NCCI Bureaucratic Liaison Unit -- Year 2 A clear and practical regulatory environment is critical to principled humanitarian access and programming. NGOs working in Iraq have regularly cited access, a lack of regulatory clarity, inconsistencies in the application of regulations, frequent procedural changes, and overlapping jurisdictions as impediments, which constrain humanitarian space and create challenges that cause delays to implementation and increase operational costs.
BLU was founded in 2018 to advocate for the regulatory and operational space that allows NGOs to operate in Iraq. The unit is a leading information resource, providing relevant and updated information to members. BLU has fostered high-level relationships with relevant actors, including the central and local authorities in the GOI and KRI, the UN and the diplomatic community. Since early 2019, BLU has increasingly focused on access related issues.  
This project will extend BLU’s operations for one year. In 2019, NCCI will scale up work on access and field level constraints in close collaboration with the Access Working Group (AWG) while continuing to address the many other regulatory impediments. BLU will work with the authorities and other external actors to understand and communicate changing policies and practices to the NGO community. BLU will track, report and analyse NGO challenges and communicate concerns to government stakeholders. NCCI’s advocacy, knowledge management and coordination capacity will continue to help the NGO community maintain and expand humanitarian access.
While many impediments arise unexpectedly, in 2019, BLU will prioritise NGO-oriented solutions to bureaucratic impediments, including working closely with the central and governorate-levels government and other external actors to understand and communicate changing regulatory policies and practices to the NGO community. 
	Access: Acceptance of Access Letters in federal Iraq is inconsistent and continues to pose a challenge. Local actors, notably in Ninawa, have demonstrated a reluctance to accept letters issued by the JCMC. It is anticipated that this trend will continue with a spill-over to other governorates. BLU is working closely with the AWG and member NGOs, including relevant heads of base, to ensure a unified response. BLU’s engagement with the central government has already resulted in positive change in the Access Letter application process. NCCI’s advocacy with DNGO has brought the issue to the attention of the Secretary-General of COMSEC. BLU will increase its high-level engagement with the central and local authorities, and NGO heads of base, to find a workable solution. Blue will also submit all reported access incident to the AWG matrix.
	GoI Visas: BLU will continue to advocate for a faster and more streamlined visa issuance process including. clarity in the visa renewal process.
	Hiring quotas: Government officials, particularly in KRI, continue to pressure NGOs to comply with certain staff quotas. BLU will continue to advocate for principled humanitarian policies and regulations that are inclusive to all ethnicities.
	Work permits: MOLSA has asked NGOs to apply for work permits for their expat staff at a cost of 1000 USD per employee per year. BLU is working with the DNGO and MOLSA to obtain an exemption for expat NGO staff.
	Tax and customs: BLU will continue working with relevant government institutions on NGO compliance with tax, customs and transport regulations and to ensure the uninterrupted movement of goods and cargo from the KRI into GoI. 
	Registration: The GOI registration process is cumbersome and can take in excess of one year. In May 2019, DNGO announced that it would no longer issue temporary registrations. BLU will advocate with DNGO to reconsider its decision.
	Residency restrictions on shared office space: As a result of our engagement, Residency has temporarily suspended restrictions on NGO collocation. BLU will advocate for this to become permenant.