Table compiled by Brandon Wu, ActionAid USA, and Liane Schalatek, Heinrich Böll Foundation Washington, DC
| Topic | US Proposal | EU TC members' Proposal | Developing Countries' Proposal | CSO (ENGO/WGC) Proposal |
| Objectives & Principles | serve developing countries that are particularly vulnerable to the adverse effects of climate change; operate in a transparent and accountable manner guided by efficiency and effectiveness; catalyze finance, both public and private; pursue a country-driven approach; be scalable and flexible and a continuously learning institution; promote environmental, social, economic and development co-benefits, and taken a gender-sensitive approach (para 3) | transparent and accountable... guided by efficiency and effectiveness, acknowledging the importance of new, additional, adequate and predictable financial resources... country-owned programmatic approach... scalable and flexible... promoting environmental, social, economic and development co-benefits, and taking a gender-responsive and human-rights-based approach (para 3) | The Fund is the main channel for new multilateral finance to address loss and damage associated with the adverse effects on climate change (para 3); operate under principles of UNFCCC & Paris Agreement; country-driven; predictable, new, adequate, additional, significant resources; primarily grant-based; flexible; etc (paras 7-20) | Fund is to make a significant and ambitious contribution; will operate under international law & guided principles & provisions of UNFCCC & PA and of intl cooperation & solidarity, including ensuring: CBDR; country ownership; new/additional/ adequate/predictable financing; balanced & comprehensive in scope; non-debt-creating; human rights based; robust public participation (section I) |
| Accountability/relationtship to COP/CMA | receive guidance from the COP/CMA on policies, programs and eligibility criteria (para 4, GI para 5-6) | Receive guidance from the CMA on its policies, programmatic priorities and eligibility criteria (para 5a) | Operating Entity of the financial mechanism of the Convention (para 1 and 57), accountable to COP/CMA (para 57) | Operating Entity of the Financial Mechanism of the Convention and Paris Agreement, accountable to COP/CMA (section II-A) |
| Overarching Entity | hosted by the World Bank as a Financial Intermediary Fund (para 5) | the Fund is to be hosted by the World Bank as a Financial Intermediary Fund (decision para 6) | Standalone fund - desinated as an operationg entity of the financial mechanism (paras 1, 57) | UNFCCC - OE of the FM (II-A) |
| Legal Personality | as a World Bank-hosted FIF, relies on World Bank's legal personality | as a World Bank-hosted FIF, relies on World Bank's legal personality | The Fund, as a body under international law, shall possess international legal personality. (para 68) | in order to operate effectively internationally, the Fund will possess juridical personality… (section II.B) |
| Eligibility | developing countries that are particularly vulnerable to the adverse effects of climate change (GI paras I-2, para III-C-51) | developing countries that are particularly vulnerable to the adverse effects of climate change, namely LDCs, SIDS, and other particularly vulnerable countries based on specific eligibility criteria approved by the Board (34, 44) | In accordance with the Convention, including Article 4.3, all developing countries that have suffered climate-related loss and damage, without discrimination or any form of exclusion, are eligible to receive financial resources from the Fund. (para 33) | All developing country Parties to the Convention and the Paris Agreement are eligible to receive financial support from the Fund to address economic and non-economic loss and damage. Eligibility will not be determined or differentiated by income classifications used outside of the UNFCCC. (V-B) |
| Board Composition | 29 members: 2 Africa, 2 Asia/Pacific, 2 Latin America & Caribbean, 2 SIDS, 2 LDCs, 1 Eastern Europe, 10 Western Europe & Others Group, 4 contributors, 1 civil society, 1 private sector, 1 philanthropic, 1 Indigenous People (paras 10-11; GI para II-B-7); due consideration to gender and regional balance (para B-9) | 22 voting members: 2 Africa, 2 Asia/Pacific, 2 Latin America & Caribbean, 2 SIDS, 2 LDCs, 1 Eastern Europe, 6 Western Europe& Others Group, 6 contributors; | equitable and geographically balanced representation of all Parties; equitable number of members from developing and developed country Parties; representation from developing country Parties shall include representatives of relevant United Nations regional groupings and representatives of small island developing States and the least developed countries (para 58) | 25 members: 3 from each of the 5 UN regional groups, 2 SIDS, 2 LDCs, 3 Annex I, 3 non-Annex I; In addition, the Board shall develop further mechanisms, including the consideration of designated Board seats, to ensure and enable the meaningful participation of communities adversely impacted by climate change (II-C-1) |
| Board Observers | 2 CSO, 2 PSO active observers (GI para II-B-15) | 7 active observers, 1 each from CSO, PSO, philanthropy, IPO, LGMA, youth, WGC | The Fund may further consider means to enhance engagement with observer organisations. (para 60) | 2 active observers (1 developed, 1 developing) from each UNFCCC constituency, with funding support provided (II-C-7) |
| Board Decision-Making | consensus; 4/5ths majority vote in absence of consensus (GI para II-B-12) | consensus; 4/5ths majority vote in absence of consensus (13) | consensus; 2/3rds majority vote with majority from each constituency in absence of consensus (para 66) | consensus with voting procedures to be adopted by the Board (II-C-5) |
| Secretariat | The World Bank is to be invited to serve as the Trustee of and provide secretariat services to the Fund, and in this role to serve in a fiduciary and administrative capacity, and is to be bound by its Articles of Agreement, by-laws, rules and decisions. (GI para II-A-7; also para 13) | The World Bank is to be invited to ... provide secretariat services to the Fund (7) | Independent Secretariat (para 70) | Independent Secretariat; committed to best practice work culture and adequately staffed with with professional stuff with relevant experience and expertise from diverse backgrounds … and with an understanding of the lived experiences of affected communities; staff selection with geographical and gender balance (II-E) |
| Executive Director | Selected by Board (GI para II-D-21) | Selected by Board (22) | Established by Board (para 69) | Appointed by and accountable to the Board (II-E-1) |
| Trustee | The World Bank is to be invited to serve as the Trustee of and provide secretariat services to the Fund, and in this role to serve in a fiduciary and administrative capacity, and is to be bound by its Articles of Agreement, by-laws, rules and decisions. (GI para II-A-7; also GI para II-E-25 through II-E-30; also para 9) | The World Bank is to be invited to serve as the Trustee of... the Fund (7, 26-31) | Invites the World Bank to act as the Trustee of the LD Fund on an interim basis until confirmed by the Board (para 13 of decision) | The World Bank will serve as interim trustee for the Fund, subject to a review three years after the operationalization of the Fund. (II-F) |
| Implementing Entities | international entities, government systems and entities or local entities, as appropriate for SOE and Small Markets; MDBs for Recovery & Reconstruction | Secretariat mandated to Establish modalities to allow recipients to use implementing entities, including international entities, national systems or local institutions as appropriate (24m) | The Fund will adopt a partnership model to be operationalized through identifying potential programming partners and/or recognized accredited entities, including at the regional, national, and local levels. (para 15) | direct access (through regional, national, and subnational entities) and international access (through international entities such as United Nations agencies) using entities already accredited by other funds (V-E) |
| Country Ownership | The Fund should support activities based on a country-driven approach; encourage the involvement of relevant stakeholders, including vulnerable groups; and be gender responsive (para 31) | country-owned programmatic approach that strengthens national systems, institutions and policies (para 32) | very strong emphasis in section on country ownership in paras 37-41, including provisions for direct budget support | In line with a country-driven approach, the Fund will provide finance to support existing and new national and local level coordination mechanisms (V) |
| Access | access modalities defined in the context of different proposed sub-fund details (see below) | no mention aside from Board mandate to approve access modalities (19b) | there will be arrangements to provide direct access, including through national, sub-national, and regional entities, or in partnership with entities accredited to other financing vehicles, or otherwise through implementing partners appointed by the Board (para 29) | ...the Fund will prioritize direct access, including by affected communities and vulnerable groups, including women, youth, Indigenous Peoples and people living with disabilities. (V); Access to Fund resources will be primarily through a designated national agency or body, including existing designated authorities or focal points already registered with other climate funds or country coordinating mechanisms. (V-E) |
| Windows or Sub-Funds | Slow onset event (SOE) sub-fund; recovery & reconstruction sub-fund; small markets sub-fund; Board may add, modify and remove sub-funds, substructures, or facilities (GI paras III-A) | main fund plus LDC/SIDs sub-fund; recovery & reconstruction sub-fund; pre-arranged finance sub-fund; small grants response sub-fund; human mobility sub-fund | No specific provisions for windows | rapid-onset; medium-term rehabilitation/ reconstruction; slow-onset; community direct access. The Board has the authority to add, modify or remove additional windows or sub-structures as needed. (V-C) |
| Window: Rapid Onset Response | no provisions | through main fund which will operate by facilitating and financing the country-owned national Response Plans that address both slow and rapid onset events (34-35) | In the aftermath of climate-related events, the Fund will act as an available safety net when impacts overburden national capacities. (para 13) | A rapid-onset window to provide quick release funding in the aftermath of climate disasters (V-C-1); access via direct budget support or through a designated national entity (V-E) |
| Window: Slow Onset Events | countries develop SOE plans to submit to Board for approval and decide on implementing entities; Board considers and approves proposals, including possibly readiness support (GI paras III-A-33 through III-A-37) | through main fund which will operate by facilitating and financing the country-owned national Response Plans that address both slow and rapid onset events (34-35) | The Fund will meet programmatically defined needs for addressing loss and damage from extreme weather and slow-onset events (para 13); The Fund's resource allocation system shall also pay attention to, among other things, loss and damage associated with slow onset events... (para 29) | A slow-onset window to provide funding for longer-term loss and damage, including support for planning and policy frameworks and transformative programming such as permanent relocation or a just transition to alternative livelihoods (V-C-3); access through existing international and direct access entities accredited with other funds (V-E) |
| Window: Recovery & Reconstruction | provide funding for eligible countries that need additional, or more concessional, funding for recovery and reconstruction through MDBs - countries work with MDB to get loans at terms more favorable than those offered by WB; subject to Board approval (GI paras III-A-38 through III-A-42) | sub-fund will closely cooperate with MDBs... to provide additional and as appropriate more concessional funding for recovery and reconstruction in response to economic and non-economic loss and damage post climate-related disasters (38) | no mention | A window focused in the medium-term on rebuilding lives, livelihoods, wellbeing and infrastructure through rehabilitation and reconstruction measures (V-C-2); access through existing international and direct access entities accredited with other funds (V-E) |
| Window: Community Direct Access | no provisions; local entities may be nominated as implementing entities under SOE or Small Markets sub-funds | The Small Grants Response Sub-Fund is to provide financial and technical support to local civil society and community-based organizations... to develop and implement local actions to respond to loss and damage in alignment with Response Plans. (40) | Board may develop modalities for Enhanced access for communities and other groups (para 42b) | A community direct access window for subnational and local actors, in particular affected communities, women, youth, Indigenous Peoples, people living with disability, and civil society organizations working directly with them for both rapid-response and addressing slow-onset impacts (V-C-4); access modalities to be defined by Board (V-E) |
| Window: Small Markets | accessible to countries with populations of five million or fewer, which develop Response Plans to economic and non-economic L&D, submitted to the Board for consideration and approval, including the possibility of readiness funding (GI paras III-A-43 through III-A-47) | no mention, instead the LDCs/SIDS sub-fund is targeted at countries formally listed as LDC and/or SIDS by UN the at the time of their submission of... plans with support available for response to both slow and rapid onset events (37) | no mention | no mention |
| Window: Others | none | Pre-Arranged Finance sub-fund works with e.g. Global Shield to provide additional funding for pre-arranged financing for loss & damage (39); Human Mobility sub-fund finances activities related to human mobility, including planned relocation, migration and force displacements caused by climate change (41) | none | none |
| Financial Inputs | from, inter alia, national governments, regional economic integration organizations, sub-national governments, private sector, philanthropies, NGOs, innovative sources such as voluntary carbon markets or international pricing mechanisms (para 17; GI para V-50) | from, inter alia, national governments, regional economic integration organizations, sub-national governments, private sector, philanthropies, NGOs, innovative sources such as voluntary carbon markets or international pricing mechanisms; Parties in a position to do so will contribute to the fund (53-54) | primarily sourced through grant-based public financing in a predictable and additional manner (para 12); but will accept various sources including from developed countries, with voluntary contributions from other Parties (paras 48-51); The Fund will maintain the flexibility to receive financial inputs on an ongoing basis and receive grants from public and private sources and paid‐in capital contributions and concessional loans from public sources (para 53); can receive additional financial inputs from philanthropic foundations and other non‐public and alternative sources, including new and innovative sources of finance that meet the principles and purposes of the Convention and the Agreement (para 54) | mainly from developed countries and exclusively in the form of grants and non-debt-creating instruments; capable of receiving and administering financial inputs on an ongoing basis from a variety of other public as well as private , philanthropic and innovative/alternative sources (section IV) |
| Earmarking | earmarking allowed to specific sub-funds (GI para V-52) | earmarking allowed to specific sub-funds (55) | no earmarking - Contributors may only pledge and/or make payments directly to the LDF General Trust Fund (para 52) | no mention |
| Financial Outputs | grants and concessional lending, taking into account vulnerability, access to other financial contributions and debt sustainability. (GI para III-G-55) | The Fund is to provide financing in the form of grants and concessional lending, and may do so through other modalities, instruments or facilities , such as guarantees, reimbursable grants and equity, based on the Board’s policies. (50) | The Fund shall primarily provide grants (full costs and incremental costs) and non-debt finance (para 44); The Fund should also be able to facilitate a blending of different financial tools to optimize the use of scarce public funding (para 45); The Board of the Fund will develop and deploy a range of additional financial instruments that limit the financial burden on countries suffering climate loss and damage (highly concessional loans, guarantees, direct budget support and policy-based finance, equity, insurance mechanisms, risk sharing mechanisms, performance-based programmes, and other financial products where appropriate) (para 47) | The Fund will provide financing exclusively in the form of grants and non-debt creating financial instruments. (VI) |
| Allocation | In allocating resources, the Board is to take into account the needs of developing countries that are particularly vulnerable to the adverse effects of climate change and the importance of accessibility in all regions. [The Board will annually allocate contributions to the Fund to individual sub-funds in a balanced way that takes into account factors that include vulnerability and demand.] (GI para III-E-52) | Board-approved allocation system, which may vary by sub-fund, based on vulnerability indicators eg GDP per capita, debt exposure, HDI, environmental vulnerability ranking, exposure to climate hazards, etc (paras 45-48) | The Board shall strive to ensure a fair balance between the abovementioned considerations through Fund guidelines and other modalities while ensuring a geographical and thematic balance (para 35) | Board will take into account the urgent and immediate needs of developing countries that are particularly vulnerable to the adverse effects of climate change, including by considering minimum allocation floors for some country groups; allocation will also be balanced among windows with a set-aside for the direct access window (V-G) |
| Approval Process | Board approval across all sub-funds | streamlined programming and approval processes to enable timely disbursements. The Board is to develop processes for the approval of proposals with a view toward enhancing access for certain activities, in particular small-scale activities (49) | The Fund shall have a streamlined and rapid approval process to enable effective disbursement, with simplified criteria and procedures for all activities under its scope (para 30) | The Fund will have streamlined programming and approval process to enable timely disbursement. This includes both a trigger mechanism for rapid-onset window ad simplified processes for the approval based on a template approach through the medium-term and slow-onset windows. (V-H) |
| Monitoring & Evaluation | regular monitoring; participatory monitoring involving stakeholders is encouraged; results management framework; periodic evaluations by World Bank Independent Evaluation Group to be presented to COP/CMA (GI paras VI and VII) | regular monitoring; participatory monitoring involving stakeholders is encouraged; results management framework; periodic evaluations by World Bank Independent Evaluation Group to be presented to CMA (57-60) | no mention | regular monitoring with participatory monitoring singled out as crucial; results management framework; periodic indepedent evaluations, by an independent evaluation unit to be established by the Board (sections VII and VIII) |
| Environmental & Social Safeguards | each implementing entity applies [its own][its respective] environmental and social safeguards policies, which are to be applied to all activities financed by the Fund; Secretariat will support the strengthening of capacities in recipient countries, where needed, to enable them to attain functional equivalency with the World Bank’s environmental and social safeguards (GI paras IX) | each implementing entity applies its respective environmental and social safeguards policies, which are to be applied to all activities financed by the Fund; Secretariat will support the strengthening of capacities in recipient countries, where needed, to enable them to attain functional equivalency with the World Bank’s environmental and social safeguards (63-64) | general reference in para 20; safeguards section (paras 55-56), bu no specific reference to environmental and social safeguards. | best-practice environmental and social safeguards and human-rights-based gender and Indigenous Peoples policies to be adopted and applied to all financed activities, with support for capacity-building as needed (section X) |
| Stakeholder Participation | the Board is to develop mechanisms to promote the input and participation of stakeholders, including private-sector actors, civil society organizations, vulnerable groups, women and indigenous peoples, in the design, development and implementation of the activities financed by the Fund. (GI para XII-66) | the Board is to develop mechanisms to promote the input and participation of stakeholders, including private-sector actors, civil society organizations, vulnerable groups, women and indigenous peoples, in the design, development and implementation of the activities financed by the Fund. (para 69) | The Fund may further consider means to enhance engagement with observer organisations. (para 60); also: The Board may establish consultative forums to engage, communicate and consult with stakeholders. (para 71) | The Board will develop mechanisms to promote the equitable, effective and inclusive input and participation of stakeholders, including ones from affected communities, civil society organizations, and groups that have been made vulnerable through historic marginalization such as women, Indigenous Peoples, people living with disability, and youth in the design, development, implementation, and monitoring and evaluation of the strategies, policies, and activities to be developed and financed by the Fund. This will include development of appropriate mechanisms at the Fund and recipient country levels and adequate access to information. (section XIII) |
| Complementarity/ Coherence | establish Resilient Futures Coordination Council which meets every 2 or 5 years and includes members from WB/MDBs, IMF, relevant UN agencies, multilateral climate funds, and L&D experts (paras 25-28) | establish High Level Council for coordination (Annex 2); fund will coordinate with and take into account sources, funds, processes and initiatives under and outside the Convention and the Paris Agreement relevant to responding to loss and damage (42-43) | Fund should play the central role in a systemic global response to loss and damage... The Fund shall organise and lead a central platform for exchanging information, good practices, and consultations between existing mechanisms (para 26) | The Fund will coordinate between itself and other existing funds and funding arrangements under the Convention, and between itself and other funds, funding arrangements, entities, and channels of loss and damage financing outside the Fund (section V-A) |
| Other Notable | scalable target of $100bn by 2030 (para 23) | establishment of accountability mechanisms: independent integrity unit, redress mechanism (section XI) |