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IPS175 Pietro Gennari et al.
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documents subsequently produced to clarify implementation modalities,
there is still no specific mechanism foreseen for data validation, in case the
estimates have not been produced by the national statistical system.
a. Provisions that may hamper collaboration between countries and custodian
agencies
One of the most controversial provisions in the Guidelines is included in
paragraph 24.c), which foresees that “if a country disagrees with the
methodology used to produce the internationally comparable indicators or
the indicator value itself”… and a mutually agreeable solution cannot be found,
then the country data for the indicator should not be published. This provision
is problematic on a number of counts, but it also marks a clear instance in
which the validation of methods and data can be conflated. Firstly, in principle,
individual countries should not be in a position to question the methodology
of SDG indicators, which is a prerogative of the IAEG-SDG, through the Tier
classification system. Secondly, even if we assume a broad reading of the term
“methodology” to also include “selection of a data source”, then this raises
another question: is the purpose of the validation procedure to provide a
country with the opportunity to question the data source per se, or should it
rather be to check that the internationally established methodology has been
properly applied in calculating the country estimate? In the authors’ view, the
latter alternative is correct, which is also corroborated by a preceding provision
under article 23.b) that suggests that:
“The decision on whether to utilize the data set [provided by an entity outside
of the NSS] shall…take into account the professional and scientific
independence of the data provider, the use of scientific methods and
impartiality, while also keeping in mind the two important principles of country
ownership of SDG monitoring and the value of internationally comparable
data and statistics”.
The third reason that provision 24.c) is problematic is that it foresees the
possibility for a country to disagree with the indicator value itself. This
effectively means that regardless of whether a methodology is internationally
approved, or whether the non-official source is properly vetted, or whether
the country estimate has been produced in accordance with the established
methodology, a country could still veto the publication of the estimate. As
there are apparently no statistical reasons left to claim, countries may refuse
the publication of country estimates presumably on the basis of non-statistical
reasons. Custodian agencies are further compelled to follow the same
procedure “for subsequent years until the country is able to compile the
indicator according to international standards and definitions”. This means
that even if a country has validated an estimate produced by a custodian

9 Op. cit., 4
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