For the second consecutive year, the European Network of National Human Rights Institutions (ENNHRI) continues, through its annual joint reporting, to present developments and challenges affecting the rule of law, democracy, and human rights across the enlargement region. ENNHRI brings together 51 National Human Rights Institutions (NHRIs) from across wider Europe, including all 10 EU candidate and potential candidate countries: Albania, Bosnia and Herzegovina, Georgia, Kosovo*, Moldova, Montenegro, North Macedonia, Serbia, Türkiye and Ukraine.

In 2025, NHRIs in the enlargement region continued to play an active role in upholding the rule of law, human rights and democratic values. They engaged in this through functions including: providing human rights recommendations to national authorities; complaints-handling, legal assistance and protection support to human rights defenders (HRDs) and civil society organisations (CSOs); monitoring of national trends and challenges, including through specialised mandates such as National Preventive Mechanisms (NPM), Equality Bodies and monitoring of the implementation of the Convention for the Rights of Persons with Disabilities (CRPD), among others; capacity-building and awareness-raising; and active engagement in EU accession-related reforms, including screening exercises and Chapter 23 dialogue.

At the same time, NHRIs reported a range of interconnected challenges, including constraints on the enabling environment for NHRIs and civic space actors, limitations on participation in law-making processes, the growing impact of disinformation on democratic systems, and persistent structural human rights issues. Several NHRIs also face specific pressures linked to armed conflict, restricted access to non-government controlled territories, and weaker parliamentary follow-up. Such issues pointed to a situation that requires coordinated, sustained, and decisive action by national authorities, EU institutions and other regional actors.

Rule of law, democracy and human rights are core EU values and preconditions for EU accession under the EU’s enlargement policy. The EU 2025 Enlargement Package continued to link progress on Chapter 23 (Judiciary and Fundamental Rights) and Chapter 24 (Justice, Freedom and Security) to broader institutional reform and geopolitical resilience, while the European Commission’s Rule of Law Report will progressively expand to enlargement countries, with Albania, Montenegro, North Macedonia and Serbia already integrated. In this context, ENNHRI engaged actively with EU institutions, including through its strategic partnership with DG ENEST and coordination with the EEAS, contributing to the Enlargement Packages and advancing the recognition of strong, independent NHRIs as a benchmark of progress under Chapter 23.

ENNHRI welcomes the European Commission's recognition of NHRIs entrusted with a broad mandate to promote and protect all human rights, reflected in the EU 2025 Enlargement Package and the European Commission’s 2025 Rule of Law Report. However, ENNHRI calls on the European Commission to continue its efforts so that NHRIs are explicitly and consistently recognised across all relevant EU reporting, and recognised as a benchmark under Chapter 23 for a healthy rule of law.

ENNHRI's 2026 Enlargement Rule of Law Report provides a comparative overview of developments across the 10 enlargement countries, alongside targeted recommendations to national authorities, EU institutions and other regional actors. The report draws on evidence submitted by ENNHRI members from the enlargement countries and highlights both persistent structural issues and emerging risks, while showcasing the actions undertaken by NHRIs to monitor, prevent and respond to rule of law challenges at national level. 

The report covers key thematic areas central to the rule of law, through the NHRI perspective. It examines the enabling environment for NHRIs, including their establishment, independence, effectiveness and resilience; the state of civil society space and the situation of human rights defenders; the overall state of democracy, with particular attention to disinformation and law-making processes; and persisting challenges for the rule of law and structural human rights issues across the enlargement region.

This report complements ENNHRI's EU-focused Rule of Law report and feeds into ENNHRI's wider Europe Rule of Law report.

Currently, six of the 10 NHRIs in enlargement countries hold A-status (Albania, Bosnia and Herzegovina, Georgia, Moldova, Serbia, and Ukraine), while three out of 10 NHRIs (Montenegro, North Macedonia, and Türkiye) hold B-status, and the institution of Kosovo* remains a non-accredited associate member due to the country’s specific international status. Several NHRIs are advancing legislative reforms to strengthen their mandates and independence (Albania, Moldova, Serbia, and Ukraine), while the NHRI in Montenegro is undergoing a reform process, which has raised concerns regarding its institutional and financial autonomy. A majority of NHRIs continue to report insufficient and inadequate resources, particularly where mandates are expanding, alongside persistent challenges in access to information, cooperation with authorities, and follow-up to recommendations. Several NHRIs (Georgia, Moldova, Montenegro, and Ukraine) also reported online attacks or disinformation campaigns against the institution, including from public officials.

ENNHRI’s key recommendations

ENNHRI calls on national authorities to:

1. strengthen the enabling environment for NHRIs in line with the UN Paris Principles and relevant regional standards, by ensuring their institutional, functional and financial independence and providing effective measures to protect NHRIs, including their leadership and staff, from intimidation, harassment, threats, attacks and disinformation campaigns;
2. ensure that NHRIs are provided with adequate, sustainable and predictable financial and human resources commensurate with the scope and complexity of their mandates, and consult NHRIs in advance when new mandates are assigned;
3. ensure systematic and effective follow-up to NHRI recommendations; and
4. ensure meaningful NHRIs’ participation in EU accession-related discussions to guarantee a human-rights based approach.

ENNHRI calls on the European Union and other regional actors to:

5. continue supporting NHRIs in enlargement countries as key actors for the protection and promotion of human rights, democracy and the rule of law, with particular attention to NHRIs operating in complex environments; 
6. recognise NHRIs as strategic partners in monitoring and advancing reforms linked to the EU acquis and international human rights obligations, and promote their systematic involvement in enlargement-related discussions; and 
7. acknowledge that strong and independent NHRIs constitute an important benchmark of progress under Chapter 23.

None of the NHRIs from the enlargement region reported an open environment for civil society. Three ENNHRI members (from Albania, Kosovo* and North Macedonia) reported a narrowing civic space, and two (from Bosnia and Herzegovina and Georgia) reported a restricted space, with the NHRI from Georgia describing an increasingly challenging situation for HRDs, including hostile campaigns. Eight NHRIs identified a lack of adequate funding for CSOs and HRDs, with five reporting explicit barriers to accessing funding, with a situation especially concerning in Georgia following the introduction of its Foreign Agents Registration Act. Intimidation and harassment of CSOs and HRDs were reported by seven NHRIs, with women HRDs, LGBTI activists, and the organisations representing them, being disproportionately targeted. None of the 10 enlargement countries has adopted specific legislation for the protection of HRDs, although Kosovo* introduced a SLAPPs protection mechanism.

ENNHRI’s key recommendations

ENNHRI calls on national authorities to:

1. ensure a safe and enabling environment for civil society and human rights defenders, including by preventing and addressing intimidation, harassment, smear campaigns, strategic lawsuits against public participation (SLAPPs), and online attacks, and by establishing or strengthening effective protection mechanisms;
2. ensure meaningful participation of CSOs and HRDs in legislative and policy-making processes; and
3. ensure predictable, transparent and sustainable funding frameworks for civil society organisations, including by allowing funding from foreign resources.

ENNHRI calls on the European Union and other regional actors to:

4. continue supporting civil society and human rights defenders in enlargement countries, in line with the EU Civil Society Strategy, through sustainable funding, capacity-building and technical assistance; 
5. ensure systematic monitoring of civic space and the situation of HRDs within the EU Enlargement Packages and related rule of law processes, and respond promptly where developments undermine fundamental rights, democracy or the rule of law; and
6. support NHRIs to strengthen their work and capacity as part of the protection system of civic space.

NHRIs across enlargement countries report that disinformation increasingly affects democratic governance, public trust, electoral processes, and the enjoyment of human rights, with adverse effects on freedom of expression, privacy and participation in public life. NHRIs play an active role in countering disinformation through monitoring, advisory functions and awareness-raising, and some have also adopted national frameworks or strategies on strategic communication and countering disinformation. At the same time, NHRIs raised concerns that some counter-disinformation measures risk being incompatible with freedom of expression and access to information.

ENNHRI’s key recommendations

ENNHRI calls on national authorities to:

1. develop coherent, transparent and rights-compliant responses to disinformation; counter-disinformation measures should be clearly prescribed by law, necessary, proportionate, and subject to effective oversight and appeal mechanisms, safeguarding freedom of expression, media freedom, access to information and privacy; and
2. invest in media and digital literacy and education for citizens, with particular attention to children and young people, and promote access to reliable, pluralistic and accessible sources of information.

ENNHRI calls on the European Union and other regional actors to:

3. support enlargement countries in developing rights-based approaches to countering disinformation, including through technical assistance, exchange of good practices, capacity-building and strengthened cooperation with NHRIs and civil society; and
4. continue monitoring whether national counter-disinformation frameworks comply with freedom of expression, privacy, access to information and democratic participation standards.

Significant challenges affecting the quality and inclusiveness of law-making processes persist across the enlargement region. The most frequently reported challenge concerns the extensive use of fast-track and emergency legislative procedures, often limiting parliamentary scrutiny and public debate. Six NHRIs reported insufficient consultation periods and largely formalistic consultation processes, with the same number of NHRIs identifying a limited use of human rights impact assessments. Several NHRIs also highlighted that shortcomings in legislative processes disproportionately affect women, LGBTI persons, and minority communities. NHRIs continued to play an active role through monitoring, legislative opinions, and recommendations, although implementation of these inputs remains uneven.

ENNHRI’s key recommendations

ENNHRI calls on national authorities to:

1. ensure that law-making processes are transparent, accessible and participatory, including for NHRIs and civil society; 
2. limit the use of expedited and emergency legislative procedures to genuinely exceptional and duly justified circumstances; and 
3. systematically integrate human rights considerations throughout the legislative process, including through human rights impact assessments where appropriate.

ENNHRI calls on the European Union and other regional actors to:

4. continue promoting high standards of democratic governance, legislative transparency and stakeholder participation as part of enlargement-related reforms, including by supporting inclusive law-making practices, strengthening parliamentary scrutiny, promoting human rights impact assessments and ensuring meaningful engagement of NHRIs in legislative and policy-making processes.

NHRIs report a range of persistent structural human rights challenges affecting the rule of law across the enlargement region. These include insufficient protection of groups in vulnerable situations, including children, persons with disabilities, Roma communities and victims of trafficking; concerns relating to detention conditions, including overcrowding and inadequate healthcare; persistent gaps in media freedom and access to information; and emerging digitalisation-related risks, including personal data protection and algorithmic decision-making. 

The impact of armed conflict and occupation on human rights and the rule of law remains a distinct and pressing concern, particularly for Georgia, Moldova, and Ukraine. Beyond these structural issues, NHRIs report persistent challenges affecting access to justice, including the excessive length of proceedings, shortages of judges and court staff, and continued delays or failures in implementing domestic and European Court of Human Rights (ECtHR) judgments, alongside ongoing concerns regarding corruption and accountability mechanisms.

ENNHRI’s key recommendations

ENNHRI calls on national authorities to:

1. strengthen the effective implementation of human rights standards and ensure that rule of law reforms are grounded in the protection of fundamental rights, with particular attention to access to justice and legal aid, the protection of persons in vulnerable situations, and safeguards for persons deprived of liberty; and
2. improve access to justice by addressing excessive delays in judicial proceedings, strengthening judicial capacity, and ensuring the effective implementation and enforcement of domestic and regional judicial decisions; 

ENNHRI calls on the European Union and other regional actors to:

3. continue supporting enlargement countries in strengthening the implementation of human rights standards and rule of law reforms, including through technical assistance, capacity-building and support for independent institutions and civil society; and
4. continue supporting justice sector reforms, judicial independence and the implementation of European human rights standards throughout the enlargement process.

The European Network of National Human Rights Institutions (ENNHRI) brings together 51 members across wider Europe, including from all EU candidate countries, namely Albania, Bosnia and Herzegovina, Moldova, Montenegro, North Macedonia, Serbia, Türkiye, Ukraine, and Georgia, as well as a potential EU candidate country, Kosovo*. ENNHRI provides support for the establishment and strengthening of National Human Rights Institutions (NHRIs), and creates a platform for collaboration, solidarity, and a common voice of NHRIs at the European level to advance human rights, democracy, and the rule of law.

NHRIs are independent, state-mandated bodies with broad constitutional or legal powers to promote and protect human rights in line with the UN Paris Principles. Acting as bridge-builders between state authorities and civil society, they cooperate with a variety of actors to provide an authoritative overview of the state of human rights, and issue recommendations to governments, parliaments, and other institutions accordingly. Their independence, pluralism, accountability, and effectiveness are periodically assessed through accreditation by the UN-supported Sub-Committee on Accreditation (SCA) of the Global Alliance of NHRIs (GANHRI). Strong and independent NHRIs in compliance with the UN Paris Principles have become an indicator of a healthy rule of law.

Rule of law, democracy, and fundamental rights are core EU values and preconditions for EU accession under the EU enlargement policy. The revised 2020 Enlargement Methodology and the EU 2025 Enlargement Package link progress on Chapter 23 (Judiciary and Fundamental Rights, covering judicial independence, anti-corruption, and protection of fundamental rights) and Chapter 24 (Justice, Freedom and Security, covering issues such as migration, asylum, border management, and the fight against organised crime) to broader geopolitical resilience and institutional reform.

ENNHRI welcomes the European Commission’s recognition of role of NHRIs in promoting and protecting fundamental rights. Building on this recognition, ENNHRI reiterates its call on the EU to adopt a consistent approach in its enlargement policies and reporting by creating a benchmark under Chapter 23, which would ensure a systematic attention to the existence and functioning of an NHRI in compliance with the UN Paris Principles. This call is supported by a broader international framework, including the UN Sustainable Development Goals indicator 16.a.1 that recognises the establishment and strengthening of UN Paris Principles-compliant NHRIs as a key measure of progress towards peaceful, just and inclusive societies. 

ENNHRI will continue to support NHRIs in the enlargement region to strengthen their compliance with the UN Paris Principles and their effectiveness in contributing to the EU accession process. When NHRIs fulfil their mandates effectively and independently, they contribute fully to democratic reforms and to the EU’s vision of resilient, rights-based societies across the region with a merit-based, values-driven enlargement process.

Recognising the centrality of the rule of law and fundamental rights in the EU accession process, this ENNHRI report includes information from ENNHRI members across 10 enlargement countries: Albania, Bosnia and Herzegovina, Georgia, Kosovo*, Moldova, Montenegro, North Macedonia, Serbia, Türkiye, and Ukraine. 

Grounded in the national monitoring mandates of NHRIs, this report offers both a comparative overview in enlargement countries and detailed country-specific insights. It builds on ENNHRI’s sustained engagement in European rule of law monitoring and its established methodology, developed in 2020, which underpins joint annual reports by NHRIs within ENNHRI’s reporting on the state of the rule of law across Europe. This year, the report presents structured NHRI contributions across key thematic areas, including the establishment, independence, and effectiveness of NHRIs; civic space and human rights defenders (HRDs); disinformation and law-making processes; and other issues affecting human rights and the rule of law.

This report provides an evidence-based perspective on rule of law developments from NHRIs in enlargement countries, aiming to inform EU institutions, national authorities, and international partners supporting progress on their path to EU membership. In particular, it aims to inform the European Commission’s ongoing monitoring efforts in the enlargement region through its annual Enlargement Package. Based on a common methodology used across its wider membership, ENNHRI’s contribution can also inform further consistency and complementarity with annual Rule of Law reporting of the European Commission, which is set to increasingly include enlargement countries.

ENNHRI’s reporting contributes to the EU monitoring framework by offering insights grounded in the unique position of NHRIs as independent, national actors mandated to promote and protect human rights and the rule of law. With members in all 10 enlargement countries, ENNHRI is well-placed to provide regionally coherent yet nationally specific perspectives, supporting efforts of enlargement countries to meet EU accession criteria under Chapters 23 and 24.

The accreditation landscape for NHRIs across the 10 enlargement countries reflects notable variation in compliance with the UN Paris Principles. These Principles are foundational to ensuring the independence, pluralism, and effectiveness of NHRIs. 

During the reporting period, six out of 10 NHRIs from the enlargement countries hold A-status, demonstrating full compliance with the UN Paris Principles. These include the institutions in Albania, Bosnia and Herzegovina, Georgia, Moldova, Serbia, and Ukraine. Three countries, namely Montenegro, North Macedonia, and Türkiye, have B-status NHRIs, indicating partial compliance with the UN Paris Principles. This reflects the need for further legal and institutional strengthening to reach full compliance with the UN Paris Principles. ENNHRI’s member in Kosovo* remains unaccredited due to the specific international status of Kosovo* and is currently classified as an associate member of ENNHRI. 

As an observer to the accreditation process, ENNHRI provides tailored support to all its members which undergo (re-)accreditation review. ENNHRI also supports members to follow up on recommendations from the GANHRI Sub-Committee on Accreditation (SCA) to strengthen their compliance with the UN Paris Principles.

While in 2025 no NHRIs in the enlargement region were scheduled for review by the SCA, in 2026 the SCA considered the reaccreditation of the Ukrainian NHRI (April 2026) and will consider also the Serbian NHRI (November 2026).

Among B-status institutions, the NHRI Montenegro, which has held B-status since 2016, is in the process of legislative reform. Work on a new law on the NHRI is currently ongoing and aims to strengthen its institutional framework and ensure full alignment with the UN Paris Principles. The Ministry of Human and Minority Rights is coordinating the process, and a draft Law has been sent to the European Commission for comments. At the same time, concerns have been raised both by the NHRI and ENNHRI regarding certain provisions of the draft currently under discussion, particularly in relation to institutional independence and compliance with the UN Paris Principles and the standards of the Venice Commission. In particular, several proposed provisions may negatively affect the NHRI’s institutional and financial autonomy and represent a regression in compliance with international standards compared to previously discussed versions of the draft law.

The NHRI in Türkiye was accredited with B-status in October 2022, with the SCA including recommendations on independence and addressing human rights violations. Since then, it has taken steps to increase interaction and cooperation with international and national human rights systems and actors, monitor and address human rights violations, follow up on activities and raise public awareness, while having its budget increased.

Meanwhile, the NHRI in North Macedonia, holding a B-status since 2011, continues to encounter challenges concerning its financial autonomy. Despite its expanding mandate and responsibilities, it remains under-resourced. Efforts are ongoing to advocate for a stable and adequate budget that would be determined in a way that guarantees full operational independence from the executive branch. Moreover, although in practice the institution performs a broad human rights mandate, the legal framework governing its work has not yet been updated in follow up to SCA recommendations.

Finally, due to the specific international standing of Kosovo*, the institution is unable to seek accreditation before GANHRI. It is a non-accredited, associate member of ENNHRI and has worked for the promotion and protection of a wide range of human rights issues in Kosovo*. ENNHRI remains engaged in supporting its member institution in Kosovo* for eventual international accreditation once possible.

The diverse accreditation status across the enlargement region highlights both the progress and the persistent challenges in establishing strong and independent NHRIs. ENNHRI continues to prioritise tailored support and capacity-building to help all its members move toward full compliance with the UN Paris Principles, reinforcing their role as vital partners in the EU enlargement process.

Across enlargement countries, NHRIs reported gradual progress in implementing recommendations issued by international and European actors, including the GANHRI SCA, the European Commission, the Council of Europe and other regional mechanisms. Similar to trends identified in the ENNHRI's 2026 report on the state of the rule of law in the European Union, progress is most visible where national authorities have taken steps to strengthen the legal framework, institutional capacity, and resources of NHRIs. This is illustrated by the recent re-accreditation with A-status of the NHRIs of Bosnia and Herzegovina (May 2024) and Georgia (October 2024), both of which have since taken concrete steps to follow up on SCA recommendations. 

At the same time, many recommendations requiring legislative reform on enhanced institutional independence or sustained budgetary support remain only partially implemented. In this context, NHRIs are called to advocate for these changes towards national authorities. While ENNHRI plays a key role in supporting NHRIs to follow up to SCA recommendation, regional partners like the European Commission and the Council of Europe can intensify their efforts to further liaise with NHRIs to understand their needs and consider technical support. They can also play an important role, in cooperation with the NHRI, to encourage national authorities to advance and support implementation of relevant SCA recommendations. Finally, reforms in the context of EU accession processes can serve as a way to advance the implementation of SCA recommendations.

Several NHRIs reported ongoing efforts to align their legal frameworks and institutional mandates with the UN Paris Principles and SCA recommendations. Following its re-accreditation, the NHRI of Bosnia and Herzegovina has worked actively with authorities and civil society to implement the SCA recommendations, including through the establishment of the National Preventive Mechanism (NPM). The Albanian NHRI has advanced a comprehensive review of the law governing the People's Advocate of Albania, including proposals to strengthen the institution's mandate, increase its staffing capacities, and extend its competence to private actors. The NHRI of Moldova is preparing amendments aimed at further strengthening financial independence and institutional safeguards, including guarantees of protection of the institution against criminal and civil liability for work undertaken in good faith, while the NHRI in Türkiye has initiated a legislative review process through dedicated reform mechanisms linked to broader judicial and EU accession reforms. 

The NHRI in Ukraine reported that consideration of draft legislative amendments is ongoing and aims to address several long-standing SCA recommendations, including provisions on appointment procedures, mandate, tenure, and financial guarantees. In addition, the above-mentioned draft Law also promotes a transparent and participatory selection and appointment process and provides an explicit legal basis for cooperation with human rights organisations and public associations. 

On the other hand, legislative alignment for NHRIs remains pending in North Macedonia, where NHRI continues to operate under legal frameworks that does not fully reflect its existing mandate or the requirements of the UN Paris Principles. However, in Georgia, while the Organic Law on Public Defender is interpreted to include a human rights promotion mandate, the SCA has recommended introducing an explicit language on this mandate in the law. In follow-up, the NHRI has adopted an internal guidance document standardising awareness-raising as a core institutional function, and will work with Parliament to bring the recommended amendment into the existing legislation. The NHRI in Montenegro further reported concerns that certain provisions of a proposed new Law could weaken institutional independence and depart from previously discussed reform proposals.

The provision of adequate and sustainable funding, including in follow-up to recommendations of the SCA, remains a key challenge across the region, consistent with findings from the 2025 ENNHRI Enlargement Rule of Law Report. Despite some positive developments, such as increased budget allocations in several countries, many NHRIs continue to face persistent obstacles to securing resources commensurate with their expanding mandates, which constitutes a recurring barrier to the full follow-up of SCA recommendations, and which is examined further in the section on challenges below. 

The reporting also points to a growing focus on strengthening institutional effectiveness and operational capacity. Several NHRIs have undertaken reforms to operationalise expanded mandates, including the establishment of new monitoring functions, recruitment of specialised staff and development of internal methodologies and governance tools. In Serbia, for example, the NHRI further strengthened its operational capacity through a newly adopted transparent and merit-based public competition process for seven vacancies, in line with the SCA's recommendations. Emerging trends include increased investment in institutional digitalisation and data management systems, as reported by the NHRI in Georgia, as well as efforts to standardise internal monitoring, reporting and awareness-raising functions. Such developments reflect a broader shift towards strengthening institutional resilience, accountability and evidence-based human rights monitoring in response to the recommendations on the regional and international levels.

Across enlargement countries, NHRIs reported varying levels of engagement in enlargement-related reforms. While the EU accession process continues to provide an important framework for advancing rule of law and fundamental rights reforms, the extent to which NHRIs are embedded in these processes differs significantly across countries.

Several NHRIs reported active and structured participation in EU accession-related reforms. The NHRIs from Albania, Montenegro, Serbia, and Ukraine described engagement in formal accession mechanisms, including participation in screening exercises, including rule of law working groups on the implementation of Chapter 23 requirements, dialogues with the European Commission, and contributions to national reform agendas. In Ukraine, the NHRI participated in bilateral screening meetings under several negotiation chapters and contributed to rule of law reform measures aimed at strengthening the institution's effectiveness and independence. The Albanian institution reported that NHRI-related reforms have been integrated into the Government's Rule of Law Roadmap, while the Serbian NHRI highlighted engagement through Chapter 23 dialogue and EU-supported rule of law reforms. The NHRI in Montenegro similarly reported participation in accession working groups covering rule of law and social policy issues.

On the other hand, some NHRIs reported engagement that remains primarily project-based or consultative. In Georgia, support to the NHRI is largely channelled through EU-funded technical assistance and capacity-building projects rather than through structured participation in enlargement reforms. Similarly, the NHRIs of Bosnia and Herzegovina and North Macedonia reported cooperation with the EU and international partners, but limited involvement in the design and implementation of enlargement-related reforms. The ENNHRI member in Kosovo* reported that EU integration processes have contributed to strengthening the institution's visibility and operational capacity, including through participation in EU-funded programmes and legislative alignment processes, although engagement remains largely indirect.

As in previous years, enlargement-related reforms continue to support institutional strengthening of NHRIs through technical assistance, peer exchange and capacity-building initiatives. Several NHRIs reported benefiting from EU-funded projects, including Twinning and TAIEX instruments, as well as cooperation with peer institutions and regional partners. In some countries, such support has contributed to legislative reform efforts, institutional modernisation and the strengthening of specialised mandates. This is the case for the institutions of Kosovo* and Serbia, which report that enlargement-related reforms have contributed to strengthening the independence and effectiveness of the institutions. Furthermore, the institution in Kosovo* indicated that draft laws undergo mandatory EU acquis alignment checks which contribute to a stricter rule of law framework.

Developments reported by NHRIs in enlargement countries indicate a continued strengthening of institutional mandates and regulatory frameworks, building on trends identified in the previous 2025 ENNHRI Enlargement Rule of Law Report. Several NHRIs reported legislative reforms or draft amendments aimed at strengthening institutional independence, expanding competencies and improving compliance with the UN Paris Principles.

Similar to the situation of NHRIs in the EU, NHRIs in the enlargement countries increasingly exercise multiple and specialised mandates simultaneously, extending beyond their core human rights functions. Across the region, reforms primarily focused on strengthening existing mandates, operationalising previously assigned functions and preparing institutions for future EU accession-related responsibilities.

In 2025, several NHRIs were granted new or expanded mandates. In Montenegro, amendments to the Law on the Protector of Human Rights and Freedoms expanded the NHRI’s anti-discrimination mandate to cover EU, EEA and Swiss nationals exercising free movement rights within the country. The NHRI in Türkiye was formally designated as the national monitoring mechanism under the Convention on the Rights of Persons with Disabilities (CRPD), representing a notable expansion of its specialised monitoring functions. In Bosnia and Herzegovina, the NHRI reported a newly formalised oversight role concerning the implementation of freedom of information legislation at different levels of government. The Georgian NHRI further reported an expansion of its monitoring mandate to include juvenile care and support facilities, effective as of July 2026. In Albania, the NHRI presented a comprehensive review of its enabling law, including proposals to expand its mandate to address human rights violations committed by private actors. 

A notable trend across the region is the growing diversification of NHRIs’ additional mandates. In addition to their core NHRI mandates, many NHRIs now exercise responsibilities as National Preventive Mechanisms (NPM), equality bodies, CRPD monitoring mechanisms, whistleblower protection bodies, anti-trafficking monitoring mechanisms and other specialised oversight actors. Several institutions also reported preparations for additional responsibilities linked to the EU acquis. The NHRI in Montenegro is preparing to assume monitoring functions under the EU Asylum Procedure Regulation, and the NHRIs in both Montenegro and Serbia continued working towards the establishment of border monitoring mechanisms in line with the EU Pact on Migration and Asylum. These developments reflect a growing recognition of NHRIs as trusted institutions capable of providing independent monitoring and accountability across multiple policy areas.

At the same time, progress in strengthening the core legal framework of NHRIs remains uneven. Similar to findings of the previous ENNHRI Enlargement Rule of Law Report, reforms aimed at bringing NHRI legislation fully into line with the UN Paris Principles remain pending in several countries. The NHRIs in Georgia, Moldova, and North Macedonia reported limited progress in addressing long-standing legislative gaps, while the NHRIs in Montenegro and Ukraine continue to pursue broader reforms aimed at strengthening institutional safeguards and independence.

Several NHRIs reported efforts to strengthen internal governance, digitalisation, data collection systems and specialised monitoring methodologies. The evidence is strongest for the NHRI in Georgia, with some indications for the NHRI in Serbia, and to a lesser extent for the NHRIs in Albania and Türkiye.

For a better overview of NHRIs’ mandates in the enlargement countries, please check this table.

Challenges in implementing multiple mandates

As identified in the ENNHRI's 2026 report on the state of the rule of law in the European Union, the expansion of NHRI mandates is frequently not accompanied by adequate resources or institutional safeguards. NHRIs in enlargement countries reported similar challenges, particularly regarding staffing levels, financial sustainability, and specialised expertise.

Insufficient financial and human resources remain the most frequently reported obstacle to the effective implementation of multiple mandates. The ENNHRI members in Albania, Bosnia and Herzegovina, Kosovo*, Moldova, North Macedonia, and Serbia reported that despite the additional responsibilities the institutions were entrusted with, these were not matched by corresponding increases in funding or personnel. The Moldovan NHRI noted that only a portion of legally approved staff positions can currently be financed, while the NHRI in Bosnia and Herzegovina highlighted a persistent gap between the breadth of its mandate and available operational resources.

Several NHRIs also reported difficulties arising from increasingly specialised responsibilities. Similar to observations made by EU NHRIs, the implementation of domain-specific mandates requires dedicated expertise and capacity-building. The Serbian NHRI identified the need for specialised expertise in implementing anti-trafficking and CRPD-related functions, while the NHRI in Türkiye highlighted operational challenges linked to the territorial scale of the country and broadness of its mandates and monitoring responsibilities.

Unlike trends reported across the EU, enlargement-country NHRIs continue to face a number of mandate-specific structural constraints. The NHRIs in Moldova and Ukraine reported significant obstacles in exercising their mandates in non-governmental controlled territories, due to lack of access, obstructions from the de facto authorities, and physical danger to the NHRIs’ staff. The NHRIs in both Georgia and Ukraine highlighted limitations affecting oversight in the field of personal data protection, while the Georgian NHRI further reported isolated cases of impediment in the systematic monitoring activities of the Public Defender Office that hindered its ability to conduct proactive inquiries.

Based on the challenges identified, NHRIs across enlargement countries emphasised the need for adequate, predictable and sustainable financial and human resources to effectively implement their mandates. Similar to trends identified among EU NHRIs, institutions highlighted that the expansion and diversification of mandates are not always accompanied by corresponding increases in staffing, operational budgets or specialised expertise. Several NHRIs also stressed the importance of being systematically consulted when new mandates are assigned or legislation affecting their work is developed. In addition, institutions pointed to the need for stronger parliamentary engagement, more effective follow-up to NHRI recommendations, improved cooperation with public authorities, and continued investment in digital infrastructure, data management systems and specialised staff capacities. These needs are particularly relevant where NHRIs are expected to carry out increasingly technical monitoring functions or operate in complex contexts, including migration management, data protection and monitoring in areas with restricted access.

Several NHRIs further highlighted the importance of support from regional and international actors, including ENNHRI, in strengthening their effectiveness and independence. Requested support includes peer learning and exchange of good practices, capacity-building activities, technical expertise, strategic litigation support, advocacy at the European level in situations affecting NHRI independence and NHRIs under threat, and assistance in strengthening institutional resilience and specialised monitoring functions. NHRIs also underlined the value of ENNHRI's Rule of Law reporting, regional cooperation platforms and engagement with European institutions in amplifying concerns related to NHRI independence, compliance with international standards and the implementation of their recommendations. In particular, some institutions highlighted the role ENNHRI can play in further supporting advocacy towards national authorities, promoting parliamentary follow-up to NHRI recommendations in line with UN Paris Principles, and facilitating exchanges on emerging challenges, including monitoring in restricted-access territories, migration-related functions and the implementation of multiple mandates.

Structural challenges affecting NHRI independence and effectiveness 

ENNHRI’s reporting confirms that NHRIs in enlargement countries continue to face structural challenges that affect their ability to operate independently and effectively. The most persistent challenge, as noted above, remains insufficient and inadequate resources, particularly where NHRIs are expected to implement broad or expanding mandates. This was reported by the NHRIs in Albania, Bosnia and Herzegovina, Moldova, North Macedonia, and Ukraine. In Ukraine, the discrepancy between available resources and the scope of the institution’s mandates has been further exacerbated by martial law, attacks on infrastructure, the energy crisis and the growing complexity of digital complaints. In Albania, Bosnia and Herzegovina, and Moldova, limited financial and human resources continue to constrain NHRIs’ institutional capacity in practice. 

Challenges related to financial autonomy and budget determination processes also remain significant. The Moldovan NHRI reported that the institution’s budget remains integrated into the general government budget process without a distinct budget line fully reflecting its independent status. The NHRI in Montenegro noted that, although its budget is formally provided through the State budget, the lack of full financial independence limits its ability to plan and implement activities across multiple mandates. The Ukrainian NHRI reported a continued reduction in funding for the NPM mandate since the full-scale invasion, affecting the institution’s ability to conduct regular monitoring visits and engage necessary experts. 

NHRIs also reported persistent challenges in access to information, cooperation with authorities and follow-up to their recommendations. The Moldovan NHRI reported difficulties in accessing information from the Ministry of Defence. The Georgian NHRI highlighted selective obstruction by several public authorities, including law enforcement, penitentiary, judicial and municipal bodies, reporting particular obstacles to effective cooperation with law enforcement authorities during mass detention events.  

Low or inconsistent implementation of NHRI recommendations remains a cross-cutting challenge, reported by the ENNHRI members in Albania, Bosnia and Herzegovina, Georgia, North Macedonia and Serbia, with the ones in Albania and Kosovo* further highlighting limited parliamentary follow-up to their reports and recommendations. The Georgian NHRI provided detailed data showing that only a small proportion of recommendations to state authorities were fully implemented, while the Serbian NHRI distinguished between more frequent implementation of individual recommendations and weaker follow-up to systemic recommendations requiring broader institutional reforms. These challenges demonstrate that the effectiveness of NHRI mandates depends not only on formal legal competences but also on the willingness of state institutions to cooperate with and act upon NHRIs ‘findings and recommendations. 

Threats and attacks against NHRIs 

Similar to the concerns raised by the NHRIs in the EU, several NHRIs in enlargement states reported threats, attacks or attempts to undermine their credibility and effectiveness. These included online attacks, defamatory campaigns, verbal attacks, obstruction in carrying out mandates and, in some cases, security-related threats. The NHRIs in Georgia, Moldova, Montenegro, and Ukraine reported online attacks or disinformation campaigns against the institutions or their work. The Ukrainian NHRI also reported cybersecurity threats, including phishing attacks targeting staff credentials, and documented verbal attacks and threats against the institution, leadership and employees, particularly in digital spaces. 

The NHRI in Georgia reported disinformation campaigns and defamatory narratives, including statements by high-ranking public figures, aimed at undermining public trust in the Public Defender’s Office. An emerging trend is that reputational attacks may originate not only from public authorities but also from private actors, as reported by the Georgian NHRI in relation to attacks linked to a discrimination case. The NHRI in Bosnia and Herzegovina reported verbal attacks and narratives questioning the relevance of the institution, linked to a general misunderstanding of NHRIs' attributed mandates and responsibilities, which exclude executive powers as foreseen under international standards. The NHRIs in Montenegro and Ukraine also reported threats and intimidation, including gender-based threats directed at leadership and staff. 

Beyond these structural patterns, some NHRIs also reported more direct obstruction in the course of specific operational activities. The Georgian NHRI reported barriers to timely access during detention-related monitoring visits, while NHRIs in Ukraine and Montenegro reported obstruction directly affecting the implementation of specific institutional functions.  

Responses to threats and measures to strengthen resilience 

NHRIs are developing a range of responses to strengthen institutional resilience. Some NHRIs rely on constitutional, legislative and criminal-law safeguards protecting the independence and immunity of mandate holders and staff. The Georgian NHRI reported constitutional and legal safeguards, including criminal sanctions for exerting pressure on the Public Defender. The Serbian NHRI highlighted statutory mechanisms enabling the Protector of Citizens to respond to threats, while the NHRI in Bosnia and Herzegovina noted that the institution benefits from a certain level of functional immunity in carrying out their duties and can draw on the general civil and criminal law protection measures available to all entities, including the possibility of reporting attacks that amount to criminal offences to the competent authorities, primarily the Ministries of Internal Affairs, but considered these general safeguards insufficient and called for dedicated security and support mechanisms tailored to the institution. 

Several NHRIs reported internal measures to improve preparedness and response. The Ukrainian NHRI reported systematic monitoring of risks, strengthened internal coordination, improved cyber and information security procedures, and rapid-response mechanisms for interference with online activities. The Albanian NHRI reported development and adoption of the internal policies aimed at ensuring institutional integrity, transparency, and stable decision-making. The NHRI in Montenegro highlighted internal procedures, staff training, digital security, transparent public communication and cooperation with civil society and international partners as the key step to strengthen the response to threats. 

A further trend concerns the use of public communication, transparency and evidence-based follow-up as resilience tools. The Georgian NHRI publicly responded to disinformation campaigns and defamatory narratives, while the NHRI in Serbia relied on public reporting, reasoned recommendations and regular communication with the National Assembly and the public as safeguards against undue influence. The Georgian NHRI also introduced a more analytical follow-up approach, including quantified data on recommendation implementation and direct meetings with state authorities. This indicates a shift from reactive responses to more structured accountability and resilience-building practices. 

NHRIs also emphasised the importance of strategic partnerships with domestic, regional and international actors. Several institutions identified ENNHRI as an important source of peer support, solidarity, advocacy and technical assistance. The Ukrainian NHRI highlighted cooperation with ENNHRI and other regional mechanisms to exchange information and mobilise support in response to threats. The Albanian NHRI noted that ENNHRI and other partners can assist the institution through public statements, advocacy and institutional solidarity. The NHRIs in Bosnia and Herzegovina and Serbia also underlined the value of ENNHRI’s peer support, exchange of good practices and institutional backing as an additional layer of protection for NHRI independence and effectiveness. 

Overall, enlargement-country NHRIs face challenges that broadly mirror those reported by EU NHRIs, including insufficient resources, weak follow-up to recommendations, access-to-information barriers and attacks on institutional credibility. However, enlargement-country NHRIs also face specific pressures linked to conflict, restricted-access territories, weaker parliamentary follow-up and more fragile institutional safeguards. Strengthening NHRI resilience therefore requires not only adequate resources and legal protections, but also systematic involvement in human rights-related policymaking, stronger follow-up by public authorities, and continued regional support through ENNHRI and other European actors. 

ENNHRI will continue supporting NHRIs in enlargement countries through peer exchange, capacity-building, advocacy and solidarity actions. In line with ENNHRI’s Strategic Plan 2026–2030, particular attention will be given to strengthening NHRI resilience, supporting institutions facing threats or pressure, promoting implementation of the UN Paris Principles, and enhancing NHRI capacity to address emerging challenges, including digitalisation, conflict-related human rights issues, shrinking civic space and the implementation of multiple specialised mandates.

To national authorities

In light of the developments identified across enlargement countries, ENNHRI calls on national authorities to strengthen the enabling environment for NHRIs in line with the UN Paris Principles and relevant regional standards. Particular attention should be paid to ensuring the institutional, functional and financial independence of NHRIs, including through adequate legal safeguards, transparent appointment procedures and protection from political interference.

ENNHRI urges national authorities to ensure that NHRIs are provided with adequate, sustainable and predictable financial and human resources commensurate with the scope and complexity of their mandates. Budgetary arrangements should adequately reflect the independent status of NHRIs and allow institutions to determine their priorities and activities independently, in line with international standards on NHRIs. Particular attention should be paid to strengthening the operational capacity of NHRIs carrying out multiple specialised mandates, including National Preventive Mechanism, Equality Body, CRPD monitoring and anti-trafficking functions, as well as the emerging responsibilities linked to the EU accession process and the future implementation of the EU acquis.

National authorities should continue efforts to strengthen NHRI legal frameworks and ensure their full compliance with the UN Paris Principles. This includes adopting and implementing pending legislative reforms, in cooperation with NHRIs, aimed at strengthening NHRI independence, mandate effectiveness, immunity guarantees and access to information. Where new mandates are assigned, NHRIs should be consulted in advance and provided with the necessary legal, financial and operational support for their effective implementation.

ENNHRI further calls on national authorities to ensure systematic and effective follow-up to NHRI recommendations, including through strengthened parliamentary oversight, transparent reporting on implementation and clear accountability mechanisms, in line with Council of Europe Recommendation CM/Rec(2021)1, which calls for a legal obligation to provide a timely and reasoned reply to NHRI recommendations. Public authorities should cooperate fully with NHRIs, provide timely access to information and involve NHRIs meaningfully in legislative and policy-making processes, particularly where proposed reforms affect human rights, democracy and the rule of law.

National authorities should also take effective measures to protect NHRIs, their leadership and staff from intimidation, harassment, threats, attacks and disinformation campaigns. This includes ensuring prompt responses to incidents, safeguarding the security of NHRI personnel and publicly reaffirming the legitimacy and importance of NHRIs as independent institutions.

To European and regional actors

ENNHRI calls on the European Union, the Council of Europe and other regional actors to continue supporting NHRIs in enlargement countries as key actors for the protection of human rights, democracy and the rule of law. Particular attention should be given to supporting NHRIs in fulfilling their mandates in complex environments, including situations of conflict, democratic backsliding, shrinking civic space and digital transformation.

European and regional actors should continue providing institutional, technical and financial support to strengthen NHRI capacity, resilience and effectiveness. This includes support for institutional reforms, specialised monitoring functions, digitalisation, data management systems, staff training and capacity-building, as well as peer-learning opportunities and exchanges of good practices. Particular support should be directed towards legislative reform processes aimed at bringing NHRI founding laws into full compliance with the UN Paris Principles, including through technical assistance provided in cooperation with ENNHRI. European and regional actors should also advocate for the implementation of NHRI recommendations, to ensure tangible impact on human rights protection.

ENNHRI encourages European and regional actors to strengthen advocacy in support of NHRI independence and to respond promptly where NHRIs face threats, interference or obstacles in carrying out their mandates. This includes raising concerns regarding attacks against NHRIs and supporting efforts to strengthen legal and institutional safeguards for independent human rights oversight.

Given the importance of EU accession and enlargement processes as drivers of institutional reform, ENNHRI further calls on European actors to promote the systematic involvement of NHRIs in enlargement-related reforms, including rule of law, fundamental rights and Chapter 23 processes. NHRIs should be recognised as strategic partners in monitoring and advancing reforms linked to the EU acquis and international human rights obligations. In addition, strong and independent NHRIs that fully comply with the UN Paris Principles should be acknowledged as constituting an important benchmark of progress made under Chapter 23.

Civil society organisations (CSOs) and human rights defenders (HRDs) are key actors in the system of checks and balances in healthy democracies. They play an essential role in promoting and safeguarding EU values - the rule of law, fundamental rights and democracy - as they serve as watchdogs, raising awareness about essential issues, while often representing diverse groups in vulnerable situations. As a result, they are of crucial importance in supporting enlargement countries’ alignment efforts with the EU acquis. Their protection is therefore an essential component of a functioning democracy and central to the EU enlargement process. Under the Chapter 23 of the EU enlargement process, candidate countries must guarantee freedom of assembly, expression, and association, and create an enabling environment for civil society. Looking ahead, this is reinforced by the EU Strategy for Civil Society, adopted in November 2025, which extends its actions to candidate and potential candidate countries on the same basis as the EU Member States, and recognises civic space across the EU and the enlargement region as a shared, interconnected space.

Acting as unique independent public bodies with a broad human rights mandate, NHRIs play a pivotal role in protecting, empowering, and supporting CSOs and HRDs. At the same time, NHRIs are human rights defenders themselves and often face risks similar to other HRDs.

This year, findings of NHRIs from the enlargement region reveal that gaps in the protection of CSOs and HRDs, legislative and administrative measures, and hostile narratives towards them, have contributed to a shrinking civic space and difficult conditions of operation. They re-affirm the urgency of effectively ensuring an enabling environment for civil society.

Concerningly, none of the NHRIs from the enlargement countries indicated an open environment for CSOs and HRDs. This alarmingly low figure, along with the low number contained in ENNHRI's EU Rule of Law Report, reveals general concerns regarding the enabling environment for CSOs and HRDs.  Key concerns were voiced regarding attacks and harassment against CSOs and HRDs (Albania, Georgia, Moldova, Montenegro, and Ukraine) and funding and resources (Kosovo* and North Macedonia).

Three ENNHRI members from enlargement countries (Albania, Kosovo* and North Macedonia) reported that CSOs and HRDs operate within a narrowing environment for different underlying reasons. In Albania, the narrowing stems from a range of operational and political pressures, including concerns regarding media freedom, journalist safety, disinformation campaigns and politically motivated public attacks targeting civil society actors. In Kosovo* and North Macedonia, by contrast, the primary driver is the significant deterioration in international donor support, including the reduction or suspension of major funding streams such as USAID programmes, rather than direct state interference with civil society operations. Smaller organisations are reported to be particularly vulnerable to these shifts. 

The ENNHRI member in Kosovo* noted a positive development regarding the Forum for Dialogue with Civil Society, bringing together the institution and 27 CSOs to develop action plans and host government roundtables on funding gaps, illustrating that institutional mechanisms for engagement can provide some resilience even in constrained environments. 

Two NHRIs (in Bosnia and Herzegovina and in Georgia) indicated that CSOs and HRDs operate in a restricted civic space. In particular, the NHRI from Georgia reported challenging situation for HRDs, with multiple reports of explicit barriers to accessing funding for activities of HRDs in 2025.

Nonetheless, some ENNHRI members (Bosnia and Herzegovina, Kosovo* and Ukraine) pointed to positive developments and indicators. Among them, the NHRI from Ukraine reported that civil society in Ukraine demonstrates high resilience despite four years of war and noted that national authorities continue to make efforts towards creating a favourable environment for CSOs.

NHRIs from enlargement countries reported several structural challenges negatively impacting the work of CSOs and HRDs, including lack of adequate funding, barriers to participation in lawmaking and policymaking, and legislation restricting the right to association and peaceful assembly. 

ENNHRI members from eight enlargement countries (Albania, Bosnia and Herzegovina, Georgia, Kosovo*, Moldova, Montenegro, North Macedonia, and Ukraine) indicated a lack of adequate funding for CSOs and HRDs. 

Out of these eight ENNHRI members, five (Albania, Georgia, Kosovo*, Montenegro and North Macedonia) indicated that explicit barriers to access to funding hindered the ability of CSOs to fund their activities. Five of ENNHRI’s enlargement members (from Albania, Georgia, Kosovo*, Moldova, and Montenegro) cited difficulties in securing foreign funding as a core issue affecting CSOs. 

The ENNHRI members from Albania and Kosovo* underscored that limited access to domestic public funding has left CSOs and HRDs disproportionately reliant on foreign donors, an aggravating factor that exposes the sector to instability when external funding is reduced or withdrawn. As a result, CSOs are more vulnerable to shifts in foreign funding, such as the cancellation of funding programmes by USAID, which is reported to have negatively impacted the ability of CSOs to operate in Albania, Georgia, and Moldova. In some enlargement countries, explicit barriers in securing foreign funding have accentuated this precarious situation. In Georgia, where the newly introduced Foreign Agents Registration Act imposes special registration and reporting obligations on all persons considered “agents of a foreign principal”, with imprisonment as a result of non-compliance. These provisions disproportionately affect many CSOs relying on foreign funding in Georgia.

A vibrant civil society involved in political life is an important component in the requirements enshrined in Chapters 23 and 24 of the Fundamentals Cluster, and a pre-requisite for further progress in these areas. Across the enlargement region, NHRIs reported difficulties for civil society in securing meaningful consultation in law and policy- making processes.

Six ENNHRI members (Albania, Bosnia and Herzegovina, Georgia, Moldova, North Macedonia, and Ukraine) reported barriers in access to law- or policymaking and meaningful consultation as a major issue faced by CSOs and HRDs. 

For half of these NHRIs (Georgia, North Macedonia, and Ukraine), the use of shortened or expedited legislative procedures was seen as a major obstacle to CSO involvement and consultation in lawmaking. For example, the NHRI from North Macedonia observed that the continued use of shortened procedures for adopting legislation, often without meaningful public consultation, reduces opportunities for CSOs and HRDs to participate in policymaking processes.

In many cases, consultation procedures are deemed too formalistic, with little impact in practice as indicated by the NHRIs from Bosnia and Herzegovina and Moldova. The NHRI from Moldova also indicated that many instances of public consultation are carried out formally or superficially, without ensuring effective and substantial participation of civic society.

A lack of CSO and HRD involvement is particularly noted in policymaking concerning specific areas, such as national budget and fiscal processes (Albania), or information rights and security (Ukraine).

The freedom of association, central to the EU integration commitment, is facing restrictions flowing from laws and policies in four NHRIs (Georgia, Moldova, Türkiye, and Ukraine).

The issue is especially noticeable in Georgia, where amendments to the Assembly Law introduced restrictions on face coverings during demonstrations, and stricter advance notice requirements for demonstrations with criminal liability for repeated violations and sanctions ranging from steep fines to detention. Laws and policies negatively impacting the right to association, assembly and to protest, compounded by police intervention in peacefully organised meetings and demonstrations, which was not always in line with European Court of Human Rights standard by policing of peacefully organised meetings, were also noted as a challenge by the NHRI in Türkiye. The same NHRI further highlighted the ECtHR violation rulings regarding freedom of assembly, calling for structural problems to be identified and eliminated and for relevant legislation to be reviewed in line with international standards. 

Administrative barriers were reported as an issue by three NHRIs (Albania, Bosnia and Herzegovina and Georgia). They can stem from lack of action, slowness, or lack of transparency of the administration as in Bosnia and Herzegovina and Albania, where delays in registration and status changes for CSOs and HRDs are reported as a result of a non-functioning Electronic Register of Non-Profit Organisations, creating additional problems because of the absence of an updated list of active organizations. They can also include excessive administrative audits or controls. Such practices are reported in Georgia, where a number of CSOs have been subjected to inspections, orders requiring them to hand over sensitive data, and requests for detailed operational reports.

Finally, wartime conditions flowing from Russia’s war of aggression against Ukraine have posed significant structural challenges affecting CSOs and HRDs in Ukraine since 2022. Among these are restrictions on constitutional freedoms, including freedom of association, pursuant to Martial Law, and heightened risks associated with operations in frontline regions.

Civil society in the enlargement region continues to be subjected to attacks, mainly in the form of intimidation or harassment, verbal attacks and negative narratives surrounding CSOs and HRDs (including from public authorities), and physical attacks.

Intimidation and harassment of CSOs and HRDs, which have occurred both online and offline, were reported by six out of ten NHRIs (Albania, Bosnia and Herzegovina, Georgia, Moldova, Montenegro, and Ukraine). 

Three NHRIs (in Albania, Montenegro, and Ukraine) reported online harassment towards CSOs and HRDs, with Albania citing online abuse – often gender-based – as the main form of pressure towards HRDs. In Ukraine, a movie festival planning to screen LGBTI+ movies was targeted through Instagram posts which publicly called for the obstruction of the festival.

Intimidation and harassment have also occurred before, during, or after protests and elections, placing significant pressure on participating CSOs and HRDs. 

SLAPPs constitute a form of intimidation against HRDs and have been reported across the enlargement region. Instances of SLAPPs being used to silence HRDs are reported by the NHRI in Bosnia and Herzegovina, where the NHRI has been engaged in ex officio monitoring of the case of two environmental activists targeted by SLAPPs based on the information contained in a communication from the UN Special Rapporteur on SLAPP lawsuits.

Across enlargement countries, civil society faces negative narratives reinforced by disinformation. Six NHRIs (Albania, Bosnia and Herzegovina, Georgia, Moldova, Montenegro, and Ukraine) mentioned narratives aimed at undermining or stigmatising the work of CSOs and HRDs. Concerningly, all of them reported that in many cases, negative narratives originated from or were amplified by public figures. In Georgia, the NHRI identified several threats affecting CSOs and HRDs, including verbal attacks and the promotion of negative narratives by public authorities. In this context, the Public Defender’s Office actively monitors challenges that undermine the creation of an enabling environment for HRDs' activities and the full enjoyment of their freedom of association. 

Attacks on CSOs and HRDs were reported by six out of ten ENNHRI members in enlargement countries (Albania, Bosnia and Herzegovina, Georgia, Moldova, Montenegro, and Ukraine). The attacks took the form of predominately verbal attacks and negative narratives seeking to portray CSOs and HRDs in a negative light and de-legitimise them. 

In these countries, verbal attacks against HRDs and CSOs, seeking to portray them in a negative light and de-legitimise them, have taken place. In Albania, public accusations questioning the legitimacy, transparency, and purpose of CSO funding, portraying organisations as acting against the public interest and promoting foreign agendas were disseminated by non-state actors including conservative groups, online portals, and anonymous social media accounts. 

Pressure by state actors, including surveillance and other intrusive measures, was reported by ENNHRI members in Bosnia and Herzegovina and Georgia. For example, the Georgian member reported that the Anti-Corruption Bureau issued broad and intrusive requests for information from CSOs, these requests were based on critical information and statements disseminated in the public space, raising concerns about retaliation, interference and intimidation. The member from Bosnia and Herzegovina also identified surveillance by state actors as a documented threat affecting CSOs and HRDs. 

Across the enlargement region, an over-arching trend in threats to CSOs and HRDs is the disproportionate targeting of women HRDs, LGBTI activists, and CSOs representing them and other marginalised groups. In Montenegro, the NHRI noted that female activists and journalists often face additional forms of threats, including sexist statements and gender-based attacks. In Albania, much of the online abuse and negative narratives have centred on CSOs working on women’s rights and LGBTI rights, which have been repeatedly targeted in 2025. Further to the introduction of the draft law “On Gender Equality”, disinformation campaigns and hate speech and organised anti-gender, “pro-family” mobilisation were reported. Finally, financial pressures targeting CSOs in Kosovo* disproportionately affected women-led CSOs and minority or marginalised groups.

Reporting by NHRIs reveals substantial gaps in the protection and support of HRDs and CSOs in enlargement countries. In many cases, their protection rests on constitutional guarantees and general legal provisions or sectoral legislation, rather than on dedicated protection mechanisms. The ENNHRI members from Albania, Bosnia and Herzegovina, and Kosovo* indicated that rights relevant to the protection of CSOs and HRDs are enshrined in constitutional guarantees, for example, Article 44 of Kosovo*'s Constitution guarantees freedom of association without prior permission. NHRIs from Albania and Montenegro indicated that protection relies instead on the general legal and sectoral framework. In particular, Albanian NHRI reported that provisions in the Criminal Code, Civil Code and Labor Code, alongside sectoral legislation on NGOs, non-discrimination, and peaceful assembly, make up its legislative framework for CSOs and HRDs. While some countries have taken steps to set up dedicated protection mechanisms, these remain absent in others, highlighting uneven progress across the region. Such discrepancies are relevant to the EU accession process, which expects sustained progress on fundamental rights and democratic governance under Chapter 23.

Currently, none of the 10 enlargement countries have adopted specific legislation for the protection of HRDs. The ENNHRI members from Albania, Bosnia and Herzegovina, Georgia, Kosovo*, Moldova and Ukraine explicitly reported the absence of laws dedicated specifically to HRDs and the protection of their rights. Beyond protection, NHRIs also reported the absence of structured frameworks to support the work of HRDs and CSOs, including through access to sustainable funding, participation in public decision-making, capacity-building opportunities and other forms of institutional support. As also noted above regarding Kosovo*'s Forum for Dialogue, somewhat positive developments were noted by the NHRI in Albania, where clearer mechanisms for support, financing, and monitoring of volunteer activities were introduced by the new Law on Volunteering. Such mechanisms could in practice indirectly benefit CSOs and HRDs.

Specific protection and support mechanisms for civil society and HRDs were reported in five ENNHRI members (Albania, Bosnia and Herzegovina, Georgia, Kosovo*, and Ukraine), which take the shape of legal aid, safe houses, emergency response systems, and anti-SLAPPs protection mechanisms. A noteworthy advancement in this regard took place in Kosovo*, which became the first country in Europe to ensure that SLAPPs are treated as priority cases by the courts through its new SLAPPs protection mechanism. It also includes priority handling of defamation cases and criminal cases linked to CSOs, journalists, and media professionals. The relevant SLAPP protection mechanism is also being developed in Ukraine by an interagency working group chaired by a parliamentary committee.

Only one NHRI from enlargement country – in Ukraine – mentioned a specific national strategy to protect HRDs. Adopted for the period 2021-2026, it prioritises the creation of a favourable legal environment for the activities of civil society organisations and ensuring their participation in public decision-making processes.

While four of the ENNHRI members in the enlargement countries (Albania, Kosovo*, Moldova, and Ukraine) reported that women HRDs and women’s rights CSOs were disproportionately affected by intimidation, harassment, and online abuse, no enlargement country has developed a gender-sensitive strategy to address these issues. As a result, issues of harassment and intimidation remain largely unresolved, as reported by the Ukrainian NHRI. 

NHRI initiatives in 2025 to promote civil society space and HRDs

ENNHRI’s 2026 reporting demonstrates that NHRIs in enlargement countries continue to undertake a broad range of activities aimed at strengthening civil society participation and supporting HRDs, often in challenging operating environments.

A clear trend across enlargement countries is the promotion of civic space and awareness-raising on the role of civil society and human rights defenders. The ENNHRI members in Albania, Bosnia and Herzegovina, Georgia, Kosovo*, Moldova, Türkiye and Ukraine carried out communication campaigns, public events, outreach activities and awareness-raising initiatives to increase public understanding of human rights and strengthen the visibility of civil society actors and HRDs. Several NHRIs also used public statements and media engagement to raise concerns regarding restrictions affecting human rights defenders and civic freedoms.

Another prominent trend is structured dialogue and cooperation with CSOs and HRDs. The large majority of reporting NHRIs organised consultations, roundtables, conferences and advisory mechanisms bringing together civil society actors, public authorities and other stakeholders. Such activities were reported by nine ENNHRI members, namely, in Albania, Bosnia and Herzegovina, Georgia, Kosovo*, Moldova, Montenegro, Serbia, Türkiye and Ukraine. In several countries, NHRIs established or maintained permanent consultation structures, advisory bodies or dialogue platforms aimed at facilitating regular engagement and information exchange with civil society.

Many NHRIs also focused on strengthening the capacity of civil society actors and human rights defenders. Capacity-building initiatives were reported by the ENNHRI members in Albania, Kosovo*, Montenegro, Türkiye and Ukraine, including dedicated training activities, support to advocacy efforts, information sessions, and initiatives aimed at enhancing engagement with national and international human rights mechanisms. Through these activities, NHRIs contributed to strengthening the ability of civil society actors to participate effectively in public affairs and human rights protection.

In addition, several NHRIs undertook advocacy and advisory activities to promote an enabling environment for civil society participation and the protection of human rights defenders. For example, the NHRIs in Albania, Moldova, North Macedonia and Serbia reported advocating for stronger consultation frameworks, greater involvement of civil society in decision-making processes, improved access to public funding, and enhanced protection mechanisms for HRDs and vulnerable groups. Such engagement reflects the role of NHRIs as independent bridge-builders between civil society and public authorities.

NHRI actions to protect civil society space and HRDs

In addition to promoting civic space and supporting civil society participation, NHRIs in enlargement countries also undertake a range of activities aimed at protecting CSOs and HRDs. ENNHRI’s 2026 reporting indicates that NHRIs increasingly use their monitoring, complaints-handling, advisory and specialised protection mandates to respond to challenges affecting civic space and the work of HRDs.

A notable trend is the monitoring and documentation of threats to civic space and HRDs. The NHRIs in Albania, Bosnia and Herzegovina, Georgia, Serbia, Türkiye, and Ukraine reported monitoring activities relating to civic space, human rights defenders, journalists and public participation. In Albania, the NHRI’s monitoring focused on online threats, journalist safety and the impact of restrictions on women and LGBTQ+ defenders. The Georgian NHRI has established internal guidance on work concerning HRDs and combined media monitoring, social media monitoring and detention monitoring. During 2025, the NHRI visited 131 detained individuals in the context of protests and documented allegations of ill-treatment and physical injuries. While less widespread, some NHRIs also engaged in monitoring and intervention concerning individual cases affecting human rights defenders and civic space. In Georgia, for example, the NHRI publicly addressed cases involving detained journalists and human rights defenders, monitored their treatment, and raised concerns regarding restrictions on freedom of expression and civic freedoms. Such actions demonstrate the important role NHRIs can play in responding to threats against HRDs and safeguarding civic space. 

Another significant trend is the handling of complaints and provision of legal support to CSOs and HRDs. Eight ENNHRI members from enlargement countries (Albania, Bosnia and Herzegovina, Georgia, Moldova, Montenegro, North Macedonia, Türkiye and Ukraine) reported receiving and addressing complaints concerning civic space, freedom of expression, discrimination and other human rights violations affecting civil society actors. Several NHRIs also provided legal advice or legal analysis. In Georgia, the NHRI submitted a series of amicus curiae opinions in cases involving journalists, protesters and human rights defenders, contributing to acquittals in several cases and raising concerns regarding pretrial detention, privacy rights and freedom of assembly. In North Macedonia, the NHRI identified complaint handling and legal assistance as the institution’s core protection activities.

NHRIs also play an important role in issuing recommendations and advocating for legislative and policy reforms to strengthen civic space and the protection of HRDs. This was reported by nine NHRIs, namely Albania, Bosnia and Herzegovina, Georgia, Moldova, Montenegro, North Macedonia, Serbia, Türkiye and Ukraine. For example, the Albanian NHRI issued recommendations concerning civil society access to public funding, participation in decision-making processes and consultation standards. The Ukrainian NHRI provided recommendations regarding access to information and the protection of journalistic activities during martial law, while the Georgian NHRI continued to raise concerns regarding legislative developments and judicial practices affecting civic freedoms and human rights defenders.

Several NHRIs further contribute to CSOs’ and HRDs’ protection through specialised mandates and institutional protection mechanisms. The NHRIs in Bosnia and Herzegovina, Georgia, Moldova, Montenegro, Serbia and Ukraine reported using mandates such as the NPM, whistleblower protection functions, anti-trafficking mandates or dedicated human rights defender frameworks to support and protect civil society actors. In Georgia, the NHRI has developed a dedicated institutional framework on human rights defenders and has included a dedicated chapter on HRDs in its annual reports since 2019. In Bosnia and Herzegovina and in Serbia, the NHRIs’ specialised mandates facilitate structured engagement with civil society organisations as part of monitoring and protection activities.

ENNHRI’s reporting also highlights growing attention to the protection of women human rights defenders and defenders of LGBTI rights. The Albanian NHRI integrated gender considerations throughout its monitoring, advocacy and protection activities, including through work on gender equality legislation and monitoring of the impact of restrictions on women and LGBTI defenders. In Georgia, the NHRI undertook targeted interventions in cases involving women human rights defenders and journalists, including through amicus curiae submissions and dedicated monitoring of detention conditions.

The findings demonstrate that NHRIs in enlargement countries are increasingly using their independent mandates to monitor civic space, respond to violations affecting HRDs, provide legal and institutional protection, and advocate for stronger safeguards for civil society and human rights defenders.

In light of the challenges identified, further efforts are needed to strengthen the protection and support provided to HRDs and CSOs across enlargement countries.

To national authorities

ENNHRI calls on national authorities in enlargement countries to ensure a safe and enabling environment for civil society and human rights defenders, including by preventing and addressing intimidation, harassment, smear campaigns, strategic lawsuits against public participation (SLAPPs), and online attacks. National authorities should establish or strengthen effective protection mechanisms for HRDs (including NHRIs’ role in this), ensure prompt investigations into threats and attacks, and guarantee accountability for violations.

ENNHRI further calls on national authorities to ensure meaningful participation of CSOs and HRDs in legislative and policy-making processes, strengthen standards for public consultation, and guarantee access to information. Authorities should also ensure predictable, transparent and sustainable funding frameworks for civil society organisations, including those providing essential services and support to vulnerable groups.

ENNHRI emphasises that independent and adequately resourced NHRIs are essential for the effective protection of HRDs and civic space. Enlargement countries should therefore strengthen the legal, financial and operational independence of NHRIs, in line with the UN Paris Principles, and ensure that NHRIs have the necessary capacities to monitor threats, respond to violations and engage effectively with civil society. Particular attention should be paid to emerging challenges, including digital threats and online harassment targeting HRDs, as well as the specific risks faced by women human rights defenders and defenders working on gender equality and LGBTI rights.

To European and regional actors

ENNHRI calls on the European Commission, EU Delegations and other regional and international actors to continue supporting civil society, human rights defenders and NHRIs in enlargement countries through funding, capacity-building and technical assistance. The EU should ensure systematic monitoring of civic space and the situation of HRDs within the Enlargement Package, the EU Civil Society Strategy, and related rule of law processes, and respond promptly where developments undermine fundamental rights, democracy or the rule of law.

Further, ENNHRI encourages the European Commission and regional partners to support NHRIs in their role to support and protect HRDs, through peer exchange, training and cooperation initiatives, including on monitoring methodologies, HRD protection mechanisms and responses to emerging challenges. Strengthening the role of NHRIs as independent protection actors will contribute to more resilient civic space, stronger democratic participation and greater respect for human rights throughout the enlargement region.

Democracy is a foundational EU value and a core element of the accession process. Respect for democratic principles, the rule of law, and human rights forms an integral part of the Copenhagen criteria and remains central to the EU enlargement agenda. As consistently underlined in the European Commission's Enlargement Packages and annual country reports, democratic institutions, effective checks and balances, meaningful public participation, and an enabling environment for civil society are essential for ensuring accountable governance and promotion and protection of human rights.

Democratic processes across the enlargement region continues to face significant challenges. Similar to trends identified in the EU 2025 Enlargement Package and the European Democracy Shield initiative, NHRIs report  concerns regarding the quality and inclusiveness of decision-making processes, the increasing use of expedited legislative procedures, declining trust in public institutions, disinformation, and pressures on civic space and public participation. Insufficient follow-up to independent oversight recommendations, and limited stakeholder consultation in legislative processes. Obstacles to transparency and accountability further compound these challenges, risking the weakening of safeguards designed to ensure participatory, evidence-based and rights-respecting policymaking.

As independent institutions established in line with the UN Paris Principles, NHRIs play an important role in strengthening democratic governance and resilience. Through their monitoring, reporting, advisory, and awareness-raising functions, NHRIs support transparent and accountable governance, facilitate dialogue between public authorities and society, and promote the meaningful participation of CSOs, HRDs, and other stakeholders in public decision-making — including by countering democratic backsliding, advocating for inclusive law-making processes and promoting the implementation of recommendations aimed at strengthening democratic institutions.

The present report examines developments affecting democratic governance and resilience across enlargement countries, with particular attention to the quality of legislative and policy-making processes, stakeholder participation and consultation, follow-up to NHRI recommendations, access to information, and emerging challenges linked to disinformation and democratic accountability. However, it should be noted that the involvement of NHRIs from the enlargement region in the above-mentioned areas differs depending on mandates, thematic priorities and the context.

Emerging technologies, including artificial intelligence and digital communication platforms, continue to transform information environments across enlargement countries. While these developments create new opportunities for access to information, public participation, and democratic engagement, they also facilitate the rapid dissemination of disinformation, hate speech and manipulated content. Similar to concerns identified in the EU 2025 Enlargement Package and the EU’s broader efforts to strengthen democratic resilience, including the European Democracy Shield, NHRIs in the enlargement countries reported that disinformation increasingly affects democratic governance, public trust and the effective enjoyment of human rights.

These findings reflect broader trends identified in the European Commission’s annual enlargement assessments, which continue to highlight challenges related to media freedom, strategic communication, foreign information manipulation and interference across the enlargement region. 

In several countries, disinformation is reported to contribute to societal polarisation, undermine informed public debate and electoral processes, weaken trust in public institutions, and disproportionately affect vulnerable groups. The issue is particularly acute in contexts characterised by geopolitical tensions, conflict-related information operations and heightened political polarisation. 

Human rights implications of the spread of disinformation

NHRIs in the enlargement countries reported a wide range of human rights issues linked to disinformation. Similar to findings across the EU, institutions highlighted adverse effects on the freedom of thought and the right to hold opinions without interference, freedom of expression, privacy and participation in public life. The NHRIs in Bosnia and Herzegovina, Montenegro, and Türkiye identified growing concerns regarding the impact of disinformation and hate speech on individuals' ability to form opinions freely and participate in informed public debate. The NHRI in Bosnia and Herzegovina further reported that hate speech targeting ethnic, religious and gender identities contributes to social polarisation and undermines democratic discourse.

Several NHRIs also identified significant impacts on democratic participation and trust in public institutions. The Albanian NHRI reported that disinformation and online hostility affected the participation of women candidates during the 2025 parliamentary elections, including through misogynistic attacks, stereotypical narratives, and digital violence. The ENNHRI member in Kosovo* reported electoral disinformation attempts during the electoral period, including campaigns linked to foreign information influence, while the Ukrainian NHRI highlighted the role of disinformation in undermining trust in democratic institutions and promoting narratives aimed at weakening societal resilience during wartime. Disinformation was also identified as a significant concern in the ENNHRI 2026 Report on the State of the Rule of Law in the European Union, where a large number of ENNHRI members reported its corrosive effect on public trust in democratic institutions

Privacy-related concerns were reported by ENNHRI members in Bosnia and Herzegovina, Kosovo*, Moldova, and Ukraine. The Ukrainian NHRI identified the manipulative use of personal data, including doxing, fake profiles, unlawful disclosure of personal information, and targeted intimidation campaigns, as a particularly serious concern. Under martial law, such practices may create additional security risks and contribute to offline harassment and persecution. NHRIs also identified specific groups disproportionately affected by disinformation, including women in politics, migrants, ethnic and religious minorities, children, journalists, human rights defenders, internally displaced persons, and persons living in conflict-affected areas. In Türkiye, the NHRI highlighted digital Islamophobia as an emerging form of disinformation contributing to discrimination and restrictions on the enjoyment of freedom of religion or belief.

Actions taken by NHRIs to address disinformation

NHRIs across enlargement countries reported a broad range of activities aimed at addressing the human rights implications of disinformation through monitoring, awareness-raising, reporting, and engagement with public authorities. Several NHRIs have monitored disinformation trends as part of their broader human rights mandate. The NHRIs in Albania, Bosnia and Herzegovina, Moldova, and Ukraine reported monitoring activities relating to the human rights dimension of electoral processes including media narratives, online hate speech, privacy violations and information manipulation. The Ukrainian NHRI also reported monitoring the implementation of measures aimed at countering disinformation in light of recommendations issued by the EU, the Council of Europe and the OSCE.

Many NHRIs have also made use of their advisory functions to provide recommendations and guidance to public authorities. The NHRI in Bosnia and Herzegovina continued to advocate for stronger regulation of the online media environment and measures to address hate speech, while the NHRI in Moldova issued recommendations concerning electoral integrity, protection of children and prevention of manipulation of public opinion. The Ukrainian NHRI reported extensive work on recommendations relating to personal data protection, privacy safeguards, content moderation and alignment of anti-disinformation measures with European human rights standards.

Awareness-raising and promotion of reliable information sources also featured prominently in NHRIs’ responses. The Albanian NHRI organised outreach activities in schools and communities focusing on the impact of disinformation and online harassment on children, while the Moldovan NHRI promoted verification of information through credible and pluralistic sources. The NHRI in Montenegro reported positive developments concerning journalist protection, including the establishment of an interdepartmental working group on journalist safety and the introduction of new guidance aimed at strengthening responses to disinformation while protecting professional journalism. Several NHRIs also highlighted cooperation with civil society, media actors and international organisations as an important element of addressing disinformation through a human rights-based approach.

National follow-up to European recommendations and standards

Several NHRIs from the enlargement countries reported steps taken nationally aimed at implementing recommendations and standards developed by the European Union, the Council of Europe and other regional actors to strengthen information integrity. The Moldovan NHRI reported on the adoption of a national framework on strategic communication and countering disinformation for the period 2024–2030. The Albanian NHRI shared information about a new national strategy addressing foreign interference and disinformation, while also strengthening cooperation with European partners in the area of hybrid threats and cybersecurity. The ENNHRI member in Kosovo* pointed to the launch of a Government Communications Manual aimed at improving strategic communication and resilience against misinformation, while the NHRI in Ukraine indicated the development of guidance and training materials promoting rights-based approaches to information management and access to information during wartime.

At the same time, several NHRIs raised concerns regarding the human rights implications of certain measures adopted to counter disinformation. The Moldovan NHRI reported concerns relating to the compatibility of some anti-disinformation measures with freedom of expression and access to information, emphasising the need for a human rights-based approach. The NHRI in Bosnia and Herzegovina identified the criminalisation of defamation in Republika Srpska as a matter of concern, echoing recommendations made by European institutions regarding freedom of expression and media freedom. The NHRI in Ukraine similarly reported concerns regarding disproportionate restrictions on access to information, as well as accessibility barriers affecting official information resources. These examples demonstrate that while efforts to counter disinformation are increasingly recognised as necessary, they must remain compliant with international human rights standards and avoid creating undue restrictions on freedom of expression, access to information and democratic participation.

ENNHRI reporting confirms that disinformation is becoming an increasingly significant challenge for democratic resilience across enlargement countries. Similar to trends identified across the EU, NHRIs in enlargement countries underlined the importance of addressing disinformation through a human rights-based approach that combines media literacy, independent oversight, transparency, protection of journalists and safeguards for freedom of expression, while strengthening public trust in democratic institutions and processes.

To national authorities

On the basis of the identified challenges related to disinformation and its impact on democratic participation, public trust and fundamental rights, ENNHRI calls on national authorities in enlargement countries to develop coherent, transparent and rights-compliant responses to disinformation. Counter-disinformation measures should be clearly prescribed by law, necessary, proportionate, and subject to effective oversight and appeal mechanisms. They should safeguard freedom of expression, media freedom, access to information, privacy, and personal data protection, while ensuring that measures cannot be misused for political purposes or to restrict legitimate public debate.

ENNHRI urges national authorities to strengthen legal and institutional frameworks addressing disinformation, hate speech, online harms and media regulation in line with European and international human rights standards. This includes ensuring that relevant draft laws are publicly accessible and subject to timely, inclusive and meaningful consultation with NHRIs, civil society, independent experts, journalists and media actors. Public authorities should also ensure stronger coordination with NHRIs and independent oversight bodies when assessing the human rights implications of counter-disinformation measures.

ENNHRI further calls on national authorities to invest in media and digital literacy, critical thinking and public education for citizens of all ages, with particular attention to children, young people and groups most exposed to disinformation or digital harms. Authorities should promote access to reliable, pluralistic and accessible sources of information, communicate proactively with the public and media in a timely and accurate manner, and reduce information gaps that may enable disinformation to spread. Public officials should refrain from disseminating false or misleading information and should contribute to a public information culture grounded in accuracy, accountability, and respect for human rights.

To European and regional actors

ENNHRI calls on European and regional actors, including the European Union, the Council of Europe and the OSCE, to support enlargement countries in developing rights-based approaches to countering disinformation. Such support should include technical assistance, exchange of good practices, capacity-building, support for independent media and media literacy initiatives, and strengthened cooperation with NHRIs and civil society. European actors should continue monitoring whether national counter-disinformation frameworks comply with freedom of expression, privacy, access to information and democratic participation standards.

Further, ENNHRI stresses that responses to disinformation in enlargement countries should be connected to broader efforts to strengthen democratic resilience, rule of law and fundamental rights in the enlargement process. NHRIs should be meaningfully involved in the design, implementation and monitoring of counter-disinformation policies, including national strategies, media regulation, election-related measures and digital governance frameworks. Their independent monitoring and advisory role are essential to ensure that efforts to address disinformation strengthen, rather than undermine, democratic institutions and human rights.

The quality of law-making processes is a key indicator of democratic resilience and respect for the rule of law, directly affecting the protection of human rights, legal certainty and public trust in institutions. As highlighted in the Council of Europe's standards on participatory democracy and OSCE/ODIHR’s guidelines, which apply to all member and participating states, meaningful public participation, effective parliamentary scrutiny and rights-based legislative processes constitute core democratic benchmarks. The EU 2025 Enlargement Package reaffirms these standards specifically for candidate and potential candidate countries as part of their broader democratic reforms and EU accession efforts. Current reporting from NHRIs in the enlargement countries confirms that significant challenges affecting the quality and inclusiveness of law-making processes persist across the enlargement region. Mirroring the findings highlighted in the ENNHRI's 2026 report on the state of the rule of law in the European Union, NHRIs reported frequent reliance on expedited legislative procedures, insufficient consultation periods, limited participation opportunities for stakeholders, and inadequate use of human rights impact assessments. In addition, enlargement-country NHRIs reported structural shortcomings affecting legislative transparency, stakeholder engagement and implementation of adopted legislation.

Key challenges affecting law-making processes

The most frequently reported challenge concerns the extensive use of fast-track and emergency legislative procedures, identified by the NHRIs in Albania, Bosnia and Herzegovina, Georgia, Moldova, North Macedonia, and Ukraine. Similar to concerns raised by several EU NHRIs, ENNHRI members in the enlargement countries reported that accelerated procedures often limit parliamentary scrutiny, public debate, and stakeholder participation. The NHRI in Bosnia and Herzegovina noted that urgent procedures have increasingly become the norm rather than the exception, while the Georgian NHRI highlighted repeated use of accelerated procedures affecting legislation related to the judiciary, freedom of assembly, and media regulation. The Ukrainian NHRI reported cases where amendments affecting social protection and pension rights were introduced through budget legislation, limiting opportunities for substantive debate and review.

Closely linked to the above-mentioned trend are concerns regarding insufficient consultation periods and barriers to meaningful participation. The NHRIs in Albania, Bosnia and Herzegovina, Georgia, Moldova, Montenegro, and North Macedonia reported that consultations are often organised within very limited timeframes or take place in a largely formalistic manner. Several NHRIs noted that civil society organisations, affected communities and independent institutions are not systematically involved in legislative processes. In addition, enlargement-country NHRIs identified the absence of institutionalised mechanisms to ensure that stakeholder input is meaningfully considered in final legislative outcomes.

A further recurring challenge concerns the limited use of human rights impact assessments (HRIAs). This issue was identified by the NHRIs in Albania, Bosnia and Herzegovina, Georgia, Moldova, Montenegro, and Ukraine. NHRIs reported that draft legislation is often adopted without adequate assessment of potential human rights implications, particularly where accelerated procedures are used. The Georgian NHRI noted that fast-track procedures frequently prevent thorough impact assessments and broader public debate, while the Ukrainian NHRI highlighted the absence of systematic equality and human rights assessments in legislative and policy-making processes. 

Several NHRIs also identified additional challenges affecting legislative quality and implementation. These include formalistic public consultations and limited access to information (Moldova), failure to adopt implementing legislation (Bosnia and Herzegovina and Ukraine), legal uncertainty resulting from inconsistent legislative frameworks (Ukraine), weak interinstitutional coordination (North Macedonia), and in the case of Kosovo*, the prolonged inability to constitute legislative institutions, effectively preventing legislative activity during the reporting period.

Gender and inclusion in law-making processes

Several NHRIs highlighted that shortcomings in legislative processes disproportionately affect women and groups at risk of marginalisation. The Albanian NHRI reported barriers affecting the participation of women, LGBTQ+ persons and minority communities in legislative consultations, while also identifying disinformation campaigns and hostile narratives targeting gender equality legislation and women's rights organisations. The Ukrainian NHRI reported the absence of systematic gender-sensitive impact assessments and highlighted insufficient participation of women, LGBTI persons and other vulnerable groups in policy development processes. These findings suggest that weaknesses in participatory law-making can reinforce existing inequalities and reduce the responsiveness of legislation to the needs of diverse groups.

NHRI actions to strengthen law-making processes

NHRIs across enlargement countries continue to play an active role in promoting transparent, inclusive and rights-based legislative processes. Similar to practices observed among EU NHRIs, institutions engage through monitoring, legislative opinions, recommendations, public advocacy and participation in working groups.

Monitoring of legislative developments was reported by almost all enlargement-country NHRIs (in Albania, Bosnia and Herzegovina, Georgia, Moldova, Montenegro, North Macedonia, and Ukraine). Several institutions systematically assess compliance with parliamentary procedures, transparency requirements and human rights standards. In Georgia, the Public Defender repeatedly raised concerns regarding accelerated legislative procedures affecting fundamental rights, including amendments concerning the judiciary and freedom of assembly.

NHRIs also continued issuing recommendations and legislative opinions. The Moldovan NHRI reported providing 296 opinions on draft legislation between 2022 and 2025. The Albanian NHRI submitted opinions and human rights assessments on draft laws and strategic reforms, including the Intersectoral Justice Strategy. The NHRI in Bosnia and Herzegovina issued recommendations and opinions concerning disability rights, inclusive education, and social protection legislation, some of which resulted in legislative amendments. The NHRIs in Montenegro and North Macedonia similarly reported advocating for amendments where legislation was found to be inconsistent with human rights standards.

Several NHRIs also sought to strengthen accountability and public debate through public statements, parliamentary engagement and strategic litigation. The Moldovan NHRI participated in parliamentary hearings and Constitutional Court proceedings concerning procedural deficiencies in law-making. The ENNHRI member in Kosovo* challenged legislative provisions before the Constitutional Court due to concerns regarding legal certainty and effective remedies. The Ukrainian NHRI actively participated in expert and governmental working groups developing anti-discrimination, disability rights, child rights and personal data protection legislation.

Follow-up to European recommendations on law-making processes

A number of NHRIs from the enlargement countries reported measures aimed at strengthening legislative processes in response to recommendations issued by the European Union, the Council of Europe and OSCE/ODIHR. Similar to positive developments identified in some EU Member States, several enlargement countries have undertaken reforms to strengthen transparency, participation and alignment with European standards.

The Moldovan NHRI reported efforts to modernise parliamentary procedures, improve transparency, and strengthen consultation mechanisms as part of broader EU accession reforms. The Albanian NHRI highlighted the introduction of an electronic legislation portal aimed at facilitating public participation and access to legislative information. The Ukrainian NHRI reported extensive engagement in legislative reforms linked to the EU accession, including personal data protection, anti-discrimination, accessibility and disability rights legislation, with the NHRI participation embedded in several reform processes. The NHRIs in Georgia, Montenegro, and North Macedonia also reported cooperation with the Council of Europe, OSCE and EU institutions to strengthen legislative frameworks and improve compliance with international standards.

Despite these positive developments, NHRIs across the region continue to report that implementation remains uneven. Procedural reforms do not always translate into meaningful participation, effective human rights impact assessments or stronger legislative scrutiny in practice. ENNHRI's reporting therefore confirms the continued need to strengthen participatory, transparent and evidence-based law-making processes as an essential component of democratic governance, rule of law reforms and EU accession efforts.      

To national authorities

ENNHRI calls on national authorities in enlargement countries to ensure that law-making processes are transparent, participatory, accessible and evidence-based. Draft legislation should be made publicly available at an early stage and be subject to timely, meaningful and inclusive consultation with NHRIs, civil society, academia, social partners, affected communities and other relevant stakeholders. Particular efforts should be made to ensure the effective participation of groups whose voices are often underrepresented in decision-making processes, including women, persons with disabilities, minority groups and other individuals at risk of exclusion.

ENNHRI further urges national authorities to limit the use of expedited and emergency legislative procedures to genuinely exceptional and duly justified circumstances. Legislative proposals should be accompanied by adequate explanatory materials, impact assessments and sufficient implementation periods to allow meaningful scrutiny, adaptation and effective implementation. Human rights considerations should be systematically integrated throughout the legislative process, including through the use of human rights impact assessments where appropriate.

In addition, national authorities should strengthen mechanisms for monitoring, evaluating and reviewing the implementation and effectiveness of legislation. This includes ensuring consistent application of laws, improving coordination among public authorities, and establishing effective follow-up mechanisms to assess whether legislative measures achieve their intended objectives while respecting human rights and rule of law standards.

To European and regional actors

ENNHRI calls on the European Union and other regional actors to continue promoting high standards of democratic governance, legislative transparency and stakeholder participation as part of enlargement-related reforms. Particular attention should be given to supporting inclusive law-making practices, strengthening parliamentary scrutiny, promoting human rights impact assessments and ensuring meaningful engagement of NHRIs in legislative and policy-making processes.

Further, ENNHRI encourages European and regional actors to continue supporting NHRIs in their role as independent contributors to legislative processes through capacity-building, peer exchange and structured engagement within enlargement and rule of law frameworks. The expertise and independent oversight provided by NHRIs contribute to improving legislative quality, strengthening democratic accountability, and ensuring that reforms remain grounded in human rights and the rule of law.

ENNHRI members reported that several structural human rights challenges continue to affect the rule of law environment across enlargement countries. Similar to findings identified in the EU 2025 Enlargement Package, these challenges often disproportionately affect persons in vulnerable situations and reflect persistent shortcomings in the protection and implementation of fundamental rights.

A recurring concern relates to the insufficient protection of vulnerable groups and unequal access to rights in practice. ENNHRI members from Albania, Bosnia and Herzegovina, Kosovo*, North Macedonia, Serbia, and Ukraine reported persistent challenges affecting children, persons with disabilities, Roma communities, minority groups, victims of trafficking and other persons in vulnerable situations. These challenges frequently stem from weak implementation of existing legislation, inadequate institutional coordination, insufficient support services and limited resources at national and local level. The ENNHRI member in North Macedonia informed that concerns were raised regarding accessibility barriers affecting persons with disabilities and allegations of discrimination affecting Roma, Turkish and Vlach communities. The NHRI from Albania highlighted continuing gaps in the implementation of children's rights protections, while the NHRI from Serbia reported persistent shortcomings affecting support and protection systems for children, persons with disabilities and victims of trafficking.

Several NHRIs also identified detention conditions and the protection of persons deprived of liberty as persistent structural challenges. NHRIs from Albania, Georgia, Moldova, Serbia and Ukraine reported concerns relating to overcrowding, inadequate healthcare, insufficient safeguards against ill-treatment and weaknesses in complaint mechanisms.  Similar concerns have also been raised by some ENNHRI members in EU Member States which reported prison overcrowding and related structural deficiencies, indicating that detention conditions remain a relevant rule of law concern in parts of the EU as well. In Ukraine, the NHRI further reported systemic shortcomings in prison healthcare, overcrowding and inadequate safeguards in closed institutions, while the NHRI in Moldova continued to identify deficiencies in detention infrastructure and medical services.

ENNHRI members additionally highlighted persistent challenges regarding media freedom, access to information and freedom of expression. The ENNHRI members from Georgia, Kosovo*, Moldova, Montenegro, and Ukraine reported concerns regarding media pluralism, access to public information and restrictions affecting public debate. Several NHRIs noted that limitations on access to information continue to affect accountability and democratic participation, while weaknesses in media regulation and ownership transparency remain unresolved in parts of the region. Similar concerns have been identified by the European Commission in its EU 2025 Enlargement Package and remain closely linked to broader rule of law developments.

Several NHRIs further identified digitalisation and emerging technologies as an evolving structural human rights challenge. The NHRIs from Moldova and Ukraine reported concerns regarding personal data protection, algorithmic decision-making, digital surveillance and access to effective remedies in increasingly digitalised public services. These developments mirror trends identified by ENNHRI members in the EU and underline the need to ensure that digital transformation remains grounded in human rights and rule of law safeguards.

A distinct trend identified in this reporting cycle concerns the impact of armed conflict and occupation on the enjoyment of human rights and the functioning of the rule of law. The Ukrainian NHRI reported widespread and interconnected challenges affecting internally displaced persons, children, victims of conflict-related sexual violence, residents of temporarily occupied territories and other persons affected by Russia’s ongoing armed aggression. Similarly, the Moldovan NHRI highlighted continuing human rights challenges linked to the Transnistrian region. These findings demonstrate that protracted conflict situations continue to create significant and long-term pressures on human rights protection systems and rule of law institutions.

Gender dimensions were also reported across several thematic areas. The NHRI from Albania highlighted barriers faced by survivors of gender-based violence in accessing protection and legal assistance, while the NHRI from Montenegro reported concerns regarding gender-based violence and hate speech. The NHRI in Ukraine further reported challenges relating to conflict-related sexual violence and stressed the need for gender-sensitive approaches in policy-making, implementation and data collection.

The challenges identified by NHRIs demonstrate the continued need to address structural human rights issues as an integral part of rule of law reforms in enlargement countries.

To national authorities

ENNHRI calls on national authorities to strengthen the effective implementation of human rights standards and ensure that rule of law reforms are grounded in the protection of human rights. Particular attention should be given to improving access to justice and legal aid, ensuring the protection of persons in vulnerable situations, strengthening safeguards for persons deprived of liberty, and addressing persistent barriers affecting equality and non-discrimination. National authorities should also ensure adequate resources, effective coordination mechanisms and systematic follow-up to recommendations issued by NHRIs, courts and international human rights bodies.

The gender dimensions of structural human rights challenges should be systematically addressed. National authorities should ensure that women and girls, survivors of gender-based violence and other groups facing intersecting forms of discrimination have effective access to justice, support services and participation in decision-making processes.

To European and regional actors

ENNHRI calls on the European Union and other regional actors to continue supporting enlargement countries in strengthening the implementation of human rights standards and rule of law reforms. This should include technical assistance, capacity-building, support for independent institutions and civil society, and continued monitoring of progress through EU accession and rule of law frameworks. Regional actors should ensure that the protection of fundamental rights remains a central component of enlargement-related reforms and assessments.

Beyond the structural human rights concerns identified above, ENNHRI members reported several developments directly affecting the functioning of justice systems, accountability mechanisms and institutional checks and balances. Similar to findings identified in the EU 2025 Enlargement Package and ENNHRI’s previous reporting, these challenges continue to affect legal certainty, effective remedies and public trust in institutions.

The most frequently reported challenge concerns access to justice and the effective functioning of judicial systems. NHRIs from Albania, Georgia, Kosovo*, Moldova, North Macedonia, Serbia, and Ukraine reported persistent concerns regarding excessive length of proceedings, delays in case resolution and obstacles affecting the right to a fair trial. Several institutions also highlighted growing backlogs and difficulties in ensuring timely access to justice. Similar concerns continue to be identified by the European Commission across enlargement countries.

Closely linked to these developments are structural challenges affecting judicial capacity and efficiency. The ENNHRI members from Albania, Kosovo*, Moldova, and Ukraine reported shortages of judges and court personnel, delays in judicial appointments and broader human resource challenges affecting the administration of justice. The NHRI from Ukraine additionally reported concerns regarding the institutional stability of the Constitutional Court and the continued impact of martial law on the functioning of courts. The NHRI from Türkiye, by contrast, highlighted ongoing judicial reforms aimed at strengthening efficiency, legal certainty and professional capacity within the judiciary.

Several NHRIs also reported persistent concerns regarding the implementation and enforcement of judicial decisions, including judgments of the European Court of Human Rights. The ENNHRI members from Albania, Georgia, Kosovo*, Moldova, North Macedonia, and Serbia highlighted delays or failures in implementing domestic court decisions and ECtHR judgments. As reflected elsewhere in this report, weak implementation continues to undermine legal certainty, accountability, and public confidence in state institutions. Similar concerns have been consistently identified in the EU 2025 Enlargement Package and, in annual ENNHRI rule of law reporting.

Additional challenges were identified regarding access to legal aid and effective remedies, particularly for persons in vulnerable situations. The NHRIs from Moldova and Serbia reported financial, institutional and practical barriers affecting access to legal assistance, while the institutions from Kosovo* and North Macedonia highlighted continuing concerns regarding access to effective remedies and enforcement of rights in practice.

Finally, several NHRIs reported developments relating to anti-corruption frameworks and institutional accountability mechanisms. The NHRI from Moldova noted progress in anti-corruption reforms, while identifying continuing implementation challenges regarding whistleblower protection. The NHRI from North Macedonia highlighted corruption as a persistent obstacle to the rule of law, while other institutions stressed the importance of strengthening accountability mechanisms, institutional oversight and implementation of existing legal frameworks.

The challenges identified by NHRIs demonstrate that the effective functioning of justice systems, accountability mechanisms and institutional checks and balances remains central to strengthening the rule of law across enlargement countries.

To national authorities

ENNHRI calls on national authorities to improve access to justice by addressing excessive delays in judicial proceedings, strengthening judicial capacity, ensuring adequate staffing and resources for courts, and improving access to legal aid, particularly for persons in vulnerable situations. Authorities should further ensure the effective implementation and enforcement of domestic judicial decisions and judgments of the European Court of Human Rights, including through strengthened parliamentary oversight and inter-institutional coordination mechanisms.

ENNHRI further urges national authorities to reinforce the independence, effectiveness and accountability of justice institutions and anti-corruption frameworks. This includes ensuring transparent and merit-based judicial appointments, strengthening anti-corruption measures and whistleblower protection frameworks, and improving oversight mechanisms to enhance public trust in institutions and legal certainty.

In countries affected by armed conflict or occupation, authorities should ensure comprehensive and coordinated responses to rule of law and human rights challenges, including access to justice for victims, accountability for serious human rights violations, protection of children and other affected groups, and effective remedies for conflict-related harm.

To European and regional actors

ENNHRI calls on the European Union and other regional actors to continue supporting justice sector reforms, judicial independence, and the implementation of European human rights standards throughout the enlargement process. Regional actors should strengthen support for NHRIs and other independent oversight institutions, promote the implementation of ECtHR judgments, support human rights-based legislative reforms, and maintain robust monitoring of rule of law developments in enlargement countries.