“大行政公开”理念将公开的对象从相对人全面升级为公众,认为行政行为说明理由不等于公开理由,从而确立行政行为理由公开制度,推动行政公开走向行政透明。理由公开制度不仅继承理由说明制度的功能并可克服其失灵,也是反腐利器,而且还具有提高治理绩效、维系官民和谐的重要作用,是真正的“共和”之道。具体行政行为中的不利行为和授益行为、抽象行政行为都应公开理由。行政行为理由公开制度构成行政治理现代化的重要支柱,我国目前缺乏该制度,未来制定《行政程序法》时应考虑建立之。 The concept of “big administrative openness” fully publicized the object of publicity from the relative to the public. The reasons for the administrative act are not equal to the public reasons, so as to establish an open system of administrative behavior reasons and promote the administrative openness toward administrative transparency. The open reasoning system not only inherits the justification of the function of the system but also overcomes its failure as well as the anti-corruption device. It also has the important function of improving governance performance and maintaining the harmony between officials and civilians, and is a true “republican” approach. The specific administrative acts of unfavorable behavior and behavior of interest, abstract administrative act should be an open reason. The open system of administrative reasons constitutes an important pillar of the modernization of administrative governance. At present, our country lacks the system and should be considered in the future when formulating the Administrative Procedure Law.