Lessons learned for implementation

Over the last decade, a number of core principles have been established when implementing income and asset disclosure regimes. Taking these into account will maximise effectiveness and can help to increase public confidence by demonstrating to citizens that official behaviour and public finances are being scrutinised.  

Clarity of form and function.

To be credible, disclosure regimes need to be explicit in defining their purpose and institutional structure: who reports what to whom and when, who enforces compliance, who verifies content and who levies sanctions.[1]

Separating compliance from enforcement.

Financial disclosure regimes include both compliance elements (educating officials, managing receipt of declarations and managing conflicts of interest) and law enforcement (verification, investigation and prosecution). It is advisable to separate responsibility between those entities managing the compliance elements from law enforcement agencies so that officials with procedural questions are less reticent to ask questions about declarations. 

Context matters.

Disclosure systems need to be designed in a way that their objectives and procedures complement the local institutional, cultural and political environment. This can help overcome the inevitable administrative burden, privacy concerns and variable state capacity.

Gradual roll-out.

Coverage needs to start with high-risk senior positions and be incrementally expanded as the infrastructure develops. Before introducing meticulous verification procedures, for example, it is advisable to ensure compliance with the submission regime. Excessively ambitious disclosure regimes are likely to prove ineffective and lose political support.     


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