Bureaucratic behavior in the implementation of freedom of information laws: evidence from a field experiment in Belgian municipalities

Abstract Freedom of Information (FOI) laws are widely adopted to promote transparency, yet their implementation diverges from formal legal expectations. This article examines how variations in FOI requests shape administrative responses and what these patterns reveal about bureaucratic behavior in municipal administrations. Drawing on a randomized field experiment across Belgian municipalities, the study analyzes how public officials respond to identical FOI requests varying by requester identity and legal framing. The findings show that responsiveness is not neutral but varies systematically across request characteristics and contexts. Ordinary citizens receive higher disclosure rates than institutional or advocacy actors, and invoking FOI law increases compliance for some requesters while reducing it for others. These patterns suggest that administrative responses – understood as observable expressions of bureaucratic behavior – are shaped by how officials interpret implications of requests, including perceived risk and accountability. The article advances a behavioral interpretation of FOI implementation as an embedded administrative practice.