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Netherlands Action Plan Review 2020-2022

This product consists of an IRM review of the Netherlands’ 2020-2022 action plan. The action plan is made up of 13 commitments that the IRM has filtered and clustered into 11. 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 IV. Methodology and IRM Indicators.


Participating since: 2011

Action plan under review: 2020-2022

IRM product: Action Plan Review

Number of commitments: 13

Overview of commitments:*

  • Commitments with an open gov lens: 12
  • Commitments with substantial potential for results: 2
  • Promising commitments: 5

Policy areas carried over from previous action plans:

  • Political party financing
  • Digital democracy
  • Freedom of information
  • Open contracting
  • Open data
  • Government algorithms

Emerging policy areas:

  • Electoral transparency
  • Plain language in government
  • Open-source
  • Public service complaints

Compliance with OGP minimum requirements for Co-creation:

  • Acted according to OGP process: Yes

*For commitments that are clustered, the IRM assessed potential for results at the cluster level, rather than the individual commitments.

Overview of the 2020-2022 Action Plan

The Netherlands’ fourth action plan addresses some issues of key relevance to the domestic political context, such as freedom of information, open contracting, and open technology. Full implementation would also position the country as a global pioneer in political party financing transparency and the registration and management of public service complaints. The commitments were developed through strong processes involving cross-government and civil society consultations. Implementation will benefit from involvement of external experts for objective learning and comparison with global best practice, and from support for synergies between commitments.

The Netherlands’ fourth action plan includes 13 commitments organized around seven themes that stakeholders identified during the co-creation process.[1] The action plan builds on some policy areas from the previous plan, including political party financing, digital democracy, freedom of information, open contracting, and government algorithms. It also introduces new topics such as electoral transparency, plain language in government, and publishing open data for public complaints. For the purposes of this review, the IRM has clustered three commitments on open technology, which entail open data communities, open source, and algorithms.

The fourth action plan offers modest but important steps in addressing well-publicized challenges in government transparency, particularly the implementation of the Public Access to Government Information Act (Vervolg Open Wob – WoB). Observers have accused the government of rejecting legitimate WoB requests, not responding in time to requests, or making false references to grounds for redaction (in particular, “policy intimacy”- the privilege of government officials to deliberate discreetly when forming policy).[2] These issues saw intense political debate and media attention during the child benefits scandal that led to the fall of the Dutch government in January 2021. The scandal revealed that the government knowingly withheld vital information from the public and that senior executives hold diverging views on how to share information with the public.[3] In this regard, Commitment 4 continues the previous action plan’s efforts to increase the number of government agencies making WoB information available in standardized open format. Commitment 7, meanwhile, addresses “policy intimacy” specifically.

Beyond the domestic context, the full implementation of two commitments could position the Netherlands as a pioneer in global open government efforts. Commitment 1 aims to strengthen legislation on transparency of political parties’ financing. If well-enforced, the binding rules around transparency of (digital) political campaigns would reveal how foreign and domestic actors seek to influence public discourse in the Netherlands through micro-targeting and online campaigns. In addition, the lessons learned from developing an open data standard around public service complaints (Commitment 13) could help other countries seeking to improve the transparency and effectiveness of their own public service delivery.

The action plan is the result of an extensive, year-long co-creation process that involved numerous (virtual) meetings with stakeholders and experts. A variety of new government agencies and civil society stakeholders joined this action plan for the first time and launched a new network called the Open Government Alliance.[4] This will require the Ministry of Interior and Kingdom Relations to balance input from an increased number of contributors with different and sometimes conflicting agendas, while preventing duplication of efforts in the existing multistakeholder forum. Nonetheless, the high level of collaboration on cross-cutting issues is laudable. Several commitments also include financial support for civil society involvement, which could bode well for successful implementation.

Although the final commitments are generally relevant to the open government context in the country, some do not clearly define their intended outputs. This has made it difficult for the IRM to understand and assess the potential for results of the commitments in key policy areas, such as the disclosure of government information. In addition, commitments often focus on technical solutions when there is a need for broader cultural and behavioral changes on issues that have become central to recent discussions on trust in government. Lastly, despite interest among civil society, beneficial ownership, lobbying transparency, and whistleblower protection are not included in this action plan. The government deemed these topics not feasible during the co-creation process.[5] The IRM recommends revisiting these topics for future action plans.

The next section will highlight the promising commitments that the IRM identified in this review and provide strategic recommendations to support their successful implementation. During the implementation, the IRM recommends seeking broad consultations with stakeholders with expertise and experience in these policy areas, especially where there is overlapping work. This could include external experts on political party financing (Commitment 1), experts in organizational psychology (Commitment 7), and international experts in algorithmic transparency (Commitment 12). Also, the open data communities from Commitment 10 could be consulted when creating the consolidated platform for procurement data (Commitment 9). The IRM also recommends connecting implementation of these commitments to broader domestic and international discussions. For example, implementing stakeholders could tie Commitment 1 to ongoing European discussions around political party financing legislation, and could consult the Dutch Whistleblowers Authority when developing the open data standard for public complaints under Commitment 13.

Promising Commitments in the Netherlands 2020-2022 Action Plan

The following review looks at the five Promising Commitments that the IRM identified as having the potential to realize the most promising results. The IRM will use this selection of Promising Commitments and their potential results to inform the assessment of Action Plan progress and impact at the end of the implementation period.

The IRM selected the Promising Commitments based on their importance to the overall government transparency and accountability context in the Netherlands, their potential results in the long run, and the proposed work being fit for purpose. The IRM also considered the direct involvement of relevant stakeholders in the planned work. This review provides an analysis of challenges, opportunities, and recommendations to contribute to the implementation of these commitments and the lessons learned.

The Netherlands’ fourth action plan generally addresses important areas for improvement. However, some commitments remain abstract and lack a more concrete vision for change. Specific milestones or intermediate steps are not always identified. In addition, the potential for results are often difficult to determine because the usage of planned outputs, such as guidelines and documents, are not specified. It is not always clear how these outputs will help define new practices or identify future work. Without illustrating the broader usage for such outputs, their added value could be limited. Future actions could be more impactful if they more clearly articulate the steps towards implementation and the added value from the planned outputs.

Commitment 1 could increase the transparency of political parties’ financing and reveal who is seeking to influence political discussions in the Netherlands, if the proposed binding rules for transparency of digital political campaigns are enacted and enforced. Commitment 9 could lead to greater public scrutiny of government contracts and government spending if the proposed contracts platform is delivered. Commitment 13 could improve accountability and action on citizen complaints through the proposed publication of complaints data in open formats. Finally, the cluster on technology (Commitments 10, 11, and 12) could strengthen the openness of and participation in open data, open source, and government algorithms.

Several commitments center around the Public Access to Government Information Act (WoB). Commitment 4 continues the previous action plan’s efforts to increase the number of public authorities making WoB information available in standardized open formats. Commitment 5 will proactively disclose certain categories of government information, in compliance with the WoB’s forthcoming successor, the Open Government Law (Wet open overheid- Woo). While these are positive initiatives, the IRM has focused on Commitment 7 in this Action Plan Review. The guidelines and discussions from this commitment could be useful starting points for addressing a critical issue in the debate on freedom of information in the Netherlands: “policy intimacy”.

The commitments not selected for further analysis in this Action Plan Review are positive efforts but are ultimately less critical to the open government context in the Netherlands. Commitment 2 could lead to greater transparency of how elections results are tabulated at the municipal level. The IRM has not reviewed this commitment in further detail because electoral results in the Netherlands already enjoy high levels of trust and transparency.[6] Commitment 6 on plain language could improve government communication with citizens, though this issue is less pertinent compared to those addressed in the Promising Commitments. Lastly, Commitment 3 will largely continue the previous action plan’s efforts to strengthen local democracy by developing and promoting digital participation tools.

Table 1. Promising commitments

Promising Commitments
1. Transparency in the Political Parties Act: The proposed legislation could improve regulations and transparency around political party financing in a number of ways. Importantly, the legislation could provide binding rules around the transparency of digital campaigns and micro-targeting, which is currently unregulated and highly opaque. 
7. The Future of Policy Intimacy: This commitment is a preliminary step towards resolving tensions around the issue of “policy intimacy”, where government information that includes the personal opinions of public officials on policies does not have to be disclosed.
9. Contract Register in the Netherlands: The new platform from this commitment could lead to greater public scrutiny of contract information by a larger group of experts and stakeholders and support the Netherlands’ post-COVID-19 economic recovery.
10, 11, 12. Open Technology: The commitments in this cluster could improve how the Netherlands uses critical technologies and data. The human rights impact assessment under Commitment 12 could help reduce possible biases and ethical issues in the algorithms procured by government agencies.
13. Open data standard for public service complaints: The publication of complaints data in open format could provide the government, civil society, and citizens with better insights into the scale, scope, and outcome of complaints. Through standardized data collection, trends in poor public service delivery could be recognized faster and remedied better. In addition, this commitment could help other countries strengthen their public service delivery methods.

[1] Ministry of the Interior and Kingdom, The Netherlands Open Government Action Plan 2020-2022,

[2] Government and WoB requests, and

[3] Tweede Kamer, Verslag Parlementaire ondervragingscommissie Kinderopvangtoeslag, December 2020,

[4] Open Government Alliance,

[5] The Netherlands National Action Plan 2018-2020, End-of-Term Self-Assessment Report, p 8,

[6] See for example,,, and


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