Despite NGO recommendations, after approval by the Board, several weaknesses remained in the policy. The policy failed to:
- Include provisions that give affected communities the opportunity to influence project or program design through their participation.
- Give priority to the Bank's activities for enforcement and implementation of the policy (in the policy the main responsibility for the implementation of environmental considerations falls on the ADB borrowing countries)
- State that borrowing governments will be required to comply with the Environment Policy in loan agreements.
- Strive toward applying the same environmental standards and requirements for all of its operations. The language regarding program lending, sector lending, private sector operations, and lending to financial intermediaries is vague and unclear about how the policy will apply to these areas of the Bank's operations.