Access to Information Committee Decision on Appeal Case Number AI10145 : Lesotho Sustainable Livelihoods Aide Memoires (Decision dated September 10, 2026)

Overview & Synopsis

The Decision AI10145 documents the decision of the Access to Information Committee (AIC) regarding an appeal challenging the World Bank’s refusal to disclose eleven aide-mémoires related to the Pathways to Sustainable Livelihoods Project in Lesotho. The requester appealed on the grounds of an alleged violation of the World Bank’s Access to Information (ATI) Policy. After reviewing the requested records, the ATI Policy provisions, the borrower’s views, and the historical and policy context governing aide-mémoires, the AIC determined that the documents are inherently deliberative in nature and are therefore protected under the ATI Policy’s Deliberative Information exception. The Committee also found that several documents contained information provided in confidence by the borrower and that the Government of Lesotho explicitly declined consent for disclosure, a mandatory requirement for the release of aide-mémoires. Accordingly, the AIC concluded that the Bank had properly and reasonably restricted access, found no violation of policy, and upheld the Bank’s original decision to deny public disclosure of the requested records. The decision further reinforces the established policy framework protecting confidential and deliberative communications between the Bank and borrowing countries during project implementation.