Anti-Corruption and Integrity Outlook 2024 – Country Notes: Estonia

Contextual factors

 

State structure	Executive power	Legislative system	Legal system
Unitary	Parliamentary	Unicameral	Civil law

Strategy and institutions on anti-corruption and public integrity

In 2012, Estonia adopted its Anti-Corruption Act, to combat corruption amongst all officials, including government, law enforcement, and other areas of the public sector. It is complemented by the Civil Service Act, which sets out a number of standards on integrity and ethics. In February 2021, the new government adopted the Anti-Corruption Action Plan 2021 – 2025, for which several annual activity reports have subsequently been published. The Action Plan addresses areas such as transparency of state activities and local government activities, a fair business environment, the investigation of corruption offences, and impact assessment of anti-corruption policies.

In terms of institutions, the Ministry of Justice leads the government’s anti-corruption policy and coordinates its implementation. Estonia has central government bodies responsible for lobbying (Ministry of Justice), open data policy (Ministry of Economic Affairs and Communications), political finance (Political Parties Financing Surveillance Committee), conflict-of-interest, and internal control and internal audit (Ministry of Finance). The Data Protection Inspectorate functions as supervisory body responsible for public information issues.

Overview

 

Greatest strengths	Areas to improve
Lobbying	Conflict of interest - implementation
Conflict of interest - regulation	Corruption risk management and audit - implementation
Transparency of public information	Post-public employment integrity

Anti-corruption strategy

Estonia's strategic framework, the Anti-Corruption Action Plan 2021 – 2025, performs above the OECD average.

The strategy refers to several sources of information on public integrity, including the Corruption Perceptions Index (CPI) and staff and business surveys. The strategy was developed in close collaboration with civil society groups and non-state actors. Estonia also has several safeguards to monitor and report on the implementation of the strategic framework. The action plan contains a list of actions to support each objective and facilitate implementation, and it identifies lead organisations for each objective. However, it is worth noting that the action plan does not contain outcome-level indicators to measure the impact of implemented actions. Annual monitoring reports are publicly available, and consultations with civil society organisations are conducted based on the monitoring reports.

Corruption risk management and audit

As measured against OECD standards on risk management, which include internal control and internal audit, Estonia fulfils 88% of criteria for regulations and 35% for practice, compared to the OECD average of 67% and 33%, respectively.

Estonia is among the top performers in the OECD in terms of its regulatory safeguards for internal control and risk management. The Government of the Republic Act defines internal control policies according to international standards, the objectives of internal control, managerial responsibility for internal control, and annual reporting activities. Standards of conduct for ministers, members of parliament, civil servants and other political appointees are also available. The existing risk management framework explicitly addresses public integrity risks, and the Risk Management Handbook supports public bodies through the steps of the risk management process.

In practice, integrity, corruption, and fraud are frequently included in the scope of public organisations’ audit plans. However, not all organisations have conducted risk assessment exercises in the past three years or have established a system for documenting the results of risk assessments. Less than half of organisations’ have recently conducted risk assessments covering integrity risks. Additionally, not all public bodies sampled have an audit charter in place. In Estonia 61% of audit recommendations issued were implemented within one year, but there is no data on how many public organisations were internally audited.

Lobbying

As measured against OECD standards on lobbying, Estonia fulfils 75% of criteria for regulations and 67% for practice, compared to the OECD average of 38% and 35%, respectively.

Estonia has developed a code of conduct outlining good practice for communicating with lobbyists. While Estonia collects publishes data on meetings between lobbyists and government officials, this data does not include information on the budget/expenses for lobbying activities and only sometimes includes the piece of legislation or regulation targeted. Furthermore, there have been no investigations for non-compliance as lobbying is regulated by guidelines.

Conflict of interest

As measured against OECD standards on conflict of interest, Estonia fulfils 89% of criteria for regulations and 22% for performance in practice, compared to the OECD average of 76% and 40%, respectively.

Estonia’s regulations such as the Civil Service Act and Anti-Corruption Act define conflict-of-interest situations and establish procedures and responsibilities for managing them at various levels of government. Furthermore, they require interest declarations upon entry into public office from members of the Government, parliament, members of the highest bodies of the judiciary, and top-tier civil servants of the executive branch. Although not for public employees in high-risk positions. However, Estonia does not fully track whether these regulations are implemented in practice. No central data was provided on compliance with declaration requirements, nor on the percentage of declarations verified or sanctions issued.

Political finance

As measured against OECD standards on political finance, Estonia fulfils 80% of criteria for regulations and 71% for practice, compared to the OECD average of 73% and 58%, respectively.

In Estonia, the Political Parties Financial Surveillance Committee monitors political finance. Regulations establish personal liability for electoral candidates who breach the rules, proportionate sanctions for such breaches, and bans on anonymous donations and contributions from foreign states and enterprises and publicly owned enterprises. Comprehensive reporting requirements and requirements for mandatory public disclosure of party finances are in place. All parties represented in parliament submitted financial reports to the Political Parties Financial Surveillance Committee in line with statutory deadlines, and they are publicly available on a single online platform in a user-friendly format.

Transparency of public information

As measured against OECD standards on public information, which include access to information and open data, Estonia fulfils 89% of criteria for regulations and 81% for practice, compared to the OECD average of 67% and 62%, respectively.

Estonia is a top performer in the area of public information. The Data Protection Inspectorate supervises public access to information. It conducts inspections and issues sanctions in cases of non-compliance. Many key integrity-related datasets are proactively published, including agendas and minutes of Government sessions, consolidated versions of primary laws, salaries of senior civil servants, public tenders, the business and land registries, and data on meetings of elected officials with interest representatives. However, no information was provided on whether conflict-of-interest and asset declarations for elected officials, members of the judiciary and senior civil servants are publicly available.