The investment chain in today’s global capital markets relies on a wide range of service providers that support institutional investors with analysis, data and advice. Principle III.D. of the G20/OECD Principles of Corporate Governance recommends that entities and professionals providing analysis or advice relevant to investor decisions disclose and minimise conflicts of interest that could compromise the integrity of their work and ensure transparency in the methodologies they use.
As part of the OECD Corporate Governance Committee’s mandate to monitor and support the implementation of the G20/OECD Principles of Corporate Governance, this report examines the regulatory frameworks and market practices related to conflicts-of-interest management and methodology transparency among key capital market service providers. The report focuses on proxy advisors, environmental, social and governance (ESG) ratings and data providers, and index providers. While securities analysts and credit rating agencies fall outside the main scope of the analysis, a brief section provides context on how jurisdictions have addressed comparable issues in those areas.
The report draws primarily on responses to a detailed questionnaire from 50 jurisdictions participating in the work of the OECD Corporate Governance Committee complemented by desk research. They are the same jurisdictions covered in the OECD Corporate Governance Factbook 2025, with the addition of Thailand and the exceptions of Iceland, Saudi Arabia and the United States. It also reflects discussions with a broad range of market participants and policymakers, including contributions from an expert roundtable held in April 2025 with Neil Acres (MSCI), Monica de Virgiliis (Snam), David Henry Doyle (S&P Global), Hugo Gallagher (Institutional Shareholder Services), Henriette Peucker (Deutsches Aktieninstitut), Konstantinos Sergakis (Best Practice Principles Oversight Committee) and Jenn-Hui Tan (Fidelity International). Three in-depth case studies – Belgium, Chile and India – offer further insight into how different jurisdictions approach the governance of market service providers and address issues related to conflicts of interest and methodological transparency.
The peer review explores several key policy considerations. These include whether and how different types of service providers should be regulated; the role of self-regulatory codes; approaches to monitoring compliance and mitigating regulatory arbitrage; mechanisms for minimising conflicts of interest; and ways to ensure sufficient transparency of methodologies while preserving incentives for innovation and improvement.
This report has been developed by the Capital Markets and Financial Institutions Division of the OECD Directorate for Financial and Enterprise Affairs. It was prepared by Adriana De La Cruz, Tiziana Londero and Hitesh Tank under the supervision of Caio de Oliveira, Head of the Sustainable Finance and Corporate Governance Team, and Serdar Çelik, Head of Division.