Comment: 37 pages, 11 tables, 2 AppendicesWe use the Newcomb-Benford law to test if countries have manipulated reported data during the COVID-19 pandemic. We find that democratic countries, countries with the higher gross domestic product (GDP) per capita, higher healthcare expenditures, and better universal healthcare coverage are less likely to deviate from the Newcomb-Benford law. The relationship holds for the cumulative number of reported deaths and total cases but is more pronounced for the death toll. The findings are robust for second-digit tests, for a sub-sample of countries with regional data, and in relation to the previous swine flu (H1N1) 2009-2010 pandemic. The paper further highlights the importance of independent surveillance data verification projects.