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Madagascar has made meaningful progress in implementing the 2016 EITI Standard, with considerable improvements.

Outcome of the Validation of Madagascar.

Decision number
2020-30
Decision basis
EITI Articles of Association 2019-2021, Article 12.1. ix)
9 June 2020

Board decision

The Board came to the following decision:

The EITI Board agrees that Madagascar has fully addressed seven of the fifteen corrective actions from the country’s first Validation. Consequently, Madagascar has made meaningful progress overall in implementing the 2016 EITI Standard, with considerable improvements across several individual requirements.

The Board congratulates the Government of Madagascar and the multi-stakeholder group (MSG) for improving transparency in areas of public interest. The EITI has shed light on challenges resulting from the moratorium on the award of new mining licenses. Reporting and dissemination of findings related to subnational transfers of mining revenues to communities, including of largest mining projects Ambatovy and QIT Madagascar Minerals, remains a core strength of EITI implementation. In addition to catalysing the publication of financial statements of all state-owned enterprises (SOEs) and independent government agencies, Madagascar’s EITI reporting increases public understanding about complex transactions such as the creation of the Kraoma Mining joint-venture. The EITI is a key source of public information on extractive companies’ social expenditures and SOEs’ quasi-fiscal expenditures, and constitutes the only source of publicly available information on extractive companies’ beneficial and legal ownership data. The Board also acknowledges that Madagascar is establishing best practices amongst EITI implementing countries in reporting on environmental monitoring and gender-related issues in extractives, including gender-disaggregated employment data and promoting inclusive participation in debate at the local level. 

The Board recognises that gaps remain in disclosures related to issues such as license allocation and state participation and urges the government to take concrete steps towards contract transparency ahead of the 1 January 2021 deadline established in the 2019 EITI Standard. Further efforts should be made to ensure that significant improvements in disclosures are matched by efforts to strengthen the multi-stakeholder nature of EITI implementation and the sustainability of the process. The Board encourages the MSG to ensure that the broader government and civil society constituencies participate actively in all aspects of implementation, This will enable the EITI to contribute to the government’s domestic resource mobilisation and anticorruption programmes and to a broader public understanding of the extractive industries.

The Board takes note of Madagascar’s plans to transition to systematic disclosures through government and company systems. There is scope for EITI Madagascar to build on its close collaboration with key government entities to ensure systematic disclosures of licensing data, subnational transfers of mining administration fees, and extractives production and export data, and to draw from the industry constituency’s strong engagement to enable systematic disclosures of payments data and audited financial statements. Progress on systematic disclosures would enable the MSG to focus on the use and analysis of EITI data.

The Board has determined that Madagascar will have 18 months before a third Validation, i.e. until 9 December 2021, to carry out corrective actions regarding government engagement (Requirement 1.1), civil society engagement (Requirement 1.3), MSG oversight (Requirement 1.4), license allocations (Requirement 2.2), contract disclosure (Requirement 2.4), state participation (Requirement 2.6), data disaggregation (Requirement 4.7), and subnational transfers (Requirement 5.2).

Failure to achieve satisfactory progress in the third Validation will result in temporary suspension in accordance with Article 6 of 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.

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 third Validation commencing on 9 December 2021:

  1. In accordance with Requirement 1.1.c, the government must demonstrate full, active and effective engagement in all aspects of EITI implementation in Madagascar. The government should contribute to the functioning of the national secretariat, as well as other EITI activities as per the MSG’s work plan, through sustainable funding. The government should ensure that all its representatives are nominated on the MSG and participate actively to all aspects of EITI implementation, including through increasing awareness amongst relevant government agencies. To strengthen implementation, the government is encouraged to draw on the EITI Madagascar platform for multi-stakeholder consultations in the development of key legal and regulatory reforms, such as the revision of the Mining Code. The government may also wish to leverage the EITI platform to sustain direct dialogue with industry, civil society and partners around the management of the sector and the latter’s contribution to government revenues. The government is encouraged to draw on strategic recommendations from Validation related to Requirements 2-6 to transition towards systematic disclosures of data required by the EITI Standard through routine government systems in a timely, reliable and disaggregated manner.

  2. In accordance with Requirement 1.3.a, civil society must demonstrate full, active and effective engagement in all aspects of EITI implementation, including outreach to civil society organisations outside the capital city and dissemination of EITI findings. Civil society should ensure that all its representatives are nominated on the MSG and participate actively to all aspects of EITI implementation. Civil society representatives should ensure that they undertake effective fundraising activities to ensure adequate technical and financial capacities for their full, active and effective participation in EITI activities. All stakeholders, including development partners, are encouraged to ensure that representatives of the civil society constituency benefit from available capacity-building on EITI-related issues. To strengthen implementation, civil society is encouraged to consistently document activities undertaken by CSOs in communities affected by extractive activities. Civil society is strongly encouraged to capitalise on the EITI Madagascar multi-stakeholder consultation infrastructure, including MSG meetings and consultations with communities affected by extractive activities, to discuss issues around the management of the extractive industries of high public interest. Civil society may wish to leverage new provisions under Requirements 6.1 and 6.4 in the 2019 EITI Standard on the environmental impact of extractive activities to ensure greater transparency around environmental payments by companies, industry practices related to environmental management and the role and activities of relevant government agencies.

  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, to ensure that MSG members have the capacities to carry out their duties. In accordance with Requirement 1.4.b.viii, the MSG must keep written records of its discussions and decisions. To strengthen implementation, the MSG is encouraged to make these records publicly available on its website. The MSG might wish to ensure that its meetings are planned in advance, held at a reasonable frequency and address key issues in the oversight of EITI implementation. The MSG is encouraged to ensure that deviations from their Terms of Reference are recorded and transparent. Government and civil society 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. Company representatives might wish to consider reviewing the positions representing the oil and gas sub-constituency on the MSG to ensure that they reflect the industry.

  4. In accordance with Requirement 2.2, Madagascar should disclose information on the statutory process for transferring licenses in the oil and gas sector, as well as an assessment on potential non-trivial deviations in practice in the transfer of both oil and gas and mining licenses. Madagascar might wish to prioritise systematically disclosing such information through the OMNIS and BCMM websites. To strengthen implementation, Madagascar might wish to draw from EITI reporting and recommendations to improve the management of mining licenses, including in setting standard, clear and publicly available technical and financial criteria in the award and transfer of licenses. The MSG is encouraged to consider the findings and conclusions of the upcoming Transparency International study on corruption risks in licensing to formulate recommendations to address such risks.

  5. In accordance with Requirement 2.4, Madagascar should clarify and document the government’s policy on disclosure of contracts and licenses. To strengthen implementation, Madagascar is encouraged to disclose the full text of all extractive contracts and licenses. The government may wish to include contract disclosure provisions in its review of sector legislation and companies operating in Madagascar are encouraged to adhere to the EITI supporting companies’ expectations in demonstrating support for contract disclosure. In line with the 2019 EITI Standard and particularly given the lack of clarity of the government’s policy, the MSG is expected to include plans for disclosing contracts with a clear timeframe for implementation in its work plan, ahead of the 1 January 2021 deadline. Madagascar might wish to systematically disclose the full text of mining licenses through the BCMM register, including the decree awarding and transferring licenses and the terms and conditions (“cahier de charges”) to which companies subscribe, as well as the full text of oil and gas PSCs on the OMNIS website.

  6. Madagascar should agree a definition of SOE for EITI reporting purposes that is in line with the definition in Requirement 2.6.a.i, namely “a wholly or majority government-owned company that is engaged in extractive activities on behalf of the government.” In accordance with Requirement 2.6.a.ii, Madagascar should ensure that a comprehensive description of the terms associated with state participation in the extractive industries is publicly accessible on an annual basis, including equity interests held by SOEs’ subsidiaries, joint ventures and affiliates. To strengthen implementation, Madagascar could consider ways of systematically disclosing information on the statutory financial relations between KRAOMA, OMNIS and the state, by publishing the SOEs’ statutes and all other relevant laws, regulations and decrees codifying the financial relations between extractives SOEs and the state. Madagascar is encouraged to explore ways of systematically disclosing information on the financial relations in practice between extractives SOEs (KRAOMA and OMNIS) and the state, for instance through routine publication of their audited financial statements on their respective websites, with additional narrative describing each SOE’s practices of distributing profits, retaining earnings, reinvesting in their operations and third-party financing in accordance with Requirement 2.6.a.i. Madagascar may wish to ensure that a description of any changes in state participation be systematically disclosed through government and SOE systems annually, including the terms of each transaction.

  7. In accordance with Requirement 4.7, Madagascar should ensure that it publishes EITI data disaggregated by each individual project, for impositions that are levied at a per-license basis (e.g. non-tax). Madagascar is required to ensure that its definition of project is consistent with that in Requirement 4.7, namely that as “operational activities that are governed by a single contract, license, lease, concession or similar legal agreement, and form the basis for payment liabilities with a government.”

  8. In accordance with Requirement 5.2, Madagascar should disclose discrepancies between statutory shares of mining administration fees (FAM) and ristournes and effective transfers disaggregated by local government unit, for all extractive companies. To strengthen implementation, Madagascar might wish to consider systematically disclosing information about subnational transfers of FAM on the BCMM website, including the decrees that determine the computations for transfers to each local government unit. Stakeholders are encouraged to use EITI data on subnational transfers to promote debate at the subnational level and strengthen the management of extractive revenues by local authorities, to ensure the sector’s contribution to more inclusive and sustainable local development. 

Madagacar is encouraged to also consider the strategic recommendations in the Secretariat’s assessment.

Background

Madagascar joined the EITI in 2008. On 29 June 2018, Madagascar was found to have made meaningful progress in implementing the 2016 EITI Standard. Madagascar’s second Validation against 2016 EITI Standard commenced on 29 December 2019. The EITI International Secretariat has assessed the progress made in addressing the 15 corrective actions established by the EITI Board following Madagascar’s first Validation. The corrective actions are related to:

  1. Government engagement (Requirement 1.1)
  2. Civil society engagement (Requirement 1.3)
  3. MSG governance (Requirement 1.4)
  4. License allocations (Requirement 2.2)
  5. Contract disclosure (Requirement 2.4) 
  6. State participation (Requirement 2.6)
  7. Data comprehensiveness (Requirement 4.1)
  8. Transportation revenues (Requirement 4.4)
  9. Direct subnational payments (Requirement 4.6)
  10. Data disaggregation (Requirement 4.7) 
  11. Data quality and assurance (Requirement 4.9)
  12. Distribution of extractive industry revenues (Requirement 5.1)
  13. Subnational transfers (Requirement 5.2)
  14. Quasi-fiscal expenditures (Requirement 6.2)
  15. Outcomes and impact of implementation (Requirement 7.4).

The Board asked Madagascar to address these corrective actions to be assessed in the second Validation. Madagascar has undertaken a number of activities to address the corrective actions:

  • The publication of the 2015, 2016, 2017 and 2018 EITI Reports over the span of 18 months;
  • The publication in 2018 of thematic reports on, respectively, the impact of a decade of EITI implementation, subnational payments and transfers, and beneficial ownership disclosures;
  • The publication in 2018 of guides to help citizens, companies and parliamentarians read EITI Reports and use EITI data;
  • The signature of a memorandum of understanding in December 2018 between the EITI Madagascar and the Supreme Audit Institution, la Cour des Comptes, for the certification of government data disclosed through the EITI;
  • Several capacity building and consultation workshops with MSG members, government, company and CSO representatives, including in March 2019 on the 2017-2018 Annual Progress Report;
  • Outreach and dissemination in Fort Dauphin, Toliara, Moramanga and Tamatave, regions affected by extractive activities, in May and June 2019, to share findings from EITI reporting on revenue allocation and management at the local level;
  • The adoption of action plans to strengthen engagement in the EITI process by the government and civil society constituencies in 2019;
  • The publication of the audited financial statements of OMNIS, BCMM and ANOR for the fiscal years 2017-2018, for the first time.

Madagascar’s second Validation commenced on 29 December 2019. The Secretariat assessed the progress made in addressing the 15 corrective actions established by the EITI Board. Subject to the EITI Board's consideration of new information published after the commencement of Validation (in particular related to Requirements 4.9 and 6.2), the EITI International Secretariat’s assessment is that Madagascar has fully addressed seven of the 15 corrective actions and has achieved “satisfactory progress” on the corresponding requirements.

The draft assessment was sent to the MSG on 19 March 2020. Following MSG comments received on 22 April 2020, the assessment was finalised for consideration by the EITI Board. The Validation Committee reviewed the case on 20 May 2020 and agreed the recommendation.

Scorecard for Madagascar: 2020

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 shown encouraging signs of its commitment to the EITI. Nevertheless, statements of support at the high-level have not consistently been matched by concrete efforts to support all aspect of EITI implementation at the operation level since June 2018, as evidenced by uneven awareness of the EITI by different agencies represented on the MSG, limited support to the funding and sustainability of the process in the period under review, limited activities to follow-up on recommendations from EITI reporting and delayed nomination of government representatives on the MSG in 2019.

1.2Industry 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

Both publicly available evidence and stakeholder consultations point to a positive tendency in civil society’s engagement in EITI implementation. At least two civil society representatives contribute actively and regularly to the process, and civil society organisations had participated in several capacity-building and outreach activities in the period under review. There are several examples of advocacy and policy recommendations issued by civil society organisations on key developments of the sector. Nonetheless, their engagement remains affected by limited capacity and resources, the lack of participation from a majority of representatives on the MSG and the challenges in securing nominations for vacant seats on the MSG, which reflect gaps in the broader constituency’s engagement. Uneven engagement of the broader civil society constituency has led to the duties and responsibilities of actively participating in all aspects of EITI implementation being placed on two civil society stakeholders, thereby exacerbating the constituency’s capacity constraints. In addition, the International Secretariat did not find evidence indicating any backsliding on adherence to the Civil Society Protocol, as confirmed in stakeholder consultations.

1.4MSG governance

Based on available documentation and stakeholder views, meetings were not consistently announced in a timely manner in the period under review, nor were MSG discussions and decisions regularly recorded. There was consensus that deviations in practice from MSG TORs were due to significant funding and capacity challenges that prevented the national secretariat from providing administrative support to the MSG. Stakeholders consulted also raised concerns around the representative nature of MSG members for the oil and gas sub-constituency and noted challenges in securing nominations for vacant CSO seats.

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

2.1Legal 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.

2.2License allocations

EITI reporting has been instrumental in identifying the award and transfers of licenses in the mining sector in the context of the ongoing moratorium, a priority issue for the management of the sector in Madagascar. With regards to technical and financial criteria, EITI reporting contributed meaningfully to public debate by highlighting the absence of such criteria in awarding and transferring licenses in the mining sector. While EITI reporting has been key in identifying inefficiencies in the management of licenses in the extractive sector, some gaps in disclosures related to license transfers remain. The 2018 EITI Report does not comment on the statutory process for transferring oil and gas licenses, nor does it comment on potential non-trivial deviations in practice in the transfer of licenses, both in the mining and oil and gas sectors.

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

The MSG should be commended for its efforts in clarifying the government’s policy and prompting the oil and gas company association APPAM to state its support for contract disclosure. EITI reporting allowed to document the practice in contract disclosure and identify gaps, including highlighting that the disclosure of the profit oil split was considered particularly sensitive. Despite this, the government’s policy remains unclear. Stakeholder consultations confirmed challenges in contract disclosure, both from the government’s and the industry’s perspectives.

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 2018 EITI Report correctly defines KRAOMA as a SOE, but explicitly omits OMNIS as a SOE despite the latter’s representation of the state in oil and gas contracts and as owner of equity in several mining companies. The report describes the rules and practices related to the financial relations between both KRAOMA and OMNIS and the government, including those related to distribution of profits, retained earnings, reinvestments and third-party financing. It presents a comprehensive list of state participations in the mining, oil and gas sectors, but does not consistently describe the terms associated with the SOEs’ equity in these extractives companies. One change in state participation in 2018, the creation of KRAOMA MINING JV, is described, including the terms of the transaction. The report only confirms the lack of loans from government and SOEs to extractives companies, but does not comment on the existence of any guarantees. There was consensus however among stakeholders consulted that there were no guarantees to extractives companies in 2018.

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

4.1Comprehensiveness

The 2018 EITI report addresses most aspects of Requirement 4.1, aside from full unilateral government disclosure of revenues, for each of the material revenue streams, from all mining, oil and gas companies, including those below the materiality threshold. Despite the MSG’s convoluted approach to selecting material companies, the approach ensured that all companies making more than USD 125,000 in payments to government were included in the scope of reporting. The report provides full government unilateral disclosures of extractives revenues for all revenue streams for the 70 largest companies. It provides full disclosure of revenues from oil and gas companies and of administrative fee (FA) payments from mining companies. The Secretariat’s assessment is that the 2018 EITI Report is transparent about practical challenges to sourcing comprehensive non-tax information from companies beyond the 70 and thus considers this gap to be of marginal importance.

4.2In-kind revenues

Not applicable

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

4.3Barter agreements

Not applicable

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

4.4Transportation revenues

The 2018 EITI Report demonstrates that the government and SOEs do not receive revenues from the transportation of extractives commodities. Nonetheless, the report reflects efforts to go beyond the minimum requirement by describing the different private transportation arrangements for extractives commodities and reconciling company payments for the use of port infrastructure.

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.

4.6Direct subnational payments

Not applicable

The 2018 EITI Report clarified the absence of material subnational payments in the extractive sector. It confirmed that no “ristournes” were paid directly to local governments by material companies in the period under review, as confirmed by stakeholder consultations.

4.7Disaggregation

The 2018 EITI Report documents the MSG’s approach to project-level reporting, although this is based on a per-mine rather than per-license basis. The reconciled financial data is de facto disaggregated by license for only six of the 17 material companies.

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.

4.9Data quality

There is evidence that the MSG approved the ToR for its Independent Administrator in line with the template, oversaw procurement of the IA for the 2018 EITI Report and approved the reporting templates. Summary data for the 2017 and 2018 EITI Reports were submitted to the International Secretariat for comments in December 2019. The 2018 EITI Report covers most aspects of Requirement 4.9, aside from a statement by the IA on the comprehensiveness and reliability of the reconciled financial data. However, after the start of Validation, EITI Madagascar published an addendum to the 2018 EITI Report that included the IA’s assessment that it did not uncover any elements that would put into question the comprehensiveness and reliability of reconciled financial data in the report.

Revenue allocation

5.1Distribution of revenues

The 2018 EITI Report clearly lists and provides the value of extractives revenues not recorded in the national budget. While it provides only a cursory explanation of their management, the publication of the audited financial statements of BCMM, OMNIS, ANOR and KRAOMA for 2017 and 2018 provides information on the management of these off-budget revenues, even if these have not been analysed in detail to date.

5.2Subnational transfers

Madagascar EITI’s work on subnational transfers is commendable as an example of EITI implementation’s meaningful contribution to public debate on an issue of national priority. The 2018 EITI Report not only includes detailed information about the disbursement of Ambatovy’s ristournes, it also provides an assessment of challenges in the effective transfer of extractive revenues and information about revenue management at the local level. However, EITI reporting has not provided data disaggregated by local government unit on statutory shares VS effective transfers, both for FAM and for ristournes paid by all extractive companies except for Ambatovy, as well as QMM after the start of Validation.

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

There is evidence that the MSG has considered quasi-fiscal expenditures since the first Validation. While the 2018 EITI Report correctly categorises two types of quasi-fiscal expenditures by OMNIS in the year under review, it provides insufficient information on the nature of the second expenditure. However, after the start of Validation (in February 2020), the OMNIS website published disaggregated information on its quasi-fiscal expenditures in 2018, achieving a level of transparency commensurate with other payments and revenue streams.

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

7.1Public 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).

7.2Data 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.

7.3Follow 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.

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.