REFUGEES RIGHT TO WORK IN UGANDA: UNDERSTANDING THE EVOLVING LEGAL FRAMEWORK, RECENT DEVELOPMENTS AND THE IMPLICATIONS FOR REFUGEES AND RELEVANT STAKEHOLDERS

By Ocen George and Timothy N. Akampurira.

As of May 2026, Uganda hosts over two million refugees and asylum seekers, making Uganda the country hosting the largest refugee population in Africa and the second highest in the world. The vast majority come from neighbouring countries such as South Sudan and the Democratic Republic of the Congo although a smaller but significant numbers of refugees also arrive from Sudan, Somalia, and Burundi.

Uganda does not strictly confine refugees to camps or bar them from earning a living through gainful employment. Instead, it operates a ‘self-reliance’ model aimed at making refugees both economically and socially independent, envisioning that refugees should be able to meet their own basic and material needs through employment, entrepreneurship and farming among others.

However, there remains a well-documented gap between refugees’ rights to work as inscribed into the Ugandan legal framework and the numerous barriers refugees face in: securing employment, registering a business, opening a bank account, or formalising a community organisation, in Uganda. This article is essential for employers, NGOs and refugees alike, to understand refugees’ legal entitlements to work in Uganda, the practical obstacles they face, and how recent case law is beginning to close some of the existing gaps.

The Legal Framework

Uganda’s approach to refugee rights rests on several layers of law: the core domestic legal framework is found in the Refugees Act[1] and the Refugee Regulations, 2010 read together with Uganda’s Self-Reliance Strategy as first introduced in 1999. International law as comprised in the 1951 UN Refugee Convention and its 1967 Protocol, and the 1969 OAU Refugee Convention, both as ratified by Uganda and reflected in the domestic laws. Under Sections 27 & 28 of the Refugees Act, a recognised refugee in Uganda is generally entitled to enjoy various rights  including but not limited to: engage in gainful employment and/or practise a profession for which they are qualified, establish and run a business; own property; move freely within the country subject to reasonable restrictions; access financial services: opening bank accounts and mobile money accounts; and access all national services such as healthcare and education.

Certain applicable and relevant provisions can also be traced in sector-specific legislation including: the Employment Act[2], the Uganda Citizenship and Immigration Control Act[3] and the Non-Governmental Organisations Act[4], together with the regulations governing business registration, taxation, and financial services.

This is a genuinely progressive framework on paper as few refugee-hosting states grant refugees such broad statutory rights to work and trade. The gulf between refugees’ legal entitlement(s) and practical access to the same continues to widen mainly at the intersection of the Refugees Act and other legislation (as highlighted above) and administrative practice in Uganda. Uganda’s promise to refugees, however, is qualified and worth setting out clearly as further below:

Uganda ratified the 1951 UN Convention [“the Convention”] and the 1967 Protocol thereto subject to significant reservations and declarations, which narrow the Government’s binding international obligations below strict interpretation of the Convention’s provisions. Uganda’s reservations and declarations limit the full application of several provisions of the Convention which Uganda treats as; matters of discretion, recommendations, or matters subject to limitation/restriction in the public interest without recourse to courts or tribunals. Some of these provisions include: Articles 7, 8, 9, 13, 16, 25 and 32 of the Convention.

Uganda’s reservation to Article 25 is particularly instructive as it helps explain why the day-to-day administration of refugee affairs (registration, documentation, and welfare support) has for decades fallen heavily on UNHCR and its implementing partners, with the Office of the Prime Minister (OPM) primarily playing a coordinating role rather than a direct service-delivery role. The practical effect is that on several matters that affect refugees’ daily lives, Uganda never fully committed to the Convention’s baseline protections, meaning that refugees in Uganda cannot always fall back on the Convention itself where domestic law or administrative practice falls short to address gaps that arise.

Practical Application: Where the applicable Law falls short to address the Reality faced

1. Obtaining of work permits and/or necessary documentation by refugees: this is an area where the law has recently shifted decisively in refugees’ favour. Whereas the Refugees Act has always exempted recognised refugees from the standard work-permit regime that strictly applies to other foreign nationals, the Directorate of Citizenship and Immigration Control (DCIC) under the Ministry of Internal Affairs has, in practice, done away with that exemption and often requires refugees to possess a Convention Travel Document, passport-stamped permit or such similar documentation that many refugees simply do not hold. That practice has now been squarely tested before the courts of law in Uganda in Kasajja Brian v Attorney General and Anor [High Court Miscellaneous Cause No. 0199 of 2019]. In that matter that came before the High Court – Civil Division, Kinobe. J, held that a recognised refugee’s statutory right to work exempts such refugee from the requirement of obtaining a separate work permit under general Ugandan immigration laws. He grounded his foregoing finding in Article 40(2) of the Constitution[5] which guarantees and extends economic freedom to earn a living to refugees by stating that every person in Uganda has the right to practice their profession and to carry on any lawful occupation, trade, or business; read together with Section 28(1)(e)(vi) of the Refugees Act which guarantees recognised refugees access to employment opportunities and engage in gainful employment. The Court also restrained authorities from arresting, prosecuting, or harassing recognised refugees for working while holding a valid Refugee Identity Card and, further relied on Section 25(1)(a) of the Refugees Act to assert extension of the same exact exemption/protection to family members of a recognised refugee including the right to be issued with all necessary or relevant supporting documents to such relative.

The upshot of the foregoing case is very significant because the court gave guidance with respect to recognised refugees in Uganda. Specifically, the court qualified the requirement to hold a valid work permit holding that; it is not a precondition for a recognised refugee or their family member(s) to commence and engage in lawful employment. Employers are advised however to take note and consider this qualification or exemption is only available to recognised status refugees wherefore asylum seekers and other unrecognised refugees remain outside the scope of this exemption. Second and important to note for employers is to highlight that the Kasajja Brian case (supra) is the first decision by a Ugandan court on this position wherefore while the decision is influential, albeit the same was delivered at High Court level, it therefore represents the substantive position of the law subject to any later appeal. Further, the decision neither binds other High Court judges nor the Superior courts of record in Uganda from departure therefrom for good reason. We think that the DCIC’s administrative practice(s) may take time to adopt and adapt to the court’s guidance as summarized above.

• Refugee-led organisations vis-à-vis the Non-Governmental Organisations (NGO) Act: a less visible but increasingly significant barrier relates to refugees’ Community-based organisations [CBOs]. The CBOs are informal, locally rooted groups operating at sub-county level or below. These CBOs usually are the vehicle through which the majority of refugee-led initiatives in Uganda organise: savings groups, women’s collectives, youth associations, and small-scale livelihood projects. Yet the framework under the NGO Act, 2016 for registering and recognising this kind of community-level structuring is designed around citizen-led civic life, which in practice manifests rather as a preserve of Ugandan nationals. For instance, a small-scale refugee-led community-based group seeking formal recognition typically has no straightforward registration pathway to obtain status as a CBO, as designed for such organisations, and is instead compelled to register fully as an NGO, which is a materially more demanding or rigorous process with many requirements. The result is that many refugee-led organisations operating as CBOs remain unregistered and non-compliant.  

The NGO Act creates a second, related difficulty for organisations, refugee-led or otherwise, that want to employ refugees directly. The Bureau’s registration and permit processes, and its expectations around staffing, typically call for identification or travel documentation that mirrors what the DCIC has historically demanded for work permits. For refugees who fled without documentation, or whose Convention Travel Document is still pending, this can make formal employment by an NGO administratively difficult in much the same way that formal employment by a private employer has been, notwithstanding the statutory right to work, and the Kasajja Brian ruling, discussed above. Advocacy for reform in this area continues, but for now, both employers and refugee-led groups need practical, case-by-case guidance on how to work within or around these constraints.

• Recognition of qualifications: Refugees with foreign degrees, professional certifications, or trade qualifications frequently find that Ugandan institutions do not recognise the same without a costly and time-consuming equating process through the relevant regulatory body such as the National Council for Higher Education for academic credentials, or professional councils for regulated professions such as law, medicine, or accountancy. Although translation and equating fees may appear to be fairly modest, they are often prohibitive for most refugee households.
• Non-recognition of Refugee status in the Employment Act: The Employment Act, as the principal statute governing the employer-employee relationship in Uganda, does not explicitly reference refugees as a protected category of worker. This creates uncertainty for both employers and employees around the explicit contractual protections. The practical effect is that many refugees with genuine skills and qualifications end up in informal or low-paying work that may not reflect their training. This mismatch remains a persistent theme that can be drawn from the existing reports on Uganda’s refugee response.  It is our view as PPL that this is a longstanding point of advocacy for legal reform and we welcome the clarity the courts have now brought to the work-permit question specifically.
• Access to finance: Refugees are legally entitled to open bank accounts and access financial services, but many banks and microfinance institutions remain reluctant to extend credit to recognized refugees, usually citing perceived risk or the absence of a credit history which is a barrier that affects refugee entrepreneurs disproportionately regardless of the underlying legal right to trade. The practical effect is that many refugees in Uganda end up accessing expensive credit at excessive and unreasonable interest rates from money lenders in addition to further surrendering any valuable collateral as well.

Key Takeaways for all relevant stakeholders:

1. Hiring a recognised refugee as an employee in Uganda is lawful and does not require such recognised refugee to obtain a work permit as now confirmed by the High Court in Kasajja Brian v Attorney General and Another [2026] UGHCCD 2017. A prudent employer should however still confirm and retain evidence of the refugee’s recognised status and registration with OPM because the exemption does not extend to asylum seekers or other unrecognised refugees;
2. Ugandan authorities are hereby restrained from arresting, prosecuting, or harassing recognised refugees for working while only holding a valid Refugee Identity Card without a work permit;
3. All rights under the Employment Act including both contractual and statutory obligations, for instance: minimum wage where applicable, notice periods, National Social Security Fund (NSSF) contributions, and occupational safety requirements, apply in the same way to employed recognised refugees in Uganda as they would to any other employee, notwithstanding the unexpressed treatment of refugee status under the Employment Act;
4. Employers should note that there are reputational, and increasingly commercial, advantages to structured refugee employment including: donor-funded programmes, development finance institutions, and impact investors, all of which are now are placing growing emphasis on inclusive hiring. We recommend that businesses aim to be well placed to benefit from such efforts;
5. Refugees, CBOs and Refugee-Led Businesses seeking to work or operate in Uganda must be aware that the starting point is always registration and documentation with OPM inorder to obtain recognized status and possess valid refugee identification document. This underpins every other right that may be available to them and/or process they may be subjected to;
6. Refugee entrepreneurs seeking credit should be aware of emerging blended-finance and credit-guarantee initiatives designed specifically to de-risk lending to refugee-owned businesses, and should seek advice on which financial institutions are actively engaging with these mechanisms. We recommend seeking tailored legal advice in such circumstances;
7. Uganda’s National Population Census as last conducted in 2024, included refugees and stateless persons for the first time in history. It is our considered belief that this indicates intentional steps by the Government to better plan for the refugee population which are expected to improve data-driven planning for better services and economic inclusion;
8. Owing to significant reduction in international humanitarian funding since 2025, the increased pressure on refugees to move from predominant foreign/donor aid dependency toward self-reliance has intensified. There is thus a serious and emerging need for stakeholders to focus on removing the administrative barriers described in this article above; and
9. Increased advocacy continues around harmonising the Refugees Act with the Employment Act, the Citizenship and Immigration Control Act, and the NGO Act, so that refugee workers and refugee-led organisations have clear enforceable protections as opposed to relying on patchwork of overlapping and sometimes inconsistent statutes and administrative practices.

How PPL Can Help:

We offer tailored legal services to refugee(s) or refugee-led CBOs to navigate the legal terrain of: registration, licensing, obtaining or verification of obtained refugee credentials, advocacy and representation in disputes involving refugee employment rights, guidance in obtaining of work-permit and other related legal matters/advisory as may be necessary from our assessment of the facts that are presented.

This article is for general informational purposes only and does not constitute direct or specific legal advice. Please contact our office for advice tailored to your specific circumstances if you require practical guidance on any of these issues as raised or to arrange a consultation.

PPL will not be responsible to, or accept any liability or responsibility of any nature for any losses, damages, costs, or expenses to any third party whatsoever and howsoever caused arising from or in connection with this article.

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[1] Cap. 312 Laws of Uganda

[2] Cap. 226 Laws of Uganda

[3] Cap. 313 Laws of Uganda

[4] Cap. 109 Laws of Uganda

[5] The 1995 Constitution of the Republic of Uganda (as amended)