IFC Performance Standards vs EBRD Requirements: A Comparison

What are the IFC Performance Standards, and which financing do they cover?

The IFC Performance Standards are the eight environmental and social requirements that the International Finance Corporation, the World Bank Group member focused on the private sector, imposes on its clients for the life of its investment. The current text is dated 1 January 2012.

Together with the Policy on Environmental and Social Sustainability and the Access to Information Policy, they form the IFC’s Sustainability Framework: the policy sets out the IFC’s own duties (due diligence, categorisation, supervision), the standards set out the client’s. Three scope rules from the 2012 texts:

• Direct investments. The IFC requires the standards for its direct investments, including project and corporate finance provided through financial intermediaries, wherever environmental or social risk is moderate to high.
• Scope. Where the use of proceeds is defined, the requirements cover the activities the IFC finances; the IFC encourages clients to apply their management system to all their operations.
• Triggers. PS1 applies to every project with environmental and social risks; PS2 to PS8 apply according to the risks identified. National law applies on top, never instead.

Eight Guidance Notes, one per standard, and an Interpretation Note on Financial Intermediaries explain the requirements; the IFC states that they may be updated.

An update under way, nothing adopted. As of 11 November 2026, ifc.org says the IFC and MIGA are updating their Sustainability Frameworks: a dialogue phase is expected to end in December 2026, then public consultation on a first draft is expected to start in January 2027. The 2012 standards remain the reference for your commitments.

The EBRD started from the same base. According to a comparative study commissioned by the IFC (March 2026; the views are the author’s own), the EBRD adapted the Performance Standards into its own requirements in 2008, and the Equator Principles, used by banks for project finance, adopted them as their technical reference. For the EBRD side in detail, see our guide to the EBRD Performance Requirements; our EBRD and IFC ESG requirements page gives the overview.

What does each of the eight IFC Performance Standards require?

Each standard has its own trigger and requirements. The table summarises them for an industrial site and shows where the EBRD handles the same topic.

Three requirements catch manufacturers out most often:

• Contractors. Workers of third-party employers engaged for a substantial duration on core business processes fall under PS2: you check that their employers are legitimate, write the requirements into contracts and open your grievance mechanism to them if needed.
• Primary suppliers. Where the risk of child or forced labour is high, PS2 requires you to identify it, remedy it and, failing that, shift over time to suppliers who comply. See also our supply chain due diligence page.
• Cost-effectiveness as a test. Under PS3, an efficiency or GHG reduction measure is cost-effective if its risk-rated return is at least comparable to the project’s: a measure you rule out must be justified.

A system certified to ISO 14001:2026 (formerly ISO 14001:2015) or ISO 45001:2018 provides the frame of the ESMS, not the communities, the supply chain or the lender’s reporting format.

What are the EHS Guidelines, and what do they add to Moroccan law?

The World Bank Group Environmental, Health, and Safety (EHS) Guidelines are the IFC’s numerical technical references: air emissions, effluents, noise, occupational and community health and safety. Against host-country regulations, the more stringent level applies.

They consist of the General EHS Guidelines, dated 30 April 2007, and Industry Sector Guidelines for more than 60 sectors, used together: cement and lime, phosphate fertilizer, textiles, fish processing, dairy processing or vegetable oil, for example. According to ifc.org, the World Bank Group is updating them; only the English version is official.

Three rules matter most for an existing site:

1. The more stringent applies. Where Moroccan regulations differ from the guideline levels, the project meets the stricter one; a less stringent level needs a full, detailed justification in the environmental assessment.
2. A timetable for existing plants. The guidelines describe what is achievable in new facilities at reasonable cost; for an existing facility, the IFC may set site-specific targets with a timetable, which go into the ESAP.
3. Checkable values. An example from the General EHS Guidelines: noise at receptors must not exceed 55 dB(A) by day and 45 dB(A) at night in residential areas, 70 dB(A) in industrial or commercial areas (one-hour LAeq), or raise background levels by more than 3 dB at the nearest off-site receptor.

The EBRD starts from Europe: under its ESR 3, a project that would fall under the EU Industrial Emissions Directive must, wherever it is located, meet EU best available techniques (BAT); outside the EU, the compliance timeframe takes account of local conditions and cost.

For quantification, an inventory built to ISO 14064-1:2018 serves both lenders as a base, adjusted to the EBRD protocol when the EBRD lends; the standard is under revision (draft ISO/WD 14064-1.2 at stage 20.60 on iso.org as of 11 November 2026). See our ISO 14064-1 requirements guide and our carbon footprint ISO 14064 page.

Which lender’s rules apply to a project in Morocco?

Those of the lender that finances you, directly or through your bank, as written into your agreement. The financing structure decides the rulebook and who you deal with.

Categories FI-1, FI-2 and FI-3 describe the risk of the bank’s portfolio, from highest to lowest; the IFC assigns them. Other financial institutions may also apply the Performance Standards: your agreement will say so.

What happens when the IFC and the EBRD co-finance the same project?

Both lenders look for a common approach and a single set of commitments; they do not impose two parallel systems on you.

• On the EBRD side, the 2024 policy (paragraph 2.15) provides that the client cooperates with the Bank and its co-financiers to agree a common approach to the assessment, development and implementation of the project. The EBRD accepts it if it is materially consistent in content and outcomes with its policy and ESRs, and decides no later than project appraisal or final credit approval. The ESAP then measures performance against the common approach, and one set of documents can be disclosed to stakeholders.
• On the IFC side, the 2012 Sustainability Policy provides that, for co-investments, the IFC cooperates with other international financial institutions to reach a common understanding of their due diligence findings and of the supplementary actions required from the client; it may also lead on these matters in syndicated loans.

In practice: one ESMS, one ESAP, a matrix linking each piece of evidence to the relevant PS and ESR and, for each numerical value, the most demanding of the EHS Guidelines, the EU standards retained and Moroccan law. Plan GHG quantification from 20,000 t CO2e a year, since the common approach must stay consistent with the EBRD policy. Our EBRD and IFC ESG requirements page explains how to build a workable ESAP.

How does an IFC review run, from public summary to annual report?

In four stages: due diligence, disclosure of a summary, contractual commitments, supervision. What you accept in the ESAP becomes public and binding.

1. Due diligence. The IFC reviews your documents, visits the site, interviews staff and stakeholders, compares your practices with the standards and the EHS Guidelines, then makes the supplementary actions (the ESAP) conditions of its investment.
2. Disclosure. For Category A and B projects, the IFC discloses an Environmental and Social Review Summary (ESRS): the rationale for the category, main risks, mitigation measures and ESAP, and expected GHG emissions where above 25,000 t CO2e. It is released at least 60 days before Board consideration for Category A, 30 days for other projects (Access to Information Policy 2012, amended 25 November 2013).
3. Agreement. The financing agreements commit you to the standards, the action plans, reporting and supervision visits. You notify the IFC of any material change in your business.
4. Supervision. The IFC reviews your Annual Monitoring Report and ESAP updates; persistent delays can lead to loss of its financial support. Affected people can complain to the Compliance Advisor/Ombudsman (CAO), which is independent of IFC management.

Is your file ready for an IFC review?

• The applicable text is identified: 2012 IFC standards, 2024 EBRD ESRs or a common approach under co-financing.
  
• The Industry Sector EHS Guidelines for your activities are listed, alongside the General EHS Guidelines.
  
• For every effluent, emission and noise level, the value retained is the stricter of the EHS Guidelines and Moroccan regulations (and EU standards if the EBRD co-finances).
  
• Each gap at an existing facility has a proposed target and date for the ESAP.
  
• Annual GHG emissions are estimated against the 20,000 and 25,000 t CO2e thresholds.
  
• Contractors and primary suppliers are listed with their social risk level.
  
• Two grievance mechanisms exist: one for workers, anonymous complaints included, one for communities.
  
• The area of influence is described, associated facilities included (roads, lines, warehouses).
  
• You know what the IFC’s published summary will say about your project.