## Appendix I. Officials Met During the Mission

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### Overview
- Report assesses the data quality of Botswana’s public sector debt statistics (PSDS) 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: May 14–20, 2025.
- Agencies compiling assessed datasets: Ministry of Finance (MoF), Bank of Botswana (BoB); Statistics Botswana (SB) as main user.

### Background and Context
- Botswana implemented the IMF’s enhanced General Data Dissemination System (e‑GDDS) in January 2016; PSDS reporting through the National Summary Data Page (NSDP) remains limited in coverage.
- Since 2016, IMF Statistics Department provided capacity development to strengthen GFS and PSDS compilation and publish quarterly PSDS through NSDP and the joint IMF-World Bank Quarterly Public Sector Debt (QPSD) database.
- Government debt ceiling maintained below 40 percent of GDP, split equally between external and domestic debt.
- Debt ratios spiked to 28 percent of GDP in March 2025, excluding other accounts payables, up from 20.2 percent of GDP in December 2023.
- Significant portion of external debt is long-term and owed mainly to multilateral and bilateral creditors; since 2018 an increasing share held by domestic banks and other domestic creditors.

### Summary Findings (by DQAF dimensions)
- Prerequisites of Quality
  - Legal Environment: PFMA 2011 (Sections 25 and 26) requires Minister of Finance to inform National Assembly about loan servicing costs but does not designate an agency responsible for public debt management and reporting.
  - Institutional Environment: Data sharing and coordination between MoF, BoB, and SB are good via long-established informal channels; recommendation to formalize timetables and strengthen resources, senior management oversight, and IT resilience.
  - Recommendation to explicitly state BADM’s responsibilities in law and enact new legislation to provide legal authority for debt management and reporting.

- Assurances of Integrity
  - PSDS compilations traditionally impartial; civil service code of conduct and Public Service Charter emphasize integrity, neutrality, and merit-based recruitment.
  - Recommendation to publish terms and conditions for PSDS collection, processing, and dissemination and provide advance notice of major methodological changes.

- Methodological Soundness
  - Botswana broadly applies GFSM 2014 and PSDSG 2013 concepts and definitions.
  - BCG debt data are broken down by residency and original/remaining maturity but not published by currency of denomination.
  - Instruments limited to loans and debt securities recorded at face value; domestic debt securities need disaggregation by non-resident holders.
  - Coverage gaps: local governments, extrabudgetary units, and public corporations not fully reported (except certain guaranteed SOE loans).
  - Recommendation to establish authoritative list of public entities sectorized per international standards and expand coverage (other accounts payables, non‑guaranteed SOE loans, domestic debt securities by residency).

- Accuracy and Reliability
  - Source data on BCG debt stocks comprehensive; integrity depends on full implementation of CS‑Meridian to interface with CSDB and GABS and replace parallel excel systems.
  - Need robust validation, QA measures, revision policy, and finalization/implementation of the Debt Management Procedures Manual (developed in-house in 2021).
  - Most data available quarterly after quarter end except guaranteed debt (updated annually); end-of-fiscal-year data available only after six months; no estimation made for missing data.

- Serviceability
  - MoF disseminates quarterly PSDS on its website, NSDP, and QPSD, but delays in QPSD submissions exist.
  - Quarterly data released within three months of period end; annual data within six months of year end.
  - First Quarterly Debt Bulletin published in April 2024 providing data for three quarters up to December 2023.
  - Internal consistency over time but inconsistencies with balance of payments flows and IIP stocks due to MoF revising historic data without informing BoB.
  - Recommendation for a full review of external sector datasets and timely reconciliation of financing with PSDS flows.

- Accessibility
  - Commended publication of first Quarterly Debt Bulletin (April 2024) with commentary, graphs, charts, and tables.
  - Need to adopt standardized core tables per PSDSG 2013 and to publish richer metadata (compilation methods, revision approaches, provisional/final status, alignment/divergence from standards).
  - Recommendation to publish contact persons and monitor user sentiment.

### Priority Recommendations (explicit)
- Enact new legislation providing explicit legal and institutional authority for debt management and reporting in Botswana.
- Establish a fully-fledged and adequately resourced public debt management office in the Department of Budget (DB) with front office, middle office, and back office functions.
- Operationalize CS‑Meridian to enhance efficiency and quality of debt recording and reporting.
- Establish a task team to:
  - determine the level of outstanding stock of account payables and non‑guaranteed SOEs debt; and
  - develop a template to monitor such debt covering all line ministries and government entities.
- Establish an authoritative list of all public entities in Botswana sectorized in accordance with international statistical standards.
- Develop and publish a clear revision policy for PSDS and implement a transparent system to monitor data users’ sentiments on the usefulness of Botswana’s public debt statistics.

### Key Quantitative Points and Dates (verbatim)
- Mission dates: May 14–20, 2025.
- e‑GDDS implemented: January 2016.
- Public debt ceiling: below 40 percent of GDP (split equally between external and domestic debt).
- Debt ratio: 28 percent of GDP in March 2025 (excluding other accounts payables).
- Comparative debt ratio: 20.2 percent of GDP in December 2023.
- Since 2018, increasing share of debt held by domestic banks and other domestic creditors.
- Debt Management Procedures Manual developed: 2021.
- Quarterly data released within three months of the end of the reporting period.
- Annual data released within six months of the end of the year.
- First Quarterly Debt Bulletin: April 2024 (providing data for three quarters up to December 2023).

### 0. Prerequisites of quality — Legal and Institutional Environment (detailed)
- Assessment findings:
  - LNO: Responsibility for collecting, processing, and disseminating PSDS is not adequately entrenched in the law; compliance with timetables is weak.
  - Sections 25 and 26 of the Public Finance Management Act, 2011 (PFMA 2011) require the Minister to inform the National Assembly about loan servicing costs but do not designate an agency responsible for public debt management and reporting.
  - BADM of the Department of Budget performs current responsibilities without explicit legal backing.
  - In April 2025, other accounts payable reported by the OAG were around four billion Pula, possibly tipping domestic debt over the limit of 20 percent of GDP.
  - BoB has legal mandate under Article 59 of the BoB Act, 1996, to require government and government corporations to seek advice before borrowing from sources other than the Bank.
- Recommendations:
  - Enact new legislation providing explicit legal and institutional authority for debt management and reporting.
  - Make public debt reporting mandatory for all government institutions and any statutory or wholly owned or controlled public corporation.
  - Publicize BADM’s data confidentiality policy and resolve MoF delays by having BoB submit data templates predictably.

### 0.2 Resources
- Assessment findings:
  - LNO: Resources for debt management and reporting are not commensurate with evolving debt management functions.
  - Seven officers are responsible for debt management in BADM; each officer has a computer and internet access.
  - BADM uses the public debt service module of GABS as primary source data; CS-DRMS is non-operational and migration to CS-Meridian stalled due to technical challenges getting data from GABS since August 2023.
- Recommendations:
  - Establish a fully-fledged and adequately resourced public debt management office with front, middle, and back office functions.
  - Speed up operationalization of CS-Meridian and interface with GABS and CSDB.
  - Implement validation templates and prioritize staff training despite travel/budget constraints.

### 0.3 Relevance and 0.4 Other Quality Management
- Findings:
  - LNO: Relevance and practical utility of PSDS is suboptimal; MoF disseminates quarterly reports with timeliness of 30 to 45 days after the reference period but publications can be batched beyond due dates.
  - BADM published its first Quarterly Debt Bulletin in April 2024; no follow-up publications have been released.
  - Lack of systematic measures for monitoring PSDS quality; draft Debt Management Procedures Manual under development.
- Recommendations:
  - Provide stronger senior management oversight and enhance user engagement (including periodic user surveys).
  - Ensure IT resilience against cybersecurity risks and implement the DMPM.

### Impartiality, Transparency, and Ethical Standards
- Impartiality and Professional Independence:
  - Compilers at MoF, BoB, and SB operate under civil service code of conduct and Public Service Charter emphasizing integrity, neutrality, and merit-based recruitment.
  - BADM staff are free from political influence in compilation and dissemination decisions.
- Transparency:
  - Terms and conditions for PSDS collection, processing, and dissemination are not published.
  - BADM discloses individuals with prior access to PSDS: Only the Director and Deputy Director of BADM have prior access.
  - No evidence BADM notifies users of methodological changes; example discrepancies stemmed partly from delays in communicating revisions from the World Bank’s DRS.
- Ethical Standards:
  - New officers in BADM required to sign Declaration of Public Service Act (No. 30 of 2008), General Order 18, and Declaration of National Security Act (CAP.23).
  - Recommendations: operationalize CS-Meridian, introduce validation templates, finalize and operationalize the Debt Management Procedures Manual (2021), and routinely notify data users of methodology/source data changes.

### Methodological Soundness (detailed)
- Concepts and Definitions:
  - Gross debt compiled largely in line with GFSM 2014 and PSDSG 2013.
  - National term “total government debt” includes contingent liabilities (BCG-guaranteed loans), which diverges from statistical standards where guarantees are contingent liabilities.
- Residency principle and scope:
  - Public debt compiled on residency principle; external debt could be understated if nonresident holders of domestically issued securities are not captured.
  - Sector coverage limited to BCG and BCG-guaranteed debt; extrabudgetary units, SOEs, and local governments not fully covered.
  - Instrument coverage limited; recommendations to expand to SDRs, pension funds, other accounts payables, and to apply residency principle strictly.
- Valuation and consolidation:
  - Domestically issued debt securities are reported at face value (redemption value) rather than nominal value with accrued interest; market value not reported as memorandum item.
  - Loans do not include accrued interest; no footnotes indicate valuation methods used.
  - Recommendation to report at nominal value including interest accrued and provide market value as memorandum items; adopt CS-Meridian capabilities.

### Accuracy and Reliability (detailed)
- Source Data and Systems:
  - Main sources: GABS (OAG) and CSDB (BoB); GABS experienced major failures from August 2023 through December 2024.
  - BADM relies on Excel-based debt database with inputs from GABS and CSDB; Excel database prone to human error.
  - No estimation methods used for missing quarterly data; last data point reused until new figures available.
- Validation and Audit:
  - AG audits public debt annually; last audited financial statements for March 2022; March 2023 and March 2024 statements still being audited at mission time.
  - Reconciliations with creditors occur annually or ad-hoc; debt securities not routinely validated against issuance data.
- Recommendations:
  - Assess and build a database for other accounts payable from AGO, MLG&TA, and parastatals.
  - Validate debt securities stocks and flows against BoB/CSDB issuance data monthly.
  - Institutionalize at least quarterly cross-validation routines among MoF, BoB, and SB.
  - Create regular procedures to investigate statistical discrepancies and periodically run and analyze revisions.

### Serviceability — Timeliness, Frequency, Consistency, and Revision Practices
- Timeliness and Frequency:
  - Quarterly PSDS disseminated on MoF website, NSDP, and QPSD; quarterly data generally released within three months of period end.
  - Annual data released within six months of year end.
  - Quarterly BCG gross debt disseminated for 2015–2024 and downloadable in excel.
  - No release calendar exists; recommendation to publish one.
  - Quarterly Debt Bulletin introduced for December 2023 but not published until April 2024; recommendation to publish quarterly.
- Consistency:
  - PSDS internally consistent over time but inconsistent with balance of payments and IIP due to failure to communicate revisions.
  - Recommendations: communicate major revisions expeditiously and review external sector datasets reliant on PSDS.
- Revision Policy and Practice:
  - BADM has no established, public revision cycle; revisions are not explicitly identified in publications.
  - Quarterly reports are published in files of four quarters, limiting long time-series analysis.
  - Recommendations: develop and publish a debt data revision policy and apply it in the context of proposed legislation and DMPM.

### Accessibility, Metadata, and User Engagement
- Data and Metadata Accessibility:
  - Quarterly Debt Bulletin provides detailed graphs, charts, and tables with commentary.
  - PSDS disseminated through NSDP and QPSD aligned with international presentations; data is downloadable.
  - MoF does not publish metadata on its website despite comprehensive metadata on the IMF’s DSBB.
- Assistance to Users and Feedback:
  - Users satisfied with analytical usefulness but request expanded coverage, improved timeliness, more granular data, richer metadata, and contact persons.
  - Survey findings:
    - Nearly all respondents used IMF or World Bank databases.
    - All respondents rated disseminated PSDS as analytically either useful or very useful.
    - Users were neither satisfied nor dissatisfied with timeliness.
    - Users never receive advance notice regarding major changes to PSDS.
- Recommendations:
  - Publish a release calendar, include comprehensive metadata on MoF’s website, publish Quarterly Debt Bulletin regularly, and provide contact persons for user queries and sentiment monitoring.

### Strengths (selected)
- Quarterly debt reports published within three months of quarter end and annual reports within six months of year end, consistent with SDDS requirements.
- Good internal consistency between BADM publications.
- Technical and Statistics Producers Committees meet quarterly to discuss e‑GDDS and SDDS participation.
- PSDS presentations align with international standards and facilitate cross-country comparability and downloadability.
- Comprehensive metadata available on IMF’s DSBB.

*IMF | Technical Report – Botswana: Data Quality Assessment for PSDS (Appendix I and accompanying assessment content).*

### Appendix I. Officials Met During the Mission ...........................................................................

### Appendix I. Officials Met During the Mission

### Overview
- Report assesses the data quality of Botswana’s public sector debt statistics (PSDS) 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: May 14–20, 2025.
- Agencies compiling assessed datasets: Ministry of Finance (MoF), Bank of Botswana (BoB); Statistics Botswana (SB) as main user.

### Background and Context
- Botswana implemented the IMF’s enhanced General Data Dissemination System (e‑GDDS) in January 2016; PSDS reporting through the National Summary Data Page (NSDP) remains limited in coverage.
- Since 2016, IMF Statistics Department provided capacity development to strengthen GFS and PSDS compilation and publish quarterly PSDS through NSDP and the joint IMF-World Bank Quarterly Public Sector Debt (QPSD) database.
- Government debt ceiling maintained below 40 percent of GDP, split equally between external and domestic debt.
- Debt ratios spiked to 28 percent of GDP in March 2025, excluding other accounts payables, up from 20.2 percent of GDP in December 2023.
- Significant portion of external debt is long-term and owed mainly to multilateral and bilateral creditors; since 2018 an increasing share held by domestic banks and other domestic creditors.

### Summary Findings (by DQAF dimensions)
- Prerequisites of Quality
  - Legal Environment: PFMA 2011 (Sections 25 and 26) requires Minister of Finance to inform National Assembly about loan servicing costs but does not designate an agency responsible for public debt management and reporting.
  - Institutional Environment: Data sharing and coordination between MoF, BoB, and SB are good via long-established informal channels; recommendation to formalize timetables and strengthen resources, senior management oversight, and IT resilience.
  - Recommendation to explicitly state BADM’s responsibilities in law and enact new legislation to provide legal authority for debt management and reporting.

- Assurances of Integrity
  - PSDS compilations traditionally impartial; civil service code of conduct and Public Service Charter emphasize integrity, neutrality, and merit-based recruitment.
  - Recommendation to publish terms and conditions for PSDS collection, processing, and dissemination and provide advance notice of major methodological changes.

- Methodological Soundness
  - Botswana broadly applies GFSM 2014 and PSDSG 2013 concepts and definitions.
  - BCG debt data are broken down by residency and original/remaining maturity but not published by currency of denomination.
  - Instruments limited to loans and debt securities recorded at face value; domestic debt securities need disaggregation by non-resident holders.
  - Coverage gaps: local governments, extrabudgetary units, and public corporations not fully reported (except certain guaranteed SOE loans).
  - Recommendation to establish authoritative list of public entities sectorized per international standards and expand coverage (other accounts payables, non‑guaranteed SOE loans, domestic debt securities by residency).

- Accuracy and Reliability
  - Source data on BCG debt stocks comprehensive; integrity depends on full implementation of CS‑Meridian to interface with CSDB and GABS and replace parallel excel systems.
  - Need robust validation, QA measures, revision policy, and finalization/implementation of the Debt Management Procedures Manual (developed in-house in 2021).
  - Most data available quarterly after quarter end except guaranteed debt (updated annually); end-of-fiscal-year data available only after six months; no estimation made for missing data.

- Serviceability
  - MoF disseminates quarterly PSDS on its website, NSDP, and QPSD, but delays in QPSD submissions exist.
  - Quarterly data released within three months of period end; annual data within six months of year end.
  - First Quarterly Debt Bulletin published in April 2024 providing data for three quarters up to December 2023.
  - Internal consistency over time but inconsistencies with balance of payments flows and IIP stocks due to MoF revising historic data without informing BoB.
  - Recommendation for a full review of external sector datasets and timely reconciliation of financing with PSDS flows.

- Accessibility
  - Commended publication of first Quarterly Debt Bulletin (April 2024) with commentary, graphs, charts, and tables.
  - Need to adopt standardized core tables per PSDSG 2013 and to publish richer metadata (compilation methods, revision approaches, provisional/final status, alignment/divergence from standards).
  - Recommendation to publish contact persons and monitor user sentiment.

### Priority Recommendations (explicit)
- Enact new legislation providing explicit legal and institutional authority for debt management and reporting in Botswana.
- Establish a fully-fledged and adequately resourced public debt management office in the Department of Budget (DB) with front office, middle office, and back office functions.
- Operationalize CS‑Meridian to enhance efficiency and quality of debt recording and reporting.
- Establish a task team to:
  - determine the level of outstanding stock of account payables and non‑guaranteed SOEs debt; and
  - develop a template to monitor such debt covering all line ministries and government entities.
- Establish an authoritative list of all public entities in Botswana sectorized in accordance with international statistical standards.
- Develop and publish a clear revision policy for PSDS and implement a transparent system to monitor data users’ sentiments on the usefulness of Botswana’s public debt statistics.

### Key Quantitative Points and Dates (verbatim)
- Mission dates: May 14–20, 2025.
- e‑GDDS implemented: January 2016.
- Public debt ceiling: below 40 percent of GDP (split equally between external and domestic debt).
- Debt ratio: 28 percent of GDP in March 2025 (excluding other accounts payables).
- Comparative debt ratio: 20.2 percent of GDP in December 2023.
- Since 2018, increasing share of debt held by domestic banks and other domestic creditors.
- Debt Management Procedures Manual developed: 2021.
- Quarterly data released within three months of the end of the reporting period.
- Annual data released within six months of the end of the year.
- First Quarterly Debt Bulletin: April 2024 (providing data for three quarters up to December 2023).

*IMF | Technical Report – Botswana: Data Quality Assessment for PSDS (Appendix I and accompanying assessment content).*

### 0. Prerequisites of quality

### 0. Prerequisites of quality

### 0.1 Legal and institutional environment
- Assessment:
  - LNO: The responsibility for collecting, processing, and disseminating PSDS is not adequately entrenched in the law. Compliance with timetables for public debt reporting by government agencies is weak.
  - Sections 25 and 26 of the Public Finance Management Act, 2011 (PFMA 2011) require the Minister of Finance to inform the National Assembly the cost of servicing loans, guarantees, and debt lawfully incurred for and on behalf of the government, but the Act does not designate an agency responsible for public debt management and reporting.
  - Current responsibilities are conducted by the Budget Analysis and Debt Management section (BADM) of the Department of Budget in the Ministry of Finance without explicit legal backing.
  - Data sharing and institutional coordination among MoF, BoB, and SB are generally adequate but need further strengthening; SPTC coordinates preparations for Botswana’s subscription to the IMF’s SDDS and includes MoF, SB, BoB, and NBFIRA.
  - In April 2025, other accounts payable reported by the OAG were around four billion Pula, possibly tipping domestic debt over the limit of 20 percent of GDP.
  - The BoB has a clear legal mandate under Article 59 of the BoB Act, 1996, to require government and government corporations to seek advice from the BoB before borrowing from sources other than the Bank and to notify the Bank of borrowing terms.
- Recommendations:
  - Enact a new legislation providing explicit legal and institutional authority for debt management and reporting in Botswana.
  - Make public debt reporting (including government guaranteed debt, non-guaranteed debt, and other accounts payable) mandatory for all government institutions and any statutory or wholly owned or controlled public corporation.
  - Publicize BADM’s data confidentiality policy on its website and in all statistical products.
  - Resolve MoF delays by having BoB submit data reporting templates to MoF in a predictable manner.

### 0.2 Resources
- Assessment:
  - LNO: Resources for debt management and reporting are not commensurate with evolving debt management functions.
  - Seven officers are responsible for debt management in BADM; each officer has a computer and internet access.
  - BADM uses the public debt service module of GABS as primary source data; CS-DRMS is non-operational and migration to CS-Meridian stalled due to technical challenges getting data from GABS since August 2023.
- Recommendations:
  - Establish a fully-fledged and adequately resourced public debt management office with three key functions—front office, middle office, and back office.
  - Speed up operationalization of CS-Meridian and interface with GABS and CSDB.
  - Implement validation templates to ensure vertical and horizontal consistency during CS-Meridian stabilization.
  - Prioritize staff training for public debt management and reporting despite travel/budget constraints.

### 0.3 Relevance
- Assessment:
  - LNO: The relevance and practical utility of PSDS in meeting policy and analytical needs is suboptimal and should be reviewed and actively monitored by senior management given the evolving unfavorable economic conditions in Botswana.
  - MoF disseminates quarterly debt reports regularly, with a timeliness of 30 to 45 days after the reference period; stakeholders view frequency as suboptimal and sometimes reports released in batches beyond due dates.
  - BADM published its first Quarterly Debt Bulletin in April 2024; no follow-up publications have been released.
  - No evidence of periodic user surveys to monitor PSDS relevance.
- Recommendations:
  - Provide stronger senior management oversight of debt management functions commensurate with evolving vulnerabilities to debt sustainability.
  - Enhance communication and engagement with key data users and monitor user needs (including periodic user surveys).
  - Ensure IT resources are robust against cybersecurity challenges and operational risks that led to GABS inoperability in August 2023.

### 0.4 Other quality management
- Assessment:
  - LO: Senior management in MoF and BoB are fully aware of emerging global economic conditions and the need for timely, reliable, and comprehensive public debt data for decision making.
  - Lack of systematic measures for monitoring PSDS quality; draft Debt Management Procedures Manual (DMPM) under development.
- Recommendations:
  - Speed up implementation of CS-Meridian to facilitate effective debt monitoring and interfacing with the IFMIS and CSDB for timely exchange of data and eventual subscription to the SDDS.
  - Implement the DMPM and conduct periodic reviews to improve PSDS quality.
  - Revamp resources and profile of debt management functions in the DB to the level of modern debt management offices.

*IMF | Technical Report – Botswana: Data Quality Assessment for PSDS (Excerpt: 0. Prerequisites of quality)*

### 23. Botswana’s PSDS are compiled and disseminated impartially. The MoF, BoB, and SB

### 23. Botswana’s PSDS are compiled and disseminated impartially. The MoF, BoB, and SB

### Impartiality and Professional Independence
- The MoF, BoB, and SB recognize the importance of professional independence for personnel compiling statistics.
- Botswana civil service code of conduct (Public Service Charter) requires public servants to be accountable, act with integrity and competence, and prioritize the public interest over personal gain; emphasizes neutrality, transparency, high standards of due diligence and efficiency, and freedom from corruption.
- Botswana’s independent Public Service Commission recruits all civil servants based on qualifications prepared by the hiring government agency.
- Promotions are based on merit, determined by annual appraisals.
- On-the-job training is the standard practice, complemented by technical training as appropriate.
- Choice of source data is dictated by internationally accepted debt concepts and definitions, informed solely by statistical considerations.
- Decisions to disseminate PSDS are based on statistical needs only.
- BADM staff are free from political influence in choosing data sources and techniques for compiling and disseminating fiscal statistics and public debt.

### Transparency
Findings:
- The terms and conditions under which PSDS are collected, processed, and disseminated in Botswana are not published.
- Sections 25 and 26 of PFMA 2011 require the Minister of Finance to present the cost of servicing public debt to the National Assembly, but the act does not detail the terms under which these statistics are collected, processed, and disseminated nor the responsible government agency.
- The mission found no evidence that BADM makes effort to inform interested parties, outside the government, about its operations and limitations.
- The BoB and SB provide more detailed references to their data sources in their publications.
- BADM provides metadata on the NSDP, indicating individuals with prior access to debt information before its release: Only the Director and Deputy Director of BADM have prior access to PSDS before they are released as products of the MoF; no other individuals have advance access to the data.
- The mission found no evidence that BADM notifies data users of changes in methodology or source data. Example: data discrepancies in the balance of payments, IIP, and debt tables published by BADM were partly due to delays in promptly communicating major revisions from the World Bank’s DRS.
Recommendations:
- To further enhance transparency, explanations regarding the special attributes of the data and linkages to contributing agencies could help users better understand the data quality and reduce misinterpretations.
- Good statistical practice: announce substantive changes in source data or methodology in advance to all stakeholders, either via the internet, through the media, or in meetings with key stakeholders.

### Ethical Standards
Findings:
- Guidelines for staff behavior are well known by civil servants in Botswana; Public Service Charter prescribes ethical behavior and public service ideals.
- All levels of management are aware of the need to ensure irreproachable conduct within and beyond MoF and officials to maintain the public credibility of the debt data they process.
- The e-GDDS metadata on the IMF’s DSBB indicates that all new officers joining BADM are required to sign a Declaration of Public Service Act (No. 30 of 2008), General Order 18, and a Declaration of National Security Act (CAP.23).
- General Order 18 requires government officers to declare not to divulge any information gained through their employment, except in the course of duty or as authorized by their superior, both during and after their employment.
- The upcoming Debt Management Procedures Manual, once finalized, will further entrench high ethical standards in the compilation, processing, and dissemination of PSDS in Botswana.
Strengths:
- High-level professionalism of staff and ethical standards embedded in the Public Service Charter—all staff are required to sign and abide by the Declaration of Public Service Act (No. 30 of 2008).
- Disclosure of individuals with prior access to debt information before the data is released publicly.
Recommendations for Improvements:
- Operationalize the new CS Meridian to exploit its superior functionalities of recording diverse range of debt instruments, computation of nominal value of debt, as well as capabilities to interface with other systems notably the IFIMIS and CSDB.
- Introduce validation templates to guarantee vertical and horizontal consistency of the debt data compiled while CS Meridian is being stabilized.
- Finalize and operationalize the Debt Management Procedures Manual (2021).
- BADM should routinely notify data users of any changes in methodology or source data.

### C. METHODOLOGICAL SOUNDNESS
Concepts and Definitions:
- Botswana’s gross debt is compiled largely in line with the concepts and definitions in the GFSM 2014 and PSDSG 2013.
- PSDS reports capture outstanding non-contingent contractual liabilities and some contingent liabilities in the form of government-guaranteed loans to parastatals.
- Divergence: Botswana’s national term “total government debt” described as “public and publicly guaranteed debt,” as determined by the 2005 Stocks, Bonds, and Treasury Bills Act, includes direct liabilities of the budgetary central government (BCG) and BCG-guaranteed loans from certain state-owned enterprises (SOEs). From macroeconomic statistical standards, called guarantees are debt, while publicly guaranteed debt is contingent liabilities for the guarantor (BCG). Botswana’s national definition includes contingent liabilities in the form of guarantees, which is not in accordance with statistical standards. Information on guaranteed debt is disseminated separately to users.

Residency principle:
- Botswana’s public debt is compiled based on the residency principle: conceptually, external debt relates to liabilities to nonresident creditors.
- External debt could be larger than reported if nonresident holders of domestically issued debt securities are included.
- Legal framework has no restrictions on the participation of nonresidents in the domestic bond market; treasury bills are reserved for resident investors only.
- The BoB has no established framework requiring commercial banks to report on their holdings of domestic securities on behalf of nonresident investors.
Recommendation:
- Establish a framework to require reporting of domestic securities holdings on behalf of nonresident investors to enhance analytical value of CSDB and facilitate monitoring of external risks.

Scope:
Findings:
- Botswana’s PSDS are limited in scope by sector and instrument coverage: sector coverage extends only to BCG debt and BCG-guaranteed debt, with no coverage of extrabudgetary units and SOEs.
- Local governments are not allowed to borrow independently but could have significant other accounts payable.
- The Botswana Public Officers Pension Fund (BPOPF) is claimed to be a self-funded pension fund; further analysis should confirm whether it is a public sector unit.
- Instrument coverage needs to expand beyond loans, debt securities, and BCG-guaranteed debt to include liabilities related to allocation of special drawing rights (SDRs), pensions funds, and other accounts payables.
- Slow adoption of accrual accounting by the OAG exacerbates underreporting as the current cash accounting system allows payment claims to remain unreported for extended periods.
- Technical issues with IFMIS could affect short-term ability to monitor accounts payable and pending bills.
- No active PPP projects or financial leases in Botswana to be included in public debt.
Recommendations:
- Capture debt liabilities of the entire public sector.
- Consider alternative data sources to address potential underreporting of debt instruments.

Classification/Sectorization:
- BADM uses the recommended instrument and institutional unit classification specified in PSDSG 2013 and GFSM 2014.
- Public debt reports (mainly the QPSD) break down PSDS using standard classification; public debt is classified correctly by instrument class and sectorized either as BCG or BCG guaranteed (Appendix III (Table A2)).
- The mission noted comprehensive coverage of BCG units, although BADM staff were unclear on the classification of some parastatals in PSDS.
Recommendation:
- Further analysis of public corporations based on the GFSM 2014 framework, following the market test and government control.
- Complete the sectorization exercise initiated by the last IMF GFS technical assistance mission in September 2024 and publish an authoritative Public Sector Institutional Table (PSIT).

Time of Debt Recording, Valuation, and Consolidation:
Findings:
- BADM does not strictly adhere to internationally accepted methods for debt recording, valuation, and consolidation.
- Domestically issued debt securities, bonds, and treasury bills are reported using face value (redemption value), which is not the preferred method; recommended practice is nominal value with interest accruing continuously.
- Market value for traded instruments is to be reported as a memorandum item, but is not the practice in Botswana.
- Loans do not include accrued interest, and no footnotes indicate the valuation method used.
- Mission recommends adopting CS-Meridian, which can report outstanding debt at nominal value using the mid-point exchange rate for foreign currency debt.
- Public debt limited to BCG only; consolidation concept and risk-and-rewards approach for leases and PPPs not assessed because these instruments are currently not applicable; no assessment on debt forgiveness.
Strengths:
- Published debt reports broadly follow concepts and definitions of international statistical standards.
- BCG data is comprehensive for loans and debt securities.
Recommendations for Improvements:
- Expand instrument and sector coverage to include account payables (pending bills), direct non-guaranteed borrowing of public units outside the budgetary central government, and SDR allocations.
- Strictly apply the residency principle when distinguishing between domestic and external debt, namely for debt securities.
- Introduce a creditor residency mapping matrix in internal compilation processes, validate it jointly in the MoF and the BoB, and guarantee consistency with the PSDSG 2013 and the GFSM 2014.
- Report public debt at nominal value including interest accrued and provide market value for traded debt instruments as memorandum items; full implementation of the new CS-DRMS would allow such reporting with minimal effort.
- Report public debt identifying other economic flows to enrich the information for analysis (Table A2 shown in Appendix III).

### D. ACCURACY AND RELIABILITY
Source Data:
- Main data sources: administrative records of loan payments and disbursements maintained in GABS of the OAG and the CSDB database of the Bank of Botswana.
- These sources do not capture non-guaranteed debt of SOEs and other accounts payables of line ministries and government departments.
- The GABS suffered major functionality failures, adversely affecting the compilation of PSDS beginning August 2023 through December 2024.
- BADM currently relies on Excel-based debt database drawing inputs from GABS and BoB’s CSDB.
- Most loan transactions are readily available in GABS; source data for guaranteed debt is not timely and is collected once a year.
- No estimation is employed for missing quarterly data; the last data point is reused for subsequent quarters until new figures are available.
- BADM has an internal system of verifying transactions directly with creditors, but this is done once a year.

Assessment of Source Data:
- Source data is consistent with definitions, scope, and classification adopted by BADM for compiling PSDS, except SOEs data which is yet to be verified and sectorized.
- Excel-based debt database is prone to human errors; reconciliation with DRS revealed significant discrepancies, leading to revisions of stocks in 2024 that impacted historical data series for 2021 and 2022.
- CS-Meridian database is expected to improve debt recording if fully implemented and used effectively; inbuilt validation checks can flag source data discrepancies.
- BADM is encouraged to implement a mandatory system of reporting other accounts payable and non-guaranteed debt of SOEs quarterly.
- The mission recommends continuous review of the system to ensure comprehensiveness and accuracy.

Feasibility of reporting “other accounts payable”:
- The OAG collects weekly data on unpaid invoices from both budgetary central government units and districts (local governments).
- The Ministry of Local Government and Traditional Affairs (MLG&TA) monitors other accounts payable from the thirty-one districts monthly.
- Some public corporations confirm availability of such data in their financial statements, reported annually to the OAG after audits.
- Many public corporations indicated willingness to provide outstanding positions on other accounts payable more frequently and timely if needed.

Statistical Techniques:
- Data compilation procedures are sound but could be improved to allow adjustment of source data as needed.
- No data compilation procedures currently minimize processing errors such as coding, editing, and tabulation errors on BADM’s internal database.
- Preliminary data are subsequently replaced by final data, but internal data files do not routinely keep records of previously published data.
- Estimation methods are not applied to fill in missing quarterly data.

Assessment and Validation of Statistical Outputs:
- The AG audits public debt annually using financial statements from reporting agencies; the last audited financial statements are for March 2022.
- Timely audits provide quality assurance, but the mission noted significant lags in financial audits: financial statements for March 2023 and March 2024 were still being audited at the time of the mission.
- Source data on loans and domestically issued debt securities are not subject to comprehensive validation and rely mostly on MoF-internal sources.
- CS-Meridian is not operational; the Excel-based internal debt database is the only reliable source for recording and reporting loans and debt securities issued by BoB.
- Loans are reconciled with creditors annually or in response to ad-hoc requests; debt securities transactions are not routinely validated against issuance data.
- MoF is a member of the auction Committee and clears instruments before they are recorded in the CSDB.
- Statistical discrepancies in PSDS are not routinely investigated. Bilateral reconciliations with external creditors occur at budget preparation time but are not routine due to resource constraints.

Revision Studies:
- BADM does not undertake revision studies to investigate potential errors, omissions, or unexplained fluctuations of PSDS output.
Recommendations:
- Assess available data on other accounts payable at the AGO, MLG&TA and parastatals and build a database using current available resources to incorporate these debt instruments into future PSDS databases.
- Debt securities outstanding stocks and related flows should be validated against issuance data from the BoB and/or CSDB on a monthly basis.
- Institutionalize at least a quarterly cross-validation routine where MoF, BoB, and SB reconcile debt stock and flows jointly.
- Create regular procedures to investigate statistical discrepancies and other potential indicators of problems in statistical outputs.
- Periodically run and analyze revisions to understand their drivers and, where relevant, use results to inform PSDS compilation procedures.

Strengths:
- The source data for public debt is largely consistent with the definitions, scope, and classification adopted by BADM.
- BADM seeks to reconcile debt records with external creditors during preparation of annual budget outturn and estimates, although this work is not embedded in routine functions.
- Statements of debt and contingent liability are subject to annual audits by the AG with results presented to Parliament.

### E. SERVICEABILITY
- (Section begins with "Periodicity and Timeliness" in the source; no further content provided in this excerpt.)

*IMF | Technical Report – Botswana  Data Quality Assessment for PSDS*

### 42. The timeliness and frequency of disseminated public debt reports are broadly

### 42. The timeliness and frequency of disseminated public debt reports are broadly 

### Timeliness and frequency
- The MoF disseminates quarterly PSDS on their website, NSDP, and the QPSD, although the latter is sometimes delayed.
- Quarterly data are generally released within three months of the end of the reporting period.
- Annual data are released within six months of the end of the year.
- This regularity and frequency of publication align with SDDS requirements for debt dissemination.
- PSDS data published on the NSDP is timely and comparable to the QPSD.
- Coverage: BCG debt by maturity and type of instrument—both external and domestic.
- Quarterly BCG gross debt is disseminated for the period 2015–2024, and the data is downloadable in excel for further reuse and analysis.
- There is no release calendar informing users of when the next report will be published; publishing a data release calendar is recommended to promote equality of data access, transparency, and fair market competition.
- A Quarterly Debt Bulletin was introduced for December 2023 but was not published until April 2024.
  - The Bulletin features quarterly debt data for three quarters to end-2023 and includes end-of-year outstanding debt stock, disbursements, government-guaranteed debt, debt by currency composition, and repayments.
  - Recommendation: publish the Debt Bulletin quarterly and make it part of BADM’s core functions.

### Consistency
- PSDS are broadly consistent but could be improved through rigorous validation with other macro-economic data sets.
- Assessment findings:
  - PSDS published by BADM on the QPSD were internally consistent over time but inconsistent with debt flows and stocks published in the balance of payments and IIP.
  - Public sector debt position data is not fully consistent with the corresponding public sector debt transactions data.
  - Most inconsistencies were due to BADM’s failure to communicate revisions from the reconciliation exercise with the DRS to BoB.
- Recommendations:
  - BADM should communicate major revisions of PSDS to all stakeholders expeditiously.
  - Conduct a full review of external sector datasets that depend on PSDS data.
  - Timely compilation and reconciliation of financing with PSDS flows.

### Revision policy and practice
- BADM has no established cycle of data revision that is known by all users.
- Revisions are not explicitly identified in publications.
- Quarterly debt reports are not published in long-time series but in files of four quarters of a fiscal year, making meaningful time series analysis difficult.
- The only known corrections were motivated by discrepancies discovered with the DRS.
- Recommendations:
  - Develop and implement a debt data revision policy as a standard best practice.
  - Publish the revision policy on MoF’s website and any other relevant website featuring its data.
  - Implement this in the context of the proposed debt management and reporting Act and formalization of the Debt Management and Procedures Manual.
  - Inform users of any major data revision to foster meaningful analysis of PSDS.

### Accessibility — Data and metadata
- Data accessibility:
  - Botswana public debt statistics are compiled and presented to facilitate proper interpretation and meaningful comparisons.
  - The Quarterly Debt Bulletin is of high quality and presents data in detailed graphs, charts, and tables with commentary.
  - PSDS largely follows the classification set out in the PSDSG 2013 and GFSM 2014.
  - Public debt statistics disseminated through the NSDP and the QPSD are fully aligned with international presentations, facilitating cross-country comparability and downloadability.
  - BADM has not provided evidence of offering customized data to individual users outside government.
  - Users (BoB and SB) indicated need for more granular data beyond NSDP, QPSD, and MoF publications.
- Metadata accessibility:
  - Botswana has very comprehensive metadata on PSDS published on the IMF’s DSBB, including concepts, definitions, classification, coverage, and data sources.
  - Although metadata for budgetary central government debt in the NSDP is detailed and comprehensive, the MoF does not publish any metadata on its website.

### Assistance to users and user feedback
- Users surveyed expressed satisfaction with current PSDS but frustration with data coverage and timeliness.
- User requests and concerns:
  - Expand institutional coverage (extrabudgetary units, local governments, and public corporations).
  - Expand instrument coverage to include other accounts payable and all domestic pending bills.
  - Improve data consistency with other macroeconomic datasets.
  - Enhance granularity of data presentation.
  - Enrich metadata with additional information on compilation methods, approaches to revisions, and whether data is final or provisional.
  - Include information on alignment with, and divergence from, international statistical standards.
  - Provide contact persons to address users’ concerns and queries and to monitor users' sentiments on the usefulness of the data disseminated.
- Survey summary findings (selected):
  - Nearly all respondents used IMF or World Bank databases; other sources included official national debt bulletins and the NSDP.
  - All respondents rated disseminated PSDS as analytically either useful or very useful.
  - Users were satisfied with periodicity but would benefit from additional detailed data.
  - Users were neither satisfied nor dissatisfied with timeliness.
  - Users reported they never receive advance notice regarding major changes introduced to PSDS.
  - Users agreed PSDS are presented in a way that facilitates proper interpretation and meaningful comparisons; most indicated PSDS is partly consistent with other macroeconomic datasets.

### Strengths
- Quarterly debt reports are published within three months of the quarter end and annual reports within six months of the end of the year consistent with the SDDS requirements.
- The PSDS demonstrates good levels of internal consistency between publications.
- A Technical Statistics Producers Committee and a Statistics Producers Committee are in place and meet quarterly to discuss progress and challenges regarding the participation of the e-GDDS and subscription to the SDDS.
- Botswana macroeconomic statistics including PSDS are disseminated regularly, via the NSDP accompanied with comprehensive metadata.
- Botswana public debt statistics are compiled and presented in a manner that facilitates proper interpretation and meaningful comparisons.
- Debt data disseminated through the NSDP and the QPSD are fully aligned with international presentations and facilitate cross-country comparability as well as downloadability for further analysis.
- Metadata are comprehensive and meet the requirements of the IMF’s data standards initiatives.

### Recommendations for improvements
- Publish a release calendar to inform users when each public debt report will be published and disseminate reports in accordance with this calendar.
- Review external sector datasets that depend on PSDS data in line with the recent revisions of historical time series.
- Develop, publish, and apply a PSDS revision policy to guide users and PSDS compilers in reporting and classifying revisions.
- Publish the Quarterly Debt Bulletin regularly.
- Include detailed and comprehensive metadata for the Quarterly Debt Update publications on MoF’s website.
- Provide contact people to address users’ concerns and queries and to monitor users’ sentiments on the usefulness of the data disseminated.

*IMF | Technical Report – Botswana Data Quality Assessment for PSDS*

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_Source: https://www.imf.org/-/media/files/publications/tar/2025/english/tarea2025078-source-pdf.pdf_
