3-Line Summary
- The membership requirement for registering a non-profit private organization remains 100 or more regular members under Article 2 of the “Act on Support for Non-Profit Private Organizations.” An amendment to lower this to 50 members was proposed in April 2026 and referred to the Administrative Affairs Committee subcommittee in August, but it has not yet been passed or promulgated.
- The timing of the amendment’s passage and its effective date have not been determined. If you are aiming for next year’s public subsidy applications, it is more certain to prepare according to the current registration requirements rather than waiting for the amendment.
- It is easier to have your membership recognized if the membership qualifications in the articles of association, the membership application forms, and the membership roster all match. In addition, you must apply for registration with the Si/Do (City/Province) along with proof of public interest activities for the past year and proof of office use.
Table of Contents
- A single news headline saying, “It will change to 50 people”
- Six registration requirements for non-profit private organizations and the 100 regular members
- The 50-person relaxation amendment: Where does it stand now?
- From 61 members to 104 members: Why we had to re-examine the articles of association
- One year of public interest activity performance and proof of office use
- Registration application, on-site inspection, and the registration certificate
- Scope of work for an administrative agent (administrative scrivener) office
- Checklist to review before registering a non-profit private organization
1. A single news headline saying, “It will change to 50 people”
I am an administrative agent (administrative scrivener) working in Songdo, Incheon. I would like to introduce an anecdote I encountered while working.
News of a law changing spreads much earlier than the actual date the change occurs. An email I received in early September started with such news.
The email included a screenshot of an article. The headline was “Non-profit private organization membership requirement to change from 100 to 50 people.” Below that, a question followed: “Our membership is 61 people; can we apply for registration now? We are planning to submit the documents to City Hall next week.”
The sender was a woman in her late 20s who leads a coastal cleanup volunteer group in Yeonsu-gu. During the day, she works as a researcher handling water quality samples at an environmental analysis company, and on weekends, she roams the coasts of Songdo and Namdong-gu with members to pick up trash. The group started in the spring of 2024 with a few colleagues from work, and they now hold regular activities twice a month.
The reason for rushing the registration was clear. They had been purchasing consumables such as tongs, gloves, and trash bags using membership fees and the personal money of the organizers, but as the number of participants increased, the cost per activity grew. One of the organizers mentioned that they could no longer contribute as much due to high expenses related to wedding preparations. To apply for public interest activity support projects early next year, they had to register as a non-profit private organization first.
The problem was that article. What the article covered was an amendment submitted to the National Assembly, and it was not yet a law.
2. Six registration requirements for non-profit private organizations and the 100 regular members
Registration as a non-profit private organization is not a system for creating a legal entity (both corporations and non-corporate organizations can register). It is not a system for obtaining permission, but a system where you register once you meet the registration requirements. However, you must demonstrate that you meet these requirements through documentation.
Article 2 of the “Act on Support for Non-Profit Private Organizations” stipulates the following six registration requirements for non-profit private organizations:
- The direct beneficiaries of the projects must be an unspecified large number of people.
- There must be no distribution of profits among members.
- The primary purpose must not be to support or oppose a specific political party or elected candidate, or to propagate the doctrines of a specific religion.
- There must be 100 or more regular members.
- There must be a record of public interest activities for at least the past year.
- Non-corporate organizations must have a representative or a manager.
This group had no concerns regarding items 1, 2, 3, and 6. Coastal cleanup is an activity for everyone who uses the beach, not for specific members, and all membership fees were spent on consumables and insurance premiums. The representative had also been elected according to the articles of association.
The sticking points were items 4 and 5. In particular, “regular members” in item 4 was not just a matter of counting numbers. They also examine whether the articles of association define who is a member, whether those people have actually joined, and whether their name, date of birth, address, and date of joining can be verified in the membership roster. A list of online cafe members or event participants alone provides weak evidence of regular members.
Registration is conducted in accordance with Article 4 of the “Act on Support for Non-Profit Private Organizations.” Organizations whose scope of business spans two or more Si/Do (City/Province) and have offices in two or more Si/Do must register with the central administrative agency that oversees their primary public interest activities; all other organizations must register with the Si/Do where their main office is located. Since this group’s activity area and office were both within Incheon, they were in a case where they had to apply to Incheon Metropolitan City.
3. The 50-Person Relaxation Amendment: Where Does It Stand Now?
I first checked the amendment on the day I received the email.
The article referred to the “Partial Amendment to the Non-Profit Private Organization Support Act” (Bill No. 2218183) proposed on April 8, 2026. It contained three main points: lowering the requirement for regular members from 100 or more to 50 or more, allowing operating expenses to be included in subsidies, and establishing a legal basis for the free use of state or public property.
The process was as follows: It was introduced to the Administrative and Safety Committee of the National Assembly on August 24, 2026, and was currently awaiting review by the subcommittee. As of the time of writing this post, the law has not been amended, and the current law still applies.
For an amendment to become law, it must undergo subcommittee review, a vote by the standing committee, review of the system and wording by the Legislation and Judiciary Committee, a vote by the plenary session, and promulgation. Even after promulgation, the effective date is often determined separately in the supplementary provisions of the law. The content may also change during the subcommittee stage or be merged with other bills.
I conveyed this exact information during our call. If they apply with 61 members now, there is a high possibility of rejection because it does not meet the current registration requirements, and if a record of rejection remains, it creates one more thing to explain during the next application.
There were two options.
- Waiting for the amendment: They would not need to recruit more members, but there is no way of knowing when it will happen. It is difficult to guarantee whether they can meet next year’s public recruitment schedule.
- Preparing according to current registration requirements: They would actually need to secure 100 regular members, but they can decide the date when preparations are complete.
The representative said they would think about it for a day. The reply that came the next morning was brief: “We will try to meet the 100-person requirement. However, the people who actually come with us are over 100.”
Therefore, I first verified the actual participants who were not on the membership roster.
4. From 61 Members to 104: Why I Re-examined the Articles of Association
On the scheduled day, the representative and the general manager came together. The general manager was a man in his early 30s who was in charge of the organization’s accounting and activity logs. The materials they brought were the articles of association, membership fee payment records, a folder of activity photos, and an attendance sheet recording monthly participants.
Looking at the attendance sheet, the representative was correct. There were 118 people who had participated in activities three or more times over the past year. However, there were only 61 people on the membership roster.
The cause lay in the articles of association. The articles used when the group was formed contained only one line: “Regular members shall be those who pay the annual membership fee.” Only those who paid the annual fee via bank transfer were placed on the membership roster, while those who contributed the cost of consumables in cash on-site or attended consistently without paying fees remained only as “participants.”
I decided on three tasks to be done here.
① Organizing membership qualifications in the articles of association
We changed the membership qualification to “a person who submits a membership application and receives approval from the Steering Committee,” and made the payment of membership fees a separate duty of the member. The amendment to the articles of association had to go through a resolution by the general assembly as prescribed by the articles. Since the regular general assembly was at the end of the year, we held an extraordinary general assembly two weeks later in accordance with the regulations for calling an extraordinary general assembly in the articles. We attached the attendance signature list and photos of the meeting to the minutes of the general assembly.
② Using actual dates for membership applications
We asked the people on the attendance sheet if they wished to join. During this process, the general manager made one suggestion: for those who had been attending for a long time, let’s record their join date as the date of their first activity. I did not accept this suggestion. The date the membership application is written is the join date, and if the date is backdated, it makes the entire membership roster unreliable. It was sufficient to show their activity history separately through the attendance sheets and activity logs.
③ Re-creating the membership roster
We created a new membership roster by recording the name, date of birth, address, and join date in the order that the membership applications were received. We did not include people who could not be reached or who did not wish to join. Over the course of three weeks, membership applications were collected, and the number of members reached 104.
A small incident occurred during the collection of membership applications. All the volunteer vests piled up on the workshop table were size L. One newly joined university student tried on a vest, folded the sleeves twice, and said, “This is a blanket,” and that day, “Add S/M vests” was written in the general manager’s notepad.
5. One Year of Public Interest Activity Records and Proof of Office Use
Once the issue regarding the number of members was resolved, the next step was the record of public interest activities for the past year or more.
The duration of the activities themselves was over two years, which was sufficient. However, the photo folders were only saved by date, and there were no records explaining where and what was done. In the registration documents, it is necessary to show not only the period of activity but also that the content of the activities constitutes public interest activities for an unspecified large number of people.
I created a public interest activity report by matching the activity logs written by the general manager with the dates the photos were taken. For each session, I included the date, location, number of participants, amount collected, and one representative photo. Since the general manager had records of the amount collected using a portable scale each time, I transferred those details as they were. For the two beach cleanup events conducted with the District Office, I attached the official notice from the District Office.
The office also had to be addressed. The address of the group had been the studio apartment where the representative lived. If a residential space is used as an office, it is difficult to have it recognized as a group office during an on-site inspection. Coincidentally, one of the members was running a woodworking workshop in Yeonsu-gu, so we decided to use a desk and a cabinet in a corner of the workshop as the group’s office space. I obtained a Letter of Consent for Use from the workshop operator and moved the group’s supplies there so that it would become a space actually in use. This was because it is difficult to explain during an on-site inspection if only the address on paper has been changed.
6. Registration Application, On-site Inspection, and the Certificate
The documents were prepared as follows:
- Application for Registration of Non-profit Private Organization
- Articles of Association (amended articles, with official seals on each page)
- Minutes of the Extraordinary General Meeting (including the signature list of attendees and photos) and Minutes of the General Meeting from the previous year
- Business Plan, Income and Expenditure Budget for the current and previous years, and Financial Statements from the previous year
- Organization Profile and Public Interest Activity Report
- Member List (104 people) and copies of Membership Applications
- Letter of Consent for Use of Office
For the Income and Expenditure Budget, I reorganized the existing ledger—which previously only recorded membership fee income and expenses for consumables and insurance—into specific categories. Since the budget and financial statements must match the same criteria if the group receives subsidies from public contests next year, I established categories from the beginning: consumables, safety equipment, volunteer insurance, and promotional materials.
In the last week of September, we applied for registration with Incheon Metropolitan City. After the application, the officer in charge visited the workshop for an on-site inspection and verified the tongs, vests, and original activity logs organized in the cabinet. They also randomly selected several people from the member list to verify the original membership applications. The fact that the dates had been recorded accurately was confirmed on the spot.
The processing period is within 20 days, including the on-site inspection. On the 18th day of the application, the registration certificate was issued without any requests for supplementation.
On the day the certificate was received, I added one more thing to the representative. Even after registration, the group must continuously maintain the requirements for permanent members and public interest activities, and if the name, representative, location, or main business changes, an application for change of registration must be filed. Once the amendment is passed, the new standards can be checked again at that time.
7. Scope of Work at the Administrative Agent Office
Registration of a non-profit private organization may not seem to require many documents, but the Articles of Association, Member List, General Meeting Minutes, and Activity Reports must all align with one another. In this case, the problem was not the number of members, but a single line in the Articles of Association.
Hwang Yunsang Administrative Agent Office performs the following tasks regarding the registration of non-profit private organizations:
- Preliminary inspection of registration requirements (permanent members, public interest activity records, office)
- Drafting of amended Articles of Association and General Meeting Minutes
- Organizing Member Lists and Membership Application forms
- Drafting Business Plans, Income and Expenditure Budgets, Financial Statements, Organization Profiles, and Public Interest Activity Reports
- Drafting and submitting registration applications, and preparation for on-site inspections
- Application for change of registration due to changes in name, representative, or location after registration
Regarding matters that have not yet been finalized, such as proposed amendments to laws and regulations, we provide guidance based only on the current stage. Since whether registration requirements are met varies by case, individual verification is required.
8. Checklist Before Registering as a Non-Profit Private Organization
Even the week after the registration certificate was issued, the group went out to the coast as usual. The only things that had changed were that there were now three different vest sizes and that next year’s public contest schedule had been posted on the general manager’s desk.
While news of legal amendments is welcome, it takes time for an amendment to become law. The preparations you can make while waiting are the same as they are under the current standards.
If you are preparing to register as a non-profit private organization, please check the following first:
- Distinguish between the amendment and current laws: The relaxation to 50 members is an amendment currently under review by the National Assembly. If you apply now, the standard of 100 or more permanent members will apply.
- Membership qualifications in the bylaws: Check whether the membership qualifications stipulated in the bylaws match the actual membership roster. If you have defined members solely by the payment of dues, there may be a discrepancy with the actual number of active participants.
- Use actual dates for joining dates: The joining dates on the membership application forms and the membership roster must be the actual dates they were written. Activity history should be demonstrated separately through attendance sheets and activity logs.
- Public interest activity performance for the last year or more: Match your performance reports—which include the date, location, number of participants, and content—with your photographs.
- Proof of office use: Instead of residential spaces, prepare an actual office space being used and a letter of consent for use.
If you are someone preparing for the registration of a volunteer group or a civic organization in Incheon or Songdo as a non-profit private organization, please ensure your bylaws and membership roster match before submitting your documents.
If you are curious about a similar situation, please feel free to leave an inquiry.
This has been reconstructed to aid understanding and is not related to any specific person or event.
