Refugee-Led Organisations: The Equality Trap - Why the Humanitarian System Must Think 'Equity'

This is the second in a series of pieces on localisation and what it truly demands of the humanitarian system. The first explored whether "localisation" is even the right word. This one asks: even if we get the word right, are we prepared to do what the concept actually requires?

In the late 1990s and early 2000s, the humanitarian system had a reckoning about aid to women and girls: providing equal, generic assistance often left women and girls entirely marginalised, their distinct needs invisible within a supposedly neutral response. Decades of gender discrimination had created a gap so structural, so embedded in institutions, funding mechanisms, and programming logic, that merely treating women equally and the same as men would never close it. What was needed was equity: targeted, differentiated action to correct an imbalance that equal treatment would perpetuate rather than resolve.

The Inter-Agency Standing Committee, the highest-level humanitarian coordination forum, moved from acknowledging the problem to institutionalising the solution in 2009, with the IASC Gender Marker, later made mandatory for projects in consolidated appeals and CERF from 2011. The Marker required aid organisations to demonstrate that their programming actively accommodated the different and distinct needs of women and girls, rather than treating all affected people as a uniform group.[1] The marker was subsequently strengthened and replaced in 2018 by the IASC Gender with Age Marker (GAM), which codes projects on a 0 to 4 scale across twelve gender equality measures, moving from compliance to quality assessment.[2]

The OECD-DAC Gender Equality Policy Marker, which has tracked donor financing against gender objectives since 1997 using a three-point scale (not an objective / significant objective / principal objective), has also helped operationalise financial accountability.[3]

The system also adopted successive gender policies, culminating in the updated IASC Policy on Gender Equality and the Empowerment of Women and Girls in Humanitarian Action (2024), which is explicit that the goal is transformation, recognising that women and girls "continue to be disproportionately affected and severely disadvantaged in humanitarian crisis settings."[4]

The same logic emerged for persons with disabilities. The UN Convention on the Rights of Persons with Disabilities (2006) established that the rights of persons with disabilities could not be realised simply by applying universal human rights frameworks; specific, equity-based measures were required. The principle of meaningful participation, crystallised in the now-iconic phrase "Nothing about us without us"[5], was operationalised in the IASC Guidelines on the Inclusion of Persons with Disabilities in Humanitarian Action (2019), which set out concrete standards for disability-inclusive programming, coordination and partnership across the humanitarian programme cycle.[6]

In both cases, the system learned the same lesson: equality of treatment cannot compensate for inequality of condition. We are now at precisely that inflection point with refugee-led organisations.

The Gap Is Structural

Refugee-led organisations (RLOs) are not peripheral actors who need a little encouragement to participate. They are, as researchers from Uganda have documented in their own words, "not only first responders — we are educators, health promoters, peacebuilders and advocates. Our initiatives reach communities sooner, cost less and carry trust that international programmes rarely match." What they lack, as that same research makes clear, "is not another training manual but the resources and authority that match the responsibilities we already shoulder."[7]

Yet the system continues to treat them, structurally, as recipients rather than actors. Despite the Grand Bargain's 2016 commitment to channel at least 25% of global humanitarian funding to local and national actors "as directly as possible,"[8] the data remain stark. The 2025 Humanitarian Policy Group (HPG) report How to finance refugee leadership Navigating a humanitarian system at breaking point provides damning data: The total trackable funding reaching RLOs in 2024 was just $49 million, compared to $4.7 billion provided to nine UN Refugee Response Plans in 2024, and “the $35,000 they receive is significantly lower than grants given to local and national actors ($88,000) and to United Nations (UN) agencies ($320,000)”.[9]

The humanitarian ecosystem continues to perpetuate the misconception that RLOs are small and informal fringe actors lacking capacity and expertise feeding further into the assumption that investing in RLOs is riskier than investing in large international UN agencies and non-governmental organisations. This puts RLOs in a bind: how can they convince risk-averse donors that they are capable of managing funds when they are not given funding to manage in the first place?

There is also a fundamental fairness question that the system has yet to confront honestly. As the HPG's 2025 report observes, there is a deep “unfairness in holding RLOs to a higher standard of scrutiny than the international organisations. Few international organisations would be willing to open themselves up to the same level of scrutiny, particularly around expenditure.”[10] A system that demands rigorous financial audit trails from an RLO operating on a $30,000 grant is operating a double standard.

The consequences of this structural exclusion are felt in ways the system rarely acknowledges. At times of budget cuts, RLOs are often praised for doing more with less, but this efficiency is frequently born of necessity, not choice. Without adequate investment in staffing (rather than volunteers) capacity, core costs, staff wellbeing, and institutional growth, the so-called ‘cost-effectiveness’ argument only further limits sustainability and reinforces precarity. The system instrumentalises RLOs' low costs as evidence of efficiency, when it is actually evidence of structural exclusion.

Why does the gap persist? Because the system applies equal standards - due diligence frameworks, partnership agreement templates, reporting requirements, financial management audits - that were designed by and for large, well-resourced international organisations. Applying these equally to an RLO with a part-time coordinator and no dedicated finance or MEL officers is structurally exclusionary.

What an Equity-Based Approach Actually Requires

The humanitarian system does not need to reinvent the wheel. It needs to apply lessons already learned to the specific conditions of RLOs. This means action across three interconnected domains:

1. Equity in Due Diligence

The current due diligence frameworks applied by UN agencies, INGOs and donors were not designed with RLOs in mind. Capacity assessments that measure organisational maturity against international NGO benchmarks, financial auditing requirements that presuppose dedicated systems, and registration requirements that may be legally inaccessible to refugee-led groups in host countries, all of these function as gatekeepers that screen RLOs out.

In addition to progress made on collective due diligence passporting that should be expanded to RLOs to prevent them from undergoing repetitive, exhaustive vetting by different donors,[11]  an equity-based approach means developing differentiated, proportionate due diligence that assesses risk in relation to the size of the grant and the nature of the relationship.

Much can also be learned from practices developed by trust-based philanthropy, including participatory due diligence, where funders co-design the assessment process with the grantee, asking what accountability looks like from their perspective and for their community rather than applying a standardised checklist. This is a particularly relevant practice when it comes to RLOs, whose accountability is - and should remain - primarily downward to displaced communities, rather than upward to donors.

Other trust-based philanthropy practices include differentiated application processes involving conversations, site visits, or short concept notes, instead of one-size-fits-all heavy bureaucratic templates. This is the direction of travel; it needs to become the norm.

2. Equitable Partnerships

Partnership, as currently practised, frequently means sub-granting: an international organisation retains strategic decision-making, manages the donor relationship, and passes a portion of funding downstream under terms it has largely dictated. The HPG highlights the importance of recognising “the power asymmetries that exist between institutional and local actors – particularly when intermediaries fail to pass on quality and flexible funding or decision-making power, or when they treat local actors as sub-contractors or employees, or exclude local partners from opportunities to engage with donors”.[12]

“RLOs want to work collectively and collaboratively with the international community, but they want to do this on their own terms – as equal partners not sub-contractors.”[13] reports HPG.

Equitable partnership agreements therefore must include joint design of project scope and indicators; overhead rates for RLOs that reflect their actual costs; multi-year, flexible funding where possible; formal recognition of RLOs as equal implementing actors, not sub-contractors; and RLOs’ accountability to their communities rather than donors.

Trust-based funders also provide general operating support rather than project-tied grants, removing the need for elaborate pre-grant compliance architecture around specific deliverables. The due diligence question shifts from "Can you account for every line item?" to "Do we trust this organisation's mission and leadership?"

The distinction is not semantic; it determines whether RLOs have a seat at coordination tables, whether their data counts in humanitarian information management systems, and ultimately whether they are recognised as humanitarian actors in their own right.

3. Equity in Reporting

Equitable partnership cannot stop at the funding agreement. How accountability is exercised after funding flows is equally determinative of whether an RLO is treated as a partner or a sub-contractor. Current reporting requirements (quarterly narrative reports, financial tracking spreadsheets, log-frame indicators, disaggregated data) were designed by and for organisations with dedicated monitoring and evaluation staff, reliable internet connectivity, and administrative systems capable of producing documentation in the formats donors expect. For an RLO coordinator who is simultaneously a first responder, a community mediator, and often a refugee themselves, these requirements are not neutral. They are a structural burden that consumes the time and energy the system claims to want directed at communities.

An equity-based approach makes tailored reporting formats the way to go. In practice this means accepting a range of accountability modalities as equally legitimate: photographs documenting community activities; voice notes or telephone conversations with a programme officer; participatory community feedback sessions whose outputs are shared informally; short written updates in the grantee's own language and framing. What matters is that accountability flows, and that RLOs can demonstrate impact in ways that reflect how they actually work.

Some trust-based funders have begun to recognise this, explicitly giving grantees the right to push back on reporting requirements that don't fit their context, replacing standardised templates with narrative updates, direct conversations, or relationship-based check-ins.[14]

This is not a lowering of standards; it is a recognition that the standard itself was never neutral. An equity lens asks: whose definition of accountability are we applying, and does it serve the communities at the centre of this work, or primarily the institution(s) at the top of the funding chain?

4. Equity in Measurement

The gender equity journey demonstrates that systems change when they are measured, tracked, and made visible. The humanitarian system built a suite of tools to enforce accountability on gender: it can and must build equivalent tools for RLO inclusion.

A marker for locally-led initiatives by RLOs could rate projects along a spectrum from "RLO-blind" (no engagement with refugee-led actors) to "RLO-transformative" (RLOs co-design, co-implement and co-evaluate, with funding flowing directly and recognition formally acknowledged). Coding programming on a spectrum would give donors, UN agencies and INGOs a shared vocabulary and could shift institutional behaviour at scale.

Like the OECD-DAC Gender Equality Policy Marker, an RLO funding marker, applied to donor disbursements and UN agency as well as INGO sub-grants, would help operationalise financial accountability for localisation commitments. Clear rules are required for how to report on localisation to overcome the current "intermediary" blind spot and capture subsequent funds that UN agencies and INGOs redistribute to local, grassroots responders, including RLOs. The marker's logic is straightforward: if RLO inclusion is tracked in financial reporting, it will be prioritised at the point of decision.

Finally, mandatory reporting on the tier at which funding reaches RLOs i.e. not just whether an RLO appears somewhere in the delivery chain, but whether funding is direct (first tier) or passed through one or more intermediaries. Without this granularity, the 25% Grand Bargain target will continue to obscure as much as it reveals.

A similar infrastructure to the system built to advance gender equality can - and must - now be built for RLOs. The humanitarian ecosystem must make a deliberate, documented, and monitored commitment to accountability to refugee-led organisations.

‘Equal’ is not enough when the starting points are so unequal. ‘Equity’ is the way.

Notes

[1] See Siobhán Foran, Aisling Swaine & Kate Burns, Improving the effectiveness of humanitarian action: progress in implementing the Inter-Agency Standing Committee (IASC) Gender Marker, 2012, https://doi.org/10.1080/13552074.2012.687221.

[2] IASC GenCap Project, The IASC Gender with Age Marker (GAM) (2018).

[3] See: OECD, Handbook on the OECD-DAC Gender Equality Policy Marker (2025); and OECD, Development Finance for Gender Equality Dashboard: https://www.oecd.org/en/data/dashboards/development-finance-for-gender-equality.html

[4] IASC Reference Group on Gender and Humanitarian Action, Policy on Gender Equality and the Empowerment of Women and Girls in Humanitarian Action (updated), endorsed by IASC Principals, January 2024.

[5] See: Disability and Human Rights – Edited By Nick Watson, Alan Roulstone, Carol Thomas, Routledge Handbook of Disability Studies, Chapter 6 "Disability and Human Rights", https://doi.org/10.4324/9780429430817.

[6] IASC, Guidelines on the Inclusion of Persons with Disabilities in Humanitarian Action (2019).

[7] Agook, K., Arou, K., Ahmed, S., Mugisho, J., Touloung, S.M., & Refstie, H. (2025). "Filling the gap or taking the lead? Refugee-led organisations in Uganda." Fennia: International Journal of Geography, Vol. 203, No. 1. https://doaj.org/article/c27115ef5bf847378dc34646a5dde414.

[8] Grand Bargain Localisation Workstream, at: https://gblocalisation.ifrc.org/.

[9] Sturridge, C., Girling-Morris, F., Samaha, C., & Pearson, M. (2025). How to finance

refugee leadership: Navigating a humanitarian system at breaking point. Humanitarian Policy Group (HPG) Report. London: ODI, p.35.

[10] Sturridge, C. et al. op. cit., p.18.

[11 See for instance the Charter for Change Due Diligence Passporting Tool, https://humentum.org/charter-for-change-due-diligence-passporting-tool/.

[12] Sturridge, C. et al. op. cit., p.28.

[13] Sturridge, C. et al. op. cit., p.35.

[14] Trust-Based Philanthropy Project, What is Trust-Based Philanthropy? Available at: https://www.trustbasedphilanthropy.org/what-is-tbp.