WHAT HAPPENED AT THE SEVENTH MEETING OF THE BOARD OF THE FUND FOR RESPONDING TO LOSS AND DAMAGE: A RAPID REACTION

The seventh meeting of the Board (B6) of the Fund for Responding to Loss and Damage (FRLD) took place from 7 to 9 of October, 2025 in Manila, in the Republic of the Philippines. Key agenda items included the Operationalisation of the Barbados Implementation Modalities (BIM) and the long term resource mobilization strategy for the FRLD. 

The start-up phase of the FRLD

B7 concluded with the operationalisation of the Barbados Implementation Modalities (BIM) — the start-up phase of the Fund.

Four key decisions were taken to make the operationalisation of the BIM possible:

1. The adoption of a funding criteria for the BIM — to guide the Secretariat of the FRLD in their assessment of funding proposals.
2. The adoption of a funding cycle for the BIM — to guide the Secretariat of the FRLD in the management of funding proposals.
3. A decision on access modalities — which has determined how developing countries will receive money from the FRLD.
4. The adoption of a list of implementing entities that are accredited to the Green Climate Fund (GCF), Global Environment Facility (GEF) and Adaptation Fund (AF) based on the modalities agreed under the decision on access — these implementing entities will be eligible to implement projects and programs for countries and enable direct budget support*.  

*If this can be enabled, see further explanations later in the text.

Following the adoption of these key decisions, the Secretariat of the FRLD will work to develop the guide book, terms of reference and template for the call for proposals for the BIM. This call will be launched at COP 30 with a window of just a few months for developing countries to make proposals. A number of developing country Board members called for the Board to approve these documents ahead of the launch of the call for proposals, however, this would have deleted the COP 30 launch and therefore the delivery of the BIM. Therefore, the Board will provide comments only. 

Whilst it is good news that the FRLD has operationalised, the BIM and will likely be selecting proposals to support projects on the ground within the next six months, and in doing so, provide valuable learning to guide the development of the Funds long term policies, the BIM fails short in a number of ways.  

The principal concern of many developing countries, including the Least Developed Countries (LDCs), and civil society is that the BIM replicates the traditional model of other climate funds such as the GCF.  These concerns center upon the BIM having a funding cycle that sees project proposals approved within months and not days against a funding criteria that may prove a barrier to access to many developing countries. The LDCs in particular made clear calls for the BIM to demonstrate rapid disbursement via a dedicated funding cycle. Whilst civil society called for the BIM to demonstrate small grants in spite of the BIM not being mandated to facilitate direct access to communities. Yet the decisions taken do not reflect these priorities and it will remain to be seen if enough LDCs and Small Island Developing States (SIDS) can access the FRLD to meet the 50% minimum allocation set for them in the BIM decision taken at B5. 

On access modalities, the nine page decision, is a complicated work around that reflects that access will neither be simplified nor direct having failed to cut out the traditional middle men that developing countries had hoped the Fund would by pass. With it still to be determined if the BIM will be able to offer direct access via direct budget support, a key ask by developing countries, the call for proposals will contain a caveat that any proposals seeking funding through this modality may not be able to be fulfilled. This may prove to be off putting for many developing countries seeking direct access via direct budget support, who may feel the capacity and resources required to develop a funding proposal could be wasted if the FRLD can not offer that access modality after all.         

The resource mobilisation strategy

A key agenda item for B7, one that was mandated for completion in 2025, was the long term resource mobilisation strategy for the FRLD. This highly political agenda item shows a huge divergence between developing countries, who sought to fill the fund to the scale of their needs, and developed countries, who wished to expand sources to diminish their responsibility for filling the fund. With developed countries pushing for capital markets, the private sector and expansion of the contributor base and the use of loans, only a procedural decision could be taken to request a draft resource mobilisation strategy to be prepared for B9 by the FRLD’s Secretariat. 

The failure to deliver a resource mobilisation strategy risks the Fund running out of money in 2027 and seriously limits the possibility of allocating further money to the BIM at B8 — an opportunity afforded by the decision establishing the BIM.

To date only 768.40 million USD has been pledged to the FRLD by 27 contributors. Of this, contribution agreements are in place for 560.98 million USD and only 399.89 million USD has been paid into the trust fund. This means that once the 250 million USD allocated to the BIM has been spent only 149.89 million USD will remain.

When we look at the status of resources document for B7 indicates that the following contributors still have not turned their pledges into contributions:

• Italy (has not started their contribution agreement for 100 million Euros);
  
  
• Luxembourg (has not started their contribution agreement for 8 million Euros); and;
  
  
• The EU (has only drafted their contribution agreement for 25 million Euros).

At the start of B7, civil society called the Board’s attention to the implications of the delivery of the Advisory Opinion (AO) on the obligations of states in regard to climate change but the International Court of Justice (ICJ). Making clear that the ICJ AO clarifies the obligations of developed countries to cooperate, including through the provision of finance to address loss and damage, inline with their common but differentiated responsibilities and respective capacities (CBDR-RC). And that the failure to cooperate would lead to developed countries being liable to provide remedy for climate harm. This obligation to cooperate was evoked in a statement provided to the Fill the Fund campaign by Board member Amb.  Henrietta Elizabeth Thompson of Barbados.  

The ICJ AO was also evoked in regards to the funding cycle and criteria for the BIM by Elisa Morgera the Special Rapetour on Human Rights and Climate Change, who prepared a special statement with clear guidance for Board members on the relevance of the ICJ AO to the funding criteria for the BIM, call for proposals and results management framework for the start-up phase.

The looming presence of the World Bank

Throughout B7, the spectre of the Word Bank loomed large as it became increasingly clear that World Bank policies and processes are killing the potential for the FRLD to be an innovative and different Fund. Both civil society and developing countries fought hard for the Bank not to host the FRLD through the Transitional Committee (TC) process for a large number of reasons including burdensome bureaucracy, high fees and issues related to access.

Following a compromise at TC 5 the Bank was selected as the interim host for the FRLD, with a set of conditions placed on the Bank under paragraph 20 of the decision operationalising  the Fund at COP 28 in Dubai. Yet as we approach the mandated review of the suitability of the World Bank to become the permanent host of the FRLD it is increasingly clear that the fears raised during the TC process are well founded. With the BIM decision on access modalities and the high fees projected in the 2026 budget for the FRLD Secretariat clear warning signs of what is to come if the Bank remains the host of the FRLD. 

The long term policies of the FRLD

Throughout B7 there were clear calls from developing countries to make concrete plans to develop the longer term operating modalities of the FRLD. This included a particular focus on ensuring that the Fund can enable rapid disbursements. Civil society also made a consistent demand for the FRLD to develop modalities for direct access for communities and sub-national actors including local governments and cities. These calls reflect the concern that the BIM may prove to be a procrastination exercise that will delay the long term policies of the Fund by curtailing the Secretariat's ability to deliver on the development  of the longer term modalities in parallel.  This is critical that the Board sequence work on the long term policies alongside the BIM. This sequencing must also enable the learning from the  BIM to inform the long term policies. 

The end of an era

As much as it is the start of the BIM, in many ways B7 also marks the end of an era with a large number of Board members rotating out of their seats and new Co-Chairs to be elected for 2025. The terms of the current Co-Chairs, Richard Sherman, South Africa and  Jean-Christophe Donnellier of France end on the 31st of December 2025. Yet the Board was not able to elect new Co-Chairs due to pounding nominations. As a result the current Chairs will continue to serve the Board until new Co-Chairs are elected. A decision that must not take place intentionally without a Board meeting. Richard Sherman has indicated that he will join the Board once he has stepped down as Co-Chair, but Jean-Christophe Donnellier will retire from the Board.  In their closing remarks both commended and thanked all those who had contributed to the operationalisation of the FRLD. Both Jean-Christophe Donnellier and Board member Mohammed Nasr of Egypt drew particular attention to the efforts of Richard Sherman, as Co-Chair of the Board and the Transitional Committee and resultant impact that this has had on his health.  

Further reading

Find our detailed policy updates for B7 here.

See all of the documents released before and during B7 here. Note that many of the final decision texts have not yet been released and we will need to wait until the compendium of decisions is released to see the final text. 

Re-watch the webcasts for B7 here. 

Following the close of B7, Fill The Fund held a press conference, find the recording here. Find out more about the campaign here.

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