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Estonia Action Plan Review 2020-2022

This product consists of an IRM review of Estonia’s 2020–2022 action plan. The action plan is made up of three of commitments that the IRM has organized into four. 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

Estonia’s fifth action plan continues to pursue the long-term goal of open and inclusive policy-making at the national level and open government at the local level, while also addressing lobbying transparency and, for the first time, whistleblower protection. The IRM recommends encouraging the use of the new co-creation toolbox and whistleblower reporting system through large-scale awareness-raising and capacity building efforts.


Participating since: 2011

Action plan under review: 2020–2022

IRM product: Action Plan Review

Number of commitments after clustering: 4

 Overview of commitments:*

  • Commitments with an open gov lens: 4
  • Commitments with substantial potential for results: 2
  • Promising commitments: 2

 Policy areas carried over from previous action plans:

  • Open policy-making
  • Open government at the local level
  • Lobbying transparency

Emerging policy areas:

  • Whistleblower protection

Compliance with OGP minimum requirements for Co-creation:

  • Acted contrary to OGP process: No

*For Commitment 3, the IRM has assessed the potential for results of the two un-clustered commitments separately, rather than for the commitment a whole. See Annex 1.

Estonia’s fifth action plan contains three commitments across three distinct areas, each consisting of two sub-activities. Commitments 1 and 2 aim to increase civic engagement in the co-creation of policies and to enhance government capacities at the national and local levels. Both directly continue from commitments in the fourth action plan. Commitment 3 addresses the regulation of lobbying practices and strengthening whistleblowing protections. For the purposes of this review, the IRM has un-clustered the activities under Commitment 3 into two separate commitments and analyzed them independently as Commitment 3.1 (lobbying regulation) and 3.2 (whistleblower protection).

Overall, the fifth action plan is well-structured, with concrete milestones. Like Estonia’s previous plan, the fifth action plan offers targeted commitments that can improve government practice in the particular policy area and be achieved in the course of two years (in some cases, as part of longer-term initiatives spanning several action plans). The action plan aligns with the national anti-corruption action plan for 2021–2025 and the “Estonia 2035” strategy, which aims to position Estonia as a global reference point in open government, specifically in co-creative policy making through advanced digital infrastructure.[1] Estonia also plans to apply to OGP’s Steering Committee during this action plan period.

Lobby transparency and whistleblower protection have been matters of public concern in Estonia. Commitment 3.1 addresses the lack of an established practice for ministries to publish meeting records with lobbyists. It calls for formulating recommendations for higher-level public officials on transparent communication with lobbyists and guidelines on avoiding conflicts of interest.[2] It also involves the recommendation for public officials to publish all meetings with lobbyists on a quarterly basis. Moving forward, the government could follow Transparency International (TI) Estonia’s recommendation to expand lobbying regulations and guidelines to all relevant public sector institutions, including local administrations and the Parliament.[3] The government could also consider adopting a mandatory lobby register to strengthen transparency mechanisms in public policy making.

Meanwhile, Estonian civil society organizations (CSO) have emphasized the importance of making whistleblowing safe during the COVID-19 pandemic and beyond.[4] Estonia is obligated to transpose a new EU directive on whistleblower protection into national law by the end of 2021. Prominent whistleblowing cases in recent years[5] have further signaled the need to regulate whistleblower protection and create secure channels for reporting wrongdoing. The IRM recommends accompanying the implementation of the whistleblower protection mechanism with large-scale awareness-raising and capacity-building activities. This could provide organizations the means to effectively act upon whistleblowers’ reports, while ensuring the anonymity, safety and wellbeing of whistleblowers.

The policy areas covered in the plan were identified by stakeholders as priorities during the co-creation process.[6] In several cases, governmental ministries and CSO stakeholders proposed similar commitments. For instance, both the Ministry of Justice and TI Estonia proposed measures for whistleblower protection (Commitment 3.2),[7] whereas the Ministry of Finance and CSOs proposed continuing promoting open government practices in municipalities

(Commitment 2).[8] Not all CSO proposals ended up in the action plan, either because other CSOs and government institutions deemed the proposal to be difficult to align with the scope and timeframe of OGP action plans or due to the lack of financial resources in responsible institution to implement the idea.[9] Taking up an IRM recommendation to include interest groups not involved in previous OGP processes, the Government Office and the OGP CSO roundtable met with associations of disabled people, youth and rural communities, and experts on elderly policies and transparency.[10]

The next section provides in-depth analyses and strategic recommendations for commitments 1 (online tool for co-creation) and 3.2 (whistleblower protection). Commitments 2 (open government in local municipalities) and 3.1 (regulation of lobbying) are not analyzed in greater detail. This is because these commitments currently lack a plan for broader institutionalization. However, these commitments could potentially see strong results if their implementation involves the integration of binding reforms and rules around their respective policy areas.

Promising Commitments in Estonia’s 2020-2022 Action Plan

 The following review looks at the two 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.

Key criteria used for selecting the promising commitments included the clarity of objectives, foreseen change in the respective policy area compared with the status quo, and the potential sustainability of the expected positive results. Commitment 1 continues the efforts to increase civic engagement in the co-creation of policies by releasing and testing the first usable version of the online co-creation tool (developed during the previous action plan). It goes further by also piloting a new toolbox of co-creation methods. This constitutes an important step toward integrating various types of policy initiatives and different parts of public policy making into one transparent and collaborative process. For Commitment 3.2, the Ministry of Justice aims to create a secure mechanism for whistleblowers to report wrongdoing, abuses, or harm. This is important given that whistleblower protection is currently unregulated in Estonia. As Estonia transposes the EU directive on whistleblower protections, this commitment could provide public sector institutions with a common tool for employees to use to report possible wrongdoings.

Two commitments are not analyzed in depth in this Action Plan Review. Under Commitment 2, the planned open government workshops in local municipalities could encourage best practice sharing among the municipalities.[11] However, the responsible ministries have not yet articulated how the outcomes from these activities will be sustained beyond carrying out the training events,[12] so it is not clear to what extent this commitment would create binding or institutionalized changes in local authorities’ governance practices.[13] That said, this commitment also entails developing a model that systematizes possible collaboration formats between local-level authorities and communities. If the Ministry of Interior and local municipalities develop a mechanism for mandating or encouraging the implementation of this model in local-level policy making, this commitment could significantly improve civic participation. For there to be a substantial impact on local public governance practices, the IRM also recommends going beyond pilots by integrating more binding mechanisms of change.

Finally, Commitment 3.1 involves implementing guidelines for good practice in lobbying for higher-level public officials with decision-making authorities and recommendations for public officials to publish quarterly information on all meetings with lobbyists. This commitment is unlikely to see institutionalized changes in government practice because, as clarified to the IRM by the Ministry of Justice, it will not entail consequences or sanctions for breaches.[14] However, the recommendation to publish quarterly information on all meetings with lobbyists is a positive step. The Ministry of Justice and the Government Office plan to develop a common template for public officials to present this information. The ministry also plans to mobilize Estonia’s existing corruption prevention network and possibly TI Estonia to monitor the implementation of the good practice.[15]

Table 1. Promising commitments

Promising Commitments
1. Increase co-creative policy-making capacity within government authorities. Building from previous action plans, the Government Office aims to develop an online tool for policy co-creation and publish and test a toolbox of co-creation methods. This commitment could be a significant step toward a government-wide transition to a more collaborative policy-making model built around the concept of co-creation.
2. Support the implementation of whistleblower protection regulations. The Ministry of Justice aims to develop a common digital tool that whistleblowers can use to report breaches of law, fraud, corruption, and other types of wrongdoing securely and confidentially. This commitment could be a significant step toward institutionalizing whistleblower protection in Estonia, in line with the EU directive.


[1] Strategy “Estonia 2035″

[2] Group of States against Corruption (GRECO), Fifth Evaluation Round: Preventing corruption and promoting integrity in central governments (top executive functions) and law enforcement agencies. Evaluation report: Estonia, 2018,

[3] Interview with Carina Paju (TI Estonia), 2 March 2021.

[4] Coalition to make whistleblowing safe during COVID-19, European Centre for Press and Media Freedom,

[5] See, for example, EU Observer, “Whistleblower: Danske Bank gag stops me telling more“, 19 November 2018,

[6] Government Office, Summary of ideas received through the public crowdsourcing campaign (unpublished).

[7] Interview with Carina Paju (TI Estonia), 2 March 2021.

[8] Interview with Kaie Küngas (Ministry of Finance), 20 April 2021.

[9] Interview with Ott Karulin (Government Office), 26 April 2021.

[10] The meetings mainly resulted in these groups’ improved awareness of their participation opportunities in the OGP process but did not yield concrete proposals for commitments. According to the representative of the CSO roundtable who participated in the meetings, most of the policy problems raised in the meetings were too complex to be addressed in the form of specific commitments within a two-year timeframe. Interview with Alari Rammo (Network of Estonian Nonprofit Organizations), 12 November 2020.

[11] As part of this commitment, the Ministry of Finance plans to conduct eight workshops to improve local governments’ awareness of open government, aiming to reach 48 out of the 79 Estonian local municipalities. Interview with Kaie Küngas (Ministry of Finance), 20 April 2021. The Ministry of the Interior plans to involve five municipalities in a development program to improve their skills in co-creation and civic engagement. E-mail interview with Marten Lauri (Ministry of the Interior), 19 April 2021.

[12] Interviews with Kaie Küngas (Ministry of Finance) and Marten Lauri (Ministry of the Interior).

[13] The Ministry of Finance has preferred a step-by-step approach to planning the activities to adapt to issues that municipalities consider relevant at a given moment. Interview with Kaie Küngas (Ministry of Finance), 20 April 2021.

[14] Mari-Liis Sööt and Kätlin-Chris Kruusmaa, Ministry of Justice, e-mail, 27 April 2021.

[15] The anti-corruption network is composed of 1–2 public officials in each ministry responsible for coordinating the implementation of the national anti-corruption law and strategy


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