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Finland Design Report 2019-2023

Finland’s fourth action plan focuses on promoting sustainable open government practices, lobbying transparency, and open data. The government involved a more diverse group of participants in the action plan co-creation and shared the agenda-setting power with civil society. At the mid-term review of the action plan in 2021, the government could consider expanding lobby regulation and registration obligation to the local and regional levels and improve the openness of key datasets on government transparency and anti-corruption.

Table 1. At a glance
Participating since: 2013
Action plan under review: 4
Report type: Design
Number of commitments: 4

Action plan development
Is there a multi-stakeholder forum: Yes
Level of public influence: Collaborate
Acted contrary to OGP process: No

Action plan design
Commitments relevant to OGP values: 4 (100%)
Transformative commitments: 1 (25%)
Potentially starred commitments: 1


The Open Government Partnership (OGP) is a global partnership that brings together government reformers and civil society leaders to create action plans that make governments more inclusive, responsive, and accountable. The Independent Reporting Mechanism (IRM) monitors all action plans to ensure governments follow through on commitments. Finland joined OGP in 2013. Since, Finland has implemented three action plans. This report evaluates the design of Finland’s fourth action plan.

General overview of action plan

Finland’s fourth action plan has a four-year duration, which aligns the action plan with the government program and strategies relevant to open government. It largely continues the priorities of previous action plans, mostly focusing on improving public access to information and the understandability of government information to societal groups with special needs. The action plan also addresses several gaps in Finland’s open government landscape, notably the lack of information on which interest groups influence governmental decision making.

The government successfully broadened the circle of participants during the action plan’s co-creation, including local and regional stakeholder consultations with groups who had not participated in previous OGP processes. The consultations resulted in new ideas being included in the action plan, such as the regional open government tours or the NGO Academy Day, which provides a platform for civil society actors and government officials to network and learn from each other.

The commitments’ level of ambition is diverse. While some constitute incremental improvements to the existing situation, the action plan also includes the ambitious commitment of setting up a lobby register to track the participation of interest groups in the government’s and Parliament’s decision-making processes (Commitment 3). If the register that emerges in the planned legislation is an obligatory instrument, and encompasses regional and municipal government in its coverage, and if it is accompanied by proper training and mechanisms for sanctioning non-compliance, this commitment could transform government openness in Finland.

Compared to the lack of verifiable milestones in the previous action plan, the fourth plan includes clearer descriptions of the planned activities along with timelines, responsibilities, and measures to assess their implementation. At the action plan’s mid-term review in 2021, the government could supplement activity-level indicators with outcome-level impact indicators to better monitor whether the activities help achieve the intended change in government practices.

Table 2. Noteworthy commitments

Commitment description Moving forward Status at the end of implementation cycle
Commitment 3: Transparency Register

Develop a legal basis and an information system to set up Finland’s first lobby register after parliamentary preparation and consultation with civil society.

During implementation, the Ministry of Justice could devote particular attention to securing easy online public access to information from the register and to training officials and lobbyists to use the system. The Ministry could also expand the registration obligation to local and regional levels of government. Note: this will be assessed at the end of the action plan cycle.


The IRM recommendations aim to inform the development of the next action plan and guide implementation of the current action plan. Please refer to Section V: General Recommendations for more details on each of the below recommendations.

According to the fourth action plan, the Government of Finland may consider including additional stakeholder suggestions in the action plan after the mid-term evaluation in 2021. Therefore, the key recommendations below aim to inform this mid-term evaluation of the current action plan, as opposed to the development and design of the fifth action plan.

Table 3. Five KEY IRM Recommendations

Continue and expand the broad stakeholder engagement model used in the co-creation of the fourth action plan.
Supplement activity-level implementation indicators of the commitments with outcome-level results and impact indicators.
Develop a more systematic approach to improving information understandability and accessibility for groups with special needs.
Expand lobby regulation and registration obligation to the local and regional levels.
Improve the openness of key datasets on government transparency and anti-corruption.



Filed under: IRM IRM Report

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