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Spain Design Report 2017-2019

Spain’s third action plan made significant progress in terms of strengthening and deepening the open government agenda in the country. The plan is highly relevant to the value of access to information and notably committed to the institutionalization of the open government forum. During its development, the Government provided well-founded feedback about the extent to which public input was incorporated. The IRM recommends for the new forum created as part of this plan to serve as a space for collaboration and iterative dialogue with civil society during the design phase of future plans. To increase ambition, the IRM researcher recommends seeking stronger engagement of different branches of the State with high level support and to share leadership of the plan with civil society representatives and the public.

Table 1. At a Glance

Member since: 2011

Action plan under review: 2017-2019

Type of report: Design

Number of commitments: 20


Action plan development

Is there a multi-stakeholder forum? Yes

Level of public influence: Involve

Acted contrary to OGP process: No

Action plan design

Commitments relevant to OGP values:

16 (80%)

Transformative commitments: 1 (5%)

Potentially starred: 1

Action plan implementation

Starred commitments: N/A

Completed commitments: N/A

Commitments with major DIOG: N/A

Commitments with outstanding DIOG: N/A

Open Government Partnership (OGP) is a voluntary initiative that aims to secure concrete commitments from governments to promote transparency, empower citizens, fight corruption, and harness new technologies to strengthen governance. The Independent Reporting Mechanism (IRM) conducts yearly assessments of each OGP member’s activities to ensure that governments comply with their commitments. Spain joined OGP in 2011 and has since implemented three action plans. This report assesses the design of the third action plan (2017-2019).

Spain’s third action plan was a watershed moment with regards to previous action plans, as it incorporates the creation of a new governance structure – the Open Government Forum – as one of its commitments. The forum represents a space for dialogue and collaboration with equal representation from the Central Administration, autonomic administrations, and civil society. The country’s administrations are making significant progress in e-government and transparency. Spain has three active action plans led by the three levels of government: the Government of Spain, the Basque Government, and the Municipality of Madrid.[1] Areas of opportunity include securing and streamlining the right to access to public information, promoting social control, and public accountability.

Overall, stakeholders’ perception of the third action plan process was positive, and it was seen as a first step to increase the influence of the public in the future, as compared to the first and second action plans. All the interviewees acknowledged that the different forums contributed to increasing the understanding and trust of participants. During this period, the Government reached the involve level as a result of the disclosure of well-founded feedback with regards to the public input received. The Government led the consultation and drafting processes of the plan, including10 commitments that directly address citizen proposals, out of a total of 20. The Government also hosted a series of meetings with civil society organizations to discuss the public input. However, there was not a space in the process to allow for non-governmental stakeholders (experts, academia, civil society organizations, etc.) to share the leadership in the agenda-setting (with decision-making capacity over the plan) or to contribute to the structuring of commitments and milestones. However, the AGE showed a clear commitment to engage the territorial administrations and civil society organizations that showed interest during the implementation phase (which is not assessed in this report).

The 20 commitments that comprise the third action plan are organized in five themes: collaboration, transparency, participation, accountability, and education. They include numerous actions for collaboration among territorial administrations; measures to initiate children and youth in open government values; efforts to deepen the understanding and practice of administrations, to promote citizen participation and innovations in e-government and transparency.

Table 2. Noteworthy commitments

Commitment description Next steps Status at the end of the implementation cycle
1.1 Create an Open Government Forum Consolidate the forum as a means to funnel the development of the action plan, ensuring the incorporation of iterative dialogue among stakeholders throughout the co-creation process. This will be assessed at the end of the implementation cycle.
1.3 Network of Local Entities for Transparency and Participation

Promote the consolidation and operation of the Network of Local Entities for Transparency and Participation  

The IRM researcher recommends promoting peer learning, making data openness tools more sustainable, harmonizing criteria to interpret access to information rights and fostering inter-administrative dialogue and coordination. This will be assessed at the end of the implementation cycle.
2.2 Participation Observatory

An assessment of participation in the public realm to identify best practices and develop effective participation approaches


Adjust the Participation Observatory to apply lessons learned from the studies. Influence the creation of a legal framework for participation.


Create an outreach strategy focused on beneficiaries.

This will be assessed at the end of the implementation cycle.
3.5 Rules for the Transparency Act

Development of the Transparency, Access to Public Information, and Good Governance Act with Public Participation

Enable the completion of active disclosure obligations and guarantee the protection of access to information rights: defining time limits, procedures and undetermined legal concepts to secure enforcement of the causes of non-admission and/or limits according to Act 19/2013 and interpretative criteria of the Transparency and Good Governance Council. This will be assessed at the end of the implementation cycle.
5.3 Open Government Education

Educate students to practice democracy, transparency and interaction with the public realm

Continue online education, differentiating among target audiences: government officers, CSOs, teachers and citizens. Enhance the exchange of experience and resources to create inter-administrative networks for a unified methodology of ethical standards and participatory approaches, promoting an open government culture among public administrations. This will be assessed at the end of the implementation cycle.


The IRM recommendations aim to inform the design of the upcoming action plan and guide the implementation of the current plan.

Table 3. Five KEY IRM recommendations

1. Improve the forum workflow and operations to increase the quality of participation and offer spaces that allow the public to influence the commitment design.
2. Reduce the number of commitments but increase their completion, ambition, and potential impact; incorporate a focus on citizen priorities, such as anti-corruption, through open data approaches, whistleblower protection policies, and lobby regulation.
3. Incentivize active participation of civil society and strengthen its internal coordination.
4. Design a communication strategy to allow the public to identify the national OGP process and opportunities to participate.
5. Secure high-level political engagement and additional government entities in the OGP process and advance toward and “open State”.


[1] Pilot OGP Local Program. See:,,


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