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Friday, April 17, 2026

Open Letter to the IMF on the IEO


Open Letter  ·  Spring Meetings 2026  ·  Day 2  ·  April 14, 2026

An Open Letter to the Managing Director of the International Monetary Fund on the Independence and Mandate of the Independent Evaluation Office

On 81 Years Without a Project Rating System, a Structurally Disempowered Evaluation Office, and What Genuine Accountability Would Require

Dear Managing Director Georgieva,

Yesterday’s letter asked five questions about the $3.4 billion Nigeria COVID emergency disbursement and the conviction of the Accountant General. This letter concerns the institutional architecture that made that outcome possible — and that makes it likely to recur.

The IMF has been lending to sovereign governments for 81 years. It operates programmes in 149 countries. It has never — not once — produced a project-level rating of whether those programmes delivered their stated objectives. The World Bank rates every completed project. The African Development Bank rates every completed project. The Asian Development Bank rates every completed project and publishes the gap between management ratings and independent evaluator ratings. The IMF does none of this.

The Independent Evaluation Office was established in 2001 to provide independent assessment of IMF policies and activities. In 25 years it has produced valuable thematic work — on programme design, on surveillance, on the pandemic response. But the IEO does not rate individual country programmes. It cannot tell you whether the programme in Nigeria in 2020 worked. It cannot tell you whether the programme in Ghana in 2023 worked. It produces thematic reports rather than programme-level accountability for individual country outcomes.

This is not an accident. It is a design choice. And the design choice has consequences that the Nigeria COVID case makes concrete.


The IEO’s structural constraints are worth stating plainly. The IEO Director is appointed by and reports to the Executive Board — not to an independent oversight body. The IEO budget is determined by management. The IEO has no power to compel the disclosure of documents. Its recommendations are advisory. Management’s response to IEO findings is published alongside those findings — which means the institution being evaluated has equal editorial space to contest the evaluation in the same document. When the IEO’s 2023 evaluation of the IMF’s COVID emergency response found that the governance framework was “a checklist,” management’s response was published in the same report. The finding stands. The structural mechanism for translating that finding into institutional change is not clearly defined.

Compare this to the World Bank’s Independent Evaluation Group, which reports to the Board rather than management, has its own budget allocation protected by Board resolution, and produces project-level ratings that are published regardless of whether management agrees with them. The IEG is imperfect — this platform has documented its imperfections at length — but it is structurally more independent than the IEO. The Asian Development Bank’s Independent Evaluation Department goes further still: it validates 100 percent of management’s project completion reports and publishes the gap between management ratings and IED ratings, by name, by project, by year. That gap is currently 12 percentage points. It is published. It is not resolved. But it is visible.

At the IMF, the gap is not published. It is not measured. There is no mechanism to measure it, because there are no project ratings to compare against.



This letter asks five questions about the IEO’s mandate and independence. They are addressed to you because you are the Managing Director and because the IEO’s structural position — reporting to the Board but funded and operationally constrained by management — means that meaningful reform requires your office’s active support.

Question 1 The IEO was established in 2001 with a mandate to conduct independent evaluation of IMF policies and activities. In 25 years it has never produced a project-level rating of an individual country programme. Is this a deliberate policy position of the institution — that individual programme ratings are not within the IEO’s mandate — or is it a resource and capacity constraint? If the former, what is the institutional rationale for exempting individual programmes from independent rating when every comparable multilateral development bank rates individual operations?
Question 2 The IEO’s 2023 evaluation of the COVID emergency response described the governance framework as a checklist. Management’s response was published in the same document. What specific changes to programme governance design were made following that finding? Please provide the implementation record for any governance reforms adopted between the IEO’s COVID evaluation and the current Spring Meetings.
Question 3 The IEO Director is appointed by the Executive Board. The IEO budget is determined through the management budget process. IEO recommendations are advisory and carry no binding force. In what sense is the IEO structurally independent of the institution it evaluates? What specific governance reforms would be required to give the IEO the same degree of operational independence as the World Bank’s IEG or the Asian Development Bank’s IED?
Question 4 WP/25/75 documented near-universal budget losses in COVID emergency spending across 50 countries. The paper was produced by the IMF’s Legal Department, not the IEO. Why was this analysis not produced by the IEO? Does the division of responsibility between the Legal Department and the IEO create gaps in the institution’s accountability architecture — specifically, gaps in which neither function produces a named, country-specific assessment of programme outcomes?
Question 5 The IMF is this week discussing a further $20–50 billion in emergency financing demand. Before that financing is approved, will the IMF commit to: (a) an independent project-level rating of the 2020 COVID emergency programmes in the ten largest recipient countries; (b) a published assessment of what proportion of those disbursements reached their stated purposes; and (c) a reform of the IEO’s mandate to include individual programme ratings with a defined implementation timeline? If none of these commitments is currently planned, what alternative assurance can the institution provide that the governance weaknesses documented in WP/25/75 will not recur in future emergency deployments?

The IMF asks sovereign governments to accept conditionality, to publish their fiscal data, to submit to Article IV surveillance, and to reform their institutions as a condition of access to Fund resources. The standard the IMF applies to its borrowers — transparency, accountability, measurable outcomes — is precisely the standard the institution should apply to itself. The absence of project ratings is not a technical gap. It is an accountability gap that protects the institution from the consequences of its own decisions while those consequences fall entirely on the countries that borrowed the money.

The Spring Meetings are the right place to commit to changing this. The shareholders are in the room. The question is whether the will exists.

Respectfully,

Parminder Brar

Founder, mdbreform.com

Former World Bank Country Manager and Lead Governance Specialist

April 14, 2026


The full IMF analysis series — ratings, governance, COVID, mandate duplication, and the structural accountability gap: Kofi and the Six Ships

Yesterday’s letter on the Nigeria $3.4bn COVID disbursement: Open Letter to the IMF Managing Director — Day 1

The seven questions for the Spring Meetings: Spring Meetings 2026 Brief

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