Assessment of the implementation of development strategies for state-owned organizations: a new authority of the Federal Treasury

Lapina Marina Afanas'evna ORCID: 0000-0003-0320-161X Doctor of Law, PhD in Technical Science Professor; Department of International and Public Law; Financial University under the Government of the Russian Federation Chief Researcher; Financial University under the Government of the Russian Federation 38 Shcherbakovskaya St., Moscow, 105187, Russia LapinaMarina@inbox.ru Other publications by this author

Kulazhina Anastasia Olegovna ORCID: 0009-0000-5307-2073 Senior Controller-Auditor; Office for Control and Evaluation of Strategic Organizations with State Participation; Federal Treasury Junior Researcher; Institute for Research on Socio-Economic Transformations and Financial Policy; Financial University under the Government of the Russian Federation 49/2 Leningradsky ave., Khoroshevsky district, Moscow, 125057, Russia aokulazhina@fa.ru

Introduction

The current stage in the development of the Russian public administration system is characterized by the formation of a strategic planning vertical that encompasses not only public authorities, but also the largest economic entities with state participation. The point of intersection of this process with the evolution of state financial control was the Decree of the Government of the Russian Federation dated October 23, 2025 No. 1646 "On measures to improve the quality of evaluation of the performance of Individual Joint-Stock Companies owned by the Russian Federation and FSUE" (in effect. ed.), which assigned the Federal Treasury the authority to annually evaluate the implementation of strategies for the development of strategic organizations with state participation. Earlier, by Decree of the Government of the Russian Federation No. 2199-r dated August 15, 2024 (as amended), methodological recommendations for the development of these strategies were approved, and paragraph 38 of these recommendations stipulates that the implementation of strategies is subject to annual assessment by the federal executive authority authorized by the Government of the Russian Federation.

It is important to emphasize that the new authority represents a natural stage in the evolution of the functions of the Federal Treasury. In accordance with the Regulations on the Federal Treasury, approved by Decree of the Government of the Russian Federation No. 703 dated December 1, 2004 (as amended), the Treasury performs law enforcement functions to ensure the execution of the federal budget, cash services for the execution of budgets of the budgetary system of the Russian Federation, preliminary control over operations with federal budget funds, as well as control and supervision in the financial and budgetary sphere. The Treasury's list of powers has been consistently expanded: from 2016 - treasury support, from 2021 - budget (later Treasury) monitoring in the treasury payment system (Articles 242.13-1 of the BC RF), from 2023 - control (analysis) of financial and business operations of large corporations (Resolution No. 1543), from 2024. - also the functions of a currency control agent ^{[6, p. 24-27; 8, p. 33]}. Thus, giving the Treasury the authority to evaluate strategies is a logical continuation of its transformation from cash management to systematic analytical support of state financial control.

The emergence of the new authority has posed a number of challenges for financial and legal science: what is the legal nature of this authority, why the choice was made in favor of the Treasury rather than the Accounts Chamber of the Russian Federation, what are the legal consequences of the Treasury's conclusion, and whether it has coercive powers. This article is an attempt to answer these questions.

The main part

In accordance with the Decree of the Government of the Russian Federation No. 1646 and the Decree of the Government of the Russian Federation No. 2199-r, two categories of organizations are subject to evaluation. Firstly, these are joint-stock companies whose shares are federally owned. As noted by R.A. Toriya and N.A. Hasanov, joint-stock companies with state participation have a specific legal status that distinguishes them from other legal entities, which has traditionally made it difficult to exercise financial and budgetary control ^{[19, pp. 49-50]}. Secondly, these are federal state unitary enterprises (FSUE) included in the list approved by Decree of the Government of the Russian Federation dated June 20, 2011 No. 1060-r (in effect. ed.) (in respect of which a special decision-making procedure is established). For the purposes of this study, it is also necessary to briefly describe the organizational and legal forms of legal entities with which the Treasury will interact under the new authority. In Russian legislation, there are several organizational and legal forms of legal entities with state participation, each of which has significant differences ^{[11, pp. 27-28]}. State unitary enterprises are commercial organizations that do not own the founder's property; this property is assigned to them by the right of economic management or operational management. The founder may be the Russian Federation, a constituent entity of the Russian Federation, or a municipal entity. State corporations, on the contrary, are non-profit organizations without membership, established by the Russian Federation on the basis of a property contribution and federal law. They are created to perform social, managerial, or other publicly significant functions. The property is owned by them, they can establish subsidiaries (examples: Rosatom State Corporation, Roscosmos, VEB.RF). State-owned companies also belong to non-profit organizations, but their highest governing body is necessarily the board of directors (or supervisory board), which distinguishes them from state corporations ^{[11, pp. 28-31]}. The discrepancy draws attention to itself: some organizations in their official names indicate a different organizational and legal form than the one in which they were created. An example is the FSUE, named as the "State Corporation for the Organization of Air Traffic in the Russian Federation," which is at odds with the requirements of the law. FSUE State Corporation for the Organization of Air Traffic in the Russian Federation is one of the organizations for which the Treasury carries out an assessment in accordance with Resolution No. 1646 ^{[11, pp. 32-33]}. The list of organizations whose strategies are subject to an annual assessment by the Treasury is determined by the Government of the Russian Federation. According to the appendix to the guidelines (Order No. 2199-r), the special list of organizations includes 49 joint-stock companies (including PJSC Aeroflot, PJSC Transneft, VTB Bank, JSC Russian Railways, JSC Russian Post, etc.) and 9 federal state unitary enterprises (including FSUE "Russian Television and Radio Broadcasting Network", FSUE "Space Communications", FSUE "Rosmorport", etc.). As noted by I.I. Smotritskaya and N.D. Frolova, companies with state participation in the modern economy are considered as the most important tool for implementing state economic policy, and their share in the economy of the leading countries of the world is steadily growing ^{[18, pp. 594-595]}.

Doubts have been expressed in the scientific literature about the expediency of giving the Treasury the authority to evaluate strategies. Thus, some researchers believe that this function should belong exclusively to the Accounts Chamber of the Russian Federation as an external state audit body specializing in performance assessment. Other authors, on the contrary, note that the Accounting Chamber is focused on thematic inspections and does not have the resources for systematic annual monitoring of the activities of a wide range of organizations ^{[1, pp. 154-155]}. In addition, there was concern in the corporate legal literature that giving the Treasury evaluative powers could lead to a substitution of corporate governance bodies and a weakening of the role of the board of directors. As noted by I.Y. Belyaeva and H.P. Kharchilava, the specifics of the activities of supervisory authorities in Russian public joint-stock companies with state participation require special attention to the differentiation of competencies ^{[2, pp. 74-75]}. While disagreeing with this thesis, we note that the Treasury's opinion is advisory in nature and does not negate the Board of directors' independence in making strategic decisions, but only introduces a mandatory procedural review stage. In discussing the nature of the new authority, it seems important to refer to the position of E.A. Isaev, who consistently justifies the transition from a repressive to a partner model of control, in which assessment becomes a tool to help the object of control achieve planned results ^{[8, p. 33]}. The present study develops this thesis in relation to strategic planning.

Article 267.1 of the Tax Code of the Russian Federation assigns to the Treasury the preliminary control over transactions with federal budget funds (including verification of compliance with government contracts), as well as control over the use of budgetary funds. Preliminary control is carried out at the stage of drafting and reviewing draft budgets, verifying the validity of budget estimates. The Accounts Chamber of the Russian Federation, in accordance with Federal Law No. 41-FZ of April 5, 2013 "On the Accounts Chamber of the Russian Federation" (as amended), carries out subsequent control (efficiency audit, compliance audit). Thus, preliminary control and control over the use of funds is the prerogative of the Treasury, and subsequent control is the responsibility of the Accounting Chamber. The Treasury's list of powers has been consistently expanded: since 2016, the Treasury of Russia has been exercising control and supervision functions in the financial and budgetary sphere, including monitoring the reliability of reports on the results of the provision and use of budgetary funds ^{[8, p. 33]}. This period was marked by the introduction of a treasury support mechanism for earmarked funds, which, as indicated in the explanatory note to Resolution No. 1646, made it possible to ensure full traceability of the movement of budget funds along the chain of customer - contractor - subcontractors. Starting in 2021, the Budget Code of the Russian Federation introduced Article 242.13-1 "Treasury Monitoring" (in its original version, "Budget monitoring in the Treasury payment system"). Treasury monitoring is a mechanism by which the Treasury identifies and prevents financial irregularities of participants in the treasury payment system at an early stage. Within the framework of treasury monitoring, response measures such as refusal to open a personal account, suspension of operations, and warning (informing) are applied, and it is carried out on the basis of the Rules for Treasury Monitoring and Response Measures approved by Decree of the Government of the Russian Federation No. 2483 dated December 25, 2021 (as amended). This experience of "analytical control with procedural consequences" became the methodological basis for the new authority to evaluate strategies. Since 2023, on the basis of the Decree of the Government of the Russian Federation dated September 21, 2023 No. 1543 (as amended), the Treasury has been monitoring (analyzing) the financial and business operations of state corporations (companies), publicly owned companies and business entities with a participation of the Russian Federation of more than 50% ^[12]. As part of this work, as E.A. Isaev points out, methods of auditing investment and debt policy, property complex management and budget planning systems have been developed ^{[7, p. 44]}. In 2023-2024. The Treasury successfully conducted a "pilot" assessment of the implementation of a long-term development program and achievement of key performance indicators of the Joint-Stock Company State Transport Leasing Company (JSC GTLK), as well as an assessment of the activities of the joint-stock company Russian Post and Joint-Stock Company United Shipbuilding Corporation (JSC USC) and their subsidiaries and affiliates societies. In 2024, as a result of the implementation of the roadmap measures, Russian Post JSC alone received an additional financial effect in the amount of more than 6 billion rubles. ^{[7, p. 42]}. Thus, the new authority to evaluate strategies fits seamlessly into the evolutionary range of Treasury functions.: cash services → treasury support → Treasury monitoring → control (analysis) of operations → evaluation of strategies.

When granting new assessment powers, the question arises: why the Treasury, and not the Accounting Chamber of the Russian Federation? The analysis allows us to identify three key factors. The first factor is belonging to the system of executive power. The Accounting Chamber, being the highest body of external state audit (control) and acting as an independent control body, carries out thematic efficiency checks and is distanced from operational management. The Treasury, on the contrary, is a federal executive authority subordinate to the Ministry of Finance of the Russian Federation, and carries out preliminary control, as well as control (analysis) of financial and business transactions. The annual assessment of the implementation of strategies is considered by the state as an element of the regular management cycle, which makes the Treasury a more suitable entity. The second factor is the technological infrastructure. Evaluating strategies requires processing large amounts of reports and verifying financial and economic models. The Federal Treasury is the operator of key state information systems in the financial and budgetary sphere: the state integrated information system for public finance management "Electronic Budget" (GIIS "Electronic Budget"), the Unified Information System in the field of Procurement (UIS), the subsystem of information and analytical support, which allows for full traceability of the movement of funds through the chain of subcontractors. As E.A. Isaev points out, the transition to a partner control model based on digitalization is technically feasible only if such an infrastructure is available ^{[8, p. 33]}. Neither the Accounting Chamber, nor the Federal Property Management Agency, nor the line ministries have a comparable platform for systematic annual monitoring. The third factor is accumulated competence. Since 2023, the Treasury, based on Resolution No. 1543, has been analyzing the financial and business operations of organizations with a Russian Federation participation of more than 50% ^[12]. In addition, in 2023-2024. The Treasury successfully conducted a "pilot" assessment of the implementation of the long-term development program and achievement of key performance indicators of JSC GTLK, as well as an assessment of the activities of JSC Russian Post, JSC USC and their subsidiaries and affiliates. This experience has become a practical validation of the new authority.

The transfer of valuation powers to the Treasury is a global trend. In France, the efficiency of public sector enterprises is assessed not by the Court of Auditors (Cour des comptes), but by the Directorate General of the Treasury (Direction Générale du Trésor), which is part of the Ministry of Economy and Finance. It is the Treasury that conducts an annual analysis of the implementation of strategic plans of state-owned companies (EDF, SNCF, RATP), and the Accounting Chamber is involved only for thematic audits ^{[4, p. 45-47]}. In the People's Republic of China, control over the implementation of strategic plans by State-owned enterprises is carried out primarily by the Ministry of Finance and the State Committee for Control and Management of State Property (SASAC). The Supreme Financial Control Body conducts only random checks. Annual monitoring is delegated to the financial department in order to maintain managerial flexibility ^{[14, p. 112-114]}. In Brazil, the National Treasury (Tesouro Nacional) monitors the compliance of financial and economic indicators of state-owned companies with approved strategic plans. The Court of Auditors (Tribunal de Contas da União) focuses on the audit of budget funds, rather than on the effectiveness of asset management ^{[20, p. 78-80]}. In Italy, state-owned companies are controlled by the Department of the Treasury ^{[16, p. 1-24]}, which is part of the Italian Ministry of Economy and Finance (Ministero dell'Economia e delle Finanze). At the same time, in 2023, the creation of a separate structural unit responsible for the management of state-owned companies was discussed in the Italian Treasury, but the initiative was not implemented ^[17]. Describing the Polish experience of external financial control, Dobrovolsky, Barren Martinez J., Sluga V. and co-authors make an important clarification - formal acceptance by the audited organization of all recommendations of the supreme financial control body does not mean real improvements. During several stages of the audit, the Polish Financial Ombudsman declared acceptance of all recommendations, but violations were recorded repeatedly ^{[5, p. 688]}. This conclusion is of direct importance for the Russian model. The criterion for the effectiveness of the new Treasury authority can be an assessment of actual changes in the financial and economic parameters of a strategic organization's activities, verified through an analysis of its financial model in dynamics. Foreign studies confirm that an increase in the share of state participation in capital in the absence of an independent evaluation mechanism correlates with a deterioration in the financial performance of organizations ^{[9, p. 5-7]}. The consolidation of the role of an independent strategy evaluator for the Russian Treasury partially compensates for the lack of external corporate control. The concept of public value, developed by M. H. Moore and applied by K. Corderi and D. Hay ^{[13, p. 26]} to the activities of the supreme financial control body, proceeds from the fact that the public value of the work of the control body is determined not by the number of violations detected, but by the real contribution to improving the activities of controlled entities ^{[3, p. 128-142]}. Thus, the Russian model fits into global practice: when switching to regular monitoring, evaluation powers are transferred to the Treasury as a body embedded in the executive vertical and possessing the necessary infrastructure.

An analysis of Resolution No. 1646 allows us to assert that this authority is not classical state financial control (Article 267.1 of the Tax Code of the Russian Federation) and is not limited to efficiency audit in the understanding of the budget legislation of the Russian Federation (Article 157 of the Tax Code of the Russian Federation) and the Federal Law "On the Accounts Chamber of the Russian Federation" (No. 41-FZ), which refers to The main tasks of the Accounting Chamber are to "determine effectiveness... the procedure for the formation, management and disposal of federal and other resources", "audit of the feasibility and effectiveness of achieving strategic goals", as well as "assessment of the effectiveness of providing tax and other benefits and advantages". At the same time, the term "efficiency audit" as a type of control is fixed in the Budget Code of the Russian Federation, and not in No. 41-FZ. The Treasury's conclusion does not give it the right to adjust the strategy's targets, suspend its implementation, apply administrative responsibility measures to management, or issue mandatory prescriptions. In this sense, the new authority organically continues the model that has already been tested by the Treasury in the framework of treasury monitoring (Articles 242.13-1 BC RF). In Treasury monitoring, the Treasury also does not apply direct coercive measures, but uses response measures such as warning (informing), refusal to open a personal account, or suspension of operations. At the same time, the Treasury acts only within the limits of its competence and the Rules for Treasury Monitoring and Response Measures (Decree of the Government of the Russian Federation dated December 25, 2021 No. 2483). This model of "analytical control with procedural consequences" became the prototype for the new authority. The legal form of exercising the authority is a conclusion. Unlike the audit report or the order of the Accounting Chamber, the Treasury's conclusion is not of an authoritative and administrative nature. However, it entails mandatory procedural consequences: the conclusion is sent to the organization, its board of directors, the Federal Property Management Agency and the Government of the Russian Federation. The Board of Directors is obliged to review the conclusion and, if it does not agree with the recommendations, the Board of Directors is obliged to state its position in a reasoned manner. Information on the opinion and position of the Board of Directors is subject to disclosure in the annual report. Consequently, these consequences are not coercive measures in the public law sense. They create a legal guarantee of taking into account the position of the state as a public owner. As I.Y. Belyaeva correctly notes, the state in the corporate governance system occupies a dual position — that of a regulator and an owner, which generates a conflict of interests in self-assessment ^{[1, p. 154]}. The Treasury, being independent of the shareholder, removes this conflict.

The essence of the role of the Federal Treasury under the new authority can be revealed through three elements. Firstly, systematic analytical monitoring: unlike one-time audits of the Accounts Chamber, the Treasury carries out an annual assessment throughout the entire period of the strategy's implementation (at least 5 years). Secondly, independence from the shareholder (government agency), which ensures the objectivity of the assessment. Thirdly, the launch of corporate procedures: the conclusion does not replace the decision of the board of Directors, but obliges it to consider adjusting the strategy. G.V. Petrova and V.I. Stupakov, using the example of Russian Railways, show that a comprehensive analysis of the activities of organizations, taking into account their financial and economic condition and the results of development programs, allows the owner to make the most balanced management decisions ^{[15, p. 51]}. As previously explained, in accordance with the INTOSAI Moscow Declaration (2019), the supreme financial control bodies are called upon to act as strategic assistants in the public administration system, assess the achievement of national goals and systemic risk management ^{[10, pp. 64-65]}. However, the new authority of the Treasury, unlike the strategic audit of the Accounts Chamber, is focused on the microlevel - the assessment of the strategies of specific organizations. These two institutions complement each other: the Accounting Chamber evaluates strategic management "from above" (macro-level, national projects, government programs), the Treasury - "from below" (the effectiveness of the implementation of strategies by individual organizations). Such a distinction corresponds to the principle of differentiation of competencies of control bodies.

It is important to emphasize that the new authority is not isolated. Since 2024, the Treasury has been endowed with the functions of an agent of currency control, which confirms the systematic nature of the expansion of its competence. Together with treasury support, treasury monitoring (Article 242.13-1 of the BC RF) and control (analysis) under Government Decree No. 1543, the new authority completes the formation of an integrated system of state financial control, covering all stages: from planning and bringing funds to evaluating strategic results.

Since the new authority was introduced only at the end of 2025 and is currently regulated exclusively by by-laws (Resolution No. 1646, Order No. 2199-r), its legal formalization needs further development. Based on the analysis of the legal nature of this authority, which, being objectively related to the financial and economic activities of organizations (participants in government programs and recipients of budget funds), nevertheless is not classical state financial control, it seems advisable to implement three areas of improvement of regulatory regulation.

First, it is necessary to consolidate the Treasury's authority to evaluate strategies directly in the Budget Code of the Russian Federation, but not in chapter 26 "Fundamentals of State (Municipal) Financial Control", but in a separate article or chapter of Section IX devoted to Treasury's evaluation activities. This will make it possible to clearly distinguish the evaluation of strategies with preliminary and subsequent control, as well as with performance audits, without creating terminological confusion.

Secondly, amendments should be made to Federal Law No. 172-FZ of June 28, 2014 "On Strategic Planning in the Russian Federation", supplementing it with provisions stating that the assessment of the implementation of strategies of organizations with state participation is a mandatory stage of the strategic cycle. This will give the assessment the status of an element of public administration, rather than a one-time control procedure.

Thirdly, by analogy with the classifier of signs of financial violations of participants in treasury support (approved by Order of the Ministry of Finance dated June 23, 2025 No. 76n), it seems reasonable to develop a classifier of indicators of risks of non-implementation of the development strategy. Such a classifier could include, for example, deviation of the actual values of key performance indicators from the planned ones by more than a set percentage, non-compliance with interim deadlines for the implementation of measures, identification of unreliability of financial and economic model data, lack of positive dynamics of net assets. Formalization of the assessment process based on such a classifier will increase its transparency, ensure uniformity of approaches and reduce the influence of the subjective factor in the preparation of Treasury conclusions.

Conclusion

The assignment to the Federal Treasury of the authority for the annual assessment of the implementation of strategies is institutionally justified. The choice in favor of the Treasury is due to its affiliation to the system of executive power, the availability of technological infrastructure (GIIS "Electronic Budget", EIS, subsystem of full traceability) and accumulated competence in the analysis of financial and economic activities of large corporations, confirmed by the practice of treasury support, treasury monitoring and "pilot" projects (JSC "GTLK", JSC "Russian Post", JSC "USC").

The conducted research allows us to substantiate that the new authority, being objectively related to the financial and economic activities of organizations involved in the implementation of state programs, does not belong to the control powers within the framework of state financial control (Article 267.1 of the Code of Criminal Procedure of the Russian Federation) and is not a type of efficiency audit (Article 157 of the Code of Criminal Procedure of the Russian Federation, the Law on the Accounting Chamber). It is an independent analytical (evaluative) authority exercised by the Treasury within the framework of its functions, and differs from control and supervisory measures in the absence of direct coercion, but in the presence of mandatory procedural consequences (mandatory consideration by the board of Directors, reasoned justification in case of disagreement).

Comparative legal analysis shows that the transfer of appraisal powers to the Treasury, rather than to the supreme financial control authority, is a global trend (China, Brazil, France). The Russian model fits into global practice and is thus not unique.

There are no direct measures of state coercion for the new authority. However, the Treasury's conclusion entails mandatory procedural consequences.: consideration by the Board of Directors and reasoned justification in case of disagreement.

The current legal regulation needs to be developed: in order to give a new authority a consistent legal status, it is necessary: 1) fix it in the Budget Code of the Russian Federation (in the new chapter of Section IX, outside the chapter on financial control); 2) include an assessment of the implementation of strategies in the Federal Law "On Strategic Planning in the Russian Federation" as an obligatory element of the strategic cycle; 3) develop a classifier of indicators of risks of non-implementation of the development strategy by analogy with the classifier of signs of financial violations of treasury support participants. The implementation of these proposals will eliminate terminological confusion, clearly distinguish evaluation from financial control, and ensure uniformity of evaluation procedures.

The article is published in the version approved by the reviewers (after receiving a positive review recommending the manuscript for publication) with corrections made by the author (after receiving the editor’s comments, if any).
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