The debate over which actors contribute to customary international law generally centres on international organizations and other non-State actors, and easily accepts States as the only relevant actors. However, on rare occasions States can be governed by an international organization. When an international organization becomes entangled with a State government, the normal participation in the formation of customary international law becomes confused. A survey of practice citing to the acts of international territorial administrations shows that it is possible for these governance arrangements to contribute to customary international law in the same manner as states, even though those acts are formally undertaking by an international organization. However, their evidentiary value might be less persuasive than the practice of states.