Did the World Bank and IDB address civil society’s concerns in their Full Mutual Reliance Framework?

In July 2026, the World Bank (WB) and the Inter-American Development Bank (IDB) approved their Full Mutual Reliance Framework (FMRF), a new co-financing model for Latin America and the Caribbean. Under the framework, one institution serves as “Lead Lender” and applies its environmental, social, access to information, procurement, and accountability policies throughout the project cycle, while the other acts as “Trail Lender” and relies on those standards instead of applying its own. The arrangement builds on the first such framework, signed between the World Bank and the Asian Development Bank (ADB) in February 2025. 

Before Board approval, BIC and partner organizations from across Latin America and the Caribbean submitted recommendations warning that the framework could weaken protections for project-affected communities. After comparing our recommendations with the approved text, we found that many core concerns remain unaddressed, while key implementation details have been deferred to future guidance. Because communities affected by co-financed projects may interact only with the Lead Lender’s safeguards and accountability mechanism, the framework has important implications for access to environmental and social protections. As the FMRF is expected to serve as a model for future mutual reliance agreements among multilateral development banks, the remaining gaps extend beyond this single framework.

1. Consultation remained inadequate. Stakeholders were invited to three meetings that included presentations, Q&As, and summaries, but were never given the opportunity to review or comment on the draft framework itself. This repeats the approach used for the WB-ADB FMRF. Future frameworks should release draft texts for public comment and explain how stakeholder feedback influenced the final text.
2. Environmental and social alignment was not independently assessed. We recommended an independent, public, standard-by-standard comparison of the IDB’s Environmental and Social Policy Framework (ESPF) and the World Bank’s Environmental and Social Framework (ESF). Instead, the assessment was conducted internally by World Bank and IDB staff. The institutions’ identified four areas where their policies diverge — minimum age of employment, biodiversity offsets in critical habitats, Indigenous land titling, and disputed areas — are excluded from FMRF financing altogether. While this is a positive step,, it remains unclear how those exclusions will apply in practice.
3. Stronger protections against reprisals were not preserved. Annex B recognizes that the IDB has a formal definition of reprisals and an institutional obligation to respond, while the World Bank relies on a public commitment without an equivalent definition. Nevertheless, the framework concludes that the two approaches are sufficiently similar. As a result, the IDB’s stronger protections, including safeguards against judicial harassment and Strategic Lawsuit Against Public Participation (SLAPP), do not apply when the World Bank serves as Lead Lender, despite the high risks faced by environmental defenders across the region.
4. Access to accountability mechanisms remains limited. Communities may access only the Lead Lender’s independent accountability mechanism (IAM). Complaints submitted to the Trail Lender are forwarded to the Lead Lender. Although the framework recognizes that the IDB’s MICI offers broader eligibility criteria and access to dispute resolution, it concludes these differences are unlikely to affect outcomes. But because the World Bank’s Inspection Panel and Dispute Resolution Service apply stricter eligibility requirements, project-affected people may have fewer avenues to accountability whenever the World Bank serves as Lead Lender. Although the Trail Lender’s IAM may participate as an observer role its role is limited to attending missions and receiving information, without any decision-making authority.
5. The Trail Lender still lacks meaningful oversight. The framework does not allow the Trail Lender to raise concerns and require corrective action when significant issues arise. Once implementation begins, responsibility for monitoring borrower compliance rests solely with the Lead Lender. The Trail Lender’s role is limited to receiving updates and participating in missions.
6. Pilot evaluation measures efficiency over E&S outcomes, with no plan to engage civil society. The evaluation of the four-year pilot phase still centers on indicators that track operational efficiency, average processing time, client satisfaction, and staff perceptions of knowledge sharing. Not one indicator measures environmental or social outcomes, complaints filed or resolved, or the quality of engagement with affected communities. Although the institutions suggest that E&S indicators may be added later, the pilot could still be considered successful even if E&S protections and accountability weaken in practice. 
7. Key implementation details remain unsolved. Many of the framework’s most important operational arrangements, including coordination between the institutions, cooperation between their accountability mechanisms, governance of the pilot, and final monitoring indicators, remain unresolved and will be developed in the next coming months. No public timeline or formal role for civil society has been established. Our recommendation for a civil society engagement roadmap was not adopted.

In contrast, one provision that reflects CSOs input is the provision relating to procurement. Universal procurement eligibility will apply regardless of which institution serves as Lead Lender, allowing firms from any country to compete. The framework also applies the World Bank’s disqualification rules for firms found responsible for sexual exploitation, abuse, and harassment across all FMRF projects. These provisions represent a meaningful strengthening of the procurement framework.

Over the four-year pilot, BIC and partners will monitor implementation of the framework, including Lead Lender designations, environmental and social oversight, and access to accountability mechanisms. We will continue engaging both institutions to strengthen the framework before these gaps translate into weaker protections for project-affected communities.

Read our full comments and recommendations to the IDB and World Bank Boards here, as well as the briefer submitted to the Boards here.