CIVIL SOCIETY SUBMISSION TO THE GREEN CLIMATE FUND ON ACCREDITATION, SAFEGUARDS AND FIDUCIARY STANDARDS

This 2014 submission from a coalition of civil society organizations provides critical feedback to the Green Climate Fund (GCF) on its proposed accreditation system, fiduciary standards, and environmental, social, and gender safeguards. The authors argue that the current framework relies too heavily on the IFC Performance Standards, which they claim do not represent international best practice, and that safeguards lack the detail and mandatory rigor applied to fiduciary standards. The submission advocates for a "do no harm" approach, the adoption of an exclusion list for high-risk activities, and a differentiated accreditation process based on the risk level of proposed projects.

• The GCF should adopt a "do no harm" approach, ensuring it does not fund activities with significant environmental, social, or gender equity risks. Safeguards must be mandatory for all implementing entities and intermediaries, and there must be access to redress for those harmed.
• The submission argues that the IFC Performance Standards are not the international best practice and should not be the sole basis for GCF safeguards. Instead, the GCF should synthesize best practices from various institutions, including the World Bank and Asian Development Bank (ADB), as well as international treaties and human rights conventions.
• There is a significant imbalance between fiduciary standards and environmental, social, and gender safeguards. Fiduciary standards are currently more detailed and rigorous, featuring mandatory external independent audits, while safeguards lack similar institutional-level assessment and external audit requirements.
• The authors support a differentiated accreditation system where requirements become more stringent as the environmental, social, and gender risks of a proposal increase. This would allow low-risk programs to be accredited more easily while ensuring high-risk activities are managed by entities with proven capacity.
• The GCF is urged to implement an "exclusion list" to prevent funding of activities with prohibitively high risks or severe reputational damage, specifically citing the extraction and refinement of fossil fuels as an example of what should be excluded.
• The submission highlights a need for specific safeguards regarding land tenure, noting that tenure is often contested in forested areas targeted for climate finance. It also calls for standards on transparency, information disclosure, and gender-responsive stakeholder engagement.
• The authors warn against over-reliance on self-assessment and self-reporting by implementing entities, citing a 2012 independent review of the IFC's financial intermediary portfolio which found that such models failed to track actual environmental and social impacts.
• The submission recommends that the GCF retain the authority to withdraw accreditation from entities that under-perform or violate safeguard requirements to ensure strong incentives for implementation.

APA

Center for International Environmental Law (2014). CIVIL SOCIETY SUBMISSION TO THE GREEN CLIMATE FUND ON ACCREDITATION, SAFEGUARDS AND FIDUCIARY STANDARDS. https://www.ciel.org/wp-content/uploads/2014/11/Safeguards_CSOs_17Mar2014.pdf

Chicago

Center for International Environmental Law. CIVIL SOCIETY SUBMISSION TO THE GREEN CLIMATE FUND ON ACCREDITATION, SAFEGUARDS AND FIDUCIARY STANDARDS. 2014. https://www.ciel.org/wp-content/uploads/2014/11/Safeguards_CSOs_17Mar2014.pdf.

Wikipedia

{{cite press release |author=Center for International Environmental Law |title=CIVIL SOCIETY SUBMISSION TO THE GREEN CLIMATE FUND ON ACCREDITATION, SAFEGUARDS AND FIDUCIARY STANDARDS |date=17 March 2014 |url=https://www.ciel.org/wp-content/uploads/2014/11/Safeguards_CSOs_17Mar2014.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centerforinternationalenvironmentallaw2014civil, author = {{Center for International Environmental Law}}, title = {{CIVIL SOCIETY SUBMISSION TO THE GREEN CLIMATE FUND ON ACCREDITATION, SAFEGUARDS AND FIDUCIARY STANDARDS}}, publisher = {Center for International Environmental Law}, year = {2014}, month = mar, url = {https://www.ciel.org/wp-content/uploads/2014/11/Safeguards_CSOs_17Mar2014.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }