Systems of local governance and how citizens participate: international review

Analyses local governance systems in seven case studies across the world, and how citizens are able to participate in local governance. The case studies are Denmark, England, Germany, New Zealand, Quebec, Scotland, and Uruguay.

1. Introduction

This report sets out the findings of an international review which analyses the local governance systems in a diverse range of case studies from around the world, and looks at the ways in which citizens are able to participate in those local governance systems.

This first section provides some explanatory background and context to the review; sets out the aim of the review; and describes how the review was undertaken: how case studies were selected; and the case study approach that was applied.


The work described in this report was undertaken to contribute evidence and analysis that would help inform the Local Governance Review (LGR), established to meet government commitments set out in successive Programmes for Government.

The LGR was launched in December 2017 and is being undertaken by the Scottish Government in partnership with the Convention of Scottish Local Authorities (COSLA), and working closely with the community sector in Scotland. The LGR is concerned with governance arrangements in Scotland and the decentralisation of power and decision-making. It is considering how powers, responsibilities and resources are shared across national and local spheres of government, and with communities. The review is being taken forward through three inter-connected streams of work looking at community, functional and fiscal empowerment.

The Local Governance Review follows earlier work by the Scottish Government focused on community empowerment. The Community Empowerment (Scotland) Act 2015, made changes to powers and responsibilities relevant to community planning, communities' right to buy land and take ownership of public assets, and participation of communities in local service delivery through the specific use of participation requests. Alongside the implementation of the legislation, Scottish Government and COSLA have worked together with the community sector to establish and build the application of participatory budgeting approaches in Scotland.

The issues of concern for the Local Governance Review have been the subject of repeated appraisal over the last twenty years by a number of commissions and independent reports, including:

The issues that have been commonly set out in these reports include:

  • a concern with government centralisation
  • the quality of local democracy
  • the lack of a constitutional/legal position for local government
  • the fiscal position of local government, and
  • the quality of citizen participation.

The reports and commissions also often draw unfavourable international comparisons between Scotland and other countries, particularly our neighbours in Europe, based on quantitative measures such as the average geographic size of local authorities and the size of the population they serve, the number of local authorities, and the ratio of elected councillors to local electorate.

The aim of the international review

This review is international in scope; it draws on examples not just from Europe but also from North and South America and Australasia. It takes a predominantly qualitative approach to produce in-depth case studies which offer a rich profile of local governance in each instance. It looks not simply at governance structures but at building an understanding of local governance as a system, recognising that the operation of governance involves inter-connections and dependencies vertically between levels of government and horizontally between similar local governance structures. And the review looks also at participative democracy; whether and how citizens can participate in local governance: the means and mechanisms available to them to influence or take part in local decision-making beyond voting in elections.

The review considers the case studies comparatively, to identify where there are common issues and challenges and patterns in the ways in which systems are designed and function, and where systems differ or diverge. Profiles of each case study describe the system of democratic and public service governance, including the different spheres of government and their functions, and mechanisms for public participation and offer an appraisal of each country's system of governance. The results of this review complement and add to the picture provided by the reports listed in the previous section.

The review does not identify an 'ideal type' of local governance that can be simply transferred and applied to Scotland. Instead, the review contributes to a deeper knowledge and a richer understanding of different local governance systems. In that way, it aims to act as resource for learning and reflection that can inform ongoing discussions about governance and democracy in Scotland.

It is difficult to capture the complexities of governance in a simple definition. The literature on governance proposes several definitions, but most rest on three dimensions: power/authority, decision-making and accountability. The Institute of Governance working definition of governance reflects these dimensions: governance determines who has power, who makes decisions, how other players make their voice heard and how account is rendered.[1]

How the review was undertaken

This section describes how the case studies were selected and the approach taken to the review.

The review was supported by a Research Advisory Group (RAG). The membership of the RAG comprised representatives from COSLA, Development Trusts Association Scotland (DTAS), Scottish Community Development Centre (SCDC), Scottish Community Alliance (SCA), Glasgow Disability Alliance (GDA), Scottish Government Analytical Services, Dr Oliver Escobar from the University of Edinburgh and Dr Sarah Skerratt then at Scotland's Rural College.

Selection of case studies

The selection of the case studies was guided by the following set of criteria, agreed with the RAG:

  • The case studies reflect a diverse range of countries/territories across the world, recognised as democratic systems
  • The case studies include examples from across the range of four identified 'state traditions'[2]
  • The selection of case studies is informed by data on the quality of governance, democracy and levels of inequality, measured across a range of international indices.

Data on the quality of governance, democracy and levels of inequality was drawn from the following international indices:

More information about the international indices is set out in Annex A. Based on an analysis of the data and suggestions from RAG members, a shortlist of 14 potential case studies was identified. There was research capacity available to review seven case studies. Using the criteria and the data analysis, and in consultation with the RAG, the following case studies were identified as scoring highly across the measures for inclusion in the review:

  • Denmark, Germany, New Zealand, Quebec, Uruguay; and England selected as the most similar case to Scotland. An analysis of Scotland provides a foundation for comparison.

Summary data on the specific measures in each index for the selected case studies is set out in Annex A.

Method of case-study review

This was a desk-based review drawing on published reports and other information online. It drew on a range of data: comparative information about countries worldwide; academic articles and books on local governance and international comparisons; specific data and information including qualitative sources such as Participedia, which is a recognised international database of participatory activity.

In addition, a range of international contacts was identified who could offer an informed assessment of the local governance system in a particular case study. Telephone interviews were conducted with these contacts between March and May 2019; most on a one to one basis, and a couple as paired interviews. Interviewees were also generous in sharing further information that contributed to the review. The interviewees included academics and others active in research about local governance and/or citizen participation, and practitioners working in some of the local governance systems. A list of interviewees is at Annex B.

Using the desk-based review and the interviews, a profile of each case study was produced. The profiles aim to provide a rich qualitative picture of the governance systems that covered the following themes:

  • Historical development of governance
  • Key reforms in local governance
  • Current structure and function of local governance
  • Financial arrangements in local governance
  • Local democracy and politics
  • Citizen participation in local governance

The case studies are at Annex C. Draft versions of completed profiles were shared with interviewees for review in October 2020, and a draft version of the full report shared in December 2020.

Additional note

The completion of this report was delayed following the onset of COVID-19 and the pause in the Local Governance Review over the early months of the Scottish Government's response to the pandemic.



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