Project RESILIENT Update, December 2025
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 project team would like to draw your attention to the developments affecting health and rights of people living with HIV (PLHIV), people using drugs (PUD), LGBTQI+, sex workers and organizations involved in HIV responses.
The region of Eastern Europe and Central Asia (EECA) continues to experience the shrinking civic space with “foreign agent” law initiatives and “anti-LGBTQI+ propaganda” and “drug-propaganda” laws [1]:
- 2 countries have adopted “foreign agent” laws – Georgia and Kyrgyzstan; Armenia, Kazakhstan and Moldova had related initiatives.
- 5 countries have laws that restrict registration, operation and/ or funding of the civil society organizations – Azerbaijan, Belarus, Kazakhstan, Tajikistan, Uzbekistan.
- 6 countries have “drug-propaganda” like laws – Azerbaijan, Belarus, Kazakhstan, Kyrgyzstan, Tajikistan and Uzbekistan. Discussions of such legal initiatives are ongoing in Ukraine.
- Armenia and Uzbekistan have legal initiatives which continue and strengthen drug policy relying on punitive measures, rather than health and human rights.
- 3 countries have “anti-LGBT propaganda” like laws – Belarus, Georgia, Kyrgyzstan. Ongoing discussions are in Ukraine, very active phase of law introduction in Kazakhstan.
These laws not only target key populations (LGBTQI+, PUD, SW, PLHIV), impede the functioning of civil society and community organizations, including working in HIV response, but also may be used as means to pressure and silence uncomfortable civil society/ community organizations and media.
Below please find the recent worrying developments in Armenia, Kazakhstan, Kyrgyzstan and Uzbekistan. Atter adoption of health and rights-oriented Drug Policy Strategy in summer 2025 Ukraine presents some concerning processes as well.
Armenia
In June 2025 the Government of Armenia approved the 2025-2027 Strategy for Combating the Non-Medical Use and Illicit Trafficking of Narcotic Drugs and Psychotropic Substances, which envisages that conscripts, military personnel, school children and students may be subject to voluntary drug testing.
- Experts have warned that testing children is not an effective prevention method and may lead to stigmatization, discrimination, or labelling of minors who test positive. Instead, they stress the importance of education, awareness-raising, and early recognition of behavioural changes.
- There is a fear that voluntary testing in hierarchical environments will become mandatory as fit to duty test, that such testing may become coercive in practice.
To add to these fears, currently the Draft law on amendments and additions to the Criminal Code of Armenia focuses heavily on expanding aggravating circumstances. This deepens the longstanding concern that the government continues to rely on increasingly punitive responses without investing in harm-reduction services, youth mental-health support, or community-based rehabilitation. Additionally, treating online drug distribution as an aggravating circumstance may lead to expanded digital surveillance.
Kazakhstan
Recent legislative initiatives in the Republic of Kazakhstan aim to introduce administrative liability for so-called “propaganda of non-traditional sexual orientation”. These proposals pose a serious threat to the human rights and dignity of LGBTQI+ people, contradict the state’s international obligations, and create grounds for arbitrary restrictions on freedom of expression, access to information, and the activities of civil society:
- On October 28–29, 2025, the Majilis Working Group approved amendments to the draft law “On Archival Affairs and Amendments to Certain Legislative Acts”, which introduces provisions criminalizing so-called “propaganda of non-traditional sexual orientation.”
- Amendments were also made to the Law “On the Rights of the Child”: Paragraph 3 of Article 34 is supplemented after the word “violence” with the phrase “propaganda of non-traditional sexual orientation and paedophilia.” In paragraph 1 of Article 39, after the word “pornography,” the word “propaganda” is added. Part 3 of paragraph 1 of Article 39 is supplemented with a new definition:
“For the purposes of this Law, propaganda means the dissemination of information about non-traditional sexual orientation and adherence to it, carried out publicly or through mass media, telecommunications networks, or online platforms, including the deliberate distortion of such information for an indefinite audience for the purpose of forming a positive image.” - Similar amendments are proposed to the Laws “On Advertising”, “On Communications”, “On Culture”, “On Education”, “On Protecting Children from Information Harmful to Their Health and Development”, “On Cinematography”, “On Online Platforms”, and “On Mass Media.”
- Members of the working group unanimously supported amendments to the Code of Administrative Offenses of the Republic of Kazakhstan, adding Article 456-2, which establishes administrative liability for “propaganda of non-traditional sexual orientation and paedophilia”. The proposed sanctions include a fine of 20 monthly calculation indices for a first offense and 40 monthly indices (about USD 300) or up to 10 days of administrative arrest for repeat offenses.
ECOM is concerned that such laws might lead to increased violence, blocking of human rights websites, closure of NGOs, heightened stigma, and worsening public health outcomes. The World Health Organization (WHO) and UNESCO recognize access to accurate information on sexual and reproductive health as part of the human right to health and education. Restricting such access causes direct harm, especially to adolescents and young people, for whom information on identity and health is critically important.
Kyrgyzstan
On 23 September, it was announced that the Kyrgyz President signed a law mandating the closure of the National Centre for the Prevention of Torture (NCPT) and transferring its torture prevention mandate to the Ombudsperson. Office of the High Commissioner for Human Rights (OHCHR) signals that it violates Kyrgyzstan obligations towards protection of the human rights.
In addition, in July 2025 the amendments to the Criminal Code Article 18 were proposed to consider acts committed “for the purpose of protecting sovereignty, the constitutional order, national, environmental, economic, and information security, public order, the health and morality of the population, and the rights and freedoms of citizens” as non-criminal. Such wording allows law enforcement officials to broadly interpret actions as permissible, even if they formally fall under the definition of a crime. Also, such concepts as ‘morality’, ‘information security’ or ‘economic security’ have no clear legal definition and can be used to justify actions that contradict the principles of legality and equality.
Kyrgyzstan civil society must be vigilant and monitor if the discussions around these amendments continue after Cabinet of Ministers is formed after elections in November-December 2025, as protection of “morality of the population” in combination with “non-criminal acts” might be weaponized against PUD and sex workers.
Ukraine
In August 2025 Ukraine has adopted a new Drug Policy Strategy until 2030 and approved the operational plan for its implementation for 2025–2027 with a big emphasis on development of harm reduction and opioid maintenance treatment (OMT). At the same time, both “drug-propaganda” and “anti-LGBT propaganda” laws are under discussion.
In 2025, discussions continue on a previously registered bill to amend the Criminal Code of Ukraine regarding the criminalization of advertising or propaganda of narcotic drugs, psychotropic substances, their analogues, or precursors. The bill is currently under discussion and review.
It is proposed to supplement the Criminal Code with a new article 315-1, “Advertising or propaganda of narcotic drugs, psychotropic substances, their analogues or precursors”, which could blur the concept of “propaganda” and create the risk of criminal prosecution for organizations that disseminate information about harm reduction, HIV prevention, and the rights of people who use drugs.
The bill of Draft Law on Amendments to the Code of Ukraine on Administrative Offenses Regarding Liability for Propagating Deviations from Constitutional Norms on Family, Childhood, Motherhood, and Fatherhood was registered in 2021 and reintroduced to the agenda of the Verkhovna Rada of Ukraine in 2025, currently under review and analysis in parliament.
It proposes introducing a new Article 180-2, “Propaganda of paedophilia, homosexuality, and transgenderism,” into the Code of Ukraine on Administrative Offenses, which would create a legal basis for censorship, persecution of LGBTQI+ organizations, blocking of educational and advocacy initiatives, and administrative pressure on civil society organizations working in the field of human rights.
Uzbekistan
Uzbekistan remains the only country in the region that criminalises consensual same-sex relations between men under Article 120 of the Criminal Code. The Article provides for up to three years’ imprisonment for consensual sexual contact between men. Relationships between women are not formally mentioned in the Criminal Code, but any open LGBTQI+ lifestyle is subject to prosecution under this article in the case of men and trans women.
On 8th November 2025, a 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” (hereinafter referred to as the Decree) came into force. The Decree is positioned as an instrument for implementing the National Strategy for Combating Drug Addiction and Drug-Related Crime for 2024-2028 and protecting “public health and the nation’s gene pool,” with a particular focus on young people. The Decree aims to comprehensively combat drug addiction as a serious threat to public health and the nation’s gene pool, as well as to eliminate organised drug crime. A separate priority is the comprehensive protection of minors and young people from drugs, with increased responsibility on the part of all state bodies.
EHRA is concerned that the legislative amendments and systemic changes to the work of institutions planned under this Decree increase risk of systematic human rights violations and threats to the health of people who use drugs and other marginalised communities such as LGBTQI+, sex workers, and people living with HIV.
Importantly, the Decree No. DP-207 overlaps with amendments already adopted in 2025, introducing mandatory HIV testing for Uzbek citizens aged 18–60 who have been abroad for more than 90 days without interruption, as well as for foreigners and stateless persons entering or residing in the country for work purposes. Combined with an increasingly punitive drug policy, this creates an environment in which control and surveillance replace voluntary testing, confidential counseling, and human rights-based support.
RESILIENT project (started in 2025) – implemented by EHRA, ECOM, EWNA and SWAN – aims to build resilience and strengthen advocacy of community-led groups/organizations in the countries of Eastern Europe & Central Asia (EECA) to prevent and mitigate regulatory challenges (including “foreign agent”, “anti-LGBT propaganda”, “drug-propaganda” like laws) that threaten the rights of PLHIV, PUD, LGBTQI+, sex workers and organizations involved in HIV responses.
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[1] “Foreign agent“ laws force civil society organizations receiving foreign funding to register under stigmatizing labels, subjecting them to burdensome reporting, state surveillance, and reputational attacks. “Propaganda” bans are increasingly used to criminalize access to information. Drug “propaganda” laws might restrict public education on harm reduction, while LGBTQI+ “propaganda” bans erase visibility and delegitimize queer identities in media, schools, and public discourse.