To determine how to achieve their goals, the IFIs periodically set broad institutional policies. The institutions target their priority goals, conduct research, draft new policies and approve them through a multi-stage process. The outcomes of these efforts – on topics such as whether to lend to the oil and gas industries, how to be more supportive of sustainable development, what disclosure policies should say – have sweeping ramifications for many years.
The processes for setting these institutional policies go by many different acronyms, but they are broadly similar among the IFIs. Sometimes this sort of policy-setting is referred to by the phrase “policy and sectoral work.”
The degree to which the public is involved, and the availability of documents varies somewhat by institution. However, overall the IFIs maintain a tight grip on information about ongoing policy-setting projects, draft documents, proposals to the board, and eventual self-assessments.
To begin with -- aside from rumors of impending internal reviews, speeches and other informal indications of upcoming activity -- the onset of IFI action on a new policy formulation effort is not marked by official announcements, such as a notice of intent to review a particular area. Officials describe their approach to making early announcements as “ad hoc.” The nascent trend towards issuing more future board work programs and agendas may help in this area. The EBRD and the ADB lead the pack, as the EBRD has a policy of posting planned sectoral reviews on its website and of maintaining a mailing list for those without Internet access, and the ADB makes available a list of policies under review or to be developed on a roling basis.
As the institutions plan their process for reviewing or developing a particular policy, the procedures and timelines for decision-making may or may not be revealed. Similarly, many IFIs fail to say whether there is a plan for seeking external comments and how these consultations will work. After topics are picked, IFI staff conducts research, prepare drafts, and sometimes hold consultations. Sometimes special outside panels are involved. Records of those consulted and/or comments received from the public are not always revealed as the process unfolds, and no IFIs have actual policies on this. Access to the background research materials, including commissioned outside work, is often denied or limited, even after the decisions have been made.
Draft versions of the proposed policy are sometimes disclosed. When an early draft is issued, it typically will be accompanied by an invitation for public comment, often with comment periods of as little as one month. Some IFIs have virtually no set guidelines on releasing such drafts, including the ADB (although a few have been issued), the EIB, the IFC (although it releases some drafts), the IIC, the IMF (although it sometimes does) and MIGA.
On the other hand, the AfDB promises to release draft policy papers at least 50 days in advance of board consideration. The IDB reserves the option of disclosing drafts “when appropriate.” The EBRD has a policy of disclosing draft sectoral strategies, with comments due in 45 days. The EBRD, however, does not extend this policy to cover crafting of their long- and medium-term general policy strategies. Also positively, at the World Bank an “initial draft concept note for a sector strategy paper,” must be disclosed, and initial drafts of operational policies also are disclosed in draft form.
Disclosure of public comments on policies under development is spotty, and often their release is delayed. Few IFIs post the public comments promptly on their web sites. And there may be further restrictions. The EIB said it would release comments from institutions, but not from individuals. Some IFIs summarize outside comments in a separate document that may be released around the time of board action, or afterward. The ERBD only issues a summary of the comments after board approval. These summaries sometimes are accompanied by detailed point-by-point IFI staff rebuttals and comments.
After digesting outside and internal comments, orthodox-operating procedure results in a report and/or proposed policy for board consideration. This is often referred to as a final draft board policy, and is widely circulated within the institution, but not necessarily outside. They are often sent to the board weeks in advance of their docketed date for consideration. Only at the ADB and the IDB, under certain circumstances, release of these final drafts is possible. In only a few cases are members of the public able to track the final staff recommendations to the boards prior to approval.
Once a board decision is made, disclosure of most policies and sectoral strategies is near universal. But information about the board discussion, via open meetings, transcripts, summaries, or minutes is rare in any of those forms, though the ADB has begun to disclose a Board chair's summary of discussions regarding policy reviews. The weakest practices regarding disclosure of final decisions are those of the AfDB, the EBRD (with regard to medium- and long-term strategies) and the private lending wings (IIC, IFC, and MIGA).
As policies mature and the IFIs conduct reviews, the results are uncommonly disclosed, at the discretion of the institution.
All told, the processes used by the IFIs to set their broadest policies proceed with limited opportunities for participation and minimal documentation.