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South Africa Action Plan Review 2020-2022

This product is an IRM review of South Africa’s 2020–2022 action plan. The action plan is made up of three commitments. This review analyzes the strength of the action plan to contribute to implementation and results. For 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 III: Methodology and IRM Indicators.

Overview of South Africa’s 2020–2022 Action Plan

South Africa’s fourth action plan aims to reinvigorate the OGP process in the country after several years of inactivity. The plan’s three proposed themes are relevant and a good foundation on which to build. However, at present the commitments lack clarity and ambition. To strengthen its in-country impact and global leadership, South Africa can take advantage of an opportunity to submit a revised action plan, with clear implementation roadmaps and stronger government engagement.

South Africa had not submitted an action plan since its third ended in 2018. The new fourth plan (2020–2022) is an attempt to revive the OGP process in the country.


Participating since 2011
Action plan under review: 2020–2022
IRM product: Action plan review
Number of commitments: 3

Overview of commitments:
• Commitments with an open gov. lens: 3
• Commitments with substantial potential for results: 0
• Promising commitments: 0

Policy areas carried over from previous action plans:
• Open budget
• Fiscal transparency
Beneficial ownership transparency

Compliance with OGP minimum requirements for co-creation:
• Acted according to OGP process: Yes

All three of the commitments are quite mature in that they build on previous open government plans and have strong civil society leaders supporting them. However, changes in the OGP government point of contact, timing, and complexity of deliberations impacted the quality of the action plan. Two out of the three commitments lack verifiability, do not have clear potential for results, and resemble initial deliberations rather than concrete commitments. For example, the commitment on transformative fiscal transparency provides significant background to understand why it was important to include in the action plan but does not define activities or expected results.

The action plan states that consultations to further develop the commitments will continue, thus the commitment on beneficial ownership transparency is presented in vague terms with the expectation of ongoing co-creation. In the view of the IRM, the ongoing consultations foreseen in the commitment will be critical to articulate what it sets out to achieve during implementation.

One of the main challenges moving forward is strengthening the OGP program in the Department of Public Service and Administration (DPSA). Although there is political leadership, the DPSA and other government agencies require more technical resources and ownership. This action plan was built with strong civil society energy and leadership. Government leadership is necessary to ensure success during implementation but most importantly to deliver results and meet the expectations with which civil society engaged in the OGP process.

IRM action plan reviews focus on promising commitments. While the action plan is a step in the right direction, none of the commitments as they stand now meet the IRM’s criteria for promising commitments. Nonetheless, the themes of each commitment area are a strong foundation. The IRM encourages stakeholders in South Africa to further develop the current commitments and take advantage of the opportunity to submit a revised action plan with clear implementation roadmaps and a formal OGP multistakeholder forum that strengthens government engagement.

Promising Commitments in South Africa’s 2020–2022 action plan

The IRM focuses this section of the review on commitments that the IRM identifies as promising, analyzing the plan’s challenges and opportunities, and recommending options to facilitate the learning and implementation of the action plan. In addition, this review informs the IRM’s research approach to assess implementation in the results report. The results report builds on the early identification of potential results from this review to contrast with the outcomes at the end of the action plan’s implementation.

After an initial review of commitments in South Africa’s 2020–2022 action plan, the IRM determined that all three of the commitments in the plan have an open government lens, yet all lack any substantial potential for results, and most lack the clarity to be considered promising. The commitment on open data is verifiable and although the potential for results is modest, interviewed stakeholders considered this commitment to be fundamental to advance other commitment areas in the action plan.

Commitments 2 (transformative fiscal transparency) and 3 (beneficial ownership transparency) are vague and do not include clear activities or actionable milestones, making their potential for results impossible to predict or verify.

Given the lack of clarity in the design of most commitments in the action plan, the analysis below will focus on areas of opportunities and recommendations to inform the ongoing co-creation process of this action plan.


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