DOCUMENT OF THE WORLD BANK FOR OFFICIAL USE ONLY REPORT NO: PAD2480 INTERNATIONAL DEVELOPMENT ASSOCIATION PROJECT APPRAISAL DOCUMENT ON A PROPOSED CREDITS AND GRANT TO THE REPUBLIC OF CÔTE D’IVOIRE & THE REPUBLIC OF GUINEA AND ON A PROPOSED GRANT TO THE ECOWAS COMMISSION IN THE TOTAL AMOUNT OF SDR 84 MILLION (US$122.1 MILLION EQUIVALENT) FOR THE WEST AFRICA UNIQUE IDENTIFICATION FOR REGIONAL INTEGRATION AND INCLUSION (WURI) PROJECT USING THE MULTIPHASE PROGRAMMATIC APPROACH WITH AN IDA FINANCING ENVELOPE OF SDR 218.1 MILLION (US$317.1 MILLION EQUIVALENT) FOR PHASE 1 OF A MPA PROGRAM: MAY 9, 2018 SOCIAL PROTECTION & JOBS GLOBAL PRACTICE AFRICA REGION This document has a restricted distribution and may be used by recipients only in the performance of their official duties. Its contents may not otherwise be disclosed without World Bank authorization. The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) CURRENCY EQUIVALENTS (Exchange Rate Effective April 30, 2018) Currency Unit = CFAF, GNF, SDR CFAF 542 = US$1 GNF 9026 = US$1 SDR 0.70 = US$1 FISCAL YEAR 2018 Regional Vice President: Makhtar Diop Country Director: Rachid Benmessaoud Senior Global Practice Director: Michal J. Rutkowski Practice Manager: Jehan Arulpragasam Task Team Leader(s): Qaiser M. Khan, Samia Melhem, Tina George 2 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) ABREVIATIONS & ACRONYMS AfDB African Development Bank AFD Agence Française de Developpement [“French Development Agency”] API Application Programming Interface BCEAO Banque Centrale des Etats de l'Afrique de l'Ouest [“Central Bank of West African States”] BTC Belgian Technical Cooperation CFA Communauté financière d'Afrique [“Financial Community of Africa”] CFAF CFA franc CFTA Continental Free Trade Area CGAP Consultative Group to Assist the Poor CPF Country Partnership Framework CR Civil Registry CRI Corporate Results Indicator CSO Civil Society Organization DA Designated Account DAF Directorate of Administration and Finance, ONI (Côte d’Ivoire) DLI Disbursement Linked Indicator ECOWAS Economic Community of West African States eIDAS Electronic Identification and Trust Services Ecosystem (European Union) EFC Error, Fraud and Corruption ENBIC ECOWAS National Biometric ID Card EU European Union FM Financial Management fID Foundational ID FY Fiscal Year G2P Government-to-Person GDP Gross Domestic Product GFF Global Financing Facility GNF Guinean franc GRM Grievance Redress Mechanism GRS Grievance Redress Service HD Human Development IBRD International Bank for Reconstruction and Development ICR Implementation Completion and Results Report ICT Information and Communication Technology ID Identification ID4D Identification for Development IDA International Development Association IEG Independent Evaluation Group IFC International Finance Corporation IFI International Financial Institution 3 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) IGF Inspection générale des finances [“Inspectorat General of Finances”] (Côte d’Ivoire) IMF International Monetary Fund IOM International Organization for Migration IPF Investment Project Financing ICT Information and Communication Technology KYC Know Your Customer LoA Level of Assurance M&E Monitoring and Evaluation MIGA Multilateral Investment Guarantee Agency MoU Memorandum of Understanding MPA Multiphase Programmatic Approach NGN Nigerian Naira NGO Non-Governmental Organization ONI Office National d'Identification [“National Identification Office”] (Côte d’Ivoire) OVC Orphans and Vulnerable Children PDO Project Development Objective PEFA Public Expenditure and Financial Assessments PFM Public Expenditure Management PforR Program-for-Results PIM Project Implementation Manual PIU Project Implementation Units PMO Office of the Prime Minister PPP Public-Private Partnership PPSD Project Procurement Strategy for Development PrDO Program Development Objective RFP Requests for Proposals RSR Rapid Social Response (World Bank Program) SCD Systematic Country Diagnostic SDG Sustainable Development Goals SAMP Social Assessment & Management Plan SEP Stakeholder Engagement Plan SIM Subscriber Identity/Identification Module SME Small and Medium Enterprise SPJ Social Protection, Labor and Jobs SSA Sub-Saharan Africa UNESCO United Nations Educational, Scientific and Cultural Organisation UNHCR Office of the United Nations High Commissioner for Refugees UNI Unique Identification Number UNICEF United Nations International Children’s Emergency Fund US$ United States dollar WAEMU West African Economic and Monetary Union WB World Bank WBG World Bank Group 4 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) GLOSSARY For ease of reference, and in order to facilitate comprehension of this document, the following terms are defined in this glossary: Authentication factor An element used in confirming an individual’s identity, of which there are five types: (i) knowledge factors (i.e., something you “know”), (ii) possession factors (i.e., something you “have”); (iii) inherence factors (i.e., something you “are”), (iv) locations factors (i.e., where you are); and (v) behavioral factors (i.e., what you “do”). Every authenticator has one or more authentication factors. Multi-factor authentication (MFA) applies when two or more factors (often of different types) are used to authenticate, with two-factor authentication being increasingly common. 1 Beneficiary registries Systems for maintaining information on beneficiaries of specific social programs to support operations, management, and the administration of benefits. 2 Biometrics Physiological or behavioral characteristics that are unique to an individual (e.g., fingerprints, voice patterns) and which can be used as a means of automatic verification of an individual’s identity.1 Biometric identification The automatic comparison of an individual’s biometrics to a stored template of that person’s biometrics for the purposes of confirming an individual’s identity. The comparison may be either a one-to-one (1:1) matching, where comparison is done against a single template, or one-to-many (1:n) matching, where comparison is done against multiple templates. 3 Civil identification The verification, registration, management, and conservation of personal data, with the goal of establishing a unique identity. Civil identification includes data from the civil registry of that particular individual (typically having a certain, requisite legal status), as well as other attributes, such as assignation of a unique number and/or collection of biometric data. Civil identification frequently serves as a basis for the verification of identity in subsequent systems (e.g., passport, national identification documents). 4 Civil registration (CR) system A foundational system for establishing a person’s existence, the CR system is the continuous, permanent, compulsory, and universal recording of the occurrence and characteristics of vital events (live births, deaths, fetal deaths, marriages, and divorces) and other civil status events pertaining to the population as provided by decree, law or regulation, in accordance with the 1 Grassi, Paul; Garcia, Michael; and Fenton, James. 2017. “Digital Identity Guidelines”. Report. National Institute of Standards and Technology. https://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-63-3.pdf. 2 Leite, Phillippe; George, Tina; Sun, Changqing; Jones, Theresa; and Lindert, Kathy. 2017. “Social registries for social assistance and beyond: a guidance note and assessment tool (English)”. Report. Washington, DC: World Bank Group. http://documents.worldbank.org/curated/en/698441502095248081/pdf/117971-REVISED-PUBLIC-Discussion-paper-1704.pdf. 3 Jain, Anil; Ross, Arun; and Nandakumar, Karthik. 2011. Introduction to Biometrics. Book. New York: Springer Publishing Co. 4 Harbitz, Mia; and Kentala, Kristo. 2015. “Dictionary for Civil Registration and Identification”. Report. Inter-American Development Bank. https://publications.iadb.org/bitstream/handle/11319/3679/Dictionary%20for%20Civil%20Registration%20%20and%20Identification%20 2015.pdf?sequence=7. 5 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) legal requirements in each country. 5 Typically, the CR system is the basis for establishing a person’s legal identity. Deduplication The process (either “in-line”, as data is flowing, or “post-process” after it has been written) of (or “single instancing”) eliminating duplicate or redundant information; in the case of an individual’s identity, that process applies to removing duplicate identities of a single individual in order to establish uniqueness in the system. 6 Digital identity A unique representation of an individual engaged in an online transaction, it is always unique in the context of a particular digital service, but does not necessarily uniquely identify that individual in all or even any other contexts; as such, accessing a digital service may not mean that the individual’s real-life identity is known.1 Foundational identification A collection of systems, the foundational identification (fID) ecosystem establishes the legal (fID) ecosystem identity of individuals, principally by (i) establishing the individual’s legal existence and (ii) creating a means for that individual to prove their identity. There is no single blueprint for either institutional or operational arrangements, nor for how foundational systems interrelate. 7 Typically comprised of a CR system (for establishing legal existence) and either a fID system (for proof of identity) or a collection of ID systems, the fID ecosystem’s efficacy is enhanced by data sharing between foundational systems. 8 Foundational identification A foundational system for proving an individual’s identity, the fID system uses a minimal set of (fID) system attributes, such as biographic and biometric data, to uniquely and exclusively describe an individual, and, on that basis, to provide government-recognized ID credentials (fIDs). The fID system is “foundational” relative to various, functional systems and databases (e.g., education, health, telecommunications), on which they rely, but it is a parallel and complementary component (along with, for instance, the CR system) of the larger fID ecosystem. In this document, the fID system is understood to be inclusive of all persons in the territory of a country, irrespective of nationality, citizenship or legal status.8 Functional identity An identity credential issued by an entity in order to identify individuals for a particular service or transaction (e.g., driver’s licenses, voter cards, health and insurance records, bank cards). These may be commonly accepted for broader identification purposes. 9 Government-recognized ID In this document, references to “government-recognized IDs” or “foundational IDs” (fIDs), are or foundational IDs (fIDs) exclusively with regard to the credentials issued by the fID system, and are understood as being an official form of unique identification, not necessarily linked to nationality, citizenship or legal 5 Department of Economic and Social Affairs, United Nations Statistics Division. 2014. “Principles and Recommendations for a Vital Statistics System - Revision 3”. Report. Series M, No. 19/Rev.3. New York: United Nations. https://unstats.un.org/unsd/demographic/standmeth/principles/M19Rev3en.pdf. 6 Kumar, B. Sateesh; Rani, V. Uma; and Raj, T. Akshay. 2016. “A Survey on Distributed Deduplication System for Improved Reliability and Security”. Article. International Research Journal of Engineering and Technology. https://www.irjet.net/archives/V3/i8/IRJET-V3I8104.pdf. 7 Gelb, Alan; and Clark, Julia. 2013. “Identification for Development: The Biometrics Revolution”. Working Paper. Centre for Global Development. https://www.cgdev.org/sites/default/files/1426862_file_Biometric_ID_for_Development.pdf. 8 As defined for this project. 9 World Bank Group, GSMA & Secure Identity Alliance. 2016. Digital Identity: Towards Shared Principles for Public and Private Sector Cooperation. Discussion Paper. Washington DC: World Bank Group. https://secureidentityalliance.org/public-resources/4-july-2016- report-digital-identity/file. 6 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) status, recognized by the state as proof of identity that can be used as the basis for accessing a variety of public and private services.8 Identity (ID) An attribute, or set of attributes, that uniquely describe(s) a subject within a given context.1 Identity assurance The ability to determine, with a degree of certainty—or level of assurance (LoA) or authenticator assurance level—that a claim to a particular identity made by some person or entity can be trusted to be actually be the claimant’s “true” identity. 9 Identity credential A mechanism, process, device or document that vouches for the identity of a person through some method of trust and authentication (e.g., ID cards, certificates, numbers, passwords or SIM cards) 9 Identity document Any document that includes, references or substantiates identity-information, as opposed to vouching for a person’s identity (e.g., apartment lease, utility bill).1 Identity proofing The process of establishing that a subject is who they claim to be.1 International Development The part of the World Bank that helps the world’s poorest countries, it is overseen by 173 Association shareholder nations, and aims to reduce poverty by providing loans (called “credits”) and (the “Association” or IDA) grants for programs that boost economic growth, reduce inequalities and improve people’s living conditions. 10 Interoperability The ability of organizations to interact towards mutually beneficial goals, involving the sharing of information and knowledge between these organizations, through the business processes they support, by means of the exchange of data between their ICT systems. 11 Multiphase Programmatic A World Bank-financed program that contributes to development objectives of member states, Approach (MPA) program and which consists of two or more operations that have a common program development objective(s). 12 National identity A government-recognized form of an individual’s identity issued by the state to its nationals or citizens, or to other individuals having a certain legal status recognized by the state (e.g., residents), that can be used as the basis for accessing a variety of public and private services. 8 National population registry A mechanism of continuous recording, and/or of coordinated linkage, of selected information pertaining to each member of the resident population of a country in such a way to provide the possibility of determining up-to-date information concerning the size and characteristics of that population at selected time intervals. 13 Personal data Any information relating to an individual who can be identified, directly or indirectly, in particular by reference to an identifier (e.g., name, identification number, location data, online 10 World Bank. 2018. “What is IDA?”. Website. Washington, DC: World Bank Group. http://ida.worldbank.org/about/what-ida. 11 European Union. 2017. New European Interoperability Framework. https://ec.europa.eu/isa2/sites/isa/files/eif_brochure_final.pdf. 12 World Bank. 2017. Multiphase Programmatic Approach (English). Report. Washington, DC: World Bank Group. http://documents.worldbank.org/curated/en/203081501525641125/Multiphase-Programmatic-Approach. 13 United Nations Statistics Division. 1969. Methodology and Evaluation of Population Registers and Similar Systems. Book. New York: United Nations. https://unstats.un.org/unsd/publication/SeriesF/Seriesf_15e.pdf. 7 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual). 14 Physical presence The place where a person is actually, physically located, regardless of duration therein or of legal status. In this document, “physical presence” is used as the basis for inclusion in the fID system (although other persons, such as a country’s foreign nationals) may also be included.8 Rapid Social Response (RSR) A multi-donor program established to help the world’s poorest countries to build effective program social protection systems and one of the key instruments for implementing the Bank’s SPJ Strategy for resilience, equity and opportunity in IDA-eligible countries. 15 Social protection, labor and Policies and programs that help individuals and societies manage risk and volatility, and that jobs (SPJ) system help to protect them from poverty and destitution through instruments that improve resilience, equity and opportunity (i.e., pensions and social insurance, social assistance/social safety net and employment programs). 16 Social registry Information systems that support outreach, intake, registration and determination of potential eligibility for one or more social programs.2 Trust framework Within the context of multi-party identity systems, the generic name, for the set of system rules governing the collection, verification, storage exchange, authentication, and reliance on identity information that, collectively, allows participating entities to trust each other (e.g., Visa operating rules, the EU’s eIDAS). The term is synonymous with terms such as “system rules”, “scheme rules”, “operating regulations” or “common operating rules”. 17 Unique identification An identification number that is unique to that individual; international good practice is that number (UNI) the number should be unintelligible, randomly-assigned and issued at birth.8 Vulnerable groups Individuals or groups who, by virtue of, inter alia, their age, gender, income, ethnicity, language, religion, physical, mental or other disability, social, civic or health status, sexual orientation, gender identity, economic disadvantages, engagement in informal or illegal activities, or location in remote or isolated areas, may be less likely to benefit from the Project or participate fully in the mainstream consultation process.8 14 European Commission. Regulation (EU) No. 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (Text with EEA relevance). https://eur-lex.europa.eu/legal- content/EN/TXT/?uri=celex%3A32016R0679. 15 World Bank. 2018. Rapid social response program: building effective and adaptive social protection and jobs systems for rapid response to urgent social needs (English). Washington, DC: World Bank Group. http://documents.worldbank.org/curated/en/679091519669977586/Rapid-social-response-program-building-effective-and-adaptive- social-protection-and-jobs-systems-for-rapid-response-to-urgent-social-needs. 16 World Bank. 2012. Resilience, equity, and opportunity: The World Bank’s social protection and labor strategy 2012–2022 (English). Report. Washington, DC: World Bank Group. http://documents.worldbank.org/curated/en/443791468157506768/pdf/732350BR0CODE200doc0version0REVISED.pdf. 17 Makaay, Esther; Smedinghoff, Tom; and Thibeau, Don. 2017. “Trust Frameworks for Identity Systems”. Report. Open Exchange. http://www.openidentityexchange.org/wp-content/uploads/2017/06/OIX-White-Paper_Trust-Frameworks-for-Identity- Systems_Final.pdf. 8 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) Table of Contents DATA SHEET ............................................................................................................................................... 10 MAIN DOCUMENT...................................................................................................................................... 20 I. STRATEGIC CONTEXT ............................................................................................................................... 20 A. Regional Context ............................................................................................................................................ 20 B. Sectoral and Institutional Context.................................................................................................................. 22 C. Relevance to Higher Level Objectives ............................................................................................................ 26 D. Multiphase Programmatic Approach (MPA) .................................................................................................. 28 II. PROJECT DESCRIPTION ........................................................................................................................... 37 A. Project Development Objective (PDO) ........................................................................................................... 37 B. Components ................................................................................................................................................... 37 C. Beneficiaries ................................................................................................................................................... 40 D. Rationale for Bank Involvement and Role of Partners ................................................................................... 40 E. Lessons Learned and Reflected in the Project Design.................................................................................... 41 III. IMPLEMENTATION ARRANGEMENTS ..................................................................................................... 44 A. Institutional and Implementation Arrangements .......................................................................................... 44 B. Results Monitoring and Evaluation Arrangements ........................................................................................ 47 C. Sustainability .................................................................................................................................................. 48 IV. PROJECT APPRAISAL SUMMARY ........................................................................................................... 49 A. Technical, Economic and Financial Analysis ................................................................................................... 49 B. Fiduciary ......................................................................................................................................................... 53 C. Safeguards ...................................................................................................................................................... 55 V. KEY RISKS............................................................................................................................................... 58 VI. RESULTS FRAMEWORK AND MONITORING ............................................................................................ 63 ANNEX 1: DETAILED PROJECT DESCRIPTION ................................................................................................ 65 ANNEX 2: PROJECT COSTS .......................................................................................................................... 84 ANNEX 3: IMPLEMENTATION SUPPORT PLAN ............................................................................................. 87 Attachment 1: Summary Of Project Procurement Strategy For Development ................................................ 102 ANNEX 4: STAKEHOLDER ENGAGEMENT AND SOCIAL RISK MANAGEMENT ................................................ 104 9 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) DATA SHEET BASIC INFORMATION Project Name: WEST AFRICA UNIQUE IDENTIFICATION FOR REGIONAL INTEGRATION AND INCLUSION (WURI) Project ID: MPA Program Name: WEST AFRICA UNIQUE IDENTIFICATION FOR REGIONAL P161329 INTEGRATION AND INCLUSION (WURI) Phase 1 Borrower Country Responsible Agency Contact Information Mr. Teï KONZI Nigeria ECOWAS Commission Commissioner, Trade, Customs, Free Movement and Tourism + 234 808 343 6964 Republic of Office of the Prime Minister (PMO or Mr. Khader BARRY Guinea Special Adviser to the Prime Minister Guinea Primature) + 224 628289496 Republic of Mr. Diakalidia KONATE Côte Côte Office National d’Identification (ONI) Directeur Général, ONI d'Ivoire d'Ivoire + 225 07571414 Financing Instrument Investment Project Finance Modality [ ] IPF with Disbursement Linked Indicators [ ] IPF with Contingent Emergency Response Component [ ] Project Based Guarantee [ x ] Multiphase Programmatic Approach [ ] Regional project [ ] Situations of Urgent Need of Assistance or Capacity Constraints [ ] Financial Intermediaries Closing Date: MPA Program Expected Expected Guarantee Approval Date: Expiration Date (for Guarantee Closing date: 05-June-2018 03-July-2024 Operation, only): 03-July-2028 10 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) Bank/IFC/MIGA Collaboration Environmental Assessment Category: B - Required (Yes/No) Proposed MPA Program Development Objectives (PrDO): Increase the number of persons in participating countries who have government-recognized proof of unique identity that facilitates access to services. Project Development Objectives (PDO): For phase 1 of the Project: Increase the number of persons in the Republic of Côte d’Ivoire and the Republic of Guinea who have government-recognized proof of unique identity that facilitates their access to services. Project Components: Component Name Cost (US$, millions) Component 1: Strengthening the legal and institutional framework 9.60 Component 2: Establishing robust and inclusive foundational ID systems 100.85 Component 3: Facilitating access to services through fIDs 11.65 Project Organizations: Borrower: Republic of Côte d'Ivoire Republic of Guinea Implementing Agency: ECOWAS Commission Office National de l'Identification (ONI) Office of the Prime Minister (PMO or Primature) MPA FINANCING O Total MPA Program Of which Bank Financing (IBRD/IDA): US$317.1m Financing (Estimated): US$317.1m FINANCING DATA (in US$, million) Total Project Of Which Bank Financing Project Financing Gap: Financing: (IBRD/IDA): US$317.1m US$317.1m 11 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) PROJECT FINANCING DETAILS (in US$, millions) Financing Source Details Financing Source Amount (in US$, millions) International Development Association (IDA) 92.50 IDA Grant 29.85 Total 122.10 Implemented by Public Sector World Bank Group Financing IBRD IDA (Credit or Grant), By IDA 18 Window World Bank Guarantees IFC Own Resources/Mobilisation MIGA Non-World Bank Group Financing Trust Funds Government Resources Other Sources (IFIs, Bilaterals, Foundations, Private) Private Sector Investors/ Amount Debt Amount (in US$, millions) Shareholders Equity (in US$, millions) IFI Debt Government Contibution IBRD Government resources IDA (Credit or Grant) IBRD Trust Funds IDA (Credit or Grant) IFC A Loans Trust Funds Other IFIs Other Donors Commercial Debt Non-Government Contributions Guaranteed Private Sector Equity Unguaranteed IFC Equity IFC B Loans Other IFIs Other Debt Mezzanine Debt Payment Security/Guarantee : [ ] Yes [ ] No Total Expected Disbursements of Bank Financing (in US$, millions) Fiscal Year 2018 2019 2020 2021 2022 2023 2024 Absolute: 0.2 4.52 8.15 16.99 27.59 31.35 21.9 Cum. Disb.: 0.2 4.72 12.87 29.87 57.46 88.81 122.1 12 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) PROJECT INSTITUTIONAL DATA Contributing Practice Areas: Finance, Competitiveness & Innovation Practice Area (Lead): Social Protection & Jobs Health, Nutrition & Population Transport & Digital Development Gender Tag Does the Project plan to undertake any of the following? a. Analysis to identify project-relevant gaps between males and females, especially in light of country gaps identified through SCD and CPF (Yes/No) NO b. Specific action(s) to address the gender gaps identified in (a) and/or to improve women or men's empowerment (Yes/No) NO c. Include Indicators in Results Framework to monitor outcomes from actions identified in (b) (Yes/No) NO Climate Change and Disaster Screening This operation has been screened for short and long-term climate change and disaster risks (Yes/No) YES Climate Change Co-benefits (When applicable): N/A Corporate Results Indicators: If there are Corporate Results Indicators (CRIs) relevant to this Project, are they included in the Results Framework? (Yes/No): N/A Risk Category Rating 1. Political and Governance z Substantial 2. Macroeconomic z Moderate 3. Sector Strategies and Policies z High 4. Technical Design of Project or Program z High 5. Institutional Capacity for Implementation and Sustainability z High 6. Fiduciary z Substantial 7. Environment and Social z Substantial 8. Stakeholders z High 9. Other (Lack of Technology Neutrality and Vendor Lock-in) z High 10. Overall z High 13 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) PROJECT COMPLIANCE Safeguard Policies Triggered by the Project The project is rated as Safeguards Category B consistent with the provision of OP/BP 4.01 Environmental Assessment. The Project is expected to have minimal to no adverse environmental impacts as no civil works are financed. No other environmental or social safeguards policy is triggered. Legal Covenants The Republic of Côte d'Ivoire: 1. Shall, pursuant to Section I.A of Schedule 2 of the Financing Agreement, not later than three (3) months after the Effective Date, cause its Ministère de l'Economie et des Finances to enter into a written agreement with the Inspection General des Finances (IGF) to manage the internal audit function of the Project and conduct periodic reviews of Project transactions. 2. Shall, pursuant to Section I.A.1 of Schedule 2 of the Financing Agreement, not later than one (1) month after the Effective Date, cause ONI to recruit, and thereafter maintain, a senior social specialist; not later than two (2) months after the Effective Date, recruit, and thereafter maintain, an accountant; and not later than three (3) months after the Effective Date, recruit, and thereafter maintain: (i) an assistant financial management officer, and (ii) a grievance redress mechanism (GRM) assistant specialist; all with qualifications, and under Terms of Reference (ToRs), satisfactory to the Association. 3. Shall, pursuant to Section I.A.2 of Schedule 2 of the Financing Agreement, not later than two (2) months after the Effective Date, cause ONI to install, and thereafter maintain, an accounting software for the Project, in a manner acceptable to the Association. 4. Shall, pursuant to Section I.B.1 of Schedule 2 of the Financing Agreement, cause ONI, not later than two (2) months after the Effective Date, prepare and adopt a Project Implementation Manual (PIM), in form and substance satisfactory to the Association. 5. Shall, pursuant to Section I.D.1 of Schedule 2 of the Financing Agreement, not later than three (3) months after the Effective Date, prepare and thereafter disclose a Social Assessment and Management Plan and a Stakeholder Engagement Plan, in form and substance satisfactory to the Association (“Safeguard Instruments”), and implement the Project in accordance with the Safeguard Instruments. 6. Shall, pursuant to Section I.D.3 of Schedule 2 of the Financing Agreement: (i) by not later than three (3) months after the Effective Date, establish, and thereafter maintain throughout the period of implementation of the Project, a GRM, satisfactory to the Association, for the management of complaints related to the Project; and (ii) ensure that adequate measures, satisfactory to the Association, are put in place to ensure that all aspects of Project implementation are carried out in an inclusive, non-discriminatory and participatory manner. 14 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) 7. Shall, pursuant to Section I.A.3 of Schedule 2 of the Financing Agreement, not later than four (4) months after the Effective Date, cause ONI to recruit, and thereafter maintain, an external auditor, with qualifications and under ToR, satisfactory to the Association. 8. Shall, pursuant to Section I.D.5 of Schedule 2 of the Financing Agreement, not later than six (6) months after the Effective Date, recruit and maintain an independent third party with the responsibility of oversight of the use of fID system, with qualifications and under ToRs satisfactory to the Association. 9. Shall, pursuant to Section I.B.2 of Schedule 2 of the Financing Agreement, carry out the Project in accordance with the PIM, and shall not amend the PIM without the prior written approval of the Association. 10. Shall, pursuant to Section I.C of Schedule 2 of the Financing Agreement, develop and conduct Trainings, select trainees, and provide reports, all in form, substance, and process satisfactory to the Association. 11. Shall, pursuant to Section I.D.2 of Schedule 2 of the Financing Agreement, ensure that adequate information on the implementation of the Safeguards Instruments is suitably included in the Project Reports (and promptly in a separate report whenever the circumstances warrant), including details of: (i) measures taken in furtherance of the Safeguards Instruments; (ii) conditions, if any, which interfere or threaten to interfere with the smooth implementation of the Safeguards Instruments; and (iii) remedial measures taken or required to be taken to address such conditions. 12. Shall, pursuant to Section I.D.4 of Schedule 2 of the Financing Agreement, ensure that all technical assistance and that the registration campaign conducted under the Project, shall only be undertaken pursuant to ToRs, reviewed and found satisfactory by the Association, such ToRs ensuring that the technical assistance takes into account, and calls for application of, the Association’s environmental and social safeguards policies, as well as the Recipient’s own laws relating to the environment and social aspects. 13. Suspension Clause: Pursuant to Section 4.01 of the Financing Agreement, the Association may suspend the Project in the event that the Recipient does not adopt a fID system law and/or its related regulations, and, after such adoption, the System and/or its related regulations have been amended, suspended, abrogated, repealed, or waived so as to affect materially and adversely the achievement of the objectives of the Project. The Republic of Guinea: 14. Shall, pursuant to Section I.A.1 of Schedule 2 of the Financing Agreement, maintain throughout the period of Project implementation the PIU to run the day-to-day management of the Project, in a form and with terms of reference, functions, composition, mandate, staffing, and adequate resources satisfactory to the Association, and as further described in the PIM. To this end, the Recipient shall: not later than (1) one month after the Effective Date recruit, and thereafter maintain, a senior social development specialist; not later than three (3) months after the Effective Date, recruit, and thereafter maintain: (i) a financial management officer; (ii) an accountant; not later than (1) one month after the Effective Date recruit, and thereafter maintain (i) two (2) procurement specialists; and (ii) a grievance redress mechanism assistant specialist; all with qualifications and under ToRs satisfactory to the Association. 15 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) 15. Shall, pursuant to Section I.A.2 of Schedule 2 of the Financing Agreement, not later than two (2) months after the Effective Date, install and, thereafter maintain, an accounting software for the Project, in a manner acceptable to the Association. 16. Shall, pursuant to Section I.B.1 of Schedule 2 of the Financing Agreement, not later than two (2) months after the Effective Date, prepare and adopt a PIM, in form and substance satisfactory to the Association. 17. Shall pursuant to Section I.A.3 of Schedule 2 of the Financing Agreement, not later than three (3) months after the Effective Date, recruit and, thereafter maintain, an internal auditor, with qualifications and under ToRs satisfactory to the Association. 18. Shall, pursuant to Section I.D.1 of Schedule 2 of the Financing Agreement, not later than three (3) months after the Effective Date, prepare and thereafter disclose a Social Assessment and Management Plan and a Stakeholder Engagement Plan, in form and substance satisfactory to the Association (“Safeguard Instruments”), and implement the Project in accordance with the Safeguard Instruments. 19. Shall, pursuant to Section I.D.3 of Schedule 2 of the Financing Agreement: (i) by not later than three (3) months after the Effective Date, establish, and thereafter maintain throughout the period of implementation of the Project, a GRM, satisfactory to the Association, for the management of complaints related to the Project; and (ii) ensure that adequate measures, satisfactory to the Association, are put in place to ensure that all aspects of Project implementation are carried out in an inclusive, non-discriminatory and participatory manner. 20. Shall, pursuant to Section I.A.2 of Schedule 2 of the Financing Agreement, not later than five (5) months after the Effective Date, recruit and, thereafter maintain, an external auditor, with qualifications and under ToRs satisfactory to the Association. 21. Shall, pursuant to Section I.D.5 of Schedule 2 of the Financing Agreement, not later than six (6) months after the Effective Date, recruit and maintain an independent third party with the responsibility of oversight of the use of fID system, with qualifications and under ToRs satisfactory to the Association. 22. Shall, pursuant to Section I.B.2 of Schedule 2 of the Financing Agreement, carry out the Project in accordance with the PIM, and shall not amend the PIM without the prior written approval of the Association. 23. Shall, pursuant to Section I.C of Schedule 2 of the Financing Agreement, develop and conduct Trainings, select trainees, and provide reports, all in form, substance, and process satisfactory to the Association. 24. Shall, pursuant to Section I.D.2 of Schedule 2 of the Financing Agreement, ensure that adequate information on the implementation of the Safeguards Instruments is suitably included in the Project Reports (and promptly in a separate report whenever the circumstances warrant), including details of: (i) measures taken in furtherance of the Safeguards Instruments; (ii) conditions, if any, which interfere or threaten to interfere with the smooth implementation of the Safeguards Instruments; and (iii) remedial measures taken or required to be taken to address such conditions. 25. Shall, pursuant to Section I.D.4 of Schedule 2 of the Financing Agreement, ensure that all technical assistance and that the registration campaign conducted under the Project, shall only be undertaken pursuant to ToRs reviewed and found satisfactory by the Association, such ToRs ensuring that the technical assistance takes into account, and calls for application of, the Association’s environmental and social safeguards policies, as well as the Recipient’s own laws relating to the environment and social aspects. 16 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) 26. Shall, pursuant to Section I.A.5 of Schedule 2 of the Financing Agreement, not later than 30th June 2021, designate or establish an independent agency to be responsible for matters of identity and for the fID system, in form and mandate satisfactory to the Association. 27. Suspension Clause: Pursuant to Section 4.01 of the Financing Agreement, the Association may suspend the Project in the event that the Recipient does not adopt a fID system law and/or its related regulations, and, after such adoption, the fID system law and/or its related regulations have been amended, suspended, abrogated, repealed, or waived so as to affect materially and adversely the achievement of the objectives of the Project. The ECOWAS Commission: 28. Shall, pursuant to Section I.A.1 of Schedule 2 of the Financing Agreement, maintain throughout the period of Project implementation the PIU to run the day-to-day management of the Project, in a form and with terms of reference, functions, composition, mandate, staffing, and adequate resources satisfactory to the Association, and as further described in the PIM. 29. Shall, pursuant to Section I.A.1 of Schedule 2 of the Financing Agreement, not later than (2) two months after the Effective Date, recruit, and thereafter maintain, an accountant and a procurement specialist, both with under Terms of Reference and with qualifications satisfactory to the Association. 30. Shall, pursuant to Section I.B.1 of Schedule 2 of the Financing Agreement, not later than two (2) months after the Effective Date, prepare and adopt a PIM in form and substance satisfactory to the Association. 31. Shall, pursuant to Section I.C of Schedule 2 of the Financing Agreement, develop and conduct Trainings, select trainees, and provide reports, all in form, substance, and process satisfactory to the Association. Conditions Description of Conditions: N/A PROJECT TEAM Bank Staff Name Role Specialization Unit Team Leader (ADM Qaiser M. Khan SPJ, TTL (Regional) GSP01 Responsible) Samia Melhem Team Leader ICT, TTL (Regional) GTD09 Tina George Team Leader SPJ, TTL (Regional, ECOWAS) GSPGL ICT, Country TTL (Guinea, Côte Marc Jean Yves Lixi Team Member GTD11 d'Ivoire) 17 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) Laura B. Rawlings Team Member SPJ, Former TTL GSP01 SPJ, TTL (Engaging Vulnerable Emily Weedon Chapman Team Member GSP08 Groups) Conrad C. Daly Team Member Sr. Legal Consultant (Regional) GTD12 Christopher Boyd Tullis Team Member SPJ (Regional) GSP07 Procurement Specialist(ADM Procurement Coordinator Xiaoping Li GGOPF Responsible) (Regional) Financial Management Aissatou Diallo FM Coordinator (Regional) WFACS Specialist Alexandra C. Bezeredi Social Safeguards Specialist Social Safeguards (Regional) GSU01 Environmental Safeguards Abdoulaye Gadiere Environment Safeguards GEN07 Specialist Saba N. M. Gheshan Counsel Lawyer (Regional) LEGAM Issa Thiam Team Member Finance Officer WFACS Adebayo Adeniyi Team Member Procurement (ECOWAS) GGOPA Akinrinmola Oyenuga Team Member FM (ECOWAS, Nigeria) GGOAS Akinyele Alpha Mamoudou Bah Team Member Procurement (Guinea) GGOPF Anita Mittal Team Member SPJ (Delivery Systems) GTD12 Arcade Bigirindavyi Team Member Procurement, Niger GGOPF David Satola Team Member Legal Adviser (Regional) ICOIO Devarakonda Priyanka Team Member SPJ (Economic Analysis) GSP08 Kanth Gernot Brodnig Social Safeguards Specialist Social Safeguards GSU01 Isadora Nouel Cordido Team Member Program Assistant (Regional) GSP08 FM (Côte d'Ivoire, Burkina Jean Charles Amon Kra Team Member GGOAW Faso) Josue Akre Team Member FM (Niger) GGOAW Kadidiatou Bah Team Member Team Assistant (Côte d'Ivoire) AFCF2 18 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) Kameshwari Akella Team Member ID4D, Analyst GTD12 Chandra Maria Elena Garcia Mora Social Safeguards Specialist Social Safeguards OPSES Marie Roger Augustin Team Member PPA Legal LEGAM Maurice Adoni Procurement Specialist Procurement (Côte d'Ivoire) GGOPF Mohamed El Hafedh Team Member Procurement (Burkina Faso) GGOPF Hendah Racky Dia Camara Team Member Team Assistant (Guinea) AFMGN Robert Palacios Team Member SPJ, Economic Analysis GSPGL Tahirou Kalam Team Member FM (Guinea) GGOAW Vasumathi Anandan Team Member SPJ (Delivery Systems) GSPGL SPJ (Engaging Vulnerable Victoria Esquivel Korsiak Team Member GSP07 Groups) Vivian Obianujunwa Team Member Team Assistant (Nigeria) AFCW2 Mbusu Vyjayanti T. Desai Team Member ID4D, Program Manager GTD12 19 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) MAIN DOCUMENT I. STRATEGIC CONTEXT A. Regional Context 1. Roughly 40 percent of Sub-Saharan Africa (SSA)—approximately 502 million people—lack official proof of identification 18 and, consequently, face significant barriers to accessing critical services and becoming full members of society. 19 Exclusion is worst for the poorest. Identification can serve as a key enabler for eradicating poverty and for achieving a broad range of development outcomes. Target 16.9 of the Sustainable Development Goals (SDGs) recognized the centrality of proof of identification in assuring an inclusive world: to “provide legal identity for all, including birth registration” by 2030. 2. Increasing access to identity and building ID systems is beneficial at all levels—the individual, the state and the regional. Without government-recognized credentials, such as birth certificates, unique identification numbers (UNIs) or other identification (ID) credentials, people are frequently denied access to rights and to public services; the most vulnerable people—those who might otherwise benefit most from social protection and jobs (SPJ) services—are the most adversely affected. Reciprocally, governments also struggle to authenticate and deliver services to the unregistered and unidentified. Further, regional interoperability of IDs could help to drive down costs, as well as facilitate integration, encourage the movement of peoples and goods, grow trade and improve security, with benefits accruing to both individual member states and to the ECOWAS region at large. Wuri, a West African counting game, is, like this Project, about “making everyone count”. 20 3. While the risks of engaging in this area are great, the risks of not engaging are greater still. Advancing identification for all facilitates the delivery of services such as social protection, women’s empowerment, financial inclusion, governance, healthcare, digital development and humanitarian assistance. However, when paired with the cyberspace—identity, a contentious matter unto itself—the risks increase exponentially. No matter how it is understood, cyberspace has transformed the world and humankind’s way of being. It has created a “virtual” space parallel to the “real”, physical world, with great implications for the “real” world, and, indeed, for what “real” means. 21 Ignoring the issue of lack of identification means that those already isolated will find themselves increasingly limited in how they can conduct their “real” world affairs and potentially entirely deprived of any real virtual presence. 4. One of two different perspectives is typically taken for ID systems: either a broad, nationwide ID perspective, or a narrow, sectoral one, wherein functional IDs are used to deliver services, and which thus leads to a fragmented, untrustworthy identification landscape with substantial inefficiencies and costs for both the 18 As the project is a technical one, and is developed on the basis of a precise set of definitions and understandings, a detailed glossary of terms has been prepared and placed at the beginning of the document (see Glossary, above). 19 Identification for Development. 2017. “Identification for Development Global Dataset”. Dataset. Washington, DC: World Bank Group. https://data.worldbank.org/data-catalog/id4d-dataset. 20 Wuri, one of the most social of games, is also one of the most ancient board games in the world; in other parts of the world, it is called congkak (Malaysia, Indonesia), pallanguzhi (South India) or mancala (from naqala in Arabic). 21 World Bank. 2017. Combatting Cybercrime: Tools and Capacity Building for Emerging Economies. Book. Washington, DC: World Bank Group. www.combattingcybercrime.org. 20 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) private and public sectors. Single-use, functional IDs are costly, administratively inefficient and undermine effectiveness, with the negative effects being disproportionately borne by the poor and vulnerable groups. Further, multiple, parallel ID systems result in poor data, confusion and duplicative spending of scarce resources. In 2015, one-off voter registration systems cost African states approximately US$1.4 billion. These costs include the production of biometric ID cards. Costs typically range from US$5–10 per card but can go as high as US$46 (in Côte d’Ivoire); in Nigeria, a one-off biometric, voter-registration exercise cost US$8.6 per voter and totaled approximately US$627 million, yet registered only 70 million voters of its roughly 95 million eligible voters (less than 74 percent). 22 5. Foundational ID (fID) systems provide government-recognized ID credentials (fIDs) upon which both the public and private sector can subsequently rely for transactions and delivery. Typically, fID systems sync with civil registration (CR) systems and interoperate with sectoral systems (e.g., SPJ, health, education, financial services, population, travel), without connoting legal status. 23,24 Robust fID systems take a basic set of an individual’s attributes—such as biometrics and biographic data that exclusively describe that person—and randomly assign an unintelligible UNI. Critically, fID systems are underpinned by a robust legal and institutional framework. fID and CR systems together compose a fID ecosystem. 6. Roughly 53 percent of the population of the ECOWAS region—about 196 million people—are unregistered and do not have proof of identification. 25 ECOWAS was founded with the goal of promoting economic integration and 70 percent of all ECOWAS migrants travel within the region. Côte d’Ivoire is the largest host state, with over 2.3 million non-Ivoirians present in its territory, and is the largest host to Guineans of any ECOWAS member state. 26 ECOWAS is also host to large populations of displaced and stateless persons due to historic and ongoing fragility. Nearly half of ECOWAS member states were classified as Fragile Situations in FY18 by the World Bank. 27 While inherent difficulties in measuring stateless populations lead to substantial variations, the region hosts approximately 2.5 million internally displaced persons and 290,000 refugees.28 The stateless 22 Gelb, Alan; and Diofasi, Anna. 2016. “Biometric Elections in Poor Countries: Wasteful or a worthwhile investment?”. Article. Center for Global Development. https://www.cgdev.org/sites/default/files/biometric-elections-poor-countries-wasteful-or-worthwhile- investment.pdf. 23 For population statistics in Nigeria, see WB ID4D Global Dataset (2017). 24 Some legal identification systems, such as the national ID programs of Peru and Pakistan, are linked to national status, while others are not. By contrast, India’s Aadhaar system—"aadhaar” means “foundation” or “base”—has de-linked the concept of nationality from identification in order to establish the uniqueness of the country’s 1.2 billion residents and create a platform for secure authentication by third parties for service delivery. See Gelb & Clark (2013). 25 WB ID4D Global Dataset (2017). 26 Awumbila, Mariama; Benneh, Yaw; Teye, Joseph; and Atiim, George. 2014. Across Artificial Borders: An Assessment of Labour Migration in the ECOWAS Region. Report. African, Caribbean, and Pacific (ACP) Observatory on Migration. https://publications.iom.int/system/files/pdf/ecowas_region.pdf?language=en. 27 Côte d’Ivoire, Gambia, Guinea-Bissau, Liberia, Mali, Sierra Leone and Togo are classified as fragile states. 28 UNHCR. 2018. “2018 Planning Summary - West Africa.” Factsheet. UNHCR. http://reporting.unhcr.org/sites/default/files/pdfsummaries/GA2018-WestAfrica-eng.pdf. 21 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) population in Côte d’Ivoire alone is 700,000 people, with a further 750,000 people being at risk of statelessness in the region. 29,30 B. Sectoral and Institutional Context 1. Key Benefits of fID Systems 7. Establishing fID systems that are mutually recognizable across ECOWAS member states would yield both domestic and regional benefits due to free movement, as well as a host of other services, from SPJ to finance and health. fID systems can reduce overall costs to government and to beneficiaries by eliminating unnecessary spending on fragmented functional ID systems. For example, by relying on fID systems to provide government-recognized IDs (i.e., fIDs) for deduplication of individuals and authentication at the point of service delivery, social safety net programs could focus on the processes of outreach, intake and registration, eligibility assessment, decisions on registration of beneficiaries and on benefits and service packages, and managing data on beneficiaries. 8. Reliance on fID systems improves HD- and SPJ-program service delivery, particularly to women 31, children and persons with disabilities.32 Through fID systems, government-recognized IDs can be issued to the entire population, therein improving access to, and quality of, frontline programs, especially when UNIs are issued at the time of birth. It can greatly improve the efficiency of SPJ programs, such as cash transfers and pensions, as well as reduce errors of inclusion and exclusion, and improve monitoring and resolution of error, fraud and corruption (EFC). As such, assistance is more likely to reach intended beneficiaries. For example, Pakistan’s national ID system underpinned the rollout of a cash transfer program for poor women, therein enabling a 94 percent increase in female enrolments between 2008 and 2014 33; as a result of this transfer, households spent more on nutrition and on child education, and women’s household decision-making increased markedly. 34, 35 Health sector programs have particularly benefited from the use of UNIs, which have increased coverage, facilitated inter-agency cooperation and improved management and treatment of illnesses, both chronic and acute. fID systems can help monitor disease outbreaks (as in the case of Ebola) and facilitate cross-border emergency responses by aggregating and sharing anonymized patient-level data (e.g., cause of death) across 29 Manby, Bronwen. 2015. “Nationality, Migration and Statelessness in West Africa: A study for UNHCR and IOM”. Report. http://www.unhcr.org/ecowas2015/Nationality-Migration-and-Statelessness-in-West-Africa-REPORT-EN.pdf. 30 Adjami, Mirna. 2015. “Statelessness and Nationality in Côte d’Ivoire: A Study for UNHCR”. Report. http://www.refworld.org/docid/58594d114.html (noting that Côte d’Ivoire country has the highest population of people affected by statelessness in the sub-region). 31 Dahan, Mariana; and Hanmer, Lucia. 2015. “The Identification for Development Agenda: Its Potential for Empowering Women and Girls”. Report. Washington, DC: World Bank. https://openknowledge.worldbank.org/bitstream/handle/10986/22795/The0identifica0s000background0paper.pdf?sequence=1&isAllow ed=y. 32 Hanmer, Lucia; and Elefante, Marina. 2016. “The Role of Identification in Ending Child Marriage”. Report. Washington, DC: World Bank Group. http://documents.worldbank.org/curated/en/130281472492551732/pdf/107932-WP-P156810-OUO-9-Child-Marriage.pdf. 33 Cheema, Iftikhar; Hunt, Simon; and Javeed, Sarah; Lone, Tanya; and O’Leary, Sean. 2016. “Benazir Income Support Programme: Final Impact Evaluation Report”. Report. Oxford Policy Management. http://bisp.gov.pk/wp- content/uploads/2017/02/BISP_FinalImpactEvaluationReport_FINAL-5.pdf. 34 Identification for Development. 2017. “Making Everyone Count”. Pamphlet. Washington, DC: World Bank Group. http://pubdocs.worldbank.org/en/726141507833458171/ID4DBrochure101217.pdf. 35 World Bank. 2016. “Pakistan: Building Equality for Women on a Foundation of Identity”. Blog. Washington, DC: World Bank Group. http://www.worldbank.org/en/news/feature/2016/02/04/pakistan-building-equality-for-women-on-a-foundation-of-identity. 22 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) communities and borders, thereby helping countries to tackle pandemics, especially in high-migration areas. 36 Botswana, for example, has used its national ID to uniquely identify patients and enable an advanced monitoring system that has increased patient retention and facilitated evaluation and scale-up. 9. At the regional level, fID systems can be interoperable across borders, ensuring secure and seamless interactions for public and private sectors. fID systems can unleash a powerful cascade of public and private resources, enabling positive development outcomes. fID systems facilitate regional electronic-Know your Customer (eKYC) 37, while also pushing parallel movements to bolster cybersecurity 38 and to grow cyberspace opportunities 39. For instance, the European Union (EU) is obliging its member states to develop an interoperable, pan-EU, electronic identification and trust services (eIDAS) ecosystem that enables cross-border, electronic authentication with the same legal status as paper-based processes, regardless of which member state is the issuer. 40 Further, as the eIDAS system is outcome-oriented, each nation is empowered to take its own approach. 10. Building robust fID systems with authentication processes that allow for mutual recognition across the region is a multifaceted challenge. ECOWAS member states are all at different stages of design or development in (i) establishing their own robust legal and institutional frameworks, (ii) building systems to register and enroll individuals and (iii) enabling authentication processes for access to services through interoperability. 2. State of Legal and Institutional Frameworks in ECOWAS Member States 11. While legal and institutional frameworks across ECOWAS member states tend to be weak and fragmented, the regional trend is towards building the sufficiently-robust frameworks needed for reliable and trustworthy fID systems. Of the 15 ECOWAS member states 41, nine member states have specific data protection legislation, seven of which have also created a central data protection agency. 12. Relatedly, nine member states have specific, centralized agencies dealing with identification, seven of which have also passed national ID legislation (see Table 1). Fundamentally, the legal and institutional framework should guarantee data protection, individual privacy, non-discrimination and inclusion. On that basis, the institutional and governance arrangements must engender a culture of trust between the state and individual recipients. 36 Countries are better prepared to tackle pandemic diseases by information-sharing that aggregates anonymized patient-level data (e.g., cause of death) across communities and borders. Identification for Development. 2018. “The Role of Digital Identification for Healthcare: The Emerging Use Cases”. Washington, DC: World Bank Group. http://pubdocs.worldbank.org/en/595741519657604541/DigitalIdentification-HealthcareReportFinal.pdf. 37 “Know your customer” (KYC) is the mandatory, complete documentation process used by a business, especially banks and insurers, to identify and verify identity of its clients. Electronic KYC (eKYC) is when this process is conducted in a paperless fashion. 38 WB Cybercrime Toolkit (2017). 39 World Bank. 2016. World Development Report 2016: Digital Dividends. Book. Washington, DC: World Bank Group. http://documents.worldbank.org/curated/en/896971468194972881/pdf/102725-PUB-Replacement-PUBLIC.pdf. 40 European Commission. Regulation (EU) No. 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic identification and trust services for electronic transactions in the internal market and repealing Directive 1999/93/EC. http://eur- lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014R0910&from=EN. 41 Benin, Burkina Faso, Cabo Verde, Côte d’Ivoire, The Gambia, Ghana, Guinea, Guinea-Bissau, Liberia, Mali, Niger, Nigeria, Senegal, Sierra Leone and Togo; Morocco recently joined ECOWAS, although it is not acceded to full membership status. http://www.ecowas.int/member-states/. 23 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) Table 1: Legal and Institutional Frameworks for Identification and Data Protection ECOWAS Data Protection Data Protection National ID National ID Member States Legislation Agency Legislation Agency Benin 9 9 8 8 Burkina Faso 9 9 9 9 Cabo Verde 9 9 8 9 Côte d’Ivoire 9 9 9 9 The Gambia 9 8 8 9 Ghana 9 9 9 9 Guinea 9 8 8 8 Guinea-Bissau 8 8 8 8 Liberia 8 8 9 9 Mali 8 8 8 8 Morocco† 9 9 8 8 Niger 8 8 8 8 Nigeria 8 8 9 9 Senegal 9 9 8 8 Sierra Leone 8 8 9 9 Togo 8 8 8 9 † While Morocco’s ECOWAS membership has been approved in principle, it has not acceded to full membership status. 3. ID and CR Systems in ECOWAS Member States 13. Coverage of national IDs and birth registration remains low across ECOWAS member states (see Table 2). Where they exist, national ID systems are of poor quality, fragmented and wasteful. Civil registries capturing vital events (primarily birth, death, marriage and divorce) are largely paper-based, incomplete, insecure and often unreliable (e.g., suffering from poor management, deterioration, destruction). Civil registries and national ID systems tend not to be integrated. The mixture of often ad hoc, hybrid paper-and-digital-based registries prevents sustainable, quality recordkeeping. A regional reform would mitigate these concerns and benefit all ECOWAS member states. 24 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) Table 2: Birth Registration and ID Registration Coverage 42 Birth Registration National ID ECOWAS Population Member States Rate Coverage Paper/Digital Coverage Paper/Digital (Age 0-5) Benin 11,459,000 80.2% Paper 68% Paper Burkina Faso 19,173,000 76.9% Paper 36% Paper Cabo Verde 539,560 91% Digital 95% Digital Côte d’Ivoire 23,816,000 55% Paper 45% Digital The Gambia 2,120,000 52.5% Paper No data Digital Ghana 28,210,000 62.5% Paper 2.1% Digital Guinea 13,291,000 57.9% Paper No data Paper Guinea-Bissau 1,816,000 39% Paper 87% Paper Liberia 4,730,000 24% Paper No data Paper Mali 18,690,000 80.8% Paper No data Digital † Morocco 36,191,805 94% Digital 60% Digital Niger 21,564,000 63.9% Paper No data Paper Nigeria 191,836,000 29.8% Paper 6% Digital Senegal 15,410,000 73% Paper No data Digital Sierra Leone 7,396,000 78% Paper No data Paper Togo 7,606,000 77.9% Paper 9% Paper † While Morocco’s ECOWAS membership has been approved in principle, it has not acceded to full membership status. 4. State of Access to Services Authenticated through IDs in ECOWAS Member States 14. Across ECOWAS, access to services is greatly hindered by inadequate ID systems. Even when individuals are enrolled in a national ID program, additional sources may be required to prove identity, as these systems may be weak, paper-based and fail to guarantee uniqueness. In many countries, the principal form of government- recognized IDs is the birth certificate; however, even in such countries, not everyone has one, and, even when registered, not everyone receives one. Across ECOWAS member states, a host of obstacles—secondary acquisition costs (Côte d’Ivoire, Ghana, Togo), lack of parental motivation (Chad, Togo), distance (Nigeria 43), persistent conflict (Niger 44)—cause significant burdens and hinder identification. In Côte d’Ivoire, only 55 percent of the population (over the age of five) is registered, yet birth certificates are an annual prerequisite to school enrollment. 45 42 WB ID4D “ID for Healthcare” (2018). 43 In Nigeria, for instance, birth registration in rural areas (19 percent) is significantly lower than in urban areas (50 percent). 44 In conflict-affected regions, such as Niger Delta, birth registration rates are also considerably lower. 45 While the local chief may vouch for school enrolment up to elementary school, such is not acceptable proof of ID for secondary education or above. 25 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) 15. Lack of government-recognized IDs results in inefficient implementation of HD- and SPJ-programs. Without government-recognized IDs, beneficiaries are often unable to open bank accounts, and, where they can, have severe transaction limits imposed. Moreover, the proliferation of program-specific (functional) IDs hinders the consolidation of beneficiary registries. Creation of social registries is affected by the lack of government- recognized IDs (Côte d’Ivoire, Nigeria), making intake, registration and eligibility-assessment inefficient and difficult. Further, without government-recognized IDs, both crosschecking self-reported data for eligibility against administrative data, and authenticating beneficiaries at pay points, is cumbersome at best and frequently woefully inaccurate. C. Relevance to Higher Level Objectives 16. Building fID systems in participating ECOWAS member states that are interoperable will have substantial socioeconomic benefits at both the regional and national levels over the medium-to-long term. At the national level, a fID system will facilitate access to services, especially for those who are vulnerable and excluded, serving as a key enabler for social inclusion and poverty reduction. At the regional level, interoperable fID systems will enable a broader range of development outcomes in the region. 17. Interoperable fID systems will help ECOWAS achieve its vision of freedom of movement, substantially advancing its goal of economic integration across its member states, while also advancing a variety of cross- border development objectives. The ECOWAS vision is “the creation of a borderless region […] where the population enjoys free movement, has access to efficient education and health systems and engages in economic and commercial activities while living in dignity in an atmosphere of peace and security.” 46 The Protocol relating to Free Movement of Persons, Residence and Establishment puts forward a three-phased approach for achieving “complete freedom of movement” based on the right to enter, reside and establish economic activities in the territory of member states. 18. Step-by-step achievement of the ENBIC would be significantly advanced by a progressive, collaborative approach for interoperable fID systems, developed on the basis of common standards, among ECOWAS member states. In 2014, ECOWAS Heads of State substantially built upon the Free Movement Protocol when, in dialogue with national immigration authorities, they approved the ECOWAS National Biometric Identity Card (ENBIC) to be used as a regional travel document. 47 While the fID systems will collect only minimal data—less than that required for the ENBIC—all data capture will be done in accordance with ECOWAS technical specifications. As such, while the fIDs are not replacements for the ENBIC and do not of themselves confer any travel rights, they are significant stepping stones for each country to advance to rollout the ENBIC. Those desiring an ENBIC may provide their fIDs, as well as any other additional information required by the ENBIC. The EU’s experience with eIDAS offers important guidance on the utility of having a central authority act as facilitator (in that case, the European Commission). The ECOWAS Commission provides an effective means of shepherding through a coherent regional approach while also respecting country particularities and ownership, just as with eIDAS. 19. Regional integration would be facilitated by a progressive, collaborative approach for interoperable fID systems, developed on the basis of common standards, among ECOWAS member states. Interoperable fID 46 Economic Community of West African States. 29th May 1979. Protocol Relating to Free Movement of Persons, Residence and Establishment. A/P.1/5/79. http://documentation.ecowas.int/download/en/legal_documents/protocols/PROTOCOL%20RELATING%20TO%20%20FREE%20MOVEMEN T%20OF%20PERSONS.pdf. 47 Presently, Ghana and Senegal have already undertaken initiatives to deploy the ENBIC. 26 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) systems would especially benefit those requiring a low-cost credential for their daily needs. At the same time, basic, interoperable fID systems lay the basis for deeper regional integration and go especially far in building the basis of the digital economy upon which secure, electronic transactions can occur, supporting regional exchange of goods and services. fID systems advance a variety of cross-border development objectives, including financial inclusion, access to healthcare and education, and overall better access to public and private services at both the regional and national levels 48, and are basic prerequisites to building marketplaces along the lines of Alibaba or eBay in the region. For individuals, entrepreneurs or small and medium enterprises (SMEs), regional integration would dramatically reduce costs (e.g., logistics, transport, banking, cross-border commerce), especially on the region’s most frequently used routes and corridors. (See Annex 1 for country-specific objectives.) 20. Achieving a monetary union has long been another objective of ECOWAS and is intended to accompany a broader integration process that would include regional trade and common institutions. ECOWAS is moving towards greater trade integration. The West African Economic and Monetary Union (WAEMU) 49—the sub-regional bloc of Benin, Burkina Faso, Côte d'Ivoire, Guinea-Bissau, Mali, Niger, Senegal and Togo—is of growing significance. Efforts to create a pan-African Continental Free Trade Area (CFTA) 50 are also making significant headway (see Box 1). Interoperable fID systems could greatly facilitate such initiatives, significantly deepening financial-services integration across the region. Early discussions with WAEMU indicate interest in leveraging robust ECOWAS-wide interoperable fID systems to facilitate “know-your-customer” (KYC) financial requirements to be done through the Central Bank of West African States (BCEAO). Furthermore, financial services, including mobile money, can be offered more efficiently at a regional level, as recognized by the harmonization of rules in the CFA franc zone. Mutual recognition will particularly facilitate access to markets for smaller countries, helping trade and labor market integration. 21. Support to the ECOWAS Commission to achieve a regional framework for mobility and broader integration through fID systems is aligned with the World Bank Group’s forthcoming Africa: Regional Integration & Cooperation Assistance Strategy. In particular, it responds to Priority 3, namely, “Scale-up access to quality public services and entrepreneurship through complementary regional solutions” within the development of a regional ID system, has been identified as a flagship initiative. The Project also contributes to fulfilling two other Strategy objectives, namely, “Generate Economic Dynamism along Regional Economic Corridors” (Priority 1) and “Develop Functioning Regional Markets in ICT / digital, financial sector and mobility of skilled labor” (Priority 2). Box 1: Promoting Free Movement and Trade in Africa On 21st March 2018, a major milestone in the development of free movement and economic integration of the continent of Africa was set when senior representatives of fifty African states met at the 10th extraordinary summit of African Union in Kigali, Rwanda to discuss the launch of the African Continental Free Trade Area (AfCFTA) 51, a significant move towards creating a single continental market for goods and services. Of those meeting, 44 countries signed the agreement launching 48 Manby, Bronwen. 2016. “Identification in the Context of Forced Displacement”. Report. Washington, DC: World Bank Group. http://documents.worldbank.org/curated/en/375811469772770030/pdf/107276-WP-P156810-PUBLIC.pdf. 49 Union Economique et Monétaire Ouest Africaine (UEMOA). 2018. “West African Economic and Monetary Union”. Website. UEMOA. http://www.uemoa.int/en. 50 African Union. 21st Mar. 2018. “Continental Free Trade Area”. Website. African Union. https://au.int/en/ti/cfta/about. 51 African Union. 21st Mar. 2018. List of African Countries that signed the Establishment of the African Continental Free Trade Area (AfCFTA) at the 10th Extraordinary Session of the Assembly on the Launch of AfCFTA. Webiste. African Union. https://au.int/en/pressreleases/20180321/list-african-countries-signed-establishment-african-continental-free-trade. 27 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) the AfCFTA, 30 signed the Protocol on the Free Movement of Persons and 47 signed the Kigali Agreement. Following cloture of signature, the President of the African Union, Paul Kagame of Rwanda, made the following statement: “Today’s agenda is to adopt the Agreement establishing the African Continental Free Trade Area, as well as the Protocol on the Free Movement of Persons, and the Kigali Declaration, which expresses our unity in moving our continent forward. Taken together, these are surely to be counted among the most consequential actions that this Assembly has ever taken. The Continental Free Trade Area is the culmination of a vision set forth nearly 40 years ago in the Lagos Plan of Action, adopted by Heads of State in 1980. That undertaking led directly to the Abuja Treaty establishing the African Economic Community in 1991. Among the most important guidelines is the pre-eminent role of our Regional Economic Communities. They have been the model and the engine for Africa’s economic integration and they will continue to be. The task now is to ratify the African Continental Free Trade Area and the Protocol on the Free Movement of Persons, so that they may come into force as soon as possible. It is well understood that some Member States require additional time for internal procedures and consultations.” 52 The AfCFTA, as well as the larger efforts of the African Union and its Commission, are supported by the Bank. 53 The AfCFTA particularly allows for the expansion and integration beyond what is presently envisioned in the MPA. The MPA has been developed on the basis of a partnership with ECOWAS. Of all of the Regional Economic Communities (REC) in Africa, ECOWAS has been at the vanguard of the continental free movement agenda, notably by advancing its own Free Movement Protocol 54, which this MPA aims to support, notably by facilitating cross border trade individuals, entrepreneurs or SMEs. The newly-approved AfCFTA and accompanying Free Movement Protocol makes it possible for countries that are not ECOWAS members states to be brought into the MPA. While substantial interest in joining has already expressed interest, any new countries wishing to join the MPA—that is, beyond the five confirmed in this document—will only be allowed after receiving Board approval, as provided for under MPA guidelines. D. Multiphase Programmatic Approach (MPA) 1. Rationale for Using MPA 22. The Multiphase Programmatic Approach (MPA), approved by the Executive Directors of the World Bank Group on 21st July 2017, is an adaptive and programmatic approach that allows clients to structure a long, large or complex engagement as a set of linked operations (or phases) with intermediate, shorter-term objectives that contribute to an overall Program Development Objective (PrDO). 55 The MPA is the ideal instrument for channeling World Bank support to this Program for the following reasons: the Program is regional, being built around the ECOWAS Free Movement Protocol, but it also takes a series of national perspectives, allowing countries to join when they are ready, and to join at different implementation levels insofar as they subscribe to the same PrDO and take the same basic approach. The MPA also allows—and encourages—adjustments on the basis of learned implementation experience within the framework of the PrDO. Most importantly the MPA allows the Bank to quickly respond to changing client needs and timing, while maintaining overall objectives and approach. Under the MPA, the Board approves a maximum financing envelope for a program proposal—in this case, up to US$317.1 million equivalent—and authorizes Management to commit the financing in phases, over a given period, to achieve program outcomes. The financing of future phases is subject to then applicable IDA terms 52 Paul Kagame. 21st Mar. 2018. “Opening Address by President Paul Kagame at the 10th Extraordinary Summit of the African Union on AfCFTA”. https://au.int/en/speeches/20180321/opening-address-president-paul-kagame-10th-extraordinary-summit-african-union. 53 See, e.g., World Bank. 2018. Support for Capacity Development of the AUC and Other African Union Organs - P166316. Proposal. World Bank. 54 ECOWAS Free Movement Protocol. 55 Operations Policy and Country Services. World Bank. 2017. Multiphase Programmatic Approach. Report. Washington, DC: World Bank Group. https://hubs.worldbank.org/news/News%20Documents/MPA.pdf. 28 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) and to country borrowing limits. The approval of subsequent phases is delegated to Management, with each operation going through the same rigorous project preparation process and drawing heavily on the lessons learned from implementation of preceding phases. 23. The MPA’s programmatic approach provides consistency across ECOWAS member states, while also capitalizing on the transformational potential of creating a systematic and sequential framework for regional integration, thereby bringing together donor partners, government counterparts and the private sector. The MPA allows ECOWAS to remain engaged throughout the process, as member states successively develop their systems and progress towards achieving the PrDO. The MPA’s novel approach helps to draw partners together, therein yielding a sustained, sequentially-implemented, regional solution. While a similar end could be achieved through either a standalone IPF or PforR, or through a series of independent projects, such an approach would result in a “stop-and-go” approach that would likely fail to muster the sustained support of partners, and which would lose out on creating regional synergies, integration and cooperation. By operating under the structure of an MPA, the capacity gains and connections built with in-country Project Implementation Units (PIUs) can be readily called upon to facilitate implementation in other countries. Further, this approach gives assurances to ECOWAS and its member states of coherent, long-term, Bank support for the ID agenda, attracting complementary investments. The private sector will also benefit from the MPA and a regional, standards-based approach, encouraging greater competition to build new applications and services as layers on top of fID systems both at the national and regional level, thereby generating new jobs and opportunities. (See Annex 2 for these details.) Donor partners will benefit from a MPA approach by providing a platform upon which to base financing that is not covered under this operation, such as financing automated CR systems. 24. The MPA encourages greater adaptability in design and implementation, allowing countries to flexibly join the Program based on readiness, as well as allowing countries in later phases to incorporate lessons from initial phases. Currently five countries have confirmed their readiness to join the proposed MPA Program: Benin, Burkina Faso, Côte d’Ivoire, Guinea and Niger through letters of intent. Morocco, which has had its membership to ECOWAS approved in principle, though it is not a full member, is currently implementing its own fID system, supported by a standalone IPF operation. 56 Financing for other countries will be through subsequent phases, or through Additional Financing to the MPA Program, with Board approval depending on the needs and country situations. The MPA logic allows for a progressive, organic approach wherein states might engage as they are ready. Further, the progressive approach allows them to incorporate lessons learned, including system design, institutional arrangements, governance mechanisms, procurement, private partnerships and use of services. As such, the MPA encourages efficiencies and faster response to client needs. 25. The MPA’s progressive, harmonized approach will help countries to progressively achieve interoperable fID systems and policies based on common standards coordinated regionally by ECOWAS, with all parties learning from the others. Starting with Côte d’Ivoire and Guinea in phase 1, the MPA will build the fID systems in a manner compatible with common regional standards, to which other countries will progressively be added. For instance, the uniform capture of minimum biographic data (e.g., name, date of birth, address) and of specific biometric data (e.g., fingerprints, iris) by all participating countries, in standardized and commonly agreed upon data formats, paves the way for mutual recognition and regional integration. The MPA will also support capacity 56Tesliuc, Emil Daniel. 2017. Morocco - Identity and Targeting for Social Protection Project: P155198 - Implementation Status Results Report: Sequence 01. Washington, DC: World Bank Group. https://hubs.worldbank.org/docs/imagebank/pages/docprofile.aspx?nodeid=27942358. 29 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) building for the ECOWAS Department of Free Movement and Tourism (DFMT) and for the Department of Telecommunication and Information Technologies (DTIT), strengthening its ability to coordinate regionally, to facilitate knowledge exchange and to monitor implementation. 2. Program Results Chain† 26. By the end of the MPA in 2028, the Program aims to increase the number of persons in participating countries who have government-recognized proof of unique identity (i.e., fIDs) to 100 million beneficiaries, (i.e., 27 percent of the population in ECOWAS) facilitating their access services (see Figure 1). 27. The MPA aims to develop the necessary legal and institutional framework of participating ECOWAS member states, while also attaining close to universal coverage of fIDs. The Program aims to develop a comprehensive enabling legal and institutional framework at the heart of the fID system, which requires both (i) an enabling law that, among other things, supports an independent agency responsible for rolling-out and maintaining the fID system and (ii) a data protection and privacy law that provides the legal and institutional safeguards to support user-control of their data, and which is supported by an independent agency. As indicated in Table 1, above, several of the participating ECOWAS member states have already taken steps towards achieving these objectives. That said, while the laws and institutions exist in some circumstances, their mere existence— even where all of the necessary component elements are nominally present—is not sufficient. As such, the Program will undertake a qualitative review of those laws and institutions against a set of commonly-applied, good international practice standards to ensure that they include the necessary elements to provide effective support and safeguards. Structuring this work within an MPA will not only allow for case-by-case assessments, it will also facilitate collective, regional advancement and integration. In addition to building the necessary architecture, effective service delivery requires that the issued fIDs be rolled-out as widely as possible, with a particular focus on including the vulnerable. 30 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) Figure 1: Causal Results Chain for the Program PrDO: “Increase the number of persons in participating countries who have government-recognized proof of unique identity that facilitates their access to services” Outcomes/ Impact Gaps in legal, Interoperability mechanisms developed to facilitate access to key regulatory and services authenticated through IDs institutional Medium to x Key services linked to ID systems frameworks for Long Term foundational ID Results 100 million IDs by 2028 systems bridged Robust, inclusive foundational ID systems developed with x Legal framework authentication processes for mutual recognition across borders Short Term established x Beneficiaries with government-recognized IDs (including Women) Results Program Component 1: Program Component 2: Program Component 3: Strengthening the legal Inputs and institutional Establishing robust & inclusive Foundational ID Facilitating access to systems selected key services framework Review of Legal and Regulatory Strategy for linking service Civil Credential providers to ID systems Framework Registry fID system Issuance System system Integrating service delivery Institutional Capacity Building systems with ID systems for Implementing Agencies Procuring equipment for authentication at service ECOWAS - Regional Communications, grievance redress and access points engagement & interagency project management collaboration Communications and Outreach Leverage preexisting institutional and legislative framework, and other foundational systems Precursors such as Civil Registration † Critical Assumptions: x Political instability and fragility could hinder program progress in that country; x Autonomy of implementation agencies in participating countries is maintained; and x Public trust in government data collection and usage. 31 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) 3. Program Development Objective (PrDO) 28. The PrDO is to “Increase the number of persons in participating countries who have government- recognized proof of unique identity that facilitates access to services.” The Program will aim to provide government-recognized IDs for the fID system (i.e., fIDs) to all individuals in participating countries, irrespective of legal status. Progress is anticipated in the number of enrolled women, as well as in the number of previously- unrecognized individuals (that is, those not formerly having a government-recognized ID), which is expected to substantially overlap with the vulnerable population. Another result will be to link key services, such as social safety net programs, to the fID systems. Progress towards the PrDO will be measured through the following program-level outcome indicators: i. Legal Robustness: Development of foundational ID (fID) system enabling legal and institutional framework (including relevant data protection and privacy laws and a mandated ID agency and data protection agency), in keeping with regional standards and international good practices; ii. Technical Robustness: Development of fID system which generates UNIs, in keeping with international good practices; iii. Inclusion & Coverage: Number of direct project beneficiaries who have received a UNI (of which women); and iv. Access to Services: Number of national or regional functional public and private services linked to the fID system. 4. Program Framework 29. The MPA will employ a multi-borrower approach and will include at least two phases, each of which will run for at least 6 years from FY18 through FY28, with any country allowed to progressively join the Program once the first set of countries have been approved for financing (see Figure 2). The three key components of the Program—(i) strengthening the legal and institutional environment; (ii) establishing robust and inclusive fID systems; and (iii) facilitating access to services through fIDs—will be replicated by countries participating in subsequent phases. 32 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) Figure 2: Conceptual framework of a 10-year investment to build fID systems in West Africa 30. Phase 1 of the Program will include Côte d’Ivoire, Guinea and the ECOWAS Commission. Both countries are important gateways to landlocked countries of the Sahel, like Burkina Faso and Mali. They are also located in key economic corridors of West Africa and serve as important transportation and trade hubs, such as the Abidjan– Lagos corridor. Additionally, Côte d’Ivoire is a key member of the WAEMU zone, and could generate interest among other members of the monetary union for interoperable fID systems within the agreed ECOWAS framework. These issues are also all ECOWAS priorities. 31. Additional phases of the MPA will aim to add at least three other countries (see Table 3). Regional interest is great and it is anticipated to grow. The Program has received letters of intent from Burkina Faso, Benin and Niger. 32. Participating countries must adhere to the ID4D Principles, which would be reflected in the design and implementation (see Figure 5, page 69). 33 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) Table 3: Phases of MPA on Unique IDs for Regional Integration and Inclusion in West Africa Program To increase the number of persons in participating countries who have Development government-recognized proof of unique identity that facilitates their access to Objective (PrDO): services. IBRD, Estimated Estimated Estimated Phase Sequential or IPF IDA, Environmental Proposed DOs Approval Amount (US$ # Simultaneous or TF, and Social Year Mil) PforR PPP Risk Level To increase the number of persons in Côte d’Ivoire and Guinea who have government- 1 — IPF IDA FY18 Category B 122.1 recognized proof of unique identity that facilitate access at least one public service. To increase the number of persons in Benin, Burkina Faso and Niger who have government- 2 Simultaneous IPF IDA FY19 Category B 195.0 recognized proof of unique identity that facilitate access to access at least one public service. Estimated financing for the Program 317.1 33. Table 4 summarizes the overall distribution of costs among phase 1 countries and the ECOWAS Commission as well as between national and regional IDA and between credit/grant. Table 4: Regional and National Distribution of Financing for Phase 1 National IDA Regional IDA Country/Regional Total Entity Grant Credit Grant Credit (US$ Mil) (US$ Mil) (US$ Mil) (US$ Mil) (US$ Mil) Côte d’Ivoire – 22.4 – 45.0 67.4 Guinea 8.28 8.28 16.57 16.57 49.7 ECOWAS Commission – – 5.0 – 5.0 Total 122.1 34 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) 5. Learning Agenda 34. The MPA has the unique advantage of allowing for built-in, multilevel, phase-to-phase learning. Given that phase 1 countries (Côte d’Ivoire, Guinea) are at different stages of implementing the fID system, the two will provide significantly different lessons, learning that can be brought to bear in subsequent phases. Further, the MPA approach will enable increasingly nuanced risk management, as lessons are learned and experiences gained. Feedback will allow the team to adjust program details while maintaining program objectives. Understanding the most effective means of increasing enrollment in the fID system will be one of the key and immediate lessons learned. Proposed methods include mass-registration campaigns, walk-ins and possibly even subcontracting to the private sector, as was done in India. 57 Furthermore, registrations may also be undertaken at safety net service delivery points to avoid denial of service (for lack of IDs) of those most in need. 58 35. Lessons learned from phase 1 of the operation will be channeled to countries participating in phase 2, as facilitated through the ECOWAS Commission under Component 1.2 of the Project. Lessons learned will also be curated and financed through a proposed regional analytical task. The creation of a regional-level working group will provide a demonstration effect encouraging other ECOWAS member states to learn from initial phases. Targeted national and regional institutional capacity-building will ensure more efficient implementation. The capacity of the ECOWAS Commission to coordinate and harmonize fID initiatives is key to facilitating regional dialogue and to bolstering capacity. Furthermore, with the support of the Bank’s ID4D Program 59, lessons learned from global implementations will be shared with participating countries using various means (e.g., including videoconferences, seminars, presentations and knowledge sharing forums). 36. The MPA will produce a great diversity of lessons and approaches to a more robust design of the legal and technical components of the Project, and to assuring inclusion of the vulnerable: i. Even as they share a border and have many similar objectives for the fID system, the two phase 1 countries are at different stages of sophistication. Given that each may adopt a different approach to enacting their legal framework, they will yield-up different lessons that will facilitate work subsequent phases. The Program will closely monitor these experiences and share lessons with the ECOWAS community. ii. Service providers of social protection, health or education are at different levels of readiness in terms of linking to the fID systems. The Program will focus on social protection, and explore options for linking to one additional service in each country, assessing the efficiency and effectiveness of using fIDs and the benefits to their clients. Furthermore, lessons learned from international experience of linking fIDs to service providers indicate the potential for data misuse in the absence of beneficiary consent, capture by vested interests and EFC. Ongoing learning in 5 countries will collectively inform on where to improve, as well as creating opportunities to adjust program direction, policies and protocols, therein facilitating the maximization of administrative efficiencies and the effectiveness of service delivery. 57 Sathe, VIjay. 2014. “Managing Massive Change: India's Aadhaar, the World's Most Ambitious ID Project (Innovations Case Narrative: Project Aadhaar)”. Paper. MIT Press Journals. https://www.mitpressjournals.org/doi/pdf/10.1162/inov_a_00204. 58 Abraham, Ronald; Bennett, Elizabeth; Sen, Noopur; and Shah, Neil Buddy. 2017. “State of Aadhaar Report 2016–17”. Report. IDinsight. http://stateofaadhaar.in/wp-content/uploads/State-of-Aadhaar-Full-Report-2016-17-IDinsight.pdf. 59 Identification for Development. 2018. “ID4D”. Website. Washington, DC: World Bank Group. http://www.worldbank.org/en/programs/id4d#5. 35 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) iii. The national productive social safety net programs in both Côte d’Ivoire and Guinea will be the first functional users to rely on the fID systems, meaning that particular attention will be given to identifying the most effective and efficient approach to increasing registration in the fID system. The Program also aims to learn lessons from the development of an interoperability mechanism linking the fID system to service providers, while also assuring privacy, data protection and user-consent. iv. Many of the intended beneficiaries are invisible, whether due to vulnerability, living in less accessible areas or some other factor. In order to ensure inclusiveness, lessons pertaining to outreach to the vulnerable, communicating with those living in rural and remote areas to participate in mass- registration campaigns and updating, correcting data and addressing grievances will be particularly important. Box 2: International Lessons Learned on Sequencing Have Been Varied Various lessons have already been learned from international experiences. For the purposes of this Project, those of India, Estonia and the European Union (EU) are particularly informative: In India, the launch of Aadhaar, its fID system, was followed seven years later by the corresponding fID system law. 60 However, several essential elements, notably those pertaining to data protection and privacy, were not adequately reflected in that law notwithstanding the delay in legislating it. As a result, a series of constitutional challenges were brought, the most significant of which resulted in the Supreme Court’s landmark ruling that the right to privacy is a fundamental right protected by the Constitution of India. 61 In a rare, unanimous, nine-judge decision, with six separate and concurring judgements, the Court reversed its prior decisions and found that the right to privacy applies across the gamut of “fundamental” rights, including equality, dignity, speech, expression, life and liberty. The Court advised the Government to create a “robust regime of data protection ensuring a careful and sensitive balance between individual interests and legitimate concerns of the State […] (including) preventing the dissipation of social welfare benefits.” Further issues, notably pertaining to the absence of a legal framework for collection and safeguarding of biometric information, as well as the policy framework that effectively makes Aadhaar authentication mandatory for accessing a variety of public services, persist and are still set to be addressed in the Supreme Court. 62 Direct lessons can be learned regarding both specific elements for inclusion in a fID system law; that said, the Project does not want to risk unforeseen hindrances by over-correcting from the Indian experience by legislating something prematurely. In Estonia, ownership and usage rights of specific technology components associated with software and application programming interface (API) were not specified in the contracting stages, leading to litigation between the Government and the private vendor years on. Although Estonia has a robust legal and institutional framework, supported through well- established practices, service delivery was the primary objective at the time that the country’s ID system was built. Reliance was on a large procurement for a complete and integrated ID system. The MPA will, on the one hand, look to ensure that participating countries adopt open standards, open development and process transparency to avoid vendor lock-in; on the other hand, and in order to avoid any form of incidental lock-in, the MPA will look to construct a modular system, with smaller, individual and exchangeable components, rather than instituting systems through large, single procurements. 60 Government of India. 2016. Aadhaar (Targeted Delivery of Financial and other Subsidies, benefits and services) Act. No. 18 of 2016. https://uidai.gov.in/images/the_aadhaar_act_2016.pdf. 61 Puttaswamy v Union of India, Writ Petition (Civil) No. 494 of 2012 (24 Aug. 2017). http://supremecourtofindia.nic.in/supremecourt/2012/35071/35071_2012_Judgement_24-Aug-2017.pdf. 62 See, e.g., Vombatkere v. Union of India, Writ Petition (Civil) No. 829 of 2013. 36 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) The EU is in the process of developing a trust framework for pan-EU access to digital public services. 63 Its 2014 eIDAS Regulation creates an identity and service-provision ecosystem that enables mutual recognition and cross-border, pan-EU interoperability of digital public services. 64 By taking an outcome-oriented approach, eIDAS respects member state sovereignty, encouraging each state to act as creative, “laboratories” 65 that account for national preferences and particularities. The end result is a framework that allows member state systems to rely upon, and put trust in, electronic identity outputs of other member states without needing to question the legitimacy of, or control how, those other systems assure authenticity due to mutual recognition. The result is coherent, secure, pan-EU systems communications that facilitate the free movement of goods and services, on both a physical and digital level. The EU undertook learning exercises before launching eIDAS, notably the 2008 and 2012 STORK pilot projects, which offered technical solutions for cross-border interoperability using a variety of ID approaches from EU member states. 66,67 Separately, in addition to creating the eIDAS trust framework, the EU also implemented robust data protection and privacy rules, namely its General Data Protection Regulation (GDPR). 68 Designed to enable individuals to better control their personal data—whether collected in that individual’s private, public or professional role—, the GDPR sets a single, robust set of rules for application across the EU but with extra-territorial application. Importantly, the GDPR enters into force ahead of the deadline for notifying eIDAS systems. 69 II. PROJECT DESCRIPTION A. Project Development Objective (PDO) 37. The PDO for phase 1 of the Project is to “increase the number of persons in the Republic of Côte d’Ivoire and the Republic of Guinea who have government-recognized proof of unique identity that facilitates their access to services.” The target aims to cover 80 percent of the cohort of the population in phase 1 countries; approximately 22.5 and 12.5 million people in Côte d’Ivoire and in Guinea, respectively. 70 The outcome indicators for phase 1 of the Project will be the same as the PrDO indicators. B. Components 38. Each country-level operation of the proposed MPA is structured around three main components: (i) Strengthening the legal and institutional framework; (ii) Establishing robust and inclusive foundational ID systems (fIDs); and (iii) Facilitating access to services through fIDs. This section outlines the broad scope of each 63 European Commission. 2018. “Trust Services and eID”. Website. European Commission. https://ec.europa.eu/digital-single- market/en/trust-services-and-eid. 64 Regulation (EU) No. 910/2014. 65 The descriptor of states as “laboratories” was popularized in the opinion of Justice Louis Brandeis of the Supreme Court of the United States in New State Ice Co. v. Liebmann, 285 U.S. 262 (1932) (“It is one of the happy incidents of the federal system that a single courageous State may, if its citizens choose, serve as a laboratory; and try novel social and economic experiments without risk to the rest of the country.”). Although not directly applicable, the sentiment underlying the EU approach is similar to the one espoused in that case. 66 European Commission. 2018. “Secure Identity Across Borders Linked (STORK): Take your e-identity with you, everywhere in the EU”. Website. European Commission. https://ec.europa.eu/digital-single-market/en/content/stork-take-your-e-identity-you-everywhere-eu. 67 European Commission. 2018. “Secure Identity across Borders Linked (STORK) v. 2.0”. Website. European Commission. https://www.eid- stork2.eu. 68 Regulation (EU) No. 2016/679. 69 The GDPR enters into force on 25th May 2018, at which time the EU Data Protection Directive will cease to have effect. The eIDAS Regulation states that, by 29th September 2018, all online public services requiring electronic identification assurance corresponding to a level of “substantial” or “high” must be able to accept the notified eID schemes of other EU member states. 70 The combined figure of 35 million people is 80 percent of a population of 44 million (adjusted for growth) in countries at the end of Phase 1 (2024). 37 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) component as a generic framework to be applied and adjusted to the country-specific context. (See Annex 1 for a detailed description of how these frameworks are applied to Côte d’Ivoire and Guinea, MPA phase 1.) 1. PROGRAM COMPONENT 1 – STRENGTHENING THE LEGAL AND INSTITUTIONAL FRAMEWORK 39. Under this Component, the MPA will finance the preparation, development and implementation of the legal and institutional framework necessary to structure robust fID systems. Fundamentally, this Component will finance the development of a law creating a fID system. The necessary institutional and governance arrangements will be developed on the basis of that law, and implemented through appropriate executive instruments. As part of its legal architecture, the fID system will have the appropriate barriers protecting against potential abuse, and securing data acquired by agencies offering supplemental services in reliance on the fID system. Coverage should be universal, with all persons in the territory of the state being (i) registered voluntarily and (ii) uniquely identified in an unintelligible way (i.e., the UNI is unique, random and unintelligible). At an institutional level, the Project reinforces the capacity of implementing agencies, including investing in ongoing training for users and administrators, at both central and decentralized levels. 40. Develop an enabling legal and regulatory environment for linking fID and CR systems. This Component will also finance technical assistance for an enabling legal and regulatory environment linking fID and CR systems, and for ensuring automated flow of data on births and deaths between systems for sustained operations. 41. Provide for mutual recognition and authentication of services across participating ECOWAS member states. The Project will facilitate regional dialogue leading to the definition of common standards and protocols that will facilitate cross-border interoperability of fID systems. While development of the form of the legal and institutional framework will be guided by international good standards, it will be adapted to both the regional and country-specific contexts. 2. PROGRAM COMPONENT 2 – ESTABLISHING ROBUST AND INCLUSIVE fID SYSTEMS 42. This Component will support the creation of fID systems based on the issuance of UNIs linked to biometric data, which will be collected in accordance with international quality standards. The fID system will link with the CR system to have UNIs entered into the CR system and appended on birth certificates, and to retire UNIs from the fID system after death. Registered individuals may subsequently opt to receive a fID. Individuals may use either their UNI or fID for authentication to access services domestically and, once the trust framework is built, regionally, as facilitated by mutual recognition of fID systems. The design of fID systems for registration, processing and issuance of fIDs will be informed by a human-centered design study financed by the Gates Foundation (for Côte d’Ivoire), learning that can be brought to bear elsewhere. The fID systems will be supported by a grievance redress mechanism (GRM) to address issues and complaints. Effective project management will be critical to ensure the successful implementation of the fID system, as well as mass registration, fID issuance and facilitating access to services on the basis of the fID system. 43. This Component will finance the design, development and implementation of the following: (i) the technical aspects of establishing a fID system, including mass registrations and supporting infrastructure; as well as open standards to reduce costs, avoid vendor lock-in and provide flexibility for future adaptation; (ii) strengthening interoperability between fID and CR systems to ensure the data flow accounts for new births and deaths (integration should include issuance of a UNI at birth where uniqueness is ensured biometrically at a specified age, and retiring of UNIs for deaths registered in the CR system); (iii) developing basic methods of fID 38 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) issuance (especially for remote areas); and (iv) communications, stakeholder engagement, GRM and project management, including the implementation of the Social Management Plans. 44. The quality of fID systems depends on design and technical factors, which have profound implications for system cost, utility and security. These factors include the organizational design of identity management, the choice of technology used for establishing uniqueness, the authentication infrastructure (i.e., how fIDs are used to verify proof of identification at the point of transaction), the form and type of token or credential (i.e., different types of cards, use of only numbers or biometrics) and security measures put in place for protecting databases (e.g., natural disasters, cyberattacks). Hardware and software procurement should comply with open standards to reduce costs, avoid vendor lock-in and provide flexibility for future adaptation. 71,72 45. There are five key elements to fID systems. They will (i) be robust, meaning that they ensure the uniqueness of the assigned UNIs and have the necessary technical and legal underpinnings to function reliably and to effectively safeguard personal data; (ii) be inclusive, such that all individuals in any of the participating countries have access to a UNI that will identify them for life and newborns are issued a UNI at birth; (iii) be foundational, in that they are linked by design and practice to the CR system and can be used by functional registers for deduplication and authentication purposes; (iv) be mutually recognizable, allowing persons to establish their identity across borders through trust frameworks; and (v) facilitate access to services, for individuals in the public and private sectors by reliably authenticating a person’s identity. (See Annex 1 for a comprehensive list of the design objectives, endorsed by more than 23 international organizations.) 3. PROGRAM COMPONENT 3 – FACILITATING ACCESS TO SERVICES THROUGH fIDs 46. This Component will focus on service delivery at both the national and regional levels. Although fIDs will not themselves serve as travel documents, fID systems enabling mutual recognition among participating countries will facilitate safe and orderly cross-border movement, and promote access to regional and national public and private services using the fIDs for their functional applications. 47. This Component will support integration between the fID system and social safety net programs to facilitate access to services. To incentivize the uptake of fIDs, this Component will enable authentication of UNIs to facilitate access to social safety nets services. Other potential service sectors include public health (e.g., patient tracking), social protection programs (e.g., cash transfers), education (e.g., student IDs), mobile communications (e.g., SIM-card registration) and financial inclusion (e.g., KYC). 48. Take-up of the fIDs will be incentivized by linking the fID system to ongoing, national social protection programs. In both Côte d’Ivoire 73 and Guinea 74, national productive social safety net programs, which are co- financed through IDA and government resources, presently use their own functional IDs. Shifting program- reliance to fID systems will not only facilitate both deduplication of beneficiaries and authentication at pay points, but will also help develop more robust and secure systems, while also alleviating administrative pressures from 71 Identification for Development. 2018. “Technical Standards for Digital Identity”. Draft for Discussion. Washington, DC: World Bank Group. http://pubdocs.worldbank.org/en/579151515518705630/ID4D-Technical-Standards-for-Digital-Identity.pdf. 72 George, Tina; Mittal, Anita; Anandan, Vasumathi; and Caillava, Ines Rodriguez. 2018. “Leveraging an Open Source Model to Create a Public Good for ID4D & SPJ Delivery Systems”. Working Paper (forthcoming). Washington, DC: World Bank Group. 73 World Bank. 2015. Project Information Document (Appraisal Stage) - Cote d'Ivoire - Productive Social Safety Net - P143332. Report. Washington, DC: World Bank Group. https://hubs.worldbank.org/docs/ImageBank/Pages/DocProfile.aspx?nodeid=24159819. 74 World Bank. 2012. Guinea - Productive Social Safety Nets Project (English) - P123900. Rep. No. 66196-GN. Washington, DC: World Bank Group. http://documents.worldbank.org/curated/en/222311468257333859/Guinea-Productive-Safety-Nets-Project. 39 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) social safety net programs. Further, as the Project will implement an interoperability mechanism to provide UNIs that are in line with the appropriate privacy, data protection and user-consent policies, the Project will reduce risk of EFC for service providers. C. Beneficiaries 49. By 2028, the Program aims to achieve fIDs for 100 million potential beneficiaries in the ECOWAS region (i.e., 27 percent of the population). Through the implementation of the phase 1 (Côte d’Ivoire, Guinea), the Project aims to achieve fIDs for 35 million potential beneficiaries (i.e., 80 percent of the population in these two countries, being 10 percent of the regional population). The MPA is expected to provide fIDs to all persons physically in the territory, irrespective of nationality, residency or legal status. The operation will facilitate regional integration by facilitating freedom of movement within ECOWAS, as well as access to services within participating member states. D. Rationale for Bank Involvement and Role of Partners 50. The World Bank is well-positioned to help its clients by supporting the development of robust and inclusive fID systems in line with the shared principles for sustainable development. 75 Robust, inclusive and sustainable fIDs in turn will facilitate access to a range of health, educational, financial, political, social services and rights within countries and across the region. As discussed, the output of this initiative aligns with SDG target 16.9. Further, on the basis of the outcome and long-term impact of this initiative, not only will SDG 16 (Peace, Justice and Strong Institutions) be advanced, but so, too, will many other SDGs—for instance, SDG 1 (No Poverty), SDG 4 (Quality education), SDG 5 (Gender Equality), SDG 8 (Decent work and economic growth) and SDG 10 (Reduced Inequalities). 51. World Bank leadership in this area is justified for many reasons. The World Bank has done, and continues to do, systematic analytical work on ID systems in countries around the world. Further, much of the Bank’s work is done across many sectors; much of that work depends on accurate, meaningful identification and tracking of individuals (e.g., safety nets programs, health, financial, trade services). Bank leadership in this area brings relevant and insightful cross-sectoral knowledge. Further, the Bank’s strong convening power helps to create synergies in different sectors and to bring together partners in a coherent and sustained manner. Use of IDA funds for this MPA is justified because the development of digitized fID systems will help improve expenditure efficiencies in sectors ranging from safety nets to health to access to credit on which IDA invests heavily in most ECOWAS countries. This will allow IDA to have more impact in these countries. 52. The World Bank is collaborating with various donor partners to ensure the rollout of interoperable fID systems across participating ECOWAS member states (see Table 5). The MPA’s programmatic approach provides consistency across participating ECOWAS member states, and creates a systematic and sequential framework for regional integration, bringing together donor partners, government counterparts and private sector through a long-term engagement and throughout the lifetime of the operation. Donor partners will also benefit from the MPA approach, as the Program will provide a platform upon which they might finance operations that are not covered, such as CR systems. The Program is collaborating with various donor partners with a longstanding interest in ID and CR reform and modernization in the region, including the EU, the Agence française de developpement (AFD), the Belgian Technical Cooperation (BTC) and the African Development Bank (AfDB). The 75 Identification for Development. 2017. “Identification for Development: Africa Business Plan IDA 18 (FY18-20)”. Report. Washington, DC: World Bank. http://pubdocs.worldbank.org/en/484791507732929415/ID4D-Africa-Business-Plan-FINAL.pdf. 40 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) World Bank is in discussions with all of these donors to identify how their efforts in each country could best complement the World Bank’s fID efforts and vice versa. The Bank is also coordinating with Office of the United Nations High Commissioner for Refugees (UNHCR) and the International Organization for Migration (IOM), particularly on how to best ensure that the Bank-financed ID systems remain accessible to vulnerable populations. A long-term engagement through the MPA will facilitate consultations with donors, key national and regional stakeholders throughout the lifetime of the operation. 53. Considering the importance of integration between fID and CR systems, the Project will consider related operations, and actively work with other donor and development partners to further that integration, including by strengthening civil registration and vital statistics (CRVS) (see Table 5). While the Project is not directly investing in the strengthening of CRVS, there are opportunities for these additional aspects to be financed, either through additional Bank financing, or through the financing of development partners. In addition to Bank efforts in the region, 76 UNICEF and the Global Financing Facility (GFF) are also being consulted on birth and death registration in the region, and efforts will be made to collaborate with other development partners, such as the United Nations Economic Commission for Africa (ECA), the Centre of Excellence for CRVS Systems, and other partners of the Africa Programme on Accelerated Improvement on Civil Registration and Vital Statistics (APAI- CRVS). Table 5: Engagement with Donor Partners on the MPA Donor Partners Domain of Engagement EU Civil Registration AFD Civil Registration BTC Civil Registration AfDB Civil Registration UNICEF Civil Registration GFF Civil Registration UNHCR Migration; Refugees IOM Migration; ECOWAS Gates Foundation Human-Centered Design and Ethnographic research E. Lessons Learned and Reflected in the Project Design 54. The MPA draws on lessons learned from other regional projects in West Africa and from the results of the Independent Evaluation Group (IEG)’s assessment of regional programs. Other regional projects have highlighted the challenges in working with regional institutions and stressed the importance of building strong commitment among participating countries to drive buy-in and engagement at the regional level. The IEG assessment from December 2006 highlights the need to design projects which have: (i) better integration of regional programs with national country assistance programs; (ii) strong country commitment to regional cooperation; (iii) a scope of project which matches national and regional capacities; and (iv) clear delineation and coordination of the roles of national and regional institutions. 76World Bank. 2018. Guinea Health Service and Capacity Strengthening Project - P163140. Report. Washington, DC: World Bank Group. https://hubs.worldbank.org/docs/imagebank/pages/docprofile.aspx?nodeid=29792119. A GFF-grant may finance a CR component in this project. 41 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) 55. The task team has worked closely with country teams and with the ECOWAS Commission to ensure the MPA responds to national and regional gaps. The MPA includes resources to support targeted national and regional institutional capacity-building to ensure more efficient implementation. Experience building and sustaining regional engagement from the Regional Sahel Pastoralism Support Project in West Africa 77 has also informed the design of the ECOWAS grant element, in particular will create a regional-level working group of stakeholders from ID and immigration agencies of participating ECOWAS member states to ensure policy coherence and agreement on a common goal of mutual recognition. The regional working group will provide a demonstration effect encouraging other ECOWAS member states to join subsequent phases of the MPA as soon possible. 56. The MPA draws on lessons from other Bank projects. In addition to helping to develop strong project management, the MPA approach will allow for integrating and sharing of various project pieces, including terms of reference (ToRs), requests for proposals (RFPs) and knowledge and ideas across countries, therein helping cross-fertilization among projects and the development of monitoring and evaluation (M&E) capacity. Building bridges across countries, particularly through regional working group led by the ECOWAS Commission, will advance progress, address common challenges and encourage knowledge sharing from other participating countries, regardless of their stage of progress. 57. The MPA also draws on lessons learned from other ID projects and on the wealth of analytical and global convening work on identification by the World Bank’s ID4D Program. Key lessons include the following: i. fID systems should strictly limit data collection in order to prove identity, upon which other functional, sector-specific systems can in turn rely. Proof of ID should only indicate an individual’s identity—that is, that verify that an individual is who s/he says s/he is—rather than trying to cater to any or all specific uses (e.g., voting, travel). 78 Building a single, fID system seeking to cater to all sectors results in a cumbersome and often-unwieldy design that makes enrollment, validation and authentication burdensome and inefficient, and which is too complex to successfully rollout universally. Reciprocally, it has been repeatedly shown that parallel, sector-specific ID systems operating independently of each other is inefficient. The appropriate balance is struck by building an inclusive fID system with limited data fields, linked to which detail-rich, sector-specific databases can be subsequently built. ii. fID systems should be open to all persons physically present in the territory, and registration done on a voluntary basis. Registration in the fID should not be tied to legal status (e.g., citizenship, residency), as doing so both creates substantial upfront verification burdens and discourages registration. Further, the higher the degree of required inputs, the more burdensome the system, and the more difficult it becomes to encourage voluntary registration. Registration in the fID should simple and expedient, and offered alongside of service pay-points, to the extent possible. Relatedly, registration should be done on a voluntary basis, meaning that denial of services for failure to register in the fID system should not be permitted. 77 World Bank. 2017. Western Africa - P147674 - Regional Sahel Pastoralism Support Project - Procurement Plan. Report. Washington, DC: World Bank Group. https://hubs.worldbank.org/docs/ImageBank/Pages/DocProfile.aspx?nodeid=28746903. 78 Identification for Development. 2017. “Identification for Development 2017 Annual Report”. Report. Washington, DC: World Bank Group. http://pubdocs.worldbank.org/en/561391513609113984/2017-ID4D-Annual-Report.pdf. 42 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) iii. fID systems should endeavor to provide unique identification from birth to death. Unique identification allows for the minimization of fraud and linkages of the fID with critical services which require a one-to-one authentication (e.g., bank accounts, attendant credit, insurance histories), or any payments which suffer from double-dipping (e.g., subsidies, Government-to-Person (G2P) 79 payments intended for specific beneficiaries, pensions, salaries). iv. Strong linkages should be established between fID and CR systems. This element is critical to ensuring that births and deaths are consistently captured across the population. 80 v. Implementation of fID systems is more likely to be successful with high-level political will. That political will is needed to coordinate cross-ministerial engagement and to develop a synthesized national strategy or action plan. High-level political support also prevents the emergence of a fragmented ID ecosystem plagued with duplicative or one-off efforts by various individual ministries. vi. A robust legal and institutional framework is a critical enabler of long-term fID system success. 81 Such frameworks provide relevant mandates to identify the roles of various stakeholders in fragmented systems, as well as to institute laws which protect data and privacy (e.g., through use- purpose specification). Such an underpinning should be developed progressively, not anticipatorily. vii. The most significant fID-system costs are associated with issuance of a sophisticated credential (e.g., a smartcard) and the hiring of full-time staff (chiefly to enroll populations). The design of fID systems should, where possible, leverage an ecosystem-based approach to enrolling populations, relying on fID systems that collect minimal data to issue unique, biometric-linked numbers. Access to services can be guaranteed through the Issuance of a basic, low-cost ID credential or fID. 58. Furthermore, the MPA draws on lessons learned on exclusion risks. Overall, exclusion risks can be managed by developing detailed procedures, targeting vulnerable groups for inclusion and strengthening the GRM. Specific risks and strategies for their management include the following: i. Individuals unable to prove their identity can result in non-registration and, therefore, in denial of services. Generally speaking, legislation should be in place ordaining that the lack of a government- recognized IDs should not prevent access to services; program implementation protocols should assure as much in greater detail, and should detail procedure for overcoming such obstacles. Additionally, those protocols should encourage and facilitate the registration of such individuals so as to both enable their receipt of benefits, as well as their inclusion in the fID system and in the services built on that system. Additionally, penalties and sanctions must be defined to dissuade service providers from turning away beneficiaries, who are often those in most need. ii. Inability to obtain biometric data can result in non-registration and non-issuance of a UNI, and hence in exclusion. As the capturing of biometric data can be difficult, the enrolment procedure 79 Pickens, Mark; Porteous, David; and Parker, Sarah Rotman. 2009. “Banking the Poor via G2P Payments”. Consultative Group to Assist the Poor (CGAP). http://www.cgap.org/publications/banking-poor-g2p-payments. 80 For a broad guide providing an overview of factors to be considered in building robust and inclusive systems, see Identification for Development. 2017. “Principles on Identification for Sustainable Development: Towards a Digital Age”. Report. Washington, DC: World Bank Group. http://documents.worldbank.org/curated/en/213581486378184357/pdf/112614-REVISED-English-ID4D- IdentificationPrinciples.pdf. 81 World Bank. 2017. “The State of Identification Systems in Africa – A Synthesis of Country Assessments”. Report. Washington, DC: World Bank Group. http://documents.worldbank.org/curated/en/156111493234231522/pdf/114628-WP-68p- TheStateofIdentificationSystemsinAfricaASynthesisofIDDAssessments-PUBLIC.pdf. 43 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) should specifically detail both backup procedures and, as necessary, exceptions (e.g., for those without fingers, or for those with cataracts) should be specifically provided in the protocols—such as mobile one-time password (OTP), iris-scan or local authority authentication—so that individuals are not be structurally excluded. Further, sanctions for operators who either deny enrollment of individuals or who abuse the biometric exception process to create fraudulent fIDs should be detailed. iii. Individuals living in geographic isolation are at greater risk of exclusion. The mass-enrollment rollout strategy should sequence and prioritize rural and remote areas, as the most challenging to reach, before turning to register urban areas and cities. iv. Individuals without identity documents (e.g., women, children) are at greater risk of exclusion. Individuals lacking identity documents (see Glossary, above) risk being excluded. To manage this risk, protocols should be included allowing for their inclusion on the basis of formal letters of introduction coming from a local authority (e.g., village chiefs, leaders, officials, representatives) that have the requisite identifying details (e.g., photograph, name, address). Additionally, family cards listing all family members in the household, including children, should be allowed as a means of introduction. v. Individuals without an address (e.g., nomadic peoples, street children) are at greater risk of exclusion. In order to mitigate the risk of exclusion, NGOs and humanitarian agencies might be called upon to assist determining an address for delivering credentials. vi. Individuals living in sites of active conflict and violence are at greater risk of exclusion. The mass registration campaign should specifically target these areas to expand coverage and reach. vii. Group bias by those responsible for enrollment can result in exclusion. This risk can be mitigated by employing multiple vendors to both design and rollout the registration process, as well as by using performance-based contracts. III. IMPLEMENTATION ARRANGEMENTS A. Institutional and Implementation Arrangements 59. While financing of fID systems will be done at the country level, overall, regional program coordination will be done through the ECOWAS Commission. The Commission’s role as a regional governing body is critical for ensuring the mutual recognition of country fID systems. The capacity of the ECOWAS Commission to coordinate and harmonize fID initiatives is key to the Program’s regional success. To this end, financial support in the form of an IDA grant of US$5 million will be made available to the Commission to facilitate regional dialogue and to bolster its capacity. Internally, the Commission has identified its DFMT to lead an internal task force to implement this grant. That task force will include the DTIT, Department of Social Affairs, the Community Development Unit and the Monitoring & Evaluations (M&E) Unit, with other competencies to be added as necessary to help develop a regional trust framework for participating member states. Further, the task force is responsible for monitoring the Project’s regional progress, allowing linkages to country-level activities. 60. The ECOWAS Commission meets the criteria for accessing regional IDA grants. While countries are the typical recipients of IDA grants, the ECOWAS Commission meets the criteria (see Table 6) and is therefore eligible for receipt of regional IDA grants. 44 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) Table 6: The ECOWAS Commission Meets the Criteria for Accessing Regional IDA Grants Criteria for Accessing Rationale Regional IDA Grants 1 Recipient is a bona fide regional The Economic Community of West African States (ECOWAS) is a regional organization that has the legal status bloc of 15 members states, officially formed by the ECOWAS Treaty of 28th and fiduciary capacity to receive May 1975 and revised 24th July 1993. 82 Its executive organ is the ECOWAS grant funding and the legal authority Commission, and has the legal authority to receive the funds allocated to carry out the activities financed. under the grant. ECOWAS institutions have benefited from IDA grants, including a PPA to the ECOWAS Centre for Renewable Energy and Energy Efficiency (ECREEE) in the amount of US$5 million for the Regional Off Grid Electrification Project (P160708). 2 Recipient does not meet eligibility The ECOWAS Commission has limited resources. criteria to take on an IDA credit. 3 The costs and benefits of the activity The IDA grant would support regional implementation by accomplishing to be financed with an IDA grant are the following: not easily allocated to national (i) The Program is structured upon the ECOWAS Free Movement Protocol programs. and countenances the integration theoretically enabled by the ECOWAS National Biometric Identity Card (ENBIC); the Commission will elaborate and execute change-management plans to sensitize stakeholders to create a mutual understanding of the importance of a phased approach to implementing the ENBIC via fID systems for participating ECOWAS member states. (ii) The Program aims to develop and implement fID systems that, though national, are interoperable among participating countries and across border; the ECOWAS Commission will play a central role in developing uniform standards, policies and technical standards for participating ECOWAS member states; (iii)The Program is phased, with various participating countries entering in at various times; the ECOWAS Commission will play a vital role in sharing lessons learned and building capacity of implementing agencies and authorities; (iv)The Program supports economies of scale: individual projects in smaller countries would benefit from shared activities; and (v) The Program aims to move the region as a whole forward; the Commission will play an important role in monitoring national and regional progress towards the achievement of interoperable fID systems and ENBIC. The IDA grant will finance activities that are difficult to allocate by country: (i) The development of uniform standards and policies for fID system interoperability for participating ECOWAS member states; (ii) The elaboration of a roadmap from fID system to ENBIC for participating ECOWAS member states; (iii)The coordination and sharing of lessons learned among participating ECOWAS member states; (iv)The supporting of economies of scale; and 82Economic Community of West African States (ECOWAS), Treaty of the Economic Community of West African States (ECOWAS). 28th May 1975. http://www.ecowas.int/wp-content/uploads/2015/01/Revised-treaty.pdf. 45 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) (v) The monitoring of implementation progress. 4 The activities to be financed with an The Program supports the development of fID systems that are IDA grant are related to institutional interoperable across the region, thereby furthering regional economic cooperation for regional economic integration, notably by facilitating both in-country and cross-borders integration and coordinated access to services and by encouraging freedom of movement and trade. interventions to provide regional public goods. 5 Grant co-financing for the activity is The Program focuses on the development and implementation of fID not readily available from other systems (for the purposes of facilitating access to services) and might be development partners. used as a stepping stone for tackling the larger issue of legal identity and the rehabilitation of national CR systems. The Program and the Bank’s convening power may serve as a catalyst for drawing the financing and support of donor partners who have substantial expertise and longstanding interests in these surrounding matters, notably the EU, the AFD, BTC and the AfDB. 6 The regional entity is associated with The ECOWAS Commission will be associated with the regional an IDA-funded regional operation. harmonization of the Program. 61. At the country level, implementation will be carried out by PIUs. Each country will separately design and develop specific fID implementation arrangements. In countries with national ID agencies that already have strong ID-reform mandates, the PIU could be housed within those agencies, therein helping to build institutional capacity and to ensure project alignment with national ID agendas. In countries without a suitable agency, the Project would create a new, freestanding PIU or, where possible, could leverage an existing PIU in order to minimize implementation costs. (See Annex 3 for a detailed review of the Institutional Arrangements.) 62. Project implementation in Côte d’Ivoire will be carried out by Office National d’Identification (ONI). In Côte d’Ivoire, reform of national ID systems is already underway, having been identified as a high priority reform by the Government. The Government recently took several important steps to advance the ID agenda, notably by formally giving ONI authority in the newly-created, central body set up to lead the way in developing a fID system. 83 At the very top is the Steering Committee (Comité de Pilotage). Composed of various ministers and headed by the Prime Minister, it is charged with defining the larger dimensions of the fID system, has overall supervising authority and is to follow and approve technical progress, as well as to have financial oversight. The National Technical Committee (Comité Technique National) provides the key technical inputs. ONI serves as the Committee’s secretariat; further, ONI’s institutional superior, the Minister of the Interior, is the Committee’s head. The Executive Management (Direction Executive), which has ONI at its helm, is tasked with assuring the administrative, technical and financial success of the yet-to-be proposed fID system; most notably, it will propose a technical action plan for fID system implementation, as well as appropriate financing. Important administrative linkages and lines of communication are structurally created between fID and CR systems by making the Director of the Civil Registry the Technical Secretariat to ONI, with the Secretariat’s members being chosen by the Minister of the Interior in his capacity as head of the National Technical Committee. With regard to project implementation, staffing of the PIU is underway. A Project Implementation Manual (PIM) will be prepared following Board approval. The procurement package is being developed. 63. Project implementation in Guinea will be carried out by a PIU housed within the Office of the Prime Minister (PMO or Primature). As Guinea lacks an agency with either a clear mandate or with the inter-sectoral 83 Arrêté n° 079/PM/CAB (6 février 2018). 46 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) reach to execute the broader ID reform, the Government of Guinea has elected to anchor the Project in the PMO until such time as a more permanent institutional arrangement for overseeing the fID system can be established. A project coordinator is being hired. The procurement package is being developed. A PIM will be prepared following Board approval. B. Results Monitoring and Evaluation Arrangements 64. MPA results indicators. Progress towards the achievement of the overall PrDO will be measured based on the MPA PDO-level and intermediate results indicators as part of the Program’s Results Framework (see Section VI). Relevant data and information pertaining to measuring results, including project outcomes and quality of project execution will be collected. The World Bank team will conduct an annual evaluation to review the progress against results indicators, based on data supplied by the PIUs. Country PIUs will be responsible for developing detailed M&E plans, specifying standard protocols and developing guidelines for data collection and use for the duration of the Project, as well as will organize trainings for relevant stakeholders in the M&E plan. Progress reports will be closely reviewed by the multi-sectoral steering committees set up in each country, as well as by the ECOWAS task force created to supervise the Project at the regional level. Country PIUs will provide quarterly monitoring tables and progress reports on all PDO- and intermediate-level results indicators, as well as any additional country-level indicators specified in the country projects’ respective M&E plans to the World Bank during routine implementation-support missions. (See Section VI; see also Annex 3 for a detailed review of the M&E aspects, including details for phase 1 of the MPA.) 65. At the regional level, the ECOWAS Commission will help establish the baseline for both coordinating with participating member states and institutions, as well as for measuring progress at both the regional and national levels. As the regional partner, the ECOWAS Commission can receive information on individual country progress, which, when supplemented through desk research and data, can help facilitate country coordination and provide a more complete picture of the task ahead. As the Project progresses along the phases, collected empirical data can show periodic progress in terms of the number of issued government-recognized IDs, allow for comparing of figures with existing data and provide benchmarking tools. The PrDO measures the number of persons in participating ECOWAS member states with fIDs facilitating access services. Given the wide variation in the population across the ECOWAS region (ranging from 2 million to 192 million people in The Gambia and Nigeria, respectively), the Program’s overall success may be more usefully assessed by measuring the percentage enrolment per member state as opposed to absolute numbers. The threshold for achieving success would be 80 percent enrolment in at least 80 percent of the participating member states. 66. At the country level, M&E will be supervised by the Project Coordinator. Given the logistical challenges of implementation in both countries, a firm will be contracted to design the M&E parameters, implement a system and to conduct M&E activities. The need for a full-time M&E specialist in the PIU will be reassessed every 6 months. Tools such as geocoding, geospatial mapping and poverty maps can be used to monitor the progress of mass registration. Such tools can pinpoint where enrollment sites should be setup and to dispatch mobile registration units to remote regions. The outcome is twofold: the project implementation phase can be more accurately and effectively rolled out and, if enrolment is done at a sector-specific site—for instance, at a health center—then the health sector would also benefit immediately, allowing for the rolling out of public health programs, such as health camps or immunization campaigns. Systematically collating registration data from remote/rural areas and urban areas can provide insight into the level of coverage, inclusion and access, especially in poor regions and along borders. 47 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) C. Sustainability 67. The Program will support Côte d’Ivoire and Guinea to make project gains self-sustaining. Sustainability will depend on the development of a viable business model for the fID system taking into account: (i) cost drivers, (ii) a robust legal and institutional enabling framework and (iii) stimulating demand for IDs based on access to services and vice versa. 68. A close analysis of the cost drivers of identification systems across 15 countries has revealed that the two largest cost components tend to be (i) staff costs associated with enrollment (35 to 65 percent) and (ii) costs of issuing credentials (between 10 and 40 percent). Interestingly, there is a high (approximately 30 percentage point) spread in both these drivers in terms of their contribution to total cost. This variation is typically attributed to a few key design-choice based drivers—the choice of biometrics collected, the enrollment timeline, the technical features of the credential, the number of data fields collected and the level of linkage with the CR system: i. Cost of Enrollment: The Project has been designed based on lessons learned from other ID implementations. Initial round costs of mass registration will be borne by the Project. However, recurring costs done after this first sweep (including day-to-day enrollment, registry update and maintenance) will be carried out by civil servants and embedded in the existing government budget. The Project will also explore public-private partnerships (PPP) to support expansion and maintenance of the fID system in the long term. ii. Cost of Credential Issuance: To enable universal access to identification, the Project will issue low- cost government-recognized IDs that will be free of charge to beneficiaries. Should a higher-cost card be needed for certain population subsets (e.g., for travel, extended services), those costs will be supported by other sources of financing or passed on to end-users. The Program will develop costed roadmaps for each country and studies to inform the design of their business models based on analysis of the two key drivers listed above. This will ensure that the chosen business model for the fID system is sustainable beyond the life of the Project, both by making cost-effective design choices and by developing relevant revenue streams where possible (e.g., charging for any additional credentials and/or authentication services). The economic and financial analysis further demonstrates the sustainability of the investment. 84 69. The Project will build in sustainability through the creation of a robust legal, institutional and governance framework. The development of laws and policies will set in place the necessary elements, such as an independent ID agency with roles and responsibilities clearly assigned, to ensure the longevity of the fID system. Strong institutional capacity is key to ensuring sustainability. To this end, competitive hiring will be used to ensure that the agency is staffed with those having the appropriate technical capacity and skills. In order to finance the recurring costs of enrollment, updates and maintenance, through the existing government budget, a memorandum of understanding among government agencies will be devised for data sharing and the like, based on issues such as the authentication of services through IDs. 84 Identification for Development. 2018. “Understanding Cost Drivers of Identification Systems”, Report (forthcoming). Washington, DC: World Bank Group. 48 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) 70. The Project will build in sustainability by stimulating demand for fIDs based on access to services and vice versa. For platforms such as fID systems to be successful in a public-sector setting, the demands of several service providers (e.g., social protection services, health) potentially desirous of using the platform to deliver their own services must be considered. As such, it is important to get the pricing structure and incentives right. Importantly, demand on each side vanishes if there is no demand on the other—a chicken or egg situation. For instance, banks will not accept the fID if no one carries it as no transactions will materialize. The fID system will need to obtain a critical mass of users on one side (i.e., near universal coverage) so as to stimulate demand from service providers to use the IDs in order to authenticate their services. 85 IV. PROJECT APPRAISAL SUMMARY A. Technical, Economic and Financial Analysis 71. This analysis captures (i) the expected contribution to the socioeconomic development of both the ECOWAS region as a whole, as well as to its member states; (ii) the rationale for public sector provision; and (iii) the value added of the Bank’s support. 72. The available evidence on the benefits of robust and inclusive ID systems strongly suggests that social and economic returns justify the significant investment required. These returns are of three types: i. Social returns in the form of a variety of important benefits to individuals by enabling access to public- and private-sector services, reducing transaction costs and facilitating the protection of vulnerable groups and humanitarian responses; ii. Economic benefits through increased efficiency of firms and, in the case of mutually-recognized IDs, lower costs of international trade and migration; and iii. Fiscal savings through the reduction of EFC and duplication of costs. 73. With regard to benefits to individuals, the international experience offers a wide range of examples. In Thailand, the government could identify the population that was not covered by health insurance by cross- checking databases with the national ID. This allowed them to increase coverage from 71 to 95 percent in two years.86 In Peru, the World Bank partnered with the Peruvian ID agency to register poor children so that they could access cash transfers and nutritional support. Conversely, there is evidence that gaps in coverage of social programs are sometimes due to lack of proof of identity. In Nepal, 12 percent of the elderly could not receive the old-age pension due to their inability to prove their identity and age. There is even research suggesting that having age-verified IDs can contribute to reducing child marriage. 87 74. Another important benefit of a fID system is the ability to respond quickly to provide assistance in the context of a disaster. In 2005, Pakistan was able to disburse more than US$350 million to those affected by a major earthquake in just a few months using the national ID database and a robust authentication process. In 85 For instance, Diners Club gave away its charge card to cardholders at first: there was no annual fee, and users got the benefit of the float. Evans, David S; Hagiu, Andrei; and Schmalensee, Richard. 2006. Invisible Engines: How Software Platforms Drive Innovation and Transform Industries. Book. MIT Press. 86 WB ID4D “ID for Healthcare” (2018). 87 Hanmer and Elefante (2016). 49 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) contrast, when Nepal was hit by a devastating earthquake in 2015, millions of dollars and many months were spent collecting data on individuals living in the affected areas before aid could even be dispersed. More than two years after the event, Bank-supported efforts are still paying out benefits. Thailand uses its national population register to manage its local response to disease outbreaks, such as to manage distribution of vaccinations when there was a Dengue outbreak in provinces bordering Lao. 75. Perhaps the most important social returns from robust and inclusive ID systems relate to financial inclusion. According to the Findex survey, 18 percent of those without bank accounts across more than 100 countries cite lack of documentation. fID systems can facilitate the opening of access to the financial and banking systems, helping banks and other service providers (e.g., credit agencies, mobile phone providers) fulfil KYC requirements by ensuring that individuals have access to government-recognized IDs. An extension of this is mobile money accounts which have expanded dramatically, especially in East Africa, but are constrained by increasingly tight KYC regulations, both for banking and telecommunications (i.e., SIM cards). 76. All of these benefits are relevant for Côte d’Ivoire and Guinea, as well for ECOWAS member states. While poverty targeted cash transfers and other assistance currently cover a small part of the population in both countries, there are plans to scale them up in the next few years. The same is true for health insurance coverage. Côte d’Ivoire has set a goal of universal health insurance coverage. In both cases, the lack of proof of identity could result in exclusion of vulnerable groups. The original engagement in Guinea on this subject arose from the recognition that the poor system of identification hampered efforts during the Ebola crisis. 77. The lack of proof of identity makes it difficult for millions of people to fulfill KYC and anti-money laundering (AML) requirements or to establish reliable credit histories. In Côte d’Ivoire and Guinea, only some 34 and 7 percent, respectively, of people over the age of 15 have bank accounts.88 Estimates based on the Findex survey suggest that reaching universal coverage in identification could enable 2 to 4 million adults and 1 to 3 million adults in Côte d’Ivoire and in Guinea, respectively, to access their first mobile phone and allow between 88Kunt, Asli Demirguc; Klapper, Leora; Singer, Dorothe; and Van Oudheusden, Peter. 2014. “The Global Findex Database 2014: Measuring Financial Inclusion around the World”. Working Paper. Washington, DC: World Bank Group. http://www.worldbank.org/en/programs/globalfindex. 50 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) 700,000 and 3 million and between 300,000 and 2 million in Côte d’Ivoire and in Guinea, respectively, to open their first bank account. These social returns to individuals from better access to services are generated within the national borders. 78. Further benefits to individuals would be anticipated to the extent that the regional objective of the Project in terms of mutual recognition is realized. The movement of people (and associated financial flows) is relatively high compared to the rest of SSA. Intra-regional remittances account for US$6 billion, the equivalent of half of all cross-border remittances in SSA. In The Gambia for example, remittances account for 20 percent of GDP. Digital financial services, including mobile money, can be offered more efficiently at a regional level as recognized by the harmonization of rules in the CFA franc zone, largely a subset of the ECOWAS membership. Early discussions with WAEMU indicate interest in leveraging robust ECOWAS-wide interoperable fID systems to allow for eKYC across the sub-region. Mutual recognition will particularly facilitate access to markets for smaller countries, helping trade and labor market integration. 89 79. In addition to this economic impact, fID systems can contribute to the economy through increased private sector efficiency. For example, KYC costs for banks and telecom firms have been reduced dramatically in India after the introduction of Aadhaar. A recent study in Zambia estimated that savings for banks and telecoms from lower costs of KYC would run into the tens of millions of dollars over the medium term should the new government-recognized ID be introduced. Credit rating agencies and micro-finance institutions also stand to benefit from the ability to link unique numbers across databases in order to track credit histories. Finally, the existence of a robust system for authentication obviates the need for individual entities or industry associations to set up their own silo systems, duplicating costs many times over. This is the case in countries like Brazil, Ghana and Nigeria, for example, where the banking sectors have spent tens of millions of dollars on their own functional ID systems in the absence of a well-functioning fID system. 80. fIDs are likely to generate fiscal savings by reducing EFC. A forthcoming report on the subject 90 finds numerous examples of savings from the reduction of EFC. One of the earliest cases cited is Argentina, where linking 34 social program databases with a UNI revealed inclusion errors in eligibility of various social programs and led to a reduction in spending of US$143 million over an 8-year period. In 2010, Pakistan launched the Watan Card program in response to devastating floods that displaced some 20 million people (over 10 percent of the country’s population). About 40 percent of the initial 2.7 million people that applied were found to be ineligible or were duplicate family members. 91 This translates to an estimated savings of some PKR 21 billion (US$248 million in 2010). In 2016, Thailand eliminated 660,000 applicants out of 8.4 million based on cross-checking databases using the UNI, generating savings of US$30–60 million. 81. Savings are often found through reducing pension and wage bill costs for the civil service. The problem of ghost workers and pensioners in the public sector is a common one in Africa. In 2016, Uganda removed around 89 Hanmer, Lucia; and Lubega-Kyazze, Jean. 2017. “Opening door: How national IDs empower women cross border traders in East Africa”. Blog. World Bank. https://medium.com/world-of-opportunity/opening-doors-how-national-ids-empower-women-cross-border-traders-in- east-africa-8443c98e2aad. 90 Clark, Julia. 2018. “Public Sector Savings and Revenue from Identification Systems: Opportunities and Constraints”. Report. Washington, DC: World Bank Group. http://pubdocs.worldbank.org/en/745871522848339938/PublicSectorSavingsandRevenueIDSystems-Web.pdf. 91 Hakeem, Ali Arshad. 2010. “Citizens Damage Compensation Mechanism: National Database and Registration Authority”. Presentation by Ali Arshad Hakeem, NADRA chairman, Government of Pakistan. 51 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) 6,000 ghost workers generating savings estimated to be between 8 and 11 million dollars. Since this result was achieved through the use of the national ID, it can be seen as generating these savings every year. In many countries, there have been one-off biometric censuses which have produced savings but which allow the problem to emerge again in the future. Nigeria estimated savings from one such effort at US$1.12 billion between 2007 and 2014. 92 As noted below however, Nigeria spent much more than this on multiple biometric functional IDs that compete with the national ID. 82. Costs can also be reduced if multiple programs can use the fID system infrastructure rather than setting up “siloed” functional ID systems. Perhaps the most important example is the periodic cost of issuing voter IDs periodically. In 2015, 14 African countries spent more than US$1 billion dollars on elections. 93 Since 1999, South Africa has leveraged its national ID database to generate the voter rolls. In contrast to the rest of the region, this has contributed to a reduction in election costs from US$170 to US$32 million between 1999 and 2009. 94 In contrast, Nigeria is estimated to have spent over US$3 billion on functional biometric ID systems, including the voter ID that competes with the national ID. 83. The potential fiscal savings in Côte d’Ivoire and Guinea are significant. Côte d’Ivoire spends about 8 percent of its GDP on civil service wages and pensions. If the number of ghost workers and pensioners is reduced by just one percent, the investment would have paid for the initial investment in few years. If spending on social programs is ramped up as planned and ghosts and duplicates are reduced, the fiscal savings would be even greater or the ability to cover more people would be greater with the same budget. 84. As in most of the region, both countries have spent large amounts on their elections. Côte d’Ivoire spent more than US$260 million on the overall election, including voter registration. Guinea is estimated to have spent US$10 million for biometric voter registration in the last election alone. A conservative estimate would place cost- savings at one-third of these figures from the implementation of a fID system, largely regarding registration and credential issuance. In other words, most of the initial cost of setting up the proposed fID system would be covered by the savings from one election cycle. 85. The combined benefits to individuals, to the overall economy and to the fiscal situation suggest a high rate of return; however, those benefits are inherently difficult to measure. The only rigorous cost-benefit analysis of an ID system project (at least for a developing country) is the forthcoming World Bank-commissioned report on Zambia. This report assumes savings from reduction in EFC and leakage based on conservative assumptions as well as reduction in duplication of costs of producing a voter ID. The analysis also estimates the cost of initial mass registration, as well as the incremental recurrent costs of maintaining the system (e.g., new enrolments, lost cards) over an 18-year period. The estimated internal rate of return (IRR) ranged from 38 percent to more than 500 percent in the four scenarios presented. These high rates of return are mainly driven by fiscal savings related to social spending and lower costs of holding elections both of which are recurrent as opposed to one-off savings. They do not take into account the kind of social returns to the investment described above. 92 Gelb, Alan; and Metz, Anna Diofasi. 2018. Identification Revolution: Can Digital ID Be Harnessed for Development?. Book. Washington, DC: Center for Global Development. 93 United Nations Economic Commission for Africa. 2013. African Governance Report III. Election & the Management of Diversity. Book. Oxford: Oxford Univeristy Press. http://www.africa.undp.org/content/dam/rba/docs/Reports/Africa%20Governance%20Report%203.pdf. 94 Identification for Development. 2018. “Public Sector Savings and Revenue from Identification Systems: Opportunities and Constraints”. Report. Washington, DC: World Bank Group. http://pubdocs.worldbank.org/en/745871522848339938/PublicSectorSavingsandRevenueIDSystems-Web.pdf. 52 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) 86. The rationale for public sector provision arises from improving pro-poor public service delivery coverage and strengthening public sector institutional capacity to do so. Public sector investment helps to ensure that personal data contained within ID systems are protected by adequate legal, regulatory and information technology (IT) standards. Improving the efficiency of public service delivery is critical for targeted strategies needed to accelerate poverty reduction and realize national development plans. Additional benefits outside the scope of this analysis include improving coverage and reducing error in social security systems for the informal sector, voter registration, payroll and tax administration and civil service management. Finally, financial savings permit creating the fiscal space needed to support mid- to long-term sustainability and equity of public resources, particularly in low-income and in ECOWAS. 87. The Bank has unique policy and technical value-add to supporting the development of the fID system financed by this operation. Importantly, the Bank’s substantial global in-house technical expertise is unique, combining broad analytic capacity and operational guidance specific to the roll-out of robust, sustainable and inclusive fID systems, particularly through leveraging the global ID4D Program managed by the Bank. This expertise stems from long-standing, detailed evaluations of global lessons learned from country case studies, as well as the regular convening of topical internal and external experts on technical standards, costing and technology. Bank engagement is expected to facilitate broad cross-sectoral dialogue on fID systems across government agencies, with individuals and between the public and private sector, therein boosting constructive cooperation across all key stakeholders. Further, at the regional, pan-SSA and global levels, the geographic and political breadth of the World Bank’s engagements enables it to simultaneously convene various member states and the ECOWAS Commission. In short, the technical, economic and financial support of the Bank to ECOWAS member states, as well as to the regional body itself, has the potential to generate significant benefits in terms of access to services for millions of individuals, improve the regional economy and create fiscal space to help sustain the system in the long run. B. Fiduciary 1. Financial Management 88. Overall Conclusion: The conclusion of the assessment is that the Financial Management (FM) arrangements in place in the implementing entities—ONI in Côte d’Ivoire, the PMO in Guinea and the ECOWAS Commission—all meet the Bank’s minimum requirements under the Bank Policy/Bank Directive for IPF, and therefore are adequate to provide, with reasonable assurance, accurate and timely information on the status of the Project funds required by the Bank. The overall FM residual risk rating is Moderate for the ECOWAS regional part of the Project, and Substantial for the Côte d’Ivoire and Guinea parts, respectively. (See Annex 3 for an FM Action Plan to enhance the FM arrangements for the Project.) 89. An FM Assessment was conducted on the FM arrangements for the WURI Project that will be implemented at the national level by ONI in Côte d’Ivoire and by the PMO in Guinea and, at the regional level, by the ECOWAS Commission. The objective of the assessment was to determine: (i) whether these implementing entities have adequate FM arrangements (e.g., planning, budgeting, accounting, internal control, funds flow, financial reporting, auditing arrangements) to ensure that project funds will be used for purposes intended in an efficient and economical way; (ii) project financial reports will be prepared in an accurate, reliable and timely manner; and (iii) the Project’s assets will be safeguarded. The FM assessment was carried out in accordance with the Financial Management Manual for World Bank Investment Project Financing Operations that became effective 53 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) on 1st March 2010 and as last revised on 10th February 2017. In this regard, a review of the FM arrangements has been conducted for the above entities as further detailed below. i. Côte d’Ivoire: The overall FM risk for the Côte d’Ivoire component of the Project is rated Substantial. This is due to (i) the ONI’s lack of experience and familiarity with Bank-FM procedures; (ii) project design, which involves several actors with beneficiaries based in the countryside; and (iii) some project activities that are prone to irregularities. ONI’s Directorate of Administration and Finance (DFA) will have adequate capacity to effectively manage Bank funds once the following measures are implemented prior to and after project effectiveness: (i) competitively appoint the following FM staff familiar with Bank FM requirements: recruitment of one principal/senior FM Officer and one accountant; (ii) draft the FM procedures manual; and (iii) acquire and install the accounting software and train the users of the software. Furthermore, as ONI is an “etablissement public national à caratère administrative” (EPA) under the responsibility of the Ministry of Interior, ONI’s Budget Controller and the Public Accountant will be involved in the implementation of the Project. 95 Finally, ONI will be required to prepare and submit the following to IDA: (i) annual work plan and budgets approved by its governance body; (ii) quarterly interim un-audited financial statements (IFR) 45 days following the end of each calendar quarter; and (iii) audited annual financial statements six months following the end of the calendar. Further, two bank accounts will be opened: (i) one DA in CFAF at the Central Bank of West African States (BCEAO); and (ii) a transaction account in a commercial bank on terms and conditions acceptable to the Bank. The transaction account will be managed by the Public Accountant on terms and conditions acceptable. ii. Guinea: The overall FM risk for the Guinea component of the Project is rated Substantial. The FM assessment of the PMO was conducted to check whether this office could manage the Project. The main findings arising from this assessment showed the following weaknesses for the PMO: (i) capacity- shortage in the areas of FM human resources; (ii) lack of familiarity of the FM team with Bank-financed project procedures and requirements; and (iii) lack of project accounting software and efficient internal audit function. Due to the overall fragility of the country FM systems, and specifically the critical areas for improvements of the PMO, the conclusion was that PMO could be in a position of managing Bank’s funds once a number of measures are implemented to strengthen its current FM system beginning with the creation of a PIU inside the PMO, with the PIU’s FM team being the Bank’s main counterpart and focal point for all fiduciary aspects of the Project. Implementation of the Project will require specific FM arrangements as follows: (i) recruitment of one FM Officer and one accountant; (ii) preparation of a PIM, including FM procedures; (iii) acquisition of the accounting software to allow the recording of project transactions; (iv) recruitment of an internal auditor to conduct ex-post reviews of project transactions; and (v) recruitment of an external auditor for auditing annual financial statement. These actions will be completed on time to help implement the Project. Funds from the Bank will be disbursed to a DA denominated in US$ opened at the Central Bank of Guinea. The PMO will in addition open a Project Account denominated in Guinean Francs opened in a commercial bank acceptable to the Bank. iii. ECOWAS Commission: The overall FM risk for the ECOWAS component of the Project is rated Moderate. The External Fund Management Unit in the Finance Department of the Commission will be responsible for accounting for and reporting on the use of project funds. The Unit is experienced in 95 Per Côte d’Ivoire’s PFM system, and décret n° 2015-475 (1 juillet 2015). 54 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) the implementation of Bank-financed projects having implemented Bank-assisted projects in the past and is currently implementing the Natural Disaster Risk Reduction Program. While the Commission has adequate FM arrangements in place (see Annex 3), the Commission will need to take the following actions to strengthen its financial management system in order to implement the Project: (i) designate an accountant for the Project;(ii) agree with the Bank on the format of the unaudited Interim Financial Reports; and (iii) agree with the Bank on the external audit ToRs. Furthermore, the Commission will open a segregated Designated Account (DA) denominated in United States Dollars (US$) to receive disbursements from the Bank and a Project Account denominated in Naira. Both accounts shall be opened in a commercial bank acceptable to the Bank. 2. Procurement 90. Procurement under the Project will be carried out in accordance with the World Bank’s New Procurement Framework: (i) Procurement Regulations for IPF Borrowers (1st July 2016, revised as of 1st November 2017); and (ii) Guidelines on Preventing and Combating Fraud and Corruption in Projects Financed by IBRD Loans and IDA Credits and Grants (15th October 2006, revised as of 1st July 2016); and (iii) other provisions stipulated in the Financing Agreements. 91. Procurement shall be carried out (i) at the national level by the PIUs in Côte d’Ivoire and Guinea for phase 1 and (ii) at the regional level by the ECOWAS Commission. The Bank has assessed the implementation arrangements. The procurement risk is rated as Substantial. To address the risks and weaknesses identified, mitigation measures have been discussed and agreed with the PIUs respectively. (See Annex 3: for the Implementation Support Plan, including details of the procurement arrangements.) 92. An initial Procurement Plan has been developed and agreed upon with the ECOWAS Commission and the participating countries, respectively, covering the activities of the first 18 months of project implementation. The Procurement Plan will be updated in agreement with the Bank annually or as required to reflect the Project’s actual implementation needs and improvements in institutional capacity. C. Safeguards 1. Environment (including Safeguards) 93. The Project is rated as a Safeguards Category B, consistent with the provision of OP/BP 4.01 Environmental Assessment. The Project is expected to have minimal to no adverse environmental impacts as no civil works are financed. No other environmental or social safeguards policy is triggered. 94. The Bank will do its due diligence on environmental and social policies for all phases of the Program. The phase will be re-submitted for Board approval in the event it is assessed as Category A under the current Operational Policies or classified as “High” or “Substantial” risk under the Environmental and Social Framework. Relevant safeguards instruments, as appropriate, will be promptly disclosed during the preparation of the future phases. 2. Social (including Safeguards) 95. Government-recognized IDs that are mutually recognizable across ECOWAS member states will have substantial social benefits. Mutually-recognized IDs will expedite travel, limit costs (to both the state and the 55 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) individual), cut down on corruption and harassment and help combat human trafficking. fIDs will eventually facilitate service access and delivery across the ECOWAS region. In this regard, the benefits will be particularly evident for frequent travelers, such as cross-border traders and those residing in border regions. 96. The universality of the government-recognized IDs will help to break patterns of exclusion and discrimination, especially for the historically marginalized. Due attention will be given throughout the ID life cycle (see Annex 1) to ensuring that vulnerable groups are included and that discrimination is actively combated. With the support of a Rapid Social Response (RSR) Program 96, vulnerable groups in each country will be identified through consultations and other stakeholder engagement (SE) activities and targeted for inclusion. Doing so will help close the feedback loop between people and governments. Outreach strategies will incorporate tailored measures to target obstacles—logistical, cost (including indirect fees), distance—to assure universality. Techniques, such as home-based registration and mobile registration units, can help reach the elderly, women, persons with disabilities and illiterate 97 population, as well as those living in isolated communities. The government-recognized ID will be free of charge, ensuring inclusion of the poorest and special attention will be given to ensuring accessible, culturally-sensitive implementation, with efforts supported through strong collaboration with national human right bodies, local civil society organizations (CSOs) and international non- governmental organizations (NGOs) and agencies (UNICEF, UNHCR, IOM) (see Annex 4). Further, risks of exclusion will be managed through (i) training registration teams, at all levels, in non-discrimination and cultural awareness and sensitivity; (ii) public information and awareness campaigns to inform users of their rights; (iii) development of a non-discrimination policy by the relevant national identity agency; (iv) development of strong GRM; and (v) hiring of locals to help with uptake and any cultural adaptations needed. Further, stakeholder engagement indicators (aiming at effective benefits delivery through transparency and accountability, stakeholder participation, grievance redress, monitoring and mitigation of project risks) are included as part of the RFM and M&E system. 97. Understanding barriers at the individual and community level is paramount to guaranteeing universal inclusion. With support from both the RSR and (for Côte d’Ivoire) a human-centered design study, the Project will conduct qualitative and ethnographic research to better understand user issues, including barriers, data sharing and usage concerns, and reservations in uptake, as well as experiences with previous identification efforts and/or with accessing services due to the lack of identification. This qualitative research will be complemented through targeted research with key hard-to-reach groups and focus group discussions, roundtables and consultations with civil society and members of these vulnerable groups. These will be the basis for national-level Social Assessment and Management Plan (SAMP) that will be prepared during implementation to inform the design of the fID systems under Component 2 and will provide a roadmap for the overall implementation of the Project. Preliminary social risk analysis and roundtable discussions with stakeholders is being conducted during preparation to inform the design of the Project. An initial assessment is being undertaken. Further, a ToR for a consultant to conduct a full SAMP for each of the two phase 1 countries (Côte d’Ivoire and Guinea) was developed and has been disclosed on the Bank’s external website on the 29th March 2018. 98. Stakeholder engagement, awareness campaigns and social accountability measures are integral to the Project’s success. In each country, the PIU will be responsible for developing national, project-specific, 96 World Bank. 2017. RSR12 Engaging Marginalized Groups in the Design of Identification Systems in Africa - P164513. RSR Proposal. World Bank. 97 Adult literacy levels are 43.91 and 32 percent in Côte d’Ivoire and in Guinea, respectively. Levels are lower among women: 36.8 and 21.96 percent, respectively. UNESCO Institute of Statistics. 2018. “Data for Sustainable Development”. Website. UNESCO. http://uis.unesco.org/en/home#tabs-0-uis_home_top_menus-3. 56 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) Stakeholder Engagement Plans, drafts of which will be prepared during implementation. A gender-sensitive approach will be adopted in all engagement activities. To coordinate and implement the GRM, the PIUs will recruit one full-time, senior social development specialist and one support staff. Additionally, each PIU will ensure that the views of direct project beneficiaries have been accounted for in project M&E and that an independent third party is retained to oversee implementation. 99. The Project will develop multi-level GRMs as part of the Stakeholder Engagement Plans. A GRM is a system which responds to queries or clarifications, resolves problems with implementation and efficiently and effectively addresses complaints. The GRM will (i) be responsive to the needs of beneficiaries; (ii) serve as a channel for soliciting enquiries, inviting suggestions and increasing participation; (iii) collect information to improve operational performance; (iv) enhance project legitimacy among stakeholders; (v) promote transparency and accountability; (vi) deter fraud and corruption; and (vi) mitigate project risks. In developing the GRM, multiple avenues for connecting with beneficiaries will be explored using technology-based channels—such as hotlines, mobile apps, text messaging and social media channels—to triage complaints to the relevant government agencies, in addition to alternative grievance-resolution channels, such as traditional or religious leaders. 100. The Project structurally limits concerns about the improper use, or sharing of, data leading to discrimination or targeted persecution by, first, the limited data in the fID system and, second, the development of a strong legal and institutional controls. First, the data collected for the fID system will be extremely limited and will not include any socio-economic or demographic data. Further, the assigned UNI will be unique, random and unintelligible. Second, the Project’s Component 1 focuses on strengthening the institutional and legal systems to guarantee privacy and confidentiality of data. The communications and stakeholder engagement campaigns, at the regional and country levels, will highlight the key benefits of the Project to users, users’ rights and availability of GRM. 101. Social safeguards: No civil works will be financed and no land acquisition is expected; therefore, OP/BP 4.12 Involuntary Resettlement is not triggered. There are no indigenous peoples as per the definition of OP/BP 4.10 Indigenous Peoples in Côte d’Ivoire or Guinea and thus OP/BP 4.10 Indigenous Peoples is not triggered. Nonetheless, the multilingual and multicultural richness of the countries, including the presence of pastoralists, require close collaboration with local and traditional authorities as well as consideration to certain ethnic groups that might be historically marginalized and thus less likely to participate in the Project without culturally appropriate outreach and consultation efforts. This will be done through the social analysis explained above. 3. Other Safeguards 102. No other safeguards are triggered. 4. Grievance Redress Mechanism 103. Communities and individuals who believe that they are adversely affected by a World Bank (WB) supported project may submit complaints to existing project-level, grievance redress mechanism (GRM) or the WB’s Grievance Redress Service (GRS). Project affected communities and individuals may submit their complaint to the WB’s independent Inspection Panel which determines whether harm occurred, or could occur, as a result of WB non-compliance with its policies and procedures. Complaints may be submitted at any time after concerns have been brought directly to the World Bank’s attention, and Bank Management has been given an opportunity to respond. For information on how to submit complaints to the World Bank’s corporate Grievance Redress 57 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) Service (GRS), please visit http://www.worldbank.org/en/projects-operations/products-and-services/grievance- redress-service. For information on how to submit complaints to the World Bank Inspection Panel, please visit www.inspectionpanel.org. V. KEY RISKS 104. While identification can raise sensitive political issues, they can be managed, allowing identification to render truly transformative results, notably by making the invisible visible, facilitating access to services and preventing wastage of scarce resources. Issues around identification are being managed by the commitments of all ECOWAS member states to the underlying principles on ID systems, established by the World Bank and its partners. These principles center around (i) inclusion: universal coverage and accessibility; (ii) design: robust, secure, responsive and sustainable; and (iii) governance: building trust by protecting privacy and user rights. Adherence to these principles facilitates management of concerns surrounding identification. Risks are also mitigated by the agreement of the participating countries to develop the fID system based on physical presence in the territory, irrespective of legal status. 105. The overall risk for the MPA is High. Table 7 presents programmatic risks by category. Primary risks arise from: (i) unstable and fragile politics and governance; (ii) sector strategies and policies related to IDs; (iii) technical design; (iv) low institutional capacity for implementation; (v) structuring a regional project around IDs given national interests and prerogatives; and (vi) fiduciary factors. Table 7: Risk Rating Risk Categories Rating Political and Governance Substantial Macroeconomic Moderate Sector strategies and policies High Technical design of project or program High Institutional capacity for implementation and sustainability High Fiduciary Substantial Environment and social Substantial Stakeholders High Other: Lack of Technology Neutrality and Vendor Lock-in High OVERALL HIGH 106. Political and Governance risks are Substantial. A high-level of political commitment is necessary across all counterparts to successfully implement significant and potentially complicated legal and regulatory reforms. In Côte d’Ivoire, the Government is pursuing its reconciliation agenda with opposition parties and the peaceful 2015 presidential election helped further stabilize and normalize the sociopolitical situation. Despite positive developments, political instability and fragility are possible and, if arising, could hinder project implementation. The next presidential elections will take place in late-2020, which is still within the Project timeline, though investments will be frontloaded limiting some of the risks posed by elections. The Project has cross-cutting appeal, not tied to any political group, with a clear economic rationale. However, the question of citizenship has been used in the past to capture power, which has had detrimental effects on social cohesion and led to conflict and social tension. Political pressure could cause the Government of Côte d’Ivoire to move too quickly on project implementation, foregoing critical legal reforms or procuring inadequate systems if not supervised closely. Such 58 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) concerns are being addressed, however, with the Government recently officially recognizing ONI as the entity charged with developing the fID system.98 In Guinea, the PMO is spearheading the ID agenda. Sustained high level leadership and support for the initiative over the long term across the political spectrum, provides the essential foundation for change. As in Côte d’Ivoire, the next presidential election will take place in 2020. In order to mitigate the risk to project continuity in the instance of the Government changing, it is critical for Guinea to establish an independent ID agency with the capacity to coordinate across horizontal and vertical levels of government, to oversee the implementation of the Project and to clarify institutional arrangements for the Project. However, the Government established the Ministère des Postes, des Télécommunications et de l'Economie Numérique (Ministry for ICT) as having reserve authority. 99 107. Macroeconomic risks to the Project are Moderate. In Côte d’Ivoire, macroeconomic risks to the Project are Moderate, primarily due to the need for fiscal adjustment over the next few years and re-emerging tensions in the build-up to the 2020 elections. However, the overall context is not expected to negatively impact the Project. The country registered an average real growth rate of 8.5 percent per year (among the highest in the SSA region) over 2012–15, impelled by agriculture, services, industry, increased domestic demand and rising investment. The economic outlook for the next three years is positive, given several factors including a growth rate that is expected to top off around 7 percent, the maintenance of moderate inflation and the control of public finances through prudent fiscal and monetary policies, as well as the furtherance of reforms aimed at improving the business climate and facilitating the efficient use of PPPs. At the same time, the Government must reduce its fiscal deficit by approximately 1.5 percent of GDP over the next two years in order to ensure fiscal and debt sustainability, in line with the International Monetary Fund (IMF)-supported program and WAEMU targets. While this adjustment is manageable, it will require redoubling efforts in terms of revenue mobilization and containing public spending and it will take place as the country prepares for the forthcoming presidential elections in 2020. In Guinea, macroeconomic risks are Substantial, although the impact on the Project is Moderate. Policy slippages, delays in structural reforms and external vulnerabilities constitute important risks. External risks include: a growth slowdown in China and advanced economies (which could reduce investment in Guinea and demand for its mineral resources); tighter or more volatile global financial conditions and another decline in commodity prices. On the domestic front, socio-political tensions stemming from local elections and the run-up to the 2018 legislative elections could also undermine near-term growth and policy reforms. Domestic capacity and financial constraints in implementing infrastructure projects and delays in structural reforms could also weaken medium-term growth prospects. However, Guinea benefits from a track record of recent successful macroeconomic stabilization and has a favorable medium-term outlook. The new three-year IMF ECF (Extended Credit facility) program approved in December 2017 is also an important mitigating factor. 108. Sector strategy and policy risks are High. The Project must enable demand for IDs based on demand for access to services and vice versa. Importantly, the demand from service providers (e.g., social protection, health) vanishes if there is no demand on the other side (i.e., uptake of fIDs), a chicken or egg situation. The fID system will need to obtain a critical mass of users on one side (i.e., near universal coverage) to stimulate demand from service providers to use the fIDs in order to authenticate their services. Thus, if the Project is unable to devise an agreement with key service providers to use the fIDs to authenticate for services such as G2P cash transfers, end- users will see little use for enrolling in the fID system. In order to mitigate these risks, the Project will ensure that MoUs are signed with key service providers prior to implementation and rollout of the fID system. 98 Arrêté n° 079/PM/CAB (6 février 2018). 99 Arrêté n° A/2017/6390/PM/CAB/SGG (28 novembre 2017). 59 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) 109. Technical Design risks are High. There have been a number of previous attempts to build national ID systems in Côte d’Ivoire and Guinea. It will be important to have commitment from the government that the data collected from previous attempts will be converted, migrated or integrated within a prescribed timeframe to maximize the use of the fID system and to ensure that people benefit rather than having yet another form of identity. The regional nature of the Project adds a layer of complexity to the technical design, as the systems should be mutually recognized and eventually facilitate cross-border access to services. To mitigate these risks, ECOWAS will convene an internal task force on identification to supervise the work under the grant, led by the Commissioner for Trade, Customs, Industry & Mines, Free Movement of Persons & Tourism, the primary counterpart for the MPA, and will include the Commission of ICT, Commission of Social Affairs and the Community Development Programme, with others to be added, as necessary. The task force will implement comprehensive change management plans to sensitize stakeholders, within and across member states, to have a mutual understanding of the importance of a regional approach, commencing with the establishment of fID systems at the national level. The task force will include representatives of public and private sector services to ensure a smooth transition to facilitate access to services, Component 3, as the systems are rolled out. Throughout the Project, the ECOWAS Commission will monitor regional progress towards the achievement of mutually recognized fID systems. 110. Institutional capacity for implementation risks are High. Weak institutional capacity would impact project implementation. The initial assessment indicates that neither ONI, nor the PIU within the PMO have the capacity to manage the social risks highlighted below. In Côte d’Ivoire, ONI has the sole mandate for ID matters and has substantial experience and capacity in the area of ID systems. In Guinea, implementation arrangements are complex and span several agencies. Some of these agencies have limited experience implementing World Bank projects and complying with fiduciary, safeguards and project management requirements. To manage these risks, the Project will seek to competitively recruit appropriately skilled staff and/or build technical capacity and skills to steer the Program agenda both at the country level in Côte d’Ivoire and Guinea in phase 1 and, at the regional level, within the ECOWAS Commission. Further, these risks will be managed through capacity-building initiatives, including training for the PIUs on the Bank’s fiduciary procedures, the new procurement framework, safeguards and project management. Furthermore, previous experience with Bank operations has shown that the ECOWAS Commission has limited capacity. The Project will also seek to strengthen the implementation capacity of the DFMT, to help achieve these objectives. 111. Fiduciary risks are Substantial. Counterparts’ fiduciary capabilities also differ and could impede project implementation. Delays in implementation of the foundational elements of the Project and/or lack of buy-in from partner agencies would affect the Project’s capacity to meet project objectives and to link national IDs to service delivery. In Côte d’Ivoire, procurement and financial management risks are both rated Substantial. In Guinea, procurement and financial management risks are both rated Substantial due to the multiple implementation agencies involved and the lack of experience with the World Bank’s fiduciary procedures. Allegations of fraud and corruption have come up in previous projects related to identification, biometrics and electoral rolls. Technology vendor lock-in could result in higher future maintenance costs. To mitigate these risks, the Project will adopt an FM procedures manual and will competitively recruit senior FM staff familiar with World Bank fiduciary procedures. Capacity building will be planned prior to project effectiveness and training and hands-on advice will be provided to FM and procurement staff. Funds will be controlled and audited ex-ante and ex-post. A computerized accounting system will be used. IFR and financial statements have been agreed upon. Audits will include field visits and reports on the findings of physical controls of goods, services and works acquired the Project. Civil society and other stakeholder participation is built into the Project’s design and will enable social 60 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) accountability and monitoring of the use of funds. The Project will be designed to be technology neutral and to avoid vendor lock-in through the use of open standards based procurement. 112. Social risks are Substantial. Historically, ID systems have led to exclusion because of gaps in nationality laws and their application, having negative impacts upon vulnerable groups. As discussed, the universality of the government-recognized IDs will help to break patterns of exclusion and discrimination, especially for the historically marginalized. Further, the RSR will be used to address risks of exclusion by aiming to reflect project impact, both positive and negative, on people’s daily lives through the financing of both national consultations, and of South-South learning on privacy, freedom of movement and access to services. Strong public awareness campaigns, tailored outreach strategies, an inclusive and transparent communications plan, a robust GRM and continuous stakeholder engagement will further help management of this risk. The Project structurally limits concerns about the improper use or sharing of data leading to discrimination or targeted persecution by, first, the limited data in the fID system and, second, the development of a strong legal and institutional controls. Both Côte d’Ivoire 100 and Guinea 101 have robust personal data protection laws in place. Further, both, by separate instrument, have created data protection agencies: in Côte d’Ivoire, the Autorité de Régulation des Télécommunications (ARTCI) 102, operating under the auspices of Ministère de la Communication, de l'Economie numérique et de la Poste (Ministry for ICT) 103 and, in Guinea, the Agence Nationale de la Sécurité des Systèmes d'Information (ANSSI) 104, operating under the auspices of the Ministère des Postes, des Télécommunications et de l'Economie Numérique (Ministry for ICT) 105,106. In addition, the Project will finance third party monitoring through civil society organizations (CSOs) as part of the social-risks mitigation plan. Operationally, the Project will also explore a user-consent framework that can alert users in real-time when their data is requested or shared by the fID system, therein providing users with even greater assurance. 113. Stakeholder risks are High. In Guinea, the stakeholder risks are high as several ministries seek to play a leading role. This is being mitigated by placing the PIU under the PM’s office and setting up clear roles for different stakeholders. In Côte d’Ivoire, while ONI has been tasked with fID and CR systems, its historical expertise principally pertains to issues of nationality. As in Guinea, the PMO plays a leading role and will help mitigate this risk. Furthermore, the Bank’s convening role among both public and private stakeholders and donor partners will be used to mitigate these risks in both of these countries. Nevertheless, the residual risk is kept high as institutional roles and players may change over the course of implementation. 114. Other risks related to technology neutrality and vendor lock-in are High. On the technology front, it is critical that counterparts adopt a technology-neutral approach which avoids vendor lock-in (see Box 2, page 36) thereby ensuring value for money and ease of maintenance or future revision of the systems. To mitigate these risks, foundational technology components must be carefully sequenced and common technology standards established to ensure technology neutrality. The use of PPPs could be explored to work closely with and to invest 100 Loi n° 2013-450 (19 juin 2013) relative à la protection des données à caractère personnel. 101 Loi n° 2016-037 (28 juillet 2016) relative à la cyber-sécurité et la protection des données à caractère personnel en République de Guinée. 102 “Telecommunications Regulatory Authority”. 103 “Ministry of Communication, of the Digital Economy and of Telecommunications”. See Ministère de la Communication, de l'Economie numérique et de la Poste. 2018. “Autorité de Régulation des Télécommunications (ARTCI)”. Website. République de Côte d’Ivoire. http://www.artci.ci/. 104 “National Information System Security Agency”. 105 “Ministry of Post, Telecommunications and the Digital Economy”. 106 Ministère des Postes, des Télécommunications et de l'Economie Numérique. 2018. “Autorité de Régulation des Postes et Télécommunications (ARPT)”. Website. République de Guinée. http://www.arpt.gov.gn/. 61 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) in strengthening the overall capacity of the public and private sector in the country, and to leverage these for improvements in the public sector more broadly through the ID initiative. In order to mitigate risks related to legacy systems and parallel efforts, the Project will (i) review existing ICT infrastructure and connectivity, (ii) examine the possibility of migrating data from prior and/or failed ID efforts and (iii) ensure linkages with existing relevant systems and legacy systems. High-level, specialized support on complex procurement packages will be sought, for instance on performance-based contracts, open standards in bidding documents, data ownership contract clauses, preventing vendor lock-in and ensuring technology neutrality. Further, a technical architect in each country PIU could help coordinate design and provide critical local technical support. 115. Climate risks pose very little threat to the Project at regional and national levels. The operation has been screened for short- and long-term climate change and disaster risks. Small physical investments will be made to set up data centers and fID system infrastructure at national levels (e.g., servers, computers, tablets). Extreme temperature, precipitation and flooding could pose a risk to these systems but they will be designed and installed with these risks in mind and highly secured in urban areas. In rural areas, equipment may be slightly exposed but mitigation measures will be taken. 116. To mitigate risks overall, each phase of the MPA will follow a modular approach, focusing on Component 1, to strengthen the legal and institutional framework, linking to Component 2 to establish fID systems and facilitating access to services through Component 3. Implementation of components will be undertaken simultaneously (See Box 3.) Box 3: Managing Political Risks through Parallel Tracking of Components The Project will, in parallel tracks, simultaneously develop Components 1 and 2, thereby economizing both time and political will, while also developing a more effective and better tailored foundational ID (fID) system law. Further, while the Project includes a legal covenant on implementing a fID system law, it is not time-bound, as doing so risks hasty compliance, thereby undermining the gains made through parallel tracking. The covenant equally applies to a fID system law that materially and adversely affects the achievement of the objectives of the Project; as participating countries are obliged to adhere to the ID4D Principles (see Figure 5, page 69), this provision, ensures, inter alia, open standards, technology neutrality and protects against vendor lock-in. While the intent is to have the governing legislation in place before the fID system is operational, the Project will guide the development of the legal and institutional framework according to the Project’s requirements through other elements (see below), culminating in the fID system law once an appropriate and properly tailed legislative base can be developed. Following the Napoleonic tradition, laws in both Côte d’Ivoire and Guinea tend provide more of a “framework”, with most of the detail relegated to implementing decrees; as such, and following the studies of sub-component 1.1 (see Annex 1), it is likely that, with proper upfront direction and guidance, a fID system law can be speedily legislated. It is anticipated that subsequent phases will benefit particularly greatly from Component 1 experiences. Furthermore, doing as much within the context of the MPA approach has the additional advantage of facilitating the process in subsequent participating countries and encouraging knowledge sharing and lesson learning. The following elements will help guide the development of the fID system law: (1) Data Protection Laws: Assuring data protection and privacy is a key element of the Project and of the fID system. The Project will benefit from the fact that both Côte d’Ivoire and Guinea already have robust data protection laws in place and, by separate instrument, data protection agencies. Thus, even before development of the fID system law, the existence of these laws puts the countries on the right footing; further, assurances have already been 62 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) given by both countries that the laws will indeed apply to the fID system. In due course, the fID system law will notify in its text that the fID system is subject thereto. (2) Inclusiveness: In order to be inclusive, the fID system is to be of universal application for all persons in the territory of the country. With questions of nationality out of the discussion because the fID system will serve as a proof of identity without connoting legal status, the universal applicability of the fID system will not be called into question. Risks are also mitigated by the agreement of the participating countries to develop the fID system based on physical presence in the territory, irrespective of legal status. (3) ID4D Principles: All participating states are obliged, as a precondition, to sign up to the ID4D Principles, guaranteeing adherence of the fID system to international good practices of inclusiveness (universal coverage and accessibility), design (robust, secure, responsive and sustainable) and governance (trust, privacy and user rights). Adherence to these principles facilitates management of concerns surrounding identification. (4) Executive Instruments: Executive instruments—décrets, arrêtés, directives—will be used to shape the direction until such time that the fID system law exists. Indeed, Côte d’Ivoire recently issued an arrêté 107 specifically puts the ID agency (ONI) at the center of the process of developing the law for the fID system, both in the identification and execution phases, and Guinea is in the process of exploring what its own ID agency will look like. (5) Regional Coordination through ECOWAS: To whatever extent possible, the Project will lean on the ECOWAS Commission and the ECOWAS Protocols to help create as smooth and unified of a regional solution as possible, one which respects the ID4D Principles, etc. VI. RESULTS FRAMEWORK AND MONITORING RESULTS FRAMEWORK Program Development Objective (PrDO): To increase the number of persons in participating countries who have government-recognized proof of unique identity that facilitates their access to services. Phase 1 Project Development Objective(s) (PDO): The PDO for phase 1 of the Project is to increase the number of persons in the Republic of Côte d’Ivoire and the Republic of Guinea who have government-recognized proof of unique identity that facilitates their access to services. Key PDO Indicators (with baselines and targets): Baseline End Target Unit Y0 Y6 PDO Indicators Indicator 1: Legal Robustness: Development of Yes/No No Yes foundational ID (fID) system enabling legal and institutional framework (including relevant data protection and privacy Objective/ laws and a mandated ID agency and data protection Outcome 1: agency), in keeping with regional standards and international good practices. Indicator 2: Technical Robustness: Development of fID Yes/No No Yes system which generates UNIs, in keeping with international good practices. 107 Arrêté n° 079/PM/CAB (6 février 2018). 63 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) Indicator 3: Inclusion & Coverage: Number of direct project Number 0 35 m Objective/ beneficiaries who have received a UNI (of which women). (17 m) Outcome 2: Indicator 4: Access to Services: Number of national or Number 0 2 regional functional public and private services linked to the fID system. Intermediate Results (IR) Indicators IR Indicator 1: Robustness (Data Quality): Percentage of Percentage 0 100% individuals in the fID system whose biometric and demographic data meet international quality standards. IR Indicator 2: Robustness (Sustainability): Percentage of Percentage 0 80% Component newborn birth registrations that are assigned UNIs. 1: IR Indicator 3: Robustness (Legal): The law for the fID Yes/No No Yes system has been created, establishing, inter alia, the system’s inclusivity for all persons in the country, UNI (a unique, random, unintelligible number), linking to the CR system, and assuring data protection and privacy. IR Indicator 4: Stakeholder Engagement: Regular Yes/No No Yes consultations held with beneficiaries, ID stakeholders, marginalized groups and government to solicit feedback and report on actions taken to address feedback since prior consultations. IR Indicator 5: Stakeholder Engagement: Percentage of Percentage 0 90% Component grievances responded to and/or resolved within the 2: stipulated service standards for response times. IR Indicator 6: Access to Services: Number of digital No. 0 1600 authentications made by functional users (by sector or service) per month on behalf of their beneficiaries or clients (of which percent on behalf of women). IR Indicator 7: Readiness: The fID system is operational and Yes/No No Yes ready for rollout. 64 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) ANNEX 1: DETAILED PROJECT DESCRIPTION COUNTRY: Western Africa West Africa Unique Identification for Regional Integration and Inclusion (WURI) This Annex gives a brief country description, and then outlines the broad scope of each Component as a generic framework to be applied and adjusted to the country-specific context, and then describes how they apply phase 1 of the MPA (Côte d’Ivoire, Guinea and the ECOWAS Commission). *** A. Project Context 1. Côte d’Ivoire 1. Despite strong economic performance since the 2011 political crisis (fueled by inequality and questions of nationality), Côte d’Ivoire faces significant development challenges, including low coverage and lack of robustness of identification systems. Access to health and education services is low, especially among women: while 35 percent of adults over the age of fifteen have bank accounts, that figure falls to 12 percent for women of that group. Increased statelessness and a great number of migrants further exacerbate access to services by putting pressure on institutions. 2. Côte d’Ivoire has a specific, decree-established 108 agency for national identification—the Office National d’Identification (ONI)—as the sole authority with the mandate for ID and CR matters, a mandate that was firmed-up following the Ouagadougou Political Agreement. 109 Côte d’Ivoire has an identification law 110, as well as robust data protection 111 and cybercrime laws 112. It also has a data protection agency—Agence de Sécurité et Protection Côte d’Ivoire (ASPCI) 113—established under the auspices of Ministère de la Communication, de l'Economie numérique et de la Poste (Ministry for ICT). Further, ONI was recently made the central agency in developing the law for the fID system.114 3. Côte d’Ivoire has a very low ID coverage, with records missing for an estimated 60 percent of the population and only 55 percent of birth registration covered, impacting access to services that require proof of identity. Côte d’Ivoire’s National ID Card System covers less than 64 percent of the population over the age of 16 108 Décret n° 2004-28 (15 février 2001) portant modification de décret n° 2001-103 (15 février 2001) portant création de l’Office national d’Identification (« ONI »). 109 Accord Politique de Ouagadougou (4 mars 2007). https://peacemaker.un.org/sites/peacemaker.un.org/files/CI_070304_Accord%20Politique%20de%20Ouagadougou%20%28French%29.p df. Pursuant to this agreement, the parties, among other things, decided to accelerate the identification of populations. 110 Loi n° 2004-303 (3 mai 2004) portant modification de la loi n° 2002-03 (3 janv. 2002) relative à l’identification des personnes et au séjour des étranger en Côte d’Ivoire. 111 Loi n° 2013-450 (19 juin 2013) relative à la protection des données à caractère personnel. http://www.artci.ci/images/stories/pdf/lois/loi_2013_450.pdf. 112 Loi n° 2013-451 (19 juin 2013) relative à la lutte contre la cybercriminalité. http://www.artci.ci/images/stories/pdf/lois/loi_2013_546.pdf. 113 Ordonnance n° 293 (21 mars 2012) relative à la protection des données à caractère personnel. http://www.droit- afrique.com/upload/doc/cote-divoire/RCI-Code-2012-telecommunications.pdf. 114 Arrêté n° 079/PM/CAB (6 février 2018). 65 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) years of age. Furthermore, personal data in that system is not securely encrypted, a matter of concern as ID enrollment is done using biometrics. 2. Guinea 4. Notwithstanding its 2010 democratic transition and the introduction of numerous public-sector reforms, Guinea remains one of the poorest countries in the world. Poverty rates have increased from 40.3 percent to 55.2 percent, with rural populations disproportionately affected. On the demand side, individuals face multiple constraints to accessing services, ranging from high service fees, distance, lack of trust in the public sector, and cultural and social barriers. This impacts the national identification coverage and birth registration logistics. 5. Guinea has weak institutional and legal frameworks for a fID system. Despite its multiple past efforts to roll-out national ID programs, Guinea does not have a specialized agency to oversee fID system initiatives. Further, while having a robust data protection and cybercrime law, and a data protection agency—the Agence Nationale de la Sécurité des Systèmes d'Information (ANSSI), operating under the auspices of the Ministère des Postes, des Télécommunications et de l'Economie Numérique (Ministry for ICT) 115—it does not have a legal framework or institutional base upon which a fID system might be built. 6. In Guinea, a country of only 13.2 million, poor management of the CR by municipal authorities has resulted in low birth-registration rate (only 58 percent), further impeding access to services. Successive governments have tried to address service-delivery issues by designing ad hoc functional IDs. This approach, especially once coupled with fragmentation in ID systems management, has resulted in the creation of parallel ID systems, duplication and waste of scarce resources. The frequent and diverse need for IDs—for access to social welfare benefits, banking, registering to vote and more—highlight the need for a robust fID system with authentication processes. 7. Access to several services remains extremely low in Guinea, including education, health and financial services. Education attainment in Guinea is very low and can partly be linked to lack of government-recognized IDs required for school enrollment. Nearly 80 percent of adults older than 25 years-of-age have never been to school, with rural populations faring worst. 116 In the health sector, there are severe service delivery challenges in rural and poor urban communities, particularly for attended childbirths; strong fID and CR systems, from birth, could significantly help address these situations. Further, only 7 percent of the population 15 years-of-age and over has a formal bank account in Guinea. B. Project Components 8. The proposed MPA structures each country-level operation around three main components: (i) strengthening the legal and institutional framework; (ii) establishing robust and inclusive fID systems; and (iii) facilitating access to services through IDs (see Figure 4). This section outlines the broad scope of each Component. 115 Ministère des Postes, des Télécommunications et de l'Economie Numérique. 2018. “Autorité de Régulation des Postes et Télécommunications (ARPT)”. Website. République de Guinée. http://www.arpt.gov.gn/. 116 World Bank. 2018. “Guinea. Literacy rate, adult total (% of people ages 15 and above).” World Development. Website. World Bank. https://data.worldbank.org/indicator/SE.ADT.LITR.ZS?locations=GN. 66 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) Figure 4: Project Components 1. PROJECT COMPONENT 1 – Strengthening the Legal and Institutional Framework (ECOWAS: US$5m (SDR 3.4m); CI: US$2.3m (EUR 1.9m); GN: US$2.3m (SDR 1.6m)) COMPONENT 1 OVERVIEW: 9. The objective of this Component is to strengthen the legal and institutional framework for fID systems, including providing authentication processes that would allow for mutual recognition across participating ECOWAS member states, thereby facilitating access to services at both regional and country levels. In order to achieve this objective, this Component will generally finance activities to: i. Identify and address gaps in the existing legal, regulatory and institutional framework. This Component will finance technical assistance to elaborate national policy and to build out the legal and regulatory framework needed for a fID system that is mutually recognizable across ECOWAS member states. ii. Develop a law governing the fID system, and build and implement the surrounding legal and institutional measures necessary to the functioning of the fID system. This Component will develop the core law of the fID system. That law will, among other things, strictly delimit what information is collected; indicate the independent government authority responsible for the fID system; affirm that the data protection and privacy laws apply to the fID system; affirm that specialized ID systems and stakeholders, both public and private (e.g., banks, healthcare facilities, SIM-card providers) will be able to access and rely on the fID system (see Component 2, below); provide for sanctions for system abuse, including denial of services; and develop robust GRMs. Further executive instruments— décrets, arrêtés, directives—necessary for the full usage and functioning of the fID system will also be 67 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) developed. A strong emphasis will be on the ten principles identified in the Principles on Identification for Sustainable Development: Toward the Digital Age (ID4D Principles). (See Figure 5.) 117, 118 iii. Develop an enabling legal and regulatory environment, and build institutional capacity to strengthen the link between fID and CR systems. This Component will look to assuring the appropriate system linkages, so that fID and CR systems do not diverge. At an institutional level, the necessary investments will be made to build capacity in order to carry the Project forward, including investing in ongoing training for new and existing users and administrators. The focus will be on the central agency responsible for the fID system, with training extending to those capturing and inputting data into the fID system (including the capture of biometrics). iv. Conduct regional dialogue on mutual recognition of fID systems. The Program will facilitate dialogue leading to a definition of standards and protocols enabling interoperability of fID systems at the regional level. 10. Under phase 1 of the MPA, this Component will be implemented in Côte d’Ivoire and Guinea through the following sub-components and activities: 1.1 SUB-COMPONENT: Identify and address gaps in existing legal, regulatory and institutional frameworks for the fID system (CI: US$2.3m; GN: US$2.0) 1.1.1 Review of legal and regulatory frameworks (CI: US$0.9m; GN: US$1.0m) 11. This sub-component will finance technical assistance to Côte d’Ivoire and Guinea to identify and remediate gaps in existing legal, regulatory and institutional frameworks. The gap-filling exercise will ensure that existing legal and policy guarantees—notably those of non-discrimination, privacy, data protection and network security—apply to the fID system; if such is not the case, the appropriate revisions will be undertaken. Particular attention will be paid to the use of UNIs to assuring mutual recognition of systems, both within the country and at the regional level. 12. This sub-component will also support the elaboration of an identification policy and the development and implementation of a corresponding law creating the fID system, with a focus on allowing subsequent access to services by specialized ID systems on the basis of authentication processes allowed by the UNI. This sub- component will oversee the definition and publication of policies for the usage of the fID system, including standards on access, authentication, data sharing protocols and mutual recognition, in accordance with international good practices, and provide for usage and authentication by both the public and private sectors. The new fID system law will reaffirm such guarantees and create a system for all including and registering all persons in the territory of the country, including refugees, stateless persons and other vulnerable groups. That law will, among other things, strictly delimit what information is collected and provide for sanctions for abuse of the system, including denial of services. Further instruments necessary for the full usage and functioning of the fID 117WB ID4D “Sustainable Development” (2017). 118The African Development Bank (AfDB), Asian Development Bank (ADB), Bill and Melinda Gates Foundation (BMGF), Center for Global Development (CGD), Digital Impact Alliance (DIAL), ID4Africa, International Organization for Migration (IOM), Mastercard, Omidyar Network, Open Identity Exchange UK/Europe, Organization of American States, OSCE Office for Democratic Institutions and Human Rights (ODIHR), Plan International, Privacy and Consumer Advisory Group to the Government Digital Service and GOV.UK, Secure Identity Alliance (SIA), The GSMA, United Nations World Food Program (WFP), United Nations High Commissioner for Refugees (UNHCR), United Nations Children’s Fund (UNICEF), United Nations Development Program (UNDP), United Nations Economic Commission for Africa (UNECA), and the World Bank Group (WBG). 68 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) system will also be developed. Throughout, a strong emphasis will be on the ten principles identified in the ID4D Principles. It will also establish that the system can be used and relied upon by separate, specialized ID systems, both public and private, to ensure their regulatory frameworks also allow users to employ the authentication potential of the fID system. Individuals will be identified in the system through the assignation of a unique, random, and unintelligible identification number (i.e., the UNI). 13. Legal policies and protocols will be elaborated to allow integration and interoperability between fID and CR systems, as well as other relevant registries and databases. These policies and protocols will implement the legal framework for data exchange between fID and CR systems, and will detail the type of access, the various sanctioned use cases, technical protocols for data transfer and appropriate data privacy safeguards. These policies and protocols will extend to cover how other registries and databases—both public and private—might rely and access the fID system. Interoperability between fID and CR systems will ensure that, going forward, the uniqueness of civil records can be assured using the UNI. 14. Specifically, in Guinea, the Project will support the development of an institutional framework for implementing fID system. Guinea presently lacks a designated ID agency and necessary strategies for its fID system. This sub-component will support a consultative and transparent process for developing these strategies and mandating a body to lead management and implementation of the new fID system. 1.1.2 Institutional capacity-building for implementing agencies (CI: US$1.4m; GN: US$1.3m) 15. This sub-component will reinforce the capacity of implementing agencies to carry out the Project (CI: US$900,000; GN: US$400,000). It is expected that ONI in Côte d’Ivoire and the PMO in Guinea may require investments in their infrastructure and personnel. In Côte d’Ivoire, while ONI is an institution of abundant technical capacity that already has considerable experience in ID and CR activities, its capacity to execute the Project—especially given its recently expanded mandate—will be assessed and capacity gaps addressed. In Guinea, in the short term, the Project will ensure that the PMO has sufficient technical and project-management 69 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) personnel at its disposal; in the long term, the Project will help create and support the independent institution that will eventually be tasked with administering the fID system. 16. To ensure the sustainability of the new systems, this sub-component will provide ongoing training for new and existing users and administrators, including at decentralized levels (CI: US$500,000; GN: US$900,000). Existing civil servants who will use any of the systems will be targeted for additional and ongoing training, and the curricula used to train new civil servants (e.g., registrars, police) will be revised. Other personnel involved in the fID system’s use will also need training, including database administrators, card-production operators, programmers and various government officials. The training will include topics such as usage of the new digital systems; identification and resolution of common problems; roles and responsibilities; legal, security and privacy issues; and sensitization training on non-discrimination. 1.2 SUB-COMPONENT: Conduct regional dialogue on mutual recognition of fID systems (ECOWAS: US$5m) 17. This sub-component will foster inter-agency collaboration and strengthen regional engagement on the basis of the fID systems and the ECOWAS NBIC (ENBIC). Four activities underlie this sub-component: i. Develop and execute comprehensive, change-management plans to sensitize national ID and immigration stakeholders (both within and across participating ECOWAS member states), in order to create a mutual understanding of the importance of a phased approach to implementing ENBIC, commencing with the establishment of fID systems at the national level, and common standards and protocols at the regional level (see Figure 6); ii. Develop a roadmap to ENBIC for participating ECOWAS member states implementing fID systems under the Project, including clarification of technical standards for type and quality of data to be collected by national fID systems (e.g., demographic data, quality and format of biometric data, coding standards), data security and privacy (e.g., data storage guidelines, rules governing international use of data for public and private sectors, formats and protocols to use in data exchange); iii. Monitor regional progress towards the achievement of interoperable fID systems and ENBIC; and iv. Strengthen the implementation capacity of the ECOWAS Department of Free Movement and Tourism (DFMT), to help achieve these objectives. 70 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) Figure 6: Roadmap to ECOWAS NBIC 18. The ECOWAS Commission will convene an internal task force on identification to supervise the work under grant. The ECOWAS task force will be led by the DFMT, the primary counterpart for the MPA, and also will include representation from the Department of Telecommunication and Information Technologies (DTIT), the Department of Social Affairs, the Community Development Unit and the Monitoring & Evaluations (M&E) Unit, with others to be added as necessary. A comprehensive and cohesive regional approach will facilitate continuous engagement and participation, allowing ECOWAS member states to move towards mutual recognition of fIDs and the usage of ENBIC across borders. 19. The grant to ECOWAS Commission will finance several types of activities, ranging from regular policy dialogue to knowledge generation and sharing. These include: (i) Promoting regional engagement, and mutual understanding and cooperation among ECOWAS member states on the Program by means of common standards, change-management techniques, advocacy and sensitization; (ii) Developing a roadmap for the path from a fID system for participating countries to an ENBIC; (iii) Reviewing existing reports and assessments for ECOWAS member states to develop a baseline and progress indicators to monitor implementation of mutually-recognizable fID systems; and (iv) Strengthening the implementation capacity of the DFMT. 20. All ECOWAS member states are candidates for support under this sub-component. Across the region, there is a wide range of investment and capacity in connection with fID systems’ rollout, coverage and application. 2. PROJECT COMPONENT 2 – Establishing Robust and Inclusive fID Systems (CI: US$59.5m (EUR 48.3m); GN: US$40.75m (SDR 28.0m)) COMPONENT 2 OVERVIEW: 21. Under phase 1 of the MPA, Component 2 will support the creation of fID system, infrastructure and related sub-systems, including (i) interoperability between fID and CR systems, (ii) a fID system for mass registration, identity proofing, deduplication, UNI-generation, authentication, identity-management services, 71 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) reporting and threat analytics, (iii) a basic credential issuance system, (iv) implementation of the Social Management Plan and (v) a grievance redress mechanism (GRM) (see Figure 7). A mass registration campaign will collect basic demographic and biometric data from individuals to perform identity proofing and to generate UNIs in accordance with regional specifications and international standards. The UNI will be a random, unintelligible number, not containing any identity attributes, and unique across participating countries. Each country will have threat analytics and data analytics components to meet security and reporting requirements. A system to issue basic, low-cost credentials will be developed. To ensure sustainability of the fID system, the Project will develop interoperability between fID and CR systems facilitating an ongoing flow of data on births and deaths. While the design and implementation of a full-fledged CR system is out of the current scope, there is the possibility of attracting complementary financing from other donor partners to this end as well as seeking additional Bank financing. Finally, a GRM will be developed to permit individuals to request remedies for issues related to the Project. Figure 7: Process Architecture of Component 2 119 22. The quality of fID systems depends on a number of design and technical factors and has profound implications for system cost, utility and security. This includes the organizational design of identity management, the choice of technology used for establishing uniqueness, the authentication infrastructure (i.e., how IDs are used 119 The schematic is indicative only, and used for illustrative purposes. 72 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) to verify at the point of a transaction), the form and type of token or credential (i.e., different types of cards or the use of only numbers and biometrics) and securing databases against disaster and cyberattack. All software should comply with open standards to reduce costs, avoid vendor lock-in and provide flexibility for future adaptation. 23. To ensure the development of a robust and inclusive fID system, Component 2 will finance the design, development, and implementation of the following sub-components: i. Creating a fID system, including supporting infrastructure and information systems (see Figure 8). The fID system will be built for the core function of providing government-recognized IDs (i.e., fIDs). It will comprise a database initially be populated by a mass registration campaign: all persons in the territory of the country will be eligible for registration, irrespective of their nationality or legal status. The field registration campaign will be conducted by a team with proven capacity and will use various channels, including mobile devices, to ensure coverage of poor, rural and marginalized populations. During enrollment, basic demographic data will be collected, including a picture, last name, first name, date of birth, in addition to biometric data (e.g., iris, fingerprints). Based on collected data, validation, verification and de-duplication will be performed for identity proofing, and in order to generate a UNI. The UNI will be linked to biometric and demographic data. Biometric data will be stored in a separate, secure encrypted database to limit the possibility of any breach. UNIs will be unique and random—that is, the number should be unintelligible, not containing any logic that might reveal personal or identifying characteristics, including nationality and ethnicity. The system will include an application programming interface (API) layer to connect to other systems, including authentication of IDs by social protection, health, financial service providers and demographic data updates. A data analytics and reporting module will be designed to analyze all transactions and requests made of the system. Supporting information systems investments for the fID system will include a secure data center and a disaster recovery site to host various systems (e.g., project monitoring system, enrollment, data processing, UNI-generation system, interoperability mechanism between fID and CR systems, GRM). 73 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) Figure 8: Technical Architecture of fID Systems 120 ii. Strengthening links to CR systems. This will entail laying the groundwork for the automation of CR systems and the design of an interoperability mechanism to ensure the flow of data on births and deaths to the fID system for sustainable operations. Policies and protocols will be elaborated to allow interoperability between fID and CR systems. Data from the fID system could be leveraged by the Project and/or other sources of financing (e.g., EU, AFD, AfDB) to guide special operations to deliver late birth certificates. If the country elects to finance the issuance of late or delayed birth certificates for individuals not already in the CR, it will do so separately from the mass registration campaign that populates the fID system. iii. Developing a basic credential issuance system. This Component will finance the design and development of a system for production of basic credentials for all those who are enrolled in the fID system. It will also finance a study to recommend a sustainable model for financing ongoing operational expenditures to produce credentials for new enrollments after the Project concludes. At the time of enrollment in the fID system, deduplication will, where internet connectivity makes it possible, be performed at the time of issuance and UNIs issued on the spot. In the case of lack of internet connectivity, non-deduplicated UNIs will be issued, with deduplication occurring at a later time. iv. Communications, stakeholder engagement, GRM and project management. An awareness-raising campaign outlining rights and responsibilities will be developed and made publicly available by means of field registration operations. Registration operations will be designed to mitigate behavioral barriers to participation, based on the recommendations of the SAMP and associated studies. 121 The design of the fID systems will also include the development of GRMs to solicit complaints and to 120 The schematic is indicative only, and used for illustrative purposes. 121 WB RSR12 - P164513 (2017). 74 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) respond to issues with the enrollment of individuals in the fID system, the interoperability mechanism between fID and CR system and the credential issuance system. 24. During phase 1 of the MPA, Component 2 will be implemented in Côte d’Ivoire and Guinea through the following sub-components and activities: 2.1 SUB-COMPONENT: fID System (CI: US$38.5m; GN: US$23m) 2.1.1 Creation of the fID system (CI: US$18m; GN: US$7.5m) 25. This sub-component will finance the establishment of the fID system. The fID system will be developed according to the technical architecture diagram (see Figure 8, above). The fID system will allow for the authentication of unique identity and will be interoperable with other relevant registries and databases (e.g., CR system). 26. A central system will generate and manage UNIs. UNI generation (including main and backup systems) will ensure uniqueness and randomness of assigned numbers, across participating countries. For newborns, UNIs will be generated without biometric data, meaning that uniqueness may not necessarily be guaranteed. Biometrics will be captured at a later date, at which time the deduplication process will be completed. 27. Biometrics will be captured for the purposes of unique identification and of ongoing de-duplication of the fID system. Examples of biometric technology that the fID system may employ are those based on fingerprints and iris recognition. The system will also include mobile access points for registration and authentication. Standardized interfaces will permit functional registers and relevant service providers (e.g., Social Protection, Finance, Health) to authenticate users’ identities against the fID system using biometrics. For each country, procedures will be elaborated to deal with exceptional cases where biometrics cannot be captured. 28. Policies will be developed to allow access to authentication and other services (via webservices/APIs) while maintaining appropriate access control and data privacy safeguards. The sub-component will support the definition of Open APIs and standards to facilitate access to the fID system by relevant service providers in the public and private sectors (e.g., Social Protection, Finance, Health). Policies will be developed detailing the types of service providers allowed to link to the fID system, the various use-cases, technical protocols for data transfer, and appropriate data privacy safeguards, as well as penalties and sanctions for misuse of data. 2.1.2 Mass registration campaign (CI: US$20m; GN: US$15m) 29. The fID system will initially be populated via a mass registration campaign carried out at the national level in each country; all persons in the territory of the country will be eligible to register, irrespective of their nationality or legal status. 122 This policy will ensure the fID system has the core function of issuing fIDs, is maximally inclusive, and that all persons in the territories of the participating countries are assigned a UNI. It will also ensure that the UNI can be effectively used as a unique identifier by service providers domestically and across borders. 30. Because mass registration represents a one-time mobilization of significant human resources, it is expected that it will probably be subcontracted to a third-party, with proper accreditation and experience. 122 The fID system will also be designed to accommodate nationals residing abroad, although these populations will not be covered by the mass registration campaign, and will instead be covered under ongoing enrollment. 75 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) There are many potential providers with experience working with biometrics at a national scale who could perform the enrollment. The chosen provider will be expected to perform quality checks of the incoming biometric data in real time to allow any poor-quality data to be recaptured while enrollment teams are still in the field, thus avoiding costly repeat operations. The provider is expected to abide to the recommendations of the Social Management Plan to reach and protect vulnerable populations. The chosen provider will train staff from the implementing agency on the enrolment process to sustain ongoing registrations after the mass registration have been completed, and to strengthen local capacity. 31. The registration campaign will be conducted in such a fashion as to mitigate physical and behavioral barriers to participation. Many beneficiaries, especially the most vulnerable, will have limited mobility and thus limited ability to travel to an enrollment location. The Project will mitigate access barriers by conducting enrollment as near to beneficiaries’ homes as technically feasible. In particular, the Project will explore the possibility of using an offline solution for registration that assigns a UNI using mobile devices in order to penetrate to localities without electricity and/or telecom network coverage. Subsequently, the UNI will be validated, verified and deduplicated. Relatedly, deduplication processes for resolving multiple records, and for retiring duplicative UNIs, will also be developed. Where possible, online solutions for enrollment will be used to ensure deduplicated UNIs are provided on the spot. Additionally, enrollments may be also carried out at social safety nets pay points to ensure that beneficiaries are not denied the service for lack of an UNI. Furthermore, policies governing the fID system will elaborate exceptions for enrolling persons for whom biometric capture is not possible (e.g., due to missing fingerprints, cataracts, personal objection). 32. A number of behavioral barriers could affect the coverage of the enrollment campaign that will need to be mitigated. These include, such as, the perceived negative personal consequences of enrollment, association of the enrollment campaign with past enrollment drives (e.g., enrollments for electoral registers), the perception that there is no personal benefit to enrollment, and the direct and opportunity costs of enrollment. The Project will mitigate such behavioral barriers whenever possible by investing in measures such as communication campaigns and incentives to entice individuals and their families to enroll while informing them about their rights and the protection of their privacy. The Project will draw on work done under an RSR, as well as a study on ethnographic research and human-centered design for ID registrations in Côte d’Ivoire. The Project will also leverage the learnings of development partners such as UNICEF, UNHCR and the GFF who are piloting mitigation measures for behavioral barriers to birth and death registration in partnership with local governments. 2.1.3 Facilitating ongoing registration (CI: US$0.5m; GN: US$0.5m) 33. Procedures for ongoing registration in the fID system will be developed, with the third-party provider of the mass registration campaign being obliged to provide the hardware and training for managing a mobile, data-collection system based on tablets needed for ongoing registration. 123 While the mass registration campaign will ensure that the fID system contains a large, complete snapshot of the population from system inception, that snapshot will necessarily be temporally limited. Therefore, additional procedures will be needed for ongoing registration of, for example, newborns, migrants, nationals residing abroad and any others not having taken part in the mass registration. Such systems may include links to the birth and death notification systems in 123Recent developments in biometric technology make tablet-based enrollment solutions increasingly attractive compared to traditional enrollment “kits”, which combined various separate pieces of equipment (laptop computer, camera, fingerprint reader, etc.) into a semi- portable suitcase format. Not only are tablets more portable than traditional kits, they are also generally less fragile, less vulnerable to misuse, and can be significantly less expensive to acquire. Since they run entirely on battery power, tablets also allow enrollment teams to perform enrollment in beneficiaries’ localities of residence even without electricity. 76 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) communities and health centers. The “kits” used for ongoing registration must be portable, capable of assigning a UNI and able to collect biometrics for individuals over the required age. 2.2 SUB-COMPONENT: Creating links between fID and CR systems (CI: US$11.5m; GN: US$8.5m) 34. This sub-component will finance the provisioning of UNIs to individuals newly-registered in the CR system. The fID system will determine methods for decentralized registration (e.g., health centers, in communities) of new vital events and decentralized printing of documents. The fID system will allow UNIs to be provided to individuals newly-registered in the CR system, be it at birth or at a later date. The Project will work with donor partners (e.g., EU, AFD, AfDB), who may finance major aspects of a digital CR system. 35. Technical policies and protocols will be elaborated to allow interoperability between fID and CR systems, as well as other relevant registries and databases. These technical policies and protocols will allow for data transfer between fID and CR systems and support and reinforce the above legal framework (e.g., data privacy safeguards, sanctions, penalties for misuse). Interoperability between fID and CR systems will ensure that, going forward, the uniqueness of civil records can be assured using the UNI. 124 36. Assessment of existing paper-based and digital civil registries. This sub-component will also support a complete inventory and evaluation of the state of the existing CR system, including all civil registers and archives in the country, and rate each register on the feasibility of digitization. 125 Following the inventory and evaluation of the state of the existing CR, a budget and a strategy will be drawn up for the digitization of the stock of CR records, taking into account, in both Côte d’Ivoire and Guinea, the relatively poor condition of the current civil registers. As the Project will not finance the digitization of stock, the strategy for digitization will include alternate sources of financing for relevant aspects, including avenues for financing pilots, in selected regions. 2.3 SUB-COMPONENT: Production of fIDs (CI: US$4.5m; GN: US$4m) 2.3.1 Distribution of fIDs to all persons registered in the fID system (CI: US$2m; GN: US$1.5m) 37. After registration in the fID system and generation of the UNI, a basic, low-cost, physical credential (i.e., a “fID”) will be issued and distributed. fIDs will display the assigned UNI and will feature a machine-readable code (e.g., bar code, QR code) and additional, select data. This basic, low-cost credential will permit authorized agents using a compatible biometric terminal to facilitate authentication of individuals to allow access to services. 2.3.2 Systems for production of fIDs (CI: US$2.4m; GN: US$2.4m) 38. The Project will consider options for issuing a basic, low-cost credential (i.e., a fID). The Project will consider the options for sustained production of basic low-cost credentials, or fIDs, which meet each country’s specific needs while ensuring progress towards the implementation of the ECOWAS Free Movement Protocol. The production system will include not only the printers and specifications for fIDs, but will also include all 124 World Bank. 2018. “Integrating Unique Identification Numbers in Civil Registration”. Report. Washington, DC: World Bank Group. http://pubdocs.worldbank.org/en/795091518546134883/27385-Integrating-Unique-Identification-NEW-FINAL-0221.pdf (discussing, among other things, different online and offline models of integrating fID and CR systems, depending on the local, country conditions, especially with regard to internet connectivity, user experience and administration challenges). 125 Many existing paper registries will be digitized and incorporated into the new digital CR database, while others paper registries will have been lost or deteriorated to the point where digitization is unfeasible. 77 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) software applications linked to processing requests (e.g., request, production, quality control, delivery, payment) and will feature an interface based on mobile devices. 2.3.3 Development of a business plan to ensure sustainability (CI: US$0.1m; GN: US$0.1m) 39. A plan for the sustainable financing of the production of fIDs will be developed. The systems for card production will ensure that basic, low-cost credentials, or fIDs, can be produced using open standards and technologies to ensure sustainability and technology neutrality, and to avoid vendor lock-in. This sub-component will help design the most appropriate financing model for ongoing credential production in order to efficiently balance concerns of financial sustainability and universal access to fIDs. 2.4 SUB-COMPONENT: Supporting information systems (CI: US$2m; GN: US$2.15m) 2.4.1 Project management and monitoring system (CI: US$0.15m; GN: US$0.15m) 42. The Project will finance reinforcement of implementing agencies’ information systems to assist in project management and monitoring. This sub-component will finance upgrades to the implementing agencies’ information systems to improve overall project management by tracking and reporting information, triggering early warnings on issues and bottlenecks and providing an evidence-base to inform future policy. The project management and monitoring system upgrades will support at minimum the following core functions: (i) operations, including ongoing enrollment in the fID system and management of databases; (ii) monitoring and management, including creation of indicators and management alerts; (iii) control and accountability including the generation of reports and materials for communication with the stakeholders and the public; and (iv) management and resolution of grievances received through the Program’s GRM system, including communication with beneficiaries. 2.4.2 Secure data center and backup (CI: US$1.85m; GN: US$2m) 43. This sub-component will finance both a secure data center and backup center to host the fID system. Specific systems that countries could choose to host in this data center include: project management and monitoring system, the fID system, credential issuance system and functional registries for services under Component 3. 126 Both main and backup data centers will be procured and operated in line with international good practices for data security and applicable data protection laws in each country. Combining and centralizing data storage for all systems which make up the fID system will allow the Project to take advantage of economies of scale and ensure security of stored data. Centralization comes with some risks; thus, the sites will focus on mitigating potential disaster risks and ensuring continuous power supply to enable continuous system functioning, with strict policies managing access to both the physical sites and to the data. 2.5 SUB-COMPONENT: Project management, GRM and stakeholder engagement (CI: US$3.3m; GN: US$3.4m) 2.5.1 Support for PIU (CI: US$1.4m; GN: US$1.3m) 44. This sub-component will finance activities related to project management. Such activities in Côte d’Ivoire and Guinea will include the operational costs of the PIUs, the recruitment of a dedicated project- 126Should such be desired, the Government may use other financing to expand the capacity of this data center to serve other national data-hosting needs, insofar as it does not undermine the functioning of the fID system or its use by functional systems and services. 78 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) management resource to coordinate implementation activities between different implementing ministries and the development of a project implementation plan. 2.5.2 Project monitoring and evaluation (CI: US$1.3m; GN: US$0.5m) 45. This sub-component will finance the development and implementation of a monitoring and evaluation (M&E) system, as well as ongoing M&E activities. 2.5.3 Awareness-raising campaign and stakeholder engagement (CI: US$0.45m; GN: US$1.45m) 46. Awareness-raising campaigns outlining rights and responsibilities of registered persons will be developed and implemented as part of the project communications strategy. The fID system will aim to deliver fIDs to populations that may never have been registered. In order to maximize participation, and thus to increase system coverage, it is essential that the benefits of the fID system, as well as its inclusiveness, be effectively communicated to the population well in advance of registration drives. It is also essential that the populations understand their rights and responsibilities under the new fID system. The communications campaign will effectively outline service standards, explain the process of delivering IDs from intake and registration to receipt of credentials, and will address concerns about privacy, costs, inclusiveness and benefits to end users. The campaign will also introduce and regularly remind people of the existence of the GRM systems. (See Annex 4 for further information on stakeholder engagement under the Project.) 2.5.4 Development of GRM (CI: US$0.15m; GN: US$0.15m) 47. Design of the fID systems will also include the development of GRMs to collect and to respond to beneficiary issues with the implementation and rollout of fIDs. The GRMs will be designed in line with international good practices, and will provide an avenue for all persons affected by the new fID systems to file a grievance and be assured of its resolution. The GRMs will be linked to project management and monitoring. Regular monitoring of GRM indicators will inform the implementation of the fID system. This activity will include technical assistance to enhance the Government’s capacity to address beneficiaries’ complaints. 3. PROJECT COMPONENT 3 – Facilitating Access to Services through fIDs (CI: US$5.3m (EUR 4.3m); GN: US$6.35m (SDR 4.4m)) COMPONENT 3 OVERVIEW: 48. This Component will describe the operational and implementation arrangements, and integration and interoperability mechanisms between the fID system and social safety nets systems, as a means of facilitating access to services for the population. These include financing of the development of a broader national strategy for linking fID systems to key services, and specifically a technical analysis and implementation plan. These may include interoperability mechanisms and technologies; information, education and communication (IEC) campaigns to individuals to encourage the use of fIDs for access to social safety net programs; piloting and testing among a cohort of social program beneficiaries; gradual rollout; and scale-up, as feasible, and based on pilot results. 49. To incentivize take-up of the fIDs as a means of facilitating access to services, Component 3 will link the fID systems to ongoing national social protection programs. Specifically, Component 3 will be implemented 79 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) through the national productive social safety net programs in Côte d’Ivoire 127 and Guinea 128, both of which are co-financed by IDA and government resources. Both programs have social registry information systems with plans to adopt the UNI in the future once available, as they currently rely upon less robust, functional IDs for deduplication of registered individuals in the system and for authentication of beneficiaries at pay points. The Project will implement an interoperability mechanism to provide UNIs, while also assuring the appropriate application of privacy, data protection and user-consent policies. An Executive Order or MoU will govern the data exchange protocols between systems. Linking to the safety nets program is to serve as a good-practice example and to encourage other services to develop their own linkages with the web services or APIs of the fID system. Provided availability of financing, other potential services that could be linked to the fID system under this Component, include health sector services (e.g., patient tracking), mobile communications (e.g., SIM card identification) and financial services (e.g., KYC). 50. Component 3 will help each participating country to define its strategy by choosing among multiple options for leveraging fIDs for authentication of identity for delivery of services. Some of the factors that influence the choice of authentication systems design include the type of credential; for instance, if it is a smart card, then offline authentication is feasible. If the issued credential is a basic one without chip, an online comparison of biometrics against the template of stored biometrics in the fID system can be done by invoking the authentication service of the fID system. If the country has implemented a derived credential, such as mobile ID, then a mobile-based authentication mechanism using the authentication services of the fID system could be used. 129 The level of assurance required for a transaction also determines the type of authentication mechanism to be used. For a high value transaction, biometric authentication or multi factor authentication would be used. By contrast, for simple transactions requiring lower assurance levels, a demographic authentication or mobile ID- based authentication may suffice. Service providers could also switch from the default of online authentication to offline authentication in the instance that internet connectivity is poor or non-existent. Other factors influencing choice are internet coverage, cost of the equipment required for smart card-based systems (i.e., smart card readers, biometric readers and the smart cards themselves), design choice of neighboring countries (where most of the cross-border transactions would take place), network coverage and availability of services linked to the fID system, both domestically and abroad. 51. Online authentication for domestic and cross-border access to services in the ECOWAS region. This model would require the social safety net service provider systems to integrate with biometric readers and with the authentication service API of the fID system. For accessing the API of any cross-border fID system, an additional component could be developed centrally for the ECOWAS region and each country can deploy one or more instances of this authentication service component for their service providers (see Figure 9). Service providers could connect to an open API developed by this Component. The API could dispatch the request to the authentication API of the fID system of the country to which the fID of the individual belongs and return the response via the authentication service aspect to the service provider. This model is cost-effective if there is good internet coverage at the service delivery point. It could also be used for mobile ID-based authentication. Where possible, common standards and guidelines, as convened by the ECOWAS Commission, will be followed to allow 127 World Bank. 2015. Côte d’Ivoire - Productive Social Safety Net Project - P143332. Rep. No. PAD1189. Washington, DC: World Bank Group. http://projects.worldbank.org/P143332?lang=en. 128 WB. Guinea - Productive Social Safety Nets Project - P123900 (2012). 129 Identification for Development. 2018. “Technology Landscape for Digital Identification”. Report. Washington, DC: World Bank Group. http://pubdocs.worldbank.org/en/199411519691370495/ID4DTechnologyLandscape.pdf. 80 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) for regional integration of systems. As already noted, the EU’s experience with eIDAS offers important guidance to how regional variations might enrich system functionality and versality, while also increasing cooperation and encouraging innovation (see Box 2, page 36). A trust framework is an important aspect of interoperability between countries and systems that are not harmonized. Figure 9: Service Access with fID System (In-Country and Cross-Border): Online Authentication Model 130 1. User provides UNI, biometric and country name 2. Service provider calls API of authentication service (or fID system API invoked directly without authentication) 3. Dispatcher formats and sends the request to fID system of respective country 4. fID system matches biometric (1:1) and returns response (yes/no). NO DATA IS SHARED. 5.Authentication service forwards response to service provider 52. Offline authentication for domestic and cross-border service access in the ECOWAS region based on ENBIC card. Linkage of social safety net systems with smart card readers and biometric devices could facilitate offline authentication of those using ENBIC, both for in-country and cross-border service delivery. Wide coverage of a smart card based on ENBIC specifications could facilitate adoption of this mechanism of authentication. (See Figure 10.) Figure 10: Service Access Interaction with fID System: Offline Authentication Model (both Online and Offline Authentication Shown)128 53. The Project will facilitate access to services by fIDs by financing the following sub-components and activities: 130 The schematic is indicative only, and used for illustrative purposes. 81 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) i. Strategy, design and implementation of linkage between the fID system and the social information system for safety nets. First, national strategies for the linkage of services to the fID system will be developed. These strategies will also identify how social safety net services will be linked to the fID system in light of domestic needs and priorities as well as capacity and readiness for integration. The social information system will receive support to build software components to integrate with the components like the biometric reader, smart card reader, authentication service API depending on the model(s) adopted for authentication, link existing resident data record in the service provider system with the UNI, acquire biometric terminals and/or smart card readers and train staff. The precise nature of allocated support given will depend on the presented needs, with every effort being made to assure that other financing sources, including other donors and the private sector, are not crowded-out. ii. Communications campaigns. A mass communications campaign will ensure that individuals are aware of the ways they can benefit from the new linkages to the social safety nets program to maximize demand. 54. During phase 1 of the MPA, Component 3 will be implemented in Côte d’Ivoire and Guinea through the following sub-components and activities: 3.1 SUB-COMPONENT: Elaboration of a national strategy for linking the fID system to key services (CI: US$0.5m; GN: US$0.5m) 55. This sub-component will finance the elaboration of national strategies for Côte d’Ivoire and Guinea to prioritize key services that can be linked to the fID system. These strategies will be based on consultations with key stakeholders in each country and will include a list of services to be linked to each country’s fID system in the short-, medium- and long-term, in order of priority. The strategies will be based on the needs and priorities of key stakeholders; the capacity and readiness of the various potential services for integration with the fID system; the potential impact on end-users of each linkage; the need to demonstrate the utility of linkage to the fID system in a diverse array of applications in the public and private sectors; budgetary considerations; and the availability of financing, including non-project financing. 3.2 SUB-COMPONENT: Design and implementation of interoperability between the fID system and social safety net systems (CI: US$1.0m; GN: US$1.6m) 56. This sub-component will finance technical assistance to social safety net services to ensure the effective linkage of social information systems to the fID system. The Project will finance technical assistance for the design and implementation of linkages with the fID system to assure quality and sustainability (e.g., review and revision of business processes and service models in light of the fID system in order to improve service delivery; capacity building of key staff to ensure optimal use of the new systems). One or more services will be linked to the fID system based on the recommendation of the strategy developed under sub-component 3.1. 3.3 SUB-COMPONENT: Targeted investments in equipment (CI: US$3.0m; GN: US$4.0m) 57. This sub-component will invest in biometric “kits” in order to ensure a successful rollout among services. Depending on financing needs, the Project will provide targeted support for acquiring biometric equipment necessary for authentication processes. 82 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) 3.4 SUB-COMPONENT: Communications campaigns (CI: US$0.80m; GN: US$0.25m) 3.4.1 Development of a communications strategy (CI: US$0.05m; GN: US$0.05m) 58. A strategy for communicating with beneficiaries on accessing services using fIDs will be developed, with particular emphasis placed on groups previously excluded from these services due to lack of government- recognized IDs. Creating a digital linkage between databases of service providers and the fID system for the purpose of authenticating identity is unprecedented in both Côte d’Ivoire and Guinea. While this new functionality has significant potential to improve service delivery—especially to vulnerable populations and groups that have historically been excluded—, doing so also represents a significant departure from the status quo. Those service-delivery entities involved in this sub-component will play a key role in the communication campaign, especially vis-à-vis groups previously incapable of accessing services. 3.4.2 Communications campaigns on service delivery using fIDs (CI: US$0.75m; GN: US$0.2m) 59. This sub-component will finance a communications campaign to raise awareness about the new functionality of the fID system for accessing services. The design of the communications campaign will draw on the country communications strategies, and will be adapted to permit communication with the various groups targeted in the strategy, including vulnerable groups such as illiterate persons and linguistic minorities, who will access these priority services (e.g., social safety net, health). 83 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) ANNEX 2: PROJECT COSTS COUNTRY: Western Africa West Africa Unique Identification for Regional Integration and Inclusion (WURI) COSTS AND FINANCING OF PHASE 1 OF THE PROGRAM A. Program Costs Project IBRD or IDA Trust Counterpar Program Components Cost Financing Funds t Funding PROGRAM COMPONENT 1 – STRENGTHENING THE LEGAL 9.6 9.6 0 0 AND INSTITUTIONAL FRAMEWORK PROGRAM COMPONENT 2 – ESTABLISHING ROBUST AND 100.85 100.85 0 0 INCLUSIVE FOUNDATIONAL ID SYSTEMS PROGRAM COMPONENT 3 – FACILITATING ACCESS TO 11.65 11.65 0 0 SERVICES THROUGH fIDs Total Costs Total Phase 1 Costs 122.1 122.1 0 0 Front End Fees 0 0 0 0 Total Financing Required 122.1 122.1 0 0 B. Côte d’Ivoire Project IBRD or IDA Trust Counterpart Project Components Cost Financing Funds Funding COMPONENT 1 – STRENGTHENING THE LEGAL AND INSTITUTIONAL 2.3 2.3 0 0 FRAMEWORK 1.1 Identify and address gaps in existing legal, regulatory and 2.3 2.3 0 0 institutional frameworks for fIDs 1.2: Conduct regional dialogue on mutual recognition of country fID 0 0 0 0 systems COMPONENT 2 – ESTABLISHING ROBUST AND INCLUSIVE 59.8 59.8 0 0 FOUNDATIONAL ID SYSTEMS .1 Creating a fID system 38.5 38.5 0 0 2.2 Creating links between fID and CR systems 11.5 11.5 0 0 2.3 Developing systems for production of fIDs 4.5 4.5 0 0 2.4 Creating supporting information systems 2 2 0 0 2.5 Project Management, GRM and stakeholder engagement 3.3 3.3 0 0 84 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) COMPONENT 3 – FACILITATING ACCESS TO SERVICES THROUGH fIDS 5.3 5.3 0 0 3.1 Elaboration of national strategy linking fID system to services .05 .05 0 0 3.2 Design and implementation of interoperability between the fID 1 1 0 0 system and key services 3.3 Targeted investment in equipment 3.0 3.0 0 0 3.4 Communications campaigns 0.8 0.8 0 0 Total Costs 67.4 67.4 0 0 C. Guinea Project IBRD or IDA Trust Counterpart Project Components Cost Financing Funds Funding COMPONENT 1 – STRENGTHENING THE LEGAL AND INSTITUTIONAL 2.3 2.3 0 0 FRAMEWORKS 1.1 Identify and address gaps in existing legal, regulatory and 2.3 2.3 0 0 institutional frameworks for fIDs 1.2: Conduct regional dialogue on mutual recognition of country fID 0 0 0 0 systems COMPONENT 2 – ESTABLISHING ROBUST AND INCLUSIVE 41.05 41.05 0 0 FOUNDATIONAL ID SYSTEMS 2.1 Creating a fID system 23 23 0 0 2.2 Creating links between fID and CR systems 8.5 8.5 0 0 2.3 Developing systems for production of fIDs 4 4 0 0 2.4 Creating supporting information systems 2.15 2.15 0 0 2.5 Project management, GRM, and stakeholder engagement 3.4 3.4 0 0 COMPONENT 3 – FACILITATING ACCESS TO SERVICES THROUGH fIDs 6.35 6.35 0 0 3.1 Elaboration of national strategy linking fID system to services 0.5 0.5 0 0 3.2 Design and implementation of interoperability between the fID 1.6 1.6 0 0 system and key services 3.3 Targeted investment in equipment 4.0 4.0 0 0 3.4 Communications campaigns 0.25 0.25 0 0 Total Costs 49.7 49.7 0 0 85 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) D. ECOWAS Commission Project IBRD or IDA Trust Counterpart Project Components Cost Financing Funds Funding COMPONENT 1 – STRENGTHENING THE LEGAL AND INSTITUTIONAL 5 0 0 0 FRAMEWORK 1.1 Identify and address gaps in existing legal, regulatory, and 0 0 0 0 institutional frameworks for fIDs 1.2: Conduct regional dialogue on mutual recognition of country fID 5.0 5.0 0 0 systems (including support for the PIU) COMPONENT 2 – ESTABLISHING ROBUST AND INCLUSIVE 0 0 0 0 FOUNDATIONAL ID SYSTEMS 2.1 Creating the fID system 0 0 0 0 2.2 Creating links between fID and CR systems 0 0 0 0 2.3 Developing systems for production of fIDs 0 0 0 0 2.4 Creating supporting information systems 0 0 0 0 2.5 Project management, GRM, and stakeholder engagement 0 0 0 0 COMPONENT 3 – FACILITATING ACCESS TO SERVICES THROUGH fIDS 0 0 0 0 3.1 Elaboration of national strategy linking fID system to services 0 0 0 0 3.2 Design and implementation of interoperability between the fID 0 0 0 0 system and key services 3.3 Targeted investment in equipment 0 0 0 0 3.4 Communications campaigns 0 0 0 0 Total Costs 5 5 0 0 86 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) ANNEX 3: IMPLEMENTATION SUPPORT PLAN COUNTRY: Western Africa West Africa Unique Identification for Regional Integration and Inclusion (WURI) A. Strategy and Approach for Implementation Support 1. At the regional level, ECOWAS will be supported directly. While the investments in ID systems financed by the Project will be made at the national level, the role of ECOWAS must be emphasized. ECOWAS’s role as a regional governing body is critical for ensuring that regional standards allowing mutual recognition between the country ID systems financed by the Project are established and upheld. The Commission’s capacity to coordinate and harmonize national ID initiatives is key to the success of the regional project. To this end, financial support in the form of an IDA grant of US$5million will be made available to Commission to facilitate regional dialogue and capacity building. The Commission has identified its DFMT to lead an internal task force to implement this grant. 2. At a country level, national PIUs will work with the core team at ECOWAS to ensure that national programs are aligned with the regional roadmap. Specific implementation arrangements will be designed separately for each country. In countries that already have a national identification agency with a strong mandate for ID reform, the Project could consider creating PIUs housed within these agencies in order to build institutional capacity and to ensure alignment with national ID agendas. In countries without a suitable agency, the Project could create a new freestanding PIU or leverage an existing PIU where possible to minimize implementation costs. Technical specialists may also be hired into the PIUs in order to streamline project implementation. Additionally, in some countries it may be desirable to recruit assistant project managers to assist the project coordinator, especially when the country’s institutional environment requires coordination between different agencies or ministries in order to execute project activities. In addition to PIUs, steering and oversight committees with representatives from relevant stakeholder ministries, regulatory authorities, potential institutional beneficiaries of digital ID systems in the public and private sectors, and civil society will be considered to provide strategic guidance to PIUs. 3. During phase 1 of the MPA, project implementation in Côte d’Ivoire will be carried out by ONI. ONI is an institution with high technical and institutional capacity. In Côte d’Ivoire, reform of ID and CR systems is already underway, having been identified as a high priority reform by the government, with ONI serving as the lead agency in this effort. Additionally, the new Côte d’Ivoire strategy for ID reform gives ONI a clear mandate to continue overseeing ID and CR reform in the long term. Further, ONI has the technical and institutional capacity to implement the Project. This capacity will help ensure coordination between the Project and Côte d’Ivoire’s ongoing ID reform efforts, maximizing project sustainability by building ONI’s institutional capacity. Project implementation will be overseen by the same steering committees already in place to supervise the broader reform effort. 4. In Côte d’Ivoire, the Project will also invest in a dedicated project management resource to assist ONI with implementation. Because of the cross-cutting nature of the ID reform agenda, the diverse number of firms that need to be contracted, and the broad array of stakeholders implicated, efficient project management is particularly important to the success of this operation. The assistant project manager will support ONI in sequencing and prioritizing various activities, drafting and updating the project implementation plan with input from relevant stakeholders, developing a risk-management strategy, ensuring that monitoring is carried out according to the Project’s M&E Plan, communicating with stakeholders, and ensuring that the steering committee 87 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) is informed of any delays, etc. Additionally, ONI will need to hire a social specialist to help manage and monitor the social risks highlighted above. 5. During phase 1 of the MPA, project implementation in Guinea will be carried out by a PIU housed within the PMO. Since Guinea lacks an institution with a clear mandate or with the inter-sectoral reach to execute the broader ID reform, the Government of Guinea has elected to anchor the Project in the PMO until a more permanent institutional arrangement to oversee modernized fID and CR systems can be established. The PMO is an appropriate choice because of its high institutional and technical capacity and because its non-sectoral position in the government makes it well-placed to lead such a cross-cutting reform. The PIU within the PMO will be established through the open recruitment of a project coordinator, procurement specialist, finance specialist, accountant, social development specialist, as well as any other technical or project-management resources for which need is identified, such as a legal expert. Implementation by this PIU will be overseen by a steering committee composed of focal points of the ministries of Territorial Administration and Decentralization; Security and Civil Protection; Posts, Telecommunications and Digital Economy; Health; as well as the PMO. B. Financial Management 6. A preliminary Financial Management Assessment was conducted on the FM arrangements for the Project that will be implemented at the regional level by the ECOWAS Commission and at the national level by ONI in Côte d’Ivoire and by the PMO in Guinea. 7. The objective of the assessment was to determine: (i) whether these implementing entities have adequate FM arrangements (planning, budgeting, accounting, internal control, funds flow, financial reporting, and auditing arrangements) to ensure that project funds will be used for purposes intended in an efficient and economical way; (ii) project financial reports will be prepared in an accurate, reliable and timely manner; and (iii) the Project’s assets will be safeguarded. The FM assessment was carried out in accordance with the Financial Management Manual for World Bank Investment Project Financing Operations that became effective on 1st March 2010 and as last revised on 10th February 2017. In this regard, a review of the FM arrangements has been conducted for the above entities as further detailed below. 8. Planning and Budgeting: i. Côte d’Ivoire: ONI will prepare a detailed consolidated annual work plan and budget (AWPB) for implementing the activities of the Project. The AWPB will be submitted to the ONI Steering Committee/ governance structure for approval and thereafter to IDA for no-objection, not later than November 30 of the year preceding the year the work plan should be implemented. ii. Guinea: The PIU will be responsible for preparing the Project’s consolidated annual work planning and budget (AWP&B) based upon the agreed program to be financed. The work plan and budgets will identify the activities to be undertaken and the role of respective parties including the PIU and other implementing entities. The AWPB will provide detailed information on the amount allocated per activity showing unit costs and quantities. The Project will submit the AWP&B to the World Bank for the no objection no later than 30 November of the year preceding the year the work plan should be implemented. iii. ECOWAS Commission: The annual budget will be prepared based on the work plan approved by the Bank. An accountant in the External Fund Management Unit in the Finance Department of the Commission will be designated for the Project and will prepare the Project’s annual budget, which must be approved before the beginning of each financial year. The budget preparation process will 88 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) be done in line with ECOWAS Commission Financial Regulations & Manual of Accounting Procedures. The annual budget once approved is uploaded into SAP, the system tracks the budget execution preventing over commitment. Reporting on budget performance will be done using the quarterly unaudited interim financial reports (IFRs) wherein actual expenditures are compared with the budget estimates and explanations provided for significant variances. 9. Internal Control System and Internal Audit: Internal control system is designed to ensure (i) the effectiveness and efficiency of operations, (ii) the reliability of financial reporting, and (iii) the compliance with applicable laws and regulations. i. Côte d’Ivoire: ONI does not have a FM procedures manual. For the Project, the accounting, financial and administrative procedures manual including procurement, to be developed, will document, explain and describe work processes, information flow, authorization and delegation of authority, timing, segregation of duties, controls, compliance with project objectives, micro and macro rules and regulations. In line with Decree n° 475 governing the implementation arrangements for donor- financed projects in Côte d’Ivoire, 131 the Inspection générale des finances (IGF) will oversee the internal audit function of the Project managed by the ONI. A MoU will be signed between IGF and ONI to allow the government institution to conduct internal audit missions periodically. ii. Guinea: For the purpose of the Project, the accounting, financial and administrative procedures manual, to be developed, will document, explain and describe work processes, information flow, authorization and delegation of authority, timing, job segregations, auto and sequential controls, compliance with project objectives, micro and macro rules and regulations. Application of the procedures set up in the manual will be mandatory for all staff at all levels. There is no formal internal audit department or Unit within the PMO. The Project will provide financial support to recruit an internal auditor (individual consultant) to conduct the reviews of project expenditures including physical verifications of acquisition of works, goods and services on a daily basis. All deficiencies or circumvented practices identified will be communicated by the internal auditor in a timely manner to the minister, senior management of the for immediate corrective action as appropriate. One copy of such reports will also be communicated to the Bank. iii. ECOWAS Commission: The internal control systems to be used by the Project are documented in the ECOWAS Commission Financial Regulations & Manual of Accounting Procedures. These are adequate for the Project. There is adequate segregation of duties in the External Funds Management Unit. ECOWAS Commission has an internal audit unit headed by a Chief Internal Auditor. Projects are included in the annual audit plan based on their risk rating. The unit has an audit manual and uses a risk based auditing approach. An audit software is also in place. Audit reports are submitted to an audit committee that ensures that audit issues are addressed by management. 10. Accounting Arrangements: i. Côte d’Ivoire and Guinea: The prevailing accounting policies and procedures in line with the West African Francophone countries accounting standards—SYSCOHADA—in use in Côte d’Ivoire and Guinea for ongoing World Bank-financed operations will apply. The accounting systems and policies and financial procedures used by the Project will be documented in the Project’s administrative, accounting and financial manual to be developed by project effectiveness. For Côte d’Ivoire, ONI will 131 Décret n° 2015-475 (1 juillet 2015). 89 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) customize the accounting software to meet project requirements. To strengthen the staffing, ONI will recruit and appoint) one senior accountant by effectiveness and one assistant 3 months after effectiveness, both familiar with Bank FM procedures. For Guinea, the PMO will use acquire and install a project accounting software. This software should be capable of recording transactions and reporting project operations in a timely manner including preparation of withdrawal applications and periodic financial reports (Interim unaudited Financial Reports- IFR- and Annual Financial Statements). The software should include budgeting, operating and costs accounting systems to facilitate monitoring, evaluation and reporting. ii. ECOWAS Commission: The Project will use ECOWAS Commission Financial Regulations & Manual of Accounting Procedures. The accounting system is computerized using SAP Enterprise Resource Planning System. There is adequate support being provided for the proper utilization and functioning of the accounting software. The Grant Management module of the software is used by the External Fund Management Unit in accounting for and reporting on Donor Partners’ funds. The International Public Sector Accounting Standards (IPSAS), accrual basis of accounting will be used in preparing the Project’s financial statements. There is adequate staffing in the External Funds Management Unit. From amongst the team, an accountant will be designated for the Project. The designated project accountant will report to the Head of the External Funds Management Unit who reports to the Director Finance. 11. Interim Financial Reporting: i. Côte d’Ivoire and Guinea: The unaudited IFRs will be prepared every quarter and submitted to the World Bank regularly (for example, 45 days after the end of each quarter) and on time. The consolidated quarterly IFR for the Project includes the following financial statements: (i) Statement of Sources of Funds and Project Revenues and Uses of funds; (ii) Statement of Expenditures (SOE) classified by project components and/or disbursement category (with additional information on expenditure types and implementing agencies as appropriate), showing comparisons with budgets for the reporting quarter, the year, and cumulatively for the Project life; (iii) cash forecast; (iv) explanatory notes; and (v) DA activity statements. ii. ECOWAS Commission: ECOWAS Commission will submit calendar quarter unaudited Interim Financial Reports (IFRs) within 45 days of the end of the relevant quarter. The formats of these IFRs will be agreed with the Bank before the signing of the agreement. The IFR section on Financial Reporting will comprise: (i) Statement of Sources and Uses of Funds; and (ii) Detailed Statement of Uses of Funds by Project Activity/Component. The IFR section on Disbursements will comprise: (i) Statement of Sources and Uses of Funds by expenditure category, (ii) DA Activity Statement; (iii) Summary Statement of DA Expenditures for Contracts subject to Prior Review; (iv) Summary Statement of DA Expenditures for contracts not subject to Prior Review; and (v) Bank Statements for the Designated and Project Account and their reconciliation statements. 12. Annual Financial Reporting: i. Côte d’Ivoire and Guinea: In compliance with International Accounting Standards and IDA requirements, ONI will produce annual financial statements. These include (i) a Balance Sheet that shows assets and liabilities; (ii) a Statement of Sources and Uses of Funds showing all the sources of project funds and expenditures analyzed by project component and/or category; (iii) a DA Activity Statement; (iv) a Summary of Withdrawals using SOEs, listing individual Withdrawal Applications by 90 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) reference number, date, and amount; and (v) notes related to significant accounting policies and accounting standards adopted by management and underlying the preparation of financial statements. The financial statements will be audited annually by the external auditor. ii. ECOWAS Commission: ECOWAS Commission will prepare annual financial statements in accordance with IPSAS, these shall be audited by an external private audit firm and submitted to the Bank within 6 months after the end of the financial year. 13. External Auditing: For all implementing entities. The external audit of the Project’s funds will be done by a private audit firm acceptable to the Bank on the basis of Terms of Reference (ToRs) cleared by the Bank. The audit will be carried out in accordance with the International Standards on Auditing. The audit report together with the management letter will be submitted to the Bank within six months after the end of the financial year. The financial years for preparing audited accounts will follow financial year of the implementing entity. Audit reports will be publicly disclosed by the Bank in accordance with the World Bank disclosure policy. Table 8: Due Dates of the Audit Report Audit Report Due Date Responsible Party (a) Not later than June 30 (2000 + N) if effectiveness has Audited financial statements PIU / ONI occurred before June 30 (2000 + N-1). including audit report and ECOWAS Commission, (b) Not later than June 30 (2,000 + N+1) if effectiveness has Management Letter PMO occurred after June 30, (2000 + N-1) 14. Funds Flow Arrangements: i. Banking Arrangements. Each implementing entity will open a DA in a financial institution acceptable to IDA. (See Table 9 for bank accounts and currencies.) The ceiling of the DA is stated in the DFIL. Table 9: Bank Accounts and Currencies Designated Account Project Account Implementing Entity DA Ceiling Financial Institution Currency Côte d’Ivoire Central Bank (BCEAO) CFAF2,200,000,000 CFAF US$3,300,000, of which: Guinea Central Bank (BCRG) US$2,200,000 – Credit GNF US$1,100,000 – Grant ECOWAS Commission Commercial Bank US$350,000 NGN ii. Disbursements for all implementing entities. Upon credit effectiveness, disbursements will follow the Disbursement Guidelines for Investment Project Financing operations issued in February 2017. The Project will finance 100 percent of eligible expenditures, inclusive of taxes. The Project can make use of all four disbursement methods (advance, reimbursement, direct payment and special commitment). An initial advance up to the ceiling of the DA will be made into the DA from which payments for incurred eligible project expenditures will be made. Where payment is to be made for eligible project expenditures in local currency, funds will be transferred from the DA to the Project Account to make such payments. Balance in the Project Account will be as close to zero as possible after payments have been made. For Côte d’Ivoire and Guinea, subsequent disbursements will be made against submission of SOE reporting on the use of the initial/previous advance; for ECOWAS 91 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) Commission, subsequent disbursements will be made against submission of quarterly unaudited IFRs (also known as report-based disbursements) to report on the use of advances for eligible expenditures. The minimum value of applications for these methods is twenty percent of the DA ceiling. The authorized signatory for each entity will sign and submit Withdrawal Applications electronically using the eDisbursement module accessible from the Bank’s Client Connection website. iii. Payments to Implementation Agencies and services providers in Côte d’Ivoire. ONI is an Etablissement public national à caratère administratif (EPA) under the responsibility of the Ministry of Interior; therefore, in line with the country’s Public Expenditure Management (PFM) system, a Budget Controller and a Public Accountant have been appointed. In line with the Use of Country System, as stipulated in Decree n° 475 governing the modalities of donors-financed project implementation in Côte d’Ivoire, the two civil servants should be involved in the management of the Project’s funds. ONI will make payments to Implementing Agencies for the specified activities in the components of the Project. Payments will be made in accordance with the payment modalities, as specified in the respective contracts/conventions. In addition to these supporting documents, ONI will consider the findings of the internal audit unit (i.e., IGF) while approving the payments. ONI will reserve the right to verify the expenditures ex-post, and refunds might be requested for non-respect of contractual/convention (e.g., maîtrise d’ouvrage délégué (MOD)) clauses. Misappropriated activities could result in the suspension of financing for a given entity. iv. Local taxes: Funds will be disbursed in accordance with project categories of expenditures and components and their financing will be in line with the Financing Agreement and will be inclusive of taxes per the current country financing parameters approved for both Côte d’Ivoire and Guinea. 15. Financial Management Action Plan: The FM Action Plan described in Table 10, below, has been developed to mitigate the overall financial management risks. Table 10: FM Action Plan FM Responsible Completion Issue/Topic Remedial Action Recommended Effectiveness Body/Person Date Conditions ONI, PMO, Agree with the Bank the format of the Completed at Reporting ECOWAS NO unaudited Interim Financial Reports. negotiations Commission Recruitment of (i) one FM Officer and (ii) 2 months after PMO NO one accountant effectiveness Recruitment and appointment of one 2 months after Staffing senior accountant familiar with Bank FM ONI NO effectiveness procedures Recruitment and appointment one 3 months after assistant familiar with Bank FM ONI NO effectiveness procedures Information Acquisition and installation of an 2 months after system accounting accounting software for the Project and ONI, PMO NO effectiveness software training of the users 92 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) Table 10: FM Action Plan FM Responsible Completion Issue/Topic Remedial Action Recommended Effectiveness Body/Person Date Conditions Administrative Draft and disseminate the FM and 2 months after NO Accounting & ONI, PMO administrative manual effectiveness financial Manual Contract with IGF to manage the internal audit function of the Project and to 3 months after ONI/ MEF (IGF) NO conduct periodic reviews of project effectiveness Internal auditing transactions Recruit an internal auditor 3 months after PMO NO (individual consultant) effectiveness ONI, PMO, Agree with the Bank the external audit Completed at ECOWAS NO TOR negotiations Commission External auditing Appointment of the external auditor 4 months after ONI NO completed and contract signed effectiveness Appointment of the external auditor 5 months after PMO NO completed and contract signed effectiveness 16. Support to the implementation plan. FM supervisions will be conducted over the Project’s lifetime. The Project will be supervised on a risk-based approach. Based on the outcome of the FM risk assessment, the following implementation support plan is proposed. The objective of the implementation support plan is to ensure the Project maintains a satisfactory FM system throughout its life. Table 11: FM Implementation Support Plan FM Activity Frequency Desk Reviews IFRs’ review Quarterly Audit report review of the Program Annually Review of other relevant information such as interim internal control systems Continuous, as they become reports available On-site Visits Review of overall operation of the FM system (Implementation Support Mission) Every 6 months for Substantial risk Monitoring of actions taken on issues highlighted in audit reports, auditors’ As needed Management Letters, internal audits, and other reports Transaction reviews As needed Capacity-building Support Before project effectiveness and FM training sessions during implementation as needed 93 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) C. Procurement 17. Procurement under the Project will be carried out in accordance with the following World Bank procedures: (i) Procurement Regulations for IPF Borrowers (1st July 2016, revised as of 1st November 2017); (ii) Guidelines on Preventing and Combating Fraud and Corruption in Projects Financed by IBRD Loans and IDA Credits and Grants (15th October 2006, revised as of 1st July 2016); and (iii) other provisions stipulated in the Financing Agreements. 18. Procurement shall be carried out (i) at the regional level by the ECOWAS Commission and (ii) at the national level by Project Implementation Units (PIUs) in Côte d’Ivoire and Guinea for phase 1. The procurement functions will be delivered through the following arrangements: i. Côte d’Ivoire: ONI has been designated by the Government of Côte d’Ivoire to implement the Project. This institution has been well established with various administrative and technical staff of about 35. It carries out procurement activities following the national public procurement law and regulations. ONI has already conducted a lot of preparatory technical work for project activities. This may allow ONI to have a quick start of the procurement under the Project. ii. Guinea: A PIU to be established within the PMO will manage the Project. In the first instance, the implementing agency of the Economic Governance Technical Assistance & Capacity Building Project will carry out the procurement activities for the Project. This agency will be responsible for the recruitment of key project staff, including a procurement specialist. It will also launch the preparation activities, such as drafting Project Procurement Strategy for Development (PPSD), selection of consultants who will propose the technical specifications for the information systems required for the Project. iii. ECOWAS Commission: ECOWAS DFMT has been designated to implement the Project at the regional level. The categories of procurement activities consist mainly of consulting services which will include change management, development of roadmap for the path from a fID system for each of participating countries to an ENBIC, development of a baseline and progress indicators to monitor implementation of mutually recognized fID systems, and strengthening implementing capacity of the ECOWAS Commission. Small contracts for supply of goods may also be procured. The appropriate selection method for each consulting and goods contract would be established in the Procurement Plan. 19. The Bank has assessed the above arrangements. The main procurement risks identified and mitigation measures agreed are as follows: i. Côte d’Ivoire: The main procurement risk identified is the lack of qualified technical and procurement staff within the implementing agency ONI. Its existing procurement team has no experience in Bank- financed projects. Actions to strengthen its procurement capacity agreed during the assessment include: (i) employment of qualified procurement staff: one specialist and one assistant, both dedicated to the Project; (ii) engagement of technical consultants to provide various technical support, including draft ToRs, detail designs and specifications, etc. (iii) Its procurement filing system should be strengthened to ensure complete records are kept for procurement and contract management. 94 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) ii. Guinea: The main risk lies in the fact that the executing agency is to be created from scratch. Furthermore, the executing agency will have to interact with various partners within the government that will be involved from procurement planning to delivery of services and goods the Project will finance. The PPSD has identified the risks, strengths and weaknesses of the parties involved in project procurement activities, as well as the mitigation measures. The Project needs to start with recruitment of qualified key staff, including a procurement specialist familiar with the Bank’s Procurement Regulations and preferably with the relevant technical skill or background. Slowness of procurement process caused by both the low quality of procurement documents and the slowness of decision-making is often observed in Guinea. It is important that the project team is well assisted with technical assistance in the preparation of technical specifications and in the choice of procurement method and market approach. iii. ECOWAS Commission: The ECOWAS procurement system is effective but its efficiency could be improved, as the process steps usually exceed the time allowed under the ECOWAS Tenders Code. The Commission’s Procurement Department has a small staff, and is not familiar with the new Bank Procurement Regulations. Further, procurements going above prescribed thresholds must be approved by the Procurement Committee or the Procurement Board at every critical stage (viz., Bidding Document preparation; Technical Evaluation; Final Evaluation; Negotiation and Draft Contract Preparation), thus causing added delays. As a result, the Procurement Department’s staff may not be able to cope with the additional procurement under the Project. In this regard, a procurement consultant with requisite experience in World Bank Procurement Regulations will be hired to support the Commission for procurement activities under the Project. This also includes the setting up of a robust procurement filing and record management system. To avoid potential long delays in the procurement process due to awaiting approval by Procurement Committee or Procurement Board, the DFMT should be allowed to implement the procurement once the appropriate authority of the Commission has approved the annual workplan. When the Project is launched, procurement-related staff in the DFMT will be provided with a training workshop on the Bank’s Procurement Regulations. 20. The PPSD will be developed respectively by the PIUs of Côte d’Ivoire, Guinea, and the ECOWAS Commission. The Bank will review the PPSDs. A summary will be provided in Attachment 1 to this Annex 3. 21. Consistent with the PPSD, an initial Procurement Plan was developed and agreed upon for ECOWAS Commission and the participating countries respectively, covering the activities of the first 18 months of project implementation. The Procurement Plan will be updated in agreement with the Bank annually or as required to reflect the Project’s actual implementation needs and improvements in institutional capacity. D. Environmental and Social (including safeguards) 22. Social risk management capacity including stakeholder engagement and GRM will be further assessed during implementation. The initial assessment indicates that neither ONI, nor the PIU within the PMO have the capacity to manage the social risks highlighted above. Furthermore, a remote assessment indicates that there are no GRM in place that could be used for the Program. Therefore, the following actions are recommended: (i) staffing, (ii) capacity building, and (iii) establishing of risk management systems. 95 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) Table 12: Social Action Plan Responsible Completion Effectiveness Issue/Topic Milestone Body/Person Date Conditions (i) Preparatory Exercises for Social Assessment Recruitment and appointment of senior social development specialist ONI/ 1 month after NO with experience in GRM and PIU within PMO effectiveness Staffing consultations Recruitment and appointment one ONI/ 2 months after assistant familiar with GRM NO PIU within PMO effectiveness procedures Draft TOR for SAMP disclosed on ONI/PIU within Completed prior Bank’s external website and NO Social PMO and Bank to negotiations Borrower’s website Assessment & ONI/ 2 months after Management Draft SAMP NO PIU within PMO effectiveness Plan (SAMP) Final SAMP disclosed on Bank’s and ONI/PIU within 3 months after NO Borrower’s websites PMO and Bank effectiveness (ii) Implementation of Dynamic Social Management Strategy ONI/ 2 months after Stakeholder Draft SEP NO PIU within PMO effectiveness Engagement Plan Final SEP disclosed in Bank’s external ONI/PIU within 3 months after (SEP) NO website and Borrower’s website PMO and Bank effectiveness Capacity building on social risk management including grievance ONI/ 3 months after Capacity Building NO redress, non-discrimination in the PIU within PMO effectiveness provision of services, etc. ONI/ 3 months after GRM Grievance redress system operational NO PIU within PMO effectiveness Appointment of independent third External party (for oversight of the use of ONI/ 6 months after NO monitoring identification systems) completed and PIU within PMO effectiveness contract signed E. Monitoring and Evaluation 23. Results indicators. Progress toward the achievement of the PDO will be measured based on the PDO- level and intermediate results indicators as part of the Project’s Results Framework (see Section VI). Project management information systems and M&E systems of participating countries will be used to collect relevant data and information pertaining to measuring results, including project outcomes and quality of project execution. The country PIUs will be responsible for carrying out the main M&E functions, with the exception of the first PDO indicator on the legal and technical robustness of the ID system, which will be calculated based on an evaluation performed by the World Bank team based on data supplied by the PIUs. Country PIUs will be responsible for developing a detailed M&E plan, specifying standard protocols and guidelines for data collection and use for the duration of the Project, and will organize trainings for relevant stakeholders in the M&E plan. Progress reports will 96 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) be closely reviewed by the multi-sectoral steering committees set up in each country as well as by the ECOWAS work group created to supervise the Project on the regional level. The country PIUs will provide quarterly monitoring tables and progress reports on all PDO- and intermediate-level results indicators as well as any additional country-level indicators specified in the country projects’ respective M&E plans to the World Bank during routing implementation-support missions. 24. The Project includes five indicators to measure the success or failure of the operation. The first five are PDO-level indicators, measuring the progress toward PDO achievement. Each of these indicators assesses a particular aspect of the PDO: robustness and inclusivity of the country ID system, mutual recognition within ECOWAS, and the population’s ability to use the ID system to access services. At the end of the Project, the success of this operation will be measured against the target values of the PDO indicators. During implementation, the PIUs will be able to measure whether implementation is on track or not by benchmarking against the yearly targets listed in the Results Framework. If project execution underperforms against these yearly indicators, the PIU(s) of the country or countries responsible for the underperformance must propose a list of corrective actions. 25. The views of direct beneficiaries will be brought into the M&E process. Annually, each PIU will ensure that the views of direct project beneficiaries, including institutions (functional users) and individuals (those eligible to receive a UNI), have been accounted for in project M&E. The M&E plan should detail how and at what intervals the views of both groups will be assessed. Data sources may include consultations conducted as part of project stakeholder engagement, data from the GRM, as well as separate data-collection efforts as necessary. 26. Existing M&E arrangements of the country PIUs will be evaluated and capacity gaps addressed. It is expected that the country PIUs will likely need to reinforce their M&E capacity, for example by recruiting or training technical personnel or making improvements to their respective project management information systems in order to better manage project data. The M&E evaluation conducted in each country will identify all such capacity gaps and propose a costed plan for addressing them, including a detailed timeline. The M&E evaluation should be available prior to credit effectiveness in order to allow sufficient time to address the identified capacity gaps through project investments before the main project activities begin. 27. In each country, the PIU will be responsible for developing a detailed M&E plan. This M&E plan will include all project indicators, including all indicators listed herein, as well as any additional indicators deemed necessary to effectively monitor implementation; to identify data sources and data collection protocols for all indicators; to detail logistical arrangements for data collection; and to explain communication needs related to M&E, especially to stakeholders. For each phase of the MPA, the M&E plan should be available prior to credit effectiveness in the respective country in order to allow effective monitoring of Year 1 of each MPA phase. 28. The country PIUs will be primarily responsible for collecting the data needed to measure implementation progress, as specified in the Project’s Results Framework. The PIU will obtain all of the relevant data needed from the data sources identified in the M&E plan to calculate the different required indicators from relevant project stakeholders as necessary. For any data sources that are not under the PIUs’ purview, the relevant PIU will be responsible for identifying a focal point and to detail a data-sharing plan between institutions in compliance with international good practice on data privacy as well as any applicable local laws. These inter- institutional arrangements should be detailed in the M&E plan. 29. The country PIUs will be responsible for data collection, consolidation, analysis, and evaluation. The PIU will submit an M&E quarterly report to both the Bank and to the Steering Committee. Each report will include an 97 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) updated country-level Results Framework and corresponding Action Table listing corrective actions to be implemented with deadlines and persons responsible clearly identified. F. Role of Partners 30. The World Bank is collaborating with various development partners to ensure the rollout of mutually recognizable fID systems across ECOWAS. In the region, there are a variety of donors with a longstanding interest in IDs and CR reform and modernization, including the EU, the AFD, BTC, and the AfDB. The World Bank is in discussions with all of these donors to identify how their efforts in the ID and CR space could best complement the World Bank’s efforts and vice versa. The Bank is also coordinating with UNHCR and IOM on refugee and nationality issues in the region, in particular on how to best ensure that the Bank-financed fID systems remain accessible to such vulnerable populations. UNICEF and the GFF are being consulted on the issue of birth and death registration in the region. The Gates Foundation is providing support for a human-centered design study to inform the design of the fID system in Côte d’Ivoire, which will have broader lessons and implications for the regional Program. G. Implementation Support Plan and Resource Requirements 31. The strategy for supporting project implementation will focus on successfully mitigating the risks identified at various levels and supporting the risk management proposed above in the Key Risks section; it will consist of (i) implementation support missions and (ii) technical assistance. 32. Implementation support missions. The supervision strategy will use a number of instruments to review progress and respond to implementation issues, including: x Implementation support missions will be conducted at least twice per year. Missions will be based on the latest quarterly implementation and financial monitoring reports prepared and submitted by the PIU. Missions will allow the World Bank team to perform evaluations of implementation progress and provide technical support to the PIUs and to any other implementing institutions. Additional implementation support will be provided by field-based World Bank staff. There will be one mission per country as well as one regional mission each year. Support from technical partners will be sought when needed, including from the ID4D team. x Mid-Term Review (MTR): A mid-term review will be conducted within 30 months of credit effectiveness. The purpose of this review will be to assess progress and make recommendations, if necessary, for any changes in the PDO, the content of the components, resource allocation, and performance indicators. The MTR will also serve as a mechanism for revisiting design issues that may require adjustments to ensure satisfactory achievement of the Project’s objective. x Implementation completion: At the close of the Project, each Government, ECOWAS and the World Bank will carry out separate implementation completion reviews to assess the success of the project and draw lessons from its implementation. Each country’s PIU will prepare a completion report documenting the Project’s achievements and results, and drawing lessons for future interventions. The completion report will be based in part on the Project’s technical, economic, social and environmental impact survey studies, as well as an assessment of beneficiaries’ (both functional users and individuals) satisfaction. An Implementation Completion and Results Report (ICR) will be prepared for the Project at closing. 98 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) 33. There will be three regional TTLs, one with a strategic role and two with technical roles, as well as country- specific TTLs. This arrangement will enhance interaction with countries and improve monitoring of progress. The World Bank is seeking possible trust funds to strengthen additional capacity for project supervision and to support learning. 34. Objective of implementation support mission. The implementation support missions will have the combined aim of reviewing the quality of implementation, providing solutions to implementation problems and assessing the likelihood of achieving the PDO. More specifically, they will (i) review implementation progress by component, including institutional development aspects; (ii) provide solutions to implementation problems as they arise; (iii) review each country’s action plan and disbursement programs for the next six months; (iv) review the Project’s fiduciary aspects, including disbursement and procurement; (v) verify compliance of project activities with the World Bank’s environmental and social safeguard policies; and (vi) review the quality of capacity-building activities, which are crucial for an effective implementation of the program. The missions will combine field visits, when feasible; field-based focus group discussions and interactive workshops with stakeholders for feedback; and regional workshops with ECOWAS, as well as workshops with participating countries to highlight implementation issues, pick-up emerging implementation lessons and share mission recommendations, including agreements on actions moving forward. It will also include reviews of semestrial/annual reports and various studies. Implementation Support Plan and Resource Requirements 35. Technical support: Some of the activities contemplated under the Project are technically complex. In addition to the World Bank’s core supervision team, additional expertise may be periodically to provide (i) expert advice on key technology and infrastructure options (panel of experts) and (ii) technical assistance to implementing agencies in the form of hands-on training and mentoring. 36. Focus of support: The first two years of implementation will require technical support, with focus subsequently moving to more routine monitoring, troubleshooting and assessments based on the Results Framework. The implementation support missions to participating countries will be on a semiannual basis, followed by regional workshops to discuss views on progress and challenges. The support missions may be complemented by short visits by technical specialists to follow up on specific thematic issues as needed. 37. Fiduciary support: Fiduciary teams based in World Bank country offices (procurement and FM specialists) will closely supervise the project's fiduciary management. They will participate in the twice-yearly implementation support missions and facilitate capacity building for the Project’s fiduciary needs, and, at least annually, procurement staff will organize a post-review of procurement activities. 38. Support missions: The FM implementation support plan will consist of desk reviews, onsite visits and capacity building. During implementation support missions, the project FM specialist based in the country office will review the FM systems to ensure the continued adequacy of FM arrangements and will follow up on the implementation of the risk mitigation measures agreed during preparation and set out in the FM action plan. The FMS will review the overall operation of the FM system; monitor actions taken on issues highlighted in audit reports, auditor’s management letters, internal audits and other reports; conduct transaction reviews. Desk reviews will include reviews of IFRs and/or annual audited Financial Statements; and periodically assess project compliance with the FM Manual as well as the Financing Agreement. The FMS will conduct training on Bank procedures 99 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) 39. Procurement. On the procurement front, the World Bank will provide implementation support to the client through a combination of prior and post reviews, procurement training to project staff and relevant implementing agencies, and periodic assessment of project compliance with the procurement manual. Implementation support missions will be geared toward (i) reviewing procurement documents, (ii) providing detailed guidance on the World Bank’s Procurement Guidelines and (iii) monitoring procurement progress against the detailed Procurement Plan. Following the recommendations of the fiduciary assessments of the implementing agencies, and in addition to the prior review supervision to be carried out from World Bank offices, the semiannual supervision missions will include field visits, of which at least one mission will involve post review of procurement actions. 40. Safeguards: The World Bank specialists in social and environmental safeguards based in Washington or country offices will provide support to participating countries to ensure proper implementation of the safeguards instruments. Each year, they will conduct implementation support missions to (i) review safeguards reports on project progress, (ii) ensure that procurement arrangements are consistent with the safeguards requirements set out in the project legal agreements and (iii) assess compliance with agreed upon social actions (e.g., mitigation, monitoring, management measures). They will also participate in regional meetings to discuss findings, share lessons learned and propose good practices to help improve safeguards compliance as well as sustainability. 41. Main focus of implementation: Table 13 summarizes the main focus of implementation support during the life of the Project. Table 13: Implementation Support Plan Time Focus Skills Needed x Project start-up x Regional TTLs + Country TTLs x Support to preparatory activities x ID Technical Specialist (sensitization, community x ID Legal Specialist consultations and planning, institution x FM building, strengthening x Procurement implementation capacity including x Social safeguards M&E) x Communications First Twelve x Support to finalization of manuals x M&E Months x Guidance on applying safeguard x Leadership development instruments x Development of impact evaluation methodology and oversight of baseline survey x Establishing coordination mechanisms with complementary projects x Monitoring implementation x Regional TTLs + Country TTLs performance including progress x ID Technical Specialist x Review technical designs and x ID Legal Specialist 12–48 architecture, legal and institutional x FM Months design. x Procurement x Review of annual work plans and x Social safeguards disbursement schedule x Communications 100 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) x Review quality of semestrial/annual x M&E reports, data, and various produced x Leadership development studies x Assess quality of implementation process and data collected x Review of audit reports and IFRs x Review adequacy of the FM system and compliance with financial management covenants x Assess quality of safeguards instruments as they are applied 42. Skills mix required: Table 14 summarizes the skills mix required for project implementation. Table 14: Skills Mix Required Skills Needed Number of Staff Weeks Number of Trips Comments Regional TTLs 10 2 HQ- based Operations Officer 10 2 HQ- based Country TTLs 10 2 for each HQ/CO- based ID technical specialist 20 2 HQ- based ID legal specialist 20 2 HQ- based FM 6 1 CO- based Procurement 6 1 CO- based Social Development 6 2 CO- based Communications 2 1 HQ- based M&E 2 1 HQ- based Leadership 2 1 HQ- based Development 101 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) Attachment 1: Summary of Project Procurement Strategy for Development A. Côte d’Ivoire The total value of the financing for Côte d'Ivoire is US$67.0 million, of which more than 80 percent is dedicated to acquisitions of goods and related services. x Goods and related services: they are mostly standard goods and equipment and readily available from the local market. However, the acquisition of tablets for identification will have to be awarded through international competitive bidding because of certain specialized technical requirements. x Consultancy: Recruitment of consultants will be mainly subject to open competition. For the most important studies required for project, expertise will be at the international level. It is therefore important to ensure that the publication of notices is done through international channels. Attention should particularly be paid to ensure quality of the terms of reference. Consulting firms and even individual national consultants may be mobilized for studies for which expertise is sufficiently provided by the local market. x Works: The national market offers a diversity of entrepreneurs of different sizes for most activities in this category. For the specific work of development of computer sites (Central and Backup), local expertise has been proven with all the work already done in Côte d'Ivoire. However, for greater efficiency, international competition should be considered. B. Guinea The total value of the financing for Guinea is US$49.7 million, mostly to be used in ICT infrastructure and Equipment (9 percent of the amount) and Consultant’s Services (81 percent of the amount) x ICT infrastructure and Equipment (US$4.5 million, 9 percent of the amount): these contracts comprise Data Centers principal and secondary; Biometric Readers for Service delivery; Tablets for interoperability; Vehicles. The Data Centers principal and secondary contracts will be procured through International Open Competition and the Biometric Readers for Service delivery; Tablets for interoperability; Vehicles will be procured through National Open Competition. x Consultant’s Services (US$40.4 million, 81 percent of the amount): Consultancies to be implemented will include, institutional framework and capacity building; Turnkey foundational ID systems implementation; Mass registration and enrollment of individuals in IDs; Basic credential issuance system and rollout; Interoperability with civil registration system; Monitoring and Evaluation; Implementation of Interoperability framework and platform for access to social safety net services and rollout across the country; Change Management and Stakeholder Communications; Social Management Plan to address ongoing risks of exclusion and risk of data protection, etc. Since there may not be well qualified consulting firms in Guinea for all such assignments, most of these contracts will be advertised internationally. 102 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) C. ECOWAS Commission The total value of financing for ECOWAS is US$5.0 million mostly to be used for fostering inter-agency collaboration and strengthen regional engagement in West Africa based on foundational ID systems and the ECOWAS NBIC. The procurement will consist mainly of selection of consultants x Consultancies will include change management, development of roadmap for the path from a foundation ID system for each of the countries participating in the project to an ENBIC, development of a baseline and progress indicators to monitor implementation of mutually recognized foundation ID systems, and strengthening implementing capacity of the ECOWAS Commission. It may be difficult to get well qualified consulting firms in the ECOWAS sub-region who have participated in the such previous similar assignments. However, it is expected that some competition is likely from other countries of West Africa, as well as from outside Africa. For this reason, such consulting assignments will be advertised internationally. x Other goods such as office and ICT equipment/consumables are available locally. Given by the size and nature of goods to be procured, most of the potential bidders are available locally, using simplified competitive quotation procedures. 103 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) ANNEX 4: STAKEHOLDER ENGAGEMENT AND SOCIAL RISK MANAGEMENT COUNTRY: Western Africa West Africa Unique Identification for Regional Integration and Inclusion (WURI) A. Strategy and Approach for Implementation Support 1. Stakeholder engagement (SE) is a core responsibility of all World Bank projects and is especially critical in assessing, mitigating, and addressing potential social risks related to the design and rollout of ID systems. The Project will employ a variety of methods for engaging all individuals who are impacted by ID systems, and closing the feedback loop between these persons and government on project design and implementation. CE in this operation aims at creating an environment that will facilitate effective delivery of project benefits through promotion of transparency and accountability, stakeholder participation, grievance redress, regular monitoring to improve operational performance and mitigation of project risks. The Project is supported by an RSR, which is focusing on the needs and perspectives of vulnerable groups in IDs through activities which include legal framework reviews, targeted research, and formal and informal consultations with key groups. 2. In addition to closing the feedback loop between people and government, CE activities will focus on ensuring that technocratic solutions do not inadvertently institutionalize discrimination against vulnerable groups. Strengthening fIDs should result in direct gains in the provision and efficiency of social services, safety net benefits, pensions, among others. However, improving ID systems also could result in the unintended consequence of making access to services more difficult for people who cannot get identification and can ultimately lead to further marginalization of the poorest and most vulnerable. Thus, the operation pays particular attention to inclusion of the perspectives and needs of marginalized groups such as orphans and vulnerable children (OVC), unaccompanied children, migrants, women, elderly persons, persons with disabilities, persons belonging to religious, linguistic and ethnic minorities, gender minorities, refugees, asylum seekers, internally displaced persons, border populations, non-citizens and stateless persons, amongst others. 3. The aim of the CE activities is to ensure that the ID systems in the sub-region reach those most in need— the poor and vulnerable who require access to services—and that the design and implementation do not exacerbate marginalization or exclusion, and indeed that these persons are offered an avenue through which to influence the design of the ID systems. The operation will primarily employ the following methods for CE: (i) Communications and Engagement Plans for regular engagement with beneficiaries and stakeholders in the ID landscape at regional and national levels; (ii) robust communications strategies at regional and national levels; (iii) GRMs at national levels 132; and (iv) monitoring (through, e.g., community reporting through information boards, social media, local newspapers or through the use of community scorecards). These scorecards and reporting could help build a two-way communication that will enable feedback and responsive action. 4. Meaningful consultations can contribute to improved design, implementation and sustainability of the Project. They provide an avenue for receiving and acting on input relevant to project design and implementation, 132The operation is benefitting from an RSR to identify the key vulnerable groups in each country and design and implement consultations and other stakeholder engagement activities to ensure the project accounts for their needs and does not cause further marginalization or exclusion. WB RSR12 - P164513 (2017). 104 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) give voice to the needs of marginalized groups, improve project risk management and increase transparency and public understanding. 133 5. Stakeholder identification and analysis for participation in the consultations has included due consideration of representativeness and inclusion of vulnerable groups. Groups to be consulted in every country shall include: women, youth, elderly, persons with disabilities and refugees, forcibly displaced and stateless persons. Additional key groups have been identified based on the particular country context (e.g., minority ethnic/nationality groups, geographically isolated communities) with the help of experts. The use of independent third-party specialists might be needed to support an inclusive engagement process. 6. Pilot methodologies for the consultations will include a series of roundtables, field-based research and open, national consultation meetings with civil society, beneficiaries and other stakeholders to solicit feedback on project design and implementation and, over time, report back on how that feedback is incorporated. These will form the basis of an active and ongoing feedback loop under the operation. This multi-methods approach to consultations will ensure operations in each country reach civil society more broadly, and especially vulnerable groups who cannot actively and meaningfully participate in national consultations due to distance, safety or access issues—the “last mile” groups (including, based on country context, e.g., refugees and the forcibly displaced; border communities; stateless persons; the elderly; gender minorities; persons with disabilities and their caregivers; minority ethnic/nationality groups). Methodologies will range from individual and regional meetings or roundtables to focus groups to participant-observer research, depending on the context in each country and the best way to contact hard to reach groups. Information will be disclosed in relevant local languages in a culturally appropriate and accessible manner, taking into account the differentiated needs of vulnerable groups. 7. A robust communications and outreach strategy is an important tool for large-scale interventions. Individuals, beneficiaries, communities, implementers and officials need a strong understanding of project information (e.g., entitlements, objectives, eligibility, service standards). Communications strategies should provide quality information that is easily consumed by the public, available in multiple languages, and disseminated via various media (e.g., radio, television, newspapers, pamphlets, roadshows). 8. ECOWAS will develop a communications strategy at regional level as part of its grant. The regional communications strategy will focus on fostering country buy-in for regional mutual recognition and addressing concerns, and undertaking advocacy campaigns and sensitization about social issues (e.g., privacy, movement, security, inclusion, statelessness). 9. Participating countries will develop communications strategies at national levels which are tailored to their particular context and effectively explain the ID lifecycle. The strategy will explain each step, from eligibility through enrollment and receipt of credentials, and will address concerns about privacy, costs, links to nationality, access, usefulness (i.e., why an ID is necessary) and other pertinent elements. 10. Communications strategies will be informed by the feedback received during the consultations process to ensure these are tailored to specific groups within each country to facilitate maximum take-up of fIDs. 133Manroth, Astrid; Hernandez, Zenaida; Masud, Harika; Zakhour, Jad; Rebolledo, Miguel; Mahmood, Syed; Seyedian, Aaron; Hamad, Qays; and Peixoto, Tiago. 2014. Strategic framework for mainstreaming stakeholder engagement in World Bank Group operations: engaging with citizens for improved results (English). Book. Washington, DC: World Bank Group. http://documents.worldbank.org/curated/en/266371468124780089/Strategic-framework-for-mainstreaming-citizen-engagement-in- World-Bank-Group-operations-engaging-with-citizens-for-improved-results. 105 The World Bank West Africa Unique Identification for Regional Integration and Inclusion (WURI) (P161329) 11. As part of their communications strategies, participating countries will introduce public awareness campaigns outlining the rights and responsibilities users and service providers and set service standards which are publicly relayed. These are building blocks for a strong system of stakeholder engagement which actively involves beneficiaries in providing feedback about the Project. For example, the campaign should be particularly clear about service standards (i.e., entitlement/eligibility for an ID, right to grievance redress) and how to access a redress system. 12. Specific communication on the GRM system will be supported. This will include: the types of grievances that can be submitted; how to submit a complaint; standards and timeframes for complaint resolution; and options available to a complainant if she or he is dissatisfied with the grievance redress process or outcome. Communications should aim to reach vulnerable groups and emphasize that there is no financial charge for making a complaint; grievances help improve project policies, systems and service delivery; and grievances will be confidential and complainants will not be punished for submitting them. B. Grievance Redress Mechanism 13. The Project will establish GRM at national levels. A GRM is a system which responds to queries or clarifications, resolves problems with implementation, and efficiently and effectively addresses complaints and grievances. The GRM will (i) be responsive to the needs of beneficiaries and non-beneficiaries and address and resolve grievances; (ii) serve as a channel for soliciting enquiries, inviting suggestions and increasing participation; (iii) collect information to improve operational performance; (iv) enhance project legitimacy among stakeholders; (v) promote transparency and accountability; and (vi) deter fraud and corruption and mitigate project risks. 14. In developing the GRM, multiple avenues for connecting with beneficiaries will be explored using a variety of technology-based channels (e.g., hotlines, SMS systems) to triage complaints to various government systems, as well as alternative grievance resolution channels, such as traditional or religious leaders and faith- based organizations. GRM manuals will be developed to guide stakeholders on their key functions, roles and responsibilities. These will include clear steps on how to address each type of appeal or complaint with clear procedures to be followed; and ensure that feedback is provided to complainants. The GRM manual will also set performance standards and targets for grievance handling. Grievances should also be linked to the Project monitoring and information system (e.g., template on GRM module will be linked). An independent fraud and corruption component could be linked to the GRM, as necessary. 15. GRM reviews will take place each year to ensure that the GRMs produce results. If complaints and queries are not responded to in a timely manner, beneficiaries will not trust the system. Measuring performance of the GRM is critical to understanding whether beneficiaries are aware of how to register complaints and staff are handling grievances properly and in a timely fashion. Lessons learned from the reviews will be fed back into the GRMs, communications strategies and consultations, as applicable, to strengthen operational performance and overall stakeholder engagement systems. 106