Ordering, a very close relative of instigating, has generally been considered an accessorial mode of liability, particularly at the ICC (despite the contrary view of some commentators). In light of its elements, ordering could even be described as ‘aggravated instigating’. While ordering can be found in the statutes of all modern international criminal tribunals, its requisite elements have not been subject to significant controversy or focused academic scrutiny. These elements can be traced back to the moment the ICTY first turned its attention to modes of liability. It held, on the basis of numerous World War II modes of liability cases, that most modes (including ordering) require intent on the part of the accused and that the accused’s actions contribute to the relevant crime.