## governance-commitments-in-covid-19-rapid-instruments-as-of-9-1-2020

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### Section 1 — Overview and common governance safeguards
- Lists governance safeguards included in Letters of Intent (LOIs) for COVID-19-related rapid instruments (RCFs and RFIs) approved by the IMF’s Executive Board as of August 31, 2020.
- Exclusions: (i) the commitment to undertake a central bank safeguards assessment (required in all cases), and (ii) governance-related prior actions (included in several cases).
- Governance-related commitments were added in all RFI/RCFs except in: Albania, Bosnia and Herzegovina, Cabo Verde, Cote D’Ivoire, Dominica, Ghana, Kosovo, North Macedonia, Panama, Senegal, and St. Lucia.

### Section 1 — Transparency and publication commitments (selected country excerpts)
- Afghanistan (RCF): publish quarterly reports on pandemic-related spending, including procurement contracts and the beneficial ownership of companies awarded those contracts; undertake audits of selected spending performed by the Supreme Audit Office and publish the audit reports by end-December.
- Bahamas (RFI): publish procurement contracts of crisis mitigation spending including beneficial ownership information; report quarterly on COVID-19 mitigation spending; audits by the Auditor General within 9 months of the end of the fiscal year; finalize Public Procurement Law by end-June and submit Public Financial Management Bill and Public Debt Management Bill to Parliament by end-2020.
- Bangladesh (RFI): publish (i) an audit of COVID-19 related expenditures by the Office of the Comptroller and Auditor General within 12 months and (ii) crisis-related public procurement contracts and related documents including names of companies awarded contracts and ex-post validation of delivery.
- Democratic Republic of Congo (RCF): publish online all COVID-19 related procurement contracts that exceed US$12,000 and, for the contracts exceeding USD 1 million, disclose beneficial ownership information; undertake monthly internal audit and a specific audit as part of the annual control of the Audit Court, which should be published.
- Djibouti (RCF): publish on the Ministry of Budget’s website procurement contracts of COVID-19 expenditures in excess of US$100,000 and the beneficial ownership of selected companies; commission an independent ex-post audit in about a year and publish results.
- Ecuador (RFI): regularly publish on SERCOP COVID-19-related public procurement contracts and related documents including names of awarded companies and their beneficial owners and ex-post validation of delivery; undertake an independent audit by mid-2021 and publish results.
- Ethiopia (RFI): publish all public contracts related to the COVID-19 response; publish online eligibility criteria and budgeted limits for relief measures; frequent monthly monitoring of spending; make information available to internal auditors and, as soon as practicable, independent auditors for ex-post audits.
- Gabon (RFI): commit to on-line publication of all related procurement contracts and beneficial ownership information within thirty days of each contract award (second request); commission an independent third-party audit and publish outcomes on-line within nine months of the end of each relevant fiscal year (second request).
- Multiple other countries (e.g., Bolivia, Burkina Faso, Cameroon, Central African Republic, Comoros, Costa Rica, Dominican Republic, Egypt, El Salvador, Eswatini) commit to publishing procurement contracts, beneficial ownership, periodic reporting, and ex-post audits with specified timelines.

### Section 1 — Audit, oversight, and timing patterns
- Common commitments across LOIs:
  - Publish procurement contracts and related documents, including beneficial ownership information.
  - Commission independent ex-post audits or third-party audits of COVID-19-related spending and publish results.
  - Report periodically on COVID-19 expenditures (quarterly, bi-monthly, semi-annual).
  - Publish audit results within specified timeframes such as “within 9 months of the end of the fiscal year,” “within 12 months,” “within six months of disbursement,” “by end-December,” “by mid-2021,” and “within thirty days of each contract award.”
- Specific monetary thresholds noted:
  - Democratic Republic of Congo (RCF): publish procurement contracts exceeding US$12,000; disclose beneficial ownership for contracts exceeding USD 1 million.
  - Djibouti (RCF): publish procurement contracts of COVID-19 expenditures in excess of US$100,000.

### Section 1 — Procurement and beneficial ownership transparency (practices and reform commitments)
- Recurrent commitments:
  - Publish names of awarded companies and their beneficial owners.
  - Publish ex-post validation of delivery and delivery reports.
  - Publish full text of procurement contracts online.
  - Adopt or finalize procurement and public financial management laws or bills (example: Bahamas deadlines).

### Section 2 — Budget execution, publication, and audit commitments
- Budget execution:
  - Continue to publish budget execution reports on a quarterly basis with specific information on pandemic-related spending.
  - Create or use dedicated funds/accounts for COVID-19 spending, often linked to the Treasury Single Account (TSA) or a “COVID-19 Pandemic Response Fund”.
  - Prepare comprehensive supplementary budgets and full audits of emergency spending once situation normalizes.
- Procurement documentation to be published:
  - Signed procurement contracts, procurement plans, notices, and awarded contracts.
  - Names of awarded companies and the names of their beneficial owner(s).
  - Ex-post validation of delivery.
  - Full texts of related procurement contracts and bidding documents, including for state-owned enterprises and joint stock companies with state shares of more than 50 percent and their subsidiaries.
- Publication platforms cited include ministry websites, Public Procurement portals, and country-specific procurement sites.

### Section 2 — Audit commitments and country-specific timelines (selected examples)
- Guatemala (RFI): audit report by an independent external auditor of RFI-financed spending no later than six months after the end of the fiscal year.
- Guinea (RFI): publish monthly reports on execution of COVID-19 related spending; Court of Accounts to conduct a full audit published online by June 2021.
- Kyrgyz Republic: subject procurement of urgently needed medical supplies to ex-post audit by the Audit Chamber; publish results on the Ministry of Finance website.
- Lesotho: full audit by the Auditor General of the revised FY2020/21 budget including targeted audit of COVID-19 related expenditure; publish and disseminate within 5 months after the end of the fiscal year.
- Liberia (RCF): General Audit Commission to conduct a post-crisis audit within a year of the RCF disbursement and publish results online within two weeks of finalization; publish procurement contracts above thresholds along with awarded companies, beneficial owners, and validation of delivery (thresholds: US$200,000 for goods, US$400,000 for works, US$100,000 for services).
- Madagascar (2nd RCF): independent third-party audit of contracts to be published on-line by end-December 2021; Cour des Comptes to produce independent audit report on the emergency fund for 2020 published on-line by end-December 2021.
- Mongolia: commission an independent third-party audit within six months of disbursement and publish results on the MOF website.
- Montenegro: State Audit Institution to publish audit results online within 12 months of the end of the fiscal year.
- Malawi: National Audit Office to submit quarterly audits of COVID-19 related spending and publish comprehensive audit to Parliament after pandemic.

### Section 2 — Selected numeric thresholds and timeframes (exact figures)
- Liberia: publish procurement contracts paid from the budget in the remainder of FY2020 and all of FY2021 above a value of US$200,000 for goods, above US$400,000 for works, and above US$100,000 for services.
- Guatemala: audit report no later than six months after the end of the fiscal year.
- Guinea: Court of Accounts audit to be published online by June 2021.
- Madagascar: independent third-party audit published on-line by end-December 2021; Cour des Comptes independent audit published on-line by end-December 2021.
- Montenegro: publish audit results online within 12 months of the end of the fiscal year.
- Lesotho: publish audit results within 5 months after the end of the fiscal year.
- Mongolia: commission independent third-party audit within six months of disbursement and publish results.

### Section 3 — Transparency, procurement disclosure, and auditing (selected country commitments)
- Myanmar: publish quarterly reports on all COVID-19 related expenditure; publish targeted audit results by the Office of the Auditor General for Myanmar (OAGM) within 6 months of the end of the fiscal year; publish procurement contracts above Kyat 100 million within 3 months of being signed including names of companies and their beneficial owners, price per unit, and overall contract amount; publish ex-post validation of delivery.
- Nepal: report quarterly and commission independent audit by the Office of Auditor General of Nepal in about a year’s time; publish large procurement documentation with ex-post validation of delivery and beneficial owner names.
- Nigeria: create specific budget lines and report monthly on the transparency portal (http://opentreasury.gov.ng/); publish procurement plans and notices including names of awarded companies and beneficial owners; publish independent audit report no later than three to six months after the end of the fiscal year.
- Papua New Guinea: post procurement awards within a week on the government procurement website including names of entities and their beneficial owners, price per unit, and overall contract amount; consolidated report to be published within three months of the end of the emergency; audit by reputable independent auditor within a year of the end of the emergency.
- Rwanda: E-Procurement system to publish participants, each initial bid, winning bid name and price, total contract amount, and delivery period; Office of the Auditor General to audit and publish outcomes.
- Sierra Leone: Audit Service Sierra Leone to audit COVID-19 Fund management and publish online within 12 months of the end of the fiscal year; publish large public procurement contracts with awarded companies and beneficial owners and ex-post validation of delivery.
- Solomon Islands: audit results by the Office of the Auditor General before December 2021; publish procurement documentation including names of entities and beneficial owners and ex-post validation of delivery.
- South Africa: Auditor General to audit COVID-19-related expenditures including ex-post valuation of delivery within 12 months of the end of the fiscal year and publish findings; publicly disseminate COVID-19-related procurement contracts and allocation with awarded companies and beneficial owners.
- Uganda: publish documentation on large procurement contracts defined as contracts above Ush500 million for works and above Ush200 million for goods and services; undertake independent audit in about a year’s time including ex-post validation of delivery.
- Uzbekistan: publish monthly reports on COVID-19 related expenditures on www.mf.uz; Chamber of Accounts to publish ex-post audit report no later than six months after the end of the fiscal year as part of the regular audit of the 2020 State Budget Report.

### Section 3 — Procurement disclosure and thresholds (selected exact figures)
- Myanmar: disclose procurement contracts above Kyat 100 million within 3 months of being signed.
- Papua New Guinea: first consolidated COVID-19 expenditure report circulated on May 18; procurement award details posted within a week.
- Uganda: publish large procurement contracts above Ush500 million (works) and above Ush200 million (goods and services).
- Uzbekistan: publish ex-post audit report no later than six months after the end of the fiscal year as part of the regular audit of the 2020 State Budget Report.

_italics: governance-commitments-in-covid-19-rapid-instruments-as-of-9-1-2020 - Sections 1–3 (source PDF content provided)_

### Section 1

### Governance Commitments in Letters of Intent for COVID19-Related Rapid Instruments — Section 1

### Overview
- This section lists governance safeguards included in Letters of Intent (LOIs) for COVID-19-related rapid instruments (RCFs and RFIs) approved by the IMF’s Executive Board as of August 31, 2020.
- Exclusions noted in the source: (i) the commitment to undertake a central bank safeguards assessment, which is required in all cases, and (ii) governance-related prior actions, which were included in several cases.
- The source notes that governance-related commitments have been added in all of these RFI/RCFs except in the following: Albania, Bosnia and Herzegovina, Cabo Verde, Cote D’Ivoire, Dominica, Ghana, Kosovo, North Macedonia, Panama, Senegal, and St. Lucia.

### Transparency and Publication Commitments
- Afghanistan (RCF): “We will do our utmost to ensure effectiveness and strong governance in implementing crisis-mitigation measures. To ensure full transparency, we commit to publishing quarterly reports on pandemic-related spending, including procurement contracts and the beneficial ownership of companies awarded those contracts. We will undertake audits of selected spending, to be performed by the Supreme Audit Office in line with our legislative framework and publish the audit reports by end-December. In addition, as per standard practice, select donor-financed programs and projects will be audited by external auditors approved by donors.”
- Bahamas (RFI): “We will adhere to best practices in procurement and contract awards related to the pandemic, ensuring transparency and ease of tracking of COVID-19 expenditures in the budget. We have recently re-established the Audit Committee to strengthen implementation of recommendations by internal and external audits. The Auditor General is empowered to undertake regular audits of public procurement. We will publish procurement contracts of crisis mitigation spending, including beneficial ownership information of companies awarded procurement contracts, report quarterly on COVID-19 mitigation spending, and such spending will be audited by the Auditor General in accordance with international best practice within 9 months of the end of the fiscal year, and auditing results will be published on the government’s website. We will also ask the Auditor General to quantify the revenue losses that are directly associated with the COVID-19 pandemic. [...] We intend to finalize the Public Procurement Law—which will modernize our procurement system and bring it in line with international best practice—by end-June this year. We also plan to submit the Public Financial Management Bill and the Public Debt Management Bill to Parliament by end-2020.”
- Bangladesh (RFI): “We are committed to ensuring that crisis resources are used transparently and effectively. Toward that end, we will ensure that applicants for COVID-19 related contracts provide their beneficial ownership information to the government and that this information is appropriately recorded and made available to audit authorities and will publish online (i) an audit of COVID-19 related expenditures and other government subsidized programs by the Office of the Comptroller and Auditor General within 12 months and (ii) crisis-related public procurement contracts and related documents, including the names of the companies awarded the contract and ex-post validation of delivery. We will seek to adopt reforms to allow publication of beneficial ownership information of companies awarded public procurement contracts as soon as feasible.”
- Bolivia (RFI): “…we commit to adhere to best practices in procuring and awarding contracts related to the pandemic (including by publishing regularly documentation on procurement contracts on the government’s website, together with ex-post validation of delivery along with the name of awarded companies and the name of their beneficial owners) as well as publishing an external independent audit report on virus-related expenditures once the crisis is over.”
- Burkina Faso (RCF): “The government also commits to a transparent and accountable use of the funds disbursed under the RCF, including by enhancing transparency of health-related expenditures.”
- Cameroon (RCF): “We will ensure that the financial assistance received is used for the intended purposes, in strict compliance with the provisions of the Law on the Code for Transparency and Good Governance in Public Finance Management in Cameroon and the Law on the Financial Regime for the Government and Other Public Entities, all adopted in July 2018. For this purpose, the funds linked to COVID-19 will be subject to the strict application of the budgetary procedures and controls provided for by the above Laws. In addition, we commit to issue a semi-annual report on COVID-19 related spending and to commission an independent audit of this spending at the end of the 2020 fiscal year and publish the results. We also commit to publishing documents relating to the results of public procurement awarded by the government and the beneficial ownership of companies receiving procurement contracts on COVID-19 related expenditures. In the meantime, such COVID-19 related expenditures are being incorporated in a supplementary budget in preparation and expected to be presented to the Parliament in June 2020.”
- Central African Republic (RCF): “…we will ensure that the additional external financing we are receiving is used effectively to address crisis-related needs and will undertake an independent audit of the crisis-mitigation spending after the crisis abates, whose results we will publish.”
- Comoros (RCF/RFI): “We concur with Fund staff that strengthening institutions and promoting good governance, transparency and accountability, and tackling corruption are crucial for inclusive and sustainable growth. We are keen to ensure that the best possible use will be made of the funds provided by the IMF and to that effect, we will enhance mechanisms of reporting and controls for the disbursement of funds, building on recommendations of IMF-provided capacity building on government accounting of recent years. We commit to report quarterly on the spending of these funds and to commission an independent and robust third-party audit of this spending in about a year’s time and publish its results. The Government will also publish regularly on its website dedicated to public procurement documentation on large public procurement projects, together with ex-post validation of delivery along with the name of awarded companies and the name of their beneficial owner(s). The Government expects that this website will be operational within six months. The Government will start publishing the information on its general website in case the website dedicated to procurement should become operational only with a delay.”
- Costa Rica (RFI): “We are also committed to using the RFI resources transparently and through established governance mechanisms, including ex-post accountability and controls, to ensure the funds are used to address the Covid-19 related shocks.”
- Democratic Republic of Congo (RCF): “The proper use of those resources will be guaranteed through the implementation of our public financial management legislation, but also through the publication of budget execution figures contained in the treasury plan on a monthly basis to enhance financial transparency. Moreover, we commit to publish online all COVID-19 related procurement contracts that exceed US$12,000 and, for the contracts exceeding USD 1 million, to disclose the beneficial ownership information of contracted companies. We will also undertake a monthly internal audit as well as a specific audit of COVID-19 related expenditures as part of the annual control of audit of the Audit Court, which should be published. To ensure resource revenue transparency and in line with commitments with the EITI of which DRC is a member, a presidential ordinance will be signed confirming the appointment of the National EITI Coordinator approved by the Council of Ministers on March 13. In addition, the monthly payments of the operating allowance of the DRC EITI will resume to allow the resumption of its work. Furthermore, the government’s commitment to fight against corruption in DRC is shown by the recent issuance of a decree establishing an anti-corruption agency and also by the intention to publish and implement an anti-corruption action plan based on ongoing governance and safeguards assessments.”
- Djibouti (RCF): “To foster transparency of accounting and management of resources, we will outline the new measures in a supplementary budget expected to be submitted to Parliament in May. We are also committed to continuing to adhere to the best fiscal management practices and to ensuring that the best possible use is made of the resources provided by the IMF and our other partners. To do so, we will (i) publish on the Ministry of Budget’s website, once they are signed, procurement contracts of COVID-19 expenditures in excess of US$100,000 as well as the beneficial ownership of the selected companies, and (ii) commission an independent ex-post audit of COVID-19-related spending in about a year’s time and publish the results.”
- Dominican Republic (RFI): “… we commit to adhere to best practices in procuring and awarding contracts related to the pandemic as well as publishing an externally audited report on virus-related expenditures once the crisis is over.”
- Ecuador (RFI): “We remain committed to implementing strong control, reporting, and transparency requirements concerning public sector finance statistics and crisis-related government spending. Ecuador will continue to comply with the Fund’s safeguards policies. We are committed to the highest level of governance to help safeguard the resources committed to fight the pandemic, including (i) by regularly publishing on the government’s website (SERCOP) COVID-19-related public procurement contracts and related documents, including the names of the awarded companies and their beneficial owners, and ex-post validation of delivery, as well as information on all other COVID-19 related spending; and (ii) by undertaking an independent audit of COVID-19-related spending by the Office of the Comptroller General by mid-2021 and publishing the results. Any additional spending and or initiatives to combat the pandemic will be subject to similar assurances.”
- Egypt (RFI): “In the interest of transparency and accountability, we will continue to track and report all crisis-related spending, including through our various fiscal documents published throughout the budget cycle in line with international best practices. We intend to publish all crisis-related spending in a consolidated manner on the ministry of finance web site and we will publish government procurement plans and awarded contracts for the emergency responses to COVID-19, including the names of the awarded companies and information on beneficial ownership in accordance with the applicable law. As is customary, the State Audit Authority will audit crisis-mitigating inflows and spending including ex-post validation of delivery, and publish the results after the end of the fiscal year in line with our constitutional mandate.”
- El Salvador (RFI): “We remain committed to strengthen competitiveness by improving the business environment, reduce public debt, combat corruption, and strengthen the financial supervision and regulatory framework, and the governance and AML/CFT frameworks.” The staff report also notes that the president assigned the International Commission Against Impunity in El Salvador (CICIES) to inspect the COVID-19 emergency funds and nominated a Committee in Charge and Accountable for Administering the Fund.
- Eswatini (RFI): “First, we fully recognize the importance of ensuring that financial assistance and budget allocations to support COVID 19-related spending are used for intended purposes. To that end, we will: (i) use specific budget lines to facilitate the tracking and reporting of the release of funds of all crisis-mitigation spending, and (ii) publish on the National Disaster Management Agency (NDMA)’s website (www.ndma.org.sz) bi-monthly reports on funds released and expenditures incurred for health, social and other crisis-mitigation spending; (iii) regularly publish, on the Eswatini Public Procurement Regulatory Agency (ESPPRA)’s website (www.sppra.co.sz), signed public procurement contracts for crisis-mitigation spending, along with the names of awarded legal persons and their beneficiary owners, and ex-post validation of delivery; in addition, (iv) the Auditor General will undertake a financial and compliance audit of all crisis-mitigation spending and related procurement processes using independent external audit companies and will publish the results within six-months from the end of the 2020/21 fiscal year. Moreover, the Eswatini Public Procurement Regulatory Agency (ESPPRA) will undertake separate compliance and value-for money audits of all procurement activities related to COVID-19 spending, and publish the result on its website. [...] Finally, the government continues to support the strengthening of the Anti-Corruption Commission. Despite the fiscal constraints, the funding to the agency has increased in the last two years to support the upgrading of its systems, building staff capacity, and accelerate the solution of pending cases.”
- Ethiopia (RFI): “We commit to a transparent and accountable delivery of policy measures to respond to COVID-19 health and economic challenges and to effectively mitigate corruption concerns. Targeted measures will include (i) publishing all public contracts related to the COVID-19 response, using open and competitive bidding and strictly limiting the use of emergency non-competitive processes to the extent possible; (ii) publishing online eligibility criteria and budgeted limits for the various relief measures as soon as they are adopted; (iii) channeling donor funding through the budget with full transparency on its utilization; (iv) frequent monitoring of spending on crisis mitigation measures at the end of each month for the duration of the crisis; and (v) making information on how emergency relief funds are spent available to internal auditors and, as soon as practicable, to independent auditors to conduct ex-post audits over COVID-19 related spending and revenue collection.”
- Gabon (RFI): First request: “The government will continue to publish information on revenue and expenditure performance on a regular basis, and to provide a separate reporting mechanism for COVID-19 expenditures in order to assure transparent accounting of all the funding received to combat the pandemic. We commit to report quarterly on the spending of emergency funds and to commission an independent, third-party audit of this spending within six months of disbursement and publish the results. The published results will include the full text of all related procurement contracts, along with the beneficial ownership information for the companies receiving those contracts.” Additional commitments in the second request (applying also to spending financed by the first request): “We are [...] committed to the effective and transparent use of public funds, including on the use of funds to respond to the COVID-19 pandemic and on the funds from the RFI. We commit to provide a separate reporting mechanism for COVID-19 expenditures in order to assure transparent accounting of all the funding received to combat the pandemic. This commitment includes the on-line publication of all related procurement contracts, along with the beneficial ownership information for the legal persons receiving those contracts, within thirty days of each contract award, and the on-line publication of ex post reports on the delivery of these procurement contracts. Moreover, we will commission a reputable firm to conduct an independent, third-party audit of all government expenditures and procurement tenders linked to the pandemic, which will be finalized with the support of the Court of Accounts, whose independence is enshrined in the constitution and law, and will publish the outcome on-line within nine months of the end of each relevant fiscal year.”

### Audit, Oversight, and Timing Commitments
- Common commitments across multiple LOIs include:
  - Publishing procurement contracts and related documents, including beneficial ownership information.
  - Commissioning independent ex-post audits or third-party audits of COVID-19-related spending and publishing results.
  - Reporting periodically (quarterly, bi-monthly, semi-annual) on COVID-19 expenditures.
  - Publishing audit results within specified timeframes such as “within 9 months of the end of the fiscal year,” “within 12 months,” “within six months of disbursement,” “by end-December,” “by mid-2021,” and “within thirty days of each contract award.”
- Specific monetary thresholds noted:
  - Democratic Republic of Congo (RCF): publish online all COVID-19 related procurement contracts that exceed US$12,000 and, for the contracts exceeding USD 1 million, disclose beneficial ownership information.
  - Djibouti (RCF): publish procurement contracts of COVID-19 expenditures in excess of US$100,000.

### Procurement and Beneficial Ownership Transparency
- Multiple LOIs commit to:
  - Publishing the names of awarded companies and the names of their beneficial owners.
  - Publishing ex-post validation of delivery and delivery reports.
  - Publishing the full text of procurement contracts online.
  - Adopting or finalizing procurement and public financial management laws or bills (e.g., Bahamas: Public Procurement Law by end-June; Bahamas: Public Financial Management Bill and Public Debt Management Bill to Parliament by end-2020).

*Source: governance-commitments-in-covid-19-rapid-instruments-as-of-9-1-2020 - Section 1 (IMF PDF).*

### Section 2

### governance-commitments-in-covid-19-rapid-instruments-as-of-9-1-2020 - Section 2

### Budget execution and publication commitments
- Budget execution reports will continue to be published on a quarterly basis, with specific information on pandemic related spending.
- Several countries commit to creating or using dedicated funds/accounts for COVID-19 spending, often linked to the Treasury Single Account (TSA) or a “COVID-19 Pandemic Response Fund”.
- Governments commit to preparing comprehensive supplementary budgets and full audits of emergency spending once the situation normalizes to assess the total fiscal cost of addressing COVID-19 and to avoid creating undue spending pressures in subsequent budgets.

### Procurement transparency and contract publication
- Commitments to publish procurement documentation, including:
  - signed procurement contracts,
  - procurement plans, notices, and awarded contracts,
  - names of awarded companies and the names of their beneficial owner(s),
  - ex-post validation of delivery.
- Some countries commit to publishing full text of related procurement contracts and bidding documents, including those of state-owned enterprises and joint stock companies with state shares of more than 50 percent and their subsidiaries.
- Publication platforms cited include ministry websites, Public Procurement portals, and country-specific procurement sites (e.g., www.guatecompras.gt).

### Audit commitments and timelines
- Ex-post audits by independent auditors, Courts of Accounts, State Audit Institutions, or Auditor General offices are widely committed to, with publication of results. Examples include:
  - Guatemala: audit report by an independent external auditor of RFI-financed spending no later than six months after the end of the fiscal year.
  - Guinea: publish monthly reports on execution of COVID-19 related spending; Court of Accounts will conduct a full audit published online by June 2021.
  - Kyrgyz Republic: subject procurement of urgently needed medical supplies to an ex-post audit by the Audit Chamber; results to be published on the Ministry of Finance website.
  - Lesotho: full audit by the Auditor General of the revised FY2020/21 budget, including targeted audit of COVID-19 related expenditure, with results to be published and disseminated within 5 months after the end of the fiscal year.
  - Liberia: General Audit Commission to conduct a post-crisis audit of all crisis response spending within a year of the RCF disbursement and publish results online within two weeks of its finalization.
  - Madagascar: commission an independent third-party audit of contracts, to be published on-line by end-December 2021; Cour des Comptes to produce an independent audit report on the emergency fund for 2020 published on-line by end-December 2021.
  - Mongolia: commission an independent third-party audit of COVID-19 spending within six months of disbursement and publish results on the MOF website.
  - Montenegro: State Audit Institution will audit crisis-mitigating spending and publish results online within 12 months of the end of the fiscal year.
  - Malawi: National Audit Office will submit quarterly audits of COVID-19 related spending to the Minister of Finance and, once the pandemic abates, publish a comprehensive audit to Parliament.
- Several commitments specify ex-post validation of delivery as part of audit and publication requirements.

### Specific country commitments (selected excerpts)
- Gambia (RCF): ensure full transparency and proper budget procedure for emergency assistance; use provisions under the Public Finance Act to proceed with spending reallocations and create a temporary fund within the TSA; prepare a comprehensive supplementary budget and a full audit once situation normalizes.
- Grenada (RCF): resources received from development partners will be earmarked for specific COVID-19-related expenses; accurate and timely information will be provided to the public as envisioned in the supplementary 2020 budget.
- Guatemala (RFI): commit to publish quarterly reports of COVID-19 related expenditures and all related signed procurement contracts (www.guatecompras.gt), including names of awarded companies and beneficial owners, and an ex-post validation of delivery; audit report by an independent external auditor no later than six months after the end of the fiscal year.
- Guinea (RFI): create a budgetary fund for earmarked external and domestic resources; establish a dedicated TSA account; publish monthly reports on execution; inspectorate-general will conduct timely ex-post control of high-risk expenditures with civil society involvement; publish all awarded procurement contracts and beneficial owners; Court of Accounts to conduct full audit of COVID-19 spending.
- Haiti (RCF): prepare monthly budget execution reports for all COVID-19 expenditures; undertake thorough ex post financial and operational audit of all COVID-19 related operations.
- Jamaica (RFI): adhere to best practices in procurement; publicly available procurement information including beneficial ownership; request Auditor General’s Department undertake and publish ex-post audit of COVID-related spending.
- Jordan (RFI): create specific budget lines, link fund to the TSA, publish procurement plans/notices/awarded contracts including beneficial ownership, undertake ex-post audits by the Audit Bureau and publish results within 6 months from the end of the fiscal year.
- Kenya (RCF): commit to post-crisis auditing by independent audit office of samples of crisis-related expenditures and publication of results; strengthen institutions to detect illicit enrichment and address conflict of interest.
- Kyrgyz Republic (RFI/RCF): subject procurement of urgently needed supplies to ex-post audit by the Audit Chamber and publish results; publish documentation on all direct procurement and competitive bidding including state-owned enterprises and subsidiaries; publish ex-post validation of delivery with names and beneficial owners.
- Lesotho (RFI & RCF): publish quarterly reports on budget implementation including COVID lines; internal audit quarterly on COVID expenditure; full Auditor General audit of revised FY2020/21 budget with targeted audit of COVID spending published within 5 months after fiscal year end; publish signed procurement contracts and beneficial owner names.
- Liberia (RCF): post-crisis audit within a year; publish audit results online within two weeks of finalization; publish procurement contracts above specified thresholds along with awarded companies, beneficial owners, and validation of delivery (thresholds: US$200,000 for goods, US$400,000 for works, US$100,000 for services).
- Madagascar (2nd RCF): adopted Multisectoral National Response Plan; decree establishing “COVID-19 Pandemic Response Fund”; commit to publish lists of financial transfers, signed procurement contracts, legal entities and beneficial owners, ex-post delivery reports; commission independent third-party audit published by end-December 2021; quarterly budget execution reports with pandemic-specific information; Cour des Comptes independent audit of emergency fund for 2020 to be published by end-December 2021.
- Malawi (RCF): publish procurement documentation (tenders, bids, awarded companies, products/services and costs) on PPDA website; publish beneficial owners and ex-post validation of delivery; publish quarterly statements on commitments and payments of COVID-19 activities; specify COVID-19 related costs in monthly salary report; National Audit Office to submit quarterly audits and publish comprehensive audit to Parliament after pandemic.
- Maldives (RCF): commit to improve fiscal reporting and transparency to meet international standards and strengthen SOE risk supervision and fiscal responsibility framework.
- Mali (RCF): report quarterly on spending of funds and commission independent third-party audit in about a year’s time; publish documentation on large public procurement projects with ex-post validation and beneficial owner names.
- Mauritania (RCF): keep all spending on-budget, track and report resources on ministry of finance website, publish procurement contracts and beneficial owners, and request Court of Accounts to audit emergency spending and publish results.
- Moldova (RFI/RCF): implement strong control, audit, reporting and transparency requirements; publish public procurement and beneficial owners; subject crisis-mitigation spending to dedicated audit by the Court of Accounts Chamber and make the audit report public.
- Mongolia (RFI): publish quarterly reports on COVID-19 expenditures on MOF website; commission independent third-party audit within six months of disbursement and publish results including full text of procurement contracts, awarded companies, beneficial owners, and ex-post validation of delivery.
- Montenegro (RFI): State Audit Institution to audit crisis spending including ex-post validation and publish results within 12 months of fiscal year end; publish procurement plans, notices and awarded contracts including beneficial owners; adopted new AML/CFT law and guidelines.
- Mozambique (RCF): undertake independent audit of crisis-mitigation spending and related procurement processes once crisis abates and publish results; publish large public procurement contracts, names of awarded companies, beneficial owners, and ex-post validation of delivery.
- Myanmar (RCF/RFI): commit to strengthen anti-money laundering and anti-corruption frameworks and ensure crisis resources are used transparently and effectively.

### Thresholds and timeframes (selected exact figures)
- Liberia: publish procurement contracts paid from the budget in the remainder of FY2020 and all of FY2021 above a value of US$200,000 for goods, above US$400,000 for works, and above US$100,000 for services, along with names of the companies awarded, their beneficial owners, and validation of delivery.
- Guatemala: audit report by an independent external auditor of RFI-financed spending no later than six months after the end of the fiscal year.
- Guinea: publish monthly reports on execution of COVID-19 related spending; Court of Accounts audit to be published online by June 2021.
- Madagascar: independent third-party audit to be published on-line by end-December 2021; independent audit of emergency fund for 2020 published on-line by end-December 2021.
- Montenegro: publish audit results online within 12 months of the end of the fiscal year.
- Lesotho: publish audit results within 5 months after the end of the fiscal year.
- Mongolia: commission an independent third-party audit within six months of disbursement and publish results.

_Italic: governance-commitments-in-covid-19-rapid-instruments-as-of-9-1-2020 - Section 2 (source PDF content provided)_

### Section 3

### governance-commitments-in-covid-19-rapid-instruments-as-of-9-1-2020 - Section 3

### Transparency and public reporting commitments
- Myanmar: publish on the MOPFI website (i) quarterly reports on all COVID-19 related expenditure; (ii) the results of a targeted audit of COVID-19 related expenditures by the Office of the Auditor General for Myanmar (OAGM) within 6 months of the end of the fiscal year; (iii) information on procurement contracts on COVID-19 related expenditure within 3 months of being signed above Kyat 100 million, including the names of the companies awarded and their beneficial owners, the specific nature of the goods or services procured, price per unit, and the overall contract amount; and, (iv) reports of ex post validation of delivery related to (iii). The ADB will also assist us in publishing CERP progress reports.
- Nepal: commit to report quarterly on the spending of these funds and to commission an independent audit by the Office of Auditor General of Nepal of COVID-19 related spending in about a year’s time; publish the quarterly reports and audit results on the website of the implementing agencies; publish large public procurement documentation together with ex-post validation of delivery along with the name of awarded companies and the name of their beneficial owner(s); allocate and execute all COVID-19 related expenditures using existing public financial management processes and within legislated frameworks; allocation details will be made public on the Ministry of Finance website.
- Nigeria: (i) create specific budget lines to facilitate the tracking and reporting of emergency response expenditures and report funds released and expenditures incurred monthly on the transparency portal (http://opentreasury.gov.ng/); (ii) publish procurement plans, procurement notices for all the emergency response activities—including the name of awarded companies and of beneficial owners—on the Bureau of Public procurement website; and (iii) publish no later than three to six months after the end of the fiscal year the report of an independent audit into the emergency response expenditures and related procurement process, to be conducted by the Auditor General of the Federation.
- Papua New Guinea: State of Emergency Controller posts details of all procurements awarded on the government procurement website within a week of procurement, including the names of the entities awarded the contract and their beneficial owners, the specific nature of the goods or services procured, their price per unit, and the overall contract amount, as well as reports of ex-post validation of delivery; COVID-19 expenditure reports presented to the Budget Management Committee on a weekly basis with the first report circulated on May 18; a consolidated report will be submitted to the National Executive Council and published within three months of the end of the emergency; commission and publish an audit, conducted by a reputable independent auditor, of COVID-related spending within a year of the end of the emergency.
- Rwanda: carry out transparency of procurement in accordance with the Law Governing Public Procurement and E-Procurement system providing publicly available information on all awarded government contracts, including the name of companies that participated in the tender, each initial bid, the name and price of the winning bid, the total amount of the contract, and the delivery period; Office of the Auditor General will audit all government expenditures and procurement tenders, including those linked to the pandemic, and publish the outcome.
- Sao Tome and Principe: ensure proper monitoring of all expenditure relating to the pandemic and improve transparency in public procurement; adopt measures by end-April 2020 to ensure better transparency and publicity regarding public procurement by publishing on the website of Ministry of Finance (MOF) or through announcements on other media (i) public procurement contracts, once signed, that require prior authorization from the Court of Accounts as per the Organic Law (no. 11/2019) and the ex-post validation of delivery of the contracts and (ii) monthly COVID-19 related expenditure; a revised budget will be submitted to parliament when conditions allow, at the latest by end-July; conduct an independent audit of spending after the crisis abates and publish the results.
- Seychelles: submit monthly reports of the emergency spending on wage subsidies, health, and social spending to Finance Public Accounts Committee (FPAC) of the National Assembly; these reports will be made public within three months; undertake an independent audit of emergency spending and related procurement processes and publish its results.
- Sierra Leone: COVID-19 Response Transparency Taskforce launched to ensure integrity, accountability and transparency in the use and management of funds; established a COVID-19 account and begun regular reporting on the use of these emergency funds; Audit Service Sierra Leone will audit the management of the COVID-19 Fund and COVID-19 response and publish its report online within 12 months of the end of the fiscal year as required under the Constitution and laws of Sierra Leone, including the PFM Act 2016; plan to publish on the Government’s website large public procurement contracts related to crisis mitigation, the names of the companies awarded contracts, their beneficial owners, and ex-post validation of delivery.
- Solomon Islands: publish on the Ministry of Finance and Treasury’s website (i) results of an audit by the Solomon Islands Office of the Auditor General of COVID-19 related expenditures before December 2021; and (ii) documentation on crisis-related public procurement, including the nature of the goods or services procured, the contract amounts, the names of the entities awarded the contract and their beneficial owners, followed by documentation on ex-post validation of delivery.
- South Africa: commit to transparently plan, use, monitor and report all Covid-19 related spending by (1) publishing on a regular basis the execution of Covid-19-related expenditures, auditing such expenditure, including ex-post valuation of delivery, within 12 months of the end of the fiscal year, to be performed by the Auditor General and publishing the findings; and (2) publicly disseminating all Covid-19-related procurement contracts and allocation (with details about awarded companies and their beneficial owners).
- St. Vincent & the Grenadines: publish procurement documentation including information on the beneficial owners of the companies that receive crisis-related procurement contracts, report monthly on COVID-related expenditures, and undertake a full ex-post financial and operational audit of COVID-19 spending at the time of the annual audit.
- Tajikistan: prepare quarterly reports on the spending of emergency funds and publish the results on the external website of the Ministry of Finance; subject health spending, including procurement of urgently needed medical supplies, and social spending to ex-post audits by the Chamber of Accounts and ex-post validation of deliveries in a year’s time, which will also be published on the external website of the Ministry of Finance; improve transparency of procurement processes in line with international best practices.
- Uganda: provide a separate reporting mechanism for COVID-19 expenditures in the context of Program Based Budgeting; publish, once they are signed, documentation on the government’s website of large procurement contracts—defined as contracts above Ush500 million for works contracts, and above Ush200 million for goods and services—of COVID-19 expenditures, together with the names of awarded companies and their beneficial owners; undertake an independent audit of COVID-19 expenditures in about a year’s time, which will include an ex-post validation of delivery of the large procurement contracts, and publish the results.
- Uzbekistan: (i) appropriate COVID-19 emergency measures through the Anti-Crisis Fund; (ii) publish reports of COVID-19 related expenditures on a monthly basis on the Ministry of Finance website (www.mf.uz); (iii) publish on the Ministry of Finance website (www.mf.uz) COVID-19 related signed public procurement contracts and related documents, including the names of companies awarded those contracts and ex-post validation of delivery and will continue to improve our procurement framework expeditiously in line with international best practice, including by publishing information on beneficial owners; and (iv) ensure the Financial Control Department of the Ministry of Finance includes all COVID-19 related expenditures in its forthcoming inspections; the Chamber of Accounts will conduct an ex-post audit of COVID-19 expenditures and related procurement processes and will publish the audit report no later than six months after the end of the fiscal year as part of the regular audit of the 2020 State Budget Report.

### Procurement disclosure and beneficial ownership
- Myanmar: disclose procurement contracts above Kyat 100 million within 3 months of being signed, including names of companies and their beneficial owners, specific nature of goods/services, price per unit, and overall contract amount; provide ex post validation of delivery.
- Nepal: publish large public procurement documentation and ex-post validation of delivery with names of awarded companies and their beneficial owner(s).
- Nigeria: publish procurement plans and procurement notices including the name of awarded companies and of beneficial owners on the Bureau of Public procurement website.
- Papua New Guinea: post procurement award details within a week on the government procurement website including names of entities and their beneficial owners, price per unit, and overall contract amount; provide ex-post validation of delivery.
- Rwanda: E-Procurement system publishes participants, each initial bid, winning bid name and price, total contract amount, and delivery period.
- Sao Tome and Principe: publish public procurement contracts requiring prior authorization and ex-post validation of delivery on MOF website or other media.
- Sierra Leone: publish large public procurement contracts related to crisis mitigation with names of companies awarded contracts and their beneficial owners and ex-post validation of delivery.
- Solomon Islands: publish procurement documentation including contract amounts, names of entities awarded and their beneficial owners, and ex-post validation of delivery.
- South Africa: publicly disseminate all Covid-19-related procurement contracts and allocation with details about awarded companies and their beneficial owners.
- St. Vincent & the Grenadines: publish procurement documentation including information on beneficial owners of recipient companies.
- Uganda: publish large procurement contracts above Ush500 million (works) and Ush200 million (goods/services) with awarded companies and beneficial owners.
- Uzbekistan: publish signed public procurement contracts and related documents including names of awarded companies and ex-post validation of delivery; improve procurement framework and publish information on beneficial owners.

### Audit, ex-post validation, and timing commitments
- Myanmar: targeted audit results by OAGM within 6 months of the end of the fiscal year; ex post validation reports.
- Nepal: independent audit by the Office of Auditor General of Nepal of COVID-19 related spending in about a year’s time.
- Nigeria: independent audit into emergency response expenditures and procurement to be published no later than three to six months after the end of the fiscal year.
- Papua New Guinea: audit by reputable independent auditor of COVID-related spending within a year of the end of the emergency.
- Rwanda: Office of the Auditor General will audit pandemic-linked expenditures and publish the outcome.
- Sao Tome and Principe: independent audit of spending after the crisis abates and publish results.
- Seychelles: independent audit of emergency spending and related procurement processes and publish results.
- Sierra Leone: Audit Service Sierra Leone to audit COVID-19 Fund management and publish within 12 months of the end of the fiscal year.
- Solomon Islands: audit results of COVID-19 related expenditures by the Office of the Auditor General before December 2021.
- South Africa: Auditor General to audit Covid-19-related expenditures, including ex-post valuation of delivery, within 12 months of the end of the fiscal year, and publish findings.
- St. Vincent & the Grenadines: undertake a full ex-post financial and operational audit of COVID-19 spending at the time of the annual audit.
- Tajikistan: ex-post audits by the Chamber of Accounts and ex-post validation of deliveries in a year’s time; publish on Ministry of Finance external website.
- Uganda: independent audit of COVID-19 expenditures in about a year’s time including ex-post validation of delivery of large procurement contracts.
- Uzbekistan: Chamber of Accounts will publish the ex-post audit report no later than six months after the end of the fiscal year as part of the regular audit of the 2020 State Budget Report.

*Source: governance-commitments-in-covid-19-rapid-instruments-as-of-9-1-2020 - Section 3 (PDF).*

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_Source: https://www.imf.org/-/media/files/topics/covid/governance-commitments-in-covid-19-rapid-instruments-as-of-9-1-2020.pdf_