## EXECUTIVE SUMMARY

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---

### Scope and purpose
- Background paper consists of six stand-alone sections supporting the review of the Fund’s Transparency Policy (TP) and Open Archives Policy (OAP).
- Information pertains to the rules of the TP/OAP in effect before the completion of the 2024 review.
- Sections cover:
  - Overview of revisions to the Fund’s Transparency Policy (TP) since 2009.
  - Examples of documents circulated to the Executive Board (EB) that are not covered by the TP or are covered by other publication regimes.
  - Current publication rules for press releases (PR).
  - Fund’s legal framework for treating confidential information.
  - Analysis of the experience with Market Access Countries Sovereign Risk and Debt Sustainability Framework (MAC SRDSF) special deletion rules under the TP.
  - Time rules for releasing document series under the Fund’s Open Archives Policy (OAP).

### Revisions to the Transparency Policy since 2009
- 2009 Review
  - Introduced the “transparency principle”: Fund will strive to disclose documents and information on a timely basis unless strong and specific reasons argue against disclosure.
  - Introduced possibility to obtain publication consent for country documents on a non-objection basis and strengthened the presumption of publication.
  - Broadened modification options for Board documents (e.g., corrections for “evident ambiguity”).
  - Accelerated access to the Fund’s archives.
- 2013 Review
  - Extended the strong presumption of publication to all program-related documents.
  - Defined “prompt publication” as within 14 days from Board consideration.
  - Introduced brief factual statements (within 28 days) when publication is delayed.
  - Created lower-profile publication procedures for significantly delayed reports.
  - Introduced an indicative list of documents covered by the policy and recommended more consistent use of press releases and more translations.
  - Added category of multi-country documents (e.g., “cluster reports”) and adapted modification rules to support spillover analysis integration and third-party deletion requests.
  - Required an annual report to the Executive Board on all modification requests received over the previous year to strengthen monitoring of evenhandedness.
  - Prioritized digitization of paper-based records under the OAP.
- Post-2013 Changes
  - Small modifications to accommodate creation of new instruments: Policy Coordination Instrument (2017) and Resilience and Sustainability Facility (2022).
  - Introduced deletion of sensitive information related to the Fund’s Sovereign Risk and Debt Sustainability Framework (2022).

### Examples of Board-circulated documents not covered by the TP or covered by other regimes (indicative list)
- Capacity Development Information (including Technical Assistance Reports) — own publication regime; publication encouraged.
- Safeguard assessments — considered confidential; full reports available to the central bank and the ED representing the country; EB receives only a summary appearing in the next staff report.
- Assessment letters provided by the IMF to other institutions.
- Presentations circulated to the EB not intended for external publication.
- Fiscal Safeguards Assessments.
- External publications authored by staff (Working Papers, Staff Discussion Notes, Departmental papers) provided to EDs in advance of publication.
- Mission Concluding Statements, Statements by Managing Director, and other press releases not circulated to the Board prior to publication.
- Regional Economic Outlooks.
- Staff guidance notes.
- Board Committee Documents.
- Statements by Executive Directors Offices (e.g., Grays, BUFF/EDs, Greens).
- Reports and statements made to the Board of Governors or its committees.

### Current rules about the content and publication of press releases (PR) (TP rules before the 2024 review)
- General
  - PRs are an important external communication product; Fund strives to issue PRs for country documents (with member consent) and policy papers shortly after EB consideration.
  - Rules for content and timing vary notably by type of Board document.
- Content variation by type of country document
  - Article IVs (AIVs), regional surveillance, stand-alone FSSAs:
    - PR consists of (i) introductory section with factual information including a table of selected economic indicators (or on the financial system for stand-alone FSSAs); and (ii) the summing up of the Board’s assessment of members’ prospects and policies; for stand-alone FSSAs the Board’s assessment of financial system stability.
  - UFRs, EPA, EPE, PCI, PFA, SMPs, combined AIV with PFA/EPE, HIPC participation discussions, PRS status report:
    - PR contains an introductory background section and a Chair’s Statement (rather than a summing up) covering key points made by the Board.
  - AIV combined with a UFR discussion:
    - PR normally includes an introductory section, the AIV summing up, and the Chair’s Statement (covering UFR issues). If the AIV summing up is not available soon, two separate PRs can be issued referencing each other.
  - AIVs, regional surveillance, stand-alone FSSAs considered on a lapse-of-time (LOT) basis:
    - PR includes a background section and the staff appraisal verbatim from the staff report (deemed Board-endorsed).
    - For a UFR request/review concluded on a LOT basis, there is no PR, but a factual statement may be issued.
- Publication rules and timing
  - Country documents:
    - Publication of a PR is “voluntary but presumed” and requires a member’s consent.
    - Timing depends on member consent, modification requests to the introductory section, and/or finalization of the summing up.
    - If member has consented to publication of staff report and PR, PR is published with the staff report.
    - If staff report is not expected to be published within seven days after the Board date/LOT decision date but member has consented, a PR will be published separately shortly after the Board meeting.
    - If after 28 days after the Board meeting or LOT decision date the member has still not consented to publication of the PR, the Policy requires issuance of a brief factual statement stating that Board consideration has taken place.
    - In UFR cases, if the member has not consented to publication of the PR, a short factual statement is expected to be issued immediately after the Board consideration.
    - For UFR and combined reports, a single PR will normally be issued on the day of the Board meeting. If member has not consented or no Chair’s statement issued because a decision was on an LOT basis, a brief factual statement is to be issued immediately after the Board describing the Board’s decision regarding use of Fund resources or approval of the member’s PCI, and consideration of PRGS documents.
  - Policy documents:
    - Publication of a PR is presumed with few exceptions.
    - PR normally published with the Board document promptly after the EB meeting or LOT decision date.
    - If document not expected to be published within seven days, a PR is to be issued shortly after Board consideration.
    - If discussion has not reached a stage where informing the public is useful, the Board may hold publication of the PR.
    - For policy documents sent to the Board for information only, a PR is to be issued within 14 days after issuance to the Board.
    - For PRs prepared for an informal EB session, publication is deemed approved unless an ED objects by the date set in the Secretary’s cover memorandum.
  - Multi-country documents:
    - Publication of a PR requires consent from concerned members or EB approval (e.g., ESR).
- Table 1 (Press Releases: Content by Type of Document) — indicates whether a PR contains a Summing Up and/or Chair’s Statement for a range of document types (AIV Consultation, Stand-alone FSSA, Use of Fund Resources, Policy Coordination Instrument, Procedures related to failure to provide information under Article VIII, Section 5, HIPC Initiative, SMP, PMB, etc.), including notes:
  - Note 1: Internal summing up only.
  - Note 2: The Chair’s Statement relates only to the Use of Fund resources (UFRs), not the AIV consultation.
- Footnote: This section describes TP rules for PRs before the 2024 review. During the 2013 review, a decision was taken to use “press releases” for external communication products, discontinue “public information notes” (PIN), and expand translations into languages other than English.

### The Fund’s legal framework for the treatment of confidential information
- Objective
  - Protect confidential information received from members and other parties and generated internally; regulate sharing both with the public and within the Fund.
- Rules of confidentiality vis-à-vis the public
  - General principle: EB, management and staff may not disclose information that a member or other person has provided in confidence, unless that party consents and disclosure is consistent with Fund rules.
  - Determination of confidentiality is based on examination of surrounding circumstances, including the nature of the information and whether there was an understanding (expressed or implied) that it would not be disclosed without consent.
  - Where doubts exist, Fund's approach is to give the benefit of the doubt to the member or other party.
  - Three broad legal bases:
    - Article IX, Section 5 of the Fund‘s Articles of Agreement: archives of the Fund shall be inviolable; non-public documents produced by the Fund or received from members/third parties are protected and cannot be published or produced without Fund approval. Approval can be general (e.g., OAP, TP, Transmittal Policy) or case-by-case.
    - Article XII, Section 8 of the Articles of Agreement: Fund should not publish documents containing its views (meaning the EB‘s views) regarding a member without that member‘s consent, except under specified circumstances (70 percent majority provision described but never used).
    - Internal rules: Rules N-6 and N-11 of the Fund‘s Rules and Regulations, Staff Handbook, General Administrative Order No. 35 Rev.2 (GAO 35), and Code of Conduct for EB members, management, staff, and EDs prohibit unauthorized disclosures of confidential information obtained during service to the Fund.
- Rules of confidentiality within the Fund
  - Handling of confidential information within the Fund is regulated by rules on sharing with EDs, confidentiality, information security, information classification, and data privacy.
  - Confidentiality rules apply to contractual employees as per employment agreements.
  - References provided to Staff Regulation N-6, Staff Regulation N-11, Staff Handbook Chapter 11.02 Section 2.3(vi), and Code of Conduct for Members of the Executive Board with revision dates.

### Circumstances requiring disclosure to the Executive Board
- Management and staff must inform authorities when confidential information cannot be withheld from the Executive Board; broadly three circumstances are identified:
  - First, the member should not purport to withhold from the Board any information required to be reported to the Fund as a result of members‘ obligations under the Articles of Agreement.
  - Second, where the Board has established a policy requiring that certain information received from members must be disclosed to the Board, members are understood to be on notice of the existence of such a policy and are considered to have consented to such disclosure.
  - Third, in the absence of policies mandating disclosure to the Board, disclosure is required if such information is judged to be of a nature that is critical for the Board to be able to exercise its responsibility in a meaningful way.
- Context-specific illustrations:
  - Surveillance: members, management, and staff may not on grounds of confidentiality withhold from the Board any information that is required to be reported under Article VIII, Section 5 or that is otherwise judged to be necessary for the conduct of surveillance.
  - Use of Fund resources: the Board has a policy requiring Fund management and staff to disclose to the Board confidential information provided by a member in the form of a side letter.
  - Capacity development (CD) and technical assistance (TA):
    - TA reports and other final CD outputs are treated as confidential vis-à-vis the Board.
    - Fund policy requires management to share with the Board certain CD reports for the purposes of informing Board work on surveillance: Reports on Standards and Codes and Assessment of Financial Sector Supervision and Regulations.
    - High-level summaries of strategic final CD outputs are required under the Staff Operational Guidance on Dissemination of Capacity Development Information; these summaries are intended for publication (and dissemination to the Board) with the presumed consent of the CD recipient on a 30-day lapse-of-time basis and may not include confidential information.
  - If no policy mandates disclosure but management believes disclosure is necessary for the Board to make an informed decision (e.g., program review or effective surveillance), management should not recommend Board action unless the member consents to disclosure.

### Board and Executive Directors (EDs) publication constraints and secure access
- Even when information is required to be provided to the Executive Board (EB), neither the EB nor EDs can publish information provided by a member or other person on the understanding that it remains confidential vis-à-vis the public, unless the member or other person consents.
- Confidential information to the EB is typically provided via a secure platform allowing access by each ED and individually authorized member country officials.
- For the most sensitive information, EDs are provided access via uniquely identifiable encrypted documents that may not be copied or shared. All such confidential information is encrypted to prevent further distribution to non-designated individuals.
- EDs are governed by the Code of Conduct for the Members of the EB requiring them to protect the security of any confidential information provided to, or generated by, the Fund.
- Authorities are obliged to ensure applicable Fund restrictions on access to documents containing confidential information are respected, including limitations on internal access in accordance with their classification, as well as no public disclosure or citation of any confidential information.

### Confidentiality, information security, data privacy, and classification
- Confidentiality is linked to information security and requires compliance with the Fund’s rules on classification of information and information security.
- Under the Staff Handbook, Fund staff have a duty to safeguard non-public information which they create, or to which they have access in the performance of their official duties, and to comply with all applicable policies concerning information classification and information security as may be issued from time to time.
- Information security rules applicable to Fund staff are currently primarily set out in GAO 35 and in the Information Security Policies. The Information Security Framework of the Offices of EDs is set out in Decision No. a/14300-(20/106) adopted on 30 October 2020.
- For Fund staff, the originator is required to classify documents according to the following information security classifications:
  - FOR OFFICIAL USE ONLY—accessible to all staff and in some cases may be shared with national officials or other authorized individuals or institutions;
  - CONFIDENTIAL—accessible on a need-to-know basis; and
  - STRICTLY CONFIDENTIAL—accessible on a strict need to know basis.
- Classification responsibilities and procedures:
  - The authoring department or office, in consultation with the Secretary of the Fund, is responsible for the classification of all documents issued to the EB and the Board of Governors and their committees if they are in the categories “for official use only” or “confidential.”
  - The Secretary, in consultation with staff/management and, for country reports, with the ED concerned, determines whether a Board document should be classified as “strictly confidential,” based on an assessment of whether the information is particularly sensitive.
  - After classification, management and staff may make the document available only to the extent envisaged under the relevant security classification and must use appropriate care to prevent unauthorized access.
  - If a document is not given a classification and it is not clear how it should be classified, staff should treat it as if it had at least FOR OFFICIAL USE ONLY classification or consult the originating department or the communications department.
- Personal information and personal data:
  - Documents that contain information about identified or identifiable individuals (personal information or personal data) are subject to additional safeguards and should be classified within the same information security categories.
  - Handling of such documents is subject to the Fund’s personal data privacy rules set out in the Personal Information Privacy Guidelines.
  - These rules will be superseded by the Fund’s Personal Data Privacy Policy, which becomes effective on May 1st, 2025.
  - The Personal Data Privacy Policy imposes additional restrictions on collection, use, retention and other processing of personal information by Fund management and staff (e.g., there needs to be a legitimate basis for processing personal information, personal information should be retained only as long as there is a valid business need for it, access should be restricted based on security classification, etc.). The Policy also establishes certain rights for individuals to access their information and seek redress if that information is mishandled.

### Protecting confidential information from accidental disclosure
- The Transparency Policy includes rules on deletion of certain types of sensitive information from documents published by the Fund, which helps avoid accidental disclosure of confidential information.
- The rules differ by document type and include procedures and timelines that must be followed for making deletions.

### Analysis of MAC SRDSF special deletions under the Transparency Policy
- Exemption introduced in July 2022 allows deletion of specific elements of the Debt Sustainability Framework for Market Access Countries (MAC SRDSF), in specific circumstances, before publication. Such deletions include:
  - Near-term sovereign risk assessment (when included with the Sovereign Risk and Debt Sustainability Assessment-SRDSA), which includes the "Near-Term Risk Analysis” and, in the main summary table, the near-term mechanical signal, the near-term final assessment, and the corresponding commentary.
  - The mechanical signal on debt sustainability (whether the assessment was mandatory or optional).
  - When debt is assessed to be sustainable, the qualification "with high probability” or “but not with high probability,” unless such qualification is required for use of Fund resources.
- Review and assessment of these deletions:
  - The Board indicated in the 2021 Review of the MAC SRDSF that it would review these deletions after 12 months of implementation. More than 18 months have passed since the implementation became mandatory for all MACs and some information is now available to reassess these deletions.
  - Observations based on implementation experience and evidence gathered:
    - Costs and consistency with debt transparency:
      - These across-the-board deletions contradict the Fund’s push for debt transparency. Debt transparency is one of the pillars of the Joint IMF/WB Multipronged Approach to Address Debt Vulnerabilities and these deletions seem inconsistent with that approach and the importance attached by the Board to debt transparency.
      - Civil society organizations and investors have criticized the Fund for lack of transparency in the MAC SRDSF, highlighting the reputational cost of these exemptions for the Fund.
    - Resource costs:
      - Implementation of these deletions carries resource cost. The set of rules for implementing these deletions is complex as deletions vary depending on whether the country has a Fund arrangement and with the type of Fund arrangement, requiring country teams to regularly check which deletions apply and how to implement them.
      - Information expected to be deleted needs to be deleted across the entire staff report, including in the middle of sentences, making deletions hard to single out and enforce and risking changes in text meaning without extensive changes as required by the Transparency Policy’s general rules.
    - Methodological confidentiality not strictly necessary:
      - The deletion of the mechanical signal on debt sustainability was initially motivated by the need to keep confidential the Fund’s mechanical rule for debt sustainability assessments. However, important components of the Fund’s decision rule for assessing debt sustainability would still remain strictly confidential, limiting the ability of the markets to infer the Fund’s decision rule for generating a mechanical signal.
    - Near-term risk assessments alignment with markets:
      - Near-term sovereign risk assessments, deleted from staff reports, are typically aligned with market assessments and publication would have rarely surprised the market on the downside.
      - The argument for deleting the near-term assessment was that publication could cause markets to react due to the short horizon associated with this assessment.
      - Experience during the first 18 months shows the Fund’s near-term assessment rarely differs from market risk perception as expressed in sovereign spreads.
      - Summary of comparison (as described in text): among MAC SRDSAs through May 2024 for which near-term risk assessment was required, classifications by near-, moderate-, and high-risk assessments produced very large overlap with low, moderate, and high sovereign spread levels; only one high near-term risk assessment was associated with moderate spreads and none with low spreads.
      - There were 4 other cases where the near-term risk assessment (moderate) was less positive than market spreads, but 10 cases where the near-term risk assessment was more positive than that implied by spreads.
      - There are 36 cases for which spreads were not available, of which only 3 were classified as high risk of near-term sovereign stress.
      - Note: the logit model used for this assessment has been published in the SRDSF guidance note, making it relatively easy for market actors to forecast the near-term risk mechanical signal.
    - Mechanical signals vs. final assessment:
      - Since the rollout of the MAC SRDSF started, there have been 3 cases out of 57 where mechanical signals on debt sustainability assessment were worse than the final assessment. In these cases, results from the medium-term tools were already published, providing the relevant information to the market (Egypt 2022, 2024, and Gabon 2024).
    - Accidental publications and market reaction:
      - Where the near-term assessment and/or the three-way debt sustainability assessment were by mistake published, publication triggered no market reaction.
      - An event study using the rollout period since mid-2022 identified seven inadvertent publication cases and indicates no significant market reaction to the publication of this information.
      - Caveats to the event study: (i) small number of events; and (ii) in all these events the information provided did not include negative news (assessments indicated low risk and debt being sustainable with high probability), which could bias results if market reaction to positive and negative news is not symmetric.
  - Overall conclusion:
    - Evidence so far is preliminary and further experience with the application of the MAC SRDSF and related deletions will continue to accumulate.
    - Outcomes of the framework are generally aligned with market perceptions and information, although a few tail cases have emerged.
    - Further experience will help shed additional light on concerns about market sensitivity of SRDSF outputs, which underpin the current exemption of elements of the MAC SRDSF from the Transparency Policy’s deletion rules.

### Time rules for document series under the Open Archives Policy (OAP)
- Category 1: Executive Board Series Available Under The Three-Year Access Rule (20 years for those pertaining to the Fund’s physical and cyber security vulnerabilities)
  - Document series listed include: BUFF (Chairman’s Summing Up or Concluding Remarks Only), BUFF statements by Managing Director and Staff Representatives to EB on matters not related to use of UFR, PSI, and PCI, BUFF/ED statements by EDs to Board on matters not related to UFR/PSI/PCI, DEC (EB Decisions on matters not related to use of UFR/PSI/PCI), DEC/A (Administrative Decisions on matters not related to use of UFR/PSI/PCI), EB/A (EB Meetings Agendas), EB (various) (EB Committees—including Agendas, Documents, Statements, Undocumented Papers), EBAM (EB Administrative Matters), EBAP (EB Administrative Papers), EBC (EB Meetings Calendar), EBD (EB Documents), EBM (EB Minutes on matters not related to use of UFR/PSI/PCI), EBS (EB Specials), FEFM (Foreign Exchange and Financial Markets), FO/Dis (Front Office Informal Distribution), Gray (Preliminary Version of ED’s Statements to EB on matters not related to use of UFR/PSI/PCI), Green (Statements by EDs on Matters for Lapse of Time Consideration not related to use of UFR/PSI/PCI), IS/A (Secretary’s Journal of Informal Sessions Agendas), RP/CP (Pension Committee), RP/CP/A (Pension Committee Agendas), RP/CP/U (Pension Committee Undocumented Papers), SEC/Circ (Secretary’s Circulars), SM (Staff Memoranda), SU (Chair’s Summing Ups), SUR (Surveillance-related Chair’s Summing Ups), and UNDOC (Undocumented Papers).
- Category 2: Executive Board Series Available Under The Five-Year Access Rule (20 years for those pertaining to the Fund’s physical and cyber security vulnerabilities)
  - Document series listed include: BUFF (Statements by Managing Director and Staff Representatives to EB on matters related to use of UFR, PSI, and PCI), BUFF/ED (Statements by EDs to EB on matters related to use of UFR, PSI, and PCI), DEC (EB Decisions on matters related to use of UFR, PSI, and PCI), DEC/A (Administrative Decisions on matters related to use of UFR, PSI, and PCI), DM (Departmental Memoranda), EB (various) (EB Committees—Minutes), EBM (EB Minutes on matters related to use of UFR, PSI, and PCI), EBM/R (Restricted EB Minutes (classified Strictly Confidential) on matters related to use of UFR, PSI, and PCI), Gray (Preliminary Version of EDs’ Statements to EB on matters related to use of UFR, PSI, and PCI), Green (Statements by EDs on Matters for Lapse of Time Consideration related to use of UFR, PSI, and PCI), IS/Mtg (Secretary’s Journal of Informal Sessions Minutes), Précis/Mtg (Précis of EB Meetings (replaced by Weekly Précis)), RP/CP/Mtg (Pension Committee Minutes), SEM/A (EB Seminar Agendas), SEM/Mtg (EB Seminar Minutes), WDR (Weekly Decision Report), Weekly/Précis/Mtg (Précis of EB Meetings (replaced by Weekly Decision Report)).
- Category 3: Executive Board Series Available Under The 20-Year Access Rule
  - Document series listed include: EB/EVC/Mtg (Evaluation Committee Minutes).

*Prepared by Strategy, Policy, and Review Department; Approved By Mark Flanagan (SPR), Gilles Bauche (SEC), Magí Clavé Badia (ITD), Bernhard, and Steinki (LEG). Consultations with Executive Directors, Country Authorities, Mission Chiefs, and Civil Societies Organizations. October 1, 2024.*

### EXECUTIVE SUMMARY

### EXECUTIVE SUMMARY

### Scope and purpose
- Background paper consists of six stand-alone sections supporting the review of the Fund’s Transparency Policy (TP) and Open Archives Policy (OAP).
- Information pertains to the rules of the TP/OAP in effect before the completion of the 2024 review.
- Sections cover:
  - Overview of revisions to the Fund’s Transparency Policy (TP) since 2009.
  - Examples of documents circulated to the Executive Board (EB) that are not covered by the TP or are covered by other publication regimes.
  - Current publication rules for press releases (PR).
  - Fund’s legal framework for treating confidential information.
  - Analysis of the experience with Market Access Countries Sovereign Risk and Debt Sustainability Framework (MAC SRDSF) special deletion rules under the TP.
  - Time rules for releasing document series under the Fund’s Open Archives Policy (OAP).

### Revisions to the Transparency Policy since 2009
- 2009 Review
  - Introduced the “transparency principle”: Fund will strive to disclose documents and information on a timely basis unless strong and specific reasons argue against disclosure.
  - Introduced possibility to obtain publication consent for country documents on a non-objection basis and strengthened the presumption of publication.
  - Broadened modification options for Board documents (e.g., corrections for “evident ambiguity”).
  - Accelerated access to the Fund’s archives.
- 2013 Review
  - Extended the strong presumption of publication to all program-related documents.
  - Defined “prompt publication” as within 14 days from Board consideration.
  - Introduced brief factual statements (within 28 days) when publication is delayed.
  - Created lower-profile publication procedures for significantly delayed reports.
  - Introduced an indicative list of documents covered by the policy and recommended more consistent use of press releases and more translations.
  - Added category of multi-country documents (e.g., “cluster reports”) and adapted modification rules to support spillover analysis integration and third-party deletion requests.
  - Required an annual report to the Executive Board on all modification requests received over the previous year to strengthen monitoring of evenhandedness.
  - Prioritized digitization of paper-based records under the OAP.
- Post-2013 Changes
  - Small modifications to accommodate creation of new instruments: Policy Coordination Instrument (2017) and Resilience and Sustainability Facility (2022).
  - Introduced deletion of sensitive information related to the Fund’s Sovereign Risk and Debt Sustainability Framework (2022).

### Examples of Board-circulated documents not covered by the TP or covered by other regimes (indicative list)
- Capacity Development Information (including Technical Assistance Reports) — own publication regime; publication encouraged.
- Safeguard assessments — considered confidential; full reports available to the central bank and the ED representing the country; EB receives only a summary appearing in the next staff report.
- Assessment letters provided by the IMF to other institutions.
- Presentations circulated to the EB not intended for external publication.
- Fiscal Safeguards Assessments.
- External publications authored by staff (Working Papers, Staff Discussion Notes, Departmental papers) provided to EDs in advance of publication.
- Mission Concluding Statements, Statements by Managing Director, and other press releases not circulated to the Board prior to publication.
- Regional Economic Outlooks.
- Staff guidance notes.
- Board Committee Documents.
- Statements by Executive Directors Offices (e.g., Grays, BUFF/EDs, Greens).
- Reports and statements made to the Board of Governors or its committees.

### Current rules about the content and publication of press releases (PR) (TP rules before the 2024 review)
- General
  - PRs are an important external communication product; Fund strives to issue PRs for country documents (with member consent) and policy papers shortly after EB consideration.
  - Rules for content and timing vary notably by type of Board document.
- Content variation by type of country document
  - Article IVs (AIVs), regional surveillance, stand-alone FSSAs:
    - PR consists of (i) introductory section with factual information including a table of selected economic indicators (or on the financial system for stand-alone FSSAs); and (ii) the summing up of the Board’s assessment of members’ prospects and policies; for stand-alone FSSAs the Board’s assessment of financial system stability.
  - UFRs, EPA, EPE, PCI, PFA, SMPs, combined AIV with PFA/EPE, HIPC participation discussions, PRS status report:
    - PR contains an introductory background section and a Chair’s Statement (rather than a summing up) covering key points made by the Board.
  - AIV combined with a UFR discussion:
    - PR normally includes an introductory section, the AIV summing up, and the Chair’s Statement (covering UFR issues). If the AIV summing up is not available soon, two separate PRs can be issued referencing each other.
  - AIVs, regional surveillance, stand-alone FSSAs considered on a lapse-of-time (LOT) basis:
    - PR includes a background section and the staff appraisal verbatim from the staff report (deemed Board-endorsed).
    - For a UFR request/review concluded on a LOT basis, there is no PR, but a factual statement may be issued.
- Publication rules and timing
  - Country documents:
    - Publication of a PR is “voluntary but presumed” and requires a member’s consent.
    - Timing depends on member consent, modification requests to the introductory section, and/or finalization of the summing up.
    - If member has consented to publication of staff report and PR, PR is published with the staff report.
    - If staff report is not expected to be published within seven days after the Board date/LOT decision date but member has consented, a PR will be published separately shortly after the Board meeting.
    - If after 28 days after the Board meeting or LOT decision date the member has still not consented to publication of the PR, the Policy requires issuance of a brief factual statement stating that Board consideration has taken place.
    - In UFR cases, if the member has not consented to publication of the PR, a short factual statement is expected to be issued immediately after the Board consideration.
    - For UFR and combined reports, a single PR will normally be issued on the day of the Board meeting. If member has not consented or no Chair’s statement issued because a decision was on an LOT basis, a brief factual statement is to be issued immediately after the Board describing the Board’s decision regarding use of Fund resources or approval of the member’s PCI, and consideration of PRGS documents.
  - Policy documents:
    - Publication of a PR is presumed with few exceptions.
    - PR normally published with the Board document promptly after the EB meeting or LOT decision date.
    - If document not expected to be published within seven days, a PR is to be issued shortly after Board consideration.
    - If discussion has not reached a stage where informing the public is useful, the Board may hold publication of the PR.
    - For policy documents sent to the Board for information only, a PR is to be issued within 14 days after issuance to the Board.
    - For PRs prepared for an informal EB session, publication is deemed approved unless an ED objects by the date set in the Secretary’s cover memorandum.
  - Multi-country documents:
    - Publication of a PR requires consent from concerned members or EB approval (e.g., ESR).
- Table 1 (Press Releases: Content by Type of Document) — indicates whether a PR contains a Summing Up and/or Chair’s Statement for a range of document types (AIV Consultation, Stand-alone FSSA, Use of Fund Resources, Policy Coordination Instrument, Procedures related to failure to provide information under Article VIII, Section 5, HIPC Initiative, SMP, PMB, etc.), including notes:
  - Note 1: Internal summing up only.
  - Note 2: The Chair’s Statement relates only to the Use of Fund resources (UFRs), not the AIV consultation.
- Footnote: This section describes TP rules for PRs before the 2024 review. During the 2013 review, a decision was taken to use “press releases” for external communication products, discontinue “public information notes” (PIN), and expand translations into languages other than English.

### The Fund’s legal framework for the treatment of confidential information
- Objective
  - Protect confidential information received from members and other parties and generated internally; regulate sharing both with the public and within the Fund.
- Rules of confidentiality vis-à-vis the public
  - General principle: EB, management and staff may not disclose information that a member or other person has provided in confidence, unless that party consents and disclosure is consistent with Fund rules.
  - Determination of confidentiality is based on examination of surrounding circumstances, including the nature of the information and whether there was an understanding (expressed or implied) that it would not be disclosed without consent.
  - Where doubts exist, Fund's approach is to give the benefit of the doubt to the member or other party.
  - Three broad legal bases:
    - Article IX, Section 5 of the Fund‘s Articles of Agreement: archives of the Fund shall be inviolable; non-public documents produced by the Fund or received from members/third parties are protected and cannot be published or produced without Fund approval. Approval can be general (e.g., OAP, TP, Transmittal Policy) or case-by-case.
    - Article XII, Section 8 of the Articles of Agreement: Fund should not publish documents containing its views (meaning the EB‘s views) regarding a member without that member‘s consent, except under specified circumstances (70 percent majority provision described but never used).
    - Internal rules: Rules N-6 and N-11 of the Fund‘s Rules and Regulations, Staff Handbook, General Administrative Order No. 35 Rev.2 (GAO 35), and Code of Conduct for EB members, management, staff, and EDs prohibit unauthorized disclosures of confidential information obtained during service to the Fund.
- Rules of confidentiality within the Fund
  - Handling of confidential information within the Fund is regulated by rules on sharing with EDs, confidentiality, information security, information classification, and data privacy.
  - Confidentiality rules apply to contractual employees as per employment agreements.
  - References provided to Staff Regulation N-6, Staff Regulation N-11, Staff Handbook Chapter 11.02 Section 2.3(vi), and Code of Conduct for Members of the Executive Board with revision dates.

### Other sections (listed in contents)
- ANALYSIS OF MAC SRDSF SPECIAL DELETIONS UNDER THE TRANSPARENCY POLICY.
- TIME RULES FOR DOCUMENT SERIES UNDER THE OPEN ARCHIVES POLICY (OAP), including:
  - Category 1: Executive Board Series Available Under The Three-Year Access Rule.
  - Category 2: Executive Board Series Available Under The Five-Year Access Rule.
  - Category 3: Executive Board Series Available Under The 20-Year Access Rule.
- Tables included (titles only as listed in the source):
  - Table 1. Press Releases: Content by Type of Document.
  - Table 2. Fund Near-Term Risk Assessment Under the MAC SRDSF and Market Spreads: Surveillance and Precautionary Program Cases (as of May 2024).
  - Table 3. Executive Board Series Available Under The OAP Three-Year Access Rule.
  - Table 4. Executive Board Series Available Under The OAP Five-Year Access Rule.
  - Table 5. Executive Board Series Available Under The OAP 20-Year Access Rule.

*Prepared by Strategy, Policy, and Review Department; Approved By Mark Flanagan (SPR), Gilles Bauche (SEC), Magí Clavé Badia (ITD), Bernhard, and Steinki (LEG). Consultations with Executive Directors, Country Authorities, Mission Chiefs, and Civil Societies Organizations. October 1, 2024.*

### 9. While the authorities may provide information to Fund management and staff on the

### 9. While the authorities may provide information to Fund management and staff on the understanding that such information is to be kept confidential, there are circumstances where management and staff cannot undertake to withhold such information from the Executive Board

### Circumstances requiring disclosure to the Executive Board
- Management and staff must inform authorities when confidential information cannot be withheld from the Executive Board; broadly three circumstances are identified:
  - First, the member should not purport to withhold from the Board any information required to be reported to the Fund as a result of members‘ obligations under the Articles of Agreement.
  - Second, where the Board has established a policy requiring that certain information received from members must be disclosed to the Board, members are understood to be on notice of the existence of such a policy and are considered to have consented to such disclosure.
  - Third, in the absence of policies mandating disclosure to the Board, disclosure is required if such information is judged to be of a nature that is critical for the Board to be able to exercise its responsibility in a meaningful way.

- Context-specific illustrations:
  - Surveillance: members, management, and staff may not on grounds of confidentiality withhold from the Board any information that is required to be reported under Article VIII, Section 5 or that is otherwise judged to be necessary for the conduct of surveillance.
  - Use of Fund resources: the Board has a policy requiring Fund management and staff to disclose to the Board confidential information provided by a member in the form of a side letter.
  - Capacity development (CD) and technical assistance (TA):
    - TA reports and other final CD outputs are treated as confidential vis-à-vis the Board.
    - Fund policy requires management to share with the Board certain CD reports for the purposes of informing Board work on surveillance: Reports on Standards and Codes and Assessment of Financial Sector Supervision and Regulations.
    - High-level summaries of strategic final CD outputs are required under the Staff Operational Guidance on Dissemination of Capacity Development Information; these summaries are intended for publication (and dissemination to the Board) with the presumed consent of the CD recipient on a 30-day lapse-of-time basis and may not include confidential information.
  - If no policy mandates disclosure but management believes disclosure is necessary for the Board to make an informed decision (e.g., program review or effective surveillance), management should not recommend Board action unless the member consents to disclosure.

### Board and Executive Directors (EDs) publication constraints and secure access
- Even when information is required to be provided to the Executive Board (EB), neither the EB nor EDs can publish information provided by a member or other person on the understanding that it remains confidential vis-à-vis the public, unless the member or other person consents.
- Confidential information to the EB is typically provided via a secure platform allowing access by each ED and individually authorized member country officials.
- For the most sensitive information, EDs are provided access via uniquely identifiable encrypted documents that may not be copied or shared. All such confidential information is encrypted to prevent further distribution to non-designated individuals.
- EDs are governed by the Code of Conduct for the Members of the EB requiring them to protect the security of any confidential information provided to, or generated by, the Fund.
- Authorities are obliged to ensure applicable Fund restrictions on access to documents containing confidential information are respected, including limitations on internal access in accordance with their classification, as well as no public disclosure or citation of any confidential information.

### Confidentiality, information security, data privacy, and classification
- Confidentiality is linked to information security and requires compliance with the Fund’s rules on classification of information and information security.
- Under the Staff Handbook, Fund staff have a duty to safeguard non-public information which they create, or to which they have access in the performance of their official duties, and to comply with all applicable policies concerning information classification and information security as may be issued from time to time.
- Information security rules applicable to Fund staff are currently primarily set out in GAO 35 and in the Information Security Policies. The Information Security Framework of the Offices of EDs is set out in Decision No. a/14300-(20/106) adopted on 30 October 2020.
- For Fund staff, the originator is required to classify documents according to the following information security classifications (these classifications determine how widely available the document will be):
  - FOR OFFICIAL USE ONLY—accessible to all staff and in some cases may be shared with national officials or other authorized individuals or institutions;
  - CONFIDENTIAL—accessible on a need-to-know basis; and
  - STRICTLY CONFIDENTIAL—accessible on a strict need to know basis.
- Classification responsibilities and procedures:
  - The authoring department or office, in consultation with the Secretary of the Fund, is responsible for the classification of all documents issued to the EB and the Board of Governors and their committees if they are in the categories “for official use only” or “confidential.”
  - The Secretary, in consultation with staff/management and, for country reports, with the ED concerned, determines whether a Board document should be classified as “strictly confidential,” based on an assessment of whether the information is particularly sensitive.
  - After classification, management and staff may make the document available only to the extent envisaged under the relevant security classification and must use appropriate care to prevent unauthorized access.
  - If a document is not given a classification and it is not clear how it should be classified, staff should treat it as if it had at least FOR OFFICIAL USE ONLY classification or consult the originating department or the communications department.
- Personal information and personal data:
  - Documents that contain information about identified or identifiable individuals (personal information or personal data) are subject to additional safeguards and should be classified within the same information security categories.
  - Handling of such documents is subject to the Fund’s personal data privacy rules set out in the Personal Information Privacy Guidelines.
  - These rules will be superseded by the Fund’s Personal Data Privacy Policy, which becomes effective on May 1st, 2025.
  - The Personal Data Privacy Policy imposes additional restrictions on collection, use, retention and other processing of personal information by Fund management and staff (e.g., there needs to be a legitimate basis for processing personal information, personal information should be retained only as long as there is a valid business need for it, access should be restricted based on security classification, etc.). The Policy also establishes certain rights for individuals to access their information and seek redress if that information is mishandled.

### Protecting confidential information from accidental disclosure
- The Transparency Policy includes rules on deletion of certain types of sensitive information from documents published by the Fund, which helps avoid accidental disclosure of confidential information.
- The rules differ by document type and include procedures and timelines that must be followed for making deletions.

### Analysis of MAC SRDSF special deletions under the Transparency Policy
- An exemption introduced in July 2022 allows deletion of specific elements of the Debt Sustainability Framework for Market Access Countries (MAC SRDSF), in specific circumstances, before publication. Such deletions include:
  - Near-term sovereign risk assessment (when included with the Sovereign Risk and Debt Sustainability Assessment-SRDSA), which includes the "Near-Term Risk Analysis” and, in the main summary table, the near-term mechanical signal, the near-term final assessment, and the corresponding commentary.
  - The mechanical signal on debt sustainability (whether the assessment was mandatory or optional).
  - When debt is assessed to be sustainable, the qualification "with high probability” or “but not with high probability,” unless such qualification is required for use of Fund resources.

- Review and assessment of these deletions:
  - The Board indicated in the 2021 Review of the MAC SRDSF that it would review these deletions after 12 months of implementation. More than 18 months have passed since the implementation became mandatory for all MACs and some information is now available to reassess these deletions.
  - Observations based on implementation experience and evidence gathered:
    - Costs and consistency with debt transparency:
      - These across-the-board deletions contradict the Fund’s push for debt transparency. Debt transparency is one of the pillars of the Joint IMF/WB Multipronged Approach to Address Debt Vulnerabilities and these deletions seem inconsistent with that approach and the importance attached by the Board to debt transparency.
      - Civil society organizations and investors have criticized the Fund for lack of transparency in the MAC SRDSF, highlighting the reputational cost of these exemptions for the Fund.
    - Resource costs:
      - Implementation of these deletions carries resource cost. The set of rules for implementing these deletions is complex as deletions vary depending on whether the country has a Fund arrangement and with the type of Fund arrangement, requiring country teams to regularly check which deletions apply and how to implement them.
      - Information expected to be deleted needs to be deleted across the entire staff report, including in the middle of sentences, making deletions hard to single out and enforce and risking changes in text meaning without extensive changes as required by the Transparency Policy’s general rules.
    - Methodological confidentiality not strictly necessary:
      - The deletion of the mechanical signal on debt sustainability was initially motivated by the need to keep confidential the Fund’s mechanical rule for debt sustainability assessments. However, important components of the Fund’s decision rule for assessing debt sustainability would still remain strictly confidential, limiting the ability of the markets to infer the Fund’s decision rule for generating a mechanical signal.
    - Near-term risk assessments alignment with markets:
      - Near-term sovereign risk assessments, deleted from staff reports, are typically aligned with market assessments and publication would have rarely surprised the market on the downside.
      - The argument for deleting the near-term assessment was that publication could cause markets to react due to the short horizon associated with this assessment.
      - Experience during the first 18 months shows the Fund’s near-term assessment rarely differs from market risk perception as expressed in sovereign spreads.
      - Summary of comparison (as described in text): among MAC SRDSAs through May 2024 for which near-term risk assessment was required, classifications by near-, moderate-, and high-risk assessments produced very large overlap with low, moderate, and high sovereign spread levels; only one high near-term risk assessment was associated with moderate spreads and none with low spreads.
      - There were 4 other cases where the near-term risk assessment (moderate) was less positive than market spreads, but 10 cases where the near-term risk assessment was more positive than that implied by spreads.
      - There are 36 cases for which spreads were not available, of which only 3 were classified as high risk of near-term sovereign stress.
      - Note: the logit model used for this assessment has been published in the SRDSF guidance note, making it relatively easy for market actors to forecast the near-term risk mechanical signal.
    - Mechanical signals vs. final assessment:
      - Since the rollout of the MAC SRDSF started, there have been 3 cases out of 57 where mechanical signals on debt sustainability assessment were worse than the final assessment. In these cases, results from the medium-term tools were already published, providing the relevant information to the market (Egypt 2022, 2024, and Gabon 2024).
    - Accidental publications and market reaction:
      - Where the near-term assessment and/or the three-way debt sustainability assessment were by mistake published, publication triggered no market reaction.
      - An event study using the rollout period since mid-2022 identified seven inadvertent publication cases and indicates no significant market reaction to the publication of this information.
      - Caveats to the event study: (i) small number of events; and (ii) in all these events the information provided did not include negative news (assessments indicated low risk and debt being sustainable with high probability), which could bias results if market reaction to positive and negative news is not symmetric.
  - Overall conclusion:
    - Evidence so far is preliminary and further experience with the application of the MAC SRDSF and related deletions will continue to accumulate.
    - Outcomes of the framework are generally aligned with market perceptions and information, although a few tail cases have emerged.
    - Further experience will help shed additional light on concerns about market sensitivity of SRDSF outputs, which underpin the current exemption of elements of the MAC SRDSF from the Transparency Policy’s deletion rules.

### Time rules for document series under the Open Archives Policy (OAP)
- Category 1: Executive Board Series Available Under The Three-Year Access Rule (20 years for those pertaining to the Fund’s physical and cyber security vulnerabilities)
  - Document series listed include: BUFF (Chairman’s Summing Up or Concluding Remarks Only), BUFF statements by Managing Director and Staff Representatives to EB on matters not related to use of UFR, PSI, and PCI, BUFF/ED statements by EDs to Board on matters not related to UFR/PSI/PCI, DEC (EB Decisions on matters not related to use of UFR/PSI/PCI), DEC/A (Administrative Decisions on matters not related to use of UFR/PSI/PCI), EB/A (EB Meetings Agendas), EB (various) (EB Committees—including Agendas, Documents, Statements, Undocumented Papers), EBAM (EB Administrative Matters), EBAP (EB Administrative Papers), EBC (EB Meetings Calendar), EBD (EB Documents), EBM (EB Minutes on matters not related to use of UFR/PSI/PCI), EBS (EB Specials), FEFM (Foreign Exchange and Financial Markets), FO/Dis (Front Office Informal Distribution), Gray (Preliminary Version of ED’s Statements to EB on matters not related to use of UFR/PSI/PCI), Green (Statements by EDs on Matters for Lapse of Time Consideration not related to use of UFR/PSI/PCI), IS/A (Secretary’s Journal of Informal Sessions Agendas), RP/CP (Pension Committee), RP/CP/A (Pension Committee Agendas), RP/CP/U (Pension Committee Undocumented Papers), SEC/Circ (Secretary’s Circulars), SM (Staff Memoranda), SU (Chair’s Summing Ups), SUR (Surveillance-related Chair’s Summing Ups), and UNDOC (Undocumented Papers).
- Category 2: Executive Board Series Available Under The Five-Year Access Rule (20 years for those pertaining to the Fund’s physical and cyber security vulnerabilities)
  - Document series listed include: BUFF (Statements by Managing Director and Staff Representatives to EB on matters related to use of UFR, PSI, and PCI), BUFF/ED (Statements by EDs to EB on matters related to use of UFR, PSI, and PCI), DEC (EB Decisions on matters related to use of UFR, PSI, and PCI), DEC/A (Administrative Decisions on matters related to use of UFR, PSI, and PCI), DM (Departmental Memoranda), EB (various) (EB Committees—Minutes), EBM (EB Minutes on matters related to use of UFR, PSI, and PCI), EBM/R (Restricted EB Minutes (classified Strictly Confidential) on matters related to use of UFR, PSI, and PCI), Gray (Preliminary Version of EDs’ Statements to EB on matters related to use of UFR, PSI, and PCI), Green (Statements by EDs on Matters for Lapse of Time Consideration related to use of UFR, PSI, and PCI), IS/Mtg (Secretary’s Journal of Informal Sessions Minutes), Précis/Mtg (Précis of EB Meetings (replaced by Weekly Précis)), RP/CP/Mtg (Pension Committee Minutes), SEM/A (EB Seminar Agendas), SEM/Mtg (EB Seminar Minutes), WDR (Weekly Decision Report), Weekly/Précis/Mtg (Précis of EB Meetings (replaced by Weekly Decision Report)).
- Category 3: Executive Board Series Available Under The 20-Year Access Rule
  - Document series listed include: EB/EVC/Mtg (Evaluation Committee Minutes).

*International Monetary Fund — 2024 Review of the Fund’s Transparency Policy and Open Archives Policy—Key Concepts and Supportive Analysis*

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_Source: https://www.imf.org/-/media/files/publications/pp/2024/english/ppea2024060.pdf_