How China and Russia's Anti-Protest Laws Compare as Countries Face Unrest

China and Russia are facing large waves of civil unrest and both countries have taken steps to crack down on dissent.

Russians protesting President Vladimir Putin's decision to invade Ukraine face tough measures and even jail time. A new law passed on Thursday allows less space for domestic critics, expanding the country's "foreign agents" law and cracking down on free expression and protests.

The law, which rights groups say is a tool to suppress dissent, was adopted in July 2022 but was delayed. Under the new law, almost any person or entity, regardless of nationality or location, who engages in activism or expresses opinions on Russian policies, can be considered "a foreign agent," as long as authorities say they are under "foreign influence."

Those designated as a "foreign agent" are considered spies or traitors, and there is no way for the defendant to contest this in court before the designation is made. Those designated must follow all requirements the day after authorities add them to the registry or face a harsher prison sentence.

The original foreign agent law was brought in 2012 and targeted NGOs after anti-Putin protests. It defined "foreign agents" as individuals or entities that have received foreign support to oppose the government.

Since 2014, Russian authorities can give a fine or a detention of 15 days for holding a demonstration without the permission of the authorities. Prison sentences of up to five years may be given if this law is breached three times.

On March 4, Russia's state Duma enacted two laws that make independent war reporting and protesting the Ukraine war illegal, each carrying punishments of up to 15 years behind bars.

In China, November 26 saw thousands of people in Shanghai—the country's largest city—protest the government's strict "zero COVID" measures and rally against the Chinese Communist Party. The protests have since spread to other cities, including Beijing and Guangzhou.

China is known for tightly suppressing protests and in recent years has increased surveillance and online censorship, as well as imprisoning many activists. As with Russia, the country's security infrastructure has long been prepared for large protests.

Beijing has signed the Universal Declaration of Human Rights, which protects the right to protest peacefully, but has not ratified it.

Chinese protest laws are malleable, so that anyone who is targeted by authorities can go to prison, even if the charges are vague.

The Associated Press reported that "picking quarrels and provoking trouble" can be punishable by up to five years behind bars. Charges relating to "subverting state power" are often used, without much evidence required, other than that the accused was critical of the Chinese Communist Party. The accused are often denied their right to a lawyer, and the cases almost always result in conviction, the news agency reported.

Protesters in both countries have been using blank placards in their protests, to make it harder for them to be arrested. The blank paper is meant to represent an implicit and understood message, but the lack of writing makes it harder for authorities to prove that regulations have been violated.

Newsweek has contacted analysts for comment on and comparison of the two country's protest laws.