Agence Française de Développement’s Environmental & Social Complaints Mechanism Falls Short of Good Practice

Agence Française de Développement (AFD), a French public financial institution that implements France's official development assistance and diplomatic policies, recently concluded the public consultation process for its Environmental & Social Complaints Mechanism (CM) policy review. Accountability Counsel, the Coalition for Human Rights in Development’s Defenders in Development Campaign, and several civil society organisations submitted joint written comments in June, setting out recommendations on how to strengthen the policy.

AFD operates in 115 countries and has a financing capacity of over EUR 12 billion each year, which further leverages another EUR 12 billion of private and public co-financing. Its projects span across many sectors, including infrastructure, agriculture, energy sectors. In particular, AFD resumed direct investments in the mining sector in 2025, reflecting EU’s strategic priorities in securing a diversified and sustainable supply of transition minerals. 

Given that many sectors AFD invests in are associated with higher environmental and social risks to people and the planet, it is essential that AFD CM provides an independent, accessible and predictable grievance channel for communities harmed by AFD-supported projects to raise concerns and seek redress. Unfortunately, the draft CM policy does not currently provide a solid basis for an effective complaints process. 

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Draft CM Policy Significantly Lags Behind Good Practice, including AFD’s own Proparco

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In May 2026, the CM released its draft updated Rules of Procedure (Rules) for public consultation. The Rules significantly lags behind peer independent accountability mechanisms at other development finance institutions, particularly with respect to the mechanism’s independence and accessibility, as well as the strength of its mandate to deliver remedy to projected affected communities. 

Notably, the Independent Complaints Mechanism (ICM) of Proparco, the AFD Group subsidiary dedicated to private sector investments, has a much stronger policy which came into effect in March 2026 following public consultation. Given the similar governance structure of Proparco, the ICM offers an important benchmark for what accountability can and should look like at a bilateral public development institution.

A fundamental flaw of the CM Rules is the explicit exclusion of the provision of both monetary and non-monetary compensation as a possible remedy the CM process could offer complainants. This is fundamentally incompatible with the CM’s remedy mandate and its adherence to the effectiveness criteria set out in the UN Guiding Principles on Business and Human Rights. While AFD should rightfully play a crucial role in using their leverage over Beneficiaries to facilitate the delivery of remedial actions by Beneficiaries directly, its ultimate role is to enable and ensure remedy. This could and should include directly remedying harms which it has caused or directly or indirectly contributed to, especially if the Beneficiary is not participating constructively in grievance redress and remedial actions. We strongly urge AFD to follow the standard practice, including at Proparco, and delete any such exclusion of compensation from possible remedies.

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The CM Needs More Direct Board Oversight and Better Safeguards Against Management Influence 

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When it comes to the mechanism’s independence, the CM differs from most IAMs in that its secretariat is a one-person team supervised by AFD’s Ethics Advisor and does not have distinct teams of staff for its two main functions, compliance audit and conciliation. It instead entirely relies on outside consultants to conduct eligibility assessments, act as conciliation or compliance experts, and conduct monitoring and reporting. The thin staffing presence of the CM secretariat makes it even more important that the Rules contain robust safeguards to ensure the independence of the Ethics Advisor and the Head of the CM Secretariat. 

Unfortunately, the current governance structure, reporting line and decision-making powers of the CM casts doubt on the CM’s independence on paper and in practice. If communities and CSOs perceive a mechanism to be beholden to or unduly influenced by management, when it is meant to either investigate management’s alleged noncompliance with institutional policies or facilitate conciliation dialogues as a neutral party, they will be less likely to use it. 

We urge the CM Rules to, amongst other things, (1) make the CM Secretariat (under the supervision of the Ethics Advisor) the ultimate adjudicator of eligibility and closure decisions, and (2) create a direct reporting line to the AFD Board, rather than the Steering Committee made up solely of representatives from internal AFD departments, and entrust the Board with the approval of the CM budget.

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The CM Must Allow A Broader Range of Complaints

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Despite some improvements in allowing the resubmission of inadmissible complaints and loosening the requirement for prior engagement with project-level grievance mechanisms, a number of key barriers exist for project-affected communities that could prevent the CM from being a viable  grievance avenue. 

The draft policy currently prevents complaints from proceeding if other venues have also received complaints.The CM is the only venue that can determine AFD’s compliance with its own policies and instigate its own internal institutional learning of systemic shortcomings of the implementation of AFD policies as part of its continuous improvement mandate. As such, it should allow cases to proceed even if there are parallel proceedings in judicial forums or at a peer IAM which have delivered some remedies to complainants.

The CM should also allow communities to convey early warning of credible risks of harm potentially overlooked by environmental and social assessments relating to projects currently being considered for financing, something the Proparco ICM allows. While the AFD operations, investment, risk and compliance teams should certainly be part of the dialogue, the CM is designed with the independence to be a neutral adjudicator for whether AFD’s own operations and decision-making had resulted in noncompliance with AFD policies and harm.

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The CM Should Commit to Public Consultation for each Review

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Previous revisions to the CM policy have occurred without public consultation, which is contrary to standard IAM practice. Accountability Counsel commends AFD for subjecting this important review and revision process to public consultation, and urges the CM to enshrine the commitment to public consultation and a minimum length of 40 business days for the consultation on every future revision process in the Rules.

We hope AFD will now incorporate civil society and external stakeholder feedback into its final CM Rules, such that it reflects the institution’s commitment to true accountability.

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