Published October 2026

Syria’s draft NGO law presents an important opportunity to establish a legal framework that supports independent civil society and its role in the country’s recovery. While the draft includes welcome protections for freedom of association, several provisions could restrict how organizations form, operate, access funding, and cooperate internationally.

WHAT THE DRAFT GETS RIGHT
Guarantees freedom of association and NGO independence Art. 2	Protects expressive and opinion activities, including advocacy and research Arts. 7, 10	Requires a final court ruling before involuntary dissolution Art. 31	Offers tax incentives for donations and public-benefit work Arts. 182–189

Among other issues, we highlight eight concerns with the draft NGO law

1. Informal groups would be penalized for operating unregistered

The draft bars public activities before registration and requires prior approval of voluntary temporary initiatives by “a number of people” to serve the community (Arts. 23, 111, 194(3)(a)). The UN Human Rights Committee has repeatedly found mandatory registration incompatible with Article 22.^[i] As drafted, the law appears to require prior approval even for a neighborhood park cleanup.

2. Foreign funding would need prior government approval

Every bank transfer from an account outside Syria, whether in the form of an individual payment or as part of a fundraising campaign, would need Ministry of Foreign Affairs approval (Art. 181(9)), with the rules on foreign donations left to regulations (Arts. 168, 181(10)). Access to domestic, foreign, and international resources is integral to freedom of association.^[ii] Prior approval should be replaced by proportionate annual reporting.

3. Who can found or join an NGO would be limited

The draft requires a minimum of seven founders. Founders and members must also be Syrian citizens, over the age of 18, and must have a clean criminal record. Freedom of association extends to everyone, including foreign nationals and youth.^[iii] A past conviction alone should not cause someone to lose their right to form or join an association, as this would exclude a broad group of people, including those convicted of minor offenses or later rehabilitated.

4. Registration could take over seven weeks, with no fundraising or public activities in the meantime

Authorities would have up to 50 working days to review and approve a new NGO’s registration (Art. 20); best practice is under 30 days. Providing temporary legal status during this review is welcome, but organizations are not able to raise or manage funds or organize public activities during this review period. Organizations should be able to fully operate as a legal entity as soon as they receive temporary legal status.^[iv]

5. Authorities could interfere in NGOs’ internal affairs

An NGO’s bylaw amendments would need government approval (Art. 22); notification should suffice. The draft law would authorize employees of the administrative body to enter the premises of any NGO after a 3-day notice period to review its records (Art. 128). While independent bodies have the right to examine the associations’ records as a mechanism to ensure transparency and accountability, such a procedure should not be arbitrary and must respect the principle of non-discrimination and the right to privacy.^[v] In addition, NGOs need sufficient time to review the scope and subject of the audit and request the presence of their auditors and legal representatives.

6. International cooperation would be both encouraged and restricted

The draft welcomes cooperation with international NGOs (Arts. 4, 6) yet requires prior approval before an NGO could participate or affiliate with an NGO based outside of Syria (Art. 194(3)(b)). The chapter on foreign NGOs is still under discussion with the Ministry of Foreign Affairs and should be completed before adoption.

7. Vague suspension powers could sidestep the courts

Despite the important safeguard of requiring a final judicial ruling before an NGO can be involuntarily dissolved (Art. 31), authorities could suspend activities or intervene in an NGO’s financial management based on vague grounds (Arts. 134, 138, 191) without prompt judicial review.

8. The draft is incomplete, and the consultation period is too short

Key chapters remain unfinished, and many details are deferred to future regulations. NGOs should be able to review a complete draft and have more than 30 days to provide feedback. A transparent consultation process, followed by careful legal and technical review, would clarify ambiguities, strengthen safeguards against arbitrary interference, and create a more predictable environment for independent civil society.

Syria has an opportunity to establish a legal framework that protects independent civil society and supports its contribution to the country’s recovery.

Addressing these eight concerns through meaningful consultation and targeted revisions would help ensure that the new law enables, rather than restricts, civil society organizations.

For more information or a detailed analysis, contact Haneen Bitar, Senior Legal Advisor – MENA, at hbitar@icnlalliance.org or Kristen McGeeney at kmcgeeney@icnl.org.

References

[i] ↑ United Nations General Assembly, “Lebanon,” Report of the Human Rights Committee: Volume 1 (A/52/40) (1 January 1997), paragraphs 357–358; and United Nations General Assembly, “Lithuania,” Report of the Human Rights Committee: Volume 1 (A/53/40) (15 September 1998), para. 177.

[ii] ↑ United Nations General Assembly, Report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association, Maina Kiai, U.N. Doc. A/HRC/23/39 (2013), para. 8.

[iii] ↑ UN Special Rapporteur, Report on the right to freedom of association of migrants and their defenders, available online at UN Report; and Convention on the Rights of the Child, art. 15, adopted 20 November 1989, 1577 U.N.T.S. 3 (ratified by Syria in 1993); status available at UN Treaty Collection.

[iv] ↑ United Nations General Assembly, Report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association, Maina Kiai, U.N. Doc. A/HRC/20/27 (2012), para. 58.

[v] ↑ United Nations Human Rights Council, A/HRC/20/27, “Report of UN Special Rapporteur on the rights to freedom of peaceful assembly and of association, Maina Kiai,” May 21, 2012, para. 65.