Civil society organisations (CSOs) in Uganda’s health sector have raised serious concerns over the provisions of the Protection of Sovereignty Bill, 2026, warning that the legislation is unnecessary, overly broad, and risks harming the economy and essential services.
In a strongly worded public statement issued on the Bill (No. 13 of 2026), the organisations said they support efforts to safeguard Uganda’s sovereignty, independence, and territorial integrity.
However, they argued that the Bill, currently before the Joint Committee of the Committee on Defence and Internal Affairs and the Committee on Legal and Parliamentary Affairs, is not the right approach.
“We are not opposed to the object of the Bill in principle,” the statement reads.
“The protection of Uganda’s sovereignty… is a legitimate object of legislation.”
The CSOs, which include key players in health service delivery, submitted a detailed memorandum to Parliament outlining their position.
Existing Laws Sufficient, CSOs Argue
The organisations contend that Uganda already possesses a robust legal framework to address potential threats to national sovereignty. They pointed to several existing statutes, including:
- The Non-Governmental Organisations Act (Cap. 109), which governs registration, inspection, suspension, and de-registration of CSOs.
- The Anti-Money Laundering Act (Cap. 118) and Anti-Terrorism Act (Cap. 120).
- The Foreign Exchange Act (Cap. 167) and provisions in the Penal Code Act covering seditious and treasonable conduct.
Uganda is also party to international instruments such as the UN Convention against Transnational Organised Crime and aligns with Financial Action Task Force (FATF) standards through the Eastern and Southern Africa Anti-Money Laundering Group.
“If any specific gap has been identified, the appropriate response is targeted amendment of the relevant existing statute, not the enactment of a new, overlapping regime,” the statement emphasised.
Vague Definitions and Sweeping Powers
A major concern raised is the Bill’s broad definitions of “foreigner,” “agent of a foreigner,” and “disruptive activities.”
The CSOs warned that these could capture legitimate entities such as hospitals partially funded by international foundations, universities with foreign academic partnerships, churches receiving diaspora offerings, law firms in international networks, and community organisations with even minor foreign support.
They noted that the vague phrasing of “disruptive activities” — particularly conduct “prejudicial to or threatening the security of Uganda” — mirrors language previously struck down by the Constitutional Court in the 2005 Andrew Mujuni Mwenda case for being impermissibly vague.
The statement also criticised clauses granting the Minister wide powers to expand these categories through statutory instruments laid before Parliament merely “for information,” effectively allowing the Executive to alter the penal scope of the law with minimal oversight.
Disproportionate Penalties and Economic Risks
The CSOs described the proposed penalties as excessive, with fines reaching up to UGX 4 billion for entities and UGX 2 billion or 20 years’ imprisonment for individuals.
Other provisions flagged include:
- A public inspection register of funding sources that may conflict with the Data Protection and Privacy Act.
- A cap on foreign funding at approximately UGX 400 million per year — far below the operational needs of many hospitals, universities, and research institutions.
- Requirements forcing banks and mobile money operators to act as gatekeepers, with heavy penalties for non-compliance.
- Warrantless inspections of private premises without reasonable suspicion or safeguards for privileged or medical records.
Such measures, they argued, cannot be justified under Article 43 of the Constitution, which allows limitations on rights only when demonstrably justified in a free and democratic society.
The organisations further warned of severe economic fallout.
Uganda received USD 2.5 billion in diaspora remittances in 2025 (about 3.8% of GDP), a vital source of foreign exchange support for the shilling.
The civil society sector contributes over UGX 4.5 trillion annually to the economy and employs tens of thousands.
Recent disruptions to USAID and PEPFAR funding already led to an estimated 15,000 health-sector job losses and a UGX 600 billion gap in the HIV response.
The Bill, they said, risks compounding such vulnerabilities by introducing political grounds for disrupting financial inflows.
CSOs as Partners, Not Adversaries
The signatories stressed that health sector CSOs are Ugandan-registered entities accountable to local beneficiaries.
They play a critical role in delivering health, education, water, and social services across the country, in line with the Constitution’s Sixth Schedule and National Objectives.
“Civil society is a partner of Government, not its adversary,” the statement declared, citing the Government’s own Partnership Policy for Engagement with CSOs, the National Development Plan, and Vision 2040.
Constructive Alternatives Proposed
Instead of the current Bill, the CSOs proposed:
- A joint Government-CSO national sensitisation programme on sovereignty, involving relevant ministries, the Uganda Human Rights Commission, cultural leaders, and faith-based institutions to mobilise citizens.
- A framework to strengthen domestic funding for civil society through tax incentives for local philanthropy, a Uganda Public-Private CSO Basket Fund, corporate social responsibility partnerships, and lawful channels for diaspora giving — phased over at least five years.
“Rather than enacting legislation that curtails our operations,” the statement concluded, “the government would do far better to invest in policies that strengthen and enable civil society so that we may continue to work alongside the state to build this nation.”
The Bill was tabled in mid-April 2026 and is undergoing parliamentary scrutiny.
Its outcome is expected to have significant implications for Uganda’s civic space, health service delivery, and broader development partnerships.
