Overview:
The Protection of Sovereignty Bill, 2026, currently before Parliament, classifies a Ugandan living outside the country as a “foreigner.” Under its provisions, a family member in Uganda who receives financial support from such a person could be deemed an “agent of a foreigner,” triggering a range of legal obligations.
A proposed law intended to shield Uganda from foreign interference could significantly affect ordinary citizens, with its provisions extending to routine activities such as receiving money from relatives abroad.
The Protection of Sovereignty Bill, 2026, which was tabled before Parliament on Wednesday, classifies a Ugandan living outside the country as a “foreigner.” Under its provisions, a family member in Uganda who receives financial support from such a person could be deemed an “agent of a foreigner,” triggering a range of legal obligations.
The Bill further requires that before any funds are released, banks must obtain a ministerial funding declaration and authorisation from the Minister of Internal Affairs. The draft law does not provide exemptions for remittances, raising concerns about its potential impact on households that depend on support from abroad.
Analysts say the implications of the Bill go beyond its stated aim of regulating foreign influence, with its provisions likely to affect Ugandan citizens, organisations and financial institutions.
Broad definitions
At the centre of the Bill are two key definitions—“foreigner” and “agent of a foreigner”—both of which are broadly framed.
A foreigner includes not only non-citizens but also Ugandans living abroad, foreign governments, embassies, international organisations, and companies or non-governmental organisations registered outside Uganda. The Minister of Internal Affairs is also empowered to designate any entity as a foreigner.
An “agent of a foreigner” is defined as anyone who acts on behalf of, is employed by, or is directly or indirectly funded or controlled by a foreigner.
Legal experts note that the inclusion of the term “indirectly” significantly widens the scope. For example, a local NGO funded by another organisation that receives international grants could qualify as an agent. Similarly, employees of donor-funded health facilities, academic institutions or media houses may also fall within this category.
Restrictions and approvals
The Bill places several restrictions on those classified as agents of foreigners. They are prohibited from providing services in sectors such as health, education, water and infrastructure without Cabinet approval. They are also barred from developing, influencing or implementing government policy.
However, the draft law does not specify timelines within which Cabinet must make decisions, nor does it require reasons to be given for refusals. There is also no administrative appeals mechanism.
This could affect thousands of organisations currently operating under existing permits issued by the NGO Bureau, all of which would require fresh approvals if the Bill is enacted.
The legislation also introduces offences tied to broadly worded provisions. Clause 5 prohibits activities deemed to promote the interests of a foreigner “against the interests of Uganda,” a phrase that is not defined.
Clause 13 creates the offence of economic sabotage, covering actions that “weaken or damage” the country’s economic system. Notably, the Bill does not require proof of intent for prosecution under these provisions.
Registration requirements
The Bill establishes a mandatory registration system for all agents of foreigners. Individuals and organisations must obtain certification from the Department of Internal Affairs before operating.
Failure to register attracts penalties of up to 10 years’ imprisonment and a fine of Shs1 billion.
Applicants are required to disclose detailed information, including employee records, agreements with foreign entities, financial contributions received within 60 days, and a statement of political activities. The department may also seek information on applicants’ physical and mental health.
Certificates would be valid for two years, but the Minister would have powers to revoke them without prior notice or an opportunity for the holder to respond.
Pressure on banks
The proposed law also places obligations on financial institutions. Banks would be required to verify ministerial approval before processing transactions involving agents of foreigners and submit monthly reports on such transfers.
A bank that releases funds without authorisation risks a civil penalty of up to Shs4 billion, while withholding legitimate payments could expose it to legal claims from customers.
The Bill also requires financial declarations to be made publicly accessible, potentially conflicting with existing provisions under the Anti-Money Laundering Act, which protect the confidentiality of financial transactions.
Legal inconsistencies
Legal analysts have raised concerns about possible conflicts between the Bill and existing laws.
The requirement for disclosure of health status, financial information and political views touches on categories classified as “special personal data” under the Data Protection and Privacy Act, which cannot be processed without explicit consent. The Bill, however, does not provide a consent framework.
In addition, some offences in the Bill overlap with provisions in the Penal Code and the Anti-Terrorism Act but carry heavier penalties and fewer safeguards. For example, offences related to economic sabotage under the Bill attract up to 20 years’ imprisonment without requiring proof of intent or approval from the Director of Public Prosecutions.
Questions have also been raised about the introduction of the Minister of Internal Affairs as an additional authority in approving foreign funding to government institutions, alongside the Minister of Finance, without clarifying how the two roles would be harmonised.
Transition concerns
The Bill does not provide transitional arrangements for organisations currently operating lawfully. If enacted in its current form, existing approvals and permits could immediately fall under the new framework without a clear pathway for compliance.
This, analysts say, could expose organisations and individuals to legal risk for activities that are currently lawful.
Next steps
The Bill is yet to be debated and scrutinised by Parliament. Stakeholders are expected to engage during the committee stage, where proposals can be amended and concerns formally recorded.
Legal experts advise organisations to begin assessing potential compliance gaps, particularly in funding arrangements and partnerships, given the extensive disclosure and approval requirements proposed.
They also recommend that Parliament clarifies key definitions, aligns the Bill with existing laws, and introduces safeguards to prevent unintended consequences.
While the objective of regulating foreign influence remains a matter for legislative consideration, observers say the current draft raises significant questions about scope, implementation, and its potential impact on ordinary Ugandans.
