The World Bank’s Board of Executive Directors (the “Board”) on December 18, 2025 approved a recommendation by the Inspection Panel not to investigate the Serbia: Public Sector Efficiency and Green Recovery DPL (the “Program”). 

The Panel received a Request on March 31, 2024, submitted by two representatives of A11 Initiative for Economic and Social Rights, a non-governmental organization located in Belgrade, Serbia. They are representing six individuals living in Serbia, some of them belong to the Roma Community (the “Requesters”). The Requesters asked to include Amnesty International as their advisor in the Panel’s process. 

The Request alleged that there were four negative impacts resulting from one of the Program’s Prior Actions: the establishment of a Social Card Registry for the consolidation of data on social protection beneficiaries, created to improve social protection policymaking and targeting. These alleged four impacts comprised: (1) alleged loss of benefits resulting from erroneous exclusions; (2) alleged lack of transparency and consultation; (3) alleged inaccessibility and delays in the appeals process; and (4) alleged disregard for the international human rights approach to data management.

The Panel registered the Request on August 27, 2024. One month later (September 27, 2024), World Bank Management (“Management”) submitted its Response to the issues raised in the Request. On November 12, 2024, the Panel submitted its Report and Recommendation, in which it recommended an investigation as to whether the World Bank had conducted sufficient due diligence to assess whether the establishment of the Social Card Registry could have a significant social impact arising from two of the four allegations raised: the loss of benefits as a result of erroneous exclusions and inaccessibility of, and delays in the appeals process. 

On May 28, 2025, Management submitted an Addendum to its initial Management Response, describing specific actions that it would take in order to address the two allegations raised. On October 17, 2025, the Panel submitted a Statement from the Chairperson, revising its earlier recommendation and deferring its final decision on whether to recommend an investigation for nine months or until the Panel received a progress report from Management regarding the completion of proposed actions. 

On December 4, 2025, Management submitted a detailed progress report, including information on actions it had taken. These have included convening workshops with civil society organizations (with a majority representing Roma people) on the lessons learned from the implementation of the Social Card Registry; supporting training activities for officials who oversee social protection workers managing the Social Card Registry in the Centers for Social Work; and providing analytical work on social assistance in Serbia. Additionally, Management provided information on the  mandatory training on environmental and social due diligence that World Bank staff working on Development Policy Financing are required to undertake.

The Panel considered the actions taken by Management and after doing so, revised its earlier recommendations on the Program to the effect of no longer recommending an investigation. On December 18, 2025, the Board approved the Panel’s recommendation not to investigate.