Policy Coherence and Impact Measurement for Sustainable Development


Dr Lara Bezzina


Complete Report (PDF)

Focus on Policies Impacting Migrants in Malta

The Sustainable Development Goals (SDGs) laid out in the Agenda 2030 comprise elements of economic development, social inclusion and sustainable environmental management, and the idea that these interconnected components cannot be tackled separately.1 In view of this, there is an evident need of policy coherence for sustainable development (PCSD), including at country level. The study “Policy Coherence and Impact Measurement for Sustainable Development Focus on Policies Impacting Migrants in Malta2 summarised here explores this concept from different aspects with regard to the state of play in Malta. It aimed to:

  1. assess the state of play of PCSD with regard to the SDGs implemented in Malta
  2. investigate the ways in which Malta reports on – and measures the impact of – policies on SDG targets
  3. explore the involvement of civil society in implementing and promoting sustainable development; and
  4. explore the impact of policies and practices regarding pertinent SDGs on migrants in Malta.

The study was conducted through a combination of interviews with key stakeholders and desk review of policies, governmental and parastatal reports and other key documents.


State of Play of PCSD in Malta

Sustainable Development (SD) in Malta is underpinned by two main documents. The Sustainable Development Act of 2012 establishes measures to mainstream sustainable development across policy areas, including coordination mechanisms among different ministries and government agencies.3 The Act sets up two bodies – the Guardian of Future Generations (GFG) and the Sustainable Development Network (SDN), who are together responsible for coordinating and implementing Malta’s SD.4 However there seems to be no readily available information or reports on the work that the GFG has carried out since its establishment; and the SDN’s mandate was initially not backed by the necessary resources to do the work. The current SDN has now applied for resources which – according to a Sustainable Development Directorate (SDD) representative –will be allocated through the forthcoming Budget5 measures. The same Act states that every Ministry shall have a Sustainable Development Focal Point, whose function is to mainstream sustainable development across their Ministry. Meanwhile, the SDD is working to enable different ministries to work together, mainstream sustainable development principles, and to develop their annual budget measures based on such principles. However, the SDD representative confirms, there is need for more training on data collection methods and awareness of sustainable development.6

The second document, the national Sustainable Development Vision for 2050 (SDV 2050), was launched in 2018. The SDV affirms the government’s commitment to mainstreaming the principles of sustainable development; nonetheless it contains very little reference to coherence. The SDD representative confirms that such content will be contained in the Strategy and Action Plan that is to follow the Vision to assist in its implementation.7

Meanwhile, according to the annual Sustainable Development report for 2018,8 sustainable development has been mainstreamed in the government’s operations and policy formulation. Evidence, however, demonstrates otherwise: the lack of cohesion between policies such as those related to education and health, and sustainability, is underscored by the 2017 issue of the Social Watch Report for Malta.9

Reporting and Measurement of the Impact of Policies on SDG Targets

Conflicting information between that published and what is implemented is also found at the reporting and measurement level. While in its report for the Voluntary National Review (VNR) of 2018,10 the then Minister for Foreign Affairs and Trade Promotion (MFTP) states that the country has already met or exceeded a number of SDG targets; civil society reports11 argue that the targets covered by the MFTP report are not directly relevant to the SDGs. Furthermore, the European Sustainable Development Network (ESDN) profile12 on Malta states that new policies – and revisions of existing policies – will reflect the country’s commitment with regard to SDGs. The first step towards this is mapping existing national policies against the SDGs. The SDD representative, however, notes that this exercise currently consists of mapping which policies and strategies exist in the different ministries, but does not yet include mapping against the SDGs. The SDD is exploring the ways in which these policies can fit with the SDGs and how this can become integrated towards policy coherence.13

Meanwhile, the implementation of SDG 1 is currently being audited by the National Audit Office (NAO).14 Beyond SDG 1, however, the Maltese government does not appear to be measuring the impact of its policies on SDG targets. When questioned on this aspect, stakeholders – as well as the Malta SD report for 201815 – refer to the United Nations (UN) SDG Index and the Eurostat SDG Indicator, with no specific reference to how Malta measures its achievements. This is also evidenced by the lack of reference to SDGs in policy implementation reports or programmes such as the National Reform Programme of 2020.16 The current lack of impact measurement is equally related to the absence of monitoring mechanisms assessing the impact of its policies on sustainable development.17 The Strategy and Action Plan to follow the SDV 2050 will, according to the SDD representative, cover impact measurement.18

Involvement of CSOs in Implementing and Promoting Sustainable Development

Kopin argues that there is a lack of consultation with regard to PCSD and monitoring of progress on the achievement of the SDGs in and by Malta.19 The Sustainable Development Act establishes that the GFG is to engage NGOs in SD advocacy. The Act was then revised in 2019 in a bid to further increase the participation of civil society organisations (CSOs) and other social actors in mainstreaming sustainable development. Consultation by the government with civil society in the drafting of key development documents is also emphasised on the ESDN website, where it is stated that such inclusiveness is safeguarded through consultations and “national stakeholder engagement mechanisms.” However, there is no further information on these; and the national platform of Maltese Development NGOs (SKOP) decries the lack of consultation on the VNR report of 2018. Thus, calls have been made by civil society for an inter-agency forum to include CSOs; however, these calls have, to date, remained unanswered.20

Impact of Policies and Practices (regarding relevant SDGs) on Migrants in Malta

The need for policy coherence emerges strongly with regard to migrants residing in Malta. The SDV 2050 mentions asylum seekers and immigrants as one of the groups at risk of poverty; nonetheless poverty-reduction measures do not specifically address this group. Migrant integration is also not addressed in other pertinent documents such as the Malta 2018 VNR report, which only mentions migrants with regard to the setting up of an Integration Unit and to labour market needs. The latter area – being one where migrants face ample discrimination and weak law enforcement21 - lacks policies which aim at curbing illegal employment and discrimination by employers. Meanwhile, the national employment agency Jobsplus inspects workplaces and takes action against abuses related to work; it also provides the opportunity to anonymously report situations of undeclared work through a Freephone number and website.22 Such reporting measures, however, work under the assumption that all TCNs have access to the internet, know English or Maltese, are literate, and are aware of their rights and of the existence of these measures.

Furthermore, policy impact relating to migrant workers is not measured or monitored.23 This lack of monitoring and impact measurement is not only limited to migrants’ participation in the labour market. TCNs’ integration processes are not measured, although the Head of the Intercultural and Anti-Racism Unit24 confirms that this is due to the novelty of services being provided. While research on migrants’ progress regarding integration is planned for the coming years, the Head argues that reviewing the Unit’s operations against SDG targets relating to migration issues is difficult in view of the fact that the Agenda 2030 does not make sufficient reference to migrant integration.

In practice, migrant integration is also far from ideal. Derogatory public discourse by various politicians and the ex-chairman of the Guardian of Future Generations against foreign workers and Muslims in Malta are examples of the lack of such integration. And while a Hate Crime and Speech Unit has been set up, this is targeted at supporting victims of hate speech, rather than prosecuting perpetrators. On a positive note, a Migrant Learners’ Unit provides induction courses to TCN students and other types of support in order to enable them to access and integrate into mainstream schooling.25 Jobsplus, among other initiatives, also launched a project for migrants which offers guidance and job brokerage services to asylum seekers and migrants with a protection status.26 However, this project does not train employers or raise awareness on migrant discrimination (although the project will include a publication targeting employers, highlighting various services and information on current misconceptions.)27 Nonetheless, none of these actions are measured according to SDG targets. Overall, therefore, based on consultations with relevant stakeholders it appears that action plans and policies neither mention SDG targets nor is their implementation reviewed against the Agenda 2030.

Conclusions and recommendations

As the preceding discussion demonstrates, Malta faces a long road ahead in order to achieve policy coherence for sustainable development. While efforts to mainstream policies and achieve coherence are being implemented by such entities as the Sustainable Development Directorate and the Sustainable Development Network, such endeavours are still in their infancy and require the necessary human and financial resources as well as the backing of political will and initiative to be able to do their work.

Relatedly, there is a need to move away from the idea that sustainable development relates only to the environment and related matters, an idea which seems to be rooted in the country’s mentality. This is shown by several entities, ranging from the media – for example, the online media company Newsbook, when reporting on the new SDN and GFG appointments, reports it in the context of unsustainable construction28 – to the government. The SDD, for example, was, since its inception and up until December 2019, part of the then Ministry for the Environment, Sustainable Development and Climate Change29 (the name of the Ministry also demonstrating the leaning of SD towards environment-related matters). While the Directorate has now moved to the Office of the Prime Minister – which is hopefully a move which will enable further policy coherence and mainstreaming of SD in all sectors – such erroneous thinking still affects the implementation of SD today.30 The Sustainable Development Act, for instance, establishes that the SDN has to include an NGO representative from the environment sector, but does not enforce the inclusion of NGO representatives from other sectors such as the social sector.

PCSD faces also other stumbling blocks in Malta, including the lack of impact measurement of policies (and practices) as well as lack of reporting and evaluation on policy and project implementation. The absence of monitoring mechanisms and a clear picture of Malta’s progress towards the SDGs render policy coherence as well as the achievement of SD more challenging. While some initiatives – such as the NAO audit of progress towards SDG 1 – are commendable, such exercises need to be systematic and implemented on a regular basis for all SDGs.

Furthermore, it is to be hoped that Malta’s Sustainable Development Strategy and Action Plan will include concrete impact measurement for the measures it lays out, as well as ensure that they are developed in regular consultation with the relevant stakeholders, including CSOs, for each different aspect of sustainable development. It is important that these vital documents do not simply pay lip service to policy coherence but ensure that there is indeed coherence between policies covering each area.

Finally, as the UN Committee for Development Policy communiqué on VNRs31 recommends, stronger and broader strategies are needed to achieve inclusive development, together with “honest reflection on trade-offs and groups that could be “pushed behind”. This is particularly relevant to Malta, where TCNs, especially asylum-seekers and refugees, are often the subjects of rampant discrimination, injustice and racism. Policy coherence as well as formal evaluation of migrant integration, inclusion and quality of life are of utmost importance not only for the full implementation of the Agenda 2030 but also to ensure the full upholding of rights for those often left behind.


1 Miola, A., Borchardt, S., Neher, F. and Buscaglia, D. (European Commission).2019. Interlinkages and policy coherence for the Sustainable Development Goals implementation. An operational method to identify trade-offs and co-benefits in a systematic way. Available: https://ec.europa.eu/jrc/en/publication/interlinkages-and-policy-coherence-sustainable-development-goals-implementation-operational-method

2 The data collection and analysis on which this executive summary is based was finalised in September 2020 and generally reflects the status quo of the same period. Nonetheless, key developments are noted in footnotes in order to provide as accurate a picture as possible at the time of writing this document in June 2021.

3 InterCap. 2019. First Annual Policy & State-of-the Art Paper for Policy Coherence for Development (PCD). Available: https://developtogether.eu/en/resources/category/4-reports-and-papers

4 Universita’ ta’ Malta (Newspoint). 2020. UM academics to lend expertise on Sustainable Development Network. June, 5. Available: https://www.um.edu.mt/newspoint/news/2020/06/um-academics-sdn?utm_source=update&utm_campaign=update&utm_medium=email&utm_con%E2%80%A6; European Sustainable Development Network. 2020. Single Country Profile: Malta. May, 20. Available: https://www.sd-network.eu/?k=country%20profiles&s=single%20country%20profile&country=Malta

5 This refers to the Budget 2021.

6 SDD Representative. 2020. Interview with author.

7 SDD Representative. 2020. Email Exchange with author.

8 Office of the Prime Minister. 2019. Sustainable Development Annual Report 2018. Provided by George Said, Sustainable Development Directorate.

9 Grech, W. (Social Watch). 2017. Malta. Implementation of the 2030 Agenda: Are “partners” delivering? Available: http://www.socialwatch.org/node/17788

10 Sustainable Development Goals Knowledge Platform. 2018. Malta. Voluntary National Review 2018. Available: https://sustainabledevelopment.un.org/index.php?page=view&type=30022&nr=969&menu=3170

11 Grech, W. (Social Watch). 2017. Malta. Implementation of the 2030 Agenda: Are “partners” delivering? Available: http://www.socialwatch.org/node/17788

12 European Sustainable Development Network. 2020. Single Country Profile: Malta. Available: https://www.esdn.eu/

13 SDD Representative. 2020. Interview with author.

14 This review was published in December 2020. Among other aspects, it notes that the complexity of poverty renders its measurement challenging. The review notes that according to the UN, Malta has achieved the target of alleviating absolute poverty. Nonetheless, national efforts also focus on alleviating relative poverty. The NAO concludes that, while in certain aspects, progress has been registered, there was an increase in the number of persons at risk of poverty. Consultation with NGOs and academics working in the sector raised concerns on the increase in living expenses and standard of living which is not matched by an equivalent increase in income. The review can be found here: https://nao.gov.mt/en/recent-publications.

15 Office of the Prime Minister. 2019. Sustainable Development Annual Report 2018. Provided by George Said, Sustainable Development Directorate.

16 Ministry for Finance and Financial Services. 2020. Malta National Reform Programme. Available: https://mfin.gov.mt/en/Library/Pages/National-Reform-Programme.aspx

17 Kopin. 2018. 1st Annual Paper – State of Affairs on PCD, Malta. Available: https://developtogether.eu/en/resources/category/4-reports-and-papers

18 SDD Representative. 2020. Interview with author.

19 Kopin. 2018. 1st Annual Paper – State of Affairs on PCD, Malta. Available: https://developtogether.eu/en/resources/category/4-reports-and-papers

20 Grech, W. 2020. Email exchange with author.

21 Malta Migrants Association. 2015. Public Consultation: Mind D Gap – Together we can make a difference. National Migrant Integration Strategy 2015-2020. Input Submission. Available: https://meae.gov.mt/en/Public_Consultations/MSDC/Documents/2015%20-%20Integration/11.Malta%20Migrants%20Association.pdf

22 Jobsplus. 2020. Report Abuse. Available: https://jobsplus.gov.mt/forms

23 Cini, N. 2020. Email exchange with author.

24 Tortell, A. 2020. Interview with author.

25 Farrugia Buhagiar, J. 2020. Interview with author.

27 Cini, N. 2020. Email exchange with author.

28 Newsbook. 2020. New board appointments to safeguard sustainable development. May, 31. Available: https://newsbook.com.mt/en/new-board-appointments-to-safeguard-sustainable-development

29 Office of the Prime Minister. 2019. Sustainable Development Annual Report 2018. Provided by George Said, Sustainable Development Directorate.

30 In November 2020, the SDD was once again assigned a new ministry, the Ministry for Energy, Enterprise and Sustainable Development.

31 United Nations Committee for Development Policy. 2020. Communique on further improving the voluntary national review process. Available: https://www.un.org/development/desa/dpad/voluntary-national-reviews.html