The ICM Policy Review & Update
The DFIs are committed to regularly reviewing and, where necessary, updating the ICM Policy to ensure it stays robust, effective, accessible, and properly structured to guide the complaints process, while serving the needs of stakeholders as intended.
ICM Policy Review (2022-2023)
In 2022, the Management Boards of the DFIs started the review process by commissioning a report from an independent expert. The purpose of the report was to advise the DFIs on key policy gaps, issues and opportunities and to build consensus among the DFIs around areas of policy revision.
The Policy Review report made broad-based recommendations for change in light of accepted good international practice and key stakeholder concerns and interests. It included a document review, DFI peer benchmarking, and stakeholder interviews.
ICM Policy Update (2024-2025)
The Policy Review report (as mentioned above) was finalized in 2023 and, based on its recommendations, the Policy Update process commenced in 2024.
A joint working group was established consisting of the Independent Expert Panel members that form part of the ICM, and representatives from the DFIs. This group was responsible for drafting the revised ICM policy and integrating feedback from various stakeholders. The process was facilitated by an independent external consultant with the aim of reaching consensus on a revised ICM policy.
It was agreed that where the Independent Expert Panel and the DFIs did not reach consensus, the Independent Expert Panel would highlight their differing views in the Draft ICM Policy when shared for public consultation. The differing views of the Independent Expert Panel are shown in grey comment boxes in the draft policy text and stakeholders can share their opinion on these as part of the Public Consultation.
ICM Public Consultation (Aug – Oct 2025)
During the ICM Policy Update process, some external stakeholders (including NGOs and experts) were consulted and, to ensure the successful implementation of the revised policy, the DFIs committed to conducting a meaningful public consultation process.
The ICM Public Consultation included informing and engaging with stakeholders on email and through this website, receiving feedback on the Draft ICM Policy through an online questionnaire, and through dialogue during regional webinars and in-person events. These efforts were aimed at engaging both internal and external stakeholders, as well as members of the public, to gather valuable input on the Draft ICM Policy.
The ICM Public Consultation began on Wednesday 20 August 2025 and concluded on Friday 17 October 2025.
ICM Policy Final Update & Board Approval (Nov 2025 – Q1 2026)
The input and comments submitted by stakeholders during the ICM Public Consultation are being collated and summarized, and will published on this website, and on the respective DFI web pages, in the coming weeks. It should be noted that attribution to an individual or entity will automatically be removed prior to sharing it internally or including it in any public consultation report.
The joint working group responsible for drafting the Draft ICM Policy (i.e. the ICM Independent Expert Panel and representatives from the DFIs) are engaging in a collaborative process, facilitated by an independent external consultant, to consider the findings and prepare a final version of the ICM Policy.
The final version of the ICM Policy will be approved by the Boards of the DFIs in December 2025 /early January 2026, and will become effective on a date to be agreed by the institutions (but expected within the first quarter of 2026).