Humanitarian access and adherence to international humanitarian law
International Development Committee
Closed
Inquiry
International humanitarian law includes important rules to facilitate the passage of humanitarian relief such as food, clothing and medical supplies as well as rules on the protection of humanitarian personnel. In addition, UN Security Council resolutions have called for safe and unhindered access for humanitarian personnel. Yet, in recent years …
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20
Recommendations
31
Conclusions
1
Report
1
Oral session
1
Letter
1
Event
Activity timeline 5 events
5 Sep
2025
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26 Jun
2025
2025
12 Jun
2025
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11 Mar
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11 Mar
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2025
Formal meeting (oral evidence session) · The Thatcher Room, Portcullis House
Oral evidence sessions 1 session
11 Mar 2025
View on parliament.uk
Humanitarian access and adherence to international humanitarian law
Anna Tazita Samuel · Women for Change
Imogen Wall · IW Response Associates
Jon Novakovic · Global Interagency Security Forum (GISF)
Steve Dennis · Proper Support
Tarini Ross · Humanitarian Aid International
Reports 1 report · click to expand
| Title | HC No. | Published | Items | Response |
|---|---|---|---|---|
| 5th Report - Protection not permission: The UK’s role in upholdi… | HC 526 | 12 Jun 2025 | 51 | Responded |
Recommendations & Conclusions
51 results
1
Conclusion
Acknowledged
5th Report - Protection not permis…
Rising aid worker deaths and IHL breaches increasingly traded off by belligerents with deadly consequences.
Numbers of aid worker deaths are rising year on year and the situations where access to aid is deliberately impeded are also increasing. This violates the purpose of IHL: to protect civilians in a time of war. We see growing …
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Government Response
The government agrees with the committee's concerns regarding rising aid worker deaths, restrictions on humanitarian access, and IHL violations, affirming that IHL must be respected and all tools leveraged to address these issues.
2
Conclusion
Accepted
5th Report - Protection not permis…
Publicly condemn attitudes of 'trading off' IHL breaches to prevent damage to legal frameworks.
We agree with the view of the ICRC that IHL is clear and comprehensive. It represents both a body of law that is robust and universal in its coverage, and a spirit by which warring parties must place the protection …
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Government Response
The government agrees on the importance of IHL's comprehensiveness and accountability, detailing its existing foreign policy of supporting international criminal justice, vigilant alarm-raising, and support for the International Criminal Court.
3
Recommendation
Not Addressed
5th Report - Protection not permis…
Lead efforts to reach consensus on autonomous weapons and create an international instrument.
We recommend that the UK Government takes the lead in efforts to reach a consensus on the use of autonomous weapon systems and artificial intelligence on the battlefield and the creation of an international instrument on their use. (Recommendation, Paragraph …
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Government Response
The government response discusses diplomatic influence, multilateral engagement, and enhancing IHL adherence for humanitarian access, but it does not address the recommendation regarding autonomous weapon systems and artificial intelligence on the battlefield.
4
Conclusion
Accepted
5th Report - Protection not permis…
Lack of leadership in condemning IHL abuses, despite UK's strong position to lead.
There is encouraging collaboration by a select few UN Member States that are promoting adherence to IHL and, in particular, the protection of aid workers. Yet there is a lack of comprehensive leadership across all aspects of IHL by a …
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Government Response
The government agrees on the vital role of local organisations in humanitarian access negotiations and describes its commitment to leveraging UK influence to include them, and its funding of the Centre for Competence on Humanitarian Negotiations.
5
Conclusion
Not Addressed
5th Report - Protection not permis…
UK armed forces demonstrate strong adherence to International Humanitarian Law, serving as a global example.
The UK armed forces have a strong and proud history of supporting IHL. They have experience of operating within the spirit and letter of IHL in extremely challenging environments, and of complying with accountability mechanisms when there have been allegations …
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Government Response
The government response discusses mitigating sanctions impact on humanitarian aid and monitoring IHL adherence generally, but does not address the committee's specific conclusion regarding the UK armed forces' history and role as an example in upholding IHL.
6
Recommendation
Not Addressed
5th Report - Protection not permis…
Prioritise military-to-military training on International Humanitarian Law for foreign militaries.
We recommend that the Government prioritises military-to-military training on IHL in line with the increase in defence spending. It should make full use of the range of resources it has at its disposal to support foreign militaries to understand not …
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Government Response
The government response outlines the UK's general support for IHL and calls on all parties to comply, but does not address the specific recommendation to prioritise and make full use of military-to-military training on IHL for foreign militaries.
7
Conclusion
Not Addressed
5th Report - Protection not permis…
FCDO's traditional approaches to humanitarian access challenges are ineffective, requiring a new strategy.
The FCDO appears to be repeating the same approaches to overcoming access challenges whilst expecting different results. Successful records of traditional forms of public diplomacy in promoting unimpeded access to aid are patchy at best. Polarisation within bodies such as …
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Government Response
The government response discusses protecting aid workers, IHL, and countering disinformation, but does not address the committee's observation that the FCDO is repeating approaches to access challenges and needs a radically new strategy.
8
Recommendation
Accepted
5th Report - Protection not permis…
Explore creative diplomacy with likeminded states to solve access issues and evaluate FCDO capacity.
We recommend that the UK explores creative forms of diplomacy with likeminded states that can bring maximum pressure and combined diplomatic capability to solving specific access issues. As part of this initiative the diplomatic capacity and influence of the FCDO …
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Government Response
The government agrees that humanitarian aid must be facilitated and commits to strengthening UK diplomatic influence through a new internal humanitarian diplomacy and access strategy, actively pursuing diplomatic efforts, and supporting relevant international mechanisms.
9
Conclusion
Not Addressed
5th Report - Protection not permis…
UK well-positioned to amplify local voices in humanitarian aid access and localisation.
The UK is well placed to ensure the voice of local organisations is heard in negotiations over access for humanitarian aid. This input is vital for effective and sustainable aid delivery as well as maximising the safety of 49 those …
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Government Response
The government response discusses risk management for aid workers, programme guidelines, and budget lines for security, but does not directly address the committee's conclusion that the UK is well placed to ensure local organisations' voices are heard in access negotiations.
10
Conclusion
Accepted
5th Report - Protection not permis…
Unclear UK anti-terrorism legislation risks limiting safe delivery of aid.
We applaud the work of the current and previous Governments in ensuring that the safe delivery of aid is not jeopardised by most of the UK’s own legislation. However, lack of clarity around the UK’s anti-terrorism legislation has had a …
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Government Response
The government acknowledges seeking to mitigate negative impacts of sanctions and counter-terrorism legislation on humanitarian aid delivery and describes existing work with aid partners, including the UK Tri-Sector Group, to promote compliance.
11
Recommendation
Accepted in Part
5th Report - Protection not permis…
Provide clearer guidance and consider standing exemptions for humanitarian organisations regarding sanctions.
We encourage the Government to consider a standing exemption for relevant humanitarian organisations to ensure that they do not risk liability for their legitimate dealings with sanctioned entities. In the meantime, the Office of Financial Sanctions Implementation (OFSI) must provide …
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Government Response
The government agrees and commits to introducing a tailored humanitarian exemption or ‘carve-out’ across autonomous UK sanctions when parliamentary time allows. They also state OFSI has comprehensive guidance and will continue working to produce clear guidance for humanitarian actors.
12
Conclusion
Accepted
5th Report - Protection not permis…
UK has important role in supporting mechanisms for accountability of IHL breaches.
During an evidence session, the Minister was unclear about the extent of the application of approved approaches when it came to creative responses to the situation in Gaza. There are various mechanisms available at the international, regional and domestic levels …
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Government Response
The government asserts it is clear and consistent in its support for IHL in Gaza, consistently urges Israeli authorities to conduct swift investigations into incidents involving aid workers, and believes it is meeting its obligations through existing measures.
13
Conclusion
Acknowledged
5th Report - Protection not permis…
International Criminal Court provides forum for holding states accountable for IHL breaches.
At the international level, the International Criminal Court provides a forum for holding states and individuals, respectively, accountable for breaches of IHL. (Conclusion, Paragraph 35)
Government Response
The government agrees with the conclusion, affirming its full commitment to international law and respect for the independence of the ICJ and ICC. It reiterates its strong support for the ICC through multilateral engagement and by encouraging states to become parties to the Rome Statute.
14
Conclusion
Accepted
5th Report - Protection not permis…
Firmly support international courts and accountability mechanisms to prevent impunity for IHL violations.
At a time when the legitimacy and impartiality of international courts is being questioned by some, the UK must stand firm in support of these important mechanisms for accountability to prevent impunity for serious violations of IHL. (Recommendation, Paragraph 36)
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Government Response
The government agrees to stand firm in support of international courts, stating its full commitment to international law and respect for the independence of the ICJ and ICC, and reinforcing its support through multilateral fora.
15
Conclusion
Acknowledged
5th Report - Protection not permis…
UK lacks consistency condemning IHL breaches, especially when protecting allies.
We welcome the times that the Government has made a stand on the likely breaches of IHL that have reduced access of populations to aid and/or have failed to protect those delivering aid. We also welcome the more general calls …
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Government Response
The government partially agrees, stating it consistently calls on all parties to comply with IHL without differentiation and engages with partners to address reported violations. It clarifies that it cannot provide a running commentary on possible breaches due to lack of detailed information.
16
Recommendation
Acknowledged
5th Report - Protection not permis…
Condemn IHL breaches consistently, irrespective of diplomatic relationships with offending parties.
As part of the UK’s leadership role, the Government must be ready to call out actions not only when a blatant breach of IHL has been ruled on by a court, but when the spirit of IHL is being eroded. …
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Government Response
The government partially agrees, stating it consistently calls on all parties to comply with IHL and observe robust standards without differentiation. It clarifies that it cannot provide a running commentary on possible breaches due to lack of detailed information to determine IHL violations.
17
Conclusion
Deferred
5th Report - Protection not permis…
Government failed to formally respond to ICJ opinion on Israel's IHL compliance.
The FCDO needs to be led by the law without fear or favour. In July 2024, the International Courts of Justice handed down its advisory opinion on the legality of Israel’s policies and practices in the Occupied Palestinian Territories. This …
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Government Response
The government acknowledges the ICJ's advisory opinion and states it is carefully considering it, committing to publish a full response in due course. It reiterates its commitment to international law and respects the ICJ's independence.
18
Recommendation
Rejected
5th Report - Protection not permis…
Issue formal response to ICJ opinion on Israel's policies in Occupied Palestinian Territories.
We urge the Government to issue a formal response to the ICJ’s opinion concerning Israel’s policies and practices in the Occupied Palestinian Territories, setting out how it is complying with the obligations on the UK as a third party. (Recommendation, …
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Government Response
The government rejects the recommendation, stating that consistent with long-standing policy, it does not consider the ICJ to have jurisdiction in this contentious case between Israel and Palestine. It maintains that a lasting peace requires a negotiated settlement between the parties.
19
Recommendation
Accepted in Part
5th Report - Protection not permis…
Call for UNSC Special Session on IHL disregard, humanitarian access, and aid worker safety.
We recommend that the UK works with the other UN Member States represented on the ministerial group for the safety of humanitarian aid workers to call for a Special Session of the UNSC to discuss the problem of disregard of …
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Government Response
The government partially agrees, stating it already actively engages with UN Member States and co-sponsored UNSCR 2730, which addresses humanitarian personnel protection and will lead to a UN Secretary-General's report. It also supports the inclusion of humanitarian access in UN reports and commits to continue doing so, but does not specifically commit to calling for a Special Session of the UNSC focused on hearing from aid workers.
20
Recommendation
Rejected
5th Report - Protection not permis…
Establish an independent central repository of evidence for IHL breaches against aid workers.
We recommend that the FCDO works with international partners to establish an independent central repository of evidence of breaches of IHL relating to the delivery of aid and attacks on aid workers. For this to be successful, the Government should …
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Government Response
The government partially agrees with the intent but rejects leading the establishment of a new standalone central repository for evidence of IHL breaches. It prioritizes supporting existing mechanisms, such as UN and IIIM mechanisms, to prevent duplication of efforts.
21
Conclusion
Accepted
5th Report - Protection not permis…
Insufficient UK support for local prosecution of IHL breaches.
We agree with the Government that it is preferable to prosecute suspected breaches of IHL within the jurisdiction where they occurred, but only where there are sufficient resources and guarantees of fair trials. There is more the UK could be …
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Government Response
The government agrees that prosecuting breaches of IHL locally is preferable and highlights its existing support for capacity building in partner countries to strengthen justice and accountability mechanisms for IHL violations.
22
Recommendation
Rejected
5th Report - Protection not permis…
Establish a roster of independent experts to investigate IHL breaches.
We recommend that the UK works with other willing members of the Ministerial Group on the Safety of Humanitarian Workers to establish a roster of independent legal experts and expert investigators who can support the criminal investigations of suspected breaches …
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Government Response
The government explicitly rejects establishing a new roster of independent legal experts and investigators, stating it will continue to prioritise support to existing accountability mechanisms instead.
23
Conclusion
Accepted
5th Report - Protection not permis…
Ensure UK can exercise universal jurisdiction over international crimes against aid workers.
The preamble to the Statute of the International Criminal Court recalls “the duty of every State to exercise its criminal jurisdiction over those responsible for international crimes.” At the domestic level, the UK must ensure that it can exercise universal …
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Government Response
The government states it is committed to bringing perpetrators of serious international crimes to justice and already possesses a robust legal framework, including extraterritorial jurisdiction, for prosecuting such crimes in the UK regardless of where they were committed.
24
Recommendation
Rejected
5th Report - Protection not permis…
Amend International Criminal Court Act to provide universal jurisdiction for war crimes.
We recommend an amendment to the Crime and Policing Bill, to amend the International Criminal Court Act 2001, to provide for universal jurisdiction. This would allow for suspected war criminals to be investigated and prosecuted in the UK irrespective of …
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Government Response
The government explicitly rejects amending the Crime and Policing Bill to extend universal jurisdiction, asserting that its existing robust legal framework, including the ICCA 2001, is sufficient for prosecuting international crimes.
25
Recommendation
Accepted
5th Report - Protection not permis…
Support and fund UN investigative mechanisms for IHL breaches and evidence preservation.
The UN has also established various investigative mechanisms in response to particular atrocities. Wherever possible, the UK should support, fund and participate in these mechanisms to assist with fact-finding, truth discovery, and the preservation of evidence of breaches of IHL. …
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Government Response
The government agrees, stating it already strongly supports and funds various UN investigative mechanisms, providing specific examples of financial support to several missions and ongoing funding for the ICC and other bodies. It also commits to promoting the use of the IHFFC where appropriate.
26
Recommendation
Accepted
5th Report - Protection not permis…
Utilise International Humanitarian Fact Finding Commission to establish IHL breaches and recommend its services.
Specifically, we recommend that the UK makes better use of the good offices of the International Humanitarian Fact Finding Commission as part of its process of establishing whether IHL has been broken in specific cases. It should also be actively …
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Government Response
The government agrees, stating it recognises the IHFFC as an important mechanism and, while it hasn't used it in specific past contexts, it will consider its use where appropriate and will promote the use of the IHFFC.
27
Recommendation
Accepted
5th Report - Protection not permis…
Utilise existing sanctions powers to ensure greater respect for international humanitarian law.
In addition to legal mechanisms, the Government must use its powers to make sanctions a tool for ensuring respect for IHL. The Sanctions and Anti-Money Laundering Act 2018 provides the Government with the power to make sanctions for the purpose …
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Government Response
The government agrees, stating it already uses its extensive sanctions powers to encourage compliance with IHL, citing specific examples of sanctions against individuals in Sudan, South Sudan, and Myanmar in 2025 and 2024.
28
Recommendation
Accepted
5th Report - Protection not permis…
Apply sanctions to individuals for clear IHL breaches, with sufficient resources and evidence.
The Government must use its power to sanction individuals in response to clear breaches of IHL, such as unlawful killings of aid workers and restrictions on humanitarian aid and assistance. To do this the Government 52 must make sure that …
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Government Response
The government agrees, stating it already uses its sanctions powers to encourage compliance with IHL, providing examples of recent sanctions. It also notes that the FCDO continues to assess resourcing requirements for the Sanctions Directorate and that the evidential threshold for designations is set appropriately.
29
Conclusion
Accepted in Part
5th Report - Protection not permis…
Insufficient government action to prevent UK weapon components harming aid workers.
There is much more the Government could do to ensure that UK manufactured weapon components do not fall into the hands of those who may use them in attacks on aid workers and aid infrastructure. (Conclusion, Paragraph 61)
Government Response
The government partially agrees, stating it already has a robust export control regime and will publish an annual report on UK strategic export controls. However, it rejects commitments to an independent review of past allegations, independent audits, or temporary freezing of licences.
30
Recommendation
Accepted in Part
5th Report - Protection not permis…
Introduce interim measures to freeze arms export licences for suspected IHL breaches.
We recommend the Government a. Provide for interim measures to allow for the temporary freezing of licenses where there are credible allegations of IHL breaches, subject to full investigation and final determination; b. report findings of independent audits of arms …
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Government Response
The government partially agrees, stating it already assesses IHL risks and wider security context, including risks to aid workers, for export licences, and will publish an annual report on strategic export controls. However, it rejects providing for interim licence freezing and independent audits of arms exports due to policy and operational reasons.
31
Conclusion
Rejected
5th Report - Protection not permis…
Companies lack legal requirement to halt arms exports risking IHL breaches.
There is no legal requirement for companies in the UK to stop exporting arms when they are aware of a clear risk that their weapons could be used in suspected breaches of IHL–instead the legal obligations rest on the Government. …
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Government Response
The government rejects the implicit call for action, stating that legal obligations for arms exports rest with the government, not manufacturers, and it does not intend to legislate for binding due diligence requirements. It maintains the UK already has a robust export control regime.
32
Recommendation
Rejected
5th Report - Protection not permis…
Legislate binding due diligence for arms manufacturers and prosecute complicit directors.
The Government should legislate to provide for binding due diligence requirements on arms manufacturers. The Government should also make use of existing powers under the International Criminal Court Act (2001) to prosecute directors of arms manufacturers for complicity in war …
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Government Response
The government rejects the recommendation, stating it already has a robust export control regime and does not intend to legislate for due diligence requirements. It also states that prosecutions are a matter for independent authorities, which the government cannot direct.
33
Recommendation
Accepted in Part
5th Report - Protection not permis…
Commemorate sacrifices of aid workers through memorial services and parliamentary updates.
We recommend that the Government takes appropriate opportunities to commemorate the sacrifices of the hundreds of aid workers every year who pay the ultimate price in the service of others. This should include representation at the memorial service in Westminster …
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Government Response
The government agrees to commemorate aid worker sacrifices, noting it already marks World Humanitarian Day, attends memorial services, delivers speeches for UNSCR 2730, and has introduced the Humanitarian Medal. It welcomes the suggestion to update Parliament on this issue as feasible.
34
Conclusion
Acknowledged
5th Report - Protection not permis…
Aid workers face unprecedented dangers and attacks, contravening international humanitarian law.
It has never been more dangerous to be a humanitarian aid worker. These workers put their lives on the line every day to protect others. Aid workers suffer direct intimidation and attacks in the field, as well as the impact …
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Government Response
The government acknowledges the increased risks to humanitarian personnel and reaffirms its commitment to championing aid worker protection through ongoing initiatives, including the proposed Australia-led Declaration.
35
Conclusion
Acknowledged
5th Report - Protection not permis…
Malicious disinformation hampers aid worker safety and humanitarian aid delivery.
The safety of aid workers and aid delivery is further hampered by the spread of malicious disinformation online and in other forms of media. (Conclusion, Paragraph 71)
Government Response
The government agrees that malicious disinformation threatens aid worker safety, highlighting the BBC World Service's role and describing FCDO's existing efforts to counter foreign information manipulation, including a recent programme in Sudan.
36
Recommendation
Accepted in Part
5th Report - Protection not permis…
Collaborate with ODA partners to counter disinformation and fund BBC World Service.
We recommend that the Government work closely with those delivering UK Official Development Assistance to identify appropriate responses to disinformation aimed at neutral implementing partners. This should include ensuring organisations such as the BBC World Service are adequately funded to …
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Government Response
The government agrees to work on identifying responses to disinformation, citing existing FCDO efforts like a programme in Sudan. However, it clarifies the BBC World Service's editorial independence and does not commit to directly ensuring its funding as a government tool for countering disinformation.
37
Conclusion
Acknowledged
5th Report - Protection not permis…
Overly-politicised humanitarian responses risk safe delivery of UK-funded aid.
While it is important that the UK’s aid, trade, defence and diplomacy objectives are coherent, there is a risk that overly-politicised humanitarian responses can make the safe delivery of UK-funded support difficult. (Conclusion, Paragraph 73)
Government Response
The government agrees that humanitarian aid must be impartial, outlining its current approach to ensure principled aid delivery through strong partnerships, coherent diplomatic action, new humanitarian diplomacy training, and a humanitarian allocation model.
38
Conclusion
Accepted
5th Report - Protection not permis…
Government must ascertain employer duty of care after aid worker casualties.
It is vital that, where aid workers delivering UK Official Development Assistance are casualties, the Government is able to ascertain whether the employer was diligent in its duty of care responsibilities. (Conclusion, Paragraph 75)
Government Response
The government acknowledges the importance of employers' duty of care, detailing its existing due diligence processes for partner organizations, post-incident assessments, and funding for INSO, while also committing to incorporating the IASC Risk Sharing framework.
39
Conclusion
Rejected
5th Report - Protection not permis…
Adequately resource Charity Commission to investigate NGO duty of care to employees.
Where incidents relate to employees of UK-registered NGOs, it is essential that the Charity Commission is adequately resourced, and has the necessary powers, to investigate whether relevant organisations were diligent in their statutory obligations regarding their employees. (Recommendation, Paragraph 76)
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Government Response
The government partially agrees but clarifies the Charity Commission's independent and limited role, and does not commit to ensuring it receives adequate resources or new powers as recommended.
40
Conclusion
Accepted
5th Report - Protection not permis…
Underfunding of security risk management jeopardises aid worker mental health and welfare.
Constrained budgets and competition for funding may incentivise the over- promising of delivery by international NGOs at the risk of underfunding security risk management. This runs the risk of subjecting aid workers to unnecessary pressures, and of their welfare being …
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Government Response
The government agrees, explaining that FCDO already prioritises mental health and psychosocial support (MHPSS) funding through existing internal guidance, due diligence frameworks, and funding guidelines, which enable partners to budget for staff psychological support.
41
Conclusion
Accepted
5th Report - Protection not permis…
Provide flexible funding to local organisations for culturally appropriate aid worker psychological support.
Psychological support and wellbeing strategies need to be appropriate to the context and culture of the aid workers in question. Sufficient flexibility in funding must be built in to ensure that local organisations are supported in designing and implementing their …
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Government Response
The government agrees, detailing that FCDO's existing guidance, due diligence framework, and funding guidelines already enable partners to budget for staff psychological support and wellbeing, including for local organisations, and ensures flexible cost recovery.
42
Conclusion
Accepted in Part
5th Report - Protection not permis…
Make FCDO security and mental health expertise accessible to local NGOs upon request.
Beyond funding, the FCDO should explore how it might make its in- house security and mental health expertise, particularly at diplomatic mission level, accessible to local NGOs as requested as appropriate. (Recommendation, Paragraph 81)
Government Response
The government partially agrees, stating they cannot commit resources to extend direct security and mental health services to third parties. However, they are open to sharing the rationale for their strategic approach to staff welfare and wellbeing and encourage mutual information exchange with interested partners.
43
Conclusion
Accepted
5th Report - Protection not permis…
Donors and employers bear moral responsibility for mitigating risks to aid workers.
Whilst it is always the perpetrator who is responsible for the harm caused to victims, there is more that donors and employers could do to mitigate the risks. Indeed, it is the moral responsibility of donors to do all they …
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Government Response
The government accepts its responsibility and plans to review existing programme guidelines and consider stand-alone guidance on mitigating risks to aid workers, including promoting direct partner contact. They will also continue efforts to support global Humanitarian Notification Systems.
44
Conclusion
Accepted
5th Report - Protection not permis…
Avoid prejudicing humanitarian aid proposals with higher security costs; question lower cost proposals.
We recognise the impact that reducing Official Development Assistance from 0.5%-0.3% of gross national income will have on availability of funding for humanitarian relief. However, any defunding of costs associated with the security of aid workers would be a false …
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Government Response
The government partially agrees, stating FCDO is committed to aid worker safety and assesses high and low security costs using a Value for Money lens focused on maximising impact. They clarify that their existing Humanitarian Allocation Model already accounts for access and local security considerations.
45
Recommendation
Rejected
5th Report - Protection not permis…
Establish a dedicated, flexible fund for security risk management, separate from programme costs.
We recommend security risk management costs are decoupled from other programme costs. There should be a designated security risk management fund that organisations delivering UK Official Development Assistance can apply to in order to support their broader security requirements. These …
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Government Response
The government partially agrees on the importance of aid worker safety but explicitly rejects the recommendation for a new designated security risk management fund, arguing it would reduce overall funding due to significant administrative and management costs.
46
Conclusion
Accepted
5th Report - Protection not permis…
Ensure programme-specific security risk management costs are distinct budget lines, not administration.
Where programme-specific security risk management costs are still built into programme budgets, these should be a distinct budget line rather than being part of administration costs. (Recommendation, Paragraph 88)
Government Response
The government agrees and commits to exploring the possibility of including a dedicated budget line for programme-specific security risk management costs in FCDO's standard templates, and will issue guidance to staff reviewing humanitarian budgets.
47
Conclusion
Accepted
5th Report - Protection not permis…
Inadequate funding arrangements hinder local organisations' security requirements in humanitarian aid delivery.
Approaches to negotiating contracts and funding arrangements, where local organisations will be delivering humanitarian aid, are not always fit for purpose. There are inadequate mechanisms to ensure that the security requirements of local organisations are fed through intermediaries to the …
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Government Response
The government agrees, committing to issue internal guidance emphasizing the importance of FCDO officials aiming for direct contact with local delivery organisations during proposal and implementation stages to ensure security concerns are adequately covered.
48
Conclusion
Accepted
5th Report - Protection not permis…
Establish direct FCDO contact with local delivery organisations on security during contract phases.
FCDO officials managing contracts where a significant amount of aid will be delivered by local organisations should aim for direct contact with the relevant local delivery organisation during the proposal agreement stage, regardless of who the contract is with. These …
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Government Response
The government agrees and commits to issue internal guidance emphasizing the importance of FCDO officials aiming for direct contact with local delivery organisations during proposal, implementation, and evaluation stages to ensure security concerns are adequately covered.
49
Conclusion
Accepted in Part
5th Report - Protection not permis…
Ensure comprehensive and affordable insurance covers aid workers' legal, medical, and psychological support.
The FCDO needs to make sure that insurance provided to aid workers by their employers covers legal advice and longer-term medical, including physiological support. The FCDO should work with insurance providers and delivery partners to ensure that appropriate and affordable …
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Government Response
The government partially agrees, stating that while they support partners' access to insurance, the choice of provider lies with partners. They note flexible funding guidelines and due diligence processes that ensure partners consider staff wellbeing, highlighting the HAVEN programme in Ukraine as an example.
50
Conclusion
Accepted
5th Report - Protection not permis…
FCDO's contract approach obstructs cost-effective pooling of security risk management services.
The relief and development sector continues to strive for value for money– maximising the essential aid to those who need it whilst keeping its staff safe. We have witnessed the strong collegiate working between security risk management professionals across the …
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Government Response
The government partially agrees that collaborative approaches enhance cost efficiency, but states that a new security risk management fund is not required. They fund INSO as a pooled resource, are exploring funding for GISF, and support consortia for shared resources and impact.
51
Recommendation
Rejected
5th Report - Protection not permis…
Prioritise security risk management fund grants to catalyse pooling of activities.
The security risk management fund we recommend should prioritise grants that catalyse the pooling of activities–ensuring the best value for money and maximum reach. For example, this could include funding for pooled Hazardous Environment Awareness Training, in-country NGO forums, shared …
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Government Response
The government partially agrees on the value of collaborative approaches but rejects the recommendation to establish a new security risk management fund. They state they already fund pooled resources like INSO and are exploring support for GISF, and have a history of supporting consortia.
Correspondence 1 letter
26 Jun 2025
Correspondence to the Secretary of State for Business and Trade relating to the exemption of F-35 components from suspended arms exports to Israel, 26 June 2025
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