Making due diligence work for local partners
"Making due diligence work for local partners."
An interview with Joé Hein, NGO Humanitarian Action Focal Point, Ministère des Affaires étrangères et européennes, de la Défense, de la Coopération et du Commerce extérieur, Luxembourg
Without a dedicated internal due diligence department, Luxembourg has had to find smarter ways to assess risk, uphold standards and support partners without adding another layer of bureaucracy. That has meant looking for ways to harmonise donor requirements rather than multiply them.
A pilot project with Danida and Foreign, Commonwealth and Development Office (FCDO) provided a clear proof of concept. It showed that a single HQAI CHS audit enabled a Bangladeshi NGO to meet the compliance requirements of FCDO, ECHO, Luxembourg and Danida at the same time. This “one audit, multiple recognitions” model strengthens quality and accountability while cutting the duplication that wastes resources and too often sidelines local actors.
Luxembourg is now advocating for CHS verification to serve as a passporting tool. Independently verified evidence should help local NGOs gain more direct access to major funding streams, rather than forcing them through repeated, donor-specific due diligence processes.
The sector should avoid building new, competing mechanisms that demand even more from already stretched organisations. The CHS offers a common framework that puts people at the centre while giving donors credible evidence of quality and accountability.
Joé Hein, NGO Humanitarian Action Focal Point, Ministère des Affaires étrangères et européennes, de la Défense, de la Coopération et du Commerce extérieur, Luxembourg
Luxembourg has also tested this approach in practice. It has conducted a pilot scheme with HQAI to subsidise CHS audits for local partners in Palestine and has gone to the country level to understand how the model works in real contexts. In settings where Luxembourg does not have a direct diplomatic presence, CHS audits provide a reliable, independent assurance mechanism that complements existing bilateral safeguards.
At a time when the Humanitarian Reset could either simplify the system or create another layer of compliance, this matters. The sector should avoid building new, competing mechanisms that demand even more from already stretched organisations. The CHS offers a common framework that puts people at the centre while giving donors credible evidence of quality and accountability.
Luxembourg’s approach shows what it means for a donor to walk the talk: reduce duplication, trust independent verification, support local partners to meet shared standards and use due diligence to enable access rather than block it.
Luxembourg remains committed to evidence based, efficient and fair approaches that strengthen trust, enable equitable partnerships and improve assistance to crisis-affected communities.
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