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Peer-Review Record

Comparative Approach to Municipal Transparency: Which Index Best Assesses Compliance in Spain?

Sustainability 2025, 17(5), 1842; https://doi.org/10.3390/su17051842
by Elisabeth Zafra-Gómez *, Lorena Márquez-Arenas, María Angustias Navarro-Ruiz, Pablo Povedano-Fernández and Jose Luis Zafra-Gómez
Reviewer 1: Anonymous
Reviewer 2: Anonymous
Reviewer 3:
Sustainability 2025, 17(5), 1842; https://doi.org/10.3390/su17051842
Submission received: 18 November 2024 / Revised: 27 December 2024 / Accepted: 11 February 2025 / Published: 21 February 2025
(This article belongs to the Section Sustainable Management)

Round 1

Reviewer 1 Report

Comments and Suggestions for Authors

Without a shadow of a doubt, transparency represents a very significant basis of public activities. It is crucial for freedom and democracy and, nowadays, there is a general understanding that citizens want information and easy access to that information. In this context, legislation plays a key role, as it is exposed in this article (through Spanish Law 19/2013, of 9 December, on Transparency, Access to Public Information, and Good Governance, among other regulatory frameworks).

This issue has become increasingly significant in recent years, as well as the relationship between transparency and trust -specifically, the importance of transparency to increasing citizen trust-. Therefore, from an academic perspective, I find this research interesting and relevant. Its objective is clear: to assess the transparency of Spanish local authorities using a transparency index, with the aim of achieving an improvement in the levels of compliance.

I consider that the article begins with an accurate introduction to the topic, and that the structure and content are appropriate, including a literature review, methodology and data, results and conclusions.

Finally, I usually make one recommendation: to specify who this article is addressed to.

Author Response

Without a shadow of a doubt, transparency represents a very significant basis of public activities. It is crucial for freedom and democracy and, nowadays, there is a general understanding that citizens want information and easy access to that information. In this context, legislation plays a key role, as it is exposed in this article (through Spanish Law 19/2013, of 9 December, on Transparency, Access to Public Information, and Good Governance, among other regulatory frameworks).

This issue has become increasingly significant in recent years, as well as the relationship between transparency and trust -specifically, the importance of transparency to increasing citizen trust-. Therefore, from an academic perspective, I find this research interesting and relevant. Its objective is clear: to assess the transparency of Spanish local authorities using a transparency index, with the aim of achieving an improvement in the levels of compliance.

I consider that the article begins with an accurate introduction to the topic, and that the structure and content are appropriate, including a literature review, methodology and data, results and conclusions.

Thank you to the reviewer for the comments and suggestions, which have been addressed. Regarding the point raised, we would like to note that the text now includes the statement: "This paper is aimed at information users who are interested in the actions carried out by the TC and the External Control Bodies (OCEX), showing how transparency is measured by two bodies with auditing powers in relation to the principle of transparency.

Reviewer 2 Report

Comments and Suggestions for Authors

Dear authors_

Thank you for the opportunity to read this work. The topic is relevant, so it has also been extensively studied in the literature. However, I highlight, below, some important aspects that the authors should improve for possible publication.

I believe that the introduction of the paper should be improved, beyond indicating that the multiplicity of transparency indexes shows that there is no consensus on how to measure transparency. Although the authors begin by indicating the importance of transparency for good governance and the achievement of the SDGs, these two arguments can be reinforced and improved, in order to raise the interest of the research topic. On the other hand, what does a new transparency index bring when there are already so many? This requires further justification to draw attention to the interest of this work.

In the theoretical framework approach what the authors do is to explain, to expose what transparency is and to expose a series of indexes. I suggest two aspects to improve this part of the work:

·         First, to expose the theoretical frameworks that can support this research. The authors point to one of them, agency theory, but they barely develop it in relation to the topic. There are other theoretical frameworks, such as institutional theory, which also deserve to be incorporated into the work.

·         Second, this research topic has been widely addressed by the literature. The authors should improve this part of the research by reviewing this type of work to show where the gap in the literature is.

There are several authors, such as A. Navarro-Galera, P. Tirado-Valencia or M. Ruiz-Lozano, who have worked on this subject and whose works are not only missing, but whose reading may help the authors to improve the introduction and the theoretical framework by addressing the issues indicated.

On the other hand, when presenting the different transparency indexes, it would be interesting to add a comparative table of different dimensions or aspects of each index. Likewise, the number of indicators of the indexes is indicated, but the exact indicators are not presented. All this is important to show the value and interest of your own index proposal.

Regarding the empirical study.

The selection of the sample is based on the size of the municipalities. This criterion is based on previous literature, but the authors do not provide any reference in this regard. You can consult one of the works of the authors mentioned for this.

The methodology does not indicate how many people made the valuation of each municipality. In this type of study, each individual in the sample, in this case, each municipality, is analyzed by two judges. Subsequently, to evaluate the reliability of the scores obtained, the degree of coincidence of both judges is calculated according to the Holsti index. None of this is mentioned in the research.

It should be noted that in the presentation of the results, the authors make an effort to explain the cases of greater discrepancy between the scores obtained in each index by some municipalities.

The paragraph between lines 434-440 should be at the beginning of the empirical study, to clarify the scope of this part of the work.

The conclusions could also be improved by distinguishing between a discussion of the results and a conclusion section. In the discussion of results, the authors should emphasize the differences between the two indices compared. In this regard, it is important to highlight the different purpose of the promoting body of each index, the items, the way each item is assessed (in one index it is dichotomous and in the other, it is not), etc. All this may be behind the results and is the subject of further discussion. These issues are not results of the work, but discussion and should be separated from the conclusions. To the above should be added a discussion of results compared with previous studies in this same field.

I think the work requires a thorough review of some of the aspects indicated. Thank you, very much and good luck, with your research.

Author Response

Thank you for the opportunity to read this work. The topic is relevant, so it has also been extensively studied in the literature. However, I highlight, below, some important aspects that the authors should improve for possible publication.

I believe that the introduction of the paper should be improved, beyond indicating that the multiplicity of transparency indexes shows that there is no consensus on how to measure transparency.

Thank you to the reviewer for the comments and suggestions, which have been addressed. Regarding the point raised, we would like to note that the text now includes the statement: "The World Bank defines governance as ‘the way in which power is exercised in the management of a country's economic and social resources for development’. There has been significant concern about the declining level of trust in government and the detrimental effects this has on government and societal cohesion [A,B]. In this international context, researchers have sought to identify the factors which facilitate or promote this behaviour, to design and implement dissuasive measures [B]. Greater trust will equate to better governance [A]. According to the World Bank, transparency is not a sufficient condition for controlling corruption, but it is a necessary condition in most cases [C]."

Regarding the point raised about good governance, we would like to note that the following text has been added to the literature review to emphasize the importance of transparency for good governance:

"According to [E], it is difficult and controversial to define the principles of good governance. The United Nations Development Program (UNDP, ‘Governance and Sustainable Human Development, 1997’) enunciates a set of principles that, with slight variations, appear in much of the literature. Accountability is mentioned as one of the principles of good governance, and is related to transparency. The 12 Principles of Good Governance are enshrined in the Strategy for Innovation and Good Governance at Local Level, adopted by decision of the Committee of Ministers of the Council of Europe in 2008. They cover issues such as ethical conduct, the rule of law, efficiency and effectiveness, transparency, sound financial management, and accountability. To ensure this, the various bodies need to provide themselves with the tools and means to make information available to citizens [F, G]. According to [H], [I] produced the multi-criteria of good governance principles for local government based on the operation research literature and decision analysis. The governance principles are (i) political stability, voice, and accountability; (ii) market access and regulation; (iii) government effectiveness; and (iv) the rule of law and corruption prevention. A study using a south-east Asian country [J] validated governance principles: transparency, the rule of law, virtue, accountability, and participation. [K] applied the governance principles (legitimacy and transparency) as an indicator of local governance quality. Other authors, such as [L], have referred to the numerous studies that have emphasized that transparency is a key element of good governance [M, N, Ñ, O, P]."

Although the authors begin by indicating the importance of transparency for good governance and the achievement of the SDGs, these two arguments can be reinforced and improved, in order to raise the interest of the research topic.

Regarding the point raised about good governance, we would like to note that the following text has been added to the literature review to emphasize the importance of transparency for good governance and its role in achieving the Sustainable Development Goals (SDGs):

“This is an issue that has been widely discussed in the literature in recent years. According to [E], in a context of sustainable governance, transparency practices on sustainability can improve the effectiveness, efficiency, and accountability of public entities.

Transparency practices regarding the sustainability of public policies are particularly important for local governments due to their direct contact with citizens, the volume of resources that the governments manage and the tenuous government financial circumstances [L,D,Q]. Several studies have tried to identify the factors that can contribute to greater disclosure of information on sustainability in public bodies, identifying, among others, cultural factors and the development of right to information laws [D,R,S,T]. However, the conclusions obtained by [T] show that the transparency laws of these European countries have made a limited contribution to the online dissemination of information on sustainability in local governments, and that there remains considerable room for improvement.”

On the other hand, what does a new transparency index bring when there are already so many? This requires further justification to draw attention to the interest of this work.

In relation to this issue, we should point out that this work provides the creation of an index that synthesizes and allows numerical measurement of the level of achievement of the parameters contemplated in the TC's Audit Guide, as well as other indices created by the transparency audit bodies in Spain. The TC and the OCEX have similar audit functions and the indices developed on the basis of them should be similar to measure this audit principle. Our objective is to determine whether they measure the same thing or not, so we do not work with indices that are so different in terms of the objectives to be achieved.

 

In the theoretical framework approach what the authors do is to explain, to expose what transparency is and to expose a series of indexes. I suggest two aspects to improve this part of the work:

  • First, to expose the theoretical frameworks that can support this research. The authors point to one of them, agency theory, but they barely develop it in relation to the topic. There are other theoretical frameworks, such as institutional theory, which also deserve to be incorporated into the work.

We have proceeded to develop the theoretical framework of the study as follows:

“In the context of transparency, the Agency Theory, formulated by Jensen and Meckling (1976), is essential to understand the problems arising from the relationships between principals (shareholders, owners or citizens) and agents (managers, directors or administrators). The interests of both parties may not be aligned, leading to conflicts and opportunistic behavior. One of the main challenges addressed by this theory is information asymmetry, which refers to the advantage that the agent obtains by possessing privileged information that is not available to the principal. In this framework, transparency policies are presented as crucial tools to facilitate the control and accountability of public and private managers [55]. However, Agency Theory has been criticized for focusing exclusively on the interests of the principal, neglecting the needs of other stakeholders or the possible natural alignments between the interests of agents and principals [56]. Despite these limitations, information disclosure remains a key tool for managing relationships and mitigating potential conflicts.

Likewise, Legitimacy Theory offers a complementary perspective, emphasizing that organizations operate within a broader social framework. According to this approach, an institution's ability to gain and maintain social acceptance depends on its alignment with the prevailing norms, values and expectations of society [57] . In this scenario, the adoption of transparency policies becomes a fundamental means to reinforce the social legitimacy of institutions[58][59][60]. The need for transparency increases especially in controversial or sensitive situations, such as government decisions that may generate negative reactions. According to[61] , in these cases, greater disclosure of information can help mitigate negative repercussions and protect the reputation of institutions. This approach also stresses the importance of the active participation of citizens in municipal management, using tools that encourage their direct involvement and the strengthening of trust in public institutions.

In line with these theories, neoinstitutionalism adds a new angle to the analysis of transparency by focusing on social and cultural influences on organizational decisions. Emerging between the 1970s and 1980s, this approach stresses that organizations tend to adopt similar practices in response to institutional pressures, not necessarily to improve operational efficiency, but to gain social legitimacy [62]. From this perspective, the adoption of transparency policies aligns with prevailing social expectations, strengthening the public perception of institutions as responsible and trustworthy actors. According to [63], transparency practices enable organizations to maintain their legitimacy within a constantly changing social environment.

Finally, New Public Management (NPM), which emerged in the 1980s and 1990s, offers a results-oriented vision of public administration, inspired by private sector practices. Based on principles such as decentralization, competition and efficiency, NPM finds in transparency and accountability essential elements to align the interests of public managers with those of citizens[64]. Although this approach has been criticized for prioritizing efficiency over values such as equity and democratic participation[65], there is no doubt that it reinforces the importance of transparency as a key tool to promote public trust and ensure alignment between public policies and citizen expectations.

In this context, the audit carried out by the Court of Audit constitutes an essential mechanism within this theoretical framework, its main objective being to reduce the asymmetry of information existing between public agents and citizens, ensuring that public resources are managed in a transparent and efficient manner. Thus, by providing information that minimizes the risks of opportunistic behavior, it simultaneously reinforces institutional legitimacy by aligning government actions with social expectations.”

  • Second, this research topic has been widely addressed by the literature. The authors should improve this part of the research by reviewing this type of work to show where the gap in the literature is.

There are several authors, such as A. Navarro-Galera, P. Tirado-Valencia or M. Ruiz-Lozano, who have worked on this subject and whose works are not only missing, but whose reading may help the authors to improve the introduction and the theoretical framework by addressing the issues indicated.

Reference has been made to the aforementioned studies, as well as to others of a similar nature that have dealt with the issue in question in the text incorporated both in the Introduction and in the Review of the literature, with the corresponding references being added in the Bibliography.

On the other hand, when presenting the different transparency indexes, it would be interesting to add a comparative table of different dimensions or aspects of each index. Likewise, the number of indicators of the indexes is indicated, but the exact indicators are not presented. All this is important to show the value and interest of your own index proposal.

 

We have added a comparative table featuring the transparency indices developed in the literature.

Table X.Comparison of Transparency Indexes: Dimensions, Aspects, and Indicators

 

Index

Type

Number of indicators

Description

Theory

Source

ITA

Practical

80

Six areas to the 110 biggest municipalities

Agency

https://transparencia.org.es/ita-2017/

DYNTRA

Practical

159

Citizens’ collaboration

Legitimacy

https://www.dyntra.org

Infoparticipa

Practical

41

Representation in a map with colors

Agency

http://www.mapainfoparticipa.com

MESTA

Practical

21

Evaluation in three areas and two dimensions: compulsory content and information quality

Agency and Legitimacy

https://www.gobierto.es/blog/20170510-mesta

Jorge et al. (2011)

Lourenço et al. (2013)

Academic

13

Financial information

Agency

Jorge et al. (2011)

Lourenço et al. (2013)

Piotrowski & Bertelli (2010)

Academic

35

Three Categories

Agency

Piotrowski & Bertelli (2010)

Da Cruz et al. (2016)

Academic

76

Collaboration with public entities

Agency

Da Cruz et al. (2016)

Rawlins (2009)

Academic

38

Responsibility, important information, and participation

Agency

Rawlins (2009)

Composite Transparency Indicator (CTI)

Academic

24

Evaluation through two dimensions: integrity and performance

Legitimacy

Galli, Rizzo & Escaglioni (2017)

Italian Transparency Index

Academic

13

Evaluation through two dimensions: integrity and efficiency

Legitimacy

Alaimo et al. (2023)

Regarding the empirical study.

The selection of the sample is based on the size of the municipalities. This criterion is based on previous literature, but the authors do not provide any reference in this regard. You can consult one of the works of the authors mentioned for this.

This issue has been reinforced and clarified at the beginning of section 3 of the revised version of the manuscript, where bibliographical references have been added to support and substantiate the decision to focus our study on municipalities with larger populations. In summary, the choice to focus on large municipalities is justified by the greater social and media pressure to promote transparent policies, the positive correlation between population size and financial transparency, as well as the greater availability of data that these local authorities tend to present, which facilitates research and analysis of transparency.

The methodology does not indicate how many people made the valuation of each municipality. In this type of study, each individual in the sample, in this case, each municipality, is analyzed by two judges. Subsequently, to evaluate the reliability of the scores obtained, the degree of coincidence of both judges is calculated according to the Holsti index. None of this is mentioned in the research.

Thank you for your comment. At the end of section 3.1.1. we describe in detail the methodology used in the evaluation of each municipality, specifying that each has been assessed by two independent evaluators. We have also added how the Holsti index was calculated, which yielded a value of 0.87 in our study, reflecting a high degree of agreement between the two evaluators. Finally, in order to clearly illustrate how the score of each municipality is obtained, Annex I has been included, where the evaluation of the municipality of Madrid, the calculation of its score and the value of the corresponding Holsti index are presented.

It should be noted that in the presentation of the results, the authors make an effort to explain the cases of greater discrepancy between the scores obtained in each index by some municipalities.

The paragraph between lines 434-440 should be at the beginning of the empirical study, to clarify the scope of this part of the work.

Following your suggestion, the paragraph between lines 434 and 440 has been moved to the end of the first paragraph of section 3, in order to clarify the scope of the empirical part of the paper.

The conclusions could also be improved by distinguishing between a discussion of the results and a conclusion section. In the discussion of results, the authors should emphasize the differences between the two indices compared. In this regard, it is important to highlight the different purpose of the promoting body of each index, the items, the way each item is assessed (in one index it is dichotomous and in the other, it is not), etc. All this may be behind the results and is the subject of further discussion. These issues are not results of the work, but discussion and should be separated from the conclusions. To the above should be added a discussion of results compared with previous studies in this same field.

In order to address these suggestions, section 4.1 (‘Result Discussion’) has been added, where we delve into the differences observed between the two indices analysed, paying special attention to the items that make them up and the assessment procedures (differentiating between dichotomous and non-dichotomous indicators). In this way, it is concluded that complying with the minimum information requirements at the legal level (TC) does not necessarily imply a greater breadth and depth of information (BTI), nor vice versa. Likewise, the results are contrasted with previous studies that use indices based on dichotomous indicators and with others that integrate indicators of a non-dichotomous nature. Finally, the section 5 (‘Conclusions’) has been reorganised to emphasise the divergences between the two indices and to offer an explanation of the factors that may be behind these differences.

I think the work requires a thorough review of some of the aspects indicated. Thank you, very much and good luck, with your research.

We hope these additions address the reviewer’s concerns comprehensively.

We would like to thank the reviewer for their valuable comments, which have significantly improved the initially submitted work.

Reviewer 3 Report

Comments and Suggestions for Authors

The article presents an interesting analysis, but its methodology raises several concerns. Specifically, the comparison of indices with differing methodologies is problematic. These indices often use distinct variables, weighting systems, and aggregation methods, making direct comparisons inherently unreliable. The results, therefore, are predictable rather than insightful - simply reflecting the discrepancies in the underlying methodologies rather than offering new knowledge. Consequently, the conclusions drawn from such comparisons lack originality.

Another critical oversight is the limited conceptualization of transparency. While the article discusses transparency, it fails to consider the perspective of open data. Transparency is increasingly understood in terms of data accessibility, allowing stakeholders to independently verify and analyze information. This omission diminishes the depth and relevance of the discussion, as open data is a cornerstone of modern transparency standards.

Overall, the article could benefit from a more robust methodological framework and a broader exploration of the transparency concept to deliver original and impactful conclusions.

Author Response

The article presents an interesting analysis, but its methodology raises several concerns. Specifically, the comparison of indices with differing methodologies is problematic. These indices often use distinct variables, weighting systems, and aggregation methods, making direct comparisons inherently unreliable. The results, therefore, are predictable rather than insightful - simply reflecting the discrepancies in the underlying methodologies rather than offering new knowledge. Consequently, the conclusions drawn from such comparisons lack originality.

We believe that, given that both are oversight bodies of the principle of transparency, there should not be significant differences. For this reason, the expectation highlighted by the reviewer is not expected to arise in this work. However, the conclusions indicate that, despite measuring the same principle, two bodies operating under the same regulatory framework produce very different evaluations. We have added a discussion section to address this important result.

Another critical oversight is the limited conceptualization of transparency. While the article discusses transparency, it fails to consider the perspective of open data. Transparency is increasingly understood in terms of data accessibility, allowing stakeholders to independently verify and analyze information. This omission diminishes the depth and relevance of the discussion, as open data is a cornerstone of modern transparency standards.

We have added the following text:

In this sense, open data in public administrations has been consolidated as a fundamental concept in efforts to increase transparency and accountability regarding the use of information. Since 2010, open data has begun to be associated with broader reforms related to open government [D], which in turn has linked this practice with transformations in public management [E].

Currently, open data portals act as a key interface to promote transparency [G]. In recent years, several studies have highlighted that the publication of open government data (OGD) in these portals has a positive impact on processes that promote transparency, particularly in areas prone to problems such as corruption, waste of resources and inefficiency [H,I,J].

Overall, the article could benefit from a more robust methodological framework and a broader exploration of the transparency concept to deliver original and impactful conclusions.

We have implemented a more robust comparative methodology.

We would like to thank the reviewer for their valuable comments, which have significantly improved the initially submitted work.

 

Round 2

Reviewer 2 Report

Comments and Suggestions for Authors

The work has improved compared to the initial version.

Cordial greetings

Reviewer 3 Report

Comments and Suggestions for Authors

I appreciate the corrections made by the authors. I believe that in its current form the text can be accepted for publication

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