A critical and comparative analysis of fiscal responsibility frameworks across countries: lessonsfor Mauritius

Purpose Fiscal responsibility represents government commitment to prudent financial management, transparent budgeting processes and sustainable public finance through disciplined revenue collection and expenditure control mechanisms. This research aims to examine Mauritius’s deteriorating fiscal position, where public debt increased from 59% to 87% of gross domestic product between 2015 and 2021, raising fundamental questions about long-term sustainability. Design/methodology/approach Through systematic doctrinal and comparative analysis of 11 carefully selected jurisdictions, examining official government documents, International Monetary Fund reports and Organization for Economic Co-operation and Development databases collected between January and September 2025, this study identifies three distinct fiscal framework models with varying effectiveness. Principles-based systems demonstrate superior crisis adaptability while rules-based frameworks achieve higher compliance rates when supported by strong enforcement mechanisms. Findings The research reveals that countries with independent fiscal councils experience average fiscal balance improvements of two point three percent of gross domestic product over five years. For Mauritius, establishing a comprehensive Fiscal Responsibility Act with an independent Fiscal Council requiring Rs 75m annual investment could reduce debt-to-gross domestic product ratio by 15 percentage points over five years while generating savings of Rs 400m–Rs 800m annually through reduced borrowing costs. Originality/value To the best of the authors’ knowledge, this study provides the first comprehensive comparative legal analysis of fiscal frameworks specifically tailored to small Island developing states contexts bridging fiscal law and development economics through actionable recommendations that balance oversight stringency with necessary flexibility.