Following its competencies, the Agency for the Protection of the Right to Free Access to Public Information monitored 88 holders of information, i.e. the websites of municipalities, the Community of Local Self-Government Units, and the Centers for the Development of Planning Regions, that were published the list of holders of information on the Agency’s website. 

The monitoring took place between July 1st and July 20th, 2021. According to Article 10 of the Law on Free Access to Public Information, the Department of Cooperation and Analysis was in charge of monitoring the complete publication of documents and information that information holders must publish on their websites.

Proactively published information of the holders should be easily accessible and understandable, usable, relevant to citizens and regularly updated. Information is a prerequisite for a responsible government and a basis for democratic processes. To this end, the information about the holders’ work enables citizens to adequately draw conclusions and participate in decision-making on issues of interest to them. Thus, transparency and access to public information are inseparable instruments in the fight against corruption.

It should be emphasized that the web pages of the monitored owners are updated according to their activities, and they serve as the first point of contact for citizens and the services they provide. In most of the monitored web pages, it is noticeable that the information holders still need to publish the data about their competencies. At the same time, they still need to systematize the information following Article 10 of the Law on FAPI.

Furthermore, we should highlight that unsystematized information causes confusion among citizens for easy access to the information they need and is in accordance with the legal obligation for transparency of the holders of public information. Therefore, we urge the municipal authorities to make the information available to citizens in as few as three clicks. “Informed citizens, satisfied citizens” is the maxim for transparent municipal government.

According to the established methodology and in compliance with Article 10 of the Law, a check was carried out to see whether the monitored holders have published all 22 categories of information that they are obliged to publish on their websites and whether the published information is complete and up-to-date. In this regard, each type of thoroughly and updated published information was evaluated with a score of 1, each partial publication of the required information was evaluated with a score of 0.5, and each unpublished (or non-transparently published) information was evaluated with 0 points.

The degree of fulfilment of the legal obligation for their active transparency was graded based on the total number of points that the monitored holders received concerning the published necessary documents and information following Article 10 of the Law, as follows: holders with a very low level of transparency who have between 0 and 6 points, holders with a low level between 7 and 10 points, holders with a medium level between 10 and 14 points, and holders with a high level between 10 and 14 points.

At the same time, it was determined that eight holders have a high level of transparency concerning published information, 39 have a medium level of transparency, 24 have a low level, and 17 have a very low level of compliance in terms of active transparency.

According to the monitoring, the municipality of Valandovo has 20 points out of a possible 22 points under Article 10 of the Law on FAPI, followed by the municipalities of Demir Hisar and Kochani, each with 19 points. The municipalities of Valandovo and Demir Hisar are good examples of municipalities that efficiently comply with Article 10. They have systematized the 22 required categories as follows:

By singling out the web pages of the two mentioned municipalities, we want to point out to the other municipal authorities to arrange the active transparency of their web pages following the examples of these owners, which will bring their operations closer to the citizens and also increase their transparency and accountability.

While conducting the monitoring, the Agency determined that the active transparency among the holders is still at a level that requires the municipalities to improve their proactivity towards the citizens and the information they publish and to place it in a separate banner/link under the LIST OF INFORMATION title, thus making it accessible to applicants and thereby reducing the number of requests for free access to public information.

In the future, the trainings that the Agency regularly organizes for officials with information holders will continue to emphasize active transparency and consistent application of Article 10 of the Law on Free Access to Public Information because, in this way, the holders help the citizens to better understand the functioning of the institutions, their rights and obligations, how they can influence the making of decisions that are reflected on their daily living and work, as well as to make it easier for them to access the services offered by the institutions under the jurisdiction of the local self-government.


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