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

The document argues that the GCF's proposed safeguards are insufficiently detailed and overly reliant on the IFC Performance Standards, which the authors claim do not represent international best practice. It advocates for a differentiated accreditation system based on project risk levels, the adoption of a mandatory 'do no harm' principle, and the creation of an 'exclusion list' for high-risk activities such as fossil fuel extraction. The submission emphasizes that environmental, social, and gender safeguards must be developed with the same rigor and independent oversight as fiduciary standards, specifically calling for mandatory requirements on land tenure, indigenous peoples' free, prior and informed consent, and gender-responsive stakeholder engagement.

• The GCF should implement a differentiated accreditation system where requirements become more stringent as the environmental, social, and gender risks of a proposal increase, allowing low-risk programs easier access while maintaining rigor for complex activities.
• The authors argue that the IFC Performance Standards are not the international best practice and should not be the sole basis for GCF safeguards, suggesting instead a combination of the most robust standards from various international financial institutions and human rights treaties.
• There is a significant imbalance between the detailed, mandatory nature of fiduciary standards and the vague, high-level nature of environmental and social safeguards; the latter must be developed with equal rigor and independent audit requirements.
• The GCF is urged to adopt a strict 'do no harm' approach, which includes refusing to fund activities with significant social, gender equity, or environmental risks.
• The submission recommends the creation of an 'exclusion list' to explicitly prohibit funding for certain high-risk activities, specifically mentioning the extraction and refinement of fossil fuels.
• The document highlights a critical need for specific safeguards regarding land tenure and the requirement for the free, prior and informed consent of indigenous peoples for any activities impacting their lands or resources.
• The authors criticize the GCF's reliance on self-assessment and self-reporting by implementing entities, citing a 2012 IFC audit that showed such systems failed to track actual environmental and social results at the sub-client level.
• The submission calls for the integration of comprehensive, gender-responsive standards for transparency, information disclosure, and grievance mechanisms to ensure affected communities have access to redress.

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} }