The Illusion of "Reform"

UNRWA reports both Category 2 recommendations as completed, but its own reporting does not demonstrate that the governance deficiencies identified by Colonna have been resolved. Recommendations were closed after procedural steps that produced no change in UNRWA’s governance structure and key elements remain unimplemented.

1. UNRWA Has Not Demonstrated Completion of Recommendation 2

Recommendation 2 prescribed specific changes to strengthen the Advisory Commission’s ability to address neutrality: convening annually at UN headquarters in New York at Permanent Representative level; making neutrality a standing item at its twice-yearly meetings; and creating a Working Group on neutrality and integrity issues that would invite host countries and Israel to present their concerns.^{[63]Independent Review of Mechanisms and Procedures to Ensure Adherence by UNRWA to the Humanitarian Principle of Neutrality, at p. 8, UN (April 20, 2024), Link, archive link: Link.}

UNRWA reports Recommendation 2 as fully completed, but its own progress reports do not demonstrate implementation of all of these requirements. The Agency repeatedly cites neutrality as a standing AdCom agenda item and the establishment of the Working Group, but does not identify the annual New York meeting at Permanent Representative level required by Recommendation 2(a). Nor does it report that host countries and Israel were invited to present their concerns to the Working Group, as required by Recommendation 2(c).

2. The Working Group Does Not Perform the Function Colonna Envisioned

This is particularly significant because Colonna found that the AdCom had “frequently been reluctant to consider sensitive neutrality-related issues,” including staff-union neutrality concerns.^{[64]Independent Review of Mechanisms and Procedures to Ensure Adherence by UNRWA to the Humanitarian Principle of Neutrality, at p. 7, UN (April 20, 2024), Link, archive link: Link.} Yet UNRWA’s progress reports principally describe the new Working Group as reviewing evidence presented by UNRWA itself to support closure of Colonna recommendations—40 recommendations by Q2 2026—rather than as a forum for scrutinizing sensitive neutrality concerns raised by outside parties.^{[65]Q2 Progress Report: Implementing the Colonna Report at UNRWA: April 2026-June 2026, UNRWA (August 2, 2026), Link archive link: Link.}

Israeli input, expressly required by Recommendation 2(c), also cannot currently function. Following Israeli legislation restricting official interaction with UNRWA, there is no official contact between UNRWA and Israeli government officials.^{[66]Approved in final readings: Bill banning state authorities from maintaining any contact with UNRWA or a representative of the agency, Knesset News (October 29, 2024), Link, archive link: Link.} Israel therefore cannot present directly to the Working Group its intelligence and neutrality concerns regarding UNRWA personnel and facilities. UNRWA nevertheless counts Recommendation 2 as completed.

The limitations on external scrutiny extend beyond the Working Group. According to the USAID OIG, the UN Office of Internal Oversight Services (OIOS) refused to provide unredacted investigative materials concerning UNRWA employees implicated in the October 7 attacks.^{[67]USAID’s Gaza-related Oversight Work, at p. 1, USAID OIG (July 30, 2025), Link, archive link: Link.} The withholding of such evidence from an external government oversight body illustrates the weakness of a governance model that remains dependent on UN-controlled information and internal review.

3. Recommendation 3 Was Closed Without Any Change to UNRWA’s Governance Structure

Recommendation 3 called on UNRWA to “explore additional governance arrangements” to provide strategic direction and improve external communications.^{[68]Independent Review of Mechanisms and Procedures to Ensure Adherence by UNRWA to the Humanitarian Principle of Neutrality, at p. 8, UN (April 20, 2024), Link, archive link: Link.} UNRWA did so through the Secretary-General’s Strategic Assessment and, in February 2026, submitted to AdCom members a proposal contemplating replacement of the AdCom with an Executive Board.^{[69]Q1 Progress Report: Implementing the Colonna Report at UNRWA: January 2026-March 2026, UNRWA (May 11, 2026), Link; archive link: Link.}

This responds to the literal requirement to explore alternative arrangements, but does not amount to governance reform. No Executive Board has been established, the AdCom remains in place, and UNRWA acknowledges that any change rests with Member States. Indeed, its Q2 2026 report states that it remains available for further dialogue on the proposal “or any alternative governance model.”^{[70]Q2 Progress Report: Implementing the Colonna Report at UNRWA: April 2026-June 2026, UNRWA (August 2, 2026), Link archive link: Link.} Thus, Recommendation 3 may be closed, but the governance deficiency that prompted Colonna to recommend alternative arrangements remains unchanged.

4. Administrative Closure Does Not Establish Effective Governance Reform

Category 2’s 2/2 completion figure obscures the distinction between administrative milestones and actual governance reform. Recommendation 2 is classified as complete even though UNRWA’s reporting does not demonstrate implementation of all its express requirements, including the contemplated channel for Israeli input. Recommendation 3 is classified as complete because an alternative governance arrangement was explored and proposed, although no alternative governance structure has been established.

Colonna concluded that UNRWA’s existing governance arrangements meant that the Agency “cannot rely on the needed political support to effectively address neutrality issues.”^{[71]Independent Review of Mechanisms and Procedures to Ensure Adherence by UNRWA to the Humanitarian Principle of Neutrality, at p. 7, UN (April 20, 2024), Link, archive link: Link.} Adding neutrality to an AdCom agenda, creating a Working Group principally described as reviewing UNRWA’s own implementation evidence, and proposing to replace AdCom with an Executive Board do not establish that this underlying deficiency has been resolved. UNRWA’s 100% completion rating thus measures the completion of administrative steps, not whether the substantive governance and oversight deficiencies identified by Colonna have actually been resolved.

UNRWA’s claim that it has fortified its internal oversight and accountability mechanisms rests heavily on administrative outputs—new policies, training programmes, internal units, reporting systems, and management tools—rather than evidence that these measures are capable of detecting and preventing the serious neutrality violations that prompted the Colonna review in the first place. UNRWA reports 13 of 15 recommendations in this category completed, or 87 percent. Yet its own progress reports show that important structural reforms remain unfinished, while several recommendations have been closed based principally on the creation of processes whose effectiveness against deliberate terrorist infiltration remains unproven.

1. Training and Ethics Cannot Detect Deliberate Terrorist Infiltration

UNRWA repeatedly cites mandatory e-courses, an updated Code of Ethics, Outside and Political Activities declarations, Supervisory Skills Training (SST), and new managerial accountability requirements as evidence of strengthened oversight. Such measures may improve compliance among ordinary employees, but they are inherently incapable of determining whether staff are simultaneously affiliated with terrorist organizations or engaged in terrorist activity.

Indeed, UNRWA’s Code of Ethics expressly permits staff to be members of political parties,^{[94]Code of Ethics, at p. 26, UNRWA (2023), Link, archive link at Link.} while UNRWA separately states that it prohibits membership in militant or armed groups.^{[95]Statement by UNRWA Commissioner-General ad interim Christian Saunders at the Pledging Conference, UNRWA (June 30, 2026), Link, archive link at Link.} In the case of Hamas, this distinction means that UNRWA’s ethics and disclosure system does not treat Hamas membership itself as disqualifying, but instead depends on identifying prohibited military affiliation or activity. The increase in annual Outside and Political Activities declarations from approximately 1,000 to 3,000 therefore demonstrates only increased participation in an administrative process, but does not establish that staff are not members of armed or militant groups.

The inadequacy of treating the problem principally through ethics and compliance mechanisms is illustrated by cases uncovered through external investigation. The USAID OIG, for example, identified an UNRWA school principal as an operative of Hamas’s East Jabaliya Battalion, ultimately resulting in his ten-year U.S. government-wide debarment.^{[96]INVESTIGATIVE SUMMARY: USAID Inspector General’s Continuing Investigation Leads to Referral of Over 100 Current and Former UNRWA Staff Linked to Hamas for Suspension/Debarment, USAID OIG (June 5, 2026), Link, archive link: Link.}

UNRWA’s closure of Recommendation 15 is particularly revealing. Colonna called on the Agency to “develop and implement” tailored management and oversight training for senior area staff serving as front-line managers and supervisors. Yet UNRWA closed the recommendation after training 189 supervisors across all Field Offices except Gaza—the field operation at the center of the neutrality crisis—while acknowledging that implementation there remained outstanding and would occur only “once conditions on the ground allow.”^{[97]Q4 Progress Report: Implementing the Colonna Report at UNRWA October 2025-December 2025, UNRWA (February 2, 2026), Link, archive link: Link}

2. Limits of Internal Oversight Revealed by External Investigations

UNRWA also points to the expansion of the DIOS, additional investigative personnel, a P4 Quality Assurance Officer, surge support to address case backlogs, and the centralized Neutrality Investigations Unit as evidence of strengthened internal accountability. In 2025, the Neutrality Investigations Unit received 40 neutrality-related complaints, authorized 31 investigations, completed 22, and substantiated 13 allegations, after which UNRWA says “proportional disciplinary measures” were imposed.^{[98]Q2 Progress Report: Implementing the Colonna Report at UNRWA: April 2026-June 2026, UNRWA (August 2, 2026), Link archive link: Link.}

The scale of cases identified externally is significantly larger. By June 2026, USAID OIG reported that its independent investigation had resulted in 108 referrals of current or former UNRWA personnel for suspension or debarment consideration based on alleged Hamas affiliation and/or participation in the October 7 attacks.^{[99]INVESTIGATIVE SUMMARY: USAID Inspector General’s Continuing Investigation Leads to Referral of Over 100 Current and Former UNRWA Staff Linked to Hamas for Suspension/Debarment, USAID OIG (June 5, 2026), Link, archive link: Link.} The individuals identified included school principals, teachers, security personnel, counselors, and medical professionals, including employees alleged to have held military positions within Hamas.

UNRWA does not explain whether the individuals identified by USAID OIG were among its 40 neutrality complaints, 31 authorized investigations, or 13 substantiated cases. Nor does it disclose the nature of the 13 substantiated violations or what “proportional disciplinary measures” were imposed. The scale of cases identified externally raises questions about whether UNRWA’s internal mechanisms can independently detect serious misconduct.

3. OIOS Cooperation Does Not Equal Transparent Accountability

UNRWA further cites continued cooperation with the UN OIOS on “serious and high-risk allegations” as evidence of stronger oversight.^{[100]Q1 Progress Report: Implementing the Colonna Report at UNRWA: January 2026-March 2026, UNRWA (May 11, 2026), Link; archive link: Link.} Recommendation 6 called for greater interaction between DIOS and external UN oversight structures and, in cases of grave allegations, for the Commissioner-General to request that the Secretary-General refer the investigation to OIOS.^{[101]Independent Review of Mechanisms and Procedures to Ensure Adherence by UNRWA to the Humanitarian Principle of Neutrality, at p. 16, UN (April 20, 2024), Link, archive link: Link.} UNRWA’s progress reports do not identify any such referral or otherwise demonstrate implementation of this component of the recommendation. At the same time, the handling of the October 7 investigations demonstrates the limitations of relying on OIOS as the principal external check within the Colonna framework.

In investigating allegations concerning UNRWA personnel, the USAID OIG sought information from both UNRWA and OIOS. OIOS permitted USAID OIG to review its investigation report only with the subjects’ names redacted, which USAID OIG said rendered the report unusable for its purposes.^{[102]INVESTIGATIVE SUMMARY: USAID OIG’s Investigative Work to Prevent UNRWA Staff Associated With Hamas From Circulating to Other U.S. Government-Funded Aid Organizations, USAID OIG (April 14, 2025), Link, archive link: Link.} UNRWA also did not provide USAID OIG with the names of personnel whose appointments had been terminated following the October 7 allegations.^[103]Id. As a result, the very mechanism UNRWA cites as evidence of strengthened oversight prevented an independent U.S. government oversight body from identifying the individuals investigated or meaningfully assessing UNRWA’s response.

The subsequent leak^{[104]Exclusive: UN Is Actively Obstructing US Probe Into Links Between Its Gaza Relief Groups and Hamas, as Americans Warn UN To Divorce 'Cancerous UNRWA,' Washington Free Beacon (July 30, 2026), Link, archive link Link.} of the confidential OIOS report^{[105]Investigation Report on Misconduct by Staff Members at the United Nations Relief and Works Agency for Palestine Refugees in the Near East, OIOS (July 31, 2024), Link, archive link: Link.} exposes a second problem: the limitations of OIOS itself as a neutrality-accountability mechanism. The leaked report, which was never published by the UN or UNRWA, identifies the employees only as “subjects,” without their names—consistent with USAID OIG’s account. More importantly, OIOS expressly limited its mandate to determining whether the 19 employees were involved in the October 7 attacks and stated that it did not reach conclusions regarding their alleged membership in Hamas or other militant groups.^{[106]Id. at p. 5.} Thus, a finding that the evidence was insufficient to establish participation in October 7 was not a finding that the employee had no terrorist affiliation.

The report also shows that OIOS relied in part on statements provided by the subjects themselves. In several cases, employees denied involvement in the attacks or affiliation with militant groups, and OIOS considered those denials while declining to treat Israeli intelligence—including Hamas membership records, military identification numbers, ranks, military training, or operational roles—as sufficient without independent authentication or corroboration.^{[107]Id. at pp. 1-2.}

The lack of transparency surrounding these investigations has also left victims without a clear accounting of how individual cases were resolved. This is illustrated by the case of Ayelet Samerano, whose son Yonatan was abducted on October 7 in an incident involving an UNRWA employee captured on CCTV.^{[108]‘Does the UN hold my son?’ mother of murdered hostage asks as families assail UNRWA, Times of Israel (February 21, 2024), Link, archive link: Link.} Although the leaked report provides some insight into OIOS’s findings, it still withholds the subjects’ identities. Moreover, this information became available only through an unauthorized leak rather than transparent disclosure by the UN or UNRWA. Victims, donors, and outside investigators should not have to rely on leaked confidential documents to understand how allegations of terrorist involvement by UNRWA personnel were investigated and resolved.

Accordingly, cooperation with OIOS does not itself establish independent or transparent accountability. The Colonna framework provides no mechanism outside the UNRWA/UN system to investigate serious neutrality breaches, test UNRWA’s findings against external evidence and intelligence, or ensure transparency about the results.

4. Administrative Risk and Project Systems Do Not Establish Operational Neutrality (Recommendations 11, 14, 16)

The same limitation appears in UNRWA’s broader management reforms. Under Recommendation 11, the Agency established a Neutrality Policy and Implementation Unit and incorporated neutrality into a draft Strategic Risk Register. These measures formalize institutional responsibility for neutrality but do not provide a mechanism for identifying terrorist affiliations, testing staff backgrounds against external intelligence, or detecting military activity within Agency operations. Similarly, UNRWA’s Gender Parity Portfolios and efforts to increase women in senior management under Recommendation 14, while responsive to Colonna, provide no evidence that underlying neutrality risks have diminished.

UNRWA’s project reforms under Recommendation 16 present the same problem. The Agency rolled out a Project Procedures Manual and launched a public Project Transparency Portal to improve transparency and traceability. These measures may improve project administration, but they do not establish that projects or facilities are protected from terrorist exploitation or provide an independent means of detecting such misuse.

5. The More Structural Reforms Remain Unfinished (Recommendations 7 & 12)

Most revealingly, the two recommendations that remain unfinished concern reforms less amenable to completion through policies, training, or administrative systems. Recommendation 7 requires periodic independent evaluations of DIOS. UNRWA acknowledges that reviews of both its investigation and evaluation functions remain underway, appropriately recognizing that initiating an external review is not the same as completing one.

Recommendation 12 likewise remains unfinished. Colonna called on UNRWA to “reinforce the internationalization of UNRWA’s senior managerial area staff positions,”^{[109]Independent Review of Mechanisms and Procedures to Ensure Adherence by UNRWA to the Humanitarian Principle of Neutrality, UN (April 20, 2024), Link, archive link: Link.} but further internationalization remains contingent on additional funding. Whatever the financial constraints, this structural reform has not been implemented.

This contrast exposes the weakness of UNRWA’s 87% completion figure. The metric gives equal weight to administrative measures such as e-courses and policies as well as to more structural oversight reforms, allowing easier process requirements to be checked off while more consequential reforms remain unfinished. The resulting figure measures administrative completion more than whether UNRWA’s underlying oversight and accountability failures have been resolved.

UNRWA claims to have completed 90% of the Colonna recommendations on staff neutrality, closing nine of ten recommendations by Q2 2026.^[126]Id. But this figure substantially overstates the significance of the reforms. UNRWA frequently treats the completion of an administrative deliverable—a revised policy, training program, pilot project, monitoring tool, or procedural reform—as equivalent to resolving the underlying neutrality problem. The relevant question is not simply whether UNRWA created new systems, but whether those systems are capable of identifying and addressing the extensive Hamas infiltration and support among UNRWA staff documented by independent investigations and other evidence.^{[127]See, e.g., INVESTIGATIVE SUMMARY: USAID Inspector General’s Continuing Investigation Leads to Referral of Over 100 Current and Former UNRWA Staff Linked to Hamas for Suspension/Debarment, USAID OIG (June 5, 2026), Link, archive link: Link; The Connection Between UNRWA and Hamas in Gaza, GOVEXTRA (Last visited August 24, 2026), Link, archive link: Link; Schools in the Grip of Terror: How UNRWA Allowed Hamas Chiefs to Control its Education System, UN Watch (September 2025), Link; The Unholy Alliance: UNRWA, Hamas and Islamic Jihad, UN Watch (December 2024), Link.}

1. UNRWA Counts Administrative Outputs as Completed Reforms (Recommendations 20, 24, 25)

Several of UNRWA’s “completed” recommendations illustrate the weakness of its 90% figure. Most strikingly, UNRWA closed Recommendation 24 after completing a commercial vetting pilot, evaluation, and costed implementation plan.^{[128]Q1 Progress Report: Implementing the Colonna Report at UNRWA: January 2026-March 2026, UNRWA (May 11, 2026), Link; archive link: Link.} Yet in Q2 2026—after declaring the recommendation complete—UNRWA acknowledged that it was still “exploring options for the phased introduction of commercial vetting,” subject to funding.^{[129]Q2 Progress Report: Implementing the Colonna Report at UNRWA: April 2026-June 2026, UNRWA (August 2, 2026), Link archive link: Link.}

The same problem appears in Recommendations 20 and 25. UNRWA closed Recommendation 20 after institutionalizing a neutrality training plan and holding a May 2026 Training of Trainers workshop for 34 personnel, although the Neutrality Training Handbook remained under development.^[130]Id. It closed Recommendation 25 after developing a tool to monitor public social media expressions, while subsequently reporting that its social media monitoring capabilities were still being refined.^{[131]Id. See also Q4 Progress Report: Implementing the Colonna Report at UNRWA October 2025-December 2025, UNRWA (February 2, 2026), Link, archive link: Link}

These may be legitimate institutional improvements, but completing a pilot, mechanism, or training infrastructure does not establish a more neutral workforce. Indeed, while UNRWA was reporting near-completion of the Colonna reforms, USAID OIG identified extensive terrorism-related affiliations among current and former UNRWA personnel. In June 2026, USAID OIG referred 108 current or former UNRWA employees for suspension or debarment consideration based on participation in the October 7 attacks and/or affiliation with Hamas’s military wing, including school principals, deputy principals, teachers, security personnel, counselors, and medical staff.^{[132]INVESTIGATIVE SUMMARY: USAID Inspector General’s Continuing Investigation Leads to Referral of Over 100 Current and Former UNRWA Staff Linked to Hamas for Suspension/Debarment, USAID OIG (June 5, 2026), Link, archive link: Link.}

2. UNRWA’s Vetting System Does Not Screen for the Core Affiliation Problem (Recommendations 22-24)

Recommendations 22–24 seek to strengthen staff screening and vetting, but none of the mechanisms UNRWA identifies has been shown to systematically screen out Hamas membership. UNRWA screens against the UN Security Council Consolidated Sanctions List,^{[133]UNRWA: Claims Versus Facts, UNRWA ( February 2025), Link, archive link: Link; Statement by Philippe Lazzarini, UNRWA Commissioner-General at the Meeting of the Advisory Commission (AdCom), UNRWA (June 25, 2025), Link, archive link: Link.} which does not designate Hamas or PIJ. ClearCheck 2.0, digitalized background verification, and expanded screening at recruitment, promotion, and transfer do not close this gap. Nor has UNRWA shown that its proposed commercial vetting would screen for Hamas membership. Despite closing Recommendation 24, it had completed only a pilot and costed implementation plan, with rollout still subject to funding.^{[134]Q2 Progress Report: Implementing the Colonna Report at UNRWA: April 2026-June 2026, UNRWA (August 2, 2026), Link archive link: Link.}

UNRWA’s own rules create an additional limitation. Staff may hold personal political views and belong to political parties subject to restrictions on political activity,^{[135]Code of Ethics, UNRWA (2023), Link, archive link at Link.} while membership in militant or armed groups is prohibited.^{[136]Statement by UNRWA Commissioner-General ad interim Christian Saunders at the Pledging Conference, UNRWA (June 30, 2026), Link, archive link at Link.} Thus, Hamas affiliation itself does not trigger exclusion unless UNRWA can establish prohibited military affiliation or activity. Yet identifying such affiliation requires precisely the kind of intelligence UNRWA acknowledges it does not possess: the Agency states that it has no police or intelligence capacities and depends on Member States for such information.^{[137]Statement by the Commissioner-General ad interim of UNRWA, Christian Saunders, UNRWA (June 11, 2026), Link, archive link: Link.}

External investigations illustrate the consequences. In June 2026, USAID OIG identified UNRWA personnel simultaneously occupying significant military positions with Hamas, including a deputy school principal serving as a deputy company commander and squad leader, as well as other educators and staff serving in military and intelligence functions.^{[138]INVESTIGATIVE SUMMARY: USAID Inspector General’s Continuing Investigation Leads to Referral of Over 100 Current and Former UNRWA Staff Linked to Hamas for Suspension/Debarment, USAID OIG (June 5, 2026), Link, archive link: Link.} Israel has likewise published evidence identifying UNRWA employees whom it says held positions in Hamas and PIJ.^{[139]The Connection Between UNRWA and Hamas in Gaza, GOVEXTRA (Last visited August 24, 2026), Link, archive link: Link.} UNRWA school principal Emad Yousef Al-Samhouri provides a concrete example: after he was killed by Israel, Hamas eulogized him in a martyr video as a Hamas operative and platoon commander in the Rafah Brigade,^{[140]@HillelNeuer, X (August 13, 2026, 7:07 PM), Link.} while UNRWA mourned him as an employee killed in the conflict.^{[141]@HillelNeuer, X (August 13, 2026, 7:44 PM), Link.} A further example emerged in July 2026, when UNRWA teacher Nabhan Mohammed Nabhan Al-Amsi was killed in an Israeli strike. The Gaza Staff Union mourned Al-Amsi as an UNRWA teacher,^{[142]UNRWA Health Department Staff Meeting, Facebook (July 22, 2026), Link, archive link: Link.} while the IDF identified him as head of the Military Intelligence Desk in Hamas’s Gaza Brigade.^{[143]Israel kills three Hamas members in Gaza, Shafaq News (July 25, 2026), Link, archive link: Link.}

Recommendation 23 suffers from a separate problem. It relies on sharing staff information with Israel and host authorities for external cross-checking. Israel states that meaningful cross-checking became possible only after UNRWA provided a digital Gaza staff list containing identification numbers in February 2024.^{[144]Dismantling UNRWA Chief Lazzarini's Falsehoods, GOVEXTRA (January 2025), Link, archive link: Link.} But the mechanism can no longer operate as contemplated with Israel. Legislation that entered into force in January 2025 prohibits Israeli government authorities from maintaining contact with UNRWA or its representatives.^{[145]Approved in final readings: Bill banning state authorities from maintaining any contact with UNRWA or a representative of the agency, Knesset News (October 29, 2024), Link, archive link: Link.} UNRWA nevertheless continues to count Recommendation 23 as completed.

Thus, UNRWA’s screening reforms have not been shown to systematically screen for Hamas membership; the Agency lacks independent intelligence capabilities to identify military affiliation; and a principal external cross-checking mechanism envisioned by Colonna is no longer operational.

3. Social Media Monitoring Cannot Ensure Staff Neutrality (Recommendation 25)

UNRWA closed Recommendation 25 after developing a tool to monitor potential neutrality breaches in staff members’ public social media activity.^{[146]Q4 Progress Report: Implementing the Colonna Report at UNRWA October 2025-December 2025, UNRWA (February 2, 2026), Link, archive link: Link.} Such monitoring can identify public violations, but it cannot detect activity through private profiles, closed groups, or private communications on platforms such as WhatsApp and Telegram, nor conduct expressed offline.

UN Watch has documented years of UNRWA employees publicly praising Hamas, glorifying terrorism, and promoting antisemitism.^{[147]UNRWA Report, UN Watch (Last visited August 24, 2026), Link, archive link: Link.} Following October 7, UN Watch documented a Telegram group of approximately 3,000 UNRWA Gaza teachers and other staff in which members celebrated the attacks, praised the terrorists, and shared Hamas-related content.^{[148]Group of 3,000 UNRWA teachers celebrates Hamas massacre and rape, UN Watch (January 10, 2024), Link; see also UNRWA’s Terrorgram, UN Watch (January 10, 2024), Link.} Such monitoring also depends on the conduct remaining visible. Employees can avoid detection by deleting posts, restricting profiles, moving communications to closed groups, or simply ceasing to express such views publicly. None of these changes establishes that the employee has become more neutral.

The problem also extends beyond individual social media activity. UNRWA staff unions have repeatedly mobilized in support of employees disciplined for neutrality violations. In 2011, the Gaza Staff Union conducted months of protests after UNRWA suspended principal Suhail Al-Hindi over Hamas-related activities;^{[149]Schools in the Grip of Terror: How UNRWA Allowed Hamas Chiefs to Control its Education System, UN Watch (September 2025), Link.} in 2023, the Lebanon Staff Union organized weeks of protests after teacher Riad Nimr was suspended for social media posts supporting terrorism;^{[150]Striking UNRWA Staff Protest Suspension of Teacher Who Incited Terrorism, UN Watch (March 22, 2023), Link.} and in 2024, the Union organized prolonged protests and school strikes in support of Fateh Sharif after his suspension.^{[151]Schools in the Grip of Terror: How UNRWA Allowed Hamas Chiefs to Control its Education System, UN Watch (September 2025), Link.} Hamas subsequently acknowledged Sharif as its leader in Lebanon after he was killed in a targeted Israeli strike.^[152]Id.

These cases reflect a broader institutional challenge in which pro-Hamas and nationalist sentiment conflicts with UN neutrality requirements and segments of UNRWA’s workforce have resisted their enforcement. Public social media monitoring may detect some violations, but it does not address the underlying attitudes, affiliations, or conduct.

4. UNRWA Bypassed Its “Strengthened” Disciplinary System in the 70 Gaza Cases (Recommendations 21 & 27)

UNRWA counts Recommendations 21 and 27 as completed based on strengthened procedures for investigating and disciplining neutrality violations, including revised SOPs and reforms to its disciplinary processes.^{[153]Q3 Progress Report: Implementing the Colonna Report at UNRWA July 2025-September 2025, UNRWA (October 20, 2025) Link, archive link: Link; Q1 Progress Report: Implementing the Colonna Report at UNRWA: January 2026-March 2026, UNRWA (May 11, 2026), Link; archive link: Link.} Yet its handling of the most serious recent allegations against its staff raises questions about the effectiveness of those systems.

On June 11, 2026, UNRWA terminated 70 Gaza employees with immediate effect following a safety and security assessment, while expressly stating that the dismissals were “not part of a disciplinary process” and did not validate the underlying allegations.^{[154]Statement by the Commissioner-General ad interim of UNRWA, Christian Saunders, UNRWA (June 11, 2026), Link, archive link: Link.} UNRWA said it had repeatedly sought supporting evidence from Israel and emphasized that it lacks police or intelligence capacities.^[155]Id.

Yet information concerning at least some of these employees was already publicly available. UN Watch had documented public evidence concerning several UNRWA employees with ties to Hamas, including social media support for Hamas and terrorism and Arabic-language reporting on alleged Hamas activities.^{[156]Fired UNRWA Staff Claim Innocence While Praising Hamas Terrorists and Suicide Bombers, UN Watch (June 16, 2026), Link; see also Schools in the Grip of Terror: How UNRWA Allowed Hamas Chiefs to Control its Education System, UN Watch (September 2025), Link.} One was Mohammad Juma Shuwaideh, an UNRWA school principal and Gaza Union official who was also a Hamas commander^[157]Id. and was among the 70 employees dismissed in June 2026.^{[158]Shocking messages: UNRWA lays off dozens of employees in Gaza, Al Jazeera (June 22, 2026), Link, archive link: Link.} Another, Muhammad Abd Al-Nasser Al-Khatib, was a commander in Hamas’s Maghazi Battalion.^{[159]Teachers’ Sector at UNRWA - Gaza City, Facebook (August 1, 2026), Link, archive link: Link; IDF kills several terrorists in Gaza from Hamas, Palestinian Islamic Jihad, Army of Islam, Jerusalem Post (August 2, 2026), Link, archive link: Link; @IDF Arabic, Telegram (August 2, 2026, 8:49 AM), Link, archive link: Link.} After his death in an Israeli strike, the Gaza Staff Union confirmed that he was among the 70 employees and mourned him as a colleague dismissed over what it called “false and unsubstantiated allegations.”^{[160]Teachers’ Sector at UNRWA - Gaza City, Facebook (August 1, 2026), Link, archive link: Link.} Separately, USAID OIG referred more than 100 current or former UNRWA personnel for suspension or debarment consideration based on evidence of October 7 participation and/or Hamas military-wing affiliation.^{[161]INVESTIGATIVE SUMMARY: USAID Inspector General’s Continuing Investigation Leads to Referral of Over 100 Current and Former UNRWA Staff Linked to Hamas for Suspension/Debarment, USAID OIG (June 5, 2026), Link, archive link: Link.}

UNRWA thus closed recommendations intended to strengthen investigation and discipline, yet bypassed that framework when confronting dozens of terrorism-related cases and expressly declined to determine whether the underlying allegations were true.

5. Training and Whistleblower Protections Cannot Address the Underlying Neutrality Problem (Recommendations 20 & 26)

UNRWA cites expanded neutrality training and whistleblower protections as evidence of reform. More than 8,500 employees completed a mandatory humanitarian principles e-learning course under Recommendation 18;^{[162]Q3 Progress Report: Implementing the Colonna Report at UNRWA July 2025-September 2025, UNRWA (October 20, 2025) Link, archive link: Link.} under Recommendation 20, UNRWA institutionalized neutrality training through a Training of Trainers model;^{[163]Q1 Progress Report: Implementing the Colonna Report at UNRWA: January 2026-March 2026, UNRWA (May 11, 2026), Link; archive link: Link.} and under Recommendation 26, it conducted whistleblower awareness, bystander, and anti-retaliation training, including for 70 middle managers.^[164]Id.

These measures address knowledge of neutrality rules and mechanisms for reporting violations. They do not address employees who knowingly maintain prohibited affiliations or activities. USAID OIG, for example, identified educators and other UNRWA personnel allegedly holding simultaneous roles within Hamas’s military structure—conduct that cannot plausibly be attributed to a failure to understand humanitarian principles.^{[165]INVESTIGATIVE SUMMARY: USAID Inspector General’s Continuing Investigation Leads to Referral of Over 100 Current and Former UNRWA Staff Linked to Hamas for Suspension/Debarment, USAID OIG (June 5, 2026), Link, archive link: Link.}

Formal whistleblower protections also cannot by themselves overcome an environment in which employees have repeatedly rallied behind colleagues accused of Hamas-related or other serious neutrality violations. UNRWA staff unions have organized protests, strikes, and pressure campaigns on behalf of disciplined employees,^{[166]Schools in the Grip of Terror: How UNRWA Allowed Hamas Chiefs to Control its Education System, UN Watch (September 2025), Link.} a pattern that continued after Colonna. Following UNRWA’s June 2026 dismissal of 70 Gaza employees over terrorism-related allegations, the Gaza Staff Union organized a large-scale sit-in demanding their reinstatement and pledged continued action until the dismissals were reversed.^{[167]UNRWA Health Department Staff Meeting, Facebook (July 21, 2026), Link, archive link: Link.}

6. Staff Care Is Important, but It Does Not Address the Neutrality Problem (Recommendation 28)

Recommendation 28—the sole recommendation UNRWA still classifies as incomplete—calls for an international Staff Care Specialist in each of UNRWA’s five fields.^{[168]Independent Review of Mechanisms and Procedures to Ensure Adherence by UNRWA to the Humanitarian Principle of Neutrality, UN (April 20, 2024), Link, archive link: Link.} UNRWA reports substantial demand for staff care services but states that recruitment of the five specialists remains dependent on predictable funding.^{[169]Q2 Progress Report: Implementing the Colonna Report at UNRWA: April 2026-June 2026, UNRWA (August 2, 2026), Link archive link: Link.}

Staff wellbeing is a legitimate concern, particularly for personnel working under extraordinarily difficult conditions. But counseling for stress and trauma cannot address Hamas affiliation or support among UNRWA personnel, nor substitute for effective screening, investigation, and accountability.

Including staff care among the ten recommendations used to measure progress on “Neutrality of Staff” also illustrates the weakness of UNRWA’s claimed reform success rate. Even full implementation of Recommendation 28 would only expand employee wellbeing services, not establish that UNRWA’s workforce is free from terrorist affiliation or systemic neutrality violations.

UNRWA reports significant progress in protecting the civilian nature of its installations, including completion of Recommendations 29 and 30 and continuing implementation of Recommendations 31–33. Yet the fundamental weakness of this category lies partly in the Colonna recommendations themselves. The prescribed measures—training staff, educating communities, conducting administrative assessments, communicating with authorities, and reporting violations—may improve awareness and documentation of installation misuse, but they do not give UNRWA the physical security or investigative capacity necessary to prevent or reliably detect deliberate military exploitation of its facilities.

1. Training and Awareness Cannot Prevent Deliberate Military Misuse (Recommendations 29 and 30)

UNRWA closed Recommendation 29 after introducing training on the civilian nature of its installations and subsequently reported that more than 2,000 installation managers had received in-person training. It closed Recommendation 30 after community outreach through awareness sessions, school activities, murals, and posters. These measures may reinforce humanitarian principles, but they cannot prevent deliberate military exploitation by an armed organization. Extensive evidence indicates that Hamas deliberately embeds military activities and infrastructure within civilian environments.^{[186]Hamas’s Human Shield Strategy in Gaza, Henry Jackson Society (April 2025), Link, archive: Link.}

The limitation is particularly acute where those responsible for safeguarding UNRWA installations are themselves affiliated with an armed group. USAID OIG has identified UNRWA school principals and other senior educators simultaneously serving in Hamas military roles.^{[187]INVESTIGATIVE SUMMARY: USAID Inspector General’s Continuing Investigation Leads to Referral of Over 100 Current and Former UNRWA Staff Linked to Hamas for Suspension/Debarment, USAID OIG (June 5, 2026), Link, archive link: Link.} Israel identified UNRWA school principal Mohammad Juma Shuwaideh as a Hamas squad commander in the Gaza Brigade,^{[188]Senior UNRWA Educators in Gaza Involved in Terrorism, GOVEXTRA (Last visited August 24, 2026), Link, archive link: Link.} and UN Watch reports that UNRWA subsequently placed him in charge of one of its shelters during the war.^{[189]Schools in the Grip of Terror: How UNRWA Allowed Hamas Chiefs to Control its Education System, UN Watch (September 2025), Link; See also Al-Jazeera Palestine, Facebook (October 20, 2023), Link, archive link: Link.} UNRWA ultimately dismissed him in June 2026 as one of 70 Gaza employees terminated following terrorism-related allegations.^{[190]Shocking messages: UNRWA lays off dozens of employees in Gaza, Al Jazeera (June 22, 2026), Link, archive link: Link.} Training an installation manager on the civilian character of a facility provides little safeguard if that manager is himself affiliated with the armed organization whose misuse the system is intended to prevent.

UNRWA’s closure of Recommendation 30 also illustrates the weakness of its completion methodology. UNRWA declared the recommendation complete in Q4 2025 while acknowledging that implementation in Gaza and the West Bank remained constrained by the political and security context.^{[191]Q4 Progress Report: Implementing the Colonna Report at UNRWA October 2025-December 2025, UNRWA (February 2, 2026), Link, archive link: Link} ‘Completion’ therefore did not mean that the prescribed community-awareness measures had been fully implemented across all five fields.

2. The Inspection System Is Weakest Where the Threat Is Greatest (Recommendation 31)

Recommendation 31 calls for additional capacity to “increase the frequency and widen the scope” of installation visits to include military misuse, after Colonna found existing quarterly inspections “insufficient” and daily monitoring inadequate.^{[192]Independent Review of Mechanisms and Procedures to Ensure Adherence by UNRWA to the Humanitarian Principle of Neutrality, UN (April 20, 2024), Link, archive link: Link.} UNRWA reports that its Integrated Assessments now use updated questionnaires and SOPs to capture potential military misuse, but the assessments remain quarterly and the standard regime does not operate in Gaza. In Q1 2026, UNRWA assessed 85 percent of installations outside Gaza.^{[193]Q1 Progress Report: Implementing the Colonna Report at UNRWA: January 2026-March 2026, UNRWA (May 11, 2026), Link; archive link: Link.} In Q2, it conducted 599 assessments across all fields except Gaza, where security and access restrictions require an “adapted monitoring approach.”^{[194]Q2 Progress Report: Implementing the Colonna Report at UNRWA: April 2026-June 2026, UNRWA (August 2, 2026), Link archive link: Link.}

Gaza is not a peripheral exception. It is the field where the most serious evidence and allegations of military misuse have arisen, including tunnels and shafts beneath or adjacent to facilities, weapons and military infrastructure at UNRWA sites, and personnel allegedly holding Hamas military roles.^{[195]Hamas’s Human Shield Strategy in Gaza, Henry Jackson Society (April 2025), Link, archive: Link; UPDATED: Evidence Of UNRWA Aid To Hamas On And After October 7th, UN Watch (July 12, 2024), Link; Senior UNRWA Educators in Gaza Involved in Terrorism, GOVEXTRA (Last visited August 24, 2026), Link, archive link: Link.} The standard inspection system is therefore absent where detecting military misuse is most consequential.

More fundamentally, the inspection regime is structurally incapable of detecting and addressing the most serious forms of military misuse. Colonna acknowledged that UNRWA lacks the “policing, military or wider investigative capacities or competencies required to detect” critical breaches such as weapons, military activity, or tunnels.^{[196]Independent Review of Mechanisms and Procedures to Ensure Adherence by UNRWA to the Humanitarian Principle of Neutrality, UN (April 20, 2024), Link, archive link: Link.} Acting Commissioner-General Christian Saunders reiterated this limitation in June 2026, stating that UNRWA “does not have police or intelligence capacities” and depends on Member States for information concerning serious allegations.^{[197]Statement by the Commissioner-General ad interim of UNRWA, Christian Saunders, UNRWA (June 11, 2026), Link, archive link: Link.}

3. Cooperation with Israel Cannot Operate as Colonna Envisaged (Recommendation 32)

Recommendation 32 contemplated strengthened cooperation with host countries and Israel concerning misuse of UNRWA installations, including possible joint visits. Earlier UNRWA reports cite bilateral engagement with Israel and host countries and formal protest letters. Later reports refer only to host countries or Member States, without identifying continued engagement with Israel.

An essential component of the recommendation can no longer operate as envisaged. Israeli legislation adopted in October 2024 prohibits Israeli government agencies and representatives from maintaining contact with UNRWA or its representatives,^{[198]Approved in final readings: Bill banning state authorities from maintaining any contact with UNRWA or a representative of the agency, Knesset News (October 29, 2024), Link, archive link: Link.} precluding substantive coordination or joint visits that could provide external verification of alleged misuse.

Formal protest letters do not fill that gap. They may document UNRWA’s objection after an incident, but cannot independently verify an installation, identify concealed military infrastructure, or remove military assets. UNRWA may therefore continue administrative elements of Recommendation 32 through letters and engagement with other authorities, but the cooperation with Israel expressly contemplated by Colonna cannot currently function.

4. Reporting Violations Is Reactive, Not Preventive (Recommendation 33)

Recommendation 33 calls for transparent reporting to Member States on violations of the neutrality and inviolability of UNRWA installations.^{[199]Independent Review of Mechanisms and Procedures to Ensure Adherence by UNRWA to the Humanitarian Principle of Neutrality, UN (April 20, 2024), Link, archive link: Link.} UNRWA is developing regular Integrated Assessment Reports and continues to classify the recommendation as in progress.^{[200]Q2 Progress Report: Implementing the Colonna Report at UNRWA: April 2026-June 2026, UNRWA (August 2, 2026), Link archive link: Link.} Such reporting is inherently reactive: it does not prevent military exploitation of an installation, detect concealed infrastructure, or address involvement by UNRWA personnel.

UNRWA has also repeatedly framed this reporting in terms of breaches by “external actors.”^{[201]Q3 Progress Report: Implementing the Colonna Report at UNRWA July 2025-September 2025, UNRWA (October 20, 2025) Link, archive link: Link; Q4 Progress Report: Implementing the Colonna Report at UNRWA October 2025-December 2025, UNRWA (February 2, 2026), Link, archive link: Link.} Yet USAID OIG,^{[202]INVESTIGATIVE SUMMARY: USAID Inspector General’s Continuing Investigation Leads to Referral of Over 100 Current and Former UNRWA Staff Linked to Hamas for Suspension/Debarment, USAID OIG (June 5, 2026), Link, archive link: Link.} Israel,^{[203]Senior UNRWA Educators in Gaza Involved in Terrorism, GOVEXTRA (Last visited August 24, 2026), Link, archive link: Link.} and UN Watch^{[204]Schools in the Grip of Terror: How UNRWA Allowed Hamas Chiefs to Control its Education System, UN Watch (September 2025), Link.} have identified UNRWA employees—including school principals, educators, security personnel, and other staff—who simultaneously held positions within Hamas or PIJ. Meaningful reporting must therefore examine not only which external actor misused an installation, but whether UNRWA personnel facilitated, participated in, knew of, or failed to report the misuse.

Recommendation 33 remains unfinished more than two years after the Colonna Report, with successive progress reports still describing efforts to strengthen or finalize reporting to Member States. Given the extensive evidence of military activity in and around UNRWA facilities since October 7,^{[205]Hamas’s Human Shield Strategy in Gaza, Henry Jackson Society (April 2025), Link, archive: Link; UPDATED: Evidence Of UNRWA Aid To Hamas On And After October 7th, UN Watch (July 12, 2024), Link.} such reporting should identify the circumstances of each incident, the actor involved, whether civilians were present, whether the facility was functioning as a civilian installation, and any evidence of involvement or knowledge by UNRWA personnel. Without that transparency, the reporting mechanism cannot provide a meaningful account of installation misuse or help identify how it can be prevented.

UNRWA’s reported progress under Category 6 largely measures the creation or completion of administrative processes—textbook reviews, reporting channels, classroom inspections, teacher training, and digital tools—rather than whether the underlying neutrality problems in its education system have been resolved. Most importantly, UNRWA has not demonstrated that educational content inconsistent with UN values has actually been eliminated from its classrooms.

1. Reviewing Problematic Textbooks Does Not Remove Problematic Content (Recommendations 34 and 35)

UNRWA closed Recommendation 34 after determining that it had completed all actions “within its control,” principally by systematically reviewing host-country textbooks against UN values and UNESCO standards and establishing mechanisms to share its findings with relevant authorities upon request.^{[216]Q4 Progress Report: Implementing the Colonna Report at UNRWA October 2025-December 2025, UNRWA (February 2, 2026), Link, archive link: Link} Yet Recommendation 34 called for reviewing “all textbooks and supplements with host countries, Israel and the Palestinian Authority,” not merely conducting an internal review and sharing findings upon request.^{[217]Independent Review of Mechanisms and Procedures to Ensure Adherence by UNRWA to the Humanitarian Principle of Neutrality, UN (April 20, 2024), Link, archive link: Link.} Nor does reviewing textbooks remove the problematic content identified. UNRWA continues to use host-country curricula, while acknowledging that additional UNRWA-owned materials aligned with UN values and UNESCO standards would require substantial resources and have therefore been deferred.

This is particularly important because Recommendation 35 requires UNRWA to ban hate speech, incitement to violence, and antisemitic references from educational materials and directs it, “[i]n the meantime, [to] stop using such material.”^{[218]Independent Review of Mechanisms and Procedures to Ensure Adherence by UNRWA to the Humanitarian Principle of Neutrality, UN (April 20, 2024), Link, archive link: Link.} UNRWA states that its policy prohibits such content in classrooms.^{[219]Q2 Progress Report: Implementing the Colonna Report at UNRWA: April 2026-June 2026, UNRWA (August 2, 2026), Link archive link: Link.} Yet, the education watchdog, IMPACT-se, found that the 2025–2026 PA curriculum used in UNRWA schools in Gaza and the West Bank continued to contain material promoting jihad, glorifying violence and terrorism, and conveying antisemitic narratives.^{[220]Analyzing UNRWA’s Response to the UN Independent Review (Colonna Report), IMPACT-se (July 2026), Link, archive: Link; see also Review of the 2025-2026 Palestinian Authority School Curriculum Grades 1-12 Selected Examples, IMPACT-se (November 2025), Link, archive: Link.}

IMPACT-se identifies, among other examples, a Grade 5 Arabic lesson presenting militant figures as heroic role models and referring to Dalal Mughrabi, perpetrator of the 1978 Coastal Road massacre in which 38 Israelis, including 13 children, were killed. A Grade 9 Islamic Education lesson presents violent jihad against non-Muslims as religiously mandated and potentially applicable beyond its historical context, while a Grade 8 chapter teaches the concepts of the mujahid and martyr and presents jihad and death in battle positively.^[221]Id.

Recommendation 34 also cannot readily be treated as a completed task because host-country curricula continue to change. IMPACT-se reports that the PA, Jordan, and Syria introduced new or revised materials after UNRWA’s initial reviews, with no publicly available evidence that UNRWA subsequently reviewed all of them.^{[222]Analyzing UNRWA’s Response to the UN Independent Review (Colonna Report), IMPACT-se (July 2026), Link, archive: Link.} Institutionalizing a review mechanism does not make the task complete where the curricula continue to change and newly introduced materials require ongoing review.

2. UNRWA’s “Completion” Methodology Measures Administrative Milestones, Not Substantive Implementation (Recommendations 38, 39 and 41)

UNRWA’s education completion claims must be understood in light of the “Minimum Viable Product” (MVP) methodology introduced in June 2025.^{[223]One Year On: Implementing the Colonna Report at UNRWA: Annual Report June 2024-June 2025, UNRWA (August 5, 2025), Link, archive link: Link.} Under this approach, a recommendation may be classified as completed once its “core functional objective” has been achieved, even where further measures remain necessary for full institutionalization. Following its introduction, UNRWA’s overall number of completed Colonna recommendations increased from five in April 2025 to 20 by June.^{[224]See also UNRWA Implementation of Colonna Report April 2025, UNRWA (April 23, 2025), Link, archive link: Link; Q3 Progress Report: Implementing the Colonna Report at UNRWA July 2025-September 2025, UNRWA (October 20, 2025) Link, archive link: Link.}

Category 6 illustrates the problem. UNRWA closed Recommendation 38 after establishing a hotline for reporting problematic teaching content, Recommendation 39 after institutionalizing randomized classroom inspections, and Recommendation 41 after establishing regular neutrality and humanitarian principles training for teachers and principals.^{[225]Q3 Progress Report: Implementing the Colonna Report at UNRWA July 2025-September 2025, UNRWA (October 20, 2025) Link, archive link: Link.} These may be useful oversight mechanisms, but UNRWA provides little information on their results, including serious neutrality violations detected, corrective action taken, or measurable improvements in classroom neutrality.

This concern is particularly significant given the composition of the education workforce itself. UN Watch has documented senior UNRWA educators—including school principals and other education officials—with Hamas affiliations or military roles.^{[226]Schools in the Grip of Terror: How UNRWA Allowed Hamas Chiefs to Control its Education System, UN Watch (September 2025), Link.} The effectiveness of internal reporting and classroom oversight ultimately depends on the neutrality of the personnel implementing and responding to these mechanisms.

UNRWA’s own funding estimates further illustrate the gap between technical “completion” and implementation. IMPACT-se reports that UNRWA sought approximately $800,000 for Recommendation 38 and $23 million for Recommendation 41, yet subsequently classified both as completed.^{[227]Analyzing UNRWA’s Response to the UN Independent Review (Colonna Report), IMPACT-se (July 2026), Link, archive: Link.} Recommendations can therefore be closed under the MVP methodology while substantial resources remain necessary to operationalize or institutionalize the underlying reforms.

UNRWA’s reliance on teacher training also warrants caution. Its Critical Thinking Approach, intended to help teachers address problematic content in host-country textbooks, predated Colonna and was already operating when the Review identified continuing educational-neutrality concerns. Expanding a methodology already in place when those deficiencies were identified does not demonstrate its effectiveness in correcting them.^[228]Id.

3. Digitalization Does Not Equal Transparency or Curriculum Reform (Recommendation 40)

UNRWA presents expansion of its Digital Learning Platform (DLP) as a means of centralizing educational resources, increasing transparency, and supporting education during emergencies. Although Recommendation 40 specifically links continued digitalization to increased transparency, expanding digital access does not establish transparency over the curriculum actually taught in UNRWA classrooms.

IMPACT-se reports that the DLP functions primarily as an emergency remote-learning tool, while students continue to rely on hard-copy PA textbooks. It also found that key subjects, including Islamic education and social studies, were unavailable on the platform.^{[229]Analyzing UNRWA’s Response to the UN Independent Review (Colonna Report), IMPACT-se (July 2026), Link, archive: Link.} Even a fully functioning DLP therefore would not provide transparency over the full curriculum taught to students.

This limitation is significant because IMPACT-se’s separate review of 290 textbooks and 71 teacher guides in the 2025–2026 PA curriculum found problematic content across numerous subjects.^{[230]Review of the 2025-2026 Palestinian Authority School Curriculum Grades 1-12 Selected Examples, IMPACT-se (November 2025), Link, archive: Link; see also Review of the 2025-2026 Palestinian Authority School Curriculum Grades 1-12 Selected Examples, IMPACT-se (November 2025), Link, archive: Link.} Expanding digital infrastructure and making selected materials available online does not establish that such content has been removed from the underlying curriculum or that material taught in UNRWA classrooms conforms to UN standards.

4. Engagement with UNESCO Is Not Evidence of Compliance with UNESCO Standards (Recommendation 36)

UNRWA cites its continuing engagement with UNESCO under the 2023 Recommendation on Education for Peace, Human Rights, and Sustainable Development as evidence of progress under Recommendation 36.^{[231]Q2 Progress Report: Implementing the Colonna Report at UNRWA: April 2026-June 2026, UNRWA (August 2, 2026), Link archive link: Link.} But Recommendation 36 does not merely call for engagement with UNESCO; it requires a yearly review of all textbooks and supplements used in UNRWA schools together with UNESCO.^{[232]Independent Review of Mechanisms and Procedures to Ensure Adherence by UNRWA to the Humanitarian Principle of Neutrality, UN (April 20, 2024), Link, archive link: Link.} UNRWA’s progress reports describe continuing engagement and dialogue on textbook review methodologies, but do not report completion of such a yearly joint review.

The relevant question is whether the educational content received by students actually conforms to UN standards. IMPACT-se’s 2025–2026 curriculum review found that antisemitic narratives, glorification of terrorism, incitement to violence, and other problematic material remained in textbooks used in UNRWA schools despite UNRWA’s engagement with UNESCO.^{[233]Review of the 2025-2026 Palestinian Authority School Curriculum Grades 1-12 Selected Examples, IMPACT-se (November 2025), Link, archive: Link.}

UNRWA should therefore be assessed on substantive alignment with UNESCO standards, not the existence of a dialogue about those standards.

5. Gender Parity Does Not Measure Education Neutrality (Recommendation 37)

UNRWA also counts Recommendation 37, concerning women's representation in educational management, among the five completed recommendations underlying its 63% Category 6 completion rate. UNRWA subsequently reported that women held 56% of leadership positions within its Education Programme by Q2 2026.^{[234]Q2 Progress Report: Implementing the Colonna Report at UNRWA: April 2026-June 2026, UNRWA (August 2, 2026), Link archive link: Link.}

Increasing women’s representation in educational leadership may be a legitimate institutional objective, but it does not demonstrate progress on the neutrality problems at the center of Category 6, such as problematic textbooks, teacher conduct, classroom incitement, or Hamas influence within the education workforce.

Its inclusion also highlights a broader weakness in UNRWA’s 63% completion figure, which gives equivalent numerical weight to fundamentally different measures: achieving gender representation targets, establishing a reporting hotline, reviewing textbooks, conducting classroom inspections, and training teachers. The percentage measures completion of prescribed actions, not substantive neutrality in UNRWA’s education system.

UNRWA reports all six recommendations in Category 7 as closed. Yet its own progress reports show that several of the structural reforms prescribed by Colonna have not actually been implemented. The 6/6 closure figure therefore misrepresents the true picture.

Colonna had identified staff unions as a significant neutrality risk, citing “long-standing concerns over politicization and interlinkages with Palestinian political factions,” politicized union elections, and resistance to disciplinary actions “including on neutrality.” The Independent Review concluded that “an urgent modernization of the union statute and operational structures is needed.”^{[246]Independent Review of Mechanisms and Procedures to Ensure Adherence by UNRWA to the Humanitarian Principle of Neutrality, UN (April 20, 2024), Link, archive link: Link.} Yet events after UNRWA declared Category 7 fully closed—including the Gaza Staff Union’s mobilization against the June 2026 dismissal of 70 employees following allegations of links to armed organizations—show that the structural problems identified by Colonna remain unresolved.^{[247]UNRWA Health Department Staff Meeting, Facebook (July 21, 2026), Link, archive link: Link.}

1. Drafting a Revised Statute Does Not Reform the Existing Union Structure

Recommendation 42 called on UNRWA to “Reform the 6 November 1990 Statute of the Union of Area Staff of UNRWA to align it with UN system Staff Union Statutes and Regulations,” particularly regarding union elections.^{[248]Independent Review of Mechanisms and Procedures to Ensure Adherence by UNRWA to the Humanitarian Principle of Neutrality, UN (April 20, 2024), Link, archive link: Link.} UNRWA closed the recommendation after commissioning an independent review, preparing a revised statute, and transmitting it to the Inter-Staff Union Conference. The proposed statute reportedly includes gender quotas, one-year term limits, reduced union membership, and other governance reforms.^{[249]Q1 Progress Report: Implementing the Colonna Report at UNRWA: January 2026-March 2026, UNRWA (May 11, 2026), Link; archive link: Link.}

But the revised statute has not been adopted. As of Q2 2026, UNRWA continued to state that responsibility for “considering and formally adopting” it rests with the staff unions.^{[250]Q2 Progress Report: Implementing the Colonna Report at UNRWA: April 2026-June 2026, UNRWA (August 2, 2026), Link archive link: Link.} The 1990 statute identified by Colonna as requiring modernization therefore remains in place.

This is particularly significant given Colonna’s findings that union elections were politicized, Palestinian political forces could use the unions to pressure UNRWA leadership, and staff unions had resisted disciplinary action, including on neutrality.^{[251]Independent Review of Mechanisms and Procedures to Ensure Adherence by UNRWA to the Humanitarian Principle of Neutrality, UN (April 20, 2024), Link, archive link: Link.} UN Watch has also documented senior union officials with Hamas affiliations, including former Gaza Staff Union chairman Suhail al-Hindi and former Lebanon Teachers Union head Fateh Sharif.^{[252]Schools in the Grip of Terror: How UNRWA Allowed Hamas Chiefs to Control its Education System, UN Watch (September 2025), Link.}

Yet the problem persisted even after UNRWA declared all six Category 7 recommendations closed. Three months later, the Gaza Staff Union mobilized against the dismissal of 70 employees and demanded their reinstatement.^{[253]UNRWA Health Department Staff Meeting, Facebook (July 21, 2026), Link, archive link: Link.} Union secretary Shuwaideh also stated that the union had sought abolition of the provision granting the Commissioner-General broad authority to dismiss employees.^{[254]Shocking messages: UNRWA lays off dozens of employees in Gaza, Al Jazeera (June 22, 2026), Link, archive link: Link.}

Against this background, closing Recommendation 42 before adoption of the revised statute treats completion of UNRWA’s preparatory work as implementation of the structural reform that Colonna prescribed.

2. Women’s Representation Does Not Address the Underlying Neutrality Problem

Recommendation 43 called for increased women’s representation in staff unions. UNRWA closed the recommendation based on activities through its Women’s Advisory Forum, including a gender analysis and capacity-building initiatives, but its progress reports do not demonstrate a corresponding increase in women actually serving as union representatives. The proposed gender quota also remains part of the revised Staff Union Statute, which has not been adopted.^{[255]Q2 Progress Report: Implementing the Colonna Report at UNRWA: April 2026-June 2026, UNRWA (August 2, 2026), Link archive link: Link.}

More fundamentally, increasing women’s representation does not address the neutrality concerns that prompted Colonna’s staff-union reforms: politicization, links with Palestinian political factions, politicized elections, and resistance to neutrality-related disciplinary action. Even full implementation of Recommendation 43 would therefore say little about whether those underlying problems have been addressed.

3. A Funding-Dependent Vetting Plan Is Not Neutrality Vetting

Recommendations 44 and 45 directly addressed the neutrality risks identified by Colonna. Recommendation 44 called on UNRWA to request, through an independent entity, “dedicated neutrality vetting for every staff union representative, beginning with the most senior,” while Recommendation 45 required UNRWA vetting procedures when representatives are elected.^{[256]Independent Review of Mechanisms and Procedures to Ensure Adherence by UNRWA to the Humanitarian Principle of Neutrality, UN (April 20, 2024), Link, archive link: Link.}

UNRWA nevertheless closed both recommendations in Q1 2026 after developing a costed plan for periodic and post-election vetting, while acknowledging that implementation remains contingent on “sustainable and predictable funding.”^{[257]Q1 Progress Report: Implementing the Colonna Report at UNRWA: January 2026-March 2026, UNRWA (May 11, 2026), Link; archive link: Link.} A funding-dependent plan for future vetting does not establish that the neutrality vetting required by Colonna is actually taking place.

The continuing relevance of this requirement is evident in Gaza. As of summer 2026, no new union bureau elections had occurred and Mustafa Al-Ghoul remained in charge. In June, Al-Ghoul acknowledged that UNRWA had described the allegations against the 70 dismissed employees as involving affiliation with Palestinian political factions, specifically Hamas, while demanding that the dismissals be reversed.^{[258]Shocking messages: UNRWA lays off dozens of employees in Gaza, Al Jazeera (June 22, 2026), Link, archive link: Link.} Shuwaideh simultaneously held a senior union role and was among those dismissed following allegations of links to armed organizations.^{[259]Id. See also Fired UNRWA Staff Claim Innocence While Praising Hamas Terrorists and Suicide Bombers, UN Watch (June 16, 2026), Link.} UN Watch had previously identified him in its September 2025 investigation, Schools in the Grip of Terror.^{[260]Schools in the Grip of Terror: How UNRWA Allowed Hamas Chiefs to Control its Education System, UN Watch (September 2025), Link.} These developments underscore why Colonna called for actual independent neutrality vetting of union representatives rather than merely a plan for future vetting.

4. “Unimplementable” Does Not Mean Implemented

Recommendation 46 directed UNRWA to “[o]utsource all issues related to the setting of pay and pay-related benefits to an independent entity comparable to the International Civil Service Commission.” Colonna identified the unions’ role in salary negotiations as a source of potential “undue influence” over UNRWA activities, noting repeated strikes and protests over pay, including a nearly 100-day union action in the West Bank in 2023.^{[261]Independent Review of Mechanisms and Procedures to Ensure Adherence by UNRWA to the Humanitarian Principle of Neutrality, UN (April 20, 2024), Link, archive link: Link.} Outsourcing pay-setting would remove this source of union leverage from the management-union relationship.

UNRWA did not implement the recommendation. After approaching the ICSC, UN Secretariat, ILO, and private-sector consultancies without finding an entity willing or able to assume the function, UNRWA closed Recommendation 46 in Q1 2026 as “unimplementable.”^{[262]Q1 Progress Report: Implementing the Colonna Report at UNRWA: January 2026-March 2026, UNRWA (May 11, 2026), Link; archive link: Link.} The underlying problem therefore remains. UNRWA’s conclusion that a structural reform deemed necessary by Colonna is “unimplementable” also underscores a central weakness of the entire reform project.

5. Category 7 Provides a Real-World Test of UNRWA’s Closure Claims

Category 7 illustrates the weakness of UNRWA’s closure methodology. Recommendation 42 was closed despite the revised statute remaining unadopted; Recommendations 44 and 45 were closed despite implementation of the vetting system remaining funding-dependent; and Recommendation 46 was closed despite being expressly deemed “unimplementable.” In each case, closure is treated as a measure of progress even though the structural reform prescribed by Colonna has not been—or cannot be—implemented.

The underlying union problems nevertheless persisted after closure. Within months, the Gaza union—under unchanged leadership—mobilized against the dismissal of 70 employees following allegations of links to armed organizations, including its own union secretary, and demanded their reinstatement.^{[263]UNRWA Health Department Staff Meeting, Facebook (July 21, 2026), Link, archive link: Link.} The union continued to challenge the dismissals in July, characterizing them as based on allegations and imposed without proper legal procedures, and demanding that UNRWA review the measures taken against employees.^{[264]Arab Employees Union in Gaza, Facebook (July 22, 2026), Link, archive link: Link.} Thus, despite all six recommendations being closed, the staff-union neutrality problems identified by Colonna remain unresolved.

UNRWA reports all three recommendations in Category 8 as completed, citing increased participation in humanitarian coordination mechanisms, new partnerships, additional staffing, and an internal “cultural shift.” These measures provide evidence of increased inter-agency engagement, particularly under Recommendation 49. But UNRWA’s 100% completion claim overstates the extent of the reform. Much of the cooperation it cites predates Colonna, while the “cultural shift” required by Recommendation 50 was still described as “underway” when the category was declared complete.^{[275]Q3 Progress Report: Implementing the Colonna Report at UNRWA July 2025-September 2025, UNRWA (October 20, 2025) Link, archive link: Link.}

1. Much of UNRWA’s Claimed “Enhanced Cooperation” Predates Colonna

UNRWA cites expanded partnerships and participation in humanitarian coordination mechanisms as evidence of reform. Yet Colonna itself emphasized that UNRWA already had a “long history of partnerships” before the Independent Review, including decades of embedded WHO expertise, numerous field-level partnerships, and existing cooperation with IOM, WFP, UNICEF, and other humanitarian organizations. The Review described UNRWA as already engaged in a “plethora of cross-agency partnerships.”^{[276]Independent Review of Mechanisms and Procedures to Ensure Adherence by UNRWA to the Humanitarian Principle of Neutrality, UN (April 20, 2024), Link, archive link: Link.}

UNRWA has taken some new steps that respond more directly to Recommendation 49, including securing a P-5 Senior Humanitarian Affairs Officer post, expanding staff training, and systematizing participation in cluster mechanisms. But longstanding or expanded partnerships are not themselves evidence of implementation of the specific changes prescribed by Colonna, and UNRWA declared the category complete while recruitment for the new P-5 position was still underway.

Israeli restrictions on official interaction with UNRWA and on its operations also constrain inter-agency cooperation where humanitarian activities require access, security coordination, movement of personnel or supplies, or engagement with Israeli authorities. Greater participation in coordination structures does not remove those constraints.

2. UNRWA Declared a “Cultural Shift” Complete While Describing It as Still Underway

Recommendation 50 required UNRWA to “drive an internal cultural shift” in redefining its relationship with the wider humanitarian community and its role within the coordination architecture, particularly the clusters.^{[277]Independent Review of Mechanisms and Procedures to Ensure Adherence by UNRWA to the Humanitarian Principle of Neutrality, UN (April 20, 2024), Link, archive link: Link.} Yet in the same reporting in which UNRWA declared all three Category 8 recommendations completed, it described this cultural shift as still “underway.”^{[278]One Year On: Implementing the Colonna Report at UNRWA: Annual Report June 2024-June 2025, UNRWA (August 5, 2025), Link, archive link: Link.} A reform UNRWA itself describes as ongoing cannot simultaneously serve as evidence of completed implementation.

Colonna also documented institutional resistance to such a shift. The Commissioner-General’s 2022 partnership initiative was abandoned after host governments and staff associations opposed greater involvement by other organizations, viewing it as a step toward dismantling UNRWA.^{[279]Independent Review of Mechanisms and Procedures to Ensure Adherence by UNRWA to the Humanitarian Principle of Neutrality, UN (April 20, 2024), Link, archive link: Link.} At the same time, UN Watch’s The Unholy Alliance documented longstanding engagement between senior UNRWA officials and Hamas, PIJ, and other factions, including meetings described in terms of “partnership,” “cooperation,” and “coordination,” and instances in which these groups pressured UNRWA over its decisions.^{[280]The Unholy Alliance: UNRWA, Hamas and Islamic Jihad, UN Watch (December 2024), Link.}

Serious neutrality problems also persisted after UNRWA declared the cultural shift complete. In June 2026, USAID OIG reported referrals involving 108 current or former UNRWA employees based on evidence of participation in the October 7 attacks and/or affiliation with Hamas’s military wing.^{[281]INVESTIGATIVE SUMMARY: USAID Inspector General’s Continuing Investigation Leads to Referral of Over 100 Current and Former UNRWA Staff Linked to Hamas for Suspension/Debarment, USAID OIG (June 5, 2026), Link, archive link: Link.} Days later, UNRWA dismissed 70 Gaza employees following a safety and security assessment, while expressly stating that the dismissals were not disciplinary and did not validate the underlying allegations.^{[282]Statement by the Commissioner-General ad interim of UNRWA, Christian Saunders, UNRWA (June 11, 2026), Link, archive link: Link.} The scale of serious neutrality cases identified by an external U.S. oversight body, even after UNRWA declared the cultural shift complete, calls into question what substantive change that claimed shift had produced.

3. Enhanced Cooperation Preserves Rather Than Tests UNRWA’s “Irreplaceable” Role

Category 8 also illustrates a fundamental limitation of the Colonna reform project. Faced with operational constraints and neutrality concerns at UNRWA, the Review could have examined whether greater responsibility should be transferred to other UN agencies and humanitarian organizations. Instead, Colonna expressly reaffirmed UNRWA’s “central and irreplaceable role” and framed enhanced cooperation around preserving it. Recommendation 48 called on other humanitarian organizations to “sustain and scale up support to UNRWA’s humanitarian operations in Gaza,” while emphasizing that partnerships should operate “in full respect of UNRWA’s mandate.”^{[283]Independent Review of Mechanisms and Procedures to Ensure Adherence by UNRWA to the Humanitarian Principle of Neutrality, UN (April 20, 2024), Link, archive link: Link.}

The resulting model may improve humanitarian coordination, but it assumes UNRWA should remain at the center of the system rather than asking whether its functions could be replaced by other humanitarian actors in light of its repeated neutrality failures.