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Publishing Budget Law (RS0028)



Action Plan: Serbia Action Plan 2018-2020

Action Plan Cycle: 2018

Status: Active


Lead Institution: Ministry of Finance

Support Institution(s): NA

Policy Areas

E-Government, Fiscal Openness, Publication of Budget/Fiscal Information, Regulatory Governance

IRM Review

IRM Report: Serbia Design Report 2018-2020

Starred: Pending IRM Review

Early Results: Pending IRM Review

Design i

Verifiable: Yes

Relevant to OGP Values: Access to Information

Potential Impact:

Implementation i



COMMITMENT 1: Publishing of the Law on Budget of the Republic of Serbia in a machinereadable format
Q4 2018 - Q1 2019
Lead implementing agency Ministry of Finance
Description of Commitment
Problem addressed by the
The budget of the Republic of Serbia is not published in a
machine-readable format.
Main objective The Ministry of Finance will also publish the Law on Budget
of the Republic of Serbia in WORD and EXCEL formats, in
addition to the existing presentation in PDF format.
How will this commitment
contribute to problem solving?
The Law on Budget will be published in WORD and EXCEL
formats on the official website of the Ministry of Finance.
This would facilitate access to the content of the Law on
Budget for the general public, in accordance with the principle
of state administration transparency, thus simplifying its
downloading and electronic processing for subsequent
This would improve interpretation of publicly available data
and consequently facilitate the use of such data.
The way in which this commitment is
relevant to further advancing OGP
Publishing of the budget in a machine-readable format is fully
compliant with the open government principles proclaimed by
the Open Government Partnership. Publishing data in a
machine-readable format would improve availability of data.
Additional information Implementation of this commitment does not require
additional budget funds.
Activity with a verifiable deliverable
and completion date
Start Date: End Date:
1. Law on Budget published also in a
machine-readable format on the
official website of the Ministry of
After the adoption of the Law
on Budget of the Republic of
Serbia for 2019
After the adoption of the
Law on Budget of the
Republic of Serbia for 2019
Contact information
Name of a responsible person in the
implementing agency
Branislav Stipanović, Head of the Group for IT Support to
Title, Department Budget Sector
Email and phone number
Phone: 3642 915

IRM Midterm Status Summary

1. Publishing Budget Law in a machine-readable format

Language of the commitment as it appears in the action plan:

Title: Publishing of the Law on Budget of the Republic of Serbia in a machine-readable format

The budget of the Republic of Serbia is not published in a machine-readable format.

The Ministry of Finance will also publish the Law on Budget of the Republic of Serbia in WORD and EXCEL formats, in addition to the existing presentation in PDF format.

For full commitment text, please refer to the National Action Plan at

Start Date: Q4 2018

End Date: Q1 2019

Context and Objectives

Serbia has a low level of budgetary data transparency, with few opportunities for citizen engagement in the budget process. The country scored 43% on budget openness in the Open Budget Index, [1] and the state budget is not openly licensed in a machine-readable format. [2] Poor oversight by the legislature exacerbates the problem, as the Budget Law has been adopted without purposeful parliamentary debate for two consecutive years due to obstruction of the debate procedure. [3]

Despite some positive developments, the problem of accessibility and readability of budget data remains. For example, although the Ministry of Finance (MoF) published a simplified citizens’ budget for 2018, [4] alongside some limited financial data in .xlsx formats, its analysis requires days of copying and comparing several different documents manually. [5]

The commitment’s objective is to facilitate access to the Budget Law of Serbia, simplify data processing, and reuse and enable its interpretation by the public. To that end, the government committed to publish the Budget Law in two additional formats (.docx and .xlsx) on the MoF web page. Though the commitment describes precise actions to be taken and is verifiable, it is unclear from the text of the commitment whether the data will be part of the official government Open Data Portal, [6] in line with the recently enforced Law on the eGovernment, [7] considering that thus far, the MoF has not had any datasets open on this portal.

The commitment is relevant for increasing opportunities to access and (re)use of data. However, if fully implemented as designed, this commitment would have a minor impact on changing the current state of budgetary openness in the country. On the positive side, it would proactively enable experts to analyse, interpret, and visualize budget data. [8] If implemented successfully, the commitment can also possibly motivate local administrations to open their budgets and also publish open data on budget expenditures. [9]

At the same time, this commitment has a negligible scope compared with what is needed for alignment with the leading world trends on accessibility of budget data. [10] Experts consulted by the IRM researchers believe that this commitment represents a minimum standard of data availability. [11] According to one CSO representative, the commitment is insufficient to achieve budget transparency, as it does not specifically apply to the budget execution but only to funds approved by the law. [12] Other experts note that the government proposed Microsoft formats that are not entirely open and free such as CSV.

Overall, the IRM researchers assess that publishing the Budget Law in only one recognized machine-readable format demonstrates a lack of ambition to reach the international standards in budget data openness. The commitment represents a small step toward increasing the supply of data but without attempting to take a holistic view of the potentials of data reuse and the necessary additional efforts to enable reuse. The IRM researchers could not obtain the official position on these issues, as the responsible body, the Ministry of Finance, did not accept the request for interview.

Next steps

The IRM researcher considers this commitment a first step for furthering budget data openness through the subsequent OGP cycles. As stated by Transparency Serbia, a more ambitious commitment on this theme would not only motivate the knowledge economy but also help the government receive valuable feedback, which can be used to improve data quality, better understand user needs, and better formulate and implement public policies. [13] 

IRM researchers recommend the following actions be taken to improve the commitment design in future action plans:

  • To increase specificity, the MoF should commit to and explicitly communicate the commitment to publish data on the central government Open Data Portal, conforming with the Law on eGovernment [14] and the Regulation on the Mode of Operation of the Open Data Portal. [15] This way, the data will become centrally available. Compliance with the regulation will mean that the data are up-to-date and available in prescribed open formats.
  • To increase the ambition and scope:
    • The MoF could increase the diversity of truly open formats available. The Open Data Standards Directory [16] explicitly indicates that DOC(X) does not represent a machine-readable format, in other words, the one that ensures that data can be read and manipulated, without requiring a precise proprietary software, such as XML, RSS feed, CSV, RDF, JSON, TXT, XLS (X), and KML. [17]
    • The OGP Working Group, the MoF, and civil society should include activities that openly encourage budget data (re)use, for instance the visualization of the draft budget law for 2018 and 2019 [18] or the pioneer initiative “Open Budget in Your City” [19] to present information on budget surplus and deficit in a sample of local communities. Additional activities could include organizing hackathons, offering incentives to the data science professionals, and publishing calls for innovative infographics, apps, factsheets, and interactive maps.
    • The MoF could learn from relevant international practices such as the Open Data Standards Directory on how governments could publish budget data.
    • The MoF should publish other documents relevant for fiscal transparency in machine-readable formats. For example, publication of the Law on Final Account of the Budget (which has not been adopted in Serbia for more than a decade) in open format could fill a critical gap. [20] Other documents include:
      • fiscal strategy
      • citizens’ budget
      • monthly budget execution reports
      • mid-year budget execution reports
      • year-end budget execution reports
      • final account of the budget

In addition to these, Transparency Serbia proposed that the following documents be published in open formats:

  • Draft Budget Law
  • Budget Law Proposal
  • Other working documents (tables) created during the budget preparation and execution
  • Data stemming from individual sources of income such as fees, revenues generated from the use of public funds, income from the sale of non-financial assets, income from borrowing and selling of financial assets.
  • Through amendments to the Rules of Procedures of the National Assembly and their proper application, the Members of the Parliament should ensure legal and practical mechanisms that prevent the obstruction of parliamentary debate, especially when deciding about crucial national documents such as the Budget Law.
[1] The Open Budget Survey, Serbia, available at and
[2] Global Open Data Index, Serbia, available at
[3] MPs had 62 points on the agenda for a 5-hour debate. The ruling majority submitted 500 amendments on the two draft laws preceding the Budget Law, additionally limiting the time. Finally, the government submitted the Draft Budget Law, containing hundreds of pages, a few of days before the Parliament session. For more detailed information on this case, please consult: Istinomer, “Crta i Otvoreni parlament: Opet bez sveobuhvatne rasprave o budžetu,” available at 
[4] Ministry of Finance, Citizens budget, available at  
[5] Raša Nedeljkov, CRTA, Panel-discussion “Why data matters,” 6 November 2016,
[7] Article 27 stipulates that the bodies are obligated to publish open data from their scope of work at the Open Data Portal in a way that enables easy search and reuse. The Law on eGovernment, Official Gazette of the Republic of Serbia 27/2018-25.
[8] Focus group with civil society, journalists, and experts, 20 February 2019.
[9] Representatives of a CSO involved in the OGP Working Group, interviewed by IRM researcher, 8 March 2019.
[10] See comparisons between countries on the availability of government budget in a machine-readable format:
[11] Focus group with civil society, journalists, and experts, 20 February 2019.
[12] Representative of a CSO dealing with transparency, interviewed by IRM researcher, 20 February 2019.
[13] Transparency Serbia, Initiative to the Ministry of Finance regarding the publishing of data on preparation and execution of the budget in open data format, which enables comparison and free use, available (in Serbian) at
[14] Official Gazette of the Republic of Serbia 27/2018-25.
[15] Official Gazette of the Republic of Serbia 104/2018-9
[16] Open Data Standards Directory, available at
[17] Open Data Charter, available at
[20] Representative of a CSO monitoring the public finance management in Serbia, interviewed by IRM researcher, 21 February 2019.


  1. Increasing Transparency and Participation in Parliament

    RS0042, 2018, Civic Space

  2. Publishing Budget Law

    RS0028, 2018, E-Government

  3. e-Calendar for Financing Civil Society

    RS0029, 2018, Anti-Corruption

  4. Publish Data on Environmental Protection Funds

    RS0030, 2018, Access to Information

  5. Opening Data for Public Calls for Media Development

    RS0031, 2018, Access to Information

  6. Open Data Reports on CSOs

    RS0032, 2018, Access to Information

  7. Amending Media Registration Bylaws

    RS0033, 2018, E-Government

  8. Assistance with and Monitoring of Adoption of LAP

    RS0034, 2018, Anti-Corruption

  9. Updating of Electoral Roll

    RS0035, 2018, Anti-Corruption

  10. ePaper

    RS0036, 2018, E-Government

  11. e-Notice Board

    RS0037, 2018, E-Government

  12. Improving Proactive Transparency – Information Booklet

    RS0038, 2018, Access to Information

  13. Access to Information Law

    RS0039, 2018, Access to Information

  14. Cooperation with CSOs on Regulations

    RS0040, 2018, Capacity Building

  15. E-Civic Engagement

    RS0041, 2018, E-Government

  16. Develop a Model of Job Description or Part of Job Description of an Officer Responsible for Cooperation with Civil Society in Local Administration

    RS0014, 2016, Capacity Building

  17. Organise Trainings for Public Administration Officers in Connection with the Application of the Guidelines on Inclusion of Civil Society Organisations in the Process of Passing Regulations

    RS0015, 2016, Capacity Building

  18. Organise Trainings for CSO in Connection with Application of the Guidelines on Inclusion of Civil Society Organisations in the Process of Passing Regulations

    RS0016, 2016, Capacity Building

  19. Improve the System for Collecting Initiatives from Citizens and Businesses

    RS0017, 2016, Capacity Building

  20. Introducing Standards for Civic Participation in the Public Policy Management System

    RS0018, 2016, Capacity Building

  21. Improving Proactive Transparency – Information Booklet

    RS0019, 2016, Capacity Building

  22. Amendments to the Law on Free Access to Information of Public Importance

    RS0020, 2016, Access to Information

  23. Development of an Open Data Portal

    RS0021, 2016, Access to Information

  24. Draft a Bylaw Based on the Guidelines for Evaluation of Websites

    RS0022, 2016, Access to Information

  25. Improve the Institute of Public Hearing in the Drafting of Laws

    RS0023, 2016, Legislation & Regulation

  26. Development of a Uniform Methodology for Planning, Monitoring and Performance Evaluation of Programmes and Projects Implemented by Civil Society Organisations and Monitoring the Spending of Allocated Funds

    RS0024, 2016, Capacity Building

  27. Amend the Regulation on Funds to Support Programmes or Missing Amount of Funds for Programmes of Public Interest Implemented by Associations

    RS0025, 2016, Capacity Building

  28. Enactment of a Law on Electronic Documents, Electronic Identification and Trusted Services in Electronic Business

    RS0026, 2016, Capacity Building

  29. Establish a Single Public Register of Administrative Procedures and Other Conditions for Pursuing a Business Activity

    RS0027, 2016, Capacity Building

  30. Transparency in Monitoring Budget Expenditures

    RS0001, 2014, Capacity Building

  31. Law on Financing Political Activities

    RS0002, 2014, Anti-Corruption

  32. Transparent Public Procurement Procedures

    RS0003, 2014, Anti-Corruption

  33. Transparent Financing of Civil Society Organizations

    RS0004, 2014, Civic Space

  34. Extending and Clarifying Responsibilities of the Anti-Corruption Agency

    RS0005, 2014, Anti-Corruption

  35. Whistleblower Protection Trainings and Campaigns

    RS0006, 2014, Anti-Corruption

  36. Draft Law Regulating Inspections in Public Administration

    RS0007, 2014, Anti-Corruption

  37. e-Governmental Portal Awareness and Mobile Application

    RS0008, 2014, E-Government

  38. Starred commitment Public Administration Website Harmonization and Amendments to the Law on Free Access to Information of Public Importance

    RS0009, 2014, Access to Information

  39. New Technologies to Improve Citizen Services

    RS0010, 2014, E-Government

  40. Cooperation with Civil Society Organizations in Public Policymaking

    RS0011, 2014, Civic Space

  41. Citizen Participation in Local Government Affairs

    RS0012, 2014, Public Participation

  42. Civil Society Participation in Monitoring the Public Administration (PAR) Strategy

    RS0013, 2014, Anti-Corruption

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