Source: www.forum18.org
Date: February 25, 2025
https://www.forum18.org/archiv
By Mushfig Bayram, Forum 18, and John Kinahan, Forum 18
Freedom of religion and belief (FoRB) and related human rights issues in
Kyrgyzstan include but are not limited to: state control and repression of
the majority Islamic community; a 2025 Religion Law which among many other
violations continues to ban exercise of freedom of religion or belief with
others without state permission and denies communities without 500 adult
citizens from being allowed to exist; jailing and fining critics of the
regime's freedom of religion or belief violations; failures to bring the
perpetrators of violent attacks to justice; the continued banning of the
Ahmadi Muslim community, and continued arbitrary refusals to grant
registration to communities seeking state permission to exist; regime
denials that legally-binding international obligations are legally-binding;
and raids on religious communities.
Context
Kyrgyzstan has the fourth largest surface area of the five Central Asia
countries. Regime statistics indicate that it has around 6 million people,
the fourth largest population of the five countries. They also state that
over 70 per cent of the population are ethnic Kyrgyz and around 15 per cent
ethnic Uzbeks (popularly regarded as being of mostly Sunni Muslim
background), with significantly smaller percentages of Russians (popularly
regarded as being of Russian Orthodox or other Christian background) and
other ethnicities. Around three per cent of the population are thought to
be of other religious backgrounds.
Violations of interlinked human rights such as freedom of expression and
freedom of religion and belief
(https://www.forum18.org/archi
years, as documented by human rights defenders such as Kylym Shamy
(https://www.ksh.kg/) and Human Rights Watch
(https://www.hrw.org/europe/ce
Human Rights Watch described the regime as "relentless in its crackdown on
civil and political rights"
(https://www.hrw.org/news/2024
Repression of the majority Islamic community
The regime-controlled Muslim Board (Muftiate) controls all public
expressions of Islam. Such controls on Muslims exercising freedom of
religion or belief can be highly repressive. In July and August 2023 the
National Security Committee (NSC) secret police closed 39 mosques and 21
religious schools in Osh Region using excuses such as allegedly not having
official registration and violating sanitary norms. The raid was part of a
nationwide pattern of raids on mosques and madrassahs followed by forced
closures for varying periods of time.
The regime appears to have also targeted other religious communities in the
context of its increasing repression of any exercise of human rights,
including Catholic, Protestant, and Hare Krishna communities.
Janybek Dosmambetov, Deputy Prosecutor of Kara-Suu District, told Forum 18
that Osh Prosecutor's Office ordered raids on and closures of mosques and
madrassahs in the region as: "Some of them violated sanitary norms, did not
have registration, and violated other legal norms."
In one example, on 21 July 2023 officials raided and closed Kara-Suu
District's Al-Sarakhsi Mosque. The officials were from the NSC secret
police, the Interior Ministry, the Regional and District Police, the
Emergency Situations Ministry, the State Sanitary and Epidemiological
Service, Kara-Suu District Architecture Department, Kara-Suu District Land
Cadastre, the State Commission for Religious Affairs (SCRA), and the
state-controlled Muslim Board including its Osh District representative
(qazi).
Some mosques and madrassahs, though not Al-Sarakhsi Mosque, are still
closed. One day later the mosque was suddenly reopened after a video
protest (see below). Regime officials denied this protest was the reason,
but could not explain why they reopened the mosque.
Jailing regime critics
The regime of Sadyr Japarov targets people who publicly criticise its
policies and actions. Three Muslim men (Asadullo Madraimov, Mamirjan
Tashmatov, and Mahamatayubhon Mashrapov, all members of the Al-Sarakhsi
Mosque community) posted a video online on 27 July 2023 protesting against
the closures. They observed that the mosque "was not closed even in Soviet
times, and there is no excuse for its closure". The video dismissed as
"absurd" the regime's claim that the mosque had no running water, noting
that Muslims can on religious grounds use dust for the cleansing ritual if
water is not available.
Police arrested Madraimov, Tashmatov, and Mashrapov after their protest,
and they were questioned, required to write a written statement, and then
released. The regime then began to prepare criminal cases against them. On
18 August 2023, Justice Ministry "experts" Shekerbek Berdibek uuly and
Almaz Kulmatov produced an "expert analysis" (which Forum 18 has seen). The
"expert analysis" states that the video discredited the authorities'
actions by saying that "law-enforcement agencies interfered in mosque
matters and acted against Muslims".
Kulmatov of the Judicial Expert Analysis Centre refused in March 2024 to
explain to Forum 18 why he and his colleagues' "expert analysis" of
Madraimov's comments described them as "extremist". When Forum 18 asked
what, for example, was "extremist" in Madraimov's factual comment that
"even during Communist times the Al-Sarakhsi Mosque was not closed",
Kulmatov would not explain his claim.
Police Senior Lieutenant Edilbek Japarov claimed to Forum 18 that the video
was made for "illegal dissemination" and "constitutes inciting religious
hatred". He refused to explain why he made these claims, even when Forum 18
pointed out that the Justice Ministry "expert analysis" does not specify
who the alleged "hatred" was incited against. He also refused to explain
why criticising the regime – which is not a religious group – is
"illegal" and is "inciting religious hatred".
Colonel Urmatbek Jumabekov, head of the Interior Ministry's "Department for
the Struggle against Extremism and Illegal Migration", also refused to
explain to Forum 18 why the criminal cases were opened against Madraimov,
Tashmatov, and Mashrapov.
Deputy Prosecutor Dosmambetov claimed to Forum 18 that the three Muslims
were arrested and detained as "they are extremists". When Forum 18 asked
what exactly the "extremism" was, he replied: "You do not know the details
of the case, and I will not tell you."
On 18 October 2023, Madraimov, Tashmatov, and Mashrapov were arrested. On
26 February 2024, prisoners of conscience Madraimov and Tashmatov were
jailed for three years and two years respectively. In a separate hearing in
January 2024 the third protestor, Mahamatayubhon Mashrapov, was fined
100,000 Soms (about five months' average wage for those in formal work).
On 13 May 2024, the jail sentences were halved on appeal and Tashmatov was
freed in the court room as he had served his full sentence. However, on 28
October the Supreme Court restored the three-year jail term for 36-year-old
Muslim prisoner of conscience Madraimov.
In another example of targeting people who publicly protest against the
regime, in August 2022 a Protestant, Aytbek Tynaliyev, who on social media
commented on religious topics and on the President was fined the equivalent
to eight months' average wage. In July 2023, a court in the northern Chuy
Region jailed him for six months for "inciting religious enmity" for social
media posts sharing his faith and questioning the regime's religious
policy.
"I was critical of the 2022 Presidential Decree where slaughtering of many
cows and lambs during funerals or other religious ceremonies was not
recommended," Tynaliyev explained to Forum 18. "And therefore knowing that
in Islam they pray for the dead from the Koran, and wondering why those who
come to the funeral can pray for the dead person but the authorities think
that it is not normal to eat a good meal at the funeral, I asked the
question. Why must the authorities regulate our faith, our traditions?"
Neither Prosecutor Kaliya Rysbek kyzy, nor the two Justice Ministry
religious "experts", who supported the prosecution case against Tynaliyev
in court, would explain to Forum 18 why the prosecution was brought.
Violence and regime collusion
Violent attacks against non-Muslims in regions outside the capital Bishkek
have continued, local Protestants have told Forum 18. The treatment of the
perpetrators of violent attacks on people and communities exercising their
freedom of religion and belief is in stark contrast to the regime's swift
arrests and jailings of critics of its actions.
Officials have repeatedly refused to explain to Forum 18 why perpetrators
are not prosecuted and punished, and what is being done to stop such
attacks. When such attacks happen, Protestants stated, "local believers are
afraid to complain to the authorities" as "they are afraid of reprisals
from the authorities and local mobs for complaining".
These attacks include "concrete threats by mobs in regions nationwide to
forcibly convert ethnic Kyrgyz Christians to Islam", a Protestant who
wished to remain anonymous for fear of state reprisals stated. In one such
case, a mob threatened ethnic Kyrgyz Christians that they would be driven
out of their homes if they did not convert to Islam. Protestants told Forum
18 that the local authorities "calmed down the mob members and made the two
sides make peace", but officials brought no prosecutions against the
perpetrators.
Zamir Tursunbekov of the Presidential Administration, who is responsible
for religious affairs, and Kanatbek Midin uuly, Deputy Director of the
State Commission for Religious Affairs (SCRA), both refused to explain to
Forum 18 why the regime does not punish the perpetrators of violent attacks
on non-Muslims.
Smaller vulnerable communities often experience problems in carrying out
burials in their own way, and in accordance with the wishes of relatives
and the deceased. Relatives and friends who want to bury their dead with
non-Muslim rites are frequently afraid to publicly discuss such problems,
for fear of reprisals and mob violence aided by regime officials' lack of
willingness to defend people's human rights. Some non-Muslims have been
forced to convert to Islam to bury their dead. In other cases,
state-appointed Muslim clergy and state officials have prevented non-Muslim
families from burying their dead in local authority-controlled cemeteries.
Repressive 2025 Religion Law and Amending Law
A 2025 Religion Law replaced the 2008 Religion Law and subsequent
amendments. An associated new Amending Law in the Area of Religion changes
the 2021 Violations Code, the Political Parties Law, the Laws on Elections
of and Status of Deputies of Local Keneshes [administrations], and the Law
on Status of Deputies of the Zhogorku Kenesh. The 2025 Religion Law came
into force on 1 February 2025, and the Amending Law days later. The regime
published the text of the new laws only as they went into force.
Both drafts were prepared at the regime's initiative by the State
Commission for Religious Affairs (SCRA), the National Security Committee
(NSC) secret police, and the Interior Ministry. Religious communities, who
also wished to remain anonymous for fear of state reprisals, told Forum 18
that neither the SCRA nor other regime officials had informed or consulted
them on the proposed new Laws.
The justification for the then draft Religion Law – signed by SCRA Chair
Azamat Yusupov - claims that its objective "is to improve the legislative
framework, fulfil the international obligations of the Kyrgyz Republic, and
ensure continuity and consistency of state policy in the religious sphere".
He also falsely claimed that adopting the 2025 Religion Law would have "no
negative social, economic, legal, human rights, gender, ecological, or
corruption consequences".
The Religion Law seriously violates Kyrgyzstan's legally binding
international human rights obligations, such as those outlined in the OSCE
/ Council of Europe Venice Commission Guidelines on the Legal Personality
of Religious or Belief Communities
(https://www.osce.org/files/f/
Freedom of Religion or Belief and Security: Policy Guidance
(https://www.osce.org/files/f/
The new Amending Law's changes to the Violations Code increase the
punishable scope of the exercise of freedom of religion or belief, and
sharply increase fines.
A Foreign Agents Law signed into law in April 2024 does not ostensibly
apply to religious organisations, but members of some religious communities
expressed their fears. "The government can twist any law to use against us
arbitrarily," one told Forum 18.
"Illegal" exercise of freedom of religion or belief
Article 8, Part 3 of the 2025 Religion Law continues to make the
unregistered exercise of freedom of religion or belief illegal and
punishable, specifying that the exercise of this freedom without SCRA
registration is illegal and punishable under the Violations Code.
Religion Law Article 24 specifies that the activity of registered religious
organisations "is forcibly terminated by court decision in cases of the
systematic violations of the norms of the Constitution, this Law or other
Laws or in cases of the systematic carrying out of activity contradicting
the aims in the Statute". Such a decision makes any activity by the
liquidated religious community illegal and punishable.
The Amending Law's changes to the Violations Code rewords the provision in
Violations Code Article 142 to punish those who exercise freedom of
religion or belief or use a place of worship without state permission with
a fine of 200 Financial Indicators (FIs) on individuals (20,000 Soms,
equivalent to three weeks' average wage) and 650 FIs on organisations. The
Violations Code allows the police and the SCRA to issue summary fines for
violating Article 142.
"Impossibly high" registration requirements
Article 9 of the 2025 Religion Law specifies two forms of legal religious
organisations:
- local religious organisations, which can function only in the
administrative territory where they are registered, and require at least
500 adult citizen founders living in a single Region of the country. (The
2008 Religion Law required 200 adult founders living anywhere in the
country.);
- and central spiritual administrations.
Under Article 23, those with criminal records are not allowed to act as a
founder or religious community leader.
Many smaller religious communities of a range of beliefs have not sought
state registration as they are, as one told Forum 18 in July 2023, "afraid
of state reprisals for themselves as communities as well as their members".
They fear that if regime agencies are given – as is required – the
personal details of founders this will lead to state surveillance of their
private lives, and possible later targeting by regime agencies.
"Many people will not want to identify themselves to the regime as founders
of a religious community," a human rights defender, who wished to remain
anonymous for fear of state reprisals, told Forum 18 in December 2024.
"Setting the impossibly high threshold of 500 signatory founders living in
the same district will seriously limit the number of religious communities,
and denies the reality that we are a multi-confessional society."
The human rights defender added: "Many religious communities will not be
able to collect the 500 signatures, and will run into trouble with the
authorities for exercising their constitutional right to freedom of
religion or belief without state permission." They observed that, as a
result, "members of communities will not be able to meet to read religious
texts or pray and worship together. They also will not be able carry out
charitable or other activities."
Various smaller religious communities, who all wished to remain anonymous
for fear of state reprisals, told Forum 18 in December 2024 that "it is
obvious that the draft Law is aiming to push various smaller religious
communities into unions of so-called ‘central spiritual administrations',
which will make it easier for the regime to control individual religious
communities and their clergy".
Article 9, Part 5 of the 2025 Religion Law requires all the founders of any
religious organisation to be personally present at a meeting that formally
founds the organisation and chooses its leadership. All participants have
to vote unanimously to found the organisation. A simple majority of votes
is required to choose the leaders. It remains unclear what would prevent an
individual who did not want a specific religious organisation to exist –
for example a regime official - from attending a founding meeting, and
voting against its founding.
Under Article 9, Part 10, a religious community's application requires a
full list of all the founders. It appears that would have to list their
full names and passport details. This list has to be legally notarised.
It appears that when - for example - a local religious community gathers
500 adult citizens living locally, and they unanimously agree to found a
religious organisation, and submit an application and associated
documentation. If the SCRA thinks that any of the 500 is ineligible, the
local religious community's application is to be rejected. The religious
community would then have to start the whole procedure again by calling a
new founders' meeting and preparing a new application.
Article 21, Part 4 allows the religious community to appeal against a SCRA
rejection after the application and associated documents have been returned
to the community. The appeal must be made in accordance with the law on
administrative procedures.
Under Article 9, Part 10, religious communities applying for registration
have to include with their application a document with "information about
the basics of the doctrine and the practice corresponding to it, including
the history of its origin, the forms and methods of its activities, the
attitude towards family and marriage, education, the peculiarities of the
attitude towards the health of followers of the given religion, and
restrictions for members and servants of the organisation regarding civil
rights and obligations".
Religious communities also have to include documentary evidence that they
have a suitable venue, which cannot be a residential address, with all
documentation related to the venue's purchase or rental.
Article 10, Part 3 of the 2025 Religion Law requires religious
organisations to include in their statute "the territories in which the
religious organisation carries out its activity".
Under Article 21, the SCRA has 30 days to consider registration
applications. The SCRA checks "the veracity of information and accordance
with the current Law" of the application and associated documents. The SCRA
would be allowed an extra 30 days if it considers it necessary to get an
"expert analysis" on undefined "controversial issues".
Article 21 specifies that, "in cases of necessity", the SCRA has the right
to seek extra information or to forward the applicant's documents to the
"appropriate state agencies" (unspecified). These would probably be the
Interior Ministry and the NSC secret police.
Article 21 allows the SCRA to reject applications if an "expert analysis"
finds a "failure to abide by the demands of legislation on countering
extremist activity".
The NSC secret police already blocks registration applications, attempts to
ban religious communities (such as Jehovah's Witnesses), and has been
responsible for the banning of Ahmadi Muslims.
Regime "expert analyses" of religious materials and religious communities'
beliefs have been used to justify regime human rights violations, such as
censoring and banning films and texts officials dislike, attempting to ban
an entire religious community, and in August 2023 jailing a Protestant for
six months for questioning regime policy on freedom of religion or belief.
Article 9, Part 9 allows individuals to check in advance with the SCRA if a
proposed name for a religious organisation would be suitable.
Under Article 18, Part 1 a registered religious organisation is required to
re-register (under the full requirements imposed for registration) in the
case of reorganisation, a change of name, amendments to the statute, or if
a court ordered re-registration. They are also required to re-register when
the 10-year validity of their registration certificate runs out.
Repeated denials of state registration, raids
Many religious communities have for many years been repeatedly denied state
registration. The Hare Krishna community in Bishkek, for example, has been
trying for years to gain state registration, and in 2009 various regime
officials told it of a "secret instruction" to block its registration
attempts. The Hare Krishna community met the SCRA on 24 July 2023, and was
told that it must fulfil the Religion Law's (then) requirements for 200
adult founders and other necessary documents.
However, "many members are afraid to give their signatures, names and other
details to state agencies as they fear state reprisals", human rights
defender Erzhan Kayipov told Forum 18. "This puts the community in a very
awkward situation, outside the law and vulnerable to punishment by the
state at any time and in any circumstances."
On 11 June 2023, officials of the Interior Ministry, police "Department for
the Struggle against Extremism and Illegal Migration," and the SCRA raided
the wedding rehearsal of a Hare Krishna couple. This was taking place in
the flat of another Hare Krishna devotee. The devotee was fined just over
two weeks' average wage, and about 10 Indian students present had their
student visas cancelled and were deported.
Similarly, in November 2024 the NSC secret police, ordinary police, and
SCRA officials raided a public event with an international guest speaker
arranged by members of Bishkek's Hare Krishna community. The NSC secret
police said that attendees were "lectured about cleansing of
self-consciousness and psychological courses on self-improvement". However,
the NSC claimed, attendees "were not informed that the event is of a
religious nature".
"The International Society for Krishna Consciousness, which is a sect, was
involved in illegal religious activity," the NSC secret police also
claimed. The NSC said it is running "a campaign of operational-search
measures to prevent illegally operating religious sects and organisations
in the territory of Bishkek City." In the course of this, it "identified
and halted the illegal activity of the Hare Krishna community".
The SCRA and the ordinary police then drew up reports of an offence against
16 members of the Hare Krishna community, and each was fined two weeks'
average wage. The NSC then publicly urged "citizens to be on guard not to
participate in commercial courses of such pseudo-psychologists in order to
prevent the activity of sects".
Similarly, on 25 June 2024, the NSC secret police and ordinary police
"Department for the Struggle against Extremism and Illegal Migration"
officers raided a meeting of more than 100 young people from Protestant
churches around Central Asia. It appears that the ordinary police and the
NSC secret police already knew from informers among the participants that
the conference was taking place, Protestants told Forum 18. Regime
officials also had photos of the conference which some participants had
apparently shared with them.
Police claimed that an "illegal" religious meeting was taking place, and
detained and questioned five conference leaders for nine hours The NSC
secret police announced that it had "halted the religious-propaganda
activity of adepts of the Word of God religious movement". Three leaders
were fined two weeks' average wage and deported.
Communities seeking registration have long found that decisions are
arbitrary. An association of the Falun Gong spiritual movement was
registered in July 2004, but - under Chinese pressure - was liquidated as
"extremist" in February 2005. On 26 January 2018 the Chui-Bishkek Justice
Department in the capital Bishkek registered a Falun Gong association.
However, on 20 March 2018, less than eight weeks later, the Justice
Department issued a decree cancelling the registration, according to the
Justice Ministry register of legal entities.
In a similar arbitrary decision, officials banned Ahmadi Muslims as
allegedly "extremist". They have not been able to publicly meet for worship
since July 2011 after the NSC secret police told the SCRA that they are a
"dangerous movement and against traditional Islam".
Unregistered religious communities particularly are "in danger of being
punished for their religious activity at any given moment", Jehovah's
Witnesses observed to Forum 18. Denials of state registration make
Jehovah's Witness communities illegal, and have "a chilling effect",
leaving them "vulnerable to police harassment", and "landlords are
unwilling to rent property where they could hold peaceful religious
meetings".
Multiple raids have taken place against Jehovah's Witnesses meeting for
worship, including a 10 August 2024 raid by the ordinary police and NSC
secret police on a Jehovah's Witness meeting in Kyzyl-Kiya in the
south-western Batken Region. Religious materials, including two Bibles and
a laptop, were confiscated and would be sent for "expert analysis to see
whether the materials contain extremist ideas", regime officials told
Jehovah's Witnesses. Jehovah's Witnesses told the officials that all the
texts were imported with permission of the State Commission for Religious
Affairs (SCRA), but they were still sent for "expert analysis".
All 16 Jehovah's Witnesses were detained and questioned for six hours,
Jehovah's Witnesses told Forum 18. "The officer then took several Jehovah's
Witnesses to the nearest police station for further questioning. At the
station they were once again questioned, personal photos were taken, and
they were then released." On 11 August 2024, the day after the raid,
regime-controlled news agencies stated that Jehovah's Witnesses "who
illegally met for preaching and reading religious books were detained by
the police". Jehovah's Witnesses told Forum 18 that they think this was
"done to scare the public". Jehovah's Witness communities, including in
Batken Region, have been repeatedly denied state registration.
(In December 2019, the NSC secret police opened a criminal case against
unspecified members of the Jehovah's Witness national centre in Bishkek on
charges of inciting religious hatred. The criminal case has never been
closed.)
SCRA Deputy Director Kanatbek Midin uuly and the NSC secret police both
refused to talk to Forum 18 about the raids on Jehovah's Witness, Hare
Krishna, and Protestant events.
Regime denies legally binding human rights obligations are legally binding
Kyrgyzstan ratified both the International Covenant on Civil and Political
Rights
(https://www.ohchr.org/en/inst
(ICCPR) and its Optional Protocol (OP1) (under which individual complaints
(https://www.ohchr.org/sites/d
made) on 7 October 1994. By voluntarily doing this, Kyrgyzstan took on both
the binding international human rights law obligations of the ICCPR, and
the obligation to correct any violations
(https://www.ohchr.org/en/inst
of its obligations – such as violations found by the United Nations Human
Rights Committee.
Individual complaints to the UN Human Rights Committee include those
concerning Jehovah's Witness communities, which have been repeatedly denied
state registration since 2010. In March 2019 (CCPR/C/125/D/2312/2013
(https://undocs.org/CCPR/C/125
(CCPR/C/132/D/2659/2015
(https://tbinternet.ohchr.org/
the Human Rights Committee found that Kyrgyzstan violated the rights of
Jehovah's Witnesses by arbitrarily refusing state registration to their
communities in Naryn, Osh, and Jalal-Abad Regions.
The most recent SCRA denials of registration applications by Jehovah's
Witness communities in Jalal-Abad, Naryn, Osh, and Batken Regions came on
16 March 2022. In all four of these Regions state officials have repeatedly
refused to explain to Forum 18 why they rejected the registration
applications. Jehovah's Witnesses challenged the denials in Bishkek City
Court on 1 August 2022.
During the hearing, the SCRA claimed – wrongly – that UN Human Rights
Committee views "are for consideration but not for implementation". Bishkek
City Court accepted the SCRA's excuses and refused to order the
registration refusals to be reconsidered. Both the SCRA and court officials
refused to explain to Forum 18 why the SCRA rejected the registration
applications again, ignored repeated Human Rights Committee decisions, and
why the SCRA claimed that Kyrgyzstan's legally binding international human
rights law obligations are not legally binding.
Similarly, Nursultan Amirakulov of the Chancellery of the Supreme Court
also refused to explain to Forum 18 how Kyrgyzstan's legally binding
international human rights law obligations are not legally binding. After
Forum 18 explained the details of the case, he responded: "We have many
complaints from Jehovah's Witnesses with us, which one exactly are you
talking about?" When Forum 18 once again explained the case he refused to
discuss it. When Forum 18 asked again why Kyrgyzstan's legally binding
international human rights law obligations are not legally binding,
Amirakulov refused to answer, repeating his previous response.
Religious organisations must re-register every 10 years
Article 8 of the 2025 Religion Law divides registered religious
organisations (the only ones allowed to exist and function) into central
and local organisations.
Article 9, Part 2 specifies that the required compulsory SCRA registration
lasts no more than 10 years. Religious organisations that want to continue
to function will then be required to undergo re-registration. No reason is
given for the 10-year time limit on the validity of registration.
Article 18 specifies that re-registration applications will entail the same
requirements as in the original registration procedure. This requires a
meeting of all the adult citizen founders and preparation of all required
documentation.
The 2008 Religion Law had no time limit for the duration of registration.
However, Article 40 of the 2025 Religion Law specifies that provisions
(such as existing state registration) related to registered religious
organisations will not have retroactive force. It appears that religious
organisations that had registration at the time the new Law entered legal
force on 1 February 2025 will have to re-register 10 years later.
One Protestant expressed concern about re-registration, commenting that "we
think that they will use this to close down any church they do not like".
Another Protestant, who wished to remain anonymous for fear of state
reprisals, described the "repetition of this [re-registration] process" to
Forum 18 as "an immense burden". Jehovah's Witnesses commented that "this
proposed 're-registration' process can be used as a tool to deny
registration to religious minorities".
Central spiritual administrations given power over individual communities
Under Article 11 of the 2025 Religion Law, only religious organisations of
one faith will be allowed to form one central spiritual administration.
Article 11, Part 2 also specifies that for Muslims, the central spiritual
administration will be the regime-controlled Muslim Board (Muftiate). This
would appear to prevent the formation of independent nationwide Muslim
bodies that are not controlled by the regime. Why Muslims are targeted by
this restriction is not explained.
Article 11 defines the functions of a central spiritual administration as,
among others, to name leaders of religious educational establishments and
of individual communities under the central spiritual administration. This
will prevent imams not appointed by the state-controlled Muslim Board from
leading Islamic communities.
Central spiritual administrations are also responsible for applying to the
SCRA to found and build religious educational establishments and places of
worship.
SCRA given extensive arbitrary "control" powers
Under Article 36 of the 2025 Religion Law, the State Commission for
Religious Affairs (SCRA) and its regional branches exercise "control" over
how registered religious organisations and religious education
establishments, as well as registered places of worship, abide by the
provisions of the Religion Law and their own statutes.
The SCRA has the right to demand administrative and financial documents
from the leadership of registered religious organisations. It also has the
right to seek such information from state tax and statistics authorities,
as well as from banks.
The SCRA also has the right to send its officials to attend events by
registered religious organisations.
The SCRA is empowered to inspect registered religious organisations,
religious education establishments and place of worship. Regime agencies
and municipal bodies can ask the SCRA to conduct such an inspection of a
particular religious organisation or place of worship.
Under Article 37, if SCRA officials find a violation of the Religion Law
during such an inspection, the SCRA issues a written warning to the
religious organisation specifying a deadline (of up to 30 days) by which it
will have to have ended the violation.
If the religious organisation does not in the SCRA's view end the violation
within the SCRA's deadline, the SCRA can, under Article 37, ban the
organisation's activity for 90 days. If the religious organisation still
does not in the SCRA's view end the violation within that period, the SCRA
can go to court to liquidate the organisation. This makes all exercise of
freedom of religion or belief by the organisation illegal.
The exercise of freedom of religion or belief by religious organisations
can also be "halted, liquidated, or banned" if they violate the February
2023 Countering Extremist Activity Law.
Intrusive reporting requirements
Article 36 of the 2025 Religion Law specifies that the SCRA and its
regional branches check that every type of religious organisation and their
approved places of worship act in accordance with their statutes and the
requirements of the Religion Law. The SCRA is empowered to demand to see
administrative and financial documents, send officials to attend events,
and inspect financial and other transactions.
Article 36 requires registered religious organisations, religious education
establishments, and religious charities to provide the tax authorities and
the SCRA with intrusive reports revealing extensive personal,
organisational, and financial information.
Reports to the SCRA are to include "an annual report on its activities,
including religious premises, personnel of governing bodies, employees,
teachers and students for a religious educational establishment, as well as
documents on the expenditure of funds and the use of other property,
including those received from international and foreign organisations,
foreign citizens and stateless persons".
If a religious organisation fails to supply the annual report, the SCRA
issues a written warning. If it fails to comply within the SCRA's deadline
of up to 30 days, the SCRA can, under Article 31, ban the organisation's
activity for 90 days. If it then fails to comply within that period, the
SCRA can go to court to liquidate the organisation (thereby rendering all
its activity illegal).
If a religious organisation commits a violation for the second time within
a year, the SCRA can go to court to have the organisation liquidated.
Places of worship require registration
Article 17 of the 2025 Religion Law requires state registration with the
SCRA of buildings used by both registered religious organisations
(including places of worship), and by registered religious education
establishments. Such buildings can only be used after they have gained
state registration.
In the SCRA justification for the then draft Religion Law (see above), SCRA
Chair Yusupov claimed that registering places of worship and banning
building them on private land are necessary because "the building of
religious buildings has been chaotic because of the absence of laws".
Registration applications for communities under a central spiritual
administration can only be lodged by the administration, which will also
own the building. This would mean, for example, that the Muslim Board will
be the only body allowed to apply for approval of a new mosque.
If a religious community is not part of a registered central spiritual
administration, the local community must apply for registration for its
place of worship.
Applications to register a place of worship need to include documents
confirming the ownership, rental or other legal use of the building.
A Protestant, who wished to remain anonymous for fear of state reprisals,
described the registration requirement for places of worship as "an extra
burden on religious organisations". "Getting such registration will be a
difficult process, as the NSC secret police, the Interior Ministry, and
local mayors' office will have to give permission for such registration,"
the Protestant told Forum 18. "The registration as a religious building
could mean that the community may be banned in future to use it for other
purposes for its members or the wider public."
Under Article 17, Part 10, building places of worship on land owned by
individuals is banned.
A Protestant, who wished to remain anonymous for fear of state reprisals,
told Forum 18 in December 2024: "Construction of church buildings on
private land will be very difficult, as the state authorities will invent
excuses not to give permission."
The Protestant also noted that "using private homes to exercise freedom of
religion or belief with others will be banned under the Law", adding: "This
will make meeting for worship almost impossible for many churches." This
will force religious communities into central spiritual administrations to
get state registration for their buildings, "which will make state control
of religious communities easier, and also allow the regime to decide how
many religious buildings will be allowed".
Once a religious building is registered, under Article 17 the owner is
required to notify the local administration where it is based within five
working days of its registration and its address. The owner's name,
address, phone number, e-mail address and passport details must also be
provided. The owner needs to send confirmation of this notification to the
SCRA within five working days.
The Cabinet of Ministers is in charge of setting out provisions for
building, reconstructing or changing the usage of such religious buildings.
Article 17 specifies that the number of religious properties must not
exceed a number set by the Cabinet of Ministers.
The Amending Law's changes to the Violations Code adds a provision to
Violations Code Article 142 to punish those who use a place of worship
which is not registered with the SCRA with a fine of 200 Financial
Indicators (FIs) on individuals (20,000 Soms, equivalent to three weeks'
average wage) and 650 FIs on organisations. The Violations Code allows the
police and the SCRA to issue summary fines for violating Article 142.
"Preachers" must be registered every year
In a new move, Kyrgyz citizens who want to carry out undefined "preaching
activity" within the country or abroad will require state registration.
Religion Law Article 3 defines a "preacher" as a Kyrgyz citizen "involved
in spreading a religion by various methods (including through the media and
on the internet)" appointed by a registered central spiritual
administration, and who has been given SCRA registration as a preacher.
Only registered religious organisations can have "preachers". Also, "only
those people who have specialised higher or general religious education can
act as preachers", Article 13 of the Religion Law states.
"Preachers" must apply to the SCRA for registration. They must submit
written approval from a registered central spiritual administration
together with their application, passport, and religious diploma. SCRA
registration lasts for up to one year, though a preacher can apply to
extend this period. When the SCRA issues the registration certificate, the
SCRA must then tell the "preacher" that they must not violate the Religion
Law, and that any violations will be taken into account in deciding on
registration period extensions.
Within five working days of gaining SCRA registration, the preacher must
notify the local administration where they will be conducting preaching
activity. They will have to provide their passport details, their contacts
and their residential address. They will then have five working days to
provide confirmation of this notification to the SCRA.
Article 13 states that "preachers" can only speak in the name of a
state-registered central spiritual administration, and can only act within
a state-registered religious community's territory. However, "spreading a
religion" is not explicitly defined. It is unclear whether a "preacher" and
"preaching activity" taking place in the context of a regular meeting for
worship within a state-registered place of worship of a state-registered
religious community requires SCRA registration.
Members of various religious communities, who wished to remain anonymous
for fear of state reprisals, criticised both the Law's regulation of
"preachers" and lack of clarity. This leaves much room for arbitrary state
actions.
Protestants, for example, criticised the requirement for "preachers" to be
registered by the SCRA every year. "It is also unclear what exact
relationship preachers must have with a registered church. Will they need
the permission of a central spiritual administration, which potentially
creates greater regime control of preachers?"
Similarly, other Protestants also criticised the regime's claim to
determine who is a "preacher". "It is not clear to us if a preacher is
defined as a pastor of a church, and will pastors need to be separately
registered by a local administration and the SCRA?" They observed that
"this would allow local authorities or the SCRA to block, obstruct, or
punish pastors".
Under Article 13, the "preacher" must get the approval of the registered
central spiritual administration of their religious community for the
content of their sermons.
Under Article 11, "preachers" can only appear in the media or online after
the central spiritual administration of a registered religious community
has gained permission from the SCRA.
"Registration does not give you the freedoms one should expect"
State registration does not remove many obstacles to exercising freedom of
religion and belief. Members of a variety of communities throughout the
country, all of whom wished to remain anonymous for fear of state
reprisals, pointed out to Forum 18 that among the problems they face
"communities cannot have public meetings outside their registered addresses
unless they receive prior permission for each event from the authorities,
and our experience is that the authorities do not normally give
permission", and "the authorities have punished people for sharing their
beliefs in public places with adults."
One member of a religious community who wished to remain anonymous told
Forum 18 that "practically speaking, registration only gives you permission
to exist. Registration does not give you the freedoms one should expect."
On 26 March 2023, the State Commission for Religious Affairs (SCRA), the
National Security Committee (NSC) secret police, and Talas police
"Department for the Struggle against Extremism and Illegal Migration"
raided the registered St Nicholas Catholic Church in Talas, in the
north-western Talas Region, after a Sunday evening Mass. Officers, some of
them carrying weapons, forced those leaving the state-registered Church
back into the Church.
The armed officers forced people to remain in St Nicholas Church for about
one and a half hours until two Slovak nuns, Sister Daniela Cincilova and
Sister Eva Eliasova, signed a statement that they were "guilty" of alleged
"illegal missionary activities" and "spreading their ideology". The nuns'
"crime" was to read passages from the Bible aloud in the Church during
Mass. The SCRA then fined the nuns the maximum fine under Violations Code
Article 142, Part 4 ("Carrying out religious activity without registration
at the executive state body for religious affairs") of just over two weeks'
average wage. The Catholic Church appealed against the fines.
Also in spring 2023, two foreign Protestants at a registered Protestant
church were fined for "illegal missionary activity" after a raid by regime
officials, a local Protestant who wished to remain anonymous for fear of
state reprisals told Forum 18. The raid and fines also took place around
the time St Nicholas Church in Talas was raided, and included officials
from the police "Department for the Struggle against Extremism and Illegal
Migration".
Three days after the raid on St Nicholas Church, on 29 March 2023, the SCRA
wrote to the Catholic Apostolic Administration in Bishkek (which leads the
Church in the country) threatening that if more "violations" occur, the
SCRA will "take action against the Apostolic Administration in Kyrgyzstan
for its liquidation".
SCRA Deputy Director Kanatbek Midin uuly refused to explain to Forum 18 why
his fellow-Deputy Director Zamir Kozhomberdiev threatened the Catholic
Church in writing with possible liquidation.
The Interior Ministry and police "Departments for the Struggle against
Extremism and Illegal Migration", the SCRA, and the NSC secret police all
refused to explain to Forum 18 why the regime violates its legally-binding
international human rights obligations.
Public events require SCRA permission
Under Article 31 of the 2025 Religion Law, registered religious
organisations and educational establishments are allowed to hold events in
their own premises, at places of pilgrimage and at cemeteries.
For any religious rituals or other mass events they plan elsewhere, they
need to notify the local administration and the SCRA 10 working days before
the proposed event, giving the date, location and programme of activity.
The local administration and the SCRA are responsible for giving or
refusing permission for the event.
Religious events in prisons, homes for elderly or disabled people, or the
armed forces are allowed only at the request of residents and in special
premises. The institution's administrations must also get approval for the
event from the SCRA.
The creation of religious organisations in state bodies (including the
armed forces) is banned by Religion Law Article 5.
The Amending Law's changes to the Violations Code adds a provision to
Violations Code Article 142 to punish those who exercise freedom of
religion or belief without SCRA permission with a fine of 200 Financial
Indicators (FIs) on individuals (20,000 Soms, equivalent to three weeks'
average wage) and 650 FIs on organisations. Violations Code Article 142
allows the police and the SCRA to issue summary fines for violating the
Religion Law.
Religious materials censored
Article 32 of the 2025 Religion Law specifies that registered religious
organisations have the right to produce, acquire, distribute, export and
import religious literature and other materials (which includes items in
the media and on the internet). It says that the procedure would be set out
by the Cabinet of Ministers, but gives no information about what this
procedure might consist of.
Under Article 32, individuals entering the country are allowed to have only
one copy of any one religious publication, which are for their own use
only.
Imports of religious literature are already subject to SCRA censorship. For
example, in 2022 the SCRA denied permission to import the 2022 issue of a
Jehovah's Witness booklet, the Kyrgyz version of "Examining the Scriptures
Daily". This was one of 13 publications and six videos the NSC secret
police and the General Prosecutor's Office tried to have declared
"extremist" in a failed 2021 application to the courts.
On 23 February 2023, the SCRA denied permission to import a Jehovah's
Witness brochure for parents to read with their children, "The Lessons for
Little Ones" in both Kyrgyz and Russian. "Although Jehovah's Witnesses met
with SCRA representatives to discuss this instance of religious censorship,
the SCRA's decision to ban the brochure still stands," Jehovah's Witnesses
noted.
Article 32 of the 2025 Religion Law empowers the SCRA to conduct "religious
studies expert analyses" of printed and online religious literature and
materials. It will normally have up to 30 working days to complete such
analyses, but this could be extended by an extra month "taking into account
the level of complexity and quantity of materials".
All religious literature acquired by libraries requires a SCRA "religious
studies expert analysis".
Regime "expert analyses" of religious materials and religious communities'
beliefs have been used to justify regime human rights violations, such as
censoring and banning films and texts officials dislike, attempting to ban
an entire religious community, and in August 2023 jailing a Protestant for
six months for questioning regime policy on freedom of religion or belief
(see above).
The most high profile film censorship case was the 2012 banning of the film
"I am Gay and Muslim", in which five Moroccan men reflect on their
orientation and Islam. After a protest from the then-acting Chief Mufti to
the NSC secret police, the NSC asked the SCRA to conduct an "expert
analysis", which classified the film as "extremist".
The NSC confiscated the film before it was shown at Bishkek's Bir Duino
(One World) human rights film festival, warned the festival organiser that
she could be prosecuted for "incitement of national, racial, or religious
hatred", the State Communications Agency blocked internet access to the
film, and it was placed on the Justice Ministry's list of banned
"extremist" materials.
Article 32 of the 2025 Religion Law does not state when the SCRA can impose
"expert analyses" on literature and materials, stating only that the
procedure is set out by the Cabinet of Ministers. No information is given
about what this procedure might consist of.
All religious literature, audio and video recordings, including online,
produced by registered religious organisations or religious educational
establishments has to have the full official legal name of the organisation
and its religious affiliation.
Article 32, Part 4 bans the distribution of religious literature or
materials "in public places, as well as by going round residential
properties, state and municipal organisations, in military sites, and in
pre-school and general educational establishments, with the exception of
religious sites and religious educational establishments". Those who
violate this face punishment under the Violations Code.
Article 142, Part 3 of the Violations Code already punished (before the
2025 amendments) distributing religious literature in public with a fine of
55 Financial Indicators (FIs) on individuals (5,500 Soms, equivalent to
just over a week's average wage) and 170 FIs on organisations. The 2025
Amending Law's changes to the Violations Code specified in more detail the
sorts of distributed religious materials and places where it is distributed
(including in public places and going door to door) for which punishment is
set out. It also increased the fines to 200 FIs (20,000 Soms, equivalent to
three weeks' average wage) on individuals and 650 FIs on organisations.
Violations Code Article 142 allows the police and the SCRA to issue summary
fines for violating the Religion Law.
A member of a religious community expressed concern about the restrictions
on sharing faith in public, commenting: "Even if you can register
overcoming all the obstacles put there by the authorities, we won't be able
to effectively share our faith." They added, "We would like to pass out our
books and literature on the street to others so they can find out about our
faith, but this is directly banned."
Religious education – with state permission only
Article 6, Part 9 of the 2025 Religion Law specifies that religious
education (whether of children or adults) is to be under the control of the
Cabinet of Ministers, but gives no information about what this control
might consist of.
Under Article 6 and Article 12, for religious communities that are part of
central spiritual administrations, only the administrations are allowed to
apply to the SCRA for permission to establish religious educational
establishments "for children and adults". Registered religious communities
which are not part of central spiritual administrations are also allowed to
apply to the SCRA for permission to found such establishments.
Article 6, Part 3 allows registered religious organisations to establish
religious educational establishments to prepare "clergy and religious
personnel they need". It remains unclear why they are not able to establish
such facilities for any adult who wishes to learn more about a faith. They
are also allowed to hold "short-term religious courses for adults and
children".
Article 12, Part 1 specifies that only registered religious organisations
can found religious educational establishments.
Article 12, Part 6 specifies that applications from a registered religious
organisation to register a religious educational establishment with the
SCRA need to include "a curriculum together with a list of religious
literature to be used in study".
The application will also need to show that the religious educational
establishment has "high-quality teachers" approved by the founding
registered religious organisation.
Article 6, Part 6 specifies that anyone teaching religion in a registered
religious educational establishment has to have "specialised higher or
general religious (spiritual) education" with an appropriate certificate.
The applicant religious organisation also needs to submit documents for the
premises where the religious educational establishment is based, together
with certification of the premises from the sanitary-epidemiological and
fire services.
Article 6, Part 8 of the 2025 Religion Law requires SCRA permission for
adults to travel abroad to study in a religious educational establishment.
The SCRA then informs the Foreign Ministry. Those studying abroad must
register with the Kyrgyz consulate in the country where they are studying.
The SCRA maintains a list of "recommended" religious education
establishments abroad.
A member of a religious community, who wished to remain anonymous for fear
of state reprisals, commented: "We would like to send our members, who have
the possibility to go, to study abroad since we are not able to do so in
Kyrgyzstan."
Once a religious educational establishment is registered, under Article 36
it is required to notify the local administration where it is based within
five working days of its registration and its address. It also has to
provide it with the name, address, phone number, and passport details of
the head of the establishment. The religious educational establishment
needs to send confirmation of this notification to the SCRA within five
working days.
Once a religious educational establishment is registered, it must notify
the administration where it is based within 5 working days. Under Article
19, it is required to notify the SCRA within 30 days of any changes to its
name, address, leadership body, phone number, or e-mail address.
Individual religious teaching banned
Article 6, Part 7 of the 2025 Religion Law continues to ban teaching
religion individually outside a registered religious educational
establishment. Those who violate this face punishment.
The Amending Law's changes to the Violations Code added a provision to
Article 142 to punish those who teach religion individually outside a
registered religious educational establishment with a fine of 200 Financial
Indicators (FIs) on individuals (20,000 Soms, equivalent to three weeks'
average wage) and 650 FIs on organisations.
Violations Code Article 142 allows the police and the SCRA to issue summary
fines for violating the Religion Law.
One individual noted, before the 2025 Religion Law was passed, that young
people go to a mosque and receive "short lessons on behaviour, prayer or
reading the Holy Koran". They added that "a person can simply come with
questions to the imam, and during the time when the imam answers his
questions, some may consider this a lesson in the wrong place and fine
him?!"
Foreign missions and "missionaries" require registration
Articles 14 and 15 of the 2025 Religion Law require missions of foreign
religious organisations and those sent by foreign religious organisations
"to conduct religious activity in Kyrgyzstan" (also described as
"missionaries") to have state registration with the SCRA. Under Article 14,
missions require 200 adult citizen founders living in one Region, and all
their personal details (confirmed by a notary) will have to be submitted
with the application.
Among other restrictions, missions must provide for all staff members their
full names, birth dates, citizenship, education, places of previous work,
and residential addresses.
Missions must supply "information about the basics of the doctrine and the
practice corresponding to it, including the history of its origin, the
forms and methods of its activities, the attitude towards family and
marriage, education, the specifics of the mission's attitude towards the
health of followers of the given religion, and restrictions for members and
servants of the organisation regarding civil rights and obligations".
The SCRA allows "missionaries" to operate for one year, although this can
be renewed for a maximum of a further three years.
Religious believers banned from political activity
Article 5, Part 7 of the 2025 Religion Law bans "interference by religious
figures in the activity of state bodies, local administrations and their
officials, including exerting pressure on them in any form".
Many of the Religion Law's provisions on this and other topics are vaguely
worded. It remains unclear if religious community members who lobby state
officials or parliamentary deputies on state policy on freedom of religion
or belief or other issues of public concern, or even simply express their
opinions on such subjects, would be violating this ban. Article 5, Part 7
also bans "parties and other political formations founded on a religious
basis".
Articles 3 and 4 of the Amending Law ban elected deputies of local keneshes
and the national Zhogorku Kenesh from conducting undefined "religious
activity". It is unclear what this means, for example if deputies cannot be
leaders or members of registered religious organisations, or even be banned
from attending any meetings for worship.
The ban on religiously-inspired political parties could affect the Yiman
Nuru (Light of Faith) Party, which has an Islamic inspiration, though a
parliamentary official insisted in February 2025 that it would not. The
Justice Ministry registered the party in June 2012, and the party gained
five deputies in November 2021 parliamentary elections
(https://www.osce.org/files/f/
State control and impunity
The regime systematically violates intertwined fundamental rights in its
quest to control the society it rules. Without fundamental change -
especially genuine independently verifiable implementation of international
human rights obligations – it is likely that the regime's officials will
continue to violate fundamental human rights with impunity. (END)
More reports on freedom of thought, conscience and belief in Kyrgyzstan
(https://www.forum18.org/archi
Previous Forum 18 Kyrgyzstan religious freedom surveys
(https://www.forum18.org/analy
Forum 18's compilation of Organisation for Security and Co-operation in
Europe (OSCE) freedom of religion or belief commitments
(https://www.forum18.org/archi
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