Centre for Civic Education (CCE), through its continuous monitoring of the implementation of Montenegro’s Reform Agenda 2024–2027, notes that key governance and communication mechanisms were established only after the reform process had already begun, indicating an improvised approach to implementation.
Although the Reform Agenda represents one of the most important reform and financial instruments currently being implemented in Montenegro, numerous elements of the system for coordination, monitoring, and communication were introduced with significant delays or have yet to be fully completed. This has further complicated the implementation of reform commitments and contributed to delays that now pose a serious risk to the withdrawal of funds from the Growth Plan, the EU instrument designed to support and reward reforms.
It is important to recall that immediately following the adoption of the Reform Agenda, a Coordination Body for Monitoring its Implementation was established with the task of ensuring timely monitoring of implementation, coordination among institutions, and reporting on progress. At the very first meeting of this body, held on 28 October 2024, the need to establish a clear legal and institutional framework for coordination, implementation, oversight, and reporting was recognised. However, apart from the adoption of the Law on Ratifying the Agreement on Accession to the Reform and Growth Facility and the signing of the Loan Agreement between the European Union and Montenegro, which did not regulate the governance structure of the process in greater detail, no significant progress was made in establishing a comprehensive normative framework for this system by the end of 2025.
Furthermore, the Supervisory Board of the Reform and Growth Facility convened for the first time only in November 2025, at a moment when the third reporting period was already approaching its conclusion. During that meeting, the European Commission representative, Barbara Jesus-Gimeno, emphasised the urgent need to adopt the Regulation on the Implementation of EU Financial Support through the Reform and Growth Facility. In December 2025, the Government adopted the Information on the Establishment of the Institutional Framework, Management and Control System, and the Method of Implementing European Union Support through the Reform and Growth Facility. However, the Regulation that more specifically prescribes the implementation of financial support and the coordination of reforms envisaged under the Reform Agenda entered into force only on 6 May 2026.
In other words, the key document defining the functioning of the Reform Agenda implementation system and specifying coordination, oversight, and reporting mechanisms was adopted only after a significant portion of the reform process was already underway. Although certain mechanisms and bodies existed beforehand, it remains unclear why an act of such importance, one that should have contributed to greater clarity of responsibilities, improved institutional coordination, and more effective monitoring of progress, was adopted only at a stage when delays in the implementation of certain reform steps had already become evident. As a result, an opportunity was missed to establish from the outset a clear division of responsibilities, more effective coordination among institutions, and a more systematic oversight of obligations, thereby ensuring a higher level of overall effectiveness.
Particularly indicative is the fact that the institutional and governance architecture was functioning in practice before the rules governing its operation had been formally defined. While such an approach may be sustainable in the short term, in the long run it creates room for ambiguity regarding competences, differing interpretations of obligations, and difficulties in determining responsibility for potential shortcomings.
An additional concern is the fact that the Communication Plan, whose preparation was envisaged by the Regulation,was never formally adopted, despite the fact that a draft had been prepared and made publicly available. The purpose of this document was to establish a coordinated and systematic approach to communication regarding the Reform Agenda, both towards the public and among the institutions involved in its implementation, through clearly defined activities, responsibilities, and communication channels. Although certain activities were likely carried out even without the formal adoption of the plan, its absence created space for inconsistent internal and external communication, reduced visibility of the reform process, and insufficiently defined responsibility for communicating and monitoring one of the country’s most important reform undertakings.
At a time when Montenegro faces a serious risk of losing part of the financial support available through the Growth Plan for the Western Balkans, while delays in the implementation of reform steps continue to grow, it is difficult to avoid the conclusion that a significant share of responsibility lies precisely in the failure to establish and formalise the governance and coordination system in a timely manner. From the very beginning, the Reform Agenda required a high degree of organisation, a clear division of responsibilities, and an effective institutional response. Unfortunately, practice to date demonstrates that the key elements of this system were established belatedly, while the consequences of the absence of a systematic approach are becoming increasingly visible. At the same time, responsibility for the resulting delays and missed opportunities remains largely unacknowledged.
Ivan Kašćelan, Project Assistant