Executive summary
Saint Lucia does not begin from a legal vacuum. The Constitution allocates ministerial and permanent-secretary responsibility, protects the Integrity Commission and Director of Audit, establishes an independent Director of Public Prosecutions and provides defined routes for continuity when a minister cannot act. Separate laws govern declarations, gifts, complaints, prosecution, finance, audit, procurement and public records.
The unresolved problem sits between those institutions. A declaration may be filed, a contract varied, an audit response sent and a Cabinet decision recorded without one public status layer showing whether the required step happened on time. Mandate junctions can delay referrals, weak records can damage transitions, and publication without due process can expose complainants or prejudge respondents.
The OAS anti-corruption review adopted on 12 March 2026 recommended stable resources for the Integrity Commission, clearer coordination between the Special Prosecutor and DPP, review of the illicit-enrichment framework and usable results data. It recorded that the Special Prosecutor's office was not yet fully staffed and operational. These are institutional findings based partly on an October 2025 visit, not accusations against any person.
SLPA proposes an administrative framework backed by targeted amendments after legal review: a ministerial conduct and recusal process; merit and integrity controls for boards; contract, variation and beneficial-owner publication; audit and major-decision registers; safe complaint routing; records and transition rules, and a small delivery unit that publishes aggregate performance but cannot control an investigation.
The first practical service reform should be a Public Rules Register. Existing government web and records staff can publish the current operating rules for 25 high-use programmes and services without creating a new institution. Each record should name the owner and legal authority, state who qualifies, list the steps and documents, set the service clock and correction or review route, and show its version, effective date, review date and change history.
Distilled from the SLPA research package on four unresolved policy systems, using the Constitution, integrity, prosecution, finance, audit, procurement and archives laws alongside the March 2026 OAS/MESICIC review.
The OAS findings describe institutional capacity and coordination; they are not findings of misconduct by any individual. Proposed thresholds, protocols, posts and costs require legal review and appropriation.
Key findings
Saint Lucia has the core institutions; their junctions need work.
Integrity, prosecution, audit, finance, procurement, public-service discipline and records functions have distinct legal owners. Common intake, referral, evidence-transfer and status rules can reduce gaps without merging or directing independent mandates.
Evidence-led findingA recusal is a management measure, not a verdict.
A potential conflict, complaint or investigation should trigger neutral jurisdiction and service-risk triage. A proportionate response may be disclosure, a paper barrier, recusal, lawful function transfer or portfolio reallocation, with the authority, duration and review date recorded.
Evidence-led findingContract risk continues after an award.
Plans and awards are only part of the public-money story. One identifier should connect procurement method, evaluation summary, signed contract, beneficial owner, implementation milestone, payment, variation, termination and completion.
Evidence-led findingA complaint front door should route cases, not own them.
Web, telephone, post and assisted channels can issue a secure receipt and send evidence once to the legally competent body. The router must not investigate, publish allegations or turn case age and conviction counts into staff incentives.
Evidence-led findingRecords are part of government continuity.
Official business conducted through personal channels should be captured promptly. Portfolio or government transitions need a legal hold and signed inventory of live decisions, contracts, deadlines, audit actions, appointments and access-controlled proceedings.
Evidence-led findingPeople need one current rule for each public service.
A grant, licence or public service is hard to use and hard to audit when its operating rules are spread across announcements, forms and offices. A versioned Public Rules Register would make the responsible owner, authority, eligibility, steps, documents, service clock and review route inspectable without changing the legal power of the agency that delivers the service.
Evidence-led findingInstitutional boundary
Publish each institution’s duties while preserving independent investigations.
The framework coordinates routine controls and public status. Independent institutions keep every power the Constitution and law assign to them.Use an administrative framework plus targeted amendments.
Put codes, registers, routing, publication standards and records controls into operation within 100 days while counsel settles the statutory gaps.
Do not merge or direct independent case functions.
The delivery unit cannot obtain confidential case files, decide complaints, direct the Integrity Commission, DPP or Special Prosecutor, or label an allegation as fact.
Publish compliance, delivery and follow-up status.
Show whether declarations, awards, variations, audit actions, board records, complaint-routing steps and high-use service rules are current without exposing protected evidence or personal data.
View 6 draft provisions
Policy proposal · Not legal advice
Administrative rules for lawful continuity and public evidence
These clauses are policy instructions for Attorney General and constitutional review. They are not current law, a formal legal opinion or findings about any officeholder.- 01Recusal minute
Record the interest category, restricted matter, lawful substitute, start and review dates, paper barrier and signing limits; state that the measure makes no adverse finding.
- 02Variation publication
Record authority, revised scope, price and time effect, cumulative change and approval before a variation takes effect, except a documented life-safety direction reviewed within ten working days.
- 03Beneficial-owner warranty
An awarded supplier identifies the natural persons who ultimately own or control it and reports material change; inconsistency triggers clarification and risk review with existing review rights preserved.
- 04Non-retaliation
A manager may not disadvantage a person for a qualifying good-faith report or cooperation. Protective action remains separate from investigative merits.
- 05Official records
Public business is captured to the official file, held under Archivist-approved schedules and legal holds, and cannot be destroyed or removed to frustrate audit, transition or proceedings.
- 06Public service rule
Each covered programme publishes one authoritative record naming its owner and legal authority, eligibility, steps, required documents, service clock, correction and review routes, version, effective and review dates, and change history.
Constitutional counsel must validate every leave, acting, function-transfer and portfolio scenario; especially any case involving the Prime Minister; before a protocol is adopted.
Month-12 operating standard
The framework sets public first-year compliance thresholds.
minimum share meeting the standardSLPA first-year green thresholds. Publish each numerator, denominator, exclusion rule, data owner and quality rating before assigning RAG status.
Use this data
Copy the visible figures or download them with the unit, claim label and method note attached.
SLPA policy proposal
Public Integrity and Government Machinery Framework
Make routine integrity duties easy to perform, hard to hide and fair to everyone, while keeping investigations, prosecutions, audits and adjudication independent.
Executive conduct and lawful continuity
Use written interests, gifts, lobbying, official-resources and records rules with confidential advice, documented recusals, proportionate consequences and constitutional continuity instruments.
Open appointments and functioning boards
Publish role and skills needs, selection route, term, vacancy, remuneration band, attendance, training and conflict-management status while the lawful appointing authority retains the decision.
Contracts visible through delivery
Publish covered procurements from plan to completion, including exception reasons, signed terms, beneficial-owner verification, payments, variations and delivery evidence.
Audit and major-decision registers
Connect each finding or major decision to an owner, due date, fiscal band, implementation milestone and review while preserving Cabinet confidentiality, privilege and protected information.
Safe complaints and fair enforcement
Provide one assisted front door, secure evidence transfer, anti-retaliation protection, jurisdiction rules, notice and answer, time standards and independent review under the applicable law.
Records and transition discipline
Capture official business, apply legal holds and retention rules, preserve audit trails and complete a signed, access-controlled portfolio inventory within 20 working days of transfer.
One current rule for each high-use service
Pilot a machine-readable Public Rules Register for 25 programmes and services, maintained by existing web and records staff. It should publish the owner, authority, eligibility, steps, documents, service clock, correction and review routes, version dates and change history without creating a new institution.
Delivery sequence
Name the owner and establish the real baseline
- Approve a Cabinet resolution naming the Cabinet Secretary as senior delivery owner while expressly protecting every independent mandate.
- Publish government's response to the OAS recommendations and a primary baseline of vacancies, declaration backlog, audit actions and procurement publication.
- Ask the Attorney General to certify the current legal and commencement map and review constitutional continuity scenarios.
- Freeze unauthorised record destruction and draft the executive code, recusal protocol and transition inventory.
- Select 25 high-use programmes and services for a Public Rules Register pilot, then name the existing agency owner and records or web editor for each one.
Open the core controls
- Have ministers and parliamentary secretaries sign the code; launch interests-management, recusal and board registers with lawful redaction.
- Open the assisted complaint router and sign referral, deconfliction and evidence-custody rules accepted by each competent institution.
- Pilot award, beneficial-owner and variation publication in three high-spend ministries using one contract identifier.
- Publish the first 25 Public Rules Register records in accessible web pages and machine-readable form, with a responsible owner, legal check and review date for every record.
- Approve a stable funding and staffing response for the Integrity Commission and Special Prosecutor without executive case direction.
Publish a tested government-wide scorecard
- Put every ministry on the registers and verify ownership status for every covered award.
- Publish an independently checked data-quality report and the first six-month scorecard for parliamentary scrutiny.
- Introduce protected-disclosure and targeted procurement or integrity amendments after consultation and constitutional review.
- Run a change-of-government and hurricane procurement exercise, then publish the process failures and corrections.
Extend the controls and review the law
- Scale proportionately to statutory bodies and state-owned enterprises.
- Connect procurement, finance and public registers with open, exportable standards and independent security testing.
- Evaluate the framework in years two and five, revise thresholds and run annual regional peer and disaster reviews.
Responsible institutionsFramework delivery and independent case decisions have different owners.The offices below are named from located official or OAS records. Names establish responsibility or documented status; they imply no view about personal conduct and should be rechecked at adoption.5 owners
Set Cabinet direction, fund the framework and remain politically accountable for ministerial-code consequences within the Constitution.
Own implementation templates, Cabinet decision controls, recusal records and transition certificates without access to protected case files unless law permits.
Lead the Commission's independent statutory functions and determine what coordination or aggregate data arrangements it lawfully accepts.
Exercise the office's statutory functions independently and agree lawful referral or case-deconfliction rules with the DPP and other competent bodies.
Retain sole lawful control over audit findings, prosecutorial decisions and parliamentary scrutiny; the executive dashboard reports status without rewriting those decisions.
The current full Integrity Commission roster, Director of Audit, DPP, Director of Finance, Accountant General and authorised posts should be confirmed from primary records before launch.
Public accountabilityMeasures for public accountabilityQuarterly operating signals and one independently reviewed annual outcome report.7 measures
Tracks routine compliance without publishing protected declaration particulars; proposed green threshold is at least 90% by month 12.
Shows whether transparency follows direct, emergency and competitive procurement into implementation.
Tests whether beneficial-owner information is checked rather than collected as an unverified form.
Keeps management follow-up visible while only the auditor may call a finding accepted or closed.
Tests the router's timeliness without rewarding rapid closure, accusation or conviction.
Makes records, deadlines and service continuity measurable before a political or disaster transition.
Tests whether each of the 25 pilot services has one legally checked record with an owner, eligibility, steps, documents, service clock, review route and visible version history.
04Limits, uncertainty & sources7 limits · 10 sources
Limits of this analysis
- This is policy architecture, not a constitutional opinion, enacted code or finding about any person. The Attorney General and legislative process must settle final authority and language.
- The OAS report was adopted in March 2026 and relies partly on an October 2025 visit. Current budgets, staffing, backlogs and operating status require fresh primary confirmation.
- Absence from a public website does not show that a declaration, appointment, response or internal record does not exist or that any duty was breached.
- The EC$3.4 million year-one and EC$2.25 million recurrent figures are central planning scenarios, not vendor quotes, appropriations or a settled capital/recurrent split.
- Publication must be reconciled with confidentiality, privacy, procurement review, national security, legal privilege, fair-trial rights and protection of complainants and witnesses.
- The proposed EC$100,000 direct or emergency award threshold, EC$250,000 works threshold, 20% cumulative variation review and 90-day time-extension review require legal and market calibration.
- The Public Rules Register is a bounded 25-service pilot using existing web, records and programme staff. It is not a new regulator, does not replace the underlying law and requires each agency to certify that its published rule is current.