The Request alleged that there was no information disclosing that the Public Sector Efficiency and Green Recovery program (the “Project”) was supported by the World Bank. The Request raised four negative impacts resulting from one of the Project’s Prior Actions: the establishment of a Social Card Register (SCR or the “Register”) for the consolidation of data on social protection beneficiaries for the purpose of improving social protection policymaking and targeting. The 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.
As part of its due diligence, the Panel met with some of the Requesters on April 26, 2024, and May 7, 2024, to better understand their claims, seek clarifications, and inform them about the Panel’s process and mandate. On May 7, 2024, the Panel met with Bank Management, which provided a summary of the Program and its views of the issues raised in the Request. On August 15, 2024, the Panel received documentation showing that Requesters had met with Management and Management had had an opportunity to respond to their claims. After Requesters informing the Panel that they wanted to proceed with the Panel process, the Panel registered the Request on August 27, 2024.
Management submitted its Response to the issues raised in the Request on September 27, 2024, stating the harm alleged in the Request is unrelated to the adoption of the Law on Social Card or the establishment of the SCR. Management also stated that the adverse impacts described by the Requesters do not stem from any non-compliance with Bank policy requirements applicable to the Development Policy Operations. In Management’s view, the SCR has improved public sector efficiency, fairness, inclusion, and transparency in social protection.
A Panel team visited Serbia on October 15-21, 2024. On November 12, 2024, the Panel submitted to the Board of Executive Directors its Report and Recommendation, recommending an investigation into whether the World Bank had conducted sufficient due diligence to assess whether the establishment of the SCR 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 the inaccessibility of, and delays in, the appeals process.
Following several informal interactions prompted by Board members, Management submitted an Addendum to its initial Response on May 28, 2025, describing specific actions it would take to address the two allegations the Panel had recommended for investigation. On October 17, 2025, the Panel submitted a Statement from the Chairperson, 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 the proposed actions.
On December 4, 2025, Management submitted a detailed Progress Report on the actions it had taken. These included convening workshops with civil society organizations on the lessons learned from the implementation of the SCR; supporting training activities for officials who oversee social protection workers managing the SCR 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 revised its earlier recommendations to the effect of no longer recommending an investigation. On December 18, 2025, the Board approved the Panel’s recommendation not to investigate the Project.
