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The Board agreed that the Republic of Congo has made meaningful progress in implementing the 2016 Standard.

Outcome of the Validation of the Republic of Congo.

Decision reference
2018-34 / BM-40
Decision basis
2016 EITI Standard, Requirement 8.3 EITI Validation deadlines and consequences

Board decision

Following the conclusion of the Republic of Congo’s Validation, the EITI Board decided that the Republic of Congo has made meaningful progress overall in implementing the EITI Standard. In accordance with requirement 8.3c, the Republic of Congo will be requested to undertake corrective actions before the second Validation on 29 December 2019.

The Board took note of the Validator’s findings regarding requirement 1.3 on civil society engagement and adherence to the civil society protocol. The Board agreed that the situation raised serious concerns regarding significant aspects of the EITI Principles and Requirements. The Board agreed not to enforce a suspension under Requirement 8.3.c.i at this time. The Board agreed to monitor progress with the corrective actions and revisit the issues following the next Validation. 

The Board congratulates the Government of Republic of Congo and the EITI Executive Committee on the progress made in improving transparency and accountability in the extractive industries by providing a trusted source of data to inform public debate. The Board welcomed regulatory reforms to embed transparency in government systems. The Board noted the adoption of a new Transparency Code in March 2017, which translates key EITI Requirements into national legislation, including contract transparency, state participation, reporting on cost-oil, revenues and expenditure by the national oil company, beneficial ownership disclosure, publication of production data, audit and reconciliation of government revenues, transparency of resource allocation and extra-budgetary spending, project-level reporting and open data. The Board encouraged full implementation of this ambitious legislation.

After ten years of EITI reporting, the Republic of Congo has also expanded the scope of EITI reporting to include the forestry sector. The Board welcomed this innovative use of the EITI reporting framework.

The Board recognises Republic of Congo’s earlier efforts to publish quarterly reports on oil sales providing detailed information on the sale of oil by the national oil company (SNPC) in the period 2004 to 2014. The Board took note that these reports, which are highly relevant for compliance with certain aspects of the EITI Standard, are no longer in the public domain. The Board encouraged continued publication of information on the sale of oil by SNPC and the corresponding transfers to the treasury as provided by the Ministry of Finance quarterly reports.

The Board noted that despite the constrained general environment, civil society appears particularly engaged in the EITI process. Representatives from the civil society constituency attend MSG meetings regularly, conduct analysis of EITI Reports, produce communication materials and organise public events to inform citizens on issues related to the governance of the extractive industries. Civil society representatives in the MSG regularly express their views related to EITI activities and highlight their concerns, but self-censorship is also common practice to avoid reprisals. Cases of intimidation and arrest of journalists substantially engaged in the EITI process remain a concern.

The Board has determined that Republic of Congo will have 18 months, i.e. until 29 December 2019 before a second Validation to carry out corrective actions regarding the requirements relating to civil society engagement (1.3), MSG governance (1.4), licence allocations (2.2), license register (2.3), state-participation (2.6), production data (3.2), in-kind revenues (4.2), barter agreements (4.3), SOE transactions (4.5), data quality (4.9), distribution of revenues (5.1), social expenditures (6.1), SOE quasi-fiscal expenditures (6.2) economic contribution (6.3) and public debate (7.1), with SOE quasi-fiscal expenditures being the main area of concern.  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, Republic of Congo’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 April 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. Stakeholder comments on the report were taken into consideration by the independent Validator in finalising the Validation report. 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 Republic of Congo. Progress in addressing these corrective actions will be assessed in a second Validation commencing on 29 December 2019:

  1. In accordance with Requirement 1.3, the Government of Congo should ensure that there is an enabling environment for civil society participation, and that civil society representatives are able to engage in public debate related to the EITI process and express opinions about the EITI process without restraint, coercion or reprisal.

  2. In accordance with EITI Requirement 1.4, the government should renew the membership of the MSG in line with statutory documents. EITI Congo should review formalise and publish its per diem policy and set a reasonable amount in line with national practices. The MSG should ensure its TOR are in accordance with Requirement 1.4, publicly accessible, and implemented in practice.

  3. To strengthen implementation, EITI Congo may wish to ensure that the fiscal framework, the roles and responsibilities of key government entities and current or recent reforms in the mining, oil and gas sectors are clearly described in future EITI reporting. EITI Congo may wish to consider whether the EITI Congo website could provide a platform for updated information on the legal environment and fiscal framework.

  4. In accordance with EITI Requirement 2.2, EITI Congo should clearly define the number of mining, oil and gas licenses awarded and transferred in the year(s) under review, describe the statutory allocation and award procedures, including specific technical and financial criteria, and highlight any non-trivial deviations in practice. In addition, EITI Congo may wish to comment on the efficiency of the current license allocation and transfer system as a means of clarifying procedures and curbing non-trivial deviations.

  5. EITI Congo is required to maintain a publicly available register or cadastre system(s) with timely and comprehensive information in accordance with EITI Requirement 2.3. EITI Congo should ensure that future EITI Reports provide the dates of application and expiry, commodity(ies) covered and coordinates for all mining, oil and gas licenses held by material companies.

  6. To further strengthen implementation and prepare for full disclosure of beneficial ownership by 2020, it is recommended that EITI Congo considers piloting beneficial ownership reporting in the forthcoming EITI Report in order to increase awareness of beneficial ownership transparency and pilot beneficial ownership definitions and thresholds. EITI Reports must document the government’s policy and multi-stakeholder group’s discussion on disclosure of beneficial ownership. EITI Congo may also wish to conduct broader outreach to the companies on the objectives of beneficial ownership transparency, as well as hold conversations with government agencies on how to make such disclosures mandatory.

  7. In accordance with EITI Requirement 2.6, EITI Congo should ensure that future EITI Reports clarify the rules and practices governing financial relations between extractives SOEs and the government, the level of and terms associated with state equity participation in the sector as well as a comprehensive overview of loans and guarantees extended by the state or SOEs to extractives companies in the year under review. EITI Congo may wish to consider the extent to which implementation of Article 15 of the March 2017 Transparency Law would support progress in meeting aspects of Requirement 2.6.

  8. To strengthen implementation, EITI Congo may wish to ensure that the description of the extractive industries in future EITI Reports includes a clear overview of significant exploration activities in the year under review.

  9. In accordance with EITI Requirement 3.2, EITI Congo should ensure that future EITI Reports provide production volumes and values for all minerals produced in the ROC in the year(s) under review. EITI Congo may also wish to consider the extent to which such information could be regularly disclosed on government websites as a means of complying with provisions requiring publication of more granular production data in Article 66 of the March 2017 Transparency Law.

  10. To strengthen implementation, EITI Congo may wish to ensure that future EITI Reports provide export volumes and values for all commodities exported in the year(s) under review, including artisanal-mined commodities like gold.

  11. To strengthen implementation, EITI Congo may wish to ensure that the materiality threshold for selecting companies in future EITI Reports ensures that all payments that could affect the comprehensiveness of EITI reporting be included in the scope of reconciliation. The MSG is invited to consider whether setting a quantitative materiality threshold for selecting companies would ensure these aims are met.

  12. In accordance with EITI Requirement 4.2, EITI Congo should ensure that future EITI Reports present information on the sale of the state’s in-kind revenues disaggregated by buyer. The government is encouraged to reinstate the practice of publishing the Ministry of Finance’s quarterly oil sales reports to ensure timelier compliance with Article 16 of the March 2017 Transparency Law and with Requirement 4.2 of the EITI Standard. The Validator notes the recent Public Eye report on a Swiss commodity trader in the Republic of Congo, and encourages the MSG to take steps to provide more transparency in the role of oil commodity trading in future.

  13. In accordance with EITI Requirement 4.3, EITI Congo should assess the existence of any barter arrangements or infrastructure provisions during the scoping phase for its next EITI Report to ensure that reporting of the implementation of such agreements provides a level of detail and transparency commensurate with the disclosure and reconciliation of other payments and revenues streams. The MSG, together with the IA, should gain a full understanding of the terms of the relevant agreements and contracts, the parties involved, the resources which have been pledged by the state, the value of the balancing benefit stream (e.g. infrastructure works), and the materiality of these agreements relative to conventional contracts.

  14. To strengthen implementation, EITI Congo may wish to undertake outreach to SOCOTRAM with a view to engaging it in EITI implementation. Given the significant public debate surrounding the Maritime Tax, the MSG could consider including SOCOTRAM in the scope of reporting, further adding to the EITI’s impact on public debate.

  15. In accordance with EITI Requirement 4.5, EITI Congo should undertake a comprehensive assessment of transactions between SOEs (SNPC and its subsidiaries) and oil and gas companies, as well as between SNPC’s subsidiaries and government in its scoping of future EITI Reports. All SOEs collecting material revenues or making material payments to government should be included in future EITI reporting.

  16. To further strengthen implementation, the MSG may wish to consider the extent to which implementation of the March 2017 Transparency Law would enable it to make progress in implementing project-level EITI reporting ahead of the deadline for all EITI Reports covering fiscal periods ending on or after 31 December 2018, agreed by the EITI Board at its 36th meeting in Bogotá.

  17. To strengthen implementation, EITI Congo may wish to consider the extent to which it can leverage implementation of Article 63 of the March 2017 Transparency Law to ensure timelier disclosure of data required under the EITI Standard through routine government and company systems.

  18. In accordance with EITI Requirement 4.9, EITI Congo should ensure that summary data tables for all EITI Reports are prepared in a timely manner in line with requirements of the Board-approved IA’s ToR. The MSG and the IA are encouraged to provide a more detailed account of audit and assurance practices of material companies and government entities, including SOEs with a view to formulating recommendations that strengthen government and company audit and assurance systems. They may also wish to revisit the quality assurance requested from government entities included in the scope of reporting.

  19. In accordance with EITI Requirement 5.1, EITI Congo should work with the IA in preparing the next EITI Report to clearly trace any mining, oil and gas revenues that are not recorded in the national budget and provide an explanation of the detailed allocation of these off-budget revenues.

  20. To strengthen implementation, EITI Congo is encouraged to assess the materiality of subnational transfers, provide the specific formula for calculating subnational transfers of extractives revenues to individual local governments, disclose any material subnational transfers in the year(s) under review and highlight any discrepancies between the transfer amount calculated in accordance with the relevant revenue-sharing formula and the actual amount that was transferred between the central government and each relevant subnational entity.

  21. To strengthen implementation, EITI Congo could consider including additional information on extractives revenues earmarked for specific purposes as well as on the budget-making and auditing process for government accounts in future EITI Reports.

  22. In accordance with EITI Requirement 6.1, EITI Congo should systematically categorise types of mandatory social expenditures mandated by law or contract and ensure that reporting of mandatory social expenditures in future EITI Reports be disaggregated between cash and in-kind expenditures, by type of payment and beneficiary, clarifying the name and function of any non-government (third-party) beneficiaries of mandatory social expenditures. The MSG may also wish to consider the feasibility of reconciling mandatory social expenditures.

  23. In accordance with EITI Requirement 6.2, EITI Congo should undertake a comprehensive review of all expenditures undertaken by extractives SOEs (and their subsidiaries) that could be considered quasi-fiscal. The MSG should 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.

  24. In accordance with EITI Requirement 6.3, EITI Congo should ensure future EITI Report include employment figures for the mining, oil and gas sectors. The MSG may also wish to work with the Ministry of Finance, the national statistics agency (CNSEE), customs and the Ministry of Labour and Social Security to ensure that reporting of key information required by the EITI Standard on the extractive industries’ share of GDP, revenues and exports is embedded in routine government disclosures.  

  25. To improve accessibility of EITI disclosure, and in accordance with EITI Requirement 7.1, EITI Congo should resume its dissemination activities of all EITI disclosures, including the EITI Reports, the KPMG Reports and other useful materials that can contribute to a public debate on the EITI Congo website.  

  26. To strengthen implementation, the MSG may wish to consider commissioning an independent impact evaluation study to better document the extent to which EITI Congo has contributed in changing behaviour and improving the management of the extractive sector for the benefit of all citizens.

Background

The government of the Republic of Congo (ROC) committed to implement the EITI on 9 June 2004 and established a multi-stakeholder group in October 2006, following broad consultations with stakeholders. The Republic of Congo became a Candidate country implementing the EITI in February 2008 and was declared Compliant with the EITI Rules in March 2013.

The Validation process under the Standard commenced on 1 April 2017. In accordance with the Validation procedures, an initial assessment [English | French] was prepared by the International Secretariat. The Independent Validator reviewed the findings and wrote a draft Validation report [English | French]. Comments were received from Government representatives [English] and civil society groups [English | French]. The Independent Validator reviewed the comments, before finalising the Validation report [English| French].

The Validation Committee reviewed the case on 4 December 2017 and 12 January 2018. 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 timetable for Republic of Congo’s 2017 and 2018 EITI Reports.

Scorecard for Republic of the Congo: 2018

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 is committed to the EITI and relevant government representatives are part of the MSG. Participation in MSG meetings is relatively low, but meetings are usually quorate.

1.2Company engagement

Companies are actively engaged in the design and implementation of the EITI, including MSG deliberations.

1.3Civil society engagement

Civil society is actively engaged in the EITI process, but the application of the civil society protocol, particularly as it relates to freedom of expression, is limited to civil society members on the MSG. This controlled space for civil society is narrowly defined to MSG members and excludes important actors substantially engaged in the EITI process who are routinely exposed to intimidation, reprisal and censorship.

1.4MSG governance

The MSG includes relevant actors with adequate representation of key stakeholders, but the three-year mandate of MSG members (December 2012 to December 2015) has expired with no evidence of renewal. The MSG meets frequently, but there are gaps in attendance and record keeping. The MSG’s TOR lacks clear procedures for decision making, internal governance and the per diem policy remains ad hoc, opaque and could lead to conflicts of interest.

1.5Work plan

EITI Congo work plans include objectives that reflect national priorities, such as the extension of the scope of EITI reporting to the forestry sector and the drafting of a transparency law. Work plan activities are measurable and time-bound, structured to achieve the agreed objective. The work plans also include activities aimed at addressing capacity constraints and activities aimed at embedding EITI reporting in government system through the Transparency Code.

Licenses and contracts

2.1Legal framework

The 2014 EITI Report provides an overview of the legal framework and fiscal environment in the mining, oil and gas sectors. However, it does not clearly detail the functions of the different government entities in the sectors. The description of revenue flows shows which government entity collects which revenue stream and most government agencies’ role is limited to collecting taxes and revenue, except DGH, which also plays a regulatory role.

2.2License allocations

The 2014 EITI Report lists one oil and gas license equity transfer, seven oil and gas license transfers and one mining license renewal in 2014, but provides only a cursory overview of the license allocation process. The report does not mention any mining exploration license awards in 2014, although stakeholder consultations highlighted the existence of several such awards in 2014. Detailed technical and financial criteria assessed during license awards and transfers are not described, nor are any deviations from statutory procedures for all licenses awarded and transferred in 2014.

2.3License register

The 2014 EITI Report provides a list of mining, oil and gas licenses held by material companies, although it is unclear whether exploration licenses held by two material mining companies that are not members of the Federation of Mines were included. Information provided includes license-holder name and dates of award, as well as commodity covered for mining licenses but not for oil and gas. While dates of expiry and license coordinates are not provided in the 2014 EITI Report, the report provides the Decree numbers for 62 of the 65 licenses covered in the 2014 EITI Report (albeit without guidance on how to access individual Decrees), with license coordinates and dates of expiry accessible from the full text of the Decrees. However, the 2014 EITI Report does not provide dates of application for all licenses held by material companies, even though these are available in hard copy upon request from the line Ministries, nor guidance on how to access them. Licenses held by non-material companies are not covered and the 2014 EITI Report refers only generally to weaknesses in the license registers.

2.4Policy on contract disclosure

The government’s policy requires that all contracts signed by the state with mining, oil and gas companies, including PSCs to be published in the Journal Officiel and are therefore public documents. A new Transparency Law has expanded the scope to include forestry contracts. In practice, contracts are published in the Journal Officiel with a link to the website of the Secretary General of the Government and some contracts are available on the EITI Congo website.

2.5Beneficial ownership

Not assessed

EITI Congo has agreed a three-year beneficial ownership roadmap and the March 2017 Transparency Law codifies government beneficial ownership policy, although the 2014 EITI Report does not explicitly address beneficial ownership.

2.6State participation

The 2014 EITI Report clarifies that state participation gives rise to material revenues in oil and gas, not in mining. It describes the SOEs operating in oil and gas but does not appear to provide a comprehensive list of SNPC participations nor clarify whether there were any changes in state ownership in any SOEs or their subsidiaries in 2014. The terms associated with state equity in the mining, oil and gas sectors are not described. While the financial relations between the government and SNPC are briefly described, the rules for retained earnings, reinvestment and third-party financing for all extractives companies in which the state holds majority stakes are not comprehensively disclosed, nor are any significant deviations in practice. While the 2014 EITI Report implies a sovereign guarantee on oil-backed infrastructure projects financed by China EXIM Bank and refers to unpaid arrears from the CORAF to the Treasury, the terms of such loans and guarantees are not described and it is unclear whether disclosures of loans and loan guarantees by the state and extractives SOEs are comprehensive.

Monitoring production

3.1Exploration data

The 2014 EITI Report provides an overview of the mining, oil and gas sectors, but does not provide a clear description of significant exploration activities undertaken in 2014.

3.2Production data

The 2014 EITI Report provides production volumes for crude oil and it is possible to calculate the value of oil production based on the average oil price provided. While diamond production volumes are provided in the report, values are not. Finally, production volumes and values are not provided for natural gas.

3.3Export data

The 2014 EITI Report provides export volumes and values for crude oil and diamonds, but not for gold from artisanal mining.

Revenue collection

4.1Comprehensiveness

The MSG has agreed materiality thresholds for selecting companies and revenue streams, although the setting of a qualitative threshold for selecting companies means that companies that had ceased activities in 2014 were nevertheless included in the scope of reporting. The 2014 EITI Report lists and describes all material companies and revenue streams. The materiality of revenues from non-reporting companies is assessed, although the netting out of discrepancies tends to underestimate their cumulative value. Full government disclosure is provided.

4.2In-kind revenues

The 2014 EITI Report reconciles the volumes collected by government with company payments of in-kind revenues and discloses volumes of the state’s in-kind revenues sold by SNPC as well as the transfer of sales proceeds to the Treasury. The information on SNPC’s sales of the government’s in-kind revenues is not disaggregated by buyer, nor reconciled.

4.3Barter agreements

There is no evidence of the MSG’s assessment of the materiality of barter arrangements described in the 2014 EITI Report. The report appears to describe two barter arrangements, but does not provide sufficient detail on project values, terms of repayment or guarantee structure. There is insufficient information on a framework infrastructure agreement backed by future oil sales proceeds between the ROC and China to assess the applicability of Requirement 4.3 to this agreement.

4.4Transportation revenues

Not applicable

While there is evidence of the MSG’s assessment of the materiality of the Maritime Tax (see Requirement 4.1), the Maritime Tax is a payment from oil and gas companies to a private company.

4.5SOE transactions

The 2014 EITI Report discloses SNPC’s transactions with the government and the revenues collected by SNPC from material oil and gas companies. However, it is unclear whether the MSG has assessed the materiality of revenues collected by subsidiaries of SNPC and the 2014 EITI Report only briefly discloses one transaction between an SNPC subsidiary (CORAF) and the government.

4.6Direct subnational payments

Not applicable

While the 2014 EITI Report could be clearer in stating that direct subnational payments from extractives companies do not exist, the International Secretariat’s understanding is that this is not applicable in the period under review.

4.7Disaggregation

The 2014 EITI Report presents reconciled financial data disaggregated by receiving government entity, by company and by revenue stream.

4.8Data timeliness

Although the timeliness of the ROC’s EITI reporting has slipped since 2014, data in the ROC’s EITI Reports has always been published within two years of the end of the fiscal period under review.

4.9Data quality

The MSG approved ToR for the IA in line with the Board-approved template. There were no significant deviations from the IA’s ToR in practice, and the MSG approved the same reporting templates as previous years in its approval of the inception report. While there are concerns over the comprehensiveness of the review of audit and assurance procedures and practices, there are no requirements in the Board-approved IA ToR for the detailed findings of the review of audit procedures and practices to be included in the EITI Report itself. There are also concerns that the assurances required from government agencies has been given less attention in 2014 compared to the 2012-2013 EITI Reports. While this trend is unfortunate in reducing the extent to which the EITI Is used as a catalyst for improving public-sector auditing practices, the standard IA ToR gives the mandate to the MSG to agree with the IA the quality assurances for EITI reporting, which was done in preparing the 2014 EITI Report. The largest material companies and government entities appear to have complied with the agreed quality assurance procedures and the IA concluded that the data presented in the report was “reasonably reliable”. There is no evidence that the IA or MSG prepared summary data tables for the 2014 EITI Report.

Revenue allocation

5.1Distribution of revenues

The 2014 EITI Report describes three types of revenues related to oil and gas that are not recorded in the national budget. The aggregate value of each type of allocated revenue in 2014 is disclosed. However, it is unclear whether the private company collecting Maritime Tax revenues (SOCOTRAM) remits any proceeds from these payments to government. More significantly, the allocation of revenues to specific projects under the ROC-PRC framework agreement are not described in sufficient detail, since the IA did not have access to even general terms of the agreement. This is a particular concern given that roughly 37% of the state’s in-kind oil revenues were used off-budget for the reimbursement of these projects (see Requirement 4.3).

5.2Subnational transfers

Not applicable

The 2014 EITI Report describes the general system of subnational transfers of oil and gas royalties to host local governments. However, the International Secretariat understands that the statutory subnational transfers were not effective in 2014 due to the lack of implementing regulations. The report does not refer to any ad-hoc subnational transfers.

5.3Revenue management and expenditures

Not assessed

EITI Congo has made modest efforts to include additional information on earmarks of extractives revenues for off-budget infrastructure projects (see Requirements 4.3 and 5.1) and the budget-making and audit processes.

Socio-economic contribution

6.1Mandatory social expenditures

The 2014 EITI Report provides mandatory social expenditures by oil and gas companies, in the form of workforce training, but it does not show the identity of any non-government beneficiary. The report also discloses mining companies’ payments of USD 16 000 in mandatory social payments, but does not specify whether these were in cash or in-kind. The nature of any in-kind expenditures and the identity of any non-government beneficiary was not disclosed. The 2014 EITI Report provides unilateral reporting of voluntary social expenditures, albeit only disaggregated by company.

6.2Quasi-fiscal expenditures

The 2014 EITI Report does not refer to quasi-fiscal expenditures undertaken by SNPC or any of its subsidiaries and provides only limited information on transactions that could be considered quasi-fiscal expenditures. There is no evidence that the MSG or IA considered Requirement 6.2 in preparing the 2014 EITI Report.

6.3Economic contribution

The 2014 EITI Report provides, in absolute and relative terms, the mining, oil and gas sectors’ share of GDP, government revenues and exports as well information on the location of production. However, the report does not provide information on employment in the mining, oil and gas sectors nor estimates of informal gold exports.

Outcomes and impact

7.1Public debate

The MSG has taken steps to ensure that the 2012 and 2013 EITI report are comprehensible, actively promoted and publicly accessible. Through various dissemination methods, EITI-Congo has ensured that the EITI contributed to public debate. There is no evidence that the MSG agreed an open data policy for EITI Congo.

7.2Data accessibility

Not assessed

EITI-Congo does not yet provide EITI data in open data formats, despite some effort to develop an online portal with SAP. However, mainstreaming transparency in government systems through the transparency law has been a major achievement for the MSG.

7.3Follow up on recommendations

The MSG has been thorough in taking steps to act upon lessons learned and monitoring progress with the implementation of recommendations in EITI Reports. Together with the IA, significant efforts have been made to identify, investigate and address the causes of discrepancies in EITI reporting.

7.4Outcomes and impact of implementation

EITI-Congo has produced annual progress reports for 2014 and 2015 that thoroughly document progress and outcomes of implementation.