PSEAH in IFIs: Progress, Gaps and the Road Ahead

IFIs have made meaningful progress in protecting from SEAH in several areas.

They have strengthened their policy architecture and are embedding PSEAH in a maturing, risk-based approach. Most IFIs have integrated PSEAH into their operational policies and systems, most clearly through E&S frameworks. The broader E&S architecture — risk screening, project design, due diligence and supervision — provides a consistent foundation for PSEAH as it integrates SEAH considerations into established operational systems. That said, PSEAH is embedded in E&S frameworks with variable depth and enforceability. IFAD is the only IFI with a dedicated, institution-wide PSEAH policy. The policy is soon to receive Board-approved status and embeds PSEAH in E&S standards, codes of conduct, and gender strategies.  Other IFIs rely only on these instruments, using each to cover just a part of their work. Still others, such as the IFC and the World Bank, rely on guidance based on good practice rather than making explicit E&S prohibitions.¹

PSEAH guidance and operational tools for PSEAH are gradually converging. IFIs have developed a growing body of technical guidance and notes on good practice that help translate policy ambitions into operational action. New guidance across sectors including major civil works, agribusiness, transport, as well as human development, provides project implementation units and clients with clearer expectations for prevention, mitigation and response. IFIs are increasingly co-developing guidance. This expanding toolbox has improved operational consistency and supports staff in applying SEAH considerations more systematically across diverse project contexts.

Co-operation among IFIs is expanding at both normative and operational levels as the interpretation of SEAH-related requirements converges gradually. Led in part by the MFI SEAH Working Group, institutions are relying increasingly on shared standards and joint guidance, driving greater alignment and clearer expectations for clients and staff. Operational co‑operation on PSEAH is also taking shape. Such early steps towards mutual reliance arrangements in co-financed projects makes it possible for IFIs to draw on one another’s assessments or procedures. While these efforts remain limited, they do reduce duplication, support more coherent supervision, and highlight the value of further harmonising standards to strengthen collective influence and reduce the fragmentation of PSEAH expectations across jointly financed operations.

The study highlights the strategic and operational challenges. Together, they point to a need for clearer institutional vision, stronger resourcing, and more consistent accountability in applying the PSEAH principles.

Strategic and Systemic challenges

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

Global PSEAH benchmarks and expectations have advanced since the 2018 joint IFI commitment, especially with the Common Approach to Protection from Sexual Exploitation, Sexual Abuse and Sexual Harassment (CAPSEAH). However, IFIs have not updated their collective pledge. While the original commitment spurred substantial guidance, tools and good-practice notes, most of these remain voluntary and practice varies widely. Partner countries and clients face different requirements as a result. IFIs run into obstacles to cooperating in operations, which limits their ability to influence national systems. Shareholders and practitioners call increasingly for harmonised minimum standards to boost coherence and collective impact.

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

IFI-UN collaboration remains under-developed normatively and operationally. IFIs and the UN system have complementary mandates and strengths in addressing SEAH which they could harness better through stronger collaboration. The impact of such a collective approach could be greater than the sum of its parts. But in practice, IFIs and UN agencies have not yet aligned with a common, system-wide framework, nor do they often conduct joint diagnostics or reinforce each other’s engagement with governments. This limits their collective leverage to develop shared minimum standards and collaborate in-country. They also miss opportunities to coordinate prevention and survivor assistance which weakens collective leverage and reduces the sustainability and reach of GBV/PSEAH outcomes.

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

IFIs lack whole-of-institution strategies for PSEAH. Only IFAD has a board-approved, organisation-wide vision that coherently links operational risk management, country engagement and internal systems. Such a whole-of-institution policy is pivotal for elevating PSEAH strategically. Without it, efforts tend to be fragmented, leadership signals uneven, and action often skewed toward compliance rather than transformational change. Without an overarching institutional vision to locate SEAH among broader development challenges, it is seldom integrated into high-level country or regional industry sector strategies. Early alignment opportunities in project planning are under-used and policy-focused work often relies on separate funding streams that constrain uptake.

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

Strategic vision and leadership vary significantly across IFIs. Strong senior-level direction is a key enabler of effective PSEAH practice. Inconsistent prioritisation and follow-through weaken the collective capacity to elevate PSEAH as a strategic issue. Such unevenness also affects resource allocation. Where leadership signals are weak, PSEAH is less likely to receive dedicated staffing, sustained funding, or the institutional visibility needed to support its effective implementation. These strategic and systemic challenges translate into persistent operational gaps that limit consistent implementing, monitoring and enforcing PSEAH commitments across IFI portfolios.

Operational challenges

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

Public reporting on PSEAH measures and incidents remains insufficiently transparent. Joint reporting after the 2018 commitment has ended; IFIs have no collective platform to demonstrate progress. No IFI publishes consolidated reporting on PSEAH implementation internally and in operations. Case reporting remains sparse and inconsistent compared to established mandatory practices across the UN system. These gaps reflect a lack of policy on reporting, limited supervisory rigour, weak digital tools for portfolio-wide tracking, uneven data systems and limited incentives. These all make it harder to build trust, strengthen learning and demonstrate institutional improvement.

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

This weak feedback loop reinforces a compliance-heavy approach rather than a focus on effectiveness. PSEAH measures are often applied as procedural safeguards rather than as tools for development impact, encouraging routines focused on documentation rather than outcomes. PSEAH therefore remains unevenly embedded across operations, constraining prevention and limiting adaptive decision-making and continuous improvement.

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

Insufficient institutional capacity further compounds implementation gaps. Evidence points to shortages of dedicated staff, gaps in specialist PSEAH expertise, and the absence of benchmarks for minimum capacity. These shortfalls affect supervision, borrower support and institutional learning, and they push IFIs to prioritise only the highest-risk cases, leaving many projects underserved.

Challenge 8: Grievance mechanisms lack shared quality benchmarks

Grievance mechanisms in operations make capacity constraints quite visible; their quality varies and they lack shared benchmarks. All IFIs maintain grievance channels, but accessibility and survivor-centred orientation differ significantly and gaps in referral pathways can expose complainants to harm. Inconsistent monitoring of usage data further limits opportunities to improve performance, while the absence of joint minimum requirements creates uneven expectations for clients and reduces coherence in handling SEAH-related complaints.

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

Victim-centred approaches (VCAs) remain IFIs’ weakest PSEAH area: implementation is uneven, accountability to survivors weak, and expertise scarce. Referral pathways are often unmapped and services limited; reporting is inconsistent and underused. Inadequate follow-up can compound harm, erode trust and constrain institutional learning, especially in low-capacity contexts.

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

The possibility for IFIs to collectively leverage their potential for change regarding PSEAH through private-sector operations has not yet been fully realised. The private-sector arms of several IFIs have developed PSEAH guidance for companies in higher-risk sectors such as major civil works, transport, agribusiness, hotels and manufacturing. However, due diligence, supervision and monitoring remain uneven — particularly where financial intermediaries are involved — and public and private-sector arms do not reinforce one another consistently. These gaps reduce coherence across portfolios and weaken IFIs’ ability to use private-sector leverage to strengthen outcomes.

Taken together, the evidence suggests that after significant progress over the past years, the moment has come for IFIs to re-align with international efforts on PSEAH. Unless they adopt an institution-wide approach, harmonise their standards among each other, and align with a broader, system-wide vision, they risk losing their hard-won gains. Without a stronger vision and adequate investment, they are also missing opportunities to collectively advance towards an effective, preventive PSEAH ecosystem.

The study makes recommendations that are relevant to Leadership, Senior Management of IFIs as well as board members, shareholders and donors. It highlights future directions that — if elevated and resourced strategically — could significantly strengthen system-wide PSEAH performance.

Strategic and Systemic recommendations

Recommendation 1: Renew IFIs’ joint commitment on PSEAH, aligning with CAPSEAH, the most recent international PSEAH framework

This will allow IFIs to move toward normative convergence. Develop and endorse shared minimum standards and expectations to reduce fragmentation and strengthen collective influence with partner countries.

Recommendation 2: Deepen collaboration across the IFIs, the UN, and other partners

Deepen IFI collaboration and expand coordinated in-country engagement with UN agencies. Leverage comparative strengths through joint diagnostics, harmonised standards / indicators, shared tools and reporting, and mutual-reliance to cut duplication. Pool resources for survivor services and use vetted misconduct-disclosure mechanisms to prevent rehiring.

Recommendation 3: Build an institution-wide vision for protecting from SEAH

Mandate board‑approved institution-wide strategies that integrate internal systems, country or industry sector engagement and operational risk management into a single, coherent framework.

Recommendation 4: Strengthen leadership for PSEAH

Strengthen senior leadership and accountability by ensuring visible leadership signals, clear responsibilities and adequate institutional prioritisation to drive resourcing and follow‑through.

Operational recommendations

Recommendation 5: Increase transparency and accountability in reporting

Introduce joint IFI reporting on PSEAH implementation, as well as consolidated reporting at the level of each IFI. Increase institution‑wide transparency and reporting systems based on consistent monitoring that is facilitated by digital tools.

Recommendation 6: Complement the compliance approach with measuring effectiveness and learning

Measure the effectiveness of PSEAH efforts internally and at country level. Introduce indicators measuring outcomes and use evaluations, audits and learning loops to assess and improve the impact of PSEAH measures.

Recommendation 7: Ensure that institutional capacity for PSEAH reflects the scale of risk, and ensure predictable funding and institutional capacity for portfolio-wide GBV/PSEAH action

Establish minimum institutional capacity benchmarks. Define staffing, skills and resource expectations for the entire institution. Ensure predictable funding for supervising and supporting PSEAH implementation.

Recommendation 8: Adopt shared minimum requirements for grievance mechanisms

Harmonise standards for accessibility, survivor‑centredness and referral pathways to ensure adequate, effective assistance to victims.

Recommendation 9: Define and build survivor-centred approaches

Embed VCAs in safeguards, legal agreements and supervision, with clear roles and timely follow-up. Ensure mapped, quality-assured referral pathways and trained SEAH/GBV expertise at points of contact.

Recommendation 10: Leverage private‑sector operations strategically to reinforce uptake of PSEAH standards

Align expectations across public and private‑sector arms within IFIs, strengthen the supervision of financial intermediaries and use private‑sector influence to strengthen PSEAH.

Recognising that SEAH risks harming individuals, programmes, investments, and the trust in institutions, IFIs and member states cannot afford to let PSEAH investments erode at this crucial moment of heightened pressure on development finance. Robust PSEAH systems are fundamental for IFIs to uphold the highest standards of accountability, integrity and transparent risk management, and to continue to be trusted partners for member countries and communities. In this context, building the right policies, systems and expertise to prevent SEAH is a sound investment that far outweighs the costs and harms it can cause. IFIs’ credibility, and the trust of member states, partners and communities, hinges on demonstrating that they can prevent harm, support survivors and uphold the integrity of development investments.

The strategic opportunities identified in this study offer a pathway to consolidate progress, reduce institutional risk, and ensure IFIs fully leverage their financial and operational influence to safeguard the dignity and rights of all people affected by the operations they finance.