Silenced by Fear: How Retaliation Risks Undermine Access to Accountability Mechanisms

Development projects come with the promise of prosperity and progress. But for many communities, especially in the Global South, these promises are accompanied by disruption, dispossession, and fear. Independent Accountability Mechanisms (IAMs) offer a formal path to seek redress when projects financed by international financial institutions cause harm. Yet, the threat of retaliation continues to be one of the biggest, and least addressed, barriers to justice and remedy.

Filing a complaint is never a neutral act, it is an act of resistance. It often means challenging entrenched power: governments, corporations, and financiers. In many contexts, especially where civic space is closing, those who dare to disrupt the status quo face real consequences. Despite institutional commitments to transparency and remedy, Independent Accountability Mechanisms (IAMs) still fall short of offering the safety and support that such courageous action demands.

IAMs do not accept anonymous complaints. Even when civil society organizations file on behalf of communities, the identities of those affected will eventually be known, formally or through inference. In contexts where civic space is closing and dissent is dangerous, this can expose community members and their advocates to grave risks. In some cases, communities choose not to file complaints at all, not because there is no harm, but because the price of seeking justice and remedy is simply too high.

The Hidden Cost of Complaints

When a community files a complaint to an Independent Accountability Mechanism (IAM), it can initiate much-needed change by triggering investigations, policy shifts, halting of harmful projects, and, sometimes, remedy. But it can also open the affected communities to intimidation, harassment, and even violence especially against those who dared to speak up.

Forms of retaliation vary widely and can include constant surveillance and intimidation by police, project staff, or private security; verbal threats and public shaming; unjustified arrests and detentions; or being fired from work or denied access to critical government services. In more severe cases, retaliation escalates to criminal charges, legal harassment, gender-based violence, physical attacks, and orchestrated community divisions—often instigated by project beneficiaries or local authorities seeking to isolate or discredit complainants.

The retaliation isn’t just directed at the complainants themselves but also at the organizations or individuals who support them.

In our work in Uganda, community members affected by forced evictions in the Lubigi Drainage Channel (which is part of the World Bank–financed Kampala Institutional and Infrastructure Development Project (KIIDP-2)) filed a confidential complaint with the World Bank Accountability Mechanism. While the process formally offered confidentiality, complainants and their representatives were soon met with arrests, criminal charges, and sustained intimidation from police, project agents, and state authorities. Witness Radio, a local civil society organization that supported the community in preparing the complaint, was among 54 NGOs suspended in a government crackdown on CSOs.

Still in Uganda, members of the Paten Clan filed a confidential complaint with the African Development Bank’s Independent Recourse Mechanism (IRM) over forced displacement and exclusion from the Wadelai Irrigation Project under the Farm Income Enhancement and Forestry Conservation Project (FIEFOC-2). Following the complaint and advocacy, at least 16 community members were shot and wounded, others arrested and beaten, and civil servants among them were interdicted. In a further escalation, the local organization Buliisa Rural Initiative for Development (BIRUDO) which supported the complainants, was suspended by Ugandan authorities and accused of supporting the community to ‘sabotage government projects’.  These reprisals were linked to their organizing and engagement with the accountability process, and mark one of the clearest examples of retaliation within an AfDB grievance case.

In Cambodia, communities evicted under the World Bank-supported Land Management and Administration Project (LMAP) filed a confidential complaint with the Inspection Panel. Yet, according to reports by the Coalition for Human Rights in Development, community leaders faced harassment, surveillance, and pressure from authorities to withdraw their complaint despite supposed protections.

These examples expose a harsh reality: confidentiality alone is not a shield. Independent Accountability Mechanisms often lack the resources, mandate, or readiness to address the full spectrum of retaliation risks. As a result, the very act of seeking justice can endanger the people these systems are meant to protect and deterring others from coming forward and silencing voices that deserve to be heard.

IAMs Aren’t Built for High-Risk Contexts

Even as more IAMs adopt anti-retaliation statements/policies/approaches and offer confidentiality clauses, these measures are often reactive and symbolic. Risk assessments are conducted too late and in most cases, after retaliation has already begun. There are rarely staff dedicated to protection, no formal partnerships with national human rights institutions or protection organizations, and no budget lines to fund safety-related responses.

Worse still, IAMs often rely on the very governments or companies being challenged to “guarantee” the safety of complainants. This inherent conflict of interest undermines trust and can place communities in even greater danger.

A recurring frustration in many cases is the IAMs’ hesitation to issue timely statements of condemnation and solidarity with victims/ communities when retaliation is reported. Complainants who are threatened may wait weeks, sometimes months, for the IAM to “verify” the incident before action is taken. In that time, the damage is done or worse.

Risk Isn’t Equal

It’s also important to recognize that not everyone faces the same level or kind of risk. Women, LGBTQ+ individuals, Indigenous Peoples, persons with disabilities, and other marginalized groups are often more vulnerable to retaliation. The threats they face are not only physical but social and psychological exacerbated by intersecting systems of oppression.

Yet IAM processes rarely reflect these nuances. Risk assessments are generalized and not tailored to the specific vulnerabilities of complainants. There are no trauma-informed procedures or pathways to support survivors of gender-based violence. And in many mechanisms, there is still no meaningful engagement with marginalized groups in designing protective strategies.

Without intentional inclusion and safeguards for these groups, IAM processes risk replicating the very marginalization they aim to remedy.

What Needs to Change

To truly make IAMs accessible and just, retaliation must be addressed as a systemic barrier, not an incidental concern. This means:

• Proactive risk assessment – Conducting risk assessments before, during, and after the complaint process and not just after retaliation begins.
• Safe engagement channels – Offering safe, alternative ways to engage such as encrypted communication, offsite meetings, or working through trusted intermediaries.
• Formal partnerships – Partnering formally with protection actors, including national human rights institutions, legal aid groups, and UN bodies.
• Clear lines of responsibility for donors and banks to demand protective measures from clients and governments
• Establishing budget lines and staff roles dedicated to protection and security.
• Transparency and accountability – Holding clients accountable when retaliation occurs through public statements, corrective action plans, or suspension of project financing.

Communities should not have to choose between safety and accountability. If IAMs are to live up to their mandate of  providing remedy for harm they must embed security into their design. It’s not  just a matter of protection but one of legitimacy.