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.
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.
| Institution | Role in mining finance | Adequacy rank |
|---|---|---|
| KfW / KfW-IPEX | Export and project finance, often tied to raw material supply for German industry | 1 — weakest |
| ECAs / UFKs | State guarantees that make risky projects bankable | 2 |
| German Raw Materials Fund | State fund supporting access to strategic raw materials | 3 |
| IFC / MIGA | World Bank Group's private-sector arm: loans, guarantees, influential Performance Standards | 4 |
| EIB | EU development bank; anchor investor for strategic raw materials | 5 |
| EBRD | Development bank; growing role in critical raw materials | 6 — relatively strongest |
Even EBRD lacks a mandatory independent HRIA, a hard FPIC precondition, and no-go zones for mining in sensitive ecosystems.
The report assesses institutions against 20 criteria across three dimensions. ▼ weak/absent · ● partial/procedural · ▲ relatively strong.
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.
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.
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.
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.
Neither the fund nor the KfW entity that manages it operates an independent grievance mechanism — the project developer is expected to set one up.
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."
Select the institution financing the project.