An Agenda for a Dignified and Sustainable Rohingya Refugee Response in Bangladesh partners, the lines of accountability remain unclear, as no single entity can be held entirely responsible for any potential failures.227 As per the findings from a Disaster Emergency Committee (DEC) Review of the Response (2018)- 228 The lack of a refugee response framework or strategy, focusing on the rights of refugees, from the start has had an impact on the quality of the response. Humanitarian action cannot be focused exclusively on the delivery of services. It must be provided with a Protection mind-set from the outset. In addition, organisations must also analyse the coordination framework in which they are working. The UN – particularly UNHCR and IOM – could have worked with the government to ensure clarity on the coordination model…. The mixture between the two models has created greater confusion. The Review Team feels that too few NGOs have a clear understanding of the models behind the UN’s humanitarian coordination – or the legal mandate of UNHCR (in comparison to IOM). 4.2.1 Inter-agency coordination and its limits 4.2.1.1 United Nations led coordination structure In terms of camp-level coordination, half the refugee population living in the camps is managed by IOM while the other half is managed by UNHCR based on a geographic division of responsibility or areas of operation (AOR). Such division of labour at the camp level has created service delivery gaps across camps and highlighted the need for harmonisation of camp management and stronger intersectoral coordination.229 The ISCG established prior to August 2017 was initially led by IOM and resembles the cluster approach that is in place globally for internal displacement (IDP) settings. Following the influx in August 2017, the United Nations Office for the Coordination of Humanitarian Affairs (OCHA) deployed a Coordinator reporting to IOM and to the UN Resident Coordinator. Since January 2018, following the formation of SEG, the ISCG Senior Coordinator was seconded from UNHCR and the ISCG Secretariat was comprised of staff and thematic experts from different UN agencies. The sectors were led by UN agencies, with NGO co-lead roles in some sectors (education, WASH, Shelter/NFI, Site Management). Traditionally, UNHCR is the lead agency for refugee responses around the world. However, in the context of the Rohingya refugee response in Bangladesh, a silo-ed cluster/sectoral approach is adopted that has impacted integrated humanitarian coordination.230 The hybrid coordination structure described earlier has continued to adjust itself to the evolving protection and operational environment in Bangladesh. However, the continued reluctance of the Government of Bangladesh in recognising Rohingya as refugees and the absence of a clear and predictable operational framework in the response runs the risk of diluting responsibility and accountability principles and limits the scope of achieving refugee rights and protection.231 4.2.1.2 Complexity of NGO Coordination More than 130 Bangladeshi (national and local) and international NGOs are supporting Rohingya refugees and host communities in Cox’s Bazar. Many of them are part of the formal humanitarian 227 DEC, UK AID, Here Geneva, Responding to the needs of refugees and host communities: Review of the DEC Phase 1 responses, March 2018, p.29, available at https://www.dec.org.uk/sites/default/files/PDFS/dec_rohingya_crisis_appeal_response_review_report270318.pdf 228 Ibid, p. 33 229 Sida and Schenkenberg, supra n. 152, p. 16 230 DEC Review, supra n.228, p. 28 231 Sida et.al, supra n. 57, pp. 8-9 Act for Peace / May 2021 51