Commissioned report concludes there is a ‘prevailing assumption that harm will not occur’, and finds that existing practices ‘are not a substitute for a comprehensive allegations tracking and response mechanism.’
A summary of the study, conducted on behalf of the MoD by an independent consultant with a professional military background, was released to our partner, the Ceasefire Centre for Civilian Rights, via a Freedom of Information Act request. Unredacted is today separately publishing this document.
Overall, the review has found multiple and significant gaps in the UK’s approach to civilian harm mitigation and response (CHMR). There is an absence of a coherent policy framework in this area, with relevant responsibilities and practices scattered across different domains. As a result, serious deficiencies have been identified in the MoD’s current approach to tracking allegations and evidence of civilian harm, as well as conducting investigations and providing post-harm redress. Where ‘legacy processes’ may have once existed in the context of the wars in Iraq and Afghanistan, the study has found that these systems have ‘fallen into disuse.’1
There is, in particular, no system for tracking civilian casualties. The review found an absence of any central register of civilian harm incidents or allegations, with cases instead addressed by officials on an ‘ad hoc basis’. Across the MoD and military, there remains ‘no systematic recording of allegations, rationales for dismissal, or lessons identified.’2 Likewise, the review found no formalised policy framework for investigating allegations of civilian harm, with no centralised definition of investigative standards, procedures or responsibilities. Where harm has been identified, existing procedures for providing redress are also in need of updating. This is particularly true in the context of future operations, given that these are likely to involve higher levels of civilian harm.3
The deficiencies identified by the report are significant. As Mae Thompson, advocacy officer at Ceasefire, has said: ‘The UK’s inability to detect civilian harm calls into question its ability to comply with international humanitarian law, which requires states to take “constant care” to spare the civilian population and take “all feasible precautions” to avoid or minimise civilian harm.’4
The full MoD study was completed in November 2025, and has not been released.
- Ministry of Defence (Human Security in Defence Policy), UK MOD Civilian Harm Mitigation and Response (CHMR) Baseline Study 2024/5, external summary report, 28 Apr 2026, pp. 4-5. ↩︎
- Ministry of Defence (Human Security in Defence Policy), UK MOD Civilian Harm Mitigation and Response (CHMR) Baseline Study 2024/5, external summary report, 28 Apr 2026, p. 5. ↩︎
- Ministry of Defence (Human Security in Defence Policy), UK MOD Civilian Harm Mitigation and Response (CHMR) Baseline Study 2024/5, external summary report, 28 Apr 2026, p. 6. ↩︎
- Guardian, MoD Has no System to Detect Civilian Deaths Caused by Military, Study Shows, Dan Sabbagh, 5 May 2026. ↩︎
