Background
The IFC & MIGA Independent Accountability Mechanism (CAO) Policy requires the International Finance Corporation (IFC) and Multilateral Investment Guarantee Agency (MIGA) Boards to initiate a review of the CAO Policy no later than five years after its effective date (July 1, 2021). In connection with that commitment and considering the relevance for, and timeline of, the work of the Task Force on Integration of World Bank Group Accountability Mechanisms (the “Task Force”), the IFC and MIGA Boards commissioned a targeted review of the CAO Policy (the Targeted Review) on an accelerated timeline.
The Review Team is working in close coordination with the Task Force to ensure that relevant findings and recommendations from the CAO Targeted Policy Review are considered by the Task Force.
Objective
The Targeted Review aims to address questions on five key issues jointly identified by CAO, IFC, and MIGA and, where possible, provide an evaluative assessment and recommendations for potential enhancements, if any:
1) Financial Intermediary (FI) eligibility criteria: Are the additional criteria and process for determining the eligibility of FI complaints fit-for-purpose? What is working well and what aspects could be enhanced, if any?
2) Referrals/Deferrals of complaints to IFC/MIGA: Have referrals and deferrals of complaints to IFC/MIGA been effective instruments for early resolution? Have these instruments worked as intended? Are adjustments needed to enhance these instruments?
3) IFC/MIGA participation in the Dispute Resolution (DR) process: What has been the experience with IFC/MIGA participation in the DR process for different stakeholders [1], including for IFC/MIGA? What has been working well? What are the opportunities for enhancement, if any?
4) Management Action Plans (MAPs): What has been the experience of different actors with the preparation, consultations, approval, and implementation of MAPs in response to CAO compliance investigations? Is the MAP process fit-for-purpose? What opportunities are there for enhancement, if any? Are there parts of the process that currently do not have timelines, where a timeline or suggested timeline might be useful?
5) Timelines: What has been the experience of different actors with timelines set out in the CAO Policy? How have the new timelines in the CAO Policy supported predictability and responsiveness in the complaint-handling process? Are any adjustments needed to enhance predictability and responsiveness?
Review Team and Mandate
The Boards selected two internationally renowned experts, Ms. Renosi Mokate and Mr. Roland Michelitsch (“the Review Team”), to conduct this Targeted Review to inform the Boards’ discussions on any needed Policy adjustments and to serve as one input to the Task Force. This Targeted Review will inform and does not replace the comprehensive review required by the CAO Policy.
The Review will be guided by the following principles: improved effectiveness; no regression of Policy and mandate while taking care to keep the strength of the CAO and not weaken accountability; external stakeholder consultations; safeguard the independence of the CAO; enhance the CAO’s leadership in the field; and transparency and ensuring that all stakeholders are transparent about the process and decision-making.
Approach
The Review Team will gather input and information on the five key areas by assessing relevant documentation and conducting in-depth reviews of selected cases. Case reviews will include consultations with external stakeholders, particularly clients, complainants, and, where relevant, outreach to host country government agencies. The Review will examine CAO complaints handled since the CAO Policy took effect in July 2021, with emphasis on FY2022–2025. For comparisons with pre‑FY2022 practice, the Review Team will primarily rely on existing reports.
The Review Team will then produce a draft report with findings and recommendations for discussion, summarizing key observations for each focus issue, including stakeholder perspectives, implementation experiences, and any areas of ambiguity or inconsistency. Feedback on the draft report will be sought from internal and external stakeholders before a final report is produced for the Board. Upon producing a final report, the Review Team will also provide a summary of the feedback received in the public consultations
Timeline
- November 2025 - January 2026: Gather input and information on the five key areas
- January - February 2026: Develop findings and recommendations for discussion
- March - April 2026: Hold public consultations on the draft report
- May 2026: Produce a final report for Board consideration
Further information on the Review Team’s approach and work plan is available here: Scoping Report
Written comments and questions should be sent to CAO Policy Review Team caopolicyreview@worldbankgroup.org
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[1] Stakeholders include IFC/MIGA, CAO, complainants, civil society representatives, and clients/sub-clients, as appropriate involved in the process under review.
Last Updated: Jan 30, 2026