Transparency Concerns Surrounding the Somaliland Development Fund (SDF)

For more than a decade, the Somaliland Development Fund (SDF) has been one of the primary vehicles through which international donors including the United Kingdom, Denmark, Norway, and the Netherlands have financed infrastructure and development projects in Somaliland. Established in 2012 as a multi-donor pooled fund, the SDF was designed to strengthen public financial management and support development priorities aligned with Somaliland’s National Development Plan. Roads, water systems, agriculture, and institutional capacity building have been funded under its framework. SSC regions and Somaliland Development Fund allocations since 2012 Public records do not support the literal claim that the SSC areas have had “no” Somaliland Development Fund (SDF) support since 2012. Primary SDF and Government of Somaliland documentation shows that Sool and Sanaag were explicitly included in SDF Phase 1 through (at minimum) “Education in Sool & Sanaag” and “Health in Sool & Sanaag,” alongside a water resources package that included eastern locations. especially in the years after 2018. That said, an evidence-based reading of the portfolio does explain why Sool (and, in SSC framing, “Cayn”) can still appear to have received little or no SDF funding in practice, especially in the years after 2018: Yet a growing number of citizens and civil society observers are asking a fundamental question: Where is the transparency, and who is holding the Fund accountable? A Fund Operating in a Fragile Governance Context Somaliland operates without international recognition, meaning donor support is channelled through special arrangements. While this provides flexibility, it also raises oversight challenges. Unlike internationally recognised states with strong parliamentary scrutiny and fully independent anti-corruption agencies, Somaliland’s institutional accountability mechanisms remain limited in capacity and independence. Although oversight manuals and donor steering committees exist on paper, public access to detailed regional expenditure data remains minimal. The result is a perception gap: Communities see projects concentrated in certain regions while others particularly conflict-affected or politically sensitive areas report limited investment. Without transparent, disaggregated spending data, those perceptions cannot be objectively confirmed or refuted. The Core Concerns The issue is not necessarily proven criminal corruption. Rather, it involves three interlinked accountability concerns:

• Lack of Publicly Available Regional Breakdown

There is no easily accessible, comprehensive public dataset showing: Total SDF allocations by region (since 2012)

• Per capita distribution
• Criteria used to prioritise projects
• Independent evaluation reports by geographic impact

When public funds particularly UK taxpayer funds are involved, such transparency should be standard practice. 2 – Oversight Structures Are Opaque to the Public The SDF is governed by a Joint Steering Committee made up of donors and Somaliland officials. However:

• Meeting minutes are not systematically published.
• Audit findings are not widely accessible.
• Complaint mechanisms are unclear to ordinary citizens.

This opacity fuels distrust, even if no wrongdoing has occurred. 3-Political Sensitivities and Exclusion Risks In fragile or disputed territories, development funds can unintentionally reinforce political power dynamics. If allocation criteria are not transparently applied, funds may:

• Appear politically motivated
• Deepen regional grievances
• Undermine conflict-sensitive development principles

International donors are bound by “Do No Harm” and “Leave No One Behind” commitments. Transparent allocation data is essential to demonstrate compliance with these principle.  Donor Responsibility The United Kingdom (via FCDO), Denmark, Norway, and the Netherlands are not passive funders. They sit on the Steering Committee and have oversight responsibilities. If funds are:

• Unevenly distributed,
• Poorly monitored,
• Or lacking public accountability mechanisms,

Then donor governments share responsibility for ensuring corrective action. The issue is therefore not simply domestic governance it is also about international aid governance standards. By Osman Ahmed