Revising the IMF Fiscal Transparency Code

Transcription

1 Revising the IMF Fiscal Transparency Code Civil Society Comments and Recommendations I. Significance and Process of Public Consultation Why is the IMF Fiscal Transparency Code Important? Governments and civil society organizations have long encouraged the IMF to promote more inclusive and transparent fiscal policy processes. International norms on fiscal transparency have been shaped largely by the IMF s Fiscal Transparency Code (FTC). IMF member governments use the FTC to guide their fiscal policy processes and their reports to national legislatures, the public and international institutions. Additionally, a new function of the FTC will be to guide the IMF s new Fiscal Transparency Assessments (FTAs), which will rate countries according to criteria within the FTC. For these reasons, the FTC is an important policy tool. However, the FTC has not been revised since the financial crisis and the IMF s own review of fiscal transparency identified major gaps in governments reporting of their fiscal positions and the risks to those positions, even in advanced economies. In light of these weaknesses, the IMF is revising its Fiscal Transparency Code for the first time since To enhance the legitimacy and effectiveness of the revision process, the IMF is undertaking a broad consultation, including the engagement of civil society organizations, especially from developing countries. New Rules for Global Finance (New Rules) coordinated, facilitated and encouraged feedback from civil society during this consultation and successfully advocated for a longer consultation period to maximize opportunity for feedback. At the end of the consultation, New Rules presented the comments and recommendations from civil society to the IMF Fiscal Affairs Department. New Rules engaged civil society through various forums and streams of communication. Feedback was organized into 3 sections: General Comments, Responses to New Rules Questionnaire, and Specific Comments in FTC Text. See section II of this report. Next Steps: This consultation focused on revising the 3 Pillars in the IMF s FTC (see description of FTC below). The IMF plans to integrate a 4 th Pillar on Resource Revenue Transparency. The IMF s current Guide on Resource Revenue Transparency, which has not been revised since 2007, will likely serve as the foundation for the FTC s 4 th Pillar. To the best of our knowledge, the IMF plans to hold a public consultation on Resource Revenue Transparency at the end of

2 What is the IMF Fiscal Transparency Code? The IMF Fiscal Transparency Code created in 1998 and revised in 2007 defines the basic principles for fiscal transparency regarding comprehensiveness, clarity, reliability, timeliness, and relevance of public reporting on the past, present, and future state of public finances. The IMF Code also provides the framework for evaluating country compliance with these principles. The IMF Fiscal Transparency Code Draft Paper was divided into 4 sections: A. Principles: The Principles outline the elements that the IMF believes are necessary for good fiscal policy. There are 45 principles organized into 3 Pillars (pages 1-4) 1. Fiscal Reporting 14 Principles 2. Fiscal Forecasting and Budgeting 16 principles 3. Fiscal Risk Analysis and Management 15 Principles B. Rating: Framework for rating adherence with fiscal transparency principles (pages 5-14) 1. Country adherence to each principle is rated as BASIC, GOOD or ADVANCED C. Indicators (pages 15-16) 1. Explains how country adherence is measured D. Glossary of terms in Fiscal Transparency Code (page 17-19) II. Civil Society Comments & Recommendations 1. General Comments These are comments and recommendations that were not specific to a particular text or paragraph within the FTC. In general, feedback was largely supportive of the efforts and appreciative of the opportunity to participate. Online is preferable to print, especially in a specialized journal or government publication. The transparency code should include the media used, and its quality, its ability to convey information to a broad audience. Information must be published, and accessible, and available to all citizens; Frequency is essential and should be a core criterion of practice level. Need to publish everything in machine readable format for maximum ease and access, and have fiscal available as bulk download. Raw data is preferable to aggregated data. The IMF should secure relevant licenses. The requirement for a break down by impact groups (gender, vulnerable, demographic, regional) in the Citizens Budget is a very big plus We hope the focus on the quality of reported information, and the greater specificity of the graduated reporting will facilitate more systematic utilization of the Code, including more direct integration in the activities of the IMF and key partners. 2

3 Need for greater clarity in the formulation of the indicators, their use, and their interaction with the graduated approach in practice: Is the aim to have a binary yes/no or actual measurement for each indicator? Preference is for specific and graduated approach of the latter, provided they are based on IMF reports reference the measurement as well as in the original country publication. The Code should include Section V: a Table with listing all the reports in the text, with a brief description of the information to be included and the dates for publication. The Draft Code gives too little attention to strong legislative oversight and the need for public engagement in fiscal affairs. See High Level Principles issued by the Global Initiative for Fiscal Transparency (GIFT) See Principles 7, 8, and 10 of GIFT s High Level Principles: The Code should have a Preamble, such as: There is consensus that good governance is of central importance to achieving and sustaining macroeconomic stability and high-quality growth; and that sound fiscal management including fiscal transparency, robust and independent oversight institutions, and public engagement in fiscal affairs are key aspects of good governance. Fiscal openness allows for informed debate by both policy makers and the public about the design and results of fiscal policy, and establishes accountability for its implementation. In strengthening credibility and public understanding of macroeconomic policies and choices, fiscal openness fosters more favorable access to domestic and international capital markets. It also helps to highlight potential risks to the fiscal outlook, resulting in an earlier and smoother fiscal policy response to changing economic conditions and thereby reducing the incidence and severity of crises. 2. Civil Society Feedback on Questionnaire To stimulate participation, New Rules developed a questionnaire based on issues within the IMF FTC and early discussions with leading civil society organizations in the fiscal transparency arena. Question 1: Should the IMF Fiscal Transparency Code encourage public engagement in budget (income and spending) decisions? The respondents agreed all on an encouragement of public engagement in budget decisions, as decision makers utilize tax revenues to finance budget expenses. Besides, the survey highlighted that through such encouragement, the level of accountability of the budget legislators would increase and thus a decrease in corruption could be expected. Moreover, citizens could be able to influence the utilization of the budget and hence assure that the budget expenses meet the public priorities, especially in developing countries with poor governance such development could increase trust as well. Furthermore, one respondent argued that public participation without appropriate transparency has no result. In general the budget proposal should be presented at a sufficiently early stage for meaningful consultation to take place, with an informative Citizens Guide to the Budget which breaks down the proposed budget. However, criticism arose that the loss of prestige of the IMF could obstruct this process. One participant 3

4 advocated that such encouragement would not be productive but rather makes the IMF Fiscal Transparency Code less cohesive and less complementary. Question 2: The IMF Code stipulates that governments should make available a Citizens Guide to the Budget. This is defined as a clear, accessible, and useful summary of fiscal performance and economic prospects as well as the distributional implications of the fiscal policies. Is this sufficient? The majority of respondents deemed the definition as clear and helpful to inform citizens about government measures and their impact. In addition citizens would have the opportunity to monitor the effects of fiscal redistribution policies and it would strengthen the awareness of democratic deficits and lack of strong governance. However, few respondents mentioned that the question will be to what degree such a guide can be realized, especially regarding high illiteracy rates in less developed countries. Furthermore, the question arose whether this Citizens Guide to the Budget is prepared at the level of the consultation, which would be preferable, or only after the budget is approved as it is often conducted. The Guide should serve as a consultative document, which is then updated when the final budget is approved. Four answers did not agree with the definition as they thought that it falls short of citizen needs and the IMF does not obey itself to this definition. Furthermore, critics claimed that the guide should further breakdown key expenditures and revenue indicators such as social expenditures and revenues derived from extractive industries like mining. The risk they observed is that the definition is too general and thus will be useless for adaption. Question 3: Which fiscal documents or reports should include a Citizens Guide summary? The answers to this question are quite diverse in respect to the amount of fiscal document which should be included in a Citizen s Guide. A general perspective is that such guide should include the budget allocated to every ministry and what the funds are intended for during the fiscal year. Furthermore, various respondents called for a complete list of all IMF loans and programs including their conditions and terms and all governmental financial records. Such records would include preliminary budget draft, civil budget in common understandable terms, the approved budget, intermediary reports, half year budget, the full annual report, and the audited review. Such overview would be quite extensive, thus other participants proposed just to implement the main fiscal budget for the forthcoming fiscal year. In addition the Citizen s Guide should include Fiscal Forecasting and Budgeting, detailing Macroeconomic Forecasts, Medium-term Budget Framework and Fiscal Strategy Report. Oxfam proposed to include tax revenue by type of revenue, break-down of non-tax revenue, natural resource revenues, and tax expenditures, tax gap on the revenue side. On the expenditure side, budget by geographic area, special funds, and sector should be mentioned, as well as fiscal forecasting and major risks 4

5 Question 4: The Citizens Guide includes distributional implications of fiscal policies. What type of impacts (social, financial, etc.) should be included? The majority of participants favored the inclusion of social, economic, and financial impacts in relation to income levels of the population. Furthermore, the focus should not merely be on the central government but on the subnational level in countries because the increasing importance of subnational debt and the role of states as end-service provider. Moreover, an assessment should be conducted of the level of participation and influence of citizens in design of tax policies, although some policies of the IMF minimize such rights. Respondents valued equality among gender, sustainability and environment as important. Ecuador was named as a good example as it introduced an integral auditing commission to study external and internal public debt to determinate illicit parts of debt and detailed impact on social well-being. As a last addition, one participant called for a focus on the progress in attainment of MDG targets, the social expenditures as percentage of total expenditures and inflation adjusted social expenditures. Moreover one respondent would include demographic, employment, and health impacts as well. In addition, the Guide should include gender, income inequality, food security, and climate change impact on the budget. Question 5: In regards to question 4, who should be involved in calculating these impacts? 1. Government Agencies 30 % 2. Private Sector 10 % 3. Think Tanks 5 % 4. Civil Society Organizations 15 % 5. International Organizations 25 % 6. Academia (Universities) 15 % Other answers which were given, included: Independent experts/professional and practitioners including CSOs that have track records in distributional impact analysis The IMF should strengthen the legislature Sector and Industry specialists from related ministries / state agencies CSO s, women s group, minorities Social Workers, representatives of underprivileged groups Religious Groups, Economists, Media Ministry of Finance / Tax Authority should present draft assessment, which is then verified by relevant stakeholders in each sub-group Question 6: Should the IMF Code specify the items that each type of fiscal report should include? The majority of participants favoured to specify the items that each type of fiscal report should include. It should eliminate the possibility of giving government an opportunity to choose what to publish and should remain understandable for the public as well. The focus should be transparency and detail orientation with the aim to increase accountability of state agencies. It 5

6 could be also sufficient to just focus at an outline including a general heading as guidance. Nevertheless, one respondent warned of the danger of being too specific and suggested to just include the Citizens Guide. The Code should establish common recommended methods so that fiscal reports are comparable across countries. However, there will be specific countrybased needs as well. Question 7: The IMF Code calls for the disclosure of fiscal reports and documents, but does not specify how often some reports should be disclosed. How often should the following be disclosed? Long-term fiscal sustainability reports: a) Two times a year 8 % b) Annually 50 % c) Every two years 33 % d) Every 5 years e) Other 8 % (every three years) Reports on Specific fiscal risks: a) Two times a year 41 % b) Annually 7 % c) Every two years d) Every 5 years e) Other Risks relating to major assets and liabilities: a) Two times a year 33 % b) Annually 67 % c) Every two years d) Every 5 years e) Other Reports on Environmental Risks: a) Two times a year 41 % b) Annually 50 % c) Every two years 8 % d) Every 5 years e) Other 6

7 Question 8: Should the IMF Code stipulate legislative oversight of government income? No 25 % Yes 75 % The overall response is that the legislature should have an oversight of the government income. Only 3 respondents did not agree with this. The strong support for legislative oversight may indicate a lack of trust in the current government or its budget policies and processes. Key comments/suggestions: Should be standard for each country Depends on political system; e.g. in parliamentary republics the law dictates all government records be under the legislative oversight, which strengthen fiscal transparency Oversight of government income should include tax revenue Question 9: Should the IMF Code stipulate legislative oversight of government spending? No 25 % Yes 75 % 3. Specific Comments in FTC Text The comments below are in blue and located under the respective line or section within the structure of the Fiscal Transparency Code. A. FISCAL TRANSPARENCY PRINCIPLES I. FISCAL REPORTING: Fiscal reports should provide a comprehensive, relevant, timely, and reliable overview of the government s financial position and performance 1.1. Coverage: Fiscal reports should provide a comprehensive overview of the fiscal activities of the public sector, according to international standards Structure of the Public Sector: The structure and functions of the public sector and its relationship with the private sector are clearly defined. TI: The Basic Level must always include publication of any report for a fiscal transparency effort, including the publishing of the registers of all public sector entities. Add the role of each entity and its relations with the other entities and the public 7

8 Coverage of Institutions: Fiscal reports cover all entities engaged in public activity according to international standards. all entities should include private institutions where substantial public investments have been made by the public sector Coverage of Stocks: Fiscal reports include a balance sheet of public assets, liabilities, and net worth Coverage of Flows: Fiscal reports cover all public revenues, expenditures, and financing Tax Expenditures: The government regularly discloses all revenue loss from tax expenditures. Quarterly finance reports and tax expenditure reports for the sake of symmetrical information Tax expenditures do not fit in this section and instead could be included with the budget documentation (particularly since the Code is asking for tax expenditure information to be reported regularly which it defines in this case to be at least annually. In general, tax expenditure information is important because it shows which policies are being achieve through the tax side. Presumably a goal of the budget process should be to coordinate policies on the tax and spending sides. This means having tax expenditure information available at the time of the budget debate seems more appropriate. Plus tax expenditure information is generally not presented in terms of the actual related revenue loss (they are always estimates), and this pillar is about retrospective fiscal reporting. TI: The minimum for all practices for publishing of tax expenditures should be at least annually; however for Good it should be at least semi-annually; and for Advanced at least quarterly Frequency and Timeliness: Fiscal reports should be published in a frequent, regular and timely manner Frequency of In-Year Fiscal Reports: In-year fiscal reports and statistics are published on a frequent and regular basis Timeliness of Annual Financial Statements: Audited or final annual financial statements are published in a timely manner. Audited or final annual statements are published within: o 9 months Basic o 6 months Good o 4 months Advanced See Comments on below 1.3: Quality: Information in fiscal reports should be relevant, internationally comparable, and internally and historically consistent Classification: Fiscal reports classify information in ways that make clear the use of public resources and facilitates international comparisons. The Code is not balanced, since it places much greater emphasis on expenditures than on taxes or revenue. o The advanced practices should call for the publication of all revenue sources. In addition to basic, good, advanced the financial report should include additional classifications for administrative, economic and functional performance. (see French) Imbalance between reporting of expenditures vs. revenues; recommend greater level of information and coverage be required for revenues. 8

9 Data Consistency: Fiscal reports are internally consistent and include reconciliations between alternative measures of summary fiscal aggregates Historical Consistency: Material revisions to historical fiscal statistics are disclosed and explained Integrity: Fiscal statistics and financial statements should be reliable and subject to external scrutiny Statistical Integrity: Responsibility for verifying fiscal statistics is vested in a specific body that is independent External Audit: Annual financial statements are subject to a published audit by an independent supreme audit institution according to international standards. Why does the Good practice NOT have the Supreme Audit Institution presenting a true and fair view of the state of public finances? Share IBP s view Statistical Dissemination: Fiscal statistics meet internationally accepted systems and standards Reliability of Financial Statements: The annual financial statements meet generally accepted accounting standards and their reliability is validated. Cells in chart are reversed and contradict common sense Financial reports should always satisfy an independent full audit report in the named 3 levels (?). II.FISCAL FORECASTING AND BUDGETING: Budgets and their underlying fiscal forecasts should provide a clear statement of the central government s budgetary objectives and policy intentions and comprehensive, timely, and credible projections of the evolution of the public finances Comprehensiveness: Fiscal forecasts and budgets should provide a comprehensive overview of fiscal prospects. The finances, revenues and expenditures of all levels of government should be made available in a single document to provide a complete and comprehensive picture. In large federal governance structure the subnational governments often account for more than half of the fiscal story Unity: Revenues, expenditures, and financing of central government, both budgetary and extrabudgetary, are authorized by the legislature. All 3 levels (basic, good, advanced) should publish extra-budgetary funds. All levels should include the national pension fund.ti: The Basic Practice does not have to publish its extra-budgetary funds; given the risk extra-budgetary funds pose to public sector integrity, we recommend they be included as part of Basic Practice Gross Budgeting: Revenues and expenditures are presented on a gross basis in budget documentation. The rule for the Gross Budget should apply to basic and good as well as advanced Macroeconomic Forecasts: The budget projections are based on comprehensive macroeconomic forecasts which are disclosed and explained Medium-term Budget Framework: Budget documentation includes outturns and projections of revenues, expenditures, and financing over the medium-term. 9

10 2.2. Timeliness: The government should provide timely updates on fiscal prospects Fiscal Strategy Report: The government provides a mid-year report summarizing macroeconomic and fiscal developments since the last budget, and macroeconomic and fiscal forecasts for the preparation of the upcoming budget. The IMF should include information related to a Pre-Budget statement (fiscal and macroeconomic forecasts needed for budget preparations) which should be in all 3 levels of practice. [Existing language is unclear even for good/advanced about budget preparation materials.] Basic practice has no requirement to include information on fiscal forecasts: the IMF should clarify when this information should be presented Budget Submission: The legislature and the public are consistently given adequate time to scrutinize and approve the annual budget before the start of the financial year. Basic and good must submit the budget at least 3 months before the fiscal year for adequate participation of CSO and research institutions, given the budget s complexity. Basic - 2 months Good 3 months Advanced 3 and a half Budget Approval: The approval and publication of the budget legislation consistently provides adequate time for its effective execution. The rule of the provisional 12 th already has given a solution in case of delay it is necessary to maintain the adoption and publication of the budge before the start of the fiscal year for both the basic and the good. (French) (?? Jmg) Basic - published up to 2 weeks after Good published up to 1 week 2.3. Legal Framework: The fiscal powers of the executive, legislative, and judicial branches of government should be well defined in law, and the opportunity for public engagement should be provided.(ibp) Access to understandable information about taxpayers tax obligations must be required in all three levels, for ithe basis for the consent of the governed for taxation Organic Budget Legislation: The use of public resources should be governed by a comprehensive legal framework Revenue Collection: Laws and regulations related to the collection of tax and non-tax revenues should be comprehensible and accessible The legislature should be provided with the authority, resources, and information required to oversee the use of public resources. Citizens should have effective opportunities to participate in public debate and discussion over the design and implementation of fiscal policies Policy Orientation: Fiscal forecasts and budgets should be presented in a way that facilitates policy analysis and accountability Fiscal Policy Objectives: The government states and reports on clear and measurable objectives for the public finances Performance Information: Budget documentation provides information regarding the objectives and results achieved under each major government policy area. 10

11 Citizens Guide to the Budget: The government makes available to all citizens a clear, accessible, and useful summary of fiscal performance and economic prospects as well as the distributional implications of fiscal policies. Good and Advanced practices call for detailed information about the financial impact of major policies on different income groups. The term financial impact is narrow and should be expanded to include financial and social impact. Definition is not clear. The Citizens Budget should information appropriate to the specific phase of the budget it relates to. Citizens should have clear, accessible and useful summary in the report to facilitate engagement in all stages of the budget process, thereby promoting accountability Fiscal Sustainability Analysis: The government regularly publishes the projected evolution of the public finances over the long-term. What does regularly mean? Basic covering a horizon of at least 5 years Good horizon of at least 10 years Advanced of at least 15 years 2.5. Credibility: Fiscal forecasts and budgets should be credible Independent Evaluation: The government s fiscal forecasts are subject to independent evaluation. Not clear: I understand the objective and the reasoning for it, but when we say independent what exactly does it mean in the light of the Code? Independent from the governments: Could the parliament s Budget Committee be independent, or the Central Bank assumed to be independent evaluator, or SAI or CSO? Independent from the country s policies, independent expertise? Otherwise, well thought and comprehensive Supplementary Budget: Any material changes to the approved budget are authorized by the legislature. Different formulations in the table on amending the budget are not sufficiently comprehensive; they should involve increases and decreases in revenue as well as in the expenditure in relation to the forecast Forecast Reconciliation: Budget documentation and any subsequent updates explain any material changes to the government s previous fiscal forecasts, distinguishing the fiscal impact of new policy measures. III.FISCAL RISK ANALYSIS AND MANAGEMENT: Governments should analyze and manage risks to the public finances and ensure effective coordination of fiscal decision-making across the public sector Risk Disclosure and Analysis: Governments should publish regular reports on risks to their fiscal prospects Macroeconomic Risks: The government reports on how fiscal outcomes might differ from baseline forecasts as a result of different macroeconomic shocks Specific Fiscal Risks: The government regularly reports on the main specific risks to its fiscal forecasts, such as contingent liabilities. What does regularly mean? 11

12 Comparability of Fiscal Data: Fiscal forecasts, budgets, and fiscal reports are presented on a comparable basis, with any deviations explained Risk Management: Specific risks to the public finances should be regularly monitored, disclosed, and managed Allowances for Budgetary Contingencies: The budget has adequate and transparent provision for contingencies that arise during budget execution. The Basic Practice excludes publishing transparent access criteria to contingencies; transparent access criteria should be included as part of the Basic Practice for the dimension Asset and Liability Management: Risks relating to major assets and liabilities are disclosed and managed. How often? Natural Resources: The value of the government s interest in exhaustible natural resource assets and their exploitation is disclosed. Good and Advanced should both include disaggregation of resource revenues by type of revenue stream and on a project-by-project basis (see best practices in US Dodd-Frank Section 1504 and EU Accounting and Transparency Directives; plus EITI 2013 Standards) ALL revenue categories covered: sales and fiscal revenue too excusive; must ALSO include: bonuses, fees, in-kind revenues, direct sales of resources by state owned enterprises (e.g., sale of profit oil or direct production), equity dividends and other revenue as well as traditional fiscal revenue. Clarify value and major : Value the preferred term based on projected sales, fiscal and otherwise see above); Major is not defined and could lead to nondisclosure of important assets and revenue. o The Existing Code does NOT include this qualification; NOR should this Draft Code Ensure coverage of resource revenues of ALL state-owned enterprises AND/OR public sector entities. o This Principle (Natural Resources) + Principle (Coverage of Institutions) could result in certain national resource companies not being covered under the Basic or Good practice. o Principle s references to central government entities, general government entities and public sector entities (and how those are defined or not in the Glossary) should be reviewed to ensure comprehensive coverage Financial Derivatives: Financial derivative positions, if any, are regularly disclosed, assessed, and managed Guarantees: Government guarantees and their management policy are regularly disclosed Financial Sector Exposure: The government s potential fiscal exposure to the financial sector is analyzed and disclosed : Major and Multi-Annual Contracts: Major and multi-annual contracts, including public-private partnerships and contracts for the exploitation of resources, are regularly disclosed and actively managed, with all public rights, obligations and other exposures detailed. Include a clear statement on the public disclosure of contracts: The contracts themselves must be publicly disclosed for all 3 gradations; the Draft Code s references to publishing total rights, 12

13 obligations and other exposures under contracts is NOT as clear as a statement clearly calling for the publication of the contracts themselves. o Publication of a summary of contract terms should be within Good and Advanced practices o NOT clear: reference to actively managed. Clearly define and/or link to the Guide or the Natural Resource Charter for appropriate reference. Major and multi-annual contracts more problematic words o Contracts for the exploitation of resources : the Code should instead be clear the licenses or other agreements that provide the terms attached to the exploitation on natural resources should the equally subject to public disclosure. o Major : either drop the word from the Draft Code (not used by Existing Code, or IFC or EITI), OR specify that any contract for natural resource extraction entered into by the government IS major. o Glossary is NOT clear for Multi-annual : term of more than a year does NOT equal long term lease (10 or more years) o Existing Code BETTER: Arrangements between the government and public or private entities THAN Draft Code Definition of Multi-annual contracts references only between government or private entities. This is relevant where the state interest in a contract is often represented by a state owned enterprise rather than the government. o Incorporate an appropriate transparency indicator and measurement for contract disclosure: No real indicator or measurement is included on the question of contract disclosure.*the IMF should add+ include and indicator such as the percentage of total relevant contracts Environmental Risks: The potential fiscal exposure to natural disasters and other major environmental risks are analyzed, disclosed, and managed. How often? 3.3. Fiscal Coordination: Fiscal relations across the public sector should be analyzed, disclosed, and coordinated. This should include all public private partnerships and other off-budget expenditures Sub-National Governments: Comprehensive information on the fiscal condition of sub-national governments, individually and as a consolidated sector, are collected and published Public Corporations: The government oversees and regularly publishes comprehensive information on the financial performance of public corporations. Code should reference the need to publicly disclose audits of public corporations Annual reports should cover financial performance of the public corporation, not just the sector; and should apply to all levels of practice, not just advanced The reporting intervals should be at least six months Quasi-Fiscal Activity: Quasi-fiscal Activity is avoided, or if undertaken, comprehensively reported Health and Social Security: Fiscal risks relating to the social security and healthcare funds are disclosed and managed. C. FISCAL TRANSARENCY INDICATORS 13

14 These seem generally acceptable; we can judge their effectiveness in practice. Fiscal transparency indicators are incomplete and misleading since they do not take into account the portions of the budget sometimes extremely large that are officially secret. The IMF should consider using the Open Budget Survey. In my humble opinion (IMHO) it should be formulated in some straighter manner or secret share should be just added as a particular indicator. [Provides research on the Russian budget of percentage of each line item that is not disclosed as well as a global map where colors indicate which countries have the most and least portion of their budgets hidden.] The qualitative fiscal indicators are also a welcomed addition to the Fiscal Transparency Code; however, in our opinion there are some indicators which do not seem to relate directly to fiscal transparency (for example, 1.e, 2.g, 3.j.). It is clear that all indicators are relevant for the appropriate management and monitoring of the health of public finances; nevertheless, some addition indicators that relate directly to the quality and quantity of fiscal information published should be included to those indicators with a focus on fiscal management. III. Civil Society Participants Country Bangladesh Congo France Germany Hungary India Ivory Coast Kyrgyz Republic Kyrgyzstan Libya Organization The Alliance for Budget Transparency Recontre pour la Paix et les Droits de l Homme (RPDH) French Ministry of Finance Transparency International Fiscal Responsibility Institute Budapest International Budget Partnership CREFDI Bureau on Human and the Rule of Law USAID-UNDP Libyan Transparency Association 14

15 Mexico Mongolia Nigeria Nigeria Nigeria Poland Russia Togo UK Ukraine USA USA USA USA USA Fundar Citizens Oversight of Budget NGO Coalition of Mongolia Civil Resource Development and Documentation Center Civil Resource Development and Documentation Center Initiative for Food Environment and Health Society Fundacja Magazyn Kultury Gaidar Institute for Economic Policy REJED Togo OpenSpending Open Society Foundation Bangladesh Development Research Center (BDRC) Global Financial Integrity (GFI) Oxfam International International Budget Partnership Revenue Watch Institute 15