Dear GCF Board members, alternates, and advisors:
While the GCF observer network of civil society, Indigenous Peoples, and local communities appreciates that action has been taken towards updating the Fund’s Gender Action Plan (GCF GAP), and recognizes the efforts made to enhance the draft following consultations in April, we urge the Board not to adopt this GCF GAP without further updates, in particular ensuring adequate time to consider findings of the Independent Evaluation Unit’s Evaluation of the GCF’s Gender Approach and how to better align with the Belém Gender Action Plan (Belém GAP).
Delaying adoption does not have to mean delaying momentum on advancing the GCF’s approach to gender-responsive climate finance. Instead, it allows key actions that should have preceded this draft to be taken, informing an adequate approach to potential approval at B.46. Between B.45 and B.46, the Board could request the Secretariat to complete a mapping and gap analysis against the Belém GAP and to more fully integrate the IEU’s core recommendation on focusing the GCF’s gender actions to shift from mere compliance to accountable outcomes. It could also instruct the Secretariat to conduct the proposed learning needs assessment of accredited entities, National Designated Authorities and delivery partners and integrate its findings into the GAP.
The ostensible reason for ignoring the COP29 guidance to update this long-overdue GAP earlier, awaiting the COP30 outcome on the UNFCCC GAP (the Belém GAP), is only sensible if indeed the GCF GAP “actively contribute[s] to the implementation of activities” of the Belém GAP, in response to COP30 guidance. At present, the draft commits to future alignment and mapping exercises, rather than integrating specific Belém actions, timelines and priorities. The GCF GAP should be a key mechanism that, inter alia, contributes to implementing the Belém GAP, not merely a parallel effort.
For instance, the Belém GAP places strong emphasis on access to climate finance for grassroots women’s organisations, Indigenous Peoples and local communities, as do other UNFCCC mandates that the GCF is poised to support Parties in delivering. Yet the IEU found that in GCF activities that engage women’s organisations, 79 per cent are mostly engaged as consulted stakeholders or beneficiaries, while fewer than 4 per cent are involved in roles that manage or channel funds, such as an implementing partner. Access requires much more than consultation. The GCF GAP could be strengthened through targets, or a clear trajectory, for increasing the share of GCF finance reaching women- and girl-led organisations, beyond an Engagement-to-Access Pathway focused on accreditation. The GAP does not take forward several of the IEU’s more structural recommendations, including minimum thresholds for the involvement of gender-focused organisations in country programming, co-design roles in identifying national gender priorities, and CSO monitoring arrangements. This effort would also respond to the New Collective Quantified Goal’s para. 24 for multilateral climate funds to strengthen efforts in “scaling up and prioritizing direct access” – and do so in the context of the NCQG para.16 ambition of tripling funds’ outflows by 2030.
The Belém GAP also calls for stronger collection and use of gender- and age-disaggregated data that accounts for multidimensional factors. The draft GCF GAP makes welcome commitments here, but defers much of the detail on intersectionality to the Harmonized Results Management Framework (HRMF). Greater clarity on how the GAP will also support data capture on age, disability, Indigenous status and other factors intersecting with gender, and how it interacts with the HRMF, would strengthen accountability, and is work best done in alignment with the continued consultations on the HRMF on the path to B.46.
The IEU Evaluation of the GCF’s Gender Approach, and its respective discussion, is part of an important institutional process to inform discussions on next steps on gender, including the updated GAP. Yet its release just one business day before the draft GAP, and the management response over a week later, which assumes the GCF GAP adoption, leaves no time for the Board and other relevant stakeholders to contemplate the right relationship and sequence between these documents. Even the Secretariat in its management response acknowledged that the time after it received the IEU’s report was too short, as “the highly granular and operational nature of the recommendations needed more careful consideration.” Greater engagement with the IEU findings will hence be needed to ensure a robust GCF GAP.
The case for a strong GAP is indeed supported by the IEU evaluation finding that the Gender Policy has strengthened compliance and design quality, but this has not yet translated into stronger gender outcomes; in fact, reported outcomes appear to be declining. This is the central challenge the next GAP must address. In this phase of implementation, the priority must be accountability for better outcomes. The IEU emphasised that gender requirements should also help the GCF, AEs, and NDAs learn, adapt and improve throughout the project cycle to achieve lasting outcomes.
As the Board considers an update of the HRMF and the Information Disclosure Policy, the GAP would also benefit from stronger transparency and accountability at project and sub-project level; indeed, it is silent on sub-projects, when the majority of approved funding in the portfolio is under a programmatic approach and so far not a single sub-project GAP under approved programmes has been disclosed on the GCF website. At present, the draft places greater emphasis on institutional and process-level indicators, while downplaying the significance of gender-responsive implementation across the portfolio. At a time when the watchword for the Fund is impact, a five year GAP that doesn’t deliver gender-responsive action for the beneficiaries of its projects and programmes is not an effective plan.
Best,
GCF observer network of civil society, Indigenous Peoples, and local communities
