United Kingdom Action Plan Review 2023-2025

The UK’s sixth action planAction plans are at the core of a government’s participation in OGP. They are the product of a co-creation process in which government and civil society jointly develop commitments to open governmen... includes promising commitments on open contractingA transparent procurement process, known as open contracting, increases competition, improves public service delivery, and ensures governments better value for their money. Technical specifications: C... More and aidMore and better information about aid helps partner countries and donor institutions plan and manage aid resources more effectively, parliaments and civil society to hold governments accountable for t... transparencyAccording to OGP’s Articles of Governance, transparency occurs when “government-held information (including on activities and decisions) is open, comprehensive, timely, freely available to the pub... More, building on efforts from previous action plans. Improvements in civil society-government relations helped restore the OGP process in the UK. Stakeholders could build on this momentum in the next action plan by addressing priority policy areas not covered in the sixth action plan, such as digital governanceAs evolving technologies present new opportunities for governments and citizens to advance openness and accountability, OGP participating governments are working to create policies that deal with the ... More, freedom of information, beneficial ownershipDisclosing beneficial owners — those who ultimately control or profit from a business — is essential for combating corruption, stemming illicit financial flows, and fighting tax evasion. Technical... More, open justiceAn open, independent, and impartial justice system serves as a foundation for better access to justice by fulfilling all people’s civil liberties and allowing individuals to more effectively protect..., and government transparency.

The UK’s sixth action plan (2023-2025) has four commitments on open contracting, aid transparency, civic society engagement in anti-corruption measures, and transparency and inclusiveness of the UN Convention Against Corruption (UNCAC) review mechanism.^[1] Commitment 1 on open contracting supports the implementation of the Procurement Act, expected to take effect in 2024. It involves establishing a new platform for data throughout the contracting process and passing secondary legislation to support the Procurement Act.[2] CommitmentOGP commitments are promises for reform co-created by governments and civil society and submitted as part of an action plan. Commitments typically include a description of the problem, concrete action... 2 aims to make aid data available in a timely manner across all Official Development Assistance (ODA) departments, engaging civil society. It also aims to maintain momentum on quality and timeliness of data publishing following a temporary pause in publication following the merger of the Department for International Development and the Foreign and Commonwealth Office into the Foreign, Commonwealth and Development Office. The other commitments, while verifiable, lack concrete activities that would allow detailed analysis of their potential for results. For example, Commitment 3 includes civil society attendance at UNCAC events, but the influence civil society will have on anti-corruption efforts at UNCAC are unclear.

The Central Digital and Data Office (CDDO), which is part of the Cabinet Office, coordinated the development of the action plan. Civil society participation continued to be coordinated by the UK Open Government Civil Society Network (UK OGN). The multi-stakeholder forum (MSF) met quarterly to oversee the development of the action plan.^[3] The MSF comprised civil servants, members of the steering committee of the UK OGN, and subject matter specialists or network leaders.^[4] At each MSF meeting, there were between 30-50 participants.^[5] In February 2021, the UK was put under Procedural Review for acting contrary to the process for three action plans.^[6] However, for this action plan, the UK provided reasoned responses to stakeholder feedback, an improvement from the co-creation processCollaboration between government, civil society and other stakeholders (e.g., citizens, academics, private sector) is at the heart of the OGP process. Participating governments must ensure that a dive... of the previous action plan.

Civil society and government stakeholders acknowledged that the co-creation process for this action plan was better organised compared to previous action plans.^[7] According to the OGN chair, the quality of discussions between civil society and the government improved, and government partners were more engaged and informed throughout the process than in the previous co-creation process.^[8] The Parliamentary Secretary for the Cabinet Office, Alex Burghart MP, participated in the June 2023 MSF meeting, where stakeholders selected the commitments to take forward.^[9] The minister’s presence at this juncture underscored the government’s dedication to transparency and collaboration and signalled to civil society that decision-makers were fully briefed on stakeholder perspectives, nurturing a more informed decision-making process.^[10]

Despite a robust co-creation process, the action plan’s scope is limited. This was attributed primarily to resource constraints and insufficient time for more comprehensive outreach to stakeholder groups.^[11] The voluntary nature of stakeholder involvement, combined with limited resources and time constraints limited the opportunity to broaden participation. Effectively engaging in close and candid collaboration during co-creation sometimes proved challenging in these circumstances, but this was widely achieved with additional support were needed.^[12]

The co-creation process also saw discussions around topics with strong demand for action, such as digital governance, freedom of information, beneficial ownership, open justice and government transparency.^[13] Ultimately, stakeholders deemed these topics untimely for inclusion in this action plan, but they are earmarked for consideration in the seventh action plan. Beneficial ownership was not included due to the inability to develop clear objectives within the allotted timeframe.^[14] The IRM recommends amending the action plan to incorporate a commitment on beneficial ownership transparency, potentially combining it with the work on anti-corruption. In December 2023, the UK government put out a public consultation on proposals to make information on trusts and their beneficial owners, in the context of land ownership, more publicly available.[15] A commitment on the topic could focus on incorporating the views from the consultation, and specific action to improve the transparency of information on trusts holding lands. Additionally, potential commitments could encourage greater transparency across Crown Dependencies and British Overseas Territories in beneficial ownership to ensure consistency and transparency across all jurisdictions under the British Crown. This would be timely, given that many of the British Overseas Territories, as of December 2023, appear to be following the direction of the European Court of Justice and adopting the ‘legitimate interest test’ approach instead of implementing publicly accessible beneficial ownership registers.[16]

Promising Commitments in the United Kingdom’s 2023-2025 Action Plan

The following review looks at the two commitments that the IRM identified as having the potential to realise 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

[1] Open Government PartnershipThe Open Government Partnership (OGP) is a multi-stakeholder initiative focused on improving government transparency, ensuring opportunities for citizen participation in public matters, and strengthen... More, UK Open Government Sixth National Action Plan 2024-2025,

https://www.gov.uk/government/publications/uk-national-action-plan-for-open-government-2024-2025/uk-national-action-plan-for-open-government-2024-2025

[2] The secondary legislation was passed on 22 May 2024.

[3] Matthew Donnelly and Ben Gittins (Cabinet Office), interview by the IRM, 25 March 2024.

[4] UK Open Government Network website, https://opengovernment.org.uk/nap6/

[5] Kevin Keith, interview by the IRM, 22 February 2024.

[6] Resolution of the Criteria & Standards Subcommittee regarding the Participation Status of the United Kingdom in OGP, https://www.opengovpartnership.org/wp-content/uploads/2022/12/UK-Procedural-Review-Resolution-December-2022-CS-approved-Dec-20-2022.pdf

[7] Kevin Keith, interview by the IRM, 22 February 2024; Matthew Donnelly and Ben Gittins (Cabinet Office), interview by the IRM, 25 March 2024.

[8] Kevin Keith, interview by the IRM, 22 February 2024.

[9] Kevin Keith, interview by the IRM, 22 February 2024; Matthew Donnelly and Ben Gittins (Cabinet Office), interview by the IRM, 25 March 2024.

[10] Kevin Keith, interview by the IRM, 22 February 2024.

[11] Matthew Donnelly and Ben Gittins (Cabinet Office), interview by the IRM, 25 March 2024.

[12] Matthew Donnelly and Ben Gittins (Cabinet Office), interview by the IRM, 25 March 2024.

[13] Readout from the UK Multi-Stakeholder Forum on 22 June 2023, https://opengovernment.org.uk/2023/07/19/6925/

[14] Matthew Donnelly and Ben Gittins (Cabinet Office), interview by the IRM, 25 March 2024.

[15] UK Government, Transparency of land ownership involving trusts consultation, https://www.gov.uk/government/consultations/transparency-of-land-ownership-involving-trusts-consultation

[16] Government of the Virgin Islands, Position on publicly accessible registers of beneficial ownership, 8 December 2023,