On March 1, 2022, the “Administrative Measures for Internet Religious Information Services”, published in December last year, officially came into effect. All provinces and cities across China successively made notifications, tests, and issued certificates. Particularly in Guangdong, Zhejiang, and other developed regions in the economy and information technology, the progress was faster. Different legal organizations such as religious groups, religious venues, religious colleges, and companies have obtained Internet religious information service licenses.
Brother Xie, Hu, and Liu are all Christian professionals who have been engaged in IT technology for many years. A few days ago, they had a technical dialogue and explained their understanding of some terms in the Measures, and gave suggestions on how the churches should be responded to the Measures with the Christian Times, an online Chinese Christian newspaper.
Christian Times: Brother Xie, would you please share with us the essence of the “Administrative Measures for Internet Religious Information Services”?
Brother Xie: The “Administrative Measures for Internet Religious Information Services” jointly issued by multiple ministries and commissions is a detailed system aiming at the particularity of religious content. The superior legislation is the "Administrative Measures for Internet Information Services." Contents such as domain name filing, information security, and real-name authentication are not mentioned in the Measures but are detailed in the upper-level law, which must be complied with first.
Concerning the contents, we should pay special attention to several key points. For example, Article 6 stipulates that the license should be obtained for providing information about religious teachings, religious knowledge, religious culture, and religious activities to the public in the form of texts, pictures, audios, and videos through internet websites, application programs, forums, blogs, micro-blogs, official accounts, instant messengers and live webcasts.
There are different understandings in this article. Several points must be clarified:
First, religious information can be spread to the public;
Second, the contents must be the information about religious knowledge, religious culture, and religious activities (note that it is not religious activities, nor preaching classics, but the information). It can be understood as "information that can be communicated under the license". The communication platform must also obtain an Internet religious information service license.
Another key point is Articles 15 to 17:
Article 15 The religious groups, religious colleges and temples, and churches that have obtained the license for Internet Religious Information Service can and only can have religious staff and teachers of religious colleges and universities teaching and sermon through their self-built websites, Apps, forums, etc., to explain the contents of doctrines and regulations that are conducive to social harmony, the progress of the times, health and civilization, and guide religious citizens to be patriotic and law-abiding. Participants in lectures and sermons are authenticated with their real names.
Article 16 Religious colleges and universities that have obtained the license can only carry out religious education and training for students and religious staff in religious colleges and universities through their self-built dedicated websites, Apps, forums, etc. Dedicated websites, Apps, forums, etc. must be connected by the virtual private network, and the identity of the personnel participating in education and training should be verified.
This means that even after obtaining the license, you are not necessarily allowed to do missionary work, lecture, preach or develop more believers online. Article 15 stipulates "... can and only can have religious staff and teachers of religious colleges and universities teaching and sermon through their self-built websites, Apps, forums, etc."
That means after obtaining the license, religious institutions, religious groups, and churches must give lectures and conduct training courses on self-built online platforms. Article 15 and 16 make it clear that both the sender and the receiver of the content need to be authenticated.
Article 17 further clearly states that for the Christian church, worship, praise, fellowship, preaching, and lessons are all regulated.
Article 18 and Article 19 are also very strict regulations. Article 18 says, “No organization or individual may set up religious organizations, religious colleges, and places for religious activities, or develop believers on the Internet.”
If a newcomer comes into contact with the church through the Internet, they are developed on the internet in a strict sense. Will there be any controversy?
According to the Measures, after obtaining the license, if the church preaches through the Internet, it needs its self-built platform. The understanding of "self-built" is closely related to the IT field, but the official interpretation is not seen yet.
Christian Times: What needs to be defined as "self-built" from the system client to the hardware deployment?
Brother Hu: From my preliminary understanding, there are two obvious differences from the current general church practice.
The first point is that the church needs not only a domain name but also a certificate or license to build a website so that it can be filed.
Second, with the license, public platforms such as WeChat and WeChat official accounts can be used to publish religious-related knowledge and information. However, WeChat and Weibo platforms must also obtain the license.
Based on these two points, the point is the "self-built platform" for preaching. My understanding is as follows:
The first is that it should not be a public platform or a platform of a third party. The platform should be owned, funded, and planned by the licensee.
Second, the licensees should take responsibility for the production, review, release, and management of contents.
Third, the self-built system is defined as the virtual professional network in Article 16, which means that it can only be used by people in colleges or churches, and cannot be accessed by the public at will.
The whole religious community, such as the church, has a very low internet penetration rate at present. For example, pandemic prevention and control measures ask believers to make an appointment to go to church. If you make an appointment on the public platform of the provincial Ethnic and Religious Affairs Committee, the platform will not display the participants’ list, which would make the church unable to comply with the regulation of the local management department that the participants’ list should be provided due to the pandemic control requirements.
Besides, the churches rarely have a network office system. For example, there would be no idea of the number of priests and sermons, the idea of pastoral care, and the pastoring records five years, 10 years, or 20 years ago for a century-old church. There is no record of believers’ attendance, attending courses, spiritual growth, and changes either as they have the freedom to come and go in the church. The church has no idea and has never made records.
In medical and other fields, it is clear how many people have high blood pressure and diabetes among the elderly and people with chronic diseases in this area and whether they have had a physical examination, and also how many children in kindergartens are anemic or not up to standard in development. In the church, you may not know their names even as you meet them every day, as the church information management is seriously behind the times.
With the self-built system, these problems will be fundamentally solved, and online pastoring will become possible. It used to be done by WeChat groups, but the communication tool would still lose the previous recordings even with a high penetration rate.
The self-built platform can be maintained and managed, and it is clear who has read the content, who has attended the party, who are the believers, and how many believers have left. So there are pros and cons. It depends on how we look at it.
Brother Xie: From the user's experience, I think at least the self-built system should be an independent program and can be installed and operated independently. Second, when users log in, they reach their church, instead of having multiple hotels (churches) to choose from like Ctrip.
Brother Wei: I quite agree with your opinions, especially about the self-built system.
Christian Times: Are the churches you have come into contact with willing to build their systems?
Brother Xie: I think everyone feels the need now, but they still don't know how to do it.
Christian Times: Do you have any plans or suggestions in this regard?
Brother Xie: As IT staff believers, we have this willingness to help build their systems and be entrusted to help churches develop their programs.
Christian Times: As builders of the self-built systems, do you need to apply for a license?
Brother Xie: I don't think it is covered by the Measures. We are only providing technical services now, not operating a religious network platform. It is like the church needs to apply for religious land to build a church, but the construction company does not need a religious business license to build the church.
Christian Times: September 1 is a key date for the implementation of the Measures. If one doesn’t get a license, including third-party platforms, could they publish religious information?
Brother Xie: I think there are three levels: First, there are laws to abide by; second, the laws must be abided by, and third, those who break the law must be punished. We are now at level 1 as we have the law, but there is no way to predict whether the law should be fully complied with or if those who break the law should be punished.
- Translated by Oliver Zuo
2022年3月1日，去年12月公布的《互联网宗教信息服务管理办法》正式执行，各省市根据自己的情况陆续进行通知、考试和发放证件，尤其广东、浙江等经济和信息技术发达的地区，进展得更为快速，陆续有宗教团体、宗教场所、宗教院校和公司等不同的法人组织得到互联网宗教信息服务许可证。
谢、胡、刘三位都是从事多年IT技术工作的专业人士，同时他们都是基督徒，日前，这三位专业人士从技术的角度进行了对话，并对《互联网宗教信息服务管理办法》中的一些条目字词阐述了自己的理解，以及教会如何落地和执行给出了专业建议。
讨论内容摘录：
主持人：请谢弟兄给我们分享一下《互联网宗教信息服务管理办法》的核心要义好吗？
谢弟兄：多家部委单位联合颁发的《互联网宗教信息服务管理办法》是针对宗教内容的特殊性而细化的制度，前提是《管理办法》，比如域名备案、信息安全、实名认证等内容，虽然宗教信息服务里没有过多说明，但是其上位法，《管理办法》里规定的，首先要落实。
关于办法的内容，重点的几条大家要特别留意，比如第六条：通过互联网站、应用程序、论坛、博客、微博客、公众账号、即时通信工具、网络直播等形式，以文字、图片、音视频等方式向社会公众提供宗教教义教规、宗教知识、宗教文化、宗教活动等信息的服务，应当取得互联网宗教信息服务许可。
这一条，到目前为止每个人理解都不一样。这里面涉及到好几个点：
其一，可以向社会公众传播；
其二，传播的内容必须是宗教知识、宗教文化、宗教活动信息，（注意，不是宗教活动本身，也不是传经讲道）可以理解为“持牌传播限制的信息”，同时传播的平台也须取得互联网宗教信息服务许可。
还要一个重点是第十五条至十七条：
第十五条 取得《互联网宗教信息服务许可证》的宗教团体、宗教院校和寺观教堂，可以且仅限于通过其依法自建的互联网站、应用程序、论坛等由宗教教职人员、宗教院校教师讲经讲道，阐释教义教规中有利于社会和谐、时代进步、健康文明的内容，引导信教公民爱国守法。参与讲经讲道的人员实行实名管理。
第十六条 取得《许可证》的宗教院校，可以且仅限于通过其依法自建的专用互联网站、应用程序、论坛等开展面向宗教院校学生、宗教教职人员的宗教教育培训。专用互联网站、应用程序、论坛等对外须使用虚拟专用网络连接，并对参加教育培训的人员进行身份验证。
这意味着取得了互联网宗教信息服务许可证以后并不意味着你可以在网上进行宣教、讲经、传道、会众拓展的工作。第十五条“取得相关证件以后...可以且仅限于通过其依法自建的互联网站、应用程序、论坛等由宗教教职人员、宗教院校教师讲经讲道。”
也就是说，取得相关证件后，宗教院校、宗教团体、教会教堂必须在自建网络平台进行讲经讲道，开展培训课程。第十五条明确了内容发出者，第十六条明确了内容接收者，都需要进行身份验证。
第十七条的更清楚讲明对于基督教会而言，教会的敬拜、赞美、团契、礼拜、证道、课程应该都属于这里所说的“宗教仪式”。
后面的第十八条、第十九条也是很严格的规定。第十八条 任何组织或者个人不得在互联网上成立宗教组织、设立宗教院校和宗教活动场所、发展教徒。
如果一个新人通过网络来接触教会，严格来说就属于发展教徒，会不会存在争议？
按照办法，教会在取得互联网宗教信息服务许可证后，若通过网络来传经讲道，需要自建的平台。“自建”到底如何理解，这个与IT的相关领域有比较密切的联系，到目前还没有看到官方的解读。
谢弟兄问胡弟兄：从一个系统用户端的接触，到底层的硬件部署，有哪些层次需要进行是否“自建”的界定？
胡弟兄：
从目前初步了解的情况看，跟当前教会的一般做法两个明显的不同。
1 教会做一个网站不仅仅需要有域名，还需要有证书或者说得到许可证，才能够去备案 。
2 有了许可证可以使用微信和公众号等公用平台来发布宗教相关的知识与信息，但是，所发布的平台，比如微信、微博必须要取得互联网宗教信息服务许可。
重点是在这两点基础上，进行传经讲道的 “自建平台”。我对“自建”的理解：
第一点不是一个公用的平台、不是第三方的平台，所有权是自己的，是自己出资、自己策划的。
第二点内容产生、审核、发布、管理的责任都要担当。
第三点自建系统在第十六条限定了虚拟专业网，也就是说只有院校或教会内部的人才能使用，不是任何可以随意公开访问的。
当前整个信仰界，比如说教会拥抱互联网程度是很低的。比如说因疫情防控各地要求信徒去教会需要预约。若使用省民宗委的公共平台预约，该平台不显示预约名单，而当地管理部门又往往因疫情管控要求提供当日参加人数据。教会就很被动。
还有，教会很少看到有网络办公系统。比如教会可能有100多年了，但是它有多少牧师，讲了多少道，牧养的思想是什么？一个教会很难找到5年前、10年前、20年前的牧养记录。再比如一个信徒在教会来去自由没有记录，什么时候来、是不是经常来、参加了哪些课程，灵命从来到现在有没有成长和变化，教会无从掌握也没有记录。
而其他领域，比如医疗领域，这个辖区老年人和慢性病人群、多少人高血压、多少人糖尿病，是不是做了体检；幼儿园多少贫血，多少发育不达标，这些很清楚。教会里，可能天天见都不知道名字，教会信息化管理方面是严重落后于这个时代的。
有了自建系统，这些问题才会根本性解决，线上牧养也就成为可能。以前用微信群做，但是这是个沟通工具，信息覆盖率很高。之前辛苦的录音也会流失。
自建平台可以维护、管理内容，谁看了内容、谁参加了聚会、信徒都有谁、流失了多少，一目了然。所以有好的一面、有不好的一面。看主要是我们怎么去看待。
谢弟兄：我觉得，从用户端的感受而言，至少自建系统首先应该是一个独立的程序，是独立安装，独立运行。第二，用户登录的时候打开的是所在的教会，不是像携程那样上面有多个酒店（教会）由我来挑。
卫弟兄：我很赞同这二位的意见，特别是关于自建系统这部分。
主持人：你们所接触到的一些教会很愿意做自建系统吗？
谢弟兄： 我认为现在大家都觉得有需要，但是都还不知道怎么做。
主持人：你们在这方面有什么打算或者建议吗？
谢弟兄：我们作为主内的IT人员确实有这个心，帮助各都会自建系统，受委托帮教堂开发他们独有的程序。
主持人：作为自建系统的建设者，你们需要申请许可证吗？
谢弟兄：我觉得不属于这个办法规定的主体范围，我们现在只是技术服务，不是要做宗教网络平台。好像教会盖教堂需要去申请宗教用地，请建筑公司来建，建筑公司不需要专门的宗教业务许可证。
主持人：9.1号是办法实施的节点，如果没有得到许可证包括第三方平台就彻底不能发布宗教信息了吗？
谢弟兄：我认为有三个层次：1有法可依，2有法必依，3违法必究。目前对行业而言，至少实现了”有法可依“ ，至于第二点第三点，这个没有办法预测。
圆桌谈| 三位IT技术人员探讨:《互联网宗教信息服务管理办法》大背景下 教会如何应对网络化的挑战？
On March 1, 2022, the “Administrative Measures for Internet Religious Information Services”, published in December last year, officially came into effect. All provinces and cities across China successively made notifications, tests, and issued certificates. Particularly in Guangdong, Zhejiang, and other developed regions in the economy and information technology, the progress was faster. Different legal organizations such as religious groups, religious venues, religious colleges, and companies have obtained Internet religious information service licenses.
Brother Xie, Hu, and Liu are all Christian professionals who have been engaged in IT technology for many years. A few days ago, they had a technical dialogue and explained their understanding of some terms in the Measures, and gave suggestions on how the churches should be responded to the Measures with the Christian Times, an online Chinese Christian newspaper.
Christian Times: Brother Xie, would you please share with us the essence of the “Administrative Measures for Internet Religious Information Services”?
Brother Xie: The “Administrative Measures for Internet Religious Information Services” jointly issued by multiple ministries and commissions is a detailed system aiming at the particularity of religious content. The superior legislation is the "Administrative Measures for Internet Information Services." Contents such as domain name filing, information security, and real-name authentication are not mentioned in the Measures but are detailed in the upper-level law, which must be complied with first.
Concerning the contents, we should pay special attention to several key points. For example, Article 6 stipulates that the license should be obtained for providing information about religious teachings, religious knowledge, religious culture, and religious activities to the public in the form of texts, pictures, audios, and videos through internet websites, application programs, forums, blogs, micro-blogs, official accounts, instant messengers and live webcasts.
There are different understandings in this article. Several points must be clarified:
First, religious information can be spread to the public;
Second, the contents must be the information about religious knowledge, religious culture, and religious activities (note that it is not religious activities, nor preaching classics, but the information). It can be understood as "information that can be communicated under the license". The communication platform must also obtain an Internet religious information service license.
Another key point is Articles 15 to 17:
Article 15 The religious groups, religious colleges and temples, and churches that have obtained the license for Internet Religious Information Service can and only can have religious staff and teachers of religious colleges and universities teaching and sermon through their self-built websites, Apps, forums, etc., to explain the contents of doctrines and regulations that are conducive to social harmony, the progress of the times, health and civilization, and guide religious citizens to be patriotic and law-abiding. Participants in lectures and sermons are authenticated with their real names.
Article 16 Religious colleges and universities that have obtained the license can only carry out religious education and training for students and religious staff in religious colleges and universities through their self-built dedicated websites, Apps, forums, etc. Dedicated websites, Apps, forums, etc. must be connected by the virtual private network, and the identity of the personnel participating in education and training should be verified.
This means that even after obtaining the license, you are not necessarily allowed to do missionary work, lecture, preach or develop more believers online. Article 15 stipulates "... can and only can have religious staff and teachers of religious colleges and universities teaching and sermon through their self-built websites, Apps, forums, etc."
That means after obtaining the license, religious institutions, religious groups, and churches must give lectures and conduct training courses on self-built online platforms. Article 15 and 16 make it clear that both the sender and the receiver of the content need to be authenticated.
Article 17 further clearly states that for the Christian church, worship, praise, fellowship, preaching, and lessons are all regulated.
Article 18 and Article 19 are also very strict regulations. Article 18 says, “No organization or individual may set up religious organizations, religious colleges, and places for religious activities, or develop believers on the Internet.”
If a newcomer comes into contact with the church through the Internet, they are developed on the internet in a strict sense. Will there be any controversy?
According to the Measures, after obtaining the license, if the church preaches through the Internet, it needs its self-built platform. The understanding of "self-built" is closely related to the IT field, but the official interpretation is not seen yet.
Christian Times: What needs to be defined as "self-built" from the system client to the hardware deployment?
Brother Hu: From my preliminary understanding, there are two obvious differences from the current general church practice.
The first point is that the church needs not only a domain name but also a certificate or license to build a website so that it can be filed.
Second, with the license, public platforms such as WeChat and WeChat official accounts can be used to publish religious-related knowledge and information. However, WeChat and Weibo platforms must also obtain the license.
Based on these two points, the point is the "self-built platform" for preaching. My understanding is as follows:
The first is that it should not be a public platform or a platform of a third party. The platform should be owned, funded, and planned by the licensee.
Second, the licensees should take responsibility for the production, review, release, and management of contents.
Third, the self-built system is defined as the virtual professional network in Article 16, which means that it can only be used by people in colleges or churches, and cannot be accessed by the public at will.
The whole religious community, such as the church, has a very low internet penetration rate at present. For example, pandemic prevention and control measures ask believers to make an appointment to go to church. If you make an appointment on the public platform of the provincial Ethnic and Religious Affairs Committee, the platform will not display the participants’ list, which would make the church unable to comply with the regulation of the local management department that the participants’ list should be provided due to the pandemic control requirements.
Besides, the churches rarely have a network office system. For example, there would be no idea of the number of priests and sermons, the idea of pastoral care, and the pastoring records five years, 10 years, or 20 years ago for a century-old church. There is no record of believers’ attendance, attending courses, spiritual growth, and changes either as they have the freedom to come and go in the church. The church has no idea and has never made records.
In medical and other fields, it is clear how many people have high blood pressure and diabetes among the elderly and people with chronic diseases in this area and whether they have had a physical examination, and also how many children in kindergartens are anemic or not up to standard in development. In the church, you may not know their names even as you meet them every day, as the church information management is seriously behind the times.
With the self-built system, these problems will be fundamentally solved, and online pastoring will become possible. It used to be done by WeChat groups, but the communication tool would still lose the previous recordings even with a high penetration rate.
The self-built platform can be maintained and managed, and it is clear who has read the content, who has attended the party, who are the believers, and how many believers have left. So there are pros and cons. It depends on how we look at it.
Brother Xie: From the user's experience, I think at least the self-built system should be an independent program and can be installed and operated independently. Second, when users log in, they reach their church, instead of having multiple hotels (churches) to choose from like Ctrip.
Brother Wei: I quite agree with your opinions, especially about the self-built system.
Christian Times: Are the churches you have come into contact with willing to build their systems?
Brother Xie: I think everyone feels the need now, but they still don't know how to do it.
Christian Times: Do you have any plans or suggestions in this regard?
Brother Xie: As IT staff believers, we have this willingness to help build their systems and be entrusted to help churches develop their programs.
Christian Times: As builders of the self-built systems, do you need to apply for a license?
Brother Xie: I don't think it is covered by the Measures. We are only providing technical services now, not operating a religious network platform. It is like the church needs to apply for religious land to build a church, but the construction company does not need a religious business license to build the church.
Christian Times: September 1 is a key date for the implementation of the Measures. If one doesn’t get a license, including third-party platforms, could they publish religious information?
Brother Xie: I think there are three levels: First, there are laws to abide by; second, the laws must be abided by, and third, those who break the law must be punished. We are now at level 1 as we have the law, but there is no way to predict whether the law should be fully complied with or if those who break the law should be punished.
- Translated by Oliver Zuo
Panel: Three IT Technicians Discuss How Churches Should Respond to Online Challenges Under the Administrative Measures for Internet Religious Information Services
