ABSTRACT Regulatory intermediaries (RIs) are transforming implementation of contemporary regulatory policy. While the mainstream Regulator-Intermediary-Target framework offers important insights, limited research investigates the prerequisites for non-governmental organizations (NGOs) to function as RIs. This study investigated the organizational capacities and institutional conditions for environmental NGOs’ contributions as RIs in China’s newly established Environmental Public Interest Litigation system. Analyzing data from interviews, archive retrieval and participatory observation, it found that their effective contributions require not only adequate capabilities and competences for the assigned authorities, but also alignment of their strategic and survival interests with the broader regulatory objectives. The contributions were influenced by their interactions with other key actors in the regulatory system and related institutions. The study suggests that researchers and designers of regulatory systems relying on NGO-RIs should consider their organizational capacities and interests in their evolving interactions with actors within and beyond the focal system and before and after its introduction. Constant feedback about their latest operational needs and concerned issues would help update the regulatory system. Institutional arrangements that support their development would also enable their effective functioning for the system, inducing wider and more dedicated contribution. The study highlights the complexity in governing with NGOs.
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