Mission Concluding Statement 

Mongolia: Concluding Statement of the 2024 IMF Staff Visit

October 14, 2024

• A critical priority for the new coalition government is to manage the current commodity boom prudently to effectively implement its ambitious reform and investment agenda.
• Building external and fiscal buffers will help create the necessary policy space to implement the ambitious investment program and other reforms in line with the economy’s absorptive capacity while maintaining external and internal balance. In the current situation, achieving these goals requires fiscal policy tightening, adherence to fiscal rules, tight monetary and macroprudential policies, and enhanced financial supervision.
• Progress on soft infrastructure related to legislative, regulatory, and institutional frameworks is just as important as building hard infrastructure, to strengthen the business climate and governance. Priorities include upgrading important regulations, ensuring regulatory coherence, and boosting central bank operational independence. The introduction of a nominal debt ceiling with strong deterrence is a major and welcome step forward. So will be the planned and overdue energy tariff reforms, which will be essential to ensure reliable national energy supply. Infrastructure projects should be well prioritized and effectively implemented with proper feasibility studies, strengthened medium-term fiscal planning and sound public investment management.

The economy: A commodity boom

A booming mining sector, record high coal exports, and strong household and government spending have led to buoyant economic activity despite a large contraction in agriculture due to the severe winter. The large and permanent wage and pension increases in the 2023−2024 budgets, large dividend payouts by Erdenes Tavan Tolgoi, government support programs, and a minimum wage hike helped raise household incomes and salary‑backed consumer credit, boosting consumption and imports. Strong revenue collection and backloaded capex registration have contributed to a budget surplus despite significant public spending increases. Public debt declined to 47 percent of GDP at end-2023, consistent with IMF staff estimates of the appropriate debt anchor for Mongolia.

Headline inflation has eased and lies within the BOM’s 6±2 target band. The decline is largely due to softer import prices, supported by a small exchange rate (ER) appreciation, and has led to policy rate cuts. However, core inflation remains sticky and has ticked up to the upper limit of the target band in August. Moreover, credit growth in the bank and non-bank financial (NBFI) sectors, especially consumer loans, has been rapid, exceeding long-term trends and has prompted the BOM to tighten reserve requirements and debt service to income (DSTI) limits for consumer loans. Household debt is rising rapidly, especially for some segments of borrowers.

External vulnerabilities declined despite a marked deterioration in the current account deficit due to strong imports and softer coal export prices. FDI and other financing inflows have helped support gross international reserves (GIR) which remains broadly at end-2023 levels (US$4.7 billion at end-August, 3.3 months of imports or 96 percent of the ARA metric). Well-executed external debt refinancing and the BOM’s repayment of half of the outstanding PBOC swap line have reduced external debt risks, resulting in a sovereign credit ratings upgrade.

Outlook: Continuing commodity boom, robust growth, but rising imbalances

Growth is expected to remain robust in 2024−25 reflecting strong mining sector growth, bolstered by the increased production of higher‑grade copper and stronger coal exports to China, and the expansionary, and procyclical 2024 supplementary and draft 2025 budgets. Assuming the government’s spending plans on mega projects[1] is gradually phased in in line with external financing, fiscal deficits are expected to rise through 2029, raising gross financing needs, public debt, and fiscal risks. The output gap is estimated to remain positive through 2028.

Expansionary fiscal policies are likely to widen Mongolia’s external and internal imbalances. Inflation is expected to continue to rise in 2024H2 and remain above target till 2026 due to the lagged effects of the substantial fiscal stimulus in the pipeline, additional stimulus from the 2024 supplementary and 2025 budgets, energy tariff increases, and strong credit growth. Current account deficits are expected to persist due to the high import intensity of investment projects, reducing GIR buffers, despite FDI and new external borrowing. 

The forecasts are subject to considerable uncertainty related to the implementation pace, financing, and private sector participation in mega projects, which is still under discussion. The greater the reliance on domestic financing, the larger the impact on GIR, ER, and inflation given the high import intensity of capex. However, procuring external financing to the tune of 67 percent of 2024 GDP within 4−5 years will be difficult. Realistically, therefore, investments are likely to proceed gradually, as implementation runs into capacity and financing constraints, thereby improving macroeconomic outcomes relative to current forecasts.

The outlook is also subject to downside risks stemming from commodity price volatility, uncertainty related to Chinese demand for coal, disruptions in fuel imports from Russia, and delays at China’s Tianjin port, a major transit point for Mongolia’s imports. Potential production and export delays in copper due to regulatory and procedural barriers pose risks. Natural disasters and geopolitical developments add uncertainty. On the upside, commodity prices or exports to China could be stronger than expected, especially in the near term. Moreover, new mining production could come onstream over the medium-term, boosting exports.

Policies: Prudent commodity boom management to sustain growth momentum

A. Fiscal tightening and adherence to fiscal rules: the top policy priority

Fiscal policy tightening is necessary to ensure external and internal balance, build buffers during the current boom and to reduce the burden on monetary policy in confronting inflationary risks. To achieve fiscal consolidation while boosting investment, additional measures are needed to reduce current spending and boost non-mining revenues, such as containing the wage bill, targeting social assistance, increasing progressivity in personal income taxes, reducing tax exemptions, and tax and customs administration reforms (IMF 2023 Report).

Reorienting spending toward infrastructure investment could enhance productivity, provided it is well managed and aligned with the economy’s absorptive capacity. The government should proceed cautiously given Mongolia’s external vulnerabilities, import dependence, limited domestic financing capacity, tighter global financing conditions, and weaknesses in public investment management (PIM). Building buffers during the boom helps create the fiscal space for a gradual, more effective implementation of critical public investment priorities. A more effective Medium-Term Fiscal Framework (MTFF) including capital expenditures is needed to guide capital spending and anchor fiscal and external risks. Investments should be well-prioritized based on proper feasibility studies, with sound implementation of PIM and PPP legislative frameworks to avoid corruption and unproductive projects.

The adoption of a nominal debt ceiling of 60 percent of GDP is a major step forward in strengthening Mongolia’s fiscal rules, as it boosts transparency and accountability, and includes strong deterrence measures. Retaining the structural deficit ceiling helps contain excessive deteriorations in fiscal balances. Nevertheless, neither rule will be able to constrain spending sufficiently in the near term since the debt limit is not binding at present. The procyclicality of the new expenditure rules helps support spending when the economy is booming, and requires spending cuts when it is not, thereby aggravating economic cycles. The rules will need to place some constraints on total spending, which would also preempt potential spending misclassifications (IMF staff stand ready to assist the government in developing appropriate total spending constraints that could allow the government to undertake spending related to its reform and investment plans). Frequent changes in fiscal rules should be avoided as they undermine the effectiveness of the rules as a policy anchor.

B. Ensuring tighter domestic financial conditions

Monetary and macroprudential policies should continue to ensure that domestic financial conditions remain tight. Given the expected rise in inflation in the absence of fiscal consolidation, the BOM should ensure real policy rates remain high until there is greater certainty regarding the stabilization of inflation within the target band. In this regard, maintaining an unchanged monetary policy stance in September 2024 would have been better aligned with the BOM’s assessment of the inflationary outlook. The tightening of DSTI limits and reserve requirements to slow excessive credit growth in the banking sector, on the other hand, were timely and appropriate measures, though more maybe needed (below). The government’s plans to resume domestic debt issuances to establish a yield curve should help improve monetary policy transmission.

C. Building external buffers to strengthen resilience, increase policy space for reforms

External buffers should be increased to strengthen resilience to external shocks and create the room for an effective implementation of the government’s reform priorities. The BOM should allow greater ER flexibility to help absorb external shocks. The government should use its ability to monitor export contracts to better enforce SOE repatriation and the currency settlement law and undertake reforms to attract new FDI and external private financing (below). The newly established BOM-MOF-MOED working group to align the pace of investments with external stability considerations, is an excellent initiative and should help inform the government’s investment plans and the MTFF.

D. Ensuring a sound financial sector

Financial sector supervision should remain vigilant about emerging risks, notably credit risk, given the exceptionally strong credit growth across the financial sector. Enhanced financial soundness indicators during periods of strong economic and rapid credit growth can mask underlying vulnerabilities. It would be important to align the planned reduction in DSTI limits for NBFIs with the lower bank DSTI limits rapidly to prevent regulatory arbitrage to contain explosive consumer credit growth. Supervisors should ensure that DSTI limits are being effectively enforced, accelerate the use of FICO credit scoring, and discourage over‑leveraged consumers from additional borrowing by improving financial literacy. Adherence to NBFI regulations and a rapid approval of the upgraded NBFI regulatory framework would help reduce risks. BOM and FRC supervisors should identify and reduce interlinkages between banks and NBFIs to pre-emptively reduce financial sector vulnerabilities and systemic risks including through targeted onsite supervisions and special provisioning requirements, if necessary. The BOM Governor should be allowed to exercise powers granted by the Central Bank Law to nominate key personnel responsible for financial sector supervisory oversight immediately to facilitate financial sector risk management and reforms.

The financial sector’s ability to lend to credit worthy entities should be strengthened through broader reforms. Insolvency and creditor rights must be improved to assist financial sector institutions address poor asset quality expeditiously. To keep banking sector reforms on track to meet the new end-2026 deadline, the BOM should continue to monitor the development of time-bound plans for shareholder diversification. Shareholder limits should be increased to ensure the effective management and operation of banks, including by allowing selected IFIs to invest in multiple banks.

E. Strengthening soft infrastructure is just as important for sustainable growth

Improving Mongolia’s business climate and governance is critical for strong and sustainable growth. Key priorities for soft infrastructure reform are—a strengthened Investment Law to cut red tape; accelerated overhaul of the Minerals Law; and approval of amendments to the SOE, Insolvency and the draft Whistleblower Laws. Effective enforcement of SOE governance reforms, and a strong judiciary is also necessary, as is ensuring the operational independence of BOM. The planned energy tariff reform is long overdue and necessary to secure energy supply to households and businesses while boosting long-term growth. Tariff increases should be well communicated, appropriately paced, and supported by targeted but temporary assistance to poor households to alleviate transition costs. Ensuring regulatory coherence with tax laws and effective tax dispute resolution processes would facilitate the operation of existing FDI projects and attract new FDI. The new Sovereign Wealth Fund is welcome but a strong governance framework for its sub-funds should be quickly established.

An IMF team visited Ulaanbaatar to conduct the discussions during September 25–October 1, 2024. The IMF mission would like to thank the Mongolian authorities for frank and constructive discussions and their kind hospitality.