Abstract: The COVID-19 epidemic prevention and control command organization set up all over the country has played an important role in the disclosure of epidemic information.However,this deliberation and coordination body is not the legal subject of government information disclosure obligation in our country.The reason is that the defects of the administrative subject theory lead to many practical difficulties in the government information disclosure obligation subject system.In this regard,based on the economic,social and political reality of our country and the acceptability of the subject of the obligation of government information disclosure,we should consider it from the functional standard on the basis of separation from the theory of administrative subject.Whether or not to enjoy and exercise the power of public administration in accordance with the law should be taken as the reconstruction logic of the subject system of government information disclosure obligation.The functional standard has many advantages:it is no longer divorced from the reality of administrative organization,no longer pays too much attention to the independent personality of administrative law;it is longer limited to national administrative functions and powers,and no longer limits the integration of administrative subject and administrative litigation defendant qualification and so on.When carrying on the concrete reconstruction,we can unify the "quality" of the obligation subject of government information disclosure with the name "reality" of the authority of public administration,clarify the "quantity" of the obligation subject of government information disclosure with the legitimacy of the authority of public administration,and deal with the conflict of the right of acceptance of the obligation subject of government information disclosure with the principle of first acceptance.

Key words: government information disclosure, administrative subject, obligation subject, functional standard, public administration authority