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Portugal Action Plan Review 2021-2023

This product consists of an IRM review of Portugal’s 2021–2023 action plan. The action plan has nine commitments. This review analyses 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.

Overview of the 2021–2023 Action Plan

Portugal’s promising commitment on transparency of COVID-19 recovery and resilience funding could strengthen openness in procurement and introduce important civic monitoring mechanisms. Following an improved participatory co-creation process, effective multistakeholder engagement could enhance ambition and precisely identify the open government results of commitments during implementation of the action plan.


Participating since: 2017

Action plan under review: 2021–2023

IRM product: Action Plan Review

Number of commitments: 9

Overview of commitments:

  • Commitments with an open gov lens: 6 (67%)
  • Commitments with substantial potential for results: 1 (11%)
  • Promising commitments: 1 (11%)

Policy areas:

Carried over from previous action plans:

  • Access to information
  • Open data

Emerging in this action plan:

  • Beneficial ownership transparency
  • Transparency of COVID-19 recovery funds

Compliance with OGP minimum requirements for co-creation:

Acted according to OGP process: Yes

Portugal’s second action plan contains nine commitments focusing on e-government initiatives, open data and increased access to information, beneficial ownership, public spending, education, and cybersecurity.

Most commitments are in new policy areas except those promoting access to information, which build on activities from the first action plan. Five commitments are part of other government initiatives (e.g., the SIMPLEX modernization programme) and civil society directly proposed two commitments (Commitment 8 on COVID-19 recovery and resilience funding, and Commitment 9 on enhancing access to information).

Compared to the previous action plan cycle, there were improvements to the development of commitments as the co-creation process included early, direct public outreach. The process encompassed a survey, policy assessment, three public workshops organised by civil society, four sessions between civil society and government to develop commitments, and a public consultation on the final version. Although the draft did not immediately meet civil society expectations, the commitment on beneficial ownership was strengthened, and commitments on COVID-19 recovery funding and access to information were included in the final plan as a result of civil society advocacy.

Commitment 8 on transparency of COVID-19 recovery and resilience funding demonstrates substantial potential for results. It would ensure all procurement-process and contract information for dispersing funds from the European Union’s (EU) Recovery and Resilience Plan are transparent and linked to different government data sources. In many ways, the commitment builds on advances made in e-procurement in Portugal, but it goes further by ensuring all procurement process are available in open data. In addition, envisioned Integrity Pacts could significantly expand the use of civic monitoring on the €16.6 billion of EU funding.

Other commitments in the action plan present modest advances in their respective policy areas or have unclear potential for results. Commitments 1–4 are related to Portugal’s SIMPLEX simplification and modernization programme. The IRM was unable to establish an open government lens for commitments 2-4 because they focus on e-government and public service delivery outcomes and not on improving access to information, citizen participation, or public accountability. This could change if, for example, they considered using innovative citizen participative methods to influence the changes being proposed. Commitment 5 is too broad, although engaging with citizens to understand their data needs may help focus implementation and could be reflected in newly published datasets. Commitments 6 on promoting cybersecurity and 9 on access to information do not point to clear changes in policy or government practice and thus have an unclear potential for results within the action plan period. The need to adopt various pieces of legislation that could take a while to pass through parliament presents a major barrier limiting the potential of Commitment 7 on beneficial ownership transparency within the action plan cycle. In any case, the awareness-raising efforts need to be systematic and extensive to effectively prepare businesses with the requirements to provide beneficial ownership data.

The commitments can be adapted during implementation to enhance their ambition and secure stronger results for open government. On beneficial ownership, it is necessary that access to a register be available to anyone without restriction, that the authorities enforce the submission of up-to-date and accurate data, and that they implement a verification mechanism. Finally, for the promising commitment on increasing transparency of COVID-19 recovery and resilience funding, authorities must ensure that detailed data on procurement and contracts are published in a timely manner as open data. To ensure effective public oversight, the government needs to implement civic monitoring mechanisms that also facilitate reporting irregularities of COVID-19 recovery procurement and contracts to the relevant authorities for further investigation.

Promising Commitments in Portugal’s 2021–2023 Action Plan

The following review looks at 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 action plan’s implementation period. This review also analyses challenges, opportunities, and recommendations to aid the learning and implementation process of this action plan.

Commitment 8 on increasing the transparency of COVID-19 recovery and resilience funding is analysed in depth in this review. It would increase the amount of information available on procurement and dispersal of €16.6 billion of funding, and encourage the development of civic monitoring of this spending.

Commitments 1, 2, 3, and 4 are all connected to Portugal’s SIMPLEX simplification and modernization programme, which seeks to improve public service efficiency. Commitment 1 aims to centralize and simplify citizen access to education-related information and services,[1] but results could be more impactful if during implementation, the public administration engages with users of education services to tailor the Single Education Portal to better reflect user needs.

Commitments 2, 3 and 4 may improve government efficiency or citizen access to public services through digitization, but the IRM was unable to establish that these commitments clearly set out to make a policy area, institution or decision-making process more transparent, participatory or accountable to the public. Commitment 2 seeks to digitize and automate help for public service users by developing a virtual assistant on the Portal das Finanças website. However, engaging with users of the Portal das Finanças website to improve, simplify, streamline or better explain how to use their public services would give the commitment a clearer open government lens. Commitment 3 would create more inclusive ways for accessing public services, but it is not clear that digitization and modernization of services would provide the intended beneficiaries with new or better-quality information than was already available. Commitment 4 seeks to improve data interconnection between different public entities, but should be followed up with actions that would bring greater transparency, participation or accountability, rather than solely focusing on increasing government efficiency in data management.

Commitment 5 seeks to increase the number of entities publishing data on the open data portal, as well as raise awareness and enhance usage amongst businesses, civil society, and the public. The commitment is of interest to civil society,[2] and milestones engaging civil society and citizens to understand their data needs could result in positive outcomes. However, the commitment is broad; it seeks to improve the quality and quantity of publicly available datasets, but with no clarity on the policy goals or how to improve decision making. Future commitments on publishing datasets would benefit from analyses of the deficiencies and identification of where open data would have most benefit to decision making.

According to the government, the topic of cybersecurity repeatedly appeared during co-creation. Commitment 6 therefore seeks to develop initiatives that produce and share knowledge about good cybersecurity practices. This is a relevant topic, particularly as Portugal undertakes its modernization programme to digitize many public services (such as Commitments 1, 2, 3, and 4). However, the potential for results of Commitment 6 is unclear because even though it aims to engage citizens, the milestones do not point toward changes in government policy or practice within the action plan cycle.

Commitment 7 aims to strengthen the Central Register of Beneficial Owners (RCBE) through implementing the beneficial ownership data standard, raising awareness amongst obligated entities about the RCBE’s importance and how to submit information, and linking the data to other relevant public datasets. However, interviews with government officials revealed that there are legislative barriers to implementing the data standard and therefore also linking the data to public datasets.[3] While raising awareness will be important to ensure data is regularly and accurately updated, it is necessary for the register itself to be available to anyone without restriction, and that the authorities also enforce the submission of up-to-date and accurate data, including a verification mechanism.

Commitment 9 seeks to promote and ensure implementation of access-to-information legislation. This commitment’s potential for results is unclear, as it is dependent on the availability of financial resources to raise awareness of, and implement, current legislative requirements to identify and publish the names of relevant transparency officers within institutions.

Table 1. Promising commitments

Promising Commitments
8. Enhance transparency and corruption prevention in the implementation of the Recovery and Resilience Plan (PRR) and in the application of public funds: This commitment seeks to encourage public oversight of the dispersal of EU funds under the Recovery and Resilience Plan in Portugal. Increasing transparency of such information and engaging citizens as part of the monitoring process could prevent or uncover corruption, and ensure the money is spent effectively.

[1] Nuno Rodrigues (Directorate-General for Statistics of Education and Science), interview by IRM researcher, 18 Nov. 2021.

[2] Luís Vidigal (PASC and APDSI), interview by IRM researcher, 19 Nov. 2021.

[3] Patrícia Paralta, Marta Cotrim, and Elsa Belo (LabX and Administrative Modernisation Agency (AMA)), interview by IRM researcher, 8 Nov. 2021.


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