THE ROLE OF OMBUDSMAN INSTITUTIONS IN ADMINISTRATIVE ACCOUNTABILITY: A COMPARATIVE PERSPECTIVE

Abstract

The transformation of modern administrative governance requires mechanisms that ensure state institutions remain accountable, transparent, and responsive to the public they serve. In this context, ombudsman institutions have gained growing attention as independent oversight bodies that address complaints, scrutinize administrative practices, and defend individuals against potential misuse of public power. This study aims to assess the functions, strengths, and limitations of national ombudsman institutions by focusing on their structural frameworks and operational dynamics in selected European countries. The research is guided by the objective of understanding how institutional independence, legal mandates, and political environments influence the effectiveness of ombudsman models in delivering administrative accountability. The methodology employed is a comparative qualitative approach, using three case studies as representative examples of differing legal traditions and governance systems. Data were gathered through the analysis of official documents, legal texts, and institutional outputs such as reports and policy recommendations. Content analysis was applied to identify patterns of practice, jurisdictional reach, and modes of public engagement. The analysis was framed by principles of public law, administrative justice, and democratic oversight, allowing for a cross-sectional evaluation of institutional impact and resilience. The findings indicate that while each ombudsman institution operates within its own national context, they share core objectives in promoting legality, fairness, and citizen protection. Variations in structure and authority affect their capacity to influence public administration, but moral credibility, procedural accessibility, and transparency remain critical tools for effectiveness. The study highlights the adaptability of ombudsman institutions, their role in safeguarding administrative integrity, and their potential to evolve in response to both internal and external pressures. The conclusions point to the importance of preserving independence, expanding public outreach, and reinforcing cross-border cooperation to strengthen their contribution to democratic governance across Europe.