While the region has established increasingly robust integrity frameworks, ensuring their effective implementation and long-term sustainability remains the central challenge for the decade ahead. Building on the progress achieved, this chapter identifies six priority areas where stronger implementation, institutional capacity and sustained political commitment are needed to translate reforms into tangible results, strengthen public trust and deliver greater impact for citizens.
The Next Decade of Action for Public Integrity in Latin America and the Caribbean
2. The next decade: Bridging implementation gaps to achieve impact
Copy link to 2. The next decade: Bridging implementation gaps to achieve impactAbstract
2.1. Introduction
Copy link to 2.1. IntroductionDespite these advances and achievements, the region faces some challenges in achieving impact. To address these challenges, the countries in the region can build upon the advances and strengths presented in the previous chapter. By having strengthened the inter-institutional co-ordination and the strategic approach, countries have laid the foundation through which persisting and emerging challenges can be dealt with more effectively.
Drawing on lessons from previous OECD work in the region and on available data from the OECD Public Integrity Indicators, six priority areas are identified in the following sections where bridging the implementation gaps is essential for making meaningful progress in the region over the next decade: 1) Addressing undue influence in public decision making; 2) Empowering civil servants; 3) Renewing the citizen-government interface; 4) Promoting integrity at subnational levels; 5) Identifying and managing integrity risks; and 6) Tackling impunity by strengthening transparent and effective enforcement mechanisms. Together, these priorities form a roadmap for future action to help LAC countries deliver lasting impact in advancing integrity and anti-corruption reform.
Beyond these challenges, state-owned enterprises (SOEs) face specific integrity risks arising from their market participation, commercial relationships and governance structures. Safeguarding integrity in SOEs is essential to protecting public resources, ensuring alignment with their public purposes and maintaining trust. Although this report does not examine these issues in detail, LAC countries could strengthen risk-based safeguards, including transparent and merit-based board appointments, conflict-of-interest management, effective internal controls and clear accountability arrangements.
In addition, a common challenge shared globally, including across LAC countries, is sustaining the progress made on integrity and open government policies. Reforms in these areas require approaches that transcend government cycles, and continuous, incremental efforts are needed to achieve meaningful and lasting impact. Too often, however, successive governments do not build on progress made by the previous, or worse, adopt policies that undermine or reverse progress. This endangers the long-term success of reforms. At times, political considerations may bias policy decisions towards short-term, visible gains and away from fundamental, albeit more difficult or longer-term, reforms; this can be especially challenging when politically viable solutions fail to address root causes or ensure reform sustainability.
2.2. Addressing undue influence in public decision making
Copy link to 2.2. Addressing undue influence in public decision makingPublic decision making is prone to be influenced to reflect narrow interests instead of the public interest. Political finance shows one of the largest implementation gaps in the OECD Public Integrity Indicators: 41 percentage points in LAC countries, compared to 19 points in OECD non-LAC countries. Lobbying stands out as one of the most under-regulated areas in the region. Managing conflict of interest continues to be a challenge despite existing regulations and policies. Addressing these areas remains therefore a key priority in the region.
Undue influence in public decision making remains a key vulnerability in the region (OECD, 2018[5]) and is reflected in people’s perceptions that vested interests are steering policies away from the public interest. Nearly half of people in LAC (49%) feel high-level political officials would not reject private sector incentives in exchange for political favours (OECD, 2025[2]). Special interests may follow economic, political or criminal rationales. In some countries, organised crime creates particularly acute risks of undue influence and institutional capture, including through public procurement, regulatory decisions, infiltration of public institutions and intimidation of public officials. Risk-based preventive controls, protection of public officials exposed to threats and information-sharing among competent authorities can strengthen institutional resilience.
The capture of public decisions often starts during election processes to unduly influence the results and ensure that the winners will have to “repay” the support they received during their campaigns. Once in office, special interests may continue to influence policies. This might be done with integrity and transparency through regulated lobbying activities that enable accountability, or in the shadow, through opaque channels. Finally, managing conflicts of interest is essential to safeguarding the integrity of public decision making and ensuring that public officials act in the public interest.
2.2.1. Political finance and electoral integrity
Political finance is an essential element of the democratic process enabling political participation, competition and the expression of support during elections. However, without adequate safeguards, political contributions can become a vehicle for undue influence, posing serious risks to the integrity of electoral outcomes and subsequent decision making.
According to the PII, the LAC region outperforms OECD non-LAC countries in meeting standard regulatory criteria on political finance, fulfilling 89% of the criteria on average compared to 74% in OECD non-LAC countries (Figure 2.1). For example, all LAC countries have regulatory frameworks that include proportional sanctions for breaches of political finance and election campaign regulations, as well as bans on contributions from foreign states and enterprises and from publicly owned enterprises. 11 out of 14 LAC countries have also established ceilings for electoral campaign expenses for parties and candidates. However, only 5 out of 14 have done it for third-party campaigning, which refers to activities conducted by stakeholders and interest groups that are involved in election campaigns but do not formally run in elections. As such, spending caps for third parties remains largely unregulated despite significant risks of undue influence (OECD, 2021[17]).
Nevertheless, despite overall strong regulatory safeguards, the LAC region, on average, meets fewer standards on practice, with 48% of criteria fulfilled, compared to 54% in OECD non-LAC countries. For instance, although all LAC countries require political parties and candidates to report their finances (both funding and expenses) during electoral campaigns, only 5 out of 14 LAC countries have seen all political parties represented in Congress submit their annual accounts within the timelines set by national legislation over the past five years. Even more concerning, only 4 out of 14 LAC countries have had all political parties represented in Congress submit election-related accounts on time for the past two election cycles. Only 7 out of 14 LAC countries publish financial reports from all political parties represented in Congress, and merely 6 out of 14 make this information available through a single user-friendly online platform, highlighting significant room for improvement to strengthen transparency across the region. When it comes to transparency, Colombia, Guatemala and Mexico are noteworthy exceptions that could serve as inspiration for other countries. For instance, the website of Colombia’s National Electoral Council, Cuentas Claras, provides user-friendly information on the annual income and expenditure of all political organisations.
Figure 2.1. Gaps between the regulatory framework and the implementation of political finance safeguards in LAC and OECD non-LAC countries
Copy link to Figure 2.1. Gaps between the regulatory framework and the implementation of political finance safeguards in LAC and OECD non-LAC countries
Note: Data for Uruguay is not available. OECD non-LAC refers to the average of available data for OECD countries, excluding data for the four LAC member countries: Chile, Colombia, Costa Rica, and Mexico.
Source: OECD Public Integrity Indicators database (Data extracted on 16 September 2026).
In addition, experts perceive vote buying to be more common in LAC than in OECD countries (Figure 2.2). Vote buying can distort electoral results and diminish trust in democratic processes. While some progress had been achieved since the 1980s, this progress has stagnated and is even slightly reversing since 2005. It is therefore important for LAC countries to ensure transparency on who can donate to political parties and under what conditions (when, how much, by which means), how campaign funds are used, and how constituencies and institutional donors are treated after the elections. To that end, transparency and electoral institutions should have the mandate and necessary resources to conduct financial investigations, co-operate with other relevant entities and enforce sanctions when required.
Figure 2.2. Election vote buying in LAC and OECD countries
Copy link to Figure 2.2. Election vote buying in LAC and OECD countriesElection vote buying estimates, where lower values indicate more vote buying.
Note: For vote buying, the index reflects answers to the question “In this national election, was there evidence of vote and/or turnout buying?”, where answers ranged from “Yes. There was systematic, widespread, and almost nationwide vote/turnout buying by almost all parties and candidates” to “None. There was no evidence of vote/turnout buying”.
Source: Own elaboration based on data from Varieties of Democracy (V-Dem): https://v-dem.net/data_analysis/VariableGraph/. The methodology used to collect data and construct indexes is available on their website.
2.2.2. Transparency and integrity in lobbying
Lobbying is a natural part of the democratic process, but it needs to be regulated properly to establish safeguards ensuring that relevant interests are represented fairly in policymaking and that lobbying activities are conducted within the bounds of transparency and integrity. Transparency about who influences decision makers should be strengthened by greater traceability of the evidence, interests and considerations informing public decisions and the reasons underpinning them. This can facilitate scrutiny of potential undue influence while recognising legitimate stakeholder participation.
In the LAC region, as in the OECD, lobbying remains one of the most underregulated areas of public integrity. However, the regulatory gap is particularly pronounced in LAC. On average, countries in the region fulfil only 23% of the standard regulatory criteria for lobbying and fulfil just 10% of standard criteria on practice (Figure 2.3). By contrast, OECD non-LAC countries meet 42% of those regulatory criteria and fulfil 37% of practice criteria (Figure 2.3). Even foundational elements of a lobbying framework are often absent in LAC: only 5 out of 14 LAC countries have legally defined what constitutes lobbying activities and who qualifies as a lobbyist. Moreover, no LAC country has established cooling-off periods in their regulatory framework to prevent conflict of interest when lobbyists move into public roles, and only two countries (Chile and Mexico) have established proportionate sanctions for breaches of standards of transparency and integrity in lobbying. In general, Chile is a noteworthy exception and continues to work on strengthening its legislation. In Peru, sanctions exist for public officials engaging in lobbying activities.
Figure 2.3. Gaps between the regulatory framework and the implementation of lobbying safeguards in LAC and OECD non-LAC countries
Copy link to Figure 2.3. Gaps between the regulatory framework and the implementation of lobbying safeguards in LAC and OECD non-LAC countries
Note: Data for Uruguay is not available. OECD non-LAC refers to the average of available data for OECD countries, excluding data for the four LAC member countries: Chile, Colombia, Costa Rica, and Mexico. Mexico regulates lobbying exclusively through parliamentary rules of procedure, under which lobbyists must register to access one or both houses of Parliament. Argentina, and Brazil limits lobbying regulation to decrees or administrative schemes applying only to the executive branch. All other countries primarily regulate lobbying through primary legislation, either in dedicated lobbying laws or broader integrity and transparency laws. These approaches are not mutually exclusive, as primary legislation is sometimes complemented by branch-specific rules, such as parliamentary codes of conduct or additional access requirements.
Source: OECD Public Integrity Indicators database (Data extracted on 16 September 2026).
2.2.3. Managing conflict of interest
Managing conflict of interest remains a key challenge across the region. According to the PII, regulatory safeguards are widespread: 13 out of 14 countries have set out incompatibility rules, all have established asset and/or interest declaration requirements, and half have introduced oversight mechanisms. Indeed, the LAC region outperforms OECD non-LAC countries in meeting standard regulatory criteria on conflict of interest, fulfilling 94% on average compared to 77%. Yet, implementation gaps persist. When it comes to practice, LAC countries perform slightly lower than OECD non-LAC countries, fulfilling 41% on average compared to 42%. LAC countries, on average therefore have an implementation gap of 53 percentage points, showing the need to strengthen implementation (Figure 2.4).
This implementation gap on conflict of interest is due to different issues. First, submission rates of interest declarations remain low across all categories of public officials (including members of the Government, members of parliament, members of the highest body of the judiciary, newly appointed/reappointed top tier civil servants). For example, only 42% of LAC countries achieved a 100% submission rate by members of the Government over the past six years. Second, verification remains limited, highlighting the need to further strengthen oversight mechanisms. According to the PII, only 5 of 13 LAC countries select interest declarations for verification based on a risk-based approach. This may limit the ability of responsible authorities to identify and prioritise verification of interest declarations that pose a higher risk of conflict of interest. Third, the responsible authority has issued recommendations to resolve conflict-of-interest situations in only 4 out of 13 LAC countries for all cases of conflict of interest detected for the past three years, meaning opportunities to prevent a conflict-of-interest situation from turning into an integrity breach are not being fully used. Finally, while preventive measures are key, an effective conflict-of-interest framework should also make use of sanctions that are proportional to the offence and are applied fairly, objectively and in a timely manner. However, only 6 out of 13 LAC countries issue sanctions of different proportions in case of breaches.
This highlights the need to further strengthen the understanding of conflict of interest and move beyond regulations to fully harness the potential of conflict-of-interest frameworks to identify, prevent and manage situations in which the private interests of public officials could, or could be perceived to, improperly influence the performance of their official duties. This includes providing public officials with accessible ethics advice and guidance, promoting the timely disclosure of private interests and potential conflict-of-interest situations, and ensuring that actual, apparent and potential conflicts are identified and appropriately managed before they lead to integrity breaches. A solid conflict-of-interest framework requires countries not only to build their systems in regulations but also to ensure the responsibilities are met in practice.
Figure 2.4. Gaps between the regulatory framework and the implementation of conflict-of-interest safeguards in LAC and OECD non-LAC countries
Copy link to Figure 2.4. Gaps between the regulatory framework and the implementation of conflict-of-interest safeguards in LAC and OECD non-LAC countries
Note: Data for Uruguay is not available. OECD non-LAC refers to the average of available data for OECD countries, excluding data for the four LAC member countries: Chile, Colombia, Costa Rica, and Mexico.
Source: OECD Public Integrity Indicators database (Data extracted on 16 September 2026).
2.3. The human dimension: Empowering civil servants
Copy link to 2.3. The human dimension: Empowering civil servantsClear guidance and trainings on integrity are key to promoting organisational cultures of integrity in the public sector and countries in the region have made significant efforts in these areas. However, structural weaknesses in public employment pose a threat to achieving such cultural change and should therefore be a top priority for demonstrating commitment to sustainable results.
If the institutional arrangement of an integrity system is the backbone which enables and sustains the implementation of integrity policies, civil servants are its heart and soul. Institutions alone cannot ensure ethical conduct, uphold integrity standards or implement policy instruments or procedures correctly. Public integrity also requires individuals to act differently to achieve lasting change.
However, structural weaknesses in public employment remain a constraint to the institutionalisation of integrity in the region (OECD, 2019[18]). Despite some advances, the effectiveness of integrity-related policies is often undermined by politicisation, high staff rotation, and frequent resort to temporary contracts for permanent functions. These factors not only weaken the professional independence of public officials but also erode the administrative stability necessary for building trust and accountability. For instance, merit-based recruitment remains uneven across LAC administrations, particularly at senior management levels where appointments are still frequently discretionary. According to the OECD-IDB Public Service Leadership and Capability Survey, 11 of the 15 surveyed LAC countries (73%) directly appointed senior management positions without a competitive recruitment process in 2022 (OECD, 2024[7]). This illustrates the challenges that some public administrations face in ensuring merit-based recruitment.
Additionally, beyond these broader public employment challenges, the persistence of clientelist practices poses a further risk to integrity, distorting administrative decision making, weakening institutional autonomy and undermining the principle of equal access to public employment. While the V-Dem indicator presented in Figure 2.5 suggests that clientelism reached a regional low between 2002-2011, it also points to a slow increase since 2005.
Figure 2.5. Clientelism is still an issue in Latin America and the Caribbean
Copy link to Figure 2.5. Clientelism is still an issue in Latin America and the CaribbeanHigher values indicate more clientelism
Note: The clientelism index was constructed on a low to high (0-1) scale by aggregating data on vote-buying, the distribution of particularistic vs. public goods, and whether party linkages are programmatic or clientelistic. Both estimates rely on expert interviews and cover over 160 countries (Lundstedt and Edgell, 2020[19]).
Source: Based on data from Varieties of Democracy (V-Dem): https://v-dem.net/data_analysis/VariableGraph/. The methodology used to collect data and construct indexes is available on their website.
Moreover, when people in LAC assess their daily interactions with public institutions, there are persistent concerns about fairness and integrity. Only 36% of respondents across LAC countries believe that their application for government benefits would be treated fairly, 38% believe that public employees treat all people equally, and 31% believe that public employees would refuse a bribe, compared to 52%, 45% and 36%, respectively, in OECD countries (OECD, 2025[2]). Beyond formal rules and compliance mechanisms, integrity depends on daily choices, shared values and leadership that models ethical behaviour. Embedding the principles of a values-driven and merit-based civil service into the culture of the public administration requires continuous effort and reinforcement at all levels of government.
The LAC region has advanced significantly in promoting organisational cultures of integrity through a range of complementary measures that reinforce one another over time. Examples include the participatory development of public service values and integrity codes of conduct in countries like Brazil and Colombia, the development of clear guidelines on conflicts of interest and prevention of corruption in Costa Rica, awareness-raising campaigns for public officials informed by behavioural insights in Mexico, and efforts to promote integrity leadership through specialised trainings and networks in Brazil.
However, additional efforts are required. First, there is a need to address the structural weaknesses of public employment mentioned above. Addressing these challenges is a priority to create a fertile ground for organisational cultures of integrity to prosper throughout the public administration.
Second, strengthening integrity cultures requires a better understanding of the behavioural factors that influence how public servants make ethical decisions and how they implement integrity policies in practice. A behavioural insights perspective can help identify barriers and enablers to ethical conduct and improve the uptake and effectiveness of measures such as integrity risk management, managing conflict of interest, asset declarations, gift policies, audit reports or lobbying registries, thereby supporting more effective and sustainable behavioural change across the public sector (OECD, 2018[20]).
Finally, building and maintaining a culture of integrity in the public sector requires sustained investment in the skills, capabilities, and professional development of public servants, enabling them to exercise sound judgement, uphold public values, and adapt to emerging risks and opportunities. This includes investing in initiatives that equip public employees with the knowledge, skills and competencies needed to navigate ethical dilemmas, exercise sound judgement and integrate public service values into day-to-day decision-making, complementing rules-based compliance approaches. It includes as well fostering organisational environments that enable public officials to seek advice on ethical dilemmas and raise integrity concerns through appropriate channels without fear of retaliation.
Regarding emerging risks and opportunities, skills and capabilities are particularly important in the context of new technologies such as artificial intelligence (AI). Skills gaps remain the most frequently cited barrier to AI adoption in government, affecting all functions, fuelling resistance to change (Heyaca and Pallotta, 2026[15]). Without sufficient in-house expertise, governments struggle to design effective training, recruit and retain talent, creating a self-reinforcing cycle of dependency. As a result, public agencies risk merely reacting to technological change rather than shaping it, while audit institutions that cannot demonstrate effective, self-directed use of AI may also find it difficult to provide a credible assessment of its usage by government in the long term.
2.4. A renewed citizen-government interface: Promoting strategic engagement and protecting civic space
Copy link to 2.4. A renewed citizen-government interface: Promoting strategic engagement and protecting civic spaceOpen government reforms can contribute to public integrity and anti-corruption by enabling citizens, civil society organisations and other non-state actors to participate in public decision making, scrutinise government action and contribute to the identification of integrity risks. To achieve greater impact, LAC countries need to move beyond fragmented initiatives, strengthen meaningful and inclusive participation, protect civic space and improve implementation. More integrated and evidence-based approaches can help translate openness into safeguards against corruption and undue influence, greater accountability, responsiveness and public trust.
Citizen participation and civic engagement are important components of a comprehensive public integrity system. The OECD Recommendation on Public Integrity calls for a whole-of-society approach in which governments, civil society, the private sector and individuals share responsibility for upholding public integrity. This approach recognises that interactions between public institutions and external stakeholders can create both opportunities for greater accountability and risks to integrity. Meaningful engagement can therefore help bring diverse perspectives into public decision making, identify potential integrity risks and enable external actors to scrutinise how public decisions and resources are managed.
At the same time, citizen participation and citizen engagement can contribute to public trustenabling citizens, both individually and through organised groups and collective interests, to contribute to public decision making and helping public institutions better understand and respond to societal needs, thereby supporting policies that improve economic and social well-being. As across OECD countries, in LAC countries people’s sense of “having a say” in what governments do is more strongly associated with differences in public trust than any socio-economic or demographic characteristics are. In LAC, 66% express high to moderately high trust in government among those who feel that people like them have a say in what government does, while the share of respondents who report trusting their national government drops sharply to approximately 21% among those who feel they lack political voice (OECD, 2025[2]) – a trust gap of 45 percentage points, compared to 47 percentage points in OECD countries (OECD, 2026[21]).
2.4.1. Citizen participation
To strengthen the contribution of open government to public integrity and promote public trust, governments could adopt strategies that embed open government principles across public governance and align them closely with broader integrity frameworks. Instead of relying on fragmented, albeit innovative, initiatives, a coherent strategy can bring together existing efforts under a shared vision, ensuring alignment and consistency across institutions and other relevant agendas. Demonstrating the impact of open government also requires a shift from anecdotal success stories to robust, evidence-based evaluation. As such, governments in LAC and across the OECD could invest in better monitoring and evaluation systems that capture, for example, how citizen participation contributes to public integrity, improved service delivery and trust in government. Feedback mechanisms through which public institutions explain how citizens’ contributions have been considered can also help translate participation into greater responsiveness and accountability.
Challenges also remain across the region in enabling more meaningful citizen participation. While LAC countries have adopted dedicated legislation and policy frameworks to promote citizen participation, implementation remains fragmented across sectors, such as environment and infrastructure (OECD, 2024[7]). In practice, citizens also continue to report limited or unequal access to participation opportunities (V-DEM, 2025[22]). This gap between written commitments and their de facto implementation highlights the need not only to strengthen the enabling environment for citizens to participate, but also to enhance governance capacities within the public administration and institutionalise citizen participation throughout the policy cycle spanning from agenda setting to implementation and evaluation (V-DEM, 2025[22]).
Brazil provides an example of how institutional arrangements can help move participation beyond isolated initiatives. The National Secretariat of Social Participation, established within the General Secretariat of the Presidency, provides an institutional mechanism to co-ordinate participatory processes, conduct research and articulate participatory instances across the federal government. Supported by this institutional framework, Brazil has combined institutional, territorial and digital channels to engage citizens at scale in shaping strategic policy priorities, including the preparation of the 2024-27 Multiannual Plan and national climate and culture plans. This illustrates how dedicated governance arrangements can help move participation beyond fragmented initiatives and embed it more sustainably in public governance.
2.4.2. Civic space
Civic space is increasingly under pressure across the globe, including in LAC (OECD, 2022[23]; OECD, 2025[8]). Because effective participation depends on the ability of citizens and civil society organisations to organise, express views, scrutinise public action and engage freely and safely in public life, strengthening participation mechanisms alone is insufficient. Meaningful citizen participation therefore rests on a strong and protected civic space (OECD, 2022[23]). Only when civic space is protected and actively nurtured, individuals and civil society stakeholders can participate in public life, advocate for change without fear of retribution and contribute to public accountability. It also enables communities to mobilise around shared interests andraise their concerns and views on policy problems, their impacts and possible ways to address them. In turn, an open and inclusive civic space can foster richer engagement, strengthen external scrutiny and help governments better understand different societal concerns and anticipate emerging tensions.
In 2025, the OECD published a regional review of civic space in the LAC region, based on data collected from 13 countries (Argentina, Brazil, Chile, Colombia, Costa Rica, Dominican Republic, Ecuador, Guatemala, Honduras, Mexico, Panama, Peru and Uruguay). Key findings include (OECD, 2025[8]):
Civic-space policies remain fragmented. Efforts to protect civic space by LAC governments are typically undertaken by a variety of public institutions or ministries and are often disjointed and siloed. As such, countries in the region can benefit from adopting a more comprehensive and co-ordinated approach to civic space. For example, the Dominican Republic elaborated the first-ever Civic Space Strategy, built around five key pillars: creating an enabling environment for civil society; promoting citizen participation; protecting freedom of assembly, demonstration and human rights; guaranteeing access to information, freedom of the press and combating disinformation; and fostering digital civic space (OECD, 2025[8]).
Freedom of expression requires effective protection in practice. Although freedom of expression is constitutionally guaranteed in all 13 LAC countries covered, challenges remain in ensuring the full realisation and protection of this right. In particular, strategic lawsuits against public participation (SLAPPs) are a major concern. Countries in the region continue to lack robust data on SLAPP occurrences and specific legal protections for individuals, civil society organisations (CSOs) and media targeted by these lawsuits (OECD, 2025[8]).
Ensuring proportionate and accountable responses to demonstrations. While freedom of peaceful assembly is permitted and facilitated in all surveyed LAC countries, challenges persist, particularly in ensuring the proportional use of force against protestors during large-scale demonstrations. Also, most LAC countries lack dedicated laws regulating freedom of peaceful assembly beyond constitutional recognition (OECD, 2025[8]). Addressing these issues, thereby safeguarding assemblies, requires specific legislation, protocols, and accountability mechanisms. Establishing dialogue channels between protestors and the government and adopting de-escalation tactics are also crucial (OECD, 2025[8]).
An enabling environment for civil society is important for public accountability. Governments can also further strengthen legal, regulatory, and policy frameworks that create an enabling environment for CSOs by developing overarching CSO strategies, among others. In several LAC countries, burdensome regulations, such as registration procedures and costs, hinder the full realisation of the right to freedom of association. Aligning national frameworks with international standards and simplifying administrative processes, while ensuring equitable access to funding, would enable CSOs to contribute more effectively to public life (OECD, 2025[8]).
2.5. Reaching the territory: Promoting integrity at subnational levels
Copy link to 2.5. Reaching the territory: Promoting integrity at subnational levelsOne size does not fit all. Integrity frameworks need to consider the diversity in risks, capacities and resources to ensure covering the whole territory and achieve visible impact for all citizens. Initial good practices in the region are promising, but a more strategic investment in addressing subnational challenges should be a priority for the LAC region over the next years.
To build a culture of integrity, it is key to reach the territorial level, especially municipalities. Considering their responsibilities for delivering public services and regulating local development (such as education, health, waste management, granting licenses and permits, undertaking inspections), municipalities are particularly vulnerable to corrupt practices. Local particularities can further exacerbate these risks, e.g. municipalities with ports may have integrity risks associated with organised crime, while municipalities with natural resources may have integrity risks related to illegal logging or mining. Also, municipalities vary significantly in terms of size, capacities and resources making it more difficult to prevent and control effectively corruption in procurement or construction, for example.
These specificities require differentiated integrity policies that respond to the local realities (OECD, 2019[18]). At the same time, the proximity of local governments to citizens’ needs and daily realities, as well as their frequent interactions with the public, has the potential to strengthen positive perceptions and enhance public trust. While average trust in local governments and national governments is similar in LAC (37% and 35%, respectively) (OECD, 2025[2]), there remains significant potential to increase trust at the local level. For instance, continued efforts to ensure fairness and expand opportunities for participation could generate meaningful improvements in citizens’ confidence in local government.
However, integrity policies are generally neither designed nor implemented in such a differentiated manner. Instead, they are typically established at the national level, following homogeneous patterns, without considering the differences in local contexts and the capacities of local governments. Promoting integrity at subnational level requires therefore approaches that are proportionate to the size, functions, capacities and risks of different subnational governments, supported where appropriate by technical assistance, shared tools and co-operation across levels of government. The federal countries in the region, Argentina, Brazil and Mexico, face an additional challenge resulting from the high level of autonomy of their subnational governments. According to data collected through the OECD Public Integrity Indicators, in LAC countries only 57% of integrity action plans include activities to collaborate with institutions at the subnational level (this corresponds to 8 out of 14 LAC countries).
Nonetheless, LAC countries are increasingly acknowledging and addressing this challenge. Peru has been making efforts to reach out to municipalities to support the implementation of integrity policies through their Integrity Model (Modelo de Integridad). Costa Rica is currently developing, with support from the OECD, a framework to promote integrity policies in municipalities. In Colombia, the already mentioned mainstreaming tool MIPG provides differentiated implementation and measurement criteria for subnational institutions. Brazil has implemented initiatives to encourage subnational governments to adopt some of the regulations on public integrity implemented at the federal level, including the initiative “Transparency and Integrity in Municipalities and States” (Transparência e Integridade em Municípios e Estados, TIME Brazil) and the National Programme for the Prevention of Corruption (Programa Nacional de Prevenção à Corrupção, PNPC). In Mexico, the General Law of the National Anticorruption System requires all states to establish their own anti-corruption systems that operate as part of the national framework, ensuring a cohesive and standardised approach to anti-corruption efforts across all subnational entities. In 2025, the IDB, through its regional InvestmentMap initiative, supported the deployment of subnational transparency platforms in major Colombian cities, including Cali and Bogotá (Box 2.1).
Box 2.1. Advancing integrity and accountability at the subnational level through InvestmentMap
Copy link to Box 2.1. Advancing integrity and accountability at the subnational level through InvestmentMapWhile integrity reforms are often designed at the national level, citizens frequently experience government through local services, infrastructure projects and public investments implemented in their communities. Strengthening integrity at the subnational level is therefore essential to improving accountability, public trust and citizen engagement.
These platforms provide citizens with accessible and user-friendly information on public investments and local development projects, enabling greater visibility over how public resources are allocated and implemented within their territories. By combining open data, digital technologies and citizen-centred transparency, these platforms seek to strengthen public accountability, facilitate social oversight and promote more informed citizen participation in local governance.
They also demonstrate how digital transparency tools can help operationalise integrity principles beyond the national level, bringing information closer to citizens and supporting more responsive and accountable local institutions. The experience illustrates the growing role of subnational governments in advancing integrity and highlights the potential of digital transparency initiatives to strengthen trust and oversight where public policies and investments directly affect people's daily lives.
Source: (IDB, n.d.[24]).
2.6. Strengthening risk management, internal control and audit
Copy link to 2.6. Strengthening risk management, internal control and auditSeveral countries in the LAC region have made progress in developing strong frameworks for integrity risk management, internal control and audit. To achieve impact, it is key to strengthen the responsibility and ownership of public managers in managing risks and applying internal controls. Internal and external audit can be further strengthened to provide oversight and assurance.
Risk management, internal control and audit help prevent fraud and corruption by ensuring that risks are effectively managed and that organisational objectives are met. Beyond preventing fraud and corruption, these systems also play a broader role in identifying and mitigating integrity risks that may undermine public service values, ethical conduct or public confidence, even where no fraud or corruption has occurred. These systems also support sound decision making, improve efficiency and help ensure value for money.
The LAC region performs on par with OECD non-LAC countries, indicating the existence of relatively strong regulatory frameworks in the region, while also underscoring the need to ensure that these frameworks are effectively applied in practice. According to PII data, on average, LAC countries meet 72% of regulatory criteria but only 26% of criteria on practice, compared to 68% and 32% respectively in OECD non-LAC countries (Figure 2.6).
Several LAC countries have developed corruption risk management methodologies, such as Brazil, Colombia, Peru, Ecuador and the Dominican Republic. Overall, 9 out of the 11 LAC countries for which PII data is available are explicitly addressing integrity risks in their risk management frameworks, compared to 18 out of 26 OECD non-LAC countries with available data. 4 out of the 11 LAC countries have issued guidelines on assessing integrity risks to all public sector institutions, compared to 10 out of 25 OECD non-LAC countries with available data. The maturity of risk management varies significantly within countries and improving public managers’ ownership of integrity risk management remains a challenge in both LAC and OECD non-LAC countries. The underlying qualitative research feeding into the PII suggests that integrity risk management across LAC countries is not widespread yet and continues to take place in the framework of internal audit. Similarly, most countries have not set up an institution within the executive responsible for co-ordinating and overseeing the internal control system, with external oversight bodies such as the Comptroller General’s Office playing this role in most of the countries observed.
Significant implementation efforts are also required to strengthen internal audit. None of the 6 surveyed LAC countries have internal audit units staffed with at least two auditors, nor do at least 85% of public officials performing internal audit functions hold national or international certification in internal auditing. Stronger leadership commitment is also needed: only 1 out of 6 LAC countries reported that audit charters and procedure manuals are formally adopted by institutional heads across all sampled organisations, and that internal audit reports are submitted directly to these leaders.
Supreme Audit Institutions (SAIs) can contribute to strengthening public integrity through independent audits and oversight. They provide objective assurance and advice on the management of public resources, helping identify vulnerabilities to corruption, weaknesses in internal control systems and deficiencies in government programmes. SAIs can conduct compliance or performance audits to examine the effectiveness of key integrity mechanisms, such as codes of conduct, conflict-of-interest frameworks, asset declaration systems, whistleblower protection arrangements and integrity strategies. They may also assess whether public institutions have effective risk management and controls in place to identify, manage and mitigate integrity risks, and whether oversight mechanisms promote ethical conduct and accountability. Going a step further, SAIs can also draw on accumulated audit findings to generate insights on cross-cutting patterns, root causes, and emerging risks affecting public integrity systems.
Figure 2.6. Gaps between the regulatory framework and the implementation of risk management and internal control and internal audit safeguards in LAC and OECD non-LAC countries
Copy link to Figure 2.6. Gaps between the regulatory framework and the implementation of risk management and internal control and internal audit safeguards in LAC and OECD non-LAC countries
Note: Data for Bolivia, Colombia, Paraguay and Uruguay are not available. OECD non-LAC refers to the average of available data for OECD countries, excluding data for the four LAC member countries: Chile, Colombia, Costa Rica, and Mexico.
Source: OECD Public Integrity Indicators database (Data extracted on 16 September 2026).
2.7. Addressing impunity through effective enforcement mechanisms
Copy link to 2.7. Addressing impunity through effective enforcement mechanismsDespite some progress, impunity remains a challenge across the region. International co-operation to fight transnational corruption has advanced and some countries have managed to strengthen their corporate liability frameworks, fine-tune their disciplinary processes and enhance the capacities of their law enforcement agencies. In the upcoming years, building on these efforts will be key, as will promoting co-ordination and protecting the independence of the judiciary and law enforcement capacity.
Addressing impunity requires more than strong legal frameworks; it also depends on the capacity of institutions to investigate, prosecute and adjudicate cases effectively. In recent years, growing concerns about organised crime, illicit financial flows and transnational criminal networks have reinforced the need for stronger enforcement mechanisms and greater regional co-operation.
Reflecting this trend, countries in Latin America and the Caribbean launched the Alliance for Security, Justice and Development in 2024 with the support of the IDB. The Alliance promotes evidence-based approaches to strengthen security and justice institutions, reduce illicit financial flows and markets, and enhance co-operation across countries and institutions. These efforts illustrate the growing recognition that tackling impunity requires co-ordinated institutional responses that extend beyond traditional anti-corruption frameworks and connect oversight bodies, prosecution services and courts.
The effective and consistent enforcement of laws and regulations demonstrates that governments are committed to upholding integrity. Integrity violations need to be detected, and sanction mechanisms enforced to avoid impunity. Impunity, even if only perceived, undermines the rule of law, trust in institutions and provides the breeding ground for more unethical practices, apathy or cynicism. Effective enforcement must respect due process, impartiality and proportionality, ensuring that responsibility is established through fair and reliable procedures rather than inferred from allegations alone.
2.7.1. Safeguards for judicial and prosecutorial integrity
Progress in strengthening judicial and prosecutorial integrity and ensuring safeguards are in place to protect against undue influence in the LAC region remains uneven. An analysis of the OECD Working Group on Bribery’s country monitoring reports since 2018 on the seven LAC countries that are Parties to the OECD Anti-Bribery Convention reveals that persistent challenges remain. These include insufficient resources and expertise, as well as ongoing threats to the independence of judges and prosecutors. In several jurisdictions, political interference in the appointment and dismissal of prosecutors and judges, along with undue influence over ongoing investigations, continues to raise serious concerns. PII data similarly reveal variation across LAC and persistent gaps between the adoption and implementation of justice-system integrity safeguards. Figure 2.7 and Figure 2.8 present the share of regulatory and practice criteria fulfilled concerning judicial and prosecutorial integrity.
Figure 2.7. Regulatory and practice criteria for judicial integrity in LAC and OECD non-LAC countries
Copy link to Figure 2.7. Regulatory and practice criteria for judicial integrity in LAC and OECD non-LAC countries
Note: Data for Bolivia, Mexico and Paraguay are not available. OECD non-LAC refers to the average of available data for OECD countries, excluding data for the four LAC member countries: Chile, Colombia, Costa Rica, and Mexico.
Source: OECD Public Integrity Indicators database (Data extracted on 16 September 2026).
Figure 2.8. Regulatory and practice criteria for prosecutorial integrity in LAC and OECD non-LAC countries
Copy link to Figure 2.8. Regulatory and practice criteria for prosecutorial integrity in LAC and OECD non-LAC countries
Note: Data for Bolivia, Colombia and Paraguay are not available. OECD non-LAC refers to the average of available data for OECD countries, excluding data for the four LAC member countries: Chile, Colombia, Costa Rica, and Mexico.
Source: OECD Public Integrity Indicators database (Data extracted on 16 September 2026).
Although judicial governance arrangements vary considerably across the LAC region, common challenges exist. The region includes systems involving popular elections, arrangements in which governance is largely anchored within the judiciary itself and dedicated judicial governance bodies with different mandates and compositions. Across these models, regulations require judicial appointments to be based on recommendations from an independent body in only 27% of countries. Shortcomings include risks of political influence over the composition of these bodies and arrangements in which judges elected by their peers constitute less than half of their membership. Ensuring that at least half of the members are judges chosen by their peers helps protect career decisions from political influence and brings relevant professional expertise into these decisions. Bodies responsible for appointments and promotions should operate autonomously from the executive and legislative branches, apply clear and objective criteria, and be governed by transparent rules for the selection, appointment and removal of their members. Similar shortcomings affect prosecutorial governance. Merit-based and objective procedures for the selection and promotion of prosecutors, such as standardised written exams, panel interviews, or fair elections in systems where prosecutors are elected, are established in regulations in only 27% of LAC countries, where sometimes prosecutorial authorities retain appointment discretion, or procedures are established only in secondary or internal regulations.
Appeal mechanisms in selection and promotion processes are also not widely available in LAC. Regulations establish a right of candidates to appeal decisions on the appointment and promotion of judges in 39% of OECD countries and of prosecutors in 44%. The corresponding figures for LAC are only 27% for both groups. Effective recourse mechanisms are an essential safeguard for merit: they allow candidates to challenge arbitrary or procedurally flawed decisions, thereby strengthening transparency and accountability.
Safeguards governing the transfer of judges constitute another area for improvement. In 75% of OECD countries, judges may be transferred only with their consent or at their request, except in specific circumstances established by law. This safeguard exists in only 64% of LAC countries, where the permissible grounds for transfers are sometimes either not regulated or set out only in secondary regulations. Clear legal safeguards are important because involuntary transfers can otherwise be used to exert pressure on judges, penalise particular decisions or remove them from sensitive cases.
Regulations on financial independence are comparatively strong in LAC, but implementation remains problematic. In 91% of assessed countries, judicial authorities must be consulted on resource allocations, which must follow publicly available criteria; 82% provide equivalent safeguards for prosecution services. Nevertheless, funding shortfalls or reductions against approved financing proposals were reported in half of the region’s judiciaries and 70% of its prosecution services. This significant gap between formal safeguards and actual funding can undermine operational autonomy, exacerbate staffing and capacity constraints, and limit institutions’ ability to investigate and adjudicate complex corruption cases effectively.
Nevertheless, the Working Group on Bribery also highlights some positive developments. In Brazil, law enforcement capacities have been strengthened through training, guidance, and organisational reforms (OECD, 2023[25]). In Chile, prosecutorial and investigative resources have increased significantly, and innovative technologies have been introduced to support complex investigations (OECD, 2018[26]).
PII data also identify areas of institutional governance and independence in which LAC countries perform comparatively well. In all but one of the LAC countries assessed (91%), regulations require judges to undergo performance evaluations based on predetermined criteria. When conducted transparently and with appropriate safeguards, such evaluations can support professional development and accountability while reducing the scope for arbitrary decisions concerning judicial careers. All but one assessed LAC country has also established specialised units or teams of prosecutors responsible for investigating and prosecuting corruption and financial crime, including a specialised directorate in Colombia and specialised prosecutors’ offices operating across Peru. These structures can concentrate expertise, facilitate institutional co-ordination and strengthen the capacity to handle complex cases. Finally, all prosecution services also regularly publish performance reports, supporting transparency and enabling public scrutiny of their activities and results.
2.7.2. Standards of conduct and whistleblower mechanisms in the justice system
Clear integrity rules and standards of conduct help judges and prosecutors identify and manage ethical dilemmas and provide a basis for addressing misconduct. These safeguards are widely established across the region: PII data shows that standards of conduct are available and applicable in 91% of assessed countries for both judges and prosecutors. Regulations also commonly define conflict of interest situations for prosecutors (73%), judges (64%) and court employees (55%). In addition, all assessed countries establish grounds and procedures for the recusal of judges, and 90% do so for prosecutors.
However, implementation remains a concern, since institutional arrangements, guidance and training needed to apply these rules are less developed. Only Costa Rica, Ecuador and Peru have established ethics advisory bodies that provide counselling and help manage integrity risks in both the judiciary and the prosecution service. Regular training on integrity safeguards is available to judges in only six LAC countries, while training for prosecutors on integrity safeguards and the prosecution of corruption cases is available in 5. Expanding advisory bodies and practical training would help translate formal standards into consistent conduct.
The implementation gap is particularly stark for interest declarations. All assessed LAC countries require national and senior judges to submit declarations, compared with 57% of OECD countries, and these obligations are accompanied by sanctions for non-compliance. Requirements for prosecutorial authorities are similarly widespread. However, only 50% of LAC countries provide sufficient data to demonstrate that most judges had submitted the required declarations over the previous four years, and only 33% did so for prosecutors. Verification is even weaker: Costa Rica was the only assessed country to demonstrate that the responsible authority had verified at least 60% of declarations submitted. Interest declarations are only publicly available in 27% of countries in the region. Stronger monitoring, verification and publication of aggregate compliance data are therefore needed to make disclosure systems effective.
Procedures for reporting judicial and prosecutorial misconduct also exist widely, but safeguards for reporting persons remain underdeveloped. All assessed LAC countries have established complaints procedures for judicial misconduct, and all but one have done so for prosecutorial misconduct. However, most lack dedicated legal guarantees of confidentiality and protection against retaliation for internal whistleblowers. No assessed LAC country requires staff handling reports in courts to undergo mandatory confidentiality training, while publicly available information on whistleblower rights exists in only 22% of countries for judicial misconduct and 30% for prosecutorial misconduct. Nonetheless, recent initiatives point to progress: Chile’s prosecution service and Peru’s judiciary have introduced whistleblower mechanisms through internal policies, while Costa Rica’s whistleblower protection law provides guarantees for internal reporting in both the judiciary and prosecution service.
2.7.3. Disciplinary enforcement
Disciplinary enforcement complements criminal enforcement by addressing forms of misconduct that do not imply criminal liability but still undermine integrity in public institutions. By ensuring consequences for breaches of obligations and duties within the public service, disciplinary sanctions promote accountability and reinforce the broader enforcement framework through timely, proportionate and preventive action. However, ensuring effective co-operation, co-ordination and information-sharing among relevant institutions and bodies remains a challenge in the LAC region, as disciplinary proceedings often depend on the collaboration of a wide range of actors, both within and outside the concerned entity. Beyond institutional co-ordination, effective enforcement also depends on adequate procedural safeguards, professional capacity and reliable systems for managing and monitoring disciplinary cases.
Effective implementation also requires greater standardisation and professional capacity. Disciplinary proceedings depend on co-operation and information-sharing among multiple institutions. Without central guidance and training, similar cases may therefore be handled differently across the public administration. Yet only 64% of assessed LAC countries provide relevant training to all officials responsible for disciplinary investigations, while 73% have issued central guidance on the standardisation of procedures. The centralised disciplinary system of Brazil’s federal executive branch (Sistemas Correcionais, SISCOR), coordinated by the Office of the Comptroller General (CGU), is a good example of how co-ordination and timely communication can support more effective disciplinary processes. The CGU has developed methodologies, manuals, training programmes, and technical guidelines to support public officials responsible for investigating irregularities, conducting disciplinary proceedings, and safeguarding organisational integrity. Initiatives such as the Disciplinary Management Assessment and Monitoring framework, a supervisory structure designed to measure, track, and improve the performance of sectoral disciplinary units across the federal executive branch, and the VESPA Project, which uses automated analysis to support the assessment of potential illicit enrichment, help strengthen investigative capacity and promote more consistent, evidence-based disciplinary proceedings.
Digital case-management systems and better enforcement data could also strengthen implementation. Electronic systems can improve the timeliness and traceability of proceedings while enabling authorities to aggregate information on cases. However, only Mexico, Argentina and Brazil use an electronic case-management system for disciplinary proceedings, and only Brazil publishes aggregated data in an open data-format on the number and type of disciplinary sanctions applied against civil servants. Without this information, governments may not readily assess whether cases are resolved promptly or sanctions are applied consistently. Greater investment in digital tools, data quality and transparency would therefore support not only more effective enforcement, but also the use of disciplinary evidence to improve prevention.
2.7.4. Criminalisation of corruption and corporate liability frameworks
An analysis of the OECD Working Group on Bribery’s country monitoring reports since 2018 on the seven LAC countries that are Parties to the OECD Anti-Bribery Convention reveals that at least two of them have amended their foreign bribery offences. In 2018, Argentina introduced a new definition of a foreign public official (OECD, 2019[27]). That same year, Chile expanded the foreign bribery offence to cover all economic activities conducted abroad (OECD, 2018[26]). Regarding corporate liability, Argentina introduced corporate liability for foreign bribery in 2018 (OECD, 2019[27]). Costa Rica followed in 2019 with the introduction of criminal corporate liability for foreign bribery (OECD, 2020[28]). In 2023, Peru also took steps to address some recommendations related to its Corporate Liability Law (OECD, 2023[29]). Chile and Costa Rica increased fines against legal persons (OECD, 2020[28]; OECD, 2018[26]).
2.7.5. International co-operation in the fight against transnational corruption
LAC countries have strengthened co-operation in transnational corruption cases. An analysis of the OECD Working Group on Bribery country monitoring reports since 2018 on the seven LAC countries that are Parties to the OECD Anti-Bribery Convention reveals that despite issues such as delays in responding to incoming mutual legal assistance requests and the quality of outgoing requests, most countries display a sound framework for international co-operation and actively engage in direct co-operation through law enforcement networks such as the OECD’s Latin-America and Caribbean Law Enforcement Network (LAC LEN). Co-ordination in multijurisdictional cases has also increased. Brazil, for instance, has played an active role in helping OECD Working Group on Bribery’ and non-member countries’ authorities resolve their foreign bribery cases (Table 2.1). The 2026 OECD report on Sanctioning Foreign Bribery through Multijurisdictional Resolutions provides quantitative and qualitative analysis of how multijurisdictional resolutions are transforming the fight against corruption. It examines 31 cases consisting of 114 distinct resolutions and involving 12 countries and 27 distinct enforcement authorities, including Brazil (OECD, 2026[30]).
Table 2.1. Brazil: Selected multi-jurisdictional resolutions in which other Parties sanctioned foreign bribery
Copy link to Table 2.1. Brazil: Selected multi-jurisdictional resolutions in which other Parties sanctioned foreign bribery|
Company |
Other countries |
Total penalties imposed by Brazil and other participating countries (including fines, forfeiture, restitution). |
Date (Year) |
|---|---|---|---|
|
Odebrecht / Braskem |
Switzerland, United States |
USD 3.5 billion, distributing the principal fine to Brazil (80%), Switzerland (10%), and the United States (10%). |
2016 |
|
J&F Investimentos |
United States |
USD 2 billion, with approximately USD 1.85 billon to be paid to Brazil. |
2017, 2020 |
|
SBM Offshore |
Netherlands, United States |
USD 808 million, paid as follows: Brazil (USD 330 million), the Netherlands (USD 240 million), and the United States (USD 238 million) |
2014, 2017, 2018 |
|
Rolls-Royce |
United Kingdom, United States |
USD 800 million, paid as follows: Brazil (USD 25.6 million), the United Kingdom (USD 604.8 million), and the United States (USD 169.9 million). |
2017 |
|
Glencore |
United Kingdom, United States |
USD 739 million in relation to foreign bribery, including amounts to Brazil (USD 39.6 million) and the United Kingdom (USD 165.9 million). |
2022 |
|
Keppel Offshore & Marine Ltd |
Singapore, United States |
USD 422 million, paid as follows: Brazil (50%), Singapore (25%), and the United States (25%). |
2017, 2018, 2022 |
Source: (OECD, 2023[25]).