The report examines the entire disclosure chain – from the scope of declarants, declarable content and publication to data structure, linkage, institutional oversight and verification. The authors draw on several comparative studies with different samples, including World Bank data covering 176 countries. Particular attention is paid to how the disclosed information can subsequently be used.
As the authors note, there is no uniform, generally accepted approach to how declarations should be designed, what they should contain, how they should be published, or how compliance with the relevant requirements should be enforced.
Overall, the analysis shows that while more than 160 countries have introduced some form of financial disclosure system for public officials, only a small number publish declaration data that simultaneously:
- have sufficiently broad coverage;
- provide sufficient depth of information;
- are available in a format that permits systematic analysis across countries and over time.
Scope of declarants
According to the report, five broad categories can be distinguished in terms of the coverage of declaration systems:
- members of parliament;
- high-ranking executive officials, including heads of state and government, cabinet members, and deputy ministers;
- representatives of the judiciary, primarily judges and prosecutors;
- heads of public bodies and organizations;
- representatives of subnational institutions, including local elected politicians and senior subnational administrators.
An analysis of global practice shows that disclosure requirements most commonly cover members of parliament, heads of government and cabinet members; coverage of the judiciary is substantially more limited, while political party officials are the least commonly covered category. At the subnational, or local, level, almost two-thirds of the surveyed countries require disclosure from elected local politicians, while one-third require it from subnational administrators.
Requirements concerning disclosure of information on family members also vary considerably depending on a country’s income level. Such requirements are in place in only 38% of low-income countries and 51% of high-income countries, compared with 79% of lower-middle-income countries and 85% of upper-middle-income countries.
Content of declarations
As the report notes, the depth of required information determines the analytical and enforcement potential of a declaration system.
A comprehensive and detailed declaration should distinguish between asset-related and interest-related information. The former is intended to support the tracking and analysis of wealth, changes in net worth, and possible illicit enrichment; the latter is intended to support the identification and prevention of conflicts of interest, even where no direct monetary value is apparent.
Across many countries, the categories of information subject to disclosure are broadly similar: financial accounts, securities, and property are among the most frequently required categories.
However, the level of detail may vary considerably between jurisdictions. For example, in some jurisdictions the concept of “assets” covers only domestic property, while in others it also includes foreign property. Likewise, some systems require the current market value of an asset, while others record its acquisition price.
Moreover, even where the same nominal categories of information are required, the information actually reported may differ substantially. In Chile, for example, the fiscal cadastral value is reported for each property, which typically lags the market value. Bulgaria requires officials to report the acquisition cost, which, depending on when the asset was acquired and subsequent price developments, may differ substantially from its current market value. Croatia, by contrast, requires the current market value, while Romania does not require a monetary value at all, instead collecting descriptive information such as the type, location, and size of the property.
These differences create significant obstacles to cross-country comparisons.
Publication and data quality
Drawing on a 2022 Open Government Partnership study, the authors note that although all 67 countries assessed require the collection of asset declarations, only 61% actually publish them. Among these, only 37% publish data under open licenses, 17% provide machine-readable data, and just 7% offer bulk downloads.
According to the authors, publication alone does not make declaration data usable for analysis. The most common publication formats remain HTML and PDF, including scanned or handwritten documents. Such declarations may formally be publicly accessible, but they are difficult to process automatically, compare over time, or link to other datasets.
Effective use of declaration data requires structured, machine-readable formats, such as CSV, XML, JSON, or XLSX, as well as unique identifiers for natural persons and legal entities. Such identifiers make it possible to cross-reference declaration data with, for example, company registries, public procurement data, and beneficial ownership records. Without them, matching records by names alone is considerably less accurate and more resource-intensive.
The report provides examples of systems where such data linkage is already used in practice. Romania’s PREVENT system cross-references asset and interest declarations with public procurement data to identify potential conflicts of interest. In Ukraine, the analytical module of the National Agency on Corruption Prevention automatically cross-checks declaration data against 16 registries at the time of submission.
Another issue is the temporal persistence of published information. In some countries, declarations are removed from public access after an official leaves office. This impedes retrospective analysis, including efforts to identify gradual wealth accumulation or conflicts of interest that emerge after the end of an official’s term.
Thus, the analytical value of a declaration system depends not only on whether declarations are published, but also on the completeness and accuracy of the information they contain, the format in which the data are made available, their ability to be linked with other datasets, and their persistence over time.
Recommendations
Overall, the authors note that the main challenge today is no longer a lack of guidance, empirical evidence, or examples of good practice, but rather insufficient implementation and the absence of a common data standard.
GTI experts put forward a number of recommendations aimed at strengthening the potential of asset and interest declaration systems, including:
- Design structured data infrastructure – move to structured and machine-readable formats with clearly defined fields and values and develop the necessary IT capacities;
- Mandate unique identifiers for natural persons and legal entities – to enable declarations to be cross-referenced with other datasets;
- Widen coverage – extend disclosure obligations to a broader range of public officials, including senior officials in public agencies and subnational decision-makers, while also extending disclosure requirements to close family members;
- Tailor data access to different audiences – for researchers and civil society, provide API access, clear identifiers, and bulk-download functionality; for the wider public, provide accessible dashboards and explanatory materials;
- Require asset valuation – declarations should capture the location and current value of assets to allow year-on-year changes to be traced and unexplained wealth accumulation to be detected;
- Enable data verification systems – an independent oversight body should have adequate legal authority, sufficient and stable funding, and technical capacity to conduct automated and identifier-based cross-checks, complemented by targeted spot checks on higher-risk profiles.