The Civil Societies Proclamation No. 1113/2019 (the “2019 Proclamation”) marked a clear legal break with Ethiopia’s repressive 2009 Charities and Societies regime and reopened important spaces for civic organization, international partnership, and advocacy. On paper, the 2019 law corrected many of the most damaging features of the 2009 legislation and established a formal regulator—the Ethiopian Authority for Civil Society Organizations (ACSO)—to streamline registration and oversight.
In practice, however, the gains from 2019 have been uneven and fragile. Implementation delivered measurable openings—including thousands of re-registrations and new CSO formations in the immediate aftermath of reform—but those openings were never fully consolidated into durable, rights-protecting institutions. Political polarization, war since 2020, inconsistent institutional capacity, and the continued use of vague “national security” and “public interest” tests have produced selective enforcement, ad hoc suspensions, and legal uncertainty for many organizations.
The 2025 draft amendments published this year would, if enacted in their current form, institutionalize many of the very powers that the 2019 law had reduced: broader suspension and asset-freeze powers for ACSO on the basis of mere “suspicion,” restrictions on foreign and diaspora funding for organizations engaged in governance and election-related work, reduced civil society representation on the regulator’s board, and the effective elimination of independent judicial appeal from ACSO decisions.
This article explains what changed in 2019, why implementation fell short, what the 2025 draft amendments actually propose, and the likely political, operational and legal consequences if those amendments are adopted. It concludes with evidence-based policy suggestions for lawmakers, donors and civil society actors that aim to preserve the practical gains of 2019 while addressing legitimate regulatory concerns.
The 2019 Proclamation: design, intent, and early outcomes
Ethiopia’s 2019 Proclamation repealed the highly restrictive 2009 Charities and Societies Proclamation allegedly to align domestic law more closely with internationally recognized protections for freedom of association. The law revised definitional categories, removed categorical bans on rights-based activity for foreign-funded organizations, and established ACSO to professionalize registration, oversight and support functions.
Early, measurable effects were significant. Within a short period after enactment many organizations moved to re-register or to register anew. A UN Women mapping exercise reported a large number of re-registrations and new registrations in the first months and years after the Proclamation entered into force, showing both renewed organizational activity and a recovery of previously constrained operational modalities.
International civil society and democratic governance observers generally welcomed the reform as a corrective to the 2009 law, noting that the 2019 text provided improved clarity on permissible activities and administrative norms while opening the door for a wider ecosystem of rights-based and service-delivery organizations. The formal establishment of ACSO was also read as a sign that oversight would become more professional and transparent over time.
Why the 2019 gains did not fully consolidate: implementation dynamics and political constraints
The legal text of 2019 was necessary but not sufficient to secure a stable, rights-respecting operating environment for civil society. Three interlocking factors explain why the law’s potential was only partially realized.
First, institutional capacity and regulatory practice lagged behind statutory reform. ACSO and related implementing mechanisms required rule-making, staffing and regional harmonization that did not keep pace with demand. Incomplete or delayed implementing regulations, uneven guidance from ACSO to regional offices, and limited institutional resources meant that many organizations continued to operate amid procedural ambiguity. The uneven roll-out amplified enforcement discretion and produced divergent outcomes across regions and sectors.
Second, the political environment deteriorated after 2019 in ways that directly affected civic space. Between 2020 and 2024 Ethiopia experienced renewed armed conflict and heightened polarization. Human Rights Watch and other monitors have documented episodes in which suspensions, asset freezes, and restrictions were applied to organizations working on governance, human rights, or conflict-sensitive reporting—practices that reveal how statutory discretion can be deployed punitively when political will favors control over protection.
Third, the country’s accountability architecture—chiefly judicial capacity to provide prompt, independent review of administrative measures—has not consistently functioned as an effective backstop. Where the law allowed for appeal in principle, practical barriers to swift legal recourse (lengthy court processes, costs, and lack of judicial independence in politically charged cases) have weakened the procedural protections that the 2019 Proclamation promised on paper. Civil society actors have reported that recourse to courts often came too late to avert de facto shutdowns or serious operational harm.
Taken together, these implementation dynamics explain why the 2019 Proclamation created a window for expanded civic activity without cementing a reliably protective regime. The legal structure was fragile in a polarized environment; where the political calculus favored control, the state retained tools—and the political impetus—to constrain organizations despite the reformed text.
The 2025 draft amendments: what they would change and where the risks lie
Public reporting and civil society analysis of the 2025 draft identify several categories of change that, if enacted, would materially narrow the operating space that the 2019 law created. The draft has been described by multiple independent monitors as shifting authority back toward executive control, expanding discretionary suspension powers, restricting foreign and diaspora funding for governance work, reducing civil society voice within ACSO, and curtailing judicial remedies. Human Rights Watch’s July 29, 2025 statement summarized many of these concerns, noting the draft’s timing ahead of national elections and its potential to silence independent oversight and civic engagement.
One central substantive change reported is the expansion of grounds and mechanisms for suspension. Under the draft, ACSO could issue suspension orders on the basis of “suspicion” that a serious legal violation may occur or that “irreparable harm” will follow—authority that departs from the more circumscribed suspension powers in the 2019 text and that would allow preventive, rather than corrective, action with asset freezes and immediate operational disruption.
A second major change would be explicit restrictions on foreign and diaspora funding for organizations engaging in governance-related, election-oriented or advocacy work. The proposed amendments would allow the regulator to prohibit foreign funding to groups involved in those activities or to deny registration on grounds that an organization’s work threatens “national security” or the “public interest.” By conflating foreign support with political risk, the draft would reproduce a mechanism previously used to exclude and limit rights-based organizations during the 2009 era. Analysts and international NGOs warn that such restrictions would force many watchdog and civic education activities to shut down or relocate. Human Rights Watch and the Observatory for the Protection of Human Rights Defenders (FIDH–OMCT) have highlighted this issue as a central threat to democratic oversight and civic participation.
The governance architecture of ACSO itself is another flashpoint in the draft. Reports indicate that the amendment would reduce the number and weight of civil society seats on ACSO’s board and increase ministerial appointment powers, concentrating influence with the Ministry of Justice and narrowing independent oversight. FIDH–OMCT’s joint statement and multiple press reports emphasize that this would invert the 2019 intention to create a regulator with meaningful civil society participation. The draft would also curtail judicial appeal rights, rendering ACSO decisions final and eliminating a timely and independent avenue for redress—an outcome critics characterize as a structural removal of checks and balances, even more curtailed than they currently are.
Finally, the draft increases administrative burdens: shorter timelines for reporting on foreign funding, prior approvals for routine operational transactions, and stricter compliance reporting that will raise transaction costs for small and mid-sized organizations. The cumulative effect of these measures is not merely bureaucratic; they are likely to be selective in impact, disproportionately harming organizations without diversified funding or in politically sensitive fields.
Likely consequences if the 2025 amendments are enacted as drafted
If the draft passes in the current form, the consequences will be legal, operational and political. Legally, the elimination of timely judicial appeal and the reallocation of appointment power to government officials would create a regulatory environment in which administrative decisions are effectively final. This removes a core procedural safeguard and increases the risk that suspension, de-registration, or funding bans will be used to silence dissenting voices. Human Rights Watch and the ICNL have explicitly warned that such a legal architecture would be inconsistent with regional and international standards on freedom of association.
Operationally, stricter funding rules and tighter reporting will increase transaction costs for CSOs and create acute liquidity risks. Organizations that rely on foreign or diaspora support for governance, human rights, civic education or election observation may find those activities prohibited or made legally perilous. Donor uncertainty, conditionality and potential extraterritorial relocation of activities would follow. Civil society actors already report heightened concern about sustainability and the possibility of forced exile, closure or self-censorship.
Politically, the timing of the draft—discussed publicly in mid-2025 with national elections scheduled for 2026—raises the risk that the amendments become tools for pre-empting independent election monitoring and civic mobilization. Restrictions on election-related civic activity, when paired with broader suspension powers, would reduce transparency and citizen access to independent information at a crucial democratic juncture. Observers have flagged the amendments as likely to impair election credibility and civic resilience if implemented before the electoral cycle.
Finally, the normative effect of reversing 2019 gains is important even where direct enforcement does not occur. Laws shape expectations: a statutory reversal will chill civic entrepreneurship, shrink the available talent pool for advocacy, and deter international partnerships, thereby producing long-term erosion of civil society capacity that is harder to reverse than any single enforcement action.
How the draft compares to regional and international norms
Prominent international monitoring bodies emphasize that any regulation of civil society must be necessary, proportionate, and accompanied by effective remedies. The draft’s expansion of preventive suspension powers, broad national security language, and removal of effective appeal mechanisms contravene these principles in the view of multiple international NGOs and legal analysts. The ICNL and regional human rights guidance (African Commission on Human and Peoples’ Rights) call for narrow definitions of public order and national security and for guarantees of judicial review; the 2025 draft moves in the opposite direction by enlarging executive discretion and shrinking independent oversight.
Policy suggestions: a rights-consistent pathway to secure regulation without backsliding
Ethiopia’s political leadership, if concerned with legitimate regulatory objectives—transparency, accountability, and prevention of fraud or illicit financing—has options that preserve public order while respecting rights. First, any expansion of suspension powers should be tied to narrow, clearly-defined grounds and mandatory procedural protections, including immediate judicial review and time-limited preventive measures. Second, restrictions on foreign funding for governance or election-oriented work should be replaced with rules requiring transparency of funding sources and activity reporting rather than categorical bans; proportional, targeted measures against proven illicit activity are preferable to broad prohibitions that punish legitimate advocacy. Third, ACSO governance should retain meaningful civil society representation to preserve credibility and technical expertise; reducing civil society seats would erode the regulator’s legitimacy and technical capacity. Fourth, implementation requires investment in ACSO institutional capacity and the publication of clear, accessible implementing regulations, accompanied by public consultations and phased transition periods to reduce compliance shocks. These measures better reconcile state interests and rights protections than the blunt instruments reflected in the draft amendments.
International partners and donors play a role too. Targeted diplomatic pressure that avoids unconditional freezes, conditioned development assistance tied to measurable protections for civic space, and support for legal aid and monitoring coalitions can raise the political cost of legally institutionalized rollbacks while bolstering domestic resilience. Donors should prioritize predictable multi-year funding mechanisms and technical support for compliance that does not erode independence.
Conclusion
The 2019 Proclamation opened a window in Ethiopia’s civic space by removing the most overtly repressive constraints of the 2009 law and by creating a legal framework more consistent with international norms. The law’s promise, however, depended on institutionalization and political commitment. Implementation gaps, judicial bottlenecks, and an increasingly securitized political climate after 2019 left those gains precarious. The 2025 draft amendments—if enacted as currently reported—would codify an executive-heavy model of control, constrict funding and activity for governance and election work, and remove critical safeguards of judicial review and independent oversight. The likely results are legal uncertainty, self-censorship, program disruption, and diminished electoral transparency.
Policymakers who seek to regulate effectively without sacrificing democratic resilience should narrow suspension powers, restore judicial appeal and civil society representation, favor transparency over prohibition for international funding, and invest in ACSO capacity and transparent implementation. These steps would protect state interests while preserving the civic space necessary for accountability, service delivery, and long-term political stability. International partners and donors should align assistance with these normative guardrails and support legal and institutional remedies that secure the 2019 Proclamation’s original promise. For a country whose stability will in large part depend on the capacity of non-state actors to provide services, mediate conflict and hold power to account, shrinking civic space is ultimately self-defeating.
