_(i) Prioritizing direct reporting_ . Rather than linking indirect reporting to funding conditionalities, MDBs could introduce incentives to improve direct disclosure.<sup>4344</sup> Public and direct access to these records would be a strong accountability mechanism. As shown in Section 2, citizens in several countries have to rely on indirect sources to get a sense of their own government’s debt portfolio. Solid and accessible direct databases would also improve efficiency for exchanging data with external agents. Finally, future debt restructurings can have a stronger and long-lasting impact on debt transparency if the main players (e.g., borrowing country, Paris Club, IMF/WB, etc.) commit to ensuring that the necessary data reconciliation process with creditors is reflected in direct reports.

(ii) _Targeting a core of global, achievable, and enforceable direct reporting standards_ . As shown in Section 3, few developing countries fully comply with standards and definitions (e.g., nominal value rather than face value; external debt by residency; total public sector debt coverage). This paper shows that requiring high standards without consideration of local limitations, leads to divergent levels of compliance which perpetuates cross-country comparability issues and distrust over debt data. In this context, the focus on direct reporting should be supported by _interim_ standards aiming at consolidating debt statistics based on simplified definitions (i.e., external debt by currency; face value) and achievable coverage levels which should be clearly indicated (from central government to general government to public sector). This needs to happen in conjunction with building DMOs’ capacity and developing technical solutions to foster disclosure under best international standards.

(iii) _Standardizing and coordinating templates among external agents_ . Ongoing indirect reporting efforts to expand sectoral or instrument coverage, as in the LIC-DSA framework, should be encouraged. External agents should also seek to build their work on direct sources, rather than on multiple _ad-hoc_ data requests, which overburden DMOs. This would reinforce the incentives for stronger direct reporting. Indirect reports should clearly specify individual deviations from direct sources to avoid further comparability issues. To that end, this paper recommends introducing a log of the amendments made to the original data and explicit engagement of external agents; this will help enforce feedback procedures and ensure that DMOs can record these changes themselves.

(iv) _Equipping DMOs with modern and integrated systems._ An integrated repository for public debt could be developed. Appendix A proposes a concrete strategy to develop and implement an international loan repository (ILR). The goal of the ILR is to provide a platform to reconcile debt records between creditors and debtors, thus improving the accuracy of debt records and limiting operational risk. The ILR would also enable the creation of a central database, which can be used for public reporting purposes,<sup>45</sup> it could

> 43 In the case of the IMF, for instance, “while members have to provide the required data to the Fund, they are under no obligation to publish such data” (IMF, WB, 2020).

> 44 IDA’s recent Sustainable Development Finance Policy (SDFP) follows this approach, as a number of Performance and Policy Actions (PPAs) focus on the publication of comprehensive statistical bulletins by the authorities. 45 A similar approach has been proposed by civil society (Eurodad and others, April 2019) and formalized by a G20 working note (Ayadi, Avgouleas, 2020). However, the proposal in Appendix A differs from this approach on several fronts as: (i) participation in the ILR is entirely voluntary, although its use can be incentivized by official lenders; (ii) the scope of the ILR is limited to loans, as bonds tend to be more transparent (e.g., contract terms are disclosed through prospectus and commercial platforms); (iii) the ILR is not replacing well-established platforms for issuing or trading debt instruments; (iv) the ILR is not tracking use of funds; (v) the ILR should facilitate the data reconciliation between  creditors and debtors.