The Ministry of Social Policy, Family, and Unity of Ukraine has prepared a draft resolution of the Cabinet of Ministers of Ukraine titled "Certain Issues of Acquiring and Losing the Status of a Verified Humanitarian Organization." The document was developed to implement Law of Ukraine No. 4608-IX, which introduced the institution of the "verified humanitarian organization."
The goal of adopting the act is to define the procedure for acquiring, confirming, and losing the status of a verified humanitarian organization, as well as to regulate issues related to the import of vehicles as humanitarian aid, state border crossing by employees of humanitarian organizations, integration with the automated humanitarian aid registration system (AHAS), and the possibility of applying mechanisms for criticality and "reservation" (mobilization exemptions).
The key concept of the Draft is the automated verification of organizations through the AHAS using inter-agency electronic exchange with the registers of the Ministry of Justice, the State Tax Service, and the Pension Fund of Ukraine. The status of a verified humanitarian organization is granted for a term of 12 months, and decisions are made automatically. Provision is also made for generating an electronic extract with a QR code and maintaining a public list of verified organizations.
Experts from the Ukrainian Center for Independent Political Research note several positive aspects of the project. Among them:
- reduction of administrative discretion and corruption risks thanks to formalized criteria;
- increasing transparency and standardization of the humanitarian sector thanks to established publicity requirements;
- simplification of status confirmation and speed of status confirmation (up to 72 hours);
- unification of rules for the use of humanitarian transport;
- integration with logistics mechanisms and border crossing.
At the same time, the Project poses risks to civil society organizations (CSOs), particularly for small and newly established organizations. The introduction of a financial threshold of 2 million UAH for expenditures and the requirement to publish reports for 2 years may effectively exclude a significant portion of organizations that carry out humanitarian response but lack the corresponding financial indicators. A separate concern is raised by the lack of a clear procedure for administrative appeal of automatic refusals or loss of status, as well as excessively broad and evaluative grounds for exclusion from the list.
In general, the Project should be supported in terms of digitalization, transparency, and increased accountability in the humanitarian sector; however, it requires refinement. In particular, this refers to the introduction of "transitional" or differentiated conditions for small organizations, clear procedures for appealing automated decisions, mechanisms for eliminating technical deficiencies without immediate sanctions, and the principle of proportionate responsibility.
Without making such changes, there is a risk that the verification mechanism will not become a tool for increasing trust and efficiency in humanitarian response, but will instead narrow access to humanitarian activity for a significant portion of CSOs.
Detailed analysis of the document at the link.
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