The infographic “Tracking the Reform Agenda: From Adoption to EC Assessment” provides a clear and concise visual overview of the key stages in the reform process, from the initial adoption of policies to their evaluation by the European Commission. Designed to enhance understanding of this complex journey, it highlights critical milestones.
The European Commission has adopted an Implementing Decision approving the first release of funds to Serbia under the Reform and Growth Facility (RGF) for the Western Balkans. The decision follows the Commission’s assessment of Serbia’s compliance with the Facility’s preconditions, general payment conditions, and the achievement of reform steps due by December 2024.
Follow the money: Funds are released, disbursement may wait
Under this Implementing Decision, the Commission approved a net amount to be released under this first payment request of around EUR 56.55 million, of which 16.23 million is in grants and 40.32 million is in loans. The total gross amount is EUR 61.1 million, comprising if of 17.55 million in non-repayable financial support (grants) and EUR 43.60 million in loan support. Part of the instalment is used to clear advances i.e. the pre-financing of 7% foreseen for all beneficiaries under the RGF.
In line with the Facility and Loan Agreements, the approved funds will be transferred through the two main channels. The grant component will be made available through the Western Balkans Investment Framework (WBIF) and paid conditional on the conclusion of contribution arrangements and the submission of payment requests by the WBIF fund managers – EIB and the EBRD. This means that the EC implementing decision itself does not imply immediate cash transfers in form of grants. The loan component, on the other hand, is split into two components. Around EUR 14.0 million, or 34.75%, is earmarked for WBIF-linked investments and subject to separate contribution arrangements, while a sum of around EUR 26.3 million will be disbursed directly to Serbia’s Treasury.
Pre- and general conditions met: cautious but accommodating interpretation
The Commission concluded that the pre-conditions and general conditions for payment are met, including democratic governance, rule of law, macroeconomic stability, and public financial management. This assessment is made despite explicit concerns noted in the same document, including persistent political polarisation and pressure on independent institutions, and ongoing challenges related to judicial independence, citizens’ and media freedom.
The release of funds is also conditional on Serbia’s constructive engagement in the EU-facilitated dialogue with Kosovo, which constitutes a specific precondition for these two countries under the RGF. In its assessment, the Commission concludes that this precondition is fulfilled, based on Serbia’s continued participation in the dialogue and input provided by the European External Action Service.
Reform delivery: Success in green and digital, delays in “Fundamentals”
Out of seven reform steps that were due in December 2024, assessed under Serbia’s first payment request, 3 reform steps were assessed as fully achieved, and 4 steps were assessed as not achieved.
The partial reform delivery of Serbia’s Reform Agenda comes with the Commission confirmation that the reform steps relating to the electricity market integration with key steps taken toward day-ahead market coupling with regional partners and EU, the adoption of a bylaw transposing the EU Toolbox for 5G Security and the termination of visa-free access for at least three third countries in view of alignment with the EU visa regime.
On the other hand, three of the four steps that have not been achieved are in the area of “Fundamentals”. It should be noted that this assessment reflects the situation at the moment when Serbia submitted its request for payment and does not fully capture subsequent developments. In particular, this is relevant in two cases. First, regarding media legislation, the assessment refers to the period prior to the adoption of key media laws, notably amendments to the Law on Electronic Media, the Law on Public Information and Media, as well as the adoption of the Law on Public Service Media, which were adopted subsequently and whose progress is acknowledged in the EC Serbia 2025 Report. The remaining unfulfilled steps relate to electoral framework reforms, notably the functioning of the ODIHR-recommended working group, the voter register audit, and the re-election of the REM Council as well as, in the domain of anti-corruption with the requirement for Serbia to adopt an action plan covering the entirety of the anti-corruption strategy implementation (2025–2028). In the area of state aid transparency, the inventory submitted by Serbia at the time of the payment request did not fully address earlier Commission comments and was therefore considered not achieved. However, the adoption of the final state aid inventory was later confirmed in the EC Serbia 2025 Report.
Already behind schedule: Delays and backloging crucial reforms
This implementing decision and assessment arrive later than those for other beneficiaries in relation to the December 2024 reform deadlines. For example, North Macedonia and Montenegro received their corresponding decision in July 2025, which highlights uneven pacing in the Commission’s assessment and decision-making across beneficiaries.
At the time of adoption of this implementing decision, the assessments of the June 2025 reform steps are still pending, for which Serbia has 10 additional reform commitments. Furthermore, the deadline to report on the December 2025 deadlines passed was 15 January 2026, covering a further 20 reform steps. This sequencing highlights the pressure for reform delivery as Serbia is advancing into the next reform cycles while assessments of earlier deadlines remain pending.
For all non-achieved steps due in December 2024, the grace period runs until 31 December 2026. During this period, Serbia may still complete the outstanding reforms without an immediate financial penalty. However, as explained above, these postponed reforms increase the pressure for administration to deliver an increasing number of reforms over time that may affect future payment requests.
Photo: © European Union, 2026, CC BY 4.0, via Wikimedia Commons
For years, it seems that the Serbian Government has operated under the assumption that being almost aligned with EU criteria should be treated as meaningful progress. This mindset has contributed not only to the slow pace of reforms but also to the reality that, after eleven years of accession negotiations, Serbia has opened only two clusters. Under the EU Growth Plan, however, the habit of presenting partial fulfilment as genuine reform is becoming a structural obstacle, especially in the Reform Agenda’s area where reforms matter the most: Rule of Law and Fundamental Rights.
A striking example is the reform of the Unified Voter Register. The entire process – including the audit – was supposed to be completed by December 2024. Instead, Serbia approaches the end of 2025 with the reform still only halfway implemented. The legal framework exists, and the composition of the audit commission is progressing, but the core element, the audit itself, has not even begun. The Reform Agenda indeed provides a two-year grace period, meaning Serbia can still receive the funds associated with this step. Yet the fact that a reform so central to electoral integrity and democratic legitimacy has not been prioritised for an entire year raises a deeper concern: if even this cannot be delivered on time, what does that say about the seriousness of the overall reform effort?
A similar pattern is visible in the area of anti-corruption. Serbia adopted a new Anti-Corruption Strategy in July 2024 and, at first glance, appeared to fulfil its obligation by adopting the accompanying Action Plan in December of the same year. However, the Action Plan covers only 2024 and 2025, rather than the entire duration of the Strategy, despite the Reform Agenda explicitly requiring a full implementation cycle. The result is a reform that is presented by the Government as “completed,” but it is substantively partial. It illustrates how institutional energy is often invested in satisfying the appearance of compliance rather than in establishing the foundations of effective policy.
The case of the REM Council further reinforces this pattern. In addition to being a formal obligation under the Reform Agenda, Serbia also committed in December 2024 – through a non-paper submitted to Member States – to urgently complete the election of the Council as part of a broader effort to persuade Member States to support the opening of Cluster 3. A year later, eight of the nine
members have been elected, leaving the Council still incomplete. The process has been repeatedly interrupted, criticised by civil society, and burdened by procedural controversies. It is an improvement, but it is also plainly insufficient. In the logic of the Growth Plan, partial reform is simply not reform at all.
The only exception within this framework applies to quantitative steps – those formulated as reaching a specific number or percentage – which may be assessed as partially fulfilled and can therefore trigger partial disbursement, proportional to the share of the quantitative target that has been achieved. But qualitative reforms – and most rule-of-law obligations fall squarely into this category – cannot be treated this way. They must be implemented fully, not approximately or substantially. This is not a procedural detail; it is the core principle that separates reforms that exist on paper from reforms that genuinely reshape institutions.
This accumulation of “almost reforms” now appears to be complicating the European Commission’s assessment process. Serbia submitted its first and second payment requests in March and July 2025, yet no decision has been issued, well beyond the usual timeframe. Part of the delay likely reflects the Commission’s attempt to distinguish what is genuinely fulfilled from what is merely presented as such, requiring follow-up questions and clarifications from the Government. But the unusually long period may also indicate a deeper review – one that goes beyond individual reform steps and examines whether Serbia continues to meet the fundamental preconditions related to democratic institutions, rule of law, and the normalisation of relations with Pristina.
At this moment, Serbia faces a choice. Treating EU reforms as a checklist has produced diminishing returns. What is needed now is not more drafting, nor more announcements, but clear political will and institutional capacity to deliver reforms in full. Partial implementation cannot restore trust, cannot unlock credibility, and cannot bring Serbia closer to the European Union. Only genuine, complete reforms can do that.
Almost done is not done. And almost-membership is still not membership. If Serbia is serious about its European future, it must demonstrate that seriousness through reforms that are implemented fully, not symbolically, and through institutions that function in practice, not only on paper.
Author: Marko Todorović, European Policy Centre (CEP)
Image created with Gemini
Yesterday, the first plenary session of the Intersectoral Working Group for Monitoring the Implementation of the Reform Agenda of the Republic of Serbia was held, organised by the National Convention on the EU (NCEU) and the European Policy Centre (CEP) within the framework of the WB Reform and Growth Monitor project.
This platform was established to ensure the active participation of civil society in the implementation and monitoring of Serbia’s Reform Agenda, through tracking progress on reform steps, providing analytical support and external monitoring, as well as assessing their impact on European integration and informing the public about the results.
In its work, the IWG will cooperate closely with representatives of the European Union and state institutions to ensure effective oversight of the implementation of this important strategic document, which is linked to EU support amounting to EUR 1.6 billion by the end of 2027.
During yesterday’s session, the IWG adopted its Rules of Procedure, while subgroup coordinators presented their areas of work and upcoming plans. The discussion focused on the report from the first meeting of the Reform and Growth Facility (RGF) Monitoring Committee.
This platform represents an important step toward strengthening the contribution of civil society, academia, and the private sector to the reform implementation process in Serbia.
The infographic “Tracking the Reform Agenda: From Adoption to EC Assessment” provides a clear and concise visual overview of the key stages in the reform process, from the initial adoption of policies to their evaluation by the European Commission. Designed to enhance understanding of this complex journey, it highlights critical milestones.
This infographic provides an overview of Serbia’s Reform Agenda implementation up to June 2025, highlighting progress made, pending measures, and key challenges across priority areas.
Reform-Agenda-Snapshot-up-to-june-‘25_Serbia
Ovi ažurirani podaci o Reformskoj agendi: Pilot-monitor reformi prvi je u nizu nacionalnih izveštaja o monitoringu u okviru projekta „Praćenje reformi”.
Ovaj prvi pregled ispunjenosti Reformske agende – Pilot-monitor reformi je preliminarno ažuriranje namenjeno kao presek stanja sredinom semestra (upozorenje!), a ne kao detaljna evaluacija. Kako projektni tim probno primenjuje metodološki pristup i indikatore, novi momenti politike u narednim nedeljama mogu da promene status reformi koje su trenutno na čekanju. Zemlje obuhvaćene ovim procesom imaju još mesec dana da ostvare dalji napredak kako bi ispunile rokove koji ističu u junu 2025. godine.
Monitor reformi prati preduzimanje odabranih reformskih koraka iz Reformskih programa. Odabrani koraci reformi organizovani su u takozvanim „domenima politike” koji spadaju u oblasti politike i pod-oblasti Reformske agendi. Ovi „domeni politike” su utvrđeni nakon dodatnog nivoa identifikacije reformi i kodiranja reformskih koraka koje je obavio projektni tim. Ovaj pristup je izabran radi fokusa na reformskim koracima zajedničkim celom regionu Zapadnog Balkana i da bi omogućio analize na regionalnom nivou, postavljanje merila i uporedivost, s obzirom na raspoložive ljudske resurse i tematsku ekspertizu TEN mreže. Za metodološke napomene i proces odabira reformskih koraka, pogledati napomenu o nacrtu metodologije.
Ovo probno ažuriranje podataka o ispunjenosti Reformske agende prati strukturu usklađenu sa metodologijom Monitora reformi, koja obuhvata: (1) Sažetak za visoki nivo; (2) Proceduralnu usklađenost sa Instrumentom za reforme I rast; (3) Status realizacije reformskih koraka po domenu politike; i (4) Narativ i analizu ključnog napretka i izazova. Svaki odeljak daje trenutnu sliku napretka i prepreka u vezi sa sprovođenjem Reformske agende Srbije.
Treba imati na umu da je krajnji datum za prikupljanje i procenu podataka za ovo ažuriranje 30. jun 2025. godine. Dešavanja koja nastupe nakon ovog datuma nisu obuhvaćena ovim izveštajem, ali će biti razmotrena u narednim pregledima.
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This Reform Agenda Update: Pilot Reform Monitor is the first of the series of national monitoring reports within the Reform Monitor project.
This first Reform Agenda Update – Pilot Reform Monitor is a preliminary update intended as a mid-semester snapshot (alert!) rather than a detailed evaluation. As the project team pilots the methodological approach and the indicators, further policy developments in the coming weeks may shift the status of currently pending reforms. The countries have one more month to make further progress to meet the June 2025 deadlines.
The Reform Monitor tracks the implementation of selected reform steps from the Reform Agendas. The selected reform steps are organised in so-called “policy domains” that fall within the policy areas and sub-areas of the Reform Agendas. These “policy domains” are developed following an additional level of reform identification and coding of reform steps developed by the project team. This approach was chosen to focus on reform steps common across the WB region and to enable regional-level analyses, benchmarking and comparability, given the available human resources and the thematic expertise of the TEN network. For methodological notes and the reform steps selection process, see the draft methodology note.
This Pilot Reform Agenda Update follows a structure aligned with the Reform Monitor’s methodology, covering: (1) a high-level Executive Summary; (2) procedural compliance under the RGF; (3) reform steps implementation status per policy domain; and (4) narrative and analysis of key progress and challenges. Each section provides a snapshot of progress and obstacles related to Serbia’s Reform Agenda implementation.
Please note that the cut-off date for data collection and assessment for this update is 30 June 2025. Developments occurring after this date are not reflected in this report but will be considered in subsequent updates.
RA_Pilot-Reform-Monitor_Serbia_First-Semester-2025_As-of-June-2025The second meeting of the Intersectoral Working Group for Reform Agenda Monitoring, and the first held within the framework of the WB Reform and Growth Monitor project as a national consultation mechanism, marked important steps forward in operationalising the N-CoMRA platform in Serbia. Participants agreed on the process for forming thematic subgroups based on existing NCEU working groups, supported by transparent coordination, inclusive outreach, and a shared understanding of expected contributions for the upcoming monitoring cycle.
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