PSEAH in IFIs: Progress, Gaps and the Road Ahead

IFIs play a crucial role within the international community in delivering on commitments on PSEAH but they have faced several challenges to using their potential for the benefit of PSEAH in a transformative way. These challenges are described below.

Challenge 1: IFIs do not speak with one voice on PSEAH and GBV and thus fail to raise the bar sufficiently

The 2018 joint IFI commitment on PSEAH was a significant starting point. Since then, global practice has advanced, including in most IFIs. Governing members, donors and other actors in the development sector have raised the bar by signing up to the DAC Recommendation and to CAPSEAH, setting more granular, negotiated benchmarks and signalling their commitment to moving towards collective approaches. IFIs themselves have engaged in developing GPNs and guidance, but most of this remains voluntary.

Meanwhile, IFIs have not updated their collective pledge, which is a challenge. In operations, partner countries and private sector borrowers must conform to different sets of requirements; IFIs face challenges in capacity, transparency, GMs and victim-centred approaches. IFIs’ efforts remain fragmented, siloed by project and IFI. This is further impacted by the fundamental differences in engaging with public versus private sector clients and business contexts. This hampers learning and leads to many missed opportunities for co-operation and efficiency gains. Taken together, these challenges have made it difficult for IFIs to have a transformative impact in PSEAH (and GBVH more broadly), as the lagging progress in MOPAN assessments shows.

Although co-operation among IFIs and with the UN and others clearly shows a need for harmonised standards and policies to make PSEAH efforts effective, sustainable and efficient, IFIs have not yet aligned with the collective approach that is emerging in the international community (CAPSEAH).

Many sides are calling for a renewed commitment, notably shareholders.³⁵ In 2023, 15 MFI shareholders, accounting for 85% of ODA in 2021, engaged in a dialogue with IFIs to define aligned language on PSEAH that could be used in their funding agreements to reflect key minimum safeguarding standards and to include specific language on PSEAH. (A similar agreement was reached with the UN’s Office of Legal Affairs in 2021). However, these efforts were paused as no conclusion was found. Shareholders consulted for this study indicated their readiness to reopen the dialogue on the proposed aligned language to work towards a mutually agreeable outcome, factoring in subsequent developments, including the launch of CAPSEAH.

PSEAH practitioners in IFIs also call for harmonised minimum institutional standards. In their daily work at country or project level, practitioners see how the lack of common minimum standards hinders IFIs from working collaboratively. Borrowing governments and companies must navigate many due diligence mechanisms, community reporting standards, and contractual clauses, which is both confusing and inefficient. Harmonising these requirements and establishing co-operation agreements would bring significant synergies and cost savings.

While IFIs can individually push clients to raise standards, a collective voice amplifies leverage, influence, and impact: it would significantly strengthen IFIs’ policy impact on governments, industries and private sector, and is essential in the early country alignment phase of projects. This is an under-utilised opportunity for IFIs to anchor PSEAH considerations in national strategies on economic development and labour markets, gender equity, social protection or human rights.

Challenge 2: Despite great potential, IFI-UN collaboration is under-explored

The complementary mandates of IFIs and the UN system bode well for a significant breakthrough in PSEAH. However, IFIs and the UN are not yet joining forces despite their important complementary advantages in advancing PSEAH. In its programmatic co-operation with governments and civil society on the development of norms, matters of governance, human rights, gender equality, and labour standards, the UN brings value by providing technical knowledge that can foster efforts to prevent GBV, including SEAH. Several IFIs noted the UN’s capacity in country context analysis and data collection. While IFIs do not have the programmatic approach distinctive to UN organisations, they bring financial leverage and links to the private sector that the UN cannot offer. To minimise project risks, IFIs depend on governments to create an environment that prevents GBV (including SEAH in IFI projects). This enabling environment, in turn, is often strengthened with support from the UN and civil society partners.

Both families of organisations negotiate with the same governments. This is an opportunity to pass the same message about PSEAH and make support conditional on it. IFIs and the UN are not currently united sufficiently to use their joint leverage. In May 2024 the UN integrated language on SEA into the model template for United Nations Sustainable Development Cooperation Frameworks (UNSDCF), establishing an UN-system-wide framework for PSEA in countries.³⁶ The clause aims at strengthening government capacity in this area. UNSDCFs are directly relevant only for UN agencies (including for IFAD and the World Bank) but provide an important opportunity for IFIs to reflect on how best to combine their PSEAH-related expectations with this framework.

Collaboration for PSEAH is most promising where UN, government and IFI actors align based on comparative strengths and field-level needs. Interviewees believe that to work effectively together, co-operation must pivot toward strengthening national capacities that can endure beyond individual projects. IFIs and the UN would thus do well to take a common, co-ordinated stance on SEAH with respect to governments with whom they both partner.

The partnership between ILO and IFC and EBRD is one example of collaboration between a UN agency and a private sector IFI (Box 6.1).

At a practical level, emerging collaboration between IFIs and the UN on PSEAH holds considerable promise. MOPAN assessments highlight this collaboration as an opportunity, especially in fragile contexts, although systematic cooperation has yet to develop. It is too early to identify concrete results as structured collaboration remains nascent. However, interest and early momentum for building synergies in strengthening partner and service provider capacity are growing. In interviews, IFIs mentioned many more opportunities to improve quality, sustainability and efficiency through better collaboration (Box 6.2).

These collaboration efforts remain uneven. Most initiatives are still at early stages. Strengthening and scaling them up will be essential if IFIs are to provide coherent support to governments, civil society and the private sector, and maximise the global impact of PSEAH commitments.

IFAD and the WBG could serve as a bridge between IFIs and the UN, a conduit for good practice in both directions. As specialised agencies within the UN system, they are in a particular position as they participate in many joint UN efforts on PSEAH. IFAD systematically partners with other UN development system agencies, participates in the voluntary annual staff survey on SEAH organised by the UN Special Coordinator, submits action plans and a management letter to the Secretary-General every year to report on progress, and participates in iReport. The World Bank participates in various PSEAH-related fora of the UN and beyond — the IASC Deputies Group on PSEA — and generally invited to UN country team and PSEAH coordination meetings (primarily for work on internal misconduct).

Areas of further potential cooperation include joint diagnostics, capacity development and support to victim-survivors: 

• Joint diagnostics: Joint diagnostics and analysis are among the low-hanging fruit. IFIs and the UN could share risk, GBV or gender assessments, especially in fragile settings where they overlap. MOPAN, however, found no systematic examples so far.
• Government capacity development: IFIs see scope to join forces with UN agencies in supporting governments in setting norms and providing support to survivors. Country-level working groups on PSEAH, often convened by UN Resident Coordinators’ Offices, could serve as entry points.
• Support to victim-survivors: IFIs in our sample view survivor mechanisms and service provision as an obvious area for deeper IFI-UN collaboration. Historically, IFIs have relied on civil society and the UN to provide these services, and the UN has promoted community-based complaint mechanisms as entry points for grievances across both UN- and IFI-financed projects. Many local GBV organisations that underpin these systems have been funded by UN agencies or international NGOs. This symbiosis is now at risk: shrinking humanitarian, gender and budgets for development, equality and inclusion jeopardise service continuity just as needs remain high. That makes predictable, sustainable funding essential – beyond ad-hoc project support. It also points to the need, as previously mentioned, to raise cooperation to the policy level so IFIs and the UN can engage in a joined-up policy dialogue with governments, for example, on resourcing survivor services (Challenge 7). In practice, this could mean aligning on referral pathways, leveraging UN-convened or other local country-level GBV or PSEAH groups and, where appropriate, co-financing or pooling resources to stabilise local service providers.

A central question for IFI-UN collaboration is whether to prioritise strengthening government-led mechanisms or independent ones. The IFI public sector business model emphasises governments’ duty to prevent and respond to SEAH, whereas the UN often supports humanitarian or community-based systems. To align these approaches, the World Bank recently negotiated and revised the UN Standard Forms of Agreement.³⁷ It governs situations where World Bank clients mobilise the UN for delivering work and contains PSEAH requirements. These situations offer an opportunity to advance mutual understanding and collaboration in practice.

Challenge 3: Vision, leadership and a renewed commitment: The need to elevate PSEAH strategically

For GBV/PSEAH to become a priority in discussions with client governments, leadership by IFIs – both individual IFIs and IFIs as a group – is critical for progress. The leverage IFIs hold in their financing relationships with governments is an exceptionally strong asset for advancing this agenda. Similarly, for GBV/PSEAH to become a priority in engagements with businesses and industry groups, strong leadership by IFIs — individually and collectively — is essential. IFI leverage through private-sector financing is a powerful driver of progress on this agenda.

Leadership is an important positive enabling factor for addressing SEAH and matters at several levels: IFIs as a group, executive boards, senior leadership, its country management, as well as leadership by the (borrowing) government or companies in tackling GBV.

The DAC Recommendation and CAPSEAH both call for strong leadership on PSEAH. CAPSEAH considers it as one of six minimum agreed actions and understands it as “prioritising and embedding a culture of zero tolerance of inaction.” Leaders need to show clear and visible commitment to zero tolerance for inaction on SEAH and allocate sufficient resources to prevent and respond to it. They should regularly assess and monitor the implementation and impact of efforts to prevent and respond to SEAH and set out and incentivise clear responsibilities on PSEAH.³⁸

The DAC Recommendation calls for strong leadership on PSEAH within every development and humanitarian organisation to drive a culture of zero tolerance, accountability, and active prevention of SEAH. It expects institutional ownership through visible executive commitment, adequate resources, and systems that embed SEAH risk management into core operations. At the collective system level, DAC members are asked to show joint leadership by aligning policies, coordinating action, and promoting mutual accountability across the international aid system. Lastly, the recommendation emphasises the importance of country-level and survivor-centred ownership, urging engagement with partner governments and affected communities so that prevention and response efforts reflect local leadership and context-specific accountability.

However, interviews suggest that securing sustained institutional attention for PSEAH within organisations remains a challenge. GBV, and PSEAH as part of it, must be recognised as a challenge to development. Although several interviewees stressed that the most likely way to get senior leadership’s attention to SEAH today was by pointing out the enormous operational and reputational risk it poses, evidence from this study points to a need to recognise SEAH not only as a risk, but first and foremost as intrinsically linked with GBV and thus with development. The risk of not addressing SEAH is therefore not only operational and reputational but also mission critical.

Executive boards are not yet exerting the necessary leadership on PSEAH. However, they have a key role to play in stating clear expectations, demanding and scrutinising evidence of implementation, and holding IFIs accountable to their commitments. As IFIs often work with borrower systems, they can only implement effectively if national institutions have adequate capacity and align with IFI standards. Success therefore relies on policy alignment with country realities and robust monitoring. A common suggestion by interviewees from IFIs and governments was that executive boards should raise the relevance and visibility of PSEAH and GBV by doing the following:

• Making PSEAH a regular agenda item (as the UN does). In this vein, the MOPAN assessment of AfDB, for instance, encourages the Bank to “ensure reporting at the Bank’s Governing Board” about PSEAH, thus strengthening the accountability of its leadership to take forward the PSEAH initiatives recommended by its board.
• Requiring concrete, institution-wide evidence on progress in implementing the PSEAH agenda and on public reporting on systems and demand regular updates.

To strengthen GBV governance by its Board, IFC in 2023 released a tip sheet with guidance for boards of directors on overseeing GBV and harassment risks. (IFC, 2023b[69])

Within an organisation, top managerial leadership is often missing in securing resources, establishing accountability, ensuring more effective performance, and creating trust among staff and clients. The role of leadership is essential in framing protection and response to SEAH as an institutional responsibility for which all staff play a role but for which management bear the ultimate responsibility, similar to the management of financial and other operational risks.

Expectations of good managers include:

• Subjecting PSEAH systems to scrutiny through audit and evaluations.
• Integrating PSEAH project performance and sustainability reporting.
• Benchmarking institutional resources for PSEAH against the portfolio and budget.

A stronger “tone from the top” is needed. MOPAN assessments and interviewees found that the “tone from the top” on PSEAH needed to be stronger to ensure the commitments IFIs have made are implemented. Interviewees reinforced that this was important to ensure that staff take the issue seriously, managers allocate time and resources to it, and that investment officers accept building in “extra requirements” from clients rather than just “getting the deal done”. Clear leadership also help personnel to develop the courage to speak up and build trust in the Bank’s mechanisms for reporting and believe in its commitment to accountability (Box 6.3).

Stronger joint IFI and government leadership at country level are needed. Working to achieve transformational change on GBV that goes beyond project-level safeguards requires IFIs to engage with the government at the country level (Section 4.4). IFIs deplored that this was often lacking, due frequently to capacity constraints. World Bank interviewees stressed the importance of leadership at country level for seizing opportunities for GBV and PSEAH where they arise. Such entry points are:

1. Integrate PSEAH into country engagement strategies, signed by governments; and making prevention of GBV an integral part of discussions with Ministries of Finance, the primary interlocutor for IFIs.

2. Strengthen project designs with respective ministries (such as Education, Social Protection, Health, Transport, etc.) so that they can lead to a shift in gender norms. In the World Bank’s experience, having a GBV pillar in the Bank’s gender strategy greatly facilitated this endeavour.

3. Have an institutional strategy for PSEAH in place that ensures GBV expertise at the country level as a prerequisite for every project above a certain SEAH risk threshold.

The shifting context of shrinking funding is a key challenge to all considerations made in this report and a general perception that clients’ political will to own this agenda has diminished. This study mentioned that where governments were happy to borrow resources for GBV projects in the mid-2010s, many hesitate today, according to IFI staff interviewed by MOPAN as part of this study. Shrinking funding for UN agencies and civil society is expected to fall considerably.³⁹ This affects the work on GBV on which IFIs indirectly rely and is likely to affect the work on PSEAH of IFIs. These challenges will be harder for IFIs to address in the current context, making it even more important for those leaders who remain committed to step up.

Challenge 4: IFIs are not working through a “whole-of-institution” vision for PSEAH

Most IFIs lack a strategic board-approved vision for addressing SEAH for the organisation as a whole. MOPAN assessments and interviews reveal that the lack of a clear, holistic institutional vision encompassing both GBV and SEAH hinders strong leadership. MOPAN’s EBRD assessment recommended that the Bank build a strategic vision for GBVH, as a key prerequisite for strong leadership. Similarly, the AfDB assessment found that the institution lacked an organisation-wide strategy describing how it intends to align its capacity and approaches with its commitments. In the World Bank Group, the interviews for this report suggest the public and private sector focused PSEAH entities could work better together. The recent reorganisation may facilitate this aim.

The lack of an overarching vision can lead to a narrow, compliance-based approach to PSEAH at the country level. A stronger institutional vision would position SEAH as a challenge to development, in which SEAH risk management in operations is clearly complemented by work with the government to reduce GBV, and where institutional efforts directed at the IFI’s own personnel is part of a larger strategy.

PSEAH considerations, including the promotion of an enabling environment to address PSEAH using country systems, are rarely integrated into high-level country strategies systematically. Initiatives like the World Bank’s “Overview Assessments” are one such entry point at the country level (Box 4.3). There are also other examples in sovereign operations where project-related risk management processes have opened up workstreams and financing to address GBV as a broader development challenge, such as the World Bank’s projects in India (Box 6.4). In general, the country alignment phase presents an important but often under-utilised opportunity for IFIs to anchor PSEAH considerations early, particularly by linking them to national strategies on gender equity, social protection, or human rights (see also Challenge 3). However, unlike project level E&S management plans, which are systematically financed, policy-based initiatives at the country level often rely on separate funding streams. Where governments are reluctant to borrow or have limited access to concessional resources such as IDA grants, uptake of PSEAH in country strategies remains constrained.

Lack of a coherent strategy also leads to disjointed institutional responses, fragmented policies and reporting. The internal justice systems of IFIs encompass independent actors thanks to strong institutional mandates and predictable resources. Yet effective responses to misconduct can be thwarted by diffused roles and responsibilities. In some IFIs, ethics offices are responsible for the intake of complaints of internal SEAH and referral for investigation, whereas the HR department is responsible for implementing whistleblower protection measures upon the recommendation of Integrity or Investigations offices.⁴⁰

MOPAN assessments point to gaps in coordinated handling complaints. Some IFIs have reported an important time lapse between when a complaint is made and when victims receive protection, while others voiced concerns about data protection and confidentiality risks. This fragmentation can also make it challenging for survivors to access end-to-end support and updates of their case as it progresses to different stages overseen by different actors.

Co-ordination among units dealing with internal conduct and with misconduct in operations requires that they all have a clear understanding of their complementary but related roles. ADB reported that it has sought to connect lessons on PSEAH in projects to its internal workplace practices, which is positive.

Executive boards should demand a coherent, overarching PSEAH strategy as interviewees from IFIs and governments commonly suggested, along with regular, transparent reporting against its implementation to strengthen their accountability.

Underlying these efforts is the lack of common standards that go beyond country-specific collaboration. Several IFIs interviewed for this study consider CAPSEAH a useful reference point with which standards should eventually align. Some are already integrating CAPSEAH principles into training and policy language, while others find that misalignment with existing E&S frameworks hinders full endorsement. Still, interviews broadly agreed that minimum standards, particularly around victim assistance, would provide a common baseline and serve as a pathway to more consistent survivor-centred responses.

Challenge 5: Insufficient transparency in public reporting on PSEAH measures and incidents

Given the information available from IFIs, it is not possible to determine how effective they are in protecting from SEAH.

Joint accountability is fragmented across IFIs. Discontinuing joint IFI reporting as part of the CSSG framework could further weaken collective accountability and visibility of progress on PSEAH.

Following the commitments from the October 2018 London Safeguarding Summit⁴¹, institutions produced voluntary collective progress reports in 2019⁴² and 2021⁴³. IFI staff reported that those reports positively supported institutions in the following ways:

• Benchmarking institutional maturity
• Identifying gaps in survivor support systems
• Assessing resourcing and staffing needs
• Reviewing approaches to grievance mechanisms and due diligence, and
• Informing policy updates and internal decision-making.

Boards, senior management, and technical teams across IFIs widely referenced these reports. A final one was shared in 2023, at the five-year anniversary mark, when six IFIs reported on their achievements (ADB, AIIB, EBRD, EIB, IDB, and the World Bank, including IBRD/IDA and IFC)⁴⁴. This practice ended when CAPSEAH superseded the earlier framework, and no new mechanism for joint accountability has been introduced. As a result, it is unclear whether, and through what mechanism, IFIs will track collective implementation progress going forward. This fragmentation contrasts sharply with the UN system’s reporting, where, through the Secretary-General’s annual report on Special Measures for Protection from SEA, UN entities disclose actions taken to strengthen PSEAH implementation across operations, institutions, and country programmes every year.

Limited transparency in reporting on actions to prevent and respond to SEAH risks in operations. IFIs collect detailed SEAH data from projects but rarely disclose how risks are identified, managed, or mitigated. According to MOPAN assessments (see Annex B, element 4.7.7), while IFIs publish sustainability or E&S reports for investors, recent reports have emphasised environment and climate risk disclosure and reporting, and sometimes gender and safeguards. However, they do not contain an institutional update on PSEAH. Specific reporting on overall implementation was not available for high-risk cases either (where third-party monitoring was used).

This is not for lack of data. During project implementation, clients are asked to report on compliance with E&S frameworks on a monthly, quarterly, or semi-annual basis, depending on the risk level. They are also asked to report on compliance against the ESCP in the case of the World Bank and the agreed instruments such as ESAPs (ADB, EBRD, IFC) or ESMPs (AfDB, IFAD, IDB, World Bank) as part of their project completion report. (ADB announced that it will soon require project completion reports to demonstrate specifically how SEAH issues were managed and include PSEAH under compliance indicators). These project process reports aim to ascertain that SEAH risk assessments were conducted and that mitigation measures have been taken in line with the management or action plans.

Even where information on SEAH risk management at the project level is available, MOPAN assessments found that IFIs rarely synthesise it for publication. Under-reporting can be a consequence of several factors.

• Older projects: Most projects take 7-8 years or longer to implement, yet tools to consolidate observations on risk management, where they exist, are recent, so not yet active in older projects.
• Poor identification of SEAH risk: where SEAH risks are not flagged upfront and mitigation actions included in related instruments (ESAP, E&SMP, ESCP), or where new risks emerge throughout the project cycle, reporting on mitigation will be inadequate. Mitigation plans should be living documents that are updated, disclosed and reported against.
• Capacity issues and resource constraints in project level monitoring, which in turn can stem from IFI resource constraints and inadequate staffing and contribute to uneven oversight of risks.
• Lack of harmonised M&E frameworks for E&S policies: E&S policies generally have no harmonised M&E framework. This leads to heterogenous client reports, against indicators established separately at the project level, which makes aggregation complicated.
• Technical challenges in aggregating monitoring information at portfolio or institutional levels. Where risk signals are not aggregated and visualised across portfolios, safeguarding teams struggle to assure consistent supervision. This is the case in most IFIs, as until recently, client reports in Excel or on paper were the norm. Digitalisation is underway in some IFIs. IFC uses an internal GBV/SEAH dashboard and is developing the AI-powered MALENA tool (see Box 6.6); IFAD introduced a SECAP dashboard for project teams in 2024, and ADB, EBRD, and AfDB are at various stages of transition. Until such systems enable aggregation and disclosure, operational reporting will remain fragmented and opaque.
  

Public incident reporting on SEAH allegations in operations, incident handling and trends, is incomplete and inconsistent, offering little assurance that victim-survivors receive protection and follow-up support. The majority of IFIs require their borrowers and other clients to report severe incidents, such as SEAH, within a maximum of 48 hours. In their reporting to IFIs, they are typically required to provide anonymised information on the number of grievances received and their type, the status of their resolution, actions taken, remedial measures, cooperation with authorities, and survivor support provided. IFC was the last IFI in the cohort to recently introduce this requirement in March 2025, following the widespread publication of child protection gaps in a co-sponsored project in Kenya in the early 2010s. Yet most IFIs do not publish statistics showing how allegations in operations were handled. This is an important gap. Interviewees indicated that for stakeholders, the reassurance that IFIs and their clients acted appropriately — protecting survivors, providing assistance and enforcing sanctions – is even more important than the number of allegations itself.

Incident reporting on internal misconduct is similarly fragmented and opaque, which harms trust in IFIs’ justice systems. Usually, each function under the internal justice system releases its own annual reporting, making it challenging to obtain a clear picture of how sexual (and other) misconduct is addressed end-to-end. Communicating transparently, clearly listing outcomes and sanctions, is important for demonstrating fairness and accountability, and building trust.

IFIs voiced concern that incident-based reporting would pose a risk to confidentiality and to a survivor-centred approach, and that it would jeopardise the trust established with borrower countries on the use of data they submit to the IFI. This contrasts sharply with the UN’s system-wide SEAH reporting — anonymised data on allegations involving UN personnel and external actors such as implementing partners and international forces authorised under Security Council mandates is consolidated monthly for public release⁴⁵ — and with the SEAH Harmonised Reporting Scheme,⁴⁶ suggesting that transparency and survivor confidentiality can coexist if well managed through consistent reporting standards.

IFIs have begun to report allegations, but these reports concern only SEAH perpetrated by staff and not clients and their contractors. Although the reporting of such information in aggregate and anonymised form is an important component of demonstrating accountability, MOPAN assessments found wide disparities. EBRD publishes high-level information in its annual Integrity and anti-corruption report on internal misconduct matters, including the type of misconduct, outcome of disciplinary decisions of cases internally since 2023, but it has never registered a SEA complaint. AfDB reported no SEAH cases in 2020–21; ADB does not publish data on SEA allegations or actions taken to address them (ADB’s OPEC report aggregates only the number of SH reports received); IDB publishes data on SH in its Ethics Office annual report, including sanctions and recommendations following root cause analyses. However, the report does not include a specific category for SEA allegations, i.e., those involving external victims. As a result, publicly available information does not include data on SEA cases; mandatory reporting was introduced in the WBG. While the World Bank and IFAD disclose the most data, the case outcome for SEAH is unclear from the aggregate reporting the World Bank provides, and there is no reporting on the assistance provided. Although IFIs have occasionally provided case studies, none provide consolidated incident reporting to their boards.

Challenge 6: IFIs currently focus on compliance more than on effectiveness

Accountability tools to assess how well PSEAH measures work are underused, limiting institutional learning and evidence-based decision-making.

IFIs have established rigorous risk framework-related processes to certify that they and their partners are compliant with requirements. Across the board, risk frameworks and related reporting yield data for IFIs that show whether specific mitigation measures have been followed. Such data is compiled in reports such as the World Bank’s biannual Implementation Status and Results Report, ADB’s quarterly and semi-annual safeguards monitoring and IDB project monitoring reports, often prepared by borrowers/clients, and varying in coverage, frequency, and accessibility.

Reporting is heavily compliance oriented. It tends to focus on activities and outputs such as the implementation of management plans, the existence of GRMs, number of complaints received, resolved or pending, staffing and training, or whether mitigation measures have been carried out. It does not allow IFIs to determine how effective interventions have been, i.e. how well prevention has worked, how well the GRM functioned, whether victims have been protected and been taken care of, or what changes training brought about. The 2019 review of IDB’s OVE, for instance, notes that IDB safeguard policies “focus strongly on up-front preparation requirements, with little emphasis on how to achieve results” and can “encourage a tick-the-box attitude.”⁴⁷

IFIs have not yet embedded PSEAH into their wider accountability and learning systems. This hinders learning, limits understanding of what works and constrains strategic decision-making on policy and resource allocation.

• Audits and evaluations rarely assess how effective PSEAH systems are in practice. MOPAN identified only few examples — i.e. the World Bank’s forthcoming Independent Evaluation Group (IEG) review of WB ESF implementation and of IFC performance standards, both of which will include SEA/SH considerations,⁴⁸ the WBG’s Group Internal Audit assurance review of IFC’s GBV risk management processes in projects (which will however remain internal) and the ADB’s IED evaluation of 2021 (albeit with a focus on grievance redress mechanisms).
• The lack of PSEAH indicators is one important reason why data analysis is nearly impossible and why measuring effectiveness of PSEAH in IFIs remains challenging.
• Project closure, audits and evaluations are not yet linked to accountability mechanisms. Doing so, wherever possible, would be a powerful means to promote transparency.
• Project completion reports, though designed to capture achievements and lessons, often remain internal, are inconsistently quality assured, and are seldom aggregated at portfolio level. As MOPAN assessments (see Annex B, elements 4.7.2 and 4.7.7) note, they have limited value for measuring the effectiveness of SEAH efforts or fostering institutional learning.
• Training evaluations generally track participation rates rather than impact. MOPAN found few cases where IFIs assessed whether training resulted in behavioural or cultural change (Element 4.7.4).

Some positive developments are emerging. The IDB introduced effectiveness-oriented reporting at project level (Box 6.7.) and several IFIs — ADB, AfDB, EBRD, IFAD, and the World Bank—are investing in digitalisation to improve data transparency and portfolio-level learning see (Annex B, element 5.4.5).

Ultimately, these should feed into broader learning at the institutional level.

However, institutional learning remains constrained by:

• Lack of SEAH theories of change, and of harmonised M&E frameworks to inform PSEAH, including indicators, which prevents portfolio-wide analysis.
• Weak or inconsistent data quality, as the MOPAN assessment of IDB highlighted: “weaknesses in the quality and scope of data generated by intervention-level monitoring and evaluation, the extent of data disaggregation, and changes in project objectives during execution not reflected in results matrices.
• Limited data transparency and digitalisation and continued reliance on paper-based client reporting (except for IFC). (see Annex B, element 5.4.5)
• Limited capacity and comparatively few resources for PSEAH, with many focal points double or triple-hatting, describing lesson-learning as “add-on” tasks, and many IFIs lacking specific GBV expertise.
• Uneven knowledge management structures, with only some IFIs — such as EBRD’s GBVH focal point network, the World Bank’s regional GBV focal points, or ADB’s knowledge champions (see Box 6.8 — offering hubs for learning.
• Low prioritisation of effectiveness-oriented learning by management and governing boards.

To close these gaps, IFIs could strengthen learning through portfolio reviews, thematic evaluations, peer learning, research on development effectiveness, and staff surveys with PSEAH components. Embedding these mechanisms would help shift from compliance monitoring to genuine assessment of effectiveness and impact.

Challenge 7: A shortage of PSEAH capacity and resources and the lack of capacity benchmarks result in prioritisation of only the highest-risk cases, leaving many projects underserved

Financial resources are not clearly aligned with PSEAH risk levels, limiting the effectiveness of PSEAH measures. MOPAN’s assessments found that the link between assessed SEAH risk levels and resource allocation was not consistent (See Annex B, element 4.7.3). This is the case for both types of resources needed to implement PSEAH measures -- IFI operating budgets and client allocations to cover the E&S management plans.

Severe staffing gaps and a lack of benchmarks for IFI staff resources for PSEAH and GBV undermine delivery and accountability. IFIs are not sufficiently aligning financial and human resources for SEAH and GBV to risk levels. These resources should be foreseen in the operating budget (or administrative budget), which covers the IFI’s side of E&S measures. These include risk assessment, implementation support missions, review of borrower E&S instruments, E&S safeguards monitoring, and supervision. IFIs determine the level of institutional resources needed to address risks during the project screening phase. However, assessments and interviews highlight that SEAH responsibilities are often added to already heavy environmental and social portfolios, and that GBV risk management specialists are often lacking (ADB, EBRD, IDB, IFAD). In IFC, the modest resources foreseen for PSEAH are taken from loan fees and often charged directly to a client. Where clients are unwilling to engage in PSEAH, resourcing it is also a challenge.

Limited time and funding for PSEAH focal points and expertise focused at HQ leave project supervision under-resourced. This obliges IFIs to prioritise the highest-risk cases, leaving many projects underserved. Examples abound. At IDB, just two social specialists in sexual and GBV support 330 operations. EBRD relies on junior, short-term gender leads; IFAD’s PSEAH capacity remains overstretched, with its first SEAH officer appointed only in 2024; AfDB noted it expects generalist safeguards staff to be able to oversee PSEAH measures, and its 2020 Safeguards Action Plan – while improving systems — did not meet staffing targets. The 2024 MOPAN assessment of IFC found that insufficient supervision of external GMs, for lack of qualified staff, results in low utilisation and reduced trust — a feedback loop where under-reporting reinforces under-investment. Furthermore, IFC GBV specialists are rarely able to be included in mission budget for project monitoring.

The World Bank has made attempts to address this. One component of its 2017 GBV Action plan stipulated that budget would be ensured for the additional cost associated with high GBV risks. (MOPAN, 2023d[75]) Interviewees noted that regional allocations for PSEAH issues complement E&S framework budgets at country level. The World Bank is currently developing a framework for integrating more realistic cost estimates into its operating budgets from the outset (for sovereign operations).

Within the project, PSEAH measures to execute E&S management plans or their equivalents are also often underestimated and inadequate. These measures are budgeted by the borrower and are eligible project expenditures that are an integral part of project implementation, financed through the loan/grant. They can be complemented by counterpart financing (co-financing) from the borrower and include hiring E&S specialists, costs for CoCs, GBV/SEAH training, community awareness, and survivor support. In MOPAN interviews, several IFIs emphasised that insufficient resources were allocated to these functions, which, in contexts of low capacity, could mean that severe gaps go unaddressed.

Beyond IFIs’ risk-related work, country-level GBV and PSEAH system-strengthening efforts remain under-resourced. Separate financial instruments are needed for public-sector focused IFIs to strengthen national systems for GBV prevention and response, but remain limited, unpredictable, and highly jeopardised in the current funding environment. Few of them systematically invest in the broader enabling environment — strengthening policies, legislative reforms, institutions, and community engagement. One avenue for governments is to borrow additional funds. The World Bank’s Development Policy Financing (DPF) illustrates what is possible in countries willing to borrow resources for engaging in these reforms (Box 6.9.). Although the World Bank found in its 2022 Stock Take that its clients shifted increasingly to this modality (WBG, 2022[76]), IFI interviewees for this study in 2025 report waning government willingness to borrow for GBV initiatives.

Dwindling funding for local GBV services represents a high risk to IFI risk management.  Resources are extremely scarce for victim protection and assistance. Assistance is assumed to be primarily provided locally. IFIs depend on community-based GBV organisations for prevention, capacity building and survivor care, but funding for this service rarely comes through the project cycle as IFIs do not work through direct implementation. In the case of private sector IFIs, community development efforts are largely outside scope. IFIs can, however, support country-level initiatives supported by donors, trust funds, NGOs and the UN (often UNFPA and UNICEF). The availability of concessional donor funding for GBV prevention and assistance is thus becoming even more important. Yet trust funds or bilateral grants from donors are increasingly scarce and competitive as demand for them has clearly outstripped supply. Also, they are usually short-term, and less predictable than capital for lending. This makes it difficult to implement interventions positioned to achieve transformative change.

Where leadership links resources, capacity, and accountability, progress follows — but remains uneven. The World Bank’s 2017 PSEAH/GBV Action Plan expanded specialist capacity and embedded GBV prevention within its gender strategy. IFC scaled staffing and digital systems with senior-level backing, and EBRD’s gender strategy review offers an opportunity to strengthen PSEAH resourcing. Sustained progress will require risk-based budgeting, benchmarks for SEAH and GBV staffing and training and long-term financing instruments that build national capacity for GBV prevention and survivor support. Without these, IFIs will remain compliance-focused rather than effectiveness-driven in advancing the PSEAH agenda.

Shortage of capacities for internal SEAH

Capacity gaps exist also in the structures designed to address internal SEAH, which vary widely across IFIs. The World Bank has a dedicated unit for preventing and addressing SEAH and discrimination internally. Led by a manager, it comprises 12 staff, including 2 in country offices. In contrast, MOPAN’s assessment of IFAD found no dedicated time or budget for PSEAH; its ethics office uses much of its administrative budget for awareness materials. Only in 2024–25 did IFAD appoint an ethics officer with SEAH responsibilities, expand its team to four, and increase its budget, though capacity remains stretched to deliver interventions at the project level. AfDB’s 2020 Safeguards Action Plan achieved many objectives, but staffing and budget targets set by the board remain unmet.

Challenge 8: Grievance mechanisms lack shared quality benchmarks

In line with good practice, IFIs typically have multiple channels for victim-survivors to report incidents and seek assistance. Accordingly, they have scored relatively well on this indicator in the MOPAN Assessment (see Annex B, element 4.7.3). However, several IFIs noted in interviews that the low number of reports received might reflect not only cultural barriers,⁴⁹ but also weaknesses within the channels themselves. While MOPAN did not speak directly with communities, IFI good practice and interviews suggest that effective GMs require more than multiple entry points. A strong GM is well known, quality assured, locally anchored, and provides coordinated, survivor-centred follow-up pathways.⁵⁰ These attributes are critical for encouraging reporting and require further collective effort.

The absence of shared quality benchmarks results in inconsistent standards and effectiveness. Good SEAH-related grievance mechanisms should be accessible, confidential, trusted, survivor-centred, and functional in local languages, yet IFIs have not agreed on minimum standards. Without shared benchmarks, supervision and comparability remain uneven across institutions.

Weak quality assurance limits the credibility and functionality of GMs for SEAH. IFIs often verify only the existence of GMs rather than their performance or quality (including on PSEAH), citing capacity constraints.⁵¹ ADB’s independent evaluation in 2021 discovered through an evaluation that only 66% of programmes had established a functional GRM. In many cases, GRMs were created, but not accessible, poorly functioning, or ineffective in resolving complaints (ADB IED, 2021[78]).⁵²

Some positive developments exist. ADB’s 2023 policy now mandates survivor-centric mechanisms with SEAH-specific case handling IDB has begun monitoring GM usage across channels. The World Bank introduced SEAH-specific requirements for GMs in its template ESCP, including for GMs to be equipped to receive, register, and facilitate the resolution of SEA/SH complaints, including through the referral of survivors to relevant GBV service providers, all in a safe, confidential, and survivor-centred manner. However, data remains largely non-disaggregated and under-reporting persists. Interviewees stressed that a lack of complaints should itself trigger concern about accessibility or trust.

Few GMs are fully equipped with SEAH-specific capacity. While the IFIs require GMs for all projects regardless of risk classification, only a few have integrated provisions for handling SEAH.⁵³ The World Bank’s E&S Incident Response Toolkit provide templates and examples for project-level SEAH incident reporting, and guidance for monitoring these cases until closure and escalating them to senior management. IDB provides guidance on Standard 9 that states GMs must adapt the GM for SGBV, link the GM to an intermediary that can handle such complaints, or create an independent GM for SGBV by outsourcing to a third party.⁵⁴ IFC’s toolkit supports private sector clients in developing and managing community-based grievance and feedback mechanisms.⁵⁵ ADB’s latest policy includes SEAH-specific guidance for integrating reporting and case handling into project GMs (ADB, 2023e[79]). IDB’s research confirms that strong SEAH grievance systems improve project sustainability. Nonetheless, data gaps and persistent underreporting make effectiveness difficult to gauge.

Local capacity constraints undermine the credibility and survivor-centred nature of grievance systems. All IFIs report that clients struggle with staffing, skills, and resource challenges in operating GMs effectively. EBRD identified major systemic weaknesses among clients in Turkey and Uzbekistan and shifted towards capacity building. The ADB’s Good Practice Note for GRMs in projects with civil works⁵⁶, and a separate GPN for ADB’s private sector operations provide guidance to strengthen client implementation.⁵⁷ Training is another core investment in local capacity. The World Bank, IFC, IDB, ERDB and ADB all invest in training clients to share knowledge and tools so they can respond to complaints on their own. The reach of training varies. World Bank, IFAD, ADB, and IFC requirements of implementing partner training appear more standardised while AfDB, EBRD, and IDB partner training appears more project-specific, risk-based, or advisory in nature. IFC has put in place a new capacity building component since the last MOPAN Assessment.

It would seem from all these initiatives and requirements that there is a large, untapped potential for IFIs to agree on minimum requirements for the capacity of GMs (including basic psychosocial first aid training). There is also an opportunity to lend joint support to strengthen such mechanisms that form part of the country’s own system at the sector level, such as GBV hotlines and reporting mechanisms by line ministries.

Referral pathways are an essential but underdeveloped element of survivor support. Survivors require access to psychosocial, health, and legal services, and GMs should serve as coordinated entry points. IFC and the World Bank require clients to map local services and develop a referral pathway and IFC is building a roster of regional GBV and child protection consultants for private sector companies to draw on. Efforts are also underway to develop a shared template to map existing GBV services. Mapping pathways requires specialised skills. Interviewees noted that pathways are not only often mapped inconsistently, but sometimes also in ways that create harm, as when unqualified staff disclose service providers that should not be publicly advertised for reasons of survivor protection, thereby putting victim-survivors at risk.

However, interviewees noted that while project-related GMs are typically financed by projects, the sustainable financing of community-based GMs and the local support services they rely on remains unresolved. In practice, project GMs often refer complainants to local providers that depend on underfunded civil society organisations – described by some interviewees as “extractive reliance”. Clients are sometimes expected to resource such gaps in local PSEAH capacity. The World Bank, for example, expects clients in higher-risk projects to allocate resources to fill gaps in existing medical, psychosocial and legal support services, helping strengthen in-country systems for GBV survivor assistance. It also often mobilises women’s organisations or other NGOs to provide technical assistance to clients for discrete PSEAH actions (such as training, community awareness). Such partnerships are critical to put community-based complaint mechanisms in place that are accessible, trusted and survivor-centred. In practice, however, interviewees noted that resources invested are not sufficient to ensure that local support services are capacitated.

Making them viable would require IFIs, clients and executing agencies to jointly identify gaps and advocate for greater support. They could, for instance, reinforce UN efforts to establish CBCMs, support training of local investigators,⁵⁸ and equip local gender and social organisational to handle SEAH/GBV cases.

Remedial action beyond GMs is coming into focus.  IFC and MIGA are piloting an interim approach for structured responses to harm resulting from environmental and social impacts, signalling a potential evolution in accountability practice.⁵⁹ It states that IFC/MIGA are not the guarantors of “E&S outcomes or remedial action nor can they act as insurers for costs related to remedial action for project related harm” but recognises IFC/MIGA’s role in the broader remedial action ecosystem, noting that IFC/MIGA may contribute to remedial action through “(a) financial, contractual and/or relationship influence with clients and other responsible parties; and (b) enabling activities, including fact-finding, technical assistance, capacity building and/or community development activities” . Although current discourse about remedial action often focuses on financial remedies, the concept is much broader, as OHCHR pointed out in its comments and recommendations feeding into the update of the AfDB’s Integrated Safeguard System:  it encompasses “not only compensation […], but also restitution, rehabilitation, satisfaction […], and guarantees of non-repetition (including policy changes to prevent recurrence).”⁶⁰

Challenge 9: Challenges in adopting a victim-survivor-centred approach

Victim-survivor-centred approaches (VCAs) remain the weakest element of PSEAH performance across IFIs. Across IFIs, VCAs scored the lowest of all PSEAH dimensions assessed by MOPAN (See Annex B, element 4.7.8). Since 2018, most IFIs have introduced victim-survivor-centred language in policies and strategies and issued guidance notes for borrowers emphasising confidential referrals, informed consent, and codes of conduct prohibiting SEAH. The World Bank, notably, built GBV task force recommendations, a GBV action plan and GPNs on this principle (Box 6.11). However, implementation remains uneven and accountability to victim-survivors weak.

Several IFIs have introduced structures to operationalise victim-survivor-centred responses. The World Bank has appointed regional and GBV focal points to manage complaints and provide support to clients and project teams managing complaints. IFC established a stakeholder grievance response team. IFAD trained investigators to interview vulnerable victim-survivors. ADB mobilised financing for case management, and several IFIs trained investigators to interview vulnerable victim-survivors. The IASC Investigators Manual for a victim-centred approach to investigations of SEA, as well as available training constitute a valuable source for such efforts.⁶¹ Collectively, these initiatives signal that IFIs are beginning to embed victim-survivor-centred responses in safeguards and operations.

Legal and operational frameworks still lack consistent victim-survivor provisions. Despite progress, VCAs are not systematically integrated into legal standards or E&S frameworks. Referral pathways remain unmapped, and quality support services may be unavailable, with no consolidated requirements to fill the gaps, at least in higher risk investments. AfDB and ADB noted these issues. Oversight is limited by scarce specialist staff at HQ and country levels, making effectiveness reliant on implementing agencies. Victim-survivors are often called “beneficiaries” rather than rights-holders, diluting accountability across institutional layers. Some IFIs escalate incidents without adequate follow-up, exacerbating harm instead of providing survivor-centred protection.

Weak reporting and limited trust hinder effective institutional learning. Reporting systems across IFIs, implementing agencies, partners and clients remain inconsistent and underused. Although they remain responsive to survivor needs, inconsistency and low uptake are also shaped by wider systemic barriers to reporting. Some partners and clients avoid disclosure for reputational reasons, and project-level GMs are not always trusted. As a result, victim-survivors may bypass formal channels or raise complaints informally during IFI visits, reducing both transparency and institutional learning.

Strengthening VCAs requires investment in capacity and accountability at project level. Addressing these gaps demands stronger project-level understanding of what a survivor-centred response entails at project level and how to operationalise it. Borrowers/clients must be able to map referral pathways and ensure access to safe, trusted services based on informed consent and the existence of appropriate procedures, and that access is being managed by the client with the IFI’s institutional oversight. Greater investment in local capacity and service providers is critical, alongside clearer accountability structures to ensure survivors receive follow-up and remedies.

IFIs must adapt VCAs to low-capacity contexts without assuming direct case management. Given that many projects operate in places where protection services are weak, IFIs must guide teams on how to apply victim-survivor-centred principles even in low-capacity environments. Institutions should refrain from managing cases directly, focusing instead on capacitating clients. Some IFIs still rely on senior managers rather than trained experts to interact with victim-survivors, thereby escalating cases and weakening trust.

Embedding VCAs in operational safeguards and accountability systems is essential to rebuild trust. To align commitments with practice, IFIs should integrate VCAs firmly in their own internal processes (such as investigations), as well as in operations (through their safeguards mechanisms) so that follow-up responsibilities, sanctions and remedial mechanisms are clear. Clear documentation of response pathways and responsibilities would help rebuild victim-survivor trust and reinforce institutional credibility.

Victim-survivor-centred practices for internal sexual misconduct

IFIs have developed internal victim-survivor-centred approaches but apply them unevenly. Within IFIs, victim-survivor-centred approaches to internal sexual misconduct combine formal and informal mechanisms to ensure safety, confidentiality, and agency. Ethics or conduct offices usually serve as intake points, supported by human resources, ombudspersons and staff networks that provide confidential advice. Most IFIs now maintain clear reporting channels, whistleblower protections, interim protection measures, counselling, alongside informal resolution options and workplace culture surveys.

Oversight and protection mechanisms remain inconsistent across institutions. While oversight typically rests with ethics or integrity offices, mandates and autonomy vary, and protections are unevenly applied. Trust deficits persist. In some IFIs, mandatory reporting rules compel disclosure without victim-survivor consent while in others, fear of reputational harm or light disciplinary action discourages reporting. Protective measures such as temporary suspension or relocation are available but often delayed by bureaucracy.

Awareness and support initiatives are helping to rebuild institutional trust. Several IFIs are taking steps to strengthen internal trust and encourage reporting. IDB has embedded prevention staff in regional offices to offer accessible support. EBRD analyses consensual intimate workplace relationships from the lens of conflict disclosure to prevent power imbalances and harassment risks. ADB provided assistance to staff who were facing domestic violence during COVID-19. Interview evidence shows that some IFIs have revised policies to encourage reporting without penalising non-reporting and to prioritise strong support for those who come forward. Across IFIs, an increase in reported complaints is seen both as evidence of persistent challenges and of growing confidence in institutional systems.

Challenge 10: IFIs are not yet leveraging the strengths and innovation of the private sector to advance PSEAH

IFIs have yet to fully leverage the private sector’s potential to strengthen prevention and accountability. As major employers and community actors and drivers of economic development, private companies, are well positioned to influence national standards and promote a culture of prevention. They can be powerful allies in advancing PSEAH, including with local governments. IFC, for instance, considers that the daily interaction of its partners with workers, service providers, and subnational governments makes them influential advocates and community anchors for safer childcare, safer transport, and tourism. These are pressures that can spur public authorities to act yet this potential remains largely underused and could be mobilised more deliberately, as a recent example from IFC in Brazil illustrates (Box 6.12).

There is an even greater potential for influence where IFIs operate through financial market structures rather than directly with project implementers. Among the seven IFIs in our sample, ADB, AfDB, EBRD, IDB and IFC reported working through commercial banks, private equity funds, and microfinance institutions. Such financial intermediaries provide unique opportunities to embed PSEAH in enterprises and influence market behaviour, resembling efforts to curb fossil fuel investments. A comparable multiplier effect exists for cooperatives, a model that IFAD uses. As IFAD expands its engagement with small cooperatives, integrating PSEAH into agreements and practice could significantly deepen its impact on GBVH and SEAH.

However, financial intermediary structures are not yet fulfilling their role as multipliers. IFIs noted that the increased distance from the investments made by financial intermediaries and the fact that the recipients of such investments are not clients of the IFI essentially curtails oversight of safeguard implementation in sub-project funding. Thus, there are direct limitations on what an IFI can do. The only real leverage is with the FI client itself, not its investees. This means that there is no compliance obligation for PSEAH in financial intermediary investments. This also makes PSEAH compliance harder to monitor. The MOPAN assessment of EBRD noted, for instance, that EBRD’s limited reach of risk requirements in FI portfolios undermined consistency across operations. Without solid monitoring, compliance assurance, and capacity building for addressing GBV in the private sector, these challenges will persist. Weak environmental and social management systems and inconsistent grievance mechanisms were mentioned. As of 2025, EBRD and IFC reported that they were jointly developing cross-sector guidance on financial intermediaries to learn from each other and avoid duplication — an area where PSEAH practice is still nascent.

This points to a broader challenge. The public and private sector arms of IFIs are not yet promoting PSEAH jointly as a single institution. For the private sector to address GBV, including SEAH, partner countries’ legal systems need frameworks and incentives making addressing GBV norms a legal requirement — norms that would also benefit companies working with IFIs’ borrowers on sovereign projects.

IFIs have not developed overarching guidance linking their public and private sector PSEAH work or clarifying how these operations complement each other (see Challenge 4: IFIs are not working through a “whole-of-institution” vision for PSEAH). IFIs working with the private sector cited a “translation problem”: strategy and guidance remain framed for sovereign borrowers and have not been contextualised to private-sector realities. Most IFIs struggle to adapt public-sector safeguards to private operations, leaving financial intermediaries and private firms without adequate instruments. The WBG’s new gender strategy, for example, focuses on social norms and public systems but does not harness private-sector advantages. Moreover, legal covenants are difficult to adapt consistently across private sector instruments and financial products — often targeting banks, private equity funds, and insurance products — resulting in uneven application and inconsistent risk coverage.

The lack of coherence between public and private sector work remains a major concern, suggesting that progress has been too slow. Many private sector actors including both public and private sector arms of IFIs, are linked into public-sector PSEAH commitments through mechanisms such as London Summit commitments, the CSSG, and CAPSEAH. However, no dedicated forum for PSEAH exists yet in international private sector or FI operations beyond the MFI SEAH Working Group. This points to a greater challenge: public and private sector parts of IFIs are not yet promoting PSEAH jointly. While the protection of people is a state prerogative and public and private sector IFIs and their clients operate under different mandate structures, SEAH risks cut across both spheres. These distinctions do not diminish the importance of private-sector engagement or the need for public and private arms of IFIs to contribute actively to PSEAH. However, they underline that their roles, potential, and obligations are complementary.

Guidance notes have been developed to bridge this gap. IFC’s Performance Standards on Environmental and Social Sustainability are a significant driver that could be harnessed for PSEAH (the recent reorganisation to integrate World Bank Group E&S teams may facilitate this). Through contractually binding standards in loan and equity agreements, IFC has set a benchmark widely adopted by private companies, even beyond IFC-funded investments. The refresh of the IFC performance standards to explicitly cover SEAH is therefore a promising initiative with broad reach. Other banks have highlighted in interviews that they have aligned their frameworks with these standards (IDB-Invest, for instance, uses IFC performance standards for private sector work, rather than IDB’s ESPF). The IFI Performance Standards extend beyond development finance through the Equator Principles. Adopted by over 130 commercial banks worldwide, this framework requires borrowers to align with IFC’s standards. The principles thus cascade PSEAH into private-sector projects beyond IFC’s own portfolio and beyond IFIs and are a potential link to larger markets.

IFC standards have become a de facto benchmark but do not yet ensure effective survivor-centred practice, as monitoring and supervision vary widely. Implementation often remains procedural rather than outcome-driven, and firms lack guidance on engaging with civil society, limiting integration of community-based survivor support. Applying these standards consistently and clarifying links with the public sector and civil society could help transform market norms.

Co-investment arrangements in which IFIs are part of a consortium add complexity, as seen with IFC’s Bridge project case, in which IFC was a minor investor amongst several investors. In such arrangements, IFIs may still carry SEAH risk exposure even with small stakes.