Today, Coalition 27 presented the Shadow Reports for Chapter 27 and Chapter 15 at the European House. Coalition 27 is an informal network of 18 non-governmental organizations from Montenegro, serving as a platform for joint participation of civil society organizations in the process of adopting European Union standards and values in the field of environmental protection.
Since its establishment, Coalition 27 has been preparing Shadow Reports for Chapter 27 – Environment and Climate Change. However, taking into account the importance of the energy sector and its significant impact on environmental protection, we considered it useful to expand our activities and include monitoring of Montenegro’s obligations within the EU integration process under Chapter 15 – Energy.
Although decision-makers continue to state that all obligations under this chapter will be closed by the end of 2026, we believe that Montenegro has achieved only limited progress in implementing the Action Plan for meeting the closing benchmarks under Chapter 27 – Environment and Climate Change. The implementation of planned obligations is slow, with a high share of partially fulfilled measures and frequent extensions of deadlines. It is necessary to intensify the enforcement of legislation and adopt sectoral strategies and by-laws, particularly in the areas of waste management, air quality, nature protection, and climate change. Establishing a sustainable financing system and strengthening institutional and administrative capacities are crucial in order to meet the obligations under Chapter 27 within the set deadlines. This year, the Shadow Report for Chapter 27 – Environment and Climate Change was symbolically titled “Chapter 27 in a Time Trap.” The report was prepared by Dr. Ana Pavićević, consultant, with the support of Coalition 27 members.
Progress in the area of waste management was presented by Ms. Azra Vuković, who emphasized that limited progress was achieved during the reporting period. Of particular concern is the fact that the National Waste Management Plan has still not been adopted, as well as delays in the planned timeline for adopting the remaining by-laws necessary for further alignment with European Union legislation.
Progress in the sub-area of nature protection was presented by Ms. Ksenija Medenica, who assessed that no progress had been achieved due to delays in the adoption of key laws and strategies, which hinders the implementation of European standards and the fulfillment of international obligations.
Out of the ten sub-areas under this chapter, civil protection is the only one in which all obligations have been fulfilled and which has been formally provisionally closed. Nevertheless, despite the progress achieved—including the adoption of the Disaster Risk Reduction Strategy for the period 2025–2030 and technical integration with European emergency systems—there remains a need for further strengthening of operational capacities and sustainable systemic solutions, particularly in responding to forest fires and other increasingly frequent natural disasters.
Therefore, “Chapter 27 in a Time Trap” means that Montenegro is spending a significant amount of time implementing activities without achieving real progress or meeting objectives. Many activities related to the closing benchmarks for this chapter were initiated several years ago and are still ongoing, i.e., not completed, and as such cannot deliver adequate results in practice.
Regarding the Shadow Report for Chapter 15 – Energy, we believe that Montenegro has reached a good level of preparedness in this area; however, only limited progress was achieved during the reporting period.
The adoption of the National Energy and Climate Plan (NECP) and the full transposition of the requirements of the “Clean Energy for All Europeans” package continue to be delayed. The recently adopted Energy Law and the Law on the Use of Renewable Energy Sources represent important steps toward alignment with the EU acquis in the fields of electricity and renewable energy sources. Nevertheless, functional implementation remains slow and fragmented. The operational application of these laws has been postponed due to the need to adopt a large number of by-laws, technical regulations, and digital tools. Such a transposition model—where a significant portion of obligations is transferred to secondary legislation—carries a high risk of delays and regulatory gaps, limiting the achievement of objectives on the ground.
Institutional capacities, particularly in terms of human resources, technical equipment, and inter-sectoral coordination, remain insufficient for the full implementation of the EU acquis. The report for this chapter was prepared by Danilo Barjaktarović, consultant, with the support of Coalition 27 members. More detailed insights from this area will follow.
The reports were prepared within the project Strengthening Civil Society engagement in the EU Accession supported Environmental Reforms funded by the European Union through the Civil Society Facility 2023 programme and co-financed by the Ministry of Regional-Investment Development and Cooperation with Non-Governmental Organizations.
