authorization of some or all of the activities of an association is therefore incompatible with the freedom of association.301 Accordingly, participating States should promptly eliminate any such systems. 209. States should ensure that reporting requirements placed on NGOs and other asso- ciations are reasonable and do not inhibit their functional autonomy.302 Similarly, laws and regulations concerning audits and inspections of NGO offices and their financial records should be clear, fair and transparent, and should provide for sufficient safeguards against abuse. Ample notice should be given prior to an inspection to give the NGO adequate time to prepare. Appropriate notice should also be given if an NGO fails to comply with reasonable reporting requirements or other regulations so as to give the organization an opportunity to supply additional documentation or make corrections.303 Any sanctions – such as fines and the withdrawal of state subsidies or other privileges – imposed in case of persisting violations of reasonable requirements and regulations must be proportionate, and preference should always be given to the least intrusive means of achieving the envisioned objective.304 In order to provide safeguards against abuse, there must under all circumstances be fully effective remedies to appeal any such sanctions. While laws and regulations may require that individual members of an NGO or other association that does not have legal personality bear liability, such provisions must not be abused as a means of exerting pressure on individual human rights defenders for their legitimate work. Participating States should also eliminate practices of harassment and intimidation of project beneficiaries and private contractors who provide services to NGOs. 301  See CDL(2013)017, “Some preliminary reflections on standards and legislation relating to freedom of association and non-governmental organisations (NGOs)”, 28 March 2013, paras. 19-21. 302  A/HRC/RES/22/6, 12 April 2013. 303  See UN Special Rapporteur on the situation of human rights defenders, “Commentary to the Declaration of Human Rights Defenders”, p. 46, para. xiii, which also points out that states should not criminalize non-compliance with laws governing civil society organizations. 304  In its views on the case of Belyatsky v. Belarus (Communication 1296/2004, 24 July 2007, UN Doc. CCPR/ C/90/D/1296/2004), which concerned the dissolution of the human rights organization “Viasna”, the UN Human Rights Committee emphasized: “[t]he mere existence of reasonable and objective justifications for limiting the right to freedom of association is not sufficient. The State party must further demonstrate that the prohibition of an association is necessary to avert a real and not only hypothetical danger to national security or democratic order, and that less intrusive measures would be insufficient to achieve the same purpose“ (para. 7.3). See also the case of Korneenko et al. v. Belarus (Communication 1274/2004, 31 October 2006, UN Doc. CCPR/C/88/D/1274/2004), which concerned the dissolution of another human rights association by a Court order based on two perceived violations, namely: “(1) improper use of equipment, received through foreign grants, for the production of propaganda materials and the conduct of propaganda activities; and (2) deficiencies in the association’s documentation”. The Committee held that the dissolution violated the requirements of Article 22(2) of the ICCPR, noting among other things that even if the documentation did not fully comply with the requirements of domestic law, the reaction of the state party’s authorities in dissolving the association was disproportionate (para. 7.6.). The Venice Commission of the Council of Europe also recalled “that the dissolution of an NGO is an extreme measure, which needs to be based on a well-founded rationale and it is well established under the international case-law that it can only be resorted to in exceptional situations.” See “Opinion on the compatibility with universal human rights standards of article 193-1 of the criminal code on the rights of non-registered associations of the Republic of Belarus”, CDL-AD(2011)036, para. 107. Guidelines on the Protection of Human Rights Defenders 97