A bank account number appears in a messaging group, accompanied by a voice note seeking contributions for the construction of a temple. Soon, members begin transferring money and posting screenshots of their contributions.
Such informal fundraising has become increasingly common on messaging platforms such as WhatsApp, Telegram and WeChat, particularly for religious and cultural projects. But while raising money has become as simple as circulating an account number online, Bhutan’s existing rules do not recognise social media as an authorised platform for conducting donation drives.
Officials from the Commission for Religious Organization and the Department of Culture and Dzongkha Development say fundraising for religious and cultural projects requires prior approval and is subject to financial reporting and monitoring.
Despite these requirements, donation drives continue to be organised on messaging platforms without approval.
For religious projects, the Commission for Religious Organization first verifies the proposed project and its estimated cost before deciding whether to permit fundraising.
“Firstly, the project needs to have an estimated cost. Based on the estimated cost of the project, we give them approval to collect the amount. We give them a six-month period to collect the money. After the six months, we ask them to submit a report within a month on how much money has been collected,” said Sangay Dendup, Chief Programme Officer of the Commission for Religious Organization.
The Commission requires another report six months after the fundraising period to determine whether the money collected has been spent for its stated purpose. Fundraisers must also provide receipts and other financial records documenting the collection and expenditure of the funds.
Registered religious organisations are required to comply with the applicable Act, rules and regulations. Unauthorised fundraising can invite action if it is reported to the Commission.
“If a donation drive is conducted without approval and comes to our attention through a complaint or report, action can be taken in accordance with the relevant laws and regulations,” Sangay Dendup said. “This may include requiring the funds collected to be refunded or, in certain circumstances, transferring the funds to the government.”
Around 116 religious organisations are currently registered with the Commission. Of these, only one has approval to conduct a donation drive.
According to the Commission, unauthorised fundraising is largely being carried out by individuals and groups that are not registered with it. Officials say a lack of awareness about the approval process could be contributing to the practice.
For cultural projects undertaken by individuals or groups outside the Commission’s registration system, applications for donation drives are handled by the Department of Culture and Dzongkha Development.
“In general, donation drives are done by the agencies. These are the CSO, Department of Law and Order, Commission for Religious Organization and the Department of Culture and Dzongkha Development,” said Singye Samdrup, Culture Specialist with the Department. “The Department of Culture and Dzongkha Development permits those donation drives which are culture-related, specifically to those who are not registered under the Commission for Religious Organization.”
The Department also scrutinises agreements between those initiating cultural projects and the people commissioned to carry out the work. For projects involving statues and other cultural structures, officials examine whether those undertaking the work have the required experience and whether prescribed standards are being followed.
Monitoring continues after permission is granted.
“When it comes to monitoring, we ask for a report on whether the project is completed or not. If it is not completed, we give them an extension of time to complete the project,” Singye Samdrup said. “If the project is completed, we check whether the money has been used for the intended purpose. We have a group that monitors it.”
Between January and August this year, the Department approved six donation drives involving unregistered individuals or groups.
The growing use of messaging and social media platforms, however, presents a regulatory complication. Even when a fundraising project itself has received approval, officials say the donation drive cannot be conducted through social media under the existing policy.
“According to the donation policy, social media is not the officially approved platform to conduct a donation drive,” Singye Samdrup said. “If the donation drive gets our approval and they use social media as a platform to conduct the donation, we will stop the drive. We do not legally accept the platform.”
The issue is not new. In 2019, the Commission for Religious Organization issued a circular asking people to refrain from using social media platforms for donation drives.
Seven years later, however, fundraising has increasingly migrated to the same digital spaces that the rules do not recognise. Private messaging groups allow appeals and bank details to circulate quickly, with contributions often beginning before questions about authorisation, financial reporting or oversight arise.
The shift leaves regulators confronting two related issues: identifying donation drives being conducted without approval and enforcing a regulatory framework designed without today’s widespread messaging-based fundraising in mind.
As donation appeals continue to move online, the gap between how funds are raised in practice and how fundraising is regulated is becoming increasingly difficult to ignore.
