## Appendix I. Officials met during the Mission

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### Background
- Assessment framework and mission:
  - Conducted against the IMF’s Data Quality Assessment Framework (DQAF) for Public Sector Debt Statistics (PSDS) 2024.
  - Mission funded under a two-year project by the Government of Japan through the Japan Administered Account for Selected IMF Activities (JSA).
  - Mission took place from July 23 to 29, 2025.
- Agencies assessed:
  - The National Treasury and Economic Planning (NT), the Central Bank of Kenya (CBK) and the Kenya National Bureau of Statistics (KNBS).
- Data dissemination and gaps:
  - Kenya participates in the IMF’s Enhanced General Data Dissemination System (e-GDDS) and submits quarterly debt data to the Joint IMF-World Bank Quarterly Public Sector Debt statistics database (QPSD).
  - Debt data has not been updated on the e-GDDS National Summary Data Page (NSDP) since 2018Q4.

### Overall assessment highlights
- Public debt status and risks:
  - IMF-World Bank debt sustainability analysis (DSA) of October 2024: public debt considered sustainable but remains at high risk of debt distress.
  - Public debt-to-GDP ratio peaked at 72 percent at the end of the 2022/23 fiscal year.
  - Debt reported at 66 percent of GDP at the end of the 2023/24 fiscal year, according to national debt reports.
  - Around half of the total debt stock is external (mainly concessional) and the other half is domestic.
  - Key challenges: managing exchange rate risk of external debt and the high-interest rate cost of domestic debt.
- Mission objective:
  - Identify key strengths and areas for improvement in PSDS compilation and dissemination using the DQAF and recommend priority actions to enhance public debt data transparency.
- General conclusion:
  - Public debt statistics are broadly accurate and timely but require alignment with international statistical standards and broader scope in public sector debt reporting.

### Summary findings by DQAF dimension
- Prerequisites of quality (Legal and institutional environment):
  - Legal framework:
    - PDMO responsibility established in the Public Finance Management (PFM) Act 2012 and expanded in the PFM Regulations 2015.
    - Constitution of Kenya (article 229) requires annual audits of public debt.
    - Constitution of Kenya (article 214) defines public debt narrowly as loans raised or guaranteed and securities issued or guaranteed by the national government which result in a charge on the Consolidated Fund.
    - Recommendation: establish clear mandate for comprehensive reporting of all debt liabilities in line with international statistical standards; consider amending PFM Act or PFM Regulations if necessary.
  - Institutional environment and resources:
    - PDMO structured with back, middle and front office; PDMO staffing: 44 technical staff (per NT Strategic Plan 2023–27) and significant support staff.
    - CS Meridian is the central repository for public debt data; integration with CBK’s DhowCSD and NT’s IFMIS is underway.
    - Recommendation: revitalize the Technical Working Group (TWG) on GFS with structured quarterly meetings.
- Assurances of Integrity:
  - NT, CBK and KNBS are professional and impartial; Public Service Code of Conduct and Ethics 2016 and the Statistics Act underpin conduct.
  - Recommendation: disclose pre-release access lists and provide advance notice of changes in source data/methodology.
- Methodological Soundness:
  - Reports generally follow GFSM 2014 and PSDSG 2013 concepts.
  - Current external/domestic distinction is by currency rather than residency; CBK’s DhowCSD contains residency information that should be used.
  - Coverage limited to loan and debt security liabilities of the budgetary central government (BCG) and guarantees; recommendation to expand coverage across instruments and entities.
  - Priority instrument expansion: include other accounts payable (pending bills).
  - Securitizations of revenue flows (e.g., road maintenance levy securitization) should be recognized as debt liabilities per GFSM 2014 and PSDSG 2013.
  - Valuation: Kenyan reports use face value; preferred international valuation is nominal value. CS Meridian supports nominal valuation and market price information.
  - Recommendation: include tables/charts using GFSM 2014 and PSDSG 2013 classifications and taxonomies.
- Accuracy and Reliability:
  - Data sources: CBK’s DhowCSD for debt securities and PDMO’s CS Meridian for external loans are comprehensive and robust.
  - Need for new data sources to compile PSDS for entire public sector.
  - Potential source: quarterly and annual financial statements from all public sector entities transmitted to NT within 15 days of quarter-end and within two to three months of year-end; annual statements are audited.
  - Alternative source: self-reported outstanding pending bills collected by the OCOB, estimated at Ksh 684 billion for the public sector as at the end of March 2025.
  - Recommendation: publish comprehensive standardized reconciliation tables of changes in debt (transactions and flows) and have TWG assess PPPs and securitizations for potential imputed debt.
- Serviceability:
  - Kenya disseminates monthly, quarterly and annual public debt reports and some weekly aggregate reports.
  - Timeliness: quarterly and annual reports available two months and three months after period end, respectively; monthly reports less predictable.
  - Discrepancies among PDMO, CBK, KNBS and OCOB publications are numerous though generally small and likely explainable by vintages or compilation differences.
  - Recommendation: TWG on GFS to conduct regular consistency checks, remove immaterial differences before publication, and explain other differences to users.
  - Neither NT nor CBK currently follow a formal revision policy; NT has drafted a policy that should be finalized, published and implemented.
- Accessibility:
  - Quarterly and annual bulletins include graphs, charts, tables and commentary.
  - Major shortcoming: lack of adequate metadata explaining terms, coverage, valuations, and compilation methods.
  - Recommendation: provide comprehensive structured metadata and consider machine-readable dissemination (Excel or .csv) as done by CBK.
  - User support: contact information provided; promotion of Citizens’ Service Delivery Charter services could be enhanced.

### Priority recommendations (as listed)
- Establish a clear mandate for the compilation and dissemination of public debt statistics in line with the debt definition of the international statistical standards.
- Revitalize the TWG on GFS by establishing regular structured quarterly meetings which address PSDS quality assurance and identified areas for PSDS development and improvement.
- Expand the sector coverage of the public debt reports to comprehensively cover the non-guaranteed borrowing of public units outside the BCG.
- Expand the instrument coverage of the public debt reports to cover other accounts payable (pending bills).
- Report external and domestic debt based on the residency of the creditor/investor, in addition to the current reporting based on currency.
- Review details of PPP projects, and securitization operations, and where applicable apply statistical techniques to calculate imputed debt in accordance with international statistical standards.
- Provide more comprehensive and accessible metadata in a structured format 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.

### Additional detailed findings and recommendations
- Legal and institutional specifics:
  - PDMO established under PFM Act 2012 (sections 62-64) and PFM Regulations 2015 (sections 183-206).
  - Constitutional constraint: article 214 limits scope of debt reporting to charges on the Consolidated Fund.
  - KNBS oversees official statistics under the Statistics Act (rev. 2019) and publishes annual PSDS in the KNBS annual Economic Survey.
  - CBK administers domestic currency debt securities and external public debt payments and publishes PSDS despite no legal mandate for reporting.
- Resources and systems:
  - CS Meridian used by PDMO; CBK uses DhowCSD. Integration of systems expected to automate processes and improve quality.
  - Recommendation: update PDMO middle office operational manual to align with the back office manual and maintain regularly updated comprehensive documentation to support business continuity and quality.
- Scope and instruments:
  - Scope currently limited to BCG loans and debt securities and guarantees; PDMO began including non-guaranteed borrowing of 21 state corporations/agencies as an annex in the 2023/24 report.
  - Instrument omissions include other accounts payable (pending bills), deposit-related liabilities, pension liabilities, finance leases, PPP-related liabilities, securitization operations.
  - Pending bills breakdown and size as at end-March 2025:
    - Total outstanding pending bills: 684 billion Kenyan Shillings (Ksh).
    - Ministries, Departments and Agencies: 90 billion Ksh.
    - Counties: 172 billion Ksh.
    - State corporations, state-owned entities and semi-autonomous government agencies: 422 billion Ksh.
  - Actuarial valuation under way for historic defined benefit pension scheme.
- Valuation and consolidation:
  - Current valuation: face value (outstanding principal for loans and redemption value for debt securities).
  - International recommendation: nominal valuation with continuously accruing interest.
  - CS Meridian facilitates reporting at nominal value; recommendation to disseminate reports at both face and nominal value.
  - As coverage expands beyond BCG, consolidation and identification of intra-public-holder debt needed to avoid double counting.

### Accuracy, validation, and statistical procedures
- CS Meridian enforces checks and validations on granular debt data and PDMO conducts cross-checks (including biannual cross-checks for guaranteed loans of SOEs).
- The QPSD is obtained from CS Meridian but published QPSD data are inconsistent with national debt publications; discrepancies larger for domestic debt than external debt.
  - Recommendation: investigate variances and reconcile datasets or provide explanatory metadata.
  - Recommendation: complete the QPSD time series which has gaps in 2016 and 2018.
- Statistical techniques for non-cash liabilities:
  - No statistical techniques currently used to include non-cash liabilities (e.g., PPPs, securitization) or to impute related debt.
  - Recommendation: PDMO should assess PPPs and securitizations and apply statistical techniques where applicable; TWG on GFS could provide oversight.
- Reconciliation and revisions:
  - Annual tables identify transactions and flows but do not include price changes (e.g., foreign exchange revaluations); management migrating to accrual accounting to capture these.
  - Recommendation: publish reconciliation tables demonstrating internal consistency of published data, including foreign exchange changes (example Annex III Table A2).
  - PDMO does not undertake revision studies; recommendation to undertake regular revision studies to detect persistent reporting biases.

### User survey results (selected aggregated responses and key statistics)
- Consent question response counts: "13 3".
- Respondent institutions:
  - Academia and research institutes: 3
  - International charities: 2
  - Foreign governments: 3
  - International organizations: 4
  - Civil society organizations: 1
  - Public sector: 3
- Main interests in PSDS data:
  - Policy-making: 13
  - Compilation of other macro-economic statistics: 3
  - Investment decisions: 5
  - Academia or research: 3
  - Other analytical work: 1
  - No response: 3
- Analytic usefulness (Question 4):
  - Very useful: 5
  - Useful: 10
  - Somewhat useful: 1
  - Not useful: 0
  - Undecided: 0
- Perceived unbiasedness and accuracy (Question 5):
  - Strongly agree: 3
  - Agree: 10
  - Neither agree nor disagree: 1
  - Disagree: 2
  - Strongly disagree: 0
- Satisfaction with timeliness and detail (Question 6):
  - Very satisfied: 1
  - Satisfied: 8
  - Neither satisfied nor dissatisfied: 6
  - Dissatisfied: 1
  - Very dissatisfied: 0
- Coverage gaps reported:
  - Instruments inadequately covered (Question 10):
    - Accounts payables (arrears): 13
    - Loans: 4
    - Debt securities: 4
    - Pension liabilities: 9
    - Other: 3
  - Subsectors needing more coverage (Question 11):
    - Local government / State governments: 13
    - Public corporations: 12
    - Budgetary central government: 5
    - Extra-budgetary units: 9
- Valuation appropriateness (Question 12):
  - Yes: 13
  - No: 3
- Timeliness and dissemination:
  - Are PSDS disseminated in a sufficiently timely manner? (Question 14)
    - Yes: 6
    - No: 3
    - Not sure: 7
  - Is comprehensive published source and methods document/metadata readily accessible? (Question 20)
    - Yes, available and accessible: 1
    - Partial information available: 8
    - No information available: 2
    - Not sure: 4

### Standardized reporting templates (appendix summaries)
- Table A1 (Standardized Quarterly Debt Reporting Table) recommended elements:
  - Breakdown by maturity and instrument type; debt by currency of denomination; debt by residence of creditor; interest rate type; memoranda items including "Debt securities at market value", "Publicly guaranteed debt", "Arrears".
- Table A2 (Reconciliation between Public Sector Debt Flows and Stocks) recommended structure:
  - Opening balance; CHANGES DURING THE PERIOD (Transactions, Other Economic Flows including Incurrence of liability, Repayment of liability, Other, Revaluations, Other Volume Changes, Principal Interest lines); Closing balance.
  - Instrument rows include SDRs; Currency and deposits; Debt securities; Loans; Insurance, pensions, and standardized guarantee schemes; Other accounts payable.

### Authorities’ response
- Government of Kenya appreciation:
  - Expresses appreciation to the IMF and the Government of Japan for the technical assistance mission conducted between 23rd – 29th July, 2025.
  - Commits to strengthen transparency, accuracy, and reliability of PSDS and to work closely with CBK, KNBS, OCOB, and development partners to implement recommended actions.

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

### Appendix I. Officials met during the Mission ...........................................................................

### Appendix I. Officials met during the Mission

### Background
- The assessment was conducted against the IMF’s Data Quality Assessment Framework (DQAF) for Public Sector Debt Statistics (PSDS) 2024.
- The mission was undertaken under a two-year project funded by the Government of Japan through the Japan Administered Account for Selected IMF Activities (JSA).
- The mission took place from July 23 to 29, 2025.
- Agencies assessed: The National Treasury and Economic Planning (NT), the Central Bank of Kenya (CBK) and the Kenya National Bureau of Statistics (KNBS).
- Kenya participates in the IMF’s Enhanced General Data Dissemination System (e-GDDS) and submits quarterly debt data to the Joint IMF-World Bank Quarterly Public Sector Debt statistics database (QPSD).
- Debt data has not been updated on the e-GDDS National Summary Data Page (NSDP) since 2018Q4.

### Overall assessment highlights
- Kenya’s public debt status and risks:
  - IMF-World Bank debt sustainability analysis (DSA) of October 2024: public debt considered sustainable but remains at high risk of debt distress.
  - Public debt-to-GDP ratio peaked at 72 percent at the end of the 2022/23 fiscal year.
  - Debt reported at 66 percent of GDP at the end of the 2023/24 fiscal year, according to national debt reports.
  - Around half of the total debt stock is external (mainly concessional) and the other half is domestic.
  - Key challenges: managing exchange rate risk of external debt and the high-interest rate cost of domestic debt.
- Mission objective:
  - Identify key strengths and areas for improvement in PSDS compilation and dissemination using the DQAF and recommend priority actions to enhance public debt data transparency.
- General conclusion:
  - Public debt statistics are broadly accurate and timely but require alignment with international statistical standards and broader scope in public sector debt reporting.

### Summary findings by DQAF dimension
- Prerequisites of quality:
  - Legal environment:
    - PDMO responsibility established in the Public Finance Management (PFM) Act 2012 and expanded in the PFM Regulations 2015.
    - Constitution of Kenya (article 229) requires annual audits of public debt.
    - Constitution of Kenya (article 214) defines public debt narrowly as loans raised or guaranteed and securities issued or guaranteed by the national government which result in a charge on the Consolidated Fund.
    - Recommendation: establish clear mandate for comprehensive reporting of all debt liabilities in line with international statistical standards; consider amending PFM Act or PFM Regulations if necessary.
  - Institutional environment:
    - PDMO structured with back, middle and front office; sufficient staff resources but relatively high staff turnover.
    - CS Meridian is the central repository for public debt data; integration with CBK’s DhowCSD and NT’s IFMIS is underway and encouraged to be completed swiftly.
    - Recommendation: revitalize the Technical Working Group (TWG) on GFS with structured quarterly meetings.

- Assurances of Integrity:
  - NT, CBK and KNBS are professional and impartial; Public Service Code of Conduct and Ethics 2016 and the Statistics Act underpin conduct.
  - Major releases specify legal basis and contact details; recommendation to disclose pre-release access lists and provide advance notice of changes in source data/methodology.

- Methodological Soundness:
  - Reports generally follow GFSM 2014 and PSDSG 2013 concepts.
  - Current external/domestic distinction is by currency rather than residency; CBK’s DhowCSD contains residency information that should be used.
  - Coverage limited to loan and debt security liabilities of the budgetary central government (BCG) and guarantees; recommendation to expand coverage across instruments and entities.
  - Priority instrument expansion: include other accounts payable (pending bills).
  - Securitizations of revenue flows (e.g., road maintenance levy securitization) should be recognized as debt liabilities per GFSM 2014 and PSDSG 2013.
  - Valuation: Kenyan reports use face value; preferred international valuation is nominal value. CS Meridian supports nominal valuation and market price information.
  - Recommendation: include tables/charts using GFSM 2014 and PSDSG 2013 classifications and taxonomies.

- Accuracy and Reliability:
  - Data sources: CBK’s DhowCSD for debt securities and PDMO’s CS Meridian for external loans are comprehensive and robust.
  - Need for new data sources to compile PSDS for entire public sector.
  - Potential source: quarterly and annual financial statements from all public sector entities transmitted to NT within 15 days of quarter-end and within two to three months of year-end; annual statements are audited.
  - Alternative source: self-reported outstanding pending bills collected by the OCOB, estimated at Ksh 684 billion for the public sector as at the end of March 2025.
  - Recommendation: publish comprehensive standardized reconciliation tables of changes in debt (transactions and flows) and have TWG assess PPPs and securitizations for potential imputed debt.

- Serviceability:
  - Kenya disseminates monthly, quarterly and annual public debt reports and some weekly aggregate reports.
  - Timeliness: quarterly and annual reports available two months and three months after period end, respectively; monthly reports less predictable.
  - Discrepancies among PDMO, CBK, KNBS and OCOB publications are numerous though generally small and likely explainable by vintages or compilation differences.
  - Recommendation: TWG on GFS to conduct regular consistency checks, remove immaterial differences before publication, and explain other differences to users.
  - Neither NT nor CBK currently follow a formal revision policy; NT has drafted a policy that should be finalized, published and implemented.

- Accessibility:
  - Quarterly and annual bulletins include graphs, charts, tables and commentary.
  - Major shortcoming: lack of adequate metadata explaining terms, coverage, valuations, and compilation methods.
  - Recommendation: provide comprehensive structured metadata and consider machine-readable dissemination (Excel or .csv) as done by CBK.
  - User support: contact information provided; promotion of Citizens’ Service Delivery Charter services could be enhanced.

### Priority recommendations (as listed)
- Establish a clear mandate for the compilation and dissemination of public debt statistics in line with the debt definition of the international statistical standards.
- Revitalize the TWG on GFS by establishing regular structured quarterly meetings which address PSDS quality assurance and identified areas for PSDS development and improvement.
- Expand the sector coverage of the public debt reports to comprehensively cover the non-guaranteed borrowing of public units outside the BCG.
- Expand the instrument coverage of the public debt reports to cover other accounts payable (pending bills).
- Report external and domestic debt based on the residency of the creditor/investor, in addition to the current reporting based on currency.
- Review details of PPP projects, and securitization operations, and where applicable apply statistical techniques to calculate imputed debt in accordance with international statistical standards.
- Provide more comprehensive and accessible metadata in a structured format 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.

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

### 0. Prerequisites of quality

### 0. Prerequisites of quality

### 0.1 Legal and institutional environment
- Assessment rating excerpts:
  - LO: The primary responsibility and arrangements for collecting, processing, and disseminating public debt statistics is well established in the PFM Act 2012, and related legislation.
  - Constitutional constraint: The Constitution of Kenya limits the scope of debt reporting by defining public debt as a charge on the Consolidated Fund.
- Findings:
  - The PDMO is established under the PFM Act 2012 (sections 62-64) and PFM Regulations 2015 (sections 183-206).
  - The legal framework requires a variety of debt reports, including quarterly reports from public entities and a comprehensive annual debt report to Parliament within three months after the end of the financial year.
  - The Constitution of Kenya (article 214) defines public debt as loans raised or guaranteed and securities issued or guaranteed which represent a charge on the Consolidated Fund, excluding a wide range of debt instruments and some liabilities of non-budgetary public entities.
  - Independent oversight: Parliament, Office of the Controller of Budget (OCOB), and Office of the Auditor General (OAG) have designated responsibilities for oversight, approval, and audit of public debt.
  - KNBS (Statistics Act rev. 2019) oversees official statistics and publishes annual PSDS in the KNBS annual Economic Survey under the eight fundamental principles of official statistics.
  - CBK administers domestic currency debt securities and external public debt payments, and publishes PSDS in several of its publications despite having no legal mandate for reporting.
  - Data sharing and institutional coordination among PDMO, CBK, KNBS, and OCOB are well established, facilitated by the TWG on GFS, but TWG meetings are often ad hoc rather than the scheduled quarterly.
- Priority recommendations:
  - Establish a clear mandate for the compilation and dissemination of public debt statistics in line with the debt definition of the international statistical standards.
  - Revitalize the TWG on GFS by establishing regular structured quarterly meetings to address PSDS quality assurance and development, and to ensure consistency across PSDS published by the four organizations.

### 0.2 Resources
- Assessment rating excerpt:
  - O: The number of staff in the PDMO are adequate for their duties.
- Findings:
  - PDMO structure aligns with international good practice: front office (Resource Mobilization), middle office (Debt Policy, Strategy and Risk Management), back office (Debt Recording and Settlement).
  - PDMO staffing: 44 technical staff (per NT Strategic Plan 2023–27) and a significant number of support staff; staff resources assessed as sufficient and comparable regionally.
  - Staff qualifications: All technical staff have relevant degrees and receive structured training; management faces budgetary constraints and relatively high staff turnover.
  - Systems: PDMO uses CS Meridian; CBK uses DhowCSD (Central Securities Depository). Systems are well maintained; CS Meridian was run in parallel with the previous system for a year before switch over.
  - Current document sharing via secured government email domains; management developing a dedicated secure intranet platform.
- Priority recommendations:
  - Update PDMO middle office operational manual to align with the back office manual and maintain regularly updated comprehensive documentation to support business continuity and quality.

### 0.3 Relevance
- Assessment rating excerpt:
  - LO: PDMO have made efforts to consult users on issues related to Kenyan public debt.
- Findings:
  - PDMO conducted public consultation on the 2025 Medium-Term Debt Strategy (MTDS); outreach to rating agencies and investors/creditors is documented in the PDMO’s annual public debt management report 2023/24.
  - Stakeholder engagements tend to focus on debt levels, sustainability, and management rather than debt reporting.
  - An electronic survey of Kenyan PSDS users was conducted (findings described in Appendix II of source).
- Priority recommendations:
  - Establish regular communication channels to consult with users specifically on the adequacy and relevance of existing debt reports, and systematically identify user demands across advanced and less-knowledgeable stakeholders (general public, media).

### 0.4 Other quality management
- Assessment rating excerpt:
  - O: There is recognition throughout the PDMO of the importance of quality in debt reporting.
- Findings:
  - NT Strategic Plan 2023-2027 highlights system integration and transparency as priorities to improve efficiency and build trust.
  - Back office operational manual recently updated with step-by-step guidance and screenshots; middle office manual is outdated and lacks necessary detail.
  - Integration of CS Meridian with CBK’s DhowCSD and government IFMIS expected to automate processes and improve data quality and staff capacity to focus on quality.
- Priority recommendations:
  - Maintain and enhance operational procedural manuals for both back office and middle office; ensure regular updates and comprehensive coverage.

### Strengths (as listed)
- Legislative framework (Constitution, PFM Act 2012 and related legislation) provides clarity on stakeholder responsibilities for debt management and reporting.
- Staff and ICT resources are sufficient for compilation and dissemination of quality debt data, with opportunities to improve staffing and document management.
- Use of CS Meridian and ongoing integration with CBK’s DhowCSD and IFMIS supports efficient delivery of high quality debt data.

### Recommendations for improvements (summary)
- Establish a clear mandate for compilation and dissemination of public debt statistics in accordance with international statistical standards.
- Revitalize the TWG on GFS with regular structured quarterly meetings addressing quality assurance and PSDS development.
- Establish regular communication channels to consult with users on adequacy and relevance of debt reports and to identify user demands.
- Update the PDMO middle office operational manual to provide detailed guidance and minimize impacts of staff turnover.

*Source: tarea2026025 - 0. Prerequisites of quality*

### 26. Staff involved in the production of PSDS are highly professional and supported by

### 26. Staff involved in the production of PSDS are highly professional and supported by structured training and performance review procedures.

### Professionalism and Legal Framework
- Staff at PDMO, CBK and KNBS are recruited based on relevant expertise and experience.
- Structured opportunities for formal and on-the-job training are available.
- Management and HR policies support and promote a culture of professional conduct.
- Legal frameworks support reporting of debt in accordance with professional independence:
  - Oversight of OCOB and audit function of OAG provide checks and balances to ensure integrity and accuracy of reported public debt data.
  - The Statistics Act requires all official statistics, including PSDS, to be produced impartially and with strict adherence only to professional considerations.
- Given KNBS’s relatively peripheral role in PSDS compilation, it is unclear to what extent principles of official statistics are currently applied or can be effectively implemented for public debt compilation and reporting.

### Transparency
- Terms and conditions for dissemination of PSDS are transparently laid out in the quarterly and annual NT publications:
  - Quarterly Economic and Budgetary Review references relevant sections of the PFM Act 2012 in its introduction.
  - Introduction to the Annual Debt Management Report describes the legal and institutional framework, including reference to the Constitution of Kenya 2010, PFM Act 2012 and PFM Regulations 2015.
- Debt reports indicate producing agency and provide contact details for users, with one exception:
  - PDMO’s monthly debt bulletin indicates the compiling agency is the NT but does not provide any contact details.
- Gaps relative to international statistical practice for transparency:
  - Debt reports do not disclose which individuals had access to the PSDS prior to release to the public.
  - Metadata in all debt publications is very limited.
  - No evidence of advance notice being given to users of changes in methodology or source data.

### Ethical Standards
- Public Service Code of Conduct and Ethics 2016 establishes expected conduct and penalties for misconduct.
- PDMO staff are required to sign the code of conduct at recruitment and are reminded of it (and the citizens’ service delivery charter) via signage in atriums.

Strengths:
- The PDMO, CBK and KNBS staff involved in debt reporting are highly professional and understand their obligations and core mandate.
- Ethical standards are established in the Public Service Code of Conduct and Ethics 2016.
- Significant amounts of formal and on-the-job training are provided to staff to maintain and upskill.
- Checks and balances in procedures are appropriate to ensure quality of reported debt.

Recommendations for Improvements:
- Disclose within debt publications those individuals with prior access to debt information before public release.
- Include information within debt publications on major changes to source data and/or methodology.
- Routinely notify data users of any changes in methodology or source data.

### Methodological Soundness — Concepts, Scope, Classification, Valuation
- Concepts and Definitions:
  - Kenya’s gross debt broadly follows GFSM 2014 and PSDSG 2013 concepts. Reports capture outstanding noncontingent contractual liabilities and some contingent liabilities (government guaranteed borrowing of parastatals) under “public and publicly guaranteed debt”.
  - Recommendation: Report gross debt as noncontingent debt only and present guaranteed debt separately as supplementary information.
- Distinction between external and domestic debt:
  - Currently based on currency; all domestically issued debt securities are reported as domestic debt even when held by nonresidents.
  - Recommendation: Report external/domestic debt based on residency of creditor/investor as per international standards.
  - CBK improvements: DhowCSD central securities database and new sectorization of debt securities have recently improved resident/nonresident identification.
- IMF SDRs allocated in 2021:
  - Recorded correctly as domestic debt liabilities of the Kenyan budgetary central government (BCG).
  - In Kenyan context, SDR allocations considered liabilities of CBK; SDR funds were transferred to NT under a loan agreement. External SDR liabilities are recognized as liabilities of CBK with corresponding domestic loan liability of NT to CBK.
- Scope of coverage:
  - Public debt reporting limited to BCG and BCG guarantees of other public entities; excludes extrabudgetary units, local governments (counties), public corporations (unless guaranteed).
  - Borrowing contracted by national government and on-lending is included in government debt; directly contracted debts of public entities captured only when guaranteed.
  - PDMO has begun including outstanding non-guaranteed debt of public entities as an annex (non-guaranteed borrowing of 21 state corporations/agencies included in the 2023/24 report).
  - Recommendation: Expand coverage to comprehensively include all borrowing of public units (loans and debt securities) and include aggregated public sector debt in main tables.
- Instrument coverage omissions:
  - Reports limited to loans and debt securities and omit other debt liabilities: other accounts payable (pending bills), deposit-related liabilities, pension liabilities.
  - Pending bills: as at end of March 2025 there were 684 billion Kenyan Shillings (Ksh) across the public sector in outstanding pending bills, amounting to almost 4 percent of GDP.
    - Breakdowns: 90 billion Ksh in pending bills for Ministries, Departments and Agencies; 172 billion Ksh for counties; 422 billion Ksh for state corporations, state-owned entities and semi-autonomous government agencies.
  - Actuarial valuation under way for historic defined benefit pension scheme to provide basis for inclusion of pension liabilities in PSDS.
- Securitization, PPPs, and financial leases:
  - Securitization of future revenue (e.g., Road Maintenance Levy) has occurred but not recognized in debt reporting.
  - GFSM 2014 (paras. A3.59-A3.66) guidance: securitization should be treated as a loan to securitization unit or direct government borrowing; future revenue stream repays borrowing — thus should be recorded in PSDS.
  - Debt from financial leases and PPPs should also be reflected in PSDS; NT has role in reviewing, approving and monitoring such arrangements (Public Regulations 2015 – sections 128 and 194).
- Classification/sectorization and presentation:
  - Debt reported across many publications (PDMO, CBK, KNBS) but generally not using PSDSG 2013 standardized tables, inhibiting cross-country comparison.
  - Recommendation: Expand reporting to include standardized tables (e.g., Table A1 in Appendix III) and reconcile inconsistencies between national debt reports and data reported to the Joint IMF-World Bank QPSD database.
- Time of Recording, Valuation, Consolidation:
  - Valuation: Kenya reports debt at face valuation (outstanding principal for loans and redemption value for debt securities); internationally recommended is nominal valuation with interest accruing continuously.
  - CS Meridian facilitates reporting at nominal value; recommendation to disseminate reports at both face and nominal value.
  - Consolidation: Current scope limited to BCG loans and debt securities so consolidation not yet required; as coverage expands, identifying debt holders is important to avoid double counting (e.g., domestic on-lending of external loans).

Strengths:
- Comprehensive reporting of loans and debt securities for the BCG.
- Guaranteed debt of public entities outside the BCG are separately identified.
- Wide range of debt reports providing granular and aggregate data.

Recommendations for Improvements:
- Report external and domestic debt based on residency of creditor/investor in addition to current currency-based reporting.
- Expand sector coverage to include extrabudgetary units, local governments, social security funds, and public corporations following KNBS Public Sector Institutional Table sectorization.
- Expand instrument coverage to include other accounts payable (pending bills) and securitization of future public revenue streams, prior to deposit and pension liabilities.
- Disseminate aggregate PSDS reports using standard international statistical formats (see Table A1 of Appendix III) at both face and nominal value.

### Accuracy and Reliability — Source Data and Assessment
- Domestic currency debt securities:
  - Robust data on issuances, payments and redemptions is held by CBK in DhowCSD.
  - Data extracted from DhowCSD are shared with PDMO on request (typically monthly) in an MS Excel tool which is manually uploaded into Meridian.
  - Integration of DhowCSD directly with CS Meridian is ongoing and expected to be completed within the 2025/26 financial year.
- External loans and external currency debt securities:
  - Comprehensive data maintained in CS Meridian; details of each loan contracted (and guaranteed) and tracking of disbursements and payments are held.
  - Integration of CS Meridian with NT’s IFMIS is being pursued to facilitate efficient servicing of loan payments.
- Additional data needs to expand PSDS coverage:
  - Required sources include accounts payable (pending bills), non-guaranteed borrowing, pension liabilities, deposit-related liabilities, finance leases, PPP-related liabilities, securitization operations.
  - Supplementary information on contingent liabilities would require further additional data.
- Potential data sources for expansion:
  - Timely financial statements produced by all public sector entities (PFM Act 2012 section 83 mandates submission of quarterly and annual financial statements to NT/AGD).
    - Quarterly reports due within 15 days of quarter end; annual reports within three months (mission advised requirement to move earlier to within two months after year end).
    - Annual consolidated financial statements are subject to audit by OAG.
  - OCOB stock of pending bills and GIPE collection of financial data from state corporations/agencies.
    - Suggestion: GIPE could expand GIMIS to capture outstanding stocks and contractual loan details to allow entry into CS Meridian.
- Assessment of source data and validation:
  - Current source data are routinely assessed.
  - CS Meridian facilitates validation, quality assurance, and reporting with inbuilt validation checks to flag discrepancies.
  - PDMO conducts cross-checks of external debt data (biannual cross-checks with debtors and creditors for guaranteed loans of SOEs).
  - PDMO departments have staff operational manuals describing validation and reconciliation processes; middle office manual needs expansion and updating.

*Source: tarea2026025 - 26. Staff involved in the production of PSDS are highly professional and supported by structured training and performance review procedures.*

### 48. The QPSD is obtained from CS Meridian, however the published data are not consistent

### 48. The QPSD is obtained from CS Meridian, however the published data are not consistent

### Data sources and consistency
- The QPSD is obtained from CS Meridian but the published data are not consistent with any national debt publications, including those issued by the PDMO which are also sourced from CS Meridian.
- Discrepancies are considerably more pronounced in domestic debt compared to external debt, where differences remain minimal.
- Recommendation: the PDMO should promptly investigate these variances and either reconcile the datasets or provide comprehensive explanatory metadata to explain the inconsistencies.
- Recommendation: complete the QPSD time series which has gaps in 2016 and 2018.

### Statistical techniques
- Statistical rules around debt assumption are applied when distinguishing between guaranteed and non-guaranteed debt. Example: in the last two years, government debt guarantees related to the borrowing by Kenya Airways were called resulting in substantial amounts of debt being removed from the reported guaranteed debt and included instead within the direct debts of government.
- No statistical techniques are used to include certain non-cash liabilities:
  - Non-cash liabilities, such as those for PPP projects, are not currently included via statistical techniques.
  - No statistical techniques are adopted to recognize the debt liability related to the securitization of the Road Maintenance Levy.
- Recommendation: PDMO needs a role in assessing PPP projects and novel arrangements such as securitizations to determine whether imputed debts should be calculated and included in the PSDS in accordance with the international statistical standards.
- Recommendation: oversight of these assessments could be usefully provided by the TWG on GFS to benefit from cross-institutional expertise and reach a commonly agreed understanding.

### Assessment and validation of statistical outputs
- PSDS outputs are routinely investigated for errors or discrepancies, but not using a comprehensive framework.
- Annual tables (External Public Debt Register) identify and quantify factors explaining differences between beginning and end-period debt values for each loan and debt security type, including repayment, disbursement, refinancing and restructuring.
- The tables do not include price changes (e.g., foreign exchange rate changes). Management is addressing this by migrating to an accrual accounting method which will capture this information.
- Recommendation: publish reconciliation tables that demonstrate the internal consistency of published data (Annex III (Table A2) provides an example). Such a table should transparently reconcile changes in debt stock over a period with the debt flows in that same period, including foreign exchange rate changes.

### Revision studies
- PDMO does not undertake revision studies to investigate potential errors, omissions, or unexplained fluctuations related to PSDS outputs.
- Recommendation: PDMO should undertake regular revision studies to refine preliminary data for subsequent periods and detect any ongoing misreporting. This is internationally accepted good practice and should be embedded in PDMO functions and operational procedures.

### Strengths (as reported)
- CS Meridian enforces a variety of checks and validations on the granular debt data that it contains, highlighting potential issues or inconsistencies to system users.
- The requirement for all borrowing of public sector entities to be approved by the PDMO ensures that the PDMO has a comprehensive view of all borrowing activities in the public sector.
- The production of timely quarterly and annual financial statements for all public sector entities provides a rich data source for the instrument and sector expansion of PSDS.
- The remit and cross-institutional expertise of the TWG on GFS allows it to play a key role in overseeing the data quality and accuracy of PSDS.

### Recommendations for improvements (consolidated)
- Develop data collection processes to compile PSDS for government entities beyond BCG, building on existing data collections and system developments, to assure good sector and instrument coverage.
- Reconcile or explain the discrepancies between PSDS as reported in national debt publications and that reported via the QPSD.
- Review details of PPP projects and securitization operations, and where applicable apply statistical techniques to calculate imputed debt in accordance with the international statistical standards.
- Review and publish in a complete framework a reconciliation of the change in debt stocks with the transactions and other flows (including exchange rate changes) driving the changes.
- Undertake regular revision studies to refine preliminary data for subsequent periods and identify any persistent reporting biases.

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

### 1. The results of this survey will be aggregated and anonymized for reporting purposes, but on occasion

### 1. The results of this survey will be aggregated and anonymized for reporting purposes, but on occasion it may be helpful to the narrative of the quality report to include specific quotes from users, do you give consent to your responses being quoted?

### A. User consent and profile
- Consent question: respondents asked if they give consent for specific quotes to be used.
  - Response counts: "13 3" (as presented in source).
- Survey responders by institution:
  - Academia and research institutes: 3
  - International charities: 2
  - Foreign governments: 3
  - International organizations: 4
  - Civil society organizations: 1
  - Public sector: 3

### A.1 Main interest in disseminated PSDS data
- Policy-making: 13
- Compilation of other macro-economic statistics: 3
- Investment decisions: 5
- Academia or research: 3
- Other analytical work: 1
- No response: 3

### A.2 Sources from which users obtain PSDS and related data
- Official national debt bulletins and press releases: 12
- IMF or World Bank databases and/or publications: 12
- Other international organization databases and/or publication: 2
- Media reports: 5
- Data published on the National Summary Data Page (NSDP): 6
- Private sector summaries and analyses: 4
- Other sources: 5

### B. Overall assessment — analytical usefulness and satisfaction
- Analytically useful (Question 4):
  - Very useful: 5
  - Useful: 10
  - Somewhat useful: 1
  - Not useful: 0
  - Undecided: 0
- Perceived unbiasedness and accuracy (Question 5):
  - Strongly agree: 3
  - Agree: 10
  - Neither agree nor disagree: 1
  - Disagree: 2
  - Strongly disagree: 0
- Satisfaction with timeliness and level of detail (Question 6):
  - Very satisfied: 1
  - Satisfied: 8
  - Neither satisfied nor dissatisfied: 6
  - Dissatisfied: 1
  - Very dissatisfied: 0

### C. Coverage and concepts
- Satisfaction with sector coverage (Question 7):
  - Very satisfied: 2
  - Satisfied: 9
  - Neither satisfied nor dissatisfied: 1
  - Dissatisfied: 4
  - Very dissatisfied: 0
- Satisfaction with coverage of debt instruments (Question 8):
  - Very satisfied: 2
  - Satisfied: 7
  - Neither satisfied nor dissatisfied: 3
  - Dissatisfied: 4
  - Very dissatisfied: 0
- Satisfaction with coverage of public nonfinancial corporations (Question 9):
  - Very satisfied: 0
  - Satisfied: 6
  - Neither satisfied nor dissatisfied: 3
  - Dissatisfied: 4
  - Very dissatisfied: 1

### C.1 Which debt instruments are inadequately covered? (Question 10)
- None – coverage is adequate for all debt instruments: 0
- Accounts payables (arrears): 13
- Loans: 4
- Debt securities: 4
- Pension liabilities: 9
- Other: 3

### C.2 Which subsectors need more coverage? (Question 11)
- None – coverage is adequate for all subsectors of the public sector: 0
- Local government / State governments: 13
- Public corporations: 12
- Budgetary central government: 5
- Extra-budgetary units: 9
- Other: 0

### C.3 Valuation appropriateness of outstanding stock positions (Question 12)
- Yes: 13
- No: 3

### D. Periodicity and timeliness
- Satisfaction with periodicity (Question 13):
  - Very satisfied: 1
  - Satisfied: 9
  - Neither satisfied nor dissatisfied: 4
  - Dissatisfied: 2
  - Very dissatisfied: 0
- Are PSDS disseminated in a sufficiently timely manner? (Question 14)
  - Yes: 6
  - No: 3
  - Not sure: 7

### E. Dissemination practices
- Is there a published release schedule and are releases punctual? (Question 15)
  - Yes, and the data is released on schedule: 1
  - Yes, and the data is sometimes released on schedule: 6
  - Yes, and the data is never released on schedule: 0
  - No: 3
  - Not sure: 6
- Is analysis published to explain revisions, breaks, adjustments? (Question 16)
  - Yes: 7
  - No: 5
  - Not sure: 2
  - No response: 2
- At time of dissemination, are users informed whether data are preliminary, revised, or updated? (Question 17)
  - Always informed: 5
  - Sometimes informed: 5
  - Never informed: 2
  - Not sure: 3
- Do users receive advance notice of major changes (coverage, methods, sources)? (Question 18)
  - Yes: 4
  - No: 6
  - Not sure: 1
  - No response: 4

### F. Accessibility and usefulness
- Presentation facilitates interpretation and comparisons (Question 19):
  - Strongly agree: 0
  - Agree: 12
  - Neither agree nor disagree: 4
  - Disagree: 0
  - Strongly disagree: 0
- Is comprehensive published source and methods document/metadata readily accessible? (Question 20)
  - Yes, available and accessible: 1
  - Partial information available: 8
  - No information available: 2
  - Not sure: 4
- Are PSDS largely consistent and reconcilable over time with other macroeconomic datasets? (Question 21)
  - Fully consistent: 0
  - Partly consistent: 9
  - Not consistent: 1
  - Not sure: 6

### Key statistics (as presented)
- Multiple itemized counts preserved verbatim across questions (examples above include: "13 3", "5 10 1 0 0", "1 8 6 1 0", etc.).

### Observations from survey material
- Commonly reported gaps: accounts payables (arrears) and pension liabilities flagged as inadequately covered.
- Stakeholders request greater coverage for local government / State governments and public corporations.
- Mixed user experience on timeliness: 6 respondents consider dissemination timely, 3 do not, 7 are not sure.
- Metadata and source documentation accessibility rated limited: 1 "Yes, available and accessible", 8 "Partial information available", 2 "No information available", 4 "Not sure".

### G. Appendices — standardized reporting templates (summary)
- Table A1: Standardized Quarterly Debt Reporting Table includes:
  - Breakdown by maturity and type of instrument (short-term by original maturity; long-term by original maturity; total gross debt; by currency of denomination; by residence of the creditor; by interest rate type).
  - Memoranda items including "Debt securities at market value", "Publicly guaranteed debt", "Arrears".
- Table A2: Reconciliation between Public Sector Debt Flows and Stocks includes:
  - Columns for Debt stocks: Opening balance; CHANGES DURING THE PERIOD (Transactions, Other Economic Flows including Incurrence of liability, Repayment of liability, Other, Revaluations, Other Volume Changes, Principal Interest lines); Debt stocks: Closing balance.
  - Instrument rows: Special Drawing Rights (SDRs); Currency and deposits; Debt securities; Loans; Insurance, pensions, and standardized guarantee schemes; Other accounts payable.
  - Notes clarifying treatment when data are not available, interest transaction impacts when stocks are at face value, what "Other transactions" include, common sources of revaluations, and footnote guidance for other volume changes.

### H. Authorities’ response to assessment report
- Government of Kenya appreciation:
  - Expresses appreciation to the IMF and the Government of Japan for the technical assistance mission conducted between 23rd – 29th July, 2025.
  - Mission provided insights into strengths and areas for improvement in Kenya’s Public Sector Debt Statistics (PSDS).
  - Acknowledges constructive engagement with IMF staff, collaborative stakeholder discussions, and recommendations aimed at enhancing transparency, accuracy, and reliability of Kenya’s debt reporting framework.
  - Commits to strengthen transparency, accuracy, and reliability of PSDS and to work closely with stakeholders including the Central Bank of Kenya (CBK), the Kenya National Bureau of Statistics (KNBS), the Office of the Controller of Budget (OCOB), and development partners to implement recommended actions.

*IMF | Technical Report – Kenya Data Quality Assessment for Public Sector Debt Statistics | excerpts from provided content*

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_Source: https://www.imf.org/-/media/files/publications/tar/2026/english/tarea2026025.pdf_