Inclusion and accessibility within Accountability Mechanisms: ensuring persons with disabilities are not left behind

Representing over 1 billion people, persons with disabilities are one of the world’s most significant minorities according to the World Health Organization. This number is growing every day due to causes such as increasing ageing populations, conflicts, and climate-related disasters. Among persons with disabilities, eighty per cent live in developing countries where development projects and programmes such as the ones financed by the Green Climate Fund (GCF) are implemented.

According to Article 1 of the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD), “Persons with disabilities include those who have long-term physical, mental, intellectual or sensory impairments which in interaction with various barriers may hinder their full and effective participation in society on an equal basis with others.” However, the World Health Organization (WHO) also recognises people who have a disability regardless of its duration. Hence, the term "persons with disabilities" encompasses a range of people with different experiences of disability. It is, therefore, difficult to find solutions that can accommodate all persons with disabilities, as their experiences are very different.

Development projects and programmes are often large-scale and aim to improve the lives of millions of people. However, sometimes these projects or programmes can unintentionally affect a person or a group negatively. Among those who may be negatively affected, a range of vulnerable people, such as persons with disabilities, should be given greater protection because they may be overlooked in projects or programmes' plans and can subsequently be negatively impacted by them. Nevertheless, specific guidelines and policies regarding persons with disabilities appear to be relatively rare among accountability mechanisms. Therefore, by looking at what has been put in place by parent institutions of complaint mechanisms, this article presents some examples of opportunities that accountability mechanisms can consider to strengthen their inclusion and accessibility to persons with disabilities.

In recent years, some Development Finance Institutions (DFIs) have begun to include more provisions in their policies to enable persons with disabilities to be better integrated into development plans. For example, the World Bank (WB), the United Nations Development Programme (UNDP), and the Asian Development Bank (ADB) use frameworks or have adopted commitments directed explicitly at increasing the inclusion of persons with disabilities.

In 2018, the WB produced the Disability Inclusion and Accountability Framework. Promoting this Framework is one of the ten commitments the World Bank Group made to support the Bank’s new Environmental and Social Framework and provide guidance and direction to the Bank staff to achieve disability-inclusive development. The WB has incorporated this framework in its general policies, guidelines, and procedures, including its accountability and grievance resolution mechanisms. It is mentioned in the framework that “the World Bank’s accountability and grievance resolution mechanisms need to be accessible to persons with disabilities, which entails specific efforts toward reasonable accommodation and outreach”. The updated version of the Inspection Panel’s Operating Procedures from 2022 has cited in its footnote under the passage on accessibility: “the Panel adopts the four main principles of the World Bank’s Disability Inclusion and Accountability Framework: non-discrimination and equality, accessibility, inclusion and participation, and partnership and collaboration.” Since the Disability Inclusion and Accountability Framework is to be implemented in the WB’s policies and operations, all its bodies will thus have to ensure that they are accessible to persons with disabilities.

The Inspection Panel has not yet published any instrument on how to implement a more inclusive and accessible complaint mechanism effectively for persons with disabilities. However, it has participated in events informing persons with disabilities and relevant organisations about the Panel’s mandate and procedures. For example, during the Convention on the Rights of Persons with Disabilities (COSP9), the Inspection Panel hosted a side event with the Special Rapporteur on the Rights of Persons with Disabilities, introducing the World Bank’s Inspection Panel and informing the disability community about the Inspection Panel’s mandate, policies and procedures. Sign language interpretation was also provided during the event.

This example is rather important because although some DFIs are beginning to incorporate provisions designed for persons with disabilities into their rules and procedures, it is still relatively rare to find specific guidelines for the better inclusion and accessibility of persons with disabilities within the Independent Accountability Mechanisms of these institutions. Even though most accountability mechanisms have provisions to be equally accessible and available to all, this provision might not always be efficient in practice, particularly if the institution doesn’t have strict guidelines regarding this group of people. Yet, since persons with disabilities represent such a significant minority group, accountability mechanisms need to consider existing policies and procedures which can strengthen the inclusivity and accessibility of this population and, more broadly, to all potential stakeholders.

Another example is the UNDP’s Guidance Note called the Disability Inclusive Development in UNDP. This Guidance Note aims to better include persons with disabilities in development programmes and achieve the Sustainable Development Goals. It presents areas where disability inclusive development should be strengthened and gives practices to improve it. For example, on the accessibility of communications materials and web content, the Guidance Note suggests that “when creating documents and other communication materials, everyone can use an approach for print and/or digital formats that meets the needs of all users, also known as ‘universal design.’” Universal design can be applied in the design of a variety of mediums, it can be used in the creation of buildings, products and services, but it can also be used in the development of websites and documents. The universal design of web pages and documents requires, for example, simple edits such as accessible fonts, descriptive links, bullet point lists, headings, and simple tables for data to make access to online tools and documents easier to read for screen reader users. Having alternative formats for documents such as large prints, Braille or ‘easy to read’ formats (a format that is easy to understand by people with intellectual difficulties, children, or people with low literacy levels, which can involve pictures and graphs to explain the content), are also ways to make documents more accessible to a broader audience. Applying universal design standards to all types of documents is a way to address barriers that prevent access to information, particularly for persons with disabilities. The UNDP Guidance Note presents concrete steps within the context of the UNDP programming to ensure more accessibility for persons with disabilities. For example, in the section on the UNDP Environment and climate change disability-inclusive development, recommendations are made to integrate the needs and knowledge of people with disabilities in environmental programmes, such as: “ensuring that organisations of persons with disabilities are more consistently engaged in all community initiatives on environment and climate change adaptation at design, implementation and monitoring stages.” Or “Ensuring research and data on different areas of environmental programming is disability inclusive and adequately captures the impact on persons with disabilities.” (p. 49). Yet, its recommendations could be applied to other organisations as well. For instance, the GCF could implement the UNDP Guidance Note’s recommendations on the environment and climate change section into its policies. Considering that the impact of climate change is disproportionately affecting persons with disabilities, ensuring that persons with disabilities are included in the development plans, projects and programmes of DFIs and that they have access to support and remedies if needed is essential. Therefore, the UNDP Guidance Note’s recommendations and good practices could be used by DFIs and their accountability mechanisms to strengthen their policies and guidelines to better include persons with disabilities.

A final example is the ADB which participated in the Global Disability Summit in 2018 and signed the Global Disability Summit Charter for Change. The ADB adopted nine supplementary commitments during the Summit to promote disability-inclusive development. According to the Bank Information Center, the ADB is currently updating its policy brief regarding disability inclusion.

The cited DFIs possess guidelines or have signed charter agreements to include persons with disabilities in their policies and development plans. Creating similar approaches to integrate persons with disabilities better could be an opportunity for accountability mechanisms to improve their accessibility and inclusivity as well. Some basic implementations would be, for example, to ensure that the mechanism’s websites and online tools are available for persons with disabilities and that users with disabilities can provide feedback to improve the document’s accessibility. For example, the technology corporation Microsoft started inclusive usability studies with persons with disabilities to test their applications and ensure they are inclusive and accessible to all. A Microsoft researcher initiated the study by asking company employees who have a range of disabilities to test the Microsoft portal by performing a series of tasks and then providing feedback on their user experience. With this feedback, which included changing the contrast and colour scheme of the interface, using simpler language or providing a video user guide in American Sign Language (ASL), the engineers were able to get a real sense of how to improve the Microsoft portal and make it more accessible and usable to all users. Usability testing of websites or online tools with people with various disabilities is a strategy that can be implemented by any organisation or unit, such as accountability mechanisms, and can provide solutions on how to improve the accessibility of shared online documents.

As mentioned above, ensuring that available online documents are shared in the universal design format or creating brochures in Braille would be ways to make information more accessible for persons with visual impairment. For instance, the different UN bodies have been distributing Braille materials on several occasions. During the COVID-19 pandemic, the United Nations Development Programme (UNDP) produced Braille materials on awareness and prevention of COVID-19. It circulated them to the Ministry of Gender, Community Development and Socials Welfare in Malawi to help spread correct information to the vulnerable population, such as persons with visual impairment. Recently, the IRM has also taken its first steps to improve its accessibility to persons with a hearing impairment. At its most recent outreach event in the Pacific Region, the IRM offered sign language interpretation to attendees at the recommendation of the partner CSO, the Pacific Islands Climate Action Network (PICAN), with whom the event was held to ensure that the presentation of the IRM’s mandate and how to use its services could reach as many people as possible. Therefore, the IRM is in the process of implementing ways to make itself more accessible to a wider range of people. Offering sign language interpretation at virtual events is a way to be more inclusive of persons with disabilities. The prominence of virtual events today due to the COVID-19 pandemic facilitates this form of communication since online conference platforms can easily accommodate sign language interpreters.

However, in terms of accessing accountability mechanisms, persons with disabilities, when faced with additional accessibility barriers such as illiteracy, lack of internet access, lack of knowledge about their rights, etc., may need other types of implementations since the above examples are not sufficient to ensure accessibility for all. More general recommendations introduced by the WB in a presentation on Effective Grievance Redress Mechanisms are, for example, to establish grievance uptake locations in areas where marginalised people reside and engage with local intermediaries on the ground to help these populations file complaints if needed. Therefore, by reaching out to local organisations or disability rights civil society organisations (CSOs) on the ground, the likelihood that information about the accountability mechanism is being transmitted to marginalised populations such as persons with disabilities with intersecting discrimination could increase, thereby improving the accessibility of the accountability mechanism and the chances of providing redress to people in need.

The above are just a few recommendations to consider in ensuring that redress remains accessible and inclusive to all, especially persons with disabilities. Of course, these recommendations do not encompass all types of disabilities, given the wide range of disabilities experienced. Therefore, much more research and institutional support is needed to find methods to include an even broader range of people. Finally, perhaps the most effective way would be for institutions to adopt a disability framework in their policies to ensure that persons with disabilities are taken into account when formulating and implementing projects or programmes and that all units within institutions share a unified framework. This way, resources would be used to meet the needs of the entire population. Again, given the large number of persons with disabilities in the world, particularly in developing countries where most development projects and programmes are conducted, accountability mechanisms must strengthen their inclusion and accessibility to persons with disabilities and be able to provide them with recourse when necessary.

Disclaimer: The views expressed in the blog are the author's own and do not necessarily reflect the views of the Independent Redress Mechanism of the Green Climate Fund.