Anti-Corruption Reform Tracker[1]
Reform
Area: Anti-Corruption,
Integrity, and Transparency
Last Updated: August 2025
Citizen Impact Summary
Dimension |
Snapshot |
Source |
Who
Is Affected? |
Lebanon’s entire
population is impacted, with depositors facing de facto losses, vulnerable
groups disproportionately affected by inflation, service collapse, and
informalization, and the middle class shrinking from 57% to 40%. |
World Bank Lebanon - Systematic country
diagnostic, Summer 2024 |
Financial
Burden? |
The financial
collapse, driven by systemic corruption and unregulated banking practices,
has cost smaller depositors an estimated US$15 billion and rendered the
sector insolvent with over US$70 billion in losses, while the public debt
surged amid unchecked fiscal mismanagement. |
World Bank Lebanon - Systematic country
diagnostic, Summer 2024 |
Public
Services? |
Corruption has led to the deterioration of public
services, including healthcare, education, and infrastructure, affecting the
quality and accessibility of essential services for the population. |
|
Mental Health Toll? |
Widespread trauma, compounded by corruption, crises, and
lack of accountability, has led to severe psychological distress, rising
suicide risks, and untreated mental illness. Inadequate services, stigma, and
impunity deepen public despair and erode resilience |
Overview
& Objectives
Goal |
Establish a transparent, accountable governance system capable of
preventing impunity, safeguarding public resources, and restoring citizen
trust through institutionalized
anti-corruption measures. |
Strategic
Importance |
Meeting obligations under UNCAC, 3RF, and SDG 16; enabling
fiscal integrity, public investment efficiency, and donor confidence. |
Key
Reform Priorities |
1. Legislative Framework: Enact and
enforce anti-corruption laws aligned with international standards. 2. Integrity in Public Office:
Institutionalize merit-based appointments and codes of ethics across the
public sector. 3. Procurement Reform: Operationalize
the Public Procurement Authority and reduce systemic vulnerabilities. 4. Judicial
Independence: Strengthen the
judiciary’s autonomy and capacity to prosecute corruption. 5. Oversight Bodies: Modernize and
empower institutions such as the Court of Accounts, Central Inspection, and
Ombudsman. 6. Civic Engagement: Promote public
participation, awareness, and media accountability in anti-corruption
efforts. 7. Sectoral
Prevention: Mainstream
corruption risk management in key sectors and promote private sector
integrity. |
Reform
Actions & Status
Specific
Reform Actions & Accountability
Reform Action Required |
Current Status (up to date) |
Lead Authority |
Implementing Body |
Oversight / Supporting Actors |
Primary Source |
Subject Casino du Liban, Middle East Airlines, and
Régie to Public Procurement Law & ex-post CoA audit |
Draft law discussed in Economy Committee; recommendation
for joint study by CoA & PPA within 1 month |
Parliament (Economy Committee) |
CoM & Line Ministries |
Court of Accounts (CoA), Public Procurement Authority
(PPA) |
|
Lift parliamentary immunity and launch judicial
investigations in high-profile corruption cases |
Immunity lifted for ex-Minister George Bouchikian; 3
telecom ex-ministers under parliamentary investigation |
Parliament |
Public Prosecution |
Judiciary, NACC, Media |
|
Operationalize judicial proceedings for corruption
in telecom and industry sectors |
Investigations ongoing; arrest warrants for 4 ministry
employees; Interpol alert for director abroad |
Public Prosecution |
Judiciary / SIC |
NACC, Ministry of Justice |
|
Integrate integrity education in curricula and
public awareness campaigns |
MoU signed between NACC & Center for Educational
Research and Development (CERD) to integrate anti-corruption content |
NACC |
CERD |
UNDP, GIZ, CSOs |
|
Fund the National Anti-Corruption Commission (NACC) |
Internal regulations adopted (early 2024); operating
budget line approved in 2024 and 2025 budgets; Treasury advance of 13.8
billion LBP released Dec 2024. |
Council of Ministers |
NACC (upon activation) |
UNDP, MoF |
|
Comprehensive Civil Service Census |
LFF-funded project
approved; blocked over privacy & outsourcing issues; resolve data‑privacy
reservations and decide whether to contract a private firm; issue start
decree. |
Council of Ministers / OMSAR |
OMSAR |
Central Inspection, Civil Service Board |
|
Launch
transparent, merit-based appointment framework for first-category civil
service posts |
Pledged in Feb 2025 ministerial statement; implementation
mechanism pending |
Council of Ministers |
OMSAR / Civil Service Board |
Central Inspection |
|
Appoint or activate boards of key oversight bodies
(e.g. telecom, aviation, media) |
Declared commitment; no timelines or decrees issued yet |
Council of Ministers |
Line Ministries |
Court of Accounts |
|
Operationalize
international judicial cooperation in anti-corruption investigations |
Political pledge; legal framework and MOUs needed |
Ministry of Justice |
Judiciary / SIC |
NACC, International Partners |
|
Operationalize Public Procurement Authority (PPA) |
Internal & financial regulations adopted (18 Dec
2024); legal staff recruited; transfer
2025 budget allocation & complete e‑procurement roll‑out. |
Council of Ministers / MoF |
Public Procurement Authority |
Court of Accounts, World Bank, GIZ |
|
Access-to-Information
Law enforcement |
Decree No. 6940
(2020) remains poorly implemented. According to the NACC’s 2025 report: only
40% of administrations publish information proactively, fewer than 50% of
national administrations and only 25% of local ones have appointed
information officers. 76% of ATI requests were fulfilled at the national
level, and 63% locally. Enforcement mechanisms remain weak, with NACC’s
binding decisions often ignored. |
Council of Ministers |
Line ministries |
OMSAR, Central Inspection |
NACS; NACC Annual Report on ATI Implementation, 3
April 2025 – launched at UNESCO Conference; supported by UNDP, EU, and Danish
Government |
Whistle-blower
Protection System |
Law in force (2018, amended 2020); Reception
Office remains inactive. |
Ministry of Justice |
NACC (upon activation) |
UNDP, Parliament |
|
Asset
Recovery Law implementation |
Law 214/2021 adopted; executive decrees pending; draft decrees; set up asset‑tracing
task‑force. |
Ministry of Justice |
SIC / Public Prosecution |
NACC (post-activation), Central Bank |
|
Enforce
asset declaration obligations under Law 189/2020 |
NACC received over 20,000 declarations (as of April 2025);
verification ongoing. Declarations remain confidential. TI-Lebanon recommends
making them public for high-risk sectors. |
Civil Service Board, NACC |
NACC |
Parliament, Judiciary |
NACC
ATI Report (April 2025); TI-Lebanon, Nidaa Al-Watan, 13 Feb 2025 |
Reform
Roadmap Timeline & Critical Path
Recent Milestone
Date |
Description |
Critical Path Status |
Source |
Jul
2025 |
Parliament lifts immunity for ex-Minister Bouchikian and forms a
committee to investigate 3 telecom ex-ministers |
Breakthrough in judicial accountability for corruption |
|
Jul
2025 |
Economy Committee approves draft law to subject Casino, MEA, and Régie
to Public Procurement & CoA oversight |
Expands procurement transparency to major state-linked
enterprises |
|
Jul
2025 |
NACC–CERD MoU signed to integrate anti-corruption awareness into
curricula and extracurricular activities |
Public awareness & preventive education milestone |
|
Dec
2023 |
Fund the National
Anti-Corruption Commission (NACC): NACC bylaws approved by Council of
Ministers |
NACC bylaws approved by Council of Ministers |
|
Dec
2024 |
Operationalize
Public Procurement Authority (PPA): Council of Ministers adopted three key
decrees for the Public Procurement Authority (PPA) |
PPA legal framework finalized |
Procurement
Reform In Lebanon Progress Note – For The Period May – December 2023 |
Feb
2025 |
Asset Declarations
(NACC / Law 189/2020): Prime Minister and President submitted financial
disclosures to NACC. While legally compliant, this is symbolic; systemic
enforcement and follow-up remain lacking. |
Formal step under asset declaration obligations |
|
April 2025 |
Access-to-Information Law enforcement: NACC released first annual report on
implementation of Right to Information Law |
Identifies 76% of
information requests were answered nationally, compared to 63% locally |
Next
Steps – Transparency and Accountability Calendar
Action |
Responsible Entity |
Target Date |
Source |
Pass
law to include Casino, MEA, and Régie under Public Procurement Law |
Parliament & CoM |
Q3 2025 |
|
Launch
judicial proceedings and asset-freezing for ex-ministers and implicated
directors |
Public Prosecution /
SIC / Judiciary |
Q3–Q4 2025 |
|
Launch
NACC-CERD nationwide integrity education program |
NACC & CERD |
Q4 2025 |
|
Comprehensive
Civil Service Census: Approve decree launching civil-service census and confirm contractor |
Council of Ministers
(CoM), OMSAR |
- |
|
Fund
the NACC: Include NACC funding in 2025 draft budget |
CoM, Ministry of
Finance |
- |
|
Whistle-blower
Protection System: Approve SOPs and launch whistle-blower hotline |
Ministry of Justice, NACC |
- |
|
Asset
Recovery Law implementation: Adopt asset-recovery decrees and task force plan |
MoJ, SIC, NACC, Council of Ministers |
- |
Implementation
Bottlenecks & Required Actions
Bottleneck |
Road‑Map Diagnosis |
Required Counter‑measure |
Comprehensive
Civil Service Census: Census privacy stalemate |
Objection from CSB & unions |
Use GDPR style
safeguards; outsource only data capture, keep analytics in OMSAR |
Weak
enforcement of Access to Information (ATI) Law |
Less
than 50% of national administrations and only 25% of local
administrations appointed information officers; low rate of proactive
disclosure. Despite NACC’s legal authority, its decisions under the ATI Law
are not universally enforced. |
Mandate appointment of trained information officers;
enforce legal timelines; and amend the ATI Law to mandate penalties for
institutions that fail to comply with lawful information requests and NACC
directives. |
Dysfunctional NACC operations |
Institutional
paralysis due to lack of administrative staffing, over-reliance on externally seconded
staff, and legal ambiguity over mandate |
Approve and fund
NACC's staffing plan via Civil Service Board; clarify its role through
legislative amendments; transition from donor-reliant operations to
state-funded independence |
Stakeholders
& Roles
Entity |
Core Function |
Primary Contact Point |
National
Anti-Corruption Commission (NACC) |
Lead agency for
receiving complaints, initiating investigations, and issuing integrity
reports (activation pending). |
Council of Ministers Secretariat |
Office
of the Minister of State for Administrative Reform (OMSAR) |
Coordinates implementation of NACS and leads public sector
reform initiatives. |
Minister of State for Reform |
Court
of Accounts |
Conducts external audits on public expenditures; ensures
compliance with legal frameworks. |
President of the Court of Accounts |
Central
Inspection (CI) |
Performs administrative inspections, evaluates service
delivery, and enforces internal controls. |
Inspector General |
Public
Procurement Authority (PPA) |
Oversees procurement transparency, approves tendering
processes, and manages e-procurement systems. |
President of the PPA |
European Union Delegation (EU DEL) |
Provides policy
guidance, technical assistance, and budget support for governance and justice
reforms. |
Governance & Rule of Law Attaché |
United Nations Development Programme (UNDP) |
Supports NACS implementation, capacity-building for
oversight institutions, and civic engagement initiatives. |
UNDP Governance Team, Lebanon CO |
World Bank (WB) |
Provides analytical support and financing for procurement
reform, fiscal transparency, and integrity systems. |
Governance Practice Lead, MENA Region |
International Monetary Fund (IMF) |
Sets anti-corruption structural benchmarks and advises on
financial transparency and institutional reform. |
IMF Lebanon Mission Team |
GIZ / AFD / SIDA |
Fund targeted reform programs (e.g., procurement,
judiciary, civil service) and support institutional strengthening. |
Country Programme
Leads |
Legal
& Policy Framework
Instrument |
Status |
Key Provisions |
Implementation Note |
Law
No. 28 (2017), amended by Law No. 233 (2021) (Access to
Information) |
In force |
Grants public access to official information; broadens
access rights and narrows exceptions |
Implementation
decree No. 6940 issued in 2020; national guide and training initiated; most
ministries non-compliant; law not yet enforced uniformly |
Law
No. 83 (2018) (Whistleblower protection) |
In force |
Establishes protections and incentives for whistleblowers |
Dependent on NACC activation; interim mechanism through
Public Prosecution at Court of Cassation; Reception Office for Whistleblowers
established |
Law No. 182 (2020) (Amends
whistleblower law - Expands legal safeguards) |
In force |
Allows Court of Cassation to receive disclosures in
absence of NACC; ensures protection for whistleblowers and their families |
SOPs and reception office created; staff trained; digital
system in development with UNDP/UNODC support |
Law No. 189 (2020) (Asset
declarations and illicit enrichment) |
In force |
Mandates periodic asset declarations and enhances
penalties for illicit enrichment |
Enforcement
initiated; asset registry system being digitized; compliance follow-up under
way by Civil Service Board and judiciary |
Law No. 214 (2021) (Asset recovery
law) |
In force |
Establishes mechanisms for recovering illicitly gained
assets; allows settlements |
Implementation decrees pending; task force and recovery
fund under development |
Law
244/2021 (Public Procurement) |
In force |
Establishes the Public Procurement Authority (PPA);
mandates e-procurement system |
Decrees on internal structure and financial regulations
adopted; operationalization ongoing |
Law
214/2021 (Asset Recovery) |
In force |
Defines procedures for seizing and returning illicit
assets to the Lebanese state |
Requires implementing decrees and coordination with
judiciary and anti-corruption bodies |
Law
1/2025 (Bank Secrecy Amendment) |
In force (April 2025) |
Lifts secrecy for anti-money laundering and asset recovery
investigations |
Enables SIC, NACC, and oversight entities to access
financial data without prior hurdles |
Official
Sources and Reference Materials
Instrument |
Source |
Statement of Ministerial Policy (Feb 2025) |
|
National Anti-Corruption Strategy |
|
3RF Governance Priorities |
|
National Anti-Corruption Strategy 2020 - 2025 |
|
World Bank Lebanon - Systematic Country Diagnostic, Summer
2024 |
World Bank Lebanon - Systematic country
diagnostic, Summer 2024 |
List
of Acronyms – Anti-Corruption Reform Tracker
Acronym |
Full Name |
AFD |
Agence Française de
Développement |
BCC |
Banking Control Commission |
BdL |
Banque du Liban (Central Bank of Lebanon) |
CAS |
Central Administration of Statistics |
CI |
Central Inspection |
CoM |
Council of Ministers |
CSB |
Civil Service Board |
EU
DEL |
European Union Delegation |
ERA |
Electricity Regulatory Authority |
GIZ |
Deutsche
Gesellschaft für Internationale Zusammenarbeit |
HJC |
Higher Judicial Council |
IMF |
International Monetary Fund |
MoE |
Ministry of Environment |
MoF |
Ministry of Finance |
MoJ |
Ministry of Justice |
MoSA |
Ministry of Social Affairs |
MoEW |
Ministry of Energy and Water |
NACC |
National Anti-Corruption Commission |
NACS |
National Anti-Corruption Strategy |
NSPS |
National Social Protection Strategy |
OECD |
Organisation for
Economic Co-operation and Development |
OMSAR |
Office of the Minister of State for Administrative Reform |
PPA |
Public Procurement Authority |
PMO |
Prime Minister’s Office |
SIC |
Special Investigation Commission |
SIDA |
Swedish International Development Cooperation Agency |
SOGIESC |
Sexual Orientation, Gender Identity and Expression, and
Sex Characteristics |
SOPs |
Standard Operating Procedures |
ToRs |
Terms of Reference |
UNDP |
United Nations
Development Programme |
UNODC |
United Nations Office on Drugs and Crime |
WB |
World Bank |
[1] All reform data presented
here is based on official Lebanese government sources, such as laws, decrees,
strategies, and verified public data. Where possible, each update is linked to
a document, gazette entry, or institutional publication.