The Request alleges that two Bank-financed projects in Tajikistan, the Sustainable Financing for Rogun Hydropower Project (P181029) and the Technical Assistance for Financing Framework for Rogun Hydropower Project (P178819) (unless explicitly stated otherwise, both projects are hereafter jointly referred to as the “Project”), are likely to cause harms to communities downstream of Tajikistan’s Vakhsh Hydropower Cascade. The Request claims that the Bank did not comply with its Environmental and Social Framework (ESF) and failed to develop a “robust” Environmental and Social Management Plan (ESMP) and Environmental and Social Commitment Plan (ESCP) for the Rogun Dam.
The Request alleges that the Bank’s “errors and omissions” in the design and implementation of the Project will contribute to ecological harm and interdependent environmental and socioeconomic impacts. The Request also alleges a lack of meaningful consultation and stakeholder engagement.
Firstly, regarding the environment, the Request claims that the Rogun Dam will result in water deficit and affect water quality, degrade important coastal ecosystems resulting in the loss of their recreational properties, and cause the extinction of critically endangered species. The Request alleges that the Rogun Dam’s Environmental and Social Impact Assessment (ESIA) is based on incomplete and outdated data and that cumulative impacts resulting from this dam and other water infrastructure projects downstream along the Amu Darya were not appropriately considered.
Secondly, on socioeconomic impacts the Request claims that water flow redistribution caused by the Project could affect the livelihood of downstream communities in Turkmenistan and Uzbekistan, and the alleged forced resettlement of people from Tajikistan could potentially create a “migration/displacement crisis” in the already disadvantaged Amu Darya basin in the downstream. According to the Request, the Project will affect the dependent canal systems in Karakum, Karshi, and Amu-Bukhara areas in Uzbekistan, exacerbating environmental problems that could potentially require costly overhauls of agriculture and municipal water supplies. The Request also claims that, if left unaddressed, such impacts could lead to an increase in unemployment and a collapse of the region’s economy. Additionally, the Request claims that a potential reduction in the flow of the Amu Darya River caused by the construction and operation of the Rogun Dam could impact communities’ health due to water mineralization (increased salt content) and dried-out areas releasing salts into the air. The Request also alleges cultural ties with riverine life will be severed, unless the natural habitat is protected from negative Project impacts.
Third, the Request alleges harm arising from insufficient consultation and lack of disclosure to affected downstream communities of the Project’s safeguard documents. The Request claims that no meaningful consultations or surveys were conducted in the potentially affected regions during the preparation of the ESIA for the Rogun Dam, and the ESIA planning and preparation “completely ignored” the interests of people living downstream of the Project, particularly those in the Aral delta region. The Request claims that the project lacks a facility for filing compensation claims in case the dam malfunctions or bursts. The Request also claims that the Project’s Stakeholder Engagement Plan lacks clear procedures, fails to ensure meaningful consultations, and - in a context of “closed civic space in Central Asia” - exposes individuals to potential reprisals.
As per the Panel’s process, an initial due diligence was undertaken to verify that the Request meets the relevant criteria for the Panel to admit the request. The Panel met virtually with the Requesters, their representative and advisors on March 19 and 28, 2025. The Requesters elaborated on their concerns regarding the impact of the Rogun HPP in the riparian countries of Uzbekistan and Turkmenistan. As part of its review the Panel also met with Bank Management on March 25, 2025. Management provided the context and timeline of the Bank’s involvement in the Rogun HPP development, the description of the Project, and the current status.
The Panel, being satisfied that the Request meets the criteria, registered the Request on April 8, 2025. Bank Management provided its written response to May 23, 2025. A Panel visited Tajikistan from June 1-7, 2025. On June 26, 2025, the Panel recommended an investigation to the alleged issues of harm in the Request and possible noncompliance of the applicable World Bank policies. In its recommendation, the Panel noted that the Request for Inspection, and the Requesters met the technical eligibility criteria based on Panel precedents, where a project’s adverse impacts are alleged to occur in a territory downstream from the borrowing country. Panel determined that Requesters from the downstream countries who claim to be directly affected by these impacts, can be eligible. The Panel also considered that there could be a plausible link between the alleged harm in the Request and the Project.
On November 11, 2025, the Board of Executive Directors of the World Bank considered the Panel’s Report and Recommendation, and concluded that the Request did not meet the technical eligibility criterion as set out in paragraph 29(a) of the Accountability Mechanism Resolution. In making this determination, Executive Directors did not make a judgment on the merits of the Request.
The Panel has closed the case.
