ICM PUBLIC CONSULTATION

ICM Policy Review & Update (2022-2025)

The DFIs are committed to regularly reviewing and, where necessary, updating the ICM Policy to ensure it remains robust, effective, accessible, and properly structured to guide the complaints process, while serving the needs of stakeholders as intended.

In 2022, the DFI Management Boards launched the ICM Policy Review process and appointed an independent expert to conduct a high-level review of the ICM Policy—including document analysis, peer benchmarking, and stakeholder interviews— and produce a report identifying key policy gaps, issues, and opportunities. The report also helped build consensus among the DFIs on the priority policy areas for revision. The Policy Review Report was finalized in 2023 and made broad recommendations in line with accepted good international practice and in response to stakeholder concerns and interests.

The ICM Policy Update Process was initiated in 2024, during which the DFIs consulted a select group of external stakeholders—including non-governmental organizations and subject-matter experts—on the ICM Policy. Subsequently, a joint working group —comprising the ICM Panel and DFI representatives— was established to reflect on stakeholder feedback, consider the recommendations of the Policy Review Report, and begin preparing the Draft ICM Policy.

The drafting process was facilitated by an independent external facilitator with the aim of reaching consensus on the proposed policy revisions. It was agreed that where the ICM Panel and the DFIs did not reach consensus, the Panel would highlight their differing views in the Draft ICM Policy when it was shared for public consultation, and stakeholders would be encouraged to share their views on the outstanding points.

The Draft ICM Policy was approved for formal public consultation by the DFI Management Boards in July 2025.

ICM Public Consultation (Aug – Oct 2025)

The ICM Public Consultation began on Wednesday 20 August 2025 and concluded on Friday 17 October 2025.

The primary aim of the Public Consultation was to seek feedback on the Draft ICM Policy prior to its finalization and adoption by the DFIs, to ensure it meets the needs of its intended stakeholders and can be effectively implemented by the DFIs and the ICM Panel.

During the 8.5-week consultation period, a diverse range of stakeholders — including national and international non-governmental and civil society organizations, peer financial institutions, independent accountability mechanisms, DFI clients, and subject matter experts — provided substantive feedback on the Draft ICM Policy.

Feedback was received in writing through 13 formal submissions representing 34 unique organizations and individuals, and verbally through a series of regional webinars and in-person meetings attended by over 50 individuals representing all key stakeholder groups and geographies. A summary report on the ICM Public Consultation activities is available for download here: ICM Public Consultation Activity Report.

ICM Policy Final Update & Board Approval (Nov 2025 – Q1 2026)

The joint working group has continued its collaborative process to review all stakeholder feedback and finalize the ICM Policy.

The ICM Policy will be finalized following approval of the Management Boards and endorsement by the Supervisory Boards of the DFIs, anticipated in December 2025.

A formal response to stakeholders will be published with the final ICM Policy and it will detail how feedback has been considered and integrated. The updated ICM Policy is expected to come into effect in the first quarter of 2026, with further details be provided with the formal response.