Analysing and Assessing Accountability: A
Conceptual Framework
1
Mark Bovens*
Abstract: It has been argued that the EU suffers from serious accountability deficits. But
how can we establish the existence of accountability deficits? This article tries to get to
grips with the appealing but elusive concept of accountability by asking three types of
questions. First a conceptual one: what exactly is meant by accountability? In this article
the concept of accountability is used in a rather narrow sense: a relationship between
an actor and a forum, in which the actor has an obligation to explain and to justify his
or her conduct, the forum can pose questions and pass judgement, and the actor may
face consequences. The second question is analytical: what types of accountability are
involved? A series of dimensions of accountability are discerned that can be used to
describe the various accountability relations and arrangements that can be found in the
different domains of European governance. The third question is evaluative: how should we
assess these accountability arrangements? The article provides three evaluative perspec-
tives: a democratic, a constitutional and a learning perspective. Each of these perspectives
may produce different types of accountability deficits.
I Accountability and European Governance
There has long been a concern that the trend toward European policy making is not
being matched by an equally forceful creation of appropriate accountability regimes.
2
Accountability deficits are said to exist and even grow, compromising the legitimacy
of the European polity.
3
But how can we make a more systematic assessment of the
1
An earlier, much longer version of this article was published as EUROGOV paper C-06-01. It built to
some extent on a chapter on public accountability which has been published in E. Ferlie, L. Lynne and
C. Pollitt (eds), The Oxford Handbook of Public Management (Oxford University Press, 2005) and a Dutch
paper which was published in W. Bakker and K. Yesilkagit (eds), Publieke verantwoording (Boom, 2005).
Earlier versions have been presented at Connex team meetings in Leiden, Belfast and Mannheim. I thank
Carol Harlow, Paul ‘t Hart, Peter Mair, Yannis Papadopoulos, Richard Rawlings, Helen Sullivan,
Thomas Schillemans, Marianne van de Steeg and Sonja Puntscher-Riekmann for their valuable comments
on previous versions of this article.
* Professor of Public Administration, Utrecht School of Governance, Utrecht University, The Netherlands.
2
P. Schmitter, How to Democratize the European Union...AndWhyBother? (Rowman and Littlefield,
2000).
3
T. Bergman and E. Damgaard (eds), Delegation and Accountability in the European Union (Frank Cass,
2000); C. Harlow, Accountability in the European Union (Oxford University Press, 2002); D. Curtin, Mind
the Gap: The Evolving European Union Executive and the Constitution, Third Walter van Gerven Lecture
European Law Journal, Vol. 13, No. 4, July 2007, pp. 447–468.
© 2007 The Author
Journal compilation © 2007 Blackwell Publishing Ltd, 9600 Garsington Road, Oxford, OX4 2DQ, UK
and 350 Main Street, Malden, MA 02148, USA
various accountabilities regarding the exercise of European governance, and establish
whether and where accountability deficits do exist?
Accountability is one of those golden concepts that no one can be against. It is
increasingly used in political discourse and policy documents because it conveys an
image of transparency and trustworthiness. However, its evocative powers make it also
a very elusive concept because it can mean many different things to different people, as
anyone studying accountability will soon discover.
The aim of this article is first to develop a parsimonious analytical framework that
can help to establish more systematically whether organisations or officials, exercising
public authority, are subject to accountability at all. This is basically a mapping
exercise—for example what are the accountabilities, formal and informal, of a particu-
lar European agency? For this purpose we need to establish when a certain practice or
arrangement qualifies as a form of accountability at all. In order to give more colours
to our map, we also want to be able to distinguish several, mutually exclusive, types of
accountability. Second, and separately, this article aims to develop an evaluative frame-
work that can be used to assess these accountability maps more systematically. For this
purpose we need perspectives that can help us to evaluate these accountability arrange-
ments: are the arrangements to hold the agency accountable adequate or not, sufficient
or insufficient, effective or ineffective?
The article is organised on the basis of three different questions, which provide three
types of building blocks for the analysis of accountability and European governance.
First a conceptual question: what exactly is meant by accountability? Then an analyti-
cal one: what types of accountability are involved? The third question is an altogether
different, evaluative question: how should we assess these accountability relations,
arrangements and regimes?
II The Concept of Accountability
A From Accounting to Accountability
The word ‘accountability’ is Anglo-Norman, not Anglo-Saxon, in origin. Historically
and semantically, it is closely related to accounting, in its literal sense of bookkeeping.
According to Dubnick,
4
the roots of the contemporary concept can be traced to the
reign of William I, in the decades after the 1066 Norman conquest of England. In 1085
William required all the property holders in his realm to render a count of what they
possessed. These possessions were assessed and listed by royal agents in the so-called
Domesday Books. This census was not held for taxation purposes alone; it also served
as a means to establish the foundations of royal governance. The Domesday Books
listed what was in the king’s realm; moreover, the landowners were all required to swear
oaths of fealty to the crown. By the early twelfth century, this had evolved into a highly
centralised administrative kingship that was ruled through centralised auditing and
semi-annual account giving.
In the centuries since the reign of William I of England, accountability has slowly
wrestled free from its etymological bondage with accounting. In contemporary political
(Europe Law Publishing, 2004); W. van Gerven, The European Union: A Polity of States and People (Hart,
2005).
4
M. J. Dubnick, Seeking Salvation for Accountability, paper presented at the Annual Meeting of the
American Political Science Association (2002), pp. 7–9.
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discourse, ‘accountability’ and ‘accountable’ no longer convey a stuffy image of
bookkeeping and financial administration, but they hold strong promises of fair and
equitable governance. Moreover, the accounting relationship has almost completely
reversed. ‘Accountability’ does not refer to sovereigns holding their subjects to account,
but to the reverse: it is the authorities themselves who are being held accountable by
their citizens.
Since the late twentieth century, the Anglo-Saxon world in particular has witnessed
a transformation of the traditional bookkeeping function in public administration into
a much broader form of public accountability.
5
This broad shift from financial account-
ing to public accountability ran parallel to the introduction of New Public Manage-
ment by the Thatcher Government in the UK and to the Reinventing Government
reforms initiated by the Clinton-Gore Administration in the USA.
6
The emancipation of ‘accountability’ from its bookkeeping origins is therefore
originally an Anglo-American phenomenon—if only because other languages, such as
French, Portuguese, Spanish, German, Dutch or Japanese, have no exact equivalent
and do not (yet) distinguish semantically between ‘responsibility’ and ‘accountability’.
7
However, what started as an instrument to enhance the effectiveness and efficiency of
public governance, has gradually become a goal in itself. Accountability has become an
icon for good governance, first in the USA,
8
but increasingly also in the EU. As a
concept, however, ‘accountability’ is rather elusive. The term ‘has come to stand as a
general term for any mechanism that makes powerful institutions responsive to their
particular publics’.
9
It is one of those evocative political words that can be used to patch
up a rambling argument, to evoke an image of trustworthiness, fidelity and justice, or
to hold critics at bay. For anyone reflecting on accountability, it is impossible to
disregard these strong evocative overtones. As an icon, the concept has become less
useful for analytical purposes, and today resembles a dustbin filled with good inten-
tions, loosely defined concepts and vague images of good governance. Nevertheless, we
should heed the summons from Dubnick
10
to save the concept from its advocates and
friends, as he so succinctly puts it.
B Broad and Narrow Accountability
In contemporary political and scholarly discourse ‘accountability’ often serves as a
conceptual umbrella that covers various other distinct concepts, such as transparency,
equity, democracy, efficiency, responsiveness, responsibility and integrity.
11
Parti-
cularly in American scholarly and political discourse, ‘accountability’ often is used
interchangeably with ‘good governance’ or virtuous behaviour. For O’Connell,
12
for
5
Harlow, op. cit. note 3 supra,p.19.
6
C. Pollitt and G. Bouckaert, Public Management Reform: A Comparative Analysis (Oxford University
Press, 2nd edn, 2005).
7
R. Mulgan, ‘“Accountability”: An Ever Expanding Concept?’ (2000) 78 Public Administration 555;
Harlow, op. cit. note 3 supra, pp. 14–15; Dubnick, op. cit. note 4 supra.
8
Dubnick, op. cit. note 4 supra.
9
R. Mulgan, Holding Power to Account: Accountability in Modern Democracies (Pelgrave, 2003).
10
Dubnick, op. cit. note 4 supra.
11
Ibid; Mulgan, op. cit. note 7 supra, at 555; R. D. Behn, Rethinking Democratic Accountability (Brookings
Institution Press, 2001), pp. 3–6.
12
L. O’Connell, ‘Program Accountability as an Emergent Property: The Role of Stakeholders in a
Program’s Field’, (2005) 65(1) Public Administration Review 86.
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Journal compilation © 2007 Blackwell Publishing Ltd.
example, accountability is present when public services have a high quality, at a low
cost and are performed in a courteous manner. Koppell
13
distinguishes no less than five
different dimensions of accountability—transparency, liability, controllability, respon-
sibility, responsiveness—that are each icons and umbrella concepts themselves. Such
very broad conceptualisations of the concept make it very difficult to establish empiri-
cally whether an official or organisation is subject to accountability, because each of the
various elements needs extensive operationalisation itself and because the various
elements cannot be measured along the same scale. Some dimensions, such as trans-
parency, are instrumental for accountability, but not constitutive of accountability;
others, such as responsiveness, are more evaluative instead of analytical dimensions.
Accountability in this very broad sense is basically an evaluative, not an analytical,
concept. It is used to qualify positively a state of affairs or the performance of an actor.
It comes close to ‘responsiveness’ and ‘a sense of responsibility’—a willingness to act in
a transparent, fair and equitable way. Accountability in this broad sense is an essen-
tially contested and contestable concept,
14
because there is no general consensus about
the standards for accountable behaviour, and because they differ from role to role, time
to time, place to place and from speaker to speaker.
15
In this article, I will not define the concept in such a broad, evaluative sense, but in
a much more narrow, sociological sense. ‘Accountability’ is not just another political
catchword; it also refers to concrete practices of account giving. The most concise
description of accountability would be: ‘the obligation to explain and justify conduct’.
This implies a relationship between an actor, the accountor, and a forum, the account-
holder or accountee.
16
I will therefore stay close to its etymological and historical roots
and define accountability as a specific social relation.
17
Accountability is a relationship
between an actor and a forum, in which the actor has an obligation to explain and to justify
his or her conduct, the forum can pose questions and pass judgement, and the actor may
face consequences.
C Accountability as a Social Relation
This narrow definition of accountability contains a number of elements that need
further explanation. The actor can be either an individual, in our case an official or civil
servant, or an organisation, such as a public institution or an agency. The significant
other, the accountability forum, can be a specific person, such as a superior, a minister
or a journalist, or it can be an agency, such as parliament, a court or the audit office.
13
J. Koppell, ‘Pathologies of Accountability: ICANN and the Challenge of “Multiple Accountabilities
Disorder”’, (2005) 65(1) Public Administration Review 94.
14
See W. B. Gallie, ‘Essentially Contested Concepts’, in M. Black (ed.), The Importance of Language (Ithaca,
1962), pp. 121–146.
15
See E. Fisher, ‘The European Union in the Age of Accountability’, (2004) 24(1) Oxford Journal of Legal
Studies 495, at 510, for similar observations about the use of ‘accountability’ in the European context.
16
C. Pollitt, The Essential Public Manager (Open University Press/McGraw-Hill, 2003), p. 89.
17
Following, among others, P. Day and R. Klein, Accountabilities: Five Public Services (Tavistock, 1987),
p. 5; B. S. Romzek and M. J. Dubnick, ‘Accountability’, in J. M. Shafritz (ed.), International Encyclopae-
dia of Public Policy and Administration, Vol. 1: A–C (Westview Press, 1998), p. 6; J. S. Lerner and
Ph. E. Tetlock, ‘Accounting for the Effects of Accountability’, (1999) 125 Psychological Bulletin 255;
H. E. McCandless, A Citizen’s Guide to Public Accountability: Changing the Relationship Between Citizens
and Authorities (Trafford, 2001), p. 22; C. Scott, ‘Accountability in the Regulatory State’, (2000) 27(1)
Journal of Law and Society 40; Pollitt, op. cit. note 16 supra, p. 89; Mulgan, op. cit. note 9 supra, pp. 7–14.
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The relationship between the forum and the actor can have the nature of a principal–
agent relation—the forum being the principal, for example parliament, who has del-
egated authority to a minister, the agent, who is held to account himself regularly about
his performance in office. This is often the case with political forms of accountability.
18
However, as we will see, in many accountability relations, the forums are not principals
of the actors, for example courts in cases of legal accountability or professional asso-
ciations in cases of professional accountability.
The obligation that lies upon the actor can be formal or informal. Public officials
often will be under a formal obligation to render account on a regular basis to specific
forums, such as supervisory agencies, courts or auditors. In the wake of administrative
deviance, policy failures or disasters, public officials can be forced to appear in admin-
istrative or penal courts or to testify before parliamentary committees. An example is
former European commissioner Edith Cresson, who was brought before a Belgian
penal court and the European Court of Justice after allegations of nepotism and
corruption were made against her. But the obligation can also be informal, as in the
case of press conferences and informal briefings, or even self-imposed, as in the case of
voluntary audits.
The relationship between the actor and the forum, the actual account giving, usually
consists of at least three elements or stages. First of all, it is crucial that the actor is
obliged to inform the forum about his or her conduct, by providing various sorts of data
about the performance of tasks, about outcomes or about procedures. Often, particu-
larly in the case of failures or incidents, this also involves the provision of explanations
and justifications. Account giving is more than mere propaganda, or the provision of
information or instructions to the general public. The conduct that is to be explained and
justified can vary enormously, from budgetary scrutiny in cases of financial accountabil-
ity, to administrative fairness in cases of legal accountability, or even sexual propriety
when it comes to the political accountability of Anglo-American public officials.
Second, there needs to be a possibility for the forum to interrogate the actor and to
question the adequacy of the information or the legitimacy of the conduct—hence, the
close semantic connection between ‘accountability’ and ‘answerability’.
Third, the forum may pass judgement on the conduct of the actor. It may approve of
an annual account, denounce a policy, or publicly condemn the behaviour of an official
or an agency. In passing a negative judgement, the forum frequently imposes sanctions
of some kind on the actor.
It has been a point of discussion whether the possibility of sanctions is a constitutive
element of accountability.
19
Some would argue that a judgement by the forum, or even
only the stages of reporting, justifying and debating, would be enough to qualify a
relation as an accountability relation. I concur with Mulgan
20
and Strom
21
that the
possibility of sanctions of some kind is a constitutive element of narrow accountability
and that it should be included in the definition. The possibility of sanctions—not the
actual imposition of sanctions—makes the difference between non-committal provi-
sion of information and being held to account.
18
K. Strom, ‘Delegation and Accountability in Parliamentary Democracies’, (2000) 37 European Journal of
Political Research 261; K. Strom, ‘Parliamentary Democracy and Delegation’, in K. Strom et al. (eds),
Delegation and Accountability in Parliamentary Democracies (Oxford University Press, 2003), pp. 55–106.
19
Mulgan, op. cit. note 9 supra, pp. 9–11.
20
Ibid., p. 9.
21
Strom, ‘Parliamentary Democracy and Delegation’, op. cit. note 18 supra,p.62.
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