Centre for Civic Education (CCE) assesses that the low level of implementation of reform commitments from the Reform Agenda 2024–2027, particularly in the area of the rule of law, indicates a lack of genuine political will and weaknesses in institutional capacities, which slows down the European integration process at a crucial stage and increases the risk of delays in withdrawing funds from the EU Reform and Growth Facility for the Western Balkans.
The Growth Plan is aimed at accelerating European integration through economic development and the implementation of structural reforms. Through this instrument, the EU allocated € 383.5 million to Montenegro, of which 110 million are grants, and the rest comes in the form of loans under favourable conditions. Access to these funds is conditioned by the implementation of measures from Montenegro’s Reform Agenda 2024–2027, which gives this document a key role in the economic and political development of the country.
The Government adopted the first drafts of the reform measures in December 2023, and the final version in September 2024. The European Commission granted official approval in October 2024. It should also be recalled that the process of drafting the Reform Agenda was non-transparent and lacked an adequate consultation process.
The Reform Agenda contains 130 quantitative and qualitative measures across four priority areas: business environment and private sector development; digital and energy/green transition; human resources development; and rule of law and fundamental rights.
In the area of the business environment, 34 reform steps are foreseen, of which three out of seven planned were fulfilled by June 2025, including the establishment of a register of state-owned enterprises and companies with state participation, increased transparency of intergovernmental agreements and contracts, and the adoption of Montenegro’s Spatial Plan. Key measures, such as improving the integrity of inspections, revising the anti-corruption framework and reforming corporate governance in state-owned enterprises, as noted by the EU, have not been implemented.
The second area, focused on digital infrastructure and the transition to sustainable energy sources, envisages 42 reform steps, and by mid-year seven of the twelve planned measures have been fulfilled. These include the liberalisation of the electricity market, the adoption of the National Broadband Infrastructure Development Plan, improvement of e-government, the alignment of the Information Security Act with the NIS2 Directive, and measures to protect energy-vulnerable consumers. However, key steps are delayed, such as the full transposition of the electricity market integration package, the adoption of legislation on renewable energy sources (RED II Directive), auctions for at least 400 MW of renewable energy capacity, a building renovation strategy and an operational structure for a just transition.
The third area, human resources development, has 24 reform steps focused on education, employment and social inclusion. So far, only one measure was planned and it has been implemented, relating to defining a minimum package of guaranteed social services and its financing through the De-institutionalisation Strategy.
The weakest results were recorded in the fourth area – rule of law and fundamental rights, crucial for progress in EU accession negotiations, where a total of 30 reform measures were foreseen, particularly in the domains of judiciary, fight against corruption and organised crime, and freedom of expression and media. In this period, only one of the five planned steps was implemented – the appointment of the President of the Supreme Court, although even that process lacked necessary transparency. Constitutional amendments in line with the recommendations of the European Commission, Venice Commission and GRECO were not carried out, data exchange between the Special State Prosecutor’s Office (SSPO) and other bodies wan not established, nor a system of standard operating procedures in the judiciary for handling cases of gender-based violence, and visa-free travel with countries for which the EU requires a visa regime has not been abolished.
In overall, results range from 20% in rule of law, through 43% in business environment, to 58% in digital and energy transition, while in human resources development the only planned measure has been implemented.
CCE previously warned that the slow pace of reforms costs Montenegro European funds and credibility, and that the state has so far withdrawn only 38% of the total value of reform measures, i.e., € 18.3 out of the planned € 52.1 million, implementing only 12 out of a total of 25 planned measures for this period. It is also indicative that the Government attempted to mislead the European Commission, claiming that 17 measures had been implemented, while the European Commission, after its evaluation, confirmed only 12 as completed.
Although funds may still be withdrawn next year, current delays indicate that Montenegro will end the year with a significant backlog, given an additional 32 planned measures by the end of the year, on top of the previous backlog of 13 measures. No publicly available data exists regarding Government activities to accelerate this process, nor regarding accountability of institutions and their managers for delays to date.
CCE concludes that the delay indicates a lack of political commitment and weaknesses in public administration, where nepotism, clientelism and party-based employment continue to limit the capacity to implement reforms.
Ivan Kašćelan, project assistant