"The Centre for Law and Democracy (CLD) and the Bank Information Center (BIC) have jointly prepared Comments on the Public Information Interim Policy of the Asian Infrastructure Investment Bank (AIIB)...The analysis shows that the AIIB is lagging behind other international financial institutions (IFIs) when it comes to information disclosure...

Some of the key problems...are:

• The scope of proactive publication commitments lags far behind better practice IFIs.
• The regime of exceptions is vastly overbroad, including many open-ended exceptions, lacking harm tests in many cases and failing to provide for any public interest override.
• The failure of the AIIB to adopt guidelines on implementation means that the Interim Policy lacks almost any procedural rules governing the processing of requests.
• Unlike many IFIs, there is no provision for an appeal to an independent oversight body.
• As a matter of practice, the AIIB has on at least some occasions failed to process requests for information.

While we welcome the AIIB’s decision to adopt a public information policy at such an early stage in its development, in many areas the Interim Policy fails to meet the minimum information disclosure standards established by international law and the practice of other international financial institutions (IFIs). As a result, there is a clear need for fundamental revision of the rules regarding the disclosure of information at the AIIB...This need is particularly urgent since the AIIB has now begun to finance projects..."

"In fall 2016, civil society organisations...had the opportunity to comment on the AIIB’s Energy Sector Strategy...Civil society submissions emphasized the importance of supporting Asian countries to transform their energy sectors in line with the Paris Climate Agreement and the Sustainable Development Goals (SDGs)...[and] highlighted the importance of adopting a binding operational policy on energy..."