On March 1, 2023, Mali submitted a letter to the Security Council president rejecting France as penholder on all issues concerning Mali, claiming France was responsible for “acts of aggression, violation of our airspace, subversion and destabilization.” Though Mali’s demand for a new penholder has not found support among the Council, this incident calls for a renewed look at the penholder system and may present an opportunity to promote greater inclusivity and unity in how the Council produces outcomes, particularly when it comes to context-specific matters.

Penholder diversification has become a noted topic of discussion in recent months, raised by the Security Council’s ten elected members (E10) in a joint statement at the 2022 Open Debate on Working Methods of the Security Council, and by Russia through the subsequent organization of an Arria-formula meeting on penholdership. While, for a number of reasons, a full overhaul of the penholder system would not be practical or appropriate, increased sharing of the pen could support a more united and representative Council in the near term. A more inclusive approach could help build the foundation for broader reform of Council membership while also addressing concerns voiced by elected members, as well as several peacekeeping host states.
Holding the Pen

When a Security Council member holds the pen on an agenda item, they have the benefit of shaping and leading related Council action. Although any member of the Council may hold the pen—a point emphasized in Presidential Note 507—France, the United Kingdom, and the United States (the P3) have played a dominant role in drafting Council outcomes since the emergence of this informal practice in 2003.

Today, P3 members independently hold the pen on 22 out of 33 country-specific files (including 11 out of 12 peacekeeping contexts);[1] share the pen on an additional four country files; and lead on seven out of 12 Council thematic matters. Given their permanent status on the Council, they can hold the pen on an agenda item as long as they wish and also move to take the lead on new files when the two-year terms of elected members expire. This has caused some to characterize the P3 as maintaining a “de facto monopoly” on Council outcomes, unduly limiting the influence of elected members. Those in favor of continuous penholding reference the need for Council efficiency and continuity, particularly as country-specific outcomes (e.g., resolutions on peacekeeping and sanctions) have become more detailed, technical, and lengthy.

The current penholder arrangement came into use to minimize competition among the P3 to be the first to circulate their drafted resolutions. However, the consequence of such divvying up is that the P3 not only draft and introduce outcome documents on the majority of country matters, but they are also empowered to organize relevant meetings and debates, speak first in those meetings, and chair negotiations. In terms of consulting on draft outcomes, the self-designated P3 member usually prepares a full “zero” draft before informally circulating it first among the P3 and close allies, then to Russia and China, and lastly to the full Council. Negotiation periods tend to be relatively short (e.g., a few weeks), which can allow elected members insufficient time to consider and propose adjustments by the time the draft text reaches them, or render the penholder less open to new ideas if P5 agreement has already been achieved.

Any proposed alternatives to this arrangement should take into account that while Council members may enjoy the potential influence that comes with holding the pen, becoming a penholder is also a matter of capacity, both in New York and back in capital. Taking up the pen on a country file requires strong political motivation and operational capacity, the latter of which poses more of a challenge for elected members. On the political side, penholding necessitates substantive expertise, aided by a history of diplomatic engagement and regional connection. Operationally, expert staff capacity and efficient communication between the mission in New York and the capital are vital for drafting texts and managing negotiations, as well as for facilitating Council consultations with country stakeholders, such as through mission visits. In a 2021 workshop for incoming Security Council members, it was recommended that elected states have 10-11 experts dedicated solely to Council matters.

Additionally, it can be hard for new members to identify an unclaimed issue where they hold a comparative advantage, as most Council files already have acknowledged penholders.[2] Elected members cannot be expected to maintain comparable institutional knowledge of Council action or procedures, given their brief and intermittent Council tenures. Given these challenges, elected members tend to focus their energies on thematic issues, which do not necessarily require the same level of continuity or historical knowledge. The Council has partially addressed this continuity gap by “passing the baton” on specific country files (e.g., Afghanistan, Ethiopia, Guinea-Bissau, West Africa, and humanitarian issues in Syria) and thematic files (e.g., children and armed conflict, the International Residual Mechanism for Criminal Tribunals, non-proliferation of weapons of mass destruction, and working methods) from departing to incoming E10 members.

Sharing the Pen

Sharing the pen between two Council members has become more common over the last decade, with elected members serving as co-penholders on six country files in 2023, following a notable uptake of the practice from 2018 onwards. This practice is a game changer for Council members with less political heft, experience, or capacity within their permanent mission, as it allows for burden sharing and drawing on each member’s respective comparative advantages. Today, seven out of ten elected members serve as (co-)penholders on country files.

*Ukraine’s political and humanitarian situation counted as two separate files. Click to enlarge.

To ensure co-penholding indeed adds value, each relationship should provide a clear political advantage. Otherwise, the additional coordination and time required for frequent sign-offs from two or more capitals may not be easily justifiable. Further, co-penholders should be able to agree to a general set of objectives and priorities for each proposed outcome, ensuring a smooth and efficient process. In the case of Estonia and Norway sharing the pen on Afghanistan in 2021-2022, both states viewed protection and promotion of human rights and women’s rights as aims for their Security Council tenure, so calling out human rights abuses and mistreatment of women in Afghanistan became a common priority.

As each Council member—whether P5 or E10—brings different political and functional capacities, every jointly held file will likely result in a distinct burden-sharing arrangement. It is likely that one penholder may emerge with more comparative strengths and thus take the lead role. Alternatively, co-penholders could divide responsibility for longer outcome documents by section, limiting the extra layer of coordination required by sharing the pen. This option could allow for more equal burden-sharing, in which case it may make sense for Council states with comparable or complementary capacities to join forces. A prime example of this is when the United Kingdom and Germany jointly managed the Libya and Sudan files from 2019 to 2020, while Germany served as chair of the two relevant sanctions committees.

Despite the increased bureaucratic challenge, co-leading on files does have potential benefits. Permanent members may benefit from the fresh energy, perspective, and diplomatic relationships an elected member could bring. Further, P3 credibility may be improved by sharing the pen with a member from the relevant region or the chair of the corresponding subsidiary body.

In turn, elected members could gain further international visibility and recognition from co-penholding. Those from a region affected by the issue at hand may have a vested interest in shaping outcomes that mitigate the consequences of conflict and insecurity on regional and national affairs. And Council members who are particularly invested in a file but do not hold the pen could nevertheless show their support through co-sponsorship of outcomes, a practice widely used in the General Assembly.

Toward a More Inclusive and Effective Council

Greater sharing of the pen within the Council could also help mend perceptions of partiality and facilitate more inclusive working methods, thereby supporting more effective multilateralism. In recent years, elected African members (collectively referred to as the A3) have expressed interest in shaping outcomes for African contexts. In the words of Gabon, “we [the A3] would like to hold the pen to ensure the destiny of our peoples.” At present, both France and the United Kingdom lead Council action on their former colonies (e.g., France holds the pen on the Central African Republic and Mali, while the United Kingdom leads on Cyprus and Sudan). Having another penholder on these files may allow for enhanced consultation with host country and regional actors (including the African Union and regional economic communities) and help balance claims that penholder action is biased or unilateral in nature.

As in the case of Mali, several peacekeeping host states have become increasingly critical of penholder arrangements and practices, even to the point of overt opposition—emboldened in part by China and Russia’s backing in Council meetings and rising abstention rates on Council products. For example, the Central African Republic proposed last year that either an A3 member or the host state itself should hold the pen on MINUSCA’s mandate (the latter of which runs counter to Council practices and would violate the peacekeeping principle of impartiality). More recently, the representative of South Sudan called for the United States to adopt a more collaborative approach as penholder on UNMISS and consider proposals made by other Council members going forward.

As potential co-penholders on African files, A3 Council members are likely to have the greatest positive impact where they already play a regional role, provided they can serve as impartial moderators. Ghana, for instance, may be well placed to inform the mandate renewal for the peacekeeping mission in Mali, as well as on outcomes for the Sahel. In contrast, while Gabon’s geographic placement could make it well suited to contribute to files on Central Africa, its abstention on MINUSCA’s 2022 mandate renewal raises concerns about whether it would help calm tensions or impede necessary Council action.

Ultimately, renewed debate around who holds the pen in the Security Council calls for further examination of this informal system. In the near term, increased sharing of the pen could allow for more balanced representation and greater Council unity on country matters, particularly in the absence of more comprehensive reform. Going forward, it will be up to elected members to assert their desire to serve as co-penholders and, in turn, for France, the United Kingdom, and the United States to be open to the idea of such arrangements. Continued exchange within the Informal Working Group on Documentation and Other Procedural Questions will be key for motivating the realization of a more “representative, inclusive, transparent, effective and accountable” Council.

[1] The UN Disengagement Observer Force (UNDOF) in Golan Heights serves as the exception, with Russia and the United States sharing the pen on the file.

[2] Files without clear penholders at present include Ethiopia; Guinea-Bissau; peace and security in Africa; and climate change and security.

[3] Data collected from Security Council Report’s annual chart on “Chair of Subsidiary Bodies and Penholders.”

[4] Data collected from Security Council Report’s annual chart on “Chair of Subsidiary Bodies and Penholders.”

Julie Gregory is a Research Analyst at the Stimson Center.