Telling an international body what a government would prefer to keep quiet takes courage. Organisations that submit shadow reports, and the women whose experiences inform them, can face pressure or retaliation at home. RFLD’s manual, Reporting on the Maputo Protocol: a manual for shadow reports, treats reprisals as a real risk to plan for. It also shows that the African Commission has tools to respond.
What the rules say
The Commission’s 2020 Rules of Procedure contain clear protections. Rule 74 obliges States Parties to ensure that there are no reprisals against persons who give information to the Commission. That covers organisations submitting shadow reports and individuals who speak at sessions.
Rule 107 extends protection in the communications procedure, where individual complaints are examined. It covers victims, complainants, their families and representatives, witnesses and experts.
These rules matter. When a State delegation appears before the Commission, it does so under an explicit commitment not to punish those who have engaged with the process.
A dedicated focal point
In 2014, the Commission adopted Resolution 273, which added reprisals to the mandate of its Special Rapporteur on Human Rights Defenders. The mandate is now called the Special Rapporteur on Human Rights Defenders and Focal Point on Reprisals in Africa.
The Commission’s Fact Sheet No. 1 on Reprisals, published in November 2023, describes the functions of the mechanism:
The mechanism gathers information on alleged reprisals and keeps a database of cases. It provides guidance on urgent cases and reports at each session of the Commission. It also follows up with the States concerned.
For shadow reporters, this means there is a named mandate within the Commission to contact if something goes wrong. The manual’s risk check asks coalitions to decide in advance who will contact the Focal Point on Reprisals if a problem arises, and how.
Anonymity for authors
The Commission’s 2022 Guidelines on Shadow Reports say that shadow reports are published with the authors’ names. Authors who fear retaliation may ask for anonymity. The manual encourages coalitions to discuss this openly. In a joint report, one member may be comfortable being named while another, working in a more hostile environment, is not. The Guidelines require all signatories to be listed, so any request for anonymity needs to be agreed and made clearly at the time of submission.
The five-point risk check
Before submitting, the manual asks every team to work through a short risk check:
- Could any person or organisation named in the report face retaliation?
- Have you removed all identifying details from case descriptions?
- Does any coalition member need to request anonymity?
- Who will contact the Focal Point on Reprisals if a problem arises, and how?
- Are digital copies of evidence stored securely?
These questions are short. Answering them properly may take a coalition meeting. They should be answered before the report leaves the organisation, since a published report cannot be recalled.
Protecting the women behind the evidence
Anonymity for authors does not protect the individuals described in a report. That protection depends on the care taken during documentation and drafting. The manual’s Module 5 asks authors to remove identifying details from every case description, keeping in mind that a combination of small details can reveal a person’s identity in a small community.
On communication, the manual recommends a single spokesperson for the coalition. This keeps the message consistent and avoids exposing members, or survivors, to unwanted attention. Press releases can be prepared in national languages, and coalition members can give interviews, but always within an agreed plan.
Digital safety
Much of the evidence behind a shadow report now lives on phones, laptops, shared drives and messaging apps. Interview notes and recordings can identify people if they fall into the wrong hands. The manual’s risk check includes secure storage of digital evidence as a standing question. Coalitions should agree who holds the evidence and who can access it, and record this in the coalition agreement.
Reprisals as evidence
Pressure on civil society is itself a human rights issue that the Commission follows. When the Kenya National Commission on Human Rights submitted its own shadow report on Kenya’s reports under the Charter and the Maputo Protocol in 2021, its topics included the intimidation of NGOs. A shadow report can document the environment in which civil society works, provided this is done with the same care as any other evidence.
Safety first, then visibility
The manual’s position is consistent throughout: no submission is worth putting a woman or an organisation at serious risk. In many cases, risks can be reduced with good planning. In some cases, the safest choice is to work through a regional partner, to rely on public data, to limit what is published or to wait for a later review.
Engaging the African Commission is a right. The rules are designed to protect those who use it. Knowing those rules, and planning for the worst, allows organisations to engage with confidence. RFLD’s report on online violence against women in West and Central Africa offers further background on digital risks facing women’s rights defenders.
About the report
This article draws on RFLD’s report Reporting on the Maputo Protocol: a manual for shadow reports, published on 4 October 2026. Read the summary, download the English edition or the French edition.
