Centre for Civic Education (CCE) once again draws attention to the fact that Montenegro continues to miss a significant portion of the potential offered by the European Union through the Growth Plan, a key financial instrument designed for the countries of the Western Balkans.
CCE notes that on 16 January, without holding a formal Government session and based on the consent of a majority of Government members obtained remotely, i.e. by telephone, the Government adopted the Third Semi-Annual Report on the Implementation of Montenegro’s Reform Agenda under the EU Reform and Growth Facility 2024–2027. In that document, the Government reported the successful implementation of 24 measures, which is significantly below the originally planned scope.
The Report covers the status of implementation of reform steps envisaged for the third reporting period, which expired in December 2025, as well as unfulfilled steps from the previous two reporting periods, amounting to a total of 45 reform steps. Of the 32 steps whose implementation deadlines expired in December last year, the Government classified 17 as fully implemented. In addition, four out of five carried-over steps from the first reporting period and three out of eight from the second reporting period were fulfilled.

The overall level of implementation to date amounts to 36 out of the planned 57 reform measures, i.e. 63.16% of what was envisaged for the period so far. Notably, despite the fact that this represents a partial outcome accompanied by serious delays compared to the initially established deadlines, the Government assessed this performance as a “confirmation of commitment to key reform objectives.”
It is important to underline that the European Commission’s evaluation of the Third Report is still pending, as it provides the final assessment of the degree to which reform steps have been fulfilled. CCE recalls that discrepancies between the Government’s assessments and those of the European Commission were also present in previous reporting periods, and that unrealistic Government evaluations regarding the fulfilment of certain steps resulted in reduced disbursement of financial resources.
According to the data contained in the latest Report, of the 24 steps the Government marked as fulfilled, eight relate to the digital and energy, i.e. green transition, six concern the area of the rule of law, while five steps each pertain to the business environment and private sector development, and to human capital development.
It is particularly concerning that not all obligations from the first reporting period have been fulfilled even almost a year after the deadline, nor have five reform steps whose deadline was June 2025. Nevertheless, pursuant to Article 21 of EU Regulation 2024/1449, Montenegro may still receive funding for these steps if it is determined that they have been fulfilled within 24 months in the case of obligations from the first reporting period, and within 12 months in the case of steps from the second and third reporting periods.
Should the European Commission confirm the fulfilment of the steps from the third semi-annual report, Montenegro could receive approximately EUR 59.1 million on that basis. When combined with funds already disbursed in the previous period, this would amount to a total of approximately EUR 78.77 million out of the planned EUR 135.55 million, i.e. 58%. It should be emphasised that the total amount of released funds is proportionally reduced by approximately 7%, due to the previously paid advance, as has been the case so far.
Ivan Kašćelan, Project Assistant
