On December 1, 2023, the Swedish International Development Cooperation Agency (Sida) published the results of an internal review, commissioned by the Swedish government, of all ongoing funding to Palestinians (excluding funding to UNRWA, which does not fall under Sida’s purview). This funding was frozen (except for humanitarian aid) in response to the 7 October Hamas massacre in Israel. The review guidelines specified examining whether “Swedish funds go to actors that do not unconditionally condemn Hamas, that commit violence, threaten or encourage violence against the State of Israel or its population, or pursue an antisemitic agenda, nor to people associated with such actors” (emphasis added).

Regarding NGO funding, Sida’s review proclaimed that no Swedish funds went to terrorist activities through NGO projects, and that no NGO grantees were involved in incitement to hatred and violence after the 7 October 2023 events. In contrast, the reviews conducted by the EU, Switzerland, and Germany concluded that some of the same NGOs had been involved in these activities, and those governments ended funding.

Most of the criteria in the government’s request to SIDA were not addressed in the review. Revealingly, Sida admits that the government’s expectation that NGO grantees would “‘unilaterally condemn Hamas,’…would exclude cooperation with virtually all of Sida’s partners.” Indeed, NGO Monitor has documented in detail how NGOs supported by Sweden not only failed to condemn Hamas, but have actively participated in incitement and justified violence since October 7.

As detailed below, NGO Monitor’s analysis of Sida’s review points to several systematic and methodological failures to address the issues. Sida primarily relies on self-reporting of NGO grantees; only a very small number of projects were independently evaluated; and the review does not address the core question of NGO incitement to violence. Furthermore, the report fails to realistically address the probability of Swedish aid having been physically diverted to Hamas and other designated terror organizations, and, as noted, it dismisses governmental concerns over the failure of grantees to condemn the Hamas massacre.

In addition, the Sida review includes a number of misrepresentations, including regarding the restrictive measures and sanctions enacted by the EU and Switzerland following their respective reviews. Similarly, Sida does not mention several Palestinian NGOs partners, which have been accused of incitement to violence and other disqualifying activities in the past, from one of its flagship projects.

Detailed NGO Monitor Analysis

  1. Methodologically, Sida’s review is not independent:
    • The review is mainly based on NGO self-reporting.
    • It only uses external audits to assess the terror financing risk and only to review two projects.
    • The external audit did not relate to allegations of incitement to violence.


  1. Instead of investigating NGOs regarding responses to the Hamas massacre and incitement to violence, Sida ignored most of the criteria and offered apologetics

On October 10, the Swedish government suspended aid to Palestinians (excluding humanitarian aid) and instructed the Swedish International Development Cooperation Agency (Sida) to “conduct a review of aid to Palestine to ensure that no Swedish funds go to actors that do not unconditionally condemn Hamas, that commit violence, threaten or encourage violence against the State of Israel or its population, or pursue an antisemitic agenda, nor to people associated with such actors.”

In the review’s methodology section, Sida states that, if it were to strictly interpret the terms relating to “unconditionally condemn[ing]” Hamas, the review “becomes redundant.” According to Sida, “this would exclude cooperation with virtually all of Sida’s partners (including the UN, the World Bank and perhaps the EU)” (emphasis added). In other words, the review’s point of departure was maintaining funding for Palestinian NGO allies and ignoring their contributions to encouraging violence against the State of Israel or its population, antisemitism, and similar behavior.

Sida also attempts to explain why NGO grantees insist on contextualizing and relativizing the Hamas massacre. They offer a justification echoing the political agenda of many grantees, claiming that “a number of Sida’s partners are absolutely unwilling to refrain from criticizing Israel, or from pointing out the root causes of the conflict, in contexts when you distance yourself from or condemn …..crimes against the laws of war, of the kind committed by Hamas.”

As seen in the following examples of rhetoric from NGO grantees after October 7, these apologetics obscure and erase the incitement prevalent among many of Sweden’s Palestinian NGO partners:

Al-Haq (Project: Human Rights Programme Palestine 2018-2023)

  • On October 10, Al-Haq Head of the Training and Capacity Building Unit Ziad Hmaidan wroteon Facebook, “It is written in the Hadith: ‘You must wage jihad. The best jihad is preparing for war, and it is best to prepare for war in Ashkelon’.”
  • On October 10, Al-Haq Legal Researcher and Advocacy Officer Ahmed Abofoul tweeted, “It is outrageous to call on Palestinian resistance (permitted by international law) to CEASE its attacks while asking the occupying power ONLY to respect IHL.”
  • On October 12, Al-Haq Legal Researcher and Advocacy Officer Aseel Al-Bajeh tweeted, “We don’t need to speak of our right to resist, for it is not a right, but a way of being & survival for Palestinians. We don’t demand our right to narrate. Our ability to narrate was never out of our hands & resistance doesn’t need the pre- approval of static int’l law codes. Its not ‘our duty to expose the bloody barbarism of zionism, their actions as a fascist state & a ruthless army are more than sufficient to undertake this task. We remain attached to our land & in our humanity, as Pal Arabs no need to prove our humanity to those who have lost it.”
  • On October 9, Hmaidan shared a picture on Facebook of a Palestinian terrorist Ibrahim Nabulsi aiming a gun, and wrote, “A message of intense love. The picture of one of the men of the ‘flood’ [referring to the name ‘the flood of Al-Aqsa’ given by Hamas to the murderous October 7 attacks], during a confrontation in one of the [israeli] bases that was stormed [by Palestinian terrorists]. This picture carries a thousand signs and meanings. Observe the picture that the sniper of the flood stuck on his rifle. Do you recognize who is in the picture? This is the intense love is for Ibrahim [Nabulsi].”
  • On October 9, Hmaidan posted on Facebook, “To Palestine alone we give everything, until it is pleased. And for what the world wants – may it go to hell.”
  • On October 7, Al-Bajeh tweeted by quoting Hamas head Ismail Haniyeh, “Leave our land, get out of our faces.”

BADIL (Project: Human Rights Programme Palestine 2018-2023)

  • On October 9, BADIL tweeted, “Impunity and double standards are no longer acceptable! In pursuit for their liberation, the Palestinian people have an equal right to resist.”
  • On October 8, BADIL tweeted, “Nothing about the Palestinian resistance is unprovoked. The Palestinian people have been suffering for 75 years of colonial-apartheid regime, ethnic cleansing, forcible transfer/displacement…massacres on Palestinian towns, desecration of Palestinian holy sites…In seeking the inalienable rights of self-determination and return, resistance is the most human and legitimate act” (emphasis added).

Palestinian Medical Relief Society (The bilateral strategy for development)

  • According to Wattan, during a demonstration held “in support of the resistance in Gaza” on October 10, PMRS President Mustafa Barghouti stated, “These marches affirm the Palestinian people’s support in the resistance and that the Palestinian people is united wherever it is.”
  • On October 7, in an interview with Al Jazeera, Barghouti stated, “This initiative by the resistance that we have seen is a response to Israeli settlers terror that has been taking place all over the West Bank with the protection of the Israeli army. It is a response to the fact that the Israeli army and the settler terrorists killed 248 Palestinians, including 40 children. It is a reaction to the attacks on the Aqsa mosque and the process of judaization of not only Jerusalem and the Aqsa mosque but the whole of the West Bank…but maybe politically it is also a response to those who thought that through normalization with the Arab countries they can liquidate and marginalize the Palestinian issue. It is coming back in the most possible forcible way…It shows that Israel is not almighty and also it shows what Palestinians can do when they are determined to resist for their freedom…”

DCI-P (Project: Human Rights Programme Palestine 2018-2023)

  • On October 8, 2023, DCI-P Advocacy Officer Miranda Cleland tweeted, “It is beyond insulting and blatantly racist to assume Palestinians resisting Israeli colonization & trying to take back their landwill result in anti-Semitic attacks in DC. What a joke” (emphasis added). Cleland shared a statement by the Mayor of DC condemning the Hamas attacks and committing to protect the Jewish community in DC.

Independent Commission for Human Rights (The bilateral strategy for development)

  • On October 9, ICHR sent a letterto UN officials, claiming, “Since October 7, 2023, when Palestinian factions in Gaza launched the ‘Al-Aqsa Storm’ operation targeting settlements near Gaza…The root causes of Israel’s actions and crimes against Palestinians stem from its discriminatory policies based on the Apartheid. Addressing these root causes, including ending the occupation, colonial settlement, and racial segregation, while acknowledging the inalienable rights of the Palestinian people, including their right to self-determination, are imperative actions that the international community must take.”

Palestinian Centre for Human Rights (PCHR; partner of a Sweden funded project with Save the Children)

  • On October 7, 2023, PCHR Fundraising and Program Officer Feda’a Murjan posted on Facebook, “We will truly step in our land. Allah, you are our protector and supporter.”
  • During the May 2023 conflict between Israel and Palestinian Islamic Jihad (PIJ), PCHR published a statement in which it “affirms the Palestinian people to resist the occupation by all available means, including armed struggle….”
  1. Sida does not mention several Palestinian NGOs partners, which have been accused of incitement to violence and other disqualifying activities in the past, from one of its flagship projects..

Sida did not review one of its ongoing flagship programs, “Human Rights Programme Palestine 2018-2023” ($8.2 million). Implementing partners on this project include highly politicized and controversial NGOs – BADIL, Al-Haq, and DCI-P.

Note that in 2020, BADIL refused to sign a €1.7 million EU grant because of a newly introduced anti-terror requirement (1.5 bis).

In October 2021, the Israeli Ministry of Defense designated Al-Haq and DCI-P as “terror organizations,” claiming they are part of “a network of organizations” that operates “on behalf of the EU-designated Popular Front for the Liberation of Palestine (PFLP). The NGOs were accused of diverting humanitarian funds from European donors to the PFLP and with recruiting members for the terror group.

Germany and Netherlands suspended their funding to these designated organizations.

  1. Sida bases its review on a very weak EU anti-terror contractual clause that fails to address most examples of Palestinian NGO terror affiliations. 

Sida refers to its Article 16 of general terms of agreement for support to NGOs, “which stipulates that the partner must ensure that the funds are not made available, or given to the benefit of, third parties that are registered on the EU’s consolidated list of persons, groups and entities subject to financial sanctions (EU sanctions list).”

This language echoes the European Commission’s anti-terror condition in contracts with NGOs (1.5 bis of ANNEX II “General conditions applicable to European Union-financed grant contracts for external actions”) introduced in all EU NGO contracts around the world in 2019.

This clause is largely inapplicable in the Palestinian context since it only references the persons, groups and entities subject to the EU list of restrictive measures (terror list) – which includes Palestinian entities like Hamas, Islamic Jihad, and PFLP – but does not include any persons or organizations affiliated with them.

An EU review published in November 2023 reveals that Palestinian NGOs involved in 11 projects totaling €14.3 million refused to sign this anti-terror requirement (1.5 bis).

It is not clear from Sida’s review if Article 16 was applicable in the Swedish contracts signed by NGOs that refused to sign the EU contracts.

  1. Sida misrepresents the restrictive measures and sanctions enacted by the EU and Switzerland following their respective reviews

The EU, Germany, Switzerland, Finland, Denmark, and Austria launched internal reviews of their Palestinian portfolios following the October 7 Hamas massacre. At the time that Sweden published its review, the EU and Switzerland had released their findings, and media reported on German sanctions of NGOs.

  • European Union

In its review, Sida states that “the EU has completed its review without prompting any review of ongoing operations (however, two small organizations are subject to further investigation). No payouts have been suspended during the EU review process.”

This is inaccurate: The EU review clearly states, “beneficiaries subject of allegations of incitement to hatred and violence after the 7 October 2023 events were requested to comment on the allegations brought against them. This concerns notably two projects with Civil Society Organisations. Payments will be processed once satisfactory clarifications have been provided, in line with the Financial Regulation.” The Irish Times reported that these two NGOs of concern have been awarded EU grants worth €8 million” (emphasis added).

Sida omits that one of the main conclusions of the EU review is that the European Commission will introduce a new anti-incitement requirement in its contracts with NGOs.

  • Germany

Sida’s review states that “Germany has completed its review of humanitarian aid and of UNRWA without prompting any review of ongoing activities. The review of other development cooperation has not yet been completed.”

German government has not yet made its review public. However on November 22, 2023, Deutsche Welle (DW) reported that a Palestinian NGO, Al-Haq, “will no longer receive funds from the German Ministry for Economic Cooperation and Development.” According to DW, “a spokesperson for the ministry recently said that organizations that supported armed resistance to Israel were not appropriate partners” (emphasis added).

Al Haq is longstanding Sida partner.

  • Switzerland

Sida states that Switzerland “paused support for 11 organizations during their review. They have since resumed support for eight of them as no irregularities have been found. In two cases, they do not intend to renew the collaboration after the agreement period expires in December. In one case, cooperation has been suspended (an organization that does not have Sida funding).”

This is inaccurate: the Swiss Federal Department of Foreign Affairs (FDFA)  states: “For three [out of 11 NGO grantees] instances of non-compliance [with the FDFA’s code of conduct and the anti-discrimination clause] were identified, leading to the termination of their contracts” (emphasis added).

One of the three NGOs, PCHR, is currently funded by Sweden, as part of a project with Save the Children.