Is opening a representative office necessary for developing a meaningful programme in China?
Registration as an enterprise and/or links with the MOFTEC hierarchy through FESCO or INGO Societies can confer practical benefits and a useful degree of formal recognition, but these procedures are not absolutely essential to working effectively in China, particularly if your operations are fairly small scale. If you can show that you are cooperating with a recognised Chinese agency, and if you are not doing anything that is particularly contentious or sensitive, it is unlikely that you will encounter any kind of trouble arising from not having official registration and status, apart from the practical difficulties of not being able to open a bank account in the name of the organisation. Several international NGOs operate substantial programmes in China without any formal registration status, merely reaching working agreements with government partners on a project-by-project basis. The lack of a clearly defined procedure for registration itself justifies this approach.