The question of accountability has been a long-standing issue within the humanitarian sector. It refers to the obligation of humanitarian organizations to be transparent, responsive and accountable to the people they serve and to those who authorize and provide assistance. It acts as an adjunct to the humanitarian principles by increasing trust and facilitating the constructive engagement of communities and parties to conflict. The rising scale and complexity and the contractual nature of humanitarian financing has increased demands for accountability to meet the requirements of donors and governments. These normally take the form of evaluations that assess the impact, effectiveness and efficiency of humanitarian action but rarely look at its appropriateness from the perspective of the people affected by crises.
Humanitarian accountability requires coordination and collaboration among various stakeholders, including donors, governments, local actors and affected communities. The Inter-Agency Standing Committee (IASC) is a mechanism to promote humanitarian coordination within the UN system, Red Cross and Red Crescent Movement and NGO bodies. In recent years, the IASC has produced several initiatives, including notably the ‘Accountability to Affected People’ process intended to address the accountability gap. Nevertheless, the consensus among participants at the workshops for this paper and in recent literature is that little real progress has been made.
There are two major shortcomings of the IASC’s role. The IASC does not foster coordination and there is no common reporting and accountability framework to hold the IASC and its constituent parts accountable in a joined-up way. Instead, each organization reports separately to its own governing body.
There is also little appetite for system reform despite an emerging consensus that the commitments to humanitarian accountability made in the Grand Bargain are not being met.
Coordination
Coordination can take place either in a consensus or military-style command-and-control model. To a large extent, coordination is determined by the underlying business or financing model in use. The IASC, chaired by the ERC, is a consensus-seeking body that utilizes an ‘all in’ model that engages all sectors in each crisis through an incentivized project-based financing system, which ‘tends to reward compliance with standard procedures and financial targets, rather than choosing the best course of action to optimise humanitarian outcomes’. The IASC brings together organizations that do not report to the ERC but to their own boards. The structure of the IASC is mirrored in countries in conflict by the HCT, chaired by a humanitarian coordinator (HC), whose authority lies in managing by consensus.
While current approaches to coordination and leadership are more acceptable in situations where a national government is managing the response to floods, drought or similar events, in countries where armed conflict is raging and government structures may have collapsed, current coordination structures can lead to a ‘free for all’ environment, in which each organization does what it thinks best with the funds it has raised.
This ‘all in’ approach extends to the preparation of the annual HRP for each country based on the various identification, prioritization and costing of needs by each sectoral cluster – these ‘clusters’ bring together organizations involved in a specific sector of humanitarian action, such as health, food security or shelter. At the global level, clusters have become the means for major UN agencies to control and manage a sector. While international NGOs increasingly become cluster co-leads, no national NGOs have yet become co-leads at the global level, and their membership of clusters at country level remains limited. Membership of the cluster is also a requirement for financing from the Central Emergency Response Fund (CERF) and more importantly the country established ‘pooled-fund mechanisms’, which are often the only way for national NGOs to access independent funding. The increasing technocratic and formulaic nature of HRPs has resulted in a loss of sensitivity and an inability to reflect how local communities perceive their needs. The HRP is also not subject to any conflict-sensitivity assessment, which might identify proposals that could have a negative impact on the local economy or aggravate existing political divides in the country. As summarized by Mark Lowcock, a former ERC, ‘the humanitarian system is set up to give people in need what international agencies and donors think is best, and what we have to offer, rather than giving people what they themselves say they most need’.
The first Sanguine Mirage research paper suggested practical ways to improve the humanitarian response. However, improving coordination at the IASC level would require a radical rethink of the relationship between the IASC and the main UN humanitarian agencies, and there is currently no political appetite for such reform. Therefore, it is essential to examine the existing systems of accountability. Drawing on the arguments presented so far, the authors believe that urgent attention must be given to this issue and that agencies propose practical ideas for achieving it.
Accountability in UN operations in conflict environments
Although the secretary-general submits an annual report on overall UN humanitarian operations to ECOSOC, there is no comparable accountability process for individual humanitarian operations.
Representatives of UN humanitarian agencies, notably UNHCR, UNICEF, the World Food Programme (WFP) and WHO, may argue that they report to their respective boards, which are made up of member state representatives. However, these are not joined-up coordinated processes and they do not include any assessment of an agency’s role in an operation from the ERC, the UN official tasked with coordinating these efforts. While these agencies maintain regular informal contact with their board members, any formal review usually takes place after the launch of an operation, on the authority of the executive head of the agency.
Under the financing model of voluntary contributions, decisions about which emergencies receive funding and which activities are supported rest largely with the small number of individual donors who provide the bulk of funds. These donor governments are separately accountable to their parliaments, but donor coordination mechanisms have proved inadequate to support coherence in funding priorities and joint accountability. Inevitably, the ability of humanitarian organizations to meet essential needs, and to do so while operating in accordance with the principles, is influenced by the decisions taken by these states.
In 2006, in recognition of this and other related problems, OCHA, with support from the UK government, proposed the establishment of the CERF, initially with a target amount of $450 million annually in voluntary contributions, putting funds directly under the control of the ERC. Subsequently, several other pooled-fund mechanisms were established for support of operations in specific countries. Globally these mechanisms amounted to $1.9 billion out of the $31.7 billion that was spent on humanitarian assistance in 2021.
While there is an increased focus on accountability to donors and a need for a stronger overarching accountability framework, there is also a requirement for more accountability to peoples, communities and governments in conflict contexts and other crises. The key elements of an approach to achieve this were defined in the Grand Bargain as workstream 1 (greater transparency) and workstream 6 (participation revolution – i.e. including recipients of assistance in the decision-making process). A recent review of performance against the aims of the Grand Bargain highlighted little progress in these areas. Specifically, workstream 6 has been hampered by a lack of collective political interest from signatories and has failed to deliver on the original ambitions of a ‘revolution’. Instead, the available data, including from four years of perception surveys, suggest that aid continues to be based on what agencies and donors want to give, rather than what people say they want and need. In the absence of any genuine incentives for change, and in the context of increasing risk intolerance among donors, progress under this workstream is likely to remain incremental at best. Humanitarian evaluations that continue to be one of the main accountability tools fail to consult locally on perceptions and judge performance on the terms of the system rather than those being assisted.
There is a requirement for more accountability to peoples, communities and governments in conflict contexts and other crises.
In the workshop discussions, representatives of humanitarian organizations urged the project to be ‘realistic’ in its recommendations, and not to propose additional bureaucratic layers of oversight that add unnecessary administrative burdens. At the same time, representatives of donor states encouraged the project to be ‘bold’ and address the fundamental flaws in the current system. So far, the humanitarian system has shown itself impervious to demands for improved accountability and has consistently rejected proposals that might give voice to those affected by crises.
In 2009, OCHA proposed the establishment of a ‘Humanitarian Ombudsman’ as part of its humanitarian reform initiative. The aim was to provide an independent, impartial and confidential mechanism for addressing complaints and grievances from affected communities and other stakeholders. In 2021, OCHA proposed a pilot project, the Independent Commission for Voices in Crises (ICVIC), that would, ‘pilot approaches to elevating the priorities and needs identified by affected people to senior decision makers; and to independently evaluate how well the international humanitarian response delivers against those needs’. This initiative also floundered, in part due to the lack of support within the humanitarian system that felt that these issues were already addressed.
Consequently, in seeking to address the flaws with minimal additional bureaucracy and to promote a joined-up approach to accountability, this paper recommends a programme of auditing that would offer significant confidence to member states, including the major contributors of funding for humanitarian operations, the members of the executive boards of UN humanitarian agencies and, indirectly, the boards and managers of the NGOs that partner with these UN bodies.
The proposed model is to create an independent panel with a remit to assess the impact of humanitarian assistance through a system of country portfolio reviews. This approach can evaluate the impact and performance of all humanitarian assistance in a country and the extent to which it has been conducted in accordance with humanitarian principles. It would include a strong focus on understanding people’s voices and engagement. The proposal would also task the panel to commission audits of HRPs, as a way of increasing the transparency of humanitarian assistance, with the support of national government audit bodies to provide greater oversight of global appeal processes. This proposal differs from ICVIC and previous proposals by recognizing the need for an overarching framework that reports to ECOSOC, rather than to the ERC. The intention is to provide a mechanism that would broaden the engagement of member states through its regular reporting.
Auditing the IASC
Possible elements of an audit of IASC’s oversight of efforts to operate in accordance with humanitarian principles and coordination of the humanitarian response in situations of armed conflict might include:
- HRP process, including estimates of needs and requirements;
- Conflict-sensitivity assessments and the role of humanitarian principles;
- Coordination arrangements, both within the humanitarian system and between humanitarian, peacekeeping, peacebuilding and development systems;
- Use and effectiveness of ethical decision-making processes;
- Contracting and sub-contracting and procurement processes; and
- Monitoring and evaluation of outcomes.
Such an audit process should be considered as a basic requirement for programmes absorbing huge resources within the UN system. The process could be requested by the GA, on the recommendation of ECOSOC, and financed from the budgets of donor governments already allocated for monitoring and evaluation activities.