Guidance note 2 on developing an EITI work plan, including template
The EITI work plan forms the foundation for all EITI activities in implementing countries and ensures that implementation activities are targeted to deliver the results desired by stakeholders. Based on the EITI Standard and discussions about challenges and priorities for the extractive industries, the multi-stakeholder group, in consultation with key stakeholders, should develop a work plan that sets out why the EITI is being implemented, the national priorities for developing and governing the extractive industries, and the EITI implementation objectives. The EITI objectives should reflect the circumstances, challenges and opportunities in the country, and stakeholders’ expectations for how the EITI can contribute to developments and reforms. The EITI can be implemented to address specific concerns about corruption or lack of trust, to address quality of public expenditure, to attract foreign direct investment, or simply to bring all key data about the sector together in one place.
Requirement 1.5 of the EITI Standard sets out a number of requirements on what the work plan must contain. This note explains requirement 1.5 in more detail, and proposes a five-step approach for how a work plan could be elaborated namely: (1) Identify national priorities for the extractive sector; (2) Define objectives for implementation; (3) Agree the activities needed to achieve the objectives; (4) Endorse and publish the work plan; and (5) Monitor and revise. The note draws from experiences gathered thus far and provides examples and suggestions for further reading.
Step 1: Identify national priorities for the extractive sector
Step 2: Define objectives for EITI implementation
Step 3: Agree the activities needed to achieve the objectives
Step 4: Endorse and publish the work plan
Step 5: Monitor and revise
One of the most important changes to the 2016 EITI Standard was the inclusion of provisions to encourage systematic disclosure. Transparency should be an integral feature of how governments manage the extractive industries. Rather than relying on the EITI reporting mechanism to bring about transparency, governments implementing the EITI should make the information required by the EITI Standard available through government and corporate reporting systems such as databases, websites, annual reports and portals while ensuring the quality and comprehensiveness of the data is maintained.
In February 2018, the Board reaffirmed that implementing countries are expected to take steps to integrate EITI implementation in company and government systems. Systematic disclosure is the default expectation, with EITI Reports to be used where needed to address any gaps and concerns about data quality. In taking this decision, the Board recognised that implementing countries face challenges in fully mainstreaming EITI implementation. In some countries, this transition will require substantial reforms and sustained political, technical and financial support. Not all countries will be able to transition to systematic disclosure at the same speed.
Concretely, all implementing countries are expected to develop a costed work plan that includes steps to mainstream EITI implementation in company and government systems within 3-5 years, with the scope to seek a longer transitional period where needed. This approach acknowledges that the circumstances differ in each country, that not all countries will be able to transition to systematic disclosure at the same speed, and that the financial implications need to be considered, both in the near and long-term. The MSG may request a longer transitional schedule where needed. Some MSGs may wish to maintain separate EITI work plans and mainstreaming roadmaps. Alternatively, these can be combined into a single document.
Requirement 1.5 of the Standard requires that the multi-stakeholder group maintains a current work plan, fully costed and aligned with the EITI reporting and Validation deadlines established by the EITI Board.
The work plan must:
a) Set EITI implementation objectives that are linked to the EITI Principles and reflect national priorities for the extractive industries. The multi-stakeholder group is encouraged to explore innovative approaches to extending EITI implementation to increase the comprehensiveness of EITI reporting and public understanding of revenues, and encourage high standards of transparency and accountability in public life, government operations and in business.
b) Reflect the results of consultations with key stakeholders, and be endorsed by the multi-stakeholder group.
c) Include measurable and time-bound activities to achieve the agreed objectives. The scope of EITI implementation should be tailored to contribute to the desired outcomes and impact that have been identified during the consultation process. The work plan must:
i. assess and outline plans to address any potential capacity constraints in government agencies, companies and civil society that may be an obstacle to effective EITI implementation;
ii. address the scope of EITI reporting, including plans for addressing technical aspects of reporting, such as comprehensiveness and data reliability (4.1); and
iii. identify and outline plans to address any potential legal or regulatory obstacles to EITI implementation, including, if applicable, any plans to incorporate the EITI Requirements within national legislation or regulation.
v. outline plans for disclosing beneficial ownership information in accordance with clauses 2.5(c)-(f), including milestones and deadlines.
d) Identify domestic and external sources of funding and technical assistance where appropriate in order to ensure timely implementation of the agreed work plan.
e) Be made widely available to the public, for example published on the national EITI website and/or other relevant ministry and agency websites, in print media or in places that are easily accessible to the public.
f) Be reviewed and updated annually. In reviewing the work plan, the multi-stakeholder group should consider extending the detail and scope of EITI reporting including addressing issues such as revenue management and expenditure (5.3), transportation payments (4.4), discretionary social expenditures (6.1.b), ad-hoc subnational transfers (5.2.b), beneficial ownership (2.5) and contracts (2.4). In accordance with Requirement 1.4.b (viii), the multi-stakeholder group is required to document its discussion and decisions.
g) Include a timetable for implementation that is aligned with the reporting and Validation deadlines established by the EITI Board (8.1-8.4) and that takes into account administrative requirements such as procurement processes and funding.
Source: EITI Standard, p. 18-19
Simply put, the work plan should define and explain:
- What the MSG wants to achieve through the EITI:
- Which national priorities and issues does the MSG want to address and why?
- How does the MSG aim to ensure systematic disclosure of EITI data and to meet all the requirements of the EITI Standard? The MSG is strongly encouraged to conduct a systematic disclosure mapping or feasibility study to inform these discussions.
- What steps does the MSG intend to take to ensure that systematic disclosure implementation takes into account differences in access, literacy, and technical knowledge of the range of public data consumers, with a particular focus on women, minority groups, and other sub-groups of citizens with potentially limited access?
- How will the MSG ensure the provision of gender statistics and gender-disaggregated data when relevant?
- How the MSG plans to achieve these objectives:
- Which EITI requirements are already systematically disclosed, what reforms are underway, and what additional reforms are needed?
- Which activities will the MSG organise to gain buy-in from all constituencies and relevant government and corporate entities?
- What challenges exist and how will the MSG mitigate or address them?
- What assistance is needed to achieve these objectives?
- When the MSG plans to undertake these activities?
- Whois responsible for undertaking the activities? What additional technical expertise is required (e.g. gender expertise)?
- How much the activities are expected to cost and how the process will be financed?
- How will the MSG track progress and ensure effective implementation of the work plan?
The EITI International Secretariat proposes the following five-step approach to developing a work plan:
According to the EITI Standard the work plan must “set EITI implementation objectives that are linked to the EITI Principles and reflect national priorities for the extractive industries” (Requirement 1.5.a), “reflect the results of consultations with key stakeholders” (Requirement 1.5.b). In order to identify national priorities for the extractive sector, the MSG is advised to:
- Identify and consult EITI stakeholders regarding their views on the priorities for the management of the extractive sector. Consultations could be conducted through national or regional workshops, or through an active and open invitation to all citizens through national and local media, using inclusive approaches that are gender-responsive.
- Consider government policies or strategies for the extractive sector, public debates about issues in the extractive sector, and analysis and research undertaken by government, media, NGOs, companies or other institutions.
- Review the EITI Principles, the Standard and the findings of Validation reports or EITI Reports where available, including any recommendations following from these reports.
- Consider any existing reform efforts aimed at improving extractive industry governance in the country, and how the EITI may be linked operationally or financially to these efforts. The MSG should consider efforts gaining buy-in for ensuring ‘transparency at source’ by advocating for systematic disclosure of EITI data by government and corporate entities. As noted above, the MSG is strongly encouraged to conduct a systematic disclosure mapping or feasibility study to inform these discussions.
Subsequent to the consultations, the MSG may wish to categorise and prioritise the issues identified with a view to agreeing on priorities to be addressed through the EITI. In order to ensure relevance of the EITI process, the MSG may wish to emphasise data that can inform any major debates or concerns related to natural resource management in the country. The MSG is also encouraged to consider whether the issues identified can be addressed by data provided through the EITI, or whether complementary measures or other instruments are needed. In doing so, the MSG may wish to review the EITI Principles and the EITI Standard to explore how the issues identified fit with the overall goals of the EITI.
Examples of resources that can help identify priorities for the extractive sector:
Case study: identifying challenges and priorities
On 7-9 October 2013, some 30 government, industry and civil society representatives from Albania, Azerbaijan, Kazakhstan, Kyrgyz Republic, Mongolia, Tajikistan and Ukraine gathered in Astana to discuss the EITI Standard and share views on what they want to achieve through the EITI in their countries:
Implementing country examples: Addressing the challenges of gender in the Extractive Industries
Some EITI implementing countries have begun to include initiatives to advance gender equality in the activities that form part of the MSGs annual work plans. The 2017-2019 Burkina Faso work plan includes several activities specifically targeting women. These included a training session targeting female members of parliament on women in mining, a television debate on female leadership in the sector and awareness campaigns on the condition of women in artisanal and small-scale mining. The Malawi 2015-2017 work plan included an activity to undertake a gender-based study on fiscal regime and socioeconomic impacts with gender disaggregated data along the decision/value chain in the extractives sector.
Key information about the governance of the sector is reported annually alongside recommendations for improving sector governance through EITI Reports and data portals. Gender-disaggregated EITI data is already being disclosed in some EITI Reports, particularly with respect to employment statistics. For example, the Philippines 2016 EITI Report, includes a summary of employment data by participating entities for 2014. The report provides information on female permanent and contractual workers, which is further disaggregated by indigenous peoples.
Case study: Making the EITI relevant in Mongolia by addressing environmental aspects
Environmental aspects of natural resource management are considered important to many EITI stakeholders in Mongolia. Extractive companies therefore disclose details about funds transferred to the government for environmental rehabilitation. Mongolia’s 2012 EITI report also includes a survey on the implementation of environmental protection and remediation activities (technical remediation, top soil remediation, and biological remediation), on the basis of reports provided by the Mongolian Mineral Resources Authority.
Mainstreaming feasibility study: Pilot Study in the Republic of Kazakhstan
As of August 2017, Kazakhstan had published 11 national EITI Reports on an annual basis. However, despite the progress made through EITI Reports, the Kazakh MSG and national secretariat (Kazakh EITI) decided that extractive industry transparency should not be limited only to production of annual EITI Reports and rather become an integral part of the overall extractive sector governance mechanism in the country. Kazakh EITI therefore commissioned a pilot study to explore how Kazakhstan could mainstream EITI reporting, ensuring that the relevant government and corporate entities systematically disclose all the information required by the EITI Standard.
The study focused on the contemporary reporting environment in the Kazakh economy, including identification of existing data portals, gaps and duplication of data. Based on this analysis the study outlined recommendations and a roadmap aimed at improving extractive industries data reporting systems, thus contributing to reduction of costs of EITI Reports and making Kazakh EITI’s efforts more relevant. For more information, please review the study in either English or Russian.
Based on the priorities identified, the MSG should develop objectives for implementation. Objectives should set out what the MSG wants to achieve through the EITI, and should thus reflect the priorities identified. In formulating objectives, the MSG is advised to:
- Consider applying a SMART (Specific, Measurable, Achievable, Relevant, Time-bound) design.
- Consider complementing the objectives with a short narrative explaining the rationale.
- Consider how objectives relate to existing recommendations from Validation and EITI reporting (and where applicable, the findings from systematic disclosure feasibility studies).
- Consider how the development of the extractive industries can contribute towards achieving gender equality, including through EITI implementation and work plans that are designed according to the principles of accountability and through the disclosure of gender-disaggregated data in the extractive industries (employment, local procurement, training, etc).
Examples of work plan objectives:
Example of establishing the relevance of an issue for national debates and priorities: Beneficial ownership
EITI countries have outlined plans for disclosing beneficial ownership information in accordance with national objectives for beneficial ownership disclosure in their work plans or roadmaps, in accordance with requirement 1.5.c. v. This includes establishing national objectives for beneficial ownership disclosure.
Some examples include addressing tax evasion and transfer mispricing by improving ownership information available to tax authorities (Ghana); reducing conflict of interest in license allocation by ensuring due diligence in mining licensing (Sierra Leone); pursuing anti-corruption and anti-money laundering reform by requiring ownership disclosure for all companies (Ukraine); and attracting and diversifying investment to allow investors to know who they are doing business with.
More information on making a plan for beneficial ownership disclosure in EITI Guidance note 22: eiti.org/GN22
According to the EITI Standard, the work plan must “include measurable and time bound activities to achieve the agreed objectives. The scope of EITI implementation should be tailored to contribute to the desired outcomes and impact that have been identified during the consultation process.” (EITI Requirement 1.5.c). Once the objectives have been defined, the MSG needs to decide what activities it plans to undertake to reach its objectives, including:
- Ensuring that the work plan contains the activities necessary to achieve the objectives and to implement the recommendations from Validation, systematic disclosure feasibility studies and EITI reporting.
- Ensuring that the work plan reflects activities related to the various aspects of EITI reporting: including systematic disclosure of contextual information; technical aspects of reporting, such as comprehensiveness, data availability and disaggregation where applicable and data reliability; and plans for communicating and disseminating EITI data.
- Ensuring that the work plan adequately outlines plans for disclosing beneficial ownership information in accordance with requirement 2.5, or refers to the beneficial ownership disclosure roadmap.
- Identifying potential constraints(expertise, data gaps, capacity, finances, legal, administrative) that may affect implementation of the activities.
- Assigning responsibilities for the various activities to relevant stakeholders. This may in some cases require the involvement of stakeholders beyond those represented on the MSG (for instance for activities related to beneficial ownership disclosure), and consultation with such stakeholders might be necessary. In some countries, an assessment of integrating multi-stakeholder consultation and oversight into existing representative bodies may be useful.
- Elaborating a time frame for implementing the activities. The timeframe should take into account the deadlines established by the EITI Board for production of EITI Reports, annual activity reports and Validation. In developing the timetable, the MSG also needs to take into account administrative requirements such as procurement processes and funding.
- Estimating the cost of the activities and identifying how these will be funded.
At this point, once there is further clarity on and definition of the objectives and activities, the MSG may wish to revisit the question of prioritising. The constraints, activities, costs, etc. could be applied as criteria in establishing which objectives to aim for, and in which order. A matrix such as provided in Annex 1 could assist in such a prioritisation exercise. A template for outlining actions from EITI Report recommendations is also available in Guidance Note 20 on Developing, implementing and monitoring recommendations from EITI reporting.
Examples of work plan activities linked to objectives:
Objective: Provide timely, comprehensive and reliable information about how licenses are awarded in [country]. This will enable stakeholders to understand on what basis rights to exploit natural resources are granted.
Activity 1: Produce an overview of blocks that are being awarded in [country’s] 10th licensing round, including the applicable process, criteria (if any) and guidelines.
Activity 2: Publish a list of bidders.
Activity 3: Produce a template for disclosing information about how each block is awarded, in accordance with requirement 3.9 and 3.10 of the EITI Standard, and collect information from the relevant parties.
Activity 4: Ensure the agency performs a systematic and regular publication of the list of bidders, and to regularly monitor this practice.
For Zambia EITI, systematic disclosures were deemed to be in line with the overall objective of ZEITI. In fact, at the time of writing the MSG in Zambia were in the process of approving the inclusion efforts to mainstream EITI disclosures, ensuring that EITI disclosures are made systematically. The below screenshot shows how they related the activities to the overall objectives of ZEITI.
Example of systematic disclosures as part of the work plan: Zambia EITI’s draft work plan for 2018/2019
Click on the image to enlarge
In accordance with requirement 1.5.e, “the work plan must be made widely available to the public, for example published on the national EITI website and/or other relevant ministry and agency websites, in print media or in places that are easily accessible to the public”.
The MSG may find it helpful to organise the work plan in a format that is easy to use, monitor and revise, such as a table or a diagram. A template is provided in Annex 1.
The MSG may wish to attach narrative reports, or other documents complementing their work plans, including:
- A systematic disclosure feasibility study, assessing what EITI information is already systematically disclosed;
- A Gantt-chart, presenting a project schedule;
- A fully costed and long-term work plan as well as a one-year excerpt;
- A running calendar, with dates of activities and events;
- A set of Key Performance Indicators, to monitor progress, performance and impact;
- A gender-responsive communications plan.
Example: Philippines’ work plan
The Philippines EITI (PH-EITI) website contains a detailed narrative description of how the work plan was elaborated. The website also explains the issues that PH-EITI aims to address, the rationale behind the objectives, the planned activities, and how the different elements of the EITI process link to other reform efforts:
The work plan is a living document, which must be reviewed and updated annually:
Requirement 1.5 of the Standard requires that the multi-stakeholder group maintains a current work plan (…)” which must be “reviewed and updated annually.” (Requirement 1.5.f)
“In reviewing the work plan, the multi-stakeholder group should consider extending the detail and scope of EITI reporting including addressing issues such as revenue management and expenditure (5.3), transportation payments (4.4), discretionary social expenditures (6.1.b), ad-hoc subnational transfers (5.2.b), beneficial ownership (2.5) and contracts (2.4)”. (Requirement 1.5.f)
“The multi-stakeholder group is encouraged to explore innovative approaches to extending EITI implementation to increase the comprehensiveness of EITI reporting and public understanding of revenues, and encourage high standards of transparency and accountability in public life, government operations and in business.” (Requirement 1.5.a)
In order for the work plan to be useful as a management tool, the MSG is advised to consider more regular updates and revisions. The MSG could, for example, agree to revisit briefly the work plan during each of its meetings to take stock of progress.
Revising the work plan is also essential to reflect lessons learned and integrate the recommendations for improvement, as for example presented by the Independent Administrator:
“The multi-stakeholder group is required to take steps to act upon lessons learnt, to identify, investigate and address the causes of any discrepancies; and to consider recommendations for improvement from the Independent Administrator.” (Requirement 7.3).
And requirement 1.5(c)iv
“[The work plan must] outline the multi-stakeholder group’s plans for implementing the recommendations from Validation and EITI reporting.”
The MSG may thus find it useful to update the work plan subsequent to the publication of the EITI Report and Validation.
Annex 1: Work plan template (download excel file)
 The terms “mainstreaming”, “integrated reporting” and “systematic disclosure” are often used interchangeably. For the purposes of this guidance note, the terms systematic disclosure and integrated reporting are synonymous. They refer to the desired end-state, where the EITI’s disclosure requirements are met through routine and publicly available company and government reporting. This could include, public financial reporting, annual reports, information portals, and other open data and freedom of information initiatives. This should include an explanation of the underlying audit and assurance procedures that the data has been subject to, with public access to the supporting documentation. Mainstreaming refers to the process for realising this goal, which may include interim measures, pilots, and other capacity building activities. EITI websites would then increasingly be used as a portal for accessing these systematic disclosures, with EITI Reports disclosing information not available elsewhere.
 Publish What You Pay (2014), “Extracting Equality – A Guide”: http://www.publishwhatyoupay.org/pwyp-resources/extracting-equality-a-guide/.
 See Guidance note 22 on Developing a plan for implementing beneficial ownership disclosure: https://eiti.org/GN22, and Advisory checklist for EITI beneficial ownership roadmap: https://eiti.org/sites/default/files/documents/advisory_checklist_for_eiti_beneficial_ownership_roadmap.pdf