Skip to main content

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

Outcome of the Validation of Madagascar.

Decision reference
2018-35 / BM-40
Decision basis
2016 EITI Standard, Requirement 8.3 EITI Validation deadlines and consequences

Board decision

Following the conclusion of Madagascar’s Validation, the EITI Board decided that Madagascar has made meaningful progress overall in implementing the EITI Standard.

The Board congratulated the Government of Madagascar and Multi-Stakeholder Group (MSG) on the progress made in improving transparency and accountability in the extractive industries. The Board recognised that the complexities of Madagascar’s mining licensing system, fiscal decentralisation and state participation in the extractives sector are particularly well-suited to the EITI’s multi-stakeholder governance model. Overcoming funding and capacity challenges and uneven engagement of its different constituencies, EITI Madagascar is recognised for having made a tangible impact on extractives governance. While the EITI’s impact has been greatest on clarifying mining license awards since the 2011 moratorium on new licensing and contributing to the launching of an online mining cadastre in 2017, the Board considered that more work was needed in clarifying license transfers. The Board notes that EITI data on subnational payments, transfers and social expenditures has empowered mayors in communes and regions to demand their statutory share of extractives revenues. The Board recognises Madagascar’s efforts to go beyond the requirements of the EITI Standard in providing information on informal extractives activities. The Board encourages the government to continue discussions on extractives license management, production data and subnational transfers, and to expand them to other salient issues such as transparency of state owned companies (SOEs).

While stakeholder engagement has historically been inconsistent across different constituencies, the Board takes note of stakeholders’ renewed engagement following the EITI’s institutionalisation by Decree in August 2017. All three constituencies are urged to revitalise the Multi-Stakeholder Group in balancing interests between equal partners and representing the interests of their broader constituencies through proactive outreach, canvassing and dissemination.

The Board has determined that Madagascar will have 18 months, i.e. until 29 December 2019 before a second Validation to carry out corrective actions regarding the requirements relating to government engagement (1.1), civil society engagement (1.3), MSG governance (1.4), license allocation (2.2), contract transparency (2.4), state participation (2.6), comprehensiveness of revenue disclosures (4.1), transportation revenues (4.4), direct subnational payments (4.6), level of disaggregation (4.7), data quality (4.9), distribution of revenues (5.1), sub-national transfers (5.2), quasi-fiscal expenditures (6.2) and documenting outcomes and impact of implementation (7.4).  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, Madagascar’s MSG 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 September 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 Madagascar. Progress in addressing these corrective actions will be assessed in a second Validation commencing on 29 December 2019.:

  1. In accordance with Requirement 1.1, the government must be fully, actively and effectively engaged in the EITI process. The government is required to appoint a senior individual to lead the implementation of the EITI. The appointee should have the confidence of all stakeholders, the authority and freedom to coordinate action on the EITI across relevant ministries and agencies, and be able to mobilise resources for EITI implementation. To further strengthen implementation following the institutionalisation of EITI Madagascar through the 2017 Decree, the government is encouraged to further entrench EITI funding in government budgeting to ensure the sustainability of EITI implementation over the long term. In accordance with requirement 8.3.c.i, the government constituency should develop and disclose an action plan for addressing the deficiencies in government engagement documented in the initial assessment.

  2. In accordance with requirement 1.3.a, the civil society constituency should demonstrate that they are fully, actively and effectively engaged in the EITI process. Specifically, civil society should ensure that they fully contribute and provide input to the EITI process and that they have adequate capacity to participate in the EITI. In accordance with requirement 8.3.c.i, the civil society constituency should develop and disclose an action plan for addressing the deficiencies in civil society engagement documented in the initial assessment.

  3. In accordance with Requirement 1.4.b.vii, the MSG should ensure that there is sufficient advance notice of meetings and timely circulation of documents prior to their debate and proposed adoption. The MSG is encouraged to ensure that deviations from their ToR are recorded and transparent. Government and company constituencies are encouraged to ensure that their representatives’ attendance at MSG meetings is consistent and of sufficiently high level to allow the MSG to take decisions and follow up on them. In accordance with Requirement 1.4.b.viii, the MSG must keep written records of its discussions and decisions.

  4. In accordance with Requirement 2.2, a description of the process for transferring or awarding the license and the technical and financial criteria used should be publicly available. Not least given the significant debate surrounding license movements in the mining sector, EITI Madagascar is encouraged to use EITI reporting as a diagnostic tool for non-trivial deviations from the applicable legal and regulatory framework governing license transfers and awards. In cases of competitive tender for mining, oil and gas licenses, the MSG will have to disclose the list of applicants and the bid criteria for licenses awarded through a bidding process. The MSG is encouraged to consider stakeholders calls for further analysis on the efficiency and effectiveness of licensing procedures in Madagascar.

  5. In accordance with Requirement 2.4, EITI Madagascar should clarify and document the government’s policy on disclosure of contracts and licenses, as well as actual practice, including any reforms that are planned or underway.

  6. In accordance with Requirement 2.6, the MSG should ensure that a comprehensive list of state participation in the extractive industries, including terms associated with state equity and any changes in the year under review, be publicly accessible. The MSG must also clarify the rules and practices governing financial relations between SOEs (most notably KRAOMA) and the state. The MSG may wish to liaise with relevant government entities and development partners to assess the extent to which clarification of such issues could support progress under the IMF extended credit facility. Stakeholders are encouraged to embed reporting of such information through routine government systems, for instance in publishing extractives SOEs’ statutes and audited financial statements on a regular basis.

  7. In accordance with Requirement 4.1.a, the MSG should ensure that its materiality decisions related to selecting companies and revenue streams for reconciliation are clearly documented. In its approach to the materiality of revenue streams, the MSG is encouraged to strike a balance between comprehensiveness and relevance for stakeholders, to ensure that a workable approach to reconciliation is adopted and to facilitate the embedding of revenue transparency in government and company systems. In accordance with Requirement 4.1.c, the MSG should ensure that the materiality of payments from each non-reporting entity is clearly assessed to support the IA’s overall assessment of the comprehensiveness of reconciliation. In accordance with Requirement 4.1.d, unless there are significant practical barriers, the government is additionally required to provide aggregate information about the amount of total revenues received from each of the benefit streams agreed in the scope of reconciliation, including revenues that fall below agreed materiality thresholds.

  8. In accordance with Requirement 4.4, the MSG should assess the materiality of government revenues from the transportation of minerals, clarifying the management of port-related fees on the transportation of minerals.

  9. In accordance with Requirement 4.6, the MSG should establish whether direct subnational payments, within the scope of the agreed benefit streams, are material. Where material, the MSG is required to ensure that reconciled information on company payments to subnational government entities and the receipt of these payments be publicly accessible. EITI Madagascar may wish to provide more information on the disbursement of ristournes from Ambatovy to host communes built-up since the start of production in 2012 given the materiality of such delayed payments.

  10. In accordance with Requirement 4.7, the MSG is required to ensure that EITI data is presented by individual company, government entity and revenue stream. To strengthen implementation, the MSG may wish to consider the extent to which it can 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. 

  11. 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 comprehensiveness and reliability of the (financial) data presented, including an informative summary of the work performed by the Independent Administrator and the limitations of the assessment provided.

    3. 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.

  12. In accordance with Requirement 5.1, EITI Madagascar should publicly clarify which extractive industry revenues, whether cash or in-kind, are recorded in the national budget. Where revenues are not recorded in the national budget, the allocation of these revenues must be explained, with links provided to relevant financial reports as applicable. To strengthen implementation, EITI Madagascar may wish to use EITI reporting to monitor the migration of government finances towards a single Treasury account system, providing a platform for public information on the management of off-budget extractives revenues.

  13. In accordance with Requirement 5.2, the MSG is required to ensure that material subnational transfers of extractives revenues are publicly disclosed, when such transfers are mandated by a national constitution, statute or other revenue sharing mechanism. The MSG should also disclose any discrepancies between the transfer amount calculated in accordance with the relevant revenue sharing formula and the actual amount transferred between the central government and each relevant subnational entity. The MSG is encouraged to reconcile these transfers.

  14. In accordance with Requirement 6.2, the MSG should undertake a comprehensive review of all expenditures undertaken by extractives SOEs that could be considered quasi-fiscal. The MSG should develop a reporting process for quasi-fiscal expenditures with a view to achieving a level of transparency commensurate with other payments and revenue streams.

  15. In accordance with Requirement 7.4, the annual progress report should be the product of consultations with all stakeholders and include a review of the impact of EITI implementation. Civil society groups and industry involved in the EITI, particularly, but not only those serving on the MSG, should be able to provide feedback on the EITI process and have their views reflected in the APR.

The government and the MSG are 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 Madagascar committed to implement the EITI in 2007 and was accepted as an EITI Candidate in February 2008. Following its suspension by the EITI Board for political instability in October 2011, interrupting the country’s Validation under the EITI Rules, Prime Minister Jean Omer Beriziky issued a Ministerial Order in March 2013 establishing a permanent EITI National Committee. The EITI Board lifted Madagascar’s suspension in June 2014. The government’s Decree 2017/736 in August 2017 institutionalised the EITI under the Prime Minister’s Office.

The Validation process commenced on 1 September 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 from the MSG [English | French] were received on 8 May 2018. The Independent Validator reviewed the comments and responded to the MSG, before finalising the Validation report [English] [French].

The Validation Committee reviewed the case on 22 May 2018 and 6 June 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 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 Madagascar’s 2016 and 2017 EITI Reports.

Scorecard for Madagascar: 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 International Secretariat understands that the government has not been fully, actively and effectively engaged in the EITI process between 2014 and 2017 and notes concerns from various stakeholders that the more recent engagement might not be sustained in the long-term. However, the commitment reflected in the months leading to Validation, coupled with the institutionalization of EITI Madagascar through the August 2017 Decree, more sustainable funding and mechanisms to ensure more consistent government participation in EITI activities, are strong signs that the government has renewed its commitment to the EITI. The extent to which the government sustains this commitment to use the EITI as an instrument to drive reforms will be key to the prospects of EITI implementation.

1.2Company engagement

Companies are fully, actively and effectively engaged in the EITI process, both as providers of information and in the design, implementation, monitoring and evaluation of the EITI process. The government has ensured that there is an enabling environment for company participation. Despite constraints imposed by confidentiality provisions of the tax code, the waiver system designed by the MFB has provided a means of facilitating company reporting. In the International Secretariat’s view, the industry constituency has made efforts to go beyond the minimum requirement in the quality, consistency and proactive nature of its engagement in all aspects of EITI implementation. Amidst weakening engagement from the other two constituencies, such engagement has been key to ensuring the sustainability of EITI implementation.

1.3Civil society engagement

There is no evidence of legal, regulatory or practical barriers to civil society’s ability to engage in EITI nor to their ability to freely operate, communicate and cooperate with the broader constituency. Minutes of MSG meetings and stakeholder consultations showed no constraints on civil society’s rights or ability to be actively engaged in the EITI. However, civil society’s engagement in EITI implementation has declined markedly since 2015 and several civil society stakeholders engaged in extractives issues but not represented on the MSG expressed frustration at the lack of adequate constituency coordination and representation in EITI implementation. While technical and financial capacity constraints and the fragmented nature of Malagasy civil society help explain this declining engagement, lack of coordination between CSOs directly involved in EITI and their constituents has meant that key EITI documents such as the annual work plan and ToR of the IA do not appear to reflect the priorities of the broader civil society constituency (see Requirements 1.5 and 4.9).

1.4MSG governance

The MSG includes appropriate representation of each constituency and the process by which each stakeholder group nominated their representatives is clear. All civil society representatives on the MSG are independent, operationally and in policy terms, from government. The MSG’s ToR outlines the roles and responsibilities of MSG members and meeting records show that MSG members who attend meetings carry out their duties and responsibilities. However, there have been significant deviations from the MSG’s ToR in practice in the 2015-2017 period, including inadequate planning and execution of MSG meetings, inconsistent MSG attendance by government and civil society and frequently inquorate MSG meetings. While the MSG has always respected its clear statutory decision-making rules in practice, the lack of quorum at most MSG meetings has weakened MSG members’ buy-in to key decisions related to designing, implementing, monitoring and evaluation of EITI implementation. This is particularly reflected in decisions related to the scope of EITI reporting (see Requirement 4.1), quality assurance (see Requirement 4.9) and annual progress reporting (see Requirement 7.4). The MSG does not have a practice of per diems. While MSG members generally have the capacity to carry out their duties, funding constraints have had a strong impact on the MSG’s capacity, given constrained secretarial support. However, the institutionalisation of EITI Madagascar through the August 2017 Decree and the renewal of MSG members in late 2017 are encouraging trends.

1.5Work plan

The work plan reflects MSG priorities for EITI implementation, is updated annually and is the product of consultations with key stakeholders. It includes time-bound, measurable and costed activities, taking into consideration funding and capacity constraints. The work plan includes specific activities to follow up on recommendations from EITI reporting. Delays in work plan implementation appear reasonable given funding constraints.

Licenses and contracts

2.2License allocations

EITI Madagascar has ensured disclosure of the process for awarding licenses and contracts pertaining to companies in the scope of the 2014 EITI Report. The latter comments on general non-trivial deviations from the 2011 moratorium and the efficiency of licensing procedures. However, the 2014 EITI Report does not clarify the nature of different license movements, leaving the process for transfer of license rights unclear, lacks clarity on the existence of technical and financial criteria and does not comment on the award of seven licenses in 2014. While there is a case for considering that the objective of transparency in license allocation and transfer is far from met, the prevailing lack of clarity related to the enforcement of the licensing freeze helps highlight the important impact of EITI reporting and the EITI- mandated studies as genuine diagnostic tools supporting debate over regulatory reform.

2.3License register

Madagascar disclosed the mandated information under Requirement 2.3 for oil and gas licenses in 2014 and commented on the existence of publicly available registers at the end of 2016. Gaps in information on mining licenses in the 2014 EITI Report were offset by the BCMM’s new online cadastre or accessibility upon request from BCMM.

2.4Policy on contract disclosure

While the 2014 EITI Report comments on the practice of contract disclosure, it does not clarify government policy, which remains unclear to stakeholders consulted.

2.1Legal framework

Madagascar has disclosed information on the legal framework and fiscal regimes governing the extractive industries, including a comprehensive description of the three co-existing mining legal frameworks and the degree of fiscal devolution. Tje 2014 EITI Report includes information on the roles and responsibilities of some government agencies, and information on the roles and responsibilities of relevant government entities is accessible through the EITI Madagascar website. The report also describes ongoing reforms.

2.5Beneficial ownership

Not assessed

The 2014 EITI Report does not clarify the government’s policy on beneficial ownership disclosure in the extractives sector. While it provides information on the legal owners of roughly half of the material companies, the identity of shareholders of companies incorporated in Madagascar are available from the Registry for Trade and Companies (RCS) website, albeit only for registered members at a fee.

2.6State participation

The 2014 EITI Report provides a list of state interests in the mining sector, although there is a lack of clarity amongst stakeholders over the comprehensiveness of the list provided. The Report does not describe the terms associated with state equity in extractives companies, nor any changes in state participation in the extractives sector in 2014. While the report provides a succinct description of financial relations between SOEs in practice in 2014, it does not describe the statutory financial relations between SOEs and the government. The report does confirm that there were no loans or guarantees provided to extractives companies in 2014.

Monitoring production

3.1Exploration data

The 2014 EITI Report provides an overview of the extractive sector, including exploration activities. In the International Secretariat’s view, Madagascar has also gone beyond the minimum requirements by providing additional information on ASM including on the value chain, license award and two detailed cases studies, as encouraged by the Standard and of high value to stakeholders.

3.2Production data

The 2014 EITI Report provides data on production volumes and values for most minerals, disaggregated by commodity and producing region. Missing figures for Kraoma’s production can be calculated based on export data (see Requirement 3.3). Although data is incomplete for dolomite, calcite and kaolin production, it is not material in the International Secretariat’s view. These minerals are destined for quarrying activities, which have been assessed as outside of the scope of the EITI in other instances by the EITI Board. The report confirms the lack of commercial oil production in 2014.

3.3Export data

The 2014 EITI Report provides export volumes and values for each commodity exported and producing region. While the export value of one company’s quartzite export is missing, the latter is a quarrying material and therefore not considered substantial in the International Secretariat’s view (see Requirement 3.2). This is also offset by extensive information provided on the country’s illicit exports of gold and precious stones. Madagascar has made remarkable efforts to compare existing data and highlight the loss in fiscal revenues.

Revenue collection

4.3Barter agreements

Not applicable

The 2014 EITI Report demonstrates that there were no barters or infrastructure provisions in force in 2014.

4.6Direct subnational payments

The 2014 EITI Report describes direct subnational payments, with one revenue stream specific to extractives activities. The lack of clarity around the beneficiaries of ristournes payments means that there is insufficient information in the report to assess the comprehensiveness of the reconciliation. There was consensus amongst stakeholders consulted that the reconciliation of direct subnational payments was not comprehensive. The lack of description of the unpaid Ambatovy ristournes in the 2014 EITI Report is also a concern given the value of these arrears and their importance for relevant subnational governments.


Reconciled financial data in the 2014 EITI Report is disaggregated by company and government entity, not by individual revenue stream. While this appears to have been an oversight, the lack of sufficiently disaggregated reconciled data has a material impact on assessments of the comprehensiveness of reporting (see Requirement 4.1).

4.9Data quality

The MSG has approved the selection of the IA for the 2014 EITI Report. The IA appears to have reviewed material entities’ statutory audit procedures prior to agreeing quality assurance procedures for ensuring the reliability of reconciled data in the 2014 EITI Report, and actual audit practices over the course of reporting. The 2014 EITI Report does not assess the materiality of payments from entities that did not comply with the agreed quality assurance procedures, although the IA’s assurances regarding the comprehensiveness and reliability of reconciled data are welcome. The IA has prepared summary tables of data in Madagascar’s 2014 EITI Report and added suggestions to its assessment of follow-up on past EITI recommendations.


The 2014 EITI Report includes the MSG’s rationale and definition of materiality thresholds for companies to be included in reconciliation based on payments to government. There is no evidence of the MSG having considered the materiality of revenue streams included in the scope of reconciliation, although the MSG appears to have consistently adopted a de-facto materiality threshold of zero for selecting material revenue streams. In addition, the 2014 EITI Report’s description of the approach to materiality for selecting companies is not sufficiently clear to ensure its accessibility to the average reader. The companies that did not report are named and the value of their payments to government is provided relative to government-reported revenues in aggregate, although not by non-reporting company. The share of non-reporting companies is deemed insignificant by the IA. While material government entities appear to have reported all revenues from 71 of the largest extractives companies, the lack of data on the remaining 70 companies and the lack of any data disaggregated by revenue stream is a concern. The report includes commentary from the IA on the comprehensiveness of the EITI Report.

4.2In-kind revenues

Not applicable

The 2014 EITI Report clearly states that the government did not collect any revenues in-kind in 2014.

4.4Transportation revenues

There is insufficient information to assess whether the government collects any revenues from the transportation of minerals, and no evidence of MSG discussion of the materiality of transportation revenues. While two port management companies were included in the scope of reporting as government entities, there is no explanation of their legal status nor the management of port-related fees they collect.

4.5SOE transactions

Not applicable

The 2014 EITI Report states that there were no financial transactions between extractives SOEs and the state and there is no evidence of dividend payments from QMM to OMNIS and from MCM to NASSCO. Stakeholder consultations confirmed the lack of payments from extractives companies to government entities and from KRAOMA to the government.

4.8Data timeliness

The 2014 EITI Report was published within two years of the end of the fiscal period under review, in December 2016, and the MSG agreed the reporting period.

Revenue allocation

5.1Distribution of revenues

The 2014 EITI Report states that Madagascar operates a single Treasury account where all extractives revenues are recorded, but there was consensus amongst stakeholders consulted that this was not the case. The lack of clarity on whether or not revenues collected by government entities are recorded in the national budget is a particular concern given public controversy over the role and status of Public Administrative Companies and the lack of publicly-available information on these entities’ finances.

5.2Subnational transfers

EITI Madagascar has included all transfers in the scope of its EITI reporting (see Requirement 4.1). The 2014 EITI Report describes the general revenue sharing formula for FAM, but there is insufficient information to identify discrepancies between budgeted and executed subnational transfers, disaggregated by LGU. Madagascar has disclosed the transfers of 2014 FAM executed in 2016. EITI Reports have been proven an effective diagnostic mechanism for delays in FAM transfers.

5.3Revenue management and expenditures

Not assessed

It is encouraging that Madagascar provided additional information on revenue management and expenditures.

Socio-economic contribution

6.1Mandatory social expenditures

The 2014 EITI Report presents information on companies’ mandatory social expenditures disaggregated by project and beneficiary. While the results are not presented disaggregated between cash and in-kind, the IA confirmed that all mandatory social expenditures are paid in-kind. Madagascar has also made efforts to go beyond the minimum requirements by providing additional information on discretionary social expenditures.

6.2Quasi-fiscal expenditures

While the 2014 EITI Report refers to the need to clarify the existence of quasi-fiscal expenditures linked to extractives revenues, there is no evidence that the MSG has undertaken efforts to clarify the existence of such expenditures in the year under review (2014). There is no evidence that the IA or MSG discussed this issue with relevant government entities and there is insufficient information in the public domain regarding this issue.

6.3Economic contribution

EITI reporting provides data on the extractive industries’ contribution to GDP, government revenues and employment, as well as an overview of extractives activities. While it only provides official estimates of exports in absolute terms, it is possible to calculate the relative share of total exports based on data provided.

Outcomes and impact

7.2Data accessibility

Not assessed

Madagascar’s EITI data was not publicly-available in machine readable format at the start of Validation, although EITI Madagascar had prepared draft summary data tables in line with Board guidance prior to September 2017. EITI Madagascar has published summaries of EITI Reports and made EITI information available in local languages.

7.4Outcomes and impact of implementation

The 2016 annual progress report reflects efforts to strengthen EITI implementation and provides information on progress in implementing EITI Requirements and work plan objectives. However, the report does not provide an assessment of the impact of the implementation of these objectives. There are also concerns that the annual progress report does not reflect the views of most stakeholders.

7.1Public debate

Madagascar has ensured that the EITI Report is comprehensible, actively promoted, publicly accessible and contributes to public debate. While there is little evidence of outreach and dissemination to communities in mining regions in the 2015-2017 period, the assessment of Requirement 7.1 must be taken in the context of broader funding challenges (see Requirement 1.5) and uneven engagement across different constituencies (see Requirement 1.4).

7.3Follow up on recommendations

Despite limited resources, the MSG has taken steps to act upon lessons learnt, including on causes of discrepancies, and consider recommendations resulting from EITI reporting. Despite the lack of institutionalised framework for follow-up on EITI recommendations, tangible government reforms have been enacted following for the latter.