Centre for Civic Education (CCE) once again warns of the alarmingly slow implementation of obligations under Montenegro’s Reform Agenda 2024–2027, as a result of which Montenegro has still not been able to access a significant portion of the financial resources envisaged under the Growth Plan, the European Union’s key financial instrument for the Western Balkans.
The Growth Plan is based on a clearly defined timeline for implementing reforms, with the gradual disbursement of funds every six months, depending on the level of implementation of obligations in individual reporting periods. At the end of December 2025, the third six-month period was completed, after which Montenegro submitted a report on the implementation of reform steps – both those from the most recent period and obligations carried over from previous cycles. However, even after the third reporting period, the obligations from the first two cycles have still not been fully met.
The deadline for fulfilling the obligations from the first reporting period was initially December 2024, and was later extended to February 2025. Despite the additional time, Montenegro fulfilled only seven out of a total of 14 reform steps within that period, although in its own assessment it had at the time marked as many as ten as fully implemented. In the following six-month period, two more of the seven remaining steps were completed, while an additional three were implemented in the latest cycle. In other words, obligations that, according to the original plan, should have been completed more than a year ago have still not been finalised even after two deadline extensions and three consecutive reporting cycles.
More precisely, of the 14 reform steps from the first period, 12 have been implemented to date, while two remain unfulfilled. Both relate to the area of the green transition and fall under the responsibility of the Ministry of Energy. Particularly indicative is the step concerning the alignment of legislation with the Renewable Energy Directive (RED II). The Government assessed this step as fully implemented as early as the first reporting period, while the European Commission had been pointing out from the outset that key by-laws were missing and that the process of alignment with EU rules had not been completed. Although certain regulations have since been adopted and some progress has been made, the full transposition of the Directive has still not been completed. The fact that the Government, in its latest report, itself returned this same step to the category of unfulfilled obligations confirms that the initial assessment was premature, and also points to serious shortcomings not only in the implementation of reforms, but also in the Government’s own system for monitoring and assessing progress. Due to the specific nature of the reforms from the first reporting period, the final deadline for implementation and for accessing the funds linked to these two steps remains the end of 2026.
The results of the second reporting period are also not encouraging. Out of a total of 11 reform steps, Montenegro implemented only three within the prescribed deadline, while another three were completed in the following six-month period. This means that five reform steps still remain unfulfilled. Since the deadline for their subsequent implementation expires after one year, Montenegro must complete them by the end of this month in order to avoid losing the funds linked to their results. This involves more than EUR 15 million, the disbursement of which is highly uncertain and directly depends on the ability of institutions to successfully complete the outstanding obligations within a very short timeframe.
However, even if it successfully completes these steps, Montenegro will face a far more serious challenge by the end of the year.
The third reporting period was also the most extensive, comprising a total of 32 reform steps. To date, only 14 have been implemented, meaning that the remaining 18 must be completed by the end of the year in order to avoid the loss of funds linked to their implementation.
The Reform Agenda precisely defines the institutions responsible for implementing each of the 130 reform steps. Primary responsibility lies with the ministries, but also with administrations, agencies and other state administration bodies. The Parliament of Montenegro also has a particularly important role, as, although it is not always formally listed as the lead institution for individual obligations, it is an indispensable factor in the implementation of reforms that require amendments to the legislative framework and improvements to procedures.
A total of 15 institutions and bodies are directly responsible for implementing the 25 reform steps that are currently unfulfilled. Ministries dominate among them – 12 in total. The Parliament of Montenegro appears as the responsible institution for two steps, while the Agency for the Protection of Competition and the Special State Prosecutor’s Office (SSPO) are responsible for one step each.
The largest number of unfulfilled obligations falls under the responsibility of the Ministry of Public Administration, which is responsible for four reform steps. Two steps each fall under the responsibility of the Ministry of the Interior, the Ministry of Energy, the Ministry of Finance, the Ministry of Ecology, Sustainable Development and Development of the North, the Ministry of Education, Science and Innovation, and the Ministry of Economic Development. One reform step each falls under the responsibility of the Ministry of Justice, the Ministry of Transport, the Ministry of Foreign Affairs, the Ministry of Social Welfare, Family Care and Demography, and the Ministry of Spatial Planning, Urbanism and State Property.
In addition to the institutions formally designated as the lead bodies for individual steps, their implementation in a significant number of cases also depends on coordinated action by other authorities and bodies, further confirming the need for much more effective inter-institutional cooperation.
CCE believes that all of this indicates that the problem is no longer merely the pace of reforms, but also the ability of those leading the process to reliably plan, coordinate and monitor their own obligations, as well as the lack of accountability on their part. At the same time, the time available for corrections is rapidly diminishing, while the risk of permanently losing European funds is becoming increasingly likely.
Ivan Kašćelan, Project Assistant