Forum Network Submission on ADB Energy Policy Review 2025

As mandated by the 2021 Energy Policy, the Asian Development Bank is now undertaking a midterm review of its existing policy. However, the process so far reflects a worrying lack of transparency, a clear stakeholder consultation process, and accountability.

Since the review was announced, the NGO Forum on ADB has actively and critically engaged with ADB through multiple discussions with the Energy Sector Office and some Board Members. These engagements aimed to clarify the review process and to emphasize the critical and unaddressed gaps from the 2021 policy. Yet, halfway through the year, civil society organizations and affected communities are given a limited space to engage. No concrete stakeholder engagement plan has been released, citing that it is only a “simple review”. The timeline appears rushed, and public information on the scope, content, and outcomes of the process remains severely limited.

Even more concerning are the proposed amendments that have surfaced, many of which represent a serious regression from the climate, environmental, and human rights safeguards ADB claims to uphold. Prominently, these include:

• The proposed removal of the policy’s prohibition on nuclear energy investments.

• Mainstreaming of Critical Minerals for Clean Energy Technologies (CM2CET), despite unresolved environmental, social, and governance concerns raised repeatedly by CSOs;

• The expansion of the Energy Transition Mechanism's scope to include oil and gas plants, despite the mechanism’s structural flaws and the risk of reinforcing fossil fuel dependencies.

• The inclusion of false energy solutions such as co-firing of biofuels, green hydrogen, and ammonia, and continued reliance on Carbon Capture, Utilization and Storage (CCUS) technologies, which are widely criticized as false solutions that delay real climate action.

These amendments, introduced without adequate consultation or evidence-based justification, reveal a disturbing trend: a rush to approve policy changes that benefit corporate and state interests while sidelining the very communities most vulnerable to energy and climate risks. The lack of clear direction, combined with the opaque and exclusionary nature of this review, underscores ADB’s failure to uphold meaningful, rights-based, and participatory processes.

In light of these serious concerns, the NGO Forum on ADB, along with its network members and allies, submits this matrix of comments and recommendations. We urge the ADB to move beyond cosmetic commitments and adopt bold, rights-centered reforms that are truly aligned with the 1.5°C target. This requires rejecting false solutions, phasing out all forms of fossil fuel support, and ensuring communities, especially those on the frontlines, are central to shaping a just and sustainable energy future. This review must not be reduced to a procedural exercise.

ON THE REVIEW PROCESS AND TIMELINE
Item	Forum and allies' comments and/or recommendations
Timeframe	A month after the NGO consultation during the Asia Clean Energy Forum, we observed a critical concern regarding the recent changes to the Energy Policy Review timeline, which now targets finalization by September 2025 and Board consideration by October 2025. This is significantly earlier than the previously indicated Q4 2025 to Q1 2026 schedule. This acceleration, reportedly to avoid a “busy” 2026 Board calendar, risks undermining the transparency and inclusiveness of the review process. Given the scope of the proposed amendments, we strongly urge ADB to ensure that the process allows adequate time for meaningful engagement, particularly with civil society organizations. A rushed timeline compromises the quality of consultation and the ability of stakeholders to provide informed input. We call on the Bank to reconsider the revised timeline and retain the 2026 deadline to allow adequate scrutiny of the proposed changes.
Consultation Process  June 4, 2025: First Official NGO Consultations on ADB Energy Policy Review 2025  July 22, 2025: Virtual Briefing for CSOs on Energy Policy Review	We note with concern the limited and unclear timeline for civil society engagement in the ADB Energy Policy Review 2025. The first official NGO consultation was held on June 4, 2025, followed by a CSO virtual briefing on July 22, 2025, during which the opening of the public comment period was only formally announced. This provides civil society with less than two weeks—until August 8, 2025—to review, analyze, and submit inputs on a critical policy with long-term implications. The Bank, later on, extended the submission to September 10 upon the strong opposition from the CSOs. Regardless of the extension of the deadline, the original timeframe was retained, which raises a serious question about how ADB will meaningfully integrate these comments in a brief period.  Moreover, the interchangeable use of “CSO Briefing” and “Consultation” raises serious concerns about the clarity and consistency of the engagement framework. Briefings are primarily informational, whereas consultations are expected to be dialogic and participatory. This conflation diminishes the quality and intent of meaningful consultation.
Information Disclosure / Transparency	We are concerned that the Energy Policy Review process has lacked transparency and falls short of ADB’s own Access to Information Policy. Only briefing notes dated May 30 and July 7, 2025, were shared with limited NGO/CSO audiences. The Draft Revised Policy itself was not disclosed publicly, nor was it posted on the ADB website or opened for public comment. The only opportunity for input was during the July 22 CSO briefing, where participants were informed of an August 8 deadline, leaving just two weeks to respond, without access to the full draft. It was only after a request from Forum Network members and allies that the Bank agreed to extend the comment period to August 28.  This restricted approach undermines the principle of “clear, timely, and appropriate” disclosure, which ADB commits to in its Access to Information Policy to ensure meaningful stakeholder engagement and promote good governance. As stated in their posted timeline, Phase 1 of the review process started in Q1 of 2025, while Phase 2 is currently rolling. However, it was only on July 30 that the ADB disclosed the related documents on the designated ADB webpage, signaling a significant delay in its obligations to transparency and due diligence. We urge the Bank to fulfill its disclosure obligations and enable transparent, inclusive participation in this critical policy process.
Proposed Amendments
Proposed Additions to the Energy Policy
Item	Forum and allies' comments and/or recommendations
Critical Minerals and Clean Energy Technology Manufacturing: Reflect the increasing importance of critical minerals and clean energy technology manufacturing for energy transition in the region. Recognize ADB’s potential role in this area in line with proposed board direction and operational approach papers on critical minerals and manufacturing value chains.	We are concerned by ADB’s proposal to include CM2CET Manufacturing in the revised Energy Policy, despite the absence of publicly available information on the approach paper and the proposed regional financing facility. This lack of transparency prevents stakeholders from meaningfully assessing or responding to the implications of this proposed mechanism. Furthermore, CSO concerns raised about CM2CET have not been adequately addressed by ADB officials, highlighting a broader pattern of limited responsiveness in the policy review process. We are also deeply alarmed by the growing trend among multilateral development banks, including ADB, to position critical minerals as a new investment frontier under the banner of the “energy transition”. Following the steps of the World Bank, aligning with the ‘climate-smart mining’ framework replicates the troubling pattern of reintroducing mining as ‘green’ and a part of the Bank’s ‘clean energy transition’ agenda. Case in point, ADB’s technical assistance on Climate-Smart Mining in Mongolia, wherein it was packaged as an economic diversification mechanism for the country by supporting rare earth minerals extraction. However, we continuously reiterate that it could deepen Mongolia’s dependence on mining, threaten water and grazing lands, undermine nomadic livelihoods, and jeopardize the livestock-based wool and cashmere sectors. This narrative and expansion of the sector will only deepen existing inequalities and injustices by propping up an industry with a legacy of human rights abuses, environmental destruction, and militarization, while funneling public resources and profits to the Global North. This renewed engagement in the extractive sector is alarming given the historical and ongoing harms associated with mining investments backed by development banks and private actors. These projects have consistently fallen short on due diligence, transparency, and accountability, leaving behind irreversible social and environmental damage. A just energy transition must not come at the expense of communities and ecosystems; we urge ADB to reconsider this path and prioritize genuinely sustainable and rights-respecting approaches.
Methane Leakages and Routine Gas Flaring Reduction: Support investments in methane leakage and routine gas flaring reduction in existing upstream oil and gas fields to align with commitments made in COP26 as part of the Global Methane Pledge.	We recognize that reducing methane leakages is a critical component in lowering greenhouse gas emissions and achieving net-zero targets. However, adopting measures on the efficiency of existing oil and gas fields could pave the way for expanded fossil gas production. This, in turn, would increase overall greenhouse gas emissions over time, undermining climate goals. Therefore, we welcome the ADB’s acknowledgment that projects aimed at reducing methane emissions should not contribute to extending the operational life of existing oil and gas fields. However, we believe that clear and enforceable criteria are essential to ensure these projects do not inadvertently prolong fossil fuel use or enable the expansion of related operations. These criteria should include: (1) partner companies must commit to a clear fossil fuel phase-out date aligned with IEA net-zero scenarios, and (2) companies must not expand their fossil fuel operations.
Proposed Amendments to Current Provisions
Oil Trading: Update paragraph 74 to reflect ADB's current Trade and Supply Chain Finance Program commitment to cease support for oil trading from July 2025.	We welcome the proposed changes to cease the support for oil trading. We encourage the ADB to exclude support for all fossil fuel trading from its Trade and Supply Chain Finance Program.
Accelerated Decommissioning of Oil and Gas-fired Power Plants and Oil-fired Heating Plants: In addition to ADB’s support for early closure of existing coal power plants, expand support for early closure of oil and natural gas-fired power plants and coal and oil-fired heating plants as part of the ADB’s Energy Transition Mechanism in paragraph 75.	The current design of ADB’s ETM has demonstrated serious shortcomings. It offers incentives to coal plant operators without requiring robust reparation or just transition plans, raising the risk of de facto bailouts. The mechanism appears to favor fuel switching over actual plant closures, lacks transparency, and involves limited community participation, ultimately placing public funds at risk of reinforcing, rather than retiring, coal infrastructure. Moreover, the financing model of the ETM, which is currently reliant on loans, fails to consider the wider implications of additional debt on the public. Expanding ETM’s scope to include fossil gas and oil, without first addressing these structural flaws, would further undermine its credibility. Such a move would effectively transform the ETM into a refinancing tool for fossil fuel expansion, contradicting the goals of a just and equitable energy transition.
Co-Firing in Coal and Gas Power Plants: Update paragraph 75 to reflect the technology advancements and the current policy provisions which allow for other forms of support for emission reduction in current fossil-fuel fired power plants, to capture co-firing with clean fuels such a biofuels, green ammonia and green hydrogen in existing coal and gas power plants subject to substantially reducing greenhouse gas emissions and not extending the lifetime of the existing power plants.	We strongly oppose the retrofitting of coal and fossil gas power plants and related infrastructure for biofuels, hydrogen, and ammonia co-firing. This approach constitutes a false solution to the energy and climate crisis, as it prolongs the life of high-emitting fossil fuel facilities and relies on energy-inefficient processes. The electrolysis process used to produce green hydrogen is inherently inefficient, with significant energy losses across production, compression, storage, and transport. Moreover, the volatility of hydrogen poses serious safety risks to nearby communities and ecosystems, while its production demands heavy water use, threatening local water sources. We also raise concerns about co-firing with biofuels. In this context, solid biofuels likely refer to the use of wood sourced from natural or semi-natural forest ecosystems, which constitutes a clear destruction of the natural environment. Even when wood is obtained from genuine plantations, such plantations often occupy land previously covered by natural forests or used for agriculture. Furthermore, the combustion of this wood releases more carbon dioxide than coal or natural gas. Several MDBs explicitly prohibit the financing of logging in natural forests. For instance, the ADB prohibits “commercial logging operations or the purchase of logging equipment for use in primary tropical moist forests or old-growth forests.” Nevertheless, the burning of solid biofuels creates increased incentives for logging natural forests, including old-growth ecosystems such as swamp forests in the southeastern United States.  This path also depends on costly and extractive technologies, including electrolyzers that require critical minerals such as platinum and rare earth elements, raising concerns about environmental degradation, labor conditions, and the social impact of industrial siting. With no clarity on where these facilities will be established or who will bear the burdens, communities are left vulnerable. Hydrogen blending also contributes to harmful NOx emissions and risks delaying the real solutions we need: community-owned, distributed renewables like wind, solar, biogas from anaerobic digestion, and community battery energy storage systems. ADB must reject these false solutions and commit to advancing truly sustainable, just, and people-centered energy systems.
Carbon, Capture, Utilization and Storage (CCUS): Under paragraph 77, it is proposed to extend prohibition of CCUS projects coupled with enhanced oil recovery to include also those coupled with enhanced gas recovery. It is also proposed to allow the use of depleted oil and gas wells for carbon dioxide storage in CCUS projects.	We acknowledge the commitment of the Bank to continue the prohibition of CCUS with Enhanced Oil Recovery, since these efforts only capture a small fraction of total emissions and enable further fossil fuel extraction. On the other hand, we firmly assert that ADB must end all financing, whether through technical assistance, piloting, or project development, for Carbon Capture, Utilization and Storage (CCUS). These technologies remain unproven at scale, despite decades of experimentation, and have failed to deliver meaningful reductions in greenhouse gas emissions. They also pose serious risks, including the potential for induced seismic activity, and their long-term viability remains uncertain. These technologies are deeply contested as “carbon neutral” due to emissions associated with land-use changes, biomass cultivation, transportation, and processing, which can negate their climate benefits entirely. Continued investment in these false solutions diverts attention and resources away from the deployment of real, community-centered renewable energy systems and entrenches the power of polluting industries.
Nuclear Power: Under paragraph 79, elaborate on the existing provision on ADB’s technical support for long-term capacity development needs in nuclear power if DMCs choose to opt for nuclear power as part of their generation mix.  The current provision has already recognized the role of nuclear power as an important technology option to replace conventional fossil fuel fired baseload power plants, in emissions reduction.  An amendment is proposed to capture this position more clearly.  Further, it is proposed to remove the prohibition on financing investments in nuclear.	Under paragraph 79, ADB proposes to elaborate on its existing provision for technical support in nuclear power development and to remove the current prohibition on financing nuclear energy investments. This signals a concerning regression in ADB’s energy policy, positioning nuclear as a viable decarbonization pathway despite its well-documented risks. The Nuclear-Free Bataan Movement (NFBM) strongly opposes this shift. Drawing from decades of community resistance to the Bataan Nuclear Power Plant (BNPP), NFBM underscores that nuclear energy is neither safe nor just. The BNPP, located near an active fault line and a volcano, remains a dormant but dangerous relic of misguided energy policy. It has cost the Philippines over $2.3 billion without generating a single watt of electricity, and continues to pose seismic, environmental, and financial risks. “The BNPP sits on a geologically unstable site near an active fault line and a volcano. It is not just a financial burden—it is a radioactive threat to our communities. Reviving nuclear energy financing will deepen our national debt, expose us to irreversible risks, and ignore the lessons of Chernobyl, Fukushima, and Three Mile Island. Safety is not just a technical issue—it is a myth when profit overrides precaution.” — Derek Cabe, Coordinator, Nuclear-Free Bataan Movement NFBM’s community-led initiative, we have conducted a community-based cost-benefit analysis revealing overwhelming local opposition to nuclear energy and strong support for renewable alternatives. Their findings highlight: The seismic and volcanic risks of the BNPP site The lack of a viable radioactive waste management plan The massive financial burden and debt implications for developing member countries The historical exclusion of affected communities from energy decision-making processes In light of these realities, we strongly urge ADB to retain and strengthen its prohibition on nuclear energy financing. Supporting nuclear energy not only delays urgent climate action but also entrenches environmental injustice and undermines community safety. ADB must instead prioritize community-owned, decentralized renewable energy systems that are safer, more equitable, and aligned with the 1.5°C climate goal.
The proposed removal of the explicit prohibition on nuclear energy investments in ADB’s Energy Policy signals a concerning regression. Positioning nuclear as a viable option for decarbonization overlooks its high social and environmental risks, long development timelines, and financial burdens, particularly for DMCs. New technologies such as Small Modular Reactors (SMRs) are often promoted as faster, cheaper, and “clean” alternatives, but these claims do not hold up under scrutiny. All four SMR projects currently operating or under construction have faced cost overruns of three to seven times their original estimates and have experienced significant delays. A recent UN report also found that nuclear energy remains five to six times more expensive than the average cost of new wind or solar power. Supporting capacity development in this sector diverts attention and resources away from safer, more sustainable, and people-centered energy solutions. We strongly urge ADB to reject this direction, as nuclear expansion risks locking DMCs into massive debt and delaying urgent climate action needed to remain within the 1.5°C threshold. ADB should instead prioritize proven, community-led renewable energy strategies that deliver just, equitable, and timely climate outcomes.
THEMATIC AREAS
Improve transparency in financial intermediary lending	The bank intends to retain the utilisation of FI lending to support energy efficiency and energy access. However, it is yet to resolve the significant risks, in particular around clients’ adherence to E&S safeguards, lack of transparency, and exposure to fossil fuel projects of this type of lending. The concern about transparency is that money invested through FIs could end up supporting fossil fuels by the back door. For example, in 2016, Indonesia Infrastructure Fund participated in a $3.745 billion loan package to finance the expansion of the Tangguh LNG project in West Papua together with other commercial banks. ADB must publish the name, sector, and location of all high and medium-risk projects it supports through FIs, to enable public tracking and assessment of ADB’s fossil fuel and climate commitments. Without transparency reforms, there is no way for the general public to ensure that ADB’s FI lending is not going to coal, gas, and other fossil fuels.
Strengthen Coal Prohibition	While the Energy Policy 2021 prohibits coal investments, several loopholes indirectly expose the bank to coal investments. ADB must close these gaps in the ongoing Energy Policy Review through: adding clauses to clarify that it will stop financing projects that are not viable without a dedicated coal-based power supply, nor will it invest in businesses with plans to expand or create new captive coal capacity; ending all disbursements to existing clients that are developing coal projects; ending the financing of major coal developers and companies enabling coal expansion, or those that don’t have coal phase-out plans;  ensuring that all high and medium-risk subprojects financed via financial intermediaries are disclosed on the ADB website; introducing no coal clauses, and improving transparency, for any projects (such as Results-Based Lending) where the use of proceeds is not clearly defined.
Fossil Gas	The 2021 Energy Policy continues to fall short of committing to a full phaseout of fossil fuels, as it leaves the door open to investments in, financing of, and technical assistance for fossil gas, both directly and through intermediaries. The continued framing of fossil gas as a ‘transition fuel’ is deeply troubling and runs counter to the urgent guidance of the IPCC Sixth Assessment Report, which clearly warns against the development of new fossil fuel infrastructure. Furthermore, the International Energy Agency's 2023 report emphasized that there is no need for “long lead time conventional oil and gas projects” to be approved and developed. Already in 2016, Oil Change International calculated that no more fossil fuel infrastructure can be built if we are to meet the goals of the Paris Agreement. The potential carbon emissions from the oil, gas, and coal in the world’s operating fields and mines would already take us beyond 2°C of warming, and even excluding coal, the reserves in currently operating oil and gas fields would take us beyond 1.5°C. The 2021 Energy Policy is therefore already lagging behind the science, so it can only be made more stringent. Therefore, the policy stance reflects a significant disconnect from science-based climate targets and undermines the credibility of ADB’s decarbonization commitments.  ADB must commit to a strategic, time-bound phaseout of all support for midstream and downstream fossil gas projects across all financing modalities, including direct lending, equity investments, and technical assistance. Gas infrastructure should no longer be classified under any category of ‘low-carbon’ investment, as doing so undermines the integrity of the Bank’s climate commitments.
Large Hydropower	We express deep concern over the continued classification of utility-scale hydropower as a renewable, climate-compatible solution by the ADB, despite its well-documented social, environmental, and economic harms. Large and even small-scale dam projects have led to the widespread dispossession of Indigenous Peoples and local communities, destroying ancestral lands, agricultural areas, biodiverse forests, and cultural identities. Communities have been pressured, often under militarized conditions, to abandon their homes for inundation zones, in processes that are fundamentally undemocratic and violent. The impacts of these projects span upstream and downstream ecosystems, dewatering rivers and increasing risks of landslides, floods, seismic activity, and droughts. Hydropower projects are neither climate-resilient nor low-emission. Dam failures after extreme weather events, such as glacial lake outburst floods and heavy rains, are becoming more frequent under climate change. Rehabilitation loans and dam-related infrastructure projects (e.g., transmission lines, access roads) often deepen existing grievances, environmental damage, and sovereign debt. Furthermore, when built on transboundary rivers, dams can violate international water-sharing agreements and escalate regional tensions. Going forward, we therefore urge the ADB to steer clear of investments in utility-scale greenfield hydropower projects, avoid engaging in partnerships with hydropower companies involved in any existing development bank accountability mechanism processes, and ensure outstanding grievances of communities affected by past ADB financing in the hydropower sector are duly addressed.
Geothermal Energy support	Geothermal projects financed by ADB are often constructed on the ancestral lands of Indigenous Peoples and in rural communities. When discussing geothermal energy within the energy policy context, we talk about a policy direction and not about safeguards implementation. It is crucial to note that the policy's direction, which supports geothermal energy as a clean and renewable source, contradicts its intended goals. Such policy direction does not align with promoting environmental sustainability, nor enhancing climate resilience in the community, gender equality, and a just transition, as outlined in the proposed new energy policy. Communities residing near geothermal power plants, such as those in Indonesia, seven projects among others, financed by the ADB, are facing a myriad of issues. These include air and water pollution, water scarcity, health problems like respiratory and skin diseases, loss of income and harvest, and an increased risk of earthquakes. It's essential to recognise that even communities currently unaffected by a lack of electricity or climate-related issues may become vulnerable due to false climate solutions, such as geothermal energy, which could compromise their ability to withstand climate disasters. Such outcomes stand in direct contradiction to ADB’s stated commitments to human rights and environmental sustainability, and underscore the urgent need for stronger safeguards and genuine community participation at every stage of project development. Therefore, we stick with the call that the new energy policy does not support the financing of geothermal and other climate false solutions.
Waste-to-Energy	We urge ADB to phase out WTE incineration, thermal investments, and all forms of waste-burning, including co-firing of Refuse-Derived Fuel (RDF) and biomass from its energy and climate strategies. These technologies are known to produce high levels of greenhouse gas emissions, directly contradicting the Bank’s decarbonization goals. Moreover, their integration into coal plant refurbishment through co-firing methods poses serious health and environmental risks, including the release of toxic ash and other hazardous pollutants. WTE incineration is a fossil-intensive source of energy reliant on plastic, rubber, and other fossil-based materials. ADB’s order of priorities states that waste should first be reduced, then reused, then recycled, before WTE. ADB has failed to prove that it is following this in its latest investments in Can Tho, Vietnam, and Canvest, China.  WTE is not a circular economy intervention. The UNEP’s Global Waste Management Report 2024, page 25, defined Waste-to-energy as a representation of linear resource use since materials that are combusted can never be recovered and used again. It reduces incentives to decrease waste generation and move towards a zero-waste and low-carbon society. In fact, Europe has already taken away WTE in its circular economy roadmap because it is a barrier towards circularity. Current global policy development and national development strategies are moving towards upstream interventions on waste management, which will impact the viability of the WTE industry and ADB’s WTE projects. Single-use plastic bans, plastic reduction policies, improved recycling, and the emerging Global Plastics Treaty mean that there is a push to reduce the appropriate feedstock for waste incineration. As a case in point, the evaluation of ADB’s project of Shanghai SUS in 2024 in China revealed that policies towards waste minimization, segregation, and recycling has led to shutdowns of WTE plants in China due to a lack of feedstock. WTE is also not aligned with the new safeguards policy, which bans the production of persistent organic pollutants and calls for the reduction of material use intensity. Again, returning to the Can Tho WTE Plant, Vietnamese researchers have found that it emits persistent organic pollutants like dioxins. Local officials are currently challenged with how to manage this hazardous pollution.  Multiple studies have shown that WTE is not cost-effective compared to truly renewable alternatives such as wind and solar. It is significantly more expensive than both coal and clean energy, making its promotion economically unsound as well as environmentally harmful. Instead, the ADB should redirect support toward safe, sustainable, and community-centered renewable energy solutions.
Nuclear	We strongly urge the ADB to maintain its current policy of excluding nuclear energy from its financing portfolio. Nuclear power, often presented as a climate-friendly solution, is, in reality, an expensive and unreliable distraction from the urgent need to accelerate the renewable energy transition. Recent interest in technologies like Small Modular Reactors (SMRs) has been driven by promises of cost savings, faster deployment, and lower environmental impact. However, a report by the Institute for Energy Economics and Financial Analysis that SMRs are not competitive with renewable energy. Projects so far have cost much more and taken far longer than promised. From a financial and environmental standpoint, nuclear energy is not competitive. According to a recent United Nations report, the average cost of electricity from nuclear power is over 23 cents per kilowatt-hour, far exceeding that of solar (4.3 cents/kWh) and wind (3.4 cents/kWh). These figures do not yet account the long-term financial burdens associated with decommissioning plants and managing radioactive waste. Nuclear energy does not offer a “clean” alternative. Radioactive emissions occur across the entire lifecycle, including uranium mining, fuel processing, plant operation, and waste disposal. Moreover, no country has yet implemented a permanent solution for high-level nuclear waste, which requires secure management for tens of thousands of years. Beyond cost and environmental concerns, nuclear power poses significant safety and security risks. The Fukushima disaster underscored how a single accident can devastate communities, ecosystems, and economies for generations. The potential for military misuse of nuclear materials and the threat of terrorist attacks on nuclear facilities further compound these risks. Supporting nuclear energy financing would not only misallocate resources but also delay the widespread adoption of safer, cheaper, and cleaner renewable technologies. ADB should remain focused on financing proven, sustainable solutions like decentralized wind, solar, and energy storage.
Stringent Compliance with the ADB Safeguards, Paris Alignment, and Just Transition	We urge ADB to embed clear and binding safeguard language within the Energy Policy itself to protect the rights of communities and directly address the urgent realities of the climate crisis. This is essential to ensuring accountability, not only for ADB but also for other actors responsible for the social and economic harms caused by decades of dirty energy investments. Communities must not be left to bear the costs of a transition that continues to ignore their voices and lived experiences. Equally alarming is the lack of clarity and accountability in the Joint MDBs' High-Level Principles on Just Transition. Without concrete metrics, there is no credible way to assess whether ADB and other MDBs are making meaningful progress or simply issuing empty commitments. ADB's ongoing failure to implement robust systems for tracking GHG emissions across the full project cycle and its continued support for fossil fuels undermine both its Paris Alignment goals and its credibility. These dangerous maneuvers must be halted if ADB is to play a legitimate role in advancing a truly just and climate-aligned energy future.
Stronger Safeguards and Human Rights Approach as Reflected in the Energy Policy	Large-scale energy projects are often related to serious human rights violations: involuntary resettlements, land grabbing, civic repression, destruction of the living environment, and other violations. The communities are often excluded from decision-making at the earliest stages. These harms are connected both with fossil fuels, as well as renewable energy projects, where supply chains are increasingly implicated in labor abuses, land conflicts, and environmental degradation. ADB should align its Energy Policy with international human rights standards, including the UN Guiding Principles on Business and Human Rights and the UN Declaration on the Rights of Indigenous Peoples (UNDRIP). This also means fully integrating human rights and the updated social and environmental safeguards across the energy project cycle, including comprehensive Human Rights Due Diligence (HRDD). The Energy Policy must prohibit the dilution of safeguards in co-financing arrangements, such as under mutual reliance frameworks with other institutions like the World Bank. The Bank must remain accountable to its own standards, regardless of financing modality. The Energy Policy should also clearly articulate that: Energy transition should align with a just transition paradigm, supporting workers, women, and communities impacted by the fossil fuel phase-out. Ensure any form of support related to the critical minerals supply chain complies with national and international legal obligations to environmental, labor, and human rights matters, and that ADB will commit to stay away from supporting projects in sites where serious/systematic human rights violations have already been flagged, including but not limited to extrajudicial killings and disappearances of community members as well as other forms of physical, verbal and psychological violence against those who raise critical questions about mining ventures. Avoid technologies that lead to new forms of extractivism, land grabbing, or exclusion of communities. ADB must ensure that the transition towards clean energy does not come at the cost of human rights. The Energy Policy should uphold the principle that a zero-emissions future must also be a zero human rights abuses future. In contexts of shrinking civic space, militarization, or conflict, energy projects should not cause further harm. Community engagement should not contain the risks of retaliation or violence; the environmental and human rights defenders’ protection must be seriously addressed by the bank. The Bank should conduct thorough conflict and security risk assessments in fragile contexts and ensure that security forces around project sites are mandated, rights-trained, and accountable. It is essential that the ADB Energy Policy stresses human rights protection and ensures public participation in decision-making regarding both concrete projects and energy sector reforms. Accordingly, the Energy Policy should lead not just to zero emissions, but also to zero human rights abuses during the energy transformation.   This can be reached only through a well-structured public participation process and the inclusion of affected communities in decision-making, a comprehensive assessment of civic space, and a well-developed mitigation framework.  The policy should be based on the respect of human rights and not tolerate any human rights violations by its borrowers.  It should require meaningful consultation processes with communities and workers, human rights due diligence processes, benefit-sharing schemes, and respect for all core International Labour Organization Conventions and Indigenous Peoples’ rights as per the UN Declaration on the Rights of Indigenous Peoples. This includes the right of communities to say no and withdraw consent at any time if violations occur. It should ensure local communities’ rights, including land rights and free, prior, and informed consent (FPIC) over the project's lifespan, and effective access to grievance mechanisms at the project level. These mechanisms should be gender-responsive, culturally-appropriate, and must provide adequate, timely provisions for remedy of any harm, environmental damage, or rights violations committed by the project proponents. A human rights-based approach to the energy transition entails respecting the right of communities to safely determine their development – the right to decide land use, resource governance, and to pursue community-led solutions for the energy transition.
Gender	It is a misconception of the new proposed ADB energy policy that gender inequality in the energy sector stems from a lack of women's access to clean and modern energy services. In reality, the extraction of energy sources, such as geothermal, biofuel, and coal, which often leads to the loss of livelihoods and natural resources, as well as the structure of the energy industry, is the root cause of gender inequality. ADB's privatisation strategy, including electricity and water, has further exacerbated these problems. The proposed new Energy Policy, unfortunately, ignores these root causes and therefore may exacerbate existing gender inequality.

Endorsed by the following organizations: 

350 Pilipinas, Philippines

350.org Asia, Asia

AbibiNsroma Foundation, Ghana

Adarsha Samajik Progoti Sangstha, Bangladesh

Aksi! for Gender, Social, and Ecological Justice, Indonesia

Alternative Law Collective (ALC), Pakistan

Asian Peoples' Movement on Debt and Development (APMDD), Regional

Asian Forum for Human Rights and Development (FORUM-ASIA), Regional, Asia

Bangladesh Working Group on Ecology and Development (BWGED), Bangladesh

Bank Climate Advocates, United States

Bank Information Center, United States

Bantay Kita, Inc., Philippines

Bir Duino-Kyrgyzstan, Kyrgyz Republic

Buliisa Initiative for Rural Development Organisation (BIRUDO), Uganda

CEE Bankwatch Network, Czech Republic

Center for Environmental Justice (CEJ), Sri Lanka

Centre for Financial Accountability, India

CLEAN (Coastal Livelihood and Environmental Action Network), Bangladesh

Climate Action Network (CAN) Africa, Regional node (Africa)

Coastal Livelihood and Environmental Action Network (CLEAN), Bangladesh

Community Initiatives for Development in Pakistan-CIDP, Pakistan

Conseil Régional des Organisations Non Gouvernementales de Développement, RDC

Consumers' Association of Penang, Malaysia

DIPTO - A Foundation For Gender & Development, Bangladesh

Eco-Coalition Armenia, Armenia

Ecolur informational NGO, Armenia

Forum on Ecology and Development (FED), Bangladesh

Freedom from Debt Coalition, Philippines

Friends of the Earth Japan, Japan

Fundación CAUCE: Cultura Ambiental - Causa Ecologista, Argentina

Gender Action, USA

Global Alliance for Incinerator Alternatives (GAIA), Asia-Pacific

Growthwatch, India

Inclusive Development International, United States

Indian Social Action Forum (INSAF), India

Indonesian Center for Environmental Law, Indonesia

Indus Consortium, Pakistan

Inisiasi Masyarakat Adat (IMA), Indonesia

Initiative for Right View(IRV), Bangladesh

International Accountability Project, Global

International Rivers, Global

ISDE Bangladesh, Bangladesh

Jamaa Resource Initiatives, Kenya

Japan Center for a Sustainable Environment and Society (JACSES), Japan

Jubilee Australia Research Centre, Australia

Just Energy Transition Network Bangladesh (JETnet-BD), Bangladesh

Karbi Anglong Solar Power Project Affected Peoples Rights Committee, India

Legal Rights and Natural Resources Center, Philippines

Life Haven Center for Independent Living, Philippines

Lumière Synergie pour le Développement, Senegal

Mangrove Action Project, USA

MATI, Bangladesh, Bangladesh

Mekong Watch, Japan

Nash Vek PF, Kyrgyzstan

National Hawker Federation, India

Nuclear/Coal-Free Bataan Movement, Philippines

ONNOCHITRA FOUNDATION, Bangladesh

Oyu Tolgoi Watch, Mongolia

Pakistan Fisherfolk Forum, Pakistan

Participatory Research & Action Network- PRAAN, Bangladesh

Peace Point Development Foundation-PPDF, Nigeria

Philippine Movement for Climate Justice (PMCJ), Philippines

Recourse, Global

Rivers without Boundaries Coalition, Mongolia

Rivers without Boundaries International Coalition, Regional

Safety and Rights Society (SRS), Bangladesh

SoDESH, Bangladesh

Songshoptaque, Bangladesh

SRIJONY Mohila Lok Kendro, Bangladesh

Terranusa Indonesia, Indonesia

Transparency International Anticorruption Center, Armenia

Trend Asia, Indonesia

Urgewald, Germany

Uzbek Forum for Human Rights, Germany/Uzbekistan

WALHI (Wahana Lingkungan Hidup Indonesia), Indonesia

ADB EPR 2025 Submission_ Calls and Demands_NGO Forum on ADB.pdf

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