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IPS175 Pietro Gennari et al.
            to produce the indicator with official sources. The main reason cited by those
            countries who refuse to authorize the publication of country estimates is the
            non-official nature of the data source. The result is that for those countries, no
            country value is published, as the NSS itself has not yet produced the indicator.
            Such  an  approach  effectively  presents  custodian  agencies  with  a  catch  22
            situation: they are obligated to request countries’ authorization, due to the
            use  of  non¬official  sources,  yet  most  countries  deny  the  authorization
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            precisely because of the non-official nature of the data source .
                Another problem with the UN Statistical Commission’s recommendation
            was that, at the time, no agreed mechanism existed for such a review, not even
            a set of key principles able to give guidance on fundamental questions such
            as  what  to  do  in  case  countries  did  not  respond  to  custodian  agencies’
            solicitations or outright rejected the estimate proposed. This was clearly not a
            satisfactory  situation,  as  it  meant  that  even  SDG  indicators  with  approved
            methodologies could go unreported by the majority of countries. Such an
            outcome would evidently hamper the ability to monitor progress toward the
            SDGs and risked undermining the credibility of the entire edifice of the 2030
            Agenda’s mutual accountability mechanism, grounded on the SDG indicator
            framework. In the next section, this article will review the main guidelines that
            were  developed  to  address  this  gap,  and  highlight  some  of  their  key
            shortcomings with regard to data validation.

            3.  Challenges for Data Validation
               Acutely  aware  of  the  serious  implementation  challenges  posed  by  the
            global reporting process, the UN Statistical Commission in 2017 instructed the
            IAEG-SDG to “develop guidelines on how custodian agencies and countries
            can  work  together  to  contribute  to  the  data  flows  necessary  to  have
            harmonized statistics”. The resulting “Guidelines on Data  Flows and Global
            Data  Reporting”,  developed  in  consultation  with  the  Committee  for  the
            Coordination of Statistical Activities (CCSA), are a critical document advancing
            consensus and collaboration among national statistical systems and custodian
            agencies.  However,  they  also  have  several  limitations.  Firstly,  some  of  the
            provisions in the Guidelines can be questioned as they may hamper, rather
            than  foster, consensus  and  collaboration  between  countries and  custodian
            agencies.  Secondly,  even  where  the  Guidelines  are  more  specific,  many
            countries are still opposed to their practical implementation, which can put
            custodian agencies in difficult situations. Thirdly, they are simply “guidelines”,
            mainly  outlining  general  principles,  and  despite  additional  supporting




              The CCSA has developed recommendations and collected best practices on the use of non-
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            official data for international statistics, see Op. Cit.
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