ADB Energy Policy Review Scorecard: A Ring Hollow to a Just Energy Transition and Climate Justice
- NGO Forum on ADB
- 4 hours ago
- 8 min read
NGO Forum on ADB Network Statement on ADB Energy Policy Review 2025
A Decade in the Paris Agreement & Worsening Climate Crisis
This year marks the first decade marking the Paris Agreement. The historic climate accord has set the crucial targets globally in the hopes of preventing the irreversible impacts of climate change by the second half of the century. Unfortunately, the objective of limiting the temperature to 1.5°C above pre-industrial levels is getting slower and slower each year, as the record shows has been constantly breached for consecutive years since 2023. Even climate scientists are now at a growing consensus that this target is no longer attainable.
It is also ironic that 10 years under the Paris Agreement, more and more countries in the Global South are being heavily affected by the dire impacts of climate-induced disasters. The strongest storm in 2025, Typhoon Ragasa, first battered the Philippines, displacing around 4 million families, and later on hit Hong Kong and Taiwan with the same intensity. Pakistan, India, and Bangladesh experienced massive flooding during the monsoon season due to an abnormal amount of rainfall, resulting in huge casualties and damage to properties. These disasters are appallingly the new normal for Asia.
Our Score: Zero for Failed Process, lack of climate ambition, no account for justice
This year also coincides with the Asian Development Bank’s midterm review of its Energy Policy. At a time when climate action is crucial, the largest development financier in Asia must step up its efforts and reassess its current policies. However, the Bank miserably failed: from the process down to the thematic areas of the policy.
ADB’s Energy Policy Review process has been opaque, rushed, and exclusionary. What the Bank describes as a ‘midterm review’ has been anything but a participatory or transparent exercise. From its delayed disclosure of key documents to the hasty and limited consultation window, ADB’s process falls dramatically short of its Access to Information Policy and its own commitments to stakeholder engagement.
The first ‘official consultation’ with civil society took place on June 4, 2025, followed by a single virtual briefing in July, where the public was given barely two weeks to respond to policy changes that could lock Asia’s energy future for decades. Even after the comment period was reluctantly extended under pressure, there was no indication that the Bank would meaningfully integrate civil society feedback.
Briefings were conflated with consultations; information was shared selectively; draft policy texts were withheld from public view until late in the process. These actions betray the principles of openness and accountability that should underpin any institution claiming to be a partner in sustainable development.
The proposed amendments claim alignment with the Paris Agreement, but instead lay the groundwork for new fossil fuel dependencies. The proposed revisions reveal a dangerous pivot toward corporate and extractive interests, not a just and renewable future.
The Bank continues to brand fossil gas as a ‘transition fuel’, despite overwhelming scientific consensus that no new gas infrastructure is compatible with the 1.5 °C goal. The International Energy Agency has been unequivocal: there is no room for new oil and gas fields if the world is to remain within safe climate limits. Yet, ADB’s policy maintains loopholes allowing financing and technical support for gas exploration, midstream pipelines, and downstream facilities; all while classifying them under ‘low-carbon’ investments.
Meanwhile, the Energy Transition Mechanism, once touted as a pathway to retire coal plants, risks becoming a tool for refinancing fossil fuel expansion. By extending ETM’s coverage to oil-heated plants, without addressing its structural flaws or ensuring genuine community participation, ADB could end up subsidizing polluters and indebting countries further.
Moreover, it was made clear by the Bank that there is no intention of closing the loopholes on coal financing. While the current policy formally banned coal financing, its practice and review language keep loopholes wide open. Through financial intermediaries, captive coal projects, and results-based lending mechanisms, ADB remains exposed to coal developers and financiers. Civil society has repeatedly urged the Bank to close these gaps: to explicitly prohibit indirect coal exposure, disclose all high-risk subprojects financed through intermediaries, and end all support to clients still expanding coal. Yet, the midterm review offers no such commitments. The Bank’s continued silence on financial intermediary transparency undermines any claim to a ‘no-coal’ stance.
Perhaps most alarming is ADB’s push to rebrand mining as ‘green’. Through its proposed Critical Minerals for Clean Energy Technologies (CM2CET) initiative, the Bank positions extractive industries as essential to the energy transition. Communities from Mongolia to Indonesia, the Philippines, and beyond know this story too well: so-called ‘green mining’ devastates water sources, displaces Indigenous Peoples, militarizes territories, and deepens environmental injustice. Critical minerals may be crucial for technology production, but they cannot come at the cost of human rights and ecological survival.
A just energy transition cannot be built on new frontiers of extraction. Yet, ADB’s proposal signals a return to its troubled legacy in mining and extractives, which terribly ignores the call for no-go zones, Free, Prior, and Informed Consent (FPIC), and accountability for past harms.
To add fuel to the fire, the Bank’s consideration of removing the explicit prohibition on nuclear energy financing represents a reckless regression. Framing nuclear as a ‘transition’ or ‘green’ solution ignores its prohibitive costs, unresolved safety risks, and catastrophic waste legacy. Community representatives remind us of the lived dangers: the Bataan Nuclear Power Plant sits near an active fault line and volcano, a $2.3-billion monument to failed energy policy that never produced a single watt. Across Asia, nuclear projects compound debt burdens and divert resources from proven, community-safe renewables like solar, wind, and microgrids.
Small Modular Reactors, touted as a safer alternative, remain prohibitively expensive and unproven. UN data show nuclear remains five to six times costlier than renewables. Its inclusion in ADB’s policy signals not innovation but desperation to maintain centralized, corporate-driven energy control.
ADB’s policy revisions also read like a catalogue of techno-fixes designed to prolong fossil dependency: co-firing coal plants with biomass, hydrogen, or ammonia; promoting Waste-to-Energy incineration; expanding large hydropower and geothermal projects in Indigenous lands.
Each of these so-called ‘solutions’ worsens the climate crisis, erodes ecosystems, and deepens inequality. Co-firing extends the life of old fossil infrastructure; hydrogen and ammonia rely on intensive extraction and high water use; large hydropower displaces communities and destroys rivers; geothermal projects have triggered earthquakes, water depletion, and land conflicts across Indonesia and the Philippines; and Waste-to-Energy incinerators emit toxins while undermining zero-waste systems.
ADB needs to be reminded that it cannot buy its way into climate credibility by counting pollution-intensive technologies as ‘clean’.
Zero for Justice and Human Rights
Beyond the thematic and technical discussions, energy transitions that trample on rights are neither just nor sustainable. Yet, ADB’s review process and proposed amendments neglect human rights and gender justice, despite clear evidence of violations linked to past energy projects, including forced displacement and land grabbing, repression of defenders, and gendered violence. The Bank’s frameworks remain silent on binding human rights due diligence, protection of environmental defenders, or FPIC obligations. Without explicit safeguards embedded in the Energy Policy, ADB risks perpetuating harm while claiming progress. Communities must have the right to participate, to consent, and to say no. The energy transition must deliver zero emissions and zero human rights abuses.
This civil society scorecard speaks for the collective act of resistance from communities who bear the brunt of extractivism, fossil fuel expansion, and false climate narratives. CSOs and affected communities across ADB's member countries in the Asia Pacific and beyond have scored ADB not through numbers, but through lived experience.
When ADB funds gas pipelines that cut through Indigenous territories, that is a zero.
When it fails to disclose where its financial intermediary money goes, that is a zero.
When it pushes nuclear, extractives, or incinerators while calling itself a ‘climate bank’, that is a zero.
ADB cannot claim progress by publishing new frameworks while ignoring the voices of those it claims to serve. The climate emergency demands leadership rooted in justice, transparency, and science, and not in profit.
Our Demands: Time for ADB to Earn a Passing Grade
Civil society organizations, movements, and communities across Asia and the world demand that the ADB Board of Directors and the Management act decisively to correct course. The 2025 Energy Policy Review must not pass in its current form. We call on the Board and the Management to:
Restart a genuine, participatory, and transparent review process.
Reopen consultations until 2026 with clear timelines, disclose all drafts publicly, and ensure meaningful participation of communities and civil society, especially those directly affected by ADB’s energy portfolio.
Close all coal loopholes, once and for all.
End indirect exposure through financial intermediaries, captive coal projects, and corporate clients expanding coal. Mandate full disclosure of all high- and medium-risk subprojects.
Commit to a time-bound phaseout of fossil gas.
Remove gas from any ‘low-carbon’ category, cease financing for all midstream and downstream infrastructure, and redirect resources to community-owned renewable systems.
Reject the inclusion of nuclear and extractives.
Maintain the prohibition on nuclear financing and abandon CM2CET or other extractive-driven initiatives that threaten communities and ecosystems.
End all false solutions.
Exclude co-firing, Waste-to-Energy, large hydropower, large geothermal, and other destructive technologies from ADB’s definition of “clean energy.”
Integrate human rights and just transition principles into the Energy Policy.
Embed binding safeguards that ensure FPIC, gender equality, labor rights, and the protection of environmental defenders.
Align fully with the 1.5 °C pathway.
Adopt science-based emission reduction targets, phase out fossil support by 2030, and prioritize decentralized, rights-based renewable systems.
ADB’s score of zero is a mirror reflecting the Bank’s choices. The midterm review could have been an opportunity to lead Asia’s clean energy future; instead, ADB clings to the past, rewriting old mistakes in a new language.
But communities across Asia refuse to accept failure. The civil society scorecard stands as a public verdict: this review is a clear threat to Asia’s energy future, and it risks locking in another generation of fossil dependence.ADB’s Energy Policy Review remains what it is today: a failed test, a failing grade, and a stark warning that the path to 1.5 °C cannot be built on fossil fuels, false solutions, or exclusion.
ENDORSED BY:
NGO Forum on ADB
350 Pilipinas, Philippines
AbibiNsroma Foundation, Ghana
Adarsha Samajik Progoti Sangstha, Bangladesh
Aksi! for Gender, Social, and Ecological Justice, Indonesia
Aksyon Verde, Philippines
Alliance of Bengkulu Farmer, Indonesia
Alliance of Pari Island Women, Indonesia
Al Rehmat Welfare Society Gujranwala, Pakistan
Alternative Law Collective (ALC), Pakistan
Alyansa Tigil Mina (ATM), Philippines
Asian Forum for Human Rights and Development (FORUM-ASIA), Thailand/Asia
Asian Peoples' Movement on Debt and Development (APMDD), Regional
ATM Youth Network, Philippines
Bandhan, Bangladesh
Bangladesh Working Group on External Debt (BWGED), Bangladesh
Bank Climate Advocates, United States
Bir Duino-Kyrgyzstan, Central Asia/Kyrgyz Republic
Centre for Community Mobilization and Support NGO, Armenia
Centre for Research and Advocacy, Manipur , Manipur, India
CEPR (Centre for Environment and Participatory Research), Bangladesh
Civil Society Support Program (CSSP) , Pakistan
CLEAN (Coastal Livelihood and Environmental Action Network), Bangladesh
Community Resource Centre (CRC), Thailand/Southeast Asia
DIPTO- A Foundation For Gender & Development , Bangladesh
DOPS Foundation , Rangpur, Bangladesh
Effulgeo, Philippines
Environmental Protection Organization (EPO), Pakistan
Forum on Ecology and Development (FED), Bangladesh
Friends of the Earth Japan, Japan
GAIA Asia Pacific, Asia Pacific
Good Thinkers Organization , Pakistan
Greenfield Livelihood Services (GLS), Bangladesh/South Asia
Growthwatch, India
INCIDIN Bangladesh, Bangladesh
Indian Social Action Forum (INSAF), India
Indigenous Women's Legal Awareness Group (INWOLAG), Nepal
Indus Consortium, Pakistan
Inisiasi Masyarakat Adat (IMA), Indonesia
Initiative for Right View (IRV), Bangladesh
International Rivers, United States / Global
IPDP (Initiative for the Participatory Development Through Peace), Pakistan
ISDE Bangladesh, Bangladesh
Jalaur River for the People's Movement, Philippines
Japan Center for a Sustainable Environment and Society (JACSES), Japan
Jember' Women and Politics, Indonesia
Jubilee Australia Research Centre, Australia
Legal Rights and Natural Resources Center, Inc.-Kasama sa Kalikasan/ Friends of the Earth Philippines, Philippines
LAPPAN Maluku, Indonesia
LEKAT Papua, Indonesia
Life Haven Center for Independent Living, Philippines 10
Lumière Synergie pour le Développement, Senegal
Mangrove Action Project, USA
MATI, Bangladesh, Bangladesh
Mekong Watch, Japan
Mongla Nagorik Somaj , Bangladesh
Monitoring Group of External Aid, Kyrgyzstan
Nash Vek, Kyrgyzstan
National Disability and Development Forum NDF, Pakistan
Onnochitra Foundation, Bangladesh
Oyu Tolgoi Watch, Mongolia
Pakistan Fisherfolk Forum , Pakistan
Paribartan, Bangladesh
Peace Point Development Foundation-PPDF , Nigeria
Philippine Movement for Climate Justice (PMCJ), Philippines
PRANTOJON, Bangladesh
Recourse, Global
Rivers & Rights , Southeast Asia (Regional)
Rivers without Boundaries Coalition , Mongolia
Rivers without Boundaries Mongolia, Mongolia
Social Welfare And Community Development Society , Pakistan
SoDESH, Bangladesh
Solidaritas Anak Merdeka, Indonesia
Solidarity of Independence People Foundation , Indonesia
SONGSHOPTAQUE, BANGLADESH
South Asia Just Transition Alliance (SAJTA), Regional
Sowrd, Pakistan
Manusher Jonno Foundation (MJF), Bangladesh
Srizony Foundation, Bangladesh
Sustainable Development Foundation SDF , Pakistan
SYCOP, Pakistan
Trend Asia, Indonesia
Urgewald, Germany
Uzbek Forum for Human Rights, Germany/Uzbekistan
Village Development Organization VDO sindh , Pakistan
The Indonesian Forum for Environment (WALHI), Indonesia
WomanHealth Philippines, Southeast Asia
