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The report details the 2023 compliance monitoring of GCF accredited entities (AEs). Of 48 AEs required to submit annual self-assessments, 89.6% reported changes that either had no impact or positive impacts on their accreditation status. Midterm reviews (MTRs) for 14 AEs were conducted, with 11 completed, generally confirming continued compliance with fiduciary, environmental and social safeguards (ESS), and gender standards. Additionally, 27 international access AEs (IAEs) reported providing over 444 cases of support to direct access entities, primarily focusing on building track records (48.9%) and meeting accreditation standards (48.6%).

The Independent Integrity Unit (IIU) reported progress on its 2024 Work Programme between June and September 2024, focusing on the development of an integrity policy framework, the management of internal and external investigations, and global outreach. Key activities included drafting Administrative Remedies and Exclusion (ARE) documents, finalizing a Capacity-Building Strategy, and preparing for the November 2024 GCF Integrity Forum. During the reporting period, the IIU opened 16 new cases and closed 13, while engaging in international anti-corruption forums and regional dialogues to foster a culture of integrity in climate finance.

The Independent Integrity Unit (IIU) report details its activities from January to June 2024, focusing on four strategic objectives: fostering a culture of integrity, acting as a thought leader in climate finance integrity, serving as a trusted investigation mechanism, and utilizing technology for data-informed decision-making. Key achievements include the launch of an e-learning module for Accredited Entities, the conduct of a regional capacity-building workshop in Morocco for African entities and CSOs, and the opening of 17 new cases. The unit also advanced its policy framework by drafting guidelines for Administrative Remedies and Exclusion (ARE) and managing conflicts of interest for external panel members.

The document outlines a 24-month readiness program (April 2024 to March 2026) implemented by the Global Green Growth Institute (GGGI) for Ethiopia. It focuses on four main areas: building the capacity of the Ministry of Planning and Development (the new NDA) and the Ministry of Finance; supporting the pre-accreditation of the Development Bank of Ethiopia (DBE) to access the GCF Private Sector Facility; establishing essential coordination mechanisms including a No-Objection procedure and an operational manual; and developing a GCF Country Programming Document and two high-quality project concept notes based on pre-feasibility studies. The program also includes the creation of a knowledge management portal and international learning visits to countries such as Rwanda, South Africa, or Tanzania.

The GCF Accreditation Panel recommends the accreditation of Bancóldex, a Colombian state-owned development bank, as a national direct access entity. The bank is recommended for a 'medium' project size category (USD 50 million to USD 250 million) and a 'medium' environmental and social risk category (B/I-2). While Bancóldex demonstrated strong fiduciary capacities in project management, grant allocation, and on-lending, the panel identified gaps in whistleblower protection, gender policy, E&S information disclosure, and grievance redress mechanisms. These gaps are framed as conditions for accreditation to be met either before the master agreement becomes effective or before the first funding proposal is submitted.

ClientEarth submits evidence to the UK Work and Pensions Committee arguing that current fiduciary duty legislation is too narrow, leading trustees to prioritise short-term returns over systemic climate risk management. The organisation recommends statutory duties to manage risks to the portfolio as a whole and to assess the real-world impacts of investments on society and the environment, aligning UK practice with European standards and UN human rights principles.

ClientEarth brought a derivative action against Shell's Board of Directors in the High Court of England and Wales, arguing that the company's Energy Transition Strategy was inadequate and breached sections 172 and 174 of the Companies Act 2006. The claim alleged failures in setting Scope 3 targets, over-reliance on carbon capture and nature-based solutions, and non-compliance with a Dutch court order. Despite support from institutional investors managing over half a trillion USD in assets, the High Court refused permission to continue the claim, citing a lack of formal expert evidence and the wide discretion afforded to directors in management decisions. The Court of Appeal subsequently refused permission to appeal this decision.

ClientEarth advises a UK pension scheme's trustees to cease providing bond capital to energy companies unless they have credible net-zero transition plans and enforceable bond covenants. The letter asserts that climate change represents a material financial risk—including physical, transition, and litigation risks—that trustees must manage to meet their legal fiduciary duties and protect beneficiaries' interests.

The Green Climate Fund's Accreditation Panel recommends the re-accreditation of the Food and Agriculture Organization of the United Nations (FAO) for a second term, maintaining its scope for medium-sized projects and medium environmental and social risk (Category B). The assessment confirms FAO's strong technical expertise in adaptation, REDD+, and the blue economy, and its ability to implement GCF's gender and environmental and social policies. While generally compliant, the Panel identified a gap in explicit policy statements regarding Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT), making the re-accreditation conditional upon the formal approval of an AML/CFT policy or the inclusion of consistent statements within its prohibited practices policies.

The document defines greenwashing in the financial sector as false or misleading representations of environmental impact and warns that it can misallocate capital and undermine the Paris Agreement. It outlines five categories of evolving regulation—disclosure, labelling, ratings, taxonomies, and net zero integrity—and classifies enforcement actions into brand, product, financing, and reporting greenwashing. To mitigate risk, the guide proposes 'five pillars' of guarding against greenwashing: screening claims, ensuring transparency, aligning internal actions with public image, monitoring regulatory changes, and adhering to fiduciary duties.

The document outlines a readiness project to enhance Lao PDR's access to climate finance by accrediting two national financial institutions. The project focuses on capacity building, institutional gap analysis, and knowledge sharing to enable these entities to provide on-lending and blending fiduciary services. It includes technical assistance to meet GCF standards, the development of a project pipeline, and an international learning visit to other successful DAEs in Southeast Asia.

The GCF's direct access modality, primarily operationalized through institutional accreditation, has largely failed to enable a diverse range of national entities to access funding at scale. While the number of Direct Access Entities (DAEs) has grown, the portfolio remains highly concentrated among a few well-resourced financial institutions, with 63% of DAEs having no approved projects. The report finds that the high transaction costs of accreditation and project design favor high-capacity institutions, while support mechanisms like the Readiness and Preparatory Support Programme (RPSP) and Project Preparation Facility (PPF) have not effectively leveled the playing field. Implementation challenges for DAEs are similar to those of International Accredited Entities (IAEs), though DAEs show better adaptability to national governance disruptions. The report recommends diversifying access pathways beyond accreditation, clarifying the strategic vision for direct access, and enhancing implementation support.

The Independent Integrity Unit (IIU) report details its activities from September 2022 to February 2023, focusing on investigation efficiencies, policy development, and risk mitigation. During this period, the IIU opened nine new cases, including three project-related and six staff misconduct cases, while closing 11 cases in total. Key operational advancements include the development of a draft Investigation Manual, the issuance of three Management Implication Reports, and the creation of an automated referrals tracker for Accredited Entities and Delivery Partners. The Unit is also operationalising the Administrative Remedies and Exclusion (ARE) Policy through four secondary documents. To enhance risk detection, the IIU expanded its machine learning capabilities, integrating significantly more data into its Integrity Due Diligence Platform and applying a Red Flag Detection Workflow to the Readiness Programme. Additionally, the IIU provided technical assistance to Mongolia and engaged in international forums at COP27 to discuss the intersection of corruption and climate change.

The document outlines a 24-month project implemented by the Global Green Growth Institute (GGGI) to address technical and institutional barriers preventing Vanuatu from accessing direct climate finance. The project focuses on developing an NDA Project Development Handbook, a national accreditation strategy, and strengthening the capacity of the Ministry of Finance and Economic Management (MFEM) to meet GCF fiduciary, environmental, social, and gender standards. Additionally, it aims to develop two high-quality project concept notes and a pre-feasibility study to build a paradigm-shifting investment pipeline.

The document examines the legal mechanics of shareholder climate resolutions in Asia, detailing jurisdiction-specific requirements for filing, voting thresholds, and the role of company charter documents. It highlights a general trend toward increased ESG consciousness and regulatory focus on net-zero transitions in the region, while noting that legal landscapes vary significantly between countries.

The complaint argues that TIAA/Nuveen engages in systematic greenwashing by marketing sustainable ESG products while maintaining substantial holdings in coal, oil, and gas, and acquiring land in Brazil linked to deforestation and human rights abuses. It requests that the PRI Board investigate these practices and require corrective actions, including full divestment from fossil fuels by 2025.

The report identifies subnational pension funds as a significant source of untapped capital for urban climate action, estimating at least USD 9.5 trillion in assets across Brazil, Canada, Germany, the Netherlands, South Africa, the UK, and the US. It details structural barriers such as low risk appetite and limited fund size, as well as external barriers like a lack of bankable project pipelines and ticket size mismatches. To overcome these, the document recommends the use of financial instruments such as blended finance, green bonds, and supply-side aggregation (pooling), while urging funds to make net zero commitments and build internal capacity.

ClientEarth warns EMR Capital that financing the proposed Whitehaven coal mine in West Cumbria poses significant climate-related financial risks and may breach fiduciary duties to investors. The letter highlights the mine's incompatibility with the 1.5°C warming limit and the likelihood of it becoming a stranded asset due to declining demand for coking coal in the UK and EU steel industries. ClientEarth further asserts that the investment contradicts EMR Capital's status as a UN PRI signatory and its own ESG policy, potentially exposing the firm to legal challenges and accusations of greenwashing.

The document outlines a plan to transition the Economic and Social Development Agency (ADES) from a humanitarian organization to a GCF-accredited entity. It identifies critical gaps in ADES's fiduciary standards, environmental and social safeguards (ESS), and gender policies. The proposed 18-month intervention includes updating organizational manuals, training staff on climate finance and GCF investment criteria, and co-developing three project concept notes and one Project Preparation Facility (PPF) request. The goal is to increase Chad's country ownership of climate projects and enhance the implementation of its Nationally Determined Contributions (NDCs) and Country Programme.

The proposal outlines a 24-month program implemented by the Global Green Growth Institute (GGGI) to address gaps in Thailand's climate finance architecture. Key objectives include supporting Kasikornbank's GCF accreditation, updating the 2017 Thailand Country Programme (TCP) to align with the updated NDC and Long-term Low Greenhouse Gas Emission Development Strategy, and creating a national climate finance strategy. A central component is the design of the Thailand Circular Economy Financing Facility (T-CEFF), a blended finance mechanism intended to de-risk investments in Municipal Solid Waste to Energy (MSW2E) and bioenergy projects, targeting a USD 200 million loan portfolio by 2025. The project also aims to refine the National Designated Authority's (NDA) no-objection procedure to better accommodate private sector proposals.