26th November 2024
Since the beginning of the full-scale invasion by Russia in 2022, the humanitarian crisis in Ukraine has become one of the largest in the world. Local organisations have naturally served as first responders and work tirelessly, providing critical support to their communities. Many of these actors have rapidly expanded their capacities to address immense humanitarian needs, with staff and volunteers working relentlessly without electricity, heating or internet while facing the risks of airstrikes, burnout, and emotional exhaustion.
“Localisation” remains a hot topic, driven by strong voices from Ukraine’s diverse, well-established civil society. Despite their critical role in the response, local actors point out that they receive only a fraction of the funding, face excessive bureaucracy, and are often excluded from decision-making. In my personal view, many ‘localisation workshops’ are led by international actors who, despite frequently using terms like ‘partnerships’ and ‘capacity building’, can often fail to genuinely support locally-led responses.
Due Diligence as the Hot Topic of the Day
One of the top buzz phrases as part of the localisation agenda is ‘Due Diligence Passporting.’ While it may seem surprising that a niche, compliance-focused topic that few non-technical people had heard of could spark such debate, it highlights the tensions in ensuring a fair and effective partnership framework.
For those unfamiliar with the topic, Due Diligence is essentially an assessment of a local partners’ organisational capacity that evaluates the legal, financial, operational, and ethical practices to ensure accountability, compliance, and alignment with donor requirements.
Many local organisations express profound frustration with the bureaucratic barriers, high thresholds for accessing funding, and standardised Due Diligence requirements (see the open letter to international actors) and the call to “simplify and standardise requirements” from colleagues at Philanthropy in Ukraine.
These discussions recur in nearly every localisation meeting in Ukraine and appears frequently in reports, including the Localisation Baseline and similar studies. The debate on Due Diligence continues to gain momentum among the humanitarian community. After all, it highlights a broader issue: the lack of space for local leadership and meaningful participation.
The Impact on Civil Society
The high thresholds and often repetitive procedures have exacerbated ongoing developments within Ukraine’s civil society. This includes a polarisation of funding among national organisations with greater capacity, whereas smaller, grassroots, often youth-led, or women’s rights organisations, struggle to navigate the donors’ complex processes.
Some local actors try to adapt to this by prioritising meeting procedural standards rather than organically building capacity, sometimes with the support of their donors. However, there is a risk that this increased ‘Due Diligence capacity’ might turn what could be meaningful capacity assessments into box-ticking exercises.
Exhaustion and burnout are another issue – I’ve found that many first responders lack adequate financial and capacity support, making it challenging to work sustainably and healthily. Undergoing the same assessments over and over again, sometimes without a promise of funding, further reinforces donor-beneficiary power imbalances and increases the strain on actors that do most of the heavy lifting while being most at-risk.
Finally, local actors are increasingly frustrated with the perceived unwillingness or inability of international agencies to adapt processes, provide capacity-strengthening, or genuinely involve them in shaping the localisation agenda, where they should be central.
International Responses, in Ukraine and Beyond
International agencies have attempted to address these challenges within the limits imposed by institutional donors, though with limited success. Some organisations have focused on Due Diligence certification and passporting, harmonising processes with other agencies, and adapting global tools to the Ukrainian context, which are all great first steps.
Globally, initiatives such as from Collaborative Cash Delivery Network (CCD) are under way and are focusing on generating evidence around the topic, advocating with donors internationally, and pioneering alternative ready-to-use tools in the Turkiye-Syria Earthquake Response, and now also in Ukraine. Colleagues from Humentum developed the Charter for Change Due Diligence Passporting Tool as an adaptable option for other organisations. Other tools and studies are on the way.
Finally, in Ukraine, the “Reverse Due Diligence” (or donor assessment) is something that has been pioneered by the Ukrainian organisation NGO Resource Center (NGORC) in attempt to reverse the power dynamics, increase transparency and upwards accountability.
Ukraine’s Due Diligence Task Force
In Ukraine, ActionAid and eight other organisations formed a ‘Due Diligence Task Force’ under the Humanitarian NGO Platform, where colleagues from different agencies meet bi-weekly to discuss, share experiences, and advocate for local partners’ concerns.
Key outputs of the Due Diligence Task Force so far include a harmonised vocabulary of terms like ‘certification’ and ‘passporting’, a comparative analysis of tools showing that over 80% of content is similar, a database of local partners, and an informal information-sharing network.
With support from the Disaster Emergency Committee, the Task Force’s work will continue until late 2025, to deepen networks, engage more stakeholders at both the Ukraine and global levels, and increase the buy-in of senior decision-makers to adapt some of their Due Diligence processes and practices. This also includes more advocacy with donors who could push for Due Diligence Certification as a mandatory requirement.
A Call to Action
The Task Force has proven that International NGOs can make a big difference with some simple steps. Adapting and aligning Due Diligence tools with other organisations can make processes easier without lowering compliance standards. A basic certification approach – accepting assessments from other international donors (with partner approval), can greatly cut down the workload.
INGOs should also end the practice of withholding assessment results – sharing assessment findings allows local actors to make informed choices about capacity-strengthening and even challenge the assessment if needed. Perhaps strict institutional rules and strong institutional capacity might not even be needed (or desirable) for every small, local, youth-led or rights-based organisation.
As INGOs, we continuously face the dichotomy of acting as both donors and partners to local organisations. At ActionAid, we recognise that financial relationships inherently create power dynamics that cannot be ignored. While we strive to be partners (and often like to label ourselves as such), we understand that our local partners will often see us as donors. Inevitably, this means that, in order to be better partners, we must be better donors in the first place.
About the author
Jasper Kiepe is the Head of Programmes for ActionAid in Eastern Europe. Based in Ukraine since early 2023, he is a founding member and co-chair of the Due Diligence Task Force and a co-chair of the Partnerships Working Group under the NGO Platform. He holds degrees from SOAS University of London and the University of Hildesheim.
ActionAid is a global federation working towards a world free from poverty and injustice. ActionAid works through federation members and partners with people living in poverty and exclusion, civil society organisations and social movements in 70 countries. Motivated by the believe that local leadership should be central, ActionAid has been supporting local organisations in Ukraine, Poland, Romania and Moldova since early 2022, including strengthening their capacity and facilitating access to international platforms and donors.