Proactive disclosure

📋 Proactive disclosure: do public administrations publish what the law requires of them?

Since 2014, the Transparency Law 19/2013 has required every public administration to publish on its own initiative, without anyone asking, a list of information on its transparency portal: who is in charge and how much they earn, what rules it is preparing, what contracts and grants it awards, its budgets and accounts, its assets. This is known as proactive disclosure (publicidad activa). This page brings together the official assessments that show, entity by entity, to what extent the law is complied with.

What the law requires

Law 19/2013 (arts. 5 to 8) groups the obligations into three blocks, and the regional transparency laws add others for their administrations and municipal councils:

• Institutional, organisational and planning information: functions, regulations, organisation chart, officials and their career history, plans and programmes with their degree of completion.
• Information of legal relevance: guidelines and instructions, preliminary draft bills and draft regulations, reports and memoranda from the rule-making files.
• Economic, budgetary and statistical information: contracts (including minor contracts), agreements, commissions to in-house entities, grants and aid, budgets and their execution, accounts and audit reports, pay of senior officials, compatibility of posts, property assets and statistics on the quality of services.

The information must be clear, structured, up to date and reusable (art. 5). Repeated failure to meet these obligations is a serious infringement under national law (art. 9.3), but in practice penalties are exceptional: the oversight bodies recommend and assess; they do not fine.

Who assesses and what they publish

There are also civil society rankings (Dyntra, the Infoparticipa Map of the Autonomous University of Barcelona, the former indices of Transparency International Spain). They are not used here: they are not official sources and we have not verified that their licence allows the data to be reused.

General State Administration

Every year the CTBG assesses the General State Administration's Transparency Portal. For each obligation, the ICIO measures whether the information is published and with what quality (form, update date, accessibility, reusability).

All five assessments relate to governments of Pedro Sánchez, so they do not allow parties to be compared in central government. The CTBG also separately assesses hundreds of bodies, companies and foundations of the national public sector every year; their scores are in individual reports and have not yet been incorporated.

Autonomous communities and municipal councils assessed by the CTBG

The communities that did not create their own oversight body signed an agreement for the CTBG to monitor their transparency. In 2020 the CTBG assessed their portals and in 2021 it reviewed whether they had applied its recommendations.

All of them improved after the recommendations. With only eight communities, governed by four different parties, comparing parties makes no sense: any difference could be down to a single community.

The municipal councils assessed by the CTBG are few and do not form a representative sample (the Council chose them). Even so, they show how far a large council can be from compliance: 5 of 11 were still below 50 % in the 2021 review.

Canary Islands: the entire public sector, entity by entity

The Canary Islands are the only community that publishes every year and as open data the score of all its administrations. The Transparency Commissioner sends a questionnaire on the obligations of the Canary Islands law (more demanding than the national one), checks the answers against the portals and calculates the Canary Islands Transparency Index (0 to 10). An entity that does not complete the assessment is listed as non-compliant.

The last two assessments are not calendar years: «2022/23» covers 2022 and the first half of 2023; «2023/24», the second half of 2023 and 2024. The score is shown out of 100 to compare it with the chart's scale (7.5 out of 10 = 75).

The improvement is clear: the average score of municipal councils rose from 3.1 in the first assessment to 8.9 in the latest. Part of the rise reflects entities learning how to answer the questionnaire, and many are already at the maximum, so high scores do little to distinguish between them.

Municipal councils, 2025

The colour scale starts at 50: anything below that appears in red. A municipality in grey did not submit to the assessment.

Government of the Canary Islands and island councils

Island councils (cabildos) are not attributed to a party: SpainFacts does not yet have an official register of their presidents.

Public companies, bodies and foundations

Non-compliance is highest not in the administrations themselves but in their dependent entities: public companies, foundations, consortia and public-law corporations, which are also bound by the law.

By party

The comparison is only possible with the Canary Islands municipal councils: there are 88 of them, all are assessed, with the same method, since 2016. For each council and assessment, the expected score is calculated: the average of Canary Islands councils of the same size (under 5,000, 5,000 to 20,000 and over 20,000 inhabitants) in that same assessment. The average score of the councils governed by each party is then compared with its expected score.

Only parties with at least 20 assessments; councils that did not submit to the assessment have no score and are not included in the calculation. The confidence interval is calculated with the number of distinct municipalities, not assessments, because the scores of the same council in consecutive years are not independent. «Sin detalle en la fuente» (no detail in the source) groups mayoralties elected on lists that the official register labels generically; «Independientes y locales» (independents and local parties), voter associations. A difference between parties does not prove it is due to the party: staffing, technical resources, the island and the person in charge all play a part.

For the autonomous communities and central government there is not a large enough sample: a single assessment per community and year, and in the case of the State a single government throughout the period assessed.

What is missing

• There is no uniform assessment for the whole of Spain. Each oversight body assesses its own remit with its own method: the score of a Canary Islands council (ITCanarias) and that of a Cantabrian one (CTBG ICIO) cannot be compared.
• Most regional bodies do not publish scores per entity as open data. Murcia, Catalonia, Andalusia, Castile and León and others publish annual reports and documents in PDF, sometimes with the scores only in charts. If any of them publishes its results per entity in a reusable format, they will be added.
• Spain's more than 8,100 municipal councils are not assessed systematically, except in the Canary Islands. The CTBG assessed 11 in 2020-2021.
• The national public sector (bodies, companies and foundations) does have a score per entity in the CTBG reports, but in individual documents. In 2025 the CTBG assessed 225 of these entities, with an average ICIO of only 38.9 % (CTBG press release). This is the next feasible extension.
• The assessments measure whether the information is published and how, not whether its content is accurate or complete.

Methodology and sources

• Council of Transparency and Good Governance – Assessment: Mandatory Information Compliance Index (ICIO) of the MESTA methodology, read from the text of each final report (.docx): General State Administration Transparency Portal (2021-2025), autonomous communities and cities with an agreement (2020 assessment and 2021 review) and their assessed municipal councils. The CTBG reviews each portal directly and scores, for each obligation, whether the content is published and its quality attributes (form, updating, accessibility, reusability). Data source: Council of Transparency and Good Governance (reuse under Law 37/2007).
• Canary Islands Transparency Commissioner – Scores: master table of public sector scores of the Canary Islands Transparency Index (XLSX, CC BY 4.0), since the 2016 assessment. It combines compliance with mandatory information, the quality of the web platform and voluntary transparency (methodology). The entity fills in a questionnaire and the Commissioner verifies it. It is shown out of 100 (score times 10) only to plot it alongside the ICIO; the two scales are not equivalent.
• Municipalities: the Commissioner's names are matched to the INE code by name (six with a different form, by hand). Population from the INE municipal register for the year assessed.
• Attribution to parties: for municipal councils, the mayor in office at the end of the period assessed according to the register of mayors of the Ministry of Territorial Policy (for the «2022/23» assessment, 1 June 2023, before the councils formed after the May elections); for communities and the State, the president or prime minister in office on 31 December of the year assessed (ITCanarias) or on 30 June of the assessment year (CTBG). Parties are grouped into political families.
• Legal obligations: arts. 5 to 9 of Law 19/2013 on transparency, access to public information and good governance; in the Canary Islands, Law 12/2014 on transparency and access to public information.

Data updated 7 minutes ago