Insufficient transparency on appraisal and financing terms
Key appraisal information and material financing terms are not disclosed in a timely, complete, and consistent way, limiting scrutiny and enabling undue influence or discretion.
Red Flags & Indicators
- Appraisal documents are unpublished, released late, limited to summaries, or missing key annexes needed to test assumptions.
- Financing terms and contingent liabilities are undisclosed or incomplete, obscuring fees, guarantees, and repayment conditions.
- Published information is inconsistent, incomplete, or access-restricted, preventing timely scrutiny.
Stakeholder Guidance
Stakeholder Exposure
Exposure includes higher reputational risk; greater uncertainty around bid terms; increased bid costs and partnership risks; and a higher risk of disputes and renegotiation.
Decision Point
Before early engagement and bid/no‑bid decision, assess timing, completeness, and consistency of the appraisal documentation and financing terms.
Mitigation Actions
• Avoid side-letters or undisclosed fees
• Use internal compliance escalation processes and whistleblower channels, where available, to report internally any request to omit or turn a blind eye to material appraisal and financing information
• Document gaps and data limitations and other issues related to poor transparency in appraisal and financing documentation
• Require internal sign-off that disclosures and representations are complete, consistent, and accurate before submitting committing to the bid
Mitigation Resources
Maintain internal oversight of the company’s appraisal and financing disclosures; require complete and accurate disclosure of key assumptions, fees, guarantees, side letters, and material changes, and track corrective action for control failures.
Risk-based internal audit planning — https://toolbox.infrastructuretransparency.org/resource/risk-based-internal-audit-planning/Use the company’s compliance process to review and escalate requests to omit, delay, or restrict key appraisal information, findings, or financing information without documented justification; require documented rationale and compliance or legal sign-off before term sheets, guarantee requests, or deal commitments proceed.
Compliance management system — https://toolbox.infrastructuretransparency.org/resource/compliance-management-system/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes hidden financial conditions; appraisal flaws; misprice risk; heightened ESG and reputational risk; approval delays; and higher risk of incomplete material information disclosure.
Decision Point
Before investment committee decision, require complete appraisal pack.
Mitigation Actions
• Treat material gaps or lack of transparency as a no-go condition
• Pause engagement if disclosures are late, inconsistent, or access-restricted such that assumptions cannot be tested or governance requirements cannot be met
Mitigation Resources
Conduct integrity due diligence on counterparties linked to appraisal and financing decisions; require complete disclosure of key appraisal information and financing terms, use disclosure covenants and reporting requirements, and withhold approval, disbursement, or waivers where material gaps, opacity, or inconsistencies remain.
Investor integrity due diligence and monitoring — https://toolbox.infrastructuretransparency.org/resource/investor-integrity-due-diligence-and-monitoring/Review publicly disclosed appraisal and financing records before financing decisions; identify disclosure gaps, omitted terms, or unexplained changes early.
Transparency and data disclosure standards — https://toolbox.infrastructuretransparency.org/resource/transparency-and-data-disclosure-standards/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes approval of projects based on incomplete appraisal and financing information; erosion of public trust; risk of cost overruns; and renegotiation pressure when costs and liabilities become visible.
Decision Point
Before approving the project, assess whether appraisal and financing analysis is complete, documented and evidenced.
Mitigation Actions
• Publish financing agreements, with only lawful and justified redactions
• Require formal approval and maintain an auditable record of side-letters, waivers, and amendments
• Use independent approval review for complex projects and financing structures
• Commission independent appraisal review when appraisal and financing documentation is incomplete
Mitigation Resources
Apply stage-gate reviews, readiness checks, and documented approval logs before approving appraisal and financing records; return the case for further work where disclosure is incomplete, evidence is weak, or material terms are withheld without documented lawful grounds.
Stage-gate governance and independent assurance — https://toolbox.infrastructuretransparency.org/resource/stage-gate-governance-and-independent-assurance/Publish and maintain public access to appraisal and financing records, including key terms, annexes needed to test assumptions, approval records, side letters, waivers, amendments, and reasons for material changes, with only lawful redactions.
Transparency and data disclosure standards — https://toolbox.infrastructuretransparency.org/resource/transparency-and-data-disclosure-standards/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes limited scrutiny of costs and impacts; limited ability to test value-for-money and fiscal risk; capture concerns; and risk of retaliation when requesting information.
Decision Point
During budget cycle allocation and/or pipeline publication, request disclosure of appraisal and financing documentation. Decide whether to (a) escalate through oversight channels to raise missing items and gaps, or (b) monitor while gathering evidence safely.
Mitigation Actions
• Engage oversight bodies when appraisal and financing information is incomplete, restricted or inconsistent (use safe, confidential reporting and anonymisation where the risk of retaliation is significant)
• Advocate for disclosure of project information based on recognised infrastructure data standards such as the OC4IDS
• Mobilise communities affected by poor project planning to highlight the importance of complete disclosure of appraisal and financing information
Mitigation Resources
Request access to non-public appraisal and financing records, such as committee minutes, approval notes, records explaining changes in financing terms, or records showing why appraisal findings or material terms were withheld, so incomplete or inconsistent disclosure can be examined and raised through oversight channels.
Access-to-information and demand-side transparency — https://toolbox.infrastructuretransparency.org/resource/access-to-information-and-demand-side-transparency/Review publicly disclosed appraisal and financing records at an early stage; identify omitted material terms, missing appraisal documents, unexplained changes, or gaps between versions, and raise concerns about non-disclosure with an oversight body.
Transparency and data disclosure standards — https://toolbox.infrastructuretransparency.org/resource/transparency-and-data-disclosure-standards/Submit formal complaints or protected reports through audit, committee, or other oversight channels where appraisal or financing disclosures are materially incomplete, inconsistent, or restricted in ways that prevent scrutiny; use confidentiality and source-protection measures where retaliation risk is material.
Grievance, complaints, and protected reporting — https://toolbox.infrastructuretransparency.org/resource/grievance-complaints-and-protected-reporting/