Project RESILIENT Update, March 2026

The RESILIENT project involves ongoing monitoring of the regulatory landscape in 10 EECA countries: Armenia, Azerbaijan, Belarus, Georgia, Kazakhstan, Kyrgyzstan, Moldova, Tajikistan, Ukraine and Uzbekistan. With this update the project team would like to draw your attention to the developments related to the civic space and affecting health and rights of people living with HIV (PLHIV), people using drugs (PUD), LGBTQI+, sex workers (SW) and organizations involved in HIV responses. Check out previous updates.
Update includes 9 countries, recent legal developments and incidents affecting civic space are presented first, followed by updates on marginalized communities and civil society organizations working with them. In Tajikistan no significant updates within December 2025 – February 2026.
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ARMENIA
Civic space
Armenia is scheduled to hold parliamentary elections on 7th June 2026. Probably in this context, an increase in discussions of the “foreign agent” law in political discourse is observed, as well, as sharpened conflict between current government (namely, Prime Minister) and opposition (including former President and senior figures linked to the Armenian Apostolic Church): e.g. the Prime Minister Nikol Pashinyan accused former president Robert Kocharyan, opposition politicians and segments of the clergy of Armenian Apostolic Church of representing ‘external (Russia) interests’ rather than the Armenian people (article 1, article 2). Representatives of church and opposition, call the government being US and EU agents and civil society organizations being pro-government foreign agents.
Marginalised communities
The Human Rights Watch 2026 report confirms that the civic space for LGBTQI+ people in Armenia remains limited due to LGBTQI+ community being vulnerable, unprotected, and subject to widespread discrimination across state institutions, including law enforcement, education, and healthcare.
State administrative resources and restrictive internal regulations are used to silence civil society oversight. In August 2025, the Armenian Ministry of Health (MoH) suspended human rights defender Mamikon Hovsepyan (PINK Human Rights Defender NGO) from the Country Coordinating Mechanism after he publicly exposed financial mismanagement and corruption risks in the healthcare sector. The MoH justified the suspension labeling his anti-corruption oversight as “defamation.”, publicly mocked Hovsepyan and questioned his professional status to delegitimize his findings within CCM (Human Rights House, ILGA-Europe). By November 2025, the Yerevan Civil Court accepted Hovsepyan’s lawsuit to challenge this administrative retaliation.
AZERBAIJAN
Civic space
According to Human Rights Watch Azerbaijan’s poor human rights record continued to deteriorate as the government intensified its crackdown on independent media, political opponents, and civil society, silencing dissent, and further entrenching a climate of fear. In addition, Azerbaijan suspended operations or expelled United Nations-affiliated organizations, including the UN Development Program (UNDP), the UN High Commissioner for Refugees (UNHCR), and the International Committee of the Red Cross (ICRC). Authorities also revoked accreditation for the remaining international media outlets.
Marginalised communities
In late 2025 and early 2026 there were incidents showing a broader effort to control independent groups and marginalized communities:
- Police raid on LGBTQI+-friendly club “Labyrinth” in Baku in the night of 26–27 December 2025. Around 100–106 people were detained. Human rights groups criticized the raid and described it as part of broader pressure on marginalized groups, expressed solidarity with the community in Azerbaijan. Authorities stated that the operation was related to suspected drug use or administrative violations, though activists argued it targeted LGBTQI+ people specifically.
- Reports of police abuse and extortion (January 2026) – detainees after the raid reported use of violence, humiliation, and threats (during the operation); violence, humiliation, and demands for bribes, beatings, forced hair cutting, and degrading treatment (while in custody). Human-rights groups called for an investigation, but there were no publicly announced investigations into police conduct.
- Online hate speech and harassment against LGBTQI+ people – monitoring groups and civil-society reports noted significant online harassment: instances of anti-LGBTQI+ hate speech on social media platforms; and in discussions about the nightclub raid.
- Pressure and surveillance affecting LGBTQI+ activists and NGOs – human-rights groups and reports mention pressure on activists and civil-society organizations working on LGBTQI+ or related issues: authorities used monitoring or deceptive tactics to identify LGBTQI+ individuals or their addresses.
- LGBTQI+ public gatherings or events remain rare due to safety concerns and fear of backlash, which restricts freedom of assembly for activists.
Raid fits into a wider climate of pressure on civil society in Azerbaijan – some queer activists and NGO representatives were questioned by prosecutors regarding foreign funding or grants. Such pressure has knock-on effects on NGOs working on HIV prevention, LGBTQI+ rights, and other services.
Azerbaijan stays on punitive drug policy path. In the fall 2025 the “State Program on Combating the Illegal Circulation of Narcotic Drugs, Psychotropic Substances and Their Precursors and Drug Addiction for 2025–2030” has been officially approved following a decree signed by Azerbaijani President Ilham Aliyev. The new program, as the previous one:
- Keeps emphasis on supply reduction (illegal trafficking) and demand reduction (abstinence-based prevention and treatment).
- Operates under a punitive framework where personal use remains criminalized.
- Does not prioritize harm reduction or opioid substitution therapy (OST).
Sex workers are not “left behind” as well – attention of authorities to online sex-work arrangements, which have become more common through social media and messaging apps, is growing. in January a new regulation introduced a 500-manat (255 EUR) administrative fine for public calls to engage in prostitution on the internet (for example on social media or messaging platforms).
BELARUS
Civic space
Lawtrend’s report “Monitoring of the situation with freedom of association and the status of civil society organizations in the Republic of Belarus – January 2026” concludes that the scale of repression has not decreased, while forced liquidations, prosecutions, searches, and the use of “extremism” designations against civic actors continue.
Marginalised communities
ILGA-Europe’s Annual Review 2026 confirms that the environment for LGBTQI+ community further deteriorated during 2025, including through expanded anti-LGBTQI+ restrictions and continued risks for those working on related rights issues in Belarus. In January 2026 a Law No. 86-Z amending the Law “On the Rights of the Child” (adopted in July 2025) entered into force. The new wording classifies as harmful to children’s psychological health the “propaganda of homosexual relations, gender reassignment, pedophilia, and childlessness,” and also refers to discrediting the institution of the family and marital and family relations for such purposes. This strengthens and makes more explicit the existing anti-LGBTQI+ restrictions.
Tightening the grip on “drug-propaganda”: in February 2026, the Belarusian authorities published a “Draft Law on Amendments to Laws on Counteracting Illicit Trafficking in Narcotic Drugs, Psychotropic Substances, Their Precursors and Analogues” introducing administrative liability for so-called “propaganda of narcotic drugs, psychotropic substances, and their analogues” and defines this concept very broadly, including dissemination of information about methods of manufacture, acquisition, use, cultivation, names, chemical structure, or any content presenting consumption as permissible, attractive, or necessary.
GEORGIA
Civic space
Georgia keeps a steady civic space deterioration path with “foreign agent”, FARA laws and further restriction within the Law on Grants. Amendments to the Law on Grants passed on 3rd March 2026, and signed into force the same day by President Mikheil Kavelashvili tighten foreign funding, expand the grant definition and impose stricter penalties:
- Grants require prior government approval.
- OSCE Office for Democratic Institutions and Human Rights says it sanctions civil society organisations and other recipients of foreign funding, bans them from joining political parties and running for public office, further constrain international financial assistance to civil society, and criminalises activities deemed to “delegitimise” the government.
- Violations carry prison terms up to six years, fines, or community service, escalating from 2025’s fines (double the grant amount). Party leaders face criminal liability for unauthorized funding.
The new legislation would have a detrimental impact on the rights to freedom of expression and of association, and severely limits political and public participation. The broad scope of the law could potentially impact not just independent civil society organisations and human rights defenders, but also individual experts, consultants, or service providers.
Marginalised populations
Recent amendments to Georgia’s Mental Health Law mandate the creation of a national registry of individuals with mental health conditions by 1 May 2026. The registry is to be established with the active involvement of the Ministry of Internal Affairs, granting law enforcement authorities access to highly sensitive mental health data. People using drugs would also be included into the registry. Organisations working in the field of mental health and human rights; mental health professionals and human rights experts, fear that framed as measures to enhance public safety, the amendments in fact constitute an unjustified interference with the right to respect for private life and create conditions conducive to discrimination, stigmatization and exclusion from public and political life, compounded by the risk of unauthorized access to sensitive data.
KAZAKHSTAN
Civic space
Kazakhstan is preparing to adopt a new Constitution via a nationwide referendum on 15 March 2026 text of which raises concerns in relation to democracy and civic space:
- The president gains expanded appointment authority over key institutions like the Supreme Court, Central Election Commission, and vice president.
- Removes explicit supremacy of international law clause and states that international treaties ratified by Kazakhstan will be implemented through national legislation in accordance with constitutional norms, subjecting them to parliamentary oversight to resolve potential conflicts with domestic law, including provisions that would give priority to “national security and the protection of traditional values” over international obligations.
- State’s strategy shifted from adopting a separate law on “foreign agents” to constitutional legitimization of restrictions – amendments include mandatory state audits of organizations receiving foreign funding to ensure that it is “in line with national interests.” This effectively introduces a “foreign agent” regime at the highest legal level, making any future restrictions on NGO activities irreversible and immune from challenge in international courts (article 1, article 2).
Between January and March 2026, amid preparations for a referendum increased pressure on the civil sector was observed: administrative arrests (around 20 people detained or fined), fines for “illegal” surveys for persons and media, social media blocks, and criminal prosecution under the pretext of combating extremism. Police are conducting phone calls to citizens who publish posts criticizing the Constitution, citing the fight against the spread of knowingly false information as the reason.
In addition:
- Kazakhstan’s Ministry of Finance maintains and expanded a public registry of individuals and entities receiving foreign funding, with key changes effective from January 2026 under the new Tax Code. Based on an order from the Ministry of Finance, starting in January 2026, the registry has become very detailed – registry includes not only the names of organizations, but also specific sources (donors), exact grant amounts, and project goals and objectives. Article 460-1 of Kazakhstan’s Code of Administrative Offenses establishes fines for violations in reporting foreign funding, with amounts scaling up to about 1,081,250 tenge (around 1.900 EUR) in 2026. Repeated offenses can lead to activity suspension for up to 3 months, targeting non-profits and individuals for late, incomplete, or false disclosures.
- Adopted on 30 December 2025 a law “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on Public Associations and Social Protection of Persons Engaged in Work with Harmful Working Conditions” has made registration in the information system (the Unified Digital Platform e-NPO) mandatory for NGOs. From February 2026, the absence of up-to-date data in the e-NPO system or refusal to register on the platform will be grounds for blocking access to state social orders and grant funding.
All of the above, takes “foreign agent” like provision to the highest legal level with governmental oversight and control systems in place.
Marginalised communities
Law of the Republic of Kazakhstan “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on Archival Matters and Restrictions on the Distribution of Illegal Content” adopted on 30 December 2025, introduces an official ban on “propaganda of non-traditional sexual orientation” with amendments for 8 laws. The law might lead to increased violence, blocking of human rights websites, closure of NGOs, heightened stigma, and worsening public health outcomes as access to accurate information on sexual and reproductive health, HIV prevention might become very restricted.
In addition, the chilling effect for LGBTQI+ community and organizations is created by the following incidents:
- Between December 2025 and February 2026, there were cases of prosecution and arrests of both LGBTQI+ activists and journalists in Kazakhstan due to their activities in relation to the proposed “LGBT propaganda” law.
- In February 2026, Kazakhstan adopted amendments to subordinate legislation concerning the Unified System for Monitoring the Internet Space and strengthened monitoring through the Unified Internet Access Gateway (EShDI), including blocking VPN, P2P, and remote access by default. The law works on a “declarative” basis — blocking or fines are imposed after complaints are received from citizens or monitoring groups.
As of February 2026, social media accounts and websites of organizations providing psychological assistance to LGBTQI+ teenagers have already been monitored, as their content was deemed “harmful to spiritual development.” There were also reports of selective blocking of foreign resources that did not remove such content at the request of the Ministry of Culture and Information.
- High-profile criminal cases against the heads of independent media outlets—Gulnara Bazhkova (Orda.kz) and Amir Kasev (KazTAG) in December 2025–February 2026 under Article 274 of the Criminal Code “Spreading false information” — sent a signal to the entire media market. Since these publications were the main platforms for covering the problems of the marginalized groups, their neutralization led to total self-censorship by other media outlets.
KYRGYZSTAN
Civic space
On 18 December 2025 OHCHR published the report “IMPACT OF THE LAW ON NON-COMMERCIAL ORGANIZATIONS ON CIVIL SOCIETY IN KYRGYZSTAN” (so-called the Law on foreign agents) stating that although the authorities did not adopt a punitive approach to the implementation of the Law on Foreign agents, its enactment and accompanying practices (e.g. increased surveillance, detention of human rights defenders, journalists and activists and negative public rhetoric about civil society organizations (CSOs)) have had a significant impact on the daily functioning of CSOs. 76 per cent of CSOs reported a chilling effect on their activities – self-censorship, reduced public-facing activities (scaled down advocacy, media, and outreach), censored communications (avoided sensitive language/criticism). Not only does this raise concerns related to freedom of expression, but it also effectively amounts to an excessive interference in the ability of CSOs to undertake their functions, thereby also amounting to undue restriction on the right to freedom of association.
The right to peaceful assembly still restricted. The ban on peaceful assemblies in centre of Bishkek has been extended until 31 March 2026 and even though in previous years the march on 8th March has been allowed, it was denied in 2026 for the reasons of Ramadan and Orozo.
Marginalised communities
The same OHCHR report states that LGBTQ+ movement has become extremely marginalized in Kyrgyzstan – LGBTQI+ organizations have been specifically targeted, including through hate speech, smear campaigns, threats of arrest, acts of violence, intimidation and legal restrictions. Public discourse, shaped by political figures and conservative commentators, has framed LGBTQ+ advocacy as a foreign threat to national values.
The Law on Foreign agents and associated legislation, such as the law on “harmful information for children,” have created a highly restrictive environment for organizations assisting LGBTQI+, sex workers, people living with HIV/AIDS and drug users in the Kyrgyz Republic:
- Self-censorship: CSOs and community-led organizations that work with marginalized communities in response to the Law on Foreign agents modified their charters, removing references to advocacy, and stopped their previously core activities of advocating for changes in laws and practices and turned instead to only service provision. Cooperation between CSOs and Government also deteriorated. LGBTQI+ organizations believe that they were one of the primary targets of the Law on Foreign Representatives.
- Criminalization and crackdowns have forced many sex workers underground and drastically reduced their access to prevention programs.
As of February 2026 law enforcement raids about 70 sex workers were taken to the police station, 30 administrative reports were drawn up under Article 109 of the Criminal Code of the Kyrgyz Republic, and fines of 20,000 soms (approximately 198 EUR) were imposed on each sex worker.
In January 2026, members of the Supreme Council (Жогорку Кеңеш) submitted for public discussion a draft law “On Amendments to Certain Legislative Acts of the Kyrgyz Republic (Family Code, Law of the Kyrgyz Republic ”On Civil Status Acts,“ Law of the Kyrgyz Republic ”On the Protection of Citizens’ Health in the Kyrgyz Republic“)” with amendments aiming banning the possibility to change gender marker and prohibiting medical interventions of gender affirming surgery. In addition to obvious risks to civil society and community organizations supporting trans* people and trans* people themselves, there are risks related to broad formulations in the law (e.g. “with regard to minors, any actions aimed at changing their gender identity or forming ideas about the possibility of changing their gender are prohibited…”), which could be used to ban psychological assistance, educational programs, counselling, outreach work, and information campaigns.
MOLDOVA
Marginalised communities
A pattern (December 2025 – February 2026) of violence against LGBTQI+ people being lured into the meetings via dating apps is evident.
For example, on 10 January 2026, an LGBTQI+ person was lured to a meeting via a dating app, subjected to intimidation/blackmail, robbery, deprivation of liberty, and physical assault. Police detained the suspects and cases were opened/charges were brought for violent crimes with a bias motive. In February 2026, at least two more similar incidents were reported.
Оn 26 December 2025, the Ministry of Internal Affairs submitted for public consultation a draft law on amendments to a number of regulatory acts in the field of preventing and combating illicit drug trafficking No. 1026/MAI/2025. In February 2026 the draft has been sent to the Government for subsequent submission to Parliament; comments and proposals from civil society organisations on the draft have been rejected. The draft law maintains and reinforces a punitive approach to drug use and introduces additional reporting obligations for “suspected use,” which raises serious concerns in terms of the right to health, confidentiality, and access to harm reduction services.
UKRAINE
Civis space
At the end of 2025, the study “CSO Barometer 2025” confirmed that the environment for civil society in Ukraine remains relatively favourable and is even strengthening: the implementation of the National Strategy for CSO Development continues, an action plan for the development of civil society for 2025–2026 has been adopted, and the registration of organizations through e-governance system “Diia” has been simplified.
At the same time, serious challenges have been identified: deteriorating access to funding due to the curtailment of certain international assistance programs (including USAID), problems with banking services for CSOs, stricter requirements from the National Bank of Ukraine, and cases of persecution of activists, which negatively affect freedom of expression and the space for civil society.
Marginalised communities
On 12 February 2025, Verkhovna Rada adopted in the first reading bill No. 9398 that removes an article of the Criminal Code for infection with HIV and other incurable infectious diseases and transfers such cases to the general provisions on causing harm to health. Human rights and HIV service organizations view this as a step toward decriminalizing HIV transmission and reducing stigma.
No news to previously introduced draft laws with components of “anti-drug propaganda” and “anti-lgbt propaganda”
According to the 2025 report by the LGBTQI+ human rights center “Nash Svit” from January to September 2025, 44 cases of violence, discrimination, and other violations of the rights of LGBTQI+ people in Ukraine were documented:
- A significant portion involved attacks on LGBTQI+ events and centres, as well as on businesses that support equality (in particular, KyivPride, KharkivPride, Insight, and the Sens bookstore).
- In addition, there have been cases of discrimination and violence in the military, education, and the service sector. 44 documented incidents included cases of sexual violence and discriminatory pressure on LGBTQI+ military personnel by the command, failure to register complaints, and denial of services.
- In 20 cases, the victims reported the incidents to the police. In at least 6 cases, violations of rights by law enforcement officers themselves were recorded: ineffective investigations, discriminatory treatment, and in one case, the unlawful use of physical violence.
According to the results of a study on barriers to accessing services and the impact of martial law on the rights of sex workers by “Legalife-Ukraine”, 69% of sex workers surveyed have faced violations of their rights (an increase of 13% compared to the start of the war), and 39% have faced various forms of violence, over the past 12 months. Violations were particularly frequent from medical workers (40% of cases) and law enforcement officials (27% of cases), including insults, degrading treatment, extortion and blackmail, illegal detentions and searches, torture, and ill-treatment.
UZBEKISTAN
Civic space
CIVICUS monitor notes increased pressure on critical voices of civil society and discussions of possible additional restrictions; mentions the call for a “foreign agent” approach as a sign of pressure.
As of February 2026, a separate law that would clearly regulate the procedure for holding peaceful assemblies has still not been adopted, and this continues to create legal uncertainty, to the extent that peaceful solo/small actions can be interpreted as “disturbing the peace”, e.g. Sardoba flood victims fined for peaceful protest for promised housing.Liability for “violating public order” continues to be applied under Article 201 of the Code of Administrative Offenses (fine/administrative arrest).
January 2026 can be marked as a month of violation of right to freedom of expression. It witnessed massive blocks of social media (Instagram), Telegram and YouTube channels of media, activists, opposition leaders and human rights organizations. The suspected causes are for “being uncomfortable” as for example the human rights organizations’ channel featured interviews, analysis, and documentation of torture/violations. The removal has impaired access to archives and independent monitoring.
Marginalised communities
Internal monitoring of human rights activists have recorded 102 cases of violations of rights based on SOGI, including 12 criminal cases under Article 120 of the Criminal Code criminalising consensual same-sex relations between men in the period of December 2025 – February 2026.
A month-long campaign on crimes against morality is currently implemented, and data on the persecution of individuals under Article 120 is being recorded, including through the identification of LGBTQI+ individuals at dachas and other recreational facilities, raids on sex workers.
Uzbekistan continues on the path of criminalization of drug use: within the Presidential Decree No. DP-207 of the President of the Republic of Uzbekistan “On comprehensive measures for the effective protection of public health and the nation’s gene pool from drug addiction and drug-related crime” (3 November 2025), on 10 February 2026, a bill was passed to toughen penalties for drug-related crimes including stricter liability, administrative measures for use/being under the influence in public places. Human rights activists fear that the law can be used to arrest uncomfortable activists, not excluding by planting psychoactive substances on them.
