On September 28, the first day of the Asian Infrastructure Investment Bank (AIIB)’s annual meeting in Doha, 108 Indigenous people from Lombok, Indonesia, filed a complaint with the bank’s grievance body, the Project-affected People’s Mechanism (PPM). They said the AIIB-financed Mandalika Urban and Tourism Infrastructure Project forced them from their homes, took their farming land, cost them their livelihoods, and ignored their right to be consulted. Many now struggle to make ends meet and fear future evictions.

Headquartered in Beijing, with China its largest shareholder, the AIIB began operations in 2016. In a decade, it has grown to 111 members and invested almost $70 billion in more than 350 projects across 40 economies. At the Doha meeting, AIIB President Zou Jiayi announced plans to double its annual financing to about $20 billion by 2030. A growing footprint in Asia and beyond demands an accountability and risk management system to match.

Like its peer multilateral development banks (MDBs), the AIIB has committed to “do no harm” and to offer people a route to seek redress when its projects cause harm. Independent accountability mechanisms, separate from bank management, exist at most MDBs and other development finance institutions. Complaints pass through an initial screening stage, known as admissibility, eligibility, or registration, to establish whether they fall within the mechanism’s mandate. The mechanism then offers dispute resolution or, if parties do not agree to it, examines whether the bank followed its environmental and social rules through a compliance review. 

Complaints Hit an Admissibility Wall 

Communities affected by AIIB-financed projects have never been able to test whether the PPM process works. Since the mechanism’s creation in 2019, none of the 45 complaints tracked on its website as of September 15 this year had passed the admissibility stage. By contrast, peer mechanisms at other development banks regularly take complaints into dispute resolution or compliance review. One of the largest handled more than 60 cases in each of the last two financial years.

The revised policy introduced in 2026 raised hopes that the PPM would become more effective and improve its track record. Since it took effect, however, the PPM has found 14 out of 16 complaints inadmissible. The remaining two, submitted in May, are still awaiting an admissibility decision. The Mandalika complaint would be the 17th complaint of 2026. 

The PPM’s entry requirements are significantly more restrictive than those of its peers. These “roadblocks to accountability” include referring complaints about co-financed projects to the lead lender, imposing narrow time limits on complaints about loans to governments, and requiring prior “good-faith efforts” to resolve grievances with both the project-level grievance mechanism and bank management. 

Complainants must also establish at the admissibility stage that their complaint concerns the AIIB’s failure to comply with its policies, while the complaint mechanism must conduct an assessment that other mechanisms carry out only in later steps. 

A central obstacle to accessibility is the requirement that complainants make “good-faith efforts” with both the project-level grievance mechanism and AIIB management. Under the PPM policy, complainants must explain why they could not resolve their concerns through these channels, and the PPM decides whether their efforts were sufficient. 

The rule has previously been used to reject complaints, including one regarding the Bhola gas power plant in Bangladesh, despite attempts to engage amid legitimate constraints and fears of retaliation. The two complaints filed in May 2026 remain pending while complainants have been asked to engage with the client and management.

Requiring prior engagement at both levels is unique among these mechanisms. Some peers require good-faith efforts with bank management, but not with the project-level grievance mechanism as well. Nor do they require complainants to explain why those efforts failed. The PPM’s approach places that burden on the people seeking redress.

There are legitimate reasons why such engagement may be impossible. A client’s grievance mechanism may be inaccessible or ineffective. The client or management may refuse to engage meaningfully. Restrictions on movement and the threat of retaliation can create further barriers. In many of the AIIB’s borrowing countries, restrictive civic space makes these risks particularly acute. 

The PPM policy lists risks of retaliation against complainants as a factor allowing the PPM to accept a complaint despite the absence of engagement with client and management. That provision has yet to be tested. It will only work only if the PPM trusts complainants’ accounts of why they could go no further and considers all relevant circumstances, including the risks they face. The Mandalika complaint will be an important test, as communities report continuing and increasing attempts at retaliation.

For complaints seeking a compliance review, the threshold is higher still. In addition to meeting the general criteria, they must relate their claim to the AIIB’s noncompliance with its environmental and social policy. The policy excludes complaints relating to actions “that do not involve AIIB’s failure to comply.” 

As we understand the rules, complainants must show the bank’s noncompliance at the outset and, on the strictest reading, that it caused their harm. The evidence for this sits in AIIB’s due diligence and supervision records, which communities cannot see. They cannot know whether the AIIB checked a resettlement plan or what its staff found on supervision visits. Establishing these facts is the purpose of an investigation. Unlike most of its peers, the PPM asks complainants to supply evidence that the mechanism itself should establish.

These restrictions raise doubts about whether any complaint could qualify for compliance review under a strict interpretation of the criteria. Without a compliance review there are no findings: nothing to establish what went wrong, to support remediation for affected communities, or to help the bank improve its procedures and practices.

An Opportunity to Change Course 

These technical restrictions run counter to a simple principle: admissibility is a straightforward step to establish whether a complaint falls within the mechanism’s mandate. At peer mechanisms, apart from formal exclusions, the substantive screening focuses on the complaint’s connection to a bank-financed project and its environmental and social policies, and on indications of actual or potential harm. Detailed examination comes later. 

In a compliance review for instance, the mechanism must investigate whether the bank failed to comply with its policies and whether those failures relate to the alleged harm. That work can involve reviewing hundreds of project preparation and supervision documents, conducting field visits, and consulting intensely with affected people and other stakeholders. The admissibility phase is not the place for such an investigation. 

Yet the PPM Policy and Rules of Procedure complicate this initial step, impose unduly strict restrictions, and demand substantial work from both complainants and the mechanism before a case can proceed. It is little surprise that no complaint has cleared this hurdle.

At the AIIB’s annual meeting, Zou spoke of infrastructure “connecting people to opportunities” and of “people-centered development.” Carmen Nonay, the new managing director of AIIB’s Complaints-resolution, Evaluation, and Integrity Unit, which includes the PPM, can help turn that vision into practice by bringing the mechanism into line with its peers. There are 22 other mechanisms with established practices to learn from. 

The managing director has the authority and responsibility to interpret the PPM’s Rules of Procedure. The pending complaints offer an immediate opportunity to do so. We urge her to apply the policy and rules in line with established accountability practice: treat admissibility as a quick, straightforward first step; trust complainants’ accounts of their efforts and the risks they face; and hear them impartially before making a decision. The PPM should use its unrestricted access to management information to identify indications of noncompliance, rather than place that burden on complainants. This approach follows the PPM peers’ shared principles, reiterated this year, which put accessibility first: “A recourse mechanism is not effective if affected people do not know it exists or are unable to access its services.”

Because the PPM sits within the institution it reviews, its managing director may not feel sufficiently independent to pursue this approach. The AIIB board should make it clear that it expects the mechanism to follow its peers’ good practice. If the PPM still struggles to deliver on its mandate, the board should review the obstacles and require changes to the policy, particularly its accessibility provisions.

Almost eight years after the PPM’s creation, workers and communities affected by AIIB-financed projects deserve the same care and accountability as those affected by other MDBs. That is a matter of fairness and credibility for the AIIB and its shareholders. An accessible, effective complaints mechanism would strengthen the bank’s reputation and its ability to finance development sustainably.