The report, titled ‘Regulation or Restriction?’, states that NGOs are being subjected to multiple and complex approval requirements. These include mandatory memorandums of understanding with the Economic Affairs Division, district-level no-objection certificates, security clearances, and re-registration under the provincial charity commission.
It notes that these measures have restricted operational capacity and led to the suspension or closure of several human rights and democracy-related initiatives.
According to the report, although courts have provided limited relief – including the annulment of the Economic Affairs Division’s 2022 policy – the absence of a clear and rights-compliant legal framework has allowed administrative authorities to retain wide discretionary powers.
The fact-finding mission observed that state institutions are using administrative tools, within legal frameworks, to exert pressure on civil society. These include delays in approvals, freezing of bank accounts, and repeated scrutiny of organisations.
The report states that such actions have disproportionately affected rights-based groups, forcing many to divert resources towards regulatory compliance, reduce activities, or withdraw from advocacy work.
It further highlights that women-led organisations and those working with minority communities are facing disproportionate impact. These groups are also exposed to additional risks, including non-state threats and limited institutional support.
Speaking at a seminar held in Lahore at the launch of the report, fact-finding mission member Zeeshan Nool said that the gradual erosion of civic freedoms through legal and policy measures has become a visible form of democratic decline.
Another mission member, Naseem Anthony, said the process is also narrowing intellectual space in society.
Advocate Saqib Jillani said there is a need for coordination among lawyers pursuing legal challenges against the 2022 policy. Neelum Hussain of Simorgh said organisations must continue engagement and dialogue despite financial constraints.