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Active Transparency Rating 2021

12 May 2021 г.

On May 11, 2021 during an online press conference, the Access to Information Programme (AIP) presented the Results from the 2021 audit on institutional web sites.


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 2021 audit was performed within the period March 1 - April 29, 2021 by eight researchers from the AIP team. The web sites of 563 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, 563 electronic requests were filed with the request to provide an updated list for the year 2020 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 2021 transparency level was assessed along a checklist of 99 indicators for the primary budget-managing bodies, 115 indicators for the municipalities, and 90 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 16, 2021. The AIP considered all received statements and after the two-week deadline, on April 29, 2021, all 89 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.





2021 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 2019 – 2021


Comparative results from audits performed by the Access to Information Programme covering 564 in 2019, 562 institutional web sites in 2020, 563 institutional web sites in 2021, 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 2021 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 563 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).








 project is implemented with the financial support of Iceland, Liechtenstein and Norway under the EEA Financial Me

The main objective of the Access to Information Forum project is to improve the transparency and accountability of public institutions.
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