Evergreen explainer. Every year the United States is supposed to review religious freedom in every country and name the worst offenders “Countries of Particular Concern” (CPCs). The label is a U.S. legal designation, not a UN or court finding. This page explains how the system works, who is on the list, how often sanctions actually follow, and where governments push back. It covers developments up to September 30, 2026.
It is one of four explainers that begin with the State Department’s Bureau of Democracy, Human Rights, and Labor (DRL), whose Office of International Religious Freedom (IRF) runs the process. U.S. findings are treated as one party’s assessment and set beside the independent U.S. Commission on International Religious Freedom (USCIRF), the Congressional Research Service (CRS) and the governments concerned. See the Investigations hub for the series.
Contents
- 1. Key takeaways
- 2. The law: IRFA, CPCs and the Wolf Act
- 3. Who is on the list
- 4. What happens after a designation
- 5. The missing reports and a shrunken apparatus
- 6. USCIRF’s independent recommendations
- 7. Disputed cases: Nigeria and India
- 8. Documented, alleged and disputed
- 9. Timeline
- 10. Frequently asked questions
- 11. Key sources and related coverage
- 12. Note on method and status
1. Key takeaways
Key takeaways
- What a CPC is: Under the 1998 International Religious Freedom Act (IRFA), a CPC is a country whose government engages in or tolerates “particularly severe” violations, defined as “systematic, ongoing, egregious” violations such as torture, prolonged detention without charges or forced disappearance.
- The current list: The State Department’s page lists 12 countries designated on 29 December 2023 (Burma, China, Cuba, Eritrea, Iran, North Korea, Nicaragua, Pakistan, Russia, Saudi Arabia, Tajikistan, Turkmenistan), plus Nigeria, which President Trump designated on 31 October 2025.
- Designation rarely brings new sanctions: CRS says administrations have generally either pointed to sanctions already in place or issued waivers. For the December 2023 list, four countries received national-interest waivers and the rest were “referred to preexisting sanctions.”
- Reports are overdue: The State Department’s last religious freedom report covers 2023 and was released on 26 June 2024. CRS said in June 2026 that the reports for 2024 and 2025 had not been released.
- Governments dispute it: Nigeria rejected the designation and denies a campaign against Christians. India rejected USCIRF’s 2026 recommendations as “motivated and biased.”
1998
IRFA enacted
Created the CPC process
13
Current CPCs
12 from Dec 2023, plus Nigeria (Oct 2025)
18
USCIRF CPC picks
2026 annual report, 4 Mar 2026
2023
Last State IRF report year
Released 26 Jun 2024
2. The law: IRFA, CPCs and the Wolf Act
The International Religious Freedom Act of 1998 created the Office of International Religious Freedom within the State Department, headed by an Ambassador-at-Large, required an annual report on religious freedom in every country, required the President to designate CPCs and created USCIRF, according to CRS. The Frank R. Wolf International Religious Freedom Act of 2016 added a “Special Watch List” (SWL) for countries with “severe” violations that do not meet all CPC criteria, and “Entities of Particular Concern” (EPCs) for non-state actors that commit particularly severe violations. The State Department says the President delegated the designation authority to the Secretary of State.
The State Department’s own FAQ explains the rationale: religious freedom is a right in instruments such as the Universal Declaration of Human Rights and the International Covenant on Civil and Political Rights, and publishing the report is a way to “shine a light on its abuse.” The Office’s funding notices tie “religious freedom” to Article 18 of the Covenant. The process is nonetheless an American one. The U.S. applies its own statute to other countries, and the designations carry no UN or judicial standing.
3. Who is on the list
| Category | Members (latest State Department designations) | Date |
|---|---|---|
| Countries of Particular Concern | Burma, China, Cuba, Eritrea, Iran, North Korea, Nicaragua, Pakistan, Russia, Saudi Arabia, Tajikistan, Turkmenistan | 29 Dec 2023 |
| Country of Particular Concern (added) | Nigeria, designated by President Trump | 31 Oct 2025 |
| Special Watch List | Algeria, Azerbaijan, Central African Republic, Comoros, Vietnam | 29 Dec 2023 |
| Entities of Particular Concern | Al-Shabaab, Boko Haram, Hayat Tahrir al-Sham, the Houthis, ISIS-Sahel, ISIS-West Africa, Jamaat Nasr al-Islam wal Muslimin, the Taliban | 29 Dec 2023 |
No full slate of designations has been issued since December 2023, CRS says. The list therefore reflects the situation at the end of 2023, plus one addition. Treat the list as a record of past decisions, not a current ranking.
4. What happens after a designation
IRFA provides an escalating menu of responses, from diplomatic protests to economic measures. For CPCs, the executive branch is to implement one or more of the sanctions suggested in the law, but it has wide discretion. CRS says administrations can apply a “commensurate substitute action,” can exempt a CPC by pointing to existing “broad-based” sanctions, or can waive sanctions in the U.S. national interest. “In practice,” CRS writes, administrations “have generally either referred to sanctions already in place against CPCs under other authorities or issued waivers instead of implementing new sanctions under IRFA.”
| CPC (Dec 2023) | U.S. action |
|---|---|
| Burma, China, Cuba, Eritrea, Iran, Nicaragua, North Korea, Russia | Referred to preexisting sanctions |
| Pakistan, Saudi Arabia, Tajikistan, Turkmenistan | National-interest waiver |
The source for that table is CRS’s summary of the 89 Federal Register 3980 notice. The pattern matters for interpreting headlines. A designation signals U.S. concern and can shape diplomacy, but it does not by itself mean a new penalty.
5. The missing reports and a shrunken apparatus
The annual IRF report is supposed to be issued around 1 May. The report covering 2023 went to Congress on 26 June 2024. CRS, in an analysis republished by Eurasia Review on 4 June 2026, says the department had not released the report for 2024, due around 1 May 2025, or the one for 2025, due around 1 May 2026. The State Department’s remarks-and-releases page for the Office, which we opened, shows country reports dated 26 June 2024 as the latest report entries. We found no later release, though our review is not exhaustive.
CRS also describes a changed institutional picture:
- The IRF Office and the Office of the Special Envoy to Monitor and Combat Antisemitism were realigned under DRL in the State Department’s 2025 reorganization, which eliminated the Under Secretary position they had reported to since 2019. The DRL Key Topics page lists both offices.
- Mark Walker’s nomination as Ambassador-at-Large was not confirmed before the Senate session ended. He then served as Principal Advisor for Global Religious Freedom until April 2026, and CRS says no new nomination had been announced as of its writing. The special envoy, Yehuda Kaploun, was confirmed in December 2025.
- In early 2025 the administration paused nearly all foreign assistance. CRS cites USCIRF reporting that “a significant portion of programs that utilized funds directed by Congress to promote IRF” were ultimately terminated. The State Department’s site shows new IRF funding notices for Nigeria dated 22 May 2026.
- In December 2025 Secretary of State Marco Rubio announced a new visa restriction policy for individuals involved in religious freedom violations, according to CRS.
USCIRF publicly urged the State Department on 4 March 2026 to “issue its Annual Report on International Religious Freedom and make its designations,” as quoted in its press release. The State Department’s reasons for the delay are not stated in the sources we opened, and we did not find an official explanation.
6. USCIRF’s independent recommendations
USCIRF is an independent, bipartisan federal commission created by IRFA. Its 2026 annual report, released on 4 March 2026, covers calendar year 2025. It recommends that the State Department designate 18 countries as CPCs: the 12 designated in December 2023, Nigeria, and five additional countries (Afghanistan, India, Libya, Syria and Vietnam). It recommends 11 countries for the Special Watch List (Algeria, Azerbaijan, Egypt, Indonesia, Iraq, Kazakhstan, Kyrgyzstan, Malaysia, Qatar, Turkey and Uzbekistan) and seven entities as EPCs.
Its recommendations are typically broader than the State Department’s, CRS notes. USCIRF’s mandate and reports are distinct from the State Department’s, and its commissioners vote on findings. Chair Vicky Hartzler’s statement singled out China’s arrests of underground church members, mob violence in India and Pakistan, Burma’s military bombing of houses of worship and Tajikistan’s restrictions on teaching children about faith. These are USCIRF’s characterizations. CRS said in June 2026 that USCIRF was authorized through September 2026 and that bills to extend it through September 2028 were pending. We did not verify the reauthorization status as of September 30.
7. Disputed cases: Nigeria and India
Nigeria
On 31 October 2025, President Trump posted that “Christianity is facing an existential threat in Nigeria,” that “thousands of Christians are being killed” and that “radical Islamists are responsible,” and said he was making Nigeria a Country of Particular Concern. Al Jazeera reported that he appeared to bypass the usual procedure, in which the label is normally assigned on the recommendation of USCIRF and State Department specialists. (Al Jazeera’s headline described a “watch list,” while the State Department’s page lists Nigeria as a CPC. We follow the State Department’s page.) Republican lawmakers including Rep. Riley Moore and Sen. Ted Cruz welcomed the move.
Nigeria’s government rejected the label. A federal government statement, quoted by ThisDay, said the claims “do not reflect the situation on the ground.” President Bola Tinubu said the characterization of Nigeria as religiously intolerant “does not reflect our national reality.” Foreign Ministry spokesman Kimiebi Imomotimi Ebienfa told Al Jazeera that “there is no Christian genocide in Nigeria,” that killings were not limited to Christians (“Muslims are being killed. Traditional worshippers are being killed”), and that “the killings are not sanctioned by the Nigerian government.” He blamed Boko Haram and al-Qaeda- and ISIS-linked groups. Al Jazeera reported that experts have called the framing of the violence as a religious attack “largely inaccurate,” pointing to a northeast insurgency and to farmer–herder disputes over resources. Nigeria has denied that those clashes are primarily religious. Al Jazeera separately reported that Trump then threatened possible military action, and a Tinubu adviser said Nigeria would welcome U.S. help “as long as it recognises our territorial integrity.”
Both framings contain verifiable elements. Nigeria faces serious violence from jihadist groups, including in a majority-Muslim northeast, and Christians are among the victims. Whether the violence is best described as religiously targeted, and whether the government tolerates it, is disputed. This page takes no position beyond attributing each claim.
India
USCIRF’s 2026 report recommended that India be designated a CPC and, according to the Times of India, recommended targeted sanctions on the Rashtriya Swayamsevak Sangh and the Research and Analysis Wing. India’s Ministry of External Affairs said on 16 March 2026 that it “categorically” rejected the report’s “motivated and biased characterization.” Spokesman Randhir Jaiswal said USCIRF relies on “questionable sources and ideological narratives” and urged it to look at attacks on Hindu temples and intimidation of the diaspora in the United States. That is India’s position, and we did not assess the underlying evidence on either side. Note that the State Department itself has not designated India.
We did not open official responses from other listed governments, such as China or Russia, for this page. Where a government’s denial is not cited, readers should not assume none exists, only that we did not review it.
8. Documented, alleged and disputed
| Claim | Status | Who says it | Notes |
|---|---|---|---|
| Twelve countries were designated CPCs on 29 Dec 2023; Nigeria added 31 Oct 2025 | Documented | State Department CPC page | Official list. |
| Most CPCs get no new IRFA sanctions | Documented (CRS analysis) | CRS; Federal Register | Four waivers and eight referrals to preexisting sanctions for the 2023 list. |
| State IRF reports for 2024 and 2025 have not been released | Documented as of June 2026 (CRS) | CRS via Eurasia Review; State site | We found no later release; not exhaustive. |
| India should be a CPC; sanctions on RSS and RAW | USCIRF recommendation | USCIRF; Times of India | India rejects it; State has not designated India. |
| Nigerian Christians are being killed in large numbers for their faith | Disputed | U.S. President; Nigerian officials deny; experts cited by Al Jazeera call the framing inaccurate | Violence is real; attribution to religion is contested. |
| The IRF apparatus has been weakened | Contested characterization | CRS documents staffing, funding and reporting facts | The State Department’s view is not stated in the sources we opened. |
9. Timeline
| Date | Event | Source |
|---|---|---|
| 1998 | IRFA enacted; CPC process and USCIRF created | CRS via Eurasia Review |
| 2016 | Frank R. Wolf IRF Act adds Special Watch List and EPCs | CRS via Eurasia Review |
| 29 Dec 2023 | Last full slate of State Department designations | State Dept |
| 22 Jan 2024 | Designations published in the Federal Register (89 FR 3980) | Federal Register |
| 26 Jun 2024 | State Department releases 2023 IRF reports | State Dept |
| 31 Oct 2025 | Trump designates Nigeria a CPC | Al Jazeera |
| 2 Nov 2025 | Nigeria rejects the designation and claims of genocide | Al Jazeera |
| Dec 2025 | Rubio announces religious-freedom visa restriction policy | CRS via Eurasia Review |
| 4 Mar 2026 | USCIRF 2026 annual report urges State to issue its report | USCIRF |
| 16 Mar 2026 | India rejects USCIRF report | Times of India |
| 22 May 2026 | State posts IRF funding notices for Nigeria | State Dept |
| 4 Jun 2026 | CRS says 2024 and 2025 IRF reports remain unreleased | CRS via Eurasia Review |
10. Frequently asked questions
Does a CPC designation mean sanctions?
Not necessarily. The law authorizes actions, but the executive branch can substitute other measures, point to existing sanctions or waive them for national-interest reasons. CRS says that is what administrations have generally done.
Is the CPC list a UN list?
No. It is a U.S. designation under U.S. law. The UN has its own Special Rapporteur on freedom of religion or belief, Nazila Ghanea, whose 2023 report to the Human Rights Council set out a global “landscape” of the issue.
Why is Nigeria’s case controversial?
Because the designation rests on a claim about the cause of violence that Nigeria’s government and some experts contest, and because it was announced in a presidential post rather than following the usual recommendation process, according to Al Jazeera.
11. Key sources and related coverage
Key sources and further reading
- State Department: Countries of Particular Concern, Special Watch List Countries, Entities of Particular Concern
- State Department: FAQ on the IRF Report and CPCs
- Federal Register: Secretary of State’s Determinations under IRFA (89 FR 3980)
- CRS (via Eurasia Review): Global Human Rights, International Religious Freedom Policy
- USCIRF: 2026 Recommendations
- USCIRF: 2026 Annual Report press release
- Al Jazeera: Trump places Nigeria on watch list
- Al Jazeera: Nigeria rejects claims of Christian genocide
- ThisDay: Tinubu replies to Trump
- Times of India: MEA slams USCIRF report
- OHCHR: UN Special Rapporteur on freedom of religion or belief, A/HRC/52/38
Related on Peter’s World
- Investigations hub
- State Department Human Rights Report: How It Works and What Changed
- Xinjiang Forced Labor: What Is Documented, Alleged and Disputed
- IRGC Investigation: Crimes Against Humanity and Genocidal Intent, on Iran, a CPC
- Pakistan Mosque Attack at Kohat Police Lines Kills at Least 16 During Friday Prayers
- Fawzia Amin Sido: A Yazidi Woman’s Decade-Long Ordeal from ISIS Enslavement to Rescue and Advocacy
12. Note on method and status
This page is an independent explainer compiled from public sources; allegations are not findings of guilt. Last updated: Sep 30, 2026.
Method: claims are attributed to the named source. Single-source items are flagged. The State Department’s reporting delays and the IRF Office’s staffing history rest mainly on one CRS analysis. The description of USCIRF’s recommendation on RSS and RAW comes from the Times of India alone, and the Tribune’s copy of the India story did not load for us. The Pew Research religious-restriction data we wanted to cite was not accessible to our tools, so it is omitted. Corrections are welcome through our Contact page.