Webinar Report – 09 September 2026
On 9 September 2026, Prof. Gamze Erdem Türkelli and Ms. Janet Jebichii Sego of the Law and Development Research Group at the Faculty of Law, University of Antwerp, hosted a webinar on Independent Accountability Mechanisms (IAMs) in Development Finance, in the context of multilateral development banks (MDBs) and bilateral Development Finance Institutions (DFIs).
The webinar featured presentations from Prof. Daniel D. Bradlow, a distinguished scholar in International Development Law and author who has extensively researched and written on the Law of International Financial Institutions, among other accolades and Ms Stephanie Amoako, Policy Director at Accountability Counsel and a seasoned civil society expert who has taken part in implementing strategies to strengthen accountability mechanisms for human rights harms caused by internationally financed projects across the globe.
Generally, IAMs enable affected communities and individuals in financed development projects to raise concerns where such projects have caused harms to human rights, to the social well-being and to the environment due to these institutions’ failure to comply with their own operational policies and procedures (OPPs).[1] The role of IAMs and efforts to improve their operations have never been timelier. After 33 years since the establishment of the first IAM, of the World Bank Inspection Panel and of the subsequent establishment of similar IAMs by all international financing institutions (IFIs), there remain several ongoing difficulties, such as persistent gaps in access to effective remedy by affected communities and the IAMs’ lack of independence from the MDBs’ and DFIs’ management, among other challenges.[2] The recent decision by the World Bank’s Executive Board to reject the findings of the IFC Compliance Advisory Ombudsman (CAO) holding the IFC to be non-compliant with its OPPs in the financing of banks involved in microfinance activities in Cambodia is a case in point on the challenges of independence and resistance that the IAMs face from within.[3]
The 2030 Sustainable Development Agenda calls for the mobilisation of public and private finance to fill the Sustainable Development Goals financing gap in developing countries (Erdem Türkelli 2025, 221–222). This trend has potential human rights implications, particularly where the ultimate use of this finance involves public-private partnership arrangements to implement development projects with adverse human rights impacts on communities, for example, forced evictions and labour rights violations, in the recipient developing countries. This implies that affected communities and their civil society representatives will continue filing complaints within the IAMs of the MDBs and bilateral DFIs involved in such development projects.
The two complementary presentations, by Bradlow and Amoako, considered the history and the rationale for the establishment of the first IAM broadly, and the efforts to improve their operation, as well as the implications of these efforts for communities seeking accountability for harms associated with the financed development projects.
Prof. Bradlow briefly outlined the reasons for the establishment of the World Bank Inspection Panel and how it has become a soft law-making mechanism through its decisions involving interpretation and application of the World Bank OPPs.[4] Reflecting on the developments, Prof. Bradlow noted the convergence of the World Bank’s Environmental and Social Safeguards and other regional MDBs’ policies, as well as the establishment of similar IAMs by these regional MDBs and bilateral DFIs alongside the increased co-financing initiatives by different MDBs and the challenges that these developments present to the communities approaching these IAMs. These challenges include the lack of total institutional independence of the IAMs from the MDBs, where their decisions may be approved or rejected by their respective boards; challenges in access to IAMs in MDBs’ co-financing arrangements; and the inability of the MDBs to provide compensation or meet the costs of the harms suffered by the communities.
To this end, he proposes a Super IAM, delinked from the individual MDBs and able to handle complaints against all participating MDBs in accordance with each MDB’s OPPs, as a possible solution to the challenge of institutional independence.[5] To respond to the issue of monetary costs for harms suffered by the affected communities, Prof. Bradlow recommends the establishment of an Assistance Fund to which there could be contributions by international organisations, states, individuals, corporations and foundations among others. A finding of the Super IAM that there would be harm as a result of non-compliance of the relevant MDB would be sufficient to entitle the affected communities to request to benefit from the Assistance Fund. Further discussion of Prof. Bradlow’s proposal, together with other insights on IAMs, can be found in his co-edited volume Perspectives on Accountability at International Financial Institutions: Thirty Years after Creation of the World Bank Inspection Panel.
Ms. Amoako complemented this presentation through the lens of the affected communities and civil society. She highlighted the high demand from communities to access the IAMs for harms suffered in internationally financed projects. To Ms. Amoako, the innovative proposal of a Super IAM could offer solutions to the common challenges faced by affected communities, for instance, in co-financing arrangements involving multiple MDBs. However, the use of the OPPs and the IAM of the lead financier in co-financing arrangements results in a situation where other MDBs and bilateral DFIs are left off the hook. In other instances where communities can file multiple complaints, the IAM processes vary across institutions, which can be confusing for communities and affect access to remedy altogether.
Ms Amoako also noted that adopting a Super IAM could enhance the IAM’s standing and perceived authority among MDBs and other stakeholders. She noted that it is common for MDBs to reject the findings of their own IAMs, as shown by the recent World Bank’s Board of Directors’ rejection IFC CAO’s findings of the IFC’s noncompliance with its OPPs on financing through financial intermediaries in Cambodia.[6] This decision led to the resignation of the CAO’s chairperson, sparking strong concerns and reactions from civil society organisations and individuals concerned about accountability to affected communities.[7]
Having been extensively involved in civil society actions in the World Bank Group’s ongoing operationalization of the integration of the Inspection Panel, the Dispute Resolution Service and the IFC/MIGA CAO[8], Ms Amoako highlighted the importance of a strong policy foundation of an IAM at the outset. She highlighted the risk that, in developing an integrated Super IAM, participating MDBs may settle on a weaker policy, as negotiations over a common policy would necessarily involve compromises among the diverse policies under which the MDBs’ existing IAMs operate. A Super IAM should adopt a strong Policy, pointing out the IFC CAO’s current policy as one that could set a good example, for instance, in the context of the World Bank’s new IAM. Some of the policy recommendations pointing out the strong policy provisions that the World Bank’s new IAM could adopt can be found here, and the 2024 updated Good Policy Paper on the policies of IAMs can be found here
Ms. Amoako also acknowledged that positive decisions of IAMs are only part of the affected community’s successful access to “remedy” on paper, but what they actually consider as an effective remedy also matters. While appreciating the proposal for an Assistance Fund to support compensation, she highlighted that, if implemented, it should be conceptualised from a human rights perspective and consider the harms suffered, to avoid it being perceived merely as a charitable fund.
The webinar concluded by highlighting that Prof. Bradlow’s proposal for a Super IAM seeks to reduce fragmentation in accountability processes by promoting cooperation among the IAMs of participating MDBs, while strengthening both the institutional independence and, ultimately, access to effective remedy for affected communities. The discussion also generated insights for further reflection, including the Super IAM and the distribution of responsibilities in co-financing arrangements, the Assistance Fund and similar proposed funds like the International Fund for Victims in the Updated draft legally binding instrument on business and human rights and the Trust Fund under the Rome Statute.[9]
The journey towards a Super IAM appears to have gained momentum, as evidenced by the World Bank’s new IAM. It is worth noting that this development is not without precedent, albeit not from the context of MDBs. Some bilateral DFIs, with OPPs and IAMs heavily borrowing from or adopting those of the MDBs, have already developed and operated a joint IAM as a form of institutional integration. In particular, three leading European bilateral DFIs namely, the Dutch Nederlandse Financierings-Maatschappij voor Ontwikkelingslanden N.V. (FMO), the German Deutsche Investitions- und Entwicklungsgesellschaft mbH (DEG), and the French Société de Promotion et de Participation pour la Coopération Économique (Proparco) operate a joint Independent Complaints Mechanism (ICM).[10] The ICM was established by the FMO and DEG in 2014, while Proparco joined in 2019.[11] Between 2022 and 2025, the three DFIs undertook a review of the 2017 ICM Independent Policy, culminating in an Updated ICM Policy that entered into effect on 1 March 2026.[12]
The experience of this joint ICM is relevant to the emerging discussion on a Super IAM because it provides an existing example of how accountability processes can be jointly organized across different DFIs. The World Bank’s new IAM represents a development towards some of the institutional features envisaged in Prof. Bradlow’s proposed Super IAM, particularly in relation to greater independence from the MDBs’ Management. In this respect, the new provision by the FMO, DEG and Proparco to strengthen the independence of their ICM by establishing it as a stand-alone mechanism is a particularly relevant development.[13] While the current discussion on a Super IAM mainly focuses on the MDBs, the experience of the FMO/DEG/Proparco ICM suggests that the bilateral DFIs’ context may also offer relevant practical insights. The experience of FMO/DEG/Proparco’s joint ICM, together with lessons that may emerge from the implementation of the new ICM Policy 2026, could therefore inform ongoing discussions about greater collaboration and integration among IAMs.
In all these efforts, however, the guiding principle should remain the core rationale behind the establishment of the first IAM: providing meaningful accountability to communities and individuals affected by the actions of MDBs and bilateral DFIs alike.
The full webinar recording is available below.
[1] Accountability Counsel and others, ‘Good Policy Paper: Guiding Practice from the Policies of Independent Accountability Mechanisms’ 10 <https://cdn.prod.website-files.com/68e5762082f60ead6d3ad3ab/69120e1e0bcd523edf15e204_good-policy-paper-2024.pdf> accessed 23 September 2026.
[2] Daniel D Bradlow and others (eds), Perspectives on Accountability at International Financial Institutions: Thirty Years after Creation of the World Bank Inspection Panel (Brill | Nijhoff 2025) 2–3 <https://doi.org/10.1163/9789004729735> accessed 8 May 2026.
[3] Accountability Counsel, ‘World Bank Board Destroys Trust in Its Accountability System’ (30 June 2026) <https://www.accountabilitycounsel.org/blog/world-bank-board-destroys-trust-in-its-accountability-system> accessed 23 September 2026.
[4] Daniel D Bradlow, ‘The Inspection Panel and International Law’ in Daniel D Bradlow and others (eds), Perspectives on Accountability at International Financial Institutions: Thirty Years after Creation of the World Bank Inspection Panel (Brill Nijhoff 2025) 43–47 <https://brill.com/edcollbook-oa/title/72165> accessed 23 September 2026.
[5] Bradlow Daniel D., ‘A Proposal for One “Super” Independent Accountability Mechanism’ in Daniel D Bradlow and others (eds), Perspectives on Accountability at International Financial Institutions: Thirty Years after Creation of the World Bank Inspection Panel (Brill | Nijhoff 2025) <https://doi.org/https://doi.org/10.1163/9789004729735_033> accessed 8 May 2026.
[6] Accountability Counsel (n 3).
[7] Inclusive Development International, ‘World Bank Board Denies Recourse to Millions of Victims of Predatory Lending, Sets a Dangerous Accountability Precedent’ (30 June 2026) <https://www.inclusivedevelopment.net/world-bank/world-bank-board-denies-recourse-to-millions-of-victims-of-predatory-lending-sets-a-dangerous-accountability-precedent/> accessed 23 September 2026.
[8] World Bank Group, ‘World Bank Group Boards Strengthen Independent Accountability Mechanisms’ (9 June 2026) <https://www.worldbank.org/en/news/press-release/2026/06/09/world-bank-group-boards-strengthen-independent-accountability-mechanisms> accessed 23 September 2026.
[9] Rome Statute of the International Criminal Court 2021 art 79; Updated draft legally binding instrument to regulate, in international human rights law, the activities of transnational corporations and other business enterprises 2023 art 15.7.
[10] DEG, FMO and Proparco, ‘ICM Policy’ 4–5 <https://www.fmo.nl/news-detail/91d59bc9-49dc-4e2d-bfa3-36c6675f0cd0/revised-independent-complaint-mechanism-policy-in-effect> accessed 29 April 2026.
[11] ICM, ‘Independent Complaints Mechanism’ <https://icmpanel.eu/en/> accessed 23 September 2026.
[12] DEG, FMO and Proparco, ‘Independent Complaints Mechanism Public Consultation on the Draft Policy: Stakeholder Feedback Report’ (2026) <https://icm-consultation.org/wp-content/uploads/2026/03/2026_03_01_ICM_Public_Consultation_Stakeholder_Feedback_Report.pdf> accessed 29 April 2026.
[13] Janet Jebichii Sego, ‘An Appraisal of the Updated FMO/DEG/Proparco’s Independent Complaints Mechanism Policy: Assessing Its Prospects and Potential Impact on Access to Remedy’ (African Legal Studies, 29 May 2026) <https://africanlegalstudies.blog/2026/05/29/an-appraisal-of-the-updated-fmo-deg-proparcos-independent-complaints-mechanism-policy-assessing-its-prospects-and-potential-impact-on-access-to-remedy/> accessed 23 September 2026.