Buganda Kingdom Details What’s Wrong With Sovereignty Bill and How to Fix It

The Buganda Kingdom has formally raised concerns over Uganda’s Draft Protection of Sovereignty Bill 2026, outlining key weaknesses in the proposed law and offering recommendations for improvement.

In a detailed submission dated April 13, 2026, and addressed to the Attorney General of Uganda, the Kingdom emphasized that its position is not politically motivated but aimed at refining the legislation to better serve national interests.

“These submissions are not partisan politics in nature and are not in opposition to the Government of the Republic of Uganda,” wrote Christopher Bwanika, the Attorney General of Buganda.

“Our wish is to assist your good office and Parliament in refining this legislation so that it truly serves its stated object of protecting Uganda’s Sovereignty.”

The Kingdom urged lawmakers to revise how “foreigner” is defined, stressing that citizenship—not location—should be the determining factor.

“We observed that the defining characteristic of a ‘foreigner’ ought to cover ‘non-citizenship’ and not one’s geography or residence,” Bwanika stated.

He added that diaspora contributions should not be criminalized, warning that “to label such contributions as ‘foreign funding’ and to designate family members back home as ‘agents of foreigners’ is a profound injustice.”

The Kingdom proposed exemptions for cultural, family, and community transactions, as well as traditional institutions.

The Kingdom called for amendments to Clauses 7 and 8 to safeguard its role in public discourse. It warned that the Bill could criminalize its engagement on key issues, noting that “any public engagement by the Kingdom on government policy could be prosecuted, if the Kingdom has received a form of ‘foreign’ support.”

It also called for revision of the economic sabotage clause. On Clause 13, the Kingdom raised alarm over vague wording and harsh penalties.

“The clause seems to have no clarity regarding the difference between deliberate sabotage… and good faith commentary on economic policy,” Bwanika wrote.

He recommended limiting the offence to intentional acts tied to foreign interests, emphasizing that “the criminal intent (mens rea) must be proven.”

Mengo also asked that foreign funding thresholds be raised. The Kingdom criticized the UGX 400 million cap on foreign funding as unrealistic. “The threshold… is unrealistic, as regards activities of the Kingdoms,” the submission noted.

It warned that penalties—including fines and asset forfeiture—could undermine development work, proposing higher thresholds or blanket exemptions for traditional institutions.

The Bill’s requirement for entities deemed “agents of foreigners” to register was described as burdensome.
“This could create an administrative burden that would cripple operations,” Bwanika stated, urging that traditional institutions be exempted from Clause 14.

The Kingdom opposed public disclosure of funding sources, arguing it violates privacy rights. “The public disclosure regime… seems to conflict with the right to privacy,” the submission reads.

It recommended that disclosures be kept confidential or limited to anonymized data to protect contributors.

On banking and reporting restrictions, the Kingdom singled out Clause 25, which imposes strict reporting requirements on financial institutions, was flagged as disruptive.

The Kingdom warned that requiring ministerial approval before releasing funds “could cause significant delays in disbursement of project funds.”

The Kingdom cautioned that the Bill could harm Uganda’s attractiveness to investors. “This Bill… will definitely scare away many potential investors,” Bwanika warned.

He added that it may “doom our economy and increase the cost of doing business in Uganda,” potentially leading to capital flight to neighboring countries.

The Kingdom also criticized what it called excessive regulation that could hinder development. “The Bill introduces restriction on policy development and implementation,” the statement notes, adding that it overlooks the role of cultural institutions in sectors like health, education, and agriculture.

The Kingdom urged the Attorney General to allow more time for consultations and revisions. “We believe that the spirit of this intended law is to ‘promote the interests of Uganda’… which in our view can’t be served by the draft law in its current state,” Bwanika stated.

The Buganda Kingdom reaffirmed its willingness to engage further with government to ensure the legislation aligns with constitutional principles and supports national development.

Buganda Kingdom on Protection of Sovereignty Bill 2026

OBWAKABAKA BWA BUGANDA
(KINGDOM OF BUGANDA)

13th April 2026

The Attorney General of Uganda
Attorney General’s Chambers
JLOS Towers, Plot 98-102, Katalima Road, Naguru

Dear Sir,

RE: DRAFT PROTECTION OF SOVEREIGNTY BILL 2026

I send you greetings from the Kingdom of Buganda and my office.

I write to respectfully submit the Kingdom’s detailed concerns, observations and recommendations on the Draft Protection of Sovereignty Bill 2026 for your urgent consideration, before the Bill proceeds to its further stages in Parliament.

For avoidance of any doubt, I emphasize that these submissions are not partisan politics in nature and are not in opposition to the Government of the Republic of Uganda. On the contrary, the Kingdom of Buganda regards itself as a partner of Government in national development, as evidenced by the numerous memoranda of co-operation entered between the Kingdom of Buganda, and Government Ministries over the years.

Our wish is to assist your good office and Parliament in refining this legislation so that it truly serves its stated object of protecting Uganda’s Sovereignty, without inadvertently harming the Kingdom’s constitutional mandate, the interests and welfare of all citizens in Buganda and beyond, and the broader national interest.

As you are aware, the Kingdom of Buganda’s legal standing on issues affecting its interests and people, is grounded in Article 246(1) of the 1995 Constitution of Uganda, as amended, which provides for its existence in accordance with the cultural customs and traditions or wishes of the people. Likewise, Section 9 of the Traditional Rulers Act, mandates the Kingdom to promote and preserve cultural values, and promote the development, preservation and enrichment of the people. Section 10(2) of the aforesaid Act,in the same regard, recognizes the Kingdom’s entitlement to privileges and benefits under
culture, custom or traditions that are not inconsistent with the Constitution.

In essence, these submissions on the Bill are not made with a view of influencing the ultimate
outcome, in a partisan manner, but in the spirit of upholding Article 11 of the 1995
Constitution in a free and democratic society.

In addition to the proposals and views already received by your good office, we respectfully
submit our observations and recommendations and urge Government to carefully evaluate
the potential impact of this Bill on the constitutional role of traditional institutions, and
national development objectives.

1. Amend the definition of a Foreigner and “Agent of a Foreigner”

We observed that the defining characteristic of a ‘foreigner’ ought to cover ‘non-citizenship’
and not one’s geography or residence. Pursuant to Article 11 of the Constitution, a Ugandan
residing abroad doesn’t by ‘fact alone, loose their citizenship.

The Uganda Diaspora (including the non-Baganda) is one of the largest in United Kingdom,
United States, United Arab Emirates, and other jurisdictions, and they are known for
religiously maintaining deep cultural, economic and familial ties to Buganda. Many
contribute morally and financially, to the Kingdom’s programmes on basis of cultural
trust and voluntary solidarity, as evidenced in the “Buganda Bumu Conventions”,
“Oluwalefwa Lwafte” and “Kabaka Birthday Run” for instance, as Ugandan citizens, regardless
of their place of residence should be excluded.

Needless to mention, the Kingdom of Buganda receives grants, funding and support from
international development partners, including; UNAIDS, UNESCO, USAID, and others, for
health, education, agricultural development, cultural heritage and community development
programs. Under the Bill, the Kingdom and all its affiliated entities would be classified as
‘agents of foreigners’ in respect of every programme undertaken.

To label such contributions as ‘foreign funding’ and to designate family members back home
as ‘agents of foreigners’ is a profound injustice. In effect therefore, there’s need to add an
explicit carve-out for cultural, private, commercial and family transactions between Ugandan
citizens and their families or communities.

The above noted, we humbly submit that you consider inserting a clause, modelled on Article
246 of the 1995 Constitution, exempting constitutionally recognized Traditional Cultural
Institutions, and their affiliated entities, from the broad definition of “agent of a foreigner”.This in effect shall uphold and affirm the constitutional autonomy of the Traditional Institutions, and their governance framework, supported by the relevant line ministries. Their activities align with Government policies.

2. Amend Clauses 7(3) & 8(3) & (4) to expressly preserve the right of constitutionally recognized Traditional Institutions to engage on matters of: culture, development and community wellbeing.

We observe the need of drawing a clear distinction between foreign-directed political or security interference (which it legitimately targets) and domestic cultural and civic advocacy.

Clauses 7 & 8 of the Bill, read together with Clause 2(1)(f) of the Bill, create a regime under which any public engagement by the Kingdom on government policy could be prosecuted, if the Kingdom has received a form of ‘foreign’ support.

Over the years, the Kingdom of Buganda through its officials and entities, has always made public statements and engaged Government on numerous projects and programs involving: Land Rights; Cultural Heritage Engagements; Agricultural Programs; Health; Education, etc. Any of the many engagements could if funded internationally, be characterized as ‘influencing Government Policy’ or ‘influencing the public to oppose Government Policy’ at any point in time.

3. Clause 13 on Economic Sabotage ought to be redrafted with precision and clarity.

Clause 13 creates the offence of Economic Sabotage, penalizing any person who “publishes information or participates in any act or activity that weakens or damages the economic system or viability of the country.

The clause seems to have no clarity regarding the difference between deliberate sabotage motivated by foreign interest, and good faith commentary on economic policy. A Kingdom Government Project affecting the community, could be prosecuted for economic sabotage.

The penalties thereto even raise more concern, as they seem to be excessively harsh, and ought to be relaxed.

Clause 13 imposes penalties of up to Ugs. 2 billion for legal entities, and twenty (20) years imprisonment for individuals. We believe this clause, in its current state, is inconsistent with Article 29(1)(a) of the 1995 Constitution, which guarantees freedom of expression and press, and Article 38, which guarantees the right of every citizen to participate in peaceful activities to influence the policies of Government.We humbly suggest that the offence be limited to specified deliberate acts of economic
subsidy undertaken in furtherance of a foreign interest or with proven intent to destabilize
the economy, and not mere publications of critical economic commentary. The criminal intent
(mens rea) must be proven.

4. A substantially higher threshold for foreign funding approvals, or a blanket
exemption for all legitimate transactions undertaken in the ordinary course of
cultural preservation, community development, and heritage-related activities by
recognized traditional institutions.

As noted hereinabove, the Kingdom of Buganda operates comprehensive development
programmes across multiple sectors, that is health, education, cultural heritage, agriculture
and the like, most of which are supported by international organizations. The threshold of
Ugs. 400,000,000/= placed on every person receiving foreign financial support, under Clause
22, within any 12-month period, is unrealistic, as regards activities of the Kingdoms.

The penalties created under this clause, increase of breach, include a fine of upto UGX 4 billion
for a legal entity, or Ugs. 2 billion, and 20 years imprisonment for an individual. Clause
22(3) goes ahead to include forfeiture of the funds to the State. In otherwords, funds received
by the Kingdom of Buganda for socio-economic causes, would be confiscated by the State,
without compensation, a fact which offends Article 26 of the Constitution. As observed
earlier, all these punishments are harsh and ought to be relaxed.

In the circumstances, the Ugs. 400,000,000/= threshold could be increased substantially.
Preferably, an exemption framework established for all constitutionally recognized
Traditional Institutions and their affiliated development partners.

5. Exempting constitutionally recognized Traditional Institutions and their affiliated
entities from Registration under Clause 14

Clause 14 requires every person acting as an ‘agent of a foreigner’ to register with the
Department and obtain a certificate from the Minister for Internal Affairs, renewable every
two years. Given the broad definition of ‘agent of a foreigner’, the Kingdom itself and each
of its affiliated entities such as Kabaka Foundation, Nnabagereka Development Foundation,
and the like could be required to separately register. This could create an administrative
burden that would cripple operations.

We therefore suggest that Traditional Institutions and their affiliated entities be expressly
exempted from the registration regime under Clause 14.

6. Declarations of Fund Sources ought be filed on a Confidential basis with the
regulatory authority. (Clause 21)Clause 21 requires every person receiving funding from a foreigner to submit a declaration to the Minister, which declaration is publicly available for inspection by any member of the public upon payment of a fee.

The Baganda Diaspora have over the years contributed and continue to contribute to Kingdom Programmes on the basis of cultural trust and voluntary solidarity. Most of these contributors are private individuals, who value their privacy and give to the Kingdom as a cultural obligation, not as a commercial or political act.

The public disclosure regime, under this Bill seems to conflict with the right to privacy under Article 27 of the Constitution of Uganda, and the Data Protection and Privacy Act, 2019.

Broadly speaking, the public disclosure is likely to deter diaspora Baganda from contributing to Kingdom programmes, something that is likely to pose a threat to the Kingdom’s financial independence and its ability to deliver services to all Ugandans living within and beyond Buganda.

In the circumstances, we respectfully suggest that public access should be limited to anonymized and aggregated statistical information, sufficient to achieve the transparency objective. Preferably, Kingdoms, Private and Family remittances should be explicitly excluded from the disclosure regime.

7. Clause 25 be amended to exclude Traditional Institutions from the supervised institution reporting regime.

Clause 25 imposes obligations on banks and money transfer operators, in respect to cross boarder transfers to ‘agents of foreigners’. They have to receive a declaration of the source of the funds and proof of ministerial approval before paying out any money.

The Kingdom often receives donor funds, diaspora contributions, and project remittances, through the Bank System, and the requirement of Ministerial Approval before any payout could cause significant delays in disbursement of project funds.

In any case, we believe that the existing laws and financial regulatory frameworks are adequate to address legitimate transparency concerns without this additional layer.

8. Undermining Foreign Direct Flows into Uganda.

Uganda has been looked at as an ideal investment destination with minimal regulation. Government previously focused on deregulation to attract more capital inflows. This Bill now seeks to over regulate foreign remittances and appears to be a policy reversal, and will definitely scare away many potential investors.

The damage likely to be done caused by the ripple effect of this legislation may outstrip the benefits of concerns sought to be protected. This Law will not protect the sovereignty and interests of Uganda, but on the Contrary doom our economy and increase the cost of doing business in Uganda and give the Country a low – rating globally, as an investment destination.

Beyond deterring prospective investors, the Bill as currently drafted, poses a serious risk of capital flight from Uganda’s existing investment base. Institutions and individual investors routinely assess the regulatory environment of recipient countries before committing or maintaining capital flows. Uganda doesn’t exist in an economic vacuum. She competes for investment, diaspora remittances, and development financing with the neighbouring East African Community States, of which maintains comparatively lighter regulatory burdens on cross-border transactions.

In effect, there is a real danger that, should the Bill be enacted in its current form, capital flows that would otherwise be directed into Uganda, will be re-directed to these competing economies.

9. Policy Restrictions and De – regulation

The Bill introduces restriction on policy development and implementation. These restrictions seem to ignore the fact that Cultural Institutions complement Government Services in various sectors like health, education, social services, Traditional justice and dispute resolution environmental protection, Agriculture especially through “Bulungi Bwansi” self-help projects.

10. Conclusion

We invite the Attorney General to seek enough time to refine the legislation. We believe that the spirit of this intended law is to “promote the interests of Uganda” and the sovereignty of the country, which in our view can’t be served by the draft law in its current state.

We are available for any further engagements or clarifications that may be required.

Yours faithfully,

__________
CHRISTOPHER BWANIKA
ATTORNEY GENERAL OF BUGANDA

Cc: Katikkiro
Cc: Cabinet Ministers Buganda Kingdom
Cc: The Minister for Justice & Constitutional Affairs
Cc: The Speaker of Parliament

You can also read Bank of Uganda Governor’s criticism of the Protection of Sovereignty Bill and how it can cause the economy to collapse Here.

President Museveni’s government and Buganda Kingdom have previously disagreed on key issues such as ‘federo’, as detailed Here and There.