Civic Space and Resilient Civil Society in the Mediterranean and its neighbourhood

1. Context and why it matters now

Three developments make a review of civic space in the Mediterranean and its neighbourhood timely in late 2026. First, the CIVICUS Monitor reported in December 2025 that 83 countries and territories were rated closed or repressed, compared with 67 in 2020, and that just over 7% of the world's population lived in countries rated open or narrowed [1]. Second, the funding base of many CSOs has shrunk: the OECD reported preliminary data showing a 23.1% fall in official development assistance in real terms in 2025, which it described as the largest annual drop on record [12], and the UN Special Rapporteur on freedom of peaceful assembly and of association linked threats to these freedoms to the dismantling of global aid and to securitisation [17]. Third, regulation of the non-profit sector is changing in several of the thirteen countries covered here, through new association laws, counter-terrorism financing measures and court rulings, which are described in Section 3.

For the thirteen countries where TIPCS has offices (Tunisia, Algeria, Libya, Egypt, Mauritania, Palestine, Lebanon, Syria, Türkiye, Jordan, Iraq, Kenya and Italy), the question is practical as well as normative. Donors, municipalities and ministries need to know which legal and funding conditions CSOs face, and CSOs need to know which organisational choices are associated with continuity of work under pressure. This paper separates three kinds of statement: documented facts, attributed to their source; interpretations offered by institutions or researchers, which are labelled as such; and the proposal in Section 6, which describes what TIPCS would do and is not evidence.

The paper is a desk review of public sources accessed on 26 October 2026. It takes no position for or against any government, party or policy. Where sources are advocacy organisations (for example Human Rights Watch or ICNL), their statements are attributed to them, and where a government's own position was not found in the sources reviewed, the text says so. Terminology follows United Nations usage, with the CIVICUS Monitor's own country labels noted where they differ (CIVICUS uses 'Occupied Palestinian Territories' and 'Turkey') [2].

2. Standards and what the evidence says

International standards on associations, funding and the enabling environment

The UN Secretary-General's Guidance Note of September 2020 defines civic space as the environment that enables people and groups to participate meaningfully in the political, economic, social and cultural life of their societies, and organises UN action around participation, protection and promotion [18]. The OECD's 2024 Practical Guide for Policymakers builds on its 2022 global report, which drew on 52 OECD and partner countries and set out ten high-level recommendations [19]. For donors, the OECD Development Assistance Committee adopted in July 2021 a Recommendation on Enabling Civil Society in Development Co-operation and Humanitarian Assistance, which ICNL describes as the Committee's first policy instrument on civil society, with 28 principles under three headings: respect, protect and promote civic space; support and engage with civil society; and encourage CSO effectiveness, transparency and accountability [20].

On funding, the key reference text is the 2013 report of the UN Special Rapporteur on the rights to freedom of peaceful assembly and of association, Maina Kiai (A/HRC/23/39). It treats the ability to seek, receive and use resources, whether human, material or financial and from domestic, foreign or international sources, as part of freedom of association. It recommends a notification rather than authorisation regime for forming associations, and it states that associations should be able to access funding without prior authorisation or other undue impediments, with accountability achieved through notification and reporting [6].

The Financial Action Task Force (FATF) is the other major source of constraint and guidance. Its revised Recommendation 8 and Interpretive Note, released on 16 November 2023, require countries to identify the organisations that fall within the FATF definition of non-profit organisations, assess their terrorist financing risk, and apply focused, proportionate, risk-based measures. The FATF states that not all non-profit organisations are high risk, that only a small portion may face a high risk of terrorist financing abuse, and that the revision responds to misapplication of the Recommendation that led some countries to impose disproportionate measures hindering NPOs' operations and access to resources, a problem it began analysing in 2021 [7]. The FATF list of jurisdictions under increased monitoring of 19 June 2026, as reproduced by Guyana's Financial Intelligence Unit, includes four of the thirteen countries covered here: Iraq (newly added), Kenya, Lebanon and Syria [21]. Inclusion on that list concerns national anti-money-laundering and counter-terrorist-financing systems as a whole and does not by itself show how non-profits are treated.

Why restrictions spread: the closing-space literature

Carothers and Brechenmacher's 2014 Carnegie study described restrictive actions against domestic civil society, and against international support for it, as multiplying and intensifying around the world [22]. A 2019 Carnegie follow-up by the same authors dated the closing of civic space to the mid-2000s, cited Freedom House data showing associational and organisational rights eroding in 43 countries between 2006 and 2019 and improving in 16, and judged the international response 'too limited, loosely focused, and reactive' [23]. A quantitative study of 153 low- and middle-income countries for 1993 to 2012 found that 39 adopted laws restricting foreign aid to domestic NGOs. Higher aid flows were associated with a greater probability of such a law, and the association was stronger where elections were competitive, which the authors interpret as governments worrying that funded NGOs may support political opponents [24]. This is an association across countries and does not explain any single case. It does suggest that restrictions on foreign funding are not only a reaction to security concerns and that the way aid is delivered can interact with domestic politics.

What the literature says about resilience

Evidence on what makes CSOs resilient is thinner than the volume of advice suggests. Four sources are used here, all qualitative or based on small samples, and Table 1 summarises them.

Three interpretations follow, each with caveats. First, diversification and networks plausibly work through a simple mechanism, which is that they remove single points of failure, whether a donor, a bank or a registration authority. That is a mechanism, not a demonstrated causal effect. Second, legal literacy has a double function: it helps organisations meet formal requirements that authorities may otherwise use as pretexts, and it supports challenges in court, but the sources report that courts do not always provide relief. Third, studies of organisations that continued to work are subject to survivor bias, since organisations that closed or left are not interviewed. Carnegie's 2019 assessment makes a related point, that emergency funds, adaptation programmes and new coalitions have helped many groups but cannot reverse broader political trends [23].

Donor practices: localisation, the Grand Bargain and flexible funding

The Grand Bargain, launched at the World Humanitarian Summit in Istanbul in May 2016, contains commitments that bear directly on CSO resilience. Aid organisations and donors committed to a global, aggregated target of at least 25% of humanitarian funding going to local and national responders 'as directly as possible' by 2020. They also committed to increase multi-year, collaborative and flexible planning and funding, and donors to an aspirational target of 30% of contributions non-earmarked or softly earmarked by 2020 [14]. The Grand Bargain's 2023 to 2026 framework retains quality funding and localisation among its priorities and lists 66 signatories as of 2023 [26]. The State of the Humanitarian System 2026 reports that only 8.7% of all reported humanitarian flows were directly and indirectly allocated to local and national actors in 2025, down from 9.5% in 2024, with direct funding at 4.3% (3.9% in 2024) [13]. Country-based pooled funds did better, with 46% of 2025 funding reaching local and national actors directly [13].

For civil society outside the humanitarian system, the picture is one of contraction. The IDS review cites an EU survey in which 72% of responding CSOs were directly affected by the 2025 closure of USAID and wider cuts and 40% faced severe budget reductions, and it reports that core and flexible funding were the most valued modalities, with 87% of one fund's grantee networks using core funding for salaries and basic operations [25]. A Tech Global Institute survey cited by a Carnegie commentary found that 71% of organisations in Global Majority countries had to scale back programmes [27]. These are survey results from self-selected samples and should be treated as indicative. The IDS review also records trade-offs: pooled funds lower administrative costs but can produce lowest-common-denominator priorities, and intermediaries can reach hard-to-access groups but may crowd out local actors [25]. A workshop memo summarising experimental studies adds that private donors respond to crackdowns in unpredictable ways: some give more to organisations restricted by their governments, while others give less [11].

3. The regional picture across the 13 countries

Civic space ratings

The CIVICUS Monitor rates 198 countries and territories as open, narrowed, obstructed, repressed or closed, combining data from country-focused civil society organisations, regional research teams, international human rights indices and in-house experts, and assigns each a score from 0 to 100 [28, 1]. In the Monitor's definitions, an 'obstructed' rating means civic space is heavily contested by power holders, a 'repressed' rating means it is significantly constrained, with threats of de-registration and closure for CSOs, and a 'closed' rating means complete closure in law and in practice [29]. Table 2 reproduces the ratings from each country's CIVICUS profile, read on 26 October 2026.

Three readings are possible from the table, and none implies a causal claim. First, ten of the thirteen countries are rated closed or repressed, and the other three are obstructed. Second, ratings have moved in both directions since 2018: Tunisia, Jordan, Kenya, Italy, Iraq and Palestine are rated lower (more restrictive) than their earliest rating in the profile, while Libya (from closed to repressed in the 2023 edition) and Mauritania (from repressed to obstructed in the 2025 edition) are rated higher [2]. Italy's move from narrowed to obstructed was announced with the 2025 report, which also downgraded France, Germany, the United States and Israel [30, 1]. Third, the ratings are composite judgements. They record violations documented by the Monitor's partners, they differ in coverage across countries, and CIVICUS itself reports different counts of countries with documented protester detention in two of its own outputs (at least 76 in the press release and at least 82 on the findings page) [1, 28]. Ratings are best read as one structured source, to be combined with legal analysis.

Legal frameworks for registration and funding

Table 3 summarises the main framework in each country as described by the source indicated, with a focus on how an organisation is formed and how it may receive foreign funds. The descriptions are those of the sources and are not a legal opinion. Cells say so where no verified information was found.

Tunisia: Decree-Law 88 and the changes since 2022

ICNL describes Decree-Law 88 of 2011 as having established one of the most enabling civil society frameworks in the Middle East and North Africa, with broad protection for freedom of association, a prohibition on state interference in CSOs' operations and a right to engage in public affairs. It records about 25,354 NGOs in 2025 [3]. The sources document the following sequence since 2022, which is stated here as reported and not as a finding of this paper.

• February to June 2022. A draft law on associations prepared by the executive was leaked and denounced by Tunisian civil society. On 24 February 2022 President Kais Saied announced an intention to 'prevent foreign funding to associations'. UN experts raised concern in a communication of April 2022, and the government's reply of June 2022 confirmed its intention to amend Decree-Law 88, according to a joint statement by eight rights organisations including Human Rights Watch [4].
• July 2022. A new Constitution was adopted on 25 July 2022; its Article 40 guarantees the freedom to form associations and requires them to adhere in their statutes and activities to the Constitution and the law, to financial transparency and to the rejection of violence [3].
• September 2022. Decree-Law 54 on crimes related to information and communication systems was issued on 13 September. ICNL reports penalties of five years' imprisonment and a fine of 50,000 dinars for spreading false news that harms others' rights, public security or national defence, doubled to ten years where the target is a public official, and notes prosecutions of journalists and activists under it [3]. The UN High Commissioner for Human Rights said in May 2026 that it is being used to criminalise protected speech and encouraged lawmakers to amend it [42].
• October 2023. Ten members of parliament submitted a draft law to replace Decree-Law 88. The eight rights groups said that, as drafted, it would let a department of the Prime Minister's Office deny a group the right to operate within a month of registration (Article 9.2), would require prior approval for national associations to receive foreign funding (Article 18) and would require authorisation from the Foreign Affairs Ministry for international organisations [4].
• 2024 to 2026. ICNL reports that in July 2024 the government was said to be drafting its own replacement, that the parliamentary committee on rights and freedoms met on 30 March 2026 to review the 2023 draft (No. 27/2023) with a focus on foreign funding, and that lawmakers were divided between strengthening oversight and preserving constitutional guarantees [3].
• Practice under the existing decree. ICNL reports that between July and November 2025 authorities suspended or targeted at least 14 CSOs, citing alleged financial irregularities, and that the Human Rights League was suspended in April 2026. Human Rights Watch identified at least 20 suspended associations between July and October 2025 and in April and May 2026, and reported that some did not receive the formal warnings required by law [3, 5]. ICNL also reports that some banks have declined to open accounts for associations since 2019 revisions to the counter-terrorism and anti-money-laundering law [3].

The sources reviewed did not include an official Tunisian statement setting out the rationale for these measures beyond the legislative debate on foreign-funding oversight recorded by ICNL, and this is a limit on the balance of the account. What the sources do show is a gap between a notification-based legal text that remains in force and administrative practice, and a legislative direction toward prior approval of foreign funds that contrasts with the standard in the Special Rapporteur's 2013 report [6, 3].

Egypt: Law 149 of 2019

President Abdel Fattah al-Sisi approved Law 149 of 2019 on regulating the work of civil associations in August 2019, and implementing regulations were issued on 11 January 2021 under Prime Ministerial Decree 104. Human Rights Watch notes that the law removed the prison sentences contained in the previous 2017 law but retained most restrictions, and that the government's own position was that the law 'removed all obstacles' to establishing an organisation, since it allows establishment by notification [34]. ICNL describes the process as burdensome in practice: documentation includes criminal records of founders and proof of a physical headquarters, an association is not legally established until 60 days pass without objection, foreign funds may not be used for 60 days after notification, and associations may not conduct opinion polls, with field research requiring prior approval. It reports more than 35,000 associations registered by the beginning of 2025 [33]. UN experts, in a briefing of 7 September 2021 as reproduced by the Committee for Justice, said the law and bylaws were debated in parliament in one day and that vague terms such as public order, morals and national security could be applied arbitrarily [43]. Egyptian CSOs have, according to the Böll study, filed lawsuits against provisions of the law while engaging in international advocacy [9].

Kenya: from the NGO Coordination Act to the PBO Act

Kenya's Public Benefit Organizations Act took effect on 14 May 2024, more than a decade after enactment, and replaced the NGO Coordination Act of 1990. The PBO Regulatory Authority replaced the NGO Board, NGOs registered under the earlier Act were deemed registered as PBOs and had one year from commencement to re-register, and a PBO Disputes Tribunal was created [15, 40]. ICNL reports 14,687 PBOs and more than 70,000 societies, and no specific legal restriction on receiving foreign funds. It also records that in 2024 the government accused 16 CSOs of using foreign funding to support nationwide protests against the Finance Bill, 2024 and that the Authority forwarded their files to the Directorate of Criminal Investigations. In September 2026 Kenya established a Multi-Agency Coordination Working Group on Non-Profit Organisations at Risk of Terrorism Financing, and ICNL comments that the implications will depend on whether monitoring remains targeted and proportionate [15]. CIVICUS rates Kenya repressed, with a score of 31 [2]. The Kenyan case therefore combines a modernised, comparatively enabling statute with political and security-framed pressure in practice. Kenya also appears on the June 2026 FATF list of jurisdictions under increased monitoring [21].

Türkiye: counter-terrorism financing rules and the courts

ICNL reports 103,008 registered associations and 6,852 foundations in Türkiye in September 2026, of which only 1,528 associations (1.5%) were active in rights and advocacy fields according to the Directorate General for Relations with Civil Society [8]. Law 7262, in force from 31 December 2020 and justified by the need to conform Turkish law to international standards on terrorist financing and money laundering, allowed the Minister of Interior to suspend association board members under prosecution for certain offences. The Constitutional Court annulled several key provisions on 3 April 2024, and the Council of State on 28 May 2025 annulled provisions of a 2021 regulation that classified associations into risk groups, while upholding the principle that audits may be risk-based. Türkiye was grey-listed by the FATF in 2021 and removed in June 2024 [8]. ICNL also reports that a 2024 'agents of influence' bill, which could have exposed organisations with foreign funding to criminal investigation, was shelved at the end of that year, and that the Directorate General of Foundations is preparing amendments to the Law on Foundations to meet FATF recommendations, which ICNL says do not fully comply with FATF standards and threaten over-regulation [8]. The case illustrates a pattern with relevance for the whole region: measures adopted to meet an external standard were tested before domestic courts, and the outcome combined annulment of some powers with continuing reports of burdensome inspections [8].

Italy: a European member state under review

CIVICUS downgraded Italy from narrowed to obstructed in December 2025, citing a security law enacted in June 2025 that introduced new offences and expanded police powers, and the reported use of spyware against critics [30]. A report published by the European Civic Forum in May 2026, written by the Italian association ARCI, states that the government has made no attempt to dissolve CSOs formally, which it attributes to the constitutional guarantee in Article 18, but that legal and administrative measures have been used to restrict their operations, in particular those of sea-rescue organisations under a 2023 decree, and that cases against climate activists often ended in acquittals or dismissals while imposing financial and reputational burdens. It also reports that a measure to revoke the VAT exemption for non-profit associations was postponed by one year after pressure from civil society, and that the European Commission's 2025 Rule of Law Report noted civil society's concerns but made no recommendation to repeal or amend the security law [41]. The sources reviewed for Italy come from civil society and monitoring organisations, and statements by the Italian government were not retrieved, so the account is partial.

The other countries

• Algeria. ICNL reports 108,940 associations (Ministry of the Interior), prior authorisation for international funds, and increasing use of anti-terrorism legislation against peaceful dissidents; on 28 July 2026 the authorities dissolved an independent teachers' union [31].
• Libya. HRW described in June 2021 a 2019 decree that gave the Civil Society Commission authority over registration, funding and activities. UNSMIL and the Berlin Process working group co-chairs raised concerns about it in December 2021, and a joint statement in May 2022 reported that the Tripoli commission had suspended the registration of organisations that had not complied and that the Benghazi commission had issued a re-registration ultimatum [32, 44, 45]. No more recent verified legal analysis was found, and Libya's divided institutions make nationwide statements difficult.
• Mauritania. Law 2021-004 moved from authorisation to declaration for associations [35]. CIVICUS upgraded Mauritania to obstructed in 2025, and its 2026 updates continue to document protest-related arrests [2].
• Lebanon. The 1909 law is relatively liberal, but ICNL reports that CSOs face banking limitations, scrutiny of financial flows and reduced, uncertain funding streams as donor priorities shift [37].
• Jordan. ICNL reports prior approval for foreign funding and for public donations, due diligence obligations with penalties and a cybercrimes law with steep penalties for certain online expression [38].
• Iraq. ICNL records no legal barriers to resources, and notes that the 2026 to 2029 government programme proposes an independent commission for CSOs, a proposal whose effect will depend on implementation [39].
• Palestine. ICNL describes a formally liberal Law No. 1 of 2000, with practical barriers including political interference by both the Palestinian Authority and the de facto authorities in Gaza. It also reports that the Israeli registration framework upheld in May 2026 requires extensive information about staff and activities and allows registration to be denied or revoked on broad grounds, and that Adalah and other CSOs warned it could hinder humanitarian and human rights work [36].
• Syria. Sources describe registration as easier since the political transition of December 2024 but based on political will rather than enforceable rights. Arab Reform Initiative's analysis notes that Article 23 of the March 2025 Constitutional Declaration allows broad restrictions on vague grounds, and Al Jazeera reports that a May framework recognises peaceful assembly as a right while requiring local permission [46, 16]. CIVICUS continues to rate Syria closed with a score of 6 in its 2025 edition [2].

4. Analysis: mechanisms, openings and counter-evidence

Mechanisms of restriction

Across the case notes, four mechanisms recur. The first is administrative discretion within formally liberal texts: Tunisia's notification regime and Palestine's Law No. 1 of 2000 are described as liberal, while practice involves unacknowledged filings, suspensions and inspections [3, 36]. The second is financial gatekeeping through approval or waiting periods for foreign funds (Algeria, Jordan, Egypt, and the Tunisian drafts) or through banks and anti-money-laundering rules (Tunisia, Lebanon) [31, 38, 33, 3, 37]. The third is the framing of oversight in terms of security or counter-terrorism financing, which has a legitimate basis in FATF standards but which the FATF itself says has been misapplied in some countries [7]. The fourth is legitimacy pressure, such as public accusations of 'foreign agendas' reported by ICNL in Tunisia and the shelved 'agents of influence' bill in Türkiye [3, 8]. The cross-national study of aid restrictions suggests that this fourth mechanism is partly political and interacts with competitive elections [24].

Openings

Documented openings are real but limited. Courts have acted as a check in Türkiye, and ARCI reports acquittals in Italian cases [8, 41]. Kenya's PBO Act brought a more enabling statute into force, and Kenya's Public Participation Bill, 2025 was before the Senate in September 2026 [15]. In Syria, registration has risen sharply and the Ministry of Social Affairs and Labour drafted a 2026 to 2028 strategy with civil society involvement, although funding approval and assembly rules remain restrictive and interviewees described a divide between groups aligned with and opposed to the authorities [16]. Iraq's government programme proposes an independent commission, and the FATF's 2023 revision gives CSOs and regulators a common reference for proportionality [39, 7]. Whether these openings last depends on implementation, which the sources do not yet allow to be judged.

Counter-evidence and competing interpretations

Four caveats apply. First, ratings and legal descriptions come largely from civil society monitors and legal research organisations that advocate for civic freedoms, while official positions are often absent from the sources, so a hostile reader may reasonably ask whether the picture is balanced. The paper therefore reports official rationales where found: the Egyptian government's position that Law 149 removed obstacles, the justification of Law 7262 as conformity with international standards, and the debate in Tunisia's parliament about oversight of foreign funding [34, 8, 3]. Second, governments have a legitimate interest in financial transparency and in preventing terrorist financing, and the FATF standard itself requires risk-based measures [7]; the question documented in the sources is proportionality and process, for example whether suspensions follow the warnings that the law requires [5]. Third, the resilience evidence is subject to the limits in Table 1 and the associations reported may reflect organisational size, age or political proximity rather than the factor studied. Fourth, comparing countries as different as Italy and Egypt on one scale requires caution, and the rating moves of a few points can reflect the data available as well as real change.

5. Implications for policy and practice

The following implications follow from the evidence above. They are addressed to named kinds of actors and are framed as options for consideration, not as positions on contested political questions.

• Governments and legislators: align association and funding rules with the notification and reporting standard in the Special Rapporteur's report, publish drafts for consultation, and ensure that suspension or dissolution follows the warning and appeal procedures set out in law [6, 5]. Where counter-terrorism financing measures are adopted, apply the FATF's risk-based approach as revised in 2023 and consult the non-profit sector, as ICNL reports CSOs in Türkiye requested [7, 8].
• FATF-related regulators and financial institutions: distinguish between the small group of non-profits at higher risk and the wider sector, and assess whether bank account refusals for associations, reported in Tunisia and constraints reported in Lebanon, reflect risk or over-compliance [7, 3, 37].
• Donors: assess practice against the DAC Recommendation and the Grand Bargain commitments, and consider multi-year core funding and reduced reporting burdens, which the IDS review and the Böll study identify as the most useful modalities in restrictive contexts [20, 14, 25, 9]. Report publicly on the share of funding that reaches local organisations, since the SOHS figures (8.7% in total and 4.3% direct in 2025) remain far from the 25% commitment [13]. Include risk-sharing for organisations that face administrative or financial investigations.
• Municipalities and local authorities: ICNL reports that municipal councils in Tunisia have been replaced by councils that are not open to CSOs, and that a 2025 law excludes civil society from local affairs. In contexts where local participation channels still exist, such as the public participation provisions under consideration in Kenya, they offer a lower-risk route for CSO engagement [3, 15].
• CSOs: map legal obligations and deadlines (for example the one-year re-registration window under Kenya's PBO Act), diversify income across donors and local sources, join networks that provide shared legal and digital-security services, and document the costs of adaptive strategies such as self-censorship and reduced visibility [40, 25, 9].
• Researchers: test the resilience factors in Table 1 with larger and comparable samples that include organisations that closed, and publish methods so that findings from restrictive contexts can be replicated without exposing respondents [9, 10].

6. What TIPCS proposes

TIPCS is an independent, nonpartisan research, dialogue and training institute headquartered in Monastir, with offices in the thirteen countries covered by this paper and working in English, French and Arabic. It has seven policies in force (code of conduct, safeguarding and PSEA, anti-fraud and anti-corruption, conflict of interest, whistleblowing and complaints, sanctions and due diligence, and research ethics and editorial independence) and publishes its funding. TIPCS proposes three linked workstreams, designed to address the gaps identified in this paper.

Workstream 1: a comparative legal and funding environment tracker

TIPCS would build and publish, under an open licence, a tracker of the legal framework for registration, funding and dissolution in the thirteen countries, coded against the standards in Section 2 and updated twice a year, with a right of reply offered to the relevant ministries and regulators before publication. The research question would be which provisions and administrative practices are associated with differences between formal law and practice. Methods would combine legal text analysis, review of published decisions and reports, and structured interviews with officials, lawyers and CSO staff who consent to take part.

Workstream 2: a resilience study with a comparison group

TIPCS would test whether the factors in Table 1 are associated with continuity of operations after a defined shock, such as a funding loss, a suspension or an audit. The design would draw a sample of CSOs across several countries and sectors, including organisations that have reduced or stopped activity where they consent to be included, and would compare funding diversification, network membership, legal and compliance capacity and digital-security practice, controlling for organisational size and age. Results would be reported with their limits, in particular that association does not establish cause, and the instruments and anonymised data would be published where privacy safeguards allow.

Workstream 3: training in legal and regulatory literacy and donor-practice review

TIPCS would develop, with partner legal organisations, short open training materials in English, French and Arabic on registration, reporting, counter-terrorism financing compliance and the handling of inspections, and would pilot them with volunteer CSOs. In parallel it would review the practices of a small group of donors that agree to take part, against the DAC Recommendation and Grand Bargain commitments, using indicators such as the share of funding that is multi-year and core, reporting burden and time to payment.

Safeguarding, ethics and independence

• The safeguarding and PSEA, research ethics and editorial independence, and whistleblowing and complaints policies would apply to all staff, partners and consultants, with complaint channels in English, French and Arabic.
• Data minimisation and respondent safety: informed consent in the participant's language; no publication of information that could identify an individual or an organisation at risk without explicit consent; secure storage and communication; the right to withdraw at any time; a documented risk assessment for each country before fieldwork.
• Local ethical review where required and an independent advisory group that includes legal specialists and, where possible, representatives of regulators, together with a documented stop rule if participation appears to create risk.
• Independence and neutrality: findings would be reported with attribution to sources, the same standard would be applied to all thirteen countries, official positions would be sought and reported, and TIPCS would publish its funding and conflicts of interest and would not advocate for or against any government, party or candidate.

Partnership model and measurement

TIPCS would seek partnerships with universities, legal-research organisations, CSO networks, municipalities and donors, with roles agreed in writing and shared data governance. Results would be measured against the indicators in Table 4 at baseline, mid-term and end-line with an external evaluator, and published in English, French and Arabic, including findings that do not support the proposal's assumptions.

7. Risks, limitations and what we do not know

• Source balance. Most detailed country accounts come from ICNL, Human Rights Watch and other civil society organisations. Official government positions were found for few countries, and none was retrieved for Tunisia's rationale or for Italy's security law. Secondary reproductions were used for some items, such as UN experts' statements on Egypt and the FATF list of June 2026.
• Currency. Several events are recent and developing (Tunisian suspensions in 2026, Kenya's September 2026 working group, Syria's transition). The most recent verified legal analysis for Libya dates from 2021 to 2022, and no source on Mauritania's rules on foreign funding was found.
• Ratings. CIVICUS ratings are composite and are updated annually, with the latest edition published in December 2025; CIVICUS country updates from 2026 are not yet reflected in the ratings.
• Resilience evidence. The studies reviewed are qualitative with small samples (ten interviews in five countries, four NGOs in Tanzania), and cover mainly human rights and advocacy organisations. They do not establish causation, and they exclude organisations that closed.
• Gaps. No comparable data were found on the number of CSOs that closed in each country, on the share of CSO funding that is domestic, or on the effect of the 2025 aid cuts on organisations in the thirteen countries specifically.
• Proposal risks. Research with CSOs under pressure carries risks of exposure and retaliation, and comparative work can be misread as political; the safeguards above are designed to reduce, not remove, these risks.

8. Conclusion

The public evidence supports a measured conclusion. Civic space is constrained in most of the thirteen countries by the CIVICUS Monitor's assessment, and the documented constraints work less through the text of associations laws than through approval requirements for foreign funds, administrative discretion, financial gatekeeping and counter-terrorism financing rules [2, 3, 7]. International standards give a clear reference for proportionality, and the Türkiye case shows that national courts and standards can narrow measures that go further than required [6, 8]. The literature on resilience points to diversified funding, networks and legal and digital capacity, but the evidence is thin, and donor practice has moved away from the flexible, local and multi-year funding that the studies recommend [9, 25, 13, 12]. What is missing is comparable, independent evidence: coded legal data, data on organisational survival and larger comparative studies. The proposal in Section 6 aims to contribute to that evidence base from within the region, with safeguards that match the sensitivity of the subject.

Method and limits of this brief

This paper is a desk review of public sources accessed on 26 October 2026; it does not draw on primary fieldwork, interviews or non-public data. Legal descriptions rely mainly on ICNL's Civic Freedom Monitor and on reports by human rights organisations, and were not checked against the original legal texts, which are in Arabic, French, Turkish, Italian and other languages. Official positions were retrieved for few countries. Ratings are CIVICUS Monitor composites, and the most recent edition (2025) precedes several events described here. Studies of CSO resilience are small and qualitative, and some sources are secondary reproductions of primary documents. Statements about TIPCS are limited to its institutional profile and to the proposal in Section 6, which describes intended work and not results.

References

1. [1]CIVICUS Monitor (2025). 15 countries downgraded in new ratings report on the state of civic freedoms (press release, People Power Under Attack 2025, 9 December 2025). CIVICUS. https://monitor.civicus.org/press_release/2025/global-press-realease/ (accessed 2026-10-26)
2. [2]CIVICUS Monitor (2026). Country profiles with current rating, score and rating history for Tunisia, Algeria, Libya, Egypt, Mauritania, Palestine (Occupied Palestinian Territories), Lebanon, Syria, Türkiye (Turkey), Jordan, Iraq, Kenya and Italy (pages of the form monitor.civicus.org/country/<name>/, all read on 26 October 2026). CIVICUS. https://monitor.civicus.org/country/tunisia/ (accessed 2026-10-26)
3. [3]International Center for Not-for-Profit Law (2026). Civic Freedom Monitor: Tunisia (last updated 2 August 2026). ICNL. https://www.icnl.org/resources/civic-freedom-monitor/tunisia (accessed 2026-10-26)
4. [4]Human Rights Watch and seven other organisations (2023). Tunisia: Reject Bill Dismantling Civil Society (joint statement, 7 November 2023). Human Rights Watch. https://www.hrw.org/news/2023/11/07/tunisia-reject-bill-dismantling-civil-society (accessed 2026-10-26)
5. [5]Human Rights Watch (2026). Tunisia: Civil Society Under Siege (news release of 2 September 2026 on the report 'We Are Living on Borrowed Time': Repression of Civil Society in Tunisia). Human Rights Watch. https://www.hrw.org/news/2026/09/02/tunisia-civil-society-under-siege (accessed 2026-10-26)
6. [6]Kiai, M., UN Special Rapporteur on the rights to freedom of peaceful assembly and of association (2013). Report to the Human Rights Council, A/HRC/23/39 (24 April 2013). United Nations. https://right-docs.org/doc/a-hrc-23-39 (accessed 2026-10-26)
7. [7]Financial Action Task Force (2023). Protecting non-profits from abuse: implementation of the revised Recommendation 8 (16 November 2023). FATF. https://www.fatf-gafi.org/en/publications/Fatfrecommendations/protecting-non-profits-abuse-implementation-R8.html (accessed 2026-10-26)
8. [8]International Center for Not-for-Profit Law (2026). Civic Freedom Monitor: Türkiye (last updated 10 September 2026). ICNL. https://www.icnl.org/resources/civic-freedom-monitor/turkiye (accessed 2026-10-26)
9. [9]Saliba, I. (2025). Resilience support for CSOs in the WANA region (study of Tunisia, Jordan, Iraq, Egypt and Lebanon, 25 June 2025). Heinrich Böll Stiftung, Beirut. https://lb.boell.org/sites/default/files/2025-10/resilience-support-for-csos-in-the-wana-region.pdf (accessed 2026-10-26)
10. [10]Rugeiyamu, R. and Nguyahambi, A. M. (2024). Advocacy non-governmental organizations (NGOs) resiliency to shrinking civic space in Tanzania. Journal of Humanities and Applied Social Sciences 6(3), pp. 258-279. Emerald. https://www.emerald.com/jhass/article/6/3/258/1225765/Advocacy-non-governmental-organizations-NGOs (accessed 2026-10-26)
11. [11]Programmatic Flexibility and Private Funding: How INGOs Navigate Closing Civic Space (2025). Workshop memo for the Carnegie closing space workshop, November 2025, hosted at stats.andrewheiss.com; summarises studies by Chaudhry, Heiss and co-authors. https://stats.andrewheiss.com/2025-11_carnegie-closing-space-workshop/ (accessed 2026-10-26)
12. [12]OECD (2026). International aid fell sharply in 2025, says OECD (press release, April 2026, on preliminary official development assistance data). OECD. https://www.oecd.org/en/about/news/press-releases/2026/04/international-aid-fell-sharply-in-2025-says-oecd.html (accessed 2026-10-26)
13. [13]ALNAP (2026). The State of the Humanitarian System 2026, chapter 4.1: Funding pathways and the politics behind the numbers. ALNAP. https://alnap.org/help-library/resources/sohs-2026/chapter-4-power-imbalances-and-improving-accountability/4-1-funding-pathways-and-the-politics-behind-the-numbers/ (accessed 2026-10-26)
14. [14]Grand Bargain signatories (2016). The Grand Bargain: A Shared Commitment to Better Serve People in Need (22 May 2016), sections 2, 7 and 8. World Humanitarian Summit, Istanbul. https://gblocalisation.ifrc.org/wp-content/uploads/2018/06/grand_bargain_final_22_may_final-2_0.pdf (accessed 2026-10-26)
15. [15]International Center for Not-for-Profit Law (2026). Civic Freedom Monitor: Kenya (last updated 16 October 2026). ICNL. https://www.icnl.org/resources/civic-freedom-monitor/kenya (accessed 2026-10-26)
16. [16]Al Jazeera (2026). Syria's civil society navigates post-Assad era: partnership or control? (20 August 2026). https://www.aljazeera.com/features/2026/8/20/syrias-civil-society-navigates-post-assad-era-partnership-or-control (accessed 2026-10-26)
17. [17]Romero, G., UN Special Rapporteur on the rights to freedom of peaceful assembly and of association (2025). Collective action and human solidarity facing an existential threat, A/80/219 (14 November 2025); as summarised by the International Drug Policy Consortium. https://idpc.net/publications/2025/11/report-of-the-special-rapporteur-collective-action-and-human-solidarity-facing-an-existential (accessed 2026-10-26)
18. [18]United Nations (2020). United Nations Guidance Note: Protection and Promotion of Civic Space (September 2020). United Nations. https://www.lrwc.org/wp-content/uploads/2020/12/UN_Guidance_Note.pdf (accessed 2026-10-26)
19. [19]OECD (2024). Practical Guide for Policymakers on Protecting and Promoting Civic Space (19 November 2024). OECD Public Governance Reviews, OECD Publishing. https://www.oecd.org/en/publications/practical-guide-for-policymakers-on-protecting-and-promoting-civic-space_6c908b48-en.html (accessed 2026-10-26)
20. [20]International Center for Not-for-Profit Law (2021). What can donor countries do to expand civic space? (analysis of the OECD DAC Recommendation on Enabling Civil Society in Development Co-operation and Humanitarian Assistance, July 2021). ICNL. https://www.icnl.org/post/analysis/what-can-donor-countries-do-to-expand-civic-space (accessed 2026-10-26)
21. [21]Financial Intelligence Unit, Guyana (2026). Circular No. 3: Jurisdictions under Increased Monitoring, 19 June 2026 (reproducing the FATF list). https://fiu.gov.gy/wp-content/uploads/2026/06/Circular-No.-3-2026-FATF-Grey-List-June-19-2026.pdf (accessed 2026-10-26)
22. [22]Carothers, T. and Brechenmacher, S. (2014). Closing Space: Democracy and Human Rights Support Under Fire. Carnegie Endowment for International Peace (event page). https://carnegieendowment.org/events/2014/04/closing-space-democracy-and-human-rights-support-under-fire?lang=en (accessed 2026-10-26)
23. [23]Brechenmacher, S. and Carothers, T. (2019). Defending Civic Space: Is the International Community Stuck? Carnegie Endowment for International Peace. https://carnegieendowment.org/research/2019/10/defending-civic-space-is-the-international-community-stuck (accessed 2026-10-26)
24. [24]Dupuy, K., Ron, J. and Prakash, A. (2016). Hands off my regime! Governments' restrictions on foreign aid to non-governmental organizations in poor and middle-income countries. World Development 84, pp. 299-311. https://ideas.repec.org/a/eee/wdevel/v84y2016icp299-311.html (accessed 2026-10-26)
25. [25]Institute of Development Studies (2026). How can external funders better support civil society networks? (opinion piece of 21 April 2026, drawing on the IDS-led K4DD review). https://www.ids.ac.uk/opinions/how-can-external-funders-better-support-civil-society-networks/ (accessed 2026-10-26)
26. [26]Inter-Agency Standing Committee (2023). Grand Bargain 2023-2026 (one-pager). IASC. https://interagencystandingcommittee.org/sites/default/files/migrated/2023-10/One%20Pager%20Grand%20Bargain%202023-2026.pdf (accessed 2026-10-26)
27. [27]Sesan, G. (2025). Shrinking Civic Space, Digital Funding, and Legitimacy in a Post-Truth Era (17 July 2025). Carnegie Endowment for International Peace. https://carnegieendowment.org/research/2025/07/shrinking-civic-space-digital-funding-and-legitimacy-in-a-post-truth-era?lang=en (accessed 2026-10-26)
28. [28]CIVICUS Monitor (2025). Global Findings 2025: People Power Under Attack 2025. CIVICUS. https://monitor.civicus.org/globalfindings_2025 (accessed 2026-10-26)
29. [29]CIVICUS Monitor (2025). How it works: Ratings (definitions of open, narrowed, obstructed, repressed and closed). CIVICUS. https://monitor.civicus.org/about/how-it-works/ratings/ (accessed 2026-10-26)
30. [30]CIVICUS Monitor (2025). Italy downgraded to 'Obstructed' (press release on People Power Under Attack 2025). CIVICUS. https://monitor.civicus.org/press_release/2025/italy/ (accessed 2026-10-26)
31. [31]International Center for Not-for-Profit Law (2026). Civic Freedom Monitor: Algeria (last updated 1 September 2026). ICNL. https://www.icnl.org/resources/civic-freedom-monitor/algeria (accessed 2026-10-26)
32. [32]Human Rights Watch (2021). Libya: Draconian Decree Would Restrict Civic Groups (4 June 2021). Human Rights Watch. https://www.hrw.org/news/2021/06/04/libya-draconian-decree-would-restrict-civic-groups (accessed 2026-10-26)
33. [33]International Center for Not-for-Profit Law (2026). Civic Freedom Monitor: Egypt. ICNL. https://www.icnl.org/resources/civic-freedom-monitor/egypt (accessed 2026-10-26)
34. [34]Human Rights Watch (2021). Egypt: Restrictions on Civic Work Underscored (16 April 2021). Human Rights Watch. https://www.hrw.org/news/2021/04/16/egypt-restrictions-civic-work-underscored (accessed 2026-10-26)
35. [35]Lextenso (2022). Mauritanie: la loi sur les associations, fondations et reseaux fait peau neuve (Law No. 2021-004 of 10 February 2021). L'essentiel Droits africains des affaires, 2022 n.3. https://www.labase-lextenso.fr/l-essentiel-droits-africains-des-affaires/2022-n3/mauritanie-la-loi-sur-les-associations-fondations-et-reseaux-fait-peau-neuve-DAA200r5 (accessed 2026-10-26)
36. [36]International Center for Not-for-Profit Law (2026). Civic Freedom Monitor: Palestine (last updated 25 August 2026). ICNL. https://www.icnl.org/resources/civic-freedom-monitor/palestine (accessed 2026-10-26)
37. [37]International Center for Not-for-Profit Law (2026). Civic Freedom Monitor: Lebanon (last updated 20 May 2026). ICNL. https://www.icnl.org/resources/civic-freedom-monitor/lebanon (accessed 2026-10-26)
38. [38]International Center for Not-for-Profit Law (2026). Civic Freedom Monitor: Jordan (last updated 29 July 2026). ICNL. https://www.icnl.org/resources/civic-freedom-monitor/jordan (accessed 2026-10-26)
39. [39]International Center for Not-for-Profit Law (2026). Civic Freedom Monitor: Iraq (last updated 23 June 2026). ICNL. https://www.icnl.org/resources/civic-freedom-monitor/iraq (accessed 2026-10-26)
40. [40]DLA Piper Africa (2024). The Public Benefits Organisation Act, 2013 finally comes into effect (Kenya). https://www.dlapiperafrica.com/en/kenya/insights/2024/the-public-benefits-organisation-act-2013-finally-comes-into-effect (accessed 2026-10-26)
41. [41]Arci, in European Civic Forum (2026). Civic Space Report 2026: Italy (May 2026). European Civic Forum. https://civicspacewatch.eu/wp-content/uploads/2026/05/Civic-Space-Report-2026-Italy-European-Civic-Forum.pdf (accessed 2026-10-26)
42. [42]Office of the UN High Commissioner for Human Rights (2026). Türk calls on Tunisia to end repressive measures against civil society and media (7 May 2026), as reproduced by ecoi.net. https://www.ecoi.net/de/dokument/2140390.html (accessed 2026-10-26)
43. [43]Committee for Justice (2021). UN concerned about Egypt's NGO law, calls for societal dialogue (reproducing a UN experts' briefing in Geneva, 7 September 2021). https://www.cfjustice.org/un-concerned-about-egypts-ngo-law-calls-for-societal-dialogue (accessed 2026-10-26)
44. [44]UNSMIL and the Netherlands and Switzerland, co-chairs of the Berlin Process Working Group on International Humanitarian Law and Human Rights (2021). Statement on Human Rights Day (10 December 2021). United Nations Support Mission in Libya. https://unsmil.unmissions.org/en/node/56094 (accessed 2026-10-26)
45. [45]Cairo Institute for Human Rights Studies with AfricanDefenders, Article 19, CIVICUS and EuroMed Rights (2022). Libya: Authorities in East and West Unite in Imposing Crackdown on Civil and Political Freedoms (joint statement, 12 May 2022). https://cihrs.org/libya-authorities-in-east-and-west-unite-in-imposing-crackdown-on-civil-and-political-freedoms/?lang=en (accessed 2026-10-26)
46. [46]Haid, H. (2025). Syria's Expanding but Fragile Civic Space: Opportunities and Risks in the Post-Assad Transition (4 December 2025). Arab Reform Initiative. https://www.arab-reform.net/publication/syrias-expanding-but-fragile-civic-space/ (accessed 2026-10-26)

How to cite

Tunisian Institute for Peace and Conflict Studies (TIPCS) (2026). Civic Space and Resilient Civil Society in the Mediterranean and its neighbourhood. Monastir: TIPCS. www.tipcs.org/publications/civic-space-resilient-civil-society