Steps to produce a shadow report

This section outlines the main steps in developing a shadow report on SDG 16.10 by Civil Society Organizations. It is important to note that civil society reporting is not an official mechanism like the government-led Voluntary National Reviews. Therefore, the approach and steps taken to produce a shadow report might differ per context. Furthermore, it is important for CSOs to take into account the national context and political climate, to ensure this reporting can be done in a secure way and that a report has the potential to lead to action by the government.

1.1 Preparation

The very first step is to find out whether your government has a national action plan for SDG implementation and is submitting a Voluntary National Review. On this website of the United Nations you can find all past and promised VNR reviews per country. If your country is submitting a VNR review, find out who is the national focal point for the review and which government entity is responsible for the coordination of the VNR. Consult them to understand whether and how civil society can participate in preparing the VNR, and urge your government to include a review of SDG 16.10 in its VNR.

Based on this, you can define the objective of the report, as well as who the report is aimed at. The goal of your shadow report might differ depending on the context. When civil society has not been able to participate meaningfully in the VNR process of the government, the goal could be to provide alternative or complementary data and insights into the progress of the SDGs in the country. The shadow report might also be used to call specific attention to the importance of SDG 16.10, if this goal has not been included in the VNR or received little attention in the overall SDG monitoring process. Finally, the shadow report can also be used to advocate for a more inclusive VNR process.

Examples of objectives of shadow reports

  • Providing alternative or complementary data to government reporting
  • Calling specific attention to the importance of SDG 16.10
  • Advocating for a more inclusive VNR process

Depending on this objective, the shadow report can be targeted to different stakeholders, such as specific government departments or ministries, the United Nations or international partners. Setting a clear goal and scope for the shadow report from the beginning of the process, ensures an efficient process and a clear and focused report.

Finally, in the preparation of the shadow reporting, it is important to plan the process well in advance and secure the necessary financial and human resources for the data collection, report writing as well as stakeholder engagement and advocacy. Especially if you work together with different stakeholders, it is important to build in enough time for consultations and revision of the report. Ideally, you should allocate at least six months for the entire process.

1.2 Stakeholder processes and management

It is important to involve different stakeholders from the start of the process, to ensure an inclusive process and achieve better results. It is therefore recommended to do a stakeholder mapping1 at the beginning of the process to identify who could play a role in the development of the shadow report, and how to engage with them. Think about the following stakeholders:

  • Government entities (both national and local level)
  • Civil Society Coalitions
  • International organizations
  • Media
  • Diplomatic community

The following sections look at the different stakeholders and how you could engage with them in the process of writing a shadow report.


First of all, it is important to -where possible- engage with the official Voluntary National Review process of the government. As mentioned before, it differs per country to what extent the government includes civil society organizations in the drafting of the VNR and monitoring SDG 16 in general.

During the stakeholder mapping, map the different relevant state actors. This could include different national government departments, as well as local and provincial government entities. The relevant state governments will differ per context, but could include:

  • National statistics agency
  • Ministries responsible for human rights, access to information, media and freedom of expression
  • Judicial entities
  • SDG committees (also on local and provincial level)

When there are official consultations for the VNR, take the opportunity to participate in them. You can also ask your government for data and information on the progress of the implementation of the SDGs for your shadow report. If no official consultations are planned, advocate for a formal mechanism or platforms for the active contribution of civil society to the VNR. Alternatively, you could hold independent consultations with civil society.

If there are possibilities to provide feedback on a draft version of the VNR report, you can use this opportunity to review the report with regards to SDG 16.10. You could also ask the government for information and data for your shadow report and share your shadow report with the government before publishing it to receive input. It is important to have a constructive approach towards government engagement by providing concrete recommendations, and avoiding focusing only on the shortcomings of governments in implementing SDG 16.10. In this way, you build a positive working relationship towards the implementation of the SDGs, and government actors will be more likely to accept the findings and recommendations of the shadow report.

Finally, you could encourage your government to include civil society stakeholders in their delegation to the HLPF, since including civil society in the process of drafting the VNR as well as during the presentation at the HLPF is part of the UN guidelines on the VNR process2. Alternatively, it’s possible to (co)organize a side event at the HLPF on your country’s implementation of SDG 16.10.

Best practice – constructive approach to government engagement

The African Freedom of Information Centre has a lot of experience in producing shadow reports for the VNR, as well as the Universal Periodic Review and the African Commission of Human and People’s Rights. In this, they have observed the importance of consulting the government in the process and having a constructive approach.

In the UPR and SDGs, how issues are presented matters

Gilbert Sendugwa, executive director of AFIC.

Furthermore, they noticed that consulting with the government builds a relationship and strengthens the findings.

“Sometimes the government can provide you with information that is not publicly available. […] The process of verification already creates a relationship between civil society and the public entity. As a result, when you come up with recommendations after those engagements, they readily accept them, because they feel they have been part of the process from the beginning.”

Susan Juliet Agwang, Legal and Research Officer of AFIC

Finally, the organisation noticed that in-person meetings often are most effective and recommends to establish contact with key people within relevant institutions, so that you can reach out individually during the different moments of engagement.

If there are little opportunities to participate in and contribute to the official VNR process, the shadow report and the advocacy strategy around it will be even more important in order to share the perspective of civil society on the progress of SDG 16.10 implementation. Furthermore, you could engage with national or regional UN offices for updates on the VNR process and the implementation of the SDGs in your country, as well as with civil society organizations or international partners.

Finally, engagement with the government does not end at the publication of the VNR and shadow report. The conclusions and recommendations of the VNR can be used to advocate with your government for the advancement of SDG implementation.

Different moments of engaging with the government

1. Preparation

Understanding the VNR process and identifying avenues for government consultation

2. Data Collection

Requesting information and consulting government actors

3. Writing the report

Sharing first draft of report, asking for input and feedback from government actors, participating in national VNR consultations

4. Publishing and publicising the report

Actively reaching out to (international) civil society organisations and diplomatic missions and sharing the report and its findings

5. High Level Political Forum

Ensuring inclusion of issues into contribution of government; organising side-event

6. Post-HLPF

Advocating for follow-up on recommendations; making action plans

CSO coalitions and collaboration

Setting up CSO coalitions and collaborating with other CSOs can help to collect more complete data, bring in different expertises and perspectives and make a stronger case by presenting the analysis and recommendations as a group.

In some countries, there are already CSO coalitions of platforms on SDG monitoring. It could be useful to be a part of this, in order to raise awareness on the importance and specific issues of SDG 16.10. If this is not the case, mobilize relevant civil society organizations to engage in the VNR process. These could include organizations working on human rights, transparency and accountability.

It is also important to build the capacity of civil society, with regards to resources as well as knowledge and understanding of the SDG agenda and VNR process. Organizations can complement each other with time and resources as well as by sharing information and networks.

Collaboration with civil society organization can take many different forms, including:

  • Setting up a network of organizations to collect and verify data.
  • Combining the expertise and insights of different organizations representing different groups. This ensures an inclusive view on the progress of SDG 16.10 and gives more leverage to the report.
  • Using the different networks of different organizations to connect to the right government actors and other relevant stakeholders.
  • Make a regional report with CSOs reporting on SDG 16.10 of different countries to highlight regional trends3.
  • Jointly drafting an advocacy strategy to raise awareness on SDG 16, encourage an inclusive VNR process and follow-up on the commitments and recommendations made
  • Share the draft report with relevant organizations who can review it and sign it.
  • Learn from the experience of other civil society organizations in developing and disseminating a shadow report, exchange methodologies and lessons learned.
  • In broader SDG coalitions, raise awareness for the specific issue of SDG 16.10 and its importance.

Presenting a shadow report that was jointly developed by multiple civil society organizations provides more leverage and makes it more likely that recommendations will be accepted. When setting up CSO coalitions, it is important to set a shared goal for the process and make a clear work plan and task division, as well as a timeline. Furthermore, it is essential to have a shared understanding and agreement on the methodology and indicators used.

International partners

Working together with international partners and donors can help you advocate an international level the findings of your shadow report and highlight the importance of the report, including SDG 16.10 and the inclusiveness of the VNR process of your government. Especially when reporting within a country is too risky, an alternative could be to use regional or international forums to reflect on the implementation of SDG 16.10 in your country.

International partners and donors could also help secure funding and resources for developing a shadow report and setting up coalitions. International organizations and coalitions can contribute to raising awareness of the findings of your report on an international level, and help provide access to UN mechanisms, for example side-events of the HLPF. Finally, it could be useful to connect to civil society organizations from around the world to learn from their experience reporting on SDG 16.10 and exchange best practices and methodologies.

Best practice – Bringing together findings on SDG 16.10 from different countries

In 2021, Free Press Unlimited, with the support of UNESCO’s International Programme
for the Development of Communication, published a synthesis report on the progress on Sustainable Development Goal 16.10.

This report summarized the findings of 5 civil society reports on the status of safety of journalists and access to information in different countries. The report also reflected on the inclusiveness of the VNR processes and whether SDG 16.10 was included in the reports by Member States.

The monitoring organisations expressed concern over the lack of constructive engagement from their governments to ensure that their data are taken seriously. The reports are a call to action to improve the safety of journalists and access to information in their respective countries and for constructive dialogues with Civil Society to jointly achieve this.

The findings of this report were also used to call attention to these issues during a side event of the 2021 High-level Political Forum on Sustainable Development.


The media sector is an important stakeholder in producing a shadow report on SDG 16.10. Media outlets, local press clubs and journalists associations can provide you with information and contribute to data collection and data verification. Furthermore, it is important to engage with them as part of your advocacy strategy, since they can help raise awareness for the issues raised in the shadow report and hold governments accountable to their commitments.

Diplomatic community

The diplomatic community in your country could be an interesting partner in the shadow reporting progress. It is useful to identify which foreign missions in your country are actively working on and interested in SDG 16.10, as well as which ones are part of relevant coalitions and groups on an international level. For example, Groups of Friends on the Safety of Journalists have been created in New York, Geneva, Paris and Vienna since 2016 with the purpose of improving multilateral cooperation to prevent violence, protect journalists in danger, prosecute perpetrators and ensure a safe environment for media workers.

Embassies in the country could help provide information, amplify the report, and promote the findings at the international level, for example at the United Nations. According to Owais Ali Aslam, Secretary General of the Pakistan Press Foundation, “embassies can also make it part of the discussion they have on a regular basis with the state. […] It makes a difference”.

1.3 Data collection

In order to monitor the progress made on SDG 16.10, it is important to collect credible data to include in the shadow report. This section will look at both indicators of SDG 16.10 and how to measure them.

Official data on the progress of the SDGs of a country is generally produced by national statistical offices and is often collected through formal government processes, such as administrative records, expert assessments, and surveys. Ideally, this data should be publicly available. Therefore, depending on the country-specific context, it might be possible to reach out to the government or UN offices that could provide any data or evidence of implementation efforts. Whether or not this data is available is already an indication of progress on SDG 16.10 with regards to access to information.

In general, the methods used for data collection depend on the time and resources available and could include:

  • Reviewing existing data and reports
  • Consultations with other civil society organizations, media organizations and other relevant stakeholders
  • Consultations with local authorities
  • Setting up database with cases of violence against journalists
  • Monitoring media reports about violations and following up on them
  • Surveys
  • Interviews

In collecting the data, ensure that you receive input from a variety of stakeholders, for example from minority and under-represented groups as well as people outside of urban centres. It’s possible to combine quantitative data, such as the number of cases of violence against journalists, with qualitative data, such as interviews with experts and case studies.

The two indicators for SDG 16.10

  • 16.10.1 – Number of verified cases of killing, kidnapping, enforced disappearance, arbitrary detention and torture of journalists, associated media personnel, trade unionists and human rights advocates in the previous 12 months
  • 16.10.2 – Number of countries that adopt and implement constitutional, statutory and/or policy guarantees for public access to information

The UN Statistics Division published documentation about the SDG indicators that explains the definition and measurement of each indicator as well as the responsible UN entities for measurement4. The next sections give some indications on how to operationalize measurement of each indicator. Depending on the context, you could also decide to include additional indicators56.

In general, it is important to have a clear understanding and agreement on the indicators you will measure and the methodology to do this. Furthermore, the data should be verified to ensure a credible and accurate report.

Indicator 16.10.1

16.10.1 – Number of verified cases of killing, kidnapping, enforced disappearance, arbitrary detention and torture of journalists, associated media personnel, trade unionists and human rights advocates in the previous 12 months

Indicator 16.10.1 implies the collection of data with regards to individual cases of violations against journalists, associated media personnel, trade unionists, and human rights advocates. In general, there is a risk of under-reporting of these cases, due to various factors, including fear of reporting by the victim, changes and biases in reporting practices, processes errors, omissions, and manipulations.

A defining factor for this indicator is the motivational or causal factor: the violation took place because of the work of the victim. This means that it is important to thoroughly verify each case to understand the motivation.

Ideally, this indicator is monitored throughout the year, building a database of verified cases of violence against journalists. It is important to register at least the following information:

  • Gender of victim
  • Age group of victim
  • Type of violation
  • Perpetrator status (e.g. state actor or non-state actor)
  • Geographic location of violation

The indicator as measured by the UN System includes the following categories of violations7:

  • Killing
  • Enforced disappearance
  • Torture
  • Arbitrary detention
  • Kidnapping
  • Other harmful acts

The last category of ‘other harmful acts’ was added to include a wider range of violations that restrict press freedom, access to information and freedom of expression, as well as the safety and security of journalists. Many CSOs therefore monitor a wider range of violations, such as8:

  • Stigmatizing discourse
  • Restrictions in access to information
  • Criminal and civil legal processes against journalists and media outlets
  • Raids
  • Abusive use of state power
  • Legal frameworks and government directives
  • Digital attacks and internet restrictions

Based on the context of your country, it might be useful to include other indicators or types of violations in the data collection.

Best Practice – Regional data comparison in Latin America

Voces del Sur is an initiative of the Pan American Development Foundation to promote freedom of expression in Latin America. The organization has brought together organisations from different countries in the region that monitor press freedom violations, with the aim to build common indicators and definitions, in order to be able to compare the data across countries.

The most important element in this is having a shared understanding of the indicators, for example by making a list of every violation that would fall under a specific category.

Having a solid understanding of the indicators you are going to work with is critically important. The key is to truly comprehend their definitions, goals, and limitations.”

Chloe Zoeller, Voces del Sur

Furthermore, the organization emphasizes the need to disaggregate the data, so that it is possible to make a more in-depth analysis of what is going on, for example by looking at differences between rural and urban areas or exploring the gender dimensions of the issues.

By providing data on a regional level, Voces del Sur has been able to amplify the work of the individual organisations in the different countries, identify trends and attract more attention to the regional issues. Their 2021 shadow report on SDG 16.10.1 was based on the data of 13 countries in Latin America.


details with different sources, such as the victim, organizations on the ground, media organizations, press clubs, witnesses or family of the victim. Furthermore, it is important to verify the motivation of the violation: was it carried out because of the work of the victim as journalist or media worker?

Best practice – Data verification (La Fundación para la Libertad de Prensa)

Organizations that structurally monitor cases of violence against journalists often have one or multiple staff members dedicated to this task. Verification of each case and understanding the process is essential to ensure the data is credible and that the attack was related to the work of the journalist.

“We call, corroborate the information with two other people, document the case with photos and judicial documents. Each case is almost a small journalistic production. This gives solidity to the numbers.”

Raissa Carillo, La Fundación para la Libertad de Prensa (FLIP), Colombia

In this, having a network of people and organizations throughout the country that can contribute to the verification is very effective. For example, FLIP has a network of correspondents throughout Colombia that they can contact to help verify the data.

Similarly, the Alliance of Independent Journalists (AJI) of Indonesia has chapters in 40 cities in the country that contribute to the verification of cases.

The Pakistan Press Foundation follows a similar approach:

“If there is an attack on a journalists, we have a list of people that we will contact about it. This includes the local press club, the local journalist union, the police department, the district administration, personal colleagues of the journalist, the head office where the journalist works and the family of the journalist or the journalist him/herself. Based on that, we get an idea of why that attack probably took place”.

Owais Ali Aslam, Secretary General of the Pakistan Press Foundation

Best practice – Documenting violence against journalists in Indonesia

The Alliance of Independent Journalists (AJI) of Indonesia records cases of violence against journalists regularly and provides information for the public through a website. The association has chapters in over 40 cities throughout Indonesia and works with CSO coalitions to identify and verify cases of violence against journalists. Each case is verified through an internal mechanism and published on the website.

They also monitor media content for reports of violations against journalists, which they further investigate. Every year, AJI issues the annual report which presents an updated overview on the safety of journalists in Indonesia and they nominate the ‘enemy of the press’ of that year. This is often the actor that was the main perpetrator of violence against journalists.

Finally, the organization also advocates for follow-up of cases to ensure that the perpetrators are brought to justice. In 2020, the data collected by AJI was used by the Indonesian government to report on the progress of SDG 16.10.

Indicator 16.10.2

16.10.2 – Number of countries that adopt and implement constitutional, statutory and/or policy guarantees for public access to information

UNESCO is responsible for collecting global monitoring data on SDG 16.10.2 and does so through an annual survey. For this indicator, it is important to not only assess the existing laws and policies with regards to access to information, but also to what extent they are being implemented and what mechanisms are in place to guarantee access to information.

Methodologies to measure this indicator could include reviewing information available on government websites, assessing institutional mechanisms9, interviews, and submitting requests for information to the government to assess the responsiveness and transparency of the government. Interestingly, the availability of information on how the government is reporting on the SDGs and the VNR process, is already an indication on the implementation of 16.10.2.

Best practiceAssessment of the Implementation of SDG Indicator 16.10.02 on Access to Information in Four African Countries

In 2021, the Africa Freedom of Information Centre published a shadow report on the implementation of SDG Indicator 16.10.2 in Namibia, Nigeria, Sierra Leone and Zimbabwe. Based on a methodology developed by Freedom of Information Advocates Network (FOIAnet), they assessed the extent to which States with RTI laws are implementing SDG 16.10.2 by looking at:

  • The extent to which a State is proactively disclosing information (without a request)
  • The extent to which institutional measures have been put in place to assist with implementation
  • The extent to which requests for information are being responded to timely and dutifully.

The last point was assessed by sending requests for information on three sectors (health and the context of COVID-19, environment/climate and financial proactive disclosure of budgets).

1.4 Report writing

The shadow report should be clear, brief and easy to read. In this it is important to use balanced and neutral language and back up statements with reliable data. Focusing only on the shortcomings of governments in implementing SDG 16.10 should be avoided. Instead, focus on both positive and negative aspects of the implementation and highlight activities by civil society organisations, as well as the government to implement SDG 16.10. Furthermore, consider linking SDG commitments to existing laws in the country, as well as the obligations that states have according to international and regional human rights mechanisms.

Finally, make sure that the recommendations are constructive, clear, and practical. Suggest realistic solutions with clear time frames and mention who should implement it (for example a specific government entity or stakeholder). This will make it easier to follow up on the recommendations. Broad statements are much easier to ignore by the relevant stakeholders.

The Tools section provides an example of an outline of a report that can be used as a guideline to write the shadow report.

Best practice – linking the shadow report to human rights mechanisms

In the shadow report report, it could be useful to link your findings to international and regional human rights frameworks. Issues of access to information and freedom of expression are recognized in international human rights.

International and regional human rights monitoring bodies, processes and mechanisms, such as the Universal Periodic Review (UPR) and the UN Special Rapporteurs, regularly provide recommendations to states on these issues. In the shadow report, you can refer to these recommendations and argue that they are also relevant to implementing SDG16.10. This can provide additional legitimacy to the findings and recommendations of the shadow report.

The Dutch expert centre on sexuality Rutgers has mainstreamed their messaging in two international processes

“Rutgers produced a separate ‘shadow report’ to use it as material to influence the [Dutch] government VNR report, and to ensure inclusion of SRHR-related issues in both the national section as well as the contribution of the Netherlands to the international realization of the SDGs. The shadow report included data, analysis and concrete recommendations which we tried to get integrated into the government report. Note that in parallel, the Netherlands was going through the Universal Periodic Review (UPR) process in Geneva and Rutgers also produced a stakeholder submission for that. We used the same/ similar messages (but adapted to the particular type of review) in order to have a consistent influencing strategy across the VNR and UPR processes. All of our messages were in line with our existing national advocacy strategies.”

Rineke van Dam, Advocacy Officer for Rutgers, the Netherlands, quoted in: Engaging with the Voluntary National Review Process: A Guide for Members of the Women’s Major Group

The page Related international and regional mechanisms of this toolkit provides more information about these human rights mechanisms.

1.5 Follow up

Since there is no official mechanism for shadow reporting, it is important to disseminate the report widely and design an advocacy strategy on how to raise awareness on the findings. This starts with publishing the report online, so that it is easily accessible. Furthermore, the report should be actively shared with relevant stakeholders, such as government officials at different levels, non-governmental organizations, and regional and global level actors, such as UN agencies and civil society organizations10. Issuing a press release or a launch event of the report can also be considered.

Where possible, try to participate in the High Level Political Forum in New York, either through your government or by (co)organizing a side event. Around the HLPF you can raise awareness for the findings of your shadow report. Furthermore, it helps to have very concrete goals of what you want to achieve with your advocacy, for example the passing of a specific resolution or recommendation. This will help to target your advocacy and make a strong case.

After the presentation of the VNR at the HLPF, it is important to advocate for the implementation of the recommendations and act on the findings. For example, advocate for the inclusion of the follow-up of the VNR in national development plans, action plans or dialogues, as well as an alignment of government programmes related to SDG 16.10 to civil society activities.

In the follow up, ideally make use of the coalitions and relations you already built during the shadow reporting process. As stated by Owais Aslam Ali of the Paksitan Press Foundation, “writing the report is the easy part. The most difficult part is developing links and lobbying for change. And that will only happen when we focus on consultations and on community building”.

Jointly advocate for the implementation of the SDGs and follow-up on the recommendations. Dedicated international and national days related to access to information or the safety of journalists are good occasions to highlight the findings of your shadow report. Finally, many organizations continue to advocate for the victims of the violations reported, in order to ensure that the perpetrators are brought to justice. Highlighting specific cases is often an effective way to make the issue relatable and show the urgency.

1The Free Press Unlimited Media Advocacy Resource Guide provides an overview of different stakeholder analysis tools.


3See for example the report by Voces del Sur that outlines progress of SDG 16.10.1 in Latin America:

4The ‘metadata’ for SDG 16.10 can be found here:

5The FPU Media Advocacy Resource Guide provides an overview of relevant indicator frameworks that could be used to formulate complementary indicators.

6The TAP Network provides an overview of supplemental global indicators of each SDG 16 target

7For full information on the definitions used, see:

8See for example the shadow report by Voces del Sur, with an explanation of the different categories used on page 16:

9Such as RTI agencies, oversight measures, action plans and/or guidelines

10For example, the TAP Network has a platform to gather civil society reports on SDG 16.