The presentation discusses the ETACA Guidelines and is structured into three main parts, followed by conclusions. 

Part one provides context for the ETACA guidelines and introduces some of their most critical aspects in light of the European Charter of Fundamental Rights. 

Part two analyzes the Swedish experience with cooperative compliance over the years. The Swedish case is unique and extensively debated. The Swedish Constitution establishes a principle of open access to all documents held by public authorities: this includes information and documents part of cooperative compliance programs. Insights are drawn from Swedish literature and praxis to assess how well the ETACA guidelines consider or do not consider the consequences of the principle of publicity of documents held by public authorities. 

Part three examines international legal instruments, such as the Council of Europe Convention on Access to Official Documents, that may introduce legal challenges similar to those presented by the Swedish Constitution but that remain largely undebated in the context of cooperative compliance projects. An argument is made for if and how the ETACA guidelines meet the international legal standards. 

The conclusions outline a few lessons learned from the discussion.