ADB Energy Policy Review 2025: A Rushed and Regressive Detour, Locking Asia and the Pacific into Decades of Fossil Fuel & False Solutions

Forum Network Statement on ADB Energy Policy Review 2025 

The Asian Development Bank’s  2025 Energy Policy Review is unfolding as a rushed, opaque, and dangerous process. Mandated as a midterm review of the 2021 Energy Policy, this process has veered alarmingly off course. Despite its far-reaching implications, the EPR is being accelerated for internal convenience and a tickbox exercise rather than for public interest.

As cited in the previous statements by the Forum Network, we pointed out the critical changes made by the Bank in terms of the review timeline: from the initial Q4 2025/Q1 2026 schedule to a September 2025 deadline for the release of the final revised policy and consequent board approval. This shortened schedule leaves civil society and frontline communities with little time to meaningfully engage and be afforded a concrete consultation process. On top of this, it was after the July 22 CSO Briefing when CSOs were given a mere two weeks to comment. The solidarity of different organizations definitely pushed the Bank to extend it until August 28, 2025. Transparency and delayed release of relevant documents to the public domain violate both the spirit and letter of ADB’s own Access to Information Policy. Although Phase 1 of the review process began in early 2025, ADB only disclosed key documents on July 30, highlighting a serious delay in transparency and exposing a deliberate strategy to limit scrutiny. 

More troubling are the proposed amendments themselves. It is clear that ADB is regressing from the intention of the update to assess whether it is truly supporting a just and low-carbon transition, manifested in the dangerous provisions will be injected into its existing energy policy. 

Among the new areas of concern is the proposed removal of the ban on nuclear energy financing. According to the Bank, they will support developing member countries (DMCs) to bolster their capacities for nuclear energy if it is a part of their national energy plan. We strongly condemn this move by the ADB that recognizes nuclear as a viable option for decarbonization. This blatantly disregards the enormous financial risks, environmental and human rights concerns, and the unaffordable burden it places on DMCs. Nuclear infrastructures are among the most expensive and time-consuming energy investments, often plagued by massive cost overruns, delays, and unresolved issues of radioactive waste disposal. The Bataan Nuclear Power Plant is a cautionary tale to this. Completed in the 1980s but mothballed due to safety concerns and the project cost a soaring $2.3 billion. For decades of non-operation, it continues to incur maintenance costs while producing no electricity, and posing ongoing threats of contamination and seismic vulnerability in a geologically active region. New technologies like the Small Modular Reactors (SMRs), despite being marketed as faster, cheaper, and safer, continue to face severe challenges such as project cancellations due to ballooning costs even before the it is built. UN Report also revealed that wind and solar PVs are much cheaper and faster to deploy than nuclear energy. Continuing this would only bring developing countries to bear burdens, with public funds locked into high-risk technologies at the expense of truly sustainable and community-centered alternatives.

Moreover, ADB pushes to mainstream Critical Minerals for Clean Energy Technologies (CM2CET), despite widespread documentation of the extractive violence, environmental damage, and Indigenous rights violations associated with mining operations. The ADB’s alignment with the World Bank’s Climate-Smart Mining (CSM) Framework and its subsequent development of the CM2CET approach signal mining as essential to the ‘clean energy’ transition it wanted to achieve. However, this model replicates a long-standing pattern of green extractivism, where the burdens of the global energy shift fall on resource-rich, often impoverished nations in the Global South. With countries like Mongolia, Indonesia, the Philippines, and Kazakhstan identified as critical mineral hubs, ADB’s approach risks turning these nations into sacrificial zones, bearing the environmental and social costs of global clean energy ambitions. This ‘comeback’ of ADB to the extractive sector is an attempt to bury its troubled legacy, particularly the Marcopper Mines in the Philippines – among the country’s worst environmental catastrophes, destroying communities’ source of life. Such harm must not be repeated in the name of the energy transition. Its own version of circular economy falsely pins our hopes on offsetting the impacts of mining with harmful recycling technologies.  iWithout strong human rights protections and genuine local participation, venturing out to critical minerals mining risks deepening inequality and ecological harm, reinventing it as ‘green’.

The review process also covers the proposal to articulate the expansion of the Energy Transition Mechanism to include oil and gas. Forum constantly raised concerns over the structural flaws of this coal retirement scheme. By incentivizing coal plant operators without requiring binding commitments to just transition, reparations, or community participation, the ETM effectively rewards polluters while sidelining those most affected. Rather than ensuring permanent plant closures, it promotes refurbishing of plants with fuel switching technologies, all while operating with minimal transparency. Worse, its reliance on debt-financing places an unjust burden on the public, turning ‘decarbonization’ into a costly liability for communities without delivering equitable climate outcomes. To date, there has been no successful ETM pilot showing how deep the existing issues are. Expanding the scope of this mechanism to fossil gas and oil, without overhauling its structure, it risks becoming a fossil fuel bailout scheme and a refinancing tool for the same industry, undermining both ADB’s credibility and the very notion of a just, equitable energy transition.

The proposed amendments also include co-firing in coal and gas plants as an emission reduction scheme. We strongly oppose retrofitting fossil fuel plants with ammonia, biofuels, and hydrogen co-firing technologies, as it is only a deceptive tactic that props up the expansion of this polluting infrastructure. Aside from this, the way these are produced poses serious safety hazards to nearby communities, and their massive water demands threaten local resources in already stressed regions. 

What’s missing in the current policy update is the ADB’s commitment to address the gaps in the existing policy. The review process implicates seriously misplaced priorities, rather than strengthening safeguards or fully aligning with the 1.5°C climate goal. While the Energy Policy 2021 prohibits coal investments, a major loophole in its development finance plugs in support for coal assets indirectly. Fossil gas is still framed as a ‘transition fuel’ despite urgent guidance from climate science that the development of fossil fuel infrastructure has no place in achieving the 1.5°C goals set forth by the Paris Agreement. ADB-financed utility-scale projects, such as hydropower and geothermal power projects, have long histories of human rights violations: land grabbing, forced displacement, labor abuses, and the exclusion of communities from decision-making. In contexts of shrinking civic space and militarization, such projects not only deepen injustice but also endanger the lives of environmental and human rights defenders. 

It is clear that these proposals represent a regressive detour on ADB’s stated commitments to Paris Alignment, rights-based development, and inclusive governance, threatening Asia and the Pacific region with a fossil fuel and false solution future.

With this, we call ADB to abandon the regressive direction of its current review and commit to a rights-centered energy policy that reflects climate science, international human rights standards, and the lived realities of communities on the frontlines. We strongly urge the ADB to: 

• Extend the review timeline to 2026 to allow a genuine consultation process 

• Close all the gaps in the existing policy, such as:

  • Strengthening the provisions on the coal ban through stronger transparency measures for subprojects information via financial intermediaries, results-based and policy-based lending that might plug in support for coal, and excluding clients expanding their coal assets (including captive coal). 

  • Implement a time-bound phase-out of fossil gas across all financing modalities, including direct lending, equity investments, and technical assistance, and remove fossil gas from the category of ‘low-carbon’ investments

  • Reject investments in utility-scale greenfield hydropower projects, halt all project developers with an outstanding record of violations against accountability mechanisms to any development banks, and ensure that all the grievances of the project-affected communities are adequately addressed.

  • Stop the build-out of geothermal power projects, given the track record of harm caused to the communities, including serious health and environmental impacts, seismic risks, dispossession of Indigenous Peoples’ lands, gender-based violence, and grave human rights violations. The Bank must remove them from the Renewable Energy category in its investment portfolio. 

  • Phase out from Waste-to-Energy incineration and stop other waste-burning investments such as co-firing and repurposing of coal plants into WTE which burns resources which should be reduced, reused, repaired and safely recycled – and which violates internationally binding environmental and chemicals conventions including the imperative to conserve material resources in a dying planet. 

• Retain the prohibition on nuclear energy investments and strengthen the language by removing the policy clause marketing nuclear power as an alternative to fossil-fuel-based power plants for emission reduction. ADB must dismantle support, even technical capacity-building programs to its DMCs, as it will lock countries into high-risk technology, decades of debt, stranded assets, and complex social and environmental issues. 

• Reject all support for critical minerals initiatives – including technical assistance, consultancies, financial intermediaries, green or blue bonds, or direct financing – across the supply and manufacturing chains nationally/globally. The alarming ‘comeback’ of ADB to the extractive sector raised several concerns from the CSOs and mining-affected communities in the region, citing the historical and ongoing harms backed by development banks. 

• Abandon false solutions, including co-firing technologies in coal and gas plants, as it will only extend the last lifeline of fossil fuels. 

• Embed human rights safeguards, including FPIC, HRDD, and robust accountability mechanisms, in all energy financing

To end, we call out the ADB for facilitating an Energy Policy Review that is railroaded and exhibits a deeply regressive process. Rather than strengthening its climate and human rights commitments, the Bank is paving the way for decades of fossil fuel dependency, extractive false solutions, and complicity with corporate interests. We urgently call the Bank to reverse course: extend the review timeline, reject false solutions, phase out fossil fuels, and embed stronger safeguards and a human rights approach. A truly just energy transition must go beyond emissions targets. It must be grounded in human rights, community ownership, and meaningful participation.