Written submission to the International Development Committee inquiry: Humanitarian access and adherence to international humanitarian law 

Evidence submitted by ActionAid UK 

1.       About ActionAid  

1.1.             ActionAid is a global federation working with more than 41 million people living in more than 71 of the world’s poorest countries. We want to see a just, fair and sustainable world, in which everybody enjoys the right to a life of dignity, and freedom from poverty and oppression. We work to achieve social justice and gender equality and to eradicate poverty, including by shifting power to local organisations and movements. Women are disproportionately impacted by disasters, conflicts and crises; that’s why we have a particular focus on women’s rights and cultivating women’s leadership in emergencies.

1.2.             Our human rights-based approach aims to ensure that people are drivers of their own change and are able to claim the rights they are entitled to. We focus on women and girls because the denial of their rights is a grave injustice and one of the underlying causes of poverty worldwide. By working directly with communities, women’s movements, activists, groups and networks, social movements, and other allies, we aim to tackle the structural causes and consequences of poverty and injustice. For more information, please contact Sangeetha Navaratnam-Blair, Senior Humanitarian Advocacy Manager at Sangeetha.Navaratnam-Blair@actionaid.org

2.       Summary & recommendations

2.1.             The UK government must take a consistent approach to strongly condemn any violations by international states who violate international humanitarian law, target humanitarian workers and restrict humanitarian access. They must acknowledge when failures to adhere to international humanitarian law occur and demand respect for the law. The UK must leverage its diplomatic relationships to condemn violations of international humanitarian law publicly and privately, and to support investigations into the violations of international humanitarian law.

2.2.             Attacks on humanitarian workers can constitute violations of international humanitarian law when they breach protections afforded to humanitarian personnel under the Geneva conventions and their Additional Protocols. This includes the intentional targeting of humanitarian workers delivering food, medical supplies, or other relief to civilians in conflict zones; attacks on clearly marked humanitarian facilities (such as hospitals, warehouses, and ambulances); the denial of access to humanitarian workers, and hindering the safe evacuation of humanitarian workers. Such violations of international humanitarian law and attacks on workers is counterproductive to the support that the UK government provides in the form of ODA and humanitarian appeal funding.

2.3.             International humanitarian law also states that attacks must not be targeted against civilians. The targeting of civilians has a specific impact on women and girls, who are disproportionately impacted by conflict. Women undertake a disproportionate amount of the care burden for their families and the community as a whole, which only increases during conflict especially when food insecurity and military violence causes more need. Violations of international humanitarian law worsens these conditions for civilians, putting women and girls at greater risk of exploitation and harm.

2.4.             The UK government must condemn attacks on civilians during conflicts. They must also engage women from affected communities in their humanitarian response, conflict policy and peacebuilding, to recognise the crucial role women play and to have the most effective response. They can achieve this through meaningful partnership with women’s rights organisations and women-led organisations who are the experts in their contexts.

2.5.             The UK government’s humanitarian approach must be political and programmatic: we reiterate the messages made in a 2024 UN OCHA report regarding the situation in Myanmar, “urgent humanitarian diplomacy at the political level is required to reduce the human impact of the conflict and facilitate access to affected people”[1].

2.6.             The UK government’s approach must also be context-specific. This submission shows examples where governments responsible for violations of international humanitarian law are resistant to advocacy and diplomatic leverage has a lesser impact. In these cases, the UK government must weigh up the potential efficacy of sanctions with the possible inadvertent impact on the general population through disruption of economic activities and access to essential goods. These sanctions must be carefully considered and targeted. While putting sanctions on governments can be effective, it is also very important to note the case of Myanmar where the State Administration Council (SAC) and their families have alternative income generation strategies outside the country.

2.7.             The UK government must acknowledge this, actively engage with proximate civil society and women’s rights organisations to listen to their needs and ramp up their support for these organisations. The UK Government provided £878 million in ODA for humanitarian assistance in 2023[2], but this work is undermined by continued violations of international humanitarian law.

2.8.             The UK government must recognise the highly volatile and ever-changing context of working in humanitarian, disaster and conflict zones. The UK must change its funding modalities to reflect the context, by providing flexible and unrestricted funding to national and local actors, who can adapt to changing situations and target funding and resources to the most appropriate work. The UK must ensure that 25% of humanitarian funding goes to national and local actors, as per the commitments made under the Grand Bargain, in particular national and local women’s rights organisations who are able to respond to the needs of the whole population including women and girls who are most impacted by humanitarian disasters but are often the least considered.

3.       Impact of conflict and international law violations on aid workers

3.1.             Many international actors, including the UK, take a binary approach where humanitarian workers and the communities served are seen as two distinct and separate groups. However, we know from our humanitarian practice that the people providing humanitarian assistance and coordinating humanitarian response are themselves the survivors of the conflict, sexual violence and humanitarian emergencies. Humanitarian workers and their families are directly impacted by humanitarian crises.

3.2.             Direct attacks on humanitarian workers, medical provisions (e.g. hospitals, medical staff, ambulances), and on aid supplies (e.g. vehicles, aid truck) are also a violation of international humanitarian law. This directly negates the safe operation of humanitarian workers and impairs the physical access to humanitarian supplies. Since the military coup in Myanmar in 2021, 880 healthcare workers have been arrested and 97 have been killed – resulting in a serious impact on health facilities and access to healthcare. [3].

3.3.             Attacks on humanitarian workers not only violate international humanitarian law but also undermine the delivery of critical assistance to those most at need. States, armed groups, and all parties to a conflict are obligated to respect and protect humanitarian personnel, facilities, and operations under international law. Accountability for such violations is crucial to maintaining the principles of humanity, neutrality, and impartiality in conflict zones.

3.4.             In Myanmar, the State Administration Council (SAC) introduced enforced military conscription in February 2024, for men aged 18-35 and women aged 18-27[4]. This has directly impacted humanitarian workers who are included in this, which has resulted in some humanitarian workers fleeing the country to claim asylum in other countries. Other humanitarian workers report waiting on edge until they receive conscription. This removal of large numbers of young people from communities has increased the care responsibilities for those remaining, in particular older women.

3.5.             In the occupied Palestinian territory, Israeli government airstrikes have targeted and killed humanitarian workers directly—343 humanitarian workers have been killed since October 2023. Primarily this is a violation of their human rights and international humanitarian law, but additionally reduces the number of people who can provide humanitarian supplies to the community and discourages other humanitarian organisations from working in the occupied Palestinian territory.

3.6.             Throughout 2024, the Israeli military increased their offensive and full-scale ground invasion in the occupied Palestinian territory, which prevented humanitarian workers from communicating with each other. Hospitals in Gaza are under constant attack, and the medical staff on the ground face daily threats. The Kamal Adwan hospital was bombed in December 2024, killing five healthcare workers[5] and arresting medical staff who refused to leave their patients, a direct violation of international humanitarian law.

4.       Physical access to provide humanitarian services

4.1.             A lack of adherence to international humanitarian law through direct attacks on civilians has an impact on humanitarian provision. Attacks on civilians cause an increase in demand, necessitating more humanitarian workers to work in dangerous and difficult conditions. This puts them at greater risk of harm themselves. For example, women’s rights organisations have told ActionAid about a lack of safety meaning that a “volatile security situation hinders us to go and work at local level and meaningfully respond to the situation”[6]

4.2.             In the occupied Palestinian territory, despite an increase in need for humanitarian services and basic supplies, trucks carrying essential goods are denied entry at border crossings by the Israeli state. Aid convoys and food distribution activities are even targeted by Israeli air strikes, killing humanitarian workers and civilians. Hindering humanitarian access to Gaza is a clear violation of international humanitarian law. Under international humanitarian law, the Israeli state has obligations to provide the basic needs of the people of the occupied Palestinian territories.

5.       Granting formal access to humanitarian organisations

5.1.             The decision to grant certain actors humanitarian access and withhold it from others needs to be agreed by all parties concerned and therefore the decisions are often political  and impacts the conflict itself. States and multilateral bodies grant humanitarian access by establishing relief corridors and humanitarian pauses during conflict to allow for humanitarian access.

5.2.             By being granted humanitarian access, organisations can be seen as more authoritative by the international community and are able to receive more funding and support[7]. Conversely by having access denied, organisations can be seen as less legitimate, despite any previous successful work and are unable to deliver crucial humanitarian supplies; the requirements that lead to be granted access can be impractical and contrary to providing aid[8].

5.3.             Furthermore, this perpetuates a cycle where organisations which do not have established political recognition, find the requirements to be granted access unachievable, and then do receive the legitimacy to take part in high-level decision making-spaces. ActionAid sees this dynamic frequently with women’s rights organisations and women-led organisations being shut out from key decision-making spaces and are less able to advocate for the needs of women and marginalised groups impacted by humanitarian crises.

5.4.             For example, ActionAid research with women’s rights organisations and youth groups in Uganda found that only 24% of respondents felt that they had enough engagement with international humanitarian actors during conflict emergencies[9]. The lack of engagement led to a lack of access to crucial peacebuilding spaces, a lack of access to information and ultimately an inability to access opportunities and funding. This is another way that humanitarian access is impacted by the dynamics of working with donor states such as the UK.

5.5.             Even once humanitarian access is granted, there are challenges in delivering humanitarian operations - for example, bureaucratic measures that delay or stall delivery or states imposing sanctions that prevent the purchase of supplies and resources. ActionAid staff in the occupied Palestinian territory shared that “obtaining essential items inside Gaza is difficult since little is available on the market and prices are hugely inflated.[10]” The Palestinian NGOs Network (PNGO), an umbrella organisation of 30 Palestinian NGOs and a partner of ActionAid, reported that the shortage of humanitarian supplies has led to people starving. In Myanmar, the military has used so-called security and bureaucratic measures to obstruct the delivery of aid, adding to requirements to obtain approval to travel and inspections at security checkpoints[11].

6.       Registration of humanitarian organisations

6.1.             In certain contexts, the state or de-facto authorities can set regulations for organisations to require registration to work and deliver humanitarian assitance. This can cause significant issues, especially where authorities are hostile to civil society or where registration requires or implies alignment with the authorities.

6.2.             Registration of humanitarian organisations is a particular problem in Myanmar, where some organisations are unable to become formally registered with the junta, and others have refused to do so. The Organization Registration Law (ORL) was enacted by the State Administration Council (SAC) in October 2022 and imposes stringent controls over civil society and humanitarian actors. This inhibits a lot of their work and significantly impacts the ability to provide humanitarian support.

6.3.             Meanwhile, the humanitarian need is incredibly high following bombing of civilian areas and targeting of civilian infrastructure in areas such as Northern Shan state. There is, therefore, a significant gap between the needs of affected communities and humanitarian access to them.

6.4.             International donors, including the UK, can also require organisations to be registered with the junta in order to receive funding, putting them at significant security and safety risks[12]. Many women leaders in Myanmar have cited that their work has been hindered by the lack of access to humanitarian spaces. Furthermore, remaining ‘neutral’ in Myanmar is seen as akin to aligning with the SAC[13].

6.5.             In the occupied Palestinian territory, as of December 2024, the Israeli government has also introduced new restrictions on humanitarian organisations[14] by approving legislation designed to deny registration and work visas to international NGOs whose “main activity” is to “provide assistance for the social welfare of Palestinian residents.” The impact of these restrictions has not unfolded yet but there are concerns that the restrictions are framed broadly which would make it easy to target specific organisations, specifically any who have criticised the Israeli government’s policies. This also could create additional administrative burden and ultimately makes it more difficult to deliver life-saving humanitarian assistance.

7.       Violations of international humanitarian law in Gaza

7.1.             In Gaza, there have been further violations of international humanitarian law including through attacks on residential areas, including shelters housing multiple families, with dozens of people killed in single incidents. As of 14th January 2025, the official death toll reached 46,645[15].

7.2.             There have been continuous attacks on humanitarian workers by the Israeli military. The UN Secretary General has remarked on the blockages of humanitarian assistance and the Israeli government’s failures to respect international humanitarian law[16]. The actions of the Israeli state could also be interpreted to have violated the ruling of the International Court of Justice (ICJ in its provisional measures, which demanded that the Israeli government take immediate action to prevent genocide and uphold its obligations under the Convention on the Prevention and Punishment of the Crime of Genocide. One of those provisional measures focused on facilitating humanitarian aid “The State of Israel shall take immediate and effective measures to enable the provision of urgently needed basic services and humanitarian assistance to address the adverse conditions of life faced by Palestinians in the Gaza Strip”[17].

7.3.             Despite the clear ruling from the ICJ, the provision of essential assistance (e.g. food, water, electricity, fuel, shelter, clothing, hygiene, sanitation, medical supplies and healthcare) has fallen below the minimum required to sustain life—see box 1. This has a specific impact on women and girls who require more water and menstrual care products during their menstrual cycle, more food and water during pregnancy and breastfeeding and specialised healthcare throughout their life.

7.4.             There has been systematic denial and restriction on the delivery of aid supplies into Gaza. Vital supplies entering have dropped to dangerously low levels: At least 10,000 trucks per month were the bare minimum needed to supply 2.2 million Palestinians living in the Gaza Strip (500 per working day). In the month with the highest entry of humanitarian supplies (April), just under 5,700 humanitarian trucks were able to enter. Since then, there has been a steady and systematic decline, dropping to only 1,830 in December 2024.  However, merely counting the number of trucks dropped at the border is inadequate to assess whether affected populations actually received sufficient aid.

7.5.             In December, restrictions on humanitarian supplies being delivered was due to delayed approval to enter and confiscation of crucial lifesaving supplies by Israeli soldiers. The Israeli military has also launched targeted attacks on humanitarian workers during food distributions, killing civilians waiting for food, aid workers and their families.

7.6.             While Israeli authorities frequently announced the opening of new crossings, these declarations were often reversed and rarely sustained in practice, with functional capacity remaining heavily suppressed. While operational hours were severely constrained, aid trucks could only access the crossings sporadically, as opening days were limited. 

7.7.             As a ceasefire deal is delivered it is vital that immediate humanitarian access is provided to all areas of Gaza, otherwise the impact of UK funding will continue to be limited. The UK must use all diplomatic levers to urge the Israeli government, as its stated ally, to adhere to international humanitarian law. As an occupying power, the Israeli government has an obligation to allow and provide aid to people within Gaza

8.       Humanitarian access for services for women and marginalised groups

8.1.             Humanitarian access cannot be considered suitable if the services do not reach specific sections of the population, or do not serve the needs of certain demographics. Women-led organisations who use a Human Rights Based Approach[18] and are proximate to the humanitarian crisis are able to reach marginalised and at-risk groups. These groups are able to consider the needs of marginalised groups and centre them in their humanitarian response.

8.2.             ActionAid knows from our work in many contexts that women face increased risks of violence in emergencies. For example, women-led organisations in Gaza have reported a rise in cases of gender-based violence and increased demand for their services, at the same time as survivors lack access to justice due to the collapse of the legal system amid the ongoing war. 

8.3.             Humanitarian operations that are not gender-sensitive do not provide the required services that are needed by women and girls. For example, many humanitarian actors deprioritise sexual and reproductive health services and do not consider this as essential within their healthcare provisions[19]. In Myanmar, women and girls have struggled with access to sexual and reproductive health and mental health services, partly due to the restrictions of goods and services to certain regions by the military regime.

8.4.             This has also been seen in Ukraine. ActionAid’s partners have reported that donor funding does not provide for sexual and reproductive health services which means that “in regions near active conflict, medical personnel and medications may be absent or difficult to access.”[20] An ActionAid policy report found that this lack of sexual and reproductive health services has had a particular impact on pregnant women, and trans and intersex people[21].

8.5.             Access to vital and urgent humanitarian support required by women are not prioritised. Even when services exist providing protection, mental health & psychosocial support, and sexual and reproductive health, they are often not adequate to serve the needs of women. For example, women’s protection is drastically underfunded even in contexts such as Ukraine where funds for food security and education are mostly fully funded[22].

8.6.             Women’s rights organisations and women-led organisations are at the frontline of humanitarian response and the staff within these organisations are impacted by the humanitarian crisis itself. Shortcomings in access to healthcare, access to mental health and psychosocial support services, protection services and physical safety, affect aid workers and the community as a whole.

9.       The UK’s commitments to humanitarian access

9.1.             Humanitarian access is not just impacted by the adherence (or lack thereof) to international humanitarian law. How donors such as the UK choose to fund the humanitarian sector has an impact on organisations’ resources, staff retention and therefore sustainability[23].

9.2.             When local organisations do not have dedicated and reliable core and flexible funding, they cannot maintain organisational stability and their ability to deliver humanitarian aid is affected. A survey of ActionAid partner organisations showed that 65% of respondents found international donors’ processes are too bureaucratic and are not fit for purpose for humanitarian response and the quick delivery needed to effectively deliver humanitarian support[24].

9.3.             This is despite the important role that these organisations play. ActionAid knows from its work that women’s rights organisations support communities in conflict-affected contexts, even in areas that are inaccessible to international organisations[25]. Women’s rights organisations are among the most effective humanitarian aid agents and so it crucial to resource them.

9.4.             The UK government has made a series of commitments through the Grand Bargain, UN Security Council Resolution 1325 and the Women, Peace and Security – Humanitarian Action (WPS-HA) Compact. The UK has also established these into successive National Action Plans on Women, Peace and Security[26] which lay out their commitments, plans to implement them and their achievements so far. These commitments should shape how the UK government engages with organisations delivering humanitarian response and how it supports their humanitarian access.

9.5.             The Grand Bargain commits the UK to engaging with local civil society organisations, in particular women’s rights organisations and women-led organisations. As a signatory, the UK must push for sector-wide transformation and participation, to support more effective humanitarian response[27]. In the Grand Bargain, the UK joined other signatories in agreeing to a 25% target for humanitarian funds being shared with local actors[28]. Globally, only 0.75% of humanitarian funds in 2024 went directly to local and national responders, with the UK not much better[29]. Frontline women’s rights organisations receive only 0.2% of total bilateral aid globally[30], which reflects the UK’s funding practices. In 2021, only 0.2% of UK ODA (£14.8m) went to women’s rights organisations and movements[31]. Funding for women’s rights organisations must be ringfenced within humanitarian spending.

9.6.             The UK’s approach to the International Criminal Court (ICC) and the ICJ must be consistent and supportive of international humanitarian law. Where the ICC brings cases and issues arrest warrants and the ICJ issues advisory opinions and rulings, the UK must always centre human rights, the rights of women and girls and of marginalised people. On multiple occasions the UK has affirmed the independence of the ICJ[32] and showed support for the ICC, even stating that the UK has “committed not to vote against any credible draft resolution [at the UN Security Council] intended to prevent or halt mass atrocities”[33]. However, the UK has abstained on votes on the ICJ’s Advisory Opinion on the Israeli government’s presence in the occupied Palestinian territory.[34]  We encourage the UK to support the ICC and ICJ in their efforts towards accountability.

10.   Funding challenges affecting humanitarian access

10.1.          The ability to receive adequate funding is also a major component of humanitarian access. A prominent example was the suspension of funding for the UNRWA by the UK and others in January 2024[35], at a time when need for aid was at its highest. Since then, the Israeli parliament has also attempted to ban UNRWA from operating within land occupied by the Israeli state. Both of these actions greatly affect humanitarian access as UNRWA’s activities were constrained. The UK has since reinstated funding for UNRWA, which ActionAid has welcomed.

10.2.          In Uganda, ActionAid’s research found that only 4% of women’s rights organisations received any form of long-term grants[36], which makes it difficult to deliver sustainable and long-term support in humanitarian contexts, including post-conflict contexts. This has an impact on aid workers who are working on the frontline but then do not have the structural support or job security to continue their work. Furthermore, without long-term and flexible funding, mental health and psychosocial support services cannot be provided to humanitarian workers.

10.3.          In Myanmar, respondents to ActionAid’s research reported that they have to provide services and undertake activities without sustainable budget—putting a massive strain on humanitarian workers. When funding is available, it is too slow and inflexible for a rapidly changing conflict-affected context[37]. According to the Myanmar Humanitarian Needs and Response Plan 2025, the context is one of the world's most underfunded humanitarian responses[38], with only 24% of the required funding received.

10.4.          The humanitarian crisis in Ethiopia is underfunded by over US$3 billion[39] according to estimates by the Ethiopian Humanitarian Response Plan 2024, and this has been flagged as a major issue by local humanitarian aid providers that ActionAid works with[40]. In ActionAid’s research[41], women’s rights organisations and youth-led organisations who provided humanitarian assistance and supported the needs of displaced communities, cited “a lack of facilities, insufficient budgets, and scarce long-term funding” and donor funding that requires time-consuming admin.

10.5.          Donor requirements from the UK have been cited by ActionAid staff in many countries to cause considerable issues. These have created barriers to accessing funding, impacting community trust and at times risking their security by requiring them to register with repressive governments. The organisations who are most able to adhere to donor restrictions are not necessarily the organisations who are best placed and skilled to deliver quality humanitarian services.

8