## Section I. Detailed Assessment and Recommendations

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### Overall Assessment
- Assessment against the IMF’s Data Quality Assessment Framework (DQAF) for Public Sector Debt Statistics (PSDS) 2024.
- Mission undertaken under a two-year project funded by the Government of Japan through the Japan Administered Account for Selected IMF Activities (JSA).
- Mission dates: January 29 to February 4, 2025.
- Agencies compiling datasets assessed: Ministry of Finance and Economic Affairs (MoFEA), Reserve Bank of Malawi (RBM), National Statistical Office of Malawi (NSO).
- Key contextual facts:
  - Malawi’s total public sector debt rose from 48 percent of GDP in March 2020 to 93 percent of GDP in March 2024 (MoFEA figures).
  - IMF granted a 48-month financing arrangement under the Extended Credit Facility (ECF) in November 2023.
  - Latest IMF-World Bank debt sustainability analysis (DSA) indicates Malawi is in debt distress.
  - Coverage of published Malawi public sector debt: central government, Central Bank, and guaranteed debts of State-Owned Enterprises (SOEs).
  - Public Finance Management Act 2022 (PFMA, 2022), Public Finance Management (Debt and Aid Management) Regulation 2023 (PFMR, 2023), and 2024 Guidelines for Guarantees, “On-lending and Borrowing by Public Bodies” provide legal framework developments.
  - MoFEA moved from biannual to quarterly debt reporting in August 2024; only one quarterly debt report published so far.
- General conclusion: PSDS are broadly reliable and improving; sustained commitment needed to enhance debt data transparency and accountability.

### A. Prerequisites of Quality
- Findings:
  - Legal environment:
    - Primary responsibility for collecting, processing, and disseminating public debt statistics established but not explicitly entrenched in law.
    - Article 6, (1), (g)) of PFMA, 2022 gives the Treasury overall responsibility for public debt management, but PFMR, 2023 is not explicit about the responsible agency/department for operationalizing these functions.
  - Institutional environment:
    - Data sharing and coordination among debt data-producing agencies broadly adequate; flow of information is generally efficient and well-coordinated.
    - A Memorandum of Understanding between MoFEA and RBM to formalize data sharing on domestically issued debt has been drafted but not signed.
    - Lags exist in timely availability of data, particularly for payment arrears where verified accounts payables (by the Auditor General’s Office) are not always timely.
  - Resources:
    - Human and financial resources generally commensurate with DAD responsibilities.
    - Computing resources and IT infrastructure largely inadequate; most new staff rely on personal computers—only three out of ten new staff have a desk top computer.
    - Urgent need to secure resources (including the new Integrated Financial Management Information System (IFMIS)) to facilitate integration of DAD’s CS Meridian with RBM’s Central Securities Depository (CSD).
- Priority recommendations:
  - Consider a slight modification of PFMA, 2022 and introduction of new legislation explicitly assigning debt and aid management responsibilities to DAD.
  - Conclude and sign the MoFEA–RBM Memorandum of Understanding to formalize data sharing arrangements.
  - Secure computing resources and IT infrastructure, and implement integration between CS Meridian and RBM’s CSD (including IFMIS linkage).

### B. Assurances of Integrity
- Findings:
  - DAD staff compile PSDS on an impartial basis; professional independence is recognized and supported by MoFEA.
  - Compilation guided by PSDSG 2013 and GFSM 2014; DAD staff free from political or other influence in choosing sources and methods.
  - Public debt statistics are reviewed and validated by DAD management prior to publication clearance by the Minister.
  - Internal data sharing arrangements exist for information from other government departments (e.g., SOEs, accounts payables).
  - Capacity constraints: staff need substantial training to compile PSDS fully in accordance with PSDSG 2013 and GFSM 2014.
  - Publication timeliness and regularity need improvement.
- Priority recommendations:
  - Strengthen capacity through sustained training on PSDSG 2013 and GFSM 2014 methodologies.
  - Regularly publish key debt reports and annual statements in a timely manner to enhance transparency.
  - Publish the terms and conditions under which PSDS are collected, processed, and disseminated.
  - Develop and promulgate a DAD-specific code of conduct to guide staff.

### C. Methodological Soundness
- Findings:
  - Concepts and definitions of government debt broadly aligned with international standards:
    - Recognized as debt: disbursed outstanding debt and other accounts payable (including expenditure arrears).
    - Contingent liabilities (guarantees) are recorded as supplementary information.
  - Debt reports present data by instrument, currency, creditor residency, remaining maturity, and value external debt using mid-point exchange rates.
  - PSDS reports cover loans and debt securities of the budgetary central government and borrowing by RBM on behalf of central government or wider public sector.
  - Over 95 percent of all public sector borrowing in the form of loans and debt securities is captured in the reports.
  - Important gaps:
    - Need to expand instrument coverage to include other accounts payable (which incorporate expenditure arrears) as recognized in PFMR, 2023.
    - Significant part of public sector liabilities incurred as arrears; clarity needed on magnitude of outstanding accounts payable by counterpart sector/subsector.
    - When extending coverage, consolidation principles must be applied because significant accounts payables exist between budgetary central government and other subsectors.
  - Specific observations:
    - Debt stocks are reported at face value and debt flows on a cash basis rather than nominal value and accrual basis.
    - Foreign currency debt converted using mid-point exchange rate; debt reported gross, market value for debt securities not shown as a memorandum item.
    - At end of March 2024, non-guaranteed direct borrowing of public entities was around 300 billion MK and payables of local governments 15 billion MK (about 2 percent of total reported public debt).
- Priority recommendations:
  - Expand coverage to include other accounts payable (including expenditure arrears) with initial focus on local governments and public corporations.
  - Apply consolidation principles when extending PSDS coverage to avoid double counting from inter-subsector accounts payables.
  - Report PSDS using a nominal valuation (including accrual of interest) and present consolidated data as coverage expands.
  - Show market value of government debt securities as a memorandum item.
  - Expand debt reports to include internationally standardized tables presenting PSDS by instrument, creditor residency, original maturity, residual maturity, and currency.

### D. Accuracy and Reliability
- Findings:
  - Data provenance:
    - RBM is source for government debt securities.
    - MoFEA is data owner for external government borrowing.
    - External debt data held on CS Meridian; debt securities managed by RBM’s CSD.
  - Systems and validation:
    - CS Meridian automates and facilitates validation; CSD subject to validation processes.
    - Lack of an interface between CSD and CS Meridian complicates compilation, introduces inefficiencies and manual error risks.
  - Operational risks:
    - Network/connection issues to CS Meridian prevented DAD access since early December 2024; prevented validation of debt payments, entry of new debts, and production of debt reports.
    - Issue was connection-related rather than server-related; possible solutions include cloud hosting by the Commonwealth Secretariat.
    - Connection to CS Meridian was restored shortly after the mission.
  - Quality practices recommended:
    - Regularly produce two reconciliation tables:
      - Reconciliation A: explain how the change in debt stocks over a period is explained by debt flows.
      - Reconciliation B: reconcile government deficit/surplus in a period with the change in debt stocks to highlight drivers of debt.
    - Monitor and demonstrate consistency in compiled PSDS as a quality metric and for user confidence.
- Priority recommendations:
  - Automate information exchange between CS Meridian and RBM’s CSD.
  - Implement measures to avoid future connectivity disruptions to CS Meridian (including consideration of cloud hosting).
  - Produce regular reconciliation tables to demonstrate consistency and drivers of changes in debt stocks.
  - Include and validate guarantee data in CS Meridian.

### E. Serviceability
- Findings:
  - Timeliness and periodicity:
    - Statistical good practice: publish quarterly PSDS within a quarter of end of reporting period.
    - Quarterly PSDS bulletin introduced in August 2024 covering 2023Q3 - 2024Q2 with two-month timeliness after reporting period.
    - Timeliness not maintained; no further quarterly bulletin published at mission time.
    - DAD compiled a quarterly report in November 2024 that was not yet cleared for publication.
    - MoFEA dissemination of PSDS did not follow a predictable pattern; most recent quarterly data at mission was end-June 2024 (seven months previous).
    - Annual PSDS generally disseminated three months after end of year but periodicity not always followed; biannual reports published for two of last five years.
  - Need for dissemination discipline:
    - Establish a release calendar indicating expected publication dates for each debt report.
    - Develop, publish, and implement a PSDS revision policy explaining timing and drivers of revisions.
  - Cross-publication consistency:
    - Difficulty comparing data across different statistical reports; macro publications use calendar year while debt statistics use financial years complicating consistency analysis.
    - Establishment of quarterly debt time series will assist comparability.
    - Compilers in MoFEA, RBM, and NSO should regularly review, identify, and report on differences across macroeconomic statistical reports.
- Priority recommendations:
  - Publish a release calendar and adhere to it.
  - Develop and publish a PSDS revision policy.
  - Establish and maintain quarterly debt time series and regular cross-agency reconciliation of macroeconomic reports.
  - Regularly check and explain inconsistencies across MoFEA, RBM, and NSO publications; provide metadata explaining differences.
  - Flag preliminary data in footnotes where applicable.

### F. Accessibility
- Findings:
  - Presentation:
    - PSDS reports include clear commentary, charts, and tables that support non-expert users.
    - DAD provides contact details and responds to user queries, including bespoke data requests (e.g., extended time series).
  - Limitations for expert users:
    - Reports are only available as searchable pdf files; expert users prefer downloadable formats (e.g., MS Excel).
    - Metadata in current reports is difficult to find and insufficient in detail and coverage.
  - Dissemination opportunities:
    - Recommendation to (re)disseminate quarterly PSDS through the IMF-World Bank Joint Quarterly Public Sector Debt (QPSD) statistics database and Malawi’s National Summary Data Page (NSDP).
      - Benefits: increases visibility, metadata clarity (standard structure), and allows data download in multiple formats including MS Excel.
    - DAD encouraged to include a core set of standard tables and graphics in every PSDS bulletin (perhaps in an annex) to facilitate easy comparison between reports.
- Priority recommendations:
  - Disseminate PSDS via QPSD and NSDP to improve visibility, metadata quality, and data downloadability.
  - Provide downloadable data formats (including MS Excel) to cater to expert users.
  - Enhance and publish detailed metadata and include a core set of standard tables/graphics in each PSDS bulletin.
  - Provide data in MS Excel, csv, SDMX formats and renew dissemination via QPSD and NSDP.

### Staff, facilities, computing resources, and financing
- Findings:
  - Human and financial resources devoted to PSDS compilation generally commensurate with DAD responsibilities.
  - Computing resources inadequate; only three out of ten new staff have a desk top computer.
  - Plans underway to implement updated IFMIS to facilitate data exchange with RBM and eventual integration of DAD CS Meridian and RBM CSD.
- Recommendations:
  - Enhance computing and information technology resources.
  - Implement more modules in upgraded IFMIS to enable electronic sharing of debt information and integration with RBM’s CSD and the Auditor General’s verified accounts payables data.
  - Capture checks, validations and reconciliation processes in compilation documentation.

### CS Meridian, CSD interface, and IT continuity
- Findings:
  - CS Meridian currently used only to manage and report external borrowing; external debt reports from CS Meridian must be manually combined with other sources.
  - Data on debt securities (issuances, payments, redemptions) held by RBM’s CSD; data extracted and shared with DAD on request (typically monthly) in MS Excel.
  - CS Meridian was inaccessible to DAD staff since early December 2024 due to a network fault; access was restored shortly after the mission.
- Recommendations:
  - Expand CS Meridian coverage to house all public sector debt data.
  - Interface CSD directly with CS Meridian to remove manual extraction and reconciliation.
  - Implement measures to avoid CS Meridian access interruptions and consider cloud hosting or other continuity solutions.
  - Capture and document validation, quality assurance, and reconciliation practices; compile and publish reconciliation tables (Annex III Tables 2 and 3 provide examples).

### Consolidated Recommendations (selected)
- Expand data in CS Meridian to include direct (non-guaranteed) borrowing of local governments, extrabudgetary units, and public corporations, and accounts payable (including expenditure arrears) of all public entities.
- Interface CS Meridian with the RBM CSD to improve efficiency and reduce manual errors.
- Include and validate guarantee data in CS Meridian.
- Assess the materiality of PPPs and finance leases and capture non-cash liabilities.
- Compile and publish reconciliation tables:
  - Reconciliation between change in debt stocks and debt flows.
  - Reconciliation between change in debt stocks and government deficit/surplus.
- Periodically analyze revisions and publish a PSDS revision policy.
- Publish a release calendar; disseminate quarterly debt data within 3 months of the end of the quarter.
- Standardize core tables and graphics in debt reports and provide comprehensive metadata.
- Provide data in MS Excel, csv, SDMX formats and renew dissemination via QPSD and NSDP.
- Promote and document the on-request user service; include contact email and maintain logs of queries.

### Strengths (as reported)
- Flow of information needed to compile Malawi’s PSDS is efficient and well-coordinated.
- Malawi migrated external debt data from CS-DRMS to CS Meridian and validated migrated data.
- Granular information on issuance, trading and redemption of debt securities is maintained by RBM on the CSD.
- Timely and comprehensive source data on district and city councils (local government) can be leveraged to extend sector coverage.
- PSDS reports include commentary and charts/tables that assist non-expert users.
- CS Meridian functionality can enable PSDS production consistent with international standards once coverage expanded.

### APPENDIX II. USERS’ SURVEY RESULTS
- Overview:
  - Total respondents: 12.
  - Respondent types: financial institutions, regional organizations, foreign governments, research institutes, media, NGOs, Parliament of Malawi.
  - Nearly all respondents used the national debt bulletins; all respondents felt disseminated PSDS were at least somewhat analytically useful.
  - Common concerns: timeliness and narrow coverage (raised by two users).
- Coverage and concepts — instruments inadequately covered (response counts):
  - Accounts payables (arrears): 7
  - Loans: 2
  - Debt securities: 4
  - Pension liabilities: 4
  - None – adequate for all instruments: 0
  - Other: 1
- Coverage — subsectors users want more coverage (response counts):
  - Local government / State governments: 7
  - Public corporations: 10
  - Budgetary central government: 5
  - Extra-budgetary units: 9
  - None – adequate for all subsectors: 0
- Valuation of outstanding stock positions:
  - Yes: 10
  - No: 2
- Periodicity and timeliness — satisfaction with periodicity (response counts):
  - Very satisfied: 1
  - Satisfied: 6
  - Neither satisfied nor dissatisfied: 3
  - Dissatisfied: 2
  - Very dissatisfied: 0
- Are PSDS disseminated in a sufficiently timely manner?
  - Yes: 5
  - No: 5
  - Not sure: 2
- Dissemination practices — awareness of release schedule:
  - Yes, sometimes released on schedule: 2
  - No: 1
  - Not sure: 9
- Are users informed whether data are preliminary, revised or updated?
  - Always informed: 1
  - Sometimes informed: 4
  - Never informed: 1
  - Not aware: 6
- Accessibility and usefulness:
  - Presented to facilitate interpretation and comparisons:
    - Agree: 8
    - Neither agree nor disagree: 3
    - Strongly disagree: 1
  - Is comprehensive metadata readily accessible?
    - Yes, available and accessible: 3
    - Partial information available: 4
    - Not sure: 5
- Selected overall assessment statistics:
  - Are the disseminated PSDS analytically useful?
    - Very useful: 6
    - Useful: 4
    - Somewhat useful: 2
  - The disseminated PSDS are unbiased and accurate:
    - Agree: 8
    - Neither agree nor disagree: 3
    - Disagree: 1
  - Level of satisfaction with timeliness and level of detail:
    - Satisfied: 7
    - Neither satisfied nor dissatisfied: 3
    - Dissatisfied: 1
    - Very dissatisfied: 1

*Source: Section I. Detailed Assessment and Recommendations, IMF Technical Report – Malawi Data Quality Assessment for Public Sector Debt Statistics.*

### Section I. Detailed Assessment and Recommendations .....................................................................

### Section I. Detailed Assessment and Recommendations

### Overall Assessment
- Assessment against the IMF’s Data Quality Assessment Framework (DQAF) for Public Sector Debt Statistics (PSDS) 2024.
- Mission undertaken under a two-year project funded by the Government of Japan through the Japan Administered Account for Selected IMF Activities (JSA).
- Mission dates: January 29 to February 4, 2025.
- Agencies compiling datasets assessed: Ministry of Finance and Economic Affairs (MoFEA), Reserve Bank of Malawi (RBM), National Statistical Office of Malawi (NSO).
- Key contextual facts:
  - Malawi’s total public sector debt rose from 48 percent of GDP in March 2020 to 93 percent of GDP in March 2024 (MoFEA figures).
  - IMF granted a 48-month financing arrangement under the Extended Credit Facility (ECF) in November 2023.
  - Latest IMF-World Bank debt sustainability analysis (DSA) indicates Malawi is in debt distress.
  - Coverage of published Malawi public sector debt: central government, Central Bank, and guaranteed debts of State-Owned Enterprises (SOEs).
  - Public Finance Management Act 2022 (PFMA, 2022), Public Finance Management (Debt and Aid Management) Regulation 2023 (PFMR, 2023), and 2024 Guidelines for Guarantees, “On-lending and Borrowing by Public Bodies” provide legal framework developments.
  - MoFEA moved from biannual to quarterly debt reporting in August 2024; only one quarterly debt report published so far.
- General conclusion: PSDS are broadly reliable and improving; sustained commitment needed to enhance debt data transparency and accountability.

### A. Prerequisites of Quality
Findings:
- Legal environment:
  - Primary responsibility for collecting, processing, and disseminating public debt statistics established but not explicitly entrenched in law.
  - Article 6, (1), (g)) of PFMA, 2022 gives the Treasury overall responsibility for public debt management, but PFMR, 2023 is not explicit about the responsible agency/department for operationalizing these functions.
- Institutional environment:
  - Data sharing and coordination among debt data-producing agencies broadly adequate; flow of information is generally efficient and well-coordinated.
  - A Memorandum of Understanding between MoFEA and RBM to formalize data sharing on domestically issued debt has been drafted but not signed.
  - Lags exist in timely availability of data, particularly for payment arrears where verified accounts payables (by the Auditor General’s Office) are not always timely.
- Resources:
  - Human and financial resources generally commensurate with DAD responsibilities.
  - Computing resources and IT infrastructure largely inadequate.
  - Urgent need to secure resources (including the new Integrated Financial Management Information System (IFMIS)) to facilitate integration of DAD’s CS Meridian with RBM’s Central Securities Depository (CSD).

Priority recommendations:
- Consider a slight modification of PFMA, 2022 and introduction of new legislation explicitly assigning debt and aid management responsibilities to DAD.
- Conclude and sign the MoFEA–RBM Memorandum of Understanding to formalize data sharing arrangements.
- Secure computing resources and IT infrastructure, and implement integration between CS Meridian and RBM’s CSD (including IFMIS linkage).

### B. Assurances of Integrity
Findings:
- DAD staff compile PSDS on an impartial basis; professional independence is recognized and supported by MoFEA.
- Compilation guided by PSDSG 2013 and GFSM 2014; DAD staff free from political or other influence in choosing sources and methods.
- Public debt statistics are reviewed and validated by DAD management prior to publication clearance by the Minister.
- Internal data sharing arrangements exist for information from other government departments (e.g., SOEs, accounts payables).
- Capacity constraints: staff need substantial training to compile PSDS fully in accordance with PSDSG 2013 and GFSM 2014.
- Publication timeliness and regularity need improvement.

Priority recommendations:
- Strengthen capacity through sustained training on PSDSG 2013 and GFSM 2014 methodologies.
- Regularly publish key debt reports and annual statements in a timely manner to enhance transparency.

### C. Methodological Soundness
Findings:
- Concepts and definitions of government debt broadly aligned with international standards:
  - Recognized as debt: disbursed outstanding debt and other accounts payable (including expenditure arrears).
  - Contingent liabilities (guarantees) are recorded as supplementary information.
- Debt reports present data by instrument, currency, creditor residency, remaining maturity, and value external debt using mid-point exchange rates.
- PSDS reports cover loans and debt securities of the budgetary central government and borrowing by RBM on behalf of central government or wider public sector.
- Over 95 percent of all public sector borrowing in the form of loans and debt securities is captured in the reports.
- Important gaps:
  - Need to expand instrument coverage to include other accounts payable (which incorporate expenditure arrears) as recognized in PFMR, 2023.
  - Significant part of public sector liabilities incurred as arrears; clarity needed on magnitude of outstanding accounts payable by counterpart sector/subsector.
  - When extending coverage, consolidation principles must be applied because significant accounts payables exist between budgetary central government and other subsectors.
- Recommendation to focus initially on accounts payables related to local governments and public corporations due to good existing data sources from accrual accounting adoption.

Priority recommendations:
- Expand coverage to include other accounts payable (including expenditure arrears) with initial focus on local governments and public corporations.
- Apply consolidation principles when extending PSDS coverage to avoid double counting from inter-subsector accounts payables.

### D. Accuracy and Reliability
Findings:
- Data provenance:
  - RBM is source for government debt securities.
  - MoFEA is data owner for external government borrowing.
  - External debt data held on CS Meridian; debt securities managed by RBM’s CSD.
- Systems and validation:
  - CS Meridian automates and facilitates validation; CSD subject to validation processes.
  - Lack of an interface between CSD and CS Meridian complicates compilation, introduces inefficiencies and manual error risks.
- Operational risks:
  - Network/connection issues to CS Meridian prevented DAD access since early December 2024; prevented validation of debt payments, entry of new debts, and production of debt reports.
  - Issue was connection-related rather than server-related; possible solutions include cloud hosting by the Commonwealth Secretariat.
  - Connection to CS Meridian was restored shortly after the mission.
- Quality practices recommended:
  - Regularly produce two reconciliation tables:
    - Reconciliation A: explain how the change in debt stocks over a period is explained by debt flows.
    - Reconciliation B: reconcile government deficit/surplus in a period with the change in debt stocks to highlight drivers of debt.
  - Monitor and demonstrate consistency in compiled PSDS as a quality metric and for user confidence.

Priority recommendations:
- Automate information exchange between CS Meridian and RBM’s CSD.
- Implement measures to avoid future connectivity disruptions to CS Meridian (including consideration of cloud hosting).
- Produce regular reconciliation tables to demonstrate consistency and drivers of changes in debt stocks.

### E. Serviceability
Findings:
- Timeliness and periodicity:
  - Statistical good practice: publish quarterly PSDS within a quarter of end of reporting period.
  - Quarterly PSDS bulletin introduced in August 2024 covering 2023Q3 - 2024Q2 with two-month timeliness after reporting period.
  - Timeliness not maintained; no further quarterly bulletin published at mission time.
  - DAD compiled a quarterly report in November 2024 that was not yet cleared for publication.
- Need for dissemination discipline:
  - Establish a release calendar indicating expected publication dates for each debt report.
  - Develop, publish, and implement a PSDS revision policy explaining timing and drivers of revisions.
- Cross-publication consistency:
  - Difficulty encountered comparing data across different statistical reports to ensure consistency.
  - Establishment of quarterly debt time series will assist comparability.
  - Compilers in MoFEA, RBM, and NSO should regularly review, identify, and report on differences across macroeconomic statistical reports.

Priority recommendations:
- Publish a release calendar and adhere to it.
- Develop and publish a PSDS revision policy.
- Establish and maintain quarterly debt time series and regular cross-agency reconciliation of macroeconomic reports.

### F. Accessibility
Findings:
- Presentation:
  - PSDS reports include clear commentary, charts, and tables that support non-expert users.
  - DAD provides contact details and responds to user queries, including bespoke data requests (e.g., extended time series).
- Limitations for expert users:
  - Reports are only available as searchable pdf files; expert users prefer downloadable formats (e.g., MS Excel).
  - Metadata in current reports is difficult to find and insufficient in detail and coverage.
- Dissemination opportunities:
  - Recommendation to (re)disseminate quarterly PSDS through the IMF-World Bank Joint Quarterly Public Sector Debt (QPSD) statistics database and Malawi’s National Summary Data Page (NSDP).
    - Benefits: increases visibility, metadata clarity (standard structure), and allows data download in multiple formats including MS Excel.
  - DAD encouraged to include a core set of standard tables and graphics in every PSDS bulletin (perhaps in an annex) to facilitate easy comparison between reports.

Priority recommendations:
- Disseminate PSDS via QPSD and NSDP to improve visibility, metadata quality, and data downloadability.
- Provide downloadable data formats (including MS Excel) to cater to expert users.
- Enhance and publish detailed metadata and include a core set of standard tables/graphics in each PSDS bulletin.

*Source: Section I. Detailed Assessment and Recommendations, IMF technical report on Malawi Data Quality Assessment for Public Sector Debt Statistics.*

### 0. Prerequisites of quality

### 0. Prerequisites of quality

### 0.1 Legal and institutional environment
- Finding: The flow of information needed to compile Malawi’s public sector debt statistics (PSDS) is efficient and well-coordinated. The sharing of data for public debt reporting between government data agencies and different departments in the MoFEA is well established, with no obstacles in the flow of data.
- Finding: The PFMA, 2022 gives the Treasury the overall responsibility of public debt management, but the specific responsibilities for collecting, processing, and disseminating debt statistics are not explicitly specified in the law and accompanying regulation (PFMR, 2023).
- Recommendation: Consider a slight modification of PFMA, 2022 and introduction of new legislation (Public Debt Management Act) explicitly assigning debt and aid management responsibilities to DAD. This will make it more explicit that DAD in MoFEA is the responsible agency for collecting, processing, and disseminating public sector debt statistics of Malawi in line with intended spirit in the legislation (PFMR, 2023, Article 8 (2)) and the trend in emerging market economies.
- Additional detail (Section I): The DAD of the MoFEA is responsible for front, middle, and back-office functions of public debt management but specific responsibilities are not well articulated in law. A Memorandum of Understanding between the MoFEA and RBM to facilitate data sharing on domestically issued debt has been drafted but not yet signed. Verified accounts payables from the Auditor General’s Office are not always available on a timely basis. The Malawian National Statistics Act (NSA), July 2013 (Article 13 (i) and 14) and the Code of Practice for Official Statistics (May 2023) provide confidentiality provisions; DAD may wish to develop and promulgate its own code of practice.

### 0.2 Resources
- Finding: The human and financial resources devoted to the compilation, processing, and dissemination of PSDS are, in general, commensurate with DAD’s assigned responsibilities.
- Finding: Computing resources and information management systems are inadequate to facilitate efficient exchange of debt information.
- Recommendation: DAD to implement the upgraded IFMIS system to be able to share debt information electronically including possible integration of DAD’s CS Meridian and the RBM’s CSD, as well as the Auditor General Office (for data on verified accounts payables).

### 0.3 Relevance
- Finding: The DAD compiles and publishes data on the public sector debt to meet various user needs including preparation of the Medium-Term Debt Strategy, Annual Budget Statement, Annual Public Debt Report, Quarterly Debt Bulletin, etc.
- Finding: User surveys are not undertaken to monitor the relevance of PSDS in meeting users’ needs.
- Recommendation: DAD should undertake user surveys to monitor the relevance of published PSDS in meeting users’ needs and user’s sentiments on timeliness of its products.

### 0.4 Other quality management
- Finding: The DAD adheres to the Code of Practice for official statistics which dictates that public debt data and information must be based on the right sources of statistical data with transparent judgements about definitions and methods, and judgements about the strengths and limitations of the statistical data and information.

### 1. Assurances of integrity

### 1.1 Professionalism
- Finding: PSDS have traditionally been compiled and disseminated on an impartial basis. The MoFEA establishes the professional independence of the departments responsible for these statistics. DAD staff are, in practice, free from political, or other influence, in choosing the most appropriate sources and methods for compiling public debt statistics.
- Finding: Public debt statistics are carefully reviewed and validated by the management of the DAD before they are cleared for publication and dissemination but there is need for further training.
- Recommendation: Staff involved in compiling PSDS continue to need substantial training to compile PSDS in accordance with the standards set in the PSDSG 2013 and GFSM 2014 framework.
- Recommendation: Enhance debt data transparency by regularly publishing the key debt reports and annual statements on a timely manner.

### 1.2 Transparency
- Finding: DAD enjoys a reasonable degree of autonomy in carrying out its functions which guarantees that no government authority has access to its statistics before they are cleared by the Minister for publication and simultaneous access to all.
- Finding: The terms and conditions under which PSDS are collected, processed, and disseminated are not publicly available.
- Recommendation: Publish the terms and conditions under which PSDS are collected, processed, and disseminated to the public.

### 1.3 Ethical standards
- Finding: All levels of management are aware of the pressing need to ensure irreproachable conduct within and beyond the MoFEA, and for officials to fulfill their obligations to maintain the public credibility of the debt data they process.
- Finding: Staff generally could not remember the specific details of the code of conduct for civil servants.
- Recommendation: Considering the analytical usefulness of public debt statistics, DAD to consider developing and promulgating its own code of conduct to guide staff in promoting professionalism, transparency, impartiality, and integrity in the compilation and dissemination of PSDS.

### 2. Methodological soundness

### 2.1 Concepts and definitions
- Finding: In line with GFSM 2014, only disbursed outstanding debt is recognized as debt, with contingent liabilities (guarantees) recorded separately.
- Finding: Time of recording is aligned with statistical standards and debt statistics reports include information on debt instruments, creditor residency, currency, and remaining maturity.

### 2.2 Scope
- Finding: Sector coverage is limited to budgetary central government and central bank borrowing (on behalf of the public sector) with data for local governments and non-guaranteed debt of extrabudgetary units and public corporations missing.
- Finding: With regard to debt instruments, only the liabilities in the form of loans and debt securities are reported, despite expenditure arrears known to be highly material in magnitude.
- Recommendation: Extend the sector coverage of the core PSDS reports through the inclusion of local governments and the non-guaranteed borrowing of extrabudgetary units and public corporations.
- Recommendation: Extend the instrument coverage to include other accounts payable (which will include expenditure arrears).

### 2.3 Classification / sectorization
- Finding: Although debt securities and loans are separately identifiable, as is domestic and external debt, the main debt reports do not use the standardized presentation or nomenclature of the international statistical standards. In particular what is reported as domestic debt includes elements of external debt (by residency).
- Recommendation: Expand the debt reports to include internationally standardized tables which present the PSDS by instrument, creditor residency, original maturity, residual maturity, and currency over an extended time period.

### 2.4 Time of debt recording, valuation, and consolidation
- Finding: Debt stocks are reported at face value and debt flows on a cash basis, rather than the preferred nominal value and accrual basis.
- Finding: Foreign currency debt is converted using the midpoint exchange rate and all debt is reported on a gross basis, but debt is not consolidated nor is the market value for debt securities shown as a memorandum item.
- Recommendation: Report PSDS using a nominal valuation (which includes the accrual of interest), and as the sector coverage is expanded the data should be presented on a consolidated basis.
- Recommendation: The market value of government debt securities should be shown as a memorandum item.

### 3. Accuracy and reliability

### 3.1 Source data
- Finding: Source data on debt securities and external lending appear robust but were very significantly hampered by network issues that led to the CS Meridian not being accessible by compilers between December 2024 and February 2025.
- Finding: Existing administrative data on local governments and public entities could be leveraged to expand the sector coverage of PSDS, while quality and coverage of data on arrears needs improvement.
- Recommendation: Expand the data available in CS Meridian to include administrative data on the direct (non-guaranteed) borrowing of local governments, extrabudgetary units, and public corporations, as well as accounts payable (including expenditure arrears) of all public entities.

### 3.2 Assessment of source data
- Finding: Source data on loans are subject to validation against creditor records and stocks reconciled against debt-related flows. Debt securities data is compiled by both the RBM and the MoFEA with any differences investigated. Compilation of data on guaranteed debt is less systematic.
- Recommendation: Interface CS Meridian with the CSD to improve efficiency and reduce the risk of errors being introduced through manual processing.
- Recommendation: Include and validate guarantee data in CS Meridian.

### 3.3 Statistical techniques
- Finding: On-lending arrangements are correctly captured; however, data are on a cash basis and no statistical techniques are employed to capture non-cash liabilities (such as those related to finance leases and public-private partnerships (PPPs)).
- Recommendation: Review the materiality of liabilities related to PPPs and finance leases.

### 3.4 Assessment and Validation of Statistical Outputs
- Finding: Although CS Meridian enforces consistency between debt stocks and related flows, there is no evidence of wider reconciliation being undertaken and discrepancies investigated.
- Finding: There is a need to ensure that changes in total debt stocks are fully explained and that annual changes in debt are reconciled with cash deficits/surpluses in the same period.
- Recommendation: Compile and publish reconciliation tables between (i) change in debt stocks and debt flows, and (ii) change in debt stocks and the government deficit/surplus; using these reconciliations to identify and investigate discrepancies.

### 3.5 Revision studies
- Finding: Although there is evidence in the MoFEA debt reports of debt stocks being revised between reports, there is no analysis or explanations of these revisions.
- Recommendation: Periodically analyze revisions to understand the drivers of revisions and use the results of the analysis to inform PSDS compilation procedures.

### 4. Serviceability

### 4.1 Periodicity and timeliness
- Finding: MoFEA dissemination of PSDS does not follow a predictable pattern. At the time of the mission the most recent quarterly data was from end-June 2024 (seven months previous) in part due to the network issues that have led to CS Meridian not being available to DAD staff since December 2024.
- Finding: Annual PSDS has generally been disseminated three months after the end of the year, but this periodicity has not always been followed, while biannual debt reports have only been published for two of the last five years.
- Recommendation: Publish a release calendar to inform users of when each debt report will be published and, in accordance with statistical best practice, disseminate quarterly debt data within 3 months of the end of the quarter being reported.

### 4.2 Consistency
- Finding: PSDS reports are internally consistent and consistent time series spanning at least four years are published.
- Finding: Reasons for revisions between publications are not explained. There is broad comparability between debt stocks and flows published by the MoFEA and RBM but exact figures often differ with no explanations provided.
- Recommendation: Regularly check debt stocks and flows reported in different publications for consistency and transparently communicate to users the reason for any differences.

### 4.3 Revision policy and practice
- Finding: The MoFEA have not developed and published a revision policy. Revisions can be observed by comparing different publications but are not explained in report commentary or metadata.
- Recommendation: Develop, publish, and apply a PSDS revision policy to guide users and PSDS compilers on the process for reporting and analyzing revisions.

### 5. Accessibility

### 5.1 Data accessibility
- Finding: Debt reports include commentaries and charts/tables that can facilitate user understanding. However, reports are in pdf format only and data is not standardly published in electronic formats that permit easy reuse and analysis of the data (e.g. Excel, csv, SDMX).
- Finding: Lack of consistent presentation between debt reports hampers usability and there is no preannounced schedule for publication.
- Recommendation: Renew dissemination of quarterly PSDS through the IMF-World Bank Joint Quarterly Public Sector Debt (QPSD) statistics database (latest data relates to 2020Q2) and via Malawi’s National Summary Data Page (NSDP) (latest data relates to 2016Q2).
- Recommendation: Standardize core tables and graphics in the debt reports to facilitate comparison between reports.

### 5.2 Metadata accessibility
- Finding: Some metadata on valuation, coverage and exchange rates is included within the text of the debt reports but it is difficult to find and insufficient. There is little consideration of the needs of different user groups.
- Recommendation: Provide more comprehensive metadata within, or alongside, the debt reports to explain the data sources, coverage, compilation methods, concepts and definitions, highlighting any divergencies from the international statistical standards.

### 5.3 Assistance to users
- Finding: Each debt report provides clear information on who to contact regarding the publication, and DAD staff reported that they frequently receive user requests for bespoke data presentations which they provide.
- Recommendation: Actively promote the on-request user service currently provided by DAD and include a contact email address in the debt bulletins to facilitate the raising of user queries.

*IMF | Technical Report – Malawi Data Quality Assessment for Public Sector Debt Statistics*

### 18. Staff, facilities, computing resources, and financing are commensurate with statistical

### 18. Staff, facilities, computing resources, and financing are commensurate with statistical programs but need enhancement.

### Staff, facilities, computing resources, and financing
- Human and financial resources devoted to the compilation, processing, and dissemination of PSDS are, in general, commensurate with DAD’s assigned responsibilities including coordination of information flow from key stakeholders and promulgation of international standards for production of high quality and cross-country comparable public debt data.
- Computing resources are inadequate; most new staff rely on personal computers to carry out official tasks—only three out of ten new staff have a desk top computer.
- DAD needs to implement more modules in the upgraded IFMIS system to be able to share debt information electronically, including linking DAD’s CS Meridian with the RBM’s CSD and the Auditor General’s data/information on verified accounts payables.
- Plans are underway to implement the updated IFMIS to facilitate easy exchange of data with RBM and eventual integration of both DAD CS Meridian and RBM CSD.

### Relevance and practical utility of statistics
- Various debt reports are compiled and disseminated to meet specific needs of users.
- DAD compiles and publishes a wide set of PSDS as part of its contribution to Malawi’s annual work programs, policy-related documents, and annual budget statement to parliament.
- DAD compiles and publishes Mid-Year and Annual Public Debt Report as well as Quarterly Debt Bulletin providing aggregate public debt statistics, both domestic and external.
- DAD reports public debt data to the World Bank’s Debtor Reporting System (DRS) and the QPSD and submits numerous PSDS tables to international organizations including, the IMF.
- DAD compiles financing and debt data to inform policymakers on annual borrowing plan as required by Cabinet.
- The mission could not find evidence that the DAD undertakes periodic user surveys to monitor the relevance of PSDS in meeting users’ needs.

### Processes to focus on quality and monitor quality
- DAD’s statistical production function is an integral part of the National Statistical System as set out in NSA (July 2013) and the Code of Practice for Official Statistics.
- The Code of Practice dictates that public debt data and information must be based on the right sources of statistical data with transparent judgements about definitions and methods, and judgements about the strengths and limitations of the statistical data and information.
- Staff training programs emphasize the importance of quality and give staff an understanding as to how quality may be achieved.
- DAD provides internal procedures for data publication to ensure quality by recognizing tradeoffs.
- Processes for monitoring quality are based on indicators that assess progress achieved in the work programs, including production of key debt reports required for the budget preparation, reporting to Cabinet and parliament, and for the production of the Quarterly Debt Bulletin and semi-annual and annual debt reports.
- Where necessary, data is cross-checked with primary sources (accounts payables with the Auditor General and payment claims/transactions, loans and guaranteed debt with direct creditors, both external and domestic).
- Steps have been taken to enhance data quality, including improved coverage, periodicity, and timeliness. Data requirements for (previous) IMF programs have provided impetus for improvements in data quality including verification of payment arrears and accounts payables.

Strengths:
- The flow of information needed to compile Malawi’s public sector debt statistics (PSDS) is efficient and well-coordinated.
- Individual reporters’ data are kept confidential and used for statistical purposes only.

Recommendations for improvements:
- Undertake slight modification of PFMA, 2022 to introduce a new regulation explicitly assigning DAD the responsibility for collecting, processing, and disseminating the PSDS of Malawi.
- Develop and promulgate new staff code of conduct to foster integrity, transparency, and professionalism in debt and aid management.
- Enhance computing and information technology resources.

### Assurances of integrity
- PSDS in Malawi are compiled and disseminated on an impartial basis. The MoFEA recognizes the importance of ensuring professional independence for personnel compiling statistics.
- Professional competence is the basic criterion for recruitment and promotion in DAD.
- Public debt statistics are carefully reviewed and validated before they are cleared by management for publication.
- Choices of sources and statistical techniques, as well as decisions about dissemination of PSDS are informed solely by statistical considerations and guided by recommendations set in the PSDSG 2013 and GFSM 2014.
- DAD staff are, in practice, free from political, or other influence, in choosing the most appropriate sources and methods for compiling public debt statistics.
- Decisions governing the disclosure of information are informed solely by statistical considerations as set out in the Code of Practice for Official Statistics and encouraged in Government Open Data Policy.
- DAD staff are free to comment on erroneous interpretation and misuse of statistics and to explain technical aspects of the public debt statistics publicly and through the Ministry’s public relations officer.
- Explanatory material, including contributing agencies and contact person(s), is provided on published data; additional information is provided when requested.
- The compilation of PSDS is governed by laws and regulations related to the formulation of government financial policy and related planning processes. Article 71 and 72 of the PFMA, 2022 dictates the periodicity of compilation of public debt information required for preparation of the Medium-term Debt Management Strategy and Annual Borrowing Plan.
- The time for discussion of these documents by the Cabinet of Ministers dictates the work program of DAD and the periodicity of production and dissemination of PSDS.
- The terms and conditions under which PSDS are collected, processed, and disseminated are not publicly available.
- The autonomy that the DAD enjoys guarantees that no government authority has access to its statistics before they are cleared by the Minister for publication; other than relevant senior officials of the MoFEA, no government unit or public servant has access to the public debt data before they are published.
- PSDS are disseminated as products of the MoFEA with appropriate attribution to DAD and relevant agencies as the primary source of data.

Strengths:
- Malawi’s PSDS are compiled and disseminated on an impartial basis.
- Choices of sources and statistical techniques, as well as decisions about dissemination of PSDS are informed solely by statistical considerations.

Recommendations for improvements:
- Publicize the terms and conditions under which PSDS are collected, processed, and disseminated.
- Publicize individual(s) who have access to the statistics prior to their release.
- Provide users advance notice on impending major changes in methodology, source data, and statistical techniques.
- DAD should endeavor to provide users advance notice on impending major changes in methodology, source data, and statistical techniques; there is no evidence that DAD notifies data users of any changes in methodology or source data. Any substantive change should be announced in advance by Internet and by meetings, seminars, and in publications specifying sources and methods and whether the data are preliminary or revised.
- Guidelines for staff behavior are in place and well known to staff, but DAD staff could not remember what is included in the general code of conduct for civil servants or when they last read it.
- Create a code of ethics tailored for DAD (along the lines of that developed by the Ministry of Local Government, Unity, and Culture (MLG)) to govern standards of conduct for those compiling public debt data, in addition to the Code of Practice for Official Statistics.

### Methodological soundness
- The concept and definition of what constitutes public sector debt in Malawi is in line with the international statistical standards: reported public debt only includes those liabilities where an unconditional obligation exists, with guarantees (contingent liabilities) reported separately in an annex.
- MoFEA public debt reports present public debt by instrument, currency, creditor, creditor residence, original maturity and remaining maturity. Foreign currency debt is translated into Malawian Kwatcha using the mid-point exchange rates.
- Standardized presentations and nomenclature described in GFSM 2014 and PSDG 2013 are not applied within the Malawi public debt reports.
- Presentation of residency: although the residency of the creditor is identified, what is reported as “domestic public debt” includes debt securities held by nonresidents; these nonresident-held debt securities should be recorded under “external public debt” using a creditor residency criterion.
- Instrument coverage: reported public debt is limited to loans and debt securities and does not capture arrears, which are known to be materially significant for Malawi. The statistical standards recognize six distinct types of debt instrument; Malawi currently only reports public debt related to two of the six instruments.
- Data on liabilities from allocations of IMF Special Drawing Rights (SDRs) are readily available and could be included in PSDS.
- Other accounts payable (which includes expenditure arrears) are material in the Malawian context and their inclusion should be a priority.
- Sector coverage: debt reports described as “budgetary central government (BCG) and the central bank” understate effective coverage. Most borrowing of public entities is either contracted by the BCG and on-lent to public entities or contracted by the entity but guaranteed by the BCG; both are included in the debt reports (the former in BCG debt and the latter as BCG contingent liabilities in annexes).
- Not all liabilities of the central bank are included—only borrowing undertaken on behalf of the government or wider public sector are included.
- At the end of March 2024, non-guaranteed direct borrowing of public entities was around 300 billion Malawian Kwacha (MK) and the payables of local governments 15 billion MK. This amounts to around 2 percent of the total reported public debt.
- Debt securities are reported at face valuation; nominal valuation (which includes accrual of interest) should also be reported and can be calculated from available granular information on loans and debt securities.
- CS Meridian can report debt at nominal value without manual calculations, but until data on debt securities is entered into CS Meridian this functionality is limited to external borrowing.
- Consolidation is essential to avoid double counting as debt reporting is expanded to all subsectors; currently guaranteed debt of public corporations is treated as contingent liabilities but if fully incorporated will become actual liabilities with intra-sector on-lending eliminated in consolidation.

Strengths:
- Clear recognition in Malawi public debt reports of what constitutes a debt liability, with contingent liabilities included within the annex.
- Public debt reports broadly follow statistical concepts by presenting data by instrument, currency, creditor residency, remaining maturity, and by valuing external debt using mid-point exchange rates.

Recommendations for improvements:
- Extend the sector coverage of the core PSDS reports through inclusion of local government debts and the non-guaranteed borrowing of extrabudgetary units and public corporations.
- Extend the instrument coverage to include other accounts payable (which will include expenditure arrears).
- Expand the debt reports to include internationally standardized tables presenting the PSDS by instrument, creditor residency, original maturity, residual maturity, and currency over an extended time period.
- Report PSDS using a nominal valuation (which includes the accrual of interest), and as sector coverage is expanded present the data on a consolidated basis; show the market value of government debt securities as a memorandum item.

*IMF | Technical Report – Malawi Data Quality Assessment for Public Sector Debt Statistics*

### 37. The use of CS Meridian by DAD facilitates the validation, quality assurance, and reporting

### 37. The use of CS Meridian by DAD facilitates the validation, quality assurance, and reporting

### CS Meridian usage and coverage
- Currently CS Meridian is only used to manage and report on the external borrowing which means that the external debt reports from CS Meridian must be manually combined with other data sources.
- Recommendation: Expand the coverage to house all public sector debt data within the one system to leverage the full functionality of the CS Meridian database, and reduce duplication and inefficiencies.

### Data on debt securities and CSD interface
- Data on the issuances, payments and redemptions of debt securities is held by the RBM who manage the administration of debt securities on behalf of the government. The data on debt securities is held on the RBM’s CSD.
- Current practice: Data extracted from CSD are shared with the DAD on request (typically monthly) in a MS Excel tool which calculates key aggregates. These aggregates are compared with those populated by DAD using auction results and any differences investigated.
- Recommendation: Interface the CSD directly with CS Meridian to negate the necessity of manual extraction and reconciliation. Note: this has been successfully implemented in several other countries (including Tanzania).
- Additional recommendation: Include and validate guarantee data in CS Meridian.

### IT infrastructure, access and continuity
- At the time of the mission CS Meridian had not been accessible by DAD staff since early December (a period of two months), due to a fault in the network used by DAD to access the server where CS Meridian is housed.
- Consequences of lack of access: prevents maintenance and reporting of external debt data, validation of payment invoices, and forecasting of future debt servicing requirements.
- Mission outcome: Shortly after the mission access to CS Meridian was restored.
- Recommendation: Implement measures to avoid similar access interruptions in the future and ensure CS Meridian is adequately supported by the MoFEA IT infrastructure.

### Validation, quality assurance, and documentation
- DAD demonstrated processes to cross-check both external and domestic debt data, but many of these processes have been established through prior experience and are shared verbally with newer members of staff.
- Recommendation: Capture checks, validations and reconciliation processes in compilation documentation to provide a robust compilation environment usable when more experienced colleagues are not available.
- Recommendation: Compile and publish reconciliation tables to demonstrate internal consistency of published data (Annex III Tables 2 and 3 provide examples). The first table reconciles changes in debt stock over a period with the debt flows in that same period. The second reconciles the cash deficit/surplus, as reported in government finance statistics, with the changes in debt stock.
- Mission attempted reconciliation using 2022/23 data; figures are shown in Annex III Table 3.

### Serviceability — publication frequency, timeliness, revisions, and consistency
- Observation: Biannual public debt reports are compiled by MoFEA but not all are published on the Ministry website. For the five-year period between 2019/20 and 2023/24, all annual reports are published but only two mid-year reports are published (those of 2020/21 and 2023/24).
- Issues: Reports are split between two webpages (“Debt & Aid” and “Annual Debt Reports”) and recent reports are not found on the landing page.
- Recommendation: Organize documents on the MoFEA website and ensure all compiled reports are published.
- Quarterly debt bulletin: Introduced in August 2024. Timeliness of first quarterly bulletin: two months after the reporting period. At the time of the mission no further quarterly bulletins had been published. DAD produced a 2024Q3 (end-September 2024) bulletin in November 2024, approved by the Minister, but only for publication alongside the budget.
- Principle: Timing of public debt statistical publications should not be influenced by external considerations; release calendar is required in accordance with Principle 17 of the Malawi Code of Practice for Official Statistics.
- Data consistency issues: Macroeconomic publications of RBM and NSO are by calendar year, debt statistics use financial years, complicating consistency analysis. Lack of disaggregated published data hampers identification of reasons for differences (e.g., RBM central government external debt series is significantly lower than MoFEA’s).
- Recommendation: MoFEA, RBM and NSO statistical compilers should regularly review and identify reasons for differences between debt stocks and flows reported in different statistical publications and provide metadata explaining the differences.
- Revisions: Revisions occur between MoFEA publications but are not identified nor explained.
- Recommendation: Develop and publish a PSDS revision policy and inform users through footnotes about the preliminary nature of disseminated data.
- Strength noted: Some improvement in frequency and timeliness — the 2023/24 mid-year report was published within two months of the end of the period and a quarterly debt report was introduced in August 2024 (although further quarterly reports remain outstanding).
- Recommendations for serviceability:
  - Publish a release calendar to inform users of when each debt report will be published and, in accordance with statistical best practice, disseminate quarterly debt data within 3 months of the end of the quarter being reported.
  - Regularly check debt stocks and flows reported in different publications for consistency and transparently communicate to users the reason for any differences.
  - Develop and publish a PSDS revision policy to guide users and compilers on the process for reporting and analyzing revisions.

### Accessibility, metadata, formats, and user engagement
- Debt reports include commentary, graphs, charts, and tables that facilitate user understanding, but improvements are suggested in metadata coverage, standardized tables, and data provision in electronic formats.
- Current metadata: Preface/introduction contains instrument coverage, sector coverage (BCG and Central Bank), and valuation (face value). Reports also provide GDP and exchange rate used.
- Recommendation: Expand metadata (tabular or structured annex preferred) to include data sources, whether data is final or provisional, compilation methods, approach to revisions, debt concepts used, approach to consolidation, and whether debt is on a net or gross basis. Include information on alignment with/divergence from GFSM 2014 and PSDSG 2013 and the Malawian Code of Practice for Statistics.
- Report structure: Varies between issues; recommendation to standardize a set of core tables and charts to be included in every report while allowing additional items for specific commentary.
- Recommendation: Elicit user feedback via surveys, outreach meetings, bilateral correspondence, and use international statistical standards (e.g., QPSD tabular structure reproduced in Annex III Table 1) to guide standardized tables.
- Data formats: Currently data only available in pdf. Recommendation: Provide data in MS Excel, csv, SDMX to enhance usability.
- Recommendation: Renew dissemination of PSDS via the QPSD database and via Malawi’s NSDP of the IMF’s Data Dissemination Standards to expose data to broader users and provide access to Excel and SDMX formats.
- User support: DAD receives upwards of 30 user queries a year; contact details are prominently displayed at the front of each report.
- Recommendation: Maintain and build upon the on-request user service; include an email point of contact and maintain logs of queries to inform a user contact list and future PSDS improvements.

### Strengths (as reported)
- Malawi has successfully migrated external debt data from CS-DRMS to the new CS Meridian public debt management system. The migrated data has been validated using the improved validations of CS Meridian.
- Granular information on the issuance, trading and redemption of debt securities is maintained by the RBM on the CSD.
- Timely and comprehensive source data on district and city councils (local government) can be leveraged to extend the sector coverage of PSDS in Malawi.
- Malawi debt reports include commentaries and charts/tables that assist non-expert users to understand the public sector debt position of the Malawian government as well as the debt sustainability and risk profile.
- The CS Meridian system used for management of external debt includes functionality which enable PSDS to be produced following the concepts, valuations and presentations of the international statistical standards.

### Consolidated recommendations (extracted from text)
- Expand the data available in CS Meridian to include administrative data on the direct (non-guaranteed) borrowing of local governments, extrabudgetary units, and public corporations, as well as accounts payable (including expenditure arrears) of all public entities.
- Interface CS Meridian with the CSD to improve efficiency and reduce the risk of errors being introduced through manual processing.
- Include and validate guarantee data in CS Meridian.
- Assess the materiality of government liabilities related to PPPs and finance leases.
- Compile and publish reconciliation tables using the tables to identify and investigate discrepancies.
- Periodically analyze revisions to understand the drivers of revisions and use the results of the analysis to inform PSDS compilation procedures.
- Publish a release calendar; disseminate quarterly debt data within 3 months of the end of the quarter.
- Regularly check and explain inconsistencies across MoFEA, RBM, and NSO publications; provide metadata explaining differences.
- Develop and publish a PSDS revision policy and flag preliminary data in footnotes.
- Renew dissemination of quarterly PSDS through the QPSD and via Malawi’s NSDP.
- Standardize core tables and graphics in debt reports.
- Provide more comprehensive metadata and data in MS Excel, csv, SDMX formats.
- Actively promote the on-request user service and include a contact email address; maintain logs of queries.

*Source: IMF Technical Report – Malawi Data Quality Assessment for Public Sector Debt Statistics (selected section).*

### APPENDIX II. USERS’ SURVEY RESULTS

### APPENDIX II. USERS’ SURVEY RESULTS

### Overview
- Total respondents: 12.
- Respondent types included financial institutions, regional organizations, foreign governments, research institutes, media organizations, non-governmental organizations, and the Parliament of Malawi.
- Nearly all respondents said that they made use of the national debt bulletins.
- Overall sentiment: all respondents felt the disseminated PSDS were at least somewhat analytically useful.
- Common concerns raised:
  - Timeliness of reports.
  - Narrow coverage of reported PSDS leading to implicitly inaccurate and biased figures (raised by two users).

### Coverage and concepts
- User satisfaction was split on instrument and sector coverage.
- Frequently cited coverage gaps:
  - Arrears and other accounts payable.
  - Pension liabilities.
  - Contingent liabilities.
  - Need to expand coverage of public corporations, extrabudgetary units, and local governments.
- Valuation approach: Most users were happy with the current approach to the valuation of debt.
- Key survey response counts:
  - Instruments inadequately covered in disseminated public debt:
    - None – coverage is adequate for all debt instruments: 0
    - Accounts payables (arrears): 7
    - Loans: 2
    - Debt securities: 4
    - Pension liabilities: 4
    - Other: 1
  - Subsectors for which users would like more coverage of PSDS:
    - None – coverage is adequate for all subsectors of the public sector: 0
    - Local government / State governments: 7
    - Public corporations: 10
    - Budgetary central government: 5
    - Extra-budgetary units: 9
    - Other: 0
  - Is valuation of outstanding stock positions appropriate?
    - Yes: 10
    - No: 2

### Periodicity and timeliness
- Users were split on satisfaction with timeliness and periodicity.
- Specific concerns:
  - Sporadic publication of debt reports.
  - Publication lags.
  - Missing expected reports.
  - Difficulty finding reports; website sometimes not accessible.
- Survey response counts:
  - Satisfaction with periodicity of disseminated PSDS:
    - Very satisfied: 1
    - Satisfied: 6
    - Neither satisfied nor dissatisfied: 3
    - Dissatisfied: 2
    - Very dissatisfied: 0
  - Are PSDS disseminated in a sufficiently timely manner?
    - Yes: 5
    - No: 5
    - Not sure: 2

### Dissemination practices
- Users were largely unaware of any specific dissemination practices.
- Survey response counts:
  - Is there a published release schedule/calendar and are PSDS released punctually?
    - Yes, and the data is released on schedule: 0
    - Yes, and the data is sometimes released on schedule: 2
    - Yes, and the data is never released on schedule: 0
    - No: 1
    - Not sure: 9
  - Is analysis published to identify and explain revisions, breaks, adjustments, and discontinuities?
    - Yes: 2
    - No: 4
    - Not sure: 6
    - No response: 0
  - At time of PSDS dissemination, are users informed whether the nature of data is preliminary, revised or updated?
    - Always informed: 1
    - Sometimes informed: 4
    - Never informed: 1
    - Not aware: 6
  - Do users receive advance notice when major changes will be introduced into the PSDS?
    - Always: 0
    - Sometimes: 4
    - Never: 5
    - Not sure: 3

### Accessibility and usefulness
- Most users perceived the disseminated PSDS as accessible and useful.
- Survey response counts:
  - Are the disseminated PSDS presented to facilitate proper interpretation and meaningful comparisons?
    - Strongly agree: 0
    - Agree: 8
    - Neither agree nor disagree: 3
    - Disagree: 0
    - Strongly disagree: 1
  - Is there comprehensive published source and methods information (metadata) readily accessible?
    - Yes, available and accessible: 3
    - Partial information available: 4
    - No information available: 0
    - Not sure: 5
  - Are the PSDS largely consistent and reconcilable over time with other macroeconomic data sets (GFS, national accounts, IIP, external debt, MFS)?
    - Fully consistent: 2
    - Partly consistent: 6
    - Not consistent: 0
    - Not sure: 4

### Selected overall assessment statistics
- In your view, are the disseminated PSDS analytically useful?
  - Very useful: 6
  - Useful: 4
  - Somewhat useful: 2
  - Not useful: 0
  - Undecided: 0
- The disseminated PSDS are unbiased and accurate:
  - Strongly agree: 0
  - Agree: 8
  - Neither agree nor disagree: 3
  - Disagree: 1
  - Strongly disagree: 0
- Level of satisfaction with the timeliness and level of detail of the disseminated PSDS:
  - Very satisfied: 0
  - Satisfied: 7
  - Neither satisfied nor dissatisfied: 3
  - Dissatisfied: 1
  - Very dissatisfied: 1

*Source: APPENDIX II. USERS’ SURVEY RESULTS (IMF Technical Report – Malawi Data Quality Assessment for Public Sector Debt Statistics).*

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_Source: https://www.imf.org/-/media/files/publications/tar/2025/english/tarea2025037-print-pdf.pdf_