OBSERVARE

Universidade Autónoma de Lisboa

e-ISSN: 1647-7251

VOL. 16, Nº. 2, TD2

Thematic Dossier

Portugal and China in International Relations:

Historical Legacies and Contemporary Dynamics

February 2026

HYBRID ADMINISTRATIVE TRADITIONS IN MACAO SAR: BETWEEN

NAPOLEONIC AND CHINESE ADMINISTRATIVE TRADITIONS

JOÃO CARLOS CORTESÃO FARIA

joao.faria@ipleiria.pt

He is an Invited Assistant Lecturer at the School of Technology and Management, Polytechnic of

Leiria (Portugal). He is currently a doctoral candidate in Public Administration at the Institute of

Social and Political Sciences, University of Lisbon, where he is supported by an FCT–CCCM

doctoral fellowship (ISCSP-ULisboa). His research is funded by the Foundation for Science and

Technology (FCT) through the Macau Scientific and Cultural Centre Doctoral Grant

(PRT/BD/154975/2024). His scholarly interests lie at the intersection of public administration,

governance, and the evolving institutional dynamics linking Portugal, Europe, and the Lusophone

world. https://orcid.org/0009-0007-7986-175X

ANABELA RODRIGUES SANTIAGO

Anabela_Santiago@iscte-iul.pt

She holds a PhD in Public Policies from the University of Aveiro. She is a Researcher at the Centre

for International Studies (CEI) of Iscte – Instituto Universitário de Lisboa (Portugal) and an

external researcher at GOVCOPP (Governance, Competitiveness and Public Policies), University of

Aveiro. Her work focuses on global governance, international policy diffusion, and the European

Union’s scientific diplomacy toward the Global South, including Africa, Asia, and Latin America.

She is an active member of COST Action SiDnet – Science in Diplomacy Network, where she

contributes to the development of analytical frameworks for understanding EU scientific

diplomacy. In addition, she is a member of COST Action CHERN – China in Europe Research

Network (WG1), through which she has participated in several international research missions

and training initiatives, including: i) a scientific mission mapping Chinese investments in the

agri-food sector (University College Cork); ii) the CHERN Training School China Scholarship and

Policy Advice: Reaching Out to Policy-makers (European Commission, Brussels); and iii) a

scientific mission mapping Chinese health-related projects associated with the Belt and Road

Initiative in Europe (University College London). Her research portfolio reflects a sustained

engagement with contemporary geopolitical, economic, and diplomatic relations between Europe

and China, as well as broader transformations in global governance. https://orcid.org/0000-

0002-3897-0323

Abstract

Macao is a Special Administrative Region of the People's Republic of China, governed by the

principle of ‘One Country, Two Systems’. With a Portuguese historical legacy lasting more than

400 years, which continued until December 1999, we consider that the Region has a very

particular model of public administration and is undergoing a gradual process of administrative

reform, which is the subject of this article. Its public administration is not limited to a linear

continuation of the Portuguese period, nor is it a simple transposition of the administrative

model of the People's Republic of China; rather, it is a hybrid configuration, in which the

Napoleonic legacy (of Portuguese origin) provides a resilient legal-administrative support,

recontextualized by a post-1999 political-administrative logic associated with the Chinese

administrative tradition (of Confucian origin). The results point to a configuration in which the

legal and administrative support remains predominantly Napoleonic (legalism, uniformity,

legal and administrative control mechanisms), while the political logic shows Confucian traits

(centrality of the executive, vertical accountability and primacy of stability). We conclude that

Macao exhibits a relatively stable hybrid model, resulting from the coexistence and

JANUS.NET, e-journal of International Relations

e-ISSN: 1647-7251

VOL. 16, Nº. 2, TD2

Thematic Dossier - Portugal and China in International Relations: Historical Legacies

and Contemporary Dynamics

February 2026, pp. 32-54

Hybrid Administrative Traditions in Macao SAR: Between Napoleonic and Chinese

Administrative Traditions

João Carlos Cortesão Faria, Anabela Rodrigues Santiago

recombination of distinct (but also similar) administrative traditions, with incremental

adaptations that preserve the inherited legalistic basis and simultaneously reinforce political

coordination mechanisms typical of the Chinese context.

Keywords

Administrative traditions, Macao SAR, One Country, Two Systems, Napoleonic and Chinese

tradition.

Resumo

Macau é uma Região Administrativa Especial da República Popular da China, regida pelo

princípio de “Um País, Dois Sistemas”. Com um legado histórico português com mais de quatro

séculos, que perdurou até dezembro de 1999, consideramos que a Região apresenta um

modelo de administração pública particularmente singular e atualmente em processo gradual

de reforma administrativa — objeto central deste estudo. A sua administração pública não

constitui uma mera continuidade linear do período português, nem resulta de uma simples

transposição do modelo administrativo da República Popular da China; trata‑se, antes, de uma

configuração híbrida, em que o legado napoleónico (de matriz portuguesa) fornece um suporte

jurídico‑administrativo resiliente, recontextualizado por uma lógica político‑administrativos

pós‑1999 associada à tradição administrativa chinesa (de origem confuciana). Os resultados

apontam para uma configuração na qual o enquadramento jurídico‑administrativo permanece

predominantemente napoleónico (legalismo, uniformidade, mecanismos de controlo jurídico

e administrativo), enquanto a lógica política revela traços confucianos (centralidade do

executivo, responsabilização vertical e primazia da estabilidade). Concluímos que Macau

apresenta um modelo híbrido relativamente estável, resultante da coexistência e

recombinação de tradições administrativas distintas - embora também similares - com

adaptações incrementais que preservam a base legalista herdada e, simultaneamente,

reforçam mecanismos de coordenação política típicos do contexto chinês.

Palavras-chave

Tradições administrativas, RAEM de Macau, Um País, Dois Sistemas, Tradição napoleónica e

chinesa.

How to cite this article

Faria, João Carlos Cortesão & Santiago, Anabela Rodrigues (2026). Hybrid Administrative

Traditions in Macao SAR: Between Napoleonic and Chinese Administrative Traditions. Janus.net, e-

journal of international relations. Thematic Dossier - Portugal and China in International Relations:

Historical Legacies and Contemporary Dynamics, VOL. 16, Nº. 2, TD2, February 2026, pp. 32-54.

https://doi.org/10.26619/1647-7251.DT0126.2

Article submitted on 3rd November 2025 and accepted for publication on 12th January

2026.

JANUS.NET, e-journal of International Relations

e-ISSN: 1647-7251

VOL. 16, Nº. 2, TD2

Thematic Dossier - Portugal and China in International Relations: Historical Legacies

and Contemporary Dynamics

February 2026, pp. 32-54

Hybrid Administrative Traditions in Macao SAR: Between Napoleonic and Chinese

Administrative Traditions

João Carlos Cortesão Faria, Anabela Rodrigues Santiago

HYBRID ADMINISTRATIVE TRADITIONS IN MACAO SAR:

BETWEEN NAPOLEONIC AND CHINESE ADMINISTRATIVE

TRADITIONS

JOÃO CARLOS CORTESÃO FARIA

ANABELA RODRIGUES SANTIAGO

1. Introduction

In recent decades, public administration reforms have established themselves as key

instruments for modernizing the state, with a view to improving the efficiency,

effectiveness, transparency, integrity and quality of public services. In this context, the

Macao Special Administrative Region (MSAR) is particularly relevant: the transfer of

administration to China (20 December 1999), negotiated following the Sino-Portuguese

Joint Declaration (1987), presented the MSAR with the challenge of preserving

institutional continuity and stability, while adjusting structures, practices and public

policies to the new political and socio-economic conditions.

The singularity of Macao's public administration results from an unusual historical and

institutional overlap. On the one hand, over centuries, the region consolidated an

administrative model associated with the Napoleonic tradition, characterized by legalism,

procedural formalism, centralization and a legal-administrative regime. On the other

hand, the post-1999 period has intensified the influence of the Chinese administrative

tradition, marked by a strong primacy of executive power, hierarchy and state-centric

coordination, with a political-administrative relationship that is often more fused than

separate. Comparatively speaking, the case of Macao suggests that the “hybridity” in

SARs should be specified by the traditions in interaction. Unlike Hong Kong – often read

as a hybrid dynamic between Anglo-Saxon administrative institutions and Chinese

governance – in Macao, hybridity results from the combination of a Napoleonic legal-

administrative legacy and Chinese mechanisms of political-administrative coordination.

This study therefore has the following main objective: to understand how Napoleonic and

Chinese traditions have conditioned and shaped this process, contributing to the

contemporary configuration of a hybrid model of public governance in the MSAR. The

research question focuses on: how do Napoleonic and Chinese traditions influence

Macao's public administration, making it a hybrid case?

The results show that Napoleonic and Chinese administrative traditions influence

administrative reform in Macao not as parallel legacies, but as interacting mechanisms.

The Napoleonic legacy provides a resilient legal-administrative infrastructure – legalism,

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VOL. 16, Nº. 2, TD2

Thematic Dossier - Portugal and China in International Relations: Historical Legacies

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February 2026, pp. 32-54

Hybrid Administrative Traditions in Macao SAR: Between Napoleonic and Chinese

Administrative Traditions

João Carlos Cortesão Faria, Anabela Rodrigues Santiago

uniformity, procedural predictability and strong legal scrutiny – through which reform

tends to advance incrementally and stabilize institutionally. At the same time, post-1999

political and administrative logics have reconfigured the exercise of authority and the

way accountability is organised: the centrality of the executive, the fusion of politics and

administration, and a predominantly vertical chain of accountability structure the conduct

of reform, leadership control, and administrative coordination. The result is a relatively

stable hybrid configuration, in which legal continuity sustains capacity and predictability,

while vertical coordination conditions priorities, elite control, and practical limits on

participation and democratic accountability.

2. Administrative Traditions: Concept and Administrative Hybridity,

Dimensions

For Peters (2008), an administrative tradition can be understood as “an historically based

set of values, structures and relationships with other institutions that defines the nature

of appropriate public administration within society” (p. 118). Administrative traditions

have roots that go back centuries and continue to influence current administrative

behavior. It is important to note that, although rooted in the past, administrative

traditions are not static (Peters, 2021). They interact with new ideas, constraints and

political dynamics, producing patterns of change over time (Painter & Peters, 2010b).

Peters (2021) argues that, despite their historical origins, traditions have contemporary

relevance and continue to influence the patterns of public bureaucracies. As Painter and

Peters (2010a) and Peters (2021) point out, administrative traditions impose paths of

development (path dependence) that explain why different countries, subject to similar

international pressures for reforms inspired by management models, follow different

reform trajectories conditioned by their institutionalized legacies.

In the field of comparative public administration science, several authors have identified

families of countries that share similar administrative traditions due to common historical

and cultural experiences (Heady, 2011; Kuhlmann et al., 2025; Painter & Peters, 2010a).

Painter and Peters (2010b), for example, classified national bureaucracies into four major

families: Anglo-Saxon, Napoleonic (or continental European), Germanic, and Nordic

(Scandinavian), to which they add the administrative traditions of post-colonial Latin

America, South Asia, and Africa, East Asia, the Soviet Union, and the Islamic world.

Recent literature recognizes that classic “families” of administrative traditions do not

always accurately capture the empirical diversity of administrative systems. In Jugl’s

(2025) study, administrative traditions are reconceptualized and measured in two

dimensions – citizen orientation and structural concentration –, which appear to be

largely independent, allowing for empirical observation of multiple combinations of

characteristics and relevant variation within the supposed families. Despite this, the

author shows that much of the literature continues to operationalize administrative

traditions through categorical classifications (“families”), often with little empirical

transparency, which limits systematic comparison and the identification of more nuanced

patterns.

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Thematic Dossier - Portugal and China in International Relations: Historical Legacies

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February 2026, pp. 32-54

Hybrid Administrative Traditions in Macao SAR: Between Napoleonic and Chinese

Administrative Traditions

João Carlos Cortesão Faria, Anabela Rodrigues Santiago

In theoretical terms, a hybrid administrative tradition describes an administrative system

that combines elements from different families or historical-administrative legacies. Jugl

(2025) observes that administrative traditions often exhibit a hybrid nature and openness

to exogenous ideas. In fact, the literature on public administration recognizes that:

Traditions are likely to be hybrid and more complex than what is suggested

by the AT families and the previous focus on paradigmatic cases; and while

hybridity is acknowledged in the theoretical discussion on AT (...) it has

hardly been studied empirically in comparative public administration (Jugl,

2025, pp. 13–14).

Precisely because hybridity refers to variable combinations of attributes – and not just to

belonging to a “family” – it becomes analytically useful to break down administrative

tradition into dimensions. In Tradition and Public Administration (2010a), Painter and

Peters propose a comparative framework to clarify the concept of administrative

traditions, operationalizing it through four analytical dimensions: (i) State and Society;

(ii) Law vs. Management; (iii) Administration and Politics; and (iv) Accountability.

The first dimension (State and Society) encompasses both the conceptualization of the

State (whether understood as an organic entity or as a contractual construct) and the

role it assumes in relation to society and the economy. This includes contrasting models

such as a centralized and interventionist State versus a limited State oriented toward

safeguarding market guarantees. Traditionally, comparative analyses have highlighted,

for instance, the organic conception of the State prevalent in continental traditions, where

the State is regarded as the embodiment of the common good and vested with legitimate

authority to shape societal structures. This stands in sharp contrast to the more

contractual perspective characteristic of Anglo-Saxon traditions, in which the State is

conceived as the outcome of a social agreement, with functions narrowly defined and

constrained by societal consent.

This dimension is critical because it reflects foundational assumptions about sovereignty,

legitimacy, and the scope of governmental authority. The organic view, rooted in

continental European thought, tends to emphasize hierarchical integration and normative

unity, positioning the State as a moral and political agent responsible for articulating

collective interests and ensuring social cohesion. Conversely, the contractual paradigm,

deeply embedded in liberal Anglo-American traditions, prioritizes individual autonomy

and market mechanisms, framing the State as a neutral arbiter whose legitimacy derives

from consent rather than transcendental notions of the common good. These divergent

conceptions have profound implications for administrative design, policy-making, and the

balance between regulation and freedom, shaping not only institutional architectures but

also the normative expectations of governance within different cultural and historical

contexts.

The second dimension (Law vs. Management) lies in the role conception of the

administrative systems: the juridical administrator who applies codified law with

procedural correctness (strong in Napoleonic/Germanic traditions) versus the managerial

administrator who prioritizes results, efficiency, and organizational performance (strong

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VOL. 16, Nº. 2, TD2

Thematic Dossier - Portugal and China in International Relations: Historical Legacies

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February 2026, pp. 32-54

Hybrid Administrative Traditions in Macao SAR: Between Napoleonic and Chinese

Administrative Traditions

João Carlos Cortesão Faria, Anabela Rodrigues Santiago

in Anglo-American traditions). This dimension is particularly significant because it reveals

the normative foundations and operational priorities of administrative systems. A

legalistic orientation, deeply rooted in continental European and Napoleonic traditions,

emphasizes procedural correctness, predictability, and the supremacy of law as a

safeguard of legitimacy and equality before the State. In such systems, administrative

discretion is minimized, and compliance with codified norms is considered the

cornerstone of public integrity. Conversely, managerial approaches, inspired by Anglo-

American pragmatism and reinforced by the doctrines of NPM, privilege outcomes over

processes, advocating for flexibility, innovation, and performance metrics as drivers of

administrative effectiveness (Painter & Peters, 2010a; Peters, 2021). This shift from rule-

bound administration to results-oriented governance reflects broader transformations in

public sector paradigms, including the diffusion of private-sector management techniques

and the growing emphasis on accountability through measurable outputs rather than

formal adherence to legal norms. The tension between these two orientations continues

to shape contemporary debates on administrative reform, efficiency, and democratic

legitimacy (Painter & Peters, 2010a; Peters, 2021).

The dimension of “Administration and Politics” addresses the degree of politicization

within the civil service and the structural relationship between political and administrative

spheres. It asks to what extent political actors (such as elected officials and parties)

shape the internal functioning of public administration, particularly regarding

appointments, career progression, and bureaucratic decision-making. As Peters (2021)

emphasizes, this dimension is crucial for distinguishing administrative traditions. In

contractarian systems, such as those within the Anglo-American tradition, the normative

ideal is a clear separation between politics and administration, grounded in principles of

neutrality, merit, and permanence. The British civil service model exemplifies this

approach, conceiving the bureaucracy as an instrument of law rather than an extension

of partisan authority. Conversely, organic conceptions of the State, typical of Napoleonic

or patrimonial traditions, foster more permeable boundaries between politics and

administration. In these contexts, political control over the bureaucracy is often

institutionalized through patronage or systems such as the spoils system, historically

prevalent in the United States (Painter & Peters, 2010a; Peters, 2021). This dimension

also reflects contemporary tensions. Reforms inspired by NPM have introduced

performance-based accountability and contractual appointments, challenging the

traditional separation of roles. However, historical institutionalist perspectives

underscore the resilience of inherited patterns: administrative traditions act as “default

options,” shaping the trajectory and interpretation of reforms.

Finally, “Accountability” reflects how the bureaucracy is held responsible for its actions

and decisions. Mechanisms of accountability vary across administrative traditions and

can be broadly categorized into legal/formal controls and political/public controls.

Legalistic approaches emphasize compliance with codified norms and hierarchical

supervision, enforced through instruments such as administrative courts, audit courts,

inspectorates, and internal procedural rules. In contrast, political and societal

mechanisms rely on parliamentary oversight, media scrutiny, and civil society

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Hybrid Administrative Traditions in Macao SAR: Between Napoleonic and Chinese

Administrative Traditions

João Carlos Cortesão Faria, Anabela Rodrigues Santiago

engagement, prioritizing transparency and responsiveness (Painter & Peters, 2010a;

Peters, 2021).

As developed by the same authors, further distinction concerns the timing of

accountability:

− Ex ante accountability involves preventive measures, such as prior

authorization or legal review before administrative action (e.g., the role

of the Conseil d’État in Napoleonic systems).

− Ex post accountability occurs after decisions are implemented, through

audits, judicial review, parliamentary inquiries, or electoral processes.

This dimension is critical for understanding variations in governance, as it shapes the

incentives and behaviour of public officials, influences administrative culture, and

determines the degree of openness and trust between State and Society.

These four dimensions proposed in 2010 provided an initial analytical framework for

comparing and contrasting administrative families. However, subsequent research has

broadened this set of attributes to capture additional relevant characteristics. In his most

recent work, Administrative Traditions: Understanding the Roots of Contemporary

Administrative Behavior (Peters, 2021), the author retained the original axes while

incorporating further elements to offer a more comprehensive view of administrative

traditions.

Among the additions, four dimensions stand out.

The fifth dimension concerns the orientation of public administration toward authority

versus service to citizens. This attribute, referred to by Peters as the “Administration

versus Service” dimension, examines whether public officials primarily conceive of

themselves as executors of laws and programs defined by political leaders (the classical

administrative function) or as service providers oriented toward meeting the needs and

expectations of citizens as “clients” of public services. This dimension, introduced in

Peters’ 2021 book, reflects the influence of recent paradigms such as citizen-oriented

management and the concept of public service motivation, even though it remains

relatively underexplored in the literature. It signals a normative shift from a state-centric,

rule-bound conception of administration toward models emphasizing responsiveness, co-

production, and user satisfaction. These developments challenge traditional bureaucratic

identities and raise governance-related questions about the balance between legality,

efficiency, and democratic legitimacy.

The sixth dimension is “The Career”. This dimension refers to the extent to which public

employment constitutes a distinct civil service career, clearly differentiated from political

careers and private-sector employment, and to whether officials tend (or not) to remain

in government for most of their working lives.

The seventh dimension is “State and Society II” that is, the legitimate role played by

societal actors (e.g., interest groups, experts, and citizens) in shaping public policy, both

in its formulation and implementation.

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VOL. 16, Nº. 2, TD2

Thematic Dossier - Portugal and China in International Relations: Historical Legacies

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February 2026, pp. 32-54

Hybrid Administrative Traditions in Macao SAR: Between Napoleonic and Chinese

Administrative Traditions

João Carlos Cortesão Faria, Anabela Rodrigues Santiago

The eighth and final dimension is “Uniformity”. Uniformity refers to the extent to which

the State can ensure that public administration applies policies and procedures in a

similar way across the entire territory, limiting variation between services and regions.

3. Napoleonic and Chinese Administrative Tradition

In the case of the Macao Special Administrative Region, for example, we consider the

coexistence between the Napoleonic administrative tradition (as Macao was a territory

under Portuguese administration for more than four centuries) and the Chinese

administrative tradition (with origins dating back to the Qin dynasty) explains not only

how changes were implemented, but also the resistance and adaptations that occurred

over time – allowing us to analyze the case of the Macao Special Administrative Region

as a cluster of the coexistence of two administrative traditions.

Table 1 summarizes the similarities and differences between the Napoleonic and Asian

(Confucian, which was largely influenced by China) administrative traditions. This allows

us to illustrate how the overlap of these two administrative traditions – the European

legal and organizational structure and the values and mechanisms of Chinese

administration – manifests itself in the administrative practice of the Macao Special

Administrative Region

Table 1 - Napoleonic and Asian (Confucian) Traditions

State tradition

Napoleonic

Asian (Confucian)

Law vs. management

Organic

Administration and politics

Law

Mixed

Administration or service

Fused

State and society II

Administration

Uniformity

Mixed

Pluralist/illegitimate

Accountability

Uniform

Source: Authors based on Peters (2021, p. 162)

3.1 Napoleonic Administrative Tradition

Our analysis refers to the Napoleonic model, developed in France in the 18th and 19th

centuries, which influenced southern European countries such as Portugal, Spain, Italy,

and Greece (Painter & Peters, 2010a). This model reflects the influence of the

Enlightenment, especially Rousseau's theory of democracy and Montesquieu's separation

of powers (Ziller, 2003). In these systems, the law serves as a tool of the State to

organize and control society, not just to resolve conflicts between individuals. Public

administration is heavily regulated by a legal hierarchy that includes the Constitution,

laws, regulations, and other norms, which consequently exercise strict control over what

civil servants can do, through specialized courts (Painter & Peters, 2010a; B. G. Peters,

2008).

Our analysis didn’t include the element “career”.

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VOL. 16, Nº. 2, TD2

Thematic Dossier - Portugal and China in International Relations: Historical Legacies

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February 2026, pp. 32-54

Hybrid Administrative Traditions in Macao SAR: Between Napoleonic and Chinese

Administrative Traditions

João Carlos Cortesão Faria, Anabela Rodrigues Santiago

The French State is centralized and technocratic, playing an important role in nation-

building. Senior positions in public administration are held by an administrative elite who

were educated at prestigious schools. These officials often transition from public service

to political office seamlessly, as their roles are clearly defined by law. In southern

European countries, there is a great deal of legal formalism, or many rules and

procedures. However, in practice, informal arrangements are often used to achieve

objectives. This encourages clientelism, patronage, nepotism, and sometimes corruption.

Additionally, appointments are highly politicized, and many public positions are used as

political favors. This contributes to an excess of civil servants and a less professional and

less efficient administration (Painter & Peters, 2010a; B. G. Peters, 2008).

Thus, the Napoleonic administrative tradition is characterized by an organic conception

of the State, in which the State is invested with legitimate power to exercise authority

over society. It is also characterized by a highly centralized and hierarchical state

structure with little room for interest groups to intervene in the public policy-making

process. This intervention is even seen as illegitimate. Additionally, it is a tradition

marked by the primacy of formalism and legalism, or the principle of legality, which

shapes administrative action around legal norms (Painter & Peters, 2010b; Peters, 2008).

3.2 Chinese Administrative Tradition

China has the oldest and most deeply rooted administrative system in the world. Its

origins date back to the Qin dynasty (221–206 BC) through a highly bureaucratic system

that is considered one of the most enduring elements of Chinese civilization (Dwivedi,

2003). The Chinese administrative tradition reflects a long history of centralization and

hierarchical control, shaped by cultural values and philosophies rooted in Confucianism

and legalism (Dong et al., 2010; Dwivedi, 2003).

Painter e Peters (2010b) argue that the Confucian administrative tradition combines

philosophical ideas with practices of the Chinese empire, and it is possible to verify that

the Confucian administrative tradition (principles of virtue, meritocracy, rituals, and

reciprocity) is, for Painter and Peters (2010b), the ideological matrix that gave rise to

the Chinese administrative tradition. Although the Chinese administrative tradition has

undergone numerous “reinterpretations” (Yuan, Ming, Qing, Republic, Maoism), Cheung

(2010b) notes that the Confucian core has persisted in people's mindsets.

The Confucian administrative tradition combines philosophical ideas with Chinese

imperial practices. During the Han era, scholars began to integrate into the State as

mandarins, linking the central government to local authorities. In Confucianism, ritual

and reciprocity-maintained order better than laws. Relying on virtuous men could lead to

favoritism, but meritocracy prevailed: scholars were recruited through imperial

examinations, assessing literacy and knowledge of the classics. Despite this,

examinations could fail or be corrupted (Painter & Peters, 2010a). Despite the destruction

of imperial institutions by the republican revolution and the communist regime, the

Confucian core – especially moral leadership, hierarchical relationships, and the ruler's

obligation to cultivate virtue – remained in the mindsets of Chinese cadres. Even in Mao's

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Thematic Dossier - Portugal and China in International Relations: Historical Legacies

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February 2026, pp. 32-54

Hybrid Administrative Traditions in Macao SAR: Between Napoleonic and Chinese

Administrative Traditions

João Carlos Cortesão Faria, Anabela Rodrigues Santiago

restructuring, cadres were evaluated for their moral integrity and paternalistic style. It

was only after the reforms of the late 1970s that these values came to be presented as

“socialist virtues,” but their impact on administrative culture remained unquestionable.

The influence of continental Europe on Chinese administration became particularly visible

from the late 19th century onwards, when the need to modernize the State was

recognized (Cheung, 2010). Inspired by French legal codes and the Prussian bureaucratic

model, Chinese reformers adapted principles such as the uniform codification of laws and

the creation of ministries organized by function (Painter & Peters, 2010b). Thus, a

continental-style legal system was introduced that coexisted with the Confucian tradition

of hierarchy and meritocracy (Peters, 2021) which we can analyse in Table 2.

Table 2 – Asian traditions (Confucian), European Transplants

Transplant

Confucian

Continental Europe

Japan, Korea, Taiwan, China, Vietnam

[to this set we add Macao]

Anglo-American

Hong Kong, Singapore

Source: Authors based on Peters (2010b), p. 26)

China's administrative tradition continues to evolve, especially in the context of reforms

that began at the end of the 20th century. These reforms maintain centralization and

hierarchical principles as basic foundations while incorporating modernization and anti-

corruption mechanisms. The goal is to strengthen ethics in public services and increase

the efficiency of public administration (Alsancak et al., 2022; Cheung, 2010; Dong et al.,

2010).

4. Methodology

The research is based on a qualitative design, structured as a case study of the Macao

SAR, understood as an institutional configuration where elements of the Napoleonic

administrative tradition (legacy of Portuguese administration) and the Chinese

administrative tradition (of Confucian origin) coexist and combine.

Specifically, the analysis is organized according to the seven dimensions we identified in

the literature, allowing us to observe whether the MSAR is closer to a Napoleonic model,

a Confucian model, or a combination of the two. The grid is applied to the following

dimensions: (i) State–society I; (ii) law vs. management; (iii) administration and politics;

(iv) administration vs. service; (v) State–society II; (vi) uniformity; and (vii)

accountability

The evidence strategy is predominantly documental and bibliographical, combining: (a)

academic literature on administrative traditions and administrative reforms; (b) legal-

institutional and governance references relevant to the political-administrative design of

In our analysis, we chose to exclude the dimension “The Career”, since, in Peters’ original framework (2021),

this dimension is not used in the comparison of European and Asian administrative traditions (see p. 162).

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February 2026, pp. 32-54

Hybrid Administrative Traditions in Macao SAR: Between Napoleonic and Chinese

Administrative Traditions

João Carlos Cortesão Faria, Anabela Rodrigues Santiago

the MSAR; and (c) secondary information supporting the bibliographical references. This

triple approach allows us to sustain a dimensional reading without relying on a single

source or a single type of evidence.

The point is, hybridity shouldn't be seen as a static mix of “Portuguese” and “Chinese”

traits. Administrative traditions have historical roots, but remain open to recombination

under new political constraints and under the influence of ideas of modernization;

therefore, the decisive point is to understand how competing logics are activated,

reconciled or hierarchized in different arenas of governance. Based on this premise, we

treat Macao's hybridity as an empirical question: across the seven dimensions, we

identify observable indicators associated with Napoleonic legalism and Chinese political-

administrative coordination, examining how their interaction shapes path dependence in

the MSAR.

Finally, it is important to highlight a methodological limitation: as this is primarily a

documental and conceptual analysis, the study focuses on characterizing the model and

its logic, and could be further developed in subsequent works using additional methods

(e.g. interviews with managers and technicians, observation of implementation, analysis

of administrative processes) to test in greater detail how hybridity translates into

administrative routines and concrete public policy outcomes.

5. Discussion and results

Based on the theoretical framework and the data collected, the assumptions that Macao

harbours characteristics from two major administrative traditions – Napoleonic and

Confucian (Chinese) – resulting in a hybrid model are confirmed. In this section, we

discuss the dimensional results of the analysis, examining each of the seven dimensions

in the context of Macao, in light of administrative traditions. In each dimension, we

identify the aspects that correspond to the Portuguese/Napoleonic legacy, those that

reflect Chinese/Confucian influence, and how the interaction between the two shapes the

current policies and administration of the MSAR.

Table 3 - Napoleonic and Confucian (Chinese) traditions: Macao’s positioning

Aspect

Macao as hybrid

configuration tradition

Justification

State tradition

Organic

Strong executive; priority given to

stability/order (“One Country, Two

Systems” with central oversight).

Law vs.

management

Mixed elements law

Rule-based culture; incremental

modernisation (simplification,

e-government, performance management).

Administration

and politics

Fused

Appointments and control of senior

management by the Chief Executive;

criteria of trust/political loyalty.

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Hybrid Administrative Traditions in Macao SAR: Between Napoleonic and Chinese

Administrative Traditions

João Carlos Cortesão Faria, Anabela Rodrigues Santiago

Administration

and service

Administration with

service elements

“Serving the people” and improvements in

service (one-stop, quality letters), but

formalistic/bureaucratic routines persist.

State and

society II

Mixed, tending to

limited

Many advisory councils and dense

associations, but with a government

agenda and limited autonomy (risk of

formal consulting).

Uniformity

Uniform

Small region; lack of autonomous local

power; common procedures/statutes

(uniformity “from within”).

Accountability

Predominantly legal

with mixed elements

Predominance of legal and ex post control:

courts (including Administrative Court) +

CACC + Audit Commission; more limited

political-democratic scrutiny.

Source: Authors3

5.1 State and Society - I

According to Yee (2001), the transition and institutional design of the MSAR are based

on a strongly state-centric model of governance: the process is led by Beijing in

cooperation with pro-China economic and associative elites, while the population remains

largely in a political culture of “subjects”, valuing stability, order and government

leadership. This combination of a strong executive, elite consensus and paternalism

reinforces the idea of a Special Administrative Region that combines Napoleonic centralist

organicism with the Chinese administrative tradition of benevolent authority (Castellucci,

2012). Indicators of this are evident in multiple aspects.

Constitutionally, the Basic Law of Macao confers significant powers on the Chief

Executive, a single-person body that accumulates the functions of head of government

and concentrates executive power. The Chief Executive is not elected by universal

suffrage, but chosen and appointed by the Central People's Government of China

(Gouveia, 2012). The legitimacy of the Macao SAR government does not come from

universal suffrage, but from a process defined by the central authority (Beijing),

reinforcing the notion of a tutelary State: ultimately, it is the Chinese State that delegates

authority to the Macao government (Gouveia, 2012). However, within Macao, this

authority is exercised in a Napoleonic manner and centralized (Chou, 2004; Peters,

2021).

Another indicator of the organic and centralizing character of the Macao Region is the

absence of significant challenges to its authority or movements that question the

prominent role of the government. Research indicates that, even after the transition,

Macao's civil society remained relatively weak and submissive, with high levels of trust

or, at least, passive acceptance of authority on the part of citizens (Ho, 2015; Kwong,

2011). As Choi (2011) points out, relations between Macao and the Central Government

have been marked by cooperation, but it is clear that the national interests defined by

The authors present the results based on Table 1, structured according to the analytical dimensions proposed

by Peters (2021).

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João Carlos Cortesão Faria, Anabela Rodrigues Santiago

Beijing take precedence in the strategic guidelines of the Macao SAR. This means that

Macao is part of a framework of sovereignty in which the State (in this case, the Chinese

State through its local representative) retains the right and duty to govern the territory

according to broader national objectives, which take precedence over local requests.

There was therefore no contractualist or liberal reorientation of the Region after 1999;

on the contrary, Macao's autonomy was designed to strengthen national unity and the

stability of the Chinese State.

Understanding (the organic nature of the State) as an entity with its own will and

interests, above particular groups, is also evident in official discourse that justifies

reforms or policies by appealing to the global public interest. The 2025 Government

Action Lines, for example, mention goals such as “raising governance capacity” and

“strengthening awareness of the big picture” among civil servants, which suggests that

they are expected to think of the administration as a whole serving the common good,

rather than segmented by sectoral interests. This rhetoric echoes the French tradition of

service to the intérêt général (Chevallier, 1975), with the difference that in Macao such

general interest is also aligned with the strategic guidelines defined by Beijing (e.g.,

economic diversification, social stability, patriotism).

5.2 Law vs. Management

Macao's administrative structure preserves a strong legal tradition, inherited from the

Napoleonic model (based on its Roman-Germanic roots), where legality is central to

administrative action. This legal tradition is evident in the maintenance of the

administrative law system, the hierarchical administrative organization and the

supremacy of written law (Godinho, 2016; Xinyu, 2016).

Under Portuguese administration, Macao operated under a legal system based on the

European continental model – the Administrative Code (Torrão, 2016), the Penal Code,

the Civil Code, the Commercial Code, laws and regulations (Mendes, 2013) – and the

local bureaucracy was accustomed to formal procedures, paperwork and strict

compliance with legal regulations (Bolong, 2011).

With the transition to China approaching, the need to modernize administration by

incorporating public management concepts was identified (Lam, 2011). Not

coincidentally, this period coincided globally with the spread of New Public Management

(NPM) (Bouckaert & Pollitt, 2011). Thus, as early as the 1990s, and intensifying after

1999, the case of Macao revealed a path of balance between the legalistic heritage of the

Portuguese system and international pressures to adopt modern management practices

after the transition period (Kei, 2005; Lam, 2011).

As described by Yu (2011), Edmund Ho's government (1999-2009) introduced

competitive recruitment systems and periodic performance evaluations, in addition to

investing in professional training for civil servants, measures characteristic of a

managerial approach aimed at improving the quality of public service. These reforms

denote the incorporation of NPM principles – meritocracy, performance-based human

resource management, management skills development – signaling a shift from purely

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Administrative Traditions

João Carlos Cortesão Faria, Anabela Rodrigues Santiago

legal-bureaucratic administration to one concerned with results and efficiency (Bouckaert

& Pollitt, 2011).

Another example is the digitalization and simplification of administrative procedures,

which began in the 2000s and sought to reduce excessive red tape and streamline the

provision of public services (Choi, 2011). Integrated service centers, e-government

platforms and more user-oriented processes (one-stop services) were created,

highlighting management's concern with service quality and policy effectiveness (Yu,

2011).

These initiatives are reflected in government discourse: successive Chief Executives have

emphasized the importance of modernization and administrative efficiency in their Policy

Addresses. For example, during the Chui Sai On administration (2009–2019), “e-

governance” and “administrative simplification” programs were launched to improve

internal efficiency and convenience for citizens. According to the Government Action

Guidelines for the 2020 financial year, both the Public Administration and the legal

system of Macao, which have been in operation for more than two decades, show signs

of maladjustment in the face of socio-economic changes in the Region – demonstrating

limitations in their ability to respond to the new demands of society and, as a result,

progressively falling short of the population's expectations in terms of the effectiveness,

efficiency, transparency and quality of public services (Mota, 2019).

In conclusion, Macao has transitioned from a predominantly procedural legalistic

administration to a legalistic administration with management features. Legal norms and

procedures continue to guide state action (and legitimize decisions before the law), but

there is greater concern with performance, quality and efficiency, evident in

administrative reforms and government discourse. This synthesis highlights the hybrid

nature of the system: the Napoleonic tradition provided the legal-bureaucratic backbone,

while the contemporary influence of New Public Management and the pragmatism of the

Chinese administrative tradition brought in elements of public management. The result

was a gradual improvement in efficiency (for example, Macao has high levels of

government effectiveness according to the Worldwide Governance Indicators

(Government Effectiveness dimension). The score rose from 55.98 (percentile) in 1998

to 72.44 in 2010, reaching 73.04 in 2022, reflecting a continuous improvement in the

perception of the quality of public services, policy formulation and implementation, and

government credibility).

5.3 Administration and Politics

During the Portuguese colonial period, especially in the final decades (1980–1999),

Macao did not have a fully democratic system: The Governor, appointed by the President

of the Portuguese Republic, concentrated executive powers and relevant legislative

powers, assisted by a only partially elected council and a Legislative Assembly with a

mixed composition, resulting from direct and indirect suffrage, with a strong presence of

organized interests (Cardinal, 2008; Shiu-Hing, 1989). In this context, management

positions in the administration were often filled by political appointment.

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Yee (2001) characterizes the Portuguese administration in the final decades as an

executive-centered and politicized system: The Governor and under-secretaries were

political appointments and, although directors and deputy directors were formally career

civil servants, many were recruited from Portugal on a contractual basis and linked by

personal relationships to the under-secretaries, tending to leave when their “patrons”

were replaced. This pattern reinforced the politicization of top appointments and

constrained the progression of local staff. There was thus politicization of appointments

at the top, which is consistent with characteristics often associated with the Napoleonic

administrative tradition: permeability between political and administrative careers, the

presence of a logic of ‘spoils’ and the politicization of senior positions (Ongaro, 2010).

However, after the transition of Macao's administration to China, the top ranks of the

administration – secretaries, directors of services and other senior positions – came

under the direct control of the new Chief Executive (Basic Law of the Macao SAR, arts.

45, 50 (6)), and indirectly under the influence of Beijing (Chou, 2013).

Political loyalty has thus become an explicit criterion: senior officials in Macao are

expected to be politically reliable to the Central Government (Yee, 2014). This suggests

the persistence of political interference in the bureaucracy – a feature compatible with

the Chinese administrative tradition, insofar as the boundaries between politics and

administration tend to be more porous and the bureaucracy remains strongly subordinate

to political leadership (party-state) and also observable in the Napoleonic tradition

(Cheung, 2010; Christensen & Fan, 2018; Painter & Peters, 2010a).

In recent years, some secretaries have been recruited from civil society figures –

businesspeople or professionals with backgrounds outside senior civil service – reflecting

the importance of economic and associative elites in the MSAR’s ruling coalition (Kwong,

2017). However, their selection does not follow any logic of party distribution, not least

because Macao is, as Lou and Tang (2023) note, a society without political parties, but

rather the personal and political trust of the Chief Executive and the requirement that

the main leaders be “patriots who love the country and Macao”, as emphasized in official

statements.

5.4 Administration and Service

In the context of Macao, the administrative culture inherited from the Portuguese period

was close to a hierarchical and unprofessional bureaucratic model, in which the

administration saw itself primarily as an instrument of government and political control,

rather than as a service to citizens (Bolong, 2011). As Lo (1995) describes, the civil

service before the transition was characterized by inefficiency, low levels of education

among many employees, endemic corruption, frequent reorganizations, recruitment and

promotion based on political patronage, and intense conflict between departments, to

the extent that Macao's bureaucracy could be considered ‘from a Weberian perspective,

underdeveloped and backward’ (Hing, 1995, p. 116).

After 1999, in the context of the international spread of public administration reforms

and drawing explicitly on the experiences of the US, the UK, Hong Kong and Singapore,

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João Carlos Cortesão Faria, Anabela Rodrigues Santiago

the discourse on the need to “serve the people” and cultivate a citizen service mentality

began to take hold in Macao (Kei, 2005). During Edmund Ho's first term (2000–2004),

despite the difficulties already analyzed, this translated into initiatives to improve public

services, such as the simplification of administrative procedures, the creation of

integrated one-stop public services, the introduction of Quality Charters and quality

management systems, and the strengthening of training for civil servants in customer

service and modern management skills (Kei, 2005).

However, there remains a cultural gap between the official discourse of ‘government at

the service of the people’ and the routines of many career civil servants, trained in a

traditional administrative culture. Ho Iat Seng himself, in his 2020 Policy Address, set as

a goal ‘strengthening the service awareness of civil servants’ and ‘correcting the service

attitude, avoiding bureaucratic practices,’ which implies recognition that behaviors

marked by formalism and a predominant concern with compliance with internal rules

continue to exist, rather than proactive resolution of citizens' problems.

However, it should be noted that Macao's economic prosperity – largely supported by the

expansion of the gaming sector and the associated increase in public revenues – has

enabled the Government to strengthen, in certain areas, the provision of social services

and benefits (namely, public/subsidized healthcare provisions and the

expansion/planning of public housing), as well as to institute universal cash transfers to

residents through the Wealth Partaking Scheme launched in 2008 (Kwong, 2013; Lok,

2011).

Macao continues to adopt a more pronounced public service perspective, without,

however, abandoning its inherited formalism. Thus, there is a certain tension between

the persistence of complex procedures and documentary requirements (a classic

bureaucratic trait) and the growing orientation towards making life easier for

citizens/customers. The Chinese administrative tradition, which values harmony and

avoids confrontation, also encourages officials to be helpful and solve citizens' problems

in order to maintain social order – which, in this respect, converges with the notion of

service. In short, administration or service in Macao is becoming increasingly ‘service-

oriented’, albeit within the limits of a bureaucracy still regulated by strict legality.

5.5 State and Society - II

Historically, under Portuguese administration, Macao developed limited forms of

corporatism: the Portuguese government, especially from the 1980s onwards,

institutionalized councils and advisory bodies that included representatives of economic

and community interest groups. The Consultative Council itself was composed of

members appointed by the Governor, representatives of municipal bodies and

representatives of interest groups (Luz, 2000), which reinforced the logic of functional

integration of economic and associative elites in the governance of the territory (Chou,

2015; Lou, 2004).

After 1999, Macao maintained – and even expanded – the structure of advisory bodies

inherited from the Portuguese period, now having dozens of sectoral advisory councils

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Administrative Traditions

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(education, health, tourism, administrative reform, among others), created under the

Basic Law to consult society on different policies. However, as Wang and Li (2023) show,

decision-making remains concentrated in the Executive Council and the councils directly

dependent on the Chief Executive, with the Government deciding on the creation of

bodies, convening meetings and setting the agenda, while many councils and the general

public intervene only passively, which means that consultations run the risk of becoming

a mere formality.

Until 2017, Macao had an exceptionally large number of associations - approximately

7,000 - resulting in a remarkably high density of organizations relative to its population

(Macao Youth Federation, 2020). However, existing research indicates that this pattern

of associativism reflects a specific corporatist model of state–society relations.

Historically, participation in associations has served as the primary channel for political

engagement in Macao, as individuals seldom act independently in the political sphere

(Kai Chun, 2012). The government, both during Portuguese administration and in the

Macao SAR, co-opted the leaders of the main associations as representatives of

community interests, in an informal corporatist arrangement. As one analyst points out,

“relations between associations and the government have characteristics of corporatism:

[…] associations have no autonomous will, while influences on civil society are weak” (p.

133). In the most recent period (since 2019), Ho Iat Seng’s official rhetoric on

administrative reform has emphasized the need to “listen to society” and “enhance

transparency”, possibly in response to the recommendations of international reports and

the context of Hong Kong after the 2019 protests.

Thus, the Region coexists with a semi-state civil society, where the main associations act

as conduits for government policies to the population, rather than channeling

independent pressure from the people to the Region. The relationship between the State

and society – particularly with regard to the participation of interest groups, social

organizations and citizens in the public policy process – in Macao has mixed

characteristics, but tends more towards the statist and controlled model, close to the

traditional Napoleonic model and, in a way, even more restrictive, in line with the

Confucian view that autonomous interventions by civil society are illegitimate.

5.6 Uniformity

With regard to the uniformity of the administrative apparatus and its degree of

decentralization, Macao has a highly uniform and centralized structure, which is

consistent with both the Napoleonic tradition (centralized unitary states) (Peters, 2021)

and the Chinese model (unitary state with strong central control) (Cheung, 2010).

In fact, Macao, being a region with a small geographical area and population, does not

have a local political-administrative level with true autonomy (the former municipalities

were abolished and replaced by an advisory body with no political power) (Faria, 2023).

Public services, civil service statutes, administrative procedures and service delivery

mechanisms are largely common across the territory, promoting a high degree of formal

equality in terms of access and equal treatment of citizens (Bolong, 2011; B. Kwong,

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Administrative Traditions

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2011; Yu, 2011). This configuration is consistent with the Napoleonic tradition (Ongaro,

2010) inherited from the period of Portuguese administration, in which regulatory and

administrative uniformity is anchored in the law, in the administrative career and in the

predictability of procedures (for example, the Macao Administrative Procedure Code

(essentially derived from the Portuguese code) establishes principles of equality,

impartiality and uniformity in the conduct of administrative proceedings) (Torrão, 2016).

In the post-1999 period, this situation did not change substantially; in fact, during

negotiations on the future of Macao, this option of maintaining and adapting local

legislation became known as the “localization of laws”, i.e. their continuity under Chinese

administration, but anchored in the MSAR’s own legal system. (Mendes, 2013).

Based on Alsancak et al. (2022), who characterize the People's Republic of China as a

system with a highly centralized bureaucracy and strict control over local governments,

the MSAR can be seen (like Hong Kong), from the perspective of the political center in

Beijing, as an exceptional institutional arrangement: a Special Administrative Region that

has a high degree of autonomy from the Beijing administration. In terms of Peters' theory

(2021), we can argue that Macao therefore combines high intra-regional uniformity,

consistent with the Napoleonic tradition (of the Portuguese legacy), with low uniformity

at the Chinese state level, since it embodies a solution of internal institutional pluralism.

This dual position – uniformity “inside”, diversity “outside” – is central to understanding

the hybrid nature of Macao’s governance model and how continental European legacies

and the political logic of the PRC are articulated within it.

5.7 Accountability

Applying the accountability aspect to Macao, the starting point is to understand that

accountability is organized primarily around legal and administrative mechanisms, rather

than political-democratic control mechanisms in the classical sense. From a political-

institutional point of view, the Basic Law establishes a fairly vertical chain of

accountability

− The Chief Executive is accountable to both the Central People's

Government and the Macao SAR;

− The Government must obey the law and be accountable to the Legislative

Assembly, presenting policy reports, implementing the approved budget

and responding to questions from Members of Parliament. However,

given that the Chief Executive is chosen by a restricted electoral college

and only some of the Members of Parliament are elected by direct

suffrage, political accountability is based more on a logic of upward

accountability (to Beijing and the local political and administrative elite)

than on direct accountability to the voters.

Cf. articles 45.º, 47.º and 65.º of the Basic Law of MASR and respective annexes I and II.

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Hybrid Administrative Traditions in Macao SAR: Between Napoleonic and Chinese

Administrative Traditions

João Carlos Cortesão Faria, Anabela Rodrigues Santiago

At the legal and administrative level, accountability is strongly law-based and ex post.

Macao's courts, including the Administrative Court, exercise control over the legality of

administrative acts and sub-legal regulations, ensuring that the Administration acts in

accordance with the law and offering citizens means of appeal against illegal or unfair

decisions.

The Macao SAR also has two central pillars of specialized accountability, as provided for

in the Basic Law itself:

− the Commission Against Corruption (CACC), which operates

independently and whose Commissioner reports to the Chief Executive,

with the dual mission of fighting corruption and acting as an ombudsman,

investigating complaints of illegality or maladministration and

recommending changes to procedures and systems (Chang, 2011);

− the Audit Commission (AC), which is also independent, conducts financial

and value-for-money audits of the Administration, contributing to

accountability for the use of public funds, although its Director is

politically accountable to the Chief Executive and not directly to the

Legislative Assembly (Tan, 2011).

Both combine classic ex post control functions with a growing role in prevention and

advice, close to what Peters (2021) describes as recent attempts to strengthen

accountability through NPM-inspired reforms (performance audits, system improvement,

promotion of integrity).

We can therefore say that in Macao, accountability is based primarily on internal,

legalistic, judicial and administrative accountability, typical of the Napoleonic tradition,

reinforced by specialized control bodies (CACC, AC, courts), and only partially on a logic

of pluralistic and societal political accountability. By way of illustration, according to the

Worldwide Governance Indicators (Voice and Accountability dimension), Macao's

percentile score was 59.17 in 1998, rising to 69.26 in 2019, but fell again to 57.96 in

2024, suggesting a deepening of the limitations on political participation and democratic

accountability over the last decade.

This configuration contributes to a hybrid model: a strong emphasis on legality and

administrative integrity, combined with a political structure in which accountability is

exercised mainly “upwards” (Beijing and the Chief Executive) and less “outwards”

(citizens and public opinion).

6. Conclusion

At this point, we believe that our analysis supports the view that Macao is a hybrid model

in which two administrative traditions coexist and influence each other. On the one hand,

there is a Napoleonic framework, with elements such as the primacy of Portuguese law

and legal-administrative formalism, a high degree of administrative uniformity, and the

prevalence of legal control and review mechanisms. On the other hand, there is a political

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Hybrid Administrative Traditions in Macao SAR: Between Napoleonic and Chinese

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logic compatible with the Chinese administrative tradition, marked by the centrality of

the executive, the fusion of administration and politics, and accountability patterns that

are more vertical (‘upwards’) than pluralistic (‘outwards’). We also note that there are

several arrangements that belong to both administrative traditions, resulting in

arrangements that interact.

In terms of the aspects outlined by Painter and Peters (2010) and Peters (2021), the

study highlights: (i) an organic and Region-centric government; (ii) a “law vs.

management” axis that tends to be legalistic, but with the incremental incorporation of

administrative modernization practices and a focus on results; (iii) permeable boundaries

between politics and administration; (iv) an incomplete transition from “administration”

to “service”, with efforts to improve service and simplification, but persistence of

formalistic routines; (v) consultative and relatively limited civic participation; (vi) strong

centralization and administrative uniformity; and (vii) mainly legal-administrative

accountability, reinforced by specialized bodies, with limitations on political-democratic

scrutiny.

In terms of its contribution, we consider that the study shows that the MSAR should not

be seen as a simple continuation of the period of Portuguese administration or as a mere

importation of the PRC's administrative model: it is a hybrid configuration, in which the

maintenance of the legal and administrative framework coexists with a political and

symbolic reconfiguration aligned with priorities of stability and central governance.

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