EBRD and IFC ESG Requirements: ESRs, Performance Standards, ESAP

What do the EBRD and the IFC require from the companies they finance?

They require you to manage the project’s environmental and social risks to their own standards, and to prove it for the life of the loan. The EBRD applies the ten Environmental and Social Requirements (ESRs) of its 2024 policy; the IFC, the World Bank Group member focused on the private sector, applies its eight Performance Standards of 2012.

Lender ESG reporting follows the life cycle of the loan:

1. Categorisation: the lender rates the project by the scale of its potential risks and impacts.
2. Environmental and social due diligence: it reviews your documents, visits the site and compares your practice with its requirements.
3. Environmental and social action plan (ESAP): where gaps remain, corrective actions are negotiated and attached to the financing agreements.
4. Reporting: you report, usually once a year, on ESAP implementation and on your environmental and social performance.
5. Monitoring: the lender, its representatives or independent experts review the reports and may visit the site.

The EBRD has invested in Morocco since 2012 and has a resident office in Casablanca. It lends directly or through partner banks. The IFC Performance Standards reach beyond the IFC itself: according to their text, other financial institutions may also apply them. A manufacturer in Morocco, Egypt or elsewhere in Africa may therefore meet both frameworks over its borrowing life.

For a requirement-by-requirement walk through the ten ESRs, read our guide to the EBRD Performance Requirements, now ESRs. This page compares the two lenders and describes how we support borrowers.

Which text governs your financing?

The one your loan agreement cites. For the EBRD, that is normally the policy in force when Bank management gave initial approval to your project; for the IFC, the 2012 edition of its Sustainability Framework, except for older investments.

According to the EBRD’s official page, the 2024 policy supersedes the 2019 policy and its associated requirements, previously called Performance Requirements. Numbering is unchanged (ESR 2 matches the old PR2), which is why buyers and bankers still search for “EBRD performance requirements”.

IFC: an update under way, not yet adopted. As of 11 November 2026, the IFC’s official page publishes the 2012 Performance Standards and states that the IFC and MIGA are updating their Sustainability Frameworks. The published timeline (page updated September 2026) shows a dialogue phase expected to conclude in December 2026 and a public consultation phase expected to start in January 2027. Nothing has been adopted: the 2012 Performance Standards remain the basis of your commitments. The IFC also publishes Guidance Notes for each standard, last updated on 14 June 2021.

EBRD ESRs vs IFC Performance Standards: what is different?

The two frameworks cover the same ground and can be read almost line by line. The differences lie in structure, technical references and some thresholds.

Beyond the titles, four differences shape the work on an industrial site:

In practice, a well-designed ESMS for one lender serves most of the other. The difference lies mainly in emission limit values, the carbon threshold and the reporting format. If you have both lenders, build one system and one matrix that links each piece of evidence to both frameworks.

Which category will your project fall into, and why does it matter?

The category sets the depth of due diligence and the disclosure obligations. The lender decides it, not the borrower.

Under the IFC’s Sustainability Policy, Category A covers activities with potential significant adverse risks or impacts that are diverse, irreversible or unprecedented; Category B, limited risks that are few, generally site-specific, largely reversible and readily addressed through mitigation; Category C, minimal or no adverse risks; Category FI, investments in financial intermediaries. The EBRD follows similar logic: a Category A project requires a formalised, participatory environmental and social impact assessment, and most plant upgrades fall into Category B.

What the category changes for you:

• Category A: expect a formal, participatory impact assessment; under the IFC’s policy, the category also sets what the lender must disclose;
• Category B: due diligence focuses on the site’s concrete gaps, which feed the ESAP;
• Category C: requirements are light; the IFC notes that not all projects have an ESAP or reporting requirements, Category C projects for example.

What makes an environmental and social action plan (ESAP) workable?

A workable ESAP is a list of verifiable actions, each tied to a requirement, with a deliverable, an owner, a deadline, resources and closure evidence. It is a contractual commitment, not a statement of intent.

Both lenders say much the same. At the EBRD, ESR 1 requires an ESAP where existing facilities do not meet the ESRs at approval, and the ESAP forms part of the financing agreements. At the IFC, PS1 requires action plans that define desired outcomes as measurable events where possible, with performance indicators, targets or acceptance criteria tracked over defined periods, and estimates of resources and responsibilities. The IFC Sustainability Policy adds that the legal agreements commit the client to the conditions of these action plans, and that persistent delays can lead to loss of IFC financial support.

The most common mistakes: deadlines accepted to close the deal, with no budget or owner; vague actions that no evidence can close; contractors forgotten, although their workers and their accidents belong to the project.

How do ISO 14001:2026 (formerly ISO 14001:2015) and ISO 45001:2018 support lender requirements?

They provide the frame of the management system the EBRD and the IFC require, without covering its full scope. EBRD ESR 1 asks for an integrated environmental and social management system or an equivalent management system; IFC PS1 describes an ESMS with seven elements that closely mirror an ISO management-system standard.

ISO 14001:2026 was published in April 2026, with a transition period to 30 April 2029. ISO 45001:2018 is the current edition, shown at stage 90.92 (“to be revised”) on iso.org as of 11 November 2026. The EBRD guidance note on ESR 4 recommends a health and safety system based on the Plan-Do-Check-Act cycle, consistent with ISO 45001:2018.

Do not build a parallel ESMS: we integrate lender requirements into the existing system. See ISO 14001 certification, ISO 45001 certification and the integrated QHSE management system.

What carbon data do lenders ask for?

Above an emissions threshold, an annual quantification of the project’s greenhouse gas emissions. The thresholds differ: 20,000 t CO2e per year at the EBRD, 25,000 t CO2e per year at the IFC.

At the IFC, PS3 requires quantification of direct emissions from facilities owned or controlled within the physical project boundary, and of indirect emissions from the off-site production of the energy the project uses. Quantification is annual and follows internationally recognised methodologies and good practice, without prescribing a specific standard. It covers all significant sources, including non-energy sources such as methane and nitrous oxide.

In both cases, the safest method is an inventory built to ISO 14064-1:2018 and the GHG Protocol, with a written boundary and sourced emission factors. As of 11 November 2026, ISO 14064-1:2018 is under revision: a draft ISO/WD 14064-1.2 is at stage 20.60 on iso.org, and the 2018 edition remains the one that applies. See our carbon footprint to ISO 14064 service and our ISO 14064-1 requirements guide.

Carbon does not stop at reporting. IFC PS3 also asks the client to consider alternatives and implement technically and financially feasible, cost-effective options to reduce project-related emissions: that is the purpose of a decarbonisation strategy. Your company’s exposure to climate risk is a separate topic, covered in climate risk and IFRS S2.

What goes into the annual report, and how do you prepare a monitoring visit?

The annual report proves that the ESAP is progressing and that the project meets the requirements; the monitoring visit checks it on site, against the same evidence file.

At the EBRD, ESR 1 sets the minimum content of reports: compliance with the ESRs and implementation of the ESMS and ESAP, significant risks and impacts, performance indicators, grievances from workers and external stakeholders, and the assurance process used. Serious incidents are reported promptly, outside the annual cycle. For projects with significant risks, the Bank may require periodic reviews by independent experts.

At the IFC, the Sustainability Policy provides that the IFC reviews performance through the client’s Annual Monitoring Report and ESAP updates, and that legal agreements provide for supervision visits by IFC staff or representatives. PS1 adds that, for projects with significant impacts, the client retains external experts to verify its monitoring information, and reports to affected communities at least annually on action plans that concern them.

For a monitoring visit, prepare:

1. the status of each ESAP action, with its evidence and, where late, the explanation and proposed new date;
2. the year’s indicators and their source: meter readings, registers, filings;
3. the registers of accidents, incidents, internal and external grievances, and how they were handled;
4. contractor records for those working on site: contracts, training, accidents;
5. a site walk that shows completed actions, not just procedures.

Is your company ready for lender due diligence?

Run through these points with senior management, finance, HR and the HSE team before the first meeting with the lender.

• The governing text is identified: EBRD 2019 or 2024 policy, 2012 IFC Performance Standards, partner-bank requirements.
  
• The requirements that apply to the project are listed one by one, with the evidence expected.
  
• The risk register covers environment, health and safety, working conditions, communities and contractors.
  
• Environmental permits and emission monitoring reports are available and current.
  
• HR data (contracts, working hours, wages, agency workers) match social security filings.
  
• A grievance mechanism exists for workers, and another for communities.
  
• Workplace accidents of employees and contractors are recorded and analysed.
  
• Annual greenhouse gas emissions are estimated, to see whether the project approaches the lenders’ thresholds.
  
• Core suppliers and their labour risks are identified.
  
• An owner is appointed for the ESAP and the annual report.
  
• The procedure for prompt notification of serious incidents to the lender is written down.
  

If several boxes stay empty, start with requirements mapping and the gap assessment: they keep you from signing an ESAP your organisation cannot deliver.

What ACG does for EBRD and IFC borrowers

ACG, accredited by the EBRD, prepares and supports; the lender decides. We map requirements, assess gaps, draft the ESAP, help implement it, and prepare reports and visits. The firm reports 502 projects, 10 in-house consultants and more than 100 qualified external experts, and more than 120,000 people trained. We work with manufacturers in Morocco and Africa, notably in industry and energy, agri-food and packaging.

Lender requirements overlap with what your customers ask: sustainability questionnaires from European buyers (see CSRD, VSME and ESG questionnaires) and supply-chain due diligence (see supply-chain due diligence). For audits of your contractors and suppliers, see audits and inspections. For the full picture, go back to ESG and CSR.

We train your teams during the project: see our training. To discuss your financing, describe your project.