Kind of want to re-iterate the points made by @pelleaardema and myself above - would be great if the proposers of this change would engage with those arguments.
My strong preference would be to:
- consult with accounting organisations and use a widely-recognised definition from international accounting standards;
- do not mix up IATI's (evolving) traceability standards with the definitions of different types of financial flows. How to implement traceability should be included in guidance, rather than trying to crowbar it into these definitions.
Examples of problems with the proposed definition:
- budget support would be classified as expenditure (because recipient governments are not expected to report to IATI), when it clearly is not under a logical/intuitive understanding of "disbursement" and "expenditure".
- funds transferred to a private company may be classed as disbursement or expenditure depending on whether the provider org had traceability requirements that covered private companies, rather than depending on the nature of the flows.
As currently proposed, these changes would have quite negative effects on the usefulness of this data at country level, where the understanding of disbursements and expenditures is generally much closer to the existing definition than the proposed definition. Given the wide concern about increasing data use, we should be trying to move closer to those country-level definitions, not further away.