Addis Abeba — In early June 2025, the House of Peoples' Representatives unanimously approved the Ethiopian Disaster Risk Management Proclamation. First introduced to parliament on March 18, the proclamation called for the creation of the Ethiopian Disaster Risk Management Commission as an autonomous federal agency. According to the explanatory notes, its primary objective is to establish a comprehensive legal framework for disaster risk reduction, response, and recovery. The law further introduces an integrated Disaster Risk Management (DRM) system that recognizes civil society organizations (CSOs) as key partners, while also imposing strict compliance requirements and significant penalties for violations.
Resilience in law, preparedness in practice
The proclamation demonstrates several important strengths that align with international best practices in DRM and global resilience frameworks. First, it is consistent with the Sendai Framework for Disaster Risk Reduction 2015-2030, reflecting the four Sendai priorities--risk understanding, risk governance, risk-informed investment, and preparedness to "build back better." Although the Sendai targets (A-G) are not explicitly cited, the Proclamation operationalizes them in practice. Embedding these priorities and referencing Sendai indicators ensures interoperability in monitoring and evaluation systems with global frameworks.
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The law establishes a whole-of-cycle DRM process, extending beyond emergency response to prevention, preparedness, mitigation, timely response, and rehabilitation. Ethiopia's approach--moving from prevention to preparedness, then response and recovery--aligns with international guidance, which underscores that legislation should formalize both pre-disaster risk reduction measures (such as risk assessments, early warning systems, and contingency planning) and post-disaster recovery protocols to enhance resilience and ensure sustainable outcomes.
It elevates DRM as a constitutional duty and a state-led responsibility. Framing disaster management as a national obligation aligns with the African Union Programme of Action for the Implementation of the Sendai Framework (2015-2030), which emphasizes strong state ownership and regional cooperation in DRM governance.
The proclamation advances clarity through standardized terminology, defining key DRM concepts such as risk, mitigation, early warning systems, and vulnerability. Establishing a common lexicon across government levels to reduce coordination failure and enhance coherent implementation. Furthermore, it places strong emphasis on prevention and preparedness, prioritizing risk reduction, early warning systems, and resilience-building. This reflects global good practice, which highlights the efficiency and inclusivity gains of shifting resources upstream toward local early warning systems, social protection linkages, and community-led preparedness.
The law adopts a multi-sectoral framing, formally recognizing CSOs as critical partners in resilience-building. Under Article 13, CSOs and other non-state actors--such as the Ethiopian Civil Society Council, Red Cross and Crescent, Inter-Religious Council, Media Council, and business representatives--are institutionalized within the Disaster Risk Management Council, ensuring direct involvement in shaping national DRM policy and governance. Global guidance emphasizes formalizing community and CSO representation in local DRM processes, risk assessments, and EWS operations by ensuring multi-stakeholder engagement. The Proclamation further strengthens CSO engagement through principles of participation, collaboration, and inclusivity [Art. 4(5-7)]; Commission oversight in licensing, capacity building, and coordination [Art. 9(3,17,21)]; and lead sector institutions' coordination mandate [Art. 19(5)]. Operationally, CSOs contribute as trained volunteers [Art. 2(28)], facilitate community education programs [Art. 25(3)], coordinate charitable activities [Art. 25(5-6)], provide financial support to the Disaster Risk Response Fund [Art. 29(2)], and integrate DRM into private and community plans [Art. 9(3)]. Collectively, these provisions establish a robust framework that embeds CSOs at both policy and operational levels, enhancing sustainability, accountability, and equity in Ethiopia's disaster risk management system. This mirrors lessons from community-based disaster risk management approaches, which stress that codified CSO and community engagement enhance sustainability, accountability, and equity of outcomes.
In addition, the proclamation ensures coherence with climate resilience agendas, creating space for joint planning between DRM and climate change adaptation strategies. This reflects the growing global consensus that DRM laws must be integrated with national climate change adaptation and resilience policies to address systemic risks.
The establishment of the Ethiopian Disaster Risk Response Fund represents a notable strength of the law. Its diverse funding sources--ranging from domestic resource mobilization mechanisms (loans, digital banking charges, insurance premiums, flight ticket surcharges, and data usage fees) to international donations and government budget allocations--reflect global recommendations on predictable disaster financing. The success of this mechanism will depend on transparent access rules, accountability, and the availability of localized financing windows such as micro-grants.
The law establishes a whole-of-cycle DRM process, extending beyond emergency response to prevention, preparedness, mitigation, timely response, and rehabilitation."
Finally, the proclamation integrates humanitarian assistance safeguards, underscoring principles of timeliness, impartiality, and dignity in relief operations. This aligns with the Core Humanitarian Standard (CHS) and global lessons and best practices on principled humanitarian response, reinforcing Ethiopia's commitment to protecting affected populations.
Strengths overshadowed by oversight gaps, risks
While the proclamation demonstrates notable strengths, several potential weaknesses remain. Safeguards are required across multiple areas to ensure that DRM is implemented effectively, impartially, and accountably. First, there are concerns around accountability and oversight of central authorities. The Commission, though autonomous, is directly accountable to the Prime Minister [Art. 5(1,2)] and is granted extensive powers, including licensing NGOs, managing funds, owning property, and entering contracts [Art. 9(21); and 12, Art. 9(32)]. While principles of transparency and accountability are mentioned [Art. 4(4,8)], mechanisms for enforcement remain underdeveloped. Without independent oversight, public reporting, or grievance channels, there is a risk of opacity, politicization, and even misuse of discretionary powers, as past aid agency suspensions in 2021 and the Aid Diversion Crisis (2023) illustrate. While central authority strengthens national leadership, it risks limiting the autonomy and flexibility of CSOs, whose collaboration may be interpreted as strict compliance with top-down directives. Ethiopia-specific research documents how restrictive governance previously narrowed CSO roles.
The second weakness is related to participation and governance of the Disaster Risk Management Council. Although its multi-sectoral composition is a strength [Art. 13], decision-making procedures are not clearly defined. A quorum of just half the members is sufficient [Art. 15(2)], raising concerns that major decisions could be taken without broad representation. Moreover, with the Prime Minister chairing the Council and appointing members [Art. 13(1-2)], there is a need for transparent appointment criteria to prevent politicization and ensure balanced participation of non-state actors.
There is also ambiguity surrounding institutional roles and mandates. Lead sector institutions are required to "collaborate, coordinate, and lead" [Art. 19(5)], but without clarification, the term "lead" may be interpreted as directive authority, limiting CSO independence. Similarly, provisions on "vulnerability-based targeting" [Art. 9(29-30)] could be vulnerable to bias if not transparently and evidence-based applied. Additionally, the Prime Minister's power to declare a state of emergency without prior Council submission [Art. 23(2)] risks unchecked authority without sufficient oversight.
Furthermore, there are gaps in enforcement and legal safeguards. While the Proclamation outlines the rights of victims and vulnerable people [Art. 25(1-6)] and prohibits misconduct such as aid diversion or misinformation [Art. 34], enforcement mechanisms and grievance systems are not sufficiently detailed. Without independent oversight and clear sanctions, victims may struggle to access redress, and violations may go unpunished, weakening accountability.
The other weakness is risks arising in funding and resource mobilization. The centralization of resources through the national DRM fund [Art. 29(2)] could limit CSO independence, innovation, and flexibility. The absence of direct local funding windows and simplified fiduciary rules restricts localization and may hinder rapid anticipatory action and last-mile service delivery. Accessible micro-grants at regional and woreda levels are necessary to safeguard community ownership.
In addition, concerns exist regarding decentralization and the localization agenda. Ethiopia's federal constitution (Arts. 50 & 52) grants residual authority to regions, and national DRM policy emphasizes community-centered approaches. However, centralization at the EDRMC risks weakening regional and woreda councils, creating disconnects between national frameworks and local realities. Stronger localized fiduciary mechanisms and decision-making authority are needed to preserve community ownership and resilience.
Finally, equity considerations highlight risks of exclusion of vulnerable populations. Internally displaced people require representation, grievance systems, and civil documentation. Women and girls need sex- and age-disaggregated data, quotas, GBV-sensitive services, and budget lines. People with disabilities require inclusive early warning, evacuation, and shelter design. Pastoralist and agro-pastoral groups need tailored mobile services and rangeland governance systems. Youth must be engaged through livelihood programs, training, and digital feedback mechanisms. Without explicit safeguards, these groups risk marginalization, undermining the inclusivity principle [Article 4(5-7)].
CSOs confront harsh penalties, operational hurdles
CSOs engaged in disaster risk management and humanitarian assistance face significant risks under the Proclamation, largely stemming from the Prohibited Acts [Art. 34] and Criminal Responsibilities [Arts. 35-36]. While the framework intends to safeguard accountability, the breadth of prohibitions, coupled with stringent sanctions, creates risks of over-criminalization, operational burden, and political interference.
First, severe sanctions for prohibited acts pose major risks. The diversion of aid [Art. 34(1)], misinformation to procure aid [Art. 34(3)], obstruction or delay in aid delivery [Art. 34(4)], provision of aid to non-entitled persons [Art. 34(5)], and false relief requests [Art. 34(6)] are all criminalized. Penalties range from imprisonment of six months to twenty-five years and fines up to 1,000,000 Birr [Art. 36(1-4)]. Additional prohibitions, including substandard packaging of humanitarian food [Art. 34(11)], aggravating disaster risk through political, economic, or social activities [Art. 34(7)], or prolonged dependency on humanitarian support [Art. 34(8)], further expand CSO liability. Without clear distinctions between intentional fraud and good-faith administrative errors, legitimate CSO operations risk undue criminalization.
Second, high compliance burdens may disadvantage smaller and grassroots CSOs. Strict requirements on reporting, monitoring, procurement, and fund management [Art. 29, 34(10), 35] impose uniform heavy obligations that may overwhelm organizations with limited administrative capacity. The absence of risk-based or graded compliance systems risks narrowing participation to larger CSOs, undermining localization and last-mile service delivery.
Third, risks of political interference remain significant due to broad discretionary powers in aid allocation and enforcement. While impartiality is presented as a guiding principle, the strong executive control vested in the Council and Commission creates the potential for politically motivated targeting or exclusion of CSOs. Moreover, provisions requiring CSOs to collaborate with state and private institutions [Art. 19(5-6)] may be interpreted in ways that compromise organizational independence and restrict advocacy roles. These risks are further compounded by access constraints documented in the joint EHRC-OHCHR reporting, which underscores the need for independent review and transparent enforcement mechanisms. To mitigate these risks, inclusion and accountability measures such as stronger oversight mechanisms and the promotion of women's leadership in decision-making are essential.
Finally, reputational risks remain significant. Any allegation of involvement in prohibited acts, dependency-creating practices [Art. 34(8)], or operational mismanagement could damage trust among communities, donors, and partners, even without legal conviction.
CSOs engaged in disaster risk management and humanitarian assistance face significant risks under the Proclamation...."
Taken together, these risks highlight the need for clearer safeguards--such as explicit defenses for administrative errors, proportional compliance mechanisms, independent oversight, and transparent enforcement processes--to ensure that CSOs can contribute effectively to disaster risk management without undue criminalization or politicization.
Clarity on 'Prohibited Acts'
Evidence indicates that the vague "prohibited acts" clauses, combined with broad administrative discretion, have a chilling effect on legitimate CSO operations. The prohibited acts outlined in Article 34 of the Proclamation, however, are generally clear and specific in defining actions forbidden within the context of disaster risk management and humanitarian assistance. The provisions enumerate distinct acts with straightforward descriptions, leaving little room for ambiguity in most cases.
First, the majority of prohibited acts are described with a high degree of specificity. This includes diverting humanitarian aid, which is clearly defined as redirecting aid from its intended purpose, selling it, possessing it without authorization, or transferring it to a third party [Art. 34(1)]. Failure to implement precautionary measures that result in serious harm, such as the loss of lives or livelihoods, is attributed directly to administrators at federal or regional levels, even in the presence of early warning information [Art. 34(2)]. Providing false information or submitting exaggerated requests is explicitly framed as an attempt to procure humanitarian aid or claim assistance under false pretenses of a disaster [Art. 34(3)]. Delaying or obstructing aid is plainly prohibited, ensuring that humanitarian assistance reaches affected populations in a timely manner [Art. 34(4)]. Similarly, providing aid to unauthorized recipients [Art. 34(5)], making false relief requests [Art. 34(6)], exceeding allocated aid shares [Art. 34(9)], and violating food supply standards--including packaging, labeling, and contamination requirements [Art. 34(11)]--are all unambiguously prohibited.
Second, some provisions allow for a degree of interpretation but remain reasonably clear in their intent. This includes aggravating or creating disaster risks through "political, economic, social, or environmental activities" [Art. 34(7)], which may require contextual judgment to determine what constitutes risk-aggravating behavior. Additionally, prolonged humanitarian dependency is prohibited when it results in "incompetency and dependency" [Art. 34(8)]. While terms such as "prolonged period" and "dependency" are open to interpretation, the underlying intent is evident--to discourage aid practices that foster long-term reliance. Moreover, fund management obligations, including the failure to collect, deposit, or submit reports on time [Art. 34(10)], are generally straightforward, though their clarity is partially contingent on the guidance provided in Article 29.
Third, the linkage between prohibited acts and criminal penalties strengthens clarity. Article 36 directly ties violations to corresponding sanctions, ranging from fines to imprisonment (up to 25 years). For instance, aid diversion [Art. 34(1)] is explicitly linked to rigorous imprisonment and fines [Art. 36(2)], ensuring enforceability.
However, vagueness in certain terms creates risks. Phrases such as "dependency," "prolonged period," or "activities aggravating disaster risk" leave room for subjective interpretation. CSO leaders have raised serious concerns that, if interpreted broadly, these provisions could expose organizations to severe criminal liability for routine programming decisions or unintended administrative errors. In such cases, ambiguity does not just create compliance challenges--it poses significant operational and reputational risks, potentially chilling CSO engagement in humanitarian and DRM activities.
In conclusion, while the Prohibited Acts section is generally clear due to its detailed enumeration and direct link to criminal liabilities, areas of vagueness create uncertainty. Without further clarification, these provisions risk over-criminalizing CSO activities and undermining their independent, good-faith humanitarian efforts.
Implications for CSOs: Steps for action
CSOs engaged in disaster risk management and humanitarian assistance must proactively adapt to Ethiopia's DRM framework. The following priorities, drawn from the Proclamation and international best practices, outline essential measures for CSOs to operate safely, effectively, and independently.
The first priority is to plan for full alignment and secure formal representation. CSOs should align their DRM activities with the strategies of the Ethiopian Disaster Risk Management Commission (EDRMC) and national policies to ensure coherence and effectiveness. They should also seek formal representation--ideally with voting rights--within national, regional, and local DRM bodies. Reference models, such as the Somalia Revised National DRM Policy (2020) and IFRC governance guidance, can inform advocacy efforts and help secure meaningful inclusion in governance structures [Art. 19(5-6)].
The second measure involves upgrading accountability systems. CSOs must implement digital tracking, feedback mechanisms, and comprehensive beneficiary registries to prevent aid diversion, ensure proper targeting, and avoid exceeding allocated shares. Risk-based internal audits and accessible complaints mechanisms are critical for accountable operations and compliance with the Proclamation's provisions on prohibited acts.
Furthermore, CSOs should pivot toward disaster risk reduction (DRR) and preparedness. This includes prioritizing proactive measures such as local hazard mapping, community early warning system (EWS) operations, nature-based solutions, and safe construction awareness. Step-by-step, replicable approaches will strengthen community resilience while aligning with the Proclamation's emphasis on prevention, preparedness, and mitigation.
In addition, institutionalizing risk-informed development and capacity building is essential. CSOs must integrate DRM and DRR principles into all development programming, including livelihoods, WASH, health, and local government planning. Linking anticipatory action with social protection mechanisms can help prevent unintended disaster risk and reduce prolonged dependency. Ongoing staff training in DRM standards, compliance, and scalable program approaches is also critical for effective, consistent, and legally compliant operations.
Finally, CSOs should invest in legal and compliance literacy. Given the explicit "prohibited acts" and severe criminal responsibilities, organizations should conduct scenario planning to anticipate risks, pre-agree evidence standards with authorities, and monitor enforcement patterns. Legal literacy is crucial to avoid sanctions, navigate administrative discretion, and learn from past CSO restrictions, thereby ensuring safe, independent, and accountable engagement in humanitarian and DRM activities.
Gaps vs. Good Practice: Advocacy priorities
Participation Mechanics. CSOs and communities require clear, formalized roles in DRM governance across national, regional, and local levels. While the Proclamation establishes the federal Council, it does not mandate formal councils at regional or local levels. Advocacy should focus on specifying how CSOs and communities participate in risk assessments, EWS operations, and recovery planning, including the development of participation mechanisms such as quotas, voting rights, quorum rules, public agendas and minutes, and notice periods. This will ensure meaningful engagement, accountability, and inclusion in DRM decision-making, even in the absence of formal subnational councils.
Localization Finance. Local CSOs often lack direct access to resources, and the Proclamation does not explicitly allocate funding to them. Advocates should push for a reserved portion of the national DRM fund for local CSOs through direct micro-grant windows with simplified procurement and reporting requirements. Embedded technical assistance should accompany these grants to strengthen local administrative, operational, and financial capacity.
Proportionate Oversight and Due Process. Oversight mechanisms must balance accountability with fairness. Directives should include risk-based audits, clear mens rea thresholds to distinguish between administrative errors and intentional fraud, accessible administrative appeal routes, independent review panels, and publication of enforcement statistics. These measures will ensure transparency while protecting CSOs from undue criminalization under the "Prohibited Acts" provisions.
Open Data and Transparency. Timely and accessible information strengthens trust and efficiency. Advocacy should mandate public release of early-warning bulletins, needs assessments, distribution plans, and fund allocations in machine-readable formats. This enables CSOs, local authorities, and communities to make informed decisions, verify equitable resource allocation, and participate effectively in risk reduction and disaster response planning.
Capacity Building at Scale. Sustainable DRM requires continuous learning and skills development. Funding should support recurring, certified training programs for CSOs and local administrations on DRM standards, including EWS management, logistics, monitoring and evaluation, and inclusive approaches that consider gender, age, and disability. This ensures that both federal and regional actors are capable of implementing risk-informed development in line with the national framework.
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Advocacy Consideration - Regional Governance Structures. Although the Proclamation does not mandate formal councils at the regional or local level, regions are empowered to enact their own disaster risk reduction frameworks, strategies, and laws compatible with the national Proclamation. CSOs can advocate for the creation of inclusive, transparent regional governance structures--potentially in the form of councils or advisory bodies--to ensure systematic participation, integration of regional plans with the EDRMC, and strengthened local disaster risk management capacity.
If-Then Scenario Mapping: Conceptual overview
Scenario mapping is a structured approach that links policy or regulatory decisions ("If") with expected outcomes ("Then"). In the context of Ethiopia's DRM Proclamation, it helps CSOs, policymakers, and communities anticipate the consequences of regulatory choices, especially regarding participation, transparency, compliance, and local ownership. By visualizing possible pathways, stakeholders can identify risks, opportunities, and necessary safeguards.
CSOs engaged in disaster risk management and humanitarian assistance must proactively adapt to Ethiopia's DRM framework."
First Scenario: Top-Down Directives Without Participation or Transparency
If the DRM directives retain top-down approval mechanisms without formal quotas for CSOs or communities, and if transparency measures are weak at national, regional, or local levels, then CSOs are likely to act mainly as implementers rather than decision-makers. Furthermore, small or local CSOs may exit the sector due to heavy reporting and compliance burdens, and "prohibited acts" could create a chilling effect on aid, which would leave vulnerable populations, including IDPs, pastoralists, women, youth, and people with disabilities, underserved.
Second Scenario: Embedded Participation, Transparency, and Risk-Proportionate Compliance
Conversely, if the directives embed meaningful participation, transparency, and risk-proportionate compliance, then CSOs can co-lead risk-informed development initiatives across WASH, health, livelihoods, and social protection sectors, while also contributing actively to risk assessments, Early Warning System operations, and recovery planning. In addition, micro-grant windows and direct funding to local CSOs would accelerate anticipatory action and last-mile service delivery and, when combined with simplified procurement and reporting procedures, reduce administrative bottlenecks.
Moreover, if sanctions are structured to target intentional fraud while good-faith administrative errors are handled proportionately, and if independent appeal mechanisms and published enforcement statistics are implemented, then accountability is enhanced without discouraging legitimate operations. As a result, equity Key Performance Indicators (KPI), such as GBV-sensitive services, disability-inclusive EWS, and pastoral mobility corridors, would show measurable improvements, while transparency and participation strengthen monitoring, verification, and community trust.
Therefore, embedding inclusive, transparent, and risk-proportionate mechanisms transforms CSOs from passive implementers into co-leaders of disaster risk reduction and resilience-building, whereas centralization without safeguards risks exclusion, inefficiency, operational overreach, and reputational hazards.
Bottom line for CSO leadership
The Ethiopian DRM Proclamation presents both opportunities and risks for CSOs. It positions them as key partners in disaster risk reduction, preparedness, response, and recovery, while also imposing strict compliance requirements and severe penalties that could constrain operational space.
CSOs should treat the Proclamation as a conditional opportunity. To stay effective, they must strengthen accountability and compliance systems, align programs with national DRM priorities while maintaining community-led approaches, leverage regional strategies and international standards in policy dialogue, and advocate for meaningful participation and access to local funding.
CSOs are expected to be active collaborators--participating in emergency risk assessments, EWS operations, vulnerability-based targeting, community education, and volunteer mobilization--while contributing financially to the national Disaster Risk Response Fund. Compliance with prohibited acts and humanitarian regulations is critical, alongside proactive risk-informed programming.
Strategically, CSOs can use the Proclamation to co-lead inclusive, community-driven, and risk-informed DRM, shaping Ethiopia's resilience agenda while safeguarding organizational autonomy and sustainability. AS
Editor's Note: Nigussie Tefera serves as the Humanitarian Forum Coordinator and HIV Project Coordinator at the Consortium of Christian Relief and Development Associations (CCRDA). He is also a humanitarian and governance specialist with extensive experience in social accountability, community engagement, and project coordination. Nigussie is also a postgraduate student in Coaching & Mentorship for Leaders in Organizations at Leeds Beckett University. He can be reached at [email protected]
