Syrians have sought refuge in Egypt since 2011 as a result of the Bashar al-Assad regime’s bloody repression of pro-democracy protests. Throughout these years, Syrians were dealt with according to the Egyptian political context, thereby receiving privileges in education and visas until the Egyptian regime changed in 2013.

Since then, Syrian citizens endured hardship and suffering that included restrictions on entry and residency, which subjected them to the so-called ‘security approval’ that was extortionist. Nonetheless, a radical shift in mid-2023, that can only be described as a ‘push-back’ process, occurred and resulted in the issuance of an informal decision to legalize the presence of foreigners. This decision was followed in 2024 by a series of announced and unannounced measures that restricted Syrian citizens’ agency; some of which represented a major reversal of legal protections they still required such as exemption from education fees.

With the conclusion of Bashar al-Assad’s regime at the end of 2024, Syrians were subject to more restrictions on entering Egypt, and the arrest of those celebrating the conclusion of Bashar’s regime. This caused their forced displacement as some of them were deported by the Egyptian authorities. 

In this report, the Refugee Platform in Egypt reviews the history of Egypt’s treatment of Syrian citizens since 2012, how security approval was imposed, and how the Egyptian authorities profited from said bureaucratic imposition. This report also provides legal analysis of the measures levied by the Egyptian authorities and the extent to which these measures comply with local laws, legislation, and international conventions. Additionally, this report discusses the appropriateness of describing Syria as a ‘safe country’ to which refugees, migrants, asylum seekers, and forcibly displaced people can be returned. Finally, this report offers a set of recommendations and strategies that address the hosting of Syrian citizens residing in Egypt.

Introduction

At the beginning of 2024, the Egyptian authorities issued a series of progressive security decisions and instructions through the Interior Ministry’s General Directorate of Passports, Immigration, and Nationality. These decisions were all issued in an unofficial manner, as none of them were published in the official gazette, some of them were announced through security sources who spoke to media outlets, and others were not announced but were implemented regardless. These decisions concern the status of Syrians residing in Egypt, whether registered or unregistered, as well as Syrians coming to Egypt.

Some of these decisions came earlier in 2024, others in the second half of December 2024, and some during the first few days of January 2025. The first period witnessed a rapprochement between the Egyptian authorities and the Bashar al-Assad regime, including agreements regarding the facilitation and organization of repatriation operations to Syria, that the Refugee Platform in Egypt previously issued a warning about last year.1 Meanwhile, the other set of decisions took place at a time when Syria witnessed radical internal changes after the fall of Bashar al-Assad’s regime.

According to UNHCR reports, Syrians are suffering from deteriorating security and living conditions which makes returning home a risky option.2 This is a result of diminishing livelihood standards, where basic elements of life are lacking in several Syrian territories. This livelihood degradation leaves nearly 90% of Syrians below the poverty line and more than 15 million people in need of humanitarian aid.3

Although many Syrians in Egypt are facing difficult economic and living conditions, they have contributed significantly to the Egyptian economy over the past years. According to data released by the General Authority for Investment and Free Zones (GAFI), Syrian investments in Egypt exceed $800 million, according to a GAFI statement.4 The number of Syrian factories and workshops in Egypt ranges from 5,000 to 7,000 factories and workshops, in addition to various small and micro commercial activities, all of which adds economic and cultural diversity to Egyptian society. 5

In this position paper, the Refugee Platform in Egypt focuses on the legal context of Syrian citizens’ status in Egypt in general. Through which, the platform reviews the preceding circumstances and evolutions in Egyptian government policy towards Syrian refugees, migrants, and asylum seekers since 2012. This review includes the measures recently circulated by Egyptian authorities, without the issuance of formal declarations, and ends with the most recent measures, following the fall of the Syrian regime, which the political regime is implementing through executive and legal tools. This review also extrapolates on the constitutionality, legality and humanity of these cases and their compliance with international standards and obligations, as well as the process of profiting from the Syrian crisis.

The paper then presents legal remarks by the Refugee Platform in Egypt on Egyptian legislation and procedures against Syrian citizens, while also discussing the main argument used by the Egyptian regime to return Syrians to Syria as a ‘safe country’, and concludes with practical solutions on how to proceed with the repatriation of Syrian citizens to ensure a safe exit from Egypt, when returning to their homeland, without endangering Syrian citizens lives. The paper also presents a vision for future mechanisms that contribute to improving the quality of civil treatment, so that human beings are valued, their rights are respected, and their dignity is promoted, thereby reflecting a commitment to humanitarian principles and international laws. 

First, changes in Egyptian policies regarding the entry, residency, and living conditions of Syrian citizens in Egypt:

1- Drastic changes due to the change of political administration in Egypt (summary of 2012 to 2024):

Since the outbreak of the Syrian revolution in March 2011, the Egyptian authorities allowed Syrians to enter Egypt without the need for a visa prior or additional security clearances upon or before their arrival, which was the default legal condition. Additionally, the tourist residency was easy to obtain, with permits ranging from one to three months, which facilitated the residence of Syrian citizens without the need for many of them to go through the UNHCR asylum process.

Nevertheless, in July 2013, after the political changes in Egypt with the removal of the late President Mohamed Morsi and the appointment of Chancellor Adly Mansour as interim president, authorities imposed new restrictions on the entry of Syrian citizens. A prior visa and security approval became prerequisites for entry, which was a major shift from the default conditions. Despite these restrictions, Syrians with residency status in countries such as the United States, Schengen, Britain, and Canada were exempt from the requirement to obtain security clearance to enter Egypt. 

During this time, the process of issuing ‘security approval’ began to escalate, with tourism companies extracting this approval under the umbrella of various Egyptian security agencies. According to sources with whom Refugee Platform spoke, “the security coordination process was carried out since 2013 through a group of companies, some affiliated with the General Intelligence Service and others affiliated with the National Security of the Interior Ministry. These companies collect fees that vary in American dollar value per person to obtain the security approval that allows people to enter Egypt for the duration of the issued visa, which does not provide the right to reside,” and was termed the ‘National Security Visa’ or ‘Intelligence Visa’ within Syrian communities in Egypt, depending on the affiliation of the company that finalized the coordination process.

Since late 2013, many Syrians have faced great difficulty entering Egypt, and those registered with the UNHCR were prevented from exiting Egypt before requesting the closure of their files. This rapid change in entry policies has prevented many families from reunification plans in Egypt, hindered refugees, migrants, and asylum seekers from finding a safe haven to seek asylum, as well as posed a major obstacle for students wishing to study in Egypt. All this forces Syrian citizens to resort to alternative routes, even if they are deadly unlawful routes, by entering from Sudan on a journey through the desert where people are exposed to various forms of exploitation and abuse.6 This takes place while Egyptian authorities do not carry out search and rescue operations, where dozens of people were documented to have died on this route in several different cases.7 

On the other hand, the removal of legal protection for Syrian citizens (whether registered with the UNHCR or not) strengthened hate speech and provocation. This incitement was adopted by many media outlets in Egypt against Syrian citizens in Egypt, and provided the basis for legal violations. Human rights organizations documented the targeting and harassment of Syrian migrants, asylum seekers, and refugees in Egypt, including forced deportation, refusal of entry, and deportation without due legal diligence or judicial procedure. The UNHCR’s 2022 report noted the forced return of five Syrians, including three registered refugees. The Refugee Platform also monitored cases of forced deportation of Syrian citizens under the pretext of ‘public interest’ including the decision to deport Khaled Riad al-Khatib in February 2021 and Yamen Ibrahim al-Bitar in September 2022, without providing them with an opportunity for legal appeal.

Egypt forcibly deported Syrian refugees to Damascus in January 2013 and almost deported 13 more Syrian citizens before international organizations intervened, according to Human Rights Watch. In July of that same year, the organization revealed that Egypt threatened to deport 14 refugees, migrants, and asylum seekers, as well as a member of the Syrian National Council. In October 2013, Amnesty International called on the Egyptian authorities to halt the forcible

deportation of 36 Syrian refugees to Damascus, and, in April 2014, to halt the deportation of two more Syrian refugees and another asylum seeker. In November of that same year, the organization called on Egyptian authorities again to halt the forcible deportation of 56 refugees. 

In July 2023, following the Cabinet’s approval of the draft law on asylum for foreigners on June 7th, a decision was issued by the Central Administration for Expatriate Student Affairs in Egypt to raise the university enrollment fees for expatriates to $2,000 American dollars, excluding Syrian citizens for the first time since they began arriving in Egypt.8 In September of that same year, the Egyptian Ministry of Education issued a decision to set tuition fees for expatriate students in public schools, which, unusually, did not exclude Syrians.9 

In February 2023, the Syrian presidency announced on their Telegram channel that ‘Egyptian Foreign Minister Sameh Shoukry visited Bashar al-Assad and conveyed a message from Abdel Fattah al-Sisi in which he emphasized Egypt’s solidarity with Syria, Egypt’s readiness to continue their support, Egypt’s pride in the relationship between the two countries, and Cairo’s keenness to strengthen this relationship and develop joint cooperation between the two countries.’ This visit, which the Refugee Platform in Egypt warned against for fear of its impact on the situation of Syrian refugees, migrants, and asylum seekers in Egypt, was followed by harsh and illegal decisions against Syrian citizens. 

Starting in July 2024, the authorities banned the renewal of tourist residency permits for Syrian citizens, and Syrians reported that they were informed by the security services that they must leave Egypt and return to Egypt again to submit a tourist residence permit every six months.10 This was a procedure implemented without an official decision, and reports of this procedure’s implementation were from different government offices. This indicates that the procedure is a general decision and not an individual incident. Syrian citizens can no longer obtain a tourist residency permit, as security approval from the National Security Agency has become a prerequisite. All while sources, with whom Al-Monitor researchers spoke with, state that “since early 2024, a review process has been conducted on the files of Syrian citizens residing in the country to issue deportation orders for some of them”; based on what sources reported as a “danger to public security.” The sources also stated that the security coordination process is currently being done solely through National Security companies, not the General Intelligence Service. 

As people were prevented from renewing their residence permits, students from families that were prevented, at different stages of education, were denied access to education. This development was based on numerous grievances received by the Refugee Platform in Egypt during 2024 from families of students whose applications to public schools were rejected. Consequently, the Egyptian authorities were causing panic within refugee communities in general after raiding and closing community schools for some refugee nationalities and expatriates residing in the country. Furthermore, students and teachers were arrested and deported outside the country on a national scale that involved many governorates, including the

capital of Cairo, Giza and Alexandria. During which it was reported that the security authorities conducted arrests of non-Syrians as well. 

According to sources from the Passport Administration, ‘no tourist residency permits were granted to Syrians during 2024, and all applications were rejected without a clear response or ignored completely.’ If an application is rejected, the applicant is given seven days to leave the country.

The Refugee Platform in Egypt considers this course of action as a means of restricting the right to freedom of movement and residence, which causes greater risk and harm for migrants, asylum seekers, and refugees. Moreover, the denial of access to civil rights and liberties, specifically the right to seek asylum, explicitly contradicts Egypt’s ratified international obligations, including the principle of non-refoulement and non-discrimination enshrined in international conventions.

In July, the Egyptian government canceled the exemption for Syrian minors living in Egypt from residency fees, which meant paying a settlement for past years’ residency fees was now required. This cancellation was executed without an official announcement or directive from the Immigration and Passports Department. 11 Previously, the Egyptian government exempted Syrian children under the age of 16 from paying residency fees as well as any fines imposed on those who failed to obtain residency. The government demanded that Syrian minors pay late fines of 5,000 Egyptian pounds for each year they were not enrolled in school, retroactively, only to surprise parents by demanding sums of up to 30,000 Egyptian pounds when issuing residency for the first time, in order to enroll their children in school.12 

In August 2024, enrollment in public schools became limited to holders of an asylum card, provided that the student as well as their parents hold a valid residence permit.13 90% of Syrians in Egypt do not hold an asylum card as the UNHCR only registered 150,000 Syrians according to reports issued by the organization. Moreover, the Egyptian government statistics estimate there to be approximately 1.5 million Syrian citizens inside Egypt. Regardless of the accuracy of these numbers, the sudden implementation of this decision a few weeks before the start of the academic year caused confusion for thousands of Syrian families whose children study in Egypt. Resultantly, these families were forced to resort to private education and thus were forced to suffer from Egyptian private education’s exorbitant costs.

In the same month, Egypt issued a decision to cancel exemptions for Syrian citizens from visa and residency fees, and then began collecting fees according to new laws at a value of $25 American dollars.14 In September, ‘student’ residency fees in Egypt for Syrian citizens increased by more than 200% without an official announcement; as Syrians who went to renew their residency were surprised by the increase where fees reached 7,000 Egyptian pounds instead of 2,100 Egyptian pounds.

In October, the Department of Expatriate Affairs and Welfare in Egypt issued a statement imposing administrative fees for services provided at Egyptian universities; and, for the first time, Syrians were not exempt from them.15 According to the statement, the new fees included a range of services that Syrian citizens used to pay for in Egyptian pounds, unlike other expatriates and nationalities, but this year the prices doubled and had to be paid in American dollars. 

2 – Recent changes:

Following the fall of Bashar al-Assad’s regime in Syria, the takeover of the government by armed opposition groups on December 8th, 2024, along with the formation of an interim caretaker government, Egyptian policies towards the entry and residence of Syrian citizens underwent additional and rapid changes.

According to Refugee Platform sources, an internal decision was issued to deport any Syrian citizen arrested for any reason by security services regardless of their legal status and whether they are refugees or residents. According to the Egyptian Initiative for Personal Rights, Egypt deported three Syrians who celebrated the fall of the Assad regime.16

The Refugee Platform in Egypt emphasizes that this protocol directly contradicts Egypt’s domestic legislation and the principle of non-refoulement, which obliges states not to relocate refugees, migrants, and asylum seekers to countries where they may face persecution or danger. 

On December 14th, 2024, a new decree was issued canceling the exceptions that were granted to Syrian citizens with residency in the United States, Schengen, Britain, and Canada, thus making prior security clearance a mandatory requirement for all Syrian citizens entering Egypt. The decision was implemented immediately and without prior notice, which led to many Syrians who were unaware of the new procedures being denied entry and returning from Egyptian airports.

The Refugee Platform in Egypt believes that imposing additional security requirements on a specific category of refugees is discriminatory, especially if there are no clear security justifications and specific procedures officially announced to all stakeholders. 

On December 29th, 2024, the Egyptian Civil Aviation Authority, which is part of the Egyptian Civil Aviation Ministry, issued a circular to the directors of airline companies and agencies, a copy of which was seen by the Refugee Platform in Egypt, that was addressed from the head of the Civil Aviation Authority to ‘airlines and agency companies operating in Egypt’ regarding ‘issuing a decision not to allow the acceptance of Syrian passengers coming to Egypt from various countries around the world.’ The directive excluded ‘temporary residence holders for non-tourism in the country’ while emphasizing that ‘the necessary administrative fines will be applied if companies violate these instructions.’ 

The Red Sea Authorities also issued a statement on their Facebook page about Egyptian-Jordanian cooperation to ‘facilitate the return of Syrians to their country through

Nuweiba seaport’ while confirming that ‘the first wave of Syrians returning to their country left Nuweiba seaport on the ferry Ayla, were comprised of 40 people, and were transported by the Jordanian company JETT via buses from their residences in Cairo to the port, then to the Jordanian port of Aqaba, and then transferred to the Jaber Border Crossing between Jordan and Syria’s border to return to their homeland.’17

While media outlets circulated this statement, the platform could not verify the statement’s information, nor could we contact any returnees to confirm whether or not they were forcibly deported or expelled. 

At the same time, the recent period witnessed security campaigns targeting Syrian citizens living in Egypt. One of the most prominent cases documented was the arrest of Syrian activist Laith Fares al-Zoghbi who lives in the city of Hurghada in the Red Sea governorate.18 His arrest came days after he posted a video in which he asked the Syrian consulate in Egypt to take down the flag of the former Syrian regime and replace that flag with the flag of the Syrian revolution, in a move that reflects political shifts after the fall of Bashar al-Assad’s regime. 

Security forces raided Zoghbi’s apartment and arrested him, which raised questions about the reasons for his arrest that also included his status as a refugee however this is a purely legal and not criminal charge. The arrests extended to others, amid reports of the deportation of some Syrian citizens and the detention of others, during a tense security situation following the celebrations of the fall of the Syrian regime.

Since the beginning of the ongoing developments in Syria, the Syrian Embassy in Cairo issued various statements for individuals whose passports have expired as well as those wishing to return to the country.19 The embassy offered them the possibility of extending their passport for six months, free of charge for one time, where the renewal period starts from the date of extension. The goal of this offer was to facilitate the completion of citizens’ transactions within the country of residence, while the embassy noted that this procedure wont allow passports to be used to travel abroad as airlines do not accept this procedure.

In another post, the embassy noted that ‘due to the impossibility of issuing passports for technical reasons under the current circumstances, and in response to frequent inquiries from fellow citizens who wish to return to Syria and do not have valid passports, the embassy would like to clarify that they can be granted a free passage document to return to Syria, given that obtaining the passage ticket is done on the same day without prior appointment.’20

3 – Security clearance:

Security clearance is an administrative procedure imposed by the Egyptian authorities as a prerequisite for allowing certain nationalities to enter the country, including Syrians, and to carry out specific procedures within Egypt such as obtaining residency permits or traveling to certain

areas. This procedure requires prior approval from the relevant security authorities (e.g. National Security or General Intelligence), based on a thorough background check and assessment of the person’s case.

The application process includes filling out a form containing the following information: Full name (in Arabic and English), nationality, date and place of birth, passport number, occupation, academic qualifications, current residence address, phone number, email address, date of arrival in Egypt, purpose of visit, expected length of stay, and place of residence within Egypt. The following documents must also be attached: A copy of the applicant’s passport, personal photos, and proof of residence in Egypt.

Types of security approval:

Types of approval are divided into different categories according to their mechanism of issuance as well as the authoritative body responsible for their issuance. Generally, a Syrian citizen applies for an advance visa through the Embassy of the Arab Republic of Egypt in their country of residence and attaches an application for the necessary security approval with the visa application. This application includes all the data required to process the approval. These applications are processed and the applicant is notified of the acceptance or rejection of the visa based on their application results. 

As the number of applications increased, embassies were unable to process applications quickly enough, leading to a significant backlog. As a result, the number of issued visas decreased compared to the number of applications, which contributed to the emergence of companies that facilitate security approvals in shorter periods of time. These companies offer their services at varying prices, starting from $300 for a permit, up to $1,500 for a General Intelligence permit, and $3,000 for a National Security permit. This was until December 8th, 2024, when the General Intelligence permit was suspended and the cost of the National Security permit increased to $5,000. 

Profiting from the tragedy:

According to the True Egypt Facebook page, security clearance became a business, and the cost changed due to the fluctuations in regional situations, reaching $3300 for Sudanese after the proxy war began, and $2300 for Syrians after the fall of Bashar.21 This inflation is in addition to the hundreds of dollars of cost for Yemenis and other nationalities. This money goes to a network of foreign and Egyptian intermediaries as well as Egyptian tourism companies that, through their connections, monopolize on the issuance of security clearances from sovereign agencies. The brokers offer Syrians two types of security approvals: the first is ‘slow’ and takes between 15 to 30 days for $1150-1200; and is issued by a security agency through a tourism company.

The second: ‘Fast’, and takes between 3 days to a week from the date of application at a cost of $2200-2300. This approval is issued by a second agency through two other companies, according to Syrian brokers.

According to the True Egypt Facebook page, security clearance requires a valid passport and round-trip flight reservations for those seeking slow clearance. Travelers must not have previously entered Egypt in an unlawful manner, and travel from Syria must be via Syrian Airlines, and from outside Syria via EgyptAir. Sudanese citizens are also required to book through EgyptAir, according to guidelines that brokers state are required for security approval.

A Syrian middleman reported that middlemen get, at most, $50 or $100 of what each traveler pays, and an Egyptian middleman makes about the same amount, whereas companies associated with the security services keep most of the money.

Second, a bitter reality that requires urgent solutions. How have these decisions affected the lives of Syrian citizens?

These aforementioned decisions have disrupted the lives of Syrian refugees, migrants, and asylum seekers who are either registered or unregistered with UNHCR, as follows:

1- Responding to ongoing changes from 2013 to early 2024:

Egyptian government decisions to impose security approval on Syrian citizens’ entry visas to Egypt since 2013 led to severe restrictions on the migration movement of Syrians. This directly affected their right to asylum and stability in the country, which forced people to resort to unlawful routes for transit and residence. This caused serious human rights violations against them to occur due to the decisions’ removal of legal protection for Syrian citizens. Despite the presence of large numbers of Syrians in Egypt, the absence of a clear legal system that recognizes them as official refugees, migrants, and asylum seekers has further complicated their circumstances.

These conditions resulted in a constant state of instability for Syrian citizens, as they were affected by frequent changes in political decisions that had a direct impact on their daily lives thereby making their livelihood completely unstable over the past few years. 

One of the most prominent challenges Syrian citizens face is the high costs associated with renewing residency permits and obtaining security clearances, whether to travel, return to Egypt, or continue residence. This burden was compounded by the exclusion of Syrian citizens from the exemption granted since 2013 from tuition fees for basic education. This forced many Syrians to resort to private schools, whose exorbitant tuition fees are not comparable to Egyptian public schools. This puts a great deal of pressure on low-income families with minors who are still studying or continuing their education. These exorbitant fees created a huge gap between refugees, migrants, and asylum seekers and their ability to access basic resources, like education, healthcare, and civil rights.

In an attempt to alleviate these burdens, some Syrian citizens were forced to apply for asylum with the UNHCR to escape the costs associated with residency and education. Nevertheless, this was not enough to ensure that they receive their basic rights; especially considering the number

of asylum and residency applications have increased since the outbreak of the proxy war in Sudan. This resulted in long delays of anywhere between one to two years in processing these applications. This delay caused thousands of Syrian citizens, specifically those without residency permits, to be denied access to basic services such as education, healthcare, and civil rights. As a result, many Syrian children lost a year or more of schooling because they were unable to enroll, which deepened the humanitarian and social crisis that Syrian refugees, migrants, and asylum seekers in Egypt face.

Moreover, Syrians’ issues are exacerbated by the instability of their legal status, leading many of them to live in unlawful conditions that expose them to serious human rights violations and undermine their ability to lead a dignified life. The lack of a fair asylum system that protects the rights of refugees and allows them to access various services has contributed to their suffering. Many Syrian citizens were denied the right to legal protection from exploitation, and many have reported over the past several years that they were exploited due to the uncertainty of their legal position under the weight of fluctuating legislation.

At the same time, the lack of legal protection has denied refugees, migrants, and asylum seekers access to the justice system. This allows perpetrators of crimes and violations against them to go unpunished. This situation has also contributed to hate speech, incitement, and misinformation about refugees, migrants, and asylum seekers as well as their reasons for residing in Egypt, further worsening their social and psychological conditions. 

Through interviews conducted by the Refugee Platform in Egypt with community leaders and Syrian refugees and expatriates residing in Egypt as part of different legal frameworks, as well as through cases documented by the platform and by analyzing the consultation requests the platform received during the previous period, we conclude that Syrian migrant communities in Egypt are facing a significant increase in their fear of further legal restrictions including shifts in the Egyptian political administration towards Syrian citizens’ presence. Most of them expressed their unwillingness to return to Syria, at least currently, for many reasons; the most prevalent of which are uncertainty about the security situation and a lack of a viable source of income if they return.

Concerns have increased since the beginning of 2024, specifically since the Syrian refugee communities in Egypt, despite all the challenges they faced, participate prominently in the Egyptian macroeconomic system. This participation had a considerable positive impact on the Egyptian economy, as well as on Syrian expatriate communities in Egypt, which constitutes a relative but incomplete stability. 

The changes in the current entry and residency process and, before that, the denial of services through various administrative decisions provokes a state of instability in Egypt for these communities of all backgrounds. These changes result in a kind of ‘push-back’ that violates international obligations and relies on provoking a state of ‘insecurity’ in the host country.

2 – Responding to changes from the beginning of 2024 to present-day:

At the beginning of 2024, when the issue of non-renewal of tourist residency permits for Syrians in Egypt came to light, and the security approval required for these residency permits was either denied or not issued, many Syrian citizens rushed to seek alternative solutions to ensure their legal residence. Among the available options, some registered asylum applications with the UNHCR, while others chose to establish companies in Egypt to obtain investment residency instead, which is a type of residency that allows for longer residency periods and bypasses the complexities of tourist residency. 

Although security clearance is required for all types of residency, the process is faster and smoother for investment residency. Nonetheless, this option is not available to everyone, as establishing a company in one of the legally recognized forms of capital companies requires that the company’s capital exceed $35,000 USD and be fully deposited in dollars or the equivalent in Egyptian pounds at a bank.  

This financial requirement is a major obstacle for most Syrians, as this amount is only available to very few people. As a result, the least expensive and theoretically easiest option is to register with the UNHCR to obtain a legal document that enables them to reside in Egypt legally. Nevertheless, this option does not necessarily guarantee access to all the rights and services that refugees, migrants, and asylum seekers need.

In their 16th regional report on the ‘Syrian Crisis’, the UNHCR stated that ‘as of February 25th, 2025, there are 142,300 registered Syrian refugees, migrants, and asylum seekers in Egypt, representing 15% of the total number of registered refugees in Egypt’.22 The report goes on to note that there exists ‘a rise in requests to close cases from Syrian applicants.’ Over the past few months, the UNHCR has received ‘6,120 requests affecting more than 12,516 individuals since early December 2024; a significant increase from the November average of 7 to 111 requests per day.’ 

Indeed, the number of registered refugees decreased by more than 5,800 people from December 22nd, 2024 to February 25th, 2025 alone. The report continues by stating that ‘at the same time, the number of new asylum applications submitted by Syrians to UNHCR in Egypt has fallen to a third of previous levels. Between December 8th, 2024 and February 24th, 864 new registration applications were submitted, an average of 16 per day compared to 45 per day before the new regime came to power in Syria.’ 

In a previous report, the UNHCR emphasized that ‘for refugees in Egypt, regardless of their nationality, closure requests are required when requesting an exit permit to leave. The decision to return (for Syrians) from Egypt, which does not share a land border with Syria, is therefore particularly consequential.23Although Syrian refugees registered with UNHCR and holding asylum-based residency are not affected by these restrictions, the announcement led to an

eight-fold increase in reactivation requests per week for Syrians until December’ the report concluded, citing the impact of the residency decisions on future ‘reactivation’ applications.

Earlier, the UNHCR reported, in their December 19th regional report, the perspectives and concerns expressed by refugee communities in the Middle East, particularly in Egypt, Jordan, Lebanon, Iraq, Turkey and Jordan, regarding the evolving situation in Syria.24 In the immediate aftermath of the fall of the Assad government, ‘many refugees expressed enthusiasm and renewed hope for a future in Syria, while remaining cautious. Many expressed interest in returning.’ 

Most refugees adopted a ‘wait-and-see’ approach, emphasizing the need for clarity on several critical issues. Refugees also highlighted or questioned the continued presence of non-state armed groups and their associated risks, including unexploded ordnance and criminal activity. They also expressed concern over the limited infrastructure in Syria, whether their homes were destroyed, whether their families were able to access healthcare, or whether their children were able to go to school, while others noted the economic challenges in Syria, including the collapse of the Syrian economy. 

The report emphasized that ‘in Egypt, many expressed no desire to return, with a small minority expressing interest, but mostly not within the next twelve months’, which was confirmed by Refugee Platform researchers through interviews they conducted for this report.

Third, Legal comments from Refugee Platform in Egypt:

The recent measures taken by Egyptian authorities, including the suspension of tourist residency renewals for Syrian citizens, exceptions for security clearances, as well as unannounced security instructions on the immediate deportation of Syrian expatriates regardless of their legal status, are a clear restriction of refugees’ rights. They may also constitute a clear violation of Egypt’s constitutional and international obligations to protect refugees and ensure respect for international human rights. 

1- Regarding the Egyptian constitution and laws:

Article 93 of the Egyptian Constitution stipulates that the state is obligated to implement the international treaties and agreements Egypt ratifies, which means that these agreements acquire legal force within the national system. Egypt has signed and ratified many international conventions and treaties. Accordingly, the state has a responsibility to respect and promote the rights of refugees, asylum seekers, and migrants; which requires ensuring that they are not subjected to any arbitrary or discriminatory treatment as this aligns with Egypt’s international human rights obligations.

In this context, the Foreign Asylum Law No. 164 of 2024, which was approved by the President of the Republic on December 16th, 2024, specifically addresses the issue of voluntary return of refugees. Article 25 of the law stipulates that this return is organized in coordination with the UNHCR and the refugee’s country of nationality, with the aim of ensuring a safe and dignified return of refugees without exposing them to serious danger. Article 13 of the same law prohibits the return of a refugee to their country if their life or freedom is threatened, reflecting an obligation to protect them from refoulement as one of the fundamental principles of refugee rights. 

Nevertheless, despite these legal provisions, the new law has been widely criticized by civil society organizations, as they expressed reservations about the lack of effective implementation mechanisms to ensure that refugees are definitively protected.25 These criticisms indicate that the law lacks sufficient legal safeguards to prevent refugees from being subjected to human rights violations, especially in light of the long history of human rights violations committed by security agencies against them.26

Against this backdrop, recent measures such as the suspension of tourist residency permits for Syrian refugees, migrants, and asylum seekers and the imposition of selective security conditions, as well as the forced deportation of some of these expatriates, raise legal concerns about the compatibility of these policies with the Egyptian constitution. These measures may violate the rights of refugees enshrined in the constitution, as well as in international conventions that Egypt has committed to implementing, which calls for the need to reconsider these policies and ensure their compatibility with domestic and international legal standards. 

2 – Regarding international agreements and commitments:

As we have already detailed, the Egyptian Constitution obliges the regime to respect the international conventions Egypt has signed, as these conventions have the force of law and/or domestic legislation: The Universal Declaration of Human Rights (1948), the International Covenant on Civil and Political Rights (1966), the International Covenant on Economic, Social and Cultural Rights (1966), the Convention on the Elimination of All Forms of Racial Discrimination (1965), the Convention on the Rights of the Child (1989), the Convention on the Elimination of All Forms of Discrimination against Women (CEDAW) (1979), the United Nations Convention against Transnational Organized Crime (2000), the Protocol to Prevent, Suppress and Punish Trafficking in Persons, specifically women and children, and the Organized Crime Convention (2000).

The 1951 Convention relating to the Status of Refugees and its 1967 Protocol obligate states to protect the rights of refugees and ensure that they are not forcibly returned to places where they may face persecution or danger. The 1969 Organization of African Unity (OAU) Convention on the Status of Refugees obliges member states to provide protection and assistance to refugees fairly and without discrimination, and to prevent their forcible return to areas that may threaten their safety. Therefore, the measures recently approved by the Egyptian authorities may constitute a double violation of both domestic legislation and Egypt’s international obligations.

3 – The legality of security clearance:

The exclusion of a specific nationality from entering Egypt and the imposition of exceptional procedures, such as requiring prior security clearance, in addition to charging fees for security clearance forms for Syrians, raise serious legal and human rights questions. These measures contradict the principle of non-discrimination enshrined in international and domestic laws, raise concerns about transparency in the application of government policies, and raise suspicions of profiteering and exploitation of migrants in dire humanitarian situations such as fleeing armed conflict.27

• Discriminatory Aspect:

It should be noted that it is not permissible to discriminate between nationalities regarding the conditions of entry into Egypt, or to impose exceptional requirements on a specific group without clarifying the objective reasons that justify these measures. Imposing exceptional security requirements on Syrian expatriates and citizens violates international principles that guarantee equality and non-discrimination between individuals on the basis of nationality or origin.

• Charging Fees and Illegal Profiteering or Racketeering:

Charging fees for these applications adds another layer of legal concerns, as a group of people are forced to pay money in order to fulfill entry requirements set by administrative bodies. These fees place an undue financial burden on refugees, migrants, and asylum seekers who often have no other options due to their humanitarian circumstances. This may deprive some of them of their right to asylum or mobility, and create an environment in which their needs and conditions may be exploited for unjustified financial gain. 

Fourth, is Syria safe?

In light of recent developments in Syria, after armed opposition took control of the country and the fall of Bashar al-Assad’s regime, serious questions arise regarding the safety of returning to Syria before national circumstances fully stabilize; specifically given the complex humanitarian and security challenges posed by the Syrian refugee crisis. Despite the overthrow of the former regime, the situation on the ground remains unstable. The United Nations High Commissioner for Refugees (UNHCR) warned against rushing to repatriate Syrian citizens, emphasizing the need to ensure their return is voluntary, safe and dignified, as well as in accordance with international standards that protect the rights of refugees migrants, and asylum seekers.28

On the other hand, some European countries decided to suspend accepting of asylum applications for Syrian citizens after the fall of the regime, which was widely criticized by international human rights organizations. Amnesty International emphasized that the situation in Syria is still turbulent, and that ending decades of repression and abuses will not be achieved overnight.29 The organization also warned against using the issue of Syrian refugees as a political ploy, jeopardizing Syrians’ safety for vapid political gains. 

The main pretext for European countries stopping the reception of Syrian asylum applications, or allowing their deportation, is that Syria has become a ‘safe country’ after the fall of the regime. Nevertheless, the gravity of Syrian citizens’ reality is painfully apparent to these countries however Europe is dominated by the far-right fascists in Europe’s decision-making, who are infamous for their hostility against immigrant communities from the global South. Such calls raise concerns about the future of Syrian refugees, migrants, and asylum seekers and create a hostile environment towards them.

In this context, Egypt demonstrated caution towards the new developments in Syria after Ahmed al-Sharaa took over the country’s affairs temporarily in December 2024. Egypt emphasized the nation’s support for the unity and sovereignty of Syria while calling for comprehensive dialogue between Syrian parties. With the announcement that al-Sharaa would assume the presidency of Syria in January 2025, Egyptian President Abdel Fattah al-Sisi congratulated his Syrian counterpart, while expressing his hope for stability and development for Syria. The two sides also met on the sidelines of the Arab Summit in March 2025, where Sisi emphasized the importance of an inclusive political process and Syria’s reintegration into the Arab world. 

The Egyptian authorities should adopt a neutral stance toward the new Syrian regime, while ensuring that they do not export crises to it nor should they use Syrian refugees, migrants, and asylum seekers as a tool for political pressure. Simultaneously, promoting a misleading image that the situation in Syria has stabilized must be avoided, especially if said representation is at the expense of the rights and suffering of Syrian refugees. Alternatively, Egypt should focus on taking deliberate and transparent action that ensures the protection of Syrian refugees, migrants, and asylum seekers, and their rights, while maintaining a humanitarian approach that balances Egypt’s international responsibilities with progressive, regional circumstances. This requires a careful assessment of the conditions on the ground to ensure that returnees are not exposed to any danger that may threaten their lives or dignity. 

Fifth, Conclusion

Egypt’s rapid changes in entrance policies and accompanying restrictions since July 2013 have forced Syrian expatriates and citizens to seek alternative routes, even if they are unlawful and deadly, by entering from Sudan route through the desert where people are subjected to various forms of human rights violations, exploitation, and abuse, where dozens of deaths were documented on this path. 

The removal of legal protection for Syrians (whether or not they are registered with the UNHCR) forced many Syrian refugees, migrants, and asylum seekers to live in unregulated conditions that render them vulnerable to serious human rights violations, impair their ability to lead a dignified life, prevent them from accessing the justice system, social services, or necessary resources, and expose them to exploitation. 

Additionally, one of the most prominent challenges that Syrians faced was struggling with inflated costs associated with renewing residency permits and obtaining security approvals, as well as exorbitant education fees after the cancellation of the exemption of Syrian citizens from tuition fees.

Afterwards, following the overthrow of Bashar al-Assad’s regime in December 2024, other decisions and security measures were taken, which affected family reunification as well as Syrians communities’ economic and social conditions. This led to an increase in requests to close asylum files to start repatriation to Syria, despite the unstable conditions in Syria taking place until now.

Given the legal and procedural status of Syrians in Egypt, Egyptian legislation and security practices represent a clear violation of Egypt’s constitutional and international obligations to protect refugees, migrants, and asylum seekers and ensure compliance with human rights, particularly the 1951 Convention relating to the Status of Refugees and its 1967 Protocol, as well as the 1969 Organization of African Unity Convention. 

What measures should Egypt implement to make repatriation safe for Syrians?

When considering the repatriation of Syrian refugees, migrants, and asylum seekers, the Egyptian government should keep in mind the main reasons why these refugees left Syria in the first place. These reasons revolve around the unstable security conditions, political repression, and human rights violations. Therefore, Egypt must ensure that returnees are not subjected to any form of abuse, including detention, exploitation, or inhumane treatment. Egypt must also not threaten the economic and social security achieved in refugee communities, without providing an opportunity to stabilize the conditions involved.

To achieve this, the following actions should be taken:

• Coordinate with the United Nations High Commissioner for Refugees (UNHCR):

The Egyptian government should work closely with UNHCR to ensure that repatriation is voluntary and safe, and aligns with international standards that prohibit forcible return to areas where refugees may be at risk. UNHCR should oversee all stages of the repatriation process to ensure that the rights of returnees are respected. 

• Assess the security situation in Syria:

An accurate and comprehensive assessment of the security situation in Syria, specifically the areas from which Syrians expatriates were forcibly displaced and to which they are expected to return, should be conducted, which includes the stability of those areas and their absence of armed conflicts or unrest. This assessment must include ensuring the existence of an independent judicial system and human rights protection mechanisms to prevent any potential human rights violations of returnees, as well as the reconstructing of key sectors and housing that were damaged and providing access for basic services in the majority of residential areas. 

• Ensure the legal rights of returnees:

Ensure that returnees have the necessary legal documents, such as identity cards and birth certificates, to ensure that they can access all their civil rights, as well as guarantees of justice for victims and survivors. This includes maintaining a comprehensive justice system without exclusion or discrimination, which requires studying each case individually to guarantee these civil liberties and the availability of supporting documents for each case.

• Provide special protection for the most vulnerable refugees, migrants, and asylum seekers: 

Special protection must be executed for marginalized groups that are likely to face additional discrimination or fall under the description of ‘most vulnerable, such as women, unaccompanied children and minors, as well as the elderly.

• Cooperation with international and local organizations:

Coordination with humanitarian organizations and international institutions is required to support reconstruction processes in Syria, ensuring a conducive environment for returnees.

Sixth, Recommendations

The Egyptian government must:

• Fully adhere to the principle of non-refoulement of migrants, asylum seekers, and refugees with different residency statuses with respect to Syria, specifically in light of precarious security conditions.
• Issue official and transparent decisions on the entry and residency policies of Syrian citizens and expatriates, as well as publish them continuously to the public while also giving sufficient time to implement these decisions in order to avoid random enforcement and unannounced procedure changes that cause confusion and violations of the human rights of refugees, asylum seekers, and migrants.
• Provide adequate legal protection for Syrians residing in Egypt, including providing and facilitating access to various services such as education, health, and litigation, while ensuring that they are not subjected to human rights violations and exploitation.
• Eliminate discriminatory measures that target certain groups, including Syrians.
• Reconsider the imposition of requirements on certain nationalities, such as the requirement for security clearance, whether to obtain a visa or to obtain a residence permit in Egypt; and reverse the imposition of exorbitant administrative fees whether when issuing a residence permit or fines for delays and past residency.
• Stop bureaucratic targeting and security harassment of civil society organizations and allow them to provide services to migrants, asylum seekers, and refugees, including Syrians, as well as decriminalize the provision of assistance to unlawful refugees, asylum seekers, and migrants.