## may22matrix-implementation-status-of-governance-commitments-on-pandemic-related-spending

## Source details

**Canonical URL:** [may22matrix-implementation-status-of-governance-commitments-on-pandemic-related-spending](https://www.imf.org/-/media/files/topics/governance-and-anti-corruption/may22matrix-implementation-status-of-governance-commitments-on-pandemic-related-spending.pdf)

## Other formats

- [Markdown version](/-/media/files/topics/governance-and-anti-corruption/may22matrix-implementation-status-of-governance-commitments-on-pandemic-related-spending.pdf.md)
- [Structured JSON version](/-/media/files/topics/governance-and-anti-corruption/may22matrix-implementation-status-of-governance-commitments-on-pandemic-related-spending.pdf.json)

---

### Compliance audits and audit reporting (selected country highlights)
- Bangladesh
  - Compliance audit on accounts related to FY19/20 of quarantine expenditure for doctors and health workers in selected hospitals in Dhaka carried out under the Health Services Division of the Ministry of Health and Family Welfare.
  - Compliance audit related to FY19/20 with a special focus on COVID-related procurement carried out in organizations of Bangladesh Army, Bangladesh Navy, Bangladesh Air Force, and Inter Forces under the Ministry of Defense.
  - All three audit reports have been approved by the CAG and are in the process of being tabled in parliament through the president.
  - Audit reports reviewed by both the Prime Minister and President’s offices and sent to the Finance Minister’s office; Finance Minister’s office proposed tabling health audit reports during the June 9th session of parliament.
  - Once audit reports are tabled and accepted in parliament, reports will become public documents and be published on the CAG’s website.
- Cabo Verde: 2020 audited financial accounts, including COVID-related expenditures, were delivered to parliament; government continues to publish COVID-19-related expenditures on the Ministry of Finance website.
- Cameroon
  - Audit prepared by the Audit Bench of the Supreme Court (Chambre des Comptes) was published on November 16, 2021.
  - Revised Finance Law enacted in June 2020 allocates resources to a special COVID-19 account, financed at 76 percent by resources released by debt service suspension and external budgetary support.
- Central African Republic
  - Audit report covering budgetary expenditure finalized on August 31, 2021, is published; audit of expenditure implemented directly by donors remains pending.

### Procurement transparency and publication of contracts (commitments, thresholds, practices)
- Recurring commitment across many countries: publish COVID-19-related procurement contracts, names of awarded companies, and beneficial owners; complementary commitments included periodic reporting, dedicated accounts, ex-post independent audits, and publication of delivery/validation reports.
- Country-specific publication thresholds and practices (examples preserved verbatim):
  - DRC: publish procurement contracts exceeding US$12,000 and disclose beneficial ownership for contracts exceeding USD 1 million; identified 36 COVID-19-related contracts over US$12,000 totaling US$6.8 million.
  - Djibouti: publish contracts in excess of US$100,000 and beneficial ownership; no publications because contracts fell below US$100,000 threshold.
  - Liberia: publish procurement contracts paid from the budget above specified thresholds — above US$200,000 for goods, above US$400,000 for works, and above US$100,000 for services; full text of procurement contracts for FY19/20 above thresholds have been published on the PPCC’s website; publication of contracts for FY20/21 is ongoing.
  - Madagascar: published amount of COVID-19 committed spending was MGA1,906 billion (about US$500 million or 3.3 percent of GDP) as of March 8, 2021; as of May 20, 2022, published amount was MGA1,789 billion (about US$500 million, or 3.6 percent of GDP); COVID spending data for 2021 preliminary: domestically financed commitments so far account for 0.25 percent of GDP (MGA 137 billion), of which 0.04 percent of GDP was paid through the COVID-19 Response Fund.
  - Eswatini: NDMA received E353.5 million out of a total budget of E482.2 million as of August 31, 2021.
  - Ecuador: SERCOP webpage uploaded a total of 33,302 contracts, totaling over US$4 billion for January–December 2022; about ¼ of contracts contained partial and missing beneficial ownership information.
- Legislative and regulatory actions to enable publication:
  - Examples include procurement legislation amendments, circulars requiring beneficial ownership information, and production of e-procurement or transparency portals (examples preserved in country narratives such as Costa Rica, Comoros, Kenya, Kyrgyz Republic, Pakistan).

### Beneficial ownership disclosure — approaches and obstacles
- Common obstacles:
  - Procurement codes or regulations often did not initially require beneficial ownership disclosure (examples: Chad, DRC threshold, Kenya legal barrier).
  - Legal and operational barriers delayed publication; remedies included decrees, procurement regulation amendments, circulars, or new procurement laws.
- Implementation steps used:
  - Issuance of decrees/circulars (examples: Comoros circular November 2021; Costa Rica amendment published March 2022; Haiti decree November 2021).
  - Requiring bidders’ affidavits, registry filings, or registrar cooperation to collect beneficial ownership information (examples: PPCC actions, Business Registry cooperation).
- Timelines and thresholds explicitly cited:
  - DRC: US$12,000 threshold for contract publication; USD 1 million threshold for beneficial ownership disclosure.
  - Djibouti: US$100,000 threshold.
  - Liberia: US$200,000 (goods), US$400,000 (works), US$100,000 (services).

### Audits and ex-post validation — timing, scope, and findings
- Typical audit commitments:
  - Independent external/third-party audits with publication timelines ranging from six weeks after audit completion to nine months after fiscal year end; some commitments specified end-July 2021, end-September 2021, end-April 2022, end-June 2022.
- Examples of audit completion/publication status:
  - Chad: international accounting firm completed auditing in early February 2022; final report pending authorities’ review.
  - Comoros: independent audit commissioned December 2021; full report to be published within six weeks after audit completion.
  - DRC: Cour des Comptes audit sent to Parliament in October 2021 and published in November 2021.
  - Eswatini: SNG Grant Thornton audits published for NDMA and emergency spending; Auditor General launched compliance/procurement audit at NDMA.
  - Guinea: General Inspectorate of Finance finalized 16 audits; summary report published May 2022; Court of Accounts audit published August 2021.
  - Gambia: NAO first phase audit covering March–October 2020 published; second phase to be published end-September 2022.
  - Haiti: superior audit court (CSSC/CA) audit near finalization; final report expected soon.
- Audit findings and follow-up:
  - Some audits identified irregularities forwarded to prosecutors (example: Ecuador — approximately a third of audit reports presented irregularities and were forwarded to the Public Prosecutor’s Office).
  - Forensic and compliance audit findings have prompted parliamentary scrutiny or investigative action (examples: Kenya forensic audit, Gambia NAO phases).

### Budgeting, tracking, and reporting mechanisms
- Institutional arrangements and tracking actions:
  - Dedicated treasury accounts, special funds, or sub-accounts established to receive/disburse COVID-19 resources (examples: Chad dedicated treasury account; Guinea dedicated account at the central bank; Guinea-Bissau dedicated account at BCEAO; Gambia dedicated sub-account in TSA).
  - Labeling/tagging mechanisms in FMIS to track COVID-related expenditures implemented in several countries (examples: Kenya, Honduras).
  - Supplementary budget provisions and dedicated budget lines were used to cover COVID-related expenditures in many cases.
- Report cadence and publication:
  - Commitments and practices include monthly, quarterly, and semi-annual reporting; examples of publication cadences preserved in country entries (e.g., Guinea monthly reports through March 2021; Gambia MoFEA monthly reports).
- Selected specific financial figures and program amounts (preserved verbatim):
  - DRC: US$52 million identified as COVID-19-related spending; external donor commitments exceeding US$200 million and US$116 million executed by end-June 2021 (donor-financed); 36 COVID-19 related contracts over the US$12,000 limit totaling US$6.8 million.
  - Eswatini: NDMA received E353.5 million out of a total budget of E482.2 million as of August 31, 2021.
  - Ecuador: SERCOP webpage uploaded 33,302 contracts totaling over US$4 billion for January–December 2022; about ¼ of contracts contained partial and missing beneficial ownership information.
  - Gambia: 2022 budget includes about US$20 million partial on-lending of the special SDR allocation to finance COVID-19 related health spending.
  - Madagascar: COVID-19 Response Fund total budget MGA 265 billion (0.5 percent of GDP); COVID-19 committed spending reported MGA1,906 billion and MGA1,789 billion in different reports (about US$500 million).

### Implementation challenges and policy implications
- Legal and regulatory gaps:
  - Delayed beneficial ownership disclosure often traced to procurement codes not requiring such disclosures; remediation via decrees, procurement law amendments, and secondary legislation is common.
- Capacity and operational constraints:
  - Timely publication hampered by delayed submission of documents from spending agencies and limited audit institution capacity.
- Threshold-driven transparency gaps:
  - Publication thresholds (e.g., US$100,000, US$12,000, USD 1 million) create uneven transparency coverage; some countries proposed lowering thresholds.
- Audit publication delays:
  - Delays reflect internal review processes, judicial considerations during ongoing investigations, and capacity constraints at auditing institutions.
- Integration into regular PFM:
  - Integrating COVID-19 expenditures into regular budget processes and FMIS tagging/labeling facilitates oversight and ex-post audits.

### Key actionable measures reported by authorities (examples)
- Publish procurement contracts and procurement plans on government and specialized transparency portals.
- Require submission and publication of beneficial ownership information from bidders via affidavits, registry filings, or regulatory decrees (examples: Costa Rica amendment March 2022; Haiti decree November 2021; Jordan circulars).
- Commission external independent audits of COVID-19 spending with explicit publication timelines (examples: Guinea, Gabon, Comoros, Equatorial Guinea).
- Establish dedicated treasury/sub-accounts for COVID-19 funds and earmark expenditures in the budget (examples: Chad, Guinea, Guinea-Bissau, Gambia).
- Implement labeling/tagging mechanisms in FMIS to track pandemic-related spending (examples: Honduras, Kenya).

*Source: IMF — Implementation Status of Governance Commitments on Pandemic-Related Spending (May 2022).*

### 2. A compliance audit on  accounts related to FY19/20  of

### may22matrix-implementation-status-of-governance-commitments-on-pandemic-related-spending - 2. A compliance audit on  accounts related to FY19/20  of

### Compliance audits carried out and pending (Bangladesh)
- A compliance audit on accounts related to FY19/20 of quarantine expenditure for doctors and health workers engaged in the treatment of COVID patients was carried out in selected hospitals in Dhaka under the Health Services Division of the Ministry of Health and Family Welfare.
- A compliance audit related to FY19/20 with a special focus on COVID-related procurement was carried out in organizations concerned with the Bangladesh Army, Bangladesh Navy, Bangladesh Air Force, and Inter Forces under the Ministry of Defense.
- All three audit reports have been approved by the CAG and are in the process of being tabled in parliament through the president.
- Audit reports have been reviewed by both the Prime Minister and President’s offices and have been sent to the Finance Minister’s office.
- The Finance Minister’s office has proposed to table the health audit reports (as part of the compliance audit reports) during the June 9th session of parliament.
- As per procedure, once the audit reports are tabled and accepted in parliament, the reports will become a public document and be published on the CAG’s website.

### Barbados — procurement transparency, auditing, and fiscal rules
- Commitment: strengthen the efficiency and quality of the Government of Barbados (GOB) procurement process; strengthen effectiveness of the Public Accounts Committee; ensure full transparency including procurement contract information and beneficial ownership of contracting companies.
- Commitment detail: Barbados committed to table contracts exceeding BDOS 1 million in parliament effective March 2021.
- Legislative action: Updated procurement legislation was passed in December 2021 to promote integrity, fairness, transparency, and value for money in public procurement, providing a framework to facilitate the audit of crisis expenditures and publication of contracts and names of successful bidders.
- Audits: Authorities have confirmed that the Auditor General will audit pandemic-related spending, though the timing is unclear. The Auditor General’s 2020 Report does not reflect on COVID-related spending.
- Tracking: Separate sub-programs have been opened for COVID-related expenditure to assist in tracking these expenditures.
- Budgeting: Supplementary budget provisions were sought during 2020 and 2021 to cover COVID-related expenditures.
- Fiscal rule: Barbados implemented a procedural fiscal rule in December 2021 specifying hierarchical fiscal objectives, an accounting basis, monitoring bodies, and correction mechanisms; the legislation requires the Barbadian authorities to provide a budget in March and a fiscal framework publication in August of each fiscal year.

### Benin — publication of contracts, beneficial ownership, audits, and tracking
- Commitment: publish monthly procurement documents and key contract information relating to major projects under the response plan, indicating amounts and names of beneficial owners; entrust the Accounting Chamber (Cour des Comptes) with an audit to be published by end-June 2021.
- Procurement transparency: Authorities implemented commitments on procurement transparency, publishing the list of contracts awarded in the context of the fight against the pandemic (for procurement of FCFA 10 million and above) on the public procurement department website, including references of the contracts, validation of delivery, purpose, types and amounts of procurements, references of awarded companies (name, address, commercial register), and their beneficial owners.
- Beneficial ownership: Companies must provide detailed information on beneficial owner at the commercial register and tax administration; such information is collected by the procurement agency and published on its website. Failure to comply excludes companies from public procurement.
- Audits: Ongoing audits by the General Inspectorate of Finance, the Accounting Chamber, the Economic and Financial Unit, and reputable external auditors cover financial, compliance, and performance audits for all COVID-related spending; judicial audits operate when fraud is suspected.
- Accounting Chamber action: The Accounting Chamber is finalizing the audit of personal protective equipment spending in a cross-country regional initiative and has completed its audit of COVID-related spending, which was published.
- Reporting: Authorities periodically publish reports on pandemic-related expenditures; the latest publication is from end-September 2020; the Government also has weekly publications on its website.
- Tracking and budgeting: Benin adopted program-based budgeting; the COVID-19 response plan is included in programs supporting health policies, social protection, and aid for the economy; dedicated budget lines were created at the level of the general budget. COVID-19-related spending is reflected in the Amended Finance Law of 2020.
- Institutional innovation: With World Bank assistance, Benin set up a National Fund for Catastrophe Response (FONCAT). Decree of FONCAT and procedure manual are available online.

### Bolivia, Burkina Faso, Burundi — summary of commitments and implementation status
- Bolivia (RFI): Committed to adhere to best practices in procuring and awarding contracts related to the pandemic, including publishing procurement documentation, ex-post validation of delivery, names of awarded companies and beneficial owners, and publishing an external independent audit report on virus-related expenditures once the crisis is over. Status: Bolivia repurchased the RFI credit 10 months after its approval; funds were never deployed; consequently no action was taken on RFI commitments and no audit has been published.
- Burkina Faso (RCF/ECF): Commitments included transparency of COVID-19 resources, publication of contracts and ultimate beneficiaries, and audited reporting. Actions:
  - Circular issued on May 6, 2022 to identify ultimate beneficiaries for COVID-19 related contracts equal to or exceeding CFAF 10 million; publication of awarded contracts and beneficiaries followed.
  - Audits: First audited report of COVID-19-related spending up to end-June 2020 was shared with IMF staff in October 2020; audit covering expenditure until end-December 2020 was published in May 2021 by the Higher Authority of State and Control Against Corruption.
  - Budgeting: COVID-19-related expenditures were incorporated in the revised 2020 budget.
  - Tracking: Budget IT was complemented with a tracking system to enable tracking of COVID-19 expenditures.
  - Additional: A COVID-19 Economic Recovery Fund (FRE) was set up in the amount of FCFA 100 billion to support businesses in strongly affected sectors.
- Burundi (RCF): Commitments included semi-annual reports to the Court of Auditors, publication on Ministry website within three months after each semester, and collection of ultimate beneficiary ownership information starting end-December 2021.
  - Status:
    - Beneficial ownership: No beneficial ownership information has been published thus far.
    - Audits: Authorities prepared first report on use of COVID-19 funds in August 2021 and submitted it to the Court of Auditors, which started its audit in April 2022; no audit report has been published yet.
    - Reporting: First COVID-19 report (covering October 15, 2020 to August 10, 2021) was shared with staff but not published; the second report covering the second semester of 2021 was due by end-January 2022 and had not been shared with staff as of the update.
    - Other measures: A technical committee for the COVID-19 response and a single fiduciary fund with a related account at the Bank of the Republic of Burundi were established.

### Cabo Verde, Cameroon, Central African Republic — publication, audits, and reporting
- Cabo Verde (PCI):
  - Commitment: Execution of COVID-19 expenditures in line with transparency and accountability practices; tracked and published on the Ministry of Finance website; audited by the Tribunal of Accounts at the time of the 2020 budget audit.
  - Status: 2020 audited financial accounts, including COVID-related expenditures, were delivered to parliament; government continues to publish COVID-19-related expenditures on the Ministry of Finance’s website.
- Cameroon (RCF):
  - Commitments included strict application of budgetary procedures and controls, semi-annual reporting on COVID-19 spending, an independent audit of 2020 spending, and publication of procurement documents and beneficial ownership.
  - Actions and status:
    - Procurement: Authorities published backlog of all COVID-19-related contracts awarded since May 4, 2020 (including beneficial ownership) prior to the RCF-2 Board date; subsequently published contracts awarded from October 20, 2020 to end-December 2021, including names of companies’ beneficial owners.
    - Beneficial ownership: Circular issued in October 2020 requiring beneficial ownership information at time of bidding on COVID-19-related contracts; beneficial ownership of successful bidders is published at contract award.
    - Audits: Committed to an independent audit of COVID-19-related spending at end of fiscal year 2020 and to publish results. An audit prepared by the Audit Bench of the Supreme Court (Chambre des Comptes) was published on November 16, 2021.
    - Budgeting and reporting: A special COVID-19 account dedicated to financing the national response plan was created; the Revised Finance Law enacted in June 2020 allocates resources to the account, financed at 76 percent by resources released by debt service suspension and external budgetary support. A circular governs organization, operation, monitoring, and evaluation of the account and requires a consolidated report on expenses thirty days after the end of each semester. A report on COVID-19-related spending for March–December 2020 has been published.
- Central African Republic (RCF/ECF):
  - Commitments: Ensure effective use of additional external financing, undertake an independent audit of crisis-mitigation spending with published results, set up an inter-ministerial committee to monitor pandemic-related spending in real time, and publish tenders related to the spending.
  - Actions and status:
    - Procurement publication: On December 14, 2020 and 2021, authorities published lists of COVID-19-related procurement contracts approved each year; lists contain nine and six contracts approved in 2020 and 2021, respectively. For each contract the legal person awardee and the "name of the natural person who is the manager/signatory of the contract" are provided.
    - Audits: Authorities committed to an independent audit by the Court of Auditors of pandemic-related expenses incurred in 2020; the audit report covering budgetary expenditure finalized on August 31, 2021, is published. Audit of expenditure implemented directly by donors remains pending.
    - Reporting: Authorities publish data on COVID-19-related expenditures and related procurement contracts; a decree establishing the inter-ministerial committee provides for publication of tenders; the Minister of Finance must produce consolidated reports thirty days after each semester.

*Source: IMF — Implementation Status of Governance Commitments on Pandemic-Related Spending (May 2022), Section 2.*

### 1.  The Execution of Expenses to fight against COVID-19  over the

### may22matrix-implementation-status-of-governance-commitments-on-pandemic-related-spending - 1.  The Execution of Expenses to fight against COVID-19  over the

### Execution of Expenses to fight against COVID-19
- "The Execution of Expenses to fight against COVID-19  over the period from July 2020 to October 2021; the  reports are published here and here"

### Situation of Contracts relating to the Fight against Covid-19
- "The Situation of the Contracts relating to the Fight against Covid-19 is published here and here"

*may22matrix-implementation-status-of-governance-commitments-on-pandemic-related-spending*

### 3.   The name of the enterprises that in 2020  benefited from

### may22matrix-implementation-status-of-governance-commitments-on-pandemic-related-spending - 3.   The name of the enterprises that in 2020  benefited from

### Overview of recurring commitments
- Many countries committed to publish COVID-19-related procurement contracts and to disclose the names of awarded companies and their beneficial owners.
- Common complementary commitments included: quarterly or monthly reporting on COVID-19 spending; creating dedicated treasury or special accounts; conducting ex-post independent audits of COVID-19 spending; and publishing delivery/validation reports.
- Typical audit publication timing commitments cited:
  - within six months of the end of the fiscal year;
  - within nine months after the end of each relevant fiscal year;
  - specific deadlines such as end-July 2021, end-September 2021, end-April 2022, end-June 2022.

### Procurement contract publication: status and practices (selected country findings)
- Chad
  - Commitment: publish procurement contracts in full and include beneficial owners within 30 days of award.
  - Status: procurement contracts published on the Ministry of Finance and Budget website; could not publish beneficial owners because Procurement Code does not require it. Authorities plan a new regulation to collect this information.
  - Audit: international accounting firm completed auditing in early February 2022; final report to be published after authorities’ review.
  - Budgeting: dedicated treasury account opened; COVID-19 expenditures earmarked in the budget.
- Comoros
  - Commitment: publish documentation on large public procurement projects and ex-post validation, with names of awarded companies and beneficial owners.
  - Status: started publishing in July 2021 on the central bank website; documentation succinct and missing dates and ex-post validation.
  - Beneficial ownership: circular issued November 2021 requiring collection and publication for large contracts; publication to commence June 2022 (biannually for 2022, quarterly from March 2023).
  - Audit: independent audit commissioned to the Court of Auditors in December 2021; full report to be published within six weeks after audit completion.
- Costa Rica
  - Commitment: publish COVID-related procurement and beneficial ownership; launch revamped Transparency Portal by end-December 2021.
  - Status: Comptroller’s Office and Planning Ministry launched COVID-related Transparency Portals; data include vendors and, where required, beneficial owner information. New public procurement law (Law 9986) requires implementing regulations by November 2022; amendment enabling collection/publication of beneficial ownership published March 2022.
- Democratic Republic of Congo
  - Commitment: publish all COVID-19 procurement contracts exceeding US$12,000 and disclose beneficial ownership for contracts exceeding USD 1 million.
  - Status: identified 36 COVID-19-related contracts over US$12,000 totaling US$6.8 million; one contract above one million published without beneficial owner. IMF TA requested to lower the US$1 million threshold.
- Djibouti
  - Commitment: publish contracts in excess of US$100,000 and beneficial ownership.
  - Status: no publications because contracts fell below US$100,000 threshold; external audit TOR prepared; audit expected and publication planned in 2022.
- Egypt
  - Commitment: publish crisis-related spending and procurement contracts, including beneficial ownership in accordance with law; State Audit Authority audit of crisis spending.
  - Status: detailed procurement information published up to February 2021; legal ownership information published for contracts awarded after January 1, 2021 until May 2021; executive regulation adjusted to allow collection/publication of beneficial ownership.
  - Audit: summary of financial audit by Accountability State Authority covering March 2020–May 2021 published (summary does not cover ex-post validation of delivery).
- Eswatini
  - Commitment: publish contracts and beneficial ownership and ex-post validation; Auditor General to undertake financial and compliance audit and publish within six months from end of 2020/21 fiscal year.
  - Status: ESPPRA published tables summarizing procurement contracts with awarded companies’ names and directors; signed contracts, beneficial owners, and ex-post validation not yet provided. SNG Grant Thornton audits published for NDMA and emergency spending.
  - Budgeting: NDMA received E353.5 million out of a total budget of E482.2 million as of August 31, 2021.
- Guinea
  - Commitment: publish monthly execution reports, publish awarded procurement contracts including beneficial owners, and have Court of Accounts audit and publish by June 2021.
  - Status: contracts and beneficiaries published; General Inspectorate of Finance finalized 16 audits and summary report published in May 2022; Court of Accounts audit published August 2021.
  - Reporting: monthly COVID-related spending reports available through March 2021 on MEF website.
- Kenya
  - Commitment: publish comprehensive tender award information including beneficial ownership and require publication in line with open contracting standards.
  - Status: Public Procurement Information Portal launched July 2018; procurement-related information must be published in line with open contracting standards. Beneficial ownership publication delayed by legal barrier addressed April 8, 2022; revised standard tender documents effective April 21, 2022 require beneficial owners’ consent and enable future publication.
  - Audits: Auditor General published comprehensive audit of COVID-related spending for March 13–July 31, 2020 in April 2021; a forensic audit covering March 31–July 31, 2020 (KEMSA) presented to parliament in September 2020.

### Beneficial ownership disclosure: approaches, obstacles, and timelines
- Common legal/operational obstacles:
  - Procurement codes or regulations often did not initially require beneficial ownership disclosure (e.g., Chad, DRC threshold, Kenya legal barrier).
  - Some countries required bidder affidavits or registrar filings as interim or permanent measures (e.g., Costa Rica amendment March 2022, Jamaica Cabinet Decision No. 26/20, Jordan circulars).
- Notable timelines and quantitative thresholds:
  - DRC: publish procurement contracts exceeding US$12,000; disclose beneficial ownership for contracts exceeding USD 1 million.
  - Djibouti: publication threshold set at US$100,000 (no contracts exceeded threshold).
  - Georgia-style examples not present in supplied content; only the above country-specific thresholds and dates were supplied.
- Implementation steps reported:
  - Issuance of decrees, circulars, or procurement regulation amendments (examples: Comoros circular November 2021; Costa Rica amendment published March 2022; Haiti decree November 2021; Equatorial Guinea decree for beneficial ownership).
  - Development of technical assistance roadmaps and IMF/TA support to draft regulations and implement publication platforms.

### Audits and ex-post validation: status and findings
- Audit commissioning and publication practices:
  - Many countries committed to independent external/third-party audits with publication commitments ranging from six weeks after audit completion to nine months after the end of the fiscal year.
  - Examples of audit completion/publication status:
    - Chad: international accounting firm completed audit in early February 2022; final report pending authorities’ review.
    - Comoros: audit commissioned to Court of Auditors in December 2021; committed to publish full report within six weeks after audit completion.
    - Dominican Republic: Chamber of Accounts began COVID-spending audits in 2021Q4; audits underway with final reports to be published on dedicated website.
    - DRC: Cour des Comptes audit sent to Parliament in October 2021 and published in November 2021.
    - Eswatini: two SNG Grant Thornton audits covering NDMA and emergency spending published; Auditor General launched compliance/procurement audit at NDMA.
    - Guinea: General Inspectorate of Finance finalized 16 audits; summary report published May 2022; Court of Accounts audit published August 2021.
    - Gambia: NAO first phase audit covering March–October 2020 published; second phase to be published end-September 2022.
    - Haiti: superior audit court (CSSC/CA) audit near finalization; final report expected soon.
- Audit findings and follow-up:
  - Some audit reports identified irregularities and forwarded findings to prosecutors (e.g., Ecuador: approximately a third of audit reports presented irregularities and were forwarded to the Public Prosecutor’s Office).
  - Parliamentary and investigation agency follow-ups were initiated in several cases (e.g., Kenya forensic audit findings led to parliamentary and investigative actions).

### Budgeting, tracking, and reporting mechanisms
- Typical institutional arrangements and actions taken:
  - Dedicated treasury accounts or special funds established to receive and disburse COVID-19 resources (e.g., Chad dedicated treasury account; Guinea dedicated account at the central bank; Guinea-Bissau dedicated account at BCEAO; Gambia dedicated sub-account in TSA).
  - Supplementary budgets and budget lines:
    - Gabon: special allocation documented in the supplementary budget (program 30) for FY20; separate budget line for health expenses related to COVID-19 in 2021 Budget Law.
    - Kenya: labeling mechanism to tag COVID-related expenditures in FMIS; became fully operational for execution of 2021 budget.
    - Honduras: labeling mechanism implemented to categorize and track pandemic-related expenditure; manual of procedures for emergency purchases introduced.
  - Reporting cadence:
    - Commitments to publish quarterly or monthly reports; many countries published monthly or quarterly execution reports (examples: Gambia MoFEA monthly reports; Guinea monthly reports; Eswatini financial reports for several months published).
- Specific budget figures and financial data (as reported)
  - DRC: US$52 million identified as COVID-19-related spending; external donor commitments exceeding US$200 million and US$116 million executed by end-June 2021 (donor-financed); 36 COVID-19 related contracts over the US$12,000 limit totaling US$6.8 million.
  - Eswatini: NDMA received E353.5 million out of a total budget of E482.2 million as of August 31, 2021.
  - Ecuador: SERCOP webpage uploaded a total of 33,302 contracts, totaling over US$4 billion for January–December 2022; about ¼ of contracts contained partial and missing beneficial ownership information.
  - Gambia: 2022 budget includes about US$20 million partial on-lending of the special SDR allocation to finance COVID-19 related health spending.

### Implementation challenges and policy implications (synthesized from country statuses)
- Legal and regulatory gaps often delay beneficial ownership disclosure; remedy paths include issuing decrees, amending procurement codes, or passing new procurement laws with implementing regulations.
- Capacity constraints hinder timely publication and completeness of procurement documentation; IMF technical assistance and capacity development have been used to prepare circulars, decrees, and implement portals.
- Thresholds for mandatory publication (e.g., US$100,000, US$12,000, USD 1 million) create uneven transparency coverage and motivate proposals to lower thresholds over time.
- Audit publication delays frequently reflect internal review processes, judicial considerations when investigations are ongoing, or capacity constraints at audit institutions.
- Integrating COVID-19 expenditures into regular budget processes and FMIS tagging/labeling facilitates longer-term oversight and ex-post audits.

### Key actionable measures reported by authorities (examples of commitments and reforms)
- Publish procurement contracts and procurement plans on government portals and specialized transparency portals (several countries implemented or revamped portals).
- Require submission and publication of beneficial ownership information from bidders via affidavits, registry filings, or regulatory decrees (examples: Costa Rica amendment March 2022; Haiti decree November 2021; Jordan circulars).
- Commission external independent audits of COVID-19 spending with specific publication timelines (examples: Guinea, Gabon, Comoros, Equatorial Guinea).
- Establish dedicated treasury/sub-accounts for COVID-19 funds and earmark expenditures in the budget (examples: Chad, Guinea, Guinea-Bissau, Gambia).
- Implement labeling/tagging mechanisms in FMIS to track pandemic-related spending (examples: Honduras, Kenya).

*Source: IMF matrix on implementation status of governance commitments on pandemic-related spending (selected country commitments and status entries).*

### 2021.  Moreover,  the  auditor general’s report of the  2020  budget

### may22matrix-implementation-status-of-governance-commitments-on-pandemic-related-spending - 2021.  Moreover,  the  auditor general’s report of the  2020  budget

### Transparency and procurement reforms
- Amendments to the procurement law enacted in January 2021 require publication of all bidding documents at the official portal of public procurement of the Kyrgyz Republic.
- Subsequent changes to the amendments excluded SOEs from the coverage of the law; authorities are developing secondary legislation for SOE procurement to follow similar principles as the main law.
- The amended Article 51(7) of the procurement law requires procuring organizations to post the implementation status of procurement contracts on the public procurement web portal in a timely manner; the relevant module has not been put in place yet because of lack of technical and financial resources.
- The amendments to the public procurement legislation increased the number of procuring organizations subject to the law.

### Beneficial ownership disclosure and publication
- The new procurement legislation now requires disclosure of information on beneficial owners for all procurement contracts (not only pandemic-related spending) as a permanent reform.
- Work is ongoing on the software to implement the systematic publication of beneficial ownership information of contractors, suppliers, and consultants.
- Commitments included publishing ex-post validation of delivery along with the name of awarded companies and their beneficial owner(s) for all public procurement contracts.

### Audits, validation of delivery, and reporting
- The State Chamber of Audits conducted audits of all public procurement contracts for 2020 in March 2021 and published the report in November 2021, including a separate section on COVID-19 emergency spending; the report was formally submitted to Parliament and is available online.
- The Kyrgyz commitment: subject procurement of urgently needed medical supplies to an ex-post audit by the Audit Chamber, with results to be published on the website of the Ministry of Finance.
- Authorities plan to publish documentation on all direct procurement and bidding documents for competitive procurement, including those of state-owned enterprises and joint stock companies with state shares of more than 50 percent and their subsidiaries, on the Public Procurement portal.
- The authorities are adding complaints filing to the list of paid services offered on the procurement portal; related documentation is at the approval stage.

### Country-specific commitments and implementation status

- Kyrgyz Republic
  - RFI/RCF first request commitment: 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.
  - Additional commitments in the second request: publish documentation on all direct procurement and bidding documents for competitive procurement; publish ex-post validation of delivery and names and beneficial owners of awarded companies; ensure Independent Complaints Review Commission on procurement has sufficient means by including its fees on the list of government payable services.
  - Implementation notes: procurement law amendments enacted January 2021; exclusion of SOEs in subsequent changes; secondary legislation for SOE procurement under development; Article 51(7) requires posting implementation status but portal module not yet implemented due to resource constraints; State Chamber of Audits audit of 2020 procurement conducted March 2021 and published November 2021.

- Lesotho
  - Commitments: (i) publish quarterly reports on budget implementation, including specific budget lines accounting of expenditures for COVID-mitigation measures; (ii) have internal audit on a quarterly basis focusing on COVID-related expenditure; (iii) a full audit by the Auditor General of the revised FY2020/21 budget, including a targeted audit of covid-19 related expenditure, with results to be published and disseminated within 5 months after the end of the fiscal year; (iv) publish, on the government’s website, signed procurement contracts for crisis-mitigation spending, the names of the companies awarded these contracts and their beneficial owners, and ex-post validation of delivery.
  - Implementation notes: COVID-19-related procurement contracts from a subset of Ministries, Departments, and Agencies have been published; enforcing online submission requires enactment of the PFMA and Procurement Bills; a financial audit for FY20/21 by the Ministry of Finance has been published; internal audit of COVID-related spending for FY20/21 Q1-Q2 near completion with work on the last two quarters ongoing; a full audit by the Auditor General of the revised FY20/21 budget is ready but the Office of the Auditor General is awaiting funding to print the report for parliament's approval for publication, which is expected by end-May 2022.
  - Reporting: Quarterly Mitigation Report shows expenditure related to COVID-19 and budget implementation; quarterly reports published online for FY20/21 Q1-Q2; budget documents and budget implementation posted online; spending on (i) social protection measures and (ii) COVID-related spending by quarter available online.
  - Legislative status: Anti-Corruption Bill will be revised as part of the Omnibus Bill; PFM Bill undergoing stakeholder consultations with no available timeline; Procurement Bill has been submitted to parliament.

- Liberia
  - RCF commitment: General Audit Commission to conduct a post-crisis audit of all crisis response spending within a year of the approval of the RCF disbursement; publish the results online within two weeks of finalization; publish on the government’s website all procurement contracts paid from the budget in the remainder of FY2020 and all of FY2021 above specified thresholds, along with names of companies awarded the contract, their beneficial owners, and validation of delivery.
  - Specified publication thresholds: above US$200,000 for goods, above US$400,000 for works, and above US$100,000 for services.
  - Implementation notes: The Public Procurement & Concession Commission (PPCC) has published approved pandemic-related procurement plans; full text of procurement contracts along with key information on winning companies and their legal owner for FY19/20 above the specified thresholds have been published on the PPCC’s website; publication of contracts for FY20/21 is ongoing.
  - ECF reviews: To enable greater disclosure and transparency, publication on the PPCC website of all information on procurement contract awards started in March.

*Source: may22matrix-implementation-status-of-governance-commitments-on-pandemic-related-spending - 2021.  Moreover,  the  auditor general’s report of the  2020  budget (IMF).*

### 2020.  We have  set up a team of audit experts and

### may22matrix-implementation-status-of-governance-commitments-on-pandemic-related-spending - 2020

### Procurement transparency and e-procurement systems
- The PPCC will require MACs to publish on the PPCC’s website all relevant information on their procurement activities (from planning to awards).
- The PPCC changed its data collection template to include beneficial ownership of contract awardees for publication on the PPCC website.
- The PPCC will set up a reliable and comprehensive procurement database as the first step of an e-procurement system to systematically collect, maintain, and publish public procurement information for monitoring procuring entities’ efficiency and compliance with the legal framework.
- The authorities are working to publish on the PPCC’s website procurement contracts paid from the budget above:
  - US$200,000 for goods,
  - US$400,000 for works,
  - US$100,000 for services.
- The PPCC expects to have published information for 75 percent of the FY20 contracts by end-January 2021.
- Timely publication is often hampered by long delays in submission of required documentation by spending agencies.
- The government launched an Electronic Document Management System in FY21 to help ensure better-quality reports for FY21.

### Beneficial ownership disclosure measures
- The PPCC committed to collect and publish beneficial ownership information from firms bidding on public procurement contracts and to provide beneficial ownership information on past contracts to the extent feasible.
- Actions taken by the PPCC:
  - Sent the list of entities awarded contracts to the Business Registry; the Business Registry will return the file with an additional column including the beneficial owners of the businesses.
  - Asked all businesses in the vendor registry to update existing information to provide beneficial ownership information.
  - Plans to send a circular to all procurement entities asking them to submit a notarized document providing beneficial ownership information of winning businesses when they submit their contracts.
- The Ministry of Economy and Finance published for direct award contracts the tax identification number and trade register number of beneficiaries; as of May 20, 2022, links to contracts for 99 contracts had been posted and 93 ex-post delivery reports (“Procès verbaux de reception”) had been posted.
- For Madagascar, as of March 8, 2021:
  - Published amount of COVID-19 committed spending was MGA1,906 billion (about US$500 million or 3.3 percent of GDP), of which more than 90 percent has been either paid or given the order to be paid.
  - As of May 20, 2022, published amount of COVID-19 committed spending was MGA1,789 billion (about US$500 million, or 3.6 percent of GDP), of which more than 90 percent has been either paid or given the order to be paid.
  - COVID spending data for 2021 is preliminary: domestically financed commitments so far account for 0.25 percent of GDP (MGA 137 billion), of which 0.04 percent of GDP was paid through the COVID-19 Response Fund.
  - The COVID-19 Response Fund was created in July 2020, operationalized in April 2021, with a total budget of MGA 265 billion (0.5 percent of GDP).

### Audits and independent reviews
- The General Audit Commission (supreme audit institution) financial audits of FY20 pandemic-related spending are near completion; the FY21 audit is scheduled to follow in the same year.
- The administration will collaborate with the General Audit Commission to ensure the audit for FY2020 budget execution is conducted timely and reported to the Legislature by end-February 2021; the GAC is expected to conclude the audit by end-February 2021 and submit to the Legislature by end-March 2021.
- The authorities committed to commission an independent third-party audit of COVID-19 contracts to be published on-line by end-December 2021 (Madagascar commitment).
- The National Audit Office (Malawi) submitted an audit report for MWK 6.2 billion completed in March 2021 and made public in April 2021; audits for two other tranches are underway.
- The Office of the Auditor General (Myanmar) audited FY19/20; the audit report was published on June 25, 2021 (local language only) after delays due to political turmoil.
- The National Audit Office (Mongolia) completed an audit on COVID-19 expenditure for 2020, including beneficial owners of procurement contracts and an ex-post validation of delivery; the audit was published on the Ministry of Finance’s website in October 2021, with some missing beneficial owner information being pursued.
- The Tribunal Administrativo (Mozambique) completed an independent audit of COVID spending published in April 2022.
- The Office of the Auditor General (Mali, BVG) published an independent audit of COVID-related spending in September 2021 identifying administrative and financial irregularities.
- Mauritania’s Court of Accounts published the 2020 audit of pandemic-related spending in March 2022 and the 2021 audit in May 2022; the government’s inspectorate general audited all contracts awarded by the special fund.
- Montenegro’s State Audit Institution completed and published:
  - A financial and regularity audit “Verification of the healthcare costs related to COVID-19” in December 2021.
  - A performance audit “Efficiency of grant management for coronavirus control” published on March 3, 2022; it found that while funds were spent according to crisis needs, management of donations was not sufficiently efficient.
- Mozambique’s supreme audit institution completed an independent audit (Tribunal Administrativo) published in April 2022.

### Reporting, publication of contract texts and ex-post delivery validation
- The PPCC plans to publish procurement contracts and the names of awarded companies and their beneficial owners for contracts above specified dollar thresholds and expects publication progress for FY20 contracts as noted above.
- The authorities acknowledge long delays in submission of documentation by spending agencies as a constraint to timely publication.
- The PPPC will ensure adequate funding to implement the described reforms.
- Madagascar:
  - Posted details about competitively concluded 2020 contracts on ARMP website; as of March 8, links to contracts for 109 of 127 contracts had been posted; 32 ex-post delivery reports had been posted; remaining ex-post delivery reports for fully executed contracts were to be published by June 2021.
  - Pledged to publish budget execution reports quarterly with specific pandemic-related spending information.
- Malawi:
  - Publication of public procurement details can be found on the PPDA website, although not updated with 2021 data.
  - Beneficial ownership information was collected and published only for a subset of contracts and updates are mostly only up to 2021 Q1.
  - Quarterly statements and reports on COVID-19 related spending across all MDAs have been produced and published for FY19/20 and FY20/21, but with significant delay; the National Audit Office will submit quarterly audits within 180 days after the end of each quarter, and a comprehensive audit within 180 days after the end of the pandemic.
- Moldova:
  - All contracting authorities must submit procurement contract information except for small-value contracts (goods and services under MDL 200,000 or works under MDL 250,000); data on 2,191 contracts amounting to MDL 582.3 million have been published.
  - A new requirement to provide beneficial owner information in all public procurement conducted through the Public Procurement Agency took effect in September 2020 (Order 146/2020).
- Mongolia:
  - As stipulated by the Glass Account Law (2014), government entities report expenditures and procurement above MNT5 million (excluding wages); MOF published full texts of procurement contracts by key COVID-19 spending agencies including awarded companies and their beneficial owners.
- Myanmar:
  - Published key information on large contracts above MMK100 million, including price per unit and overall contract amount; ex-post validation of delivery is also published.
- Mauritania:
  - Since June 2020 the Ministry of Finance published eleven bimonthly reports on the execution of the special social solidarity and pandemic response fund; reports progressively added information (nature of goods, contract amounts, source of financing, payment modalities, status of delivery, list of awarded companies, legal owners, shareholders with tax and national identification numbers).
  - Certificates of delivery have not been published, though status of delivery is provided.
- Mozambique:
  - Some large public procurement contracts related to crisis mitigation have been published including awarded company names and partial beneficial owner information; the Ministry of Finance is reviewing procurement processes including ex-post validation of delivery.
- Maldives:
  - Ministry of Finance published weekly/quarterly reports since May 2020; as of end-October 2021 the report is published on a quarterly basis and includes number of beneficiaries and amounts disbursed under support schemes; the weekly fiscal report continues to be published every Tuesday.

### Other governance and PFM measures
- The authorities increased the scope of public expenditure processed through the Integrated Financial Management Information System.
- Authorities moved from annual to quarterly expenditure reconciliation.
- Summary fiscal reports were posted on the Ministry of Finance and Development Planning’s website from June 2020.
- The PPPC continues compliance monitoring visitations; since January 2021, 21 compliance audits including on procurement procedures have been completed.
- Maldives conducted a Fiscal Transparency Evaluation with IMF Fiscal Affairs Department in December 2020; authorities committed to implementing FTE recommendations and published a Fiscal Risk Statement.
- Mozambique implemented reforms from the August 2019 governance diagnostic report, including:
  - Adoption of a revised banking law published December 31, 2020.
  - Continued publication of annual fiscal risk statements and an updated Fiscal Transparency Evaluation integrated into the revised PFM strategy.
  - Revision of the Public Probity law and preparation of written procedures for investigating and prosecuting corruption cases involving the Anti-corruption Cabinet (GCCC) and SERNIC.
  - Progress toward a new comprehensive PFM law (SISTAFE) establishing the expenditure chain.
- Mauritania created a national committee for monitoring the Solidarity Fund and COVID-19 expenditure chaired by the Minister of Finance with 20 members representing Parliament, opposition, councils, civil society, and partners; the committee has met six times and regularly briefs the public.
- Mauritania incorporated beneficial ownership transparency requirements into the draft implementing regulation of the revised public procurement code expected to be approved later in the year.

*Source: IMF — Implementation Status of Governance Commitments on Pandemic-Related Spending (excerpts).*

### 2021.  We will also publish online, on the website of

### may22matrix-implementation-status-of-governance-commitments-on-pandemic-related-spending - 2021

### Procurement contract information and beneficial ownership
- Namibia: The Ministry of Finance publishes all procurement contracts at https://mof.gov.na/tender-awards. The beneficial ownership information has not yet been published.
- Nepal: Procurement contract information is published as per the Public Procurement Act. The Ministry of Finance issued a public information notice to collect and publish beneficial ownership for all new COVID19-related contracts in the health sector as of December 9, 2021. The Ministry of Health and Population has begun publishing large public procurement documentation, ex-post validation of delivery, name of awarded companies, and name of beneficial owner(s) for all new COVID-19 related contracts as of December 9, 2021.
- Nicaragua: Publication of all COVID-related public procurement contracts commenced on October 15, 2020. As of January 31, 2022, 155 contracts have been published, for a total amount of C$595,208,660.84 and US$179,664,831.58, of which 100 percent are completed.
- Niger: Government publishes data on larger contracts (over 0.5 million CFA) including names of companies and company representative. A regulation requires beneficial ownership information for companies submitting bids for all COVID-19-related public procurement, with publication on the Public Procurement Portal; March 2022 regulation extended requirement to companies awarded non-competitive contracts.
- Nigeria: Pandemic-related procurement contracts are published according to specific guidelines. Procurement contracts above N5 Million are published on the Ministry of Finance’s portal (access remains uneven). The Corporate Registry started to publish the list of Persons with Significant Control since January 2021.
- Pakistan: Authorities publish key information of all COVID-related awarded procurement contracts on the Public Procurement Regulatory Authority website. Issuance of regulations to require collection for publication of beneficial ownership information from companies awarded public procurement contracts of PRs 50 million and above was an end-March 2022 structural benchmark; the PPRA Board approved and published the relevant regulations in May 2022.
- Papua New Guinea: COVID-related contracts and beneficial ownership information for March 13–July 21, 2020 are posted on the procurement website; nothing more recent.
- Paraguay: No procurement-specific publication actions noted in the RFI summary.
- Rwanda: Authorities continue to make information publicly available on all government contracts through their online e-procurement system, including COVID-19 related tenders.
- Samoa: Contracts approved and awarded during the State of Emergency period are publicized on the Ministry of Finance’s website. Tender awards valued at SAT $100,000 and above are published on the Ministry of Finance’s website, including full name of successful supplier/contractor/consultant, total awarded contract price, and full names of all bidders.
- Sao Tome and Principe: Publication of some procurement contracts started in Q3 2020; prior action on publication of a full set of information for June–August 2020 was met in January 2021. Publication of contracts and related documents in 2021 is irregular; continuous structural benchmarks on transparency of procurement information are not met.
- Senegal: For food aid procurement, orders and results were published; medical equipment single-source procurement exemption was repealed on September 16, 2020, after which COVID-19 spending is subject to regular public procurement code.
- Seychelles: No specific procurement publication details beyond commitment to transparency.
- Sierra Leone: By mid-February 2022, details of all large emergency public procurement contracts through September 2021 were published on the National Public Procurement Authority website, including contract value, method of procurement, contracting entities, awarded companies, and their beneficial owners. Contracts after September 2021 have not been published.
- Solomon Islands: Documentation on pandemic-related public procurement has not yet been published to staff’s knowledge.
- South Africa: National Treasury created a dashboard to publish procurement contract information and allocations at http://ocpo.treasury.gov.za/COVID19/Pages/Reporting-Dashboard.aspx, updated on a weekly basis; some government departments are not reporting COVID19-related procurement to National Treasury. Names of awarded companies and names of their directors (rather than beneficial owners) are listed.
- South Sudan: RCF disbursements were used mainly to clear wage and salary arrears; purchases requiring publication of procurement contracts and beneficial ownership have been minor so far.
- St. Vincent & the Grenadines: Information on awarded procurement contracts is published at http://finance.gov.vc/finance/index.php/publications-and-reports. Information on beneficial owners of companies contracting with government is published; Attorney General confirmed no legal impediment to publication (June 2021).
- Tajikistan: Authorities committed to improving transparency of procurement processes; work on procurement law reform and e-procurement integration ongoing.
- Tanzania: Beneficial ownership information for COVID-related procurement contracts is published at the Ministry of Finance and Planning; procurement contracts are published on the Ministry website.
- Tonga: Authorities have yet to publish procurement contracts and beneficial ownership as committed; procurement website contains bidding opportunities and quarterly procurement statistics.
- Tunisia: Current regulations require publication of all government procurement contracts on a dedicated government website; authorities plan to recast the website and make it more accessible and include beneficial ownership and delivery validation.
- Uganda: Authorities published procurement contract summaries on COVID-19 expenditures in June 2021 that did not include beneficial ownership. A circular and collection template for beneficial ownership were adopted; publication of beneficial ownership information for COVID-19 related procurement started with contracts of January 2022 as a prior action for the First Review of the ECF. Authorities decided to collect beneficial ownership for all procurement, publication currently covers COVID19-related contracts.
- Ukraine: Procuring entities publish procurement information in the electronic procurement system; procurement legal framework amended to require collection and publication of beneficial ownership but this information is not yet published on procurement website.
- Uzbekistan: Information on procurement contracts funded by the Anti-Crisis Fund has been published by the Ministry of Finance. The procurement contract information includes beneficial owners of contracting companies. An online public procurement portal and publicly accessible platform mandatory for all public procurement was set up with EBRD assistance.

### Audits (ex-post, special, and external audit actions)
- Namibia: Auditor General published a special report on “Response to COVID-19 by the Government of the Republic on Namibia” for FY20/21, identified irregularities and recommended corrective actions. The RFI commitment on this is fully met.
- Nepal: The Office of the Auditor General published the latest OAG report for FY19/20 in August 2021. A “Special Audit Report on Management of COVID-19, 2021” was published. The annual audit of FY20/21 government spending is expected in CY22; no further action needed to meet audit-related RCF commitment.
- Nicaragua: UNOPS will use US$250,000 from RCF/RFI resources for an external audit of all COVID19-related expenditures covering April 1, 2020 through May 31, 2021; the external audit is expected to be published within two weeks of finalization. A second audit is planned to cover the period after May 31, 2021.
- Niger: Two audit reports on 2020 COVID-19-related public spending and tax exemptions in the extractive sector covering 2017-2020 were completed and published in April 2022 by the Auditor General as part of ECF structural benchmarks.
- Nigeria: The Office of the Accountant General has commissioned an audit unit for financial audit of COVID-19 spending; the Auditor General’s office is conducting audits across procurement agencies—first audit recently conducted and report being drafted. A single national audit report is deemed infeasible due to decentralized auditing authority.
- Pakistan: Auditor General of Pakistan conducted an ex-post audit of procurement of COVID-related supplies and social payments during FY20; the audit was published on November 19, 2021. AGP submitted annual audit reports for FY21 (including COVID-related spending) to procuring agencies in February 2022; these reports are expected to be submitted and laid before the national assembly by end-July 2022.
- Papua New Guinea: An internal audit of COVID-19 procurement has been commissioned; no information yet available about an independent audit or its publication.
- Rwanda: Auditor General published, at end-April 2021, an audit of all government expenditures and procurement tenders for FY19/20 including pandemic-linked spending. Audits of COVID-19 related spending for FY20/21 were expected to be published by end-May 2022 as part of the annual independent audit.
- Samoa: Pre-audit function conducted by the supreme audit institution for government spending; real-time audits on procurements conducted. Pandemic-related Public Accounts FY19/20 and FY20/21 have been audited and published.
- Sao Tome and Principe: Tribunal de Contas performed an ex-post audit of the Emergency Fund during 2020; audit report was expected to be finalized by end-October 2021 and to be public in first part of 2022. Auditor General audit of 2020 COVID-19-related spending package was expected to be finalized by end-October 2021; so far no audit report has been published but expected in early 2022.
- Senegal: ARMP carried out an audit of 95 percent of COVID-related government contracts; report was published in December 2021. The Fonds Force COVID-19 Committee carried out an 11-month audit; report available online. A special audit report by Cour des comptes on execution of COVID-19 related expenditures was being finalized and publication expected in July (period extended to first quarter 2021).
- Seychelles: Audit of emergency spending by the Auditor General was initially planned to be published in September 2021 but delayed due to staffing shortages related to COVID.
- Sierra Leone: Audit Service Sierra Leone (ASSL) conducted a real-time compliance audit for March–Dec 2020 and a financial audit for July–December 2020; the ASSL published the first audit report. Annual audit of government accounts for FY20 was published in December 2021. ASSL published unaudited NaCOVERC financial statements as of December 31, 2020 and later published NaCOVERC’s operations unaudited reports for 2021Q2.
- Solomon Islands: Audit of COVID-19 related expenditures by the Office of the Auditor General is being prioritized and should be completed in 2022; no audit report published yet.
- South Africa: Auditor General published three special audit reports on the COVID-19 relief package in September 2020, December 2020 and June 2021.
- South Sudan: Auditor General completed and published the audit of the spending of the RCF1 disbursement in September 2021 (Statement of the AG and the Consolidated Report). The audit suggests up to US$16 million out of the US$52 million disbursed may not have been in compliance with the intended purpose. AG’s office was to complete an audit of RCF2 spending by end-2021; process delayed and expected to be completed in June 2022.
- St. Vincent & the Grenadines: Authorities committed to undertaking a full ex-post financial and operational audit of COVID-19 spending at the time of the annual audit, but completing and publishing the full ex-post audit could take years due to backlog.
- Tajikistan: Chamber of Accounts conducted an ex-post audit on COVID-related spending (March 31, 2021).
- Tanzania: Controller and Auditor General audit on CCRT spending has been completed and is expected to be published by end-May 2022. Authorities committed to completing and publishing a post-crisis audit of pandemic-related spending by December 2022.
- Tonga: An audit of COVID-19 related expenditures by the Audit Department was committed within 9–12 months; as of the report no audit published.
- Tunisia: Cour des Comptes has started an audit of COVID-related spending; staff recommended a comprehensive ex-post audit 6–12 months after fiscal year end and publication online.
- Uganda: Supreme audit institution published an audit of COVID-19 expenditures for FY19-20 on March 26, 2021. A special audit covering FY20/21 was finalized, discussed in parliament in January 2022 and published (link provided in source).
- Ukraine: State Audit Service completed the audit within MEFP deadlines by end-March 2021 and it is publicly accessible; Accounting Chamber prepared and published its report. A report on use of COVID Fund resources by program and economic classification was prepared within 30 days of Fund closure and published on Ministry of Finance website.
- Uzbekistan: Chamber of Accounts completed its regular audit of government accounts including an examination of anti-crisis spending; audit report was published in September 2021.

### Budgeting and tracking of COVID-related expenditures
- Namibia: All COVID-related expenditures are incorporated in the FY21/22 budget. COVID-related spending was augmented during the mid-year budget review to address the impact of COVID’s third wave. Auditor General to conduct independent audit within 12 months of end of FY20/21.
- Nepal: Aggregate spending from the COVID-19 Fund is being published. CARES reports (final CARES report published in April 2022) detail response measures and expenditure. COVID-related spending authorized through budgetary process and dedicated funds such as the COVID-19 Fund.
- Nicaragua: Compilation and publication of public finance and external debt statistics transferred from the Central Bank to the Ministry of Finance in 2021; monthly fiscal statistics and quarterly reports published on Ministry of Finance website.
- Niger: All spending appears integrated into the budget; some measures coordinated directly by other ministries with ex-post costing imposed on Ministry of Finance. New law on asset declarations extended coverage to 2000 high-ranking public officials (from 50); only the President’s declaration is up-to-date and published in detail.
- Nigeria: Specific budget lines were created for tracking emergency response expenditures in 2020 but have not been used subsequently.
- Pakistan: Enacted emergency measures are to remain targeted and temporary; an e-procurement system piloted end-July 2022 with World Bank support; full roll-out expected by next fiscal year.
- Papua New Guinea: COVID-19 expenditure reports are presented to Budget Management Committee on weekly basis; first report circulated on May 18 (prior action). Consolidated report to be submitted to National Executive Council and published within three months of end of emergency (timing unclear due to ongoing local outbreaks).
- Rwanda: E-Procurement system provides publicly available information; FY19/20 Auditor General Report includes pandemic-linked expenditures; FY20/21 audit expected by end-May 2022.
- Samoa: Pandemic-related spending regulated under Public Finance Management Act 2001; pandemic-related spending of FY19/20 and FY20/21 part of Government Public Accounts and audited/published.
- Sao Tome and Principe: Monthly COVID-related expenditure reports published up to August 2020; authorities continue to publish monthly reports with some delays. Procurements integration challenges; working with World Bank on procurement system to integrate ministries, COSSIL, Court of Accounts and Budget Directorate.
- Senegal: COVID-19 spending envelope spelled out in Economic and Social Resilience Program (PRES) and reflected in 2020 Revised Budget Law; Financial Management Information System provides COVID-19 checkbox to track expenditures; budget execution reports published within 90 days after each quarter.
- Sierra Leone: Supplementary budget approved in July 2020 regularized COVID-19 spending. NaCOVERC legal framework and fiduciary rules established; dedicated fund and reporting (unaudited financial statements) published; commitment to publish NaCOVERC statements quarterly.
- Solomon Islands: Economic stimulus package approved by parliament via supplementary appropriations bill; oversight committee established to monitor pandemic-related spending and assess impacts.
- South Africa: Draft procurement legislation to consolidate public procurement rules expected to be presented to parliament in 2022 (facing procedural delays). National Treasury published an explanatory note on COVID-19 expenditure execution for FY20/21 in February 2022.
- South Sudan: RCF disbursements used to clear wage and salary arrears for government employees (health workers, teachers, civil servants); transactions recorded in IFMIS through a dedicated sub-account.
- St. Vincent & the Grenadines: Authorities passed a supplementary budget to authorize pandemic-related spending.
- Tajikistan: Prepared quarterly reports on emergency fund spending and published them on the Ministry of Finance external website for 2020 and first nine months of 2021.
- Tanzania: Supplementary budget submitted to parliament in late February 2022. All COVID-19 spending tracked through IFMIS under one project code number. Second quarterly report published on Ministry of Finance website; commitment to publish quarterly reports within one month after quarter ends.
- Tonga: Authorities finalizing PFM action plan and strengthening procurement, cash management, and internal audit processes; legal and regulatory framework and quarterly procurement statistics available on MoF procurement website.
- Ukraine: Fund to Fight Against COVID-19 and its Impact created for 2020. The fund's resources in 2020 amounted to UAH 80.9 billion, including UAH 72 billion in the general fund and UAH 8.9 billion in the special fund. Fund procedures approved by Cabinet of Ministers Resolution #302. Decisions on allocation published on Cabinet website; reports to Cabinet and parliament’s budget committee on use of funds were monthly.
- Uzbekistan: Anti-Crisis Fund appropriated COVID-19 emergency measures; amendment (ZRU-168) to Budget Law including COVID-related expenditures approved May 18, 2020. Anti-Crisis Fund terminated end-2020; Ministry of Finance published regular summary updates on pandemic-related spending on its telegram channel.

### Reporting, publication timelines, and other governance measures
- Namibia: Auditor General will conduct an independent audit of COVID-19 spending, including ex-post validation of goods and services procured, as part of annual auditing within 12 months of end of FY20/21. Finalization of the Public Financial Management bill expected by mid-2023; adoption expected by end-2022 (authority language: finalize draft by end-2021 and adopt by end-2022 in original commitment).
- Nepal: Authorities commit to report quarterly on spending, commission independent audit by OAG in about a year, and publish quarterly reports and audit results on implementing agency websites.
- Nicaragua: UNOPS external audit will be published on the government’s website within two weeks of finalization; financial statements of five largest state-owned enterprises covering 2015–20 published including external audit reports and certification for ENATREL, ENEL and ENACAL. IMF conducted technical assistance missions in November 2020 and follow-up TA in 2021; Fiscal Transparency Evaluation conducted in March 2022.
- Niger: Following financial irregularities at ministries of Finance and Defense, administrative sanctions and legal actions were taken and adjustments to expenditure chain introduced, including suspension of payments without prior payment orders.
- Pakistan: FATF plenary in October 2021 recognized progress: 26 of 27 action items satisfactorily addressed; one pending action related to terrorist financing investigations (Immediate Outcome 9). Authorities on track to complete 2021 AML/CFT Action Plan by end-January 2023 with 6 of 7 action items satisfactorily addressed. Authorities working to establish electronic asset declaration system focused on high-level public officials (Base Pay Scale 17 to 22) with regulations as end-March 2022 structural benchmark.
- Papua New Guinea: Consolidated report submission and publication within three months of end of emergency committed; unclear timing due to ongoing local outbreak.
- Rwanda: Authorities’ E-procurement system accessible online; Auditor General audit outcomes to be published; FY20/21 audits expected by end-May 2022.
- Samoa: FinanceOne System used to strictly monitor pandemic-related expenditures; progress report on implementation of response plan prepared.
- Sao Tome and Principe: Working with World Bank to build procurement system to integrate actors and modernize procurement; draft procurement law with beneficial ownership reporting under review by MoF for transmission to Parliament.
- Senegal: COVID-19 expenditure monitoring committee established; monitoring and publication cadence described above.
- Seychelles: All beneficiaries of wage subsidies published publicly on Ministry of Finance website; full report being finalized for publication.
- Sierra Leone: Authorities published NaCOVERC unaudited financial statements as of December 31, 2020 (prior action); committed to monthly publication of large procurement contract details on NPPA website and to facilitate ASSL final audit publication within 12 months of fiscal year end.
- South Africa: Auditor General special audit reports and National Treasury dashboard published; draft procurement legislation procedural delays noted.
- South Sudan: All RCF-related transactions reflected in IFMIS through dedicated sub-account; Auditor General audit identified potential non-compliance up to US$16 million of US$52 million disbursed.
- Tajikistan: Authorities publishing quarterly reports on Ministry of Finance external website for 2020 and first nine months of 2021.
- Tanzania: Commitment to publish ongoing CCRT audit by April 2022 and complete post-crisis audit by December 2022; IFMIS codes created to track RCF/RFI spending.
- Uganda: First semi-annual COVID-19 spending report prepared but not yet published; Uganda Development Bank published a first report on use of funds; special audit published and discussed in parliament January 2022.
- Ukraine: Accounting Chamber and State Audit Service reports published; procurement notices and purchase orders to be accessible on ProZorro; Fund reports prepared within deadlines.
- Uzbekistan: Financial Control Department included all Anti-Crisis Fund expenditures in inspections and provided monthly reports to management; Chamber of Accounts audit published September 2021.

---


_Source: https://www.imf.org/-/media/files/topics/governance-and-anti-corruption/may22matrix-implementation-status-of-governance-commitments-on-pandemic-related-spending.pdf_