Written evidence submitted by the Foreign, Commonwealth and Development Office in response to the International Development Committee call for evidence on humanitarian access and adherence to IHL

Introduction

The last year has seen the highest number of armed conflicts since World War II. Conflicts are also becoming increasingly severe and complex. Access to humanitarian assistance and the ability of aid workers to access populations safely are more critical yet more challenging. Aid worker fatalities almost doubled in 2023 compared with 2022 according to the Aid Worker Security Database[1] (AWSD) and 2024 was the deadliest year on record for aid workers.

International Humanitarian Law (IHL, also known as the law of armed conflict or the laws of war) seeks to limit the effects of armed conflict to protect people who are not, or who are no longer, participating in the hostilities, and limits the methods and means of warfare. The principles of distinction, proportionality and precaution are central to IHL.

When national authorities and other parties to conflict fail to comply with the rules of IHL, the direct consequences for civilians include death, injury, sexual violence, torture, displacement, unlawful detention, family separation, loss of livelihoods, interrupted access to basic services, and psychological harm.

The Government has been clear that the UK is committed to protecting those most at risk in situations of conflict and crisis, including civilians, refugees, internally displaced people, women and girls, and people with disabilities. Promoting IHL compliance is a cornerstone of UK humanitarian policy.

1. What are the current trends in adherence to international humanitarian law in conflicts, particularly regarding the safe delivery of humanitarian assistance?

There are many reports from the UN and civil society alleging breaches of IHL, including deliberate targeting of civilians and mass atrocities in conflicts around the world. These include Syria (2011), Yemen (2014), the impact of Russia’s full-scale invasion of Ukraine (2022), the current conflict in Gaza (2023) and Sudan (2023). Conflict is increasingly urbanised, increasing the proximity of civilians and humanitarian relief operations to military targets, putting the former at risk.

Non-state armed groups (NSAGs) have also grown in number. According to the ICRC, the number of armed groups of humanitarian concern[2] has consistently exceeded 450 over the past six years[3] - in comparison with only 170 in 2011. The motivations, size, structure and capabilities for violence of NSAGs vary widely. While large groups with centralized and well‑defined command and control structures continue to arise and thrive, other groups are decentralized in their structure and operate in fluid alliances. These factors compound difficulties enforcing IHL, securing access, and complicates efforts to promote their compliance. This has increased the risks and complexity of humanitarian operating environments.

As a result of significantly increased levels of global conflict, the UN assesses that civilian deaths increased by over 70% in 2023. Conflict continues to disproportionately impact women and children: the proportion of women killed in armed conflicts during 2023 doubled compared to 2022; violence against children in armed conflict increased, with the UN recording a 21% increase in grave violations against children[4] in 2023. The impact of conflict on women and girls is exacerbated by the roll-back on their rights, including restricted access to healthcare for women and girls in conflict.

The UK advocates for full, unimpeded, and timely access by impartial humanitarian actors to affected populations in need of protection and life-saving assistance. The UK also consistently highlights, with grave concern, reports that limitations on aid access are increasingly imposed by parties to conflict to further their war aims, gain leverage in negotiations or to undermine the legitimacy of adversaries. The UN noted in 2023 that the denial of humanitarian access took various forms, including the restriction of humanitarian activities and movements, interference with humanitarian operations and aid recipients, disinformation and arbitrary detention, the perpetration of violence against and the killing of humanitarian personnel, and looting[5]. The highest number of denials of humanitarian access, as verified by the United Nations, were in Afghanistan, the Central African Republic, Israel and the Occupied Palestinian Territories, Mali, Myanmar, areas of Ukraine occupied by Russia, and Yemen. In 2023, the UN reported 5,205 verified incidents of the denial of humanitarian access to children, an increase of over 32% from 2022.

The high number of fatalities among aid workers in 2024 was driven in large part by deaths in Gaza, Sudan and South Sudan, among other crises. Gaza is the deadliest context for humanitarians in the world. Since the start of the conflict over 330 humanitarians have been killed in Gaza, including three British humanitarians working for World Central Kitchen (WCK).

Technological advancements and digitisation have enabled mis- and disinformation[6] to spread more widely and undermine perceptions of the neutrality of aid workers and relief operations, damaging community acceptance and increasing risks.

2. What impact does lack of adherence have to both the physical access to humanitarian supplies and the safe operation of aid workers?

Conflict parties’ denial or blockage of humanitarian access undermines civilians’ access to basic goods, services and humanitarian relief. This, combined with destruction of essential civilian infrastructure to meet basic needs (for example, food production sites), compounds the suffering of civilian populations in conflict zones and increases their reliance on extreme and irreversible coping strategies, such as selling assets and child marriage. In 2023, over 281 million people faced acute food insecurity in 59 countries. Of this number, 80% were in this situation primarily due to conflict and instability.

In addition to the direct harm caused by the lack of adherence to legal norms, indirect impacts include undermining trust between warring parties and humanitarian organisations. This has the potential to restrict access further and make it more difficult to negotiate safe passage, creating a volatile operational environment which directly threatens aid workers' safety. In areas where aid workers suffer repeated attacks, security considerations result in lower operational presence of UN and international NGO aid agencies on the front line. This increases reliance on local and national actors to deliver aid, making them take bigger risks to reach those most in need of support. Security incidents therefore disproportionately affect local and national aid actors, which often have inadequate resources for security risk management.

Constraints on humanitarian access and lack of adherence to IHL increases the financial cost of humanitarian aid. As global humanitarian funding is insufficient to meet growing needs, additional costs ultimately decrease the volume of aid provided to those who need it most. Volatile environments require aid organisations to commit more money to security management, insurance and protective equipment. Costs are also incurred to replace or repair destroyed or damaged aid items and humanitarian facilities. Delays associated with blocked access make aid less timely and cost-efficient, and perishable items can spoil while aid actors are unable to deliver. Bureaucratic impediments such as the requirement for aid actors to pay for visas, custom fees and other levies, similarly increase the cost of delivery, and decrease the amount of funding available for aid that supports people in need.

3. What is the FCDO’s record of using its diplomatic levers to promote access to aid, protection of aid workers? How might its approach be improved?

FCDO is committed to using its diplomatic reach and political influence to achieve humanitarian outcomes in crises. Diplomatic tools are critical to encourage parties to consent to humanitarian relief operations, facilitate unimpeded access, and protect civilians including humanitarian aid workers. The UK uses its seats at key multilateral fora such as the UN Security Council, its bilateral relationships with parties to conflict and states with influence over them, and its partnerships with humanitarian actors on the front line to enhance impact. This includes both public and private actions. We consider the full range of influence that the UK can bring to bear, working across departments. For instance, the FCDO regularly briefs Defence Attachés on humanitarian policy, and seeks their advice, including on humanitarian access and protection.

The FCDO has a strong record of using diplomatic tools to enhance humanitarian outcomes. For example, the Pretoria peace agreement between the Government of Ethiopia and the Tigray People's Liberation Front (TPLF) transformed humanitarian access into Tigray which had been severely constrained during the conflict. The talks were convened by the African Union’s Special Envoy, with the UK and partners playing pivotal roles. The UK used its influence with key actors including lobbying parties for ceasefires and a negotiated solution. In 2022, UK diplomatic lobbying supported the Black Sea Grain Initiative, led by the UN Emergency Relief Coordinator, to stabilise global food markets and supply chains, helping to ameliorate risks of global food insecurity. When the deal collapsed in 2023, UK diplomacy paired with military support helped Ukraine to continue to export grain and other key foodstuffs. For Syria, the UK played an important role in the Humanitarian Task Force (HTF), created through a Ministerial conference, to help facilitate the implementation of a ceasefire and support a political settlement. In 2016, for example, HTF members used shuttle diplomacy between states to enable talks with government and opposition parties, and the states with influence over them. It delivered humanitarian outcomes, notably on access, by helping to enable localised agreements with opposition groups albeit some agreements were not sustained – over the long term.

Where the traditional humanitarian system is not able to negotiate access or States do not provide consent, the UK has also supported other approaches to alleviate constraints. The UK has, for example, previously supported the designation by the UN Security Council of cross-border access routes into Syria to ensure that populations can be reached through the most effective means and without interference from state, non-state and other actors of influence who may seek to politicise assistance. However, this type of approach comes with severe operational risks. When humanitarian organisations enter a country under the auspices of a UNSC resolution, rather than state consent, humanitarian organisations often lack security assurances from the State or other parties to conflict which form the normal basis of humanitarian access. In conflict contexts, the lack of consent or engagement with the parties to conflict can expose aid workers to attack or other forms of violence. It can also undermine the perception of humanitarian neutrality which might act as a barrier to humanitarian access in the longer term.

More recently, the UK Government has used its seat on the UN Security Council (UNSC) to promote access to aid and stress the importance of protecting aid workers. This includes UK-penned UN Security Council resolution 2736 on Sudan, which called on the parties to allow unimpeded humanitarian access and demanded compliance with international law. The resolution also requested the UN Secretary General provide the Security Council with a report on recommendations for the protection of civilians in Sudan. The UK co-hosted a Ministerial event to highlight serious concerns about the safety of civilians and amplify the voices of Sudanese civil society organizations. On Gaza, the UK Government continues to do all it can to improve aid access. At a recent Humanitarian Conference hosted in Cairo, the Minister for Development met with international partners, to discuss how to urgently alleviate suffering in Gaza, as part of a three-day visit to Egypt, Jordan, the OPTs and Israel. Moreover, the UK has supported UNSC resolutions including 2720, which focussed on removing barriers to humanitarian assistance in the Gaza strip, and reiterated the parties’ obligations to protect civilians, including humanitarian workers, in line with IHL.

In May 2024, the UK co-sponsored UNSC resolution 2730. This resolution strongly condemned attacks and all forms of violence, including sexual and gender-based violence, threats, and intimidation, against humanitarian personnel and United Nations and associated personnel, their premises and assets. UNSC resolution 2730 also emphasised protection for national and locally recruited personnel and requested the UN Secretary General to update the UNSC regularly on progress to protect humanitarian personnel. The UK also co-sponsored the UN General Assembly Resolution on the Safety and Security of humanitarian personnel. The UK used this as an opportunity to reaffirm the importance of the International Criminal Court (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, which established the ICC. The UK also uses its seat at the UN to promote the meaningful participation and protection of women in crisis response and peacebuilding, counter reprisals against women peacebuilders and women’s rights defenders and build protection against conflict related sexual violence, within UN Security Council country and thematic resolutions. In 2024, the UK also secured language on preventing threats, violations and abuses experienced by women and girls in armed conflict within the UN’s ‘Pact for the Future’.  These efforts contribute towards building a safer and more protective environment for female aid workers to carry out their work and helps to facilitate safer access to humanitarian assistance, especially for women and girls. The UK has consistently lobbied at the UNSC for the release of aid workers unlawfully detained by the Houthis. In September 2024, the UK co-chaired an event at the UN General Assembly on Houthi detentions, resulting in a joint statement signed by seven international partners demanding the immediate and unconditional release of Houthi detainees.

At the UN General Assembly in September 2024, the UK joined the Australian–led Foreign Ministers’ initiative, with other states, to develop a political declaration to enhance protection for humanitarian personnel. The proposed declaration is intended to complement UNSC resolution 2730 by galvanising collective action to protect aid workers and amplifying calls for compliance with IHL. The UK also recently agreed to join an open pledge on the protection of humanitarian personnel announced at the 34th International Conference of the Red Cross and Red Crescent in Geneva.

Bilateral diplomatic engagement is used, at various levels, to promote access to aid and the protection of aid workers. By way of example, the Foreign Secretary has regularly raised IHL compliance with the Israeli Government on both Gaza and Lebanon. The Foreign Secretary raised humanitarian access in January 2025 with Israeli Foreign Minister Sa’ar. The Minister for Development pushed on access issues in detail with the Israeli Government during her December 2024 visit to Tel Aviv, and these issues have been regularly raised by the Minister for the Middle East and North Africa. In addition, the Foreign Secretary appointed a Representative for Humanitarian Affairs for the OPTs who routinely holds senior conversations with the Government of Israel to reinforce UK advocacy and meets regularly with the Palestinian Authority, other regional and international partners, as well as the UN to advance UK priorities for the OPTs. The UK has repeatedly lobbied Israel to secure justice for victims of the World Central Kitchen incident in Gaza and to improve aid worker safety. This includes the UK lobbying Israel to provide a timetable for the conclusion of the Israeli Military Advocate General’s (MAG) investigation into the incident. The Foreign Secretary has also advocated for Israel to complete the MAG investigation swiftly and thoroughly. The UK has made private and public representations to Israel to improve deconfliction mechanisms, including notification, which help to protect aid workers operating in Gaza. The UK was a key facilitator of efforts to drive urgent action on polio vaccination in Gaza, including by convening an emergency session of the UN Security Council in August 2024 alongside direct advocacy to press Israel to enable humanitarian access and delivery of the vaccine. The UK’s flexible funding supported delivery of the polio vaccination campaigns through the Global Polio Eradication Initiative[7] (GPEI). The UK also funds Gavi, the Vaccine Alliance[8], and works with international partners as part of the Gavi Board to support wider immunisation across the globe including children living in Gaza, the West Bank and within the Palestinian populations in Lebanon.

The UK uses diplomatic levers to press all parties to honour and respect the Humanitarian Notification System (HNS) in southern Lebanon. The HNS is a mechanism that informs conflict parties of the location of humanitarian facilities and movements that are entitled to protection under IHL. This is critical to protect humanitarian personnel and assets from attack and enable humanitarian agencies to deliver life-saving assistance and protection, and to promote the safety of the UN peacekeeping mission in Lebanon. 

As part of the UK Strategic Arms Export Licensing Criteria, the Government suspended certain export licences to Israel for use in military operations in Gaza, following a review that concluded there is a clear risk that items might be used to commit or facilitate serious violations of international humanitarian law in Gaza.

The FCDO is currently examining ways to more systematically mobilise collective diplomatic action with partners and allies to maximise impact on humanitarian access and protection. For example, we have led the international community in calling for increased protections for aid workers in Gaza, including in public statements at the UN and elsewhere, and in private dialogue with the Government of Israel. This type of collective diplomatic action draws on global lessons learned from the diplomatic initiatives – mentioned previously in this response – that aimed to enhance humanitarian outcomes in Syria, Tigray in Northern Ethiopia, and the Black Sea Grain Initiative in Ukraine. A humanitarian diplomacy training module is also under development in partnership with the British Red Cross to bolster capability across FCDO, share lessons learnt, and mitigate risks to enhance protection for humanitarian personnel.

The FCDO is also continuing to strengthen its monitoring and understanding of atrocity risk factors to inform more targeted and effective action in high-risk contexts, including diplomatic action, and to improve guidance and best practice on atrocity prevention across the FCDO network. 

4. How has the level of risk for aid workers changed in recent years and where does responsibility for their protection lie? What protections are available and are they adequate?

2024 has been the deadliest year on record for aid workers and follows an almost doubling of fatalities between 2022 and 2023 according to the AWSD. Aid workers and aid facilities are increasingly affected by attacks, kidnappings, and harassment. In Gaza, which as previously detailed, has the highest number of aid worker deaths globally, barriers to access and restrictions on humanitarian aid have worsened aid worker safety. A simultaneous decline in law and order has further increased risks for aid delivery and aid workers. Although armed non-state groups remained the most frequent perpetrator of incidents involving aid workers globally in 2023, the proportion of incidents involving state actors increased according to the AWSD. Analysis of perpetrators in 2024 has yet to be released.

As previously intimated local and national humanitarian actors are consistently disproportionately impacted. This can be particularly acute for female aid workers and women’s rights organisations. We are currently witnessing a global roll-back on women’s rights which is increasing restrictions on female aid workers in contexts such as Afghanistan and Yemen, and threats, intimidation and reprisals against local women’s rights organisations impacting on access to critical humanitarian services, especially for women and girls. The global scale of conflict-related sexual violence (CRSV) cases is also deeply concerning, with a 50% increase in the number of UN-verified cases of CRSV recorded in 2023.[9] Through the Preventing Sexual Violence in Conflict Initiative (PSVI), we are supporting thousands of survivors around the world, strengthening national justice systems leading to landmark convictions for CRSV, and driving international action through the International Alliance on PSVI. Our PSVI Team of Experts can be deployed to support international, and local efforts to address CRSV. Recent deployments include Israel and the Occupied Palestinian Territories and Ukraine.

Responsibility for protection is outlined in international law. For instance, personnel participating in humanitarian relief operations are usually civilians and thus entitled to the protection afforded by IHL. 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.

In addition, the 1994 Convention on the Safety of United Nations and Associated Personnel requires state parties to criminalise murder, kidnapping or other attacks upon the person or liberty of any UN or associated personnel; and violent attacks upon the official premises, the private accommodation or the means of transportation of United Nations or associated personnel.

Conducting attacks against humanitarian personnel and diverting or looting humanitarian supplies have been the basis for the imposition of sanctions by the UN Security Council, including in the Central African Republic and Somalia.

Current protections for aid workers have limitations, particularly when aid workers deliver humanitarian assistance in close proximity to active conflict. Humanitarian Notification Systems (HNS) are a critical tool to help protect aid workers, when parties fully engage, but they are voluntary and therefore not consistently adhered to. The efficiency of the HNS is also reliant on the UN having sufficient capacity to process large volumes of information, and these systems are not always easily accessible to local and national aid organisations.

FCDO-funded research[10] highlighted the importance of efforts to engage armed non-state actors in efforts to promote compliance with IHL including clear messaging that civilians, including aid workers, must not be targeted. Meaningful inclusion of national aid organisations in the development of security management systems or other protective mechanisms is also critical to effectively reduce vulnerability to conflict.

5. How could UK ODA funding be made more relevant and accessible to support protection of workers, both local and international?

FCDO uses a variety of approaches to ensure that ODA is relevant and accessible to support the protection of international and local aid workers. This includes direct investment to support the protective measures our partners require to work safely, the freedom to use different aid modalities such as cash transfers when they can reduce risks to aid workers and aid recipients, and flexible funding to enable our partners to strengthen their risk mitigation strategies when required.

Examples of UK ODA funding that contributes to the protection of aid workers include:

-          Core funding to the United Nations Office for the Coordination of Humanitarian Affairs (UNOCHA) whose mandate includes the management of HNS, as well as leading humanitarian access negotiations.[11]

-          Partnership with the International NGO Safety Organisation (INSO) to fund risk analysis, safety advice, and security training for international and national humanitarian non-governmental organizations in crises.[12]

-          Funding at the country level, as required, to support security risk management among humanitarian organisations. For instance, in Ukraine the FCDO funds the Humanitarian Action through Volunteers, Enablers and Networks (HAVEN) consortium to provide a 'duty of care package’ to local partners and first responders operating on the front line. This funding also contributes to the provision of armoured vehicles that enhances the safety of aid workers delivering programmes.

-          Funding for the International Committee of the Red Cross (ICRC) to uphold and alleviate suffering, protect victims of armed conflict and promote International Humanitarian Law[13] and the International Federation of the Red Cross and Red Crescent Societies (IFRC) and British Red Cross (BRC) to build National Society capacity, promoting IHL, maintaining the Customary IHL database, and undertaking their valuable auxiliary function for the UK Government.[14]

-          Being a major donor to UN managed Country Based Pooled Funds (CBPFs) which also play a key role in funding humanitarian action by local and national organisations.[15]

-          Advocating for the use of cash to meet basic needs in crises when appropriate which can reduce the risks aid workers are exposed to when they travel long distances to transport various goods to distribute themselves. Advancements in financial services and satellite imagery have also enabled greater reach into remote and difficult to access areas.[16]

-          In project funding, consistently building in funds to allow NGO and UN partners, and the Red Cross and Red Crescent Movement, to manage security in insecure environments.

This support must keep pace with emerging risks and new technologies to remain relevant. In recent years we have seen the consequences of disinformation on humanitarian assistance. Disinformation undermines the protection of humanitarian workers by eroding trust, spreading false narratives, and potentially inciting violence against them. UK support to local media and trusted global media outlets such as the BBC World Service, and media development actors, increase access to reliable and accurate information by civilians and parties to conflict. The FCDO also funds specific programmes to understand the impact of misinformation and disinformation on humanitarian action, such as in Sudan. Building on this work could help to counter the misinformation and disinformation that is increasing threats to civilians, including local and international aid workers.

Since 2022, the FCDO has used technology to enable improved risk analysis through its partnership with open-source investigation (OSINT) organisations that draw on digital data (e.g. satellites and social media) to remotely monitor issues related to conflict and human rights. The FCDO has funded OSINT projects in specific geographics where there are risks of large-scale human rights violations and abuses, for example with the Centre for Information Resilience (CIR) in Sudan. In some cases, the CIR works directly with justice and accountability actors.

6. Are the levels of support, including psychological support, for those affected by trauma in the delivery of ODA adequate and how could the Government better enable provision of these services?

FCDO takes seriously issues of health and safety, including mental health and safeguarding, for our partners, those affected in humanitarian contexts, and our staff. We recognise the courage and commitment of those who take part in humanitarian operations, especially national and locally recruited personnel. This includes those serving with national and international non-governmental organisations in the field, often at great personal risk and a negative impact on their health, including mental health and psychosocial well-being, especially when working in situations of armed conflict and exposed to direct violence, injury and risk of illness with limited access to medical and emergency facilities.

FCDO funding arrangements require partners to demonstrate sufficient capacity and capability to meet their obligations under the arrangements, including those relating to the priorities of health (both physical and mental), safety, security and safeguarding measures.  This is tested through the FCDO’s due diligence framework, which considers risks that are relevant to the programme in question. This framework covers social and environmental impacts and the measures that partners have in place to manage these risks down the delivery chain. 

The FCDO will also fund additional mental health support for partners when there is an identified gap in available service provision. For instance, in Ukraine a FCDO-funded Volunteer Resilience Programme has provided a crucial opportunity for volunteers and the staff of local humanitarian organisations to access mental health support.

The Government requires all organisations we fund directly or indirectly to do all they reasonably can to prevent and respond to sexual exploitation, abuse and harassment (SEAH). This includes taking a survivor-centred approach and having clear guidelines for supporting individuals affected by SEAH. UN and NGO data show that access and funding constraints mean that less than half of victim-survivors of SEAH receive assistance, and no services (e.g. medical, legal or psychosocial services) are available for about a quarter.  The Government will provide funding over the next five years to improve support to victim-survivors of SEAH and continue to advocate for improved global resourcing of support services in humanitarian, development and peace-related work. In November the FCDO published a related paper[17] as part of the global Common Approach to Protection from SEAH[18].

FCDO also provide consular assistance and support to British nationals working for NGOs and UN Agencies overseas, if requested.

FCDO staff themselves can also face wellbeing challenges. The majority work overseas, many in hostile or challenging environments far from home, family, and friends. The FCDO is responding with a range of interventions. The Home welfare and overseas welfare teams assist colleagues and managers in the UK and overseas, drawing on advice from our Mental Health Experts Advisory Group. The FCDO recently launched a welfare strategy for staff, as well as guidance about exposure to potentially distressing material. Staff can receive support from our global network of over 355 Mental Health First Aiders, and an active Mental Health, Wellbeing and Listening Network. During 2023, the FCDO conducted around 60 Trauma Risk Management assessments in places like Tel Aviv and Jerusalem. All staff (and adult dependants posted overseas) have 24/7 access to the FCDO’s Employee Assistance Programme whose provider also arranges bespoke support for priority posts.

7. What are the gaps in international humanitarian law when it comes to humanitarian access and what could be the UK Government’s role in addressing this?

The expression ‘humanitarian access’ is not found in IHL but is frequently used in Security Council resolutions and policy documents. There are two elements of humanitarian access:

• the ability of humanitarian actors to conduct humanitarian relief operations as foreseen by IHL; and

• the ability of civilians to access basic goods and services, including when provided as humanitarian assistance.

IHL provides the framework for the regulation of armed conflict with a view to minimising suffering of the civilian population, which includes rules on humanitarian relief operations. IHL recognises the right for the civilian population of a State affected by armed conflict to receive humanitarian assistance. 

In recent conflicts, parties have interfered with infrastructure and services to which civilians need access to meet their basic needs and for their livelihoods, including electricity, telecommunications, and internet. IHL does not address the situation when services are simply suspended, as occurred in Sudan when there was a nationwide telecommunications blackout and in Tigray when electricity, internet and telecommunications, and banking services were shut down which restricted civilians’ access to critical services. In such circumstances, states’ rights and obligations under other bodies of law, including any that arise under applicable human rights law, continue to apply. The specific issue of internet shutdowns in both conflict and non-conflict settings is gaining increased global attention. The UK is working to address the issue of internet shutdowns through the UN, G7 and Freedom Online Coalition (FOC) including the FOC’s Task Force on Internet Shutdowns which we chaired in 2023 and 2024.

In response to the broader aspects of humanitarian access and civilian harm not specifically addressed by IHL, the UK and others have focused on what other interventions can be used beyond promoting compliance with IHL to protect and address the needs of civilians in humanitarian crises. For example, in May 2024 the UN Secretary General stressed the need to move towards an approach of seeking to ensure the “full protection of civilians”, which goes beyond minimum legal compliance with IHL and seeks to address the complex, overlapping, and cumulative nature of civilian harm.”[19]

At the UN Security Council, the UK highlighted the stark picture presented by the UN Secretary General’s report and affirmed that Member States should reverse these trends by taking a comprehensive approach to protection. We continue to champion the report and raise the need for protection of civilians in contexts such as Sudan, Gaza and Haiti. 

Building on our pioneering research with ICRC on the ‘Roots of Restraint in War’[20], the UK has devised and funded new research by the “Beyond Compliance Consortium” that is identifying what strategies have the most potential to generate compliance with IHL by armed actors and what new guidelines and other measures could address issues that IHL does not fully cover. This research will inform more effective engagement by FCDO with parties to conflict to reduce civilian harm and also help to develop broader UK policy on the protection of civilians. Further, we supported the London School of Health and Tropical Medicine to develop ground-breaking statistical analysis to make the estimation of food availability and projection of mortality in the Gaza conflict faster and more accurate.[21] This type of work helps to inform the Government and other actors’ understanding of the impact of conflict on civilians and to adjust public health and nutrition interventions based on anticipating future scenarios.

8. What more could the Government do, with or without partners, to hold perpetrators of attacks and abuse against aid workers to account and encouraging adherence to international humanitarian law on these issues?

Accountability

Support for international criminal justice and accountability is a fundamental element of the Government’s foreign policy. The International Criminal Court (ICC) is the primary international institution for investigating and prosecuting individuals charged with the most serious crimes of international concern, holding perpetrators to account and achieving justice for victims. The UK is one of the Court’s main funders, contributing £13.3 million to the ICC’s annual (2025) budget.  We provide practical support including expert secondments, training on investigative capability, and witness protection, sentence enforcement, and voluntary contributions to provide cyber security support.  

This Government will continue to support both the ICC and domestic accountability efforts, examining opportunities to support other governments to build their own judicial and investigative capabilities so that perpetrators of attacks and abuse, including those against humanitarian personnel, can be held to account. We will consider further secondments to ICC investigations where we can provide specific expert support, including where in-country access is limited. We will explore where we might provide capacity building support to develop domestic capabilities, and work with partners to ensure effective co-ordination of international support, as we have done with the US and EU through the Atrocity Crimes Advisory Group for Ukraine.

Adherence

The UK actively promotes adherence to IHL in multilateral fora and bilaterally, by supporting States as they seek to improve domestic implementation. The UK leads by example in this area.  In October 2024, under the auspices of the UK’s National Committee on International Humanitarian Law, we launched a new and expanded UK Voluntary Report on the Implementation of International Humanitarian Law at the Domestic Level. Further in October 2024 the Minister for Development and Women and Equalities and the Attorney General attended a UK event to commemorate the 75th anniversary of the Geneva Conventions. This event convened key IHL stakeholders from the military, legal, government, and humanitarian organisations. The Minister highlighted that the UK must work with partners to close the gap between where we are and where we need to be on global compliance with IHL.

The UK provides funding to actors who promote and disseminate IHL, notably components of the International Red Cross and Red Crescent Movement.  The UK funds the ICRC to support its role assisting parties to conflict in meeting their IHL obligations, supporting States to implement IHL, and its work to understand how IHL applies to evolving methods of warfare. The British Red Cross has a responsibility and role in the promotion and implementation of IHL in the UK, so it has a special relationship with HMG in this field. The UK provides funding to relevant NGOs, for example Geneva Call, who encourage non-state armed groups to comply with IHL.

The UK also provides core funding as well as diplomatic and operational support to the International Humanitarian Fact-Finding Commission (IHFFC), a dedicated investigative body at the service of parties to an armed conflict to conduct inquiries into alleged violations. 

Adherence will also be enabled by knowledge and understanding. We intend to publish a new UK legal handbook on Conflict, Hunger and International Law that presents the IHL rules most relevant to addressing conflict-induced hunger in an accessible manner for use by practitioners. The IHL rules are accompanied by practical guidance, case studies and recommendations on good practice, including on humanitarian access.

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