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A guide to the Independent Consultation and Investigation Mechanism (MICI)
If the IDB Group has funded or supported the project that is causing you harm, you may be able to file a complaint with their accountability mechanism, the Independent Consultation and Investigation Mechanism (MICI).
What is the IDB Group?
The IDB Group is a multilateral development bank headquartered in Washington, D.C., that provides financing to both the public and private sector in Latin American and Caribbean countries. The IDB Group is made up of three entities: the Inter-American Development Bank (IDB), IDB Invest, and IDB Lab.
The Inter-American Development Bank (IDB) is a regional development bank that finances government projects. The IDB was established in 1959, and provides loans, grants and technical assistance to the public sector in Latin America and the Caribbean. Its mission is to reduce poverty and inequality, and promote sustainable development in those regions.
In addition to MICI, if you are affected by an IDB project you can also raise a complaint with the IDB Grievance Protocol (GP), a management-led process to receive and resolve complaints. You can access the IDB complaint form for IDB projects at this link. Although using the GP may be a more efficient strategy for resolving simple issues, these mechanisms lack the rigor, transparency and independence of MICI.
IDB Invest (previously known as the Inter-American Investment Corporation - IIC) is a regional development bank that finances corporate activities. IDB Invest was established in 1984 to promote private sector development in Latin America and the Caribbean. It provides financing, advisory services and technical assistance to small and medium-sized companies and financial institutions.
In addition to MICI, if you are affected by an IDB Invest project you can also raise a complaint with their Management Grievance Mechanisms (MGM), a management-led process to receive and resolve complaints. You can access the MGM for IDB Invest projects at this link. Although using the MGMs may be a more efficient strategy for resolving simple issues, these mechanisms lack the rigor, transparency and independence of MICI.
IDB Lab (previously known as the Multilateral Investment Fund - MIF) finances start-up initiatives to promote regional innovation and growth. IDB Lab was established in 1993, and provides financing, knowledge and connections for early-stage investments.
What is MICI?
The IDB Group has an independent accountability mechanism: the Independent Consultation and Investigation Mechanism (also known as MICI). MICI receives complaints related to the environmental and social impacts of IDB Group-funded projects. If you are affected by an IDB Group-funded project, you can file a complaint with MICI.
To file a complaint, you need to provide specific information about the issue you are experiencing, as outlined in the “How to file a complaint” section.
If your complaint is found to be eligible, MICI has two functions to try to resolve the complaint: dispute resolution or compliance review (also known as investigation at MICI). You can decide which process you would like your complaint to enter if found eligible. If you want to try both dispute resolution and compliance review, you are required to try dispute resolution first.
You can learn more about the difference between dispute resolution and compliance review, and which option is better for your complaint here.
Dispute Resolution
At MICI, the voluntary dispute resolution process is called “dispute resolution”. During this dispute resolution process, the MICI team will facilitate dialogue and negotiations between the affected communities, the IDB Group’s client, and the IDB group, with the goal of reaching a mutually agreeable solution. You can learn more about this phase below.
Compliance Review
At MICI, the fact-finding compliance review process is called the “investigation”. During the compliance review phase, MICI investigates whether the IDB Group has complied with its environmental and social policies, and whether any non-compliance has caused harm to the community. MICI then prepares an investigation report that includes its findings and recommendations for the IDB Group. You can learn more about this phase below.
Can you complain to MICI?
Before filing a complaint, ask yourself the following questions. If your answer is yes to all of the questions, then you can complain to MICI.
MICI accepts complaints about all IDB Group projects from the date of their approval until up to 24 months after the last disbursement by the IDB Group entity. You may be able to find this information on the relevant project page on the IDB website, but if not, reach out to us or to MICI directly to ask for help.
If you are complaining about a project that is not yet approved, you can still submit a complaint, but it will be forwarded to and handled by IDB Management rather than MICI. If the project is subsequently submitted to the IDB Board for approval, the project documents will include a summary of the complaint, with management’s response and any action taken in regard to it.
Are those people living in the country where the project is being implemented?
Important: Your complaint cannot be anonymous, but you can request confidentiality regarding your identity or other information you submit to MICI. If you are facing reprisals or fear retaliation be sure to tell MICI and discuss how they can support you to address the risk of reprisals.
Duly appointed representatives can represent affected communities.
The harm is related to negative environmental and/or social impacts caused or likely to be caused by the IDB Group-financed project.
If you don’t fear retaliation, you are required to contact the IDB Group Office in your country or its headquarters in Washington D.C. to let them know about the problem and give them an opportunity to address it before contacting MICI. When filing a complaint, submit a description of any good faith communication you had with bank staff. Keep copies of all communications (even if they are unanswered), and notes from all meetings, with Management to submit with your description.
Important: If you are facing reprisals or fear retaliation, you can skip this step and go directly to MICI. Tell them why you did not contact the IDB Group Office, if you would like them to keep your identity confidential, and discuss how they can support you to address the risk of reprisals.
Model complaint letter
Complaint filing checklist
Download checklistStrengthen your complaint by referencing IDB Group policies
When filing your complaint to MICI, you may want to reference bank policies that were violated. Environmental and social safeguard policies play an important role in your complaint. These safeguards are rules and policies designed to identify and mitigate risks associated with bank activities, with an overarching goal of preventing environmental and social harms. Understanding these safeguards is essential for anyone seeking to hold banks accountable for harms associated with their investments.
MICI receives complaints related to all “Relevant Operational Policies,” including environmental safeguards, gender policies, and information disclosure policies, which can be found below.
Including this information is optional.
IDB Policies
The IDB Group requires its projects to meet the following environmental and social standards::
Standard 1: Assessment and Management of Environmental and Social Risks and Impacts
This standard requires the borrower (IDB Group’s client) to assess and manage environmental and social risks of projects, take precautions to reduce negative impacts, encourage better environmental and social practices, address complaints, and involve and inform people affected by the projects.
Show more Show lessStandard 2: Labor and Working Conditions
This standard protects workers rights, promotes fair treatment, non-discrimination, compliance with laws and safe working conditions. It prohibits child labor and forced labor, promotes freedom of association and provides effective channels to address workplace concerns.
Show more Show lessStandard 3: Resource Efficiency and Pollution Prevention
This standard safeguards human health and the environment by promoting sustainable use of resources, reducing pollution from project activities, minimizing project-related emissions and waste generation, and managing pesticide risks
Show more Show lessStandard 4: Community Health, Safety, and Security
This standard aims to avoid and minimize adverse impacts on the health, safety and security of project-affected people as a result of project activities. This includes infrastructure safety, hazardous materials management, ecosystem services, disease prevention, emergency preparedness, and security personnel conduct.
Show more Show lessStandard 5: Land Acquisition and Involuntary Resettlement
This standard aims to avoid or minimize displacement, forced eviction and adverse social and economic impacts of projects, by compensating for lost assets, minimizing disruption to social networks, and ensuring appropriate disclosure of information and consultation. It also aims to improve or restore the livelihoods and living standards of displaced persons and provide safe and secure housing at resettlement sites.
Show more Show lessStandard 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
This standard promotes the conservation and sustainable management of biodiversity and natural resources.
Show more Show lessStandard 7: Indigenous Peoples
This standard safeguards the rights, culture and natural resources of Indigenous peoples, by avoiding or minimizing adverse impacts of projects, promoting sustainable development, establishing ongoing consultation, ensuring Free, Prior and Informed Consent (FPIC), and preserving Indigenous Peoples’ culture and knowledge.
Show more Show lessStandard 8: Cultural Heritage
This standard safeguards cultural heritage from project activities and promotes fair sharing of benefits derived from its use.
Show more Show lessStandard 9: Gender Equality
This standard prevents risks and negative impacts based on gender, sexual orientation, and gender identity, promotes inclusion and safe participation, and upholds legal and international commitments related to gender equality throughout the project cycle. Where avoidance of these risks is not possible, this standard aims to mitigate and compensate for impacts of sexual and gender-based violence, including sexual harassment, exploitation, and abuse.
Show more Show lessStandard 10: Stakeholder Engagement and Information Disclosure
This standard establishes a systematic approach to stakeholder engagement, assessing stakeholder views, promoting inclusive engagement with project-affected people, disclosing information on environmental and social risks and impacts, and providing accessible channels for stakeholders to voice their concerns and grievances.
Show more Show lessAs of October 2021, the Environmental and Social Policy Framework covers all safeguards that apply to IDB and IDB Lab. For projects approved before October 2021, some relevant IDB Operational Policies also apply, including:
OP-102: Access to Information Policy - The IDB has implemented a policy to ensure transparency and maximize access to information regarding its operations, with exceptions limited to cases where disclosure could potentially cause harm, and with clear procedures for processing requests and reviewing decisions.
As of October 2021, the Environmental and Social Policy Framework covers all safeguards that apply to IDB and IDB Lab. For projects approved before October 2021, some relevant IDB Operational Policies also apply, including:
OP-708: Public Utilities Policy - This policy sets out the IDB’s commitment to promote universal access to and increase the efficiency and quality of public utilities service delivery, including water, sanitation, electricity, natural gas, solid waste, and telecommunication services, under conditions that are affordable and environmentally and socially sustainable, with a focus on financial, environmental, and social sustainability.
OP-703: Environment and Safeguards Compliance Policy (superseded by ESF)
This policy aims to integrate environmental sustainability outcomes in all bank operations and activities, ensure that they are environmentally sustainable, and promote corporate environmental responsibility to achieve sustainable economic growth and poverty reduction goals.
Show more Show lessOP-704: Natural Disaster Risk Management Policy (superseded by ESF)
This policy aims to assist borrowers in reducing risks from natural hazards and managing disasters to support their social and economic development goals through strengthening the Bank’s effectiveness in managing risks and facilitating rapid assistance in response to natural disasters.
Show more Show lessOP-710: Involuntary Resettlement Policy (superseded by ESF)
This policy aims to minimize the impact of physical displacement caused by development projects, by avoiding it whenever possible, and providing fair compensation and rehabilitation when unavoidable, to ensure affected people have access to basic necessities.
Show more Show lessOP-761: Policy on Gender Equality in Development (superseded by ESF)
This policy aims to promote gender equality and empower women in Latin America and the Caribbean, through proactive actions that promote gender equality and empowerment, and preventative actions that safeguard, prevent or mitigate adverse impacts on people due to gender.
Show more Show lessOP-765: Indigenous Peoples Policy (superseded by ESF)
This policy aims to support the development of indigenous peoples by strengthening their identity and governance capacities while safeguarding their rights in Bank-funded development projects.
Show more Show lessIDB Invest Policies
The policy aims to promote good environmental practice, including pollution prevention, resource efficiency, climate change adaptation and mitigation, biodiversity and ecosystem services, and disaster risk management.
The policy also commits to promote good international practice in all social aspects, including respecting human rights, promoting open and transparent stakeholder engagement, and protecting against reprisals. The policy also aims to manage gender risk and equality, respect the rights of indigenous people and other vulnerable groups, protect the rights of persons with disabilities, employ good labor practices, working conditions and health and safety practices, avoid forced eviction and involuntary resettlement, and providing accessible channels for stakeholders to voice their concerns and grievances.
This policy outlines IDB Invest’s commitment to providing access to information to the public, with exceptions based on international standards, while respecting the confidentiality of information received from clients and third parties, and establishing clear procedures for requesting and reviewing access to information requests.
IDB Lab Policies
Similarly to IDB Policies mentioned above, the IDB Environmental and Social Policy Framework also applies to IDB Lab projects.
After filing your complaint, MICI will decide whether to register your complaint or not. Your complaint will be registered if it meets MICI’s requirements as outlined in the “How to file a complaint” section above.
If your complaint is registered, MICI will review it to determine whether it meets their eligibility criteria:
- Alleged violations: The complaint must allege that the IDB Group has violated one or more of its own operational policies and procedures.
- Harm: The complaint must relate to environmental and/or social harm caused or likely to be caused by the approved IDB Group project.
- Attempted resolution: If the complainant has no fear of reprisals or retaliation, you must show that you have attempted to resolve your concerns with IDB Management. Keep copies of all communications (even if they are unanswered), and notes from all meetings with Management.
- Time limit: The complaint must be filed within 24 months of the last disbursement by the IDB Group.
- Fresh evidence: The issues raised in the complaint must be new. If MICI has already reviewed the issues, there must be new evidence or circumstances that were not available at the time of the initial complaint.
The MICI Director determines eligibility. If your complaint is found to be eligible, it will then be transferred to the next stage, being the substantive phase that you chose to enter when you filed your complaint.
All eligible complaints should then enter a substantive phase. As MICI you are given the option of a dispute resolution process called the dispute resolution phase, or a compliance review process called an investigation.
MICI will speak to you about which option you prefer. If no agreement is reached during a dispute resolution phase, or if the agreement does not address all the issues raised by the complaint, parties can choose to enter compliance review after the dispute resolution phase.
Dispute Resolution
When a complaint is declared eligible for the dispute resolution phase, MICI will enter an assessment stage to gather information to understand the harm. Based on the results of the assessment, the complaint will either enter dispute resolution, or if collaborative resolution is not possible, the complaint will be forwarded to a compliance review phase.
As mentioned above, the dispute resolution phase is a voluntary dispute resolution process, where MICI acts as the facilitator between the community, the IDB Group’s client, and the IDB Group. The aim is to reach an agreement between all the parties, and find a mutually agreeable solution to your concerns.
A dispute resolution process can involve dialogue, joint fact-finding, mediation, negotiation, and facilitation. It is a voluntary process, and any party can choose not to participate. A community can share their concerns about the project directly with the IDB Group and its client, and advocate for special solutions to their concerns. If the parties agree on solutions, MICI will help them to formalize those solutions in a signed agreement. If no agreement is reached, the case will be transferred to Compliance. Upon completion of this phase, MICI will prepare a report on the results of the dispute resolution process.
If at any stage of this process a party no longer wants to continue with dispute resolution, the case is transferred to compliance review.
If you would like to know more about what a dispute resolution process involves, see the case study for Caracol Industrial Park below or MICI’s Dispute Resolution (Consultation) Phase Guidelines.
Compliance Review
When a complaint is transferred to the compliance review phase, MICI will prepare a recommendation and terms of reference for the investigation. This will include the objectives of the investigation and the issues to be investigated. MICI will then submit this recommendation to the Board of Executive Directors jointly with Management’s comments. The Board will then make a decision based on this recommendation. If approved, the complaint is then investigated.
As mentioned above, the compliance review phase is a fact-finding process, where MICI acts as the investigator to investigate whether the IDB Group has complied with its environmental and social policies, and whether such non-compliance has caused harm to the community.
After investigating, MICI prepares an investigation report with its findings and recommendations. The IDB Group then has a specified period to respond to the report and indicate the actions it will take to address the concerns raised. Finally, MICI presents its report to the Board, which determines what action to take, including whether Management should develop an action plan to address any non-compliance. The report is released to the public along with the Board's decision.
If your complaint goes through a dispute resolution process and results in an agreement, or goes through a compliance review and a compliance report is published, then the complaint will enter a monitoring phase.
Dispute Resolution
If an agreement is reached, MICI may develop a monitoring plan and timeline (not to exceed 5 years from the date the agreement was signed). If you have added monitoring procedures into your agreement, these would come into play at this stage.
The monitoring plan must then be approved by the Board. If approved, MICI will then monitor the implementation of this agreement. Monitoring can involve site visits, meetings, and regular reporting to the Board and the affected community.
Compliance Review
If an investigation report is published, this report is provided to the IDB Group showing MICI’s findings and recommendations. Management will then decide on an Action Plan that should be developed to address any non-compliance. The Board will approve the management action plan, and MICI will prepare a monitoring plan and timeline (not to exceed 5 years from the date on which the Board approves the plan). MICI will then monitor the implementation of the plan or other agreed remedial action.
Comparison to best practice
Independence: MICI’s reporting line is independent from bank management; it reports to the Board of Executives.
Independence: While this is generally a good level of independence, the Board has used its powers to stop MICI from investigating certain complaints: a problematic feature of MICI’s structure.
Transparency: MICI makes complaints, eligibility reports, final compliance reports, dispute resolution reports, and follow-up monitoring reports public.
Remedy: MICI can make recommendations for corrective measures to address areas of non-compliance, but does not explicitly have a mandate to recommend remedy for communities.
A look at the data
We have brought together some charts, based on the latest data available in the Complaint Dashboard, to offer a deep dive into the IDB Group and MICI’s performance.
Complaint Outcomes
Eligibility
Dispute Resolution Outcomes
Compliance Review Findings
Complaint issues
Complaint sectors
Recommendations to improve MICI
MICI’s policy should not allow the IDB Board to object to a compliance review investigation. (GPP 46)
To strengthen its ability to prevent harm, MICI should be able to accept complaints about projects before they are approved by the Board. (GPP 30)
MICI’s policy should allow it to self-initiate compliance reviews without having to receive a complaint. This would increase MICI’s effectiveness in contexts where reprisals and restrictions on civic space make it too dangerous for project-affected communities to file complaints. (GPP 47)
Independent Consultation and Investigation Mechanism (MICI): https://www.iadb.org/en/mici/mici-independent-consultation-and-investigation-mechanism
Email:
AccessMICI@iadb.orgTo send complaints:
mecanismo@iadb.org1300 New York Ave. NW Washington, DC. USA. 20577
Date Last Updated: Sept. 9, 2025