EUROPEAN COMMISSION Brussels, 9.1.2023 SWD(2023) 3 final COMMISSION STAFF WORKING DOCUMENT Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS







Assessment report of the Member States’ national Roma strategic frameworks {COM(2023) 7 final}



INTRODUCTION AUSTRIA 3 BELGIUM 9 BULGARIA 16 CROATIA 25 CYPRUS 31 CZECHIA 37 DENMARK 44 ESTONIA 48 FINLAND 52 FRANCE 59 GERMANY 65 GREECE 72 HUNGARY 80 IRELAND 88 ITALY 92 LATVIA 101 LITHUANIA 107 LUXEMBOURG 113

THE NETHERLANDS 117 POLAND 123 PORTUGAL 129 ROMANIA 133 SLOVAKIA 141 SLOVENIA 148 SPAIN 154 SWEDEN 164 Appendix 1. Tables with the situation of targets per objectives – prepared by EU FRA 169 Appendix 2: Summary of the Roma Civil Monitoring Preparatory Action’s assessment of EU Member States’ NRSFs 171 INTRODUCTION All EU Member States were invited to develop and adopt national Roma strategic frameworks (NRSFs) according to their national contexts and circumstances, also taking into consideration the size of Roma population living on their territories, the EU Roma Strategic Framework for equality, inclusion and participation and the commitments made in the Council Recommendation.

The Commission services analysed the information provided in each NRSF to assess to which extent the measures included in the NRSFs reflect the particular challenges of the respective Member State, and whether the measures are ambitious enough to help meet the EU Roma Strategic Framework’s headline targets by 2030. This Staff Working Document (SWD) provides the country specific assessment of the NRSFs, in the form of country fiches. These country fiches reflect the structure of the Council Recommendation, and assess for each Member State the correspondence of their main proposed measures with the EU Roma Strategic Framework and the Council Recommendation. The country fiches also highlight areas for improvement. The SWD also includes two appendixes. Appendix 1 presents a table prepared by EU Fundamental Rights Agency (FRA) which provides an overview of targets set by Member States. Appendix 2 presents a summary of the Roma Civil Monitoring Preparatory Action’s assessment of Member States’ NRSFs.



AUSTRIA APPROACH OF THE NATIONAL ROMA STRATEGIC FRAMEWORK (NRSF) Strategy for the continuation of Roma inclusion in Austria (07-04-2021, extending the ongoing strategy of 28-06-2017 to the end of 2023) ESTIMATED ROMA POPULATION Council of Europe estimates (plus national census data, where available) CoE estimate (2012): 35,000; 0.42% of total population National Roma Contact Point (NRCP) Austrian Federal Chancellery NATIONAL ROMA CONTACT POINT KEY FEATURES AREAS FOR IMPROVEMENT The NCRP has a staff of two persons. Its institutional role as part of the Austrian Federal Chancellery is to coordinate with ministries and other stakeholders with regard to the implementation and monitoring of Roma equality and inclusion measures and to contribute to mainstreaming Roma equality and inclusion in relevant sectoral policies. Dialogue with civil society is facilitated through a National Roma Platform supported with EU funding. The NRCP follows national strategies, policies and processes in relevant fields and liaises with line ministries and public authorities to ensure that specific needs and challenges faced by Roma people are explicitly addressed in mainstream policies. An external evaluation of the ongoing strategy was carried out in the course of 2022, and published on 4 October 2022. HORIZONTAL OBJECTIVES 1.FIGHT AND PREVENT ANTIGYPSYISM AND DISCRIMINATION 1A. FIGHTING DISCRIMINATION, HARASSMENT, HATE CRIME AND HATE SPEECH AGAINST ROMA KEY FEATURES AREAS FOR IMPROVEMENT The NRSF defines the fight against antigypsyism as one of seven priority objectives, linking it to five qualitative targets. Measures in this area include conferences and workshops, as well as anti-discrimination training for future police officers. Racist and xenophobic motivations of criminal acts are recognised by law as an aggravating circumstance. Specific measures in this area include monitoring and recording of such crimes. Qualitative targets include a strengthened awareness and sensitisation of majority society, including public servants and media representatives, enabling Roma, in particular Roma youth, to access the media-related labour market, and the professionalization of the media and public relations work of Roma Civil Society Organisations (CSOs). More focus could be given to victims' support, to preventing and combating anti-Roma hate speech and hate crime, as well as to addressing multiple and structural discrimination. Baselines, targets and indicators could be defined more closely in line with EU level objectives and targets. 1B. PROMOTING AWARENESS OF ROMA HISTORY, CULTURE, RECOGNITION AND RECONCILIATION KEY FEATURES AREAS FOR IMPROVEMENT Measures include the creation and continuation of museum exhibitions as well as education modules on Roma culture and history, Roma and Sinti celebration and commemoration events, development and dissemination of teaching materials on Roma history in several languages including Romani, and the embedding of the non-discrimination principle in teacher training. The NRCP also supports a school mediation CSO project raising awareness about Roma culture and history, facilitating dialogue and communication between teachers, pupils and parents, and assisting parents in educational matters. More focus could be given to promoting positive narratives about Roma and Roma role models in mainstream society and Roma communities, in order to foster a better understanding of the challenges faced by Roma and to inspire Roma youth. 1. 2.REDUCE POVERTY AND SOCIAL EXCLUSION KEY FEATURES AREAS FOR IMPROVEMENT In this area, the NRSF focuses on mainstream policies and schemes, as well as on targeted sectoral measures, in particular in the area of education as the basis for inclusion and labour market access. A qualitative target is included on ensuring that Roma with low income are not put at existential risk. More explicit focus could be given to ensuring effective equal access for Roma to mainstream social protection safety nets. Baselines, targets and indicators could be defined more closely in line with EU level objectives and targets.



3.PROMOTE PARTICIPATION THROUGH EMPOWERMENT, COOPERATION AND TRUST KEY FEATURES AREAS FOR IMPROVEMENT The NRSF includes Roma participation among its seven objectives. Measures include regular National Roma Platform meetings, exchanges with civil society on annually changing themes through regular expert workshops, and regular communication with CSOs through e-mail distribution lists. The NRSF includes a specific objective on Roma women and girls, and an objective on empowering Roma youth. Qualitative targets include empowerment and equal participation opportunities for Roma women and girls in all social spheres, strengthening civil society organisations, and empowerment of Roma youth. Baselines, targets and indicators could be defined more closely in line with EU level objectives and targets. SECTORAL OBJECTIVES KEY FEATURES AREAS FOR IMPROVEMENT 4.INCREASE EFFECTIVE EQUAL ACCESS TO QUALITY INCLUSIVE MAINSTREAM EDUCATION The NRSF includes measures targeting all young people with a migrant background or a weak socio-economic background, such as promotion of early childhood education and care, facilitating the transition from early childhood education to primary school, language learning as well as counselling and support to prevent early school leaving and facilitate the transition from education to employment. Targeted measures include bilingual and native language education in Burgenland, involvement of Roma civil society in the work of the Forum on Minority Schools, development of specific mediation capacities in schools, as well as involvement of parents and Roma civil society in mediation and counselling efforts. The NRSF defines qualitative targets such as strengthening equal opportunities and gender equality in education, increased participation in early childhood education and care, higher educational achievements of disadvantaged groups, and a reduction in early school leaving. Targeted support measures – such as school mediation, assistance to parents, bilingual and native language education – could be scaled up and replicated. 5.INCREASE EFFECTIVE EQUAL ACCESS TO QUALITY AND SUSTAINABLE EMPLOYMENT Targeted measures to promote access for Roma to the labour market include continuing education – such as language and literacy courses, and qualification measures – as well as job counselling, coaching, and infotainment events. The NRSF also includes awareness-raising actions aimed at employers, trade unions, teachers and media, as well as job counselling for young Roma. The NRSF includes qualitative targets, such as better access to the labour market and reduction of obstacles, as well as ensuring that Roma with low income are not put at existential risk. In the post-2023 NRSF, baselines and targets could be defined closely in line with EU level objectives and targets, while making a best use of the EU portfolio of indicators. Further focus could be given to ensuring effective and equal access for Roma women to employment and addressing the gender employment gap among Roma. 6.IMPROVE ROMA HEALTH AND EFFECTIVE EQUAL ACCESS TO QUALITY HEALTHCARE AND SOCIAL SERVICES Overall, Austria has a well-functioning health system, with near universal health insurance coverage. The NRSF sets out the objective of ensuring discrimination-free access for Roma to education, employment, health and housing in general terms. It refers to inclusive mainstream health policies taking into account the needs of Roma and aiming to support access to healthcare for disadvantaged groups. Some measures contribute to health objectives, such as the introduction of low-threshold health and social counselling services for Roma women and girls. The NRSF does not contain a specific objective or set of measures concerning the health sector. The post-2023 NRSF should address the area of health policy through setting out a specific objective and measures to improve the health situation of Roma people and ensure their effective equal access to healthcare, while taking into account the needs of specific groups within the Roma population, including women and children, supported by adequate data. In the post-2023 NRSF, baselines and targets could be defined closely in line with EU level objectives and targets, while making a best use of the EU portfolio of indicators. 7.INCREASE EFFECTIVE EQUAL ACCESS TO ADEQUATE DESEGREGATED HOUSING AND ESSENTIAL SERVICES The NRSF refers to mainstream inclusive housing policies taking into account the needs of Roma and aiming to support access to housing for disadvantaged groups. The NRSF doesn’t contain a specific objective or set of measures to ensure effective equal access of Roma to housing. The post-2023 NRSF should address the area of housing through setting out a specific objective and measures to ensure effective equal access of Roma to housing, based on a comprehensive needs assessment and adequate data. Baselines and targets could be defined closely in line with EU level objectives and targets, while making a best use of the EU portfolio of indicators. MONITORING FRAMEWORK KEY FEATURES AREAS FOR IMPROVEMENT BASELINE The NRSF does not define baselines. In the post-2023 NRSF, national baselines could be defined towards the EU Roma Framework’s objectives and targets. TARGETS The NRSF defines qualitative targets in several areas; however, these are not closely linked to EU level targets. National targets could be defined more closely in line with EU Roma Framework’s objectives and targets, based on a comprehensive needs assessment. INDICATORS The NRSF does not define indicators. Indicators could be defined closely in line with the EU level targets, building on the EU portfolio of indicators.

OTHER ELEMENTS KEY FEATURES AREAS FOR IMPROVEMENT PARTICIPATION OF KEY STAKEHOLDERS (NRCP, National Roma Platform, national, regional and local CSOs, equality bodies) Since 2012, the NRCP has been organising regular meetings of the National Roma Platform to contribute to monitoring and reviewing the implementation of national Roma strategy as well as of ongoing policies of relevance and further contribute to the adjustment or development of new measures. Regular thematic workshops are also conducted. The National Roma Platform includes representatives of Roma civil society, line ministries and local authorities. The NRSF aims to further strengthen links between the Platform and local integration fora. While the ongoing NRSF does not explicitly refer to the involvement of the equality body for equal treatment, the post-2023 NRSF could indicate specifically the nature and level of involvement of the equality body. MAINSTREAMING OF ROMA EQUALITY AND INCLUSION AT THE NATIONAL LEVEL AND CONNECTION WITH OTHER RELEVANT EU INITIATIVES & DIVERSITY CONSIDERATIONS To ensure the link with mainstream sectoral policies, the NRCP follows relevant policies and processes and contributes to addressing Roma specific challenges both through mainstream and targeted measures. The NRSF refers to relevant EU initiatives in some areas, such as Erasmus+ and the Youth in Action programme. Empowerment of Roma women, girls and youth are included as priority objectives in the NRSF and connected to specific measures, such as an edition of the National Roma Platform dedicated to youth empowerment, as well as a Girls Week implemented by a CSO. A stronger focus could be given to addressing the needs of specific groups, in particular Roma women and girls, in sectoral policy areas such as health, including by investing in capacity building of Roma women and youth and of their civil society organisations. F U N D I N G CONNECTION WITH EU FUNDING PROGRAMMES (instruments) Actions funded under the ESF 2014-2020 include targeted measures to promote access of Roma to employment (with a total budget of EUR 8 million), as well as mainstream measures explicitly including Roma among the target groups in the areas of education and social inclusion. It could be further clarified to what extent Roma and pro-Roma civil society participates in the preparation, implementation, monitoring and evaluation of programmes. OTHER SOURCES OF FUNDING The NRSF refers to measures funded by federal ministries, provinces and municipalities, but does not specify amounts. As of 2021, the federal budget for national minorities allocated by the Federal Chancellery was more than doubled. It could be clarified further which share of the national funding instruments referred to in the NRSF will benefit Roma equality and inclusion. PROMISING PRACTICES /APPROACHES FOR COUNTRY-TO-COUNTRY LEARNING The Austrian National Roma Platform, which has been meeting regularly since 2012 and contributes to monitoring and reviewing the implementation of the national strategy and relevant policies, as well as to the development of new measures, can be highlighted as a positive example of a national dialogue process. The Roma school mediation project, which includes actions to raise awareness about Roma culture and history, facilitate dialogue and communication between teachers, pupils and parents, and assist parents in educational matters, can be highlighted as a positive example. Bilingual and native language education activities for Roma pupils that are implemented regionally appear promising and could be further scaled up. BELGIUM APPROACH OF THE NATIONAL ROMA STRATEGIC FRAMEWORK (NRSF) National strategy for Roma integration 2021-2030 ESTIMATED ROMA POPULATION Council of Europe estimates (plus national census data, where available) CoE estimate (2012): 30,000; 0.29% of total population National Roma Contact Point (NRCP) Anti-poverty department of the Federal Public Service for Social Integration KEY FEATURES AREAS FOR IMPROVEMENT HORIZONTAL OBJECTIVES 1.FIGHT AND PREVENT ANTIGYPSYISM AND DISCRIMINATION 1A. FIGHTING DISCRIMINATION, HARASSMENT, HATE CRIME AND HATE SPEECH AGAINST ROMA KEY FEATURES AREAS FOR IMPROVEMENT The NRSF articulates the fight against discrimination and antigypsyism around awareness-raising among the Roma people of the equality body to ensure reporting of hate speech and hate crime, and promotion of positive narratives about Roma. At national level, the NRSF is linked with the National Action Plan against Racism (NAPAR) currently being developed. A number of proposals for actions will be integrated into the NRSF once the negotiations on NAPAR have been concluded. Following the “Conference to Combat Racism” held in 2021-2022 in the Brussels Parliament, 207 recommendations were issued to the Brussels Government, amongst which specific recommendations for Roma. As a follow-up, the NRSF proposes an action in Brussels, aiming at analysing how recommendations issued in particular to tackle challenges faced by Roma can be implemented. One of these recommendations is about emphasising the need for specific training and meetings, in particular with the equality body. The Brussels anti-racism action plan is being drawn up on these bases. Flanders, Wallonia, and the German-speaking community are also involved in the development of the national anti-racism action plan. The NRSF mentions equality bodies and data collection but more concrete measures could be proposed to develop baselines. It remains to be seen, once the Belgian action plan against racism is adopted, how hate crime, and hate speech offline and online against Roma will be addressed and integrated into the current NRSF. 1B. PROMOTING AWARENESS OF ROMA HISTORY, CULTURE, RECOGNITION AND RECONCILIATION KEY FEATURES AREAS FOR IMPROVEMENT Actions such as the exhibition “Reflections: Roma in Belgium” can be continued and expanded to reach the broadest audience possible. 2.REDUCE POVERTY AND SOCIAL EXCLUSION KEY FEATURES AREAS FOR IMPROVEMENT The NRSF proposes mainstream inclusion plans (for migrants and foreigners in Wallonia) and mediation. Policy interventions in the fight against poverty lie at the intersection of different policy areas such as employment, housing, education and health. Consultation forums on combatting poverty and social exclusion –also tackling the aspect of Roma inclusion– are organised through open platforms which meet several times a year at the initiative of the SPP Social Integration. The NRSF does not mention any target for this objective, nor the use of indicators. 3.PROMOTE PARTICIPATION THROUGH EMPOWERMENT, COOPERATION AND TRUST KEY FEATURES AREAS FOR IMPROVEMENT Besides the National Roma Platform at federal level, the NRSF lists regional supports in Wallonia, Brussels, Flanders, and the German-speaking community, which focus mainly on supporting inclusion via language courses and cultural activities for Roma and Travellers, and via intercultural mediators, as is the case in Flanders and Brussels through the non-profit organisation ‘le Foyer’, subsidised by the Common Community Commission (COCOM). In Wallonia, the French Community Commission (COCOF) promotes the social and socio-professional projects of Travellers and encourages citizens’ participation by Travellers and their associations. Although the NRCP is composed of institutional representatives of regional level of competences the articulation of the coordination of the strategy and of the National Roma Platform is not clear from the NRSF. The NRSF does not determine how Roma civil society will contribute to the monitoring and evaluation of the actions proposed in the strategy. SECTORAL OBJECTIVES KEY FEATURES AREAS FOR IMPROVEMENT 4.INCREASE EFFECTIVE EQUAL ACCESS TO QUALITY INCLUSIVE MAINSTREAM EDUCATION Education is a community-level competence in Belgium. Therefore, the measures vary according to the region/community. The Roma and “Gens du voyage” Service of the “Foyer” organisation, supported by the Flemish Community Commission aims to promote the schooling of Roma children. To this end, they work on: awareness raising, guidance, enrolment, school mediation, increasing parental participation and supporting teachers and pupils. Mainstream measures include the “Fight against school failure” subsidised by the Wallonia-Brussels Federation, and the support for migrant and asylum-seekers in the German-speaking community. 5.INCREASE EFFECTIVE EQUAL ACCESS TO QUALITY AND SUSTAINABLE EMPLOYMENT The NRSF mentions several awareness and activation programmes launched under the “ESF 457 Awareness and Activation call”, either targeted for Roma, or more generic in Flanders, and the continuation of the job search service provided by the “Centre de Mediation des Gens du Voyage et des Roms” in Wallonia. The current call for Roma@work runs until 31 December 2022 and is extended for the year 2023. A grant of EUR 161,000 is awarded for the year 2022. The German-speaking community ensures equal access to activation programmes, such as “AktiF and AktiF-Plus”. The NRSF does not address the significant gender gap in employment in the Roma population. 6.IMPROVE ROMA HEALTH AND EFFECTIVE EQUAL ACCESS TO QUALITY HEALTHCARE AND SOCIAL SERVICES In the Brussels region, the Flemish Community Commission (COCOM) has collaborated with the National Roma Platform to inform Roma mediators on access to healthcare. The specific challenges of the Travellers, otherwise covered under other objectives, are not mentioned under this objective in the NRSF, nor is there any mention of specific health challenges of women, in relation to reproductive health for example. 7.INCREASE EFFECTIVE EQUAL ACCESS TO ADEQUATE DESEGREGATED HOUSING AND ESSENTIAL SERVICES MONITORING FRAMEWORK KEY FEATURES AREAS FOR IMPROVEMENT BASELINE The NRSF does not set up any other baseline than the FRA Survey. TARGETS Targets could be defined more closely in line with the EU Roma Framework’s objectives and targets. INDICATORS The NRSF uses qualitative national indicators. Indicators could be defined closely in line with the EU level targets, building on the EU portfolio of indicators. OTHER ELEMENTS KEY FEATURES AREAS FOR IMPROVEMENT PARTICIPATION OF KEY STAKEHOLDERS (NRCP, National Roma Platform, national, regional and local CSOs, equality bodies) The NRSF does not provide information on how the NRCP will cooperate with the local and regional authorities. MAINSTREAMING OF ROMA EQUALITY AND INCLUSION AT THE NATIONAL LEVEL AND CONNECTION WITH OTHER RELEVANT EU INITIATIVES & DIVERSITY CONSIDERATIONS The National Action Plan for the Belgian Child Guarantee is mentioned in the NRSF as paying special attention to the needs of Roma and Travellers children. The NRSF mentions being in line with the Commission’s work in other areas, such as the EU Anti-Racism Action Plan 2020-2025, the Victims’ Rights Strategy, the EU Gender Equality Strategy, and the UN Sustainable Development Goals.



The NRSF takes into account specific needs of different groups such as the EU mobile Roma. F U N D I N G CONNECTION WITH EU FUNDING PROGRAMMES (instruments) OTHER SOURCES OF FUNDING Flemish authorities and VDAB Brussels. Funds mobilised through the Decree of the Walloon Government of 18 July 2019 inserting provisions on assistance to Travellers in the Walloon Regulatory Code for Social Action and Health. PROMISING PRACTICES /APPROACHES FOR COUNTRY-TO-COUNTRY LEARNING The diversity of the Roma population is reflected and taken into account through the specific support for the Travellers, in particular in relation to education. The subsidies programme for municipalities to welcome Travellers in Wallonia can be a good practice which deserves to be further expanded.





BULGARIA APPROACH OF THE NATIONAL ROMA STRATEGIC FRAMEWORK (NRSF) National Strategy of the Republic of Bulgaria for Equality, Inclusion and Participation of the Roma (2021-2030) National Action Plan for the period 2022-2023 ESTIMATED ROMA POPULATION Council of Europe estimates (plus national census data, where available) CoE estimate (2012) : 750,000; 9.94% of total population National census (2021): 266,720 In line with the EU Roma Framework’s common but differentiated approach, this Member State was invited to make more ambitious commitments to Roma equality, inclusion and participation than other Member States. National Roma Contact Point (NRCP) Secretariat of the National Council for Cooperation on Ethnic and Integration Issues. NATIONAL ROMA CONTACT POINT KEY FEATURES AREAS FOR IMPROVEMENT Under the administration of the Council of Ministers, the NRCP has a staff of four persons. With an annual budget up to BGN 60,000 (ca. EUR 30,000), it is equipped with a mandate to monitor the implementation of Roma-related measures and report progress to the National Council. It acts as a coordinating structure of activities at national level in the formulation, implementation, monitoring and evaluation of integration policy. A mechanism for inter-institutional coordination with line ministries and agencies has been established. Line ministries report annually to NRCP their progress on implementing Roma-related measures via the System for Monitoring, Evaluation and Control.



The NRCP takes part in the work structures for programming and implementation of EU Partnership Agreement with Bulgaria and programmes of EU structural funds for 2021-2027 and is part of their monitoring committees. The NRSF could have indicated more clearly whether the capacity of the NRCP will be further strengthened, as proposed by the Council Recommendation. There are no indications whether the T.E.A.M 3 project ongoing until 2023, which supports the National Roma Platform (NRP) will be continued from national sources to retain this level of institutional capacity, or whether the NRP will be reformed in any way. HORIZONTAL OBJECTIVES 1.FIGHT AND PREVENT ANTIGYPSYISM AND DISCRIMINATION 1A. FIGHTING DISCRIMINATION, HARASSMENT, HATE CRIME AND HATE SPEECH AGAINST ROMA KEY FEATURES AREAS FOR IMPROVEMENT The NRSF includes the horizontal objective “Effective equality: Fight to prevent manifestations of anti-Roma attitudes and discrimination against the Roma in general”. The Action Plan’s operational goal focuses on guaranteeing the rights of citizens, with an emphasis on women and children, protection of public order, prevention and counteraction to the manifestations of intolerance and hate speech. Measures include: strengthening of inter-institutional dialogue and co-operation to support minors at risk; training of police officers to work with victims of violence; solving the problem with the lack of identity documents for vulnerable communities, including Roma. The Action Plan includes output indicators on numbers for all objectives (e.g. number of participants, beneficiaries, number of activities, events, projects). The NRSF sets national targets that cover issues addressed by the EU level targets as included in the EU Roma Framework on cutting the proportion of Roma with discrimination experience by at least half. The NRSF does not make references to antigypsyism specifically but to anti-Roma attitudes. While the aspects of hate speech and hate crime are included, the proposed measures lack in ambition. There are no measures specified addressing the aspect of structural and multiple discrimination. Measures on anti-discrimination are rather weak, lack in ambition and focus mainly on awareness raising activities. The NRSF include only output indicators (number of persons), which will make it more difficult to measure the outcomes of the implemented measures. 1B. PROMOTING AWARENESS OF ROMA HISTORY, CULTURE, RECOGNITION AND RECONCILIATION KEY FEATURES AREAS FOR IMPROVEMENT Under its objective on Culture and Media, the NRSF includes the operational goal: Improving the conditions for equal access of the Roma community to public cultural life, preservation and promotion of Roma traditional culture, development and promotion of creativity as factors for cultural integration and social cohesion. The operation goal includes measures aimed at preservation and promotion of the traditional culture of the Roma community; stimulating the Roma community to actively participate in public cultural life and promoting intercultural dialogue; de-ethnicisation of the phenomena of poverty in the Bulgarian public media. Although the NRSF includes an objective on culture and media, underlining the crucial role of the media in reducing anti-Roma attitudes, and has set out under its operational goals to fight against xenophobia, racism, anti-Roma attitudes and hate speech in the media, as well as the preservation and promotion of Roma traditional culture, the Action Plan lacks specific measures to implement activities in this area. Measuring progress in these areas may prove to be difficult. Targeted measures to promote representation of Roma and their participation through radio and television broadcasts are lacking, as well as measures to promote positive narratives about Roma and Roma role models. 2.REDUCE POVERTY AND SOCIAL EXCLUSION KEY FEATURES AREAS FOR IMPROVEMENT The NRSF includes the horizontal objective “Socio-economic inclusion: Reduction of poverty and social exclusion and elimination of socio-economic differences between the Roma and the rest of the Bulgarian society”. While socio-economic inclusion is not being covered distinctly under this horizontal objective, it is addressed across sectoral priorities on employment, health, rule of law and anti-discrimination, and housing conditions. The NRSF includes national targets responding to the EU level target included in the Framework (cutting the poverty gap between Roma and general population by at least half, and cutting the poverty gap between Roma children and other children by at least half.) Although the NRSF mentions the issue of poverty extensively and has set targeted measures to reduce poverty and address social exclusion, they are insufficiently developed. Given the large number of Bulgarian Roma living in extreme poverty, as acknowledged in the strategy, a solid poverty-reduction package of measures should be developed and implemented, making a best use of EU funding. The baseline for used indicators is 2019. The values can be updated with 2020 data from FRA/BNSI survey (data available). 3.PROMOTE PARTICIPATION THROUGH EMPOWERMENT, COOPERATION AND TRUST KEY FEATURES AREAS FOR IMPROVEMENT The NRSF includes the horizontal objective “Significant participation: Encouraging participation through empowerment, cooperation and trust.” It has a dedicated section on Roma women with a focus on promoting their equality and participation in public life. The NRSF sets a national target (doubling the proportion of Roma who file a report when they experience discrimination) responding to the EU level target included in the Framework. Although participation is mentioned throughout the NRSF and Action Plan, it is not set as a distinct area for action. The NRSF lacks targeted measures to support empowerment, capacity building and meaningful participation of Roma. SECTORAL OBJECTIVES KEY FEATURES AREAS FOR IMPROVEMENT 4.INCREASE EFFECTIVE EQUAL ACCESS TO QUALITY INCLUSIVE MAINSTREAM EDUCATION The NRSF includes the objective “Increasing effective access to quality inclusive education”, detailing measures in the Action Plan. Each of the sectoral objectives include priorities and general objectives. Measures focus on creating conditions for the implementation of quality and inclusive education, including for vulnerable groups, and Roma; educational desegregation and prevention of secondary segregation, and work with parents. The NRSF includes a number of education-related indicators with baselines and national targets responding to the following EU level target included in the Framework: -cut the gap in participation in early childhood education and care by at least half; -reduce the gap in upper secondary completion by at least one third; -work towards eliminating segregation by cutting at least in half the proportion of Roma children attending segregated primary schools (in Member States with significant Roma population). While the NRSF often refers to existing mainstream frameworks and horizontal measures addressed to all students and children, it lacks specific targeting of Roma. There are no measures to support the engagement of more Roma teachers and education mediators in schools with a larger number of Roma children. The baseline for some of the indicators is rather outdated (2019), and uses target values at the level of the whole population, lacking specific values about Roma. The values can be updated with 2020 data from FRA/BNSI survey (data available). 5.INCREASE EFFECTIVE EQUAL ACCESS TO QUALITY AND SUSTAINABLE EMPLOYMENT The NRSF includes the objective “Increasing effective access to quality and sustainable employment” detailing measures in the Action Plan’s operational goal on equal access of Roma on the labour market, reduction of social inequalities and active social inclusion. Measures include: promoting employment through vocational guidance and training of unemployed; provision of employment, including through entrepreneurship for Roma. The NRSF includes employment-related indicators with baselines and targets responding to the EU level target included in the Framework (cut employment gap by at least half; cut gap in NEET rate by at least half; cut gender employment gap for Roma by at least half). NRSF and Action Plan indicate mainly mainstream programmes and measures, lacking details of how they will be applied to Roma. Measures to address discrimination in accessing employment are not sufficiently articulated. Most of the used indicators do not seem to be Roma specific but indicators covering the whole population. 6.IMPROVE ROMA HEALTH AND EFFECTIVE EQUAL ACCESS TO QUALITY HEALTHCARE AND SOCIAL SERVICES The NRSF includes the objective “Improving the health status of the Roma and increasing the effective access to quality health and social services”. Measures under this objective are detailed in the Action Plan’s operational goal on ensuring equal access to quality public health and improving the health of the population in vulnerable communities, with a concentration of poverty. Measures include: improving maternal and child health in vulnerable communities; reducing stigma and discrimination against people from vulnerable groups; implementation of protection against vaccine-preventable infectious diseases, training of health mediators. The NRSF includes a number of health-related indicators with baselines and targets (Cut life expectancy gap by at least half) responding to the EU level target included in the EU Roma Framework. Although the set measures cover a wide range of health-related areas and needs, the action plan lacks specific measures to address discrimination and obstacles limiting access of Roma to health care services. A mainstream indicator of life expectancy is used in the NRSF, however, it is not mentioned in the Action Plan. 7.INCREASE EFFECTIVE EQUAL ACCESS TO ADEQUATE DESEGREGATED HOUSING AND ESSENTIAL SERVICES The NRSF includes the objective “Increasing effective access to adequate desegregated housing and basic services”. The Action Plan’s operational goal focuses on improving housing conditions, including adjacent technical and public service infrastructure. Measures for this objective include: establishment of a working mechanism for evaluation of the housing stock in areas with compact Roma population; providing support under priority “Housing Conditions” to fifty urban municipalities in the country; providing conditions for the acquisition of affordable housing and introduction of alternative models of social housing for households in poverty areas; adopting an Act amending the Spatial Planning Act to introduce the principle of proportionality in issuing an order for the removal of illegal construction; expanding access to quality water, electricity and sewerage in separate neighbourhoods. The NRSF includes a number of housing-related indicators with baselines and targets responding to the EU level headline targets included in the EU Roma Framework (reduce gap in housing deprivation by at least one third; cut gap in overcrowding by at least half; ensure that at least 95 % of Roma have access to tap water). The NRSF does not include a solid dimension on provision of social housing for vulnerable Roma. The NRSF and action plan lack concrete measures to address the issue of housing segregation of Roma. It does not include specific desegregation measures. MONITORING FRAMEWORK KEY FEATURES AREAS FOR IMPROVEMENT BASELINE The NRSF includes a baseline and measurable targets. Data on implementation of the Strategy is also collected on a territorial basis for settlements with a concentration of poverty. The NRSF uses data as produced by the National Statistical Institute.

The NRSF refers to a System for monitoring, evaluation and control of the implementation of the strategy, including at regional and local level. Although the NRSF refers to the existence of a baseline, the word itself appear only few times through the NRSF and Action Plan. Moreover, sources of data are lacking from the Action Plan. It is not sufficiently clear which are the values provided for baselines or targets, except the sources included in the appendix of indicators for monitoring, which are (National Statistics Institute) NSI, BG-SILC, and one survey. TARGETS The annex “Indicators for monitoring the implementation of the National Strategy of the Republic of Bulgaria for Equality, Inclusion and Roma Participation (2021-2030)” contains a list of indicators with quantitative targets for EU Roma Framework’s objectives. The NRSF sets out baselines and targets based on a description of the situation. Most targets set in the NRSF respond to the EU level targets included in the Framework. While the NRSF states the magnitude of the challenges affecting Roma, it is not sufficiently clear on the sources and level of resources projected to address them. The link between the measures and targets is rather weak. Targets contained in the Strategy’s Annex of indicators for monitoring are not included in the Action Plan. The Action Plan includes target values which are outputs of measures that are not linked directly to the targets contained in the Annex. More consistent and substantial usage of data should be considered in the next revision of the NRSF and its Action Plan. INDICATORS The NRSF provides in an Annex a list of indicators for monitoring implementation of the strategy, linked with targets. Although the indicators in the NRSF Annex are linked to quantitative targets, the indicators included in the Action Plan are only connected to measures and not to targets, and are input indicators (number of reports, meetings, participants, plans, etc.). Moreover, many of the indicators are at the level of the general population and seem to be outdated (2019). Values can be updated with 2020 data from FRA/BNSI survey. Improvements are needed regarding indicators and their correlation with baselines and targets, while more efforts should be made to develop Roma specific indicators. OTHER ELEMENTS KEY FEATURES AREAS FOR IMPROVEMENT PARTICIPATION OF KEY STAKEHOLDERS (NRCP, National Roma Platform, national, regional and local CSOs, equality bodies) The NRSF includes a number of measures aimed at promoting participation of Roma as well as facilitating co-operation between NRCP, the Roma civil society and other relevant stakeholders. Cooperation with the Roma civil society and all other relevant stakeholders is envisaged through the formation of advisory councils and civic monitoring, including of young people and Roma women; establishment of a Council for monitoring the implementation of the strategy; collection, systematisation and analysis of information on good practices for monitoring of sectoral policies. The NRSF dedicates a section for empowerment and equal opportunities for Roma women. The NRSF does not make sufficient references to the involvement of the equality body. The National Roma Platform is mentioned mainly in the context of co-operation with the government in the development of the strategy. No other references are made to engagement with Roma organizations during implementation, or for monitoring, evaluation and reporting of the NRSF. While NRSF refers to capacity building of Roma organisations, the Action Plan is missing measures in this regard. The NRSF refers in its national context and analysis section to the need for institutions to step up efforts to combat discrimination, hate speech and hate crimes, however, objectives and measures in this regard are not sufficiently articulated. Plans in this area are unclear, which will make measuring of progress difficult. MAINSTREAMING OF ROMA EQUALITY AND INCLUSION AT THE NATIONAL LEVEL AND CONNECTION WITH OTHER RELEVANT EU INITIATIVES & DIVERSITY CONSIDERATIONS The strategy follows an approach based on the development of common policies (mainstream) with the implementation of targeted measures by sector, especially at local level. The targeted approach is designed to compensate for inequalities. The NRSF mentions the importance of targeted support for marginalised groups such as the Roma, underlining the fact that Roma are a potential force for the labour market, and that the implementation of its measures will contribute to the indicators of various mainstream priorities and programmes. The NRSF does not provide clear indications about how Roma issues are specifically mainstreamed in the public policies, and extent to which Roma will benefit of them. F U N D I N G CONNECTION WITH EU FUNDING PROGRAMMES (instruments) The NRSF relies on coherence between EU funding instruments, e.g. Europe 2020, cohesion policy funds and complementarity with other strategic documents and national programs. NRSF measures are built on the basis of use of resources at national, regional and local level, as well as those at European level (e.g. accessing funds of the EU for the programming period 2021-2027). The NRSF indicates that Bulgaria will receive funds from ESF+, the “Human Resources Development” Programme, the “Food and Basic Material Support” Programme and the Programme “Education”, as well as the ERDF. While the NRSF indicates a number of measures as being funded under EU cohesion policy funds, and European Economic Area Financial Mechanism (EEA FM) 2014-2021, it is not clear whether those funds will be continued beyond their announced timeframe, or continued through other programmes, either EU or state-funded. OTHER SOURCES OF FUNDING State budget; municipal budgets; Norwegian Financial Mechanism (NFM) 2014-2021; other donor programs. Financial resources mentioned in the Action Plan are only indicative for now, and their quantum remains to be confirmed later, during the implementation process, depending on approved budgets per institution and municipality. PROMISING PRACTICES /APPROACHES FOR COUNTRY-TO-COUNTRY LEARNING Young unemployed under the age of 29 (among them Roma) are one of the priority target groups of mainstream active labour market policies. Early support to young people will be provided through the implementation of the new EU Council Recommendation “Job to Jobs - Strengthening the Youth Guarantee”. With a view to expanding its network of health mediators appointed on a delegated budget, the Ministry of Health has adopted the Ordinance No 1/19.07.2020 on the requirements for the activity of health mediators. The measure was taken in order to overcome an existing risk of uneven distribution of mediators due to a possible lack of appointment of health mediators by targeted municipal administrators and to ensure that concerned neighbourhoods will not be left without health mediators. CROATIA APPROACH OF THE NATIONAL ROMA STRATEGIC FRAMEWORK (NRSF) National Plan for Roma Inclusion 2021-2027 Action Plan ESTIMATED ROMA POPULATION Council of Europe estimates (plus national census data, where available) CoE estimate (2012): 35,000; 0.79% of total population National census data (2017): 24,524 National Roma Contact Point (NRCP) Office for Human Rights and Rights of National Minorities of the Government of the Republic of Croatia NATIONAL ROMA CONTACT POINT KEY FEATURES AREAS FOR IMPROVEMENT The NRCP has resources, staff capacity and institutional authority in order to effectively coordinate efforts with the line ministries and relevant authorities and monitor implementation of national policies for Roma equality inclusion and participation, including outreach at local level. A Commission was established for Monitoring the Implementation of the National Roma Program. The NRCP is involved in the coordination of cross-governmental discussions on the distribution of EU funds for Roma, and in systematic monitoring of their use. Roma were involved in the drafting of the National Roma Programme with a focus on childcare, employment, social welfare, protection of families, motherhood and youth, physical planning and others. The capacity of the Roma Civil society is very limited and needs substantial investment and empowerment.

HORIZONTAL OBJECTIVES 1.FIGHT AND PREVENT ANTIGYPSYISM AND DISCRIMINATION 1A. FIGHTING DISCRIMINATION, HARASSMENT, HATE CRIME AND HATE SPEECH AGAINST ROMA KEY FEATURES AREAS FOR IMPROVEMENT The NRSF contains measures, indicators and data used to measure progress in the horizontal objective of combatting anti-Roma racism and discrimination. Specific measures provide for reducing the number of Roma who have experienced discrimination and hate crime and fostering integration processes and strengthening social cohesion between the Roma and the majority population. Related activities include promoting a comprehensive system of support and assistance to victims of discrimination and hate crimes, promoting positive speech about Roma, as well as raising awareness of Roma cultures, language and between the Roma and majority population. The NRSF sets national targets responding to the EU level target included in the Framework (cut the proportion of Roma with discrimination experience by at least half; and decrease the proportion of general population who feel uncomfortable having Roma neighbours by at least a third). The effective practical enforcement of antidiscrimination legislation to combat anti-Roma manifestations is not properly presented in the strategy. 1B. PROMOTING AWARENESS OF ROMA HISTORY, CULTURE, RECOGNITION AND RECONCILIATION KEY FEATURES AREAS FOR IMPROVEMENT The NRSF includes activities aimed at raising awareness on Roma cultures, language and history, including remembrance of Roma victims of the Holocaust and reconciliation processes, including the provision of appropriate teacher training and the development of an appropriate school curriculum, considering that such awareness is key to reducing prejudice and anti-Romani sentiment. Promotion of positive narratives about Roma and Roma role models could be envisaged at a larger scale. The strategy does not present foreseeable actions for the recognition at national level of the Holocaust Memorial Day. 2.REDUCE POVERTY AND SOCIAL EXCLUSION KEY FEATURES AREAS FOR IMPROVEMENT In order to reduce poverty and social exclusion, the NRSF foresees activities combining income support and incentives to promote labour market participation as well as supporting financial literacy for young adults. The Plan focuses particularly on combatting and preventing child poverty by co-financing access to basic services, education, nutrition and leisure activities. Targets, aligned with EU targets, include reducing the share of Roma at risk of poverty from 93% to under 15% and the share of Roma children from 95% to less than 50%. The NRSF sets national targets responding to the EU level target included in the Framework (Cut poverty gap between Roma and general population by at least half; and cut poverty gap between Roma children and other children by at least half). 3.PROMOTE PARTICIPATION THROUGH EMPOWERMENT, COOPERATION AND TRUST KEY FEATURES AREAS FOR IMPROVEMENT The Action Plan includes measures fostering active citizenship by promoting social, economic, political and cultural participation, including of women and young people in the Roma community, promoting capacity building of Roma civil society organisations, including Roma youth and women’s organisations, supporting the employment of professionals from the Roma community in public institutions to enhance diversity and expertise, and raising awareness of members of marginalised Roma communities about human rights and the rights and responsibilities of citizens. The NRSF sets national targets responding to the EU level targets included in the Framework (capacitate and engage at least 90 NGOs in EU wide coordinated Roma civil society monitoring; ensure participation of Roma NGOs as full members in national monitoring committees for all programmes addressing needs of Roma communities; double proportion of Roma who file a report when they experience discrimination; Encourage participation of Roma in political life at local, regional, national and EU levels). Roma civil society is rather weak and therefore specific measures to empower and build its capacity are necessary. This could be directly linked to a very low level of awareness of the Roma communities about the existing possibilities but also limited reach-out of the NRCP to these communities. SECTORAL OBJECTIVES KEY FEATURES AREAS FOR IMPROVEMENT 4.INCREASE EFFECTIVE EQUAL ACCESS TO QUALITY INCLUSIVE MAINSTREAM EDUCATION The Action Plan contains measures such as the development and dissemination of inclusive teaching through mentoring and mutual learning, the training of teaching staff on Roma history and culture, ensuring Roma pupils acquire skills in line with the labour market needs, investing in preschool education and reducing early school leaving with an emphasis on Roma girls and supporting the participation in extracurricular and well-being activities. Regarding the measures against segregation in education, these are strongly present at the level of early childhood education and care, while in later education there are mostly measures of additional support in education, scholarships and places in student accommodation, but not targeted ones for non-segregated classrooms. The NRSF sets national targets responding to the EU level targets included in the Framework (cut the gap in participation in early childhood education and care by at least half; reduce gap in upper secondary completion by at least one third; work towards eliminating segregation by cutting at least in half the proportion of Roma children attending segregated primary schools)although using country adaptations for the segregation target (covering only the county with largest Roma population) and for the upper secondary education (restriction in years covered by this level – four or five years of education). It defines baselines and target values for all of them. The NRSF uses all outcome indicators provided in the EU portfolio of indicators complemented by number of country-specific indicators. Values are provided only for the headline indicators. The NRSF (currently available for 2021-2022) includes also process indicators at the level of measures). There is a need to further develop and implement activities to promote the acquisition of digital skills, ensure broadband access, suitable digital infrastructure and the provision of teaching materials for distance learning, both in formal and non-formal education, for Roma students and their teachers, facilitators and parents, especially for people living in marginalised communities. 5.INCREASE EFFECTIVE EQUAL ACCESS TO QUALITY AND SUSTAINABLE EMPLOYMENT The NRSF includes specific measures such as promoting adult education, including Roma adults in literacy programmes, increasing the employability of Roma by providing them with new competences in demand on the labour market, promoting good practices and information provision to employers, including on Roma youth and women. The NRSF sets national targets responding to the EU level targets included in the Framework (cut employment gap by at least half; The activities included in the action plan in the area of employment are a combination of project-based and mainstream measures. In order to assess their cumulative efficiency and overall impact, a careful monitoring will be needed. 6.IMPROVE ROMA HEALTH AND EFFECTIVE EQUAL ACCESS TO QUALITY HEALTHCARE AND SOCIAL SERVICES The NRSF encourages activities aimed at strengthening the health of Roma people with special emphasis on women’s reproductive health, the achievement of the strategic objective “Healthy, active and quality life”, reducing the life expectancy gap between the Roma and the general population and increasing the awareness of the Roma population about gender-based violence health professionals and Roma communities. The NRSF sets a national target responding to the EU level target included in the Framework (cut life expectancy gap by at least half) The NRSF could include more targeted measures to train health staff on diversity and discriminatory bias. 7.INCREASE EFFECTIVE EQUAL ACCESS TO ADEQUATE DESEGREGATED HOUSING AND ESSENTIAL SERVICES The NRSF includes measures to improve equal access to social housing by adopting access criteria prioritising social needs, to ensure access to essential services, such as tap water, adequate sanitation and waste collection, to monitor, prevent and combat any spatial segregation, to prevent forced evictions by early warning and mediation, and to prevent and tackle the negative health impact of exposure to pollution and contamination. The NRSF sets national targets responding to the EU level targets included in the Framework (reduce gap in housing deprivation by at least one third; cut gap in overcrowding by at least half; ensure that at least 95 % of Roma have access to tap water) There are no specific actions foreseen to address the issue of the legality of Roma housing units. The NRSP and Action Plan could include more specific measures with regards to spatial desegregation, relocation of persons living in segregated settlements to mainstream non-segregated areas, social housing provided for these persons in non-segregated areas. The measures planned in this area do not include an allocated budget, indicative timelines and source of funding. MONITORING FRAMEWORK KEY FEATURES AREAS FOR IMPROVEMENT BASELINE The NRSF defines baselines for every indicator. TARGETS The NRSF sets qualitative and quantitative national targets responding to all the EU level targets included in the EU Roma Framework The Commission welcomes the effort invested in establishing a solid set of targets which aligns with the ambition set by the EU Roma Strategic Framework. INDICATORS The NRSF uses all indicators provided in the EU portfolio of indicators (headline and secondary) complemented by number of national indicators. The NRSF includes all indicators disaggregated by sex and age. OTHER ELEMENTS KEY FEATURES AREAS FOR IMPROVEMENT PARTICIPATION OF KEY STAKEHOLDERS (NRCP, National Roma Platform, national, regional and local CSOs, equality bodies) All state administration bodies and other public bodies are involved in drafting and monitoring the Action Plan. The ombudsperson’s institution play a central role, as well as civil society organisations, especially the national coordination of councils and representatives of the Roma National Minority Alliance. The Commission for the Monitoring of the National Plan for Roma Inclusion is composed of the Deputy Prime Minister, a Roma member of the Parliament, and representatives of state administration bodies, as well as representatives of the Roma national minority and associations. MAINSTREAMING OF ROMA EQUALITY AND INCLUSION AT THE NATIONAL LEVEL AND CONNECTION WITH OTHER RELEVANT EU INITIATIVES & DIVERSITY CONSIDERATIONS The strategy provides for alignment and complementarity with other mainstream strategies in the field of anti-discrimination, promotion of human rights, poverty and social exclusion and gender equality, all based on the relevant EU documents such as EU Anti-Racism Action Plan 2020-2025, EU Gender Equality Strategy 2020¬2025, and the European Pillar of Social Rights. Specific details on how the NRSF is aligned with other relevant national strategies could have been better illustrated. F U N D I N G CONNECTION WITH EU FUNDING PROGRAMMES (instruments) In its indicative financial plan, the NRSF mentions the uses of EU funding programmes with specific amounts. In various projects, the NRSF foresees the use of ESF+. OTHER SOURCES OF FUNDING The detailed indicative financial plans provides precise and yearly amounts allocated mainly by the State budget and also loans and other sources. For a clearer picture of the specific budget allocations and their long-term sustainability, the additional sources of funding and could have been better detailed. PROMISING PRACTICES /APPROACHES FOR COUNTRY-TO-COUNTRY LEARNING In 2020/2021, Croatia started to implement a Roma curriculum in schools. Its aim is to preserve the Roma’s language and culture. Roma children can attend 2-5 hours of extra classes per week taught in their native tongue. CYPRUS APPROACH OF THE NATIONAL ROMA STRATEGIC FRAMEWORK (NRSF) ESTIMATED ROMA POPULATION Council of Europe estimates (plus national census data, where available) CoE estimate (2012): 1,250; 0.16% of total population National Roma Contact Point (NRCP) Social Welfare Services, Deputy Ministry of Social Welfare NATIONAL ROMA CONTACT POINT KEY FEATURES AREAS FOR IMPROVEMENT The NRCP, the Deputy Ministry of Social Welfare, was established in May 2021 and entered into force in July 2021, with the purpose of strengthening social welfare services and to address the social problems faced by the citizens in Cyprus, including Roma. It provides technical expertise and financial support to local authorities and communities with the aim of setting up the necessary teams of professional social workers for the development of Social Work in the Community. The NRSF 2030 does not provide sufficient information with regards to the specific mandate of the NRCP to ensure the coordination and monitoring of the NRSF. In this sense, it appears that the NRCP is mainly tasked with strengthening accessibility of social welfare services for all citizens. The NRCP does not seem to be counting on a dedicated team and mandate which would align with the minimum commitments set in the EU Roma Strategic Framework and the 2021 Council Recommendation. Setting up a National Roma Platform could help to improve the coordination of outreach to the Roma population and co-operation with Roma civil society.

HORIZONTAL OBJECTIVES 1.FIGHT AND PREVENT ANTIGYPSYISM AND DISCRIMINATION 1A. FIGHTING DISCRIMINATION, HARASSMENT, HATE CRIME AND HATE SPEECH AGAINST ROMA KEY FEATURES AREAS FOR IMPROVEMENT The aim of the National Strategy is to create and strengthen a framework in which all bodies will implement measures for the effective protection and promotion of human rights, in compliance with the obligations arising from European and international commitments of the Republic of Cyprus. It includes measures such as the “National Strategy for the protection and promotion of Human Rights” (June 2021) which seeks to combat discrimination and eliminate obstacles that Roma encounter in the enjoyment of human rights, the Code of Conduct against Racism & Guide for Managing and Recording Racist Incidents, or awareness raising for students about Roma culture, language and history, including the Roma Holocaust, through the history curriculum and events for the International Roma Day. The NRSF refers to an anti-racism policy which takes account of the phenomenon of antigypsyism yet the strategy could potentially provide for a more targeted approach to combat antigypsyism explicitly. 1B. PROMOTING AWARENESS OF ROMA HISTORY, CULTURE, RECOGNITION AND RECONCILIATION KEY FEATURES AREAS FOR IMPROVEMENT The NRSF does not contain this horizontal objective. The Ministry of Education, Culture, Sport and Youth is pursuing awareness raising to students about Roma culture, language and history, including about the Roma Holocaust through the history curriculum, as well as through organising activities in Cyprus to celebrate the International Roma Day, and the “Code of Conduct against Racism & Guide for Managing and Recording Racist Incidents”. Promotion of positive narratives about Roma and Roma role models are not specifically mentioned in the NRSF, although such measures are important for the mainstream society to better understand the challenges that Roma face and to inspire the young Roma. 2.REDUCE POVERTY AND SOCIAL EXCLUSION KEY FEATURES AREAS FOR IMPROVEMENT The NRSF does not contain a specific objective to cover this area. It includes mainstream measures, as part of a project co-funded by the European Social Fund, aiming at the improvement of accessibility, enhancing individualised and holistic /multidisciplinary support to people and families. Support Measures included in ESF+ for minority and vulnerable groups are available for the Roma communities as well. Due to the mainstream approach of the interventions, the planned measures do not seem to be ambitious enough to tackle the needs of the Roma communities in Cyprus. 3.PROMOTE PARTICIPATION THROUGH EMPOWERMENT, COOPERATION AND TRUST KEY FEATURES AREAS FOR IMPROVEMENT The NRSF’ does not include a specific objective for this area. Participation is referred to as a matter of principle to be promoted generally by the National authorities. The NRSF does not present a clear course of the consultation processes carried out in drafting the national framework and has no future provisions for strengthening the process. SECTORAL OBJECTIVES KEY FEATURES AREAS FOR IMPROVEMENT 4.INCREASE EFFECTIVE EQUAL ACCESS TO QUALITY INCLUSIVE MAINSTREAM EDUCATION The NRSF main goal is to ensure that all Roma have effective and equal access to education and are able to participate in all forms and stages of education, with the necessary measures in place that will promote their personal development. Towards this objective the Ministry of Education, Culture, Sport and Youth (MoECSY) has set two goals and targets: The majority of Roma Children complete compulsory education until the age of fifteen or complete lower Secondary Education Cycle (Gymnasium) or whatever comes first. To reduce the gap in upper secondary education or vocational /technical secondary education. The NRSF plans to introduce a core programme beginning from lower secondary education to address the problem of disengaged students and students at risk of dropping out, including Roma students. The NRSF includes also measures to enable the study of the Greek language classes to Roma and all the vulnerable groups and immigrants. There is no reference to digital skills, except the provision for digital equipment and digital access /connection. The NRSF does not envisage measures to re-integrate Roma early leavers into education. No measures are established regarding participation of Roma students at higher education level and the overall higher education attainment for them. Cyprus’ tertiary education attainment is one of the highest in the EU and would be an asset to also integrate Roma students to the higher education. 5.INCREASE EFFECTIVE EQUAL ACCESS TO QUALITY AND SUSTAINABLE EMPLOYMENT The NRSF does not contain a specific objective in this area. There are no targeted Roma measures, but mainstreamed measures aimed at: training and retraining of unemployed and low-paid workers, with particular emphasis on beneficiaries of social benefits, plans for subsidising the recruitment of unemployed, people with disabilities, chronic patients and young people up to 29 years, mechanisms of activation of the beneficiaries of the Guaranteed Minimum Income (GMI) for those who can work. 6.IMPROVE ROMA HEALTH AND EFFECTIVE EQUAL ACCESS TO QUALITY HEALTHCARE AND SOCIAL SERVICES The NRSF does not contain a specific objective in this area. The mainstreamed measures refer to the National Health Scheme (Gesy) and the restructuring of the public hospitals into autonomous establishments, a scheme which introduced the institution of a personal physician for everyone. There is a provision that promotes the registration of children with a paediatrician of their choice; personal physician’s services are provided free of charge. Awareness of Roma could be raised in relation with the above-mentioned rights when receiving medical care, and, to guide Roma for the purpose of enrolment in the GESY. 7.INCREASE EFFECTIVE EQUAL ACCESS TO ADEQUATE DESEGREGATED HOUSING AND ESSENTIAL SERVICES The NRSF does not include a specific objective for this area. Cyprus introduced in July 2014 the Guaranteed Minimum Income (GMI) (No. L-109(I)/2014) which provides benefits such as housing, care and emergency needs, and support for disability. The GMI can be provided to people in need, including Roma of Cypriot Citizenship. The scope and scale of interventions in housing infrastructure is largely insufficient, therefore the package of measures could be scaled-up. MONITORING FRAMEWORK KEY FEATURES AREAS FOR IMPROVEMENT BASELINE The NRSF does not include baseline values. National baselines could be defined TARGETS The NRSF sets national quantitative or qualitative targets covering issues other than those addressed by the EU level targets in a given objective of the EU Framework. National targets could be defined more closely towards the Framework’s EU level objectives and targets based on a comprehensive needs-assessment. INDICATORS The NRSF does not use indicators, neither from the EU portfolio nor national indicators. Indicators could be defined. OTHER ELEMENTS KEY FEATURES AREAS FOR IMPROVEMENT PARTICIPATION OF KEY STAKEHOLDERS (NRCP, National Roma Platform, national, regional and local CSOs, equality bodies) The NRSF places the NRCP centrally to enhancing cooperation and involvement of the local authorities. The NRSF envisages setting up a “committee to monitor the implementation of the Strategic Framework”. The TOR of the Committee however is not defined yet, but it envisages participation of non-governmental organisations. The NRSF does not detail on how the NRCP will cooperate with the local and regional authorities. The NRSF does not include support measures for capacity building of Roma NGOs. The NRSF does not envisage the establishment of a structured form of dialogue with the Roma civil society, an aspect that need to be properly addressed and strengthened. MAINSTREAMING OF ROMA EQUALITY AND INCLUSION AT THE NATIONAL LEVEL AND CONNECTION WITH OTHER RELEVANT EU INITIATIVES & DIVERSITY CONSIDERATIONS The measures provided for to reach out to the Roma population are mainstream measures. The Strategy refers to key features of the Social Policy Strategy, 2021-2027; National Strategy for Preventing and addressing School Violence or National Child Guarantee Action Plan – still in development at the time of the submission of the NRSF. Multiple discrimination and other issues related to discrimination have not been adequately included in the NRSF. F U N D I N G CONNECTION WITH EU FUNDING PROGRAMMES (instruments) The NRSF contains references to some ESF projects. OTHER SOURCES OF FUNDING PROMISING PRACTICES /APPROACHES FOR COUNTRY-TO-COUNTRY LEARNING Towards this aim to improve the quality of health care system, the government of Cyprus introduced the National Health Scheme (Gesy) and the restructuring of the public hospitals into autonomous establishments. The pandemic showed the multiple benefits and the usefulness of the scheme which serves people universally and equally including the Cyprus Roma. The scheme introduced the institution of a personal physician for each individual. CZECHIA APPROACH OF THE NATIONAL ROMA STRATEGIC FRAMEWORK (NRSF) Roma Equality, Inclusion and Participation Strategy 2021–2030 (NRSF) Implementation plan 2021-2030 ESTIMATED ROMA POPULATION Council of Europe estimates (plus national census data, where available) CoE estimate (2012): 200,000; 1.9% of total population National census (2021): 21,691; 0.2%. In line with the EU Roma Framework’s common but differentiated approach, this Member State was invited to make more ambitious commitments to Roma equality, inclusion and participation than other Member States National Roma Contact Point (NRCP) Office of the government council for Roma minority affairs (EN), Inter-ministerial Commission for Roma Community Affairs | Rada vlády pro záležitosti romské men menšiny (CZ) (NRCP) NATIONAL ROMA CONTACT POINT KEY FEATURES AREAS FOR IMPROVEMENT The NRCP can count on a dedicated team and institutional mandate that ensures political weight, cross-sectoral coordination and mainstreaming of Roma equality and inclusion. It is involved (by EU fund managing authorities) in the coordination of cross-governmental discussions on the distribution of EU funds for Roma, and in systematic monitoring of their use. Currently, the NRCP consists of a small team, however, in order to further expand its capacity in fulfilling efficiently its full range of coordination, monitoring and reporting roles, more human and financial resources seem to be necessary to achieve the targets set in the NRSF and Implementation plan. The specific objective of “Strengthening key stakeholders responsible for coordination and implementation of the Roma Integration Strategy 2021–2030 on central, regional and local level” is a welcome development in this regard.

HORIZONTAL OBJECTIVES 1.FIGHT AND PREVENT ANTIGYPSYISM AND DISCRIMINATION 1A. FIGHTING DISCRIMINATION, HARASSMENT, HATE CRIME AND HATE SPEECH AGAINST ROMA KEY FEATURES AREAS FOR IMPROVEMENT 1B. PROMOTING AWARENESS OF ROMA HISTORY, CULTURE, RECOGNITION AND RECONCILIATION KEY FEATURES AREAS FOR IMPROVEMENT The NRSF includes the strategic objective “Emancipation - promoting equality, inclusion and participation” with concrete measures under the specific objectives: increasing the active participation of Roma in decision-making processes at the local, regional and national levels; promoting cultural emancipation of Roma; and reconciling the past injustice committed against Roma during the World War II. It also provides relevant measures in this area under the strategic objective concerning quality inclusive education. Considering the high level of stereotypical attitudes towards Roma of a significant part of the teaching staff , targeted measures are needed to counter these pervasive negative perceptions among teachers. Such measures should specifically include reinforced training for teachers on the Roma history, including the Roma Holocaust, culture and language when working with Roma pupils, promotion of positive role models and narratives, more Roma teachers, multicultural activities and campaigns in schools as well as more substantial and adequate portraying of Roma in the school textbooks. 2.EDUCE POVERTY AND SOCIAL EXCLUSION KEY FEATURES AREAS FOR IMPROVEMENT The NRSF does not include this specific objective but mentions poverty as an issue that goes across all sectoral objectives. The At Risk of Poverty and Social Exclusion (AROPE) indicator is used as a strategic objective indicator for the area of housing. Although this specific objective is not included as such in the NRSF, a target has been established for Roma at risk of income poverty includes which responds to the EU level target included in the EU Roma Framework (cut poverty gap between Roma and general population by at least half) 3.PROMOTE PARTICIPATION THROUGH EMPOWERMENT, COOPERATION AND TRUST KEY FEATURES AREAS FOR IMPROVEMENT The specific objective “Increasing the active participation of Roma in decision-making processes on the local, regional and national levels” includes important measures concerning community work and community organising, putting an emphasis on empowering communities and promoting harmonious inter-ethnic coexistence, as well as Roma participation in advisory and consultative bodies dealing with affairs concerning Roma. Roma Council, Roma NGOs and experts were closely involved in consultations and in the process of the development of the NRSF. The measures concerning Roma women and youth are featured in the NRSF. However, there could be more support provided for the networking of Roma women and youth, establishment and functioning of Roma and pro-Roma women’s and young NGOs or associations. While the targets on national monitoring committees and on reporting discrimination are addressed explicitly, the remaining two EU targets are addressed only at the level of measures. SECTORAL OBJECTIVES KEY FEATURES AREAS FOR IMPROVEMENT 4.INCREASE EFFECTIVE EQUAL ACCESS TO QUALITY INCLUSIVE MAINSTREAM EDUCATION The NRSF specific objectives are focused on: better participation of Roma children in pre-school education; elimination of discrimination and segregation of Roma in education, institutional care and education; improving the quality and increasing the staff of the counselling system in education; increasing the level of education of Roma; ensuring support for the development of professional competences of teachers; and ensuring conditions for the meaningful use of after school time of Roma children, pupils and students, especially in the area of recreational and artistic education, sports and other activities that support meaningful inclusion. The NRSF responds to all headline EU level targets included in the EU Roma Framework. (cut gap in participation in early childhood education and care by at least half; reduce gap in upper secondary completion by at least one third; work towards eliminating segregation by cutting at least in half the proportion of Roma children attending segregated primary schools (in Member States with significant Roma population) Roma children are still disproportionately represented among children diagnosed with mild mental disability and inadequately placed in the mainstream education programme with decreased learning outputs. The adequate use of modern diagnosis methods and tools is a key to correctly address children’s needs and to prevent and eliminate occurrence of any misdiagnosing of Roma children. The methodological guidance and improved monitoring arrangements planned are likely to be insufficient to achieve progress due to a lack of societal consensus on the benefits of inclusive education. It is therefore important to increase commitment at local level for inclusive education, for instance by creating incentives. 5.INCREASE EFFECTIVE EQUAL ACCESS TO QUALITY AND SUSTAINABLE EMPLOYMENT The NRSF specific objectives are focused on ensuring the monitoring of discrimination, in access to employment and at work, on grounds of Roma origin; ensuring support for socially excluded people, including Roma, in accessing the labour market; ensuring support for self-employed and entrepreneurial Roma; ensuring the development of entrepreneurship of Roma; ensuring support in a comprehensive manner to address Roma unemployment. The NRSF responds to the EU-level target included in the EU Roma Framework’s targets on NEETS and employment gap (cut employment gap by at least half; cut gap in NEET rate by at least half Although the NRSF does not respond to the EU Roma Framework’s target on the gender employment gap, it mentions some measures targeting Roma women. With regard to the number of Roma NEETs (not in employment, education or training), there is need for the ALMPs (active labour market policies) to be tuned to address their needs through individual counselling and advice. In the context of access to the labour market, PES (public employment services) need to be reformed in order to provide practical support to Roma job seekers, when transiting from unemployment to the labour market, by learning new skills or upskilling. 6.IMPROVE ROMA HEALTH AND EFFECTIVE EQUAL ACCESS TO QUALITY HEALTHCARE AND SOCIAL SERVICES The NRCP specific objectives are focused on redressing for unlawful sterilisation of women, improving access to and participation in health care among Roma, ensuring representative quantifiable data on health and health care among Roma in all regions, ensuring the availability of health services in time, place, capacity and price, specifically for socially excluded populations, including Roma; ensuring the availability of drug services for Roma substance users; ensuring that domestic and gender-based violence in Roma families and among Roma LGBTIQ+ people is addressed. The NRSF sets a national target responding to the EU level target included in the Framework (cut life expectancy gap by at least half) The NRSF uses a strategic indicator on life expectancy at birth. Reduction of health inequalities (in all dimensions) among Roma also requires systemic measures to ensure equal access to mainstream health services, e.g. investment in Roma health professionals (nurses, general practitioners, etc.) and measures to address digital exclusion of Roma people in their access to healthcare services. 7.INCREASE EFFECTIVE EQUAL ACCESS TO ADEQUATE DESEGREGATED HOUSING AND ESSENTIAL SERVICES The NRSF specific objectives are focused on reducing discrimination and segregation in access to housing; increasing the quality and availability of housing for socially excluded population including (a) adoption of a law on affordable housing that will include regulation of social housing and right to decent housing (b) existence of subsidy programmes /calls to support affordable housing and social housing, including Roma; targeted monitoring /monitoring of the housing market situation and support for rehousing tools. The NRSF explicitly responds to the EU-level target included in the Framework’s on housing deprivation. The EU-level target included in the Framework on overcrowding is adjusted to the average number of rooms per person in the Roma households and also responds to the EU-level target. On top of the proposed measures, it is important to sensitise the social housing system to take into consideration multiple disadvantages people may face. In addition, NRSF could provide integrated housing programs for marginalised Roma through measures such as combining microcredit for housing construction and maintenance with financial literacy and savings programs, training in the areas of construction and activation measures. MONITORING FRAMEWORK KEY FEATURES AREAS FOR IMPROVEMENT BASELINE The NRSF sets national baselines. TARGETS The NRSF provides national specific objectives and targets including comprehensive analysis. Most of these targets respond to the EU level target included in the Framework. Czechia is encouraged to set more ambitious 2030 national targets corresponding to the EU-level targets included in the EU Roma Framework, in the areas of child poverty; cutting the gap in gender unemployment; and increasing access to tap water, as it is a country with a significant Roma population and complex challenges. INDICATORS The NRSF rather uses national indicators. It also uses, in a limited manner, the outcome indicators from the EU portfolio of indicators. Sources of data for the listed indicators are not clear in the strategy. Although it mentions sources for baseline values, it is not clear if the same data collections would be in place also in the future. OTHER ELEMENTS KEY FEATURES AREAS FOR IMPROVEMENT PARTICIPATION OF KEY STAKEHOLDERS (NRCP, National Roma Platform, national, regional and local CSOs, equality bodies) Roma and pro-Roma NGOs working under the umbrella organisation Roma-net and the Government Council for issues concerning Roma were meaningfully consulted in the development of the national Roma strategic framework. While co-operation with the Roma civil society in the NRSF development was successful, the involvement of regional offices (political representatives and administration of the regions) and local municipalities is also very important as it represents the basic precondition for the functional implementation of the NRSF. In addition, the city /district strategies shall be aligned with the NRSF. MAINSTREAMING OF ROMA EQUALITY AND INCLUSION AT THE NATIONAL LEVEL AND CONNECTION WITH OTHER RELEVANT EU INITIATIVES & DIVERSITY CONSIDERATIONS The NRSF lists a number of national strategies and plans relevant for the NRSF: Social Inclusion Strategy 2021–2030, Long-term Plan for Education Development of the Education System of the Czech Republic 2019–2023, Strategy for the Education Policy of the Czech Republic up to 2030+ and many others. The NRSF refers to the European Social Charter. The NRSF provides intersectional approach and covers the issues of Roma women, children, youth and LGBTIQ. F U N D I N G CONNECTION WITH EU FUNDING PROGRAMMES (instruments) The NRSF states that the support for Roma inclusion will be directed primarily from three programmes within the 2021–2027 programming period: Employment Plus Programme, Johannes Amos Comenius Programme (both financed from ESF+) and Integrated Regional Programme (financed by the ERDF). Recovery and Resilience Plan investments supporting Roma need to be more clearly identified in the national strategic framework. The NRSF should explain more clearly how the various funding streams complement each other. OTHER SOURCES OF FUNDING

PROMISING PRACTICES /APPROACHES FOR COUNTRY-TO-COUNTRY LEARNING The NRCP has an institutional mandate, coordination role and can co-operate with the line ministries for implementation of the NRSF. Strengthening key stakeholders responsible for coordination and implementation of NRSF on central, regional and local level” is a promising practice in this regard. Romodrom’s Housing First for the Moravian-Silesian Region project addresses homelessness and housing deprivation of people of Roma origin who are socially excluded or at risk of social exclusion. The project aims to help people who need the most support, e.g. people in severe housing need. The target group includes households (individuals, couples, and families) that do not have housing or are at immediate risk of losing their homes. The project includes several activities, such as finding apartments, contacting private homeowners, establishing cooperation with owners, addressing the target group, finding and selecting clients, establishing a confidential relationship with clients, moving assistance and complex support after moving. The project applies the principles of the Housing First model and connects the non-profit sector and the private sector. DENMARK APPROACH OF THE NATIONAL ROMA STRATEGIC FRAMEWORK (NRSF) Set of policy measures relevant for Roma. Denmark’s strategy on Roma equality, inclusion and participation (NRSF). ESTIMATED ROMA POPULATION Council of Europe estimates (plus national census data, where available) CoE estimate (2012): 5,500; 0.1% of total population National census: not available National Roma Contact Point (NRCP) Ministry for Children, Gender Equality, Integration and Social Affairs (NRCP) NATIONAL ROMA CONTACT POINT KEY FEATURES AREAS FOR IMPROVEMENT The NRCP is given mandate, resources and staff to ensure ongoing coordination and monitoring and presenting a regular progress report. HORIZONTAL OBJECTIVES 1.FIGHT AND PREVENT ANTIGYPSYISM AND DISCRIMINATION 1A. FIGHTING DISCRIMINATION, HARASSMENT, HATE CRIME AND HATE SPEECH AGAINST ROMA KEY FEATURES AREAS FOR IMPROVEMENT The NRSF includes information on the mainstream legislation and policies concerning Gender Equality Act, Act on Ethnic Equal Treatment, social inclusion and hate crime. The NRSF does not include specific measures to tackle antigypsyism. 1B. PROMOTING AWARENESS OF ROMA HISTORY, CULTURE, RECOGNITION AND RECONCILIATION KEY FEATURES AREAS FOR IMPROVEMENT The NRSF includes information that one of the school curriculum topics is ‘culture, aesthetics and community’ and that educational staff must actively promote culture and support all children, regardless of their background, skills and previous experience of culture. Pupils from EU/EEA countries can also be offered mother-tongue education to develop not only the skills they need to communicate in their mother tongue, but also their linguistic awareness, based on the fact that they use two languages in everyday life. Measures promoting positive narratives about Roma and Roma role models could be developed 2.REDUCE POVERTY AND SOCIAL EXCLUSION KEY FEATURES AREAS FOR IMPROVEMENT The NRSF includes information on the mainstream reforms, measures and other initiatives relevant for Roma, e.g. Children First, Action plan to combat homelessness by making greater use of the Housing First approach, Day Care Act. While the NRSF does not cover this specific objective, it could have set out how the mainstream measures contribute to reducing poverty and social exclusion of Roma. 3.PROMOTE PARTICIPATION THROUGH EMPOWERMENT, COOPERATION AND TRUST KEY FEATURES AREAS FOR IMPROVEMENT The NRSF includes measures to promote the participation and institutional capacity by means of several actors, most notably the National Roma Contact Point, the Council for Ethnic Minorities, and the Council for the Socially Vulnerable and other civil society organisations. Denmark has a long tradition of a strong civil society working for and with vulnerable and socially disadvantaged groups, however, the NRSF does not include any information on the existence or participation of Roma civil society organisations. Hence, the NRSF could include specific measures to promote capacity-building and facilitate active participation of Roma civil society in all stages of policy-making and ensure its involvement in in the implementation and monitoring of the NRSF. A National Roma Platform could be established to bring together the NRCP, line ministries, equality bodies and Roma civil society. SECTORAL OBJECTIVES KEY FEATURES AREAS FOR IMPROVEMENT 4.INCREASE EFFECTIVE EQUAL ACCESS TO QUALITY INCLUSIVE MAINSTREAM EDUCATION According to the NRSF, Roma, like other citizens residing legally in Denmark, are covered by legislation and policy initiatives generally aimed at ensuring that the entire population has access to day-care and inclusive education. The NRSF could have included more specifically measures proposed by the Council Recommendation in this sectoral area, according to Denmark’s national context. PISA 2018 results showed a significant performance gap for young people with migrant background. This indicates that the quality of education both at early childhood education and especially primary school level could be improved warranting the need for more targeted support measures. 5.INCREASE EFFECTIVE EQUAL ACCESS TO QUALITY AND SUSTAINABLE EMPLOYMENT According to the NRSF, the mainstream employment strategy focuses on active employment policies with the aim of helping people to achieve sustainable integration into the labour market. The NRSF includes several measures targeting vulnerable groups to support their access to the labour market. The NRSF could have included more specifically measures proposed by the Council Recommendation in this sectoral area. 6.IMPROVE ROMA HEALTH AND EFFECTIVE EQUAL ACCESS TO QUALITY HEALTHCARE AND SOCIAL SERVICES According to the NRSF, the Health Act and Social Services Act states that persons with resident statute in Denmark have access to all public, regardless of ethnic or national background. The NRSF could have included more specifically measures proposed by the Council Recommendation in this sectoral area. 7.INCREASE EFFECTIVE EQUAL ACCESS TO ADEQUATE DESEGREGATED HOUSING AND ESSENTIAL SERVICES According to the NRSF, everyone residing legally in Denmark, regardless of income, social, religious, ethnic or national background, has the opportunity to apply for good quality housing in the non-profit social housing sector, including Roma. The NRSF could have included more specifically measures proposed by the Council Recommendation in this sectoral area. The NRSF does not include reference to EU mobile Roma and whether they are entitled and granted access to services. MONITORING FRAMEWORK KEY FEATURES AREAS FOR IMPROVEMENT BASELINE TARGETS INDICATORS Indicators could be defined closely in line with EU level objectives and targets and the EU portfolio of indicators. OTHER ELEMENTS KEY FEATURES AREAS FOR IMPROVEMENT PARTICIPATION OF KEY STAKEHOLDERS (NRCP, National Roma Platform, national, regional and local CSOs, equality bodies) According to the NRSF, the government involves civil society in national integration efforts and supports a number of civil society organisations working to integrate people with a foreign background. It also promotes inter-authority cooperation, with central and local agencies coordinating on data collection and fund allocation. MAINSTREAMING OF ROMA EQUALITY AND INCLUSION AT THE NATIONAL LEVEL AND CONNECTION WITH OTHER RELEVANT EU INITIATIVES & DIVERSITY CONSIDERATIONS The NRSF consists of a set of mainstream policy initiatives referred in all sections above. It underlines that Denmark has a comprehensive approach of non-discrimination in all policy and sectoral areas. Although the adopted national framework is titled as “Strategy on Roma equality, inclusion and participation”, it mostly refers to mainstream policies and initiatives concerning legal residents and persons of foreign background, lacking substantiation on specific information and measures about the Roma (including EU mobile Roma). F U N D I N G CONNECTION WITH EU FUNDING PROGRAMMES (instruments) OTHER SOURCES OF FUNDING

PROMISING PRACTICES /APPROACHES FOR COUNTRY-TO-COUNTRY LEARNING In Denmark, all municipalities must establish a coherent, coordinated youth strategy across the employment, education and social sectors for young people under 25 who have not completed upper secondary education. This could ensure a bottom-up and tailor-made approach on municipality level and might be a promising practice in this regard. ESTONIA APPROACH OF THE NATIONAL ROMA STRATEGIC FRAMEWORK (NRSF) Cohesive Estonia Strategy: Integration, Inclusion Adaptation 2022-2025 Set of policy measures relevant for Roma ESTIMATED ROMA POPULATION Council of Europe estimates (plus national census data, where available) CoE estimate (2012): 1,050; 0.08% of total population Population register (2021): 673; 0.06% National Roma Contact Point (NRCP) Ministry of Culture (NRCP) NATIONAL ROMA CONTACT POINT KEY FEATURES AREAS FOR IMPROVEMENT The NRCP is given mandate, resources and staff to ensure ongoing coordination and monitoring and presenting a regular progress report. The NRSF could be more explicit regarding the NRCP mandate and resources, indicating whether it is strong and sufficient enough to ensure proper coordination with line ministries, regional and local authorities, as well as with the Roma and pro-Roma civil society. HORIZONTAL OBJECTIVES 1.FIGHT AND PREVENT ANTIGYPSYISM AND DISCRIMINATION 1A. FIGHTING DISCRIMINATION, HARASSMENT, HATE CRIME AND HATE SPEECH AGAINST ROMA KEY FEATURES AREAS FOR IMPROVEMENT The policy documents submitted include in the Integration plan the indicator “Proportion of people with an open attitude based on the composite tolerance index”. In general, the documents mention that Roma are much more likely to encounter intolerance compared to the other nationalities. However, they do not include any measures concerning antigypsyism and discrimination. There is no substantiation in the Integration plan about the relevance of the listed indicator. 1B. PROMOTING AWARENESS OF ROMA HISTORY, CULTURE, RECOGNITION AND RECONCILIATION KEY FEATURES AREAS FOR IMPROVEMENT The mainstream Cultural Development Plan 2030 refers to the importance of introduction of Roma culture and history to the general public. There is no specific information or measures to promote Roma history, culture, recognition and reconciliation. 2.REDUCE POVERTY AND SOCIAL EXCLUSION KEY FEATURES AREAS FOR IMPROVEMENT The mainstream Welfare Development Plan is listed as the policy document to address poverty. While the submitted documents do not cover this specific objective, it could have set out how the mainstream measures contribute to reducing poverty and social exclusion of Roma. 3.PROMOTE PARTICIPATION THROUGH EMPOWERMENT, COOPERATION AND TRUST KEY FEATURES AREAS FOR IMPROVEMENT To promote Roma integration and coordinate information the Advisory Council for Roma Integration (Roma Platform, 3 people) has been established as part of the Ministry of Culture. Its role is to analyse the integration issues, make policy recommendations to relevant institutions, and co-operate towards this goal. The Ministry of Culture carries out projects aimed at Roma empowerment, as funded by the EU. While acknowledging the issue of the very low level of participation among the Roma NGOs, as well as a lack of trust in state institution, the submitted documents do not provide sufficient indications about how the empowerment of Roma NGOs could be further strengthened to ensure their active participation in all stages of policy-making and implementation, including monitoring and reporting.

SECTORAL OBJECTIVES KEY FEATURES AREAS FOR IMPROVEMENT 4.INCREASE EFFECTIVE EQUAL ACCESS TO QUALITY INCLUSIVE MAINSTREAM EDUCATION The Integration plan refers to the indicator “Percentage of Roma 15 and older who have a secondary, vocational or higher education” and an associated baseline and target. The NRSF responds to one EU-level target included in the EU Roma Framework (reduce gap in upper secondary completion by at least one third) The documents acknowledge that Roma lag far behind in education. However, there are no specific measures mentioned to support their integration into early childhood education and care as well as primary education, including preventing early school leaving. 5.INCREASE EFFECTIVE EQUAL ACCESS TO QUALITY AND SUSTAINABLE EMPLOYMENT The Estonian labour policies are focused on the improvement of the availability of needs oriented labour market; provision of services for people from different linguistic and cultural backgrounds; supporting the recruitment of employees with other native languages in state and local government agencies; support employment diversity policies. The Integration plan refers to the indicator “Employment rate of Roma (15-74-year-old)’’ and associated baseline and target. The NRSF responds to one EU-level target included in the EU Roma Framework (cut employment gap by at least half) The policy documents acknowledge that the Roma face more challenges in accessing labour market compared to general population. However, there are no specific measures associated with the indicator “Employment rate of Roma (15-74-year-old)’’. 6.IMPROVE ROMA HEALTH AND EFFECTIVE EQUAL ACCESS TO QUALITY HEALTHCARE AND SOCIAL SERVICES The submitted policy documents do not include this sectoral objective. Furthermore, there are no measures included from those proposed by the Council Recommendation in this sectoral area. 7.INCREASE EFFECTIVE EQUAL ACCESS TO ADEQUATE DESEGREGATED HOUSING AND ESSENTIAL SERVICES The submitted policy documents do not include this sectoral objective. Furthermore, there are no measures included from those proposed by the Council Recommendation in this sectoral area. MONITORING FRAMEWORK KEY FEATURES AREAS FOR IMPROVEMENT BASELINE The relevant baselines for employment rate and education of Roma are based on the national data from Ministry of Culture, 2019. TARGETS The NRSF sets one national target responding to the EU level target included in the EU Framework for education (reduce gap in upper secondary completion by at least one third), and for employment (cut employment gap by at least half) INDICATORS Employment rate of Roma (15-74-year-olds); Percentage of Roma 15 and older who have a secondary, vocational or higher education. OTHER ELEMENTS KEY FEATURES AREAS FOR IMPROVEMENT PARTICIPATION OF KEY STAKEHOLDERS (NRCP, National Roma Platform, national, regional and local CSOs, equality bodies) According to the Cohesive Estonian Strategy, all policies are consulted with regional and local stakeholders. The Advisory Council for Roma Integration (Roma Platform) has been established (3 people) as part of the Ministry of Culture. The Roma civil society should be strengthened to ensure its meaningful participation in all relevant processes. MAINSTREAMING OF ROMA EQUALITY AND INCLUSION AT THE NATIONAL LEVEL AND CONNECTION WITH OTHER RELEVANT EU INITIATIVES & DIVERSITY CONSIDERATIONS Some mainstream policies are listed in the submitted documents, such as the Education Development Plan, the Cultural Development Plan, and the Youth Field Development Plan. F U N D I N G CONNECTION WITH EU FUNDING PROGRAMMES (instruments) ESF+ will be used for the measure related to integration and Estonian-language learning. In addition, ESF+ offers considerable support for active labour market measures, activation for NEET youth and other social inclusion measures. OTHER SOURCES OF FUNDING The policy documents could include information on the other sources of funding relevant to Roma. PROMISING PRACTICES /APPROACHES FOR COUNTRY-TO-COUNTRY LEARNING Since 2015, the Ministry of Culture, with the support of the European Commission, implements the Roma Integration Support Project (ESTROM), which aims to promote cooperation and dialogue between integration stakeholders, Roma, local governments and state institutions. FINLAND APPROACH OF THE NATIONAL ROMA STRATEGIC FRAMEWORK (NRSF) Strategy: Finland’s National Roma Policy (ROMPO) 2018-2022 (01-01-2018) ESTIMATED ROMA POPULATION Council of Europe estimates (plus national census data, where available) CoE estimate (2012): 11,000; 0.21% of total population National Roma Contact Point (NRCP) Ministry of Social Affairs and Health NATIONAL ROMA CONTACT POINT KEY FEATURES AREAS FOR IMPROVEMENT The NRCP consists of one full-time staff handling Roma issues within the Ministry of Social Affairs and Health. It has a full mandate to coordinate with ministries and other actors and is in charge of monitoring implementation of the NRSF and coordinating with different authorities on the implementation of measures. The NRCP organises frequent meetings of the Advisory Board on Romani Affairs, bringing together Roma civil society and public authorities, and it is in regular contact with Roma civil society representatives and local and regional authorities. As the NRCP is staffed by just one person, particular attention should be given to providing guidance and training in situations of staff mobility, in order to ensure the best possible continuity of its work.

HORIZONTAL OBJECTIVES 1.FIGHT AND PREVENT ANTIGYPSYISM AND DISCRIMINATION 1A. FIGHTING DISCRIMINATION, HARASSMENT, HATE CRIME AND HATE SPEECH AGAINST ROMA KEY FEATURES AREAS FOR IMPROVEMENT Fighting discrimination and multiple discrimination are taken into account in the NRSF as horizontal priorities. Measures include monitoring of discrimination by the Police University College and National Police Board, training by the Ministry of Justice, to prevent ethnic profiling, as part of the education of police officers and security personnel, awareness-raising actions aimed at different professional groups, anti-racism campaigns, as well as commemoration and celebration events on occasions such as International Roma Day, Roma Holocaust Memorial Day, International Holocaust Remembrance Day, and Finnish Indepe