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North Macedonia

Regular Posting and Updating the List of Information Holders (MK0057)



Action Plan: Macedonia, Second Action Plan, 2014-2016

Action Plan Cycle: 2014

Status: Inactive


Lead Institution: Ministry of Information Society and Administration, Commission for the Protection of the Right to Free Access to Public Information

Support Institution(s): All information holders

Policy Areas

Capacity Building

IRM Review

IRM Report: Macedonia End-of-Term Report 2014-2016, Macedonia Progress Report 2014-2015

Starred: No

Early Results: Marginal

Design i

Verifiable: Yes

Relevant to OGP Values: Access to Information

Potential Impact:

Implementation i



Regular posting and updating the list of information holders

IRM End of Term Status Summary

VI. Open Data: Inventories and Proactive Transparency

Commitment 2.1: Proactive Open Data Access

Commitment Text: 2.1. Open data of the bodies and public sector institutions according to their technical features which they create in exercise of their powers that will be made available for use.

Commitment 2.3: Open Data Catalog

Commitment Text: 2.3. Establishing a Central catalog of public sector data published for use […] (

Commitment 2.4: Open Data Contact Persons

Commitment Text: 2.4. Establishing a database for the contact person in [public] institutions […] responsible for the technical adaptation and publishing of [accurate] data […] on the website of the authority and […] the catalog […].

Commitment 3.4: Access to Information Contact Persons

Commitment Text: 3.4. Regular posting and updating the list of information holders [and] implementation of the legislative obligation […].

Commitment 3.5: Proactive Access to Information

Commitment Text: 3.5. Availability of all public information on the web sites of the information holders.

Responsible institution(s): Ministry of Information Society and Administration (MISA); Commission for Protection of the Right to Free Access to Public Information

Supporting institution(s):  All information holders

Start Date: 1/4/2014     End Date: 31/12/2016

Commitment aim

The commitments in this cluster sought to improve the proactive, online release of information held by public institutions, and to provide datasets in open formats. Prior to Macedonia joining OGP, the proactive release of information inside the country was regulated by the Law on Free Access to Information, but its scope was narrow. The law did not specify the format for released information, and there was an overall lack of implementation. This cluster of commitments aimed to address the gap.



Commitment 2.1: Limited

Commitment 2.3: Not started

Commitment 2.4: Limited

Commitment 3.4: Not started

Commitment 3.5: Not started

Regarding open data (commitment 2.1), the government reported that 154 datasets from 24 institutions were released. The IRM review of datasets on the portal showed that only 90 datasets from 21 institutions were made available. The commitment did not specify the dynamics and scope of the released data, making it difficult to measure. However, the IRM review, plus the number of downloads, suggest that many of the released datasets are of little use to citizens.

A central catalog of public sector data (commitment 2.3) was not created, but the datasets can be filtered, according to the government’s self-assessment report. An Internet search of government ministries confirmed that the catalogs of datasets have not been created and made available, despite the legal requirement to do so.

Commitment 2.4 sought to establish a database of contacts within public institutions who are responsible for managing and updating the datasets. The government reported that it has started building the database using 11 pilot institutions, and will expand it as the commitment moves forward. However, the IRM researcher could not find evidence of the database’s existence, and the contacts for the pilot institutions are for internal use only by the government. In that sense, implementation of this commitment has begun, especially since the adopted legal framework has a much wider scope. 

Commitment 3.4 aimed for a “published list of information in accordance with the Law on Free Access to Information,” but the IRM researcher could not find evidence of an update. In its midterm self-assessment, the government did not provide information on the progress of this commitment.

For more information, please see the 2014-2016 IRM midterm report.

End of term

Commitment 2.1: Limited

Commitment 2.3: Not started

Commitment 2.4: Not started

Commitment 3.4: Limited

Commitment 3.5: Limited


There was limited progress on open data. The IRM review of the portal revealed that only four new datasets were released in the second year of implementation. Utilization of the portal is low, and only sparse data have been released. Several datasets were used as follows:

       7 pieces of data were downloaded more than 100 times

       12 were downloaded more than 20 times

       15 were downloaded more than 10 times

       18 were downloaded more than 5 times

The majority of the released data (87) was never viewed or downloaded. The most frequently downloaded data were:

       Address book of public and private kindergardens

       Number of disabled people per municipality

       Address book of children vacation hostels

       List of health institutions that perform preventive examinations of workers

       List of transfered numbers between mobile operators

The government’s end of term self-assessment report and a review by the IRM researcher showed no further progress on the implementation of commitments 2.3, 2.4, and 3.4.

CSOs proactively monitoring transparency in Macedonia maintained that state and local authorities tend not to comply with statutory obligations for releasing information.[Note 49: German Filkov, Sabina Fakic, and Marko Mitevski, Index of Active Transparency 2016, (Skopje: Center for Civic Communication, 2016), 12 [available at:, in Macedonian].] These authorities score better when it comes to information related to obligations from the FOI law, such as the official handling requests for access to information. On average, 61% of ministries and 52% of municipalities have this information.[Note 50: Ibid.] Additionally, fiscal transparency is the weakest area, as budget and spending information is rarely published. For example, recent monitoring by a CSO showed that institutions are more open when they receive a formal request for information, and rarely publish any information proactively, especially information about annual budgets and spending.[Note 51: Association for Emancipation, Solidarity and Equality of Women, Proactive and Reactive Transparency for 2015, (Skopje: ESEM, 2016), [available at:, in Macedonian]. ]

Did it open government?

Access to information: Marginal

Proactive transparency was one of the key priorities identified by civil society in all IRM reviews. Commitments under this cluster all aimed to promote the release of information and datasets proactively, thereby curbing the secretive culture in government.

These commitments changed government practice on proactive transparency only marginally, with the introduction of the new open data portal. There are still serious concerns about the government’s willingness to open information.[Note 52: IRM personal interview with key civil society experts in the area: Qendresa Sulejmani, Marija Sazdov, German Filkov, and Nada Naumovska, September 2016.] Civil society added that data and information were not collected in a timely way or updated, and that the formats in which they are stored limited the usability of such information. Serious efforts are needed to improve the quality and scope of government-held information. Indeed, the government has accepted this issue, and the new OGP action plan contains a measure to ensure the proper cataloguing and recording of data collected and stored by government bodies.[Note 53: OGP National Action Plan, Measure 2.4, 21, 3rd. ]

Carried forward?

None but the commitment to strengthen the proactive release of information were carried forward. However, the government stated in its end of term self-assessment that all the activities would continue as competences of the relevant institutions, due to statutory obligations guaranteed by law. Taking into consideration that the legal framework existed before Macedonia joined OGP, but did not guarantee implementation, pushing for compliance in the next action plan is important. 


Open Government Partnership