Over recent years and despite increasing humanitarian needs in many contexts, bureaucratic and administrative impediments (BAI) have significantly curtailed the ability of frontline humanitarian NGOs and increasingly UN agencies to provide humanitarian assistance to affected people in a safe and unfettered manner. Recognizing the importance of tackling this worrying trend in a collective, proactive, and systematic manner, the IASC’s Results Group 1 on Operational Response (which addresses system-wide issues to enhance operational response) undertook extensive research on the issue including through four country case studies (Myanmar, Nigeria, Venezuela and Afghanistan) to inform a draft framework to guide efforts by Humanitarian Country Teams (HCTs) to overcome BAI.   The HC dialogue was an opportunity to discuss the challenges and opportunities identified through this effort and to seek HCs’ perspective including on areas that require more focus, including to support their leadership role.


  • Reena Ghelani, chair of the IASC Emergency Directors’ Group (Facilitator)
  • Eddie Kallon – Resident/Humanitarian Coordinator. Nigeria
  • Osnat Lubrani – Resident/Humanitarian Coordinator- Ukraine
  • Clémence Caraux-Pelletan, Director of the INGO Forum in the DRC
  • Kathryn Striffolino, Senior manager for humanitarian practice at InterAction and Lead Researcher on the BAI report

The following key points were highlighted:

  • BAI is a system-wide concern which is growing in humanitarian and development contexts, and which takes up the attention, time, and resources of operational partners and RC/HCs.  In the last two years, BAI may have been exacerbated by COVID measures.  While in the past, the issue was primarily affecting NGOs, it is increasingly impacting UN agencies as well.  Collective action is essential to avoid divide and rule and single agency agreements which set precedents.
  • While BAI is negatively affecting timely, effective and principled humanitarian response in most cases, there are cases when BAI can be positive. Additional administrative requirements imposed by national authorities to mitigate PSEA for instance should be welcomed.
  • While HCs, the ERC, and the broader IASC (including through a dedicated workstream under ‘results group 1”) are prioritizing the issue through a collective approach, dedicated field capacity to better understand BAI and a more consistent engagement by all HCT members is required including through better information sharing and analysis of BAI trends and opportunities to address them.   
  • In order to be effective, approaches to address BAI need to be anchored in a sophisticated understanding of the motivations behind them.  Motivations may include distrust and suspicion of humanitarian organizations by host governments and/or non-state armed groups (sometimes legitimately based on past experience), attempts to boost government revenues, rent-seeking behaviors by individual actors, disruption or prevention of humanitarian access to specific populations or locations, and institutional gaps in administrating humanitarian organizations.  Each of these drivers require specific approaches.  
  • Counter-terrorism settings often provide more challenging BAI environments, and lead to greater suspicion of humanitarian actors.  These settings demand high levels of transparency and robust due diligence. 
  • Approaches to address BAI need to be balanced: In some contexts, the political engagement and behavior of the international community (including imposition of sanctions; counter-terrorism legislation etc..) leads to BAI.  This needs to be recognized and addressed in a systematic way including through high-level advocacy, for instance, to standardize exemptions and/or other financial and administrative requirements by donors.
  • Trust building is a critical part of addressing BAI and requires authorities and other stakeholders understanding and respecting humanitarian principles, and humanitarian partners consistently understanding and respecting the national rules and regulations.  It is important not to assume that all actors understand humanitarian principles or international humanitarian law, and to recognize that systematic educational efforts are required when ministers or other key actors are changed.                                                                                                           
  • Identifying threats and risks that could cause a deterioration in BAI is key to a more systematic, collective and coordinated approach to addressing BAI. Early action is also critical to establishing monitoring and alert systems that identify issues before they become more systematic. 
  • The role of the RC/HC is critical to guide a collective effort, build/rebuild trust with relevant authorities, open doors and create space for dialogue for operational humanitarian agencies to engage.  In some cases the RC/HC may need dedicated legal capacity in their office to properly address BAI issues.
  • Donor engagement needs to be carefully considered and timed.

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