The 2019 Directive on Open Data and the Re-use of Public Sector Information draws together two traditions in ensuring proactive access to government data. On one hand, it embraces the concept of ‘open data’, a concept rooted in government accountability and transparency for citizen participation. On the other hand, the directive covers the re-use of non-sensitive public sector information, which is deemed crucial for the internal market and realisation of the European data economy. Indeed, the directive itself is a further iteration of an earlier 2003 directive on the re-use of public sector information. Yet, despite the appearance of a seamless fusion of the different concepts, it is important to interrogate critically to what extent open data is actually incorporated. While the shorthand title for directive the Open Data Directive (ODD), there is a risk that much of the open data movement’s demands fall outside of its purview. Hence, the present paper undertakes a careful analysis of the ODD. It asks firstly, how does the directive align with and diverge from the rationale and requirements of the movement for open data? And secondly, what are the implications of this for citizen participation? The findings show that the original largely technical principles of open data are somewhat respected and incorporated into the ODD but are disjointed from the rationale behind them. References to citizen participation in the directive and supporting documentation, while welcome, risk being little more than window dressing.