C0006 Nicaragua

FP146: Bio-CLIMA: Integrated climate action to reduce deforestation and strengthen resilience in BOSAWÁS and Rio San Juan Biospheres

C0006 Nicaragua

In June 2021, the IRM received a complaint relating to FP146. The complainant(s), while welcoming the objectives of the project, alleged that the project would harm indigenous and Afro-descendant communities as 1) prior to the approval of the project, there was no proper consultation with communities, including no free, prior, and informed consent (FPIC); 2) the project will lead to environmental degradation and attacks by armed non-indigenous settlers; 3) the Accredited Entity’s actions do not seem to comply with the GCF’s policies, especially on participation and information disclosure; 4) the GCF Board conditions placed on the project, especially relating to the implementation of FPIC and to the selection of independent third party monitor(s), will not be defined and complied with effectively; and 5) the executing entity will not fulfil its obligations in the implementation of the Bio-CLIMA project (more details about the complaint can be found in the eligibility determination report). The complainant(s) requested confidentiality, and the IRM granted confidentiality in accordance with its TOR and PGs and as a result of its retaliation risk assessment. The complaint was declared eligible on 21 July 2021, and the case proceeded with the Initial Steps phase, where the IRM explored the options of problem solving and compliance review, with the complainant(s) and other stakeholders. After an initial round of meetings, all parties expressed their willingness to explore problem solving under the facilitation of the IRM. At the conclusion of this phase (extended to 180 days from the original 60 days), parties were unable to reach an agreement on substantive matters relating to the framework and process design of a dialogue before the deadline. In these circumstances, on 17 January 2022, the IRM referred the complaint to compliance review for further processing. Subsequently, the IRM requested the GCF Secretariat to provide a response to the complaint and a response was submitted on 3 March 2022. Having received the response, the IRM undertook its compliance appraisal process culminating in a compliance appraisal report, published on 24 March 2022. Subsequently, the IRM commenced a compliance investigation to further assess the three issues set out at the end of the compliance report and reach a final finding on the issues. As part of the investigation, the IRM conducted in-person and virtual interviews with relevant parties and stakeholders, including but not limited to, the complainant(s), AE, GCF Secretariat, EE and experts on relevant issues. After concluding its investigation, the IRM submitted the final compliance report, with factual findings and recommendations, to the Board on 30 August 2022. During meetings of the Board held in October 2022 (B.34), the Board issued a decision related to the ongoing consideration of the IRM Compliance Report.

Case status


30 Jun 2021

Eligibility / Preliminary inquiry
Initial steps and process choice
Compliance appraisal
Compliance investigation
Compliance report
Board decision



Nature of harm raised

Land ownership & possession
Project due diligence
Cultural heritage
Free, prior, informed consent
Indigenous people rights
Environmental damage

GCF policies raised

Environmental and social standards
Environmental and social policy
Indigenous peoples policy


Title Versions
Eligibility determination
ENGLISH | español
First time limit extension for initial steps
Second time limit extension for initial steps
ENGLISH | español
Final time limit extension for initial steps
English | español
Report on the Initial Steps Phase
English | español
Extension of time decision - Response from the Secretariat
English | español
Compliance Appraisal Report
Board Decision (B.34/23): Consideration of IRM Compliance Report on Case C-0006-Nicaragua

Project details

Project numberFP146
Project title Bio-CLIMA: Integrated climate action to reduce deforestation and strengthen resilience in BOSAWÁS and Rio San Juan Biospheres
Country Nicaragua
Latin America and the Caribbean
Accredited Entity Central American Bank for Economic Integration
Result areas
Forests and land use
Risk category Category A