Since 2011, civil society organisations in Egypt have faced a mounting wave of restrictions and arbitrary measures, which have varied in severity and in their tools, but have all shared a single aim: reducing the role of these organisations and curbing their influence in the public sphere.
It escalated markedly with Case No. 173 of 2011, known in the media as the “foreign funding” case, whose repercussions lasted for nearly 13 years. It resulted in travel bans being imposed on a number of human rights defenders, men and women, along with the freezing of their bank balances, as well as the detention of some of them pending investigation.
That was before the Egyptian authorities decided to close the case in March 2024 after 13 years of prosecution and bans, when the investigating judge in the case decided that there were no grounds to bring criminal proceedings against five human rights organisations, and decided to lift the travel ban and asset freeze imposed on the staff of these organisations.
Over time, the pressure did not stop at judicial prosecution, but extended to obstructing the work of the institutions themselves, through the rejection or delay of the security and administrative approvals needed to implement their projects, despite their compliance with the procedures set out in the Law Regulating Civil Work. This has in effect undermined these organisations’ ability to continue and weakened their role in providing services and defending rights, in a legal and administrative context marked by ambiguity and restriction.
Over the past two years, a number of civil associations and foundations began registering, in application of the Law Regulating the Practice of Civil Work issued in 2019, which human rights advocates have described as an arbitrary law that imposes broad restrictions on the work of civil society.
Despite these criticisms, these institutions began taking the steps of establishment and legal regularisation, seeking to continue their work officially and to avoid legal prosecution, but these attempts ran into complex administrative procedures, in the form of delays in activating bank accounts, the requirement to obtain prior approval to carry out activities, and the rejection or obstruction of a number of projects without clear reasons being given, according to what Zawia3 documented while preparing this report, which has had a negative effect on their ability to perform their social and human rights role effectively.
Obstacles from the moment of establishment
Under the Law Regulating the Practice of Civil Work No. 149 of 2019, all civil associations and foundations are obliged to register with the Ministry of Social Solidarity, submitting the required legal documents and papers. The law provides for the application of what is known as the “principle of silent response”, whereby a registration application is considered implicitly accepted if the administrative body does not respond within 60 days of the date the notification was submitted, unless the ministry issues a written objection within this period.
On the experience of the Association for Freedom of Thought and Expression with the obstacles to establishment, Mohamed Abdel Salam, its executive director, says: “The foundation registered its entity as a civil foundation in July 2023, but it took about 11 months, until May 2025, just to activate its bank account.
He explains in his interview with Zawia3: “This was the first major obstacle we faced. We have official papers and approval from the Ministry of Social Solidarity to activate the account, but the private banks kept refusing. Each time they ask repeated questions: What are the sources of funding? What are the areas of activity? Who is running it? We send the documents and then they are requested again in different forms.”
Abdel Salam adds: “One of the banks made it a condition that the Ministry of Solidarity’s letter be amended to add a statement that the ministry does not require a licence to collect funds in order for the account to be activated”, questioning what the activation of a civil foundation’s account has to do with fundraising procedures, which concern charitable associations only.
The executive director points out in his interview that an employee at one of the banks explained to them, indirectly, that the decision to activate the account did not depend on the bank’s management alone, but required approvals from external bodies, which was understood to mean interference by security or executive bodies.
After a series of letters and contacts, and the intervention of public figures, the account was activated after 11 months. But the foundation faced a new stage of complications when it submitted the papers for a foreign grant to implement a project with one of its partner organisations.
Egypt’s 2019 Law on Associations requires all associations to register under its provisions, including associations that were previously registered, otherwise they are liable to be dissolved. According to Amnesty International, some institutions registered to obtain a degree of protection from harassment by the security services or to preserve their eligibility for funding, while other associations reported that they felt they had no choice because of the penalties for non-compliance. Amnesty International explained that it has information indicating that the authorities have not, to date, dissolved any association for failing to register. Some associations registered as law firms or non-profit companies chose not to register, for fear that the law’s restrictions would limit their work.
Amnesty International noted in its report that under international human rights law, associations may never be obliged to register within a specific legal framework or be criminalised for lacking legal status. States must guarantee the right to freedom to form or join associations for registered groups, regardless of the legal framework they choose, as well as for unregistered groups.
In its report, the organisation also stated that independent associations in Egypt face severe restrictions imposed by the state on their right to seek, receive and use resources, including financial resources, whether from domestic, foreign or international sources. Even after registration, associations cannot open or activate bank accounts without a letter from the Central Unit for Associations and Civil Work, and in some cases banks refuse or delay opening accounts until they obtain separate “security” approvals, which in several documented cases has led to delays ranging from three to 15 months, paralysing associations’ ability to pay staff salaries or rent or to carry out activities.
Obstacles
The law and its executive regulations impose additional restrictions, obliging associations and foundations to notify the ministry of the receipt of any funds, whether from domestic or foreign sources. The competent administrative body is given a period of up to 60 days to review the funding and raise any objection to it, and during this period the foundation is prohibited from disposing of or using the funds. If the period expires without a rejection decision being issued, approval is deemed to stand by force of law, but this practical mechanism is often used, according to human rights organisations, as a tool for obstructing activities and delaying the implementation of projects.
The executive director of the Association for Freedom of Thought and Expression continues: “We submitted the grant contract, the budget, the activities and the internal regulations, but the staff refused to accept them, and made it a condition that a sub-account be opened before approval was obtained, even though this condition is not stipulated in the law”. After the sub-account was opened, an inspection by the Ministry of Solidarity was requested, and then the inspection was delayed on the pretext of a staff shortage.
He continues that the discussion escalated to the point of a threat to report the foundation to “State Security” on the claim that it was a “troublemaker”, before the inspection was finally carried out and the grant papers were accepted at the end of July, after about two months of attempts.
Nevertheless, the foundation was surprised by repeated requests to “complete papers” without explanation, and the same procedures were then repeated when it applied for a second grant in August. After the papers were submitted to the ministry in October, the foundation obtained a written opinion from the Cairo Solidarity Directorate stating that it had no objection to accepting the two grants, as the foundation complied with the law and its statutes, but the Ministry of Solidarity notified the foundation at the end of November that it had not approved the two grants, without giving any reasons, Abdel Salam says.
Abdel Salam explains that the Association for Freedom of Thought and Expression submitted an administrative grievance, considering the rejection unreasoned and arbitrary. He points out that “since the foundation obtained its licence two and a half years ago, it has not received a single pound to fund its activities, and it covers the costs of its premises and basic expenses through its own efforts, even though the foundation has a working team of about 16 people”. He describes what is happening as security interference and illegal measures that obstruct the work of civil society and deprive institutions that have been licensed for years of any funding.
Under the Law on Associations of 2019, associations are also required to obtain prior approval before receiving any foreign funding, and the Central Unit for Associations and Civil Work may object within 60 days without providing clear and legal justification, which in effect gives the state a veto over external resources. However, associations that receive funding without obtaining prior approval are exposed to the risk of suspension of their activities or dissolution, while their employees or directors face the risk of financial penalties, according to Amnesty International.
The 60-day trap, then rejection without reasons
In this context, Sherif Gamal, executive director of the Center for Egyptian Women’s Legal Assistance, says that the mechanism for handling civil society organisations’ projects within the Ministry of Social Solidarity is marked by procedural complications that empty the legal text of its content, foremost among them the interpretation of the 60-working-day period stipulated for deciding on project applications.
Gamal explains in his interview with Zawia3 that projects are first submitted to the local administration to which the foundation belongs, then referred to the directorate, and from there to the Ministry of Solidarity, pointing out that the 60 working days are not counted from the date the project is delivered and an incoming reference number is obtained, but from the date it actually reaches the ministry, a date that is unknown to the foundations.
He adds: “Sometimes we are told after four or five months that the project has not yet reached the ministry, and at other times it arrives within days or a week. This period is subject to multiple administrative judgements, and each administrative level can hold up the file on the pretext of review or waiting.
The executive director of the Center for Egyptian Women’s Legal Assistance points out that this interpretation is the first form of obstruction, while the second consists of restarting the count of the 60 working days every time the ministry sends the foundation a query, with the period starting again after the reply arrives, which may be repeated several times.
He explains that these queries may be mere formalities or relate to information already contained in the project papers, such as the nationality or headquarters of the donor, or may be the result of administrative errors within the ministry, such as mixing up the papers of two projects, with the foundation then made responsible for re-sorting and resubmitting them. He believes that this mechanism has led to waiting periods stretching from several months to as much as a year, affirming that projects that are supposed to be decided within 60 days are not in fact settled within this period.
In another context, Gamal explains that the Center for Egyptian Women’s Legal Assistance relies on these projects for its budget, and that delays in approvals threaten the stability of the foundation and the continued employment of its staff, and lead to a drain of skilled people as a result of the lack of financial and job stability. He explains that the foundation faces the rejection of projects without reasons being given, even though the same donor had previously been approved in earlier projects, and even though the nature of the projects has not changed.
The executive director of the Center for Egyptian Women’s Legal Assistance affirms that the lack of reasoning in rejection decisions represents a legal dilemma, as it deprives the foundation of its right to appeal or to correct any possible errors, pointing out that appeals submitted against rejection decisions often go unanswered.
He notes that these policies directly affect the women who benefit from the foundation’s services, especially women without means, women subjected to violence, divorced women and widows, who receive free legal, psychological and social support, including filing lawsuits, consultations, obtaining identity documents and support in accessing social protection services, Gamal says.
He explains that the obstruction of projects has a negative impact on the continuation of these services, and may keep women in violent environments, which in some cases may go as far as threatening their lives. He also points out that the impact of the obstruction extends to the foundation’s work in raising awareness and influencing public policy, citing the foundation’s experience in the Bahariya Oasis, which began in 2021–2022 in coordination with government bodies, affirming that the rejection of new projects threatens the sustainability of this work. He affirms that independent civil society organisations are not hostile to the state, but need real spaces in which to work, and need their voices to be heard as a partner that raises problems and solutions, not merely as a body to be restricted or silenced.
In this context, human rights lawyer Negad El-Borai says that the crisis facing civil society organisations in Egypt does not relate to the procedures of establishment or registration, affirming that these procedures “mostly proceed quickly and are not the core problem”.
El-Borai explains in his interview with Zawia3 that he has documented two cases of at least two foundations whose projects were rejected, pointing out that this pattern is repeated with other associations, which raises questions about the nature of rejection decisions and their reasons.
He adds: “The law regulates the matter, and gives the association the right to file a grievance against the rejection decision before the Ministry of Social Solidarity, and also allows it to appeal before the State Council. This legal route is available and known, but the crisis lies in the fact that project rejection decisions are often issued without reasons being given, in flagrant violation of the law”. El-Borai adds: “Even we who work in the field do not know why the rejection happened, and therefore we do not know how to avoid the reason next time”.
The human rights lawyer affirms that the law obliges the administrative body to give reasons for a rejection decision, and considers that refraining from stating the reasons is a flagrant violation of the law and undermines the right to grievance and judicial appeal. He points out that these practices represent one of the fundamental causes of the civil society crisis that has persisted since around 2013, explaining that foreign grants are essentially the backbone of civil work.
El-Borai adds that civil society relies on donations, whether domestic or foreign, but domestic donations face multiple obstacles, including limited tax incentives, as the tax deduction allocated for donations has declined, alongside the prevailing culture that prefers donating to traditional charitable works, such as building places of worship or hospitals, over supporting human rights organisations or cultural work. In addition, this reality makes foreign grants a main target for many associations, and if this door is also closed, these organisations’ ability to work will be paralysed, even without an official decision to close them.
He concluded by saying that grants are not a secondary matter, but a pivotal issue relating to the survival of civil society and its ability to perform its roles in the fields of human rights and cultural and artistic work, fields that do not enjoy broad community support in terms of domestic donations.
The bleeding of civil society
Nevine Ebeid, chair of the board of trustees of the New Woman Foundation, believes that the obstacles facing civil society in Egypt are not only internal and do not begin at the stage of project approvals; rather, she sees them as accumulating “from the very start of the road”, whether at the level of grant-making or of dealing with the national bodies responsible for monitoring and approving projects.
Nevine explains in her interview with Zawia3 that one of the main problems lies in the decline in international grants, as a result of the rise of conservative right-wing currents in a number of donor countries, along with some donors’ tendency to prioritise supporting government plans and policies at the expense of civil society organisations that offer alternative proposals or critical reviews of public policy.
She adds that the volume of available grants has shrunk significantly, often reaching “subsistence level”, which does not allow projects to achieve a sufficient degree of sustainability or institutional accumulation. Ebeid affirms that this decline directly affects organisations’ ability to plan for the long term.
The chair of the board of trustees of New Woman points out that all the projects implemented by the New Woman Foundation previously obtained approval from the Ministry of Social Solidarity, but she noted that the future of upcoming projects remains unclear, saying: “We will try and see what the situation will be with the new projects, but the journey is not smooth, neither with donors nor with the size of grants, and perhaps it will not be smooth either with the national bodies responsible for monitoring and approval”.
Nevine expresses her hope of obtaining approval for some of the projects currently being submitted. Regarding her assessment of the future of civil society in Egypt, Ebeid says that it is “in a very bad state”, pointing to a continuous drain of young cadres trained in civil work, research studies and critical writing.
She adds that the opportunities available within civil society organisations are no longer able to keep pace with the rising cost of living, especially for young feminist cadres who are entirely economically self-reliant, which leads to a great human and professional loss that is difficult to make up.
She points out that the number of organisations of a human rights character or linked to the human rights agenda has shrunk sharply, saying that these organisations “can now be counted on the fingers of one hand”, amid the shrinking of the public sphere and the decline in the spaces available for independent civil work.
She considered that this shrinking is directly reflected on society as a whole, explaining that the dominance of a single voice in interpreting public policy deprives citizens of exposure to alternatives and different visions, and pushes towards further frustration, depression and general decline. She concluded by saying that the citizen has become preoccupied solely with securing the basic requirements of living, amid the decline of hope and of the ability to dream, which represents a comprehensive loss for society.
In a paper entitled “Whatever security says gets done”: Restricting the freedom to form or join independent associations in Egypt, Amnesty International stated that although the Egyptian authorities closed Case 173 of 2011, thereby ending 13 years of baseless investigations concerning associations, in addition to lifting the asset freezes and travel bans imposed on human rights defenders, the restrictive provisions of the Law on Associations issued in 2019, and the continuing interference of the National Security Sector, still severely limit the activities of independent associations, as well as their funding and registration, which undermines the right to freedom to form or join associations.
The paper explained that the 2019 Law on Associations contravenes international law and international human rights standards, as it gives the Ministry of Social Solidarity powers to interfere in the work of associations, in their activities and their access to funding, and gives the authorities the right to dissolve associations without a judicial decision, in addition to imposing other arbitrary restrictions. In fact, the law makes it easy to exploit it and to prevent or punish human rights violations and the holding of officials to account.
It also explained that the law undermines the ability of associations to cooperate with local, regional or foreign entities, including international organisations, treats individuals and representatives of associations as suspects from the outset, and imposes on them heavy and excessive fines for violating the provisions of the law.
The paper published by Amnesty International identified 22 cases studied by Amnesty International, and concluded that the authorities had imposed restrictions on the functioning of civil associations working in various fields, including human rights, social development, media and digital rights. These restrictions included interference in the appointment of board members, as well as in determining their activities and obtaining funding.
According to Amnesty International, the 2019 Law on Associations allows the authorities to refuse the registration of independent human rights associations on vague grounds, for example, irrespective of associations in “community development”, and to ban civil society activities on the grounds that the authorities consider that they “undermine national security”, “public order” or “public morals”.
Since 2011, civil society organisations in Egypt have faced a complex web of legal and administrative restrictions and security interference that makes the practice of human rights and service work a daily challenge. Despite institutions’ attempts to comply with the official laws and register their activities, the continuing obstacles to activating bank accounts, the delays in approving projects and their sometimes being rejected without clear reasons significantly undermine these organisations’ ability to continue and to provide their services to society.
Editorial correction: The first version of the report stated that the number of the “foreign funding” case was 173 of 2013, and the correct number is 173 of 2011. The final paragraph also reflected what was stated by Amnesty International, which criticises the fact that the 2019 Law on Associations allows the authorities to refuse the registration of associations on vague grounds.
