Le Mexique obtient un score global faible dans la mise en œuvre de la Norme ITIE 2019

Mexico EITI has agreed a national EITI work plan every two years since joining the EITI, including 2017-2019 and 2021-2022. While the MSG agreed a document in lieu of a work plan for 2020 at its 11 September 2020 meeting, the plan was never published and contained neither objectives nor clear costings. The irregularity of updates and lack of annual updates of activity planning is a concern, with the 2021-2022 work plan only approved on 2 September 2021. Nonetheless, the MSG’s 2021-2022 work plan provides a clear planning document, albeit with some weaknesses, that appears to have been the product of consultations with the constituencies given that it was developed by the MSG’s technical working group in meetings over March-August 2021. This marks an improvement on previous Mexico EITI work plans, to which several stakeholders consulted noted there had been little input from the various constituencies. It defines objectives that appear aligned with national priorities (e.g. the 2019-2024 National Development Plan and constituency priorities described in the ‘Stakeholder engagement’ template) and sets out activities to achieve these objectives. The work plan is timebound, with sources of funds indicated, but is not fully costed, providing only costs of only some consultants but not of most activities. Nonetheless, activities to address the MSG’s technical and financial resource constraints are a part of the work plan. The MSG’s planning document includes activities to extend the scope of EITI implementation to other areas such as the energy transition, environment and gender information and contract transparency. Plans to address any potential legal or regulatory obstacles to EITI implementation are included. The work plan includes a general reference to follow-up on corrective actions from Validation, a number of work plan activities relate to follow up on recommendations in the EITI Reports without being labelled as such, including follow-up on environmental information. The 2021-2022 document includes activities to improve the systematic disclosure and accessibility of EITI data, including tailoring data to the needs of target audiences. The extent to which the MSG uses the work plan as a regular monitoring tool is unclear based on a review of MSG and working group’s (succinct) meeting minutes. The MSG appears to have discussed its work plan only when undertaking updates to the plan, rather than on an ongoing basis. Several civil society stakeholders consulted did not consider the objective of annual planning for EITI implementation that supports implementation of national priorities for the extractive industries had been fulfilled, while members of other constituencies did not express particular views on the issue. The Secretariat’s assessment is that Requirement 1.5 is mostly met in Mexico in the period under review. The annual EITI work plan does not yet appear to be a key accountability document for the MSG vis-à-vis broader constituencies and the public.

Mexico EITI has undertaken only ad hoc and relatively infrequent communication efforts that have not yet enabled evidence-based public debate on extractive industry governance, despite objectives of the Mexico EITI work plan that seek to ensure EITI findings inform public debate on the extractive industries. The MSG’s Outcomes & impact template provides a critical self-assessment of fledgling progress and significant outstanding work required in outreach and dissemination of EITI findings. The MSG notes that accessibility of EITI data remains a challenge, in part due to the Mexico EITI website being out of date. Many stakeholders from all constituencies expressed concern at the infrequency of updates and the low accessibility of information on the website, although government officials explained that this was due to weaknesses in the National Secretariat’s capacities rather than a lack of willingness to maintain an updated website. Although the MSG highlights the government portal on budgetary transparency as a robust tool for public disclosure of government extractive revenue information, civil society’s comments raised concerns over the need to improve the neutrality of language used on the portal related to the desirability of extractive projects. The MSG’s submission for Validation also called for greater attention to the accessibility of EITI data by stakeholders at the subnational level. While the MSG’s template notes the different indigenous languages of resource-rich communities, the Mexico EITI Reports and other communication materials have only been published in Spanish to date. Several civil society stakeholders consulted deplored the lack of accessibility of EITI Reports to the general public and called for the development of summary materials to communicate EITI findings to the broader public. There is evidence of some use of EITI findings in academic reports on anti-corruption efforts in Mexico, although there is limited use of EITI findings by the various constituencies represented on the MSG, aside from civil society reports and cursory references to EITI implementation in reports from industry associations in both mining (CAMIMEX’s sustainability reports) and oil and gas (AMEXHI’s reports on industry engagement with host communities). While there is evidence of outreach and dissemination driven by CSOs, the pack of the MSG’s communications activities appears to have declined significantly since 2020. Many stakeholders consulted attributed this to a combination of financial constraints and the impact of the Covid-19 pandemic. The MSG has undertaken some outreach and dissemination activities although these have remained infrequent, with two outreach events in the (Yucatan and Coahuila) regions in 2018, one international civil society event in Colombia in 2019 and one workshop for civil society each in December 2020 and January 2021. The MSG organised a series of workshops aimed at awareness raising around beneficial ownership in mid-2020, with support from the Joint Mexican-German Fund and the Simone de Beauvoir Leadership Institute. Despite evidence of such subnational outreach, Mexico EITI does not appear to have considered undertaking a more systematic outreach and strategic communications campaign at the subnational level, despite calls from some stakeholders for outreach to state-level officials and local parliamentarians. Several stakeholders attributed the lack of effective EITI-related communications to the government’s relative disengagement since 2019, with the lack of senior government officials on the MSG seen as impacting media coverage of EITI activities. A comprehensive communications strategy has not been developed for Mexico EITI to date. The MSG’s submission for Validation calls for the identification of different target users’ information needs through the conduct of surveys and workshops. It does not appear that the MSG has taken gender considerations into account in planning or executing EITI events to date. Many stakeholders criticised the lack of awareness about EITI in Mexico, although MSG members consulted did not appear to consider this a key part of their responsibilities as members of Mexico EITI. The MSG’s submission for Validation includes calls from all constituencies on the MSG to enhance Mexico EITI’s proactive dissemination of findings from EITI implementation. Most stakeholders consulted did not consider that the objective of enabling evidence-based public debate on extractive industry governance through active communication of relevant data to key stakeholders was still far from being fulfilled. The Secretariat’s assessment is that Requirement 7.1 is partly met in Mexico.

Mexico EITI does not appear to have agreed or published an open data policy aligned with the EITI’s openness policy. The MSG is transparent about the shortcomings of its open data efforts in the templates it submitted for this Validation, for instance by identifying the lack of updates to the Mexico EITI website as a key challenge. The MSG’s Outcomes & impact template submitted for this Validation states categorically that “to date there have been no additional efforts to improve the availability of data in open format”. Data from EITI has been submitted to the International Secretariat in open format as Summary Data files for the 2016, 2017 and 2018 EITI Report, but it has only published the 2017 data in open format on its website, not 2018. Beyond this, some government data on the extractive industries, such as oil and gas license and contract data from CNH, is available in open format, although much extractive data remains either published in PDF or remains unpublished. In its comments to the draft assessment however, the MSG highlighted the publication of extensive oil and gas data in various formats (including .csv) on the websites of the Mexican Petroleum Fund and of the Ministry of Finance (SHCP). However, the Mexico EITI website has made some efforts to disclose specific data sets (such as extractive revenues) in open format, although the irregular website updates have meant that publications of open data have been ad hoc. The Secretariat’s assessment is that Requirement 7.2 is partly met in Mexico in the period under review. The objective of enabling the broader use and analysis of information on the extractive industries, through the publication of information in open data and interoperable formats, is still far from being fulfilled.

The MSG has made some efforts to strengthen the impact of EITI implementation by acting upon lessons learnt, although this has only been achieved through ad hoc discussions of EITI recommendations at MSG and working group meetings rather than through a consistent mechanism for follow-up on EITI findings. The MSG does not appear to have a systematic approach to following up on recommendations from EITI reporting, which was confirmed by several stakeholders consulted. One government official explained that the MSG and its working groups had had so many issues to prioritise that it had not devoted sufficient attention to follow-up on recommendations. Evidence presented in the MSG’s Outcome & impact template indicates that civil society appears to have been the primary driver of follow-up on EITI recommendations, publishing for instance detailed reports on beneficial ownership and socio-environmental impacts. Furthermore, the lessons learned from EITI highlighted in the MSG’s template focus only on Pemex and the AMEXHI association. Several civil society stakeholders noted that government agencies were not undertaking sufficient efforts to implement recommendations, including related to environmental reporting, beneficial ownership transparency and gender aspects of extractive industry governance. The 2021-2022 EITI work plan demonstrates that the MSG has planned activities to follow up on recommendations related to the environment and beneficial ownership, although it only includes a general activity related to follow-up on Validation corrective actions rather than detailed plans on following up on recommendations from EITI Reports. While most stakeholders did not express particular views on the issue, several CSOs consulted considered that the objective of ensuring that EITI implementation is a continuous learning process that contributes to policymaking was still far from being fulfilled. Review of MSG meeting minutes does not indicate frequent or regular discussion of recommendations from EITI Reports. The Secretariat’s assessment is that Requirement 7.3 is partly met in Mexico.

Mexico EITI only ever disclosed one annual review of outcomes and impact of implementation covering 2017, published in October 2018. There is no evidence in MSG or working group meeting minutes of the MSG considering other reviews of outcomes and impact of implementation. A government official explained that the MSG had not published an annual review of outcomes and impact from EITI since 2018 as it had prioritised frequent meetings to address issues that were considered to be ‘minor’ instead. The 2017 annual progress report (APR) documents the activities conducted during the first year of EITI implementation, after Mexico’s accession to the EITI. While an overview of progress against each EITI Requirement is not provided, the report does describe activities related to specific aspects of the EITI Standard and progress against work plan objectives. No follow-up on EITI recommendations is included given that this report covered only the start-up phase of EITI reporting. Nonetheless, the report describes the strengths and opportunities of the EITI process, although it focuses on the initial outputs and outcomes of the EITI process rather than impact, given the early stages of implementation it covers. The report refers to the gender composition of the MSG but does not further describe plans for taking gender considerations into account. There is evidence that the 2017 annual progress report was developed in an inclusive manner by the MSG’s working group, although it is unclear from documentation provided for this Validation whether the broader constituencies were given the opportunity to provide input in the review. While discussions in the MSG’s working groups (particularly Groups 1 and 2) have regularly considered progress and challenges in EITI implementation, these discussions of outcomes and impact have not been publicly documented. One document of MSG comments was published in June 2020, although it was entirely focused on the 2018 EITI Report. There have been efforts by civil society to publish analysis and opinion on advances and challenges in EITI implementation in Mexico, particularly focused on beneficial ownership transparency, environmental and social impacts as well as gender considerations. No more recent MSG review has been published since 2018. While the MSG includes cursory updates on its views on the outcomes and impacts of implementation to date in its Outcome & impact template, this is only available on a Google Drive rather than referenced on a public website. Several stakeholders consulted, particularly from civil society, considered that the objective of regular public monitoring and evaluation of EITI implementation with a view to ensuring the EITI’s own public accountability was far from being fulfilled. The Secretariat’s assessment is that Requirement 7.4 is partly met in Mexico.

There were regular statements of commitment to the EITI from high-level government officials in the 2016-2018 period. While such statements have become far less frequent under the new administration since late 2018, President Andrés Manuel López Obrador highlighted Mexico’s EITI implementation as an integral part of the government’s transparency and anti-corruption efforts in his second State of the Union address in September 2020. The EITI was also highlighted in the incoming administration’s first government report for 2018-2019. A senior government official has led implementation since 2016, although the position was transferred from the Under-Secretary of the Ministry of Finance to the Under-Secretary of Mines of the Ministry of Economy in 2017. The current EITI Champion is the Minister of Economy although there is no public evidence of a document appointing the official as EITI Champion. However, the institutional government host for the EITI Mexico secretariat has changed over the course of Mexico’s implementation, with the Ministry of Energy hosting the secretariat before it was moved to the Ministry of Economy in 2019. Thus, the EITI Champion and the secretariat were in two different ministries in the 2017-2019 period. As part of the government’s decentralisation efforts, the EITI Mexico secretariat was moved to the northern state of Chihuahua (1,500km from Mexico City) in 2019. In practice, the National Coordinator has effectively played the role of government lead in this period, with Director General of Mining Development replacing the Under-Secretary of Mines in 2019. Yet the current National Coordinator has been in an interim position since 2019 and this creates uncertainty over the depth of government commitment. The three main ministries engaged in EITI implementation have consistently been represented on the MSG with three full seats and three alternates since 2017, including the Ministries of Finance and Public Credit (SHCP), of Energy (SENER) and of the Economy. While other relevant government agencies such as the Ministry of the Environment and Natural Resources (SEMARNAT) and key regulatory agencies such as the Tax Authority (SAT) or the Hydrocarbons Commission (CNH) have not been represented on the MSG, the MSG invited SEMARNAT as a permanent observer at Technical Working Group meetings in 2020 while several government officials considered that the regulatory agencies were represented on the MSG through their parent ministries. Several CSOs consulted considered that it would be pertinent to include the National Institute for Transparency, Access to Information and Personal Data Protection (INAI) on the MSG given its responsibility for access to information issues as an autonomous government agency. While the seniority of government officials represented on the MSG has declined since 2019, with Director-General level officials or below attending meetings instead of Under-Secretaries as in the 2017-2018 period, this is at least partly due to restructuring of the Federal Government under the austerity programme, which eradicated the Under-Secretary of Mines position in the Ministry of Economy. Nonetheless, several civil society and industry stakeholders consulted expressed concern over the declining seniority of government officials engaged in the EITI and considered this to reflect declining government engagement. However, government attendance at MSG meetings appears to have remained consistent, albeit with a slight decline from an average of four government officials attending the MSG to three in 2021. Government attendance at Technical Working Group meetings have nearly always been at the level of Director-General. However, civil society stakeholders consulted did not consider that the constituency was treated as an equal partner on the MSG. However, there appear to have been other weaknesses in government engagement in EITI over the 2017-2021 period. While government attendance at MSG and TWG meetings appears to have been relatively consistent, there have been gaps in the government’s submission of data, efforts to overcome legal barriers to implementation, and contribution to outreach. While all material government entities have consistently participated in EITI reporting, legal taxpayer confidentiality (‘fiscal secrecy’) constraints have hindered SAT’s ability to disclose revenues from companies that did not sign confidentiality waivers. There is no evidence that SAT was involved in designing the waivers or following up with non-complying material companies. Likewise, the government does not yet appear to have considered the need for legal or regulatory reforms to facilitate disclosure of revenues, mining production or beneficial ownership data. Government funding for the national secretariat remains insufficient and below the level required to sustain operations. Rather, the three ministries represented on the MSG have sought to provide funding for EITI activities on an ad hoc basis. The Germany-Mexico Common Fund provided a total of EUR 604,414 through GIZ to EITI in the 2016-2019 period, although this funding expired in 2020. Many MSG members consulted noted the capacity constraints in the EITI Mexico secretariat and considered that these were due to funding constraints. Several stakeholders from different constituencies expressed significant concern over the medium-term sustainability of EITI implementation given these funding constraints. In terms of outreach, while there is evidence of senior government participation in outreach in the 2016-2018 period, there is little evidence of their engagement beyond attending trade events where EITI was mentioned since 2019. There is no evidence of government efforts to publish information on the EITI process or undertake outreach to relevant stakeholders. It does not appear that government officials consult each other on EITI-related issues outside of MSG and TWG meetings. The majority of stakeholders consulted did not consider that the objective of full, active and effective government lead for EITI implementation had yet been fulfilled. Thus, the Secretariat’s assessment is that Requirement 1.1 is mostly met.

While there is evidence that the industry members on the MSG are fully, actively and effectively engaged in EITI implementation, there appear to be weaknesses in the broader industry constituency’s engagement in EITI. Industry’s representation on the MSG consists of the oil and gas SOE, Pemex, as well as the industry association for international oil and gas companies (AMEXHI) and for the mining sector (CAMIMEX). The AMEXHI counts 35 companies out of 111 oil and gas contract-holding companies as members, while CAMIMEX counts around 100 members out of thousands of mining companies although it estimates that its membership covers 85% of Mexico’s total mining production by value. Thus, while the major extractive producers appear to be represented through the associations, this has not included representatives from key mining sub-sectors such as coal. Several civil society and development partner stakeholders consulted considered that the lack of direct company participation on the MSG diluted industry’s engagement in the EITI given that association representatives were not considered to be “decision-makers” and called for direct extractive company representation on the MSG to ensure that the MSG could work through technical challenges to reporting. While stakeholders highlighted ad hoc outreach to companies that are not members of the associations in the early stages of implementation in 2017-2018, there is no evidence of sustained outreach to non-member companies since then. Several industry stakeholders consulted considered that it was only the government’s responsibility to undertake outreach to companies that were not members of the two associations engaged in EITI. There appear to be consultations between companies on EITI through the two associations outside of MSG and TWG meetings. Minutes of MSG and TWG meetings indicate that the three industry MSG members and their alternates have consistently attended and engaged in meetings. However, several civil society and government stakeholders considered that industry’s participation in EITI discussions was not matched by their provision of data for EITI reporting in practice. There have been gaps in industry participation in EITI reporting in the first three EITI Reports published to date (covering 2016-2018), with 13 oil and gas companies and five mining companies marked as non-reporting in the 2018 EITI Report. A minority of extractive companies operating in Mexico that are part of corporate groups domiciled in the European Union and Canada systematically disclose information on their payments to government, although the majority of extractive companies in Mexico do not. Given that EITI reporting has been presented as ‘voluntary’ for companies, this reporting rate over-estimates the level of companies’ engagement given that a high number of companies appear to have declined to participate in EITI reporting and to sign taxpayer confidentiality waivers (see Requirement 4.1). There is no evidence of follow-up by companies to help overcome barriers to EITI reporting or implementation, for instance through a more sustainable approach to taxpayer confidentiality waivers (e.g., pluri-annual waivers for instance). There is some evidence of industry attendance at EITI outreach and dissemination activities driven by the three MSG members, particularly in the 2017-2019 period. While there is evidence of industry publications referring to the EITI process, such as CAMIMEX’s annual reports and sustainability reports as well as AMEXHI’s reports on industry engagement with host communities, there is only limited evidence of industry use of EITI data in public documents aside from reference to some specific EITI data in AMEXHI’s Pulso Energético blog series. However, several industry stakeholders consulted explained that both Pemex and the industry associations used EITI data in their own communications activities with investors and companies. There appears to be generally an enabling environment for company participation in the EITI, although legal taxpayer confidentiality constraints have reduced the level of government revenue disclosures related to companies that do not waive their confidentiality rights. Several industry stakeholders consulted noted the need for legal reform to reduce barriers to companies’ EITI reporting, particularly in the mining sector. There is no evidence of government follow-up with non-reporting companies to ensure that the taxpayer confidentiality waivers were an effective means of circumventing legal barriers to reporting. While AMEXHI appears to have followed up with non-reporting oil and gas companies, there does not appear to have been equivalent efforts in the mining sector. Likewise, several industry stakeholders explained that companies would be willing to disclose their social impact assessments as requested by civil society if the government disclosed these first, although this had not yet been done. Several CSOs consulted considered that companies often used the lack of legal requirements to explain their lack of EITI reporting of certain data and made allegations of collusion between government and industry on the MSG, with reference to the practice of ‘revolving doors’ where government officials took jobs in industry while maintaining their engagement in EITI (see Requirement 1.4). Several CSOs and development partners consulted did not consider that the government had made sufficient efforts to overcome legal barriers to EITI implementation, citing the example of ‘fiscal secrecy’ constraints and the lack of legal reforms to support beneficial ownership transparency. While industry and government stakeholders consulted broadly considered that the industry constituency was fully engaged in EITI implementation, none of the CSOs consulted considered that this was the case. The Secretariat’s assessment is that Requirement 1.2 is mostly met.

Requirement 1.3 is partly met due to breaches to the EITI protocol: Participation of civil society. Civil society is actively participating in the EITI process and public expression on natural resource governance, albeit with constraints related to the enabling environment for civil society particularly related to freedoms of expression and of operation. There have been high-level stigmatisation of CSOs by senior government officials and credible allegations of threats, intimidation and reprisals against CSOs engaged in public debate on the extractive industries outside of the EITI. Allegations of self-censorship by CSOs substantially engaged in the EITI process due to fears of reprisals either through high-level political stigmatisation or the launch of a tax audit are a significant concern.

The government has established a MSG to oversee implementation of the EITI since 2017, following appointments to the MSG from government in June 2015, from industry in September 2015 and from civil society in April 2016 as described in Mexico’s EITI candidature application. There was a renewal of government MSG representation in 2019 following the change in administrations, while industry renewed its representation on an ad hoc basis following personnel changes in Pemex and the two associations. Available documentation and stakeholder consultations confirmed that the invitation to participate in the MSG was open and transparent. Appropriate stakeholders appear to be adequately represented on the MSG, although several stakeholders questioned the lack of direct MSG representation for key government entities such as the Tax Authority (SAT) and the Hydrocarbons Commission (CNH), even if their parent ministries are members of the MSG. It was noted that SEMARNAT had been invited to be a permanent observer at the MSG’s TWG in 2020. One CSO called for representation on the MSG for INAI given its responsibilities for ensuring access to information. Several CSOs and development partners expressed concern at the lack of direct company representation on the MSG given their view that association representatives were not “decision-makers” that could move the process forward. The lack of MSG representation for companies not member of either association was also highlighted as a concern given the relatively narrow membership of the two associations. Both industry (through the two associations) and civil society have clear nominations procedures for their MSG representatives that appear to have been followed in practice in both the original appointments and the renewals. While the civil society constituency appears to take gender considerations into account in the nominations procedures, neither industry nor government nominations procedures reference gender. A legislative basis for EITI implementation has not been established to date (or planned). The MSG has clear Terms of Reference (ToR) that have been revised since their original approval in July 2017. The ToR cover all aspects of Requirement 1.4.b, including in codifying the capacities, roles and responsibilities of MSG members, including in outreach and dissemination, the MSG’s internal governance, procedures and decision-making and includes reference to the adherence to the EITI Code of Conduct. The MSG does not operate a per diem policy or practice. In practice, the MSG has established five Technical Working Groups (TWG) that have met frequently in the period under review, dedicated to EITI reporting, to socio-environmental aspects of the extractive industries, to communications, to beneficial ownership and to gender. However, there appear to have been significant deviations from the MSG’s ToR in practice over the 2017-2021 period based on available documentation and stakeholder consultations. While a review of MSG and TWG meeting minutes indicates that all MSG members appear to have the capacity to carry out their duties, several stakeholders from all constituencies noted the national secretariat’s capacity constraints in supporting the MSG’s work, which was broadly attributed to funding constraints. In practice, these weaknesses have led to insufficient advance notice of meetings and delays in circulation of meeting records to MSG members. It appears that the TWG have met far more often (at times several times a week) than the MSG to undertake most of the technical work, with some stakeholders consulted attributing the high pace of meetings was due to the need to compensate for insufficient secretarial support for the MSG. While the right of any MSG member to table issues for discussion is confirmed in the ToR, a government stakeholder explained that it was uncommon for MSG members to suggest additions to the agenda in practice. Review of MSG and TWG meeting minutes appears to indicate that the MSG’s statutory decision-making has been adhered to in practice, in accordance with the ToR’s qualified majority voting rules. However, several civil society MSG members consulted considered that the constituency was often over-ruled by the MSG. For instance, it was explained that the MSG decided not to publish government revenues disaggregated by project in the 2018 EITI Report despite civil society advocacy in favour of this granularity. Likewise, the first three EITI Reports did not include information on beneficial ownership or socio-environmental aspects of the extractive industries due to a MSG decision to omit this, despite strong lobbying from civil society. A final example highlighted consisted of a proposal by civil society MSG members to request the engagement of an external expert for this Validation, which had been discussed at a TWG meeting but not submitted as a recommendation to the MSG. The lack of timely record-keeping of MSG and TWG activities was cited as a significant challenge by several CSOs consulted, who considered that the lack of records meant that follow-up on previous MSG decisions was challenging. They considered that the MSG’s conversations on beneficial ownership transparency kept returning to basic explanations of the reasons why such disclosures were required, rather than building on progress to date, given the lack of documented past MSG decisions. Several CSOs consulted considered that there was a practice of ‘revolving doors’ between the government and industry that led to alleged collusion between the two constituencies against civil society’s interests. Three incidences of government employees joining private companies or associations while maintaining their engagement in the EITI were cited as examples of this phenomenon. They explained that they considered that the government always held pro-industry views on the MSG, which was attributed to collusion between government and industry. Government and industry stakeholders consulted denied that these instances had led to any collusion and explained this development by the fact that expertise in the EITI was not commonplace in the Mexican labour market. One stakeholder considered that there had also been a ‘revolving door’ in civil society when the consultant contracted to prepare the 2017-2019 Social and Environmental Report later joined the MSG as a civil society representative. Several CSOs noted that they had sent a letter to the MSG chair raising concerns over this practice, but that the MSG had not instituted any mechanism to avoid the perception of conflict of interest. While most stakeholders consulted considered that the MSG was an independent body, opinions were split on whether the MSG was exercising active and meaningful oversight of all aspects of EITI implementation that balances the three main constituencies’ interests in a consensual manner. While several government and industry representatives considered that this objective had been achieved, none of the CSOs consulted considered that the MSG was effectively overseeing implementation and highlighted concerns over the lack of civility in discussions on the MSG and TWG. The Secretariat’s view is that weaknesses in capacity linked to insufficient support from the national secretariat, combined with perceptions from at least one third of MSG members that the MSG did not balance the three constituencies’ views in practice, mean that the objective has not yet been fulfilled. The weaknesses in MSG capacity and oversight in the period under review have caused gaps in EITI disclosures, for instance in adequately scoping transportations revenues or SOE quasi-fiscal expenditures (see Requirements 4.4 and 6.2). Thus, the Secretariat’s assessment is that Requirement 1.4 is mostly met.

The Secretariat's assessment is that Mexico has exceeded Requirement 3.1. Public access to an overview of the extractive sector in the country and its potential, including recent, ongoing, and planned significant exploration activities is provided through systematic disclosure in government websites and portals, including the GeoInfoMex and the Hydrocarbons Information System registers as well as the Statistical Yearbook of Mining. In the oil and gas sector, information on reserves and resources with significant economic potential are systematically disclosed online. The MX-EITI 2018 Report adds some value by summarizing how these sectors operate today and provides overall numbers of projects in 2018 for mining and hydrocarbons, with references to systematic disclosures on government websites.

The Secretariat's assessment is that Mexico has exceeded Requirement 6.3. The government discloses information on the contribution of the extractive industries to the economy through systematic disclosure as well as through EITI reporting. The mining, oil and gas sectors’ contributions to the economy are provided in both absolute and relative terms, including to GDP, government revenues, exports and employment. While Mexico has not included references to estimates of informal extractive activities such as artisanal mining in its EITI reporting to date, it is unclear whether credible third-party estimates of such activities are available in Mexico. While the disparity between employment data provided in the EITI Report and through government systematic disclosures is a concern, the discrepancies appear due to the fact that the 2018 EITI Report provides employment only of extractive companies that are members of the two professional associations engaged in EITI implementation, not of all extractive companies operating in Mexico. Nonetheless, government systematic disclosures of employment data for the extractive industries are disaggregated by gender. An overview of the location of mining, oil and gas activities is available through government portals maintained by the Geological Survey (SGM) and the hydrocarbons regulator (CNH). There is evidence that the MSG has made efforts to exceed the requirement given the availability of extractive investment data on relevant government websites. There is evidence that Mexico has exceeded Requirement 6.3 given the systematic disclosures of economic data on the extractive industries through government portals, including gender-disaggregated employment data. The government’s data portal provides information on employment in ‘economic units’ in the mining, oil and gas sectors of 10 staff or less, which can be considered a proxy for small-scale and information activities in the mining sector, including data on gender, age, and education level. While the lack of complete data on the value of government extractive revenues in the mining sector, Mexico’s EITI reporting has been transparent about the taxpayer confidentiality constraints and provided credible estimates of the value of government mining, oil and gas revenues in absolute and relative terms. The systematic disclosure of all information on the contribution of the extractive industries to the national economy aside from government mining revenues supports the Secretariat’s assessment that Requirement 6.3 is exceeded.

The Secretariat’s assessment is that Mexico has exceeded Requirement 2.1. The 2018 EITI Report describes the legal, environmental, and fiscal regime for mining, oil and gas, including the roles of government entities, the level of fiscal devolution and ongoing and planned reforms in the extractive sector as a whole. Relevant government websites provide the broader laws and regulations that are summarized in the MX-EITI 2018 Report, including updates on ongoing reforms in the extractive sector, the fiscal regime, fiscal devolution and the roles of government entities.

The Secretariat's assessment is that Mexico has mostly met Requirement 2.4. Mexico EITI has documented relevant government policy for the mining and hydrocarbon sectors and mapped out relevant laws and regulations. All contracts and licenses in the oil and gas sector, including both exploration and production licenses as well as annexes and amendments, have been systematically disclosed on the Rondas website. Entitlements granted to Pemex have also been disclosed on the Ministry of Energy website. However, all licenses and contracts in the mining sector (particularly those awarded or amended in 2021) have not all been comprehensively disclosed to date and the MSG has not explained the reasons for the lack of comprehensive disclosure of mining contracts and licenses in accordance with government policy. The MSG does not yet appear to have prepared a comprehensive list of all active contracts and licenses in the mining, oil and gas sector, clearly indicating which have been published and which have not, with clear links to published documents. It is unclear whether any new mining, oil and gas contracts or licenses have been awarded or amended since the start of 2021 and where these documents are publicly disclosed, where applicable. In its comments on the draft assessment, the MSG noted that the FMP website provided a list of all registered oil and gas contracts. While the FMP list did not provide links to the full text of each contract, these were comprehensively published on the Rondas Mexico website. While Mexico has made exemplary progress on contract disclosure in the oil and gas sector, this level of transparency has yet to be replicated in the mining sector.

The Secretariat’s assessment is that Mexico has made some efforts to disclose information on the environmental impact of the extractive industries. However, Mexico has not yet addressed all aspects of this encouraged provision of the EITI Standard and thus has not yet exceeded Requirement 6.4. Therefore, Requirement 6.4 is marked as not assessed. Mexico EITI’s Social and Environment Report covering 2017-2019 provides some basis for stakeholders to assess the adequacy of the regulatory framework and monitoring efforts to manage the environmental impact of extractive industries, although weaknesses in company participation in reporting raise concerns over the comprehensiveness of disclosures. Therefore, while Mexico has made some effort to ensure that its EITI reporting provides an overview of relevant legal provisions and administrative rules related to environmental management and monitoring of extractive investments in the country, it has not yet used EITI reporting to provide an annual diagnostic of practices in this regard. Information on regular environmental monitoring procedures, administrative and sanctioning processes of governments, as well as environmental liabilities, environmental rehabilitation and remediation programmes has only partly been disclosed publicly.

The Secretariat's assessment is that Mexico has mostly met Requirement 2.2. Mexico systematically discloses some information on the award of mining concessions and oil and gas licenses and contracts. However, while the 2018 EITI Report identifies the awards of mining licenses in 2018, it does not identify the number of license transfers. In oil and gas, the MSG states that there were no new license or contract awards or transfers in 2018, although third-party sources indicate that several dozen new oil blocks were awarded to international oil companies in 2018 through the conclusion of Bid Rounds 2.4 and 3.1 and there appear to have been some transfers of participating interests in oil and gas blocks. In its comments on the draft assessment, the MSG confirmed that there were no new awards of oil and gas licenses and contracts in 2018 aside from those through Bid Rounds 2.4 and 3.1. While Mexico’s EITI reporting has described the statutory procedure for awarding licenses and contracts in the mining, oil and gas sectors, with technical and financial criteria systematically disclosed on government websites, it has not described the process for transferring licenses or contracts (or participating interests therein), including criteria assessed. Nonetheless, information on the statutory procedure for transferring oil and gas contracts (or participating interests therein) is publicly disclosed through the official gazette., In its comments on the draft assessment, the MSG explained that the general process for transferring participating interests in oil and gas contracts was described in the “Guidelines establishing the requirements and procedure for entering into alliances or associations in which the transfer of corporate and management control or control of operations is carried out” issued by the CNH, although they noted that a detailed overview of the statutory transfer procedure was not available to the public. Yet the MSG noted that the CNH’s decisions regarding approvals of transfers were recorded in the CNH Governing Council’s resolutions published in its public registry. The MSG does not appear to have undertaken a review of non-trivial deviations from statutory procedure in license and contracts awards and transfers in either mining or oil and gas. In its comments on the draft assessment, the MSG highlighted that six oil and gas contracts had had modifications approved by the CNH in 2018, providing specific references to the relevant resolutions published on the official gazette website. Oil and gas licenses and contracts can be awarded through competitive tender, with information on the bid criteria and full list of bidders for each awarded block systematically disclosed on the Rondas website. The MSG has not yet used EITI reporting to provide a diagnostic of the efficiency of the licensing and contracting procedures in either mining or oil and gas. The Secretariat’s assessment that Requirement 2.2 is mostly met strikes a balance between robust systematic disclosures of license awards and transfers in the oil and gas sector on the one hand and weaker relevant systematic disclosures in the mining sector.

The Secretariat's assessment is that Mexico has mostly met Requirement 2.3. In mining, there are two registers that provide public access to mining concessions and licenses. In oil and gas, the Rondas website and the Asignaciones website (through the Ministry of Energy) provide public access to oil and gas allotments, associations, and contracts. The registers appear to provide a comprehensive list of entitlements, concessions, associations, and contracts active in the mining, oil and gas sectors, irrespective of the materiality of payments to government associated with each license. Indeed, the coverage of 34,757 mining licenses and concessions in the CartoMinMex portal appears to cover all active mining licenses, irrespective of the materiality of payments associated with each license. While the date of award for Pemex’s entitlements is not explicitly provided on the Asignaciones, stakeholder consultations clarified that all such awards took place on 13 August 2014 through Round 0. The date on which Pemex requested all of these entitlements was 21 March 2014, as confirmed in a press release published on the Ministry of Energy website and in the full text of the entitlements. While most information listed under Requirement 2.3.b is publicly accessible, there are some gaps in information on mining licenses and contracts. In mining, the dates of expiry of each license do not appear publicly disclosed.

The Secretariat's assessment is that Mexico has partly met Requirement 2.5. Mexico's MSG has recently agreed upon a definition of beneficial ownership that includes thresholds for public disclosure. A legal definition of ‘politically exposed person’ is publicly available. There does not appear to be a legal or regulatory framework for the collection and disclosure of beneficial ownership information from extractive companies. While Mexico’s EITI reporting has not included requests for beneficial ownership data, it appears that such data was requested of companies bidding for oil and gas contracts, although the beneficial ownership information on companies bidding for recent oil and gas contracts does not appear to be publicly accessible. More broadly, there does not appear to have yet been an attempt to collect beneficial ownership data from all companies holding or applying for mining or hydrocarbons licenses and contracts since January 2020 in a consistent manner. There is no indication that the MSG has yet undertaken and published a review of the comprehensiveness and reliability of beneficial ownership disclosures to date. It appears unlikely that beneficial ownership information of all extractive companies will be consistently requested and disclosed from January 2022. Equally, information on legal ownership of extractive companies does not appear to be publicly accessible in Mexico.

The Secretariat's assessment is that Mexico has mostly met Requirement 2.6. The 2018 Report has adequately explained the role of the SOE in the oil and gas sector, Pemex. Pemex systematically discloses significant amounts of financial and governance information given the multiple jurisdictions in which it has publicly listed securities. Pemex’s financing is determined by congressional approval as part of the budget every year, which ensures a level of transparency in the statutory entitlements of Pemex in terms of both state and third-party funding. Statutory rules covering Pemex's retained earnings, reinvestment, and third-party financing are also contained in the Petroleum Law. The practice of Pemex’s financial relations with the state are systematically disclosed through Pemex group’s statutory filings to various financial exchanges, given the public listing of its securities in different jurisdictions (Mexico, US, Luxembourg). The financial statements describe Pemex’s interests in subsidiaries and joint ventures, including the terms attached to this equity, they do not cover affiliate companies in which Pemex holds interests. Pemex's consolidated financial statement contains information about loans from the Mexican government to Pemex and Pemex indicates that it does not provide loans or loan guarantees to extractive companies and projects. However, it is less clear where to find information on loans and loan guarantees from the state to any other extractive companies and projects. In mining, the MSG does not appear to consider the two SOEs in the mining sector as material, albeit without justifying this with data. While the first is the Geological Survey (SGM), which might be excluded based on materiality considerations, the second is a commercial salt company, a joint venture between the state and Mitsubishi. This company is likely to give rise to material payments to government, although the MSG does not appear to have considered this in the scope of EITI reporting. Therefore, while the broader objective of Requirement 2.6 appears to have been fulfilled in the oil and gas sector, it does not yet appear to have been addressed in the mining sector.

The Secretariat's assessment is that Mexico has mostly met Requirement 4.2. The state is entitled to in-kind revenues in the oil and gas sector, not in mining. The two in-kind revenues collected by government consist of ‘base royalty’ and ‘additional royalty’. The state appoints a marketing agent to commercialise in-kind revenues on its behalf, namely Trafigura for crude oil and CFEnergía for natural gas in 2018. Information on sales of the state’s in-kind revenues is systematically disclosed through the Economic Information System on the Banxico website, albeit only in aggregate per month, not disaggregated by revenue stream, producing company/project or buyer. The Pemex website discloses information on crude oil sales volumes and values on a monthly basis, albeit not disaggregated by individual buyer. The 2018 EITI Report discloses information on the volumes of in-kind revenues collected by the state in 2018, albeit only disaggregate by company and project, not by revenue stream. The EITI Report does not appear to provide the volumes of the state’s in-kind revenues that were sold in 2018, nor the value of the proceeds of those sales disaggregated by individual buying company. Trafigura’s 2019 Responsibility Report provides the aggregate volumes and values of the company’s purchases of crude oil from Pemex’s subsidiary PMI Trading, it does not disclose the value of Trafigura’s sales of crude oil on behalf of the government. A cursory overview of additional information on the process for commercialising the state’s in-kind revenues is provided in the EITI Report, albeit without a detailed description of the process for selection of marketing agents or buyers nor details of the sales contracts. While Trafigura's reports disclose the volumes of crude oil purchased from the state in Mexico, disaggregated by cargo, it does not provide the values of these purchases.

The Secretariat's assessment is that Mexico has mostly met Requirement 4.5. In mining, the 2018 EITI Report only states that the MSG considered the two SOEs to be non-material, albeit without justification with reference to the value of transactions involving these SOEs in 2018. In oil and gas, the 2018 EITI Report only confirms the lack of dividend payments by Pemex to the state in 2018 but does not clarify whether any other transaction involving Pemex (such as subsidiary dividend payments to the group or federal government transfers to Pemex) were deemed material in 2018. While the audited financial statements of Pemex provide data the SOE’s payments to government and revenues from other companies (subsidiaries, joint ventures, affiliates, other companies), it is unclear from Mexico EITI documents whether the information in the financial statements is comprehensive of all transactions involving the SOE, e.g., including any payments from affiliates engaged in the upstream extractive industries. The lack of explicit MSG review of transactions related to SOEs through EITI reporting is problematic.

The Secretariat's assessment is that Requirement 6.2 is partly met. While the 2018 EITI Report references Pemex's assurances that the SOE did not undertake any quasi-fiscal expenditures, there is evidence of at least two types of Pemex expenditures in the period under review that could be categorised as quasi-fiscal expenditures although only one of these types appears to have been applicable in 2018 (the other commencing in 2019). Pemex appears to provide sales and donations of subsidised fuel and asphalt to state and municipal governments annually, without compensation from the Federal Government or other government agencies. The total value of these donations is provided as Ps 1.3 billion in 2018 according to Pemex’s 2018 audited financial statements. Given the lack of evidence of a distinct materiality threshold set by the MSG for disclosure of quasi-fiscal expenditures, these fuel and asphalt donations appear to consist of material quasi-fiscal expenditures in 2018. While Pemex's systematic disclosures provide the aggregate value of such donations in 2018, it does not provide the value of quasi-fiscal expenditures by beneficiary. Of concern for future EITI reporting, there is no evidence that the MSG has considered Pemex's participation in the Federal Government's Sembrando Vida programme to provide fertilizers to small agriculture producers from 2019 onwards, which could constitute forms of quasi-fiscal expenditures.

The Secretariat's assessment is that Mexico has fully met Requirement 3.2. In the oil and gas sector, production volumes are systematically disclosed online to levels of disaggregation encouraged by the EITI Standard. While specific oil and gas production values are not systematically disclosed, the benchmark prices of oil and gas published allow for estimates of production values to be calculated based on official government data. In the mining sector, production volumes and values are systematically disclosed online, albeit not yet disaggregated to levels encouraged by the EITI Standard.

The Secretariat's assessment is that Mexico has mostly met Requirement 3.3. In the oil and gas sector, export volumes and value are systematically disclosed, albeit not disaggregated by API grade of type of gas nor by region, company, or project. However, the MSG's claim that oil and gas export data provided covers only Pemex exports is concerning. In the mining sector, export values are systematically disclosed by commodity, if not by region, company, or project, while export volumes for mineral commodities are available through the Statistical Yearbook of Mining with the destination country listed, if not the purchasing company or project.

The Secretariat's assessment is that Mexico has partly met Requirement 4.1. The MSG’s decisions on materiality thresholds and scope of EITI reporting remain unclear for 2018. The selection of material revenue streams for reconciliation does not appear to have been based on the government’s full unilateral disclosure of revenues and several revenue streams listed under Requirement 4.1.c do not appear to have been included in the scope of reconciliation. In its comments on the draft assessment, the MSG noted that a total of USD 681m in signature bonus payments were received by government in 2018 (including USD 525m from Bid Round 2.4, USD 124m from Bid Round 3.1, USD 2m from Bid Round 2.3 and USD 30.8m from the Ogarrio partnership concluded in 2017). This raises significant concerns over the omission of signature bonus from the scope of reconciliation. Nonetheless, material revenue streams are identified and described in the 2018 EITI Report. The selection of material companies for reporting appears to have been based on their share of total production, although this does not provide sufficient assurances that all extractive companies making material payments to government in 2018 were included in the scope of reconciliation. Several companies appear to have refused to report, although the 2018 EITI Report only provides the names of non-reporting companies, not the value of each non-reporting company’s payments to government. The significant final unreconciled discrepancies in both mining as well as oil and gas are a concern and raise questions about the comprehensiveness and reliability of reconciled financial data. The 2018 EITI Report does not appear to include a statement by the IA related to the comprehensiveness of the reconciled financial data. The government’s full unilateral disclosure of total extractive revenues is provided, albeit only in aggregate, not disaggregated by individual revenue stream. The 2018 EITI Report provides the target for reconciliation in mining but does not provide the final reconciliation coverage for both mining and oil and gas. The report states that extractive companies’ audited financial statements are publicly accessible but does not provide further guidance on accessing them.

The Secretariat's assessment is that Requirement 4.3 is partly met in Mexico. While the 2018 EITI Report states that there are no infrastructure provisions and barter arrangements in the mining, oil and gas sectors in 2018, the basis for the MSG's assessment is unclear from publicly accessible Mexico EITI documents. It remains unclear whether the MSG and IA have reviewed relevant agreements and revenue flows as a basis for assessing the applicability of Requirement 4.3.

The Secretariat's assessment is that Requirement 4.4 is partly met in Mexico. While the 2018 EITI Report states that there are no transportation revenues in the mining, oil and gas sectors in 2018, the basis for the MSG's assessment is unclear from publicly accessible Mexico EITI documents. It remains unclear whether the revenues from the third-party use of transport infrastructure for oil and gas collected by Pemex Logistica constitute forms of transportation revenues in accordance with Requirement 4.4 and whether these were considered material in 2018. Nonetheless, it is important to note the systematic disclosures by Pemex Logistica in Pemex’s annual financial statements, which provide some information on transport revenues collected from third parties by Pemex Logistica. While there is evidence of the MSG discussing transportation revenues in general terms in preparation of the two EITI Reports published to date, the MSG appears to have omitted Pemex Logistica from the scope of EITI reporting without a clear justification based on the materiality of the transport revenues it collects.

The Secretariat's assessment is that Mexico has mostly met Requirement 4.7. The 2018 EITI Report presents reconciled financial data disaggregated by company, government entity and revenue stream for oil and gas, but only by company and government entity (not revenue stream) in mining. There is no evidence in the public domain of the MSG’s documentation of a definition of the term project, a list of legal agreements that constitute a project, or of the specific revenue streams that are levied on a per-project basis. Although oil and gas revenues are disclosed on a per-project basis, aside from revenues involving Pemex, none of the mining revenues have been disclosed by project to date.

The Secretariat's assessment is that Requirement 4.8 is fully met in Mexico. Mexico EITI financial data has been published in a sufficiently timely manner and the MSG has approved the period for reporting, although more information on the MSG's plans to improve the timeliness of reporting would be welcome.

The Secretariat's assessment is that Mexico has partly met Requirement 4.9. The MSG agreed an approach to disclosure of payments and revenues that is aligned with the standard Terms of Reference for Independent Administrators approved by the EITI Board. While the MSG and IA do not appear to have undertaken a review of government and company audit and assurance practices in 2018 as a basis for agreeing quality assurances for EITI reporting, the quality assurances for EITI are described in the 2018 EITI Report, consisting of a simple management attestation for each reporting entities’ templates. Several reporting entities appear to not have provided the required quality assurances, although the 2018 EITI Report does not list the non-complying government agencies or companies, nor provide an assessment of the materiality of payments from each of the non-complying entities. Of greatest concern, the 2018 EITI Report does not include a statement from the IA related to the comprehensiveness of reconciled financial data, although it does include a statement that the reconciled financial data is considered reliable. Nonetheless, all non-financial information in the 2018 EITI Report appears to be clearly sourced.

The Secretariat's assessment is that Mexico has fully met Requirement 5.1. There are a total of nine government funds to which specific extractive revenues are earmarked and transferred, prior to being recorded in the national budget. These consist of eight funds for oil and gas revenues and one fund for mining revenues. The 2018 EITI Report and public documents such as financial reports describe the management of funds received by the Mexican Petroleum Fund and its transfers to seven other oil and gas funds, while the 2018 EITI Report and systematic disclosures describe he legal provisions governing the statutory management of the mining fund and the value of aggregate revenues transferred to the mining fund in 2018. The Secretariat understands that the mining fund was responsible for subnational transfers in 2018 (prior to a change in mandate in 2019), meaning that the gaps related to disclosures by the mining fund are covered with regards to subnational transfers (see Requirement 5.2). There appears to be sufficient transparency on the revenues accruing to the nine funds in the extractive industries, even if financial reports for the mining fund do not appear accessible for 2018 (although they are for previous years). There is no evidence that the MSG has referenced national revenue classifications in its EITI disclosures to date.

The Secretariat's assessment is that Mexico has made some progress in disclosing revenue management and expenditure information. However, Mexico has not yet addressed all aspects of this encouraged provision of the EITI Standard and thus has not yet exceeded Requirement 5.3. Therefore, Requirement 5.3 is marked as not assessed. The 2018 EITI Report and government portals such as the Secretary of Finance and Public Credit’s website provide information on earmarked extractive revenues, the federal government’s budget and audit procedures as well as some information on projections and assumptions underpinning the budget. However, financial reports describing the management of extractive revenues by certain government funds do not appear publicly disclosed, nor descriptions of the methods for ensuring accountability and efficiency in the use of earmarked funds.

The Secretariat's assessment is that Mexico has partly met Requirement 4.6. While the 2018 EITI Report states categorically that extractive companies do not make any direct payments to subnational governments in Mexico, the basis for the MSG's assessment remains unclear based on publicly available documents. It remains unclear whether mining, oil and gas companies were required to make any payments to subnational governments (e.g., state governments) in 2018.

The Secretariat's assessment is that Mexico has mostly met Requirement 5.2. Mexico EITI has demonstrated that subnational transfers of extractive revenues operate in the oil and gas sector but has not described statutory subnational revenue sharing mechanisms in the mining sector despite evidence that the Fund for Sustainable Regional Development of States and Municipalities (Mining Fund) was operational in 2018. The 2018 EITI Report and public documents provide the general revenue-sharing formulas for the two types of subnational transfers in oil and gas (from the Hydrocarbon Extraction Fund and from the Mexican Petroleum Fund), albeit without the formula’s variables that would allow for calculations of notional subnational transfers. While the value of subnational transfers of oil and gas revenues in 2018 are provided by individual subnational government beneficiary, there is no evidence that the MSG has assessed discrepancies between the transfer amount calculated in accordance with the relevant revenue sharing formula and the actual amount that was transferred between the central government and each relevant subnational entity. There is no information in the 2018 EITI Report on the value of subnational transfers of mining revenues in 2018.

The Secretariat's assessment is that Mexico has partly met Requirement 6.1. With regards to social expenditures, although the 2018 EITI Report and MSG submission for Validation reflect the MSG’s view that there are no social expenditures mandated by law or by contract from oil and gas companies, the Hydrocarbons Law includes provisions requiring oil and gas rights-holders to complete a Social Impact Assessment and commit to a Social Management Plan inclusive of social expenditures. There is no evidence that such mandatory social expenditures by oil and gas companies are publicly disclosed, either in the 2018 EITI Report, the Mexico EITI’s 2017-2019 Social and Environmental Report or in other public documents. As explained in more detail in the MSG’s Transparency template, for those Social Impact Assessments that do outline expenditures, these values are redacted. Mexico EITI references Pemex’s systematic disclosures of social expenditures it categorises as ‘voluntary’ in its annual Sustainability Report, although these are not disaggregated to levels in accordance with Requirement 6.1.a. The Fund for Federal and Municipal Entities Producing Hydrocarbons (pp. 161-162) is assigned revenues meant to be used for social improvement. While overall collected revenues are recorded in the MX-EITI 2018 Report, it is not clear which companies contributed to these funds. Likewise, there are no disaggregated expenditures recorded indicating how revenues located in this fund were used in practice. There do not appear to be any mandatory social expenditures in the mining sector and the MSG does not appear to have worked on disclosures of voluntary social expenditures by mining companies to date. The MX-EITI 2018 Report describes the Fund for Regional Sustainable Development for Mining States and Municipalities (pp. 159-161) and lists total values of revenues collected in the fund. However, as the Social and Environmental Report confirms, it is not possible to trace where these revenues were derived from nor is it possible to trace expenditure of these revenues in disaggregated form. With regards to environmental payments to government, while there is no information on this type of payment in the 2018 EITI Report, Mexico EITI’s 2017-2019 Social and Environmental Report provide some information on extractive companies’ environmental payments to government, although the comprehensiveness of such disclosures is in doubt. While the MSG’s additional report provides disclosures of seven out of 20 oil and gas companies’ environmental payments to government, it provides references to reports on environmental payments of only a minority of mining companies (nine of 31) that are members of CAMIMEX given delays in the association members’ reporting. There is no evidence of outreach to extractive companies that are not members of either AMEXHI or CAMIMEX. While the MSG has undertaken significant efforts in scoping environmental payments by extractive companies, most stakeholders consulted did not consider the disclosures of these environmental payments to be close to comprehensive to date.