In April 2026, the systemic crisis regarding freedom of association in Belarus persisted.
The situation remained consistently unfavorable and showed no signs of improvement. Dozens of representatives of civil society organizations (CSOs) continue to be held in places of detention. Independent CSOs continue to operate under conditions of a de facto ban on full-fledged activity within the country, administrative control, the threat of criminal prosecution, and the expanding application of extremism-related legislation. There remains a constant risk of sanctions for activities that do not align with the official expectations of state authorities.
A notable feature of the monitoring period was the further spread of repressive practices to human rights, publishing, socio-cultural, and charitable organizations and initiatives. The cancellation of festivals and events related to national culture continued. The practice of discrediting CSOs in state and propaganda information channels also persists. The state continued to actively use mechanisms for designating organizations and initiatives as “extremist” as a tool to ban their activities, criminalize interaction with them, and intimidate potential participants, partners, donors, and members of target groups. In April 2026 alone, 26 civil society entities were added to the list of “extremist” organizations.
As of the end of April 2026, according to monitoring conducted by Lawtrend, the overall losses in the civil society sector since the post-election period of 2020 amount to at least 2,022 institutionalized NPOs (public associations, trade unions, political parties, foundations, non-governmental institutions, associations).
A separate trend remains the expansion of transnational repression practices. During the monitoring period, cases of the arbitrary invalidation of passports of former political prisoners who had been forcibly expelled from Belarus after their release in September and December 2025 became known. A group of independent UN experts strongly condemned these actions by the Belarusian authorities, calling them a violation of the state’s international obligations.
1. Liquidation of non-profit organizations
During the monitoring period, it became known that one charitable foundation had been liquidated. According to Lawtrend monitoring, from early 2021 through the end of April 2026, at least 1,240 NPOs of various legal forms were forcibly liquidated. At least 782 NPOs (including public associations, associations, foundations, institutions, and political parties) decided to undergo voluntary liquidation.
Thus, in April 2026, the intensity of the liquidation of NPOs decreased significantly. At the same time, mechanisms of forced liquidation, as well as the coercion of NPOs into deciding on voluntary liquidation, remain one of the key instruments of pressure on the civil sector in the country. The practice of previous months, including decisions on the forced liquidation of at least 14 non-governmental institutions, indicates the systemic use of this instrument and its readiness for further application whenever deemed necessary.
Despite the completion of the re-registration process of religious organizations in early July 2025, comprehensive official information on the results of this procedure has not yet been published. In particular, no data has been provided on the number of religious organizations that completed re-registration, those that did not undergo the procedure, those liquidated by court decision, or those that ceased activities voluntarily. The information available on the Commissioner for Religious and Ethnic Affairs’ website remains current only as of the end of 2024.
At a meeting of the board of the Office of the Commissioner for Religious and Ethnic Affairs, as well as in the national report submitted under the Universal Periodic Review (the UPR) procedure, it was stated[1] that all 25 denominations and religious movements confirmed their existence following re-registration. At the same time, available data indicate cases in which certain religious organizations failed to re-register and were subsequently liquidated.
For example, on April 9, 2026, the Supreme Court of the Republic of Belarus considered an appeal by a Greek Catholic parish in Brest against the Brest Regional Court’s decision to liquidate it. The appeal was dismissed, and the liquidation decision entered into legal force. Overall, in the Brest region, all three Greek Catholic (Uniate) religious organizations have been liquidated: the parish in Brest, the Parish of Saints Cyril and Methodius in Baranavichy, and the parish in Ivatsevichy.
According to the official report of the Republic of Belarus submitted to the UPR, the total number of religious organizations decreased from 3,592 to 3,426 due to re-registration, representing a reduction of approximately 4.6%. This decrease may include both cases of refusal of re-registration or failure to submit documents, as well as cases where organizations had effectively ceased operations before the start of the procedure. The absence of detailed statistics makes it impossible to determine the exact proportion of these categories or to identify the full list of religious organizations that did not complete re-registration.
Fragmentary conclusions about the consequences of re-registration can be drawn from information published on regional executive committees’ websites.
According to data[2] from the Hrodna Regional Executive Committee, 483 religious organizations from 14 denominations are currently active in the region, compared to 520 organizations from 16 denominations before re-registration. Thus, the number of organizations decreased by 37, and the number of denominations decreased by 2 (without specifying which ones).
In the Vitsebsk region, the register includes[3] 492 religious communities of 17 denominations, whereas as of January 1, 2025, there were 525 (18 denominations). Among those liquidated are communities of various denominations, including the Belarusian Orthodox Church, Pentecostal Christians, Evangelical Christian Baptists, Seventh-day Adventists, the Evangelical Lutheran Church, Full Gospel Christians, Jewish communities, and others. At least one denomination, the Church of Jesus Christ of Latter-day Saints, has ceased to exist in the region.
In the Homiel region, as of February 1, 2026, 380 religious communities from 15 denominations and movements are registered[4], compared to 422 organizations from 16 denominations previously. A reduction is noted in the number of parishes of various denominations, including the Belarusian Orthodox Church, the Roman Catholic Church, Protestant, and Jewish communities. At least two denominations previously represented in the region are absent from the current list.
In the Mahiliou region, the number of religious communities decreased from 298 (20 denominations) to 237 (17 denominations). Religious communities of several denominations, including the Churches of Christ, Mormons, and Baháʼís, have ceased to operate in the region. A significant reduction has also been recorded in the number of parishes of both Orthodox and Catholic churches, as well as Protestant and other religious organizations.
Thus, the available data indicate a significant reduction in the number of religious organizations following re-registration. At the same time, the lack of complete and transparent official information prevents a comprehensive analysis of the consequences of this procedure, including the exact number of liquidated organizations and their denominational affiliations.
2. Administrative and criminal prosecution of the leadership and members of civil society organizations, as well as other forms of pressure on civil society organizations
Dozens of representatives of CSOs, as well as religious organizations, continue to be held in places of detention. In addition, at least 20 trade union and labor movement representatives remain in custody. The practice of detaining activists under administrative and criminal cases continues. Thus, during the monitoring period, public activist and member of the «За Свабоду» (English: “For Freedom”) movement, Viktar Yaumenenka, as well as human rights defender and public activist from Mahiliou, Uladzimir Tseliapun, were detained. The latter has been charged in a criminal case, including under Article 361-4 of the Criminal Code (facilitation of extremist activities).
During the monitoring period, the use of information campaigns in state and propaganda media as tools of pressure and discreditation against CSOs continued. On April 8, 2026, propaganda channels disseminated video recordings of seminars for former volunteers and observers of the Human Rights Center “Viasna,” as well as individual project documents from the period 2019-2020, presenting them as “sensational materials.” According to available information, these materials were obtained by state authorities during the persecution of Viasna human rights defenders in 2020-2021 as a result of the seizure of data storage devices.
Pressure on charitable organizations persists, including through the initiation of criminal cases accompanied by public interpretation of their activities as unlawful (this trend has been observed since the end of January 2026). In particular, the prosecutor of the city of Hrodna, following an inspection conducted jointly with officers from the economic crime units of the internal affairs bodies of the Leninsky District administration of Hrodna, initiated a criminal case against officials of the local charitable foundation «Чудо детям» (English: “Miracle for Children”) (registered in June 2024) on charges of fraud on an especially large scale. According to the official version, foreign citizens serving as founders, a director, and a deputy director of the foundation between June 2024 and April 2026, under the pretext of carrying out charitable activities (social support and protection of citizens, assistance to children with disabilities and other vulnerable groups), misappropriated funds of the foundation amounting to no less than 390,000 rubles. The actions of the suspects are classified under Part 4 of Article 209 of the Criminal Code of the Republic of Belarus. One of the suspects has been detained, his property has been seized; the other individuals involved are outside the Republic of Belarus.
During the monitoring period, officers of the State Security Committee conducted a series of searches and detentions of individuals associated with socio-cultural organizations and initiatives. During investigative actions, questions arose about the receipt of foreign funding by organizations. These measures coincided in time with the designation of several socio-cultural organizations and their projects as extremist formations, indicating a connection between these processes.
The practice of applying anti-extremism legislation continues to expand, effectively leading to the criminalization of a wide range of civic activities. By the end of April, 365 entities (26 more than in the previous monitoring period) had been included in the List of Organizations, Formations, and Individual Entrepreneurs Involved in Extremist Activities. During the monitoring period, the following were recognized as “extremist formations,” among others:
- Human rights organization “Belarusian Helsinki Committee”;
- «Belarusian Council for Culture» / «Беларуская Рада культуры» and related projects;
- Organization «ІншыЯ» / “The Others”;
- Youth educational initiative «Гэта База» (English: “That’s based”);
- Platform «Три слона» (English: “Three Elephants”);
- SVAE app (a rebranding of the “New Belarus” platform);
- Initiative to support political prisoners «Вольныя» (English: “Free People”);
- “Center for New Ideas”;
- «Fundacja Brama Dziedzictwa»;
- “Belarusian Investigative Center”;
- Electoral lists for the Coordination Council elections.
By decision of the Supreme Court of the Republic of Belarus, the European Humanities University has been designated an extremist organization. This decision significantly increases risks for a wide range of individuals and organizations interacting with the university. Any form of participation in the organization’s activities or cooperation with it may entail criminal liability, including under articles of the Criminal Code that provide for punishment for the creation of, participation in, or other facilitation of extremist activities.
Those at risk of criminal prosecution include university staff and faculty, students and graduates who continue to maintain ties with the university, individuals involved in educational, research, outreach, and other projects implemented with the university’s participation, as well as partner organizations and experts. Additionally, the risk of administrative liability increases for disseminating informational materials related to an organization designated as extremist. This includes social media posts, mentions in résumés, reposts, and even the storage of such materials, including diplomas.
Significant consequences also arise in the areas of funding and international cooperation. Any financial transactions, including tuition payments, grant support, or other forms of material assistance to the university, may be classified as financing extremist activity. This affects both individuals and CSOs, including partner structures, educational initiatives, and donor organizations.
The “Swedish International Liberal Centre Foundation” has also been designated an extremist organization by decision of the Supreme Court.
Thus, during the monitoring period, two civil society entities were simultaneously recognized as extremist organizations. By comparison, over the entire previous period since 2021, only six entities had received such a designation. This trend indicates an expansion in the use of a more severe legal instrument.
Unlike the designation of an “extremist formation,” which is applied extrajudicially and serves as a primary mechanism of pressure on civil society, the designation of an “extremist organization” is made based on a court decision. This reflects the institutionalization of persecution within the judicial system and may be viewed as an additional form of legitimizing repressive practices.
During the monitoring period, the Republican List of Extremist Materials was expanded to include online resources of CSOs and initiatives, including social media pages (Threads, Instagram, Facebook), as well as resources of diaspora associations (for example, “Belarusians in Oxford,” “Belarus RAZAM Berlin,” “Belarusians in Greece,” and others).
3. Legislation
The Law of the Republic of Belarus of April 15, 2026, No. 138-Z “On Amendments to Codes on Issues of Administrative Liability” has supplemented the Code of Administrative Offenses with several provisions related to the exercise of freedom of association. These provisions will enter into force two months after the official publication of the law, i.e., on June 19, 2026.
3.1. The Code of Administrative Offenses has been supplemented with a new article establishing liability for the so-called “propaganda” of homosexual relationships, gender transition, childlessness, as well as for disseminating information about the acceptability of pedophilia (Article 19.16 of the Code of Administrative Offenses).
Under this provision, dissemination in any form of information aimed at shaping perceptions among citizens about the attractiveness of homosexual relationships, gender transition, or childlessness entails administrative fines: up to 20 basic units for individuals, up to 100 basic units for individual entrepreneurs, and from 100 to 150 basic units for legal entities.
A stricter liability is established in cases where such actions expose a minor to the relevant information. In such cases, individuals may face a fine (from 20 to 30 basic units), community service, or administrative arrest. In contrast, individual entrepreneurs and legal entities are subject to significantly increased fines (for legal entities, from 150 to 200 basic units).
This provision is characterized by broad, vague wording, such as “shaping perceptions of attractiveness,” which creates significant risks of arbitrary and expansive interpretation by law enforcement authorities. The absence of clear criteria distinguishing prohibited information from permissible expression of opinions, scientific, educational, or human rights activities, significantly increases legal uncertainty.
The adoption of Article 19.16 creates additional risks for CSOs, including:
- limiting opportunities for educational and awareness-raising activities in the field of human rights and non-discrimination;
- increasing pressure on initiatives working with vulnerable groups, effectively banning the activities of LGBTQ+ organizations engaged in gender equality, family policy, and reproductive rights;
- enabling its use as a tool for persecution for expressing opinions and disseminating information not related to unlawful activity, where even neutral information, research, or educational programs may be interpreted as “promoting a positive attitude”;
- further narrowing the space for freedom of expression and association.
Particular importance is attached to the provision on stricter liability when information becomes accessible to minors, which effectively expands the scope of the article to public online communications.
3.2. The revised Article 24.53 of the Code of Administrative Offenses significantly expands the scope of liability for violations of legislation on gratuitous (sponsorship) assistance. Unlike the previous version, which established liability only for the provision and use of assistance prohibited by law, the new provision also covers receipt of such assistance. It extends to a broader and not clearly defined range of “cases prohibited by legislative acts.”
The forms of assistance are explicitly listed (funds, property, works, services), and administrative liability is introduced for legal entities, which were not previously explicitly covered. Additionally, a separate offense has been established: misuse of gratuitous (sponsorship) assistance, which allows liability even when funds were lawfully received but their use is deemed inconsistent with designated purposes.
These changes significantly increase risks for NPOs receiving or distributing funding. The expansion of offenses and the introduction of liability for receiving assistance, as well as for its misuse, create conditions for broader and potentially arbitrary application of the law, especially given the absence of clear criteria for assessing targeted use. The introduction of liability for legal entities and the detailing of sanctions increase the likelihood of penalties for formal violations.
3.3. The Code of Administrative Offenses has been supplemented with Article 24.62, establishing liability for the so-called “unlawful representation of the Republic of Belarus at international events.” The provision establishes liability for violating legal requirements for organizing or conducting cultural, educational, sports, and other events aimed at selecting individuals to participate in international events, as well as for violating the procedure for sending representatives to participate in such events on behalf of the Republic of Belarus.
The wording of this article is also broad and evaluative, as it covers both the selection process and participation in international events. At the same time, the criteria distinguishing private participation from state representation are not defined.
In essence, this provision aims to restrict the participation of Belarusian citizens and organizations in international processes outside state control. It may be applied to a wide range of individuals, including representatives of CSOs, human rights defenders, civic activists, and other participants in international events. This creates risks of liability for effectively exercising the right to participate in international cooperation and publicly express positions abroad.
This regulation affects rights guaranteed under international law, including freedom of expression (Article 19 of the ICCPR), freedom of association (Article 22 of the ICCPR), and the right to participate in public affairs (Article 25 of the ICCPR), and indicates further tightening of control over cross-border activities and international cooperation of CSOs.
Taken together, these amendments to the Code of Administrative Offenses demonstrate a trend toward expanding administrative regulation in areas directly related to the activities of CSOs:
- information and educational activities;
- financial activities;
- international cooperation.
As noted, the new provisions are characterized by evaluative language and the absence of clear application criteria, increasing the risk of arbitrary interpretation. This, in turn, heightens legal uncertainty and CSOs’ vulnerability.
[1] The text is available in Russian only
[2] The text is available in Russian only
[3] The text is available in Russian only
[4] The text is available in Russian only