Policy paper

Independent Commission for Aid Impact's review of UK aid to Sudan: UK government response

Published 18 December 2025

The Government welcomes the Independent Commission for Aid Impact’s (ICAI) review of UK aid to Sudan from 2019 to 2025. We are pleased that the report recognises the UK’s sustained commitment to Sudan, our international leadership and diplomacy as well as our leadership in the humanitarian response.  

The review rightly recognises the deep expertise, professionalism and commitment of UK civil servants working on Sudan and neighbouring countries who have been key to the UK’s credibility, relationships and influence. The ICAI report acknowledges that UK aid to Sudan was delivered in a complex and rapidly evolving context which required continual reassessment and repositioning, and that it is now one of the world’s most difficult operating environments.    

We welcome ICAI’s recognition of the Government’s contribution, including that:

• the UK has demonstrated responsible global leadership through its past, present and planned efforts both in Sudan and regarding the impact on neighbouring countries
• the UK has continued to strengthen women’s participation in the pro-democracy movement and helped keep women’s inclusion on the agenda, with stakeholders emphasising that the UK is well placed to lead in this area
• the UK has demonstrated clear leadership in raising global awareness on conflict-related sexual violence and the need to protect women and girls in Sudan, as well as putting in place some of the foundations for future accountability
• the UK played a leading role in supporting economic recovery, providing diplomatic and technical support to Sudan’s transitional government in 2019 to 2021 to clear arrears with the International Financial Institutions and unlock access to concessional financing 
• the UK has provided credible and visible humanitarian leadership in Sudan and the region, acting as a responsive and respected donor and valued by humanitarian partners for the flexibility of its funding which positioned the UK as a ‘first mover’

The UK is committed to supporting the people of Sudan. UK aid is continuing to provide life-saving humanitarian assistance and protection to the most vulnerable people in the hardest to reach areas, tackling sexual and gender-based violence, prevention and verification of atrocities, and supporting civilian led dialogue processes.  During the review period between 2019 and 2025, the UK spent approximately £500 million in Official Development Assistance (ODA). 

This contributed to the following results:

• over 2 million people were reached with humanitarian assistance from 2019 to 2023, and a further 2.5 million people since the start of the conflict

• for more than a decade we have partnered with Sudanese community leaders to prevent female genital mutilation and early enforced marriage through our flagship Sudan Free of Female Genital Mutilation programme, which reached over 145,000 people with GBV services and supported nearly 2,000 communities to reject FGM
• cash transfers provided to 3.2 million people in partnership with World Bank through the Sudan Family Support Programme prior to the coup in 2021

The Government acknowledges the findings of the review and accepts the recommendations in full, which are in line with our own priorities and in line with our continued commitment to the people of Sudan.   

Our responses to ICAI’s recommendations are as follows:

Recommendation 1

Ensure sustained high-level political attention to the Sudan conflict and humanitarian crisis, including by strengthening cross-government ownership and coordination.

Response: Accept

UK engagement has evolved with the context in Sudan and the Government’s assessment of its ability to constructively achieve outcomes, set against wider geopolitical and HM Government priorities. Political attention was substantial after the fall of President Bashir in 2019, supporting preparation of a civilian led government.  After the 2021 coup, the Government sustained attention through the UK’s Ambassador in Sudan, working with the UN/AU/IGAD Trilateral process and later as part of the Quad to encourage a new political process. 

Sudan has been prioritised by the Prime Minister, the former and current Foreign Secretary and the Special Representative to push for a ceasefire, protection of civilians, and humanitarian access. The Prime Minister has made clear that we will continue to play a key humanitarian role in Sudan and has committed to protecting our funding to support people affected by the crisis over the next 3 years. Baroness Chapman reiterated this to the IDC hearing on 28 October.

The Foreign Secretary set out her commitment on Sudan to Parliament in her statement of 30 October and through a high rhythm of engagements such as at the G7 and with the Quad countries (US, Saudia Arabia, Egypt, UAE). She has called for the same intense international efforts to address the crisis in Sudan as we have seen around Gaza, to bring about an immediate and permanent ceasefire, for the unimpeded access of humanitarian aid, for the protection of civilians who are facing unimaginable atrocities, and for external actors to contribute to the restoration of peace and security.  She also committed to the UK playing its full part to ensure that it is the Sudanese people, not any warring party, that determines Sudan’s future.

The FCDO agrees that cross government coordination is beneficial and regularly engages with counterparts across other departments.  The FCDO is seeking greater engagement with MOD to continue efforts to form closer relations with elements of the security sector.  Engagement with the Home Office on migration is working well to ensure a strategic and joined-up response.

Recommendation 2

Develop and implement a clear regional approach to the Sudan conflict, aligning strategies across Sudan and neighbouring countries.

Response: Accept

The UK Government aims to deliver aid through the most locally effective channels, which may include regional portfolios (eg the Sahel for support to Sudanese who have fled to Chad), local embassies (eg South Sudan), or regional offices (eg in Kenya where regional humanitarian leadership resides). Coordination across these modalities is ensured through close collaboration among Development Directors coming under the line management of a single Head of Department and Geographic Director. This enables alignment of policy objectives, joint monitoring mechanisms and clear lines of accountability.

The Government shares ICAI’s assessment that there are critical interdependencies between conflict and fragility in Sudan and its neighbours. The conflict is generating significant cross-border or spillover effects, placing increasing pressure on already fragile neighbouring countries. 

The Government acknowledges the finding in the review that a more explicit regional approach may be helpful to enhance ongoing coordination and action, and work is already underway to draft this.  It draws together ongoing work across the region to mitigate the destabilising impacts of the conflict on neighbouring countries such as large-scale migration, weapons flows, and illicit financial flows. 

The Government notes ICAI’s view that focus on Sudanese refugees and returning citizens risks distorting aid investment priorities in host countries, where local populations face equally urgent needs. FCDO staff working on Sudan, Chad and South Sudan are in close contact regarding the situation in border areas, the humanitarian needs, priorities and gaps and conscious of risks around creating push and pull factors for those seeking humanitarian assistance. The UK continues to be a significant donor to South Sudan and Chad, supporting humanitarian aid, peacebuilding and basic service delivery to both local populations as well as those displaced from elsewhere including Sudan.  

The FCDO is considering future budget allocations for FY 2026 to 2027 onwards. Reducing the overall size of our ODA budget will have an impact on the scale and shape of the work we do. Inevitably, reducing our ODA spend means that for some countries and themes, there will be less to spend. In line with the Prime Minister’s commitment, levels of funding to support Sudan will be protected. Across all our work, the FCDO will continue to prioritise supporting the most vulnerable.

Recommendation 3

Align delivery capacity with ministerial ambition by backing Sudan’s priority country status with multi-year, protected funding and by adequate capacity to deliver effectively.

Response: Accept

The UK will remain a leading humanitarian actor in Sudan, working to end the conflict, ensure protection of civilians, and provide lifesaving humanitarian assistance, as well as supporting people to build resilience to enable them to return to their livelihoods.

Demonstrating this prioritisation, the Government is finalising allocation of significant funding to Sudan for the next 3 years despite reductions in the overall size of our ODA budget. This will provide predictability for our work, enabling us to commit to longer-term approaches with our partners.

The Government is committed to modernising our approach to international development, as a partner, investor and reformer.  In order to allow us to release more resources to the frontline of what we do, we need to ensure that we are focused on what we are trying to deliver strategically and that we are then able to prioritise rigorously. That is only possible if we get significantly smaller over the next few years.  

FCDO welcomes ICAI’s recognition of our staff for their deep expertise, professionalism and commitment, as well as the importance of staff wellbeing. As part of the FCDO’s prioritisation of Sudan, and with ongoing internal reviews of capability, FCDO are considering the staffing needs for the Sudan response including its recruitment and mechanisms for deploying extra staff at short notice. The Foreign Secretary has directed that additional resourcing is committed to the Sudan response.

Recommendation 4

Adopt a more flexible and coherent delivery model for fragile and conflict-affected environments, to maximise agility in dynamic contexts.

Response: Accept

The Government acknowledges the finding in the review that FCDO systems could be more flexible.  However, it is right that FCDO maintains strong oversight and compliance mechanisms given the importance of providing assurance that UK taxpayers money is being spent and managed robustly. We recognise that flexibility is essential in a fast-paced context such as Sudan and are reviewing how FCDO compliance procedures can be adapted to better suit the operating environment, including how FCDO’s Programme Operating Framework can ensure processes for programme delivery are more agile.

The Government shares ICAIs view that locally hired staff are essential to our effective operations and that there was a loss of institutional memory and contextual knowledge with the departure of many of our Sudanese staff. Due to the start of the conflict in April 2023, FCDO was forced to evacuate and close the Embassy because it was unsafe. FCDO adopted a remote operating model given there was no viable chance of reopening an embassy inside Sudan in the near-term. This was unfortunately not viable for the majority of our staff due to the nature of their work, and work permit requirements in third countries. FCDO did retain its UK staff in the new British Office Sudan who maintained continuity, partnerships, and institutional memory, along with a limited number of Sudanese staff who remain critical to our work in Sudan.

HMG places importance on discharging its duty of care to its staff. The FCDO acknowledges that the inability to travel within Sudan – beyond Port Sudan – does impact our ability to fully understand the context, and explore the issues, opportunities and challenges with local stakeholders. The FCDO relies on our partner networks, information through our programmes and third-party engagement and have sought to increase these information flows. The FCDO continues to monitor the situation and will seek to expand the areas within Sudan to which our staff can travel when the security situation allows.

The Government welcomes ICAI’s point that focus should not be solely on humanitarian response but balanced portfolios with resilience building and nascent development work. This has already been considered given the evidence of working across the humanitarian-development-peace linkages in FCAS states including to strengthen resilience to conflict and recurring shocks. 

In Sudan, while we have reduced our development programming since the war started due to the scale of humanitarian need and risk of politicization of aid by the parties to the conflict, the FCDO has begun some resilience focussed activities through the Cash Consortium Sudan. This aims to engage and strengthen markets and begin to open opportunities for livelihoods beyond immediate lifesaving assistance, in response to the demand from communities.

The FCDO will document learning from this and assess opportunities to expand on this based on evidence of what works. We also work closely with, and make significant contributions centrally to, the International Financial Institutions such as the World Bank and African Development Bank, who will play a critical role in the reconstruction of Sudan when conditions allow.

Recommendation 5

Support the UK’s localisation commitment by increasing direct funding to local organisations, simplifying compliance procedures, fostering long-term partnerships and strengthening local leadership of humanitarian response and resilience building.

Response: Accept

The Government agrees with ICAI that local responders play a critical role in getting support to those in the hardest reach areas, especially in the face of bureaucratic access constraints imposed by parties to the conflict.  We fund local responders in countries such as Sudan where this offers the best value for money and outcomes for populations in greatest needs.

The Government is committed to exploring a greater shift towards more locally led development and humanitarian action, including through making greater use of humanitarian pooled funds where appropriate. We recognise that stronger, more inclusive engagement with partners and local organisations can better empower those that development and humanitarian efforts are designed to serve. We have enhanced locally led actors’ access to UK ODA through simplifying compliance procedures. Earlier this year, the FCDO launched due diligence passporting which reduces bureaucracy for local partners, while ensuring that they meet our stringent accountability and compliance requirements.

With hundreds of local organisations operational across Sudan, mostly working at a very localised level, it is not realistic for the FCDO to fund directly at the scale required to reach those in need. In Sudan, our decision on how to channel funding to local partners is based on a range of factors which measure the quality of funding and impact on target populations. These measures include: the extent to which the funding mechanism allows for flexible and timely responses, provides capacity building opportunities and passes overheads to local responders, manages risk to frontline responders, and fundamentally, allows local responders themselves to make decisions on how funding is allocated. The FCDO also aims to limit the reporting burden and embed risk management into delivery. In some cases, we assess that funding to local partners through an intermediary will provide the strongest value for money and impact.

Since the review, in Sudan, the FCDO has supported 2 new partnerships with pooled funding mechanisms that channel funding to local partners with significantly lower overheads than we see with other intermediaries. The Government will continue to increase our support to local actors under our new humanitarian programme, with the aim that at least 30% of humanitarian funding by 2029 is channelled to locally led initiatives. The FCDO’s experience and learning from Sudan is shared across the department to inform overall learning in this critical area.

The Government notes ICAI’s finding that diaspora groups have a strong desire for deeper engagement with the UK. FCDO officials regularly meet a broad cross-section of Sudanese civil society and diaspora groups to better understand their concerns and to encourage an inclusive and unified approach to transition to a civilian-led government following a sustainable ceasefire. The FCDO will consult on what forum would work best for regularised, more strategic diaspora engagement.

Recommendation 6

Address the need for more targeted programming for priority gender-related challenges in Sudan and assess how well the current mainstreaming approach is delivering results for women and girls.

Response: Accept

The humanitarian and protection needs for women and girls in Sudan have reached catastrophic levels in many states. The FCDO has already stepped up our work in this area, through pivoting our approach within our humanitarian programme to channel more funding to Women Led Organisations and integrating gender specific protection assistance into our humanitarian response. The FCDO has actively supported women’s participation and voices, including in ongoing efforts to unify Sudan’s civilian political forces. We will continue to look for opportunities to support women’s political participation as part of our commitment to the building blocks for an inclusive political process.

The Government accepts that our funding to women-led organisations has been largely through pooled funding managed by UN Agencies due to the advantages this brings, including efficiency, risk sharing and reducing administrative burdens on smaller organisations.  We have assessed options that allow us to provide funding to local responders whilst also preserving their autonomy to decide how best to spend the funds they receive and providing proportionate compliance requirements to protect UK taxpayers’ money. As noted for recommendation 5, since the review, we have supported 2 new partnerships to increase funding for locally led organisations.

We accept ICAI’s view that our approach to protection programming could go further and agree the need to complement policy interventions with the delivery of interventions that could change dynamics on the ground. Two new programmes, one addressing Gender Based Violence and one focused on the protection of civilians, are currently under design. 

We accept that we need to do more to capture outcomes on gender and social inclusion mainstreaming in our programmes. The FCDO will achieve this by ensuring data from partners is disaggregated in accordance with the Inclusive Data Charter, and by refreshing our Gender Equality, Disability, and Social Inclusion (GEDSI) analysis to identify gaps and opportunities in our programming.

The Government does not accept that we opted to take the least ambitious approach to the prevention of atrocities. The UK’s commitment to atrocity prevention in Sudan is long-standing, having led efforts to establish the UN Fact-Finding Mission (FFM), secured its mandate extension for 2 successive years, and supported the deployment of a specialist sexual and gender-based violence (SGBV) investigator this year.  We are also funding the Sudan Witness Project with £1.5 million to document and verify attacks on civilians. Work is underway to deliver 2 new programmes, one focused on tackling Gender Based Violence and the other to enhance community protection in Darfur and across Sudan.

Recommendation 7

Use learning from the Sudan conflict as an opportunity to rethink and adapt UK international leadership on mobilising and coordinating the international response to major crises, given severe global funding pressures, a shifting donor landscape and rising humanitarian need.

Response: Accept

The Government agrees the importance of ensuring the learning from the Sudan conflict informs our work in other contexts. The UK is working closely with other donors to look at how we can support and drive forward reform through the UN80 process and the UN Inter-Agency Standing Committee (IASC) humanitarian reset. This includes prioritisation of life-saving actions, simplified coordination, more funding to national and local actors, and improving advocacy and communications.  In doing so, we draw heavily from the learning and experience from our humanitarian experts working on crises including Sudan.

We note ICAI’s view that the UK and others have not succeeded in overcoming UN performance gaps in Sudan. As part of our leadership of both the Core and the Humanitarian Donor Working Groups, we have enabled collective strategic planning on the humanitarian system funding cuts, ensuring that funding decisions are well coordinated amongst donors and are aligned to critical planning documents such as the Humanitarian Needs and Response Plan. 

We will continue to work closely with the UN Resident and Humanitarian Coordinator, who is playing a critical leadership role in the response and with donor/member state groupings, to look at where we can inform and support the humanitarian response to be more strategic. We remain committed to working closely with the UN at headquarters and in Sudan, both bilaterally and in coordination with other development partners, to ensure that they have the tools and support they need to be as effective and impactful as possible.