Why Climate Finance Integrity Is Not Just Anti-Corruption

Imagine an adaptation program designed to help smallholder farmers cope with increasing drought.

There is no bribery. No resources are diverted. No contractor colludes with a public official. No invoice is falsified. No conflict of interest is concealed.

By conventional anti-corruption measures, there may be nothing to investigate.

But suppose the program was designed without meaningful consultation with the farmers it intended to support. Suppose the technology selected works well under controlled conditions but is too expensive to maintain locally. Suppose women perform most of the agricultural work in the target communities but were barely represented in the consultations. Suppose the project counts the number of farmers trained but never establishes whether those farmers subsequently became more resilient to drought.

Nothing in that scenario necessarily constitutes corruption.

Something is still wrong.

That space between the absence of corruption and the presence of a system worthy of confidence is where the broader idea of climate finance integrity becomes important.

Anti-corruption answers an essential question

Anti-corruption frameworks perform indispensable work. They seek to prevent and address the abuse of entrusted power for private gain: bribery, fraud, embezzlement, collusion, favoritism, coercion, and other forms of misconduct. Climate finance needs these controls. Resources should not be diverted. Procurement should not be manipulated. Contractors should not falsify delivery.

The argument for a broader conception of integrity is therefore not an argument against anti-corruption. It begins from the opposite premise.

Anti-corruption is necessary. It is simply not sufficient.

What happens when nobody is corrupt?

Consider how many ways a climate project can lose legitimacy or effectiveness without anyone committing a corrupt act.

A project can be designed using poor data. A consultation can comply with formal requirements while excluding people unable to attend. A technically sound intervention can be inappropriate for the local context. A procurement process can be lawful but produce poor value. An implementing entity can report outputs accurately while measuring the wrong things. A project can reach thousands of people while systematically missing those most vulnerable to the climate risk it was created to address. A monitoring system can collect large volumes of information without generating reliable evidence of impact.

None of these weaknesses requires a bribe. Yet each affects whether climate finance decisions and reported results should command confidence.

This is why integrity cannot be reduced to misconduct. Sometimes the problem is not that somebody cheated the system. Sometimes the problem is the system itself.

The evidence already points beyond corruption

A 2024 synthesis by the Adaptation Fund's Technical Evaluation Reference Group examined final evaluations across a portfolio of Fund-financed adaptation projects. Its recurring findings were not principally about bribery or embezzlement.

Evaluators identified weaknesses such as insufficient monitoring and evaluation capacity, inadequate provision for longer-term monitoring, lack of beneficiary participation, and insufficient attention to gender and youth in project planning and implementation.

The synthesis drew an important lesson from those evaluations: understanding local context and stakeholder needs is fundamental to effective project design. It also concluded that failure to address inclusion can undermine a project's ability to produce genuine improvements in adaptive capacity and resilience.

These are integrity questions. Not because the projects were necessarily corrupt. Because the quality of climate finance depends on more than whether resources were stolen. It depends on whether the right communities were heard, whether the intervention responded to actual vulnerability, whether institutions could verify what changed, and whether reported results reflected durable outcomes rather than completed activities.

A project does not need a corruption scandal to have an integrity problem.

Integrity is about the quality of the whole chain

Climate finance travels through a chain of decisions. A need is identified. A project is designed. Finance is allocated. Partners are selected. Contracts are awarded. Activities are implemented. Beneficiaries are identified. Results are measured. Claims are verified. Lessons are reported.

Anti-corruption controls protect important points along that chain. Integrity asks whether the chain as a whole works as it should.

Was the project based on credible evidence? Were relevant interests and conflicts disclosed? Were affected communities able to participate meaningfully? Were decisions transparent enough to be understood and challenged? Was implementation supervised independently enough to detect problems? Were complaints accessible and safe? Were climate results measured using credible assumptions and appropriate indicators? Were institutions willing to correct course when evidence contradicted the original design?

These questions do not all belong to the traditional domain of anti-corruption. Together, however, they determine whether the systems carrying climate finance are capable of protecting the purpose they were built to serve.

Compliance is not the same as integrity

This distinction also helps explain why formal compliance can sometimes provide false reassurance. A consultation may have taken place. A tender may have been advertised. A monitoring report may have been submitted. A grievance mechanism may exist.

Each requirement can be satisfied procedurally. The harder question is whether it functioned substantively. Did the consultation influence the project? Was competition meaningful? Could communities actually use the grievance mechanism? Did monitoring reveal whether vulnerability had changed?

Integrity therefore asks more of institutions than whether the correct box was checked. It asks whether the underlying purpose of the requirement was achieved. That is a more demanding standard. It is also the standard that climate finance increasingly needs.

A wider lens does not mean an unlimited one

There is a risk in making integrity so broad that it comes to mean everything good about a project. That would make the concept useless. Not every technical failure is an integrity failure. Not every delay is an integrity failure. Not every disagreement about project design is an integrity failure.

The integrity question arises where weaknesses in governance, decision-making, transparency, accountability, inclusion, evidence, or oversight materially affect the credibility of how climate finance is allocated, delivered, or reported. That boundary matters.

Climate finance integrity should sharpen institutional judgment, not replace it with a vague demand for perfection. Its purpose is to connect concerns that are too often treated separately: corruption risk, conflicts of interest, transparency, accountability, beneficiary inclusion, credibility of data, quality of verification, and accessibility of complaints.

Each may sit in a different policy, department, safeguard, or assurance process. But those relying on the final claim that a project has delivered climate impact ultimately confront a single question:

Can I have confidence in this?

From preventing wrongdoing to creating confidence

Anti-corruption begins with an important concern: what must we prevent people from doing improperly? Climate finance integrity adds another: what must the system do well enough for its decisions and results to merit confidence?

The questions overlap, but they are not interchangeable. The first protects climate finance from abuse. The second asks whether the architecture through which climate finance operates is credible enough to deliver on its purpose.

Both matter. A project can lose public resources through corruption. It can also lose climate impact through poor governance, exclusion, weak evidence, or inadequate accountability.

If we look only for misconduct, we will miss some of the most consequential weaknesses in the system.

The absence of corruption is not the end point of climate finance integrity. It is the starting point.

References

AF-TERG (2024). Second Synthesis of Adaptation Fund Final Evaluations.