HRCP report exposes systematic suppression of rights-based NGOs across Punjab

March 27, 2026

By Ahmed Saeed

---

LAHORE

Rights-based nongovernmental organizations across Punjab have endured a decade of mounting pressure from state authorities, facing an elaborate web of regulatory hurdles, security agency surveillance, frozen bank accounts, and forced office closures — all carried out under the guise of lawful administration.

This is the central finding of a new fact-finding report titled ‘Regulation or Restriction? The Shrinking Space for Rights-Based NGOs in Punjab’, published in 2026 by the Human Rights Commission of Pakistan (HRCP) with financial support from the European Union.

The report, compiled following a four-day fact-finding mission conducted in Lahore and Multan between 29 October and 1 November 2025, draws on interviews with NGO representatives from Kasur, Sialkot, Faisalabad, Rajanpur, Layyah, Vehari, Lahore, and Multan. Its findings paint a troubling portrait of democratic backsliding in Pakistan’s largest province, where the machinery of the state has been systematically deployed not to regulate civil society, but to suppress it.

At the heart of the report’s findings is the sheer complexity of bureaucratic requirements imposed on NGOs seeking to operate legally and access foreign funding. Following the introduction of the Economic Affairs Division’s (EAD) foreign funding policy in 2015 — justified at the time as a measure to comply with Financial Action Task Force (FATF) requirements on countering terror financing — organizations were required to seek approval and sign a memorandum of understanding (MOU) with the EAD before accessing any foreign grants.

But the MOU was rarely sufficient on its own. NGOs also needed a no-objection certificate (NOC) from the district administration, specifically the deputy commissioner, to implement activities at the local level. Then, from 2018 onwards, following the enactment of the Charities Commission Act in Punjab, all previously registered NGOs were required to re-register with the Punjab Charities Commission — adding yet another layer to an already burdensome process.

The report documents how reaching an agreement with the EAD came with its own informal conditions. According to respondents, organizations were repeatedly instructed to remove terms such as “human rights,” “governance,” “democracy,” “peace,” and “conflict resolution” from their project documents as a precondition for approval. Even with all approvals in place, security agency representatives could still intervene — directly or through the local administration — to halt activities at any time.

The procedural dysfunction was compounded by a structural contradiction that left many organizations in an impossible bind. As one respondent from Multan described: “Donors required an MOU to be submitted along with the project proposal, while the EAD would only accept the application once the project was approved. Donors often sought blanket approval from the EAD, whereas the EAD issued only project-specific approvals and MOUs. The process was also inconsistent, as some organizations were able to secure long-term, blanket MOUs of up to three years.”

The consequences of these multilayered requirements were devastating for civil society programming. The report documents numerous cases in which registration delays directly caused the closure of ongoing projects and the withdrawal of donor funding.

One of the most detailed testimonials in the report concerns the Democratic Commission for Human Development (DCHD), a rights-based capacity-building organization that worked across Pakistan training community groups in democratic values and human rights. After a speaker at a conference it hosted challenged unlawful surveillance practices, the DCHD was placed under official scrutiny. Its bank accounts were frozen, two longstanding projects monitoring child labour in the carpet-weaving industry were halted, and operations nationwide were made contingent on obtaining an EAD MOU — which was applied for twice and rejected both times. Its registration under the Societies Registration Act 1860 was also denied renewal. The organization eventually ceased operations entirely. Former staff members are now engaged in consultancy work and small-scale medical and educational services.

The case of a women’s rights NGO based in northern Punjab offers a similarly grim account. After 2018, its bank accounts were seized and ongoing projects halted. Two major banks froze its funds until it signed an MOU with the EAD. A donor subsequently withdrew from an already-approved project due to the lack of banking access. Approval was granted for only one of the multiple EAD MOU applications the organization submitted. In a particularly disturbing development, contact details of participants in one of its activities — submitted to the authorities as part of the approval process — were leaked, after which participants received threatening messages accusing the NGO of being a foreign agent. “In the last two years, the situation has improved,” the report notes, “but the NGO remains uncertain about what lies for it in the future.”

For many smaller organizations, survival meant abandoning the work that had defined them. As one respondent from Lahore reflected: “Many of us have managed to sustain our work through difficult times, yet others were co-opted or forced to cease operations, having no other choice. Several organizations scaled down their activities, adopting a ‘survive today, fight another day’ approach.”

A recurring theme throughout the report is how authorities avoided overt bans or direct confrontations in favor of administrative mechanisms that achieved the same result while maintaining a surface appearance of legality. The report documents a consistent pattern: withholding NOCs for events, freezing bank accounts, delaying or denying registration for new NGOs, closing offices, and subjecting organizations to repeated inspections and questioning.

The effect was to create what the report calls “an environment of persistent uncertainty and operational paralysis.” Critical NGOs found themselves spending enormous time and resources navigating administrative hurdles rather than advancing their core mandates. State actors were able to exert decisive pressure while claiming, at every turn, to be acting within proper procedures.

The case of South Asia Partnership Pakistan (SAP-PK) illustrates the pattern starkly. In 2016, the Ministry of Interior ordered its shutdown, alleging it was working against national interests after it submitted a shadow report to the UN Human Rights Council. When SAP-PK challenged the decision in the Lahore High Court, the chief justice ruled the ministry’s notification illegal, declaring it a violation of constitutional provisions. Similarly, Women in Struggle for Empowerment (WISE) had its operations shut down in 2017 on national security grounds, also obtaining legal relief only after prolonged court proceedings. Both organizations eventually resumed operations, but only after enduring forced office closures and frozen accounts.

The HRCP report frames these incidents within the broader theoretical concept of democratic backsliding — the incremental, often legally dressed erosion of institutional safeguards described by political scientist Nancy Bermeo. Rather than dramatic coups or outright bans, the pressure on civil society has taken the form of what the report calls “gradual changes” that hollowed out civic space while preserving the appearance of democratic normalcy.

The report dedicates particular attention to the disproportionate impact of shrinking civic space on women-led organizations and minority rights groups. These bodies faced pressure not only from state institutions but also from nonstate actors, including extremist groups, local power brokers, and conservative community elements — a dual exposure that, the report finds, has compounded their vulnerability.

Women respondents specifically highlighted how bureaucratic processes favored those with informal social access — networks and influence they were less likely to possess. As one woman respondent from Multan explained: “We do not have the networks or the ability to ‘settle matters informally’ the way men often can. Just three or four visits to the offices of local administrations or provincial departments are enough for our presence to be questioned and our character to be scrutinized. Even so, we did everything we could, but our work has suffered significantly. The support that small women-led organizations once received from larger NGOs and donor agencies has gradually disappeared. What was previously a collaborative and supportive environment has become increasingly isolating, leaving us to navigate these challenges largely on our own.”

The case of Qaswa Women Development Organization in Rajanpur is particularly illustrative. Despite receiving no foreign funding at all, its bank accounts were frozen on the apparent recommendation of the District Intelligence Committee. The bank continued accepting deposits but refused withdrawals, offering no clear justification. The registration authority confirmed full compliance but clarified it had no mandate to issue the approvals the bank demanded. The organization found itself ensnared in a bureaucratic loop with no clear resolution.

Minority rights organizations expressed comparable frustration. A group from Faisalabad told the mission they had felt abandoned by larger rights-based organizations after the mob violence against the Christian community in Jaranwala in 2023. They noted that established organizations had been forced to scale back due to the restrictive environment, creating a vacuum quickly filled by less experienced actors who lacked genuine commitment to rights-based work — diluting advocacy quality and leaving victims of the violence without adequate support.

The HRCP report concludes with a set of specific recommendations directed at government, NGOs, and international donors.

To the federal and provincial governments, it calls for the enactment of a rights-compliant legal framework for NGO regulation through primary legislation — not executive policies — that is fully aligned with constitutional freedoms and Pakistan’s international human rights obligations. It urges the standardization of registration processes with clear, time-bound approval timelines and automatic approval where deadlines are missed, along with online tracking systems giving NGOs transparency into their application status.

The report also calls on governments to establish formal, regular consultative forums with civil society to jointly develop and review NGO policy, and to clearly delineate the roles of civilian and security agencies in NGO oversight. Critically, it urges governments to treat NGOs’ engagement with international human rights mechanisms — including shadow reports to UN treaty bodies — as a legitimate contribution to accountability rather than an adversarial act.

For international donors, the report calls for targeted, flexible funding for women-led, minority-focused, and human rights-based organizations — and specifically requests that donors discontinue the requirement to obtain prior NOCs when applying for donor-funded grants, a practice that inadvertently reinforced state pressure on NGOs. Donors are also urged to support legal aid initiatives and evidence-based research on civic space at the provincial and national levels.

As one respondent from Multan captured the broader atmosphere: “It has become increasingly difficult to work the way we did a few years ago, especially when political parties, from whom we expect much, compromise on citizens’ rights. The environment is more challenging now, but some of us continue, as we have not learned any other way to make a difference.”

The HRCP report leaves little doubt about its central conclusion: what has been presented as regulation is, in practice, restriction — a sustained and deliberate narrowing of the civic space that democratic societies depend upon to hold power accountable.