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The Board agreed that Mali has made meaningful progress with considerable improvements in implementing the 2016 EITI Standard.

Outcome of the Validation of Mali.

Decision reference
2019-47 / BM-43
Decision basis
EITI Articles of Association 2019-2021, Article 12.1. ix)

Board decision

Following the conclusion of Mali’s second Validation on 17 June 2019, the EITI Board concluded that Mali has made meaningful progress overall in implementing the EITI Standard, with considerable improvements across individual requirements.

The EITI Board agreed that Mali has partly addressed the corrective actions from the country’s first Validation. Consequently, Mali has made meaningful progress overall with implementing the EITI Standard, with considerable improvements across several individual requirements.

The Board recognised Mali’s efforts to use the EITI to as an annual diagnostic of government systems in challenging circumstances linked to country’s political and security fragility. Mali’s EITI implementation was recognised as having led to tangible reforms in the country’s public financial management, tax administration and tax policy.

The Board noted that, while the EITI’s requirement on subnational transfers is not applicable to Mali in the years under review, stakeholders have gone beyond the EITI Requirements in using EITI reporting as a means of ensuring greater transparency and accountability in the public financial management of extractives revenues, particularly with the redistribution of taxes to local governments, to meet robust popular demand for this information.

While recognising improvements in the multi-stakeholder group’s (MSG) oversight of implementation, the Board encouraged Mali to strengthen the accountability of MSG representatives to their respective constituencies. Mali is also encouraged to strengthen its use of EITI as a diagnostic of license allocations and transfers, while adopting a more systematic approach to following up on recommendations and assessing impact. The Board encouraged Mali to explore opportunities to improve government and company disclosures through systematic disclosures of data required under the EITI Standard.

The Board has determined that Mali will have 12 months, i.e. until 17 June 2020 before a third Validation to carry out corrective actions regarding MSG oversight (1.4), license allocations (2.2), discrepancies and recommendations from EITI Reports (7.3), outcomes and impact of EITI implementation (7.4).  Failure to achieve satisfactory progress in the Third Validation will result in suspension in accordance with the EITI Standard. In accordance with the EITI Standard, Mali’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 Mali. Progress in addressing these corrective actions will be assessed in a thrid Validation commencing on 17 June 2020:

  1. In accordance with Requirement 1.4, Mali should ensure that the procedures for nominating and changing EITI multi-stakeholder group representatives are public and implemented in practice. Mali is encouraged to ensure that effective outreach activities are undertaken with civil society groups and companies, including through communication such as media, website and letters, informing stakeholders of the government’s commitment to implement the EITI, and the central role of companies and civil society. Members of the MSG are strongly encouraged to liaise with their constituency groups on a regular basis, and to consult broadly on EITI documents, including the annual progress report, the work plan, and the EITI Report.

  2. In accordance with Requirement 2.2.a, Mali should ensure that the awards and transfers of mining, oil, and gas licenses during the year are publicly disclosed annually, highlighting the process for awarding and transferring licenses, including technical and financial criteria, and any non-trivial deviations from the applicable legal and regulatory framework governing license awards and transfers.

  3. In accordance with Requirement 7.3, Mali should introduce a systematic and structured mechanism to track follow-up on recommendations from EITI Reports and from Validation, with a clear timeframe and clear responsibilities for follow-up. Mali should also take a more proactive role in formulating its own recommendations. Mali should ensure that the next annual progress report and EITI Report provide a detailed summary of progress in implementing recommendations from EITI Reports and Validation.

  4. In accordance with Requirement 7.4.a.iv, Mali should include an assessment of progress with achieving the objectives set out in its work plan, including the impact and outcomes of the stated objectives. Mali may wish to conduct a dedicated assessment of the impact of EITI implementation in Mali.


Mali was admitted as an EITI Candidate in September 2007.  The first Validation of Mali commenced on 1 July 2016. On 24 May 2017, the EITI Board found that Mali had made meaningful progress in implementing the 2016 EITI Standard. Nine corrective actions were established by the EITI Board, pertaining to the following requirements:

  1. MSG governance (Requirement 1.4)

  2. Workplan (Requirement 1.5)

  3. Licence allocation and licence registers (Requirements 2.2 and 2.3)

  4. Comprehensiveness (Requirement 4.1)

  5. Data quality (Requirement 4.9)

  6. Subnational transfers (Requirement 5.2)

  7. Public Debate (Requirement 7.1)

  8. Follow up on Recommendations (Requirement 7.3)

  9. Review of outcomes and impact (Requirement 7.4).

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

  • Publishing its 2017 Annual Progress Report on 31 July 2018;

  • Publishing its 2016 EITI Report on 31 December 2018;

  • Adopting a revised EITI Decree on 10 January 2019;

  • Publishing the updated MSG ToR on 21 February 2019;

  • Publishing the industry constituency ToR on 21 February 2019;

  • Publishing the 2019 Mali EITI work plan on 21 February 2019;

  • Publishing a plan to follow-up on EITI recommendations on 21 February 2019.

Mali’s second Validation commenced on 27 February 2019. The Secretariat assessed the progress made in addressing the nine corrective actions established by the EITI Board. The EITI International Secretariat’s assessment is that Mali has fully addressed five of the nine corrective actions, with significant improvements on the four outstanding requirements. The draft assessment was sent to the Multi-Stakeholder Group (MSG) on 3 May 2019. Following MSG comments expected on 24 May 2019, the assessment will be finalised for consideration by the EITI Board.

Scorecard for Mali: 2019

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

1.2Company engagement

1.3Civil society engagement

1.4MSG governance

The MSG has clarified and updated MSG governance procedures, leading to a partial renewal of MSG membership, limited to government and industry. Industry has agreed on a clear selection procedure for its representatives on the MSG. Civil society has published a code of conduct to govern its participation on the MSG. There is no evidence however that these procedures have been implemented in practice.

1.5Work plan

In accordance with Requirement 1.5, Mali approved a triennial work plan (2017-2019) and a 2019 work plan with implementation objectives that reflect national priorities. The work plan includes a broad timeline for achieving the objectives, as well as costings and proposed funding sources. In practice, the work plan is well managed and followed by all stakeholders.

Licenses and contracts

2.2License allocations

The 2016 EITI Report lists the licenses awarded and transferred and provides a general overview of the licence allocation and transfer procedures in Mali. However, it does not specifically describe the technical and financial criteria used in practice in licence allocations and transfers.

2.3License register

The 2016 EITI Report and Mali’s mining cadastre provide all of the information required under Requirement 2.3.b.

2.4Policy on contract disclosure

2.1Legal framework

2.5Beneficial ownership

Not assessed

2.6State participation

Monitoring production

3.1Exploration data

3.2Production data

3.3Export data

Revenue collection

4.3Barter agreements

Not applicable

4.6Direct subnational payments

Not applicable


4.9Data quality

There is evidence that Mali EITI and the IA took steps to ensure that material payments and revenues were certified. In accordance with Requirement 4.9, the 2016 EITI Report includes an assessment of the materiality of payments from companies and government entities that did not comply with the agreed quality assurances. The 2016 Report provides a clear assessment that the reconciled financial data presented is reliable.


The 2016 EITI Report provides a comprehensive reconciliation of government revenues and company payments. A definition of the materiality thresholds for payments and companies were included in the scope of reconciliation, including a justification for why the thresholds were set at these levels. The materiality of omissions from non-reporting companies is assessed and considered not to affect the comprehensiveness of the reconciliation.

4.2In-kind revenues

Not applicable

4.4Transportation revenues

Not applicable

4.5SOE transactions

Not applicable

4.8Data timeliness

Revenue allocation

5.1Distribution of revenues

5.2Subnational transfers

The MSG disclosed and reconciled payments of the “patente” tax, a subnational transfer that was not linked exclusively to extractives companies, hence this requirement is not strictly applicable in Mali. The MSG’s efforts were in response to demands for information on the ‘patente’ for the development of local communities in mining regions.

5.3Revenue management and expenditures

Socio-economic contribution

6.1Mandatory social expenditures

6.2Quasi-fiscal expenditures

Not applicable

6.3Economic contribution

Outcomes and impact

7.2Data accessibility

7.4Outcomes and impact of implementation

The Mali EITI APR focused on activities and outcomes, but not on results and impact. Although the MSG developed processes to measure impact, there is no evidence that consultations on assessing the impact of EITI implementation were conducted in practice and that a standalone impact assessment was undertaken.

7.1Public debate

Mali EITI Reports are published and actively promoted through various channels. The MSG adopted an Open Data Policy, which covers the terms of access, use and reuse of EITI data. The MSG disseminated a synthesis of the 2015 and 2016 EITI Reports in the three main mining regions of Mali. There is evidence that Civil society used EITI data in research on the economic impact of mining at the local level.

7.3Follow up on recommendations

There is evidence that the MSG has taken steps to act upon lessons learnt, to identify weaknesses of the EITI process and to consider the recommendations for improvements from the Independent Administrator by adoption a roadmap. There is no evidence however that the MSG has adopted a mechanism for consistent follow up to recommendations.