A mirror and a map for the next generation of Accountability Mechanisms

The Promise of IAMs

The first independent accountability mechanism (IAM) was created 30 years ago out of a need to provide access to justice for communities harmed by bank-financed development projects.  Since then, IAMs have proliferated, but until now, there has not been a systematic study evaluating how well IAMs are meeting the purpose for which they were built.  Accountability Counsel’s new report fills this gap.

Through a mixed-methods approach combining analysis of all 2,270 complaints filed to 16 IAMs through 2022 with 45 in-depth interviews across 25 complaints globally, we identified both the promises and challenges faced by communities in holding Banks and their clients accountable when development goes wrong. 

One of the most positive stories we heard came from Nicaragua, from a group of sugarcane workers who filed a complaint to the CAO, the IAM for the International Finance Corporation (IFC), for rampant illnesses and deaths believed to be caused by one of IFC’s client’s, Navinic Montelimar’s, extractive labor practices and harmful pesticide use.  Upon reflecting on their use of the IAM process, the community shared: 

“We’ve seen a big change. We didn’t think we were going to sit at the table with the company, and that’s a change.  Actually getting results, that’s new too. [...] We’ve achieved things that are unimaginable, but we need more progress because some agreements haven’t been implemented. But, now we have a good relationship with [the Company], and we sit at a dialogue table every two months.”  

With facilitation from the CAO, the community managed to win health support programs for workers, support for a microenterprise hiring workers and family members impacted by the sugar mill’s practices, a joint committee to process complaints from other workers, research and training to to reduce risk of occupational diseases or accidents, improved labor practices, and improved health and safety practices around agrochemical exposure, among other concessions.  

Did they feel that they achieved justice for all the harms suffered?  No.  They couldn’t get the company to stop aerial fumigation, which still pollutes their environment, some of the agreements for livelihood restoration are still far behind, and water monitoring is not transparent or responsive.  And yet, there is a recognition and a pride in having achieved a significant degree of justice that had initially seemed impossible to them, and most importantly, having won a seat at the table where they continue to have a voice in improving the company’s practices.

While the experience of this sugarcane worker collective reveals the promise of these IAM processes, our research reveals how stunningly rare this result is.  Our research shows that only 15 % of the 2,270 complaints filed to IAMs since 1994 resulted in any identifiable commitment, and just 10 % saw those commitments fully completed. In other words, for every ten grievances lodged, only one ends with a concrete remedy. Below, we lay out the key findings of our research and the path forward that must be forged if development banks are to achieve their goal of providing meaningful remedy when harm occurs.

Key Findings

1️⃣ Accountability mechanisms can produce creative, meaningful remedies, and are sometimes the only avenue for justice available to communities.

Our research codified and tracked 1,758 commitments made by development banks or their clients ranging from cash compensation and land restitution to policy reforms and infrastructure upgrades. These commitments were found in negotiated agreements or management action plans following an investigation into non-compliance by a bank facilitated by accountability mechanisms.

The chart below shows the categories of commitments that were confirmed implemented. In some cases, communities secured transformative outcomes such as stopping the expansion of an airport that would have forcibly displaced locals from their homes and businesses, getting support for microenterprises as a form of livelihood restoration, and receiving cash compensation or replacement land, to name a few.

This diversity of commitments, from apologies to land restitution, from project-level grievance mechanisms to microfinance programs, speaks to the unique role IAMs play in shaping remedy that is often unattainable through courts or administrative complaint channels.

Most interviewees said that even though harm from projects was not fully remediated, they would nevertheless make the same choice to engage in an IAM process. This suggests a dearth of alternatives but also the unique importance these mechanisms play in community struggles for accountability.

Table 1. Categories of Completed Commitments

2️⃣ Despite important successes, the scope of remedy is dwarfed by the scale of harm.

Only 46 % of eligible complaints generated any commitment, and among those, 31 % reported completion of any commitment. Even when commitments to remedy harm are made, they often address a fraction of the damage.

For example, in an interview with an indigenous Maasai community in Kenya displaced by the Olkaria Geothermal Project financed by the World Bank and European Investment Bank, community members reported that after being resettled for the project more than 10 years ago, they are still waiting for promised benefits and compensation. 

One community member explained:

“It was a shock for us to go there, imagining we would have houses, only to find out there were no houses. So we went into the forest and just settled there. We live in horrible conditions. The new buildings are made out of paper, when the rain comes, it wipes us away and we have to build new structures. We don’t have work to do. We barely have food.”

3️⃣ Implementation bottlenecks lead to inadequate outcomes.

“There was a step-by-step Action Plan in the report. It was never implemented. We did not take it seriously, it was only paper not being implemented to action.” - Affected community member of Power Development Project in Nepal, funded by the World Bank

Both the data and interviews suggest that even when robust commitments are made, they are often inadequately and unevenly implemented. About 6 % of all commitments are cancelled outright, and another 12 % stall before monitoring concludes. Our research identified the following issues: a lack of monitoring and communication with affected communities, cancellation and non-implementation of commitments, significant delays, and unfair distribution of benefits from land and resettlement agreements.

Table 2. Complaints with Incomplete or Cancelled Commitments

4️⃣ Power imbalances and retaliation threaten community outcomes.

More than 84 % of communities interviewed reported intimidation, threats, or violence linked to their complaints. Without robust anti‑retaliation safeguards, communities either withdraw from the process or endure prolonged trauma and unsatisfactory outcomes.

On top of these prevalent security risks, challenges such as poor communication on cases, language barriers, logistical and financial obstacles, and exclusion through representation structures, to name a few, make it difficult for communities to advocate for their rights in these processes.

In such cases, support from civil society organizations was often cited as an important element in overcoming such barriers and often led to stronger commitments that were more likely to be completed or started.

5️⃣ IAMS focus reporting on process metrics rather than outcomes.

Most systematic, public reporting of data by IAMs stops at the point of reporting on whether an agreement was reached or findings were made in an investigation.  But communities note that independent monitoring that focuses on accomplishing all commitments is what creates pressure for management and their clients to make good on their promises to remediate harm.

Implications

This report set out to answer a fundamental question: are Independent Accountability Mechanisms (IAMs) delivering meaningful remedy to communities harmed by development bank-financed projects? The answer, as revealed through extensive quantitative and qualitative research, is layered and complex. IAMs can deliver remedy, and in some cases, do so in ways that are creative, responsive, and transformative. But these successes are the exception, not the rule. Across the 2,270 complaints analyzed, only a small fraction resulted in verifiable commitments, and fewer still achieved full implementation. Even when promises were made, communities often bore the burden of navigating opaque, slow, and frequently disempowering systems to see those promises fulfilled.

Our research outlines the urgent need for reform to ensure that when communities are harmed by bank-financed projects, there is a genuine commitment to resolve that harm fully.  These reforms should include:

1. Developing institution-wide remedy frameworks: Establish institution-wide standards ensuring that remedy is timely, adequate, and tailored to the needs of affected communities.
2. Empowering IAMs with remedy mandates and ensuring they have the institutional resources to carry out that mandate: Equip mechanisms with the independence, staffing, and authority to monitor, enforce, and escalate when commitments stall.
3. Strengthening implementation and monitoring of commitments: Make monitoring participatory, ensuring communities have a voice in designing, tracking, and verifying commitments.  Improve independent monitoring processes at IAMs. Enforce consequences for non-implementation of commitments by requiring upfront funding for community harm and clear penalties for delays, cancellations, or incomplete remedies.
4. Addressing power imbalances, particularly around retaliation risks: Implement robust anti-retaliation measures. Empower communities to navigate the process. Design power-aware processes.  Design inclusive and grounded engagements.
5. Improving transparency and data reporting and embedding metrics in performance evaluations: Systematically track and publish outcomes across all complaints to evaluate effectiveness and strengthen institutional learning.  Outcomes of IAM processes should be included in net impact evaluation of projects and development effectiveness assessments.

When development banks fully resource and support accountability for unintended harms,  the promise of development finance—to lift people out of poverty without sacrificing their rights—becomes attainable.  Examples exist already that show the promise of what’s possible when mechanisms are empowered with the right tools, adequately resourced, and engaged in independent and participatory monitoring of outcomes.  

As one impacted community member from a U.S. OPIC-funded project in Liberia stated:

“It’s not about the number of years, it’s about the result. If it takes ten years, if there’s a real result, a remedy, you forget the time it took, because you have gotten justice.” 

Justice is the call of hope that all communities who file complaints look to achieve, and the solutions for development banks to facilitate these processes are within reach.  It is incumbent on development banks to take accountability and respect for the rights of those they purport to serve seriously by seizing the reforms that will bring a sharper focus to ensuring outcomes promised are actually achieved.

To access the full report and more detailed recommendations, visit our report here.  We invite you to explore our public database of interactive complaints and outcomes, which will continue to be updated.