Civil society engagement under the IMF’s CSO guidelines
•
Article summary
In October 2025, the International Monetary Fund launched its review of the Guidelines on the IMF Staff Engagement with Civil Society Organizations, following pressure from civil society organisations (CSOs), including in a joint letter in 2024 calling out a consistent lack of meaningful consultation. The review is taking place in parallel with other reviews on Conditionality, Surveillance (see Observer Summer 2025), and the low-income-country Debt Sustainability Framework (see Inside the Institutions, What is the World Bank & IMF debt sustainability framework for low-income countries?). It comes at a time of increased pressure on an already fractured multilateralism, with further pressure on the IMF from shareholders’ diverging interests (see Observer Winter 2024).
Against this backdrop, civil society engagement is not just a matter of transparency or inclusivity but is essential to improve IMF policy advice. Given the Fund’s decades-long promotion of fiscal austerity – often with significant social, political and distributional consequences – CSOs have raised the importance of active engagement between staff and a wide range of non-state actors (see Observer Spring 2023). CSOs, trade unions, professional associations and community groups can help identify when IMF policy advice risks constraining policy space, imposing disproportionate adjustment burdens, or exacerbating inequality and social fragility. Such policy advice is not only macroeconomically counterproductive and procyclical, but also socially costly triggering protests and political instability in what has been called the “IMF’s protest problem” (see Observer Winter 2024).
Guidelines on paper, gaps in practice
First approved in 2003 and amended in 2015, the Guidelines include directives on IMF engagement at the national, regional and global level, with particular emphasis on country missions, policy consultations and strategy papers. They detailed key principles such as engagement with CSOs before country missions, incorporating CSO input into mission design, as well as consultation with a wide range of actors and timely post mission follow-up. Guidelines on policy and strategy consultations also involved extensive engagement processes using surveys as well as webinars and conference calls to facilitate two-way discussions to enhance shared understanding and improve policy design.
In practice, however, the Guidelines are often not implemented and consistently fall short of best practice compared to other international financial institutions. A 2023 Oxfam report highlighted key shortcomings when it comes to CSO engagement, via case studies in six countries. The report found that in reality, engagement during country missions is ad hoc, opaque, overly technical and alienating to some CSOs. In addition, CSOs report being consulted after mission positions are set and often only informally – which limits influence and reinforces power imbalances. This perception is further influenced by the fact that the IMF is selective in who it consults, engaging with entities such as professional associations, chambers of commerce and financial institutions, which legally might fulfill the definition of a CSO but often represent private sector interests. Moreover, the impact of engagement is limited as CSOs often see little to no follow-up on their inputs or clarity on how their feedback was used.
More fundamentally, these shortcomings in engagement reflect deeper limitations in the substance of IMF policy advice itself. In particular, the continued reliance on narrow macroeconomic frameworks – insufficiently informed by heterodox approaches, human rights considerations, and distributional analysis – constrains the range of policy options considered and contributes to recommendations that are socially unbalanced and politically fragile, while limiting governments’ ability to pursue alternative policy paths. Recent country experiences illustrate how these dynamics play out in practice. In Kenya, proposed fiscal measures under the IMF-supported programme – including contentious tax increases – sparked widespread public opposition and were ultimately rolled back (see Observer Autumn 2024). “While IMF consultations in Kenya have shown slight improvement, CSO submissions continue to receive minimal feedback and rarely shape IMF policy positions,” notes Diana Gichengo, Executive Director of the Institute for Social Accountability in Kenya, highlighting the continued limitations of engagement and the exclusion of affected groups from shaping reform priorities. In Ecuador, the removal of long-standing diesel subsidies in 2025, implemented under a $4 billion IMF Extended Fund Facility, triggered nationwide protests led by Indigenous organisations in response to sharp increases in fuel prices and the distributional impact of the reform (see Observer Winter 2025).
Global CSO engagement on IMF policies and strategy papers reflects many of the same shortcomings observed at the country level. Current consultation processes fall short of the standards set out in the Guidelines. In particular, basic information on the timelines of policy processes is often not made publicly available; comment periods are not conducted in a systematic manner, nor are CSO submissions routinely published; and consultations are not anchored in substantive background materials prepared by staff (such as draft papers), limiting the ability of stakeholders to provide informed and meaningful input. Although the Guidelines emphasise transparency in the consultation process, including making inputs publicly accessible, to date, comments submitted through the online consultation platform have not been published. Similarly, despite the Conditionality Review being included in the 2025 Executive Board Workplan, no related consultation process, timeline or terms of reference has been made public yet to date.
Towards more effective engagement
This selective implementation of the Guidelines continues despite evidence within the Fund’s own reviews and guidance that meaningful engagement can improve the quality and relevance of IMF policy advice. The 2022 Guidance Note for Surveillance under Article IV Consultations encouraged staff to maintain continuous dialogue with a wide range of stakeholders, including CSOs, noting that such engagement enriches staff understanding of country circumstances, stimulates policy debate, and can usefully be reflected in staff reports. Similarly, the 2025 Management Implementation Plan response to the Independent Evaluation Office’s Mandate Evaluation recognised the growing need for collaboration with external partners, including CSOs, as the Fund’s work expands into macro-critical areas such as climate and gender. Together, these documents reflect an institutional understanding that broader stakeholder engagement enhances the relevance, legitimacy and traction of IMF policy advice – an understanding that has yet to be consistently translated into practice.
Building on these gaps, in a letter published in March and signed by 125 CSOs, civil society proposed a focused set of practical reforms to operationalise the Guidelines in day-to-day IMF practice. These include mandatory structured outreach to diverse CSOs before missions, supported by published stakeholder maps and mission team contact details; systematically including CSO perspectives in official reports, Article IVs and reviews of strategies and policy papers; and developing a simple CSO feedback tracker for each mission to record commitments made to CSOs and follow up on how these were addressed. The letter further proposes that, at the regional and global level, annual regional dialogues should be planned and clearly linked to IMF work cycles. For global consultations, the IMF should publish clear consultation timelines, terms of reference and relevant policy drafts, alongside accessible points of contact and areas of staff expertise, to democratise access and improve engagement with CSOs. Together, these steps would help ensure that IMF engagement with civil society is timely, transparent, inclusive, applied consistently and supported by clear feedback loops.
