Dec 11, 2021–Trend Asia along with dozens of civil society organizations around the world sent a statement to the World Bank. This joint civil society submission to the comment period for the World Bank’s Development Policy Financing (DPF) Retrospective July 2015 to July 2021. It consists of four sections: (1) raise broader issues with the Retrospective process; (2) highlight overarching concerns with the DPF instrument itself; (3) articulate key select thematic issues where the World Bank is attempting targeted policy interventions via DPF; and (4) provide recommendations. The submission complements individual submissions to the Retrospective made by some of the civil society organisation (CSO) signatories.

The 2021 DPF Retrospective has been undermined by repeated delays in the process (the Operations Policy and Country Services communicated to civil society in mid-2020 that the review would take place later that year), as well as general lack of clarity about the purpose and scope of the review. The public-facing web page for the DPF Retrospective merely notes that, “The World Bank systematically distills lessons from DPF Retrospectives as part of an ongoing effort to learn from implementation.” There is no explanation of how the World Bank will use comments that are provided by civil society, or the public at large, as part of the Retrospective comment period, despite this being recommended in the Bank’s own consultation guidelines.

There is also no clear rationale provided for the scope of the review and why some issues have been selected instead of others. As noted in a separate CSO statement published earlier this week on the IDA20 and DPF Retrospective consultations: “given civil society’s longstanding calls for the DPF retrospective and, in the light of the instrument’s importance, particularly in the pandemic response context, it was surprising to discover that civil society has been invited to provide input into the retrospective’s Executive Summary….No effort was made by the World Bank to seek input into the review’s methodology or design.” This follows civil society earlier this year being asked to provide comments on a PowerPoint overview of the World Bank’s new Climate Change Action Plan for 2021-25, rather than a full draft of the strategy.

Taken together, these public comment periods give the strong impression that the World Bank currently sees engagement with civil society largely as a box-ticking exercise, rather than as an opportunity for much-needed institutional reflection and learning designed to address shortcomings in Bank policies. This is particularly concerning in the case of the DPF Retrospective because, as will be outlined in the remaining sections, there are serious questions for the Bank to answer in terms of whether the governance oversight and policy reforms currently associated with DPF lending are fit for purpose.

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