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Comments made in consultations on drafts of what IATI should publish and Code of Conduct

October /November 2009

Comments received from 33 organisations/people Type of organisation StakeholderAidCo - EC Donor SignatoryAustralia Donor SignatoryBMZ, Germany Donor SignatorySwiss Agency for Development & Cooperation Donor SignatoryFinland Donor SignatoryGAVI Alliance Donor SignatoryMinistry of Foreign Affairs, Denmark Donor SignatoryHewlett Foundation Donor SignatoryIATI DFID Reference Group Donor SignatoryDFID Vietnam DonorMinistry of Foreign Affairs, Sweden Donor SignatoryAsian Development Bank Donor SignatoryUNDP Donor SignatoryUNDP El Salvador Donor SignatoryWorld Bank Donor SignatoryColombia Partner Country EndorseeDACU Project Coordinator, Ministry of Finance, Malawi Partner Country EndorseeHead of Statistics Unit, Austria Donor Permanent Delegation of Japan to the OECD Donor USAID Donor Afghanistan - Ministry of Foreign Affairs Partner Country Ministère de la Coopération du Développement et de l'Aménagement du Territoire, Togo

Partner Country

Dirección General de Cooperación Técnica y Científica, SRE, Mexico

Partner Country

Ministry of International Co-operation, Egypt Partner Country Ukraine Partner Country WWF European Policy Office CSO Access Info CSO AWEPA CSO Development Gateway CSO InterAction CSO Senior Policy Coordinator, Transparency International CSO Personal comments, Japan Independent Academic, UK Independent

25 November 2009

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Organisation Abridged Comment ResponseGeneral ScopeAidCo - EC Three main issues for EC at this stage: (1) clarifications on the

terminology; (2) confidentiality of certain documents; (3) extra-burden that this standard could impose. 1. Effort to explain the concepts is not always successful. EC jargon may sometimes be different for same term in other donor institutions (e.g. "concept notes", "MoU" or "tranche release details"). Rely on DAC CRS Concepts whenever possible. 2. Certain documents are or may be confidential depending on the procurement process. A non-exhaustive list includes: financing agreements (moreover the beneficiary country would have to agree before publication; commercial interest and privacy of the individual (affecting content of tenders for grants or procurement, detailed evaluations and contracts); tenders from negotiated procedures (would mean a change of practice and more frequent publication and so an additional burden) or that have been declared secret or single awards and awards for specific contracts under framework contracts or for EC funds channelled through delegated cooperation (not currently published.). 3. Relying on links to information already published in different EC web sites would avoid adding new unnecessary tasks. IATI needs to provide guidance to aggregators of information, as EC is receiving requests for aid data from different initiatives with different requirements, which put a burden on our capacity.

Noted, all these issues will be addressed during further work in 2010 on the definitions, thresholds and exceptions and assessment of support to donor implementation. Will rely on CRS wherever possible. IATI will make fullest use of information on existing websites and useful to examine format of what is already published as determine the document standards later in 2010.

AidCo - EC IATI conference raised question about status of IATI with different understanding and opinions on what IATI is(n't) or should(n't) be. In EC view IATI was established as an informal network of foremost traditional donors with a political interest in taking aid transparency forward through discussion of technical solutions on how to make this operational. At early stage ambition of IATI raised to agreement on an aid transparency standard with monitoring of adherence. This has created a mismatch with the structure of IATI, which is still an informal network. Two ways to solve the issue: a) lower the ambition level of the IATI objective(s) or b) find a way to create an appropriate structure. EC view is to continue to pursue an aid transparency standard. What options for a more formalised structure? Two options are: a) formal institution with official members/signatories, with a mandate to monitor implementation; or b) formalise agreement on IATI outputs through (a mixture of) existing mechanisms, like UN, OECD/DAC (WP-EFF and WP-STAT) and/or the EU. Should avoid proliferation of new institutions, so prefer second option and see IATI only as a temporary mechanism. Connected to this issue, we believe IATI standard should apply to all bilateral and multilateral DAC donors and preferably to all donors participating in the WP-EFF. So, IATI needs to conduct a promotion exercise towards donors that haven't signed up. Propose to put these issues on the agenda of the next IATI Steering Committee on 30 November in Paris and that all current (18) IATI signatories, and if possible all potential signatories, will be present and share their position on this issue, which then should lead to a clear decision by the Steering Committee.

Noted need to discuss the IATI structure. Too near to 30 November meeting for a discussion with all interested parties present and a decision. But noted as suggestion for meeting in first part of 2010.

Ministry of Foreign Affairs, Denmark

Most DAC-donors reporting priorities in 2010 will to fulfil the CRS++ requirement. It is not realistic to expect donors to make simultaneous investments in new ways to publish data in the old CRS-format. More feasible for IATI to invite and encourage donors to provide CRS++ data as soon as they possibly can, but for most donors this is unlikely to be much earlier than the formal submission of data on 2010 flows.

Agreed. Since its launch IATI has encouraged donors to improve the timeliness and quality of their data in CRS. It has no intention of using the 'old CRS format'. Most work to implement IATI will be for country programme staff to provide data that are not in the CRS++.

IATI DFID Reference Group

We are broadly happy with the list of areas suggested to be included in the IATI standards. IATI needs to be ambitious in order to retain credibility with our partner country and CSO stakeholders. On exceptions, we query the rationale for excluding in the following cases: 01/03: Assessments of aid and aid effectiveness 02/05: Tenders 06/02: Conditions – this

Agreed. Exceptions and thresholds will be set in line with national legislation and regulations. Data definitions will be addressed in Q1 2010, as planned and agreed by the Steering Committee. They will use DAC definitions as fully as possible.

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Organisation Abridged Comment Responseis an AAA commitment and a key partner country ‘ask’. Priority is to develop current descriptions in Appendix C into clear definitions, in line with DAC guidance where applicable, so signatories understand the full implications from the IATI standards and ensure standards themselves are credible and can be met.

Finland We warmly welcome the new initiative for more transparent and accessible information about aid. Creating a common platform for several information sources and formats, and furthermore enabling intermediaries to use and develop the information, we believe IATI could succeed by bringing the desired added value to the effective information of the global development aid activities.

Agreed.

Finland IATI standard should contain the existing items, i.e. current CRS++ database, which is our main priority for more detailed, accurate and on time reporting. Our current information systems and staff position cannot adapt to the additional burden that Appendix A would require. Want assurance that IATI will not become a new parallel reporting system existing OECD/DAC systems.

IATI will build on CRS++ standards and data where applicable. Main focus is on country-level reporting for which CRS++ is not designed. Donor support workstream will help each donor to examine implementation costs.

Ministry of Foreign Affairs, Sweden

Swedish minister of development cooperation, Gunilla Carlsson, has stated very clearly that she is not satisfied until Swedish foreign aid is fully transparent so that anyone, and especially people in our partner countries, can find out who is doing what, where, what they have learned and where the money comes from. Sweden is now taking further steps to make our development cooperation more transparent; IATI has provided a lot of inspiration. Theoretically, Sweden is well equipped to publish most of the documents you propose due to our legislation which makes most documents public. Sida is also developing a new IT-system that, eventually, will solve some of the technical challenges. But what documents on the list are most important? And for what stakeholders? The difficulties in setting global standards are widely known. Important to prioritise among the documents suggested as another reason is the problem of language. Many of our documents on the list are in Swedish and would need to be translated. That takes time and money. The amount of information in the consultation paper and the timetable suggested therefore does not seem to be very realistic.

Noted with interest. Plan to adjust the timetable for documents which can address prioritisation. One factor will be availability of documents in the language used to work with the partner country.

Swiss Agency for Development & Cooperation

Our main concern is the level of ambition and the unrealistic pace of the initiative. IATI can only succeed if all players are willing and have the capacity to participate actively with accurate and updated information. A critical mass of data and information has to be guaranteed, and this implies the participation of the major players. Too ambitious scope and schedule will discourage potential newcomers and if you do not get the main (statistical) reporters on board, IATI will not be sustainable. To meet the IATI standards, more time and investment in administrative and IT systems is required in the agencies to overcome the technical difficulty in establishing comprehensive data sets. Our internal management systems are not ready to provide the required project data and documentation. The disclosure of data on a monthly basis is not realistic. On the donor side, WP STAT's efforts to introduce the Creditor Reporting System CRS++ and the new harmonised typology of aid for the outflow data go in line with what IATI is aiming for. This does not ensure that this data extracted from the CRS – or other components of the standard posted by reporters in headquarters or field offices – will be directly useful to our partners. There is also a risk of misinterpretation and misuse of data, especially when aggregated to meet specific analytical purposes. It is illusory to merge donor systems with individual partner country systems. IATI should provide tools to improve the connection of outflow and inflow data and make sure the data and documents are interpreted in the same way.

Timetable for implementation being adjusted and frequency of publication to be discussed and tested in pilots. Donor support workstream will help each donor to examine implementation costs and will cover non-signatories if they so request. Will make full use of CRS updated standards and concepts to measure both outflow and inflow data. Procedures to record source and status of data will be incorporated.

GAVI Alliance Where indicators don’t fit/are irrelevant, don’t insist on reporting against this indicator and instead allow ‘n/a’ or

Note need to discuss with global funds what information is relevant and, as complete

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Organisation Abridged Comment Responsesimilar. Keep terminology flexible, particularly in this early stage of the IATI development. • The indicators are quite project oriented, when we are trying to move towards programme-based approaches. For example, in the case of GAVI, indicator 04/01 “total project cost” may end up meaning the total health budget of a country. This also applies to the collection of information about Paris Declaration compliance, which is better evaluated at programme/country level, rather than at project level.

definitions, to be sure they allow for their mode of operation.

UNDP Information which constitutes an exception in accordance with §11 of UNDP’s disclosure policy should not be in the IATI standard.

Agree that exceptions should be in line with existing legislation/disclosure policies.

UNDP UNDP provides public access to its budgets, programme/project descriptions, evaluations of programme/project results, procurement activities, personnel rule and regulations, financial rules and regulations, administrative policies and Executive Board decisions (web addresses supplied by type of information). UNDP’s web transparency initiative launched in 2008 requires all country offices to publish key information on their public web sites including on procurement, projects/programmes, staffing and finance. Today, 97% of Country Offices have posted basic transparency information on their sites (HR and project information), and 48% have achieved full transparency. The web transparency initiative has made UNDP one of the most ‘webtransparent’ organizations within the UN, but given the size and number of country office websites to be maintained, this initiative requires significant investment of time, man-power and tools/systems to make it a permanent reality. UNDP is currently identifying funding sources for a corporate CMS which will facilitate the automatic posting of relevant information. Pre-project assessments and post-project evaluations are not mandatory unless required by a partnership protocol. UNDP provides information in accordance with the classification standards used by the UN. UNDP’s ERP system called ATLAS is where data related to data types 3, 4 and 5 are contained. Results data are also reflected in UNDP’s Strategic Plan (global level), United Nations Development Assistance Frameworks (UNDAFs) at the country level, UNDP Country Programme Documents (CPDs), Country Programme Action Plans (CPAPs) and Annual Work Plans (AWPs) (project level). These documents are publicly available.

Noted that UNDP in good position on document publication; experience on which IATI can draw as it defines document standards. Will work with UNDP to build on mapping UN data standards to IATI standards, drawing fully on work already done/underway to report to the CRS.

UNDP “Less is more”: It will be important to agree on the most important set of information items that corresponds to partner country needs and complements the OECD/DAC Creditor Reporting System. In this regard, IATI should continue to develop the standards in close collaboration with the OECD/DAC.• Flexibility should be built into the standards in order for development partners to be able to better respond to the information needs at the country level and to be aligned with national policy priorities, planning cycles and aid information management systems. IATI should continue its engagement with partner countries and deepen it in order to have a better understanding of the linkages between IATI and country systems and the implications of IATI for partner countries, including in the capacity development area.• UNDP will need to further look into how the scope of aid information fits within UNDP’s policy framework, ERP system and business processes. Cost implications and practical feasibility will be a key determinant as to whether UNDP would be able to comply with those areas, which require changes to the organization’s ERP system and policies. In the current economic climate, it is difficult to envisage financial support for the system’s overhaul.

Agreed on working with DAC and flexibility to align with partner fiscal years and AIMS. Donor support workstream will help each donor to examine implementation costs.

World Bank Indicators of effectiveness at the project and donor agency levels.Methodologies for assessing agency-level aid effectiveness will continue to be refined. Until there is a framework that has

Noted. Options to measure aid effectiveness to be explored.

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Organisation Abridged Comment Responsea proven utility to both donor organizations and partner countries, the suggestion of regular publication of such indicators is not credible. Moreover, we question the utility of PD indicators at the project level. Therefore both (01 03) and (06 02) should be deleted as unessential to the current Standards. As an alternative, IATI may wish to include independent evaluations of donor agencies (on various dimensions of development effectiveness) in the Standards.

World Bank CRS coding as the basis for reporting. While we agree that all information listed under 03 is needed, IATI is proposing the DAC Creditor Reporting System (CRS) as the basis for making this information uniform in reporting by donors. This proposal will provide a challenge for the Bank, other agencies presently using the UN system (as opposed to the DAC classification system) as well as other organizations such as foundations which do not presently use the DAC system. Some issues include: • the CRS was designed as a system for statistical recording and reporting of historical aid data. It is not clear that the codes are as appropriate for forward looking forecasts/planning in an aid management information system (with ability to link to country budgets), which is the primary need from the partner country perspective. • the issue of mapping the Bank’s existing coding to CRS sector and thematic (policy marker) codes is not straightforward and could result in distortions in the reporting. The Bank does this mapping now for historical data with some difficulty and imperfections. • if in the longer term the Bank would consider converting its coding system to the CRS system, a cost-benefits analysis would need to be undertaken. This would need to consider the requirement that the coding system serve the Bank’s internal resource planning and management processes.It would be good if IATI would undertake an assessment of all existing coding systems and country needs for coding to determine the type of coding that is needed and what model could be most efficiently be deployed to serve the objectives of the IATI initiative-- before finalizing the decision to adopt CRS.

Noted. As part of the work on definitions and data format, the TAG will be looking at a range of de facto international coding systems. The CRS codes are common to all bilateral donors and most multilaterals report by mapping to CRS classifications while holding their data in the way that suits their internal purposes. Indeed, for sector codes even most DAC members map to the CRS codes from their agency-specific codes, so there is no presumption that internal sector codes have to be identical to CRS. Useful to note this mapping is now done for the Bank, albeit with imperfections. We have accepted the need to be flexible to link to country budgets and other country specific needs.

World Bank Glossary of Terms and Definitions. More clarity and precision is needed in the glossary of terms and definitions to avoid misinterpretation. For example, item (01/01) asks for HQ level policy and procedure on, among other things, recruitment. Does this refer to recruitment of donor organization staff or of consultants to work on a project financed by the donor organization? Another example is “annual project budget” (04 02). It is not clear whether this refers to program/project financing or administrative budget of the donor organization to design and supervise the implementation of the project? There are other examples, and they may have implications for the Bank’s ability to agree to include these items in the final list of standards. Supply Chain – Traceability of Aid Flows: Need IATI to better define the concept of the Supply Chain so that the scope of this work can become clearer. Cost-Benefit Analysis of IATI. There is a need to clarify the costs and benefits of adopting these Standards. What is its status of the Cost Benefit study? Representation in the Steering Committee. Will each signatory be represented at the SC? If there are new signatories, how many of them will be represented on the SC? How are partner countries selected? Further discussion will be useful. Links to countries AIMS. What is the status of this and are there any pilots being considered? Status of the Document. There have been many different versions of the Standards document, with different coverage, length and purposes. It would be good to agree on which document represents the final decision on information to be collected, and which can serve other purposes.

Noted. Work on detailed definitions to start in January 2010, as now agreed by the Steering Committee. SC will update on cost benefit study, representation. Pilots with various AIMS planned in Q1-Q2 2010. Agree need to clarify which document is final - to be produced in time for decisions planned for July 2010 SC meeting.

Access Info Welcome that the aid community is now fully embracing the right of access to information. Welcome inclusion of Freedom of Information Acts as an IATI information item, as crucial for

Noted and will include all common terminology in the definitions. Suggestion of publishing structure of aid machinery in each

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Organisation Abridged Comment Responsestakeholders to know that they have a right to ask for information and under what law(s). In many countries these laws are called “access to information laws”, so may be useful to include that terminology as well. One omission is user guidance information to give the full context in which aid spending takes place, naming all the bodies engaged in aid funding and explaining clearly the responsibilities and functions of each. It should include two fundamental elements: a plan of how each aid-providing body relates to each other at the national level (e.g. how an aid agency relates to a ministry), and a guide to decision-making structures of each aid funding body. Need clear signposting in the IATI Registry. Publication of information should be structured in ways best tailored to the potential users. Need caution in free-for-all approaches to how information can be presented. The report “Not Available! Not Accessible!” found that detailed information often exists but is inaccessible because of a lack of links, e.g. country websites not signposted from central Aid Agency sites. AiDA and DAC CRS not mentioned on websites of many national aid agencies, so if a user does not know they exist, they will never find the information they contain. So essential that IATI registry be clearly signposted and be accessible from all possible places where the public will search for aid information.

donor to be investigated. IATI registry will be designed to point to all relevant information that is published - indeed without the need for separate links on HQ and country websites.

Head of Statistics Unit, Austria

Given WP-STAT experience the proposed IATI standards look very ambitious, much too comprehensive and detailed, and the timetable for publication is unrealistic. WP-STAT is making current system more policy relevant, e.g. new type-of-aid classification, channels of delivery, and CRS++ contribute substantially to making data on donor inputs more comprehensive and more robust to respond to multiple information needs. Regarding the data referred to in the last section of Appendix A in the IATI A paper, CRS definitions and concepts apply to almost all items, therefore full harmonisation is to be sought with the CRS, For aggregation of such data users need to be referred to the IDS online systems of the DAC without fail.

Rephasing to address data before documents and timetable. Welcome improvements to CRS definitions which will be incorporated in IATI. Users will be referred to DAC statistics for the official time series on aid flows.

Ministry of International Co-operation, Egypt

Define strategic and essential data to start with. Quantitative aggregates are easier to supply than qualitative items such as aid policies and project impact appraisals. Such policies exist, but might not be available in a formal text.

Rephase to address data before documents

Personal comments, Japan

Applying the same standards to both donor and partner countries does not make sense. The standard intends to be applicable to both donors and partner countries, including non-governmental stakeholders. But, for example, the perspectives of government and civil society organizations are quite different, so I do not think it appropriate to establish the standards applicable to every single stakeholder. In WP-STAT donors are under a gentlemen’s agreement to submit their data on aid in an agreed format. This does not mean that each donor’s statistical system contains the same standards as the CRS; each statistical reporter struggles with the conversion between their own system and the CRS. Applying the CRS standard requires work and is not technically easy. It is logical to utilize the CRS for all data on donor outflows of aid, with further effort to disseminate CRS data and develop its user-friendliness. Statistical systems in partner countries are different from one country to another, in accordance with the needs of each individual country. There is no equivalent of WP-STAT to standardise data in the case of partner countries. There is thus one set of common data on donors (through CRS) and multiple sets of data in partner countries (one system per one country, for example). I think it necessary for those two categories of data sets to be linked in such a way that the donor aid outflow could be traced in the individual statistics of the partner countries.

Noted, and the CRS standard and data will be used as fully as possible. While there is no WP-STAT equivalent for partner countries, many have found a shared requirement for information through their efforts to develop aid management systems. Much of the data they require is common to all countries and the data and standards on donor outflows are the starting point. But where the data are not common to all countries, IATI will not be pushing a ‘one-size-fits-all solution’. There will be local customisation, e.g. budget and sub-national geographic classifications, on which IATI is working and will be piloting in 2010.

Personal comments, Japan

The data to be published include both quantitative and qualitative data. Through WP-STAT experience, I learned how difficult it is to combine both quantitative and qualitative data, even with the advance of computer technology. Anything that

Noted, IATI will be working on the confidentiality aspects of the standard in 2010, drawing on donor practice and regulations. It will also be working with

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Organisation Abridged Comment Responserequires very high standard hardware and very expensive software will not be friendly to partner countries. Also some of the data in the standard are confidential in the current norms of the donor and partner country governments. IATI cannot challenge such norms to be abolished, even among the signatories.

information providers on accessibility, including various ways to make the published information readily accessible not only on PCs, but through other media such as print and mobile phones. ‘Web 2.0’ technology now makes it relatively easy and cheap to combine data in innovative ways using web browsers.

Transparency International

By breaking down the types of information into “level” (country or headquarter), “activity” and “data”, a clearer picture of the breadth of information that is not fully transparent is revealed. TI welcomes focus on some of the basic principles of aid effectiveness: ownership, accountability and managing for results. But need a greater understanding of how the current taxonomy of categories contributes to each of these dimensions, as the consultation moves forward, while not setting high expectations that cannot be delivered through IATI alone. Important for IATI to be integrated with other initiatives, such as those by the WP-EFF and for an effective code of conduct to be established. While managing these expectations is required, the question also arises whether the IATI standard is ambitious enough. For example, phasing the standard’s implementation is welcomed, but a more specific timeline is required. In addition, often governments, parliamentarians and civil society receive information and documents that are fairly final or untimely, so their role becomes reactive and not pro-active in defining the kind of aid they wish to receive. This initiative must make sure that such an outcome is avoided. TI recommends having a maximum set of options for excluding types of information (i.e. a ‘ceiling’). Otherwise, the use of a standard can quickly become undermined.

Noted, especially need to manage expectations on what IATI should deliver and what is for others, including WP-EFF, with which IATI is working closely. Timeline will be firmed up early in 2010. Note issue of public consultation early enough in a process (in part addressed by item 01 05). Exclusions and thresholds will be in line with FoI and procurement regulations.

Phasing BMZ, Germany Including Official Development Finance: No position yet.

Something for phase two? Implementation is already quite a challenge for ODA-related data. Efforts should not be distracted to too many "to do's".

Noted. ODF proposed in order to cover the large non-concessional flows of multilateral development banks; otherwise IATI would miss a large part of their operations. Implications to be discussed with individual donors.

Asian Development Bank

02 10 Project completion report should be in phase 2 and 02 11 Post-Project evaluations should be in phase 3, the reason being that it provides more time to also work on ensuring more data issues are resolved related to post-project evaluations as well as the fact that project completion reports are also inputs to any post-project evaluation.

Noted for decision as agree on document standards. At present evaluations often published, PCRs less so.


Appendix B items with alternative timing - Project-specific documents like “02 01 Concept Notes” can only be made systematically available when internal organizational procedures are brought to a level of genuine IT-supported workflows. It is not just a matter of instructing desk officers to upload such files to a designated homepage, since their primary obligation always will be to file it correctly. Only when files are fully digitalized, and filing-systems are properly linked up to financial management and CRS-systems, will it be an option to define automatic and supply-driven publication. In the relevant “Freedom of Information Act” you will find instructions on demand-driven publication, where citizens are given the right to demand access to information. This is an entirely different realm, and this is what defines and restricts current systems. It is not possible to suggest alternative timing for such items, if the intention is to ensure full coverage.

Noted, to be examined as we look at what information is in practice available for publication and other organisations' experience with move from reactive to proactive publication.


Broadly happy with the suggested phasing but would welcome clarification of the actual phase dates. Regarding phasing of specific information, we would query the following: 01/03: Assessments of aid and aid effectiveness: Why is this set for Phase 3 and not earlier? 01/05: Information on opportunities for public participation in decision making and evaluation: Why is this in Phase 2 and not earlier? 01/08: Annual forward

Phase dates to be examined and agreed with Steering Committee in the light of further work in 2010. Exact phasing will also be checked and reworked in the light of overall phases - e.g. data ahead of documents - and existing availability. Suggest timetable and commitment to publish should be transparent

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Organisation Abridged Comment Responseplanning budget data for agency: Why is this set for Phase 3 and not earlier – see comments below? 01/09: Annual forward planning budget document for funded institutions: This is set for Phase 2. It therefore would make sense to set 01/08 to Phase 2. 02/11: Post project evaluations: Why is this set for Phase 2 and not later? Appendix B: the timetable for publication refers to ‘one month after a document is issued.’ We recommend that the term ‘issued’ is defined and clarified for signatories. We welcome the recent addition of Appendix D which clarifies what will be published by Phase. What will be published under what phase: We note that under Phase 3, different signatories may interpret timelines differently according to the need for ‘substantial amendments to systems/ practices’ required.

for each donor.

DFID Vietnam A few items can be published during the phase 1, for example: Project log frames and project design docs 0203 Detail geographical info , Annual project budget under 0402, Planned disbursements 0405, Outputs and outcomes indicators 0501, Results indicators 0502

Noted, and to be reviewed as firm up the phasing. In practice we are finding that it takes more time to prepare for publishing documents and more work is required on outputs and results, sub-national geographic information and planning figures.

GAVI Alliance Selection of phases for disclosing information categories is well-conceptualized and seems feasible. However, not clear what the distinction is between budget documentation and budget data and what internal modifications would be required to make budget data available in phase 3.

To clarify as finalise definitions and phasing. The documents often already exist and are published by some donors, but additional work may be needed to make the data readily accessible in a structured format that make them easy to use.

World Bank Phasing of the Standards. We have not yet had time to review in detail how realistic it will be for the Bank to deliver on Phase One and Phase Two data in the agreed timeframe (although we don’t expect any serious issues). We would like to suggest that Phase Three be open for review at a later date. There are a number of types of information that could arguably be included in the “desirable but difficult” category. At this stage, we would like to see the Phase Three data as suggestions rather than agreed-upon parts of the Standards.

Noted and phasing of standard to be discussed in Steering Committee.

Colombia Phasing: Suggestions in Appendix B for some earlier phasing, of logframes, mid-term monitoring reports, beneficiary organisation, geographic information, results data and Paris Declaration indicators. Some indication of availability of data about aid to Colombia on donor websites.

Noted. Steering Committee has decided to address data already available – in CRS and AIMS – ahead of other data and documents. Exact phasing will be discussed in TAG in Q1 2010.

InterAction Phasing: I am left unclear as to how exactly the proposed phases will work. Will all donors will be required to make the same information public in each phase, or, as the phrase “existing documentation” implies, will the information published under each phase vary by donor, depending on how transparent they already are? While the latter may make things easier for donors, it would pose significant obstacles for holding donors accountable – especially if where an individual donor is along the “transparency spectrum” isn’t public knowledge. If phasing will happen along the lines of the latter, will IATI note what information each donor is responsible for publishing during each phase, or commit donors to doing so publicly?

Agree need to clarify the phasing as it is finalised. The aim will be to have as much coverage as possible in each phase, but this will mean some adjustments - we suggest within a fixed period - to cater for particular donor circumstances. The suggestion is that the timetable and commitment to publish should be transparent for each donor.


The text that “donors will be able to publish below the threshold if they wish” goes against the spirit of IATI that is trying to establish a standard. Rather, recommend allowing donors to phase their implementation of the IATI standard similar to the phasing of the information coming on-line. The graduation of their status and their recognition as being “IATI compliant” would have to be set out clearly from the beginning (maximum period) and included in the Code of Conduct. Some Type 01 information is currently available and yet phased to be included at a very late stage. For example, TI believes “Annual Forward Planning Budget Data” for Agency and Country Offices to be presently accessible and important for meeting IATI’s aim of timely, useful and predictable data, and so should not be in the last phase. Likewise for Type 02, e.g. project design documents, MoUs and contracts awarded for projects are accessible and being captured as part of aid operations;

Clarify that publishing below the threshold is to increase coverage for those able to do so. Agree need for each donor's status and implementation timetable to be clear when they sign the code of conduct. Will examine all phasing once definitions complete and more research on current availability of data and documents.

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Organisation Abridged Comment Responseand Type 04, e.g. “Annual Project Budgets” and “Total Project Costs”

Publishing AidCo - EC If EuropeAid commits to provide any information, it has to

come from CRIS—our information system. We should not commit to provide information that cannot be easily obtained from CRIS. Monthly publication to IATI Part A and Part B must be automatic and supposes development of information systems (even for phase 1). For OECD reporting, EuropeAid collects data from 4 main sources: CRIS, HOPE (Echo), ABAC, EIB—an annual manual process. DG ECHO has been involved in the internal consultation, because humanitarian aid falls within the scope of IATI. Should IATI fully apply to humanitarian aid or should specific items be identified? Humanitarian aid is well advanced in the publication and sharing of information. DG ECHO manages an application (called 14points) which provides consolidated information on the EU humanitarian assistance (EC + Member States). This system is linked to the Financial Tracking System (FTS) operated by OCHA which records all reported international humanitarian aid. To avoid duplication of efforts it should be clearly noted that IATI members will rely to the extent possible on existing information systems (and in particular the 14points system operated by DG ECHO and the FTS system operated by OCHA). In respect of missing data fields - 2 important data seem to be lacking: a) on beneficiaries (at least the number of beneficiaries); b) a project level (phase 2) - the title of the project.

Noted. Donor support workstream will help each donor to examine implementation costs. Propose to include all humanitarian aid. Work on definitions and formats will look at CRS, 14 point and OCHA systems for humanitarian aid. Need more discussion of adding beneficiaries. Project title is item 03 10.

Asian Development Bank

ADB would need to commit institutional resources to timely data/information management and setting up and maintaining these web services. A uniform data format might pose problems on how ADB's current systems under development, such as P3M and CMS II, will fit if their data format is different. ADB needs to define where these IATI related processes fit within the ADB business processes and timeliness might be a challenge, especially in the financial area. Need guidance to organizations that will use the information. There should be adequate transparency without creating significant burden to aid agencies and donors in reformulating their current databases unless it is absolutely necessary. Before decisions are made on formats, systems or indicators need: a) IATI to study ADB system and advise implications of IATI for ADB in terms of compatible data systems and what changes are required; and b) more clarity on recommendations on transparency of information and data systems of partner country governments and extent of use of aid data by partner countries. Transparency only on the part of donors would not help the cause of development effectiveness.

Noted. Donor support workstream will help each donor to examine implementation costs. Intention is to use an output report for conversion from donor's system formats to the standard format, rather than reformatting internal systems. There are already case studies of partner country needs for aid data and further work will be done in pilots in 2010.

AUSAID, Australia

We consider that the proposed times for frequency of publication may prove unworkable for some donors for some items. (Ref Appendix D.) Provision of CRS data Australia, like most OECD countries, reports annually to the DAC on the CRS++ variables on a fully disaggregated (activity by activity) basis. And - with the standard delays - this information is published in a disaggregated form on the DACs statistical website. Some of the CRS++ variables are not recorded directly in our line aid management (and aid information) systems. On the contrary, some of the CRS++ variables (and/or their activity-by-activity values) are calculated from the variables in the line systems, in a major annual exercise. This not only involves calculating the CRS++ values but data checking and correction. The CRS++ data set is built from the data in the line systems - in a process which takes a number of months after the conclusion of the period being reported on. We suspect that many OECD donors are in a parallel position. That is, they do not have the full suite of CRS++ variables live on-line in their internal information systems, but derive many for annual reporting purposes. This is a perfectly viable approach to annual reporting.For a donor in this position,

Noted. Donor support workstream will help each donor to examine relevant thresholds and implementation costs, so that the bulk of the information can be published in a more timely fashion, while noting that it has not undergone all the quality checks of CRS reporting.

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Organisation Abridged Comment Responsemoving to much more regular public reporting to the CRS++ variables may involve major systems change, and have substantial resources implications. It may be that in the short run (Phase 1 by end 2010) it is not practicable to move to more regular, monthly or quarterly, provision of expenditure information. Some expenditure details for the delivery of selected types of aid activity which have simple finances may be able to be published on a quarterly basis. We think that monthly will probably be unworkable for almost all types of expenditure. However, it may be that it will prove technically very difficult to provide comprehensive expenditure details across the entire Australian aid program on a better than annual basis. This will require careful analysis.


On publishing, if aim is flexible, on-line access to data for partners, it seems to require a shared technical standard on how to design web-services or standardized reports, prepared for standardized aggregation of data from different donors. But if aim is just to allow donors to follow their own technical standards on any platform, as long as the content is transparent enough, then IATI will achieve little more than the creation of a site with unsystematic link-options. In appendix B & D apparent that IATI draws no real consequence of the identification of “ownership of info”. This should be taken more seriously, since it will have several implications: when data are identified as “donor ownership”, it must follow that the data-type is “CRS++” (where possible). When other data-providers supplement these data, using other data-types, it could be a feasible task for IATI to provide the relevant translation to and from CRS++ master-data.

Clarify the 'how' of IATI in more detail. IATI is concerned with publishing the data to a common standard and in a common format. It will leave data aggregators and intermediaries to assemble the published information to provide online access. AidData - demonstrated in the Hague - is one potential aggregator. We plan to include the source and status of the published data in the Registry. Where CRS++ is applicable, the intention is to use its standards, including for non-DAC data providers. For shared ownership with partner countries, we need to do more work and discuss it in the TAG and Steering Committee.


Quality assurance: QA of data will be a key concern for donor signatories. We recommend that any data or information published has undergone QA internally and that we avoid publishing ‘raw’ data/ information. We welcome the approach of open licensing but we also recommend the need to specify how data is attributed when it is re-used; we recommend the inclusion of clearer timelines. Automation: This links to the 'frequency' of when data will be published (in Appendix D). It is not clear whether the process for publication will be automated. The document says that IATI want to "establish a common way of recording and publishing information to create a platform that enables a variety of intermediaries to use and present the information in different ways.” Several suggestions have been put forward for how the data could be published. It will be important to find the most parsimonious and cost effective solution. If not, it could become quite time consuming if DFID staff had to get involved in a complicated process for manually publishing project data at different times of the year.

Clarify that raw data is not about their quality, but the format. Agree that QA will be important and there should be attribution. Details of the degree of automation of publishing to be worked out with each donor as part of implementation.


Ownership of information: This section needs to be clearer, especially with respect to where there are multiple stakeholder initiatives (e.g. Joint funding or silent partnerships).

Noted, need to deal with responsibility to publish under delegated co-operation and silent partnerships.

Finland Any information that is already published through our website should be accessible for the IATI registry to use. However, this requires still a detailed analysis of our information systems. For the proposed timing of the information, we are able to provide the information as soon as we have reported the annual CRS++ data or published information through our website.

Donor support workstream will help each donor to analyse how and when to publish its information, including that which is not in CRS++.


It should be avoided to impose a standard in the name of AAA (i) to reporters reluctant or not in a position to publish specific data and/or (ii) to partner countries already working with existing systems. In our view, IATI, as a multi-stakeholder initiative, has a catalytic role in the process of narrowing the information gap, developing common understanding and promoting the efforts made by the donors and the partner countries to provide, resp. use transparent and harmonised data/documentation.

Noted. IATI is working to agree a standard between multiple stakeholders based on meeting their needs while recognising constraints. In particular it focuses on partner country needs and making full use of their existing systems.

GAVI Alliance Current information publication proposal is generally feasible, however two specifics worth mentioning: The Global Fund and GAVI are performance-based financing agencies. For example, the Global Fund bases disbursements on quarterly

Note need, as complete definitions, to be sure they allow for global funds' mode of operation. Availability of partner documents still to be discussed.

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Organisation Abridged Comment Responseperformance and management reviews. Need to be able to account for performance as a predictor of future disbursements and acknowledge this as an important variable in predictable financing. Indicative disbursement schedules for each grant phase are available. Several of the data categories under Aid Activity Level Documentation and Financial Data are united in grant-specific documents. As IATI further develops, we look forward to more details on how this information will be extracted without additional reporting requirements. Where possible, it is suggested that IATI partner countries also make their aid-related documents transparently available.

Access Info Not yet clear whether documents are to be published in their entirety or just summaries of the documents. Access Info argues that documents should be published in their entirety, e.g. contracts. Some information will fall under an exception recognised by international law, such as protection of personal data, protection of commercial interests, etc. The sensitive information will need to be redacted from the documents, which can be done either manually or automatically for certain types of information contained in certain classes of documents. Increasingly it should be possible to anticipate the fields which will need to be withheld and to set up systems by which the information is automatically exempted, thereby reducing delays in making information available. Much aid information is still available in formats which limit reuse, either because it is proprietary software or non-machine readable (such as scanned PDF documents in which it’s impossible to do even a simple word search) or because of restrictions on commercial reuse of public sector information. We strongly recommend that the IATI standard includes norms on the format of the information, making it open source, not subject to any reuse limitations, and fully machine readable.

Noted. All useful issues to be considered when defining document part of standard and based on experience of donors that are already publishing. Agreed about exceptions based on law.


Donor and partner country governments face transparency demands from their own constituencies. Donors have already made efforts to increase transparency based on their national systems. Although DAC members have standardised their outflow statistics for comparative purposes, overall standardisation of both ODA outflow systems and partner country systems on inflow, usage and results of ODA does not make sense, since each performs a different role and responds to different transparency demands from their own constituencies. So, we think it necessary to have separate sets of data for transparency purposes: a) the DAC standardised data set on donor outflows; and b) the data sets for individual partner countries to be established within the specific context of each country. Important for both partner countries and donors to be able to relate inflow, use and results data to donor outflows, so the different systems must be loosely linked. But there is no justification for imposing an overall common standard on both of them.

Agree on the different roles for DAC and partner country systems and the need for links between them. These links will be best served by using common definitions and standards as fully as possible where it makes sense. But where the data are not common to all countries, IATI will not be pushing a ‘one-size-fits-all solution’. There will be local customisation, e.g. budget and sub-national geographic classifications, on which IATI is working and will be piloting in 2010.

DACU Project Coordinator, Ministry of Finance, Malawi

Extranet could be considered as an option for publication of the information. An extranet is a private network that uses Internet technology and the public telecommunication system to securely share information or operations with partners, customers, or other businesses. An IATI extranet can be viewed as part of IATI business extended to users outside the company. Publication of the information should be perceived as a way to do business with other business partners as well as to sell products to customers.

Noted and technically possible. However, aim of IATI is full transparency for all actors, including the public, and so open, free-access publication is what is proposed.


List of possible steps to demonstrate how raw documents and data would be made available could be strengthened by having ‘a minimum set of options’ (i.e. ‘lowest common denominator’) for how IATI signatories are expected to publish information.

Noted. Exact details of the 'how' to publish will be developed in 2010.

01 Country or Donor Headquarters Level Documentation and Budget AidCo - EC Clarify 01.13 Freedom of information act. For sections 01-14

and 01-15 the owner of the information is the Government, not the EC. Therefore, the EC is not entitled to make it available without previous green light from the Government.

Discuss link to partner plans and results as part of mutual reporting on results. Need to cover transparency policies for non-state organisations, such as EC.

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Organisation Abridged Comment ResponseAsian Development Bank

Some information sensitive and should have option for exception. Can provide standard tender (bidding) documents for contracts to be awarded by ADB's borrowers; but each project bidding document is slightly different and is owned by the borrowers, so ADB cannot commit to publishing such documents in IATI. Project information on private sector operations is currently confidential. Disclosure of MOUs would require concurrence from DMCs concerned.

Document exceptions and shared permission to publish documents still to be worked out. Plan to allow more time for this in 2010.


A number of the items should either be left out or should as a minimum be voluntary as they are not produced by the donors. Seen from a Danish point of view the following items should be left out: 01 05, 01 06, 01 14, 01 15, 03 11. The following items should be voluntary as they are not always produced by a donor: 01 08, 01 09, 01 10, 01 11, 01 12, 01 13.

Examine in more detail as public participation and funding opportunities are part of CSO pressure for more openness. Will work more on partner country role in results reporting. Recipient budget identifier is key for local flexibility that many comments ask for. Will look in more detail at planning budget information.


Seem to be asking donors to provide budget documents/ data from funded institutions (01 09 01 10). We recommend that this description is revised. Submissions, which constitute Ministerial advice, would be exempt from publication under IATI.

Clarify that 01 09 & 01 10 covers the budget of an official donor for its core contributions to other institutions. It is not the budget of the receiving institution. Exemptions for documents to be examined during 2010.

Hewlett Foundation

Not clear what policies would mean for foundations, especially when many program areas are not international. Procurement procedures mostly N/A. Foundations different (no FOI, no Parliament) - could perhaps provide budget after approved by Board, but may be sensitive and international aid portions not be easily extractable. 01 14 01 15 should be in the section below - when applicable to a specific country, okay to link to recipient country website ·

Foundations will need special assessments to see how standard applies to their different mode of operation. 01 14 & 01 15 intended at country not aid activity level.

Hewlett Foundation

The foundation does not fall under the jurisdiction of FOI legislation. Although many of the required documents/information do exist in the foundation systems in some form, they have not historically been available to the public. Therefore, it may take us longer to comply with the standard if we need to revise some of the documents before they - or the information contained within them - may be made public. With most grants, for example, there is sensitive personal information included in the primary documents (such as the agreement letter, e.g., the MOU), so for security reasons we would not be able to release them as is. Even if the foundation will have difficulty complying with some elements of the standard – or will take longer to comply – we would not recommend making the standard less comprehensive. We would rather be ambitious.

As above. Exemptions for documents will be in keeping with usual rules for non-disclosure of personal and commercially sensitive information.

GAVI Alliance Suggest that corporate key performance indicators also be included. These provide an important aggregate measure of institutional performance across several dimensions.

Consider when reviewing coverage of documents during 2010.

UNDP For 01 03, UNDP’s evaluations measure achievement of results and development effectiveness. Assessments of UNDP in terms of aid effectiveness are undertaken through the OECD/DAC surveys on monitoring the Paris Declaration and the MOPAN.

Consider availability of aid effectiveness measures during review of documents in 2010.

World Bank Based on the Bank’s recently approved Access to Information Policy, the Bank will not be able to provide public access to the following items: a) Internal World Bank administrative information. .. Donor Agency Budget as submitted to Board (01 07)..Annual forward planning budget data for agency (01 08)..Annual Forward Planning Budget Document for Funded Institutions (01 09)..Annual Forward Planning Budget Data for Funded Institutions (01 10).. Annual Forward Planning Budget Document of Country Offices (01 11).. Annual Forward Planning Budget Data of Country Offices (01 12)..There may also be issues with some of the documents referred to under (01 01)—e.g. HR and audit information--depending on how they are defined

Noted. Need to discuss with Bank what, if any, budget data are published at agency and country level. In doing the definitions we need to clarify that this is not about administrative budgets, but about programme budgets for Bank grants and loans. Bank funding for other institutions probably does not apply. Note need to address HR and audit issues in definitions, as well as public consultation and funding opportunities.

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Organisation Abridged Comment Response..There may also be issues-- related to either disclosure or relevance to the Bank-- with information included in (01 05) and (01 06), depending on their definition.

UNDP El Salvador

Exclude 01 05 Information on public participation in decision-making and evaluation. In many donor countries, the public does not participate directly in deciding what projects to fund, even less so in their evaluation. If this exists in some country, it’s a great idea to include it, on a voluntary basis.

Retain. Only donors that do provide these opportunities will have something to report.

UNDP El Salvador

Include Policies and Strategies of decentralized cooperation. Funding from decentralized cooperation can be significant; useful to integrate this data to get an integrated view of aid information from a certain country.

01 01. Add policies on decentralised cooperation to the description

WWF European Policy Office

Add strategic environmental assessments (SEAs). Paris Declaration calls for strengthening common procedures for EIAs for projects and common approaches for strategic environmental assessment at the sector and national levels. (Paragraph 41)

01 01. Add strategic environmental assessments to the list of types policy documents


Transparency and public participation will improve the quality of decisions impacting the environment and contribute to good environmental governance. Procedures for effective stakeholder participation in impact assessments should be made public, as well as the results, the measures or safeguards put in place to avoid negative outcomes and the reporting and evaluation procedures. Current document refers to impact assessments at the project level but not at the strategic level, without expanding on the information expected. Publication of environmental assessments of planned and past aid programmes at both levels, as well as results, recommendations, reports and the procedures for stakeholder participation and involvement would be important elements of IATI. Transparency would provide affected communities, civil society, parliamentarians, and the media, opportunities for improved participation in decision-making and monitoring of outcomes and results.

01 05. Clarify that opportunities for public participation should include environmental impact assessments.

Afghanistan - Ministry of Foreign Affairs

Each recipient country chalks out policies to manage and coordinate the aid they receive with the National Priorities and this policy guideline takes the form of Aid Policy Paper or Aid Coordination Mechanism. Include in the 1st category, the ownership of which belongs to the partner country.

01 14. Clarify that Aid policy papers related to the strategic plan are included

Dirección General de Cooperación Técnica y Científica, SRE, Mexico

Add Technical, South-South, Triangular and Horizontal cooperation to the charts of Appendix B to cover non-traditional forms of cooperation. There are methodological issues (e.g. some countries report concrete activities instead of projects, or the difficulty of identifying in Horizontal SSC, which partner carries the role of receiver and which the supplier). Mexico’s Information System of International Cooperation for Development Activities (SIMEXCID), soon to be launched to the public, provides examples.

Clarify that covers all sources of cooperation; treat methodological issues when deciding on definitions


Compliance with IATI standards would require huge increase of administrative budget – personnel and IT - when operational aid budget cannot be increased due to the financial crisis. Cannot be justified vis-à-vis our constituencies. Neither scope nor timetable seen as realistic. Some documents have confidential elements. Consider different disclosure cultures and legislations, in different countries. Unrealistic to disclose draft contractual documents prior to conclusion. IATI standards cover too many categories of data and documents.

Timetable being adjusted with more time to look into documents and national laws on disclosure and exceptions. Donor support workstream will help each donor to examine implementation costs.


Follow three principles: Information—let countries know what donors and governments are doing; Capacity—help countries lead the development process; Control—let countries lead the development process. Need independence in internal systems of countries or agencies on definitions, formats, presentation. Specific reporting format would undermine efforts of governments and agencies to lead their own development and deny citizens to participate fully in their own development. Thus omit 01 06 to 01 15.

Agree importance of ownership of development process. IATI is looking into where need flexibility in classifications to meet local needs, e.g. Budget. IATI is focused on first principal - information on what donors are doing. This includes the donors’ information on budgets and freedom of information (01 07 to 01 13). Need to discuss link to partner plans and results as part of mutual reporting on results.

Permanent Delegation of

Focus on consolidating CRS++ system and we avoid duplicating the work. Need further coordination with WP-

IATI will work more with WP-STAT and welcomes improvements to CRS++, which

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Organisation Abridged Comment ResponseJapan to the OECD

STAT. IATI format seems too wide. Compiling large amount of information is ideal but requires much higher administrative cost in reality; balance benefit and cost of collecting the data. Japan shares most of the data listed with developing countries and other donors in each country; reservations about putting such information in a uniform format given need to use country systems.

will benefit data quality in IATI. Individual donor assessments will look at cost/benefits. Main delivery will be through existing country systems, with flexibility for national classifications.

Ministère de la Coopération du Développement et de l'Aménagement du Territoire, Togo

En rapport avec les documents du gouvernement Il serait souhaitable d'avoir les PIP programme d'investissements du gouvernement, la loi de règlement et les lois de finance rectificative. Un des éléments sur lequel nous devons pencher est la forme de collecte des données de l'IATI, sur quel type de support cela va se faire, comment avoir la substance certains documents du gouvernement. Enfin, Il serait souhaitable d'avoir des informations sur le dispositif en place dans les différents pays dans le cadre du suivi des politiques.

Noted, but need more discussion of which partner government documents to include, as well as results to follow implementation of policies. IATI will work in 2010 on support required to make published information more accessible.

InterAction Inclusion of partner country government strategic plans and publications on results in the IATI standards seems a bit odd, since partner countries are not signatories. Also, why is this the only type of information that partner countries would be called on to make available and not budget information? Info codes 09 and 10: budgets of funded institutions rather than donors, seems problematic. Limit to IATI signatories.

More discussion of which partner government documents to include. Clarify that 01 09 & 01 10 covers the budget of an official donor for its core contributions to other institutions. It is not the budget of the receiving institution.

Access Info Recommend add following: Transparency Policies should donors have these, particularly relevant for institutions (e.g. World Bank and other IFIs) and states (e.g. Spain) without access to information laws. As well as laws, mention procedures that help information seekers. Integrity Mechanisms – to reduce and root out corruption, such as asset declarations and gift registers and risk assessment documents relating to prevention of corruption in recipient countries. Complaints and Whistleblower Mechanisms –guidance about complaints and whistleblower mechanisms. Document Creation Dates and New Document Due Dates –dates of current and updated documents and when next set of information will become available.

Consider when reviewing coverage of documents during 2010.

02 - Aid Activity Level DocumentationAidCo - EC In our view the Scope of reporting must be clarified: Is it only

limited to OECD /WP stats rules? (footnote 2 of code of conduct refers to Official Development Finance - ODF), or should it be extended to non ODA countries (Russia) and non developmental aid (like the Peace facility operations). Are we reporting on new projects or new + outstanding projects? The latter option would be burden of work and should be evaluated internally. Some information is confidential or sensitive and should not be published. Also third party should give agreement to publish: whole contracts, financial agreement and evaluation. A more profound analysis within the EC should be done. Evaluation reports of projects could be published with an agreement of funders and beneficiary. On Non-financial information, the EC has already a disclosure approach: Country Strategy Paper, Multiannual Indicative Programme and Annual Action Programme will be made available once they have been decided by the Commission.

Clarify that for official donors propose IATI will cover ODA and non-concessional development finance (i.e. ODF). Need to discuss take-on of outstanding projects. Confidentiality rules will be in line with existing disclosure regulations. Details of shared permission to publish to be discussed during 2010.

AidCo - EC 02.05 (and 02.06) Tenders, contract awarded: to be limited to information already available on EC website. 02.07 (02.09): Managed by EIB. EIB to be consulted.

Noted, useful to know rules for publishing on EC website.


For new projects only, we will publish all Project Documents, project information and wider documentation in line with IATI standards, unless there is a FoI exemption. We will aim to do this ahead of the IATI timetable. 02/06: Contracts awarded for project: Clarify description and thresholds. We will continue to publish links to contracts awarded but consider a link from them to project details in PPI. 02/09 Mid term monitoring report: We are not in a position to publish Annual Reviews.

Clarify definitions in 2010 and work on thresholds in line with procurement rules. Useful to share experience of why cannot publish mid-term monitoring information.

Hewlett Foundation

May be possible to release a public version of grantee proposal (with grantee's permission). Grant agreement letter (MOU), mid-term monitoring report, project completion report exist for all grants, but are not currently public documents.

Noted, definitions will need to cover foundation terminology

14

Organisation Abridged Comment ResponseMost grantees have a website, we could provide the link.


Unrealistic to ask for provisional and/or confidential data and documents. Many items listed in the IATI standard have confidential and politically sensitive elements, such as project documents in the appraisal/preparatory phase, concept notes, draft contractual documents, sensitive project evaluation reports and assessments, list of project contacts, or future funding opportunities. Disclosure of such information will not be feasible.

Consider when reviewing coverage of documents during 2010, noting though that some donors have addressed many of these issues and so may be able to share their experiences and their timetable to achieve more transparency.

World Bank Based on the Bank’s recently approved Access to Information Policy, the Bank will not be able to provide public access to the following items: b) Information to protect deliberative processes. This includes information about deliberations between the World Bank and its clients or third parties, as well as information about internal World Bank deliberations: .. Concept Notes (02 01). Pre-project Impact Appraisals (02 02).. Mid-term monitoring report (02 09)

Noted. To be taken into account in further work on scope.


At the aid activity level (02), most donors require environmental impact assessments (ex-ante) for relevant projects and these are usually based on the EIA legislation of the partner country.

Clarify that EIAs are part of documentation on pre-project appraisals (02 02)


The following should not be in the IATI standard: Concept notesPre-project impact appraisalsProject design docs / logframes Mid-term monitoring reportContracts awarded for project Loan Repayment Terms and Documentation

Discuss concerns about the inclusion of such items, some of which are already in the public domain.

Development Gateway

Additional channels of delivery/ implementing agencies, Bilateral or Multilateral Type should be shown as included in AIMS/AidData

Noted, will correct in next iteration

Ukraine Information on project design, purposes and tasks of the project (name and date of the document on adoption/agreement of the concept and/or design of the project); national beneficiary and direct receivers of the aid; conclusions of the authorized coordination body assessing project results and its effect on the development of the economy of the country.

More discussion needed on inclusion of project beneficiaries. Other information should be in project design and results documents, which are still to be defined in detail.

03 Identification dataAidCo - EC Many items available from CRIS only for new

projects/contracts. Additional channels of delivery/ implementing agencies: Clarify definition; limit to the OECD official list. New codes must be validated by OECD WP-STAT. Clarify Beneficiary Agency/Organisation. Aid Activity ID: CRS unique key to be implemented in CRIS in 2010.Recipient Budget Identifier: Information not in CRIS, added value not clear–could be eliminated. Define at which level project information must be published.

Noted that have information only for new projects. Definitions will be clarified in 2010. Will work with WP-STAT on channel codes. Link to the recipient budget is a key need for partner countries.


The following item should be left out: 03 11 - recipient budget identifier

Noted, but the link to the recipient budget is a key need for partner countries.


03/12 General/ detailed sector info: Recommend that donors work more closely in creating classifications to suit recipients (e.g. mapping DAC classification to IMF classification). 03/18 on other policy markers: We recommend that at a minimum, IATI standards should include a Gender disaggregated policy marker. 03/16 on detailed geographic information: This could be costly to collect.

Noted. Work underway on mapping to recipient classifications. If use CRS, markers will include gender equality and women’s empowerment. More work required on geographic information.

Hewlett Foundation

Bilateral or Multilateral Type not always clear when grantee works in many countries and we are providing "general support". Sector should be phase 2 for non-DAC. Project contacts: privacy concerns, only central/HQ contact info (not individual). Detailed geographic info: phase 3, difficult to track location of final expenditure when primary grantee later regrants the funds. Policy Markers: when available/applicable (have own internal policy markers). As many of our grantees (=”projects”) re-grant the funds to other organizations/implementers, it is difficult for us to know the location of the ultimate beneficiary. Presently, we do not require our grantees to report all this information to us. Interest to learn if other signatories support a policy of

Noted issues of re-granting for foundations and need to develop answers in line with policy for all donors on tracking spending through their project implementers.

15

Organisation Abridged Comment Response“encouraging” or “requiring” grantees to report to IATI. Hewlett is unlikely to require this of grantees in the near-term.

UNDP Items, if agreed upon by partners, would demand that Atlas system be adapted to map to the relevant codes. We estimate exercise would be very costly and require investment in staff training and business process re-engineering. Moreover, Atlas does not currently capture budget identifiers, sector identifiers and detailed geographical information, so policy and system modifications would be needed. See these items as potentially phase 3 with caveat that would need to decide feasibility of their inclusion and ATLAS adaptation in view of the costs.

Donor support workstream will help each donor to examine implementation costs.


The following should not be in the IATI standards: Project contacts, Detailed geographic info, Tied Aid Status

Discuss concerns about the inclusion of such items. Tied aid status in CRS. Detailed geographic info is frequent request from partner countries. Contact information will be generic e-mail accounts, not named individuals.

InterAction Category 03 – Project contacts: Wonder whether this would put an undue burden on agencies’ field staff. Agree with the idea of establishing a threshold below which only partial aid information will need to be provided.

Contacts will be generic not individuals. Cost benefit work has looked at burden of requests from providing access to more information against burden of many current ad hoc exercises.


Pleased that detailed geographic information will be captured. However, to what level of detail? Will this be linked with Google Earth or other similar mapping services? For 03/04 include “partner agencies” as part of the information that is being captured. For 03/09 wonder whether aid activity codes can be standardised at a level that is useful and comparative, particularly since additional information is being captured through 03/10 on title and description. 03/17 is an important step in addressing the use of tied aid, but propose a second step be use of a definition that is greater in scope than current OECD/CRS.

Noted, will bear in mind during definitions work. We do not underestimate difficulty of achieving comprehensive geographic coding and unique project Ids. Tied aid coding will need to adhere to CRS definitions as these are the data that are available.

Ministère de la Coopération du Développement et de l'Aménagement du Territoire, Togo

Pour les projets ne serait-il bon de fixer un montant des projets à recenser aux risques de ce trouver avec de trop petits projets. Au du SPA Special Program with Africa il y est fait un important travail sur les appuis budgétaires comment aussi donner une place à cette modalité de l'aide avec surtout leurs cadres d'organisation ?

Thresholds for project documents still to be decided, along with any exclusion for data, though main principle is to cover all aid flows in order to have complete information for countries. Budget support will be included as a type of aid.

Ukraine Notions of national beneficiary and national recipient should be clearly defined, since in IATI proposal beneficiary actually means implementing agency – donor organization that receives contract but not a local aid receiver. We propose: Recipient is resident that directly receives international technical assistance, and Beneficiary is a central executive power body where the implementation of the project is foreseen and interested in the results of the project but not directly receiving international technical assistance.

Agree need for clarity. More discussion needed on definition of implementing agencies and inclusion of project beneficiaries.

04 Financial DataAidCo - EC In our opinion agreements cannot be made public as they are

an international contract between 2 parties (the Commission and a beneficiary country or an implementing partner) and both parties need to agree to make it public. We cannot disclose the content unilaterally. (For this reason, the Agreements are not even disclosed to the Member States within the management Committees.) Annual project budgets: Not relevant for Commission in general (one unique global commitment). In general, Total Amount = annual amount. Planned disbursements or payments: Forecast module still not reliable. Added value not clear as estimated at the level of project. To be eliminated? Actual Disbursements or payments: OK if OECD/CRS Rules (i.e. aggregate disbursement). Clarify at what level payment must be reported must be clarified; e.g. for decentralised management, EC can only report payment to country. Loan and interest repayments: Need to consult EIB; timetable M/Q seems unrealistic and inclusion in phase 1 seems impossible.

Clarify definitions in 2010 to examine shared responsibility for publication; for discussion in the TAG and SC. Annual budgets and planned disbursements key for predictability - a major commitment in the AAA. Clarify disbursement and repayment requirements in donor assessment.

IATI DFID 04/01 on joint funding: would need agreement to publish Clarify definitions will be in line with DAC

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Organisation Abridged Comment ResponseReference Group

others’ funding where they are also IATI co signatories. Where other donors are not co-signatories, suggest we only show aggregate figures. 04/04: Annual commitments by individual donor: description should be clearer and in line with DAC definition.

where they exist. Will need to discuss what can be published when there is a mix of IATI and other donors.

DFID Vietnam What I think missing is technical assistance/research, studies. Use of the words project and aid activity intermittently in the document/table is confusing.

Clarify that all types of aid are covered including technical assistance/research, studies.

Hewlett Foundation

Planned disbursements or payments: has not been public information. Actual Disbursements or payments: has not been public information.

Noted, donor assessment offers chance to review this.

UNDP Item 04 06 requires actual disbursements to be captured both according to calendar and recipient’s financial year. At present, the information is captured according to UNDP’s financial year, which corresponds to the calendar year. UNDP sees these items as potentially for phase 3 with the caveat that would need to decide on feasibility of their inclusion and ATLAS adaptation in view of the costs.

Alignment with partner financial year is a major requirement. Donor support workstream will help each donor to examine implementation costs.

UNDP The standards should be flexible and recognize the constraints of multilateral organizations in terms of providing forward-spending plans on non-core funds (items 04 04, 04 05).

Noted, the issue of improving predictability of non-core funding needs to be examined with the donors that provide the funding.

UNDP El Salvador

Total sum and percentage of tied funds. Justification: Although conditionality and tied aid is required in Code #03, it would be useful to see it in financial terms. Percentage of expenditures disbursed. Justification: It is useful to visualize how a project is going with percentages, so it would be an interesting way to present the information.

Good example of type of calculation that could be made from published information.

World Bank Loan Repayments and Interest Repayments (04 07 and 04 08). Given that this information is market sensitive there will need to be a reporting lag of at least 6 months.

Noted.

Afghanistan - Ministry of Foreign Affairs

1. Most projects have technical assistance portion. The aggregate level information on the TA is necessary for the Partner country. Suggest that the TA breakdown of the expenditure be included as well. 2. The projects have administrative costs the detail of which is necessary for the stakeholders. This will further enable us to track the effectiveness and efficiency of the project

Consider in light of information already recorded in aid management systems. Not readily available in current donor systems.


The following should not be in the IATI standards: Total project cost (including all donors and any government funds), Total amount committed by individual donor


Development Gateway

Actual Disbursements or payments should be shown as included in AIMS/AidData

Noted, will correct in next iteration

05 – Results dataIATI DFID Reference Group

05/01 and 05/02 on outputs and outcome indicators and results indicators. In this area it will be particularly important to have clear and consistent guidance and definitions to ensure that all agencies are correctly interpreting.

Agreed

GAVI Alliance Results may be available in documents additional to those specified in the ‘results data’ section (05), and we request the flexibility to include outputs/results beyond what is specified here (this may, for example, include a link to the immunisation/health system information collected by the WHO/UNICEF Joint Reporting Form and made available on the WHO website). It is suggested that the spectrum of information collection be extended to output, outcome and impact targets, indicators and results.

Noted, to be examined as we look at what information on results is in practice available for publication.

UNDP El Salvador

Information that should be given in a posterior phase, 05 – Results data It is usually harder for the donor to provide information on results and indicators that is updated. It might be better to suggest this at a later phase.

Already in Phase 3, and there are requests to do more on results, so hope this can be addressed within this final phase of IATI implementation


The following should not be in the IATI standards: Outputs and outcomes indicators and Results indicators



While having results-based information on aid is essential, being able to successfully capture and standardise it is challenging without a clearer and common basis for evaluation that is used by all donors. TI would recommend cutting the

Agree with the difficulty, but there are requests to do more on results, so hope this can be addressed by the final phase of IATI implementation

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Organisation Abridged Comment Responsecategory of information known as “Results Data” unless these conditions were to change.

Independent Both of the fields in this category are listed as being free text, with links to the results matrix and final results matrix respectively. My reading is that the information contained in these matrices will not be published - only the references (URLs?) pointing to those matrices. This seems a missed opportunity. There is tremendous potential value in being able to compare the results and outcomes of different projects and organisations using the information in these matrices. I presume the perceived difficulty of making the matrices used by different organisations compatible with one another has precluded their inclusion. Ideally the standard would contain a form of matrix which could be used by all projects and organisations. A middle ground would be to include the project matrices in the standard, even if different organisations use different types, so researchers would be able to compare the matrices without having to format them. A link to the matrices is the worst option, with PDFs (from which data cannot be extracted), files which no longer exist, files in a wide variety of formats, and so on.

Noted, to be examined as we look at what information on results is in practice available for publication.

05 – Other dataAidCo - EC Project specific Paris Declaration Indicators: Not available.

Conditions: Please clarify added value. Could be eliminated. Publication date of IATI Information: Date of first submission or date of update (ex when status changes)?

To be examined. Some AIMS have project level Paris indicators. Improved information on Conditionality was a major partner country request and included in the AAA. Will clarify date stamping as part of work on data formats.

Hewlett Foundation

Conditions: OK, but perhaps not all if privacy concerns. Agreed, exceptions to be worked out based on FoI rules or disclosure policy when FoI does not apply.


The following should not be in the IATI standards: ConditionsProject specific Paris Declaration Indicators


Code of Conduct - GeneralAidCo - EC In general we welcome the principles and most elements of the

code of conduct. It gives a clear guidance on how the IATI signatories should behave and what the added value is of IATI compared to existing mechanisms. We would like to share the following observations, which need further discussion and decisions to be taken by the Steering Committee. In our opinion, the code of conduct should not be finalised nor signed until Part 1, 2 and 3 (What to publish, definitions and common format) of at least phase 1 are agreed and finalised. We would like to recommend that the code will be kept on the radar screen of IATI and keep it 'alive' in order to avoid the need to have all the work to be redone. We propose that further work will be done on: 1. The way the text is currently formulated (too legal?). 2. Defining the relationship between the code with the other parts of the standard (added value). 3. Internal scrutiny and interpretation by all signatories of the current principles and proposed operational agreements, and the operational implications. For instance, the EC wants to clarify that we see the current contractual obligation to publish ex-post, can already be considered as a "similar" standard as expressed in operational agreement. 4. In addition the EC has to assess the additional costs and workload of the implementation of the IATI standard (see also par 4). 5. The issue of central register should be further developed, especially at the technical IT level (how to retrieve information from different databases, updating and management of aid information and web sites).

Noted for further discussion of Code of Conduct.

AWEPA Under section 3, Review and monitoring, under point 4, Core Monitoring Group: I thought you informed me that it would be possible to include a parliamentary representation. My sense of the discussions in The Hague was that the exclusion of parliaments would be addressed. AWEPA would be happy to take up this role as part of our parliamentary platform on ODA work.


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Organisation Abridged Comment ResponseHead of Statistics Unit, Austria

RE: Signatories will “… agree to allow third parties to use it freely, for example to develop aggregated aid information, provided that the source of the information is acknowledged and the verification status of the information is made clear.” IATI focuses on unverified early information, while definitive “statistical” results will remain in the domain of DAC/CRS. Statistical reporters have learned that, in practice, the claim of making the verification status unmistakably clear is hardly ever met, the obvious reason being that a striking “health warning” about the preliminary, indicative nature of the information would weaken its authority and analytical worth and hence is often toned down to a degree where it is no longer recognized as such by users. Aggregation of data and information by users that are not familiar with the complex concepts and definitions on which aid data collection is based is an extremely risky undertaking and will, almost necessarily, lead to flawed aggregation results. Statistical reporters, often asked to validate data and information users are about to publish, have seen many cases where the underlying definitions and concepts were unknown or misinterpreted and both data and analytical results were wrong. In some cases database downloads were found to be flawed (sometimes due to instabilities when access is through the Web), errors were found in data harvesting methods (that no one would have detected unless we donors had checked on our data) and many a misinterpretation had to be corrected. Considering this long experience, statistical reporters’ concerns should be taken seriously. Transparency requires an extraordinary sense of responsibility and cautiousness, as the damage done can be much greater than the benefit achieved.

Noted for further discussion of Code of Conduct and indicating status of data included in IATI standard.


TI fully endorses the use of a code of conduct to govern this initiative. A code of conduct helps to ensure that transparency is authentic rather than simply being pro-forma. A code of conduct provides an incentive for donors to meet their own pledges for disclosure and provides an important accountability mechanism to ensure that the standard is upheld in the spirit and letter of which it was designed. The finalisation and launch of the IATI code of conduct should accompany the roll-out of the standards being adopted. Ideally, the code of conduct would be completed and agreed upon by IATI signatories in phase one of the project. However, its release should not exceed phase 2 of the standards implementation. In terms of the standard, compliance with the code of conduct could also be staged. Monitoring by IATI of its implementation by signatories would be based on the agreement that failure to meet the code of conduct in one year would be used to improve a donor's compliance in the following year. The current areas covered by the code of conduct are the minimum to ensure that the standards are enforced and IATI is able to meet its objective of aid transparency among signatories. TI's previous experiences in working on codes of conduct could be useful to help identify additional areas that should be covered in the text. For more information, see policy research at www.transparency.org. Specific chapters have done extensive work in developing codes of conduct. For example, the UK chapter of TI has developed common industry standards and a code of conduct for the defence sector.

Noted for further discussion of Code of Conduct and appreciate material to draw on.

Code of Conduct - EndorsementHewlett Foundation

Our lawyers caution that Hewlett may only be able to sign the Code of Conduct if we are able to craft the language in the Operational Agreements in a manner that is a bit more “aspirational”, such as “signatories aspire to implement the IATI standards…” I know that such language would take the teeth out of the code, but I have been asked to flag the issue. I imagine that similar concerns from donors will inform much of our discussions.


GAVI Alliance As the IATI team moves towards re-drafting this document, it is suggested that the code also cover partner countries’ compliance with IATI, as any information-sharing exercise is

Responsibilities of partner countries still to be discussed.

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Organisation Abridged Comment Responsea mutual responsibility.

USAID Should the US decide to formally consider the proposed Code of Conduct (CoC) it must avoid open-ended cost commitments, ex-ante agreement on standards that have yet to be produced and have a disclaimer clause on legally binding. Without these issues being resolved, it would be very hard for the US to consider endorsing or signing the CoC. Certainly, an absolute minimal requirement would be a disclaimer on legally binding and a limitation on cost. The continuing implication that the IATI steering committee will take on the status of a permanent international body is a major issue, since the US is flatly opposed to the standing up of independent permanent international bodies.


USAID To replace "will" by "should" in the guiding principles since the use of the term “will” leads to confusion as to the intention of the participants and our official office dealing with treaties and other documents that the USG signs recommends that this term be avoided in non-binding documents. If one insists on a treaty like document with binding agreements, then what is being sought is something which was not sought for the Paris Declaration or Accra Agenda for Action, and is quite unlikely to happen for an effort such as this.


Code of Conduct - WordingBMZ, Germany Para 4: Germany is in favour of the sentence in brackets

("Partner countries are called upon (...)") Chapter 2, Operational Agreements: Paras 4, 5 and possibly 6: Aren't these paras redundant to the operational documents? Redundancy should be avoided. What is the envisaged timing for the adoption of the four parts of the IATI standard (on the "What", the "Definitions", Electronic Data Format and the Code)?

Noted for further discussion of Code of Conduct. Timing to be decided by SC on 30 November.

Hewlett Foundation

Our primary challenges will be that: a) many of our documents are not currently in the public domain; and b) we do not presently require our grantees to adhere to IATI-like standards, so we will have difficulty complying with the code since they would not be complying with the code. We also understand that many of the bilaterals have questioned the “treaty-like” language in the Code, so we will plan to review it again with our in-house legal counsel after the next version is circulated.


Hewlett Foundation

Question value added in Paragraph 4, which addresses the principles of ownership and mutual accountability. As both principles are also covered in Paragraph 5, not sure we need Paragraph 4.


World Bank Pleased to see progress in revising the Code of Conduct. However, the main concern for a multilateral institution such as the World Bank still remains: the language suggests that IATI agreements are of a binding nature. Language such as “places an obligation….” is equivalent to a policy for the Bank, which would need to be approved by the Board of Directors. This will likely be a concern for other multilateral organizations as well. Therefore, we would like to suggest that multilaterals are exempt from applying the Code. But they should be encouraged to have their governing bodies endorse policies which further the principles and the behavioral change intended by the Code. A few other observations which might be useful: • We strongly endorse the suggestion that the Code will not be finalized until after the other three parts of IATI are finalized. The Code refers to the “Standards”, to the "IATI central registry" the "deadlines for the three phases" and other things, which are not yet defined and agreed upon.• Some clarification is needed on “requiring similar standards of reporting in their contracts with implementing agencies." Defining “implementing agency” will require some more thought and discussion within the Steering Committee.• Item 7 "communication and capacity development" needs to be deleted or revisited. Several members of the Steering Committee requested that this provision be deleted.• The concept of a "core monitoring group" needs to be discussed further. As IATI moves from design to implementation there

Noted for further discussion of Code of Conduct. Will need to determine how standards will be monitored in multilateral organisations.

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Organisation Abridged Comment Responsewill be a need to revisit the support structure to see what is needed. What happens to TAG for example? Does it continue to exist after the design stage?• Partner country scorecards might not be possible in, or suitable to, all circumstances and the reference to monitoring in conjunction with mutual accountability exercises is premature as many countries do not have them and there is no standard format for them.


Paragraph 3, FOIA of countries is not necessary in the text, could be included as a footnote. For paragraph 4, the suggestion would be to include “democratic ownership” as one of the areas that increased aid transparency contributes to. For paragraph 9, TI recommends including a footnote to describe what is CRS. Under “Operational Agreements”, TI would recommend that point 3 includes applicability to third parties. Under “Operational Agreements”, TI would recommend that point 4 includes more specific text to address exceptions. Under “Review and Monitoring of adherence to IATI standards”, TI recommends that the levels of monitoring be better condensed to limit overlap. It should also recognise the fact that if the data platform has the information available, then donors will be in compliance with the standards and the code of conduct.


InterAction Applicability: This language is perhaps a bit too strong. I’d be concerned about holding NGOs to IATI-level aid reporting standards, especially on the same timeline as donors and without assistance for increasing their capacity to comply. Also, something like this should be a matter of negotiation between NGOs/implementing agents and government agencies. Perhaps the language could be softened along these lines: “Signatories agree to work with their implementing partners to increase their capacity to adhere to IATI’s transparency standards”? At a minimum, the word “requiring” should be changed to “encouraging.” I also understand that the Open Forum for CSO Development Effectiveness will be looking at this issue and wonder whether it would be possible to take into account even preliminary results from that process when developing this section.


Code of Conduct - MonitoringAUSAID, Australia

Once the IATI standards have been initially established, there is a need for ongoing governance of IATI in two regards: a) to implement and apply the standards which are agreed for any given period; and b) to refine and evolve the standards over time. On the second point, aid methodology - and the requirements of aid information - are steadily evolving over time - and this will need to be reflected in the evolution of the IATI standards over time. They cannot be static in the medium to long term. Governance is intimately connected with institutional structure. Initially, the IATI was launched as an approach to public information on aid without clear specification of the institutional structures/international practices for governance and implementation. But - inevitably - this has now become a key issue for discussion.Many of the standards to be based on well-established, aid reporting standards and practices, particularly those of the OECD-DAC. Conflicting indications of whether (and to what degree) additional, independent, institutional arrangements (and consultative processes) will be established for the implementation (and governance) of the various elements of IATI. At one pole, IATI might become a significant new international organisation, sitting alongside existing donor organisations and associations, with most bilateral and multilateral donors becoming direct members (as "signatories" to IATI, and parties to the IATI agreement), and with these donors managing IATI implementation (and governance) through the new organisation on a permanent basis. Such a new institution would have a wide-ranging mandate, and overlap with the responsibilities of both bilateral and multilateral aid organisations. It would not be our preferred approach

Noted for further discussion of Code of Conduct and institutional arrangements for IATI.

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Organisation Abridged Comment ResponseAt the other pole, IATI could establish the standards in an international leadership role, and perhaps undertake some over-arching high-level review function. But it could be agreed that implementation (and governance) of major elements of IATI, which already have a home in the international institutional framework, would generally stay in their current institutional locations, while being undertaken within the over-arching IATI international aid policy framework, and with recurrent dialogue with key IATI stakeholders, particularly partner governments. This would be a "franchise" approach to IATI implementation (and governance), with each arm of the Initiative being implemented and governed through the most suitable part of the existing architecture of international aid management.For example, one major arm of IATI aid reporting is to be a (slightly) extended version of the current CRS++ aid reporting typology. However, CRS++ is owned (and further developed over time) by the member states of the DAC/OECD. - the default option is that the continuing evolution of the CRS++ reporting framework will remain with the OECD, but would be undertaken by the responsible DAC members - in accord with the international aid reporting principles of the IATI, and - with regular policy consultation with the other interested parties, particularly partner governments. On this model, existing major aid reporting elements which are taken up into the IATI would retain their basic institutional home within current international institutional structures, and their further development and governance over time would be undertaken (consistent with the agreements and policy objectives of IATI) through the existing institutional framework.

InterAction Monitoring: It may be that this section is to be developed further, but as is, it raises some questions (below). My overall impression is that there are too many layers of monitoring being included in the code of conduct. Will the partner country score cards, like the donor reporting, be done on an annual basis? Core monitoring group: What is the core monitoring group? In other words, is it an independent agency, or part of the IATI secretariat? How long is its mandate and how often will it meet to review progress? Yearly or just once (there is mention of “the” report of the group)? Will partner countries and CSOs receive funding to participate in the core monitoring group? (this would likely be necessary) How does this group relate to the group that will be conducting the mid-term review? Independent monitoring: It is not clear why independent monitoring needs to be included in the code of conduct. I imagine that certain CSOs/think tanks will choose to do monitoring on their own, for which IATI could set aside funding if it wanted to ensure that independent monitoring takes place (or that an independent reporting mechanism be developed). Independent consultants could be hired by the core monitoring group. I would therefore eliminate this type of monitoring from the code of conduct.



Suggest “Code of Conduct” be conceived more as a set of IATI “Directives”, focusing on the identification of good, transparent behaviour and reporting-practices that are additional to the DAC-directives. Strong reservations regarding the proposal of a new body for monitoring. Being an initiative, launched in the spirit of the Paris Declaration, IATI should aim at defining good practices that are feasible to be covered by regular DAC peer-reviews.

Noted for further discussion of Code of Conduct. DAC Peer Review may have a role to play, but monitoring will need to be more frequent than every 4-5 years and to cover non-DAC signatories.

Colombia This Mid-term review should be before HLF IV in 2011. The political endorsement to this initiative is absolutely necessary to guarantee the sustainability of this Initiative

Noted, will depend on timetable, but IATI and transparency will certainly feature at political level in Seoul.

Partner country capacityAUSAID, Australia

The overall package of information proposed is complex. This could markedly add to the transaction costs of data users, particularly those of partner governments. Ease of electronic access is not necessarily the main factor in high transaction

Noted for capacity development workstream. The aim is for aggregators to produce easy-to-use systems - tailored to specific needs - that become sources of key information to

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Organisation Abridged Comment Responsecosts for partner governments. The structure of the data content is also a likely source of major transaction costs. For ease of use, the overall structure of the data content needs to be simple, easily surveyable, and readily intelligible. Given the institutional, human resource, and knowledge base constraints within many partner governments they cannot afford to invest significant time (or human capital) in becoming users of complex data structures. Capacity building may sometimes be largely irrelevant to this point. If partner officials and institutions do not have the time to invest, capacity building may be of limited utility.

officials to fulfil their roles.

Ministry of Foreign Affairs, Sweden

How will individual partner countries' needs be accommodated by the IATI standards? Each country has its own budget system with different expenditure areas, policy areas, etc. Partner countries would still need to develop their own systems and collect the information they need from donor countries.

Agreed. Partners will be able to access the published information to update their AIMS. The standard will allow for flexibility in the budget and other country-specific classifications.


In partner countries, performing aid management systems should not be weakened by the introduction of new standards. What we gathered from the Conference was that common standards and definitions could be useful to address the transparency issue, but should not compete with existing AIMs. Imposing a standard, which would require additional and specific capacity development efforts, would go against the principle of ownership.

Noted. IATI intends to work with partner countries to strengthen existing AIMS them not compete with them.

DFID Vietnam Many developing agencies are still struggling with finding a good software for aid data, so if we can come up with something easy to use, low cost for countries to maintain and easy to transfer the existing data - it would be good.

Agreed on importance of AIMS to be sustainable and easy to use.

Ministry of International Co-operation, Egypt

Most developing countries are lagging behind in terms of the range of information available and of organising it in one accessible focal point. The issue of statistical inadequacy has been discussed in many meetings and there are efforts that I'm sure you are aware of that are addressing these difficulties. Most developing countries would be prepared to initiate the upgrading of their aid data bases but many would need technical assistance. The question, therefore, is whether IATI can assist or collaborate with those already providing such help.

Agreed, IATI is working with UNDP and AIMS suppliers to improve AIMS to deliver better data. It also plans to engage with country-produced systems in the pilots. Work on results will make link to statistical initiatives.


A considerable number of partner countries already have home-grown systems that should be respected and supported (by donors). Those who have not should be encouraged to start building them according to their own needs rather than be urged to take on donor-made systems. Our concern is that existing and performing systems will be weakened if IATI requires partner countries to adopt IATI global standards and formats, as it could easily lead to abandonment of their own systems due to capacity constraints. Our understanding is that the ultimate objective in partner countries, same as in donor countries, is to make aid flows transparent and information on them available to stakeholders. From this perspective, to standardise such data systems at any cost by imposing a donor-driven initiative is not in the spirit of the Paris Declaration or the AAA, quite contrary, it is undermining the principle of ownership.

Noted. IATI intends to work through existing AIMS - whether externally supplied or 'home-grown' - to improve the availability and sustainability of information. Most of the information required is standard across countries, which will be helped by using international standards. Country-specific needs are addressed by customising each system and using national classifications, such as for the budget and administrative units.

Permanent Delegation of Japan to the OECD

Many developing countries have developed their own statistical system according to their needs and background. Donors’ responsibility is to help enhance their systems rather than creating another system. Also, we have to be careful that “aid” is not a standalone issue in each country but only a part of various activities for development. Thus, what is necessary is to integrate aid information into their country’s statistical system rather than creating a separate “aid information system”. We should comply with the ownership and alignment principles which we all agreed on under Paris Declaration and Accra Agenda for Action. Each developing country should take the lead to create its own system, including regulations on what information should be published and how to publish, based on their needs.

Agreed that AIMS should be linked to each country's budget and financial system, which in turn should be part of the country's statistical system. Countries own these systems, but will benefit from having information readily available in a standard format to populate them. Donors committed to making such information available in the AAA.

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