Companion Annex · Policy Without Performance · MDB Reform Monitor · March 2026
Illustrative “Paper Trigger” Prior Actions by Global Practice: The Evidence Record
This annex catalogues the most commonly recurring prior action templates — drawn from DPF programme documents and IEG ICRRs — that exemplify the form-without-function pattern documented in the main paper. For each prior action: what the trigger requires (the form), what the evidence shows happens after disbursement (the function gap), and the specific IEG ICRR or PPAR from which the finding is sourced. All IEG source citations are drawn directly from the IEG Project Ratings dataset (n=1,551 DPF operations). Outcome ratings in parentheses: U=Unsatisfactory, HU=Highly Unsatisfactory, MU=Moderately Unsatisfactory, MS=Moderately Satisfactory. No operation is cited to assign individual blame. The argument is systemic.
Global PracticeMacroeconomics, Trade & Investment (MTI)
MTI manages approximately 39% of all prior actions across the DPAD database (Macro/Fiscal + Trade/Investment codes) — 3,967 BC-coded macro/fiscal prior actions plus 629 trade/investment prior actions. Its S+ rate is 27.5%, declining from 41% (FY2005–09) to 17% (FY2015–19). In FCS countries: 21.1% S+. In Eastern & Southern Africa: 17.4% S+. The paper trigger repertoire below is the most voluminous and institutionally consequential in the DPF portfolio.
| Prior Action Template (The Form) | Disbursement Trigger | Documented Function Gap | IEG Source & Rating |
|---|---|---|---|
| Gazetting of a new VAT or income tax law | Publication in official gazette | Revenue-to-GDP ratios unchanged; compliance rates stagnant; ghost taxpayers unpurged; new law silent on enforcement mechanisms | Afghanistan FY2020 (P172211, U/FCS): “absence of a results chain meant successive fiscal prior actions could not be evaluated or adapted; each operation repeated the previous one’s form” |
| Adoption of a Medium-Term Debt Strategy | Cabinet approval or publication | Strategy ignored in budget cycles; off-budget borrowing continues; Parliament not briefed; strategy not linked to annual appropriations law | Cabo Verde FY2014–15 (P127411/P147015, U): “in low-capacity environments operations must be realistic and selective; excessive ambition across multiple reform areas produces none” |
| Approval of a new Investment Code / Doing Business indicator reform | Decree signed or bill enacted | Red tape unchanged; FDI flows stagnant; implementation regulations never issued; Doing Business ranking improved while underlying investor experience unchanged | Mozambique FY2014–16 (P131212/P146537/P154422, U): “reforms should have focused on the misuse of Mozambique’s capital stock by its SOEs, not on the number of days to start a business” |
| Submission of a Fiscal Responsibility Law to parliament | Submission only — not passage | Bill lapses or amended to remove binding deficit ceilings; no enforcement mechanism; submission trigger creates disbursement without legislative commitment | Mali PRSC 3–5 FY2009–11 (P113451/P117270/P122483, U): Bank “recommenced with a new series before a self-evaluation could be completed” — same prior actions recycled across series |
| Gazetting of customs tariff amendments / Single Trade Window decree | Tariff schedule published or portal launched | Manual inspections unchanged; informal corridor charges persist; portal not connected to revenue authority; parallel paper processes continue | Africa Regional Trade DPO FY2015–16 (P129282/P146512, U): “policy operations without accompanying technical assistance are insufficient; the regional design also failed to account for asymmetric country commitment” |
| Adoption of a Public Debt Management Act | Law enacted | Domestic debt management office understaffed; contingent liabilities unrecorded; law confers powers no institution has capacity to exercise | Cabo Verde FY2015 (P147015, U): results frameworks lacked “clear links from objectives to reform areas, prior actions and target indicators” — attribution of any outcome impossible |
| Approval of a Revenue Mobilisation Roadmap | Cabinet endorsement | Roadmap not costed or staffed; prior roadmap from previous DPF series shelved without review; same template relaunched under new name | Angola FY2015 (P153243, U): “pressure to design a high-profile program that would garner strong international buy-in” led to targets that were “structurally unachievable from inception” |
| Decree to unify official and parallel exchange rates | Central bank circular issued | Parallel market persists within months; circular reversed under fiscal pressure; unification without institutional reform of central bank operations is inherently unstable | Togo FY2020/22 (P169867/P172023, MU): “implementing agencies given insufficient time to build up institutional capacity to execute structural reforms” — documented across both operations |
| Endorsement of a labour market reform strategy | Strategy document approved | Reforms require dismantling patronage networks; strategy approved but never costed, staffed, or legislated; no implementing agency designated | Tunisia FY2011 (P117161, U): without “solid political-economic analysis,” DPOs in labour and investment reform “cannot understand constraints caused by embedded political interests and corruption” |
| Publication of an Annual Borrowing Plan | Treasury document published | Plan not binding on supplementary budgets; borrowing regularly exceeds plan ceilings; audit trail absent; plan published after fiscal year already underway | Mali FY2017/19 (P157900/P161619, MU/FCS): “overambitious triggers had to be downgraded in PRISGO2 and ended up being input focused due to limited progress” — direct admission of trigger dilution to preserve disbursement |
MTI SUMMARY: The ten patterns above account for the majority of MTI’s 3,967 BC-coded macro/fiscal prior actions. In every case: the disbursement trigger is met; the functional reform is not delivered; IEG documents the failure; the same prior action template appears in the next series. The CPIA score for Fiscal Policy and Debt Policy and Management — the two criteria directly targeted by these conditions — has deteriorated since 2008 across Sub-Saharan Africa. SSA sovereign debt doubled 2012–2022. The prior actions were there throughout.
Global PracticeGovernance / Public Financial Management
Governance GP actions focus on PFM systems, procurement, and institutional oversight. S+ rate: 30.9% — slightly above MTI but still below the portfolio average of 35.5%. The form-function gap here typically runs between legal establishment and operational effectiveness: agencies created on paper that remain unfunded, understaffed, or politically captured.
| Prior Action Template (The Form) | Disbursement Trigger | Documented Function Gap | IEG Source & Rating |
|---|---|---|---|
| Launch of a national e-Procurement portal | Website go-live and user registration | Manual exemptions continue for most contract awards; portal not integrated with IFMIS or treasury; compliance target of 80% within six months structurally unachievable | Togo FY2020 (P169867, MU): the six-month window for achieving procurement compliance “was insufficient for government agencies to reform their procurement practices” in a weak-capacity context |
| Adoption of a Treasury Single Account Manual | Manual gazetted or formally approved | Bank accounts remain fragmented; spending units retain own accounts; TSA not connected to IFMIS; circular debt between MDAs continues off-system | Madagascar FY2019 (P166752, MU): capacity at the Debt Management Office “remained limited” despite formal adoption of the TSA framework |
| Passage of an Anti-Corruption Act or national strategy | Law enacted by parliament | New agency created but lacks prosecutorial power, dedicated budget, or judicial independence; strategy “not well designed, had very little political support, and never got implemented” | DRC FY2002/04 (P057293/P082443, U/FCS): anti-corruption strategy suffered from “weak strategy design followed by even weaker implementation” — repeated across DRC, Congo-Brazzaville, and related FCS cases |
| Approval of a Civil Service Reform Roadmap | Cabinet endorsement | Ghost workers not removed; payroll audit not completed; biometric verification deferred; “outcome indicators for civil service capacity are barely, if at all, indicative” of actual performance | Gambia FY2009 (P107398, U/FCS): civil service indicators measured inputs (share of local training in budget) rather than outcomes; fiscal and reform objectives directly contradicted each other |
| Issuance of a PFM Decree or IPSAS adoption circular | Ministerial circular issued | Accountants untrained; chart of accounts not updated; financial statements continue on cash basis; decree confers legal obligation no institution can discharge | Haiti FY2014 (P147166, U/FCS): supported “prior actions that were incipient in nature (e.g., a regulation requiring ministries to submit expenditure forecasts)” while expecting improved cash management in the same timeframe — structurally impossible |
| Establishment of an Independent Internal Audit Function | Law or decree signed | Audit committee reports to the same ministry it audits; positions unfilled; audit reports not published; independence nominal | DRC FY2004 (P082443, U/FCS): “action plans alone should be avoided as main loan conditions since they do not guarantee that the authorities will carry out the reforms” |
| Gazetting of Conflict of Interest Regulations | Regulations published | Declarations not publicly disclosed; no enforcement body designated; no prosecutions in any evaluated case; regulations issued in same cycle as related governance failures | Malawi FY2013 (P133663, U/FCS): “governments undertake reforms at a superficial level, and produce the form but not the substance of modernized institutions” — clearest statement of isomorphic mimicry in the dataset |
| Adoption of a Decentralisation Framework | Framework document approved | Sub-national transfers unpredictable; formula not implemented; intergovernmental arrears accumulate; framework approved without fiscal transfer legislation | Brazil Rio FY2013 (P126465, U): “DPLs supporting institutional reform at the subnational level require a long-term strategic vision”; stand-alone DPLs “unlikely to achieve such objectives without significant complementary support” |
| Submission of a Freedom of Information or Open Government Bill | Submission to legislature | Bill not progressed; information requests routinely refused; no compliance reporting mechanism; submission trigger decoupled from enactment | Mozambique FY2014 (P131212, U): “policy integrity” was assumed rather than verified — a pattern across transparency-related prior actions that meet submission triggers without legislative follow-through |
Global PracticeEnergy & Extractives
Energy GP paper triggers concentrate on tariff adjustments, regulatory independence, and sector unbundling — all of which require sustained political will to enforce and are therefore acutely vulnerable to reversal after disbursement. S+ rate: 57.7% — substantially better than MTI, but driven by the better-performing non-FCS/non-Africa portfolio. In FCS and Africa contexts, energy DPF failures reproduce the MTI pattern precisely.
| Prior Action Template (The Form) | Disbursement Trigger | Documented Function Gap | IEG Source & Rating |
|---|---|---|---|
| Issuance of a tariff adjustment decree | Presidential or regulatory order published | Decree suspended within 6–12 months under political pressure; circular debt grows; cost-reflective tariff never operationalised; arrears to generating companies persist | Mali PRSC 3–5 FY2009–11 (U): Bank “fell into the trap of repeating earlier mistakes” — identical energy tariff conditions recycled across a series already rated Unsatisfactory |
| Approval of a Renewable Energy Law | Law enacted | Secondary regulations not issued; feed-in tariff not gazetted; grid access rules absent; law creates framework with no implementing architecture | Tanzania FY2013/14 (P143645/P145254, MU): DPO “tripled TANESCO’s arrears despite over-achieving its income targets” — structural outcome the results framework had not modelled because prior actions measured legal approvals rather than utility financials |
| Establishment of an Independent Energy Regulator | Decree creating regulatory body | Regulator appointed by and reporting to energy ministry; tariff decisions require ministerial sign-off; regulatory independence is legal fiction | Dominican Republic FY2005 (P082712, U): “the main risks — stemming from high dependence on imported fossil fuels, deteriorating infrastructure, and significant governance issues — were not adequately addressed” despite formal creation of a regulatory authority |
| Reform programs agreed with transitional or caretaker governments | Conditions met; Board approval secured | Incoming elected government faces political costs of reforms it did not negotiate; reform momentum lost at change of government; this is a design flaw, not a country-specific failure | Bangladesh FY2008 (P107797, U): “reform programs agreed with caretaker governments are likely to face implementation problems when the reforms impose substantial political costs on the incoming government” |
| Approval of a Public-Private Partnership Law | Law enacted | No viable PPP pipeline; project preparation facility unfunded; first transactions not approved for years post-enactment; law creates framework for deals that do not materialise | Benin FY2014/15 (P132786/P146665, MU): “political economy considerations are essential to the timing, sequencing, and level of ambition of reform” — PPP laws approved without the institutional preconditions for transactions |
| Decree to unbundle integrated state utility | Legal separation decreed | Entities continue to share management, balance sheet liabilities, and staff; functional separation never achieved; unbundling creates new institutional complexity without resolving commercial viability | Tanzania FY2013/14 (P143645/P145254, MU): DPO “did not anticipate the increase in TANESCO’s arrears” because the programme measured structural reforms (unbundling decrees) rather than the commercial outcome they were meant to produce |
| Issuance of a Sector Debt Recovery Plan | Plan formally submitted to government | Plan not funded; arrears continue to accumulate post-submission; commercial viability of utility unchanged; plan presented as evidence of reform while sector finances deteriorate | Yemen FY2008 (P101453, U/FCS): “addressing deep-rooted poverty or increasing non-oil growth requires a well-considered strategy and a sharp focus in project design” — applicable to any sector plan approved without a financing mechanism |
Global PracticeFinance, Competitiveness & Innovation (FCI)
FCI prior actions span banking regulation, capital markets, insurance, and financial inclusion. S+ rate: 53.1% — the second-highest of all GPs, driven by performance in middle-income countries. The gap between legislative reform and supervisory effectiveness is especially acute in low-capacity environments where the regulator lacks the technical staff to enforce the law it has just passed.
| Prior Action Template (The Form) | Disbursement Trigger | Documented Function Gap | IEG Source & Rating |
|---|---|---|---|
| Recapitalisation of state banks combined with Banking Act reform | Law enacted; capital injection completed | Culture and incentives of banks unchanged; directed lending resumes within years; recapitalisation required again in subsequent series; legal reform without behavioural change | Lao PDR FY2002 (P068069, U): “critical to take sufficient action to change the culture and incentives of the banks” — without this, “there is a strong possibility that the banks will have to be recapitalized again”; the prediction proved accurate |
| Passage of a revised Banking or Financial Institutions Act | Law enacted | NPLs remain underreported; Prompt Corrective Action provisions unenforced; supervisory capacity absent; law creates obligations the regulator cannot exercise | Lao PDR FY2013/14 (P125298/P143025, MU): “line ministries perceived reforms as MOF-led, which led to difficulties in implementing reforms”; financial sector regulator was never the authentic owner of the conditionality |
| Approval of a Financial Inclusion Strategy | Strategy document endorsed | Strategy not costed; last-mile delivery targets aspirational; agent banking regulations not issued; digital financial infrastructure absent in target geographies | Afghanistan FY2020/21 (P172211/P176137, U–HU/FCS): “absence of a clear results chain” means financial inclusion prior actions cannot be evaluated or adapted — form of reform achieved while functional access remains unchanged |
| Establishment of a Credit Bureau by decree | Legal mandate issued | Bureau established but database empty; commercial banks not reporting; consumer credit remains informal; mandate not backed by reporting obligation or penalty regime | Multiple FCS ICRRs: legal establishment of financial infrastructure consistently preceded — by years — any operational use. Documented across DRC, Guinea, and Central Africa operations |
| Issuance of Mobile Money Regulations | Regulatory circular published | Regulations issued for market that does not yet exist; interoperability not mandated; uptake negligible; regulations technically valid but economically inert | Gambia FY2020 (P164545, MS/FCS): “the advisability of prioritizing the 4G network is questionable, considering that internet penetration stood at only 50 percent” — sequencing failure applicable to mobile money regulation issued ahead of basic connectivity |
| Adoption of a Deposit Insurance Framework | Law or decree enacted | Fund capitalisation far below minimum; trigger thresholds not defined; no resolution authority created; framework exists in law without the fiscal resource to activate it | Cabo Verde FY2014/15 (P127411/P147015, U): results frameworks lacked “clear links from objectives to reform areas, prior actions and target indicators” — impossible to assess whether enacted financial safety-net legislation had any protective effect |
| Submission of an Insolvency and Bankruptcy Reform Bill | Bill submitted to parliament | Bill not progressed; courts lack trained bankruptcy judges; reorganisation proceedings not used; submission trigger decoupled from enactment, let alone implementation | Tunisia FY2011 (P117161, U): reforms addressing “job entry” failed because they “required measures to ensure the jobs are there to be entered” — analogous logic: insolvency reform requires judicial infrastructure that legislative submission does not create |
| Decree to strengthen AML/CFT compliance | FATF-aligned law or regulation published | Financial Intelligence Unit unfunded; suspicious transaction reports not processed; no prosecutions; FATF greylisting avoided through legislative action that does not alter transaction monitoring capacity | Malawi FY2013 (P133663, U/FCS): governments produce “the form but not the substance of modernized institutions” — directly applicable to AML/CFT compliance frameworks enacted to satisfy FATF review cycles |
Global PracticeSocial Protection & Jobs
Social Protection prior actions frequently involve registry design, targeting systems, and cash transfer programme architecture. S+ rate: 60.0% — highest of all GPs. The form-function gap here is primarily a last-mile delivery problem: the system is designed and approved, but the institutional capacity to reach beneficiaries is not built in time or at all. The gap is most pronounced in FCS and in sub-Saharan Africa.
| Prior Action Template (The Form) | Disbursement Trigger | Documented Function Gap | IEG Source & Rating |
|---|---|---|---|
| Approval of a Social Registry design or roadmap | Cabinet or ministerial endorsement | Registry populated with unverified data; double registration; exclusion of poorest not addressed; registry exists as a database structure without a functioning enumeration process | Angola FY2015 (P153243, U): “pressure to design a high-profile program that would garner strong international buy-in” resulted in targets that were “structurally unachievable” — social registry timelines among the most consistently overestimated |
| Identification of pilot districts for cash transfer expansion | Formal district selection communicated | Pilots not funded; payment infrastructure absent; no biometric verification in pilot areas; district selection is administrative paperwork, not programme delivery | Bosnia and Herzegovina FY2010 (P116951, U/FCS): Bank “had not fully understood the influence and impact of key beneficiary groups and the constitutional questions surrounding the reform” — local political economy analysis absent from social protection design |
| Passage of a Social Protection Act | Law enacted | Act not accompanied by implementing regulations; budget allocation unchanged; delivery agency absent; law creates entitlement that cannot be honoured in the fiscal year | Haiti FY2010 (P117944, MU/FCS): “using DPLs in Haiti’s fragile, post-conflict setting is fraught with high risks” and required “strong institutional support to back up reforms” — absent for the social protection component |
| Adoption of a Targeting Methodology | Methodology document approved | Community-based targeting produces elite capture; proxy means test not calibrated for local conditions; errors of exclusion structurally high; methodology approved but not tested before deployment | Multiple FCS ICRRs (Mali FY2017/19, DRC, Malawi): targeting methodology prior actions met while beneficiary reach and accuracy remained unevaluated at closing |
| Approval of a Labour Market Reform Law | Law enacted | Enforcement inspectorate not resourced; informal sector unchanged; compliance monitoring absent; law creates framework that formal-sector employers comply with and informal-sector workers are excluded from | Tunisia FY2011 (P117161, U): “employment programs are regressive if they focus on formal sector entry” and “operations seeking to improve job entry efficiency require measures to ensure the jobs are there to be entered” — the structural precondition the prior action did not address |
ACROSS ALL FIVE GLOBAL PRACTICES: The form-function gap is not a marginal phenomenon confined to weak-capacity or FCS contexts. It is systematic. It appears in middle-income countries (Tunisia, Bangladesh, Dominican Republic), in non-FCS settings (Tanzania, Cabo Verde, Angola), and in operations that were rated Moderately Satisfactory as well as those rated Unsatisfactory. What varies is the severity of the gap and the visibility of its consequences. What does not vary is the structural dynamic: the disbursement trigger requires the form; the form is produced; the function does not follow; IEG documents this; the next series reproduces the same trigger. Twenty years of evidence. The design model has not changed.