Scaling Up Responsibly

Programmatic approaches now account for over half of the Green Climate Fund’s (GCF) approved funding. Of the US$20.4 billion so far committed by the Fund as of B.45, US$11 billion (54 per cent) has been channelled through programmes rather than stand-alone projects. Yet the GCF has never adopted a clear, operational definition of what constitutes a “programme” or what a programmatic approach overall should be guided by, nor has it established policies to ensure transparency, accountability, and country ownership. New policy guidance has been repeatedly delayed, and it is concerning that the Secretariat has again pushed back developing this guidance, which was in the Board’s work plan for 2025 and 2026, on the grounds that it is preparing a new strategic plan and replenishment process. The quality of GCF-funded programmes is of vital importance to these processes and their outcomes. This briefing assesses the track record of programmatic financing to date and identifies significant governance gaps – in particular, related to private equity financing and guarantees at a time when investments in these instruments are growing in scale – that need addressing.

Programmes are a type of funding proposal typically characterised by having subprojects, with the specific subprojects rarely identified in the funding proposal at the time it is approved. In practice, this means that the GCF Board often approves significant funding without clarity on its sectoral allocation, geographic distribution, risk profile, beneficiaries or alignment with national priorities. These transparency and accountability concerns at the time of the GCF funding decision are particularly acute in the case of private sector equity investments and guarantees, which are channelled through intermediary funds and investment vehicles that make their own investment decisions after GCF approval, often under commercial confidentiality, so that there is little public visibility of what is actually being financed.

Post-approval reporting on programmes also falls short. Subproject-level environmental and social safeguard assessments are disclosed only sporadically, and subproject-specific gender assessments and gender action plans are not published on the GCF website at all. In some cases, even years after approval and substantial disbursement, there is little or no public information describing subproject locations, amounts, environmental and social risks, or their approach to ensure gender equality, implementation or achieved climate results. Annual Performance Reports (APRs) are not always published, and those that do make it into the public domain are often delayed and/or heavily redacted, and lacking in adequate subproject-level information. This basic information gap weakens public scrutiny and accountability for claimed goals and beneficiaries being reached in implementation, limits opportunities for stakeholder engagement, and reduces the ability to learn from experience.

Most programmes are multi-country if not multi-region, with some spanning a disparate set of countries across the globe with little in common. Around three-quarters of GCF programmes (74 in total) span more than one country, compared with only around one in 20 stand-alone projects.1 Repeated evaluations have shown that country ownership is weaker under such multi-country programme structures. National Designated Authorities (NDAs) often have no involvement after issuing no-objection letters, with even basic programme information and funding opportunities not shared, and no formal notification given to NDAs when subprojects are approved in their countries. Inclusion in a programme’s geographic scope does not guarantee that a country will host subprojects, and evidence suggests that Least Developed Countries and smaller markets such as in Small Island Developing States, included as part of the sales pitch of larger programmes, see few subprojects. 

The programmatic model also creates space for high-risk or weakly justified financing that would not stand up to scrutiny if presented as stand-alone projects. Several cases are highlighted, including investments in luxury resorts, those linked to environmental controversies, and double financing of the same companies or projects across different funded activities without any clear communication that this has taken place.

The current absence of clear definitions on what constitutes a programme, minimum transparency standards, subproject disclosure rules, and oversight mechanisms leaves significant accountability gaps, which should be addressed through clear policy guidance on the GCF’s programmatic approach – and done so urgently as part of defining the next funding period of the GCF under its upcoming third replenishment efforts (GCF-3, 2028-2031).