A/HRC/26/29 affirming the legitimacy of associations formed to promote issues of concern to minorities for historical and economic reasons.24 54. The process of registering an association may prove to be cumbersome for marginalized groups and exclude groups such minorities or persons with disabilities. For example, the language used to communicate could be inaccessible, and physical access to locations for registration could also be a challenge for those groups. Mandatory registration, particularly where authorities have broad discretion to grant or deny registration, provides an opportunity for the State to refuse or delay registration to groups that do not espouse “favourable” views. Associations formed to defend human rights, engage in civic awareness, and to lobby and advocate are susceptible to such delays and denials, as has reportedly been the case in the Sudan. 55. The Special Rapporteur emphasizes that the right to freedom of association applies equally to associations that are not registered (A/HRC/20/27, para. 96). He endorses as best practice a voluntary registration regime that permits unregistered associations to operate. The Special Rapporteur notes with approval the recent ruling by a magistrate’s court in Zimbabwe, quashing charges of running an unregistered organization preferred against a member of the Gays and Lesbians of Zimbabwe association. 56. Nevertheless, where a registration regime exists, requirements should be framed such that no one is disadvantaged in the formation of her or his association, either by burdensome procedural requirements or unjustifiable limitations to substantive activities of associations. The State has an obligation to take positive measures to overcome specific challenges that confront marginalized groups, such as indigenous peoples, minorities, persons with disabilities, women and youth, in their efforts to form associations.25 57. Funding restrictions, including restrictions on foreign funding, may disproportionately affect associations that promote issues that do not enjoy popularity or the support of the State or the majority of the population, including those that relate to the advancement of the rights of marginalized groups. This is evidenced by the dichotomy that some States impose regarding association funding sources: certain types of activities or organizations are permitted to receive foreign funding while others only receive domestic funding. For instance, to be considered an Ethiopian charity or society, organizations cannot receive more than 10 per cent of their funding from foreign sources. Only Ethiopian charities or societies may engage in promoting human rights work, gender equality and religious equality, the rights of persons with disabilities, children’s rights, conflict resolution or reconciliation and the efficiency of the justice and law enforcement services. Foreign associations or those that receive more than 10 per cent of their funding from foreign sources may not engage in such activities. In the Russian Federation, an organization working on “political activities” and receiving foreign funding must register itself as a “foreign agent”, which in Russian is synonymous with “foreign spy”. The law broadly defines political activities as attempts to influence official decision-making or to shape public opinion to exert a similar influence, and thus can include work in areas such as human rights, governance and accountability issues. 58. Legislation that provides broad discretion to authorities to monitor or oversee the activities of associations poses a grave risk to the continued existence of organizations that engage in activities perceived to be threatening to the State. Groups that advocate against the unsustainable use of natural resources or the use of those resources contrary to the rights of indigenous peoples are often targeted and risk closure, as happened to Fundación 24 25 16 European Court of Human Rights, Sidiropoulos and others v. Greece, case No. 57/1997/841/1047, 10 July 1998, paras. 44 and 46. Human Rights Committee, general comment No. 25 (1996), para. 12.