For the seventh consecutive year, the European Network of National Human Rights Institutions (ENNHRI) continues, through its annual joint reporting, to present developments and challenges affecting the rule of law, democracy, and human rights across Europe. National Human Rights Institutions (NHRIs) from across the continent have come together to report on the overall state of the rule of law.

In 2025, NHRIs from across Europe continued to play an active role towards upholding the rule of law, human rights and democratic values. They engaged in this through functions including providing human rights recommendations to authorities; dealing with complaints; issuing advice to right-holders; providing support to human rights defenders (HRDs) and civil society organisations (CSOs); monitoring of national trends and challenges; capacity-building and training a diverse range of actors; targeted advocacy; and taking up new mandates. 

At the same time, NHRIs reported a range of interconnected challenges, including constraints on the enabling environment for NHRIs and civic space actors, limitations in participation in law-making processes, the growing impact of disinformation on democratic systems, and persistent structural human rights issues. Such issues affect key components of the rule of law, pointing to a situation that requires coordinated, sustained, and decisive action by diverse actors at both national and regional level.

The 2025 reporting period was also shaped by several important developments at regional level. At EU level, key policy initiatives included: the European Commission’s 2025 Charter Report (mid-term review from the 2020 Charter Strategy); the European Democracy Shield initiative; and the European Civil Society Strategy. The EU 2025 Enlargement Package continued to link progress of enlargement countries on Chapter 23 (Judiciary and Fundamental Rights) and Chapter 24 (Justice, Freedom and Security). At Council of Europe level, the New Democratic Pact for Europe and the Venice Commission’s updated rule of law checklist have served as a matrix for initiatives relevant to the rule of law.

In this context, ENNHRI engaged actively with regional partners, contributing to consultation processes and issuing recommendations with a view to strengthen the promotion and protection of human rights, democracy and the rule of law across Europe, including through the meaningful involvement of NHRIs. In addition, ENNHRI supported NHRIs throughout the reporting period by providing platforms for the exchange of good practices, facilitating peer learning and support, and fostering cooperation among its members to strengthen their capacity and effectiveness. 

ENNHRI welcomes the continued commitment of regional actors, including the European Commission and the Council of Europe, to consulting NHRIs in their reporting, monitoring, and standard-setting activities. NHRIs’ contributions to advancing the respect for the rule of law and human rights have been recognised across a number of regional initiatives, including the EU Civil Society Strategy, the annual EU Charter reports and the corresponding Council Conclusions, the European Democracy Shield, as well as the Council of Europe New Democratic Pact. This recognition comes amid increasingly difficult operating conditions for many NHRIs across Europe. Through their own national reports, recommendations, awareness-raising and regular engagement with state authorities, civil society and the broader public, as well as joint statements and positions issued through ENNHRI, NHRIs play a crucial role in reinforcing the impact and follow-up of EU and Council of Europe rule of law findings and standards.

Against this backdrop, ENNHRI’s 2026 Regional Rule of Law Report provides a thorough assessment of developments across wider Europe, alongside targeted recommendations to address identified shortcomings. The report draws on evidence from NHRIs and highlights regional structural issues and emerging risks. It also showcases the actions undertaken by NHRIs to monitor, prevent, and respond to the rule of law challenges at national level. 

The report covers key thematic areas central to the rule of law, through the NHRI perspective, thereby providing actionable insights on the state of the rule of law across Europe. It examines the enabling environment for NHRIs, including aspects reflecting NHRIs’ establishment, independence, effectiveness, and resilience. Further, the report assesses the state of civil society space and the situation of human rights defenders. A third section is dedicated to the overall state of democracy, with special attention devoted to disinformation and law-making processes. The final sections focus on structural human rights issues affecting the rule of law, as well as other rule of law challenges, as identified by ENNHRI members.

This publication constitutes ENNHRI’s cross-regional analysis of the rule of law developments throughout Europe. It complements two previously published reports: one capturing the state of the rule of law in the European Union, and one presenting rule of law developments across the enlargement region.

Across Europe, there has been some progress concerning the establishment and international accreditation of NHRIs. There are currently 31 NHRIs with A-status. Eight European NHRIs were re-accredited with A-status over the last monitoring period (Autumn 2025 and Spring 2026): Bulgaria (Ombudsman), Croatia, Ireland, Latvia, the Netherlands, Scotland, Slovenia, and Ukraine. There are seven states with B-status NHRIs (Azerbaijan, Belgium (FIRM-IFDH and Unia), Hungary, Montenegro, North Macedonia, Slovakia, and Türkiye), and 10 states with an ENNHRI member which has committed to taking steps towards accreditation (Andorra, Belgium (Myria, Combat Poverty), Czechia, Iceland, Kosovo*, Liechtenstein, Malta, Monaco, Romania, and Switzerland). 

Italy and San Marino are therefore the only Council of Europe member States in which there is currently no institution either accredited as an NHRI or working towards compliance with the UN Paris Principles with a view to NHRI accreditation.

As indicated in the present report, a majority of NHRIs from across Europe continue to face challenges, impacting their effectiveness and operating space. These included: a lack of adequate funding and resources; challenges in the application of international standards on appointment of the decision-making body; lack of access to information and to national authorities; and a lack of adequate follow-up by state authorities to recommendations issued by NHRIs. 

While generally welcomed by NHRIs, the attribution of new mandates by state authorities, including those stemming from the EU acquis and other international frameworks, has raised significant concerns when decided upon without prior consultation with the NHRI and without a corresponding increase in resources. 

Furthermore, NHRIs from across Europe face various threats, such as online attacks and defamatory campaigns directed against the institution and its work, as well as verbal and physical attacks against the institution, its work, and staff. Over the 2025 monitoring period, 20 NHRIs reported such issues. Concerningly, public verbal attacks and defamatory campaigns have sometimes originated from public officials.

ENNHRI’s key recommendations

ENNHRI calls on national authorities to:

• Respect and strengthen the enabling environment for strong and independent NHRIs, in line with the UN Paris Principles and relevant regional standards; 
• Ensure that NHRIs are provided with adequate, sustainable and predictable financial and human resources commensurate with the scope and complexity of their mandates, and consult NHRIs in advance when new mandates are assigned; 
• Cooperate and follow-up on NHRIs’ recommendations; and 
• Protect NHRIs from any form of intimidation, threats or attacks. 

ENNHRI calls on European and regional actors to:

• Continue and strengthen their support for NHRIs across Europe in delivering mandates, including those stemming from the EU acquis and other regional and international frameworks;
• Ensure sufficient support to strengthen NHRI capacity, resilience and effectiveness, in particular through training and capacity building; and
• Continue to speak out in support of NHRIs, including where they face threats, attacks or undue interference.

Over the last reporting period, ENNHRI members from across Europe confirmed that civic space has further deteriorated. Worryingly, only six NHRIs have reported an open environment for CSOs and HRDs, whereas a majority of European NHRIs reported a narrowing environment for the functioning of CSOs and HRDs. A further three ENNHRI members warned that CSOs and HRDs operate in a restricted civic space.

A majority of NHRIs in Europe pointed to the persistent lack of adequate funding for CSOs and HRDs as a substantial structural challenge, sometimes as the result of explicit barriers to funding, including from foreign sources. Meaningful consultation with CSOs and HRDs in law- and policy-making was reported to be significantly hampered by barriers, such as tight consultation deadlines, lack of access to information, and lack of transparency in consultation processes. Laws and policies restricting freedom of association and peaceful assembly, including undue restrictions on protests, persist across Europe, resulting in adverse conditions for CSOs and HRDs to operate. 

The report also documents instances of verbal and physical attacks on CSOs and their representatives, including HRDs. These attacks come from a wide range of actors and may take different forms, with online threats and harassment being noted as particularly concerning by ENNHRI members. Other threats to CSOs and HRDs include the criminalisation of their work by state actors, strategic lawsuits against public participation (SLAPPs), and an overall rise in negative narratives surrounding their work. Some groups, including environmental defenders, women HRDs, LGBTI defenders and those working on migration, are more often impacted.

In order to address this, NHRIs have carried out a large array of activities to promote and protect civic space and HRDs. They promoted civic space by organising large-scale communication campaigns, joint meetings, roundtables, as well as trainings for national authorities, CSO representatives, HRDs, and journalists. Initiatives by NHRIs aimed at protecting civil society space and HRDs included monitoring on the situation of CSOs and HRDs nationally and on the implementation of relevant international and regional standards on HRDs protection. In addition, NHRIs issued recommendations to national authorities on strengthening and safeguarding civic space, and support to individuals included complaints-handling or legal assistance. NHRIs have stressed that these efforts require backing from authorities in the form of adequate funding and specific HRD protection mechanisms, including dedicated legislation, both at national and European level.

ENNHRI’s key recommendations

ENNHRI calls on national authorities to:

• Ensure a safe and enabling environment for CSOs and HRDs, including by establishing effective protection mechanisms;
• Take action to protect HRDs and CSOs from attacks and negative narratives;
• Ensure access of CSOs and HRDs to predictable, stable, and secure sources of funding, including foreign funding; and
• Guarantee freedom of assembly and association, including with particular attention for HRDs focusing on specific topics, such as women’s rights, LGBTI rights, migrants, and environmental defenders.

ENNHRI calls on European and regional actors to: 

• Ensure systematic monitoring of civic space and the situation of HRDs, and respond promptly where developments undermine human rights, democracy or the rule of law;
• Support the central role of NHRIs in contributing to the protection, engagement and support of civil society and HRDs at national level; and
• Support the establishment of dedicated national and Europe-wide protection mechanisms for CSOs and HRDs.

Disinformation features prominently as an emerging challenge to democracy. Reports by ENNHRI members across Europe have stressed its cross-cutting nature, as it impacts human rights and freedoms, erodes trust in institutions, and exacerbates entrenched issues such as discrimination and hate speech directed at groups, such as the LGBTI community, migrants, and refugees. Some ENNHRI members also reported that disinformation campaigns launched by foreign actors has been used as a tool to deliberately weaken democracy and trust in institutions.

Moreover, ENNHRI members reported disinformation campaigns directed at NHRIs, CSOs, and HRDs as a recurring issue significantly hindering their work and safety. Disinformation, a complex and composite issue, requires a targeted, coordinated, and proportionate policy response. However, in many European countries, counter-disinformation measures taken by state authorities have raised human rights concerns, particularly where draft laws lacked adequate safeguards for freedom of expression, or where disproportionate measures were introduced without sufficient consideration of their necessity and proportionality. 

NHRIs have assumed a crucial role in countering disinformation in various ways. Efforts have focused on increasing media literacy across society and have also included initiatives such as independent factchecking, and the establishment of expert advisory bodies.

ENNHRI’s key recommendations

ENNHRI calls on national authorities to combat the rise of disinformation, especially online and in the media, through: 

• Transparent, targeted, proportionate and rights-compliant policy and legal frameworks;
• Preventive approaches such as media literacy education; and
• Measures to promote access to reliable, trustworthy and pluralistic sources of information. 

ENNHRI calls on European and regional actors to:

• Pursue a comprehensive and coherent approach to tackling disinformation, including through initiatives such as the European Democracy Shield and the New Democratic Pact for Europe;
• Recognise disinformation as stemming also from within the region, as well as foreign interference;
• Strengthen monitoring of States’ implementation of relevant regional standards on tackling disinformation; and
• Ensure that responses to disinformation remain consistent with human rights.

Challenges affecting the quality and inclusiveness of law-making processes were reported across Europe. In general, several European countries lack mechanisms or processes that facilitate both general and targeted participation in the law-making process. At the same time, impact assessments, including human rights impact assessments, remain underused or inconsistent in a majority of European countries. This limits meaningful consultation, including of NHRIs, and makes it difficult to anticipate the effects of draft laws on both the rule of law and human rights. This is coupled with a lack of time allocated for consultation in the law-making process, and a widely reported use of fast-track or emergency procedures aimed at accelerating law-making processes. This represents a significant obstacle in securing meaningful consultation, including with NHRIs at all stages of the law-making process.

To address these issues, NHRIs have carried out awareness-raising activities alerting both the public and relevant actors, including parliamentarians, of the harmful effects of short consultation windows and underscoring the need for thorough and adequately paced law-making processes that include human rights impact assessments. ENNHRI members across Europe have reported issuing recommendations, opinions, monitoring reports, and statements on these concerns, and NHRIs have also provided analysis and input on specific legislative proposals.

ENNHRI’s key recommendations

ENNHRI calls on national authorities to: 

• Ensure that law-making processes are inclusive, transparent, and have a reasonable timeline for checks and balances; 
• Establish clear procedural requirements for timely and meaningful public consultation, including NHRIs and CSOs; 
• Limit the use of fast-track or emergency procedures to duly justified cases; and 
• Systematically carry out human rights impact assessments for draft legislation.   

ENNHRI calls on European and regional actors to:

• Promote and apply high standards of transparent, inclusive, and well-structured law-making;
• Ensure the systematic use of human rights impact assessments in legislative and policy proposals; 
• Improve the quality and accessibility of consultation processes; and 
• Avoid approaches that hinder effective scrutiny, such as rushed or package bills.

ENNHRI members continue to report a range of persistent and structural challenges affecting the rule of law across Europe, including pressures on media freedom and journalists, strains to justice systems, insufficient protection of groups in vulnerable situations, as well as issues related to detention conditions and checks and balances. These developments include political interference or pressure on independent institutions, delays in judicial proceedings, and weaknesses in the implementation of decisions or judgments from regional and international human rights bodies. 

In addition, NHRIs reported that persistent challenges to the rule of law are closely intertwined with structural challenges in the protection of human rights. In particular, authorities’ approaches to migration and asylum policies continue to raise concerns regarding the respect of human rights in practice, including access to asylum, non-refoulement, and effective remedies. Deficiencies in these areas, such as the use of emergency measures, limited judicial oversight, and criminalisation of CSOs’ work, have weakened safeguards, affected institutional accountability, and placed additional strain on checks and balances. This illustrated how the structural lack of respect for human rights has exacerbated broader rule of law concerns. 

In response to these persistent challenges, NHRIs continue to play a key role in monitoring, reporting, and addressing systemic rule of law concerns. Through their independent monitoring and assessments, public reporting, and engagement with national authorities, NHRIs contribute to identifying risks and promoting accountability. They also support the implementation of international and European human rights standards by issuing recommendations, intervening in public debates, and cooperating with state, civil society and other stakeholders. In doing so, NHRIs help to strengthen institutional resilience and uphold human rights in the face of ongoing pressures on the rule of law. 

ENNHRI’s key recommendations

ENNHRI calls on national authorities to:

• Ensure that all legislative, policy and administrative measures fully comply with international and European human rights standards, including by addressing structural violations of human rights identified by NHRIs; 
• Ensure effective oversight and accountability in migration contexts by refraining from measures that unduly restrict independent actors’ – including NHRIs’ and CSOs’ – work in this area;
• Ensure that domestic judgments and judgments of the European Court of Human Rights (ECtHR) are implemented fully, timely and effectively; and
• Safeguard judicial independence and reinforce the independence, effectiveness and accountability of oversight frameworks.

ENNHRI calls on European and regional actors to:

• Strengthen the systematic inclusion of NHRI findings into EU, Council of Europe, and OSCE/ODIHR Rule of Law frameworks, including challenges identified by NHRIs, and supporting European countries in implementing reforms that enhance the protection of human rights, democracy and the rule of law;
• Strengthen the monitoring and enforcement of regional standards and promote and support the formal involvement of NHRIs in this regard; and 
• Enhance their monitoring of the implementation of country-specific recommendations by States.

The European Network of National Human Rights Institutions (ENNHRI) brings together 51 National Human Rights Institutions (NHRIs) across wider Europe. It provides support for the establishment and strengthening of NHRIs, a platform for collaboration, solidarity, and a common voice for NHRIs at the regional level to enhance the promotion and protection of human rights, democracy and the rule of law in the region.  

NHRIs are state-mandated bodies, independent of government, with a broad constitutional or legal mandate to promote and protect human rights at the national level. NHRIs are established and function with compliance to the UN Paris Principles and act as bridge-builder between the state and civil society. NHRIs cooperate with a variety of civil society actors, and bring an accurate overview of the human rights situation, with recommendations to governments, parliament and other state bodies.  

NHRIs are unique because their independence, pluralism, accountability and effectiveness is periodically assessed and subject to international accreditation, carried out by the UN Sub-Committee on Accreditation (SCA) of the Global Alliance of NHRIs (GANHRI) with reference to the UN Paris Principles. This accreditation reinforces NHRIs as key interlocutors on the ground for rights holders, civil society organisations, state actors, and international bodies.  

NHRIs are a key pillar for the respect of human rights, democracy and rule of law. Moreover, a strong and independent NHRI in compliance with the UN Paris Principles is an indicator of healthy rule of law. The vital role of NHRIs in upholding human rights and the rule of law has been recognised by a wide range of actors, including the European Union, the Council of Europe, and the United Nations.

Given their broad mandate and functions, independent NHRIs also serve as reliable sources of information on rule of law compliance on the ground. NHRIs are in a key position to contribute to the rule of law monitoring mechanisms given their broad human rights mandate, structural engagement with a variety of stakeholders, and the close interconnection between the rule of law, democracy and human rights. Such consistent engagement also enhances the effective follow-up to NHRIs’ rule of law recommendations by relevant national, European and international actors.

Since 2020, ENNHRI has been coordinating NHRIs’ joint engagement with European rule of law mechanisms. On the basis of a common methodology, ENNHRI has published joint annual reports on the state of the rule of law in the European Union and wider Europe for seven consecutive years. Since 2025, ENNHRI also issues an annual report on the state of the rule of law in enlargement countries. ENNHRI’s reports compile NHRIs’ country-specific submissions, focusing on national rule of law situations, as well as an overview of common trends reflecting NHRIs’ findings on the state of the rule of law across Europe. Thus, NHRIs’ independent reporting, based on a common approach, provides comparative information. 

ENNHRI’s rule of law reporting has also fed into the network’s responses to annual consultations by relevant counterparts (EU rule of law monitoring cycle, EU annual report on application of the EU Charter, Enlargement Package), as well as some specific thematic initiatives (European Internal Security Strategy (2025), European Democracy Shield (2025), EU Strategy on Civil Society (2025)). In addition, ENNHRI’s reporting has been used by ENNHRI members for their engagement with national actors to seek responses to the identified rule of law challenges.     

ENNHRI’s 2026 Regional Rule of Law Report – both the regional overview, as well as the country-specific chapters authored by ENNHRI members from across Europe, – covers the following topics:

• NHRIs' establishment, independence, effectiveness and resilience;
• Human rights defenders and civil society space;
• Disinformation;
• Law-making processes;
• Other persisting challenges for the rule of law, including structural human rights issues.

The regional trends on all of the above topics are included in the chapter on the overview of trends and challenges. Further information on all identified trends and more detailed in-country observations are included in the country reports. 

Through targeted annual rule of law reporting, ENNHRI enhances its engagement with regional stakeholders to encourage positive change for the rule of law, human rights, and democracy. Based on this reporting, ENNHRI contributes to regional policy and standard setting, while strengthening NHRIs' capacity to uphold the rule of law, democracy and protect human rights across Europe. 

This year, ENNHRI’s joint reporting met an almost complete response rate from its members across Europe. For Italy and San Marino, ENNHRI Secretariat provided updates on their NHRI establishment progress.

Since ENNHRI’s last Regional Rule of Law Report (July 2025), eight European NHRIs were reviewed by the GANHRI Sub-Committee on Accreditation (SCA). In autumn 2025 and spring 2026, the NHRIs in Bulgaria (Ombudsman), Croatia, Ireland, Latvia, the Netherlands, Scotland, Slovenia, and Ukraine were all accredited with A-status, demonstrating full compliance with the UN Paris Principles.

In November 2026, three further NHRIs will be considered by the SCA. These are the NHRIs in Azerbaijan, France, and Serbia, all scheduled for re-accreditation.

Currently, across Europe, there are 31 A-status NHRIs and seven states with B-status NHRIs (Azerbaijan, Belgium (FIRM-IFDH and Unia), Hungary, Montenegro, North Macedonia, Slovakia, and Türkiye). There are 10 states in which an ENNHRI member exists and has committed to taking steps towards accreditation (Andorra, Belgium (Myria and Combat Poverty), Czechia, Iceland, Kosovo*, Liechtenstein, Malta, Monaco, Romania, and Switzerland). There are only two states without an institution working toward compliance with the Paris Principles (Italy and San Marino).

There has been concrete progress in some states without an accredited NHRI. In Czechia, the legislative basis of the Czech Public Defender has been strengthened and expanded to include a broad human rights promotion and protection mandate. The legislation was approved by the Senate in February 2025 and entered into force in July 2025, and it could pave the way for the future international accreditation of the Public Defender as an NHRI.

In Romania, the law establishing ENNHRI’s member, the Romanian Institute for Human Rights (RIHR), dates back to 1991 and has not been amended since, although there were two legislative proposals in 2018 and 2020 respectively, aimed at strengthening its compliance with the UN Paris Principles. RIHR and the Romanian Ombudsman institution have both applied for accreditation. At the time of drafting, the applications are pending policy guidance from the GANHRI Bureau on clarifying the application of Rule 6.3 of the SCA Rules of Procedure, regarding applications by more than one NHRI in a UN Member State.

In Switzerland, the Swiss Human Rights Institution (SHRI) was established with the intention of being accredited as an NHRI, in compliance with the UN Paris Principles. The institution began operations in early 2024 and applied for accreditation at the end of 2025, and has been provisionally scheduled for review by the SCA in 2027.

In May 2025, the High Commissioner for the Protection of Rights, Liberties and for Mediation from the Principality of Monaco became an ENNHRI member, and in doing so committed to taking steps to full compliance with the UN Paris Principles and future accreditation. In addition, the Icelandic Institute for Human Rights, established with a view to being the NHRI in Iceland, joined ENNHRI in September 2025, after commencing operations in May 2025.

In November 2024, the Maltese Ombudsman institution presented a proposal for a new Ombudsman Act, with the goal of extending its current mandate to include the promotion of human rights and fundamental freedoms, and thus strengthening its compliance with the UN Paris Principles and ensuring the establishment of an NHRI in Malta. In 2025, there was no substantive engagement from national authorities on the proposed bill. However, by the time of drafting this report, the government has tabled a draft bill for the establishment of a Human Rights and Equality Commission before the Parliament. The bill has passed a first reading and aims to assign the NHRI mandate to the existing Equality Body.

In January 2024, one of the political groups in Andorra proposed amendments to the enabling law of the Andorran Ombudsman (Raonador del Ciutadà) with the goal of strengthening the institution in line with European standards. In November 2024, the General Council adopted a new law on the Ombudsman in line with the recommendations of the Venice Principles.

Finally, due to the specific international standing of Kosovo*, the institution is unable to seek accreditation before GANHRI. It is a non-accredited, associate member of ENNHRI and has worked for the promotion and protection of a wide range of human rights issues in Kosovo*.

Given these developments, Italy and San Marino are now the only Council of Europe Member States in which there is no institution either accredited as an NHRI or working towards compliance with the UN Paris Principles with a view to NHRI accreditation.

Regarding Italy, ENNHRI is aware that there are several legislative proposals for discussion at the level of the Chamber of Deputies, and has engaged with the national authorities, and in public events organised by academia and civil society in Italy about these proposals. However, these proposals have been pending for several years, and, at the time of writing, there continues to be no clear indication of a legislative proposal establishing an NHRI being close to adoption. In early 2026, ENNHRI engaged at technical level with national authorities to provide information on the UN Paris Principles and NHRI models. ENNHRI continues to remain available to support initiatives towards the establishment of an NHRI in Italy, an effort recently echoed also by the Council of Europe Commissioner for Human Rights.

In San Marino, in 2023, a popular petition was lodged in the Grand and General Council for the establishment of an NHRI in San Marino. In 2024, the UN Human Rights Committee recommended that San Marino establishes an NHRI in compliance with the UN Paris Principles. On that occasion, San Marino informed that the Parliament had recently unanimously approved the Popular Petition (Istanza d'Arengo) for the establishment of the National Human Rights Guarantor, committing the Government to take the necessary measures to create such body. San Marino added that the petition calling for the creation of such a body will have to be implemented during the current legislature, which is expected to last until 2029. 

In seven countries, B-status NHRIs are in place. In Belgium, two B-Status NHRIs co-exist; the Federal Institute for the Protection and Promotion of Human Rights (FIRM-IFDH) and the Interfederal Centre for Equal Opportunity and Fights against Racism and Discrimination (Unia). Unia has been accredited with B-status since May 2018. In March 2023, the newly established FIRM-IFDH was also accredited with B-status. Legislative changes were introduced in April 2024 strengthening the FIRM-IFDH mandate, including for greater compliance with the Paris Principles. Both the 2025-2029 Federal Government Agreement and the 2024-2029 Flemish Government Agreement mention that the governments will aim for A-status through a cooperation agreement.

In Hungary, the Office of the Commissioner for Fundamental Rights holds a B-status since March 2022. The NHRI has reaffirmed committed to the UN Paris Principles and is taking measures towards achieving full compliance with this framework, including through an awarded project under which its staff carried out study visits to A-status NHRIs to exchange experiences and good practices.

In Montenegro, the Protector of Human Rights and Freedoms of Montenegro has held B-status since 2016. In 2025, the institution underwent a reform of its legal basis at the initiative of the government, through the introduction of a new draft law integrating the SCA recommendations from 2016, and aimed at ensuring greater compliance with the UN Paris Principles. In July 2026, the Montenegrin Cabinet adopted the final text of the draft law on the Protector, which contains provisions strengthening the institution’s independence and clarifies its human rights mandate. ENNHRI supported the Montenegrin NHRI throughout the process, which may pave the way for a ‘A-status’ NHRI in Montenegro.

Meanwhile, the NHRI in North Macedonia, holding a B-status since 2011, continues to encounter challenges concerning its financial autonomy. Despite its expanding mandate and responsibilities, it remains under-resourced. Efforts are ongoing to advocate for a stable and adequate budget that would be determined in a way that guarantees full operational independence from the executive branch. Moreover, although in practice the institution performs a broad human rights mandate, the legal framework governing its work has not yet been updated in follow-up to the SCA recommendations.

In Slovakia, the Slovak National Centre for Human Rights has been accredited with B-status already since March 2014. The Centre has strengthened its compliance with the UN Paris Principles through internal rules and practice. In view of expected changes to the institution’s legal basis in the context of the transposition of the EU Directive on Equality Bodies, the NHRI has engaged in consultations with state authorities for its legislative framework to be strengthened, including in line with the UN Paris Principles, through the inclusion of the NHRI mandate, as well as independence safeguards, in the enabling law. However, so far, no changes to the enabling framework have been made to strengthen the Centre’s mandate as an NHRI in full compliance with the UN Paris Principles.

Finally, the NHRI in Türkiye was accredited with B-status in October 2022, with the SCA including recommendations on independence and addressing human rights violations. Since then, it has taken steps to increase interaction and cooperation with international and national human rights systems, monitor and address human rights violations, follow up on activities and raise public awareness, while having its budget increased.

NHRIs’ reports pointed to the need for input and action by other actors to achieve full implementation of SCA recommendations. While some recommendations call for practical adjustments to the work of an NHRI and can be implemented unilaterally by the institution itself, others require action by the national parliament or government. In some cases, the NHRIs are encouraged by the SCA to advocate for national authorities to take steps towards realising its recommendations. Some NHRIs reported doing so, for example, in Albania, Bosnia and Herzegovina, France, Georgia, Germany, Greece, Great Britain, Luxembourg, Moldova, Montenegro, North Macedonia, the Netherlands, Sweden, Slovenia, Türkiye, and Ukraine, among others.

Some NHRIs have reported recent or upcoming legislative amendments specifically following up on SCA recommendations. For instance, the NHRI of Bosnia and Herzegovina has worked actively with authorities and civil society to implement the SCA recommendations, including through the establishment of the National Preventive Mechanism (NPM). Furthermore, the Albanian NHRI has advanced a comprehensive review of the law governing the People's Advocate of Albania, including proposals to strengthen the institution's mandate, increase its staffing capacities, and extend its competence to private actors. The NHRI of Moldova is preparing amendments aimed at further strengthening financial independence and institutional safeguards, including guarantees of protection of the institution against criminal and civil liability for work undertaken in good faith. The NHRI in Ukraine reported that consideration of draft legislative amendments is ongoing and aims to address several long-standing SCA recommendations, including provisions on appointment procedures, mandate, tenure, and financial guarantees. In addition, such amendments aim to promote a transparent and participatory selection and appointment process and to provide an explicit legal basis for cooperation with human rights organisations and public associations.  

ENNHRI plays a key role in supporting NHRIs to advocate towards national authorities to strengthen NHRIs’ enabling environment and for their legislation to comply with the UN Paris Principles. In addition, other regional actors, such as the Council of Europe, the European Commission and other EU institutions, could liaise with NHRIs to understand their needs in this regard and support effective change.

In cases where the implementation of SCA recommendations requires actions by national authorities, such as through legislative reform or allocation of additional resources, regional actors such as the Council of Europe and the EU institutions could further encourage national authorities to implement relevant SCA recommendations. It is important that regional actors engage and discuss with the relevant NHRIs the best avenues to support them in the implementation of SCA recommendations.

Regarding the follow-up to the European actors’ country-specific recommendations, most ENNHRI members reported limited or no progress in the follow-up by national authorities to such findings. However, significant progress has taken place in Czechia, where the law on the potential establishment of an NHRI came into force in July 2025.

Recent developments across Europe confirm that the institutional landscape surrounding NHRIs continues to evolve. A number of ENNHRI members, namely those in Albania, Armenia, Azerbaijan, Belgium (FIRM-IFDH, Unia, Myria), Bosnia and Herzegovina, Croatia, Czechia, France, Georgia, Hungary, Latvia, Lithuania, and Montenegro reported on the changes in their regulatory framework.

As confirmed throughout the reporting, the majority of these changes aimed at strengthening the mandates and competences of the NHRIs. For example, in the case of Czechia and France, the governing framework of the institutions was updated to enlarge competences and roles, while in Bosnia and Herzegovina, and in Latvia changes clarified the National Preventive Mechanism function of the NHRI within the existing institutional framework. In Montenegro, amendments to the Law on the Protector of Human Rights and Freedoms expanded the NHRI’s anti-discrimination mandate to cover EU, EEA and Swiss nationals exercising free movement rights within the country. In Bosnia and Herzegovina, the NHRI reported a newly formalised oversight role concerning the implementation of freedom of information legislation at different levels of government. The Georgian NHRI further reported an expansion of its monitoring mandate to include juvenile care and support facilities, effective as of July 2026. 

In Albania, the NHRI presented a comprehensive review of its enabling law, including proposals to expand its mandate to address human rights violations committed by private actors. Through amendments to the founding law of the NHRI in Armenia, the institution was provided with an explicit mandate to conduct events and activities aimed at raising public awareness on issues related to human rights and freedoms, as well as to promote the alignment of the legislation of the Republic of Armenia with international human rights standards. In Azerbaijan, an amendment was made with regard to temporary accommodation centres for migrants, allowing the NHRI to better fulfil its corresponding mandates.

A few of the reforms aimed at addressing structural issues pertaining to the effective and independent functioning of the NHRI, such as the strengthening of the institutional capacity or the financial and operational independence of the NHRI, as was the case in Albania, Greece, Luxembourg, Moldova, and Ukraine. Several NHRIs also reported efforts to strengthen internal governance, digitalisation, data collection systems and specialised monitoring methodologies.

ENNHRI's 2026 Rule of Law Reporting also confirms that ENNHRI members increasingly perform multiple mandates simultaneously. Throughout 2025, many NHRIs were entrusted with additional responsibilities arising from evolving European legal and institutional frameworks, including those linked to the implementation of relevant EU legislation, Council of Europe, and UN standards. These developments increasingly assign specific functions to independent national bodies, further broadening the role and responsibilities of NHRIs. For instance, in 2025, seven additional ENNHRI members have been appointed as national authorities protecting fundamental rights in the use of high-risk Artificial Intelligence (AI) systems under Article 77 of the AI Act (in Belgium (FIRM-IFDH, Unia and Myria), Cyprus, Denmark, Finland (Parliamentary Ombudsman), and Latvia). For example, the NHRI from Cyprus reported that in the framework of its role as the competent authority under Article 77 of the AI Act, it participates in the national committee established for the implementation of the Regulation, contributing to the promotion of a human rights-based approach to artificial intelligence governance. In addition, Unia from Belgium acquired the mandate of ‘trusted flagger’ under the EU Digital Services Act, while the NHRI from Hungary was appointed as the whistleblower protection mechanism under the EU Whistleblower Protection Directive. Furthermore, in Sweden, a proposal is currently under consideration to entrust the NHRI with the mandate of the independent monitoring mechanism pursuant to the EU Anti-Trafficking Directive.

The NHRI from Norway was entrusted the mandate of the monitoring body pursuant to the Council of Europe Convention on preventing and combating violence against women and domestic violence and the Council of Europe Convention on Action against Trafficking in Human Beings. The NHRI in Türkiye was formally designated as the national monitoring mechanism under the Convention on the Rights of Persons with Disabilities (CRPD), representing a notable expansion of its specialised monitoring functions. The member from Liechtenstein was also appointed the same mandate in 2024, which became operative in 2025. Further, the Luxembourgish NHRI was entrusted with a new mandate in the area of monitoring public video surveillance; however, it indicated that the new mandate was not reflected in the institution’s regulatory framework, and the role that the NHRI should play remains imprecise.

In the context of migration and asylum, some NHRIs have already been granted new mandates, while others are expected to receive new ones subject to pending legislative reforms affecting their regulatory frameworks. For instance, the French NHRI began exercising its advisory role in 2025, in relation to the monitoring mechanism under the EU Screening Regulation, the Cypriot and Estonian NHRIs were designated as the independent monitoring mechanisms (IMM) by laws adopted in April and May 2026 respectively, while at the time of drafting this report, the ENNHRI members in Austria, Germany, Liechtenstein, the Netherlands, and Slovenia are expected to be entrusted with this mandate under the same Regulation.

Furthermore, the institutions from Cyprus, Czechia, and Estonia have been designated to carry out the monitoring mechanism under the EU Asylum Procedure Regulation (new mandates entering into force in 2026), and, at the time of drafting, legislative processes are underway in Austria, Germany, Montenegro, and Slovenia to entrust their NHRIs with comparable responsibilities under this Regulation. In addition, the NHRIs in both Montenegro and Serbia continued working towards the establishment of border monitoring mechanisms in line with the EU Pact on Migration and Asylum. 

Two ENNHRI members reported the integration of new specialised Ombuds mandates into the institutions’ regulatory framework. In Czechia, the legislation that entrusted the Public Defender of Rights with the mandate of an NHRI in early 2025 also established the new position of a Defender of children’s rights. In Lithuania, legislative amendments added the function of an Ombudsperson for Small and Medium-Sized Business.

These developments reflect a growing recognition of NHRIs as trusted institutions capable of providing independent monitoring and accountability across multiple policy areas. However, while these additional competences strengthen the human rights monitoring ecosystem at the national level, they also place additional pressure on NHRIs and are often not accompanied by sufficient safeguards and resources to ensure their effective and independent functioning in line with international and regional standards on NHRIs.

For an overview of the most reported NHRIs’ mandates, please check this table.  

Challenges in implementing multiple mandates

ENNHRI’s 2026 Rule of Law Reporting reaffirms the numerous challenges NHRIs face in implementing multiple mandates, including those stemming from international treaties and regional legal or policy frameworks. 

Insufficient or inadequate financial and human resources remain the most frequently reported obstacle to the effective implementation of multiple mandates. A substantial number of ENNHRI members, including those from Albania, Armenia, Belgium (FIRM-IFDH and Unia), Bosnia and Herzegovina, Denmark, Finland, Germany, Greece, Ireland, Kosovo*, Liechtenstein, Lithuania, Luxembourg, Moldova, Northern Ireland, North Macedonia, Poland, Romania, Scotland, and Serbia confirmed the insufficiency or uncertainty of financial and human resources to carry out additional mandates. The Moldovan NHRI noted that only a portion of legally approved staff positions can currently be financed, while the NHRI in Bosnia and Herzegovina highlighted a persistent gap between the breadth of its mandate and available operational resources. The Scottish member highlighted that there is no designated funding into its operating budget to support the mandates of NPM and CRPD, and the funding is coming from the NHRI’s core budget.

Several NHRIs also reported difficulties arising from increasingly specialised responsibilities, where the implementation of domain-specific mandates requires dedicated expertise. The NHRI from Greece highlighted that specific and more technical mandates assigned to NHRIs require more specialised personnel and further capacity-building. The Serbian NHRI identified the need for specialised expertise in implementing anti-trafficking and CRPD-related functions.

Besides the need for adequate financial and human resources, five NHRIs also pointed to shortcomings in clearly defining the obligations of the NHRI under these additional mandates. This was observed by the NHRIs in Denmark, Finland, Luxembourg, Poland, and Scotland. For example, the NHRI from Luxembourg indicated that the new mandate in the area of monitoring public video surveillance was not reflected in the institution’s regulatory framework, and the role that the NHRI should play remains imprecise. In Scotland, the NHRI reported that neither the NPM central coordinating function, nor the OPCAT obligations are currently underpinned by UK or Scottish law, which leaves uncertainty regarding the deriving responsibilities. 

Additionally, the lack of effective follow-up from national authorities or weak cooperation with other national coordination and monitoring bodies were identified by the NHRIs from Greece, Luxembourg, Northern Ireland, and Scotland. In Northern Ireland, for example, the NHRI is mandated to oversee the implementation of relevant rights and equality protections following Brexit (Windsor Framework). However, concerns have been raised about the limited consideration of these obligations by the authorities. Similarly, the Scottish NHRI reported that there is limited coordination in the UK regarding the CRPD monitoring body. This points to gaps in follow-up and coordination that may weaken the overall effectiveness of the protection frameworks.

In other cases, NHRIs reported challenges stemming from access restrictions. The NHRIs in Moldova and in Ukraine reported significant obstacles in exercising their mandates in non-governmental controlled territories, due to lack of access, obstructions from the de facto authorities, and physical danger to the NHRIs’ staff. The NHRIs in both Georgia and Ukraine highlighted limitations affecting oversight in the field of personal data protection, while the Georgian NHRI further reported isolated cases of impediment in the systematic monitoring activities of the Public Defender Office that hindered its ability to conduct proactive inquiries.

Based on the identified challenges in implementing multiple mandates, several ENNHRI members advocate at national level for ensuring adequate, predictable and sustainable financial and human resources to fulfill the breadth and specificity of additional mandates, while also highlighting the need for support from national and regional authorities in implementing multiple mandates. Several NHRIs stressed the importance of being systematically consulted when new mandates are assigned, or legislation affecting their work is developed. In addition, institutions pointed to the need for stronger engagement, more effective follow-up to NHRI recommendations, and improved cooperation with public authorities. These needs are particularly relevant where NHRIs are expected to carry out increasingly technical monitoring functions or operate in complex contexts.

Several NHRIs further highlighted the importance of support from regional and international actors, including ENNHRI, in strengthening their effectiveness and independence. Requested support includes peer learning and exchange of good practices, capacity-building activities, and technical expertise. NHRIs also underlined the value of ENNHRI's Rule of Law Reporting, regional cooperation platforms and engagement with European actors in amplifying concerns related to NHRI independence, compliance with the UN Paris Principles and the implementation of their recommendations.

Structural challenges faced in 2025 affecting NHRI independence and effectiveness

ENNHRI’s 2026 Rule of Law Reporting confirms that NHRIs increasingly face structural challenges that hinder their ability to operate effectively and independently. These challenges are often intertwined, involving a combination of insufficient resources, an inadequate legal framework, and a rise in political pressure.

Twenty-one ENNHRI members reported a structural lack of sufficient or adequate resources for the NHRI to carry out their mandates. This is the case in Albania, Belgium, Bosnia and Herzegovina, Czechia, Denmark, Finland, France, Germany, Great Britain, Ireland, Liechtenstein, Lithuania, Luxembourg, Moldova, North Macedonia, Northern Ireland, Poland, Romania, Scotland, Switzerland, and Ukraine. In some cases, such as in Albania, Belgium, Bosnia and Herzegovina, Luxembourg, and Moldova, limited resources constrained the NHRI’s capacities and affected their ability to fulfil all of their responsibilities. In Liechtenstein, the institution reported that, with the expansion of its mandates, it does not have sufficient resources to support its administrative and coordination functions. In Finland, the NHRI’s budget was reduced following broader public budget cuts, while in Estonia, the NHRI reported that Riigikogu (the Parliament) did not support the Chancellor’s request for a budget increase for 2026, which may affect the NHRI’s institutional capacity due to the rise in petitions. In Croatia, the NHRI highlighted the continued lack of permanent office premises since 2020. In Ukraine, the discrepancy between available resources and the scope of the institution’s mandate has been further exacerbated by Martial Law, attacks on infrastructure, the energy crisis and the growing complexity of digital complaints.

In addition, 10 ENNHRI members, namely those from Belgium (Unia), Czechia, Estonia, Great Britain, Liechtenstein, Luxembourg, Moldova, Montenegro, Northern Ireland, and Ukraine, also stressed the challenges related to the financial autonomy of the NHRI, including when it comes to budget determination processes. The NHRI’s financial autonomy in Luxembourg remains rather limited due to its administrative attachment to the Ministry of State, which hampers its liberty to carry out its activities and projects. Similar concerns were raised by the Moldovan NHRI, which reported that the institution’s budget remains integrated into the general government budget process without a distinct budget line fully reflecting its independent status. The NHRI in Montenegro noted that, although its budget is formally provided through the State budget, the lack of full financial independence limits its ability to plan and implement activities across multiple mandates. The Ukrainian NHRI reported a continued reduction in funding for the NPM mandate since the full-scale invasion, affecting the institution’s ability to conduct regular monitoring visits and engage necessary experts. In Liechtenstein, the member cited a lack of transparency regarding the budget decision-making process as the payment agreement with the government and the relevant authority is not legally binding.

ENNHRI’s 2026 Rule of Law Reporting also confirms challenges in adequate follow-up by state authorities to NHRI recommendations. These specific challenges were identified by 20 ENNHRI members, namely the ones in Albania, Belgium, Bosnia and Herzegovina, Georgia, Greece, Ireland, Kosovo*, Liechtenstein, Luxembourg, Malta, Moldova, the Netherlands, North Macedonia, Northern Ireland, Romania, Scotland, Serbia, Slovakia, Slovenia, and Sweden. For example, the Greek NHRI reported on the lack of follow-up and consideration of NHRI’s recommendations regarding the draft law on restricting CSOs’ action on migration and the possible criminalisation of humanitarian action. The Georgian NHRI provided detailed data showing that only a small proportion of recommendations to state authorities were fully implemented, while the Serbian NHRI distinguished between more frequent implementation of individual recommendations and weaker follow-up to systemic recommendations requiring broader institutional reforms. Similarly, the Slovenian NHRI identified more than 100 previously issued recommendations that remain unimplemented, most of which relate to the rights of various vulnerable groups. These challenges illustrate that persistent failure by state authorities to engage with and implement NHRI recommendations can significantly limit the practical impact of NHRIs' work.

Seven ENNHRI members also identified obstacles in systematic access to information and to national authorities, namely those in Czechia, Greece, Luxembourg, Moldova, Poland, Romania, and Scotland. These concerns mainly relate to the lack of granting access to classified information or documents upon NHRI request, as it was the case for the NHRI from Moldova which reported difficulties in accessing information from the Ministry of Defence. In some cases, these challenges were particularly related to the conduct of specific mandates of the NHRIs, such as in Luxembourg (monitoring public video surveillance systems) or Poland (mandate as the NPM). In the case of Greece, this relates to legislation preparation, for which the NHRI was not consulted in the early stages of the process. The Georgian NHRI highlighted selective obstruction by several public authorities, including law enforcement, penitentiary, judicial and municipal bodies, reporting particular obstacles to effective cooperation with law enforcement authorities during mass detention events.

Furthermore, seven NHRIs, namely those from Great Britain, Ireland, Lithuania, Luxembourg, Portugal, Slovenia, and Sweden, reported challenges in the selection and appointment of the decision-making body. For instance, in Portugal, the appointment of a new Head of Institution is pending since June 2025 and, in Slovenia, the member remained without an appointed Head of Institution for almost a year. Similarly, the NHRI from Great Britain reported that it remained without an appointed Commissioner for Wales for over a year. The NHRIs from Great Britain, Lithuania, Slovenia, and Sweden highlighted the importance of a more transparent, timely and open selection and appointment procedure for their decision-making body, in line with NHRI standards.

Lastly, some NHRIs reported challenges affecting their independence and effective functioning. For example, the Greek NHRI raised concerns about its designation as a voting member of the Special Committee on Fundamental Rights established under the Ministry of Migration and Asylum, noting that such participation within the executive branch may undermine its independence and compliance with the UN Paris Principles.

Threats and attacks against NHRIs

Several NHRIs reported facing threats and attacks in 2025, with some indicating experiences ranging from online and verbal attacks to, obstruction in carrying out mandates, and in one case, a physical incident targeting the Head of Institution.

Thirteen ENNHRI members, namely those from Armenia, Denmark, Estonia, Georgia, Germany, Great Britain, Ireland, Moldova, Montenegro, Northern Ireland, Slovakia, Switzerland, and Ukraine were subjected to online attacks or defamatory campaigns against the institution and its work. A concern was raised by the NHRI in Northern Ireland, which reported that content shared on social media featuring the Head of institution and its staff has generated strong and inappropriate responses. As a result, the decision was made to remove the ability for users to comment on Facebook posts due to the nature of the comments and the associated level of risk. Moreover, an advertising campaign aimed at raising awareness of the importance of protecting human rights following Brexit had to be withdrawn from Facebook due to hateful commentary.

The Swiss institution also cited a social media case involving YouTube trolling, however, the individual did not appear to be associated with any significant network or coordinated activity. The content was identified and removed promptly, and no further incidents of a similar nature have been observed. The NHRI from Ireland was subjected to a public commentary aimed at misrepresenting the status of the member by portraying it as a “state-funded NGO” and disseminating misleading claims regarding its funding. In Germany and Denmark, the NHRIs and their representatives were subjected to online attacks and hostile reactions following publications related to their institutional work. The Ukrainian NHRI also reported cybersecurity threats, including phishing attacks targeting staff credentials, and documented verbal attacks and threats against the institution, leadership and employees, particularly in digital spaces.

Twelve ENNHRI members also identified cases of increasing verbal attacks against the institution, in particular in Armenia, Belgium (Unia), Bosnia and Herzegovina, Croatia, Estonia, Georgia, Liechtenstein, Luxembourg, Montenegro, Slovakia, Slovenia, and Ukraine. In most of these cases, such attacks came from public actors. For example, the NHRI in Luxembourg reported verbal accusations from a far-right politician questioning its neutrality, ethical standards and representativeness, while the NHRI in Croatia reported demeaning statements made by both right-wing politicians as well as by the Prime Minister. The NHRI in Georgia reported disinformation campaigns and defamatory narratives, including statements by high-ranking public figures, aimed at undermining public trust in the Public Defender’s Office.

In Slovenia, the head of the NHRI faced public criticism portraying the institution as ineffective and an unnecessary public expense. Similarly, the NHRI in Bosnia and Herzegovina reported verbal attacks and narratives questioning the relevance of the institution linked to a general misunderstanding of NHRIs' attributed mandates and responsibilities, which exclude executive powers as foreseen under international standards. The NHRIs in Montenegro and Ukraine also reported threats and intimidation, including gender-based threats directed at leadership and staff.

Another cause for concern was reported by the NHRI from Austria, which indicated a physical attack against the head of the institution during public consultation days. The incident was reportedly carried out by an individual who felt unfairly treated by a judge in civil proceedings.

Some NHRIs, including those in Armenia, Great Britain, Montenegro, Poland, and Ukraine, reported cases of obstruction or harassment in carrying out the institution’s mandate. In Great Britain, this took the form of protests outside the building, sometimes leading to damage, while in Ukraine, the NHRI reported obstruction to fulfil its activities due to the authorities’ refusal to provide relevant information.

The NHRI from Great Britain reported the issue of gendered threats, attacks, or intimidation against the NHRI leadership or staff, while the NHRI from Northern Ireland reported that legal action had been initiated against it in relation to comments made by its Head about the human rights compliance of the Independent Commission for Reconciliation and Information Recovery’s process and procedures.

On a more positive note, ENNHRI members in Albania, Cyprus, Greece, Malta, North Macedonia, Norway, Portugal, Serbia, Spain, and Sweden did not report any specific threats directed against them during the reporting period.

Response to threats seeking to undermine the independence and effectiveness of the NHRI and measures to strengthen the NHRI resilience

In the context of structural challenges, threats, and attacks, NHRIs are developing and employing practices to respond, and also highlight the importance of actions taken by regional and international partners to support them in doing so. 

Fourteen ENNHRI members focus on emergency planning and preparedness policies or have developed specific action plans and internal policies to increase their resilience or their capacity to respond to threats. This is the case in Albania, Bosnia and Herzegovina, Cyprus, Finland, Georgia, Germany, Great Britain, Greece, Ireland, Lithuania, Montenegro, Northern Ireland, Sweden, and Ukraine. The Albanian NHRI reported the development and adoption of internal policies aimed at ensuring institutional integrity, transparency, and stable decision-making. The NHRI in Greece is developing an internal resilience strategy to systemise risk assessment procedures, clarify institutional response protocols, and strengthen internal coordination. It also created an internal task force to monitor emerging risks and propose preventive and corrective measures where necessary. 

Similarly, the NHRI in Lithuania strengthened cyber security, access controls, secure communications, incident response procedures, and installed protocols for managing harassment and threats. The Ukrainian NHRI reported systematic monitoring of risks, strengthened internal coordination, improved cyber and information security procedures, and rapid-response mechanisms for interference with online activities. The NHRI in Great Britain undertook a review of security procedures for its offices. Lastly, in Northern Ireland, the NHRI highlighted an internal policy on procedures for reporting incidents of verbal abuse, threatening behaviour or physical assault, pastoral support to any staff member or the Head who is the subject of abusive or threatening behaviours and guidance for imposing proportionate restrictions.

Many NHRIs also focus on building in-house capacities and increasing skills and expertise to strengthen their resilience and capacities. This is the case in Armenia, Azerbaijan, Croatia, Cyprus, Denmark, Finland, Germany, Great Britain, Greece, Lithuania, the Netherlands, Northern Ireland, Romania, and Sweden. For example, the NHRIs from Cyprus, Finland, Great Britain, Greece, Lithuania, the Netherlands, and Sweden specifically focused on capacity-building organising targeted in-house trainings of relevant staff and experts to build their capacities or identify early warning signs of institutional pressure. In addition, the NHRIs from Germany and the Netherlands provided support, and dedicated trainings to front-desk staff members respectively, to enhance their capacity to handle challenging interactions (e.g. phone calls). In Great Britain, the NHRI issued advice for staff on personal safety and welfare, including guidance on dealing with threats. The institution also has processes in place for dealing with vexatious complaints and abusive behaviour.

A further trend concerns the use of public communication, transparency and evidence-based follow-up as resilience tools. The Georgian NHRI publicly responded to disinformation campaigns and defamatory narratives, while the NHRI in Serbia relied on public reporting, reasoned recommendations and regular communication with the National Assembly and the public as safeguards against undue influence. The Georgian NHRI also introduced a more analytical follow-up approach, including quantified data on recommendation implementation and direct meetings with state authorities. This indicates a shift from reactive responses to more structured accountability and resilience-building practices.

Fourteen ENNHRI members also highlighted the importance of building strategic partnerships with domestic and international actors. For example, the members’ approach to strengthening their resilience in Albania, Armenia, Belgium (FIRM-IFDH, Combat Poverty), Bosnia and Herzegovina, Croatia, Cyprus, Finland, Germany, Greece, Liechtenstein, Serbia, Slovakia, and Ukraine builds on monitoring changes in their operating environment while engaging in cooperation with a broad network of national and international stakeholders. The Ukrainian NHRI highlighted cooperation with ENNHRI and other regional mechanisms to exchange information and mobilise support in response to threats.

The Albanian NHRI noted that ENNHRI and other partners can assist the institution through public statements, advocacy and institutional solidarity. The NHRIs in Bosnia and Herzegovina and Serbia also underlined the value of ENNHRI’s peer support, exchange of good practices and institutional backing as an additional layer of protection for NHRI independence and effectiveness. Some ENNHRI members also reported examples of positive awareness and recognition of their role, as well as efforts to maintain good relations with CSOs and the general public. This is the case, for example, in Belgium (Unia), Denmark, and Slovakia. This is of particular importance given the relationship of mutual support between NHRIs and CSOs, especially in the face of threats. 

Lastly, 10 NHRIs reported that they rely on safeguards provided by their regulatory framework, national legislation or Constitutions, including in some cases provisions granting functional immunity to staff and protection under criminal law. This is the case for the institutions of Armenia, Bosnia and Herzegovina, Cyprus, Georgia, Greece, Hungary, Liechtenstein, Northern Ireland, Portugal, and Serbia. In Georgia, the NHRI reported constitutional and legal safeguards, including criminal sanctions, for exerting pressure on the Public Defender. The Serbian NHRI highlighted statutory mechanisms enabling the Protector of Citizens to respond to threats, while the NHRI in Bosnia and Herzegovina noted that the institution benefits from a certain level of functional immunity in carrying out their duties, but considered these general safeguards insufficient and called for dedicated security and support mechanisms tailored to the institution. The ENNHRI member from Liechtenstein also noted that its founding law is the most important safeguard against threats.

As highlighted in ENNHRI’s new Strategic Plan 2026-2030, and confirmed by ENNHRI’s 2026 Rule of Law Reporting, there is a stronger need for building NHRI resilience, enabling them to respond effectively to threats, address emerging or unpredictable challenges, and maintain compliance with the UN Paris Principles.

In light of these developments, targeted action is needed at both national and regional level to safeguard the independence and effective functioning of NHRIs.

ENNHRI calls on national authorities to respect and strengthen the enabling environment for the establishment and functioning of strong and independent NHRIs in compliance with the UN Paris Principles, including by safeguarding their institutional independence and systematically supporting actions aimed at strengthening NHRI resilience. Furthermore, ENNHRI urges national authorities to ensure adequate funding for NHRIs, in particular when assigning them new mandates, which should be defined and attributed in consultation with NHRIs.

Governments should consistently match the attribution of new mandates to NHRIs with corresponding increases in budget and resources, in line with international standards on NHRIs. Funding should also be stable and predictable, as opposed to more precarious project-based approaches, in order to allow continuity and adequate planning. ENNHRI further invites national authorities to ensure that they consult with NHRIs prior to the attribution of new mandates. Responsibilities of NHRIs under such mandates should be clearly and systematically defined in their regulatory framework.

Additionally, ENNHRI highlights the importance of national authorities cooperation and follow-up on NHRIs’ recommendations, in line with the Council of Europe Recommendation CM/Rec(2021)1, which calls for a legal obligation to provide a timely and reasoned reply to NHRI recommendations. Authorities should follow-up on recommendations and input from NHRIs in a timely and justified manner while detailing and justifying follow-up actions or lack thereof. Lastly, ENNHRI calls on authorities to protect NHRIs from any form of intimidation, threats or attacks. They should in particular strengthen their support for NHRIs under threat, including by responding to and addressing cases of intimidation, harassment, and other threats seeking to undermine the independent and effective functioning of NHRIs.

ENNHRI calls on European and regional actors to continue providing institutional, technical and financial support to strengthen NHRI capacity, resilience and effectiveness. This includes support for institutional reforms, specialised monitoring functions, staff training and capacity-building, as well as peer-learning opportunities and exchanges of good practices. Particular support should be directed towards legislative reform processes aimed at bringing NHRI founding laws into full compliance with the UN Paris Principles and other regional standards, including through technical assistance provided in cooperation with ENNHRI. European and regional actors should also advocate for the implementation of NHRI recommendations, to ensure tangible impact on human rights protection.

ENNHRI further encourages European and regional actors to strengthen advocacy in support of NHRI independence and to respond promptly where NHRIs face threats, interference or obstacles in carrying out their mandates. This includes raising concerns regarding attacks against NHRIs and supporting efforts to strengthen legal and institutional safeguards for independent human rights oversight.

Civil society organisations (CSOs) and human rights defenders (HRDs) are key actors in the system of checks and balances in healthy democracies. They play an essential role in safeguarding the rule of law, human rights and democracy by serving as watchdogs, raising awareness about essential issues, while often representing diverse groups in vulnerable situations. As underlined in the EU Strategy for Civil Society and other wider-European standards such as the Council of Europe's Recommendation CM/Rec(2018)11 on the need to strengthen the protection and promotion of civil society space in Europe, their contribution is essential in fostering citizens’ engagement, democratic participation, and inclusive public discourse. Acting as unique independent public bodies with a broad human rights mandate, NHRIs also play a pivotal role in protecting, empowering, and supporting CSOs and HRDs. At the same time, NHRIs are human rights defenders themselves and often face risks similar to other HRDs.

Reporting by ENNHRI members reveals important gaps in the national protection of CSOs and HRDs across Europe, while also indicating that a deteriorating environment for CSOs and HRDs remains an issue. As highlighted in the 2023 Council Conclusions and in the above-mentioned Council of Europe Recommendation, unjustified restrictions on their operating space present a threat to the rule of law.

This year, ENNHRI’s Rule of Law Reporting confirms the need to further strengthen the protection and promotion of civil society space in Europe. ENNHRI members affirm that numerous structural challenges and threats encountered by CSOs and HRDs may reduce and ultimately discourage their participation in democratic discourse at the national level. Furthermore, as reflected in the NHRIs’ country reports, these circumstances also present considerable difficulties for CSOs and HRDs within the European context in terms of monitoring, reporting, and contributing to strengthening democratic societies. Hence, there is a need to systematically address these challenges at both national and regional level.

Only six NHRIs (Austria, Cyprus, Estonia, Norway, Portugal, and Spain) indicated that CSOs and HRDs operate within open environments and maintain strong cooperation with national authorities.

ENNHRI members from Czechia, Denmark, Liechtenstein, Lithuania, Luxembourg, Poland, Slovenia, and Switzerland rate the enabling environment as generally open; however, already pointing to warning signs of narrowing of the enabling environment for CSOs and HRDs, related for example, to access to financial resources or increasing political pressure and public stigmatisation of the CSOs and HRDs. For example, the ENNHRI member from Czechia highlighted that for CSOs working in the area of migration and foreigners’ rights, the enabling framework remains formally open, but CSOs and HRDs are highly dependent on short-term, project-based public funding. The ENNHRI member from Liechtenstein also reported the lack of resources (shrinking budgets and state funding) as a factor restricting civic space. The NHRI from Lithuania highlighted that, in the media sphere, concerns were raised about initiatives perceived as increasing political pressure on the public broadcaster, including audits and proposed legal changes. The ENNHRI member from Switzerland reported instances of criminalisation, restrictions during protests, and the increase of SLAPPs which could signal a narrowing civic space. The ENNHRI member from Iceland informed that CSOs’ recommendations were taken into account less than before.

Thirteen ENNHRI members confirmed the continuous trend of a further narrowing of the environment for the functioning of CSOs and HRDs. This was reported by the institutions from Albania, Belgium, Croatia, Finland, France, Germany, Greece, Kosovo*, the Netherlands, North Macedonia, Romania, Slovakia, and Sweden.

The ENNHRI members from Belgium, Greece, Romania, Slovakia, and Sweden reported that many CSOs and HRDs continue to be a target of harassment, threats and disinformation campaigns, while the NHRIs from France, Germany, Greece, and the Netherlands also reported on increasing pressure on CSOs and HRDs, including the increasing number of cases resorting to the use of criminal prosecution, preventive law enforcement measures, or increased surveillance by national authorities. The NHRI in Albania informed that the narrowing stems from a range of operational and political pressures, including concerns regarding media freedom, journalist safety, disinformation campaigns and politically motivated public attacks targeting civil society actors. The ENNHRI members in Kosovo* and North Macedonia, by contrast, pointed to the primary driver as the significant deterioration in international donor support, including the reduction or suspension of major funding streams such as USAID programmes, rather than direct state interference with civil society operations. Smaller organisations were particularly vulnerable to these shifts.

Three NHRIs (in Bosnia and Herzegovina, Georgia, and Northern Ireland) indicated that CSOs and HRDs operate in a restricted civic space. In particular, the NHRI from Georgia reported a challenging situation for HRDs, with multiple reports of explicit barriers to accessing funding for activities of HRDs in 2025. In Northern Ireland, the NHRI cited the existence of paramilitary groups exerting coercive control over some communities through intimidation, financial extortion, sexual exploitation, as well as a rising number of racist hate crimes and growing incidents of threats or attacks on journalists.

As highlighted by several NHRIs, some CSOs and HRDs were particularly targeted due to their areas of work, including on environmental protection, migration, minorities, the rights of LGBTI communities, or those expressing solidarity with Palestinians. Taken together, these developments contribute to a chilling effect on public participation and to fostering increased self-censorship among civil society actors and individuals.

At the same time, some ENNHRI members identified positive developments or resilience factors even in otherwise fragile or constrained contexts. In Kosovo*, the Forum for Dialogue with Civil Society, bringing together the NHRI and 27 CSOs, provides an institutional platform for engagement on action plans and funding gaps. In Ukraine, the NHRI noted that, despite the fourth year of full-scale war and heightened security, financial and institutional risks, civil society continued to demonstrate strong resilience, while national authorities maintained efforts to support CSO participation and civil society development.

Findings by ENNHRI members point to several structural challenges negatively impacting the work of CSOs and HRDs, including declining public funding, barriers in access to law and policy-making, excessive administrative burdens, and practices related to growing restrictions on the right to association and peaceful assembly.

Twenty-seven ENNHRI members (from Albania, Belgium (FIRM-IFDH, Unia), Bosnia and Herzegovina, Croatia, Finland, France, Georgia, Germany, Greece, Iceland, Ireland, Kosovo*, Liechtenstein, Lithuania, Luxembourg, Moldova, Montenegro, the Netherlands, North Macedonia, Northern Ireland, Poland, Romania, Scotland, Slovakia, Sweden, and Ukraine) reported on serious obstacles in access to funding, either due to the lack of adequate funding for CSOs and HRDs, or a significant reduction of public funding.

The ENNHRI members from Ireland, Czechia, and the Netherlands particularly pointed to the fact that the lack of adequate funding for CSOs concerns mainly those CSOs and HRDs working on the rights of groups in vulnerable situations, including women’s rights and gender equality, the rights of asylum seekers, and the rights of victims of crime. For example, a significant reduction in public funding in the Netherlands had major consequences for the work of the Dutch Council for Refugees (VluchtelingenWerk Nederland), significantly reducing its operational capacity. In Northern Ireland, the NHRI reported a “severe funding crisis that threatens the sustainability of frontline services” as CSOs came across a 64% cut to community-based support funding. The same NHRI reported that the government reduced grant funding for organisations supporting EU citizens and their families engaging with the EU Settlement Scheme (EUSS), which will especially affect Roma communities who are dependent of this scheme’s support. 

Moreover, in relation to the funding architecture, many NHRIs also underline that CSOs and HRDs face difficulties in securing stable and predictable funding and remain heavily dependent on project-based funding (Croatia, Germany, Greece, Lithuania, Sweden, and Poland), which weakens organisational sustainability, can disrupt activities’ continuity, and may have a negative effect on employee and knowledge retention. Besides barriers in access to public funding, some NHRIs also reported the challenge of encountering explicit barriers in access to funding from foreign sources. This was reported by the ENNHRI members in Albania, France, Georgia, Hungary, Kosovo*, Montenegro, North Macedonia, and Slovenia. The ENNHRI members from Albania and Kosovo* underscored that limited access to domestic public funding has left CSOs and HRDs disproportionately reliant on foreign donors, an aggravating factor that exposes the sector to instability when external funding is reduced or withdrawn.

As a result, CSOs are more vulnerable to shifts in foreign fundings, such as the cancellation of funding programmes by USAID, which is reported to have negatively impacted the ability of CSOs to operate in Albania, Georgia, and Moldova. In some countries, explicit barriers in securing foreign funding have accentuated this precarious situation. In Georgia, the newly introduced Foreign Agents Registration Act imposes special registration and reporting obligations on all persons considered “agents of a foreign principal”, with imprisonment as a result of non-compliance, which disproportionately affects many CSOs relying on foreign funding.

In terms of shortcomings in access to law and policy-making and meaningful public consultation for CSOs, these were reported by 21 ENNHRI members, namely those in Albania, Bosnia and Herzegovina, Croatia, Czechia, Estonia, Finland, France, Georgia, Greece, Ireland, Luxembourg, Moldova, North Macedonia, Northern Ireland, Poland, Romania, Scotland, Slovakia, Slovenia, Sweden, and Ukraine. These shortcomings are particularly related to short deadlines for public consultations, as identified, for example, by the NHRIs in Estonia, Finland, Georgia, Greece, North Macedonia, Northern Ireland, Slovenia, and Ukraine, or to a lack of participatory processes and meaningful public consultations as evidenced by the ENNHRI members in Croatia, Czechia, Finland, Georgia, Greece, Ireland, Lithuania, Luxembourg, North Macedonia, Poland, Romania, Slovakia, Sweden, and Ukraine.

For instance, the NHRI from Sweden reported that the engagement of CSOs can take the form of informative sessions rather than consultations, while the NHRI of Finland underlined that the decision-making processes have become less transparent and participatory, and often the input by many CSOs is not reflected in the outcome. The NHRI from North Macedonia observed that the continued use of shortened procedures for adopting legislation, often without meaningful public consultation, reduces opportunities for CSOs and HRDs to participate in policymaking processes. Additionally, in the case of Estonia, Finland, Greece, Luxembourg and Poland, the meaningful public consultation was also impacted by the lack of access to information.

In many cases, consultation procedures are deemed too formalistic, with little impact in practice as indicated by the NHRIs from Bosnia and Herzegovina, Moldova, and Northern Ireland. The NHRI from Moldova indicated that many instances of public consultation are carried out formally or superficially, without ensuring effective and substantial participation of civic society. In Northern Ireland, the NHRI reported that while public consultations are routinely conducted, they are so resource-intensive that outcomes can be significantly delayed and/or final strategies do not adequately reflect stakeholder views. In addition, in some instances, NHRIs reported a lack of meaningful CSOs consultation in specific areas of law-making. A lack of CSO and HRD involvement was particularly noted in policy making concerning national budget and fiscal processes (Albania), or information rights and security (Ukraine).

Furthermore, excessive administrative controls or audits were identified by ENNHRI members as posing a structural challenge for the CSOs and HRDs as reported by the institutions in Albania, Belgium, Bosnia and Herzegovina, France, Georgia, Greece, Ireland, Poland, Romania, and Slovakia. For instance, the NHRI from Poland pointed to excessive bureaucracy and formalities faced by CSOs, further complicated by novel developments such as digitalisation and cashless transactions, which may not be well understood by many categories such as persons with disabilities or older persons. In some cases, they can stem from lack of action, slowness, or lack of transparency of the administration as it was reported by the NHRIs in Bosnia and Herzegovina and in Albania, where delays in registration and status changes for CSOs and HRDs are reported as a result of a non-functioning Electronic Register of Non-Profit Organisations, creating additional problems because of the absence of an updated list of active organisations. 

The Greek NHRI highlighted the new regulatory framework, particularly concerning the CSOs working on migration, which includes mandatory registration obligations for organisations and their individual members and employees. Moreover, the NHRI in Slovakia also reported on the resolution passed by the Government mandating members of the Government to report information on the intention to conclude financial contracts with CSOs in advance. The Georgian NHRI also indicated that a number of CSOs have been subjected to inspections, orders requiring them to hand over sensitive data, and requests for detailed operational reports.

Similarly, 17 ENNHRI members raised concerns about the laws and policies adopted, which negatively impact the right to association or assembly or to protest (Belgium (FIRM-IFDH, Unia), Finland, France, Germany, Great Britain, Greece, Ireland, Moldova, the Netherlands, Northern Ireland, Romania, Slovakia, Slovenia, Switzerland, Türkiye, and Ukraine). For example, in Belgium and Germany, measures were taken in relation to protesters expressing solidarity with Palestine, impacting the right to freedom of expression and peaceful assembly. The ENNHRI members from Belgium (FIRM-IFDH), Georgia, and Switzerland also highlighted that strict authorisation procedures and the application of municipal administrative sanctions still contribute to the weakening of the freedom of assembly.

In Georgia, amendments to the Assembly Law introduced restrictions on face coverings during demonstrations, and stricter advance notice requirements for demonstrations with criminal liability for repeated violations and sanctions ranging from steep fines to detention. In Türkiye, the impact has been made worse by the policing of peacefully organised meetings, which was not always in line with ECtHR standards. In Switzerland, the ENNHRI member reported that, in cases where demonstrations take place without authorisation or where violence occurs, cantonal prosecution authorities often initiate criminal proceedings against participants.

Furthermore, the NHRI from Croatia reported on the lack of clarity of specific provisions of the legislation regulating the right to freedom of assembly as regards their interpretation and practice, which can have a potentially disrupting effect on organising protests. The ENNHRI member in Switzerland highlighted that legislation in several cantons allows the security and policing costs associated with demonstrations to be charged to the organisers. Lastly, in Great Britain, the NHRI referred to legislation widening the ability to place restrictions on ‘public processions and assemblies’, ‘wilful obstruction of highways’ and ‘one person protests’ in England and Wales, and expanded stop and search powers during protests, and introduced new ‘locking on’ offences, which ultimately can interfere with the right to protest.

The NHRI in Armenia noted a positive development regarding the abolition of the absolute prohibition preventing members of the Armed Forces of the Republic of Armenia, the Police, the National Security Service, the Prosecutor’s Office, as well as judges, from participating in trade union organisations. However, the member informed that a number of systemic issues remain unresolved, such as the legal and administrative setting for the establishment and maintenance of trade unions continuing to be unjustifiably burdensome and inconsistent with international standards.

Finally, wartime conditions flowing from Russia’s war of aggression against Ukraine have posed significant structural challenges affecting CSOs and HRDs in Ukraine since 2022. Among these, restrictions of constitutional freedoms, including freedom of association, pursuant to Martial Law, and heightened risks associated with operation in frontline regions are reported.

ENNHRI’s Rule of Law Reporting also confirms that CSOs and HRDs in Europe continue in many cases to operate under serious threats, with a rising number of verbal or physical attacks, a growing trend of negative attitudes, stigmatisation, hostile public rhetoric directed at CSOs and HRDs, increasing cases of intimidation and harassment, surveillance by state actors, cases of transnational repression, criminalisation of the work of HRDs or increasing use of judicial harassment through SLAPPs. Some groups, such as women HRDs, LGBTI defenders, environmental defenders, or those supporting migrants and asylum seekers remain at higher risk.

Twenty-two ENNHRI members raised concerns over the growing negative trend of verbal attacks directed against CSOs and HRDs due to their work. Such instances were identified by the institutions in Albania, Armenia, Belgium (FIRM-IFDH), Bosnia and Herzegovina, Croatia, Denmark, Estonia, Georgia, Germany, Greece, Lithuania, Luxembourg, Moldova, Montenegro, the Netherlands, Northern Ireland, Romania, Scotland, Slovakia, Slovenia, Sweden, and Ukraine. In Albania, public accusations questioning the legitimacy, transparency, and purpose of CSO funding, portraying organisations as acting against the public interest and promoting foreign agendas were disseminated by non-state actors including conservative groups, online portals, and anonymous social media accounts. In some cases, these attacks particularly concern CSOs and HRDs working on the rights of groups in situations of vulnerability or working on politically sensitive contexts. For instance, the NHRIs from Belgium, Germany, and Sweden noted the increase in assaults and violence, especially targeting women, members of the LGBTI community, faith communities, and other minority groups.

Aside from verbal attacks, six NHRIs also reported physical attacks directed against CSOs and HRDs due to their work (Belgium (FIRM-IFDH), Croatia, Georgia, Germany, Scotland, and Sweden). It was reported that most of these physical attacks concern HRDs exercising journalism. The Croatian NHRI reported that a number of death threats and other physical assaults against journalists have been recorded. Similarly, the NHRI from Georgia indicated that journalists were targets of physical assaults and had equipment confiscated. The NHRI in Northern Ireland cited over 70 incidents of threats or attacks on journalists and that there have been no prosecutions related to such threats caused by paramilitary groups, although these make up the majority of such threats. Women, LGBTI communities, and faith communities were identified as being subjected to increased risk of such attacks.

Eighteen ENNHRI members across Europe also reported a trend of growing negative narratives, pressure, and stigmatisation of CSOs and HRDs by state authorities and the wider public (Albania, Belgium (FIRM-IFDH), Bosnia and Herzegovina, Czechia, Denmark, Georgia, Germany, Greece, Luxembourg, Moldova, Montenegro, the Netherlands, Romania, Scotland, Slovakia, Sweden, Switzerland, and Ukraine). In Georgia, the NHRI identified several threats affecting CSOs and HRDs, including verbal attacks and the promotion of negative narratives by public authorities. In this context, the Public Defender’s Office reported that it actively monitors challenges that undermine the creation of an enabling environment for HRDs' activities and the full enjoyment of their freedom of association.   

In Romania, political and reputational pressure, as well as public and media narratives stigmatising CSOs and HRDs as foreign-influenced or politically biased, were highlighted. In Switzerland, public discourse and media reporting often portray demonstrations as potentially threatening, with a strong focus on incidents of violence during protests. Yet again, CSOs and HRDs working on topics including the rights of women and LGBTI persons (in Belgium, Czechia, Denmark, the Netherlands, and Slovakia), faith communities (in Sweden), or on the topic of asylum and migration (in Greece, and the Netherlands) were particularly targeted.

Seventeen ENNHRI members reported that CSOs and HRDs are increasingly the targets of online threats or harassment. These concerned Albania, Belgium (FIRM – IFDH), Croatia, Denmark, Finland, Germany, Lithuania, Luxembourg, Montenegro, Moldova, the Netherlands, Romania, Scotland, Slovakia, Slovenia, Sweden and Ukraine. For instance, the NHRI from Germany identified an increase in social media posts negatively portraying CSOs, while the NHRIs in Finland and Luxembourg highlighted that online hate speech and harassment continue to be a problem targeting especially ethnic minorities, women HRDs, LGBTI HRDs, as well as journalists. The NHRI in Albania cited online abuse – often gender-based – as the main form of pressure towards HRDs. In Ukraine, a movie festival planning to screen LGBTI movies was targeted through Instagram posts which publicly called for the obstruction of the festival.

Ten ENNHRI members also identified cases of intimidation, harassment or violence before, during or after protests (Belgium (FIRM-IFDH), Estonia, Germany, Great Britain, Lithuania, the Netherlands, Poland, Romania, Scotland, and Slovenia), where often certain groups were specifically targeted, such as environmental defenders. In Great Britain, the NHRI raised concerns that proposed measures to strengthen police powers in relation to protests could result in disproportionate policing and negatively affect the freedom to peaceful assembly.

Some NHRIs also explicitly mentioned a worrying trend of increasing attempts to criminalise the work of HRDs (Greece, France, Poland, and Switzerland) or the use of preventive law enforcement measures (France, and Germany) to increase pressure on the CSOs and HRDs. For example, the Greek NHRI reported on the legislative developments concerning the draft law targeting CSOs working on migration that opens the way to the criminalisation of humanitarian action by introducing felony-level criminal sanctions where affiliation with a registered NGO may be treated as an aggravating circumstance in relation to allegation of smuggling/facilitation-related offences, without any substantive justification. At the same time, the draft law would allow for the removal of organisations from the official registry upon the mere initiation of criminal proceedings against one of their members, even in the absence of any judicial assessment or conviction. The ENNHRI member from Switzerland reported that individuals participating in demonstrations that did not receive such authorisation are subject to criminal prosecution.

Several ENNHRI members also evidenced that CSOs and HRDs were targeted with strategic lawsuits against public participation (SLAPPs). These examples were identified mainly in Belgium (FIRM-IFDH), Bosnia and Herzegovina, Croatia, Germany, Greece, Poland, Romania, Slovakia, Slovenia, Spain, and Switzerland. The Greek NHRI also reported on the wide use of “eco-SLAPPs” as a way of deterring the work of environmental defenders. In Bosnia and Herzegovina, the NHRI has been engaged in ex officio monitoring of the case of two environmental activists targeted by SLAPPs.

Some ENNHRI members reported pressure and/or surveillance by state actors, including in Belgium (FIRM-IFDH), Bosnia and Herzegovina, Finland, Georgia, Great Britain, and Northern Ireland. In Finland, the NHRI reported an instance of telephone surveillance of four environmental HRDs by members of the police, while the NHRI from Northern Ireland reported on unlawfully obtained journalists’ data by the UK intelligence services MI5. The Georgian NHRI also reported that the Anti-Corruption Bureau issued broad and intrusive requests for information from CSOs, but these requests were based on critical information and statements disseminated in the public space, raising concerns about retaliation, interference and intimidation. The NHRI from Bosnia and Herzegovina also identified surveillance by state actors as a documented threat affecting CSOs and HRDs. 

Lastly, the Belgian NHRI (FIRM-IFDH) and the German NHRI reported on transnational repression of human rights defenders. The Belgian NHRI identified an example of a situation of physical aggression committed by representatives of a non-European state during a demonstration in Belgium to denounce violations committed by the leaders of that state. The NHRI from Germany highlighted that cases of transnational repression often go unrecognised or are not systematically recorded, whereas (administrative) responsibilities and safe points of contact are unclear to those affected, and existing legal instruments have only a limited effect.

ENNHRI’s 2026 Rule of Law Reporting reaffirms the persisting deficiencies in establishing mechanisms to protect and support HRDs and CSOs at the national level across Europe. Only a very limited number of examples of existing measures to protect HRDs and CSOs at the national level were identified by a few ENNHRI members. 

The existence of specific laws protecting the rights of the HRDs was identified only in two NHRIs, in Poland and in Great Britain, while eight ENNHRI members, namely Albania, Bosnia and Herzegovina, Finland, Georgia, Great Britain, Kosovo*, the Netherlands, and Ukraine, confirmed the existence of specific practical protection mechanisms for CSOs and HRDs, such as emergency response systems, safe houses, legal aid or anti-SLAPP protection mechanisms.

Most of these protection mechanisms aim at providing relocation support for foreign HRDs. For instance, the NHRI in Finland reported that the country hosted the first two foreign HRDs as part of the pilot programme for the temporary protection and support for human rights defenders, funded by the Ministry of Foreign Affairs and coordinated by Artists at Risk. The aim of the programme is to provide temporary relocation for foreign HRDs in need of rest and respite and to provide an opportunity for HRDs to continue their work for the promotion of human rights, to network, to access training opportunities, and to rest. Similarly, the Dutch NHRI also highlighted that the Dutch government cooperates with other states to support HRDs, while also supporting the Shelter City project, that provides HRDs who are seriously threatened, with the opportunity to reside in the Netherlands for three months. 

A noteworthy advancement in this regard took place in Kosovo*, which became the first in Europe to ensure that SLAPPs be treated as priority cases by the courts through its new SLAPPs protection mechanism. It also includes priority handling of defamation cases and criminal cases linked to CSOs, journalists, and media professionals. The relevant SLAPP protection mechanism is also being developed in Ukraine by an interagency working group chaired by a parliamentary committee.

A few more ENNHRI members (namely from Estonia, Finland, Germany, Great Britain, Lithuania, Portugal, Romania, Slovakia, and Ukraine) confirmed that their respective states have established specific national strategies, other guidelines or action plans to protect HRDs and/or to ensure their inclusion in human rights action plans. Positive examples were identified by the NHRI from Lithuania, where the Government implements a specific action plan on the protection, safety, and empowerment of journalists, as a key category of HRDs, and where secondary state-guaranteed legal aid can be provided to whistleblowers regardless of income thresholds. The NHRI in Great Britain informed that the UK government published a policy paper setting out Guiding Principles on supporting human rights defenders, although this is in relation to support for international HRDs. Also, the NHRI in Ukraine informed about a specific national strategy to protect HRDs adopted for the period 2021-2026, which prioritises the creation of a favourable legal environment for the activities of civil society organisations and ensures their participation in public decision-making processes.

Despite these positive examples, the information provided by most ENNHRI members confirms significant gaps in the protection of HRDs at national level. Eighteen ENNHRI members (in Albania, Belgium (FIRM-IFDH), Bosnia and Herzegovina, Croatia, Georgia, Germany, Greece, Kosovo*, Lithuania, Luxembourg, Moldova, the Netherlands, Northern Ireland, Romania, Slovakia, Sweden, Switzerland, and Ukraine) identified the absence of a dedicated legal framework or policies providing for the protection of HRDs as well as the absence of support structures for HRDs as the most significant gap in the protection system. The absence of such structured institutional protection mechanisms means that support often remains ad hoc and informal, limiting its effectiveness and consistency.

In most cases, protection of CSOs and HRDs rests on constitutional guarantees, general legal provisions or sectoral legislation, as reported by the institutions in Albania, Bosnia and Herzegovina, Cyprus, Hungary, Kosovo*, Luxembourg, Northern Ireland, Norway, Portugal, Scotland, and Switzerland. In Switzerland, the ENNHRI member reported that the absence of a dedicated framework may limit the visibility of risks faced by HRDs and the availability of targeted support or protection measures. In other cases, broader legislative gaps further weaken the protection environment. In Northern Ireland, there is a reported lack of hate crime legislation. 

A few NHRIs (namely, those from Belgium (FIRM-IFDH), Germany, Northern Ireland, and Slovakia) also identified a lack of sufficient funding or predictable financing opportunities as further deepening the deficiencies in the protection of HRDs nationally. In Northern Ireland, the NHRI reported a need to take all appropriate measures to sustain resources in third sector organisations and safeguard the effective provision of support and advice on social security, employment, and housing to those who require it most. Furthermore, a number of NHRIs (namely those in Croatia, Luxembourg, the Netherlands, and Slovenia) reported that the lack of public awareness regarding the role and work of HRDs and CSOs, as well as regarding the pressure under which they operate, is an additional reason for the lack of further support. 

The findings from ENNHRI’s 2026 Rule of Law Reporting confirm significant gaps in dedicated protection for human rights defenders in Europe. ENNHRI continues to advocate for the establishment of interconnected national and regional mechanisms for the protection of HRDs in Europe, including through strengthening the role of NHRIs to protect HRDs at the national level.

As previously highlighted, on the basis of their broad human rights mandate and pluralist engagement with various entities, NHRIs are key national actors to protect, support, and empower CSOs and HRDs. They do so by working closely with CSOs, including through: capacity building and awareness raising; monitoring and reporting on threats, attacks, and harassment of CSOs and HRDs; and advocating for the adoption and strengthening of the national legislative measures to support civil society space and human rights defenders. By their very mandate, NHRIs act as bridge builders between CSOs and national authorities, while remaining independent of them. In the face of increasing challenges faced by CSOs and HRDs nationally, ENNHRI’s 2026 Rule of Law Reporting reaffirms that NHRIs from across Europe undertake a variety of activities and participate in initiatives to support civil society space and HRDs.

NHRI initiatives in 2025 to promote civil society space and human rights defenders

Twenty-seven ENNHRI members have promoted civil society space and human rights defenders through carrying out promotion and communication campaigns aimed at increasing the understanding and respect for the role of CSOs and HRDs nationally. This is the case in particular in Albania, Armenia, Belgium (FIRM-IFDH), Bosnia and Herzegovina, Croatia, Cyprus, Denmark, Finland, France, Georgia, Great Britain, Germany, Greece, Hungary, Kosovo*, Latvia, Liechtenstein, Luxembourg, Moldova, the Netherlands, Portugal, Romania, Scotland, Slovakia, Sweden, Türkiye, and Ukraine.

Similarly, a significant majority of ENNHRI members also organised joint meetings and roundtables to engage with CSOs and HRDs nationally and facilitate dialogue, exchange of information, and strengthen collaboration. These initiatives covering a wide range of topics were reported, in particular, by the ENNHRI members in Albania, Armenia, Austria, Azerbaijan, Belgium, Bosnia and Herzegovina, Croatia, Cyprus, Czechia, Denmark, Estonia, France, Georgia, Great Britain, Greece, Hungary, Iceland, Ireland, Kosovo*, Latvia, Liechtenstein, Lithuania, Luxembourg, Moldova, Montenegro, the Netherlands, Norway, Poland, Romania, Scotland, Serbia, Slovakia, Slovenia, Sweden, Türkiye and Ukraine.

Twenty-four ENNHRI members (in Albania, Armenia, Azerbaijan, Belgium (Unia), Czechia, Estonia, Finland, France, Germany, Great Britain, Hungary, Iceland, Ireland, Kosovo*, Montenegro, Poland, Portugal, Romania, Scotland, Slovakia, Slovenia, Sweden, Türkiye, and Ukraine) also specifically focused on carrying out capacity-building activities to strengthen CSOs and HRDs and their activities in the protection of human rights. For example, the NHRI from Ireland developed specific guidance for CSOs on how to engage with the Committee on the Elimination of All Forms of Discrimination against Women (CEDAW), while the NHRI from Finland developed a specific rule of law training for journalists to strengthen their knowledge and understanding of different aspects of the rule of law, including its link to human rights protection. 

In some cases, the initiatives to promote civil society space took different forms. In Great Britain, the NHRI provides financial assistance (up to a maximum of once per treaty monitoring cycle) by supporting organisations to produce joint shadow reports on behalf of wider civil society, or to travel to participate in UN oral evidence sessions. This seeks to increase the diversity of representation in UN review processes. For example, the NHRI provided funding to enable a diverse range of CSOs and individuals in the UN's examination of the UK’s compliance with the International Covenant on Economic, Social and Cultural Rights (ICESCR). In Northern Ireland, the NHRI operates a human rights information clinic accessible to the public, giving advice and recommendations. 

In addition, several NHRIs undertook advocacy and advisory activities to promote an enabling environment for civil society participation and the protection of human rights defenders. For example, the NHRIs in Albania, Moldova, North Macedonia, and Serbia advocated for stronger consultation frameworks, greater involvement of civil society in decision-making processes, improved access to public funding, and enhanced protection mechanisms for HRDs and vulnerable groups. Such engagement reflects the role of NHRIs as independent bridge-builders between civil society and public authorities.

NHRI actions in 2025 to protect civil society space and human rights defenders

Along with activities aimed at promoting the civil society space and HRDs, a large number of ENNHRI members also engaged in actions or initiatives specifically focusing on protecting the civil society space and HRDs. Twenty-two ENNHRI members carried out monitoring and reporting on the situation of CSOs and HRDs, as reported by those in Albania, Belgium, Bosnia and Herzegovina, Croatia, Cyprus, Denmark, France, Georgia, Greece, Hungary, Ireland, Latvia, Liechtenstein, Luxembourg, the Netherlands, Northern Ireland, Scotland, Serbia, Slovakia, Sweden, Türkiye, and Ukraine. For example, the NHRI in Greece has established two monitoring mechanisms to gather evidence-based data on risks and violations affecting CSOs in the areas of migration and forced returns, and of racist violence respectively. Through these structured institutional channels, civil society concerns are transmitted to national and international actors by reducing the CSOs’ vulnerability and strengthening their reliability.

Furthermore, many of these NHRIs issue annual or dedicated thematic reports, and engage with relevant international and regional monitoring mechanisms regarding the situation of civic space. For instance, the 2025 edition of the ‘Annual Report on Human Rights in the Netherlands’ of the Dutch NHRI delved into the state of civic space in the country. The research was carried out using a monitoring methodology developed by a Belgian NHRI (FIRM-IFDH). In Albania, the NHRI’s monitoring focused on online threats, journalist safety and the impact of restrictions on women and LGBTI defenders. The Georgian NHRI has established internal guidance on work concerning HRDs and combines media monitoring, social media monitoring and detention monitoring. During 2025, the NHRI visited 131 detained individuals in the context of protests and documented allegations of ill-treatment and physical injuries.

At the same time, a substantial majority of ENNHRI members also issue recommendations and/or opinions to national authorities and/or advise on (draft) laws impacting civic space and HRDs. These include ENNHRI members in Albania, Armenia, Azerbaijan, Belgium, Bosnia and Herzegovina, Cyprus, Denmark, Estonia, France, Georgia, Germany, Great Britain, Greece, Ireland, Latvia, Lithuania, Luxembourg, Moldova, Montenegro, the Netherlands, North Macedonia, Northern Ireland, Poland, Romania, Serbia, Scotland, Slovakia, Slovenia, Spain, Sweden, Türkiye, and Ukraine. For example, the NHRI from Luxembourg issued an opinion on a draft bill widening the possibility to issue removal orders of individuals considered by the authorities as causing a disturbance, alerting to the implications of such a bill on freedom of assembly.

The NHRI from Greece intervened in written form when legislative or policy developments threatened civic freedoms or risked criminalising human rights and humanitarian work. The Albanian NHRI issued recommendations concerning civil society access to public funding, participation in decision-making processes, and consultation standards. The Ukrainian NHRI provided recommendations regarding access to information and the protection of journalistic activities during Martial Law, while the Georgian NHRI continued to raise concerns regarding legislative developments and judicial practices affecting civic freedoms and human rights defenders.

Several ENNHRI members also have competence to address complaints submitted by individuals, and they do so also in matters signalled or faced by CSOs and HRDs. These include the institutions from Albania, Armenia, Austria, Azerbaijan, Belgium (Unia), Bosnia and Herzegovina, Cyprus, Estonia, Georgia, Hungary, Latvia, Lithuania, Moldova, Montenegro, North Macedonia, Northern Ireland, Poland, Romania, Slovenia, Spain, Türkiye, and Ukraine. Some NHRIs, including those from Azerbaijan, Belgium (Unia), Denmark, Hungary, Latvia, Liechtenstein, North Macedonia, Northern Ireland, Poland, Spain, and Türkiye also provided legal assistance or advice. For example, the Danish NHRI intervened before courts and provided support to lawyers in a number of human rights cases, including the case concerning the legislation referred to as the “ghetto legislation.” The case was referred to the Court of Justice of the European Union, which delivered its judgment in December 2025. 

The NHRI in Northern Ireland runs a human rights information clinic, where CSOs and HRDs can have recourse to information on complaints handling. In addition, it has powers to take strategic litigation and to undertake human rights-related investigations of its own motion. The same NHRI submitted evidence to the House of Lords inquiry on Strengthening Northern Ireland’s Voice in the Context of the Windsor Framework. In Georgia, the NHRI submitted a series of amicus curiae opinions in cases involving journalists, protesters and human rights defenders, contributing to acquittals in several cases and raising concerns regarding pretrial detention, privacy rights and freedom of assembly. In North Macedonia, the NHRI identified complaint handling and legal assistance as the institution’s core protection activities.

Several ENNHRI members also provided dedicated support to CSOs and HRDs through carrying out their specific mandates. These include Belgium (FIRM – IFDH), Bosnia and Herzegovina, Cyprus, Estonia, Georgia, Great Britain, Latvia, Moldova, Montenegro, the Netherlands, Poland, Romania, Serbia, Slovenia, Spain, and Ukraine. For example, the NHRIs from Bosnia and Herzegovina, Cyprus, Estonia, Georgia, Latvia, Serbia, Slovenia, and Spain used their NPM mandate, while the Estonian NHRI used its mandates as a monitoring body under the UN Convention on the Rights of Persons with Disabilities (CRPD) and as an ombudsman for children under the UN Convention on the Rights of the Child (CRC).

Furthermore, the NHRI from Belgium (FIRM – IFDH) is mandated to provide support measures to whistleblowers, while the NHRI in Poland conducts preliminary verification of reports and provides whistleblowers with information and advice. The British NHRI also provides support to workers who are concerned that their employer is committing breaches of equality and human rights law and who can report their concerns to the NHRI in its capacity as a whistleblower protection mechanism. In Bosnia and Herzegovina and in Serbia, specialised NHRIs’ mandates facilitate structured engagement with civil society organisations as part of monitoring and protection activities. 

Furthermore, in terms of institutional HRD protection mechanisms, the NHRI from Estonia reported providing focal points towards whom defenders of human rights, rights of the child, or rights of people with disabilities can turn. In Georgia, the NHRI has developed a dedicated institutional framework on human rights defenders and has included a dedicated chapter on HRDs in its annual reports since 2019.

ENNHRI’s reporting also highlights growing attention to the protection of women human rights defenders and defenders of LGBTI rights. The Albanian NHRI integrated gender considerations throughout its monitoring, advocacy and protection activities, including through work on gender equality legislation and monitoring of the impact of restrictions on women and LGBTI defenders. In Georgia, the NHRI undertook targeted interventions in cases involving women human rights defenders and journalists, including through amicus curiae submissions and dedicated monitoring of detention conditions.

The findings demonstrate that NHRIs are increasingly using their independent mandates to monitor civic space, respond to violations affecting HRDs, provide legal and institutional protection, and advocate for stronger safeguards for civil society and human rights defenders.

In light of the challenges identified, targeted measures are needed to further protect and enable the work of HRDs and CSOs both at national and regional level.

ENNHRI calls on national authorities to ensure a safe and enabling environment for civil society and human rights defenders, including by preventing and addressing intimidation, harassment, smear campaigns, SLAPPs, attacks and threats, whether physical, verbal or online. National authorities should also establish or strengthen effective protection mechanisms for HRDs (including NHRIs’ role in this), ensure prompt investigations into threats and attacks, and guarantee accountability for violations.

ENNHRI calls on national authorities to ensure access of CSOs and HRDs to predictable, stable, and secure sources of funding, including foreign funding.

Furthermore, ENNHRI urges authorities to guarantee freedom of assembly and association, by preventing and addressing undue restrictions, including with particular attention for those HRDs focusing on specific topics, such as women’s rights, LGBTI rights, migrants, and environmental defenders.

ENNHRI calls on European and regional actors to ensure systematic monitoring of civic space and the situation of HRDs, and respond promptly where developments undermine human rights, democracy or the rule of law. In this regard, ENNHRI invites the European and regional actors to support the central role of NHRIs in contributing to the protection, engagement and support of civil society and HRDs at national level.

Furthermore, European and regional actors should focus on supporting the establishment of dedicated protection mechanisms for CSOs and HRDs. For example, dedicated Europe-scale HRD protection mechanisms could help identify early warning signs, map risks as well as register attacks and ensure timely responses to these.

From a broad European regional perspective, safeguarding democracy and enhancing democratic resilience involve protecting democratic institutions, preserving the rule of law, defending human rights, and ensuring that societies can withstand and adapt to emerging political, economic, technological, and security challenges. In Europe, democratic resilience is increasingly viewed as essential for maintaining stability, social cohesion, and security.

In these challenging times, ENNHRI welcomes and is committed to supporting the initiative of the European Commission to introduce a strategic framework to better protect and promote democracy in Europe through the European Democracy Shield. Furthermore, ENNHRI has been actively supporting and is keen to further contribute to the implementation of the New Democratic Pact for Europe, a comprehensive Council of Europe initiative to rebuild institutional trust, safeguard elections, and counter democratic backsliding. Initiatives such as this underline the importance of coordinated action to address emerging threats to democratic integrity.

At the same time, ENNHRI underscores the essential role of NHRIs in strengthening democratic governance and fostering resilient democracies. As independent state bodies established in line with the UN Paris Principles, NHRIs help ensure that democratic systems remain firmly rooted in the protection of human rights and the rule of law. Through their pluralistic structures, engagement with a broad range of civil society actors, and accessibility to the public, NHRIs are uniquely placed to promote inclusive democratic participation and support decision-making processes that reflect diverse perspectives and leave no one behind.

NHRIs also contribute to democratic resilience by monitoring and advising on legislative and policy developments, promoting transparency and information integrity, and facilitating constructive dialogue between public authorities and citizens. Furthermore, their work strengthens the wider democratic ecosystem through support for independent and pluralistic media and by helping to safeguard an enabling environment for civil society.

Against this background, ENNHRI’s 2026 Rule of Law Reporting examines key challenges affecting democratic resilience across Europe. This year’s report specifically aimed to gather inputs on disinformation and law- and policy-making processes. This thematic focus reflects growing concerns that both the information integrity and the quality of legislative processes are critical determinants of the health of democratic systems in Europe.

Emerging technologies, including artificial intelligence (AI) and digital communication platforms, offer significant benefits and are increasingly used for public participation, public governance and communication purposes. At the same time, their rapid development and deployment have fundamentally transformed the information ecosystem, creating new vulnerabilities that can be exploited at scale. While these technologies can enhance access to information and public engagement, their misuse can also pose serious risks to the rule of law, democracy, and human rights, notably through the amplification and targeting of disinformation.

Disinformation presents a growing threat to democratic governance in Europe. The scale, speed and sophistication with which false or misleading information can be produced and disseminated have increased significantly. These dynamics facilitate the widespread circulation of manipulated or deceptive content, often designed to exploit societal divisions and target vulnerable groups. In addition, coordinated disinformation campaigns, whether domestic or foreign, seek to distort public debate, influence democratic processes, and erode trust in institutions. Disinformation contributes to increased polarisation, weakening the conditions for informed and inclusive democratic participation.

Human rights implications of the spread of disinformation

Throughout ENNHRI’s 2026 Rule of Law Reporting, a significant number of NHRIs raised concerns over the spread of disinformation, including instances involving state actors or public authorities, and confirmed its increasingly far-reaching human rights implications. These include adverse impacts on the freedom of thought, and the right to hold opinions without interference, freedom of expression, and access to reliable information, as well as the right to privacy and the right to participate in public life. NHRIs also expressed concerns on the chilling effects of disinformation on public discourse, civic engagement, and trust in democratic institutions.

The key concern was raised in relation to the negative impact of the spread of disinformation on the public trust in democratic institutions. Twenty-one ENNHRI members reported a decline in trust in democratic institutions, namely those from Belgium (FIRM-IFDH), Bosnia and Herzegovina, Cyprus, France, Germany, Great Britain, Greece, Hungary, Iceland, Ireland, Kosovo*, Lithuania, Luxembourg, Montenegro, the Netherlands, Poland, Romania, Scotland, Slovakia, Spain, and Ukraine.

This trend reflects broader concerns that disinformation not only distorts public debate but also weakens institutional legitimacy and accountability. For instance, the NHRI from Germany reported that media disinformation and defamation negatively affected the process of electing judges to the Federal Constitutional Court, noting that a professor withdrew candidacy following an unprecedented defamation campaign against her. Similarly, the Albanian NHRI reported that disinformation and online hostility affected the participation of women candidates during the 2025 parliamentary elections, including through misogynistic attacks, stereotypical narratives, and digital violence. The ENNHRI member in Kosovo* reported electoral disinformation attempts during the electoral period, including campaigns linked to foreign information influence, while the Ukrainian NHRI highlighted the role of disinformation in undermining trust in democratic institutions and promoting narratives aimed at weakening societal resilience during wartime.

The NHRI from the Netherlands shared findings from its research suggesting that AI-generated and propagated disinformation erodes trust in democratic institutions by undermining citizens’ ability to access and assess accurate and reliable information about current events. In addition, the NHRI from Greece reported that sustained negative rhetoric and misleading narratives have weakened public confidence in institutional accountability mechanisms, further undermining the perceived effectiveness of democratic oversight structures. Furthermore, the NHRI from Great Britain reported that it issued a statement after the release of a Supreme Court's ruling in an effort to avoid misinformation and misrepresentation of the judgment and its consequences, which could potentially negatively impact trust in democratic institutions.

Based on their human rights monitoring and reporting, 12 ENNHRI members (from Belgium (FIRM-IFDH), Bosnia and Herzegovina, Estonia, France, Liechtenstein, Lithuania, Montenegro, the Netherlands, Romania, Slovakia, Slovenia and Türkiye) identified a significant and growing impact of disinformation on the right to freedom of thought and the right to hold opinions without interference, underlining concerns that the integrity of individual opinion-forming processes is increasingly being undermined by manipulated and misleading information environments. In particular, NHRIs pointed to the ways in which disinformation, especially when amplified through digital technologies, can distort individuals’ ability to form opinions freely and independently.

The NHRI from the Netherlands highlighted that the conclusions of their above-mentioned research demonstrate the negative impact of AI on the right to hold opinions without interference, notably through its use in generating and disseminating disinformation. The NHRIs in Bosnia and Herzegovina, Montenegro, and Türkiye identified growing concerns regarding the impact of disinformation and hate speech on individuals' ability to form opinions freely and participate in informed public debate. The NHRI in Bosnia and Herzegovina further reported that hate speech targeting ethnic, religious and gender identities contributes to social polarisation and undermines democratic discourse.

Furthermore, 18 ENNHRI members (in Albania, Belgium (FIRM-IFDH), Bosnia and Herzegovina, Cyprus, Estonia, Greece, Iceland, Ireland, Liechtenstein, Moldova, Montenegro, Norway, Poland, Romania, Scotland, Slovakia, Slovenia and Türkiye) confirmed the particular negative impacts of the spread of disinformation on the freedom of expression. In relation to this, the NHRI from Ireland particularly highlighted the lack of transparency in funding of far-right media platforms and a lack of countermeasures of the State to tackle misinformation and disinformation, while the NHRIs from Iceland and Slovakia highlighted that vulnerable population groups such as migrants and asylum seekers were particularly targeted by disinformation.

In addition, the NHRI from Greece noted sustained negative narratives concerning refugees, migrants and civil society organisations working in these areas, often portraying them as threats to social order and national security, distorting public debate and undermining the conditions for informed and pluralistic democratic discourse. Such narratives were also reported to contribute to self-censorship among journalists, civil society actors, and human rights advocates, as hostile framing of these topics often creates a chilling effect on reporting, thereby further constraining freedom of expression in practice. Similarly, the NHRI from Cyprus stressed that disinformation and online hate speech often reinforce one another, contributing to the spread and normalisation of discriminatory narratives, undermining informed democratic debate and increasing the risk of discrimination and hostility against vulnerable groups.

Thirteen ENNHRI members also raised concerns over the negative impact of disinformation on the right to participation in public life, including elections (in Albania, Belgium (FIRM-IFDH), Bosnia and Herzegovina, Cyprus, Estonia, France, Greece, Ireland, Kosovo*, Poland, Romania, Scotland and Slovakia). In this context, the NHRI from Greece reported that xenophobic and misleading narratives, as well as disinformation targeting migrants and refugees, fuel social polarisation, legitimise hostilities, and weaken social cohesion. Such dynamics create tangible barriers to the meaningful participation of affected communities in public life, further exacerbating marginalisation and exclusion from democratic processes, as it was also reported by the NHRI in Bosnia and Herzegovina.

Twelve ENNHRI members (from Albania, Bosnia and Herzegovina, Estonia, Iceland, Kosovo*, Moldova, Northern Ireland, Norway, Slovakia, Slovenia, Türkiye and Ukraine) identified the right to privacy as one of the rights being seriously impacted by the spread of disinformation. These concerns relate in particular to the use of personal data in the targeting and dissemination of disinformation, as well as to harassment and smear campaigns directed at individuals. For example, the NHRI from Slovakia specifically reported on disinformation and smear campaigns against NGOs and their staff, while the leading government party was among the largest sponsors of hateful advertisements.

The Ukrainian NHRI identified the manipulative use of personal data, including doxing, fake profiles, unlawful disclosure of personal information, and targeted intimidation campaigns, as a particularly serious concern. Under Martial Law, such practices may create additional security risks and contribute to offline harassment and persecution. In Norway, the NHRI submitted input on a bill on measures against negative social control, in which it referred to the state's duty to protect individuals from violence, abuse and neglect, as well as its obligation to protect private and family life.

In addition to this, nine ENNHRI members, namely those from Albania, Bosnia and Herzegovina, Croatia, Denmark, Greece, Iceland, Luxembourg, Romania, and Türkiye, particularly highlighted that certain groups, for example, in view of their age, gender, race, ethnicity, religion or any other characteristics, are most affected by the spread of misinformation and disinformation. These findings point to the intersection between disinformation and structural inequalities whereby existing vulnerabilities are further exacerbated within distorted information environments. 

For example, the NHRIs from Denmark and Greece specifically reported that refugees and migrants are among the groups most affected by disinformation campaigns, further contributing to their stigmatisation. In Scotland, the NHRI reported that narratives implying that the ECtHR is upholding the rights of asylum seekers and refugees at the expense of the rights of others have influenced political narratives and risk impacting policy decisions in a way which negatively affects the rights of marginalised groups. 

The NHRI from Luxembourg reported that members of the LGBTI community, as well as women, are frequently the target of disinformation, sometimes even amplified by political actors, including parliamentarians. Similarly, the institution from Romania confirmed that certain groups, including ethnic minorities, older adults, and socially marginalised communities, are more susceptible to disinformation due to limited access to reliable information or lower levels of media literacy. In Türkiye, the NHRI highlighted digital Islamophobia as an emerging form of disinformation contributing to discrimination and restrictions on the enjoyment of freedom of religion or belief. Finally, the NHRI from Croatia also highlighted a concerning example referring to a criminal case in which an individual falsely claimed a physical attack from a migrant, while the injuries were later found to be self-inflicted. Such incidents underscore how disinformation not only undermines democratic discourse but also deepens social divisions and disproportionately impacts those already at risk of discrimination.

Actions taken by NHRIs to address disinformation

NHRIs play an increasingly important role in addressing disinformation, particularly where it affects human rights, democratic participation, equality, social cohesion, and public trust. In 2025, NHRIs acted proactively to address disinformation through public debate, education, awareness-raising activities, issuing opinions and public statements as well as through institutional cooperation.

Using their promotional mandate, many ENNHRI members provided examples of actions and initiatives undertaken nationally to raise awareness about the human rights implications of the spread of disinformation, while strengthening public resilience through education and outreach. ENNHRI members from Albania, Armenia, Cyprus, Denmark, Estonia, France, Great Britain, Liechtenstein, Moldova, Montenegro, Norway, Poland, Romania and Slovakia, reported concrete activities in this regard. The ENNHRI members in Albania, Romania and Slovakia organised targeted trainings and workshops aimed at raising awareness, while those in Denmark, Estonia, Liechtenstein and Romania focused more generally on engagement with the general public and public education, while maintaining an informed and evidence-based public debate on human rights.

For example, the ENNHRI member from Liechtenstein reported having produced a podcast series on the topic of freedom of expression and having organised an annual event on the topic of freedom of expression on Human Rights Day 2025. The Moldovan NHRI promoted verification of information through credible and pluralistic sources. The NHRI in Montenegro reported positive developments concerning journalist protection, including the establishment of an interdepartmental working group on journalist safety and the introduction of new guidance aimed at strengthening responses to disinformation while protecting professional journalism. Such initiatives are particularly important in countering the effects of disinformation without undermining freedom of expression.

In addition, NHRIs make use of their advisory and monitoring mandates to address the human rights implications of the spread of disinformation. This includes issuing opinions, (thematic) reports, or public statements, as well as providing guidance and recommendations to authorities on policy and legislative measures in this area. Such activities were particularly reported by the ENNHRI members from Albania, Armenia, Belgium (FIRM-IFDH), Bosnia and Herzegovina, Croatia, Cyprus, Greece, Liechtenstein, Luxembourg, Moldova and Ukraine. The NHRI in Bosnia and Herzegovina continued to advocate for a stronger regulation of the online media environment and measures to address hate speech, while the NHRI in Moldova issued recommendations concerning electoral integrity, protection of children and prevention of manipulation of public opinion. The Ukrainian NHRI reported extensive work on recommendations relating to personal data protection, privacy safeguards, content moderation and alignment of anti-disinformation measures with European human rights standards.

Furthermore, several NHRIs reported monitoring disinformation trends as part of their broader human rights mandate. The NHRIs in Albania, Bosnia and Herzegovina, Moldova, and Ukraine reported monitoring activities relating to the human rights dimension of electoral processes including media narratives, online hate speech, privacy violations and information manipulation. The Ukrainian NHRI also reported monitoring the implementation of measures aimed at countering disinformation in light of recommendations issued by the EU, the Council of Europe and the OSCE.

NHRIs further contribute to tackling disinformation by fostering institutional cooperation and partnerships with civil society organisations, public authorities, and regional actors, facilitating coordinated and multi-stakeholder responses. This was the case for the NHRIs from Armenia, Cyprus, Greece and Ireland. 

Overall, these examples illustrate the added value of NHRIs in addressing disinformation through a human rights-based approach, combining awareness-raising, education, and independent advice, while contributing to a more resilient and informed democratic environment.

National follow-up on the recommendations and findings on countering disinformation issued by European actors

ENNHRI members reported steps aimed at implementing recommendations and standards developed by the European Union, the Council of Europe and other regional actors in the area of countering disinformation. These developments suggest a growing recognition among state authorities of the need to address disinformation through coordinated, rights-based approaches. Positive examples were identified by 13 ENNHRI members from Albania, Armenia, Cyprus, Denmark, Estonia, Germany, Kosovo*, Moldova, the Netherlands, Norway, Poland, Romania, Ukraine. The Moldovan NHRI reported on the adoption of a national framework on strategic communication and countering disinformation for the period 2024–2030.

The Albanian NHRI shared information about a new national strategy addressing foreign interference and disinformation, while also strengthening cooperation with European partners in the area of hybrid threats and cybersecurity. The ENNHRI member in Kosovo* pointed to the launch of a Government Communications Manual aimed at improving strategic communication and resilience against misinformation, while the NHRI in Ukraine indicated the development of guidance and training materials promoting rights-based approaches to information management and access to information during wartime. The NHRI from Armenia reported on the establishment of a digital tool aimed at monitoring and overseeing the fulfilment of the international and regional obligations undertaken by Armenia, as well as the implementation of recommendations in the field of human rights.

Strengthening media literacy is increasingly recognised as a key component of democratic resilience because it helps citizens make informed decisions and participate meaningfully in public life. Therefore, efforts and initiatives in this regard were extensively reported by ENNHRI members in Denmark, Estonia, Germany, the Netherlands and Romania. In Estonia, media literacy has been integrated into school curricula, while in the Netherlands, the Ministry of Education, Culture and Science is implementing an initiative aimed at strengthening citizens' media literacy skills. Similarly, the NHRI from Germany reported on civil society projects aimed at countering disinformation, funded by the Ministry of Foreign Affairs. These initiatives focus on strengthening social resilience, including through the promotion of media literacy. In Denmark, the NHRI reported on the guidance issued by the Danish Agency for Digital Government, which advises citizens, businesses and public authorities to remain aware that AI systems can generate inaccurate outputs and may reflect or reinforce existing biases. This type of guidance contributes to raising awareness of the risks associated with emerging technologies and supports more responsible use of digital tools.

Beyond educational and awareness-raising measures, several NHRIs also pointed to developments related to the implementation and alignment with legislative frameworks addressing the digital and media environment, as well as the implementation of regional actors’ projects. For instance, the NHRIs from Cyprus and the Netherlands reported on steps taken to implement the EU Digital Services Act, while the NHRI from Greece highlighted the adoption of new legislation aimed at aligning national frameworks with the EU Media Freedom Act. On the side of projects, the NHRI from Armenia supported the initiation of the Council of Europe’s program “Promoting Freedom of Expression, Freedom of the Media, and Access to Information in Armenia”, and the NHRI from Albania reported on the Council of Europe’s project "Promoting Freedom of Expression in Albania through Open Dialogue", on journalists' safety, editorial independence and transparent media governance, both of which aimed to strengthen freedom of expression and support media freedom.

At the same time, six NHRIs (Bosnia and Herzegovina, Denmark, France, Greece, Moldova and Ukraine) raised concerns regarding the human rights implications of certain measures adopted to counter disinformation. For instance, the NHRI in Denmark reported that concerns were raised in relation to a new media responsibility agreement foreseeing the establishment of an independent media ombudsman, with some stakeholders cautioning that a state-established mechanism of this kind may risk undue interference with press freedom. The Moldovan NHRI reported concerns relating to the compatibility of some anti-disinformation measures with freedom of expression and access to information, emphasising the need for a human rights-based approach. The NHRI in France noted that a ban on the social media platform TikTok introduced in the context of the crisis in New Caledonia was found by a national court to constitute a disproportionate interference with freedom of expression, including the right to communicate and receive information, notably due to its indeterminate duration.

The NHRI in Ukraine similarly reported concerns regarding disproportionate restrictions on access to information, as well as accessibility barriers affecting official information resources. The NHRI in Greece indicated that, while legislative reforms have been introduced to align with EU legislation, such reforms remain limited in scope and structural issues persist in relation to access to reliable information. Lastly, the NHRI in Bosnia and Herzegovina identified the criminalisation of defamation in Republika Srpska as a matter of concern, echoing recommendations made by European institutions regarding freedom of expression and media freedom.

These examples demonstrate that, while efforts to counter disinformation are increasingly recognised as necessary, they must remain compliant with international human rights standards and avoid creating undue restrictions on freedom of expression, access to information and democratic participation.

On the basis of the identified challenges from the spread of disinformation and its impact on public debate and human rights, coherent and rights-compliant responses are needed to address this phenomenon effectively.

ENNHRI calls on national authorities to combat the rise of disinformation, especially online and in the media, through transparent, targeted, proportionate and rights-compliant policy and legal frameworks. National authorities should ensure that any counter-disinformation measures are clearly prescribed by law, lawful, necessary, and proportionate, and subject to effective oversight mechanisms. Public authorities should strengthen cooperation with NHRIs, civil society, and independent media actors in developing and implementing such responses to disinformation.

ENNHRI further calls on national authorities to invest in media and digital literacy and education initiatives for citizens of all ages, with particular attention to children, young people and groups most exposed to disinformation or digital harms. Authorities should promote access to reliable, pluralistic and accessible sources of information, should refrain from disseminating false or misleading information and should contribute to a public information culture grounded in accuracy, accountability, and respect for human rights.

ENNHRI calls on European and regional actors, including the European Union, the Council of Europe and the OSCE, to pursue a comprehensive and coherent approach to tackling disinformation, including through initiatives such as the European Democracy Shield and the Council of Europe’s Democratic Pact. Furthermore, ENNHRI invites European and regional actors to recognise disinformation as a Europe-wide issue, stemming from foreign and domestic actors within Europe.

Additionally, ENNHRI urges European and regional actors to strengthen their monitoring of national implementation of relevant EU, regional and international legislation and policies on tackling disinformation. In particular, the European Commission and other EU institutions should monitor the implementation of the EU Digital Services Act, the EU Media Freedom Act, and the EU AI Act to ensure that implementation and enforcement of such key legal frameworks are consistently grounded in fundamental rights, particularly the freedom of expression, access to information and the right to privacy.

Lastly, ENNHRI stresses the need for European and regional actors to ensure that responses to disinformation remain consistent with human rights. In this context, NHRIs and civil society actors should be meaningfully involved in the design, implementation and monitoring of such measures to strengthen their legitimacy, effectiveness and rights compliance.

A healthy system of institutional checks and balances is central to the rule of law and depends on the quality, transparency, accountability, and inclusiveness of the processes for enacting laws and policies. Participatory law- and policy-making processes, including ensuring broad engagement of NHRIs, CSOs, HRDs and the wider public, are crucial to maintaining a thriving democratic and rule of law-compliant space within Europe, and to ensuring that diverse perspectives are reflected in decision-making. Such processes contribute to better-quality legislation, strengthen public trust in institutions, and support the overall resilience of democratic systems.

Key challenges affecting law-making processes

ENNHRI’s 2026 Rule of Law Reporting confirms that significant challenges affecting the decision and law-making processes continue to exist across Europe, including a lack of clear provisions on participation in the law-making process, insufficient timeframes for public consultations, frequent use of fast-track procedures or emergency procedures, and a lack of systematic human rights impact assessments.

A majority of ENNHRI members reported on the issue of limited and inconsistent use of impact assessments, including human rights impact assessments. These are ENNHRI members from Albania, Belgium, Bosnia and Herzegovina, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Georgia, Great Britain, Greece, Iceland, Ireland, Latvia, Lithuania, Luxembourg, Moldova, Montenegro, Northern Ireland, the Netherlands, Poland, Romania, Scotland, Slovakia, Sweden, Switzerland and Ukraine. For some NHRIs, the absence of systematic and robust impact assessments was identified as a key gap in ensuring that legislative and policy initiatives comply with human rights and rule of law standards.

For example, the NHRI from Sweden highlighted the absence of systematic human rights impact assessments in the context of government inquiries, noting that this makes it more difficult to identify potential risks at an early stage and conduct adequate necessity and proportionality assessments. The NHRI from Switzerland reported that, although the law provides for an assessment of the impact of new legislation on human rights, such assessments are not systematically carried out in practice. The Georgian NHRI noted that fast-track procedures frequently prevent thorough impact assessments and broader public debate, while the Ukrainian NHRI highlighted the absence of systematic equality and human rights assessments in legislative and policy-making processes.

Furthermore, the NHRI from Estonia raised concerns over the use of surveillance devices and access to data systems by state authorities, which in some cases have not been subject to thorough impact assessments, including from a human rights perspective. The NHRI from France further noted that impact assessments are conducted exclusively by government administrations and do not sufficiently address human rights considerations, while the NHRI from Greece reported that the absence of systematic human rights impact assessments often results in the need for frequent post-adoption amendments to legislation. In Great Britain, the NHRI reported having written to the majority of ministerial UK government departments reminding them of the legal obligation to consider equality implications of draft laws or policies. These findings underscore the importance of embedding comprehensive and timely impact assessments into law-making processes, as a key safeguard to ensure transparency, accountability, and the effective protection of human rights.

Similarly, 28 ENNHRI members, namely those from Albania, Armenia, Belgium (Unia), Bosnia and Herzegovina, Croatia, Czechia, Denmark, Estonia, Finland, Georgia, Germany, Greece, Hungary, Iceland, Ireland, Liechtenstein, Luxembourg, Moldova, Montenegro, North Macedonia, the Netherlands, Poland, Romania, Scotland, Slovakia, Slovenia, Sweden and Ukraine, reported the problem of insufficient time allocated for public consultations. NHRIs from across Europe reported that consultation periods are often too short to allow for meaningful engagement by stakeholders, including civil society, NHRIs, and the general public. In some cases, such shortcomings were identified in the context of the transposition of EU law, as mentioned by the NHRIs from Ireland, Germany, and Luxembourg.

As noted by the NHRI in Slovenia, consultation periods tend to be particularly limited in relation to politically sensitive legislative proposals. The restricted timeframes in practice limit the possibility for meaningful participation and for evidence-based contributions, thereby reducing the quality and inclusiveness of the law-making process, as reported by the NHRIs in Greece and Slovenia. The ENNHRI member from Liechtenstein cited that short deadlines render it difficult for voluntary organisations (including organisations representing the LGBTI community or other vulnerable groups) to submit a well-founded statement in good time.

Furthermore, a number of ENNHRI members raised concerns about shortcomings in ensuring meaningful public consultations (this includes the institutions in Albania, Belgium (FIRM-IFDH, Unia, Myria), Bosnia and Herzegovina, Czechia, Finland, France, Georgia, Greece, Ireland, Lithuania, Luxembourg, North Macedonia, Romania, Scotland, Slovakia, Slovenia, Sweden, and Ukraine). Several NHRIs noted that civil society organisations, affected communities and independent institutions are not systematically involved in legislative processes. These findings indicate that there are broader structural weaknesses affecting the quality and effectiveness of participatory law-making processes across Europe.

Nineteen ENNHRI members (from Albania, Belgium (FIRM-IFDH, Unia, Myria), Bosnia and Herzegovina, Czechia, Finland, France, Georgia, Greece, Ireland, Luxembourg, the Netherlands, North Macedonia, Romania, Scotland, Slovakia, Slovenia and Ukraine) reported shortcomings that are directly related to the lack of mechanisms and processes enabling both general and targeted participation in law-making processes. In particular, NHRIs pointed to the lack of institutionalised channels to ensure that stakeholder input is systematically collected, aggregated and considered by legislators. For instance, the NHRI in Slovakia pointed to the problem of the absence of a parliamentary mechanism to ensure structured public consultation, which would enable Members of the Parliament to hear collective views and comments from a range of stakeholders.

Similarly, the NHRIs in Albania, Armenia, Finland and Luxembourg stressed the predominance of a formalistic approach to consultation processes, noting that the input from NHRIs, CSOs or the wider public is often acknowledged but not meaningfully considered in legislative outcomes. In addition, some NHRIs noted that affected communities are not systematically involved in legislative processes. For example, the NHRIs in Cyprus, the Netherlands and Ukraine highlighted that, in many cases, persons potentially directly affected by proposed legislation (e.g. persons with disabilities) are not adequately or systematically included in consultation processes, further limiting the inclusiveness and representativeness of law-making.

For some ENNHRI members, these shortcomings relate rather to the lack of clear provisions on participation in the law-making processes. This was reported by the institutions in Albania, Bosnia and Herzegovina, France, Greece, Lithuania, Moldova, Montenegro, North Macedonia, Romania and Slovenia. In the context of Romania, the ENNHRI member reported that consultation documents are often complex, technical and only available online, which creates barriers for inclusive participation.

Furthermore, 20 ENNHRI members (from Albania, Armenia, Belgium (FIRM-IFDH, Unia), Bosnia and Herzegovina, Czechia, France, Georgia, Great Britain, Greece, Hungary, Lithuania, Moldova, North Macedonia, Poland, Romania, Scotland, Slovakia, Slovenia and Ukraine) raised concerns about the wide application of fast-track or emergency legislative procedures. The NHRIs reported that the frequent reliance on accelerated procedures can significantly reduce opportunities for meaningful parliamentary scrutiny, stakeholder consultation and public debate. While in some countries such concerns relate generally to draft laws coming from the Government, as reported by the NHRI from France, in others, they are linked to specific legislative areas, such as the example highlighted by the NHRI from Slovakia, pointing to the use of a series of fast-track procedures to amend the Criminal Code.

The NHRI in Bosnia and Herzegovina noted that urgent procedures have increasingly become the norm rather than the exception, while the Georgian NHRI highlighted repeated use of accelerated procedures affecting legislation related to the judiciary, freedom of assembly, and media regulation. The Ukrainian NHRI reported cases where amendments affecting social protection and pension rights were introduced through budget legislation, limiting opportunities for substantive debate and review. Similarly, as reported by the NHRI in Greece, hasty legislative procedures can include the widespread use of omnibus law-making, whereby laws regulate multiple unrelated topics, which then leads to frequent short-term revisions of newly adopted legislation. Lastly, the NHRI in Slovenia reported that there is a tendency to prioritise rapid legislative responses in situations of heightened public pressure, as was the case following the events in Novo Mesto in 2025.

Several NHRIs also identified additional challenges affecting legislative quality and implementation. These include formalistic public consultations and limited access to information (Moldova), failure to adopt implementing legislation (Bosnia and Herzegovina and Ukraine), legal uncertainty resulting from inconsistent legislative frameworks (Ukraine), weak interinstitutional coordination (North Macedonia), and in the case of Kosovo*, the prolonged inability to constitute legislative institutions, effectively preventing legislative activity during the reporting period.

Overall, these findings indicate shortcomings in participatory, transparent, and evidence-based law-making across several European countries. The frequent reliance on accelerated legislative procedures, limited opportunities for consultation, insufficient use of human rights impact assessments, and reactive rather than strategic legislative practices can diminish the quality of democratic deliberation and constrain meaningful stakeholder engagement. Such approaches may, in turn, weaken legal certainty, compromise the effective protection of human rights, and erode public confidence in legislative processes. These developments underscore the need to strengthen procedural safeguards and ensure the consistent application of rule of law principles throughout the law-making cycle.

NHRIs’ actions or initiatives to address challenges identified in the context of law-making processes

ENNHRI has previously stressed that NHRIs, by virtue of their independent mandate, expertise in human rights standards, and privileged access to national authorities, provide essential advice and support to ensure law- and policy-making processes comply with human rights obligations. In this capacity, they are well-positioned to strengthen law-making processes, by serving as independent bridges between international human rights standards and domestic legislative frameworks, thereby contributing to more transparent, inclusive and rights-compliant law making.

The findings from ENNHRI’s 2026 Rule of Law Reporting confirm that, in 2025, many NHRIs from across Europe continued to actively engage in efforts to address and mitigate the identified challenges in the context of law-making processes. Practices such as engaging through monitoring, legislative opinions, recommendations, public advocacy and participation in working groups can be observed. Such practices sought to strengthen procedural safeguards, improve the quality of legislative processes, and enhance the integration of human rights considerations at all stages of law-making.

The monitoring of legislative developments and/or publishing monitoring reports on the implementation of international human rights obligations was reported by 13 NHRIs, namely those in Albania, Armenia, Bosnia and Herzegovina, Croatia, Denmark, Georgia, Great Britain, Moldova, Montenegro, the Netherlands, North Macedonia, Norway and Ukraine. In Croatia, the NHRI reported raising the need to conduct public consultations for a standard duration of 30 days in its annual reports. The NHRI from Norway reported having published a report in 2022, which included recommendations to the authorities on removing barriers to participation in political and public life with particular attention to persons with disabilities. In addition, several institutions systematically assess compliance with parliamentary procedures, transparency requirements and human rights standards. In Georgia, the Public Defender repeatedly raised concerns regarding accelerated legislative procedures affecting human rights, including amendments concerning the judiciary and freedom of assembly.

ENNHRI members continued issuing recommendations or legislative opinions aimed at strengthening the legality, proportionality, transparency and participatory nature of law-making processes. This was reported by 14 ENNHRI members from Albania, Belgium (FIRM-IFDH), Bosnia and Herzegovina, Cyprus, Estonia, Georgia, Greece, Hungary, Kosovo*, Lithuania, Moldova, Montenegro, North Macedonia and Portugal. Through such recommendations, NHRIs seek to address structural shortcomings and promote alignment of legislative processes with rule of law and human rights standards. The Moldovan NHRI reported that within the framework of 18 opinions developed between 2022 and 2025, at least 173 concrete recommendations were formulated, aimed at ensuring the integration of a human-rights based approach into public policies and the legislative process. The Albanian NHRI submitted opinions and human rights assessments on draft laws and strategic reforms, including the Intersectoral Justice Strategy. The NHRI in Bosnia and Herzegovina issued recommendations and opinions concerning disability rights, inclusive education, and social protection legislation, some of which resulted in legislative amendments. The NHRIs in Montenegro and North Macedonia similarly reported advocating for amendments where legislation was found to be inconsistent with human rights standards.

Several ENNHRI members highlighted the importance of raising public concern (public awareness) and addressing the relevant actors regarding shortcomings in law-making processes. This was reported by the ENNHRI members in Albania, Belgium (FIRM-IFDH, Unia, Myria), Bosnia and Herzegovina, Czechia, Finland, Georgia, Great Britain, Greece, Luxembourg, Moldova, the Netherlands, Slovakia, Sweden and Ukraine. By publicly identifying and communicating concerns related to transparency, participation, and legislative quality, NHRIs contribute to fostering accountability and encouraging improvements in governance practices. For instance, in the context of the implementation of the EU Migration and Asylum Pact, the NHRIs from Czechia, the Netherlands, and Sweden raised serious concerns about the lack of broad, transparent and/or sufficiently lengthy consultation processes, while also calling on the relevant actors to address and remedy these shortcomings. Another example was reported by the NHRI from Great Britain, which called on the Government to improve its understanding of the potential impacts of synthetic pepper spray before it is rolled out in young offender institutions.

To address challenges identified in the context of law-making processes, ENNHRI members also reported engagement with courts, including Constitutional Courts. The Moldovan NHRI participated in parliamentary hearings and Constitutional Court proceedings concerning procedural deficiencies in law-making. The ENNHRI member from Kosovo* challenged legislative provisions before the Constitutional Court due to concerns regarding legal certainty and effective remedies. In Azerbaijan, the NHRI has the mandate to submit inquiries to the Constitutional Court. Several petitions were sent and examined and, in some cases, the Court found that the lack of special safeguards were incompatible with the constitutional principles of proportionality and equality.

Some ENNHRI members also concentrate on developing practical guidance and providing capacity-building opportunities for stakeholders engaged in law-making processes, as exemplified in Belgium, Greece, Liechtenstein, Romania and Sweden. For instance, the NHRI of Sweden formulated specific guidance on conducting human rights impact assessments within government inquiries, aimed at supporting more systematic and rights-based approaches to policy development. The NHRI from Greece reported engaging in structured pre-legislative dialogues with relevant ministries prior to the submission of draft laws to Parliament, enabling substantive discussion of human rights implications at an early stage of the legislative process. Meanwhile, the ENNHRI members of Belgium and Romania organised seminars, workshops and roundtable discussions to enhance the capacity of public authorities, policymakers, and other relevant stakeholders to integrate human rights considerations into legislative processes. In this regard, the institution from Liechtenstein reported that it supports organisations affected by draft legislation during the consultation processes.

Measures to follow up on the findings or recommendations on strengthening law-making processes issued by European actors     

Several measures were taken nationally to follow-up on the findings or recommendations issued by European actors on strengthening law-making processes, including participation. Measures aimed at strengthening legislative processes in response to recommendations issued by the European Union, the Council of Europe and OSCE/ODIHR, were especially reported. This was particularly the case in Albania, Armenia, Cyprus, the Netherlands, Moldova, Montenegro, Poland, Romania and Ukraine, where concrete procedural steps have been taken to enhance consultation frameworks, extend the duration of public consultation periods, and strengthen the use of impact assessments. These developments indicate progress in the engagement by national authorities aiming at aligning legislative practices with rule of law benchmarks, including those developed by the Council of Europe, the Venice Commission, and the OSCE.

As an example, the NHRI from Armenia informed about the creation of an online platform to monitor the fulfilment of the international obligations undertaken by the Republic of Armenia, as well as the implementation of the recommendations presented in the field of human rights. The same NHRI also reported the establishment of a National Mechanism for Implementation, Reporting, and Follow-up, which serves as a coordinated network of representatives drawn from the executive, legislative, and judicial branches, coordinated by the Ministry of Foreign Affairs.

The Moldovan NHRI reported efforts to modernise parliamentary procedures, improve transparency, and strengthen consultation mechanisms as part of broader EU accession reforms. The Albanian NHRI highlighted the introduction of an electronic legislation portal aimed at facilitating public participation and access to legislative information. The Ukrainian NHRI reported extensive engagement in legislative reforms linked to the EU accession, including personal data protection, anti-discrimination, accessibility and disability rights legislation, with the NHRI participation embedded in several reform processes.

It is important to ensure that law-making processes are transparent, participatory, and evidence-based, and that they fully integrate human rights considerations from the outset.

Thus, ENNHRI calls on national authorities to ensure that law-making processes are inclusive, transparent, and have a reasonable timeline for checks and balances. Furthermore, ENNHRI invites national authorities to establish clear procedural requirements for timely and meaningful public consultation, including also NHRIs and CSOs. Draft legislation should be made publicly available at an early stage and be subject to timely, meaningful and inclusive consultation with NHRIs, civil society, academia, social partners, affected communities and other relevant stakeholders. For example, national authorities could consider institutionalising pre-legislative consultation mechanisms including structured dialogues as a standard step in law-making processes to ensure early identification of human rights risks. Particular efforts should be made to ensure the effective participation of groups whose voices are often underrepresented in decision-making processes, including women, persons with disabilities, minority groups and other individuals at risk of exclusion.

Additionally, ENNHRI urges national authorities to limit the use of fast-track or emergency procedures to duly justified and exceptional cases. Legislative proposals should be accompanied by sufficient consultation periods to allow meaningful scrutiny, adaptation and effective implementation. Lastly, ENNHRI reiterates the importance of systematically carrying out comprehensive impact assessments, including human rights impact assessments for draft legislation to ensure compliance with relevant national, regional, and international standards.

ENNHRI calls on the European Union, Council of Europe and other regional actors to promote and apply high standards of transparent, inclusive, and well-structured law-making. By upholding such standards in their own processes, European and regional actors can further support good legislative practices, reinforce accountability, and serve as a reference point for national authorities in strengthening the quality and legitimacy of law-making. Moreover, ENNHRI urges European and regional actors to ensure the systematic use of human rights impact assessments across all legislative initiatives and at all stages of the law- and policy-making processes.

ENNHRI further recommends to European and regional actors to improve the quality and accessibility of consultation processes by ensuring structured dialogue and meaningful participation of relevant stakeholders. Lastly, ENNHRI invites the European Union and other regional actors to avoid expedited procedures or package bills that hinder clarity, transparency and effective scrutiny at the expense of meaningful stakeholder deliberation. Any fast-track procedures or accelerated procedures for legislative acts should remain exceptional, justified and subject to adequate safeguards.

ENNHRI members highlighted that broader structural human rights challenges continue to significantly affect the rule of law environment across Europe. These issues often reflect systematic and long-standing deficiencies that require sustained and comprehensive responses.

Many ENNHRI members reported persistent structural human rights issues impacting the rule of law in the area of asylum and migration. Ten ENNHRI members (from Belgium, Czechia, Finland (Human Rights Centre), France, Germany, Greece, Luxembourg, Northern Ireland, Scotland, and Slovakia) raised serious concerns regarding ongoing and systemic violations of the rights of migrants, including refugees and people seeking asylum. They also reported increasingly restrictive policies and legislative developments that risk undermining protection-sensitive asylum and migration frameworks. For example, the ENNHRI members from Czechia, Germany, Slovakia, and Sweden identified practices that disproportionately expose migrants to discrimination, create obstacles in accessing their rights in practice, and in some cases, deny individuals access to appropriate administrative procedures. The NHRIs from Germany and Luxembourg in particular raised concerns about the adoption of restrictive national policies, including measures such as refusals or limitations on entry for people seeking asylum (either under specific conditions or without any procedure), as well as the suspension of family reunification for beneficiaries of subsidiary protection.

The NHRI from Northern Ireland reported that the UK Government had introduced the Border Security, Asylum and Immigration Act for the purposes of “modernising the asylum and immigration system”. However, concerns emerged regarding the compatibility of the new Act with Article 2 of the Windsor Framework regarding protections for victims of human trafficking and modern slavery, and the retention of earlier legislation which reduced the rights of refugees, asylum seekers and migrants who arrive in the UK by irregular means. The NHRI from Scotland cited increasing concerns due to incidents at protests directed towards asylum seekers outside their temporary accommodation. The NHRI from Greece reported on the systematic practice of informal forced returns, which the European Court of Human Rights found to be in breach of articles 3, 5, and 13 of the European Convention on Human Rights.

Beyond the area of migration, four ENNHRI members, namely those in Belgium, France, Slovakia and Switzerland, pointed to the erosion of public trust or authority in the institutions as a broader structural human rights concern. While this issue has also been linked to the impact of disinformation, several members emphasised that declining trust in state institutions is itself a structural human rights issue affecting the rule of law. In France and Slovakia, such erosion of public trust was reported in relation to the national judicial system, where ENNHRI members identified instances of direct attacks by representatives of the executive or other political actors, coupled with insufficient responses from the authorities responsible for safeguarding institutional integrity. Myria – one of the ENNHRI members in Belgium – reported a broader trend of public authorities challenging the authority of the judiciary and undermining the principle of separation of powers.

In Sweden and Switzerland, the NHRIs expressed their concern that the authority of international human rights mechanisms, such as the European Convention of Human Rights (ECHR) and the Court, are increasingly being called into question in public and political debate. Similarly, the NHRI from Northern Ireland reported that there continues to be partial political pressure for the UK to leave the ECHR completely. These trends raise broader concerns about respect for international human rights obligations and their role within domestic legal systems.

Concerns were also raised regarding detention conditions and the protection of the rights of persons deprived of liberty. In particular, overcrowding in penitentiary institutions was identified as a persistent structural issue in Albania, Belgium, Georgia, Hungary, Moldova, Scotland, Serbia and Ukraine, alongside the situation of detainees held in prison without sufficient and appropriate therapeutic support. The Swedish NHRI also reported concerns regarding prison overcrowding, noting that the focus of the Swedish criminal policy over the last decade, including the tightening of certain penalties in Swedish criminal policy, have resulted in a significant increase in the number of inmates, with occupancy rates rising and double occupancy becoming the norm. In Ukraine, the NHRI further reported systemic shortcomings in prison healthcare, overcrowding and inadequate safeguards in closed institutions, while the NHRI in Moldova continued to identify deficiencies in detention infrastructure and medical services.

Lastly, some ENNHRI members also highlighted challenges concerning the full realisation of social rights and deficiencies concerning social protection systems, as reported by the NHRIs from Armenia, Germany, Great Britain, Finland, Scotland, and the Netherlands. The NHRIs from Finland and Germany raised concerns about reforms to the welfare and social security systems. In Great Britain, the NHRI indicated substantial gaps in access to health services for people with disabilities, while the NHRI from Scotland reported that this group of people face issues with fulfilling their right to independent living. In addition, the British NHRI observed issues regarding migrants’ access to safe and fair working conditions, with the government persistently failing to protect them from abuse and exploitation. In Armenia, the NHRI reported barriers in the protection of children’s rights in accessing education as well as a ban on access to judicial profession for persons with certain disabilities. These findings point to the interconnected nature of social rights, equality, and non-discrimination, and their importance for ensuring inclusive and resilient societies grounded in the rule of law.

Similarly to the above, a recurring concern relates to the insufficient protection of groups in a vulnerable situation and unequal access to rights in practice. ENNHRI members from Albania, Bosnia and Herzegovina, Kosovo*, North Macedonia, Serbia, and Ukraine reported persistent challenges affecting children, persons with disabilities, Roma communities, minority groups, victims of trafficking and other persons in vulnerable situations. These challenges frequently stem from weak implementation of existing legislation, inadequate institutional coordination, insufficient support services and limited resources at national and local level. The ENNHRI member in North Macedonia informed that concerns were raised regarding accessibility barriers affecting persons with disabilities and allegations of discrimination affecting Roma, Turkish and Vlach communities. The NHRI from Albania highlighted continuing gaps in the implementation of children's rights protections, while the NHRI from Serbia reported persistent shortcomings affecting support and protection systems for children, persons with disabilities and victims of trafficking.

Two NHRIs further identified digitalisation and emerging technologies as an evolving structural human rights challenge. The NHRIs from Moldova and Ukraine reported concerns regarding personal data protection, algorithmic decision-making, digital surveillance and access to effective remedies in increasingly digitalised public services. These developments underline the need to ensure that digital transformation remains grounded in human rights and rule of law safeguards.

Another trend identified in this reporting cycle concerns the impact of armed conflict, occupation and of non-state actors on the enjoyment of human rights and the functioning of the rule of law. The Ukrainian NHRI reported widespread and interconnected challenges affecting internally displaced persons, children, victims of conflict-related sexual violence, residents of temporarily occupied territories and other persons affected by Russia’s ongoing armed aggression. Similarly, the Moldovan NHRI highlighted continuing human rights challenges linked to the Transnistrian region. These findings demonstrate that protracted conflict situations continue to create significant and long-term pressures on human rights protection systems and rule of law institutions. In Northern Ireland, paramilitary groups continue to exist and exert coercive control over some communities through intimidation, financial extortion, and sexual exploitation, creating communities where people are afraid to speak out, and stifling alternative voices and leadership.

Gender dimensions were also reported across several thematic areas. The NHRI from Albania highlighted barriers faced by survivors of gender-based violence in accessing protection and legal assistance, while the NHRI from Montenegro reported concerns regarding gender-based violence and hate speech. The NHRI from Ukraine further reported challenges relating to conflict-related sexual violence and stressed the need for gender-sensitive approaches in policy-making, implementation and data collection.

Addressing structural human rights issues remains essential to strengthening the respect for the rule of law across Europe.

ENNHRI calls on national authorities to ensure that all legislative, policy and administrative measures fully comply with international and European human rights standards, including by effectively addressing structural violations of human rights identified by NHRIs. National governments should ensure that the national legal framework is equipped to address asylum- and migration-related issues in a way that is compliant with established regional and international standards, with due heed paid to human rights.

ENNHRI urges national authorities to safeguard effective oversight in migration contexts by refraining from measures that unduly restrict independent actors’ – including NHRIs’ and CSOs’- work in this area. In this regard, European States should implement migration and asylum policies in compliance with European and international human rights standards, including through the establishment of dedicated independent monitoring bodies and their close collaboration with other regional and national actors monitoring human rights in the context of migration.

Recommendations made by monitoring bodies, both regional and national, should be considered and followed, while implementation of judgments by the European Court of Human Rights should be ensured. Lastly, ENNHRI urges national governments to refrain from contributing, for instance, through statements by the executive or government officials, to the erosion of public trust in key institutions such as the national judicial systems or regional courts such as the European Court of Human Rights.

ENNHRI calls on the European Commission and the Venice Commission to further strengthen the systematic inclusion of NHRI findings into the Rule of Law framework and into the country reports, including by consistently addressing challenges identified by NHRIs, and supporting States in implementing reforms that enhance the protection of human rights and the rule of law.

Furthermore, ENNHRI encourages the EU Institutions, the Council of Europe and other regional actors to strengthen the monitoring and enforcement of European legislation in the field of migration and asylum. In this regard, ENNHRI invites the EU Institutions, the Council of Europe and other regional actors to promote and support the formal involvement of NHRIs in independent border monitoring mechanisms and in the oversight of migration-related measures, where this would add value.

Throughout ENNHRI’s 2026 Rule of Law Reporting, many ENNHRI members identified a range of additional persisting challenges or developments affecting the national rule of law environment. These concerns span media freedom, the functioning of the judiciary, accountability mechanisms, and the overall system of checks and balances, and often reflect structural weaknesses with cumulative impacts on democratic governance.

Some ENNHRI members raised concerns over the state of media freedom and pluralism, as well as excessive restriction of freedom of expression, coupled with concerns of censorship. The ENNHRI members from Moldova, Montenegro, Kosovo*, and Ukraine reported concerns regarding media pluralism, access to public information and restrictions affecting public debate. Several institutions noted that limitations on access to information continue to affect accountability and democratic participation, while weaknesses in media regulation and ownership transparency remain unresolved.

As regards the independence and effectiveness of media regulatory bodies, the most significant issues were reported by the NHRI from Slovakia, which alerted on the dissolution of the public broadcaster and its replacement by a newly established institution operating with an incomplete board and interim budget for an extended period, as well as the proposed amendment to the Media Services Act aimed at transforming the regulatory body for media services into a new body. It warned that politically driven selection processes for leadership positions in this new body risk concentrating influence within a single centre of power. In terms of hate speech, the NHRI in Armenia reported that targeting of women and persons with disabilities, discriminatory and hate speech based on ethnicity, and discriminatory speech directed against representatives of religious organisations and atheists have become more widespread. 

The ENNHRI members from Belgium, Finland, Greece, and Luxembourg pointed to the rising pressure targeting journalists and the restriction of freedom of expression. For example, the member from Finland highlighted ongoing legal proceedings involving two journalists convicted for disclosing state secrets in relation to a 2017 publication, noting concerns regarding the confidentiality of proceedings and the uncertainty surrounding the criminalisation of journalistic activities (e.g. gathering material and article preparations) in the judgment. In addition, the member from Greece reported the absence of adequate legislative or non-legislative measures to prevent SLAPPs, alongside numerous incidents affecting journalists, including harassment, physical assaults, obstruction or restriction of access to information, and criminalisation.

Several NHRIs also raised concerns about the effective functioning of justice systems, which require appropriate actions and responses from national authorities to uphold the rule of law. The ENNHRI members from Albania, Austria, Georgia, Greece, Kosovo*, Moldova, North Macedonia, Portugal, Northern Ireland, Serbia, Slovenia, Spain and Ukraine, underlined the persisting delays in court proceedings. Closely linked to these developments are structural challenges affecting judicial capacity and efficiency. The ENNHRI members from Albania, Kosovo*, Moldova and Ukraine reported shortages of judges and court personnel, delays in judicial appointments and broader human resource challenges affecting the administration of justice.

The NHRI from Spain additionally highlighted the lack of adequate training of judges in cases involving violence against women. The NHRI from Ukraine additionally reported concerns regarding the institutional stability of the Constitutional Court and the continued impact of Martial Law on the functioning of courts. The ENNHRI member from Liechtenstein informed that the justice system has been reformed, however the effects of this reform have not yet become apparent. The NHRI in Türkiye also highlighted ongoing judicial reforms aimed at strengthening efficiency, legal certainty, and professional capacity within the judiciary.

Furthermore, the ENNHRI members from Albania, Georgia, Greece, Ireland, Kosovo*, Luxembourg, Moldova, North Macedonia, Scotland and Serbia reported concerns regarding non-implementation or incomplete implementation of judgments from domestic courts and/or from regional and international bodies.

Access to legal aid and effective remedies, particularly for persons in vulnerable situations, has been cited by the ENNHRI members in Moldova, Kosovo*, Northern Ireland, North Macedonia, Scotland and Serbia, as an issue affecting the rule of law. Also, the lack of requirement on judges to publish judgments was reported by the NHRI in Scotland.

Moreover, some ENNHRI members pointed to the persistent challenges affecting the healthy system of checks and balances. These cases were reported by the NHRIs from Estonia, France, Germany, Greece, Poland, and Slovakia. For instance, the NHRIs from France, Germany, and Slovakia identified raising concerns of increasing political influence or attacks against judicial authorities, aiming to weaken the institutions and undermine their independence.

Two ENNHRI members reported developments relating to anti-corruption frameworks and institutional accountability mechanisms. The NHRI in Moldova noted progress in anti-corruption reforms, whereas the NHRI in North Macedonia highlighted corruption as a persistent obstacle to the rule of law.

Furthermore, the NHRI from Moldova and Slovakia reported on challenges regarding whistleblower protection. The NHRI from Poland continued to stress the persisting challenges regarding the composition of the National Council of the Judiciary, which remains dominated by representatives of Parliament and the Government, and challenges regarding the lawfulness of the appointment to the position of National Prosecutor.

The NHRI from Estonia also reported on issues concerning transparency in the state budget impacting the Parliament's powers, as the activity-based state budget introduced in recent years gives the executive branch too much freedom to decide on the use of budgetary funds, while those decisions must be made by the Parliament. 

Lastly, a few ENNHRI members highlighted the persisting challenges of non-ratification or incomplete incorporation of key human rights instruments as an additional concern for the rule of law. For instance, this concerned the continued absence of ratification of the Optional Protocol to the Convention against Torture in the case of Ireland, and the transposition of Protocol no. 12 to the European Convention on Human Rights in the national legislation in the case of Malta. In Northern Ireland, the NHRI remained concerned that there has been no indication of the timeline for the transposition of amendments to equality directives as required under the UK Government’s obligations post-Brexit.

In view of the persistent challenges identified in relation to justice systems, media freedom and pluralism, and institutional checks and balances, continued efforts are needed at both national and regional levels to strengthen the effective functioning of the rule of law across Europe.

ENNHRI calls on national authorities to safeguard judicial independence, to ensure the effective functioning of the justice system in law and in practice, and to reinforce safeguards for the separation of powers. This includes addressing persistent issues related to access to justice by addressing excessive delays in judicial proceedings, strengthening judicial capacity, ensuring adequate staffing and resources for courts, and improving access to legal aid, particularly for persons in vulnerable situations.

Authorities should further ensure the full, timely and effective implementation and enforcement of domestic judicial decisions and judgments of the European Court of Human Rights, including through strengthened parliamentary oversight and inter-institutional coordination mechanisms. Furthermore, ENNHRI urges national authorities to refrain from any measures which might further restrict freedom of the media, except in duly justified cases, and to address the rising pressure targeting journalists and media workers.

ENNHRI further urges national authorities to reinforce the independence, effectiveness and accountability of oversight frameworks. This includes strengthening anti-corruption measures and whistleblower protection frameworks, and improving other oversight mechanisms to enhance public trust in institutions and legal certainty. Particularly, in countries affected by armed conflict or occupation, authorities should ensure comprehensive and coordinated responses to rule of law and human rights challenges, including access to justice for victims, accountability for serious human rights violations, protection of children and other affected groups, and effective remedies for conflict-related harm.

ENNHRI calls on the EU institutions and the Council of Europe to closely monitor the implementation of their country-specific recommendations by States in relation to justice systems or judicial reforms. Regional actors should also strengthen support for NHRIs and other independent oversight institutions when working on the implementation of courts judgments or when fighting against corruption and the erosion of checks and balances.

In 2025, the Ombudsman’s Office of Latvia strengthened its institutional framework while addressing ongoing rule of law challenges, the institution was re‑accredited with A-status. Amendments to the Ombudsman Law expanded mandates, most notably regarding the Article 77 of the Artificial Intelligence Act and clarified the NPM tasks under the OPCAT, and reference to Directives 2024/1499 and 2024/1500. The Office continued its broad human rights protection, equality, disability rights monitoring, forced return oversight, and NPM mandates.

The Ombudsperson actively supported civil society and human rights defenders by facilitating NGO engagement with UN mechanisms and convening the Advisory Council on Disability Matters. The Ombudsperson urged national authorities to uphold good governance and protect institutional independence, including in the implementation of the AI Act.

The Ombudsman’s Office of the Republic of Latvia was re-accredited with A status in October 2025.

Among the recommendations, the Sub-Committee on Accreditation (SCA) reiterated its 2020 recommendation for the NHRI to advocate for the formalization and application of a selection and appointment process that includes requirements to publicize vacancies broadly to encourage diversity, and promote broad consultation and / or participation in the application, screening, selection and appointment process. In addition, the SCA encouraged the NHRI to advocate for appropriate amendments to its Law to ensure a dismissal process with clearly defined and objective grounds.

Moreover, the SCA continued to encourage the Ombudsman to advocate for the inclusion in its founding legislation of express provisions that clearly establish the functional immunity of the Ombudsman for actions taken in his or her official capacity in good faith. The SCA encourages the Ombudsman to continue to strengthen its efforts to address inequalities and promote and protect the human rights of the most vulnerable groups and minorities, including migrants and Roma, and to ensure that its positions on these issues are made publicly available.

Finally, the SCA encouraged the Ombudsman to advocate for the inclusion of provisions in its enabling legislation, regulations or binding administrative guidelines that protect against real or perceived conflicts of interest.

The national regulatory framework applicable to the NHRI has changed since January 2025. 

Amendments to the Ombudsman Law (adopted on 6 March 2025 and entering into force on 2 April 2025) included the function of the National Preventive Mechanisms in the Ombudsman Law and formalizing the procedure of accessing information and data included in the Court Information System, particularly regarding rights and obligations for data security for the employees of the Ombudsman’s Office. These amendments also included Informative Reference to so called equality bodies standards Directives 2024/1499 and 2024/1500. 

On 18 March 2025, the President of the Republic of Latvia submitted to the Parliament a draft law on the amendments to the Ombudsman Law providing that the President nominates a candidate for the position of the Ombudsman. After the 4 June 2025 sitting, the Parliamentary Legal Committee drafted amendments to the Ombudsman Law providing that both members of the Parliament (not less than 10) and the State President could nominate candidates for the position of the Ombudsman. The draft law on amendments (No 981/Lp14) has been submitted for third reading of the Parliament.

On 15 January 2026 (entering into force on 11 February 2026) amendments to the Ombudsman Law were adopted providing for additional mandate to the Ombudsman according to Article 77 of the Artificial Intelligence Act. Considering the difficult financial situation in the country, the Ombudsperson did not request additional funding for the AI mandate for 2026; however, the Ombudsperson reserved the right to request additional funding in the future. 

Besides the NHRI mandate, the Ombudsman’s Office of Latvia carries out the mandate of Ombuds, Equality Body, CRPD national monitoring mechanism, NPM, and Forced return monitoring according to the Child Rights Convention and the new mandates of Article 77 Body.

Article 77 of the AI Act 2024/1689 determines that fundamental rights institutions have the power to request and access any documentation created or maintained under this Regulation in accessible language and format when access to that documentation is necessary for effectively fulfilling their mandates within the limits of their jurisdiction. This means that fundamental rights institutions can directly ask information about AI systems. 

Current proposal (Digital omnibus) suggests that fundamental rights institutions will be able to request information through market surveillance authorities. This idea contradicts Article 3 of the Directive 2024/1500 and the Directive 2024/1499. Additional suggestion includes “This is without prejudice to the competences, tasks, powers and independence of the relevant national public authorities or bodies under their mandates.” However, this sentence is declarative, since the very requirement to request information through another institution limits the independence of the Ombudsman. 

In addition, the requirement to obtain information through another institution prolongs the process, creates an additional burden for that institution. Consequently, one cannot agree with the statement that this process reduces bureaucracy. 

The Ombudsperson is aware that there are EU countries where many institutions have been designated as Article 77 bodies, which can make it difficult for an entrepreneur to provide information. However, this situation is not in all countries. 

Therefore, the Ombudsman’s Office of Latvia:

1. calls for the question of how the acquisition of information is organised – centrally or directly – in the context of Article 77 of the AI Act to be left to the competence of the Member States.        

There were several initiatives taken by the Ombudsman’s Office of Latvia to promote civil society space and HRDs, such as promotion and/or communication campaigns or joint meetings and/or roundtables.

In October and November of 2025, the Ombudsperson met with the non-governmental institutions that represent people with disabilities and advocate for their rights. The NGOs were informed about the possibility of submitting their reports to the United Nations Committee on the Rights of Persons with Disabilities and that the Ombudsman’s Office is ready to facilitate their submissions. Also, the Ombudsperson has invited the NGOs to participate in the Advisory Council on Disability Matters, and its first online meeting took place on 22 January 2026.

Moreover, in 2025, the Ombudsman’s Office of Latvia also took several initiatives to protect civil society space and HRDs, such as monitoring, complaints handling, providing legal assistance, issuing recommendations to national authorities or through different mandates.  

Based on the human rights monitoring and reporting, the Ombudsman’s Office of Latvia identified significant challenges affecting law-making processes, namely the limited use of impact assessments, including human rights impact assessments.

Ministry of Agriculture had submitted draft laws on amendments to the Law on Forests and to the Law on Environmental Impact Assessment. Both draft laws were being promoted with a very shortened coordination period of 5 and 4 days, respectively. Given that the draft laws affect the wider public, the Ombudsman's Office called on the Ministry of Agriculture to ensure reasonable time for public consultation in accordance with good governance.