Transparency without Democracy: The Unexpected Effects of China's Environmental Disclosure Policy



This article examines the impact of transparency regulations enacted under authoritarian conditions, through a study of China's environmental transparency measures. Given China's decentralized administrative structure, environmental disclosure ends up being weakest in the most polluted cities. However, the measures have allowed nongovernmental organizations (NGOs) to affect environmental governance through unusual pathways. Multinational companies (MNCs) have used NGO pollution databases to monitor Chinese suppliers, whereas local governments have responded to a transparency index with greater NGO engagement. That said, these civil society initiatives have had limited impact on key stakeholder behavior. For the environment ministry, enforcement costs remain high. Local government behavior depends on their economic priorities and the nature of their relations with enterprises. Chinese enterprise behavior depends on the character of their relations with government and MNCs. Given China's authoritarian structure, improved governance does not translate into stronger accountability, challenging common assumptions about the relationship between transparency and accountability.