Uganda Law Society Declares Sovereignty Bill’s Financial Certificate ‘Unlawful and Void’
KAMPALA – The Uganda Law Society (ULS) has demanded the immediate withdrawal of the Certificate of Financial Implications issued for the controversial Protection of Sovereignty Bill, 2026, declaring the document “manifestly unlawful, void, and of no legal effect.”
In a forceful letter dated April 29, 2026, addressed to Minister of State for Finance Hon. Amos Lugoloboi, the ULS cited fundamental non-compliance with Section 74 of the Public Finance Management Act (PFMA) and the applicable Guidelines for Request and Issuance of Certificates of Financial Implications.
‘Materially Short’ of Legal Requirements
The Certificate, issued on April 15, 2026, claims implementation of the Bill would impose a financial burden of Shs. 29.029 billion on the Department of Peace and Security. However, the ULS argues this figure is presented as a “single aggregate sum without itemisation, underlying methodology, assumptions, timeframe, or distinction between capital and recurrent expenditure.”
According to the Society’s Vice President, Asimwe Anthony, the suggestion that first-year costs can be absorbed within the existing Shs. 14.593 billion budget is “unrealistic,” given the Bill imposes “extensive new functions” on the Department.
Millions in Revenue Ignored
In a critical oversight, the ULS notes the Certificate erroneously claims the Bill generates no direct revenue for government. In fact, the proposed legislation creates multiple revenue streams, including:
· Registration and renewal fees for agents of foreigners
· Criminal fines up to UGX 1 billion for non-registration
· Forfeiture of funds obtained in contravention of the Act
· Civil penalties up to UGX 4 billion on supervised financial institutions
· Criminal fines up to UGX 4 billion payable to the Consolidated Fund
“By failing to identify or quantify these revenue streams, the Certificate presents only the expenditure side of the fiscal equation and denies Parliament the balanced information required,” the letter states.
Bank of Uganda Warnings Ignored
The ULS letter highlights that the Certificate wholly ignores a detailed technical assessment from the Bank of Uganda (BoU), despite this being required under Article 162 of the Constitution.
In a submission to Parliament dated April 28, 2026, the BoU warned that the Bill risks introducing “regulatory fragmentation” and “voluntary shocks” that could undermine Uganda’s economic strength and financial stability.
Key risks omitted from the Certificate include:
· Foreign Direct Investment: The overly broad definition of “foreigner” could chill the USD 3.4 billion in FDI recorded in FY 2024/25
· Foreign Aid: The UGX 400 million funding cap threatens USD 420.8 million in aid flows to NGOs
· NGO Sector: Potential job losses estimated at 20,000–50,000 positions
· Diaspora Remittances: Annual USD 1.5 billion inflows face disruption
· Financial System: Risk of FATF grey-listing and loss of correspondent banking relationships
Demands and Next Steps
The Law Society has demanded that the Minister immediately withdraw the deficient Certificate and reissue one that provides:
- Itemised, transparent costing with clear methodology and distinction between capital and recurrent expenditure
- Quantification of all revenue mechanisms including fees, forfeitures, civil penalties, and fines
- A genuine economic impact assessment accounting for the Bank of Uganda’s expert analysis
Pending reissuance of a compliant certificate, the ULS has called upon Parliament to “halt any further consideration of the Protection of Sovereignty Bill, 2026.”
The letter was copied to the Speaker of Parliament, the Attorney General, the Ministers of Finance and Internal Affairs, and the chairpersons of relevant parliamentary committees.
About The Author
