According to the provisions of Article 38, paragraph 1 of the Law on Free Access to Information of Public Importance ("Official Gazette of RS", Nos. 120/04, 54/07, 104/09 and 36/10), a responsible person of a public authority designates one or more officials (the so-called authorized persons) to respond to requests for free access to information of public importance. The same article stipulates the duties of these persons. Paragraph 3 of this Article sets out that if an authorized person is not designated, a responsible person of a public authority is competent to respond to requests.

Transitional provisions of this Law in Article 49, paragraph 1 stipulate the deadline of 30 days of the date when this Law comes into force to implement this provision. In this Article, the term "appointment" of this/these person(s) is indeed used, although it is actually not an appointment, but designation of an authorized person, which is obvious from the quoted Article 38 of the Law, since those are not office holders. This does not mean that a person who is appointed to an office in a municipality in accordance with the regulations on local self-government cannot be designated as an authorized person. Since according to the Law on Local Self-Government a municipality has multiple government bodies within the meaning of Article 3 the Law on Free Access to Information of Public Importance, nothing is preventing from designating one authorized person to respond to requests to access information for all municipal government bodies (municipal assembly, municipal council, president of a municipality, municipal administration). In practice, authorized persons are mainly heads of municipal administrations.

From the Commissioner's reply No. 011-00-00174/2013-03 of 8 March 2013