Comment by the Bahrain Forum for Human Rights on Circular No. (13) of 2025 issued by the Ministry of Social Development

Despite the language intended to convey a “positive” approach toward civil organizations, Circular No. (13) of 2025 issued by the Ministry of Social Development imposes a number of administrative restrictions that undermine civil activity and subject it to official political considerations. This creates an atmosphere of anxiety and fear among those working in such organizations, further weakens the role of civil society, and contributes to additional restrictions on freedom of expression.
Moreover, the emphasis on enforcing Decree No. (18) of 1973 concerning public meetings and marches clearly shows that the authorities continue to approach civil activity with a “security permit” mentality rather than as a “civil right” guaranteed under international conventions without limiting conditions.

The requirement of prior coordination with government entities turns civil organizations into administrative units operating under official guardianship. In reality, civil activities should be based on the principle of notification, not prior authorization, in line with international standards on the right to peaceful assembly.
The regulations governing civil work must be aligned with the principles of the UN Declaration on Human Rights Defenders (1998), which guarantees the right to meet and carry out civil activities without arbitrary restrictions, as set out in Articles (1), (5), (6), (12/2), and (13). Likewise, Article (22) of the International Covenant on Civil and Political Rights guarantees the right to freedom of association without arbitrary interference.

Bahrain Forum for Human Rights
11 November, 2025