BIC proposes Key Performance Indicators to measure whether IFC and MIGA's Remedial Action Framework delivers real results

By Caroline Vesey

After years of advocacy, the International Finance Corporation (IFC) and the Multilateral Investment Guarantee Agency (MIGA) approved their Interim Remedial Action Framework (RAF) in April 2025. The RAF is a welcome step forward toward addressing harm caused by IFC/MIGA projects. However, the real test is not whether the RAF exists on paper, but whether it delivers tangible remedy to communities who have suffered harm.

Within the first six months of the interim RAF implementation period, IFC/MIGA, in consultation with the Compliance Advisor Ombudsman (CAO), were instructed to define and track key performance indicators related to the RAF’s efficiency and effectiveness. While IFC/MIGA did not meet this six-month deadline, we understand that these conversations are active. To this end, BIC has developed a set of KPIs to measure whether the RAF results in concrete outcomes rather than procedural actions or institutional perceptions. These indicators ask fundamental questions that any effective remedy framework must answer.

BIC’s proposed KPIs assess whether the RAF delivers remedy in four key ways:

1. Has harm actually stopped? Remedy requires addressing the source of harm, not just documenting it. The KPIs measure whether harmful practices have been modified or terminated, and how long it takes from the identification of harm to actual change on the ground. Delayed remedy has been a recurring problem in IFC/MIGA projects and undermines the RAF’s credibility.
2. Have communities received tangible remedial actions? Access to remedy means delivery of concrete actions, not just facilitation or planning. The KPIs assess whether remedial actions were implemented, whether communities regained access to livelihoods and benefits lost due to project harm, and whether remedial actions directly address the specific harm identified rather than offering generic and/or unrelated activities.
3. Have remedial measures lasted? Temporary fixes that disappear after the end of the project or Management Action Plan (MAP) implementation period do not constitute genuine remedy. The KPIs measure whether remedial measures remain in effect after projects end, and whether the same harm recurs, which would indicate that the root causes of harm were never addressed.
4. Have IFC/MIGA and clients learned from harm and changed their behavior? To prevent future harm, the institutions and their clients must demonstrate a willingness to make structural changes. The KPIs assess whether remedial measures have been integrated into contractual agreements with clients, and whether IFC, MIGA, and clients have improved their approaches to identifying and managing environmental and social risks.

BIC calls on IFC/MIGA to adopt these or similar KPIs during the RAF's interim period. IFC/MIGA must also commit to transparently measuring and reporting on KPIs across RAF cases, including by disclosing the projects and complaints subject to the RAF. Without clear metrics that focus on outcomes for affected communities, the institutions risk repeating past patterns in which IFC/MIGA and clients do not genuinely address the root cause of harm or implement concrete changes on the ground, while communities continue to live without real remedy.

Read our full proposed KPIs here. 

Read the original post on BIC’s website.