It could be. I would leave that to the decision of the cabinet of Parliament to debate.
In issues where a group, or a government, decides what should be proactively published, that should be separated out from the Access to Information Act. That act itself should have oversight to ensure the government is publishing information when it has a duty to do so. For example, if there are public interest overrides that require them to publish, we need someone to check in on that to make sure the government is doing it. That is a separate role from the Information Commissioner protecting individual rights to access unpublished information.