Introduction
M23, which refers to the March 23 Agreement signed in 2009 between the DRC (Democratic Republic of Congo) and the CNDP (National Congress for the Defense of the People) insurgents, is a rebel movement composed primarily of ethnic Tutsi soldiers supported by the Rwandan government. Formed in 2012 following a mutiny within the DRC army by formerly integrated CNDP rebels, the group was defeated in 2013 by the national army but resurrected in 2021 following the breakdown of secret talks with the DRC government concerning the implementation of the 2013 Nairobi Declarations on ending the group’s initial rebellion. Its stated objectives include securing political influence and greater protection for the Tutsi population in Eastern DRC.
M23 represents one of the most significant contemporary challenges to peace and human rights in the DRC, as it has been involved in numerous acts of violence during its rapid conquest of the Eastern DRC. Reports from the United Nations (UN) Groups of Experts on the DRC and various international non-governmental organizations revealed that M23 was responsible for widespread human rights violations including summary executions, rapes, forced recruitment, and indiscriminate mortar and rocket attacks against civilian objects.
The international human rights community (IHRC)’s responses to M23’s ongoing brutality have been diverse, as many approaches have been taken, but their overall effectiveness remains questionable. Despite numerous efforts, the rebel group not only continues its military activism but also remains a major threat to civilians’ human rights in Eastern DRC.
This article will first provide a succinct catalog of human rights violations perpetrated by M23. It will then assess the responses of the IHRC, including those of the UN Security Council and Human Rights Council, the United States, the European Union (EU), the African Union and its Court of Human Rights, and the International Criminal Court. This article will conclude by asserting that the IHRC’s measures have limited practical effects on M23 and recommend the IHRC and DRC government strengthen regional diplomacy, enhance multilateral engagement, and improve accountability for human rights violations.
M23 as a Threat to the Human Rights of Civilians in Eastern DRC
Since its resurgence in 2021, the M23 rebel group has committed countless human rights violations, as documented by international human rights organizations. Human Rights Watch and Amnesty International have cataloged the following unlawful acts perpetrated by M23 since the beginning of 2025: sexual violence, civilian killings, kidnapping, and illegal exploitation of natural resources.
According to a United Nations Human Rights Office report, more than 200 cases of rape and sexual violence have been recorded in Eastern DRC, some of which were perpetrated by M23. These acts could amount to crimes against humanity and war crimes under Articles 7(1)(g) and 8(2)(b)(xxii) of the Rome Statute, respectively. With M23 being a major contributor to the death toll, more than 7,000 people, many of them civilians, have been killed in Eastern DRC, and approximately 500,000 individuals have been displaced from their homes since January 2025 due to M23’s rebellion.
Furthermore, M23 launched indiscriminate attacks with explosive weapons into densely populated areas, resulting in the death of over a hundred civilians and the injury of hundreds more civilians. These attacks violated international law, specifically Article 3 of the 1949 Geneva Convention IV and Articles 7 and 8(2)(b)(i) of the Rome Statute. Besides, Reuters reported the abduction of over 130 patients from hospitals in Goma in February 2025 by M23, infringing the 1949 Geneva Convention IV (articles 34 and 147). The M23 has also been involved in the illegal extraction and trafficking of at least 150 tons of coltan from mineral-rich areas under its control, violating Article 33 of the 1949 Geneva Convention IV.
International Human Rights Community Interventions
Since its resurgence in 2021, M23 and its Rwandan allies have faced diplomatic pressure, economic sanctions, and legal actions—either individually or jointly—for violations of international human and humanitarian laws.
For instance, the United Nations Security Council (UNSC), acting under Chapter VII of the UN Charter in line with its principal mission of maintaining global peace and security, has taken an active role in tackling the M23 insurgency and its international law violations. It adopted Resolution 2641 of 2022, renewing the arms embargo against non-governmental entities and individuals operating in the territory of the DRC, and Resolution 2773 of 2025, which condemned M23’s offensive and its alliance with Rwanda while demanding immediate ceasefire and withdrawal of the M23 and Rwandan troops from captured territories. Furthermore, the UNSC applied diplomatic pressure on the governments of the DRC and Rwanda, as well as regional powers and the international community, to seek a peaceful resolution to the crisis by promoting dialogue and political discussions.
Likewise, the United Nations Human Rights Council (UNHRC) passed a resolution in February 2025 establishing (1) a fact-finding mission to investigate the serious human rights violations and abuses, along with breaches of international humanitarian law, occurring in the DRC’s provinces of North Kivu and South Kivu; and (2) an independent commission of inquiry to continue the work of the fact-finding mission. Regrettably, the measures and initiatives adopted by the UNSC and UNHRC seem fruitless so far, as M23 continues seizing new territories and regional peace talks are facing a stalemate.
Similarly, the United States and the European Union have adopted significant diplomatic, economic, and security measures in response to the resurgence of M23. On March 17, 2025, the EU sanctioned senior members of M23 and the Rwandan military for their roles in perpetuating violence in DRC and reproved Rwanda’s state mining agency for its involvement in facilitating the illegal extraction of resources from conflict zones. A month earlier, the US Treasury similarly imposed sanctions on Rwanda’s Minister and a senior militant of M23 for the corresponding reasons. It is, however, imperative to emphasize that the economic and diplomatic measures from the United States and the EU appear to strategically aim at limiting the bargaining power of M23 in future peace talks rather than seeking to alter the balance of military power on the ground. This is because the United States and the EU prefer a peaceful conflict resolution through a dialogue involving all stakeholders (such as the DRC government, the M23 and other armed groups, political parties, civil society, and local community) to address all causes of crisis and thereby end atrocities against civilians.
In the context of the African continent, the African Union (AU) is intervening alongside the East African Community (EAC) and the Southern African Development Community (SADC) to ease tensions between the DRC and Rwanda and call for peace negotiations involving M23. Unfortunately, a joint EAC/SADC summit in Dar es Salaam in January 2025 ended without an explicit agreement, while the direct talks between the DRC government and M23 in Luanda in March 2025 were boycotted by the rebels after they faced EU sanctions. These developments imply that the regional peace process initiatives are currently at an impasse, further exposing civilians to atrocities.
Efforts of the Judicial Human Rights Bodies
Regional and international judicial bodies—primarily the African Court on Human and Peoples’ Rights (ACtHPR) and the International Criminal Court (ICC)—are playing a key role in adjudicating the human rights violations perpetrated by M23 and its Rwandan allies.
For instance, on August 21, 2023, the DRC government filed a lawsuit against Rwanda before the ACtHPR, alleging violations of the African Charter on Human and Peoples’ Rights, due to Rwanda’s support of M23 since November 2021. The DRC previously lodged a similar interstate complaint in 1999 to the African Commission on Human and Peoples’ Rights (“the African Commission”) against Rwanda, Burundi, and Uganda for armed aggression and human rights violations.
Considering that both the 1999 and 2023 lawsuits addressed similar issues involving almost the same parties, it is then possible that the ACtHPR’s decision (on the DRC v. Rwanda case of 2023), which would be based on the same human rights instruments, would be the same as the one previously rendered in 2003 by the African Commission concerning the DRC’s complaint of 1999 against Rwanda, Burundi, and Uganda. In that ruling of 2003, the African Commission condemned the respondent countries for their violations of human rights against the DRC population, compelled them to cease military activities, get involved in the peace process, and required them to make financial reparations to the DRC on behalf of the victims of human rights violations.
Analogously, the ICC has increased its focus on investigating international crimes related to the ongoing conflict involving M23 in Eastern DRC, with Prosecutor Karim Khan announcing renewed efforts in October 2024. The ICC has been investigating alleged war crimes and crimes against humanity committed by all sides since January 2022. Previously, the ICC prosecuted figures like Bosco Ntaganda, Thomas Lubanga, and issued an arrest warrant for Sylvestre Mudacumura for their roles in child soldier recruitment, mass atrocities, and other forms of conflict-related violence in the DRC.
Despite the potential deterrent effects of the prosecutorial interventions, the rulings of the African human rights bodies and the ICC have commonly had limited success in stopping violence and addressing human rights abuses in the DRC. This is largely because these judicial institutions lack enforcement power and must depend on the cooperation of the very parties accused of violations.
Policy Recommendations: Strengthening Regional Diplomacy, Expanding Multilateral Engagement, and Enhancing Human Rights Accountability Mechanisms
Regardless of its essential interventions in the DRC crisis, the IHRC’s responses appear to be inefficient in addressing M23’s human rights abuses and in guiding the conflict parties toward a peaceful resolution. To strengthen the protection of civilians, both the IHRC and the DRC government should consider adopting additional and concrete measures.
The IHRC, through the UN, AU, EU, and other influential international actors, may consider strengthening regional diplomacy and multilateral engagement. This would aim at increasing diplomatic pressure on M23 and its Rwandan allies to participate meaningfully in the peace process geared toward a holistic resolution to the crisis. This may comprise the de-escalation of tensions between the DRC and Rwanda, the enforcement of a ceasefire and withdrawal of M23 and Rwandan troops from occupied territories, bringing a clear policy decision regarding the integration or exclusion of rebel forces into the DRC’s national army, efforts to resolve local community tensions, and the promotion of good governance, and institutional reform.
Moreover, the IHRC should work to consolidate and coordinate the existing fragmented peace talks, which appear to be hindering progress on peace negotiations in the DRC. Currently, there are currently three main formats for peace initiatives: the Doha talks under Qatar’s facilitation, the EAC-SADC mediation, and the peace negotiation proposed by the leaders of the Congolese Catholic and Protestant churches. Of course, these three peace efforts do not seem to have the same finality as, unlike the Catholic and Protestant Churches’ initiatives, which seek to offer a comprehensive solution to the root causes of the crisis, both the Doha and the EAC-SADC negotiations focus solely on military and geopolitical issues. Furthermore, some of these peace talks are mediated by competing regional and international actors with vested economic and geopolitical interests in the DRC. Therefore, it is essential for the IHRC to either unambiguously endorse the initiative by the Catholic and Protestant Churches as the sole peace platform aimed at addressing the root causes of the DRC crisis through inclusive dialogue or broaden the mandate of the EAC-SADC talks to go beyond military and geopolitical concerns and tackle the deeper socio-political and economic drivers of the conflict.
Additionally, the IHRC should ensure that peace talks guarantee the enforcement of human rights standards. The IHRC should use the targeted sanction approach as a deterrent tool against future abuses, thereby reinforcing civilian protection by discouraging future violations.
Finally, in connection with the DRC government, national authorities must implement stronger accountability mechanisms to address human rights violations in Eastern DRC. The DRC must strengthen its judicial system to investigate and prosecute human rights violations committed by both M23 and national army soldiers. The country should also train and equip its military and police forces with necessary skills and resources to handle conflict situations without resorting to human rights violations, which could reduce the occurrence of abuses by the state actors.
Conclusion
To sum up, M23 continues to pose a significant threat to peace and human rights in Eastern DRC, despite numerous international efforts to address its violent actions. The group’s persistent involvement in serious human rights violations and its defiance against international pressure highlights the inadequacy of current measures. The IHRC must reconsider its approach, focusing on strengthening regional diplomacy, enhancing multilateral engagement, and ensuring greater accountability for the atrocities committed. Only through a comprehensive and coordinated response can lasting peace and protection for civilians in the region be achieved.
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Roger-Claude Liwanga is an Adjunct Professor of Law and Advanced International Negotiations at Emory Law School and Associate Professor of Criminal Justice at Albany State University. He formerly served as a fellow with the FXB Center for Health and Human Rights at Harvard University and a consultant with the United Nations Development Programme (UNDP) and the Carter Center. His research focuses on international law, laws of armed conflict, conflict resolution, human rights, and human trafficking.
Image Credit: MONUSCO Photos, CC BY-SA 2.0, via Flickr.
