Banking Sector Reform Tracker
May 21, 2025
Transparency International - Lebanon
Transparency International - Lebanon

Banking Sector Reform Tracker[1]

Reform Area: Banking Sector Restructuring & Transparency
Last Updated: November 2025

Citizen Impact Summary

Dimension

Snapshot

Source

Who Is Affected?

Every depositor and account holder in Lebanon; real GDP has already contracted 37 % between 2018‑2022, wiping‑out 15 years of growth and pushing large parts of the middle‑class into poverty.

Haircuts on FX deposits estimated at 60–80%, with 2.5 million accounts under $200K losing ~$15B.

World Bank Lebanon Economic Monitor, Spring 2023;

World Bank Lebanon - Systematic country diagnostic, Summer 2024

Financial Burden?

Headline inflation averaged 171 % in 2022 (150 % in 2021; 218 % in H1‑2022) and forced‑deposit “lirafication” is imposing 60‑80 % hair‑cuts on savers.

Banking sector is effectively insolvent, with estimated losses over US$70 billion. 75% of assets are with BdL and 3% with government securities; 70% of loans are non-performing.

Cash now constitutes 46% of GDP. This shift undermines anti-money laundering frameworks and deepens informality.

World Bank Lebanon Economic Monitor, Spring 2023;

World Bank Lebanon - Systematic country diagnostic, Summer 2024

Public Services?

A 7‑fold drop in real primary spending since 2018 has led to an “acute collapse of public‑service delivery”, including electricity, water, education and health.

World Bank Lebanon Economic Monitor, Spring 2023

MentalHealth Toll?

Living‑standards keep eroding, poverty is spiralling and a “precarious environment” prevails, fuelling anxiety, emigration and social fragmentation.

World Bank Lebanon - Systematic country diagnostic, Summer 2024

Overview & Objectives

Goal

Restore solvency, liquidity, and trust in the banking sector. Rebuild financial intermediation.

Strategic Importance

Rebuilding financial intermediation capacity is critical to economic recovery. Without restructuring, credit will continue contracting, informal cash use will grow, and anti-money laundering risks will deepen.

Key Reform Priorities

1️. Adopt a comprehensive bank restructuring strategy to recognize and allocate losses transparently and equitably.

2️. Conduct externally assisted bank-by-bank evaluations to identify losses and inform resolution paths (mergers, acquisitions, liquidation).

3. Recapitalize viable banks based on independent AQRs and rigorous valuation methods; Exit non-viable banks.

4. Rehabilitate the financial safety net including prudential regulation, resolution, lender-of-last-resort, and deposit insurance.

5. Reform Banque du Liban and the BCC to regain monetary authority and improve supervision.

6. Introduce formal capital controls and a unified exchange rate.

7. Operationalize data-sharing between SIC and PPA in line with Law No. 1/2025.

8. Publish a transparent loss-allocation and recapitalization strategy, including asset recovery.

9. Implement reforms to avoid FATF grey-listing in the 2026 review.

10. Amend the bank secrecy law to meet international transparency standards.

Reform Actions & Status

Specific Reform Actions & Accountability

Reform Action Required

Current Status

Lead Authority

Implementing Body

Oversight / Supporting Actors

Primary Source

Technical consultations on restructuring roadmap and FATF priorities

Completed. BdL Governor held high-level technical consultations in Paris and Washington on banking sector restructuring, crisis management, capital flow measures, and FATF observations, including steps toward removal from the grey list and safeguarding correspondent banking links.

BdL

BdL, with MoF and relevant agencies

IMF, French Treasury, US Treasury

NNA communiqué, 30 Jun 2025

Bank Restructuring Law

Adopted July 31, 2025; partially annulled on Oct 3, 2025 by the Constitutional Council, which reinstated the suspensive effect of appeals and struck several provisions. Execution still frozen pending the Financial Gap/Deposit Recovery Law.

Parliament / CoM

MoF, BdL, BCC

IMF, WB, EU

Parliament session 31 Jul 2025; LBCI; Asharq Al‑Awsat 31 Jul 2025; L’Orient Today 2025

Bank-by-bank assessments - AQRs (Asset Quality Reviews)

Pending; ToR not signed; IMF recommends using SDRs to fund international auditors.

CoM, BdL

BdL, BCC

IMF, WB

World Bank Lebanon - Systematic country diagnostic, Summer 2024; CoM, 8 Apr 2025; IMF Comments on Bank Resolution Draft, May–June 2025

Recapitalization of Viable Banks

Stalled. Based on independent Asset Quality Reviews (AQRs) and rigorous valuation methods. Non-viable banks to exit. Awaiting results of AQRs and clarity on loss-allocation. No recapitalization mechanisms implemented yet.

BdL, MoF

Banks

IMF, WB

AlJoumhouria, May 2025; IMF Comments on Bank Resolution Draft, May–June 2025

Resolution of Non-Viable Banks

Enabled by new law but frozen until Financial Gap Law; process to include depositor participation and loss hierarchy enforcement.

CoM, Parliament

BdL, MoF

IMF

World Bank Lebanon - Systematic country diagnostic, Summer 2024; LBCI 28 Jul 2025

Amend Bank Secrecy Law (to meet FATF/IMF criteria)

Partial reform enacted, further amendments pending. Law No. 1/2025 grants Special Investigation Commission (SIC) full access, but implementation lags due to lack of a BdL circular regulating procedures. Still allows discretionary opacity; obstructs SIC and AQR data access. The practical ability of institutions to act without political interference; The lack of automatic enforcement without further decrees; Concerns about appeal mechanisms that may delay or dilute effectiveness. A draft implementing decree for Article 3 was placed on the Cabinet agenda in early Oct 2025 to operationalize data-access procedures.

Parliament

MoF, BdL

FATF, IMF, EU

World Bank Lebanon - Systematic country diagnostic, Summer 2024; L’Orient Today 2025

Formal Capital Controls & Unified Exchange Rate

Not in place; informal restrictions continue. Draft in Parliament; not IMF-compliant. The draft includes retroactive clauses and suspends judicial rulings, breaching IMF Art. VIII compliance. Formal capital controls to defend reserves. Unified, market-driven exchange rate.

Parliament

BdL, MoF

IMF, ABL

Al-Modon, 8 May 2025; Asharq Al-Awsat, 30 Dec 2023

Loss Recognition & Allocation Plan

Stalled; no agreement between key actors, and due to unresolved debate between MoF and PMO over burden-sharing between state and depositors. Recognize and allocate financial losses transparently and equitably.

MoF / BdL

BdL

IMF

World Bank Lebanon - Systematic country diagnostic, Summer 2024;

Judicial Accountability for Financial Crimes

Limited enforcement; political obstruction persists. BDL announced internal anti-corruption purge in April–May 2025. Cooperating with European law firms to pursue embezzlement and illicit enrichment cases involving former and current officials.

Judiciary

MoJ, Courts

EU, WB, CSOs

World Bank Lebanon - Systematic country diagnostic, Summer 2024; L'Orient Today, 22 May 2025

Rehabilitation of Financial Safety Net

Reform prudential regulation, resolution, lender-of-last-resort, and deposit insurance. Weak regulation, no functioning deposit insurance mechanism.

BdL

BdL, BCC

IMF, WB

World Bank Lebanon - Systematic country diagnostic, Summer 2024

Reform of Banque du Liban (BdL) and Banking Control Commission (BCC)

BdL to regain monetary authority and safety net functions. Stronger banking supervision and licensing.

Parliament

BdL, BCC

IMF

World Bank Lebanon - Systematic country diagnostic, Summer 2024

Reform Roadmap Timeline & Critical Path

Recent Milestone

Recent Milestone

Date

What Happened

Status on Critical Path

Source

Constitutional Council partial annulment of Bank Restructuring Law

Oct 3, 2025

CC reinstated suspensive effect of appeals and struck several articles.

“High-impact delay - requires amendments before resolutions can proceed.”

L’Orient Today, Oct 9, 2025.

BdL prudential updates

Sept 10 and Oct 9, 2025

Issuance of Intermediate Circular 13748 on capital adequacy and Public Announcement No. 966 on implementing Intermediate Circular 13750.

Enables supervisory preparation but does not substitute for AQRs or loss-allocation law.

BdL announcements (2025)

IMF Staff Visit

Late Sep 2025

IMF mission concluded Sep 22–25, 2025; follow-up engagement during Oct Annual Meetings.

On critical path for program design

IMF Staff Concludes Visit to Lebanon - September 26, 2025

Banking Reform Law Adopted

31 Jul 2025

Parliament passed law on bank restructuring and depositor prioritization.

Completed – execution pending

LBCI; Asharq Al‑Awsat 31 Jul 2025

Committee Approval (Finance & Budget)

28 Jul 2025

Finance Committee approved final amended draft after 6‑hour session; linked law to deposit recovery bill.

Completed

Parliament minutes

IMF Comments on Draft Bank Resolution Law

12 May 2025

IMF issued detailed technical comments on the draft law, citing concerns over depositor protections, weak resolution safeguards, and legal ambiguity.

Feedback under review by Parliament

IMF Comments on Bank Resolution Draft, May–June 2025

Subcommittee begins hearings on competing restructuring law draft

6 Jun 2025

Finance & Budget Subcommittee opened discussions on competing ideas: one favors an independent authority; the other, BDL control over restructuring.

Ongoing debate – risks delay

LP June 2025

Bank Secrecy Final Amendment (Law 1/2025)

24 Apr 2025

Adopted by Parliament on 24 April 2025 and published in the Official Gazette on 25 April 2025. Expands authority to lift secrecy for oversight, auditing, and restructuring purposes. BdL, BCC, and the National Deposit Guarantee Institute can now request full access to banking records for restructuring and auditing without needing to specify individual accounts. Requests may be challenged before an urgent matters judge. Requires a decree from the Council of Ministers upon recommendation by the finance minister, following BdL input.

Completed – prerequisite for IMF PriorAction #2

Official Gazette No. 17, 25 Apr 2025

CoM Approval of Bank Reform Draft

12 Apr 2025

Full law finalized by CoM; to be transmitted to Parliament.

Urgent – referenced as “over‑due”

CoM Minutes

IMF Art. IV – Staff concluding statement

23 Mar 2025

Re‑affirms need for restructuring & capital controls

Urgent – referenced as “over‑due”

IMF press‑release 23‑3‑2025

PPA internal & financial regulations adopted

18 Dec 2024

Enables transparent disposal of bank assets/contracts

Completed

Decree No. 27 dated 28 January 2025 – Financial Regulations of the Public Procurement Authority; Decree No. 28 dated 28 January 2025 – Internal Regulations of the Public Procurement Authority

 

Next Steps – Transparency and Accountability Calendar

Action

Responsible Entity

Target Date

Source

FATF action plan updates

BdL, SIC

Q4 2025

NNA communiqué, 30 Jun 2025

Submit Financial Gap & Deposit Recovery Law

MoF / PMO

Q3 2025

Parliamentary Finance Committee, Jul 2025

Constitute Higher Banking Authority (2‑chamber)

BdL / MoF / Judiciary

Q3 2025

LBCI News, 2 Aug 2025; Asharq Al‑Awsat, 31 July 2025

Sign decree approving AQR ToR; start fieldwork

BdL Governor & Finance Minister

N/A

N/A

First SIC public report on bank data disclosure requests

SIC

N/A

N/A

MoF publishes loss allocation simulation (baseline)

MoF

N/A

N/A

Parliament Finance/Justice joint session on Capital Control law

Speaker of Parliament

N/A

N/A

 

Implementation Bottlenecks & Required Actions

Bottleneck

Official Explanation

Required Immediate Action

Source

IMF identifies flaws in final restructuring law

Draft law deviates from international standards, including weak depositor protections and unclear RA independence

Revise law based on IMF’s 9-point critique

IMF Comments on Bank Resolution Draft, May–June 2025

Competing Proposals for Restructuring Authority

CoM draft removes ABL and empowers new body; BdL draft centralizes authority in BDL

Parliament must reconcile competing ideas; CSOs should demand independent oversight

Now Lebanon, May 2025

Financial Gap Law not submitted

MoF hesitant to define loss-sharing terms

Urgently draft and submit law to define loss distribution

MTV June 2025

Cabinet deadlock over loss sharing formula

MoF & PMO disagree on treating large depositors vs. state asset fund.

Convene tripartite MoF PMO IMF mediation workshop.

-

AQR budget unfunded

BdL cites FX shortage; MoF hesitant to authorize use of SDRs.

Sign ToRs and approve use of IMF SDR allocations for international AQR auditors.

-

Capital Control law constitutional concerns

Some MPs oppose retro‑active clauses.

Amend draft to include sunset clause + judicial review article.

-

Legal Fragmentation

Conflicting laws (e.g., capital control vs. judicial rulings) risk legal chaos.

Amend legal text to include judicial oversight and sunset clauses.

-

Elite Resistance

Powerful stakeholders resist equitable loss distribution

highlight regressive effects of delay.

-

 

Stakeholders & Roles

Entity

Core Function

Contact

Council of Ministers

Reform adoption & law submission

Presidency of CoM

Banque du Liban (BdL)

Bank supervision, macro-oversight

BdL Governor’s Office

Banking Control Commission

Regulatory oversight & assessment implementation

BCC

Parliament

Legislative approval of laws

Finance & Admin Committee

IMF / World Bank

Technical assistance and monitoring

IMF Resident Office

Association of Banks (ABL)

Sector representation & negotiation

ABL

CSOs / Depositor Groups

Advocacy, accountability

Legal Agenda, Depositors Union

 

Legal & Policy Framework

Instrument

Status

Key Provisions

Implementation Note

Bank Secrecy Law (1956) as amended by 306/2022 & 1/2025

In force

Full look through for SIC, tax & judicial bodies; no BdL veto.

BdL circular on procedures pending.

Monetary & Credit Law – Art 150 (amended 2022 & 2025)

In force

BdL must report FX reserve position quarterly to Parliament’s Budget Committee.

-

Draft Bank Restructuring Law

Cabinet draft (May 2025)

Loss hierarchy; bridge bank tool; depositor bail in limits.

Needs Cabinet approval then FastTrack to Parliament.

Capital Control Bill (9014/2023 & MP draft)

Committee stage

Temporary FX controls; withdrawal ceilings; dispute resolution panel.

Must align with IMF Art VIII by‑laws.

 

Official Sources and Reference Materials

 

Document

Where to access

Statement of Ministerial Policy (Feb 2025)

Statement of Ministerial Policy (Feb 2025)

World Bank Lebanon - Systematic Country Diagnostic, Summer 2024

World Bank Lebanon - Systematic country diagnostic, Summer 2024

World Bank Lebanon Economic Monitor, Fall 2022

World Bank Lebanon Economic Monitor, Fall 2022

IMF 2023 Staff Concluding Statement

IMF 2023 Staff Concluding Statement

Law No. 1/2025 (BankSecrecy amendment)

-

IMF Staff Concludes Visit to Lebanon

IMF Staff Concludes Visit to Lebanon

List of Acronyms – Banking Sector Reform Tracker

Acronym

Full Name

ABL

Association of Banks in Lebanon

AQR

Asset Quality Review

BdL

Banque du Liban (Central Bank of Lebanon)

BCC

Banking Control Commission

CoM

Council of Ministers

CSOs

Civil Society Organizations

EU

European Union

FX

Foreign Exchange

IMF

International Monetary Fund

MoF

Ministry of Finance

MP

Member of Parliament

PPA

Public Procurement Authority

PMO

Prime Minister’s Office

SDR

Special Drawing Rights (IMF reserve asset)

SIC

Special Investigation Commission (Anti-Money Laundering Unit)

ToR

Terms of Reference

WB

World Bank

 



[1] All reform data presented here is based on official Lebanese government sources, such as laws, decrees, strategies, and verified public data. Where possible, each update is linked to a document, gazette entry, or institutional publication.

Transparency International – Lebanon is not responsible for the accuracy, completeness, legality, reliability, or appropriateness of any content published, uploaded, or shared by Civil Society Organizations (CSOs) through the Platform. The responsibility for all content lies solely and entirely with the CSO that publishes it. TI-Lebanon does not endorse or guarantee any opinions, recommendations, or statements expressed in such content. Each CSO remains solely accountable for ensuring that its published content complies with applicable laws and regulations.

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Enforce environmental and UXO protocols for rubble removal and prevent illegal sea dumping. 4. Activate Reconstruction Fund and donor pipeline beyond WB’s $250M symbolic financing. 5. Embed municipal and CSO-led initiatives into the national reconstruction plan. Reform Actions & StatusSpecific Reform Actions & Accountability Reform Action Required Current Status Lead Authority Implementing Body Oversight / Supporting Actors Primary Source Establish Transparent Reconstruction Fund Operationalization advanced: CDR opened multiple LEAP procurement files end-Sept through Oct 2025, including EOIs and ToRs for World-Bank-financed consultancy packages, signaling the move from preparation to execution. PMO (strategic guidance) CDR implementing, MoPWT execution lead, MoE environmental oversight WB to recruit lender’s engineer for enhanced due diligence incl. 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Parliament / MoF MoF, Municipalities Council of Ministers Manaaṭeq Net Central Oversight for Rubble Removal CDR’s public procurement postings for LEAP in late Sept–Oct 2025 confirm CDR as implementing agency under WB IPF rules, with MoPWT/MoE counterparts PMO / CoM CDR, MoPWT MoE; WB lender’s engineer for compliance Najat Saliba interview, Manaaṭeq Net, July 2025; World Bank PR, Jun 25, 2025; Loan-signing reports, Aug 26, 2025; CDR 2025; CDR & LEAP 2025; CDR 2025 Make MoE Guidelines Legally Binding Weak compliance: sea dumping at Costa Brava, minimal sorting, no full EIA enforcement Ministry of Environment Contractors, Municipalities UN Debris Taskforce, Central Inspection MoE Presentation, Feb 2025; Najat Saliba interview, Manaaṭeq Net, July 2025 Mandate Use of Quarries for Disposal Weak enforcement – dumping continues in unregulated coastal and valley sites; quarry rehabilitation remains largely voluntary. MoE oversight is embedded in LEAP’s E&S arrangements, with WB-supervised compliance, but national binding force of earlier circulars still requires decree. Ministry of Environment Contractors MoE, Environment Police Youth4Governance Policy Brief, Feb 2025; World Bank PR, Jun 25, 2025; Loan-signing reports, Aug 26, 2025 Establish National CDW Database Proposed – identified as a priority in MoE’s 2025 action plan; no operational system yet. Ministry of Environment MoE PCM, Municipalities MoE Presentation, Feb 2025 Transparent Contractor Framework Partial: Beta & EMC contracts signed at $5.01 urban / $3.65 rural per m³; informal scrap incentives persist. Future procurements under LEAP will operate within WB procurement and enhanced due-diligence regime, including third-party lender’s engineer oversight. Council of the South Contractors, local subcontractors Municipalities, Media Manaaṭeq Net, July 2025; World Bank PR, Jun 25, 2025; Loan-signing reports, Aug 26, 2025 EIA Screening Compliance for Contractors MoE Circular issued, non-binding – contractors are not legally obligated to follow EIA compliance; screening forms exist but lack enforcement. Ministry of Environment Contractors MoPWT, MoF, Procurement Units MoE Presentation, Feb 2025 Hazardous Material Protocols (Asbestos, UXO, etc.) Guidelines exist, not enforced – security and health risks persist due to unclear implementation mechanisms for hazardous material detection and separation. MoE, LAF Security Forces, Contractors MoPH, UN agencies CDW Policy Brief (AUB Nature Center, Nov. 2024) Develop Circular Recycling Infrastructure Not systematized – pilot efforts exist but no formal circular economy policy has been implemented for CDW. Ministry of Environment Private Sector, Municipalities AUB, CDR, World Bank, EU Delegation CDW Policy Brief (AUB Nature Center, Nov. 2024) Integrate Municipal & CSO Reconstruction Initiatives Ongoing ad hoc: Houla & Meiss el-Jabal lead self-funded water & solar recovery Municipalities Local CSOs, Diaspora UNIFIL, NGOs Municipal interviews, Manaaṭeq Net Reform Roadmap Timeline & Critical PathRecent Milestone Recent Milestone Date What Happened Status on Critical Path Source CDR launches LEAP procurement packages 30 Sep–22 Oct 2025 EOIs/ToRs for consulting services published under WB IPF regulations, marking the shift to implementation Procurement kick-off. CDR 2025; CDR & LEAP 2025; CDR 2025 WB Board approves LEAP US$250M 25 Jun 2025 Approval of scalable US$1B framework covering urgent infrastructure repair and sustainable rubble management Funding Initiated World Bank PR, Jun 25, 2025; Loan-signing reports, Aug 26, 2025 Government signs WB loan agreement (LEAP) 26 Aug 2025 Financing agreement signed in Beirut, authorities highlight intent to channel funds to multi-sector infrastructure works Financing Effectuation Step World Bank PR, Jun 25, 2025; Loan-signing reports, Aug 26, 2025 Law on Exemptions & Demolished Buildings passed 1 July 2025 Property-focused law enacted; provides tax/service exemptions and conditional financial assistance Core Legal Milestone WB RDNA 2025; Public Works Studio July 2025 WB approves $250M loan 25 June 2025 Initial symbolic financing for rubble removal & infrastructure repair Funding Initiated WB Press Release Council of South contracts awarded 17 Feb 2025 Beta & EMC begin rubble removal; subcontract to village operators Operational Start Manaaṭeq Net Rubble pricing set April 2025 $3.65/m³ rural & $5.01/m³ urban formalized Financial Terms Finalized Council of South PM announces donor conference initiative June 2025 PM Salam announced plans for donor conference focused on reconstruction and strategic investment Roadmap Under Preparation PM Speech, 10 June 2025 Draft compensation law submitted to Parliament June 2025 Government submitted draft compensation law to Parliament covering tax/service fee exemptions for affected residents   PM Speech, 10 June 2025 MoE Circular on War Debris Guidelines Dec 2024 The Ministry of Environment issued a circular providing guidelines for managing war-generated rubble, recommending disposal in environmentally degraded sites, particularly quarries. However, this circular remains non-binding. Lacks enforcement Youth4Governance Policy Brief, Feb 2025 Gov’t approval of Solid Waste Authority Jan 2024 The Council of Ministers approved the organizational decree under Law 80 (2018) to establish the National Solid Waste Management Authority, aiming to centralize waste management efforts. Partial progress Law No.80 of 2018 on Integrated Solid Waste Management World Bank Presents Reconstruction Project March 2025 The World Bank introduced a $1 billion reconstruction project to Prime Minister Nawaf Salam, including a $250 million loan for initial reconstruction efforts. Initiated Funding Process OLJ News Report UN Launches Debris Taskforce May 2025 The United Nations established a Debris Taskforce in Lebanon to manage rubble removal with a focus on sustainability and rights-based approaches. Enhanced Coordination UN Sustainable Development Group Mobilize South Lebanon Council for debris ops March–May 2025 Operational in South, Bekaa, Nabatieh; 80% damage survey completed; 2-month deadline for contractors to clear 35K units Operational Execution Council of the South, "An-Nahar", 20 April 2025 Set rubble pricing and contractor terms April 2025 Official rate set at $3.65/m³ rural and $5.01/m³ urban; contracts underway Financial Terms Finalized Council of the South, "An-Nahar", 20 April 2025  Next Steps – Transparency and Accountability Calendar Action Responsible Entity Target Date Source Publish LEAP governance note, procurement plan, and E&S oversight modality: Align with WB’s enhanced due-diligence and AML/CFT measures CDR + MoPWT + MoE Q4 2025 World Bank PR, Jun 25, 2025; Loan-signing reports, Aug 26, 2025 Paris-led donor engagements for reconstruction: conditional on reforms - French diplomacy indicates conferences when “appropriate conditions are met.” PMO / France TBC L’Orient Le Jour, Sept. 2025 Issue implementing decrees for “Law on Exemptions & Reconstruction of Demolished Buildings” (July 2025) CoM + MoF + Parliament Q3 2025 WB RDNA 2025 Finalize valuation and survey mechanism for affected properties MoF + HRC + Council of the South Q3 2025 Youth4Governance Policy Brief, Feb 2025 Publish criteria and process for conditional financial aid (property-focused) MoF + Municipalities Q3 2025 Public Works Studio July 2025; Manaaṭeq Net Operationalize Reconstruction Fund & Board CoM + MoF + Parliament Q3 2025 Public Works Studio July 2025; Manaaṭeq Net Hold International Reconstruction Donor Conference Prime Minister’s Office   PM Speech, June 2025 Approve legal framework for compensation and service fee exemptions Parliament   PM Speech, 10 June 2025; Al Modon, June 2025 Establish legal basis and governance framework for Reconstruction Fund Council of Ministers + Parliament - Ministerial Statement, 25 Feb 2025 Amend Decision 4/12/2024 to create oversight body Council of Ministers - Youth4Governance Policy Brief, Feb 2025 Issue decree making MoE guidelines binding MoE + Council of Ministers - MoE Presentation, Feb 2025 Launch CDW database & public dashboard MoE + Municipalities - MoE Presentation, Feb 2025 Legal amendment to link Law 444/2002 to CDW violations Parliament - Youth4Governance Policy Brief, Feb 2025 Finalize National Rubble Management Policy Prime Minister’s Office - Youth4Governance Policy Brief, Feb 2025 Public Disclosure of Reconstruction Contracts Court of Audit - News Report Launch of Environmental Impact Assessments (EIA) Ministry of Environment - Public Works Studio Report, May 2025   Implementation Bottlenecks & Required Actions Bottleneck Official Explanation Required Immediate Action Source Incomplete damage valuation framework No standardized law or formula exists to determine compensation; surveys exist, but payout mechanisms stalled Finalize law, issue implementing decrees, publish regional damage cost tables Al Modon, June 2025 Government reconstruction efforts trail CSO initiatives CSOs have outpaced the government in rebuilding homes; state risks losing credibility and coordination Launch national housing plan with timeline and funding strategy PM Speech; Al Modon, June 2025 No EIA-linked enforcement of contractor actions Contractors avoid UXO detection, environmental separation due to lax oversight Mandate environmental audits, enforce via MoE, LAF, UNDP joint protocols UN Debris Taskforce Statement (May 2025); Council of the South, "An-Nahar", 20 April 2025 No designated treatment sites in some areas Temporary dumping sites approved; final environmental screening pending Finalize vetting of sites (e.g. Cana, Naqoura); enforce site-specific disposal protocols UN Debris Taskforce Statement (May 2025) Rubble with iron prioritized by contractors Contractors cherry-pick recyclable debris, leaving hazardous rubble untreated Supervise rubble sorting at source; enforce equal removal of all CDW categories UN Debris Taskforce Statement (May 2025); Council of the South, "An-Nahar", 20 April 2025 No dedicated reconstruction fund Fund is politically committed but not yet established; legal and fiscal framework needed. Issue decree to establish fund and governance board; pass enabling legislation in Parliament Ministerial Statement, 25 Feb 2025 No Enforcement of MoE Guidelines MoE issued a circular on December 4, 2024, but it lacks legal force. The guidelines are not binding and not incorporated in current contracts. MoE lacks enforcement power or legal mandate to penalize non-compliance. Link to Law 444/2002, make it enforceable Youth4Governance Policy Brief, Feb 2025 Lack of Centralized Coordination/Dispersed Mandates among Actors No central authority exists. The Council of Ministers delegated responsibilities to several entities (MoE, MoIM, HRC, municipalities) without a unifying strategy, leading to fragmented execution. Establish a centralized authority or task force to oversee and coordinate all rubble removal and reconstruction activities, ensuring adherence to national standards and efficient resource utilization. Youth4Governance Policy Brief, Feb 2025 Contractors dictate disposal by convenience/Absence of contractor compliance audits. Contractors decide disposal routes post-contract due to lack of monitoring or compliance audits. Procurement mechanisms do not embed MoE guidelines or environmental safeguards effectively. No monitoring of environmental safeguards in awarded contracts. Embed MoE standards in tenders and monitor execution. Empower oversight bodies to audit tender execution, enforce sanctions. Youth4Governance Policy Brief, Feb 2025; LCPS-TI Reform Monitor Stakeholders & Roles Entity Core Function Primary Contact Point Ministry of Environment Policy, guidelines, EIA, environmental monitoring Environment Directorate Ministry of Public Works Infrastructure rehabilitation, permitting CDW Technical Committee Council of Ministers Coordination, policy setting, regulatory reform Secretary General Higher Relief Council Emergency rubble response, fund allocation President of the HRC South Lebanon Council Local rubble clearance and contractor coordination   Southern Suburb Union of Municipalities Manages disposal sites independently of MoE   Municipalities Local implementation and oversight Union of Municipalities Environment Police Intended oversight role; lacks mandate and resources   Lebanese Armed Forces UXO removal, debris site security Army Engineering Command UN Debris Taskforce Inter-agency coordination on CDW; standards, EIA, rights-based recovery UN Resident Coordinator Donors (EU, WB, UNDP) Technical, financial support Lebanon Recovery Platform Legal & Policy Framework Instrument Status Key Provisions Implementation Note Circular No. 6/1 (MoE, 2024) In force (non-binding) Provides environmental guidelines for rubble handling, including mandatory use of quarries, hazardous material separation, and reuse of debris Requires legal decree or regulatory amendment to be binding Law No. 444/2002 (Environment) In force Establishes environmental protection and penalties for pollution Needs linkage to CDW violations Law No. 80/2018 (Solid Waste) Partially operational Calls for integrated solid waste management and authority CoM decree approved in Jan 2024 MoE Circular on CDW (Dec 2024) Advisory only Guidelines on disposal, quarry use, hazard handling Requires decree to be binding Decision 4/12/2024 In effect Delegates removal mandates, lacks coordination or enforcement tools Needs amendment for centralized authority Decree No. 5605/2019 In force Governs hazardous waste separation and disposal Referenced in MoE’s CDW guidelines Decree No. 5606/2019 In force Enforces sorting of waste at the source Needed to operationalize rubble sorting procedures Law No. 64/1988 In force Regulates hazardous and toxic waste Applicable to asbestos, UXO, and chemical debris   Official Sources and Reference Materials Instrument Source Ministerial Statement (25 Feb 2025) Ministerial Statement, 25 Feb 2025 CDW Policy Brief (AUB Nature Center, Nov. 2024) CDW Policy Brief (AUB Nature Center, Nov. 2024) MoE Presentation on Debris Management (Feb. 2025) MoE Presentation, Feb 2025 Youth4Governance Policy Brief (Feb 2025) Youth4Governance Policy Brief, Feb 2025 3RF Recovery Framework for Beirut and Lebanon (2023–2024) 3RF Recovery Framework for Beirut and Lebanon (2023–2024)     List of Acronyms – Rubble Removal and Reconstruction Reform Tracker Acronym Full Form CDW Construction and Demolition Waste CDR Council for Development and Reconstruction CoM Council of Ministers EIA Environmental Impact Assessment EU European Union HRC Higher Relief Council LAF Lebanese Armed Forces LCPS Lebanese Center for Policy Studies MoE Ministry of Environment MoF Ministry of Finance MoIM Ministry of Interior and Municipalities MoPWT Ministry of Public Works and Transport MoPH Ministry of Public Health NGO Non-Governmental Organization PCM Presidency of the Council of Ministers PMO Prime Minister’s Office SOGIESC Sexual Orientation, Gender Identity and Expression, and Sex Characteristics (Used in other trackers – anticipate use) UN United Nations UNDP United Nations Development Programme UXO Unexploded Ordnance WB World Bank 3RF Reform, Recovery and Reconstruction Framework   [1] All reform data presented here is based on official Lebanese government sources, such as laws, decrees, strategies, and verified public data. Where possible, each update is linked to a document, gazette entry, or institutional publication. read more

Social Protection Reform Tracker

Social Protection Reform Tracker[1] Reform Area: Universal, rights‑based & shock‑responsive Social Protection System Last Updated: November 2025 Citizen Impact Summary Dimension Snapshot Source Who Is Affected? All Lebanese citizens across the lifecycle; highest gains for ≈ 2 million people now under, or near, the monetary poverty line, esp. children, older persons, persons with disabilities (PwDs), informal‑economy workers, and female‑headed households. National Social Protection Strategy (NSPS) 2023 executive summary; World Bank Poverty and Equity Assessment 2024 Financial Burden? Extreme poor households spend ~80% on food, rent, health; pensions eroded by currency collapse; high out-of-pocket health costs; informal workers lack social protection. ESSN Project Reports; UN Lebanon Position Paper; IMF Conditionality Evidence Summary Public Services? Health, education, and social services severely degraded; NSSF coverage reaches ~50% of formal workers; DAEM registry improves targeting but major gaps remain. National Social Protection Strategy; ESSN–AMAN Updates; UN System Reports Mental‑Health Toll? High stress among families, especially women and older persons; exclusion worsens social isolation; caregivers under strain; children’s well-being under threat. National Strategy for Older Persons 2020–2030; Overview & Objectives Goal Transition from fragmented, donor-driven safety nets to a universal, rights-based, shock-responsive, and fiscally sustainable social protection system that guarantees dignity, inclusion, and resilience across the life cycle. Strategic Importance Central to rebuilding the social contract, reducing multidimensional poverty and inequality, supporting informal workers, and stabilizing vulnerable communities in the context of protracted crises. Key Reform Priorities (2024‑26) 1- Enact the Social Protection Framework Law (2024/302) and implement Pension Reform Law (319/2023) through decrees, institutional restructuring, and fiscal integration. 2- Introduce and scale up universal non-contributory social pensions for persons aged 65+ and disability allowances in line with CRPD. 3- Integrate NPTP, ESSN, and other transfers under a unified National Safety Net using the DAEM-SPIS platform and lifecycle-based targeting. 4- Reform NSSF pension and health schemes to expand voluntary enrollment, especially for informal workers, and ensure sustainability. 5- Approve a domestic financing roadmap (0.7% of GDP) for long-term sustainability, reducing dependency on external grants and humanitarian pipelines. 6- Enhance governance through SPCU coordination, DAEM 2.0 rollout, and enforcement of data governance and third-party monitoring protocols. Reform Actions & StatusSpecific Reform Actions & Accountability Reform Action Required Current Status (May 2025) Lead Authority Implementing Body Oversight / Supporting Actors Primary Source Institutional reform: Rename the Ministry of Social Affairs to Ministry of Social Development The Parliamentary Committee on Health, Labour, and Social Affairs approved the government’s proposal to change the Ministry’s name to the Ministry of Social Development. Minister Haneen El-Sayed described this as a strategic shift from welfare provision to economic and social empowerment, aligning with the ministry’s new social development strategy launched in October 2025. The bill now awaits discussion in the Parliament’s general assembly. Council of Ministers / MoSA MoSA Parliament Committee on Health, Labour, and Social Affairs Social Affairs, 24 Sept 2025 Finalize scope of Unified Social Registry Terms of Reference approved; State Council resolved data privacy concerns; decree pending Council of Ministers vote PCM MOSA + PCM Technical Unit EU Delegation, UNICEF, ILO National Social Protection Policy Paper ARI, Oct 2024 Draft NSPS Action Plan Action plan not yet finalized; no formal circulation or costing validation publicly confirmed Inter-ministerial SP Committee MOSA World Bank, UNDP “Commitment to Develop a Resilient Social Protection System” 2025 Activate Pension Law 319/2023 Law approved; executive decrees under preparation; fiscal impact study pending cabinet review Council of Ministers Ministry of Labour / NSSF ILO, IMF, Parliament National Social Protection Policy Paper ARI, Oct 2024 Secure Domestic Financing Plan Ministry of Finance–PCM working group completed 0.7% GDP financing proposal; awaiting Cabinet endorsement Council of Ministers Ministry of Finance World Bank, IMF National Social Protection Policy Paper ARI, Oct 2024 Initiate scale-up of Disability Allowance Pilot launched in 2023; scale-up roadmap under technical finalization MoSA MoSA + SPCU UNICEF, ILO “Commitment to Develop a Resilient Social Protection System” 2025 Transition from End-of-Service Indemnity to Contributory Pension Scheme (Law 319/2023) Law adopted; executive decrees pending; actuarial and fiscal transition scenarios under review Parliament / Council of Ministers Ministry of Labour + NSSF ILO, IMF, WB An-Nahar, May 2025 Establish Unified Social Health Protection Scheme Fragmented schemes mapped; roadmap to consolidate under a unified scheme under technical design MoPH + Council of Ministers NSSF + CSC + Army Health WHO, ILO, UNICEF An-Nahar, May 2025 Modernize and Digitize Social Development Centers (SDCs) ISOSEP project rehabilitated 30+ centers; expansion and digital services integration ongoing MoSA MoSA + AICS + EU EU, Italian Cooperation An-Nahar, May 2025 Strengthen coordination via reactivation of Social Affairs Committee Committee inactive; reform proposal under review within MoSA PCM MoSA + MoPH + MoL + MEHE UNDP, ESCWA, EU Delegation An-Nahar, May 2025 Expand AMAN Emergency Cash Program Coverage expanded to 800,000 individuals; additional funding secured PCM + MoSA MoSA + SPCU WB, UN agencies PM Speech, June 2025 Launch 4-year multisector recovery plan (South) Multi-sector strategy co-designed with UN agencies; includes social protection pillar PCM MoSA + UNCT UNRCO, UNDP, UNICEF PM Speech, June 2025 Inclusive Emergency Preparedness for PwDs MoSA announced adoption of Lebanon’s first Inclusive Emergency Plan, integrating PwDs in all phases (preparedness, response, recovery); recommends establishing a permanent MoSA Emergency Cell, updating the disability registry with disaggregated data, ensuring accessible shelters, evacuation protocols, and communications, training MoSA/municipal staff, and allocating dedicated disability budget lines – a critical step to embed inclusion in the national social protection and crisis response system MoSA MoSA + Municipalities Arcenciel, Transparency Int’l – Lebanon, OPDs, UN agencies, EU Delegation Lebanese National News Agency, 17 Sep 2025  Reform Roadmap Timeline & Critical PathRecent Milestone Date Description Critical Path Status Source 10 Nov 2025 Parliamentary Health and Social Affairs Committee approves draft law renaming the Ministry of Social Affairs to the Ministry of Social Development, signaling a policy shift toward integrated empowerment and development-based programming. Institutional milestone – awaiting Parliament vote Lebanon 24, 10 Nov 2025 July 9, 2025 Social Protection Expenditure Review 2017‑2024 launched, highlighting fiscal gaps and sustainability roadmap. Strategic milestone MoF & Basile Fleihan Institute 2025 10 June 2025 PM announces expanded AMAN coverage and outlines Lebanon’s 3.0 vision including integrated social justice and protection Strategic vision milestone PM Speech, June 2025 12 May 2025 Pension Law 319/2023 fiscal impact study submitted to CoM Awaiting cabinet scheduling National Social Protection Policy Paper ARI, Oct 2024 20 Apr 2022 Government adopts National Social Protection Strategy (NSPS) with five foundational pillars Completed on‑time National Social Protection Strategy (NSPS) 2023 executive summary 05 Jan 2025 DAEM Social Registry v2 launches with expanded modules and data linkages Completed National Social Protection Policy Paper ARI, Oct 2024 15 December 2023 Parliament passes Pension Law as part of elderly care reform Completed UN, 2023 17 Sep 2025 National Conference launches Lebanon’s first Inclusive Emergency Plan for PwDs; MoSA commits to adopt plan, establish Emergency Cell, update disability registry, and integrate inclusive measures into national SP/DRM systems Policy milestone – sets direction for inclusive preparedness; requires MoSA decision instruments, TORs, and budget allocations Lebanese National News Agency, 17 Sep 2025  Next Steps – Transparency and Accountability Calendar Action Responsible Entity Target Date MoSA decision to adopt and operationalize Inclusive Emergency Plan for PwDs (incl. Emergency Cell, registry update, accessible shelters, training, budget lines) MoSA + Municipalities + OPDs TBC Cabinet approval of Unified Social Registry decree & data governance protocol PCM + MoSA Pending Cabinet approval of Domestic Financing Plan (0.7% GDP) MoF + CoM Awaiting endorsement Finalize and launch 4-year South Recovery Plan including Social Protection pillar PCM + UN Agencies + MoSA N/A Publish NSPS Annual Implementation Report 2024 SPCU N/A Develop NSPS into an integrated Social Development Plan with decentralization lens MoSA + Council of Ministers N/A Restructure and activate the Inter-ministerial Social Affairs Committee CoM, MoSA, MoPH, MoL, MEHE Pending reform proposal Design national job activation and decent work programs MoL + CDR + Donor Partners   Parliament vote on Health Coverage Law for retirees and toward universal retirement-age health Parliament Health Committee + Parliament General Assembly Stalled Reform institutional governance of social protection institutions CoM + Parliament + NSSF Board   Ensure equitable integration of fragmented health coverage systems MoPH + NSSF + CSC + Army Health Directorate   Approve domestic financing plan for NSPS Council of Ministers + Ministry of Finance N/A Scale-up of Disability Allowance with OPD consultation MoSA + SPCU + UNICEF/ILO Technical prep underway Finalize governance protocol for Social Protection Information System (SPIS) PCM + MoSA N/A  Implementation Bottlenecks & Required Actions Bottleneck Official Explanation Required Action Source Fiscal space constraints High debt burden; limited domestic revenue Adopt domestic reallocation plan (0.7% GDP) and explore earmarked funding under NSPS financing plan National Social Protection Policy Paper ARI, Oct 2024 Political turnover risk Cabinet reshuffles delaying law approvals Build inter-party consensus and fast-track key parliamentary votes National Social Protection Policy Paper ARI, Oct 2024 Data-sharing and privacy gaps Ministries hesitant to share sensitive databases Finalize and issue data governance protocols under Unified Social Registry decree National Social Protection Strategy (NSPS) 2023 executive summary Fragmented governance Multiplicity of actors with weak inter-agency links Consolidate coordination under SPCU; clarify mandates through legal frameworks “Commitment to Develop a Resilient Social Protection System” 2025 Humanitarian-to-national transition gaps Parallel humanitarian pipelines bypass national systems Integrate humanitarian caseloads via DAEM-SPIS interoperability, with donor alignment enforced National Social Protection Policy Paper ARI, Oct 2024 Public trust / corruption perception Low confidence in cash transfer transparency Expand third-party monitoring and grievance mechanisms under NSPS framework National Social Protection Strategy (NSPS) 2023 executive summary; CAMEALEON & ARI, Oct 2024   Stakeholders & Roles Entity Core Function Contact Ministry of Social Affairs (MoSA) Sector lead; oversees NSPS, ESSN, NDA; hosts and chairs the SPCU info@socialaffairs.gov.lb Ministry of Finance (MoF) Leads NSPS financing and fiscal risk assessments; co-chairs financing working group with PCM infocenter@finance.gov.lb National Social Security Fund (NSSF) Administers contributory pensions and health coverage; implementing Pension Reform Law 319/2023 info@cnss.gov.lb Central Inspection Office / IMPACT Manages DAEM Social Registry platform, MIS integration, data quality assurance, and inter-agency access protocols info@cib.gov.lb SPCU (Social Protection Coordination Unit, within MoSA) Coordinates NSPS implementation, monitors results, prepares reports, and liaises with donors and technical partners   Committee on Public Health, Labor, and Social Affairs Oversees legislative review of social protection laws, including the Framework Law and Pension Law amendments   ILO & UNICEF Provide technical support for pension design, disability allowance, child grant, data protection, and costing beirut@unicef.org; beirut@ilo.org EU Delegation to Lebanon Provides financial and technical support for registry development, legal reform, and governance mechanisms   World Bank ESSN PMU Manages financing, fiduciary controls, and TA for ESSN program; coordinates with DAEM and SPCU     Legal & Policy Framework Instrument Status Key Provisions Implementation Note National Social Protection Strategy (NSPS, Cabinet Decision 69/2022) In force (since 2023) Establishes a national framework with 5 pillars, including lifecycle protection, social insurance, social assistance, employment links, and governance; sets roadmap 2023–2030; creates SPCU Guides actions across all line ministries; implementation coordinated by SPCU under PCM Universal Social Pension (proposed under NSPS) Policy proposal (under NSPS) Plans to introduce a universal, non-contributory social pension for persons aged 65+ to ensure minimum income security; benefit level to be indexed; design aligned with lifecycle protection pillar Requires legal drafting, Cabinet and parliamentary approval, and secured fiscal space; no draft decree yet prepared Disability Allowance Decree Pilot operational since 2023; scaling planned 2025 Provides flat cash transfer plus disability service card; aligned with CRPD obligations and designed for phased scale-up Scaling plan under technical preparation with UNICEF and ILO support Child Grant Regulation Pilot operational (2024) Designed to be poverty-neutral and integrated under NSPS targeting framework Evaluation scheduled December 2025 to assess performance and inform broader rollout NSSF Law Amendments (2024) Enacted Expands NSSF to allow voluntary enrollment for informal sector workers; strengthens contributory social insurance coverage Actuarial caps established; full implementation pending issuance of detailed board decrees and administrative measures Pension Law 319/2023 Adopted (Dec 2023); awaiting decrees Replaces end-of-service indemnity with contributory retirement scheme; mandatory for new workers & <49 y/o; phased transition model Executive decrees under drafting; fiscal impact study submitted to Council of Ministers May 2025 Health Coverage Law (Parliament Committee Draft) Under discussion in Health Committee; stalled Extends NSSF health coverage to retirees over 64; aims for universal retirement-age health protection Referred to Parliament plenary; no vote scheduled as of May 2025   Official Sources and Reference Materials   Instrument Source National Social Protection Strategy 2023 National Social Protection Strategy (NSPS) 2023 executive summary WB Poverty & Equity Assessment 2024 World Bank, “Lebanon Poverty and Equity Assessment 2024 – Weathering a Protracted Crisis” ILO “Extending Social Health Protection” 2024 ILO, “Extending Social Health Protection to Informal Economy Workers in Lebanon,” 2024 ESSN Stakeholder Engagement Plan 2023 World Bank / ESSN Project Management Unit, “ESSN Stakeholder Engagement Plan,” 2023 UN/ILO/UNICEF Position Paper 2020 UN, ILO, UNICEF, “Joint Position Paper on Social Protection Floors in Lebanon,” 2020 HelpAge / ILO Brief on Older Persons 2022 HelpAge International and ILO, “A Glimmer of Hope amidst the Pain,” 2022     List of Acronyms – Social Protection Reform Tracker   Acronym Full Term ARI Arab Reform Initiative CAS Central Administration of Statistics CoM Council of Ministers CRPD Convention on the Rights of Persons with Disabilities DAEM Social Registry Platform ESSN Emergency Social Safety Net EU European Union GDP Gross Domestic Product ILO International Labour Organization IMF International Monetary Fund IMPACT Inter-Ministerial and Municipal Platform for Assessment, Coordination and Tracking MIS Management Information System MoF Ministry of Finance MoL Ministry of Labour MoSA Ministry of Social Affairs NASS National Strategy for the Advancement of Older Persons (assumed from context) NDA National Disability Allowance NPTP National Poverty Targeting Programme NSSF National Social Security Fund NSPS National Social Protection Strategy OPDs Organizations of Persons with Disabilities PCM Presidency of the Council of Ministers PMU Project Management Unit PwDs Persons with Disabilities SP Social Protection SPCU Social Protection Coordination Unit SPIS Social Protection Information System TA Technical Assistance TOR Terms of Reference UN United Nations UNDP United Nations Development Programme UNICEF United Nations Children’s Fund WB World Bank   [1] All reform data presented here is based on official Lebanese government sources, such as laws, decrees, strategies, and verified public data. Where possible, each update is linked to a document, gazette entry, or institutional publication. read more