23rd June 2021

We, representatives of civil society organizations in the country, have followed with interest the entire drafting process of the new draft law “On the registration of non-profit organizations”, expected to be voted in the plenary session on June 24, 2021. This public appeal is part of our continuous engagement and collaborative efforts in this process.

From more than a year, since the draft law was made public by the Ministry of Justice until its approval by the Committee on Legal Affairs, Public Administration and Human Rights, despite the involvement of foreign expertise, the principles and legal framework of public consultation in the Republic of Albania have not been respected. The approach of the institutions has not been inclusive and enabling to bring together all actors in an open discussion about an important draft law for the functioning of the sector. The communication with stakeholders has been non-transparent, undermining their ability for a meaningful and significant contribution.

We assess that major concerns raised and recommendations given with regard to guaranteeing the freedom of association, have not been taken into account and are not reflected in the draft law published by the Albanian Parliament.

This draft law is expected to be voted with no clarity on the financial costs of the establishment and administration of the electronic register. It is also due to the fact that the institutions responsible for the establishment and administration of the register have not expressed any opinion on this issue. The draft law is expected to be approved without a deadline for the establishment and starting date of the register. All the above set ground for questioning the timing and quality of implementation of this legal initiative.

For us, civil society organizations, the draft law seriously violates the freedom of association, the principle of legal clarity, and that of proportionality of coercive measures. The draft law creates overlapping in coercive measures introduced and double reporting requirements with the existing legal framework. As of the above, the draft law contradicts Law 8788, dated 7.5.2001 “On non-profit organizations” and other laws and bylaws that regulate the activity of the sector, as well as international standards in respect of which we believe Albania is backsliding.

We are aware of the importance of the electronic register, not only as a need to address MoneyVal recommendations but above all as a fulfillment of the sector’s longstanding requirement that will enable a proper assessment of the role and impact of its work. Any need to address international obligations by the Albanian state, should not infringe the right of the interest groups to be heard and consulted through an effective process.

In these circumstances, we, the civil society organizations, ask the Albanian Parliament to not approve this draft law and to open a wide and participatory discussion reflecting on the requests and recommendations provided by the sector.

We remain committed to provide our expertise in a redesigned process according to the above principles, but we are also determined to pursue this issue further within the space guaranteed by the national and international legal framework.

(in alphabetical order)

Academy of European Integration and Negotiations– AIEN

ACLI – IPSIA (Albania)

Act for Society

Agrinas Albania Foundation

Agropuka Association

Albanian Association of Italian Language Teachers (A.P.A.D.I)

Albanian Center – YMCA

Albanian Center for Environmental Governance

Albanian Center for Population and Development (ACPD)

Albanian Centre for Economic Research (ACER)

Albanian Coalition for Education (ACE)

Albanian Disability Rights Foundation (ADRF)

Albanian Forum – Shkodra Lake

Albanian Foundation for Local Capacity Development

Albanian Helsinki Committee

Albanian Journalists Union

Albanian National, Professional, Businesswomen and Crafts’ Association

Albanian Organization of the Order of Malta (Malteser Albania)

Albanian Women Empowerment Network – AWEN

AlbContact Center

Alternative Pro

AMARODROM

Antigonea Association – Gjirokastër

ARSIS, Social Organization for Youth Support

Association “Mountain Areas Development Forum”

Association for the Protection of Human Rights

Association of Albanian Municipalities

Association of Paraplegics Shkodra

Association of Persons with Disabilities

Balkan Investigative Reporting Network – BIRN Albania

Beyond Barriers Association

Business Improvement District- Association BID – Berat

Center for Counseling and Psychological Services

Center for Integrated Legal Services and Practices

Center for the Protection of the Rights of the Child in Albania – CRCA

Center for Women’s Roma Rights

CESVI COOPERAZIONE E SVILUPPO – ONLUS – Përmet

Civil Society Development Center – CSDC Shkodra

Community of Pope Giovanni XXIII

Consulting and Development Partners

Contact Art

Co-PLAN, Institute for Habitat Development

COSPE Albania

Council of Social Services Associations of Durrësi district

Counseling Center for People with Disabilities – Shkodra

Counseling Line for Women and Girls

Craftsmen of the North

Diellëza Organization

Different & Equal

Dorcas Aid International Albania

Ecological Club, Elbasan

Environmental Center for Protection, Education and Rehabilitation – (EPER Center)

“Epoka e Re” Youth Center

European Movement Albania – EMA

Faktoje.al Organization

Gender Alliance for Development Center (GADC)

Genesis Center

GO2 Organization for Sustainable Urban Planning

“Gjelbërimi 2000” Association – Vlora

Help the Life Association

Hope for the Future

Hope for the World

Hope for Us – Vlora

Human Dimension Organization

Institute for Development and Civic Initiatives

Institute for Political Studies

Integrimi Association in Tropoja

International Voluntary Projects, PVN

Joscelyn Foundation

Kolping Center

Light Steps Women Centre- Shkodër

“Me, the Woman” Association

Milieukontakt Albania

Missionaries of Social Rights, Kuçovë

Multifunctional Association for Culture, Development and Education

National Association for Integration and Development

National Paraplegic-Tetraplegic Association “Hope and Love”

Natural Resources Development Organization

New Bridges Organization – Berat

No Limits Center

Observatory for Children and Youth Rights

Open Horizon Association

Open Society Foundation for Albania

Opera Madonina del Grappa

Partners Albania for Change and Development

People First Association

Plan & Go Center

Power of Education

Protect Me – Vlore

Psycho-Social Centre “Vatra”

Puka Youth Centre

Ray of Hope Organization

Resource Environmental Center – Albania (REC)

Roma Active Albania

Roma Egyptian Youth Movement

Royal Albania Foundation

SCI – Social Contract Institute

Social Justice Organization

The association “Social Center to Help People in Need” Fushë-Arrëz

The Association “Udhëtim i Lirë – Liberi di Viaggiare”

The Door

The Institute for Democracy and Mediation (IDM)

The Science and Innovation for Development Centre (SCiDEV)

The Women’s Democracy Network Albania (WDN-Albania)

The youth of Ura Vajgurore

Tirana Legal Aid Society (TLAS)

Together for Roma Integration Association (TIRC)

Trainers in Education

Union of Albanian Producers

Useful to Albanian Women

Voice of Roma in Albania

With the Community for Change – Vlora

Woman in Integration

Woman in Progress Association

Women in Progress Shkodra

Women in Progress Tiranë

Women in Public Service Albania Center

Women to Women

YMCA Shkodër

Young Entrepreneurs Club

Young Intellectuals Hope

Youth Center Arka

Youth Voice Network

 YWCA of Albania