The Network of Organizations for Children of Serbia (MODS), together with the Union of Secondary School Students of Serbia (UNSS) and the international network Child Rights Connect, submitted joint comments to the United Nations Human Rights Committee on the Draft General Comment No. 38 on the right to freedom of association.
The submission was made on 15 July 2026, in response to the Committee’s call for stakeholders to contribute to the finalisation of the General Comment, which will provide more detailed guidance on the implementation of Article 22 of the International Covenant on Civil and Political Rights.
The UN Human Rights Committee began developing General Comment No. 38 during its 144th session, held in July 2025. The first reading of the draft was completed at its 145th session in March 2026, after which States, civil society organisations, national human rights institutions, trade unions, academia and other interested stakeholders were invited to submit comments ahead of the second reading.
The joint submission by MODS, UNSS and Child Rights Connect also draws on the experiences and recommendations of children who participated in international consultations on the right to freedom of association. Their views were translated into concrete proposals for amendments and additions to the draft General Comment.
The submission particularly emphasises that the right to freedom of association applies fully to children, including informal groups, student councils, associations, and initiatives led by children and young people. It stresses that children’s activities, especially within schools, should not be treated solely as matters of school discipline, parental authority or protection, but as the exercise of their civil and political rights.
The organisations recommended that the final General Comment more clearly recognise the importance of child-friendly civic and human rights education, protect school-based groups and initiatives from both direct and indirect restrictions, and ensure accessible and child-sensitive remedies.
MODS, UNSS and Child Rights Connect also recommended that any restriction on a child’s freedom of association must meet the same strict requirements of legality, legitimacy, necessity and proportionality that apply to all other rights-holders. Age, the best interests of the child, protection concerns or evolving capacities must not be used to justify broad or automatic restrictions on this right.
Joint Submission on Draft General Comment No. 38 on Article 22 of the ICCPR of the Network of Organizations for Children of Serbia (MODS), Union of Secondary School Students of Serbia (UNSS), and Child Rights Connect is available HERE.