1. Introduction
1.1 The East and Horn of Africa Human Rights Defenders Project (DefendDefenders) is a regional civil society organisation (CSO) registered and based in Uganda. Established in 2005, DefendDefenders seeks to strengthen the work of human rights defenders (HRDs) throughout the East and Horn of Africa sub-region by reducing their vulnerability to the risk of persecution and by enhancing their capacity to defend human rights effectively. DefendDefenders focuses its work on 12 countries including Rwanda.
1.2 The Observatoire des Droits de l’Homme au Rwanda (ODHR) is a non-governmental organisation (NGO) created and based in Paris/France since 2018. Its actions are mainly focused on the situations of human right in Rwanda and impunity in the Great Lakes Region of Africa. Its missions include protection and advocacy for HRDs at risk in Rwanda.
1.3 In this submission, we examine the government of Rwanda’s compliance with its international human rights obligations to create and maintain a safe and enabling environment for civil society. Specifically, we analyse Rwanda’s record with regard to the rights to freedom of association, peaceful assembly and expression, as well as to HRDs since its previous Universal Periodic Review (UPR) in January 2021. To this end, we assess Rwanda’s implementation of recommendations received during the 3rd UPR cycle relating to these issues and provide follow-up recommendations.
1.4 During the 3rd cycle, the government of Rwanda received 42 recommendations relating to civic space. Of these, it accepted 18 and noted 24. Our assessment demonstrates that the government of Rwanda has fallen behind in its commitments to implement these recommendations. While the government has persistently failed to address unwarranted restrictions on civic space since its last UPR review, acute implementation gaps exist with regard to freedoms of association and expression.
1.5 We are gravely concerned by the adoption of the new Non-Governmental Organisation (NGO) Law No. 058/2024, which significantly expands state control over civil society. The law grants the Rwanda Governance Board (RGB) broad discretionary powers to interfere directly in the internal governance of NGOs, including authority to approve or remove leadership, dictate organisational changes, and suspend operations on vaguely defined grounds.
1.6 We are deeply alarmed by the government’s systematic repression of political opponents, HRDs, and independent journalists through pervasive surveillance, arbitrary detention, politically motivated prosecutions, torture, enforced disappearances, and
cross-border abductions.
1.7 As a result of these issues, civic space in Rwanda is currently classified as ‘repressed’ by the CIVICUS Monitor, indicating the existence of significant/severe civic space restrictions.[i]
● Section 2 of this submission examines Rwanda’s implementation of UPR recommendations and compliance with international human rights standards concerning the right to freedom of association.
● Section 3 focuses on the right to freedom of peaceful assembly.
● Section 4 focuses on the right to freedom of expression, and media freedom.
● Section 5 focuses on the protection of HRDs including civil society activists and journalists.
● Section 6 contains recommendations to address the concerns raised and advance implementation of recommendations under the 3rd cycle.
●An annex assessing implementation of 3rd cycle UPR recommendations related to civic space is in Section 7.
2. Freedom of association
2.1 During Rwanda’s 3rd UPR review, the government received 16 recommendations concerning the right to freedom of association and the creation of an enabling environment for civil society organisations (CSOs). The government pledged to “review the registration requirements for local and international NGOs with a view to better facilitating and simplifying the process” and to “guarantee the freedoms of assembly, association and expression by, inter alia, increasing the space for dissent and discussion and ensuring a safe and enabling environment for everyone to exercise these rights.” Out of these recommendations, the government accepted nine and noted seven. Despite these commitments, it failed to take adequate measures to realise many of the
recommendations.
2.2 Article 39 of the Constitution of Rwanda and Article 22 of the International Covenant on Civil and Political Rights (ICCPR), to which Rwanda is a Party, guarantee the right to freedom of association. In practice, however, the government systematically interferes in the work of CSOs, particularly those seeking to hold authorities accountable or monitor or challenge state policies. It employs legal and extra-legal measures, including infiltration and surveillance, to create an environment of intimidation and fear. As a result, many organisations engage in self-censorship to avoid reprisals.[ii]
2.3 In 2024, Rwanda enacted Law No. 058/2024 governing NGOs, which replaces previous regulations.[iii] The government claimed that the new law streamlines registration, enhances transparency, and strengthens accountability for NGOs. We acknowledge limited positive elements, such as the removal of district-level reporting approval requirements. However, Law No. 058/2024 falls significantly short of safeguarding the right to freedom of association and instead introduces new avenues for state interference and control over civil society. The RGB retains broad discretionary powers over the regulation of NGOs, without independent oversight or appeal mechanisms. Vague and overly broad provisions allow the government to exert extensive control over CSOs, limiting their independence, internal governance, and ability to engage in advocacy without fear of
reprisals.
2.4 Article 7 authorises the RGB to deny registration based on unclear grounds, including threats to “security, peace, health, unity of Rwandans, public order, good morals, or the rights and freedoms of others.”[iv] The absence of precise legal definitions permits broad and subjective interpretation, exposing organisations, particularly those critical of government policies or engaged in human rights work, to politically motivated repression. The lack of objective criteria or independent oversight further heightens the risk of arbitrary decision-making.
2.5 Beyond registration, the law intrudes into the internal governance and financial autonomy of NGOs. Article 9 imposes a rigid cap of 20% on administrative or overhead costs deemed not to directly benefit programme beneficiaries, disregarding the essential role such expenditures play in sustaining operations.[v] In addition, Article 9 requires prior government approval for internal matters such as leadership appointments, amendments to statutes, and changes to objectives or programmes. These requirements directly interfere with the autonomy of associations to govern their own affairs. Article 12 further prohibits “political activities” and any conduct that may “jeopardise unity, peace, security, good morals, or fundamental rights of others.”[vi] The vague and expansive nature of these prohibitions creates significant legal uncertainty and enables the suppression of legitimate advocacy, particularly where criticism of government action is characterised as “political.”
2.6 The law also grants the RGB extensive authority to impose sanctions on NGOs for broadly defined violations. Articles 42 to 46 empowers the RGB to suspend operations (Article 43), revoke legal status (Article 44), suspend leadership (Article 45), and impose additional administrative sanctions by regulation without parliamentary oversight (Article 46). The absence of timely, impartial, and independent review mechanisms undermines due process and leaves organisations vulnerable to unchecked executive
authority.
2.7 On 17 March 2025, Rwanda severed diplomatic relations with Belgium, expelling Belgian diplomats after accusing Belgium of undermining Rwanda’s position in the conflict in the Democratic Republic of the Congo (DRC).[vii] As a result, on 27 March 2025, the RGB issued a sweeping directive prohibiting all international and national NGOs, faith-based organisations, and foundations registered in Rwanda from engaging in any cooperation with the government of Belgium or its affiliated institutions.[viii] The directive ordered the immediate suspension of partnerships, projects, financial transactions, and ongoing collaborations involving Belgian entities. The RGB warned that non-compliance would result in severe consequences, including suspension of registration, revocation of legal status, and additional legal or administrative sanctions.
2.8 Although Article 54 and 55 of the Constitution of Rwanda guarantees the right to form, join, and operate political parties, the government maintains strict control over the political space. It employs legal and judicial measures to obstruct, intimidate, and silence political opponents.[ix]
2.9 Barriers to electoral participation remain systemic. In the lead-up to presidential elections, independent candidates regularly faced disqualification on technical grounds. In the most recent electoral cycle, six individuals submitted their candidacies to the National Electoral Commission (NEC); all were disqualified due to alleged administrative irregularities such as incomplete documentation, insufficient supporting signatures, or minor procedural errors.[x] Among those disqualified were Diane Rwigara and Fred Sekikubo Barafinda, both of whom had previously been blocked from running in the 2017 elections, under similar circumstances. These restrictions undermine their right to participate in public affairs, as protected under Article 25 of the ICCPR.
2.10 Judicial restrictions further prevent opposition leaders from exercising their political rights. On 13 March 2024, a Rwandan court upheld the ban on opposition leader Victoire Ingabire’s candidacy, citing her prior convictions for “terrorism” and “genocide denial.”[xi] Authorities had arrested Ingabire in 2010 after her public criticism of President Kagame’s government. Although she received a presidential pardon in 2018, after serving eight years of a 15-year sentence, the court denied her application for rehabilitation, finding she had not fulfilled all conditions set under the presidential order. Without rehabilitation, she remains barred from standing for public office due to legal prohibitions against candidates previously sentenced to six months or more of imprisonment.
3. Freedom of peaceful assembly
3.1During Rwanda’s 3rd UPR, the government received eight recommendations concerning freedom of peaceful assembly. Among these, it committed to “promote and protect the right to freedom of expression and peaceful assembly of all residents of Rwanda” and to “intensify its efforts to ensure full enjoyment of the rights to freedom of expression, peaceful assembly and association.” The government accepted six recommendations and noted two. It has taken no concrete steps to implement the recommendations
3.2 Article 21 of the ICCPR and Article 40 of the Rwandan Constitution both enshrine the right to peaceful assembly. In practice, however, this right remains heavily restricted. Public assemblies and demonstrations require prior authorisation from state authorities. In most cases, requests for authorisation are denied, effectively prohibiting both planned and spontaneous gatherings and meetings.[xii] Additionally, the persistent risk of arrest and prosecution deters individuals and organisations from exercising their right to peaceful assembly, resulting in widespread self-censorship and limited public demonstrations within the country.
3.3 Although the Constitution guarantees the right to peaceful assembly, Law No. 68/2018 Determining Offences and Penalties in General imposes significant limitations on its exercise.[xiii] The law fails to recognise or permit spontaneous demonstrations, thereby restricting the practical enjoyment of this right. Individuals who participate in assemblies that do not comply with the strict legal requirements, even if they are entirely peaceful, face severe penalties. Under Article 225 of Law No. 68/2018, individuals convicted of participating in protests deemed to “threaten” security, public order, or health may face prison sentences ranging from six months to one year, alongside fines between 3,000,000 and 5,000,000 Rwandan francs (approximately US$2,102 to US$3,504).[xiv] These punitive sanctions discourage the exercise of the right to peaceful assembly and contribute to a climate of fear and self-censorship. Consequently, public protests within Rwanda are rare. Demonstrations critical of government policies mostly occur among diaspora communities abroad.
4. Freedom of expression, media freedom and access to information
4.1 During Rwanda’s 3rd UPR, the government received 31 recommendations relating to the right to freedom of expression, media freedom and access to information. Among other things, the government pledged to “eliminate from legislation all provisions that undermine freedom of expression and the protection of journalists against harassment and intimidation’’ and “revise all the provisions that undermine freedom of expression as well as freedom of assembly and association and effectively protect journalists and media operators against harassment and intimidation”. Of the recommendations received, the government accepted 14 and noted 17. However, the government did not take effective measures to implement these recommendations.
4.2 Article 19 of the ICCPR and Article 38 of the Constitution of Rwanda guarantee the right to freedom of opinion and expression. In practice, however, the government imposes extensive restrictions through broadly framed limitations. For instance, constitutional provisions subject freedom of expression to limitations on vague grounds, such as “public order,” “good morals,” “the protection of youth and children,” and “the right to honour and dignity,” without providing clear definitions or adequate legal safeguards. Authorities routinely target journalists, HRDs, and political opponents who express critical views. Many face harassment, arbitrary arrest, politically motivated prosecutions, and, in some cases, enforced disappearances or extrajudicial killings.[xv] Independent media outlets operate under constant pressure, while the persistent threat of reprisals fosters widespread self-censorship, stifling open public
discourse.
4.3 The Law on the Prevention of Cybercrime (No. 60/2018) criminalises the dissemination of “rumours,” punishable by up to five years’ imprisonment and fines of up to 3’000’000 Rwandan francs (approximately US$ 2,000).[xvi] The same law imposes sentences of 15 to 20 years and fines between 20’000’000 and 50’000’000 Rwandan francs (approximately US$ 14,000 to US$ 35,000) for anyone who “establishes, publishes, or uses a site of a terrorist group” (emphasis added). By designating many exiled opposition organisations as “terrorist groups,” the government uses this provision to suppress political dissent and silence opposition both domestically and abroad.
4.4 The Information Communication and Technology (ICT) Law (No. 24/2016) introduces further restrictions on online expression. It criminalises the dissemination of “grossly offensive” or “indecent” content and the use of ICTs to cause “annoyance, inconvenience, or needless anxiety.”[xvii] These vague provisions enable the criminalisation of online speech and expand state surveillance powers. Section 123 of the law requires all electronic communication service providers to install interception capabilities that allow government monitoring of private communications, undermining privacy and further limiting digital freedoms.[xviii]
4.5 The Media Law (No. 02/2013), while presented as a framework to protect press freedom, places extensive control over the media sector in the hands of state authorities. It grants the government authority to licence new media outlets and requires journalists to obtain accreditation from state institutions, rather than through independent, self-regulatory bodies. Journalists face imprisonment for offences such as “libel,” “genocide ideology,” undermining “state security,” or disseminating “false testimony.”[xix] The amended law on “genocide ideology” (2013) is particularly problematic, prescribing prison terms of up to nine years for those found guilty of disseminating “genocide” ideology by any means, yet offering no precise definitions. This enables the state to arbitrarily prosecute journalists, critics, and opponents, thereby undermining freedom of expression both online and offline.
4.6 Journalists face the risk of arbitrary arrest and prosecution on politically motivated charges. On 9 October 2024, a court sentenced YouTuber and government critic Rashid Hakuzimana to seven years in prison for allegedly “denying” the 1994 genocide, “inciting ethnic division,” and spreading “false information.” Hakuzimana was arrested in 2021 and denied the charges, claiming his detention followed his criticism of President Paul Kagame’s government in his YouTube videos. The judge claimed Hakuzimana’s remarks, such as suggesting genocide orphans were neglected compared to officials’ children, created “division.” Having already served three years; he will spend four more in prison and pay a $700 fine.
4.7 In February 2021, police arrested YouTuber Yvonne Idamange Iryamukwiza after she posted videos criticising President Kagame. She was charged with “spreading rumours” using technology, “contempt” for genocide memorials, and “obstruction of government policies.”[xx] In October 2021, security forces arrested Théoneste Nsengimana, director of Umubavu TV, for attempting to organise “Ingabire Day” in support of political prisoners. Authorities charged him with “membership of a criminal group,” “dissemination of propaganda,” and “incitement to unrest.” Both remain in detention.[xxi]
4.8 In November 2021, the High Court sentenced YouTuber Dieudonné Niyonsenga (Ishema TV) to seven years’ imprisonment for reporting on alleged military abuses, convicting him of “forgery,” “usurpation of titles,” “impersonation,” and “humiliating” state officials.[xxii] In 2024, Niyonsenga testified before the court about torture, beatings, and denial of medical care while in detention, yet authorities failed to act on his claims.[xxiii] Similarly, in May 2022, YouTuber Aimable Karasira reported being tortured and denied medical treatment while in prison, where he remains detained on charges of “genocide denial.”[xxiv]
4.9 Digital repression extends to shutting down critical platforms. In January 2022, YouTube channels belonging to critics, including Iris TV, Yago TV, Primo TV, and Shema TV, were deactivated or hacked. While the government denied involvement, victims alleged state complicity in targeting online dissent.[xxv]
4.10 The government also obstructs independent reporting by foreign journalists perceived to be critical of it. In June 2022, the Commonwealth Secretariat, in coordination with Rwandan authorities, denied accreditation to Canadian journalist Benedict Moran and Indian journalist Anjan Sundaram during the Commonwealth Heads of Government Meeting summit.[xxvi] Both journalists had previously published internationally recognised work critical of the Rwandan government. In August 2022, the Rwanda Media Commission similarly denied accreditation to Byline Intelligence journalist Iain Overton for reporting on refugee rights.[xxvii]
5. Harassment, intimidation and attacks against human rights defenders, civil society activists and journalists
5.1 Under Rwanda’s previous UPR, the government received 12 recommendations on the protection of HRDs, journalists and civil society representatives. The government committed to “strengthening media pluralism and the safety of journalists and [HRDs] by amending the respective legislation to comply with international democratic standards.” Of the recommendations received, the government accepted only two and noted 10. However, the government has failed to operationalise these recommendations.
5.2 The ICCPR guarantees the freedoms of association, peaceful assembly and expression. Article 12 of the UN Declaration on Human Rights Defenders requires states to take the necessary measures to ensure the protection of HRDs. Despite these obligations, the Rwandan government continues to subject HRDs, civil society activists, and journalists to harassment, intimidation, and reprisals. Those who document human rights violations, expose corruption, or criticise state policies face arbitrary arrest, surveillance, smear campaigns, enforced disappearances, and, in some cases, extrajudicial killings. This pervasive climate of fear has forced many HRDs into exile, while those remaining in the country operate under constant threat, severely undermining their ability to carry out legitimate human rights work.[xxviii]
5.3 Despite Rwanda’s legal obligations to protect the rights to freedom of expression, association, and assembly, authorities systematically targeted HRDs, journalists, and political opponents through surveillance, intimidation, harassment, and extrajudicial actions. In July 2021, Amnesty International and Forbidden Stories revealed that Rwandan authorities had used NSO Group’s “Pegasus” spyware to monitor and potentially target over 3,500 phone numbers belonging to activists, journalists, political opponents, foreign politicians, and diplomats since 2016.[xxix]
This large-scale surveillance operation exposed the extent to which the government undermined the safety, privacy, and work of HRDs and independent voices.
5.4 The operating environment is not conducive to HRDs’ work, particularly those engaged in documenting human rights violations. On 13 May 2024, the Rwandan authorities denied entry to a Human Rights Watch researcher accusing the organisation of “fabricating reports” and “distorting Rwanda’s image.”[xxx] Prior to her arrival, the researcher had notified officials of her intention to conduct human rights investigations. This denial demonstrated the government’s unwillingness to allow independent scrutiny, particularly amid heightened international attention related to the UK asylum transfer agreement.
5.5 Journalists face continuous threats to their safety. On 19 January 2023, prominent journalist John Williams Ntwali died in suspicious circumstances after a speeding vehicle struck the motorcycle he was riding as a passenger. Ntwali, founder of Pax TV-IREME News and editor of The Chronicles, had been outspoken about human rights abuses and had
received multiple death threats.[xxxi] Just days before his death, he had publicly expressed fears for his life. Although authorities ruled his death a road accident, human rights organisations raised concerns about possible foul play.
5.6 The government’s repression extended beyond Rwanda’s borders, targeting exiled political opponents and journalists abroad. On 21 February 2021, opposition politician Seif Bamporiki was shot dead in South Africa. Although local police initially suggested robbery as a motive,
Bamporiki’s party, the Rwanda National Congress (RNC), argued that his killing bore striking similarities to other politically motivated assassinations such as the 2014 murder of former Rwandan intelligence chief Patrick Karegeya, who was found strangled in a Johannesburg hotel.[xxxii]
5.7 Similarly, on 23 May 2021, plain-clothed officers in Mozambique allegedly abducted exiled journalist Cassien Ntamuhanga and handed him over to the Rwandan embassy in Maputo. The officers confiscated his personal documents, refugee card, and travel papers.[xxxiii] Ntamuhanga, director of Amazing Grace Radio, was previously sentenced in absentia to 25 years in prison for allegedly conspiring against the government. After fleeing Rwanda in 2017,[xxxiv] he sought refuge in Mozambique, but his forced return raised serious concerns of unlawful extradition, in a broader context of transnational repression.
6. Recommendations to the government of Rwanda
DefendDefenders and ODHR call on the government of Rwanda to create and maintain, in law and in practice, an enabling environment for civil society, in accordance with the rights enshrined in the ICCPR, other legal instruments, the UN Declaration on Human Rights Defenders and various Human Rights Council resolutions. At a minimum, the following conditions should be guaranteed: the freedoms of association, peaceful assembly and expression, the right to operate free from unwarranted state interference, the right to communicate and cooperate, the right to seek and secure funding and the state’s duty to protect. In the light of this, the following specific recommendations are made:
6.1 Freedom of association
● Take measures to foster a safe and enabling environment for civil society, including by removing legal and policy measures that unwarrantedly limit the freedom of association.
● Remove all undue restrictions on the ability of CSOs to receive international and domestic funding in line with best practices articulated by the UN Special Rapporteur on the Rights to Freedom of Peaceful Assembly and of Association.
● Amend the NGO Law (Law No. 04/2024) to bring it into full compliance with international human rights standards by eliminating vague and overly broad provisions such as “good morals” and “political activities”, which enable arbitrary restrictions.
● Establish independent, impartial oversight and appeal mechanisms to review all decisions made by the Rwanda Governance Board.
● Ensure the full administrative and financial independence of civil society organisations by removing the discretionary powers granted to the Rwanda Governance Board that allow unwarranted interference in internal governance, leadership appointments, and financial management, in the absence of adequate judicial oversight.
6.2 Freedom of peaceful assembly
● Adopt best practices on the freedom of peaceful assembly, as put forward by the 2012 report of the UN Special Rapporteur on the Rights to Freedom of Peaceful Assembly and of Association, which calls for simple processes for the notification of assemblies being held rather than permission being required, and by General Comment No. 37 on the right to peaceful assembly adopted by the UN Human Rights Committee in 2020.
● Amend Law No. 68/2018 Determining Offences and Penalties in General and take other measures necessary to ensure that all individuals, CSOs and political parties fully enjoy, in practice, their rights to the freedoms of association, peaceful assembly and expression, including by guaranteeing that any restrictions on the exercise of such rights comply with the strict requirements set out in the Covenant
● Provide recourse to judicial review and effective remedy, including compensation, in cases of unlawful denial of the right to the freedom of peaceful assembly by state authorities.
● Revise national legislation to allow for peaceful spontaneous assemblies without prior authorisation, in line with international and African standards, and ensure that prior notification procedures do not operate as de facto authorisation requirements that can be arbitrarily denied.
● Ensure that any limitations on peaceful assemblies are strictly necessary, proportionate, and prescribed by law, and establish independent, impartial judicial oversight of any decisions restricting or prohibiting assemblies.
6.3 Freedom of opinion and expression
● Ensure the freedom of expression and media freedom by all bringing national legislation into line with international standards.
● Ensure that journalists and writers may work freely and without fear of reprisals for expressing critical opinions or covering topics that the government may deem sensitive.
● Take steps to ensure that all individuals can fully exercise their right to the freedom of expression without intimidation or harassment; in this regard, revise and reform the Penal Code and national security laws to ensure that provisions related to criminal libel and insult are consistent with international human rights obligations.
● Review and amend restrictive provisions of the Law on Prevention and Punishment of Cybercrimes to ensure they conform with international human rights obligations.
● Amend restrictive provisions of the revised Penal Code, Information and Technology Law and Law on Prevention and Punishment of Cybercrimes to provide a favourable space for the freedom of expression and media freedoms.
● Develop and implement an action plan to ensure that internet laws comply with the government’s commitment to guarantee the freedom of expression, media freedom and access to information, including by ensuring free access to electronic media, ceasing censorship and surveillance, liberalising electronic media ownership rules and enabling journalists, bloggers, and other internet users to play a full and active role in promoting and protecting human rights.
● Implement legislative measures to enable access to information and establish mechanisms to facilitate public access, in line with international best practices.
● Refrain from adopting any laws providing for censorship or undue control over social and conventional media content.
● Refrain from censoring social and conventional media and ensure that the freedom of expression is safeguarded in all arenas, including in the arts.
6.4 Protection of human rights defenders
● Provide civil society members, HRDs and journalists with a safe and secure environment in which to carry out their work, conduct impartial, thorough and effective investigations into all cases of attacks, harassment and intimidation against them, and bring the perpetrators of such offences to justice.
● Ensure that HRDs can carry out their legitimate activities without fear or undue hindrance, obstruction, or legal and administrative harassment.
● Undertake a consolidated process of repeal or amendment of legalisation and decrees that unwarrantedly restrict the legitimate work of HRDs, in line with the UN Declaration on Human Rights
Defenders.
●Immediately and unconditionally release all HRDs, including journalists and bloggers detained for exercising their fundamental rights to the freedoms of association, peaceful assembly and expression, and review their cases to prevent further harassment.
● Publicly condemn at the highest levels of government instances of harassment and intimidation of CSOs and activists.
Systematically apply legal provisions that promote and protect human rights and establish mechanisms that protect HRDs, including by adopting a specific law on the protectio