Visibility as Violence: Interrogating the Audit Paradox in Sudan’s Localization Policies (2020–2026)

Localisation is increasingly promoted as a means of addressing inequities in humanitarian governance. However, in conflict-affected settings, its implementation often relies on compliance infrastructures—such as verification protocols, standardised indicators, due diligence, and third-party monitoring—that intensify demands for visibility. In Sudan, where sovereignty is fragmented, these visibility requirements can heighten exposure risks for local responders and the informal networks that enable access to contested areas. This study examines how donor policy documents construct the concepts of ‘accountability’ and 'localisation' in Sudan between 2020 and 2026 and assesses the extent to which this language may reproduce security risks for local actors. A critical discourse analysis was conducted on a public corpus of 18 documents, including UN response plans, pooled-fund operational manuals, donor guidance, Grand Bargain reporting templates, and risk-sharing and monitoring frameworks. Coding focused on lexical fields related to accountability, transparency, evidence, verification, risk, and localisation; the directionality of accountability; referents of risk; and the positioning of local actors. The analysis identified four dominant themes: (1) accountability is primarily framed as upward and audit-compatible; (2) risk is largely constructed in fiduciary and compliance terms, often sidelining protection risks; (3) low-visibility infrastructures are rendered epistemically absent when they cannot be safely made legible; and (4) localisation is affirmed rhetorically but constrained operationally by compliance requirements that reinforce hierarchy and shift risk downward. The findings suggest that in Sudan’s conflict environment, policy-driven visibility can function as a modality of harm—what might be termed ‘visibility as violence’—by amplifying surveillance, criminalisation, and targeting risks. In response, the paper outlines a protection-sensitive approach to accountability, incorporating data minimisation, aggregation, community-based verification, relational accountability, and genuine risk sharing. Such an approach offers a viable pathway for redesign that maintains fiduciary integrity while reducing harm and enabling meaningful localisation.