Sweden’s Action Plan Against Corruption and Undue Influence 2024-2027 is its most comprehensive anti-corruption strategy to date. This chapter assesses the Action Plan’s strengths and areas for improvement. It recommends that in future Sweden could develop its strategic framework against corruption and unlawful influence into a full national anti-corruption strategy. Such a strategy should be based on a fuller situation analysis, and more ambitious objectives and actions to implement them. It should also incorporate indicators to support implementation and ensure the strategy is producing its desired aims. Sweden should also enhance its monitoring framework for future strategies, including by measuring implementation rates, and strengthen the strategy’s evaluation process.
OECD Integrity Review of Sweden
Abstract
The Recommendation on Public Integrity sets out that a strategic approach to public integrity is essential for building effective public integrity systems, and recommends that countries develop such an approach for the public sector that is based on evidence and aimed at mitigating public integrity risks (OECD, 2017[1]). A strategic approach to anti-corruption and integrity allows governments to identify challenges, establish priorities and objectives, define specific actions for achieving desired outcomes, set responsibilities and build consensus, and facilitate effective implementation through monitoring and evaluation processes based on indicators for measuring success. In short, a strategic approach, usually through the development of strategic documents, can shift a country’s focus from ad hoc anti-corruption and integrity policies relating to specific aspects of its integrity framework to a coherent and comprehensive integrity system (OECD, 2020[2]).
In the Swedish public sector, strategic documents are a form of non-traditional governance, meaning they are not a formal means of controlling or directly influencing different actors. Neither authorities nor individual actors are bound to work based on a strategy, and the strategy document cannot be used as a reason for an authority to deviate from the tasks it has been set in its instructions or special assignments. Instead, Swedish public sector strategic documents emphasise voluntariness, collaboration and co-ordination, and have been used as a way of linking different control measures to each other by explaining the connections, clarifying the division of responsibilities, and describing the expected results and impacts. Strategic documents take several forms in the Swedish public sector, including strategies, action plans, information brochures, letters and draft bills, though the Statskontoret has recently noted that it is often not clear why a particular form has been chosen (Statskontoret, 2023[3]). Whatever form is chosen, however, the Swedish government tends to use strategic documents as a tool to address complex societal challenges, when different interventions need to cut across different policy areas, or when the government wants to focus attention on a particular issue (Statskontoret, 2023[3]).
In recent years, Sweden has developed its strategic approach to integrity and anti-corruption. The 2024-2027 Action Plan Against Corruption and Undue Influence (APACUI) is Sweden’s most comprehensive strategic document on anti-corruption to date. It aims to set out a holistic approach to meeting the breadth of challenges related to corruption and unlawful influence across the public sector, with a view to maintaining a high level of trust in public administration, sustaining citizens' confidence that public operations are conducted correctly, and to ensuring that public funds continue to be used correctly.
This chapter aims to contribute to Sweden’s strategic approach to public integrity by assessing the APACUI and drawing lessons which can be applied in future strategic planning. It analyses the APACUI across the whole strategy development and implementation cycle, and recommends that:
Sweden could develop its current strategic approach into a National Anti-Corruption Strategy
Future strategies could be based on a more comprehensive situation analysis which identifies opportunities, risks and existing mitigations
Sweden could set more ambitious objectives and clearer activities to achieve them
Sweden could develop indicators to support implementation, monitoring and evaluation of strategic objectives and ensure the strategy is producing its desired aims
Sweden could establish a stronger, more transparent monitoring process which measures the implementation rate of strategic activities
Sweden could strengthen its evaluation process for the APACUI and future strategic planning
2.1.1. Sweden could develop its current strategic approach into a National Anti-Corruption Strategy
In the last five years, Sweden has developed its strategic approach to public integrity. Until 2021, Sweden did not have a dedicated strategic document for anti-corruption and public integrity. Instead, the government maintained that policies to prevent and fight corruption should be mainstreamed throughout the Swedish public sector in co-operation with the responsible Government Offices (GRECO, 2019[4]). This approach was supplemented by more sector-specific strategic documents which set out strategic objectives on integrity in their respective fields. For example, the 2017 National Public Procurement Strategy included seven policy objectives, one of which related to enhancing "Legally certain public procurement” which included the prevention of corruption (Ministry of Finance, 2017[5]).
In December 2020, Sweden adopted its first single strategic document on anti-corruption and integrity, the 2021-2023 National Anti-Corruption Plan. The Plan focused on corruption prevention in central government agencies including the Government Offices, with the aim of providing public authorities with tools and best practices on corruption prevention. Overall, the Plan was welcomed as a first step towards improving the effectiveness and co-ordination of anti-corruption work in Sweden (Transparency International, 2019[6]). But it was also criticised for its focus on only a narrow part of the public sector, for not defining specific priorities or targets, and for not undergoing sufficiently broad stakeholder consultation (European Commission, 2021[7]).
The APACUI, adopted in July 2024, sought to address many of these criticisms and to develop Sweden’s strategic framework further. Compared to the 2021-2023 Plan, the APACUI has a wider coverage, is based on broader stakeholder consultations, and establishes stronger implementation mechanisms (Figure 2.1). The strategic framework for upholding public integrity has therefore matured in the last five years. Sweden could now build on this recent progress and develop its strategic framework even further into a full National Anti-Corruption Strategy.
Note: Data in the first chart relates to the 2021-2023 National Anti-Corruption Plan and in the second chart to the 2024-2027 Action Plan Against Corruption and Undue Influence.
Source: OECD Public Integrity Indicators, 2024
Although the APACUI has a broad coverage with strategic objectives across various aspects of government including HR, fraud and public financial management, future strategies could extend coverage into the private sector. Strong anti-corruption and integrity strategies aim to cultivate a culture of integrity across the whole of society in recognition that actors outside of government are also responsible for combatting corruption, and that effective responses to the biggest corruption risks, such as organised crime, often require a whole-of-society approach. It is therefore important to include strategic objectives to mitigate corruption risks in, for instance, private and public corporations, state-owned enterprises, and public-private partnerships, or in high-risk sectors such as infrastructure, housing or healthcare (OECD, 2020[2]). These sectors are being increasingly recognised as high-risk areas for corruption (Shaheer et al., 2019[8]; Castro, Phillips and Ansari, 2020[9]; Pyman and Heywood, 2024[10]) and, of the OECD countries which have anti-corruption strategies, 67% have developed strategic objectives for the private sector and 48% have included them for high-risk sectors (OECD, 2024[11]). Like many of its peers, therefore, Sweden could extend the coverage of its strategic framework beyond the public sector to cover the whole of society, thereby developing its strategic approach to integrity from a public sector action plan to a National Anti-Corruption Strategy.
To do so effectively, to mitigate the risk that an expanded strategy is so ambitious it becomes meaningless, and to ensure it becomes an instrument of change rather than only summarising work which public authorities were already doing, Sweden could adopt a stronger theory of change in its strategy development. Theories of change enable governments to identify vulnerabilities, prioritise objectives and areas for action, and ensure implementation through monitoring and evaluation. Several theory of change frameworks have been developed (Pyman and Heywood, 2020[12]; Marquette and Peiffer, 2020[13]), and most describe strategy development and implementation in terms of a series of cyclical phases (Figure 2.2).
Source: OECD elaboration
The rest of this chapter explores these phases of strategy development and implementation and makes suggestions, based on analysis of the APACUI, for how Sweden could work through them in future strategic planning on anti-corruption and integrity.
Strong anti-corruption strategies are based on a comprehensive analysis of the risks that are most harmful to public integrity and their causes as well as the challenges and opportunities for reform. At a minimum, situation analyses identify specific risks to public integrity, the actors likely to cause or be affected by risks, and the expected likelihood and impact if risks materialise. Situation analyses are used to select the most effective measures for mitigating risks and for taking opportunities when the strategic objectives and activities are defined later in the process (OECD, 2020[2]).
2.2.1. Future strategies could be based on a more comprehensive situation analysis which identifies opportunities, risks and existing mitigations
The APACUI was based on a broad evidence-gathering process and engagement with a range of actors with knowledge and experience of anti-corruption in the public administration. The APACUI drew from a wide-ranging analysis, conducted by the Statskontoret and published in December 2023, which assessed Swedish authorities’ integrity work and made recommendations for improvement (Statskontoret, 2023[14]). The Ministry of Finance also employed a staff assistant to follow up on the 2021-2023 Anti-Corruption Action Plan who, through interviews with employees of the Statskontoret and other government agencies and a survey conducted in conjunction with the Statskontoret and Ministry of Finance, made recommendations for improving Sweden’s integrity framework. Several recommendations from these reports were adopted as commitments in the APACUI. The Government Offices also held several roundtable discussions between February 2023 and March 2024 on anti-corruption and unlawful influence which informed the development of the APACUI (Table 2.1). Finally, the APACUI drew from various international recommendations from GRECO, the European Commission, the OECD, and through the UNCAC Implementation Review Mechanism and Sweden’s membership of the Open Government Partnership.
Source: APACUI and information received from Swedish authorities in preparation for this report.
This evidence gathering process allowed the Ministry of Finance and Ministry of Justice to assemble a broad picture of the current state of Sweden’s integrity framework and to identify action areas for the APACUI. There is scope, however, to develop future situation analyses further to provide a greater sense of ownership and co-ordination, to enable the better quantification and prioritisation of risks and opportunities, and to clarify the connection between the current situation and areas for action.
Firstly, given the cross-cutting nature of corruption risk and anti-corruption work, Sweden could take a more interinstitutional approach to strategy development. Taking an interinstitutional approach helps to build a common vision which incorporates diffuse policy areas and strategic objectives. It can also increase cross-sectoral buy-in for the strategy, which is fundamental to developing a whole-of-society or ‘system’ approach to integrity (OECD, 2020[2]). The Statskontoret has noted that this sort of interinstitutional support and co-ordination has been a particular challenge in strategy development in Sweden, particularly where it has not been clear what the purpose of the co-operation was (Statskontoret, 2023[3]).
For anti-corruption work, Sweden has sought to foster interinstitutional working through the Statskontoret-led Forum for Collaboration Against Corruption, which comprises the Brå, the Swedish Financial Management Agency, the Swedish Competition Authority, the Swedish Police Authority and the Swedish Procurement Authority. The Forum has been a useful platform for increasing knowledge sharing and collaboration between authorities, but it is currently only an informal network with no decision-making powers of its own. Its contribution to the development of the APACUI was therefore advisory, largely through its members’ participation in the roundtables set out above. In future, Sweden could improve its strategic framework by giving the Forum a more central role in strategy development and implementation. For several new, complex or cross-cutting issues, the Swedish government has established co-ordinating units or agencies to provide public authorities with advice and to promote, co-ordinate, analyse and evaluate the government’s overall work on the issue (Statskontoret, 2022[15]). Sweden may not wish to formalise the Forum’s role to the extent of these other co-ordinating units or agencies, or as far as some other OECD countries have done (Box 2.1). At the least, however, Sweden could give the Forum itself (rather than just its members) more prominence in the assembly of evidence, the analysis of corruption risks and opportunities, the setting of appropriate objectives and activities, and in monitoring and evaluating the strategy. If Sweden were to expand the scope of the strategic framework to include the private and other high-risk sectors, membership of the Forum could also be expanded to include authorities responsible for those sectors including, for instance, the Swedish Payment Authority or SALAR. The advantages of taking this approach could be various, including that it could build ownership of the strategy, meaning the strategic approach is adopted across government offices and agencies rather than being seen as belonging only to the Ministries of Finance and Justice as the leading drafting authorities. It could also improve the combination of perspectives and the identification of the causes of problems and relevant solutions.
The Joint Anti-Corruption Unit (JACU) in the UK’s Home Office is responsible for developing and implementing the UK’s strategic approach to anti-corruption. JACU is a joint integrated unit, meaning it was established by embedding employees from several government agencies and departments into a single unit. JACU is responsible for ensuring better co-ordination of domestic and international anti-corruption efforts and promoting stronger links between anti-corruption and other related agendas such as international illicit finance and organised crime. JACU co-ordinates anti-corruption work across government, represents the UK at international anti-corruption forums and develops the UK government’s relationships with business, civil society and foreign governments.
Among the primary instruments of this work was the development of the UK’s 2017-2022 Anti-Corruption Strategy. Drawing on its range of embedded expertise along with a broad consultation process, JACU analysed a range of corruption risks and set out objectives and actions across six priority areas to achieve three long-term outcomes:
1. Reduced threat to national security, including from instability caused by corruption overseas
2. Increased prosperity at home and abroad, including for UK businesses
3. Enhanced public confidence in domestic and international institutions
The UK’s Anti-Corruption Strategy expired in 2022. JACU is currently developing a successor strategy due for publication in 2025.
Source: (HM Government, 2017[16])
Secondly, Sweden could broaden the evidence base to better inform the situation analysis for future strategic planning. Strong situation analyses draw on a wide range of internal and external data to identify risks and opportunities in countries’ integrity frameworks and which should therefore shape and inform strategic objectives. To identify risks and opportunities in strategy development, a combination of both qualitative data (e.g. process analysis, employee interviews, risk assessments, surveys, desk research) and quantitative data (e.g. analysis of statistical and historical data) should be used. Some countries are also leveraging big data, predictive analytics, and social media to identify trends and correlations in their environment to improve their public integrity frameworks (OECD, 2021[17]; OECD, 2019[18]).
The Ministry of Finance is taking steps to collect further evidence on corruption. For example, it has recently tasked the Statskontoret with surveying experiences of corruption across government agencies. In addition to the range of evidence gathering set out above, this survey could offer insights into the incidence and nature of corruption in public authorities which could inform future strategic planning and set a benchmark for measuring progress in public integrity work. To improve evidence gathering further, Sweden could broaden the scope of this survey to assess corruption risk and the effectiveness of integrity mechanisms across public authorities, as other OECD countries have done (Box 2.2). Suggestions for how the survey could be enhanced are included in Annex A). Even if only conducted for a limited range of high-risk authorities in the first instance, such a survey could move Sweden’s situation analysis beyond perceptions and experiences of corruption to building a clearer picture of the risks and opportunities across public authorities based on administrative data.
Since 2002 South Korea’s Anti-Corruption and Civil Rights Commission (ACRC) has annually evaluated public institutions’ anti-corruption initiatives through the Anti-Corruption Initiative Assessment (AIA). At the beginning of each year, the ACRC develops assessment criteria and draft indicators in consultation with government offices. In November, government offices submit self-assessment reports to the ACRC, including data and official documents to allow for verification. The ACRC evaluates public authorities’ reports and assigns assessment scores, and in early December each organisation is ranked into performance groups from one to five, with one being the highest performing. ACRC provides separate reports to all evaluated institutions with specific scores and comments on areas for improvement. In addition, ACRC offers consulting services to interested institutions to troubleshoot and address specific areas for reform.
The AIA assessment is made across five areas: 1) anti-corruption infrastructure; 2) enhancement of transparency and credibility of policy; 3) eradication of corruption-causing factors; 4) improving a culture of integrity in the public sector; and 5) encouraging anti-corruption activities and corruption reports. Internal assessment teams within the ACRC are assigned to each area. Quantitative assessment is also carried out by experts from the private sector and academia to evaluate areas such as the feasibility of public authorities’ initiatives, achievements, and best practices.
Along with several other indexes and surveys, including international and domestic corruption perception and experience surveys, the AIA is used to inform South Korea’s strategic framework, with strategic objectives being drawn from the findings of the evidence gathering process.
Source: (UNDP, 2016[19])
Finally, Sweden could more effectively analyse the information obtained through evidence gathering to identify risks, opportunities and existing mitigation measures. Doing so would enable the prioritisation of strategic objectives and activities and would help to ensure they are based on need. Section 2.4 of the APACUI describes how commitments in the APACUI were based on issues that the government or other national and international actors have identified as important in their analyses of the Swedish system. In future strategy development, Sweden could build on these assessments more effectively by sorting and analysing the findings of its evidence gathering to quantify and compare findings and define priorities. The Forum could be well-placed to undertake this analysis given its range of experience and responsibility for different aspects of Sweden’s integrity framework. This sorting process could include:
Categorising integrity risks, by organising the identified risks and opportunities into relevant categories such as organisational culture, policies and procedures, risk management, staff behaviour, leadership commitment, and external factors;
Identifying patterns and trends, by identifying recurring themes, common issues, or areas where Sweden consistently performs well or faces challenges;
Considering external factors, by taking account of factors that could influence integrity, such as regulatory changes, societal expectations, or economic conditions, and understanding how these external factors may contribute to, exacerbate or mitigate integrity risks.
In addition, Sweden could cross-reference assessment findings with existing processes and standards, including existing integrity standards, strategic documents, codes of conduct, and legal requirements, to understand whether existing mitigations exist. To do so, Sweden could map existing controls and mitigation measures for each identified issue to understand how far the integrity framework is already mitigating and accounting for the identified risks. Where controls do not already exist or where they are deemed inadequate, strategic objectives should be developed to reinforce controls or develop new tools for tackling the root cause. Figure 2.3 could help to guide this mitigation mapping process.
Source: Adapted from (UNODC, 2020[20])
By undertaking a broader situation analysis, including sorting issues and connecting them to existing mitigations, Sweden could better identify the major risks, challenges and opportunities in its integrity framework which should form the basis for the content of the strategy. By connecting the situation analysis, objectives and actions in this way, the strategic framework could become a better-informed instrument of change for improving Sweden’s integrity framework.
2.3.1. Sweden could set more ambitious objectives and clearer activities to achieve them
The APACUI serves as both a strategy and an action plan as it contains both objectives and activities in each area. These objectives and activities are supported throughout by a narrative which describes the rationale for each activity and makes the connection between activities and the desired outcomes. There is scope in future strategic planning, however, to develop more ambitious objectives for reform based on the risks and opportunities identified in the situation analysis, and more detailed activities which make clear how the work of individual actors and authorities contributes to a whole-of-society approach to integrity. Doing so could also enable responsible authorities to track and measure implementation more effectively.
Setting evidence-based, ambitious objectives
Primary strategic objectives are the guiding stars for those responsible for executing the strategy, as they establish the end to which the work is being done. These objectives must be aligned with the strategy’s overall vision, as well as sector-specific policy, and must take account of the risks and opportunities identified in the situation analysis to maintain a link to the contextual reality. Primary objectives then cascade down to more specific secondary objectives, actions, indicators, milestones, and targets. As the Recommendation on Public Integrity sets out, by moving through these stages governments can be clear about why they are doing what they are doing, the steps they will take to achieve their aims, and the measurements they will make to know whether or not they were successful (OECD, 2017[1]; OECD, 2020[2]).
The APACUI contains seven primary objectives and 31 secondary objectives (Table 2.2). The primary objectives, as described in the introduction of the APACUI, set the priority areas for action in Sweden’s integrity framework and the secondary objectives offer more detail about how advances in these areas will be made and the change to which they will lead. The objectives in the APACUI are mostly specific, measurable, actionable, realistic and time-bound (SMART), although rather than being in each strategic objective itself the individual SMART elements are often distributed between the objectives and ensuing explanatory narrative.
Note: The objectives set out here are not explicitly described as primary and secondary objectives in the APACUI. The primary objectives here are taken from the introduction rather than the section headings throughout Section 1 of the APACUI.
Source: APACUI
In several instances, however, the secondary objectives relate to work which has already been completed (for example, secondary objectives 10, 11, 12, 13 in Table 2.2) or to proposals which were already undergoing consultation ahead of government and parliamentary decisions (secondary objectives 23, 24 and 25 above). In other cases, objectives relate to reviews which had already begun by the start of the strategy’s review period. As a result, while the APACUI’s development prompted several pieces of new work which otherwise would not have been done, in other cases the APACUI is less an instrument of change for improving the integrity framework and more a summary of work which Swedish authorities have already done or are doing. Swedish officials explained in preparation for this report that this was in part because measures which were not already agreed and funded in the national budget could not feature in the APACUI. This is a common problem in strategy development and including un-resourced or unagreed measures can mean strategies become meaningless.
In future strategic planning, however, if Swedish authorities were to undertake a more comprehensive situation analysis with a fuller assessment of risks and opportunities, as described above, it could help to identify where new agreements or funding for activity might be necessary. In this way, although in Sweden strategies themselves are not formal steering mechanisms, the process of strategy development could become a means of identifying and supporting the development of more formal steering mechanisms. Swedish authorities have already used strategy development like this in other instances. In several of these cases, strategies have been used to develop and announce new assignments, increases in appropriation, or the reprioritisation or reshaping of other committed activities (Statskontoret, 2018[21]). In future, therefore, there could be scope for the Ministry of Finance and Ministry of Justice (or the Forum if it is given more of a role) to draw on an enhanced situation analysis to identify areas which require new formal steering measures and which could therefore feature in the strategy as new, ambitious and evidence-based objectives.
Setting clear activities
Action plans operationalise the objectives in a strategic plan into tangible short-term activities. Through cross-referencing between strategic plans and action plans it should be clear what the government plans to do (i.e. the strategic objectives) and how it is going to do it (i.e. through specified actions) (OECD, 2020[2]). OECD countries have approached the development of action plans differently, with some, like Sweden, including activities and objectives in the same strategy document and others grouping actions into a separate document with a shorter reporting period (Box 2.3). Regardless of the form, however, well-drafted action plans use language that is clear, concrete and straightforward to minimise room for misinterpretation. Ideally, each line of an action plan should adhere to a specific structure and answer questions such as “what”, “who”, “when”, “if”, and “how”:
What: Identifying how the concrete actions link to the objectives of the strategy.
Who: Determining the area / unit responsible for implementing actions.
When: Establishing the timeframe for implementation.
If: Recognising potential risks to implementation.
How: Identifying indicators for measuring successful implementation (Council of Europe, 2008[22]).
Estonia’s Anti-Corruption Action Plan 2021-2025
Estonia’s Anti-Corruption Action Plan 2021-2025 retained the objectives of previous anti-corruption strategies, which were to: 1) promote awareness of corruption; 2) increase the transparency of decision-making and activities; 3) develop the investigative capacity of investigative bodies; and 4) prevent corruption which threatens security. The 2021-2025 Action Plan explains the ongoing relevance of these objectives through a comprehensive situation analysis which included a review of recent developments and achievements in Estonia’s integrity work. On the basis of this situation analysis and justificatory narrative, 61 forward-looking activities across eight primary objectives are set out in an appended action plan which runs for the duration of the 2021-2025 Action Plan’s reporting period. The action plan contains information on the specific activity, the objective to which it will contribute, the responsible actors including any other involved parties, and the budget for each activity.
Lithuania’s National Anti-Corruption Agenda 2022-2033
Lithuania’s National Anti-Corruption Agenda 2022-2033 is based on a wide analysis of the international and domestic context which includes a comprehensive analysis of the country’s anti-corruption environment. The Anti-Corruption Agenda’s overarching aim is to create a corruption-resilient environment in the public and private sectors. This overarching aim is then elaborated into three primary objectives, which are measured through a series of outcome indicators across the 11-year reporting period, and are further developed into 19 progress targets or secondary objectives.
The Anti-Corruption Agenda is implemented in three phases, for which four-year Agenda Plans are prepared. The Agenda Plans are prepared by the Agenda co-ordinator appointed by the Government, with the participation of the bodies whose heads are the managers of the State budget allocations and of the budgetary bodies subordinate to them. The Agenda Plans set out a range of specific activities, refer to a variety of data sources, identify lead organisations for each action, and contain outcome-level indicators with target values. Annual monitoring reports are published online.
The APACUI explains through its narrative sections how specific activities will operationalise the strategic objectives. This narrative presentation makes it difficult to determine exactly how many individual actions the APACUI contains, but there are instances throughout in which it is clear what will be done, who will be responsible, and the timeframes involved. For example, it is clear that one component of operationalising the strategic objective in Section 1.3 of the APACUI relating to the transparency of party funding and contacts with lobbyists is that a parliamentary committee will review the existing regulations on political financing and submit proposals for improvement by 15 February 2025.1
In several instances, though, the specific steps which Swedish authorities will take to achieve a given objective could be more clearly set out. Several activities under strategic objective 1.1 related to co-operation between authorities and follow-up on anti-corruption work are an example. The first activity in this section relates to targeted promotion and outreach work on integrity and is assigned to the Statskontoret. However, there is little detail in the APACUI about specific outputs or steps which will be taken to develop existing and new support and outreach activities, how these will be tailored to authorities with different activities, resources and risk profiles, and when milestones in this work might be. Likewise, the activity assigned to the Statskontoret to develop follow-up on authorities’ work could be clearer about specifically how the Statskontoret will monitor and report on agencies’ work on corruption and unlawful influence and when this work should be completed. The Statskontoret has previously noted that in the last decade where Swedish government strategies have not been clear about specific responsibilities, co-ordination structures or expectations they have less effectively contributed to the government’s governance of a particular issue (Statskontoret, 2023[3]; Statskontoret, 2018[21]). Future anti-corruption strategies could build on this lesson, by extracting activities from the narrative sections and setting out more clearly what the actions are, who is responsible for them, when they will happen, how they will be measured, and how they will contribute to the government’s wider aims. Doing so could also aid the development of stronger monitoring and evaluation processes based on concrete indicators.
2.3.2. Sweden could develop indicators to support implementation, monitoring and evaluation of strategic objectives and ensure the strategy is producing its desired aims
Developing indicators, along with determining appropriate baselines, milestones, and targets, is an important aspect of anti-corruption strategy design, and several OECD countries now include them in their strategies and action plans. Indeed, of the OECD countries with an anti-corruption strategy, 50% have included outcome-level indicators for their strategic objectives, and 39% have set target values. In addition, 33% of countries’ action plans contain dedicated outcome-level indicators and baseline targets (Figure 2.4).
Note: The figure displays data for the PIIs criteria: All strategies contain outcome-level indicators for the public integrity objectives; All strategies set target values for all outcome-level indicators; All action plans include objectives with dedicated outcome-level indicators, baseline targets, and a list of activities. Canada, Iceland, Ireland, and Norway do not have a strategy in place. Data is not available for Belgium, Colombia, France, Germany, Israel, Italy, Japan, Korea, Luxembourg, New Zealand, Poland, Slovenia, Spain, and the United Kingdom. All data was gathered in 2023, except for Sweden and Hungary which was gathered in 2024.
Source: OECD Public Integrity Indicators database (data extracted on 9 May 2025).
Ideally, indicators should be developed in the initial stages of objective and activity design to give those responsible for implementation clear guidance on specific results to achieve, the means by which to achieve the results, and how success will be measured. Some indicators may align with strategic objectives while others may relate more to the activities outlined in an action plan. Either way, strong indicators provide a measure, tracked systematically over time, that demonstrates positive, negative, or no change with respect to progress towards a stated target (Johnsøn et al., 2011[25]; OECD, 2020[2]). They are therefore fundamental to governments’ abilities to measure the efficiency and effectiveness of their interventions, and ultimately how far the vision outlined in their strategy has been achieved.
The APACUI does not contain indicators, which makes it hard for the Ministry of Finance and Ministry of Justice to track and measure implementation of the APACUI’s measures and their impact. In future strategic planning, Sweden should incorporate:
Output indicators, which refer to actions that have been completed, such as establishing new practices, training staff, etc. Output indicators show that proposed actions are taking place to planned timelines, and allow for adjustments to timelines if unforeseen challenges arise.
Outcome indicators, which demonstrate the extent to which actions have achieved the objectives. Outcome indicators are typically more relevant for tracking the implementation of strategic objectives (rather than individual actions), as they measure the effects of activity over the longer term (e.g. reduction in the time taken to deliver key public services (e.g., issuing permits or licenses), number of complaints received and resolved by ombudsmen).
Impact indicators, which aim to measure the long-term effects of activity on levels of corruption or on other economic, environmental or social issues. Measures can include changes in perceptions or experiences of corruption. For public integrity, proxy indicators, such as improvements in efficiency or capability, can be used as outcome indicators to help offset the challenge of measuring levels of corruption.
In practice, the process of developing indicators should involve several stages, though how authorities have interpreted and addressed these principles may not necessarily need to be publicly represented within the text of the strategic document itself. These principles include:
Use simple and concrete indicators: Focus on manageable indicators to monitor implementation and impact, emphasising concrete, measurable results over abstract notions like ‘corruption is reduced’. Indicators should not try to measure several aspects at once but should focus on one element of the objective. For instance, an indicator measuring engagement in training and increased understanding of the integrity framework should be split into two (increased engagement in training + increased understanding of the integrity framework).
Define where the data is produced and who is responsible for providing it: For each indicator, clarify which area, unit or function is responsible for collecting the necessary information to inform the indicator, how the data is collected and how often, and how the monitoring authority will be able to access it.
Keep resources in mind: Acknowledge that measuring success requires resources. While strategies may propose ambitious methods for measuring progress, implementation may falter without adequate resources. Where possible, use information that is already collected or can be easily accessed.
Anticipate difficulties and risks: Reflect on possible difficulties and risks of collecting and analysing data and draw up potential solutions to mitigate these challenges.
Establish baselines: Provide a starting point for measurement by determining baseline data for each indicator. Historical data or initial assessments can contribute to establishing these baselines.
Set targets including target dates: Establish targets for each indicator defining what the expected performance is for a set date.
Be cautious with indicators of non-immediate impact: Indicators related to non-immediate impact may not be the optimal choice for measuring success. Action plans primarily serve as management tools, so should prioritise the status and immediate impact of implementation (‘e.g. training on conflict-of-interest management delivered’) over debatable non-immediate impact (‘more ad hoc declarations of interests’).
Combine qualitative and quantitative indicators: Impact may not always be fully expressed quantitatively. For instance, a reduction in conflicts of interest may not mean that personal interests are being better managed but could instead mean officials have stopped making declarations. It is therefore advisable to combine qualitative and quantitative indicators for a more reliable assessment. For instance, an indicator measuring the number of interest declarations could be combined with one measuring the extent to which declarations were detailed, accurate and timely.
Check the validity of the measurement defined: Ensure the defined indicators enable the organisation to be confident the objective has been reached. For instance, only measuring the number of training modules delivered does not mean employees’ capacities have increased. Further indicators measuring, for instance, their understanding, engagement, and confidence in executing their duties may need to be added, and data could be collected at different times (including directly after training and several months afterwards to gauge lasting impact).
Be careful of adverse incentives: Some indicators can create adverse incentives. For example, only using an indicator measuring the number of cases handled correctly could incentivise relevant units not to report poorly handled cases. This risk can be mitigated by setting realistic benchmarks to encourage accurate reporting (i.e. realising that a benchmark of 100% well-handled cases may be unlikely and discouraging).
By drawing on these principles, Sweden could develop a comprehensive set of indicators that enable meaningful measurement and evaluation of future anti-corruption strategies and action plans. Regular review and adjustment of indicators could contribute to the continuous improvement of the strategy’s implementation over time. Example indicators for the existing commitments in Section 1.1 of the APACUI are in Figure 2.5. These indicators are indicative, and Sweden should elaborate indicators of its own using the principles set out above, along with baselines for each indicator at the beginning of the reporting period. Measurements made through the indicators at the end of the reporting period could become benchmarks for subsequent strategic planning.
Note: The example output and outcome indicators presented here are indicative, and Sweden should apply the principles set out above to their own indicator development in future strategic plans. The primary objective, strategic objectives and planned activities included here are those listed under objective 1.1 in the APACUI.
Source: OECD elaboration based on the APACUI.
Designing strategic objectives and activities based on a comprehensive situation analysis is an essential process for guiding anti-corruption work through a robust theory of change towards defined ends. Without regular monitoring and evaluation, however, it is impossible for countries to move beyond stating intent to being sure of how far their aims have been achieved. Monitoring and evaluation are two related yet distinct parts of a wider process:
Monitoring involves collecting and analysing information on the immediate results of an activity, generally through output-level indicators. Monitoring feeds information back from the implementation level to policymakers and planning and oversight units, thereby enabling effective steering, informed decision-making, and improved policy design. Monitoring is the basis of organisational learning and the creation of knowledge that can be used to improve effectiveness.
Evaluation focuses on understanding the mid- and longer-term outcomes of a policy or action and the reasons behind that outcome having (or not having) been reached, usually through outcome indicators. Strong evaluations often take account of a broad range of factors, since outcomes often depend not only on the policy's implementation but also on variables beyond the control of the implementation process, such as political or economic factors. Effective evaluation of one strategy should inform the development of the next (OECD, 2017[26]).
The primary goal of establishing a monitoring and evaluation system is to be able to understand how effectively and efficiently strategic objectives have been met, what factors influenced the extent of implementation, and what improvements could enable stronger implementation in the future. The Recommendation on Public Integrity makes clear that all countries should establish strong monitoring and evaluation frameworks around their strategic and operational plans (OECD, 2020[2]; OECD, 2017[1]).
In Sweden, there is an established process for monitoring the individual measures in the APACUI and for evaluating their impact at the end of the action plan’s reporting period. There is scope in relation to the APACUI and future strategies, however, to enhance the monitoring and evaluation process and develop a stronger feedback loop into future planning.
2.4.1. Sweden could establish a stronger, more transparent monitoring process which measures the implementation rate of strategic activities
The monitoring process for the measures in the APACUI includes both formal processes relating to agencies’ general finances and resourcing to more informal dialogues relating to individual assignments. In all cases, the monitoring process takes place in relation to agencies’ assignments rather than there being a dedicated monitoring process for the APACUI itself, though discussions may make reference to the APACUI.
In terms of the more formal monitoring mechanisms, all Swedish government agencies are subject to an annual review process in which the responsible minister or state secretary meets the agency’s Director General to discuss, for example, the agency’s overall financial situation. Agencies are also required to develop and publish annual reports which, according to regulation Förordning (2000:605) om årsredovisning och budgetunderlag, serve as a basis for the government's assessment of the agency's results and the implementation of its activities. In relation to individual assignments, each assignment contains a requirement for the responsible government agency to make a final report on implementation to the government. During an assignment’s reporting period, the monitoring process is less formal. Once an assignment has been issued, the responsible civil servant in the relevant ministry may hold several follow-up meetings with the agency to ask how implementation is going. The agency can also ask the responsible civil servant at any time for this kind of conversation. During these conversations any aspect of the implementation of the assignment can be raised, including questions about the financing or resourcing of individual activities. The Government Offices can then decide, through a formal government decision, whether to provide additional funding or to change the nature or deadlines of the assignment. This approach to monitoring the assignments underpinning the APACUI’s activities reflects the formal nature of assignments as governance tools in Sweden compared to the informality of strategies.
There is scope, however, for Sweden to enhance the governance process for assignments related to anti-corruption work by developing a stronger monitoring process around the APACUI and future strategic planning. At present, each of the assignments underpinning the APACUI’s measures are monitored individually, with no single body responsible for collating information on implementation at an aggregate level. This makes it harder for the responsible ministries to identify trends in implementation, such as shared challenges or difficulties with implementing certain types of activity, and therefore means decision-making and steering related to ongoing assignments is not as effective as it could be.
To improve the monitoring of assignments related to anti-corruption, Sweden could, therefore, assign responsibility for monitoring implementation at an aggregate level. If the Forum is given a more central role in strategy development and implementation it could take the lead in such a process. Of the OECD countries which have an anti-corruption strategy, 91% have taken this kind of approach to monitoring strategy implementation. Some countries have developed solutions including sophisticated digital tools for monitoring and regularly publishing data on implementation (Box 2.4). In Sweden, an aggregated monitoring process could, at the least, collect information on progress against the indicators and targets set out in the action plan, collate the implementation rate of the planned activities, and form conclusions and recommendations regarding, for instance, the need for government decisions on new funding or deadlines. Beyond these basic elements, the process could also incorporate consultations with relevant state agencies and external stakeholders including civil society organisations and representatives from the private sector. Including this broader range of actors could help to ensure the monitoring process remains reliable and useful by mitigating common risks in monitoring processes, including optimism bias or that reporting authorities try to game the indicators to demonstrate a stronger performance (OECD, 2017[26]). And finally, Sweden could publish a regular monitoring report to better communicate progress and results on anti-corruption work to internal and external stakeholders, including the wider public, to signal commitment to and the credibility of integrity efforts.
Ukraine’s National Anti-Corruption Strategy 2021-2025 (NACS) comprises three chapters, 16 areas, 73 problems, 271 expected strategic results and 1 146 measures to be implemented by 109 public bodies. The National Authority for Corruption Prevention (NACP) is responsible for monitoring the implementation of the NACS, and has developed the online interactive Information System for Monitoring the Implementation of the State Anti‑Corruption Programme (ISM SACP) to do so. The ISM SACP allows the NACP to manage public and internal communication with implementing bodies. The system allows for transparent public monitoring of allocated responsibilities with deadlines for outputs and benchmarks to measure outcomes. Non-governmental actors can provide their own assessments regarding implementation, including insights into challenges to implementation and suggestions for improvement.
As of August 2025, the ISM SACP showed that 414 measures (36%) of the total 1 146 measures were fully completed, and 112 measures (10%) partially completed. 237 measures (20%) were in progress, with a deadline of December 2025. 252 measures (22%) had not yet been started but were scheduled to start later in 2025. The 131 measures (11%) indicated as “not completed” were scheduled for completion but have not been implemented (either partially or fully). The NACP reports that the final monitoring of the implementation of the current SACP will be conducted in 2026.
Source: (NACP, 2025[27]; OECD, 2025[28])
2.4.2. Sweden could strengthen its evaluation process for the APACUI and future strategic planning
Sweden has had a robust evaluation process for both the APACUI and the 2021-2023 Anti-Corruption Plan. Evaluation of both action plans has been part of the Statskontoret’s assignment to monitor and assess the development of public authorities’ work against corruption. For the previous plan, this evaluation work was presented in the Statskontoret’s end-of-assignment report, Step by Step: The authorities' work against corruption is under development (Statskontoret, 2023[14]). This final report was based on the Statskontoret’s collective knowledge gathered throughout its three-year assignment and data and insights provided by the members of the Forum. The Statskontoret’s evaluation also benefitted from two situational pictures of authorities’ anti-corruption work developed through two surveys of government administrative authorities with ten or more employees. The first survey, in 2021, was sent to 209 authorities, of which 187 (c.89%) responded. The second survey, in 2023, was sent to 208 authorities, of which 171 (c.82%) responded. The Statskontoret also interviewed representatives from 22 different types of public authority to establish different factors that could influence authorities’ work against corruption (Statskontoret, 2023[14]). In addition to the Step by Step report, the 2021-2023 Action Plan was evaluated through the work of a staff assistant, who also conducted a survey and interviews. The trade union Akavia also commissioned a survey on corruption in the public administration, which asked questions about perceptions and experiences of corruption in 14 Swedish authorities, receiving responses from almost 2 500 respondents, and made several recommendations for improvement (Akavia, 2023[29]).
Similar plans are in place for the end-of-term evaluation of the APACUI. In addition, though, the Statskontoret will also survey experiences of corruption in Swedish public authorities to inform its evaluation. While there is therefore a robust plan in place for evaluating the APACUI, the planned evaluation currently relies largely on expert assessment. These assessments are (and have been) valuable, but there is scope to move beyond expert assessments and to include other techniques to improve the reliability of the APACUI’s evaluation.
By introducing further data sources and evaluation techniques, Swedish evaluators could be more confident about where, when and how change happened as a result of the APACUI and the assignments underpinning it. One method for improving evaluation reliability is the use of a counterfactual comparison. Although in some cases it is difficult to observe a counterfactual, in other cases this kind of comparison can be made through varying the exposure to a policy across observed units. By doing so, evaluators can compare the change observed in units according to whether or not they were exposed to a given intervention. This method is most applicable to policies which affect a range of similar units, and could be employed in the evaluation of, for instance, the Statskontoret’s work to deliver training and capability building modules and the effects it has on levels of knowledge in employees exposed to the modules and those which are not. The advantages of this kind of approach to evaluation are set out in (Figure 2.6).
Note: This figure illustrates the problem of the missing counterfactual. A less developed before-after comparison would find that the outcome indicator has changed from A (before the policy intervention) to B (after the policy intervention). The change that would have happened even without the policy, from A to X, remains unobserved. If the change from A to B is fully attributed to the policy, its impact is overestimated and the evaluation is therefore less useful to future policy design.
Source: Adapted from (U4, 2013[30])
If Sweden were to adopt this advanced approach to evaluation, it could provide valuable evidence-based insights which could feed into future strategic planning and the design and adjustment of assignments to the authorities responsible for implementing Sweden’s integrity framework.
References
[29] Akavia (2023), Corruption, report more - Status of the work against corruption in public administration, https://www.akavia.se/siteassets/04-om-akavia/rapporter/akavias-korruptionsrapport-2023.pdf (accessed on 22 May 2025).
[9] Castro, A., N. Phillips and S. Ansari (2020), “Corporate Corruption: A Review and an Agenda for Future Research”, Academy of Management Annals, Vol. 14/2, pp. 935-968, https://doi.org/10.5465/annals.2018.0156.
[22] Council of Europe (2008), Technical paper: tools for reporting and implementation of anticorruption measures in line with the new anti-corruption action plan, https://rm.coe.int/CoERMPublicCommonSearchServices/DisplayDCTMContent?documentId=09000016806ed744 (accessed on 9 April 2025).
[7] European Commission (2021), 2021 Rule of Law Report Country Chapter on the rule of law situation in Sweden, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021SC0725 (accessed on 6 May 2025).
[23] Government of the Republic of Estonia (2021), Anti-Corruption Action Plan 2021–2025, https://www.korruptsioon.ee/sites/default/files/2023-07/anticorruptionactionplan20212025%20%281%29.pdf (accessed on 16 May 2025).
[4] GRECO (2019), Fifth Evaluation Round: Preventing corruption and promoting integrity in central governments (top executive functions) and law enforcement agencies, Evaluation Report Sweden, https://rm.coe.int/fifth-evaluation-round-preventing-corruption-and-promoting-integrity-i/1680943be3 (accessed on 6 May 2025).
[16] HM Government (2017), United Kingdom Anti-Corruption Strategy 2017-2022, Joint Anti-Corruption Unit, https://assets.publishing.service.gov.uk/media/5a829eb7e5274a2e87dc21f0/6_3323_Anti-Corruption_Strategy_WEB.pdf (accessed on 9 May 2025).
[25] Johnsøn, J. et al. (2011), How to monitor and evaluate anti-corruption agencies: Guidelines for agencies, donors and evaluators, https://www.u4.no/publications/how-to-monitor-and-evaluate-anti-corruption-agencies-guidelines-for-agencies-donors-and-evaluators-2.pdf (accessed on 10 April 2025).
[13] Marquette, H. and C. Peiffer (2020), “Corruption Functionality Framework”, Global Integrity - Anticorruoption Evidence (GI-ACE), Vol. 6, https://ca-anticorruption.com/wp-content/uploads/2020/12/Corruption-Functionality-Framework-szhatyj-1.pdf (accessed on 7 May 2025).
[5] Ministry of Finance (2017), National Public Procurement Strategy 2017, https://www.oneplanetnetwork.org/sites/default/files/sweden_national_public_procurement_strategy_english_web.pdf (accessed on 6 May 2025).
[27] NACP (2025), Results of monitoring and evaluation of the effectiveness of the implementation of the state anti-corruption program for 2023-2025, https://dap.nazk.gov.ua/en/module/ (accessed on 19 May 2025).
[28] OECD (2025), OECD Integrity and Anti-Corruption Review of Ukraine, OECD Public Governance Reviews, OECD Publishing, Paris, https://doi.org/10.1787/7dbe965b-en.
[11] OECD (2024), Anti-Corruption and Integrity Outlook 2024, OECD Publishing, Paris, https://doi.org/10.1787/968587cd-en.
[17] OECD (2021), Countering Public Grant Fraud in Spain: Machine Learning for Assessing Risks and Targeting Control Activities, OECD Public Governance Reviews, OECD Publishing, Paris, https://doi.org/10.1787/0ea22484-en.
[2] OECD (2020), OECD Public Integrity Handbook, OECD Publishing, Paris, https://doi.org/10.1787/ac8ed8e8-en.
[18] OECD (2019), Analytics for Integrity: Data-Driven Approaches for Enhancing Corruption and Fraud Risk Assessments, OECD Publishing, Paris, https://doi.org/10.1787/b354a27e-en (accessed on 20 September 2023).
[26] OECD (2017), “Monitoring and Evaluating Integrity Policies”, https://one.oecd.org/document/GOV/PGC/INT(2017)4/en/pdf (accessed on 11 April 2025).
[1] OECD (2017), “Recommendation of the Council on Public Integrity”, OECD Legal Instruments, OECD/LEGAL/0435, OECD, Paris, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0435.
[10] Pyman, M. and P. Heywood (2024), Sector-Based Action Against Corruption, Springer Nature Switzerland, Cham, https://doi.org/10.1007/978-3-031-59336-9.
[12] Pyman, M. and P. Heywood (2020), “The Sector Focus and Reformulation Approach (SFRA): Enabling leaders and managers to formulate practical strategies for corruption reduction”, ACE Global Integrity and Curbing Corruption, https://curbingcorruption.com/wp-content/uploads/2020/12/210111-Pyman-and-Heywood-2020-Sector-Focus-and-Reformulation-Approach.pdf (accessed on 7 May 2025).
[24] Seimas of the Republic of Lithuania (2022), National Anti-Corruption Agenda 2022-2033, https://www.stt.lt/data/public/uploads/2022/08/stt_darbotvarke_en.pdf (accessed on 16 May 2025).
[8] Shaheer, N. et al. (2019), “State-Owned Enterprises as Bribe Payers: The Role of Institutional Environment”, Journal of Business Ethics, Vol. 159/1, pp. 221-238, https://doi.org/10.1007/s10551-017-3768-z.
[3] Statskontoret (2023), Knowledge compilation on national strategies, https://www.statskontoret.se/publicerat/publikationer/publikationer-2023/kunskapssammanstallning-om-nationella-strategier/ (accessed on 6 May 2025).
[14] Statskontoret (2023), Step by Step: The authorities’ work against corruption is under development, https://www.statskontoret.se/en/publications/publikationer/publikationer-2023/step-by-step--government-agencies-are-making-progress-in-their-work-against-corruption.-final-report/ (accessed on 9 May 2025).
[15] Statskontoret (2022), The Government’s Governance in Cross-Sectoral Issues - A Study of Experiences and Development Opportunities, https://www.statskontoret.se/publicerat/publikationer/publikationer-2022/regeringens-styrning-i-tvarsektoriella-fragor---en-studie-om-erfarenheter-och-utvecklingsmojligheter/ (accessed on 9 May 2025).
[21] Statskontoret (2018), Strategies and action plans. A way for the government to govern?, https://www.statskontoret.se/publicerat/publikationer/publikationer-2018/strategier-och-handlingsplaner.-ett-satt-for-regeringen-att-styra/ (accessed on 15 May 2025).
[6] Transparency International (2019), Press Release, National Action Plan Against Corruption, https://transparency-sverige.s3.eu-north-1.amazonaws.com/xghek4kblou2l8l49aokdnsrbc7u?response-content-disposition=inline%3B%20filename%3D%22TI_Sverige_Pressmeddelande_Nationell_handlingsplan_mot_korruption_9_dec_2019.pdf%22%3B%20filename%2A%3DUTF-8%27%27TI_Sverige_Pressmeddelande_Nationell_handlingsplan_mot_korruption_9_dec_2019.pdf&response-content-type=application%2Fpdf&X-Amz-Algorithm=AWS4-HMAC-SHA256&X-Amz-Credential=AKIA2PFQWNLSRHF76DG6%2F20250506%2Feu-north-1%2Fs3%2Faws4_request&X-Amz-Date=20250506T133232Z&X-Amz-Expires=300&X-Amz-SignedHeaders=host&X-Amz-Signature=885ed13cbf300d11c777b3081b2e838de4438d91ba24eb51b791dc6fcb9d3ef0 (accessed on 6 May 2025).
[30] U4 (2013), Methods for learning what works and why in anti-corruption: An introduction to evaluation methods for practitioners.
[19] UNDP (2016), Introduction to Korea’s Anti-Corruption Initiative Assessment: A Tool to Evaluate Anti-Corruption Efforts in the Public Sector in the Republic of Korea, https://www.local2030.org/library/view/247 (accessed on 14 May 2025).
[20] UNODC (2020), State of integrity: A guide on conducting corruption risk assessments in public organizations, United Nations Office on Drugs and Crime, https://www.unodc.org/documents/corruption/Publications/2020/State_of_Integrity_EN.pdf.
← 1. In the end the review was granted an extension and reported on 8 May 2025.