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Albania Action Plan Review 2020-2022

This product consists of an IRM review of Albania’s 2020-2022 action plan. The action plan is made up of nine commitments. This review emphasizes its analysis on the strength of the action plan to contribute to implementation and results. For the commitment-by-commitment data see Annex 1. For details regarding the methodology and indicators used by the IRM for this Action Plan Review, see section III. Methodology and IRM Indicators

Overview of the 2020–2022 Action Plan

Albania’s fifth action plan aligns closely with pre-existing government strategies and priorities toward EU accession, including commitments to prevent corruption in public institutions, introduce beneficial ownership transparency, and improve access to justice. However, the government continued to act contrary to the OGP process as it developed the action plan without a multistakeholder forum. A dedicated multistakeholder forum should be established, without delay, to monitor implementation of the current plan and develop future action plans that also consider citizen and civil society priorities.


Participating since: 2011

Action plan under review: 2020–2022

IRM product: Action plan review

Number of commitments: 9

Overview of commitments:

  • Commitments with an open gov. lens: 9 (100%)
  • Commitments with substantial potential for results: 3 (33%)
  • Promising commitments: 3 (33%)

Policy areas carried over from previous action plans:

  • Budget transparency
  • Digitizing public services
  • Open data

Emerging policy areas:

  • Integrity plans
  • Beneficial ownership
  • Access to legal aid

Compliance with OGP minimum requirements for co-creation:

  • Acted contrary to OGP process: Yes

Albania’s 2020–2022 action plan is the country’s fifth OGP action plan. It contains nine commitments, which seek to develop integrity plans, a beneficial ownership register, improve and digitize public service delivery, publish open data, expand measures ensuring access to justice, and implement budget transparency and transparency of state assets and revenue.

The 2020–2022 action plan development process saw the continued absence of a forum or space for government and civil society to jointly oversee the development process, set priorities, and choose final commitments.[1] Therefore, Albania continues to act contrary to the OGP process by not establishing a dedicated multistakeholder forum or space, despite being notified of acting contrary to the OGP process in the previous cycle.[2] To overcome this, the IRM reiterates its previous recommendation for Albania to establish such a forum, in line with OGP standards, to oversee implementation of the action plan and development of the next plan.[3]

During the plan’s development, the government sent invitations to relevant civil society to participate in pre-consultation surveys on the government’s four priority areas. The summary reports for these surveys show that by this stage, the government had already chosen commitments and that the surveys included questions to support the government’s choices, or relatively general questions about open government.[4] At later stages in the process, the government invited some civil society groups to comment on most of the drafted commitments. According to some of these invited civil society groups, government institutions considered civil society input at these meetings or reflected them in the commitments, while others noted they were already in longstanding conversations with government before the action plan development process started.[5]

The government published its evaluations and feedback on civil society comments as an annex to the action plan and on the Albanian OGP repository.[6] The quality and specificity of the feedback was not consistent across the commitments, and it was not always easy to understand how specific comments were incorporated into final commitments.[7] This demonstrates some, but limited, progress in feedback compared to the previous action plan cycle, when Albania acted contrary to the OGP co-creation process for not providing any reasoned response to stakeholder input. For future action plans, the feedback should be clearer, more precise, and publicly available for stakeholders before the action plan is published so they can understand how their input was considered and incorporated.

As a consequence of this process, the commitments in the 2020–2022 action plan are largely replicated from pre-existing government initiatives and strategies, rather than stemming from priorities identified through engagement with civil society and citizens. Furthermore, since the commitments continue pre-planned or ongoing reforms, some milestones were already implemented before the action plan consultation began. As with previous action plan commitments, most are supported, financially or otherwise, by international donors or are specific measures needed in Albania’s journey towards EU accession.[8]

The quality of commitment design, however, has improved since the previous action plan; commitments have clear objectives and represent a wider range of open government topics.[9] The three promising commitments analysed in Section II could deliver substantial results. “Integrity plans” will be the first time that government risk assessments specifically focus on corruption and provide anticorruption measures that will be monitored and evaluated in collaboration with civil society (e.g., the Ministry of Justice’s integrity plan during the action plan’s implementation, and other line ministries’ plans). The beneficial ownership register will centralise and publish important information that may help authorities tackle money-laundering by publicly identifying the real owners of businesses in Albania. The commitment on access to justice will engage vulnerable and marginalized groups to increase judicial awareness and provide greater access to justice through free legal aid and mediation services.

Commitments on the open data portal and on public service delivery are coded “unclear” because they largely continue actions which were planned or started before the action plan was adopted. Commitments on budget and revenue transparency also have unclear potential, as their milestones appear to have already been implemented or constitute internal reforms, which do not clearly articulate an ambitious open government lens.

Promising Commitments in Albania’s 2020–2022 Action Plan

The following review looks at the three commitments that the IRM identified as having the potential to realize the most promising results. This review will inform the IRM’s research approach to assess implementation in the Results Report. The IRM Results Report will build on the early identification of potential results from this review to contrast with the outcomes at the end of the implementation period of the action plan. This review also provides an analysis of challenges, opportunities and recommendations to contribute to the learning and implementation process of this action plan.

If fully implemented, these three promising commitments could significantly change government practice in their respective policy areas. Commitment 1 on integrity plans aims to assess corruption risks and develop anticorruption measures in all state-level institutions and evaluate their implementation in, at least, the Ministry of Justice. This could establish clear and specific standards for ministries to prevent corruption and enable the public to understand what corruption risks exist. Commitment 2 would set up a beneficial ownership register in Albania for the first time, which could substantially increase and facilitate access to this information. This information could then assist in tackling money laundering threats. The commitment on access to justice would introduce a robust legal and institutional framework, and deliver legal aid and mediation services that could substantially change public access to these services, particularly for vulnerable and marginalized groups.

The other commitments, which have not been analysed in this section, relate to commitments which have only modest or unclear potential for results. The commitments related to improving the quality of public-service delivery at Integrated Services Centers, publishing open data, improving budget transparency, and improving transparency of public assets and revenue have unclear potential for results as they are ongoing reforms; inclusion in the action plan does not add further value or ambition to what was already planned in the Public Finance Management Reform Strategy of 2019-2022.[10] The commitment to update the Ministry of Justice website is a positive push toward greater transparency and is coded as having modest potential for results. The commitment on providing digital public services is also a positive development but has only modest potential as participation with civil society appears limited in scope (it only prioritizes which services to digitize rather than how also to improve those services).

Table 1. Promising commitments

Promising Commitments
1. Integrity plans — This is the first time that risk assessments would be implemented in Albania with a specific corruption focus and measures to tackle these risks. The Ministry of Justice plans to implement, monitor, and evaluate their own integrity plan and support other institutions in doing the same.
2. Beneficial ownership register — This commitment would centralize beneficial ownership information in Albania in one open and public register. Public authorities may find it easier to access such information and tackle issues like money laundering. It may lead to Albania being taken off the Financial Action Task Force “grey list” of countries with strategic deficiencies in this area.
6. Access to legal aid — This commitment would expand access to mediation services and legal aid, particularly to people outside the capital and marginalized or vulnerable groups.


[1] The government could not provide sufficient evidence of a dedicated multistakeholder forum when requested by the IRM. Evis Qaja, Government point of contact, email with IRM researcher, 16 Apr. 2021. One example of a government-only meeting discussing how to conduct the consultations, is available at: (see notes from 10 Sept. 2020 meeting).

[2] Sanjay Pradhan (CEO of OGP), letter to Deputy Prime Minister Brace (Albania), 14 Jul. 2020,

[3] OGP, “OGP Participation & Co-Creation Standards” (2017),

[4] Reports on pre-consultation surveys show that commitments were already chosen before civil society was engaged in the process. See Government of the Republic of Albania, The Open Government Partnership National Action Plan for Albania 20202022, Pre-consultation Report for Component 4: ‘Fiscal Transaprency’ [sic] (OGP, 2020),; Government of the Republic of Albania, The Open Government Partnership National Action Plan for Albania 20202022, Component 1: Anti-corruption Pre-consultation report (OGP, 2020),

[5] IDM confirmed they had been discussing integrity plan activities with the government since before the action plan process began. Rovena Sulstarova, emails with IRM researcher, 17 Feb. 2021. Mario Prendi (Albanian Legal and Territorial Research Institute) and Merita Toska (CO-Plan) stated their comments were reflected in the commitments (emails with IRM researcher, 17 Mar. 2021).

[6] Government of the Republic of Albania, The Open Government Partnership National Action Plan for Albania 2020 – 2022 (OGP, 2020),

[7] Id. at Annex 4. In most cases, the feedback merely describes the civil society feedback, without mentioning if or how this feedback influenced final commitments.

[8] For example, commitments on integrity plans and access to justice are supported by UNDP projects, while beneficial ownership transparency and budget transparency commitments are related to EU accession.

[9] Commitments in the prior action plan had multiple milestones on a variety of topics under a broad, overarching objective. This current plan includes milestones under each commitment that are specific and relevant to the policy area. There are more commitments with “modest” or “substantial” potential for results in this current plan compared to those assessed as “moderate” in the prior design report. Elvana Gadeshi, Independent Reporting Mechanism (IRM): Albania Design Report 20182020 (OGP, 2020),

[10] Ministry of Finance and Economy, Albania Public Finance Management Sectorial Strategy 2019-2022 (Dec. 2019),


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