Written evidence submitted by Asia Displacement Solutions Platform (AFG0014)


1. Introduction

1.1 The Asia Displacement Solutions Platform is a joint initiative of the Danish Refugee Council (DRC), International Rescue Committee (IRC), and the Norwegian Refugee Council (NRC), which aims to contribute to the development of solutions for displaced populations. Drawing upon its members’ operational presence throughout Asia, the ADSP engages in evidence-based initiatives to support improved outcomes for displacement-affected communities. As implementing agencies, ADSP members work closely with displaced populations and host communities, and are therefore able to contribute a distinctive, field-led, perspective to policy and advocacy processes which can sometimes be removed from the realities on the ground.


1.2 ADSP members are submitting this evidence to highlight the dire humanitarian situation in Afghanistan, since the Taliban became the nation’s de facto governing authority on 15 August 2021. Whilst there were significant humanitarian needs prior to the Taliban takeover, the situation for vulnerable groups including women and girls, as well as religious and ethnic minorities, has worsened throughout the country since mid-August.


1.3 As three of the largest operational humanitarian and protection actors in Afghanistan, DRC, IRC, and NRC consistently engage with communities and local partners. It is essential that the voices of women and displaced persons reach policymakers, donors, and governments so that they can contribute to the discussions that impact their lives.


2. What are the humanitarian implications of the Taliban takeover?

In recent years, Afghanistan has been hit by compounding humanitarian crises – natural disasters such as droughts and flooding, the COVID-19 pandemic, the start of possibly one of the largest migration crises in our lifetime, and economic conditions that are placing millions of Afghans in positions of precarity. According to the United Nations recently updated Flash Appeal, approximately 18.4 million people – nearly half of Afghanistan’s population – need urgent humanitarian assistance. In addition, staff in the field are reporting increases in vulnerability due to lack of access to job markets, unpaid salaries of government employees, and high inflation of the local currency.


Since the Taliban takeover, ADSP members are working to respond to a wide range of humanitarian implications. These include the assistance needs of displacement-affected communities - many of whom face severe food insecurity and are lacking access to healthcare and other key services. Delivery of humanitarian assistance has become even more difficult due to the changing context. Principled humanitarian access now requires complex negotiation, there is an ongoing financial liquidity crisis preventing meaningful scale of response programmes and the rights of women and girls are now increasingly challenging to uphold.




2.1 Humanitarian access

2.1.1 The operating environment in Afghanistan has changed drastically over the past few months. The UK Government must ensure that humanitarian operations continue to be safe, timely, unhindered, and principled, and adhere to the four basic precepts which define our work – humanity, neutrality, independence, and impartiality. ADSP members are committed to the meaningful participation of female staff as essential to our work. It is within this lens that there is a real opportunity for engagement and influencing of policy, both domestically and by the UK towards the Taliban, in relation to humanitarian activities in Afghanistan.


2.1.2 There has been a decrease in active fighting since the Taliban takeover - a reprise welcomed by local communities and humanitarian organisations alike. That being said, violence and threats towards humanitarian staff, assets and facilities is ongoing. Multiple NGO compounds in Kabul, and across the country have been occupied – some by the Taliban directly, others by those claiming to be Taliban. As NGOs are known to have larger amounts of cash on the premises, generally obtained via the hawala system, there is an increased risk of looting or thefts. Several NGO compounds have already been targeted, including immediately after receiving deliveries of cash.


2.1.3 In early September, the Taliban announced the formation of its government, with subsequent appointments made in the following weeks. However, on a functional level, many ministries lack the staff for basic day-to-day operations. This is partially due to fears by former government officials, many of whom will have tried to leave the country. In practical terms, the internal policy of each ministry is likely to be reviewed and revised by the relevant minister before operations fully resume. This will likely lead to delays in bureaucratic procedures, resulting in bureaucratic access impediments. In addition, power struggles between ministries are anticipated to lead to a disordered bureaucratic landscape whereby national-level decisions may not be enforced or acknowledged at the sub-national level. Already there have been changes in how NGOs are dealt with, as some areas, either officially (such as Kandahar) or unofficially, have made the role of NGO Commissioner defunct. Across the country, the role of Governors, the Ministry of Economy and the Ministry of Refugees and Repatriations will become increasingly important for access.


2.1.4 As noted, kinetic activity decreased as the Taliban gained military control of the country, however, while the security situation is relatively stable at present, this could likely change. Anti-Taliban groups continue to clash sporadically and are engaged in much the same tactics as the Taliban in preceding years. Moreover, large swathes of the country remain contaminated - there have been numerous improvised explosive devices (IEDs) placed during the conflict, predominantly in the south-east of the country along roads and targeting Taliban affiliates.


2.1.5 In addition, the role and potential attempts to expand the area in which Islamic State in Khorasan Province, ISKP (ISIS-K) operate should not be discounted. Aside from the major attack on Kabul International Airport in August in which over 150 civilians were killed, there has been other activity by the group. The ability of the Taliban to keep control over the country remains to be seen, with some analysts predicting a further fracturing of control and rise in conflict. Currently however, there has been a positive improvement in the security of roads, with an increased potential for humanitarian organisations to use roads to transport personnel, goods, and assets.


2.1.6 Looking at the access situation in and out of the country, the United Nations Humanitarian Air Services (UNHAS) has established an airbridge from Islamabad, although the process of acquiring Pakistan visas has been difficult. The process to renew or obtain new Afghan visas is starting to reopen. Unlike the past, currently visas must be obtained inside Afghanistan with no options to get them from embassies or consulates abroad. While the Taliban seem to understand the need for humanitarian organisations to operate in Afghanistan, there is potential for future restrictions on the number of international staff allowed to obtain visas.


2.2 Displacement

2.2.1 According to the UN Office for the Coordination of Humanitarian Affairs (OCHA), more than 665,000 individuals have been internally displaced by conflict since January 2021. Whilst 20-25% of this number have anecdotally returned to their places of origin in recent weeks, humanitarian needs such as food, shelter and health remain high.


2.2.2 As of 9 October 2021, there has not been any official large-scale movement of Afghans to neighboring countries, with UNHCR determining there to be only 11,650 new arrivals in Pakistan, 5,420 in Tajikistan and 22,750 in Iran. However, NGOs continue to receive reports of significant numbers of Afghans crossing irregularly into Iran, with estimates of 30,000 individuals crossing each week. Of this number, it is estimated that 25% of families are headed by women, and 41% are from the Hazara ethnic group. Approximately 30% of arrivals also came without identity documents.


2.2.3 The relatively small degree of official cross-border displacement is likely due to securitisation and an almost complete closure of border-crossings to civilian traffic – except in limited instances for those with valid travel documents and visas. In addition, the fact that many Taliban-manned checkpoints are in areas and roads leading to border-crossings, has likely further deterred individuals – particularly those from persecuted religious and ethnic minority groups - from attempting to cross to other countries.


2.2.4 Since early 2021, research bodies such as the Mixed Migration Centre (MMC) Asia have reported a growing reliance by Afghan migrants and refugees on smuggler services. Attempting to navigate increasingly policed and militarized borders, as well as the closure of land crossings and cessation of consular services across the country, many individuals are being forced into precarious modes of travel.


2.2.5 As part of scenario-planning processes, and in preparation for potential large-scale movements, the UN and partners continue to pre-position humanitarian supplies in neighboring countries. However, despite this pre-positioning, many within the international humanitarian community are currently burdened by bureaucratic impediments and access limitations such as challenges in registration and delays in obtaining approvals in neighboring countries. This has precluded many organisations from effectively establishing and/or scaling-up their regional presence, in anticipation of future refugee movements.


2.2.6 According to OCHA, in September more than 3.8 million people received food assistance. With less than two million out of the nation’s 38 million population deemed to have enough to eat, needs are high. As food and drinking water are the top two priorities identified by IDPs, food insecurity and drought will continue to perpetuate displacement and delay safe and voluntary returns.


2.2.7 Since the Taliban takeover, the number of households having to resort to three or more ‘distress coping mechanisms’ has doubled from 32 to 65 percent. Food insecurity represents an immediate threat to the lives of Afghans, especially as winter is looming and the country is in the midst of its second drought in four years. If not addressed immediately, large numbers of people may be forced to flee in search of basic services.


2.3 Financial liquidity

2.3.1 Immediately following the Taliban’s rise to power, Afghanistan experienced a range of compounding financial challenges that have had far reaching impacts on people’s lives. With the World Bank, the International Monetary Fund, and the United States central bank cutting Afghanistan’s access to international funds in the immediate aftermath of the takeover (estimated at USD $10 billion) - and most banks in the country subsequently temporarily closing - many Afghans have been struggling to survive. While many banks have since reopened, there remain weekly withdrawal limits of $200 USD. This has resulted in hundreds of people routinely queueing outside banks to withdraw funds.


2.3.2 For most humanitarian organisations, financial liquidity has also been a challenge. Many organisations have come to rely upon hawala agents to bring money into the country for salary payments and vital services. However, hawala agents are also struggling to meet demand. With many agents charging commissions of 8-12%, the use of hawalas is not sustainable and constitute significant budgetary complications for organisations. Without more cost-effective options, some organisations will struggle to maintain operations.


2.3.3 At the 13 September 2021 UN-organised conference on Afghanistan, dozens of donors committed a total of nearly USD $1.1 billion dollars in humanitarian support. The United Kingdom pledged £30 million out of an existing £286 million for regional stability and support to refugees. Whilst such commitments are laudable, it is essential that all committed funding is accessible immediately within Afghanistan and neighboring countries. At present global humanitarian funding equating to approximately 40% of the country’s GDP is on-hold. Safe, efficient payment channels are crucial for sustaining humanitarian operations, as well as clear exemptions from any “restrictive measures,” including sanctions.


2.3.4 The ongoing inability to access cash has had significant impacts on humanitarian organisations’ ability to operate. Many ADSP members’ local partners are at risk of shutting their doors due to an inability to pay staff. Many staff of local and international NGOs have also left or intend to leave Afghanistan. This has caused issues in knowledge management, as well as practical issues in accessing funds. The lack of cash is also causing worrying delays in the implementation of humanitarian interventions, as well as an inability to effectively plan activities. One local implementing partner noted that “the cost of basic food items has gone up, and this has affected our daily lives’ significantly. On top of this, we are concerned about the physical safety of women and girls in our organisation, and their basic rights”. They also mentioned that “job security no longer exists. As a sole provider for my family, losing my job means my family cannot eat.”






3. Ways the UK can support those at risk, particularly women and girls

3.1 Since the transfer of power to the Taliban, the international community and humanitarian organisations have raised concerns for the immediate and long-term rights and welfare of women and girls. From an organisational perspective, humanitarian actors require female staff to access communities and to ensure that all elements of society can access services and immediate life-saving support.


3.2 To date, assurances that female aid workers can return to work have differed from province to province and sector to sector. There is no blanket approval for female staff, nor does it look like there will be in the near future. In some areas, female aid workers can only work remotely. Should organisations be compelled to proceed without on-the-ground female staff, a dangerous precedent may be established i.e. that gender disparities are further entrenched and that ad hoc regulations for women to work are created.


3.3 Female staff are a vital part of the humanitarian response to ensure that the entire target population can be reached, especially women and children. In many provinces, the current refusal to allow female staff to return to work is causing delays to resumption of programmes, yet organisations are facing increasing pressure to resume activities.


3.4 Across the humanitarian sector, female staff have raised and continue to highlight a range of issues of concern. Some key issues include:

-          female staff in leadership positions worry about their inability to represent their organisations in key forums

-          many do not feel that permissions granted by the Taliban for women to work have been shared widely, and as such many still feel at risk going to the field; and

-          women in roles that include assessments and house visits feel particularly at risk.


3.5 The treatment, and allowance of female staff to work is a test case for how women will be treated more broadly in the country. Failure to ensure their right to continue working is a negative indicator for women’s rights in general.


3.6 Especially in more conservative parts of the country, it may only be appropriate for a woman to engage with another woman both in terms of needs assessments and also programmatic interventions. Should women not be allowed to engage, then there is a risk that half of the country’s population may not be served.




















4.1 As humanitarian organisations gradually resume operations, it is essential that they have adequate and consistent humanitarian access. The UK Government should leverage their diplomatic engagement to advocate for access. In addition, the UK should support partners to engage in ongoing principled humanitarian access negotiations, including by supporting operating and staff costs while negotiations are undertaken, providing funding for qualified access staff, and ensuring funding flexibility.


4.2 Financial liquidity and access to funds remains a considerable challenge for humanitarian organisations and everyday Afghans following the freezing of assets by international actors. Many humanitarian agencies are continuing to explore appropriate options to pay staff, procure goods and services, and provide relief to communities. Many humanitarian actors have utilised the services of hawala agents; however, commission rates vary across agents ranging from 8-12%. This fee has significant budgetary implications for organisations, and takes money away from communities that need it most. The UK Government should push for funding flexibility, and to work with relevant stakeholders to support fixed pricing for hawala services, as well as ensure humanitarian considerations and subsequent exemptions are made if exploring the use of restrictive measures. Furthermore, the UK needs to step up efforts to agree with the US Treasury an urgent solution to the liquidity crisis which can allow aid agencies and the civilian population to access adequate cash to purchase basic goods and services needed for the populations' survival.


The UK should also use the platform of its presidency of the G7 to urgently push key World Bank shareholders to repurpose the existing Afghanistan Reconstruction Trust Fund (ARTF) (the largest and longest-standing single country multi-donor trust fund managed by the World Bank on behalf international partners) to ensure critical support to life-saving health and other services can resume. Alternative governance, allocation and disbursement mechanisms have already been proposed which should allow the World Bank and its Board to agree to a resumption of urgent funding without delay.


The UK should work with the UN Development Fund (UNDP) to accelerate agreement for an appropriate multi-partner trust fund to address critical needs, particularly in light of the slow progress to date in relation to the ARFT). The trust-fund should seek to work with NGOs to fill immediate gaps in the delivery of health, education, and other critical services in priority locations across Afghanistan.


The UK government should work across departments to ensure its sanctions policies do not undermine its humanitarian aid efforts in Afghanistan, in line with UN Security Council resolution 2462. It is essential that the Office of Financial Sanctions Implementation (OFSI) urgently issues its promised guidance to aid agencies and banks in support of principled humanitarian action.


4.3 ADSP members and others have experienced some success in negotiating principled humanitarian access with the Taliban, including allowances for female staff to return to work unimpeded. However, significant challenges remain for the humanitarian community to fully resume and scale-up operations. As such, we strongly encourage the UK Government to reinforce NGO’s messaging on the importance of the humanitarian principles, including the immutable requirement for humanitarian actors to adhere to them.

4.4 While we have not witnessed a visible influx in cross-border movements, the humanitarian community continues to pre-position and prepare for such influxes. It is recommended that the UK support UNHCR’s Supplementary Appeal, which seeks to ensure that refugees from Afghanistan in neighboring countries are supported accordingly. Furthermore, despite not being a core member of the Support Platform for the Solutions Strategy for Afghan Refugees – as the only existing sub-regional framework – the UK Government should offer support to ensure that the SSAR’s vision and operational framework are realised.


4.5 ADSP members reiterate the absolute need for the unimpeded movement of humanitarian goods and personnel throughout Afghanistan. We request the UK Government to advocate for and work collaboratively towards a humanitarian response where all humanitarian personnel – male and female equally - can perform their work.


4.6 ADSP welcomes the decision by the UK Government to offer an additional 20,000 resettlement spaces through the Afghan Citizens’ Resettlement Scheme (ACRS). However, given the pressing humanitarian concerns, in addition to the millions of Afghans displaced in neighbouring countries, it is recommended that the UK Government increase this number substantially, as well as explore complementary pathway opportunities – particularly for women and girls, and religious and ethnic minorities.


4.7 ADSP members believe that women in Afghanistan must be allowed to work regardless of their sector of employment, and that girls must be allowed to continue their schooling. The UK Government should continue advocating for the rights of women in all fora and ensuring that adequate funding is available to support women and girls in Afghanistan.


4.8 There is a need for continued triple-nexus funding in Afghanistan (humanitarian - development - peace) to build the foundations for sustainability and resilience. The UK Government should provide multi-year nexus funding to allow organisations to make programmatic interventions that break cycles of aid dependency.



















15 October 2021