Source: V PLAN.pdf
Spain´s New 5th Open Government Plan reiterates existing commitments to whistleblower proteciton amid limited reform.
On 6 October 2025, the Spanish Government approved its Fifth Open Government Plan (2025–2029), outlining ten broad commitments on participation, transparency, integrity, digital governance, and public accountability.
Within the Integrity and accountability axis, the Plan announces the creation of a Comprehensive National System for Whistleblower Protection,coordinated by the Independent Authority for Whistleblower Protection, that includes mechanisms for the secure receipt of complaints, legal and psychological support, effective protection measures against retaliation, and guarantees of anonymity. This initiative largely repackages the legal obligations already established under Law 2/2023 as a new commitment, offering continuity rather than reform.
The Government pledges €7.5 million and 64 staff members to the Independent Authority for Whistleblower Protection, up from €5 million and 41 staff members. Yet, in the absence of an approved State Budget, the Authority’s funding continues to depend on the Ministry of Justice, a situation that undermines its independence.
NGO Hay Derecho said: “The text shows deficiencies in essential areas: a lack of progress in the protection of whistleblowers, starting with the insufficient resourcing of the Independent Authority for Whistleblower Protection; the absence of an ambitious reform of the Transparency Law; inadequate measures to address conflicts of interest and revolving doors; and the omission of reforms in high-risk areas of public procurement.
Many participating organisations reported that their input was largely disregarded, reinforcing criticism that the process was more procedural than substantive and that Spain’s open government agenda remains top-down and politically driven rather than genuinely collaborative.”
Background & Context:
Spain’s Open Government Plans are developed within the framework of the Open Government Partnership (OGP), which requires co-creation with civil society. Accordingly, the Fifth Plan was drafted through a participatory process involving public consultations via a multi-stakeholder forum (the so-called Foro de Gobierno Abierto), where NGOs, academics, and citizens were invited to contribute proposals.
Relevant Link to Further Reading:
- Press release: Hay Derecho – 5th Open Government Plan.
- Opinion: Hay Derecho / Germán J. Arenas Arias – On the Global Open Government summit: Promises at the Top, Realities at the Bottom
- Civio Position: Why Civio say NO to the 5th Open Government Plan
- Press: The small print of the 5th Open Government Plan: ‘Recycled” regulations already in the pipeline and “cosmetic” changes according to experts.