CCF Practice 2020–2026: Limits of Public Disclosure and Transparency in INTERPOL Decisions

CCF Practice 2020–2026: Limits of Public Disclosure and Transparency in INTERPOL Decisions

Published
October 1, 2026
Author
Khrabrykh S. A.
Original language
English

The report examines the public practice of the Commission for the Control of INTERPOL’s Files (CCF) and asks what can genuinely be inferred from annual reports, anonymised decisions and official procedural communications. Its central point is that the public CCF corpus is not a complete register of individual proceedings. It can reveal legal reasoning and certain institutional developments, but it does not by itself establish an overall success rate, an average processing time for particular types of requests, or the actual implementation of every decision.

The report treats transparency as several separate dimensions: availability of legal rules, disclosure to participants, publication of reasoning, statistical transparency and visibility of implementation. Improvement in one dimension does not prove improvement in the others. More published decision excerpts, for example, may make the Commission’s legal reasoning easier to understand without making it possible to calculate the probability of deletion or determine what happened after a particular ruling.

A substantial part of the analysis focuses on eight published decisions from 2023–2025 involving Red, Yellow, Green and Blue Notices, diffusions, and the SLTD and SMV databases. The comparison shows that deletion, conditional retention, correction of an identifier, retention with an annotation and unchanged retention are legally distinct outcomes. They should therefore not be reduced to a binary distinction between “success” and “failure” or described under a single formula such as cancellation of an international wanted-person record.

The report also examines the limits of statistical interpretation. It explains how results depend on the numerator and denominator chosen, on distinctions between received, admissible and completed requests, and on changes in reporting definitions. Closed cases in a particular year may have been filed earlier, while published decisions are selected and anonymised. For that reason, neither their number nor their outcome distribution should be treated as a representative statistical sample of all CCF proceedings.

ARGA proposes a model of targeted transparency. Public decisions should preserve the legally material structure of the case, identify the processing object, issue determined, outcome type and procedural stage, explain publication-selection criteria and changes in statistical definitions, and provide aggregate implementation information where feasible. The objective is greater verifiability without compromising applicants’ identities, sensitive operational information or confidential national case materials.

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