A Foreign Worker Passport Rights Guide: East Africa
A passport is not an office ID card. It proves identity and nationality, enables travel and, for a foreign worker, supports lawful immigration status. Yet employees sometimes hand the original to an employer during recruitment or work-permit processing and later discover that it is kept in a company safe, held as “security”, or returned only with management approval. The important legal question is therefore not simply whether an employer may see your passport, but whether the employer may control it.
Across the
eight Partner States of the East African Community, the precise rules differ.
Some countries expressly criminalise withholding another person’s travel
document. Others regulate passport possession, forced labour or trafficking,
while current work-permit procedures commonly ask for a copy rather than
permanent custody of the original. The safest general principle is that an
employer may have a legitimate reason to inspect, copy or briefly handle a
passport for an official process. Temporary administrative use, however, should
not become control over the worker’s ability to identify themselves, travel,
change jobs or seek help.
Inspection is different from possession
There are three
different situations. Human resources may inspect the original against a copy
and immediately return it. The passport may also be produced to immigration
because an official process requires the original. The more difficult situation
is employer custody: the company keeps the document after the official purpose
has ended and the worker cannot obtain it on request.
“Company
policy”, “safe keeping”, “everyone gives us their passport” or “you will get it
back when your contract ends” are not, by themselves, legal powers. If an
authority has lawfully required surrender or seizure, the employee should be
told which authority and under what process. A private employer should not
imitate statutory powers given to immigration officers, courts or
law-enforcement agencies.
Kenya: the law is unusually direct
Kenya gives one
of the clearest answers. Section 24 of the Kenya Citizenship and Immigration
Act says a valid passport issued under the Act remains in the holder’s
possession until there is lawful cause for withdrawal, suspension or
confiscation. Section 54 goes further by making it an offence, without lawful
cause, to confiscate, forcefully take or detain a passport or travel document
issued to another person.
The Act
separately identifies situations in which immigration or law-enforcement
officers may lawfully suspend or confiscate a travel document. Those are public
powers, not a general licence for an employer. Current Class D
employment-permit guidance also asks for passport copies. Where document
retention is used to stop a person leaving Kenya or seeking help, section 8 of
the Counter-Trafficking in Persons Act creates an additional serious protection
against interference with identification or travel documents.
Uganda: possession and
coercion both matter
Uganda’s
Citizenship and Immigration Control Act places passport administration and
control with immigration authorities. Section 48 makes possession of a passport
or travel document without lawful authority an offence. Foreign workers also
need access to the passport and immigration status on which lawful presence
depends.
Uganda’s
Prevention of Trafficking in Persons Act is particularly relevant to coercive
retention. Section 7 covers confiscating, concealing or destroying a passport,
travel document or other personal documents where this is done to unlawfully
deny freedom of movement or access to public services.
An employer
temporarily handling a passport for a sponsored permit process is not
automatically committing trafficking. Refusing to return it so that the
employee cannot leave, report abuse or approach public authorities is very
different. Uganda’s current permit procedures use documentary uploads and
require the worker to appear with the passport at relevant immigration stages.
That supports cooperation with the official process, not indefinite employer
custody.
Rwanda: withholding
another person’s travel document is an offence
Rwanda’s Law on
Immigration and Emigration is exceptionally clear. Article 53 provides that,
except for an immigration officer, a person who withholds a travel document
that does not belong to them commits an offence. Article 52 separately
addresses pledging, selling or buying travel documents.
The employer
may request the information and documents needed for a work or residence
permit, and immigration officers may inspect originals where necessary. That
does not create private passport-control powers. If a passport is withheld, the
employee should request its immediate return in writing and ask the employer to
identify any legal or immigration instruction said to justify continued
custody. If it is not returned, the matter can be taken to the Directorate
General of Immigration and Emigration and, where appropriate, law-enforcement
authorities.
Tanzania: another
person’s passport should be handed back
Tanzania’s
Passports and Travel Documents Act, Cap. 42, Revised Edition 2023, provides
that a person who comes into possession of a passport or travel document
belonging to another and fails to hand it over to the holder, the Immigration
Department or another government agent commits an offence. Current Class B
residence-permit guidance, meanwhile, asks for a copy of the national passport.
Because the
passport statute principally regulates Tanzanian passports and travel
documents, a foreign worker should not rely on that provision alone. Tanzania’s
Anti-Trafficking in Persons Act adds an important safeguard where documents are
confiscated or concealed in furtherance of trafficking or a trafficked person
is prevented from leaving or seeking redress. The practical distinction remains
clear: copying a passport for immigration compliance is not the same thing as
retaining the original to control resignation, movement or departure.
Burundi: a passport
cannot simply become employer security
Burundi’s
official legal materials continue to invoke the 1996 passport framework in
later passport measures. Article 20 of the 1996 passport decree provides a
penalty where a person destroys, steals or retains a passport or equivalent
document against the holder’s will or without a legal or plausible reason. More
recent rules governing employment of foreigners and EAC citizens require valid
travel and immigration documents for lawful work.
The 2022 joint
employment order requires a valid standard travel document in the work-permit
process. That requirement should not be confused with a right for an employer
to keep it after the application purpose ends. Where the original must
temporarily leave the employee’s hands, the practical safeguard is a receipt
stating who has it, why, and when it should be returned.
Democratic Republic of
the Congo: current permit rules ask for a photocopy
The DRC
Constitution protects the right of every person on the national territory to
move freely and to leave and return subject to law, while legally present
foreigners receive legal protection. The Labour Code also prohibits forced or
compulsory labour.
The October
2025 rules governing the foreign-worker card are especially useful in practice.
They require a photocopy of the worker’s passport and valid visa among the
application documents. The permit file itself therefore does not explain or
justify permanent employer possession of the original.
An older
Congolese ordinance also addresses retention of certain official documents
against the holder’s will without legal or plausible reason. Because that
instrument is old, it should not be the only basis for action. A worker facing
refusal should rely on current immigration documentation requirements and
labour protections and raise the matter with the labour inspectorate, migration
authorities or police.
South Sudan: official
processing is not company custody
South Sudan’s
current Ministry of Labour work-permit guidance says the foreign applicant
should be in possession of a valid passport. Official registration may require
presentation of an original, while the permit file also uses passport copies.
Those procedures do not state that an employer acquires a general right to keep
the employee’s original passport.
The Labour Act
2017 also protects access to employment records. Section 44 provides for the
employee to receive a copy of a written employment contract, while the employer
keeps its own copy. The Act prohibits forced labour as well. A worker should
therefore keep the contract, passport, work-permit card and immigration
records. If the original is required for an official step, ask which authority
requires it and when it will be returned. Unresolved withholding can be raised
with the Ministry of Labour, immigration authorities and police.
Somalia: current rules do
not create a general employer right
Somalia’s
federal work-permit service requires a valid passport and says the company must
request a work permit before a foreign employee legally begins work. The
permit-of-stay procedure likewise requires a valid passport, approved
employment contract and work permit.
The current
public service materials reviewed do not give employers a general right to
retain an original passport after processing. That fits Somalia’s newer
labour-migration framework: the National Labour Migration Policy adopted in
2025 is rights-based, while the private employment agency regulations
strengthen fair recruitment and safeguards against exploitation, with
implementation continuing in 2026.
It would
therefore be inaccurate to invent a single criminal rule or grace period that
the published materials do not provide. A worker whose passport is refused
should contact the Ministry of Labour and Social Affairs, the Immigration and
Citizenship Agency and, where coercion or immediate danger is involved, police.
What to do if the
passport is already being withheld
Begin with a
written request. Identify the document, ask for its return by a clear date, and
ask the employer to state the specific legal authority for any continued
custody. Keep the message factual. At the same time, secure copies of the
passport identity page, visa, work or residence permit, employment contract and
messages showing why the document was handed over.
If the employer
says immigration has the original, ask for the receipt, application reference
and office handling it. If the employer refuses to return it, contact
immigration and the labour ministry or labour inspectorate. Where retention is
being used to prevent travel, force continued work, block a complaint or deny
access to public authorities, involve police or an anti-trafficking body. A
consulate or embassy can assist with passport and protection issues, but do not
falsely report a document as “lost” when you know it is being withheld.
Do not hand
over an original passport as security for recruitment fees, accommodation, a
salary advance or debt merely because this is presented as normal practice. If
an original must temporarily be submitted, obtain a receipt recording the
purpose, recipient and expected return date.
The simple legal test
The most useful
question is not, “Did I voluntarily hand over my passport?” It is, “Can I get
it back when I ask?” Consent to copying or short administrative handling is not
the same as consent to indefinite control.
Across East
Africa, the strongest laws make that distinction explicit, while the more
cautious jurisdictions still provide no obvious general entitlement for a
private employer to turn a worker’s passport into company property. Immigration
compliance may require cooperation, but it should not require surrendering
personal freedom. A responsible employer verifies the document, keeps the
copies legally required, uses the original only where an official process
genuinely needs it, and returns it promptly.
Sources and publication
note
Source note. This article was prepared from official and primary
materials reviewed on 2 September 2026, including the East African Community’s
current Partner State information; Kenya’s Citizenship and Immigration Act,
Counter-Trafficking in Persons Act and immigration permit guidance; Uganda’s
Citizenship and Immigration Control Act, Prevention of Trafficking in Persons
Act and immigration guidance; Rwanda’s Law on Immigration and Emigration;
Tanzania’s Passports and Travel Documents Act, Anti-Trafficking in Persons Act
and residence-permit guidance; Burundi’s passport legislation and 2022 joint
order on employment of foreigners and EAC citizens; the DRC Constitution,
Labour Code and 2025 foreign-worker-card rules; South Sudan’s Labour Act 2017
and Ministry of Labour work-permit guidance; and Somalia’s federal work-permit
and permit-of-stay services, National Labour Migration Policy and private
employment agency framework. Individual facts and later amendments may change
the result. This is general legal information, not legal advice for a
particular case.
Suggested citation:
Ronald Serwanga, “A Foreign Worker Passport Rights Guide: East Africa” East Africa Legal Insight (2 September 2026).