Angola scores 63.5 points in EITI implementation 

The International Secretariat's final assessment is that Requirement 1.5 is fully met. The MSG’s ‘outcomes and impact’ file and MSG’s self-assessment considers the objectives of the requirement 1.5 is mostly met. Stakeholders during consultations did not express particular views in relation to the objective of the requirement but highlighted that Angola implementation was addressing key priority topics that were too sensitive previously such as a USD 16 bn debt linked to oil backed loans. The International Secretariat notes that the 2021-2024 work plan lays out realistic activities that are the outcome of wide consultations with government, industry and civil society constituencies. The work plan is linked with some key national priorities and EITI principles and was subject to a review and progress stocktake once during the period under review. The International Secretariat is of the view that the underlying objective is fully met, although the work plan could benefit from more regular reviews with a wider range of stakeholders and from strengthened linkages to fighting corruption or attracting investments, as well as more activities aimed at lifting legal barriers to implementation. Angola maintained a work plan covering 2021-2024. The work plan is publicly available on the EITI Angola website and updated annually based on consultation with relevant stakeholders as confirmed during consultation. In March 2022, Angola also produced a narrative to the work plan which was shared as part of the application to join the EITI. The work plan links activities to each EITI requirement and frames implementation under 3 macro-objectives related to building technical capacity, improving transparency in extractive sector revenue management, and promoting public disclosure of extractive sector payments. The narrative work plan highlights the link between work plan macro-objectives and some national priorities, such as domestic revenue mobilisation and the reform of the legal and institutional framework. EITI Angola also considers in its Validation template that the work plan is linked to national priorities, demonstrated through linkages to key national strategic documents including Angola Long-Term Development Strategy, National Development Plan 2023-2027, Energy Transition Strategy, and biofuels legislation. However, while the work plan objectives and some activities reflect a clear link to national priorities, the International Secretariat notes that it does not provide any clear objectives supporting efforts to address corruption or to attract investment which are two of the government’s key priorities (Although there is a description in the Angola 2022 report of anti-corruption policies for companies). Fighting corruption has been highlighted as a priority by President João Manuel Gonçalves Lourenço administrations commitments and Minister Diamantino Azevedo comments when joining the EITI , and attracting investment has been highlighted several times during stakeholder consultations as a key government objective for EITI implementation. The work plan also includes activities related to systematic disclosure, which have not yet been fully implemented. Consultations with stakeholder surfaced plans by EITI Angola to mainstream some disclosures in 2025 through development of an e-reporting platform and plans for peer learning to advance on systematic disclosure, although discussions are still in early stage. The 2021-2024 ITIE Angola work plan was developed through a comprehensive three-stage consultation process involving government, industry and civil society constituency. The outcome and impact file, stakeholder consultation, as well as the work plan narrative report indicate that the MSG formed a technical working group with representatives from all constituencies. Civil society participated primarily through the TCHOTA platform , while mining sector companies reviewed individually and oil sector input was facilitated under ACEPA, . While the consultation process has been clearly documented, there seem to be no specific documentation of input provided by each constituency to contribute to the work plan development. Additionally, the work plan was discussed by the MSG in 2023 where it was extended to the year 2024, although there is no evidence of wider consultation to update the work plan or adjustments of the activities. The 2021-2024 work plan is fully costed, with the government covering 70% of the expenditures, and the remaining 30% to be contributed by voluntary cooperation partners, which as at time of review there have been no contribution. Additionally, the work plan includes a report on budgeted versus actual expenditure. The work plan includes realistic and measurable activities, with 63 total activities identified across three main objectives, and progress tracking showing 42 activities completed, 12 ongoing, and 9 unrealised. The EITI Angola MSG has published in open format on its website an annual progress report that details a monitoring of activities from the work plan (See Requirement 7.4). EITI Angola’s work plan states capacity building as a key objective. The work plan includes activities focusing on strengthening the technical and operational capacity of the MSG and national secretariat. Evidence from EITI Angola indicates targeted capacity building exercises have been conducted for national secretariat and stakeholders in the MSG. However, stakeholder consultations suggest a limited or no capacity building effort focused on wider stakeholders, beyond the MSG. Additionally, the work plan references the timetable for the EITI Report but does not include any activities around preparing for Validation. The EITI Angola work plan builds on a result-based approach with clear activities and output linked to requirements in the EITI Standard. On contract transparency and beneficial ownership disclosure, the work plan outlines specific activities (44 and 51) that include the development of a joint government-private sector roadmap with specific timelines and assigned responsibilities, although these as at time of review are still in draft stage. Given the legal barriers in Angola to disclosure of revenues and payments, the work plan would also benefit from a stronger focus on establishing clear activities to resolve the legal and practical barriers for comprehensive disclosures and to improve data assurances of financial data. The work plan includes activities linked to improving on recommendations from previous report. Additionally, the 2022-2024 work plan includes topics beyond the basic requirements of the EITI Standard, such as on elaborating an energy transition study that will explore the impact of a transition to clean energy sources, which at time of review was still in the planning phase.

The International Secretariat’s final assessment is that Requirement 7.1 is mostly met. The MSG’s outcome and impact template considers that the objective of enabling evidence-based public debate on extractive industry governance through active communication of relevant data to key stakeholders is mostly met. During consultations, representatives from CSOs highlighted that the insufficient technical and financial capacities, combined with limited clarity of Angola EITI Reports, limited their ability to fully engage in public debate with EITI data, especially at the community level. The International Secretariat agrees with the MSG’s self-assessment in considering that the objective is mostly fulfilled. Indeed, EITI Angola has undertaken efforts to disseminate EITI reporting and implementation activities, through widespread outreach events to relevant stakeholders. However, there is limited evidence of use of EITI data particularly by CSOs, mainly due to technical capacities. The International Secretariat considers that there is scope to improve comprehensibility of EITI data and reporting in order to fully meet the objective and finds that this requirement is currently only mostly met. The EITI Angola website has published the first EITI Reports in both English and Portuguese and included an executive summary in both 2021 and 2022 EITI Reports. The MSG has actively promoted Angola EITI Reports through dissemination efforts that involve relevant stakeholders and workshops. The MSG has organised EITI Report launch events that engage media, government representatives, industry and civil society organisations. In addition, there is evidence of efforts in communicating challenges for EITI implementation in Angola including gaps in contract and beneficial ownership transparency. The MSG has agreed on an EITI Dissemination Strategy covering 2024 – 2026 and a short-term dissemination plan for 2024, which provides the framework for its outreach and dissemination activities, Only the short-term plan is publicly available on the EITI Angola website at the time of this draft report. Evidence from the outcome and impact template (annexe 13), as well as stakeholders consultations indicates that the MSG has organised and participated in various outreach events and initiatives to promote EITI disclosures. Though not exclusively conducted by EITI Angola, CSOs in the MSG organised and participated in community level engagement in Huíla (annexe 18 of the Validation template), Waku Kungo and Eastern Region of Angola (Lunda Sul, Lunda Norte, Moxico and Cuando Cubango), where they engaged with communities to communicate the importance of transparency and EITI data use in the management of natural resource, followed by CSOs publishing articles with recommendations. CSOs also highlighted the need to have the EITI findings translated into local languages. At the national level, the MSG conducted workshops to share and present information on EITI implementation with key stakeholders, including MIREMPET, ENDIAMA, SODIAM, SONANGOL, ANPG, and AGT. Additionally, through the TCHOTA platform, CSOs organise annual national regional conferences where, in addition to an opening addressed read on behalf of the Minister of Mineral Resources and Petroleum, ADRA, a CSO member of the MSG, presented on the EITI in the conference. These engagements have led to the publication of EITI implementation updates from these agencies and organisations on their respective websites. Following the publication of the first EITI Report, the civil society organisation Mosaiko disseminated a report calling for greater transparency in the extractive sector in Angola, highlighting the main challenges related to taxpayer confidentiality constraints, contract transparency and beneficial ownership transparency in the country. At the regional level, EITI Angola MSG representatives participated in three regional peer learning events aimed at promoting transparency and knowledge exchange (domestic resource mobilisation in Lusaka, commodity trading in Abidjan, and peer learning with EITI Mozambique on EITI Implementation, in Maputo). Dissemination efforts have also been widely promoted through extensive media coverage and participation in the EITI Global conference and EITI Board meeting and significant stakeholder engagement regarding Angola’s admission to the EITI. However, the International Secretariat’s review of available dissemination materials and data use examples, as well as stakeholder consultations, suggests that, despite these efforts there is limited use of EITI data to inform the public debate. Consultation with CSOs highlighted lack of technical and financial capacity as a key factor, combined with the insufficient comprehensibility of the EITI Report (See Requirement 7.2 on accessibility of EITI data). Furthermore, the media context has been marked by cases of corruption and judicial proceedings related to the extractive sector in Angola, such as the Isabel dos Santos related Luanda leaks or more recently the Trafigura corruption case . While recognizing that some of these cases relate to past practices that predate the new government and its wave of reforms against corruption since 2017, the EITI presents an opportunity for discussion by the EITI MSG on these cases or contributions of EITI to strengthen governance through public debate based on lessons learned. The International Secretariat recognises the commitments for transparency of the current government and the new state-owned enterprise officials. During consultations, stakeholders also highlighted that current practices in Angola and of its state-owned enterprises have changed and highlighted the wave of reforms initiated by the new government to fight corruption such as the creation of oil and mining regulators ANPG and ANRM. The International Secretariat also noted a general anti-corruption training involving EITI in 2023 and a description of anti-corruption policies for key companies in the 2022 EITI Report, and the presentation of the anti-corruption policies of TotalEnergies, Sonangol and Endiama during the capacity building sessions organised by the International Secretariat for the MSG in 2024. There is also an opportunity for EITI to lead public debate using EITI data around the Lobito corridor (although there is a section in the EITI Report highlighting that it has yet given rise to material transportation revenues), given the prominence of the topic in the media in terms of potential impact in the extractive sector.

The International Secretariat's assessment is that Requirement 7.2 is mostly met. The MSG’s outcome and impact template considers that the objective of enabling broader use of information on the extractive industries through the publication of information in open data and interoperable format is mostly fulfilled. The International Secretariat acknowledges the publication of an open data policy and of the data from EITI reports in open format. However, given the limited revenue disclosures, the International Secretariat considers that the level of data accessible to the public is insufficient to fully meet the objective of enabling the broader use and analysis of information on the extractive industries. Therefore, the Requirement is considered mostly met EITI Angola has published to date and in PDF format its first and second EITI report, including all tables and graphs featured in both reports on their website in Excel format (although the 2021 file seems no longer downloadable on national website, but available on eiti.org). Angola has also submitted to the International Secretariat summary data files for both EITI Reports covering financial years 2021 and 2022. EITI Angola has published an Open Data Policy on their website and the policy was approved on 27 September 2024, albeit with reservations and with the commitment to hold technical meetings between with legal experts from ACEPA, ANPG, ANRM, Sonangol E.P., ENDIAMA E.P., SODIAM E.P., MIREMPET and civil society, to further discuss and review it, if needed. These consultations were rescheduled for April 2025.

The International Secretariat’s assessment is that Requirement 7.3 is fully met. The MSG’s outcomes and impact template considers that the objective of ensuring that EITI implementation is a continuous learning process that contributes to policy making, based on the MSG regularly considering findings and recommendations from the EITI process and acting on those recommendations it deems are priorities, is mostly met. Stakeholders highlighted during consultations that improvements in the 2nd Report, such as the reconciliation pilot, and engagement in peer learning activities, was evidence that there was follow up from recommendation and that EITI in Angola was a learning process, acknowledging further improvements to be made. The Secretariat agrees with stakeholder’s views in acknowledging the efforts implemented in the 2nd EITI Report and efforts of learning from peers. The EITI Angola MSG has established mechanisms for addressing recommendations and following up on discrepancies and information gaps. The MSG meets quarterly to evaluate implementation progress. EITI Angola has also made efforts to create follow-up mechanisms beyond the work plan to ensure that recommendations are acted upon. As indicated in the outcome and impact files, this includes the establishment of technical working groups to address recommendations linked to beneficial ownership and contract transparency. The outcomes and impact Validation template also tracks recommendations related to several requirements with a description of actions taken on each of these, and the level of the implementation so far, acknowledging that some recommendations have not yet been fully implemented. Moreover, EITI Angola demonstrated efforts in setting EITI as a learning process by funding a peer learning activity in Mozambique and publishing a report with the lessons learned from the peer learning. Many stakeholders during consultations highlighted the value of the peer learning. The lessons learned from the peer learning, as highlighted in the outcomes and impact Validation template, cover several aspects of EITI implementation including consolidation of data, materiality, reconciliation, confidentiality, funding of MSG and CSOs, role of civil society, revenues and benefits to communities, company engagement, artisanal and small-scale mining, among others. Finally, there is evidence of actions taken to address gaps, such as initiating partial reconciliation for material companies which was piloted in the 2nd EITI despite existing barriers to taxpayer confidentiality. The development of roadmaps for contracts and beneficial ownership and the development of the outreach dissemination plan are also evidence of follow up on recommendations. There is an opportunity for clarity on how the MSG has prioritised key recommendations from the last EITI Report and reflected follow up actions into the annual work plan.

The International Secretariat’s assessment is that Requirement 7.4 is mostly met. The MSG’s outcomes and impact template considers that the objective of ensuring regular public monitoring and evaluation of EITI implementation, including an evaluation of whether the EITI is delivering on its goals, with a view to ensuring public accountability of the EITI, is mostly met. Some stakeholders expressed during consultation that significant work has been dedicated to drafting the progress report. The international Secretariat acknowledges that the Angola progress report reflects a solid description of progress in activities and execution of the work plan. However, the limited progress on lifting barriers relative to tax payer confidentiality, there is scope to progress further on the impact of EITI implementation on the extractive governance and to reflect on whether it has been delivering on its goal. There is also scope for broader and more regular discussion, in particular with civil society, on the impact of EITI implementation so far. The objective of the requirement is therefore considered mostly met. Since Angola started implementing the EITI, the country has an annual progress report (APR) on the Angola EITI website, documenting activities and outcomes for the period 2021–2024. The report includes summaries of key activities and assessment of progress towards achieving the objectives outlined in the work plan and an overview of responses to recommendations from first EITI report. Furthermore, the report outlines the progress and challenges in achieving activities in the work plan and includes a report on actual expenses compared to the work plan budget. The APR has also highlighted future planning demonstrated through the incorporation of pending activities into the next work plan indicating a commitment to long-term progress in Implementing the EITI. Although stakeholders have shared their views on the impact of EITI implementation during consultations, there is limited evidence of reviewing the broader impacts of EITI implementation on governance. There is also limited progress in the comprehensive disclosure of payments and revenues from the extractive sector and in lifting barriers relative to tax payer confidentiality. EITI Angola has not clearly identified the impact of their work in the country (2021-2024 work plan define objectives, EITI Requirements, outcomes and activities – but not the impact of EITI implementation). The Annual Progress Report does not show a concrete reflection on the EITI’s contribution to broader reform and does not assess MSG’s efforts to strengthen the impact of EITI implementation on natural resource governance beyond the outreach activities conducted after the publication of the 1st EITI Report. Furthermore, the Annual Progress Report was approved by the MSG on 1st October 2024, following the formation of a dedicated working group composed of two representatives of Sonangol and a representative from civil society. However, there is limited evidence available on the type of contributions by these stakeholders as well as the extent of the discussions beyond the formal approval. There is also no evidence of broader consultation on the EITI impact or the elaboration of the Annual Progress Report. In a context where civil society representatives have expressed during consultation that the EITI process is not inclusive enough of civil society, the International Secretariat considers that there is a need for wider consultation in the process of monitoring of the EITI results and impact to fully fulfill the objective of public accountability.

The International Secretariat’s assessment is that Requirement 1.1 is mostly met. The MSG’s “Stakeholder Engagement” template considers that the objective to ensure a full, active and effective government lead for EITI implementation, through both high-level political leadership and operational engagement, as a means of facilitating all aspects of EITI implementation is mostly met. During consultations, stakeholders expressed that, in particular since President Lourenço came to power in 2017 and launched a series of governance reform, the government has demonstrated commitments towards transparency and that, since joining EITI, government representatives have been highly engaged in EITI activities and discussions and that the government is fully engaged in EITI. There are strong indicators of engagement of government and senior officials in the EITI process, including from the Ministry of Mineral Resources and Petroleum (MIREMPET) which chairs the EITI process and the other entities representing the government in the MSG. The International Secretariat also considers that the government of Angola has demonstrated willingness to progress gradually towards greater implementation of the Standard, as shown notably by the partial reconciliation effort which was piloted in the 2nd EITI Report and by the involvement of relevant government entities in the EITI process. However, the International Secretariat notes the persistence of significant legal barriers to transparency, the need to significantly progress on financial disclosures and that implementation would benefit from strengthened and faster actions in favour of disclosures, particularly from the Ministry of Finance. Furthermore, while a commitment has been noted to increase staffing of the national secretariat, the latter doesn’t have yet the capacity to effectively fulfil its role. In 2020, the President appointed the Minister of Mineral Resources and Petroleum, Dr Diamantino Pedro de Azevedo as the chair of the MSG. There are many public government statements in favour of EITI, such as during the participation of Minister Azevedo at the EITI Global Conference in Dakar in 2023, or by the Secretary of State for Oil and Gas, José Barroso, representing Minister Azevedo at the occasion of a press conference following publication of the 2nd EITI Report in 2024. Senior government officials are formally represented on the MSG from relevant entities and representatives from key government entities have participated in most MSG meetings (except the Ministry of Environment). In practice, the attendance list shows that the Chair is often represented at the MSG by the Secretary of State José Barroso. In addition to the MSG Chair, the stakeholder engagement Validation template highlights that the Ministry of Mineral Resources, Oil and Gas and the Ministry of Finance are represented by Secretaries of State and that the regulatory entities for Mining (ANRM) and for Oil and Gas (ANPG) are represented by the CEOs of the entities. The attendance list also shows that in practice the Secretary of State at the Ministry of Finance and the CEO of ANPG often delegate attendance to a representative. The attendance list also highlights that while the Ministry of Environment did not send a representative for most of the period, it did attend the last two MSG meetings in September 2024. Finally, the attendance list shows that government representatives attend technical working group meetings. Furthermore, the government provides financial support to EITI implementation. The work plan and the Annual Progress Report highlighted that EITI implementation for 2021-2024 was budgeted at USD 3.06 million from which 70% was budgeted as government funding, and that in practice the government has spent USD 1.33 million over the period (which corresponds to 43% of the total budget). The government provided funding to capacity building events such as the peer learning in Mozambique. The “Stakeholders Engagement” template also highlights that the government made available technicians and facilities for EITI operations, as well as logistic support to EITI MSG members, specifically those from civil society organisations living outside Luanda. Finally, the International Secretariat notes the existence of significant legal barriers to transparency such as tax-payer confidentiality and impediments for contract transparency. These constitute significant bottlenecks to financial disclosures which need to be resolved in order to fully implement the EITI Standard and the requirements for EITI reporting. There have been preliminary actions led by the government to resolve some of these bottlenecks, such as the creation of technical working groups and the drafting of a roadmap towards contract transparency. Stakeholder consultations highlighted participation to a working group on taxpayer confidentiality in 2023 and 2024 by representatives of the Ministry of Finance, Ministry of Mineral Resources, Oil and Gas, oil and gas companies, national secretariat and the Independent Administrator. The 2nd EITI Report compiled company systematic disclosure of some oil and gas companies and piloted a partial reconciliation between revenue data from the Ministry of Finance and payment data from one oil and gas company (TotalEnergies) and one mining company (Catoca), following an agreement between these two companies and the Ministry of Finance. Furthermore, the 2nd EITI Report indicates that the working group found that the most technically feasible route to solve the taxpayer confidentiality barrier would be through a legislative reform to be approved by the National Assembly. However, no clear step has been taken towards such a legal reform and the Ministry of Finance could not provide a likely timeline for the adoption of such a reform. The Ministry of Finance also reported on discussions to include an amendment to the General Tax Code to find a temporary way out for 2025, which would be a short-term temporary solution until the reform is implemented. However, there is no detailed information on these plans. Therefore, the International Secretariat considers that there is a need for strengthened and a quicker resolution in favour of disclosures, particularly from the Ministry of Finance, in the form of waivers or more active advocacy for legal reforms. The Angola EITI national secretariat provides support to the MSG but has faced capacity constraints in the period under review. The government has provided financial support for the EITI process with both cash grants and in-kind provision of office space and staff. However, the limited staffing of two positions at the national secretariat has constrained the level of support provided to the MSG. Stakeholder consultations indicated that national secretariat capacity constraints were the main reason for delays in circulation of documents and record-keeping. Insufficient staffing of the national secretariat is also highlighted as a key challenge in the MSG’s Annual Progress Report. In September 2024, the Minister of Mineral Resources, Petroleum and Gas authorised the recruitment of six additional staff for the national secretariat, although these positions had yet to be filled as of March 2025. In its comments to the draft Validation report, the MSG shared letters from the national secretariat requesting additional staff and corresponding technical profiles, although there is no evidence that these positions have been filled. The International Secretariat recognizes all the efforts by the government of Angola to engage in EITI but notes that there is scope for improvements, both on the speed of the lifting of legal barriers for taxpayer confidentiality and to ensure adequate capacity of the national secretariat and thus considers that the objective is mostly met.

The International Secretariat’s assessment is that Requirement 1.2 is fully met. The MSG’s “Stakeholders Engagement” template considers that the objective to ensure that extractive companies are fully, actively and effectively engaged in the EITI, both in terms of disclosures and participation in the work of the multi-stakeholder group, and that the government ensures an enabling environment for this, is mostly met. While most stakeholders have expressed during consultations that companies were fully engaged, some mining companies outside the MSG which are at exploration stage have shared that they were not highly involved in the EITI process since Angola joined EITI. While there is scope for companies to be more active in promoting EITI disclosures at the national level such as disaggregated payments and contract transparency, the International Secretariat considers that there is a high level of engagement of companies in EITI activities, both from state owned enterprises and private companies. Company representatives participate in EITI events, provide data for EITI reporting and appear to be actively driving the EITI process, although there is room for improvement in the use of EITI data. In the context of taxpayer confidentiality laws in Angola, the International Secretariat notes that many International Oil Companies (IOCs) systematically disclose payments in their global reports, with payment data disclosed by more companies systematically than disclosed from the government side. While the wider oil and gas constituency is engaged and coordinated through ACEPA which is representative of companies in the oil sector, there is scope to improve outreach and coordination in the mining constituency, an aspect which is assessed under Requirement 1.4. Evidence and consultations show that three key SOEs in the Angola extractive sector (Sonangol for oil and gas, Endiama and Sodiam for diamond) are highly engaged in the EITI process as MSG members and through active participation in EITI activities, in MSG meetings and public declarations . There is also evidence of attendance of SOEs to EITI events, often at very high level, such as at the 2023 Global Conference, EITI Board meetings and regional peer learning activities. Evidence shows that the oil and gas private sector is well coordinated and engaged in EITI through the association of oil and gas operators in Angola, ACEPA. Given the importance of the EITI, ACEPA has established an EITI Subcommittee, which is attached to ACEPA’s Legal Committee and meets regularly to provide updates on important points regarding EITI developments. The subcommittee also holds meetings with the National Secretariat regularly and the International Secretariat whenever necessary. Evidence also shows high level of attendance to MSG meetings and participation in EITI working groups and capacity building events. The mining company constituency is involved in EITI mainly through the diamond SOEs Endiama and Sodiam, who are full MSG members, as well as private mining companies Tosyali (iron ore) and Pensana (rare earths) who are alternate MSG members. Evidence shows regular participation to MSG meetings of the full MSG members and partial participation to MSG meetings of the alternate members. The diamond company Catoca (partially owned by Endiama) is also involved through EITI reporting. While the mining sector beyond diamond in Angola is nascent, there is no evidence of coordination of the mining sector beyond these companies with regards to EITI or active outreach by EITI implementation to key new players who are in the exploration phase, (See Requirement 1.4). In addition, during consultations with companies, it was highlighted that there are recent discussions about the establishment of a Chamber of Mines in Angola, although the timeframe for this is not clear. The International Secretariat, however. notes general support for EITI during consultation by several mining companies within and outside the MSG, including public declaration by company De Beers that Angola re-joining EITI is a breakthrough in raising the confidence in investing again in Angola. The Stakeholders Engagement template states that there are no obstacles to participation of companies in EITI. The International Secretariat notes that the tax-payer confidentiality laws in Angola are a barrier to companies’ full disclosure of payments in the extractive sector in Angola, especially for oil and gas companies, but notes that in this context several IOCs have systematically disclosed their payments in Angola in various format . The International Secretariat also notes that both TotalEnergies and Catoca have taken part in a partial reconciliation exercise in the 2nd EITI Report following agreement with the Ministry of Finance, although TotalEnergies did not provide some of the requested data related to some of the taxes as the information is considered not in the public domain. Other mining companies have demonstrated their willingness to disclose financial data by sharing payment data with the Independent Administration, which was not included in the 2nd EITI Report due to the agreement with the Ministry of Finance to limit the pilot reconciliation to the two major companies, as mentioned above. The International Secretariat therefore considers that companies demonstrated willingness to progress towards transparency and implementation of the EITI, although there is scope for strengthened actions and advocacy by companies in favour of more disclosures and legal reforms in line with the Standard.

The Secretariat’s assessment is that Requirement 1.3 is mostly met. The MSG’s ‘Stakeholders engagement’ template considers the objective of ensuring that civil society is fully, actively and effectively engaged in the EITI process, and that there is an enabling environment for this, as mostly met. Most CSOs and international partners expressed concern with the shrinking broad civic space in Angola. However, while recognising that the challenging general civic space was leading to cautious behaviours, all CSOs inside and outside the MSG confirmed their ability to express themselves freely and in a critical manner in relation to the extractive sector. CSOs also indicated during consultations that EITI process provided a platform for discussion of topics which were previously considered too sensitive such as debt related to oil backed loans. The International Secretariat’s view agrees with the MSG’s self-assessment and considers the objective as mostly fulfilled. While the International Secretariat recognises a challenging broad civic space context in Angola, the International Secretariat notes that civil society organisations are engaged in the EITI, in particular members of the TCHOTA platform, and EITI is viewed as having improved the ability to debate freely about the extractive sector in Angola. However, capacity building remains needed to fully achieve the objective in terms of actively engaging and advocating for disclosures or critical analysis of EITI Reports and of ensuring inclusivity of the broad civil society constituency in the EITI process. The International Secretariat has not identified breaches to the civil society protocol but notes some evidence of shrinking civic space that could potentially lead to breaches of the freedom of operations and therefore, invites the MSG to actively monitor developments. Furthermore, the International Secretariat has identified current challenges limiting the full civil society engagement including the need for more technical skills and funding and a lack of inclusivity of the broader civil society constituency. There appear to be broader constraints on freedom of the press and a resulting impact on freedom of expression, with a pattern of harassment and intimidation of journalists and CSOs expressing critical views of the government and there is evidence that a number of protests have been severely repressed by the police. Yet all of the documented examples of such crackdowns have largely related to political rights, cost of living, street vendor regulations and others, rather than extractive industry governance issues. Evidence suggests that Angolan CSOs substantially engaged in the EITI process have sufficient freedom of expression and exercise it by expressing constructive criticism and recommendations towards government on the EITI process and extractive industry governance. While there is no evidence of constraints on operations of CSOs substantially engaged in EITI, the International Secretariat notes that if provisions in the draft NGO law or in the recent Presidential Decree 214/24 are enforced in a restrictive way, it would introduce strict new registration and oversight procedures as well as funding restrictions which could in turn lead to breaches of the freedom of operations. To date however, CSOs substantially engaged in the EITI process appear to have been able to operate and access local and international funding freely, despite the limitations on fundings as mentioned above. There have been numerous reports of broader restrictions on freedoms of assembly and association in the 2022-2024 period, with credible reports that restrictions have focused on demonstrations critical of the government. These restrictions do not appear, however, to have affected CSOs substantially engaged in the EITI, who have effectively coordinated through an existing civil society platform (the TCHOTA movement) focusing on governance in the extractive industries, although there is scope to improve inclusivity of civil society outside the MSG as well as accountability mechanisms of MSG representatives towards the broader civil society constituency. Civil society does not appear to have faced any restrictions in its engagement in all aspects of the EITI process and appears to have used this space to engage in EITI implementation within its technical and financial capacity. Finally, CSOs appear to have leveraged EITI in order start a dialogue and strengthen their capacity on topics related to the extractive sector which were deemed too sensitive prior to EITI implementation such as debt transparency, or that were not the subject of debate, such as ASM. There is acknowledgement that EITI’s impact has so far been limited and that there is a need to strengthen civil society’s capacities to allow CSOs to fully leverage of EITI to achieve their objectives. A detailed assessment of requirement 1.3 has been made under Annexe A.

The International Secretariat’s assessment is that Requirement 1.4 is mostly met. The objective of this requirement is to ensure that there is an independent MSG that can exercise active and meaningful oversight of all aspects of EITI implementation that balances the three main constituencies’ (government, industry and civil society) interests in a consensual manner. As a precondition for achieving this objective, the MSG must include adequate representation of key stakeholders appointed on the basis of open, fair and transparent constituency procedures, make decisions in an inclusive manner and report to wider constituencies. The MSG’s “Stakeholders Engagement” template considers that this objective is mostly met. There were mixed views among stakeholders consulted about progress towards the objective. Several stakeholders conceded that the MSG member renewal practices had not been sufficiently documented but considered that the MSG was in the process of exercising multi-stakeholder oversight of the EITI process. Some civil society stakeholders also indicated that EITI implementation in Angola was not inclusive enough of civil society given the technical complexity of the exchanges combined with civil society’s capacity constraints. The International Secretariat agrees with the MSG’s self-assessment and considers that the objective is mostly fulfilled, given MSG members’ regular attendance at meetings, partly offset by weaknesses in MSG members’ coordination with their broader respective constituencies and de facto deviations from MSG’s ToRs in terms of mandate renewals and publication of minutes notably An MSG was initially established in 2021, following nominations processes conducted by each of the three constituencies in June 2021 (for civil society) and September 2021 (for industry). Angola’s EITI candidature application highlights that gender was one of the explicit considerations in the MSG nominations process. For government, the heads of ten government entities appointed their respective MSG members. . There is no documentation of the renewal of government MSG members in 2024, although government officials consulted explained that government MSG members held their EITI position based on their government positions. For industry, the MSG member nominations were split between the mining and petroleum sectors. For oil and gas companies, the Angolan Association of Exploration and Production Companies (ACEPA) coordinated nominations of the three of five industry MSG members (and alternates) from the oil and gas sector. It is unclear who coordinated the nominations of the two full MSG members and two alternates from the mining sub-constituency. There is no publicly codified procedure for nominations of MSG members from either sub-constituency. Industry stakeholders consulted explained that the ACEPA had held discussions to renew their three MSG members and alternates for another 3-year term in 2024, although there is no indication that the mining sub-constituency met to discuss the renewal of its MSG members in 2024. For civil society, the nominations in 2021 followed two different procedures. . The hybrid approach resulted in the appointment of seven MSG members and alternates as a result of a combination of the Tchota-coordinated process and the open call for expressions of interest, and of three MSG members and alternates from the pool of CSOs initially consulted by the Minister of Mineral Resources and Petroleum in 2021. The ‘Stakeholders engagement’ template notes that the civil society constituency met on 1 February 2022 to agree on their MSG representatives under the MSG’s structure defined in the ToR agreed in January 2022. There is lack of clarity over when the first MSG membership term ends, i.e. either in June 2024 or February 2025. Oil and gas companies indicated that their term was renewed in June 2024 at the MSG following discussion within ACEPA. Civil society MSG members also considered that their first 3-year term had expired in June 2024. They explained that it had not been possible to hold new MSG nominations given resource constraints but explained that they considered that their term had de facto been extended for another three years in May 2024, given that the MSG had discussed and agreed updated ToR that month. There is no available documentation of this tacit renewal of civil society MSG members’ terms in 2024, nor evidence of consultation of the wider civil society constituency on this renewal. Although three of the five alternate civil society MSG members have not attended any or most MSG meetings in recent years (see ‘attendance’), civil society MSG members still considered them to be officially MSG alternate members. However, one of the alternate civil society MSG members stated that they no longer considered themselves part of the EITI process and that they had left in the early stages of EITI implementation. The MSG’s Terms of Reference (ToR), agreed in January 2022, were revised in May 2024 with relatively minor updates related to the possibility to renew MSG members’ terms and defining key terms such as ‘beneficial ownership’. The provisions of the MSG’s ToR cover most of the aspects mandated by Requirement 1.4.b. There is no evidence of practice of per diems to date. The ToR includes a provision that MSG members must be guaranteed capacity building (Art 10) and liaise with their respective constituency (Article 12). Capacity appears to vary significantly across MSG members from different constituencies. Whereas government and industry MSG members appear sufficiently capacitated to engage in the technical aspects of EITI implementation, civil society MSG members appear to face significant technical capacity constraints to do so. Likewise, MSG members from the government and oil industry constituencies appear to liaise with their respective constituencies, whereas there is little evidence of MSG members from the mining and civil society constituencies coordinating with their wider constituencies. Regarding coordination, ACEPA’s EITI Subcommittee is coordinated by ExxonMobil and Azule Energy, while there is no evidence of existence of codified rules within the mining company sub-constituency or civil society constituency governing the coordination of the wider constituency for EITI implementation, including regarding nominations, outreach and accountability mechanisms within each constituency. Some civil society organisations outside the MSG considered that the EITI process was insufficiently inclusive of the wider civil society constituency, with no clear rules of coordination and possibility to engage. Similarly, consultations with mining companies and available evidence indicates that the mining industry involvement in the EITI is limited to those companies represented at the MSG, either full member or alternate. In addition, there appear to have been deviations from the MSG’s ToR in practice in the period under review, particularly related to notice of meetings and advance circulation of documents and record-keeping. The MSG’s ToR requires that it hold at least four ordinary meetings a year. Annexe 37 to the MSG’s ‘Stakeholder engagement’ template lists 12 MSG meetings between January 2022 and October 2024. The MSG’s ToR (Article 24) requires that minutes of all MSG meetings be agreed and published within ten days of the meeting. However, the Angola EITI website has only published minutes for seven of these meetings , alongside minutes of another three MSG meetings held in 2021. It appears that MSG meetings in 2022- early 2023 were at times convened less than ten days ahead of time as required by the MSG, with documents circulated with too short a notice for in-depth review. However, the situation appears to have improved in 2023 and 2024 according to consulted stakeholders. A majority of full MSG members have attended all MSG meetings during the period under review, based on the attendance lists provided in Annexe 37 to the MSG’s ‘Stakeholders engagement’ template. . Attendance at MSG meetings by alternate members was weaker, with a majority of industry and civil society alternates not attending the majority of meeting. Attendance from three of the five civil society MSG alternates (UFOLO, SITCABGOSEPS and SIMA) has been particularly weak. Although the MSG’s ToR (Article 22) states that each MSG member is required to attend at least 80% of MSG meetings every year and that Article 10 indicates that absence from 3 consecutive meetings or more than 50% of meetings in the year is considered abandonment of participation, MSG members consulted still considered these alternates to hold their MSG alternate seats, which constitutes a deviation from MSG’s TOR. The MSG’s ToR (Article 20) sets out the procedures for decision-making, which should be by consensus and, if consensus cannot be reached, by absolute majority vote. All decisions seem to have been taken by consensus in the period under review, according to available meeting minutes and MSG members consulted. To bridge the secretariat’s capacity constraints, the MSG established six Technical Working Groups in June 2024, for a two-year period according to the MSG’s ‘Stakeholders engagement’ template. The membership of the working groups is publicly disclosed, but there are no public records of their discussions. While there appear to exist weaknesses in the transparency and accountability in MSG members’ nominations and renewals, combined with gaps in some MSG members’ capacities and outreach to their broader constituencies, which prevents the objective of Requirement 1.4 to be fully fulfilled notably in terms of inclusive oversight, the MSG appears to be in the process of developing its multi-stakeholder oversight of implementation. Thus, on balance, the International Secretariat’s view is that a majority of technical aspects of Requirement 1.4 are in the process of being addressed and the objective is mostly met.

The International Secretariat’s assessment is that Requirement 3.1 is mostly met. The MSG’s ‘Transparency’ template considers the objective of ensuring public access to an overview of the extractive sector in the country and its potential is fully met. Stakeholders consulted did not express any views on the objective. However, the International Secretariat considers the objective as only mostly fulfilled, given weaknesses in the public availability of information on the extractive industries, including the largest projects in the country, especially in the mining sector. There are limited systematic disclosures on government websites providing an overview of the extractive industries. The 2022 annual reports of the two mining SOEs, SODIAM and ENDIAMA, provide some information on the diamond industry, including significant exploration activities. However, there do not seem to be comparable systematic disclosures covering developments in the petroleum, gold, iron ore, or manganese sectors. Angola’s 2022 EITI Report provides some information on exploration activities in the petroleum and mining sectors but does not provide a general overview of active key projects in these two sectors. Thus, it is unclear whether a description of key projects in the petroleum and mining sectors is available to the public. In its comments to the draft Validation report, the MSG shared a file for the mining sector with a list of main projects in the prospecting and exploration phase in 2022 but without a link to where such a file would be publicly accessible and without an overview of active key projects, and ANRM committed to improving availability and exhaustivity of the information in the next Angola EITI report. For oil & gas, the MSG shared a file listing oil licenses active in 2022 and signed after 2022, although without providing a link to where such a file would be publicly accessible and without a description of key active oil projects, beyond some information on each oil block, such as type of contract, phase (exploration vs production), operators and partners and some contractual dates. The MSG also shared in its published MSG comments a description of oil and gas projects in the research phase in Angola.

The International Secretariat's assessment is that Requirement 6.3 is mostly met. The MSG’s ‘Transparency’ template considers the objective of ensuring a public understanding of the extractive industries’ contribution to the national economy is mostly met. Stakeholders did not express any views on the objective. The International Secretariat’s considers the objective as mostly fulfilled, given the existing disclosures of extractive sector contributions to GDP, exports and employment and other systematic disclosures, but also noting the lack of public information on the value of government revenues from the extractive industries and the need to expand EITI reporting to comment on credible third-party estimates of informal extractive activities, such as artisanal and small-scale mining in gold and diamonds. There are systematic disclosures of some information on the extractive industries’ contribution to the economy from government and SOEs. The National Statistics Institute (INE) website publishes quarterly reports on the Gross Domestic Product (GDP), including a breakdown in the contribution of the petroleum extraction and refining sector and the diamond, metallic and non-metallic mining sector, in absolute and relative terms (see for instance the Q4 2023 report). The central bank, Banco Nacional de Angola (BNA), website publishes quarterly datasets on the evolution of Angola’s exports, including export volumes and values for crude oil, natural gas and diamonds, but not for the other extractive commodities exported (e.g. gold). Sonangol’s 2022 sustainability report (pp.99-101) provides the number of employees in the Sonangol group, disaggregated by each of the main business units, by gender and by position. There are some systematic disclosures of employment data by the two mining SOEs, including gender-disaggregated aggregated employment data from SODIAM EP (pp.31-32 of its 2022 financial statements) and employment data broken down between direct and indirect from ENDIAMA (pp.4,33 of its 2022 financial statements). Angola’s 2022 EITI Report provides the extractive industries’ contributions to GDP, exports and employment in absolute and relative terms as well as some information on the location of extractive activities. Given the challenges in ensuring comprehensive government disclosures of extractive revenues (see Requirement 4.1), the EITI Report does not provide the value of total government extractive industry revenues: it provides the value of petroleum tax revenues (4 revenue streams), diamond tax revenue (1 revenue stream), and ‘other tax revenue’, which includes common-tax revenues from both extractive and non-extractive companies, due to limitations of SIGFE (Integrated Financial Management System of the State) in extracting structured information by sector. A new accounting system has been developed with the support of the IMF, which will include segregate reporting components, as informed in the 2022 EITI Report. The EITI Report provides outdated estimates (from 2013-2014) of the number of artisanal mining in the diamond and gold sector and estimates of the value of artisanal diamond mining in 2013 but does not reference updated credible estimates of informal activities in the mining or petroleum sectors.

The International Secretariat’s assessment is that Requirement 2.1 is fully met. The MSG’s ‘Transparency’ template considers the objective of ensuring public understanding of all aspects of the regulatory framework for the extractive industries is fully met. Stakeholders consulted did not express any views on the objective. The International Secretariat’s view is that the objective of this requirement is fulfilled, given Angola’s use of EITI reporting to provide an overview of applicable laws and the fiscal regime, even if the comprehensibility and accessibility of these disclosures could be improved. There are limited systematic disclosures on the legal framework and fiscal regime in the extractive industries in Angola. The MIREMPET website publishes the full text of the MIREMPET statutes, the Mining Code and the Petroleum Activities Law, with another webpage providing the full text of relevant Presidential Decrees. Sonangol’s audited 2022 financial statements provide a description of the fiscal regime applicable to the SOE, including applicable laws and taxes (pp.19-38 of its 2022 financial statements). Angola’s 2022 EITI Report provides brief overviews of the legal framework and fiscal regime in the petroleum and mining sectors, including roles and responsibilities of relevant government entities and general fiscal terms. While the specific different contractual fiscal terms are not summarised in the EITI Report, there is sufficient information to understand the general fiscal regime. The 2022 EITI Report describes statutory subnational transfers in the mining sector and confirms they were not effective in 2022 but does not clarify whether there is any fiscal devolution in the petroleum sector (see Requirement 5.2). The 2022 EITI Report highlights some regulatory reforms. , but also references some laws and regulations that introduced reforms to the governance of the petroleum and mining sectors in recent years. Although this information could be summarised in a much more comprehensible manner in Angola’s EITI Reports, there is sufficient information in the reports to gain a basic understanding of relevant laws and regulations.

The International Secretariat’s assessment is that Requirement 2.4 is partly met. The MSG’s ‘Transparency’ template considers the objective of ensuring the public accessibility of all licenses and contracts underpinning extractive activities is partly met. Stakeholders consulted did not express any views on the objective but highlighted legal barriers and confidentiality clauses. The International Secretariat’s view is that the objective as still far from being fulfilled, given that government policy on contract disclosure has yet to be formalised and the lack of official publication of any extractive contracts to date (including those awarded or amended since 1 January 2021). There do not appear to be any systematic disclosures of information on contract disclosure in the petroleum or mining sector. Angola’s 2022 EITI Report provides an overview of legal and contractual barriers to contract disclosure in petroleum, but not in mining. The 2022 EITI Report does not yet codify the government’s policy related to public disclosure of mining and petroleum contracts and licenses, beyond reviewing legal and contractual confidentiality clauses hindering the publication of contracts. It clarifies that none of the active mining or petroleum licenses and contracts have been published to date but does not comment on the fact that four petroleum contracts have been published (unofficially) on the ResourceContracts.org portal. A government official consulted explained that there are no confidentiality provisions in national law that hinder publication of mining contracts but there are confidentiality provisions in the actual mining contract. It was confirmed that all mining rights (including exploration and production agreements) required the conclusion of a mining investment contract and that amendments of mining contracts tended to be rare. The official noted that the government was looking at contractual confidentiality provisions with support from lawyers but also noted that it was in the process of trying to understand what key terms would be of interest beyond what is in the mining code. There have been several new contract and license awards in both mining and petroleum since 1 January 2021, as listed in the 2022 EITI Report, yet none of these have been published to date. During consultations, a government official informed that some mining contracts have already been published in the National Gazette but the access to them is unclear. Some government officials consulted highlighted that the government decrees awarding each extractive contract and license were published in the official gazette (Diário República), A government official consulted explained that the main terms of mining contracts were published in the official gazette once the agreement was concluded, but the full text of contracts was not disclosed because of the cost of publishing such lengthy contracts. Angola EITI has not yet published a full inventory list of all active licenses and contracts in both mining and petroleum, indicating the number of annexes, amendments and riders for each. Angola EITI is in the process of developing an action plan on contract disclosure, with updates on the status of progress provided in the EITI Report.

The International Secretariat's assessment is that Requirement 6.4 remains not assessed, given that several encouraged aspects of this requirement remain to be addressed by Angola EITI. The MSG’s ‘Transparency’ template considers the objective of providing a basis for stakeholders to assess the adequacy of the regulatory framework and monitoring efforts to manage the environmental impact of extractive industries is mostly met. Stakeholders consulted did not express any views on the objective. However, the International Secretariat considers the objective as still far from being fulfilled, even if the initial efforts to disclose information on laws and regulations related to environmental impacts should be welcomed. There are limited systematic disclosures of information on the management of the extractive industries’ environmental impacts. Sonangol’s 2022 financial statements (pp.91-93) describe changes in Sonangol’s provisioning for decommissioning costs both as an investor and as a concessionaire in 2022. Angola’s 2022 EITI Report provides only limited information on the rules and practices related to managing the environmental impact of the extractive industries, with only a general description of requirements for oil and gas companies to contribute to abandonment funds, an overview of some laws and decrees related to managing environmental impacts, and an overview of environmental permitting of extractive companies. However, the EITI Report's review of extractive companies' existing publications about their sustainability efforts is welcome. Government stakeholders consulted explained that material companies had not reported all of the information requested by Angola EITI, such as on the environmental impacts of extractive activities, but that outreach to companies was continuing to improve their disclosures in future EITI reporting. Despite claims from a government official during consultations that all environmental impact assessments (EIAs) would be available online, this information could not be verified. There are opportunities for Angola EITI to strengthen its disclosures of rules and practices related to environmental impact management in the extractive industries.

The International Secretariat’s assessment is that Requirement 2.2 is partly met. The MSG’s ‘Transparency’ template considers the objective of providing a public overview of awards and transfers of oil, gas and mining licenses, the statutory procedures for license awards and transfers and whether these procedures are followed in practice is partly met. Stakeholders consulted did not express any views on the objective. The International Secretariat recognizes that EITI Angola has disclosed some information on the criteria for awards and transfers as well as an overview for awards and transfers, but also considers that the objective as still far from being fulfilled, given the lack of clarity and public disclosure around how technical and financial criteria should be assessed in mining and petroleum rights awards and transfers and the weaknesses in Angola EITI’s review of the practice of license and contract awards and transfers in the period under review. There are systematic disclosures of information on licensing in the petroleum sector. Sonangol’s audited 2022 financial statements (p.24) explain that Sonangol has right of first refusal on any transfer of participating interests from one company to another. An interactive map portal for the 2020 bid round was established by ANPG, although the International Secretariat could not access it, which provide approximations of the coordinates of all oil and gas blocks offered in the 2020 round. The ANPG website also provides information on the 2023 licensing round, including an overview of the legal framework, terms of reference and technical brochures on the petroleum blocks offered, as well maps in PDF format for the oil blocks. Angola’s 2022 EITI Report provides overviews of contract and license awards in petroleum and mining but only provides a review of licensing practices for mining, not oil and gas. In oil and gas, the 2022 EITI Report lists eight awards, six transfers and two extensions of oil and gas rights in 2022. The EITI Report provides a general description of the statutory allocation and transfer procedures as well as a list of documents to demonstrate the technical and financial capacities, albeit without clarity on how the documents demonstrating the technical and financial criteria should be assessed, nor an assessment of non-trivial deviations from statutory procedures in oil and gas rights awards and transfers in 2022. Although the MSG had agreed on a sampling approach to review licensing practices in the oil and gas sector, the oil and gas regulator ANPG did not cooperate in order to implement the MSG’s decision and did not provide access to the required documentation in order for the IA to conduct the review of practices in oil and gas rights awards, invoking confidentiality constraints. Eight oil and gas blocks were awarded through public tender in 2022, and the 2022 EITI Report briefly describes the bid criteria and provides a full list of bidders for each license awarded through bidding. In its comments on the draft Validation report, the MSG confirmed the list of financial and technical requirements from the EITI Report for oil and gas, such as for operators to have “experience in management of petroleum operations” and “possessing technical competence”, but without specifying how such requirements and competences would be assessed. The MSG in its comments also confirms that precise details on how the documents are evaluated should be requested from the Negotiations Department. In mining, the 2022 EITI Report confirms the number of mining license awards and confirms the lack of license transfers in 2022, with the annexes to the EITI Report providing the list of mining license awards in 2022. A government official consulted noted that there were many new applications for mining licenses in recent years, currently averaging around 60 new applications a month. The EITI Report provides a cursory description of the procedure for awarding and transferring mining rights, but without clarifying how the documents demonstrating the technical and financial criteria should be assessed. While confirming that mining licenses are awarded on a first-come-first-served basis, mining companies consulted explained that the specific technical and financial criteria assessed in the mining licensing process were not clearly communicated to companies at present and recognised the value of additional transparency on these criteria through EITI reporting. Mining companies consulted considered that improving systematic disclosures of license information should be a top priority for reform. A government official consulted stated that there were technical and financial criteria assessed in the award and transfer of mining licenses and explained the general types of documents assessed but not assessment process by ANRM. The official explained that there was no weighting to the different technical and financial criteria in mining license awards through first-come-first-served, only in public tenders (and there were no mining rights awards through bidding since 2019). In its comments on the draft Validation report, the MSG provided 4 documents to clarify how the technical and financial criteria in the mining sector are assessed by ANRM, notably detailing the list of questions to be checked in the financial and technical evaluation, the checklist for project evaluation as well as a model declaration for financial capacity and a model for technical opinion form. The International Secretariat welcomes this additional information although it is unclear whether these documents are publicly accessible. The 2022 EITI Report includes an assessment of non-trivial deviations in only two of the 62 mining rights awards in 2022, highlighting deviations although not clarifying whether these are considered trivial or not. Yet a government official consulted explained that ANRM had not been consulted in the MSG’s decision to select these two mining license awards for review and explained that the selection of these two mining licenses was problematic as ANRM was not aware of why these two licenses were selected for review. In its comments on the draft Validation report, the MSG indicated that the 2 processes were under the responsibility of Endiama, the Directorate of Mineral Resources and Ferrangol with ANRM later assuming responsibility for extending the licenses. Therefore, ANRM was still in the process of gathering information on the processes that took place before its creation. The MSG confirmed for both licenses that while some documents were available some were not or only partially available in each case. On one license the MSG states that due to these limitations the information is insufficient to conclude about the existence or not of deviations, and on the other license the MSG states that the missing information is not material and that no deviations have been found. This information was published by the MSG on the EITI Angola website as part of its comments on the draft Validation report. There were, however, no additional comments on the process followed by the MSG to select these 2 licenses for the purpose of evaluating potential deviations.

The International Secretariat’s assessment is that Requirement 2.3 is mostly met. The MSG’s ‘Transparency’ template considers the objective of ensuring the public accessibility of comprehensive information on extractive industry property rights is mostly met. Several companies from the mining sector highlighted that it was key for Angola to strengthen transparency of the license register. The International Secretariat’s view agrees with the MSG’s self-assessment in considering the objective as mostly fulfilled, given that EITI Angola has published information on active petroleum and mining licenses but with gaps in public information compared to EITI Standard requirement. There are limited systematic disclosures of license data in the petroleum sector, but there is no evidence of systematic disclosure in mining. The report and a government official informed that the ANPG website provides high-definition and interactive maps of all active oil and gas blocks although the International Secretariat could not access it, while the maps in PDF format for the oil blocks are available. A government official consulted explained that ANRM maintained a comprehensive paper-based mining license register, but that this information was not yet available online pending the launch of the new mining cadastral portal currently under development. Angola’s 2022 EITI Report provides some information on active petroleum and mining licenses and contracts. In oil and gas, the 2022 EITI Report provides the license names, operator and partner names and their respective participating interests, dates of award, commodities covered for all active licenses and contracts. Geographic coordinates are provided for all but two of the oil and gas blocks that were active in 2022, which are marked as active in 2022 but abandoned or extinguished in 2023. In its comments on the draft Validation report published on EITI Angola website, the MSG shared the coordinates of one of the blocks and clarified that the other block was not abandoned as its area was incorporated into another block . The MSG also shared a map of abandoned blocks, although no link was provided as to where this file is publicly accessible. During consultations, a government representative indicated that the geographic coordinates would be available on the ANPG interactive maps, although the International Secretariat was unable to access them as the link does not seem to work. However, dates of application and expiry are not provided for any of the active oil and gas licenses. For the prospection blocks awarded in 2022 the EITI Report indicates that they have a 5-year prospection period. In its comments on the draft Validation report, the MSG shared a list of active oil licenses in 2022 in excel file, although no link was provided as to where this file is publicly accessible. However, the International Secretariat notes that in this file application dates are still missing for all the licenses and expiration dates are missing for 22 out of 39 licences listed as active in 2022. In mining, the 2022 EITI Report provides information on active exploration and production licenses, including company name, license number, dates of award and expiry, and commodity covered. Dates of application are only provided for a minority of active mining licenses, while geographic coordinates are not publicly disclosed for any mining license. A government official consulted explained that the coordinates of mining licenses and contracts were published in the official gazette, although these had not yet been reviewed by Angola’s EITI reporting. The EITI Report refers to ongoing work to establish a modern online cadastre in the mining sector but does not comment on any similar efforts in the petroleum sector (if any). The Angola’s 2022 EITI Report provides an update on the status of progress in building a mining cadastral portal, government stakeholders consulted explained that a beta version of the mining cadastre was expected to be piloted in early 2025. Mining companies consulted noted that the establishment of a modern online cadastral portal would be a “game-changer” for Angola in improving transparency on mining licenses.

The International Secretariat’s assessment is that Requirement 2.5 is partly met. The MSG’s ‘Transparency’ template considers the objective of enabling the public to know who ultimately owns and controls the companies operating in the country’s extractive industries as partly met. Stakeholders consulted did not express any views on the objective. The International Secretariat’s view agrees with the MSG’s self-assessment in considering the objective as still far from being fulfilled, given the lack of an enabling legal framework for beneficial ownership data collection and disclosure, and the limited piloting of beneficial ownership disclosures through EITI reporting to date. There are limited systematic disclosures of legal or beneficial ownership data in Angola. The Company Single Window (Guiché Único da Empresa) portal provides some basic company information for some companies, including the identity and general indication of the level of ownership of shareholders. However, a FATF evaluation report published in June 2023 indicates that the level of this information is limited with no mechanisms to ensure information is accurate or up to date. Angola’s 2022 EITI Report provides a brief overview of applicable laws and regulations related to beneficial ownership transparency in Angola. It demonstrates that an enabling legal and regulatory environment for the government’s collection and public disclosure of beneficial ownership information on extractive companies has not yet been established. However, there appear to be definitions of the terms ‘beneficial owner’ and ‘politically exposed person’ in Angolan legislation in Article 3(9) of Law on Preventing and Combating Money Laundering, the Financing of Terrorism and the Proliferation of Weapons of Mass Destruction. The MSG of EITI Angola also approved a definition of BO in its revised MSG ToR in May 2024. Beneficial ownership information has not yet been requested from all companies holding or applying for mining and petroleum rights, given the lack of a legal framework. Angola EITI piloted beneficial ownership data collection for the first time in the 2022 EITI Report. Stakeholders confirmed that all material reporting companies were requested to provide BO data through the reporting template. The 2022 EITI Report discloses the legal owners of the three SOEs, 6 IOCs (but without the specific % ownership for the legal owners of the 6 IOCs that are subsidiaries of publicly listed companies, although company representatives confirmed that these six companies are 100% owned by their listed parent company) and 2 private oil companies (although not specifying the percentage of ownership for one company – Somoil - and providing partial information on the company owners for the other company ACREP). With regards to ownership for the SOEs, Sonangol EP and Sonangol P&P are marked 100% owned by the State, Endiama is marked 99% owned by the State and 1% owned by Enditrade without providing BO data for Enditrade. With regards to ownership of the six private IOCs, the parent company are marked as publicly listed, including the names of the stock exchanges where they are listed but not a specific link to their regulatory filings. With regards to the two private oil companies Somoil and Acrep, some information on BO is provided, although there is no comment with regards to the exhaustivity of this information. There are no BO disclosed for private mining companies, and there is no ownership information on several private oil companies marked as material (Chevron, Galp, SSI, NIS Naftgas, INA and Prodoil). The quality assurances required for beneficial ownership disclosures are not described in the 2022 EITI Report.

The International Secretariat’s assessment is that Requirement 2.6 is mostly met. The objective of this requirement is to ensure an effective mechanism for transparency and accountability for state-owned enterprises (SOEs) and state participation more broadly through a public understanding of whether SOEs’ management is undertaken in accordance with the relevant regulatory framework. The MSG considers that the objective is fully met. Stakeholder consultations and available documentation indicate that this objective has been mostly fulfilled. Three of the main SOEs operating in the extractive sector were identified and are publishing key data through their financial statements. However, important information, such as the terms of equity interests in subsidiary companies and projects (Sonangol, ENDIAMA & SODIAM), as well as the terms of outstanding loans (Sonangol), are not comprehensively disclosed. Other important information such as third-party financing (ENDIAMA) and reinvestments (ENDIAMA) is missing. Likewise, the materiality threshold used to select these SOEs did not consider Catoca as an SOE, despite it being 59% state-owned in 2022. However, Catoca was included as a material company and for the pilot reconciliation. Consulted government stakeholders confirmed that there were no other SOEs in the extractive sector that were omitted. Oil and gas sector Sonangol The 2022 Angola EITI Report confirms that the only SOE in the oil and gas sector is Sonangol. Rules regarding the financial relationship between the government and Sonangol are described in the report, including the distribution of profits, retained earnings and reinvestments, though Sonangol’s statutory right to third-party financing is unclear. Consulted government stakeholders confirmed that Sonangol is able to raise funds through third parties, subject to Ministry of Finance approval. In terms of financial relations in practice, the report notes that Sonangol decided not to pay any dividends to the state in 2022. Consulted government stakeholders explained that Sonangol’s 2022 expected dividend payment was offset by debt repayment in the fiscal year. These stakeholders added that other tax payments made by Sonangol, including those related to the states in-kind revenues from the sale of oil to government were clearly noted in their annual reports (See Requirement 4.2). Figures on tax offsets, retained earnings, reinvestments and third-party financing can be found in Sonangol’s financial statements. There is, however, a need of increased clarity on the link between financial transactions of Sonangol with the state and this debt offsetting mechanisms (See Requirement 4.5). Sonangol’s 2022 financial statements provide an overview of the SOE’s ownership in oil and gas companies, including a list of subsidiaries and affiliates recognised in its balance sheet, albeit without a description of the terms attached to each. The 2022 financial statements also list the 14 blocks in which Sonangol holds a participating interest that are at the production phase, which appear to be held on fully paid terms. Consulted government stakeholders confirmed that these 14 production blocks were joint ventures between Sonangol and private companies held on fully paid equity. On the exploration side, the statements describe the 17 blocks in which Sonangol holds a participating interest, noting the carried interest terms attached to the participating interest in exploration. Some information on loans taken out by Sonangol are provided through EITI reporting, but it is not clear how these loans are backed. Sonangol’s audited financial statements are publicly available and the 2022 sustainability report, describes the SOE’s governance structure, including a company organogram and the composition of its Board of Directors. Information on Sonangol’s ethics and compliance policies, including on conflicts of interest and anti-corruption is also provided in this sustainability report. Mining sector SODIAM SODIAM’s financial relations with the state are described in its financial statements as well as through EITI reporting. SODIAM is obligated to distribute dividends to government, but it is unclear which set of laws govern this distribution. Consultations with government stakeholders indicated that dividend distribution is governed by Law 31/18, but EITI reporting notes these rules as following the Bridge Financing Agreement between SODIAM and the Ministry of Finance. In practice, values related to retained earnings, dividends and third-party financing are published in the 2022 EITI Report as well as reinvestments in SODIAM’s audited financial statements. The 2021-2022 EITI Report notes that SODIAM did not pay dividends in 2022. Consulted government stakeholders clarified that SODIAM will pay dividends for 2022, but that these had not been made at the time the EITI Report was written. The distribution of this dividend depends on the approval of MINFIN. Angola MSG is invited to provide documentation that SODIAM’s 2022 dividend to government was paid. EITI reporting lists SODIAM’s shareholdings in subsidiary companies but the terms attached to each equity interest are not clear nor are potential changes in the level of ownership of these companies in 2022. SODIAM’s participating interests in mining projects are described in the 2022 EITI Report but the terms of these agreements are not clear. SODIAM’s financial statements indicate that SODIAM EP has financial obligations on behalf of two subsidiaries of ENDIAMA (Victória Holding Ltd and Empresas Mineiras), implying that these are forms of SODIAM loans to these two ENDIAMA subsidiaries, although this is not explicitly stated. The terms of these loans are not described. The 2022 EITI Report also briefly mentions a loan agreement with BIC. The terms of this loan are described, and the EITI Report notes that the Ministry of Finance has backed this loan of USD 147.5 million with a sovereign guarantee. SODIAM’s annual financial statements can be found on the Ministry of Finance website as well as SODIAM’s own website. These statements are available from 2021 onward and contain the full set of financial statements, including notes. EITI reporting further details SODIAM’s Board of Directors and Code of Conduct but there is no mention of other corporate governance information, or rules or practices related to operating and capital expenditures, procurement and subcontracting. ENDIAMA EITI reporting contributes to the public’s understanding of ENDIAMA’s financial relations with government. Considering the lack of full financial statements published by the SOE, understanding these financial relationships without EITI reporting would be incomplete. In practice, the value of ENDIAMA’s retained earnings and dividends are published on Ministry of Finance website in financial statements, indicating that there were no dividends paid in 2022, although during consultations, a company representative informed that dividends were paid in 2022. ENDIAMA’s 2022 main financial items appear to indicate that ENDIAMA did not pay a dividend to government in 2022 and the Angola MSG is invited to comment on whether this occurred. However, figures on third-party financing and reinvestments are not available. EITI reporting lists ENDIAMA’s ownership in three subsidiary companies but does not list equity interests in these subsidiaries, nor the terms attached to each equity interest. EITI reporting also lists 15 participating interests in projects for ENDIAMA. Changes in participation are not indicated for 2022 nor are the terms attached to participation in each project clear. Loans or loan guarantees to companies have not been disclosed but there is no evidence that these occurred. ENDIAMA’s annual financial statements can be found on the Ministry of Finance website. These statements are available from 2021 and only contain the main financial items of the financial accounts, such as its balance sheet, income, statement, cash flow statement and auditor’s report. EITI reporting further details ENDIAMA’s Board of Directors and Code of Conduct but there is no mention of other corporate governance information, or rules or practices related to operating and capital expenditures, procurement and subcontracting. In its comments to the draft assessment, the MSG provided references to relevant legislation and regulations for ENDIAMA and SODIAM that include provisions describing applicable rules regarding the financial relationship between the government and SOEs. While the comments clarify some rules, further information would be needed to conclude that the relevant legislation addresses all aspects of Requirement 2.6 related to rules to ensure public understanding of the relevant regulatory framework in line with the objective of this requirement. The MSG’s comments also provide some information on ENDIAMA’s practices related to the financial relationship between the government and the SOE, such as information on the dividends generated in 2022 and clarification that “no third-party financing or reinvestments were made in the reporting period”. The comments provide the amount of dividends and note that the payment for the 2022 fiscal year was made in 2024. This information does not appear to be publicly available, but the Secretariat’s understanding is that it might be included in the 2024 annual financial statement once it’s compiled. In its comments to the draft assessment, the MSG provided links to the 2022 ENDIAMA reporting (here and here), but did not specify relevant pages or provide relevant data to confirm that all aspects of Requirement 2.6 related to practices are addressed through financial statements. Review of the recent annual financial statement (2023 FY) showed that reporting became more granular compared to previous years, with more detailed information available to the public. Additionally, the MSG comments provide some clarifications on SODIAM’s practices related to the financial relationship between the government and the SOE, such as information on the dividends. It is noted that “no dividends were distributed in the periods analysed”. The comments also indicate that further information on practices is available in the annual reporting but does not specify relevant pages or provide specific data to confirm if all aspects of Requirement 2.6 related to practices are addressed through annual reporting. The MSG comments do not appear to address the state participation in the oil and gas sector.

The International Secretariat's assessment is that Requirement 4.2 is mostly met. The MSG considers that the objective to ensure transparency in the sale of in-kind revenues of minerals, oil and gas to allow the public to assess whether the sales values correspond to market values and ensure the traceability of the proceeds from the sale of those commodities to the national Treasury is mostly fulfilled. Stakeholder’s have not expressed views with regards to the objective during consultations but confirmed that only oil is subject to in kind revenues. The International Secretariat considers that the objective is mostly fulfilled. Angola discloses volumes of the state’s in-kind oil revenues by blocks and by buyers, as well as values of the state’s in-kind oil exports and sales to the domestic refinery. However, the values are only provided in more aggregate form and not disaggregated by buyer and there is an unexplained inconsistency between export and domestic volumes. There is also insufficient explanation for public understanding of the actual financial flows between ANPG, Sonangol and the Ministry of Finance relative to the state in kind revenues and their rationale, preventing achievement of the objective. There are also significant gaps regarding the transparency of oil-backed loans repayments in oil shipments (assessed under Requirement 4.3) and in the absence of disclosure and reconciliation of in-kind revenues by paying company (assessed under Requirements 4.1 and 4.9). Angola’s 2022 EITI Report concludes that the state collects in-kind revenues in crude oil, but not in natural gas or minerals (although the Mining Code overview states that the government participates “in-kind in the mineral product produced in proportions to be defined throughout the production cycles”). The report describes oil in-kind revenues as the share of crude oil belonging to the ANPG as National Concessionaire. It highlights that these revenues accounted for ~11 BUSD in 2022, i.e. ~55% of government direct oil revenues, which makes them significantly material. It confirms that Sonangol commercialises the state’s in-kind revenues, either for export or to Sonangol refinery. It describes the different types of contracts in the oil and gas sector which indicates the production sharing split in PSCs and the lack of in-kind revenues from association contracts. The EITI Report presents volumes of these oil production rights of ANPG (~105,7 Mbbl, i.e. 25% of total production rights), disaggregated by blocks. It also presents oil exports of ANPG both in volumes (~100,9 Mbbl) and value (~10,35 BUSD). Other companies’ production rights and exports are also presented in a similar way, including Sonangol. Furthermore, ANPG’s export are disaggregated by buyer, as well as by crude, but only in volumes and not in values. Finally, regarding domestic sales, it presents the volume (~3,8 Mbbl) and value (374 MUSD) sold by ANPG to the Luanda Refinery. It is worth noting that Sonangol export volumes (~59,3 Mbbl) are also presented disaggregated by buyer, although these are understood to be Sonangol’s rights from equity participation and not the states in-kind revenues of ANPG. Sonangol’s production sold to Luanda refinery is also disclosed (~13,8 Mbbl valued at ~1,4 BUSD). It is unclear why the sum of ANPG export and ANPG domestic sale does not exactly match exactly ANPG’s oil production rights, and whether these numbers are entitlements or actual liftings. The Report does not provide information on the process for selection of buyers. Oil-backed debt: Angola’s 2022 EITI Report describes 3 oil-backed loans that meet the EITI definition of resource-backed loans. The EITI Report provides the aggregate value of debt servicing of 2 oil-backed loans in 2022, but does not describe the terms of the loan, specific repayment modalities, and discloses insufficient data on volumes and values of crude oil deliveries for each loan repayment and no disaggregation by buyer. This impacts the overall objective of traceability of proceeds from in-kind revenues and allow the public to assess whether the sales values correspond to market values. It also discloses insufficient information on the Lumiar Finance loan retired in 2022. (cf also Requirement 4.3). ANPG commission: The overview of Presidential Decree 289/19 in the EITI Report describes the process for transferring the proceeds of the sales of the state’s in-kind revenues, net of debt servicing and of ANPG’s commission, to the single Treasury account. It notes that the reference price for calculating ANPG’s entitlements is the oil price in the national budget, not the market price unless it is lower. It also indicates that ANPG’s commission (consignment) on sales of the state’s in-kind revenues are set at 5%, received as a budget transfer not as a withholding on crude oil sales proceeds, In 2022 the EITI and ANPG Reports indicate that it’s equivalent to 5% of oil sales at 59 USD/bbl, and shows the amount of the ANPG’s commission of ~314 MUSD, as well as accounts receivable in 2022 and 2021. Transfers from Sonangol: Sonangol’s 2022 financial statements disclose the value of its transfers of the proceeds of its oil sales on the state’s behalf to ANPG (p.78), but no information on the volumes and values of crude oil sold on the state’s behalf. Sonangol statements indicate that transactions with ANPG related to oil sales on behalf of the state dropped to zero in 2022 as the proceeds of those sales were retained by Sonangol in 2022 to off-set its tax credits (see Requirements 2.6 and 4.5). However, during consultations, stakeholders explained that ANPG owns the state oil but only receives a 5% commission as budget transfer (see above), Sonangol markets the state oil in exchange for a marketing fee but that proceeds of these sales don’t go through Sonangol and are directly paid by the buyer to the escrow account managed by the Ministry of Finance. Given this setup and taking into account the above disclosures and the offsetting of Sonangol tax credits by the proceeds of those sales in the context of transactions with ANPG, the International Secretariat’s view is that there is insufficient explanation for public understanding of the actual financial flows relative to state in-kind revenues between ANPG, Sonangol and the Ministry of Finance and their rationale. Finally, the 2022 Report has attempted a pilot reconciliation for only one oil company (TotalEnergies) as part of the data quality assurance, but only reconciles some tax payments in cash and does not seem to have attempted to reconcile in-kind payments or disclose disaggregated in-kind payments by companies beyond what is systematically disclosed by companies, despite their significant materiality in the revenues and the disclosure by TotalEnergies of its in-kind revenues in its company reporting (see Requirements 4.1 and 4.9) It is worth noting that commodity traders (which are also EITI supporting companies) Glencore and Trafigura have disclosed their purchases of crude oil from Sonangol in their 2022 payments to government reports.

The International Secretariat's assessment is that Requirement 4.5 is mostly met. The objective of this requirement is to ensure the traceability of payments and transfers involving SOEs and strengthen public understanding of whether revenues accruable to the state are effectively transferred to the state and of the level of state financial support for SOEs. The MSG considers that the objective is fully met. The Secretariat considers that the objective is mostly fulfilled given that significant information is published through financial statements of the SOEs and the EITI report but taking into account notably incomplete information on financial transfers from companies to SODIAM, lack of clarity on SODIAM’s withholding tax on sales and lack of clarity of the terms of the offsetting mechanism of tax and non-tax debt between Sonangol and the state. Stakeholders did not express particular opinions on the objective of this requirement during consultations. Oil and gas sector Sonangol EITI reporting explains the role of state-owned enterprises operating in the oil and gas sector and notes that the ANPG has collected all material revenues on behalf of the state from private oil companies since 2019. EITI reporting and Sonangol’s financial statements show that the SOE did not make payments to government in 2022. The 2022 EITI Report explains there is an agreement between government and Sonangol to offset non-tax credits against tax and non-tax debts and details a decomposition of the balance with the State at end 2022. According to the report, this debt offsetting mechanism is impacting various aspects of the relation between Sonangol and the State. First, the report states that the mechanism has offset several lines in the transactions between ANPG and Sonangol (the sale of crude oil in international market, the purchase of crude oil form ANPG and the sale of crude oil to ANPG), which makes it difficult to understand what each of these financial flows should have been without the offsetting. Second, the Report highlights that it impacts oil taxes paid, mentioning that the 2022 oil taxes had already been offset against non-tax credits and that an amount of the settlement in question was recognised as a receivable from the State (although it is not clear how much oil tax should have been paid by Sonangol if there was no offsetting, one table mentioning 676 095 + 199 357 billion AKZ while the text mentions 94.358 billion AKZ). Third, the report indicates that it offset fuel price subsidies, although the fuel price subsidies offsetting doesn’t appear in the detailed clearance summary table. Fourth, while the report indicates that Sonangol decided not to pay dividends in 2022, stakeholders indicated during consultation that dividends were not paid due to the debt offsetting mechanism, although there is no mention of dividend in the clearing of balances with the state in the EITI report and therefore lack of clarity as to why Sonangol did not pay dividend. Furthermore, during consultations, a development partner indicated that there are many cross debts between Sonangol and the State, and that more transparency is needed on how the government settles the debt with Sonangol. Therefore, on balance, the International Secretariat recognizes that there are many disclosures regarding the debt between Sonangol and the State in the EITI report and the Sonangol financial statement, but that there is scope to improve broad public understanding of this debt settlement mechanism. The Report indicates that a decision was taken in 2022 not to distribute dividends. EITI reporting does not indicate that there were other financial transfers between government and Sonangol. Payments from companies to Sonangol for its equity share are detailed in the SOE’s financial statements. Mining SODIAM SODIAM’s role is well-explained in the mining sector. SODIAM’s payments to government are disclosed in the 2022 EITI Report by revenue stream, as are the SOE’s revenues and expenditures associated with its extractive projects. EITI reporting confirms that SODIAM did not make dividend payments to government in 2022, despite operating at a profit, according to financial statements. The MSG is welcome to provide an explanation why dividends were not transferred to government. In its comments to the draft assessment, the MSG confirmed that “no dividends were paid in the period under review” but did not clarify the reason for it. Other transactions related to SODIAM’s operations with extractive companies are not reported upon in the 2022 EITI Report. However, during consultations, a government representative highlighted that SODIAM withholds a sales tax on behalf of the state on the diamonds marketed, but the corresponding financial flows between SODIAM and the state are not included in the 2022 EITI Report. ENDIAMA ENDIAMA’s role is well-explained in the mining sector. ENDIAMA’s payments to government are not disclosed through EITI reporting, though the SOE’s revenues from the diamond trading commission are disclosed in aggregate. ENDIAMA’s financial statements also indicate that it operated at a profit in 2022 but do not indicate whether a dividend was paid to government. EITI reporting confirms the lack of dividend payment to government from ENDIAMA in 2022 but do not include an explanation why the dividend was not paid to government. In its comments to the draft assessment, the MSG clarified that the dividend for the 2022 fiscal year was paid in 2024 (See Requirement 2.6). Payments from ENDIAMA’s six subsidiary companies to the SOE are provided in EITI reporting by company.

The International Secretariat's assessment is that Requirement 6.2 is mostly met. The objective of this requirement is that where state-owned enterprises undertake extractive-funded expenditures on behalf of government that are not reflected in the national budget, these are disclosed to ensure accountability in their management. The MSG’s transparency template considers the objective to be fully met. The Secretariat’s assessment is that the objective is mostly fulfilled, acknowledging the efforts to publish related information in the EITI report but given a definition of material quasi-fiscal expenditures (QFE) that does not reflect the full scope of these expenditures and incomplete information on fuel subsidies, the national urban planning and housing programme and scope for better public understanding of the participation of Sonangol in the servicing of the oil backed loans. It is encouraging that Angola MSG discussed which expenditures could constitute QFEs. The Secretariat holds a broader understanding of QFEs than what was employed in the 2022 EITI Report and considers Sonangol’s off-budget fuel subsidies and off-budget social housing debt as QFEs, as well as servicing of national debt by Sonangol if that is the case. There is no evidence that SODIAM or ENDIAMA took part in QFEs. In the Secretariat’s understanding, Sonangol takes part in the following: • Refinery subsidies – Since 2020, the refinery has been supplied by ANPG and others, including Sonangol. Sonangol supplies a portion of its own in-kind equity oil to Luanda Refinery. The report highlights that the method of calculating the price to be used for sales of crude oil to the Luanda Refinery is, since 2020, calculated on the basis of the average of the monthly quotations for Angolan crude oil. Since this means that the sale is made at market price, this may not be considered a quasi-fiscal expenditure • Sonangol off-budget fuel subsidies – The 2022 EITI Report outlines Sonangol’s financial interactions with the state in subsidising fuel sales. While the report describes the amount to be received by Sonangol at the end of the year with regards to subsidies, it also highlights that the movement in the amount to be received by Sonangol represent both the increase in the subsidy in 2022 and the decrease in the balance relating to the offsetting of tax and non-tax debt. They also disclose a transaction amount related to state subsidies in 2022, but it is unclear what it represents. Based on these disclosures only it is therefore difficult to ensure public understanding of the amount and terms of the fuel subsidies by Sonangol, which is considered by the International Secretariat as a quasi-fiscal expenditure. • Sonangol off-budget social housing (BUDHF) debt – Sonangol supported urban housing initiatives undertaken by government. To accomplish these social expenditures, Sonangol took out a loan from an international bank in 2014 and the state continues to reimburse this expenditure. Sonangol’s audited financial statements come with a ‘qualified’ opinion by the auditor. One reason for this qualified opinion is due to a lack of clarity around the timing of compensation for Sonangol’s QFEs related to social housing. It is also unclear what the related transaction amount for 2022 between Sonangol and the state disclosed in the report represents. There is therefore insufficient information for public understanding of Sonangol off-budget social housing expenditures, notably in terms of timing of compensation. The International Secretariat considers this expenditure as quasi-fiscal expenditure • Servicing of national debt – The 2022 EITI Report describes two types of oil-backed loan agreements. One involved China EximBank and the other with China Development Bank. A third oil-backed loan with Lumiar Finance was reported to have been “retired” in 2022, but further information on potential in-kind payments in early-2022 prior to retirement is not provided. During consultations, government stakeholders confirmed that Sonangol only markets the state oil in-kind revenues, with payments made to repay the loan directly sent from the oil buyers to the ministry of finance escrow accounts. There is however no confirmation in the EITI Report that Sonangol, which is no longer the national concessionaire, is no longer involved in the repayment of the oil-backed loan debt on behalf of the state, which otherwise would make this a quasi-fiscal expenditure. It is worth noting that some aggregate information on oil deliveries for the two outstanding loans is provided, but there is no information of amounts repaid by individual buying company to service the loan in the 2022 EITI Report and there is scope for better understanding the participation of Sonangol in the servicing of the oil backed loans (See Requirement 4.2 and 4.3). In its comments to the draft assessment, the MSG noted that QFEs were not applicable for SODIAM and further clarification was needed for ENDIAMA. The MSG comments do not appear to provide any clarifications on the QFEs for the oil and gas sector.

The Secretariat’s assessment is that Requirement 3.2 is mostly met. The MSG’s ‘Transparency’ template considers the objective of ensuring public understanding of extractive commodity production levels and the valuation of extractive commodity output as mostly met. Most stakeholders consulted did not express views on the objective. The International Secretariat’s view agrees with the MSG’s self-assessment in considering the objective as mostly met, given that production data are published in the EITI report but taking into account the lack of public disclosure of the values of production of Angola’s extractive commodities aside from crude oil and one diamond company’s production. There are some systematic disclosures of oil and gas production data. The ANPG website publishes monthly production volumes for crude oil and natural gas, but no production values. Sonangol’s 2022 financial statements (p.98) disclose the value, but not volumes, of Sonangol’s crude oil and petroleum product sales, disaggregated by product type. There are more extensive systematic disclosures of production data in diamond mining than in other types of mineral commodities. SODIAM’s 2022 financial statements (pp.14-15) provide aggregate 2022 diamond production volumes commercialised by Sodiam, broken down between industrial and semi-industrial production and 2022 diamond sales volumes by mining company and cooperative. SODIAM’s 2022 financial statements (pp.17-20) also disclose the value of diamond production traded in 2022, broken down between kimberlite and alluvial diamonds, by mining company and by cooperative. The volumes and values of rough diamonds supplied to Angolan cutting factories in 2022 is also provided (p.27). The systematic disclosures by ENDIAMA relate to the SOE’s own production rather than the broader national industry. ENDIAMA’s 2022 annual report (pp.4,29,34) discloses aggregate data on the SOE’s diamond production volumes in 2022, disaggregated between industrial and semi-industrial production, as well as the volumes and values of diamonds it sold in 2022. Angola’s 2022 EITI Report provides production volumes for crude oil, natural gas, diamonds, gold, ornamental stones, aggregates, iron ore, manganese. However, it does not provide production values for any of the extractive commodities produced in 2022 aside from crude oil, for which it does provide estimates of production value. It is worth noting that with regards to the natural gas, stakeholders have confirmed during consultations that it was sent to ANLG for free and that the LNG value at the exit of ALNG was reported in the EITI report. There is however no explanation in the EITI Report explaining the valuation mechanism of the natural gas from the field to ALNG, the potential value of the natural gas before it is transformed and whether some of it is used for domestic market other than LNG export. Although the value of production is not disclosed for other commodities in the mining sector, the value of a large diamond mining company’s production is disclosed, from which an estimated annual average price of diamond could be calculated given that the company in question (Catoca) accounts for around 65% of the country’s total diamond production according to the EITI Report. The production data on crude oil and natural gas is disaggregated by project, while the production data on diamonds, gold, iron ore and manganese are disaggregated by company. It is unclear whether the disclosed production data for gold, iron ore and manganese, which are nascent sectors, is comprehensive of all official extractive production data in Angola. Angola has not yet used its EITI reporting to disclose additional information on the methods for calculating production volumes and values. Mining companies consulted noted that several mining projects such as the Tosyali iron ore and the Pensana rare earths projects were still under development and were expected to start production in coming years. A government official consulted noted that diamonds were the only material commodity in the mining sectors.

The International Secretariat’s assessment is that Requirement 3.3 is fully met. The MSG’s ‘Transparency’ template considers the objective of ensuring public understanding of extractive commodity export levels and the valuation of extractive commodity exports as fully met. Stakeholders consulted did not express views on the objective. The International Secretariat agrees with the MSG’s self-assessment and considers the objective as fulfilled. The National Statistics Institute (INE) website publishes quarterly foreign trade reports (see for instance the Q1 2024 report), which provide export values for key exported commodity groups, but not volumes, disaggregated by commodity group (e.g. ‘Pearls; Precious Stones and Metals, Jewellery’) rather than by individual mineral commodity. There are more extensive systematic disclosures of export data in diamond mining, than in petroleum and other mineral production. SODIAM’s 2022 financial statements (pp.20-26) provide 2022 rough diamond export volumes and values, disaggregated by export destination, as well as the weighted average diamond sales price over 2020-2022. Angola’s 2022 EITI Report provides export volumes and values for crude oil, natural gas, diamonds, ornamental stones and gold. EITI Report also discloses exports of iron ore and manganese.

The International Secretariat’s assessment is that Requirement 4.1 is partly met. Stakeholder consultations and available documentation indicate that the objective of ensuring comprehensive disclosures of company payments and government revenues from oil, gas and mining as the basis for detailed public understanding of the contribution of the extractive industries to government revenues has not been fulfilled, which is consistent with the MSG’s self-assessment which considered that the objective is partly met. Confidentiality laws limit both government and companies from disclosing payments, even where companies are willing to disclose. This has limited the comprehensive unilateral disclosure of government revenues from extractives (as noted in Requirement 6.3), the selection of material payment streams and selection of material companies, and hence the comprehensive disclosure of company payments to government entities. Overall, this strongly limits any detailed public understanding of the contribution of the extractive industries to government revenues. So far, EITI reporting provides partial disclosure and reconciliation for only two out of 19 extractive companies. Consulted stakeholders confirmed challenges related to confidentiality provisions but highlighted the efforts related to piloting disclosures for the two biggest extractive companies as a significant achievement of the second EITI Report. The 2022 Angola EITI Report provides a general overview of the methodology used to collect data on company payments and government revenues. The report also details the legal constraints on government and company disclosure of disaggregated taxpayer information and reaffirms the MSG’s commitment to overcoming these challenges. The assessment finds that government only partially discloses extractive sector revenues by revenue stream. With regards to the selection of material revenue streams, this assessment concludes that not all material payment streams and thus reporting entities were selected, as full unilateral government disclosures and government revenues disaggregated by revenue streams are not available (see also Requirement 6.3). The 2022 Angola EITI Report identifies two common taxes, five oil and gas taxes and three mining taxes as material revenue streams. However, the report provides limited explanation on the materiality thresholds used to identify these revenue streams. The ‘Transparency’ template clarifies that the selected revenue streams were chosen based on data availability and were considered the most material by MSG members. Revenue streams listed in Requirement 4.1.c were not explicitly considered when creating the selection of material revenue streams. Despite their materiality, in-kind oil revenues paid by individual companies were not disclosed (beyond systematic disclosure by some oil companies). The Secretariat concludes that the determination of material revenue streams cannot be considered comprehensive. On the description of applicable revenue streams, this assessment finds that the overview of the legal framework and tax regime does not describe all applicable revenue streams comprehensively. With regards to the identification of relevant government entities, the EITI Report lists the selected government entities from which information would be collected. The publication of revenues disaggregated by revenue streams relies on what is available through public records (in budget execution reports) which aggregate some payment streams, except for Total Energies and Catoca. The level of disaggregation of revenue streams is hence deemed insufficient. On the selection of material companies, given the lack of access to data specifying the payees of revenues, the MSG agreed an alternative approach to selection of material companies based on production volumes. Fifteen companies, participating in eight oil and gas blocks and four mining companies exceeded the agreed cumulative threshold of 90% of total production for each sector and were thus considered material. The EITI welcomes that the MSG has tested an alternative to establishing materiality given the limitations set by tax confidentiality provisions, but it does not yet sufficiently allow public understanding if the material companies are correctly identified based on actual payments. Of those identified 19 companies considered material, two have submitted reporting templates for the 2022 EITI Report: TotalEnergies for oil and gas (~47% of production) and Catoca (~63% of production) for mining, which are noted to contribute with the highest relative share to production. The limitations of such an approach to selecting material companies are documented in the 2022 Angola EITI Report and Transparency Validation template. Stakeholder consultations indicated that while all material companies received the same templates, financial information was either not provided or not included in the EITI Report, except for TotalEnergies and Catoca, due to confidentiality provisions (except for two mining companies which submitted payments but were not disclosed as per the Ministry of Finance directive according to stakeholder consultations). It is welcome that the 2022 Angola EITI Report provides figures and links on the mandatory payments to government from several companies which follow EU, UK and Norwegian disclosure regulations to complement EITI reporting disclosures. Those companies are TotalEnergies, BP, ENI, Equinor, Galp, NIS Naftgas, Maurel & prom and INA. These data are disaggregated by project and by revenue stream category, but not by individual revenue stream, as required by the EITI Standard. For Sonangol, income tax payment to government data is available through annual audit financial statements. SODIAM discloses income tax and royalty payment, and ENDIAMA likewise publish payments to government, by revenue stream, in their audited financial statements (see here and here). The report reconciles some payments from TotalEnergies and Catoca but doesn’t reconcile oil in-kind payments from TotalEnergies. For the payments and revenues which were selected for reconciliation for TotalEnergies and Catoca, the data is disclosed by both the company and the MINFIN, except for some of the payments of TotalEnergies that were not in the public domain and were thus published only by the MINFIN. The disclosed data for reconciliation is disaggregated by each of the revenue streams and by project. However, due to reconciliation challenges, including currency differences and late government reporting, the reconciliation coverage was low and incomplete. With regard to total government reporting, only five revenue streams (Petroleum Income Tax, Oil Production Tax, Oil Transaction Tax, state in-kind crude oil revenue, Angola LNG) are reported individually and by block. On encouraged aspects of this requirement, beyond the publication the three SOE’s audited financial statements (see also Requirement 2.6), the 2022 Angola EITI Report does not comment on the public availability of other extractive company’s financial statements in Angola.

The International Secretariat's assessment is that Requirement 4.3 is partly met. The MSG’s ‘Transparency’ template considers that the objective to ensure public understanding of infrastructure provisions and barter-type arrangements, which provide a significant share of government benefits from an extractive project, that is commensurate with other cash-based company payments and government revenues from oil, gas and mining, as a basis for comparability to conventional agreements, to be mostly fulfilled. During consultations, stakeholders did not express any particular views on the fulfilment of the objective, except that debt transparency was a key issue. The International Secretariat considers that the objective is not yet fulfilled given that, while aggregate data on oil backed debt has been published, significant aspects have not been implemented, such as terms of the loans, repayment modalities and values of crude oil deliveries in service of oil-backed debt disaggregated by buyer. Angola’s 2022 EITI Report describes three oil-backed loans that meet the EITI definition of resource-backed loans. The MSG has not discussed the materiality of these loans but as noted later in this assessment, at least two of them are significant. The EITI Report provides the aggregate value of debt servicing of two oil-backed loans in 2022, but does not describe the terms of the loan, specific repayment modalities and discloses insufficient data on volumes and values of crude oil deliveries for each loan repayment and no disaggregation by buyer. It also discloses insufficient information on the Lumiar Finance loan retired in 2022. There are two of oil-backed loan agreements documented through EITI reporting – one with China EximBank and the other with China Development Bank (CDB). It notes that a 3rd oil-backed loan from Israel’s Lumiar Finance was “retired” in 2022, but without clarifying whether any repayments of crude oil took place in early 2022. The Report shows the total value of oil guaranteed debt servicing through shipments of oil (~USD 1.2bnUSD) and the total value of guaranteed debt servicing in cash and carried out directly through the treasury (~USD 2.1bn), demonstrating that oil deliveries for oil guaranteed debt service accounted for ~35% of total debt servicing in 2022. The stock of oil-backed public debt at the end of each month is disaggregated between China Eximbank and CDB (~USD 2.4bn and ~USD 13.6bn respectively at end 2022), but without volumes of oil supplied for repayments, or values of oil supplied for each loan. There is also no disaggregated data by individual company lifting the oil for the oil guaranteed debt servicing. Some consulted government stakeholders clarified that the Ministry of Finance (MINFIN) oversees the escrow account through which debt servicing payments flow and that each resource-backed loan has its own modalities, with MINFIN as the responsible government entity for overseeing the repayment of these loans. Furthermore, the 2022 EITI Report does not explain the terms of the oil-backed loans (including tenor, interest rate, repayment modalities, list of infrastructure projects if loans are tied to projects, etc). It notes that it was not possible to disclose details of the oil-backed loans because of MINFIN’s claim that the terms of the loans are confidential. The revised EITI Report notes that the Angolan government has committed to ‘limiting the confidentiality’ of public debt contracts from 2022, which the International Secretariat understands to mean to ensure at least partial disclosures of contracts being signed in the future, but that oil-backed loans predate this date. It also reiterates that there are no new oil-backed debt contracts signed after 2021. There are key opportunities for the EITI to take a proactive role in explaining the terms and repayment modalities of these significant loans, especially given that the contracts are not public. The EITI can play a role in informing the public on how the debt has been repaid over time, and what the overall implications these agreements have on the budget.

The International Secretariat’s assessment is that Requirement 4.4 is partly met. The MSG’s transparency template indicate that the objective is mostly met. Stakeholder consultations and available documentation indicate that the objective of ensuring transparency in government and SOE revenues from the transit of oil, gas and minerals as a basis for promoting greater accountability in extractive commodity transportation arrangements involving the state or SOEs has not been fulfilled yet. The 2022 Angola EITI Report provides a partial overview of the oil and gas sector’s transportation arrangements. While it covers third-party use of Angola’s gas pipeline network (PUG) and Sonangol’s transportation services, it lacks detailed information on revenue streams, tariffs, and specific transportation routes. For the oil and gas sector, the 2022 Angola EITI Report provides an overview the law regulating oil and gas transport licensing in Angola, but it does not clarify which transportation revenue streams are paid directly to the State from the licensing of oil and gas transport infrastructure. The 2022 Angola EITI Report describes the third-party use of Angola’s gas pipeline network (PUG) that is linked to Angola LNG, including oil companies’ payments to ANPG for the use of ANPG’s gas pipeline network. The report confirms that ANPG collects and retains revenues from third-party use of its gas pipeline network. It also explains that tariffs for using the gas pipeline network are calculated based on existing investment contracts between the regulator and operators. The report does not specify applicable tariffs for 2022 but mentions ongoing renegotiations of transport arrangements. While the report states that there were no payments for PUG use in 2022, it also notes that payment terms of PUG fees were unavailable due to investment contract confidentiality. Consulted government stakeholders confirmed that no payments were made in 2022. The 2022 Angola EITI Report also describes a second type of transportation arrangement in the oil and gas sector, related to the provision of transportation-related services to the oil industry by Sonangol’s Trading and Shipping business unit. The report briefly outlines the nature of transportation services provided by this unit and provides the aggregate value of Sonangol’s revenues from the provision of transportation services to third parties and the total crude oil volumes transported by Sonangol’s Trading and Shipping subsidiary. However, these data are not disaggregated by individual transportation route or arrangement. These figures are reflected in Sonangol’s 2022 audited financial statements, also in aggregate. It is unclear whether revenue from the provision of these transportation services to third parties represents a form of transportation revenues collected by Sonangol on behalf of the state or whether it is Sonangol’s own revenues. Angola MSG is invited to provide further information on this transportation arrangement. Available documentation does not appear to disclose additional information on the two types of revenues, such as a description of the transportation arrangements, a definition of relevant transportation revenues, or tariff rates and volumes of transported commodities. For the mining sector, the 2022 Angola EITI Report describes the award of a concession for the Lobito Atlantic Railway (LAR) in 2022 to a consortium of Mota-Engil, Trafigura and Vecturis, aiming to expand railway transport of mineral commodities to the coast. However, it explains that the MSG did not consider that this gave rise to material transportation revenues to the state in 2022, as the railway only began commercial operations in 2024 and due to a lack of robust data for the period under review. The report, however, presents the expected state revenues for the concession period. The view of the International Secretariat is that transportation revenues do not apply for 2022, but that they will starting 2024. Angola EITI should ensure that it publishes the details in terms of revenues, tariff rates and volumes, if possible, through routine government disclosures.

The International Secretariat’s assessment is that Requirement 4.7 is partly met. The objective of this requirement is to ensure disaggregation in public disclosures of company payments and government revenues from oil, gas and mining that enables the public to assess the extent to which the government can monitor its revenue receipts as defined by its legal and fiscal framework, and that the government receives what it ought to from each individual extractive project. The MSG’s transparency template considers that the objective is partly met. Available documentation indicates that this objective has not yet been met. The 2022 Angola EITI Report provides only partial disaggregation by revenue stream, individual company and government entity. While the MSG has identified the project level and revenue streams levied on project-level, actual disaggregation by company and project is outstanding, as well as the list of projects covering several interconnected agreements. As noted in Requirement 4.1, the level of disaggregation by revenue type is insufficient, with data available over payments to government entities for a limited number of taxes. Similarly, this assessment notes that the government revenue data in the 2022 EITI Report is not disaggregated by government entity, revenue stream or company, and is disaggregated by project (block) for some, but not all, oil and gas revenue streams. Details on the available level of disaggregation are available in the transparency template. Angola EITI defined the project level in its 2021 Report and provides a categorisation of seven revenue streams levied at a project level and six revenue streams levied at a company level. The International Secretariat could not locate the list of projects covering several interconnected agreements, which would be needed to identify the actual applicable projects. Furthermore, while EITI reporting has disaggregated payments by project, it has not done so yet by project and company. As noted in Requirement 4.1, existing payments to government reports provide an opportunity to draw on existing disclosures by company and project (albeit more aggregated payment streams) to complement current EITI disclosures.

The International Secretariat’s assessment is that Requirement 4.8 is fully met. The MSG’s transparency template considers the objective to be fully met. Stakeholder consultations and available documentation indicate that the objective of ensuring that public disclosures of company payments and government revenues from oil, gas and mining are sufficiently timely to be relevant to inform public debate and policymaking has been fulfilled, given timely publication of the 2022 Angola EITI Report. The 2022 Angola EITI Report was published in September 2024, within 21 months of the end of the fiscal period covered. The report confirms that the MSG approved the reporting period. In regard to the timeliness of financial disclosures of state-owned enterprises operating in the extractives sector, Sonangol, SODIAM and ENDIAMA publish annual reports in a timely manner. Sonangol’s, SODIAM’s and ENDIAMA’s 2022 financial statements were published within six months of the end of the reporting period.

The International Secretariat’s assessment is that Requirement 4.9 is partly met. The MSG’s transparency template considers that the objective has been partly met. Stakeholder consultations and available documentation indicated that the objective of ensuring that appropriate measures have been taken to ensure the reliability of disclosures of company payments and government revenues from oil, gas and mining has not yet been fulfilled. This is due to the limited disaggregated disclosures by payment and company, which meant that reconciliation could not be conducted in a comprehensive manner. Additionally, the EITI Report lacks a statement of the IA on the comprehensiveness and reliability of the financial data on government revenues. The International Secretariat notes that limited progress on reconciling revenue streams has been made in the second report and notes the review of existing audit practices for government and companies. The 2022 Angola EITI Report provides a brief overview of relevant laws related to audit and assurance procedures of government entities and private companies. Future EITI reporting should clarify if the statutory requirements are in line with international standards. In its comments on the draft Validation report published on EITI Angola website, the MSG referenced technical standards that apply to public companies indicating that they aim to fully adopt the International Standard on Auditing, as well as a summary of the implementation of international standard IPSAS for public accounts including the commitment of Angola to transition to international standards, but without providing conclusive assessment of whether the payments and revenues in the EITI report are in line with international standards. EITI reporting does not describe audit and assurance practices of material companies and government entities in 2022 beyond confirming that the three material state-owned enterprises’ (SOE) 2022 financial statements had been audited with a qualified opinion. It describes the approach to quality assurances for financial data but does not explain the level of adherence of reporting companies and government entities, nor include any statement on the comprehensiveness or reliability of the financial data. In its comments on the draft Validation report, the MSG confirmed that state owned companies are subject to an annual external audit with a qualified opinion as well as the laws and regulations governing auditing and assurance policies for public bodies. The MSG comments indicates that the documentation provided is in line with the procedures for reliability agreed by the MSG but highlighting the limitations in term of information collection. The report also did not perform a reconciliation of all material companies and revenue streams, or an alternative data quality assurance procedure approved by the Board. During consultations, the Independent Administrator confirmed that they had received signatures from reporting companies and would send these to the Secretariat. To date, these have not been received comprehensively. In its comments on the draft Validation report, the MSG shared with the International Secretariat the reporting templates but stressing that no publication should take place without prior authorization of the respective entities. The International Secretariat notes however that not all the shared templates included a signature and that some templates are missing from material companies. The 2022 Angola EITI Report provides partial information on the quality assurance of financial data. Although it mentions that signatures and audit opinions are used to ensure quality assurances, it does not appear to comment on the level of adherence to these practices by reporting entities. In its comments on the draft Validation report, the MSG provided an assessment of the level of adherence by companies and government entities but only for the 3 entities involved in the pilot reconciliation. Furthermore, the report does not include a statement on the overall comprehensiveness and reliability of the financial data. Available documentation acknowledges the limitations in meeting EITI Requirement 4.9 particularly regarding the challenge of conducting a detailed reconciliation. Two out of nine material companies were selected for reconciliation and it is not clear whether these companies provided the required quality assurances for their EITI reporting. In its comments on the draft Validation report, the MSG confirms that the entities for which financial payment data has been reported have complied with the prerequisites of reliability of information. The report does not provide guidance on accessing publicly available financial statements for private extractive companies in Angola and lacks clear sourcing for some tables and figures. However, it includes recommendations for future improvements. In its comments on the draft Validation report, the MSG provides links to consolidated financial results for companies that are part of listed groups and for SOEs, as well sources for various tables in the EITI report.

The International Secretariat’s assessment is that Requirement 5.1 is mostly met. The MSG’s ‘Transparency’ template considers the objective of ensuring the traceability of extractive revenues to the national budget and the same level of transparency and accountability for extractive revenues that are not recorded in the national budget has been mostly fulfilled. Stakeholders consulted did not express particular views about the objective. The International Secretariat’s view agrees with the MSG’s self-assessment in considering the objective as mostly fulfilled, given the efforts in the description of financial revenue flow but lack of clarity over whether all extractive revenues, including those earmarked to repay oil-backed loans, are comprehensively recorded in the national budget. There do not appear to be any systematic disclosures of information on the distribution of extractive industry revenues on government websites. Angola’s 2022 EITI Report does not clearly indicate whether all government extractive revenues are comprehensively recorded in the national budget. The EITI Report states generally that most government extractive revenues are recorded in the national budget, with the exception of revenues collected by the extractive SOEs and not transferred to the state through dividends. Yet the EITI Report does not clearly state whether all oil revenues used to service national oil-backed debt (through escrow accounts) are comprehensively recorded in the national budget. There were differences of opinion among consulted stakeholders about whether all oil revenues used to repay oil-backed loans first transited through escrow accounts, or whether some oil revenues were first transferred to the Treasury before being used to repay oil-backed loans. While the EITI Report provides the aggregate value of oil revenues used to repay oil-backed debt that are sourced from the government’s budget (GSA), the International Secretariat considers that repayments of oil-backed loans do not follow the conventional budgetary process and thus that they should be covered by EITI reporting as forms of oil revenues and related expenditures that are not fully reflected in the national budget. With regards to revenues collected by SOEs, the International Secretariat considers that only those revenues collected by SOEs on behalf of the state (not as a result of their commercial operations) and not transferred to the Treasury should be considered as forms of government revenues not recorded in the national budget. The EITI Report only refers to the audited financial statements of the three extractive SOEs, two of which have been published in full (only a summary of Endiama’s 2022 financial statements have been published to date) but containing qualified auditor opinions. The EITI Report provides only a high-level description of the management of crude oil revenues used to repay national oil-backed debt, but without reference to a financial report on the management of these oil revenues. Some government officials consulted explained that there were financial reports covering the operations of the escrow accounts, but that these were not publicly accessible.

The International Secretariat’s assessment is that Requirement 5.3 remains not assessed, given that several encouraged aspects of this requirement remain to be addressed by Angola EITI. The MSG’s ‘Transparency’ template considers the objective of strengthening public oversight of the management of extractive revenues is fully met. Stakeholders consulted did not express particular views about the objective. However, the International Secretariat’s view is that the objective is still far from being fulfilled, given the limited public information about the government’s budget and audit cycles, as well as on additional information on revenue sustainability and resource dependence. There are limited systematic disclosures of information on extractive revenue distribution and expenditures in the petroleum sector through Sonangol’s annual publication of its audited financial statements. Sonangol’s 2022 financial statements (pp.39-41) disclose an overview about Sonangol’s assumptions about future developments in the petroleum sector and the broader economy. There do not appear to be systematic disclosures of information on extractive revenue distribution and expenditures in the mining sector. Angola’s 2022 EITI Report provides some cursory information on statutory provisions for earmarked extractive revenues, although not the value of earmarked revenues in 2022, and only briefly describes the country’s national budget framework. The report does not describe the government’s audit cycle nor provide additional relevant information on future production and revenues.

The International Secretariat’s assessment is that Requirement 4.6 is not applicable. The Transparency Validation template notes that this requirement is not applicable. The 2022 Angola EITI Report describes the revenue allocation process which does not specify any direct subnational payments. There do not appear to be any systematic disclosures of information on direct subnational payments in either the petroleum or mining sectors. The Report highlights that the Angola MSG confirms that there are no subnational payments.

The International Secretariat’s assessment is that Requirement 5.2 is partly met. The MSG’s ‘Transparency’ template considers the objective of enabling stakeholders at the local level to assess whether the transfer and management of subnational transfers of extractive revenues are in line with statutory entitlements is mostly fulfilled. Most stakeholders consulted did not express views on progress towards the objective. However, the International Secretariat’s view is that the objective is still far from being fulfilled, given that, while the report briefly refers to subnational transfers including revenue sharing formula, there is a lack of disclosures of the value of extractive revenues that should have been transferred to each beneficiary province and municipality, even if the subnational transfers were not disbursed in the period under review. This is critical to empower local stakeholders to understand their entitlements to revenues in line with the extractive industry revenue-sharing formula. There do not appear to be any systematic disclosures of information on subnational transfers of extractive revenues. Angola’s 2022 EITI Report briefly refers to subnational transfers of government revenues from mining to provinces and municipalities but does not provide any further information on these transfers beyond the general revenue-sharing formula. While the EITI Report confirms that the statutory subnational transfers described were not disbursed in practice in 2022, the report does not provide the value of subnational transfers of mining revenues that should have been received in 2022 (according to the revenue-sharing formula) by each of the provinces and municipalities. There were different views among stakeholders consulted, including across different government entities, over whether there had been any subnational transfers of extractive revenues in practice in the period under review. There were also differences of opinion on the specific extractive revenue streams that give rise to subnational transfers according to the legal framework, highlighting the importance of further clarity through Angola EITI on this issue. The 2022 Angola EITI Report itself is unclear about which revenue streams give rise to subnational transfers, with Annexe AL listing several different revenue streams that give rise to subnational transfers, while the EITI Report only briefly discusses provisions of the Mining Code requiring subnational transfers of a share of corporate income tax paid by mining companies. A government official consulted explained that the provisions of the Mining Code establishing subnational transfers had never been implemented to date given that Law no. 27/19, which regulates the functioning of local authorities, has not yet been implemented (although there were subnational transfers of revenues from quarrying of construction materials). The International Secretariat considers that more work is needed from Angola EITI on improving transparency in subnational transfers, particularly if the legal provisions introducing subnational transfers have not yet been implemented. On a point of methodology, the International Secretariat considers that the legal provisions requiring subnational transfers of a share of corporate income tax paid by mining companies constitute subnational transfers in accordance with Requirement 5.2, even though corporate income tax is not an extractive-specific revenue stream (given that the legal provision relates only to the revenue stream levied on extractive companies). The International Secretariat welcomes the MSG views on the scope and applicability of subnational transfers in the period under review.

The International Secretariat’s assessment is that Requirement 6.1 is partly met. The objective of this requirement is to enable public understanding of extractive companies’ social and environmental contributions and provide a basis for assessing extractive companies’ compliance with their legal and contractual obligations to undertake social and environmental expenditures. The MSG’s transparency template considers the objective to be partly met. Civil Society representatives highlighted during consultations that the data disclosed in the EITI Report was challenging to use in their outreach to local communities. While there have been moderate levels of detail on some disclosed social expenditures, it is not clear whether available disclosures are comprehensive. For social expenditures and mandatory environmental payments, broad confidentiality provisions in contract and data laws prevent a comprehensive understanding of these expenditures and payments Social expenditures The 2022 Angola EITI Report notes that extractive sector legislation requires mandatory social expenditures for petroleum and mining companies. The report and the ‘Transparency’ Validation template highlight that terms of these provisions are outlined in the contracts themselves and are often particular to each contract. Confidentiality provisions in contracts prevent the disclosure of specific terms and disaggregated data per contract. The ‘Transparency’ template also notes that it was not possible to establish materiality and provide further breakdown of social expenditures due to legal limitations. This was also confirmed during stakeholder consultations. The 2022 Angola EITI Report provides information and figures on social expenditures in 2022, with disaggregation by area of support (environment, social support, culture, etc.) for the mining sector and by area of support and beneficiary organisation for the oil and gas sector. The report provides values of such expenditures but does not clarify if they were made in cash or in kind. In addition, Annexe AG to the 2022 Angola EITI Report provides an overview of social investments that were completed in 2017 to mid-2023, with information on the name of the project, area of support, payer and name of the company, and the project’s geographic region but without information on the value of expenditures, nature (in-cash or in-kind expenditures), and the identity of beneficiaries. . Financial statements published by SODIAM and ENDIAMA also contribute to disclosures of social expenditures. SODIAM’s audited financial statements provide the value of SODIAM social expenditures in 2022, disaggregated by type of expenditure, with information on the type of expenditure, the region and beneficiary, but not whether it was provided in cash or in-kind. The SOE’s 2022 financial statements also note that SODIAM contributed a total of USD 5m to MIREMPET’s Social Fund and “to cover the costs of Angola’s membership of the EITI”, but without further describing these costs/contributions. ENDIAMA’s 2022 annual report briefly describes types of social expenditures by ENDIAMA in 2022 but does not clarify whether they are mandatory or voluntary, nor disclose the value of such expenditures in 2022. The 2022 Angola EITI Report also notes the requirement for oil and gas companies to make contributions to the training for Angolan staff but does not appear to clarify relevant legal basis for this requirement. Information on values of such contributions in 2022 are provided with disaggregation per block. Environmental payments Available documentation indicates that full disclosure of environmental payments was not possible due to the same reasons as for social expenditures of confidentiality provisions. The 2022 Angola EITI Report notes environmental payments related to obtaining and renewing license as well as fees related to environmental impact assessments (EIAs), applicable to both oil and gas and mining sectors. However, the 2022 EITI Report does not appear to disclose any environmental payments, except for aggregated data for social expenditures under category “environment”.