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DEPARTMENT OF THE TREASURY, OFFICE OF TECHNICAL ASSISTANCE

Program Evaluation Report, 

Kosovo: 

Banking and Financial 

Services 

Government Debt and 

Infrastructure Finance 

December 2022

Headquarters

3050 Chain Bridge Rd., Suite 305

Fairfax, VA 22030

703-634-5701

info@bixal.com

https://www.bixal.com/
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Program Evaluation Report, Kosovo: Banking and Financial Services, Government Debt, 

and Infrastructure Finance

Table of Contents 

Acronyms............................................................................................................................ 3

I. Executive Summary .............................................................................................. 4

II. Program Overview ................................................................................................ 8

III. Evaluation Purpose................................................................................................ 8

IV. Evaluation Questions............................................................................................. 9

V. Methodology and Data Sources.......................................................................... 10

VI. Data Collection.................................................................................................... 12

VII. Data Analysis Process......................................................................................... 14

VIII. Quality Assurance ............................................................................................... 14

IX. Limitations .......................................................................................................... 15

X. EQ1 Findings and Conclusions—Banking and Financial Services .................... 17

XI. EQ2 Findings and Conclusions—Government Debt and Infrastructure Finance28

XII. EQ 3 Findings and Conclusions—Sustainability ................................................ 33

XIII. Recommendations............................................................................................... 36

XIV. Suggested Follow-Up and Next Steps................................................................. 38

XV. Annexes............................................................................................................... 39

Annex A: Evaluation Data Source Matrix ........................................................................... 40

Annex B: OTA Project Document List ............................................................................... 42

Annex C: Context Document List ....................................................................................... 44

Annex D: Data Collection Instruments................................................................................ 45

Annex E: Key Informants Interviewed................................................................................ 53

Annex F: Online Survey of Kosovar Banks........................................................................ 56

Annex G: Overview of the OTA BFS Program................................................................... 61

Annex H: Chronology of OTA BFS Program: Banking, Insurance and Real Estate ......... 67

Annex I: Overview of the OTA GDIF Program................................................................. 70

Annex J: Chronology of OTA GDIF Program Interventions............................................. 73

Annex K: Description of the “Brain Fund” ......................................................................... 75
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Acronyms

BFS Banking and Financial Services

CAMELS Capital adequacy, Assets, Management Capability, Earnings, Liquidity, 

Sensitivity

CBK Central Bank of Kosovo

DMU Debt Management Unit

ELA Emergency Liquidity Assistance

EQ Evaluation Question

FATAA Foreign Aid Transparency and Accountability Act

GDIF Government Debt and Infrastructure Finance

IMF International Monetary Fund

KBA Kosovo Banking Association

KEGA Kosovo Economic Governance Activity

KII key informant interview

M&E monitoring and evaluation 

MOF Ministry of Finance

OECD Organization for Economic Cooperation and Development

OTA Office of Technical Assistance

SME subject-matter expert

TA technical assistance

USAID United States Agency for International Development

Acronym Term
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I. Executive Summary

A. Background

In February 2022, the Department of the Treasury’s Office of Technical Assistance (OTA)

submitted a request to Bixal to design and conduct a summative evaluation of OTA’s 

Government Debt and Infrastructure Finance (GDIF) and Banking and Financial Services (BFS) 

programs in Kosovo. OTA has provided technical assistance (TA) in Kosovo’s debt and 

financial services sectors since 2007 and 2012, respectively, using resident and intermittent 

advisors who have worked closely with counterparts in the Central Bank of Kosovo (CBK) and 

Ministry of Finance (MOF). OTA’s program activities supported supervision and development 

of the banking and insurance sector, working closely with the CBK. OTA’s GDIF advisors 

focused on building Kosovo’s sovereign debt capacity and providing expert guidance in 

developing a Debt Management Unit (DMU) and supporting Kosovo’s government securities 

market. Both programs provided support to the mortgage market as well. 

B. Evaluation Purpose

The evaluation serves two purposes. First, the evaluation was conducted to meet the 

requirements of the Foreign Aid Transparency and Accountability Act (FATAA) of 2016, which

requires agencies implementing foreign assistance funds to evaluate the outcomes and impacts of 

their programs. Second, the evaluation also provides OTA with an understanding of its 

contributions to Kosovo’s public debt management and financial sector strengthening, as well as 

the sustainability of OTA’s program outcomes. The main evaluation audience is OTA’s 

monitoring and evaluation, GDIF, and BFS teams, although the report may be shared in full or 

part with the United States Department of State, OTA advisors, advisor counterparts in Kosovo, 

program stakeholders, and others at OTA’s discretion.

From February through June 2022, an evaluation team of French, Kosovar and U.S.subjectmatter experts (SMEs) and monitoring and evaluation (M&E) specialists analyzed three key 

evaluation questions, selected in a collaborative process with the OTA BFS, GDIF, and M&E 

teams:

C. Evaluation Questions and Methods

The evaluation team collaborated with OTA to determine the evaluation’s focus and scope. 

OTA selected the following high-level evaluation questions:

1. In which ways did OTA’s TA contribute to financial sector-strengthening in Kosovo?

2. In which ways did OTA’s TA contribute to improved public debt management in Kosovo?

3. Which identified outcomes of OTA’s TA in Kosovo have been sustained over time? 

The evaluation team gathered data and information from a desk review of project documents 

provided by OTA, external documents with context and background information from several 

sources, such as the CBK and MOF. The evaluation team conducted a total of 36 key informant 

interviews (KIIs) with OTA advisors working in Kosovo, advisor counterpart officials in the 

MOF and CBK. The evaluation team also interviewed and surveyed members of the Kosovo 
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Banking Association (KBA). 

D. Key Findings and Conclusions

The BFS program’s technical assistance contributed to financial sector-strengthening across the 

banking, insurance, and real estate sectors through providing technical assistance with the 

following activities and interventions:

• Establishment and organizational effectiveness of the CBK. OTA trained CBK 

counterparts in banking supervision and built capacity through on-the-job mentoring in 

developing regulations and operations;

• Kosovo’s 2012 Banking Law that established the CBK and set improved policies 

practices and banking sector corporate governance in accordance with Europe’s Basel 1 

core principles;

• Establishment of the CBK’s emergency liquidity account that can provide emergency 

funds to banks at risk of insolvency;

• Creation of short-term, intraday, and overnight liquidity transactions that enhance market 

stability;

• Development of the Law on Insurance that provides the legal framework for Kosovo’s 

insurance sector;

• Adoption of the Kosovo insurance sector’s solvency and risk oversight policies to comply 

with the EU’s Solvency I standards;

• Implementation of risk-based insurance supervision by writing an insurance supervision 

manual for CBK and training insurance supervisors;

• Development of real estate appraisal regulations that are a critical component to 

Kosovo’s market and trained CBK’s appraisers; and

• Development of mortgage lending regulations that reduce banks’ lending risk, and 

consumer protection for the residential housing sector.

The GDIF program’s technical assistance contributed to improved debt management through 

regulatory framework for sovereign debt, establishment, and development of Kosovo’s debt 

market in the following ways:

• Drafting and implementation of the Law on Public Debt that provides the regulatory 

framework to enable the government to borrow funds;

• Establishment of a Debt Management Unit (DMU) within the MOF to manage debt, and 

issue maturities;

• Developing the primary debt market through the issuance of maturities with lengthened 

debt, a key market indicator, that began with an average of less than two months in 2012 

to more than 35 months in 2020; and

• Coordination among the MOF and the CBK and market participants, establishing regular 

meetings and communications through a Liquidity Committee to manage cash balances 

and investments.

OTA’s contributions toward the establishment and growth of Kosovo’s debt market included 

knowledge and skills transfer through training and mentoring MOF counterparts in legal and 
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regulatory development and capacity-building in the MOF’s institutional operations. OTA also 

helped to establish the primary dealer system, execute liability management operations including 

debt buybacks; supported the DMU with the sovereign ratings process; and drafted a fiscal 

agency agreement between the MOF and CBK.

The sustainability of OTA’s BFS and GDIF program outcomes can be considered within four 

descriptive categories:

1) Outcomes that continue in the present such as the following:

• Law on Public Debt is still current;

• Primary debt market and debt trading system has grown and matured since inception;

• DMU within the MOF has matured since its inception;

• Coordination between the MOF and CBK on sovereign debt has been sustained;

• Emergency Liquidity Account, although never used yet, is an international 

requirement; and

• Establishment of short-term, intraday, and overnight liquidity borrowing mechanisms.

2) Tangible TA products that are still in use, such as:

• Banking risk supervision manual;

• Insurance supervision training manual; and

• Real estate appraisal training manual.

3) Milestone achievements that require revisions to meet current needs, such as:

• The Banking Law needs to be revised to comply with Basel II European standards;

• Risk-based bank supervision is not fully implemented; and

• Insurance regulations need updating to comply with more recent Solvency II 

European industry standards.

4) Outcomes that have only limited relevance or impact because of current, external, 

political and/or market constraints, such as:

• Regulation on mortgage lending has limited current impact on real estate market 

because establishing clear ownership over property is difficult under current law; and

• Regulation on real estate appraisal and training appraisers has limited impact with 

current market conditions such as property rights constraints, and an incomplete 

property cadaster.

E. Recommendations

This is a summative evaluation of OTA’s BFS and GDIF program outcomes and their 

sustainability in Kosovo. Inherent evaluation limitations, including a lack of performance 

indicators, confirmation bias of advisors and counterparts in Kosovo’s pro-American political 

context, limited program documentation, and memory recall limitations constrain the evaluation 

team to making high, program-level recommendations rather than recommendations targeted to 

OTA’s specific activities and interventions. 

Based on outcome-level findings and limitations encountered by the evaluation team, OTA 
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should consider the following:

1) Systematize and document communications, knowledge exchange, and coordination between 

and among advisors and OTA program staff.

2) Improve program-level documentation including periodic, annual, and final reports to capture 

lessons learned and institutional knowledge. 

3) Track progress toward anticipated/expected results through monitoring activities.

4) Incorporate counterpart feedback in programmatic decision-making.

5) Implement best practices in monitoring, evaluation, and learning to improve results while not 

sacrificing the flexibility of OTA’s demand-driven TA model.
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II. Program Overview

Kosovo declared its independence as a new nation, no longer a province of Serbia, on February 

17, 2008. At the outset of the Office of Technical Assistance’s (OTA’s) engagement, Kosovo 

was a newly independent, post-conflict country with significant challenges—diplomatic, 

economic financial, security, social, and political. It was dependent on the international 

community to move from independence toward stability. The first OTA advisor began work the 

same year with Kosovo’s Ministry of Finance (MOF) through OTA’s Government Debt and 

Infrastructure Finance (GDIF) program, beginning with the development of a legal and 

regulatory framework to manage public debt and the initiation of a primary debt securities 

market. Later, in 2012, OTA added Banking and Financial Services (BFS) program activities

that focused on technical assistance (TA) to the Central Bank of Kosovo (CBK). The addition 

contributed to the development of the Banking Law that enabled early milestone achievements 

for both programs, according to a universal consensus from interviews of OTA advisors and their 

counterparts in both programs, set the stage for OTA’s continued contributions to the rapid 

capacity development of the MOF and CBK, improved public debt management, and 

strengthened financial sector.

Implemented by seven different advisors since program inception, OTA’s GDIF program 

activities include developing a regulatory framework on public debt that enabled the MOF to 

borrow funds through the issuance of Treasury Bills in a debt-market trading system. The 

framework also allowed the MOF to manage sovereign debt through the establishment of its 

Debt Management Unit (DMU). Subsequently, GDIF advisors contributed to the further 

development and sustainability of the primary securities market and the MOF’s debt 

management capacity. GDIF TA is still ongoing, although advisors’ TA roles have transitioned 

from active mentoring to serving as consultative resources. 

Eight BFS advisors provided TA to the CBK and contributed to the development of a regulatory 

framework for the insurance sector. Specifically, they helped establish supervisory policies and 

trained the CBK’s first insurance supervisors. OTA also advised several governors and Deputy 

Governors of the CBK and the board of directors in central bank operation practices, corporate 

governance, and oversight for banks. OTA additionally advised the CBK on risk management 

guidelines to bring the CBK into compliance with international standard principles on banking 

supervision. OTA’s BFS program also contributed TA to Kosovo’s still-nascent real estate 

sector through the development of regulations and training appraisers.

III. Evaluation Purpose

This summative evaluation was conceived in collaboration with OTA’s monitoring and 

evaluation (M&E) team. It focuses on OTA’s contributions to achievements — or outcomes —

and the sustainability of those outcomes unique to Kosovo’s circumstances, rather than on 

performance of activities that have either ended or are winding down. Performance-related, 

qualitative data for activities that have long ended would be unreliable and difficult to collect. In 

addition, current advisors are playing a less direct, more consultative role with their counterparts 

than they have in past years. 

The outcomes and sustainability-focused evaluation of OTA/Kosovo’s BFS and GDIF programs 

serves two important purposes:
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1) To support compliance with the Foreign Aid Transparency and Accountability Act 

(FATAA) of 2016,1 which includes requirements to evaluate the outcomes and impacts of 

OTA’s programs whose dollar value equals or exceeds the median program size and 

apply the findings and conclusions of such evaluations to proposed project and program 

design; and

2) To provide OTA with in-depth, third-party, retrospective insights of its BFS and GDIF 

program activities and outcomes in Kosovo. The evaluation focuses on OTA’s

contributions to Kosovo’s financial sector and public debt governance through its 

technical assistance to the CBK and MOF.

IV. Evaluation Questions

Bixal’s evaluation team collaborated with OTA’s M&E, BFS, and GDIF program teams to 

develop a limited number of evaluation questions to better understand OTA’s work in Kosovo, 

including its contributions to financial sector-strengthening, improved public debt management, 

and sustainability of outcomes. The evaluation team’s design approach began with analyzing 

and coding categories of data found in the wide range of documents produced by individual 

advisors working on the two programs. Due to the long timeframe of both projects, the team 

compiled a chronology of activities (see Annex I for BFS and Annex L for GDIF).2 This 

document review resulted in a preliminary set of activities and interventions through which OTA 

contributed to financial sector-strengthening and improved public debt-management/debt-market 

functioning. The team then supplemented the document review with discussions with OTA’s 

M&E, BFS, and GDIF program teams and key advisors to get a base-level understanding OTA’s 

activities and interventions. These discussions also resulted in a consensus among OTA’s M&E, 

BFS, and GDIF teams regarding the evaluation’s scope and three high-level evaluation 

questions.

The evaluation questions provided the foundation for the remaining design elements such as 

methods used, and data sources.

1. In which ways did OTA’s TA contribute to financial sector-strengthening in Kosovo?

This question probes key elements of OTA’s different TA methods and key interventions in the 

BFS program. These included drafting legislation/regulations, capacity-building, creating 

manuals, and training. The evaluation examined selected interventions to better understand how 

OTA contributed to strengthening of the financial sector in Kosovo over time. It analyzed the 

appropriateness of interventions to address Kosovo’s needs and desired outcomes.

2. In which ways did OTA’s TA contribute to improved public debt management in Kosovo?

1 Foreign Aid and Transparency and Accountability Act of 2016, Public Law 114-191 

https://www.congress.gov/114/plaws/publ191/PLAW-114publ191.pdf

2 The OTA advisor for the ongoing GDIF project created a chronology for the evaluation team. The evaluation team 

created a chronology for the BFS project.
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Like question 1, this question probes key elements of OTA’s different TA in the GDIF program 

area. These elements also included drafting legislation/regulations, capacity-building, creating a 

trading system, creating a domestic market for government securities, and training. The 

evaluation examined selected interventions to better understand how OTA contributed to 

Kosovo’s improved public debt management. It also analyzed the appropriateness of 

interventions to the level of regime development in Kosovo and their relationship to desired 

outcomes.

3. Which identified outcomes of OTA’s TA in Kosovo have been sustained over time? 

This question focuses on the sustainability of OTA’s contributions to Kosovo’s financial sector 

and institutions. The evaluation team recognized that some activities were purposefully limited 

or short term in response to specific circumstances and near-term needs. Nevertheless, the 

greater arc of project activities was intended individually and collectively to contribute to 

financial sector-strengthening or improved public debt management.

V. Methodology and Data Sources

The evaluation used a mix of qualitative methods described in this section. These include:

1) A desk review of project and background documents;

2) Key informant interviews conducted on-site and virtually with OTA advisors,

counterparts, and other stakeholders; and

3) A survey of banking stakeholders.

Desk Review Process

Project Documents: The evaluation team conducted a thorough desk analysis of project 

documents provided by OTA to gain a basic understanding of OTA’s activities and interventions 

in both BFS and GDIF program areas. The desk review and initial fact-finding discussions with 

program staff helped put OTA’s TA into an evaluative context, using the six standard criteria

established by the Organization for Economic Cooperation and Development (OECD) including 

effectiveness, efficiency, coherence, impact, and sustainability.

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For evaluation question (EQ)1 and EQ2, the evaluation team focused on the effectiveness and 

efficiency of OTA’s BFS and GDIF program activities and interventions. For EQ3, the 

evaluation team focused on the coherence, impact, and sustainability of OTA’s activities and 

interventions.

OTA provided the following categories of project documents to the evaluation team:

• Proposals to the Department of State proposing funding from the Assistance to Europe, 

Eurasia, and Central Asia appropriation;

• Briefing materials;

• End-of-tour reports;

3 These criteria are described in detail on the website of the Organization for Economic Cooperation and 

Development. See https://www.oecd.org/dac/evaluation/daccriteriaforevaluatingdevelopmentassistance.htm
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• Indicator reference sheets;

• Terms of reference;

• Trip reports; and

• Workplans.

Annex A is the evaluation data source matrix that illustrates the relationship among the three key 

evaluation questions, illustrative sub-questions or probing questions, and proposed methods and 

data sources. 

In addition, the evaluation team used results mapping to better understand the contribution of 

each intervention to the overall result—financial sector-strengthening or improved public debt 

management/debt-market functioning. The results-mapping exercise also provided multiple 

opportunities to cross-reference findings and conduct quality control.

Annex B lists all the OTA documents analyzed.

Contextual Information Sources: The evaluation team conducted a desk review of reports 

published by the European Commission, the Government of Kosovo, Kosovar financial 

institutions, multilateral financial institutions, and research institutions. This review of financial 

sector analyses, reviews, and surveys provided a better understanding of the context of Kosovo’s 

financial sector and debt market. Annex C lists all the context documents analyzed.

Key Informant Interviews

Key informant interviews (KIIs) provided multiple perspectives and sources to support findings 

related to the evaluation questions. Working from interview guides tailored for each category of 

respondents, the evaluation team conducted KIIs to document a full range of perspectives on 

OTA’s work and to validate findings from the initial document analysis. Some KIIs focused on 

specific OTA activities and interventions to answer the three evaluation questions in greater 

detail. 

The evaluation team identified key informants in four categories: 

• OTA program staff and Kosovo advisors;

• Direct Government of Kosovo counterparts (CBK and MOF);

• Beneficiaries (Kosovar banks, the Kosovo Banking Association [KBA], insurance 

companies, the Kosovo Insurance Bureau, and the Kosovo Pension Trust Fund); and

• Stakeholders (other donors engaged in the Kosovar financial sector, multilateral financial 

institutions, the U.S. Embassy, and the United States Agency for International Development

[USAID]).

Annex D contains the interview guides.

Annex E is the list of key informants interviewed.

Stakeholder Survey
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The evaluation team conducted an online survey of member banks of the KBA to understand 

how OTA’s work contributed to financial sector-strengthening (EQ1), public debt management 

(EQ2), and sustainability (EQ3). All ten member banks were invited to participate in the survey.

The survey questions are found in Annex F.

Mixed-Methods Approach

The evaluation team’s design approach started with the desk review, as described above, to 

establish a basic understanding of what OTA did in Kosovo. The KIIs and stakeholder survey

were them used to verify, build on, and/or add nuance to what was already known from the 

documents. The team also analyzed OTA’s contributions to the outcomes.

Preliminary findings for the BFS program (Section X) and GDIF program (Section XI) were 

verified using multiple data sources and conclusions drawn regarding OTA’s contributions to 

overall program outcomes and their sustainability. 

VI. Data Collection 

Document Review

The evaluation team members reviewed documents in a multi-phase process that included

selecting and prioritizing high-value sources (e.g., current and former Ministers of Finance, the

Governor of the CBK, etc.), identifying preliminary findings for deeper probing and verification, 

and coding the documents using the ATLAS.ti. The ATLAS.ti software is qualitative analysis 

application that enables rigorous qualitative coding to systematically catalogue program 

documents. 

KIIs

Between May 3 and June 16, 2022, the Bixal evaluation team conducted KIIs, working in pairs 

as assigned by the team leader. The interviews were in person whenever possible, given 

constraints around scheduling and respondent preference. All interviewers closely followed 

prepared interview guides and instructions to ensure that interviews were unbiased and focused 

on the evaluation questions. Most interviews were scheduled for one hour, with a limited 

number with high-priority respondents scheduled with prior agreement for 90 minutes. 

Interviewers recorded the conversations when possible, to ensure complete and accurate data 

capture. Any notes in Albanian were translated to English for analysis.

Notetakers took notes using a notetaking guide. In advance of the first KII, notetakers were 

trained on the evaluation team’s standard operating procedure for notetaking to ensure they 

captured the highest quality of data.

From May 11-20, 2022, the evaluation team (except Michael Tatone) visited Pristina, Kosovo. 

The evaluation team completed 24 total KIIs with 36 respondents. The box below shows the 

number of participants who spoke about the GDIF or BFS project, or both.
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KII Respondent by Program Respondents

Respondents discussed the OTA BFS program 13

Respondents discussed the OTA GDIF program 11

Respondents discussed both OTA programs 12

KII Respondent Groups 

Direct Government of Kosovo counterparts 15

Beneficiaries 9

Stakeholders 6

OTA program staff and Kosovo advisors 6

KII Respondent Gender

Men 29

Women 7

Total KII Respondents 36

Respondents represented the following institutions (in alphabetical order):

Institution Respondents

Banke Ekonomike 2

Central Bank of Kosovo 8

International Monetary Fund (IMF) 1

Q Kosovo Banking Association 1

Kosovo Insurance Bureau 2

Kosovo Pension Savings Trust 2

Ministry of Finance of Kosovo 7

Office of Technical Assistance (three BFS and three GDIF) 6

Raiffeisen Bank Kosovo 1

Scardian Insurance Company 1

USAID/Kosovo 3

U.S. Embassy in Kosovo 2

Surveys 

As explained above, the evaluation team conducted an online survey of member banks of the 

KBA. The survey allowed the evaluation to probe OTA’s engagement with a defined set of

stakeholders beyond OTA’s direct counterparts, the CBK and the MOF. While the survey 

responses do not represent all Kosovar banks, they enabled the team to validate the results of 

specific OTA activities and interventions. All ten KBA member banks were invited to complete 

the survey. Four banks responded, resulting in a 40% response rate. It is important to note these 
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results do not represent all Kosovar banks, but the ten KBA member banks were invited to 

participate in the survey.

VII. Data Analysis Process

The evaluation team conducted qualitative analyses of KII data on an ongoing basis concurrent 

with fieldwork to ensure quality and the identification of emergent findings and trends as soon as 

possible during the evaluation’s brief data collection phase. Team members completed interview 

notes and shared them with the team leader as soon as possible. The Project Manager coded KII 

notes in ATLAS.ti and analyzed data by grouping similar data under themes or categories. The 

goal was to allow the evaluation team to locate, retrieve, and combine the textual data that 

corresponded to an evaluation question, concept, or theme of interest. Quantitative analysis of 

the survey included crosstabs and summaries of data to both open- and closed-ended questions.

When data collection was nearly complete, all evaluation team members convened for an 

extended analysis workshop. Participants debated, clarified, and verified potential findings and 

trends that emerged throughout the data collection and analysis period. The evaluation team 

distilled insights and ideas from this process into a presentation of preliminary findings to each 

OTA program team for vetting and discussion before the drafting of this final evaluation report. 

The preliminary findings were presented to and vetted by OTA’s M&E, BFS, and GDIF teams 

before they were considered final. With insights from the two presentations, the team analyzed 

the data again for additional validation and verification and conducted an additional KII to 

further probe a subset of the questions.

The evaluation team compiled an overview table of activities and interventions for each program, 

listing indicators, change over time, OTA’s contribution, constraints, and sustainability. (See 

Annex H for the BFS program, and Annex K for GDIF.) Finally, the evaluation team 

diagrammed how together the interventions contributed to results. (See Section X, Figure 2, and 

Section XI, Figure 4.)

VIII. Quality Assurance

The evaluation team followed standard quality assurance best practices:

1) Notetakers uploaded their notes at the end of each day of data collection. The team 

leader/Bixal staff reviewed notes for accuracy, completeness, precision, and quality.

2) The evaluation team met at the end of each day of data collection in Pristina. The team 

discussed what was heard and observed to ensure consistency in collecting and reporting 

data.

3) The ATLAS.ti application enabled the team to check for accuracy and completeness of 

qualitative data as they were entered and coded. Standard cross-checking protocols were

followed to ensure consistency and accuracy.

4) The data analysis workshop provided an opportunity for evaluation team members to 

check each other’s assumptions and cross-check data quality.

5) One subject matter expert (SME) conducted an analysis of both sets of program data —

for BFS and for GDIF. The evaluation team employed a similar line of inquiry and 

methodology to identify and categorize key OTA interventions. A second SME 
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conducted a separate analysis of the GDIF data and reviewed the analysis of both datasets 

of the first SME. 

6) The two SMEs shared their preliminary findings and conclusions with each other first. 

Then the entire evaluation team met to discuss findings and conclusions. The following 

day, the entire evaluation team conducted a follow-up workshop to map findings to 

conclusions and conclusions to recommendations.

IX. Limitations

The evaluation team faced several key limitations of time, resources, and data that constrained 

the evaluation’s possible purposes, scope, and granularity of findings. The OTA and the 

evaluation team were aware of most of these limitations from the beginning, and evaluation 

design choices were made to address these limitations.

Political Positivity Context

The MOF’s and CBK’s perceptions, expressed in KIIs, of OTA’s TA can be illustrated by a 

quote from a high-level counterpart: “It would be impossible for Kosovo to be where we are 

today.... Even if I said ‘thank you’ a thousand times, it would not be sufficient.”

The quote represents the very positive tone of many of the counterparts as well as the OTA 

advisors themselves who were interviewed during the evaluation. It reflects their shared 

perceptions of the MOF’s and CBK’s nascence when OTA’s work began juxtaposed against 

subsequent progress. The evaluation’s findings show ample evidence of OTA’s critical 

contributions to Kosovo’s current, relatively advanced state of debt-market maturity and 

financial stability.

While the positive tone of the evaluation findings indicates an overall success story, it is useful 

to consider Kosovo’s greater context for a balanced interpretation of OTA’s work. The above 

expression of gratitude reflects a recognition of OTA’s contributions, but it also reflects the 

MOF’s and CBK’s early acute needs for TA that, according to counterpart key informants, were 

addressed by “the Americans” more than any other donors or providers of financial TA. The 

quote also illustrates Kosovo’s pro-American political context underlying OTA’s work and the 

evaluation’s findings. The evaluation team considered this context in developing an objective 

understanding of OTA’s work. The evaluation probed for a diversity of perspectives on program 

outcomes, and the findings accurately reflect the various stakeholders’ views.

Demand-Driven Technical Assistance

OTA’s demand-driven TA approach, while responsive to the MOF’s and the CBK’s requests, did 

not follow a predetermined, long-term strategic plan. OTA’s demand-driven approach to TA is 

an important context to the evaluation’s design. Program activities were implemented by 

different, largely independent advisors that were focused on counterparts’ needs and requests. 

According to several advisors representing both Kosovo programs, their demand-driven 

approach precluded the use of program-level, long-term, holistic strategic plans, and 

corresponding performance indicators. For this reason, there is limited apparent connectedness 

between activities. While the project documents reflect some communications among advisors, 

the evaluation findings that identify OTA’s BFS contributions to Kosovo’s financial sectorstrengthening reads like a catalog of discrete activities and interventions undertaken by different 
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advisors, rather than a holistic program working toward a high-level strategic objective or 

following an articulated theory of change. The lack of typical program design elements such as 

theories of change, logic or results frameworks, performance indicators, or baseline measures

limited the ability of the evaluation team to design an evaluation focused on program 

performance using traditional methods.

Project Documentation Limitations

No blueprint or consistently documented overall strategy was conceived when the OTA project 

was launched in Kosovo. Annual reports were not required by OTA or the State Department. 

There is no “final” report for the BFS program. GDIF program activities remain ongoing since 

2008, but there is no document that provides a comprehensive chronology or synthesis. This was 

a key challenge for the evaluation team in gaining an understanding of OTA’s work at a program 

or systems level.

Project documents, while they included descriptions of advisors’ activities (e.g., trip reports), 

they did not document critical information such as connections between activity inputs, outputs,

and outcomes; risk factors, baselines, performance data, externalities that influenced results, 

context data, or training documentation. While OTA’s trip reports provide a basic description of 

advisor activities, they are, based on the evaluation team’s review, insufficient to provide a 

complete and nuanced understanding of activities. Missing, for example, were the logic behind 

how they were selected and designed, details of how they were implemented, what worked and 

did not work, and which results were achieved. Without this documentation, it was difficult in 

some cases for the evaluation team to determine OTA’s contributions to outcomes. 

All eight of the OTA BFS advisors and seven of the eight GDIF advisors who worked in Kosovo

noted in program documents the presence of training activities. Counterparts and stakeholders 

confirmed and validated this. However, training details such as agendas, content, lists of training 

participants, and evaluations were not available to the evaluation team as that documentation was 

apparently not kept. The lack of training activity documentation made it difficult for the 

evaluation team to assess participants’ baseline knowledge, including training utility, whether the 

agenda were appropriate for the participants, content quality, and participants ‘utilization of new

skills4. Combined with memory recall limitations among those participating in the KIIs, it was 

not possible for the evaluation team to probe for OTA’s training activities’ contributions 

regarding EQ1 beyond a general statement confirming that training occurred and at least some 

participants were assumed to be able use their new skills.

The team also found inconsistencies in documents such as missing counterpart feedback surveys 

and other missing or non-existent end-of tour documents for some years and/or some advisors.

These documents the evaluation team did not have access to could have been a good source of 

additional recommendations and constructive feedback. The few counterpart feedback surveys 

shared (by counterparts) included constructive criticism rarely heard during KIIs. The 

counterpart surveys also target the work of advisors, rather than interventions. This makes it 

4 These criteria are described in detail on the website of the Organization for Economic Cooperation and 

Development. See https://www.oecd.org/dac/evaluation/daccriteriaforevaluatingdevelopmentassistance.htm
17

difficult to track the success and results achieved by an activity or intervention, which may have 

been implemented by more than one advisor. This lack of documentation may have exacerbated 

the aggregate positive trend in the findings.

The many project documents written by numerous individual OTA advisors include many pointin-time details that suggest a large body of successful outcomes. Nevertheless, the evaluation 

team, individually and collectively, struggled initially to develop the big-picture story of OTA’s 

work in Kosovo from this mosaic. For example, the absence of quarterly or annual reports

presented a challenge to the evaluation team in fully understanding the BFS and GDIF program’s 

long arc and any interconnectivity among OTA’s many different interventions over a 14-year 

history in Kosovo. For this reason, the evaluation team chose different approaches to 

conceptualize OTA’s work: an overview table (Annexes G and I), a chronology (Annexes H and 

J), and a results diagram (see Sections X and XI) for each program. 

Time and Limited Memory Recall

Another important aspect of the evaluation’s context is the amount of time that has passed 

between OTA’s most intense periods of activity and the evaluation’s interviews with advisors, 

counterparts, and other stakeholders. In many cases, the key informants’ perspectives of 

activities that happened years in the past may have changed. A lens of selective memory and 

current circumstances may contribute to a key informant’s overall positive retrospective. For 

example, an MOF counterpart, reflecting on his or her experience as their younger self working 

with an OTA advisor, stated in a KII that “I remember working long hours and being exhausted 

and overwhelmed, but now I know that it was necessary and worth it.”

Memory limitations and recall bias presented significant challenges to the evaluation team

whenever probing questions to counterparts related to what didn’t work, or what might have 

been done better. Similarly, advisors expressed a generally positive, enthusiastic perspective 

regarding their work with their counterparts that may partially result from selective memory. 

X. EQ1 Findings and Conclusions—Banking and Financial Services

EQ1: In which ways did OTA’s TA contribute to financial sector-strengthening in Kosovo?

This section describes the evaluation findings for EQ1 under the three different sectors in which 

OTA worked: Kosovo’s banking, insurance, and real estate sectors. Figure 1 represents the 

findings as a list of OTA’s activities and interventions in those three sectors.
18

Figure 1: Banking and Financial Services Program Activities and Interventions

Banking Sector—Activities and interventions

Organizational effectiveness of the CBK

Law on Banks

Risk-based bank supervision

Corporate governance

Emergency Liquidity Assistance (ELA)

Repo system

Liquidity arrangements

Insurance Sector—Activities and interventions

Law on Insurance

Solvency I implementation

Risk-based supervision

Corporate governance

Real Estate—Activities and interventions

Regulation of appraisal of immovable property

Regulation of housing mortgages

Regulation of and training of real estate appraisers

Development and supervision 

of the insurance and 

real estate sectors

Additional details can be found in the following report annexes:

• Annex G presents an overview of the OTA BFS program describing each intervention, 

OTA’s contribution, constraints encountered during implementation of the intervention, 

and the sustainability of the intervention. The annex also includes selected context 

indicators that demonstrate the changes from 2011–2020 in the banking, insurance, and 

real estate sectors.

• Annex H presents a chronology of each set of OTA BFS program activities and 

interventions in \banking, insurance, and real estate.

Finding: On a systemic level, OTA contributed to the organizational effectiveness of the 

CBK. 

Former and current Central Bank governors, as well as senior staff of the CBK, described the 

institutional, organizational, operational, and strategic success of the CBK supported by U.S. 

government assistance, including that from the U.S. Embassy, the U.S. Department of State, 

and USAID. These parties emphasized OTA’s lead role in supporting CBK’s development, 

described in general terms, from its nascent stage in 2012 to the present. Details of CBK’s early 

capacity for comparison are difficult to know due to the lack of baseline documentation and 

memory recall limitations. However, the evaluation found evidence, through KIIs with CBK 

staff and advisors, of OTA’s contributions to the CBK’s organizational development. The TA 

in question resulted in CBK’s high-level vision and a strategic plan that is updated annually.
19

OTA’s TA and knowledge transfer to the CBK included formal training in topics such as

banking supervision, as well as on-the-job mentoring between advisors and CBK key managers 

and staff. While formal, classroom-style training was mentioned in project documents and KIIs, 

no training documentation was available. However, former, and current CBK governors and 

senior staff emphatically stated that OTA contributed in fundamental ways to the establishment, 

operational effectiveness, and institutional sustainability of the CBK.

In 2012, the CBK requested OTA assistance to establish its strategic plan. Later, according to 

KIIs with advisors, OTA’s TA — in response to CBK requests — built CBK capacities in 

specific technical areas — law, regulation, operations, etc. OTA’s high systems-level technical 

assistance enabled the CBK to function as a central bank and implement critical specific 

measures, such as laws, operations, regulations, and supervision, that were identified and 

supported by OTA and other donors and TA providers. One interview respondent stated that 

OTA was “central to the success of the CBK.” This view was confirmed by staff of a USAID 

economic governance activity. The staff member recognized OTA’s contributions to building 

the CBK and MOF that enabled USAID’s activity.

Conclusion: OTA’s sustainable contributions to the CBK include the wide range of manuals, 

policies, principles, and procedures that are still in use today — as well as the wealth of technical

knowledge OTA advisors have transferred to CBK staff over the years — that have enabled the 

CBK to progress since the inception of OTA’s TA. Country reports published by the European 

Commission (2021) and the IMF (2021 and 2021) as well as the European Union Kosovo 

Scorecard 2021 (published by the European Policy Institute of Kosovo5) recognize the CBK as a 

well-governed and well-managed central bank.

Finding: OTA contributed to the Banking Law.

Kosovo’s Banking Law was revised in 2012, which enabled the CBK to operate as a central bank 

and supervisor of banks and insurance companies. According to project documents and KIIs 

with CBK staff, OTA’s TA related to the new Banking Law included: 

• Standardization of supervisory policies;

• Training of on-site bank examiners and off-site analysts;

• Improved bank reporting standards;

• Adoption of Basel I Core Principles; and

• Institutionalization of risk-based supervision and the capital adequacy, assets,

management capability, earnings, liquidity, and sensitivity (CAMELS) ratings system.

6

However, details on OTA’s activities and interventions related to the Banking Law were 

unavailable, as the evaluation team was unable to interview the OTA advisor who worked on this 

intervention ten years ago.

5 See Annex C – Context Document List.

6 See 2012 Annual Budget Review Template III—Country Narrative Kosovo-Banking, p. 3.
20

The sustainability of the Banking Law needs to be considered in the current context of the CBK.

The original 2012 regulations need revision to align with current Basel committee principles 

under Basel II. The CBK drafted the Law with the help of OTA advisors. However, the draft 

Banking Law is still pending government and parliamentary approval.

In addition, while OTA’s TA was instrumental to the adoption of Basel I, Gesellschaft für 

Internationale Zusammenarbeit GmbH (GIZ) has been the primary TA provider working with the 

CBK to implement Basel II/III, although the governor of the CBK mentioned also discussing

Basel II/III implementation with OTA advisors. Although OTA is no longer actively 

contributing to Basel II/III, the initial Basel Committee on Banking Supervision framework, 

revised with OTA’s TA in 2012, remains the basis of the current proposed Banking Law

revisions. 

Finding: OTA contributed to implementation of risk-based bank supervision, but risk 

assessments are inconsistent.

Project documents and advisor KIIsindicate that the CBK developed a risk-based supervision 

manual with the assistance of OTA advisors. With OTA’s TA, CBK also implemented a 

CAMELS rating system, a fundamental tool for implementing risk-based supervision. 

Documentation of the U.S. Department of State’s 2011 Annual Budget Review, a process that

outlines anticipated project activities, states that: “The banking sector dominates the financial 

sector in Kosovo and its soundness will have a significant impact on the development of the 

Kosovo economy. The banking sector is also highly concentrated so that all the banks are 

systemically important and have to be subject to close supervision. There is currently one local 

bank under liquidation and there are two other small, local banks that probably will need to be 

sold or they may also face liquidation.” It proposes: “In the long-run, OTA’s technical 

assistance would focus on institutionalizing risk-based supervision and the CAMELS ratings 

system in the regular examination of financial institutions in order to foster the development of 

sound commercial banks and other financial institutions.”7

The CAMELS rating system and the supervision manual are still in use today. Furthermore, all 

four bank survey respondents stated that risk-based supervision had a good or high positive 

impact on the financial sector in Kosovo.

However, in one OTA advisor’s assessment, corroborated by members of the KBA, the riskbased supervision is still far from being effective as very few banks have adopted formal, 

consistent, internal risk assessment practices. KII participants described certain deviations from 

best practice and/or international standards. For example, the CAMELS bank assessments do 

not seem to be consistently conducted on an annual basis. 

Conclusion: Risk-based identification of priority does not seem to be in place for on-site 

inspections. Without full implementation, risk-based supervision is not certain to be sustainable,

according to one KII respondent from the CBK. 

7 Office of the Coordinator of U.S. Assistance to Europe, Eurasia and Central Asia (EUR/ACE) 2020 Annual 

Budget Review.
21

Finding: OTA contributed to improved corporate governance of Kosovar banks. 

The July 2015 Basel Committee on Banking Supervision guidelines on corporate governance for 

banks include 13 principles that supervisory authorities should implement to comply with the 

Basel committee framework. With the assistance of OTA, a regulation on corporate governance 

was issued on December 29, 2016, to align banking practices with international standards.8

Representatives of the banking industry who were interviewed said they were not invited to 

comment on the draft regulation; instead, their feedback was requested only after the regulations 

were already adopted. All four bank survey respondents agreed that corporate governance had a 

positive impact on the financial sector in Kosovo. However, CBK staff discussed in KIIs the 

issue of a limited number of qualified board members in Kosovo, a small, newly independent,

and post-conflict country with a history of emigration. 

Finding: OTA contributed to the establishment of the emergency liquidity account in 

Kosovo. 

Emergency liquidity account (ELA) is a system that is needed in the event of a banking crisis 

involving a short- or medium-term lack of liquidity at otherwise solvent banks. A requirement of 

the Banking Law, it enables the CBK to act as lender of last resort to licensed banks at its 

discretion in case of adverse market conditions or pending bank failure.

While the ELA has never been used, all four bank survey respondents agreed that its

establishment had a positive impact on the financial sector in Kosovo as a necessary safety net

that is needed to comply with European Union banking standards. One KII respondent from the 

KBA said that, given the Kosovo banking sector’s experience of consistent excess liquidity,

although the necessity of an ELA was a surprise to them, “from the legal perspective, it is 

calming and reassuring.” Despite challenges, former ministers, the current minister, and senior 

staff from the MOF all confirmed the viability of the ELA mechanism.

Conclusion: In Kosovo’s current context of excess liquidity, the KBA has not needed to use the

ELA. The KBA perceived it as unlikely that it would need to do so in the foreseeable future. 

However, the KBA recognizes the ELA as a critical tool in an emergency, and that international 

standards require it. The CBK reports periodically testing the ELA to ensure its operational 

effectiveness.

Finding: OTA contributed to the creation of short-term, intraday, and overnight liquidity 

arrangements.

According to CBK staff, CBK created — with the assistance of OTA — arrangements to enable 

short-term transactions like a repo, but under terms that are up to ten days, longer than traditional 

repo markets’ intraday or overnight timeframes. In this way, the CBK provides short-term

liquidity to Kosovo’s banks through transactions that are collateralized by government securities 

but mature beyond intraday repo terms. This solution, while not identical to a typical repo, 

improves the liquidity capacity of Kosovo’s government securities and opens the door for the 

8

 See https://bqk-kos.org/legal-framework/regulations/banks/?lang=en
22

development of a secondary market. The Regulation on Liquidity Risk Management currently 

treats these assets as liquid for the computation of the required liquidity ratios.

While the CBK recently established a repo market platform with OTA’s assistance, DMU staff

report that the current version of the CBK’s electronic trading platform, Depo/X, does not 

include a module to comprehensively support the new facility. The trading module will need to 

have sufficient flexibility to calculate the required anticipated range of transaction variables 

including varying amounts of available collateral and cash needed by different borrowers. 

Different pricing options must be available for both Treasury bills and government bonds,

9 but 

this is not fully functional although Depo/X has been used for approximately 60 transactions.

Conclusion: Typically, repos function as an effective horizontal tool among banks for intraday 

and overnight transactions. While the CBK’s short-term arrangements are effective — for its 

current, over-liquid circumstances — the CBK does not fully participate in repo. Certain typical 

repo elements are not present, e.g., an automatic switch to intraday liquidity arrangements that 

are collateralized with securities repo in case of extension. The CBK reports that the 

arrangements have been adapted to Kosovo’s current circumstances and have work well when 

needed. According to a CBK counterpart, “the liquidity facilities functioned well during the 

COVID crisis and are useful liquidity tools today.” 

Figure 2 shows a conceptual summary of insurance interventions undertaken by the BFS 

Program Team. The inputs were developed through an iterative process in which the BFS 

Program Team provided the TA shown in the white boxes, with the counterpart agencies

providing direct feedback to the BFS program team through activity outputs, described in the 

insurance-related findings for EQ2, and described in this section.

9

 See OTA Trip Report (internal), 201906_kosovo_tr_gdif_gianaris, p4

Consultation 

with Insurance 

Companies and

Professional 
23

Figure 2: Diagram of OTA BFS Project -- Insurance Intervention 

Finding: OTA contributed to the Law on Insurance, but revisions are needed.

The Law on Insurance was developed with OTA’s technical assistance and approved in 2012. 

Prior to the law’s passage, there was no legal framework for the insurance sector, and according 

to the governor of the CBK, “all successful results that today we have in the insurance sector are 

a result of the establishment of a legal framework for insurance.” The Law on Insurance 

includes all the core and necessary elements for the sector: legal regime, compensation fund, 

border insurance, bankruptcy rules, technical reserves, etc. The Kosovo Insurance Bureau agreed

with the CBK that implementation of the Law on Insurance is fundamental to the sector. 

According to CBK counterparts, the law remains unchanged and has been sustainable in its 

original form since its inception. However, as the insurance sector has matured over time, 

revisions to update the law have been proposed, but those proposed changes have remained

under review by the Parliament for more than a year for political reasons.

Consultation 

with Insurance 

Companies and

Professional 

Associations

Office of 

Technical 

Assistance 

Legislative 

and 

Regulatory 

Drafting

and 

Training

Training 

Manuals

Capacity 

Building:

Analysis

Liquidation

Supervision

Inputs

Activities and 

Interventions

Financial 

Sector 

Strengthened

Legal/Regulatory 

Framework 

Strengthened

Solvency I 

Implemented

Risk-based 

Supervision 

Implemented

Corporate 

Governance 

Strengthened

Feedback

Tailor TA 

to local 

conditions

Request 

for TA Outcomes

Comments 

on draft 

legislation
24

Finding: OTA contributed to the implementation of Solvency I, but transition to the 

European Union’s Solvency II has not been completed.

Solvency I include mandatory European Union directives for insurance sector supervision, and 

the CBK considers OTA’s technical assistance as essential for the implementation of those 

directives. First adopted in 2016, the provisions of Solvency I have been fully implemented and 

all the insurers are compliant, according to the CBK and the OTA advisor who worked in 

insurance. The Kosovo Insurance Bureau shared this assessment.

Conclusion: The CBK considered Solvency I to be a significant first step that established a

supervisory regime. However, its sustainability cannot be determined until its provisions are

updated to align with current European Union standards and comply with Solvency II guidelines. 

The new provisions include, among others, setting higher insurer solvency capital requirements, 

assessing insurers’ “true risk” profiles, and harmonizing European Union standards that 

encourage a single European market for financial services.

10 The CBK is currently working with 

the World Bank to draft the roadmap toward an updated risk-based Solvency II framework.

Finding: OTA contributed to the implementation of risk-based insurance supervision and 

improved insurers’ corporate governance. 

To support implementation of the Solvency I provisions, OTA developed a supervision manual,

still used today by CBK insurance supervisors, that is considered a milestone achievement. In a 

counterpart survey, a high-level CBK official wrote, “The preparation of the manual by [an OTA 

advisor] provides the CBK staff with standards and best practices for conducting risk-based 

examinations. As a result, [the OTA advisor’s] assistance in these areas has enhanced the 

institutional and human capacities of the CBK. Technical assistance and training sessions are a 

very important part in establishing and further developing the role of the CBK. This is the case 

for licensing, regulation, and supervision of financial institutions, respective companies, and 

insurance intermediaries.” KIIs with key members of the Kosovo Insurance Bureau

characterized Kosovo’s insurance sector supervision as appropriately conservative from their 

industry perspective.

The efficacy of the CBK’s insurance supervision can be illustrated anecdotally. In KIIs, 

counterparts reported that the CBK has revoked the licenses of two non-life insurers, in 2019 and 

2020, and sent the companies into liquidation. KII respondents reported that, during the CBK’s 

due diligence supervision, insurers had difficulties fulfilling CBK’slegal requirements regarding

capital adequacy and solvency. To safeguard insurers’ financial stability and fulfill legal and 

regulatory requirements, the CBK attempted to help the insurers resolve their financial problems. 

Despite these efforts, the insurers’ shareholders did not respond to CBK’s requests that included 

increased solvency capital and compliance with other legal requirements. The CBK revoked the 

licenses of the two insurers to protect the policyholders and to prevent an adverse impact on the 

insurance market and financial system in general.

10 Background Source: European Insurance and Occupation Pensions Authority: 

https://www.eiopa.europa.eu/rulebook-categories/directive-1382009ec-solvency-ii-directive_en
25

In addition to its contributions to risk-based supervision by the CBK, OTA also contributed to 

CBK’s implementation of the July 2015 Basel Committee on Banking Supervision principles. 

These principles were expanded to insurance companies and to non-banking financial institutions

to comply with international standards.

Conclusions: The details of these events were unclear in the retelling in KIIs. The evaluation 

team was unable to determine when CBK became aware of the insurers’ pending insolvencies 

and at what point the CBK responded. Therefore, the evaluation team was unable to assess

whether the CBK’s insurance supervision has improved over time based on these anecdotal 

incidents.

However, the industry representatives did agree that the insurance industry in Kosovo is now 

well supervised and compliant with Solvency I provisions. OTA made significant contributions 

to foundational elements, including Solvency I, the supervisor training manual, and the CBK’s 

cadre of insurance supervisors. Nevertheless, the sustainability of risk-based insurance 

supervision cannot be determined while the updated, risk-based provisions of Solvency II are 

still to be adopted.

Finding: OTA contributed to the development of the Regulation on Appraisal of 

Immovable Properties.11

The regulation was drafted with OTA’s TA and adopted in 2015, enabling banks to appraise and 

value real estate for the first time. A CBK counterpart survey conducted by OTA and shared 

with the evaluation team included a comment that characterized OTA’s TA as having addressed

“the mortgage issues here, identified many legal gaps and raised a number of issues which are 

being addressed by the CBK and also by the other relevant institutions.”

The regulations were later updated under another OTA advisor’s guidance in 2018. However, 

the current regulation is not sustainable, as the CBK reported at the time of the evaluation as 

never having had adopted the updated revisions. OTA’s intervention was ended before a real 

estate index was completed for reasons that were not clear due to memory recall with advisor and 

KIIs with CBK staff. The index is currently being developed by another donor-funded project.

Finding: OTA drafted legislation that enabled the development of mortgage regulations, 

but the real estate sector remains severely constrained by unresolved limitations. 

Before this OTA intervention, no legal framework existed for housing mortgages or commercial 

real estate mortgages. The CBK’s requests for TA prioritized 1) improving the real estate legal 

environment, 2) reducing banks’ real estate exposure to residential housing risks, and 3) 

11 Implementation of Bank Valuation Regulation is one of three indicators listed in OTA’s Office of the Coordinator 

of the U.S. Assistance to Europe, Eurasia and Central Asia (EUR/ACE) FY 2020 Annual Budget Review Project 

Narrative: Implementation of Real Estate Index; Increased Accuracy in the Valuation of Certain Properties; and 

Implementation of Bank Valuation Regulation. 

No indicators were mentioned in the EUR/ACE FY 2020 Annual Budget Review Project Narrative for 2014, 2013, 

2012.
26

consumer protection for property owners to enable post-war reconstruction, including

development in the new capital city of Pristina. 

According to OTA’s advisor, the CBK, working with OTA, faced four major constraints related 

to property rights: 1) Kosovo’s governance transition from the former Yugoslav concept of 

social ownership to the concept of private residential property ownership, 2) the destruction of 

ownership documents by Serbs during the war, 3) property owners’ difficulties in compliance 

such as seeking building licenses without clear titles, and the sale of unlicensed properties, 

exacerbating the compliance problems over time, and 4) the lack of a property register. These 

constraints remain unresolved and have resulted in delayed and partial implementation of the 

mortgage regulations over time. The situation has also been further exacerbated by the political 

attrition of multiple governors and CBK board members.

Despite these underlying constraints, some aspects of the mortgage regulations have spurred real 

estate lending and provided guidelines for collateralization, resulting in an increased volume of 

real estate loans, according to the CBK. Nevertheless, the impact of the mortgage regulations has 

been muted by the underlying constraints.

Conclusion: All four bank survey respondents agreed that the regulations on housing mortgages 

have had a limited positive impact on the financial sector in Kosovo. They agree that OTA’s 

work to draft mortgage regulations cannot be considered sustainable without the resolution of the

sector’s systemic constraints that limit the purchase and sale of real estate.

Finding: OTA contributed to the regulations on real estate appraisers and training of real 

estate appraisers, but their utility is limited in the sector’s current circumstances.

12

OTA developed the legal and institutional framework for real estate appraisers that enabled them

to provide objective assessments of the fair value of the real estate assets. OTA coordinated with 

the banking industry and drafted the regulations and put the framework in place, including a 

governance board, licencing process, and policies. As described in several stakeholders’ 

interviews, the banking industry participated actively in the design and implementation

processes, and the OTA advisor also conducted training for real estate appraisers, resulting in the 

licensing of 253 appraisers as of May 2022.

The regulation on real estate appraisal and training of real estate appraisers contributed to the 

development of the real estate industry in Kosovo, as some properties are being appraised and 

sold. However, the real estate sector challenges described above constrain full development of 

Kosovo’s real estate sector. KIIs with CBK counterparts and advisors revealed that the real 

estate appraisal activity was ended early before completion of its objectives, likely because of 

the underlying sector constraints. Respondents were not able to provide details of how and 

when the decision was made.

12 Increased Accuracy in the Valuation of Certain Properties is one of three indicators listed in the Office of the 

Coordinator of U.S. Assistance to Europe, Eurasia and Central Asia (EUR/ACE) FY 2020 Annual Budget Review 

Project Narrative: Implementation of Real Estate Index; Increased Accuracy in the Valuation of Certain Properties; 

and Implementation of Bank Valuation Regulation. 
27

Kosovo’s market circumstances also limit the impact of the regulations that were drafted with 

OTA’s TA. According to the CBK, the regulations define three risk-weight levels for mortgage 

exposures: 35% (Basel II minimum level), 50%, and 75% (Basel II level for ordinary retail 

exposures). The risk weight assessment determines the cost (interest rate) of the housing 

mortgage. According to a Kosovar bank official, current market realities make it impossible to 

apply the 35% rate because exposures are set at a default risk weight assessment of 75%. This 

risk is passed along to borrowers with high costs and the regulation does not achieve its primary 

objectives of reducing mortgage rates for residential households.

Conclusion: While the activity resulted in a regulatory framework and a cadre of appraisers, its 

relevance is limited until the underlying legal and market constraints are resolved. Some banks 

are not currently interested in real estate lending, and those that are require mortgage collateral 

which cannot be met without undisputed, clear ownership documentation. One industry 

representative explained that while some banks are making unsecured loans, they are not 

common and relationship-based and/or secured through alternative means unavailable to most 

potential borrowers.

Finding: There was limited coordination between OTA BFS advisors and individual 

project activities.

Project documents provide some evidence of written email communications and shared tripreport documents. However, the evaluation team did not find or hear evidence of substantive 

knowledge transfer, exchange of ideas, or feedback among advisors and OTA’s headquartersbased program staff; it is possible that this occurred through emails that are not available to the 

evaluation team. KIIs with advisors confirmed that any communications and coordination 

between advisors was inconsistent and not documented.

Overall Conclusions—Banking and Financial Services

To address the first evaluation question, the evaluation identified findings that describe the ways 

that OTA contributed to Kosovo’s financial sector-strengthening. Counterpart surveys and KIIs 

with advisors, CBK stakeholders, the U.S. Embassy, USAID, and the IMF all confirmed OTA’s 

contributions to Kosovo’s financial sector-strengthening in three categories: 

1. legal and regulatory development;

2. institutional and operational capacity-building; and 

3. training and knowledge transfer. 

The evaluation team used these three categories as a framework to understand the scope of 

OTA’s BFS program activities and interventions to financial sector-strengthening. They 

emerged through a review of the project documents and KIIs. 

OTA’s demand-driven approach to TA has many strengths including:

• Responsiveness to the CBK’s and MOF’s priorities, fostering ownership over activities 

and outcomes; and

• Flexibility to adapt activities or correct interventions based on emergent information or 

changing circumstances.
28

This approach has been implemented in Kosovo by a cadre of individual advisors who, while 

providing extraordinary expertise, worked largely independently with limited and coordination 

between them, such as between advisors who focused on related activities or over transitions.

The BFS program benefited from the long-term commitment of just a small number of advisors 

over a period of nearly 10 years. As a result, a great amount of OTA/Kosovo’s institutional 

knowledge was lost when individual advisors completed their scopes of work, when advisors 

were replaced, or activities were ended. One OTA advisor noted that information-sharing among 

individual OTA advisors could be improved, and that individual advisors would benefit from 

sharing institutional knowledge and technical exchange. This is particularly true when there is a 

time gap or hiatus in activities due to counterpart attrition or political transitions. In addition, 

any organizational, technical, political, or relationship-related challenges in working with 

counterparts can be documented and shared with other advisors and may provide insights for 

OTA staff on advisor/counterpart relationships.

XI. EQ2 Findings and Conclusions—Government Debt and 

Infrastructure Finance

EQ2: In which ways did OTA’s TA contribute to improved public debt management in 

Kosovo?

This section describes the evaluation findings to EQ2 and the ways that OTA’s GDIF advisors’

activities and interventions contributed to four key findings. OTA’s primary GDIF activities and 

interventions are listed in Figure 3.

Figure 3: Government Debt and Infrastructure Finance Program Activities and 

Interventions

Establishment of the legal/regulatory 

and institutional/operational framework for 

public debt management in Kosovo

Establishment of a 

domestic debt market in Kosovo

Lengthening of 

debt maturities over time

Coordination of the MOF with 

the CBK and market participants
29

Figure 4 is a visual conceptualization of OTA’s approach to improved public debt management 

and debt-market functioning, shown on the far right as the GDIF’s high-level outcome. Findings 

for EQ2 are depicted as OTA’s activities and interventions, or outputs. The inputs represent the 

GDIF program’s TA contributions listed in the white text boxes, informed by counterparts’ 

feedback.

Figure 4: OTA GDIF Project – Debt Management

Further details of GDIF program activities and interventions to supplement this section can be 

found in the following Annexes:

• Annex I is an overview of the OTA GDIF program, listing each intervention, relevant 

indicator(s), OTA’s contribution, constraints encountered during implementation of the 

intervention, and the sustainability of the intervention. 

Office of 

Technical 

Assistance 

Inputs

Activities and 

Interventions

Improved 

debt 

management 

and debt 

market 

functioning

Law on Public Debt

and

Secondary 

Legislation

Establishment of 

Debt Management 

Unit (DMU)

Calendar and

Debt Strategy

Liquidity 

Committee

ELA Repo

Trading System

Solicit Comments

Consultation 

Mechanisms and 

“Market 

Assessment”

Formal Training

Ongoing 

On-the-job 

and Formal

Training

Coordination 

Meetings

Feedback Comment 

on draft 

legislation

Tailor TA to 

local 

conditions Outcomes

Request 

for TA
30

• Annex J presents a chronology of OTA GDIF program interventions.

Finding: On a systemic level, OTA contributed to the establishment of the legal/regulatory 

and institutional/operational framework for public debt management in Kosovo.13

The Law on Public Debt was drafted with OTA’s TA and adopted by the Assembly in late 2009. 

Following adoption of the Law, OTA worked with the MOF on implementation, developing

administrative procedures and regulations for the issuance and management of all public debt 

within the Ministry of Economy and Finance. In addition to working with the MOF, advisors 

also engaged with other key stakeholders; four bank survey respondents stated that the MOF 

and/or the CBK included them, soliciting feedback and review of proposed financial sector 

regulations between 2012 and 2018. OTA’s significant contribution to the establishment of the 

legal framework was characterized in a counterpart KII, saying that it was “in large part the 

result of OTA’s support.”

KIIs with former Ministers, the current Minister, and MOF senior staff cited the technical 

expertise of OTA’s advisors and credited them for the speed with which the legal/regulatory and 

institutional/operational frameworks were established. One counterpart respondent explained 

that the role of OTA was crucial in “designing the framework as well as the timely execution of 

the debt market.”

Following approval of the Law on Public Debt and secondary legislation, a new DMU was 

created in 2010 within the MOF. OTA helped the MOF define new roles and select staff from a 

pool of candidates who had no previous direct experience in the securities market.

From 2010–2020, OTA developed DMU capacity for issuing, managing, and reporting all public 

debt through counterpart mentoring and formal training that addressed government securities 

market regulations and secondary market operations, among other topics. Initially, the OTA 

advisor was directly involved in the daily activities of the DMU, a relationship that, according to 

counterpart KIIs, shifted over time to a consultative role that provided advice and high-level 

guidance upon request. One counterpart KII respondent shared details of OTA’s TA with 

examples that covered cash and debt management, operations and systems management, 

accounting and reporting, IT, and payroll management. Another noted that OTA’s TA enabled

the DMU to conduct material assessments and assess market needs in just six to 12 months.

Since its inception, the DMU has taken the lead role in the establishment and maturation of 

Kosovo’s debt market. Over time, as the DMU’s technical capacity has developed, counterparts 

have better been able to present more specific needs and requests to OTA, and OTA advisors 

have responded with more narrowly focused TA.

Conclusion: Interviews with USAID Mission staff knowledgeable about OTA’s work through 

their portfolio of economic growth activities verified OTA’s significant contributions in building 

the capacity of the MOF and the CBK. Evidence that supports the sustainability of OTA’s 

contributions to the regulatory framework. For example, the Law on Public Debt and related 

13 For the GDIF project, the legal/regulatory and institutional/operational interventions are described together as a 

“systemic-level” intervention, as the Law and DMU were both created from scratch.
31

secondary legislation enacted in 2010 remains current. The DMU, established with OTA’s 

guidance, also remains fully functional and continues to successfully manage all public debtrelated activities. 

KIIs with staff members of the DMU revealed that the unit has experienced high personnel 

attrition in recent years due to a growing market demand for their skills. USAID has responded 

to this issue through the mission’s “Brain Fund” activity, implemented by Bearing Point, to 

attract and retain highly skilled professionals within the civil service in Kosovo. See Annex N for 

more details. 

Finding: OTA contributed to the establishment of a domestic debt market in Kosovo.

KII respondents with MOF counterparts credited OTA with providing the technical foundation 

from scratch for the establishment of Kosovo’s well-functioning primary debt market in a very 

short time. This assessment was verified by former ministers, the current minister, and senior 

DMU staff within the MOF.

OTA contributed design specifications for the hardware and software for Kosovo’s first 

government securities electronic trading platform, as verified by trip report documentsfrom

2010. As a result of OTA assistance, an efficient e-trading platform is in place today, providing 

timely calculations and auction money transfers. MOF counterparts and market participants 

reported in KIIs that the system functions well and that they were not aware of any significant 

technical problems with the e-platform. According to the DMU, market auctions have an average 

bid-to-cover ratio of 1.75 (average 2012–2020), which indicates a satisfactory level of market 

participation. See Annex K for more details. OTA helped develop the MOF’s capacity to

annually update a medium-term debt management strategy that covers current and projected 

public debt. The MOF also published a debt securities announcement calendar.

After the market was established, OTA continued to contribute to its development through 

engagement with the MOF and market participants, according to market participant KIIs. One 

avenue was initiating regular meetings that provided an opportunity for open discussion of

market conditions and assessing stakeholders’ interest in participating. MOF counterparts 

reported OTA’s technical leadership as the critical factor in building an efficient public debt 

market. All four bank survey respondents confirmed their participation in quarterly meetings

with the MOF, OTA advisors, and primary dealers of government securities. The respondents 

also participated in OTA trainings from 2012 to 2018.

One market participant noted that the primary market is “working fine” but that the secondary 

market “needs to be developed.” The comment reflects a common theme around a desire for

further secondary market development heard in KIIs with market participants, while (often 

simultaneously) acknowledging that this would be premature. A counterpart noted that OTA 

contributed to the success of the one and only non-governmental private placement to date.

Finding: OTA contributed to the lengthening of debt maturities over time.14

14 Average length of government debt maturity and existence of longer-term securities were the indicators used by

the OTA GDIF program. 
32

The current Minister and MOF staff all credited OTA for the rapid debt maturity lengthening 

over just a few years, and emphasized that without OTA’s advisors, the process would have 

likely taken much longer.

According to the advisor, in January 2012, the Republic of Kosovo issued its first government 

security. OTA’s TA contributed to the MOF’s securities issuance strategy that has lengthened 

average debt maturities from the first three-month T-bill issued in 2012, to one-year securities 

the following year, and eventually to the issuance of 10-year securities in 2018. According to 

data provided to the evaluation team by the MOF, average maturity, a key market sustainability 

indicator, increased from 1.53 months in 2012 to 35.11 months in 2020. The MOF also added 

diaspora bonds in 2021 that enable Kosovars abroad to invest funds to enable the economic 

development of the country. Annex J provides more details of the year-by-year progression of 

debt-market instruments.

While the lengthened debt maturities provide evidence that the primary market has been 

sustainable, the pace of debt-market development has slowed since 2015, according to DMU 

staff discussions in KII. Following the 10-year maturity security (2018) and the diaspora bonds 

(2021), new debt instruments have not yet been issued due to challenges related to the COVID19 pandemic.

Finding: OTA contributed to coordination of the MOF with the CBK and market 

participants.

According to counterparts in KIIs, the OTA played a crucial role in fostering dialogue among the 

MOF, the CBK, market participants, and primary dealers that enabled the DMU to assess market 

conditions and make informed decisions.

OTA supported the establishment of the Liquidity Committee between the MOF and the CBK to 

oversee the management of cash balances and investments. Because it was established through 

2020, the Liquidity Committee was sustainable and held regular quarterly meetings. Meetings 

have been less frequent since the beginning of the COVID-19 pandemic, while the MOF and the 

CBK recently have returned to pre-COVID norms.

The ELA facility15 and repo systems (both discussed in Section X) are possible because of the 

coordination–with OTA’s technical guidance–between the CBK and the MOF that was described 

by counterparts from both the MOF and CBK as a “marriage—for better or worse.” 

Overall Conclusions—Government Debt and Infrastructure Finance

To address EQ2, the evaluation team identified findings that describe OTA’s significant16

contributions to improved public debt management through:

a) Legal and regulatory development;

b) Institutional and operational capacity-building; and

15 Existence of a Liquid Adjustment Facility was one of three indicators for the OTA GDIF program.

16 The evaluation report uses the term “significant,” whereas OTA’s counterpart survey distinguishes among major 

contributions, some contributions, and no contributions made by OTA.
33

c) training and knowledge transfer.

These three categories of TA emerged through a review of the project documents and KIIs. The 

categories can be used as a framework to understand the scope of GDIF program activities, made 

more apparent through KIIs with the MOF and other key stakeholders. In addition to these 

sources, interviews with U.S. Embassy, USAID, and IMF staff who had direct knowledge of 

OTA’s activities provided additional perspectives and further verified the findings presented in 

this section. 

XII. EQ 3 Findings and Conclusions—Sustainability

EQ3: Which identified outcomes of OTA’s TA in Kosovo have been sustained over time?

Sustainability—Banking and Financial Services Program

To address EQ3, the evaluation team assessed each of the BFS program areas that OTA 

contributed to, as described in section X above, and considered the evidence of sustainability 

within the current context. The sustainability of OTA’s BFS activities and interventions is 

summarized in the following findings:

Finding: The following OTA BFS program’s contributions to financial sectorstrengthening in Kosovo are sustainable.

OTA’s contributions to the ELA, the repo system, and liquidity arrangements are all sustainable. 

As discussed in Section X, however, the ELA has never been used, the repo system is not yet 

fully matured, and the CBK does not fully participate as a horizontal market player.

Conclusions: Four insurance interventions were sustainable: the Law on Insurance, Solvency I 

implementation, risk-based supervision, and corporate governance. At the same time, necessary

revisions to the Law on Insurance to comply with Solvency II requirements have not been 

completed. In addition, two insurance companies have been dissolved since the inception of 

risk-based insurance, making sustainability unclear.

While OTA’s contributions to regulations on real estate appraisal and training of real estate 

appraisers are sustainable as evidenced by the CBK’s small cadre of appraisers (see Section X), 

these outputs have only limited impact. The impact is constrained by market features, 

particularly property ownership rights. It is not possible to determine the sustainability of OTA’s 

contributions to the real estate sector.

Finding: The following BFS Banking Law and real estate activities and interventions have 

not been sustainable:

The Banking Law as originally drafted by OTA, remains in place. Revisions needed to comply 

with changes in the Basel committee international banking principles under Basel II have been 

stalled under parliamentary review for three years. Another challenge is that risk-based bank 

supervision has not been fully implemented. The Banking Law and Basel I represent milestone 

achievements supported by OTA that are still in place. However, they need to be updated and/or 
34

fully implemented to be sustainable for the CBK to comply with European Union Basel II 

requirements.

The real estate sector’s current Regulation on Appraisal of Immovable Properties was drafted 

with OTA’s TA and adopted in 2015. However, updated amendments of this regulation, which 

OTA drafted during 2017 and 2018, have not been adopted while the property rights issue, 

outside the CBK’s direct influence, remains unresolved. Development of the real estate industry 

is still stalled due to such systemic barriers. 

Conclusion: The relevance and utility of appraisers is constrained in the current market 

environment as described in Section X. OTA’s real estate activities ended early and the 

evaluation team was unable to verify the underlying reason from KIIs with the CBK and OTA’s 

advisor.

Finding: The Banking and Financial Services program contributed to the CBK’s 

sustainability.

On a systemic level, former and current governors as well as senior staff of the CBK credit OTA 

for the ongoing organizational success of the CBK. Both counterparts and OTA advisors 

confirmed that a wide range of manuals, policies, principles, and procedures developed with the 

assistance of OTA advisors are still in use today. Also, OTA achieved a major transfer of 

knowledge to the CBK through its activities and interventions, as discussed in Section X, that 

enables the CBK to function well today and progress. 

This conclusion is confirmed by country reports published by the European Commission (2021) 

and the IMF (2021 and 2021), as well as the EU Kosovo Scorecard 2021 (published by the 

European Policy Institute of Kosovo17) that recognize the CBK as a well-governed and managed 

central bank.

Conclusions: In addition to the sustainability of BFS activities and interventions, EQ3 also 

addresses sustainability that needs to be considered in a larger context at the program level. As 

described in Section X, the BFS program activities and interventions were demand -driven, i.e., 

based on the CBK’s requests for TA. For that reason, the findings represent a menu of discrete 

activities, rather than components of a comprehensive, coordinated strategy. While there is 

ample evidence that OTA’s BFS program elements contributed to the overall sustainability of the 

CBK, OTA did not work from big-picture, multi-year plans. Rather, according to counterpart 

and advisor KIIs, requests for TA addressed the CBK’s needs following its own internal strategic 

planning. Therefore, it is relevant to note that, although most of OTA’s BFS outcomes were 

sustainable by one of the above definitions, OTA’s approach to TA was not designed with the 

CBK’s overall, big-picture sustainability as a deliberate, stated objective.

Sustainability—Government Debt and Infrastructure Finance Program

Finding: OTA’s GDIF activities and interventions are sustainable.

17 See Annex C – Context Document List.
35

These activities are summarized in the following findings:

• The Law on Debt, drafted with OTA’s TA in 2009, is still current.

• OTA contributed to the establishment of the MOF’s DMU, which is fully functional and , 

according to KIIs with advisors, counterparts, and market stakeholders, is effective in 

managing the market.

• The primary debt market, a result of OTA’s TA with the DMU, is active and sustainable. 

Evidence includes the increasing length of debt maturities over time.

• Coordinated activities and decisions among the MOF, the CBK, and market participants 

are ongoing, although meetings have been less frequent in recent years.

Finding: OTA’s Government Debt and Infrastructure Finance program contributed to the 

sustainability of the MOF’s debt management capacity and the primary debt market.

At the program level, OTA contributed to the sustainability of the legal, institutional, and 

operational framework for public debt management through its TA to the MOF and DMU. As a 

result, the issuance of public debt is a resource for financing the MOF’s budget deficits as 

needed. According to KIIs with high-level MOF officials, Kosovo’s level of debt is sustainable

and governed under established rules suggested by OTA. As a result, the primary debt market is 

fully functional and has had a positive impact on the overall sustainability of public finances.

All internal procedures and timelines, established with OTA’s guidance, are implemented today, 

including the DMU’s debt strategy and a debt schedule (calendar).

Certain risks remain. Challenges include the need to expand the investor base to include more 

individuals, insurance companies, or private companies. Diversification would improve the debt 

market’s stability through decreased reliance on the CBK’s holdings.

A common theme heard throughout KIIs is that the secondary market has not developed as 

quickly and there is still room for progress. However, constraints to further development remain,

including current market realities and the interest of market participants. In describing the 

market development, one counterpart and one market participant — in separate interviews —

used the analogy of learning to walk before you run. In their assessment, the market has 

developed and progressed “step by step.” Now, it is slowly becoming time for the market to 

develop further.

Conclusions: In contrast to the BFS program’s wide range of more loosely connected activities 

and interventions, the GDIF program was more narrowly focused. It provided TA to the MOF to 

establish and develop a government debt market and build the MOF’s capacity to manage public 

debt. However, like the BFS program’s TA approach, the GDIF program activities and 

interventions were also largely demand-driven and consultative, based on requests for TA by the 

MOF. As a result, the GDIF program’s TA approach was responsive to the MOF and its 

strategic plan rather than following a high-level, long-term development strategy. The 

evaluation team identified four GDIF activities and interventions discussed in Section XI (see 

also Annex K), including remarks about their sustainability. All four of the OTA GDIF 

program’s contributions to improved public debt management and debt market functioning in 

Kosovo contributed to sustainable outcomes. In general, these outcomes can be characterized as 

follows:
36

• Milestone achievements, or outcomes that are sustainable, such as the establishment of 

Kosovo’s primary debt market and the DMU unit of the MOF; and

• Aspects of debt market development that, while sustainable, are stalled or, arguably 

(based on a range of KII opinions), have not reached their full mature potential, such as 

the establishment of a secondary debt market.

Overall Conclusion—Government Debt and Infrastructure Finance

Many of the findings for EQ1 and EQ2 include remarks related to sustainability of OTA’s 

individual activities and interventions, or outputs. The evaluation team defined four categories of 

sustainability that emerged, as discussed in Section X, characterized as follows:

1. Outputs that continue in the present, such as regulations that remain relevant and 

unchanged;

2. Tangible products, such as training manuals developed by OTA, that remain in use, 

largely unchanged;

3. Milestone achievements, where OTA made significant contributions that have been 

superseded over time such as revised regulations or updated standards and practices; and

4. Outputs that have only limited impact due to Kosovo’s political and/or market 

constraints.

XIII. Recommendations

Recommendation: Systematize and document communications, knowledge exchange, and 

coordination between and among advisors and OTA program staff.

The evaluation team recommends that OTA consider adopting additional protocols to 

systematize communications among advisors (including those working under different program 

areas) and OTA program staff. While added demands added to advisors’ burdens need to be 

considered in OTA’s organizational culture and context, new protocols could include, for 

example, transition reports using a standard template, facilitating “shadowing” exchanges 

between advisors, and periodic virtual brainstorming workshops with current and past advisors in 

small or large groups. These examples may not be an appropriate fit for OTA’s unique needs,

but the evaluation team nevertheless recommends addressing the underlying issue that became 

apparent during the evaluation.

Recommendation: Improve program-level documentation including periodic, annual, and 

final reports to capture lessons learned and institutional knowledge. 

The evaluation team recommends that OTA require periodic (e.g., quarterly), annual, and final 

reporting frameworks to strengthen:

• Internal coherence and knowledge-sharing (within teams and between/among more than 

one team);

• donor coordination; and

• accountability (within OTA and to the U.S. government).

An annual report would contain in one document the details (narrative and monitoring data, such 

as indicators) of how the project made progress toward results. Similarly, a final report would 
37

contain aggregate information about the project, as distinguished from trip reports that contain 

data or information about the work of individual advisors. More importantly, annual reports and 

final, program close-out reports serve a wide range of purposes for Treasury/OTA, the U.S.

Embassy and USAID mission, CBK and MOF counterparts, and other donors and TA providers 

supporting the Government of Kosovo. 

Recommendation: OTA should implement best practices in monitoring, evaluation, and 

learning to improve results while not sacrificing the flexibility of its demand-driven TA 

model.

This first evaluation provides an opportunity for OTA to share data and lessons learned internally 

and with partners—including other U.S. government agencies, counterparts, stakeholders, and 

other donors.

As appropriate, OTA should share evaluation results with other U.S. government agencies, 

counterparts, stakeholders, and/or other donors, to improve communication and dialogue as well 

as engender a culture of evidence-based learning.

Monitoring activities track progress toward intermediate objectives and anticipated/expected 

outcomes. As recommended below, OTA should implement monitoring activities to:

• Identify and document assumptions, constraints and/or risks when designing an 

intervention;

• Share knowledge among advisors and among teams;

• Track progress toward program objectives and measure performance l;

• Enhance cooperation with stakeholders (counterparts, end beneficiaries, and other 

donors); and 

• Strengthen accountability (internally and to other U.S. government agencies).

On an ongoing basis, OTA should incorporate the collection and analysis of monitoring data and 

evidence. Standardized monitoring data collected by OTA throughout the life of the project

describe:

• Discrete programmatic decision-making—identifying, designing, and prioritizing a 

specific intervention in response to a counterpart request;

• Assessment of each intervention during implementation and upon completion;

• Activity design and strategy for a given project/country over a specific period; and

• Documentation of training events including agendas, source materials, participant lists, 

and post-training surveys.

Recommendation: Incorporate counterpart feedback in programmatic decision-making.

The only evidence of documented counterpart feedback that the evaluation found was the 

discovery of OTA counterpart satisfaction surveys. Several of these surveys were provided to 

the evaluation team when requested, though not included with OTA’s package of project 

documents. According to the counterparts, other satisfaction surveys were done but could not be 

located. While the evaluation team does not infer that they were intentionally withheld, the 

evaluation team found no evidence in the project documents or KIIs that they were ever used to 

inform planning or adjustments. Counterpart surveys should be consistently used, anonymized 
38

to protect individual respondents, and archived with the same careful stewardship as other 

project documents. 

The CBK and the MOF of Kosovo were eager to participate in the evaluation. They provided 

ample gratitude and praise, as well as specific constructive criticism, feedback, and suggestions 

on how OTA could improve its TA. Sharing this evaluation would demonstrate how OTA 

values dialogue with and input from counterparts.

For example, in response to counterpart survey questions, a staff member of the CBK wrote:

What weaknesses do you see in U.S. Treasury’s approach to technical assistance?

Response: “The inability to follow-up on the implementation phase is usually quite 

problematic, however in this case we are thankful for the chance to address some of the 

implementation issues and the ability to have the support for the amendments.”

What changes do you recommend to strengthen U.S. Treasury technical assistance?

Response: “The focusing on the follow-up and set aside some project dates for the 

implementation phase and reflection on the issues raised during implementation is very 

important in tackling those issues that usually is difficult to foresee before you begin the 

implementation process.”

18

Two other counterparts mentioned the lack of iterative feedback and strategic planning as the key

weakness of OTA’s operational model for delivering TA. These examples illustrate the potential 

value of counterpart feedback to enhance OTA’s effectiveness. In the absence of other means to 

pull counterpart feedback, systematic collection and distribution of survey results could provide 

OTA with a rare opportunity to receive invaluable feedback from counterparts.

XIV. Suggested Follow-Up and Next Steps

The evaluation team submitted a timetable to OTA for review and approval of this final report. 

Following approval of the final report, the evaluation team will deliver a final presentation of the 

evaluation to OTA. OTA might consider inviting counterparts and stakeholders to that 

presentation or a separate presentation of evaluation results.

18 Counterpart survey completed by Department for Payments System, CBK, November 7, 2018.
39

XV. Annexes
40

Annex A: Evaluation Data Source Matrix

Evaluation 

Question

Research Questions (indicative) Sources of Evidence Research Method

1. In which 

ways did 

OTA’s TA 

contribute to 

financial 

sectorstrengthening

in Kosovo?

How did OTA adapt its 

TA/recommendations to local realities 

in Kosovo?

What is the level/quality of Kosovar 

banks’ implementation of the main 

Basel Committee Principles?

How did OTA prioritize 

activities/interventions?

How did certain activities/interventions 

(emergency liquidity assistance, 

insurance supervision and liquidation of 

financial institutions) contribute to 

financial sector-strengthening in 

Kosovo?

How did training provided by OTA 

contribute to financial sectorstrengthening in Kosovo?

OTA documents

Financial sector 

assessments (IMF, 

etc.)

CBK

MOF

Kosovar financial 

sector institutions 

(associations, banks, 

insurance 

companies, pension 

funds)

U.S. Embassy in 

Kosovo

USAID, Kosovo

IMF, Kosovo

Document 

review

Results 

mapping

KII

Survey

2. In which 

ways did 

OTA’s TA 

contribute to 

improved 

public debt 

management 

in Kosovo?

How did the establishment of the DMU

within the Ministry of Finance 

contribute to improved debt 

management in Kosovo?

OTA TA helped create the primary and 

secondary market of government 

securities. How did this affect the 

overall sustainability of finances, 

namely financing of fiscal deficit?

How successful were project 

interventions in expanding financing 

sources to other non-bank institutions? 

How efficient was the electronic 

platform for the sale and trading of 

government securities? Were any 

irregularities reported by banks and 

other market players? 

How did training provided by OTA 

contribute to improved public debt 

management in Kosovo?

OTA documents

Financial sector 

assessments (IMF, 

etc.)

CBK

MOF

Kosovar financial 

sector institutions 

(associations, banks, 

insurance 

companies, pension 

funds)

U.S. Embassy in 

Kosovo

USAID, Kosovo

IMF, Kosovo

Document 

review

Results 

mapping

KII

Survey
41

3. Which 

outcomes of 

OTA’s TA in 

Kosovo were 

sustainable 

over time?

How did OTA coordinate with other 

donors (to ensure sustainability of 

outcomes)?

The CBK

reports that between 2013 and today, 

(the approximate duration of the OTA 

project) financial stability has improved 

significantly, despite the COVID-19 

crisis. Is it possible to measure the 

impact of the various components of 

OTA project on this improvement in 

financial stability?

Does the CBK regularly monitor 

financial institutions implementation of 

the laws/regulations drafted with OTA 

TA?

OTA and other donors worked on nonsystemic issues (insurance sector), 

systemic but low risk issues (ELA 

versus excess liquidity) and systemic 

with higher risk issues (Basel II/III, 

Solvency). On which of these aspects 

of financial stability is the impact of 

OTA's TA most evident?

How did the establishment of the DMU

within the Ministry of Finance 

contribute to sustainability of public 

finance in Kosovo?

What is the current status of the debt 

regulatory framework (Debt Law and 

related second regulation, Law on 

Public Financial Management and 

Accountability) that were supported by 

the OTA TA? 

Did staff turnover at the CBK impact 

the sustainability of OTA TA 

outcomes? OR How did OTA respond 

to staff turnover at the CBK?

OTA documents

Financial sector 

assessments (IMF, 

etc.)

CBK

MOF

Kosovar financial 

sector institutions 

(associations, banks, 

insurance 

companies, pension 

funds)

U.S. Embassy in 

Kosovo

USAID, Kosovo

IMF, Kosovo

Document 

review

Results 

mapping

KII

Survey
42

Annex B: OTA Project Document List

Annotated List of Project Documents

OTA provided the evaluation team with a few general documents about OTA (a brochure and 

organizational chart) and a variety of documents about each of the two programs: BFS and 

GDIF. Below is a list of the project documentation received, organized by category:

Kosovo BFS Program Documents

• EUR/ACE Annual Budget Review project narrative (five)

o Financial Years: 2011–2014, and 2020

• Assistance to Europe, Eurasia, and Central Asia Indicator Reference Sheets (three)

o Existence of an emergency liquidity assistance facility for banking system

o Established processes and procedures to for banks to access CBK’s emergency 

liquidity facility

o Issued bank appraisal and valuation regulation

• Briefing materials (eight)

• End-of-tour report by insurance advisor Russell Lamb, 2016 (one)

• Field trip reports of OTA advisors (114)

o Lewis Allen (10), Terry O. Blagg (7), Russell Lamb (47), Vilma Rosa Leon-York 

(1), Jimmy P. Mohler (4), Peter Nicholl (35), Deborah Senn (2) and William C. 

Thomas (8)

o Female—2; Male—6 

• Terms of Reference for work with CBK 2012

• Project workplan 2021 (1)

• OTA counterpart surveys

o Banking and Financial Services, Peter Nicholl (2010 to 2011). August 2011.

o Banking and Financial Services (Insurance), Russell Lamb (February 2012 to 

January 2015). July 2014.

o Banking and Financial Services, Russell Lamb (February 2012 to January 2015). 

September 2015

o Banking and Financial Services, Peter Nicholl (2015 to 2016). September 2015.

o Banking and Financial Services, Lewis J. Allen (December 2–16, 2017, and June 

16–30, 2018). November 7, 2018

Kosovo GDIF Program Documents

• EUR/ACE Annual Budget Review project narrative (12)

o 2010–2020

• Briefing materials (eight)

• End-of-tour reports of OTA advisors Anne L. Schwartz (2013) and William Donovan 

(2014) (two)

• Field reports of OTA advisors (121)

o William Donovan (14), Gene Evenskaas (1), George Gianaris (48), Barry Gray 

(1), Ellyn I. Greenwald (11), Bob Jelnick (1), Anne L. Schwartz (44), and 

Stephen M. Vajs (1)
43

o Female—2; Male—6 

• Terms of reference for 2008, 2012, and 2013 

• Project workplan for 2007, 2010, 2012, 2015, and 2018

• OTA counterpart surveys

o GDIF, William Donovan (March 2012 to November 2014), October 2014
44

Annex C: Context Document List 

EU Kosovo Scorecard 2021. European Policy Institute of Kosovo. November 2021. URL: 

https://www.epik-eu.com/publications

Financial Stability Report – Number 04. Central Bank of Kosovo. May 2014. 

URL: https://bqk-kos.org/repository/docs/2014/FSR_anglisht.pdf

Financial Stability Report. Central Bank of Kosovo. December 2020.

URL: https://bqk-kos.org/wp-content/uploads/2021/06/CBK_FSR_17.pdf

Government Securities rates and value. Central Bank of Kosovo. February 2022. 

URL: https://bqk-kos.org/repository/docs/time_series/13-

Government%20Securities%20rates%20and%20value.xls

IMF Country Report No. 20/217. Technical Assistance Report – Financial Sector Stability 

Review. International Monetary Fund. July 2020. URL: 

https://www.elibrary.imf.org/view/journals/002/2020/217/article-A000-en.xml

IMF Country Report No. 21/41. 2020 Article IV Consultation – Press Release; Staff Report; and 

Statement by the Executive Director for Republic of Kosovo. International Monetary Fund. 

February 2021. URL: https://www.imf.org/-

/media/Files/Publications/CR/2021/English/1KOSEA2021001.ashx

Kosovo 2021 Report. European Commission. October 19, 2021. URL: 

https://ec.europa.eu/neighbourhood-enlargement/kosovo-report-2021_en
45

Annex D: Data Collection Instruments

OTA Banking and Financial Services (BFS) Program

Qualitative Interview Guide – OTA BFS Staff Version

Interview Date

Interviewer Name

Notetaker Name

Unique ID

Years of Experience

Introduction

The evaluation of OTA/Kosovo’s Banking and Financial Services (BFS) program will serve two 

purposes:

The first purpose is to ensure OTA’s compliance with the Foreign Aid Transparency and 

Accountability Act (FATAA) of 2016, which includes requirements to evaluate the outcomes 

and impacts of OTA’s programs. 

The second purpose is to provide OTA with in-depth, third party, retrospective insights of its 

BFS program activities in Kosovo. The evaluation will focus on the key evaluation questions 

related to its contributions to financial sector-strengthening through its technical assistance to the 

Central Bank of Kosovo (CBK). 

Informed Consent

We will be asking you a series of questions on the topic of the OTA’s work in the financial sector 

in Kosovo. Your participation in this discussion is voluntary and you are free to discontinue with 

the discussion at any point or can ask us further details. 

We anticipate the discussion to take 60-90 minutes. 

We plan to share our findings in publications or presentations. You will not be identified by name. 

If we quote you, we will use a pseudonym. At the end of this interview, we will ask you if there 

is any information that you shared that is confidential or off the record. If you have understood 

these points and consent to continue the discussion, please give us a verbal agreement stating, 

“Yes, I consent to be interviewed.” 
46

Illustrative Interview Questions Notes

1. Please describe your role at OTA and with the 

Kosovo banking project.

2. How did OTA adapt its TA/recommendations to 

local realities in Kosovo?

3. How did OTA determine the starting point for a 

specific activity/intervention?

4. How did OTA prioritize activities/interventions?

5. Did OTA engage beneficiaries (stakeholders or 

end-users) in the process of designing financial 

sector infrastructure or regulations? 

6. How did certain activities/interventions 

(Emergency Liquidity Assistance, insurance 

supervision and liquidation of financial institutions) 

contribute to financial sector-strengthening in 

Kosovo?

7. The CBK FSRs report that between 2013 and 

today, (the approximate duration of the OTA 

project) financial stability has improved 

significantly, despite the COVID-19 crisis. Is it 

possible to measure the impact of the various 

components of OTA project on this improvement in 

financial stability?

8. OTA and other donors worked on non-systemic 

issues (insurance sector), systemic but low risk 

issues (ELA vs excess liquidity) and systemic with 

higher risk issues (Basel II/III, Solvency). On 

which of these aspects of financial stability is the 

impact of OTA's TA most evident?

9. How did OTA coordinate with other donors (to 

ensure sustainability of outcomes)?

10. What is the level/quality of Kosovar banks’ 

implementation of the main Basel Committee 

Principles?

11. Did staff turnover at the CBK impact the 

sustainability of OTA TA outcomes? 

AND/OR

How did OTA respond to staff turnover at the 

CBK?

12. How did training provided by OTA contribute to 

financial sector-strengthening in Kosovo?

13. Did you or other OTA staff maintain 

documentation of training conducted by OTA?
47

OTA Banking and Financial Services (BFS) Program

Qualitative Interview Guide – Counterpart Version

Interview Date

Interviewer Name

Notetaker Name

Unique ID

Organization

Sector

Years of Experience

Introduction

The Department of the Treasury’s Office of Technical Assistance (OTA) has provided technical 

assistance in Kosovo’s banking sector since 2012, using resident and intermittent Advisors who 

have worked closely with Counterparts in the Central Bank of Kosovo (CBK), the banking sector 

(including mortgage) and the insurance sector. OTA’s BFS program activities included support 

for development of Kosovo’s insurance sector and advising CBK in governance, operations, and 

banking sector oversight, and supporting Kosovo’s nascent government securities market. 

We are conducting this series of interviews to inform the OTA’s program design and to help 

identify ways in which that work contributed to financial sector-strengthening. We also want to 

identify outcomes of that work and determine which outcomes were sustainable over time. 

Informed Consent

We will be asking you a series of questions on the topic of OTA’s work in the financial sector in 

Kosovo. Your participation in this discussion is voluntary and you are free to discontinue with the 

discussion at any point or can ask us further details. 

We anticipate the discussion to take 60-90 minutes. 

We plan to share our findings in publications or presentations. You will not be identified by name. 

If we quote you, we will use a pseudonym. At the end of this interview, we will ask you if there 

is any information that you shared that is confidential or off the record. If you have understood 

these points and consent to continue the discussion, please give us a verbal agreement stating, 

“Yes, I consent to be interviewed.” 
48

Illustrative Interview Questions Notes

1. Please tell me about your roles and responsibilities in 

your current position.

2. Did you have direct interaction with an OTA Advisor

or Advisors? If so, in which capacity?

3. How did OTA adapt its TA/recommendations to 

changing realities?

4. How did OTA determine the starting point for a 

specific activity/intervention?

5. What were you hoping to achieve while working with 

OTA? What were your objectives?

6. How were OTA activities/interventions determined 

and prioritized?

7. Did your institution engage beneficiaries 

(stakeholders or end-users) in the process of 

designing financial sector infrastructure or 

regulations? 

8. What did you achieve while working with OTA’s 

Advisors?

9. How did certain activities/interventions (Emergency 

Liquidity Assistance, insurance supervision and 

liquidation of financial institutions) contribute to 

financial sector-strengthening in Kosovo?

10. The CBK FSRs report that between 2013 and today, 

(the approximate duration of the OTA project) 

financial stability has improved significantly, despite 

the COVID-19 crisis. Is it possible to measure the 

impact of the various components of OTA project on 

this improvement in financial stability?

11. Does the CBK regularly monitor financial institutions 

implementation of the laws/regulations drafted with 

OTA TA?

12. What is the level/quality of Kosovar banks’ 

implementation of the main Basel Committee 

Principles?

13. Did staff turnover at the CBK impact the 

sustainability of OTA TA outcomes?

AND/OR

How did OTA respond to staff turnover at the CBK?

14. How did training provided by OTA contribute to 

financial sector-strengthening in Kosovo?

15. Did your institution maintain documentation of 

training conducted by OTA?

OTA Government Debt and Infrastructure Finance (GDIF) Program

Qualitative Interview Guide – OTA GDIF Staff Version
49

Interview Date

Interviewer Name

Notetaker Name

Unique ID

Years of Experience

Introduction

The evaluation of OTA/Kosovo’s Government Debt and Infrastructure Finance (GDIF) program 

will serve two purposes:

First, is to ensure OTA’s compliance with the Foreign Aid Transparency and Accountability Act 

(FATAA) of 2016, which includes requirements to evaluate the outcomes and impacts of OTA’s 

programs. 

The second purpose is to provide OTA with in-depth, third-party, retrospective insights of its 

banking program activities in Kosovo. The evaluation will focus on the key evaluation questions 

related to its contributions to financial sector-strengthening through its technical assistance to the 

Central Bank of Kosovo (CBK). 

Informed Consent

We will be asking you a series of questions on the topic of OTA’s work in the financial sector in 

Kosovo. Your participation in this discussion is voluntary and you are free to discontinue with the 

discussion at any point or can ask us further details. 

We anticipate the discussion to take 60-90 minutes. 

We plan to share our findings in publications or presentations. You will not be identified by name. 

If we quote you, we will use a pseudonym. At the end of this interview, we will ask you if there 

is any information that you shared that is confidential or off the record. If you have understood 

these points and consent to continue the discussion, please give us a verbal agreement stating, 

“Yes, I consent to be interviewed.” 
50

Illustrative Interview Questions Notes

1. Please describe your role at OTA and with the Kosovo 

debt project.

2. How did OTA adapt its TA/recommendations to 

changing realities?

3. How did OTA determine the starting point for a 

specific activity/intervention?

4. How were OTA activities/interventions determined 

and prioritized?

5. Did OTA engage beneficiaries (stakeholders or endusers) in the process of designing debt market 

infrastructure or regulations?

6. How did the establishment of the Debt Management 

Unit (DMU) within the Ministry of Finance contribute 

to improved debt management in Kosovo?

7. OTA TA helped create the primary and secondary 

market of government securities. How did this affect 

the overall sustainability of finances, namely financing 

of fiscal deficit? 

8. How successful were project interventions in 

expanding financing sources to other non-bank 

institutions? How efficient was the electronic 

platform for the sale and trading of government 

securities? Were any irregularities reported by banks 

and other market players? 

9. How did the establishment of the Debt Management 

Unit (DMU) within the Ministry of Finance contribute 

to sustainability of public finance in Kosovo?

10. What is the current status of the debt regulatory 

framework (Debt Law and related second regulation, 

Law on Public Financial Management and 

Accountability) that were supported by the OTA 

technical assistance? 

11. Did staff turnover at the MOF impact the 

sustainability of OTA TA outcomes? 

AND/OR

How did OTA respond to staff turnover at the MOF?

12. How did training provided by OTA contribute to 

improved public debt management in Kosovo?

13. Did you or other OTA staff maintain documentation 

of training conducted by OTA?
51

OTA Government Debt and Infrastructure Finance (GDIF) Program

Qualitative Interview Guide – Counterpart Version

Interview Date

Interviewer Name

Notetaker Name

Unique ID

Organization

Sector

Years of Experience

Introduction

The Department of the Treasury’s Office of Technical Assistance (OTA) has provided technical 

assistance in Kosovo’s debt sector since 2007 using resident and intermittent Advisors who have 

worked closely with Counterparts in the Ministry of Finance (MOF) of Kosovo. OTA’s debt 

sector Advisors focused on building Kosovo’s sovereign debt capacity and providing expert 

guidance in developing a Debt Management Unit (DMU) and supporting Kosovo’s nascent 

government securities market.

We are conducting this series of interviews to inform the OTA’s program design and to help 

identify ways in which that work contributed to improved public debt management in Kosovo. 

We also want to identify outcomes of that work and determine which outcomes were sustainable 

over time. 

Informed Consent

We will be asking you a series of questions on the topic of OTA’s work in the financial sector in 

Kosovo. Your participation in this discussion is voluntary and you are free to discontinue with the 

discussion at any point or can ask us further details. 

We anticipate the discussion to take 60-90 minutes. 

We plan to share our findings in publications or presentations. You will not be identified by name. 

If we quote you, we will use a pseudonym. At the end of this interview, we will ask you if there 

is any information that you shared that is confidential or off the record. If you have understood 

these points and consent to continue the discussion, please give us a verbal agreement stating, 

“Yes, I consent to be interviewed.” 
52

Illustrative Interview Questions Notes

1. Please tell me about your roles and responsibilities in your 

current position.

2. Did you have direct interaction with an OTA Advisor or 

Advisors? If so, in which capacity?

3. How did OTA tailor adapt its TA/recommendations to 

local realities in Kosovo?

4. What were you hoping to achieve while working with 

OTA? What were your objectives?

5. How were OTA activities/interventions determined and 

prioritized?

6. How did OTA determine the starting point for a specific 

activity/intervention?

7. What did you achieve while working with OTA’s 

Advisors?

8. Did your institution engage beneficiaries (stakeholders or 

end-users) in the process of designing financial sector 

infrastructure or regulations?

9. How did the establishment of the Debt Management Unit

(DMU) within the Ministry of Finance contribute to 

improved debt management in Kosovo?

10. OTA TA helped create the primary and secondary market 

of government securities. How did this affect the overall 

sustainability of finances, namely financing of fiscal 

deficit? 

11. How successful were project interventions in expanding 

financing sources to other non-bank institutions? How 

efficient was the electronic platform for the sale and 

trading of government securities? Were any irregularities 

reported by banks and other market players? 

12. How did the establishment of the Debt Management Unit

(DMU) within the Ministry of Finance contribute to 

sustainability of public finance in Kosovo?

13. What is the current status of the debt regulatory framework 

(Debt Law and related second regulation, Law on Public 

Financial Management and Accountability)? that were

supported by the OTA technical assistance? 

14. Did staff turnover at the MOF impact the sustainability of 

OTA TA outcomes? 

AND/OR How did OTA respond to staff turnover at the 

MOF?

15. How did training provided by OTA contribute to improved 

public debt management in Kosovo?

16. Did your institution maintain documentation of training 

conducted by OTA?
53

Annex E: Key Informants Interviewed

Between May 3 and June 16, 2022, the Bixal evaluation team conducted Key Informant 

Interviews (KIIs). A total of 24 KIIs were conducted, with 36 respondents. The gender 

composition was seven women and 29 men. The table below presents the KIIs and respondents: 

MEET

ING

RESPONDENT

Names 

Redacted

POSITION INSTITUTION OTA 

PROGR

AM

DATE INPERSO

N/ONLINE

GENDER

1 1 Senior 

Advisor, 

Government 

Debt and 

Infrastructure 

Team

OTA GDIF May 3, 

2022

Online Male

2 2 Senior 

Advisor, 

Government 

Debt and 

Infrastructure 

Team

OTA GDIF May 3, 

2022

Online Male

2 3 Senior 

Advisor, 

Banking and 

Financial 

Services Team

OTA BFS May 5, 

2022

Online Male

3 4 Economic 

Growth Office

USAID/ 

Kosovo

BFS and 

GDIF

May 12, 

2022

In-person Male

5 Public Finance 

Objective 

Lead

USAID/ 

Kosovo 

Economic 

Governance 

Activity 

(KEGA)

BFS and 

GDIF

May 12, 

2022

In-person Female

6 Chief of Party USAID/ KEGA BFS and 

GDIF

May 12, 

2022

In-person Male

4 7 Officer 

Economic Unit

U.S. Embassy/ 

Pristina, 

Kosovo

BFS and 

GDIF

May 12, 

2022

In-person Male

8 . Economic Unit 

Chief

U.S. Embassy/ 

Pristina, 

Kosovo

BFS and 

GDIF

May 12, 

2022

In-person Male

5 9 Advisor, 

Government 

Debt and 

Infrastructure 

Team

OTA GDIF May 13, 

2022

Online Female
54

6 10 Governor CBK BFS May 13, 

2022

In-person Male

11 Chief of 

Cabinet

CBK BFS May 13, 

2022

In-person Male

7 12 Head of 

Asset 

Department

CBK BFS and 

GDIF

May 13, 

2022

In-person Female

13 Advisor to 

Governor

CBK BFS and 

GDIF

May 13, 

2022

In-person Male

8 14 Director, 

Department 

for Payment 

Systems

CBK BFS May 13, 

2022

In-person Male

9 15 Former 

Donor 

Coordinator

CBK BFS and 

GDIF

May 13, 

2022

In-person Female

10 16 Economist IMF/ Kosovo BFS and 

GDIF

May 16, 

2022

In-person Male

11 17 CEO Kosovo 

Banking 

Association

BFS May 16, 

2022

Online Male

18 Head of 

Treasury 

Office

Raiffeisen 

Bank Kosovo

BFS May 16, 

2022

Online Male

12 19 Managing 

Director

Kosovo 

Pension 

Savings Trust 

(KPST)

GDIF May 16, 

2022

In-person Male

20 Deputy 

Director

Kosovo 

Pension 

Savings Trust 

(KPST)

GDIF May 16, 

2022

In-person Male

13 21 Director Scardian 

Insurance 

Company

BFS and 

GDIF

May 17, 

2022

In-person Male

14 22 Minister MOF GDIF May 18, 

2022

In-person Male

15 23 Former 

Minister

MOF GDIF May 18, 

2022

In-person Male

16 24 Director. 

Treasury 

Office

MOF GDIF May 18, 

2022

In-person Male

25 Head of Debt 

Unit

MOF GDIF May 18, 

2022

In-person Female

26 Debt 

Management 

Officer

MOF GDIF May 18, 

2022

In-person Female
55

17 27 Director Kosovo 

Insurance 

Bureau

BFS May 19, 

2022

In person Male

28 Advisor Kosovo 

Insurance 

Bureau

BFS May 19, 

2022

In person Male

18 29 Head of Bank 

Supervision

CBK BFS May 19, 

2022

Online Male

19 30 Former 

Deputy 

Governor/ 

Former 

Treasury 

Director

CBK, MOF BFS and 

GDIF

May 19, 

2022

In-person Male

20 31 Former Debt 

Unit Director/ 

Former 

Deputy 

Director of 

Treasury

MOF GDIF May 20, 

2022

In-person Female

21 32 Chief Risk 

Officer

Banka 

Ekonomike

BFS May 20, 

2022

In-person Male

33 Treasury 

Office

Banka 

Ekonomike

BFS May 20, 

2022

In-person Male

22 34 Former 

Minister of 

Finance

MOF BFS and 

GDIF

May 20, 

2022

In-person Male

23 35 Advisor, 

Banking and 

Financial 

Services 

Team

OTA BFS May 23, 

2022

Online Male

24 36 Advisor, 

Banking and 

Financial 

Services 

Team

OTA BFS June 16, 

2022

Online Male
56

Annex F: Online Survey of Kosovar Banks

In June 2022, the evaluation team conducted an online survey of Kosovar banks. The 

survey was conducted with the cooperation of the Kosovo Banking Association (KBA). 

Four of the 10 member banks of the KBA completed the survey.

 Name of Bank Position

1 Raiffeisen Bank Kosovo Head of Treasury

2 ProCredit Bank Kosova Head of Risk Management

3 TEB Bank Head of Treasury 

4 Banka per Biznes (BPB) Head of Risk Management

1. Did you or your institution participate in quarterly meetings that the Ministry of Finance

(and OTA experts) held with primary dealers of government securities, during the time period

from 2012 to 2018?

Options Frequency 

Yes, I did 3

Yes, someone else from my institution did 1

No, neither myself, nor someone else from my institution did 0

I don’t know/remember 0

I choose to not answer this question 0

2. Did you or your institution participate in training/s for market participants conducted by the

Ministry of Finance (jointly with OTA), during the time period from 2012 to 2018?

Options Frequency 

Yes, I did 3

Yes, someone else from my institution did 1

No, neither myself, nor someone else from my institution did 0

I don’t know/remember 0

I choose to not answer this question 0

3. Did the Central Bank of Kosovo or the Ministry of Finance engage you in the process of

reviewing or commenting on proposed financial sector infrastructure or regulations, during the

time period from 2012 to 2018?

Options Frequency 

Yes, only Central Bank of Kosovo did 0

Yes, only Ministry of Finance did 1

Yes, both Central Bank of Kosovo and Ministry of Finance did 3

Neither of them engaged us in those processes 0

I don’t know/remember 0

I choose to not answer this question 0
57

4. If the capital market was further developed in the next years, what type of assets would be

prioritized by your organization?

Note: Please choose maximum three priorities

Options Frequency 

Corporate shares (on stock exchange) 2

Corporate bonds 1

Municipal bonds 2

Real estate covered bonds 0

Green bonds 3

Longer-term government or corporate bonds for project finance

(power plants, dams, roads, etc.)

1

Other (Please write.) ______________ 0

I choose to not answer this question 0

5. In your opinion, which of the following reforms (supported by OTA) have made it possible

to consolidate the financial sector in Kosovo since 2012?

Note: 1-No positive impact to 5-High positive impact

Reforms 1:

No 

positive

impact

2:

Low 

positive 

impact

3:

Medium 

positive 

impact

4:

Good/ 

Significant

positive 

impact

5:

High

positive 

Impact

I don’t 

know

I choose 

to not 

answer 

this 

question

If your 

answer is 1 

or 2, could 

you please 

provide 

brief 

explanation?

Basel II 0 0 0 4 0 0 0 N/A

Basel III 0 1 0 4 0 0 0

The Basel III rules 

have not been 

properly applied as 

almost no bank in 

Kosovo has an 

Internal-Based Risk 

Approach that 

indicates a basic 

level of risk 

management 

development at the 

Kosovo level

Law on Insurance 0 0 0 1 0 1 2 N/A

Banking Law 0 0 0 3 1 0 0 N/A

Regulations on 

housing mortgages

0 1 1 2 0 0 0

The regulations have 

had a small positive 

impact because the 

criteria are difficult 

to implement in 

practice.

Regulations on real 

estate appraisers

0 0 0 4 0 0 0 N/A

Risk-based 

supervision

0 0 0 2 2 0 0 N/A
58

Emergency 

Liquidity 

Assistance

0110200

The legislation is not 

in line with the 

MREL and the 

process has never 

been tested so far for 

the speed of 

decision-making as 

the CBK according 

to the regulation 

needs time for 

decision-making. 

Regarding the non-

emergency option 

such as short-term 

liquidity provided by 

the Central Bank in 

the form of repo, 

there is a very small 

limit by the Central 

Bank and REPO 

contracting is not 

guaranteed.

Development of 

equity market

2011000

1. The focus has 

been extremely 

narrow on local 

securities. No steps 

have been taken to 

create legislation for 

stock market, fund 

registration, 

registration of asset 

managers and exams 

for asset managers. 

There is no 

department for 

development of 

financial products in 

either the Ministry 

of Finance or the 

CBK

2.There is no stock 

market in Kosovo.

Repo system for 

liquidity 

management

0112000

The market with 

CBK does not exist. 

There is very little 

cooperation between 

banks as the cost of 

transfers to the CBK 

to remove funds 

from Kosovo is 

extremely high and 

this forces banks to 

keep funds in the 

CBK and reduces 

the need for REPO. 

Regarding Nettting

(we are not members 

of ISDA) there is no 

progress and Netting 

is mentioned only in 

the Banking Law 

and the law only 

applies to the 

financial sector.

CBK intraday and 

overnight liquidity 

arrangements

0022000 N/A

Regulation on 

corporate 

governance

0102100

It does not positively 

affect the 

development of the 

capital market. As a 

result of this 

regulation, none of 

board member[s] of 

[b]anks in Kosovo is 

experienced in 

capital markets, and 

this hinders the 

development of 

markets, stock 

exchanges, corporate

bonds, capital 

growth in 

companies. No 

board member in 

banks is required to 

have qualifications 

in investment 

management, despite

the fact that liquidity 
59

is 35% in the 

market, but it is only 

required to be 

experienced only in 

basic banking. This 

is an exception in the 

region. Also, the 

appointment of 

board members is 

not done by testing, 

and scoring as in the 

[European Union], 

in fairness and merit, 

which leaves room 

for the appointment 

of members with 

inadequate 

qualifications.

6. In your opinion, which of the following reforms (supported by OTA) need to be amended in

order to adapt to local conditions and achieve the best level of efficiency?

Note: 1-Substantial amendments are needed for the reform to be fully efficient to 5-No

amendments are needed since the reform is well implemented and fully operational

Reforms 1

Substantial 

amendmen

t is needed 

(60% or 

more)

2

Significant 

amendment 

is needed

(Around 

50%)

3

Some 

amendment is 

needed

(40 % or less)

4

Few 

amendments are 

needed

(Less than 20 

%)

5

No 

amendmen

t is needed

I don’t 

know

I choose 

to not 

answer 

this 

question

If your 

answer is 

1, 2 or 3 

could you 

please 

provide 

brief 

explanatio

n?

Basel II 0 0 0 3 0 0 1 N/A

Basel III 0 0 1 2 0 0 1

There are CRR 

regulations that 

are not properly 

implemented. 

The LCR and 

NSFR must be 

implemented as 

well as the 

capital and 

MREL rules and 

the insurance 

must conform to 

the liquidity 

delegated act for 

non-retail in the 

LCR

Law on 

insurance

0 0 0 1 0 0 3 N/A

Banking Law 0 0 0 4 0 0 0 N/A

Regulations on 

housing 

mortgages

0 1 0 2 0 1 0 No 

comment

Regulations on 

real estate 

appraisers

0 0 0 1 1 2 0 N/A

Risk-based 

supervision

0 0 0 4 0 0 0 N/A

Emergency 

Liquidity 

Assistance

0 0 0 2 0 1 1 N/A

Development of 

equity market

2 0 0 1 0 0 1

There is no 

secondary 

legislation at all 

for shares, 
60

funds. It is only 

mentioned in 

article 44 of the 

Law on Banks

Repo system for 

liquidity 

management

0 0 1 2 0 0 1

The Central 

Bank must 

reduce the 

international 

FEE, guarantee 

the amounts in 

REPO and have 

a regulation for 

Long Term 

Liquidity 

Facility for up 

to 2 years.

CBK intraday 

and overnight 

liquidity 

arrangements

0 0 0 1 2 0 1 N/A

Regulation on 

corporate 

governance

0 0 0 3 0 0 1 N/A
61

Annex G: Overview of the OTA BFS Program

Overview of OTA BFS Project – Kosovo – 2012–2020

Banking

intervention

Indicator Chan

ge

OTA 

contribution Constraint(s) Sustainability

2012 2020

Support to 

CBK

OTA 

developed 

policies/pro

cedures.

Policies/procedures 

developed by OTA 

still in use.

+

Ongoing 

technical 

assistance

Staff turnover. 

CBK cannot 

undertake 

monetary 

policy

OTA’s 

contribution 

was 

sustainable.

Legal/

regulatory 

framework

Law on 

Banking1

Revision of Law 

on Banking is 

pending for three 

years.

Stalle

d

OTA 

supported the 

revision of 

the Banking 

Law.

Delays in 

approving 

amendments to 

Banking Law.

The Banking 

Law needs to 

be amended/

revised.

Corporate 

governance

Corporate 

governance 

practices 

not in line 

with 

internationa

l standards.

Corporate 

governance 

regulation passed 

in 2016.

2

 

Implemented 

today.

+

OTA 

supported the 

regulation.

No major 

constraints.

Implementati

on of the 

regulation 

converges 

with 

international 

standards.

Risk-based 

bank 

supervision

Number of banks +2

Risk-based 

supervision.

CAMELS 

rating system.

Lack of 

implementatio

n and/or 

internal 

resistance by 

CBK. 

Risk-based 

supervision 

is not fully 

implemented.

9

3 114

Number of liquidated banks

None

1

5

1 Law on Banks, Microfinance Institutions and Non-bank Financial Institutions, CBK. URL: https://www.bqkkos.org/repository/docs/2012/Law%20on%20Banks%20MFI.pdf

2 Regulation on Corporate Governance of Banks, CBK. URL: https://bqkkos.org/repository/docs/korniza_ligjore/english/ENG%20%20Rregullore%20p%C3%ABr%20Qeverisje%20Korpor

ative%20t%C3%AB%20Bankave2019.pdf

3 Annual Report 2012, CBK. URL: https://bqk-kos.org/repository/docs/2013/CBK-AR-2012.pdf

4 Annual Report 2020, CBK. URL: https://bqk-kos.org/wp-content/uploads/2021/07/CBK_AR_2020.pdf

5 Annual Report 2012, CBK. URL: https://bqk-kos.org/repository/docs/2013/CBK-AR-2012.pdf
62

Average Capital Adequacy Ratio -

0.7%

17.2%6 16.5%7

% Non-performing loans -

3.8%

6.5%8 2.7%9

Emergency 

Liquidity 

Assistance

Liquidity: loan to deposit ratio

-8%

OTA 

supported the 

ELA.

None.

Operational 

and tested 

periodically.

82%10 74%11

Repo system 

for liquidity 

management

Nonexistent Operational +

OTA 

supported the 

repo system.

Lack of 

participation of 

CBK.

Operational, 

mainly 

between 

banks.

Liquidity 

arrangement

s

Nonexistent Operational +

OTA 

supported the 

CBK intraday 

and overnight 

liquidity 

arrangements

.

No major 

constraints. Operational.

6 Annual Report 2012, CBK. URL: https://bqk-kos.org/repository/docs/2013/CBK-AR-2012.pdf

7 Annual Report 2020, CBK. URL: https://bqk-kos.org/wp-content/uploads/2021/07/CBK_AR_2020.pdf

8 Annual Report 2012, CBK. URL: https://bqk-kos.org/repository/docs/2013/CBK-AR-2012.pdf

9 Annual Report 2020, CBK. URL: https://bqk-kos.org/wp-content/uploads/2021/07/CBK_AR_2020.pdf

10 ODC new loans and ODC new deposits, CBK. URL: https://bqkkos.org/repository/docs/time_series/11a%20ODC%20new%20deposits.xls and https://bqkkos.org/repository/docs/time_series/11%20ODC%20new%20loans.xls 

11 ODC new loans and ODC new deposits, CBK. URL: https://bqkkos.org/repository/docs/time_series/11a%20ODC%20new%20deposits.xls and https://bqkkos.org/repository/docs/time_series/11%20ODC%20new%20loans.xls
63

13 List of registered/licensed financial institutions, CBK. URL: https://bqk-kos.org/wpcontent/uploads/2022/04/Lista-e-institucioneve-financiare-01.04.2022.pdf

14 Kosovo Insurance Company was liquidated on April 2010. CBK Annual Report. URL: https://bqkkos.org/repository/docs/2018/CBK_AR_2017.pdf

Insig insurance company was liquidated on April 2019. CBK. URL: https://bqk-kos.org/the-cbk-executive-boarddecided-to-revoke-the-license-of-the-insurance-company-insig-j-s-c-kosovo-branch/?lang=en.

Overview of OTA BFS Project – Kosovo – 2012-2020

Sector 

intervention

Indicator

Change OTA 

contribution Constraint(s) Sustainability

2012 2020

Insurance:

Revision of law 

on Insurance

Law on 

Insurance 

approved in 

2012.

12

Final draft of 

amended/new 

law under 

consideration 

for one year.

-

OTA supported 

the legislation. None

OTA’s 

contributions 

are sustainable.

Insurance:

Solvency I 

implementation

Nonexistent Implemented +

OTA supported 

the 

implementation 

of Solvency I.

None with 

Solvency I.

Solvency II has 

not been 

implemented. 

Insurance:

Implementation 

of risk-based 

supervision

NonexistentSupervision 

in place. +

OTA 

developed a 

manual for 

supervision. It 

is still used 

today.

Initial effort 

to educate 

and train 

CBK staff.

The 

supervision is 

deemed by 

market 

participants as 

appropriate.

Number of insurance 

companies

-1

13 1213

Number of liquidated 

companies +

2

14

Insurance:

Regulation on 

corporate 

governance

Corporate 

governance 

practices 

not in line 

with 

international 

standards.

Corporate 

governance 

regulations 

passed in 

2016 and 

2020 apply to 

insurance 

companies. 

Implemented 

today.15

+

OTA supported 

the regulation.

No major 

constraints.

Implementation 

of the 

regulation 

converges with 

international 

standards.
64

A re-insurance company was liquidated in 2021. URL: https://bqk-kos.org/the-executive-board-of-the-cbk-takes-adecision-to-revoke-the-license-of-the-insurer-kosova-e-re/?lang=en. Neither the CBK or insurance industry 

representatives discussed this.

15 Regulation on Corporate Governance of Insurers, CBK. URL: https://bqkkos.org/repository/docs/korniza_ligjore/shqip/Rregullore%20per%20Qeverisjen%20Korporative%20te%20Sigurues

ve.pdf

16 Regulation on appraisal of immovable properties, CBK. URL: https://bqkkos.org/repository/docs/korniza_ligjore/english/Rregullore%20per%20Vleresimin%20e%20Pronave%20te%20Pa lu

atjshme.ang.pdf

17 Regulation on residential mortgage lending, CBK. URL: https://bqkkos.org/repository/docs/korniza_ligjore/english/2-Regulation%20on%20Residential%20Mortgages%20-

%20ENG%20(3).pdf

18 Other Depository Corporations New Loans, CBK. URL: https://bqkkos.org/repository/docs/time_series/11%20ODC%20new%20loans.xls

19 Other Depository Corporations New Loans, CBK. URL: https://bqkkos.org/repository/docs/time_series/11%20ODC%20new%20loans.xls

Overview of OTA BFS Project – Kosovo – 2012–2020

Sector intervention

Indicator

Change OTA 

contribution Constraint(s) Sustainability

2012 2020

Real Estate

Valuation 

regulation for 

banks

Nonexistent

Regulation 

on 

Appraisal 

of 

Immovable 

Properties 

was passed 

in 201516

+

OTA 

supported the 

regulation.

The 

amendment of 

this 

regulation, 

which OTA 

drafted during 

2017 and 

2018, was not 

passed. 

OTA made a 

contribution, but 

significant 

constraints remain.

Real Estate

Regulation of

housing mortgages

Nonexistent

Regulation 

on 

residential 

mortgage 

lending 

passed in 

201517

Limited

OTA 

supported the 

regulation.

Major 

constraints: 

lack of 

property 

rights, 

unlicensed 

properties, etc.

OTA made a 

contribution, but 

significant 

New mortgage loans constraints remain.

(million Euro)

36.1

million

Euro18

191.3 m 

Euro 

(2021)19
65

20 Regulation on appraisal of immovable properties, CBK. URL: https://bqkkos.org/repository/docs/korniza_ligjore/english/Rregullore%20per%20Vleresimin%20e%20Pronave%20te%20Palu

atjshme.ang.pdf

21 List of licensed real estate appraisers, Ministry of Finance. URL: https://mf.rksgov.net/desk/inc/media/E4240D45-8FEC-4355-8FFE-C83C81A8C87E.pdf

New mortgage loans 

as % of total new 

loans

4.9% 10.6% 

(2021)

Real Estate

Regulation of real 

estate appraisers

Nonexistent

Regulation 

passed 

201520

+

OTA 

supported the 

regulation.

Major 

constraints: 

incomplete 

cadaster, lack 

of property 

rights, 

unlicensed 

properties, etc.

Despite the 

constraints, OTA’s 

work was 

sustainable.

Number of licensed 

appraisers

+253

0

253 

(2022)21
66

22 Other Depository Corporations New Loans, CBK. URL: https://bqkkos.org/repository/docs/time_series/11%20ODC%20new%20loans.xls

23 CBK time series data, ODC new loans. URL: https://bqkkos.org/repository/docs/time_series/11%20ODC%20new%20loans.xls

24 CBK annual report 2012. URL: https://bqk-kos.org/repository/docs/2013/CBK-AR-2012.pdf

25 CBK annual report 2020. URL: https://bqk-kos.org/wp-content/uploads/2021/07/CBK_AR_2020.pdf

Overview of OTA BFS Project – Kosovo – 2012–2020

Sector

intervention Indicator Change OTA contribution Constraint(s) Sustainability

Development 

and 

supervision of 

the insurance 

and real 

estate sectors

Asset size (% of 

financial sector)

Banks

+

OTA BFS 

project 

supported 

development 

and 

supervision of 

the insurance 

and real estate 

sectors.

The insurance 

market is well

regulated. 

Insurance 

companies are 

profitable. 

Solvency II is 

not 

implemented. 

Real estate 

faces major 

constraints, as 

noted above.

Recognizing the 

positive contributions 

made by OTA, the 

CBK and market 

participants would 

like to see both the 

insurance and real 

estate sectors develop 

even further.

74.7%22 67.7%23

Asset size (% of 

financial sector)

Insurance

3.4%24 2.8%25
67

Annex H: Chronology of OTA BFS Program: Banking, Insurance and Real Estate

Project Timeline – OTA BFS Project – Banking - Kosovo (2010–2020)

Assistance within the 

Central Bank

Adoption of the new law 

on the Central Bank of 

Kosovo

First issue of the 

Financial Stability Report 

for Kosovo published

Early warning indicators 

standardized and 

produced on regular 

monthly basis

Banking Law 

Approval of the Banking 

Law (2012)

Amendment of the 

Banking Law (pending 

for three years)

Risk-Based Supervision 

Drafting of Risk-based 

Supervision Manual 

Approval of Risk-based 

Supervision Manual 

Emergency Liquidity 

Arrangements 

Approval of Law on 

Emergency Liquidity 

Assistance

Completion of Legal 

Framework for the 

Emergency Liquidity 

assistance

Corporate Governance 

Drafting of Guidelines of 

the Corporate Governance 

of Banks in Kosovo

Approval of Regulation 

on Corporate Governance 

Intraday and Overnight 

Lending 

Approval of Regulation 

on Intraday and Overnight 

Lending

2010

2012

2015

2015

2016

2020
68

Project Timeline – OTA BFS Project – Insurance – Kosovo (2010–2020)

Drafting of Laws, Regulations, and 

Supervision Manuals

Preparation of the Draft Law on Insurance and 

Secondary Legislation

Drafting of Insurance Supervision Manual

Preparation of Supporting Documentation of 

Financial Examinations and Analysis

Law on Insurance 

Approval of the Law on Insurance

Regulation on Corporate Governance

Approval of the Regulation on Corporate 

Governance of Insurers

2020

2015

2012-2014
69

Project Timeline - OTA BFS Project - Insurance - Kosovo (2010-2020)

Assistance with Mortgage 

and Construction Survey 

Preparing Mortgage 

Survey and Regular 

Mortgage Reports

Completing Survey of 

Construction in Kosovo

Drafting of Regulations 

Drafting the Regulation 

on Residential Mortgages

Drafting the Regulation 

on Appraisal of Real 

Estate

Law on Condominiums

Drafting of the Law on 

Condominiums

Approval of the Law on 

Condominiums

Property Forum 

Supported GIZ in the 

establishment of the 

Property Forum

Approval and Update of 

Regulations

Approval of Regulation 

on Appraisal of 

Immovable Properties

Approval of Regulation 

on Residential Mortgages

Establishing the 

Regulatory Framework 

for the Board for 

Licensing Real Estate 

Appraisers

Licensing and Training of 

Appraisers

2012-2014

2012-2014 2013

2014

2015-2019

Appraisers Licensed and 

Trained

2015-2019
70

Annex I: Overview of the OTA GDIF Program

Overview of OTA GDIF Project – Kosovo – 2010-2022

Intervention 

Indicator

Change OTA 

contribution Constraint(s) Sustainability

2010 2020

Establishment 

of legal and

regulatory 

framework on 

debt

Law on 

Public Debt 

approved in 

2009. No law 

existed 

previously.26

Law on 

Debt 

approved 

in 2009 

still in 

force.

+

Drafting 

legislation and 

secondary 

regulations.

None

Law on Public 

Debt and 

secondary 

legislation still 

in force. 

Establishment 

of debt 

management 

unit (DMU)

DMU 

established. 

No DMU 

existed 

previously.

Fully 

Functional 

DMU27

+

1. Creation of

DMU in 2010.

2. Capacitybuilding of

DMU.

Staff turnover

DMU manages 

all debt related 

activities. 

Establishment 

of domestic 

debt market 

(procedures,

processes, 

calendar, 

strategy) 

Domestic 

debt market 

established. 

No domestic 

debt market 

existed 

previously.

Wellfunctioning 

domestic 

debt 

market 

established 

from 

scratch.

+

1.Drafting 

market 

regulations.

2. Training of

DMU staff

(ongoing).

3. Training of

market

participants

(2010).

4. Speed of

creating the

domestic debt

market.

1. Annual 

calendar still 

published, but

quarterly

calendars

could/should

include more

details.

2. Secondary

market

underdeveloped.

3. Pace of debtmarket

development

slowed down

after 2015-16.

1. Regulations

still in force

and

implemented.

2. Annual 

financing

calendar

continues to be

published

regularly.

Trading system 

Trading 

system 

established. 

No trading 

system 

existed 

previously.

Efficient 

trading 

system and 

e-platform. 

+

1.Design 

specifications 

for the trading 

system (2010).

2. Functioning

of the eplatform,

None.

1. Efficient

trading system

created and

operational 

today.

2. Efficient eplatform.

26 Law on Public Debt, MOF. URL: https://gzk.rks-gov.net/ActDetail.aspx?ActID=2663

27 Public Debt Unit webpage, MoF, URL: https://mf.rks-gov.net/page.aspx?id=2,49
71

Overview of OTA GDIF Project – Kosovo – 2010-2022

Intervention

Indicator

Change OTA 

Contribution Constraint(s) Sustainability

2010 2020

Maturity of 

bonds and 

bid cover 

ratio 

1.58month

s 

2.4928

35.11 

months 

1.529

33.58 

months 

0.99

2012 – threemonth T-Bills

2013 – sixmonth and 

one-year Tbills 

2014 – twoyear securities 

2015 – threeand five-year 

securities 

2017 – sevenyear securities 

2018 – 10-year 

securities

2021 –

diaspora bonds

Time required 

to develop 

market and 

market 

participant 

behavior/confi

dence. 

Maturity of 

instruments

increased over 

time.

As the volume of 

issued bonds 

increased, some 

auctions were not 

fully subscribed. 

Nevertheless, the 

bid cover ratio 

remained high.

Overall debt 

volume

6.22%

Nominal 

value of 

domestic 

debt –

EUR 73.3 

million30

21.92%

Nominal 

value of 

domestic 

debt – EUR

961.90 

million31

15.7%

EUR

888.6 

million 

OTA 

contributed to 

prudent public 

debt issuance 

and 

management.

Time required 

to develop 

market and 

market 

participant 

behavior/confi

dence.

No other 

instruments 

developed yet.

Domestic debt 

volume increased 

over time. 

Establishme

nt of a 

consultation 

mechanism 

Nonexistent 

previously

Quarterly 

meetings are 

held.

+

OTA advisor 

plays an 

advisory role 

in quarterly 

meetings with 

primary 

dealers. 

Interest of 

market 

participants.

Meetings are still 

held.

28 Data provided by DMU/MOF/

29 Data provided by DMU/MOF.

30 Annual 2015 Bulletin on Public Debt. MoF, URL: https://mf.rks-gov.net/desk/inc/media/8FE80959-0A63-4049-

B97A-5C47902577D1.pdf

31 Annual 2020 Bulletin on Public Debt. MoF, URL: https://mf.rks-gov.net/desk/inc/media/46BF6C74-32C4-4483-

A149-6391F1E06F0D.pdf
72

Coordination 

of MOF with 

CBK on 

public debt 

management 

Nonexistent 

previously

Coordinatio

n takes 

place.

+

1. OTA

recommended

regular

monthly

coordination

meetings

between MOF

and CBK.

2. Liquidity

Committee

3. ELA

4. Repo

1. Less

frequent

coordination

meetings.

2. Occasional 

disagreement

between CBK

and MOF on

legal 

interpretation

and financial 

instruments.

Quarterly 

operational 

meetings between 

the MOF, CBK 

and primary 

dealers still held.
73

Annex J: Chronology of OTA GDIF Program Interventions

Project Timeline – OTA GDIF Project – Kosovo (2010-2015)

Debt Management Unit 

(DMU) established 

Debt Management Unit 

(DMU) established. 

Staff training on cash 

management.

Amendments of Laws ( 

LPFMA and CBK).

Tender for sovereign 

credit rating completed.

Establishment of Liquidity 

Committee

DMU completely staffed. 

Training provided on cash 

forecasting, risk analysis 

and debt strategy 

development.

Establishment of 

Liquidity Committee with 

CBK. 

Adoption of a primary 

dealer system to 

underwrite the securities 

offered by the MOF.

Issuance of three-month 

Treasury Bills

The first Annual Debt 

Strategy approved. 

First Issuance of Kosovo 

Treasury (T) bills with 

three-month maturity. 

Trainings on the

operational aspects of 

secondary market 

activity, repurchases 

agreements, and nonstandard government 

securities transactions. 

Issuance of Six-Month 

and One-Year T-Bills 

Issuance of six-month 

and one-year T-bills. 

MOF Regulations on the 

Primary and Secondary 

Markets for the issuance 

of Government 

Securities adopted.

Daily cash management 

in DMU strengthened.

Credit rating from 

Standard & Poor’s. 

Rating is not released to 

the public and remains 

undisclosed.

Introduction of 2-year 

securities 

Introduction of twoyear securities.

Capacity-building to 

target secondary

market activities. 

New regulation 

signed between 

MOF and CBK that 

would apply to sixmonth treasury bills 

and government 

bonds.

Introduction of 3- and 5-

Year Securities 

Introduction of threeand five-year securities.

Individuals and 

insurance companies 

able to purchase Kosovo 

government securities 

either at auction or in the 

secondary market.

The Central Bank of 

Kosovo able to purchase 

securities only in the 

secondary market.

2010

2011

2012

2013

2014

2015
74

Project Timeline – OTA GDIF Project – Kosovo (2016-2021)

Continuation of Three- and 

Five-Year Issuance 

Continued fall of interest 

rates. 

Participation of non-bank 

investors such as insurance 

companies and pension funds. 

Budgetary role reached. 

Issuance of Seven-Year 

Maturity 

Support on drafting 

regulation entitled Primary 

and Secondary Market of 

Government Securities of the 

Republic of Kosovo.

Supporting the MOF, CBK, 

and existing primary dealers 

to provide an operational 

framework for a viable 

Primary Dealer System that 

will expand secondary 

market volumes.

New Introduction of 10-

Year Securities

Issuance of 10-year maturity 

securities. 

Extension of weighted 

average maturity.

Review of the Regulation on 

the Primary and Secondary 

Market of Government 

Securities of the Republic of 

Kosovo. 

Under-subscription or failed 

auctions.

DMU Staff Turnover

Several staff left the DMU.

Ongoing TA/capacitybuilding.

Regulations on the Liquidity 

Adjustment Facility of the 

Central Bank of Kosovo was 

passed. 

Introduction of Diaspora 

Bonds 

Inter-day and overnight 

collateralized credit

regulations were formally 

adopted by the Central Bank 

of Kosovo.

The MOF completes the sale 

of three-year and five-year 

bonds specifically targeted to 

diaspora investors. Diaspora 

bonds attract a total of EUR 

10.43 million.

2016

2017

2018

2019

2020-2021
75

Annex K: Description of the “Brain Fund”

In 2009, a USAID project implemented by Bearing Point recommended the establishment of a 

“Brain Fund” to attract and retain highly skilled professionals within the civil service of Kosovo. 

The Brain Fund was suggested and conceptualized with the support of the GAP Institute. 

The Brain Fund later renamed the “Cadre Fund,” created several new positions for senior-level 

specialists, paid between EUR 800 to EUR 1,800 per month, depending on the position. A set of 

qualifications were established for employment in these positions.

Three DMU positions in the front, middle, and back office were to be paid by the Brain Fund 

project. An agreement was reached in 2009, but due to bureaucratic procedures, the process was 

delayed for four months. Two high-level staff left the DMU at the end of 2010,

32 and as a result, 

the entire process of hiring and training had to be repeated in 2011.

The Brain Fund was in effect until 2015. Despite selection criteria and clearly defined purposes 

provided by Regulation No. 14/2012, in 2015 the GAP Institute, which monitored the Fund since 

its establishment, concluded that the Fund was misconstrued and misused by various ministries.33 

The GAP Institute documented that most of the employees paid by the Brain Fund did not meet 

the established qualifications. Some did not even have an advanced university degree. Of 222 

employees paid by the Fund in 2014, only six of them held a PhD in science and 94 held a 

master’s degree. For more than half of the employee-beneficiaries, 122 people, it was not known 

if the employee held any university degree. According to the GAP Institute, the Fund was 

corrupted by high-level ministry employees to pay themselves and reward selected other

employees.

34

32 See 201012_gdim_mr_kosovo_schwartz

33 See https://www.institutigap.org/documents/88573_FondiperKuadroENG.pdf

34 See https://www.institutigap.org/documents/5439_excellence%20fund.pdf
76

Annex L: Evaluation Team Qualifications

Team Leader Geoffrey Mazullo has 28 years of technical experience as an evaluator, corporate 

analyst, subject matter expert, and trainer. His expertise includes corporate governance, socially 

responsible investment, and environmental, social and governance reporting in emerging market 

environments. He has extensive experience as an evaluation Team Leader, a program Chief of 

Party, technical expert, and expert trainer in MEL, governance, and other subjects for USAID, 

the U.S. Department of State, and numerous other government, private sector, and NGO clients. 

He has a M.Sc. in Political Science from the London School of Economics, graduate certificates 

from Jagiellonian University in Poland and Freie Universitaet in Germany, and a B.Sc. in 

Foreign Service from Georgetown University. He has lived and worked extensively throughout 

Eastern Europe, is a native English speaker, and is proficient in Serbo-Croatian, German, French, 

Polish, and Russian.

Valmira Rexhebeqaj has more than 15 years of technical experience in public finance, 

macroeconomic policy analysis, fiscal governance, budgeting, national planning, and taxation 

expertise. In the past, she served as a Director of Economic and Public Policy for the Ministry of 

Finance in Kosovo for three years ending in 2014, and currently is the Founder/Director of Rex 

Consulting Group in Kosovo, providing technical assistance, training, assessment, and evaluation 

services to the Kosovo and other regional governments, World Bank, GIZ, CEF, OECD, the EU 

Commission, and other private sector and NGO clients. She is a Ph.D. candidate in Economics at 

the University of Tirana and has an M.Sc. from Staffordshire University in the UK. She is a 

native Albanian speaker and is fluent in English and Serbo-Croatian.

Jean-François Bouchard has more than 35 years of experience in the banking sector. 

Currently, he is a lead consultant with the Agence Française de Développement, World Bank, 

GIZ, IMF and other clients providing expert guidance in such banking area subjects as antimoney laundering and financing terrorism, risk-based supervision, and enhancing banks’ 

financial stability, providing expertise in Africa and Asia. His expertise also includes 

microprudential and macroprudential policy, Basel II and III implementation, bank restructuring, 

and stress-testing. He has served as a Resident Advisor for the IMF responsible for the Central 

Africa region, as well as in Bulgaria with the European Commission for the National Bank of 

Romania. He is also a former Head of Mission for the Autorité de Contrôle Prudentiel (French 

Banking Commission), and has served in numerous high level advising, training, and 

management roles with the Banque de France. He is a native French speaker, is fluent in English 

and proficient in German and Romanian.

Genta Agaj has 10 years of technical experience in monitoring and evaluation, working across 

several sector areas including governance, microfinance, education, and community 

development. Currently, she serves as an M&E Specialist for the Millenium Challenge 

Corporation with the Kosovo Threshold Program. Her expertise includes impact evaluation, 

M&E design and planning, quantitative and qualitative methods and analysis, survey design, 

advising on performance indicators, and data collection strategies for USAID, contractors, and 

NGOs. She has a Bachelor of Applied Science degree in Economics from the Rochester Institute 
77

of Technology, and a Master’s in Applied Economics from the University of Maryland. She is a 

native Albanian speaker and is fluent in English.

Driton Zechiri has more than 20 years of technical experience, most recently as a monitoring 

and evaluation consultant for numerous USAID contractors, UN agencies, various EU funders, 

European research and policy think tanks, and NGOs. His expertise includes program 

evaluation, qualitative, quantitative, and mixed methods, evaluation management, survey design, 

baseline studies, and data collection strategies. He is a Ph.D. candidate in Sociology at the 

University of Prishtina, where he also has Master’s and Bachelor’s degrees in Sociology. He is a 

native Albanian speaker, and fluent in English and Serbian.

Michael Tatone is an International Evaluation Project Manager at Bixal. He has 13 years of 

technical experience in evaluation and research, managing and providing technical support for 

evaluations and impact studies in conflict and violence in Colombia, Brazil, and Chicago. 

Previous roles have included Research Manager at the University of Chicago, and various 

Project Manager and Researcher roles in academia and NGOs. He has a Master’s in Political 

Science from Universidad de Los Andes in Colombia, and a BA in Political Science from 

University of Wisconsin-Eau Claire. He is a native English speaker and is fluent in Spanish and 

Portuguese.

Joseph Kotun is a Director of Monitoring, Evaluation and Learning at Bixal. He has more than 

25 years of technical experience in international development, focused on evaluation. Before his 

current role at Bixal he has worked extensively as an evaluation Team Leader for contractors 

with USAID, MCC, USDA, U.S Department of State, World Bank, DFID, Asian Development 

Bank, and other private sector and NGO clients. His expertise includes evaluation design, 

mixed, qualitative, and quantitative methods, program evaluations, impact evaluations, and 

systems-based evaluations as well as MEL frameworks, strategies, and learning agenda 

development. His evaluation work includes financial inclusion and microfinance subject areas, 

as well as a broad range of other international development sectors. He has a Master’s in 

International Development from the School for International Training Graduate Institute in 

Vermont and a B.Sc. in Science from McGill University. He is a native English speaker and 

proficient in French.