Are NGOs Illegitimate Regulators? The Case of the Fair Finance Guide and the Role of Deliberation

Abstract

In this thesis I will argue that the Fair Finance Guide deals with a legitimacy problem because the procedures that generate the standards they set lack the necessary deliberation. I will show that although their activities are crucial in raising the environmental and social standards of financial institutions, these institutions justly accuse the FFG of lacking legitimacy and that their criticism should be taken more seriously in order to prevent the FFG from developing a one-sided, dogmatic and limited framework of regulation. I will suggest that the concept of deliberative democracy offers insights on how to deal with their legitimacy deficit and will offer proposals on how they might improve their practices.