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News / 10 april 2026

Both ENDS: strengthened FMO complaints mechanism is a step forward, but major gaps remain

Both ENDS welcomes the strengthened Independent Complaints Mechanism (ICM) of development finance institutions FMO, DEG and Proparco as an important step forward in accountability. Working directly with communities affected by development projects, we see daily how essential it is that people can access justice when they are harmed in the name of development. For many communities, this mechanism is one of the few avenues through which harm can be formally recognised and addressed in relation to these development banks.

Since the mechanism was established, Both ENDS – together with Inclusive Development International and other civil society organisations – has worked with communities that have experienced harm to their livelihoods, land and environment to file complaints throughout the ICM process. This experience has led us to consistently callfor policy revisions to improve access to accountability and remedy.

Active engagement in the revision process

Over the past year, we have engaged very actively in the revision process. Both ENDS has worked closely with other civil society organisations to engage in the process and helped coordinate consultation inputs to ensure that the voices of affected communities and civil society were heard as clearly as possible. We also actively engaged not only with the banks themselves and the members of the Independent Complaints Mechanism, but also with the Dutch government.

Meaningful improvements

We are pleased to see that the revised policy reflects the commitment of many actors and includes a number of meaningful improvements. The new policy introduces several important changes, including structural improvements that strengthen the independence of the mechanism, clearer procedures and shorter timelines, stronger recognition of retaliation risks faced by human rights defenders and marginalised groups, and enhanced references to international human rights and environmental standards. The possibility to submit complaints after a project has ended is also a significant improvement.

We consider these changes a clear step forward and an important win for communities seeking recognition and justice. They show that sustained engagement by civil society and affected communities can lead to real improvements in how development banks are held accountable. This is important, especially in a time where we see human rights and accountability under unprecendeted pressure and even breakdown.

Remaining concerns

At the same time, we remain concerned about several critical gaps that limit the mechanism’s ability to ensure effective remedy. In particular, the rules regarding complaints related to financial intermediaries risk blocking access to remedy in a large number of cases. There is also still a lack of clarity about when complaints can be filed early in the project cycle, strict time limits for dispute resolution, and insufficient protection for people who face retaliation after filing complaints. In addition, stronger independence and adequate staffing for the mechanism remain essential.

We welcome the revised policy as a significant step forward, while emphasising that further improvements are still urgently needed. We remain committed to continuing to work with affected communities and to holding the banks accountable so that access to justice and remedy becomes a reality.

 

Please find our statement here 

 

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