Public Money for Mining

A practical guide for communities and CSOs: who finances mining, what it means for you, and where to file a complaint

Based on the PowerShift e.V. report "Public Money for Mining: Closing the Gaps in Standards, Transparency and Accountability" (Vanessa Fischer, February 2026) and publicly available data on grievance mechanisms as of July 2026.

Contents

1. Why this document

Six public finance institutions — EIB, EBRD, KfW/KfW-IPEX, the German Raw Materials Fund, IFC/MIGA, and export credit agencies (ECAs/UFKs) — are becoming anchor investors in critical mineral mining. The PowerShift report shows that none of them have safeguards adequate to the specific risks of mining — irreversible impacts on land, water, and Indigenous rights.

This document translates that analysis into something practical: a detailed scorecard across three dimensions, an honest look at how grievance mechanisms perform in practice, and a navigator with current links for filing complaints.

Important caveat: the existence of a mechanism does not mean it will deliver remedy. Section 4 covers not just addresses, but what has actually happened to complaints in the past.

2. Map of institutions

InstitutionRole in mining financeAdequacy rank
KfW / KfW-IPEXExport and project finance, often tied to raw material supply for German industry1 — weakest
ECAs / UFKsState guarantees that make risky projects bankable2
German Raw Materials FundState fund supporting access to strategic raw materials3
IFC / MIGAWorld Bank Group's private-sector arm: loans, guarantees, influential Performance Standards4
EIBEU development bank; anchor investor for strategic raw materials5
EBRDDevelopment bank; growing role in critical raw materials6 — relatively strongest

Even EBRD lacks a mandatory independent HRIA, a hard FPIC precondition, and no-go zones for mining in sensitive ecosystems.

3. Detailed scorecard against the report's criteria

The report assesses institutions against 20 criteria across three dimensions. ▼ weak/absent · ● partial/procedural · ▲ relatively strong.

weak / absent partial / procedural relatively strong

4. How this has worked in practice

CAO (IFC / MIGA)

200+ complaints since 199958 countries~10 new eligible complaints/year10 compliance investigations ever

In dispute resolution (41-45 concluded cases since 2008), about 60% end in full or partial settlement. But independent research (Corporate Accountability Research, "Report XVII-CAO") on the Wilmar, PT Weda Bay Nickel (a nickel mine in Indonesia) and Indian tea company cases found that CAO "ultimately made little tangible difference to human rights outcomes" — partly due to mandate limits, partly due to CAO's own operational choices.

Takeaway for communities: settlement ≠ remedy.

EBRD IPAM

26 cases in the 2024 portfolioonly 1 new agreement in 2024

IPAM's main sectors are infrastructure, along with mining, renewable energy, and waste. IPAM is operationally independent and reports to the Board — but the pace of actual remedy is low relative to the size of the portfolio.

EIB Complaints Mechanism (EIB-CM)

43% of project summaries published on time in 20231-year filing limit

The mechanism only issues recommendations — there is no binding remedy mandate. Decisions can be appealed to the European Ombudsman, but its recommendations are also non-binding.

KfW / KfW-IPEX

There is no independent grievance mechanism: complaints are directed to the project developer — the very party that may be responsible for the violation.

Real precedent: Saami Council vs. KfW IPEX-Bank (2010) — a complaint over a wind farm on Saami land was filed with the German OECD NCP, transferred to the Swedish NCP (Sweden co-sponsored the project — a clear conflict of interest), and rejected as "not meriting further examination." Requests for a direct meeting with the bank were also declined.

German Raw Materials Fund

Neither the fund nor the KfW entity that manages it operates an independent grievance mechanism — the project developer is expected to set one up.

ECAs / UFKs and the OECD NCP as a political channel

OECD National Contact Points are a non-judicial mechanism: they cannot impose sanctions, only offer mediation and publish a final statement. The German NCP has repeatedly been criticised by NGOs (ECCHR, Business & Human Rights Centre) for "partiality towards companies."

Practical takeaway: the more a mechanism is formally independent of bank management (EBRD IPAM, CAO), the higher the chance of a substantive process — but not a guaranteed remedy. Where no independent mechanism exists at all (KfW, Raw Materials Fund) or it is non-judicial by design (OECD NCP), parallel political and media pressure matters more than the formal complaint itself.

5. Navigator: where to go

Select the institution financing the project.

6. Checklist before filing a complaint