EIPR campaign against biometric surveillance and surveillance-enabling legislation in Egypt (2020–ongoing)

The Egyptian Initiative for Personal Rights (EIPR)'s campaign on biometric surveillance and surveillance-enabling legislation represents Egypt's primary civil-liberties advocacy effort specifically targeting the legal architecture of state biometric and digital surveillance. Unlike Masaar's parallel campaign — which focuses on technical documentation of censorship infrastructure, strategic litigation challenging internet-blocking authority, and Arabic-language civil-society capacity-building — EIPR approaches the same surveillance state from a broader civil-liberties register: domestic legislative opposition, international human rights mechanisms via its INCLO membership, and UN and African Commission submissions that translate Egyptian and MENA civil-society experience of authoritarian surveillance into the formal language of international AI governance. The campaign operates on two fronts: resisting the expansion of state surveillance powers through Egyptian legislative reform processes, and shaping international norms on biometric surveillance and facial recognition technology (FRT) in counter-terrorism contexts through coalition submissions.

Egypt's accelerating biometric surveillance state (2020–2025)

The campaign's context is Egypt's rapid build-out of a biometric surveillance infrastructure across the 2020–2025 period. The foundations predate 2020: Egypt established its Permanent National Committee for Security Coordination of the Video Surveillance Camera System in 2015 and began procuring facial recognition equipment from US, European, and Asian suppliers in the same period; the Arab Organization for Industrialization began manufacturing domestic CCTV cameras from 2021. The most visible infrastructure expansion has been in the New Administrative Capital (NAC), a planned city under construction east of Cairo that received its first residents in 2022 equipped with over 6,000 CCTV cameras supplied by Honeywell and operated from a central command-and-control facility with "sophisticated video analytics" for crowd monitoring, incident detection, and surveillance of suspicious persons. The Ministry of Interior has launched a facial recognition mobile application (MOIEG-PASS) requiring citizens to scan their national ID and face biometrics for government service access. Egyptian officials announced deployments of facial recognition cameras in streets and metro stations before backing down from public comment, suggesting an awareness that the announcements would generate international human rights scrutiny. Egypt's Central Bank unveiled the Haweya biometric ID platform in November 2025, combining facial recognition, fingerprint, and digital signature for financial inclusion.

Alongside the infrastructure expansion, the Egyptian state's legal framework for surveillance has been under active development. The Cybercrime Law No. 175 of 2018 has been enforced aggressively from 2020 onwards — EIPR's Civil Liberties Unit documented 151+ individuals charged under Article 25 across 109 cases between 2020 and 2025. Egypt has been confirmed as a user of both Predator (Cytrox) and Pegasus (NSO) commercial spyware, with the Citizen Lab documenting targeted deployment against former presidential candidate Ahmed Eltantawy in May–September 2023. The November 2020 arrests of three EIPR staff members — Gasser Abdel Razek, Karim Ennarah, and Mohammed Basheer — in the days following a meeting with 13 Western ambassadors underlined that Egyptian state surveillance was actively monitoring EIPR's own communications and movements; this experience shaped EIPR's subsequent heightened focus on the architecture of state surveillance in its legislative and international advocacy work.

INCLO and the African Commission (2023–2025)

EIPR's most explicitly biometric-surveillance-focused international advocacy has run through its membership in the International Network of Civil Liberties Organizations (INCLO), a global coalition of national civil-liberties bodies. In response to the African Commission on Human and Peoples' Rights' June 2023 inception workshop on AI, robotics, and emerging technologies, EIPR co-submitted formal comments to the African Commission alongside the Kenya Human Rights Commission (KHRC) and Legal Resources Centre (LRC) of South Africa. The joint submission, published in August 2025, drew on INCLO's "Eyes on the Watchers: Challenging the Rise of Police Facial Recognition" principles document and addressed the specific human rights challenges posed by FRT and biometric surveillance in African contexts — including the risks of mass biometric collection without democratic legal mandates, the inadequacy of counter-terrorism exception frameworks for authorising surveillance-state infrastructure, and the need for the African human rights system to develop a coherent framework on AI and automated-decision systems. EIPR's representative for the submission was Karim Medhat Ennarah, EIPR's Criminal Justice Director and the same person arrested in November 2020 in the Egyptian state's most high-profile documented targeting of a named civil-liberties organisation.

This submission represents EIPR's most direct contribution to the international AI governance discourse from the Egyptian civil-society perspective. The African Commission process is ongoing; formal outputs had not been issued as of mid-2026. EIPR's contribution — grounding the African Commission framework discussion in Egyptian and MENA experience of authoritarian FRT deployment — is the substantive input: it channels the documentary knowledge the organisation has accumulated through legal aid, surveillance documentation, and repression of its own staff into an international standard-setting process that covers the continent in which Egypt's surveillance state operates.

INCLO "Toxic Surveillance" co-endorsement and UN mechanisms (September 2025)

In September 2025 EIPR co-endorsed the INCLO position paper "Toxic Surveillance: Counter terrorism laws don't justify unchecked FRT deployment", submitted as input to a UN call for comment on the human rights implications of AI in countering terrorism. The submission, co-endorsed by EIPR as one of 11 INCLO member organisations, argues that counter-terrorism law frameworks cannot provide legitimate authorisation for unchecked FRT deployment by law enforcement: the vagueness of terrorism definitions, the due-process deficits of security-agency operations, and the disproportionate impact of biometric surveillance on dissidents, journalists, and minority communities make the counter-terrorism exception a structural threat to the civil-liberties limits the submission argues must govern any state FRT use. The submission draws directly on the experience of INCLO member organisations — including EIPR — in documenting how counter-terrorism frameworks are deployed in practice in their jurisdictions: in the Egyptian context, as instruments for targeting civil society organisations, opposition figures, and ordinary content creators alongside any genuine security threats.

Criminal Procedure Code advocacy (February–September 2025)

EIPR's domestic legislative front has centred on the proposed revision of Egypt's Criminal Procedure Code. In February 2025 EIPR co-signed — with Access Now, Article 19, the Committee to Protect Journalists, and 9 further organisations — a joint statement "Privacy under attack: Egypt must reform its draft Criminal Procedure Code" targeting Articles 79, 80, and 116 of the draft Code. The statement objected to provisions that would allow investigating judges to monitor social media, email, and private messages for renewable 30-day periods, and that would extend interception authority to prosecutors without judicial oversight — a first under Egyptian law. The statement situated these provisions within the broader context of Egypt's documented Predator and Pegasus spyware infrastructure: the existing legal framework had already enabled targeted commercial spyware against dissidents; the proposed amendments would add a general statutory surveillance authority that could normalise mass digital monitoring alongside the targeted surveillance already documented.

In September 2025, President Sisi declined to sign the draft Code. EIPR and co-signatories of the February statement welcomed the refusal as a privacy protection outcome. The Code may return in revised form; the surveillance provisions EIPR opposed represent a recurring legislative pattern — a periodic attempt to codify in statute surveillance powers the state already exercises through extra-legal or emergency authority.

UPR submission (January 2025)

Ahead of Egypt's fourth Universal Periodic Review cycle, examined by the Human Rights Council on 28 January 2025, EIPR co-submitted joint concerns on the right to privacy in Egypt alongside Privacy International, the Association for Freedom of Thought and Expression (AFTE), and the Association for Progressive Communication (APC). The submission covered Egypt's Cybercrime Law No. 175 of 2018 as an instrument of mass digital surveillance, the proposed Criminal Procedure Code's surveillance expansion, and the broader pattern of digital monitoring of civil society organisations, journalists, and opposition figures. The UPR mechanism provides a quadrennial channel for civil-society organisations to place national surveillance architectures before the international community; EIPR's participation keeps the Egyptian surveillance state in the formal UN human rights record alongside its more targeted INCLO work.

Posture within the Egyptian digital rights landscape

Within the corpus, this campaign occupies a position distinct from Masaar's digital surveillance campaign while targeting the same Egyptian state apparatus from a different angle. Masaar's work is technical-documentation-first — OONI measurement partnerships, Sandvine DPI equipment identification, Anti-Cybercrime Law constitutional challenges — and its international dimension runs through digital-rights coalitions (MENA Coalition to Combat Digital Surveillance) rather than the civil-liberties treaty-body channel. EIPR's campaign operates at the civil-liberties end of the spectrum: it brings the legislative and human rights mechanisms tools the organisation has developed across criminal justice, religious freedom, and political-prisoner work to bear on the surveillance-state problem. The two campaigns are complementary — Masaar names and documents the infrastructure; EIPR challenges the legal frameworks that authorise it and brings the Egyptian experience to international standard-setting bodies. The overlap is that both organizations name the same surveillance tools (Predator, Pegasus, Sandvine) and the same legislative vehicles (Cybercrime Law, draft CPC) as threats; the divergence is in where they fight: technical documentation and domestic courts for Masaar, international mechanisms and legislative advocacy for EIPR.

EIPR's engagement with biometric surveillance specifically (as distinct from digital surveillance broadly) runs primarily through the INCLO channels — the ACHPR submission and the "Toxic Surveillance" co-endorsement are the corpus's two most directly FRT-focused actions in the Egyptian-led MENA civil-society sphere. They position EIPR as the Egypt link in INCLO's global network of civil-liberties organisations building an international normative framework against unchecked state FRT use — one where Egyptian experience of a surveillance state that has deployed commercial spyware, launched mass biometric infrastructure, and used surveillance-assisted targeting against civil-society organisations grounds the abstract AI governance argument in documented reality.