Churchgoers who drop money in the collection plate might want to consider the consequences of their generosity, lest their places of worship be shut down in April amid a blizzard of bureaucracy. Under new rules that Protestants fear will threaten religious freedom, churches must start counting how much of their tithe and offerings come from Russians and foreigners. The new rules also require churches to account for every service and any other event, including the time and date it took place, how many people attended and the "makeup" of the participants, such as whether they were mostly students, small-business people or some other group, according to documents that churches and other nongovernmental organizations have to submit to the Federal Registration Service. The rules are part of the contentious new law on NGOs that forced all foreign groups to reregister with the service by October. For religious organizations, the law means they must submit the new accounting forms to the service by April 15 or face closure. "If there is a collection box in the corner, how are we supposed to know who donated what?" Konstantin Bendas, a spokesman for the Russian Church of Christians of Evangelical Faith, said Friday. Furthermore, he said, keeping a tally of every service promises to be a bureaucratic nightmare. "This may be fine for an NGO that has three or five events per year, but a religious organization has events every day with services in the morning, afternoon and evening," he said. "So for every Russian Orthodox service, you would have to indicate who came to worship, who sang and who read the liturgy. It all leads to pointless bureaucracy." Bendas' union of evangelical faith is among five Protestant groups that signed a Dec. 1 appeal to First Deputy Prime Minister Dmitry Medvedev to exclude churches from the accounting rules in the NGO law. The other signatories include the Baptists and the Seventh-day Adventists. Medvedev chairs the government commission on religious organizations.

The appeal says the accounting rules violate the law on freedom of conscience and religion, and that the required paperwork makes it nearly impossible for religious organizations to remain in compliance. Vladimir Ryakhovsky, one of the country's top lawyers for religion issues, concurred that it would be "physically impossible" for religious organizations to comply with the new rules and predicted "big problems" for many organizations come April. "The biggest problem will be that organizations the powers-that-be want to strangle out of existence will be targeted for their lack of compliance," Ryakhovsky said. Gennady Alibekov, a spokesman for the Federal Registration Service, said his agency had no comment on the new rules. "Our job is merely to carry out the laws that have been passed," he said.

The NGO law, which came into effect in April, has drawn sharp criticism from Western governments, human rights groups and NGOs. Critics maintained the measure would cripple Russia's fledgling civil society, adding that it was reflective of the country's growing trend toward authoritarian government. Several organizations have been denied registration under the law, though they have had the option of resubmitting their applications after making appropriate corrections. Government officials could not be reached for comment Friday. But Andrei Sebentsov, a spokesman for the government commission on religious organizations, told Kommersant that the letter to Medvedev would not help much. "This is not an issue that Dmitry Anatolyevich can resolve," Sebentsov said. "The decree was issued together with the NGO law, and there is no reason to revise something in the document now." Sebentsov said the new rules did not violate the law on freedom of conscience and religion. Protestants are not the only religious organizations concerned about the rules. Rabbi Zinovy Kogan, chairman of the Congress of Jewish Religious Organizations, said that for the most part, synagogues in Russia were run by individual rabbis who could be overwhelmed by new bureaucratic responsibilities.

"We all report to the tax authorities, and that is normal," Kogan said. "But the rabbi usually does everything, from accounting to conducting services, and all the time usually keeping a regular job. He can barely keep up with the responsibilities he has already." A spokesman for the Russian Orthodox Church said Friday that no one was available to comment. A lawyer for the church, Ksenia Chernega, told Kommersant that the Moscow Patriarchate was drawing up an appeal to the government similar to the one sent by the Protestant churches to Medvedev. She said the requirement to account for goods and services sold by the church could be difficult to meet. "The church, for example, has never tracked the number of candles it distributes, because a candle is an offering to God," Chernega said, adding that occasional services, such as baptisms, weddings and funerals, are similarly undocumented.