Submission to IDC inquiry on FCDO and civil societies

Christian Aid, April 2024

 

For further information contact Sophie Powell spowell@christian-aid.org
 

Christian Aid is the official relief, development and advocacy agency of 41 sponsoring churches in Britain and Ireland. We work in all our country and regional programmes through local partner organisations. Through their experience and expertise our partners are able to access some of the most vulnerable communities and ensure that their voices and needs inform our programmes.  

 

Summary

 

Recommendations for FCDO

 

-          Reinvest in civil society strengthening programmes, making use of the learning from its back catalogue and the good practice examples we have set out in this submission. Critical is the provision of flexible, multi-year core funding to local organisations; then stepping back, recognising that it is local citizens, not donors themselves, that should be leading and determining priorities in a country and to whom the governments of aid-recipient countries should be accountable and responsive.
 

-          Assess how to support civil society networks that link local-to-national contexts and priorities to regional and global processes, to help ensure ambitious, equitable and inclusive outcomes, for example on climate and economic policy issues.

 

-          Translate its ambitions to direct more resources to local actors into concrete actions, including:

 

-          Recognise the relationship between private sector investments, and the objective of supporting civil society strengthening is not automatically a positive or benign one, unless measures are put in place to make it so. Specifically, FCDO should

 

 

Questions 1 and 4

 

The strengths

 

Recognising the critical role of civil society

 

  1. The recognition by FCDO, expressed through the White Paper, of the importance of supporting civil society and promoting effective state-civil society engagement is welcome. Based on our decades of working in partnership with local organisations in the global South and our extensive programmatic experience in governance and civil society strengthening[2], backed up by a much wider body of evidence[3], Christian Aid shares the view expressed in the White Paper that a strong and empowered civil society is a vital foundation for democratic accountability and for building more inclusive, equitable and sustainable societies.
     
  2. Civil society supports democratic governance via increasing representation of different groups, enabling them to exercise their rights, pressing for more democratic structures and reinforcing their legitimacy. A strong and empowered civil society operating in open and free civic space supports poverty reduction, when citizens are able to advocate for essential services and social protections (that governments have a duty to provide); and when they are empowered to defend and claim their rights, and to influence budgets and policies (including economic policies[4]) to be transparent, equitable and leave no-one behind[5]. Many CSOs also provide vital services such as health and education, directly to people, particularly filling gaps in state provision or substituting for ineffective or unwilling state institutions. An empowered civil society is the linchpin of the locally-led approach to development, which the White Paper rightly commits to supporting.

 

  1. Conversely, as concluded by the Institute of Development Studies (IDS) and ACT Alliance, without a fully engaged civil society, the SDGs are bound to fail[6]. Restrictions on civic space prevent CSOs from engaging in policy formulation, monitoring rights, raising awareness, championing the voices of vulnerable populations, and from building partnerships; they may also increase a permissive culture of corruption among elite groups.  Shrinking civic space is likely to halt or reverse progress towards reducing inequality, insuring inclusion, and improving sustainability, which only makes the right kind of active support to strengthening civil society all the more critical. Christian Aid has documented that while Covid-19 was used by many governments as a pretext to further limit civic space, civil society was a source of resilience and new forms of activism, and an important check on state power and market-based inequalities[7]. 

 

A strong programme history to build on

 

  1. FCDO has a strong back catalogue of research, evidence and learning, to inform further good civil society strengthening programming. UK DFID’s Civil Society Fund (CSF) provided long term strategic support to the establishment of multiple civil society networks and platforms e.g. STAR Ghana which was set up with UK Aid funding and continuing support. Long-term development programmes like the Engaged Citizens element of PERL Nigeria have been a success (that is now being built on in current programming). FCDO has a wealth of learning on the development of nuanced programming that has provided solutions to local service delivery contexts e.g. SABI Sierra Leone and later still the UK Aid Connect programme innovation and pilot programmes.

 

  1. ICAI[8] has recognised the positive contribution of UK aid programmes to tackling threats to democracy and human rights; supporting at-risk groups, such as women and people with disabilities, to advocate for their rights, combat discrimination, participate in politics and access basic services; and supporting the establishment of more effective civil society organisations.  FCDO has the opportunity to build on existing learning about what good looks like, and to integrate these principles into future work, in ways that realise the welcome aspirations in the White Paper.

 

  1. What good looks like

 

(i)      Approaches that build the power of communities and civil society over the long-term. This should involve support to strengthening a diverse range of local and national organisations (including faith based organisations, women’s rights organisations [WROs] and marginalised groups) to support communities to claim their rights and to advocate for fair and equitable policies based on local priorities, including through long-term flexible funding and needs based capacity support. The White Paper commitment to “build on previous and existing programmes, such as UK Aid Direct and UK Aid Match; tailored, long-term financing and capacity-strengthening support to a diverse range of CSOs”, and commitments to support WROs, are welcome and relevant.

(ii)    Civic participation programmes that help promote accountability. For example, the programme ‘Strengthening community-led accountability to improve service delivery in Sierra Leone’ (SABI)[9] worked in every district to strengthen community-led accountability, increasing awareness of, and demand for, the delivery of basic services – including health, education and social protection. This helped to create a climate of expectation of proper use of public funds.

(iii)  Supporting organisations to engage in economic decision making. For example, a DFID funded programme designed to ensure public resources were spent in the interests of all the citizens of Sierra Leone, through improving civic participation in public financial management and revenue generation, contributed to a National Tax waiver Policy and established Citizens Perceptions Surveys as direct routes for civic influence on tax policy and anti-corruption measures[10].

(iv)  Supporting national and regional civil society networks. Christian Aid partner Tax Justice Network-Africa[11] advocates for more equitable and transparent tax systems at the national level, for stronger regional cooperation and for global measures to curb tax dodging and illicit financial flows. 

(v)    Human rights and access to justice programmes. Good programming in this areas supports civil society to help defend civic space, promote access to justice and influence progressive law reforms where needed. This should include support for human rights defenders and wider civil society where human rights are under threat[12].

(vi)  Support for civil society programmes focused on people marginalized by their social class, gender, race, or sexual orientation. For example, in India, Christian Aid supported Dalit groups to understand their legal and cultural rights and to campaign for legal change to formally recognise Dalit land rights[13].  In Afghanistan Christian Aid helps communities understand the available justice systems and promotes key concepts of human rights, including Islamic concepts of protecting the rights of the powerless. Supporting marginalised groups to be better represented in local government structures is also critical.

(vii) Supporting elected women’s leadership. This has often been a feature of UK funding , for example in Sierra Leone, a partner-led programme supported by DFID helped to increase the number of women councillors in Kailahun District from 21% to 41%; in Nigeria, following the Voice to the People programme, village councils now include women and even have special places in the cabinet for women leaders.

(viii)                       Recognising the role of faith actors. Faith actors are well placed to facilitate locally-led humanitarian response and longer-term development because they are deeply embedded in local communities. For example, when Covid hit Christian Aid worked with faith actors and found that as trusted community members with vital social access and spiritual capital, they exercised considerable positive influence in many communities.  In South Sudan, faith leaders have played a critical role in reconciling communities at local and national levels, playing an influential role in the peace process by building support for the 2018 peace agreement and fostering national unity.

 

The challenges

 

  1. While the commitments in the International Development White Paper are welcome, realising them will require a significant rebuilding, including funding, as the focus on civil society strengthening, rights and empowerment has been lost in recent years and the funding pipeline for this work severely diminished.

 

Cuts to funding overall, combined with a diminished ODA pot being directed elsewhere

 

  1. Even in a context of reduced funding, there has been a notable shift away from funding programmes with a primary aim of strengthening civil society towards an approach in which civil society strengthening has become a secondary aim to delivering specific project outcomes[14]. Yet, our learning from previous UK aid programmes delivered by Christian Aid such as SABI[15] shows that it is possible to achieve remarkable results with relatively small amounts of financial investment with strong partnerships, effective collaboration with local FCDO team and implementing agency and innovation.
     
  2. A reinjection of funding is also needed. However, as is well documented, the aid cuts and significant diversion of the remaining ODA pot to Home Office spending on refugee hosting, have significantly reduced the quantity of ODA spent in lower income countries[16], including for programmes focused on strengthening civil society.

 

  1. In addition to refugee costs, there are other less discussed factors driving a redistribution of what remains of the ODA pot to be spent overseas, away from civil society strengthening (as well as away from other critical areas such as health and education).  Notably: (i) the drawing of the UK’s contribution to international climate finance from the ODA budget, which, regardless of the co-benefits of tackling poverty and climate change, constitutes double-counting between aid and international climate finance and means trade-offs when it comes to investing ODA in other critical priorities[17]; (ii) the continued protection of spending to British International Investment, as FCDO have typically ringfencing 3-4% of the aid budget for BII since 2015[18].  FCDO’s latest report and accounts show in 2024/25 it also plans a significant uptick in investment to British Investment Partnerships (£891m) and this will certainly rise given the White Paper’s emphasis on mobilising private capital. 

 

Insufficient consideration of the consequences of the private sector tilt for civil society strengthening objectives

 

  1. Asides from increased ODA funding for private sector initiatives meaning trade-offs with spending on civil society, if not appropriate regulated, the ways in which private sector investments occur may also undermine the very accountable governance objectives that civil society strengthening is intended to achieve.

 

  1. Christian Aid recognises the vital role of the private sector in driving growth, creating jobs and delivering goods and services that people need, which are in turn important elements of addressing poverty, when measures of sustainability, inclusivity and respect for human rights are integrated. Many UK businesses make a positive contribution to poverty reduction, through the creation of jobs and livelihoods in low-income countries and the BII and other blended finance initiatives could play a positive role in mobilising resources for development, if done right. 
     
  2. The existing or potential benefits of blended finance initiatives do not themselves, however, notably extend to strengthening civil society or accountable governance, or to the White Paper commitment to “ensure our development offer responds to locally owned priorities”. In addition to well documented questions about poverty focus and impact and concerns about human rights impacts[19] investments that are leveraged via BII or other blended finance initiatives, do not have a good record of transparency, or accountability to either civil society or to host governments.  Research into Development Finance Institutes (DFIs) in general found an inconsistency in alignment with government plans, and a common failure to incorporate transparency, accountability and stakeholder participation in ways that would make these investments accountable to communities[20]. BII has not demonstrated that it is an outlier in relation to these trends.  

 

  1. Whether investments come via BII blended finance initiatives or simply as pure private finance, accountability of UK investors operating in lower-income countries to human rights and environmental standards should be a concern of FCDO. The White Paper characterisation of the UK’s approach, as “defending and promoting human rights, the rule of law and accountable institutions” must include taking responsibility ensuring UK actors with a footprint in lower income countries do not themselves flout human rights or environmental standards. Christian Aid recommends that the next government to puts in place a new UK legal requirement for companies and investors to carry out human rights and environmental due diligence in their global supply chains – i.e. a Business, Human Rights and Environment Act.

 

Inadequate progress in shifting power/resources to local actors

 

  1. The recent White Paper offers welcome commitments to further localization, putting crisis-affected communities in the driving seat, as well as empowering local actors. We strongly welcome the signaling of an approach that would do more to support locally-led humanitarian preparedness, resilience and adaptation, including the scoping of a new fund for this, as well as the commitment to follow the lead of the US and ECHO to publish a cross-FCDO “strategy setting out how the UK will support local leadership on development, climate, nature and humanitarian action”. We hope to see measurable and trackable plans come through, in the process of advancing these commitments.

 

  1. In recognition of the vital role of local civil society actors in the humanitarian context, FCDO alongside most other donors signed up to the Grand Bargain, negotiated in 2016 as part of the World Humanitarian Summit, which included commitments to shift power and resources to local civil society.  Subsequently, the new Grand Bargain 2.0 Framework includes a commitment to greater support for leadership, delivery capacity of local responders and participation of affected communities in addressing humanitarian needs.  Along with many others donors, FCDO’s progress has been slow and patchy, falling well behind in their commitments to channel at least 25% of funding to local actors (either directly or via a single intermediary). 

 

  1. Under DFID the UK made some modest positive contributions to channelling resources to local organisations, via pooled funds such as the START Fund; and since then have experimented with a range of small initiatives. However, there has been an absence of clear plans or measurable targets and, in a context of poor levels of data transparency, it has been very hard to understand the scale and ambition or to track progress. The weight of compliance and due diligence requirements attached to FCDO funding calls, combined with a narrow approach to measuring risk, also work against the realisation getting resources to local civil society actors.

 

  1. Meanwhile, FCDO continues to channel the majority of its humanitarian budget to large UN agencies (which control 75% of humanitarian funding overall), which do not appear to have a good record in distributing these funds into the hands of grassroots organisations or communities themselves. FCDO does not appear to impose any strict reporting requirements upon that would incentivize this or enable it to be monitored.  A better balance  in FCDO funding between the UN and NGOs would increase speed and cost-effectiveness, incentivise progressive, locally-led, people-centred responses, mitigate risks and increase impact.

 

  1. To realise the White Paper commitments FCDO could

(i)                  learn from USAID[21], ECHO[22] and DANIDA which have launched leading policies or approaches that include, for example, insisting that those international agencies demonstrate concrete evidence of their meaningful progress toward localisation as a condition of continued funding. 

(ii)                 learn from INGOs. Recognising that one of the big challenges national NGOs face to accessing international funding is multiple complex, due diligence processes, Christian Aid is working with Trocaire, Humentum, CAFOD, CRS, Kerk-in-Actie, SCIAF and Tearfund to  produce a harmonized and simplified due diligence passporting approach that we can socialize to the wider sector. We have also agreed with the 15 UK humanitarian agency members of the DEC to introduce  due diligence passporting where one DEC agency can rely on the due diligence applied to a local partner by another DEC member and not repeat the process. 

 

  1. Beyond the quantity of funding, realising the further commitments in the Grand Bargain 2.0 to support local leadership must incorporate a more transformational shift of decision-making power, in determining priorities, programme-design and evaluation, and in whose knowledge and expertise is valued. Christian Aid civil society partners consistently report being marginalised in processes where donors and ‘implementing partners’ coordinate humanitarian response.  FCDO could do more to determine modalities for local actors to lead on consortia.

 

  1. A key initiative FCDO could support, as part of realizing its White Paper commitments is survivor-and-community-led responses (sclr), an approach developed by Local to Global Protection that  empowers people affected by crises to drive their own relief interventions and strengthen community resilience, as Christian Aid has supported in Haiti,  Ukraine, Kenya, S Sudan, Myanmar, Lebanon, Gaza, West Bank, DRC and NW Syria.[23] ODI’s Grand Bargain Annual Independent Report recognized that our survivor-led response modalities represent one of the most innovative ways in which Grand Bargain signatories have sought to bring together the Grand Bargain cash, localisation, nexus and participation themes, and they encourages donors to invest in these approaches.

 

Question 3: Are the current processes for acquiring and reporting on funding enabling or preventing smaller civil society organisations as they seek to secure support? 

 

  1. We have discussed this question in relation to humanitarian funding above. In relation to development programmes we observe that a significant amount of FCDO development project funding is delivered through procured commercial contracts, where the language is that of procurement, supply chain management and risk management. Several Frameworks such as the Global Development Delivery Framework are used for large chunks of funding – short lists of preferred suppliers. While this provides some degree of transparency of UK spend, it favours large international private sector organisations who have the infrastructures to manage the administrative barriers to entry and ongoing compliance. There are a small number of UK based INGO’s who are credited FCDO suppliers, including Christian Aid. The compliance requirements - and costs of tendering – are huge for INGO’s, so although we appreciate that FCDO is actively considering how to attract more SME’s to its supplier base, we are a long way from what should be the goal of directing an increasing part of this funding to local/national businesses and CSOs. 

 

  1. The alternative funding modality of accountable grants is also becoming more compliance heavy with terms and conditions increasingly resembling those of commercial contracts. Most local based CSO’s could not bear the cash flow cost in standard FCDO contracts, which are typically paid quarterly in arrears. FCDO’s preferred modality of payment by results (PBR) creates even bigger barriers for smaller civil society organisations. Further, the way reporting is managed, including often monthly forecasting and unrealistic key performance indicators (KPIs) around accuracy of forecasting, means recipients of funding have to spend disproportionate amounts of time managing reporting and compliance. Because all the risk is passed to the contractors, the prime contractor typically needs to pass much of that risk down to downstream partners. So even where local CSO’s receive grants from the prime, they will come with additional reporting and compliance requirements to satisfy FCDO risk management.

 

  1. There is very little scope for genuine co creation of projects tendered through the various procurement channels.

 

  1. As FCDO considers its localisation policy, the question of management of the perceived additional risk direct and indirect funding to local civil society organisations generates needs to be re balanced. The reality is that in the current model of development programming the majority of funding favours large international private sector agencies who don’t have the capacity strengthening and long term sustainability of local civil society as a values based aim.

 

Question 6: What role can the FCDO’s work on improving civil society play in broader UK international policy? 

 

  1. As the White Paper says, civil society plays a critical role in supporting open societies and accountable institutions, which in turn have had ‘more stable growth, more ambitious climate policies, better human capital, a lower risk of internal conflict and atrocities, and fewer wars’ as well as ‘development success’ that ‘benefits the majority’.  All of these outcomes, where they do manifest themselves - and where stable growth is equitable, inclusive and sustainable - are important foundations for the creation of a more equal and sustainable world, whilst also delivering on the UK’s own aspirations.

 

  1. Civil society also has a critical role to play in multilateral processes to ensure ambitious, equitable and inclusive outcomes, whether that be at UNFCCC climate talks, or fora where economic policy decisions need to be made in ways that advance the kinds of actions on debt, tax and trade that will benefit lower income countries and in ways that reach those left behind. Christian Aid welcomes the White Paper’s acknowledgement that ‘the countries and people that have historically been excluded from power must have a central voice in how the international order changes’ and the UK’s responsibility to ‘help ensure it is more representative, and that we make space for the people and countries who are closest to the development and climate challenges we share.’  This must include supporting full civil society participation in these processes, as participants in their own right and as support to governments and other official stakeholders.

 

  1. For example, civil society has been central to supporting the efforts led by the Association of Small Island States (AOSIS) to gain recognition of Loss and Damage in the UNFCCC process. AOSIS first proposed references to Loss and Damage in 1991 but it has taken around thirty years for Loss and Damage to be seen as a key pillar of climate negotiations, alongside mitigation and adaptation. Civil society groups were early supporters of the need to recognise climate impacts that are beyond the limits of mitigation and adaptation.[24] National and international civil society organisations have worked in official processes, including providing technical and other support to official constituencies in the UNFCCC, including AOSIS.

 

  1. Similarly, civil society within and across countries has played a key role in the successful calls for the UN to play a central role in international decision-making on tax. Long-standing calls from civil society were given significant impetus by the Africa Group at the UN proposing a UN Framework Convention on Tax Cooperation.[25] Most lower income countries supported the proposal, and work is now underway to define the Terms of Reference and process for establishing a Convention. By demonstrating that existing international rules on tax are not sufficient to prevent corporate and individual tax avoidance across borders, and that lower income countries are losing out disproportionately on revenue, civil society has provided momentum and helped build backing across governments from different regions.

[1] Preface, White Paper International development in a contested world

[2] For example: Christian Aid Programme Learning Partnership, power and adaptive programming:govern service contracts lessons (christianaid.org.uk); a meta evaluation of civil society and governance strengthening in Nigeria https://www.christianaid.org.uk/resources/about-us/doing-accountability-differently-voice-people-nigeria; Evaluation and learning from ECID programme focused on realising rights and improve the well-being of the most marginalised in Myanmar, Nigeria and Zimbabwe Evidence and Collaboration for Inclusive Development (ECID) - Christian Aid; as part of ACT Alliance Development Needs Civil Society- The Implications of Civic Space for the Sustainable Development Goals - ACT Alliance; and see also for example Christian Aid’s analysis of the vital role of civil society in countering Covid-19 and building accountability, rights and freedom: "Building back with justice Covid19 Report".

[3] ODI Report (thepolicypractice.com) on 20 years of UK FCDO programming in Nigeria and Civil Society Engagement in Development Co-operation - OECD

[4] See for example, Engaging Citizens and Civil Society to Promote Good Governance and Development Effectiveness ADB 2015.

[5] See Jonathan Fox and Naomi Hussein’s recent (2023) Pathways towards power shifts: State-society synergy - ScienceDirect; and (PDF) Has civil society helped the poor? - A review of the roles and contributions of civil society to poverty reduction? (researchgate.net)

[6] Development Needs Civil Society– The Implications of Civic Space for the Sustainable Development Goals

[7]  How Covid-19 has shrunk civic space | Christian Aid; christian-aid-covid-and-civic-space-report-2020-21-summary.pdf (christianaid.org.uk)

[8] ICAI recommendations on the UK’s approach to democracy and human rights: FCDO response - GOV.UK (www.gov.uk)

[9] sabi-donors-and-international-ngos-briefing.pdf (christianaid.org.uk)

[10] Public finance, anti-corruption and accountability in Sierra Leone - Christian Aid

[11] Tax Justice Network Africa (TJNA) (taxjusticeafrica.net)

[12] See learning from Civil Society Fund (CSF) - Christian Aid and more recently Evidence and Collaboration for Inclusive Development (ECID) - Christian Aid

[13] Ekta Parishad campaign 2015

[14] For examples recent calls in Nigeria for the NGCP, and in DRC for the PARI programme

[15] sabi-donors-and-international-ngos-briefing.pdf (christianaid.org.uk)

[16] UK aid funding for refugees in the UK - ICAI (independent.gov.uk) ; and UK aid provisional statistics for 2023 – a quarter of UK aid still being spent in the UK | Bond

[17] International-Climate-Finance-ICAI-Review.pdf

[18] International Development Committee Oral evidence: Investment for development: The UK’s strategy towards Development Finance Institutions, HC 884 Tuesday 25 April 2023 Q192

[19] See for example, the IDC report on DFIs which raises a number of concerns about poverty focus and transparency Investment for development: The UK’s strategy towards Development Finance Institutions (parliament.uk); Christian Aid’s submission committees.parliament.uk/writtenevidence/117562/pdf/; and documentation of impacts of in education committees.parliament.uk/writtenevidence/117563/pdf/ and healthcare committees.parliament.uk/writtenevidence/122457/pdf/

[20] Research from Oxfam and Eurodad that finds insufficient accountability to communities Blended Finance: What it is, how it works and how it is used (d3n8a8pro7vhmx.cloudfront.net)

 

[21] Localization at USAID: The Vision and Approach Moving Toward a Model of Locally Led Development (usaid.gov)

[22] Promoting Equitable Partnerships with Local responders in Humanitarian Settings (europa.eu)

[23] a-review-of-survivor-and-community-led-response-sclr-in-haiti.pdf (christianaid.org.uk) Christian Aid Template Christian Aid Template (interagencystandingcommittee.org)

[24] Timeline: The struggle over ‘loss and damage’ in UN climate talks (carbonbrief.org)

[25] A new UN Tax convention – how will it change global tax governance? – ICTD