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The Board agreed that Mozambique has made meaningful progress overall in implementing the 2016 EITI Standard.

Outcome of the Validation of Mozambique

Decision reference
2017-51 / BM-38
Decision basis
2016 EITI Standard, Requirement 8.3 EITI Validation deadlines and consequences

Board decision

On 25 October 2017, the EITI Board came to the following decision on Mozambique’s status:

The Board agrees that Mozambique has made meaningful progress overall in implementing the 2016 EITI Standard. The Board’s determination of Mozambique’s progress with the EITI’s requirements is outlined in the assessment card below.

The EITI Board agreed that Mozambique has made satisfactory progress in meeting the requirements in the EITI Standard on Requirements 1.3, 1.5, 2.1, 2.4, 3.1, 3.2, 3.3, 4.7, 4.8 and 7.4. The Board further agreed that Mozambique has made meaningful progress in meeting requirements 1.1, 1.2, 1.4, 2.2, 2.3, 4.2, 4.3, 4.6, 4.9, 5.1, 5.2, 6.1, 6.3, 7.3, inadequate progress in meeting requirements 2.6, 4.4 and 4.5, and no progress in meeting requirement 6.2. The areas of concern relate to government and industry engagement (requirements 1.1 and 1.2), multi-stakeholder group governance (1.4), license allocations and register (2.2 and 2.3), state participation (2.6), in-kind revenues, barter agreements (4.3), transportation revenues (4.4), state-owned enterprises transactions (4.5), direct subnational payments (4.6), data quality (4.9), revenue management and expenditures (5.1), subnational transfers (5.2), mandatory social expenditures (6.1), quasi-fiscal expenditures by state-owned enterprises (6.2) economic contribution (6.3), public debate (7.1) and follow-up on recommendations (7.3).

Accordingly, the EITI Board agreed that Mozambique will need to take corrective actions outlined below. Progress with the corrective actions will be assessed in a second Validation commencing on 25 April 2019. Failure to achieve meaningful progress with considerable improvements across several individual requirements in the second Validation will result in suspension in accordance with the EITI Standard. In accordance with the EITI Standard, Mozambique’s multi-stakeholder group may request an extension of this timeframe, or request that Validation commences earlier than scheduled.

The Board’s decision followed a Validation that commenced on 1 January 2017. In accordance with the 2016 EITI Standard, an initial assessment was undertaken by the International Secretariat. The findings were reviewed by an Independent Validator, who submitted a draft Validation report to the MSG for comment. The MSG’s comments on the report were taken into consideration by the independent Validator in finalising the Validation report and the independent Validator responded to the MSG’s comments. The final decision was taken by the EITI Board.

Corrective actions and strategic recommendations

The EITI Board agreed the following corrective actions to be undertaken by Mozambique. Progress in addressing these corrective actions will be assessed in a second Validation commencing on 25 April 2019:

  1. In accordance with requirement 1.1, the government should demonstrate that it is fully, actively and effectively engaged in the EITI process. In accordance with requirement 8.3.c.i, the government is requested to develop and disclose an action plan for addressing the deficiencies in government engagement documented in the initial assessment and validator’s report within three months of the Board’s decision, i.e. by 25 January 2018. The government should ensure appointment of government representatives on the MSG with the capacity to carry out their duties in terms of influences decision-making and properly informing their constituents.
  2. In accordance with requirement 1.2, companies should demonstrate that they are fully, actively and effectively engaged in the EITI process. In accordance with requirement 8.3.c.i, the company constituency is requested to develop and disclose an action plan for addressing the deficiencies in company engagement documented in the initial assessment and validator’s report within three months of the Board’s decision, i.e. by 25 January 2018. The company constituency members may wish to establish a platform or use existing channels to disseminate EITI information to companies beyond the MSG, and should play an active role in setting objectives for EITI implementation in the country.
  3. In accordance with requirement 1.4.a.ii, the MSG should ensure that its procedures for nominating and changing multi-stakeholder group representatives are public and confirm the right of each stakeholder group to appoint its own representatives. In accordance with requirement 1.4.b.ii and 1.4.b.iii, the MSG should ensure that stakeholders are adequately represented and undertake effective outreach activities with civil society groups and companies, including through communication such as media, website and letters, informing stakeholders of the government’s commitment to implement the EITI, and the central role of companies and civil society. Members of the MSG should liaise with their constituency groups. In accordance with requirement, the MSG should ensure an inclusive decision-making process throughout implementation, particularly as concerns industry and civil society. Each constituency should ensure that their representatives’ attendance at MSG meetings is consistent and at sufficiently high level to allow the MSG to take decisions and follow up on agreed matters.
  4. In accordance with requirement 2.2.a, Mozambique should ensure annual disclosure of which mining, oil, and gas licenses were awarded and transferred during the year under review, highlighting the processes for transferring licenses, technical and financial requirements and any non-trivial deviations from the applicable legal and regulatory framework governing license awards and transfers. The MSG could further consider tasking the Independent Administrator to provide an evaluation of the licensing process and make recommendations for its improvement.
  5. In accordance with requirement 2.3, Mozambique should also ensure that the license holder names, dates of application, award and expiry, commodity(ies) covered and coordinates for all petroleum licenses held by material companies are publicly available. Where this information is already publicly available, it is sufficient to include a reference or link in the EITI Report. Where such registers or cadastres do not exist or are incomplete, the EITI Report should disclose any gaps in the publicly available information and document efforts to strengthen these systems.
  6. In accordance with requirement 2.6.a, Mozambique should provide an explanation of the prevailing rules and practices regarding the financial relationship between the government and state-owned enterprises (SOEs), including the rules and practices governing transfers of funds between the SOE(s) and the state, retained earnings, reinvestment and third-party financing. The government should also, in accordance with requirement 2.6.b, ensure annual disclosure on the level of ownership held by the government and SOEs in mining, oil and gas companies operating within the country’s oil, gas and mining sector, including those held by SOE subsidiaries and joint ventures, and any changes in the level of ownership. This information should include details regarding the terms attached to their equity stake, including their level of responsibility to cover expenses at various phases of the project cycle, e.g., full-paid equity, free equity, carried interest. The government should also provide a comprehensive account of any loans or loan guarantees extended by the state or SOEs to mining, oil, and gas companies operating in the country. The MSG should discuss and document its definition of SOEs taking into account national laws, government structures and ongoing reforms.
  7. In accordance with the requirement 4.2, the MSG and the Independent Administrator are required to ensure annual disclosure of the sale of the state’s share of production or other revenues collected in kind, and where these are material, comprehensively disclose volumes sold and revenues received from these sales. The published data must be disaggregated by individual buying company and to levels commensurate with the reporting of other payments and revenue streams (4.7). The MSG should ensure that EITI Reports consistently and comprehensively describe the rules and practices regarding the management of revenue from the sale of the state’s share of gas and revenues collected in-kind. This should include details on marketing of these resources to domestic buyers, unless considered immaterial by the MSG. The Independent Administrator should provide a clear opinion on the comprehensiveness of the reported data.
  8. In accordance with requirement 4.3, the MSG and the Independent Administrator are required to consider whether there are any agreements, or sets of agreements involving the provision of goods and services (including loans, grants and infrastructure works), in full or partial exchange for oil, gas or mining exploration or production concessions or physical delivery of such commodities. Where the MSG concludes that these agreements are material, the MSG and the Independent Administrator are required to ensure that the EITI Report addresses these agreements, providing a level of detail and transparency commensurate with the disclosure and reconciliation of other payments and revenues streams. Where reconciliation of key transactions is not feasible, the MSG should agree an approach for unilateral disclosure by the parties to the agreement(s) to be included in the EITI Report. The MSG should clarify whether EITI reporting comprehensively addresses the possible existence of such agreements not covered in the report, and ensure that it is clearly stated if they do not exist.
  9. In accordance with requirement 4.4, the government and the MSG should ensure that material revenues collected by the government and SOEs from the transportation of oil, gas and minerals are disclosed. This could include a description of the transportation arrangements including the product, transportation route(s), and the relevant companies and government entities, including SOE(s), involved in transportation. The MSG may also wish to ensure disclosure of the definitions of the relevant transportation taxes, tariffs or other relevant payments, and the methodologies used to calculate them, disclosure of tariff rates and volume of the transported commodities, as well as disclosure of revenues received by government entities and SOE(s), in relation to transportation of oil, gas and minerals (4.4.a-d).
  10. In accordance with requirement 4.5, the MSG must ensure that the reporting process comprehensively addresses the role of SOEs, including material payments to SOEs from extractives companies, and transfers between SOEs and other government agencies.
  11. In accordance with requirement 4.6, it is required that the MSG establish whether direct payments from companies to subnational governments, within the scope of agreed revenue streams, are material. Where material, the MSG must ensure that direct company payments to subnational government entities are disclosed and reconciled in future EITI Reports.
  12. In accordance with Requirement 4.9.a, the EITI requires an assessment of whether the payments and revenues are subject to credible, independent audit, applying international auditing standards. In accordance with requirement 4.9.b.iii and the standard Terms of Reference for the Independent Administrator agreed by the EITI Board, the MSG and Independent Administrator should:
    1. examine the audit and assurance procedures in companies and government entities participating in the EITI reporting process, and based on this examination, agree what information participating companies and government entities are required to provide to the Independent Administrator in order to assure the credibility of the data in accordance with Requirement 4.9. The Independent Administrator should exercise judgement and apply appropriate international professional standards in developing a procedure that provide a sufficient basis for a comprehensive and reliable EITI Report. The Independent Administrator should employ his/her professional judgement to determine the extent to which reliance can be placed on the existing controls and audit frameworks of the companies and governments. The Independent Administrator’s inception report should document the options considered and the rationale for the assurances to be provided.
    2. ensure that the Independent Administrator provides an assessment of whether all companies and government entities within the agreed scope of the EITI reporting process provided the requested information. Any gaps or weaknesses in reporting to the Independent Administrator must be disclosed in the EITI Report, including naming any entities that failed to comply with the agreed procedures, and an assessment of whether this is likely to have had material impact on the comprehensiveness and reliability of the report.
  13. In accordance with requirement 5.1.a, the MSG should ensure that the allocation of extractives revenues not recorded in the national are explained, with links provided to relevant financial reports as applicable.
  14. In accordance with requirement 5.2.a, the MSG should ensure that the specific formula for calculating transfers to individual local governments be disclosed, to support an assessment of discrepancies between budgeted and executed subnational transfers. The MSG is encouraged to reconcile these transfers.
  15. In accordance with requirement 6.1.a, the MSG should agree a clear distinction between mandatory and voluntary social expenditures prior to data collection and ensure that material mandatory social expenditures are comprehensively disclosed in future EITI Reports. Where beneficiaries of mandatory social expenditures are a third party, i.e. not a government agency, the MSG should ensure that the name and function of the beneficiary be disclosed. The MSG should provide a comprehensive overview of existing social expenditures by oil, gas and mining companies, and further clarify how disbursement from social funds are being made and the basis for selection of beneficiaries.
  16. In accordance with requirement 6.2, the MSG should consider the existence and materiality of any quasi-fiscal expenditures undertaken by extractives SOEs and their subsidiaries, ensuring that all material quasi-fiscal expenditures are disclosed in future EITI Reports. Should material quasi-fiscal expenditures exist, the multi-stakeholder group is required to develop a reporting process with a view to achieving a level of transparency commensurate with other payments and revenue streams, and should include SOE subsidiaries and joint ventures.
  17. In accordance with requirements 6.3, the MSG should ensure that future EITI Reports provide the contribution of the mining, oil and gas sectors to GDP in absolute terms and an estimate of informal sector activity (6.3.a), comprehensive figures on exports from the extractive industries in absolute terms and as a percentage of total exports (6.3.c), as well as comprehensive extractives employment figures, in absolute and relative to total employment (6.3.d) for the year(s) under review.
  18. In accordance with requirement 7.1, the MSG must ensure that EITI Reports are comprehensible, actively promoted, publicly accessible and contribute to public debate. Key audiences should include government, parliamentarians, civil society, companies and the media. The MSG should discuss the role the EITI could play in achieving national priorities and how it can generate public debate around natural resource use.
  19. In accordance with requirement 7.3, the MSG is required to take steps to act upon lessons learnt; to identify, investigate and address the causes of any discrepancies; and to consider the recommendations resulting from EITI reporting. The MSG should ensure more systematic follow-up on the EITI Report recommendations and ensuring that these highlight gaps identified through the reporting process.

The MSG is encouraged to consider the other recommendations in the Validator’s Report and the International Secretariat’s initial assessment, and to document the MSG’s responses to these recommendations in the next annual progress report. 


The Government of Mozambique committed to implementing the EITI in 2008 and a multi-stakeholder group was formed in early 2009 to oversee EITI implementation. The country was accepted as an EITI candidate in February 2009, and became compliant with the 2011 EITI Rules in October 2012.

The Validation process commenced on 1 January 2017. In accordance with the Validation procedures, an initial assessment was prepared by the International Secretariat. The Independent Validator reviewed the findings and wrote a draft Validation report. Comments were received from the MSG. The Independent Validator reviewed the comments and responded to the MSG, before finalising the Validation report.

The Validation Committee reviewed the case on 20 September 2017. Based on the findings above, the Validation Committee agreed to recommend the assessment card and corrective actions outlined below.

The Committee also agreed to recommend an overall assessment of “meaningful progress” in implementing the 2016 EITI Standard. Requirement 8.3.c. of the EITI Standard states that:

ii.    Overall assessments. Pursuant to the Validation Process, the EITI Board will make an assessment of overall compliance with all requirements in the EITI Standard.

iv.   Meaningful progress. The country will be considered an EITI candidate and requested to undertake corrective actions until the second Validation.

The Validation Committee agreed to recommend a period of 18 months to undertake the corrective actions. This recommendation takes into account that the challenges identified are relatively significant and seeks to align the Validation deadline with the deadline for the 2017 EITI Report.

Scorecard for Mozambique: 2017

Assessment of EITI requirements

  • Not met
  • Partly met
  • Mostly met
  • Fully met
  • Exceeded
Scorecard by requirement View more Assessment View more

Overall Progress

MSG oversight

1.1Government engagement

The government has made public statements of support to the EITI and appointed senior officials to lead the EITI process, however, past EITI Chairs have not attended multi-stakeholder group (MSG) meetings regularly and stakeholders see the lacking engagement by government as a whole as an impediment to meaningful EITI implementation. There does however appear to be an expectation among stakeholders the new administration might result in improvements in the level of government engagement.

1.2Company engagement

Companies are not fully, actively and effectively engaged in the EITI process. While industry representatives regularly attend MSG meetings, their role appears to be more reactive rather than proactive, and the level of engagement in the design, implementation and monitoring of the EITI process appears limited.

1.3Civil society engagement

Civil society is fully, actively and effectively engaged in the EITI process and has contributed significantly to EITI implementation in Mozambique. Civil society representatives’ ability to participate in the EITI process does not appear to have been restricted or affected by the legal, regulatory, administrative and actual environment. Civil sociery has played an active role in overseeing the EITI reporting process and contributing to public debate related to extractive sector governance.

1.4MSG governance

Key government agencies that play a significant role in the management of the sector are not represented on the multi-stakehlder group (MSG) which arguably undermines its work. The MSG is encouraged to include relevant actors in the revised Terms of Reference, or ensure that there are mechanisms in place for these government agencies to provide input to the implementation and design of the EITI. The MSG should also consider including additional provisions in the revised TORs addressing the capacity of the members to fulfil their duties and requirements related to attendance.

1.5Work plan

The MSG has agreed a work plan which reflects the national priorities for the sector, and there is evidence of progress in more clearly articulating the objectives of EITI implementation.

Licenses and contracts

2.2License allocations

The 2013-14 EITI Report describes the licensing process and details on some of the licenses awarded. There is limited information on the process for transferring licenses and the technical and financial criteria used.

2.3License register

The mining cadastre includes detailed information on mining licenses. There is useful information on hydrocarbon licenses, but should also include a comprehensive overview of active hydrocarbon licenses/concessions, including date of application, date of award and duration of the license, or reference to where this information is accessible.

2.4Policy on contract disclosure

The 2013-14 EITI Report outlines the government’s policy on contract transparency as mandated by the 2014 Petroleum and Mining Laws, as well as actual practice.

2.1Legal framework

The 2013-14 EITI Report provides a summary description of the fiscal regime, including the level of fiscal devolution, an overview of the relevant laws and regulations, and information on the roles and responsibilities of the relevant government agencies involved in the governance of the petroleum and mining sectors.

2.5Beneficial ownership

Not assessed

Implementing countries are not yet required to address beneficial ownership and progress with this requirement does not yet have any implications for a country’s EITI status. Stakeholders from civil society and industry expressed interest in making ownership information transparent.

2.6State participation

The 2013-14 EITI Report includes some relevant information on state participation in the extractive industries, including an overview of direct state shareholding in the extractive sector and information on the terms of participation of SOEs in projects. However, the EITI Reports do not clearly describe the financial relationships between the government and the various SOEs, such as practices related to dividends, financing, loans and reinvestments. Changes in state ownership during the reporting years are not described.

Monitoring production

3.1Exploration data

The 2013-14 EITI Report includes a comprehensive overview of both the mining and oil and hydrocarbon sector, including reserves, new development projects and ongoing exploration activities.

3.2Production data

The 2013-14 EITI Report includes information on production values and volumes, and has attempted to obtain information disaggregated by company through the EITI reporting process.

3.3Export data

The 2013-14 EITI Report includes information on production values and volumes, and has attempted to obtain information disaggregated by company through the EITI reporting process.

Revenue collection

4.3Barter agreements

While the report describes an infrastructure agreement between the government and ENI, this appears to be a standalone agreement and there does not appear to be a link to an extractive license. It is however not clear whether the report comprehensively addresses the possible existence of other agreements which might involve the provision of goods and services in full or partial exchange for oil, gas or mining exploration or production concessions or physical delivery of such commodities.

4.6Direct subnational payments

The 2013-14 EITI Report describes the different revenues collected at the municipal level, but does not document whether there are direct payments and does not mention cases in which municipalities or district authorities collect revenue directly from extractives companies. Companies operating in the sector appear to be making some smaller payments to municipalities.


The 2013-14 EITI Report contains financial data disaggregated by individual company and revenue flow. The data is not explicitly disaggregated by government entity, although it indicates which entity receives each revenue stream.

4.9Data quality

While the 2013-14 EITI Report refers to government agencies having been audited, it does not include a review of whether government agencies have been audited in accordance with the legislation, nor does it give an overview of company auditing practices and relevant regulations.


The multi-stakeholder group (MSG) has agreed a materiality threshold for company payments, although the rationale for setting the threshold was not clearly documented. Notwithstanding this concern, the report appears to provide a comprehensive reconciliation of government revenues and company payments in accordance with the agreed scope. In 2014, 13 of the 71 companies included within the scope of the reporting exercise did not participate. However, the contribution of these firms was small, with the overall coverage of reconciliation being 99.51%.

4.2In-kind revenues

The 2013-14 EITI Report describes the collection on in-kind revenue of material value, and reconciles the volumes of in-kind revenue collected by government agencies/SOEs. The data is disaggregated by buying company. The arrangements are however not clearly explained and there appear to be some inconsistencies in the reported volumes. It is not clear from the report whether there is comprehensive disclosure of the revenues collected from the sales of in-kind revenues by Empresa Nacional de Hidrocarbonetos (ENH) and Matola Gas Company (MGC).

4.4Transportation revenues

The multi-stakeholder group (MSG) and Independent Administrator have reached out to the relevant government agencies to collect data on transportation revenue collected by these entities. While the companies did not respond, information on transportation tariffs should be accessible for the next EITI Report under the Freedom of Information Act.

4.5SOE transactions

The 2013-14 EITI Report includes limited information on the transactions between the government and SOEs. While SOEs are included in the scope of the reconciliation, it is not clear whether these have been reported comprehensively, in particular with regards to dividends collected and how they are managed.

4.8Data timeliness

The 2013-14 EITI Report was published less than one year following the end of the latest financial year covered by the report.

Revenue allocation

5.1Distribution of revenues

The 2013-14 EITI Report describes the laws and systems regulating the management of revenue from the extractive industries and outlines the distribution of the main revenues and the agencies responsible for collecting them. The report does not make it clear whether all payments are recorded in the state budget or if some revenues are retained by government entities.

5.2Subnational transfers

The 2013-14 EITI Report describes the system for allocating a percentage of the revenue from petroleum and mining to affected communities and discloses the transfers by community. There are however some inconsistencies in the figures provided, and the report does not explain how revenues are distributed among communities affected by mining.

5.3Revenue management and expenditures

Not assessed

The 2013-14 EITI Report includes a description on allocation of revenue from extractives for specific programs and geographic regions. There is no additional information such as projected production, commodity prices and revenue forecasts. Reporting on revenue management and expenditures is encouraged but not required by the EITI Standard and progress with this requirement will not have any implications for a country’s EITI status.

Socio-economic contribution

6.1Mandatory social expenditures

The 2013-14 EITI Report provides detailed information on the contributions made by companies to the social projects fund and training activities as well as their recipients. It is not clear whether the funds allocated for training are disbursed from the Institutional Capacity Building Fund, and where the revenues from Institutional Contribution are allocated. The basis for selection of beneficiaries of the social fund is not described.

6.2Quasi-fiscal expenditures

The 2013-14 EITI Report does not document whether quasi-fiscal expenditures by SOEs exist and whether they are material.

6.3Economic contribution

The 2013-14 EITI Report provides information on the contribution of the extractive sector to the economy, although there is some inconsistency in total revenue figures and some missing details related to GDP contribution and employment.

Outcomes and impact

7.2Data accessibility

EITI Mozambique has made various efforts to make data available such as producing summary briefs and brochures. However, all EITI Reports published by Mozambique EITI are in PDF format and are not machine-readable which makes accessibility to data files challenging.

7.4Outcomes and impact of implementation

The multi-stakeholder group (MSG) has reviewed the outcomes and impact of EITI implementation on natural resource governance through the production of annual progress reports.

7.1Public debate

Various efforts have been made to ensure that EITI Reports are comprehensible and actively promoted and publicly accessible. There is limited evidence of strategic outreach activities and that EITI has led to public debate in the country.

7.3Follow up on recommendations

The multi-stakeholder group (MSG) has considered the recommendations from the EITI reporting and followed up and addressed some of the recommendations, although the approach is ad hoc. A more systematic approach to developing and following up on report recommendations is needed to ensure that EITI reporting can help address gaps in the way the sector is managed.