Monitoring of the situation with freedom of association and the status of civil society organizations in the Republic of Belarus September 2024

Repressions against civil society organizations and activists continue in Belarus. Over a hundred representatives of civil society organizations are currently in detention. Criminal cases are being initiated, and courts are issuing lengthy prison sentences for aiding extremist activities, leading and participating in extremist formations, and financing extremism by donating to solidarity funds and other structures.

Every month, several civil society organizations, including those already liquidated, are being designated as extremist formations. The authorities are increasingly trying to suppress the civic engagement of Belarusians who have been forced to leave the country, including by intimidating other diaspora members. This includes initiating criminal cases against participants in protests abroad, pressuring their relatives, detaining people returning from abroad to Belarus, and issuing long sentences and heavy fines through special (in absentia) trials.

The campaign to liquidate non-governmental organizations has not stopped for four years. As of the end of September 2024, it amounts to at least 1.137 NGOs which is 21 more organizations than in the previous monitoring period. As of the end of September 2024, the number of organizations that decided on self-liquidation is at least 666. Consequently, the losses in Belarus’s civil sector since the post-election period in 2020 amount to no less than 1.803 institutionalized forms of NGOs (including civic associations, professional unions, political parties, foundations, non-governmental institutions, associations, and religious organizations).

Creation and Activities of Non-Profit Initiatives in Belarus

Despite the ongoing practice of liquidation, new non-profit organizations in Belarus, in the form of public associations, non-governmental institutions, and foundations, continue to be registered. As of September 30, 2024, at least 33 new NGOs have been registered: 16 non-governmental institutions (one of them is already in the process of self-liquidating), 4 foundations, and 13 public associations. These NGOs primarily focus on social charity, physical culture and sports, professional, patriotic, and animal protection causes. However, the number of registered NGOs is at least ten times lower than those being liquidated.

The authorities are interested in controlled association, steering and often imitating the public’s inclination to unite towards state ideology and addressing specific local issues, such as the improvement of small territories or localized social assistance.

This is the primary focus of contests supporting civic initiatives held across all regions of Belarus in accordance with the Law «On Local Governance and Self-Government». For instance, in Brest Region, winners of the civic initiative contest included projects to install new monuments for historical memory preservation, street workout complexes, and improvements to the material and technical base of a military-patriotic education and pre-conscription training center for students and youth. On September 26, an offsite seminar of the House of Representatives of the National Assembly was held to study the implementation of civic initiatives in various cities of Brest Region.

Numerous events organized by pro-government organizations, forums, and conferences are held, and clubs and centers are created for this purpose in all regions of Belarus. For example, the Charity Fund for the Support of Family, Motherhood, and Childhood «Pokrov,» the Ministry of Education, and the Belarusian Orthodox Church announced a nationwide social project competition for students, schoolchildren, college students, and participants in additional education programs. According to the organizers, the competition aims to promote a healthy, socially significant, and active life and family stance among Belarusian youth as the main alternative to negative social trends.

On September 25-26, the 12th Belarusian-Russian Youth Forum was held, where, among other topics, a roadmap was discussed, confirming joint intentions between Belarus and Russia in youth policy and cooperation among public organizations such as «The Movement of the First» (Russia), the Belarusian Republican Pioneer Organization, and the Belarusian Republican Youth Union.

On September 27-28, the First Forum of Belarusian Bloggers, «BlogBy. We Have What to Say!» was held, organized by the Ministry of Information with support from the Ministry of Education and Beltelecom Republican Unitary Enterprise.

On September 28, the first national review competition among military-patriotic clubs of the Ministry of Internal Affairs took place, regulated by a special Decree of May 4, 2022, No. 160 «On the Development of Military-Patriotic Clubs.» The goal of these clubs is the civic and patriotic education of children (from 9 years old) and youth, increasing their motivation for army service, service in law enforcement agencies, and offices for emergencies, as well as implementing state youth policy. According to the Minister of Internal Affairs, 136 military-patriotic clubs operate within the Ministry of Internal Affairs system, with over 5.000 participants. A Republican Youth Patriotic Education Center is being established at the Kobryn Fortifications of the Brest Fortress, for which funds are being raised from citizens and entities across the country.

By Resolution of the Council of Ministers of the Republic of Belarus of September 3, 2024, No. 642 «On Amendments to the Resolution of the Council of Ministers of the Republic of Belarus of October 24, 2023, No. 726» a reduced rent coefficient was established for the Liberal Democratic Party of Belarus and its organizational structures.

Forced liquidation of non-governmental organizations

The liquidation of public associations, primarily due to the failure to bring their charters into compliance with the new requirements of the Law «On Public Associations,» remains intense. First and foremost, for several months now, republican and international public associations have been subject to liquidation. According to the new legal requirements, republican public associations must have at least seven organizational structures – one in each of Belarus’s regions and the city of Minsk. Additionally, each organizational structure must have a legal address in a non-residential building. International public associations, under the new law, are required to have at least two organizational structures: one in Belarus, which must be registered or accounted for, and one abroad. However, during the process of bringing their charters in line with the new legal provisions, the registration authorities have imposed additional requirements on international public associations – specifically, the mandatory registration of an organizational structure abroad. This requirement does not directly arise from the new legal norms, as the law only mandates the registration or accounting of organizational structures within Belarus. Moreover, the legislation of a given country may not even provide the opportunity to register the organizational structure of an association that is registered in Belarus.

The liquidation of public associations that, in the authorities’ view, have facilitated extremist activities or engaged in war propaganda also continues.

In total, as of September 30, 2024, according to the monitoring conducted by Lawtrend[1], there have been 1.137 NGOs in the process of forced liquidation, including lawsuits filed by registering authorities for liquidation or being forcibly excluded from the Unified State Register of Legal Entities and Individual Entrepreneurs (USR).

Since the end of 2022, a practice has emerged of excluding public associations from the USR that were liquidated by court decision but had not completed the liquidation process (i.e., those for which a court ruling was issued, but they did not appoint a liquidation commission and/or did not undergo mandatory inspections, prepare a liquidation balance sheet, etc.). This practice initially did not affect forcibly liquidated non-governmental institutions, most of which had been listed in the USR as «in the process of liquidation» since 2021. However, during the monitoring period, the practice of exclusion from the USR without completing the liquidation process (without submitting documents to the registering authority) began to extend to institutions as well. At the same time, this practice has only affected select institutions so far. Some non-governmental institutions, liquidated during the same period as those excluded from the USR, remain in the register with the status «in the process of liquidation.»

Non-governmental organizations deciding on self-liquidation

As of September 30, 2024, according to the monitoring conducted by Lawtrend, there have been 666 NGOs (civil associations, foundations, institutions, and a political party) in which the authorized body or founders have decided to liquidate. Three out of the four NGOs that decided to undergo voluntary liquidation during the monitoring period are public associations located in the Viciebsk region.

The decision on self-liquidation is primarily due to pressure on the members and employees of NGOs, an unfavourable legal environment, and the overall socio-political situation in the country.

Since 2021, there have been repeatedly recorded cases when the decision on self-liquidation is made by a recently registered NGO. For example, on September 30, the decision on liquidation was made by the owner of the Information and Consulting Institution for Sustainable Regional Development “Fair of Initiatives”, while the decision on registration of this institution was made on February 13, 2024.

Administrative and criminal prosecution of the leadership and members of civil society organizations, and activists

In connection with the performance of their professional activities, participation in civil society organizations, and the manifestation of civic activism, 6 human rights defenders, dozens of representatives of civil society organizations, and religious organizations, and 34 representatives of trade unions and the labor movement continue to serve prison sentences[2]. Pressure on representatives of religious organizations continues.

The authorities continued active demands to suppress the civil activity of Belarusians who were forced to leave the country. For these purposes, criminal legislation on special (absentee) proceedings is widely used. At the end of September 2024, 118 people were included in the List of persons against whom special proceedings have been initiated and summoned to the criminal prosecution authority.

On September 30, the trial in absentia began in the criminal case against human rights defender and member of the «Viasna» Human Rights Center, Alena Maslyukova, who is charged under parts 1 and 2 of Article 361-4 of the Criminal Code (facilitation of extremist activities).

The use of legislation to combat extremism as a form of pressure on civil society organizations

Legislation on combating extremism continues to be actively used against representatives of civil society organizations: prosecution for money transfers to solidarity funds, assistance to political prisoners and their families, including criminal prosecution, recognition of public initiatives as extremist formations, and information resources, social networks, etc. as extremist materials.

During the monitoring period, several items were added to the Republican list of extremist materials, including content posted in the Facebook group Беларускi Хаб «Новая зямля»/Bialoruski Hub «Novaja Ziamia» (eng. «Belarusian Hub ‘New Land’); pages on the X and Instagram under the name «Libereco – PHR,» an Instagram profile called «Зашита прав призывников» (eng. «Protection of Conscripts’ Rights»), the VK community «Страна для жизни» (eng. «A Country for Life»); the X page called «Peoples Embassy of Belarus in Slovenia,» the website and Instagram account «povestka.pro,» the Instagram page «INeedHelpBY,» and a number of information resources belonging to civil society organizations.

During the monitoring period,  the «Belarus Women’s Foundation» and the «Belarusian National Youth Council ‘RADA'» have been included in the List of organizations, formations, and individual entrepreneurs involved in extremist activity.

Once a civil society organization is designated as an extremist formation, widespread repression against individuals associated with the organization or community may follow. An example of this is the mass searches and arrests at the beginning of the year targeting individuals linked to the INeedHelpBy initiative, a social project providing food assistance to victims of repression. After the KGB designated the non-profit civil initiative «Adukavanka,» which provides resource support to teachers, as an extremist formation in late August, a wave of mass summonses to KGB of teachers – including those not affiliated with the initiative – took place in September.

Funding of non-governmental organizations

On September 30, 2024, a new version of Decree «On the Provision and Use of Gratuitous (Sponsorship) Assistance» of July 1, 2005, No. 300, came into effect.

The new version does not eliminate significant provisions that limit NGOs’ access to domestic funding. These include restrictions on the purposes for which gratuitous (sponsorship) assistance may be used, the requirement to comply with the decree’s norms when transferring low-value assets, and the conflation of «gratuitous» and «sponsorship» assistance. Additionally, some new restrictive measures were introduced, such as an expanded list of prohibited purposes for receiving assistance.

However, the decree also clarifies and expands the list of allowed purposes for receiving gratuitous (sponsorship) assistance. Notably, it now includes support for public associations and organizations aimed at achieving their statutory goals. The decree also allows for the use of funds received for specific purposes to cover administrative and operational expenses, such as rent, utility services, and staff wages.

For a long time, NGOs have advocated for the complete repeal of Decree No. 300. While the expanded list of purposes for which assistance can be received and used is a positive step, making it easier for entities to provide assistance and for public associations to receive it, the significance of these changes is diminished in the context of widespread repression in the country including the mass liquidation of NGOs and the sharp reduction in business structures that support them.

The decree does not address important issues related to receiving gratuitous (sponsorship) assistance, such as reporting requirements and the need to define the types of goods (works, services) purchased with the assistance. However, since the Council of Ministers has been tasked with approving not only the contract form (as stipulated in the current legislation) but also the contract’s requirements, these issues may be addressed in subsequent legislation.

On September 30, a resolution of the Ministry of Sports and Tourism of July 25, 2024, No. 35, also came into force. This resolution, developed in accordance with the new version of Decree No. 300, regulates the procedure for higher authorities to approve the amount of support that state organizations plan to provide to sports federations and clubs.

Despite the explicit provision in the decree stating that a contract must be concluded when providing gratuitous (sponsorship) assistance, and that the requirements for this contract, as well as its sample form, are to be established by the Council of Ministers, no regulatory act governing the contract’s requirements had been issued before the decree’s enactment.

Central Election Commission Chairman Ihar Karpenka announced that after the presidential elections, Belarus may adopt a law on «foreign agents.» This is not the first time that government representatives have spoken about the necessity of such a law. In late 2020, MP Andrei Savinykh proposed adopting a «foreign agents» law modeled after Russia’s. In early 2021, MP Aleh Haidukevich, leader of the Liberal Democratic Party, confirmed that such a bill was under development in parliament.

The initiative to adopt a «foreign agents» law in Belarus defies logic, given that most NGOs unfavorable to the authorities have already been liquidated, and civil society organizations can be declared extremist formations or organizations at any time, and a permissive system for registering foreign assistance is already in place, where registration only occurs if the state has a direct interest in the assistance.


[1] The monitoring only records cases of forced liquidation and self-liquidation of non-governmental organizations (NGOs), and quantitative data does not include government institutions or republican state-public organizations. Consumer cooperatives, and other organizational and legal forms of NGOs besides public associations, foundations, religious organizations, private institutions, and associations are also not taken into account.

[2] Examples of representatives of civil society organizations in prison with terms of imprisonment, and information about being included in extremist and/or terrorist lists can be found in Lawtrend’s monthly reviews of the situation with freedom of association and the situation of civil society organizations, for example, for May 2024. Information about detained trade union members and trade union activists is published based on Solidarity data.