"Billions Beyond Control: AIIB's Disclosure Deficit", Urgewald, September 2026

Executive Summary

This report combines two assessments of the Asian Infrastructure Investment Bank’s (AIIB) transparency performance. The first draws on the 2025 DFI Transparency Index by Publish What You Fund (PWYF), which compares AIIB’s transparency policies with those of other multilateral development banks (MDBs). The second is based on findings from the AIIB Watch, a civil society initiative monitoring environmental and human rights risks in AIIB-financed infrastructure projects. Rivers without Boundaries International Coalition (RwB) contributed the chapter on the Nature Finance Accelerator Program. We would like to thank Recourse for their comments on parts of the report as well as AIIB staff for answering pertinent questions.

Key findings:

Part I: AIIB in the 2025 DFI Transparency Index

• AIIB’s non-sovereign portfolio scored 37.1 out of 100, performing worse than the majority of MDBs. Its sovereign portfolio scored 58.5 out of 100, placing fifth among the ten MDBs assessed.
• AIIB is the only MDB without a published impact management methodology and the only institution that routinely relies on the environmental and social policies of co-financiers and clients rather than consistently applying its own standards.
• AIIB does not disclose indirect investments (sub-investments) made through financial intermediaries, in contrast to several other MDBs that provide such key information.

Part II: Transparency in Practice

• Disclosure on resettlement and land acquisition: The precise number of people affected by resettlement is frequently not disclosed. When data is available, documentation is inconsistent, varies widely in quality, and contains contradictory information about resettlement impacts. Key environmental and social documents are repeatedly published after project approval. Prior to approval, documentation often does not include a full risk assessment based on field visits.
• Financial intermediary projects: Information on end use of the funds and subprojects remains largely unavailable. Several AIIB FI projects support institutions with substantial exposure to fossil fuel infrastructure subprojects with major human rights concerns.
• Financing fossil fuels: AIIB continues to finance fossil fuel projects. Projects that appear to be clean energy finance, such as the proposed China Inner Mongolia Clean Energy Transition Project, are in reality financing fossil fuel infrastructure – in this case, a coal project.
• Speed of project approval timelines: The Environmental and Social Framework allows management to shorten disclosure periods without public accountability. Some projects were disclosed for periods shorter than the minimum requirements, without formal justification.
• Climate Policy-Based Financing (CPBF): Because CPBF is provided as budget support, the final use of funds is difficult to track, yet AIIB classifies 100% of CPBF disbursements as climate finance. This creates a risk of overstating climate impacts and weakens accountability for environmental and social outcomes.
• Nature Finance Accelerator Program: AIIB’s first foray into “nature finance” is based on non-transparent FI arrangements with no mandatory disclosure of policies, procedures, or subprojects. A number of arrangements and indicators preclude the AIIB from monitoring measurable positive outcomes for biodiversity. As an example, 20% of the loan to the Bank of Jiangsu targets climate-related cross-border investments, but the link to the project’s “nature positive” objectives remain unclear.