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identified and arranged access to all the key research participants based on extensive desk research on the role of respondents in their respective organisations and their engagement with SDGs processes in India and internationally. We were successful in arranging access to and conducting interviews with senior officials in the Indian CAG office, and particularly those who have been involved in the development and signing the India’s SDGs preparedness report. In addition, we successfully arranged access and conducted interviews with a wide range of respondents, including representatives of the UN agencies and civil society organisations that are working closely with and supporting the senior executives of the think tank responsible for developing policies and programmes on SDGs in India.

Our interview questions were guided by literature on SDGs, CSR in India, and public audit, although semi-structured questions allowed participants to discuss other

important aspects and supplementary questions that arose. Ethical approval was obtained from the appropriate committee at the authors’ university, and all interviews were recorded and transcribed before being analysed against the research question and concepts used. Pre- and post-interview reflections, frequent researcher meetings, and notes enhanced the quality of forthcoming interviews and subsequent analysis.

Table 1: Interviewee identifier and time

I# Organisational type Identifier # of



1 Agency1 NGO pushing for dialogic

democracy in

budget/accountability in India

3 71


2 Agency2 SDG program specialist at UN agency in India

1 54

mins 3 NITI Aayog (Agency2

staff deputised)

Aspirational districts specialist

1 38


4 Agency3 NGO pushing for dialogic

democracy in

legislation/accountability in India

1 76


5 Office of the CAG Responsible team for SDG audit activity

9 65

mins 6 Office of the CAG Environmental audit


1 85

mins 7 Office of the CAG Environmental audit


1 66

mins 8 Office of the CAG Environmental audit


1 61

mins We chose India as a case study due to its democratic claims and credentials along with long standing constitutional institutions, active engagement with CSR and sustainability over many years (Arora & Puranik, 2004; Bergman et al., 2019), its active contribution (and influencing of) the development and finalisation of the global SDG agenda at the UN7, its claim of a strong and continuing commitment to SDGs,

7 India was member of a 30-member Open Working Group (OWG) constituted by the UN General Assembly in 2013 for preparing a proposal on the SDGs and proactively contributed and shaped the development and finalization of SDGs.

and the Indian CAG’s focus on contributing to and encouraging audits of SDG initiatives globally (Inamdar & Dadhe, 2017) (see next section). Although the World Bank ranks India as a lower-middle-income country, it has grown considerably in the last three decades.8 Nevertheless, while since 1990, the percentage of the population at the national poverty line has halved (from 45.3% to 21.9%), in the same period, the percentage of income share held by the lowest 20% of the population has reduced from 8.9% to 8.1%. Income disparity remains high, and a local Indian umbrella NGO, Wada Na Todo Abhiyan (WNTA) (2017), notes the societal marginalisation of the poor and other groups discriminated against. Further, despite improvements, India retains a corruption perception index of 40/100, placing it 86/180 on Transparency International’s list.9 Nevertheless, the Government’s Strategy for India@75 (2022 is the 75th anniversary of India’s independence as a nation) (NITI Aayog, 2018) states an intention to eradicate corruption by improving financial and non-financial reporting and auditing systems. India also struggles with poor environmental performance as evidenced in its role in reducing the COP-26 goals regarding coal use.10

While India’s national government is committed to achieving the SDGs, it

acknowledges this demands support from all levels of government, private sector, and civil society (Lok Sabha Secretariat, 2017). Thus, as shown in Figure 1, it established a Think Tank – the National Institution for Transforming India, Government of India (NITI Aayog) to collaborate with the Ministry of Statistics and Programme

Implementation (MoSPI), map ministries and relevant SDG schemes to develop a vision, strategic and action plans (See Figure 1 and 2). India is a federal republic with state and local government structures beneath the central government (this includes 28 states and 8 union territories, further disaggregated into more than 700 districts and 664,369 villages, as of 2019). Each state/union territory (UT) operates a legislature with a degree of autonomy. However, states/UTs are encouraged to work in the national interest while also working in their local interests by operating in a

‘cooperative federalist’ manner (NITI Aayog & UN, 2019).

Figure 1. SDG Implementation: Institutional Structure in India (Janardhanan,

2016, p. 7)

Figure 2: The

8 See data at:



9 See: https://www.transparency.org/en/countries/india#

10 See, for example, https://www.theguardian.com/environment/2021/nov/14/india-criticised-over- coal-at-cop26-but-real-villain-was-climate-injustice

Indian Approach to Localising the SDGs (Partners for Review, 2020, p. 34)

Monitoring and measurement is a key UN SDG strategy. Nevertheless, collecting and compiling appropriate data are challenging (Abhayawansa et al., 2021). Development Alternatives (2016) outlined India’s shortcomings, including one-off or long periods between surveys (such as a census), lack of specific data to monitor SDG

achievement, no data disaggregation for states/UTs, and often a lack of transparency and understandability (see also Southern Voice, 2020). Hence, while India’s statistical capacity is deemed relatively strong internationally (Development Alternatives, 2016), it initially shared other nations’ challenges in SDG monitoring. MoSPI was commissioned to develop a National Indicator Framework (NIF) to capture the data and monitor the progress of SDGs and associated targets. These statistical indicators increasingly provide disaggregated SDG data. The SDG India Index (SDGII) initially had 62 indicators (NITI Aayog & UN, 2018); SDGII 2.0 now has 100 indicators, covering 54 of SDG targets and 16 goals (indicators for SDG 17 are not yet available) (NITI Aayog & UN, 2020). Nevertheless, Respondent 2 noted that the number of indicators measured varies by state/UT, with Respondent 8 being concerned about unmeasured gaps that will leave some SDG targets and goals unmet nationally. Thus, MoSPI and the UN Resident Coordinator Office in India developed the ‘India SDG Dashboard’ (a pictorial representation of the NIF – see Figure 3) to coordinate data gathering from various branches of government, to develop capacity in the (State/UT) users and to make the shortcomings and successes visible.11 The SDGII 2.0 dashboard (NITI Aayog & UN, 2020) encourages ‘competition’ between states/UTs to achieve

11 See: http://www.sdgindia2030.mospi.gov.in/dashboard/

against SDG target indicators (‘competitive federalism’). NITI Aayog serves as the government’s nodal agency responsible for driving SDG achievement through policy input, including programmes designed for ‘effective governance’ (See Figure 4). NITI Aayog & UN (2019) states that periodic reports, the NIF and dashboard will ‘promote data-driven decision making’ which they hope will lead to achieving the SDGs.

Figure 3: SDG India Index and Dashboard 2020-2112

As of 2019, 23 states/UTs have developed SDG-based vision documents, with a smaller number budgeting against SDGs, or at least recognising the costs and other impacts of state/UT programmes. Consideration is being given to central government grants to incentivise more states to engage with the national government pledges regarding SDGs (NITI Aayog & UN, 2019), although Respondent 8 suggested that further tax reforms would also be needed to broaden the funding base before schemes to lead to greater sustainability could be considered.

Figure 4: Seven Pillars of NITI Aayog13

12 https://pib.gov.in/PressReleasePage.aspx?PRID=1723952

13 https://pib.gov.in/newsite/PrintRelease.aspx?relid=114273

NITI Aayog recognises that, in addition to central, state/UT, and local governments, private sector initiatives are required to assist the government to deliver against its SDG pledges; thus CSR can be an effective mechanism to assist change14. Since 2013, large profit-making companies in India (including State Owned Enterprises) have been required under Section 135 of the Companies Act, 2013, to spend a minimum 2% of their average net profit on specified CSR activities (Arora et al., 2019; Jain et al., 2021; KPMG & UN Global Compact Network India, 2017). The Securities and Exchange Board of India (SEBI) also requires large listed companies to report against their sustainability practices (NITI Aayog & UN, 2019). Private

companies may usefully interact with civil society, and some states have encouraged Public-Private Partnerships (PPPs) to ‘plug development gaps’ (NITI Aayog & UN, 2019). The large industry association Confederation of Indian Industry (2018) celebrates these partnerships as ‘solutions for the world to achieve SDGs’. Charnock

& Hoskin (2020) call such approaches to sustainable development ‘metagovernance’, due to the complex governance arrangements nationally between different sectors, different levels of government and also international actors such as the UN. While NITI Aayog & UN (2019) suggest a well-coordinated approach to India achieving SDGs, Southern Voice (2020) notes major institutional coordination challenges due to the great variety of government/state/UT departments, policies, programmes, and projects. Audit critique may assist this call.


SAIs use INTOSAI as a forum to deliberate and develop capabilities, and support and consider new ways of audit to help them achieve their goals (Cordery & Hay, 2020).

As an active developer of professional guidance, encouraging knowledge-sharing and cooperative audits for environmental issues and sustainable development (INTOSAI, 2010), INTOSAI used its international congress to endorse SDGs and effective public audit and scrutiny of how governments were preparing to meet their SDG pledges, proposing a member portal to facilitate knowledge sharing (INTOSAI, 2015). In addition, UN Resolutions A/66/209 and A/69/228 evidence UN recognition of INTOSAI’s and SAIs’ roles in ensuring sustainable development, as does the 2015 joint UN-INTOSAI symposium on SAIs’ SDG roles (Guillán Montero & Le Blanc, 2019). INTOSAI’s 2017-22 Strategic Plan prioritised SDG monitoring to ‘make a meaningful independent audit contribution’ to SDGs. Utilising its development arm (INTOSAI Development Initiative (IDI)) and a specialist working group on

environmental auditing comprising representatives of SAIs, in 2016 INTOSAI launched an ‘Auditing SDGs’ initiative to support members in conducting

performance audits of nations’ preparedness for meeting their SDG commitments.

More than 70 SAIs and one sub-national audit office across developing countries have undertaken these performance audits (INTOSAI & IDI 2019), assisted by ISSAI 5130 and ISSAI 5800 (Rajaguguk et al., 2017). Ongoing research by INTOSAI’s Working

14 A Parliament of India Report on SDGs in 2017 also mentioned “The possibility of mobilizing financial resources from the private sector and other sources, therefore, needs to be explored. In this direction, in India, there is already in place the concept of Corporate Social Responsibility wherein the corporate houses shoulder some responsibility of socio-economic development in various sectors. Time has come to encourage and incentivize such practices with more focused interventions by the private players to yield better results.” (Lok Sabha Secretariat, 2017, p.12).

Group on Environmental Audit should also lead to further audit guidance for INTOSAI members (Respondent 8).

India’s CAG assumed the leadership of a specialist working group and carried out relevant research15 as recounted by respondent 7:

We had stakeholder consultation in India where we involved the Executive international financing organisations and the auditing community, and we worked together to think of how we could go about auditing SDGs. Thereafter, we actually hosted two workshops which involved more than 20 SAIs and that was… where this co-operative audit actually took off. And at the end of it, more than 70 countries came out with reports on preparedness [to implement the SDGs] which, as you would be aware, were discussed in the HLPF at the UN in July 2019. So, we have had our small contributions in all this.

The UN (2015) requires SDG monitoring but does not take into consideration and/or demand SAI inputs; therefore, the CAG’s (2019) ‘preparedness’ performance audit has been a surprising mechanism at country level for holding the Indian government to public account for its international SDG pledge. The CAG report calls for

necessary funding for achieving SDGs. Globally, these performance audits have improved processes, programmes and structures, both in government and SAIs (Monroe-Ellis, 2018).

It may be argued that India’s CAG (its SAI) is well-placed to critique, monitor and audit the government’s preparedness and actions to achieve the SDGs. First, the CAG is a constitutional authority, “independent of both the executive and the legislature”

(Stapenhurst et al., 2005, p. 6), placing it equal to the Supreme Court (Respondent 5).

Over 15 years, the Indian CAG has developed environmental audit expertise. Its authorised performance audits extend beyond monetary values (CAG, 2007, 2020). In 2013, the CAG established the International Centre of Environmental Audit and Sustainable Development (iCED) in Jaipur (India), offering internal training, 2-3 international courses annually, and it seeks to be a ‘global centre of excellence’.16 For example, iCED “hosted Audit Planning Meetings for cooperative performance audit on preparedness for implementation of SDGs in December 2017 for 27 SAIs…”

(Anonymous, 2019, p. 12). Further, recognising the need for continuous upskilling required for SDG audit, Respondent 7 confirmed:

In India we actually have a very robust mechanism where when we look at a performance audit for any major scheme of the government, we ensure that the team which does this audit is trained. At times we involve outside experts which includes private sector experts as well in training these people… I would say that it’s both, the digital skills as well as the human skills, which would need to be upgraded as we progress towards achievement of SDGs.

15 India chaired the working group, and took the lead on INTOSAI’s Project 2 (to understand “the status of SDG12 [Responsible Consumption and Production] and supporting SAIs in auditing the implementation of plastic waste policies” (INTOSAI Working Group on Environmental Auditing, 2020, p. 7)).

16 See: http://iced.cag.gov.in/wp-content/uploads/2014/02/Brochure.pdf. India’s CAG also advises on sustainable working and has taken a lead with other SAIs, such as Jamaica, on ‘greening’ SAIs.

iCED also worked with INTOSAI IDI on the global project on SDG preparedness audits.

The CAG regularly publishes on environmental issues (including its ‘Greenfiles’

newsletter). Twenty years ago it appointed a Deputy Auditor-General Scientific Departments focusing on environmental topics and this department has completed

“well over 100 environmental audits” (Anonymous, 2019). In addition to audit risk analysis, the CAG operates an Audit Advisory Board, which collates a wide range of inputs in deciding on performance audit topics. With “any important performance audit, [the CAG] begins with what we call an entry conference, where we inform the government that this is what we propose to audit and this is how we propose to go about it” (Respondent 7). Additionally, when undertaking performance audits now, the CAG also opines on the contribution towards SDGs of that programme

(Respondent 8). It is also responsible for auditing NITI Aayog and MoSPI, integral to India having appropriate policies to achieve the SDGs and for monitoring its progress.

The CAG has also developed particular expertise in IT audit, operating a similar training centre as iCED (testament to the CAG’s commitment to training as espoused by Respondent 5).17 Thus, it is unsurprising that the CAG is involved in research within the Asian Organisation of Supreme Audit Institutions (ASOSAI) to develop a model to assist SAIs in leveraging digital/big data to help SDG achievement.18 Such initiatives are prioritised despite slow progress on a 20-year plan to move India’s public sector reporting to an accrual basis, considered best practice globally.19 A third reason to utilise this case of India is the recent release of a Consultation Paper by India’s GASB on natural resource accounting. Respondent 7 noted this was a

‘world-first’, and the standard would be a natural precursor to an auditing standard in this area.

4.1 Evidence of integrated democratic accountability

In answering the question of how SAIs aid the move towards and development of integrated democratic accountability in both its dialogic and procedural forms, we focus on three different actor types. First, we focus on the government, particularly the NITI Aayog, as national nodal agency made responsible by the Prime Minister of India for developing and implementing policies for achieving SDGs at national level, to engage in the global space on SDGs, and to produce VNRs for presenting to the UN HLPFs (NITI Aayog, 2017, 2020). The VNRs are designed to generate and evidence procedural aspects of government accountability.20 The second actor type critiques and holds government to account; these agents comprise the CAG (2019) and PAC (2021), which, amongst other issues, are concerned by the lack of progress on collecting metrics, the types of metrics used (both procedural matters) and also the poor dialogic democratic accountability in NITI Aayog’s processes.21 The third actor type is non-governmental, including NGOs/civil society, and the UN agency in India.

17 India’s CAG also Chairs the INTOSAI Working Group on IT Audit.

18 See: https://www.intosaicommunity.net/user/postdetails/22. Respondent 5 notes the CAG has been a member of ASOSAI since 1953, chaired the UNs Board of Audit, been external auditor of WHO and other influential global entities.

19 CAG established the Government Accounting Standards Board (GASB) in 2005 to develop and introduce principle-based accrual accounting (Indian Government Financial Reporting Standards – IGFRS). A roadmap to accrual is undated but five pilot sites exist.

20 We also considered government department reports (for example, Ministry of Home Affairs, n.d.) and those from specific states (for example, Government of Karnataka, 2019). These also evidenced procedural accountability.

21 India’s PAC has 14 government and 8 opposition members, one of whom is the Chair. Stapenhurst et al. (2005) note India’s PAC is ‘typical’ in having government accept and implement a majority of their recommendations.

We analysed these actors at the national level, including through interviews and the research by Development Alternatives (2016), who deeply engaged with civil society sector to develop recommendations for government to monitor progress towards SDGs, WDTA (2017) which, similar to the CAG (2019) and PAC (2021), also critiqued poor dialogic democratic accountability by government, and PRS

Legislative Research (2021), which provides research support to politicians, tracks legislative activities and publishes information on legislative affairs for key actors as well as for the general public. Our respondents and documentary reviews enabled us to analyse how accountability as an integrated democratic process is being shaped in India through the interplay with international commitments to achieving SDGs at the national level. Democratic accountability relies on strong collaboration in a country of social complexity and diversity, cultural pluralism and social inequalities. First, we consider procedural approaches and in section 4.3, dialogic approaches and critiques.

4.2 Procedural democracy and accountability to progress the SDG plan 4.2.1 Processes instituted by government and its agency – NITI Aayog

To provide an initial boost to achieving the SDGs, India’s Prime Minister launched New India@75 (NITI Aayog, 2018), identifying the need to attend to India’s

heterogeneous living standards as one way of progressing his government’s pledge to achieve the SDGs. A programme named ‘Aspirational Districts’ sought an integrated approach in health and nutrition, education and agriculture to transform highly under- developed areas through the concerted co-ordination and efforts of relevant ministries and state governments (UNDP, 2020). Respondent 3 noted that initially, real-time monitoring data on these programmes’ success was collected, but data update and validation (e.g. household surveys) are now undertaken monthly to use averages and result in fewer discrepancies. This respondent continued:

…districts are supposed to make district vision plans and identify the low hanging fruits and basically convert schemes. So, convergence is given prime importance in the programme. Then there is competition among districts. Ranking is done every month and districts aspire to get good ranks in sectors… and overall ranking.

Following injection of funding (largely from private sector CSR funds), higher-ranked districts receive grant allocations, capped at a maximum. Competitive ranking builds on the Prime Minister’s term ‘collaborative federalism’ (between central, state/UT and district government), creating ‘competitive federalism’, where federalist states/UTs compete on key performance indicators against fellow states/UTs.

Respondent 3 commented that sometimes local newspapers cover rankings and

“[districts] are very happy when they get good ranks and especially when the money is also involved”, suggesting encouraging competition is effective. Respondent 8 also noted it was “a welcome move because that will encourage those states who are falling behind”. Nevertheless, in SDG terms, the push to ‘low-hanging fruit’ may prioritise speed and generalised metrics rather than systemic change. For example, Respondent 2 noted:

So, we have already achieved one (SDG) target, it’s to ensure electricity in all the villages… But having said that, electricity in all villages doesn’t mean [electricity]

in all houses.

Appropriate dialogic democratic accountability would not be discharged in the installation of electricity ‘in a village’, when it does not result in electricity to all dwellings. Such shortcomings reflect Charnock & Hoskin (2020), who note the over- prioritisation of statistics which ignore political feasibility (here, electricity for all is demanding feasibly). Charnock & Hoskin (2020) argue for accounting reports to make such (un)truth claims visible.

Although Covid-19 derailed some SDG progress (NITI Aayog, 2021), Agency2 continues to provide support “to ensure localisation and integration of SDGs”

(Respondent 6) as well as the state indicator frameworks, dashboards and to fund semi-annual monitoring by state/UT officials. Localisation provides states/UTs with opportunities to prioritise specific goals within their frameworks, and thus, state-level data has become more readily available down to the district level (Respondent 2).

This data and the push for change reflect procedural accountability mechanisms spawned by NITI Aayog as an agent of government.