Bosnia and Herzegovina Action Plan Review 2025-2027

Bosnia and Herzegovina (BiH)’s third action planAction plans are at the core of a government’s participation in OGP. They are the product of a co-creation process in which government and civil society jointly develop commitments to open governmen... includes promising commitments to simplify registration procedures for non-governmental organizations, develop an open dataBy opening up data and making it sharable and reusable, governments can enable informed debate, better decision making, and the development of innovative new services. Technical specifications: Polici... portal, and regularly publish public procurementTransparency in the procurement process can help combat corruption and waste that plagues a significant portion of public procurement budgets globally. Technical specifications: Commitments that aim t... More contracts. Most commitments carry forward unfinished or partially finished reforms from the previous cycles. The complexity of public administration reform and overlapping governance processes may present challenges for implementation.

BiH’s third action plan (2025-2027) has 10 commitments, seven of which directly continue initiatives in the first two plans.^[i] The IRM has identified three commitments as the most promising. CommitmentOGP commitments are promises for reform co-created by governments and civil society and submitted as part of an action plan. Commitments typically include a description of the problem, concrete action... 3 is a new initiative and aims to simplify the registration procedure for associations, foundations, and non-governmental organizations (NGOs). This com

mitment could reduce the occurrence of negative decisions on applicants’ requests and enable greater transparencyAccording to OGP’s Articles of Governance, transparency occurs when “government-held information (including on activities and decisions) is open, comprehensive, timely, freely available to the pub... More and efficiency in the registration procedure. Commitments 4 and 6 could lead to significant improvements in the transparency and accessibility of public information. Commitment 4 aims to support the development of the pilot of BiH’s first national open data portal, an unfulfilled commitment from the previous action plan. Commitment 6 aims to publish all public procurement contracts in BiH to the platform launched during the previous cycle.

Most of the other commitments would either continue practices from the previous action plans or offer modest changes to these practices and policies. This is the case for commitments aimed at raising civil society awareness of beneficial ownershipDisclosing beneficial owners — those who ultimately control or profit from a business — is essential for combating corruption, stemming illicit financial flows, and fighting tax evasion. Technical... More (Commitment 1), improving proactive transparency practices in public institutions (Commitment 5), facilitating public access to statistical data (Commitment 7), and improving budget allocation transparency (Commitment 8). A new initiative involves assessing the vulnerability of the NGO sector to money laundering and terrorist financing (Commitment 2) but lacks a clear open government lens of advancing either transparency, participation, or accountability.

During the co-creation process, two meetings of the Advisory Council (BiH’s multi-stakeholder forum for OGP) and a series of interdepartmental consultative meetings were held.^[ii] In addition, from 19 February to 6 March 2025, consultations were carried out via the e-consultation platform[iii] but received no responses.^[iv] The Ministry of Justice of BiH invited all institutions to participate in discussions for the action plan, but the number of institutions involved remained the same as in the previous cycle.^[v] On 7 March 2025, the Ministry of Justice of BiH prepared a Consultation Report and sent it to the Council of Ministers of BiH for consideration, along with the action plan.^[vi] The Council of Ministers of BiH adopted the action plan on 8 July 2025.

At the time of the action plan’s adoption, the Government of BiH had not passed the state budget for the fiscal year 2025. Until the state budget was finally passed in November 2025,[vii] the state government of BiH operated largely on a temporary funding basis, meaning that institutions received limited monthly amounts based on the previous year’s model, preventing normal planning and investment at the state level. In addition, the Government of BiH expects there to be a similar delay in passing the budget for 2026, causing the same temporary funding situation. This means some commitments requiring large financial investments, such as the NGO registration simplification (Commitment 3) and initiatives from the Agency for the Prevention of Corruption and Coordination of the Fight against Corruption of BiH (Commitments 9 and 10), may not be implemented within the planned deadlines.^[viii] BiH’s OGP implementation is heavily dependent on external project financing, creating structural vulnerabilities. A civil servant noted that the completion of projects that co-financed commitments from the previous action plan, such the Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) project that supported the Public Administration Reform Coordinator’s Office (PARCO), could undermine the implementation of commitments in the current plan.^[ix] Nevertheless, civil society members of the Advisory Council remain committed to the OGP process, despite political complexities affecting previous action plans.^[x] A civil society representative believes that the measures in the third action plan are ambitious but also noted that it is crucial to link the measures of the OGP action plans and other strategic documents in order to improve implementation.^[xi]

The European Commission’s 2024 Progress Report on BiH states that the country’s European Union (EU) integration has been “relatively slow”, partly due to internal political instability and the lack of progress on electoral and constitutional reforms.^[xii] The European Commission approved BiH’s Reform Agenda in December 2025, unlocking around 975 million EUR in financing for BiH under the EU’s Reform and Growth Facility for the Western Balkans.[xiii] While this support is much needed for BiH, it is conditional on implementation of the Reform Agenda.

In 2024, Modriča (in Republika Srpska) and Travnik became the first municipalities in BiH to join the OGP Local program.^[xiv] In 2025, the Brčko District Assembly expressed its desire to work with TI BiH and join OGP, either through an Open Parliament initiative or by joining OGP Local. The Advisory Council plans to host members of the Brčko District Assembly to offer them good practices and possibly enable the establishment of an open government multi-stakeholder forum (like the Advisory Council) in the Brčko District Assembly, consisting of MPs and civil society representatives. Given the highly decentralized government structure in BiH, the national OGP process could be strengthened by finding closer synergies with BiH’s OGP Local members or by encouraging greater expansion of OGP Local. Government members of the Advisory Council also indicate that they would like the OGP Support Unit to engage more proactively in BiH by supporting the activities implemented by Advisory Council members.^[xv]

[i] Open Government Partnership, Bosnia and Herzegovina Action Plan 2025-2027, https://www.opengovpartnership.org/documents/bosnia-and-herzegovina-action-plan-2025-2027/. Implementation of the action plan will last until 31 August 2027, which is also specified as the deadline for the implementation of activities, except for those activities that will be implemented on a continuous basis.

[ii] Ministry of Justice, Minutes from regular meetings of the Advisory Council of the Open Government Partnership initiative, https://www.mpr.gov.ba/reload/default.aspx?id=10936&langTag=bs-BA

[iii] The e-consultation platform, http://www.ekonsultacije.gov.ba

[iv] Report on e-consultations held with the interested public. Topic: Preliminary draft of the Action Plan of the Council of Ministers for the implementation of the Open Government PartnershipThe Open Government Partnership (OGP) is a multi-stakeholder initiative focused on improving government transparency, ensuring opportunities for citizen participation in public matters, and strengthen... More initiative 2025-2027.

[v] Selma Džihanović-Gratz, interview by the IRM.

[vi] Open Government Partnership, Bosnia and Herzegovina Action Plan 2025-2027,

https://www.opengovpartnership.org/documents/bosnia-and-herzegovina-action-plan-2025-2027/

[vii] Sarajevo Times, BiH gets a budget for the current year in November, amounting to 1.5 billion BAM, https://sarajevotimes.com/bih-gets-a-budget-for-the-current-year-in-november-amounting-to-1-5-billion-bam/

[viii] Mubera Begić, Vedrana Faladzić (PARCO), interview by the IRM, 2 December 2025.

[ix] Ibid.

[x] Lejla Bičakčić (Center for Investigative Reporting – CIN), interview by the IRM, 27 November 2025; Emsad Dizdarević, (Transparency international BIH), interview by the IRM, 26 November 2025.

[xi] Lejla Bičakčić, Minutes from 12th meetings of the Advisory Council of the Open Government Partnership initiative from 20 January 2025, https://www.mpr.gov.ba/reload/default.aspx?id=10936&langTag=bs-BA

[xii] European Commission, Bosnia and Herzegovina 2024 Report, accessed 15 November 2025, https://enlargement.ec.europa.eu/bosnia-and-herzegovina-report-2024_en

[xiii] European Commission, Commission approves Bosnia and Herzegovina’s reform agenda, https://enlargement.ec.europa.eu/news/commission-approves-bosnia-and-herzegovinas-reform-agenda-2025-12-04_en

[xiv] PARCO, Travnik and Modrica joined the Open Government Partnership, 17 April 2024, https://parco.gov.ba/hr/2024/04/17/travnik-i-modrica-prikljucili-se-partnerstvu-za-otvorenu-vlast/

[xv] Dizdarević, interview by the IRM; Begić, interview by the IRM; Faladžić, interview by the IRM.