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Uganda Protection of Sovereignty Bill 2026: Reflections and Considerations for UK-based INGOs

  • 6 days ago
  • 4 min read
By Janine Edwards, SIDCN Trustee

Summary of discussion points from a joint event hosted by Small International Development Charities Network (SIDCN), South West International Development Network (SWIDN), Hub Cymru Africa, Scotland's International Development Alliance, CADA (Coalition of Aid and Development Agencies NI), and Bond.


Introduction

On 4 June 2026, representatives from UK-based international development organisations joined a discussion exploring the implications of Uganda's recently enacted Protection of Sovereignty Act.

 

The session brought together a range of Ugandan perspectives from civil society, legal, human rights and philanthropy practitioners. In line with the Chatham House Rule, this summary captures key themes and insights from the discussion without attributing comments to individual participants.

 

This summary and any supporting documents are intended to support reflection and dialogue. It does not constitute legal advice, and organisations should seek independent legal counsel regarding their specific circumstances.


What is changing?

Panellists discussed how the Protection of Sovereignty Act introduces a new regulatory framework governing relationships between foreign-funded actors and organisations operating within Uganda.

 

A central concern raised during the discussion was the breadth and ambiguity of several provisions within the legislation. Panellists noted that the law introduces new reporting and registration requirements for organisations and individuals receiving funding from outside Uganda, while also creating significant uncertainty regarding interpretation and enforcement.

 

Several contributors situated the legislation within a broader trend of increasing restrictions on civic space in Uganda over the past decade, alongside similar developments seen in other countries.


Who may be most affected?

While the legislation potentially affects a wide range of organisations, participants highlighted particular concerns for:


  • Human rights organisations

  • Governance and democracy initiatives

  • Women's rights and gender justice organisations

  • LGBTIQ+ organisations

  • Organisations supporting sex workers and other marginalised groups

  • Grassroots organisations heavily dependent on international funding


A recurring theme was that legal and operational risks are likely to be borne primarily by local organisations and their leadership rather than by international funders themselves.

 

Participants also noted concerns that uncertainty alone may have a chilling effect, leading organisations to delay activities, alter programming or self-censor even before enforcement mechanisms become fully established.


Implications for Civil Society

The discussion highlighted several potential consequences for civil society organisations operating in Uganda:


  • Increased compliance burden:
    • Organisations may face additional registration, reporting and disclosure requirements, creating administrative demands and increasing operational costs.

  • Reduced civic space:
    • Participants expressed concern that the legislation could further restrict the operating environment for organisations engaged in advocacy, rights-based work and social accountability initiatives.

  • Heightened risk for local leaders:
    • Particular concern was raised regarding the personal exposure of local directors, trustees and organisational leaders who may carry legal responsibility under the legislation.

  • Impact on vulnerable communities:
    • Many participants felt that organisations serving already marginalised communities may face the greatest challenges, particularly where alternative funding sources are limited.


What does this mean for UK-based INGOs?

A strong message emerging from the discussion was that international organisations should avoid responding by withdrawing from Uganda or reducing support to local partners.


Instead, participants encouraged organisations to consider how they can:


  • Strengthen equitable partnerships:
    • This includes moving beyond transactional funding relationships towards partnerships characterised by trust, mutual accountability and shared decision-making.

  • Share risk more fairly:
    • Several contributors highlighted the importance of recognising that local partners often bear disproportionate levels of legal and operational risk. Organisations were encouraged to review whether existing approaches inadvertently transfer risk onto local actors.

  • Maintain flexibility:
    • Participants emphasised the value of flexible funding arrangements that allow local organisations to respond to changing circumstances without excessive restrictions.

  • Listen to local leadership:
    • Organisations were encouraged to create opportunities for local partners to shape organisational responses and articulate the support they need.


Funding and sustainability considerations

The discussion also explored how organisations may need to think differently about funding models in the future.


Key themes included:


  • Increasing investment in local resource mobilisation.

  • Supporting community philanthropy and local fundraising initiatives.

  • Exploring community foundations and locally controlled funding mechanisms.

  • Supporting income generating activities.

  • Reducing long-term dependence on international aid.

  • Considering alternative financing structures where appropriate and legally compliant.

 

Participants emphasised that while alternative funding mechanisms may provide short-term options, strengthening local fundraising ecosystems is likely to be a more sustainable long-term strategy.


Suggested next steps

  • Seek independent legal advice on the implications of the legislation.

  • Engage in open dialogue with Ugandan partners regarding risks, concerns and possible responses.

  • Review partnership agreements, funding arrangements and organisational risk frameworks.

  • Consider how local partners can be more actively involved in shaping organisational responses.

  • Explore opportunities to support local fundraising and community-led resource mobilisation.

  • Continue monitoring developments as further guidance, interpretation and implementation emerge.


Closing reflection

A consistent theme throughout the discussion was that this moment calls for thoughtful adaptation rather than retreat. Panellists emphasised the importance of maintaining support for Ugandan civil society, listening to local voices, and ensuring that responses are guided by partnership, solidarity and a commitment to locally led development.


Further resources and links referenced during the discussion can be found below.


Summary of legal implications of the bill - Briefing for NGOs:

Final version of the bill with track changes to show what changed:

Let's Walk Uganda: Analysis report of the PSA in regards to LGBTIQ:

 
 
 

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