Indigenous Organizations Submit Recommendations to Strengthen IFC Performance Standards
Indigenous-led organizations today delivered a joint submission to the International Finance Corporation (IFC) with recommendations to strengthen Performance Standard 7 - Indigenous Peoples (PS7) and its interaction with Performance Standard 5 - Land Acquisition and Involuntary Resettlement (PS5). The IFC, which is the private sector lending arm of the World Bank Group, is currently reviewing its Sustainability Framework, with updates to its Performance Standards expected in 2028.
“The review of PS7 and PS5 comes at a moment when IFC-financed projects are increasingly intersecting with Indigenous Peoples’ lands and territories, particularly in the context of transition minerals and strategic supply chains,” says the letter. For projects across mining, infrastructure, agribusiness, and energy sectors, “the issue is not whether safeguards exist, but whether they are triggered and applied in a way that meaningfully protects Indigenous Peoples’ rights in practice.”
Review of projects that have triggered PS7 demonstrates gaps in substantive respect for Indigenous Peoples’ rights, including their rights to lands, territories, and resources and to their right to free, prior and informed consent (FPIC).
Examining case studies of impacts to Indigenous Peoples from IFC-financed development in Honduras, Cambodia, and Mongolia, a pattern emerged:
Projects can meet procedural requirements while fundamental issues such as land rights, representation, consent, and power imbalances, remain unresolved. When this occurs, risks are not reduced; they are deferred. Over time they often re-emerge as conflict, project delay, community grievance, reputational harm, and long-term instability, particularly where underlying disputes or inequalities remain unaddressed.
The letter provides recommendations to improve IFC’s standards:
Clarify FPIC as a substantive safeguard by clearly affirming FPIC as a “collective right grounded in Indigenous Peoples’ right to self-determination,” and explicitly stating that “FPIC requires a demonstrable outcome grounded in Indigenous Peoples’ own decision-making systems and structures.”
Establish clear pause and no-go triggers with “clear, operational thresholds that require projects to pause, or not proceed, when core safeguards related to Indigenous Peoples’ rights remain unresolved.”
Strengthen protection of customary land systems, requiring “concrete, verifiable steps to identify and protect Indigenous Peoples’ laws, traditions, customs and land tenure systems in a way that reflects how those systems actually function on the ground.”
Close the PS7–PS5 gap by clarifying that “FPIC applies to all projects implemented within Indigenous Peoples’ territories, not only in cases of specific impacts such as relocation, impacts on cultural heritage, or use of traditionally used lands and resources.”
Require independent verification for “all projects involving significant impacts on Indigenous Peoples, including where FPIC is required, where there are land or representation disputes, or where there is evidence of contested or conflicting information.”
Clarify limits of government-led processes - where government-led processes do not meet the requirements of meaningful consultation and consent, clients should “take additional measures to engage directly with Indigenous Peoples in a manner consistent with PS7, including independent verification.”
Address coercion and reprisals explicitly by requiring “a structured and documented assessment of conditions that may affect the freedom, safety, and legitimacy of Indigenous decision-making. In many project contexts, engagement does not take place in neutral conditions, and failure to account for these dynamics can undermine whether consent is truly free, prior, and informed.”
Safeguard continuity through ownership changes by requiring that “key social and environmental obligations are maintained through changes in ownership or control. Significant changes in project control should trigger notification to affected Indigenous Peoples and a reassessment of whether existing agreements and engagement outcomes remain valid in light of new conditions.”
Learn more about Indigenous Peoples and the IFC and a prior submission requesting the IFC formalize a dedicated consultation process for Indigenous Peoples and form an Indigenous advisory group. The joint submission was delivered by Batani Foundation, Indigenous Peoples Rights International, Quipa Collective, Securing Indigenous Peoples’ Rights in the Green Economy (SIRGE) Coalition, and Tallgrass Institute.