When Russia's full-scale invasion of Ukraine began in February 2022, the humanitarian response that followed was unlike almost anything the sector had seen in recent history: enormous in scale, rapid in tempo, dominated by a combination of well-established INGOs, newly formed diaspora organisations, and local civil society actors who had never operated in a humanitarian response framework.
HQAI has conducted audits in several Ukraine response organisations since 2022. Here are our candid reflections on what we found — and what it means for accountability in surge contexts.
The Accountability Infrastructure Gap
Many of the organisations that mounted significant Ukraine responses in 2022 had strong programmatic capacity — they knew how to deliver services. What many lacked, particularly smaller or newer organisations, was established accountability infrastructure: complaint mechanisms, MEAL systems, community consultation processes, safeguarding procedures scaled for rapid staff growth.
This gap is not unique to Ukraine. It is structurally embedded in how the sector responds to new crises. The first months of any rapid-onset response are dominated by delivery — and accountability systems are treated as something to build once the crisis "settles down." In Ukraine, as in Syria, Yemen, and South Sudan before it, that settling-down never fully arrived.
What Accountability Looks Like in Conflict Surge
Community accountability in active conflict contexts requires different mechanisms than stable programme environments. Physical suggestion boxes and community meetings are frequently not feasible or safe. Digital feedback channels require literacy and connectivity that cannot be assumed. The geographic mobility of affected populations makes systematic consultation difficult.
What works, in our audit experience, is investment in community liaison roles — trusted individuals, often from affected communities themselves, who can bridge the information gap between organisations and displaced populations. Organisations that invested early in these roles consistently demonstrated stronger accountability practice in our audits.
The Localisation Reality Check
Ukraine was widely cited as an opportunity to demonstrate localisation — Ukrainian civil society was highly capable and already mobilised. The reality, as with every previous "localisation opportunity," was mixed. International organisations that channelled significant funds and decision-making authority to local partners tended to have stronger accountability outcomes. Those that positioned local organisations as implementation subcontractors reproduced the familiar accountability gap.
The Sector's Accountability Challenge in 2025
Three years into the Ukraine response, the accountability challenge has shifted from surge to sustain. Organisations that entered Ukraine without established accountability systems now need to build them while managing fatigue, staff turnover, and reduced funding. HQAI is working with several Ukraine-response organisations on CHS verification — helping them use the audit process as a structured accountability improvement tool.