National Transparency Regimes: Rules or Principles? A Comparative Analysis of the United States and The Netherlands

Abstract

Technology development and democratization have been identified as the general drivers of the worldwide thrust in transparency. But what transparency regimes do these drivers generate in different countries? This mixed method study indicates that national regimes are different due to pre-existing institutional differences and critical junctures in the historical development of transparency regimes. Our analysis shows that the U.S. transparency regime can be characterized as a rules-based approach while a principles-based transparency regime prevails in the Netherlands. This article nuances the debate about the global character of transparency and highlights two different outcomes of the push for transparency.