## REVIEW OF TRANSPARENCY POLICY AND OPEN ARCHIVES POLICY (ppea2024057)

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### Executive summary — progress, effectiveness, and reform focus
- Nearly all Board documents are published and on average published more quickly.
- Transparency framework centered on the Transparency and the Open Archives policies is on par with other comparable international financial institutions.
- Policy effective but room for improvement; key implementation issues:
  - Some country papers continue to be published with long delays.
  - Timeliness of communicating the Board’s surveillance activities could be improved.
  - Concerns among some Executive Directors about evenhanded application of modification rules have abated since last review.
  - Developments since last review indicate scope and coverage need extension and safeguards strengthened.
- Reform proposals focus on five areas:
  - (i) reinforcing objectives underlying the policy;
  - (ii) ensuring adequate scope and coverage;
  - (iii) supporting faster communication of Board decisions and document publication;
  - (iv) strengthening rules and processes for modifying Board documents prior to publication (presentation of authorities’ views, removal of confidential information, modification of policy documents);
  - (v) enhancing safeguards under the policy.
- Staff also recommend steps to improve processes and better support effective implementation.

### Design principles and trade-offs
- Three basic objectives:
  - Timely disclosure: presumption of publication for most Board documents; publication of documents that include the Board’s views with regard to member countries requires consent of the concerned member (Article XII, Section 8) and is characterized as “voluntary but presumed.”
  - Safeguarding confidentiality: management and staff may not disclose information provided in confidence unless that party consents.
  - Staff independence and candor: draft reports are not to be shared with member authorities before they are sent to the Board; modifications are permitted only in narrowly defined circumstances.

### Key implementation findings and statistics
- Overall publication share of Board documents in recent years: about 96-98 percent.
- Publication rates:
  - Policy documents during 2014-22 averaged 97 percent (compared to 90 percent in 2009-12).
  - Country papers edged up to around 96 percent (compared to 92 percent in 2009–12).
  - Financial System Stability Assessments (FSSAs) increased to 86 percent (from 73 percent before previous review), but remained volatile.
- Footnote/statistical definition: A Board document is identified as published if it has been released to the public within six months from the end of the calendar year in which the document was considered by the Executive Board.
- Since 2014, 65 country papers (out of more than 1,600) were not published.
  - These 65 unpublished papers were equally divided between EMs and LICs.
  - 11 countries accounted for 63 percent (41 reports) of all unpublished country papers; five countries accounted for about 42 percent (27 reports).
  - About 78 percent of these country reports either did not have any modification requests or all modification requests were approved.
- Timeliness:
  - During 2014-2022, country papers were on average published 16 days after Board consideration, down from 33 days in 2009-12.
  - On average about 70 percent of country papers have been published “promptly” (i.e., within 14 days), up from 45 percent at last review.
  - Since the last review, on average 33 percent of country papers took more than 14 days to be published.
  - 12 percent of papers were published more than 28 days after Board consideration; 22 countries—mainly EMs—accounted for half of these documents.
- Publication lags for policy papers:
  - Since last review, 61 percent of policy papers were published promptly, down from 68 percent in 2009-12.
  - Average publication lags for policy papers increased to 26 days (from 20 days in 2009-12).
  - About seven percent of policy papers had publication lags exceeding 90 days.
- Press releases and Board views communication:
  - Over 2019–2022 about 91 percent of press releases for UFR country documents were published the same day of Board consideration.
  - Article IV consultation press releases: on average issued about 10 days after Board consideration; only two percent were published the same day; publication share rises to about 30 percent by the three-day point.
  - For policy papers during 2019–2022 about 92 percent of press releases were issued at the time of publication of the corresponding policy paper; on average issued 26 days after Board consideration.

### Causes of publication delays and procedural issues
- Long delays often associated with delays in obtaining publication consent.
  - During 2018-22, about 90 percent of country papers with publication delays exceeding 28 days had no pending or submitted modification requests at the 28-day mark.
  - Overall, about 83 percent of country papers not published promptly (after 14 days) had no modification requests submitted or pending after the 14-day mark.
- Ambiguity on when consent may be deemed provided under the non-objection modality has led staff to seek explicit consent before publishing, allowing indefinite delays if members request more time or opt out of non-objection modality.
- Capacity issues not identified as primary constraint; delays concentrated in a very limited number of small developing countries and LICs and generally one-off events.

### Modifications of Board documents — deletions and corrections
- Submission patterns and approvals:
  - Estimated 18 percent of all modification requests were made after the Board’s consideration.
  - In 2014-22, about 12 percent of published country papers had some deletions (compared to around 21 percent during 2009–2012).
  - During 2014-22, on average about 64 percent of deletion requests to country papers were approved.
  - About three quarters of approved deletions for country papers were for market sensitivity concerns.
  - During 2014-22, an estimated 75 percent of published country papers had corrections (compared to 65 percent in 2009-12).
  - Detailed 2018-22 data: correction requests aimed largely to rectify factual errors (52 percent) and evident ambiguities (41 percent); remainder mischaracterization of authorities’ views.
  - Share of papers with corrections by country group (2018-22): AEs: 88 percent; EMs: 71 percent; LICs: 37 percent.
  - Around 87 percent of correction requests were on average approved over 2014-2022.
- Evenhandedness evidence:
  - 96 percent of authorities believe modification rules are applied evenhandedly.
  - 37 percent of Executive Directors perceive the policy is not applied evenhandedly (improved from 50 percent in 2013).
  - Case sample assessment found only 1 percent of corrections and 5 percent of deletion requests that could have been reassessed differently; no convincing evidence of bias.
  - During 2014-22 about 74 percent of countries had approval rate of correction requests above 80 percent; more than 90 percent of countries had approval rate above 70 percent.
  - Average approval rates across income groups varied little for corrections (86-88 percent) and for deletions (62-65 percent).

### Coverage, scope issues, and recent developments
- Need to update the indicative list of Board documents covered by the policy to include new types and remove categories no longer produced.
- Enterprise Risk Assessments (ERAs):
  - ERAs incorporated into Board documents follow Transparency Policy rules for that document.
  - Stand-alone ERA reports have been treated as not presumed to be published; proposal is to continue exempting stand-alone ERA documents from the presumption of publication and include them in a new negative list (TP).
- MAC SRDSF exemptions:
  - 2022 introduced mandatory targeted deletions to remove certain outputs of the Debt Sustainability Framework for Market Access Countries (MAC SRDSF) before publication; intended temporary and to be reviewed.
  - As of May 2024, about 150 assessments published using the SRDSF provide initial sample; available data do not show signs that the information currently deleted is market sensitive.
- Documents received from other institutions:
  - Such documents are not Fund documents and are not covered by the Transparency Policy; staff propose publishing them together with the related staff report if no objection from the authoring institution (TP).
- Published documents:
  - Policy is silent on modifications of published Board documents; a few cases required post-publication changes relying on general principles.

### Deletion of confidential information and administrative errors
- Under legal framework, management, staff, and the Executive Board cannot disclose information provided in confidence without consent.
- Deletion rules effective but rare instances required deletion under general principle of safeguarding confidentiality; proposal to incorporate removal of such confidential information into the Transparency Policy (TP).
- Administrative errors procedure (introduced 2014) expanded to address cases where documents issued to the Board do not correspond to management-approved version or key components are incorrect or missing.
  - Proposal to formalize and limit administrative errors scope under the Transparency Policy and require Board be provided with minimum two working days to consider revised document (TP).

### Proposed clarifications and timelines (selected staff proposals)
- Clarify preamble to explicitly include objective of preserving independence and candor of staff analysis and that modifications are permitted only under limited circumstances (TP).
- Update indicative list of Board documents covered; add a negative list of documents not presumed to be published (TP).
- Press releases and Board views:
  - Establish a publication path for press releases for surveillance country documents separate from related staff report and include member’s publication intentions in press release (TP).
  - Timing expectations:
    - Surveillance country document press releases expected to be published shortly after Board consideration, i.e., within two business days.
    - If member has consented to publication of related staff report by end of Board consideration, member can ask for press release on an “extended time schedule,” within seven calendar days.
    - If press release not issued within two business days (or seven calendar days if extended), a brief factual statement will be issued informing the public the Fund concluded consideration and indicating member’s publication intentions (TP).
  - Consent modalities: clarify non-objection basis and when consent is deemed provided (TP).
  - Allow broader revisions to background section of press releases (TP).
- Reduce delays in publishing country staff reports and clarify non-objection timelines (TP):
  - If member requests more time or conditions consent on deletions, member expected to communicate decision within fourteen calendar days from Board consideration; consent deemed provided at that point unless explicit objection.
  - If no objection within twenty-eight calendar days from Board consideration, consent deemed provided and Fund will promptly publish following resolution of pending modification requests (TP).
  - Opt-outs: member who opted out expected to communicate decision no later than fourteen calendar days (twenty-eight if pending modification requests fourteen days after Board consideration); factual statements issued if no decision.
- Clarify and strengthen modification rules:
  - Allow limited additions to authorities’ views in surveillance staff reports where omissions exist, subject to safeguards: parsimonious additions, based on information available at time of consultations, anchored in indicative word count limit, and issued to Board two days before consideration (TP).
  - Incorporate deletion of confidential information into policy (TP).
  - Incorporate administrative errors procedure into policy with narrow scope and minimum Board review time (TP).
  - Align timing for submission of correction requests to normally no later than seven calendar days after Board consideration (or 21 days after issuance), with limited post-Board corrections allowed only where failure to correct would undermine overall value of publication (TP).
  - Clarify rules to modify policy documents prior to and after Board consideration; revised papers accompanied by articulation of changes; published policy papers to indicate which staff proposals Board did not endorse.
- Widen dispute procedures:
  - Extend existing dispute processes for serious disagreements between management and a member on deletions to include disputes on application of any modification rule (TP).
  - Extend dispute procedures for disagreements between staff and authorities to any disputes involving modification rules.
- Implementation and process improvements:
  - Monitor time to assess modification requests; ensure initial assessment within 36 hours of submission.
  - Explore IT solutions (Common Review System) to streamline submissions, link repeated requests, and provide access to justifications for rejections.
  - Update staff guidance, create a short "How To" note, offer periodic training, and require country teams to report number of modification requests received from authorities.

### Open Archives Policy (OAP) — scope, usage, and targeted improvements
- OAP governs archived permanent records using graded 3/5/20-year lapse-of-time (LOT) rules.
- Recent usage:
  - Average of about 9,000 views of the Fund’s archive website.
  - Between FY2021 and FY2024 requests to access archival records increased more than sixfold, amounting to more than 540,000 pages in the most recent fiscal year.
  - No backlog of records requests after pandemic-related delays.
- Cataloging and digitization:
  - Since 2018, automated workflows have accelerated release of Board documents and records to the archive catalog; all documents under the OAP’s 3/5-year rules are available in the catalog and accessible in digital form.
- Implementation challenges and risks:
  - OAP time rules can delay archive availability of documents already on Fund website, potentially confusing researchers.
  - Backlog of unprocessed paper records and many paper records not yet digitized.
  - Lack of official staff guidance note on OAP and need for stronger interdepartmental coordination.
  - Growing volume of born-digital records reaching end of 20-year rule requires digital preservation processes and infrastructure.
- Staff judgment and targeted reforms:
  - OAP broadly adequate and compares favorably with other IOs.
  - Targeted improvements: reassess time rules where appropriate; strengthen accessibility (prioritize processing and digitization); build digital preservation infrastructure; issue OAP staff guidance note; establish interdepartmental coordination mechanism.
  - On transcripts of informal Board meetings: staff suggest no change to 20-year rule.

### Archive accessibility proposals
- Clarify that Board documents that have been published should be part of the archived permanent records and made available under the archive catalog upon publication.
- Allow the Managing Director, in exceptional circumstances, to grant access to other documentary material before the 20-year rule expires where in the interest of the Fund.
- Proposed actions:
  - Identify additional ad hoc resources to clear backlog of unprocessed paper records.
  - Issue an OAP staff guidance note and strengthen coordination mechanisms.
  - Update processes and acquire infrastructure for enterprise-wide digital preservation.

### Resource, risk, and transitional considerations
- Estimated gross additional staff resources for some reforms: about 0.5 full time equivalent (FTE).
- Additional capital and transitional staff resources needed to address analog backlog, acquire digital preservation infrastructure, and automate early release in archive catalog.
- Medium-term net impact on staff resources likely neutral if:
  - (i) savings from proposed actions reach about 15 percent of current Transparency Policy implementation resources, and
  - (ii) improvements in publication of staff reports applied only to Article IV staff reports.
- Each five percent of savings not delivered would require 0.15 FTEs in additional resources.
- Major risks:
  - Reputational: lengthy delays in publication, perceived lack of evenhandedness.
  - Operational: human errors, multiple public versions, capacity to capture born-digital records.
- Mitigations include safeguards on authorities’ views additions, streamlined modification processes, enhanced outreach/training, expanded dispute procedures, clear post-publication modification principles, and investment in digitization and digital preservation infrastructure.
- Transitional timing proposals:
  - New policy effective two months following adoption by Board, except some provisions with different timing.
  - Implementation of modifications of published documents, removal of confidential information, and administrative errors procedures to start immediately.
  - Implementation of modifications to authorities’ views and surveillance press release background sections to start three months after adoption.
  - Proposals on correction criteria, dispute process, and modifying policy documents to take effect six months after adoption.
  - OAP changes effective two months after adoption.

### Appendix highlights — coverage and negative list
- Transparency Policy covers Country Documents, Fund Policy Documents and Multi-Country Documents; lists indicative categories.
- Indicative negative list (not presumed to be published) includes:
  - Internal Fund Administrative Documents.
  - Documents prepared for informal Board briefings for countries with excessively delayed Article IV consultations or mandatory financial stability assessments.
  - Staff Notes on preliminary evaluation of high and/or exceptional access.
  - Overdue Financial Obligations Documents.
  - Stand-alone Enterprise Risk Assessments (ERA).
- Archives access timing thresholds:
  - Executive Board documents: over 3 years (exceptions apply).
  - Minutes on use of Fund resources and certain documents: over 5 years.
  - Other documentary materials: over 20 years.
  - Managing Director consent required to declassify “Secret” or “Strictly Confidential” items in some cases.

*Source: ppea2024057 — REVIEW OF TRANSPARENCY POLICY AND OPEN ARCHIVES POLICY (selected extracts).*

### EXECUTIVE SUMMARY

### EXECUTIVE SUMMARY

### Progress on transparency
- The Fund has made significant progress towards greater transparency over the past decade.
- Nearly all Board documents are published and are on average published more quickly.
- The information available in the Fund’s archives has significantly increased and is more easily accessible to the public.
- The Fund’s transparency framework, centered around the Transparency and the Open Archives policies, continues to be on par with other comparable international financial institutions.

### Effectiveness of the Transparency Policy and implementation experience
- Experience suggests the Transparency Policy is effective but there is room for improvement.
- The policy’s principles and objectives are largely shared by the membership, and the policy’s rules-based approach has proven effective in delivering consistent implementation.
- Implementation issues identified:
  - Some country papers continue to be published with long delays.
  - Timeliness of communicating the Board’s surveillance activities could be improved.
  - Concerns remain among some Executive Directors about evenhanded application of the modification rules under the policy, though these concerns have abated since the last review.
  - Developments since the last review indicate the scope and coverage of the policy need to be extended and its safeguards strengthened.

### Proposed reforms to the Transparency Policy
- Reform proposals focus on five areas:
  - (i) reinforcing the objectives underlying the policy;
  - (ii) ensuring the adequate scope and coverage of the policy;
  - (iii) supporting faster communication of the Board’s decisions and document publication;
  - (iv) strengthening the rules and processes for modifying Board documents prior to publication, including the presentation of authorities’ views, removal of confidential information and modification of policy documents; and
  - (v) enhancing safeguards under the policy.
- In addition, staff recommend steps to improve processes and better support the effective implementation of the policy.

### Open Archives Policy (OAP)
- The Open Archives Policy remains broadly adequate and its design compares favorably to other international organizations.
- Implementation has allowed an increasing number of Fund documents to be available to the public through the archives catalog.
- Adjustments and additional investment are needed to:
  - support quicker release of some documents;
  - adapt archival records to the modern digital environment; and
  - manage implementation risks with adequate oversight.

### Context, objectives, and scope of the review
- The last review of the Transparency Policy and Open Archives Policy took place in 2013.
- Since then, the operating environment has evolved with:
  - heightened pressures to share more information and analysis, and to share it more quickly;
  - faster information diffusion through media channels; and
  - the Fund’s own evolutions reflected in the 2021 Comprehensive Surveillance Review (CSR) and the 2022 Institutional Safeguards Review (ISR).
- The review has three objectives:
  - a. Review the principles and objectives underlying the Transparency Policy and the Open Archives Policy to assess their continued appropriateness.
  - b. Assess the effectiveness of the Transparency Policy in supporting transparency and the prompt publication of Board documents, views, and decisions in the current shock-prone and fast-moving policy and media environment.
  - c. Identify challenges and propose reforms to improve the design and implementation of the Transparency Policy, including the rules to modify Board documents, and of the Open Archives Policy.

### Design principles and trade-offs in the Transparency Policy
- The policy is structured around three basic objectives:
  - Timely disclosure. The policy establishes a presumption of publication for most Board documents (with only limited exceptions) and defines rules and expectations for prompt publication and related press releases. In line with the IMF’s Articles of Agreement (Article XII, Section 8), publication of documents that include the Board’s views with regard to member countries requires consent from the concerned member, and publication is therefore voluntary but presumed, and consent is typically obtained on a non-objection basis.
  - Safeguarding confidentiality. The policy explicitly recognizes the Fund’s duty to safeguard confidential information; management and staff may not disclose information provided in confidence unless that party consents.
  - Staff independence and candor. The policy and related staff guidance include rules to modify staff reports presented for Board consideration to protect the integrity and candor of staff’s analysis and ensure staff reports’ text is not negotiated. Draft reports are not to be shared with member authorities before they are sent to the Board; after circulation to the Board, modifications are only permitted in narrowly defined circumstances.

### Structure of the full report (high level)
- Section II reviews principles and objectives underlying the Transparency Policy.
- Section III outlines recent developments in implementation and identifies areas needing improvement, drawing on empirical analysis, stakeholder feedback, and comparisons with other international financial institutions.
- Section IV outlines proposed reforms to the Transparency Policy.
- Section V discusses the Open Archives Policy, including trends, issues, and proposed reforms.
- Section VI considers risk and resource implications, links to the Fund’s communication strategy, and transitional arrangements.

*REVIEW OF TRANSPARENCY POLICY AND OPEN ARCHIVES POLICY, October 1, 2024*

### 13.      The recent Institutional Safeguards Review (ISR) reinforced the objective and the

### 13.      The recent Institutional Safeguards Review (ISR) reinforced the objective and the

### Role and objectives of the Transparency Policy
- Reinforced objective and role: protecting staff independence and candor; protecting confidential information provided to the Fund; maintaining a candid and continuous dialogue with the membership.  
- 2022 ISR reaffirmed: importance of protecting independence of staff’s technical analysis and policy advice and avoiding the negotiation of staff reports.  
- ISR stressed Fund’s responsibility to protect any confidential information provided to the Fund.

### Rules-based approach and modification rules
- The Transparency Policy relies on a rules-based approach to:
  - Foster timely disclosure by defining expectations and modalities around publication of Board documents and press releases.
  - Safeguard confidentiality by allowing deletion of specific types of sensitive information that could cause harm to members.
  - Protect staff independence and candor by allowing only limited corrections to ensure factual accuracy and clarity before Board documents are published.
- Modification rules:
  - Reduce scope for discretion, supporting more consistent application of the policy (Background Paper 1).
  - Protect integrity of Board deliberations by limiting re-opening of negotiations on content after a document has been issued to the Board.
  - Are tighter for modifications made after the Board’s consideration has concluded.
- Scope exclusions:
  - Not designed as a final quality control mechanism for content or presentation of Board documents.
  - Content and presentational issues are to be addressed through the Fund’s internal document review process and other policies and guidance (e.g., 2012 Integrated Surveillance Decision, UFR-related Board policy decisions, staff guidance notes).
  - Editorial choices on content of staff reports fall outside the Transparency Policy and its post-Board modification rules.

### Politically sensitive material and judgment limits
- Policy is explicit: material seen as politically sensitive shall not be deleted unless it meets one of the policy’s modification criteria.
- Staff are required to discuss economic, social, and political developments relevant for staff’s advice; guidance exists on presenting such developments (e.g., 2022 Guidance Note for Surveillance Under Article IV Consultations).
- Modifications on grounds of political sensitivity are not allowed, even if sensitivity appears to arise from drafting rather than substance, because assessing such modifications would be highly subjective and hard to implement in a rules-based manner.
- Expanding scope for judgment in modifications risks:
  - Uneven application of the policy.
  - Concerns over implementation.
  - Opening the door to negotiations on drafting before publication.

### Key features of the Transparency Policy (Box 1 highlights)
- Coverage: Documents prepared for Board consideration (including informal sessions) or information: country documents, Fund policy documents, multi-country documents; press releases conveying Board views on country and policy matters.
- Publication principles:
  - In line with Article XII, Section 8 of the IMF’s Articles of Agreement, publication of country documents is subject to consent of the member concerned, under the policy characterized as “voluntary but presumed.”
  - Consent is normally obtained on a non-objection basis unless the member opts out of such modality.
  - Under the non-objection modality, a document will be published unless, before the conclusion of Board consideration, the member notifies the Fund that it: (a) objects to publication; (b) requires additional time to decide whether to publish; or (c) consents to publication subject to reaching agreement with the Fund on deletions to the document.
  - Practice: members may withdraw consent at any time prior to publication.
- Publication regimes:
  - Country documents: Publication is voluntary but presumed. For UFR staff reports the presumption is stronger because the Managing Director will generally not recommend Board approval of a UFR request unless the member explicitly consents to publication. Publication is expected within 14 days of Board consideration.
  - Policy documents: Publication of documents circulated to the Board for consideration, and related press releases, is presumed (with exceptions for administrative matters and matters pertaining to Fund’s income, financing or budget). Policy documents circulated for information may be published with Board consent on a non-objection basis.
- Modifications of country documents:
  - Corrections limited to: (i) typographical errors; (ii) factual errors; (iii) mischaracterization of authorities’ views; (iv) evident ambiguity.
  - Corrections after Board consideration limited to cases where: (i) corrections were brought to the attention of the Board before the conclusion of the Board meeting, or (ii) failure to make the correction would undermine the overall value of the publication.
  - Corrections normally rectify an error or inaccuracy, rather than add or delete text. Corrections expected to be requested not later than two business days before Board consideration.
  - Deletions limited to: (i) highly market sensitive material (mainly outlook for exchange rates, interest rates, the financial sector, and assessments of sovereign liquidity and solvency); (ii) material not in the public domain on a policy the country authorities intend to implement, where premature disclosure of operational details would seriously undermine implementation. Politically sensitive material shall not be deleted unless it meets either of the two criteria.
  - Deletions may be requested by the authorities normally within seven days of Board discussions or 21 days of document issuance to the Board, whichever is later.
  - Prior to publication, TP also provides for removal of references to unpublished Fund documents, certain internal processes not disclosed to the public, breaches of obligation under Article VIII, Section 5, and de minimis misreporting (Decision No. 13849-(06/108)). Practice includes removing legal texts of members’ arrangements and Fund proposed decisions related to these arrangements.
- Modifications of policy papers:
  - Prior to publication, Managing Director (staff) can make necessary factual corrections, deletions (including country-specific references), and related rephrasing.
  - Staff’s policy proposals may not be modified prior to publication unless staff has modified its views in light of a Board discussion or following a significant new development.
  - In cases of differences between staff’s proposals and the Board’s conclusions, published staff reports will clearly indicate which proposals the Board did not endorse.

### Comparisons with other IFIs
- Rules governing Board documents and information sharing are broadly on par with other comparable international financial institutions (IFIs) (Appendix II).
- IMF strengths relative to other IFIs:
  - Stronger presumption of publication for Board documents than other IFIs (though some IFIs provide a right to request information).
  - Less restrictive modification rules (with the exception of one institution).
- Unique IMF features:
  - The IMF is the only IFI whose legal framework requires consent from the relevant member for publication of country documents.
  - Board documents are not made publicly available before the Board discussion.
- Outreach: most CSOs share the view that the Fund’s practices compare favorably to those of other IFIs (Background Paper 2).

### Ten years of experience: progress and remaining challenges
- Progress since early nineties and 2013 reforms: nearly all Board documents are now published and on average published more quickly; application of modification rules is monitored through annual publicly available reports (see Key Trends in the Implementation of Fund’s Transparency Policy).
- Remaining concerns: prompt publication of Board documents and some press releases; implementation of rules to modify Board documents; coverage of the policy.

### Publication rates and lags (findings and statistics)
- Overall publication share of Board documents in recent years: about 96-98 percent.
- Publication rates for policy documents during 2014-22 averaged 97 percent, compared to 90 percent in 2009-12.
- Publication rates for country papers edged up to around 96 percent, compared to 92 percent in 2009–12.
- Publication rates for Financial System Stability Assessments (FSSAs) increased to 86 percent, from 73 percent before the previous review, but remained volatile.
- Footnote/statistical definition: A Board document is identified as published if it has been released to the public within six months from the end of the calendar year in which the document was considered by the Executive Board. Only a handful of documents are published more than 6 months after Board consideration.
- Since 2014, 65 country papers (out of more than 1,600) were not published.
  - These 65 unpublished papers were equally divided between EMs and LICs.
  - 11 countries accounted for 63 percent (41 reports) of all unpublished country papers; five countries accounted for about 42 percent (27 reports).
  - About 78 percent of these country reports either did not have any modification requests or all modification requests were approved.
- Timeliness:
  - During 2014-2022, country papers were on average published 16 days after Board consideration, down from 33 days in 2009-12.
  - In recent years, on average about 70 percent of country papers have been published “promptly” (i.e., within 14 days), up from 45 percent at the time of last review.
  - Since the last review, on average 33 percent of country papers took more than 14 days to be published.
  - 12 percent of papers were published more than 28 days after Board consideration; 22 countries—mainly EMs—accounted for half of the documents in this latter category.
- Definition note: The Transparency Policy Decision defines “prompt publication” as within 14 days of Board consideration (or within 28 days of issuance of a document to the Board, whichever is later).

### Causes of publication delays and procedural issues
- Long delays often associated with delays in obtaining publication consent.
  - During 2018-22, about 90 percent of country papers with publication delays exceeding 28 days from Board consideration had no pending or submitted modification requests at the 28-day mark.
  - Similar result for publication delays between 14 and 28 days.
  - Overall, about 83 percent of country papers not published promptly (after 14 days) had no modification requests submitted or pending after the 14-day mark.
- Interpretation: delays in obtaining publication consent, for reasons other than pending modifications, have been the most likely cause for publication delays.
- Capacity issues:
  - Evidence suggests capacity issues are not the primary constraint; delayed publication involved a very limited number of small developing countries and other LICs, and delays were generally one-off events associated with specific reports.
- Policy and practice shortcomings contributing to delays:
  - Under the policy, publication consent for country documents is expected to be obtained on a “non-objection” basis.
  - Ambiguity in policy about at what point staff can deem consent to have been provided has led staff to be hesitant to proceed with publication when there is no notification prior to the conclusion of Board consideration, seeking explicit publication consent instead.
  - If a member indicates they need more time or to agree on deletions, explicit publication consent is required and there is no firm timeline under the policy within which consent must be provided or can be presumed, allowing for indefinitely long delays.
  - If the member has opted out of the non-objection modality, explicit consent is required and there is no timeline within which a member needs to make a decision.

*Source: ppea2024057 - 13.      The recent Institutional Safeguards Review (ISR) reinforced the objective and the*

### 27.      Contrary to country papers, average publication lags for policy papers have lately

### 27.      Contrary to country papers, average publication lags for policy papers have lately

### Publication lags for policy papers
- Since the last review, 61 percent of policy papers were published promptly, down from 68 percent in 2009-12.
- Average publication lags for policy papers increased to 26 days (from 20 days in 2009-12).
- Trends reflect presence of a small number of papers (about seven percent) with publication lags exceeding 90 days, including complex papers requiring longer publication processes.

### Communication of Board views: press releases
- Over 2019–2022 about 91 percent of press releases for UFR country documents were published the same day of Board consideration.
- Press releases for Article IV consultations:
  - On average issued about 10 days after Board consideration.
  - Only two percent were published on the same day.
  - Publication share rises to about 30 percent by the three-day point.
- For policy papers during 2019–2022:
  - About 92 percent of press releases were issued at the time of the publication of the corresponding policy paper.
  - On average issued 26 days after Board consideration.
- Longer delays for Article IV press releases reflect:
  - Rules expecting Article IV press releases to be published alongside the staff report; if member consent for the staff report is provided but the report is not expected to be published within seven calendar days of Board consideration, the press release is expected to be issued shortly after Board consideration.
  - Members often do not communicate publication intentions by the end of Board consideration, making the rules difficult to apply in practice.
  - Over recent years, 71 percent of Article IV press releases were issued together with the staff report; about half of these reports and related press releases were published more than seven days after Board consideration, often with longer delays for small developing states.
  - For country document press releases, explicit consent by the ED for the member is required if no consent for the staff report has been provided, which can cause delays.
  - Rules for modifying the introductory section of Article IV press releases follow the same strict categories as Board country documents (unlike UFR press releases), which can contribute to delay.

### Modifications of Board documents: policy intent and rules
- Policy includes:
  - Deletion rules to protect members from disclosure of sensitive information and to help ensure candor.
  - Correction rules to preserve integrity and independence of staff analysis and ensure accuracy without enabling negotiation of staff views.

### Submission of deletion and correction requests
- Estimated 18 percent of all modification requests were made after the Board’s consideration.
- Modification requests originate both from country teams and from authorities to country teams.
- Survey: about 70 percent of mission chiefs submit all (or screen few) modification requests received from authorities; remaining mission chiefs screen out requests assessed outside policy scope.
- Analysis relies on deletion and correction requests submitted by country teams for approval.

### Deletions
- In 2014-22, about 12 percent of published country papers had some deletions, compared to around 21 percent during 2009–2012.
- Decline represents a return to pre-GFC deletion levels; decline driven by drop in deletions for financial sector issues (from 12 percent in 2009-12 to five percent in 2014-22).
- During 2014-22, on average about 64 percent of deletion requests to country papers were approved.
- About three quarters of approved deletions for country papers were for market sensitivity concerns; the remainder for premature disclosure of authorities’ policy intentions, both with similar approval rates.
- Over the last few years, only three cases required reliance on general principles and special procedures because confidential information could not be removed under the deletion rules.
- Note: data for 2020-21 excluded from some analyses because of very low number of deletion requests in those years (8 in 2020, 28 in 2021).

### Corrections
- During 2014-22, an estimated 75 percent of published country papers had corrections, compared to 65 percent in 2009-12.
- Detailed 2018-22 data: correction requests aimed largely to rectify factual errors (52 percent of total requests) and evident ambiguities (41 percent); remainder covered mischaracterization of authorities’ views.
- Share of papers with corrections by country group (2018-22):
  - AEs: 88 percent
  - EMs: 71 percent
  - LICs: 37 percent
- Around 87 percent of correction requests were on average approved over 2014-2022.
- Approval rates are quite stable over time and similarly high across categories, particularly for factual corrections.

### Evenhandedness
- Stakeholder perceptions:
  - 96 percent of authorities believe modification rules are applied evenhandedly across countries.
  - 37 percent of Executive Directors perceive the policy is not applied evenhandedly (improved from 50 percent in 2013).
- Case sample assessment (about 20 percent of modification requests for evident ambiguity and deletions over 2019, 2021, and 2022):
  - Found only 1 percent of corrections (four cases) and 5 percent of deletion requests (two cases) that could have been reassessed differently.
  - These six cases covered six different countries (all EMs and LICs) and do not show convincing evidence of bias.
- Statistical evidence:
  - For country papers, most countries had high approval rates for correction requests:
    - During 2014-22, about 74 percent of countries had approval rate of correction requests above 80 percent.
    - More than 90 percent of countries had approval rate above 70 percent.
  - Average approval rates across income groups varied little for corrections (ranging from 86-88 percent) and for deletions (62-65 percent).
  - No evidence that largest economies benefited in application of the policy; approval rates for deletions and corrections for non-G-7 and non-G-20 countries similar on average to those for G-7 and G-20 countries.
  - Approval rates for correction requests varied little across regions. Larger variation in deletion approvals across regions, but small numbers limit significance.

### Coverage and scope of the policy and recent developments
- Need to update indicative list of Board documents covered by the policy to include new types introduced since last review and remove categories no longer produced.
- Enterprise risk-related issues:
  - Fund adopted Enterprise Risk Management policy and staff piloted enterprise risk assessments (ERAs) for country, policy, strategy, and administrative documents.
  - ERAs incorporated into Board documents are subject to the Transparency Policy rules that apply to that document.
  - Stand-alone ERA reports, containing more detailed and sensitive information, have been considered not presumed to be published.
  - Transparency Policy will need clarification on handling ERAs going forward.
- SRDSF exemptions:
  - In 2022, mandatory targeted deletions to country documents were introduced to remove certain outputs of the Debt Sustainability Framework for Market Access Countries (MAC SRDSF) before publication.
  - These deletion rules deviate from the policy’s standard deletion rules, introduce costs to consistency and comprehensiveness, generate reputational risk, and are costly to administer.
  - Intended to be temporary and reviewed after a period of implementation.
  - As of May 2024, about 150 assessments published using the SRDSF provide an initial sample; available data do not show signs that the information currently deleted is market sensitive, but more experience would be beneficial.
- Documents received from other institutions:
  - Need for clarity on application of Transparency Policy to documents received from other institutions required for Board consideration (e.g., RSF arrangements and World Bank assessment letters).
- Published documents:
  - Policy explicitly provides rules to modify Board documents prior to publication but is silent on modifications of published Board documents.
  - A few cases required post-publication changes, made relying on general principles of the Transparency Policy and risk assessment.

*IMF — Review of Transparency Policy and Open Archives Policy (selected extracts).*

### 43.      Experience suggests the need for the Transparency Policy to provide

### 43.      Experience suggests the need for the Transparency Policy to provide

### Deletion of confidential information
- Under the Fund’s legal framework for the protection of confidential information, management, staff, and the Executive Board cannot disclose information that a member or other person has provided in confidence without their consent (Background Paper 3).
- Such information should be removed from Board documents prior to their publication.
- The Transparency Policy’s deletion rules have been effective in removing confidential information from Board documents, but there have been rare instances in which the deletion of confidential information was not covered by such rules and confidential information had to be deleted upon management approval based on the general principle of safeguarding confidentiality.
- Consideration should be given to incorporating under the Transparency Policy the removal of such information from Board documents.
- Note on MAC SRDSF: These rules require the deletion of specific elements of the MAC SRDSF in certain circumstances and include the deletion of: (i) the near-term risk assessment; (ii) the qualification ”with high probability” or “but not with high probability” when debt is assessed to be sustainable unless such qualification is required for use of Fund resources; and (iii) the mechanical signal on debt sustainability.

### Administrative errors procedure
- The 2014 staff guidance note introduced an administrative errors procedure to provide a transparent process to address cases in which the document sent to the Board does not correspond to the version that had been approved by management.
- The procedure has expanded to address cases where key components of Board documents, necessary for Board consideration, are either incorrect or missing.
- The procedure is designed to ensure that Board consideration is based on the correct information, addressing situations that could present reputational and operational risks for the Fund.
- Although the use of this procedure remains infrequent, the cases in which documents have been modified to address administrative errors have increased in recent years (Administrative Errors Issued to the Board, 2014-2023 (Number of cases); Source: IMF staff calculations).
- Proposal: Consideration should be given to clarifying the exact scope of the procedure and to formalizing it under the Transparency Policy.

### Modification of policy documents prior to Board consideration
- The Transparency Policy Decision allows Management to make necessary factual corrections, deletions, and related rephrasing to policy documents (including for highly sensitive material and country specific references) prior to publication.
- The decision also provides that staff’s proposals cannot be modified prior to publication (without specifying whether this restriction applies before or after Board consideration).
- Circumstances exist in which management may need to make changes to the analysis and/or policy proposals ahead of Board consideration to better support the Board’s decision-making process.
  - Staff can issue supplements to the original policy document, but in exceptional cases where changes to the original paper—including amendments to the original proposals—are extensive, a supplement may not be adequate.
  - Management may see a need to adjust its policy proposal in light of the Board discussion.
- The modalities for making such changes need to be more clearly articulated and the process transparently reported to the public.
- Currently, this process is only envisaged in circumstances where there is a difference between management’s final proposal and the Board’s decision.

### Feedback from stakeholders
- Stakeholders view the policy’s objectives as generally appropriate and largely achieved in practice (Background Paper 2).
- A large majority of IMF EDs agree that the Transparency Policy should balance timely disclosure with protecting confidential information and the candor and independence of staff’s analysis.
- Most EDs, authorities, IMF mission chiefs (MCs) and CSOs agree that, in practice, the current policy rules adequately protect confidential information and the candor and independence of staff reports.
- About 40 percent of EDs believe the policy does not adequately balance these policy objectives, perceiving that the design of the modification rules is tilted towards protecting staff independence.
- Stakeholders generally support a rules-based approach to modifying documents, although some have concerns about the restrictiveness of the current rules and their implementation.
  - A majority of authorities view the existing rules to modify Board documents as appropriately balanced and sufficiently flexible.
  - Some EDs signaled the need for more clarity on how the modification rules are applied.
  - Most EDs would welcome more room to modify documents to reduce potential misinterpretation of information; some signaled the need for more effective dispute-resolution processes over such modifications.
  - MCs recognize potential benefits from broader and more flexible modification rules but most believe this could make it more difficult for staff to resist unreasonable requests, result in negotiations over staff reports, and ultimately in less candor (Background Paper 2).
- Specific disagreements over the presentation of authorities’ views in country reports can be a source of dissatisfaction despite existing rules and guidance.
  - Data show a large percentage of modification requests related to mischaracterization of the authorities’ views are accepted.
  - Surveys suggest stakeholders are generally satisfied with the application of the policy in this area.
  - There have been cases where the authorities’ views section does not include views on some of the main issues and policy recommendations discussed in the staff report; omissions cannot be corrected under the policy’s current rules (Box 1).
  - Authorities can expand upon and update their views in statements attached to staff reports for publication (e.g., the BUFF statement), but there is a general feeling among EDs that these statements have limited visibility with the public.

### Reform options — overall assessment
- The Transparency Policy does not need a major overhaul, but there is room for targeted improvements.
- After years of reforms and implementation experience, the policy is mature in many respects and its objectives remain appropriate and largely shared by membership and staff.
- The rules-based approach has proven broadly effective and compares well to IFI peers; staff’s analysis does not reveal any evenhandedness issues.
- Room exists for targeted improvements to address implementation challenges, stakeholder feedback, and to modernize the policy for faster communications.

### Staff reform proposals (overview)
- Reform proposals focus on five areas:
  - (i) clarifying the objectives of the policy;
  - (ii) ensuring the adequacy of the policy’s coverage and scope;
  - (ii i) supporting faster communication of the Board’s activities and document publication;
  - (iv) strengthening and clarifying the rules and processes for modifying Board documents before publication; and
  - (v) enhancing key safeguards under the policy.
- Proposals that require amending the Transparency Policy decision are marked with (TP).

### A. Clarify the Objectives Underlying the Policy
- The preamble to the Transparency Policy decision could be further strengthened to reflect high-level principles guiding the policy.
- The important role of the Transparency Policy in safeguarding the independence and candor of staff’s analysis is explicitly highlighted in the 2022 ISR but is not recognized in the preamble of the policy.
- Staff proposes reflecting in the preamble the objective of preserving the independence and candor of staff’s analysis; to explicitly recognize that modifications to Board documents may only be permitted under limited circumstances to protect independence and candor.
  - Proposal: Include in the preamble to the Transparency Policy decision that in allowing for modifications to Board documents, the Fund will give due regard to protecting the independence and candor of staff analysis, while recognizing the necessity of modifications under some limited and defined circumstances (TP) (Appendix III).

### B. Ensure Adequate Coverage and Clarify the Scope of the Policy
- Update the Coverage of the Policy
  - The indicative list of Board documents covered by the policy, for which publication is generally presumed, needs to be updated to include categories of Board documents introduced since the last review (and delete categories no longer produced).
  - Consultations with CSOs signaled the need to improve transparency and clarify Board documents that, although covered by the policy, are not presumed to be published.
  - Proposal: Update the indicative list of Board documents covered by the policy to include Board documents introduced, and delete documents no longer produced, since the last review (Appendix I); add to the Transparency Policy decision an indicative list of documents covered by the policy for which there is no presumption of publication (i.e., negative list) (TP).
- Enterprise Risk Assessments (ERAs)
  - The treatment of documents containing ERAs should reflect the content of the ERAs as guided by ERM policies and current practice, not by the Transparency Policy alone.
  - Standalone ERA documents have been used when management judges that detailed information on specific enterprise risk considerations is needed to support the Board but publication could undermine program or policy implementation.
  - Staff propose continuing to exempt standalone ERA documents from the presumption of publication.
  - ERAs incorporated into staff reports should continue to be subject to the Transparency Policy’s normal publication and modification rules.
  - Proposal: Include stand-alone ERA documents in the new negative list of documents covered by the Transparency Policy but not presumed to be published (TP). ERAs presented in country, and policy documents would continue to be subject to the existing rules under the Transparency Policy applicable to the Board document in which they are included.
- MAC SRDSF
  - Staff propose to continue the MAC SRDSF’s special deletions, again on a temporary basis, pending further experience with the application of the SRDSF framework.
- Documents produced by other institutions and required for Board consideration
  - Documents prepared and provided to the Fund by third parties are not Fund documents and are not covered by the Transparency Policy.
  - To preserve transparency regarding the basis of the Board’s decision-making, staff see merit in publishing these documents when the related staff report is published, provided there is no objection to publication from the third party and unless the Board decides against publication on a case-by-case basis.
  - The rules on obtaining a member’s consent to publication would not apply as these are not Fund documents; the policy’s modification rules would not apply as these documents are not prepared by staff.
  - Modifications by the third party prior to Board consideration will be reflected; changes made by the authoring institution after Board consideration would not be reflected in the version published by the Fund.
  - Proposal: Clarify that documents produced by other institutions and required for Board consideration will be published together with the Fund staff report in the version considered by the Board, provided the related staff report is published and there is no objection to publication from the institution providing the documents, and unless the Board decides against publication on a case-by-case basis. Such documents do not require a member’s consent to publication and are not subject to the Transparency Policy’s rules to modify Board documents. Changes made by the authoring institution after Board consideration would not be reflected in the version published by the Fund (TP).
- Expand scope to cover published Board documents
  - The policy does not explicitly cover published Board documents and their modification.
  - Correcting and re-publishing public documents poses transparency and reputational risks (e.g., multiple versions of the same document and reopening published documents already considered by the Board).
  - There are circumstances in which the risks of not correcting published documents are outweighed by the potential damage to the Fund’s reputation and operations (e.g., omissions, accidental publication of elements not intended for publication, missing legally required copyright information).

*REVIEW OF TRANSPARENCY POLICY AND OPEN ARCHIVES POLICY, INTERNATIONAL MONETARY FUND*

### 56.      Therefore, there is a need to clarify the principles and rules to modify Board

### ppea2024057 - 56.      Therefore, there is a need to clarify the principles and rules to modify Board

### Clarify principles and rules to modify published Board documents (paras 56–57)
- General principle: published Board documents should not be modified, with exceptions in narrowly defined circumstances (TP).
- Permitted exceptions to modify published documents:
  - i. The published document does not correspond to the version that was considered by the Board in material ways or does not contain elements considered integral to the publication (TP).
  - ii. The published document, or part of it, poses significant legal, reputational, or operational risks for the Fund (TP).
- Governance of post-publication modifications:
  - Any post-publication modifications will require management approval, with possible delegation to staff.
  - The Board would be notified of such modifications.
  - Guidance will clarify that deletions, corrections and other modifications permitted under the policy prior to publication would not be permitted for published documents.

### Support faster communication of Board views and press release publication (paras 58–61)
- Rationale:
  - Current delays in issuing Article IV press releases are out of step with the fast-paced media environment and reduce public transparency.
  - Publishing press releases separately from staff reports can remove a major source of delay.
- Proposal: Establish a publication path for press releases for surveillance country documents separate from the related staff report, and include in press releases the member’s publication intentions for the related staff report (TP).
  - Timing expectations:
    - All surveillance country document press releases would be expected to be published shortly after Board consideration, i.e., within two business days.
    - If the member has consented (explicitly or on a non-objection basis) to the publication of the related staff report by the end of Board consideration, the member can ask for the press releases to be issued on an “extended time schedule,” i.e., within seven calendar days from Board consideration to allow extra time for the finalization of the staff report. Any press release published separately from the related staff report will indicate the member’s publication intentions for the staff report.
  - If the press release is not issued within two business days (or within seven calendar days if on an “extended time schedule”), a brief factual statement will be issued informing the public that the Fund has concluded consideration and indicating the member’s publication intentions for the staff report (TP).
  - Current provision requiring factual statements to be issued if consent to publication of press releases is not provided within 28 days of Board consideration will be eliminated (TP).
- Consent modalities:
  - Clarify that consent for publication of country document press releases can be obtained on a “non-objection” basis and would be deemed provided unless the member indicates, prior to the conclusion of Board consideration, that it objects to publication or requires additional time to decide. When consent is obtained on a non-objection basis, publication will occur following resolution of any requests to modify the background section of the press release, although the timing of the factual statement will continue to apply. The member can object at any time during this process (TP).
- Modifications to the background section of press releases:
  - Allow necessary corrections, deletions, and related rephrasing (including for evident ambiguity and highly market-sensitive material).
  - Allow additions and revisions beyond the above to better reflect wording used in the related staff report and associated documents, and to include background information shared with the Board and not included in those documents.
  - Additions and revisions should be parsimonious, only include information reported in the staff report and associated documents or discussed during Board consideration, and be consistent with the general prohibition of negotiating staff reports (TP).
  - Additions and revisions will be notified to the Board (e.g., issuance of a revised background section).
  - Clarify that modifications and possible additions and revisions only apply to the background section of press releases for surveillance country documents (TP).
- No change proposed for press releases for policy papers given weaker rationale for rapid communication (para 61).

### Reduce delays in publishing country staff reports and non-objection consent modality (paras 62–64)
- Problem statement:
  - A significant share of country documents is published more than two or even four weeks after Board consideration, posing reputational risks.
- Proposal: Clarify non-objection consent modality and related timelines (TP).
  - Consent deemed provided on a non-objection basis unless, prior to conclusion of Board consideration, the member:
    - (i) objects to publication,
    - (ii) indicates it requires additional time to decide, or
    - (iii) consents subject to reaching agreement with the Fund on deletions.
  - Members can opt out of the non-objection modality. In the absence of a notification under (i)–(iii) or of a prior opt-out notification, the Fund will promptly publish the country document (TP).
- Timeframes when members request more time or condition consent on deletions:
  - If a member indicates it requires more time or consents subject to agreement on deletions, the member will be expected to communicate its decision on publication within fourteen calendar days from the date of Board consideration. At that time, consent will be deemed provided and the report will be promptly published (following resolution of any modification requests) unless an explicit objection is received or the member requests further time.
  - If no objection is received within twenty-eight calendar days from the date of Board consideration, consent will be deemed provided and the Fund will promptly publish the country report following resolution of pending modification requests. At that point no further modification requests or time extensions will be allowed (TP).
- Use of factual statements to communicate publication decisions:
  - If a member objects to publication within 14 calendar days from Board consideration, a factual statement will be issued to inform the public that the member has not consented to publication (TP).
  - For members that requested more time and subsequently object, a factual statement will be issued after twenty-eight days (TP).
- Opt-outs from non-objection modality:
  - A member who has opted out is expected to communicate its publication decision no later than fourteen calendar days from Board consideration (twenty-eight calendar days if the member has pending modification requests fourteen days after Board consideration). Consent will not be presumed.
  - If such a member has not consented within fourteen calendar days, a factual statement will be issued that the member has taken no publication decision. If the member has pending modification requests, no factual statement will be issued; if after twenty-eight calendar days the member has not communicated any decision, a factual statement will be issued providing notification that no publication decision has been taken (TP).
- Staff guidance will remind members of rules and modalities and clarify circumstances in which consent will be deemed provided.

### Strengthen rules to modify Board documents and ensure accurate presentation of authorities’ views (paras 65–70)
- Objectives of proposed improvements to modification rules (para 65):
  - (i) Amend correction rules to ensure more accurate presentation of authorities’ views in surveillance country documents.
  - (ii) Incorporate into the policy the process to delete confidential information.
  - (iii) Incorporate modalities for correction of administrative errors.
  - (iv) Clarify implementation criteria used in applying correction categories.
  - (v) Provide adequate time to submit modification requests while simplifying corrections post-Board consideration.
  - (vi) Clarify rules to modify policy documents prior to Board consideration.
  - Staff does not support introducing broader discretionary modification categories that would enable redrafting to improve presentation, as that would risk negotiating staff reports and undermine independence and candor.
- Ensure accurate presentation of authorities’ views (paras 66–69):
  - Staff see merit in expanding modification rules to allow limited additions to authorities’ views in surveillance staff reports where the report omits views on main issues or staff’s policy recommendations discussed during consultation and presented in the country report (footnote 29).
  - Rationale: views on main issues and policy recommendations are expected to be reported; limited additions help ensure accurate presentation.
  - Safeguards due to significance of change (para 68):
    - Additions are an exception to not re-opening staff reports and must be ring-fenced to avoid reopening consultations or introducing new topics not available at the time of consultation.
    - Additions must be based on information available to both staff and authorities at the time of consultations, be parsimonious, and anchored in an overall indicative word count limit.
    - Additions must be issued to the Board two days before consideration of the relevant report to ensure the Board discussion is based on the latest version of the authorities’ views (TP).
  - Guidance updates:
    - Guidance will set the timeline and overall word limit for additions and possible extensions to authorities’ views sections.
    - Guidance will clarify that staff are expected to confirm with the authorities in writing the wording describing their views to be included in country staff reports.
  - Improve visibility of authorities’ views conveyed during Board consideration but not reflected in staff reports:
    - Executive Directors’ statements (BUFF) and authorities’ statements published alongside the country staff report help convey such views.
    - New publication solutions (e.g., a table of contents with hyperlinks to each component of the published bundle) could enhance visibility for these statements and for staff supplements and important developments after Board presentation; such proposals fall outside the Transparency Policy and have resource implications (Section VII).

*International Monetary Fund — REVIEW OF TRANSPARENCY POLICY AND OPEN ARCHIVES POLICY (excerpts as provided)*

### 71.      The existing procedures to remove confidential information from Board

### The existing procedures to remove confidential information from Board documents outside of the Transparency Policy could pose transparency concerns.

### Confidential information removal: findings and concerns
- Upholding confidentiality rules and complying with existing guidance to staff on the handling of confidential information is of utmost importance to maintaining the trust between the Fund and its membership.
- Lack of clarity over procedures for handling rare cases of confidential information falling outside the deletion categories of the Transparency Policy could feed perceptions that confidential information is not adequately, transparently, and evenhandedly protected.
- Footnote context preserved from source:
  - "30 Information is deemed to have been provided in confidence if there was an expressed or implied understanding between staff and the other party that such information would not be disclosed without the party’s consent. To the extent that there are doubts as to whether certain information was provided on a confidential basis, the Fund’s approach has been to give the benefit of doubt to the other party. For an overview of the Fund’s treatment of confidential information, see the Fund’s Treatment of Confidential Information and Background Paper 3."
  - "31 If confidential information is leaked, it is not treated as publicly available."

### Proposals to incorporate deletion of confidential information into the Transparency Policy
- Proposal: Allow for the removal, before a document is published, of confidential information included in Board documents when it cannot be deleted under the policy’s current deletion rules (TP). The removal covers the cases where information was provided on a confidential basis was included in the Board document either: (i) inadvertently, or (ii) as information required to support the Board’s decision-making process. To be removed, such information should not be publicly available at the time of the request for removal. Management approval will continue to be required to remove confidential information from Board documents to be published.
- Proposal: In cases where confidential information was inadvertently included in Board documents ((i) above), the following additional procedural safeguards apply to confirm that information was originally provided in confidence:
  - Authorities will be required to substantiate their claim that information was provided on a confidential basis and not intended to be included in the staff report.
  - Staff will be required to confirm to management that they inadvertently included in the Board document information that the authorities indicated, at the time the information was provided, that it should be treated as confidential and not shared beyond staff or management.

### Staff responsibilities and guidance
- Guidance will be provided to staff to remind them of their responsibilities for classifying and handling the treatment of confidential information. This will be included in an updated staff guidance note.

### Incorporating procedures to correct administrative errors
- Formalizing under the Transparency Policy the administrative errors procedure to modify Board documents would support its transparent and evenhanded application.
- Scope recommendation: Limit administrative errors to cases that undermine the Board’s consideration of the submitted document, consistent with current practice. Examples include documents issued to the Board that were not the management-approved version, or where key elements necessary for Board consideration are missing or incomplete (e.g., Debt Sustainability Analysis tables and charts, External Sector Assessment, or structural benchmarks tables).
- Critical procedural requirement: Application of the procedure would need to provide adequate time for the Board to review the modified document before concluding their consideration.
- Footnote context preserved:
  - "32 In cases in which an administrative error is identified after Board consideration, but prior to publication, management may decide that the nature of the error requires reopening the Board consideration to present the correct elements of the Board document, including any revised decisions as necessary. Otherwise, the document will be published in the format considered by the Board."

### Proposals for administrative errors in the Transparency Policy
- Proposal: Include in the Transparency Policy the possibility to rectify administrative errors made in the submission of Board documents for Board consideration (TP). Changes due to administrative errors would be allowed in cases where documents issued to the Board (i) do not correspond to the management-approved version, or (ii) key elements necessary for Board consideration are missing or incomplete.
- Proposal: Provide that administrative errors procedures can only be used prior to the Board’s consideration of the document in question and that the Board must be provided with a minimum of two working days to consider the revised document (TP).

### Clarifying criteria guiding correction rules for country documents
- Need: Specify in the guidance note the key criteria used in assessing correction requests to improve clarity, consistency, and perceptions of evenhandedness.
- Clarifications to be included:
  - In line with the policy’s general principle on the non-negotiation of staff reports, staff’s views (including projections) cannot be modified.
  - Corrections of factual errors are permitted where the factual information in the report is determined to be inaccurate, including data, provided the information was available at the time the relevant document was submitted for Board consideration. Factual errors would also include incorrectly attributed references.
  - Corrections of typographical errors are permitted, which are limited to grammar, punctuation, and spelling issues (and thus separate from factual errors).
  - Corrections to address the mischaracterization of the authorities’ views can modify and clarify the authorities’ views presented in the staff report, including parsimonious redrafting to improve clarity.
  - Corrections for evident ambiguity are allowed to avoid plausible and specific misinterpretation; they require that more than one interpretation is possible of the meaning of a staff statement. Corrections should preserve the intended meaning without extending arguments.

### Timing and treatment of post-Board corrections
- Current rules context:
  - Requests for corrections and deletions are expected to be received no later than two business days before Board consideration of the document.
  - The policy permits deletion requests up to seven calendar days after the Board’s consideration of the document.
  - By contrast, corrections can only be made after Board consideration where (i) the corrections were brought to the attention of the Board before the conclusion of the consideration of the document, or (ii) failure to make the corrections would undermine the overall value of the publication.
  - Footnotes:
    - "33 Or 21 days after it was issued to the Board, whichever is later."
    - "34 Transparency Policy, paragraph 10. In addition, corrections with significant implications for the substance of the document should be discussed and justified in a corrections memorandum to the Executive Board or a supplementary staff report."
- Proposal on aligning deadlines:
  - Submission of requests for deletions and corrections to country documents will continue to be expected no later than two business days before the Executive Board’s consideration and, in any event, correction requests (like deletion requests) should not normally be requested later than seven calendar days after the Executive Board has considered the document (or 21 calendar days after the document was issued to the Executive Board, whichever is later) (TP). It would continue to be the case that for correction requests received post-Board, corrections can be made only where failure to make the corrections would undermine the overall value of the publication, except for corrections of typos and factual errors, which would be allowed (TP).

### Clarifying rules to modify policy documents prior to and after Board consideration
- For changes to policy proposals prior to Board discussion:
  - Management retains ultimate control and can modify policy proposals and supporting analysis through issuing a supplement or, in case of extensive changes, by issuing a revised paper with relevant changes. The revised paper should be accompanied by an articulation and explanation of the changes. Issuance of a revised paper is expected to be rare.
- For changes to policy proposals post-Board discussion:
  - Where the final adopted decision (as reflected in the press release pertaining to the Board’s consideration) differ from staff’s proposals, the Board document would be modified to clearly indicate in the published version which staff proposals the Board did not endorse (e.g., with a footnote or other indication). The guidance note will make this modality clear.
  - Where management and staff decide to make changes to the final proposal in response to the Board discussion and see a need to adjust the policy proposals beyond the issuance of a supplement to the original document, then a revised version of the final paper reflecting such changes should be issued to the Board for lapse of time consideration following the Board discussion and prior to publication, accompanied by an articulation and explanation of changes. The guidance note would elaborate this modality.
- Communication requirement: The press release accompanying the publication of such policy papers would normally indicate whether changes and additions to policy proposals were made to the document that was originally circulated to the Board.

### Widening dispute procedures over policy implementation
- Current scope: Dispute procedures under the Transparency Policy and the guidance note cover only a subset of disputes—specifically members’ requests for deletions from country documents or modifications of press releases for non-UFR documents. The guidance note permits referral to management for disagreements between staff and authorities. The Transparency Policy decision provides procedures for “serious” disagreements between management and a member, which may be referred to the Board by the Managing Director or the Executive Director.
  - Footnotes:
    - "35 Disagreements can be between staff and Fund member authorities, while “serious” disagreements can be between the Managing Director and Fund member or the Executive Director of the relevant Fund member and between Fund members.  Similar procedures apply to disagreements on deletions to cluster documents and for press releases for Article IV staff reports, regional surveillance decisions, and stand-alone FSSAs (Transparency Policy Decision 15420-(13/61), Part II, Section C, paragraph 8 (d); Part II, Section F, paragraph 12 (c) and Part IV, Section C, paragraph 25 and Guidance Note on the Fund’s Transparency Policy."
    - "36 See Institutional Safeguards Review (ISR)—Engagement Between OED and Fund Staff: Guidance to Staff, Office Memorandum June 28, 2023; Implementation Plan in Response to IMF Executive Board and Management Endorsed Recommendations of the 2022 Institutional Safeguards Review (SM/22/269), and Institutional Safeguards Review (ISR)—Enhancing the Transparency around Management Review and Clearance of Staff Papers, February 2, 2023."
- Proposal: Extend the existing dispute process for serious disagreements between management and a member on deletions to include any disputes on the application of rules to modify Board documents (TP). Similarly, the updated guidance note will extend the existing dispute procedures for disagreements between staff and the authorities on deletions to any disputes involving the application of rules to modify Board documents. In assessing any disagreements, both the Managing Director and the Board are bound by the provisions of the Transparency Policy.
- Coverage of extension: The extension would encompass disputes on corrections, deletions, modifications to published documents, and on the removal of confidential information. The process to follow in case of disagreement between staff and authorities, consistent with the current process, will be described in the updated staff guidance note.

### Support for implementation and process improvements
- Upgrade the process for modification requests:
  - Set up systems and processes to monitor time to assess modification requests and ensure requests normally receive an initial assessment within 36 hours from submission into the internal system.
  - Under the Common Review System (CRS) work, explore technological solutions to:
    - (i) further streamline and speed up the process by reducing submission mistakes (e.g., interactive submission forms to guide submissions by staff) and facilitating the assessment of subsequent requests for the same modification (e.g., linking requests);
    - (ii) provide access to the justifications underpinning rejections of modification requests to involved parties;
    - (iii) replace the current detailed annual report to the Board with an IT solution that is quicker and easier to access.
  - Guidance will ensure authorities are consistently informed of justifications leading to rejection of submitted modification requests.
- Strengthen understanding of the policy:
  - Updated guidance to staff on how to inform authorities and raise awareness of the Transparency Policy, including rules for publication and modifications of staff reports, the principle of non-negotiation of staff reports, and elements expected to be shared in advance with authorities (e.g., wording describing the authorities’ views).
  - Develop a short "How To" note on the process for modification of Board documents detailing the step-by-step process to support staff and authorities.
  - Offer periodic training for staff, with similar training made available to Executive Directors’ offices (e.g., as part of the annual onboarding exercise).
- Improve data on modification requests:
  - Country teams will be asked to report the number of modification requests received from authorities to better monitor the share of accepted requests.

*Source: ppea2024057 - 71. The existing procedures to remove confidential information from Board documents outside of the Transparency Policy could pose transparency concerns. (PDF chapter/section).*

### 85.      Staff would also make the following adjustments in updated guidance to staff to

### Staff would also make the following adjustments in updated guidance to staff to

### Adjustments to Transparency Policy guidance
- Clarify the criteria to address possible inconsistencies across documents issued to the Executive Board around the same time, especially when an Article IV staff report summarizes main findings and recommendations from highly technical documents issued around the same time, such as debt sustainability and external sector assessment annexes, Selected Issues Papers, and FSSAs.  
- Treat any factual inconsistency between the Article IV staff report and these technical documents as an evident ambiguity that could be corrected.  
- Apply all general implementation rules under the Transparency Policy, including not adding information, to such corrections.  
- Allow the introduction of cross references to the specific technical document for context as part of such corrections.

### Key recommendations from Table 1 (Transparency Policy Review)
- Reinforce principles and coverage
  - Include in the preamble to the Transparency Policy decision the objective of preserving the independence and candor of staff’s views as a key principle underpinning the policy.  
  - Include stand-alone ERAs in the new negative list of documents under the Transparency Policy for which publication is not presumed.  
  - Continue the MAC SRDSF’s special deletions, on a temporary basis, pending further experience with the application of the SRDSF framework.  
  - Require that documents received from other institutions, and required for Fund Board consideration, are published with the related staff report, unless the authoring institution requests or the Fund’s Board decides otherwise, and allow for modifications by the authoring institution only prior to Board consideration.  
  - Establish the principle that no changes to published documents should be permitted except under very limited circumstances defined under the decision.
- Support faster communication of Board activities and document publication
  - Press releases: require surveillance country document press releases (or a factual statement) to be issued immediately (two business days) after Board consideration and include the member’s publication intentions for the related document.  
  - Allow the member to postpone the publication of a surveillance country document press release up to seven days after Board consideration if it consents to publish the relevant staff report.  
  - Provide that consent for the publication of press releases would be presumed unless, prior to the conclusion of the Board consideration, the member explicitly objects or indicates that requires more time to decide.  
  - Simplify the application of modification rules to the background section of surveillance document press releases by allowing a broader set of revisions.
- Country document publication modalities and timelines
  - Clarify when publication consent is deemed to be provided under the non-objection modality.  
  - If before the conclusion of Board consideration the member has requested more time to decide on the publication of a country report, the non-objection modality applies after 14 calendar days from Board consideration (28 days if additional time is requested to take a decision).  
  - If a member objects to publication after 14 days (or after 28 days if more time was requested to make a decision), issue a factual statement providing notification that the member does not intend to publish the country report. Modification requests received after 28 days from Board consideration would not be considered.
- Strengthen and clarify rules and processes to modify Board documents
  - Allow limited additions to authorities’ views sections of country reports, subject to safeguards.  
  - Incorporate into the policy the process to remove confidential information.  
  - Incorporate into the policy the “administrative errors procedures” to allow for changes to Board documents under specific circumstances ahead of Board consideration.  
  - Clarify in the guidance to staff the decision criteria used to implement correction rules.  
  - Allow correction requests to be normally submitted no later than seven days after Board consideration (or 21 days after the document was issued to the Executive Board), whichever is longer.  
  - Allow for corrections for typographical and factual errors but otherwise maintain the higher standard currently applied for post-Board correction requests.  
  - Clarify in the guidance to staff the rules to modify Fund policy documents before Board consideration.
- Widen application of dispute procedures about policy implementation
  - Extend the existing dispute procedures for serious disagreements between management and a member for deletions to include disagreements on the implementation of any modification rule under the policy.  
  - Extend the existing dispute process for disagreements between staff and the authorities on deletions to include disagreements on the implementation of any modification rule under the policy.  
  - Adapt processes and deadlines for modification requests to the timeline of Staff Monitored Programs (SMP) country documents and documents presented for Board consideration on a LOT basis, given SMPs are issued with short circulation periods and LOT documents follow special rules about conclusion of Board consideration.

### Open Archives Policy (OAP): scope, recent experience, and issues
- OAP scope and purpose
  - The OAP governs public access to the archived permanent records of the Fund, covering archived permanent records including Board documents and records published under the Transparency Policy as well as other documentary material marked for permanent retention (e.g., minutes of Board meetings, internal memoranda, and correspondence).  
  - The OAP uses graded 3/5/20-year lapse-of-time (LOT) rules, depending on document category, with some limited exceptions to protect privacy and confidential information.  
  - Access to archived permanent records marked secret or strictly confidential must be first declassified by the Managing Director (or delegate).
- Recent usage and processing
  - There has been an average of about 9,000 views of the Fund’s archive website.  
  - Between FY2021 and FY2024 requests to access archival records have increased more than sixfold, amounting to more than 540,000 pages in the most recent fiscal year.  
  - After some delays during the pandemic period, there is no backlog of records requests.
- Cataloging, digitization, and comparators
  - Since 2018, new automated workflows have streamlined core processes and accelerated the release of Board documents and records to the archive catalog; currently all documents under the OAP’s 3/5-year time rules, including Board documents and records, are available for consultation through the catalog and accessible in digital form.  
  - Compared with 15 surveyed international organizations (IOs) that are members of the International Council on Archives (ICA), the Fund’s design compares favorably: out of the 15 IOs, only two used time rules shorter than 20 years for some material and seven IOs used 30-year (or longer) time rules. Most surveyed IOs have restrictions on disclosing confidential information and provide electronic access to archives.
- Implementation challenges and risks
  - The OAP time rules can delay availability in the Fund’s archives of documents already available on the Fund’s website (creating potential confusion for researchers).  
  - There is room to reassess whether the 20-year coverage remains appropriate for some items (e.g., transcripts of informal Board meetings).  
  - Exceptional cases may justify releasing “other documentary material” before 20 years (e.g., enforcing the Fund’s rights, cooperating with criminal investigations or other legal proceedings).  
  - Processing “other documentary material” remains resource intensive: many records are in paper format, leading to a growing backlog of unprocessed paper records and reputational risks; many paper records in the catalog are not yet digitized, limiting accessibility.  
  - Lack of an official staff guidance note on the OAP increases the potential for uneven application of the policy; better interdepartmental coordination mechanisms are absent.  
  - A growing volume of born-digital records (internal documents, emails, Sharepoint files) reaching the end of their 20-year time rule will require defined processes and infrastructure for digital preservation, management, storage, and public access.

### Reform proposals and staff judgment on OAP rules
- Overall assessment
  - Staff believe the OAP is broadly adequate and not in need of substantive reforms; the policy compares favorably with those of other IOs.  
  - The Fund’s time rules on access generally work well and strike an adequate balance between information access and protection of confidentiality by allowing sufficient time to elapse between surveillance and lending discussions and information release.
- Areas for targeted improvements
  - Ensure that the current time rules remain appropriate.  
  - Strengthen the accessibility of archived permanent records (prioritize processing and digitization of paper records; address backlog).  
  - Enhance the Fund’s capacity to implement the OAP, particularly for born-digital records (define processes and build digital preservation infrastructure).  
  - Clarify minor definitions and concepts across documents underpinning the Fund’s records management framework to better align practices and oversight.
- Specific judgments on time rules and transcripts
  - Reducing the 3/5-year time rules for Board documents could negatively affect the candor of Board discussions and risk premature release of sensitive market data; staff see risks and limited upside to reducing these rules.  
  - On transcripts of informal Board meetings: staff see both pros and cons to reducing the 20-year rule but, on balance, suggest no change. Reasons: minutes for formal Board meetings are released after 3/5 years while raw transcripts of informal Board meetings are released after 20 years; releasing transcripts automatically after five years could raise confidentiality concerns; manual review at five years would be very resource intensive given the frequency of informal Board meetings; creating a new intermediate time rule for one document type would complicate the policy. Thus, staff prefer to keep the current coverage of the 20-year rule unchanged.

*REVIEW OF TRANSPARENCY POLICY AND OPEN ARCHIVES POLICY*

### 99.      There are cases in which it should be possible for some documents to be made

### ppea2024057 - 99.      There are cases in which it should be possible for some documents to be made

### Enhancing Archive Accessibility
- Findings:
  - Board documents that are published on the Fund’s external website are not immediately available in the archive catalog due to the 3/5-year time rule for such documents.
  - There are cases where documents could be made available to the public before the period prescribed in the OAP expires.
  - Exceptional circumstances may warrant access to archived other documentary material before the 20-year time rule expires if that is in the interest of the Fund (e.g., enforcing Fund’s rights, cooperating with criminal investigations or other legal proceedings), subject to the prescribed procedure.
  - Early releases would remain subject to existing information security and confidentiality rules; information classified as confidential, strictly confidential, secret or, in some cases, for official use would only be possible after declassification.

- Policy proposals:
  - Clarify that Board documents that have been published should be part of the Fund’s archived permanent records and made available under the archive catalog upon publication.
  - Allow the Managing Director, in exceptional circumstances and when in the interest of the Fund, to grant upon request access to other documentary material before the expiration of 20-year time rule.

### Support Stronger Archives
- Findings:
  - Since the 2013 review, availability should take precedence over digitization; digitizing on an as-needed basis can be an effective second-best strategy.
  - A large volume of other documentary material approaching the 20-year time rule is born digital and does not pose a resource trade-off going forward.
  - There is a backlog of unprocessed paper records requiring additional ad hoc resources.

- Proposed actions:
  - Identify additional ad hoc resources to clear the backlog of unprocessed paper records.
  - Issue an OAP staff guidance note to elaborate on implementation aspects of the policy and review other records management rules (e.g., GAO 26) to better support consistent application of the Fund’s wider records management framework and public access to the archived permanent record.
  - Establish an interdepartmental mechanism (e.g., a committee) to strengthen internal coordination in implementing the OAP and related Fund policies on records management.
  - Update internal processes and acquire adequate infrastructure to create an enterprise-wide digital preservation system that meets the Fund’s requirements for managing its permanent digital records.

### The Fund’s Communications Strategy
- Findings:
  - The communications strategy, introduced in 1998, supports Transparency Policy objectives by making the Fund’s work more accessible and facilitating dialogue.
  - An upcoming 2024 review of the communication strategy reinforces linkages with the Transparency Policy review and proposes an evolution (e.g., leveraging data analytics, strengthening the Fund’s own media channels and platforms, integrating traditional media operations with social media).
  - Proposals in this paper (e.g., enhancing speed of communication of Board decisions and publication of country documents) would support timely communication and mitigate risks of competing narratives.

### Resource Implications of Proposed Reforms
- Estimated resource needs and impacts:
  - Some reform proposals carry costs for an estimated total gross additional staff resources of about 0.5 full time equivalent (FTE).
  - Improving publication process of Article IV staff reports to provide hyperlinked tables of content to all components and ensure that modification requests are normally assessed within 36 hours will require additional staff resources.
  - Additional financial capital and transitional staff resources would be needed to address the analog backlog, acquire infrastructure for digital preservation, and automate early release in the archive catalog of published documents.
  - Savings are expected over time but likely to materialize only over time; technological solutions (Common Review System project) could bring further savings.
  - Medium-term net impact on staff resources would likely be neutral provided that (i) savings from proposed actions over time reach about 15 percent of current Transparency Policy implementation resources, and (ii) improvements in the publication of staff reports are only applied to Article IV staff reports.
  - Each five percent of savings not delivered would require 0.15 FTEs in additional resources.
  - Continuous monitoring and adjustments will be required given high uncertainties on gross cost and possible savings.

### Enterprise Risk Assessment
- Transparency Policy risks:
  - Status quo risks include reputational risks from lengthy delays in publication of country documents and press releases; lack of clarity over scope and application; frustration over implementation; perceived lack of evenhandedness; higher operational risks including human errors.
  - Reforms should address many status quo risks but introduce potential new reputational and operational risks.

- Reputational risk considerations:
  - Allowing more modification of authorities’ views could undermine perceived independence and evenhandedness; mitigated by safeguards (e.g., indicative word limits, relevance of topics).
  - Perceptions of lack of evenhandedness may persist; mitigation includes streamlined modification process, simplified rules, enhanced communication/outreach and staff training, and extending dispute procedures to disagreements on modification rules.
  - Strengthening “non-objection” modality for consent to publication could limit delays and reduce reputational risks from publishing outdated information, but could also result in fewer publications if a member only agrees with very long delays; mitigated by the unchanged possibility for the member to reverse at any time its objection to publication.

- Operational risk considerations:
  - Separating publication of press releases and staff reports might dilute press impact but is limited by option to issue both within seven days from Board consideration and by media focus on press releases.
  - Setting timelines for the “voluntary but presumed” publication regime might prompt objections, but a member can always reverse its decision later.
  - Proposal to not consider modification requests submitted more than 28 days after Board consideration carries limited risk as on average only 1-2 such cases occur each year.
  - Correction of documents post-publication risks multiple versions circulating; proposed measures would provide clear principles, transparent flagging, and help ensure published documents correspond to the version considered by the Board.
  - Aligning post-Board correction request submission window with deletions could prompt requests that were previously pre-Board to be submitted post-Board, possibly contributing to delays; mitigations include high threshold for post-Board corrections, explicit time limit to submit requests, and consistent application of non-objection modality.
  - Incorporating administrative errors procedures could inadvertently increase such errors; proposal sets a very high risk-based threshold for correcting such errors and would require sufficient time for Board review, even if that delays Board consideration.

- Open Archives Policy risks:
  - Failure to address backlog in archive catalog availability of other documentary material poses reputational risks.
  - Inadequate capacity to capture new digital records poses operational risks.
  - Key mitigation steps: acquire adequate infrastructure and allocate resources to (i) reduce the backlog, (ii) address inability to capture new types of digital records, and (iii) put in place guidance and coordination mechanisms.

- Implementation and resource risks for proposed OAP reforms:
  - Main risks relate to availability of adequate temporary staffing resources and infrastructure; mitigation via standard project prioritization process covering temporary staff needs.

### Transitional Arrangements
- Proposed timing for implementation:
  - New policy becomes effective two months following adoption by the Board, except for some provisions, to allow adjustment of internal administrative processes and sharing new procedures with stakeholders.
  - Implementation of proposals on modifications of published documents, removal of confidential information, and rectification of administrative errors will start immediately as they can rely on existing procedures.
  - Implementation of proposals on modification of authorities’ views and background sections of surveillance press releases will start three months following adoption to allow finalizing interim guidance to staff.
  - Proposals on criteria guiding application of correction rules, dispute process, and clarification to modify policy documents will take effect six months after adoption, following issuance of updated guidance note.
  - Implementation of changes to the OAP becomes effective two months following adoption of the decision.

*Source: ppea2024057 (excerpt) — REVIEW OF TRANSPARENCY POLICY AND OPEN ARCHIVES POLICY, INTERNATIONAL MONETARY FUND*

### Appendix I. Indicative Lists of Board Documents Covered by the

### Appendix I. Indicative Lists of Board Documents Covered by the Transparency Policy

### Overview
- The Transparency Policy covers Country Documents, Fund Policy Documents and Multi-Country Documents.
- When a document is covered by the policy both the publication and modification rules of the policy apply, unless otherwise specified in the decision.
- The appendix provides:
  - an updated indicative list of documents covered by the Transparency Policy;
  - an indicative sub-list of Board documents covered by the policy that deal with the administrative matters of the Fund and, under the policy, are not presumed to be published (the “negative” list).
- The lists are indicative and are not intended to be exhaustive.
- Country Documents, Fund Policy Documents, and Multi-Country Documents created between reviews of the Transparency Policy will be subject to the Transparency Policy Decision, unless the Executive Board decides otherwise on a case-by-case basis.

### I. Country Documents — Surveillance and Program-Related Categories
- A. Surveillance and Combined Documents
  - 1. Staff Reports for Article IV consultations, Combined Article IV consultation/Use of Fund Resources, Combined Article IV consultations/PCI, Combined Article IV consultations/SMP, Combined Article IV consultations/PMB, and regional surveillance discussions.
  - 2. Selected Issues Papers.
  - 3. Reports on Observance of Standards and Codes (ROSCs), Financial System Stability Assessment (FSSA) Reports, and Assessment of Financial Sector Supervision and Regulation (AFSSR) Reports.
  - 4. Press Releases following Article IV consultations, regional surveillance discussions, and stand-alone Board consideration of FSSA reports.
  - 5. Stand-Alone Debt Sustainability Analysis reports.
  - 6. Documents prepared for informal Board briefings for countries with excessively delayed Article IV consultations or mandatory financial stability assessments.
- B. Use of Fund Resources Documents
  - 7. Joint Fund/World Bank Staff Advisory Notes (JSANs) on Interim Poverty Reduction Strategy Papers (I-PRSPs), Poverty Reduction Strategy Papers (PRSPs), PRSP Preparation Status Reports, PRSP Annual Progress Reports (APRs), and Poverty Reduction Growth Strategy Papers (PRGS).
  - 8. Staff Reports for Use of Fund Resources, Post-Financing Assessments, Ex-post Peer-Reviewed Assessments (PRAs), and Ex-Post Evaluations of exceptional access arrangements (excluding staff reports dealing solely with a member‘s overdue financial obligations to the Fund).
  - 9. Press Releases containing a Chairman‘s Statement for Use of Fund Resources.
  - 10. Preliminary, decision point, and completion point documents under the Heavily Indebted Poor Countries Initiative.
  - 11. Press Releases following Executive Board discussions on Post-Financing Assessment, PRAs or Ex-Post Evaluations of exceptional access arrangements (excluding staff reports dealing solely with a member‘s overdue financial obligations to the Fund).
  - 12. I-PRSPs, PRSPs, PRSP Preparation Status Reports, APRs, and PRGSs.
  - 13. Letters of Intent (LOIs), Written Communication from authorities, and Memoranda of Economic and Financial Policies (MEFPs).
  - 14. Technical Memoranda of Understanding (TMUs).
  - 15. Staff Notes on preliminary evaluation of high and/or exceptional access.
  - 16. Overdue Financial Obligations Documents.
- C. Staff Monitored Program (SMP) Documents and Program Monitoring with Board Involvement (PMBs) Documents
  - 17. LOIs/MEFPs for SMPs and Program Monitoring with Board Involvement (PMBs).
  - 18. Stand-alone Staff Reports on SMPs and PMBs.
  - 19. Press releases following Executive Board discussions on PMBs.
- D. Policy Coordination Instrument (PCI) Documents
  - 20. Program Statements for PCIs.
  - 21. Technical Memoranda of Understanding (TMUs).
  - 22. Staff Reports for PCIs.
  - 23. Press Releases containing a Chairman‘s Statement for PCIs.
- E. Statements on Fund Decisions
  - 24. Statements on Fund decisions on waivers of applicability, or for nonobservance, of performance criteria, and any other matter as may be decided by the Executive Board from time-to-time.

### II. Fund Policy Documents
- 25. Fund Policy Issues Papers.
- 26. Background papers to Fund Policy Papers.
- 27. Press Releases following Executive Board consideration of policy issues.
- 28. Internal Fund Administrative Documents.
- 29. Stand-alone Enterprise Risk Assessments (ERA).

### III. Multi-Country Documents
- 30. Multilateral Policy Issues Documents such as the World Economic Outlook, the Global Financial Stability Report, the Fiscal Monitor(*)
- 31. Other Multilateral Policy Issues Documents such as External Sector Reports and Spillover Reports.
- 32. Press Releases following Executive Board consideration of Multilateral Policy Issues.
- 33. Country Background Pages.
- 34. Press Releases following Executive Board consideration of Country Background Pages.
- 35. Cluster Documents.
- 36. Press Releases following Executive Board consideration of Cluster Documents.

### Indicative list of Board Documents covered by the Transparency Policy and Not Presumed to be Published (Negative List)
- 1. Internal Fund Administrative Documents.
- 2. Documents prepared for informal Board briefings for countries with excessively delayed Article IV consultations or mandatory financial stability assessments.
- 3. Staff Notes on preliminary evaluation of high and/or exceptional access.
- 4. Overdue Financial Obligations Documents.
- 5. Stand-alone Enterprise Risk Assessments (ERA).
- Note: While the presumption of publication does not apply to such documents, they can be published on a case-by-case basis on approval by the Executive Board.
- (*) Under the policy, these documents are not subject to the policy’s standard rules to modify Board documents.

### Appendix II — Comparing International Financial Institutions’ Policies on Transparency and Archives (Summary)
- Scope and benchmarking
  - The Fund’s transparency framework comprises the Transparency Policy and the Open Archives Policy, governing disclosure and modification of documents submitted to the Executive Board and public access to the organization’s records.
  - Other IFIs typically have a single access information policy covering different aspects of transparency; benchmarking pertains to disclosure and modification of Board-submitted documents and public access to records.
  - Overall, the Fund is on par with other comparable IFIs in terms of general openness and transparency of Board decisions and activities, and access and modification of Board documents.
- Key comparative observations
  - Publication and disclosure of information
    - The Fund presumes publication of Board documents; some IFIs presume disclosure of information but not necessarily publication of documents.
    - Unlike other comparators, the Fund requires publication consent of the relevant member for country documents (requirement derives from the IMF’s Articles of Agreement (Article XII, Section 8)).
  - Communications of Board’s activities
    - Like the Fund, most IFIs normally issue external communications following meetings of decision-making bodies.
    - At the Fund, press releases are expected; other IFIs generally do not explicitly regulate issuing such communications.
    - Timing of communications varies across institutions (immediately after meeting or as soon as practicable).
  - Modifications
    - The Fund allows corrections and deletions at the request of country authorities and is on par with most institutions in allowing corrections and deletions before online availability, subject to internal guidelines.
    - The Fund’s modification rules are less restrictive than those institutions that allow only corrections for material errors or only removal of confidential information.
    - One comparator institution allows corrections and deletions without specific rules (exception).
  - Protection of sensitive and confidential information
    - The Fund’s framework for handling confidential information vis-à-vis the public matches other IFIs.
    - The Fund requires staff (and management) to disclose to the Executive Board any information required under the Articles of Agreement or critical for Board decision-making (Background Paper 3).
  - Open Archives Policy
    - The Fund’s framework governing access to archives is largely aligned with other IFIs in terms of timeframes for release of different types of records.
    - Time rules for availability of historical record or records that fall under “other documentary material” at the Fund are either similar or shorter than in other organizations (Section V).

### Selected comparative features from Appendix II. Table 1 (high-level points)
- Presumption of disclosure to the public
  - IMF: Disclosure to the public via online publication is presumed for policy documents and “voluntary but presumed” for country documents. For most country documents consent to publication based on a ‘non-objection’ basis.
  - Comparator institutions vary: e.g., IBRD/IDA discloses all information not on a list of exceptions; ECB as a rule does not make Executive Board/Governing Council documents public unless authorized.
- Timing of disclosure to the public
  - IMF: Board documents are published online after discussion at the Board.
  - Other institutions: some disclose certain information simultaneously with Board distribution or prior to Board consideration for specific project documents.
- Restrictions on disclosing sensitive/confidential information
  - IMF: Confidential information not disclosed unless required under the Articles of Agreement or necessary for the Board to carry out responsibilities.
  - Other institutions: generally do not disclose confidential information; ECB ensures absolute confidentiality of Governing Council proceedings unless the Governing Council authorizes disclosure.
- External communications of Board activity
  - IMF: A press release based on the Board decision and/or the summing up, or concluding remarks, of the Board discussion preceded by a short, purely factual, background section are published.
  - Other institutions: practices vary (press releases, minutes, accounts of discussions, or no formal external communication unless required).
- Modifications of documents submitted to Executive Boards
  - IMF: Corrections and deletions allowed before online availability, subject to internal guidelines; deletions made at the request of country authorities; documents disclosed can be updated and re-issued through an official correction if errors are found.
  - Comparator practices differ: e.g., ECB documents typically final and cannot be changed except for factual corrections or minor editorial changes.
- Archives policy (high-level)
  - IMF: Executive Board records are available to the public after three years, unless they relate to the use of Fund resources (five years). Other documentary materials available after 20 years, except classified items.
  - Comparator institutions: timeframes vary (examples in Table 1 include 30 years for historical records at some institutions, five days/within 30 days for specific disclosures, and other divergent practices).

*Appendix I. Indicative Lists of Board Documents Covered by the Transparency Policy — ppea2024057*

### Appendix II. Table 1. International Institutions’ Policies on the Treatment of Documents

### Appendix II. Table 1. International Institutions’ Policies on the Treatment of Documents

### Treatment of Board minutes, records, and archives (comparative notes)
- Summing-ups of Executive Board meetings or Public Information Notices (which contain the Board’s assessment of the meeting) are generally made promptly publicly available online.
- Verbatim Board minutes:
  - IMF: Verbatim Board minutes are available to the public in the archives after three or five years.
  - IBRD/IDA: Board Minutes are routinely disclosed as soon as they are finalized.
  - ECB: The ECB keeps Governing Council minutes confidential for 30 years; however, in accordance with Article 10.4 of the ECB and ESCB Statute, the Council's monetary policy decisions are made public through a press release and an account of discussions four weeks after each meeting.
  - EBRD: Minutes of the meetings of the Board of Directors are disclosed as soon as they are finalized.
  - IDB: Minutes of Board Meetings are publicly disclosed once they are approved by the Board of Executive Directors.
  - BIS: Board minutes are made available to researchers after 30 years; with agreement of the respective BIS-based committee, documents relating to the committee meetings can also be made available to researchers after 30 years.
- Confidential agendas, minutes of Board and Committee meetings, Reports of Board Committee Chairs, and Summaries of deliberations of the Board are subject to disclosure over time within 1, 5, 10, or 20 years, based on when this information no longer requires protection.
- ECB documents not in the ECB historical archives can be made available to the public in response to a request for public access.
- Operational Policies and Loan Proposals and Technical Cooperation Documents are noted as categories present in institutional practice (table fragment).

### Revised Preamble to the Transparency Policy (IMF)
- Overarching principle: The Fund will strive to disclose documents and information on a timely basis unless strong and specific reasons argue against such disclosure.
- Balancing considerations:
  - Respect the voluntary nature of publication of documents that pertain to member countries.
  - Safeguard confidential information and follow Article XII, Section 8 of the Articles of Agreement concerning publication by the Fund of its views with respect to a member.
  - Protect independence and candor of staff analysis while recognizing necessity of modifications under limited and defined circumstances.

### The Fund’s Communication Strategy (summary of key points)
- The Transparency Policy and Communication Strategy are complementary: the Transparency Policy provides a framework for timely dissemination; the Communication Strategy employs channels and platforms to make IMF work more accessible and understandable.
- Historical framework: Established by the Executive Board in 2007, based on four guiding principles:
  - (i) build understanding and support for IMF’s policies;
  - (ii) further integrate communications and IMF operations;
  - (iii) raise the impact of communications materials;
  - (iv) rebalance outreach efforts for different audiences.
- Rationale for evolution:
  - Faster pace of decision-making and higher expectations for transparency and communication require adaptation.
  - Communications must help the IMF respond to membership needs and shifts in the news/social media landscape.
- Strategic focus areas for updated Communications Strategy:
  - (i) leveraging data analytics to make communications more rigorously targeted and strategic;
  - (ii) strengthening the Fund’s owned media channels and platforms (e.g., IMF.org, IMF Blog);
  - (iii) integration of traditional media operations with social media;
  - (iv) greater emphasis on engagements with local and regional media/stakeholders.
- Implementation: The Fund’s Communication Department (COM) is reorienting to be more digitally-savvy, more strategic, more evidence-based and more adaptable; detailed in the 2024 Board Review of Communications Strategy.

### Proposed Decisions (timing and key operative elements)
- Decision 1. Review of the Fund’s Transparency Policy:
  - 1. Pursuant to paragraph 32 of Decision No. 15420-(13/61), as amended (the “2013 Decision”), the Fund has reviewed the Fund’s transparency policy.
  - 2. The 2013 Decision is hereby further amended to read as set forth in Attachment I of SM/24/257, Sup. 1, 11/8/2024.
  - 3. Effective dates and special timing provisions:
    - Amendments specified in paragraph 2 shall become effective January 15, 2025, provided that:
      - (i) paragraphs 12 and 14(g) shall become effective on February 15, 2025,
      - (ii) paragraphs 29-31 shall become effective immediately upon the adoption of this decision by the Executive Board, and
      - (iii) any dispute resolution on modifications to documents covered by the Transparency Policy will continue to be guided by the procedures under Decision 15420-(13/61) in effect at the time of the adoption of this decision and the new procedures set forth in paragraph 32 shall become effective on May 15, 2025.
- Decision 2. Review of the Fund’s Archives Policy:
  - 1. Pursuant to paragraph 9 of Decision No. 14498-(09/126), as amended (the “2009 Decision”), the Fund has reviewed the Fund’s archives policy.
  - 2. The 2009 Decision is hereby further amended to read as set forth in Attachment II to this decision.
  - 3. This decision shall become effective on January 15, 2025.

### Attachment I. The Fund’s Transparency Policy — Selected provisions (I. General Provisions; II. Country Documents)
- I. General Provisions — Coverage and publication
  - 1. Coverage: The Managing Director shall arrange for publication by the Fund of Country Documents, Fund Policy Documents and Multi-Country Documents in accordance with the principles set forth in this Decision and the attached Indicative List. Country Documents include documents pertaining to surveillance, use of Fund resources, the Policy Coordination Instrument (PCI), and certain reports arising from Fund technical assistance. Documents pertaining to regional surveillance discussions on common policies of a currency union shall be considered Country Documents. Fund Policy Documents cover general policy issues including surveillance, use of Fund resources, technical assistance, and Fund administrative matters. Multi-Country Documents are defined further in paragraphs 19 and 20.
  - 2. Publication:
    - a. Publication of Country Documents is subject to the consent of the member concerned. Publication of Fund Policy Documents requires Executive Board approval. Publication of Multi-Country Documents requires consent of the members concerned or Executive Board approval, as set forth in paragraphs 22-28. Publication of documents jointly authored by the Fund and the World Bank requires the authorization of the World Bank. The Fund may publish documents prepared by third parties that are required for Executive Board consideration as set forth in paragraph 37.
    - b. Under paragraphs 4(c), 16, 23(b), and 26, prompt publication means the document is expected to be published no later than (a) fourteen calendar days after the Executive Board has considered the document (or the date of adoption of a decision on a lapse-of-time basis to which the document relates), or (b) twenty-eight calendar days after the document has been issued to the Executive Board, whichever is later.
  - 3. Modifications: Country Documents, Fund Policy Documents, and Multi-Country Documents submitted for Board consideration or information can be modified prior to publication pursuant to paragraphs 8 through 12, 13(c), 14(g), 18, 29 and 30.
- II. Country Documents — Consent to publication (key rules and timelines)
  - 4. General principle:
    - a. A member’s consent to Fund publication of Country Documents shall be voluntary but presumed. Procedures to encourage consent are set out.
    - b. Consent to publication on a non-objection basis: Except as otherwise provided, consent is deemed provided on a non-objection basis unless, prior to the conclusion of the Executive Board meeting (or the date of adoption of a decision on a lapse-of-time basis), the member notifies the Fund that it: (i) objects to publication; (ii) requires additional time to decide whether to publish; or (iii) consents to publication but subject to reaching agreement with the Fund on deletions to the document.
    - c. In the absence of a notification in 4.b, Country Documents shall be published promptly after the relevant Executive Board meeting (or adoption on a lapse-of-time basis). If a member objects per 4(b)(i), the document shall not be published unless explicit consent is subsequently received.
    - d. A member that notifies the Fund per 4(b)(ii) or (iii) is expected to communicate its decision whether to publish within fourteen calendar days of the Executive Board meeting (or date of adoption of a lapse-of-time decision to which the document relates).
      - (i) After fourteen calendar days, a member’s consent to publication will be deemed to be provided, and the document will be published following resolution of any pending modification requests, unless the member explicitly objected or notified the Fund that it requires additional time.
      - (ii) After twenty-eight calendar days, if the member that had requested additional time has not explicitly objected, the member’s consent will be deemed provided, and the staff report will be published following resolution of any pending modification requests.
    - e. Opt-out: A member may notify the Fund in writing at any time that it opts out of providing consent on a non-objection basis. A member that has opted out is expected to communicate its decision whether to publish (i) no later than fourteen calendar days from the date of the Executive Board meeting at which the document was considered (or the date of adoption of a lapse-of-time decision), or (ii) no later than twenty eight calendar days if there are pending modification requests fourteen calendar days after the Executive Board meeting.
    - f. Coverage note: For Documents 3, 7, 12, 17, 18, the consent procedures in paragraphs 4(b)–(d) apply only if the document has been circulated to the Executive Board in the context of a meeting or a proposal for lapse-of-time approval. If circulated for information only, the member’s explicit consent must be provided prior to publication and the document may be published immediately after circulation pursuant to paragraph 33.
    - g. The consent procedures in paragraphs 4(b)–(d) do not apply to:
      - Press Release containing a Chairman’s Statement for the use of Fund resources (Document 9),
      - Press Release containing a Chairman’s Statement in the context of a PCI (Document 23),
      - Press Release for an Article IV consultation,
      - a regional surveillance discussion, or
      - Board consideration of Financial System Stability Assessment (FSSA) report (Document 4).
      A member’s consent to publication of these documents is governed by paragraphs 13 and 14.
    - h. For any document subject to consent procedures in 4(b)–(d), the Secretary’s cover memorandum will indicate that the document will be published promptly after the Executive Board meeting (or lapse-of-time adoption), unless the member notifies the Fund as provided in 4(b)(i), (ii), or (iii), or the member has opted out per 4(e).
  - 5. Conditions related to Fund resources and program documents:
    - a. The Managing Director will generally not recommend Executive Board approval for (i) access to resources in the General Resources Account, the PRGT or the Resilience and Sustainability Trust, or (ii) access to Fund resources under the HIPC Trust, or (iii) assistance through the PCI, unless the member explicitly consents to publication of the associated staff report. Approval of use of the Fund’s resources includes completion of a review under an arrangement; assistance through a PCI includes completion of a review under a PCI. For PCI, where a member does not provide consent to publication of an interim performance update, the Managing Director may take this into account when determining whether to recommend completion of a subsequent review of the member’s PCI.
    - b. The Managing Director will not recommend Executive Board approval of (i) an arrangement under the Poverty Reduction and Growth Trust (PRGT) or completion of a review under such arrangement, or (ii) a Heavily Indebted Poor Countries (HIPC) decision point or completion point decision, if the member does not explicitly consent to publication of its I-PRSP, PRSP, PRSP preparation status report, PRSP annual progress report (APR), or PRGS (Document 12).
    - c. Executive Board approval of a Short-Term Liquidity Line (SLL) arrangement shall be conditioned on receipt of the member’s consent to publication at the time the member sends written communication confirming its wish to avail itself of the SLL arrangement. The associated staff report and the authorities’ written communication would be expected to be published by the Fund no later than fourteen calendar days after the member’s SLL arrangement becomes effective.

*Italic: Source — ppea2024057 - Appendix II. Table 1. International Institutions’ Policies on the Treatment of Documents*

### 6. Except as provided in paragraphs 13 and 14 of this Decision, a member’s explicit consent

### ppea2024057 - 6. Except as provided in paragraphs 13 and 14 of this Decision, a member’s explicit consent

### II.A. Communication of Member’s Explicit Consent (paragraph 6)
- A member’s explicit consent shall, for the purposes of this Decision, be communicated to the Fund in writing.
- Such consent may be communicated by the Executive Director elected or designated by the member.

### II.B. Member’s Statement Regarding Fund Staff Reports (paragraph 7)
- If a Fund staff report (Documents 1, 5, 8,18 and 22) on a member is to be published under this Decision, the member concerned shall be given the opportunity to provide a statement regarding the staff report and the Executive Board assessment.
- Such a statement shall be communicated to the Fund and published together with the staff report.

### II.C. Modifications to Country Documents
#### II.C.1 Deletions (paragraphs 8–9)
- Deletions may be made to Country Documents, except for country policy intention documents on poverty reduction strategies (Document 12), in accordance with paragraph 9.
- Deletions should be limited to:
  - (i) highly market-sensitive material, mainly on the outlook for exchange rates, interest rates, the financial sector, and assessments of sovereign liquidity and solvency; and
  - (ii) material not in the public domain, on a policy the country authorities intend to implement, where premature disclosure of the operational details of the policy would, in itself, seriously undermine the ability of the member to implement those policy intentions.
- For purposes of this Decision, highly-market sensitive material shall mean material that:
  - (a) is not in the public domain,
  - (b) is market relevant within the near term, and
  - (c) is sufficiently specific to create a clear risk of triggering a disruptive market reaction if disclosed.
- Politically sensitive material shall not be deleted unless the material satisfies (i) or (ii) above.
- Information relating to any performance criterion or structural benchmark (Documents 1, 8 and 13-14), or to any quantitative targets or structural benchmark (Documents 17-18), or to any quantitative targets or reform targets (Documents 1, 20-22), may not be deleted, unless the information is of such character that would have enabled it to be communicated to the Fund in a side letter pursuant to Decision No. 12067-(99/108), September 22, 1999, as amended.
- If the Managing Director determines that the requested deletions satisfy criteria (i) or (ii) in paragraph 8(a), the Managing Director may decide that the deletions shall be accompanied by minor rephrasing of text, whenever such rephrasing would help retain maximum candor or minimize the risks of misinterpretation.
- Requests for deletions:
  - May be made by the member concerned.
  - Other members may request deletions to Documents 1-3, 8, 18 and 22 if (i) the text to be deleted relates to that other member, (ii) the member to whom the document relates consents to the deletion, and (iii) the criteria set out in paragraph 8 are met. Criterion (ii) does not apply to staff reports for Article IV consultation and regional surveillance discussions (Documents 1 and 2).
  - Shall be requested in writing.
  - Are expected to be communicated to the Fund no later than two business days before the Executive Board meeting at which the document is discussed (or the date of the adoption of a decision on a lapse-of-time basis to which the document relates).
  - Shall normally be made no later than (a) seven calendar days after the Executive Board has considered the document, or (b) twenty-one calendar days after the document was issued to the Executive Board, whichever is later.
  - Requests made after twenty-eight calendar days from Executive Board consideration will not be considered.
- Once approved by the Managing Director, deletions and related rephrasing shall be circulated to the Executive Board in redlined form and the modified document shall include the justification for each modification made.

#### II.C.2 Corrections (paragraphs 10–11)
- Corrections to Country Documents shall be limited to correction of:
  - (i) typographical errors,
  - (ii) data and other factual mistakes,
  - (iii) mischaracterization of views expressed by the authorities concerned, and
  - (iv) evident ambiguity.
- Corrections shall normally take the form of substitution of text in existing sentences rather than the addition or deletion of entire sentences.
- Timing for correction requests:
  - Expected no later than two business days before the conclusion of the Executive Board’s consideration of the document (or the date of the adoption of a decision on a lapse-of-time basis to which the document relates).
  - Normally no later than (a) seven calendar days after the Executive Board has considered the document, or (b) twenty-one calendar days after the document was issued to the Executive Board, whichever is later.
  - Requests for corrections made after twenty-eight calendar days from the Executive Board consideration will not be considered.
- Except for typographical errors and data/factual mistakes, corrections made after Executive Board consideration shall be limited to:
  - (i) cases where the correction request is brought to the attention of the Executive Board before the conclusion of the Executive Board’s consideration of the document, or
  - (ii) cases where the failure to make the correction would undermine the overall value of publication.
- Corrections shall be circulated to the Executive Board in redlined form. Corrections with significant implications for substance shall be discussed and justified in a supplementary staff report or a corrections memorandum to the Executive Board.

#### Additions to Authorities’ Views (paragraph 12)
- Additions may be made to the authorities’ views in staff reports for Article IV consultations, regional surveillance discussions, and Financial System Stability Assessment Reports (Documents 1, 3).
- Such additions shall be allowed with respect to views on main issues and policy recommendations covered in the staff report on which no authorities’ views were included when the report was issued to the Executive Board.
- Additions must be parsimonious and can only refer to information available to staff and the authorities at the time of the consultation discussions.
- Additions may be requested by the member to whom the document pertains and shall be issued to the Executive Board no later than two business days before the Executive Board meeting at which the document will be discussed (or the date of the adoption of a decision on a lapse-of-time basis to which the document relates).

### II.D. Press Releases in Respect of Use of Fund Resources or the Policy Coordination Instrument (paragraph 13)
- After the Executive Board:
  - (i) adopts a decision regarding a member’s use of Fund resources (including a decision completing a review under a Fund arrangement),
  - (ii) adopts a decision approving a PCI, or conducts a review under a PCI,
  - (iii) completes a discussion on a member’s participation in the HIPC Initiative, or
  - (iv) completes a discussion on a member’s I-PRSP, PRSP, PRSP preparation status report, APR, or PRGS in the context of the use of Fund resources,
  - a Press Release, which will contain a brief background section and a Chairman’s statement on the discussion, emphasizing the key points made by Executive Directors, will be issued to the public.
- A Press Release containing a Chairman’s statement will also be issued to the public after an SLL arrangement becomes effective.
- The Chairman’s statement will contain, where relevant, a summary of HIPC Initiative decisions and the Executive Board’s views on I-PRSP, PRSP, PRSP preparation status report, APR, or PRGS in the context of use of Fund resources.
- Waivers for nonobservance, or of applicability, of performance criteria, and any other matter as may be decided by the Executive Board from time to time (Document 24), will be mentioned in the Press Release or in a factual statement issued in lieu of a Chairman’s statement as provided for in paragraph 15(b).
- Consent to publication of a Press Release is deemed provided by the member on a non-objection basis unless, prior to the conclusion of the relevant Executive Board meeting (or the date of adoption of a decision on a lapse-of-time basis), the member notifies the Fund that it:
  - (i) objects to the publication of the Press Release; or
  - (ii) requires additional time to decide whether to publish the Press Release.
- A member can opt out of providing consent on a non-objection basis pursuant to paragraph 4(e). If a member opts out, publication of a Press Release pertaining to that member will require the explicit consent of the member.
- Before a Press Release is issued, it will, if any Executive Director so requests, be read by the Chairman to the Executive Board and Executive Directors will have an opportunity to comment.
- The Executive Director elected or designated by the member concerned will have the opportunity to review the Press Release and propose minor revisions immediately after the Executive Board meeting, or, in the case of the SLL, immediately after the SLL arrangement becomes effective.
- No Press Release published under this paragraph shall contain any reference to a discussion or decision pertaining to a member’s overdue financial obligations to the Fund where a Press Release following an Executive Board decision to limit the member’s use of Fund resources because of the overdue financial obligations has not yet been issued.
- In the case of an Executive Board meeting pertaining solely to a discussion or decision with respect to a member’s overdue financial obligations, no Chairman’s statement will be published.

### II.E. Press Releases for Article IV Consultations, Regional Surveillance Discussions or Stand-alone Executive Board Consideration of Financial System Stability Assessment Reports (paragraph 14)
- After completion of an Article IV consultation, a regional surveillance discussion, or a stand-alone Board consideration of an FSSA report, the Fund may issue a Press Release reporting on the results (Document 1 or Document 3).
- The Press Release will be brief and consist of:
  - (i) a background section (a draft of which should be attached to the staff report whenever possible). For Article IV or regional surveillance: factual information on the economy and a table of economic indicators. For stand-alone FSSA: factual information on the member’s financial system.
  - (ii) the Fund’s assessment: (a) the member’s prospects and policies for Article IV/regional surveillance; or (b) the stability of the financial system for stand-alone FSSA. This section will correspond closely to the Chairman’s summing up of the Executive Board discussion.
  - (iii) any press release published separately from the related staff report shall indicate a member’s publication intentions for the related staff report.
- Consent to publication of a Press Release is deemed provided by a member on a non-objection basis unless, prior to the conclusion of the relevant Executive Board meeting (or the date of adoption of a decision on a lapse-of-time basis), the member notifies the Fund that it:
  - (i) objects to the publication of the Press Release; or
  - (ii) requires additional time to decide whether to publish.
- A member may opt out as provided in paragraph 4(e). If a member opts out, publication of a Press Release pertaining to that member will require the member’s explicit consent.
- Such Press Releases are expected to be published no later than two business days after the Executive Board has considered the relevant document (or the date of adoption of a decision on a lapse-of-time basis).
- If a member has consented to publication of an Article IV consultation, regional surveillance discussion (Document 1) or a stand-alone FSSA report (Document 3), the Executive Director for the member may request publication of the Press Release within seven calendar days following the Executive Board’s consideration to allow time for finalization of the staff report.
- If a member has consented to the publication of Documents 1 or 3, such publication will be made along with the related Press Release. Publication of the staff report will require that the member also consents to the publication of the related Press Release.
- The Executive Director for the member concerned will have the opportunity to review the draft Press Release prior to issuance to propose corrections, deletions, rephrasing, additions and revisions to the background section; these should be parsimonious and notified to the Board prior to issuance.
- In combined Board considerations (e.g., Article IV with use of Fund resources, a PCI, or discussion of a PMB), a single Press Release covering these matters will normally be issued immediately after Board consideration; a Press Release will not be issued before circulation of the summing up as a Fund document.
- Issuance of Press Releases shall not affect the summing up process for Article IV consultations, regional surveillance discussions, or FSSA Board discussions; the Chairman’s summing up will continue to be provided to the Executive Director concerned for review following the Executive Board meeting.

### II.F. Non-publication of Country Documents—Issuance by the Fund of Factual Statements in Lieu (paragraph 15)
- A brief factual statement will be issued in the circumstances and within the time frames set forth in this paragraph 15.

a. Executive Board consideration of an Article IV consultation, a regional surveillance discussion, or an FSSA report:
- (i) Factual statement in lieu of Press Releases:
  - If a Press Release is not published (a) after two business days from the relevant Board consideration (or the adoption of a decision on a lapse-of-time basis), or (b) after seven calendar days from the relevant Board meeting (or adoption of a lapse-of-time decision) as provided for in paragraph 14(e), the Fund will issue a brief factual statement stating the fact of the Board’s consideration and indicating the member’s publication intention with respect to the relevant staff report.
- (ii) Factual statement in lieu of staff reports:
  - If, after fourteen calendar days from the relevant Board consideration (or adoption of a decision on a lapse-of-time basis) the member that made a request pursuant to paragraph 4 (b)(ii) or (iii) regarding its consent, objects to publication of the staff report, a brief factual statement will be issued immediately stating the fact of the Board’s consideration and that the member has not consented to publication.
  - If, within fourteen calendar days from the Board consideration (or after adoption of a lapse-of-time decision), a member requested more time and subsequently objects to publication, a brief factual statement will be issued after twenty-eight calendar days from the Board consideration (or adoption of a lapse-of-time decision) indicating the member’s decision not to publish the staff report.
- (iii) Factual statement in lieu of staff report for members that have opted out of non-objection procedure:
  - If a member has opted out and, after fourteen calendar days from the relevant Board consideration (or adoption of a lapse-of-time decision), has not consented to publication, a brief factual statement will be issued stating that the member has taken no publication decision with respect to the staff report.
  - No factual statement will be issued at such time if there are pending modification requests. If, after twenty-eight calendar days from the relevant Board consideration (or adoption of a lapse-of-time decision), a member has not communicated its decision on publication, a brief factual statement will be issued stating that the member has taken no publication decision with respect to the staff report.

b. Executive Board consideration of use of Fund resources, a PCI:
- (i) Factual statement in lieu of Press Releases:
  - If a member does not consent to the publication of a Press Release containing a Chairman’s statement (Documents 9 and 23) under paragraph 13 where one would be applicable, or if no Chairman’s statement has been issued because a decision was taken on a lapse-of-time basis, a brief factual statement will be issued immediately after the Board consideration describing the Executive Board’s decision relating to (a) that member’s use of Fund resources (including HIPC initiative decisions (Document 10), waivers (Document 24), and consideration of PRSP documents, and PRGSs (Document 12), when relevant), or (b) the approval of a PCI for that member, or the conduct of a review under that member’s PCI.
- (ii) Factual statement in lieu of staff reports:
  - If, after fourteen calendar days from the relevant Board consideration (or adoption of a lapse-of-time decision), the member objects to publication of the staff report, a brief factual statement will be issued immediately stating the fact of the Board’s consideration and that the member has not consented to publication.
  - If the member requested more time and subsequently objects, a brief factual statement will be issued immediately after twenty-eight calendar days from the Board consideration indicating the member’s decision not to publish the staff report.
- (iii) Factual statement in lieu of staff report for members that have opted out:
  - If a member has opted out and, after fourteen calendar days from the relevant Board consideration (or adoption of a lapse-of-time decision), has not consented to publication, a brief factual statement will be issued stating that the member has taken no publication decision with respect to the staff report.
  - No factual statement will be issued at such time if there are pending modification requests. If, after twenty-eight calendar days from the relevant Board consideration (or adoption of a lapse-of-time decision), a member has not communicated its decision on publication, a brief factual statement will be issued stating that the member has taken no publication decision with respect to the staff report.
- (iv) Factual statements in lieu of SLL staff report:
  - With respect to the consent provisions in paragraph 5(c), paragraphs 15(b)(ii) and 15(b)(iii) apply, except deadlines are calculated from the effective date of an SLL arrangement and the brief factual statement will state the fact of the effectiveness of an SLL arrangement and clarify the authorities’ publication intention with respect to the staff report.

c. Stand-alone post-financing assessment or ex-post evaluation:
- If after twenty-eight calendar days from the relevant Board consideration, a member does not consent to publication of a Press Release pertaining to the Board consideration, a brief factual statement will be issued stating the fact of the Board’s consideration.

d. Factual statement in lieu of staff report for other staff reports:
- For staff reports not mentioned under paragraphs 15(a)–(c), a brief factual statement will be issued in accordance with paragraphs 15(a)(ii) and 15(a)(iii).

*International Monetary Fund — 2024 REVIEW OF THE FUND’S TRANSPARENCY POLICY AND OPEN ARCHIVES POLICY—PROPOSED DECISIONS — excerpt*

### 16. After the Executive Board meets on Fund policy issues in a formal Board meeting or informal

### 16. After the Executive Board meets on Fund policy issues in a formal Board meeting or informal session, or adopts a decision on a lapse-of-time basis, it shall be presumed that the staff report under consideration (Document 25) and/or a Press Release (Document 27) pertaining to the consideration will be published.

### Publication presumption and scope (paras. 16, 22, 23, 25)
- Presumption: After Board consideration (formal meeting, informal session, or lapse-of-time adoption), it shall be presumed that the staff report under consideration (Document 25) and/or a Press Release (Document 27) pertaining to the consideration will be published (para. 16).
- Exceptions to presumption:
  - Policy issues dealing with administrative matters of the Fund are excluded from the presumption, except matters pertaining to the Fund’s income, financing or budget that do not involve market sensitive information (para. 16).
  - Documents on the Indicative List of Documents Covered by the Decision and Not Presumed to be Published (Appendix I) are excluded (para. 16).
- Executive Board decision required: Publication of a policy paper or Press Release requires a decision of the Executive Board; staff should recommend publication and explain any recommendation not to publish in the Secretary’s cover memorandum (para. 16).
- Timing: Except as specified in paragraph 18, whenever publication is approved, the paper and/or Press Release will normally be published promptly after an Executive Board meeting or an informal session, or date of adoption of a lapse-of-time decision to which the documents relate (para. 16).
- Informal session procedure: For documents prepared for an informal Executive Board session, publication will be deemed to have been approved by the Board unless an Executive Director objects by the date set forth in the Secretary’s cover memorandum (para. 16).
- Multilateral Policy Issues Documents: Publication and modification provisions in paras. 16-18 apply, except that paragraph 18 modification rules do not apply to the World Economic Outlook (WEO), the Global Financial Stability Report (GFSR) and the Fiscal Monitor (FM); staff may modify WEO, GFSR and FM prior to publication to take into account Board views (para. 22).
- Country Background Pages: Consent of the member concerned is required to publish such a document or material section (para. 23a). Publication will occur unless, prior to the conclusion of the Board meeting (or lapse-of-time adoption date), the member notifies the Fund that it: (i) objects to publication; (ii) requires additional time; or (iii) consents subject to reaching agreement on deletions; or opts out on a non-objection basis—if no notification, the document or section shall be published promptly (para. 23b).
- Cluster Documents: Consent of each member concerned is required for publication of the report and a Press Release; if one or more members object, the document will not be published (para. 25).

### Press Releases on Fund policy issues (paras. 17, 28)
- Basis and content:
  - A Press Release pertaining to Board consideration of Fund policy issues will be based on the decision adopted by the Executive Board and/or the Chairman’s summing-up, or the Chairman’s Concluding Remarks, as the case may be (para. 17).
  - It will also include a short section setting out background information (para. 17).
- Timing rules:
  - If a policy staff report is not expected to be published within seven calendar days of the Board consideration, a Press Release will be issued shortly after the Board consideration (para. 17).
  - For Cluster Documents:
    - A Press Release is expected to be published no later than two business days after the Executive Board has considered the document (or after adoption of a lapse-of-time decision), if members concerned consent (para. 28a).
    - Executive Director(s) for one or more members concerned may request that the Press Release be published within seven calendar days after the Board’s consideration to allow time for finalization of the Cluster Document (para. 28a).
    - Any Press Release published ahead of a Cluster Document will indicate the members’ publication intentions for such document and will not be issued before circulation of the summing up as a Fund document (para. 28a).
    - The Fund will issue a brief factual statement clarifying publication intention of members concerned in the circumstances and within the time periods specified in paragraph 15(a) (para. 28b).

### Corrections, deletions, modifications pre- and post-publication (paras. 18, 24, 27, 30, 31)
- Managing Director pre-publication authority:
  - Prior to publication of a Fund policy staff report, the Managing Director may make necessary factual corrections, deletions, and related rephrasing with respect to the report (including of highly market-sensitive material and country-specific references) (para. 18).
  - However, following Board consideration, staff’s proposals in the report shall not be modified prior to its publication (para. 18).
  - If differences between staff proposals and Executive Board conclusions could cause confusion, the published report will indicate which staff proposals the Executive Board did not endorse (para. 18).
- Member rights for deletions/corrections:
  - For Country Background Pages and Cluster Documents, members concerned have the right to request deletions or corrections in accordance with criteria and procedures applicable to Country Documents (paras. 24, 27).
  - For Article IV consultation and regional surveillance staff reports (Documents 1 and 2), specific modification rules and referral rights apply (para. 32b).
- Pre-publication removals (para. 30):
  - Before publication, remove: (i) references to unpublished Fund documents; (ii) references to certain internal processes not disclosed to public under existing policies, including inquiries regarding possible misreporting and breaches of members’ obligations; (iii) any discussion of a breach of obligation under Article VIII, Section 5 of the Articles of Agreement or misreporting proposed to be treated as de minimis in nature per Decision No. 13849-(06/108), December 20, 2006; and (iv) confidential information provided by a member or a third party (removal of confidential information requires Managing Director approval) (para. 30a).
  - For Country Documents with DSAs under the debt sustainability framework for market access countries, remove before publication if included in the DSA issued to the Board: (i) results of the near-term sovereign risk assessment; (ii) the mechanical signal for debt sustainability; (iii) any mention of whether debt is sustainable “with high probability” or sustainable “but not with high probability,” for Article IV consultations or for Fund arrangements where this qualification is not required for use of Fund resources under such arrangements; and (iv) the near-term risk analysis table, chart, and commentary (para. 30b).
- Post-publication modifications limited to exceptional circumstances:
  - After publication, Country Documents, Fund Policy Documents and Multi-Country Documents shall not be modified except if: (i) the published document does not correspond to the version considered by the Executive Board in material ways or lacks elements integral to the publication; or (ii) the published document, or part thereof, poses significant legal, reputational, or operational risks for the Fund (para. 31).

### Dispute resolution on modification requests (para. 32)
- Referral to Executive Board:
  - Serious disagreements between the Managing Director and a member regarding that member’s request for modification (paras. 8–12, 13(c), 14(g), 30(a)(iv)) may be referred to the Executive Board by the Managing Director or the Executive Director elected or designated by that member (para. 32a).
  - For Documents 1 and 2, if the Managing Director approves deletions requested by other members and the member to whom the document relates disagrees, the matter may be referred to the Executive Board by the Managing Director or that member’s Executive Director (para. 32b).
  - For serious disagreements among members concerned on Cluster Document deletion requests, the Managing Director shall propose a solution; if none acceptable, the Managing Director or Executive Directors elected or designated by the members concerned may refer the matter to the Executive Board (para. 32c).
  - If the Managing Director considers requested deletions would result in a document that would undermine the Fund’s overall assessment and credibility, the Managing Director shall recommend to the Executive Board that the document not be published (para. 32d).

### Administrative and procedural provisions (paras. 29, 33–38)
- Administrative errors (para. 29):
  - Rectification limited to: (i) document issued to the Executive Board not corresponding to version approved by management; or (ii) key elements necessary for Board consideration or lapse-of-time decision are missing or incomplete (para. 29a).
  - Rectification must be made before the Board’s consideration or the deadline to request a Board meeting for a lapse-of-time decision; the administrative error should be rectified at least two business days before the Board’s consideration or such deadline (para. 29b).
- Publication timing and means (paras. 33–34):
  - Documents may be published under this Decision only after their consideration by the Executive Board, except for documents circulated for information only including: (i) I-PRSPs, PRSPs, and PRGSs; and (ii) ROSCs and AFSSR Reports, which may be published immediately after circulation to the Executive Board (para. 33).
  - Publication shall normally mean publication on the Fund’s website but may include other media (para. 34).
- Article XII, Section 8 (para. 35):
  - This Decision does not limit the Fund’s power under Article XII, Section 8 of the Articles of Agreement to decide by a seventy percent majority of the total voting power to publish a member report regarding monetary or economic conditions that directly tend to produce a serious disequilibrium in the international balance of payments of members (para. 35).
- Non-members and third-party documents (paras. 36–37):
  - For documents pertaining to a country not a Fund member, references to “member” mean “country,” and references to “Executive Director elected or designated by that member” refer to appropriate authorities of the country concerned (para. 36).
  - Documents prepared by other institutions and required for Board consideration will be published together with the related staff report in the version considered by the Board, provided the staff report is published, there is no objection from the producing institution, and the Board has not decided against publication of that category; such documents do not require member consent and are not subject to the Decision’s modification rules, and may not be modified after Board consideration (para. 37).
- Review provision: This Decision is expected to be reviewed in light of experience in five years or more, as needed (para. 38).

*Source: Excerpt from the Transparency Policy Decision (paras. 16–38) and Appendix I as provided in the content unit.*

### 5.   Stand-alone Debt Sustainability Analysis reports

### 5.   Stand-alone Debt Sustainability Analysis reports

### B. Use of Fund Resources Documents — enumerated items
- 6. Documents prepared for informal Board briefings for countries with excessively delayed Article IV consultations or mandatory financial stability assessments
- 7. Joint Fund/World Bank Staff Advisory Notes (JSANs) on Interim Poverty Reduction Strategy Papers (I-PRSPs), Poverty Reduction Strategy Papers (PRSPs), PRSP Preparation Status Reports, RSP Annual Progress Reports (APRs), and Poverty Reduction Growth Strategy Papers (PRGS)
- 8. Staff Reports for Use of Fund Resources, Post-Financing Assessments, Ex-Post Peer-Reviewed Assessments (PRAs), and Ex-Post Evaluations of exceptional access arrangements (excluding staff reports dealing solely with a member’s overdue financial obligations to the Fund)
- 9. Press Releases containing a Chairman’s Statement for Use of Fund Resources
- 10. Preliminary, decision point, and completion point documents under the Heavily Indebted Poor Countries Initiative
- 11. Press Releases following Executive Board discussions on Post-Financing Assessment, PRAs or Ex-Post Evaluations of exceptional access arrangements (excluding staff reports dealing solely with a member’s overdue financial obligations to the Fund)
- 12. I-PRSPs, PRSPs, PRSP Preparation Status Reports and APRs and PRGSs
- 13. Letters of Intent (LOIs), Written Communications from authorities, and Memoranda of Economic and Financial Policies (MEFPs)
- 14. Technical Memoranda of Understanding (TMUs)
- 15. Staff Notes on preliminary evaluation of high and/or exceptional access
- 16. Overdue Financial Obligations Documents

### C. Staff Monitored Program (SMP) and Program Monitoring with Board Involvement (PMBs) Documents
- 17. LOIs/MEFPs for SMPs and Program Monitoring with Board Involvement (PMBs)
- 18. Stand-alone Staff Reports on SMPs and PMBs
- 19. Press Releases following Executive Board discussions on PMBs

### D. Policy Coordination Instrument (PCI) Documents
- 20. Program Statements for PCIs
- 21. Technical Memoranda of Understanding (TMUs)
- 22. Staff Reports for PCIs
- 23. Press Releases containing a Chairman’s Statement for PCIs

### E. Statements on Fund Decisions
- 24. Statements on Fund decisions on waivers of applicability, or for nonobservance, of performance criteria, and any other matter as may be decided by the Executive Board from time-to time

### II. Fund Policy Documents
- 25. Fund Policy Issues Papers
- 26. Background papers to Fund Policy Papers
- 27. Press Releases following Executive Board consideration of policy issues
- 28. Internal Fund Administrative Documents
- 29. Stand-alone Enterprise Risk Assessments (ERA)

### III. Multi-Country Documents
- 30. Multilateral Policy Issues Documents such as the World Economic Outlook, the Global Financial Stability Report, the Fiscal Monitor
- 31. Other Multilateral Policy Issues Documents such as External Sector Reports and Spillover Reports
- 32. Press Releases following Executive Board consideration of Multilateral Policy Issues
- 33. Country Background Pages
- 34. Press Releases following Executive Board consideration of Country Background Pages
- 35. Cluster Documents
- 36. Press Releases following Executive Board consideration of Cluster Documents

### Indicative List — Documents Not Presumed to be Published (“Negative List”)
- 1. Internal Fund Administrative Documents
- 2. Documents prepared for informal Board briefings for countries with excessively delayed Article IV consultations or mandatory financial stability assessments
- 3. Staff Notes on preliminary evaluation of high and/or exceptional access
- 4. Overdue Financial Obligations Documents
- 5. Stand-alone Enterprise Risk Assessments (ERA)

### Attachment II. Archives Policy — access rules and exceptions
- 1. Outside persons, on request, will be given access under the terms specified in this Decision to the archived permanent records of the Fund.
- 2. Access will be given as follows:
  - (i) Executive Board documents that are over 3 years old, with the exception of Executive Board documents discussing cyber and physical security vulnerabilities of the Fund, to which access will be given after 20 years;
  - (ii) Minutes of Executive Board meetings that are over 3 years old, with the exception of Minutes of Executive Board meetings discussing a member’s use of (i) the Fund’s resources, (ii) the Policy Support Instrument, and (iii) the Policy Coordination Instrument, to which access will be given after 5 years, and Minutes of Executive Board meetings discussing cyber and physical security vulnerabilities of the Fund, to which access will be given after 20 years;
  - (iii) BUFF Statements by the Managing Director or Fund Staff to the Executive Board, BUFF/EDs, Gray Documents, and Green Documents that are over 3 years old, with the exception of such documents discussing a member’s use of (i) the Fund’s resources, (ii) the Policy Support Instrument, and (iii) the Policy Coordination Instrument, to which access will be given after 5 years, and such documents discussing cyber and physical security vulnerabilities of the Fund, to which access will be given after 20 years;
  - (iv) Précis of Executive Board Meetings (replaced by weekly Précis and weekly Decisions Report), Executive Board Seminars Agendas and Minutes, Secretary’s Journal of Executive Board Informal Session Minutes, and Executive Board Committee Minutes that are over 5 years old; and
  - (v) other archived permanent records of the Fund that are over 20 years old.
- 3. Access to Fund documents specified in paragraph 2 above that are classified as “Secret” or “Strictly Confidential” as of the date of this Decision will be granted only upon the Managing Director’s consent to their declassification. It is understood that this consent will be granted in all instances but those for which, despite the passage of time, it is determined that the material remains highly confidential or sensitive.
- 4. Executive Board documents covered by Decision No. 15420-13/61, adopted June 24th, 2013, as amended, on the Fund’s Transparency Policy, that are classified as “Strictly Confidential” after the date of this Decision will be automatically declassified when the respective time periods specified in paragraph 2 have elapsed, unless at the time of their initial classification as “Strictly Confidential, the authoring department specifies that the document in question shall not be subject to automatic declassification. If a specification is made that a document shall not be subject to automatic declassification, paragraph 3 of this Decision shall apply to the declassification of that document.
- 5. Access to the following archived permanent records will not be granted: (a) legal documents and records maintained by the Legal Department that are protected by attorney-client privilege; (b) archived permanent records furnished to the Fund by external parties, including member countries, their instrumentalities and agencies and central banks, that bear confidentiality markings, unless such external parties consent to their declassification; (c) personnel files and medical or other records pertaining to individuals; and (d) documents and proceedings of the Grievance Committee.
- 6. In exceptional circumstances, when the Managing Director determines that it is in the interest of the Fund, access to other archived permanent records referred to in paragraph 2(v) above may be granted upon request prior to the expiration of the 20 year period applicable to such records.
- 7. To enable easier and wider public access to the archived permanent records of the Fund, they may be made available through a variety of means including a catalogue published on the Fund’s external website. Accordingly, a “request” under paragraphs 1 and 6 of this Decision may be made orally in person at Fund Headquarters or by telephone; in writing by hardcopy or electronic means such as e-mail or facsimile; or through a portal of the catalogue. Requested material may also be conveyed to the public by hardcopy, electronic means and other web-based modalities. Without prejudice to access that will be given pursuant to paragraph 2(i) above, from the date of effectiveness of this Decision all Executive Board documents published by the Fund earlier shall be made available to the public through the catalogue on the Fund’s external website.
- 8. Since the Board’s approval of the Policy on Access to Fund Archives in 1996, staff has continued to follow the long-standing policy of requesting Board consent for ad hoc exceptions to the policy on behalf of external researchers. A reasonable cost recovery scheme may be maintained for administering ad hoc requests for Board approval of exceptions to the terms specified under this Decision. No charge shall be assessed for requests received from government officials of member countries.
- 9. Decision No. 11192-(96/2), January 17, 1996, as amended, on the opening of the Archives and Decision No. 12981-(03/34), April 9, 2003 on Review of the Policy on Access to the Fund’s Archives are repealed.
- 10. This Decision is expected to be reviewed by the Executive Board at regular intervals in tandem with the regular reviews of the Fund’s Transparency Policy, Decision No. 15420-(13/61), adopted June 24, 2013, as amended.

*Source: ppea2024057 - 5.   Stand-alone Debt Sustainability Analysis reports (excerpts).*

### 4. a. The Managing Director will not recommend that the Executive Board approve (i) an

### ppea2024057 - 4. a. The Managing Director will not recommend that the Executive Board approve (i) an

### Publication consent and conditional approvals
- Paragraph 4.a: The Managing Director will not recommend that the Executive Board approve (i) an arrangement under the Poverty Reduction and Growth Trust (PRGT) or completion of a review under such arrangement, or (ii) a Heavily Indebted Poor Countries (HIPC) decision point or completion point decision, or (iii) a member’s request for a PSI or the completion of a review under a PSI, if the member concerned does not explicitly consent to the publication of its Interim Poverty Reduction Strategy Paper (I-PRSP), Poverty Reduction Strategy Paper (PRSP), PRSP preparation status report, PRSP annual progress report (APR), Economic Development Document (“EDD”) or Poverty Reduction and Growth Strategy (PRGS) (Document 10 or Document 15, as the case may be).
- Paragraph b.5.a: The Managing Director will generally not recommend that the Executive Board approve a request for (i) access to resources in the General Resources Account, the PRGT or the Resilience and Sustainability Trust, or (ii) access to Fund resources under the HIPC Trust, or (iii) assistance through a PSI or athe PCI, unless thatthe member explicitly consents to the publication of the associated staff report.
  - For purposes of this paragraph 4(b5(a), approval of the use of the Fund’s resources includes the completion of a review under an arrangement, and assistance through a PSI or a PCI includes the completion of a review under the PSI or thea PCI.
  - In the case of the PCI, where a member does not provide consent to publication of an interim performance update, the Managing Director may take this into account when determining whether to recommend that the Executive Board approve the completion of a subsequent review of the member’s PCI.
- Paragraph b (repeated): The Managing Director will not recommend that the Executive Board approve (i) an arrangement under the Poverty Reduction and Growth Trust (PRGT) or the completion of a review under such arrangement, or (ii) a Heavily Indebted Poor Countries (HIPC) decision point or completion point decision, if the member concerned does not explicitly consent to the publication of its Interim Poverty Reduction Strategy Paper (I-PRSP), Poverty Reduction Strategy Paper (PRSP), PRSP preparation status report, PRSP annual progress report (APR), or Poverty Reduction and Growth Strategy (PRGS) (Document 12).
- Paragraph c: Approval of a Short-Term Liquidity Line (SLL) arrangement is conditioned on receipt of the member’s consent to publication at the time the member sends a written communication to the Fund confirming the member wishes to avail itself of the SLL arrangement.
  - The associated staff report and the authorities’ written communication would be expected to be published by the Fund no later than fourteen calendar days after the member’s SLL arrangement becomes effective.

### Communication of consent and member statements
- Paragraph 56: Except as provided in paragraphs 1113 and 12, 14 of this Decision, a member’s explicit consent shall, for the purposes of this Decision, be communicated to the Fund in writing, normally to the Secretary of the Fund. Such consent may be communicated by the Executive Director elected, appointed, or designated by the member.
- Paragraph 67: If a Fund staff report (Documents 1, 6, 14 5, 8,18 and 1922) on a member is to be published under this Decision, the member concerned shall be given the opportunity to provide a statement regarding the staff report and the Executive Board assessment. Such a statement shall be communicated to the Fund and published together with the staff report.

### Modifications, deletions, and rephrasing in country documents
- Section II.C / 7.II.C.1: Deletions
  - Paragraph 8.a: For purposes of publication, deletions may be made to Country Documents, except for country policy intention documents on poverty reduction strategies (Documents 10 and 15Document 12), in accordance with paragraph 8 below9 of this Decision.
    - Deletions should be limited to: (i) ighlyhighly market-sensitive material, mainly on the outlook for exchange rates, interest rates, the financial sector, and assessments of sovereign liquidity and solvency; and (ii) material not in the public domain, on a policy the country authorities intend to implement, where premature disclosure of the operational details of the policy would, in itself, seriously undermine the ability of the member to implement those policy intentions.
    - Definition: For purposes of this Decision, highly-market sensitive material shall mean material that (a) is not in the public domain, (b) is market relevant within the near term, and (c) is sufficiently specific to create a clear risk of triggering a disruptive market reaction if disclosed.
    - Politically sensitive material shall not be deleted unless the material satisfies (i) or (ii) above.
    - Information relating to any performance criterion or structural benchmark (Documents 1, 68 and 11-1213-14), or to any quantitative targets or structural benchmark (Documents 13-1417-18), or to any assessment criterionquantitative targets or structural benchmarkreform targets (Documents 1, and 17-191, 20-22), may not be deleted, unless the information is of such character that would have enabled it to be communicated to the Fund in a side letter pursuant to Decision No. 12067-(99/108), September 22, 1999., as amended.
  - Paragraph 8.b: If the Managing Director determines that the proposedrequested deletions satisfy criteria (i) or (ii) in paragraph 78 (a), the Managing Director may decide that the deletions shall be accompanied by minor rephrasing of text, whenever such rephrasing would help retain maximum candor or minimize the risks of misinterpretation.
- Paragraphs 89.a–d: Procedures for requesting and approving deletions
  - Requests for deletions to a Country Document, except for country policy intentions documents on poverty reduction strategies (Documents 10 and 1512) may be made by the member concerned.
  - Other members may request deletions to Documents 1-3,    6, 14,8, 18 and 1922, if (i) the text to be deleted relates to that other member, (ii) the member to whom the document relates consents to the deletion, and (iii) the criteria set out in paragraph 78 are met.
    - Criterion (ii) shall not apply to staff reports for Article IV consultation and regional surveillance discussions (Documents 1 and 2).
  - Deletions shall be requested in writing and are expected to be communicated to the Fund no later than two business days before: (i) the Executive Board meeting at which the document is discussed (or (ii) the date of the adoption of a decision on a lapse-of-time basis to which the document relates.).
  - Requests for deletions shall normally be made no later than (a) seven calendar days after the Executive Board has considered the document, or (b) twenty-one calendar days after the document was issued to the Executive Board, whichever is later.
  - Requests for deletions made after twenty-eight calendar days from Executive Board consideration will not be considered.
  - Once approved by the Managing Director, deletions and related rephrasing shall be circulated to the Executive Board in redlined form and include the justification for each modification.
  - Dispute resolution procedures:
    - (i) In case of a serious disagreement between the Managing Director and a member regarding that member’s request for deletions, the matter may be referred to the Executive Board by the Managing Director or the member’s Executive Director.
    - (ii) For staff reports for Article IV consultation and regional surveillance discussion (Documents 1 and 2), if the Managing Director approves deletions requested by other members and the member to whom the document relates disagrees, the matter may be referred to the Executive Board.
    - (iii) If the Managing Director believes the requested deletions would result in a document that, if published, would undermine the overall assessment and credibility of the Fund, the Managing Director shall recommend to the Executive Board that the document not be published.

### Corrections to country documents
- Section II.C.2 / 9–11: Corrections
  - Corrections shall be limited to correction of (i) data and typographical errors, (ii) data and other factual mistakes, (iii) mischaracterization of views expressed by the authorities concerned, and (iv) evident ambiguity.
  - Corrections shall normally take the form of substitution of text in existing sentences rather than the addition or deletion of entire sentences.
  - Timing for correction requests:
    - Expected no later than two business days before the conclusion of the Executive Board’s consideration of the document (or the date of the adoption of a decision on a lapse-of-time basis to which the document relates.).
    - Requests shall normally be made no later than (a) seven calendar days after the Executive Board has considered the document, or (b) twenty-one calendar days after the document was issued to the Executive Board, whichever is later.
    - Requests for corrections made after twenty-eight calendar days from the Executive Board consideration will not be considered.
    - Except for typographical errors and data and other factual mistakes, corrections made after Executive Board consideration shall be limited to (i) cases where the correction request is brought to the attention of the Executive Board before the conclusion of the Executive Board’s consideration of the document, or (ii) cases where the failure to make the correction would undermine the overall value of publication.
  - Corrections shall be circulated to the Executive Board in redlined form. Corrections with significant implications for substance shall be discussed and justified in a supplementary staff report or in a corrections memorandum.

### Additions to authorities’ views
- Paragraph 12: Additions may be made to the authorities’ views in staff reports for Article IV consultations, regional surveillance discussions, and Financial System Stability Assessment Reports (Documents 1, 3).
  - Additions allowed only with respect to views on main issues and policy recommendations covered in the staff report on which no authorities’ views were included when the report was issued.
  - Additions shall be parsimonious and can only refer to information available to staff and the authorities at the time of the consultation discussions.
  - Additions may be requested by the member to whom the document pertains and shall be issued to the Executive Board no later than two business days before the Executive Board meeting at which the document will be discussed (or the date of the adoption of a decision on a lapse-of-time basis to which the document relates).

### Press releases related to Fund resource use, PSI, PCI, HIPC, and SLL
- Paragraph 13 / 11a: After the Executive Board (i) adopts a decision regarding a member’s use of Fund resources (including a decision completing a review under a Fund arrangement), or (ii) adopts a decision approving a PSI or a PCI, or conducts a review under a PSI or a PCI, or (iii) completes a discussion on a member’s participation in the HIPC Initiative, or (iv) completes a discussion on a member’s I-PRSP, PRSP, PRSP preparation status report, APR, EDD, or PRGS in the context of the use of Fund resources or a PSI, a Press Release, which will contain a brief background section and a Chairman’s statement on the discussion, emphasizing the key points made by Executive Directors, will be issued to the public.
  - A Press Release containing a Chairman’s statement will also be issued to the public after an SLL arrangement becomes effective.
- Paragraph 13.b: Where relevant, the Chairman’s statement will contain a summary of HIPC Initiative decisions pertaining to the member and the Executive Board’s views on the member’s I-PRSP, PRSP, PRSP preparation status report, APR, EDD or PRGS in the context of use of Fund resources or a PSI.
  - Waivers for nonobservance, or of applicability, of performance criteria, and any other matter as may be decided by the Executive Board from time to time (Document 21), and waivers for nonobservance of assessment criteria, and any other matter as may be decided by the Executive Board from time-to-time (Document 22), will be mentioned in the Press Release or in a factual statement issued in lieu of a Chairman’s statement as provided for in paragraph 13(b).15(b) of this Decision.
- Paragraph 13.c: Consent to publication of a Press Release is deemed to be provided by the member concerned on a non-objection basis unless, prior to the conclusion of the relevant Executive Board meeting (or the date of adoption of a decision on a lapse-of-time basis) on the matter to which the Press Release pertains, the member notifies the Fund that it: (i) objects to the publication of the Press Release; or (ii) requires additional time to decide whether to publish the Press Release.
  - A member can opt out of providing consent to publication of a Press Release on a non-objection basis pursuant to the procedures set forth in paragraph 4(e) of this Decision. If a member opts out, the publication by the Fund of a Press Release pertaining to that member will require the explicit consent of the member.
  - Before a Press Release is issued, it will, if any Executive Director so requests, be read by the Chairman to the Executive Board and Executive Directors will have an opportunity to comment at that time.
  - The Executive Director elected, appointed, or designated by the member concerned will have the opportunity to review the Chairman’s statement,Press Release and to propose minor revisions, if any, and to consent to its publication immediately after the Executive Board meeting, or, in the case of the SLL, immediately after the SLL arrangement becomes effective.
- Paragraph 13.d: No Press Release published under this paragraph shall contain any reference to a discussion or decision pertaining to a member’s overdue financial obligations to the Fund, where a Press Release following an Executive Board decision to limit the member’s use of Fund resources because of the overdue financial obligations has not yet been issued.
  - In the case of an Executive Board meeting pertaining solely to a discussion or decision with respect to a member’s overdue financial obligations, no Chairman’s statement will be published.

*ppea2024057 - 4. a. The Managing Director will not recommend that the Executive Board approve (i) an*

### 1214.    a.

### 1214.    a.

### Press Releases for Article IV Consultations, Regional Surveillance Discussions, and FSSA Board Considerations
- The Fund may issue a Press Release reporting on the results of:
  - an Article IV consultation for a member, or
  - a regional surveillance discussion, or
  - a stand-alone Board consideration of an FSSA report.
- If a member has consented to the publication of Documents 1 and/or 3, such publication will be made along with the publication of a Press Release.
- A Press Release will be brief (normally 3-4 pages) and will consist of two the following sections:
  - (i) a background section, a draft of which should be attached to the staff report whenever possible, with:
    - (a) in the case of an Article IV consultation or a regional surveillance discussion, factual information on the economy of a member and a table of economic indicators, and
    - (b) in the case of a stand-alone Board consideration of an FSSA report, factual information on the member’s financial system; and
  - (ii) the Fund’s assessment of:
    - (a) the member’s prospects and policies in the case of an Article IV consultation or a regional surveillance discussion, and
    - (b) the stability of the financial system in the case of a stand-alone Board consideration of an FSSA report.
  - This assessment section will correspond closely to the Chairman’s summing up of the Executive Board discussion.
- Any press release published separately from the related staff report shall indicate a member’s publication intentions for the related staff report.

### Consent, Review, and Issuance Timing
- Consent mechanism:
  - Consent to publication of a Press Release is deemed to be provided by a member on a non-objection basis unless, prior to the conclusion of the relevant Executive Board meeting (or the date of the adoption of a decision on a lapse-of-time basis) on the matter to which the Press Release pertains, the member notifies the Fund that it:
    - (i) objects to the publication of the Press Release; or
    - (ii) requires additional time to decide whether to publish.
  - A member may opt out of providing consent to publication of a Press Release on a non-objection basis as provided for in paragraph 4(e) of this Decision. If a member opts out, the publication of a Press Release pertaining to that member by the Fund will require the member’s explicit consent.
- Timing:
  - Such Press Releases are expected to be published no later than two business days after the Executive Board has considered the relevant document (or the date of the adoption of a decision on a lapse-of-time basis on the matter to which the press release pertains).
  - If the Executive Director for the member concerned requests, and the member has consented to publication of the Article IV/regional/FSSA document, the Press Release may be published within seven calendar days following the Executive Board’s consideration to allow time for finalization of the staff report.
- Interplay with staff report publication:
  - If a member has consented to the publication of Documents 1 or 3, such publication will be made along with the publication of the related Press Release. Publication of the staff report will require that the member also consents to the publication of the related Press Release.
- Executive Director review and modifications:
  - The Executive Director for the member concerned will have the opportunity to review the draft Press Release prior to its issuance to propose changes, if any, consistent with paragraphs 7 through 10, with respect to the background section: necessary corrections, deletions, and related rephrasing. The Executive Director may also propose additions and revisions to the background section beyond the above.
  - In case of a serious disagreement between the Managing Director and the Executive Director concerned on the draft, either may request the Executive Board to consider the matter.
  - Additions and revisions to better reflect wording in related staff reports and associated documents should be parsimonious and be notified to the Board prior to issuance of the Press Release.
- Combined Board considerations:
  - In a case of a combined Board consideration of an Article IV consultation with use of Fund resources, a PCI, or the discussion of a PSI/PMB, a single Press Release covering these matters will normally be issued immediately after the Board consideration.
  - A Press Release under this paragraph will not be issued before the circulation of the summing up as a Fund document.
- Separation from summing up process:
  - Issuance of Press Releases shall not affect the summing up process. The Chairman’s summing up will continue to be provided to the Executive Director concerned for review following the Executive Board meeting, and Press Releases shall not affect staff reporting to the Executive Board on discussions with members.

### Non-publication of Press Releases and Issuance of Brief Factual Statements (Paragraph 1315 / 15)
- General rule:
  - A brief factual statement will be issued in the circumstances and within the time frames set forth in paragraph 1315.
- With respect to Executive Board consideration of an Article IV consultation, a regional surveillance discussion, an FSSA report, a post-program monitoring, an ex post assessment or an ex post evaluation:
  - (i) Factual statement in lieu of Press Releases:
    - If, after twenty-eight calendar days from the relevant Board consideration, a member does not consent to the publication of a Press Release pertaining to the Board consideration, a brief factual statement will be issued stating the fact of the Board’s consideration of the matter and indicating the member’s publication intention with respect to the relevant staff report.
    - If a document is not published (a) after two business days from the relevant Board consideration (or the adoption of a decision on a lapse-of-time basis) to which the document relates, or (b) after seven calendar days from the relevant Board meeting (or the adoption of a decision on a lapse-of-time basis to which the document relates) as provided for in paragraph 14(e) of this Decision, the Fund will issue a brief factual statement stating the fact of the Board’s consideration of the matter and indicating the member’s publication intention with respect to the relevant staff report.
  - (ii) If, after twenty-eight calendar days from the relevant Board consideration, the staff report has not been published, a brief factual statement will be issued stating the fact of the Board’s consideration of the matter and clarifying the authorities’ publication intention with respect to the staff report.
  - (ii) Factual statement in lieu of staff reports (procedure for objections and delays):
    - If, after fourteen calendar days from the relevant Board consideration (or the adoption of a decision on a lapse-of-time basis to which the document relates) the member that made a request pursuant to paragraph 4 (b)(ii) or (iii) objects to the publication of the staff report, a brief factual statement will be issued immediately stating the fact of the Board’s consideration of the matter and that the member has not consented to the publication of the staff report.
    - If, within fourteen calendar days from the Board consideration (or after the adoption of a decision on a lapse-of-time basis to which the document relates), a member has requested more time to decide on publication and subsequently objects to publication, a brief factual statement will be issued after twenty-eight calendar days from the Board consideration (or the adoption of a decision on a lapse-of-time basis) indicating the members’ decision not to publish the staff report.
  - (iii) Factual statement in lieu of staff report for members that have opted out of non-objection procedure:
    - If a member has opted out of providing consent to publication of the staff report on a non-objection basis, and, after fourteen calendar days from the relevant Board consideration (or the date of the adoption of a decision on a lapse-of-time basis to which the document relates), has not consented to its publication, a brief factual statement will be issued stating that the member has taken no publication decision with respect to the staff report.
    - No factual statement will be issued at such time if there are pending modification requests. If, after twenty-eight calendar days from the relevant Board consideration (or the adoption of a decision on a lapse-of-time basis to which the document relates), a member has not communicated to the Fund its decision on publication, a brief factual statement will be issued stating that the member has taken no publication decision with respect to the staff report.
- With respect to the Executive Board’s consideration of use of Fund resources, a PCI, or a PSI:
  - (i) Factual statement in lieu of Press Releases:
    - If a member does not consent to the publication of a Press Release containing a Chairman’s statement (Documents 79 and 2023) under paragraph 1113 of this Decision where one would be applicable, or if no Chairman’s statement has been issued because a decision was taken on a lapse-of-time basis, a brief factual statement will be issued immediately after the Board consideration.
    - The factual statement will describe the Executive Board’s decision relating to:
      - (a) that member’s use of Fund resources (including HIPC initiative decisions (Document 810), waivers (Document 2124), and consideration of PRSP documents, EDDs and PRGSs (Document 1012), when relevant), or
      - (b) the approval of a PSI or a PCI for that member, or the conduct of a review under that member’s PSI or PCI (including waivers (Document 22) and consideration of PRSP documents, EDDs and PRGSs (Document 15), when relevant).
  - (ii) Factual statement in lieu of staff reports (consent provisions):
    - If, after twenty-eight four fourteen calendar days from the relevant Board consideration (or the adoption of a decision on a lapse-of-time basis to which the document relates), the member objects to the publication of the staff report has not been published, a brief factual statement will be issued immediately stating the fact of the Board’s consideration of the matter and clarifying that the member has not consented to the publication of the staff report.
    - If, within fourteen calendar days from the Board consideration (or after the adoption of a decision on a lapse-of-time basis to which the document relates), a member has requested more time to decide on publication and subsequently objects to publication, a brief factual statement will be issued immediately after twenty-eight calendar days from the Board consideration indicating the members’ decision not to publish the staff report.
  - (iii) Factual statement in lieu of staff report for members that have opted out of non-objection procedure:
    - If a member has opted out of providing consent to the publication of staff reports on a non-objection basis, and, after fourteen calendar days from the relevant Board consideration (or the date of the adoption of a decision on a lapse-of-time basis to which the document relates), has not consented to its publication, a brief factual statement will be issued stating that the member has taken no publication decision with respect to the staff report.
    - No factual statement will be issued at such time if there are pending modification requests. If, after twenty-eight calendar days from the relevant Board consideration (or the date of the adoption of a decision on a lapse-of-time basis to which the document relates), a member has not communicated to the Fund its decision on publication, a brief factual statement will be issued stating that the member has taken no publication decision with respect to the staff report.
  - (iii)(iv) Factual statements in lieu of SLL staff report:
    - With respect to the consent provisions set forth in paragraph 5(c), paragraphs 15(b)(ii) and 15(b)(iii) shall apply, except that the deadlines will be calculated from the effective date of an SLL arrangement, and if the staff report has not been published, a brief factual statement will be issued stating the fact of the effectiveness of an SLL arrangement for a member and clarifying the authorities’ publication intention with respect to the staff report.
- With respect to Executive Board consideration of a stand-alone post-financing assessment, or an ex-post evaluation:
  - If after twenty-eight calendar days from the relevant Board consideration, a member does not consent to the publication of a Press Release pertaining to the Board consideration, a brief factual statement will be issued stating the fact of the Board’s consideration of the matter.
- Factual statement in lieu of staff report for other staff reports:
  - With respect to Executive Board consideration of a staff report not mentioned under paragraphs 15(a) to (c), a brief factual statement will be issued in accordance with the provisions set forth in paragraphs 15(a)(ii) and 15(a)(iii).

### Fund Policy Documents — Authorization, Press Releases, and Corrections
- Authorization and presumption of publication:
  - After the Executive Board meets on Fund policy issues in a formal Board meeting or informal session, or adopts a decision on a lapse-of-time basis, it shall be presumed that the staff report under consideration (Document 2325) and/or a Press Release (Document 2427) pertaining to the consideration will be published.
  - The presumption will not apply to policy issues dealing with the administrative matters of the Fund, (except with respect to matters pertaining to the Fund’s income, financing or budget matters that do not involve market sensitive information.) and other documents on the Indicative List of Documents Covered by the Decision and Not Presumed to be Published (Appendix I to this Decision).
  - Publication of a policy paper or Press Release will require a decision of the Executive Board. Staff is expected to set out a recommendation on publication of a Board policy paper and/or its related Press Release in the Secretary’s cover memorandum and, where publication is not recommended, to explain why.
  - Except as specified in paragraph 15 below18 of this Decision, whenever publication is approved, the paper and/or Press Release will normally be published promptly after an Executive Board meeting or an informal session, or date of adoption of a lapse-of-time decision to which the documents relate.
  - For papers or Press Releases prepared for an informal Executive Board session, publication will be deemed approved unless an Executive Director objects by the date set forth in the Secretary’s cover memorandum.
- Press Releases on Fund policy issues:
  - A Press Release pertaining to Board consideration of Fund policy issues will be based on the decision adopted by the Executive Board and/or the Chairman’s summing-up, or the Chairman’s Concluding Remarks, as the case may be, and will include a short background section.
  - If a policy staff report is not expected to be published within seven calendar days of the Board consideration, a Press Release will be issued shortly after the Board consideration.
- Corrections, deletions, and related rephrasing:
  - Prior to publication of a Fund policy staff report, the Managing Director may make necessary factual corrections, deletions, and related rephrasing with respect to the report (including of highly market-sensitive material and country-specific references).
  - However, following Board consideration, staff’s proposals in the report shall not be modified prior to its publication.
  - Where confusion might arise from differences between staff’s proposals in the report and the Executive Board’s conclusions as reflected in the Press Release, the published version of the report will clearly indicate which staff proposals the Executive Board did not endorse.

### Multi-Country Documents — Coverage and Publication Rules
- Definitions:
  - Multi-Country Documents comprise:
    - (i) Multilateral Policy Issues Documents,
    - (ii) Country Background Pages, and
    - (iii) Cluster Documents.
  - Multilateral Policy Issues Documents address multilateral global economic issues.
  - Country Background Pages are characterized by specific information pertaining to individual countries and to individual country data but the analysis of respective individual countries and individual country data is not integrated.
  - Cluster Documents include analysis of issues affecting a group of countries where each individual country analysis is integrated into the broader analysis.
- Scope:
  - Multi-Country Documents pertain to both individual documents and material sections within individual documents. Material sections shall mean whole chapters or appendices.
  - A single Multi-Country Document may comprise (i) a Multilateral Policy Issues Document, (ii) a Country Background Pages, (iii) a Cluster Document, or (iv) some combination of the above.
- Publication procedures:
  - For Multi-Country Documents, the Secretary’s cover memorandum will indicate the publication rules governing the document.
  - The provisions applicable to the publication of Fund policy staff reports and Press Releases set forth in paragraphs 14-15 16-17 of this Decision shall apply to Multilateral Policy Issues Documents and Press Releases for Multilateral Policy Issues Documents.
  - Paragraph 16 18 regarding modification rules for Fund policy staff reports shall apply to all Multilateral Policy Issues Documents, except for the World Economic Outlook (WEO), the Global Financial Stability Report (GFSR) and the Fiscal Monitor (FM).
  - In accordance with established practice, staff may modify the WEO, GFSR and FM prior to publication in order to, inter alia, take into account views expressed at the relevant Executive Board meeting.

*Source: ppea2024057 - 1214.    a.*

### 2123. For the purpose of publishing Country Background Pages, the following provisions shall apply:

### ppea2024057 - 2123. For the purpose of publishing Country Background Pages, the following provisions shall apply:

### Publication of Country Background Pages
- Consent of the member to which a document or a material section of a document pertains (the “member concerned”) is required to publish such a document or section.
- Fund publication of a Country Background Pages or material sections within such a document will occur, unless, prior to the conclusion of the Executive Board meeting at which that document is considered (or the date of adoption of a decision on a lapse-of-time basis to which thatthe document pertains,relates), a member concerned notifies the Fund that it has:
  - opted out of providing consent to publication on a non-objection basis; or
  - (i) objects to publication; or
  - (ii) requires additional time to decide whether or not to publish; or
  - (iii) consents to publication but subject to reaching agreement with the Fund on deletions.  
- If no member concerned provides such a notification referred to in (i), (ii) or (iii) above, the document or section shall be published by the Fund promptly after the relevant Executive Board meeting or the date of adoption of a decision on a lapse-of-time basis.
- Where one or more members concerned object to publication of information pertaining to it, the Managing Director may:
  - (i) decide to publish the Country Background Pages without the information pertaining to the objecting member(s), or
  - (ii) recommend to the Executive Board not to publish the Country Background Pages and/or, as the case may be, the associated Multilateral Policy Issues Document or Cluster Document, if the non-publication would substantially undermine the overall analysis and substance of the document.

### Deletions and corrections (Country Documents)
- For the purpose of deletions and corrections, the member concerned has the right to request deletions or corrections to information pertaining to it in accordance with the criteria and procedures applicable to Country Documents as set forth in paragraphs 7- 108-11 of this Decision.

### Cluster Documents: consent and publication
- The consent of each member to which a Cluster Document pertains (the “members Concernedconcerned”) is required for publication of the report and a Press Release pertaining to the report.
- If one or more members concerned object to publication, the document shallwill not be published.
- If the members concerned have consented to the publication of the report, such publication will be made along with the publication of a Press Release.
- The publication of a Cluster Document would occur promptly after the relevant Executive Board meeting (or the date of the adoption of a decision on a lapse-of-time basis,), unless, prior to the conclusion of the Executive Board meeting at which thatthe document is considered (or the date of adoption of a decision on a lapse-of-time basis to which that document pertains,relates), one or more members concerned notifiesnotify the Fund that it:
  - (i) objectsregarding their consent to publication as provided for in paragraph 4(b) to (e) of this Decision; or
  - (ii) requires additional time to decide whether or not to publish; or
  - (iii) consents to publication but subject to reaching agreement with the Fund on deletions to the document.

### Deletions and corrections (Cluster Documents and Press Releases)
- Each member concerned has the right to request deletions or corrections to Cluster Documents in accordance with the criteria and procedures applicable to Country Documents as set forth in paragraphs 7- 108-11 of this Decision and to Press Releases pursuant to the procedures set in paragraph 14(g) of this Decision.
- In the case of serious disagreement amongst the members concerned regarding requests for deletions, the Managing Director shall propose a solution to the members concerned. If a commonly acceptable solution cannot be found, then the Managing Director, or Executive Directors elected, appointed, or designated by the members concerned, may refer the matter to the Executive Board set forth in paragraph 32(c) of this Decision.

### Press Release timing for Cluster Documents
- If a Press Release pertaining to a Cluster Document is not expected to be published within seven calendarno later than two business days of after the Executive Board consideration,has considered the document (or after the adoption of a decision on a lapse-of-time basis to which the document relates), if the members concerned consent to issuance of the Press Release. publication of the Press Release.
- Procedures set forth in paragraph 14(c) of this Decision apply for providing a member’s consent to the publication of a Press Release pertaining to a Cluster Document.
- Executive Director(s) for one or more members concerned may request that the Press Release be published within seven calendar days after the Executive Board’s consideration of the document (or after the date of the adoption of a decision on a lapse-of-time basis to which the document relates), to allow time for the finalization of the Cluster Document.
- Any Press Release published ahead of a Cluster Document will indicate the members’ publication intentions for such document.
- A Press Release pertaining to a ClusteredCluster Document will not be issued before the circulation of the summing up as a Fund document.
- If, after twenty-eight calendar days from the relevant Board consideration, one or more members concerned do not consent to the publication of a Press Release pertaining to the Board consideration, The Fund will issue a brief factual statement will be issued stating the fact of the Board’s consideration of the matter.Cluster Report.
- If, after twenty-eight calendar days from the relevant Board consideration, the staff report has not been published, a brief factual statement will be issued stating the fact of the Board’s consideration of the matter and clarifying the publication intention of the members concerned with respect to the staff report, in the circumstances and within the time periods specified in paragraph 15(a) of this Decision.

### Administrative errors
- Rectification of administrative errors in Country Documents, Fund Policy Documents or Multi-Country Documents is limited to:
  - (i) the document issued to the Executive Board does not correspond to the version approved by management, or
  - (ii) key elements necessary for the Executive Board’s consideration of the document or the adoption of a decision on a lapse-of-time basis to which the document relates are missing or incomplete.
- Rectification shall be made before the Executive Board’s consideration of the document or the deadline to request a Board meeting for a decision proposed on a lapse-of-time basis to which the document relates.
- The administrative error should be rectified at least two business days before the Executive Board’s consideration of the corrected document or the deadline to request a Board meeting for a decision proposed on a lapse-of-time basis to which the corrected document relates.

### Other changes before publication
- Before a document is published, the following shall be removed:
  - (i) references to unpublished Fund documents,
  - (ii) references to certain internal processes that are not disclosed to the public under existing policies, including inquiries regarding possible misreporting and breaches of members’ obligations,
  - (iii) any discussion of a breach of obligation under Article VIII, Section 5 of the Articles of Agreement or misreporting under applicable Fund policies that the Managing Director has proposed be treated as de minimis in nature as defined in paragraph 1 of Decision No. 13849-(06/108), December 20, 2006, and
  - (iv) confidential information provided by a member or a third party. Removal of confidential information requires approval by the Managing Director.
- For Country Documents that include debt sustainability assessments (DSA) under the debt sustainability framework for market access countries, the following items shall be removed before publication, if included in the DSA issued to the Executive Board:
  - (ai) the results of the near-term sovereign risk assessment,
  - (bii) the mechanical signal for debt sustainability,
  - (ciii) any mention of whether debt is sustainable “with high probability” or sustainable “but not with high probability”, for Article IV consultations or for Fund arrangements where this qualification is not required for use of Fund resources under such arrangements, and
  - (div) the near-term risk analysis table, chart, and commentary.

### Post-publication modifications
- General principle: after publication, Country Documents, Fund Policy Documents and Multi-Country Documents shall not be modified except in exceptional circumstances:
  - (i) the published document does not correspond to the version that was considered by the Executive Board in material ways or does not contain elements considered integral to the publication, or
  - (ii) the published document, or part thereof, poses significant legal, reputational, or operational risks for the Fund.

### Dispute resolution procedures
- a. In the case of a serious disagreement between the Managing Director and a member regarding that member’s request for modification pursuant to paragraphs 8 through 12, 13(c), 14(g), and 30(a)(iv) of this Decision, the Managing Director, or the Executive Director elected or designated by that member, may refer the matter to the Executive Board.
- b. For staff reports for Article IV consultations and regional surveillance discussions (Documents 1 and 2), if the Managing Director approves deletions requested by other members, and the member to whom the document relates disagrees with the assessment of the Managing Director, the Managing Director, or the Executive Director elected or designated by that member, may refer the matter to the Executive Board.
- c. For a serious disagreement amongst the members concerned regarding requests for deletions to a Cluster Document, the Managing Director shall propose a solution; if no commonly acceptable solution is found, the Managing Director, or Executive Directors elected or designated by the members concerned, may refer the matter to the Executive Board.
- d. If the Managing Director considers that the requested deletions would result in a document that, if published, would undermine the overall assessment and credibility of the Fund, the Managing Director shall recommend to the Executive Board that the document not be published.

### Timing and means of Fund publication
- Documents may be published under this decisionDecision only after their consideration by the Executive Board, except for documents circulated for information only including:
  - (i) I-PRSPs, PRSPs, EDDs and PRGSs; and
  - (ii) Reports on Observance of Standards and Codes (ROSCs) and Assessment of Financial Sector Supervision and Regulation (AFSSR) Reports.
- Documents covered by this paragraph may be published immediately after circulation to the Executive Board.
- Publication by the Fund under this decisionDecision shall normally mean publication on its website but may include publication through other media.

### Article XII, Section 8
- Nothing in this decisionDecision shall be construed to be inconsistent with the power of the Fund to decide under Article XII, Section 8 of the Articles of Agreement, by a seventy percent majority of the total voting power, to publish a report made to a member regarding its monetary or economic conditions and developments which directly tend to produce a serious disequilibrium in the international balance of payments of members.

### Non-members
- For a document pertaining to a country which is not a member of the Fund:
  - (i) all references to “member” in this decisionDecision shall be taken to mean “country”; and
  - (ii) all references to “Executive Director elected, appointed, or designated by that member” shall be taken to refer to the appropriate authorities of the country concerned.

### Documents prepared by other institutions
- Documents prepared by other institutions and required for Executive Board consideration will be published together with the related staff report in the version considered by the Executive Board, provided:
  - the related staff report is published,
  - there is no objection to publication from the institution that produced the documents, and
  - the Executive Board has not decided against publication of the specific category of documents.
- These documents do not require the member’s consent to publication and are not subject to the modification rules set forth in this Decision.
- Notwithstanding the provisions of this Decision, such documents may not be modified after Executive Board consideration.

### Review
- This decisionDecision is expected to be reviewed in light of experience no later than 2018. in five years or more, as needed.

### Appendix I — Indicative list of documents covered by the Decision (selected highlights)
- The Transparency Policy covers Country Documents, Fund Policy Documents and Multi-Country Documents; when a document is covered by the policy both the publication and modification rules of the policy apply, unless otherwise specified in the decision.
- Country Documents (indicative, not exhaustive) include:
  - Staff Reports for Article IV consultations and Combined Article IV consultations/Use of Fund Resources Staff Reports, Combined Article IV consultations/PSIPCI, Combined Article IV consultations/ PCI, SMP, Combined Article IV consultations/PMB, and regional surveillance discussions
  - Selected Issues Papers and Statistical Appendices
  - Reports on Observance of Standards and Codes (ROSCs), Financial System Stability Assessment (FSSA) Reports, and Assessment of Financial Sector Supervision and Regulation (AFSSR) Reports
  - Press Releases following Article IV consultations, regional surveillance discussions, and stand-alone Board consideration of FSSA reports
  - Stand-alone Debt Sustainability Analysis reports
  - Joint Fund/World Bank Staff Advisory Notes (JSANs) on I-PRSPs, PRSPs, PRSP Preparation Status Reports, RSP Annual Progress Reports (APRs), and Poverty Reduction Growth Strategy Papers (PRGS)
  - Staff Reports for Use of Fund Resources, Post-Program Monitoring, Financing Assessments, Ex - Post Assessment Peer-Reviewed Assessments (PRAs), and Ex - Post EvaluationEvaluations of exceptional access arrangements (excluding staff reports dealing solely with a member’s overdue financial obligations to the Fund)
  - Press Releases containing a Chairman’s Statement for Use of Fund Resources
  - Preliminary, decision point, and completion point documents under the Heavily Indebted Poor Countries Initiative
  - I- PRSPs, PRSPs, PRSP Preparation Status Reports, and APRs, EDDs and PRGSs
  - Letters of Intent (LOIs), Written Communications from authorities, and Memoranda of Economic and Financial Policies (LOIs/MEFPs), and Written Communications
  - Technical Memoranda of Understanding (TMUs) with policy content
  - Staff Notes on preliminary evaluation of high and/or exceptional access
  - Overdue Financial Obligations Documents
  - LOIs/MEFPs for SMPs and Program Monitoring with Board Involvement (PMBs)
  - Stand-alone Staff Reports on SMPs and PMBs
  - Press Releases following Executive Board discussions on PMBs

*pp ea2024057 - 2123 (extracted content from the IMF PDF chapter/section provided)*

### 20.  Program 15. I-PRSPs, PRSPs, PRSP Preparation Status Reports, APRs, EDDs and PRGSs in the

### 20.  Program 15. I-PRSPs, PRSPs, PRSP Preparation Status Reports, APRs, EDDs and PRGSs in the context of PSIs

### Document types and program-related items
- Listed document categories associated with Program 15 and related instruments:
  - I-PRSPs, PRSPs, PRSP Preparation Status Reports, APRs, EDDs and PRGSs in the context of PSIs
  - Joint Fund/World Bank Staff Advisory Notes (JSANs) on I-PRSPs and PRSPs in the context of PSIs
  - Letters of Intent and Memoranda of Economic and Financial Policies (LOIs/MEFPs) for PSIs and Program Statements for PCIs
  - Technical Memoranda of Understanding (TMUs) with policy content for PSIs and PCIs
  - Staff Reports for PSIs and PCIs
  - Press Releases containing a Chairman’s Statement for PSIs and PCIs
  - Statements on Fund Decisions, including waivers of applicability or nonobservance of performance criteria and nonobservance of assessment criteria
- Other referenced document groupings across the broader decision text:
  - Fund Policy Issues Papers
  - Background papers to Fund Policy Papers
  - Press Releases following Executive Board consideration of policy issues
  - Internal Fund Administrative Documents
  - Stand-alone Enterprise Risk Assessments (ERA)
  - Multilateral Policy Issues Documents (e.g., World Economic Outlook, Global Financial Stability Report, Fiscal Monitor)
  - External Sector Reports and Spillover Reports
  - Country Background Pages and Cluster Documents

### Archives access rules and time thresholds
- General rule: Outside persons, on request, will be given access to documentary materials maintained in the Fund’s archives under the terms specified in the Decision.
- Specific access timing thresholds (as stated):
  - Executive Board documents that are over 3 years old, with the exception of Executive Board documents discussing cyber and physical security vulnerabilities of the Fund, to which access will be given after 20 years.
  - Minutes of Executive Board meetings that are over 3 years old, with the exception of Minutes of Executive Board meetings discussing a member’s use of (i) the Fund’s resources, (ii) the Policy Support Instrument, and (iii) the Policy Coordination Instrument, to which access will be given after 5 years, and Minutes of Executive Board meetings discussing cyber and physical security vulnerabilities of the Fund, to which access will be given after 20 years.
  - BUFF Statements by the Managing Director or Fund Staff to the Executive Board, BUFF/EDs, Gray Documents, and Green Documents that are over 3 years old, with the exception of such documents discussing a member’s use of (i) the Fund’s resources, (ii) the Policy Support Instrument, and (iii) the Policy Coordination Instrument, to which access will be given after 5 years, and such documents discussing cyber and physical security vulnerabilities of the Fund, to which access will be given after 20 years.
  - Précis of Executive Board Meetings (replaced by weekly Précis and weekly Decisions Report), Executive Board Seminars Agendas and Minutes, Secretary’s Journal of Executive Board Informal Sessions Minutes, and Executive Board Committee Minutes that are over 5 years old.
  - Other documentary materials maintained in the archived permanent records of the Fund’s archives that are over 20 years old.

### Classification, declassification, and exceptions
- Documents classified as “Secret” or “Strictly Confidential” as of the date of the Decision:
  - Access will be granted only upon the Managing Director’s consent to their declassification.
  - It is understood that this consent will be granted in all instances except where, despite the passage of time, the material remains highly confidential or sensitive.
- Automatic declassification policy for Executive Board documents covered by Decision No. 15420-(13/61), adopted June 24, 2013, as amended:
  - Documents classified as “Strictly Confidential” after the date of this Decision will be automatically declassified when the respective time periods specified above have elapsed, unless at the time of their initial classification the authoring department specifies that the document shall not be subject to automatic declassification.
  - If such a specification is made, the Managing Director’s consent process (paragraph on declassification consent) shall apply.
- Records to which access will not be granted:
  - (a) legal documents and records maintained by the Legal Department that are protected by attorney-client privilege;
  - (b) documentary materials archived permanent records furnished to the Fund by external parties, including member countries, their instrumentalities and agencies and central banks, that bear confidentiality markings, unless such external parties consent to their declassification;
  - (c) personnel files and medical or other records pertaining to individuals;
  - (d) documents and proceedings of the Grievance Committee.
- Exceptional access prior to expiry:
  - In exceptional circumstances, when the Managing Director determines it is in the interest of the Fund, access to other archived permanent records (those over 20 years threshold) may be granted upon request prior to the expiration of the 20 year period.

### Public access modalities and operational provisions
- To enable easier and wider public access, archival material covered by this Decision may be made available through a variety of means, including through a catalogue published on a designated section on the Fund’s external website.
- A “request” under the Decision may be made:
  - orally in person at Fund Headquarters or by telephone;
  - in writing by hardcopy or electronic means such as e-mail or facsimile;
  - through a portal in the Fund’s external website designated for access to archival material of the catalogue.
- Requested material may be conveyed to the public by hardcopy, electronic means and other web-based modalities.
- From the date of effectiveness of this Decision, all Executive Board documents published by the Fund earlier shall be made available to the public through the catalogue on the Fund’s external website (without prejudice to access that will be given pursuant to the specified paragraph for Executive Board documents).
- Administrative handling of ad hoc exceptions:
  - Since the Board’s approval of the Policy on Access to Fund Archives in 1996, staff has continued to follow the long-standing policy of requesting Board consent for ad hoc exceptions to the policy on behalf of external researchers.
  - A reasonable cost recovery scheme may be maintained for administering ad hoc requests for Board approval of exceptions to the terms specified under the Decision.
  - No charge shall be assessed for requests received from government officials of member countries.

### Repeals, review, and effective date
- Repealed decisions:
  - Decision No. 11192-(96/2), January 17, 1996, as amended, on the opening of the Archives.
  - Decision No. 12981-(03/34), April 9, 2003 on Review of the Policy on Access to the Fund’s Archives.
- Review schedule:
  - This Decision is expected to be reviewed by the Executive Board at regular intervals in tandem with the regular reviews of the Fund’s Transparency Policy, Decision No. 15420-(13/61), adopted June 24, 2013, as amended.
- Effective date:
  - This Decision shall become effective on March 17, 2010 (SM/09/264, Sup. 3, 12/9/09).

*Source: ppea2024057 - 20.  Program 15. I-PRSPs, PRSPs, PRSP Preparation Status Reports, APRs, EDDs and PRGSs in the*

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_Source: https://www.imf.org/-/media/files/publications/pp/2024/english/ppea2024057.pdf_
