Kenya’s devolved system assigns counties primary responsibility for disaster preparedness, response, and climate resilience. Over the past decade, counties have established multiple financing instruments—Emergency Funds (EFs), Disaster Risk Management Funds (DRMFs), and County Climate Change Funds (CCCFs)—intended to enable early action, strengthen local autonomy, and advance locally led humanitarian leadership (LHL). 

This study examines how these instruments function in practice across four counties—Marsabit, Tana River, Garissa, and Nairobi—and whether they deliver predictable, transparent, and inclusive disaster and climate finance. The analysis finds that counties are not constrained by the absence of legal frameworks, but by weak and uneven operationalization of those frameworks. While statutory instruments exist, most funds are dormant, underfunded, or weakly governed. Mandated institutions—such as fund boards, steering committees, and ward-level planning structures—are frequently not constituted or inactive, resulting in a persistent gap between legal design and institutional practice. A central finding concerns ambiguity and inconsistency in financing rules, particularly for Emergency Funds.

The PFMA treats the EF differently from other extra-budgetary funds by positioning it as a short-term budget management tool rather than a dedicated disaster response instrument. This ambiguity—combined with discretionary allocations and limited reporting—undermines predictability and weakens the EF’s contribution to anticipatory and locally led response. By contrast, CCCFs have clearer allocation rules in law, but compliance remains uneven and difficult to verify due to weak disclosure. Transparency and accountability represent the most significant system-wide weakness. None of the counties consistently publishes comprehensive financial statements for their disaster or climate funds, despite clear PFMA and county-law requirements. Internal audit functions are largely absent from fund governance, and Auditor-General reports repeatedly flag unsupported expenditures, reporting delays, and documentation gaps. Community consultations confirm that affected populations have never seen fund reports, audits, or project lists. While county budget transparency scores do not measure fund-level compliance directly, they provide a useful governance proxy: where baseline transparency is weak, disaster and climate financing instruments are less likely to operate as intended.

In the absence of functional county-led institutions, coordination and decision-making default to external or extra-legal platforms, most notably the County Steering Group (CSG), convened by national authorities and humanitarian actors. Although effective for crisis coordination, the CSG| operates outside county fund governance structures and shifts agenda-setting power away from locally accountable institutions. This reliance on external systems constrains county leadership and reinforces perceptions that humanitarian response is donor- or NGO-driven.

Finally, participation remains largely symbolic. Although CCCF laws envision inclusive, ward level decision-making, these structures rarely influence final funding decisions. Women, youth, pastoralist groups, and other marginalized communities have limited voice beyond initial needs articulation, weakening accountability and eroding the legitimacy of locally led response. Overall, the study concludes that locally led humanitarian leadership in Kenya is constrained less by policy gaps than by failures of activation, transparency, and institutional accountability. Counties possess the building blocks of a locally led system—devolved mandates, public funds, and participatory structures—but these remain fragmented and weakly enforced. Strengthening disaster and climate finance will require clearer financing rules, routine public disclosure, functional oversight institutions, and genuine community participation. Without these, counties will continue to rely on external actors and reactive responses, limiting the transformative potential of devolution for resilience and humanitarian leadership.