Paying compensation to unbanked households without losing the audit trail
Cash payments are fast and unevidenced; bank transfers are evidenced and exclude people. How projects run both without gaps.
Compensation has to reach the person entitled to it, and the project has to be able to show that it did. In a population where a substantial share of adults hold no bank account and some hold no identification at all, those two requirements pull in opposite directions: the payment method that reaches everyone leaves the weakest evidence, and the method with the best evidence excludes people.
The three methods and what each costs
Cash
Reaches everyone, requires nothing of the recipient, and settles immediately. Its evidence is a signature or thumbprint on a schedule, which establishes that someone signed and not much else. It also concentrates large sums at announced times and places, which creates a security risk borne by the recipients — theft on the way home from a payment point is a recurring and under-recorded harm.
Bank transfer
Produces the strongest evidence: an instruction, a settlement record, and a destination account in a name. It requires identification, an account, and a branch the recipient can reach, and it fails silently — a rejected transfer sits in a suspense account while the project's records show the payment as made.
Mobile money
Reaches much further than banking in most of the region, settles quickly, and generates a transaction record with a timestamp. Its constraints are transaction and wallet limits that a compensation payment routinely exceeds, registration in a name that may not match the register, and the fact that the SIM may be controlled by someone other than the entitled person.
In practice most programmes run all three. The failure is not the mix; it is treating the mix as three separate processes with three separate records.
What has to be true whichever method is used
- The entitled person is identified against the register, and the identification method used is recorded.
- The amount paid is traceable to a specific entitlement calculation, at a specific matrix version.
- Receipt is confirmed by the recipient, not inferred from the project's own instruction.
- The record of all three is captured at the moment of payment, in one system, not reconciled from three later.[1]
Identity without identification
Where an entitled person holds no national identification, the choice is between excluding them and constructing an identity record the project can stand behind. The second is the only acceptable option, and it needs to be systematic rather than improvised at the payment table.
A workable approach combines a photograph and biometric captured at enumeration, attestation by local authority with the attesting person named, corroboration by two neighbours who are themselves in the register, and — where a national identification system exists — support to obtain the document, started at census rather than at payment.[2]
What matters is that the standard applied is consistent and written down before payments begin. An identity practice invented case by case at the payment table cannot be defended later, and it is where the most serious allegations of diversion arise.[4]
Reconciliation is the whole point
The reconciliation that a completion audit requires runs in three columns: entitlement calculated, payment instructed, funds confirmed received. A programme can only claim to have paid compensation if the third column is populated.
Where the columns live in different systems — entitlements in the RAP database, instructions in the finance system, mobile money in a provider portal, cash in a signed paper schedule — reconciliation becomes an exercise in matching names across four sources with inconsistent spelling. It is doable and it takes months, and it is the single most common reason a programme that paid correctly cannot demonstrate it.[3]
Practical safeguards
- Pay against the register, not against a schedule. A payment list exported once and edited thereafter drifts from the entitlement record.
- Capture confirmation in the field, offline if necessary, against the household record — with a photograph of the recipient at payment where consent allows.
- Reconcile continuously. Weekly matching of instructed against confirmed catches failed transfers while they can still be corrected.
- Give the recipient a document. A slip stating the amount, the date and what it was for is the recipient's own evidence and prevents a large share of later disputes.
- Separate duties. The person who calculates an entitlement should not be the person who authorises the payment or the person who hands it over.
The security question
Announcing that several hundred households will be paid in cash at a named location on a named day is an operational decision with consequences the project does not bear. Where cash is unavoidable, splitting payment across smaller sessions, offering accompanied transport to a bank, and avoiding fixed publicised schedules all reduce the exposure. Where mobile money is available, the case for it rests as much on this as on the audit trail.
Sources
- [1]Performance Standard 5: Land Acquisition and Involuntary Resettlement — International Finance Corporation, 2012.
- [2]Good Practice Handbook: Land Acquisition and Involuntary Resettlement — International Finance Corporation, 2023.
- [3]Guidance Note 5: Land Acquisition and Involuntary Resettlement — International Finance Corporation, 2012.
- [4]Evicted and Abandoned: The World Bank's Broken Promise to the Poor — International Consortium of Investigative Journalists, 2015.
Olule Solomon
Lead Consultant, ValueSpace
Olule Solomon is Lead Consultant at ValueSpace, where he works on land acquisition and resettlement systems for donor-financed infrastructure in East Africa. He writes about the practical gap between what the safeguard standards require and what a project can actually evidence at completion audit.
Related reading
- Reconciling compensation payments: the evidence gap nobody budgets forPaying compensation and proving you paid it are different problems. How disbursement files are reconciled back to entitlements.
- Identifying vulnerable households — and what to do after you haveMost RAPs define vulnerability and then never use the flag again. Making it operational from census through to closure.
- The RAP completion audit: evidencing compliance you cannot reconstructWhat a completion audit tests, why reconstruction after the fact fails, and the records that have to exist from day one.
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