Centre for Civic Education (CCE) welcomes the proposed amendments to the Law on Higher Education, particularly those related to Article 100 and the introduction of mandatory entrance examinations for enrolment in postgraduate studies following the completion of undergraduate studies with 180 ECTS credits. These amendments may contribute to strengthening quality criteria, especially through a combination of undergraduate academic performance and entrance examination results.
However, it is important to recall that this is not a novelty, as the University of Montenegro has already established a practice whereby its organisational units, in line with their autonomy and as needed, have introduced entrance examinations. Thus, entrance exams have long been in place for medicine, dentistry, and arts faculties at the undergraduate level, while fields such as law, psychology, physiotherapy, and nursing organise entrance examinations at the master’s level, demonstrating that this issue has already been within their autonomous decision-making.
The CCE has previously highlighted the need for a cautious interpretation of the existing Article 172 by certain faculties and has called for clearer normative regulation, which is why we consider the proposed amendments to be justified. Specifically, the proposed additions of Articles 172a and 172b refer to transitional student cohorts and the obligation of institutions, upon a student’s request, to issue a specialist studies diploma if the student has obtained 60 ECTS credits at the first master’s level. In this way, the accreditation framework is effectively adjusted.
We recall that the transitional provisions under Article 172 of the current Law on Higher Education must be applied in favour of the students to whom they apply. The provision clearly stipulates that a student has the right, upon their own request, to receive a specialist studies diploma if they have obtained at least 60 ECTS credits at the master’s level.
The legislator must not leave room for legal uncertainty or retroactive application. This means that amendments adopted after the entry into force of the law cannot be applied to already submitted requests for the issuance of specialist studies diplomas by students who, within a two-year master’s programme, have obtained a total of 60 ECTS credits (from both the first and second year).
The CCE considers that these amendments should be viewed through the lens of preserving university autonomy and ensuring the consistent application of existing norms, while improving the quality of the system without undermining students’ rights.
Finally, we recall that in October 2025, a new Law on Higher Education was adopted with the intention of facilitating, rather than complicating, the position of students, particularly those transitional categories defined under Article 172. The purpose of the law must be respected, and amendments aimed at clarification and the removal of ambiguities always represent the best path towards improvement.
Snežana Kaluđerović, Senior Legal Advisor