2020 Report on International Religious Freedom


The constitution provides for freedom of conscience and religion, prohibits discrimination  based on religion, and mandates the separation of the activities of state and religious  institutions. The law requires religious institutions to register with authorities but provides  little detail on registration procedures, leaving most specifics of implementation to local  authorities. The law prohibits hindering the free exercise of faith but limits proselytization.  Some Christian and Buddhist groups reported continued difficulties or extended delays in  some localities obtaining and renewing registration or obtaining religious visas, due in part  to differing registration guidelines among provinces, uncertain registration practices,  frequent staffing changes, and the requirement for each branch (or place of worship) of a  religious group to register separately. Registration authorities in several localities  acknowledged these difficulties and delays, which they variously attributed to guidance  reportedly issued by the National Security Council or the delayed promulgation of planned  updates to the religion law that would provide greater clarity on registration and renewal  procedures for religious organizations. The registration renewal application of a Jehovah’s  Witnesses branch in the Ulaanbaatar district of Nalaikh remained pending, despite a 2017  court decision rejecting the city council’s argument that the congregation posed a potential  threat to national security. The Office of the President eliminated the position of advisor to  the President on cultural and religious policy in August, citing concerns it was inconsistent  with the constitutional separation of state and religious institutions. The previous incumbent  had made a number of public statements against “foreign” faiths.

Some religious groups expressed concern regarding television programs, including at least  one on Mongolian National Public Television, that took a negative tone toward “foreign”  religious groups, which is generally understood to refer to non-Buddhist and non-Shamanist  groups, many of which are Christian. In the early days of the COVID-19 pandemic, news of the virus’ spread among members of a South Korean Christian congregation received widespread media coverage, prompting an increase in negative social media comments  regarding foreign religious groups.

U.S. embassy officials discussed religious freedom concerns, including the renewal of  religious visas and the registration and renewal difficulties faced by religious groups, with  high level officials in the Office of the President, Ministry of Foreign Affairs, Ministry of  Justice and Home Affairs, parliamentarians, provincial governments, and the Ulaanbaatar  City Council. The Ambassador and embassy officials met regularly with religious leaders in  Ulaanbaatar to discuss religious freedom and tolerance and the impact of COVID-19  restrictions on their communities. The Ambassador met with religious leaders in Uvs and  Bayan-Ulgii Provinces in August, and an embassy official held a similar meeting in Khentii  Province in May, for interfaith discussions on the status of religious freedom in rural areas.  The embassy also regularly promoted religious freedom on social media.

Section I. Religious Demography

The U.S. government estimates the total population at 3.2 million. The national census  conducted in January reports that 59.4 percent of individuals who are 15 and older identify  as religious while 40.6 percent state they have no religious identity. Of those who  expressed a religious identity, 87.1 percent identify as Buddhist, 5.4 percent as Muslim, 4.2  percent as Shamanist, 2.2 percent as Christian, and 1.1 percent as followers of other  religions. The majority of Buddhists are Mahayana Buddhists. Many individuals practice  elements of shamanism in combination with other religions, particularly Buddhism. The  majority of Christians are Protestant; other Christian groups in the country include The  Church of Jesus Christ of Latter-day Saints, the Roman Catholic Church, Jehovah’s  Witnesses, the Russian Orthodox Church, and the Family Federation for World Peace and  Unification (Unification Church). Other religious groups, including the Baha’i Faith, also  have a presence. The ethnic Kazakh community, located primarily in the far west, is  majority Muslim.

Section II. Status of Government Respect for Religious Freedom LEGAL FRAMEWORK 

The constitution lists freedom of conscience and religion among the enumerated rights and  freedoms guaranteed to citizens. The constitution prohibits discrimination based on religion.  It prohibits the state from engaging in religious activity and religious institutions from  pursuing political activities. The constitution specifies that the relationship between the state  and religious institutions shall be regulated by law. The constitution provides that, in  exercising their rights, persons “shall not infringe on the national security, rights, and  freedoms of others or violate public order.” It further provides that the state shall respect all  religions, and religions shall honor the state. The law says that the state shall respect “the  dominant position of Buddhism” in the country “in order to respect and uphold the traditions  of the unity and civilization of the people.” It furthers states, “This shall not prevent citizens  from following other religions.”

In accordance with the criminal code, if an individual is found to have used or threatened  the use of force to hinder the activities or rituals of religious organizations, the individual is  subject to a fine, ranging from 450,000 to 2.7 million tugriks ($160-$950), a community  service obligation of 240-720 hours, or a travel ban ranging from one to six months. If a  religious organization or religious representative, such as a priest, minister, imam, monk, or  shaman, is found to have committed acts of proselytization through force, pressure, or  deception, or to have spread “cruel” religious ideology, the law allows for fines ranging from  450,000 to 5.4 million tugriks ($160-$1,900), a travel ban ranging from six to 12 months, or  six to 12 months’ imprisonment. The law does not define what constitutes “cruel” religious  ideology.

The law on petty offenses provides for fines of 100,000 tugriks ($35) for individuals and one  million tugriks ($350) for legal entities for recruiting children to religion against their will. The  law provides for a fine of 100,000 tugriks ($35) for individuals and one million tugriks ($350)  for any legal entity for disclosing an individual’s religion on identity documents without that person’s consent or for interfering with the internal affairs of a religious organization unless  otherwise allowed by law. The law also provides for a fine of 150,000 tugriks ($53) for  individuals and 1.5 million tugriks ($530) for legal religious entities for conducting  government or political activity or financing any such activity. The law specifies a fine of  300,000 tugriks ($110) for individuals and three million tugriks ($1,100) for legal entities for  organizing religious training or gatherings on public premises, including schools.

The religion law forbids the spread of religious views by “force, pressure, material  incentives, deception, or means that harm health or morals or are psychologically  damaging.” It also prohibits the use of gifts for religious recruitment. The law on children’s  rights provides children the freedom to practice their faith.

The religion law prohibits religious groups from undertaking activities that “are inhumane or  dangerous to the tradition and culture of the people of Mongolia.”

Religious groups must register with local and provincial authorities, as well as with the  General Authority for State Registration (General Authority), to function legally. National law  provides little detail on registration procedures and does not stipulate the duration of registration, allowing local and provincial authorities to set their own rules. Religious groups  must renew their registrations (in most cases annually) with multiple government institutions  across local, provincial, and national levels. Each individual branch (or place of worship) of  a religious organization is required to register or renew as an independent legal entity,  regardless of any affiliation with a registered parent organization. Some local authorities  require children under the age of 16 to have written parental permission to participate in  church activities.

A religious group must provide the following documentation to the relevant local provincial  or municipal representative assembly when applying for registration: a letter requesting  registration, a letter from the lower-level local authority granting approval to conduct  religious services, a brief description of the group, the group’s charter, documentation on  the group’s founding, a list of leaders, financial information, a declaration of assets (including any real estate owned), a lease or rental agreement (if applicable), brief  biographic information on individuals wishing to conduct religious services, and the  expected number of worshippers. A religious group must provide the General Authority its  approved registration application to receive a certificate for operation.

The renewal process requires a religious group to obtain a reference letter from the lower level local authority to be submitted with the required documents (updated as necessary),  to the local provincial or municipal representative assembly. During the renewal process,  the local provincial or municipal representatives commonly request a safety inspection of the religious organization’s offices and places of worship and remediation of any  deficiencies found. The relevant provincial or municipal representative assembly issues a  resolution granting the religious institution permission to continue operations, and the  organization sends a copy of the approved registration renewal to the General Authority,  which enters the new validity dates on the religious institution’s certificate for operation.

Public and private educational institutions are entitled to state funding for their secular  curricula but are prohibited from using state funding for religious curricula. The education  law prohibits all educational institutions from conducting any religious training, rituals, or  activities with state-provided funding. A provincial or municipal representative assembly  may deny registration renewals for religious groups that violate the ban on using state  funding for the provision of religious instruction in educational institutions.

The law regulating civil and military service specifies that all male citizens between ages 18  and 25 must complete one year of compulsory military service. The law provides for  alternatives to military service for citizens who submit an objection based on ethical or  religious grounds. Alternative service with the Border Forces, National Emergency  Management Agency, or a humanitarian organization is available to those who submit an  ethical or religious objection. There is also a provision for paying the cost of one year’s  training and upkeep for a soldier in lieu of service.

The law regulating the legal status of foreign nationals prohibits noncitizens from  advertising, promoting, or practicing “inhumane” religions that could damage the national  culture. The religion law includes a similar prohibition on religious institutions, both foreign  and domestic, conducting “inhumane” or culturally damaging activities within the country.

Foreigners seeking to conduct religious activities, including proselytizing, must obtain  religious visas, and all foreigners are prohibited from proselytizing, promoting, and  practicing religion that violates the “national culture” and law. Only registered religious  groups may sponsor foreigners for religious visas. Foreigners who enter on other classes of  visas are not allowed to undertake activities that advertise or promote any religion (as distinct from personal worship or other individual religious activity, which is permitted).  Under the law, “Engag[ing] in business other than one’s purpose for coming” constitutes  grounds for deportation.

The country is a party to the International Covenant on Civil and Political Rights. GOVERNMENT PRACTICES 

The government again did not submit to parliament planned updates to the religion law.  According to observers, the government was primarily focused on amending the legal code  to ensure consistency with constitutional amendments adopted in 2019 as well as on  parliamentary elections in June and local elections in October. According to its concept  note, the stated intent of the amendments was to improve the monitoring, registration,  renewal systems, and accountability mechanisms of religious institutions. The lack of an  updated religion law was cited by some religious registration authorities as a reason for  their failure to process new registration applications submitted by religious groups.

Representatives of several religious groups, including Christian and Buddhist groups,  stated that government authorities were not processing new registration applications,  although some renewals were processed. Registration and renewal procedures continued  to vary significantly across the country, largely depending upon the practices of local government officials. Registration delays could hurt a group’s ability to employ foreign  religious workers, as valid registration is required to sponsor a religious worker.

The Ulaanbaatar City Council continued to issue renewals valid for one year, but some  organizations complained of prolonged delays in the processing of their renewal  application, and the Ulaanbaatar City Council said approximately 30 such applications  remained pending as of November. Some provincial and municipal representative  assemblies issued renewals for two or three years. An Ulaanbaatar City Council official said  Christian groups constituted the majority of those seeking registration and renewal.  Christian leaders stated the difficulty in obtaining visas for religious workers was mainly due  to delays in the processing of their respective organization’s renewal.

Some religious groups again said they were deterred from registering because of the  unpredictability of the registration process, which could take from several weeks to years;  the difficulty and expense of establishing a dedicated, regular worship site; and changing  government personnel. They said the requirement that each local branch of the  organization separately register or renew as independent legal entities separate from their  parent organization created additional bureaucratic burdens.

Ulaanbaatar City Council officials said the government used the registration and renewal  process to assess the activities of the religious group, monitor the number of places of  worship and clergy, determine the ratio of foreigners to nationals conducting religious  activities, and determine whether their facilities met safety requirements. City council  officials said approval of applications that were ostensibly “denied,” were more accurately  “postponed” due to incomplete documentation, the poor physical condition of the place of  worship, instances of a religious organization’s providing English-language instruction  without an educational permit, or the existence of financial issues, such as failure to pay  property taxes or declare funding from foreign sources. In such cases, religious  organizations were instructed to correct the deficiencies and resubmit their applications.  Some Christian groups continued to say the government inconsistently applied and  interpreted regulations, changing procedures frequently and without notice. Some religious groups continued to state the registration and renewal process was arbitrary in some  instances and that the prolonged delays gave them no appeal mechanism.

Some Christian religious leaders said temporary unregistered status could leave their  organizations vulnerable to financial audit and possible legal action. Several groups  reported they continued to operate normally, despite the fact that their renewal applications  remained pending.

Shamanist leaders expressed concerns that the requirement for a registered place of  worship placed limitations on their religion because of its practice of worshipping outdoors.

Unregistered churches lacked official documents establishing themselves as legal entities  and as a result could not own or lease land, file tax returns, or formally interact with the  government. Individual members of unregistered churches typically continued to own or  lease property for church use in their personal capacity. According to one nongovernmental  organization (NGO), the inability of unregistered churches to report donations from their  members as income led to financial disputes. Some unregistered religious groups said they  often could still function, although some reported experiencing frequent visits by local tax  officials, police, and representatives from other agencies.

In September, the General Authority issued a notice suspending the registration of a large  number of legal entities registered in Ulaanbaatar deemed by the Ulaanbaatar City Council  to have violated the law, including 124 religious organizations. According to an NGO, some  of those religious organizations had failed to submit their registration renewal paperwork on time or had ceased or suspended operations. The suspended faith organizations included  Buddhist, Christian, and Shamanist groups.

According to a Christian group, in April, the Darkhan-Uul Provincial Council suspended the  registration of six Christian churches for failure to complete timely renewal of their expired  registrations. The lapses were discovered during inspections conducted to ensure the  churches’ compliance with State Emergency Commission pandemic-related health and sanitation guidelines. Two of the churches successfully challenged their suspension in a  local court and were again operating normally at year’s end, although their renewals were  still pending.

The Office of the President eliminated the position of advisor to the President on cultural  and religious policy, citing concerns it was inconsistent with the constitutional separation of  state and religious institutions. Prior to the elimination of the position, the incumbent made  several statements considered discriminatory regarding “foreign” religions in press opinion  pieces, social media, and nationally broadcast television appearances. Her statements  were challenged by observers, some of whom noted her attempts to link the country’s ties  to democracies such as the United States with the growth of “foreign” religions, which, she  said, degraded Mongolia’s Buddhist heritage. Some laypersons and members of the  country’s faith communities also privately expressed concerns regarding the advisor’s  statements.

One Christian group said the government placed additional burdens on religious  organizations by subjecting them to closer scrutiny by official organs, such as the General  Authority for Labor and Benefit, the Immigration Agency, or the Ulaanbaatar City Council.  The group reported it submitted a fresh renewal application in March on the advice of the  city council; the application remained pending at year’s end. Other religious organizations  reported they had good relationships with local and district level authorities, but that lack of  understanding of regulations governing religious organizations among some Ulaanbaatar  City Council officials and provincial authorities resulted in delayed processing of registration  and renewal applications.

Representatives of the Religious Society of Jehovah’s Witnesses in Mongolia reported that  the registration application for the Evangelizers of Good News of Holy Scriptures – their  organization’s legal entity in Ulaanbaatar’s Nalaikh District – remained pending with the  Ulaanbaatar City Council, despite a 2017 Ulaanbaatar Court of First Instance ruling that  struck down the city council’s argument that the congregation posed a potential threat to national security. Although the city council revoked its decision to annul the group’s  registration, it took no action to renew it.

The Immigration Agency rescinded the registration of a U.S.-based Christian NGO after  determining that it violated its registered purpose of business by failing to carry out sufficient  charity activities to be considered a humanitarian organization. The NGO stated it  conducted such activities openly and transparently for several years and noted the law  provides no mechanism for registering as a legal entity a humanitarian organization that is  Christian but does not hold religious services. The NGO did not appeal the Immigration  Agency’s decision and commenced winding down its operations.

Religious groups continued to experience periodic audits, usually by officers from tax,  immigration, local government, intelligence, and other agencies. Religious leaders said  such audits typically took place once in a two-year period, but some inspection visits  reportedly followed routine submissions of registration renewal applications. However,  several groups reported additional inspections from government officials who cited the  need to ensure compliance with restrictions adopted in connection with the heightened  state of emergency preparedness. Inspections varied from professional and cordial to  intimidating, according to representatives of religious groups. Some religious groups  reported that inspectors made inappropriate requests, such as asking for the names of  members or requiring that security cameras be installed at their offices and places of  worship. Some groups characterized these requests as a form of harassment.

Some Christian groups reported that some local authorities continued to restrict  unaccompanied minors’ participation in Christian religious services due to stated fears of  “brainwashing.” Children under the age of 16 required written parental permission to  participate in church activities. Churches were required to retain this permission in church  records and make it available upon request. According to the groups, this requirement had  greater impact on Christian than other religious groups.

Some foreign nationals continued to face difficulties obtaining religious visas. Because  religious groups were bound by the requirement they hire at least five local employees  before they could sponsor their first foreign worker, groups that could not afford to hire  enough local employees could not sponsor even their first religious visa, nor additional  ones. Christian groups reported foreign missionaries seeking to enter the country often did so under nonreligious visas (such as student, teacher, or business visas), making them  legally restricted from conducting activities allowed under religious visas. Inconsistent  interpretations of the activities in which they could legally engage left them vulnerable to  deportation, although there were no known instances of this happening during the year.  The validity of religious visas remained linked to a religious organization’s registration,  which some Christian religious groups said resulted in additional visa problems. Foreign  citizens could not receive or renew a religious visa unless their religious organization’s  registration or renewal was already granted. The length of the religious visa’s validity  corresponded with, and could not exceed, the registration validity of its sponsoring  organization. COVID-19-related border closures also created challenges for religious  groups seeking to sponsor foreign religious workers.

According to a representative of the Asia-Pacific Association of Jehovah’s Witnesses, the  legal provision allowing citizens who have ethical or religious objections to military service  to carry out alternative civilian service was insufficient, as the alternative service requires participation in a two-week drill organized by the military leadership of the relevant locality.  Another alternative to mandatory military service was to pay the equivalent of the costs  associated with one year’s training and upkeep for one soldier, an excessive financial  burden beyond the means of most of its members, the association stated.

In January, the national broadcaster, Mongolian National Public Television, aired a two-part  program entitled “Silent Danger” that questioned the intentions of foreign religious groups  and hinted at possible illegalities relating to their activities, registration, financing, and  ownership. Ostensibly raising awareness of the dangers posed by cults and religions that  engage in “inhumane activities,” the program called for a revision of the existing religious  law and tighter government control over religious affairs.

The government continued to allocate funding for the restoration of several Buddhist sites  that it stated were important religious, historical, and cultural centers.

Section III. Status of Societal Respect for Religious Freedom

There were instances of negative popular sentiment toward “foreign” religious groups, a  term sometimes used to refer to non-Buddhist and non-Shamanist religious groups, many  of which are Christian, but religious leaders from a variety of faiths reported they generally  encountered little difficulty practicing their religion. As news of the pandemic spread,  several Christian groups reported an increase in negative comments on social media  broadly directed against Christian groups and the alleged threat they posed to society  through congregant worship. An example of a Christian congregation in South Korea that  experienced a spike in COVID-19 cases was widely covered by local media.

Christian groups also expressed concern regarding television programs that featured  negative messages regarding non-Buddhist religions.

Section IV. U.S. Government Policy and Engagement

The Ambassador and other embassy officials regularly discussed religious freedom with  government officials and shared the U.S. government’s concerns regarding visa,  registration, and renewal difficulties religious groups reported at the national, local, and  provincial levels. During such meetings, they regularly raised concerns regarding pending  amendments to the religion law. The Ambassador and other embassy officers encouraged  officials to enhance efforts to protect religious freedom and underscored the value of  dialogue between the government and religious communities during meetings with  parliamentarians, and high level officials in the President’s Office, the Ministry of Foreign  Affairs, the Ministry of Justice and Home Affairs, the Ulaanbaatar City Council, and  provincial and municipal governments. For example, the Ambassador met in June with the  Ulaanbaatar City Council chairman to raise concerns regarding the registration delays experienced by several religious groups. A few days after the meeting, some religious  organizations reported that their renewals had been approved.

The Ambassador routinely visited religious sites and temples and met with local religious  leaders in his travels outside Ulaanbaatar. For example, in August, the Ambassador met  with local Buddhist, Christian, Muslim, and Shaman leaders in Uvs Province for an interfaith  discussion on the status of religious freedom in rural areas. He also met in August with  Muslim leaders in Bayan-Ulgii Province to discuss the state of religious freedom in the  country’s only majority-Muslim province. In July, the Ambassador hosted Buddhist leaders  to learn about how their communities were being affected by COVID-19-related restrictions.  During a June visit to Khentii Province, an embassy official discussed the importance of  religious freedom and tolerance with provincial authorities and met with local Buddhist and  Christian leaders. The embassy also regularly promoted religious freedom on social media.  For example, the Ambassador regularly tweeted in Mongolian and English about his visits  to religious sites and meetings with religious leaders across the country’s diverse faith  communities.