General comments of the Institute Alternative on the Draft Amendments to the Law on Electronic Government
Positive sides of the proposed amendments are:
- Prescribing deadline for submitting data on electronic registers and information systems submitted to the Ministry of Public Administration, in order to enable coordination and management of projects in the field of information societies;
- Deletion of restrictions that only state authorities and public administration bodies submit data on information systems and electronic registers;
- Prescribing deadlines for establishing electronic services and delivery of catalogue of services
However, there are certain inconsistencies and vagueness in the text which can limit the positive effect of new solutions, which primarily refer to:
- Insufficiently precise scope of application of the Law;
- Unclear competencies of different bodies in the implementation and supervision over the implementation of the Law;
- Non-prescribing obligatory supervision over electronic data exchange.
- Non-prescribing bodies’ obligation to compile a list of all registers / official records which they possess, regardless of format;
- Non-prescribing bodies’ obligation to compile a list of all services they provide, regardless of format.
