New guidelines for international aid groups threaten to further bend the humanitarian system in Palestine to serve Israeli political and military goals by muzzling advocacy and dividing NGOs between those willing to play by Israeli rules and those who refuse, aid workers in Gaza and the West Bank say.
Those who refuse to play by Israel’s rules are increasingly being frozen out, several international aid workers told The New Humanitarian. Most spoke on condition of anonymity because of concerns that Israeli authorities will retaliate against organisations who speak up.
The impending full implementation of the guidelines on 9 September comes as the aid sector in Palestine is already being roiled by news of a secret meeting between UN agencies, major humanitarian organisations, and the US- and Israeli-backed Gaza Humanitarian Foundation (GHF).
The meeting, first reported by The New Humanitarian, prompted Philippe Lazzarini, head of the UN’s agency for Palestine refugees (UNRWA), to warn of a potential “fracturing of the humanitarian community” if some UN agencies and aid organisations move to work in parallel with the GHF – which aid groups say serves Israel’s military strategy in Gaza and is deeply implicated in alleged war crimes.
In this context, the new guidelines are another tool Israel is using to bring about this fracturing and exert its control, according to aid workers.
“This is a system that’s basically stacked against us. It’s working both to classify good humanitarian agencies and bad humanitarian agencies… [and] to frighten and intimidate organisations from speaking out about what they’re seeing,” one aid worker working on the Gaza response said. “Divide and conquer is their strategy.”
Since October 2023, Israel has used visa approvals and renewals to exert pressure on UN agencies and aid organisations. In a recent example from July this year, Israel did not renew the visa of Jonathan Whittall, the head of the UN’s emergency aid coordinating office (OCHA) in Jerusalem, due to his outspoken advocacy. Israeli authorities have also relentlessly attacked UNRWA – historically the largest and most important UN agency in the occupied Palestinian territories – and used legal mechanisms to ban human rights organisations.
Now, the pending enforcement of the new guidelines poses an immediate, existential threat to humanitarian efforts in Gaza and the West Bank, aid workers say.
This comes at a time when the world’s foremost authority on hunger has declared that an “entirely man-made” famine is taking place in parts of Gaza, calling for an immediate ceasefire to allow for an influx of aid, and as Israeli military and settler violence, displacement of Palestinian communities, and settlement expansion in the West Bank is at an all-time high.
“We’re restricted at every turn, whether it’s through bureaucratic and administrative processes, or direct attacks on us on the ground, where our colleagues have been killed in record numbers,” Bushra Khalidi, policy lead for Oxfam in Palestine, said of the guidelines. “This is another milestone we’ve reached in restricting humanitarian space.”
The threat of de-registration
Israel adopted the new guidelines, which govern the registration of international NGOs working with Palestinians, in March of this year. Humanitarians have been issuing warnings about their potential impact since before they went into effect, but aid workers said some had hoped to find a way around the most objectionable parts of the rules.
The guidelines set out vague restrictions for NGOs, including a prohibition on employing or being officially associated with someone who has called for a boycott of Israel in the previous seven years as well as anyone who, in the government’s opinion, “promotes delegitimisation campaigns” against Israel or has expressed support for prosecution of Israeli soldiers.
A significant concern for many groups is the Israeli government’s demand for the names and extensive personal details of employees, including Palestinian staff.
COGAT, the Israeli military department responsible for coordinating with humanitarians, said the registration rules aim to prevent “infiltration of terrorist elements into the aid mechanism”.
But handing this data to the same authorities who have repeatedly targeted aid workers, bombed protected humanitarian sites, and who are fighting a military campaign that has killed more than 500 aid workers would be an unacceptable risk, aid workers told The New Humanitarian.
“We don’t provide staff lists to a party to the conflict that has killed humanitarian workers in record numbers. That would be a breach of our duty of care towards our staff in Gaza,” said Oxfam’s Khalidi.
The guidelines give Israeli authorities broad enforcement mechanisms, including banning non-compliant organisations. Those not registered under the new rules have been blocked from sending aid to Gaza since July.
Any hope of finding workarounds now appears unlikely. Some organisations have tried to comply with the registration process to the extent possible, but say they are legally barred from providing certain information – particularly about staff members – by privacy laws.
Groups that are refusing to comply – or who have only partially complied – are now staring down possible de-registration by 9 September, when Israeli authorities are expected to announce registration decisions.
“That will all be gone”
It is currently unclear how many groups will be de-registered on 9 September, but aid workers said it will undoubtedly have an impact on the response in Gaza – already hobbled by persistent Israeli obstruction and efforts to sideline the UN-led humanitarian system.
Deregistered organisations may be able to continue to do work in Gaza that doesn’t require bringing in goods – but the regulations will have other significant effects, including blocking the entry of staff and medical workers associated with banned organisations.
Although the guidelines apply to international NGOs, local groups will also likely lose funding and backing if partners are forced out, aid workers told The New Humanitarian. “The real issue is on the ground, in the streets, in the cities… The soup kitchens, the food parcel deliveries, the health clinics, all this stuff – this is all NGOs that are doing this,” a second aid worker speaking anonymously said. “That will all be gone. That will take just a couple of weeks.”
“One of the criteria is about the de-legitimisation of Israel… Does it mean that if I am registered under the new system, then if I’m trying to get aid into Gaza and it’s delayed or blocked for no valid reason, then I can’t tell my donors about it?”
It is also unclear if Israeli authorities will continue to talk with de-registered aid groups to deconflict their locations and movements.
Although aid workers have said repeatedly that, at best, the deconfliction system does not guarantee safety – and, at worst, seems to be treated by Israeli authorities like a target list – it does in theory provide some small measure of reassurance. “That’s the chief concern – staff safety. What if our premises are no longer acknowledged by the Israelis?” the first aid worker asked.
Even if organisations do register, the rules are open to the interpretation of a panel of officials overseen by the Ministry for Diaspora Affairs and Combating Antisemitism.
“One of the criteria is about the de-legitimisation of Israel… Does it mean that if I am registered under the new system, then if I’m trying to get aid into Gaza and it’s delayed or blocked for no valid reason, then I can’t tell my donors about it?” Khalidi asked.
The threat of de-registration for violating unclear restrictions will have a chilling effect on advocacy and on the reporting of international humanitarian law and human rights violations, according to aid workers. Overall, they said, the new guidelines aim to extend to the West Bank the same restrictions seen in Gaza.
“It’s reducing civil society to just distributing food, which goes against everything that we as humanitarians and development agencies believe in,” Khalidi said.
A push to dismantle and replace
At every turn over the past 22 months in Gaza, Israeli authorities have tried to dictate where and when humanitarians can work. These actions have often aligned with political and military goals – in northern Gaza, for example, the systematic elimination of healthcare infrastructure and the targeted killings of people delivering food aid has coincided with efforts by Israeli authorities to displace people to the south.
Recently, Israeli authorities suddenly reversed a strict ban on tents entering Gaza and said some would be allowed – but only in the south, where they also aim to concentrate civilians forcibly displaced in a new military push to take control of Gaza City. Although, it is unclear if any tents have been allowed in since the announcement.
Several aid workers connected access restrictions with the annexation of Palestinian land in the West Bank – cutting off services as a way to forcibly displace people: “They have not been scared of using those kinds of methods in Gaza, depriving people of humanitarian assistance to drive them away – so I don’t see why they would not replicate those methods in the West Bank,” a third aid worker, speaking on condition of anonymity, said.
If Israeli authorities proceed with plans pushed by influential government members to formally annex large parts of the West Bank, the new guidelines would force humanitarians to seek official permission to operate there as well.
Israeli authorities also aim to apply the new guidelines to occupied East Jerusalem, where schools run by local NGOs in partnership with international NGOs would be forced to close, as would other INGO-run services like legal support for people facing home demolitions.
Israeli forces have already stormed and closed down schools run there by UNRWA, which was banned from operating in Israel last year.
The combination of those moves would essentially eliminate access to education in East Jerusalem, Khalidi said.
If the traditional humanitarian system is allowed to collapse – or allows itself to be co-opted – several aid workers predicted that the gap left behind would be filled by organisations following the model of the GHF – whose militarised distribution sites are staffed by US security contractors and explicitly serve Israeli interests.
They described the NGO registration rules as part of an overall push by Israel to cut out humanitarians in favour of pseudo-humanitarian groups like GHF, which operate according to the whims of state policy.
“They’re not going to be principled. They’re not going to do advocacy. They’re not going to be impartial. They’re not going to talk about what they see,” the third aid worker said.
Distract and divide
Aid workers whose organisations have not complied with the new rules said they are assuming they will be de-registered and are making contingency plans – although they declined to speak on the record about what those would involve.
The new guidelines give de-registered groups two months before enforcement action – theoretically setting a possible deadline of 9 November.
But Israeli authorities said in August that three NGOs had already been de-registered for non-compliance with other parts of the guidelines: Rahma Worldwide, Catholic Relief Services, and Gaza Direct Aid.
Several aid workers told The New Humanitarian Rahma has been de-registered, but it was unclear if the same was true of Catholic Relief Services. It’s also unclear if Gaza Direct Aid – a small, volunteer-led operation – was ever registered. The first two organisations and the Israeli government press office did not respond to requests for comment. Gaza Direct Aid replied to messages but did not answer questions about their registration.
“I would be very surprised if they kicked 20 of the biggest NGOs out in one go. That’s not usually how they operate,” the third aid worker said. “Usually, they just do the frog-and-boiling-water thing, where it’s a small thing, and people will get outraged, but then they forget about it, and then suddenly that thing is normal, and they do it again, and then they do it again.”
The aid workers who spoke with The New Humanitarian said they were mystified by the decisions. “What we’re finding in general is that this whole thing is just very arbitrary and capricious,” the second aid worker said. This apparent randomness is a feature of Israeli government policy on humanitarian operations, they added: “It’s what they can get away with in the moment – and if they can’t get away with it, they back off for three, six, 12 months, and then they try again a different way.”
That uncertainty seems designed to divide organisations and create a sense of fear, the aid workers told The New Humanitarian.
Rumours that a certain NGO got approved raise questions about what they did to get their registration. “It’s also sowing, within the sector, mistrust, resentment, and fear,” the first aid worker said.
“We’re stronger when we stick together,” they continued. “What we’re worried about is that it’s also going to lead to divisions within the sector.”
That same strategy is what has helped Israeli authorities get away with increasing restrictions on humanitarians. “The reality is, organisations were afraid; policymakers didn’t do enough to stop this. And now, it’s just out of control,” the aid worker said. “We have people dying of starvation in Gaza, and at the same time, we’re being forced to chase diplomats being like, ’Please send a letter to the Israeli government telling them not to implement this policy.’… It’s so ridiculous. Just let us save lives.”
Edited by Eric Reidy.