Independence of National Preventive Mechanisms (NPMs) b. Financial independence As noted earlier, the financial autonomy of an NPM constitutes an important criterion for guaranteeing its functional independence, as required under OPCAT Art. 18. By ratifying the OPCAT, the States Party undertake to provide the NPMs with the requisite financial means for the effective performance of their activities.73 In the Federal Council’s Dispatch on the FANCPT it is assumed that the NCPT will conduct approximately 30 inspection visits to detention facilities annually.74 The costs for the conduct of such visits were estimated at that time to be low, for which reason a cost ceiling of CHF 184,000.– was adopted. A source of debate was the costs of the secretariat, with the result that only 1.3 full-time positions were budgeted for.75 The basic funding for the NCPT was provided in equal parts by the FDFA and the FDJP, whereas the FDFA transferred its share to the FDJP. International review bodies have already voiced criticism with regard to the size of the NCPT’s budget.76 The Commission is currently included in the overall budget of the FDJP-GS and is thus not listed anywhere as an autonomous unit.77 For outside observers it is consequently not apparent that the NCPT is a decentralised administrative unit, separate from the EJPD Secretariat General, which is clearly an impediment to transparency and comprehensibility. Budget sovereignty lies with the General Secretariat, which exercises financial control. See Kälin/Nowak, pp. 9 and 13. 73 Botschaft vom 8. Dezember 2006 zum Bundesbeschluss über die Genehmigung und die Umsetzung des Fakultativprotokolls zum Übereinkommen der Vereinten Nationen gegen Folter und andere grausame, unmenschliche oder erniedrigende Behandlung oder Strafe, BBl 2007 278. 74 Cf. AB 2007 S 1088 / BO 2007 E 1088. 75 See the CPT report CPT/Inf (2012) 26, at 7; UPR, Approach of the Subcommittee on Prevention of Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment regarding the rights of persons institutionalized and treated medically without informed consent (SPT), 26 January 2016, CAT/OP/27/2. 76 Cf. the 2018 budget proposal, Voranschlag, vol. 2A, p. 199. 77 Activity Report NCPT 2017 43