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Mongolia Design Report 2019-2021

The development of Mongolia’s third action plan took place in a context of a government transition resulting in significant shortcomings in the co-creation process. The action plan is largely aligned with national priorities with commitments in new policy areas such as waste management and contracts transparency for internationally funded projects. Moving ahead, the Government of Mongolia needs to reactivate its OGP multistakeholder forum and focus on sustained implementation of reforms to fight corruption and improve service delivery.

Table 1. At a Glance

Participating since: 2013

Action plan under review: 2019–2021

Report type: Design

Number of commitments: 13

Action plan development

Is there a multistakeholder forum: Yes

Level of public influence: Consult

Acted contrary to OGP process: Yes

Action plan design

Commitments relevant to OGP values: 12 (92%)

Transformative commitments: 1 (8%)

Potentially starred commitments: 1 (8%)

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. Mongolia joined OGP in 2013. Since, Mongolia has implemented two action plans. This report evaluates the design of Mongolia’s third action plan.

Mongolia’s legislative and presidential elections in 2016 and 2017 contributed to a delayed OGP process. The development of the country’s third action plan formally commenced in August 2018 with a government-hosted workshop. Prior to this, civil society organizations (CSOs) independently collected public feedback on their proposals for action plan commitments. However, the Cabinet Secretariat, which leads Mongolia’s OGP process, did not report on how these proposals were incorporated in the final action plan. In general, the overall co-creation process was weakened by the absence of a functional multistakeholder forum, as well as gaps in coordination between government and civil society stakeholders which prevented iterative dialogue. In January 2019, the Chief of the Cabinet Secretariat approved the country’s third action plan, without consulting civil society, and submitted it to OGP in April 2019. The country thus fell short of the threshold for participation in the development of the action plan and was thus found to be acting contrary to OGP process.[i]

Several policy areas are continued from previous action plans including beneficial ownership transparency, open contracting, and improvement of public service delivery. The action plan also aligns with the Mongolia Sustainable Development Vision 2030, the Three-Pillar Development Policy, and the National Anti-Corruption Strategy. The plan contains a potentially transformative commitment to open up international aid and loan data around health and infrastructure projects. However, this action plan is less ambitious than previous action plans as a whole, with six commitments of minor and one of no potential impact.

Moving forward, the Cabinet Secretariat needs to prioritize reactivation of the multistakeholder forum and thematic working groups. The forum needs to collaborate closely with civil society to design and monitor implementation of commitments in key reform areas of anti-corruption and public service delivery.


Table 2. Noteworthy commitments

Commitment description Moving forward Status at the end of implementation cycle
4. Ensure citizen and CSOs’ engagement in public procurements of health and road/transportation sectors

Develop an online procurement information portal in compliance with the International Open Contracting Data Standards, facilitate citizen monitoring of health and transportation procurement, and create a glass account portal for further monitoring.

The Ministry of Finance should introduce a communication channel within the portal where the government can respond to citizen input and provide updates. Publication of past procurement information retroactively could aid further scrutiny and identification of areas for improvement. Note: this will be assessed at the end of the action plan cycle.
6. Increase legal knowledge of the target group through multistakeholder legal guide

Distribute legal information to marginalized communities through customized formats such as cartoons, video, radio, and text.


This commitment promises to improve citizens’ legal knowledge through various accessible formats. These efforts are most impactful if implemented within a larger legal aid ecosystem that includes increased access to justice services. Additionally, channels for citizens to submit complaints about legal services would further advance access to justice in Mongolia. Note: this will be assessed at the end of the action plan cycle.
10. Transparency of beneficial owners

Pass legislation on extractive sector transparency, collect and disclose beneficial ownership information, and raise awareness to improve compliance of companies in reporting their beneficial ownership data.

The Cabinet Secretariat could expand beneficial ownership transparency reforms beyond the extractive sector. Measures are needed to advance the use of standards to ensure data quality and interoperability and engage citizens, civil society, and the private sector in monitoring and implementing the framework. Note: this will be assessed at the end of the action plan cycle.



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.

Table 3. Five Key IRM Recommendations

Reactivate and formalize OGP structures including a national multistakeholder forum and thematic working groups
Establish a publicly accessible OGP repository and provide reasoned response on the content of the future action plan
Develop and scale up initiatives on citizen participation in areas of public service delivery, including health and education
Strengthen the anti-corruption framework by improving civil society and media organizations’ participation and oversight in the work of the Independent Authority Against Corruption
Advance Beneficial Ownership Transparency by ensuring wide coverage, interoperable data, and opportunities for multistakeholder engagement

[i] Open Government Partnership, Procedural Review,


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