11 May 2020

On May 7, 2020 during an online press conference, the Access to Information Programme (AIP) presented the Results from the 2020 AIP audit on institutional web sites.

 The results are available here ◄

The aim of the audit is to evaluate if the executive bodies fulfill their obligations for proactive disclosure of information online under the Access to Public Information Act (APIA) and other legal regulations and to assess how they respond to electronic requests.

In the lack of a public body to coordinate and control the implementation of the APIA, including the obligations for proactive publication of information, the AIP Audit serves as a model publication scheme for public bodies to increase their active transparency.

Audit Methodology

The 2020 audit was performed within the period February 10 - April 15, 2020 by eight researchers from the AIP team. The web sites of 562 executive bodies on a central, regional, and local level, as well as public-law entities and independent state bodies were reviewed and assessed along a checklist of indicators (see below).
Within the audit, 562 electronic requests were filed with the request to provide an updated list for the year 2019 of the categories of information, subject to mandatory publication online concerning the sphere of activity of the respective administration as well as the formats in which it is available. The preparation and publication of this list was established as an obligation with the Article 15a APIA amendments set forth in the end of 2015.
The 2020 transparency level was assessed along a checklist of 109 indicators for the primary budget-managing bodies, 119 indicators for the municipalities, and 95 indicators for the territorial units of the central government bodies and for the secondary budget managing bodies.
The results were sent for feedback to all the audited institutions on April 1, 2020. The AIP considered all received statements and after the two-week deadline, on April 15, 2020, all 77 feedback responses were reflected in the Rating.
The assessment indicators in the checklist are combined in four groups, reflecting:

Availability of institutional, organizational, operative, and contact information under Art. 15, Para 1 of the APIA
Availability and content of the Access to Information Section under Art. 15a, Para 2 of the APIA
The obligation for launching and maintaining an Access to Information section with specific content that aims to facilitate the exercise of the right to information is effective since 2008. The 2015 APIA amendments introduced additional categories for online publication in the ATI section.
Availability of budgets, financial reports, conflict of interest declarations, public procurement information under the Public Finances Act, the Public Procurements Act, the Law on Prevention and Ascertainment of Conflict of Interests
Response to the e-request
As mentioned already, in this year’s audit AIP’s researchers requested the updated list for the year 2019 of the categories of information subject to mandatory publication online, concerning the sphere of activity of the respective administration, as well as the formats in which it is available - a requirement introduced with the 2015 APIA amendments.

2020 Active Transparency Ratings
AIP's internal web based system generates separately the Active Transparency Ratings for the different categories of administrative bodies.
The comparative rating of the institutions indicates the positions up or down in the rating, taking into account the results of each institution from the two previous years.
The web based audit module generates different types of ratings:
Active Transparency Rating of Central Government Bodies
Active Transparency Rating of the Local Government Bodies (265 Municipalities)
Active Transparency Rating of the Regional Governors’ Administrations
Active Transparency of Regional Bodies of Executive Bodies

Also, Ratings of agencies, commissions, independent state bodies; Ratings of the institutions by region; Ratings of the regional offices of the Ministry of Interior, of the Ministry of Environment and Waters, the Ministry of Education, the Ministry of Agriculture, Foods and Forests, etc.
In 2019, the AIP had the web based audit module upgraded which allows for the generation of the Active Transparency Rating of 265 Municipalities.
Another upgrade allowed for the Comparative Ratings to indicate the upward or downward motion in the rating of each institution.

Comparative Data of the Results 2018 – 2020

Comparative results from audits performed by the Access to Information Programme covering 567 in 2018, 564 in 2019, 562 institutional web sites in 2020, prepared by the AIP Executive Director Gergana Jouleva, show the following trends:
Institutional Information - Legal Basis, Functions, Public Services, Information Data Bases and Information Resources
Operational Information - Acts, Development Strategies, Plans, Activities and Activity Reports
Budget and financial transparency. Public Procurements. Integrity Information
Access to Information Sections and its content pursuant to Art. 15 a, Para. 2 of the APIA 
Obligations for proactive disclosure mandatory for Municipalities only
Map Visualizing Results of Budget, Financial Transparency and Integrity of Municipalities 2020

The results from the implementation of the obligations of the 265 municipalities in Bulgaria to proactively publish information on their budgets, financial reports, conflict of interest declarations, public procurements are visualized in the 2020 Budget, Financial Transparency and Integrity Map of Municipalities of Bulgaria.

Responses to the e-requests and information provided

The AIP publishes the answers to the 562 e-requests filed within the audit (in Bulgarian), as well as the provided information.

The web based audit system also allows for following the statistics on the responses and the provision of the requested information (in Bulgarian).

On the base of the audit results, AIP formulates the following recommendations:
• Public bodies to better manage information resources and datasets for improving information provision and enhancing proactive transparency;
• Public bodies to introduce a system for registration and notification of electronic requests;
• Common models to be set and assistance in implementation to be provided by an oversight body;
• Oversight and sanctions for incompliance to be imposed to improve the level of implementation and the proactive publications.


The Access to Information Forum project is implemented with the financial support of Iceland, Liechtenstein and Norway under the EEA Financial Mechanism. 

The main objective of the Access to Information Forum project is to improve the transparency and accountability of public institutions. Click here to visit the project's webpage.