United Nations High Commissioner for Refugees (UNHCR)
Sudanese citizens fleeing war at a Renk transit center, South Sudan, April 2024.

Legal confusion as UNHCR resumes refugee registration despite new law

Mohamed Napolion
Published Wednesday, September 2, 2026 - 17:29

The United Nations High Commissioner for Refugees (UNHCR) announced on Tuesday an updated schedule for registration and identity card renewal services across Egypt, openly resuming frontline operations just days after a landmark law stripped the agency of its mandate and formally transferred asylum management to the Egyptian government.

The move by the UNHCR, set to take effect on Sept. 6 for all nationalities, exposes a state of “extreme ambiguity and conflict between legislative text and reality on the ground,” according to Nour Khalil, executive director of the Refugees Platform in Egypt (RPE).

Khalil told Al Manassa that the contradiction proves the decades-old international system remains the only functioning mechanism on the ground.

Under the updated schedule, UNHCR partitioned operations across its offices by service type. The agency designated Sundays, Tuesdays, and Thursdays for “file closures,” a procedure that mandates the physical presence of all family members.

Mondays and Wednesdays will handle “card renewals, data modifications, and the addition of family members,” requiring only a single family representative.

UNHCR also opened new registration applications on all weekdays with single-person attendance, launched digital applications for Sudanese nationals, and assigned its 6th of October City office alongside an email portal to process “file reopening” requests.

The agency emphasized that pre-scheduled interview appointments dispatched via SMS will not change.

Since 1954, UNHCR has administered Egypt’s asylum apparatus, conducting refugee status determination and issuing official identification, while Egyptian authorities limited their role to granting residence permits pegged to UNHCR-issued cards.

However, the 2024 asylum law transferred these competencies entirely to the “Permanent Committee for Refugee Affairs,” an executive body subordinate to the prime minister and staffed by representatives from the foreign, justice, interior, and finance ministries.

UNHCR’s latest announcement signals a direct resumption of its traditional duties, creating what Khalil described as a dangerous dual-system impasse.

“We now face two systems under an active asylum law,” Khalil said. “One has operated for decades, remains active, and holds over one million registered people whose registration confers rights and legal status. Simultaneously, we have a hypothetical, theoretical government system that remains incomplete both on paper and institutionally.”

Khalil warned that this institutional split breeds deep uncertainty over legal jurisdictions: “Who is responsible for what now?!”

The clash unfolds as hundreds of thousands of refugees and asylum seekers already face systemic distress within the registration pipeline due to severe delays by Egypt’s Ministry of Interior in issuing residence permits.

The bottleneck deprives refugees of essential public services including education, healthcare, and formal court access, such as notarizing legal powers of attorney.

“Right now, we have one million registered people practically stripped of services and protection because of the interior ministry,” Khalil said. He noted that while the ministry pledged last year to scale up residence permit issuance, the increase failed to close the deficit, trapping refugees and asylum seekers in “a state of forced documentation deprivation they did not choose.”

Neither UNHCR nor the Egyptian government has published or established any transitional framework for individuals already registered with the agency, Khalil said, reiterating that authorities are using this “legislative ambiguity to inflict further livelihood, humanitarian, and legal precarity on refugees.”

To resolve the impasse, Khalil argued that the most urgent demand is for Egyptian state institutions to formally recognize UNHCR-issued documentation, guaranteeing migrants and asylum seekers access to basic services and shielding them from forced deportation.

Khalil proposed that the prime minister issue an immediate decree suspending the implementation deadlines of the asylum law's executive regulations until legislative, technical, and institutional readiness is achieved, supported by a clear transitional blueprint lasting at least five years.

He further urged the head of the Permanent Committee for Refugee Affairs to assemble three expert subcommittees focused on rectifying legislative defects, building administrative capacity, and drafting the transition plan, stressing that authorities must treat UNHCR documentation as an established "legal status that underpins personal stability and human rights."