Civilian Protection Monitor

United Kingdom

© Ray Harrington/Unsplash, 2021.

Country summary

In 2025, the United Kingdom’s CPM score remained ‘Uncommitted’.

The United Kingdom’s approach to civilian harm mitigation and response contains important examples of good practice in policies and select recent military campaigns; however, a prevalent lack of transparency means there is little information available in the public sphere on how the UK aims to mitigate harm from its own military actions. This opacity also hinders external assessment of whether these policies are meaningfully embedded in institutional practices, training, and operational decision-making.

Where elements of the approach can be reviewed publicly, there are some evident and significant gaps. The UK does not, for instance, appear to consistently track or investigate allegations of civilian harm according to the same standard as its allies and independent monitors. Without such systems, the MoD cannot hope to verify whether its operational mitigation mechanisms are effective in preventing harm to civilians.

In the past, the UK has had systems in place to offer voluntary compensation payments to civilians harmed by military operations, particularly during earlier conflicts in Iraq and Afghanistan; however, in recent operations, these mechanisms have been removed and legislation has been introduced to limit options for civilians to seek redress, meaning there is now no effective reparations mechanism in the UK. The lack of standardised systems combined with insufficient public reporting undermines the MoD’s ability to learn from incidents, demonstrate accountability to those affected, and engage credibly with external stakeholders.

Overall, the UK’s approach to protecting civilians during its own military operations is in urgent need of greater clarity, transparency, and institutionalisation. To address this, the MoD should develop CHMR-focused policies that build on existing human security frameworks. These reforms should be accompanied by the introduction of standardised civilian harm tracking, incident investigation, and post-harm response mechanisms.

Textbox 1

Key changes in 2025

  • Baseline Review into the UK approach to CHMR | Over the last year, the UK has conducted a baseline review of its human security strategy, including any CHMR capabilities. 1 Such baseline reviews have been recommended by civil society across publications and fora, particularly in the political declaration on the use of explosive weapons in populated areas, which the UK signed on to in November 2022. 2
  • International contact group | During 2025, the UK took on the co-chairing of the International Contact Group on Civilian Harm Mitigation and Response, alongside the Netherlands. 3 This is a valuable forum for bringing together states, NGOs, independent experts, and others working on CHMR.
  • UK support for US attacks in Yemen | In March 2025, the UK MoD provided air-to-air refuelling support to the US, to “aid the self defence of a US aircraft carrier” from which strikes against the Houthi forces in Yemen were targeted. 4 In late April, the UK MoD conducted the first airstrikes in Yemen in coordination with the new Trump administration. 5 While no allegations of harm to civilians were found through open source research specifically from the British airstrikes, the US campaign that the UK supported was found to have been extraordinarily deadly for civilians in the country, with as many civilians killed in Yemen in 52 days under Trump as the 23 years preceding. At least two airstrikes from this period were assessed to be apparent war crimes by human rights groups. 6
  • Preparing for large-scale combat operations | In June, the Government released ‘The Strategic Defence Review 2025 – Making Britain Safer: secure at home, strong abroad’, a “root-and-branch review of UK Defence”. 7 The SDR sets out how the UK will contribute to a more lethal NATO in the context of war in Europe, the threat of large-scale combat operations with Russia and new technologies. In spite of the risks such warfare would bring to civilians, the SDR does not mention the risk of civilian harm from UK actions in such combat, what systems it has in place to mitigate such risks, nor the concept of human security.
  • National reviews of UK defence | In August, the Government released the ‘National Security Strategy 2025: Security for the British People in a Dangerous World’. 8 While it has a strong focus on the re-emergence of threats from near-peer states as well as the risks and opportunities from new tech, the NSS does not touch on the protection of civilians or the risks to civilians from UK military action even in a large-scale combat operation.
  • Civilian harm tribunal against the MoD | In December, a tribunal on the UK’s transparency on civilian harm mitigation found that transparency on the UK’s CHMR policies is a public interest issue, and that the current lack of transparency on the UK’s policies may “undermine public confidence”. 9 Evidence during the tribunal revealed that a politically-elected minister can ultimately decide whether to accept allegations of civilian harm, casting serious doubt on the independence of this system, and that the MoD does not have a codified standard of proof when it comes to accepting allegations of harm to civilians. 10 Despite ruling that the lack of openness may damage public confidence, the tribunal ultimately ruled that the MoD is not required to release the forms on the single civilian casualty it admits from the wars of the last 12 years. The court decided this based on evidence discussed in closed court, meaning the evidence used is not public.

Ongoing processes

  • Inquiry into civilian harm in Afghanistan | The Independent Inquiry Related to Afghanistan was launched in December 2022 to investigate serious allegations of repeated extra-judicial killings of military-age civilian men by UK Special Forces in Afghanistan between 2010 and 2013, and a subsequent cover-up by senior officials in the Special Forces and MoD. 11 It is unclear when the Inquiry will deliver its findings.  However, the inquiry has already heard from an expert witness that investigations of alleged unlawful conduct resulting in civilian harm led by the Royal Military Police under Operation Northmoor were “fundamentally poorly resourced” from start to finish and “hampered by both indecision and/or apathy within the chain of command and by lack of assistance by UK Special Forces.” 12

Textbox 2

Allegations of civilian harm from UK strikes in Operation Inherent Resolve

Since 2014, the UK has dropped thousands of munitions in the war against the so-called Islamic State. It claims that those strikes have killed or wounded more than 4,300 ISIS militants, but has only accepted responsibility for the death of one civilian. 13

In contrast, Airwars estimates that at least 8,266 civilians were killed by the anti-ISIS coalition, to which the UK was the second-biggest contributor. 14 Each contributor to the coalition had different rules of engagement and thresholds for civilian harm, meaning it is not possible to say that the UK was automatically responsible for an amount of civilian harm proportionate to the amount of airstrikes conducted by the RAF. Yet even the most diligent military cannot avoid civilian harm when using explosive weapons in a populated area and the sheer amount of munitions dropped by the RAF suggests it would have been impossible to avoid extensive civilian harm.

In 2023, Airwars and The Guardian trawled through thousands of previously classified documents to uncover civilian harm incidents linked to UK airstrikes, and conducted site visits and witness interviews with those affected. In total the research identified 41 incidents that may have been caused by the UK; many of these were redacted in a way that made it impossible to verify which states was responsible. But in eight incidents, in which the Coalition accepts civilians were killed, it appears the UK conducted the airstrike in question. In these incidents at least 32 civilians died.

In a later airstrike in 2025, the UK targeted a Syrian man on June 10th, who was alleged to be a member of Daesh/ISIS. The civilian/combatant status of the man was disputed in public sources and several sources claimed he had been killed alongside a second person. 15 However, there has been no public response from the MoD to acknowledge this allegation and no evidence available in the public sphere that any investigation has been conducted. While there was a brief recognition that the UK had conducted this airstrike on the MoD website, this has since been removed and was not on the website at the end of 2025.

1. National policy

E

The national policy or system of policies, strategies, and guidance adopted by the executive branch of government and its organs (including security institutions) that establishes clear authorities, responsibilities, and guidance for the prevention, mitigation, and response to civilian harm. A national policy framework, when combined with effective implementation of its provisions and formalised engagement with civil society actors can be helpful for communicating a government's commitment to mitigate harm to civilians.

Read More

The UK has a policy framework on the protection of civilians by UK forces, developed over the last decade. The policies contain elements of good practice, particularly by examining the direct impact of war on civilians in the wider context of human security, reflecting on the indirect and reverberating consequences of warfare.

UK policies are, however, overwhelmingly focused on the UK’s commitment to mitigating harm caused by others. There are no policies in place to guide the UK approaches to operational mitigation, tracking of harm, investigations, nor transparency or responding to harm. These shortcomings hinder the practical implementation of civilian harm mitigation and response (CHMR) efforts. In 2025, a tribunal made a landmark ruling that there is a public interest in transparency on civilian harm and that the UK’s lack of publicly available civilian harm policies may “undermine public confidence” in the system’s “integrity and comprehensiveness”. 16

Recommendations
Develop an approach to civilian harm mitigation and response from UK military operations in key policies and strategies
  • As a matter of priority, the UK should develop policy and doctrine that clearly define how it will mitigate and respond to civilian harm arising from its own military activities. This framework must be applicable across the operational spectrum, including large-scale combat operations involving territorial defence or offensive manoeuvre, as well as enduring counter-terrorism and other security operations. The necessary provisions could be incorporated into existing instruments, such as Joint Services Publication 985 on Human Security in Defence, or issued as a standalone policy; either way, it should clarify how the MoD’s approach to CHMR is part of and/or aligns with broader Protection of Civilians (PoC) and human security agendas.
  • At a minimum, the policy should specify procedures for the systematic tracking, recording, and investigation of allegations of civilian harm, including evidentiary standards and analytic methodologies for determining whether it is more likely than not that harm occurred. It should further establish mechanisms for identifying trends and patterns of harm, ensuring that operational lessons are captured and translated into adaptive operational mitigation measures. Finally, it should provide clear direction on response measures where harm has occurred, including acknowledgement, reporting, and other appropriate remedial or accountability actions. These mechanisms should be integrated into defences readiness initiatives and planning for future conflict scenarios.
Increase the transparency of the UK’s approach to civilian harm
  • The UK should increase the public transparency on the methodologies and procedures used to track, assess, investigate, respond to, and learn from allegations of harm from UK actions. Ensuring transparency and accountability in these areas is crucial for military legitimacy, trust-building, and global cooperation. Implementing further transparency on this topic would align the UK to many of its allies.
Formalise engagement with independent experts and civil society actors 
  • The UK MoD should formalise regular engagement with independent experts and civil society organisations, who hold important knowledge and lessons on CHMR practice in the UK and elsewhere, through both open and closed-door roundtables and workshops which allow for tangible engagement. There has been some engagement in recent months, but this remains ad-hoc and personality-driven, rather than institutionalised.
Provide definitions of key terminology 
  • This should include clarity on terms such as ‘civilian harm’ and ‘credible’ allegations. Clear and consistent terminology is essential to avoid misinterpretation and ensure the uniform application of policies. This will enhance coordination across UK departments and international partners.
Require periodic public reporting on the implementation of the JSP985 and the UK Approach to PoC
  • Instituting mandatory, regular reports would increase accountability and allow for tracking progress. This would also highlight areas where further improvements are necessary.

1.1 National policy framework

E

The government has adopted a comprehensive national policy framework on mitigating and responding to civilian harm resulting from its own military operations, including clear definitions of key terminology such as 'civilian harm'.

The UK has a policy framework aimed at protecting civilians, notably through the Joint Services Publication 985 on Human Security in Defence (2024) and the UK Approach to Protection of Civilians in Armed Conflict (2020). 17

These documents contain elements of good practice, primarily by placing the direct impact of war on civilians in the wider context of human security reflecting the indirect and reverberating consequences of warfare. These documents also delve into the effects of warfare and conflict on different demographics, e.g. by examining the gendered impact of conflict on women and the impact on insecurity on children.

In 2025, the UK took on co-leadership of the International Contact Group on Civilian Harm Mitigation alongside the Dutch MoD, sustaining an important forum to bring together states, civil society, and experts working on this topic. 18

At the same time, steps can be taken to significantly improve the policy framework in key areas. Notably, while the policy framework highlights the UK’s commitment to mitigating harm caused by others, it offers little in addressing civilian harm from UK operations. There is a lack of  commitment to, or clarification on, civilian harm tracking methodologies by the UK MOD, unclear standards for investigations, and a lack of a response policy. While the Approach to PoC commits the UK to investigate credible allegations of harm, there is no clarification on who will do these investigations, what methodology will be applied, or what is considered a ‘credible’ allegation. These shortcomings hinder the practical implementation of civilian harm mitigation efforts.

In late 2025, a UK tribunal on a case brought by Airwars made a landmark ruling “…that there is a lack of publicly available information on the procedure usually followed in assessing civilian harm, and that the nature, comprehensiveness and robustness of such a procedure is a matter of public interest. The absence of any published procedure at all has the potential to undermine public confidence as to its integrity and comprehensiveness”. 19

In early 2025, the UK released two major reviews of its defence and national security strategy, as well as the Responsible AI Senior Officers’ Report 2025. 20 However in spite of the ‘root and branch’ nature of the reviews, and the risks presented to civilians from the military use of AI, there is no reference to civilian harm mitigation and response, or related terms such as human security, in any of these reports, nor any acknowledgement that harm to civilians can occur from UK military action in spite of efforts to avoid it. It is positive that the UK is integrating a policy on Responsible AI, as well as officers to permeate this throughout the ministry; to strengthen this, it should be made more concrete by adding specific language on how harm to civilians from AI-supported technologies and systems will be mitigated.

1.2 Clear policy language

U

The policy contains clear and actionable language and commitment to civilian harm mitigation and response.

The language in UK policies on civilian harm mitigation is relatively clear, yet there are gaps in clarity on the terminology used, including the definition of ‘civilian harm’. 21 The lack of clear details on the UK’s approach to tracking, investigating, assessing, or responding to civilian harm from its own operations leaves a significant gap. Among other things, it remains unclear what reporting channels currently exist for independent monitors and civilians wishing to report allegations of civilian harm to the MoD directly.

The JSP985 refers to human security as a “moral, legal and strategic imperative”, 22 strengthening its framework. Yet it often relies on normative language, noting what the MoD “should” do, in laying out best practice for the UK to adopt on human security. Coupled with the lack of reporting requirements and lack of clarity about resourcing available to the teams responsible for implementation, the JSP985 at times comes across as a series of recommendations for the MoD to take on board, as opposed to an internal guide on how to protect civilians effectively.

1.3 Clear implementation guidance

E

Policy and implementation guidance is clear and includes defined roles and responsibilities.

The MoD has a dedicated team in place for Human Security policy development. 23 The key document on this activity, the JSP985, lays out recommendations for which teams should be responsible for which aspects of human security, including organisational responsibilities on strategic as well as operational levels. 24 Several elements laid out by the JSP985 have been implemented since its publication in 2020; e.g. human security career paths and specific training on human security have been established, with bi-annual Human Security in Military Operational Planning courses being conducted at the Defence Academy of the United Kingdom. 25

Additionally, Human Security Advisors have been situated across all three services to provide guidance on aspects of human security and “support the advancement of human security across Defence.” 26

The JSP does not, however, set out how CHMR activities – that is, mitigation of harm from UK military action itself – will be implemented, nor how the concepts of human security and CHMR interact. There is no regular public reporting on the JSP to ensure that its commitments are implemented more broadly and there is no clarity on how the teams in question are being resourced to perform new tasks or secure buy-in from military units or commanders.

1.4 Budget and resources

EL

Funding, personnel and time are given toward implementation of CHMR policies.

The MoD has a central Human Security team focused on policies and guidance related to CHMR, and representing British commitments to human security in international fora. There are also Human Security Advisors placed throughout the MoD, though these are staff with a broad scope and limited resources, often with a very limited focus on mitigating harm from UK operations. While the budget available to this team is not publicly available, the existence and continued funding of these roles demonstrates a commitment to human security.

There continues to be a lack of clarity on how other teams in the MoD are resourced and trained to take on tasks outlined in the JSP985.

2. Civilian harm tracking

U

An internal (military or security force) process by which an armed actor gathers and analyses data about civilian harm incidents in order to better prevent, mitigate, and address harm in the future.

Read More

While the UK has outlined the importance of civilian harm tracking in rhetoric, it does not currently have a comprehensive approach to performing this function in practice. 27 Allies and independent monitors have found evidence of significant harm from UK airstrikes in Iraq and Syria, yet the MoD maintains that it has evidence of only a single civilian casualty from its contributions to warfare over the last decade, indicating either a lack of engagement with the available evidence or a threshold for admitting civilian harm that is far higher than those of its allies.

During a tribunal decided in December 2025, which found a lack of publicly available information on the UK’s procedures for assessing civilian harm and public interest in understanding such procedures, the Deputy Director of the MoD responsible admitted being unaware of a systematic approach to tracking harm allegations or a consistent UK written approach to investigating civilian harm. 28

Textbox 3

Airwars tribunal against the Information Commissioner’s Office and the Ministry of Defence

In early December 2025, a verdict was given in a tribunal between Airwars and the Information Commissioner’s Office and the Ministry of Defence. The tribunal centered around Airwars’ request to make public documents related to the single civilian casualty acknowledged by the MoD in the last decade. While the tribunal upheld the MoD’s refusal to release information on the specific incident in question, it provided damning insight into CHMR systems and gaps in the UK MoD;

  1. The tribunal found that the current lack of transparency undermines confidence
    The tribunal found that the UK’s failure to publish its civilian harm assessment processes damages public confidence in the integrity and comprehensiveness of how such harm is judged. The judge emphasised that “there is a lack of publicly available information on the procedure usually followed in assessing civilian harm … The absence of any published procedure at all has the potential to undermine public confidence as to its integrity and comprehensiveness; while there is no reason to doubt the good faith and competence of everyone involved, high level assurances do not provide the same confidence as a published procedure that can be scrutinised.”
  2. Ministers can decide whether the UK accepts civilian harm
    Evidence at the tribunal revealed that UK ministers can effectively decide whether to accept civilian harm findings, raising concerns about political influence over what should be an objective assessment.
  3. Unclear evidentiary standard
    A Deputy Director from the MoD admitted he could not specify what standard of proof the UK uses to determine civilian harm, suggesting the process lacks a clear and consistent threshold.
  4. Discrepancies with coalition records
    The UK’s sole acknowledged civilian death in Syria does not align with coalition data, which found no corresponding strike; the MoD attributed the discrepancy to an “administrative error.” However, in spite of the UK claiming to have addressed this error, the Coalition has not updated its finding that no civilian was harmed on the day and area in question.
  5. National security overrules disclosure
    Although the tribunal recognised the public interest in transparency, it upheld the MoD’s refusal to release information on the single civilian it acknowledges killing during OIR, citing national security exemptions that keep the process opaque.Source: De Silva and Dyke, ‘How does the UK determine if it killed a civilian? Five takeaways from Airwars’ tribunal against the MoD’, 2026, Airwars, available at: https://airwars.org/how-does-the-uk-decide-if-it-killed-a-civilian-five-takeaways-from-airwars-tribunal-against-the-mod/ 
Recommendations
Build - or strengthen - an institutional approach to proactively track civilian harm 
  • The MoD should proactively track civilian harm allegations from its own military action, using best practice methods including by reviewing open-source information, such as allegations emerging in the local language on social media channels or in local reports from journalists, civil society, local authorities and other third-party actors. The data gathered should be consistent across operations and deployments, and should include the sex and age of those harmed, their names, and more. Ensure strong data management on all allegations of harm to enhance institutional learning and strengthen mitigation of harm in ongoing and future operations.
  • Where the MoD finds that it cannot adopt best practices in investigating allegations of civilian harm, the department should clarify why it has been unable to do so, to allow civil society and experts to support the process of addressing challenges.
Establish a reporting channel for external reports

The UK should establish a reporting channel for civilians and third-party actors to report allegations of harm to the MoD, to ensure those reviewing evidence are able to evaluate all available information (in line with partners and allies). Once an allegation has been reported, the MoD should make it clear when those involved should expect to hear back.

Use tracking mechanisms for operational learning
  • Ensure tracking mechanisms are built to allow decision-makers in the MoD to understand and respond to harm caused and improve tactics in warfare to reduce future harm, as well as reporting on casualties and broader harm. This will align tracking efforts with the overarching goal of preventing civilian harm through operational and institutional changes; it will also improve the UK’s ability to achieve military objectives.
Coordinate tracking and investigation systems 
  • The UK MoD should establish formalised coordination between civilian harm tracking systems and investigative mechanisms to ensure a consistent and reliable process. Standardising evidence collection and publishing clear criteria for what constitutes ‘credible’ harm allegations would enhance the reliability of investigations and foster transparency.

2.1 Tracking mechanism

U

The government has or plans for the capabilities, resources, personnel, and systems needed to track civilian harm, i.e., to systematically collect and analyse information on harm.

In several policy documents, the UK commits itself to tracking credible allegations of harm to civilians; yet in practice, the UK does not systematically or effectively track civilian harm. 29 It regularly reaches different conclusions from its allies, including the US, and independent monitors on allegations of harm. 30 There is no information available to the public on how the UK tracks, assesses, or investigates allegations of harm, and a lack of clarity on what evidence is required for an allegation to be investigated or found plausible.

The tribunal brought by Airwars (textbox 2) found that there is a lack of public information on the UK MoD’s systems and methodologies on CHMR. The tribunal also found that in the UK, in stark contrast to the systems of its allies, it is a politically elected minister who decides whether the UK accepts allegations of civilian harm – not the team who conducted the analysis. This raises significant concerns about the independence of the investigative process, and also notably marks a severe distinction from the UK’s allies, where the outcomes of civilian harm assessments are determined by investigating cells or units, even if the decision to release such outcomes publicly may remain a matter of political decision-making. 30

The 2018 JDP 3-46 on Legal Support in Joint Operations notes in passing that Standard Operating Procedures (SOPs) on recording civilian harm exist, yet the MoD has repeatedly admitted – both before and after the publication of this document in 2018 – that it does not collate information on civilian harm allegations. 32 The SOPs on civilian harm are not publicly available and are not mentioned in any other document. It is possible that these are referring simply to the BDAs (see textbox 3). There is no publicly available information on how data is archived and on which data and records assessments and investigations are based.

Textbox 4

Battle Damage Assessments

A Battle Damage Assessment (BDA) is a framework developed to evaluate the impact of the use of force, primarily focused on whether the munition used functioned as expected, whether the intended target was struck, and what the impact was on enemy combatants. If harm to civilians is observed in the immediate aftermath of the use of military force, this may also be included in a BDA, but they are not tools that are meant to give an insight into harm to civilians – especially as such harm often only becomes apparent in the hours, days and weeks following military action, when a BDA will already have been completed. 33 BDAs also often rely solely on visual evidence from fighter jets or high-altitude drones, which cannot hope to capture evidence of civilians caught under structures or rubble.

In one US-based study, it was found that BDAs missed harm to civilians that was later discovered by other investigative means in 19 out of 21 cases (over 90%). 34

An over-reliance on BDAs to understand civilian harm has characterised the approach of several major militaries, some of whom have recognised its limitation and developed separate (but interoperable) civilian harm tracking methodologies.

Textbox 5

Recording, tracking, assessment, and investigation 

The process of tracking and assessing civilian harm begins with comprehensive recording of incidents, where reports from various sources are gathered to document potential civilian harm. Key components of this step include establishing a reliable data-gathering mechanism, ensuring reports are collected in real-time or shortly after incidents, and cross-referencing sources to verify details about harm. Accurate recording forms the foundation for later assessments and helps in identifying patterns of harm over time.

In the civilian harm tracking phase, collected data is systematically organised and analysed to identify trends and specific incidents that may require deeper investigation. Tracking involves cataloging each event’s location, date, weapons used, and reported civilian impacts, and aggregating data to monitor the broader impact of military actions. This stage’s key elements include maintaining a clear database, ensuring the integrity and consistency of data, and analysing frequency and severity of incidents to prioritise cases for assessment or investigation.

The final steps, assessments and investigations, focus on evaluating the incidents’ credibility and conducting in-depth examinations of selected cases. During assessments, incidents are reviewed to determine if they meet criteria for further scrutiny, often involving corroborative evidence from multiple sources. Investigations delve deeper, with forensic analysis, interviews, and site visits (where possible) to establish accountability and identify operational mistakes or violations of law

2.2 Tracking to reduce harm through analysis

U

The tracking mechanism is effectively designed to produce meaningful analysis and insights that are used by military leaders to change tactics or procedures. The express and stated purpose of the tracking mechanism in policy and practice is to prevent, mitigate, and address harm and promote institutional and operational learning.

There is no public evidence to suggest that the UK MoD produces meaningful analysis on civilian harm from its own military operation to inform their practices. There is no public policy on how the UK facilitates institutional and operational learning on this activity.

In 2011, the UK admitted it does not centrally collate allegations of civilian harm. 35 In 2021, the MoD admitted that it still does not hold information on the number of civilian casualties linked to British military activity since 2001. 36 In a tribunal released in December 2025, the Deputy Director of the MoD team responsible for tracking and investigating harm admitted he was unaware of the standard of proof the UK used when investigating allegations of civilian harm, whether written procedure governed investigations, and whether the UK tracks allegations at a systemic level. This position was finally confirmed in a May 2026 Baseline Assessment commissioned by the Ministry of Defence (full analysis forthcoming in the 2026 country analysis), which noted that tracking systems were “absent” in the MoD, with any previous efforts at civilian harm tracking now systems that had “fallen into disuse”. 37 Without systematically tracking civilian harm and gathering allegations centrally, the MoD cannot hope to analyse patterns of harm – nor to reduce harm based on the findings.

2.3 Coordination with investigation mechanisms

R

Tracking mechanisms interact effectively with civilian harm investigations.

There is no information available to the public on how the MoD’s tracking mechanisms interact with investigations. Yet without an effective tracking mechanism, harm reports are likely to be overlooked and not investigated.

The confirmed lack of a civilian harm tracking system, combined with the admission during the 2025 Tribunal (textbox 2) that a Minister can ultimately decide whether the UK accepts an allegation of civilian harm both cast serious doubt on the independence of this system and its ability to coordinate independently with investigation mechanisms. 38 ]

2.4 Data management

U

Tracking mechanisms have reliable access to accurate information and sufficiently detailed records about military operations (e.g., troop movements, airstrikes, incident reports). Incidents and analyses are properly archived and retrievable years later.

The lack of an effective data management system on civilian harm has led to a number of errors, aside from the inability to detect harm or learn from these actions: for example, the UK MoD argued in the 2025 Tribunal that there was a discrepancy between UK records and coalition records on the number of civilian casualties in Operation Inherent Resolve, because of an ‘admin error’ in their own databases which had led to a gap in reporting. However, while the MoD claims this has now been fixed, the tally between the number of civilian casualties recorded by the coalition and the UK MoD remains disparate, suggesting a continued gap. 39

Additionally, updates to one of the few transparency mechanisms in the UK have become inconsistent: in relation to an airstrike against an alleged ISIS militant on June 10th, 2025, the airstrike was not initially added to the UK’s regular overview of airstrikes, until notified by Airwars of the apparent error. It was then added within 24 hours; however, by December, it had been quietly removed again without explanation. [[[See here for an archived version of the MoD’s website when it included the June 10th airstrike. At the end of 2025, this was no longer present on the MoD website. MoD, “News story
Update: air strikes against Daesh [archived]”, July 9th, 2025. https://web.archive.org/web/20250710014057/https://www.gov.uk/government/news/update-air-strikes-against-daesh]]]

3. Investigations

U

Formal inquiries (often in the form of administrative or criminal investigations) that can be used to elucidate facts, to understand the cause of harm, to identify relevant state and/or individual responsibilities, to facilitate the appropriate response and/or remedy, and even to exonerate.

Read More

The UK has made commitments to investigate civilian harm allegations. 40 However, this is undermined by a lack of transparency, consistency, and accountability on the UK’s approach to doing so, as well as the UK’s insistence that it has evidence of only a single civilian fatality from a decade of intense, urban warfare in spite of evidence to the contrary from independent monitors and allies. 41

While past policies such as those used during ISAF in Afghanistan showed a rhetorical commitment to investigating civilian harm, allegations have recently emerged of extensive extra-judicial killings of civilians, particularly military-age civilian men, at the hands of UK special forces in Afghanistan, as well as a failure to sufficiently investigate these allegations – and at times, evidence of attempted cover-ups. 42

Finally, campaigns launched after ISAF have seen less clarity on how allegations of harm are investigated and assessed, with a lack of reporting on airstrikes and allegations of harm from recent campaigns in Syria, Iraq, and Yemen.

Recommendations
Standardise and institutionalise the UK methodology on assessing and investigating allegations of civilian harm
  • The MoD should formalise and institutionalise its investigative methodology, including through the use of open source information and engagement with those affected and third party actors. When it is plausible that the UK caused the harm in question, investigations should include site visits and witness interviews where at all possible. The MoD should clarify both its threshold for the evidence needed to launch an investigation, and the criteria for deeming an allegation ‘more likely than not’. In its policies on this, the MoD should recognise that compliance with International Humanitarian Law requires continuous self-monitoring of state practice.
Use a sliding scale to determine the credibility of reports
  • It is recommended that the MoD uses a sliding scale to determine the credibility of reports rather than binary categorisation (e.g. it should use an approach of ‘more likely than not’ as opposed to ‘credible’ or ‘non-credible’), as adopted by allies and recommended by civil society experts. By institutionalising these practices, the MoD can build the capacity to respond swiftly to reports of civilian harm and avoid reliance on external inquiries.
Increase transparency and public reporting
  • The MoD should improve transparency by regularly publishing reports on its investigations. These public reports should include descriptions of the investigation process, evidence consulted, legal and factual findings and recommendations for preventing future harm as well as a detailed consideration of the possible provision of amends. This would add legitimacy to the UK approach to investigating and responding to harm, a vital step in countering misinformation from adversaries.
Improve interaction between investigations and response mechanisms
  • The MoD should develop a formal, transparent process to ensure that investigation findings are directly linked to response mechanisms, including amends payments and operational changes. This is in line with the practice of allies and recommendations from civil society groups.

3.1 Investigates all credible reports

U

Promptly investigates all credible reports of civilian harm, whether or not it is immediately clear that a violation of international law has occurred. Obtains relevant information from all internal, and, to the extent feasible, all external sources.

There is no information available on the current methodology used by the UK to investigate civilian harm, including what the MoD considers an allegation worth investigating, what avenues should be used by civilians and third party actors to submit allegations of harm, to what extent information from civilians and third-party actors (such as independent watchdogs) is included in reviews of information, who is responsible for launching and conducting investigations, if there is any form of independent oversight of investigations, and whether there is a policy dictating when the MoD reports on investigations, whether publicly or to those affected. The UK MoD has repeatedly admitted over the last ten years that it does not collate or hold figures on civilian casualties from its military actions. 43

The UK regularly reaches a different conclusion on allegations of harm than its allies and independent monitors; previous submissions of evidence by civil society organisations like Airwars, which contain evidence that the UK may have caused civilian harm, have been rejected by the UK, even where the coalition agrees harm likely occurred. 44

On two occasions, the UK MoD has released responses to FOIA requests outlining why they believe the UK was not involved in specific allegations of civilian harm. 45 These are helpful in providing an initial understanding of possible UK involvement. Yet these have only been released in response to specific FOIA requests and suggest gaps in the UK methodology: notably, even as the UK MoD suggests it needs more than coordinates to determine whether UK weapons struck a target, they have refused to engage with NGOs such as Airwars to review further evidence on strikes, including exactly the information they seem to require. 46 Additionally, while the Permanent Joint Headquarter (PJHQ) of the UK specifically stated, in response to a 2022 FOIA request, that the lack of on-the-ground investigators may have resulted in an under-count of adversaries killed and injured during Operation Shader, they emphasised that the same logic cannot be applied to suggest “that Civilian casualties may have occurred”. 47

The Prosecutor of the ICC opened a preliminary investigation into the MoD’s investigations of allegations of UK war crimes in Iraq in 2020. Evidence for war crimes were found, but these crimes were not prosecuted by the ICC because the Court could not demonstrate an intent to shield perpetrators from criminal justice; conversely, it also could not rule out such intent. In its findings from the preliminary examination, the ICC concluded that the Army’s initial investigations into possible war crimes in Iraq were “inadequate” and lacked a “genuine effort” to be independent or impartial. 48

Service police investigations into civilian harm in past campaigns have repeatedly been terminated before their planned ends amid significant political pressure, with whistleblowers emphasising that they had evidence of significant harm, at times amounting to war crimes. 49

In 2025, the UK conducted an airstrike on June 10th, targeting a Syrian man who was alleged to be a member of ISIS. 50 The civilian/combatant status of the man was disputed in public sources and several sources claimed he had been killed alongside a second person. 51 However, there has been no public response from the MoD to acknowledge this allegation and no evidence available in the public sphere that any investigation has been conducted. While there was a brief recognition that the UK had conducted this airstrike on the MoD website, this has since been removed and was not on the website at the end of 2025. 52

Textbox 6
Non-MoD reviews of civilian harm in the UK

While independent reviews of civilian harm allegations have been commenced in the UK to review harm which may have breached the law, these have come under significant political pressure. They have led to no prosecutions, and one of the most significant (the Iraq Historic Allegations Team (IHAT)) was terminated before its planned end in the midst of a political crisis. 53

When it was shut down in 2017 (before its planned 2019 end-date), 11 detectives working on IHAT told the BBC that the allegations they were examining amounted to war crimes. 54 When Operation Northmoor was launched, 52 allegations of harm to civilians from British Special Forces were initially to be investigated; however, it was shut down in 2019 before key Afghan witnesses could be interviewed by detectives. 55 This is now the subject of the ongoing Independent Inquiry relating to Afghanistan, which is examining alleged war crimes by Special Forces that focuses on accusations that SAS troops unlawfully executed Afghan civilians, particularly during night raids between 2010 and 2013. 56

These include claims that unarmed men were killed in their homes, often described as a pattern of targeting males of ‘fighting age’. 57 The investigation also examines a potential cover-up, where senior officials allegedly suppressed or failed to thoroughly investigate these actions. 58 Two major military police probes, which previously found insufficient evidence, are under renewed scrutiny as part of the inquiry. 59 It is important to note that these incidents do not reflect standing UK military guidance. Yet they do raise concern over the effectiveness of the UK’s internal reporting, investigation and transparency policies.

3.2 Conducts witness interviews and site visits

U

Investigating officers conduct site visits and/or conduct witness interviews or provide reasons why doing so is infeasible. If this is infeasible, there is clarity on how evidentiary gaps will be addressed.

There is no evidence of a structural approach within the MoD to conduct witness interviews or site visits, nor any public evidence that the MoD has conducted witness interviews or site visits in the last decade, in sharp contrast to other states monitored by CPM.

Independent monitors, media outlets, and local NGOs have collated several allegations of harm from UK airstrikes in Iraq and Syria since 2014 based on witness interviews and site visits; the MoD has not engaged with these organisations to understand the available evidence. 60

Conversely, the organisations that operate on the ground in the area where the UK claims its single civilian casualty from the OIR campaign was killed in 2018, found no recorded deaths in the area at the time of the purported strike and had no record of the UK MoD reaching out to them to secure information on these incidents, indicating that the UK did not conduct interviews with relevant Syrians on the ground. 61

3.3 Reports of investigation

U

Reports of investigations include a description of the process followed, the evidence consulted and included (including witness statements), information about its factual and legal findings, and recommendations for preventing a recurrence of civilian harm.

The UK MoD does not report publicly on how its investigations are conducted, the process followed, the evidence consulted, its factual and legal findings, nor recommendations for preventing recurrence.

In the past, the MoD has reported that the UK was not involved in specific incidents which are known to have caused civilian harm and/or that no civilian harm resulted from incidents that the UK was responsible for. 62 These reports provide no detail on how the MoD reached its conclusion and the findings often do not align with the findings of allies or independent watchdogs. The same is true for the one civilian casualty that the UK has admitted from OIR, where the Secretary of Defence said simply that the MoD has undertaken “routine and detailed post-strike analysis”, likely to refer to the BDA process (see textbox 3). 63

3.4 Interaction with response mechanisms

U

Investigations connect meaningfully to response mechanisms. Civilians who report incidents are informed of the possible response they can expect from the state. Acknowledgements of harm following the conclusion of an investigation address the next steps in terms of amends.

There is no evidence to suggest that the UK’s investigations into allegations of harm connect meaningfully to any response mechanisms. There is no formal avenue for civilians to report allegations to the MoD and no communication on the process civilians can expect, if they do manage to report allegations. Amends schemes from past campaigns have been abolished, leaving no functional avenues for civilians to claim reparations outside of limited criminal prosecution. 64

3.5 Criminal investigations

U

Incidents of a suspected criminal nature are referred to an independent, impartial investigative authority for investigating criminal violations.

The UK has a strong focus on compliance with International Humanitarian Law in doctrine and guidance. 65 The Service Police are responsible for investigating allegations of breaches of service law, which includes the criminal law of England and Wales. Under the Armed Forces Act (2006) section 113, all commanding officers have a legal duty to report any possible serious offence that may have been committed to the service police. 66 Commanders are also responsible for ensuring proper investigation of suspected unlawful activity. The 2018 JDP 3-46 on Legal Support to Joint Operations emphasises: “All personnel must be confident to use lethal force within the relevant legal framework and, where applicable, rules of engagement. However, the need to investigate matters where either the law or our standards of conduct may have been breached is fundamental.” 67

In practice, there have been some serious concerns about the effectiveness of the service police’s approach to investigating allegations of civilian harm. This is especially true in light of their role in allegations of repeated harm to civilians from British special forces in Afghanistan, and the cover-up that allegedly followed. 68 These echo past concerns on the independence and effectiveness of Service Police investigations into serious offences, and whether they are always compliant with Article 2 of the European Convention on Human Rights. This has been the subject of two judicial reviews (the Saifullah and Noorzai cases). 69

In October 2021, Sir Richard Henriques was commissioned by the Defence Secretary to conduct a review into how allegations of serious criminal wrongdoing on overseas military operations are raised and investigated. The review report contains 64 recommendations, including the establishment of a Defence Serious Crime Unit. 70 In 2022, the Defence Serious Crime Command was formed which has taken responsibility for the investigation of all serious offences by service personnel. This sits outside the single services’ chain of command, to ensure operational independence. 71
Based on public reporting, the DSCU is primarily focused on crimes committed by UK troops against other troops; it is unclear what role they play in investigating evidence of civilian harm.

The UK’s investigatory practices have primarily emphasised retrospective criminal investigations triggered by civil litigation. 72 Official figures reveal one prosecution of UK armed forces personnel for war crimes overseas in the last 25 years. 73

4. Public reporting & transparency

U

Systems and procedures to ensure that the public and institutions of public oversight are made sufficiently aware of civilian harm, and to protect the right of victims to pursue remedy. Information may be limited or redacted due to privacy concerns for affected civilians, to safeguard other ongoing investigations or for national security reasons, but these reasons should be subject to review.

Read More

In the early years of OIR, the UK was very transparent on the time and location of its airstrikes, setting a strong example for allies. However, this practice has not been institutionalised or carried forward to new operations, such as those countering the Houthis in Yemen. The UK never reported consistently on civilian harm allegations.

As mentioned in Textbox 2, a tribunal found that there is such a lack of transparency from the MoD on its approach to civilian harm that it is likely to undermine public trust in its institutions.

The MoD often highlights and acknowledges difficulties in gathering data on civilian harm in conflicts, yet has failed to engage with international and local NGOs offering data and evidence, it has not taken on best practices used by allies and independent watchdogs performing this task in the same conflict zones, and it has not laid out a strategy for how it will address such challenges.

Recommendations
Institutionalise reporting on the use of force  
  • When it comes to OIR, the UK is among the most transparent states when it comes to reporting on the use of force in Iraq and Syria. This should be standardised across the MoD and other operations, such as Operation Poseidon Archer in Yemen. The data reported should be institutionalised and include time, date, and location within ten metres, in line with best practice.
Enhance transparency in civilian harm reporting 
  • The UK should regularly publish detailed reports on civilian harm resulting from its military actions, including the source, location, and nature of harm. These reports should explain any discrepancies with other estimates from NGOs or other independent sources as well as detail what mitigating measures were taken.
  • To enhance transparency, the MoD should implement a policy for routinely investigating and reporting on civilian harm beyond deaths and injuries, to also include reverberating and non-physical forms of harm.
Enhance oversight 
  • Establish an independent body – or empower an existing one, such as the Intelligence and Security Committee – to evaluate the MoD’s transparency practices, ensuring that withheld information is justified and that the highest levels of disclosure are achieved without compromising security.
Prepare transparency policies for high-intensity conflict 
  • The MoD should ensure that transparency policies are actively applied in future operations, particularly as the military prepares for more complex and large-scale conflicts. This has vital importance, not only for the civilians likely to be affected by such wars, but also for legitimacy, the pursuit of military objectives, and the effectiveness of force protection.

4.1 Discloses time and location of operations

U

Makes public information, to include time and location, of operations including airstrikes, except in circumstances when doing so would place civilians or security personnel at risk.

In the past, the UK has made public the time and location of its airstrikes against ISIS in Iraq and Syria, setting good practice for its allies. 74 In this campaign, the UK released approximate locations and intended targets for more than 1,700 airstrikes conducted by the RAF against ISIS. 75 In 2022, the MoD released a list of every strike that had killed militants during its contribution to OIR in response to a FOIA request, including the date and location to city level. 76   Although the locations of airstrikes given by the MoD are often too imprecise to enable matching with on-the-ground reports of civilian harm by independent monitors (with best practice is the location given within ten metres), the UK was the most transparent partner in the coalition on these details. 77

This practice, had it been continued, would have led to a higher score in this indicator. However, the UK’s past focus on transparency on airstrikes was not institutionalised and has not been replicated consistently in the current iteration of the anti-ISIS operation nor other recent campaigns. Additionally, details on allegations of harm to civilians from the UK’s strikes were never included in these regular updates.

The UK has not consistently reported on the strike location or time of an airstrike conducted in Syria in June, nor for airstrikes conducted in Yemen in 2025, suggesting a decline in the consistency of reporting.

4.2 Civilian harm reporting

U

Regularly issues and disseminates reports on civilian harm resulting from military operations that includes an estimate of casualties, the source of harm, the type of harm experienced, and the location of the incident(s) and any reasons for discrepancies with estimates or accounts from other sources such as NGOs or the media.

While the UK MoD was leading the way on regular reporting on the date and location of airstrikes during OIR, it has never regularly released information on alleged or actual civilian harm caused by its military actions.

The UK admitted to having caused only a single civilian casualty during OIR, an intense, urban campaign that unfolded over a decade. Moreover, media reporting and reporting by independent civilian harm monitor, Airwars, indicates that the airstrike which killed the single civilian was not recorded on the UK’s own list of airstrikes that killed or injured militants (in spite of a UK claim that the civilian in question was killed alongside militants), the US-led Coalition’s records of strikes in which civilian harm was deemed ‘credible’, or any local media reporting or allegations from communities, suggesting poor internal reporting mechanisms and a lack of coordination with allies. Information about this casualty was not released as part of the regular updates on airstrikes conducted in Iraq and Syria, but in a parliamentary statement two months after the incident occurred.

The UK frequently emphasises that it is impossible to gather data on civilian harm in the contexts it engages in, and that it therefore cannot report on it. Yet tangible lessons on best practices on civilian harm tracking and assessing presented by allies, notably the US, and independent monitors such as Airwars, which could drastically improve the UK’s ability to gather data on civilian harm, do not appear to have been adopted.

In the past, journalists and analysts have relied on requests made under the Freedom of Information Act (FOIA) to seek information about the UK’s approach to civilians in warfare. Yet FOIA requests have increasingly been rejected on the basis of national security, with the lowest rate of access to information granted in 2025 since records began.

Textbox 7

No response from MoD to allegations of civilians killed in Syria in 2025

On June 10th, the UK RAF conducted an airstrike in Syria, targeting, in their words, “a known Daesh terrorist”. This led to civilian harm allegations from several sources, with multiple sources contesting the militant status of the man targeted and other sources claiming a civilian second person was killed alongside the targeted man. This airstrike was not initially added to the UK’s overview of airstrikes, until notified by Airwars of the apparent error and it was added; it was then quietly removed again without explanation by December 2025. The MoD did not respond to queries from Airwars about the status of this case in 2025.

Airwars gathered all publicly available evidence and geolocated the incident to an exact location; however, in line with past practice, the UK MoD issued no public response to this allegation of harm and continues to maintain that it has evidence of only one civilian being killed by the UK contribution to Operation Inherent Resolve.

4.3 Public disclosure of process and records

U

Releases information about mitigation tactics, investigative processes and records to the public whenever possible. Shares criteria used for the 'credibility' assessment and investigation of harm allegations.

While the UK emphasises that it takes the utmost care to mitigate harm to civilians in its military campaigns, it has not released information about mitigation practices or tactics for 12 years. There is no information available in the public sphere on how the UK determines the credibility of allegations of harm or how it conducts its investigations.

While the MoD often cites its thorough mitigation tactics as a reason civilian harm is unlikely to have occurred, it remains vague about what these tactics are, how officers are trained in civilian harm mitigation or human security more broadly, and why the UK’s mitigation measures are assumed to be nearly 100 percent effective even in intense urban conflicts, where allies with similar mitigation measures acknowledge having killed over 1,000 civilians.

During OIR, the MoD had a strong focus on the dangers and roadblocks to recording civilian harm and collating data in air campaigns, without presenting a strategy to overcome these difficulties, such as adopting best practices from allies and independent monitors who are able to document harm in the same contexts. 78

5. Post-harm response

U

Efforts to acknowledge and express condolence for harm, to include offers of monetary and non-monetary forms of post-harm assistance.

Read More

The UK currently has no functional national system for providing amends to those harmed by its military actions. During counterinsurgency operations in Iraq and Afghanistan, the UK government implemented a structured system for offering compensation for civilian harm and property damage. 79 However, during OIR, there was a stark shift in policy, with no regular approach to ex gratia payments to civilians. 80 This appears to have been replicated in more recent operations, such as Operation Poseidon Archer in Yemen, which has led to allegations of civilian harm that the UK has not responded to. 81

Additionally, legislative changes limiting compensation claims have further restricted civilians’ ability to seek redress, effectively curbing the UK’s willingness to acknowledge or compensate for harm altogether. 82

Recommendations
Establish an enduring institutional approach to responding to harm to civilians 
  • A consistent and enduring approach to redress for civilian harm should be established to enable the effective processing of claims and requests, across different types of operations. When there is no ground presence, allow requests to be processed through embassies, bases, local intermediaries or online platforms, in line with best practice. These processes must be accessible in the local language and include various types of harm. The amends schemes should be actively brought to the attention of civilians on the ground.
Take a comprehensive view of response 
  • Future compensation efforts should be informed by the needs and preferences of victims. The MoD should consult affected individuals and communities before implementing compensation projects or other forms of responses, ensuring that both monetary and nonmonetary forms of redress are appropriate and culturally sensitive. The MoD’s official policies should recognise a broad range of harms, including psychological, social, and economic impacts. This comprehensive definition of harm would allow for meaningful and effective responses to civilian harm and ensure that aspects of victims’ losses are more comprehensively addressed.
Emphasise moral responsibility in amends policy 
  • While strategic arguments for response can help create buy-in for a progressive amends policy within the military, policies on amends should include an emphasis on the inherent moral responsibility of recognising and addressing civilian harm across different types of operations, incorporating a full spectrum of responses, including public acknowledgments and formal apologies.

5.1 Process for amends

U

The government implements a functional, timely, and adequately resourced process to receive and process requests and proactively provides monetary and non-monetary amends for harm caused by operations.

The UK does not currently have a process to provide amends to those harmed by UK military operations. 83 While the UK has provided amends in past campaigns, there is no evidence of similar attempts in recent campaigns, including the single acknowledged OIR incident.

In past operations with troops present on the ground, civilians could report harm directly to British forces and compensation schemes were quite commonplace; such compensation was not paid in acknowledgement that a crime had been committed, but in recognition that even military operations conducted in compliance with the law can – and often do – cause life-changing harm to civilians. For instance, the UK provided at least £5.4 million in payment to civilians harmed in Afghanistan (4,740 cases) and £26.4 million in relation to Iraq prior to OIR (1,893 cases). 84 This included compensation for loss of life, as well as property damage. By 2016, this system had been removed, as acknowledged by the then-Defence Minister: “In the special circumstances of operations in Iraq and Afghanistan HM Treasury authorised the Department to make ex-gratia payments in-theatre in appropriate circumstances to nationals of those countries who had suffered harm or damage as a result of UK military activities. No such authorisations are currently in force.” 85

Civilians who suffer harm from UK overseas operations could in theory still submit a public liability compensation claim to the Common Law Claims & Policy (CLC&P) function within the MOD, if the harm they suffered resulted from an IHL violation by UK forces. 86 CLC&P Guidance – available only in English – provides contact details online for those wishing to enquire about compensation claims. Such claims, however, are very difficult to pursue as it is difficult for overseas victims to gain a UK-based lawyer and they do not have access to the information available to the commander at the time of the attack. 38 While this route was used by civilians in Iraq and Afghanistan prior to 2016 to seek compensation, there is no public evidence to suggest that civilians affected by Operation Inherent Resolve have been able to use this route. 88

In July 2021, the UK Overseas Operations (Service Personnel and Veterans) Act was adopted. The Act, heavily criticised by civil society, legal experts, and parliamentarians, sets a six-year time limit for bringing civil claims in relation to overseas operations. 82 The only acts which are exempt from this limitation are war crimes, crimes against humanity and genocide, torture, sexual offences and those offences relating to children. It was created in 2020 in response to the perceived large number of civilian harm claims the UK faced from its military engagements.

5.2 Acknowledgement

U

The government publicly acknowledges responsibility for harm.

The UK has acknowledged harm in past campaigns, but there is no evidence to suggest they ever apologised to the victims or survivors directly. In OIR, when the UK accepted responsibility for a single civilian casualty, the Defence Minister called the incident “deeply regrettable,” but there is no evidence to suggest the MoD attempted to identify the family and loved ones of the civilian killed or to offer acknowledgement to them. 90 This goes against the UK MoD’s own guidance in the JSP985, in which it emphasises: “Where incidents, genuine or otherwise, are alleged, it is important that the UK engage appropriately in order to maintain public support. Losing their support can directly or indirectly impact the mission.” 91

There are significant gaps between the single civilian death acknowledged by the UK in OIR and the level of harm identified by allies and independent monitors. 92 In spite of the MoD’s apparent recognition that there is a gap between civilians harmed by UK actions, and the evidence they are able to use to acknowledge such harm, there has been no clarification in public about how this gap will be addressed, nor how best practices from allies and independent monitors will be reviewed and adopted in the UK. The UK MoD has refused to engage with evidence presented by independent monitors. 60

5.3 Comprehensive, victim-centred condolence

U

Policies governing the offer and provision of condolences should be broadly defined, culturally appropriate and sensitive to local needs as defined by those affected.

The UK does not currently have a system to provide amends or condolences to the victims of its military action. There is no evidence available in the public sphere to suggest the UK MoD has attempted to engage with civilians directly affected by their military operations.

Back to country overview ↑ Go back to top

Author

This analysis was authored by Megan Karlshoej-Pedersen (Airwars), with contributions from Erin Bijl (PAX, Airwars volunteer), Emily Tripp (Airwars), and Jessica Garlasco (Airwars). Lucca de Ruiter (Radboud University) co-authored the 2024 version of this report, which forms the foundation of the current report. We extend our sincere gratitude to the academics, practitioners, officials, and members of civil society who provided peer reviews and valuable feedback. 

  1. Karlshoej-Pedersen. “Tracking civilian harm from the use of explosive weapons in populated areas”, May 2025. https://article36.org/wp-content/uploads/2025/07/Tracking-civilian-harm-from-use-of-EWIPA.pdf ↩
  2. A summary report of the Baseline was released by the UK MoD in April 2026. Since this report covers January-December, 2025, analysis of this summary is not included here. However, analysis of the baseline can be found elsewhere.; Karlshoej-Pedersen and Boillot, “Implementation Toolkit on Protection of Civilians from the Use of Explosive Weapons in Populated Areas”, November 2025. https://airwars.org/wp-content/uploads/2025/11/Airwars_Art36-EWIPA-toolkit.pdf ↩
  3. Hansard, “Armed Conflict: Civilians. Question for Ministry of Defence, UIN 97137, tabled on 4 December 2025”, December 9th, 2025. https://questions-statements.parliament.uk/written-questions/detail/2025-12-04/97137 ↩
  4. Craig, Iona. “How Starmer aided Trump’s deadly bombing of Yemen”, March 18th, 2025. https://www.declassifieduk.org/how-starmer-aided-trumps-deadly-bombing-of-yemen/ ↩
  5. Beale and Durbin, “First UK strikes on Houthis in Yemen under Trump”, April 30th, 2025. https://www.bbc.com/news/articles/c1k41z4g3pzo ↩
  6. De Silva, et al., “The U.S. killed almost as many civilians in 52 days as the previous 23 years of U.S. action in Yemen“, June 18th, 2025. https://trump-yemen.airwars.org/operation-rough-rider; Amnesty International, “Yemen: “It is a miracle we survived”: US air strike on civilians held in Sa’ada detention centre”, October 29th, 2025. https://www.amnesty.org/en/documents/mde31/0367/2025/en/: Human Rights Watch, “Yemen: US Strikes on Port an Apparent War Crime”, June 4th, 2025. https://www.hrw.org/news/2025/06/04/yemen-us-strikes-on-port-an-apparent-war-crime ↩
  7. MoD, “The Strategic Defence Review 2025 – Making Britain Safer: secure at home, strong abroad”, June 2nd, 2025, p3. https://www.gov.uk/government/publications/the-strategic-defence-review-2025-making-britain-safer-secure-at-home-strong-abroad ↩
  8. Cabinet Office, “Policy paper. National Security Strategy 2025: Security for the British People in a Dangerous World”, June 24th, 2025. https://www.gov.uk/government/publications/national-security-strategy-2025-security-for-the-british-people-in-a-dangerous-world ↩
  9. Dyke and de Silva, “How does the UK determine if it killed a civilian? Five takeaways from Airwars’ tribunal against the MoD”, January 19th, 2026. https://airwars.org/how-does-the-uk-decide-if-it-killed-a-civilian-five-takeaways-from-airwars-tribunal-against-the-mod/ ↩
  10. Ibid.; Graham-Harrison, “Secrecy around UK military civilian harm ‘risks undermining public confidence’”, January 19th, 2026. https://www.theguardian.com/uk-news/2026/jan/19/uk-military-civilian-deaths-tribunal ↩
  11. Secretary of State for Defence, “Independent Inquiry relating to Afghanistan”, https://www.iia.independent-inquiry.uk/. ↩
  12. Alan Pughsley, “Report to the independent inquiry relating to Afghanistan”, n.d. https://iiaweb-prod.s3.eu-west-2.amazonaws.com/2.-AP-Exec-Summary-signed-14-August-2024-APP-OZ.pdf ↩
  13. Varghese, et al., “The hidden casualties of Britain’s war”, March 21st, 2023. https://airwars.org/britains-hidden-civilian-harm/; Action on Armed Violence, “Latest figures show RAF airstrikes targeted 4,369 militants in Iraq and Syria since 2014; MOD maintains claim only one civilian killed”, 7th April 2021. https://aoav.org.uk/2021/latest-figures-show-raf-airstrikes-targeted-4369-militants-in-iraq-and-syria-since-2014-whilst-mod-maintains-claim-only-one-civilian-killed/ ↩
  14. Airwars, “U.S.-led Coalition in Iraq & Syria”, n.d. https://airwars.org/conflict/coalition-in-iraq-and-syria/ ↩
  15. Airwars, “CS2010”, July 17, 2025. https://airwars.org/civilian-casualties/cs2010-june-10-2025/ ↩
  16. Dyke and de Silva, “How does the UK determine if it killed a civilian? Five takeaways from Airwars’ tribunal against the MoD”, January 19th, 2026. https://airwars.org/how-does-the-uk-decide-if-it-killed-a-civilian-five-takeaways-from-airwars-tribunal-against-the-mod/; These findings were supported by a publicly released summary of the UK MoD’s own Baseline Assessment released in May 2026, following the cut-off period for this report on the UK approach in 2025. The summary found that the failure to have a single unified policy risked undermining effective civilian harm mitigation and response approaches due to obscured ownership and leadership on this issue. The report confirmed as above that, “human security policy, targeting doctrine, legal processes, and operational practices each address elements of civilian harm, but there is no unifying framework that brings mitigation and response together as a single capability”. Full analysis of this baseline assessment is out of scope for the 2025 country analysis; it will instead be included comprehensively in 2026 reporting. An initial analysis and summary is available on the Airwars website, https://airwars.org/the-uk-ministry-of-defence-admits-it-lacks-tools-to-track-and-investigate-civilian-harm/ ↩
  17. MoD, “Human security in Defence (JSP 985)”, July 9th, 2024. https://www.gov.uk/government/publications/human-security-in-defence-jsp-985: FCDO, DFID, and MoD, “Policy paper: UK paper on the Approach to Protection of Civilians in Armed Conflict”, August 27th, 2020. https://www.gov.uk/government/publications/uk-paper-on-the-approach-to-protection-of-civilians-in-armed-conflict ↩
  18. Hansard, “Armed Conflict: Civilians. Question for Ministry of Defence, UIN 97137, tabled on 4 December 2025”, December 9th, 2025. https://questions-statements.parliament.uk/written-questions/detail/2025-12-04/97137 ↩
  19. Dyke and de Silva, “How does the UK determine if it killed a civilian? Five takeaways from Airwars’ tribunal against the MoD”, January 19th, 2026. https://airwars.org/how-does-the-uk-decide-if-it-killed-a-civilian-five-takeaways-from-airwars-tribunal-against-the-mod/; Graham-Harrison, “Secrecy around UK military civilian harm ‘risks undermining public confidence’”, January 19th, 2026. https://www.theguardian.com/uk-news/2026/jan/19/uk-military-civilian-deaths-tribunal ↩
  20. Cabinet Office, “Policy paper. National Security Strategy 2025: Security for the British People in a Dangerous World”, June 24th, 2025. https://www.gov.uk/government/publications/national-security-strategy-2025-security-for-the-british-people-in-a-dangerous-world: MoD, “Policy paper. The Strategic Defence Review 2025 – Making Britain Safer: secure at home, strong abroad”, June 2nd, 2025. https://www.gov.uk/government/publications/the-strategic-defence-review-2025-making-britain-safer-secure-at-home-strong-abroad; MoD, “Corporate report. Laying the Groundwork – Responsible AI Senior Officers’ Report 2025”, October 3rd, 2025. https://www.gov.uk/government/publications/laying-the-groundwork-responsible-ai-senior-officers-report-2025 ↩
  21. MoD, “Human security in Defence (JSP 985)”, July 9th, 2024. https://www.gov.uk/government/publications/human-security-in-defence-jsp-985: FCDO, DFID, and MoD, “Policy paper: UK paper on the Approach to Protection of Civilians in Armed Conflict”, August 27th, 2020. https://www.gov.uk/government/publications/uk-paper-on-the-approach-to-protection-of-civilians-in-armed-conflict ↩
  22. MoD, “Human security in Defence (JSP 985)”, July 9th, 2024. https://www.gov.uk/government/publications/human-security-in-defence-jsp-985, pi. ↩
  23. GAPS, “ APPG on Women, Peace and Security hosts the UK Government’s 2022 Annual Report to Parliament”, April 30th, 2023. https://gaps-uk.org/appg-on-women-peace-and-security-hosts-the-uk-governments-2022-annual-report-to-parliament/ ↩
  24. MoD, “Human security in Defence (JSP 985)”, July 9th, 2024. https://www.gov.uk/government/publications/human-security-in-defence-jsp-985 ↩
  25. Defence Academy, “Human Security Advisors Course”, https://www.da.mod.uk/courses/human-security-advisors-course; House of Commons Library, “Global human security: Backbench Business Committee debate initiated by Wera Hobhouse MP”, April 8th, 2021. https://researchbriefings.files.parliament.uk/documents/CDP-2021-0052/CDP-2021-0052.pdf ↩
  26. UK Government. “UK Voluntary Report on the Implementation of International Humanitarian Law at Domestic Level (Second Edition) 2024.” October 2024. https://www.gov.uk/government/publications/ implementation-of-international-humanitarian-law-at-domestic-level2024-voluntary-report. ↩
  27. This long-suspected gap was confirmed in the UK Baseline Assessment released in May 2026; while full analysis of the assessment remains out of scope for the 2025 country analysis, the report did confirm that “Defence currently does not maintain a central register of civilian harm incidents or allegations”. Initial analysis of the baseline in full is available on the Airwars website, https://airwars.org/the-uk-ministry-of-defence-admits-it-lacks-tools-to-track-and-investigate-civilian-harm/ ↩
  28. Dyke and de Silva, “How does the UK determine if it killed a civilian? Five takeaways from Airwars’ tribunal against the MoD”, January 19th, 2026. https://airwars.org/how-does-the-uk-decide-if-it-killed-a-civilian-five-takeaways-from-airwars-tribunal-against-the-mod/; Graham-Harrison, “Secrecy around UK military civilian harm ‘risks undermining public confidence’”, January 19th, 2026. ↩
  29. See footnote above in relation to the UK Baseline Assessment, which confirmed in May 2026 that the UK had a complete “absence of tracking systems”, as suspected by civil society actors and presented previously by the Civilian Protection Monitor. Full analysis of the Baseline will be included in the 2026 country analysis, with initial summary available on the Airwars website, https://airwars.org/the-uk-ministry-of-defence-admits-it-lacks-tools-to-track-and-investigate-civilian-harm/ ↩
  30. Dyke and de Silva, “How does the UK determine if it killed a civilian? Five takeaways from Airwars’ tribunal against the MoD”, January 19th, 2026. https://airwars.org/how-does-the-uk-decide-if-it-killed-a-civilian-five-takeaways-from-airwars-tribunal-against-the-mod/; Graham-Harrison, “Secrecy around UK military civilian harm ‘risks undermining public confidence’”, January 19th, 2026. Varghese, et al., “The hidden casualties of Britain’s war”, March 21st, 2023. https://airwars.org/britains-hidden-civilian-harm/ ↩
  31. Dyke and de Silva, “How does the UK determine if it killed a civilian? Five takeaways from Airwars’ tribunal against the MoD”, January 19th, 2026. https://airwars.org/how-does-the-uk-decide-if-it-killed-a-civilian-five-takeaways-from-airwars-tribunal-against-the-mod/; Graham-Harrison, “Secrecy around UK military civilian harm ‘risks undermining public confidence’”, January 19th, 2026. Varghese, et al., “The hidden casualties of Britain’s war”, March 21st, 2023. https://airwars.org/britains-hidden-civilian-harm/ ↩
  32. MoD, “Joint Doctrine Publication 3-46 – Legal Support to Joint Operations”, June 2018. https://assets.publishing.service.gov.uk/media/5b23ab59e5274a18fc321cad/20180614-doctrine_uk_legal_spt_jdp_3_46.pdf; Ministry of Defence. “Request for Information, Reference: 06-06- 2011-110425-006.” J9 POLOPS 10A, June 9, 2011. https://www.whatdotheyknow.com/request/death_of_civilians/response/182130/attach/3/20110610%20FOI%20110425%20Baker.pdf?cookie_passthrough=1; Jones, “British government doesn’t record or estimate how many civilians it has killed on operations”. September 6, 2021. https://aoav.org.uk/2021/britain-doesnt-record-or-estimate-howmany-civilians-it-has-killed-on-operations/ ↩
  33. Kolenda and Rogers, “The Strategic Costs of Civilian Harm”, June 2016. https://www.opensocietyfoundations.org/publications/strategic-costs-civilian-harm; Karlshoej-Pedersen, et al., “Civilian harm mitigation in large-scale combat operations: Lessons for UK defence”, November 5th, 2025. https://www.ceasefire.org/uk-defence-ill-prepared-to-protect-civilians-from-harm-from-uk-military-operations/ ↩
  34. Chris Kolenda and Chris Rogers, “The Strategic Costs of Civilian Harm”, June 2016, p22. https://www.opensocietyfoundations.org/publications/strategic-costs-civilian-harm ↩
  35. Ministry of Defence. “Request for Information, Reference: 06-06- 2011-110425-006.” J9 POLOPS 10A, June 9, 2011. https://www.whatdotheyknow.com/request/death_of_civilians/response/182130/attach/3/20110610%20FOI%20110425%20Baker.pdf?cookie_passthrough=1 ↩
  36. Jones, “British government doesn’t record or estimate how many civilians it has killed on operations”. September 6, 2021. https://aoav.org.uk/2021/britain-doesnt-record-or-estimate-howmany-civilians-it-has-killed-on-operations/ ↩
  37. Dyke and de Silva, “How does the UK determine if it killed a civilian? Five takeaways from Airwars’ tribunal against the MoD”, January 19th, 2026. https://airwars.org/how-does-the-uk-decide-if-it-killed-a-civilian-five-takeaways-from-airwars-tribunal-against-the-mod/; As the assessment was released outside of the review period for this country analysis, it will be more fully integrated into the CPM 2026 report released in 2027. Initial analysis on the baseline is available on the Airwars website, https://airwars.org/the-uk-ministry-of-defence-admits-it-lacks-tools-to-track-and-investigate-civilian-harm/ ↩
  38. Ibid. ↩
  39. Dyke and de Silva, “How does the UK determine if it killed a civilian? Five takeaways from Airwars’ tribunal against the MoD”, January 19th, 2026. https://airwars.org/how-does-the-uk-decide-if-it-killed-a-civilian-five-takeaways-from-airwars-tribunal-against-the-mod/. ↩
  40. FCDO, DFID, and MoD, “Policy paper: UK paper on the Approach to Protection of Civilians in Armed Conflict”, August 27th, 2020. https://www.gov.uk/government/publications/uk-paper-on-the-approach-to-protection-of-civilians-in-armed-conflict ↩
  41. Varghese, et al., “The hidden casualties of Britain’s war”, March 21st, 2023. https://airwars.org/britains-hidden-civilian-harm/ ↩
  42. MoD, “Memorandum from the Ministry of Defence on Operations in Afghanistan.” November 2011. https://publications. parliament.uk/pa/cm201011/cmselect/cmdfence/writev/afghanistan/ opa7.html; Gunter et al., “SAS had golden pass to get away with murder, inquiry told”, January 8th, 2025, https://www.bbc.com/news/articles/c07g40x1v53o; Al Jazeera, “UK special forces chiefs covered up Afghanistan war crimes, inquiry told”, December 1st, 2025, https://www.aljazeera.com/news/2025/12/1/uk-special-forces-chiefs-covered-up-afghanistan-war-crimes-inquiry-told. ↩
  43. This was confirmed in the May 2026 Baseline Assessment commissioned by the MoD, which noted that “while targeting policy emphasises operational record‐keeping and acknowledges that inquiries may occur, it does not define investigative standards, responsibilities, or procedures”. As the assessment was released outside of the review period for this country analysis, it will be more fully integrated into the CPM 2026 report released in 2027. Initial analysis on the baseline is available on the Airwars website, https://airwars.org/the-uk-ministry-of-defence-admits-it-lacks-tools-to-track-and-investigate-civilian-harm/; Ministry of Defence. “Request for Information, Reference: 06-06- 2011-110425-006.” J9 POLOPS 10A, June 9, 2011. https://www.whatdotheyknow.com/request/death_of_civilians/response/182130/attach/3/20110610%20FOI%20110425%20Baker.pdf?cookie_passthrough=1; Jones, “British government doesn’t record or estimate how many civilians it has killed on operations”. September 6, 2021. https://aoav.org.uk/2021/britain-doesnt-record-or-estimate-howmany-civilians-it-has-killed-on-operations/ ↩
  44. Varghese, et al., “The hidden casualties of Britain’s war”, March 21st, 2023. https://airwars.org/britains-hidden-civilian-harm/; Graham-Harris and Dyke, “Only official civilian victim of UK’s bombing campaign against IS appears not to exist”, April 4th, 2023. https://www.theguardian.com/uk-news/2023/apr/04/only-civilian-victim-uk-bombing-campaign-is-syria-iraq-military; Graham-Harris and Dyke, “Lives torn apart by British airstrikes in Mosul give lie to UK’s ‘perfect’ precision war”, March 21st, 2023. https://www.theguardian.com/world/2023/mar/21/british-airstrikes-mosul-civilian-victims-iraq ↩
  45. MoD, “Request for Information. Reference: FOI 2019/07855 (189).” September 11, 2019. https://www.whatdotheyknow.com/request/update_on_air_strikes/response/1429944/attach/3/20190911%20FOI1907855%20189%20FOD%20O.pdf?cookie_passthrough=1 ↩
  46. Varghese, et al., “The hidden casualties of Britain’s war”, March 21st, 2023. https://airwars.org/britains-hidden-civilian-harm/. ↩
  47. PJHQ, “Response to FOIA Request. Ref: FOI2022/08841”, August 16th, 2022. https://www.whatdotheyknow.com/request/raf_strikes_in_iraq_and_syria#incoming-2102350 ↩
  48. International Criminal Court, “Statement of the Prosecutor, Fatou Bensouda, on the conclusion of the preliminary examination of the situation in Iraq/United Kingdom”, December 9th, 2020. https://www.icc-cpi.int/news/statement-prosecutor-fatou-bensouda-conclusion-preliminary-examination-situation-iraq/united ↩
  49. The Times, “Rogue SAS unit accused of executing civilians in Afghanistan”, July 2nd, 2017. https://archive.is/77kZc#selection-1365.0-1365.60; BBC, “Iraq war allegations probe to end”, February 10th, 2017. https://www.bbc.com/news/uk-38937053 ↩
  50. Starkey, “DRONE STRIKE RAF drone wiped out an IS jihadi on a motorbike after tracking him through Syria”, June 28th, 2025. https://www.thesun.co.uk/news/35612476/raf-drone-syria-jihadi-strike/; MoD, “News story. Update: air strikes against Daesh [archived]”, July 9th, 2025. https://web.archive.org/web/20250710014057/https://www.gov.uk/government/news/update-air-strikes-against-daesh ↩
  51. Airwars, “Incident assessment, CS2010”, July 17th, 2025. https://airwars.org/civilian-casualties/cs2010-june-10-2025/ ↩
  52. An archived version of the acknowledgement can be seen here: MoD, “News story. Update: air strikes against Daesh [archived]”, July 9th, 2025. https://web.archive.org/web/20250710014057/https://www.gov.uk/government/news/update-air-strikes-against-daesh ↩
  53. Redress, “IHAT closure threatens proper investigations into allegations of torture by the UK”, February 20th, 2022. https://redress.org/news/ihat-closure-threatens-proper-investigations-into-allegation-of-torture-by-the-uk/; Bates, “Strengthening UK military investigations into civilian harm: Towards compliance, mitigation and accountability”, November, 2024. https://www.ceasefire.org/wp-content/uploads/2024/11/CFR_MilInv_ENG.pdf? ↩
  54. BBC, “UK government and military accused of war crimes cover-up”, November 17th, 2019. https://www.bbc.co.uk/news/uk-50419297 ↩
  55. Ibid. ↩
  56. Secretary of State for Defence, “Independent Inquiry relating to Afghanistan”, https://www.iia.independent-inquiry.uk/. ↩
  57. Unredacted, “UK Special Forces war crimes: operations, 2010-13”, https://unredacted.uk/briefings/uksf-ejk-incidents/; Sky News, “UK special forces unit had ‘deliberate policy’ to ‘kill fighting-aged males’ in Afghanistan, inquiry told”, December 1st, 2025. https://news.sky.com/story/uk-special-forces-unit-had-deliberate-policy-to-kill-fighting-aged-males-in-afghanistan-inquiry-told-13477589 ↩
  58. MoD, “Memorandum from the Ministry of Defence on Operations in Afghanistan.” November 2011. https://publications. parliament.uk/pa/cm201011/cmselect/cmdfence/writev/afghanistan/ opa7.html; Gunter et al., “SAS had golden pass to get away with murder, inquiry told”, January 8th, 2025, https://www.bbc.com/news/articles/c07g40x1v53o; Al Jazeera, “UK special forces chiefs covered up Afghanistan war crimes, inquiry told”, December 1st, 2025, https://www.aljazeera.com/news/2025/12/1/uk-special-forces-chiefs-covered-up-afghanistan-war-crimes-inquiry-told ↩
  59. Gunter, et al,. “SAS Public Inquiry Obtains Deleted Computer Evidence,” BBC, July 2, 2024, https:// www.bbc.com/news/articles/ce44ew9n22qo. ↩
  60. Varghese, et al., “The hidden casualties of Britain’s war”, March 21st, 2023. https://airwars.org/britains-hidden-civilian-harm/ ↩
  61. Graham-Harris and Dyke, “Only official civilian victim of UK’s bombing campaign against IS appears not to exist”, April 4th, 2023. https://www.theguardian.com/uk-news/2023/apr/04/only-civilian-victim-uk-bombing-campaign-is-syria-iraq-military ↩
  62. Varghese, et al., “The hidden casualties of Britain’s war”, March 21st, 2023. https://airwars.org/britains-hidden-civilian-harm/; Dyke and Graham-Harris, “Multiple civilian deaths linked to 2016-17 British airstrikes against IS in Mosul”, March 21st, 2023. https://www.theguardian.com/world/2023/mar/21/multiple-civilian-deaths-linked-to-2016-17-british-airstrikes-against-is-in-mosul ↩
  63. UK Parliament, “Counter-Daesh Operations Statement made on 2 May 2018”, May 2nd, 2018. https://questions-statements.parliament.uk/written-statements/detail/2018-05-02/HCWS665 ↩
  64. These findings were confirmed by the UK Baseline Assessment in May 2026, which noted that, “The UK has forged its experience on post-harm response during operations in Northern Ireland and Afghanistan”, but that “procedures for providing redress… have not been updated for contemporary operations”.As the assessment was released outside of the review period for this country analysis, it will be more fully integrated into the CPM 2026 report released in 2027. Initial analysis on the baseline is available on the Airwars website, https://airwars.org/the-uk-ministry-of-defence-admits-it-lacks-tools-to-track-and-investigate-civilian-harm/; Bates, “Strengthening UK military investigations into civilian harm: Towards compliance, mitigation and accountability”, November, 2024. https://www.ceasefire.org/wp-content/uploads/2024/11/CFR_MilInv_ENG.pdf? ↩
  65. See, for instance; UK Government. “UK Voluntary Report on the Implementation of International Humanitarian Law at Domestic Level (Second Edition) 2024.” October 2024. https://www.gov.uk/government/publications/ implementation-of-international-humanitarian-law-at-domestic-level2024-voluntary-report. ↩
  66. HMG, “Armed forces act 2006“, https://www.legislation.gov.uk/ukpga/2006/52/contents, para113. ↩
  67. MoD, “Joint Doctrine Publication 3-46. Legal Support to Joint Operations, June 19th, 2018. https://assets.publishing.service.gov.uk/media/5b23ab59e5274a18fc321cad/20180614-doctrine_uk_legal_spt_jdp_3_46.pdf ↩
  68. MoD, “Memorandum from the Ministry of Defence on Operations in Afghanistan.” November 2011. https://publications. parliament.uk/pa/cm201011/cmselect/cmdfence/writev/afghanistan/ opa7.html; Gunter et al., “SAS had golden pass to get away with murder, inquiry told”, January 8th, 2025, https://www.bbc.com/news/articles/c07g40x1v53o; Al Jazeera, “UK special forces chiefs covered up Afghanistan war crimes, inquiry told”, December 1st, 2025, https://www.aljazeera.com/news/2025/12/1/uk-special-forces-chiefs-covered-up-afghanistan-war-crimes-inquiry-told . ↩
  69. Leigh Day. “Bereaved Families Welcome Statutory Inquiry Into Alleged Extrajudicial Killings in Afghanistan,” December 15, 2022, https://www.leighday.co.uk/news/news/2022-news/bereavedfamilies-welcome-unprecedented-statutory-inquiry-into-allegationsof-extrajudicial-killings-by-uk-special-forces-in-afghanistan/ ↩
  70. Sir Richard Henriques’ Review Report on strengthening the Service Justice System, October 2021, https://www.gov.uk/government/publications/sir-richard-henriques-review-report-on-strengthening-the-service-justice-system ↩
  71. HMG, “The Armed Forces (Tri-Service Serious Crime Unit) (Consequential Amendments) (No. 2) Regulations 2022”, 2022. https://www.legislation.gov.uk/ukdsi/2022/9780348239522 ↩
  72. Bates, “Strengthening UK military investigations into civilian harm: Towards compliance, mitigation and accountability”, November, 2024. https://www.ceasefire.org/wp-content/uploads/2024/11/CFR_MilInv_ENG.pdf? ↩
  73. Burke and Lattimer. “Reparations for civilian harm from military operations: Towards a UK policy” Ceasefire Centre for Civilian Rights, November 2021. https://www.ceasefire.org/wpcontent/uploads/2021/11/CFR_Reparations_Nov21_Final.pdf. ↩
  74. Woods, “Limited Accountability: A transparency audit of the Coalition air war against so-called Islamic State”, December 16th, 2016. https://airwars.org/limited-accountability-a-transparency-audit-of-the-coalition-air-war-against-so-called-islamic-state/ ↩
  75. BBC, “RAF killed ‘4,000 fighters in Iraq and Syria’”, March 7th 2019. https://www.bbc.com/news/uk-47477197 ↩
  76. Varghese, et al., “The hidden casualties of Britain’s war; Searching for the victims of UK aistrikes in Iraq and Syria”. March 21, 2023. https:// airwars.org/investigation/britain-uk-civilian-casualties-iraq-syria/: Airwars, https://airwars.org/conflict-data/british-ekia/ ↩
  77. Woods, “Limited Accountability: A transparency audit of the Coalition air war against so-called Islamic State”, December 16th, 2016. https://airwars.org/limited-accountability-a-transparency-audit-of-the-coalition-air-war-against-so-called-islamic-state/ ↩
  78. House of Commons Defence Committee, “Defence Committee; Oral evidence: Global Islamist Terrorism, HC 735”, April 2nd, 2019. Q82. https://committees.parliament.uk/oralevidence/9180/html/ ↩
  79. Burke and Lattimer. “Reparations for civilian harm from military operations: Towards a UK policy” Ceasefire Centre for Civilian Rights, November 2021. https://www.ceasefire.org/wpcontent/uploads/2021/11/CFR_Reparations_Nov21_Final.pdf; Foreign Affairs Committee. “Annual Report on Human Rights 2006.” June 2007. https://assets.publishing.service.gov.uk/ media/5a7c76d9e5274a5255bced40/7127.pdf; NATO. “Night Raids Tactical Directive.” January 23, 2010. https://www.whatdotheyknow.com/request/isaf_night_raid_tactical_directi/response/2570691/attach/3/20240229%20NATO%20Night%20Time%20Directives%20Jan%202010.pdf?cookie_passthrough=1. ↩
  80. MoD, “Ministry of Defence: Compensation. Question for Ministry of Defence”, November 24th, 2016. https://questions-statements.parliament.uk/written-questions/detail/2016-11-24/54689/# ↩
  81. These findings were confirmed by the UK Baseline Assessment in May 2026, which noted that, “The UK has forged its experience on post-harm response during operations in Northern Ireland and Afghanistan”, but that “procedures for providing redress… have not been updated for contemporary operations”. As the assessment was released outside of the review period for this country analysis, it will be more fully integrated into the CPM 2026 report released in 2027. Initial analysis on the baseline is available on the Airwars website, https://airwars.org/the-uk-ministry-of-defence-admits-it-lacks-tools-to-track-and-investigate-civilian-harm/ ↩
  82. House of Lords Library, “Overseas Operations (Service Personnel and Veterans) Bill: Briefing for Lords Stages”, January 14th, 2021. https://lordslibrary.parliament.uk/research-briefings/lln-2020-0126; Liberty, “Liberty’s briefing on the overseas operations (Service personnel and veterans) bill for second reading in the House of Commons”, September 2020. https://www.libertyhumanrights.org.uk/wp-content/uploads/2019/02/Libertys-Second-Reading-Briefing-for-the-Overseas-Operations-Bill-HOC-September-2020.pdf; Bates, “Legislating by Soundbite: The Overseas Operations (Service Personnel and Veterans) Bill”, September 18th, 2020. https://www.ejiltalk.org/legislating-by-soundbite-the-overseas-operations-service-personnel-and-veterans-bill/ ↩
  83. These findings were confirmed by the UK Baseline Assessment in May 2026, which noted that, “The UK has forged its experience on post-harm response during operations in Northern Ireland and Afghanistan”, but that “procedures for providing redress… have not been updated for contemporary operations”. As the assessment was released outside of the review period for this country analysis, it will be more fully integrated into the CPM 2026 report released in 2027. Initial analysis on the baseline is available on the Airwars website, https://airwars.org/the-uk-ministry-of-defence-admits-it-lacks-tools-to-track-and-investigate-civilian-harm/; MoD, “Ministry of Defence: Compensation. Question for Ministry of Defence”, November 24th, 2016. https://questions-statements.parliament.uk/written-questions/detail/2016-11-24/54689/#; Karlshoej-Pedersen, et al., “Civilian harm mitigation in large-scale combat operations: Lessons for UK defence”, November 5th, 2025. https://www.ceasefire.org/uk-defence-ill-prepared-to-protect-civilians-from-harm-from-uk-military-operations/ ↩
  84. Burke and Lattimer. “Reparations for civilian harm from military operations: Towards a UK policy” Ceasefire Centre for Civilian Rights, November 2021. https://www.ceasefire.org/wpcontent/uploads/2021/11/CFR_Reparations_Nov21_Final.pdf. ↩
  85. MoD, “Ministry of Defence: Compensation. Question for Ministry of Defence”, November 24th, 2016. https://questions-statements.parliament.uk/written-questions/detail/2016-11-24/54689/# ↩
  86. Burke and Lattimer. “Reparations for civilian harm from military operations: Towards a UK policy” Ceasefire Centre for Civilian Rights, November 2021. https://www.ceasefire.org/wpcontent/uploads/2021/11/CFR_Reparations_Nov21_Final.pdf. ↩
  87. Ibid. ↩
  88. The Independent, “‘No recognition, no apology’: The UK has paid just £1,003 to innocent civilians caught in war zones”, January 28th, 2022. https://archive.is/dcegW#selection-785.0-785.99 ↩
  89. House of Lords Library, “Overseas Operations (Service Personnel and Veterans) Bill: Briefing for Lords Stages”, January 14th, 2021. https://lordslibrary.parliament.uk/research-briefings/lln-2020-0126; Liberty, “Liberty’s briefing on the overseas operations (Service personnel and veterans) bill for second reading in the House of Commons”, September 2020. https://www.libertyhumanrights.org.uk/wp-content/uploads/2019/02/Libertys-Second-Reading-Briefing-for-the-Overseas-Operations-Bill-HOC-September-2020.pdf; Bates, “Legislating by Soundbite: The Overseas Operations (Service Personnel and Veterans) Bill”, September 18th, 2020. https://www.ejiltalk.org/legislating-by-soundbite-the-overseas-operations-service-personnel-and-veterans-bill/ ↩
  90. UK Parliament, “Counter-Daesh Operations Statement made on 2 May 2018”, May 2nd, 2018. https://questions-statements.parliament.uk/written-statements/detail/2018-05-02/HCWS665; Graham-Harris and Dyke, “Only official civilian victim of UK’s bombing campaign against IS appears not to exist”, April 4th, 2023. https://www.theguardian.com/uk-news/2023/apr/04/only-civilian-victim-uk-bombing-campaign-is-syria-iraq-military ↩
  91. MoD, “JSP 985, Human Security in Defence Volume 1: Incorporating Human Security in the way we Operate.” June 2024. https://assets.publishing.service.gov.uk/media/668d2b5fab5fc5929851bc2c/JSP_985.pdf ↩
  92. Airwars, “US-led Coalition in Iraq and Syria”, https://airwars.org/conflict/coalition-in-iraq-and-syria/ ↩
  93. Varghese, et al., “The hidden casualties of Britain’s war”, March 21st, 2023. https://airwars.org/britains-hidden-civilian-harm/ ↩