At the end of 2020, a young person was murdered by a state police employee. This caused nationwide protests lasting several days that demanded the responsible person be brought to justice. The People’s Advocate of Albania launched an investigation into police conduct when arresting journalists during these protests. Media reports documented several media actors being taken to police premises. The NHRI recommended that the police analyse the cases in terms of what constitutes lawful conduct of police officers when escorting individuals. It also recommended that the police guarantee the media’s right to cover protests; train police officers to improve their conduct towards media actors; avoid violating the rights of escorted persons; and establish special rules concerning the treatment of media actors. The police have followed up on the recommendations with concrete measures and actions addressing them.
In 2024, the Human Rights Defender of the Republic of Armenia actively monitored the human rights situation during widespread protests and assemblies in Yerevan and across the provinces. Rapid response teams from the Defender’s Office visited police departments in which detained protesters were held, conducted private interviews, informed individuals of their rights, and assessed conditions firsthand. The Office also reviewed submitted complaints and conducted ongoing monitoring of mass media and social media to identify rights violations and take appropriate action. Throughout this period, the Defender issued public statements urging state authorities to safeguard the peaceful nature of assemblies and uphold fundamental rights.
In 2022-2023, the Federal Institute for the Protection and Promotion of Human Rights (FIRM-IFDH) conducted a research report on the protection of human rights defenders (HRDs) in Belgium. Most of the consulted human rights organisations had recently faced pressure and intimidation. Many indicated that the situation as a whole had deteriorated over the two-year reporting period, with a strong gendered component. The report’s conclusions highlighted that stronger protection of civic space and HRDs is required.
A number of concrete proposals were included in the report, grounded in various regional and international guidelines on the protection of HRDs. The main findings of this report were presented to and discussed with most major political actors in several meetings throughout 2024. They were subsequently included in the main priorities of political parties ahead of the June 2024 elections. The final report was published in 2024.
In 2023, the Institute also carried out a public awareness campaign to draw attention to the importance of the work of HRDs in Belgium. For nearly a month, several thousand support posters were displayed across five major cities in Belgium. On 5 December 2023, FIRM-IFDH organised a support action in central Brussels, together with human rights defenders, aimed both at raising public awareness and at presenting the first results of its research. The action generated significant interest in the written press and on the radio. The campaign was conducted in French and Dutch.
The Federal Institute for the Protection and Promotion of Human Rights (FIRM-IFDH) devoted its 2024 Annual Report to the right to protest. The report draws attention to the growing pressure on this fundamental right. Through concrete findings, it analyses the cumulative effect of different types of measures taken before, during, and after protests: preventive restrictions (such as individual protest bans), potentially disproportionate surveillance and policing measures, and administrative or criminal sanctions. As the national human rights institution, FIRM-IFDH highlights the risks these trends pose to freedom of expression, civic participation, and, more broadly, the space for public debate.
In 2023, the Federal Institute for the Protection and Promotion of Human Rights (FIRM-IFDH) was appointed by the Federal Public Service (FPS) Justice as a focal point in the fight against SLAPPs (Strategic Lawsuits Against Public Participation), following a recommendation from the European Commission. As the anti-SLAPP focal point, FIRM-IFDH will:
FIRM-IFDH is currently developing its new mandate. It collects and disseminates information about SLAPPs and participates in the Belgian Anti-SLAPP Working Group as an observer. It monitors developments in the field to enable it to advise the federal government and federal parliament on the transposition of the European Union Directive into Belgian law.
In 2025, at the request of the Justice Committee of the House of Representatives, FIRM-IFDH issued advice on a draft bill aimed at protecting critical voices against abusive legal proceedings.
Federal Institute for the Protection and Promotion of Human Rights
In June 2021, the Federal Institute for the Protection and Promotion of Human Rights (FIRM-IFDH) commented on three proposed laws aimed at prohibiting the creation and allowing the dissolution of certain groups and organisations formed to incite hatred, violence or discrimination. These proposals were also meant to allow the sanctioning of those who set up, assist, or are members of such organisations. While FIRM-IFDH welcomed the legislator’s continued commitment to combat such organisations, it noted that the current legal framework was sufficient in this regard. It further stressed that alternative sanctions to dissolution were more proportionate and less likely to impact the right of association. FIRM-IFDH also emphasised that any dissolution of an association or a group should be decided by the judiciary, not by the executive.
Ombudsman of the Republic of Bulgaria
The Ombudsman of the Republic of Bulgaria is monitoring the execution of the final European Court of Human Rights judgments in the case of Bozhkov v. Bulgaria. The case relates to the violation of the right to the freedom of expression of journalists (art. 10 ECHR) due to the fact that he reported about alleged corrupt practices. Related to the above, the Ombudsman issued a statement and invited state authorities to address a gap in whistleblower protection and ensure the timely and effective transposition of the EU Whistleblower Directive.
In June 2024, the Danish Institute for Human Rights (DIHR) published a report on the right to freedom of speech and expression and self-censorship (Ytingsfrihed og selvcensur). The report shows that one in 10 Danes (10 %) have refrained from participating in public debate in the physical public space through demonstrations, public meetings, etc. in the past year because of fear of negative reactions. Fear of violence and threats is the reason for self-censorship for one in three (31 %) of those who have refrained from participating in public debate in a physical space in the past year.
The French National Consultative Commission on Human Rights (CNCDH) takes specific actions to protect civil society space and human rights defenders (HRDs), including by issuing recommendations and opinions.
On World Human Rights Defenders’ Day in 2023, CNCDH published its “Opinion on Human Rights Defenders”. This underscored the need for a robust protection framework and the development of a national action plan for HRDs. It also praised HRDs’ essential role in ensuring the effectiveness of human rights.
In September 2025, CNCDH issued a dedicated opinion on civic space. This highlighted ongoing threats to freedom of assembly, rising surveillance of protesters, the stigmatisation of activism, and insufficient consultation with CSOs.
In February 2025, the French National Consultative Commission on Human Rights (CNCDH) adopted a comprehensive opinion titled “Combatting Strategic Lawsuits Against Public Participation (SLAPPs)” (“Lutter contre les procédures bâillons”). This recommended that a broad and protective definition of SLAPPs be included in French law, covering all national cases and including civil and criminal proceedings. It also identified (further) ways to combat SLAPPs from both public and private actors.
In 2023, parliamentary discussions on the draft law on “Transparency of Foreign Influence” commenced in Georgia. From the outset of the legislative process, the Public Defender (Ombudsman) of Georgia (PDO) has strongly criticised the bill, underlining major incompatibilities with international human rights and democratic standards. In this vein, the PDO issued a public statement in 2023 expressing concerns.
After the draft law was initially withdrawn due to major mobilisation by civil society and criticism by international stakeholders, the government launched a large-scale crackdown on protests and a denigratory campaign against civil society organisations (CSOs) and human rights defenders (HRDs).
In 2024, the parliamentary majority reintroduced the aforementioned draft law on “Transparency of Foreign Influence”, and the bill was finally adopted later that year.
In its 2022-2024 parliamentary reports, the PDO maintained that such legislation contradicts fundamental principles of a democratic society and damages civil society and HRDs, as it aim to undermine public trust in them.
The law’s adoption in 2024 was shortly followed by a Ministerial order, that obliged CSOs to register as the entities “pursuing the interests of foreign power.” The NHRI determined that the requirements of the order were unjustified and detrimental as the large-scale
publication of individuals’ personal data further exacerbated the law’s restrictive and stigmatising impact on individuals employed by the affected organisations.
Consequently, the PDO submitted a recommendation to the Ministry of Justice, requesting personal data not to be subject to disclosure. The PDO’s recommendation was partially accepted and implemented. Although names and surnames remain publicly accessible, even this partial implementation has significantly mitigated the negative impact of the regulation on the protection of personal data.
At present, the draft law is being challenged before the Constitutional Court of Georgia, and the Public Defender has submitted an amicus curiae brief in the ongoing proceedings.
Public Defender (Ombudsman) of Georgia
The Public Defender (Ombudsman) of Georgia submitted an amicus curiae brief to the Batumi City Court regarding the internal and social media code of conduct of Adjara TV. The code restricted the freedom of expression of company employees. The NHRI analysed the cases of four employees and established that their dismissal or move to another position contravened Georgia’s Labour Code and Adjara TV’s internal labour regulations. The Public Defender recommended that the Adjara TV director restore the rights of the employees. As this was not done, the NHRI asked the Prosecutor General to launch an investigation. The Public Defender also contacted both the UN Special Rapporteur on the Promotion and Protection of the Right to Freedom of Opinion and Expression and the OSCE Representative on Freedom of the Media in relation to the case.
Public Defender (Ombudsman) of Georgia
The Public Defender (Ombudsman) of Georgia has drawn attention to the challenges and threats faced by human rights defenders and civil society in both Europe and Georgia. The Public Defender dedicated a chapter to this topic in the 2018, 2019 and 2020 annual reports it submitted to parliament. The reports underlined an increasing trend of verbal abuse, physical assaults, intimidation, and defamation, including by high-ranking political officials. Specifically, the reports pointed to challenges faced by women and LGBTI+ defenders and voiced concerns about cyber threats against and the bullying of human rights defenders. The reports analysed the rights of peaceful assembly, association and expression, as well as media freedom. The NHRI called on law enforcement agencies to undertake effective, timely investigations into any cases of human rights defenders at risk. It also provided recommendations to the government on the promotion and protection of human rights defenders.
Commissioner for Fundamental Rights of Hungary
Civil society organisations are not always consulted on draft laws that may impact their activities and work. The Commissioner for Fundamental Rights of Hungary has called on ministries to ensure that civil society organisations can meaningfully participate in and be consulted during the drafting of draft laws and bills relevant to their work and beyond.
Consultative Human Rights Commission of Luxembourg
In 2018, the government of Luxembourg drafted amendments to the law Nº 6961 aimed at strengthening the protection of classified information. This was to be done by incorporating a security clearance system, mainly implemented by the National Safety Authority. In 2019, the Consultative Human Rights Commission of Luxembourg published an opinion on how the draft negatively impacted the right to freedom of expression and access to information, as well as to the protection of personal data. The NHRI expressed concerns that the law does not provide an exception for journalists or whistleblowers who report information about threats or harm to the public interest. The opinion provided recommendations to the government to ensure a human rights compliant revision of the draft legislation, one in which whistleblowers, informants and journalists are sufficiently protected. Additionally, the opinion advised on setting out clear modalities for the collection/use of personal data and avoiding excessive interference with privacy. The opinion took European regulations, European Court of Human Rights case law, and Council of Europe standards into account.
As the authority responsible for ensuring whistleblower protection in Moldova, the People’s Advocate of Moldova created a form for submitting request and alerts on their website. Through this, whistleblowers can liaise with the NHRI on reviewing their case.
The People’s Advocate of the Republic of Moldova closely monitors threats to the right to freedom of expression and freedom of the press, while publishing public statements to support human rights defenders and prevent polarisation within society. In one case, a politician verbally threatened media actors and civil society representatives criticising his political activities and position. In response, the NHRI issued a statement condemning his discourse. This was supported by OHCHR and major human rights organisations in the country. The NHRI also reacted promptly in 2018 when a mayor expressed threatening statements to journalists and in 2020 when government officials attacked the press. It issued statements calling on the national authorities and the General Prosecutor’s Office to investigate.
The activities of human rights defenders and civil society in the Transnistrian region of the Republic of Moldova have been restricted by rules and laws that limit their right to information and ability to express opposition to Transnistrian authorities. Human rights defenders’ freedom of expression was violated in 2020 when defenders were arrested and intimidated. In response, the People’s Advocate of Moldova issued recommendations to Moldovan authorities, mediators and observers. These aimed to make sure these parties applied international law and guaranteed the protection of human rights when designing measures to address the situation.
Protector of Citizens of the Republic of Serbia
The Protector of Citizens of the Republic of Serbia has completed the technical development of a unique platform for registering and tracking harassment and attacks experienced by journalists and others working in the media. Once operational and running, the platform will, help ensure faster and more efficient responses from the competent authorities in the reported cases of violations of media freedom and freedom of expression. It will also provide a broader and more comprehensive overview of the challenges faced by journalists and contribute to enhanced public confidence in state institutions. In 2021, the platform was presented to the Government Working Group for the Safety and Protection of Journalists established in 2020.
In 2024, the Slovak National Centre for Human Rights addressed a letter to the National Council of the Slovak Republic in relation to the amendment proposal to the Act on non-profit organisations (hereinafter “NGO Act”).
In the letter, the Centre shared its considerations on the draft law, including its adoption process, which was carried out without consultations with civil society organisations (CSOs), thus weakening and undermining trust in civil society. At the same time, the draft law portrayed civil society as an enemy and contributed to the restriction of democratic space and the stigmatisation of organisations.
Following widespread criticism, an amendment was presented to the National Council reformulating the original proposal. The new proposed legislation replaced the obligation to register as a ‘foreign-backed organisation’ with an obligation to register for the activity of “lobbying”, targeting non-governmental non-profit organisations only. In response to the new amendments, the Slovak NHRI published an opinion on its website, asking the deputies of the National Council not to support the parliamentary bill.
In addition, ahead of the second parliamentary hearing in March 2025, the Slovak NHRI requested a legal review of the draft law from the OSCE Office for Democratic Institutions and Human Rights (ODIHR).
Shortly before the law was adopted in April 2025, certain provisions were removed, including those relating to ‘lobbying’ activities by non-profit NGOs and to the grounds for dissolution due to non-compliance with the newly introduced requirements.
Nonetheless, ODIHR found that the adopted law still did not meet the strict requirements set by international human rights law to limit the right to freedom of association. It concluded that the law should be fully reviewed.
In Spain, the Organic Law on the Protection of Citizens’ Security was adopted in 2015. The law extends the sanctioning power of the country’s General State Administration and could facilitate inaccurate legal interpretations, leaving things at the discretion of the police. At the same time, it could hinder media freedoms and citizens’ ability to mobilise.
The Ombudsman of Spain has repeatedly asked for its modification. It has made recommendations relating to external body searches on public roads, offences in the context of meetings and demonstrations, and the use of images or data by the police. Recent annual reports of the Ombudsman have advocated the reform of some aspects of this Law, seeking the right balance between security and freedom.