CAP Liberté de Conscience (CAP LC), an international non-governmental organization with consultative status at the United Nations, has jointly submitted a report for the 52nd session of the Universal Periodic Review (UPR) Working Group, focusing on Denmark. This expert analysis was prepared in collaboration with Mr. Bashy Quraishy, Secretary General of the European Muslim Initiative for Social Cohesion (EMISCO), and Mr. Gregory Christensen, Leader of Youth for Human Rights – Denmark. Both experts are members of the Advisory Board of the Danish Institute for Human Rights and bring decades of experience in human rights, anti-discrimination, and minority integration work within Denmark and the European Union.
The Universal Periodic Review (UPR)
The Universal Periodic Review (UPR) is a unique mechanism of the United Nations Human Rights Council that involves a periodic review of the human rights records of all 193 UN Member States. The objectives of the UPR are to improve the human rights situation on the ground in every country, address violations wherever they occur, and share best practices among states and other stakeholders. It is a state-driven process conducted under the auspices of the Human Rights Council, which provides each state with the opportunity to declare what actions they have taken to improve human rights and to fulfill their human rights obligations. The review is based on information provided by the state under review, reports from independent human rights experts and groups, and information from other stakeholders, including national human rights institutions and non-governmental organizations.
Objectives of the Joint Submission
The primary objective of the joint submission by CAP LC, EMISCO, and Youth for Human Rights – Denmark is to provide an expert analysis of Denmark’s first National Action Plan Against Racism (NAPAR). The analysis evaluates whether the NAPAR constitutes an adequate response to the recommendations Denmark received during its previous UPR cycle, particularly those pertaining to structural racism, xenophobia, and discrimination against vulnerable communities. The report draws on prior recommendations from UN member states and treaty bodies, as well as assessments from European monitoring bodies, to identify significant gaps in the Danish government’s approach.
Analysis of Denmark’s National Action Plan Against Racism (NAPAR)
The joint submission acknowledges the introduction of Denmark’s first NAPAR as a positive step but identifies several critical shortcomings that undermine its potential effectiveness and alignment with international human rights standards.
A major gap highlighted is the plan’s failure to explicitly address anti-Muslim racism and Islamophobia. Despite repeated recommendations from bodies such as the European Commission against Racism and Intolerance (ECRI) and specific calls from UN member states like Malaysia and Venezuela, the NAPAR omits any mention of Muslims as a specific target group. This omission is significant as it prevents the development of tailored policies to combat the specific forms of discrimination faced by Muslim communities, including surveillance, workplace discrimination, and religious profiling.
Furthermore, the report notes the absence of a standardized, nationwide system for collecting disaggregated data on hate crimes and hate speech. The lack of data categorized by ethnicity, religion, gender, and other criteria hinders the ability to accurately measure the scope of racism, identify trends, design targeted interventions, and evaluate the effectiveness of policies. This gap directly contradicts a key recommendation from the UN Committee on the Elimination of Racial Discrimination (CERD).
The analysis also finds that the NAPAR neglects to institute essential structural and legislative reforms. It does not include clear prohibitions on racial and religious profiling by law enforcement, nor does it address stigmatizing national policies such as the so-called “ghetto law” (parallelsamfundsloven), which has been criticized for leading to forced evictions and the disproportionate targeting of residential areas with predominantly minority populations. The plan’s narrow focus, which only explicitly names Jewish and Greenlandic communities, overlooks other vulnerable groups such as Afro-Danes, Roma, and migrants.
Finally, the submission points to a lack of provisions for independent monitoring and meaningful participation from civil society. The NAPAR does not establish a statutory, independent body with investigatory powers to monitor its implementation, nor does it guarantee multi-year funding for grassroots anti-racism organizations. This top-down approach risks a lack of accountability, sustainability, and community ownership of the anti-racism efforts.
Recommendations
Based on this analysis, the joint submission puts forward a series of concrete, evidence-based recommendations for the Danish government to strengthen its National Action Plan Against Racism and ensure compliance with its international human rights obligations. These recommendations include:
- Explicitly include anti-Muslim racism and Islamophobia in NAPAR. The plan should name Muslims as a protected target group and incorporate tailored measures to address the specific discrimination they face, as repeatedly recommended by ECRI and UN bodies.
- Establish a standardized system for disaggregated hate crime data collection. Denmark must implement a unified framework to collect, analyze, and publish comprehensive data on hate incidents, disaggregated by ethnicity, religion, gender, and other criteria to enable transparent and evidence-based policymaking.
- Prohibit racial and religious profiling and reform discriminatory urban policies. The government should introduce clear legal bans on profiling, abolish stigmatizing labels like “non-Western” in official discourse, and reassess the “ghetto law” to prevent forced evictions and promote inclusive, community-led urban development.
- Ensure independent monitoring and meaningful civil society participation. Denmark should create an independent anti-racism commissioner role with investigatory powers and a mandate to publish annual evaluations. Furthermore, the government must guarantee multi-year funding for NGOs and ensure the formal participation of affected communities in the co-design and implementation of all anti-racism measures.
More information :
Media European Times News Denmark’s anti-racism action plan falls short due to Islamophobia exclusion
Media European Times News Denmark’s Anti-Racism Plan Under International Scrutiny: What the UPR Reveals
UPR Submission : JS1 Report to UN WG UPR on Denmark’s Anti-Racism Efforts
Summary of stakeholders’ submissions on Denmark
Joint submission 1 submitted by: Coordination des Associations et des Particuliers pour la Liberté de Conscience, (France); EMISCO Youth for Human Rights (Denmark)
21. Joint submission 1 (JS1) and JS2 welcomed the adoption of a national action plan against racism in February 2025. However, they were concerned that the plan had limitations in scope and lacked a clear definition of racism. JS1 was also concerned that the plan only named Jews and Greenlanders as specific target groups and omitted Muslims, Afro-Danes, Roma and migrants. JS2 recommended that Denmark include in the national action plan against racism the definition of racial discrimination and expand measures to address discrimination and hatred against all religious and ethnic minorities, including Muslims.
22. JS1 was concerned that the national action plan against racism also failed to include clear prohibitions on racial or religious profiling. It recommended that Denmark introduce such bans.
23. ISPF was concerned that hate crimes targeting Muslims continued to occur in Denmark and that underreporting and shortcomings in the recording of religiously motivated bias affected the accuracy of official statistics. The Office for Democratic Institutions and Human Rights/Organization for Security and Co-operation in Europe (OSCE-ODIHR) and JS1 recommended that Denmark establish a standardized system for disaggregated hate crime
data collection.
24. ISPF and IDE were concerned about the persistence of Islamophobic discourse and stereotyping, including in political and media contexts, and the limited counter-speech by public authorities, which contributed to the stigmatization of Muslims. They recommended that Denmark consistently condemn Islamophobic and racist rhetoric and ensure the effective enforcement of hate-speech legislation.
25. Maat Foundation for Peace, Development and Human Rights (MAAT), ISPF and IDE expressed concern about the Parallel Society Act. MAAT expressed concern that the Act, which targeted neighbourhoods with a high proportion of residents from “non-Western” backgrounds, was leading to the reduction or demolition of social housing and the termination of rental contracts, resulting in housing insecurity, stigmatisation of affected residents and barriers to their inclusion in Danish society. MAAT, ISPF, IDE and JS1 recommended that Denmark review and repeal discriminatory policies under the Parallel Society Act and refrain from classifying neighborhoods based on racial or cultural criteria that were leading to discrimination and exclusion.




