Bujagali: the completion audit nobody did, and the 24 years that followed

In December 2017, the Compliance Advisor/Ombudsman published the finding that ought to be read by anyone who thinks a resettlement file closes when the last payment clears: on the Bujagali transmission line, the completion audit that Performance Standard 5 requires was never carried out.[2] Without it, IFC held no assurance that compensation had met full replacement cost — and CAO recorded that many affected households had therefore likely been paid too little.[1]

Seven years of monitoring followed. In April 2025 CAO closed the case, not because the problem was fixed, but because it concluded there was no expectation of resolution. IFC's response on land compensation was rated Unsatisfactory.[1] The first complaint about this project had been filed in June 2001.[6]

A missing completion audit is not a paperwork gap. It is the reason a project cannot answer, twenty years later, whether it paid people enough.

The project, and the line that caused the trouble

Bujagali is a 250 MW run-of-river plant on Dumbbell Island in the Nile, roughly 8 km downstream of the existing Nalubaale and Kiira stations (IFC project 24408; MIGA 6732).[5] The reservoir inundated some 388 hectares, and the loss of the falls themselves — a site of spiritual significance — was among the earliest grievances raised.[6]

But the resettlement failure that outlasted every other issue was not the dam. It was the associated 132 kV transmission line — about 100 km of it, built by Bujagali Energy Limited on behalf of the Uganda Electricity Transmission Company (UETCL), under a separately disclosed Resettlement Action Plan.[4] A wayleave taking a strip across hundreds of smallholdings is administratively unglamorous next to a dam. It generated the claims that were still open a quarter of a century later.

What CAO actually found

The Bujagali-07 complaint was filed on 2 February 2015 by four community members on behalf of themselves and more than 200 others, alleging inadequate compensation for crops damaged by project activities.[1] CAO appraised it in November 2016 and reported its compliance investigation on 15 December 2017.[2] Four findings matter to anyone building a resettlement record:

• The RAP did not meet PS-5. CAO found IFC "did not ensure the Resettlement Action Plan (RAP) for the transmission line met the requirements of PS5."[1]
• Replacement cost was never assured. IFC "lacked assurance that the RAP's compensation framework met IFC's standards for full replacement cost, was disclosed to and consulted with affected communities."[1]
• The grievance mechanism could not carry the load. Weaknesses in the RAP surfaced in implementation, and the mechanism was "unable to handle complaints about land acquisition."[1]
• No completion audit. The audit PS-5 requires was not conducted, so there was no independent verification of what implementation had actually delivered.[2]

Read those together and the causal chain is plain. PS-5 requires compensation at full replacement cost and, where impacts are significant, an external completion audit to verify that the plan's provisions were met.[7][8] The audit is the control that would have caught the valuation problem. It was skipped, so the valuation problem survived into a dispute that no later process could settle on the evidence available.

What claimants did when the project record failed them

They went to court. In 2007, 557 people sued UETCL, pleading the Constitution and the Land Act — the domestic guarantee of prior, fair and adequate compensation, not the lender standard.[3] That claim ran in parallel with a second CAO complaint (Bujagali-05, filed 16 May 2011) covering tourism livelihoods lost with the falls, blasting damage, and transmission-line compensation.[3]

Dispute resolution worked where the RAP had not. In April 2015 a mediated agreement was signed with 514 claimants — the "557 Group" — and in May 2015 the High Court of Uganda adopted it as a judgment of the court.[3] UETCL had committed to complete payment by 31 July 2015. It did not: implementation finished in April 2017. A further 16 claimants outside the suit settled in April 2017 and were paid in June 2017. CAO closed that case on 26 September 2018.[3]

Note what it took to make a compensation claim stick on this project: a class action, an international accountability mechanism, a mediation, and a High Court judgment — spanning eight years for the group that had legal representation. That is the substitute a project buys itself when the register cannot answer the question directly.

The lesson is about sequence, not sympathy

The Inspection Panel had already investigated Bujagali. It received the request on 5 March 2007, the Board approved an investigation on 18 May 2007, and the Panel reported in 2008 (Report No. 44977-UG).[5] A second request followed in 2016. Bujagali is among the most-complained-about projects in either institution's history — and yet the specific defect that kept the file open was procedural and cheap to prevent.

The completion audit is scheduled after implementation, which is exactly why it gets dropped: by the time it falls due, the works are energised, the consultants have demobilised and the budget line looks like an expense with no deliverable. Its value is only visible in the case where something went wrong — and then it is the only thing that can establish what affected people actually received, while the people who measured the crops are still reachable.

What the register had to carry, and did not

Reconstructing a wayleave caseload after the fact means answering, per claimant, questions the original file should have closed at the time:

• The rate source for every crop and tree valued, and the date that schedule was in force — a district rate applied a season late is a shortfall, and an unrecorded rate source is an unfalsifiable one.
• The replacement-cost derivation, not just the sum paid: what market evidence supported it, and whether depreciation was deducted (PS-5 does not permit it).[7]
• Disclosure and consultation evidence tied to the claimant — CAO's finding was that assurance of disclosure was absent, which is a records failure before it is a conduct failure.
• The grievance trail, including complaints the mechanism declined to handle. Bujagali's mechanism turned away land-acquisition claims; the fact that it did so is itself the finding.
• A completion-audit dataset assembled while the evidence is live: sampled households, measured outcomes against baseline, and the exceptions with the reason each was made.

What this case does not establish

Everything above is drawn from disclosed documents: CAO's case files and investigation report, the RAP disclosed through the World Bank, the Inspection Panel record, and the court outcome as reported in the CAO case file. It is not drawn from any project register, and this article had no access to one. CAO's findings are findings about IFC's supervision; they are not a judicial determination against UETCL or Bujagali Energy Limited, and the 2015 High Court judgment adopted a negotiated settlement rather than adjudicating liability. Individual entitlements turned on Ugandan law and on facts specific to each claimant, and nothing here should be read as advice on any particular claim.