Your field teams operate in contexts of extreme vulnerability, and the question is no longer whether your donor will require a solid PSEAH framework, but when they will ask for it — often during a call for proposals, sometimes in the middle of an audit, almost always at a moment when your teams have neither the time nor the documentary evidence at hand. Protection from sexual exploitation, abuse and harassment has become a top-tier eligibility criterion at the UN, the EU, AFD, ECHO, the Global Fund and USAID. An "off-the-shelf" policy is no longer enough: it is the evidence of implementation — appointed focal points, documented training, processed reports, assessed partners — that makes the difference in front of an evaluator.
This article offers an operational reading of PSEAH for NGOs: we revisit the IASC framework and recent donor requirements, then we detail how to build a living, traceable and auditable framework — from the code of conduct to partner due diligence, by way of HR, procurement and reporting workflows. Finally, we show where Abvius, our Finance, Operations and MEAL ERP for NGOs, can centralise the evidence that turns a PSEAH policy into a compliance standard you can present to your donors.
PSEAH NGO: why the framework is becoming non-negotiable
Reading time: ~12 min
Before getting into the details, here is the table of contents:
- The PSEAH framework: from the IASC reference standard to donor requirements
- The six core principles that structure any policy
- Architecture of an operational PSEAH framework
- PSEAH due diligence on local partners
- How Abvius supports PSEAH compliance day to day
- A 90-day implementation roadmap
- PSEAH mini-FAQ
- Summary and Abvius resources
1. The PSEAH framework: from the IASC reference standard to donor requirements
PSEAH — Protection from Sexual Exploitation, Abuse and Harassment — was built up in successive layers. In 2002, the Inter-Agency Standing Committee (IASC) set out the six reference principles, revised in 2019. Since the "Oxfam moment" of 2018, donors have systematised their requirements. In 2026, the absence of a formal PSEAH framework is now disqualifying for almost all international funding.
What your donors actually expect
Expectations vary by donor, but three requirements converge: a written policy, accessible reporting mechanisms, and evidence of implementation. The table below summarises the main obligations encountered in the field.
| Donor / Framework | Applicable reference standard | Key requirements for the partner NGO |
|---|---|---|
| UN agencies (UNICEF, UNHCR, WFP, WHO, UNFPA) | UN Implementing Partner PSEA Protocol | Self-assessment against 8 standards, designated focal point, capacity-strengthening plan |
| European Commission (ECHO, DG INTPA) | ECHO PSEAH Guidance Note | Code of conduct signed by all staff, community complaint mechanism, incident reporting |
| AFD (France) | AFD safeguarding framework / OECD-DAC framework | Preliminary assessment, policy, training, traceability of reports |
| USAID / BHA | PSEA Policy and Implementation Plan | Organisational policy, staff vetting, protected reporting mechanism |
| Global Fund | Secretariat PSEAH policy | Sub-recipient assessment, quarterly reporting, corrective action plan |
| EU Pillar Assessment | Protection of the individual pillar | Formalised policy, investigation procedure, dedicated resources |
These requirements converge around a single auditor's reflex: "Show me your evidence." A policy not embodied in workflows, dates, signatures and indicators will no longer convince any pillar assessment or partnership evaluation.
2. The six core principles that structure any policy
The six IASC principles, last revised in 2019, form the backbone of any NGO PSEAH policy. They are non-negotiable: a donor who does not see them reproduced in substance in your code of conduct will deem your policy non-compliant.
- Principle 1 — Absolute gravity. Acts of sexual exploitation and abuse constitute gross misconduct and grounds for immediate dismissal.
- Principle 2 — Protection of minors. Any sexual activity with a person under 18 is prohibited, regardless of the local age of majority.
- Principle 3 — Prohibition of exchanges. Any exchange of money, employment, goods or services for sexual acts is prohibited — including assistance that is owed to beneficiaries.
- Principle 4 — Power asymmetry. Any sexual relationship between a humanitarian worker and an assisted person, based on an abuse of position, is prohibited.
- Principle 5 — Duty to report. Any staff member who has suspicions must report through the established channels, including against another organisation.
- Principle 6 — Protective environment. Every humanitarian worker must actively contribute to creating an environment that prevents abuse.
These principles must then be translated into concrete obligations: an annex to the employment contract, clauses in partnership agreements, a signature on purchase orders above certain thresholds, induction training, and reminders during field missions.
3. Architecture of an operational PSEAH framework
A credible PSEAH framework rests on seven interconnected pillars. It is the absence of one of them — not the quality of the policy text — that causes most assessments to fail.
Governance and leadership
A clear anchor point at the highest level: a commitment from the board of directors, a sponsor within executive management, and the appointment of a PSEAH focal point independent of the operational reporting lines. The appointment must be public, dated, and recorded in the documents you present to your donors.
Prevention
A binding code of conduct signed by 100% of staff — headquarters, field, consultants, volunteers — with timestamped proof of signature. Electronic signature, compliant with eIDAS, is now the standard accepted by European donors. Add to this induction training and a mandatory annual refresher cycle, with an individual certificate.
Responsible recruitment
Systematic vetting of candidates is becoming essential: reference checks on previous jobs, a query to the ClearCheck register of ineligible individuals (set up by the United Nations), and cross-checking against sanctions lists and sector-specific lists. This step must leave a usable trace at the time of the HR audit.
Reporting mechanism
At least two independent channels, including an external channel accessible to beneficiaries in their language. The mechanism must guarantee confidentiality, protection against retaliation, and a known acknowledgement deadline. Donors almost systematically check the time between a report and its acknowledgement: seven days is a common standard.
Response to survivors
A mapping of local services — health, psychosocial support, legal aid, protection — prepared before an incident occurs. An assistance policy that places the survivor's needs at the centre, without making them conditional on cooperation with an investigation.
Investigation
A formalised investigation procedure, conducted by trained internal investigators or outsourced to a qualified provider. Standard timeframes, separation between the investigation function and the reporting line of the person under investigation, rights of the defence, and preservation of evidence in a digital vault with a controlled retention period.
Accountability and reporting
An anonymised register of reports, donor reporting compliant with the requested template (UN protocol, ECHO format, AFD), and PSEAH indicators shared with the management committee. A framework is judged credible only if it produces living figures — including a duly explained zero reports — and not merely intentions.
4. PSEAH due diligence on local partners
The majority of funding now passes through local partners. Your donors hold you responsible for their practices. PSEAH due diligence on partners rests on a four-stage cycle that we recommend anchoring in your procedures manual.
| Stage | Purpose | Typical deliverable |
|---|---|---|
| 1. Pre-selection | Screening partners against minimum PSEAH criteria | PSEAH pre-qualification questionnaire |
| 2. Assessment | Documentary audit and interview on the 8 UN standards | Assessment score, strengthening plan |
| 3. Contracting | PSEAH clauses in the partnership agreement | Signed agreement with PSEAH annex |
| 4. Monitoring | Visits, annual reviews, capacity building | Visit reports, updated action plan |
The classic trap is to conduct a rigorous assessment at the start of a partnership… then forget the follow-up. Yet it is precisely this follow-up that your donors will ask you to document at the next pillar assessment.
5. How Abvius supports PSEAH compliance day to day
We design Abvius as the system of record that turns a written PSEAH policy into facts you can present to an auditor. A policy is only worth something if, two years later, you can find out who signed it, on what date, with which version, and what actions were triggered downstream. Here are the functions you most often draw on in a PSEAH framework.
- eIDAS-compliant electronic signature of the code of conduct and PSEAH annexes by all staff and subcontractors, with timestamping and evidential-value retention.
- Headquarters-field centralisation of training evidence, annual certificates and records of awareness sessions, accessible from any country of operation.
- Validation workflows for partner assessments: questionnaire, scoring, action plan, review — all timestamped and linked to the partner file.
- Digital audit trail on reports (anonymised register), decisions and status changes, compliant with retention and personal-data protection requirements.
- Real-time budget monitoring of lines dedicated to PSEAH (training, focal point, complaint mechanisms, partner audits) to demonstrate the effective allocation of resources, an indicator explicitly sought by donors.
- Automatic donor reporting using the expected template: PSEAH dashboard, training coverage rate, number of reports handled within deadlines, partners assessed over the period.
The goal is not to replace the substantive work — which remains that of your focal point and your teams — but to ensure that every action leaves a usable trace. A demo and a use case are available at abvius.org.
6. A 90-day implementation roadmap
If your PSEAH framework is incomplete or if you are approaching a new donor assessment, here is a realistic schedule to reach a presentable level of compliance in three months.
Days 0 to 15 — Diagnosis and governance
Conduct a self-assessment against the eight UN standards. Officially appoint a PSEAH focal point. Have the roadmap validated by the management committee and put PSEAH on the board of directors' agenda.
Days 15 to 30 — Policy and code of conduct
Adopt or revise the PSEAH policy and the code of conduct. Build the PSEAH annex for employment contracts and partnership agreements. Launch electronic signature of the new version for all staff, with a firm deadline.
Days 30 to 60 — Mechanisms and training
Set up or revise at least two reporting channels, including an external channel accessible to beneficiaries in their working language. Roll out a mandatory induction training module and an annual refresher module. Build the mapping of support services in each country of operation.
Days 60 to 90 — Partners and reporting
Launch PSEAH due diligence on active partners, starting with those that carry the largest donor funding. Build the monthly PSEAH dashboard and the donor reporting template. Document everything in an evidence file ready to present at the next assessment.
7. PSEAH mini-FAQ
What is the difference between PSEA and PSEAH?
PSEA (Protection from Sexual Exploitation and Abuse) targets abuse against beneficiary populations. PSEAH adds sexual harassment, which may target colleagues, partners or providers. PSEAH is today the reference scope for almost all international donors.
Is a small NGO really concerned?
Yes. Donors do not expect the same sophistication from a five-employee NGO as from an international organisation, but they require the same principles: a written policy, a signed code of conduct, a reporting channel, an identified focal point, and assessed partners. Proportionality is accepted; the absence of a framework is not.
What should you do in the event of a confirmed incident during a project?
Three reflexes: immediately trigger care for the survivor via the planned service mapping, launch the formalised investigation procedure, and inform the donor within the contractual deadline — often 48 or 72 hours for UN donors. Failing to inform a donor of an incident they would otherwise discover is the most damaging breach of trust.
How do you budget for PSEAH in your donor proposals?
Include dedicated lines: focal point (a fraction of an FTE), training and awareness, partner audits, complaint mechanism (translation, moderation), local capacity building. Donors generally accept these costs as direct or semi-direct, provided they are identified and tracked in your cost accounting.
Which PSEAH indicators should you track to steer the framework?
Four structuring indicators are enough to get started: the share of staff who have signed the code of conduct and completed the annual training, the average acknowledgement time for reports, the number of partners assessed over the period and the share of those with an ongoing action plan, and the budget execution rate of PSEAH lines. These indicators, tracked monthly and presented to the management committee, demonstrate that this is a living framework and not a document filed away in a cabinet. For organisations undergoing an EU pillar assessment, add the coverage rate of support-service mappings per country of operation.
Must the reporting mechanism be available in all local languages?
At a minimum in the working languages of beneficiaries, which often implies oral channels in areas with low literacy. Donors appreciate physical boxes accompanied by trained community relays, free phone lines and SMS channels, rather than a generic email address that no local stakeholder will use. Concrete accessibility takes precedence over technical sophistication.
8. Summary and Abvius resources
PSEAH for NGOs is no longer a peripheral HR topic: it is an eligibility criterion for international funding that is assessed on evidence. Adopt the IASC reference standard, appoint an independent focal point, have all your staff electronically sign a code of conduct, build a protected reporting mechanism, integrate due diligence into your partnership cycle, and instrument the budget monitoring of the resources allocated. At the end of the chain, your donors are looking for one thing: dated, traceable proof that the policy is alive. This is precisely what Abvius helps you produce in a few clicks, by linking electronic signature, document management, validation workflows and donor reporting.
To go further, we recommend the following articles:
- NGO Partner Due Diligence | Donor Compliance
- NGO Electronic Signature | Donor Compliance and eIDAS 2.0
- NGO Accountability | Affected Populations (AAP) and the CHS Framework
- NGO Digital Audit Trail | Donor Traceability
- NGO Donor Audit Preparation | A Complete Guide to Success
Talk to our team to assess your organisation's PSEAH maturity: get in touch via abvius.org.