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Italy Action Plan Review 2022-2023

This product consists of an IRM review of Italy’s 2022-2023 action plan. The action plan has nine linked commitments that the IRM has filtered and clustered into eight commitments (one cluster and seven individual 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 the IRM for this Action Plan Review, see section III. Methodology and IRM Indicators

Overview of the 2022 – 2023 Action Plan

Italy’s fifth action plan contains three promising commitments that establish frameworks to develop a national open government strategy, promote the prevention of corruption through training of public administration officials and by supporting whistleblowers, and enable open data and participation for monitoring public spending. Active collaboration between government and civil society to oversee the action plan as a whole, as well as to clarify the actions and implementation of commitments, would enhance potential results.


Participating since: 2011

Action plan under review: 2022-2023

IRM product: Action Plan Review

Number of commitments: 9

Overview of commitments:

  • Commitments with an open gov lens: 8 (89%)
  • Commitments with substantial potential for results: [0 (0%)]
  • Promising commitments: 3

Policy areas

Carried over from previous action plans:

  • Integrity and anti-corruption
  • Civic Participation
  • Digital Citizenship

Emerging in this action plan:

  • Open Government Strategy
  • Promoting Civic Space

Compliance with OGP minimum requirements for Co-creation:

  • Acted according to OGP process: Yes

Italy’s fifth action plan contains nine commitments which the public administration and civil society identified as priorities during the co-creation process. They focus on developing an open government strategy and governance structure, promoting integrity and preventing corruption, strengthening civil society participation, promoting engagement with women and young people and creating digital innovations.

Thematic areas carried over from previous action plans include developing networks for integrity and transparency, improving support for whistleblowers, promoting opportunities for engagement in COVID-19 recovery spending, creating a hub to support participation, enabling digital innovation, and introducing open standards that facilitate public monitoring of spending. However, they do not directly build on commitments from the fourth action plan.

Most commitments are linked to Italy’s National Resilience and Recovery Plan (PNRR),[1] which implements European Union Recovery Instrument funds.[2] The inclusion of commitments which seek to monitor (some of) the funds allocated through the PNRR are aligned to previous IRM recommendations and are closely linked to the requests put forward by civil society during the co-creation process.[3]

There are fewer commitments and policy areas in this action plan, resulting in a more cohesive plan than before. Government representatives said that the co-creation process focused on including commitments that are more targeted and narrower in scope but have a higher potential to achieve results.[4]

The co-creation process for the fifth action plan saw the involvement of 53 civil society organizations (CSOs) and 57 Public Administrations (PAs) and was structured along three phases: a start-up phase (July – September 2021) to discuss the results of the previous plan, gather feedback from civil society, and kick-start the process for the new cycle; an involvement phase (October – November 2021) during which the PAs and CSOs came together for a series of webinars, lab group sessions, and thematic meetings to identify relevant action areas; and a development phase (December 2021 – February 2022).[5] Four meetings, one (online) plenary session, five webinars, and one thematic workshop were organized by the OGP Task Force during this period.[6] The OGP Italy Team (the government secretariat that runs Italy’s OGP process), the OGP Task Force (a government body made up of experts on open government) and the Open Government Forum (the civil society forum that engages with the OGP process) were involved in the development of the action plan.[7] The meetings and relevant materials, including presentations and meeting minutes, are stored on the webpage EventiPA, and are due to be added alongside quarterly reports on implementation progress on the Monitora section of Italy’s official OGP website. The draft action plan underwent public consultation on the ParteciPa platform for one month, and a report on the results of the public consultation was published on 28 February 2022.[8]

Compared to the previous cycle, civil society stakeholders confirmed that the co-creation process for the fifth action plan considerably improved.[9] They praised the conscious effort by the OGP Italy Team to address criticisms from CSOs about the limited interaction during the implementation of the previous plan.[10] Government representatives said that they felt it was important to involve all relevant stakeholders and support those actively collaborating.[11] One CSO interviewee remarked that the high number of meetings,[12] changes to the previous practice and the several people involved in the OGP Task Force created some confusion. A representative of the OGP Task Force confirmed there was limited high-level institutional engagement during co-creation[13], which civil society also regretted.[14]

Interviewees confirmed the commitments included in the action plan align with civil society priorities and requests during the co-creation process. A shared online folder was used to store draft commitments. Access to this space was initially restricted only to those PA and CSO representatives directly working on the commitments, but was opened to the broader Open Government Forum on completion of the first draft.[15] This repository remains not accessible to the wider public. While the government provided a report on the comments submitted during the public consultation on the draft action plan, one interviewee remarked that like the previous action plan process, issues with feedback particularly at the early stages of co-creation remained problematic, with little to no feedback received from the OGP Task Force on the reason behind the inclusion or rejection of specific suggestions for commitments received by CSOs.[16]

An amended version of the action plan was submitted to OGP and published on the national OGP website in September 2022. The amendments changed the structure of commitments 2.01, 2.02 and 3.01, updated the PA and CSOs participating in each commitment and, in some cases, updated timelines for implementation. According to the Government, the action plan was amended to ensure compliance with the December 2023 implementation deadline, as well as to clarify the roles of key actors and supporting stakeholders.[17]

Implementation of the promising commitments would benefit from sustained CSO collaboration with government. This includes continuing collaboration to establish clear mechanisms and frameworks as part of implementing cluster 1 on the multi-stakeholder forum and national open government strategy. Training ‘managers’ of anti-money laundering on Suspicious Transaction Reports (STR) within local administrations as well as including CSOs in legal frameworks for supporting whistleblowers would broaden the ambition and impact of cluster 2 on corruption prevention and integrity. Likewise, training civil society on using procurement data for monitoring public spending and working with them to develop a system for reporting irregularities would boost the potential for results of Commitment 5.02.

Promising Commitments in Italy’s 2022 – 2023 Action Plan

The following review looks at the two clusters and one 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.

Commitments 1.01 and milestones one and two of Commitment 4.01 and 4.02 form a promising cluster of commitments on governance and the strategy for open government. The cluster of Commitments 2.01 and 2.02 on corruption prevention and transparency and Commitment 5.02 on open standards for the participation of civil society in monitoring public spending are also promising commitments and analyzed in depth in this section. The below narrative provides a brief overview and analysis of the rest of the commitments with targeted recommendations to steer implementation. The analysis takes into account the updates to the action plan made in August 2022.

Commitment 3.01 seeks to promote opportunities for participation and oversight of Italy’s National Resilience and Recovery Plan (PNRR). The commitment foresaw the promotion of public debate for increasing knowledge on major works as well as measures to foster structured interaction and monitoring between the Ministry of Sustainable Infrastructure and Mobility (MIMS) and civil society through use of a dedicated MIMS platform for monitoring PNRR funds. The activities related to the setting up of a dedicated MIMS platform have been removed in the amended action plan. According to the government, implementation was halted due to an overlapping of responsibilities between the MIMS and the Ministry of Economy and Finance (MEF), which is formally in charge of setting up a system[18] to monitor implementation of the PNRR.[19] The amended action plan highlights that the positive interactions that emerged between CSOs and public administration representatives in the early stages of setting up the MIMS platform will continue to be leveraged in the interactions with the MEF, and that CSO input on civic monitoring will feed into the development of the national strategy for open government.[20] No concrete commitment replacing earlier activities is, however, included in the amended action plan.

Commitment 3.02 seeks to enhance and facilitate the exchange of existing participatory practices by setting up a national Hub of expertise on participation, collecting and documenting existing participatory practices at local and national level, and promoting the establishment of a community of practice of qualified experts. The commitment does not explain how the Hub would leverage existing participatory tools set up under the framework of the previous action plan, like ParteciPA or The Hub has modest potential for results because it would benefit from more clearly defined outputs and expected impacts, which according to a government interviewee, are expected to be identified during implementation and based on the results of interviews to relevant stakeholders.[21] The Hub could be merged with ParteciPA and into a single portal to avoid the fragmentation of access points, which might otherwise be counterproductive for access to information.

Two commitments focus on the promotion of gender equality (4.01) and youth participation (4.02.). The elements related to the implementation of a Multi-stakeholder Forum are analyzed as part of cluster 1, later in this section. The remaining activity within Commitment 4.01 focuses on the development of a platform by the Department of Equal Opportunities (DPO) that makes data on the implementation of the certification system for gender equality in companies, as defined by law 162/2021,[22] accessible and transparent. Companies which implement concrete measures to reduce the gender pay gap, have positive maternity policies, and promote female leadership positions (among other actions), can receive a certification from which they receive up to EUR 50,000 of tax relief. The certification is also one of the measures included in the PNRR.[23] The IRM recommends the data published on the platform be provided in open format.

Lastly, Commitment 5.01 seeks to raise awareness as one way of enhancing current initiatives (“facilitation points”) across Italy’s regions which support citizens in accessing digital services and developing digital skills through training. The goal is to institutionalize a network of facilitation points as a reference point for these activities. A representative from the public administration explained that responsibility for implementation of these points would remain within the regional public administrations.[24] The IRM recommends ensuring regional administrations are adequately supported and trained in the management of these services.

Table 1. Promising commitments

Promising Commitments
Commitment 1.01, 4.01, 4.02: Governance and strategy for open government. This cluster of commitments (1.01, milestones one and two of Commitment 4.01, and 4.02) seeks to establish a Multi-stakeholder Forum for developing and monitoring the implementation of national OGP action plans and more broadly for developing a national strategy for open government in Italy. Targeted activities seek to promote women and youth representation.
Commitment 2.01 and 2.02: Corruption prevention and culture of integrity. This cluster of commitments seeks to facilitate networking between various public administration and civil society actors on corruption prevention with a view to reinforcing anti-corruption and anti-money laundering safeguards in particular in the implementation of the PNRR. Targeted activities further seek to strengthen the competences of institutional actors formally tasked with corruption prevention (RPCTs) through training, and by raising awareness on the existence of whistleblower support services implemented by CSOs.
Commitment 5.02: Open standards for participation of civil society in public spending. This commitment seeks to publish data included in the National Database of Public Contracts on public contracts of higher value than EUR 40,000, in open, OCDS format, and on a dedicated portal. The goal is to make existing information more accessible and easily interpretable so that civil society can more easily take part in the monitoring process.

[1] Government of Italy, National Plan for Resilience and Recovery, 2021,

[2] Regulation (EU) 2020/2094 of 14 December 2020 establishing a European Union Recovery Instrument to support the recovery in the aftermath of the COVID-19 crisis.

[3] Federica Genna, Independent Reporting Mechanism (IRM): Italy Design Report 2019–2021, 16 November 2020, p.81,

[4] Representative of OGP Task Force, interview by IRM researcher, 29 April 2022.

[5] Department of Public Function, Italy OGP website,; Open Government Partnership, Italy Action Plan 2022-2023 (December), p. 10,

[6] Government of Italy, FormezPA webpage, EventiPA,

[7] For more information on how OGP is organized in Italy, see

[8] Report on public consultation, Italy’s Fifth National Action Plan, February 2022,

[9] Federico Anghelé (The Good Lobby), interview by IRM researcher, 6 May 2022; Susanna Ferro (Transparency International Italy), interview by IRM researcher, 9 May 2022; Representative of Libera, interview by IRM researcher, 5 May 2022.

[10] The OGP Italy Team is made up of public officials from Formez PA and provides administrative support to the OGP process in Italy.

[11] Public officials from Department of Public Function, Comments received during pre-publication, 4 August 2022.

[12] In the design phase of the previous action plan, only three meetings with the Open Government Forum took place, for example. In the implementation phase, only three working group meetings took place, and no plenary meetings.

[13] Representative of OGP Task Force, interview by IRM researcher, 29 April 2022.

[14] Susanna Ferro (Transparency International Italy), interview by IRM researcher, 9 May 2022; Representative of OGP Task Force, interview by IRM researcher, 29 April 2022.

[15] Open Government Partnership, Italy Action Plan 2022-2023 (December), p. 8.

[16] Susanna Ferro (Transparency International Italy), interview by IRM researcher, 9 May 2022.

[17] Open Government Partnership, Amended Italy Action Plan 2022-2023 (December), p. 10, 1 September 2022,; Email exchange, Italy OGP team and IRM researcher, 2 September 2022.

[18] Court of Auditors, Report on progress in implementation of the PNRR, March 2022,

[19] As required by Art. 29, Regulation (EU) 241/2021. Government representatives told the IRM that this will be clarified. They added that during co-creation, responsibilities were still to be defined at the institutional level due to the new tasks assigned by the government in facing the COVID-19 pandemic situation. Deptartment of Public Function, Comments received during pre-publication phase, 4 August 2022.

[20] Open Government Partnership, Italy Fifth National Action Plan (amended version), September 2022

[21] Representative of OGP Task Force, interview by IRM researcher, 29 April 2022.

[22] Government Official Gazette, Law 162/2021,

[23] National Plan for Resilience and Recovery, p.209.

[24] Representative of Department for Digital Transformation, interview with IRM researcher, 6 May 2022.


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