Abstract
Transparency in EU Public Procurement regime can be divided into advertising obligations under the EU Procurement Directives and access to documents under national laws of Member States. Due to limited EU rules on post-award transparency the disclosure rules are subject to national laws. Here history, political development, divisions to private and public law traditions as well as the tendency for corruption seems to have affected to the level of transparency in each Member State. This paper provides a comparative analysis and discusses certain differences of national transparency rules including their objectives, scope, active publication obligations as well as some commercial concerns in public procurement regime.
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