Research and analysis

Freedom of information: international comparisons

This document provides information about comparable access to information procedures in other countries.



This document has been prepared by the Secretariat to the Independent Commission on Freedom of Information at the request of the Commission’s Chair. It covers:

  • how other countries protect collective cabinet agreement, and sensitive policy advice within the context of their access to information regimes
  • whether other countries have a power similar to the ministerial override

It looks at countries that have comparable Westminster style constitutions: Australia, Canada, the Republic of Ireland, and New Zealand (the Westminster countries). It also includes Denmark, France, Germany, Spain and the USA.

Published 2 December 2015