As the international security environment grows more volatile and major militaries shift focus from counterinsurgency and counterterrorism to large-scale combat, critical lessons on reducing and addressing civilian harm from their own operations risk being shelved at the very moment they are needed most.
That is a dangerous miscalculation. As evidenced across Ukraine, Gaza, Yemen, and Sudan, high-intensity conflicts relying on explosive weapons increase both the likelihood and scale of civilian harm, particularly when they take place in populated areas, as they are likely to do in a large-scale modern war. The impetus in the face of such conflict should be for stronger, rather than weaker, civilian protection systems.
It is a hard-earned lesson of the last two decades that effective mitigation – and a proactive response, when things go wrong – is not just a legal and moral obligation, but also essential to mission success. In conflicts such as Afghanistan and Iraq, efforts to minimize, track, and respond to civilian harm – collectively often referred to as Civilian Harm Mitigation and Response or CHMR – improved targeting, built legitimacy, and strengthened force protection.
Civil society has a critical role to play in monitoring trends and regressions, and in shining a light on both civilian protection failures and solutions. The Civilian Protection Monitor (CPM) is a new tool, co-developed by our organizations, Airwars and PAX, to support this role. It offers independent tracking of national protection policies and practices, providing a roadmap for reform, and placing each state on a scale from “regressive” to “uncommitted,” “engaged,” “emerging leader,” and “leader.” Its findings show that, among the United States, the United Kingdom, and the Netherlands – three countries active in recent counterinsurgency wars and with extensive public focus on CHMR – none are ready for the civilian-protection challenges to come with large-scale conflict.
The United States: Backsliding on Ambitious Reforms
The United States military has made some of the most significant strides to reform its approach to civilian protection from its own military in recent years, driven in part by catastrophic failures in past conflicts. The 2022 Civilian Harm Mitigation and Response Action Plan (CHMR-AP) and the 2023 DoD Instruction 3000.17 (DoD-I) set out a comprehensive CHMR framework, establishing procedures for everything from the pro-active monitoring and investigation of possible U.S.-caused civilian harm, to procedures for providing post-harm amends. As part of these reforms, the United States also created a Civilian Protection Center of Excellence (CP-COE), alongside new training programs, and it has had a $3 million annual fund in place for ex gratia, or condolence, payments to civilians harmed by U.S. operations. As a result of these mechanisms, and others that precede it, the United States scored “Emerging Leader” in the 2024 CPM country report.
Yet even prior to President Donald Trump taking office earlier this year, these advances were not without shortcomings. In spite of the $3 million annual fund set up by the 2020 National Defense Authorization Act, the United States rarely disbursed ex gratia payments, applying questionable criteria regarding which victims are considered “friendly” to the United States and thus eligible for financial support. Conditional language in the new civilian protection policies and plans also at times fell short of commitments that can be checked and monitored independently.
With the beginning of Trump’s second term as president this year, the pressure on existing and emerging initiatives has grown exponentially. Secretary of Defense Pete Hegseth has taken an offensive posture, emphasizing the need for U.S. soldiers to be able to act without restraints to focus on “lethality,” overlooking hard-earned lessons about the strategic and operational value of civilian harm mitigation, and even going so far as to suggest that the United States should ignore the international laws governing military conduct.
Part of the administration’s widespread cuts across the U.S. government have included significant reductions in the CP-COE. The future of this office — and other staff focused on mitigating harm to civilians in the Department of Defense regional commands — now hang in the balance, as their budget for the forthcoming financial year remains undecided and at risk. Such cuts have been met with resistance by veterans’ organizations; military leaders and others have also emphasized the critical importance of mitigating harm to civilians and responding when harm occurs. Leading members of the Department of Defense have testified to the importance of the CHMR staffing and approach in statements to Congress. With Hegseth yet to confirm the future of these CHMR programs, these developments exacerbate concerns about whether the United States is able and willing to apply hard-earned lessons about the importance of CHMR capabilities to large-scale wars.
The most recent U.S. operations do nothing to dispel these concerns: in Yemen alone, airstrikes conducted over 52 days of this Trump administration killed 283 people, including 31 children – nearly as many as the previous 23 years of military action in Yemen. This regression is also echoed in the administration’s continuation of military support for Israel, which continues to inflict extraordinary levels of civilian harm in Gaza.
Beyond the destruction this brings to civilians caught in wars, it also creates strategic setbacks for the United States by fostering grievances that strengthen anti-U.S. sentiment and increase the recruitment potential of various non-State armed groups. A lack of dedicated and trustworthy civilian-harm tracking and reporting mechanisms allows adversaries free rein to push disinformation and undermine people’s trust in the U.S. government and military.
The Netherlands: A Thought Leader Not Yet Built for Scale
In the Netherlands, the pendulum appears to be swinging in a more productive direction. While it so far lacks the comprehensiveness that characterize recent U.S. policies and procedures, political leadership continues to display a strong public commitment to civilian protection. From 2019 onwards, the Dutch Ministry of Defense has taken concrete steps to institutionalize some important CHMR aspects in the wake of two highly publicized Dutch civilian casualty events in Iraq, which killed at least 89 civilians, during the U.S.-led coalition’s operations against ISIS.
Most notably, the Netherlands has created progressive policies on transparency and, in 2024, established a centralized civilian harm reporting portal. This platform enables civil society organizations (CSOs) and affected civilians to directly report harm potentially caused by Dutch forces. It represents an important acknowledgement that civilian protection is a responsibility requiring not only internal oversight but external accessibility and accountability. These developments meant the Netherlands scored “Engaged” in the 2024 CPM country report.
In March this year, the Dutch MoD also proactively published the results of a year-long engagement with one of our organizations, Airwars, to assess 61 cases of possible civilian harm caused during Operation Inherent Resolve to determine whether the Netherlands could be linked to any of these cases. The MoD displays an openness to proactive engagement with CSOs that is rare for militaries. Dutch policy now further requires that the government proactively informs Parliament prior to military deployments about the anticipated risks to civilians and planned mitigation measures.
The catch is that the above measures are largely limited to so-called Article 100 missions, which primarily cover stabilization and peacekeeping operations. Most policies likely would not apply to an armed Dutch deployment in the context of a scenario in which the country were participating in collective defense under NATO’s Article 5 in the event of an attack on an ally. The Dutch approach to CHMR is highly dependent on the operational context and often provisional in implementation, particularly when working through coalitions. Combined, this makes the Netherlands ill-prepared for ensuring civilian protection in large-scale wars.
The Netherlands should embed CHMR mechanisms across all branches of the armed forces and expand them beyond the narrow scope of Article 100 operations. Otherwise, it risks losing the very leadership it has worked so hard to establish.
The U.K.: A Policy Foundation with Limited Follow-Through
While the U.K. has articulated certain policy commitments to civilian protection, its current approach reveals significant gaps in implementation and institutionalization. Despite early innovations during the Iraq and Afghanistan wars, including compensation programs and detailed airstrike transparency under Operation Inherent Resolve, the U.K. has regressed, apparently shutting down or restricting access to all of its CHMR tools, from civilian harm tracking to response mechanisms. There is no formal process for acknowledging harm or offering payments to those affected.
Furthermore, recent legislative changes have effectively blocked civilians’ access to legal remedies. Even existing policy documents largely focus on mitigating harm by others rather than addressing the consequences of U.K. operations. Reflecting this, the U.K. scored “Uncommitted” in the 2024 CPM country report.
The U.K.’s policy documents on human security, a concept that is perceived to encompass civilian harm mitigation in U.K., contains strong language on the comprehensive impact of conflict on civilians and the unique vulnerabilities of different demographic groups in conflict zones. But this is almost exclusively focused on the role of U.K. forces when they act as peacekeepers protecting civilians from the actions of adversaries, and there is little evidence that the U.K. has embedded CHMR practices into operational planning or that it systematically monitors the impact of its operations on civilians.
This disconnect between stated values and actual systems represents not just a missed opportunity, but an ethical and strategic liability. As the U.K. continues to participate in airstrikes that are alleged to cause civilian harm, such as its recent participation in a particularly deadly campaign in Yemen, the absence of a coherent CHMR strategy raises serious questions about its ability to meet the standards it espouses. It is also notable that the U.K.’s strategy on the future of its defense, focused largely on the possibility of a large-scale conflict, does not once mention the possibility of civilian harm from U.K. actions or the need to mitigate such harm.
Dangerous Amnesia
Political and military leaders increasingly beat the drum for large-scale war preparations, with steep increases in military investments and spending seen across NATO. It is deeply concerning to see the lack of attention for civilian protection amidst these preparations – and even, at times, to witness the active discarding of protection practices by countries like the United States.
Civilian harm will not be less frequent in large-scale wars. On the contrary, their scale and lethality make harm more likely and potentially more devastating. Disinformation will thrive in large-scale conflicts, and militaries that fail to acknowledge harm will see their credibility deteriorate rapidly. Civilian casualties met with impunity erode mission legitimacy, fuel adversary propaganda, complicate coalition dynamics, and can contribute to moral injury among service personnel. The only way to mitigate this is to build systems that are not only robust but scalable, consistent, and transparent.
Large-scale combat will not only test the material capabilities of States, it will also test the moral character of belligerents and the kind of international order they seek to uphold or reshape. In such conflicts, protecting civilians where possible, acknowledging harm when it occurs, and taking ownership of the narrative will be critical to preserving legitimacy and shaping global perceptions. These are not peripheral tasks but core strategic functions, and they will be the true determinants of a military’s and country’s strength and endurance. At present, none of the three major military powers monitored thus far for the CPM are prepared to meet this challenge in a systematic or credible way.
This is the moment to institutionalize, not forget, the best practices of the last two decades. The question is not whether CHMR matters in large-scale combat. It is whether governments will choose to act on what they already know or consign those hard-earned lessons to history.
