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Montenegro Action Plan Review 2022-2024

Montenegro’s third action plan has 20 commitments, covering citizen participation, open data, free access to information, fiscal transparency, anti-corruption, and open government at the local level.[1] For the purposes of assessment, the IRM clustered national commitments with local commitments that address the same topic (i.e., open data, fiscal transparency, and ethics and integrity). The IRM also clustered commitments 1, 2, and 3, which address civic participation in policy-making.


Participating since: 2012

Action plan under review: 2022–2024

IRM product: Action Plan Review

Number of commitments: 20

Overview of commitments:

Commitments with an open government lens: 20 (100%)

Commitments with substantial potential for results: 5 (25%)

Promising commitments and clusters: 3

Policy areas:

Carried over from previous action plans:

  • Public participation in policy-making
  • Open data
  • Freedom of information
  • Whistleblower protection
  • Fiscal transparency
  • Public service delivery

Emerging in this action plan:

  • Youth participation
  • Transparency of the Government
  • Accessibility of government websites
  • Transparency of EU funds
  • Integrity plans for public bodies
  • Open government at the local level

Compliance with OGP minimum requirements for co-creation: Yes

The third action plan covers a broader range of policy areas compared to the second plan (2018-2021).[2] Some areas are carried over, such as open data, whistleblower protection, and fiscal transparency. Among the new topics are improving transparency of the work of the government and publishing information on EU-funded projects. Many commitments support Montenegro’s EU accession or compliment other strategic documents.[3] According to a leading civil society organization (CSO) Institut Alternativa, these connections lowered the ambition, as the government planned to undertake many activities regardless of their inclusion in the action plan.[4] Several commitments also have a gender perspective, which reflect Institut Alternativa’s contributions during the co-creation process.

The Ministry of Public Administration (MPA) led the co-creation process, supported by the National Democratic Institute (NDI) and Institut Alternativa. The process took over one year (October 2021 to December 2022) and consisted of online and in-person consultations, interviews with CSOs, a survey of citizens, and three public hearings on the draft action plan. The mandate of the Operations Team (OT) – Montenegro’s multi-stakeholder forum – expired in July 2022 and was largely inactive during co-creation. The OT has yet to fill several vacancies due to the existence of a caretaker government following elections in August 2022. According to Institut Alternativa, the procedures for joining the OT are overly burdensome, which discouraged them from applying for membership.

Despite these challenges, the IRM noted improvements compared to the previous co-creation process. For example, the citizen survey attracted more responses, due to stronger outreach by the MPA. In addition, Institut Alternativa and NDI organized roundtable discussions in two municipalities outside the capital, which helped promote OGP to new stakeholders. However, Institut Alternativa believes that a lack of political support for OGP in Montenegro and the restructuring of the MPA in 2022 both negatively impacted the co-creation process.[5] Institut Alternativa found the commitments on anti-corruption (Commitments 12 and 13) and freedom of information (Commitment 6) insufficient in addressing long-standing gaps in these areas.[6] Institut Alternativa also proposed addressing beneficial ownership transparency, which was not taken up in the action plan.[7]

The IRM has identified two commitments and one cluster of commitments as promising. Commitment 7 could greatly improve the transparency of the work of the government, particularly when it discusses or decides on classified materials, and shed light on the work of the government’s advisory bodies. Commitment 11 could provide citizens and civil society with easier access to information on the realization of EU-funded projects in Montenegro. Commitments 1, 2, and 3 could address deficiencies of Montenegro’s e-participation portal and improve the quality of public hearings on draft legislation.

It will be important to focus on institutionalizing the reforms within public institutions (both at the national and local levels) and ensuring sustainability of the various trainings, guidelines, and awareness-raising activities focused on the public sector. The IRM recommends strengthening the commitments around anti-corruption (whistleblower protection and public institutions’ integrity plans) and addressing gaps in the legal framework for free access to information. Moreover, the IRM recommends responsible institutions consider potential synergies between national and local commitments that address the same topics (i.e., open data and fiscal transparency) for greater consistency and uptake across jurisdictions.

[1] Open Government Partnership, Montenegro Action Plan 2022-2024,

[2] Open Government Partnership, Montenegro Design Report 2018-2020,

[3] Particularly, the Public Administration Reform Strategy 2022-2026, to the Cooperation Strategy of State Administration Bodies and Non-Governmental Organizations 2022-2026, and the Digital Transformation Strategy 2022-2026.

[4] Milena Muk (Institut Alternativa Podgorica), interview by the IRM, 8 March 2023.

[5] Milena Muk (Institut Alternativa Podgorica), interview by the IRM, 8 March 2023.

[6] Institut Alternativa readout, December 2022,

[7] Institut Alternativa, December 2022,


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