Insufficient disclosure of designs, assumptions, and the rationale for changes
Limited transparency on designs, key assumptions and rational for changes reduces accountability and enables discretionary decisions that favour narrow interests.
Red Flags & Indicators
- The design basis, key assumptions, and cost calculations are missing, submitted late, or lack clear technical support and version records.
- Major design changes are approved without a complete change log, clear justification, or assessment of cost, risk, and safeguard impacts.
- Stakeholder feedback is not properly recorded, addressed, or linked to design decisions.
- Scope, cost, and safeguard commitments are spread across different documents, making it difficult to understand the full set of obligations.
- Information is released inconsistently or access is restricted, preventing timely and meaningful review.
Stakeholder Guidance
Stakeholder Exposure
Exposure includes increased bid uncertainty and design change risk; a higher risk of disputes and claims; reputational risk from perceived secrecy; and rising transaction costs.
Decision Point
Before design approval, require procuring entities to publish the complete design basis and the change log from the design review process.
Mitigation Actions
• Implement a formal system to control material design changes, documenting the rationale of the design change, costs involved, schedule, risk, safeguard impacts and approvals
• Do not implement design changes until the change record is complete and justified
• Record stakeholder inputs relevant to design (issues raised, responses, decisions) and keep a consolidated register linking scope, cost, and safeguard commitments to design versions
• Use internal compliance escalation processes and whistleblower channels, where available, to flag unsubstantiated design changes
Mitigation Resources
Maintain internal oversight of the company’s design disclosures and change records; require complete and accurate disclosure of key assumptions, standards, baseline quantities, cost drivers, design changes, and material updates, and track corrective action where control failures are identified.
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 design information without documented justification; require documented rationale and compliance or legal sign-off before design changes, submissions, or releases proceed.
Compliance management system — https://toolbox.infrastructuretransparency.org/resource/compliance-management-system/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes hidden design changes; a higher risk of inflated capex and misallocated risk; governance and ESG risks; and delays until independent review is obtained.
Decision Point
Before committing resources, require full disclosure of designs, key assumptions and rational for changes.
Mitigation Actions
• Require formal change control for material design changes (rationale, cost, schedule, risk, safeguard impacts, approvals) and timely notice of revision, treating missing change logs as a no-go condition
• Commission independent technical review to verify key assumptions, reproducibility of calculations and models where applicable, and completeness of the change record
• Retain suspension/exit rights if disclosure remains incomplete
Mitigation Resources
Conduct integrity due diligence on design disclosure and change-control processes; require disclosure of the design basis package, key assumptions, baseline quantities, cost drivers, version history, and material change records through financing conditions, and retain audit, suspension, or exit rights where disclosure remains incomplete or inconsistent.
Investor integrity due diligence and monitoring — https://toolbox.infrastructuretransparency.org/resource/investor-integrity-due-diligence-and-monitoring/Commission an independent technical adviser to test key assumptions, review design outputs, and verify the completeness of version history, change records, and supporting calculations before continued funding or milestone approval.
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 higher risks of scope and cost increase; increased auditand legal challenge risk; poor accountability for decisions; and loss of public trust.
Decision Point
Before approval of material design changes, request a complete record of the design basis and change log .
Mitigation Actions
• Implement a formal change log for material design and cost-base changes (rationale, cost, schedule, risk, safeguard impacts, approvals)
• Do not approve design changes without complete documentation
• Record stakeholder design inputs and responses and keep a consolidated register linking scope, cost, and safeguard commitments to each design version
• Commission independent design review when information is withheld or inconsistencies persist
• Publish project information based on recognised infrastructure data standards such as the OC4IDS
Mitigation Resources
Publish and maintain public access to design basis packages, including key assumptions, standards, baseline quantities, cost drivers, version history, release dates, and reasons for material changes, with only lawful redactions.
Transparency and data disclosure standards — https://toolbox.infrastructuretransparency.org/resource/transparency-and-data-disclosure-standards/Set clear approval limits, sign-off steps, and separation of duties for design basis packages, material design changes, and release approvals; ensure no single official initiates, approves, and records the same action.
Approval authority and segregation of duties — https://toolbox.infrastructuretransparency.org/resource/approval-authority-and-segregation-of-duties/Maintain and use digital publication or procurement logs for design basis packages and release approvals, including version history, notices, addenda, submissions, awards, and access changes, through an auditable trail.
Digital procurement, traceability, and audit logs — https://toolbox.infrastructuretransparency.org/resource/digital-procurement-traceability-and-audit-logs/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes missing design basis and change rational; constrained scrutiny of cost and safeguard impacts; limited ability to contest design changes; higher risk of unmitigated community harm; and risk of retaliation.
Decision Point
At the time of pipeline publication or, where it is not available, during site mobilisation, submit access to information to request clarification on design process and associated documentation. Decide whether to (a) escalate through oversight channels to report information gaps, or (b) monitor while safely gathering evidence.
Mitigation Actions
• Use access to information to request disclosure of needs analysis, lifecycle costs, alternative analysis, safeguard commitments and cost/time overruns associated with design revisions
• Mobilise communities around the importance of full transparency in design processes and associated documentation, due to environmental, social and budgetary impact
• Engage oversight bodies to raise concerns about opaque design processes, misalignment between design change and service needs, missing documentation, and unexplained changes in project scope and footprint (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
Request access to non-public design records, including design basis documents, change logs, version history, release approvals, and records explaining material design revisions, so missing rationales, withheld documents, or unexplained changes 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 design records, including design basis documents, key assumptions, change logs, version history, and release approvals; identify disclosure gaps, hidden changes, or unexplained decisions, 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/Compare disclosed design records with actual design revisions, service needs, lifecycle costs, and safeguard commitments; document unexplained gaps and raise them through oversight channels.
Independent monitoring, assurance, and social accountability — https://toolbox.infrastructuretransparency.org/resource/independent-monitoring-assurance-and-social-accountability/