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Mongolia Action Plan Review 2023–2027

Mongolia’s fifth action plan intends to pass promising legislation on extractive transparency and media freedom. It also aims to support participatory evaluation of government policies and services. Its commitments could go further to take advantage of the new four-year implementation period. Development of the action plan significantly strengthened government-civil society collaboration on OGP, despite gaps in financial and high-level political support.

Mongolia’s fifth action plan is its first to span a four-year implementation period (December 2023–December 2027). All nine of its commitments continue reforms in policy areas from previous action plans, designed with clearer objectives and milestones. During development of the action plan, Mongolia continued to meet the OGP minimum requirements for co-creation. Mongolia’s OGP multistakeholder forum decided to undertake a four-year action plan to increase engagement and impact from the OGP platform, with quarterly and biannual reporting cycles to monitor implementation progress. Prior to the co-creation process, government and civil society leaders had emphasized the need to strengthen the impact of Mongolia’s OGP action plans and the level of collaboration during implementation, which had fallen short of expectation in the past.[1]

Overall, four of the commitments undertake promising reforms. Two have substantial potential for results—Commitments 1 and 4 carry forward attempts to strengthen legislation on extractive sector transparency and press freedom from previous action plans. To complement legislative actions, implementers could consider further non-legislative measures as well. Commitments 8 and 9 are a cluster aimed at improving participatory evaluation of government policies and services. While this would be a positive step for participation, the cluster’s potential for results could be strengthened by measures to ensure sustainability. As for the remainder of the action plan, Commitments 3, 6, and 7 carry modest potential for results to enhance civil society transparency, improve the inclusion of persons with disabilities, and mainstream open-data culture. Commitment 2 on freedom of information and Commitment 5 on fiscal transparency have unclear potential for results. Despite targeting the important policy areas, Commitment 2 repeats other commitments’ milestones and Commitment 5 does not plan for significant improvements to existing practices. The action plan’s ambition does not fully reflect the advantage that comes with a longer implementation timeframe. Crucially, some commitments do not have milestones beyond 2025.

These commitments were developed over a two-month co-creation period, led for the first time by the National Committee for Human Rights (NatComHR). Responding to civil society leaders’ calls for a formal multistakeholder space for dialogue, NatComHR held an open call for stakeholders to join the multistakeholder forum.[2] In November 2023, a working group comprising of 28 government representatives and 24 non-government representatives was mandated to develop the action plan by Chief Cabinet Secretariat Order No. 99. Representatives were concentrated in Ulaanbaatar and meetings took place online. The working group discussed 10 commitment proposals drawn from past commitments that had not been fully completed, and four additional proposals suggested by an online questionnaire. Following a public discussion, the working group agreed on 10 proposals for further deliberation. After considering comments from 20 government representatives and 30 non-government representatives, the working group finalized nine commitments for inclusion in the action plan and received the Chief Cabinet Secretariat’s approval with the issuance of Order No. 120 on 27 December 2023. Of these nine commitments, four (1, 3, 4, and 7) were proposed by civil society stakeholders, three (6, 8, and 9) were proposed by government stakeholders, and two (2 and 5) were jointly proposed. Proposals that were not included in the action plan aimed to reform environmental and waste management, public procurement, access to justice, and business and human rights.[3]

NatComHR significantly improved the co-creation process, taking a major step forward for Mongolia’s OGP platform despite constraints in financial and high-level political support. NatComHR followed the available guidelines and IRM recommendations closely in designing the co-creation agenda,[4] compared to previous cycles which at times lacked effective dialogue,[5] government leadership,[6] or transparent documentation.[7] NatComHR, comprised of only two full-time staff, said they had to be creative in leading co-creation without any dedicated budget or support staff—for example, prioritizing free-of-cost online engagement and scheduling co-creation meetings alongside other budgeted activities.[8] NatComHR also took the initiative to improve the transparency of the co-creation process. It uploaded co-creation meetings and a brief OGP introductory video to its official YouTube channel.[9] The practice of publishing updates on the national OGP website immediately after each co-creation activity in both English and Mongolian provided thorough access to information, including meeting notes, video recordings, consultation notices, lists of participants, and chronological versions of the draft action plans.[10] Long-time civil society participants in Mongolia’s action plans found that the co-creation process created a constructive environment for the working group, offered equal opportunities for stakeholders to collaborate, and was more informative and engaging than previous cycles.[11]

Ahead of the 2024 parliamentary election and the 2027 presidential election, it is imperative that NatComHR and the working group are equipped with sufficient resources to ensure successful action plan implementation. Given that this is Mongolia’s first four-year plan, the IRM also recommends considering an amendment process to strengthen the commitments’ potential for results. This is permitted within one year of the action plan’s submission[12] or during the action plan’s refresh period at its halfway point.[13] The amendments could help raise the ambition level of existing commitments or introduce new ones to the action plan.

Promising Commitments in Mongolia’s 2023–2027 Action Plan

The following review looks at the four commitments that the IRM identified as having the potential to realize the most promising results. Promising commitments address a policy area that is important to stakeholders or the national context. They must be verifiable, have a relevant open government lens, and have modest or substantial potential for results. This review also provides an analysis of challenges, opportunities, and recommendations to contribute to the learning and implementation process of this action plan.

Table 1. Promising commitments

Promising Commitments
1. Advancing Extractive Industry Transparency: Driven by efforts to pass the Extractive Industry Transparency Bill into law, this commitment aims to sustain political commitment and mobilize resources to establish an integrated industry database, safeguard civic participation measures, embed corporate liability, and ensure budget allocation to support reforms.
4. Protecting Media Freedom: This commitment seeks to amend the existing Laws on Official and State Secrets, Media Freedom, Whistleblowers, and Communications to strengthen press freedom and enhance journalistic integrity. An assessment of human rights protection will identify gaps in the protection of civil and political rights at the subnational level.
8 and 9. Participatory Evaluation of Government Policies and Services: This cluster of commitments plans to intensify citizens’ satisfaction surveys and use the results to improve the effectiveness of government policies and actions through a multistakeholder approach.

[1] Bolorsaikhan Badamsambuu and Nominchimeg Davaanyam (National Committee for Human Rights), correspondence with IRM researcher, 11 Mar. 2024.

[2] National Committee for Human Rights, “Invitation to participate in Open Government Partnership fifth national plan development,” (15 Sep. 2023), https://irgen-tur.mn/mn/blog/ogp/single/220.

[3] Bolorsaikhan Badamsambuu and Nominchimeg Davaanyam (National Committee for Human Rights), interview by IRM researcher, 5 Feb. 2024, and correspondence with IRM researcher, 2 Feb. 2024 & 11 Mar. 2024.

[4] National Committee for Human Rights, “Бидний тухай” [about us] (accessed 5 May 2024), http://irgen-tur.mn/mn/blog/ogp.

[5] Open Government Partnership, “IRM Design Report: Mongolia 2019–2021” (3 Nov. 2021), https://www.opengovpartnership.org/documents/mongolia-design-report-2019-2021.

[6] Open Government Partnership, “IRM Action Plan Review: Mongolia 2021–2023” (21 Jul. 2022), https://www.opengovpartnership.org/documents/mongolia-action-plan-review-2021-2023.

[7] Open Government Partnership, “IRM Progress Report: Mongolia 2016–2018,” Open Government Partnership, 18 Sep. 2018), https://www.opengovpartnership.org/documents/mongolia-mid-term-report-2016-2018-year-1.

[8] Badamsambuu and Davaanyam, interview.

[9] National Committee for Human Rights, “Open Government Partnership Playlist” (YouTube, last updated 6 Feb. 2024), https://www.youtube.com/playlist?list=PL9fK4h0Z5-gGLocqBzSQg3QJSOIofbfwL.

[10] National Committee for Human Rights, “НЭЭЛТТЭЙ ЗАСГИЙН ТҮНШЛЭЛ” [Open Government Partnerships] [news webpage], (accessed 5 May 2024), http://irgen-tur.mn/mn/blog/ogp/news.

[11] Tsolmon Shar (EITI National Council), correspondence with IRM researcher, 12 Mar. 2024; Erdenechimeg Dashdorj (Open Society Forum Mongolia), correspondence with IRM researcher, 15 Mar. 2024; Anonymous civil society stakeholder 1, interview by IRM researcher, 18 Mar. 2024.

[12] Open Government Partnership, OGP National Handbook: Rules & Guidance for Participants v6 (Mar. 2024), https://www.opengovpartnership.org/documents/ogp-national-handbook-rules-and-guidance-for-participants-2022.

[13] The refresh period is an opportunity for stakeholders to reflect on the implementation of a four-year action plan, assess next steps, and determine a way forward to ensure ambition and results.

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