Non-delivery and ghost works
The project is not executed, or is only partially delivered, despite funds being committed or spent.
Red Flags & Indicators
- Reported outputs and milestones are not supported by site verification, geotagged evidence, and independent checks.
- Advance payments or disbursements continue despite limited mobilisation, minimal equipment on site, and low physical progress.
- Schedules are repeatedly re‑baselined and delays reclassified without a credible recovery plan.
- Handover, defects, and completion documentation is incomplete, yet certificates are issued to trigger payments.
- Controls for tracking and verifying physical progress are weak or absent.
- Alignment between physical and financial progress control systems is weak or absent.
Stakeholder Guidance
Stakeholder Exposure
Exposure includes payment freeze; higher risk of contract termination; debarment and enforcement risk; increased risk of disputes and recovery claims; severe cashflow stress; and reputational damage from non-delivery. allegations.
Decision Point
Before submitting payment claims, verify evidence of completion of on-site outputs; implement a documented remediation plan when physical progress is not demonstrated.
Mitigation Actions
• Verify work completion before claiming payment (site diaries, measurements, photos and geotagged evidence where used, supervisor and engineer sign-offs)
• Do not process payment claims without supporting evidence of completion
• Separate site supervision and progress reporting from invoice preparation and payment certification roles
• Maintain an auditable evidence pack for each milestone and payment claim
• Document corrective actions taken to complete unfinished works (recovery plan, rework, revised milestones)
• Use internal compliance escalation processes and whistleblower channels, where available, to report any pressure to certify ghost works or issue completion certificates without evidence, pausing payments pending investigation and documented resolution
Mitigation Resources
Control work progress, site evidence, delivered quantities, completion records, and records supporting claims through formal evidence requirements, site or measurement records, independent review, and verification before claim submission, internal sign-off, or payment processing.
Change control, delivery verification, and payment integrity — https://toolbox.infrastructuretransparency.org/resource/change-control-delivery-verification-and-payment-integrity/Assess fraud risks and apply prevention, detection, investigation, and corrective-action controls to work progress, site evidence, delivered quantities, completion records, and records supporting claims, including ghost works, inflated progress claims, or unsupported completion certificates.
Fraud control management — https://toolbox.infrastructuretransparency.org/resource/fraud-control-management/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes higher risk of write-downs, disbursement suspension and legal recovery costs; heightened ESG and reputational risk; litigation and fraud risk; and exit pressure.
Decision Point
Before disbursement, request evidence of physical progress; pause disbursements and apply contractual remedies where evidence is insufficient, inconsistent, or unreliable.
Mitigation Actions
• Require reconciliation of actual physical progress with the milestone schedule and bill of quantities
• Require complete completion and acceptance evidence for each payment (test results, punch list status, handover documentation, retention calculations)
• Treat gaps, repeated re-baselining, and weak mobilisation as suspension triggers
• Include audit/verification rights over progress records, site logs, payment certificates, and advance-payment utilisation
• Pause funding and trigger contractual remedies until evidence of completion is presented
Mitigation Resources
Require, through financing conditions, formal evidence and independent verification for reported progress, delivered quantities, site evidence, completion records, and payment support before disbursement decisions.
Change control, delivery verification, and payment integrity — https://toolbox.infrastructuretransparency.org/resource/change-control-delivery-verification-and-payment-integrity/Use an independent technical adviser to verify reported progress, delivered quantities, site evidence, and completion support, and to challenge weak or inconsistent evidence before disbursement decisions.
Independent technical due diligence and monitoring — https://toolbox.infrastructuretransparency.org/resource/independent-technical-due-diligence-and-monitoring/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes fiscal loss and no service delivered; higher litigation, audit and investigation risk; increased risk of project delays and restart costs; and loss of public trust.
Decision Point
Before certifying outputs and payments, verify evidence of completion; suspend certification and trigger reviews when discrepancies persist.
Mitigation Actions
• Certify payments only against verified completion evidence (site measurements, inspection reports, test results, punch list and handover status; geotagged evidence where feasible)
• Maintain an auditable inspection and acceptance file
• Apply surprise audits, risk-based spot checks and independent and second-line verification for high-value, high-risk milestones
• Commission independent review in case of repeat re-baselining, weak mobilisation, and inconsistencies between reported progress and site reality, suspending payments pending review
• Refer credible concerns of ghost works or falsified certification to independent oversight bodies; suspending payment pending documented review and resolution
• Publish project information based on recognised infrastructure data standards such as the OC4IDS
Mitigation Resources
Require verified progress, delivered quantities, site measurements, inspection reports, and completion evidence before approving certification, acceptance, or payment.
Change control, delivery verification, and payment integrity — https://toolbox.infrastructuretransparency.org/resource/change-control-delivery-verification-and-payment-integrity/Maintain internal oversight of controls governing progress records, completion evidence, and payment verification; test controls, follow up findings, and focus assurance on high-risk certifications, payments, or inconsistencies between reported progress and site reality.
Risk-based internal audit planning — https://toolbox.infrastructuretransparency.org/resource/risk-based-internal-audit-planning/Publish and maintain public access to key progress and completion records, including certified milestones, completion decisions, and reasons for payment holds or corrective actions, 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 community distrust and grievances; limited access to phisical evidence and records; intimidation and retaliation risk when documenting non-delivery; and weak accountability.
Decision Point
During project execution, submit access to information to clarify physical progress milestones. Decide whether to (a) escalate through oversight channels to report non-delivery and lack of transparency, or (b) monitor while safely gathering evidence.
Mitigation Actions
• Mobilise communities to identify project delays against observable outputs
• Engage available grievance channels and oversight bodies to report credible signs of non-delivery (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
Mitigation Resources
Use independent monitoring or social accountability to compare disclosed progress and completion records with observable outputs, site conditions, and affected services in practice; document unexplained gaps, track follow-up actions, and raise them through oversight channels.
Independent monitoring, assurance, and social accountability — https://toolbox.infrastructuretransparency.org/resource/independent-monitoring-assurance-and-social-accountability/Track reported progress, payment milestones, and delivered outputs over time; compare them with observable delivery on the ground and flag repeated claims, delivery gaps, or other signs of non-delivery.
Expenditure tracking and leakage analysis — https://toolbox.infrastructuretransparency.org/resource/expenditure-tracking-and-leakage-analysis/Review publicly disclosed progress and completion records, such as progress certificates, acceptance or handover records, and major payment milestones; identify disclosure gaps, missing justifications, or inconsistencies with observable delivery, 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/