EBRD Project Complaint Mechanism


Project Complaint Mechanism of the European Bank of Reconstruction and Development

The European Bank for Reconstruction and Development (EBRD) has established the Project Complaint Mechanism (PCM) as part of its commitment to the transparency and accountability of its operations. The PCM gives individuals, organisation and local groups that might be adversely affected by a Bank-funded project a means of raising complaints with the Bank, independently from banking operations. The PCM was launched in March 2010. The PCM website can be accessed at: http://www.ebrd.com/pages/project/pcm.shtml

Mission and Structure

Key Features:

The EBRD‟s new accountability mechanism, the Project Complaint Mechanism (PCM), operational since March 2010, has replaced the Independent Recourse Mechanism (IRM) that has been in place since July 2004.

The PCM has been established to assess and review complaints about bankfinanced projects, independently from banking operations. The Rules of Procedure of the PCM were approved by the EBRD Board of Directors in May 2009.

The new mechanism is expected to enhance the Bank‟s accountability. It includes features that make it more accessible, strengthened the Bank‟s ability to monitor clients‟ commitment to relevant EBRD policies. The Mechanism now also provides more opportunities for consultations with all relevant parties and publication of monitoring reports.


The PCM is independent from the EBRD‟s banking operations and the Bank‟s Environment Department. The Project Complaint Mechanism Officer (PCM Officer) coordinates all PCM processes and, together with an independent expert, makes an eligibility assessment of complaints, once registered. If a Compliance Review is warranted, a member of the panel of PCM Experts will carry it out. If a Problem-solving Initiative is needed, then subject to the prior approval of the Bank‟s President, the PCM Officer and/or a PCM Expert will serve as facilitator.

Four independent Experts have, to date, been appointed by the EBRD to a panel of PCM Experts. Their functions include the assessment, in conjunction with the PCM Officer of the eligibility of complaints, the undertaking of Compliance Reviews or Problem-solving Initiatives and follow up monitoring. These international experts specialise in areas such as the environment, social development and law reform and operate externally to the Bank. After initial terms of three, four or five years, the Experts‟ appointments can be extended for renewable terms of three years.


As its predecessor IRM, the PCM has two functions:

  • a Compliance Review function: to assess whether a Bank approved project complies with relevant Bank policies, specifically relevant environmental policies and project-specific provisions of the Public Information Policy, and - a Problem-solving function: to restore dialogue between the parties, where possible, to try to resolve the underlying issues giving rise to the complaint or grievance. A Problem-solving Initiative might include: independent fact-finding, mediation, conciliation, dialogue facilitation, investigation or reporting.

In assessing a complaint, there may be a recommendation for a Compliance Review or Problem-solving Initiative, or both or neither.

Changes from the previous mechanism:

Compared to the IRM, the new mechanism benefits from an improved and user-friendly registration system and wider scope for potential complainants. In particular, the group of potential complainants has been expanded to include NGOs and other civil society organisations (CSOs). Also, an individual alone may raise a complaint under the new mechanism without the necessity to be part of an affected group, which was the case under the IRM. It is important to mention, however, that complaints by CSOs will be eligible only for Compliance Reviews under the PCM.

The PCM also considerably enhances transparency by providing more opportunities for consultations with all relevant parties, including the complainant, the Bank, and the sponsors or financiers of the project in question. Importantly, it also provides for the publication of monitoring reports, such as reports on how well the Bank or client, as the case maybe, is implementing the recommendations or agreements arising from Compliance Reviews or Problem-solving Initiatives

The Project Complaint Mechanism (PCM) is the EBRD’s accountability mechanism that has been established to assess and review complaints about Bank-financed projects. It provides individual(s) and local groups that may be directly or adversely affected by an EBRD project, as well as civil society organisations, a means of raising complaints or grievances with the Bank, independently from banking operations.

Eligibility - Compliance


b) To be held eligible for a Compliance Review, the Complaint must be filed within 24 months after the date on which the Bank ceased to participate in the Project and must relate to a Relevant EBRD Policy. -

Where the Complaint raises issues appropriate for a Compliance Review, the Eligibility Assessors will, in their determination of eligibility, also consider whether the Complaint relates to:

a) actions or inactions that are the responsibility of the Bank b) more than a minor technical violation of a Relevant EBRD Policy unless such technical violation is alleged to have caused harm c) a failure of the Bank to monitor Client commitments pursuant to a Relevant EBRD Policy.

  1. A Complaint will not be eligible for either a Problem-solving Initiative or a Compliance Review if: a) it was filed fraudulently or for a frivolous or malicious purpose b) its primary purpose is to seek competitive advantage through the disclosure of information or through delaying the Project c) in the case of a request for a Problem-solving Initiative, the subject matter of the Complaint has been dealt with by the accountability mechanism of any co-financing institution and the PCM Officer is satisfied that the complaint was adequately considered by such accountability mechanism, unless there is new evidence or circumstances not known at the time of the previous complaint. In the event that a Complaint is seeking a Compliance Review, a review by another accountability mechanism will not disqualify the Complaint from being processed under these rules d) it relates to the obligations of a third party, such as an environmental authority and the adequacy of their implementation of national requirements, or relating to the obligations of the country under international law or treaty, rather than to issues that are under the control of the Client or the Bank.

PCM Register


  • EPS Restructuring (PSD 47318), EPS Kolubara Environmental Improvement (PSD 41923)
    • Eligibility Assessment currently in progress
  • GEORGIA - Jvari-Khorga Interconnection (PSD)
    • Eligibility Assessment currently in progress
  • Krnovo Wind Farm (PSD)
    • Eligibility Assessment currently in progress








IRM register

Independent Recourse Mechanism (IRM) served as the EBRD’s accountability mechanism from 2004 and was replaced by the Project Complaint Mechanism (PCM) in 2010.

This register provides details of the complaints received by the Chief Compliance Officer, charting their progress through the IRM.

This register provides details of the complaints received by the Chief Compliance Officer, charting their progress through the IRM.

Request number: 2005/01 Date complaint received: 26/07/05 Project name: Sakhalin II (PDF) Reports:

Request number: 2005/02 Date complaint received: 16/08/05 Project name: BTC (PDF) Reports:

Request number: 2006/01 Date complaint received: 24/10/06 Project name: BTC Pipeline (Georgia - Akhali Samgori) (PDF) Reports:

Request number: 2007/01 Date complaint received: 19/04/07 Project name: Vlore Thermal Power Generation Project (PDF) Reports:

Request number: 2007/02 Date complaint received: 06/07/07 Project name: BTC Pipeline (Georgia - Atskuri) (PDF) Reports: