This paper provides a critical examination of the ETACA Guidelines. Part I ofthe paper offers an overview of the ETACA Guidelines, focusing on their corecomponents, followed by an introduction to Sweden’s experience with cooperative compliance. Part II critically analyzes the ETACA Guidelines through thelens of the Swedish legal system, highlighting Sweden’s distinctive approach, which has been widely debated due to its constitutional principle of open accessto nearly all documents held by public authorities. By leveraging insightsfrom Swedish literature and praxis, this analysis evaluates how well the ETACA guidelines account for—or neglect—the implications of the principle of publicity concerning public authority-held documents. The examination then extendsto a European and international perspective, encompassing the EU legal framework,the International Covenant on Civil and Political Rights, the Councilof Europe Convention on Access to Official Documents, and the Agenda 2030. These European and international instruments pose potential legal challenges similar to those arising under the Swedish Constitution, yet such challenges are overlooked in the context of the ETACA Guidelines. The paper discusses whether and how the ETACA Guidelines align with European and international legal standards and concludes outlining areas where the ETACA Guidelines might need refinement to better meet these legal standards.