Overview
Humanitarian organizations have demonstrated resilience in delivering aid, however access remains significantly constrained with increasing restrictions on women and girls, along with bureaucratic and administrative impediments (BAI) imposed by national and sub-national authorities playing a significant role.
Between January and October 2024, humanitarian partners reported 1,345 access-related incidents, compared to 1,529 during the same period in 2023.
The majority (72 per cent) were related to interference in humanitarian activities, followed by 6 per cent linked to restrictions on the movement of agencies, personnel, or goods within the affected country. Additionally, 14 per cent were due to challenges posed by the physical environment, 6 per cent involved violence against humanitarian personnel, assets, and facilities, and 1 per cent was attributed to military operations and the presence of mines and UXOs.
In Afghanistan, humanitarian operations are frequently disrupted by the DfA’s issuance of edicts and decrees without prior consultation with the humanitarian community, coupled with inconsistent regulatory practices across governance levels. Interferences in humanitarian activities involving the DfA remain
a key challenge, with 972 interferences recorded between January and October 2024, representing 72 per cent of all reported cases. This includes prolonged Memorandam of Understanding (MoU) signature processes, repeated DfA demands to participate in recruitment and procurement processes, and interference during program implementation, resulting in temporary suspension of activities, closure of facilities, and programme relocations. As women and girls often require other women to access humanitarian assistance, restrictions on women’s participation continue to be a major barrier to an equitable response. WLOs face a multitude of restrictions such as reduced funding, increased operational costs, complex requirements concerning female staff participation and interactions with beneficiaries, and arbitrary restrictions on community access. While many organizations were forced to close,
some WLOs persist despite the challenges, adapting to informal spaces to provide essential support to vulnerable groups through community-based protection mechanisms. Restrictions for civil society organizations, including OPD further undermine the provision of specialized support for persons with disabilities.
Such restrictions are compounded by incidents of violence against humanitarian staff and assets – often as a means to enforce compliance with regulatory demands. From January to October 2024, 84 incidents of violence against humanitarian workers, assets, and facilities were reported, including the detention of 113 staff members, with the southern region seeing the highest concentration of cases. Additionally, 15 incidents involved threats against staff, including demands for sensitive data. Access to hard-to-reach areas, such as the northern and northeastern provinces or the central highlands, remains limited due to the remote and mountainous terrain, which becomes particularly challenging during winter. This is further exacerbated by funding shortages, hindering the ability to cover additional logistical costs.
These challenges are expected to persist in 2025, necessitating continued advocacy efforts at both national and sub-national levels to address policy issues and safeguard independent, unimpeded and principled humanitarian action.
Regulatory framework and directives
Since August 2021, the DfA has issued 403 directives affecting humanitarian programming in Afghanistan. Key frameworks, such as the Islamic Emirate of Afghanistan (IEA) Procedure on Coordination and Regulation of NGOs (October 2022) and the DfA Ministry of Economy’s Guidance on NGO Responsibilities (October 2023), include provisions that conflict with global humanitarian principles and the Afghanistan HCT Joint Operating Principles. These frameworks have contributed to interference in humanitarian action, affecting recruitment, procurement, beneficiary selection, and identification of programme locations, causing significant delays.
The enactment of the PVPV law in August 2024 has significantly increased scrutiny on NGOs and female staff. Over the past few months, partners have reported frequent visits by de facto PVPV officials to offices and project sites. As a result, 51 per cent of organizations (38 per cent NNGOs, 12 per cent INGOs) have reported difficulties in implementing awarenessraising projects. Additionally, 69 per cent (53 per cent NNGOs, 16 per cent INGOs) indicated that only men are permitted to continue working in their offices, and 27 per cent (23 per cent NNGOs, 4 per cent INGOs) reported that women have left their organizations due to DfA decrees.
The combination of regulatory interference and gender-based restrictions threatens to undermine equitable humanitarian support and jeopardize essential assistance for affected populations. In response, humanitarian leadership, supported by the Humanitarian Access Working Group (HAWG), will continue providing partners with guidance to navigate these interferences in 2025. This includes sustained engagement with the DfA to safeguard operational space, troubleshooting forums for cluster coordinators to address issues with DfA ministries, and high-level interactions between humanitarian leadership and the DfA to tackle these challenges directly.
Access incidents with gender dynamics
Gender-based restrictions continue to hinder aid delivery to the most affected populations, with 194 gender-related incidents reported in 2024. Since the December 2022 ban on Afghan women working with NGOs – later extended to the UN in April 2023 – the DfA has announced numerous additional restrictions on women and girls, albeit to varying degrees of enforcement. The promulgation of the PVPV Law in August 2024 tightened restrictions for all people in Afghanistan, with special attention to women and minority groups. Reportedly under development for over a year, the law codifies previous restrictions (such as the March 2022 decree requiring all women in Afghanistan to wear full-body coverings in public), while also including some new ones, and giving broad discretionary powers to inspectors. Initial concerns identified by humanitarian actors of how enforcement of the law could impact humanitarian response included: negative effects on the presence and participation of Afghan women both in the office and field, limits in the access of female healthcare workers to the community and patients, and the unacceptable toll on the mental health and wellbeing outcomes of Afghan women and men, including UN and NGO personnel.
Findings from initial monitoring efforts indicate that the PVPV Law had not significantly altered the daily lives of affected women in the community, as many were already spending most of their time inside their homes. Most women were aware of the law and noted its primary impact as an increased presence of PVPV representatives, particularly when accessing health facilities. The most reported incidents involved PVPV representatives asking women to cover themselves more fully or ensuring they were accompanied by a mahram. For Afghan women humanitarian workers, however, the law’s impact has been more pronounced. Stricter mahram requirements have been implemented in the provinces and some women have been asked to work from home. Additionally, engaging with women through meetings and focus group discussions has become increasingly difficult, especially in provinces where the law is enforced more strictly. Surveillance of Afghan women staff in urban areas has also intensified, particularly concerning their movement to meetings or offices. Additional barriers for women-led organizations include security threats, bureaucratic impediments targeting women, and the exclusion of women from leadership roles, further hindering humanitarian assistance by women for women.
Despite these challenges, local negotiations and adaptive measures continue to safeguard operational space, albeit at additional financial cost. Common strategies include providing financial incentives for mahrams, creating separate workspaces and establishing designated distribution spaces and days for women and men.
References
- OCHA Access Monitoring and Reporting framework (2024)
- Ibid.
- Humanitarian Access Working Group (HA WG)–GiHA survey Round 9 (2024).
- Ibid.
- For an overview of key instructions issued by the de facto MoPVPV and their implementation, see: De Facto Authorities’ Moral Oversight in Afghanistan: Impacts on Human Rights (2024)