According to the report of the Serbian Government on the implementation of the National Programme for the Adoption of the Acquis Communautaire(NPAA), 39% of the planned acts were adopted in the second quarter of 2025; the overall implementation of NPAA from the third quarter of 2024 to the second quarter of 2025 was 54%. The current NPAA itself covers the period from 2024 to 2027, not 2026. It is virtually impossible for Serbia to meet this goal by the end of 2026. Ursula von der Leyen and Aleksandar Vučić in Belgrade, 2025; Photo: European Union Commitment: Fulfilling the interim benchmarks for rule of law chapters 23 and 24 by the latest at the end of 2025 EU’s negotiating positions with Serbia on Chapters 23 and 24 listed a total of 91 interim benchmarks for these chapters(50 for Chapter 23 and 41 for Chapter 24). There are no direct evaluations of the fulfillment of these benchmarks as of December 2025. However, the 2025 European Commission Report on Serbia(released in November 2025) notes no progress in Chapter 23, including backsliding in the area of freedom of expression, and some level of preparation for this chapter(equivalent to 2 out of 5). Chapter 24 recorded limited progress and between some and moderate level of preparation(2.5 out of 5). The levels of preparation remain unchanged compared to last year. There are no signals from the Council of the EU regarding a possible adoption of a positive Interim Benchmarks Assessment Report(IBAR). Montenegro received a positive IBAR in June 2024. This goal has not been met. Commitment: Ambition to fully align with the EU acquis with the objective to close the accession negotiations by the end of 2026 Without a positive IBAR(see above), a candidate country cannot start closing negotiating chapters, as per the 2020 EU accession methodology. As long as Serbia does not receive one, the goal of closing accession negotiations remains out of reach. Meanwhile, in the 2025 November Enlargement Package, Serbia was not mentioned among the frontrunners by the European Commission. On the contrary, the Commission assessed that Serbia’s pace of reforms had slowed down. Commitment: Improving alignment with the EU’s Common Foreign and Security Policy (CFSP) Since the start of Russia’s aggression against Ukraine in 2022, Serbia has not imposed sanctions on Russia. It ended that year with a 44% alignment rate with the CFSP. In the following years, the alignment rate improved somewhat, but not significantly. Towards the end of 2024, at the time the non-paper was written, it stood at 59%. The alignment continues to fluctuate. In the first half of 2025, it fell to 52%(Source: ISAC Fund). In the second half of 2025, according to the Serbian Government, it increased to 63%. The November 2025 Commission Report on Serbia notes limited progress for Chapter 31, stressing that “alignment patterns remained largely unchanged”. There has been limited progress in this area, but key issues remain unaddressed. Commitment: Continuing and further strengthening support to Ukraine According to the November 2025 European Commission report, Serbia continued providing humanitarian and financial assistance to Ukraine. High-level political contacts continued, including visits of President Aleksandar Vučić(June 2025) and National Assembly Speaker Ana Brnabić to Ukraine(November 2025). Following Russia’s accusations in June 2025 that ammunition produced in Serbia was supplied indirectly to Ukraine, Serbia announced that any future such exports will require National Security Council approval. This commitment has been partially fulfilled, though Serbia continues its balancing act between Ukraine and Russia(see the section on CFSP). Assessment of the Implementation of Serbia’s Commitments for Opening Cluster 3: Far From Promised Reforms 2