Recent cases before the ICC raise the question of on behalf of which entities crimes against humanity can be committed. Interpreting the ‘organizational policy’ requirement in its context, this article argues that in principle crimes against humanity can be committed pursuant to or in furtherance of a policy of any organization that has the capacity to orchestrate a widespread or systematic attack against a civilian population. It is shown that this does not broaden the scope of the crime indefinitely but that concrete requirements defining such entities are found in the contextual elements of crimes against humanity.