Egyptian authorities should amend the associations law to lift tight restrictions over independent civil society organizations, hindering the right to freedom of association and other rights and putting the future of the country’s civic space at risk, Amnesty International said in a new briefing published today.
The briefing, ‘Whatever security says must be done’: Independent NGOs’ freedom of association restricted in Egypt, details how the authorities are imposing undue restrictions and interfering in the work of independent NGOs through the repressive law No. 149 of 2019 (the associations law) and other tactics to bring them under near total state control.
Whilst the closure of Case 173 last year after 13 years of unfounded criminal investigations of the funding and activities of NGOs appeared to be a potential turning point, the associations law grants the authorities a stranglehold over independent NGOs undermining their right to freedom of association.
“Although the lifting of decade-long travel bans and asset freezes against NGO workers was a positive step, the authorities have not only ignored calls to amend the restrictive 2019 associations law but have used it to impose burdensome regulatory requirements on NGOs, while allowing security agencies to subject them to intrusive interference, and constant surveillance. These intimidation practices suffocate vital NGO work and contribute to a chilling climate of intimidation that erodes people’s capacity to organize and exercise their human rights,” said Sara Hashash, Deputy Regional Director for the Middle East and North Africa at Amnesty International.
“Under international human rights law, any restrictions on NGOs must be narrowly defined, strictly necessary to achieve a legitimate aim, proportionate and never a tool to silence critics. The Egyptian authorities must amend the associations law to allow NGOs to register by notification instead of prior authorization, protect NGOs from NSA’s interference, intimidation and coercive practices against NGOs, and lift all undue restrictions on NGOs’ access to and use of funding.”
The Associations and Civil Work Unit (ACWU) of the Ministry of Social Solidarity, which is responsible for registering and overseeing NGOs imposes a prior authorization process for NGO registration in contravention of international standards and Egypt’s own constitution which stipulates that NGOs should acquire legal personality upon notification. Through the ACWU, the state can refuse or delay registration of NGOs, dictate limitations on their work, block their funding, interfere in the composition of their boards, and even order the dismissal of their members. This stranglehold is reinforced by unlawful interference from the National Security Agency (NSA), which harasses and intimidates members of NGOs through phone calls, unlawful summons and coercive questioning.
The briefing draws on interviews with 19 individuals representing 12 independent Egyptian NGOs working in social development, media and human rights in Greater Cairo over the past five years. Amnesty International conducted the interviews between March and July 2025 and reviewed official documents issued by the administrative bodies overseeing NGOs.
Associations law muzzling civil society
Egypt’s 2019 associations law is incompatible with international human rights law and standards. It gives authorities sweeping powers to control and punish NGOs. It allows the government to reject registration within 60 days if any of the NGO’s purposes violates Egyptian laws, many of which are incompatible with international law, to dissolve NGOs and prosecute staff on vague charges, and to confine NGO work to “societal development,” effectively barring human rights and “political” activities under overly broad notions including “national unity.” The law also lets officials interfere in NGOs’ board composition, enter premises without notice, and inspect documents, with penalties for staff who breach these overbroad rules. Many of these restrictions are enforced through ACWU giving the state a tightly centralized grip over who can operate and on what.
An amendment to the Penal Code introduced in 2014 allows authorities to prosecute individuals for receiving foreign funds on the basis of vaguely defined provisions such as “committing hostile acts against Egypt” with penalties that can reach life imprisonment or even the death penalty.
Compulsory registration or dissolution
Egypt’s 2019 associations law requires all NGOs to register under its terms, including those that were already registered, or risk dissolution. Some NGOs told Amnesty International they registered to gain some protection from security harassment or to stay eligible for funding, while others said they felt they had no choice because of the penalties for non-compliance.
To date, the authorities have not dissolved any association due to lack of registration according to information available to Amnesty International.
A few NGOs registered as law firms or non-profit companies opted not to register, fearing the law’s restrictions would limit their work.
Under international human rights law, however, associations should never be forced to register under a specific legal framework or be criminalized for their lack of formal status. The states must guarantee the right to freedom of association to registered groups, regardless of the legal framework they choose, as well as to unregistered groups.
Intimidations and interventions by the NSA
Registered NGOs are placed under the near-total control of the ACWU which in some cases facilitates unlawful interference by the NSA agents, who routinely harass and intimidate staff and board members of independent NGOs through threatening phone calls and unlawful summons and delaying registrations.
NSA agents have also intimidated NGO directors or staff members, ordering them to report on their groups’ activities and questioned them about foreign funding requests they submitted to the ACWU, creating a chilling effect given the NSA’s record of arbitrary arrests, enforced disappearances and torture or other ill-treatment.
Several NGOs told Amnesty International that hotels routinely refuse to host their events without NSA clearance, and donors said even approved events are sometimes monitored by undercover agents or require them to submit audiovisual materials for prior security approval. Such practices violate international human rights standards, which require states to let NGOs operate freely, protect them from intimidation and reprisals, and enable, rather than obstruct, their legitimate activities.
Barriers around financial resources
Independent NGOs in Egypt face severe, state-imposed barriers to their right to seek, receive and use resources, including financial resources, from domestic, foreign, or international sources. Even after registering, they cannot open or activate bank accounts without a letter from the ACWU, and in some cases, banks refuse or stall account openings until they receive separate “security” clearances, leading in several documented cases to delays of three to 15 months that paralyze organizations’ ability to pay staff, rent or implement activities.
Under the 2019 associations law, NGOs must also obtain prior approval before receiving any foreign funding, and the ACWU can object within 60 days without clear, lawful grounds, effectively giving the state a veto over external resources. NGOs that receive funds without approval risk suspension or dissolution, while their staff members or directors risk being financially penalized.
Background
Between 2011 and 2021, Egyptian authorities steadily escalated their crackdown on independent civil society, subjecting most independent NGOs to criminal investigations, asset freezes, retaliatory travel bans and prosecutions solely for their legitimate human rights work. Many staff members have faced arbitrary detention, enforced disappearance, torture and unfair trials, forcing a number of organizations and activists into exile and further hollowing out Egypt’s civic space.
Between 2021 and 2024, the authorities have eased aspects of the crackdown on NGOs. In March 2024, after 13 years of unfounded criminal investigations of the funding and activities of NGOs, the authorities announced that there were no grounds to initiate criminal proceedings in Case 173/2011, also known as foreign funding case, citing insufficient evidence. As a result, the authorities lifted decade-long asset freezes on at least seven Egyptian associations and 11 of their staff members, as well as travel bans on at least 31 human rights defenders. The announcement of this decision was particularly noteworthy since Egyptian judicial authorities hardly ever announce the closure of an investigation in political cases.
Distributed by APO Group on behalf of Amnesty International.
