Case

[Associations] Non-profit Private Organization Registration in Korea: 100 Members and 1 Year of Activity — Should You Wait for the 50-Member Amendment?

October 28, 2026황윤상 행정사AI

3-Line Summary

  1. The registration requirements for a non-profit private organization remain the same under Article 2 of the “Act on Support for Non-Profit Private Organizations”: having 100 or more regular members and a track record of public interest activities for at least the past year. An amendment to lower the membership threshold to 50 people was referred to the Administrative Affairs Committee subcommittee of the National Assembly in August 2026 and has not yet been promulgated.
  2. The main contents of the proposed amendment include easing the membership number requirement and allowing subsidies to include operating expenses. Since the one-year track record requirement must be met regardless of the number of members, you must first verify your activity start date and performance data.
  3. Even if the scope of business spans across two or more cities/provinces, if the office is located in only one city/province, you register in that specific city/province. In this case, we applied to Incheon Metropolitan City and received the registration certificate in 16 days.

Table of Contents

  1. Two numbers in the statute: 100 people and 1 year
  2. The 50-person amendment: Can it be used for current applications?
  3. When does the one-year track record of public interest activities start counting?
  4. If we also hold classes in Siheung, do we register with the Ministry of the Interior and Safety?
  5. From 78 members to 106 members: Keeping the original join dates
  6. Registration application and attached documents: One request for supplementation
  7. Non-profit private organization registration checklist
  8. Scope of work for the administrative agent (administrative scrivener) office

1. Two numbers in the statute: 100 people and 1 year

I am an administrative agent (administrative scrivener) working in Songdo, Incheon. I would like to introduce the story of a volunteer group I met while handling their organization registration.

Article 2 of the “Act on Support for Non-Profit Private Organizations” contains two numbers: the number of regular members must be 100 or more, and there must be a track record of public interest activities for at least the past year. News articles only covered the first number, and this group was hardly paying attention to the second.

In the last week of August, I received an email. “I saw an article saying the membership requirement is changing to 50 people. We have 78 members, so I think we can apply immediately; could you help us prepare the documents?” The attached files included the bylaws, a member list, and several photos of their activities.

The person who sent the email was a woman in her late 20s, a graduate student majoring in Korean Language Education. Since the fall of 2025, she has been leading a group in Yeonsu-gu that provides Korean language lessons and homework help to elementary school students from multicultural families every Saturday. It started with five of her university classmates, but in less than a year, the number of children had grown to nearly 40.

The reason the group was rushing to register was money. Currently, the representative and volunteers are splitting the costs for textbooks, snacks, and small library rental fees. Local government support projects for non-profit private organizations are only available to registered organizations. The representative wanted to complete the registration before this winter break to apply for the next public recruitment.

2. The 50-person amendment: Can it be used for current applications?

First, I verified the contents of the news article. The proposal to lower the membership requirement is the “Partial Amendment to the Act on Support for Non-Profit Private Organizations” (Bill No. 2218183). It was introduced on April 8, 2026, tabled before the Administrative Affairs Committee on August 24, and referred to a subcommittee. It contains provisions to lower the requirement of 100 or more regular members to 50 or more and to allow operating expenses to be included in subsidies.

However, a bill is applied from the enforcement date specified in the supplementary provisions after it passes the plenary session of the National Assembly and is promulgated. At the time of the consultation, the current law was the same as the law that went into effect on April 27, 2023, and no subsequent amended laws had been promulgated. The agency in charge of registration reviews applications based on the law in effect on the date of application. If they apply now with 78 members, it would be an application that fails to meet the regular member requirement.

The representative asked, “Then would it be better to wait until it passes?” I compared two options for her.

  • If waiting for the amendment: Neither the timing of the passage nor the enforcement date has been determined. Whether it will be implemented immediately upon promulgation or several months later can only be known by looking at the supplementary provisions.
  • If preparing based on current requirements: They simply need to gather 22 more members and prepare the track record data. The group can decide the schedule themselves.

The representative decided to prepare based on the current requirements. To complete the registration before the next public recruitment, they needed a schedule they could control, rather than the uncertain schedule of the National Assembly.

3. When do you start counting the one-year period for public interest activity performance?

Before checking the number of members, I first checked the date. At the very end of the Articles of Association, it stated, “Enacted at the Inaugural General Meeting on September 27, 2025.” The date of the consultation was Tuesday, September 1, 2026. Even based on the Inaugural General Meeting, it had not yet been one year.

The representative was not surprised. “We have performance records from before we were officially established. We held several classes during last summer vacation as well.” However, looking at the materials from those summer classes, the applicant for the venue reservation was the representative’s personal name, and the class announcements remained in personal messenger chatrooms. It was a time when there was neither a group name nor Articles of Association.

A judgment was required here. If we include personal volunteer work performed before establishment as the organization’s performance, the performance period becomes longer; however, whether the registration authority views this as the organization’s activity depends on the documentation. If we lead with lengthy explanations, the review period may also be extended.

Therefore, I set the reference date as Saturday, October 4, 2025. This was the day they held their first regular class after receiving a small library venue reservation under the group’s name, on the Saturday following the Inaugural General Meeting. From this day forward, venue reservation confirmation texts, attendance sheets, class photos, and membership fee deposit records were all kept under the group’s name. Once October 4, 2026, passed, they would be able to complete one year using only the performance records under the organization’s name.

Instead of discarding the summer classes held before establishment, I wrote them in the history section of the organization’s introduction as “Preparatory Activities for Establishment.” This is a method of showing them only as the background of how the group was formed, rather than using them as the standard for performance.

4. If we hold classes in Siheung as well, do we register with the Ministry of the Interior and Safety?

The representative brought up the second issue first. Since this spring, they had opened a Saturday afternoon class at a small library in Baegot, Siheung, and since their activity area now spanned two locations—Incheon and Gyeonggi—the representative asked whether they needed to register with the Ministry of the Interior and Safety.

Registration for Non-profit Private Organizations is conducted in accordance with Article 4 of the same Act and Article 3 of the Enforcement Decree. According to Article 3 of the Enforcement Decree, an organization whose scope of business spans two or more cities/provinces and has offices in two or more cities/provinces must register with the central administrative agency that oversees its primary public interest activities; other organizations register with the city/province where their main office is located. An organization must meet both conditions to be subject to registration with a central administrative agency.

This group’s office was located only in Yeonsu-gu. The Siheung class only held classes in the reserved space, while all document storage and meetings were conducted in Yeonsu-gu. Even though the scope of business spanned two cities/provinces, because the office was only in Incheon, the registration authority was Incheon Metropolitan City.

However, I did not hide the Siheung class in the business plan and wrote it as it was. This is because if actual activities differ from the documents, problems may arise later during the settlement of government subsidy projects. I also informed the representative that if they were to establish a separate office in Siheung in the future, they would need to re-verify the registration authority.

5. From 78 members to 106 members, keeping the actual joining dates

What remained was the 22 regular members. Upon reviewing the membership list again, among the 78 members, 9 had not been active for nearly a year due to becoming directors or graduating, and they could not be reached. If we apply while leaving them on the list, the credibility of the membership roster will decrease. The representative sent messages to these 9 people to confirm their intention to withdraw; those who did not respond or stated they would withdraw were removed from the roster. The starting point became 69 members.

This time, 31 more were needed. Before starting the recruitment, the representative and I verified the criteria for members recognized as regular members.

  1. People who have undergone the joining procedures stipulated in the Articles of Association: The group’s Articles of Association stipulated the submission of a membership application and approval by the Steering Committee as the joining procedure.
  2. People whose joining date is the actual date: One does not write last year’s date on an application for someone joining in September.
  3. People whose name, date of birth, address, and joining date can be verified on the membership roster: Participant lists for events or the number of people in a chatroom are weak forms of evidence.

The group sent the Articles of Association and membership applications to university students who had been consistently volunteering, parents who had observed the classes, and supporters who sent small monthly amounts. Among the parents, there were several mothers from multicultural families. As of Wednesday, September 30, 37 membership applications were received, and after passing through the Steering Committee’s approval, the membership roster reached 106 people.

A small incident occurred around this time. A second-grade child drew a face of a volunteer on the back of their mother’s membership application along with the words, “Thank you, teachers.” Since it was difficult to submit as a formal document, a photocopy was made separately, and the original with the drawing was posted on the group’s bulletin board.

6. Registration Application, Attached Documents, and One Request for Supplementation

On October 6 (Tuesday), after the performance reference date of October 4, we applied for registration with Incheon Metropolitan City. The submitted documents were as follows:

DocumentDetails Verified in This Case
Application for Registration of Non-Profit Private Organization (Statutory Form)Representative, office location, and primary business activities
Articles of AssociationMembership procedures, rights and obligations of members, and clauses prohibiting profit distribution
Minutes of General Assembly2025 Founding General Assembly, 2026 Regular General Assembly
Business Plan and Income/Expenditure BudgetIncluded both Ban and Si-heung in Yeonsu-gu
Financial Statements for the Previous YearMembership fees and expenditures from September to December 2025
Organization ProfileHistory, summary of one-year performance, and activities in preparation for establishment
Membership Roster106 members, with actual dates of joining recorded

The one-year performance record was compiled separately as a performance report. We created a monthly table listing the class dates every Saturday, the number of participating children, and the number of volunteers, and attached one rental confirmation text message and one class photo for each month. Out of the 52 weeks, there were no classes during the two weeks of the Lunar New Year holiday and one week when the library was closed; we also noted these reasons in the table. This was because leaving empty weeks would lead to separate inquiries during the review process.

One week after the application, we received one request for supplementation. The issue was that the approval by the General Assembly was not evident in the financial statements for the previous year. Since the agenda for approving the financial statements was included in the minutes of the 2026 Regular General Assembly, we attached the relevant page behind the financial statements and submitted a one-page explanation stating that the amounts in the minutes and the financial statements were identical. The registration certificate was issued on October 22 (Thursday).

7. Non-Profit Private Organization Registration Checklist

If you are an organization considering registration after hearing news about the amendment, please check the following in order:

  • Application for Registration of Non-Profit Private Organization (Statutory Form): Prepare using the form of the competent Si/Do (Metropolitan City/Province) or central administrative agency.
  • 100 or More Regular Members: Verify if members have gone through the membership procedures in the Articles of Association and if the actual dates of joining are recorded in the membership roster.
  • Public Interest Activity Performance for at least the Last Year: The date of the first activity conducted under the organization’s name, activity records by date, and supporting evidence.
  • Registration Authority: The number of Si/Dos where the office is located (this does not apply if the scope of business is simply wide).
  • Accounting Documents: Ensure that the financial statements for the previous year and the records of General Assembly approval match.
  • Progress of the Amendment: Whether it has passed the National Assembly and been promulgated, and the effective date of the supplementary provisions.

The criteria for the number of members in a non-profit private organization and the review progress of the amendment were also covered in the previous post: [Will the non-profit private organization registration member requirement change to 50? The 100-person requirement and the status of the amendment review]. Since the interpretation of requirements can vary depending on the organization’s Articles of Association and method of operation, individual verification is required for each case.

8. Scope of Work for the Administrative Agent Office

Hwang Yunsang Administrative Agent Office provides the following services regarding the registration of non-profit private organizations:

  • Review of fulfillment of registration requirements (regular members, public interest activity performance, registration authority)
  • Guidance on organizing Articles of Association, General Assembly minutes, and membership rosters
  • Preparation of registration applications, business plans, organization profiles, and performance reports
  • Acting as a proxy for submission to competent authorities and responding to requests for supplementation

On the Saturday of the week the registration certificate was issued, the representative sent me a photo of a class. A copy of the registration certificate was posted next to the blackboard, and children were practicing dictation in front of it. The group is currently waiting for the next public recruitment announcement. Regardless of whether the amendment passes or not, this group will never have to revise its documents again.

This content has been reconstructed for better understanding and is not related to any specific person or event.

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