WASHINGTON, DC, April 21, 2025 — On April 3, responding to intense sustained advocacy efforts by project-affected communities and civil society organizations, the respective Boards of the International Finance Corporation (IFC) and the Multilateral Investment Guarantee Agency (MIGA), the private sector arms of the World Bank Group, approved their long-awaited Interim Remedial Action Framework (RAF) which has now been published. The framework, along with the Approach to Responsible Exit, encapsulates the first policy from the World Bank Group to outline how the institution will deliver remedy to communities harmed by the projects it finances.
We applaud IFC/MIGA for advancing this framework, which contains promising commitments that, if well implemented, could address a troubling history of IFC/MIGA allowing environmental damage and human rights abuses to go unremedied. This has undermined its sustainable development mandate and has damaged communities’ livelihoods. As communities affected by the projects financed by IFC/MIGA and by other development finance institutions still await remedy from harm, this new policy can finally respond to their calls for accountability and remedy in ways that have not been available to them before.
Most notably the Remedial Action Framework sets forth:
- IFC/MIGA’s recognition that it has a role to play in contributing to remedial action when projects result in environmental and social harm.
- IFC/MIGA’s commitment to fund “enabling activities,” including fact-finding, technical assistance, capacity building, and community development programs. IFC/MIGA commits to developing any such programs in consultation with affected communities. Importantly, IFC/MIGA may consider other options for remedial action, which could include direct funding.
- A commitment to implement and monitor the RAF in consultation with IFC/MIGA’s independent accountability mechanism, the Compliance Advisor Ombudsman, and a commitment to regularly engage with various stakeholders during the interim implementation period.
- A commitment to focus on capacity-building for low-capacity clients, especially in poorer and fragile and conflict affected states, to strengthen their ability to mitigate harm and deliver remedy.
However, the framework still falls short of key demands from project-affected communities. Despite acknowledging that remedy often requires funding, the RAF does not explicitly commit IFC/MIGA to financially contribute, even in cases where the CAO has found IFC/MIGA non-compliant. Further, the RAF does not include a systematic funding mechanism or client-side funding requirement. Additionally, while the RAF also acknowledges financial intermediary sub-projects it provides no specific guidance on applying remedial principles to these investments, even though over half of IFC’s investments are in financial intermediaries.
Likewise, the RAF does not draw a connection with the IFC/MIGA’s Responsible Exit Approach and Principles. These policies go hand-in-hand, thus, a reference to the Principles in the RAF would solidify this interdependence. Notably, since the RAF only applies to current and future projects that could be found eligible for CAO complaint, communities that are still awaiting remedy from closed out/concluded projects still have no recourse. Without a commitment to remedy legacy harms from projects that have concluded, often due to IFC/MIGA’s irresponsible exit or client pre-payment, that RAF fails to provide holistic access to remedy for all communities.
Yet, the approval of the RAF itself is an important step toward shifting the problematic culture within the IFC/MIGA that has left communities to bear the largest risks from development projects. We applaud the IFC and MIGA Boards’ decision and recognize the IFC/MIGA’s leadership in developing a remedial action framework that other development finance institutions can replicate and build on.
This interim framework will be implemented over the next three years, and the implementation of this framework will prove if the IFC/MIGA is truly committed to ensuring that impacts that harm communities and exacerbate poverty are fully remedied. The framework should be implemented transparently, and IFC/MIGA should engage with affected communities and civil society organizations to ensure that it is meeting its mark. The final framework should address any shortcomings identified through implementation. We look forward to working with IFC/MIGA to ensure that this framework is impactful.
Endorsing Organizations:
- Center for International Environmental Law, CIEL
- Jamaa Resource Initiatives, Kenya
- Gender Action
- Arab Watch Coalition
- Urgewald
- Recourse
- Accountability Counsel
- Green Advocates International, Liberia
- Bank Information Center
- International Rivers
- Interamerican Association for Environmental Defense, AIDA
- Inclusive Development International, IDI
Media Contact
Alexandra Colon-Amil, Communications Campaign Specialist, CIEL: [email protected]