NGO Forum on ADB Draft AIIB PPM Recommendations

NGO Forum on ADB
Sep 30
6 min read

The Asian Infrastructure Investment Bank’s (AIIB) Project-affected People’s Mechanism (PPM) is intended to provide a forum for communities and stakeholders to seek redress for harms linked to AIIB-financed projects. However, the current draft PPM policy falls short in several critical areas, limiting access, weakening independence, and failing to ensure effective remedies. Drawing on the NGO Forum on ADB’s experience with accountability mechanisms, these recommendations identify key gaps and propose concrete measures to strengthen eligibility, procedural fairness, independence, remedial action, monitoring, and transparency—ensuring that affected communities have meaningful, timely, and enforceable avenues for redress.

1. Narrow scope of coverage, definition of harms

The draft PPM remains explicitly limited to alleged failures to implement the Environmental and Social Policy (ESP), excluding all other AIIB policies and directives. This means harms arising from non-compliance with AIIB’s Public Information Policy, Energy Sector Strategy, procurement rules, or broader governance fall outside the PPM’s jurisdiction (forum-adb.org, aiib.org). Complainants whose grievances stem from, for example, a lack of disclosure or misprocurement will find no forum for redress.

Firstly, we strongly recommend to broaden who/what counts as “harm.” Make eligibility explicit for indirect and diffuse harms—including biodiversity, cultural heritage, and other global public goods—so communities aren’t excluded just because impacts aren’t linear or individualized.

2. Complex and legalistic procedures

In line with Forum network observations, the draft’s language on eligibility, exceptions, and remedies remains highly technical and legalistic. Communities without legal support will find it difficult to navigate requirements such as demonstrating “failure to implement the ESP” or responding to detailed Secretariat inquiries. Poor translation of local versions risks further misunderstanding.

Also, establish accessible digital complaint channels, including online forms, mobile-friendly portals, and local-language support, to ensure inclusivity for remote or isolated communities.

3. Eligibility recommendations

Drop the “direct and material” burden on requestors. Communities should not have to prove materiality or directness up front; they should only need to explain the harm from an AIIB-financed project, consistent with AIIB’s ESF access standard.
Remove mandatory detours through Project-Level Grievance Redress Mechanisms (PL-GRMs) when unsafe or ineffective. The draft still forces communities toward project-level GRMs that they don’t trust, can’t fix structural design issues, and may expose them to retaliation—that requirement should be eased with clear, blanket exceptions.
Hard-wire anti-retaliation and confidentiality—with a process. Strengthen the rules so confidentiality and retaliation risk-assessment are operationalized (who does what, when), not just aspirational—and mirror these guarantees in the policy, not only in Rules of Procedure (ROP) comments.

Current Policy Language	Problem	Recommended Fix
“Two or more people” must file	Excludes isolated or vulnerable individuals	Allow individuals or CSOs with consent
No clear filing time limit	Creates uncertainty about when complaints are valid	Define fixed window
Co-financed project clause	Blocks legitimate AIIB-linked grievances	Permit if AIIB ESF failure/non-compliance is involved
“Material adverse effect” undefined	Vague threshold leads to arbitrary decisions	Add clearly defined direct and indirect harms, with examples of harm types
Legal jargon throughout	Not accessible to grassroots communities	Add simplified eligibility criteria checklist

4. Pre-conditions and “Good Faith” Barrier

The requirement to exhaust project-level GRMs and make “good faith efforts” with AIIB management remains in the draft. This double barrier effectively grants Management veto power over admissibility and echoes the experience in the Bhola IPP case, where the only complaint was deemed ineligible on this basis (forum-adb.org). Affected individuals face a catch-22: they must either engage and risk retaliation or delay or forgo redress altogether.

3 criteria in 4.1 identified for exclusion- 1) non-functioning GRMs, 2) Lack of timely and meaningful response by Management, 3) Risk of retaliation are appreciated, but they require further procedural detail to ensure no subjective or biased interpretations of these 3 criteria lead to the dismissal of complaints.

5. Insufficient independence of CEIU

The PPM has no fixed term or cooling-off period for the CEIU head, no transparent selection process involving external stakeholders, and Secretariat staff are still appointed by Management. Complainants cannot be certain that PPM led investigators are insulated from institutional bias.

6. No Self-Initiation or Third-Party Complaints

The mechanism remains entirely reactive. It cannot be initiated by the CEIU or Board based on credible evidence of systemic ESP breaches. Systemic harms affecting vulnerable groups risk being overlooked if they do not or cannot file themselves.

In addition, ensure direct and timely Board access in urgent harm situations. “Unimpeded access” must mean that the PPM can escalate irreversible risks to the Board rapidly—without being forced through serial, time-wasting steps via Management and the President.

7. Weak Remedy and Non-Binding Recommendations

Under both the current policy and the draft, the PPM can only recommend remedial action. There is no process to make these recommendations binding, impose sanctions for non-compliance (e.g., suspending disbursements), or fund independent monitoring of action plans (forum-adb.org). Communities may suffer harm indefinitely, even after a favourable review.

To address this gap, the policy should clearly specify what a good MAP looks like. It should require clear, time-bound actions designed to return the Bank to compliance and deliver remedy; include requestors’ feedback on adequacy and satisfaction; and have the Board approve the MAP.

9. Exclusion of Co-Financed Projects

Almost half of AIIB’s portfolio is co-financed, and the draft still allows blanket exclusion of such projects from PPM access when co-financier policies apply. This creates significant accountability gaps: communities cannot challenge AIIB’s role in co-financed projects even where co-financiers’ own IAMs do not cover AIIB’s actions.

PPM must be open for co-financed cases. Even when AIIB “relies on” a co-financier’s IAM, PPM should still be able to receive complaints and facilitate remedial action for AIIB-linked harms.
Mandatory Management report when a co-financier finds non-compliance. If the co-financier’s IAM issues non-compliance findings, AIIB Management must submit a report to the Board that (i) spells out implications for AIIB, (ii) identifies concrete opportunities for remedy to affected communities, and (iii) captures institutional learning—with the PPM given a formal chance to comment before finalization. Both the report and PPM’s comments should be presented to the Board and disclosed on the complaints registry.
Ongoing transparency and coordination. When AIIB relies on a partner IAM for a co-financed project, PPM should still provide regular updates to the Board (and public registry) on the complaint’s handling and outcomes, ensuring AIIB’s accountability isn’t outsourced.

10. Levelling the playing field during problem-solving and compliance review

During the course of investigations, all interlocutors, translators, and consultants must be engaged with the consent and perspectives of the complainants and CSO representatives. The formation of any selection committee must include complainants and CSO representatives with equal power as project developers during problem-solving negotiations to ensure fair input and decision-making authority. The selection of venues and agenda setting for consultations during and PPM-led investigations must be conducted in co-creation with the complainants and CSO representatives, to guarantee that unbiased and meaningful consultations are held without any form of oppression or coercion in the proceedings.

11. PPM monitoring capabilities

To ensure that remedial actions are credible and effective, the PPM’s role must be reinforced with independent authority, continuous monitoring, and stronger Board reporting -

Independent monitoring without Board pre-clearance. PPM should be able to verify Management Action Plan (MAP) implementation on its own authority, especially when non-compliances are material or MAP implementation stalls—rather than waiting for a fresh Board approval that slows or blunts oversight.
Monitor until the remedy is delivered. PPM’s mandate should extend through full remediation of all non-compliances, with the ability to recommend course corrections when MAP actions are delayed, inadequate, or off-track.
Verification reports to the Board. PPM should file verification reports that document the status of MAP actions, explain delays or failures, and distil lessons for institutional reform—ensuring the Board has an independent line of sight, not just Management’s self-reporting.
Routine, not “exceptional,” oversight. Independent verification should be normal practice for higher-risk cases, not an “exception” that requires extra Board gatekeeping; this is essential for timeliness, cost-effectiveness, and credibility with communities.

12. Policy Review needs a clear timeline needed

The policy must have clear, binding language with an explicit 5-year review mandate. Revise the Rules of Procedure with public input. The ROP controls eligibility, timelines, confidentiality/retaliation, disclosure, and co-financing: it must be updated (first time since 2019) with at least a transparent public consultation process on a draft.