Dear Board members, alternates, and advisors:
We have serious concerns about the proposed Revised Accreditation Framework (RAF) and its implications for the future of accreditation and programming. We therefore call on the Board not to adopt this document as it stands. While it is clear that improvements are required to make the accreditation process more efficient, this proposed overhaul of the entire system does not address the actual problems; it instead creates more potential problems and risks for the
GCF’s operations, reputation, and impact.
We need the right solutions for the diagnosed issues, ones that recognize the GCF’s current challenges as well as its key features and advantages within the climate finance architecture. This proposal seems to be a top-down wholesale revision rather than a reform informed by those with accreditation expertise (such as the Accreditation Panel) or by the type of smaller (direct access) entities that the reforms should be targeting. Accreditation is not the main barrier to access, and more accreditations do not mean more funded proposals, especially from Direct Access Entities (DAEs), or more money reaching communities.
In particular, we are concerned that the proposal:
- fails to enhance access for DAEs, which struggle to receive funding even once accredited
- moves away from the fit-for-purpose approach and appears to make accreditation more difficult for DAEs
- locks in massive changes without providing clarity on key issues, including the role of the Accreditation Panel and the scope of the new screening. criteria
- creates new potential bottlenecks and sets aside independent assessment by shifting responsibilities to the Secretariat
- has a poor evidence base, relying on a consultant’s report rather than drawing on the expertise of stakeholders such as the Accreditation Panel or direct access entities
- scraps re-accreditation rather than streamlining the process, which would undermine the GCF’s paradigm shift goals and may expose it to reputational risk
First, this proposal fails to enhance access, which remains one of the GCF ́s core objectives, by ensuring accredited DAEs are able to advance funding proposals. In the matrix of comments, the Secretariat suggests that the changes “would also facilitate achieving USP-2’s target results of doubling the number of DAEs with approved GCF funding proposals.” This approach seems to be a perversion of the goal of USP-2, to suggest that DAE access can be
solved simply by bringing in an entirely new host of DAEs instead of working to program with existing DAEs, and tackling some of the key challenges. Such approaches do not build trust, especially in a climate finance environment where mistrust threatens the ambition of climate action.
Moreover, the proposal moves away from a much needed fit-for-purpose approach to accreditation, which would actually prioritise and respond to the needs and realities of many developing country DAEs. It instead proposes a one-size-fits-all approach that will largely benefit larger, mostly international entities and private sector actors, all of which, including those from developing countries, can now self-nominate. The latter undermines country ownership. The only differentiation the revised accreditation process allows for relates to risk categories, while no reference is made to scale or differentiated fiduciary standards and capabilities. On the contrary, the proposal’s solution to DAEs’ access difficulties is to send them to a capacity building process without any assurances that it will eventually lead to accessing climate finance.
A pass/fail screening and elimination of accreditation conditions removes the possibility that entities could become accredited even if they have some policy or evidence gaps that remain to be filled, which is likely to result in fewer DAEs able to program, not more.
The risks of this undermining GCF’s best-practice policy suite are real and will be borne by the communities the GCF is supposed to serve. There are 23 policies in Annex III that would potentially need to be changed to be in alignment with the new accreditation framework, yet the Secretariat provides almost no information on expected changes and their impacts and instead merely says it will do a review. This analysis, including potential impacts and implications, particularly when it comes to GCF standards, should happen before overhauling the system. Any potential watering down of standards is not only possible but plausible given the shift from assessing institutional capacity to project-level considerations and a removal of re-accreditation, among others.
The proposal also shifts significant accreditation assessment responsibilities to the Secretariat, while remaining silent on the future role, if any, of the Accreditation Panel. If the idea is to respond to challenges linked to the lengthiness of the accreditation process and the existing backlog, then this proposal is not backed by evidence, as the backlog is in Stage I and Stage III conducted by the Secretariat, but not in Stage II, which the Accreditation Panel conducts. On the contrary, the only thing such a proposal would achieve is to rob the GCF of the Accreditation Panel’s expertise and remove the governance and integrity advantages of an independent assessment, while placing more decision-making power on a Secretariat that has not shown that it has the capacity or expertise to take on these functions.
Additionally, scrapping the process of re-accreditation is a step in the wrong direction, as it likely will lead to many entities without intention of funding proposals, but profiting from an affiliation with the GCF (and using it for possible greenwashing). The reputational risk to the GCF is undeniable. The proposed new process lacks an independent assessment component and, crucially, does away with checks on accredited entities’ wider portfolios in favour of a narrower assessment of just their GCF-financed activities, which would limit the GCF’s ability to realize a paradigm-shift as well as potentially exposing the fund to reputational risks. Rather than scrapping re-accreditation, the RAF should establish a differentiated process that reduces the burden on smaller entities while ensuring robust checks on larger actors, particularly ensuring their emissions trajectories and policies are aligned with the GCF goal of promoting a paradigm shift towards low emission and climate-resilient development pathways.
Lastly, many of the proposed changes lack transparency and a clear evidence base – with the proposal relying on an external consultant’s report and an internal audit, which has not been made public, with no clear indication of whether or how the knowledge and experience of GCF stakeholders, including DAEs and the Accreditation Panel, were meaningfully integrated into the process. Continued statements about their consultation are not statements of their endorsement.
We urge the Board to reconsider the proposed RAF and ensure that it supports, rather than undermines, the critical roles of DAEs in achieving the GCF ́s objectives.
Thank you,
The GCF observer network of civil society, Indigenous Peoples, and local communities
