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Norway Results Report 2019-2022

Norway’s fourth Open Government Partnership (OGP) Action Plan (2019–2022) contained 10 commitments, including digital public procurement, prevention of corruption, and beneficial ownership transparency. Most commitments saw only limited completion. Completed commitments included initiatives that existed outside the OGP framework. Key shortcomings remained in the country’s co-creation and participation practices throughout the action plan cycle because Norway acted contrary to OGP process.

Early Results

In total, 4 of 10 commitments achieved marginal early results. Commitment 8, identified as noteworthy in the Independent Reporting Mechanism (IRM) Design Report, is analysed in further depth in Section II. The implementation and early results of this commitment to establishing an Ultimate Beneficial Ownership (UBO) Register was hindered by Norway’s response to the Court of Justice of the European Union (CJEU) ruling invalidating public access to beneficial ownership information, despite Norway’s government approving legislative bills on the establishment of a UBO Register and developing a technical solution to host the Register. In light of the judgement, establishing a sound legal basis for opening the register will be a key challenge. Furthermore, sufficient funding must be secured for key verification mechanisms that would allow the register to serve its anti–money laundering and anti-corruption purposes. Marginal early results were analysed further for Commitment 3, which focused on expanding the use of the digital archiving system “eInnsyn” to municipalities and counties.


The original action plan submitted in 2019 contained eight commitments focusing on areas such as digitalisation of public procurement, youth involvement in rural areas, expansion of access to digitalised archiving practices, and prevention of corruption. Amendments to the action plan in 2021 added two more commitments (and amended existing commitments). Out of the ten commitments, four were fully or substantially completed (a similar level of completion as for the third action plan, where five of nine commitments were completed). The commitment on beneficial ownership, which was identified as noteworthy in the IRM Design Report, has achieved substantial completion.

Of the four commitments substantially or fully completed at the end of the fourth action plan cycle, one included an initiative that had been finished by the launch of the original action plan. Other commitments covered activities that formed the pre-existing initiatives beyond the OGP framework as most government bodies responsible for implementation confirmed that the activities would have taken place regardless. Barriers to implementation included limited high-level political buy-in as well as COVID-19.

Participation and Co-Creation

The Ministry of Local Government and Modernisation (KDD) oversees the OGP process in Norway. An OGP Council made up of five members from civil society organisations (CSOs) and businesses was appointed in 2019 and functions as an advisory body. Key shortcomings existed both in the co-creation process (although they have improved since the previous action plan) and during implementation. Civil society on the OGP Council regretted, inter alia, the format of the action plan’s co-creation meetings, where little background information and time to formulate commitment proposals were provided to participants and follow-up on stakeholders’ proposals and advice were limited. Similar structural shortcomings remained throughout action plan implementation. Civil society and the public had no opportunities for oversight of the commitment implementation progress,[1] and the national OGP website is not regularly updated with commitment status. As a result, Norway acted contrary to OGP processes during the design and implementation of its action plan.

Implementation in context

Norway is amongst the world’s strongest democracies, ranking high on international indices measuring civil liberties and civic participation, freedom of information, and anti-corruption. According to interviewees, this status can mean that OGP is perceived as superfluous because other formal channels to guarantee civic participation and transparency are already well established (e.g., public hearings, regular consultation processes on legislative bills).[2] The limited high-level political buy-in to the OGP process has affected the ambition of the action plan, with most commitments included representing existing initiatives; to some extent, it has also affected the level of implementation. Civil society have argued that delayed or limited implementation of commitments was the result of limited political push behind the initiative. The COVID‑19 pandemic was also considered a barrier to achieving results in terms of the realisation of commitment-specific activities, such as those for Commitment 3B (youth panel),[3] Commitment 6 (digitalisation of public procurement),[4] and Commitment 7 (prevention of corruption).[5] The COVID‑19 pandemic was also a barrier to the broader strategic interaction between and amongst governmental bodies, civil society, and the OGP Council, which did not meet in person throughout action plan implementation.[6] Public officials said that the need to respond to the COVID-19 pandemic meant the action plan (particularly, version 4B) was less prioritised than originally intended.[7]

[1] Tor Dolvik (Transparency International Norway/OGP Council), interview by the IRM, 2 November 2022; Mona Thowsen (Publish What You Pay/OGP Council) and Ingrid Hjertaker (OGP Council), interview by the IRM, 10 November 2022; Tom Arne Nygaard and Terje Dyrstad, interview by the IRM, 12 October 2022.

[2] Tor Dolvik (Transparency International Norway/OGP Council), interview by the IRM, 2 November 2022.

[3] Knut Ove Nordås (KDD) and Morten Mediå (Centre of Competence on Rural Development), interview by the IRM, 15 November 2022.

[4] Andre Hoddevik (Norwegian Agency for Public and Financial Management), interview by the IRM, 8 November 2022.

[5] Mona Ransedokken (Ministry of Justice and Public Security), interview by the IRM, 3 November 2022.

[6] Tor Dolvik (Transparency International Norway/OGP Council), interview by the IRM, 2 November 2022; Mona Thowsen (Publish What You Pay/OGP Council) and Ingrid Hjertaker (OGP Council), interview by the IRM, 10 November 2022.

[7] Asgeir Fløtre (Deputy Director General) and Tom Arne Nygaard (OGP Government Point of Contact), input to IRM during prepublication period, 8 March 2023.


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