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Ireland Action Plan Review 2021-2023

This product consists of an IRM review of Ireland’s 2021–2023 action plan. The action plan is made up of three of commitments. This review emphasizes its analysis on the strength of the action plan to contribute to implementation and results. For 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 IV: Methodology and IRM Indicators.

Section I: Overview of the 2021–2023 Action Plan

Ireland’s third action plan renewed national engagement in the open government process. It includes a promising commitment on lobbying transparency that would improve enforcement of the “cooling-off period” for public officials entering the private sector. To deliver substantial results from commitments on anticorruption and access to information, the IRM recommends building on the publication of planned legislative reviews to implement recommendations emerging from those reviews.

Ireland joined the OGP in 2013. This review evaluates the design of Ireland’s third action plan, which includes three commitments, emanating from the Programme for Government. The commitments build on initiatives from the previous action plans on anticorruption, access to information, and lobbying regulation.


Participating since: 2013

Action plan under review: 2021–2023

IRM product: Action plan review

Number of commitments: 3

Overview of commitments:

  • Commitments with an open gov lens: 3 (100%)
  • Commitments with substantial potential for results: 1 (33%)
  • Promising commitments: 1

Policy areas carried over from previous action plans:

  • Anti-Corruption
  • Access to Information
  • Lobbying Regulation

Compliance with OGP minimum requirements for co-creation:

  • Acted contrary to OGP process: No

This action plan renewed Ireland’s OGP engagement, following a challenging process during the previous action plan cycle. The action plan was developed with an expedited co-creation timeline. In October and November 2021, the Department of Public Expenditure and Reform (Ireland’s OGP point of contact) distilled potential commitments from the Programme for Government and oversaw an open call for proposals for the action plan. This resulted in 18 submissions from civil society. Simultaneously, along with an Interim Civil Society Round Table, it facilitated the formation of a new Round Table Multi-Stakeholder Forum, co-chaired by the Department of Public Expenditure and Reform and civil society, currently represented by the Open Government Association of Ireland. In January 2022, the Round Table selected three commitments from the Programme for Government, one of which was also submitted by Transparency International Ireland during the public call. Following the action plan’s publication, civil society is leading co-creation of three commitments to be added to the action plan, via Round Table sub-groups. Drawn from civil society submissions, these commitments would focus on participative governance, the Public Participation Network, and legislation related to the NGO sector. Building on the momentum of this co-creation process, the IRM recommends institutionalizing an OGP unit at the Department of Public Expenditure and Reform.

One of the action plan’s commitments lays out promising reforms to existing lobbying regulation. Building on a review of the Regulation of Lobbying Act (milestones completed prior to the action plan), Commitment 3 intends to develop and pass an amended bill. One of the key amendments would improve the enforcement of a cooling-off period, during which public officials are restricted from engaging in lobbying for a year after they leave office.

The other two commitments could be strengthened, building from preliminary activities to concrete policy reforms. Commitment 1 aims to review the Statutory Framework for Ethics in Public Life and Commitment 2 aims to review the Freedom of Information Regime, but neither include milestones for implementing recommendations from these reviews. The IRM recommends providing government feedback on how individual public submissions are incorporated into the reviews’ recommendations. Commitment 1 could also be leveraged to build greater transparency into the Statutory Framework for Ethics in Public Life, expanding access to information; transparency in declaration of interests; and proactive, timely publication of machine-readable data, usable by the public. For Commitment 2, the government could create enforceable legislation on the proper publication processes for Freedom of Information queries, rather than simply listing queries received. To expedite responses to Freedom of Information queries, the government could also make efforts to streamline document management.

In the future, commitments should focus on concrete policy reforms and exclude milestones that were implemented prior to the action plan. Conducting the next co-creation process over a more extended timeline can allow flexibility in designing commitments that move beyond initiatives already established by government. This would enable the open government process to offer greater added value. If full legislative review and approval processes are considered, the Round Table could designate a four-year action plan cycle.

Section II: Promising Commitments in Ireland’s 2021–2023 Action Plan

The following review looks at a commitment 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.

The IRM selected Commitment 3 based on its aim to deliver legislative reform. This commitment would amend the Regulation of Lobbying Act to close gaps on the cooling-off period for certain elected and public officials. The action plan’s other commitments aim to review Ireland’s Statutory Framework for Ethics in Public Life and Freedom of Information Regime, but do not include milestones implementing of the reviews’ recommendations or concrete policy reforms.

Table 1. Promising commitment

3. Review of the Operation of the Regulation of Lobbying Act 2015: This commitment would amend the Regulation of Lobbying Act to improve enforcement of the cooling-off period for certain elected and public officials.


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