Omar Hamdy, lender side, Cairo. Written in a personal capacity.

Last checked 2 November 2026

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IFC vs EBRD exclusion list: a three-way reconciliation with your own policy

This template lines up IFC's exclusion list, EBRD's and your own policy, activity by activity, and scores where your policy is stricter, equal, narrower or silent. It turns "is this borrower excluded?" into one answer per funding source, with the wording that binds.

Who uses it: E&S officers and heads of sustainable finance who own the lender's exclusion list; credit policy teams; internal audit; and any bank or non-bank lender that on-lends DFI money through a credit line.

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On this page

1. Why one lender runs three lists
2. What the two public lists contain
3. Three findings from reading them line by line
4. The template: eight steps
5. Worked example (fictional)
6. Rules
7. Sources
8. Cite this page
9. Related pages
10. Glossary terms on this page

Send me what you received

Why one lender runs three lists

A lender that on-lends development finance holds three exclusion lists, and nobody chose to have three. Its own policy. IFC's, which IFC requires its financial intermediary clients to apply. And EBRD's, which an intermediary screens every sub-project against. The answer to "is this excluded?" depends on whose money is in the loan.

What the two public lists contain

Three findings from reading them line by line

Only 4 of 19 categories sit on both lists as applied to financial intermediaries. These counts are against EBRD's Annex A only, and against IFC's list with its add-ons for financial intermediaries, as it applies to IFC money mandated before 2026. Forced and child labour is one of the four only because of IFC's FI add-on; it is not on IFC's core list. Split both lists into activities a loan officer would recognise and you get 19 categories. Four are on both: illegal or banned goods, asbestos, drift net fishing, and forced or child labour. Six are IFC only (weapons, alcohol, tobacco, gambling, radioactive materials, logging and forest products). Nine are EBRD only or reach IFC only through guidance: forced evictions, fossil fuels, force-feeding of ducks and geese, fur, mercury, hazardous shipping, trade without licences, biodiversity and heritage prohibitions, and protected areas.

Annex A is not the whole EBRD screen. EBRD's June 2026 screening note tells an intermediary to also exclude projects related to tobacco, defence, certain alcoholic products and standalone gambling facilities. Add those Bank-wide exclusions and four of IFC's "IFC only" categories are covered by both funders. The wording still differs: IFC tests "substantial involvement", and EBRD's note says "related to" and "certain". Reconcile both layers, not just Annex A.

Shared items are not identical, and lists change. Drift nets: both use 2.5 km. Asbestos: IFC allows bonded cement sheeting with less than 20 per cent asbestos; EBRD's item has no such carve-out. Labour: IFC says "harmful" forced and child labour, EBRD says "child and forced labour". EBRD's 2019 policy also had 13 lettered items, but not the same 13: the 2024 text folds coal, oil exploration and oil development into one fossil fuel item and adds child and forced labour and the nature sites. A 2008 copy with six items still circulates online. IFC's list moves too: on 8 December 2025 IFC removed "production or trade in radioactive materials", and the amended list applies to transactions and engagements mandated after 31 December 2025. A lender with IFC lines mandated either side of that date runs two IFC versions at once, so the screening record must say which one it used.

The template: eight steps

1. Record versions. For each list, record title, date, URL and the date you retrieved it. Use the register below.
2. Split into atoms. One prohibited activity per row. Keep thresholds, carve-outs and "substantially involved" tests in a notes column.
3. Map atoms to categories. A category is an activity a loan officer recognises. Build the row set from the union of all lists, so nothing falls between them.
4. Fill the columns. IFC item, EBRD Annex A item, EBRD Bank-wide or GET item, your policy item. Note wording differences in each cell.
5. Score each row against the list that binds: Stricter, Matches, Narrower, Missing. Add rows for items only your policy has.
6. Bind by funding source. Each facility carries its funder. The binding wording is the strictest list among its funders. Count gaps per funder.
7. Decide each gap. Adopt the DFI wording for all lending, or keep a funder annex. Write every threshold down, with an owner.
8. Control changes. Re-run when any list changes. Every screening record names the list and its version.

Version register

Reconciliation grid (blank)

Worked example (fictional)

A fictional bank has a 12-item exclusion schedule, P1 to P12. It is stricter than IFC on weapons, alcohol and gambling, which carry no threshold in its policy. Elsewhere it is narrower: it bans only child labour, only illegal logging, only coal, and nets over 3 km.

Score is against the strictest list on the row, with IFC's list as it applies to money mandated before 2026. Totals: 3 Stricter, 1 Matches, 8 Narrower, 7 Missing, 1 Policy-only.

Scored against the list that binds each funder:

• On IFC money mandated before 2026: 4 of 11 categories met or exceeded, 6 narrower, 1 missing (radioactive materials). Asbestos counts as Stricter here, because IFC allows bonded sheeting.
• On IFC money mandated from 2026: radioactive materials is off IFC's list, so the policy meets 4 of 10, 6 narrower, none missing.
• On EBRD money, Annex A only: 1 of 13 met, 6 narrower, 6 missing.

One policy, two answers. Against the strictest list on each row, 15 of 19 categories are narrower or missing, and a DFI review finds those first.

Now add EBRD's Bank-wide layer. The policy's outright bans on weapons, alcohol and gambling also sit inside EBRD's tobacco, defence, alcohol and gambling exclusions. Tobacco is the row to check: the policy bans production only, and EBRD excludes projects "related to tobacco". A tobacco distributor passes the policy and may fail EBRD.

The "substantially involved" test, worked

IFC's threshold works at portfolio level, so it needs its own arithmetic. In a fictional portfolio, borrowers earning more than 20 per cent of revenue from alcohol (hotels, restaurants, retailers) carry 6.5 per cent of exposure. That is above 5 per cent, so the Guidance Note would generally call the lender substantially involved. At 4 per cent it would not.

The fictional schedule bans alcohol outright, so it never runs the test, and pays for that in lost hotel and restaurant lending. Either choice is defensible. An unwritten threshold is not.

Rules

1. A row is closed only when the policy wording and the list wording sit side by side.
2. A policy stricter than the list is a commercial decision. Record who made it.
3. "Substantially involved" needs a written number. The IFC footnote is the public starting point.
4. A facility without a recorded funder is screened against every list.
5. Annex A alone is not the EBRD screen. Add the Bank-wide exclusions and, for GET loans, the GET list.

Sources

1. IFC, Exclusion List (2007, amended 8 December 2025 to remove production or trade in radioactive materials, applied to transactions and engagements mandated after 31 December 2025; footnote on the page) ifc.org
2. IFC, Guidance Note on Financial Intermediaries, 29 September 2023 (para 7, para 34, footnotes 9 and 11) ifc.org
3. EBRD, Environmental and Social Policy, October 2024 (in effect 1 January 2025), Annex A ebrd.com
4. EBRD, ESR 9: Financial Intermediaries ebrd.com
5. EBRD, Environmental and social risk management briefing note: screening, June 2026 (Bank-wide and GET exclusions) ebrd.com
6. EBRD, Environmental and Social Policy, April 2019 (superseded; in effect 1 January 2020) ebrd.com
7. EBRD, Environmental and Social Exclusion and Referral Lists, 9 October 2008 (superseded) ebrdgeff.com

All views are my own, written in a personal capacity. They do not represent my employer or any other institution. This template explains published lists; it is not legal advice, and your facility documents prevail.

Cite this page

Related pages

• ESDD checklist for lenders
• ESMS for non-bank lenders
• ESMS for companies
• Grievance mechanism template for borrowers
• COP31 for lenders
• PCAF data quality score worksheet for SME loan books

Glossary terms on this page

• Exclusion list
• IFC
• EBRD
• DFI
• On-lending / sub-borrower
• Credit line / facility
• E&S due diligence

Condition Precedent ends every issue with a working tool like this one. The full piece behind this page is “The exclusion list you already have is three lists”.