By Rabi Thapa

When Margaux Day became executive director of Accountability Counsel in 2024, she spoke to Accountability Matters about her plans for the advocacy nonprofit. She identified as a key research initiative the development of “a website that explains the accountability process of each mechanism, designed for communities who are thinking about filing complaints.” 

Since late 2025, that online resource—the Accountability Toolkit—has been live. Described by Day as a “community-friendly resource that assists communities … to navigate the complaints process,” it’s a “site” for sore eyes.

Over two dozen independent accountability mechanisms (IAMs) are in existence today, but stakeholders have long lacked access to a single platform that brings together information on exactly what the different IAMs do and how to approach them with a complaint about alleged harm from development projects. Even if potential complainants know which IAM to approach (a big If), they may find that submitting a complaint is a complex undertaking that, more often than not, does not obtain the desired results.

A common refrain among IAMs is that it is not enough to have been legislated into existence as a channel for complaints. William Romans, Head of Operations at the Dispute Resolution Service of the World Bank, says, “The different accountability processes can be complex and probably a bit stressful for communities to find their way through. One of the main challenges for project-impacted communities is knowing the options in the first place.”

Accountability Counsel’s data attests to this reality: just 30% of complaints filed make it to one of the substantive stages of compliance review or dispute resolution, with 42.6% rejected almost immediately after being filed. This suggests that complainants struggle to comprehend what makes for an eligible complaint.

Sharing the wealth, sharing the load

The other rationale for the Accountability Toolkit is the increase in queries fielded by Accountability Counsel. Day explains: “We’re receiving requests from either directly impacted communities or their local advocates now, on average, twice a week—an overwhelming demand. Over the years it’s gotten us to thinking that what we really need to do is to democratize and make our expertise accessible. We shouldn’t be holding it close, and have this rarefied understanding of how to navigate these channels. It should be as accessible as possible.”

Improved access goes hand-in-hand with civil society support. Day offers a startling insight: “Only 15% of cases have verified civil society support,” but “they’re three times as likely to be found eligible, and twice as likely to result in a remedial action.” Romans adds, “Civil society continues to be the best resource for complainants.”

Indeed, the Toolkit may be much less targeted toward the majority of complainants who do not have official civil society support than civil society peers. Day says: “Advocates focused on a specific place, community, or issue could have this information instead of having to start from scratch. It could be a primer or tool to add to the rest of their advocacy.”

What’s up at the One-Stop Shop

The Accountability Toolkit incorporates the database Accountability Console (launched in 2019) as the Complaints Dashboard, which now includes over 2,400 complaints from 29 accountability mechanisms. Serge Selwan, Senior Policy Advisor at the World Bank’s Inspection Panel, says, “The Accountability Toolkit acts as a repository of cases across IAMs and provides important comparative analytical data. Over the past years, by providing a bird’s-eye view and also the granular information on remedy resulting from IAM processes, the toolkit has been instrumental in shaping the remedy discourse and remains an essential tool to measure IAMs’ effectiveness.”

Day runs through the other products on offer, beginning with the Complaint Pathfinder, akin to a map through the maze of the accountability world: “What even is an accountability mechanism? What does it feel like to go through it? What do you have to think about? That’s the primer piece of the Toolkit.”

For those who feel ready to begin filling in requests, the Complaint Builder provides value-added templates. Day explains: “Many of the accountability mechanisms will have a template. What we wanted to do was to create a version of those templates that’s informed by our collective advocacy expertise. Technically, you might only need to say 1-2-3, but if you also add 4-5-6, it’s more likely to have a positive outcome.”

The Toolkit also features a Research Library that links to Accountability Counsel’s publications, and a Policy Comparison Tool that provides caseload overviews by IAM. Both are useful to researchers seeking to understand the sector. But for complainants and their civil society representatives, the AC Helpdesk is a direct channel to Accountability Counsel’s team. Supplementing the informal system of referrals that brings cases to their attention, the Helpdesk provides a standardized link for those needing bespoke support. This also has the advantage of helping systematize requests for assistance, and answer the question: “What are communities on the frontlines of these projects telling us?”

Tr[AI]ning tools for accountability

The extent to which artificial intelligence (AI) can or even should be used to process complaints from communities has been a talking point in recent years. With the Toolkit at a learning, iterative stage, the prospect of a dynamic Complaint Builder that, according to the website, “will generate customized complaint letters based on the details of your case,” is intriguing. Day is aware of the need to tread carefully: “What we would like to build out is a complaint advisor that’s AI enabled, trained on a limited set of information”—namely, verified case details from across the sector. “We have a prototype of a chatbot function that responds to a series of prompts and can then technically, at least,  produce an eligible draft complaint.” This could be used as the basis for seeking further advice.

Accountability Counsel’s wariness about using AI to process such sensitive information as may be shared by vulnerable complainants is warranted, and reflected in the reluctance of IAMs to (so far) venture much beyond AI for workflow productivity. Romans says, “AI agents are playing an increasingly central role, and we are thinking hard about the opportunities and risks that this presents.”

However, recognizing that the public at large is already using potentially unsafe AI tools, Day says that Accountability Counsel has taken a strategic decision to develop more ethical and energy-efficient alternatives.   

Filling the gaps

Accountability Counsel invested substantial resources in developing the Toolkit, but also consulted with civil society and IAMs to ensure accuracy, and to avoid its presentation as a proprietary product. Day is emphatic in stating that they view the Toolkit as a resource to be shared widely for the benefit of communities, alongside the IAMs’ own resources and that of other advocates. “Ideally, people will go to an accountability mechanism site, and there will be a part with various tools that asks: Do you need support? Here’s some places that you could go.

For now, Accountability Counsel is reaching out to fellow advocates to both familiarize them with the Toolkit and discuss ways in which gaps can be filled across the human rights and accountability sector. Through recent webinars with OECD Watch and BankTrack, for instance, Accountability Counsel is building coalitions of knowledge around improving accessibility to complaint channels, with each organization bringing specific experience to the table. The well-attended webinars offered civil society advocates the opportunity to learn not only about the Toolkit, but also BankTrack’s new Users’ Guide to commercial bank human rights complaint channels, and OECD Watch’s Complaints Guide  and National Contact Point Evaluations.

“We can’t all know everything,” Day says. “But we shouldn’t have to reinvent the wheel. And so where can we kind of get that shared knowledge? If people see that investor accountability might be a strong strategy for them to protect people and the planet, we want to have a variety of support available to them.”

Selwan, the Inspection Panel, affirms the utility of the Toolkit: “From a practitioner’s perspective, I found it to be a unique tool for interested parties—practitioners and communities alike—to learn about accountability and accountability mechanisms. It maps out the accountability mechanisms of various development institutions and provides valuable knowledge for potential complainants about options and the process related to each option.”

The Dispute Resolution Service’s Romans concludes, “I welcome the new resources from Accountability Counsel. They make a real difference. As the World Bank Group accountability architecture evolves, we have a chance to improve how we connect and help those who need us, and we’re also learning from the innovative approaches that Accountability Counsel and others are bringing."