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Croatia Action Plan Review 2022–2023

This product consists of an IRM review of the Croatia 2022–2023 action plan. The action plan comprises 16 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 IRM for this Action Plan Review, see Section III.

Overview of the 2022–2023 Action Plan

Croatia’sfourth action plan contains two promising reforms on improving transparency of media ownership and adopting a lobbying act for the first time. Administrative delays and political limits to the co-creation process negatively affected the ambition of the action plan overall and enthusiasm for the OGP process more generally. Guaranteeing relevant civil society input in drafting the lobbying act would improve implementation and help build civil society trust in government.


Participating since: 2011

Action plan under review: 2022–2023

IRM product: Action plan review

Number of commitments: 16

Overview of commitments:

Commitments with an open government lens: 16 (100%)

Commitments with substantial potential for results: 2 (12.5%)

Promising commitments: 2

Policy areas:

Carried over from previous action plans:

Policy area 1. Access to information

Policy area 2. Media legislation

Policy area 3. Whistleblower protection

Policy area 4. Open data

Policy area 5. Public consultation

Policy area 6. OGP at local/regional level

Policy area 7. Anti-corruption

Policy area 8. OGP sustainability

Emerging in this action plan:

Policy area 1. Personal data protection

Policy area 2. State assets

Compliance with OGP minimum requirements for co-creation: No

Croatia’s fourth OGP action plan contains 16 commitments. Two of these are promising commitments building on previous action plans to improve media transparency and introduce a new anti-corruption strategy and lobbying legislation.

Most commitments incrementally build upon the previous action plan, focused on increasing transparency of parliament, financial information, civil society funding, publicly owned companies, and official documents; whistleblower protection; opening up data; improving consultation processes; and stimulating open government at the local and regional levels. New themes pursued by the action plan deal with protection of personal data (linked with the implementation of the European Union’s [EU] General Data Protection Regulation [GDPR] legislation) and improving the transparency of state asset management.

Overall, this action plan is less ambitious than previous action plans, with almost half of all commitment milestones aimed at stakeholder education and training activities, or awareness-raising on different topics for the public. As in previous action plan cycles, government and civil society stakeholders have pointed to administrative constraints (such as rigid legal or procedural issues) and a lack of political ownership as reasons for decreasing ambition in action plans.[1] Furthermore, despite the relatively large number of Multi-Stakeholder Forum (MSF) members, there were few different or new policy areas proposed for inclusion in the action plan.

During development of the action plan, the MSF—made up of 27 civil society members and government officials—engaged the wider public twice via the e-consultation portal: the first to gauge which priority activities should be undertaken in the new action plan, and the second to receive feedback on the draft action plan. However, the co-creation process ground to a standstill while the competent body[2] deliberated on how to deal with the OGP action plan, as it falls outside of the scope of the country’s new strategic planning framework.[3] The delay in adopting the plan led the country to be found acting contrary to OGP process[4] and increased civil society fatigue with the development of the action plan.[5]

For Croatia’s co-creation process to meet the minimum requirements of the OGP Participation and Co-Creation Standards, it needs to ensure MSF meetings happen at least every six months, a two-week notice outlining a timeline of the development of any new action plan is published online, and there are outreach activities outside the MSF to provide information on OGP and the action plan process.

The two promising commitments identified in this review generate binding and institutionalized changes by improving media legislation, fighting disinformation, and introducing anti-corruption measures (in particular by introducing the law on lobbying). For the rest of the action plan, 13 commitments have modest potential for results and one is unclear.

Drafting the new Media Act and improving legal provisions on transparency of media ownership were carried over from the last action plan. Civil society representatives expressed some reservations regarding the drafting process and results of a new Media Act, given previous experiences in this policy area, and they agree it is an ambitious undertaking. It is important the legislation reinforces the legal framework to protect the rights of journalists and independent media. Furthermore, addressing concerns over the accuracy of information held by the “real” owners of media outlets would help to ensure ambitious implementation of this commitment.

The commitment on anti-corruption would lead to a new two-year action plan to accompany the Anti-Corruption Strategy 2021–2030 and drafting a law on lobbying transparency and regulation. The lobbying transparency reform is important, as the sector is largely unregulated despite many attempts by the lobbying community, relevant experts, civil society organizations (CSOs), and other stakeholders. It follows one of the key IRM recommendations from the last action plan cycle (to regulate lobbying and monitor the legislative footprints of Members of Parliament (MPs), government, and other officials). Such reform would benefit from bringing in relevant stakeholders with expertise in transparency and open governance to draft the lobbying act, ensuring a broad definition for lobbying, and to introduce open agendas for senior government officials and representatives.

Promising Commitments in Croatia’s 2022–2023 Action Plan

The following review looks at the two commitments that IRM identified as having the potential to realize the most promising results. Promising commitments address a policy area that is important to stakeholders or the national context. They must be verifiable, have a relevant open government lens, and have modest or substantial potential for results. This review also provides an analysis of challenges, opportunities, and recommendations to contribute to the learning and implementation process of this action plan.

Table 1. Promising commitments

Promising Commitments
Commitment 8. Media Regulatory Framework: The commitment aims to ensure greater transparency and independence of Croatian media. It involves legislative changes, such as to draft the Media Act, increase transparency of media ownership, and establish a media fact-checking system.
Commitment 12. Improving Anti-Corruption Legislation: The commitment seeks to operationalize the new Anti-Corruption Strategy 2021–2030 through a three-year action plan and regulate a specific area of anti-corruption by drafting new legislation, the Lobbying Act.


[1] The administrative constraints include rigid legal or administrative procedures, such as the obligatory gathering of official approval from each public authority involved in drafting any legislation or policy act, and the recently introduced process of fiscal impact assessment, which is compulsory for public authorities when creating commitments with potential budgetary impacts. Also, as Croatia has established a comprehensive institutional and legislative framework in the area of strategic planning, the co-creation process ground to a standstill while the competent body deliberated on how to deal with the OGP action plan, as it falls outside the scope of that framework. The political constraints were detected in previous IRM reports; specifically, a lack of a sense of ownership over the OGP process at higher levels of government. See the IRM Croatia Design Report 2018–2020:; IRM Croatia Transitional Results Report 2018–2020:

[2] The Ministry of Regional Development and EU Funds is the coordinating body for strategic planning and development management, in line with the Law on Strategic Planning and Development Management (OG 123/2017),

According to the internal e-consultation report, a positive result of this deliberation occurred when the Ministry of Regional Development and EU Funds issued the following opinion: “… all state administrative bodies responsible for drafting strategic planning acts must take care that the content of these acts does not contradict the international obligations that the Republic of Croatia has assumed based on its membership in the OGP initiative.” This means that the values that Croatia, as an OGP participating country, has promised to uphold must be taken into consideration and/or integrated into each act of strategic planning at national, regional, and local levels and their subsequent goals, measures, and activities.

[3] Internal e-consultation report and Darija Marić (Government Office for Cooperation with NGOs), online interview by IRM researcher, 15 September 2022.

[4] OGP informed the Croatian government on 15 February 2022 that it has acted contrary to the OGP process and was considered to have started a new action plan cycle,

[5] Darija Marić (Government Office for Cooperation with NGOs), online interview by IRM researcher, 15 September 2022; Melisa Skender (Gong), online interview by IRM researcher, 19 September 2022; Miroslav Schlossberg (HrOpen), phone interview by IRM researcher, 5 October 2022. Mr. Schlossberg withdrew from the OGP Council in 2021, in part due to these issues.


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