No Model of Refuge: Sudanese Refugees in Egypt

By Devon Cone , Daniel P. Sullivan | February 21, 2025

Executive Summary

The war in Sudan has created the world’s largest forced displacement and hunger crisis, severely affecting both the country and the region. Some 12 million people have been displaced, including more than 3 million to neighboring countries. Of these, Egypt hosts the largest number of Sudanese refugees. In Egypt, the policies on paper suggest a more welcoming environment than in countries like Chad, Ethiopia, and South Sudan. However, the reality is that Sudanese refugees in Egypt face increasing protection challenges including the risk of forced deportation back to Sudan. A new Asylum Law, adopted in December 2024, purports to bring Egypt into alignment with international standards and best practices, but, in reality, threatens even greater dangers to Sudanese refugees.

The law’s vague national security provisions including the right to exclude and/or revoke refugee status, the lack of consultation with the UN Refugee Agency (UNHCR) and NGOs, and the absence of transitional measures or appeal processes threaten to further marginalize asylum seekers and refugees. It also risks undermining an already skeletal support system for Sudanese who have fled to Egypt, by criminalizing those deemed to have arrived illegally and the efforts of those seeking to help them. Without significant intervention, this legal framework risks legitimizing arbitrary detentions and deportations, leaving refugees with few avenues for protection.

The bylaws that will define the specific implementation of the law are to be developed over the first six months of 2025. Egypt’s history of refugee policy and recent trends leave much room for concern. Refugees in Egypt have formally been entitled to access healthcare, education, and freedom of movement, but the situation on the ground tells a different story. Government authorities are shutting down schools serving Sudanese children, hospitals often deny care, housing and other basic needs are unaffordable, and the risk of detention and deportation is a constant threat. In the last several months, Egyptian authorities have conducted raids in Sudanese neighborhoods. Sudanese people in Cairo – both with documentation and without – fear being sent back to Sudan. Forcing people back to Sudan is against the international legal obligations that Egypt signed, including the 1951 Convention on the Status of Refugees. This deteriorating protection environment leaves refugees, particularly women and girls, increasingly vulnerable to exploitation, abuse, and even refoulement.

Sudanese women and girls, many of whom fled high levels of sexual violence in Sudan, continue to face risks of gender-based violence (GBV) in Egypt. With limited mental health and psychosocial support (MHPSS) services available, their trauma remains largely unaddressed. While Sudanese civil society organizations (CSOs) and grassroots networks work tirelessly to provide assistance, they often operate under the radar to avoid scrutiny. Meanwhile, UNHCR, which is overstretched and under-resourced, struggles to advocate for refugees’ rights and has been largely ineffective in engaging Egypt to change or amend its restrictive policies.

To address these growing challenges, urgent international action is needed. Key donors supporting Egypt, particularly the European Union who have given billions of dollars in aid, must use their influence to push back against Egypt’s new restrictive asylum policies, and pressure Egypt to reopen community schools and cease refouling Sudanese refugees back to a country in the middle of a brutal civil war. And while the current U.S. administration is unlikely to positively engage Egypt on asylum, U.S. Members of Congress can play an important role in countering claims that Egypt is a model for asylum policy and leverage future U.S. financial support.

Additionally, greater support should be directed toward refugee-led organizations (RLOs), which play a crucial role in aiding and protecting refugees on the ground. Without decisive intervention, the situation for Sudanese refugees in Egypt – a country that purports to be a model for refugee policy – will only continue to worsen, jeopardizing the safety and future of hundreds of thousands of displaced individuals.

Recommendations

The Egyptian government should:

Solicit the input and expertise of UNHCR and civil society to amend Law No. 164 of 2024, the “Law Regarding the Asylum of Foreigners,” and while drafting the bylaws that will define the law’s implementation over the next several months.
Recognize Sudanese as prima facie refugees in light of the ongoing conflict and stop deporting Sudanese back to Sudan.
Work collaboratively with the administrators of Sudanese schools in Egypt to ensure that they have the proper documentation and licensing to reopen and serve their students.
Allow Sudanese refugees who are registered with UNHCR to obtain work permits by removing some of the requirements, including the need for a passport and visa, as well as making it easier and more transparent to obtain the security clearance associated with work permits. Allowing Sudanese refugees to work will also make it easier for them to pay for the rising cost of housing.
Support the efforts of Sudanese community-based organizations (CBOs) in Egypt, including by removing provisions in the new Asylum Law that would criminalize providing informal assistance to asylum seekers.

UNHCR Egypt should:

State publicly and clearly that several provisions in Egypt’s new Asylum Law will not protect refugees and asylum seekers, will risk violating their rights, and contravene international standards and obligations. These provisions include wide latitude to deny asylum based on vague national security threats, criminalization of people and/or organizations that assist asylum seekers, and a lack of defined rights for asylum seekers as opposed to recognized refugees.
Formally request access to detention facilities in order to monitor the conditions and access Sudanese individuals who the Egyptian authorities might be unlawfully refouling.
Continue to improve and expand its registration and refugee status determination (RSD) capabilities until such time that these processes are transitioned to the Egyptian government under the new Asylum Law.
Adequately train the Egyptian government on refugee protection and international standards for reception, registration, RSD, and data management.
Develop robust referral mechanisms to assist survivors of GBV so that they can get medical care and psychosocial support.

Donor countries should:

Urgently push Egypt to engage UNHCR, other international organizations, and civil society in consultations to develop the bylaws of the new Asylum Law.
The EU, which has pledged to invest heavily in Egypt through its “Comprehensive Strategic Partnership,” should suspend funding for migration with Egypt until protection guarantees in line with international standards are included in the bylaws of Egypt’s Asylum Law.
Support NGOs and CBOs and their community-based protection efforts, assistance, initiatives, and programs that expand access to MHPSS for GBV survivors.

Methodology

In mid-December 2024, Refugees International visited Cairo to assess the situation of Sudanese refugees in Egypt and learn more about the current state of the war in Sudan. The research focused on the experiences and challenges of Sudanese women. The team interviewed dozens of Sudanese women, all of whom fled Sudan since the war began in April 2023. In addition to all being refugees in Egypt, many of the women Refugees International interviewed are activists, medical doctors, and community leaders. The team also met with local non-governmental organizations, international NGOs, community-based organizations, human rights organizations, independent experts, U.S. government officials, and the UN High Commissioner for Refugees (UNHCR) office in Egypt. The team visited many neighborhoods in and around Cairo to meet with Sudanese refugees and organizations working with them. This research and report builds on earlier Refugees International research trips to Sudan’s borders with Egypt, South Sudan, Chad, and the Nuba Mountains in Sudan since the crisis began in April 2023.

Background

The war in Sudan has triggered the world’s largest humanitarian crisis, leaving nearly half of the country’s population of 50 million people in need of aid and displacing at least 12 million people. The latest Integrated Food Security Phase Classification (IPC) report confirms that famine is widespread and is expanding. This massive crisis of forced displacement and humanitarian need has profoundly impacted both Sudan and the surrounding region. More than 3.2 million people have fled to neighboring countries, with Egypt receiving more Sudanese refugees than any other nation since the conflict began in April 2023. The Egyptian government estimates that 1.2 million Sudanese have arrived in Egypt since April 2023, of which just over 600,000 are registered with UNHCR. Almost 75 percent are women and children. But local and international NGOs suggest the true number of Sudanese refugees in Egypt is significantly higher.

Cairo hosts the largest concentration of Sudanese refugees in Egypt, where many attempt to integrate into local communities while navigating the complexities of their legal status. This report highlights the experiences of Sudanese women and girls in Egypt—an overlooked aspect of an already underreported crisis.

Egypt’s situation differs from that of other primary refugee destinations like Chad and South Sudan, where formal refugee camps exist. In theory, the Egyptian government grants Sudanese refugees a significant array of rights, including access to education, employment, and healthcare. However, in practice, these rights are limited, and Egyptian authorities are increasingly adversarial. The Refugees International team heard from several refugees and NGOs working with them of rising numbers of Sudanese detained and deported, not only near the border but also in urban areas, particularly around greater Cairo.

Sudanese women and girls face particularly harsh and unique challenges. First, huge numbers of Sudanese women experienced sexual violence in Sudan and have never received medical or MHPSS. Second, in Egypt, they are often subjected to harassment, exploitation, and abuse without access to legal protection or support services. Third, single women head many households, their husbands remaining in Sudan or seeking employment in countries like the United Arab Emirates (UAE) and Saudi Arabia. Finally, Sudanese women live in constant fear for their children’s safety, worried about the threat of abuse from a host community that is growing more resentful, or worse, the risk of detention and deportation.

The Conflict in Sudan

The current drivers of displacement from Sudan to Egypt are primarily rooted in the ongoing conflict in Sudan. The brutal power struggle between the Sudanese Armed Forces (SAF), the paramilitary Rapid Support Forces (RSF), and allied militia has resulted in pervasive violence and insecurity. The fighting since April 2023 has been marked by attacks on civilians and civilian infrastructure, blocking of humanitarian aid, widespread sexual violence, and ethnically targeted killings. In December 2023, the U.S. government made an official atrocity determination, citing that the RSF and SAF had committed war crimes and that the RSF and allied militias were responsible for crimes against humanity and ethnic cleansing. An updated atrocity determination in January 2025 found the RSF responsible for genocide.

This internal conflict has created an environment of fear and instability. All of the Sudanese women the Refugees International team talked to described stories of extreme violence sparking their decision to flee. Many of the professional women interviewed, including several medical doctors, detailed the numerous death threats they received from both SAF and the RSF.

Furthermore, many of the women Refugees International spoke to highlighted the high rates of gender-based violence (GBV) in Sudan as one of the main reasons they fled to Egypt. Even in the capital Khartoum, armed soldiers are using rape as a weapon of war, and human rights groups report that sexual violence is widespread. Sudanese women with adolescent daughters, in particular, explained to the Refugees International team that they fled to Egypt with their children specifically to protect their daughters from rape. One woman in her 50s who worked as a doctor in Sudan told the team, “If I told you stories of rape in Sudan, you would be shocked. You wouldn’t even be able to believe them.” Another woman described widespread rape, GBV, trafficking, sexual slavery, and the omnipresent threat of sexual violence, saying, “This is a war on the body of women. No one knows the number, but ask the community, and it is clearly widespread.” A third woman explained, “I had to leave. I had no choice. I have two teenage daughters, and there is nowhere safe for them in Sudan, or me for that matter.” Hunger and disease also drive Sudanese to leave. Several of the refugees with whom Refugees International spoke described growing difficulties in finding food while they were in Sudan and the rapid spread of illnesses in places like Port Sudan, to which many initially fled. As one woman told the team, “In Sudan, if you do not die from gunshot, you will die from hunger or disease.” In December 2024, the latest assessment of the IPC Famine Review Committee cited more than half of the population of Sudan as food insecure, including five areas of Sudan facing famine, with five more expected to reach famine levels by May 2025.

Why Sudanese Come to Egypt

Most Sudanese refugees who have managed to flee since the war began have relocated to neighboring countries, including Egypt, Chad, South Sudan, and Ethiopia. The largest number of these have traveled to Egypt. Egypt is quite different from other African countries in that there are no refugee camps, and the economic situation is arguably better. Furthermore, Sudanese refugees often choose Egypt over other countries due to its cultural, linguistic, and historical ties with Sudan. Both nations share Arabic as their primary language and have a predominantly Sunni Muslim population, creating an environment of cultural familiarity. These similarities ease the transition for Sudanese refugees, allowing them to integrate more easily into Egyptian society. Additionally, Egypt’s proximity to Sudan provides a sense of continuity and connection to their homeland, which is particularly important for those who view their displacement as temporary.

Economic and logistical considerations also play a significant role in this choice. Compared to Gulf countries like Saudi Arabia or the UAE, Egypt offers a more affordable cost of living, which is crucial for refugees with limited financial resources. Many Sudanese families already have ties to Egypt, whether through property ownership, education, or personal travel, making it a practical destination. Furthermore, the existing Sudanese diaspora creates a relatively supportive network.

For many Sudanese refugees, staying in Egypt also represents a strategic decision to remain close to their homeland. This proximity allows them to monitor developments in Sudan and stay connected with family members who may still be there. It also aligns with their aspirations to return and participate in rebuilding Sudan when it becomes safe.

How Sudanese Come to Egypt

Most Sudanese refugees have reached Egypt through the southern border with Sudan. In the first days of the crisis, tens of thousands of Sudanese fled north, amassing near the Sudanese town of Wadi Halfa, awaiting visa approvals or travel documents. Those with means arrived via flights, often from Port Sudan. Today, refugees continue to arrive via smuggling networks. Official statements estimate that at least a few hundred arrive daily. Given the restrictions on regular entry, many Sudanese refugees have no other option but to enter by smuggling, encountering grave risks en route. These include extortion, frequent road accidents, targeting by authorities, and in some cases death.

Challenges for Sudanese Refugees in Egypt

Despite Egypt being the country receiving the most Sudanese refugees and the one with the most welcoming policies on paper, it is not an easy or, in many cases, safe place for Sudanese refugees to stay. Sudanese refugees in Egypt, particularly women, face numerous challenges that impact their safety, well-being, and ability to rebuild their lives. Most Sudanese refugees arrive in Egypt having just survived traumatic experiences in Sudan, only to face limited access to food and essential services, along with ongoing risks of exploitation, GBV, and the threat of forced return to Sudan. During conversations with dozens of Sudanese women and NGOs, several key challenges emerged.

Faisal, one of the main neighborhoods in Cairo where Sudanese refugees live, in December 2024. Photo by Daniel P. Sullivan/Refugees International.

First and foremost, their lack of legal protection and documentation makes Sudanese refugees fearful of arrest and deportation. The lack of legal documentation also affects their ability to integrate in many other ways, such as accessing education and healthcare. Second, their economic situation and lack of financial support make their lives in Egypt difficult and precarious. Third, their inability to access education or healthcare is deeply frustrating to Sudanese refugees, especially to Sudanese women who are caring for children, elderly family members, or those with disabilities. And finally, increasing hostility from the Egyptian community is instilling fear in them and their families, limiting their comfort in interacting with the host community.

The Legal Framework

In 1981, Egypt became a signatory to the 1951 Refugee Convention and its 1967 Protocol. These international agreements formed the basis of refugee protection in Egypt. However, rather than having specific domestic legislation, general immigration laws governed refugees, and the Egyptian government delegated refugee status determination (RSD) and other related functions to UNHCR. Furthermore, Egypt attached reservations to several provisions of the Convention, including those related to employment, public education, and social assistance, which have limited refugees’ access to these rights. These reservations, combined with the lack of comprehensive domestic refugee laws, have created gaps in protection and integration. Refugees often face restrictions on work, limited access to public services, and vulnerability to exploitation and abuse. In recent years, the influx of Sudanese refugees has tested Egypt’s capacity to respond, highlighting the need for a more robust legal framework. A new Asylum Law passed in late 2024 seeks to update this legal framework, but comes with several concerns.

The New Asylum Law

Egypt recently passed a new law reforming the asylum process. The law was purportedly promulgated in response to ongoing issues refugees face in Egypt and to exert more control over the refugee situation in the country. Law No. 164 of 2024, published on December 16, 2024, is Egypt’s first comprehensive asylum law since its signing of the 1951 Refugee Convention and Memorandum of Understanding with UNHCR signed in 1954. According to the Egyptian government, the “Law Regarding the Asylum of Foreigners” provides more explicit guidelines, in line with international standards, about the rights and responsibilities of refugees in Egypt and the role of the government.

However, lawyers and human rights defenders with whom the Refugees International team spoke, warned that the ambiguity of the law threatens to lead to fewer rights and more deportations of refugees and asylum seekers, in contradiction of international standards and obligations. In particular, critics cite the creation of the Standing Committee For Refugees’ Affairs (SCRA), a committee made up of several ministries with authority to remove refugee status and deny asylum for vague reasons of national security or for failing to respect the “values and traditions of Egyptian society.” This analysis is shared by a wide range of local and international human rights groups including seven special mandate holders within the UN Human Rights Council who warned that the asylum law, if enacted, “would fall significantly short of international human rights and refugee law and other relevant standards.”

Under the law, a newly formed SCRA will take over UNHCR’s long-standing role in interviewing, registering, and protecting refugees in Egypt. The SCRA will also adjudicate cases, coordinate with international organizations and NGOs, and facilitate resettlement, deportations, and any other major decisions when it comes to the outcome of refugee cases. Although government control of these processes is not inherently a problem, the Egyptian government has historically failed to consistently or comprehensively respect the rights of its own citizens, let alone those of refugees. The development of the law itself also came without consulting UNHCR, NGOs working with refugees, or refugees themselves. One NGO told the Refugees International team, “we are the ones who actually work with the refugees and know what they are going through here. They [the Egyptian government] should have at least consulted with us.”

Perhaps most concerning about the new law is the inclusion of provisions that would criminalize both irregular entry and providing informal aid to asylum seekers. Criminalizing illegal entry into Egypt and criminalizing those who “employ or shelter” asylum seekers and possibly unregistered or undocumented refugees would put hundreds of thousands of Sudanese refugees at risk of prosecution and/or deportation. It would also be dangerous for Syrians, Ethiopians, and other refugees who similarly receive virtually no support from the Egyptian government and who rely on NGOs, CBOs, and community members for their survival.

Furthermore, it will undoubtedly have a chilling effect on the few community-based organizations (CBOs) that are providing minimal aid to other Sudanese refugees in the absence of government support or support from UNHCR. Even before the law, it was difficult for CBOs to operate in Egypt because the government would not allow many of them to register their organizations, thus limiting their ability to get funding and to operate freely. Despite these restrictions, however, CBOs have still been one of the main ways Sudanese refugees who have arrived in Egypt since April 2023 have received any support.
Finally, while the law outlines the rights of recognized refugees to be protected such as freedom of movement, freedom to work, access to basic healthcare, education, and several other rights, it does not spell out those same rights for asylum seekers. Given that hundreds of Sudanese are entering Egypt every day, the huge backlog of asylum seeker cases currently with UNHCR, and the time it takes to grant them refugee status, the law must enshrine protection for asylum seekers as well as refugees.

Thousands of Sudanese asylum seekers gathering outside of the UNHCR office in 6th of October City where UNHCR registers them and conducts interviews, December 2024. Photo by Devon Cone, Refugees International.

UNHCR should state publicly and clearly that Egypt’s new Asylum Law, as written, will not protect refugees and will risk violating their rights. It should engage Egypt towards amending the law and developing its bylaws to be in line with its international obligations. Furthermore, donor countries, namely EU member states, should condition their bilateral aid to Egypt on the Egyptian government improving the asylum law so that it complies with international standards. Donors should also insist that Egypt consults UNHCR and relevant NGOs towards amending the law and while drafting the bylaws. Finally, UNHCR should train Egyptian authorities how to register refugees and conduct RSD with refugee protection as the primary priority before Egypt’s takeover of UNHCR processes.

The bylaws that will spell out the specifics for implementing the new law are to be developed over the first six months of 2025. But the latest risks come alongside a long history of problematic asylum policies in Egypt and amid months of deteriorating protections for Sudanese in the country.

Protection Realities for Sudanese Refugees

Sudanese migration to Egypt is not new. There has been a long history of Sudanese people migrating to Egypt for safety or other opportunities. In 2004, Egypt and Sudan signed the Four Freedoms Agreement, granting citizens of both countries the rights to freedom of movement, residence, work, and property ownership within each other’s territories. This agreement aimed to strengthen bilateral relations. However, shortly after the war began in Sudan in mid-2023, the Egyptian government suspended the provisions of the Agreement. This made it much more difficult for Sudanese refugees to enter and stay in Egypt legally. The move also limited some of their previously guaranteed rights.

Refugees International documented some of these changes in a report that found that by mid-June 2023, all Sudanese nationals were required to obtain a visa from the Egyptian consular office in Wadi Halfa or Port Sudan. The Refugees International team spoke to many Sudanese refugees who were unable to do this so their only choice was to enter irregularly.

Furthermore, once in the country, the asylum process for Sudanese refugees in Egypt has historically been fraught with challenges, primarily due to bureaucratic hurdles and a lack of clear legal frameworks. UNHCR is responsible for registering asylum seekers and determining their refugee status. Several Sudanese women the Refugees International team interviewed reported that they had UNHCR registration appointments in late 2025 or even into 2026. Even once a Sudanese refugee is registered, they still wait for an appointment to receive an asylum seeker card. Issued by UNHCR, these asylum seeker cards are supposed to protect refugees from deportation. However, Refugees International heard of several cases in which Egyptian authorities deported Sudanese refugees possessing UNHCR asylum seeker cards, either because they did not have their cards with them at the time of arrest or the Egyptian authorities ignored the documentation completely. As early as mid-2023, the Egyptian government even deported Sudanese refugees who UNHCR recognized as refugees.

As of February 3, 2025, UNHCR had registered 633,792 Sudanese as either asylum seekers or refugees, a little more than 200,000 of those having received full refugee status. Currently, the Egyptian government affords the same rights to both asylum seekers and recognized refugees. Even if Sudanese arrivals complete the registration process, obtain asylum seeker cards, and in some cases, gain refugee status, Sudanese refugees still face significant challenges. UNHCR and the limited number of NGOs in Egypt are overwhelmed by the influx of Sudanese arrivals, leaving most asylum seekers and refugees without assistance.

From March 31, 2023, until December 31, 2024, the number of Sudanese refugees seeking registration with UNHCR increased by 892 percent. Although refugees live throughout Cairo, the waiting areas outside of the UNHCR office in 6th of October City visually represent this almost 1,000 percent increase of Sudanese in the last year and a half. As of the beginning of December 2024, UNHCR Egypt was more than 62 million dollars short of what they needed to provide the most basic services, namely timely documentation to Sudanese and other refugees.

Refugees International toured areas where Sudanese await UNHCR appointments. There were thousands of people, perhaps even tens of thousands. Mothers, elderly people, children, and people with disabilities all wait to be seen by UNHCR, which has limited staff and capacity. Refugees International talked to a woman who had been sleeping on the ground for days in front of the office, hoping to be given an appointment and talk to someone. She explained, “Even though my appointment is not for many months, I have nowhere to go. I have no help in this city, and I can’t afford an apartment, so sleeping here is likely safer than anywhere else.”

Although UNHCR has organized lines, maximized its space for waiting areas, provided information screens in Arabic, and prioritized vulnerable cases, the demand remains immense. The sheer number of Sudanese refugees in Egypt far exceeds its capacity to respond effectively. UNHCR has arguably done what it can with the resources it has. Donor countries need to increase their contributions immediately to ensure that as more Sudanese refugees arrive in Egypt in 2025 and perhaps beyond, UNHCR will actually be able to assist them and it will be worth their while to register.

Many Sudanese refugees the Refugees International team interviewed did not even bother registering with UNHCR. They had visas they had to renew every six months for a fee, but they were receiving money from relatives abroad. Moreover, they had either experienced or knew other Sudanese refugees approaching UNHCR, waiting in long lines for up to 12 hours just to be told to come back the next day. One woman recounted the acute feeling of lack of dignity felt by her husband after returning after a day of waiting in line for nothing. Another woman Refugees International interviewed said, “I have heard about fights breaking out at UNHCR, people sleeping everywhere, waking up at 3 am to travel so far outside the city for these appointments. It sounds like a nightmare, and I already lived through my own nightmare when I left Sudan.”

The transition of refugee determinations to Egyptian authorities amid such challenges, without any formal transition period or transparent handover from UNHCR, under the new law, raises serious questions about how the already large backlog will be addressed. Furthermore, it is as yet unclear whether those who have already been determined by UNHCR to be refugees, will be subject to new determinations under Egyptian authorities.

Mass Arrests and Deportations

In the past, obtaining UNHCR registration, even with the backlogs and difficulties, provided one of the main sources of protection for refugees in Egypt, notably preventing arrest and deportation. But recent trends indicate this is no longer the case, as Egyptian authorities have stepped up arrests and deportations, in some cases reported to the Refugees International team, even for those with UNHCR cards or pending UNHCR appointments. The security-centered new law, with its ambiguous language and apparent omission of UNHCR, leaves the Egyptian authorities with even more room to arbitrarily deem asylum seekers as illegal and ramp up deportations.

All of the refugees the Refugees International team spoke to, regardless of their legal status, cited the fear of deportation back to Sudan as their most formidable concern. The head of a community-based organization working with Sudanese refugees echoed this sentiment stating, “The biggest issue right now is deportation.”

Several interviews with refugees and groups assisting them indicate that, indeed, the Egyptian government has been scaling up its efforts to arrest and deport Sudanese since September 2023, when they deported at least 3,000 Sudanese. Furthermore, between January and March 2024, the Egyptian government forcibly returned more than 800 Sudanese individuals before even allowing them to lodge asylum claims. Whereas most deportations used to take place near the border of Egypt and Sudan, increasingly, the Egyptian government is intensifying its efforts to arrest and deport people from urban areas, including Cairo. Refugees and NGOs told the Refugees International team that Egyptian authorities have been conducting searches in neighborhoods where many Sudanese live. Several refugees reported knowing people detained and deported even if they had pending appointments with UNHCR or, in some cases, even if they had a UNHCR card confirming their refugee status. As one NGO told the team, “A few years ago, we could tell refugees that if they had a UNHCR card, they would be safe from deportation,” but that this was no longer true.

One of the main challenges in understanding the full extent of deportations is that the Egyptian government does not grant UNHCR or NGOs access to detainees. While the lack of access makes estimates difficult, reports from various sources substantiate that the Egyptian authorities have arrested and detained Sudanese people in Egypt with various forms of documentation. During 2024, through October, reports estimate the Egyptian government had deported more than 18,000 people, mostly Sudanese. They have held vulnerable Sudanese including pregnant women and survivors of GBV in deplorable conditions without access to lawyers or UNHCR representatives. UNHCR must be granted access to these detainees to ensure that they have access to asylum and that the Egyptian government is safeguarding their rights.

Egyptian authorities must also stop detaining and deporting Sudanese refugees, asylum seekers, or those who plan to seek asylum. Given how difficult it is to obtain the proper documentation, Sudanese refugees should not be penalized if they do not have it. Forcefully sending Sudanese back to an active warzone violates international legal obligations and will exacerbate the humanitarian crisis in Sudan. As a signatory to the 1951 Refugee Convention and its 1967 Protocol, Egypt is bound by the principle of non-refoulement, which prohibits returning refugees to a country where their lives or freedoms would be at risk. Beyond legal obligations, deportations damage Egypt’s portrayal of itself as a generous host country for refugees and strain regional and international relations.

Financial Instability

All of the Sudanese refugees the Refugees International team spoke to explained that second to their fear of deportation, financially surviving in Egypt is their next biggest challenge. Most Sudanese refugees in Egypt arrived with very little means and remain destitute. The Refugees International team spoke with a group of Sudanese women and their children who shared the challenges of being unable to work, struggling to find housing, and not having enough money for food. Furthermore, they were not receiving any help from organizations or the government of Egypt. Even well-established professionals in Sudan or others with some means face increasing challenges. They had resources that they used to travel to Egypt, obtain visas, and secure apartments upon their arrival in the country. However, those resources are exhausted, and now they rely on money from relatives abroad.

Access to the Labor Market

Without refugee camps or alternative effective systems for providing consistent aid, refugees in Egypt are left to “fend for themselves,” as one staff member of an NGO told Refugees International. To officially work in Egypt, Sudanese must be recognized as refugees and have work permits. However, to obtain a work permit, the Sudanese individual would have to have a passport, a valid visa, have entered the country legally, and obtain a security clearance from the Egyptian government. These requirements are, in fact, theoretical. As several people working with refugees explained to the Refugees International team, no refugee has met these requirements and been able to obtain a work permit in at least fifteen years. A staff member of one prominent NGO told Refugees International, “Any Sudanese who fled the war and is working is doing so informally.”

The impossibility of getting a work permit pushes Sudanese into informal labor markets where job opportunities are limited and can be exploitative. Some of these informal jobs that do not usually require documentation include construction, domestic work like house cleaning, or operating small businesses. Several Sudanese women described setting up shops to sell Kissra, a Sudanese bread, or perfumes after arriving in Egypt, but struggling to survive a tough market and economy.

Also, for those Sudanese refugees who speak English, some can secure remote jobs in call-centers. However, these activities usually do not pay enough to cover basic costs. The situation is further exacerbated by the high cost of living in urban centers such as Cairo and Alexandria, which restricts access to essential services, including healthcare and education. As a result, many Sudanese families – a large percentage of them female-headed households – find themselves in precarious living conditions, augmenting their vulnerability. The Egyptian government should make it easier for Sudanese refugees to obtain work permits, perhaps eliminating the requirement for security clearance or at least making the clearance feasible to obtain and transparent.

The Faisal neighborhood in Cairo where many Sudanese refugees live. Several Sudanese women told Refugees International that their only possibility to make some money is to work informally such as cleaning, December 2024. Photo by Devon Cone, Refugees International.

Additional Challenges Likely to Be Exacerbated Under the New Law

There are several other existing challenges raised by Sudanese interviewed by Refugees International that are unlikely to improve under the new law, and which may very well get worse. These include access to housing, education, and healthcare, as well as protection from GBV, and exposure to discrimination.

Housing

The cost of housing in urban areas, particularly in cities like Cairo, has risen significantly. By the time the war began in April 2023, average rents in Cairo had already increased by 30 percent from the previous year. Since that time, prices, especially for Sudanese, have just continued to rise. For example, in 6th of October City in mid-2023, rents went from 7,000 to 8,000 Egyptian pounds a month to 10,000, with prices even higher as one gets closer to the UNHCR office. A humanitarian official told Refugees International, “This is clearly price gouging. The economy right now in Egypt is tough, but it is undeniable that people are taking advantage of the desperation of Sudanese refugees, especially Sudanese mothers who need a place for their children to sleep.”

Many Sudanese refugees struggle to afford rent due to limited job opportunities and low incomes, often pushing them into substandard living conditions or overcrowded accommodations. The Refugees International team met with some Sudanese women refugees living with up to 25 people in two-bedroom apartments. A handful even explained to the team that they were considering returning to Sudan because they could not afford to rent a place in Cairo. One woman said, “if I am going to die here in Egypt, I might as well die in Sudan.” It is essential for Sudanese women to find safe housing with some level of privacy to ensure that they do not face exploitation, abuse, or harassment.

A Sudanese asylum seeker living in Cairo. She has two of her own children and is also caring for her teenage nephew with Down syndrome. Services for people with disabilities are very limited in Egypt, and she does not receive any support. Photo by Devon Cone, Refugees International.

Some landlords are reluctant to rent to refugees due to fears of legal complications or discrimination, leading them to rely on informal arrangements that offer little stability. In the informal housing market, refugees are at risk of exploitation by landlords who take advantage of their vulnerable status. The aspect of the new asylum law that criminalizes those assisting asylum seekers will also likely make it even more difficult for Sudanese to find housing and raise the risks of them being reported to authorities. UNHCR and civil society organizations need to push back on this criminalization aspect of the law. Sudanese refugees in Cairo told the Refugees International team that the only way they found places to live is through the broader Sudanese community; they all rely on each other a lot. Furthermore, the Egyptian authorities need to allow Sudanese refugees to work so they can pay for these accommodations, especially as inflation in Egypt is a challenge.

Access to Education

Another pressing concern raised in the team’s interview with Sudanese refugees was access to education.

Most of the refugee women Refugees International interviewed arrived in Egypt together with their children. They all highlighted the importance of education and noted that in addition to trying to protect their female children from sexual violence, ensuring that their children were able to continue their education was a primary reason they decided to flee to Egypt.

A ministerial decree provided Sudanese with the right to enroll in Egyptian public schools. However, this decree also stipulates that to do so, the Sudanese student must have a residency permit. Few Sudanese have this permit, the permits only last six months, and the Egyptian government is currently issuing new appointments starting in September 2027. Furthermore, there is severe overcrowding in most Egyptian classrooms. Right now, NGO staff estimate that there are about 7,000 Sudanese children enrolled in Egyptian public schools out of at least 300,000 school-aged Sudanese children registered with UNHCR. Even those fortunate enough to find a place in an Egyptian school often drop out due to harassment and bullying. Moreover, most Sudanese families want their children to continue studying the Sudanese curriculum.

When Sudanese refugees first started arriving in the spring of 2023, there were at least 300 privately run Sudanese schools. These schools had served the population of Sudanese immigrants who were already in Egypt for some years. However, in June 2024, the Egyptian authorities closed at least 50 of these schools, citing a lack of necessary registration and licensing. The schools had always operated semi-unofficially, not necessarily with all the required documentation, but also with an understanding that the Egyptian government would not regulate them, nor would they provide any government funds to these schools.

The motive behind closing so many of these schools is unclear. NGO staff who focus on refugee education in Egypt told Refugees International that it is likely because the Egyptian government is concerned that it does not have enough oversight over Sudanese schools, especially the curriculum, which presents the region’s history differently than Egyptian schools do. However, what is clear are the consequences. Tens of thousands of Sudanese children in Cairo are not attending classes, are unable to sit for exams, are spending their time with nothing to do, and are losing critical months, potentially years, of their education. One mother who had been practicing as a medical doctor in Sudan told the Refugees International team, “Educated children are the only hope we have for rebuilding our country when this terrible war ends. It is urgent that our kids are learning. It is not only important, it is dangerous for them to be at home all the time isolated.” A 16-year-old Sudanese girl told the team, “In the past, I was a good student, getting good grades…but now two years without any education, no teacher to help me.”

Community workers worry about the consequences of closing the few remaining schools. As one person supporting a Sudanese school told the team, “If we close down, where are these children going to go?”

It is in the best interest of the Egyptian government that Sudanese children are in school. It keeps them productively engaged, and also will prepare them to return to Sudan. Egyptian authorities should work together with the Sudanese school administrators to ensure that they are registered and they provide the Egyptian government with all the information necessary so that Egypt has some oversight over these schools. However, the Egyptian government should also refrain from making the process so burdensome and non-transparent that it becomes impossible.

Access to Healthcare

A lack of healthcare is also an urgent issue for Sudanese refugees. According to Egyptian law and UNHCR, refugees and asylum seekers have “access to all health services provided in its facilities on par with Egyptian citizens,” but this is not true in practice. Furthermore, as of July 2024, a new Egyptian government decree stipulates that refugees must provide a residency permit to access public services. A majority of refugees no longer have valid residency permits and they must wait until at least September 2027 to renew them. Sudanese refugees – some with valid residency permits, some without – told the Refugees International team that they have either been refused treatment at some public hospitals or that the medical care they need is too expensive.

This has led to a few alternative ways for Sudanese refugees to access some level of care. One is that some Sudanese doctors are providing “underground” unofficial care, sometimes even providing other Sudanese with medical advice online. Two, Sudanese refugees are learning what hospitals accept refugees or asylum seekers and are spreading this information through their networks. However, most Sudanese refugees are not receiving any care at all.

Volunteer Sudanese doctors working with their community reported widespread health issues going untreated, including anemia, diabetes, and breast cancer. One doctor told the team, “I’m worried about Sudanese here, because they have chronic diseases and no one to look after them.”

The Refugees International team spoke to a young Sudanese woman who has two disabled children. Her husband was killed in Sudan, she entered Egypt without a visa, and she is alone in Cairo.

Her children desperately need medical treatment, but she is afraid to go to any service providers not only because she will not be able to afford it, but more because she is unregistered and fears deportation.

The law states that refugees and asylum seekers can receive care; however, when they are waiting for many months to be registered and more than a year for an asylum seeker card, they are always at risk, especially if they seek services such as healthcare.

Many Sudanese also arrive with trauma from Sudan. As one woman described to the team, “In my mind, I am still trapped by what is happening in Sudan.” The trauma was further felt by her 4-year-old daughter, who she described crying for four days and unable to speak. The mother believes her daughter is getting better, but still needs psychotherapy.

Furthermore, so many Sudanese women in Egypt need regular sexual and reproductive healthcare (SRH) but are foregoing it due to lack of availability. One Sudanese woman who runs an organization providing women SRH in Sudan explained to the Refugees International team, “The rates of GBV in Sudan are so high, many Sudanese women you meet in Egypt have experienced this. They need care; they need treatment. Both physical and MHPSS services are really necessary. But with no money and so little available, most women will just suffer.”

A Sudanese woman in Cairo who fled to Egypt with her children. She explained that one of the reasons she left was that she feared for the safety of her teenage daughters. Photo by Devon Cone, Refugees International.

GBV in Egypt

GBV is clearly a huge risk in Sudan, but Sudanese refugee women and girls in Egypt are also at risk of GBV once they arrive. Sudanese women frequently encounter sexual harassment and assault in Egypt, particularly in public spaces and informal work environments. One Sudanese woman in her thirties told Refugees International, “Harassment on the street never stops. I fear that something is going to happen to me, but what can I do?” The lack of legal protections and fear of retaliation or deportation often prevent women from reporting such incidents, leaving perpetrators unpunished and fostering a culture of impunity.

Another woman interviewed by the Refugees International team recounted a neighbor approaching her for help after being raped by an Egyptian Uber driver. She refused to report the incident due to fear of being detained and deported by authorities. An NGO working with the Sudanese community similarly reported hearing cases of police turning away victims of crimes, including GBV, for lack of a residency permit.

Addressing GBV among Sudanese refugee women in Cairo requires a multi-faceted approach. In drafting their bylaws for the asylum law, the Egyptian government needs to allow for and even encourage CBOs to provide services for survivors of GBV. Community-based protection initiatives can help to prevent and address GBV. However, at this point, following the closure of Medecins Sans Frontières (MSF) in Cairo several years ago, there is primarily only one NGO that provides emergency SRH. Sudanese women need more care, more support, and more options. It is unconscionable that for as many Sudanese women there are in Cairo and for as many of them are GBV survivors, there are so few NGOs providing this crucial care. Donors should support any NGO or CBO willing to provide services to survivors. They should also financially support initiatives and programs that expand access to MHPSS. Furthermore, UNHCR needs to ensure that when GBV survivors report their assaults, UNHCR has the capacity to refer them for care.

Discrimination and Anti-Sudanese Sentiments

In addition to all the challenges accessing documentation, protection, and basic services, Sudanese refugees described the discrimination they face in Egypt. Several women told Refugees International that they do not allow their children outside for fear of bullying. Furthermore, social stigma and discrimination also play a significant role in the risk of GBV, as Sudanese women often face racial prejudice and are perceived as easy targets. Negative stereotypes portray Sudanese refugees as a burden on Egypt’s already struggling economy, which fuels hostility and exacerbates racism from local communities.

Each of these challenges will remain acute in the coming months as the bylaws of the new asylum law are developed. Each will risk being exacerbated by the sidelining of UNHCR and the aspect of the law that criminalizes informal aid. With the dearth of government and UNHCR resources and services available to the Sudanese community, it is Sudanese community-based organizations and individuals who provide the bulk of assistance to their community members. If these groups are increasingly threatened with arrest and fines, even this line of assistance will be dampened.

Need for Action

This is a crucial time to influence the law. From the time of passage in mid-December 2024, there is a six-month period allocated for drafting the bylaws of the new Egyptian legislation. This drafting period presents an opportunity to shape the specifics and implementation of the law. In March 2024, the EU signed an agreement with Egypt that included some €200 million dedicated to migration and donor engagement was likely a motivation behind the development of the law. However, the passage of an ambiguous and potentially dangerous law that further erodes asylee and refugee protections is not enough.

Donor countries to Egypt’s government, including the EU, must use what leverage they have to push Egypt to proactively engage UNHCR, other international organizations, and civil society in consultations to amend the law and develop these bylaws in a transparent and positive way that reflects international standards. Engaging with these groups will benefit both refugees and the Egyptian government because it will help address gaps in rights to work, education, and basic services for refugees.

UNHCR must also speak out against any provisions in the law that do not protect refugees and asylum seekers. Moreover, until the Egyptian government actually takes over registration and RSD processes, UNHCR must continue to improve and expand its registration capabilities.

The enactment of Law No. 164 of 2024 certainly signifies a pivotal change in Egypt’s refugee policy, with the SCRA now central to managing asylum processes. While the law aims to create a structured framework for handling refugee affairs, the concerns underscore the need for careful implementation and monitoring to ensure that the rights and protections afforded to refugees under international law are upheld.

Conclusion

Egypt hosts the largest number of Sudanese refugees fleeing the ongoing conflict, yet the reality on the ground falls far short of the rights promised by policies and laws on paper. Refugees face systemic barriers to accessing education, healthcare, and housing, leaving them in precarious and often unsafe conditions. Women and girls, many of whom have fled sexual violence in Sudan, remain highly vulnerable to GBV in Egypt, with limited MHPSS to address their trauma. Sudanese-led organizations work to fill these gaps, but they face significant constraints, while UNHCR struggles with insufficient funds and fails to advocate effectively for refugees’ rights amid restrictive Egyptian policies.

The implementation of Egypt’s new asylum law threatens to worsen the situation, with vague provisions that could legitimize arbitrary detentions and deportations. Without international pressure to amend the law to align with Egypt’s international obligations, ensure implementation of the law prioritizes refugee protection, and provide support to grassroots organizations, Sudanese refugees will continue to face exploitation, abuse, and systemic neglect. Urgent action is required from global actors that have leverage with the Egyptian government, such as the United States and the European Union, to ensure refugee protections are upheld. Decisive intervention is essential to safeguard the lives and futures of the hundreds of thousands of Sudanese refugees who are already in Egypt and those who will seek safety in Egypt in the future.

Featured Image: A Sudanese woman living in Cairo, Egypt, December 2024. Photo by Daniel P. Sullivan, Refugees International.