Government Information Quarterly 40 (2023) 101762

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Government Information Quarterly

journal homepage: www.elsevier.com/locate/govinf

Government transparency: Monitoring public policy accumulation and

administrative overload
Rui Pedro Lourenço *
Univ Coimbra, CeBER, Faculty of Economics, Av Dias da Silva 165, 3004-512 Coimbra, Portugal

A R T I C L E I N F O A B S T R A C T

Keywords: Democratic governments maintain their legitimacy by answering demands to solve societal problems, thus
Government transparency continuously adopting and implementing new policies, programs, and administrative rules. One possible
Policy accumulation consequence of this democratic responsiveness is policy accumulation and rule growth, thus overloading
Administrative overload
administrative resources and, ultimately, impairing policy implementation. The aim of this exploratory research
is twofold: first, to analyse the relationship between government transparency and policy accumulation; second,
to develop a government transparency framework aimed to monitor public policy accumulation and one of its
major consequences, administrative overload. To illustrate the proposal and its applicability, the framework was
used to guide the analysis of the Portuguese case, revealing the absence of a comprehensive approach to the
overload problem, and identifying relevant components for a future monitoring system. The framework, and the
analysis it provides, are intended to guide government transparency initiatives which address the public policy
accumulation and administrative overload problem.

1. Introduction The result of this imperative for political responsiveness in developed

Elected governments in democratic (representative) societies
constantly seek to maintain and reinforce their substantive (not just
formal) political legitimacy. To do so, governments need to be respon­
sive to demands for action to solve wicked societal problems (Rittel,
1967). Such problems, like water pollution, digital illiteracy, or gender
inequality, are what we call ‘policy problems’, each one described as an
“unrealized need, value, or opportunity for improvement attainable
through public action.” (Dunn, 2014, p. 5).
The negative impact of these wicked problems pressures govern­
ments to act beyond their regular activities, “associated with the man­
agement of the entire political-administrative system” (Knoepfel,
Larrue, Hill, & Varone, 2011, p. 25), and to define and execute public
policies. Each policy comprises “a series of intentionally coherent de­
cisions or activities taken … with a view to resolving in a targeted
manner a problem that is politically defined as collective in nature”
(Knoepfel et al., 2011, p. 23), and may assume the form of different
policy instruments such as executive orders, court decisions, legislative
acts (Dunn, 2014, p. 43 Table 1), programs (Goodin, Rein, & Moran,
2006), intervention programmes, political-administrative programmes,
or action plans (Knoepfel et al., 2011, p. 28).
democracies is that “the most prominent development in policy output is
not policy change but rather policy accumulation” (Adam, Hurka, Knill,
& Steinebach, 2019, p. 1). Such phenomenon may be defined as a
“continuous addition of new policy elements to existing policy portfolios
without the compensatory reduction of already existing ones.” (Adam,
Steinebach, & Knill, 2018, p. 274) This phenomenon occurs because
there is a growing number of policy issues, policy targets and interde­
pendent policy instruments (Adam et al., 2018), but also because “the
rate of policy production continues to exceed the rate of policy termi­
nation by far” (Adam, Knill, & Fernandez-i-Marín, 2017; Adam et al.,
2018, p. 270).
Policy accumulation may be problematic because an ever-growing
public policy portfolio, with added administrative rules complexity,
could make it more difficult to engage citizens and public officials in
new public policy debates (Adam et al., 2019). But also because policy
accumulation may limit the capacity to manage and implement public
policy itself (due to lack of resources), thus affecting policy effective­
ness, and ultimately undermining the very government legitimacy
responsiveness it was meant to foster (Adam et al., 2019; Bayerlein,
Knill, Limberg, & Steinebach, 2019; Limberg, Steinebach, Bayerlein, &
Knill, 2020). The latter may be better understood as a problem of

* Corresponding author.
E-mail address: ruiloure@fe.uc.pt.

https://doi.org/10.1016/j.giq.2022.101762
Received 11 June 2021; Received in revised form 12 September 2022; Accepted 15 September 2022
Available online 6 October 2022
0740-624X/© 2022 The Author. Published by Elsevier Inc. This is an open access article under the CC BY-NC-ND license (http://creativecommons.org/licenses/by-
nc-nd/4.0/).
R.P. Lourenço Government Information Quarterly 40 (2023) 101762

Table 1
Relevant information to monitor policy accumulation and administrative
overload.
Stages Information to consider
Antecedents: Popular petitions (ePetitions) demanding policy
- Agenda-setting (Dunn, action
2014) Formal and official recommendations and requests
- Policy formulation for policy action
(Dunn, 2014) Supranational organizations’ obligations that
require adopting new national policies and
regulations
Public policies in the formulation stage of the policy
cycle (before adoption)
Formal public consultation processes
Accumulation: Policy output (new policies approved for
- Policy adoption (Dunn, implementation)
2014) Policy termination (policies formally terminated)
- Policy termination Ongoing policies (policies adopted and still being
(Dunn, 2014) implemented)
Overload: Human resources (public officials) primarily
- Policy implementation assigned to administrative tasks
(Dunn, 2014) IT projects being planned and implemented, as well
- Policy assessment (Dunn, as major IT systems under operation (portfolio)
2014) New (planned) and existing organizational
structures and the policies each one manages
Policy implementation outputs
administrative overload: “a lack of sufficient administrative capacity,
[that] could stand in the way of translating policy outputs into out­
comes, which should have a negative effect on policy impacts.” (Limberg
et al., 2020, p. 5).
This work aims to identify which information should be publicly
available to allow monitoring of both policy accumulation and admin­
istrative overload and support pre-emptive actions to avoid them.
Namely, when debating existing social problems and demanding public
policies to address them, or while preparing a new policy for approval,
such monitoring information may be useful to prioritize policy in­
terventions or to reallocate sufficient resources to ensure successful
policy implementation.
Contrary to traditional public policy analysis, which usually adopts
micro-perspectives focused on individual administrative agencies, pol­
icies, or programs (Hall & O’Toole Jr, 2000), a more macro-perspective
(Bayerlein et al., 2019) will be adopted here by taking into account the
entire portfolio of public policies and the whole of public
administration.
This work is framed as a contribution to open government (Tai,
2021) or, more precisely, government transparency research. Govern­
ment transparency has been around for more than 250 years (Meijer,
2015), but it has gathered considerable momentum with the Trans­
parency and Open Government Memorandum (Obama, 2009) and
Directive (Orszag, 2009), and the creation of the Open Government
Partnership.1
As Bannister and Connolly (2011, p. 5) point out, “definitions of
transparency are not in short supply”. As a major open government
objective, transparency “advocates for public accessibility to govern­
ment information” (Linders & Wilson, 2011, p. 267), and is intended to
promote the reuse of government data to create social or economic value
(Linders & Wilson, 2011), and to support public accountability (Lour­
enço, 2015a; Lourenço, Piotrowski, & Ingrams, 2017). Without access to
relevant information it is not possible to engage citizens in substantive
public participation, deliberation and decision-making (Gudowsky &
Bechtold, 2020; Jaeger, 2007), including in the context of public policy
debates.
Several studies have addressed different elements of transparency in
public policy processes including policy inputs, such as the use of
1
https://www.opengovpartnership.org/
publicly available data (Napoli & Karaganis, 2010), the adoption of
socio-technical developments (Orlikowski, 1992) in public policy-
making, such as social media platforms (Janssen & Helbig, 2018), and
the positive (Brunswicker, Pujol Priego, & Almirall, 2019) and negative
(Fox, 2007) effects of policy transparency and how complex dynamics of
government transparency changes the power of stakeholders to influ­
ence policy-making processes (Meijer, 2013).
Other works on the theme include a framework for computer-
mediated transparency that distinguishes between decision-making
transparency, policy content transparency, and policy outcome trans­
parency (Grimmelikhuijsen & Welch, 2012), and a framework for
measuring the degree of transparency of a specific policy document, law,
or regulation throughout the whole policy process (Beblavý, Sičáková-
Beblavá, & Bačová, 2022). The latter comprises all stages of the process
and, for each stage, considers transparency elements regarding sub­
stance, rationale, process, and impact of the policy under development.
This is a very comprehensive framework, but it adopts a micro-level
approach and does not consider the macro-level policy accumulation
phenomena.
Despite these efforts, no literature was found concerning the role of
government transparency in monitoring policy accumulation. To
address this issue, this work considers policy accumulation and analyses
its antecedents (governmental responsiveness), its effects on resources,
and its consequences (administrative overload and hampered policy
implementation), and proposes a set of information elements that, if
available to the public (government transparency), may contribute to
monitoring and ultimately prevent policy accumulation and its effects.
Once an initial theoretical framework was established, an analysis of
the Portuguese case was executed to serve two purposes. First, to further
refine the framework and ‘ground’ it on actual data, thus following a
“grounded theory inductive/deductive approach, [the] theory being
grounded in … continual reference to the data” (Saunders, Lewis, &
Thornhill, 2009, p. 149). Second, to illustrate the framework’s purpose,
applicability, and value to help monitor the policy accumulation phe­
nomenon in a specific case. In the end, the analysis of the Portuguese
case, guided by the framework, may be considered a (partially)
descriptive study which is “an extension of … a piece of exploratory
research” (Saunders et al., 2009, p. 140).
The remainder of this paper is structured as follows. Section 2 ana­
lyses the way public policy processes are organized and the role of
government transparency at each stage. Section 3 identifies the ante­
cedents and effects of policy accumulation and lays out the proposed
government transparency framework to monitor policy accumulation
and administrative overload. To better understand the framework, and
how it may be applied, section 4 is dedicated to the Portuguese case. The
paper ends with conclusions.
2. Transparency and the public policy process stages
Defining and implementing public policies and policy instruments
requires a series of steps, usually considered in sequence, forming a
broader ‘policy-making process’, ‘policy process’ (Dunn, 2014), or
‘policy cycle’ (Janssen & Helbig, 2018; Knoepfel et al., 2011). The latter
expresses reality more accurately since each step is linked to the next
one forming “complex rounds or cycles … [with] no definite beginning
or end" (Dunn, 2014). Fig. 1 presents the major stages in the process/
cycle.
Public policy processes are becoming more iterative (Brunswicker
et al., 2019) and participative (Chun & Cho, 2012; Kim & Lee, 2017) as
part of open government initiatives. This includes, for instance, using
social media platforms (Ferro, Loukis, Charalabidis, & Osella, 2013),
simulation websites, visualization and serious gaming tools (Janssen &
Helbig, 2018) to promote civic engagement (Ferro et al., 2013) and
crowdsourcing to elicit public opinions (Chun & Cho, 2012; Ferro et al.,
2013; Janssen & Helbig, 2018).
Transparency is another broad trend associated with policy

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R.P. Lourenço Government Information Quarterly 40 (2023) 101762

“something will be done about a certain topic”, “why and with what
objectives”, “how the public can submit its views”, and “specify any
Percepon of private and public problems (Knoepfel et
al., 2011)
Agenda-seng (Dunn, 2014; Knoepfel et al., 2011) expected impacts” (Beblavý et al., 2022, pp. 110–114).
Problem definion (Janssen and Helbig 2018)
(Re-)emergence of a problem (Knoepfel et al., 2011) 2.2. Formulation and policy development

Policy formulaon (Dunn, 2014)
Policy development (Janssen and
Helbig, 2018)
Formulaon of alternaves
(Knoepfel et al., 2011)
Policy adopon (Dunn, 2014;
Knoepfel et al., 2011)
Policy implementaon (Dunn,
2014; Janssen & Helbig, 2018;
Knoepfel et al., 2011)
Policy Enforcement (Janssen &
Helbig, 2018)
Policy Adaptaon, Policy Succession
(Dunn, 2014)
Once the problem is identified and the need for action is acknowl­
edged, we move to the “policy formulation” (Dunn, 2014), “formulation
of alternatives” (Knoepfel et al., 2011), or “policy development” (Jans­
sen & Helbig, 2018) stage. It is at this stage, where alternative policies
are formulated (Dunn, 2014), that most research focuses their attention
to the point that the whole process is equated to this stage alone. Janssen
and Helbig (2018), for instance, propose to detail this stage as a
modelling cycle with 5 stages of its own, one of which is termed “data
collection”. Transparency efforts should make sure policy-relevant data
is available at this stage (Janssen & Helbig, 2018; Napoli & Karaganis,
2010), from open and big data sources (Aragona & De Rosa, 2019;
Janssen & Helbig, 2018), thus enabling data-driven policy-making ap­
proaches (van Veenstra & Kotterink, 2017).
Policy formulation transparency may also include information on the
overall rationale for the drafts, on who participated in the formulation
process and how they were selected, and on all ex-ante impact assess­
ment analyses (Beblavý et al., 2022, pp. 110–114).

2.3. Adoption

At some point in the process, choices have to be made and one

Policy evaluaon (Janssen &
Helbig, 2018)
Policy assessment (Dunn, 2014)
Evaluaon of policy effects
(Knoepfel et al., 2011)
Policy terminaon (Dunn, 2014;
Souza & Secchi, 2015)
Fig. 1. The public policy process/cycle.
processes, namely in combination with participatory policy-making
(Brunswicker et al., 2019). Active and meaningful participation bene­
fits from access to relevant information (Kim & Lee, 2017) but, despite
the close relation, information and transparency are separate constructs
(Grimmelikhuijsen & Welch, 2012; Piotrowski, 2017). Although trans­
parency is about the disclosure of information, it is key that such in­
formation enables external actors (e.g., citizens) to monitor, scrutinize
and assess the internal workings of governmental organizations (Ban­
nister & Connolly, 2011; Grimmelikhuijsen & Welch, 2012). Overall,
focusing on making the whole public policy process more transparent
helps to align citizens with the policy goal and improve policy effec­
tiveness (Brunswicker et al., 2019).
The next subsections further describe each policy process stage and
detail how it can be made more transparent.
2.1. Agenda-setting
The process is commonly described as starting with an agenda-
setting stage (Dunn, 2014) which marks the moment when elected
and appointed officials, possibly pressured by public opinion,
acknowledge the need for public action to solve a particular societal
problem. Some variants further detail the process and propose related
stages, such as “(Re-)emergence of a problem” and “Perception of pri­
vate and public problems” (Knoepfel et al., 2011, p. 32). Janssen and
Helbig (2018), on the other hand, simply refer to this initial stage as
“problem definition”.
Agenda-setting transparency may include an announcement that
particular policy or policy instrument is selected among the existing
alternatives (Dunn, 2014; Knoepfel et al., 2011). Before a decision is
made, policy content transparency (Grimmelikhuijsen & Welch, 2012)
requires information is available concerning each policy alternative
including how it is supposed to solve the problem, how it will be
implemented and what impacts are expected and which groups will be
affected. Information concerning all policy drafts submitted for the
adoption process should include all appendices and addenda, amend­
ments and chances proposed during the formulation stage, how they
were dealt with and the rationale behind the process (Beblavý et al.,
2022, pp. 110–114).
Once a decision has been made about which policy option to adopt,
decision-making transparency (Grimmelikhuijsen & Welch, 2012) re­
quires information should be available concerning the steps made and
the rationale behind the decision. However, despite all the push for
greater transparency at this stage, Fox (2007) argues transparency about
lawmakers’ policy choices can have negative consequences.
2.4. Implementation
Adoption is followed by the implementation (Dunn, 2014; Janssen &
Helbig, 2018; Knoepfel et al., 2011) and enforcement (Janssen & Helbig,
2018) stages, whereby public administrations mobilize resources to
comply with the policy (Dunn, 2014).
Transparency at this stage means, for instance, disclosing informa­
tion about secondary/tertiary legislation and court/regulatory decisions
implementing the policy (Beblavý et al., 2022, pp. 110–114).
2.5. Evaluation
The implementation stage is not the end of the process. Policy
implementation needs to be monitored to evaluate (Janssen & Helbig,
2018) whether it is achieving the stated objectives (Dunn, 2014) and
causing the intended effects (Knoepfel et al., 2011).
Transparency in this context means, for instance, information is
available about ex-ante and ex-post evaluations, including their ratio­
nales, who commissioned and executed them, and whether the public
had the opportunity to participate in the assessment process (Beblavý
et al., 2022, pp. 110–114). Such policy outcome transparency

3
R.P. Lourenço
(Grimmelikhuijsen & Welch, 2012) includes both information about
policy execution but also about policy effects and impact.
2.6. Termination, adaptation, and succession
Depending on the assessment results, and whether or not the original
problem subsists or has re-emerged (Knoepfel et al., 2011), it may be
necessary to adapt the existing policy or formulate a new policy to
succeed it (Dunn, 2014). If so, the policy process restarts, and it becomes
a cycle. Alternatively, if the policy is no longer needed, the process ends
with a final stage of “policy termination” (Dunn, 2014; Souza & de Souza
& Secchi, 2015).
3. A framework to monitor policy accumulation and
administrative overload
Having analysed the public policy process in detail, we are now in a
position to develop the framework.
3.1. Antecedents: Government responsiveness
To develop a government transparency framework to monitor policy
accumulation and administrative overload, we need to begin by looking
at the antecedents of policy accumulation. In other words, we need to
look into the initial stages of the policy process, agenda-setting (Dunn,
2014) and policy formulation (Dunn, 2014), and into formal mecha­
nisms used to prompt government responsiveness.
There are many ways governments become aware of the need for
public action to solve societal problems. Informal and diffuse channels
may include open letters, private and informal meetings with political
representatives, or policy debates in the public sphere.
For the purpose of this work, we will consider three types of formal
channels and mechanisms covering requests from civil society, from
within the political and administrative structure, and from suprana­
tional organizations.
The first one is ePetitions, “eParticipation tools that have the po­
tential to create dialogue and involvement of citizens and other stake­
holders in the political process” (Coelho, Cunha, & Pozzebon, 2017). To
monitor policy accumulation and administrative overload antecedents,
government transparency should include the disclosure of which pop­
ular petitions (Piotrowski, 2017) have been formally filed and are being
considered for analysis.
The second mechanism includes formal recommendations and re­
quests to act on specific societal problems by official organizations, as
contemplated in the political and administrative architecture of each
country. This might include, for instance, recommendations approved
by the Parliament to urge Government to act to address a particular issue
or problem.
Finally, we may also consider the impact of supranational organi­
zations’ obligations which require adopting new national policies and
regulations, in what may be characterized as a process of vertical rule-
making (Kaufmann & van Witteloostuijn, 2018).
These three elements could be complemented by information con­
cerning public policies already in the formulation stage of the policy
cycle, before adoption and implementation. And, by looking at this stage
of the cycle, we also can identify policies originating from other sources
other than the ones recognized in the agenda-setting stage. One specific
mechanism to consider regarding ongoing policy formulation processes
is that of formal public consultations. Sometimes these consultation
processes are mandatory, but in other cases, government officials may
want to gather contributions to improve the policies and possibly gather
support for their implementation.
All this information may contribute to reveal how demand for new
policies and rules is forming, and which policies are being considered
before they are selected for approval and implementation. If publicly
available as part of a government transparency effort, this information
4
Government Information Quarterly 40 (2023) 101762
could be used as an early warning for policy accumulation risks.
3.2. Accumulation: Policy adoption and termination
The next stage in the policy cycle, the adoption stage (Dunn, 2014;
Knoepfel et al., 2011), marks the point where particular policies or
policy instruments are selected for implementation. Policy accumulation
occurs at this stage when the rate of policy production and output ex­
ceeds the rate of policy termination, and studies confirm that has been
the general trend in contemporary democracies (Adam et al., 2019,
2017, 2018). The result is an ever-growing public policy portfolio, both
in number and complexity, of policy instruments and regulations.
To monitor policy accumulation at this stage, considering an
aggregated view of policy production, government transparency efforts
must provide information concerning policy output (new policies
approved for implementation), policy termination, and the corre­
sponding galaxy of ongoing policies at any given moment.
To monitor policy output we need to have access to official infor­
mation about which policies and corresponding high-level policy in­
struments (strategic plans, national strategies, action plans, …) were
approved. In democratic political systems such policy instruments, often
assuming a legal format, must be published in an official outlet. If
properly organized, this official outlet may be relevant as a source of
information for policy output monitoring.
Once created policies may be explicitly dismantled or terminated but
that is a rare case (Bayerlein et al., 2019; Souza & de Souza & Secchi,
2015). When such explicit termination occurs, this is an official act
which is also published in an official outlet. Perhaps more commonly,
some policies are assumed to have terminated once the period for which
they were created expires (e.g., “Strategy 2020–2030”). In other cases,
new policies may replace or extend older policies without any explicit
reference to what happens to the latter.
All in all, this means it may be difficult to ascertain whether a
particular policy or high-level policy instrument is still in place.
Therefore, for policy accumulation monitoring purposes, it is important
to be able to keep track of ongoing policies, in a non-ambiguous and
systematic way. This information is also crucial to monitor the conse­
quences of policy accumulation, namely administrative overload.
3.3. Overload: administrative capacity and policy implementation output
Administrative overload occurs when administrative capacity is not
able to cope with policy accumulation and the growth in the number and
complexity of new rules to implement (Limberg et al., 2020). Conse­
quently, new policies and rules may be ignored or poorly implemented
(Adam et al., 2019), and pre-existing policies and rules may suffer from
crucial resources being diverted to implement new policies (Bayerlein
et al., 2019).
Administrative capacity, understood as “the capacity of [bureau­
cratic] intermediaries to carry out requisite actions” (May, 2012 apud
Limberg et al., 2020), depends on how bureaucratic structures, pro­
cesses, and resources are organized (Adam et al., 2017), and on the
availability of human capacity (administrative and technical expertise),
financial, technical and organizational resources (Limberg et al., 2020).
Since measuring administrative capacity “is a tricky empirical
endeavour” (Limberg et al., 2020), a government transparency frame­
work considers whether information regarding aggregated (not sector-
specific or policy-specific) administrative capacity, namely human re­
sources, information systems, and organizational structures, is publicly
available.
Information about human resources (public officials) is essential to
be able to monitor administrative capacity: increasing the policy port­
folio (policy accumulation) without the corresponding increase in the
number of public officials in charge of managing them may lead to
administrative overload. Therefore, from an aggregated (macro)
perspective, it is important to monitor the number of public officials
R.P. Lourenço
primarily assigned to administrative tasks (i.e., excluding those who are
not, such as teachers, medical doctors, or judges). Preferably, it should
be possible to disaggregate the number of public officials according to
their technical skills or academic degree.
The use of Information Technologies (IT) in public administration
operations may offset the lack of human resources and “cushion the
impact of continuous policy accumulation on administrative overload”
(Adam et al., 2019). On the other hand, the adoption of new policies
often requires developing new information systems or adapting existing
ones. Therefore, policy accumulation may lead to an increased pipeline
of IT projects, which may work as another sign of a lack of adminis­
trative capacity to manage and execute those projects. IT governance,
both in the private and public sectors (Jonathan & Rusu, 2018; Tonelli,
de Souza Bermejo, Dos Santos, Zuppo, & Zambalde, 2017), aims “to
control the formulation and implementation of IT strategy” (Van
Grembergen, 2005) resorting to a mix of decision-making structures,
processes and relational mechanisms. Managing IT projects and port­
folios (Haes & Grembergen, 2016; Tonelli et al., 2017) is a key process of
IT governance entailing the “prioritization process for IT investments
and projects” (Haes & Grembergen, 2016). As such, some of the infor­
mation used in IT governance may be relevant to monitor administrative
capacity and overload, including the number of IT projects being plan­
ned and implemented, as well as the number of major IT systems under
operation (portfolio).
The third element we might consider is the institutional arrange­
ments used to implement public policies and corresponding high-level
policy instruments (programs, action plans, strategies,.). New policies
may overload existing organizational structures which become respon­
sible for their implementation. And even if new organizational struc­
tures (agencies, committees, …) are created specifically to manage and
implement new policies, there is still the need to coordinate between
two or more organizations (Hall & O’Toole Jr, 2000) and to reconfigure
policy networks which “typically do not replace bureaucratic organi­
zation; instead, they add one or more layers of structural complexity”
(O’Toole Jr, 2015). As such, information regarding new (planned) and
existing organizational structures, the policies each one manages, and
the networks they form to implement those policies, is essential to
monitor administrative capacity and overload.
One final type of information that may be relevant to monitor
administrative capacity and overload concerns policy implementation
outputs (not outcomes). This information is essential for political
accountability purposes, but the absence of implementation outputs and
a low level of policy execution (e.g., no actions started/completed) may
also be considered a relevant indicator of possible administrative over­
load. Therefore, it may be part of any monitoring system.
3.4. A comprehensive framework
Table 1 summarizes the information identified in the previous sec­
tion relevant to monitor policy accumulation and administrative
overload.
The list in Table 1 is not meant to be exhaustive or exclusive, nor it
was compiled as a means to build a unified and quantitative index, for
instance. Instead, it should be considered as a broad framework to guide
government transparency efforts to support monitoring policy accu­
mulation and administrative overload.
In what concerns the principles and technical aspects of how such
information should be made available, there is extensive literature on
the subject in association with government transparency, open govern­
ment and open government data (Nikiforova & McBride, 2021). In most
cases, it is possible to associate one or more datasets to each of the in­
formation types listed in Table 1. Since we are adopting an aggregated
view (not sector-specific or policy-specific) it is very important to follow
the broad principle that digital services and information should be
delivered through a single point of access (European Commission, 2016;
Tambouris & Wimmer, 2005), such as Open Government Portals
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Government Information Quarterly 40 (2023) 101762
(Lourenço, 2015b), to facilitate access to all information concerning
policy accumulation and administrative overload monitoring.
The individual datasets should be made available in adherence to
open data format and principles (Colpaert, Joye, Mechant, Mannens, &
Van de Walle, 2013; Eaves, 2009; Zuiderwijk & Hinnant, 2019; Zui­
derwijk, Janssen, Choenni, & Meijer, 2014). Also, to avoid a fragmented
analysis of each dataset and type of information, such data should be
provided as linked open data (Fayyaz, Ullah, & Khusro, 2018) in
adherence to semantic web approaches (Hoxha & Brahaj, 2011). This
would allow, for instance, to associate an ePetition with a corresponding
adopted policy and, once implementation starts, with its outputs.
4. A brief analysis of the Portuguese case
The Portuguese case will be used to illustrate how the framework laid
out in the previous section may be used to analyse government trans­
parency concerning policy accumulation and administrative overload
monitorization.
To start with, no official webpage or site was found referencing the
issue of policy accumulation or administrative overload, or that would
serve as a single point of access to the different elements of information
listed in Table 1. Also, although Portugal has a national open data portal
(dados.gov2), develop as part of an effort to promote open government
and transparency, we could not find in it any datasets regarding the
different elements. Consequently, online information concerning each
element in Table 1 will be examined separately in the next sections.
The information concerning official recommendations and requests
for policy action (section 4.1.2.), high-level policy instruments approval
and formal termination (sections 4.2.1. and 4.2.2.) was collected from
Diário da República Electrónico – DRE3 (the electronic version of the
Portuguese Republic Official Journal). The platform that hosts DRE or­
ganizes published official acts chronologically and according to some
attributes (publication date, publishing entity, …). And, despite having
some search capabilities, they are not oriented to provide the informa­
tion required for this purpose simply and directly. Therefore, a simple
Python web scraping routine (including the Beautiful Soup library4) was
used to perform automated searches for the period between 1 and 1-
2010 and 31–12-2019. The first 1000 results for each partial search
were dumped by the Python routine into a single Excel spreadsheet. The
spreadsheet was then analysed to remove duplicate and non-relevant
results using simple Excel formulas and considerable manual
observation.
4.1. Antecedents: government responsiveness
4.1.1. ePetitions
The official ePetitions5 platform is hosted by the Portuguese Parlia­
ment (Assembleia da República) website. The platform allows citizens and
organizations from the civil society to submit petitions, legislative ini­
tiatives, and requests for a referendum. It is possible to monitor the
whole process between the initial submission and the (potential) dis­
cussion at the Parliament. Using the search tool provided by the plat­
form, it was possible to identify 4 petitions6 accepted and waiting for
discussion. If successfully discussed and approved, these petitions may
give origin to new policies or new sets of rules. Therefore, this platform
provides relevant information which may be used to identify future
policy accumulation and administrative overload.
The data describing such petitions is not available in open data
2
https://dados.gov.pt/pt/
3
https://dre.pt/
4
https://www.crummy.com/software/BeautifulSoup/ (last visited 10-11-
2020)
5
https://www.parlamento.pt/ActividadeParlamentar/Paginas/Peticoes.aspx
6
25th of March 2021
R.P. Lourenço
format on the Parliament website nor it is made available as a dataset in
dados.gov,7 the Portuguese open data portal. And it is also not possible
to relate approved petitions with the corresponding future policies and
rules that originated from them.
4.1.2. Formal and official recommendations and requests for policy action
One way to influence the policy agenda is to formally approve, at the
Parliament, official recommendations, and requests for policy action. As
with any other official act, once approved, these recommendations are
published at the Diário da República Electrónico – DRE. The procedure
described at the beginning of section 4 was used to search for the word
“recommendation” (and similar terms) in DRE and resulted in the
identification of 31 recommendations to develop, adapt or implement
National Strategies, Action Plans, and other high-level policy
instruments.8
This information is yet another important element to (pre-emptively)
monitor policy accumulation and administrative overload but, although
it is indeed available on the DRE platform, it is not organized in a way to
identify recommendations unequivocally. Furthermore, it is not possible
to see whether such recommendations for action were indeed followed
and which high-level policy instruments were consequently approved.
4.1.3. Supranational organizations’ obligations
Being a European Union (EU) Member State (MS), Portugal is
required to transpose EU Directives which means adopting new national
policies and regulations.
It is possible to list all EU Directives already transposed by a
particular Member State (MS), including a reference to the internal legal
document which transposes each Directive. Portugal has 8310 directives
listed as transposed (all years considered), which illustrates the impor­
tance of this mechanism as a potential source for policy accumulation
and administrative overload.
It is also possible to find information concerning the performance of
each MS in the transposition process.9 In the latest report (2020)
Portugal had 5 overdue directives and 32 infringements (pending cases).
However, no search mechanism has been found which would list the
directives awaiting transposition for each country.
Searching for ‘European directives’ in official Portuguese govern­
ment webpages using Google Search10 did not also return a compre­
hensive list of directives awaiting transposition. Instead, webpages for
specific policy sectors were found listing the applicable directives. In
some cases, like the Employment and Work Relations dedicated web­
page11 we can see that there are currently 5 directives concerning this
policy sector waiting to be transposed.
In sum, it was not possible to have a clear and comprehensive picture
regarding which directives were awaiting transposition across all policy
sectors. Transposing such directives will result in new policies and rules,
and therefore this information would be important to (pre-emptively)
monitor policy accumulation and administrative overload.
4.1.4. Formal public consultation processes
Nowadays, participatory mechanisms such as public consultation
procedures became part of ongoing policy formulation processes (before
the adoption stage). Information about such procedures allows us to
7
https://dados.gov.pt/pt/
8
E.g., Parliament Resolution n.◦ 42/2018(https://data.dre.pt/eli/re
solassrep/42/2018/02/15/p/dre/pt/html) recommends Government to imple­
ment an action program to cut red tape and support SMEs
9 13
https://ec.europa.eu/internal_market/scoreboard/performan
ce_by_member_state/pt/index_en.htm#transposition (last visited 25/03/2021)
10
The actual search expression used was ‘directivas europeias site: gov.pt’
(25/03/2021)
11
https://www.dgert.gov.pt/atos-europeus-adotados (last visited 25/03/
2021)
6
Government Information Quarterly 40 (2023) 101762
know in advance which new policies are being considered, how are they
being shaped and what will be their impact on policy accumulation and
administrative overload.
In Portugal, there is an official platform where all public consultation
procedures are implemented.12 According to the latest information
available,13 176 consultation procedures were already completed, and
one formal consultation process is still open to discuss the National
Strategy for Preventive Civil Protection 2030.
A more detailed analysis of the National Strategy for a Preventive
Civil Protection 2030 being proposed highlights some of the elements
that may contribute to policy accumulation as the document identifies
several already existing national strategies, fundamental laws, national
programs, and action programs in related areas. Other aspects of the
strategy may also contribute to administrative overload: it creates a new
Coordination Group in charge of implementing the Strategy (22 mem­
bers), directs existing Civil Protection Committees (at national, munic­
ipal, and local levels) to monitor and keep track of projects and actions,
directs the National Emergency [response] Authority to provide logistic
and administrative support to the Coordination Group. Also, the strategy
itself is organized around 5 Strategic Objectives, 10 Priority Areas and
136 Operational Objectives, each one corresponding to a project or ac­
tion to be executed by Central and Local Administration organizations
according to a specific Action Plan. These projects and actions will have
to be managed and implemented, potentially contributing to adminis­
trative overload if new resources are not allocated.
This example illustrates the relevance of knowing which high-level
policy instruments are being considered for adoption, and what they
entail, to (pre-emptively) monitor policy accumulation and adminis­
trative overload. Unfortunately, the document format (PDF) makes it
difficult to identify key data about each policy instrument or to link it to
other related data (related policies, existing administrative organiza­
tions, …).
4.2. Accumulation: policy adoption and termination
4.2.1. Policy output (new policies approved for implementation)
In the Portuguese case, no centralized website or webpage exclu­
sively dedicated to approved policies was found. However, while
searching for such a single point of access, several webpages were found
which list national plans and strategies addressing specific policy areas
or themes.14 There is no assurance they are kept up to date or they are
comprehensive.
The only way to have a systematic and comprehensive view of policy
output is to consult the Diário da República Electrónico – DRE website and
look for high-level policy instruments. The DRE is organized by chro­
nological order (it is a daily journal of the Republic) and, in each edition,
we find all legal documents approved that day, including high-level
policy instruments (such as Action Plans, Programs, and Initiatives)
but also public administration appointments, civil and criminal laws,
spending authorizations, or public administration organizational struc­
tures. Under these circumstances, it is very difficult to have a compre­
hensive and specific view of policy output.
To illustrate the difficulty, we set out to identify which (and how
many) high-level policy instruments were approved in Portugal between
2010 and 2020. The procedure described at the beginning of section 4
was used to search for nine different expressions15 in the Diário da
12
https://www.consultalex.gov.pt/Homescreen.aspx (last visited 25/03/
2021)
Last visited 25/03/2021
14
E.g., Social Service (https://www.cm-mirandela.pt/pages/1245); Citizen­
ship and Gender Equality (https://www.cig.gov.pt/documentacao-de-refer
encia/legislacao/cidadania-e-igualdade-de-genero/)
15
Agenda, Strategy, Initiative, Action Plan, Strategic Plan, National Plan,
Program, Strategic Framework, Action Framework
R.P. Lourenço
República Electrónico – DRE website and we were able to identify 169
high-level policy instruments officially approved and published during
that period. This number should not be considered definitive, but it
already gives an idea about the dimension of policy output (and policy
accumulation) in that period.
This exercise showed that, in the Portuguese case, the information is
publicly available but there is no simple and systematic way to fully
identify all approved policies and high-level policy instruments. Also,
the information is in a legal format therefore it is not aimed at ordinary
citizens who might benefit from monitoring policy accumulation and
administrative overload.
4.2.2. Policy termination (policies formally terminated)
In the Portuguese case, any formal and explicit policy termination act
should also be published on the Diário da República Electrónico – DRE
website. However, using the same data collected to identify policy
output, it was only possible to clearly identify one such case16 between
2010 and 2020. This should be considered with care. Some policies were
formulated with a specific period in mind (as in “Policy 2020–2025”),
and they may be considered terminated once that period has ended. It is
also possible that new policies refer, in their legal texts, to previous
policies they aim to replace or update (no such detailed analysis was
made).
Either way, it is very difficult to know (with certainty) whether or
when a specific policy was terminated. Furthermore, while, in some
cases, dedicated webpages (from responsible organizations, for
instance) are removed, others remain as no one takes the trouble to
remove them. This means that if we search the web for a specific policy,
it is possible to stumble upon outdated information which gives the
impression such policy is still valid when it is not.
4.2.3. Ongoing policies (policies adopted and still being implemented)
Under the circumstances described in the previous sections, it is very
difficult to identify which policies and high-level policy instruments are
still in the implementation phase.
As already shown, if we are looking for a specific policy or high-level
policy instrument it is possible to find some information about it on a
policy theme webpage, a particular public organization website, or even
a specific policy dedicated webpage. But even if we find such informa­
tion, we cannot always be sure the policy is still being implemented.
Consequently, it is very difficult to have a comprehensive view of the
current level of aggregated policy accumulation and its impact on public
organizations.
4.3. Overload: administrative capacity and policy implementation output
4.3.1. Human resources (public officials) primarily assigned to
administrative tasks
The Directorate-General for Public Administration and Employment
(DGAEP17) is responsible for running the State Organization Information
System (SIOE18) which collects data concerning all public administra­
tion organizations (central, regional and local) and their human re­
sources. The SIOE has a public web interface which has some (very
limited) search capabilities and data download options which make it
very difficult to obtain human resources data.
16
Determination from the Council of Ministers n. 42-B/2015: “Determines
closing the e-Escolinha Program” (https://data.dre.pt/eli/resolconsmin/42-b/
2015/06/19/p/dre/pt/html)
17
Direção-Geral da Administração e do Emprego Público (https://www.dgaep.
gov.pt/)
18
Sistema de Informação de Organização do Estado (https://www.sioe.dgaep.
gov.pt/Default.aspx)
7
Government Information Quarterly 40 (2023) 101762
Instead, DGAEP regularly publishes on its website the Public
Employment Statistics Bulletin (BOEP)19 and the Public Employment
Statistical Synthesis (SIEP),20 along with Excel spreadsheets containing
detailed employment data dating from 2011 (this data is not available at
dados.gov.pt, the Portuguese open data portal). Fig. 2 shows the evo­
lution of the number of public officials in Portuguese public adminis­
tration since 2011.
Since the data is disaggregated by professional categories it was
possible to present a rough estimate of those public officials more
directly assigned administrative tasks (excluding, for instance, teachers,
doctors, security forces, …). Data shows that the number of public of­
ficials has not changed significantly during the last decade. Considering
that there is a general trend to accumulate public policies and rules in
every country (in the Portuguese case, 169 new policies were identified
since 2010), this is a strong signal of decreasing administrative capacity
to manage those policies and rules thus creating administrative
overload.
Unfortunately, although this relevant data is available, it is not part
of a coherent policy accumulation and administrative overload moni­
toring system.
4.3.2. IT projects being planned and implemented, as well as major IT
systems under operation (portfolio)
There is only limited information publicly available about IT
governance in the Portuguese public administration. The IT governance
official website21 lists some of the major existing ICT platforms and
websites, including the Authentication, the Interoperability, the Digital
Services, and the Open Data platforms, and two related IT governance
specific platforms: ‘Prior Notice’,22 a platform where public organiza­
tions must submit relevant IT investments and projects for approval
before starting implementation; and ‘ICT Report’,23 a platform where
public organizations should report current investments and IT projects
for monitoring purposes.
Both ‘ICT Report’ and ‘Prior Notice’ platforms were developed for
internal (public administration) use only and do not provide any infor­
mation to the public. This means it is not possible to obtain detailed
information about the current IT portfolio and ongoing or planned IT
projects.
To analyse the impact of policy adoption on the IT portfolio (new
Human resources in Public Administraon
8,00,000
7,00,000
6,00,000
5,00,000
4,00,000
3,00,000
2,00,000
1,00,000
0
2011 2012 2013 2014 2015 2016 2017 2018 2019 2020
All Administrave tasks
Fig. 2. Human resources in Portuguese public administration.
19
Boletim Estatístico do Emprego Público (https://www.dgaep.gov.pt/index.
cfm?OBJID=C0F56E62-5381-4271-B010-37ECE5B31017)
20
Síntese Estatística do Emprego Público (https://www.dgaep.gov.pt/index.
cfm?OBJID=ECA5D4CB-42B8-4692-A96C-8AAD63010A54)
21
https://tic.gov.pt/
22
Parecer prévio (https://parecerprevio.tic.gov.pt/)
23
Reporte TIC (https://reporte.tic.gov.pt/)
R.P. Lourenço
systems, adaptations, …) we must then investigate each policy. Let us
consider, for instance, the case of the Affordable Housing Program
adopted in 2019.24 The main piece of legislation broadly defines the
data required for affordable housing applications, the assessment rules
and the process, but it does not explicitly refer to any new IT platform to
be developed. Subsequent legislation and regulation25 specifically
required applications to be submitted using a new electronic platform.
The platform would automate the application process, thus requiring
fewer human resources to do so, but developing the platform will
require other resources to establish interoperability with existing sys­
tems (which means those systems may have to be adapted), and to
develop internal processing routines and web interfaces.26
This example illustrates the fact that new policies often require
developing new IT platforms. Considering the number of new policies
adopted (policy accumulation), the complexity of IT projects, and the
current shortage of IT resources and skills (both in the private and public
sector), IT governance may be another source of administrative overload
which hampers policy implementation.
Monitoring the IT portfolio and development pipeline would provide
useful information concerning possible administrative overload. How­
ever, there is no comprehensive information available regarding IT
governance, and it is not possible to associate IT projects with specific
policies or high-level policy instrument requirements unless we analyse
the corresponding legal documents.
4.3.3. New (planned) and existing organizational structures and the
policies each one manages
The SIOE platform (see section 4.3.1) works as a registry of existing
formal organizational structures (it does not include working groups,
committees, consultation bodies, …). A simple search returned a list of
8855 public organizations from central, regional and local administra­
tion (this includes different types of organizations).27 Each organization
is fully characterized in the system but that does not include a reference
to specific policies and high-level policy instruments each organization
is managing and implementing.
These formal organizations, and other informal structures, form
complex policy governance networks that change as new policies are
adopted. For instance, the proposed National Strategy for Preventive
Civil Protection 2030 (see section 4.1.4) assigns new roles to existing
organizations and creates a new Coordination Group in charge of
implementing the Strategy (22 members). Like the policy accumulation
phenomena, it is not clear when (or whether) these new formal and
informal organizations cease to exist, or no longer have a role in a
particular policy governance network.
In sum, while the SIOE platform does provide information about
existing formal public organizations at a given moment, there is no in­
formation available concerning existing informal structures (commit­
tees, advisory groups, …), and how both have evolved (created and
terminated). Also, the SIOE does not provide information to fully un­
derstand the role of each organization concerning each policy or high-
level policy instrument, and the policy governance networks they form.
It is possible to reconstruct this information but that requires ana­
lysing individual (dedicated) policy webpages, public organizations’
institutional webpages, and policy legal documents (as published in
DRE, for instance).
Therefore, in the Portuguese case, it is very difficult to monitor the
growing complexity of policy governance networks and the amount of
new management and implementation tasks being assigned to public
24
Programa de Arrendamento Acessível (https://data.dre.pt/eli/dec-lei/68/
2019/05/22/p/dre/pt/html)
25
https://dre.pt/application/file/a/122522641
26
The platform was developed, and it is available at https://paa.portaldahabi
tacao.pt/ (last visited April 2021)
27
April 2021
8
Government Information Quarterly 40 (2023) 101762
organizations as new policies are adopted. This information would be an
important component of a coherent policy accumulation and adminis­
trative overload monitoring system.
4.3.4. Policy implementation outputs
Formulating and adopting policies and high-level policy instruments
is just the beginning: such policies need to be managed, implemented,
and monitored. The lack of policy implementation outputs may there­
fore be interpreted as a sign of administrative overload which prevents
policies from being executed.
In the Portuguese case, the requirement to monitor policy imple­
mentation outputs is becoming part of new policies, mainly for public
accountability purposes. For instance, the Affordable Housing Pro­
gram,28 approved in 2019, specifically requires the organization
responsible for the program execution (IHRU) to regularly monitor and
assess its progress (Article 26). However, no information was found on
the IHRU website or program dedicated webpage concerning such
monitorization: the IHRU Management Indicators webpage simply
stated “Available Soon”.29
In other cases, such as the Public Administration Innovation and
Modernization Strategy officially approved by 31/07/2020,30 the
monitoring information is published on a dedicated webpage31: 6
months after approval,32 39 actions have been initiated and 1 was
concluded from a total of 59 planned actions.
In sum, in the absence of a centralized website or webpage dedicated
to monitoring the implementation output of all approved policies (see
also section 4.2.3), it is possible to find monitoring information
regarding some individual policies.
4.4. Final remarks
This brief analysis of the Portuguese case illustrates how the
framework proposed in section 3 may be used to analyse a country’s
effort (or lack of it) to monitor policy accumulation and administrative
overload.
Since no dedicated and centralized webpage or site (single point of
access) was found dedicated to the phenomenon of policy accumulation,
it seems this is not a public concern in Portugal, and it does not play a
role in the political debate leading to new policies (associated with
government responsiveness).
Nevertheless, it is possible to gather some data regarding some of the
elements identified in the framework. In some cases (e.g., number of
public officials) it is easy to collect and process such data. But in other
cases, like the number of and identification of policies and high-level
policy instruments adopted and terminated, collecting the data re­
quires a mix of automated routines and extensive manual work. And, in
the end, there is some uncertainty about the accuracy and comprehen­
siveness of the results.
It was possible to confirm some approved policies already include
provisions that require some degree of monitoring and assessment, but
that is not always sufficient to guarantee such monitoring data is pub­
licly available. Also, it seems such provisions were primarily meant for
public accountability purposes.
Since no webpage or site was found with centralized information
about all policies and high-level policy instruments being implemented,
even the information available is presented on a policy-by-policy or
element-by-element basis. This fragmentation is further stressed by the
absence of linkage between different elements concerning the same
28
https://data.dre.pt/eli/dec-lei/68/2019/05/22/p/dre/pt/html
29
http://www.ihru.pt/web/guest/indicadores-de-gestao (last visited 15/04/
2021)
30
https://data.dre.pt/eli/resolconsmin/55/2020/07/31/p/dre
31
https://www.apin.gov.pt/indicadores/ (last visited 15/04/2021)
32
The data was last updated by 31/01/2021
R.P. Lourenço
policy or public organization, something the adoption of linked open
data principles could address.
Dados.gov, the Portuguese open data portal created as part of a
broader open government and transparency initiative, does not host
relevant data to monitor policy accumulation and administrative over­
load. Therefore, even when relevant data is available, it is not a format
which adheres to open data principles.
In sum, no coherent system was found that would allow for moni­
toring policy accumulation and administrative overload. The framework
may be useful to guide future government transparency initiatives,
including extending the datasets available at dados.gov to cover this
issue.
5. Conclusion
Policy accumulation is a common phenomenon in contemporary
democracies. On the positive side, policy accumulation is the natural
consequence of government responsiveness to societal issues. But it also
carries some unintended effects such as increased rule complexity and
administrative overload which may hamper policy implementation and
outcomes. If ordinary citizens and organizations from the civil society
are not aware of the problem, nor of its effects, and focus solely on
demanding new policies and getting them approved, they may wrongly
assume those issues and problems are ‘solved’. To avoid this policy
accumulation trap, policy analysis must not focus solely on each policy
or high-level policy instrument. A broader, aggregated view across all
sectors and issues is needed and this means information must be publicly
available to monitor the policy accumulation and administrative over­
load phenomena. This information may then be considered for every
new policy or high-level policy instrument under preparation, helping to
establish policy priorities or to make sure enough administrative re­
sources are provided for its implementation.
At the same time, openness and transparency are still important
contemporary government trends, and this includes releasing open
government data through data.gov portals. But open government data
(transparency) initiatives need to determine which data to release, for
what purpose and under which technical conditions. Since much of the
information needed to monitor policy accumulation and administrative
overload lies within public administration organizations, government
transparency initiatives may be an adequate tool to make such infor­
mation available to the public.
However, the potential of government transparency in preventing
the policy accumulation phenomenon does not seem to have been pre­
viously addressed in the literature. This research effort, grounded in the
literature on transparency, policy accumulation and the policy cycle,
provides a first step to addressing this phenomenon in an innovative
way. The resulting analysis framework identifies and proposes a
comprehensive set of information monitoring elements, covering the
different stages in the public policy process and grouped around three
broad clusters: antecedents of policy accumulation (government
responsiveness), public policy accumulation (policy adoption and
termination) and administrative overload (administrative capacity and
policy implementation output).
The framework was used to analyse the Portuguese case revealing
that some of the required information is indeed available, but it does not
cover all elements in the framework. Also, the information is mostly
available in unsuitable formats thus demanding an extensive effort to
collect, process and analyse it. And, above all, the absence of a single
point of access to such information is a sign that policy accumulation
and administrative overload is not recognized as relevant public issue,
including by government transparency initiatives such as the national
open data portal. To improve the current situation policy accumulation
monitoring must be recognized as a relevant issue and a subject for
government transparency. This means creating a dedicated public policy
webpage or portal that works as a single point of access to information
across all policy areas, and/or a dedicated hashtag in the open
9
Government Information Quarterly 40 (2023) 101762
government data portal. Data for each element in the framework must
be available in a suitable format (according to open data principles),
correctly indexed and, preferably, embedded in an ontological structure
(according to linked data and semantic web principles) thus allowing
different elements associated with a single policy, high-level policy in­
strument or policy area to be easily considered together.
Despite its innovative and comprehensive nature, this research effort
still has some limitations. Policy accumulation is a complex phenome­
non and much dependent on the particularities of different countries and
different policies. Therefore, while the analysis of the Portuguese case
illustrated the framework’s purpose and usefulness, further research is
needed to apply the framework to other countries and contexts and the
insights gained would allow refining and strengthening it. Other limi­
tations, and potential areas for future research, include addressing the
technical aspects of how information should be made available in
adherence to open data principles. The framework may also be extended
by further research by defining quantitative criteria to assess the avail­
ability of each type of information and defining an aggregation method
to produce a single index for both policy accumulation and adminis­
trative overload. This would allow for better monitoring of both phe­
nomena and, possibly, a comparison among different countries.
The framework proposed in this work is intended to draw the
attention of those responsible for government transparency initiatives to
consider addressing policy accumulation and administrative overload.
As such, the framework may be useful to provide a snapshot of the in­
formation already available, to guide government transparency efforts
to improve the current situation, and to create the conditions for more
informed policy debates in the public sphere.
CRediT authorship contribution statement
Rui Pedro Lourenço: Conceptualization, Methodology, Investiga­
tion, Writing – original draft, Writing – review & editing.
Declaration of Competing Interest
The authors declare that they have no known competing financial
interests or personal relationships that could have appeared to influence
the work reported in this paper.
Acknowledgements
This work has been funded by national funds through FCT –
Fundação para a Ciência e a Tecnologia, I.P., Project UIDB/05037/2020.
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Rui Pedro Lourenço has a Bachelor Degree in Computer Science and a PhD in Manage­
ment Science, and is currently Auxiliary Professor at the Faculty of Economics and a
research member of CeBER (Centre for Business and Economics Research) at the University
of Coimbra. He is the author of several conference proceedings, scientific articles and book
chapters on the topics of Public Administration Digital Transformation (eGovernment;
eGovernance), Digital Democracy (eDemocracy; eParticipation) and Open Government
(Open Government Data, Transparency and Public Accountability). Between 2017 and
2019 he worked as Technical Advisor at the cabinet of the Minister of the Presidency and
Administrative Modernization (Portuguese Government). He was also a member of the
Digital Competencies National Initiative (INCoDe.2030) general coordination team.