National EFA Plans and achievements.408 These can be adapted and used by States to monitor progress towards the realisation of the right to education. NHRIs will also have a vital role in documenting violations of the right to education and monitoring progressive steps taken towards its realisation. NHRIs should develop a National Plan of Action on the Right to Education which would be complementary to the National EFA Plan and should assist in revising the latter from a rights-based perspective. The ACJ recommends that States maintain, update and publish at least annually qualitative and quantitative data on the progress towards realisation of the National Plan of Action on the Right to Education and/or the National EFA Plan. The Maastricht Guidelines require the documenting and monitoring of violations of the right to education to be carried out by all relevant actors, including NGO’s, national governments and international organisations.409 According to the CESCR, a State’s failure to maintain a system to monitor progress towards educational objectives will constitute a violation of article 13.410 In addition, as a matter of transparency States should be ready for and permit an audit of educational statistics and data by its NHRI, the Special Rapporteur, Treaty Bodies and other UN Agencies. 408 The EFA Development Index (EDI) is contained in the Education for All Global Monitoring Report 2006, available at http://www.unesco.org/education (last accessed 3 October 2006). The EDI constituents and related indicators are: • universal primary education: total primary net enrolment ratio; • adult literacy: literacy rate of the group aged 15 and over; • gender: gender-specific EFA index (GEI, the arithmetical mean of the GPIs for the primary and secondary gross enrolment ratios and the adult literacy rate); • education quality: survival rate to grade 5. 409 Maastricht Guidelines at para 32. 410 CESCR General Comment No. 13: The right to education E/C.12/1999/10 8 December 1999 at para 59. 130