General Comment No. 38 on the Right to Freedom of Association
ICNL Resources and Contributions
PUBLISHED: NOVEMBER 2023 / UPDATED: JULY 2026
The International Center for Not-for-Profit Law (ICNL) has been actively engaged in the development of the UN Human Rights Committee’s General Comment No. 38 on the right to freedom of association under Article 22 of the International Covenant on Civil and Political Rights (ICCPR).
Since 2023, ICNL has worked with partners, experts, and civil society organizations to support the Committee’s efforts by contributing legal analysis, convening expert consultations, and submitting recommendations throughout the drafting process.
This page brings together ICNL’s key resources and submissions related to the development of General Comment No. 38
ICNL’s Contributions
2023
- Advocated for the development of a General Comment alongside the European Center for Not-for-Profit Law (ECNL) and a coalition of civil society and academic partners.
- Published Relevant Sources of Law on Article 22 ICCPR Right to Freedom of Association, a comprehensive compilation of UN jurisprudence and standards to support the Committee’s work.
2024
- Published a Just Security article explaining why a General Comment on freedom of association was needed and the issues it should address.
2025
- Submitted recommendations to the Human Rights Committee identifying priority issues that should be addressed in General Comment No. 38.
2026
- Convened consultations on:
- Technology and the right to freedom of association
- Interest representation and lobbying
- Environmental defenders
- Submitted detailed comments on the Committee’s Draft General Comment No. 38.
- Coordinated and submitted a second set of comments on behalf of a coalition of civil society organizations and academic institutions.

Links to Resources
2023 Report: Relevant Sources of Law on Article 22 ICCPR: Right to Freedom of Association (2023) 2023 SUMMARY CHART of report 2024 Article (published in Just security): Civil Society, Under Threat Worldwide, Needs a General Comment on the Right to Freedom of Association 2026 ICNL submission to the Draft General Comment No. 38 on the Right to Freedom of Association 2026 coalition comments to DGC No. 38Related Articles
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