From Diagnostic to Implementation: An Update from Sri Lanka

Today’s guest post is from Till Hartmann, Governance Specialist with the World Bank, based in Colombo, Sri Lanka. The views expressed are his own and do not necessarily reflect the opinions and positions of the World Bank.

The global anticorruption field has in recent years had more reason to play defense than offense. In several jurisdictions, earlier gains have come under pressure, including through shifts in enforcement priorities and legal constraints on transparency measures. A recent analysis documents a significant reversal in U.S. anticorruption policy. At the same time, earlier momentum on public beneficial ownership transparency in Europe has been curtailed following a 2022 ruling by the Court of Justice of the European Union—an issue discussed on this blog shortly after the decision.

Against this backdrop, it is worth examining cases where reform momentum—though fragile—has translated into concrete institutional change. Sri Lanka is one such case. An earlier post on this blog described how civil society engagement helped shape the IMF’s 2023 Governance Diagnostic Assessment and the country’s post-crisis reform agenda. The question now is what has followed—and whether it has resulted in tangible progress.

There are early indications that important elements of the reform agenda have moved from commitment to implementation. Over the past year, Sri Lanka has enacted or amended several pieces of legislation relevant to anticorruption, including a Proceeds of Crime Act, amendments to the National Audit Act, and amendments to the Companies Act introducing beneficial ownership disclosure requirements. These legal changes have been complemented by operational steps, including the rollout of a digital asset declaration system and measures to strengthen the enforcement capacity of the Anti-Corruption Commission (CIABOC).

None of this suggests that corruption risks have diminished in a fundamental way. Recent firm-level survey data still point to deeply entrenched corruption in interactions between firms and the state: bribery incidence increased from 10% in 2011 to 26% in 2025, and bribery depth from 9% to 23%. At the same time, there are tentative signs that the direction of travel may have shifted. Sri Lanka’s Corruption Perceptions Index score increased by three points in 2025 to 35, reversing a multi-year decline. While this should be interpreted cautiously, it is nonetheless a noteworthy signal in the current global context.

Within this broader reform landscape, the development of a beneficial ownership transparency framework is particularly instructive. It provides a concrete example of how a reform priority identified in a diagnostic exercise can move through legislation and into operational reality.

The starting point was the IMF Governance Diagnostic, which identified beneficial ownership transparency as a priority reform area. This placed the issue firmly on the policy agenda. The next phase involved translating this priority into law through amendments to the Companies Act, mandating companies to disclose their beneficial owners.

The more complex challenge, however, lay in implementation. Establishing a functioning system required not only a legal mandate, but also institutional ownership, technical capacity, and coordination across agencies. The Registrar of Companies led implementation, while the Financial Intelligence Unit had strong incentives to advance progress given its relevance for international AML/CFT assessments, including FATF Recommendation 24.

Progress reflected a combination of internal leadership, external pressure, and coordinated support. Development partners, including the nonprofit Open Ownership, provided technical support for implementation, while high-level prioritization and integration into the broader reform program helped sustain momentum.

Civil society engagement also played a decisive role in shaping the final design. Legal challenges brought by Transparency International Sri Lanka contributed to revisions of the legislative approach, including extending disclosure requirements and enabling a degree of public access to beneficial ownership data. Throughout the process, organizations such as Verité Research monitored developments and contributed to public debate.

The result is the launch of Sri Lanka’s beneficial ownership register on March 31, 2026. While important limitations remain—particularly with respect to data verification and compliance—the establishment of the register marks a meaningful step forward.

The significance of this development extends beyond corporate transparency. As Sri Lanka advances reforms in areas such as electronic procurement and the integration of public financial management systems, beneficial ownership data creates opportunities for more systematic risk detection. Linking ownership data with procurement, tax, and expenditure information could help identify conflicts of interest, collusion, and other risks that are otherwise difficult to detect.

Sri Lanka’s experience does not overturn the broader global trend toward stagnation in anticorruption policy. Nor does it demonstrate that structural corruption challenges have been resolved. What it does show is that, even in a constrained global environment, reform momentum can be sustained when government institutions, civil society, and international partners converge around shared priorities and carry them beyond the diagnostic stage.

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