Fifth Special Report
The International Development Committee published its Fifth Report of Session 2024–25, Protection not permission: The UK’s role in upholding international humanitarian law and supporting the safe delivery of humanitarian aid (HC 526), on 12 June 2025. The Government’s response was received on 2 September 2025 and is appended below.
Appendix: Government Response
Introduction
1. The UK Government is grateful to the International Development Committee for its report on The UK’s role in upholding international humanitarian law and supporting the safe delivery of humanitarian aid, published on 12 June 2025.
2. The UK Government remains steadfast in its commitment to upholding international humanitarian law (IHL) and protecting civilians in conflict, including aid workers. We are clear that international law applies globally and without exception.
3. Humanitarian aid workers willingly go to some of the most unstable and dangerous environments in the world to deliver life-saving assistance. But the risks they face are rising. 2024 was the deadliest year on record for humanitarian aid workers, with over 380 fatalities, including British citizens. We must not allow this alarming trend to become the new normal. The consequences for aid workers, their families, and the vulnerable populations who rely on humanitarian assistance for survival, are devastating.
4. We welcome the Committee’s focus on these important topics and we have carefully considered the Committee’s recommendations. This response addresses the Committee’s recommendations in the order in which they appear in the report.
Upholding International Humanitarian Law
(Conclusion 1, paragraph 7) 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 examples of where IHL is ignored or used to justify the restrictions to aid delivery. This has to stop. Furthermore, we have concerns that there is a trend of breaches of IHL being ‘traded off’ by implicated parties who can be seen to justify breaking IHL as a result of the other party or parties doing the same. This apparent ‘race to the bottom’ is extremely worrying and demonstrably contrary to the spirit of IHL which sets high standards to ensure citizens and humanitarian workers are appropriately protected in conflict zones. The short-term impacts of IHL trade-offs by belligerents is having stark and deadly consequences.
Government response
5. IHL (also known as the law of armed conflict, or the laws of war) serves several important purposes. It seeks to balance military requirements and humanitarian considerations, serving as a critical tool in seeking to limit the effects of armed conflict to protect people who are not, or who are no longer participating in hostilities, and to limit the methods and means of warfare.
6. As such it sets a universal standard for the protection of people in conflict zones, offering a legal framework for the regulation of hostilities underpinned by the four basic principles governing hostilities: distinction, military necessity, humanity, and proportionality.
7. We agree that the increase in incidents which harm aid workers, and growing restrictions on humanitarian access where aid is needed most, are deeply concerning. IHL cannot be ignored and its rules on the delivery of humanitarian aid must be respected. We agree that all diplomatic, funding, and legal tools must be leveraged to stop this trend from becoming the new normal.
8. The UK is clear that all parties to armed conflict must respect IHL irrespective of the conduct of other parties. The UK calls on all parties to all conflicts, without distinction, to adhere to IHL.
(Conclusion 2, paragraph 9) 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 of civilians at the heart of their operational planning. However, there are serious deficiencies in the enforcement mechanisms and the ability of the international community to hold states and non-state actors accountable for violations of that law and spirit. As noted above, there is also an apparent willingness from non-state armed groups and UN Member States to ‘trade off’ the IHL breaches of others to justify further military action. This presents a threat to their very existence. These attitudes need exposing and publicly condemning by world leaders to prevent established and tested legal frameworks from being irrevocably damaged.
Government Response
9. We agree that IHL is comprehensive and that both compliance and accountability are critical. As noted above, the UK is clear that parties to armed conflict must respect IHL even if the other parties do not.
10. UK support for accountability and for international criminal justice remains a fundamental element of our foreign policy. We are vigilant in raising the alarm where we see signs that violations of IHL may occur – directly with the countries involved, with nearby nations, and through international organisations.
11. Violations of IHL highlight the need for mechanisms to ensure effective compliance and accountability. As regards accountability, our focus is on supporting existing mechanisms, including domestic, where governments are best placed to tackle impunity.
12. The UK strongly supports the International Criminal Court as the primary international court for investigating and prosecuting individuals charged with the most serious crimes of international concern.
(Recommendation 1, paragraph 10) 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.
Government Response: Agree
13. We agree with recommendation 1. The UK is committed to developing and using Artificial Intelligence (AI) in weapons systems safely, legally and ethically and oppose the creation and use of any AI-enabled military capabilities that would operate without context-appropriate human involvement. We have set out more detail on how we maintain this in our response1 to the report by the House of Lords AI in Weapon Systems Committee in February 2024.
14. The UK continues to support the current mandate of the Group of Governmental Experts (GGE) under the Convention on Certain Conventional Weapons (CCW) “to formulate, by consensus, a set of elements of an instrument, without prejudging its nature, and other possible measures to address emerging technologies in the area of lethal autonomous weapons systems (LAWS)” and is demonstrating leadership through working proactively to fulfil that mandate, working with a wide range of different states.
15. The Government maintains that the CCW remains the appropriate forum to consider the issue of emerging technologies in the area of LAWS. It is inclusive, expert and consensus based which means that as a forum its conclusions will have the most meaningful impact.
The International consensus
(Conclusion 3, paragraph 13) 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 single Member State and a willingness to expose and publicly condemn flagrant abuses of IHL. This is challenging when traditional allies or leading world powers may be involved, but inconsistent application of IHL will be to its long-term detriment if IHL-conscious nations don’t make the appropriate interventions. The UK is well positioned to lead this endeavour to uphold IHL and the particular obligations in relation to humanitarian access and the protection of aid workers. This is a significant opportunity for the UK in a 0.3% foreign aid budget world, given that sharing expertise costs very little. In fact, it is one of the few areas where aid budget cuts need not have an impact and the UK could maintain and enhance its position as a world leader.
Government Response
16. We agree that the UK must continue to draw upon all available levers including diplomatic influence, multilateral engagement, and ODA to enhance UK impact at a time of global funding cuts.
17. Enhancing adherence to IHL, humanitarian access, and the protection of aid workers are urgent global challenges that no single state can solve alone. But the UK is determined to play its full part – through leadership, partnership and practical action. We’re tackling these issues at every level, using the full breadth of UK influence.
18. The UK systematically uses diplomatic tools to encourage parties to consent to humanitarian relief operations, facilitate unimpeded access, protect civilians including humanitarian aid workers, and comply with their relevant obligations under international law. We take both public and private action.
19. This includes work to strengthen global rules and commitments in partnership with other Member States, as highlighted by the committee. The UK helps to secure progress through UN Security Council Resolutions (UNSCRs) including by co-sponsoring UNSCR 2730 on the Protection of Humanitarian Personnel. In addition, the UK is an active member of global initiatives like the proposed Australian-led Political Declaration on the Protection of Humanitarian Personnel, which the UK is helping to promote, and the ICRC’s Global IHL Initiative where the UK is co-chairing one of the seven workstreams (on National IHL Committees).
The UK’s role in promoting adherence to IHL
(Conclusion 4, paragraph 17) 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 against them. At a time of increasing global tensions and rising military spending, the world needs examples to follow.
(Recommendation 2, paragraph 18) 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 only their obligations under IHL, but the benefit of adherence to IHL for their own populations in a time of conflict.
Government Response: Agree
20. We agree that the UK’s Armed Forces have invaluable experience of applying IHL in extremely challenging environments, that military-to-military (mil-mil) training on IHL is an effective approach to promoting compliance and that the UK military has an important role to play.
21. The United Kingdom provides specialist training on the rule of law to foreign governments and armed forces, with a focus on 3 themes: IHL, the military justice system (which is crucial to maintaining discipline and integrity), and international agreements. With the support of the British Red Cross (BRC), the United Kingdom enhances knowledge and strengthens the application of IHL, and reinforces dialogue on IHL issues. This includes promotion of the establishment of weapons reviews, encouraging discussion and effective implementation of IHL within the Commonwealth, including hosting a Commonwealth Conference on IHL compliance, and attending and contributing to the International Conferences of the Red Cross and Red Crescent Movement.
22. Most International Defence Training courses, delivered in the UK and overseas, contain modules on IHL. The short course on ‘Managing Defence in a Wider Security Context’, which we provide to a large number of countries, has a number of IHL-related elements. The Ministry of Defence’s (MoDs) UK-based training including Initial Officer Training, courses at the Defence Academy and the programme for senior officers at the Royal College of Defence Studies (RCDS) contain IHL modules and are attended by international officers as a part of our engagement and cooperation programmes. The FCDO has also delivered sessions on humanitarian access and protection for UK and international senior military officers, diplomats, civil servants and industry officials participating on the RCDS Global Strategy Programme.
23. Permanent and short-term military training teams run by MoD, which are a fundamental Defence Engagement offering across the globe, include IHL training as well as subject matter specific training with a view to enhancing IHL compliance. The United Kingdom also provides technical training and policy support on the integration of Human Security into Defence. This entails training on the concepts and their application and integration into military operational planning. Furthermore, the United Kingdom sponsors participants from partner countries to attend the Human Security in Military Operational Planning course at MoD Shrivenham to broaden awareness and uptake of these concepts.
24. In addition, the UK MoD’s Joint Service Manual of the Law of Armed Conflict which sets out the UK’s interpretation of IHL remains available on the government’s website together with amendments. A MoD programme to update this publication is underway. It will draw upon Service, Government, and external academic legal experts to ensure that the new manual will be comprehensive and authoritative.
25. The FCDO and MoD, supported by the British Red Cross, worked together to develop and publish the Conflict, Hunger and International Humanitarian Law: A Practitioner’s Legal Handbook, launched on 6 May 2025, which sets out rules relevant to addressing conflict-induced hunger, including rules on humanitarian access. This provides clear information on the law and how to follow it, with suggestions for good practice. In October 2024, we also published the second edition of the UK’s Voluntary Report on the Implementation of International Humanitarian Law at Domestic Level (following the first edition published in 2019). The report sets out an updated picture of the UK’s domestic implementation of IHL and includes new topics such as the protection of civilians in armed conflict, mutual legal assistance, human security in military operations, media professionals in armed conflict, public curiosity, cyber warfare, outer space and autonomous weapons systems, in a single document for non-legal experts and the public.
26. Meanwhile, the UK Government continues to collaborate with the British Red Cross to provide practical assistance to selected States, which wish to produce their own voluntary reports on IHL implementation at the domestic level. The UK has published an updated toolkit (featuring a Guidance document and Templates – available on the Government’s website) to enable other States to research and draft their reports more easily.
27. The UK is also an active member of the ICRC’s Global Initiative on IHL aimed at galvanising political commitment to IHL. This Initiative aims to raise the profile and understanding of IHL globally, and in turn improve compliance and provide support for accountability efforts. The UK is co-chairing one of the seven workstreams of the Global Initiative, bearing testament to the work of the UK’s National Committee on IHL, established over 25 years ago.
Promoting unimpeded access to aid
(Conclusion 5, paragraph 23) 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 the UN Security Council limit the opportunities to overcome barriers to aid delivery. A radically new approach is needed.
(Recommendation 3, paragraph 24) 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 needs to be evaluated and invested in where needed.
Government Response: Agree
28. The UK remains an active and constructive voice in the United Nations and other multilateral forums to champion IHL, tackle barriers that restrict humanitarian access and protect civilians including humanitarian personnel.
29. The UN Security Council continues to agree action to respond to and prevent conflicts around the world, despite increased polarisation in the Council.
30. The FCDO is also committed to finding novel solutions and we agree with the committee’s call for a radical new approach to humanitarian diplomacy. The Foreign Secretary is clear that partnership must be at the core of our foreign policy; it is critical to overcome global challenges including humanitarian access. The FCDO is working with partners and allies to more systematically mobilise collective diplomatic action to maximise impact on humanitarian access and protection.
31. We recognise the importance of investment in efforts that continually enhance diplomatic capacities. The FCDO is finalising an internal humanitarian diplomacy training module focused on access and protection, in partnership with the British Red Cross, to bolster capability across FCDO.
(Conclusion 6, paragraph 26) 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 those delivering it. Moreover, the UK is well positioned to make good its commitments to localisation and to realise the benefits that this can bring.
Government Response
32. The UK agrees that participation of local organisations is vital to ensure humanitarian access negotiations result in effective, safe and sustainable aid delivery, particularly because local actors face greater levels of risk in conflict settings. We are committed to leveraging UK networks and influence to both consult with and include local actors in diplomatic efforts to enhance humanitarian access.
33. The UK funds the Centre for Competence on Humanitarian Negotiations (CCHN) to support humanitarian diplomacy for access. The CCHN provides frontline humanitarian staff with learning and training opportunities to develop their negotiation skills and share their practices with a global community to negotiate better assistance and protection for people in crisis situations. This global community includes more than 8,000 members across the globe and helps to amplify the voices of local and international negotiators on the frontline.
(Conclusion 7, paragraph 28) 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 chilling effect on those delivering UK aid and risks limiting its delivery where the implementation of sanction exemptions is not clear.
Government Response
34. The UK seeks to mitigate any unintended negative impacts of sanctions and counter terrorism legislation, including on humanitarian aid delivery. We work with our aid partners to understand the impact of sanctions. For example, the UK Tri-Sector Group brings together representatives from UK government, financial institutions and non-governmental organisations (NGOs), and enables dialogue to promote compliance while ensuring that terrorism and sanctions legislation does not unnecessarily impede legitimate humanitarian activities overseas.
(Recommendation 4, paragraph 29) 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 clearer guidance for the humanitarian sector on the interpretation of sanctions legislation. At the international level, the Government should facilitate consistent good practice with regard to creating humanitarian exemptions to sanctions regimes.
Government Response: Agree
35. We are committed to introducing a tailored humanitarian exemption or ‘carve-out’ across the UK’s autonomous sanctions when parliamentary time allows. This follows on from UN Security Council Resolution 2664—a landmark step that introduced a cross-cutting exemption to UN sanctions regimes—to support aid delivery.
36. UK sanctions include a range of humanitarian provisions including licensing grounds and exceptions. The Office of Financial Sanctions Implementation has a comprehensive suite of guidance products to support effective implementation of financial sanctions, OFSI’s general guidance can be found online2 and guidance for charities and NGO’s can also be found online.3 We will continue to work with other parts of government to produce clear guidance for humanitarian actors and those implementing financial sanctions. For example, we worked with the Crown Prosecution Service to provide straightforward legal guidance for humanitarian, development and peacebuilding organisations responsible for delivering aid in high-risk contexts.
The UK’s role in monitoring adherence and promoting accountability
(Conclusion 8, paragraph 32) 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 for holding states and non-state actors to account for alleged breaches of IHL—breaches which include the killings of aid workers and unlawful blockades of humanitarian aid and assistance. The UK has an important role to play in supporting, funding and participating in these mechanisms.
Government response
37. We are clear, robust and consistent, including through our work in New York and Geneva and our work at multilateral institutions, in our support for IHL and the need to uphold IHL in Gaza.
38. The Government has been repeatedly clear that all parties, including Hamas and other non-state actors, must comply with their obligations under IHL in Gaza, and civilians must be protected.
39. We consistently urge the Israeli authorities to conduct swift and thorough internal investigations into incidents, including those involving aid workers and medical personnel and that these investigations result in meaningful accountability.
40. Through the measures we have taken including with our export licensing programme and our international actions, we are also satisfied that we are meeting our own obligations under international law.
The International Criminal Court
(Conclusion 9, paragraph 35) At the international level, the International Criminal Court provides a forum for holding states and individuals, respectively, accountable for breaches of IHL.
(Recommendation 5, paragraph 36) 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.
Government Response: Agree
41. The UK is fully committed to international law and respects the independence of the International Court of Justice (ICJ) and the International Criminal Court (ICC).
42. The ICC is the primary international institution for investigating and prosecuting individuals charged with the most serious crimes of international concern, holding those responsible to account and achieving justice for victims. The UK stands firm in its full support of the Court, which must be permitted to exercise its jurisdiction in line with the Rome Statute, investigate allegations of the international crimes that fall within its remit, and follow legal process.
43. Through its presence in key multilateral fora, the UK reinforces our support for the ICC. At negotiations for the UN General Assembly Resolution on the Safety and Security of Humanitarian Personnel in 2024, the UK reaffirmed the importance of the ICC for the international legal order, and called upon all States which have not yet done so to consider becoming parties to the Rome Statute.
Diplomatic attention
(Conclusion 10, paragraph 38) 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 for the protection of aid workers. However, the lack of consistency across conflict types and geographies, arguably depending on the participants is startling, greater care needs to be taken to ensure that the UK’s actions and rhetoric around suspected breaches of IHL cannot be construed as being anything other than even handed—protecting allies at the expense of unconditional support for IHL is unacceptable. Such actions would set a poor example to other states and risk undermining the universality of law designed to protect us all.
(Recommendation 6, paragraph 39) 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. This condemnation needs to extend to where an overly permissive interpretation of IHL has been taken and must happen in equal measure regardless of the offending party’s diplomatic relationship to the UK. Failure to do so undermines a system designed to keep all civilians safe and to impose limits on the horrors of war.
Government Response: Partially agree
44. The UK consistently calls on all parties to conflicts, including non-state armed groups, to comply with their obligations under IHL and observe robust standards. In so doing it does not differentiate between conflicts or between parties.
45. The Government cannot provide a running commentary on possible breaches of IHL in situations of conflict. Determining whether violations of IHL have occurred in the conduct of hostilities, for example, depends upon detailed knowledge of the facts of the specific military operation, including the precise nature of the target, the methods used to attack, the attacking party’s knowledge at the time and the anticipated military advantage in launching that attack. This is information to which the FCDO does not readily have access.
46. Harm to civilians and civilian infrastructure is a tragic aspect of armed conflict, but does not in itself mean that IHL has been violated or that war crimes have been committed, particularly in circumstances where parties to a conflict are embedded among the civilian population and in civilian infrastructure.
47. This does not stop the UK highlighting the risk of atrocities occurring and flagging concerns about respect for IHL including responding to particular allegations. We engage closely with partners, publicly and privately, to call out reported violations and to press for compliance with IHL.
(Conclusion 11, paragraph 40) 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 advisory opinion sets out various obligations in respect of third states, including the obligation to ensure Israel complies with IHL. It is unacceptable that the Government has failed to issue a formal response nearly a year after the ruling was given.
(Recommendation 7, paragraph 41) 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.
Government Response: Partially Agree
48. The UK is fully committed to international law and respects the independence of the ICJ. We continue to consider the Court’s non-binding Advisory Opinion on Israel’s occupation of the OPTs carefully, with the seriousness and rigour it deserves.
(Recommendation 8, paragraph 44) 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 IHL in the delivery of aid. This session should focus on hearing from aid workers themselves, and from local organisations in particular, culminating in a declaration. In addition, the UK should push for the issue of humanitarian access to be included regularly in the annual UN Protection of Civilians Report. Finally, there should be an expectation that the UN Humanitarian Coordinator includes details of obstructions to the safe delivery of aid, including attacks on aid workers, as part of his regular reporting to the Security Council. However, we emphasise that this reporting should not be at the expense of energy and time being devoted to the ending of conflicts.
Government Response: Agree
49. The UK works with members of the ministerial group to explore all opportunities and agrees to consider a meeting of the UN Security Council (UNSC) which highlights aid worker safety, compliance with IHL, and enables members of the Council to hear from aid workers themselves (noting that a meeting on this topic is due in May 2026 as mandated by UNSCR 2730). As Security Council President during the November 2024 session to discuss implementation of UNSCR 2730, the UK invited the Director of the Aid Worker Security Database to provide a statement at the Council. Representatives of the United Nations Department for Safety and Security, and the International NGO Safety Organisation (INSO) have also delivered statements at the Council. The UK will continue to work with members of the ministerial group, and others, to explore any/all additional opportunities to highlight this important issue.
50. The UK will scope the feasibility and value of new reporting mechanisms in partnership with the UN. However, as the Committee suggests, reporting must not detract from important efforts to end conflict and support those affected by it, and duplicative reporting mechanisms must be avoided. In the meantime, the UK will continue to support transparent reporting to the Council on these important topics through existing mechanisms.
51. The UN Secretary General’s Annual Protection of Civilians report provides a comprehensive global assessment of civilian harm in armed conflict and calls to action. The 2025 report included compliance with IHL, humanitarian access, and protection of humanitarian personnel, alongside other important themes. The UK strongly supports this important process, while recognising the dire picture it presents. In May 2025, at the annual debate on Protection of Civilians, the UK called for the UNSC to use the tools at its disposal to press all parties to conflict to comply with their international law obligations.
52. The UK also champions the implementation of UNSCR 2417 which addresses conflict-induced hunger and recognises the importance of safe and unimpeded access of humanitarian personnel to civilians in armed conflict. The UK helped to establish the Group of Friends for Action on Conflict and Hunger in 2021 and continues to be active in the group.
53. Humanitarian access barriers and incidents of harm to aid workers are also reported to the council through various other mechanisms. Aid worker security is reported by the UN Secretary General to the Council under UNSCR 2730 and the denial of humanitarian access to children is captured in UN-verified reporting to the Council through the UNSC Working Group on Children and Armed Conflict.
(Recommendation 9, paragraph 45) 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 undertake a consultation exercise with international and local delivery organisations, as well as UN bodies and legal experts.
Government Response: Partially Agree
54. We agree that reliable data is key to informing the UK and other states’ action to promote IHL compliance by others. However, the UK view is that ODA is better spent supporting existing mechanisms, than establishing new databases that are unlikely to succeed and/or may undermine existing mechanisms that are already trusted and used by a range of actors.
55. As already noted, assessing IHL compliance from the outside is extremely difficult and requires detailed information relating to the specific incidents in question that is unlikely to be readily available to a third party.
56. Relevant existing mechanisms include the Aid Worker Security Database which tracks incidents of harm to aid workers across the globe, and to which the FCDO provided urgent funding in 2025. The ICRC, another FCDO partner, hosts “IHL in action: Respect for the law on the battlefield” which is a database of real case-studies documenting compliance with IHL in modern warfare. The ICRC established the database with a view to encourage the reporting, collection and promotion of instances of respect for IHL.
Criminal prosecution
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 doing to support these legal systems. (Conclusion 12, paragraph 47)
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 of IHL. (Recommendation 10, paragraph 48)
Government Response: Partially Agree
57. The UK supports other governments building their own investigative and judicial capabilities so that they are able to hold perpetrators to account. For example, the UK has provided support to the Office of the Prosecutor General of Ukraine to ensure allegations of war crimes are fully and fairly investigated. The UK has committed over £11.5 million to Ukraine’s domestic accountability efforts since the full-scale invasion, and with the US and EU partners, we launched the Atrocity Crimes Advisory group as a co-ordinating mechanism to support Ukraine’s domestic efforts.
58. It is important to build on existing work, and not undermine the existing international systems, including the crucial work of the ICC, which is a Court of last resort, and complementary to national criminal systems. The UK has seconded expert investigators to the ICC to assist its work in different situations where it has active investigations. We will continue to look for opportunities to deploy UK expertise to the ICC, but do not propose to set up a separate roster of legal experts that might undermine existing efforts.
59. The UK works closely with members of the ministerial group for the protection of humanitarian personnel and we look forward to working in partnership to implement the Declaration for the Protection of Humanitarian Personnel, including commitments to pursue greater accountability and justice in response to incidents.
(Conclusion 13, paragraph 51) 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 jurisdiction over international crimes such as the killings of aid workers and the unlawful restrictions or prohibitions on humanitarian aid and assistance.
(Recommendation 11, paragraph 52) 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 their nationality, residency status, or location.
Government Response: Disagree
60. The Government supports accountability and upholds our international obligations including under the Geneva Conventions. UK courts have jurisdiction under the International Criminal Court Act (ICCA) 2001, where an offence is committed by a UK national, a UK resident or is subject to UK service jurisdiction. The UK exercises universal jurisdiction in a number of circumstances, including for torture, under the Criminal Justice Act, 1988, and for grave breaches of the Geneva Conventions under the Geneva Conventions Act, 1957.
61. Where there is no apparent link between the UK and the crime, in general we support the principle that international crimes are best investigated and prosecuted close to where they are perpetrated. This is because of the advantages in securing evidence and the witnesses necessary for a fair investigation and prosecution, as part of a credible judicial process.
62. The most serious international crimes not covered by our domestic legislation providing for universal jurisdiction are generally already subject to the jurisdiction of the ICC. The UK is a strong supporter of the ICC and its mission to end impunity. We do not believe that legislative change is required at this time.
Investigating potential breaches
(Conclusion 14, paragraph 55) 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
(Recommendation 12, paragraph 55) 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 recommending these services to others.
Government Response: Agree
63. The UK supports fact-finding and investigative mechanisms established by the UN and other international bodies, where appropriate. These bodies often differ in their mandates – whether they are established to monitor situations, collate evidence for future investigations, or themselves conduct non-judicial investigations.
64. The International Humanitarian Fact-Finding Commission (IHFFC) is a dedicated expert body established under Additional Protocol I to the Geneva Conventions, 1949. The IHFFC stands at the service of parties to an armed conflict to conduct enquiries into alleged violations of IHL, and to facilitate, through its good offices, the restoration of an attitude of respect for the Geneva Conventions and Protocol.
65. The UK has recognised the IHFFC’s competence since 1999 and is an active supporter of its mission, providing core funding as well as both diplomatic and operational support. The UK has shown leadership within the IHFFC’s Group of Friends, serving as its inaugural Chair, with the first meeting at the UK Permanent Mission to the UN in New York in 2019.
66. We acknowledge that there are challenges as to where and how the IHFFC may be called upon, for instance where a state has not ratified Additional Protocol 1 or recognised its role. However, we agree that the IHFFC is a crucial resource, and the UK will continue to advocate that others consider use of this body for independent, expert investigations as appropriate.
Sanctions
(Conclusion 15, paragraph 58) 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 of promoting compliance with IHL.
(Recommendation 13, paragraph 59) 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 must make sure that the Sanctions Team is sufficiently resourced and that the evidence threshold is set appropriately.
Government Response: Partially Agree
67. HMG is committed to continuing to invest in its sanctions policy and enforcement architecture. The FCDO’s Sanctions Directorate has more than doubled in size since early 2022, with over 140 permanent/loan staff. This number does not include those working across FCDO and its overseas network who cover sanctions as part of their wider roles.
68. We keep all evidence and potential designations under close review. We will consider targets, guided by the objectives of the relevant sanctions regime, the evidence and wider UK objectives. The UK government has a strong appetite to consider all sanctions options in response to the intolerable level of human suffering in conflicts across the globe. The Government has previously taken action and will continue to do so where the legal framework allows an appropriate response.
69. We also keep the scope of our sanctions regimes under review to ensure they adapt to changing threats and challenges, including amending legislation where necessary.
Arms transfer
(Conclusion 16, paragraph 61) 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.
(Recommendation 14, paragraph 62)
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 exports to Parliament, including details of any incidents where British manufactured arms were used in suspected breaches of IHL;
c. embed an assessment of impact on humanitarian assistance into the foreign policy interest’s criteria for export licences.
Government Response: Partially Agree
70. The UK’s robust Strategic Export Licensing Criteria state that the Government will not issue export licences if there is a clear risk that the items might be used to commit or facilitate serious violations of international humanitarian law. The Foreign Secretary is responsible for providing advice to the Business and Trade Secretary on this issue and IHL assessments inform that advice.
71. The Government already has a robust mechanism for temporarily suspending licences where a change in circumstances means an export may no longer be consistent with the Strategic Export Licensing Criteria, pending further investigation. This allows us to respond quickly and flexibly to changing or fluid international situations. In recent years we have suspended or revoked licences for Israel, Rwanda, Russia, Myanmar, Venezuela and Afghanistan, for example.
72. We disagree with the recommendation regarding independent audits of arms exports, since we believe there is already a strong system for oversight. The UK regularly publishes data on export licences, reports frequently to Parliament, and operates one of the most robust and transparent export controls regimes in the world. We review all credible information relating to potential breaches of the Strategic Export Licensing Criteria, including where we determine there is a clear risk that the items might be used to commit or facilitate a serious violation of IHL. In such cases we will attempt to ascertain the route through which UK equipment was supplied. UK legislation places record-keeping requirements on exporters and we would notify the relevant parliamentary committees as appropriate.
73. We agree with the importance of assessing the impact on humanitarian assistance in the export licensing process. Criteria 3 and 4 of the UK’s Strategic Export Licensing Criteria already require the government to take into account humanitarian purposes or impacts.
(Conclusion 17, paragraph 63) 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. It is time for this to be addressed.
(Recommendation 15, paragraph 64) 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 crimes such as those relating to the targeting of aid workers and facilities.
Government Response: Disagree
74. We disagree with the recommendation on the need for new legislation placing additional requirements on exporters. There is a legal requirement for an exporter to have a valid licence to export arms and the Government has a robust assessment process, which includes keeping extant licences under review and re-assessing exports against the Strategic Export Licensing Criteria when circumstances change. The Criteria state that a licence would not be granted or allowed to remain extant, where there was a clear risk that items might be used to commit or facilitate serious violations of international humanitarian law.
75. Our assessments are objective and consistent. We consider information from NGOs, media, our experts in the UK and our overseas networks. Some of this information is unavailable to exporters. Additionally, we respond quickly to changing international situations and are able to suspend, refuse or revoke licences as circumstances require.
Practical protection for aid workers at risk of IHL abuses
(Recommendation 16, paragraph 67) 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 Abbey, speeches coinciding with the UN Secretary General’s update on Resolution 2730 (2024), and when updating Parliament on the FCDO’s work.
Government Response: Agree
76. FCDO marks World Humanitarian Day on 19 August by paying tribute to the bravery of humanitarians and voicing support for international law. Senior UK representatives also attend memorial services to commemorate lives lost during humanitarian responses.
77. The Humanitarian Medal was introduced in July 2023 as a way of honouring those deployed by the UK to assist in the response to major humanitarian events/disasters. It can be awarded to those in public service and members of organisations that contribute on behalf of the Government, such as charities, which respond in the aftermath of a crisis. The medal is awarded to people and organisations that have responded to emergencies both in the UK or overseas. 31 Humanitarian medals have been awarded so far. It can be awarded posthumously, if an individual meets the eligibility criteria.
78. The UK will continue to deliver speeches at the UN Security Council in support of UNSCR 2730, which the UK co-sponsored, and we welcome the suggestion to update parliament on this important issue as feasible and appropriate.
(Conclusion 18, paragraph 69) 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 of vicarious trauma through the processing of media. The disregard of aid worker safety by combatant parties is contrary to the spirit and letter of international humanitarian law.
Government Response
79. Humanitarian personnel are experiencing increased risks to their safety and security. Responsibility for protection of aid workers by conflict parties is outlined in international humanitarian law. Personnel participating in humanitarian relief operations are usually civilians and thus entitled to the protection afforded by IHL to civilians. Parties to armed conflicts must respect and protect them and must not direct attacks or commit other forms of violence against them, or take them hostage.
80. The UK is committed to championing the importance of protecting aid workers through ongoing initiatives already mentioned, including the proposed Australia-led Declaration and actions associated with its implementation.
(Conclusion 19, paragraph 71) The safety of aid workers and aid delivery is further hampered by the spread of malicious disinformation online and in other forms of media.
(Recommendation 17, paragraph 72) 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 fulfil their roles.
Government Response: Agree
81. We agree that malicious disinformation poses a serious threat to perceptions of the neutrality of aid workers and relief operations, damaging community acceptance, restricting humanitarian access, and increasing risks for aid workers.
82. The World Service remains the world’s most trusted international news service. The BBC shapes the global information environment through its role as a provider of impartial accurate news. Through high quality and investigative journalism, it also exposes and debunks the misinformation, disinformation and harmful narratives that malign actors, hostile states and others produce internationally.
83. It is not the case that the Government’s efforts to counter disinformation are undertaken “primarily through its support of the BBC World Service” as para 70 in the Report suggests. The World Service is editorially and operationally independent of government. Therefore, the BBC World Service’s engagement on disinformation is not an HMG-directed tool. The FCDO cannot and does not direct the BBC World Service to focus on specific issues including attacks on aid workers and IHL.
84. The Government values the independence and the work of the World Service. In 2025–26, the Government awarded a grant funding uplift of £32.6m (31%) for the World Service. The uplift comprised (a) £27m non-ODA provided by HMT and (b) £5.6m from the FCDO ODA budget. This pushed final allocations for that year up to £54.5m non-ODA; £82.5m ODA, marking £137m in total. This is a significant increase in an exceptionally tight fiscal situation, clearly demonstrating the importance that the Government places on the role of the World Service.
85. The World Service is part-funded through ODA. Its funding is a mix of ODA and non-ODA, in line with OECD-DAC rules. The World Service makes a significant contribution to development goals around the world. The Sustainable Development Goals include Goal 16, the right to press freedom and information. The World Service provides accurate and trusted information to populations living under authoritarian regimes and in countries with low/no media freedom (74% of their audience).
86. The World Service also provides emergency lifeline services. The BBC began airing lifeline programmes in 1994, when a new Kinyarwanda-language service began in response to the Rwandan genocide. This service has been stood up in recent years in Myanmar, Syria, Gaza, Ukraine and Sudan, providing vital safety and security information, and information about humanitarian aid availability in conflict situations.
87. The UK uses its permanent seat at the UN Security Council to condemn disinformation, information manipulation, and incitement to violence against humanitarian personnel and their premises and assets.
88. UNSCR 2730, which the UK co-sponsored, encourages member states and the United Nations system to take appropriate action to address the increasing threat of disinformation campaigns and misinformation that undermine trust in United Nations and humanitarian organisations and put humanitarian personnel at risk.
89. We recognise the importance of supporting our humanitarian partners to understand the threat posed by malicious information and identify appropriate responses. In Sudan, the FCDO recently funded a programme that works with humanitarian actors to promote greater understanding of these trends and inform cohesive action. Outcomes from this work are currently informing policy and future funding decisions.
90. Separately, the FCDO has a long history of countering disinformation, with malign information operations having been used, including by Russia, for over 100 years. The FCDO has developed and increasingly deployed tools to counter information operations and disinformation with a growing focus on acting against Foreign Information Manipulation and Interference (FIMI) networks that threaten the UK’s national security and that of our partners, specifically Ukraine.
91. We have provided written evidence to FAC as part of their inquiry into disinformation diplomacy, where we set out our approach in more detail. The written evidence is due to be published shortly.
(Conclusion 20, paragraph 73) 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.
Government Response
92. We agree that humanitarian aid must be facilitated in an impartial, neutral and independent way without political or physical impediments. The protection of civilians, including humanitarian aid workers, must be central to UK diplomatic action and is crucial to ensure safe delivery of UK funded aid.
93. Partnership with humanitarian aid organisations, particularly including local actors, is integral to ensure diplomatic action is anchored in the realities faced by those operating on the frontlines, upholds their humanitarian principles and promotes their safety.
94. Close partnership between posts and headquarters including FCDO’s political and diplomatic representatives, humanitarian and conflict advisers and legal counsel, is another key aspect of the FCDO approach to using humanitarian diplomacy to enhance humanitarian outcomes. This ensures a coherent approach to wider UK government objectives.
95. Investment in capability is also key. The FCDO’s new internal humanitarian diplomacy training includes a focus on the opportunities posed by effective humanitarian diplomacy for humanitarian access and protection, lessons learnt, as well as risks and mitigation measures.
96. The FCDO’s Humanitarian Allocation Model uses the best available humanitarian data to inform funding allocations across our bilateral portfolio. The model principally prioritises higher severity contexts over lower severity contexts, helping to ensure that delivery of humanitarian ODA is principled and prioritises those most in need.
Responsibility and accountability when things go wrong
(Conclusion 21, paragraph 75) 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.
97. Though the FCDO does not have legal responsibility for security of aid workers delivering UK-funded programmes, we take this issue seriously and work hard to mitigate risk at multiple levels.
98. We fund partner organisations once we’ve conducted reviews of their ability to responsibly deliver the programme. This includes an assessment of how due diligence is cascaded further down the delivery chain.
99. Should the tragic situation arise where an aid worker delivering UK ODA were to suffer harm, the programme team or institutional lead would urgently discuss the matter with the partner to understand if any health and safety or security weaknesses led to the serious injury or fatality. If such concerns were present, the partner would be required to take steps to mitigate these risks. The original due diligence assessment would also be reviewed to understand if this was an area of risk that was identified through that assessment, and if any recommendations made in the assessment were carried forward into actions in order to mitigate the risk.
100. Dedicated programme managers maintain close communications with delivery partners and regular risk assessment is a mandatory requirement. Regular dialogue provides opportunities for risks to be escalated and considered. For example, the UK backed the UN’s decision to pause humanitarian operations in Saada, Yemen, in March 2025 in response to heightened risk. Recognising the challenges of maintaining robust contextual understanding, particularly in volatile environments, we also procure dedicated expertise where required.
101. A good example is our work to strengthen systems that help partners to manage risks systemically, for example, financial support to organisations such as the International NGO Safety Organisation (INSO) to provide critical security information and analysis for NGOs and UN agencies. Between 2024 and 2026, FCDO is providing £2 million of central level funding to INSO to provide critical security information and analysis for NGOs and UN agencies. Of its 1,240 NGO partners, 42% are local NGOs. INSO provide support in countries affected by humanitarian crises across the globe.
102. All of this is complemented by diplomatic efforts to enhance humanitarian access and adherence to IHL.
103. The UK also supports the Inter-Agency Standing Committee (IASC) which was established, with UK support, through General Assembly Resolution 46/182 to serve as the primary mechanism for inter-agency coordination relating to humanitarian assistance. We welcome the efforts by IASC members, and humanitarian donors, to develop the IASC Risk Sharing framework, and note the FCDO engaged in the process. We are working to incorporate the framework into our programming and approach.
(Recommendation 18, paragraph 76) 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.
Government Response: Partially Agree
104. The Charity Commission is a non-Ministerial Government department that is directly funded by the Treasury. The Charities Act 2006 requires the Charities Commission to be operationally independent of ministerial influence or control. FCDO and other departments are in regular contact with the Commission as it regulates registered charities in England and Wales and maintains the Central Register of Charities, including charities funded by FCDO.
105. Recognising that the Commission’s role extends only to charities registered in England and Wales (not the UK), the Commission would not have a role in relation to any non-charitable NGOs, or charitable NGOs established in Scotland or Northern Ireland, which are the responsibility of separate regulators in those jurisdictions.
106. The Charity Commission has a specific and limited role in relation to safeguarding (in respect of charities established in England and Wales) to ensure that trustees are complying with their legal duties in the administration of their charities. This includes ensuring that beneficiaries, employees, volunteers and others who come into contact with their charities are protected from harm.
107. FCDO continues to work with the Charity Commission including on responses to safeguarding matters. The Charity Commission attends the HMG Group on Safeguarding against Sexual Exploitation Abuse and Harassment chaired by FCDO and which meets quarterly in the context of the 2020 HMG Safeguarding Strategy.
The impact on mental health and wellbeing
(Conclusion 22, paragraph 79) 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 overlooked. It is important that the mental health of these individuals and teams is compassionately and intentionally engaged with by their employers, with adequate funds being made available to provide support.
(Recommendation 19, paragraph 80) 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 own recovery strategies for their volunteers and employees.
Government Response: Agree
108. FCDO takes seriously issues of health and safety, including mental health and safeguarding, for our partners. FCDO internal guidance on Mental Health and Psychosocial Support (MHPSS) advises that funding to meet mental health needs should be prioritised within humanitarian budget allocations. FCDO’s due diligence framework, which considers risks relevant to the programme in question, requires partners to demonstrate sufficient capacity and capability to meet several obligations, including those relating to physical and mental health, safety, security and safeguarding measures.
109. FCDO funding guidelines enable partners to budget for staff psychological support and wellbeing, including for local organisations. Where there is an identified gap in available service provision in a given context, FCDO may also fund additional mental health services on a case-by-case basis.
110. A good example is the FCDO-funded Humanitarian Action through Volunteers, Enablers, and Networks (HAVEN) consortium in Ukraine, which provides a resilience programme to local humanitarian workers and volunteers, allowing them to access online and offline psychological support. By prioritising their psychological health and wellbeing, the resilience of local humanitarian workers and volunteers is strengthened, allowing them to sustain their vital contributions to humanitarian efforts.
111. Where the UK is funding a local organisation through another partner (e.g., INGO, UN Agency), FCDO expects the lead organisation to ensure full cost recovery of downstream partners, including for MHPSS, security and safeguarding needs. The lead partner must also pass on our non-project attributable cost (NPAC) rate, or 10% (whichever is the highest) to the implementing partner. The NPAC can be used by local organisations flexibly, according to identified priorities.
112. The UK also seeks to leverage its influence to raise awareness about the critical need for MHPSS among other international donors, such as the World Bank and Global Health Institutions, governments, and humanitarian agencies.
(Recommendation 20, paragraph 81) 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.
Government Response: Partially Agree
113. Mental health and security support is designed specifically to meet the needs of staff and their families for whom HMG holds a legal duty of care obligation. An extension of these services to third parties would require additional resources to meet additional demand and, to properly tailor existing FCDO services to other profiles, languages and risk appetites, to which we’re unable to commit.
114. The FCDO’s mental health and wellbeing support to staff and dependants overseas is informed by advice from our Mental Health Expert Advisory Group, which convenes professional and academic experts from outside the FCDO, and by our Chief Medical Officer. The support offer includes a contracted Employee Assistance Programme, in-house welfare officers, the use of Trauma Risk Management after potentially traumatic events, guidance on exposure to potentially traumatic material, and more. The UK-based team overseeing this work and our Chief Medical Officer remain open to sharing the rationale for our strategic approach to maintaining staff welfare and wellbeing with interested partners.
115. The safety of our staff and their families is paramount to enable them to work effectively and to protect them from harm.
116. Particularly in fragile or conflict-affected environments, local relationships, including with the international development community, are an important contribution to a robust security posture. While we have neither the resources nor local mandate to provide in-country security advice to third parties, whose approach frequently differs from our own in respect of operating models, threat profiles and risk appetite, we are keen to see regular exchanges of information where these are mutually beneficial.
Funding security risk management
(Conclusion 23, paragraph 85) 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 can to remove or mitigate the risks to aid workers.
Government Response
117. We take our responsibilities as a humanitarian donor seriously and we recognise the importance of evolving our own risk management approaches to keep pace with evolving threats.
118. We plan to review existing programme guidelines and consider stand-alone guidance on the specific issue of mitigating risks to aid workers. This may include recommendations for down-stream implementing partners to attend regular meetings with primary partners and FCDO programme teams to ensure information is conveyed first-hand and to ensure that specific issues can be addressed in an effective and timely manner. We welcome continued dialogue with partners on this important issue and will ensure their views and advice contribute to this process. The FCDO seeks to follow the principled approach to risk-sharing outlined in the IASC 2023 Risk Sharing Framework.
119. The UK will also continue its efforts to support global Humanitarian Notification Systems (HNS), which are a critical tool to support deconfliction and help protect aid workers, when parties to conflict fully engage. The UK provides core funding to the United Nations Office for the Coordination of Humanitarian Affairs (UNOCHA) whose mandate includes the management of the HNS. At the UN Security Council in November 2024, the UK also called upon all member states to take all feasible steps to ensure effective and trusted deconfliction mechanisms are in place and utilised, in line with the obligations of parties to a conflict to protect humanitarian personnel. We reiterated this call at the Council in April 2025.
(Conclusion 24, paragraph 86) 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 economy. Proposals with higher security costs should not be prejudiced against. Rather, proposals with lower costs should prompt more questions.
(Recommendation 21, paragraph 87) 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 grants should be flexible to allow for the appropriate measures to be funded in any given situation. The application process should be accessible to local organisations delivering UK ODA, and they should be encouraged to apply directly with support being provided through UK Embassies wherever possible. International NGOs and consultants applying for work with local organisations must be able to demonstrate both the relevance of their grant to their local partners and the value for money of their being an intermediary.
Government Response: Partially Agree
120. The FCDO is committed to the safety and security of aid workers. We make clear to all our partners that we expect them to make adequate budgetary provision to support aid worker safety and security.
121. High and low costs, including costs for security, will be assessed by the FCDO using a value for money (VfM) lens. Central to FCDO’s approach to VfM is not cost minimisation, but a focus and emphasis on maximising the impact of our investments per £ of ODA spent. This comprehensive framework ensures that UK-funded costs are assessed by the degree to which they support and achieve programme outputs, outcomes and impact.
122. To aid this approach, the FCDO’s bilateral humanitarian portfolio is informed by the Humanitarian Allocation Model which, in addition to accounting for the scale and severity of humanitarian crises, accounts for access and local security considerations which may affect and constrain the delivery of humanitarian aid.
123. As we consider budget allocations, humanitarian access and aid worker safety remain priorities. However, drawing upon lessons learned from FCDO experience with other standalone funds, our view is that the establishment of a new fund would require large scale programme management and administrative support which would reduce funding available to support aid worker safety.
(Recommendation 22, paragraph 88) 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.
Government Response: Agree
124. We agree. We will explore the possibility of including a dedicated budget line for programme-specific security risk management costs into FCDO’s standard templates for ODA-funded humanitarian programmes, as well as issuing guidance to staff reviewing humanitarian budgets to ensure security funding requirements are appropriately addressed.
Challenges faced by local NGOs
(Conclusion 25, paragraph 93) 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 FCDO. There is evidence of inflexibility in eligible items for funding.
(Recommendation 23, paragraph 94) 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 conversations should seek to establish whether the organisation’s security concerns have been adequately covered. Subsequent conversations during implementation and evaluation phases are also strongly recommended.
Government Response: Agree
125. We agree that FCDO officials managing agreements 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, and at regular intervals throughout implementation as feasible and appropriate, to ensure security concerns are adequately covered. Existing risk reporting requirements seek to promote these touch points, but FCDO plans to issue internal guidance that emphasises the importance of direct contact with all partners to discuss security risks as well as other risks, where this is feasible and would not put local partners at additional risk.
Insurance
(Recommendation 24, paragraph 96) 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 packages of insurance are provided—including for local staff and volunteers, where possible.
Government Response: Partially Agree
126. We agree that insurance provided to aid workers through FCDO partners should meet a range of identified needs, including legal, mental and physical health provision where applicable. FCDO’s funding guidelines are flexible, allowing for partners to budget institutional insurance policies within humanitarian projects, as well as additional country-specific insurance policies which might be exceptionally required for a programme on a case-by-case basis.
127. While the FCDO supports our humanitarian partners’ access to insurance, the choice of which insurance company is contracted lies solely with our partners. FCDO’s due diligence framework requires partners conduct transparent and fair procurement processes for services, and demonstrate that there are sufficient safeguarding, health and wellbeing (including mental wellbeing) measures in place for their staff. This includes considerations of whether insurance policies meet the needs of aid workers. FCDO due diligence assessments are context-specific and consider whether the measures taken by the UK’s partners are most appropriate to the context.
128. The FCDO’s HAVEN programme in Ukraine provides accident and life insurance coverage for local humanitarian workers and volunteers operating in frontline areas. By offering this essential safety net, local humanitarians can focus on their live-saving work with greater security. Learning from this programme will be collated and used to inform future programming.
Pooling of services and cost savings
(Conclusion 26, paragraph 98) 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 sector. However, the FCDO’s current approach to contracts does not go as far as it could to encourage the pooling of services that would allow more cost-effective security risk management.
(Recommendation 25, paragraph 99) 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 access to security advisors, mental health first aid training, and so forth.
Government Response: Partially Agree
129. We agree that collaborative approaches to risk management and shared security services can enhance cost efficiency and effectiveness. In our view, support for important common services and collaborative approaches does not require the establishment of a new security risk management fund.
130. We fund the International NGO Safety Organisation (INSO) as a pooled resource in multiple countries to provide risk analysis and training for international and local partners. We are also exploring funding support for the Global Interagency Security Forum (GISF) who play a key role in enabling shared security services for INGOs.
131. The FCDO also has a long history of supporting consortia, whereby partners work in partnership to combine reach, expertise, and share resources to enhance impact. As mentioned previously, the HAVEN consortium in Ukraine is a good example of a partnership that enhances safety and security outcomes. Other UK-funded consortia have relayed that partners shared security assessments, and security analysis, to enhance safe humanitarian access. Consortium models can also enable funding to be quickly moved between partners, if required, to respond to unanticipated needs or contextual shifts.
Footnotes
1 https://assets.publishing.service.gov.uk/media/65cb77caa7ded0000c79e526/Government_response_to_the_House_of_Lords_AI_in_Weapon_Systems_Committee_Report.pdf
2 https://www.gov.uk/government/publications/financial-sanctions-general-guidance/uk-financial-sanctions-general-guidance
3 https://www.gov.uk/government/publications/financial-sanctions-guidance-for-charities/financial-sanctions-guidance-for-charities-and-non-governmental-organisations-ngos