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

Outcome of the Validation of Mozambique

Decision reference
2019-57 / 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 Mozambique has partly addressed the corrective actions from the country’s first Validation. Consequently, Mozambique has made meaningful progress overall in implementing the 2016 EITI Standard, with considerable improvements across several individual requirements.

The Board is delighted that government engagement in the EITI has strengthened. EITI implementation has improved coordination between government agencies. Mozambique is encouraged to ensure the sustainability of transparency and multi-stakeholder governance in the extractive sector by completing the institutionalisation of the EITI secretariat. The Board encourages the industry constituency to engage more actively in the EITI to ensure that the process reflects the interests of extractive companies as well. Company representatives on the multi-stakeholder group are expected to liaise with the broader constituency.

Having published EITI Reports covering nine financial years, Mozambique is encouraged to consider routine disclosures to ensure that information is made available in a timely and cost-efficient manner. The Board commends Mozambique for improving the availability of license information. The government is encouraged to use the extractives license portal to disclose granular data related to, for example, production, exports, payments and beneficial ownership.

The Board recognises that significant gaps remain in disclosures related to state participation in the extractive industries. The MSG is encouraged to work with state-owned enterprises (SOEs) and the government agencies overseeing them to ensure that comprehensive information about the policies and practices regarding the financial relationship between the state and SOEs is comprehensively disclosed.

The Board has determined that Mozambique will have 18 months, i.e. until 16 April 2021, before a third Validation to carry out corrective actions regarding industry engagement (1.2), license allocations (2.2), state participation (2.6), comprehensiveness (4.1), in-kind revenues (4.2), barter agreements (4.3), SOE transactions (4.5), subnational payments (4.6), data quality (4.9), subnational transfers (5.2), social expenditures (6.1), quasi-fiscal expenditures (6.2), economic contribution (6.3) and public debate (7.1). 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, Mozambique’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 Mozambique. 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, companies should demonstrate that they are fully, actively and effectively engaged in the EITI process. The company constituency should establish mechanisms for communicating about the EITI with companies beyond the MSG and play an active role in setting objectives for EITI implementation in the country.

  2. In accordance with Requirement 2.2, Mozambique is required to disclose licenses awarded and transferred in the period covered by the EITI Report and ensure that information about the licenses is publicly available, for example in the license cadastre or on the INAMI and INP websites, provided that the continuous functioning of these websites is guaranteed. Mozambique is encouraged to disclose the process and criteria for transferring a petroleum license. INAMI and INP are encouraged to carefully consider the recommendations presented in the report on strengthening the license allocation process.

  3. In accordance with Requirement 2.6, Mozambique should provide a comprehensive explanation of the prevailing rules and practices regarding the financial relationship between the government and state-owned enterprises (SOEs), including the rules and practices governing transfers of funds between the SOE(s) and the state, retained earnings, reinvestment and third-party financing. The government should also disclose a comprehensive account of any loans or loan guarantees extended by the state or SOEs to mining, oil, and gas companies operating in the country. The government should also disclose details regarding the terms attached to their equity stake in each project, including their level of responsibility to cover expenses at various phases of the project cycle, e.g., full-paid equity, free equity, carried interest. The MSG should discuss and document its definition of SOEs taking into account the different arrangements for state participation defined in national laws, government structures and ongoing reforms.The government and the MSG are encouraged to undertake a study on the rules and practices of state participation in the extractive sector. Government agencies, such as INP, INAMI, IGEPE, the tax authority (TA) and state-owned enterprises are encouraged to routinely disclose data about the extractive sector through their own reporting systems and websites.

  4. In accordance with Requirement 4.1, the MSG should clearly justify the selection of material revenue streams by demonstrating that the omission of some revenue streams does not materially affect the comprehensiveness of the EITI Report. The MSG is encouraged to consider raising the threshold for selecting material companies to ensure a cost-benefit balance in reconciliation. Mozambique should document the options considered and the rationale for establishing the materiality definitions and thresholds. Mozambique should disclose aggregate information about the amount of total revenues received from each of the benefit streams agreed in the scope of the EITI Report, including revenues that fall below the agreed materiality threshold.

  5. In accordance with the Requirement 4.2, Mozambique is required to annually disclose the volumes of in-kind royalty gas sold to each company and the resulting revenues received by the government from each individual buying company. Mozambique is encouraged to disclose the contracts underlying the allocation of in-kind royalty gas.

  6. In accordance with Requirement 4.3, the MSG is required to consider whether there are any agreements, or sets of agreements involving the provision of goods and services (including loans, grants and infrastructure works), in full or partial exchange for oil, gas or mining exploration or production concessions or physical delivery of such commodities. Where the MSG concludes that these agreements are material, the MSG and the Independent Administrator are required to ensure that the EITI Report addresses these agreements, providing a level of detail and transparency commensurate with the disclosure and reconciliation of other payments and revenues streams. Where reconciliation of key transactions is not feasible, the MSG should agree an approach for unilateral disclosure by the parties to the agreement(s) to be included in the EITI Report. The MSG should clarify whether EITI reporting comprehensively addresses the possible existence of such agreements not covered in the report, and ensure that it is clearly stated if they do not exist.

  7. In accordance with Requirement 4.5, Mozambique is required to ensure that the EITI reporting process covers all dividends received by the state from reporting entities. Mozambique is encouraged to disclose financial transactions between extractive SOEs and their subsidiaries.

  8. In accordance with Requirement 4.6, it is required that the MSG establishes whether direct payments from companies to subnational governments are material. Where material, Mozambique must ensure that direct company payments to subnational government entities are disclosed and reconciled in future EITI Reports. If the central government does not have data about subnational payments, as a practical solution, the MSG is encouraged to ask companies to submit data on payments to subnational government entities.

  9. In accordance with Requirement 4.9, Mozambique should ensure that (1) the procurement of Independent Administrators for future EITI Reports follows the Standard Terms of Reference agreed by the EITI Board, (2) the MSG’s decisions on reporting templates and data assurances are clearly documented, (3) EITI Reports clearly document whether payments and revenues are subject to credible, independent audit and whether assurances agreed by the MSG were complied with and (4) the IA submits electronic data files and summary data in accordance with the latest template provided by the International Secretariat The MSG is encouraged to assess the reliability of non-financial information, disclose how government entities collect the data and make recommendation for strengthening data reliability.

  10. In accordance with Requirement 5.2, Mozambique should ensure that the specific formula for calculating transfers to individual local governments be disclosed, to support an assessment of whether executed subnational transfers correspond to the formula defined in legislation. Mozambique is encouraged to follow up on the EITI Report’s observations regarding weaknesses in the management of subnational transfers. Mozambique could also consider reviewing and drawing on the various publicly accessible sources of information related to subnational transfers published by the Ministry of Economy and Finance and the Administrative Court (Tribunal Administrativo) in its EITI reporting.

  11. In accordance with Requirement 6.1, Mozambique should clarify whether all companies making material mandatory social payments are comprehensively disclosing information about such payments. Companies should distinguish whether mandatory social expenditures are made in kind or in cash. Where beneficiaries of mandatory social expenditures are a third party, i.e. not a government agency, Mozambique should ensure that the name and function of the beneficiary be disclosed. The MSG should provide a comprehensive overview of existing social expenditures by oil, gas and mining companies, and further clarify how disbursement from social funds are being made and the basis for selection of beneficiaries.

  12. In accordance with Requirement 6.2, Mozambique should undertake a comprehensive review of all expenditures undertaken by extractives SOEs that could be considered quasi-fiscal. Mozambique should develop a reporting process for any quasi-fiscal expenditures undertaken by extractives SOEs with a view to achieving a level of transparency commensurate with other payments and revenue streams.

  13. In accordance with Requirement 6.3, Mozambique is required to publish a comprehensive figure of total government revenues generated by the extractive industries and an estimate of informal mining activity. Mozambique may wish to ensure that figures of total government revenues from the extractive industries published by government agencies such as the Administrative Court (Tribunal Administrativo) and the tax authorities are consistent.

  14. In accordance with Requirement 7.1 and to facilitate the use and analysis of data by stakeholders, the MSG should ensure that data from EITI Reports is published in open format (xlsx or csv). The MSG is encouraged to seek funding from the government, companies or development partners to communicate the findings and results of EITI disclosures.

Mozambique is encouraged to also consider the strategic recommendations in the Secretariat assessment.


Mozambique joined the EITI in 2009 and was declared compliant with the EITI Rules in 2012. Mozambique’s second Validation commenced on 25 April 2019. The EITI International Secretariat has assessed the progress made in addressing the 19 corrective actions established by the EITI Board following Mozambique’s first Validation in 2017. The 19 corrective actions related to:

  1. Government engagement (Requirement 1.1)
  2. Industry engagement (Requirement 1.2)
  3. MSG governance (Requirement 1.4)
  4. License allocations (Requirement 2.2)
  5. License register (Requirement 2.3)
  6. State participation (Requirement 2.6)
  7. In-kind revenues (Requirement 4.2)
  8. Infrastructure provisions and barter arrangements (Requirement 4.3)
  9. Transportation revenues (Requirement 4.4)
  10. Transactions related to SOEs (Requirement 4.5)
  11. Direct subnational payments (Requirement 4.6)
  12. Data quality and assurance (Requirement 4.9)
  13. Distribution of extractive industry revenues (Requirement 5.1)
  14. Subnational transfers (Requirement 5.2)
  15. Social expenditures (Requirement 6.1)
  16. Quasi-fiscal expenditures (Requirement 6.2)
  17. The contribution of the extractive sector to the economy (Requirement 6.3)
  18. Public debate (Requirement 7.1)
  19. Discrepancies and recommendations from EITI Reports (Requirement 7.3).

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

  • The 2015-2016 EITI Report was published in February 2018.[1]

  • Constituencies appointed new representatives to the MSG through free and open processes. Additional state entities and SOEs were invited to observe meetings.

  • A Coordinating Commission was appointed to act as an interim national secretariat.

  • The MSG discussed the corrective actions in a retreat in late 2018 and agreed an operational plan for 2019-2021.[2]

  • The Coordinating Commission has developed a draft study on aligning the scope of the EITI Standard to the institutional and regulatory context of Mozambique.[3]

Mozambique’s second Validation commenced on 25 April 2019. The Secretariat assessed the progress made in addressing the 19 corrective actions established by the EITI Board. The EITI International Secretariat’s assessment is that Mozambique has fully addressed six of the 19 corrective actions, with significant improvements on two other outstanding requirements.  The assessment of progress of Requirement 4.4 as ‘satisfactory’ is subject to consideration of information disclosed after the commencement of Validation. In addition, the Secretariat found that progress in implementing Requirement 4.1 has fallen below ‘satisfactory’.

The draft assessment was sent to the Multi-Stakeholder Group (MSG) on 12 June 2019. Following MSG comments received on 3 July, the assessment was finalised for consideration by the EITI Board

Scorecard for Mozambique: 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

Minister of Mineral Resources and Energy Max Tonela and his predecessor Leticia Klemens have demonstrated active engagement in the EITI. Implementation is more embedded into government agencies and their discussions than before.

1.2Company engagement

The challenges appear to be largely the same as identified in the first Validation. Companies do not appear to be fully, actively and effectively engaging in the design, implementation and monitoring of EITI implementation. Communication on the EITI within the constituency is weak.

1.3Civil society engagement

Civil society is fully, actively and effectively engaged in the EITI process and has contributed significantly to EITI implementation in Mozambique. Civil society representatives’ ability to participate in the EITI process does not appear to have been restricted or affected by the legal, regulatory, administrative and actual environment. Civil sociery has played an active role in overseeing the EITI reporting process and contributing to public debate related to extractive sector governance.

1.4MSG governance

The MSG consists of self-appointed representatives from each constituency and functions in an equitable, inclusive manner. The constituencies are adequately represented, although participationby companies continues to be limited (see Requirement 1.2). Civil society and government representatives appear to communicate and coordinate on the EITI with their broader constituencies.

1.5Work plan

The MSG has agreed a work plan which reflects the national priorities for the sector, and there is evidence of progress in more clearly articulating the objectives of EITI implementation.

Licenses and contracts

2.2License allocations

The process for awarding licenses is comprehensively disclosed, and the Secretariat commends the EITI Report for critically assessing the licensing framework and for making recommendations to address deficiencies. However, the report does not include a list of licenses awarded and transferred in the period under review, and the license cadastre does not allow the user to search for licenses by award or transfer date.

2.3License register

The mining cadastre includes detailed information on mining licenses. Required data points for petroleum licenses are available on the INP website.

2.4Policy on contract disclosure

The 2013-14 EITI Report outlines the government’s policy on contract transparency as mandated by the 2014 Petroleum and Mining Laws, as well as actual practice.

2.1Legal framework

The 2013-14 EITI Report provides a summary description of the fiscal regime, including the level of fiscal devolution, an overview of the relevant laws and regulations, and information on the roles and responsibilities of the relevant government agencies involved in the governance of the petroleum and mining sectors.

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. Stakeholders from civil society and industry expressed interest in making ownership information transparent.

2.6State participation

The 2015-2016 EITI Report discloses the level of state ownership and describes state participation in general terms. However, the policy defining the financial relationship between the state and extractive sector SOEs remains unclear and practices are only partly covered.

Monitoring production

3.1Exploration data

The 2013-14 EITI Report includes a comprehensive overview of both the mining and oil and hydrocarbon sector, including reserves, new development projects and ongoing exploration activities.

3.2Production data

The 2013-14 EITI Report includes information on production values and volumes, and has attempted to obtain information disaggregated by company through the EITI reporting process.

3.3Export data

The 2013-14 EITI Report includes information on production values and volumes, and has attempted to obtain information disaggregated by company through the EITI reporting process.

Revenue collection

4.3Barter agreements

The 2015-2016 EITI Report attempts to address the requirement regarding agreements concluded in the period underreview. However, the terms of these agreements are not detailed, and it remains unclear whether they actually contain infrastructure or barter provisionsin exchange for oil, gas or mining concessions. Stakeholder consultations suggest that agreements that fall under the requirement do not exist in Mozambique, which could indicate that the requirement is not applicable. However, the MSG does not appear to havethoroughlydiscussed the matter or investigated the agreements presented in the EITI Report.

4.6Direct subnational payments

The materiality of subnational payments by extractive companies remains unclear.


The 2013-14 EITI Report contains financial data disaggregated by individual company and revenue flow. The data is not explicitly disaggregated by government entity, although it indicates which entity receives each revenue stream.

4.9Data quality

Discrepancies in the 2015-2016 EITI Report were not material, and at least company data appears to be backed by agreed assurances. However, the report does not include an assessment of the reliability of financial data or document companies’ compliance with agreed assurances. It is unclear whether any assurances were requested from government entities. The report does not provide an overview of the audit practices of reporting entities.


The comprehensiveness of reconciliation of 2015-2016 data cannot be reliably assessed as total government revenues from the extractive sector are unknown and the rationale behind materiality decisions is not disclosed.

4.2In-kind revenues

The 2015-2016 EITI Report and the Administrative Court’s report include comprehensive information about gas royalties paid in-kind. However, the value of proceeds from the sale of in-kind gas revenues in 2015-2016 is not clear. There are also discrepancies between the information disclosed in the EITI Report and that provided in the MSG’s feedbac kon the draft assessment.

4.4Transportation revenues

The report describes thoroughly the actors involved in the transportation of gas and coal, changes in ownership structuresand transportation routes. The Secretariat considers that ROMPCO’s revenues from the transport of gas are not government revenue as such, but any material revenues that CMG as an SOE receives from its shareholding in ROMPCO are transportation revenues as defined in Requirement 4.4. The information in to included ibn the 2015-2016 EITI Report but was subsequently disclosed.

4.5SOE transactions

The 2015-2016 EITI Report discloses payments from SOEs to government entities in material revenue streams. However, the report does not disclose transaction between SOEs and their subsidiaries. It remains unclear, whether the National Directorate of Treasury (DNT) received dividends from extractive companies, as it was not a reporting entity.

4.8Data timeliness

The 2013-14 EITI Report was published less than one year following the end of the latest financial year covered by the report.

Revenue allocation

5.1Distribution of revenues

The 2015-2016 EITI Report discloses which revenues are recorded in the national budget and describes the allocation of revenues that are not.

5.2Subnational transfers

Details about actual transfers are disclosed,and efforts to reconcile the data and include information about the use of funds are commendable. The report demonstrates that transfers corresponded to the budgeted amounts. However, it remains unclear whether actual transfers represent 2.75% of the collected production tax in the base year and how the portion transferred to each community is calculated.

5.3Revenue management and expenditures

Not assessed

The 2013-14 EITI Report includes a description on allocation of revenue from extractives for specific programs and geographic regions. There is no additional information such as projected production, commodity prices and revenue forecasts. 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.

Socio-economic contribution

6.1Mandatory social expenditures

The 2015-2016 EITI Report clearly differentiates between mandatory and voluntary social expenditures. However, it is unclear whether disclosures of mandatory social expenditures in the EITI Report are comprehensive.The legal basis for mandatory expenditures isunclear. The report does not disclose beneficiaries of mandatory social contributions nor whether the contributions were made in cash or in kind.

6.2Quasi-fiscal expenditures

There is no indication that SOEs currently undertake quasi-fiscal expenditures (QFEs).However, the lack of QFEs in the year under review could not be confirmedand the MSG does not appear to have undertaken a comprehensive review of QFEs as part of preparations for the 2015-2016 EITI Report.

6.3Economic contribution

The 2015-2016 EITI Report discloses information about the extractive sector’s contribution to the GDP, exports and employment. However, inconsistencies between the EITI Report and other publicly accessible sources in total government revenue figures prevent a comprehensive understanding of the sector’s contribution to the economy.

Outcomes and impact

7.2Data accessibility

EITI Mozambique has made various efforts to make data available such as producing summary briefs and brochures. However, all EITI Reports published by Mozambique EITI are in PDF format and are not machine-readable which makes accessibility to data files challenging.

7.4Outcomes and impact of implementation

The multi-stakeholder group (MSG) has reviewed the outcomes and impact of EITI implementation on natural resource governance through the production of annual progress reports.

7.1Public debate

The MSG is undertaking efforts to ensure that EITI implementation is contributing to public debate. Especially civil societyhasanalysedthe data and conductedoutreach across the country. Providing comprehensive and timely information onissues of broad public interest, such as state participation in the extractive sector, could result in further debate. The interim national secretariat’s efforts to engage with parliamentarians are encouraging. However, EITI data is not published in open format, which makes it more difficult to analyse. The lack of financial resources is limiting the MSG’s efforts to communicate findings from the report.

7.3Follow up on recommendations

There is no documentation of the MSG systematically following up on recommendations from the 2015-2016 EITI Report. However, the MSG and individual constituencies have considered recommendations and acted upon lessons learnt from EITI reporting and the first Validation.The identified weaknesses and opportunities are reflected in work plans.