Anti-corruption and integrity are central to the governance of SOEs and are addressed in the OECD Guidelines on Anti-Corruption and Integrity in SOEs. Drawing on the results of recent monitoring of the Guidelines’ implementation, this chapter examines how integrity is addressed within the state, in the exercise of ownership and in SOE operations. It also considers the mechanisms used to promote anti-corruption and integrity and strengthen SOE accountability.
Ownership and Governance of State‑Owned Enterprises 2026
Abstract
Considering SOEs’ close links to the state, involvement in high-value activities, and presence in highly regulated sectors, they often face elevated risks related to integrity and corruption. Addressing these risks on an ongoing basis is an essential component of sound governance. In addition to the OECD Guidelines on Corporate Governance of State‑Owned Enterprises, this chapter draws on the OECD Guidelines on Anti-Corruption and Integrity in State‑Owned Enterprises (ACI Guidelines), a complementary instrument. In particular, it builds on findings from the Report on the Implementation of the OECD Recommendation on Guidelines on Anti-Corruption and Integrity in State‑Owned Enterprises (OECD, 2025[1]). While based on a distinct dataset covering 27 jurisdictions (Box 7.1), this chapter provides insights into how SOEs and their owners address integrity risks in practice. Key findings include:
Most jurisdictions have introduced measures to support high standards of conduct for the state, including whistleblower protection mechanisms and restrictions on SOE contributions to political parties. However, gaps remain in the formal documentation of interactions between the state and SOEs and in the inclusion of integrity and eligibility requirements in the recruitment of employees and heads of state ownership entities.
Requirements for SOEs to report on compliance, anti-corruption and integrity are relatively widespread, but monitoring by ownership entities remains limited. While three-fourths of respondents require such reporting, only one‑third indicate that ownership entities track the reports received, pointing to a gap between formal requirements and implementation in practice.
Integrity frameworks at the enterprise level are generally well established, but important gaps remain. Procedures for reporting wrongdoing and protections for reporting persons apply somewhat less consistently to SOEs than to state ownership entities. In addition, while 78% of jurisdictions use predetermined criteria for selecting SOE board members, only 30% report using such criteria for senior management appointments.
Accountability mechanisms remain less developed, particularly in relation to stakeholder engagement. In many jurisdictions, consultation and co-operation with civil society, the public, the media and the business community on integrity and anti-corruption matters remain limited, reducing opportunities for external scrutiny and accountability.
As SOEs take on a more prominent role as global competitors, their scale and market presence mean that integrity and governance failures can have far-reaching economic and social consequences. SOEs may be particularly exposed to corruption risks in part because of their prevalence in high-risk sectors such as infrastructure, where public and private sectors intersect through valuable concessions and large public procurement projects. Their close links to the state, combined with long project cycles, high-value contracts, complex supply chains and exposure to discretionary decision making, heighten integrity and corruption risks. An OECD survey found that 42% of SOE respondents had observed corrupt or irregular conduct within the previous three years, often involving staff, management, board members and external partners. Risks were particularly pronounced in sectors such as extractives, energy and transport, as well as in enterprises with public policy mandates (OECD, 2018[2]).
While private firms may face similar risks, SOEs are exposed to specific vulnerabilities due to their proximity to the state. These include risks of undue political interference, use as vehicles for political finance or patronage, and pressures to bypass rules in favour of political objectives. In many jurisdictions, gaps in governance and ownership arrangements continue to exacerbate these risks, particularly in high-value and highly regulated sectors where misconduct may be harder to detect. For example, a 2024 study showed that 21% of OECD jurisdictions lack explicit regulations prohibiting SOEs from financing political parties (OECD, 2024[3]).
The OECD Guidelines on Anti-Corruption and Integrity in State‑Owned Enterprises are designed to help state ownership entities and their SOEs to strengthen safeguards against corruption and to promote integrity in the state‑owned sector (OECD, 2019[4]). Organised around four pillars, they complement the SOE Guidelines by providing a dedicated framework to strengthen integrity, prevent corruption and promote accountability in the state‑owned sector. Anti-corruption and integrity measures are closely linked to effective ownership practices and sound corporate governance, complementing the analysis provided in this report. The findings draw on the OECD survey on implementation of the ACI Guidelines, providing an indication of how integrity-related arrangements are being applied across the state‑owned sector (Box 7.1).
The OECD Guidelines on Anti-Corruption and Integrity in State‑Owned Enterprises (ACI Guidelines) are the first international standard to support state owners in preventing corruption and promoting integrity in the enterprises they own or control (Figure 7.1). Adopted in 2019, they complement the OECD Guidelines on Corporate Governance of State‑Owned Enterprises by providing more detailed guidance on anti-corruption and integrity. They are organised around four pillars: the integrity of the state; the exercise of state ownership for integrity; the promotion of integrity and prevention of corruption at the enterprise level; and the accountability of SOEs and of the state.
The first review of the implementation of the ACI Guidelines was published in 2025 and drew on questionnaire responses from 27 participants: Australia, Austria, Belgium, Chile, Colombia, Costa Rica, Czechia, Estonia, Finland, Germany, Greece, Iceland, Ireland, Italy, Korea, Latvia, Lithuania, the Netherlands, New Zealand, Norway, the Slovak Republic, Spain, Sweden, Switzerland, Türkiye, the United Kingdom and the United States.
Source: OECD (2019[4]) Guidelines on Anti-Corruption and Integrity in State-Owned Enterprises, https://doi.org/10.1787/315dab91-en; OECD (2025[1]) Report on the Implementation of the OECD Recommendation on Guidelines on Anti-Corruption and Integrity in State‑Owned Enterprises.
Results from the first OECD survey on the implementation of the ACI Guidelines suggest that the 27 participating jurisdictions broadly align with provisions relating to the integrity of the state (Pillar A) and the promotion of integrity and prevention of corruption at the enterprise level (Pillar C), where average implementation levels reach 75% and 73%, respectively. Slightly lower levels of implementation are observed for provisions relating to the exercise of state ownership for integrity (68% under Pillar B), while the lowest levels are recorded for provisions concerning the accountability of SOEs and of the state (62% under Pillar D) (Figure 7.2). The following sections examine the implementation of the ACI Guidelines across participating jurisdictions, organised around the four pillars of the framework.
Note: Percentages are based on the 27 jurisdictions that participated in the Report on the Implementation of the OECD Recommendation on Anti-Corruption and Integrity in State‑Owned Enterprises (see Box 7.1).
Source: OECD (2025[1]) Report on the Implementation of the OECD Recommendation on Guidelines on Anti-Corruption and Integrity in State‑Owned Enterprises.
The level of integrity of SOEs is shaped by the broader commitment to ethical conduct within the state and within the bodies responsible for exercising ownership. Key elements include safeguards at the level of the state as owner, such as whistleblower protection mechanisms, restrictions on financial contributions to political parties, and clear frameworks governing communication between the state and SOEs. Overall findings from the implementation report point to positive steps in several of these areas, notably the establishment of whistleblower protections and measures to limit the misuse of SOEs, including restrictions on political financing in a majority of reporting jurisdictions. However, important gaps remain, particularly with regard to formal communication frameworks between the state and SOEs, as only about half systematically maintain records of these interactions.
One key dimension of maintaining high standards of conduct relates to recruitment, eligibility and appointment practices. Given that SOEs are often overseen by senior public officials, risks can arise when public office is used to advance political or personal interests through these enterprises (OECD, 2023[5]). In this context, staff within state ownership entities, or those exercising ownership on behalf of the state, should be recruited through transparent and merit-based processes (OECD, 2019[4]). Clear and formal procedures can help prevent favouritism and strengthen professionalism, while appointments based on established criteria, such as merit, skills and integrity, reinforce neutrality and help avoid potential conflicts of interest.
Survey results (Table 7.1) show that, across 27 jurisdictions, 89% have regulations establishing formal recruitment processes for employees and heads of state ownership entities. However, only 37% include explicit integrity and eligibility requirements for applicants, suggesting that fewer jurisdictions systematically embed integrity considerations into hiring practices.
Note: Results are based on the 27 jurisdictions that participated in the Report on the Implementation of the OECD Recommendation on Anti-Corruption and Integrity in State‑Owned Enterprises (see Box 7.1).
Source: OECD (2025[1]) Report on the Implementation of the OECD Recommendation on Guidelines on Anti-Corruption and Integrity in State‑Owned Enterprises.
While frameworks are in place, further efforts are needed to strengthen the state’s role as an active and informed owner, particularly through improved data collection, aggregate reporting, and more robust monitoring and oversight mechanisms. For example, although roughly three‑fourths of jurisdictions require SOEs to report on compliance, anti-corruption and integrity, data on implementation remain limited. Only one‑third report that ownership entities track the reports received (Table 7.2). In most cases, either no information was provided or respondents indicated that no tracking is conducted. In addition, coverage at the portfolio level remains limited. Only 41% of reporting jurisdictions assess anti-corruption and integrity risks across the portfolio based on information received from SOEs and aggregate reporting.
Note: Results are based on the 27 jurisdictions that participated in the Report on the Implementation of the OECD Recommendation on Anti-Corruption and Integrity in State‑Owned Enterprises (see Box 7.1).
KEY
Reporting required? ■ Yes □ No
Tracked in practice? ■ Yes ■ No – No information
Source: OECD (2025[1]) Report on the Implementation of the OECD Recommendation on Guidelines on Anti-Corruption and Integrity in State‑Owned Enterprises.
Safeguarding the integrity of decision making within SOEs includes establishing integrated risk management systems, strengthening internal control frameworks, and protecting decision-making processes from undue influence. The ACI Guidelines also call for clear and accessible procedures enabling employees and other relevant parties to report suspected or actual misconduct, as well as appropriate protection for those who report wrongdoing. These safeguards aim to promote independent, well-informed decision making and support early detection of misconduct.
Survey findings indicate that while safeguards are in place, gaps persist in their consistent application. Strengthening board independence, ensuring greater consistency across SOEs, and embedding integrity considerations more fully into risk management and executive appointments remain important areas for improvement. The results also point to the need to move beyond formal compliance towards a more operational culture of integrity. For example, most jurisdictions have adopted rules allowing for the reporting of wrongdoing and the protection of reporting persons (Figure 7.3). However, the share of respondents applying these measures to SOEs is slightly lower (85% reporting procedures and 81% protection mechanisms) than for state ownership entities (89% for both), suggesting some variation in how integrity safeguards are applied across the state‑owned sector.
Note: Percentages are based on the 27 jurisdictions that participated in the Report on the Implementation of the OECD Recommendation on Anti-Corruption and Integrity in State‑Owned Enterprises (see Box 7.1).
Source: OECD (2025[1]) Report on the Implementation of the OECD Recommendation on Guidelines on Anti-Corruption and Integrity in State‑Owned Enterprises.
The overall implementation levels of the ACI Guidelines are influenced by the participation of European Union member states that have incorporated the 2019 Whistleblowing Directive into national legislation (European Parliament and Council, 2019[6]). This legislative requirement has contributed to more consistent adoption of reporting channels and protective measures. These developments support the broader aims of the ACI Guidelines by strengthening integrity frameworks and improving the ability of the state to identify and address irregularities in state‑owned enterprises.
A further dimension of safeguarding integrity relates to the composition and functioning of SOE boards. The ACI Guidelines emphasise that board members should be selected based on clear, predetermined criteria and through transparent procedures. Survey results indicate that 78% of jurisdictions have introduced such preselection criteria, contributing to more merit-based and transparent appointment processes, as also discussed in Chapter 5.
The ACI Guidelines also stress that SOE boards should apply rigorous standards in the appointment and oversight of senior management (Provision IV.10), reinforcing the principle that responsibility for executive appointments lies with the board rather than the state. Despite this, only 30% of respondents (Austria, Costa Rica, Estonia, Germany, Iceland, Korea, the Netherlands and Türkiye) report the use of preselection criteria for senior management positions. While safeguards for board composition are relatively well established, their extension to executive appointments remains more limited.
Review mechanisms for SOEs and the application of due process in investigations and prosecutions are important tools for strengthening SOE accountability. A key component is the involvement of stakeholders, such as civil society, the public, the media and the business community, in supporting integrity frameworks. Where public policy mandates are unclear or insufficiently transparent, it becomes more difficult to distinguish legitimate public interest objectives from activities influenced by political or personal considerations. In this context, stakeholders can provide valuable monitoring, expertise and insights to help identify risks and support advocacy efforts.
Among respondents, a majority have established at least one form of corporate liability (e.g. civil, administrative or criminal), which can be applied to SOEs (OECD, 2023[5]). A large majority also report penalties applicable to both natural and legal persons, with 78% ensuring multiple forms of liability. These measures strengthen deterrence by increasing the likelihood and cost of misconduct. In addition, external audit mechanisms are in place in many jurisdictions, as noted in Chapter 4, though ensuring that ownership entities are systematically informed of audit outcomes and able to act on findings remains an important area for improvement.
Important gaps also persist in stakeholder engagement in relation to anti-corruption and integrity. OECD data show that only 13 out of 27 jurisdictions report that SOEs have consulted or co‑operated with stakeholders on integrity and anti-corruption measures in the last four years (Table 7.3) (OECD, 2025[1]). Given that stakeholder engagement is intended to be an ongoing process, the findings suggest that engagement is often ad hoc rather than embedded as a core element of integrity governance. Its further use could help strengthen accountability at the level of the state as owner and in individual SOEs.
Note: Results are based on the 27 jurisdictions that participated in the Report on the Implementation of the OECD Recommendation on Anti-Corruption and Integrity in State‑Owned Enterprises (see Box 7.1).
Source: OECD (2025[1]) Report on the Implementation of the OECD Recommendation on Guidelines on Anti-Corruption and Integrity in State‑Owned Enterprises.
References
[6] European Parliament and Council (2019), Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law, EU Directive, http://data.europa.eu/eli/dir/2019/1937/oj.
[1] OECD (2025), Report on the implementation of the OECD recommendation on guidelines on anti-corruption and integrity in state-owned enterprises, https://one.oecd.org/document/C(2025)18/en/pdf.
[3] OECD (2024), Anti-Corruption and Integrity Outlook 2024, OECD Publishing, Paris, https://doi.org/10.1787/968587cd-en.
[5] OECD (2023), Safeguarding State-Owned Enterprises from Undue Influence: Implementing the OECD Guidelines on Anti-Corruption and Integrity in State-Owned Enterprises, Corporate Governance, OECD Publishing, Paris, https://doi.org/10.1787/47444e1c-en.
[4] OECD (2019), Guidelines on Anti-corruption and Integrity in State-Owned Enterprises, OECD, Paris, https://doi.org/10.1787/315dab91-en (accessed on 19 June 2024).
[2] OECD (2018), State-Owned Enterprises and Corruption: What Are the Risks and What Can Be Done?, OECD Publishing, Paris, https://doi.org/10.1787/9789264303058-en.