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Governance: Interest & asset declarations

To what extent do relevant laws, regulations, policies, and guidance provide a basis for collecting and publishing data on the interests and assets of public officials?

Definitions and Identification

Most countries around the world have a requirement that public officials declare their interests and assets. Some such requirements are motivated by a desire to avoid conflicts of interest, some to eliminate illicit enrichment, while others combine elements of the two.

There is substantial variance in whose interests and assets must be disclosed. Some frameworks only require public officials who hold specific positions to make financial disclosures, some require all public officials. Some frameworks limit disclosures to the interests and assets under the direct control of the public official alone, some require disclosures of interests and assets belonging to partners, family members, or other close associates.

This indicator is based on the presence and strength of legislation, regulations, or policies that govern whether:

  • Financial disclosures contain data on income, spending, assets, and debts.

  • Declarations cover both financial interests (income, assets, and liabilities) and non-financial interests (gifts, hospitality, employment, memberships, etc.).

  • Declarations are updated in a timely fashion; this includes regular updates, updates that are responsive to changes in position or in interests, assets, and liabilities, as well as ad hoc disclosures to respond to potential or actual conflicts of interest that may arise.

  • Financial disclosures are published.

  • Declarations must also disclose interests, assets, and liabilities held by a public official's partner, family members, or other close associates.

  • A mandate is given to an independent agency or institution to examine declarations and/or investigate violations.

Examples

  • Bulgaria's 2018 Act on Counteracting Corruption requires high-ranking officials and civil servants to publicly declare their assets, conflicts of interest, and the incomes of their immediate family (Article 37). These declarations are subject to public access and verification by Commission inspectors (Article 43). Penalties, including asset confiscation, apply for unlawful assets. Declarations must be submitted both in paper and electronically.

  • Mexico's General Law of Administrative Responsibilities, updated in 2019, mandates detailed financial and interest disclosures for all public officials across municipal, state, and federal levels, including the Legislative, Judicial, and Autonomous Bodies. Declarations, which must be public (Article 29), include real estate, movable property, and assets of family members (Article 38). Officials must file these declarations within 60 days of taking office, update them annually, and submit them upon leaving office. Internal bodies and central agencies are responsible for auditing and verifying this information (Article 32).

Common places to find requirements regarding interest and asset disclosures include civil service or public service legislation, codes of conduct or ethics, criminal legislation, and/or specific anti-corruption legislation. Be aware that requirements may be spread across legislation. For example, often requirements for handling gifts in particular will be found in a country’s code of conduct.

Particular groups of public officials may also have their own disclosure requirements—for example, the judiciary or political appointees; often these will be found in legislation or disciplinary rules governing that group. Additionally, officials involved in high-risk activities—such as procurement, licensing, customs, or law enforcement—may also have individual requirements.

If there are multiple forms of interest and asset declaration requirements operating under different frameworks, you should focus your assessment on the most common domestic form. If there are notable variations in the assessment you would make for other common forms of declarations, please briefly comment on this in the indicator's summary box.

Note: This indicator pairs with a related indicator that assesses availability of interest and asset data in order to compare frameworks and actual practice. While completing each one, you will likely discover further information that will help answer the sub-questions of the other, so it is suggested that you work on the pair together.

Starting points

  • Sources:

    • The World Bank's Public Accountability Mechanisms offers information on countries' financial disclosure and conflict of interest provisions in law and practice; broader contextual information can also be found in the 2009 report of their collaboration with StAR.

    • OGP's database of country commitments regarding asset disclosure.

    • For countries in Europe, the EuroPAM database lists relevant laws on financial disclosure and conflicts of interest; the database currently includes 34 countries. This section of the database was last updated in 2020.

  • Search:

    • For recent updates to financial disclosure laws in the country.

    • The website(s) of the country's ethics or integrity agency or agencies for details of how they collect and manage data, and the basis of this in law or regulation.

    • For examples of current forms used to register financial disclosures, certify divestitures, or make ethics pledges.

    • For interest and asset databases constructed by journalists or country-relevant NGOs that coordinate multiple streams of financial data; among other information, these may contain details on known gaps in the country's laws or regulations.

  • Consult:

    • Investigative journalists who focus on corruption and integrity issues in the country.

    • Local officials of civil society organizations focused on transparency and accountability in governance.

    • Officials of governmental ethics or public integrity offices.

What to look for?

Look for evidence that can answer the following questions:

  • Is the framework for disclosure and verification of interests and assets data provided for in law, regulation, policy, or guidance?

  • Does the framework require financial disclosures from all public officials, or only officials or nominees to particular positions?

  • Does the framework require financial disclosures from a public official's partner, family members, or other close associates?

  • Does the framework require publication of financial disclosures? Is access to financial disclosures restricted? For example, by providing disclosures only upon request or allowing only in-person review of a paper archive?

  • Does the framework empower an agency or official to ensure the accurate and timely collection and publication of required data? Does it require a verification process?

  • Does the framework specify that information should be updated at regular intervals but also in a manner that is timely and responsive to changes in employment? To conflicts that may arise?

Show/hide supporting questions

Existence

  • Are there laws, policies, or regulations requiring collection of this information in any form?

    • No.
    • They are being drafted, or are not yet implemented.
      Supporting questions: Please provide brief details.If the framework exists only in draft form, please provide the date of any relevant drafts.Please provide a URL(s) for where evidence can be found.
    • They exist and are operational.
      Supporting questions: Please provide brief details.Please provide a URL(s) for where evidence can be found.
  • Are there laws, policies, or regulations requiring publication of this information in any form?

    • No.
    • They are being drafted, or are not yet implemented.
      Supporting questions: Please provide brief details.If the framework exists only in draft form, please provide the date of any relevant drafts.Please provide a URL(s) for where evidence can be found.
    • They exist and are operational.
      Supporting questions: Please provide brief details.Please provide a URL(s) for where evidence can be found.
  • Extent of existence:

  • How comprehensive, in terms of jurisdiction, is the coverage of the framework assessed for this question? (The framework covers one or more localities, but there are many other localities without such a framework, or with a framework of a lesser quality., The framework covers one or more localities and is representative of the kind of frameworks that can be found for all, or most, localities., The framework provides national coverage.)

    Supporting questions (conditional)

    If The framework covers one or more localities, but there are many other localities without such a framework, or with a framework of a lesser quality. or The framework covers one or more localities and is representative of the kind of frameworks that can be found for all, or most, localities.: Which locality or localities does this framework cover?

    If The framework covers one or more localities, but there are many other localities without such a framework, or with a framework of a lesser quality. or The framework covers one or more localities and is representative of the kind of frameworks that can be found for all, or most, localities.: Please explain your response.

    If The framework covers one or more localities, but there are many other localities without such a framework, or with a framework of a lesser quality. or The framework covers one or more localities and is representative of the kind of frameworks that can be found for all, or most, localities.: Please provide supporting URL(s) as necessary.

  • Existence summary:

  • Please summarize your answers to the preceding existence sub-questions, including the extent of existence. [Open Text] Drawing on the research you have conducted and the evidence you have gathered for this section, describe what you have found (or not found) when answering the existence sub-questions for this indicator.

    Supporting questions

    Please provide the URL(s) for the evidence that supports the summary provided.

Elements

  • Provisions for definitions, kinds, and fields:

  • The framework requires collecting specific information on interests, assets, and liabilities. (No, Partially, Yes)

    Supporting questions (conditional)

    If Partially: Please explain your “Partially” response.

    If Partially or Yes: Please indicate which section of the framework refers to this issue.

  • The framework requires collecting specific information on non-financial interests. (No, Partially, Yes) Answer “Partially” if the framework covers some non-financial interests but doesn’t cover gifts. Answer “Yes” if the framework covers gifts as well as other non-financial interests.

    Supporting questions (conditional)

    If Partially: Please explain your “Partially” response.

    If Partially: Which non-financial interests are covered?

    If Partially or Yes: Please indicate which section of the framework refers to this issue.

  • The framework requires collecting information on significant changes in interests, assets, and liabilities. (No, Partially, Yes)

    Supporting questions (conditional)

    If Partially: Please explain your “Partially” response.

    If Partially or Yes: Please indicate which section of the framework refers to this issue.

  • The framework requires disclosure of interests, assets, and liabilities held by a public official's spouse, family members, or other close associates. (No, Partially, Yes)

    Supporting questions (conditional)

    If Partially: Please explain your “Partially” response.

    If Partially or Yes: Please indicate which section of the framework refers to this issue.

  • Provisions for data quality:

  • The framework empowers an agency or official to ensure the accurate and timely collection and publication of required data. (No, Partially, Yes) For example, a framework might establish or resource offices for data verification, grant an agency sanction powers for noncompliance, etc.

    Supporting questions (conditional)

    If Partially: Please explain your “Partially” response.

    If Partially or Yes: Please indicate which section of the framework refers to this issue.

  • The framework requires a verification process. (No, Partially, Yes) There are many different kinds of verification processes. Some processes are automated, some involve direct human review, some combine the two. For example, in some cases, data is required from multiple parties engaged in an activity and that data is then cross-verified automatically. In others, a dedicated agency or official has the authority to conduct audits, engaging with other agencies or external parties to verify information received.

    Supporting questions (conditional)

    If Partially or Yes: Please briefly explain the verification process used.

    If Partially: Please explain your “Partially” response, including which parts of the collected data the framework requires to be verified and which parts it does not.

    If Partially or Yes: Please indicate which section of the framework refers to this issue.

  • Provisions for collection and access:

  • The framework supports the digital collection of data. (No, Partially, Yes) For example, entities submitting information may be required to use digital forms.

    Supporting questions (conditional)

    If Partially: Please explain your “Partially” response.

    If Partially or Yes: Does the framework support the collection of structured data? Please explain your response.

    If Partially or Yes: Please indicate which section of the framework refers to this issue.

  • The framework requires that data is regularly updated. (No, Partially, Yes) For example, a framework may establish a specific collection and publication schedule relevant to its intended use.

    Supporting questions (conditional)

    If Partially: Please explain your “Partially” response.

    If Partially or Yes: Please indicate which section of the framework refers to this issue.

  • The framework requires that data is updated ad hoc to disclose emergent conflicts of interest. (No, Partially, Yes)

    Supporting questions (conditional)

    If Partially: Please explain your “Partially” response.

    If Partially or Yes: Please indicate which section of the framework refers to this issue.

  • The framework requires the publication of interest and asset declarations. (No, Partially, Yes)

    Supporting questions (conditional)

    If Partially: Please explain your “Partially” response.

    If Partially or Yes: Please indicate which section of the framework refers to this issue.

  • Elements summary:

  • Please summarize your answers to the preceding element sub-questions. [Open Text] Drawing on the research you have conducted and the evidence you have gathered for this section, describe what you have found (or not found) when answering the element sub-questions for this indicator.

    Supporting questions

    Please provide the URL(s) for the evidence that supports the summary provided.

Interest and asset declarations, sometimes referred to as wealth declarations or financial disclosures, have been used since at least 1960, when the Philippines passed its Anti-Graft and Corrupt Practices Act requiring public officials to declare under oath their assets and liabilities at the beginning and end of their terms in office (Apostol n.d.). In 2003, the adoption of the UN Convention Against Corruption, which includes strong declaration practices, sparked a renewed focus on the declaration as an accountability mechanism. A World Bank study published in 2016 found that 161 of 176 countries had some form of interest and asset declaration, though these showed significant variation (Rossi, Pop, and Berger 2016).

To support government transparency and accountability efforts, this indicator investigates the frameworks countries have in place for collecting and publishing data on the interests and assets of public officials.