Policy paper

UK National Action Plan for Open Government 2021-2023 Implementation Self-assessment

Published 4 December 2025

Disclaimers

• This self-assessment relates to a plan implemented under the 2019 to 2022 Johnson, 2022 Truss, and 2022 to 2024 Sunak Conservative governments. 
• The Central Digital and Data Office (CDDO) was the business unit previously responsible for open government policy. This responsibility transferred to the Civil Service Strategy Unit within Cabinet Office in April 2025.

Introduction

The UK’s Fifth National Action Plan for Open Government 2021-2023 (NAP5) was published on 31st January 2022 and implementation ran until 31st December 2023. It set out commitments to promote open government core values of transparency, accountability and public participation. The plan built on the previous four UK National Actions Plans and was coordinated by the Central Data and Digital Office (CDDO), part of Cabinet Office, in partnership with the UK Open Government Civil Society Network (UK OGN). 

The action plan included commitments agreed by civil society and government on five initial key thematic areas: open contracting; open justice; algorithmic transparency and accountability; health; and anti-corruption and international illicit finance. It was amended on 23rd August 2022 to include: aid transparency; diversity and inclusion; freedom of information; and a section on developing local transparency. 

Following the end of the NAP5 implementation period there was a valuable opportunity to undertake a self-assessment with the aim of improving the future UK approach. This self-assessment covers the co-creation of the action plan and its subsequent implementation. It is informed by feedback from all of the meetings of the UK Multi-Stakeholder Forum for Open Government (MSF) held during 2023, as well as the specific NAP5 review session held in January 2024 MSF, and wider feedback from civil society and government outside of the MSF. A key focus of discussion at the January 2024 MSF was the value of sharing experiences and learning ideas to help improve action plan implementation in the future. 

Background

Open government is the simple idea that government and institutions work better for citizens when they are transparent, engaging and accountable. As a founding and current member of the Open Government Partnership (OGP), the UK is committed to the principles outlined in the Open Government Declaration and providing global leadership in promoting this agenda. National Action Plans set out our priorities for improving the openness of government in the UK, developed by representatives of civil society and government on agreed thematic areas through a co-creation process. Devolved Governments in Northern Ireland and Scotland, and the local authority Glasgow City Council developed their own local action plans for open government as members of the OGP Local programme. The Devolved Government in Wales is not a member of OGP Local but developed its own commitments that contribute to the UK effort.

Co-creation

The co-creation of NAP5 was launched in December 2020 and concluded following publication in 2022. The action plan unfolded as a two phase approach: phase 1 concerned the identification of potential thematic areas and phase 2 covered the co-development of draft commitments by civil society-government working groups. A strategically light touch approach was used in pursuit of a shared desire by civil society and government to begin immediate work drafting commitments. NAP5 was developed during the COVID-19 pandemic and as a result all co-creation was completely shifted to virtual engagement.

Action plan development

The initial focus was on identification of potential themes and their feasibility as commitments. A range of thematic areas emerged during the December 2020 MSF: open contracting; open justice; data ethics; health; misinformation; and freedom of information. A further two themes required further consideration: public standards and democracy building; and climate change. A bi-weekly co-creation timetable expected to run through until August 2021 was communicated as part of the April 2021 MSF, which was followed by the creation of short term working groups made up of civil society and government members. Membership of each group involved a diverse range of open government interests, with few well-established stakeholder groups. 

The focus on developing a wide range of commitments under the new conditions created by the pandemic and a lack of resources led to an underemphasis on agreeing a shared expectation between civil society and government, and associated forward planning.  As a result, there was a mismatch in expectations as to the potential outcomes of co-creation, and working groups required significant support from CDDO and central coordinators in the UK OGN. The balance of resources, time and capacity often placed significant demands on the government and members of the UK OGN steering committee to solicit membership, run workshops and produce readouts. As a result, the pace of working groups varied considerably: whilst some demonstrated effective collaboration, others were heavily impacted by personnel changes and variable groups of stakeholders resulting in a drift in the generation of ideas and poor alignment of purpose. 

Finalisation

The UK’s challenges in trying to meet OGP’s minimum participation requirements during co-creation was a strain on civil society-government relations, and this had an impact on the final stages of co-creation. It set the tone for a less constructive conversation and despite civil society-government best efforts to come together on a shared vision for the publication, the final document included substantial changes in its wording, dropping of some commitments, and the addition of some additional outline commitments.

Feedback

Following publication of NAP5, only one MSF was held during 2022 on 22nd June 2022, and some commitments which were not initially included were subsequently amended in August 2022. Correspondence with UK OGN, including ministerial, did occur outside the UK MSF. 

The difficulties encountered in developing and publishing NAP5 were initially explored through the amendment process, which involved revisiting some priority areas that were either changed or removed ahead of publication. This led to the inclusion of three additional commitments. The commitment on aid transparency had initially been excluded as the timeline for developing the 2022 International Development Strategy prevented the inclusion of a separate commitment in the NAP. The commitment on freedom of information focused on establishing an information rights user group as the basis for future collaboration, although further milestones remained undefined.  The commitment on diversity and inclusion was detailed but shortcomings remained in civil society and government ownership and capability to pursue these, despite their inclusion.

A turning point in government and civil society relations was reached at the pre-MSF meeting in December 2022 which created the conditions for re-establishing a steady pace of MSFs during 2023.  Civil society-government engagement has since acknowledged the challenges during the co-creation of NAP5, and the need to develop a stronger approach to the development of NAPs was identified.  As part of this the role and functioning of the UK MSF has been reviewed and gradually evolved, and a greater importance placed on strengthening stakeholder groups to drive the development of draft commitments.  Previously the MSF attempted to have a greater decision-making role in policy itself. The MSF has been revised to be a forum to oversee the process of developing and implementing the NAPs, as well as promoting open government in general, by creating the right conditions for success.

Moving forward: changes made to the development of UK National Action Plan

The lessons from NAP5 co-creation have been used to inform the approach to co-creation of the sixth UK National Action Plan for Open Government 2024-2025 (NAP6), including a distinct public outreach phase, a clear set of criteria for assessing the potential for successful co-creation, and placing detailed policy work to develop commitments with the relevant civil society-government ‘Thematic Stakeholder Groups’, such as the Open Contracting Advisory Group. Moreover, these changes have been designed to alleviate the pressure the process can place on individuals. That strain was visible throughout NAP5, for both civil society and government, and was mitigated more in NAP6.

Monitoring implementation

Monitoring the implementation of NAP5 commitments was initially undertaken by civil society and government stakeholder groups, and the extent of this varied depending on the strengths and weaknesses of these groups.  Progress updates through the MSF resumed at the pre-MSF meeting held in December 2022 (PDF, 196KB) and continued on a quarterly basis at each meeting to improve the transparency of progress in commitment implementation. 

Verbal updates by relevant government and civil society commitment leads provided a counterpoint to each other at each MSF. More substantial written updates on commitment progress were reintroduced in April 2023.  CDDO has coordinated the release of a substantive written assessment provided by relevant government teams at the level of individual milestones. A ‘BRAGG’ assessment - R for Red is blocked, A for Amber is at risk, G for Green is on track, B for Blue is complete, and G for Grey is not started - was used to track progress status. A comprehensive list of UK MSF readouts and slide-decks was previously published on the UK OGN website only. This content can now be accessed on GOV.UK via the UK MSF group page. 

The focus of feedback on NAP monitoring has been on improving the visibility of the reports and streamlining the reporting requirements for efficiency and clarity. Two areas of focus are worth a mention. First, issues with the wording of some commitments with vague or overly prescriptive wording, or milestones with end dates after the end of NAP itself, led in some cases to a lack of clarity and a mismatch in expectations when reporting on progress.  Reporting on milestones due after the end of the NAP itself - or even ‘ongoing’ milestones with no end date - was particularly problematic, and this needs to be avoided in future NAPs.

Second, it has proven difficult to develop the right balance between the role of the MSF in overseeing the implementation of the NAP, the role of thematic stakeholder groups to monitor commitments, and the reporting on commitment areas for other purposes.  It is important to identify the right level and cadence of reporting through the MSF so that it provides assurance as to progress of commitments and healthy civil society-government relations during implementation, whilst not generating excess levels of formal reporting just for the MSF.  This becomes particularly important when attempting to scale the process to support more commitments in the future, and considering how to promote the mainstreaming of open government.

There is joint recognition by civil society and government that revisions are needed to the monitoring of implementation to ensure that the MSF is both sufficiently well-informed and reporting is efficient.

Highlights of progress

Many of the commitments in NAP5 have made substantial progress over the two years of implementation.  This ranges from regularly publishing government procurement data in accordance with the Open Contracting Data Standard (OCDS); progress on the HMCTS Data Strategy and Data save lives strategy; promotion of the Algorithmic Transparency Recording Standard (ATRS) as one of the first initiatives of its kind globally; enhancing transparency to help tackle economic crime; making progress against the delivery of the 2020 UK Aid Transparency Review (PDF, 520KB); and establishing the Information Rights User Group (IRUG).  Limited progress was made on commitments related to diversity and inclusion and local transparency, reflecting the limited civil society and government capability for engaging in these areas.

In parallel with the implementation of commitments in the NAP, there have been wider open government efforts.  These have included improving the processes that support the development and monitoring of UK NAPs to ensure we meet OGP’s minimum participation requirements. Other efforts include developing our approach to regular meetings of the UK Multi-Stakeholder Forum to support candid and constructive discussions, which was key to developing the Sixth National Action Plan for Open Government (NAP6).  At an international level, the UK has been recognised for leadership in beneficial ownership and anti-corruption, as well as in data standards including ATRS, and played a prominent role at the OGP Global Summit 2023.

The UK has invested time and energy in reviewing feedback to improve its processes and approach to the implementation of NAP5 and co-creation of NAP6. This refinement in approach has emerged in consultation with civil society and government participants alike, which called for a clear plan of improvements to tackle gaps in process, the challenge of mismatched expectations, and the visibility of open government efforts outside UK National Action Plans.

Lessons learnt

The review of NAP5 co-creation and implementation has identified some key lessons learnt that should inform future planning for UK National Action Plans for Open Government.

Shared understanding

Successful co-creation and implementation of commitments requires effective relationships amongst all stakeholders so that a clear set of shared expectations can develop. This includes a shared understanding between civil society and government of the capabilities, timelines and constraints they are both under, as well as an appreciation of the different perspectives on these issues. It is critical that commitments are well-formed and clearly worded to ensure those commitments can be effectively implemented and clearly monitored.  To aid people who are new to the process from both civil society and government, it is important to develop induction resources/training and communities of practice to share knowledge and experience, and develop the capability for collaborative working. There is also scope to better define the level and type of support the Open Government Partnership support unit is best able to provide to national members to aid this foundational aspect of collaboration.

Transparent ways of working

Positive engagement during NAP5 implementation illustrated the benefit of a shared civil society-government purpose. It is important that the NAP, and the MSF which oversees it, is transparent and understandable to both those inside and outside of the process. Whilst this transparency has improved during the course of 2023, there was room for improvement.  Part of this improvement was to revisit the terms of reference for the MSF to provide greater clarity of purpose, operation and composition.

Efficient, meaningful and accessible monitoring

Monitoring of progress in delivering NAP commitments needs to be done at a level that can provide assurance to the MSF of progress and the health of civil society and government relations for each commitment. The type and cadence of monitoring must recognise that commitments are often part of a wider workstream in government and reporting to the MSF needs to be efficient, such as by making best use of individual thematic stakeholder groups to retain oversight of the detail. Feedback from civil society and government has identified a shared desire to improve collective responsibility for monitoring progress through thematic stakeholder groups. This is key to enabling the NAP to include a larger number of commitments. On a practical level, monitoring reports should be easy for the non-expert to understand, and reports should include simple formatting to ensure accessibility for assistive technologies.

Potential for greater flexibility

Overall, CDDO has concluded that the current approach to NAPs is insufficient to support the wider promotion of open government and the co-creation principles underpinning the NAP. To realise the full potential of the open government agenda, a more flexible approach to NAPs is needed to cater for a greater range of commitments, and to better integrate the NAP process alongside other government approaches to policy development and implementation.