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Serbia Action Plan Review 2020-2022

This product consists of an IRM review of Serbia’s 2020–2022 action plan. The action plan is made up of 12 commitments, four of which the IRM has filtered and clustered into two. 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 the IRM used for this Action Plan Review, see section IV. Methodology and IRM Indicators.

Overview of the 2020-2022 Action Plan

Serbia’s 2020–2022 Action Plan tackles diverse policy areas, and its promising commitments seek to better inform and engage the public on pressing national issues. However, the overall ambition of the action plan is low, on par with previous plans. The IRM recommends strengthening future action plans by incorporating more thorough milestones that effectively leverage each other to achieve the stated goals. It also recommends more suitably integrating higher-level public servants throughout the country’s OGP process so that the selected priorities become better integrated with government priorities and are addressed in greater depth.  


Participating since: 2013

Action plan under review: 2020–2022

IRM product: Action Plan Review

Number of commitments: 12

Overview of commitments:

  • Commitments with an open gov lens: 12 (100%)
  • Commitments with substantial potential for results: 3 (25%)
  • Promising commitments: 3 (25%)

Policy areas carried over from previous action plans:

  • Access to information
  • Civic participation
  • Environment and climate
  • Public procurement
  • Public service delivery

Emerging policy areas:

  • N/A

Compliance with OGP minimum requirements for Co-creation:

  • Acted contrary to OGP process: No

Serbia’s 2020–2022 OGP action plan is made up of 12 commitments. While the action plan largely resembles the previous one, some of its commitments carry potential to enable better monitoring and public participation in policymaking (commitments 2 and 3) and improve access to information and public accountability on combating violence involving children (commitment 7).

Overall, the action plan includes no new policy areas and carries over five themes from the previous action plan, including access to information, civic participation, environment and climate, public procurement, and public service delivery. For example, commitment 8, on amending the Access to Information Law, continues on from the 2018–2020 Action Plan[1] and is closely related to another commitment of the 2016–2018 Action Plan.[2]  Similarly, commitments 11 and 12, which seek to improve the framework and implementation of the Law on Public Information and Media, complement two commitments from the previous plan designed to improve transparency and public participation in the public financing of media.[3] It is important to note that while commitments 8, 11, and 12 are commendable in attempting to change important legal frameworks to improve access to information, civic participation, and public accountability, their results depend on the legal amendments being adopted without delay, and subsequent implementation is not likely to see early results until after the end of the action plan cycle.

The plan responds to IRM recommendations on incorporating more commitments targeting direct civic engagement and citizen-centered public services. The overall ambition of the plan, however, is comparable to that of previous cycles, in which the issues to be tackled are of high relevance to Serbia’s context, but the steps proposed to tackle them do not point to significant change in government practice, thus resulting in low ambition. Commitments that may be worth expanding on in the next Action Plan include commitment 4 on citizens’ participation in the management of protected environmental sites. The commitment envisions the formation of a working group to draft a law to this effect, but the results will flow only from effective implementation of the law, which goes beyond the scope of this action plan.

The plan’s co-creation included a broader consultation process, covering more than 70 representatives from government and civil society. It also addressed two key recommendations the IRM had made regarding the previous co-creation process[4] by including a broader range of civil society organizations (CSOs) and considering more diverse causes than it had in the past.[5] Among new topics discussed was the potential adoption of a more transparent procurement process in the government’s response to the COVID-19 pandemic. Ultimately, however, the OGP Working Group did not submit a commitment proposal relevant to this discussion in part due to the pressing deadline to submit the action plan and decided to discuss the issue in greater depth with competent authorities in the future.[6]

According to a CSO representative, civil society was able to use the co-creation’s procedures to act collectively and successfully advocate for turning down commitments they deemed of lower quality.[7] Nevertheless, several CSO representatives viewed the co-creation process as a mechanism to channel ideas to decision-makers outside of the OGP Working Group rather than a space to empower said Working Group to make decisions.[8] Some CSO representatives deemed that the agencies in charge of implementing the discussed commitments watered down the proposals without properly justifying the proposal modifications.[9]

This Action Plan Review recommends improving engagement of higher-level public servants throughout the co-creation and implementation of the action plan, better integrating CSOs’ demands with government priorities and improving the plan’s ambition by increasing the thoroughness of the commitments’ milestones to ensure that they effectively help accomplish the stated goals.

Promising Commitments in Serbia’s 2020-2022 Action Plan

 The following review looks at the three commitments (two of which are clustered together) 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 implementation period of the action plan. This review also provides an analysis of challenges, opportunities, and recommendations to contribute to the learning and implementation process of this action plan. 

The IRM selected the promising commitments discussed in this section using the methodology described on Section III. These commitments address issues of significant relevance to Serbia today. For example, commitment 7 responds to reports of widespread violence involving children, and commitments 2 and 3 seek to improve the quality of public participation in the creation of public policy. Each of the commitments included in this section is designed to have a wide reach and significant impact, and their milestones clearly articulate how they will contribute to the commitments’ respective goals. 

However, this section leaves out several commitments that at first glance appear promising but whose contextual circumstances and narratives suggest otherwise. Commitment 8, for example, seeks to create a draft amendment for the Law on Free Access to Information of Public Importance to improve the government’s transparency. Amending the law to address its current shortcomings is an ambitious endeavor, but it is something that was unsuccessfully tried in the previous two action plan cycles.[10] With the creation of the draft amendment as its last milestone, commitment 8 fails to anticipate challenges in the adoption of the draft and risks facing a similar fate. Commitment 10 has some design drawbacks as well. While it seeks to improve the government’s data management capacity, an important step for Serbia to modernize its data management capabilities and potentially the government’s ability to share information with the public, the commitment’s immediate goal is some steps removed from actually improving the delivery of information to the public, rendering its potential for early results moot.

As for commitments 11 and 12, their intention to make improvements to the Law on Public Information and Media from 2014 is highly relevant to the country, not the least because transparency as to how the government funds media has yet to be established.[11] The commitments respond to recommendations from the European Commission that Serbia make “ensuring suitable funding of public broadcasting services, transparent and equitable co-funding for media content serving the public interest, and increased transparency in media ownership and advertising” a priority, as well as to demands of the Balkan Investigative Reporting Network  (BIRN) and Civic Initiatives. [12] Nevertheless, the success of both commitments depends on the amendments being passed, and neither commitment addresses any potential roadblocks to accomplishing that. Beyond improvements in legal frameworks that both commitments would accomplish, any significant results would rely on the effective implementation of those legal frameworks, which would likely fall outside the timeframe of the current action plan.

Table 1. Promising commitments

     Promising Commitments
2 and 3: Improved public participation in the creation of public policy – These commitments aim to create a central platform to enable administrative bodies to improve access to information and public participation in the creation of national policies as well as a mechanism to systematically monitor the quality of public engagement in these processes. These efforts could improve public participation throughout the public policy cycle.
7: Combating violence involving children – This commitment seeks to create a platform to centralize and report on currently sparse or unavailable information related to violence involving children and will undertake responding to this violence through trainings and educational material for teachers and students. The platform could allow the public to report this type of violence and will require pertinent authorities to respond to those reports.

[1] See commitment 12 in the 2018-2020 Action Plan:

[2] See commitment 7 in the 2016-2018 Action Plan:

[3] See commitments 4 and 6 of the 2018-2020 Action Plan:

[4] IRM Serbia Design Report 2018-2020, OGP IRM, 2019

[5] Interview with Bojana Selaković, Civic Initiatives, 15 March 2021.

[6] Minutes of the Fourth OGP Working Group meeting:

[7] Interview with Danijel Dašić, National Coalition for Decentralisation, 12 March 2021.

[8] Minutes of the Fifth OGP Working Group meeting:; interview with Danijel Dašić, National Coalition for Decentralisation, 12 March 2021; and interviewee with stakeholder who asked for anonymity.

[9] Interview with Danijel Dašić, National Coalition for Decentralisation, 12 March 2021 and Interview with Bojana Selaković, Civic Initiatives, 15 March 2021.

[10] Commitment 6 of the 2016-2028 Action Plan sought to amend the Law on Free Access to Information of Public Importance to obligate public institutions to proactively publish information about their work in a consistent, complete, and regular manner. But the amendment was not passed, in part due to concerns from civil society that the amendments would result in backsliding on access to information rights. The following cycle, commitment 12 of the 2018-2020 Action Plan sought to amend the same law to improve oversight of compliance and expand the circle of authorities subject to the law. However, the amendment remains in limbo, and the public is uncertain about its future. For more information see the Serbia’s 2016-2020 End-of-Term Report:; and Serbia’s 2018-2020 Early Results Report: pending publication.

[11] Serbia 2020 Report, European Comission, 2020,

[12] Serbia 2020 Report, European Comission, 2020,


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