COMMISSION STAFF WORKING DOCUMENT 2023 Rule of Law Report Country Chapter on the rule of law situation in Estonia 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 2023 Rule of Law Report The rule of law situation in the European Union
Date: 2023-07-05
Institutions: European Commission, Secretariat-General
Subjects: Estonia, administrative transparency, corruption, democracy, independence of the judiciary, infringement of EU law, pluralism in the media, political rights, rule of law

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 5.7.2023  SWD(2023) 806 final  COMMISSION STAFF WORKING DOCUMENT 2023 Rule of Law Report         Country Chapter on the rule of law situation in Estonia 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 2023 Rule of Law Report                              The rule of law situation in the European Union {COM(2023) 800 final} - {SWD(2023) 801 final} - {SWD(2023) 802 final} - {SWD(2023) 803 final} - {SWD(2023) 804 final} - {SWD(2023) 805 final} - {SWD(2023) 807 final} - {SWD(2023) 808 final} - {SWD(2023) 809 final} - {SWD(2023) 810 final} - {SWD(2023) 811 final} - {SWD(2023) 812 final} - {SWD(2023) 813 final} - {SWD(2023) 814 final} - {SWD(2023) 815 final} - {SWD(2023) 816 final} - {SWD(2023) 817 final} - {SWD(2023) 818 final} - {SWD(2023) 819 final} - {SWD(2023) 820 final} - {SWD(2023) 821 final} - {SWD(2023) 822 final} - {SWD(2023) 823 final} - {SWD(2023) 824 final} - {SWD(2023) 825 final} - {SWD(2023) 826 final} - {SWD(2023) 827 final}  
 
 
ABSTRACT 

The well-advanced digitalisation of the justice system in Estonia continued to be developed. A 
portal was created linking the public e-File and the business register to enhance cross-system 
document access. Amendments to the Courts Act will create specialised departments within 
each court. This would lead to the creation of new middle management positions for judges. 
The legal framework for transfers of judges contains adequate safeguards, while some concerns 
have been voiced that the new, permanent system of specialised departments could result in a 
de facto transfer without consent. The number of judges has been increased and additional rules 
are expected to allow for a better distribution of the workload. New legal aid rules have been 
adopted.  The  high  level  of  digitalisation  allows  the  justice  system  to  continue  working 
efficiently. 

As  regards  the  guidelines  on  the  conflict  of  interests,  new  procedures  were  introduced, 
including the anti-corruption contact points and assistance to the ministers and their advisors 
in getting acquainted with the rules in place. Concerning guidelines on lobbying, the current 
rules continue to be promoted and are actively monitored by the authorities. The 2021-2025 
Anti-Corruption Action Plan is being implemented efficiently. In addition, amendments to the 
Anti-Corruption Act are under preparation. The authorities efficiently deal with investigation 
and prosecution of  corruption-related cases. While new rules were introduced in  relation to 
revolving doors for members of Government, draft laws on Political Parties’ Financing and 
whistleblowing have not yet been adopted. 

As  a  result  of  new  legislation,  the  national  media  regulator  in  Estonia  has  been  granted 
additional staff and better technical tools to ensure the implementation of new EU rules. The 
resources of the public service media, which according to polls attracts  a high level of trust 
among citizens, have been increased. Some progress has been made to improve the practical 
application  of  the  right  of  access  to  information,  which  is  protected  by  the  Constitution. 
Nonetheless,  the  Parliament  has  procured  a  study  to  provide  input  for  possible  solutions  to 
address diverging disclosure practices. In two recent judgments, the Supreme Court has upheld 
the  confidentiality  of  journalistic  sources  and  clarified  freedom  of  the  press  regarding 
disclosure of information about pre-trial proceedings. 

The  new  digital  platform  for  further  improving  the  process  of  enactment  laws  is  being 
launched, with  additional  features for including stakeholders to  be developed by the  end of 
2023. The Chancellor of Justice continued playing an active role in upholding the rule of law 
through proposals for constitutionality checks of legislation and memoranda addressed to state 
and local authorities for initiating legislation. The civic space remains open, but concerns have 
been  raised  as  regards  the  modalities  of  funding  of  Civil  Society  Organisations  through 
Parliament. 

1 

 
 
 
RECOMMENDATIONS  

Overall, concerning the recommendations in the 2022 Rule of Law Report, Estonia has (made): 

  Significant progress on ensuring that the guidelines on the conflict of interests are subject 

to an effective verification, monitoring and enforcement mechanism.  

  Fully implemented the recommendation to continue the efforts in effective implementation 

of the guidelines on lobbying.  

  Some progress on ensuring consistent and effective practical implementation of the right 
of  access  to  information  taking  into  account  European  standards  on  access  to  official 
documents. 

  Significant  progress  on  continuing  to  advance  with  the  digital  platform  to  make  the 

legislative process even more visible and inclusive for public consultation.  

On this basis, and considering other developments that took place in the period of reference, it 
is recommended to Estonia to: 

  Ensure  that  the  guidelines  on  the  conflict  of  interests  are  subject  to  an  enforcement 

mechanism. 

  Advance with the efforts to ensure consistent and effective implementation of the right of 
access  to  information  taking  into  account  European  standards  on  access  to  official 
documents. 

2 

 
 
I. 

JUSTICE SYSTEM  

The  Estonian  court  system  consists  of  three  levels:  four  County  Courts  (hearing  all  civil, 
criminal  and  misdemeanour  matters)  and  two  Administrative  Courts  at  first  instance,  two 
Circuit Courts at second instance (reviewing decisions of County and Administrative Courts), 
and  the  Supreme  Court  at  the  highest  instance,  which  reviews  court  judgments  by  way  of 
cassation proceedings. The Supreme Court administers its own budget and operations, while 
the courts of first and second instance are administered in cooperation between the Council for 
Administration of Courts and the Ministry of Justice. Estonia does not have a Constitutional 
court  but  the  Supreme  Court’s  Constitutional  Review  Chamber  can  carry  out  ex  post 
constitutional review, including, under certain conditions, based on a constitutional complaint1. 
The Council for Administration of Courts is a non-permanent body2, which has powers, among 
others,  related  to  the  judicial  map,  the  resources  of  the  judiciary  and  participates  in  the 
discussion  on  administration  of  the  courts.  Judges  of  first  and  second  instance  courts  are 
appointed by the President of the Republic on the proposal of the Supreme Court (en banc)3. 
The  Prosecutor’s  Office  is  a  government  agency  under  the  Ministry  of  Justice,  which  is 
independent  in  the  performance  of  its  duties.  It  is  managed  by  the  Prosecutor  General, 
particularly  as  regards  the  appointment  and  career  of  prosecutors4.  The  Estonian  Bar 
Association  is  an  independent,  self-governing  professional  association5.  Disciplinary 
proceedings  against  lawyers  can  be  initiated  before  the  Court  of  Honour6  by  any  interested 
person or by the board of the Bar Association7. Estonia participates in the European Public 
Prosecutor’s Office (EPPO). 

Independence  

The level of perceived judicial independence in Estonia continues to be high among the 
general public and average among companies. Overall, 65% of the general population and 
59% of companies perceive the level of independence of courts and judges to be ‘fairly or very 
good’ in 20238. According to data in the 2023 EU Justice Scoreboard, no clear trend can be 
identified in the evolution of the perceived level of independence since 2016. Nevertheless, the 
perceived judicial independence among the general public has increased in comparison to 2022 

1   § 4 of the Constitutional Review Court Procedure Act - A complaint can be referred to the Supreme Court’s 
Constitutional Review Chamber by the President of the Republic, the Chancellor of Justice, a local government 
council and the Parliament. § 9 of the Constitutional Review Court Procedure Act - Constitutional review on 
the basis of court judgment or court ruling is also possible. 

2   The Council does not function on a permanent basis and has four regular sessions, as well as extraordinary 
sessions  whenever needed. See 2020 Rule of Law  Report,  Country Chapter on the rule  of law situation in 
Estonia, p. 3. 

3   The Supreme Court en banc is the highest body of the Supreme Court. It is comprised of all 19 justices of the 
Supreme  Court. The Supreme Court  en banc is convened and chaired by the Chief Justice of the Supreme 
Court. 

4   The Prosecutor General exercises supervisory control in the prosecutor's office, and chief prosecutors exercise 

supervisory control in district prosecutor's offices. 

5   § 2(1) of the Bar Association Act. 
6   § 15(1) and § 15(3) of the Bar Association Act - The Court of Honour consists of four sworn lawyers elected 
by  the  general  assembly  of  the  Bar  Association,  two  judges  elected  by  the  Court  en  banc  and  one  jurist 
designated by the council of the Law Faculty of the University of Tartu. 

7   § 16(1) of the Bar Association Act. 
8   Figures 49 and 51, 2023 EU Justice Scoreboard. The level of perceived judicial independence is categorised 
as follows: very low (below 30% of respondents perceive judicial independence as fairly good and very good); 
low (between 30-39%), average (between 40-59%), high (between 60-75%), very high (above 75%). 

3 

 
                                                           
(60%), as well as to 2016 (62%). The perceived judicial independence among companies has 
increased in comparison to 2022 (47%) although it remains lower than in 2016 (72%). 

The amendments to the Courts Act will create specialised departments within each court. 
On 16 February 20239, the Parliament adopted amendments to the Courts Act, which aim to 
create more effective management levels through which case-law would be harmonised and 
the workload would be lowered10. Through these amendments, the currently existing territorial 
divisions of courts at national level will be abolished and converted into specialised civil and 
criminal  departments,  with  each  department  encompassing  several  court  houses.  Within  a 
department,  a  narrower  specialisation  would  be  created11.  Judges  have  raised  concerns 
regarding these amendments, noting that specialisation already exists through the distribution 
plans of the courts,  and  that there is  no need for a “compulsory” specialisation through the 
creation  of  departments  and  middle  level  management  structures12.  According  to  European 
standards, specialisation could present certain  advantages13 but also certain disadvantages14, 
and both have to be duly taken into account, having in mind the realities in each individual 
Member State.  

The  new  amendments  to  the  Courts  Act  envisage  judges  as  Heads  of  Departments  to 
support  the  administration  of  justice.  The  Courts  Act  amendments  of  16  February  2023 
envisaged  that  each  new  specialised  department  would  be  headed  by  a  judge,  who  will  be 
appointed by the president of the court after having heard the opinion of the judges of the given 
department15. The Heads of Departments support the administration of justice and organise the 
work of the officials of the department16. They also perform the duties assigned to them by the 
president  of  the  court  and  prescribed  in  the  internal  rules  of  the  court17.  The  Heads  of  the 
Departments do not by default have disciplinary authority over the judges in their department18. 

9   The amendments will enter into force in May 2023. 
10   This  would  be  achieved  through  spreading  the  workload  and  dealing  with  it  more  efficiently.  Input  from 

Estonia for the preparation of the 2023 Rule of Law Report, p. 4. 

11   E.g. within the criminal law department, there could be an anti-corruption specialisation. See also § 91 (2) of 

the Courts Act. 

12   Parliament’s Constitutional Committee, minutes No 142 of the sitting, 18 October 2022; written contribution 
from Estonian Judges Association in the context of the country visit to Estonia. The Judges’ Association stated 
that judges would have to either decide to stay in the court where they used to work and accept a new area of 
work, if the specialisation of that courthouse changed, or they would be assigned to a different court house 
where their field of specialisation exists, which would require travelling or moving. 

13   For example, concentrating case-files in the hands of a select group of specialist judges can be conducive to 
consistency in judicial decisions and consequently can enhance legal certainty. Specialist judges who provide 
knowledge  of  a  science  other  than  law  can  foster  a  multidisciplinary  approach  to  the  problems  under 
discussion. See Opinion (2012) No. 15 of the Consultative Council of European Judges on the Specialisation 
of Judges, paras. 8-13. 

14   For  example,  specialisation,  could  lead  to  reproducing  previous  decisions  when  deciding  on  same  issues, 
which can hamper the evolution of case-law in line with society’s needs. Furthermore, smaller courts may find 
it impossible to set up specialist chambers, or an adequate number of such chambers. This forces judges to be 
versatile,  and  thus  to  have  the  ability  to  address  a  range  of  specialist  matters.  Excessive  individual 
specialisation  of  judges  would  hamper  this  necessary  versatility.  See  Opinion  (2012)  No.  15  of  the 
Consultative Council of European Judges on the specialisation of judges, paras. 14 to 23. 

15   See § 122 of the Courts Act. 
16   This would include the harmonisation of the case-law in a specific area of justice. 
17   Written contribution from the Ministry of Justice, the Supreme Court, and Council for the Administration of 

Courts in the context of the country visit to Estonia, p. 1. 

18   Oversight over the administration of justice, over the performance of duties by judges, and over the forwarding 
of the data of the court information system pursuant to the established procedure remains unchanged and is 

4 

 
                                                           
Moreover, the Heads of Departments do not have the power to  give formal feedback to the 
judges, neither the competence to ask judges for the explanations regarding the application of 
the law in certain court cases19. The Government considers that open discussions and sharing 
practices within the department would be desirable effects of the new law. Initially, a feedback 
system was envisaged to be set up for first instance judges who would be assessed by second 
instance judges. However, this part was eventually left out from the adopted amendments, as 
the Association of Judges considered the system too premature and not sufficiently regulated20. 
The Association of Judges has raised concerns that the concrete implementation of these new 
powers  could  affect  judicial  independence,  as  the  concrete  application  is  specified  in  the 
internal rules of each court and the framework provided by the amendments leaves room for 
different  interpretations21.  It  is  relevant  to  recall  that  according  to  European  standards22, 
individual judges should be free from directives or pressure from the president of the court (in 
this case, the head of department) when adjudicating cases23, and these standards should be 
taken duly into account.  

The legal framework for transfers of judges  contains adequate safeguards, while some 
concerns have been voiced that new amendments to the Courts Act could result in a de 
facto transfer without consent. The legal regime for transferring judges remains unchanged 
and is accompanied by adequate safeguards24. According to the amendments to the Courts Act 
adopted on 16 February 2023, the conversion of currently existing territorial divisions of courts 
into specialised civil and criminal departments, where a department would encompass several 
courthouses, implies that certain judges would have to travel on daily basis between several 
courthouses to see different cases of the same area of law25. Consequently, a judge could be 
forced by the circumstances to relocate to another city in order to continue fulfilling their duties 
in  instances  where  distances  are  too  big  and  time  consuming  to  regularly  cover.  While  the 
Government argues that the majority of cases can be resolved through a written procedure26, in 

exercised by the president of the court. However, this could be an additional power granted  to them by the 
president of the court. This has been done in the Court of Harju, the revised internal rules of the court give 
additional powers to the Heads of Departments to initiate disciplinary proceedings. (Information received from 
the Estonian Judges Association). 

19   Written contribution from the Ministry of Justice, the Supreme Court, and Council for the Administration of 

Courts in the context of the country visit to Estonia, p. 1. 

20   Ibid. 
21   Parliament’s Constitutional Committee, minutes No 142 of the sitting, 18 October 2022; written contribution 

from Estonian Judges Association in the context of the country visit to Estonia. 

22   See Opinion (2016) No. 19 of the Consultative Council of European Judges on the role of Court Presidents. 
23   See Opinion (2016) No. 19 of the Consultative Council of European Judges on the role of Court Presidents, 

para. 13. 

24   When it comes to the legal regime for transferring a judge from one department to another, the final decision 
lies  with  the  president  of  the  court.  This  is  a  voluntary  process,  and  the  decision  is  made  following  an 
application submitted by the judge and considering the opinion of the full court. It is important to note that the 
president of the court cannot transfer a judge to another department without the judge's consent. While there 
is a theoretical possibility that the full court could assign a judge to another department without consent, the 
judge can protect their rights by submitting an application to the president of the court. Nevertheless, these 
situations are different from the de facto transfer, which is raised as an issue by the stakeholders, where the 
circumstances created by the specialisation of courthouses could force judges to ask for transfer. 

25   Information received from the Ministry of Justice in the context of the country visit to Estonia. This is also 
linked to the fact that the case allocation system does not take into account the different locations and the 
geographical distances involved. 

26   Written contribution from the Ministry of Justice in the context of the country visit to Estonia, p. 2. 

5 

 
                                                           
practice these cases could also require hearings27. Therefore, stakeholders voiced some concern 
that the new specialisation of departments could result in de facto transfers of judges without 
their consent28.  

The previous, temporary regime for the transfer of cases, intended to addressexcessive 
workload, was not further used. That regime for transfer of cases, mentioned in the previous 
two Rule of Law Reports29, was introduced as a temporary measure to cope with the excessive 
workload of certain judges and the use of it had raised concerns in relation to the transfer of 
judges.  Apart  from  the  initially  transferred  543  cases  there  have  been  no  further  cases 
transferred, and it appears that the regime for the transfer of cases as a temporary measure has 
not been further used30. 

Quality  

Further improvements have been made in the digitalisation of justice to improve cross-
system  document  access.  As  noted  in  the  2020 and  2021  Rule  of  Law  Reports,  Estonia  is 
among the best performing Member States when it comes to digitalisation of justice31. Since 
October 2022, the Document Delivery Portal has been made operational32. This is a portal to 
which  documents  that  must  be  served  or  delivered  are  transferred  from  other  interfaced 
systems. As part of a pilot project, two systems,  the public e-File and the business register, 
were interfaced into the new portal. The portal gathers all documents from interfaced systems 
and is already being used widely33. The Government has received multiple requests for linking 
other  existing  systems  to  the  new  Document  Delivery  Portal34.  On  18  January  2023,  the 
Parliament adopted a law on forensic examination, which establishes the legal grounds for fully 
digital criminal proceedings and prepares the field of forensic examination for the transition to 
fully digital court proceedings35. 

The number of judges has been increased and additional rules are expected to allow for 
a better distribution of their workload.  As mentioned in  the 2022 Rule of  Law Report36, 
challenges were identified as regards the workload of judges. To remedy the situation, in 2022, 
12 additional positions for judges were created. Furthermore, additional funding was allocated 
for court staff37. During the 121st Session of the Council for the Administration of Courts, issues 
related to the workload of judges have been discussed, mostly related to budgetary matters and 

27   Information received from the Estonian Judges Association in the context of the country visit to Estonia. 
28   Information  received  from  the  Estonian  Judges  Association  in  the  context  of  the  country  visit  to  Estonia.  
This is similar to the separate situation described in the 2022 Rule of Law Report. Some judges might also 
have to consider permanent relocation due to the distances.  

29   See 2022 Rule of Law Report, Country Chapter on the rule of law situation in Estonia, pp. 3-4. 
30   Information received from the Council for the administration of courts and the Estonian Judges Association 

in the context of the country visit to Estonia. 

31   See 2022 Rule of Law Report, Country Chapter on the rule of law situation in Estonia, p. 4. See also Figures 

41 to 48 from the 2023 EU Justice Scoreboard. 

32   Input from Estonia for the preparation of the 2023 Rule of Law Report, p. 2. 
33   Since October, 167 000 documents have been sent to DDP and 64% of them (107 135) have been delivered 
with an average delivery time of 1,5 days (as of January 2023). See input from Estonia for the preparation of 
the 2023 Rule of Law Report, p. 2. 

34   Information received from the Ministry of Justice in the context of the country visit to Estonia. 
35   Written contribution from the Ministry of Justice in the context of the country visit to Estonia. 
36   See 2022 Rule of Law Report, Country Chapter on the rule of law situation in Estonia, pp. 4-5. 
37   Information received from the Ministry of Justice and the  Council  for the  Administration of Courts in the 

context of the country visit to Estonia.  

6 

 
                                                           
salaries. A resolution with key priorities in this respect was adopted and sent to the Government 
and Parliament38. Finally, as part of the amendments to the Courts Act adopted on 16 January 
2023, provisions that could help with the distribution of the workload have been introduced. 
For  example,  a  judge  who  has  been  temporarily  away  from  service  can  return  to  his/her 
position39.  Currently,  returning  to  the  office  of  judge  is  not  guaranteed  in  such  case.  The 
amendments also provide that a judge who has been transferred to another court of the same 
instance  or  to  a  higher  court  will  continue  to  review  cases  of  the  county,  administrative  or 
district court in ongoing proceedings that were not redistributed to other judges for the purpose 
of ensuring a reasonable time for proceedings40. 

New legal aid rules have been adopted to improve access to justice.  The hourly fees for 
state  legal  aid  had  not  been  updated  since  2016,  which  has  led  to  a  diminishing  interest  of 
lawyers to participate in the scheme. On 17 November 2022, the Chancellor of Justice proposed 
to  the  Minister  of  Justice  to  amend  the  regulation  setting  up  the  hourly  fees  for  lawyers 
providing legal aid41. The Chancellor considered that the rules governing the system for legal 
aid  were  not  sufficiently  flexible  to  achieve  a  fair  outcome  in  all  cases42.  Furthermore,  the 
Supreme Court examined the constitutionality of the legal aid fee scheme in a decision of 7 
November 202243. Although the Supreme Court  held  that, when assessed  from  the point of 
view of the lawyer, the fee cap in the particular case was not unconstitutional, it found that the 
provision of state legal aid may not be sustainable under the current rates44. The Estonian Bar 
Association also informed about difficulties in finding lawyers who would voluntarily accept 
State legal aid45. On 31 January 2023, the Minister of Justice amended the regulation to increase 
the  legal  aid  fees  for  lawyers46.  Nevertheless,  stakeholders  noted  that  despite  these 
improvements, there is still little interest of lawyers to participate in the legal aid scheme, and 
that a more comprehensive reform of the system would be needed47.  

The  increased  court  fees  are  being  implemented  without  any  challenges  before  the 
Supreme Court. As mentioned in the 2022 Rule of Law Report48, the court fees were increased 
by 40% on average. The 2023 EU Justice Scoreboard also reflected this incearse and shows 
that  the  court  fees  in  commercial  cases  are  still  among  the  higher  ones  in  the  EU49. 

38   Information received from the Council for the Administration of Courts in the context of the country visit to 

Estonia. 

39   This will enable the judge to work in another position in the civil service or as a faculty member at a university. 

Currently, returning to the office of judge is not guaranteed in such case. 
40   Input from Estonia for the preparation of the 2023 Rule of Law Report. 
41   The Chancellor of Justice's proposal of 17 November 2022 to the Minister of Justice to amend regulation No. 

16 on “The procedure for paying the state legal aid fee and compensation of expenses to an attorney”. 

42   The Chancellor of Justice's proposal of 17 November 2022 to the Minister of Justice to amend regulation No. 
16 on “The procedure for paying the state legal aid fee and compensation of expenses to an attorney”, p. 1. 

43   Supreme Court Decision 5-22-2/12, of 7 November 2022.  
44   The Chancellor of Justice's proposal of 17 November 2022 to the Minister of Justice to amend regulation No. 
16 on “The procedure for paying the state legal aid fee and compensation of expenses to an attorney”, p. 2. 
45   Opinion of the Estonian Bar Association of 10 November 2022, “Bar: justice hung in the balance already in 

September”. 

46   Information received from the Office of the Chancellor of Justice in the context of the country visit to Estonia. 
47   Information received from the Estonian Bar Association and the Office  of the Chancellor of Justice in the 

context of the country visit to Estonia.  

48   See 2022 Rule of Law Report, Country Chapter on the rule of law situation in Estonia, p. 5. 
49   Figures 25, 2023 EU Justice Scoreboard. The figure presents court fees in specific commercial case scenario. 

The data in the 2023 edition of the Scoreboard present the situation after the reform. 

7 

 
                                                           
Nevertheless, the concerns raised in last year’s report50 that the increase could also be seen as 
a  way  to  decrease  the  workload  of  the  courts  by  disincentivising  cases  from  being  brought 
before the courts, did not materialise51. Furthermore, no challenges have been filed before the 
Constitutional Review Chamber of the Supreme Court against the increased court fees52. 

Efficiency 

The  justice  system  remains  efficient,  with  some  delays  observed  in  criminal  and 
administrative cases. According to the 2023 EU Justice Scoreboard, the length of proceedings 
continues to be among the shortest in the EU53. In 2022, civil cases were resolved with a similar 
efficiency  as  in  previous  years  in  county  courts  (in  102  days  on  average),  the  efficiency  in 
criminal cases54 remained stable. They were slightly shorter than in 202155 (on average, in 245 
days  in  general  criminal  proceedings,  33  days  in  simplified  proceedings,  and  44  days  in 
misdemeanour cases)56. In the first instance courts, administrative cases were also longer than 
in 2020 (on average 149 days)57. The average processing time for appeals was 196 days in civil 
cases,  81  days  in  criminal  cases  and  257  days  in  administrative  cases.  The  length  of  court 
proceedings in civil, commercial and administrative cases is still shorter than the average in 
the EU (measured in disposition time) and the number of pending cases are amongst the lowest 
in  the  EU.  Compared  to  2021,  the  clearance  rate  decreased  slightly  from  101%  to  99%. 
However,  this  still  means  that  courts  were  generally  able  to  cope  with  incoming  cases58. 
Overall, the advanced digitalisation of justice has  allowed the courts to  remain consistently 
efficient over the past several years. 

II. 

ANTI-CORRUPTION FRAMEWORK  

The anti-corruption institutional set-up remains the same in comparison to the 2022 Rule of 
Law Report. The Ministry of Justice is in charge of the preparation, oversight and coordination 
of  the  anti-corruption  Action  Plan  2021-2025.  The  Anti-Corruption  Select  Committee 
exercises  parliamentary  scrutiny  over  the  implementation  of  anti-corruption  measures.  The 
Political  Parties’ Financing Surveillance Committee oversees  political  parties’ funding. The 
Corruption Crimes’ Office of the National Criminal Police is a specialised unit responsible for 
carrying out investigations on corruption cases, and the Internal Security Service is responsible 

50   See 2022 Rule of Law Report, Country Chapter on the rule of law situation in Estonia, p. 5. 
51   According to the Council for the administration of courts there has not been a significant change in the cases 
brought before the courts since the increase of the court fees. Information received in the context of the country 
visit.  

52   Information received from the Constitutional Review Chamber of the Supreme Court. 
53   Figures 6-10 and 17-24, 2023 EU Justice Scoreboard. 
54   It should be noted that about 90% of the criminal cases are resolved in simplified proceedings. Furthermore, 
on  1  May  2023  the  amendments  in  the  Code  of  Criminal  Procedure,  that  were  adopted  were  adopted  in 
February  2023,  entered  into  force.  These  amendments  are  aimed  at  to  simplifying  the  general  criminal 
proceedings and therefore further enhance the efficiency in criminal cases. 

55   The correct number for the average time of resolving a criminal case in general proceedings in 2021 was 246 
days instead of 192, which was mentioned in the 2022 Rule of Law Report. Factual correction provided by the 
Ministry of Justice. 

56   See 2022 Rule of Law Report, Country Chapter on the rule of law situation in Estonia, p. 6  - In 2021, civil 
cases were resolved in 101 days on average, criminal cases were resolved on average in 192 days in general 
criminal  proceedings,  24  days  in  simplified  proceedings  and  44  days  in  misdemeanour  cases.  In  the  first 
instance courts, administrative cases were resolved in an average of 127 days.  

57   Input from Estonia for the preparation of the 2023 Rule of Law Report, p. 3.  
58   Figures 11-16, 2023 EU Justice Scoreboard. 

8 

 
                                                           
for  investigating  corruption  offences  committed  by  higher  state  officials  and  higher  local 
government  officials  in  six  larger  municipalities.  The  Prosecutor’s  Office  supervises  and 
directs pre-trial criminal investigation proceedings on corruption offences and represents the 
public prosecution in courts. 

The perception among experts and business executives is that the level of corruption in 
the  public  sector  remains  relatively  low.  In  the  2022  Corruption  Perceptions  Index  by 
Transparency  International, Estonia scores 74/100 and ranks 8th in the European Union and 
14th globally59. This perception has been relatively stable over the past five years60. The 2023 
Special  Eurobarometer  on  Corruption  shows  that  48%  of  respondents  consider  corruption 
widespread in their country (EU average 70%) and 18% of respondents feel personally affected 
by  corruption  in  their  daily  lives  (EU  average  24%)61.  As  regards  businesses,  27%  of 
companies  consider  that  corruption  is  widespread  (EU  average  65%)  and  7%  consider  that 
corruption  is  a  problem  when  doing  business  (EU  average  35%)62.  Furthermore,  38%  of 
respondents find that there are enough successful prosecutions to deter people from  corrupt 
practices  (EU  average  32%)63,  while  49%  of  companies  believe  that  people  and  businesses 
caught for bribing a senior official are appropriately punished (EU average 30%)64.  

The  2021-2025  Anti-Corruption  Action  Plan  is  being  implemented  efficiently.  The 
implementation is being carried out according to the schedule and the main focus in 2022 was 
on issues  regarding lobbying and the conflicts  of interest65. As a result concrete steps were 
taken in view of ensuring the efficient implementation of soft law in this regard, in particular 
ensuring  advice  on  individual  situations,  trainings  as  well  as  extensive  guidance.  The  anti-
corruption network continues to efficiently support the implementation process and provide a 
useful  forum  for  discussion  and  exchange  of  opinions  among  both  governmenal  and  other 
stakeholders66. It met four times in 2022 and its composition remains unchanged gathering both 
governmental and civil society representatives.  

Amendments to the Anti-Corruption Act are under preparation. In 2022, the Ministry of 
Justice announced the intention to prepare draft amendments to the Anti-Corruption Act, which 
are expected to clarify the current rules set in the law67. This regards for example the procedure 
for notification of exceptions to procedural restrictions and the disclosure of non-application 
of  restrictions,  which  is  expected  to  be  specified.  Declaration  of  investments  in  virtual 

59   Transparency International, Corruption Perceptions Index 2022, pp. 2-3. The level of perceived corruption is 
categorised  as  follows:  low  (the  perception  among  experts  and  business  executives  of  public  sector 
corruption scores above 79); relatively low (scores between 79-60), relatively high (scores between 59-50), 
high (scores below 50). 

60   In 2018 the score was 73, while, in 2022, the score is 74. The score significantly increases/decreases when it 
changes  more  than  five  points;  improves/deteriorates  (changes  between  4-5  points);  is  relatively  stable 
(changes from 1-3 points) in the last five years. 

61 Special Eurobarometer 534 on Corruption (2023). The Eurobarometer data on citizens’ corruption perception 

and experience is updated every year. The previous data set is the Special Eurobarometer 523 (2022). 

62 Flash Eurobarometer 524 on Businesses’ attitudes towards corruption in the EU (2023). The Eurobarometer 
data  on  business  attitudes  towards  corruption  as  is  updated  every  year.  The  previous  data  set  is  the  Flash 
Eurobarometer 507 (2022). 

63   Special Eurobarometer 534 on Corruption (2023).  
64   Flash Eurobarometer 524 on Businesses’ attitudes towards corruption in the EU (2023).  
65   Information received in the context of the country visit to Estonia from the Ministry of Justice.  
66   Information received in the context of the country visit to Estonia from the Ministry of Justice, Border Guard 

Board and Transparency International.  

67   Information received in the context of the country visit to Estonia from the Ministry of Justice.  

9 

 
                                                           
currencies and crowdfunding are expected to be made mandatory. While the rules stemming 
from the Anti-Corruption Act are considered useful in terms of ensuring the submission of the 
declarations  of  interest68,  the  Anti-Corruption  Select  Committee  of  the  Parliament  is  of  the 
opinion  that  the  registration  system  should  be  refined  in  order  to  process  succesfully  the 
verification process  without  recourse to  manual  procedures69. Based on the feedback of the 
ministries  and  other  stakeholders,  the  Ministry  of  Justice  prepared  a  draft  law,  which  is 
expected to be approved by the Government still in 2023. 

The  authorities  deal  efficiently  with  the  investigation  and  prosecution  of  corruption-
related cases. In 2022, 42 corruption-related offences were investigated, six were sent to court 
and five cases terminated on expediency70. The authorities report that the number of cases has 
been decreasing while their complexity has increased71. The Prosecutor’s Office reported on 
22  cases  currently  being  handled,  including  seven  high-level  corruption  cases72.  The 
Prosecutor’s  Office  is  composed  of  40  prosecutors  responsible  for  prosecuting  white-collar 
crimes (corruption, economic crimes and cybercrime). The Office received additional funds in 
order to investigate white collar crimes73 and generally reports to have sufficient resources and 
training in view of fighting corruption74. As regards the prosecution of foreign bribery, there 
are some who consider the enforcement to be ‘limited’, due to statutes of limitations that could 
create  barriers  to  enforcement  such  as  premature  termination  of  proceedings75.  As  regards 
cooperation  with  the  EPPO,  Estonia  is  expecting  to  recruit  additional  1-2  EPPO  delegated 
prosecutors in 2023. Overall, cooperation between the authorities and EPPO is constructive76. 
The  primary  sectors  with  a  high  corruption  risk  remain  the  healthcare  sector77,  the  local 
government and political party financing78.  

68   Information received in the context of the country visit to Estonia from the Anti-Corruption Select Committee. 
69   Information received in the context of the country visit to Estonia from the Anti-Corruption Select Committee. 
70   Input from Estonia for the 2023 Rule of Law Report.  
71   Information received in the context of the country visit to Estonia from the Police and Border Guard. 
72   This includes also the case involving the Porto Franco development project in Tallinn that led to the resignation 
of the previous Government in January 2021. Information received in the context of the country visit to Estonia 
from the Prosecutor’s Office.  

73   Input from Estonia for the 2023 Rule of Law Report.  
74   Information received in the context of the country  visit to Estonia from the Police and Border Guard.  The 
Ministry of Justice together with universities prepared and made available e-learning materials on business 
ethics, corruption and economic crimes. The purpose of the materials is to increase the knowledge of business 
students about business corruption and economic crimes.  

75   Transparency  International,  2022,  Exporting  Corruption;  covering  period  2018-2021.  The  study  offers  a 

classification in four categories, where “limited enforcement” is the third out of the four.  

76   Input from EPPO for the 2023 Rule of Law Report. Ministry of Justice, Ministry of Interior, Police and Border 
Guard, Internal Security Service, Tax and Customs Board carried out a study trip to EPPO in the 1st half of 
2023 – Input from Estonia for the 2023 Rule of Law Report.  

77   With regard to health care, in 2023 the Ministry of Justice intends to map challenges relating to healthcare-
specific  corruption  prevention  and  gain  through  specific  studies  in-depth  knowledge  about  corruption  in 
procurement related to medical equipment. The idea is to conduct a comparative study between Estonia and 
other EU members on procurement management in hospitals, comparing procurement prices and procurement 
systems and to map the scope of contractual partners’ subsidies to hospitals and their employees (e.g. through 
travel subsidies, etc). – Input from Estonia for the 2023 Rule of Law Report. The Flash Eurobarometer on 
Businesses’ attitudes towards corruption in the EU shows that 15% of companies in Estonia (EU average 26%) 
think that corruption has prevented them from winning a public tender or a public procurement contract in 
practice in the last three years. 

78   Input from Estonia for the 2023 Rule of Law Report. 

10 

 
                                                           
Efforts were made on effective implementation of the Guidelines on Conflicts of Interest. 
The 2022 Rule of Law Report recommended to Estonia to “ensure that the guidelines on the 
conflict  of  interests  are  subject  to  an  effective  verification,  monitoring  and  enforcement 
mechanism”79. In 2022, in the context of the implementation of the Guidelines for ministers 
and their advisers to avoid conflicts of interest80, it was decided by the anti-corruption network 
that each ministry would appoint individuals responsible for ad hoc consultations for matters 
related to conflicts of interest, gifts and other related topics for ministers and their advisers81. 
Moreover, on 2 November 2022, the anti-corruption network agreed on a proactive procedure 
for enforcement of the existing rules, namely on introductory sessions to incoming ministers 
carried out by each ministry. Besides this, the State Chancellery has included guidelines on 
prevention of conflict of interest to the handbook received by each minister at the beginning of 
their  term.  For  this  purpose,  changes  to  the  Rules  of  Procedure  of  the  Government  of  the 
Republic are currently being consulted with the ministries. Those changes are expected to give 
more  focused  guidance  to  the  ministers  and  their  advisers82.  As  a  follow-up,  the  relevant 
guidance on the responsibilities together with recommendations are expected to be provided as 
well  as  assistance  in  completion  of  the  e-training  programme83,  which  also  includes  a  self-
check test. The minister and the political advisers are expected to give feedback to the relevant 
service about the completion of the training. While it is too early to assess the impact of these 
procedures,  some  are  confident  that  they  are  useful  and  potentially  sufficient84.  The  new 
procedures  aim  at  raising  awareness  of  rules  in  place  as  well  as  ensuring  the  necessary 
monitoring  on  how  those  rules  are  applied.  However,  they  do  not  provide  the  enforcement 
mechanism, which would allow addressing possible breaches. Furthermore, a number of other 
entities (municipalities, institutes, state departments) made the e-learning course mandatory for 
their employees85. To further strengthen the guidelines for conflict of interest, new procedures 
have been introduced, including setting up the anti-corruption contact points and assistance to 
the  ministers  and  their  advisors  in  getting  acquainted  with  the  rules  in  place.  Therefore, 
significant progress has been made in view of the 2022 Rule of Law Report recommendation 
to ensure that the guidelines on the conflict of interests are subject to an effective verification, 
monitoring and enforcement mechanism. 

A new amendment was adopted concerning revolving doors for members of Government. 
New  legislation  was  adopted  on  1  August  2022  concerning  post-employment  rules  for 
members  of  Government86.  It  foresees  a  cooling  off  period  after  the  term  of  office  of  the 

79   See 2022 Rule of Law Report, Country Chapter on the rule of law situation in Estonia, p. 2 
80   Estonian Government (2021), Guidelines for Ministers and their advisers to avoid conflicts of interest, paras. 

12-13. 

81   Input from Estonia for the 2023 Rule of Law Report. 
82   According  to  the  wording  of  the  draft:  §  271.  Advising  a  member  of  the  Government  of  the  Republic  on 
corruption  prevention  issues  Ministers  shall  be  advised  by  the  Ministries  and  the  Prime  Minister  shall  be 
advised  by  the  State  Chancellery  on  matters  relating  to  reconciliation  of  the  duties  of  a  member  of  the 
Government of the Republic, restrictions related to leaving office, as well as requirements arising from the 
Anti-corruption Act and instructions given to avoid conflicts of interest, and good practice in communication 
with lobbyists. Input from Estonia for the 2023 Rule of Law Report. 

83   So far 2094 persons have registered to follow the course. Written contribution from the Ministry of Justice in 

the context of the country visit to Estonia. 

84   Information  received  in  the  context  of  the  country  visit  to  Estonia  from  the  Ministry  of  Justice  and 

Transparency International. 

85   Input from Estonia for the 2023 Rule of Law Report. 
86   § 121. Limitation of activities of a member of the Government of the Republic after the end of the mandate A 
member of the Government of the Republic may not act as a member of the management or control body in a 

11 

 
                                                           
Government members has expired. On its basis the person in question may not act as a member 
of the management or control body in a private legal entity, falling under the jurisdiction of the 
ministry headed by him or her,  during the six months following the end of their mandate87. 
These  amendments  were  introduced  to  follow-up  on  the  GRECO  recommendation88.  Civil 
society have expressed discontent that the non-profit organisations are not covered by the new 
rules as the movement between the private and public sector is much related also to them89. 

Efforts were made in relation to effective implementation of the Guidelines on Lobbying. 
The 2022 Rule of Law Report recommended to Estonia to “continue the efforts in effective 
implementation  of  the  guidelines  on  lobbying”.  In  2022,  in  relation  to  the  Guidelines  on 
lobbying90 contact persons in each ministry were established in case of doubts regarding the 
functioning of the guidelines91. The lobby meetings are systematically declared by the officials 
and  regularly  updated  in  the  central  registers  where  lobbyists,  public  officials,  topic  of  the 
meetings  and  dates  of  the  meetings  can  be  identified.  In  2022,  the  Ministry  of  Justice  and 
Transparency  International  Estonia  analysed  the  data  on  disclosed  lobbying  meetings.  As  a 
result, the 10 best performing entities have received the title of transparent policy maker, which 
is placed on the website of the awared entity92. From the second quarter of 2021 to the third 
quarter of 2022, almost 1200 lobby meetings were disclosed by state institutions. Based on the 
latest available data, over 60% of lobbyists represented the private sector93. The analysis of 
information from the ministries, analysing the quality of conduct and updating the ranking of 
best perfomers94 is expected to be carried out quartlerly95. According to the Ministry of Justice, 
this  practice  has  an  awareness-raising  and  encouraging  value  and,  as  a  result,  no  other 
initiatives in this regard are planned96. As a follow-up to a series of roundtables on legislative 
transparency and integrity with regard to lobbying organised  in 202297, the Anti-Corruption 
Select Committee of the Parliament proposed to introduce guidelines on lobbying also in the 
Parliament98, but currently no decision has been taken in this regard. The rules regarding lobby 
activities continue to  be promoted and actively  monitored by the authorities. Therefore, the 

private  legal  entity  that  falls  under  the  jurisdiction  of  the  ministry  headed  by  him  during  the  six  months 
following the end of his mandate, if the minister has made decisions with significant impact on the activities 
of this legal entity during his term of office, or if the legal entity has contractual relations with the ministry 
headed by him. The restriction does not apply to a non-profit organisation. Amendment to the Government of 
the Republic Act (GRA) (Government of the Republic Act–Riigi Teataja) adopted in 01.08.2022 (entered into 
force on 19.08.2022). 

87   It concerns cases when then the minister made decisions with significant impact on the activities of this legal 
entity during his/her term of office, or if the legal entity has contractual relations with the ministry headed by 
him/her. The restriction does not apply to a non-profit organization. 

88   GRECO Fifth Evaluation Round – Compliance Report, recommendation iii, para. 18. 
89   Information received in the context of the country visit to Estonia from Transparency International.  
90   Estonian  Government  (2021),  Good Practice  in  Communicating  with  Lobbyists  for  Officials.  Summary  of 

lobby meetings. 

91   Input from Estonia for the 2023 Rule of Law Report. 
92   Transparency  International  Estonia,  Press  release  of  09.12.2022,  Press  release;  Ranking:  The  ten  most 

exemplary notifiers concerning lobbying meetings revealed.  

93   Transparency  International  Estonia,  Summary  of  meetings  between  authorities  and  lobbyists  in  2021, 

30.05.2022 

94   The list of the best performers is regularly updated and available online.  
95   Information received in the context of the country visit to Estonia from the Ministry of Justice. 
96   Input from Estonia for the 2023 Rule of Law Report. According to the OECD accountability of public policy 

making indicators on lobbying safeguards in place, Estonia marks 6 out of 9.  

97   2022 Rule of Law Report, Country Chapter on the rule of law situation in Estonia, p. 8 
98   Written contribution from the Anti-Corruption Select Committee in the context of the country visit to Estonia. 

12 

 
                                                           
2022 Rule of Law Report recommendation to continue the efforts in effective implementation 
of the guidelines on lobbying has been fully implemented.  

The adoption of the draft law aiming at strengthening the powers of the Political Parties’ 
Financing Surveillance Committee is still pending. The draft law discussed in the previous 
Rule of Law Reports99 extending the investigating powers of the Committee through a legal 
basis  for  requesting  documents,  information  and  explanations  from  third  parties  has  not 
progressed since summer 2022 when it was sent for public consultations100. The intention of 
the  Ministry  of  Justice  is  to  have  it  considered  by  the  new  Government  in  the  first  half  of 
2023101.  

Legislation on whistleblower protection has not yet been adopted102. The Anti-Corruption 
Action  Plan  2021–2025  foresees  the  adoption  of  the  whistleblower  protection  act  and  the 
establishment of a replicable electronic whistleblower reporting channel103. The draft law104 
for a new comprehensive regulation105 was sent to the consultation round106. The Ministry of 
Justice  expects  to  present  it  to  the  Government  in  the  second  half  of  2023107.  Meanwhile, 
awareness-raising activities in this regard were carried out in 2022, including the development 
of the internal whistleblower hotline in the Ministry of Justice, the creation of a confidential e-
mail address for reporting within the Police and Border Guard and making it possible to submit 
reports directly to the designated person108. Whistleblower reports play an important role in 
uncovering corruption in the Corruption Crime Bureau of the Central Criminal Police and their 
number remains on the rise109. 

III.  MEDIA PLURALISM AND MEDIA FREEDOM 

In Estonia, the freedom of expression finds legal and formal protection in the Constitution110. 
Secondary legislation expressly ensures the right of journalists to protect their sources, fosters 
media  freedom  in  the  radio  and  television  sector111  and  provides  safeguards  for  the 

99   See 2021 Rule of Law Report, Country Chapter on the rule of law situation in Estonia, p. 8 and the 2022 Rule 

of Law Report, Country Chapter on the rule of law situation in Estonia, p. 9.  

100  Estonian Public Broadcasting, 22 September 2022, The draft law that aimed to toughen the supervision of 

political funding has stalled. 

101  Information received in the context of the country visit to Estonia from the Ministry of Justice. 
102  On 14 April 2023, the European Commission referred Estonia to the Court of Justice of the European Union, 
transpose  EU 

pursuing 
Directive2019/1937 on the protection of persons reporting breaches of Union law. 

launched  against  Estonia  for  failure 

infringement  proceedings 

the 

to 

103  Anti-Corruption Action Plan 2021 – 2025. 
104  Draft Whistleblower Protection Act 504 SE. 
105  This initiative has been proposed in view of aligning the national legislation with the Directive (EU) 2019/1937 
of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report 
breaches of Union law; Information received from the Ministry of Justice in the context of the country visit to 
Estonia. 

106  Press release of 1 June 2023, Ministry of Justice, The draft protection of whistleblowers in the field of work 

went to the coordination round. 

107  Input from Estonia for the 2023 Rule of Law Report. 
108  Input from Estonia for the 2023 Rule of Law Report. 
109  Corruption Crime Bureau, Overview of Bureau’s Activities 2018-2019.  
110  Constitution  of  the  Republic  of  Estonia,  §  44-46.  Estonia  ranks  8th  in  the  2023  Reporters  without  Borders 

World Press Freedom Index compared to 4th in the previous year. 

111  Media Services Act, §15 and 13. 

13 

 
                                                           
independence of the public service broadcaster112. The right to information, including access 
to documents, is explicitly recognised in the Constitution, in the Public Information Act113 and 
in the Personal Data Protection Act114.  

The responsibilities and resources of the media regulator, the Consumer Protection and 
Technical Regulatory Authority, have been strengthened. As mentioned in the 2022 Rule 
of Law Report115, and as part of the transposition of the revised Audiovisual Media Services 
Directive116, the amended Media Services Act entrusted new functions and competences to the 
national media regulator. The new functions relate to, for example, the supervision of video-
sharing platforms, as provided for in the revised AVMSD. The media regulator reports that it 
has gained powers also in new areas linked to the Regulation addressing the dissemination of 
terrorist content online117 and the Digital Services Act118, as a consequence of which it has been 
granted additional staff and better technical tools119. The MPM 2023 maintains a low risk score 
with regard to the independence and effectiveness of the media authority120. Since the 2022 
Rule  of  Law  Report,  no  regulatory  changes  regarding  transparency  of  media  ownership  or 
restrictions  to  media  ownership  and  concentration  have  been  reported.  The  MPM  2023 
considers the transparency of media ownership and the plurality of media providers to carry 
high  risks  because  the  existing  ownership  transparency  rules  do  not  cover  print  and  digital 
media and the media market is rather concentrated121. However, as regards the transparency of 
media ownership, despite the findings of the MPM 2023, information about the ownership of 
all types of media companies is in practice widely accessible in the electronic business register 
free of charge122. 

Public service media receives a high level of trust and increased resources. Citizens tend 
to trust public service broadcasting more than commercial broadcasting and the level of trust 
has  been  continuously  high123.  Public  service  media  reports  an  increase  in  its  resources 
compared  to  the  period  covered  by  the  2022  Rule  of  Law  report124  but  expressed  concerns 

112  Estonian Public Broadcasting Act; According to European Parliament’s Flash Eurobarometer: News & Media 
Survey 2022, Estonia is among top 3 Member States where citizens demonstrate the highest trust in public TV 
and radio stations (incl. online). 

113  Public Information Act. 
114  Personal Data Protection Act. 
115  2022 Rule of Law Report, Country Chapter on the rule of law situation in Estonia, p. 10 - 11. 
116  Directive (EU) 2018/1808 of the European Parliament and of the Council of 14 November 2018 amending 

Directive 2010/13/EU. 

117  Regulation (EU) 2021/784 of the European Parliament and of the Council of 29 April 2021. 
118  Regulation (EU) 2022/2065 of the European Parliament and of the Council of 19 October 2022 on a Single 

Market for Digital Services and amending Directive 2000/31/EC. 

119  Information received from the Consumer Protection and Technical Regulatory Authority in the context of the 

country visit to Estonia. 

120  2023 Media Pluralism Monitor, country report for Estonia, p. 14. 
121  2023 Media Pluralism Monitor, country report for Estonia, p. 16. 
122  Based on information received from the Government and confirmed by the Estonian Press Council and the 
Estonian  Association  of  Journalists  in  the  context  of  the  country  visit  to  Estonia.  The  business  register  is 
available at: https://rik.ee/en/e-business-register. 

123  Turu-Uuringute AS, Trust in Institutions: Estonian Public Broadcasting 2017-2022; European Parliament’s 
Flash Eurobarometer: News & Media Survey 2022; Jõesaar, A., Jastramskis, D., Rožukalne, A. (2022), Trust 
in Public Service Media in the Baltic States. Journal of Baltic Studies, 53:4, p. 587-611; Information received 
from the Ministry of Culture in the context of the country visit to Estonia. 

124  2022 Rule of Law Report, Country Chapter on the rule of law situation in Estonia, p. 12. 

14 

 
                                                           
about its long-term sustainability to produce public service content125. Since the 2022 Rule of 
Law report126, a new Management Board of the public service media has been appointed for a 
five-year  mandate  and  its  members  have  partly  changed.  While  no  regulatory  changes  are 
envisaged to affect the existing safeguards against government or political interference of the 
public service media, MPM 2023 considers this to be an area presenting low risk score127.  

Some progress has yet been made on the recommendation to improve the right of access 
to information. The 2022 Rule of Law Report recommended Estonia to “ensure consistent and 
effective  practical  implementation  of  the  right  of  access  to  information  taking  into  account 
European standards on access to official documents”128. So far, only initial research has been 
conducted  on  the  implementation  of  the  constitutionally  protected  right  of  access  to 
information  in  view  of  possible  further  action.  Notably,  the  Parliament  has  procured  an 
independent study129, which identified key problems related to access to public information, 
including a controversial role of the Data Protection Inspectorate which carries out both the 
supervision of granting access to information and the monitoring of compliance with personal 
data  protection.  Additionally,  the  study  considered  that  the  current  legislation,  which 
encourages  restrictions  to  access  to  information  and  puts  the  accent  on  the  protection  of 
personal data, does not give adequate protection to the right to freedom of information. The 
research  confirmed  that  the  rules  and  practices  for  the  release  of  information  vary  amongst 
authorities, as reported in the previous Rule of Law reports130 and still flagged by stakeholders 
particularly  as  regards  local  governments131.  The  study  is  aimed  at  providing  input  for  the 
future analysis of possible solutions and whether there is a need for amendments of the Public 
Information Act132. The MPM maintains a medium risk with regard to the protection of right 
to information, albeit slightly lower compared to the previous year133. For these reasons, it is 
considered that some progress has been made to address the 2022 recommendation.  

The Supreme Court has upheld the confidentiality of journalistic sources and freedom of 
the press. The Supreme Court established that a journalist or a publication can refuse to reveal 
the  identity  of  a  source  in  civil  court  even  if  the  latter  has  provided  false  information134, 
clarifying the law on the protection of journalistic sources. This clarification was welcomed by 
stakeholders135. In another case concerning potential state interference, the Supreme Court has 
upheld  the  judgment  of  the  appeal  court  mentioned  in  the  2022  Rule  of  Law  report136.  It 
annulled fines imposed on two journalists and a news outlet after they published information 

125  Information received from the public service media in the context of the country visit to Estonia. 
126  2022 Rule of Law Report, Country Chapter on the rule of law situation in Estonia, p. 11– 12. 
127 2023 Media Pluralism Monitor, country report for Estonia, p. 22. 
128  2022 Rule of Law Report, Country Chapter on the rule of law situation in Estonia, p. 2. 
129  Foresight  Centre:  Pild,  M.,  Turk,  K.,  Kose,  K.,  Lehemets,  M.  (2022),  Trends  in  access  to  public  sector 

information: Summary – The future of Data Freedom research team. 

130  2020 Rule of Law Report, Country Chapter on the rule of law situation in Estonia, p. 8; 2021 Rule of Law 
Report, Country Chapter on the rule of law situation in Estonia, p. 10; 2022 Rule of Law Report, Country 
Chapter on the rule of law situation in Estonia, p. 12. 

131  Information  received  from  the  Estonian  Press  Council  and  the  Estonian  Association  of  Journalists  in  the 

context of the country visit to Estonia. 

132  Input from Estonia for the 2023 Rule of Law Report, p. 11. 
133 2023 Media Pluralism Monitor, country report for Estonia, p. 12-13. 
134  Supreme Court, order of 12 December 2022, 2-21-17817. 
135  Information  received  from  the  Estonian  Press  Council  and  the  Estonian  Association  of  Journalists  in  the 

context of the country visit to Estonia. 

136 2022 Rule of Law Report, Country Chapter on the rule of law situation in Estonia, p. 13. 

15 

 
                                                           
about pre-trial criminal proceedings without seeking permission or informing the Prosecutor’s 
office, which is required under the law137. The Court found that interference with the freedom 
of  the  press  would  have  to  be  thoroughly  considered  and  justified.  The  judgment  has  been 
welcomed by stakeholders138  although some have  warned  against risks of self-censorship if 
journalists  reporting  about  criminal  proceedings  are  afraid  of  receiving  large  fines139. 
Following  the  judgment,  the  Prosecutor  General  expressed  hope  that  journalists  will  treat 
information with care and the prosecution and journalists would be able to agree on whether to 
disclose pre-trial proceedings in specific cases140. Since the 2022 Rule of Law report, no new 
alerts  for Estonia have been published on the Council of Europe’s Platform  to  promote the 
protection of journalism and safety of journalists141. The MPM 2023 notes that attacks against 
journalists in Estonia are extremely rare but journalists have been exposed to a growing number 
of online threats by private individuals142.  

IV.  OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES 

Estonia is a parliamentary republic with a single-chamber Parliament. Estonia does not have a 
Constitutional court but the Supreme Court’s Constitutional Review Chamber can carry out ex 
post  constitutional  review,  including,  under  certain  conditions,  based  on  a  constitutional 
complaint143.  In addition  to the justice system, the  Office of the Chancellor for Justice (the 
ombudsperson) plays a role144 in the system of checks and balances. Involvement of the public 
and stakeholders in public affairs is supported by advanced Information and Communication 
Technology tools. 

Significant progress has been achieved on the 2022 recommendation regarding the new 
digital  platform  for  further  improving  the  law-making  process.  The  2022  Rule  of  Law 
Report recommended to Estonia to “continue advancing with the digital platform to make the 
legislative process even more visible and inclusive for public consultation”. The Ministry of 
Justice continues working on the ‘Co-creation workspace project’, which aims to create a new 
digital platform to improve the law-making process and improve stakeholders’ involvement145. 
The  project  has  been  launched  and  pilots  are  under  way  or  about  to  be  started  in  different 

137  Supreme Court, order of 31 January 2023, 1-22-1949. 
138  Information  received  from  the  Estonian  Press  Council  and  the  Estonian  Association  of  Journalists  in  the 

context of the country visit to Estonia. 

139  2022  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law  situation  in  Estonia,  p.13;  Estonian  Media 
Association  (2023),  The  Media  Association  welcomes  the  Supreme  Court’s  decision  to  refuse  to  fine 
journalists; ERR news (2023), Delfi chief satisfied with court decision but self-censorship a concern. 

140  ERR news (2023), Prosecutor general: I hope journalists will treat information with care. 
141  Council of Europe, Platform to promote the protection of journalism and safety of journalists, Estonia. 
142 2023 Media Pluralism Monitor, country report for Estonia, p. 13. 
143  § 4 of the Constitutional Review Court Procedure Act – A complaint can be referred to the Supreme Court’s 
Constitutional Review Chamber by the President of the Republic, the Chancellor of Justice, a local government 
council and the Parliament. § 9 of the Constitutional Review Court Procedure Act – Constitutional review on 
the basis of court judgment or court ruling is also possible. 

144  The Chancellor of Justice has a broad mandate, including acting as the National Preventive Mechanism under 
the UN Convention Against Torture and the National Monitoring Mechanism under the UN Convention on 
the  Rights  of  Persons  with  Disabilities.  The  Chancellor  of  Justice  also  performs  the  functions  of  the 
Ombudsperson for Children. 

145  See  2022  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law  situation  in  Estonia,  pp.  13-14 –  Even 
though the current public consultation process in Estonia already takes place via an online platform, the new 
project,  which  would  replace  the  current  online  platform  for  public  consultation,  is  meant  to  improve  the 
visibility of the ongoing procedures and encourage wider public participation. 

16 

 
                                                           
ministries. As of now, the text editor for co-drafting is made available for the ministries, with 
the possibility to involve stakeholders in the process at a later stage146. The developers of the 
project are receiving feedback daily from the current users of the platform. Conclusions on the 
implementation and usability of the platform would be available by mid-2023147. Considering 
these developments, while noting that some features of the new digital platform still are being 
developed and rolled out to the public, including giving stakeholders access to the platform148, 
significant progress was achieved in fulfilling the recommendation from the 2022 Rule of Law 
Report. 

The Chancellor of Justice continues to play an active role in upholding the rule of law. In 
the  fall  of  2022,  the  Chancellor  of  Justice,  which  has  an  A-status  accreditation  from 
GANHRI149, published its annual report covering the period of 1 September 2021 to 31 August 
2022150.  In  2022,  the  Chancellor  of  Justice  made  eight  proposals  to  bring  legislation  in 
conformity  with  the  Constitution.  The  Chancellor  also  issued  a  total  of  14  memoranda  to 
Parliament, ministries, and local governments on the need to initiate legislation. Some of the 
issues raised have been resolved, but others are still being worked on. The Chancellor of Justice 
further  submitted  two  requests  to  the  Supreme  Court  to  declare  legislation  or  a  norm 
unconstitutional151. Under the Courts Act, alongside the chairs of the courts and the Supreme 
Court sitting in  full court,  the Chancellor of Justice is  the only institution outside the  court 
system that may initiate disciplinary proceedings in respect of a judge152. The final decision in 
these proceedings  is  made by the disciplinary chamber operating under the Supreme Court. 
The Chancellor can only assess whether a judge has failed to fulfil his/ her official duties or 
has behaved disreputably, but not substantive issues concerning the administration of justice 
or  the  merits  of  judicial  decisions153.  During  the  reporting  period,  on  fifteen  occasions  the 
Chancellor  had  to  check  whether  a  court  had  fulfilled  all  its  official  duties  or  whether  a 
complaint about disreputable conduct by a judge was justified. The Chancellor did not find a 
reason to initiate disciplinary proceedings in respect of a judge in any of the cases 154. 

On 1 January 2023, Estonia had three leading judgment of the European Court of Human 
Rights pending implementation, an increase of two compared to the previous year155. At 
that time, Estonia’s rate of leading judgments from the past 10 years that remained pending 
was at 14% (compared to 5% in 2022) and the average time that the judgment had been pending 

146  Information received from the Minister of Justice in the context of the country visit to Estonia. 
147  Ibid. 
148  E.g. Improving the internal cooperation between state authorities; improving the text editor for drafting laws; 

giving general public access to the platform and launching the feature for public consultations. 

149  Global Alliance of National Human Rights Institutions. 
150  Overview of the Chancellor of Justice of Estonia Activities.  
151  See Written contribution from ENNHRI on Estonia for the preparation of the 2023 Rule of Law Report, p. 7. 

See also Input from Estonia for the preparation of the 2023 Rule of Law Report, p. 13. 

152  §91 of the Courts Act. 
153  Overview of the Chancellor of Justice of Estonia Activities, p. 44. 
154  See previous footnote. 
155  The  adoption of necessary execution  measures  for a  judgment by the European  Court of Human  Rights is 
supervised by the Committee of Ministers of the Council of Europe. It is the Committee’s practice to group 
cases against a State requiring similar execution measures, particularly general measures, and examine them 
jointly. The first case in the group is designated as the leading case as regards the supervision of the general 
measures and repetitive cases within the group can be closed when it is assessed that all possible individual 
measures needed to provide redress to the applicant have been taken. 

17 

 
                                                           
implementation was 11 months (compared to 3 months in 2022)156. The change in the data is 
influenced by two new cases delivered against Estonia.157 On 15 June 2023, the number of 
leading judgments pending implementation remains three158. 

The civic space remains open, but concerns have been raised as regards the absence of 
clear  criteria  for  the  allocation  of  funding  to  Civil  Society  Organisations  through 
Parliament. The civic space in Estonia is considered to be open159, which has been furthered 
by the election of a Gender Equality and Equal Treatment Commissioner160. The Government 
renewed the procedure to increase transparency in the election process, by ensuring a more 
structured  approach  in  including  representatives  of  strategic  partners  in  civil  society  in  the 
decision-making  process.  For  the  candidate’s  assessment,  the  Government  cooperated  with 
Civil Society Organisations (CSOs)161, which led to the proposal of a final candidate to the 
Minister of Social Affairs162. Nevertheless, stakeholders have raised concerns163 as regards the 
modalities  of  funding  of  CSOs  through  Parliament.  As  described  in  a  petition  submitted  to 
Parliament164, there is a state budget line which is usually decided between the second and third 
readings  of  the  state  budget,  where  members  of  Parliament  can  distribute  about  EUR  3-4 
million  to  CSOs,  without  clear  criteria  or  evaluation  procedures.  For  the  2023  budget,  478 
entities were awarded a grant. Individual grants varied between EUR 2 000 and EUR 39 000. 
The total amount of money spent was EUR 3 390 000165. It would be important to take into 
account the European standards in the area of CSO funding, in particular that any form of state 
support for associations should be governed by clear and objective criteria166. 

156  All figures are calculated by the European Implementation Network and are based on the number of cases that 
are considered pending at the annual cut-off date of 1 January 2023. See the Contribution from the European 
Implementation Network for the 2023 Rule of Law Report, p. 3. 

157  Judgment  of  the  European  Court  of  Human  Rights  of  16  November  2022,  Särgava  v.  Estonia,  698/19; 
Judgment of the European Court of Human Rights of 24 January 2023, Abuladze v. Estonia, 12928/20. The 
Judgment of the European Court of Human Rights of 29 March 2022, Vool and Toomik v. Estonia, 7613/18, 
which was under enhanced supervision, was closed on 13 April 2023, see Council of Europe’s Committee of 
Ministers resolution CM/ResDH(2023)77. 

158  Data according to the online database of the Council of Europe (HUDOC-EXEC).  
159  See  rating  given  by  Civicus,  Estonia.  Ratings  are  on  a  five-category  scale  defined  as:  open,  narrowed, 

obstructed, repressed and closed. 

160  Franet (2023), Country research - Legal environment and space of civil society organisations in supporting 

fundamental rights – Estonia, p. 10. 

161  Top  Civil  Service  Excellence  Centre  and  six  representatives  of  strategic  partners  from  the  civil  society  as 
expert committee members. See written contribution from the Ministry of Justice in the context of the country 
visit to Estonia, p. 2. 

162  The Minister appointed the new Commissioner in November 2022. See written contribution from the Ministry 

of Justice in the context of the country visit to Estonia, p. 2.  

163  Information received from Open Society Estonia in the context of the country visit to Estonia. See also petition 
submitted by Network of Estonian Nonprofit Organisations (NENO) to the Parliament in the next footnote. 

164  Parliament 

Petition 

“Stop 

distributing 

roofing 

money 

in 

the 

Riigikogu” 

- 

https://rahvaalgatus.ee/initiatives/8a31585f-d7c6-4009-8833-fb5bf80a02d1.  

165  See State budget Act for 2023. 
166  See Guidelines on freedom of association by the OSCE/ODIHR, paras. 205-217. 

18 

 
                                                           
Annex I: List of sources in alphabetical order* 

* The list of contributions received in the context of the consultation for the 2023 Rule of Law report 
can 
https://commission.europa.eu/publications/2023-rule-law-report-targeted-
stakeholder-consultation_en. 

found 

be 

at 

Anti-Corruption  Select  Committee  (2023),  Written  contribution  from  the  Anti-Corruption  Select 
Committee in the context of the country visit. 

Centre for Media Pluralism and Media Freedom (2023), Media pluralism monitor 2023 – country report 
on Estonia. 

Civicus, Monitor tracking civic space – Estonia https://monitor.civicus.org/country/estonia/. 

Corruption  Crime  Bureau  (2020),  Overview  of  Bureau’s  Activities  2018-2019  kokkuvote-2018-
2019.pdf (politsei.ee). 

Council  of  Europe,  Consultative  Council  of  European  Judges  (2012),  Opinion  No.  15  on  the 
specialisation of judges. 

Council of Europe, Consultative Council of European Judges (2016),  Opinion No. 16 on the role of 
court presidents. 

Council of Europe, Platform to promote the protection of journalism and safety of journalists – Estonia 
https://fom.coe.int/en/pays/detail/11709506. 

Directive (EU) 2018/1808 amending Directive 2010/13/EU on the coordination of certain provisions 
laid down by law, regulation or administrative action in Member States concerning the provision of 
audiovisual  media  services  (Audiovisual  Media  Services  Directive)  in  view  of  changing  market 
realities. 

ERR  news  (2023),  Delfi  chief  satisfied  with  court  decision  but  self-censorship  a  concern 
https://news.err.ee/1608869882/delfi-chief-satisfied-with-court-decision-but-self-censorship-a-
concern. 

ERR  news  (2023),  Prosecutor  general:  I  hope  journalists  will  treat  information  with  care 
https://news.err.ee/1608869450/prosecutor-general-i-hope-journalists-will-treat-information-with-
care. 

Estonian  Bar  Association  (2022),  Opinion  of  10  November  2022  “Bar:  justice  hung  in  the  balance 
already in September”. 

Estonian Chancellor of Justice (2022),  Overview of the Chancellor of Justice of Estonia Activities  - 
https://www.oiguskantsler.ee/annual-report-2022/the-rule-of-law  

Estonian  Chancellor  of Justice  (2022),  Proposal  of  17  November 2022 to  the Minister of  Justice  to 
amend regulation No. 16. 

Estonian Government (2021), Guidelines for Ministers and their advisers to avoid conflicts of interest 
guidelines_for_ministers_and_their_advisers_to_avoid_conflicts_of_interest.pdf (korruptsioon.ee). 

Estonian  Government  (2021),  Good  Practice  in  Communicating  with  Lobbyists  for  Officials 
good_practice_in_communicating_with_lobbyists_for_officials_0.pdf (korruptsioon.ee). 

Estonian Government (2023), Input from Estonia for the 2023 Rule of Law Report. 

Estonian Judges Association (2023), Written contribution in the context of the country visit. 

Estonian Media Association (2023), The Media Association welcomes the Supreme Court’s decision 
to refuse to fine journalists (Meedialiit tervitab Riigikohtu otsust keelduda ajakirjanike trahvimisest) 
https://meedialiit.ee/meedialiit-tervitab-riigikohtu-otsust-keelduda-ajakirjanike-trahvimisest/. 

Estonian Ministry of Justice (2023), Written contribution from the Ministry of Justice in the context of 
the country visit. 

19 

 
Estonian  Parliament  Petition  (2019),  “Stop  distributing  roofing  money  in  the  Riigikogu”  - 
https://rahvaalgatus.ee/initiatives/8a31585f-d7c6-4009-8833-fb5bf80a02d1. 

Estonian Parliament (2021), Draft Whistleblower Protection Act. 

Estonian Parliament (2022), Constitutional committee, minutes of sitting No. 142 of 18 October 2022 

Estonian Public Broadcasting (2022), The draft law that aimed to toughen the supervision of political 
funding has stalled. 

European Commission (2020), 2020 Rule of Law Report, Country Chapter on the rule of law situation 
in Estonia. 

European Commission (2021), 2021 Rule of Law Report, Country Chapter on the rule of law situation 
in Estonia. 

European Commission (2022), 2022 Rule of Law Report, Country Chapter on the rule of law situation 
in Estonia. 

European  Commission  (2023),  2023  EU  Justice  Scoreboard.European  Court  of  Human  Rights, 
698/19, 
2022, 
judgment 
ECLI:CE:ECHR:2021:1116JUD000069819. 

November 

Estonia, 

Särgava 

16 

of 

v. 

European Court of Human Rights, judgment of 29 March 2022, Vool and Toomik v. Estonia, 7613/18. 
ECLI:CE:ECHR:2022:0329JUD000761318. 

European Implementation Network (2023), Contribution from the European Implementation Network 
for the 2023 Rule of Law Report. 

European Network for National Human Rights Institutions (2023), Written contribution for the 2023 
Rule of Law Report. 

European  Parliament  (2022),  Flash  Eurobarometer:  News  &  Media  Survey  2022,  EB-ID 
2832/FL011EP https://europa.eu/eurobarometer/surveys/detail/2832. 

European Public Prosecutor’s Office (2023), 2022 Annual Report.  

Foresight Centre: Pild, M., Turk, K., Kose, K., Lehemets, M. (2022), Trends in access to public sector 
information: 
team 
Freedom 
https://arenguseire.ee/en/reports/trends-in-access-to-public-sector-information/.  

Summary 

research 

future 

Data 

The 

of 

- 

Franet,  Estonian  Human  Rights  Center  (2023),  Country  research  -  Country  research  -  Legal 
environment  and  space  of  civil  society  organisations  in  supporting  fundamental  rights  –  Estonia, 
Vienna, EU Agency for Fundamental Rights, Rights https://fra.europa.eu/en/country-data/2023/civic-
space-report-2023. 

GRECO (2021), Fifth evaluation round – Compliance report on Preventing corruption and promoting 
integrity in central governments (top executive functions) and law enforcement agencies. 

Jõesaar, A., Jastramskis, D., Rožukalne, A. (2022), Trust in Public Service Media in the Baltic States. 
Journal of Baltic Studies, 53:4, p. 587-611. 

Lauk,  E.;Harro-Loit,  H.;  Kõuts-Klemm,  R.;  Parder,  M.-L.;  Loit,  U.  (2022),  ESTONIA.  Critical 
junctures  in  the  media  transformation  process.  In:.  Country  case  studies  on  critical  junctures  in  the 
media  transformation  process  in  Four  Domains  of  Potential  ROs  (2000–2020).  Approaching 
deliberative  communication:  Studies  on  monitoring  capability  and  on  critical  junctures  of  media 
166–201.  Mediadelcom. 
countries,  CS2,  D-2.1, 
development 
https://www.mediadelcom.eu/publications/d21-case-study-2/est/. 

EU 

14 

in 

p. 

Ministry 
Justice 
korruptsioonivastane_tegevuskava_16.02.pdf. 

(2021), 

of 

Anti-Corruption 

Action 

Plan 

2021 

– 

2025 

Organization  for  Security  and  Co-operation  in  Europe  (2015),  Joint  Guidelines  on  Freedom  of 
Association. 

20 

 
Regulation (EU) 2021/784 of the European Parliament and of the Council of 29 April 2021. 

Regulation (EU) 2022/2065 of the European Parliament and of the Council of 19 October 2022 on a 
Single Market for Digital Services and amending Directive 2000/31/EC. 

Reporters without Borders (2023) – Estonia https://rsf.org/en/estonia. 

Supreme Court, order of 12 December 2022, 2-21-17817. 

Supreme Court, order of 31 January 2023, 1-22-1949. 

Transparency International Estonia (2022), Summary of meetings between authorities and lobbyists in 
2021  Kokkuvõte  ametiasutuste  kohtumistest  lobistidega  2021.  aastal  |  Korruptsioonivaba  Eesti 
(transparency.ee). 

Transparency  International  (2022),  Exporting  Corruption  2022  2022_Report-Full_Exporting-
Corruption_EN.pdf (transparencycdn.org). 

Transparency  International Estonia (2022) Press release;  Ranking: The ten most exemplary notifiers 
concerning lobbying meetings revealed. 

Transparency International (2023), 2022 Corruption Perception Index.  

Turu-Uuringute AS, Trust in Institutions: Estonian Public Broadcasting 2017-2022. 

21 

 
Annex II: Country visit to Estonia 

The Commission services held virtual meetings in February 2023 with: 

  Anti-corruption Select Committee 
  Consumer protection and Technical Regulatory Authority 
  Estonian Association of Journalists 
  Estonian Association of Judges 
  Estonian Bar Association 
  Estonian Institute of Human Rights 
  Estonian Internal Security Service 
  Estonian Public Broadcasting 
  Estonian Press Council 
  Ministry of Culture 
  Ministry of Foreign Affairs 
  Ministry of Interior 
  Ministry of Justice 
  Office of the Chancellor of Justice 
  Open Estonia Foundation 
  Political Party Financing Surveillance Committee 
  Police and Border Guard Board  
  National Audit Office 
  The Prosecutor’s Office 
  The Supreme Court and Council for the Administration of Courts 

Transparency International Estonia 

* The Commission also met the following organisations in a number of horizontal meetings:  

  ALDA (European Association for Local Democracy) 
  Amnesty International  
  Civil Liberties Union for Europe  
  Civil Society Europe 
  Culture Action Europe  
  European Centre for Press and Media Freedom  
  European Civic Forum  
  European Federation of Journalists  
  European Partnership for Democracy  
  European Youth Forum  
  Free Press Unlimited 
  Front Line Defenders 
 
 
 
 
 
  JEF Europe  
  Osservatorio Balcani e Caucaso Transeuropa 

ILGA Europe  
International Commission of Jurists 
International Federation for Human Rights (FIDH)  
International Planned Parenthood Federation European Network 
International Press Institute  

22 

 
  Philea  
  Reporters Without Borders  
  SOLIDAR 
  Transparency International EU 

23