For more than twenty years, the World Bank framed the environmental and social risks of its operations through a set of ten Operational Policies and Bank Procedures (OP/BP 4.01 to 4.37), adopted progressively between the 1980s and 2000. This mechanism had the advantage of seniority and great familiarity amongst borrowers, but it had aged. Several OPs were redundant, others insufficiently articulated with one another, and some no longer covered issues that had become major (human rights, community health, labour, climate change).

The revision began in 2012, in a tense political context marked by NGO criticism of certain financed projects. It resulted in August 2016 in the adoption of the Environmental and Social Framework (ESF), which came into effective application on 1 October 2018 for new projects. The framework comprises:

  • an Environmental and Social Policy for the Bank, which sets out the institution's own commitments;
  • ten Environmental and Social Standards (ESS 1 to ESS 10) which set the requirements applicable to projects;
  • an Environmental and Social Directive, which details the internal obligations of the Bank's teams;
  • Environmental and Social Procedures, which specify the implementation arrangements.

This article presents the architecture of the framework, the summary content of the ten ESS, the practical differences with the former OP/BP regime, and the critical points for a borrower country structuring a project under the ESF.

The architecture: ten ESS, in thematic progression

The ten ESS are organised according to a progressive logic, from the overarching assessment to the most specific themes.

  • ESS 1: Assessment and Management of Environmental and Social Risks and Impacts.
  • ESS 2: Labor and Working Conditions.
  • ESS 3: Resource Efficiency and Pollution Prevention and Management.
  • ESS 4: Community Health and Safety.
  • ESS 5: Land Acquisition, Restrictions on Land Use and Involuntary Resettlement.
  • ESS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources.
  • ESS 7: Indigenous Peoples / Sub-Saharan African Historically Underserved Traditional Local Communities.
  • ESS 8: Cultural Heritage.
  • ESS 9: Financial Intermediaries.
  • ESS 10: Stakeholder Engagement and Information Disclosure.

The correspondence with the IFC PS is immediate on essentials. ESS 2 to 8 cover the field of PS 2 to 8, with differences in wording. Two notable innovations: ESS 9 specifically addresses financial intermediaries (which, at the IFC, falls under FI categorisation in PS1), and ESS 10 gives stakeholder engagement autonomy as a standalone requirement, whereas the IFC integrates it into PS1.

ESS 1: risk assessment and management

ESS 1 sets out the principles and cross-cutting obligations. It introduces a categorisation of projects into four levels: high risk, substantial risk, moderate risk, low risk. This gradient is finer than the former A/B/C trichotomy and allows a more precise calibration of requirements.

For each project, ESS 1 requires a proportionate environmental and social assessment, the preparation of an Environmental and Social Commitment Plan (ESCP) which lists the actions the borrower commits to undertake and their schedule, and an Environmental and Social Management System that covers implementation over time.

The ESCP is a distinctive deliverable of the ESF. It is integrated into the financing agreement as a contractual document. Its periodic updating is mandatory and conditions the release of certain disbursements.

ESS 5: involuntary resettlement, the political core

ESS 5 is one of the most heavily worked standards during the revision. It replaces the former OP/BP 4.12 and retains its fundamental principles whilst clarifying several points that had generated interpretation conflicts.

The guiding principle remains identical: avoid displacement when possible, minimise it, compensate affected persons at full replacement value, restore livelihoods to at least an equivalent level.

The clarifications provided concern in particular: more precise definition of categories of affected persons (explicitly including occupants without formal title but with occupation prior to the cut-off date), strengthened consultation obligations, post-displacement monitoring timelines, and specific treatment of informal economic activities.

ESS 7: Indigenous Peoples and Sub-Saharan African traditional communities

ESS 7 is a major innovation of the ESF. It extends the traditional field of Indigenous Peoples, long practised in tropical forest zones or polar regions, to "Sub-Saharan African Historically Underserved Traditional Local Communities".

This extension responds to a reality documented by the Bank itself: in certain African countries, rural communities find themselves in situations of structural vulnerability similar to those of Indigenous Peoples (political marginalisation, cultural attachment to ancestral territories, dependence on specific natural resources), without being formally recognised as Indigenous Peoples. ESS 7 creates a requirements regime applicable to these communities.

Obtaining free, prior and informed consent (FPIC) is required for certain types of significant impacts, consistent with IFC PS7. Implementation of this requirement is closely monitored and has given rise, since 2018, to a rich internal case-law that is useful to absorb before structuring an affected project.

ESS 9: financial intermediaries

ESS 9 covers operations where the Bank finances a financial institution (national development bank, investment fund, microfinance institution) that in turn lends to sub-projects. The approach rests on strengthening the E&S management system of the intermediary, which must then apply it to its own operations.

ESS 9 is pragmatic: it recognises that the Bank cannot assess each sub-project individually, and transfers part of the diligence to the financial intermediary. The success of this architecture depends on the initial robustness of the intermediary's system and the quality of the Bank's oversight of it.

ESS 10: stakeholder engagement, standalone requirement

ESS 10 is the other major innovation of the framework. Stakeholder engagement, treated as a sub-theme of IFC PS1, becomes here a standard in its own right. It requires the development and implementation of a Stakeholder Engagement Plan (SEP), which describes:

  • identification and analysis of relevant stakeholders;
  • the engagement methods adopted, by stakeholder category;
  • the information disclosure strategy;
  • the community grievance mechanism;
  • resources dedicated to engagement and responsibilities;
  • indicative timetable and monitoring arrangements.

The SEP is a separate document from the ESCP and the E&S assessment. It must be published prior to the Bank's approval of the project and updated regularly during implementation.

What the World Bank verifies.

  • The project categorisation (high / substantial / moderate / low risk) and its justification documented in the initial assessment.
  • The ESCP, its completeness, its schedule, and evidence of implementation of due actions.
  • The SEP, its coherence with stakeholders actually identified in the field, and the effective functioning of the grievance mechanism.
  • The thematic deliverables expected according to the applicable ESS: RAP for ESS 5, Biodiversity Management Plan for ESS 6 in critical habitat, Indigenous Peoples Plan for ESS 7, Cultural Heritage Management Plan for ESS 8.
  • The articulation with national law and the documented treatment of gaps identified between the ESS and that law.

Practical differences with the former OP/BP

For a team that had worked under OP/BP, five concrete changes emerge from the first ESF project.

First, borrower accountability. The ESF states explicitly that the borrower bears the primary responsibility for implementation, whereas the former regime rested more on the Bank's internal procedures. The corollary is that borrower country teams must be better structured and better trained.

Second, the ESCP as a contractual document. This deliverable did not exist under OP/BP. It imposes a discipline of schedule and reporting that some teams discover at the outset.

Third, ESS 10 as a standalone standard. Stakeholder engagement, long treated as an integrated part of the assessment, becomes a distinct work stream with its own deliverables and its own timelines.

Fourth, categorisation into four levels. It allows finer sizing but requires a more nuanced risk analysis from the project team from the earliest stages.

Fifth, the extension to certain Sub-Saharan African communities (ESS 7). Projects that, under OP/BP, would not have been concerned by OP 4.10 may fall under ESS 7 and then require substantial consultation and implementation work.

Transition and capacity issues

The OP/BP to ESF transition, largely complete since 2018, is not uniform. Countries that already had advanced experience with the Bank and structured E&S teams integrated the new framework more quickly. Others took several years to stabilise their practices, particularly on ESS 10 (stakeholder engagement) and on grievance mechanisms.

The Bank supported the transition through capacity-building programmes, thematic guidelines (hosting interpretations and lessons learnt) and a network of regional experts. The borrower starting an ESF project today has access to an abundant documentary resource, which was less the case in the early years.

The World Bank's Environmental and Social Framework was designed to respond to the criticisms addressed to the former regime: insufficiency on social matters, weak borrower accountability, overly narrow coverage of certain risks. Six years after its entry into application, it largely fulfils these objectives, at the cost of heightened requirements for project teams and heavier investment in capacity.

For a project sponsor, the ESF is not to be worked in parallel with other DFI frameworks: it is combined. Projects financed by the World Bank in co-financing with the IFC, AfDB, AFD or other partners rely on common deliverables, structured in coherence with the most demanding framework. This alignment logic is encouraged by the Bank itself and considerably facilitates the operational life of project teams.

For an E&S consultant working regularly with the Bank, what matters less is knowing each ESS by heart than mastering the overall mechanics: categorisation, ESCP, SEP, regular updating, continuous supervision. These mechanics, well-honed, absorb very different projects and enable one to remain productive on diversified portfolios.

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