Almost three years since Russia's full-scale invasion of Ukraine, international actors still monopolize humanitarian response funding, leadership, and policy influence. There has been insufficient structural change to effectively localize the humanitarian response, despite ample funding, support for localization pilots, and engagement on the part of Ukrainians.1 A genuinely Ukrainian-led humanitarian response would be more cost-efficient and would also be better positioned to stay and serve people in need in the face of expected donor cutbacks in the future. The survey described in this report and publicly accessible data indicate:

Because Ukrainian organizations remain mainly as sub-contractors rather than prime grantees, many L/NNGOs struggle to develop their capacity to rapidly absorb significant amounts of additional funding directly from donors.3 L/NNGOs have yet to cohere into operational consortia that could stand in for INGO-led consortia. There is also no nationally-led pooled fund as yet that could augment the United Nations Office for the Coordination of Humanitarian Affairs (OCHA)-led Ukraine Humanitarian Fund (UHF) and direct significantly more funding to L/NNGOs. At the same time, some L/NNGOs are particularly vulnerable to possibly imminent cuts by state donors to UN agencies and INGOs. Seventy percent of L/NNGOS surveyed reported having ongoing contracts with UN agencies while all reported having contracts with INGOs. A heavy emphasis on keeping L/NNGOs as sub-contractors rather than strengthening their independent capacity is widely recognized as hindering the resiliency of L/NNGOs - and humanitarian responses overall - after international actors exit because of funding shortfalls.

In Ukraine, all of the donors surveyed described growing support for and urgency around transitioning to a locally-led response. If there is to be a real shift, however, donors across the board will have to place much greater trust and confidence in L/NNGOs - and at a faster rate - than they already have. They can do so with confidence given the lack of corruption indicated in our survey:

Increased trust and confidence on the part of donors will not be enough, however, to ensure that decreasing funding finds its way directly to Ukrainian responders and the people in need they serve. Ukrainian NGOs must also build out operational coalitions that can produce aid economies of scale to replace international intermediaries. At the same time, Ukrainian humanitarian actors need to maintain strong oversight to ensure against corruption.