The rules do not mention any role of the Vatican in approving bishops, despite the 2018 Vatican-China agreement reportedly involving both Chinese authorities and the Holy See in the process of appointing bishops.
In 2018, the Vatican reached an agreement with the Chinese government on the appointment of bishops; the terms of the agreement, which was renewed in Oct., 2020, for two more years, have never been fully revealed.
According to reports, however, the agreement allows for China’s state-sanctioned church (CCPA) to select episcopal candidates, who would then be approved or vetoed by the Holy See. At the time the Vatican-China agreement was renewed in October, a Vatican newspaper reported that two Chinese bishops were appointed under the “regulatory framework established by the agreement.” The Vatican confirmed in November that a third bishop had been appointed under the regulatory framework of the agreement.
Cardinal Joseph Zen, the former bishop of Hong Kong and a vocal critic of the agreement, said it could put the Vatican in the position of having to veto repeatedly episcopal candidates advanced by China.
The agreement was undertaken to help unite the state-run Church and the underground Catholic Church. An estimated 6 million Catholics are registered with the CCPA, while several million are estimated to belong to unregistered Catholic communities which have remained loyal to the Holy See.
According to the new rules, once a new bishop is consecrated, the CCPA and the state-sanctioned bishops’ conference will send his information to the State Administration for Religious Affairs.
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Registration of clergy in a database is a key part of the new administrative measures, under which clergy in China will also be required to promote the values of the Chinese Communist Party.
For instance, Article III of the administrative measures states that clergy “should love the motherland, support the leadership of the Chinese Communist Party, support the socialist system,” and “adhere to the direction of the Sinicization of religion in China.”
The practice of Sinicization has been announced and implemented by president Xi Jinping in recent years; critics have called the plan an attempt to force religious practice under the control of the Chinese government and in line with the values of the CCP.