## IMF Central Bank Transparency Code (CBT) — CBT Portal FAQ

## Source details

**Canonical URL:** [IMF Central Bank Transparency Code (CBT) — CBT Portal FAQ](https://www.imf.org/-/media/files/data/cbt/landing-page/imf-central-bank-transparency-code-faq-for-cbt-portal.docx)

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- [Markdown version](/-/media/files/data/cbt/landing-page/imf-central-bank-transparency-code-faq-for-cbt-portal.docx.md)
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### CBT Portal access and use
- The CBT Portal is accessible for everyone. Its main function is to provide more detailed information on the CBT and to facilitate search queries of the CBT.
- Central banks can use the CBT Portal to download the Review Template (RT), and submit it to IMF Staff. Currently, this can only be done via email (CBT@imf.org), though the functionality of the Portal might be expanded in the future.
- The Review Template (RT) that is listed on the Portal is intended for use by IMF Staff and country authorities only. Though the (blank) RT is publicly accessible, the IMF does not accept fully or partially completed RTs from anyone but the country authorities, in case an agreement between the IMF and the (relevant) country authorities has been made to do so.
- Anyone wanting to provide feedback on transparency practices of one or more central banks is urged to do so directly with the central banks concerned.

### Complaints, contact, and availability of reviews
- Complaints about the lack of transparency of a central bank should be directed to the central bank concerned; the IMF does not accept such complaints via the CBT Portal.
- The IMF CBT Team can be contacted by sending an email to CBT@imf.org.
- CBT (self-) reviews are only accessible to the central bank concerned and IMF staff. Publication of a CBT (self-) review is dependent on the central bank.
- The IMF does not list which central banks will be reviewed in the (near) future, nor provide information on whether a central bank’s transparency practices will be reviewed in the future, nor provide information on which CBT reviews have taken place, except when a central bank itself chooses to disclose that information or allows the IMF to disclose such information (for instance, by publishing a CBT Review Report).

### Scope and application of the CBT
- The CBT applies to central banks of monetary unions and their transparency practices. This currently includes the ECB (European Central Bank), ECCB (Eastern Caribbean Central Bank), BCEAO (Central Bank of West African States), and BEAC (Bank of Central African States).
- In the case of the ECB, the CBT would simultaneously also apply to the so-called National Central Banks (NCBs). In the CBT (self-)reviews, transparency practices of the monetary union central banks would be reviewed. In case of European NCBs, relevant transparency practices of the ECB would be reviewed in addition to the NCB transparency practices.
- The CBT does not rate central banks on their transparency practices, nor does the CBT offer a methodology to rank central banks vis-à-vis each other. Instead, the practice levels (core, comprehensive, and expanded) are intended to guide central banks in their transparency whilst ensuring country- and central bank-specific circumstances are duly taken into account.

### Function-specific scope and exclusions
- The CBT provides guidance on central bank transparency only; it does not provide guidance on central bank governance, including the central bank’s mandate, the decision-making structure(s) of a central bank, and whether the central bank should also be a financial supervisor. Such matters explicitly fall outside the scope of the CBT.
- A review of a central bank’s transparency would only cover the current mandate of the central bank (objectives, functions, and instruments, as per its legal framework), either in part or fully. Issues that fall outside of that mandate would not be covered by the CBT.
- The CBT uses the concept of autonomy to signify that the central bank is part of the State, subject to a legal framework and is accountable to the legislature and the general public. The CBT addresses whether a central bank (i) is prohibited from seeking or taking instructions from any private or public body (institutional autonomy), (ii) can perform its duties without prior approval from the government (functional autonomy), (iii) has the financial resources available to fulfill its mandates (financial autonomy), and (iv) whether the members of their decision-making bodies have security of tenure (personal autonomy). The CBT only provides guidance on the transparency with respect to central bank autonomy and not whether the central bank’s autonomy is sufficient, or not.

### Legal framework and mandate transparency
- A central bank law (sometimes called organic law) constitutes the main element of a legal framework. In addition, the CBT includes the Constitution, treaties, and relevant regulations as well. Other laws such as banking, currency or payment system laws are also relevant as they include provisions on central bank’s mandates, decision-making structure and autonomy.
- In applying the CBT the central bank and reviewers should check the transparency of all applicable laws.
- Information in a central bank’s legal framework needs to be “translated” into more easily understandable language so that the central bank’s professional and non-professional stakeholders are able to understand and evaluate the information disclosed by the central bank.
- In the CBT, mandate is defined as a central bank’s objective, functions, and powers. What matters is that the objectives (e.g., ensuring price stability and or contributing to financial stability), associated functions (e.g., monetary policy or macroprudential policy), and legal powers (e.g., private law powers to open accounts and conduct financial transactions, or public law powers such as imposing statistical reporting obligations) are clear and transparent.

### Internal accountability and audit committee disclosure expectations
- Leading practices indicate a central bank should disclose whether:
  - the central bank has an audit committee;
  - and, if it does, the names of the members, the number of times the committee met in the past year, and a brief description of the topics discussed;
  - the audit committee has at least one “financial expert”;
  - the audit committee is governed by a charter and, if so, whether a current copy of the audit committee charter is available on the central bank’s website;
  - the audit committee members are independent.
- An audit committee report should be published and disclose whether the audit committee has:
  - reviewed and discussed the annual financial statements, including significant accounting policies with management;
  - discussed the required communication matters under applicable auditing standards with the external auditor;
  - received the required written independence communications from the external auditor;
  - evaluated the external auditor’s performance;
  - overseen the central bank’s risk management processes and internal controls;
  - assessed the performance of the internal audit function.
- A central bank should consider highlighting any changes to the audit committee’s oversight activities and key focus areas for the audit committee during the year, for instance, cyber security, ethics issues, internal investigations, or health and safety-related matters.

### Financial integrity: AML/CFT disclosure expectations
- Internal AML/CFT control frameworks relate to central bank activities that create ML/TF risks; recognizing central bank mandates vary, these principles may not apply to all central banks and will need to be considered on a case-by-case basis.
- Example: if the central bank provides bank accounts to companies or natural persons, these activities create the need for internal AML/CFT systems/controls.
- Disclosures regarding AML/CFT supervisory processes relate to offsite and onsite activities, for example, details of the supervisory minimum engagement model, the number of inspections that were carried out, the level of desk-based reviews etc.
- Disclosures on AML/CFT supervisory outcomes relate to the results/conclusions stemming from onsite/offsite activities, for example, the volume of findings that were identified and details of the breakdown of findings across different thematic areas, and details of sanctions that were imposed for breaches of AML/CFT requirements including a description of the weaknesses that were identified and the severity of the shortcomings.

### Anti-corruption measures and internal code of conduct
- Expected behavior of staff to prevent corruption and conflicts of interest could include the policy that central bank officials are required to follow regarding their financial disclosures and measures relating to conflicts of interest.
- Disclosures could cover how the central bank governs conduct and ethical behavior, including rules surrounding decision-making and impartiality, how staff are required to approach and document conflicts of interest, and the acceptance of gifts and hospitality.
- To demonstrate transparency in relation to internal conduct rules, central banks should disclose details regarding recruitment processes (e.g., controls to ensure that decisions are based on merit), the level of resources (e.g., human, technical capacity) of the function in charge of implementing the conduct rules, their annual report(s), and statistics about the number of analyses, investigations and sanctions imposed on staff who violated the rules.

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_Source: https://www.imf.org/-/media/files/data/cbt/landing-page/imf-central-bank-transparency-code-faq-for-cbt-portal.docx_