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Spain Action Plan Review 2020-2024

España Revisión del Plan de Acción 2020-2024

This product consists of an IRM review of Spain’s 2020–2024 action plan. The action plan is made up of nine commitments that the IRM has filtered and clustered into five groups. Commitments include 57 initiatives by the General State Administration and 53 subnational initiatives. This review focuses on the most promising commitments to inform their 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 II, Methodology and IRM Indicators.

Overview of the 2020–2024 Action Plan

The co-creation process for Spain’s fourth action plan represents an ambitious step to continue advancing the open government agenda in the country. The plan has a strategic approach that integrates historical civil society demands by reforming the legal framework for access to information and public integrity systems.


Participating since: 2011

Action plan under review: 2020–2024

IRM product: action plan review

Number of commitments: nine plus one additional commitment on local initiatives

Overview of commitments:

  • Commitments with open gov lens: 9 of 9
  • Commitments with substantial potential for results: 6 of 9
  • Promising commitments: 6 of 9

Policy areas carried over from previous action plans:

  • Transparency
  • Open data
  • Citizen participation
  • Training of civil servants

Emerging policy areas:

  • Public integrity systems
  • Registry of interest groups
  • Artificial intelligence
  • Whistleblower protection

Compliance with OGP minimum requirements during co-creation:

Acted according to the OGP process: Yes

Spain’s fourth action plan contains nine commitments that encompass different initiatives at the national level and are aligned with the Sustainable Development Goals. Additionally, the plan includes 53 open government initiatives from Spain’s 19 autonomous communities and cities and one from the Spanish Federation of Municipalities and Provinces, all of which address the thematic areas established at the national level.

The Sectoral Commission on Open Government and the Open Government Forum, created as part of Spain’s third action plan, organized a broad participatory process to design the action plan. The Ministry of Territorial Policy and Public Function conducted an open public consultation from which 130 citizen proposals emerged. Between June and September 2020, before drafting the action plan, stakeholders voted during workshops to evaluate and prioritize proposals. Subsequently, the draft action plan was submitted to a final public consultation and approved by the Plenary of the Open Government Forum.

The action plan addresses some policy areas carried over from past cycles, such as transparency, open data, and citizen participation. At the same time, it introduces new policy areas such as integrity for artificial intelligence, as well as historical civil society demands like the regulation of lobbying and interest groups, and the protection of whistleblowers.

Civil society representatives said that the effort put into developing this action plan is remarkable, especially considering the impact of the COVID-19 pandemic during the process.[1] They highlight the openness of government representatives to discuss the proposals obtained during the consultation process, as well as the broad participation of organizations both at the local and regional levels.[2] Regarding its content, they indicate that the issues addressed through this action plan have evolved, outlining a more harmonious and longer-term vision for open government. The plan takes into consideration the lessons learned from the challenges of implementing substantial reforms over a two-year period.[3] It is important to highlight the level of participation and efforts used to integrate subnational initiatives as part of this plan.

Generally, the commitments in the action plan present opportunities, when understood as a whole, to generate positive and sustainable results in opening government. As representatives of Access Info Europe pointed out to the IRM, the key challenge in this respect will be to secure the political will to achieve legislative approvals for proposed reforms.[4]

Regarding the action plan’s awareness-raising and training pillar (Commitments 7, 8, and 9), the IRM values the adoption of recommendations from the OECD and IRM on inclusive open government communication strategies, since they are cross-cutting and instrumental for implementing other commitments. Although the IRM considers that these commitments have a modest potential for results, it is possible that the best practices contemplated as part of the Open Government Observatory and efforts toward inclusive communication will contribute to more substantial results in policy areas that choose to replicate them.

The IRM identified four promising reform areas with substantial potential for results: the regulatory framework for transparency, the public integrity system, the improvement of citizen participation processes, and the plan to improve transparency and accountability.

Promising Commitments in Spain’s 2020–2014 Action Plan

The following review looks at the commitments that the IRM identified as having the potential to realize the most promising results. To that end, this report analyzes key challenges, opportunities, and recommendations to contribute to the learning and implementation processes of this plan. 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.  Early identification of the potential outcomes of the action plan will be the base for the upcoming results report research phase.

The IRM clustered seven out of the nine commitments included in the action plan as follows:

  • Improved citizen participation (Commitments 3 and 4);
  • Public integrity systems (Commitments 5 and 6); and
  • Open government awareness-raising and education (Commitments 7, 8, and 9).

Commitments 1 and 2 were individually assessed and the 53 local initiatives were assessed jointly as additional open government initiatives. At the end of this analysis, the IRM presents an overall analysis of the commitments’ characteristics, goals, and their relation to the action plan.[5] Based on their potential for results and the open government priorities identified during the consultation process, the IRM identified the following six commitments as the most promising.

Table 1. Promising commitments

Promising Commitments
1. Reforming the regulatory framework to increase transparency and accountability: The proposed reforms seek to improve the right of access to information, enforcing the law and addressing areas of opportunity of the current regulations.
2. Plan to improve and strengthen transparency and accountability: This commitment aims at strengthening the quality of information in key public policy areas (grants, business registers, state budgets) while establishing a method for enforcing the Transparency Act (19/2013).
3. Improved citizen participation (Commitments 3 and 4): Activities under these commitments could improve the quality of participation spaces, both in terms of interactions via the Transparency Portal, and the identification of citizen input and their traceability into public policy.
4. Public integrity systems (Commitments 5 and 6): These commitments seek to create tools for the state administration to prevent corruption and strengthen integrity.

[1] Access Info Europe, “España aprueba un ambicioso IV Plan de Acción de Gobierno Abierto” [Spain approves an ambitious fourth open government action plan] (Access Info Europe, 30 Oct. 2020),

[2] Manuel Villoria Mendieta (Universidad Rey Juan Carlos), interview by IRM researcher, 23 Mar. 2021.

[3] Rafael Rubio Núñez (Universidad Complutense de Madrid), interview by IRM researcher, 29 Mar. 2021.

[4] Access Info Europe, survey by IRM researcher, 26 Mar. 2021.

[5] See the OGP Handbook (page 26) to consult guidelines on integrating local communities into an OGP action plan. OGP, OGP National Handbook: Rules + Guidance for Participants (Feb. 2021),


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