IMPULSE Keeping Focus: Reporting developments in Serbia Assessment of the Implementation of Serbia’s Commitments for Opening Cluster 3: Far From Promised Reforms Overall assessment: ɂ Serbia has not fulfilled its commitments regarding the pace of accession negotiations or reforms in fundamental areas, including electoral conditions. ɂ Serbia has taken some steps toward meeting its commitments on foreign policy, but key issues in these areas remain unresolved. ɂ Several specific commitments in the areas of energy and the visa regime have been largely fulfilled. In November and December 2024, the Government of Serbia made efforts to open Cluster 3 in its negotiations with the European Union. The previous time Serbia opened a cluster of negotiating chapters was in December 2021(Cluster 4). In the following years, the European Commission continued to assess in its reports that Serbia was technically ready to open Cluster 3, but no consensus was reached in the Council of the European Union. To obtain the green light from the Council last year, Serbia submitted a non-paper outlining additional political commitments relevant to its EU accession process. This attempt was not successful in 2024 and, as of early December 2025, Serbia has still not opened any new clusters. The non-paper submitted by the Serbian Government was reported on in the media and included commitments relating to overall accession progress, fundamentals, and areas such as energy and good neighbourly relations. Below is an assessment of the fulfilment of each commitment one year later. Assessment of the Implementation of Serbia’s Commitments for Opening Cluster 3: Far From Promised Reforms 1

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

Commitment: Election of the new REM Council by January 2025 The political controversy surrounding the nine-member REM Council concerns the ruling party’s undue influence over its decision-making, contrary to the longstanding recommendations of institutions such as ODIHR and European Commission. REM has a wide-ranging authority regarding the work of electronic media in Serbia. After the parliament adopted a new Law on Electronic Media in 2023, a new REM Council was supposed to be elected by November 2024. However, the election process began only after a months-long delay. Civil society organizations(most notably Civic Initiatives) assessed that the ruling party had attempted to maintain its influence over the Council through GONGOs that nominated numerous candidates, in some cases illegally. The election process launched in November 2024 was cancelled in April 2025, following the pressure from the public and the EU. A new process was launched and once again saw long delays. As of December 2025, it has still not been completed because, in November 2025, the ruling majority refused to elect the ninth member of the Council. According to analysts, electing the ninth member from among the two remaining nominees would have resulted in a REM majority independent of the ruling party. The process of electing the ninth member was subsequently relaunched, with different candidates, including one perceived to be close to the ruling parties, nominated. Independent candidates withdrew on several occasions during both processes due to what they described as procedural violations and have indicated that they are prepared to withdraw again following the failed election of the ninth member. As of December 2025, this commitment has still not been implemented Commitment: Accelerating efforts to carry out the audit of the Voter Registry in the first quarter of 2025 Mistrust in the accuracy of the voter registry has become one of the main issues of the election process in Serbia in recent years. The parliament adopted the revised Law on the Voter Registry only in November 2025. The drafting process lasted more than a year and was marked by the ruling party’s rejection of numerous proposals from civil society organizations. Increased pressure from the EU in October 2025 led to a final version of the law that more closely reflected the CSOs’ proposals. The election watchdog Crta, while agreeing with the final text in principle, expressed doubts about whether it would be implemented in good faith. A Crta nominee is a member of the 10-person Commission for the Revision of the Voter Register, which is still being formed. This commitment has not been implemented, as the audit of the voter registry has not yet begun; only the new law providing the basis for the audit has been adopted. Commitment: Full and timely implementation of ODIHR recommendations regarding elections There is no data on the state of the implementation of ODIHR recommendations. Parliamentary working group for implementing ODIHR recommendation, which was set up in the spring of 2024, was effectively dissolved in January 2025 when the majority of opposition and CSO representatives left it. According to Crta, isolated local elections held in 2025 featured strong indication of the abuse of state resources by the ruling parties and intimidation attempts against voters and independent observers. Elections in the municipality of Mionica in November 2025 saw serious violence. EU Delegation to Serbia requested a full investigation into these cases. No data on formal implementation. Conduct of elections in practice shows persisting serious issues. Commitments: Gas supply diversification – issuing a final permit for Bulgaria-Serbia gas interconnector(IBS); finalising the agreement with Romania for the construction of an interconnector; certifying Transportgas In January 2025, the gas interconnector between Serbia and Bulgaria(IBS) began commercial operations. “Transportgas Srbija” was certified in March 2025, unbundling it from“Srbijagas” as a part of the wider reform demanded by the Energy Community. A memorandum of understanding between Serbia and Romania for the construction of a gas interconnector was signed in August 2024. In July 2025, Minister of Energy stated that it could be finished in the next two and a half years. These steps have been largely completed. Assessment of the Implementation of Serbia’s Commitments for Opening Cluster 3: Far From Promised Reforms 3

Commitment: Full implementation of past agreements with Pristina and refraining from unilateral moves According to the 2025 European Commission Report on Serbia,“overall, Serbia and Kosovo have participated in the Dialogue, but they need to demonstrate more serious and constructive commitment to advance the normalisation process”. Moving forward, they also need to make“further substantial efforts to avoid actions that undermine stability and rhetoric that is not conducive to dialogue and reconciliation”. The document also assesses that“domestic political preoccupations on both sides have hindered decisive steps towards implementing the 2023 Agreement on the Path to Normalisation and its implementation annex and thereby progressing on normalising their relations”. Serbia has not delivered on sanctioning the persons responsible for the 2023 Banjska attack. There has been(very) limited progress in this area, but key issues remain unaddressed. Commitment: Further aligning visa regime and reintroducing visas for four countries Serbia reinstated visa requirements for nationals of Kuwait, Mongolia, Oman and Qatar in December 2024, thus fulfilling this specific commitment(which is also a step in Serbia’s Reform Agenda for the implementation of the Reform and Growth Facility for the Western Balkans). However, according to the European Commission’s November 2025 Report,“Serbia’s visa policy is still only partially in line with the EU list of visa-required third countries”, with an emphasis on a potential security risk from nationals of Russia gaining Serbian citizenship. The specific commitment has been completed. IMPRESSUM Publisher Friedrich-Ebert-Stiftung(FES) Belgrade Office Dositejeva 51/1, 11000 Belgrade, Serbia Author Centre for Contemporary Politics Makedonska 21, 11000 Belgrade, Serbia The opinions expressed in this publication are solely those of the authors and do not necessarily represent the views of the FES. Commercial use of all media published by the FES is not permitted without the written consent of the FES. December 2025 ↗ serbia.fes.de ↗ centarsavremenepolitike.rs Assessment of the Implementation of Serbia’s Commitments for Opening Cluster 3: Far From Promised Reforms 4