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Togo has made meaningful progress with considerable improvements in implementing the 2016 Standard.

Outcome of the Validation of Togo.

Decision reference
2020-66 / BC- 295
Decision basis
EITI Articles of Association 2019-2021, Article 12.1. ix)

Board decision

The Board came to the following decision regarding the Validation of Togo:

The EITI Board agrees that Togo has fully addressed five of the seven corrective actions from the country’s first Validation. Consequently, Togo has made meaningful progress overall with implementing the EITI Standard, with considerable improvements across the remaining two individual requirements. 

The Board recognises Togo’s efforts to use the EITI to as a driving force for reforms in the mining sector with the revisions to the Transparency Code and the Mining Sector Governance Development Project, in the context of broader regional public financial management reforms. The Board takes note of the MSG’s efforts in using the EITI to improve transparency in the marketing of precious minerals, mineral transportation, and groundwater exploitation.  

The Board congratulates Togo for its efforts to enhance transparency of the two state-owned companies (SOEs) in the extractive sector, the Societe Nouvelle des Phosphates du Togo (SNPT) and la Société Togolaise des Eaux (TdE), by providing more information on the financial relationship between the state and SOEs, including the publication of SNPT’s audited financial statements. The Board encourages Togo to consider ways of systematically disclosing the rules and practices related to state participation in the extractive industries within routine government systems.  

The Board welcomes Togo’s expansion of EITI disclosures to subnational transfers of non-extractive revenues in light of robust popular demand for greater clarity on subnational revenue flows, effectively using EITI reporting to improve transparency and accountability in public financial management.  

The Board encourages Togo to further strengthen the multi-stakeholder oversight of EITI implementation, including by clarifying the rules and procedures related to all constituencies’ representation on the EITI Steering Committee. Each constituency is urged to consider gender balance in their representation to progress towards gender parity. The Board encourages the Government of Togo to review the Decree institutionalising the EITI to ensure it reflects the evolution of the EITI Standard and is sufficiently flexible to cover systematic disclosures of EITI data through routine government and company systems.  

The Board recognises the efforts of the tax office (Office Togolais de Revenues) to mainstream disclosures of extractive revenue data collaboration. Togo is encouraged to use EITI reporting as a means of strengthening systematic disclosures of information on licenses, contracts and the implementation of barter-type agreements. 

The Board recognises the government’s efforts to ensure the publication of extractive contracts and encourages the MSG to assess the comprehensiveness of contract disclosure practices to date and explore opportunities for collating all mining contracts in a single repository to facilitate access to key stakeholders. 

The Board has determined that Togo will have 12 months, i.e. until 11 September 2021 before a third Validation to carry out corrective actions regarding MSG oversight (1.4) and workplan (1.5).  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, Togo’s Multi-Stakeholder Group (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 Togo. Progress in addressing these corrective actions will be assessed in a third Validation commencing on 11 September 2021

  1. In accordance with Requirement 1.4, Togo should ensure that the procedures for nominating and replacing multi-stakeholder group representatives are public and implemented in a fair, open and transparent way. In particular, the industry constituency should elaborate and publish clear nominations and representation guidelines through establishing internal regulations or terms of reference. The MSG may also wish to build capacities of civil society groups to ensure active participation in technical aspects of EITI Implementation. In anticipation of their work on systematic disclosures, the MSG is encouraged to carry out capacity building activities for its members to ensure that they provide effective oversight of all aspects of EITI disclosures in the transition to systematic disclosures, which requires revision to Article 20 of 2010 Decree creating the Togo EITI, which places the responsibility of extractives data collection on the Independent Administrator.  The MSG should ensure they share responsibility for ensuring disclosures of EITI data.  

  2. In accordance with Requirement 1.5, Togo should ensure that national priorities are clearly identified and linked to clear objectives of EITI Implementation beyond reporting. The MSG should also ensure that ongoing activities towards  reforms in key areas such as contract transparency and systematic disclosures are included in the work plan. The MSG is encouraged to include plans to address legal and regulatory obstacles to implementation, as well as capacity-building activities to ensure effective oversight of the EITI process Togo is encouraged to strengthen processes for constituency coordination on the development of the EITI work plan and ensure that the broader government, industry, and civil society constituencies are consulted on future updates of the work plans. Togo may wish to publish more regular updates on work plan execution to reflect the detail with which the MSG and secretariat track implementation. This could further support the MSG’s efforts to reach out to prospective donors to support specific work plan activities.  


Togo was accepted as an EITI Candidate in October 2010. The first Validation of Togo against the EITI Standard commenced on 1 April 2017. On 9 May 2018, the EITI Board found that Togo had made meaningful progress in implementing the 2016 EITI Standard. Seven corrective actions were identified by the Board, pertaining to the following requirements: 

  1. Multi-Stakeholder Group (MSG) governance (Requirement 1.4) 
  2. Workplan (Requirement 1.5) 
  3. Policy on contract disclosure (Requirement 2.4) 
  4. State participation (Requirement 2.6) 
  5. Barter agreements (Requirement 4.3) 
  6. SOE transactions (Requirement 4.5) 
  7. Subnational transfers (Requirement 5.2).  

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

  • Publishing its 2017 EITI Report on 7 November 2019 
  • Adopting a revised EITI Decree on 11 July 2017 
  • Publishing the updated MSG Terms of Reference (ToR) in October 2019 
  • Publishing the 2020 Togo EITI work plan in April 2019 
  • Publishing  a self-evaluation report in November 2019 
  • Publishing its 2017 Annual Progress Report in March 2019 
  • Undergoing a renewal of the MSG in October 2019 

Togo’s second Validation commenced on 8 November 2019. The Secretariat assessed the progress made in addressing the seven corrective actions established by the EITI Board. The EITI International Secretariat’s assessment is that Togo has fully addressed five of the seven corrective actions, with significant improvements on the two outstanding requirements.  

Scorecard for Togo: 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

Government stakeholders appear fully, actively and effectively engaged in all aspects of EITI implementation, including scoping, reporting, dissemination and outreach.

1.2Company engagement

Mining and water companies are actively and effectively engaged in the EITI process as providers of information. In the absence of Chamber of Mines, the professional association of extractive industries in Togo (APIET) aims to fill this void. Despite challenges linked to land ownership, companies did not express any real barriers to operations in Togo.

1.3Civil society engagement

Civil society seems to be able to speak freely despite rare cases of repression, not directly linked to the EITI. Although civil society is fragmented across over 5,000 associations and NGOs, the efforts of MSG members to disseminate information to civil society through the print media are acknowledged.

1.4MSG governance

The Government and the MSG made significant efforts to ensure a renewal of MSG members in practice. There was a renewal of all members of the civil society and industry constituencies, and consultations show that the nomination and election processes were carried out in an open, fair, transparent and inclusive way. There have also been efforts made by the civil society and government constituencies to clarify and document nominations and renewal procedures. The official decree approving the new MSG members was published after the start of Validation. However, constituency terms of reference for the industry constituency are yet to be published.

1.5Work plan

The MSG approved an update to the triannual work plan, which includes activities geared towards the scope of EITI Reporting. The work plan is publicly available and reflects some national objectives although these are mostly geared towards EITI Reporting. There is evidence that the MSG canvassed broadly in the preparation of the work plan. Togo should ensure that national priorities are clearly identified and linked to clear objectives of EITI Implementation beyond reporting. The MSG should also ensure that ongoing activities towards reforms in key areas such as contract transparency and systematic disclosures are included in the work plan. The MSG is encouraged to include plans to address legal and regulatory obstacles to implementation, as well as capacity-building activities to ensure effective oversight of the EITI process.

Licenses and contracts

2.2License allocations

The EITI 2014 Report indicates the process for awarding or transferring the license(s), and gives information on the award of licenses. Information on transfers were included in the stakeholder consultations. There was no evidence of competitive bidding in 2014.

2.3License register

The 2014 EITI Report includes the names of licence holders and date of award and expiry for all the licenses. Further information on the dates of application and coordinates for all licenses is on the Ministry of Mines' website.

2.4Policy on contract disclosure

The MSG has documented the government’s policy on contract disclosure, which is in favour of the contract publication. Mining contracts are published on several online sites. The EITI Report lists information on contracts entered into for the year under review but does not clearly list which contracts and licenses have been published in full. The MSG is encouraged to include in its work plan detailed activities towards comprehensive contract disclosures, and assess the comprehensiveness and exhaustivity of contract disclosures

2.1Legal framework

The 2014 EITI Report includes a summary description of the fiscal regime, including gaps in the legislation. The report covers the level of fiscal devolution, an overview of the relevant laws and regulations, and information on the roles and responsibilities of the relevant government agencies. The report also includes information about reforms underway.

2.5Beneficial ownership

Not assessed

The MSG has agreed and applied its definition of BO for EITI reporting and made attempts to disclose the beneficial owners of material companies reporting in EITI Reports. The latest EITI Report lists physical persons as beneficial owners for five companies. However, the EITI Report has not clarified the government’s beneficial ownership policy. The list of legal owners is not comprehensive in the 2014 EITI Report. The MSG established a BO working group to steer preparations of Togo’s three-year roadmap by 1 January 2017.

2.6State participation

The 2017 EITI Report provides relevant information on the prevailing rules and practices regarding the financial relationship between the government and SOEs and discloses dividend payments from the government’s 10% free carry. The report clarifies the rules for retained earnings, reinvestment and third-party financing for the SOEs in the country. The SOE SNPT also published its audited financial statements and statutes, which provide an explanation of the statutory rules and practices governing transfers of funds between the SOEs and the state.

Monitoring production

3.1Exploration data

The EITI Report gives an overview of the extractive sector, including on exploration activities.

3.2Production data

Togo has no official comprehensive statistics on production. To address this gap, the MSG requested that participating companies and government agencies provide production data, which is reconciled in the EITI Report. While there are some gaps and concerns about data quality, the issues are addressed transparently in the report.

3.3Export data

Togo has no official comprehensive statistics on exports. To address this gap, the MSG requested that participating companies and government agencies provide export data, which is reconciled in the EITI Report. While there are some gaps and concerns about data quality, the issues are addressed transparently in the report.

Revenue collection

4.3Barter agreements

The 2017 EITI Report includes a detailed description of three barter-type agreements between the government and a public works company (SNCTPC), involving the development of public infrastructure (roads) in exchange for tax rebates and quarrying rights.

4.6Direct subnational payments

The 2014 EITI Report discloses payments by companies and receipts by local government units. Where possible, these flows are also reconciled. This process could be better detailed in EITI Reports.


In accordance with Requirement 4.7 of the 2016 EITI Standard, the 2014 EITI Report notes that data was reported by company, by revenue streams and by reporting public entities.

4.9Data quality

The IA and the MSG agreed ToRs to produce the EITI Report consistent with the standard ToRs and agreed upon procedures issued by the EITI Board, and applied this ToRs and procedures in practice. The report provides a clear statement from the Independent Administrator on the reliability of the (financial) data presented, including a summary of the work performed by the Independent Administrator and the limitations of the assessment provided.


The MSG has considered and agreed an approach to materiality and ensured that all material revenue streams are included in the scope of the 2014 EITI Report. The report includes a reconciliation of 97% of government revenues and company payments. The government has also disclosed total revenues received from each company.

4.2In-kind revenues

Not applicable

The EITI Report and stakeholder views have confirmed the absence of in-kind revenues as per requirement 4.2. of the EITI Standard.

4.4Transportation revenues

Not applicable

The report includes a description of the transport agreements including transportation of minerals by rail. The report states that payment of transport-specific taxes amounted to zero in fiscal 2014.

4.5SOE transactions

The 2017 EITI Report confirms the lack of material transactions between companies and SNPT and the non-existence of ad hoc transaction between the government and SNPT.

4.8Data timeliness

Data covering financial year 2014 was published by the end of 2016, in accordance with the EITI’s timeliness requirements.

Revenue allocation

5.1Distribution of revenues

The 2014 EITI Report notes that in Togo all mining taxes are collected by the financial authorities and allocated to the state budget, except for royalties, registration fees and specific fixed duties paid to the DGMG. The MGS did not discuss possible mechanisms that could be put in place to establish the traceability of extractive sector revenues.

5.2Subnational transfers

The 2017 EITI Report discloses the revenue sharing formula, as well as the revenues transferred by the Tax Department (“Commissariat des Impôts”) to the Treasury (DGTCP). Additionally, as the “ristournes” are not extractive-specific, the IA calculated the extractive-specific share of extractive companies in the subnational transfers. Transfers from the Treasury (DGTCP) to local governments could only be partially reconciled, as only four of the 15 local governments submitted reporting templates. Reforms are currently ongoing to strengthen the organisation of the municipalities and will potentially allow for a more detailed reconciliation in the future exercise.

5.3Revenue management and expenditures

Not assessed

It is encouraging that the MSG has made some attempt to including information on the budget-making process and audit processes the EITI Report.

Socio-economic contribution

6.1Mandatory social expenditures

The 2014 EITI Report discloses the nature and value of discretionary social expenditures, including identifying the beneficiaries.

6.2Quasi-fiscal expenditures

Not applicable

Stakeholder consultations have confirmed that quasi-fiscal expenditures do not occur in the extractive sector in Togo.

6.3Economic contribution

The 2014 EITI Report discloses details about the contribution of the extractive sector to the economy in terms of GDP, total government revenue, exports and producing regions. Togo has no official comprehensive statistics on employment in the sector. To address this gap, the MSG requested that participating companies and government agencies provide employment data. While there are some gaps and concerns about data quality, the issues are addressed transparently in the report.

Outcomes and impact

7.2Data accessibility

Not assessed

EITI-Togo has published data in machine-readable format and summaries of EITI Reports in accessible infographic format.

7.4Outcomes and impact of implementation

The Steering Committee used annual progress reports and Validation self-assessments to document the impact of the EITI. These assessments could be done in a more systematic manner.

7.1Public debate

The EITI Reports are comprehensible, actively promoted through varied channels, publicly accessible and have tangibly contributed to public debate on the extractive industries.

7.3Follow up on recommendations

The MSG and the government have taken steps to act upon EITI recommendations which have positively impacted mining revenue governance in Togo.