BankTrack set out to measure the implementation of the UNGPs by the banking sector in a report, “Banking with Principles?”, published in December 2014. The report was motivated by a perception that, some three and a half years after the Principles’ adoption, banks had spent much time discussing amongst themselves how to implement the UNGPs, but not nearly as much time on actually implementing them...we developed criteria which were explicitly based on the text of the UNGPs, to ensure that banks would accept them as credible and objective. We derived 12 criteria across four categories: policy commitment, due diligence commitment, reporting and access to remedy...The results showed that almost all of the 32 banks covered in the report were, as we had suspected, at an early stage in implementing the Guiding Principles. The average score was just 3 out of 12...Reporting and access to remedy were particularly major gaps...[E]valuating whether such improved policies and processes have an impact on the ground – in terms of the projects and companies backed by bank finance – is an ongoing challenge.  We can shed some light on this question by looking in more detail, and comparatively, at bank responses to specific alleged human rights impacts. Yet, efforts to measure which banks are most likely to become linked to human rights abuses by their finance, and to evaluate their responses, are hamstrung by the limited transparency from banks on what projects and companies they finance.