In parallel, the number of complaints filed with the Council against the resolutions (or administrative silence) of State bodies and entities has also experienced significant growth, with 1,397 cases registered, 19.4% more than in 2023.
Of the 1,530 statewide claims resolved in 2024, 95.6% were admitted to the proceedings and, of these, approximately two-thirds (64.5%) concluded with statements favourable to the claimants in their different modalities: full, partial or formal stimatoria (the latter implies that the administration provided the information once the claim was filed with the Council, having violated the citizen’s right to receive the information within the time period established in the Transparency Law).
The report 2024 once again highlights that a very high percentage of complaints continue to be filed for alleged denial of the request for information due to administrative silence. Some 42% of the cases resolved by the Council in 2023 at the state level had been submitted for this reason, compared to 33.7% in the previous year.
As for the most recurrent issues of the complaints resolved, it is worth mentioning those related to the public service (234 files), especially on remuneration and productivity received by public employees, and on the conduct of selective processes (access to copies of examinations and assessment reports, fundamentally).
In addition, more than one hundred resolutions have been issued on information on procedures, files and administrative documentation, as well as on contracts, public works and infrastructures. In this area, the Council has strengthened its doctrine on contractual transparency, recalling that confidentiality clauses or reservations cannot be understood in any way, in line with the provisions of the contract law itself.
The denial of access to information on high-level positions—relating mainly to representation or travel expenses—also led to a significant number of complaints, as well as that related to access to grant and aid files. There have also been numerous complaints about institutional advertising spending.
On the other hand, it is worth highlighting, for its interest, the claims on access to the source code or to the technical specifications of the algorithms used by the Public Administrations. The resolutions issued in 2024 in this matter reflect the Council’s doctrine favorable to access in order to guarantee the explicability of computer applications (and the algorithms that support them), which results in an effective safeguard against arbitrariness or discriminatory biases in the decision-making totally or partially automated by the Administration.
With regard to the bodies and entities against which complaints are filed, the ministerial departments are the main recipients of the state-wide complaints resolved in 2024. In contrast to ministries, 939 were interposed, representing 61.4% of the total.
As detailed in Annex I of the report, the Ministry of the Interior is the department that concentrated the largest number of complaints (203 files, 13.3 per cent of the total), followed by the Ministry of the Presidency, Justice and Relations with the Courts (100 complaints, 6.5 per cent of the total), the Ministry of Finance (with 72 complaints, 4.7 per cent) and the Ministry for Digital Transformation and Public Service (63 complaints, 4.1 per cent).
Claims of an autonomous and local scope
In the autonomous and local areas, where the Council only has competence when attributed to it by agreement, as already mentioned, 701 claims were resolved in 2024, which is 35.7% less than the previous year. This decrease is mainly due to the fact that, since November 2023, Castilla-La Mancha has had its own body to guarantee the right of access and, as a result, the Council has ceased to exercise the function of guardianship of the law in its territory, with the Council’s competence being limited to the autonomous communities of Asturias, Cantabria, La Rioja, Extremadura, and the Balearic Islands, as well as the autonomous cities of Ceuta and Melilla. Regarding the number of autonomous and local complaints received during the year, there was a decrease of 19.5%, with an entry of 576 files.
With regard to the outcome of the cases processed in 2024 at the regional and local level, the percentages show similar magnitudes to those of the State, since 89.6% of the claims were admitted for processing, and 66.1% ended with statements of opinion in their different modalities. It should be noted that 73.5% of the complaints were filed by administrative silence, which is an improvement compared to 2023, when 85.4% were filed for this reason.
The main issues of the complaints were requests for information related to town planning, economic information, public employment, health, administrative records and public procurement.
The autonomous community from which the largest number of resolved claims come is Extremadura, with 172 cases, followed by the Balearic Islands (142), Cantabria (113) and Asturias (108).
The municipalities concentrated 55.9% of the complaints, followed by the autonomous communities, with 32.2%.
Compliance with the resolutions
With regard to compliance with the resolutions, which the CTBG constantly monitors by publishing the result quarterly on its website, the report states that, of the resolutions issued in 2024 that required execution, as of March 31, 2025, the Council did not record compliance with 15.2% of those issued at the state level and 34.6% of those at the regional and local levels.
50 judicial appeals filed in response to Council resolutions
With regard to litigation against Council decisions, in 2024, 43 judicial appeals were filed against Council resolutions at the state level and 7 against resolutions at the regional and local levels, 50 in total, which represents 30.6% less than the previous year.
Evaluation of active advertising obligations: 14.6% more entities evaluated
On the other hand, following the trend of recent years, the Council intensified in 2024 its activity of evaluating compliance with the obligations of active publicity, which is the other main function attributed to the institution. As established in the annual plan approved at the beginning of the year, 291 bodies and entities were individually evaluated to verify whether they publish and update on their websites the relevant information to control their management to which they are bound by the Transparency Law. This represents 14.6% more entities evaluated than in 2023.
All the evaluations were carried out by Council officials and with their own resources, without outsourcing any of the processes. The general reports corresponding to the different groups of subjects evaluated, as well as the individual reports of each body or entity, 379 in total, are published on the Council’s website. It should be remembered that in the reports the Council includes specific recommendations addressed to the evaluated entities so that they can improve compliance with their transparency obligations.
Although, in general terms, there is a progressive improvement in the degree of compliance, there are still high rates of non-compliance in some obligated subjects who do not find justification when the LTAIBG has been in force for ten years. The average compliance rate stood at 51.6%, although there is a large disparity between the entities analyzed and several have reached full compliance.
Consultations on the application of the transparency law increased by 60.9%
In parallel with the two essential functions that have just been outlined, that of safeguarding the right of access to public information and evaluating the obligations of active transparency, many other tasks related to the other functions entrusted to the Council were carried out. These include advising and responding to queries made, both by agencies and by individuals, on issues related to the interpretation and application of public transparency regulations. There were 222 formal consultations, 60.9% more than in 2023, in addition to a myriad of informal consultations received by various means, such as email and telephone. There were also 92 reports on State or regional policy projects related to transparency.
Training and collaborative activities
In the belief that the training of public employees is essential for the effective implementation of the Transparency Act, in 2024 the Council continued to promote various training actions, such as its cycle of periodic seminars on essential aspects of transparency and access to public information, which addressed issues of growing interest and relevance, such as algorithmic transparency, transparency in public procurement, or confidentiality clauses as a limit to the right of access.
In addition, in 2024 the Council intensified its actions of institutional cooperation in the international arena. For example, it organized a workshop in Madrid that brought together representatives of 13 other European commissioners and guarantor councils for two days.
Cooperation with other European supervisory authorities has recently culminated in the creation in May (during the 16th International Conference of Information Commissioners in Berlin) of the European Network for Access to Information and Transparency (ENTRI), of which CTBG has been elected a member of its executive committee.
According to the president of the Transparency Council, José Luis Rodríguez Álvarez, 2024 was “a fertile year in results and that, in addition, ended with a very special anniversary when in December it celebrated its first decade of operation”. “The Council is a young institution, which is still in the process of consolidation, but which, over the last ten years, has progressively strengthened and gained specific weight with an objective and independent action, with which it has contributed decisively to the construction of the public transparency system in Spain.”
Within this consolidation process, an important milestone took place in 2024, when the new Statute of the Council was approved, which strengthens it organically and functionally as an independent administrative authority for the better fulfillment of its functions, “pending the materialization of the announced reform of Law 19/2013, of December 9, on transparency, access to public information and good governance (LTAIBG), in which the remaining pending issues must be addressed, among others, the attribution of coercive powers to the institution.”