Raw deals: EIB’s new initiative and the concerns it won’t address

At its Board of Directors meeting on 21 March 2025, the European Investment Bank (EIB) adopted a new ‘Critical Raw Materials Strategic Initiative’ to finance and provide advisory support for projects across the raw materials value chain, both within and outside the EU. The initiative aligns with the EU’s Critical Raw Material Act (CRMA) and follows the Bank’s decision in July 2023 to resume financing raw materials projects after a 10-year pause due to their poor human rights and environmental record.

The new initiative of the EIB is promoted as a tool to secure access to critical raw materials for Europe’s green and digital transitions, and to ensure the global competitiveness of European industry – including in the area of security, defence and aerospace.

However, no new financing was announced. The Bank merely reiterated its existing objective of providing €2 billion in raw materials financing for 2025. This sum was already allocated in the EIB Group 2024-2027 Strategic Roadmap (June 2024) and in the Bank’s ‘Tech-EU’ investment programme. In 2023, the EIB announced its funding aims to be deployed by 2027 and mobilise more than €150 billion in investment for the targeted sectors.

​​The main novelty is a new Critical Raw Materials Task Force, though its role and composition remain unclear. Commissioner Šefčovič proposed a similar body in February 2024, who proposed to call it “Sustainable Critical Raw Materials Task Force”. At the time, he called for it to coordinate national raw material funds, such as Germany's €1 billion fund, France's €2 billion fund, and a €500 million fund launched by a venture capital and private equity firm and the European Institute for Innovation & Technology. The EIB has not confirmed whether the Task Force will serve this function.

The EIB also plans to create a dedicated ‘one-stop shop’ to manage raw materials operations, advisory activities, technical expertise, and partnerships.

Shortly after the EIB’s announcement, the European Commission published a list of 47 ‘Strategic Projects’ in the EU, granting them expedited approvals and access to public and/or private funding. According to civil society analysis, this labeling risks greenwashing harmful projects. Moreover, they can be in ‘overriding public interest’, which means that critical environmental protections under EU law can be relaxed to advance such projects, leading to irreversible harm to biodiversity and natural ecosystems.

EIB’s answer to civil society letters

The EIB responded to two civil society letters addressed to its Board of Directors.

The first letter, signed by 23 civil society organisations and sent to the Bank in October 2024, urged the Bank to improve its transparency, accountability and meaningful public participation – including guaranteeing Free Prior Informed Consent – ahead of extending its financing to raw materials projects.

The second letter, sent to the Bank in February 2025 and signed by 64 organisations globally, criticised the Commission’s and the EIB’s cooperation agreements with Rwanda and called on the EU to suspend all mineral-related strategic projects with Rwanda in light of the violent minerals-fueled conflict in the DRC where it is involved.

In its response to the second letter, the EIB refused to adequately acknowledge the issues raised by civil society organisations about its Rwanda partnership and did not state any plans to suspend the investment partnership, despite the calls of the European Parliament to suspend the Commission’s agreement and to freeze budgetary support to Rwanda by financial institutions such as the EIB. In this regard, the EIB simply stated it currently does not finance any project.

Responding to the first letter, the EIB noted it did not expand the scope of eligible escorts with regard to raw materials, despite the Bank communicating in this very language on its website. These sectors, the EIB said, were always eligible.

On the question of its human rights policies, the EIB simply rebuked the concerns of civil society as ‘not shared’ by the Bank. It is regrettable that despite numerous civil society letters calling on the EIB to improve its human rights standards and introduce a specific human rights due diligence, the Bank considers its current policies sufficient for financing of projects that ‘may potentially adversely affect human rights’, as the Bank itself said.

The EIB also dodged questions about its Complaints Mechanism (EIB-CM), claiming it is independent and effective. However, Anna Roggenbuck (CEE Bankwatch Network) criticized its weak independence, pointing out that:

“The EIB CM operational independence from EIB Group services is merely declaratory. In reality, this independence is weakly substantiated by the relevant policy provisions. The Head of the Mechanism is hired by the EIB’s Management without any external participation. The existing case-handling procedure and reporting line undermines the independence of the EIB-CM, in that it fails to ensure that EIB management is fully accountable for implementing the recommendations of the mechanism.”

Her analysis of the Complaints Mechanism reveals that before issuing its final report, the EIB-CM discusses its findings and recommendations multiple times with EIB services. This includes an initial draft Conclusions Report, which is subject to consultations, followed by a final draft report that is once again reviewed with EIB services and the EIB Management Committee.

"The Ombudsman’s review is limited to investigating administrative aspects and it is accessible to the EU’s citizens and organisations. This may not fully satisfy those seeking a more substantial assessment of a project’s compliance with applicable standards and those living outside of the EU," added Anna Roggenbuck.

Finally, the EIB disregarded calls for meaningful public participation in its project cycles and the need for Free, Prior, and Informed Consent, insisting that its existing stakeholder engagement standards are sufficient. In response to concerns over unclear project additionality and lack of transparency, the Bank merely reiterated that it carries out assessments and is ‘constantly reviewing its transparency and disclosure practices.’ If that is the case, there is still a long way to go.

The EIB concluded its letter by stating it would follow up in the coming months. Stay tuned.