Observation (CEACR) - adopted 2025, published 114th ILC session (2026)

Minimum Age Convention, 1973 (No. 138) - Sudan (Ratification: 2003)

The Committee takes note of the Government’s indication, in its report under the Worst Forms of Child Labour Convention, 1999 (No. 182), that a new draft law on children is being examined by the competent authorities, in response to the gaps identified through the practical implementation of the Child Law of 2010. The Committee requests the Government to provide information on the progress made in the development and adoption of the new draft law on children.

Article 1 of the Convention. National policy and application of the Convention in practice. The Committee previously took note with concern of the significant number of children below the minimum age who were involved in child labour in the Sudan, (12.6 per cent among children aged 5–14 years). The Committee observes that, according to ILO Statistics Harmonized Microdata of 2022, the incidence of child labour in the country increased to 17 per cent for children aged 5-14 years. Moreover, the Committee notes, from a United Nations press release from March 2024, that since the resurgence of the conflict in April 2023, 24 million children are at risk of a generational catastrophe, and their rights to life, survival, protection, education, health, and development have all been gravely violated. According to a UNICEF press release of 2025, more than 16 million children in Sudan are trapped in one of the world’s worst humanitarian crises and urgently need aid, with many facing such violations as child labour.

While acknowledging the difficult situation prevailing in the country, the Committee must express its deep concern at the situation wherein a high number of children are involved in child labour and even more are now at risk of such exploitation. The Committee urges the Government to intensify its efforts to improve the situation of children in the Sudan and to protect and prevent them from child labour. It requests the Government to provide information on the measures taken in this regard, and the results achieved. The Committee further requests the Government to continue to provide information on the manner in which the Convention is applied in practice, and to provide data on the nature, extent and trends of child labour in the country.

Article 2(1). Scope of application and labour inspection. Following its previous comments, the Committee notes the Government’s information, in its report, that the Inspection Department at the Ministry of Labour conducts inspections within its limited capacity, focusing on mining sites in particular, and in other areas involving child labour, in coordination with state labour offices. It began its work in the River Nile State in March 2023, but the war prevented the completion of the inspection visits. The Government also indicates that the National Inspection Policy, which strengthens the capacity of the Labour Inspectorate, has not yet been formulated. While taking note of the difficulties faced by the country in this regard, the Committee urges the Government to pursue measures to adapt and strengthen the labour inspection services, including through the formulation of the National Inspection Policy, in order to improve their capacity to detect cases of child labour. It requests the Government to provide information on the measures taken in this regard and the results achieved.

Article 2(3). Age of completion of compulsory schooling. As regards the measures taken by the Government to improve the functioning of the education system, the Committee refers to its comments under the Worst Forms of Child Labour Convention, 1999 (No. 182).

Article 3(2). Determination of types of hazardous work. The Committee recalls that a committee was established pursuant to Administrative Decision No. 22 of 2018 by the Ministry of Labour and the relevant authorities to review the draft list of hazardous activities. It notes the Government’s information, as provided in its report, indicating that while an agreement was reached on issuing a regulation to identify types of hazardous work, following consultations with the relevant employers’ and workers’ organizations, a ministerial decision is still pending. Its approval is contingent upon the completion of ongoing amendments to the Labour Law, to which it will be annexed. The Committee once again expresses the firm hope that the Government will take the necessary measures, without delay, to ensure that the legal provisions determining the types of hazardous work to be prohibited for persons under 18 years of age will be adopted, in the very near future. It requests the Government to continue providing information on the progress made in this regard and to provide a copy of the list, once adopted.

Article 7. Light work and determination of light work activities. The Committee recalls that section 36(1) of the Child Act of 2010 permits exceptions to the minimum age of 14 for admission to work for children working in agricultural works that are not dangerous, but that it does not specify a lower minimum age for these activities, nor the number of hours during which, and the conditions in which, such employment or work may be undertaken. The Committee notes the Government’s information, in its report, that it is working towards ensuring that the minimum age for the types of work allowed below the age of 14 years is set at 12 years, and strengthening the Inspection Department to monitor the application of this provision. The Government indicates that, when amending the relevant laws, consideration will be given to ensuring the implementation of Article 7(1) and (4) of the Convention. The Committee requests the Government to take the necessary measures, in the process of amendment of the Child Act, to ensure that a minimum age of 12 years is set for light work activities, including in agricultural works. It also expresses the firm hope that, in the process of making these amendments, the number of hours during which, and the conditions in which, such work may be undertaken by children between 12 and 14 years, are clearly determined, in conformity with Article 7(3) of the Convention. It requests the Government to provide information on the progress made in this respect.

The Committee is raising another matter in a request addressed directly to the Government.