Government Action Plan Tracker
Demand transparency, promote accountability, and help shape the system change.
Welcome to the GAP Tracker, your window into the government’s progress toward stronger governance and accountability. This platform is designed to monitor the Sri Lankan Government’s Action plan of critical reforms called Priority Recommendations outlined in the 2023 IMF-led Governance Diagnostic Report. The tracker will enable and empower citizens and other stakeholders to oversee the government’s implementation of the action plan.
The Government Action Plan, published in February 2024, was developed as a Structural Benchmark (SB) under the second review agreement of Sri Lanka’s Extended Fund Facility (EFF) with the IMF. It aims to address systemic corruption vulnerabilities in areas of public financial management, tax policies, public procurement, and financial oversight. While implementation of the action plan is the responsibility of the government, this tracker seeks to fill a critical gap by providing an oversight mechanism for its effective implementation.
Through this tracker, created by Transparency International Sri Lanka, you can follow recent updates, explore detailed progress on priority reforms, and see how effectively and meaningfully the government is closing governance gaps and corruption vulnerabilities that impact economic stability and social equity.
We go beyond box ticking —this platform flags delays, identifies concerns, inadequacies and ineffective compliance and suggests solutions to ensure reforms are effectively implemented and deliver meaningful and sustainable change.
Trial Version in Progress -Please note that this is a trial version of the tracker, and some features are still under development. Stay tuned for updates and await the full version soon!
Gazette the rules for appointing CIABOC Commissioners
Reform commitment 01
In line with requirements under the 21st Amendment to the Constitution, the Constitutional Council will develop rules for appointing CIABOC Commissioners that will establish an open and transparent process to ensure selected candidates meet the highest levels of professionalism, ethical conduct, and integrity. These rules will be published in the Gazette.
Steps
Implemented. Link: https://www.parliament.lk/files/ads/2023/cc/ciaboc-ad-en.pdf
Institution
Constitutional Council
IMF-GDA rec.
1
CSO GDR rec.
16
Completion date
Dec 23
Publish asset declarations
Reform commitment 02
Publication of asset declarations for senior officials (President, Prime Minister, Ministers) on a designated website in line with Anti-Corruption Law.
Steps
01. Create and operationalize the centralized electronic system for the AD system (as per sec 82) before the submission period begins. The system needs to be able to generate a redacted version of ADs as per sec 88.
Issue 1: Not fully implemented – only a temporary measure is in place through a portal on the CIABOC website, allowing access to uploaded PDFs of asset declarations. However, the information is not machine-readable, and the declarations are not maintained in a centralized electronic system.
The lack of a centralized electronic system and non-machine-readable format significantly hampers the usability and accessibility of asset declarations, making it difficult to analyse or detect discrepancies efficiently. This undermines the effectiveness of the asset declaration process as a tool for ensuring accountability and transparency.
Issue 2: The CIABOC has excessively and arbitrarily redacted crucial information from asset declarations, such as bank balances, account opening dates and names of children, which goes beyond what is mandated by the Anti-Corruption Act. This undermines the transparency and effectiveness of the asset declaration system. Additionally, CIABOC’s unnecessary requirement for an email address for identity verification creates barriers to public access.
02. Draft a circular elaborating the submission process (completed) Define in regulations or as part of the circular the type of officials required to submit ADs.
Implemented. Link: https://www.ciaboc.gov.lk/images/asset_declaration_formats_website/Asset_Circular_ENG_Singed.pdf
03. Develop the asset declaration form template to be used by public officials. Publish the template on the centralized electronic system for the public to consult.
Partially implemented. A template was created and published on the CIABOC website. However, not published on the centralised electronic system as the system is not developed.
Institution
CIABOC
IMF-GDA rec.
2
CSO GDR rec.
15
Completion date
June ‘25
Enact proceeds of crime legislation
Reform commitment 03
Enact proceeds of crime legislation that is fully aligned with UNCAC and FATF standards.
Note: The Proceeds of Crime Bill was gazetted by the ninth parliament in September 2024, shortly before the parliamentary elections held on November 14, 2024. Following the elections, the new government has expressed interest in advancing an improved version of the Bill into legislation.
Steps
01. Submission of the Report of the Committee to develop the Policy and Legal Framework of the proposed Law on Proceeds of Crime by the end of February.
Implemented. Link: https://www.moj.gov.lk/images/2024/Legal/Propossed-law-on-Proceeds-of-crime.pdf
02. Preparation of Final Draft by the Legal Draftsman by mid-March.
03. Issuance of Certificate of Constitutionality for the Final Draft by end March.
04. Submission for Cabinet approval and gazetting by end-March.
Note 01: Steps 2-4 were not implemented by the deadlines; however, they were implemented with delay as the Proceeds of Crime Bill was Gazetted in September 2024.
Note 02: The legal framework and the Bill were drafted without public and adequate civil society consultation, reflecting the absence and lack of will to engage the public and civil society organizations in the policy making and legislative processes. This opaqueness undermines transparency and inclusivity and the ability to create a robust law. It is noteworthy to state that TISL has provided feedback on the Report of the Committee, following persistent advocacy and attempts to engage with the Ministry of Justice which materialised due to the assistance received from the UNDP. Limited feedback provided by TISL and Verité Research alone do not qualify as effective CSO and public consultation.
Institution
Ministry of Justice
IMF-GDA rec.
3
CSO GDR rec.
31
Completion date
April ‘24
Implement beneficial ownership law and establish a public BO registry
Reform commitment 04
Finalise and implement regulations to support the provision of beneficial ownership information as required by the Companies Act and establish a public beneficial ownership registry.
Steps
01. Drafting and Submission of Regulations to Cabinet and Parliament.
Not implemented.
02. Development of eRoC online system accordingly.
Not implemented.
03. Conducting awareness programs for the stakeholders, company secretaries, directors, and shareholders.
Not implemented.
04. Maintenance of beneficial ownership information and registry.
Not implemented.
Note: The establishment of a beneficial ownership registry has not been implemented, the ninth parliament Gazetted a Bill on August 6, 2024, to introduce the registry and law by way of an amendment to the Companies Act of 2007.
TISL challenged the Bill, citing critical concerns that undermine the effectiveness of the Beneficial Ownership Registry sought to be introduced. Key concerns included exemptions for offshore and overseas companies, allowing shell companies to evade disclosure, and limiting public access to information to only names and ownership extent, which weakens transparency, accountability, and public oversight. TISL called for stronger measures to ensure the registry deters corruption and enables oversight and scrutiny. During the hearing, the Attorney General agreed to address several concerns of TISL Petition including eliminating the exemption granted to offshore and overseas companies. However, the presidential and parliamentary elections that followed have terminated the hearing, and a fresh Bill is required to be re-gazetted by the new government to implement this reform.
As with other policies and legislation, this process was also shrouded in opacity. The amendment and provisions for the Beneficial Ownership register were drafted behind closed doors without public or civil society consultation and with no transparency regarding its progress or content, despite TISL’s active efforts to obtain a draft of the law.
Institution
Ministry of Industries Department of Registrar of Companies
IMF-GDA rec.
5
CSO GDR rec.
25
Completion date
Sept ‘24
Enact a Public Procurement Law
Reform commitment 05
Enact a Public Procurement Law that reflects international good practice.
Steps
01. The National Procurement Commission (NPC) has already initialized drafting of the Procurement Law with ADB assistance.
02. NPC has confirmed two local consultants have already been hired and another foreign consultant to be hired with ADB assistance to draft the law.
03. Plan is to have the first draft ready by end June, 2024 and subsequent to stakeholder consultations and LD/AG clearance to submit the draft Bill to Parliament by 31st December, 2024 as agreed with IMF.
Note: The drafting of the new procurement law and guidelines has taken place behind closed doors, with no public and civil society consultation or transparency regarding its progress or content. Despite active efforts by civil society organizations, including Transparency International Sri Lanka, to engage, provide feedback, or even ascertain the status of the law, meaningful access and participation have been denied.
Institution
Ministry of Finance
IMF-GDA rec.
6
CSO GDR rec.
23
Completion date
Dec ‘24
Publish report on increasing competitive tendered procurement contracts
Overall Progress
Reform commitment 06
Publish report on a designated website on progress in increasing the proportion of competitive tendered procurement contracts in the 10 agencies determined to have the lowest level of competitive tenders in 2022.
Steps
Action has been already taken to identify 10 agencies with lowest competitive tenders with the value of annual procurement in excess of Rs. 1 Billion. IMF Technical assistance is sought to decide on the information that has to be published in the MOF website.
Not implemented.
Institution
Ministry of Finance
IMF-GDA rec.
7
CSO GDR rec.
24
Completion date
Dec ’24
Publish all public procurement above LKR 1B, award winners and tax exemptions
Reform commitment 07
Publish on a designated website: (i) all public procurement contracts above LKR 1 billion, along with comprehensive information in a searchable format on contract award winners; (ii) a list of all firms receiving tax exemptions through the Board of Investment and the SDP, and an estimation of the value of the tax exemption; and (iii) a list of firms receiving tax exemptions on luxury vehicle import. Information to be updated every 6 months.
Steps
(i) Partially Implemented. Link: https://promise.lk/?p=public_cont&a=view_proc_awarded_public
Note: It was observed that the Promise.lk website does not contain details of all public procurement contracts above LKR 1 billion, for example, the procurement details of awarding the 484 MW wind power plant in Mannar and Pooneryn to Adani Green Energy Ltd, and details of the procurement process and the contract awarded to VFS Global for handling the Electronic Travel Authorization (ETA) system for the issuance of visas for tourists visiting Sri Lanka, are examples of procurements comprehensive details of which, are not published in this platform. There may be many other procurements that are within the threshold albeit not reported.
ii) Implemented. Link: https://www.treasury.gov.lk/web/tax-certificatesissued-under-boi
iii) Implemented. Link: https://www.treasury.gov.lk/web/luxury-taxexemptions
Institution
Constitutional Council
IMF-GDA rec.
8
CSO GDR rec.
12
Completion date
Dec 23
Implement the SOE Reform Policy
Reform commitment 08
Implement the SOE Reform Policy, ensuring that the holding company (HoCo) and the advisory committee are comprised of skilled, independent, and ethical staff.
Steps
01. SOE Reform Policy approved by Cabinet in May 2023.
Implemented. Link: https://www.treasury.gov.lk/web/sru/section/divestitures
02. Public Commercial Business (PCB) Act drafted and awaiting Parliamentary approval.
Not implemented.
03. Registration of HoCo and appointment of its Advisory Committee and Board of Directors to take place once PCB Law has been approved.
Not implemented.
Institution
Ministry of Finance
IMF-GDA rec.
9
CSO GDR rec.
26
Completion date
May ‘24
Abolish or suspend application of the Strategic Development Projects Act
Reform commitment 09
Abolish or suspend application of the Strategic Development Projects Act until promulgation of explicit and transparent process for evaluation of proposals and costing of investment promotion conditions.
Steps
No further exemptions will be granted under the SDP Act.
Not implemented.
Institution
Board of Investments (BOI) Office of the President
IMF-GDA rec.
10
CSO GDR rec.
06
Completion date
Until Promulgation of new provisions (as per GAP)
Amend tax legislation to eliminate or restrict ministerial authority
Reform commitment 10
Amend tax legislation to eliminate or restrict ministerial authority to introduce tax changes without prior parliamentary approval and ensure that such changes do not generate revenue losses.
Not implemented.
Steps
01. The government has already initiated a new National Tariff Policy (NTP) which will outline the way forward on border taxes including CID, SCL and other measures which are subject to ministerial authority.
02. Following the approval of the NTP by the Cabinet, MoF will review the legislation pertaining to these measures.
03. Provisions enabling unfettered ministerial authority will be reviewed during this process with a view to introducing checks and balances which strike a balance between appropriate consultation, prevention of market manipulation, ensuring revenue protection, and reducing corruption vulnerabilities.
Institution
Ministry of Finance
IMF-GDA rec.
10
CSO GDR rec.
11
Completion date
Continuous
Revise legislation, regulations, and process on financial sector oversight in the banking sector
Reform commitment 11
Revise legislation, regulations, and process relating to financial sector oversight in the banking sector, including strengthening corporate governance for banks with government ownership by improving the selection of executives and Board members.
Steps
Enactment of the Banking Act to include inter alia provisions to strengthen corporate governance in the banking sector, including the assessment of fitness and propriety of directors, CEO’s and Key Management Personnel.
Implemented.
Note: The Central Bank of Sri Lanka (CBSL) implemented the Banking (Amendment) Act, No. 24 of 2024, effective from 15 June 2024.
Institution
Central Bank of Sri Lanka
IMF-GDA rec.
14
CSO GDR rec.
Completion date
March ‘24
Establish a digital land registry, and publish progress on State land registering/titling
Reform commitment 12
Establish an online digital land registry, and publish, on a designated website, report on progress in implementing published Plan for registering/titling all state land.
Steps
01. Title Registration: Preparing BPR/SRS report, selecting vendor, implementation.
Not implemented.
02. Land Registration: Implementation of eLand System, maintenance.
Partially implemented.
Link: https://www.rgd.gov.lk/web/index.php?option=com_content&view=article&id=31&Itemid=246&lang=en
Institution
Ministry of Lands
IMF-GDA rec.
15
CSO GDR rec.
Completion date
Dec ‘24
Implement a plan to enhance resources and skills of the Judicial Services Commission
Reform commitment 13
Establish and implement a plan to expand the resources and skills available to the Judicial Services Commission in order to enhance their ability to carry out their function and define potential options for modifying governance arrangements in the Justice sector to strengthen oversight, monitoring, and proper sector development.
Not implemented.
Steps
01. Establish a separate unit to collect and update court statistics.
02. Increase number of courts to ensure speedy disposal of cases.
03. Introduce case management and court management to all courts.
04. Establish separate units to attend to public petitions and disciplinary matters.
05. Introduce a digital solution to ensure all judgements are uploaded into a system.
06. Constant supervision of the functioning of courts.
07. Establish separate units to attend to the functions of High Courts, District and Magistrates Courts, Labour Tribunals.
08. Establish an Audit Unit to attend to case audits, production audits, etc.
09. Attend to HR management of courts staff through an automated system.
10. Attend to complaints against staff expeditiously.
11. Hold recruitment examinations continuously.
12. Attend to general staff administration matters expeditiously.
13. Establish a prosecution arm to attend to the prosecution of disciplinary matters.
14. Develop a database of all disciplinary matters.
15. Evaluate the performance of Quazis.
Institution
Ministry of Lands
IMF-GDA rec.
15
CSO GDR rec.
Completion date
Dec ‘24
Amend the National Audit Act to enable accountability
Reform commitment 14
Amend the National Audit Act to enable the Auditor General to levy surcharges on officers, including chief accounting officers, for failure to properly discharge responsibility for oversight and accountability for use of public resources.
Not implemented.
Steps
01. Convening a meeting between Ministry of Finance and Auditor General’s Department, Attorney General’s Department, Presidential Secretariat, and Inspector General of Police (12th of Feb).
02. Proposals of amendments made by Auditor General.
03. Seeking approval of Presidential Secretariat on cabinet policy paper.
04. Granting of draft amendment approval by Cabinet.
05. Drafting of amendments by Legal Draftsman’s Department.
06. Review and certification of amendments by Attorney General.
07. Gazetting of amendments.
08. Presenting Amendments to Parliament for approval.
Institution
IMF-GDA rec.
4
CSO GDR rec.
4
Completion date
Dec ‘24
Despite the fact that the IMF sets out 16 Priority Recommendations in its Governance Diagnostic Report, the GAP only reflects 14 recommendations.
The 2 recommendations which are not included in the GAP are;
- Ministry of Finance to institute a short-term anti-corruption measure within each revenue department to strengthen internal oversight and sanctioning processes and linkages with CIABOC and related criminal investigation and enforcement processes by Dec 2023 and issue a public report on steps taken and results obtained by Dec 2024.
- Following a broad consultative process, the Ministry of Finance to produce a Cabinet policy paper by June 2024 on options for establishing new management arrangements for the Employee Provident Fund that terminates direct CBSL management.