## Guidance Note for Reviewing the Implementation of the Central Bank Transparency Code

## Source details

**Canonical URL:** [Guidance Note for Reviewing the Implementation of the Central Bank Transparency Code](https://www.imf.org/-/media/files/data/cbt/landing-page/imf-central-bank-transparency-code-guidance-note.docx)

## Other formats

- [Markdown version](/-/media/files/data/cbt/landing-page/imf-central-bank-transparency-code-guidance-note.docx.md)
- [Structured JSON version](/-/media/files/data/cbt/landing-page/imf-central-bank-transparency-code-guidance-note.docx.json)

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### Use of the Guidance Note
- Prepared to guide Reviewers in conducting the Review of the Implementation of the Central Bank Transparency Code (CBT) and in completing the Review Template.
- Provides guidance and practical suggestions on reviewing central bank transparency practices according to the CBT, focusing on dimensions of transparency: means, timeliness, periodicity, and quality of disclosure.
- Not intended as a detailed or prescriptive manual for measuring transparency; flexibility for country-specific interpretation is emphasized.
- Will be updated following country pilot cases at the end of the pilot phase.

### Objectives of the CBT Review
- Assist central banks to evaluate and improve transparency practices, strengthen dialogue with stakeholders, and contribute to policy effectiveness.
- Applicable to all IMF members on a voluntary basis.
- Enable central banks to assess existing transparency practices, make informed transparency choices (including on confidentiality), and explain absence of disclosure where appropriate.
- Support better public understanding of central bank mandate, governance, policies, operations, outcomes, and official relations; reduce uncertainty and facilitate public dialogue.
- CBT Review is anchored on a range of practices designed to be relevant across diverse legal frameworks, governance arrangements, and levels of economic and financial development.
- Practices are not intended for transparency ranking; the Review does not involve compliance ratings.

### Scope and Coverage of the Reviews
- Reviews use the CBT’s 5-pillar framework covering central bank governance, policies, operations, outcome, and official relations.
  - Pillar I. Transparency in governance, covering institutional issues.
  - Pillar II. Transparency in policies, focusing on the economics of the central bank policy decisions.
  - Pillar III. Transparency in operations, highlighting how policy decisions are implemented.
  - Pillar IV. Transparency in outcome, focusing on how outcomes are reported to stakeholders to facilitate accountability.
  - Pillar V. Transparency in official relations, covering central bank interaction with the government and other domestic agencies, and international relations and commitments.
- Each Review must clearly state and explain scope (Pillars) and coverage (components within Pillars), agreed with the central bank ahead of the mission and explained in the context of legal mandate, structure, organization, and other contextual issues.

### Considerations in Reviewing Implementation of the CBT Principles
- Transparency Review vs governance soundness:
  - CBT does not prescribe a governance framework; Pillar I focuses on transparency of governance arrangements without prescribing what governance should be.
  - CBT can inform governance discussions but does not pass judgment on institutional arrangements.
- Transparency Review vs policy soundness:
  - CBT does not pass judgment on policy frameworks or actions; Pillars II, III, and IV assess transparency of policies and actions, not their appropriateness.
  - Reviews focus on whether common policies, instruments, and practices are transparently disclosed when applicable.
- CBT structure:
  - Includes high-level Principles and Practices; Part A lists Principles (with sub-principles), Part B repeats Principles and adds Practices.
  - Practices divided into three categories: “Core,” “Expanded,” and “Comprehensive.”
  - In a few cases the distinction among categories is limited or nonexistent (examples cited in the Note).
- Evaluation approach:
  - Reviews evaluate central bank transparency practices against CBT Principles, taking country-specific circumstances into account.
  - Reviews should provide justifications and propose action plans for improvements.
  - When a practice spans multiple Principles, the Review should map main focus and recommend consolidation where appropriate.
- Public disclosure:
  - Public disclosure is central to transparency and includes publication in official gazettes, central bank websites, printed/electronic mass media, and other means; accessibility is required.
  - “Public” encompasses all interested individuals and entities, domestic or international, including central bank staff, legislature, government, financial supervisors, financial institutions, market parties, consumers, deposit holders, and investors (subject to country circumstances).
- Dimensions of transparency:
  - Means of disclosure: central bank website; official gazette; circulares; electronic messages via reporting channels; publications, interviews, speeches, articles in media; other electronic communication such as social media.
  - Timeliness: disclosures must be timely relative to recipients’ information needs; timeliness depends on objective (e.g., informing about forthcoming or recent policy decisions).
  - Periodicity: disclosures may be one-off or periodic; e.g., monetary policy decisions disclosed at regular intervals; legal or organizational changes disclosed less frequently.
  - Quality (accessibility and ease of understanding): information often needs translation into accessible language; consider multiple languages and website navigability; information should be findable with little effort.
- Transparency overlap with other standards:
  - CBT Review should not include review of micro-prudential supervision, resolution, and financial market infrastructure functions where established international standards exist.
  - Reviews of compliance with other standards are conducted under FSAP and stand-alone assessments; CBT Reviews should reference published ROSCs, DARs, and TNs where applicable.
- “Not Applicable” and “Not Implemented”:
  - “Not applicable” can be indicated where Principles/Sub-Principles/Practices do not apply to a central bank’s situation or where the central bank chooses not to be assessed in an area; reasons should be recorded.
  - “Not implemented” should be assigned where a Principle/Sub-Principle is within scope but not implemented or falls short of the “Core” practice description.

### Conducting the CBT Review
- Review Template components (Appendix I):
  - Table 1: For every relevant Principle/Sub-Principle, include description of practices, qualitative review (categorize as “Core,” “Expanded,” or “Comprehensive”), and additional comments.
  - Table 2: Summary of the Review listing which practices fall under “Core,” “Expanded,” “Comprehensive,” “not implemented,” or “not applicable.”
  - Table 3: “Recommended Action Plan” listing suggested steps to enhance transparency for practices with specific recommendations.
- Inclusion of official responses:
  - Template should allow authorities to include an official response to the Review; for self-Reviews this can capture central bank comments not otherwise addressed.
- Summary Review elements:
  - Clarify scope of the Review and evaluate transparency from multiple perspectives.
  - Provide background on country and institutional context, organization assessed, and country-specific circumstances.
  - Note main information sources (laws, regulations, websites); discuss the review process and use of any self-Review.
- Main findings (summary):
  - Provide overall evaluation of quality of transparency practices against CBT Principles.
  - Identify strengths and main areas of concern impacting transparency.
  - Note major transparency reforms implemented or scheduled; indicate recent improvements and motivating factors.
  - For practices needing improvement, explain main reasons for shortfalls, whether efforts exist to address them, expected timeframe, and extent of progress if efforts proceed as envisaged.
- Recommended actions:
  - For each Principle listed in the recommended actions table, note relevant practice and suggested action(s).
  - Recommendations should focus on improving transparency, not introducing governance or policy framework changes.
- Review consistency and expected reviewer conduct:
  - Follow consistent approach based on Section III (“Considerations in Reviewing the Practices of the Code”).
  - Cite or paraphrase relevant sections of laws, regulations, circulars, press releases, or other public disclosure instruments used in the assessment for each Principle.
  - Note where and how information is disclosed.
  - Evaluate and map practices to the applicable practice level.
  - Explain outcomes of analysis, particularly when practices cut across more than one transparency practice category.

### Appendix I — Guidance and Templates for Writing the CBT Review Report (key instructions)
- General: provide background on the Review, describe organization assessed, context, and reviewer particulars.
- Information used: detail main information sources (laws, regulations, reports, public statements, websites, unpublished guidelines, directives, and reviews); list counterparties, meetings, and other authorities consulted.
- Describe factors facilitating or impairing the Review, including non-cooperation and potential effects on objectivity.
- Principle-by-principle review format:
  - Avoid rating terminology (e.g., “observed,” “partially observed”).
  - Match reviews to applicable Practice category when criteria are generally met without significant deficiencies.
  - If practices cover elements of more than one category, indicate where the weight of practice lies and highlight other elements.
  - A principle/sub-principle is “not applicable” if it does not apply given structural, legal, or institutional features or if the central bank chose not to be assessed; reasons must be noted.
  - Note instances where a country demonstrates a principle-based practice via different disclosure means.
  - Elaborate on ongoing efforts to enhance transparency and state expected situation when efforts are completed; reviewers may state conditional compliance (“Practice x will meet the CBT principle under CBT practice category [X] when…”) and explain importance of exceptions.
- Each principle review should have three parts in Table 1:
  - A. Description — information on how the Principle is practiced; cite laws, regulations, reports; omit if not applicable.
  - B. Review — qualitative assessment and CBT practice category that applies.
  - C. Comments — contextual elaboration on findings.
- Template structure includes detailed Principle numbering through Pillars I–V (examples include Principle 1.1., Principle 2.1., Principle 3.1., Principle 4.1., Principle 5.1., and numerous sub-principles referenced in the Template).
- Summary tables to be produced:
  - Table 2: Central Bank Transparency Practices Overview mapping CBT Practice Category to CBT Principles (columns: Core; Expanded; Comprehensive; Not implemented; Not applicable).
  - Table 3: CBT Recommended Plan of Actions listing Reference Practice and Recommended Action for specific practices where recommendations are made.

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