The Note comments on several changes in the Revised Proposal as compared to the 2022 draft, including the following:
- The rules on making and processing requests have been improved in several small but significant ways.
- Changes to three of the exceptions are more mixed and, overall, the regime of exceptions, although notably improved from the 2010 Policy, still contains a restrictive public interest override and a veto for third parties over information provided by them.
- The list of information in the Annex which will be routinely disclosed has been expanded to cover basic operational information, but a clear framework for proactive disclosure is still lacking.
