The fall of the Syrian regime on December 8 was met with widespread relief—not only among Syrians, but also among humanitarian workers long frustrated by Bashar al-Assad’s restrictive and manipulative policies. Many hoped the regime’s collapse would mark the end of the bureaucratic and administrative barriers that had hindered independent humanitarian operations for decades.
While Syria’s transitional authorities have expressed a willingness to cooperate with international organizations, many of the same obstacles persist. Chief among these is the requirement for independent organizations to operate under a so-called “umbrella system,” which grants extensive oversight to designated national partners who function as de facto regulatory bodies.
While acknowledging the competing priorities during the transition, Syria’s new authorities must urgently prioritize breaking with these past practices. Enabling principled, needs-based humanitarian action is essential to avoid replicating the same structures that undermined relief efforts under the previous regime.
To support this shift, international humanitarian organizations (IHOs)—including UN agencies and INGOs—must work together to develop a clear framework that adheres to the core humanitarian principles: humanity independence, neutrality, and effectiveness.
Failing to act now would squander a rare opportunity—and leave millions of Syrians to continue suffering under a system that was supposed to be left behind.
Glimpse of Hope
For decades, the Syrian regime imposed multiple administrative processes on humanitarian organizations to limit their ability to operate independently. Every aspect of aid delivery—from what to distribute, to whom, and even who could be hired—required prior negotiation and was often dictated by the authorities.
The regime’s extensive interference in aid operations restricted the operational environment, undermining organizational independence, imposing local partners, influencing procurement procedures, and preventing direct monitoring and evaluation.
These restrictions have undermined humanitarian principles, impeded needs assessment, and enhanced the control of the former regime over funding allocation. Moreover, these sweeping controls enabled the former regime to weaponize humanitarian aid, using it as a tool of war; collectively starving civilians in rebel-held areas to achieve military gains. Between 2013 and 2018, starvation was systematically employed as a weapon of war in several areas, including Eastern Ghouta, Yarmouk Camp, Madaya, and Zabadani.
Observations from recent trips to Syria clearly indicate that the regime’s ousting has brought about several positive changes, including greater freedom of speech and a more enabling environment for civil society organizations.
Since the regime change, Syrian authorities have publicly committed to a more open and cooperative approach toward civil society.
Engagement with UN agencies and international organizations has also improved, with many being allowed to operate for the first time in the capital Damascus, after years of being restricted to Syria’s western or eastern regions. Syrian officials also met with a UN delegations to discuss ways to enhance coordination between the two.
Conversations with international humanitarian workers in Damascus also indicated an improvement in the operational environment. This includes notifying the authorities of field visits, instead of waiting for approvals from the regime.
Continuation of the Past
Despite promising signals from Syria’s transitional authorities about engaging with international organizations and forging a new path, bureaucratic and administrative obstacles continue to hamper efforts to tackle the country’s worsening humanitarian crisis.
In a recent report, Human Rights Watch warned that transitional authorities have revived restrictive registration policies reminiscent of the Assad era. Chief among them is the requirement for IHOs to operate under an "umbrella system" managed by a small number of state-sanctioned gatekeepers.
This system is hardly new. Under Assad, IHOs were funnelled through the Syrian Arab Red Crescent (SARC) or the Syria Trust for Development—both closely tied to the regime. The setup stifled independence, limited operational freedom, obscured aid distribution, and enabled state interference in donor-funded relief.
Notably, the transitional authorities implemented some restructuring of these key entities. Khaled Hboubati was replaced as head of SARC by Mohammad Hazem Baqlah, who had previously led its volunteer medical services. The Syria Trust for Development was renamed the Syrian Development Organization, its board of trustees was dissolved, and a committee was appointed to assume its financial and administrative responsibilities.
However, despite these changes, these entities continue to function as gatekeepers in much the same way as before. This continuity has raised serious concerns that the same old constraints—masquerading under new management—could continue to undermine humanitarian principles and operations.
Human Rights Watch also flagged the imposition of a re-registration requirement for all organizations, including long-established ones. Many now face even more complex and onerous procedures than those enforced under Assad.
Restrictive Regulatory Model
The concerns about the operational environment for non-governmental organisations (NGOs) is not only limited to international organisations. A report by Syrian organization Lugarit adds to the alarm about the future of local NGOs.
The report warns that, despite initial gestures of openness, the regulatory environment remains opaque and difficult to navigate. A major point of friction is the lack of clarity around the respective roles of the Ministry of Social Affairs and Labor (MoSAL) and the Humanitarian Action Coordination Office (HAC). Their overlapping mandates have created confusion, delays, and inconsistent decisions. The HAC’s rigid monitoring and murky approval process has further deepened the operational challenges.
Worryingly, there is growing fear that the authorities may be drifting toward an increasingly restrictive regulatory model—shrinking the space for NGOs and threatening the modest progress made since Assad’s fall.
Conversations with Syrian civil society representatives inside the country suggest that many of these obstacles arise from the continued application of outdated laws and regulations. What makes matters worse is the selective enforcement of these laws, often manipulated to suit the post-regime context. This ambiguity has given individual bureaucrats wide latitude to interpret rules as they see fit, resulting in arbitrary implementation and widespread inconsistencies.
Opportunity for Change
While recent developments raise concern, the transitional nature of the current period presents a genuine opportunity to reform outdated regulations and practices. Encouragingly, reports indicate that the MoSAL has begun engaging with Syrian civil society organizations to develop a new regulatory framework for NGOs. These efforts suggest a willingness to build the new framework in consultation with local actors—an opportunity that must be seized to ensure the resulting regulations reflect the needs and expectations of Syrian civil society.
Similarly, UN officials have informed the author that transitional authorities are also planning to review and revise the regulatory framework governing IHOs operating in Syria. To make the most of this moment, IHOs need to coordinate both internally and with the authorities to ensure the new rules protect their operational independence.
Strengthening the autonomy of IHOs is essential to uphold humanitarian principles. Aid must be allocated based on need—not political directives—and delivered fairly and without discrimination.
This requires simplifying bureaucratic procedures and curbing transitional authorities’ interference in both humanitarian and non-humanitarian activities. IHOs must also secure full and independent access to relevant data, activities, and geographic areas. The selection of local partners should be based on merit and technical capacity—not political affiliation or loyalty.
For effective engagement, IHOs need to present a unified front, agreeing on the operational conditions necessary to preserve principled humanitarian action. Forming a joint coordination team would help streamline engagement with the authorities and ensure that IHO input is conveyed in an organized and consistent manner.
This period should also be used to enhance coordination and information-sharing mechanisms—both among IHOs and between IHOs and the transitional authorities. Demonstrating how these mechanisms can address past failings, including corruption and misconduct under the Assad regime, will be vital to rebuilding trust and securing greater operational space.
Finally, UN agencies and donor states must reinforce these efforts by ensuring transparency and accountability across all levels of humanitarian programming.
Breaking Old Patterns
As Syria’s humanitarian crisis deepens, despite the lifting of sanctions, whose impact will take time to materialize, the cost of inaction grows by the day. Without urgent steps to remove, restrict and overhaul outdated regulatory frameworks, the suffering of millions of Syrians will only intensify. Past restrictions severely undermined the ability of humanitarian organizations to deliver aid effectively and hampered their ability to secure funding, as donors remain reluctant to invest in opaque and constrained environments.
The scale of humanitarian needs in Syria is staggering, and any delays in reforming the current environment will directly affect the ability of vulnerable communities to access critical support.
The transitional government must seize this moment to break from legacy policies and prioritize the creation of an enabling, transparent, and principled operational environment. Removing restrictive systems that limit flexibility and independence is essential—not just to restore aid flows, but to ensure that humanitarian assistance is delivered impartially, effectively, and at the scale required to meet growing needs.
This is not just a policy imperative—it is a moral one.