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

Outcome of the Validation of Iraq

Decision reference
2019-56 / BM-45
Decision basis
EITI Articles of Association 2019-2021, Article 12.1. ix)

Board decision

The Board came to the following decision:  

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

The Board recognises Iraq’s efforts to use the EITI as the key source for disclosing data on the oil and gas sector and bolster its international standing. Iraq has used the EITI to disclose information previously kept closed, ranging from data on oilfields and property rights to the financial statements of state-owned enterprises in the oil and gas sector. Iraq’s EITI implementation is also recognised as having generated a number of reforms, from pioneering transparency in the sale of the government’s crude oil exports to ongoing efforts to develop a license register. The Board recognises Iraq’s efforts to strengthen government and industry engagement in EITI implementation. Given Iraq’s adapted implementation request related to Iraqi Kurdistan for the 2016-2018 EITI Reports, the Board did not take account of weaknesses in coverage of Iraqi Kurdistan in its assessment of Iraq’s progress in implementing the EITI Standard.

The Board nonetheless encourages Iraq to further enhance public disclosures, particularly related to SOEs’ financial relations with government, and ensuring comprehensive disclosure of payments, including social expenditures, and provision of agreed quality assurances by all material companies. Iraq is urged to use EITI implementation as an instrument to support reforms, including improving the performance of international oil companies and SOEs to ensure that extractives revenues benefit Iraq’s citizens. The Board encourages Iraq to use its EITI implementation to drive a more transparent and accountable management of its extractive industries. The Board welcomes Iraq’s ongoing efforts to consider opportunities for improving government and company disclosures through transparency at source, through government and company systems, and encourages Iraq to strengthen its use of EITI data to support the country’s vibrant public debate. Iraq should link these systematic disclosure efforts more closely to broader public finance management reforms that are ongoing.

The Board has determined that Iraq will have 18 months, i.e. until 16 April 2021, before a third Validation to carry out corrective actions regarding industry engagement (1.2), MSG oversight (1.4), workplan (1.5), state participation (2.6), comprehensiveness (4.1), transactions related to state-owned enterprises (4.5), level of disaggregation (4.7), data quality (4.9), social expenditures (6.1), public debate (7.1), 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, Iraq’s MSG may request an extension of this timeframe, or request that Validation commences earlier than scheduled.

Corrective actions and strategic recommendations

The Validation Committee recommends that the Board agrees the following corrective actions to be undertaken by Iraq. Progress in addressing these corrective actions will be assessed in a third Validation commencing on 16 April 2021:

  1. In accordance with Requirement 1.2, the industry constituency should ensure that it is fully, actively and effectively engaged in all aspects of EITI implementation, beyond submission of data. Industry is encouraged to refine its constituency action plan to ensure that it provides robust guidelines for structuring the constituency’s engagement in EITI implementation and to move forward with efforts to systematically disclose information required under the EITI Standard through their systems.

  2. In accordance with Requirement 1.4, Iraq should ensure that any non-trivial deviations from the MSG’s ToR in practice are adequately codified, including a clear procedure for appointing proxies in the event that a MSG member is not available.

  3. In accordance with Requirement 1.5, Iraq should ensure that the annual IEITI work plan is the product of consultations with the broader government, industry and civil society constituencies, includes individually costed activities with clear sources of funding for each, and includes plans for follow-up on recommendations from Validation and EITI reporting. Iraq may wish to publish more regular updates of its work plan execution to reflect consistent monitoring of implementation and support Iraq’s efforts to reach out to prospective donors to support specific activities.

  4. In accordance with Requirement 2.6.a, Iraq should ensure that an explanation of the financial relations between material state-owned enterprises (SOEs) and the government in practice during the year under review is publicly-accessible. In accordance with Requirement 2.6.b, Iraq should ensure that a description of any loans or loan guarantees provided by the government to any mining, oil and gas companies is publicly-accessible. To strengthen implementation, Iraq is encouraged to consider means of disclosing this information through routine government and SOE disclosure systems, as well as the scope for using EITI implementation as an annual diagnostic of SOE financial relations with the state in practice.

  5. In accordance with Requirement 4.1, Iraq should ensure that future EITI reconciliations include the IA’s clear assessment of the materiality of payments from each non-reporting company, to support an assessment of whether omissions could have affected the comprehensiveness of the reconciliation of payments and revenues (see Requirement 4.9). The MSG should document the options considered and the rationale for establishing the materiality definitions and thresholds. Iraq is encouraged to strengthen its efforts to ensure that all companies making material payments to government duly submit their EITI reporting templates.

  6. In accordance with Requirement 4.5, Iraq should ensure that all material company payments to SOEs, whether in cash or in kind, and all material SOE transfers to and from government are comprehensively disclosed and reconciled. To strengthen implementation, given the importance of SOEs in the oil and gas sector, Iraq is encouraged to ensure that a clear mapping of all transactions involving extractives SOEs is publicly available.

  7. In accordance with Requirement 4.7, Iraq should ensure that all reconciled financial data, including cost recovery and remuneration fee, is disaggregated by company, revenue stream and government entity. Iraq may wish to consider the extent to which it can make progress in implementing project-level EITI reporting of sector-specific levies and taxes ahead of the deadline for all EITI Reports covering fiscal periods ending on or after 31 December 2018, agreed by the EITI Board at its 36th meeting in Bogotá.

  8. In accordance with Requirement 4.9, 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. 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.

    2. ensure that the Independent Administrator provides an informative summary of the work performed by the Independent Administrator and the limitations of the assessment provided, alongside the Independent Administrator’s clear assessment of comprehensiveness and reliability of the (financial) data presented.

  9. In accordance with Requirement 6.1, Iraq should ensure that reporting of mandatory social expenditures be disaggregated by type of payment and beneficiary, clarifying the name and function of any non-government (third-party) beneficiaries and whether expenditures were provided in cash or in kind.

  10. In accordance with Requirement 7.1, Iraq should ensure that EITI data is actively promoted, publicly accessible and contributes to public debate. Iraq should consider developing a communications strategy that looks beyond building brand recognition to addressing the national priorities identified in the work plan. Iraq is encouraged to engage with a broader group of relevant stakeholders in its EITI dissemination and outreach, including parliamentarians, academia, the media and host communities. Iraq should also agree a clear policy on the access, release and reuse of EITI data.

  11. In accordance with Requirement 7.3, Iraq should implement a mechanism for consistent follow-up on recommendations from past EITI reporting and Validation. Iraq should also consistently make efforts to identify, investigate and address the causes of any discrepancies and weaknesses of the EITI process after publication of EITI Reports. The MSG is also encouraged to take a more proactive role in formulating its own recommendations as part of EITI reporting.

  12. In accordance with Requirement 7.4, Iraq should ensure that all stakeholders are given an opportunity to provide input to the annual progress report and that their views are adequately reflected. Iraq should also ensure that the next annual progress report includes a narrative account of efforts to strengthen the impact of EITI implementation on natural resource governance.

Background

Iraq was admitted as an EITI Candidate in January 2010. The first Validation of Iraq commenced on 1 January 2017. On 26 October 2018, the EITI Board found that Iraq had made meaningful progress in implementing the 2016 EITI Standard. Twenty-two corrective actions were established by the EITI Board, pertaining to the following requirements:

  1. Government engagement (Requirement 1.1)
  2. Industry engagement (Requirement 1.2)
  3. MSG oversight (Requirement 1.4)
  4. Workplan (Requirement 1.5)
  5. Legal framework and fiscal regime (Requirement 2.1)
  6. License allocations (Requirement 2.2)
  7. License registers (Requirement 2.3)
  8. Contract disclosure (Requirement 2.4)
  9. State participation (Requirement 2.6)
  10. Production data (Requirement 3.2)
  11. Comprehensiveness (Requirement 4.1)
  12. Transactions related to state-owned enterprises (Requirement 4.5)
  13. Direct subnational payments (Requirement 4.6)
  14. Level of disaggregation (Requirement 4.7)
  15. Data quality (Requirement 4.9)
  16. Distribution of extractive industry revenues (Requirement 5.1)
  17. Subnational transfers (Requirement 5.2)
  18. Social expenditures (Requirement 6.1)
  19. Economic contribution (Requirement 6.3)
  20. Public debate (Requirement 7.1)
  21. Discrepancies and recommendations from EITI Reports (Requirement 7.3)
  22. Outcomes and impact of EITI implementation (Requirement 7.4). 

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

  • The Iraq EITI MSG held 11 meetings in 2018, on 29 January, 7 March, 7 May, 4 June, 2 July, 7 August, 3 September, 8 October, 15 November, 11 December and 20 December.

  • On 7 January 2018, the MSG established a committee to engage with the Kurdistan Regional Government. An official letter proposing an EITI visit to Iraqi Kurdistan was sent on 26 February 2018, with no response.

  • On 13 March 2018, Iraq EITI held a workshop in Basra on crude oil marketing and EITI implementation for government entities, state-owned enterprises (SOEs) and civil society.

  • On 28 March 2018, Iraq EITI held a capacity-building workshop for civil society on use of EITI data.

  • On 1 April 2018, Iraq EITI held a workshop for government entities on systematic disclosures of EITI data at the Ministry of Oil.

  • On 4 June 2018, the civil society constituency held a workshop at the Cultural Centre in Baghdad to clarify MSG member nominations procedures and proceed with the election of new CSO MSG members to the MSG. The MSG had previously established a committee to oversee civil society MSG member nominations, on 7 May 2018.

  • On 1-3 July 2018, the MSG held a capacity-building workshop in Dubai for its MSG members to discuss progress on corrective actions from Validation and strengthening capacities for effective oversight of EITI implementation.

  • Ernst & Young (EY) was selected as the IA for the 2016 and 2017 EITI Reports based on a government procurement process overseen by the MSG in line with the World Bank’s cost- and quality-based procedures (QCBS), with the contract signed on 16 July 2018.

  • The MSG updated and published its 2018-2019 Iraq EITI work plan in September 2018.

  • The MSG approved and published a study on the legal framework for the mining, oil and gas sectors in September 2018.

  • On 1-2 October 2018, the MSG held a workshop on corrective actions from the first Validation, supported by the EITI International Secretariat.

  • Iraq EITI National Coordinator Alaa Mohie El-Deen met with Deputy Prime Minister and the Minister of Oil Thamer Al-Ghadhban on 13 December 2018.

  • The MSG approved and published the 2016 IEITI Report on 28 December 2018. 

  • On 4 December 2018, the Iraq EITI website published a link to a Ministry of Oil webpage with information on the process for awarding Technical Service Contracts (TSCs) through licensing round, including bid criteria.

  • Iraq submitted a request to the EITI Board for adapted implementation related to reporting in Iraqi Kurdistan for its 2016-2018 EITI Reports on 18 December 2018, having discussed the draft request since September 2018.

  • Deputy Prime Minister and the Minister of Oil Thamer Al-Ghadhban called for Iraq EITI to monitor all of SOMO’s monthly oil-pricing meetings during his tenure on 26 December 2018.

  • The MSG approved and published Iraq’s 2018 annual progress report (APR) in January 2019.

  • The 2016 EITI Report was formally launched at a press conference chaired by Deputy Prime Minister and Minister of Oil Thamir Al-Ghadhban on 5 February 2019.

  • On 13-16 March 2019, Iraq EITI led by National Coordinator Alaa Mohie El-Deen held a capacity-building workshop with 17 journalists and CSOs on EITI related issues.

  • On 18 March 2019, the secretariat of the Council of Ministers issued a Diwani (Order) assigning Deputy Prime Minister and Minister of Oil Thamer Al-Ghadhban as chair of the Iraq EITI MSG and reassigning Alaa Mohie El-Deen as Executive Manager.

  • On 25 March 2019, Deputy Prime Minister and Minister of Oil Thamer Al-Ghadban chaired a symposium of representatives of International Oil Companies (IOCs), National Oil Companies (NOCs) to discuss key issues of EITI implementation such as systematic disclosures and contract disclosure.

  • The Board approved Iraq’s request for adapted implementation for its 2016-2018 EITI Reports in relation to coverage of Iraqi Kurdistan on 15 April 2019.

  • The MSG approved and published an addendum to the 2016 EITI Report on 20 April 2019.

  • In April 2019, following direction from the MSG at its 8 April 2019 meeting, all 17 oil and gas SOEs published their financial statements for 2016 (and in some cases subsequent years)  and their statements and certificates of establishment. 

Iraq’s second Validation commenced on 25 April 2019. The Secretariat assessed the progress made in addressing the twenty-two corrective actions established by the EITI Board. The EITI International Secretariat’s assessment is that Iraq has fully addressed ten of the twenty-two corrective actions, with significant improvements on the twelve outstanding requirements. The draft assessment was sent to the Multi-Stakeholder Group (MSG) in English on 24 May 2019 and in Arabic on 7 June 2019. Following MSG comments received on 10 July 2019, the assessment was finalised for consideration by the EITI Board.

Scorecard for Iraq: 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

There have been regular, public statements of support from the government and a senior individual has been appointed to lead on the implementation of the EITI since the inauguration of a new government in October 2018. Senior government officials are represented on the MSG and appear effectively engaged in all aspects of EITI implementation.

1.2Company engagement

The industry constituency belatedly agreed and published its action plan in April 2019. The renewal of industry’s MSG representation in late 2018 brought about a significant improvement in the constituency’s coordination on EITI issues, including through the Iraq International Oil Companies Forum. Industry representatives regularly attend MSG meetings, submit data for EITI reporting and more frequently consult with the broader constituency. However, the industry constituency’s engagement in EITI implementation appears to remain primarily focused on the provision of data for EITI reporting. The industry constituency does not yet appear to be fully, actively and effectively engaged in all aspects of implementation, including on dissemination and outreach.

1.3Civil society engagement

Despite the general constraints inherent in Iraq's security situation, civil society is able to engage in public debate related to the EITI proess and expresss opinions about the EITI process without restraint, coercion or reprisal. Civil society representatives are able to engage in the design, implementation, monitoring and evaluation of the EITI process.

1.4MSG governance

The MSG has been formed and includes self-appointed representatives from each stakeholder group with no suggestion of interference or coercion, even if nominations procedures for industry were only belatedly codified. The mechanism for civil society nominations on the MSG was open to the public, and CSO members of the MSG are operationally and in policy terms independent. Information on nominations procedures is publicly available. The ToR for the MSG addresses the requirements of the EITI Standard, although there appear to be deviations in practice in terms of actual MSG membership for the different constituencies. Meetings are convened with sufficient advance warning and MSG members generally appear to have sufficient time to review documents ahead of meetings. Attendance of the large majority of MSG members is consistent. The MSG’s per diem policy was publicly codified.

1.5Work plan

The 2018-2019 IEITI work plan is publicly accessible, produced in a timely manner and updated annually, with objectives aligned with national priorities. However, the degree of consultations with the broader constituencies represented on the MSG is unclear. The work plan also includes specific activities to follow up on recommendations from Validation, but not from EITI reporting. While around half of the activities are costed, with sources of funding clearly indicated, the other half are not.

Licenses and contracts

2.1Legal framework

The 2016 EITI Report includes an overview of relevant laws, government entities, fiscal terms in the mining, oil and gas sector, the degree of fiscal devolution and brief commentary on current reforms.

2.2License allocations

The 2016 EITI Report and its addendum clarify oil and gas license awards and transfers in 2016 and provides a description of the statutory process for awarding and transferring oil and gas licenses in Federal Iraq, including technical and financial criteria for bidding rounds and for transfers. The 2016 EITI Report and its addendum provide the identity of assignor and assignee for the one transfer in 2016 and quotes stakeholders’ views that there were no non-trivial deviations from statutory procedures. In mining, the report clearly states that no mining company was considered material in 2016. The report provides publicly-available information on license allocations and transfers in the Iraqi Kurdistan in 2016 and clearly highlights the gaps in publicly-available information.

2.3License register

The 2016 EITI Report provides guidance to accessing all information listed under Requirement 2.3.b aside from dates of application for licenses covered by TSCs with IOCs. The 2016 addendum provides dates of application for all licenses under TSCs, as well as all relevant information on oilfields operated independently by NOCs, in line with Requirement 2.3.b. In mining, the report clearly states that no mining company was considered material in 2016.The report provides publicly-available information on license register(s) in Iraqi Kurdistan in 2016 and clearly highlights the gaps in publicly-available information.

2.4Policy on contract disclosure

In April 2019, the Ministry of Oil published the government’s policy on contract disclosure in the extractives on its website. The 2016 EITI Report and its addendum provide links to model oil and gas contracts on the Ministry of Oil website and documents actual disclosure practice. The report provides publicly-available information on contract disclosure in Iraqi Kurdistan in 2016 and clearly highlights the gaps in publicly-available information.

2.5Beneficial ownership

Not assessed

Implementing countries are not yet required to address beneficial ownership and progress with this requirement does not yet have any implications for a country’s EITI status. The multi-stakeholder group published its roadmap by the deadline of 1 January 2017 as required, but it is not clear what beneficial ownership information will be disclosed in Iraq’s state-dominated oil and gas sector. The 2015 IEITI Report does not clarify the government’s policy on beneficial ownership disclosure and does not provide the legal ownership of companies operating under technical service contracts. It is furthermore not clear whether Iraq wishes to extend beneficial ownership disclosure to the mining sector, where it could perhaps be more relevant.

2.6State participation

The 2016 EITI Report provides a list of state-owned enterprises in the oil and gas sector in both Federal Iraq and Kurdistan, as well as a list of SOEs in the mining sector in Federal Iraq but not in Kurdistan. While the 2016 EITI Report states that none of the SOEs’ payments to government were considered material, the report nonetheless identifies six oil and gas companies owned by the Federal Government of Iraq as material for EITI reporting in 2016 based on their receipt of material transfers from the government. The report provides an overview of financial relations between these six SOEs and the government, both statutorily and, albeit only generally, in practice. The publication of all oil and gas SOEs’ 2016 financial statements in April 2019 provides additional information on the practice of financial relations between SOEs and the state in 2016. The terms associated with state equity in the six material SOEs and one majority government-owned gas company are described. However, the MSG did not fully described the actual practice of financial relations in 2016.

Monitoring production

3.1Exploration data

The 2015 IEITI Report provides an overview of the extractive sector, including information on significant exploration activities.

3.2Production data

The 2016 EITI Report provides production volumes for oil, gas and mining in Federal Iraq, together with an approximate description of the location of production. The 2016 report addendum provides 2016 production values for crude oil, natural gas and three of the four minerals produced in Iraq in 2016. The gaps in production values for one of the four minerals produced in 2016 were of marginal importance given that the mining sector was not considered material in 2016. The report provides publicly-available information on production data in Iraqi Kurdistan in 2016 and clearly highlights the gaps in publicly-available information.

3.3Export data

The 2015 IEITI Report provides the volumes and values of crude oil exports. There is no evidence of any Iraqi exports of natural gas or minerals in 2015.

Revenue collection

4.1Comprehensiveness

The MSG has agreed materiality thresholds for selecting companies and revenue streams, effectively removing the mining sector from the scope of reconciliation. The 2016 EITI Report lists and describes all material companies and revenue streams, names the non-reporting companies but does not assess the materiality of non-reporting companies’ payments. While the value of aggregate net discrepancies appears to be below 5% of total reconciled revenues, significant discrepancies in the reconciliation of cost recovery and remuneration fees are a concern. Full government reporting of all material revenues is provided, per revenue stream.

4.2In-kind revenues

Iraq EITI has made efforts to go beyond the minimum requirement through its cargo-by-cargo reconciliation of crude oil sales and additional information on the sales process. The 2015 IEITI Report provides the volumes of crude oil collected by the government, the volumes sold and the value of oil sales disaggregated by buyer.

4.3Barter agreements

Not applicable

EITI Requirement 4.3 on barter and infrastructure transactions is not applicable to Iraq.

4.4Transportation revenues

Not applicable

EITI Requirement 4.4 on transport revenues is not applicable to Iraq.

4.5SOE transactions

The 2016 EITI Report clearly defines six SOEs as material. The report confirms the lack of financial payments by companies to material SOEs, and its addendum confirms that NOCs receive oil and gas produced by IOCs in line with the state’s ownership of resources. The report includes an assessment of SOE payments of dividends to government in 2016 and concludes that these were not material. The report comprehensively discloses and reconciles SOMO transfers of internal service payments to each of the five SOEs receiving such payments in 2016. Finally, the report includes unilateral disclosure of intra-SOE transfers of crude oil and natural gas in kind, but does not reconcile these.

4.6Direct subnational payments

Not applicable

The 2016 EITI Report describes the MSG’s view that crude oil export revenue collected by the KRG was the only direct subnational payment stream considered material in 2016. While the lack of coverage of extractives companies’ direct payments to the KRG is a concern, the 2016 EITI Report and the IEITI website provide publicly available information on a few companies’ 2016 payments to the KRG and the KRG’s revenues in H1-2017 based on publicly-accessible data. The report provides publicly-available information on direct subnational payments in Iraqi Kurdistan in 2016 and clearly highlights the gaps in publicly-available information.

4.7Disaggregation

The 2016 EITI Report presents reconciled financial data disaggregated by government entity, but not consistently by revenue stream and by company. A higher share of material revenues have been disaggregated by company, revenue stream and government entity than in the 2015 EITI Report reviewed in the first Validation however. The MSG approved the reporting period.

4.8Data timeliness

Iraq now publishes EITI Reports within one year of the close of the fiscal period under review.

4.9Data quality

The MSG adopted ToR for the IA for the 2016 EITI Report consistent with the EITI Board-approved template, and the IA appears to have adhered to the terms of the ToR in practice. The IA undertook a review of auditing practices in 2016, and agreed quality assurance procedures with the MSG. However, companies were given the discretion to decide which specific quality assurances to provide. The 2016 report addendum names individual non-complying companies and assesses the materiality of their payments to government. While the report only includes a target reconciliation coverage, it is possible to calculate an aggregate net final reconciliation coverage in light of reporting omissions. The addendum includes the IA’s clear assessment of the comprehensiveness and reliability of data. The report includes recommendations and provide an overview of follow-up on corrective actions from Validation, while the addendum covered follow-up on recommendations of past EITI Reports. Summary data tables have been prepared for Iraq’s 2016 EITI Report.

Revenue allocation

5.1Distribution of revenues

The 2016 EITI Report confirms that all extractives revenues, other than those collected by the KRG, are recorded in the Federal Iraq national budget. The report does not explain the allocation of extractives revenues collected by the KRG, nor provide links to relevant financial reports. However, the report provides publicly-available information on distribution of revenues in Iraqi Kurdistan in 2016 and clearly highlights the gaps in publicly-available information.

5.2Subnational transfers

The 2016 EITI Report confirms the lack of effective subnational transfers to the Kurdistan Regional Government in 2016, but describes the general revenue-sharing formula. The report describes ‘petrodollar allocations’ effective in 2016, provides the general revenue-sharing formula and highlights discrepancies between the transfer amount calculated in accordance with the relevant revenue sharing formula and the actual amount transferred to each Governorate.

5.3Revenue management and expenditures

Not assessed

Reporting on revenue management and expenditures is encouraged but not required by the EITI Standard and progress with this requirement will not have any implications for a country’s EITI status. Iraq EITI has sought to include information on the budget-making process and certain budget assumptions and projections in the 2015 IEITI Report.

Socio-economic contribution

6.1Mandatory social expenditures

The 2016 EITI Report describes two types of mandatory social expenditures, while its addendum clarifies that IOCs’ expenditures on training courses are not a form of mandatory social expenditures. The report and its addendum provide companies’ unilateral disclosures of a large share of the information on mandatory social expenditures listed under Requirement 6.1.a, albeit not consistently for all mandatory social expenditures reported. The lack of reporting of social expenditures by several material companies is a concern.

6.2Quasi-fiscal expenditures

Not applicable

This requirement is not applicable in Iraq.

6.3Economic contribution

The 2016 EITI Report provides, in absolute and relative terms, the contribution of the extractive industries to GDP, government revenues, exports and employment in Federal Iraq. Challenges in sourcing data from the Kurdistan Regional Government are clearly highlighted in the report and efforts were made to source publicly-accessible information where possible.

Outcomes and impact

7.1Public debate

The Iraq EITI Reports are comprehensible and published in local languages and in open data format, although they appear far more actively promoted online than through print or active outreach. While the IEITI Secretariat has made efforts to disseminate EITI Reports, there is little evidence of MSG members contributing to outreach and dissemination in practice. While the EITI Reports themselves are publicly accessible on the IEITI website, there is little evidence of use of EITI data in practice. There have been limited attempts at active dissemination of visualisations of EITI information, including regular subnational outreach and dissemination.

7.2Data accessibility

Not assessed

Requirement 7.2 encourages the countries to make EITI reports accessible to public in open data formats. Such efforts are encouraged but not required and are not assessed in determining compliance with the EITI Standard. Iraq’s EITI data is available in machine readable format through the EITI global website, drawing on summary data tables completed by the national secretariat. IEITI has also published summaries of past EITI Reports in local languages.

7.3Follow up on recommendations

The MSG and the government have taken steps to consider the recommendations for improvements from past EITI Reports and Iraq’s first Validation. A mechanism for the MSG to consistently follow up on recommendations from past EITI Reports was belatedly established at the MSG’s 8 April 2019 meeting. However, this mechanism needs to be implemented to demonstrate that Iraq has consistently followed up on EITI recommendations.

7.4Outcomes and impact of implementation

The MSG has reviewed progress and outcomes of implementation on a regular basis, including by publishing the 2018 APR that provided an overview of activities and progress against work plan objectives. While it appears that the 2018 APR was the product of consultations within each of the three constituencies, there is no evidence that the MSG has assessed the impact of EITI implementation to date, either through the annual progress report or other channels.