Conflict-of-interest management ensures public office holders continue to serve citizens and businesses’ interests. While countries’ conflict-of-interest regulations are generally strong, an implementation gap remains in countries’ conflict-of-interest systems. Oversight authorities could improve monitoring of at-risk officials’ disclosure of interests and/or assets and office holders’ movement in and out of public entities to better understand whether safeguards are working in practice. Improving conflict-of-interest management is not just about layering process over existing mechanisms. Taking a risk-based approach can help focus efforts on those office holders most exposed to corruption risks. Countries could also enhance institutional capacity, improve verification procedures, make recommendations for resolving conflicts before they cause harm, and use appropriate sanctions for breaches.
Anti‑Corruption and Integrity Outlook 2026
Abstract
A conflict of interest involves a conflict between the public duty and private interests of a public official, in which the public official has private capacity interests that could improperly influence the performance of their official duties and responsibilities (OECD, 2003[19]). While not corruption per se, conflicts of interest that are not properly mitigated can undermine the integrity of public officials and the decisions they make, weakening trust in government. Managing conflicts of interest helps ensure stakeholders’ fair and adequate access to policymakers and policymaking processes and holds public officials to account for their decisions (OECD, 2020[14]).
An effective conflict-of-interest system provides public officials with the guidance to proactively identify and manage situations where actual, potential or perceived conflicts of interest may arise. This includes establishing clear tools and processes for submission and verification of declared interests, outlining effective, proportionate and enforced sanctions for policy breaches, and taking a risk-based approach to enforce the policy to ensure effective implementation that is not overly burdensome to both public officials and oversight entities (OECD, 2003[19]). Conflict-of-interest safeguards are a cornerstone of public integrity systems and can support an open and transparent government, and transparency and integrity in lobbying and influence as well as political finance activities.
This chapter shows that:
While conflict-of-interest regulations are generally strong, the implementation gap for conflict of interest persists for OECD Members and is even greater for OECD partner countries.
Authorities in many countries could improve monitoring of whether at-risk officials are disclosing their interests and/or assets.
To strengthen the efficiency and effectiveness of conflict-of-interest safeguards, countries can take a more risk-based approach for verification of declarations, and more frequently issue recommendations and use sanctions.
While most countries have rules on revolving door they could be more consistently tracked to better mitigate conflict-of-interest risks.
Most countries have strong regulatory frameworks to prevent conflicts of interest, but the responsible institutions lack the powers or capacity to oversee and enforce the rules. Having strong regulations but inadequate implementation can undermine public confidence in anti-corruption efforts and could be perceived as window-dressing. Management of conflict of interest has one of the largest implementation gaps across all the areas covered in this Outlook. Globally, in 2025, countries fulfil on average 85% of criteria on the strength of conflict-of-interest regulations but only 42% of criteria on practice. This leaves a global implementation gap of 43 percentage points (Figure 4.1). There are three main causes of this gap across all countries: (1) lack of verification of declarations; (2) lack of recommendations from public authorities to resolve conflicts of interest; and (3) failure to submit declarations in practice. Greater use of electronic submission and taking a more risk-based approach to verification could help countries address these causes. The sections below further explain the causes and how countries can close the implementation gap.
For OECD Member countries, the implementation gap stands at 35 percentage points in 2025, reflecting no change since 2022. OECD Member countries that have shown the greatest improvement in reducing the implementation gap between 2022 and 2025 are Costa Rica and Mexico. In both cases, this progress relates to improving and publishing the declaration submission rates for public officials and taking a more risk-based approach to verifying declarations. OECD partner countries have a wider gap in general, because they have more comprehensive regulatory frameworks to mitigate conflict-of-interest risks (fulfilling 89% of criteria on regulations), but in practice, implementation lags behind the OECD average (meeting 38% of criteria).
Note: Data not provided by Japan and Switzerland.
How to read: On average, in 2025 Poland fulfilled 89% of criteria on regulation and 11% on practice. OECD member countries are represented by dark blue bars. OECD partner countries are represented by light blue bars. Member, partner and global averages are represented by red bars. Source: OECD Public Integrity Indicators database (as of 10 March 2026).
Senior elected and non-elected officials and officials in at-risk positions are often subject to increased scrutiny and oversight to mitigate potential integrity breaches, due to their position and level of influence (OECD, 2020[14]). Clear and proportionate procedures for public officials to identify and manage interests and/or assets may consider the functions occupied, levels of seniority and exposure to potential corruption risks.
The PIIs analyse five categories of high-level public officials in relation to implementation of conflict-of-interest regulations via submission of interest and/or asset declarations: members of the Government, members of parliament (MPs), members of the highest judicial bodies, public employees in a high-risk position and any newly appointed or re-appointed top-tier civil servant of the executive branch.
In terms of regulations, ministers (members of government) are almost universally obliged to declare their assets and/or interests globally (Figure 4.2). Legal requirements for MPs to submit interest declarations are also adopted in virtually all countries. Newly appointed or re-appointed top-tier civil servants are required to make disclosures in all countries, except Austria, Denmark, Germany, Kazakhstan and Sweden.
In practice, even if regulations are generally well-established monitoring is inconsistent (Figure 4.2). If declarations are published, the submission rate of declarations for at-risk officials is publicly available. However, as shown in the public information chapter, less than half of countries publish the declarations (in accordance with national privacy restrictions, which can differ depending on the type of office holder). In such cases, central monitoring of the submission rates can promote accountability of public office holders and ensure implementation of regulations. It also enables cross-cutting analysis of trends for preventive and enforcement purposes. When a responsible authority is mandated to monitor submissions, submission rates of responsible officials’ declarations are generally high.
One common challenge across all countries is the lack of monitoring of disclosures of newly appointed or re-appointed top-tier civil servants. OECD partner countries require more categories of officials to declare, but less frequently monitor whether the disclosures of officials are done in practice. High-ranking judges in OECD Member countries least often submit their declarations. In OECD partner countries, top-tier civil servants least often submit. Demonstrating leadership by example is essential for all senior public officials to maintain public confidence in their own integrity and the integrity of the executive, legislative and judicial branches of government (OECD, 2003[19]).
Note: Data for regulations is based on criteria values for “Any member of government / member of parliament / member of the highest bodies of the judiciary must submit an interest declaration, as a minimum upon entry and any renewal or change in public office” and “Any newly appointed or reappointed top-tier civil servant of the executive branch must submit an interest declaration”. Data for monitoring and practice are based on statistics collected to calculate the criteria values for “The submission rate of interest declarations from: members of the Government is 100% for the past six years / members of parliament is at least 90% for the past six years / members of the highest bodies of the judiciary is at least 80% for the past four years / newly appointed or reappointed top-tier civil servants of the executive branch is at least 80% for the past four years.”
How to read: In OECD Member countries, members of government (Ministers) are legally required to disclose private interests in 94% of OECD Member countries. Among these 94% of countries, the disclosure of private interests is fully monitored in 81% of countries. Among these 81% of countries, the average submission rate of interest disclosures by members of government is 95%. In OECD partner countries members of government (Ministers) are legally required to disclose private interests in 96% of OECD partner countries. Among these 96% of countries, the disclosure of private interests is fully monitored in 71% of countries. Among these 71% of countries, the average submission rate of interest disclosures by members of government is 72%.
Source: OECD Public Integrity Indicators database (as of 10 March 2026)
Digital interest disclosure systems are increasingly being adopted by governments to streamline submission of declarations, more so in OECD partner than Member countries. Currently, 63% of OECD partner countries use a digital platform to submit interest and/or asset disclosures, compared with 44% of OECD Member countries (Figure 4.3). An electronic system simplifies the submission process by making the declaration form more user-friendly, reduces errors, facilitates further analysis and verification of declarations, and improves data management and security (OECD, 2023[22]). Electronic submission proves statistically significant for high submission rates for the category of newly appointed or re-appointed top-tier civil servants. Enabling electronic submission of declarations that facilitates automatic updates and analysis of red flags, as well as interoperability between systems for data collection and verification, could facilitate monitoring and early identification of conflicts of interest.
Note: Data not provided by Japan and Switzerland.
Source: OECD Public Integrity Indicators database (as of 10 March 2026)
Conflict-of-interest regulations establish clear rules and responsibilities for public officials to manage and prevent conflicts of interest. However, strict regulations that are not supported with equally robust and consistent monitoring and verification procedures risk undermining the conflict-of-interest framework (OECD, 2020[14]). 97% of OECD Member countries and 75% of OECD partner countries have regulations that define circumstances and relationships that can lead to conflict-of-interest situations and establish the obligation to manage them, which shows strong commitment to preventing undue influence in the policymaking process. The more public officials that are required to submit, the more resources are needed to maintain the system. If financial resources are not sufficient, countries face trade-offs between a wide scope in regulations and investments in the needed verification, detection, investigation and sanctioning measures that give teeth to the system. A risk-based approach focusing on those officials most at risk, combined with the use of digital tools, helps countries faced with scarce resources prevent backlogs of unverified declarations. This also provides public officials with the support they need to act in accordance with the rules and strengthens enforcement.
In 2025, only 21% of countries (25% of OECD Member countries and 17% of OECD partner countries) verified at least 60% of declarations filed during the latest two full calendar years. This indicates that responsible authorities globally face challenges in verifying declarations. A risk-based approach to submission and verification that ensures reporting requirements are proportionate to officials’ risk profile and that institutional capacity is targeted toward verifying high-risk declarations can reduce the administrative burden of verification. Furthermore, using digital tools for automatic checks and red flags can provide a cost- and time-efficient solution to detect incorrect or missing information, allowing for effective investigations and ensuring that inaccurate or false information is not published.
Issuing recommendations to concerned officials on how to resolve an actual or perceived conflict-of-interest situation can help prevent a conflict-of-interest situation from turning into an integrity breach. However, only 31% of countries (28% of OECD Member countries and 33% of OECD partner countries) did so within 12 months of detecting a conflict-of-interest situation. Costa Rica has developed several good practice verification models, including cross-checking public officials’ sworn declarations with external databases and uncovering irregularities in high-risk sectors through monitoring, which has triggered detection of conflicts of interest and led to recommendations being issued.
Preventive measures are key, but an effective system also makes use of sanctions that are proportional to the offence and are applied fairly, objectively and in a timely manner. Indeed, a proportional sanctions regime ensures that enforcement is not arbitrary and that serious breaches are met with appropriate deterrents. Most countries (75% of OECD Member countries and 83% of OECD partner countries) have defined proportional sanctions for breaches of conflict-of-interest provisions. However, just over 1 in 3 OECD Member countries (39% in 2025) and half of OECD partner countries (50%) issue sanctions of different proportions in case of breaches in practice.
An effective system to manage pre- and post-public office and employment risks and other conflict-of-interest situations includes designing rules and procedures that mitigate risks, such as cooling-off periods, subject-matter limits, time limits, disclosure of post-term engagements by holders of at-risk positions, including abroad, and prohibiting any use of “insider” information after such officials leave the public sector (OECD, 2010[15]).
In 2025, 75% of OECD Member countries have established cooling-off periods for public officials in regulations, an increase from 70% in 2022. Cooling-off periods are less established outside the OECD, present in 63% of OECD partner countries. However, even where regulatory requirements exist, few countries track post-employment restrictions of ministers and senior civil servants in practice (Table 4.1). This monitoring gap means that authorities may not know whether their regulations are being observed in practice. It also leaves the conflict-of-interest framework vulnerable to misuse or abuse, as there is no accountability mechanism to ensure public officials’ private interests (such as the prospect of employment in a sector they regulate) do not interfere with their official duties. This can result in undue influence on government policies if not properly regulated, leading to risks of conflicts of interest and regulatory capture (OECD, 2021[16]). Establishing rules is insufficient if oversight entities do not monitor whether the rules are being followed in practice (OECD, 2021[16]).
How to read: In Greece, post-employment integrity is not tracked for ministers or for top-officials. There are regulations stating mandatory cooling-off periods for public officials.
Note: In France, the High Authority for Transparency in Public Life (HATVP) does not have the means to collect information on the movement of ministers into sectors they formerly regulated, but movement is managed as part of the revolving doors control exercised by the HATVP. In Finland, while some ministries track movement, not all do and the value is “not tracking”.
Source: OECD Public Integrity Indicators database (as of 10 March 2026)