Published April 2026

Uganda’s government is considering the Protection of Sovereignty Bill, 2026 (the Bill). The Bill would impose sweeping restrictions on the ability of individuals and organizations to work with or receive financial support from foreign partners. Below, we highlight eight key concerns with the Protection of Sovereignty Bill: 

1. The Bill applies to a broad range of actors 

The Bill applies to a “person” deemed by the government to have acted as an “agent of a foreigner.”¹ A “person” can include individuals, non-governmental organizations (NGOs), partnerships, and private corporations. These actors may be deemed an “agent of a foreigner” if they receive financial assistance from or interact in other specified ways² with a “foreigner,” which is defined to include Ugandan citizens residing outside of Uganda, foreign governments, NGOs and corporations registered outside of Uganda, international organizations, and a person or body designated a “foreigner” by statute. Consequently, a wide range of actors may be impacted by the Bill’s provisions. 

2. An “agent of a foreigner” must register and disclose detailed information 

The Bill requires an “agent of a foreigner” to register with the Ministry of Internal Affairs. An applicant must disclose detailed information about its activities and sources of funding during the registration process, and the Bill imposes substantial fines and imprisonment for not registering. This creates a significant administrative burden for applicants and regulators and forces applicants to disclose information that could raise privacy concerns for their staff, beneficiaries, and funders. As in countries that have enacted similar rules, it could also stigmatize people and organizations registered as an “agent of a foreigner” by signaling that they are under the control of a “foreigner.” 

3. The Bill requires government approval to solicit or receive financial support or assistance from a foreigner above a certain threshold 

The Bill requires prior written authorization from the Ministry of Internal Affairs for a “person” or “agent of a foreigner” to solicit or receive “any financial support, donation, loan, or other assistance” from a foreigner exceeding 20,000 currency points (approximately USD $106,300) within a twelve-month period. This could enable interference in the activities of disfavored individuals or organizations, as the Ministry has wide discretion to deny or delay approval. It also creates uncertainty for development partners and philanthropic organizations, as they will not know if their financial support may be arbitrarily denied or delayed. 

4. The Bill criminalizes a broad range of conduct 

Among other restrictive categories, the Bill creates offenses related to: 

• “promoting the interests of a foreigner,” 
• “exercising functions and services for which government is responsible,” 
• taking actions related to the “development” or “implementation” of government policy; 
• promoting the foreign policy of another country or a foreign policy that contravenes principles set out in the law; 
• and “interfering with operations of government.” 

It also prohibits soliciting or receiving funds from a foreign source to engage in “disruptive activities,” which are broadly defined and include actions such as employing a person who promotes the interests of a foreigner or participating in an unlawful assembly. This vague language provides wide discretion to the authorities to arbitrarily enforce these provisions against disfavored people or groups. 

5. The Bill authorizes burdensome, intrusive reporting on foreign funding 

An “agent of a foreigner” must submit a declaration of its sources of funds and returns detailing the amounts and purposes of the funds to the Ministry of Internal Affairs. Any member of the public may inspect the declaration upon payment of a prescribed fee. The Bill does not specify procedural safeguards to protect the privacy of individuals and organizations. This could result in privacy violations and expose people and organizations that are deemed an “agent of a foreigner,” as well as their beneficiaries and funders, to undue risk, especially if the relevant funding relates to activities that are considered sensitive or controversial. 

6. The Bill could cause financial institutions to impose excessive requirements and to “de-risk” 

Under the Bill, “supervised institutions,” such as banks and other entities that facilitate the cross-border transfer of money, may not pay out funds unless an “agent of a foreigner” has declared its sources of funds to the Ministry of Internal Affairs and supplied proof of its registration as an “agent of a foreigner.” Further, a supervised institution must submit a monthly report to the Ministry detailing any funds transferred to an “agent of a foreigner.” Supervised institutions are liable to a fine of up to 200,000 currency points (approximately USD $1,063,000) for violations. This could cause supervised institutions to impose excessive due diligence requirements on transactions or to terminate or restrict their relationships with organizations perceived as high risk. For example, if banks perceive nonprofit organizations as high risk because many of them receive funding from foreign sources, they may restrict or terminate their relationships with nonprofits broadly. This phenomenon, known as “de-risking,” can weaken financial access for the entire sector. 

7. The Bill authorizes invasive inspections 

The Bill allows the inspection of the premises and documents of an “agent of a foreigner” at any time deemed “reasonable” by an inspector. The inspector is authorized to demand any documents or information he or she deems “necessary” and a person who “denies an inspector access” to documents or information or “fails to comply with any order” of the inspector is liable to substantial civil and criminal penalties, including imprisonment. This could open the door to arbitrary inspections and invasive demands for information that put an organization’s staff, beneficiaries, donors, and other stakeholders at risk. 

8. The Bill imposes significant criminal and civil penalties 

Offenses under the Bill are subject to significant criminal and civil penalties. For instance, violating the Bill’s prohibitions on various forms of conduct, such as “promoting the interests of a foreigner,” can result in imprisonment of up to twenty years and a fine of up to 100,000 currency points (approximately USD $532,000) for individuals, and a fine up to 200,000 currency points (approximately USD $1,063,000) for legal entities. These sanctions are disproportionate to the vaguely defined offenses contained in the Bill and could cause a chilling effect on various types of activity as individuals and organizations will fear exposure to these substantial penalties.