COMMISSION STAFF WORKING DOCUMENT Bosnia and Herzegovina 2024 Report Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF REGIONS 2024 Communication on EU enlargement policy
Date: 2024-10-30
Institutions: Directorate-General for Neighbourhood and Enlargement Negotiations, European Commission
Subjects: Bosnia and Herzegovina, accession criteria, accession negotiations, pre-accession strategy, regional cooperation

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 30.10.2024  SWD(2024) 691 final  COMMISSION STAFF WORKING DOCUMENT Bosnia and Herzegovina 2024 Report Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF REGIONS 2024 Communication on EU enlargement policy                           {COM(2024) 690 final} - {SWD(2024) 690 final} - {SWD(2024) 692 final} - {SWD(2024) 693 final} - {SWD(2024) 694 final} - {SWD(2024) 695 final} - {SWD(2024) 696 final} - {SWD(2024) 697 final} - {SWD(2024) 698 final} - {SWD(2024) 699 final}  
 
 
CONTENTS 

CONTEXT ......................................................................................................................................................... 3 
1.1. 
1.2.  MAIN FINDINGS OF THE REPORT ........................................................................................................................... 4 
1.3 ASSESSMENT OF THE IMPLEMENTATION OF THE STEPS SPECIFIED IN THE COMMISSION RECOMMENDATION FOR CANDIDATE STATUS

20 

2. 

CLUSTER 1: THE FUNDAMENTALS OF THE ACCESSION PROCESS .................................................................. 23 

2.1. 

2.2.  

2.2.1. 
2.2.2. 

FUNCTIONING OF DEMOCRATIC INSTITUTIONS AND PUBLIC ADMINISTRATION REFORM ................................................... 23 
2.1.1.  
Democracy ......................................................................................................................................... 23 
2.1.2. Public administration reform .................................................................................................................... 25 
RULE OF LAW AND FUNDAMENTAL RIGHTS............................................................................................................ 28 
Chapter 23: Judiciary and fundamental rights .................................................................................. 28 
Chapter 24: Justice, freedom and security ......................................................................................... 44 
2.3. ECONOMIC CRITERIA .............................................................................................................................................. 52 
2.3.1 The existence of a functioning market economy........................................................................................ 52 
2.3.2 The capacity to cope with competitive pressure and market forces within the Union .............................. 57 
2.4. PUBLIC PROCUREMENT, STATISTICS AND FINANCIAL CONTROL ......................................................................................... 59 
Chapter 5: – Public procurement ........................................................................................................................ 59 
Chapter 18: Statistics .......................................................................................................................................... 60 
Chapter 32: Financial control .............................................................................................................................. 61 

3. GOOD NEIGHBOURLY RELATIONS AND REGIONAL COOPERATION ................................................................... 62 

4.  ABILITY TO ASSUME THE OBLIGATIONS OF MEMBERSHIP ........................................................................... 64 

CLUSTER 2: INTERNAL MARKET ....................................................................................................................................... 64 
Chapter 1: Free movement of goods ................................................................................................................... 65 
Chapter 2: Freedom of movements for workers ................................................................................................. 66 
Chapter 3: Right of establishment and freedom to provide services .................................................................. 66 
Chapter 4: Free movement of capital.................................................................................................................. 67 
Chapter 6: Company law ..................................................................................................................................... 67 
Chapter 7: Intellectual property law ................................................................................................................... 68 
Chapter 8: Competition policy ............................................................................................................................. 68 
Chapter 9: Financial services ............................................................................................................................... 70 
Chapter 28: Consumer and health protection ..................................................................................................... 71 
CLUSTER 3: COMPETITIVENESS AND INCLUSIVE GROWTH ...................................................................................................... 72 
Chapter 10: Digital transformation and media ................................................................................................... 72 
Chapter 16: Taxation ........................................................................................................................................... 73 
Chapter 17: Economic and monetary policy ....................................................................................................... 74 
Chapter 19: Social policy and employment ......................................................................................................... 75 
Chapter 20: Enterprise and industrial policy ....................................................................................................... 77 
Chapter 25: Science and research ....................................................................................................................... 78 
Chapter 26: Education and culture ..................................................................................................................... 79 
Chapter 29: Customs union ................................................................................................................................. 80 

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CLUSTER 4: THE GREEN AGENDA AND SUSTAINABLE CONNECTIVITY........................................................................................ 80 
Chapter 14: Transport policy ............................................................................................................................... 81 
Chapter 15: Energy.............................................................................................................................................. 82 
Chapter 21: Trans-European Networks ............................................................................................................... 83 
Chapter 27: Environment and climate change .................................................................................................... 84 
CLUSTER 5: RESOURCES, AGRICULTURE AND COHESION ........................................................................................................ 85 
Chapter 11: Agriculture and rural development ................................................................................................. 86 
Chapter 12: Food safety, veterinary and phytosanitary policy ........................................................................... 86 
Chapter 13: Fisheries and aquaculture ............................................................................................................... 87 
Chapter 22: Regional policy and coordination of structural instruments ........................................................... 88 
Chapter 33: Financial and budgetary provisions ................................................................................................. 89 
CLUSTER 6: EXTERNAL RELATIONS.................................................................................................................................... 89 
Chapter 30: External relations ............................................................................................................................ 89 
Chapter 31: Foreign, security and defence policy ............................................................................................... 90 
ANNEX I – RELATIONS BETWEEN THE EU AND BOSNIA AND HERZEGOVINA .............................................................................. 93 
ANNEX 2 – STATISTICAL DATA ......................................................................................................................................... 95 

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INTRODUCTION1   

1.1. 

CONTEXT  

its  membership  application 

Bosnia  and  Herzegovina  applied  for  EU  membership  in  February  2016.  The  Commission  adopted  an 
Opinion2  on 
in  May  2019,  setting  out  14  key  priorities  on 
democracy/functionality, rule of law, fundamental rights and public administration reform. In December 
2022,  the  European  Council  granted  Bosnia  and  Herzegovina  candidate  country  status3  on  the 
understanding that eight steps specified in the Commission’s recommendations4 are taken. In line with the 
Commission’s  recommendation5,  in  December  2023  the  European  Council  decided  that  it  will  open 
accession  negotiations  with  Bosnia and  Herzegovina  once  the  necessary degree  of  compliance  with  the 
membership criteria is achieved.  

The commitment of the political leadership to the strategic goal of European integration brought tangible 
results between November 2023 and March 2024 in particular with the adoption of legislation on integrity 
in  the  judiciary,  anti-money  laundering,  and  conflict  of  interest.  Following  the  Commission’s 
recommendation in its report of 12 March 2024 on progress in Bosnia and Herzegovina6, the European 
Council  decided  on  21 March  2024  to  open  accession  negotiations  with  Bosnia  and  Herzegovina.  The 
European  Council  invited  the  Commission  to  prepare  the  negotiating  framework  with  a  view  to  its 
adoption by the Council the moment all relevant steps set out in the Commission’s recommendation of 
October 2022 have been taken7. 

The  reform  dynamic  stalled  between  April  and  October  2024,  among  political  controversies  and  the 
political campaign for the October local election. Bosnia and Herzegovina has to continue taking resolute 
action to finalise reforms in line with the EU acquis and European standards, addressing all relevant steps. 

Preparations have continued in view of accession negotiations. The Commission held a first introductory 
meeting  on  24 April  2024  in  Brussels  to  explain  the  screening  process,  which  is  the  first  stage  of 
accession negotiations. Bosnia and Herzegovina has received the explanatory materials on the EU acquis.  

Bosnia  and  Herzegovina  has  actively  engaged  in  implementing  the  new  Growth  Plan  for  the  Western 
Balkans8 across the four pillars of: (i) gradual integration with the European Union’s single market; (ii) 
regional economic integration; (iii) fundamental reforms; and (iv) enhanced financial support. Bosnia and 
Herzegovina has been working on preparing its reform agenda, covering reform milestones in the areas of 
business  environment  and  private  sector  development,  the  green  and  digital  transitions,  human  capital, 
and  the  fundamentals  of  EU  accession.  Bosnia  and  Herzegovina  should  urgently  finalise  its  Reform 
Agenda and submit to the Commission for agreement.  

1  The  2024  report  is  presented  in  a  renewed  format  and  structure.  Main  findings  of  the  report,  together  with  the 
recommendations  (previously  grey  assessment  boxes)  are  brought  together  at  the  beginning  of  the  report. 
Furthermore, under the fundamentals cluster, for better readability and comparability across all reports, certain data 
is provided (also) in the form of graphs. 
2 SWD (2019) 222 final, COM(2019) 261 final. 
3 European Council conclusions, 15 December 2022. 
4 COM(2022) 528 final. 
5 COM(2023) 690 final. 
6 COM(2024) 129 final. 
7 European Council conclusions, 21 and 22 March 2024, paragraph 30. 
8 COM(2023) 691 final. 

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1.2.  MAIN FINDINGS OF THE REPORT9  

CLUSTER 1: THE FUNDAMENTALS OF THE ACCESSION PROCESS  

Democracy  

The  conduct  of  the  elections  is  negatively  affected  by  the  discriminatory elements  of the constitutional 
system and by the lack of integrity of the electoral process. Parliament needs to take measures to ensure 
that elections are conducted in line with European standards by implementing the recommendations of the 
OSCE  Office  for  Democratic  Institutions  (ODIHR),  the  Council  of  Europe  Group  of  States  against 
Corruption (GRECO) and relevant Venice Commission recommendations, and to ensure transparency of 
political party financing (Opinion key priority 1). Political parties should respect the independence of the 
Central Election Commission. 

Parliament is able to exercise its powers in a broadly satisfactory way. Legislative assemblies increased 
legislative  output.  Parliamentary  oversight  over  the  executives  remains  weak.  The  Stabilisation  and 
Association Parliamentary Committee met regularly (Opinion key priority 3).  

The  institutions  in  charge  of  the  integration  process  are  broadly  in  place.  Coordination  on  EU  matters 
needs  to  be  strengthened,  including  the  role  of  the  Directorate  for  European  Integration  (DEI).  The 
Council  of  Ministers  needs  to  improve  the  functioning  of  the  coordination  mechanism,  to  develop  a 
national programme for the adoption of the EU  acquis (Opinion key priority 2) and to urgently appoint 
the  national  IPA  coordinator  (NIPAC)  under  the  Instrument  for  Pre-accession  (IPA)  III.  The  country 
should  set  up  an  operational  negotiating  structure  following  the  European  Council  decision  to  open 
accession negotiations and appoint a chief negotiator.  

Governance  is  broadly  satisfactory.  The  Council  of  Ministers  took  action  to  adopt  EU-related  reforms 
with tangible results prior to the Commission report in March 2024, although the positive reform dynamic 
has stalled since.  The  executives have  little capacity for  coordination  and  policy  planning.  Independent 
institutions remain weak. 

Civil  society  organisations  operate  in  a  constrained  environment,  in  particular  in  the  Republika  Srpska 
entity.  Bosnia  and  Herzegovina  needs  to  ensure  meaningful  and  systematic  consultations  with  civil 
society as part of an inclusive policy dialogue and adopt a framework for the transparent funding of civil 
society organisations, thus ensuring an enabling environment for civil society (Opinion key priority 11).   

Public administration reform  

Bosnia and Herzegovina is in between an early stage and some level of preparation and made some 
progress in public administration reform (PAR), notably by (i) establishing the Coordinating Committee 
for PAR at prime ministers’ level; (ii) organising the first public financial management (PFM) dialogue in 
May  2024;  (iii)  conducting  the  public  expenditure  and  financial  accountability  (PEFA)  assessment  and 
continuing  implementation  of  the  countrywide  PFM  Strategy;  (iv)  adopting  the  state-level  civil  service 
law in March 2024; and (v) establishing in October 2023 a forum of civil service agencies to steer civil 

9  This  report  covers  the  period  from  15 June  2023  to  1 September  2024.  It  is  based  on  input  from  a  variety  of 
sources,  including  contributions  from  the  government  of  Bosnia  and  Herzegovina,  EU  Member  States,  European 
Parliament reports and information from various international and non-governmental organisations. It also includes 
the results of comparative assessments and indices produced by other stakeholders, in particular in the area of rule of 
law.  
The report uses the following assessment scale to describe the state of play: early stage, some level of preparation, 
moderately prepared, good level of preparation and well advanced. To describe progress made during the reporting 
period, it uses the following scale: backsliding, no progress, limited progress, some progress, good progress and very 
good progress. Where appropriate, interim steps have also been used. 

4 

 
 
 
service policy in a harmonised way. Bosnia and Herzegovina needs to complete essential steps to improve 
the  overall  functioning  of  its  public  administration  by  ensuring  a  professional  and  depoliticised  civil 
service and a coordinated, countrywide approach to policymaking (Opinion key priority 14). 

The  Commission’s  recommendations  from  last  year  were  partially  implemented.  In  the  coming  year, 
Bosnia and Herzegovina should in particular: 

→  adopt  and  start  implementing  a  credible  and  relevant  action  plan  on  the  PAR  strategic  framework 
2023-2027  at  each  level  of  government,  increasing  budgetary  ownership  in  implementation;  and 
strengthen the capacities of PAR coordinators; 

→  ensure coordinated and well-harmonised legislative alignment with the EU acquis across all levels of 
government through a harmonised methodology and by adopting the outstanding legal framework for 
countrywide sectoral strategic planning at state level; 

→  amend and adopt civil service laws in line with merit principles, at state, entity and cantonal level. 

Chapter 23: Judiciary and fundamental rights  

Bosnia  and  Herzegovina  has  some  level  of  preparation  to  implement  the  EU  acquis  and  European 
standards  in  the  area  of  the  judiciary  and  fundamental  rights.  Limited  progress  was  made  during  the 
reporting period, including to address the related Opinion key priorities.  

Functioning of the judiciary  

Bosnia  and  Herzegovina  is  in  between  an  early  stage  of  preparation  and  having  some  level  of 
preparation in the area of the judiciary. Limited progress was made on the functioning of the judiciary 
(Opinion key priority 6), including on addressing the findings of the expert report on rule of law issues 
(the ‘Priebe Report’)10. Persistent and evident signs of deterioration continue to require urgent measures 
to strengthen integrity and restore public trust in the judiciary. The poor functioning of the judicial system 
continued to undermine citizens’ rights and the fight against corruption. In January 2024, the obstruction 
to accessing personal data for external experts tasked with monitoring the asset declaration system were 
removed from the Law on the High Judicial and Prosecutorial Council (HJPC); the right of the HJPC to 
access additional information from natural and legal person still needs to be strenghthened. The draft new 
Law  on  the  HJPC  should  be  brought  in  line  with  the  June  2024  interim  opinion  of  the  Venice 
Commission. Bosnia and Herzegovina should submit the revised draft for a follow-up opinion, and fully 
align the draft law with its recommendations before adoption by Parliament. The Republika Srpska entity 
assembly  should  swiftly  appoint  the  two  vacant  judges  to  the  Constitutional  Court  of  Bosnia  and 
Herzegovina.  The  Republika  Srpska  entity  should  also  fully  recognise  and  enforce  the  decisions  of  the 
Constitutional Court, repealing any legislation to the contrary.  

The Commission’s recommendations from last year were only partially met and thus remain valid. In the 
coming year, Bosnia and Herzegovina should in particular: 

→  urgently appoint the vacant constitutional judges, ensuring the full composition and functioning of the 
Constitutional  Court;  and,  for  the  courts  in  general,  consistently  appoint  judges  based  on  merit, 
without prevalence of ethnic criteria, and appraise the performance of judges based on quality criteria; 

→  finalise and adopt the new laws on the HJPC and the Courts of Bosnia and Herzegovina, in line with 
Venice  Commission  recommendations,  including  by  ensuring  the  access  of  the  HJPC  to  all 
information necessary to perform integrity checks; fully implement the integrity-related provisions of 
the  Law  on  the  HJPC  to  establish  a  robust  system  of  asset  declaration  verification  under  close 
external monitoring;  

10 The ‘Priebe Report’ is available online on the website of the EU Delegation to Bosnia and Herzegovina.  

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→  adopt a new justice sector reform strategy; register the sentences of international criminal tribunals in 
domestic  criminal  records;  and  effectively  implement  the  revised  national  war  crimes  strategy, 
particularly by boosting regional cooperation. 

Fight against corruption  

Bosnia  and  Herzegovina  is  in  between  an  early  stage  of  preparation  and  having  some  level  of 
preparation  in  the  fight  against  corruption.  Some  progress  was  made  during  the  reporting  period 
(Opinion key priority 7). The state-level Law on the prevention of conflict of interest, adopted in March 
2024, is a substantial step forward, although it is not yet fully in line with European standards. In June 
2024,  Bosnia  and  Herzegovina  adopted  a  state-level  strategy  and  action  plan  on  anti-corruption. 
Legislation is still not harmonised across the country. Selective and non-transparent judicial follow-up in 
corruption  cases  of  public  resonance  is  a  cause  of  significant  concern,  along  with  pressure  and 
intimidation,  as  evidenced  in  a  number  of  high-level  cases.  The  track  record  on  fighting  corruption 
(including high-level corruption) remains weak due to operational inefficiency and political interference. 
Prosecutors’ offices however advanced in a number of investigations for high-level corruption cases. The 
number of final convictions in high-level cases remains very low, one notable exception being the final 
conviction in the Novalić et al case. Only in Sarajevo Canton is there efficient application of conflict of 
interest  rules,  verification  of  asset  declarations  and  protection  of  whistle-blowers.  Targeted  risk 
assessments and dedicated measures are needed to address corruption in the most vulnerable sectors.  

In the coming year, Bosnia and Herzegovina should in particular: 

→  complete  the  legislative  and  institutional  framework  and  step  up  implementation  of  the  rules  on 
prevention of conflict of interest and on the protection of whistle-blowers by adopting new legislation 
in  line  with  European  standards  at  all  levels  of  government  and  aligning  existing  legislation  with 
them;  

→  demonstrate progress towards establishing a track record on fighting high-level corruption; improve 

cooperation between police and prosecutors’ offices; 

→  professionalise corruption prevention bodies across the country. 

Fundamental rights  

The general framework for fundamental rights is largely in place but needs to be improved. The country 
needs  to  urgently  adopt  constitutional  and  electoral  reforms  to  ensure  that  all  citizens  are  able  to 
effectively  exercise  their  political  rights,  notably  bring  the  country’s  Constitution  into  line  with  the 
Sejdić-Finci  case  law  of  the  European  Court  of  Human  Rights  (Opinion  key  priority  4.f).  Freedom  of 
assembly  remains  restricted,  and  civil  society  is  being  targeted,  in  particular  in  the  Republika  Srpska 
entity. The entity government withdrew a draft law targeting civil society groups as ‘foreign agents’; such 
a legislative initiative should not be reintroduced, as it would mark a step backwards. Further progress is 
required  across  key  priorities  9-13.  The  Commission’s  recommendations  from  last  year  have  not  been 
implemented and remain valid. In the coming year, Bosnia and Herzegovina should in particular:  

→  implement court rulings to end divided education; 

→  ensure full respect, protection and promotion of the freedom of assembly, association and expression, 

and refrain from further actions that adversely impact their exercise; 

→  harmonise and improve legislation against domestic and gender-based violence to meet international 
standards and align laws across the country with the Gender Equality Law to increase the public and 
political participation of women.  

Freedom of expression  

There is  some level of preparation on freedom of expression. There was  no progress in guaranteeing 
6 

 
 
freedom  of  expression  and  of  the  media,  and  the  protection  of  journalists  (Opinion  key  priority  12). 
Political  pressure,  intimidation  and  harassment  towards  journalists  continued,  including  physical  and 
verbal  attacks,  with  no  appropriate  institutional  follow-up.  Political  influence  over  public  broadcasters 
persists,  and  their  financial  sustainability  is  ever  more  in  danger.  The  Law  on  the  public  broadcasting 
system  remains  unimplemented,  and  entity-level  legislation  is  still  not  harmonised  with  this  law.  The 
criminal penalties for defamation in the Republika Srpska entity continue to severely impact freedom of 
expression  and  of  the  media  and  to  have  a  chilling  effect.  Sarajevo  Canton’s  legislative  initiative  on 
sanctions for online ‘fake news’, if adopted, could be abused to restrict media freedom. Any such norms 
must fully respect freedom of expression standards.  

The  Commission’s  recommendations  from  last  year  were  not  implemented  and  remain  valid.  In  the 
coming year, Bosnia and Herzegovina should, in particular:  

→  ensure  the  protection  of  journalists  and  systematic  institutional  follow-up  of  threats  and  violence 

against them;  

→  ensure  the  financial  sustainability  and  political  independence  of  public  broadcasters  and  harmonise 

entity legislation with the state-level Law on the public broadcasting system;  

→  adopt legislation on media ownership transparency and criteria for public advertising; and ensure that 

defamation is decriminalised across the country.  

Chapter 24: Justice, freedom and security  

Bosnia  and  Herzegovina  has  some  level  of  preparation  in  this  area.  Some  progress  was  made  on 
Opinion  key  priorities  7  and  8,  notably  with  the  adoption  of  the  Law  on  anti-money  laundering  and 
combating  the  financing  of  terrorism.  Action  plans  for  countering  terrorism  and  preventing  and 
countering  violent  extremism  were  also  adopted  at  all  levels.  Migration  management  continued  to 
improve.  While  broadly  aligned  with  the  EU  acquis,  legislation  is  often  not  harmonised  across  the 
country, and institutional cooperation and coordination remain weak, leading to uneven implementation.  

The  Commission’s  recommendations  from  last  year  were  partially  implemented  and  therefore  remain 
valid. In the coming year, Bosnia and Herzegovina should in particular: 

→  take over responsibility for managing migration, including management of reception centres;  ensure 
effective  coordination  of  border  management  and  migration  management  capacity;  and  guarantee 
access to quality and effective asylum procedures; 

→  improve  civilian  oversight  mechanisms  over  all  police  forces;  consistently  appoint  police  directors 

based on merit;  

→  adopt the law  on  border control  and  the strategy  and  action  plan  on  integrated border  management 
2024-2029 in line with the EU/Schengen acquis; continue to align with EU visa policy, in particular 
with regard to third countries presenting irregular migration or security risks to the EU, and introduce 
security measures to better screen visa-free arrivals. 

Fight against organised crime 

Bosnia  and  Herzegovina  is  between  an  early  stage  of  preparation  and  having  some  level  of 
preparation in the fight against organised crime. Some progress was made, notably with the adoption of 
legislation  on  anti-money  laundering,  enforcement  operations  supported  by  Europol,  and  improved 
coordination  capacity  in  the  Prosecutor’s  Office.  Systemic  shortcomings  remain  in  the  operational 
cooperation  and  capacity  of  law  enforcement  agencies  to  investigate  due  to  non-harmonised  criminal 
legislation,  weak  institutional  coordination  and  lack  of  resources.  Financial  investigations  and  asset 
seizures  and  confiscations  remain  insufficient.  A  proactive  approach  is  essential  to  stop  criminal 
infiltration in the political, legal and economic systems.  

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The Commission’s recommendations from last year were only partially implemented, and therefore 
remain broadly valid. In the coming year, Bosnia and Herzegovina should in particular:  

→  adopt  a  2024-2027  strategy  on  trafficking  in  human  beings  and  amend  legislation  on  migrant 

smuggling to better combat these two crimes; 

→  establish  specialised  multi-agency  investigation  teams  for  complex  cases;  setup  an  asset  recovery 
office; improve mutual access to databases and timely exchange of information; strengthen financial 
investigations;  

→  adopt  a  new  law  on  personal  data  protection,  as  a  precondition  for  an  agreement  on  operational 
cooperation  with  Eurojust,  and  sign  and  ratify  the latter;  establish  a  firearms  focal  point;  and  align 
legislations on the possession of weapons by civilians. 

The existence of a functioning market economy 

Bosnia  and  Herzegovina  is  at  an  early  stage  of  preparation  and  has  made  limited  progress  in 
establishing  a  functioning  market  economy.  Economic  growth  slowed  down  to  about  1.6%  in  2023, 
mainly reflecting a deteriorating international environment. The labour market remained resilient, but a 
significant outflow of workers is leading to labour shortages. The public sector continued to be inefficient 
and oversized. The business environment suffers from a fragmented internal market and a weak rule of 
law.  Political  stalemates,  a  lack  of cooperation  among  the  various  levels  of  government,  and resistance 
from entities and cantons continued to delay necessary structural reforms. 

As the implementation of last year’s Commission recommendations was limited, they remain valid. In the 
coming year, Bosnia and Herzegovina should in particular: 

→  improve the business environment by simplifying business registration and licencing procedures and 

by harmonising and mutually recognising licences and certificates between entities; 

→  strengthen  countrywide  regulatory  and  supervisory  institutions,  bolster  analytical  and  policy-
formulation  capacity  and  publish  complete  and  consistent  countrywide  data  in  a  timely  manner,  in 
particular on public finances; 

→  increase  the  transparency  and  efficiency  of  the  public  sector,  in  particular  by  establishing  a 
framework  for  better,  depoliticised  governance;  improve  tax  collection  by  ensuring  the  effective 
exchange  of  information  between  tax  authorities;  and  clarify  the  constitutional  competence  for 
establishing a registry of bank accounts of private individuals, in line with the EU acquis. 

The capacity to cope with competitive pressure and market forces within the Union 

Bosnia  and  Herzegovina  is  between  an  early  stage  of  preparation  and  having  some  level  of 
preparation and made limited progress concerning its capacity to cope with competitive pressure and 
market forces in the EU. The overall quality of education remains inadequate. The country continues to 
lag behind in the energy and digital transitions. However, some structural adjustment took place, with the 
focus  of  the  country’s  value  added  moving  towards  services  such  as  trade,  IT  and  tourism.  Economic 
integration with the EU remains high, but overall trade is below potential.  

Last  year’s  recommendations  have  been  partially  implemented,  and  therefore  remain  valid.  To  support 
long-term growth, Bosnia and Herzegovina should in particular: 

→  improve the quality of education and training, in particular accelerating the modernisation of curricula 

with a view to better alignment with labour market needs;  

→  increase the share of government capital spending in GDP, in particular by focusing on transport and 

energy infrastructure and on improving environmental standards;  

8 

 
 
→  improve management of public investment and accelerate implementation of investment projects that 

have undergone a clear positive cost-benefit assessment. 

Chapter 5: Public procurement 

Bosnia and Herzegovina has some level of preparation in public procurement. There was some progress 
in adopting the 2024-2028 public procurement strategy and in amending the Law on public procurement 
on  legal  protection.  Public  procurement  remains  prone  to  irregularities  and  vulnerable  to  corruption. 
Selective and non-transparent judicial follow-up in cases of corruption in public procurement is a cause of 
significant concern. 

The Commission’s recommendations from last year were partially implemented and remain valid. In the 
coming year, Bosnia and Herzegovina should in particular: 

→  further align the public procurement law with the EU public procurement acquis, including on public-

private partnerships and concessions; 

→  increase  staffing  levels  and  strengthen  capacity  in  the  Public  Procurement  Agency  and  the  Public 

Procurement Review Body; 

→  develop the e-procurement system and increase its use to ensure transparency. 

Chapter 18: Statistics 

Bosnia and Herzegovina is at an early stage of preparation on statistics. Limited progress was made in 
the  reporting  period,  mainly  on  environmental  statistics.  Bosnia  and  Herzegovina  should  improve 
cooperation, coordination, decision-making processes and the legal basis to develop the national statistical 
system and ensure progress in key areas. 

The Commission’s recommendations from last year were partly implemented and remain mostly valid. In 
the coming year, Bosnia and Herzegovina should in particular: 

→  conduct the agricultural census ;  
→  adopt a roadmap for preparing the next population and housing census; 
→  finalise the classification of regions equivalent to the NUTS classification (Nomenclature of territorial 

units for statistics). 

Chapter 32: Financial control 

Bosnia and Herzegovina has some level of preparation in this area. Some progress  was made on: (i) 
advancing  implementation  of  strategies  on  public  internal  financial  control  (PIFC)  at  state  and  entity 
level; (ii) producing consolidated reports while improving capacities for online reporting; and (iii) better 
training civil servants in charge of PIFC. External audit institutions at state level improved outreach on 
audit work and on  communication with civil society, and the Federation entity adopted a communication 
strategy  on  audit.  Implementation  of  recommendations  remains  low  at  between  30-50%,  and  the 
operational,  financial independence  of  Supreme  Audit  Institutions  needs to  be improved.  Parliamentary 
scrutiny of audit work remains ineffective. 

The Commission’s recommendations from last year were partially implemented and remain valid. In the 
coming year, Bosnia and Herzegovina should in particular: 

→  improve  managerial  accountability  by  amending  relevant  regulations  on  managerial  delegation  of 

tasks to include not only financial but also administrative responsibilities across public bodies; 

9 

 
 
→  establish  and  improve  the  oversight  function  of  the  fiscal  risk  of  public  companies,  particularly  at 
entity level, and ensure data collection on the public internal financial control of public companies at 
all levels of government via the relevant IT application; 

→  improve  the  implementation  of  state  audit  recommendations  via  stronger  coordination  among 

parliaments, audit authorities and governments at state and entity level. 

CLUSTER 2: INTERNAL MARKET 

Chapter 1: Free movement of goods 

Bosnia and Herzegovina is at an early stage of preparation on the free movement of goods. No progress 
was made in this area. 

The  Commission’s  recommendations  from  last  year  were  not  implemented  and  remain  valid.  In  the 
coming year, Bosnia and Herzegovina should in particular: 

→  draw up a list of technical regulations in force and start to repeal the legislation and standards across 

the country that conflict with EU legislation and European standards; 

→  adopt a countrywide strategy for quality infrastructure; 

→  examine all existing legislation and administrative practices in the non-harmonised area to assess if 
they comply with Articles 34-36 of the Treaty on the Functioning of the European Union and start to 
plan how to address all non-compliant elements. 

Chapter 2: Freedom of movements for workers 

Bosnia and Herzegovina has some level of preparation on the free movement of workers. No progress 
was  made  in  the  reporting  period  due  to  the  fragmentation  of  social  security  schemes,  limited 
administrative capacity and lack of cooperation among authorities. 

The  Commission’s  recommendations  from  last  year  were  not  implemented  and  remain  valid.  In  the 
coming year, Bosnia and Herzegovina should in particular: 

→  start developing a countrywide database on vacancies; 

→  continue negotiating and concluding new bilateral agreements on social security, particularly with EU 

Member States. 

Chapter 3: Right of establishment and freedom to provide services 

Bosnia  and  Herzegovina  is  at  an  early  stage  of  preparation  on  the  right  of  establishment  and  the 
freedom to provide services. No progress was made in this area. The legislation needs to be aligned with 
the EU Services Directive. There is no mutual recognition of qualifications for regulated professions. A 
regulatory framework and countrywide strategy to develop the postal services need to be adopted, in line 
with the EU acquis. 

The  Commission’s  recommendations  from  last  year  were  not  implemented  and  remain  valid.  In  the 
coming year, Bosnia and Herzegovina should in particular: 

→  develop and adopt a countrywide law on services that is fully aligned with the EU Services Directive, 
including  a  point  of  single  contact,  and  remove  the  remaining  barriers  to  establishing  a  single 
economic space; 

10 

 
 
→  develop and adopt a countrywide strategy and a countrywide law on postal services aligned with the 
EU  acquis  to gradually  open  the  postal  services  market to  competition,  and  strengthen  institutional 
capacity to ensure compliance with new postal market rules; 

→  align legislation  with  the EU  acquis  on  mutual recognition  of  professional  qualifications,  including 
with  the  Directive  on  recognition  of  professional  qualifications  and  with  the  Directive  on  a 
proportionality test, before regulating any new profession. 

Chapter 4: Free movement of capital 

Bosnia  and  Herzegovina  is  moderately  prepared  on  the  free  movement  of  capital.  There  was  limited 
progress  in  aligning  with the  EU  acquis,  with  the  adoption  of  a  new  law  and risk assessment  on  anti-
money laundering and countering terrorism financing. 

The Commission’s recommendations from last year were partially implemented and remain valid. In the 
coming year, Bosnia and Herzegovina should in particular: 

→  reduce the requirements for short-term capital transactions and amend the legislation to comply with 

SAA commitments on the acquisition of real estate by EU citizens; 

→  establish  a  countrywide  central  register  of  beneficial  ownership  information  for  legal  persons  and 
private individuals, and a register of beneficial ownership information for legal arrangements, in line 
with the EU acquis; 

→  adopt  legislation  to  align with the Payment  Services  Directive 2,  the  Electronic  Money  Directive  2 

and the Regulation on single euro area payments (SEPA). 

Chapter 6: Company law 

Bosnia  and  Herzegovina  has  some  level  of  preparation  on  company  law,  corporate  accounting  and 
auditing. No progress was made in this area. Further efforts are needed to align with the EU  acquis on 
company  law,  in  particular  on  accounting  and  corporate  sustainability  reporting  and  to  harmonise  its 
requirements across the country. Different regional business registers operate independently and without 
coordination. There is still no single countrywide supervisory body to oversee statutory auditors. 

The  Commission’s  recommendations  from  last  year  were  not  implemented  and  remain  valid.  In  the 
coming year, Bosnia and Herzegovina should in particular: 

→  finalise  the  review  of  the  existing  legislation  on  company  law  to  identify  amendments  needed  to 

further align with the EU acquis; 

→  improve the connection and coordination of business registers among entities and the Brčko District; 

→  review  the  existing  legislation  on  financial  and  corporate  sustainability  reporting,  transparency  and 

statutory audit to identify the legislative amendments necessary to align with the EU acquis. 

Chapter 7: Intellectual property law 

Bosnia and Herzegovina is moderately prepared on intellectual property law. No  progress was made in 
this area. Although some preparations started, more efforts are required to align legislation with the EU 
acquis and improve enforcement and coordination. A new intellectual property strategy has not yet been 
adopted. 

The Commission’s recommendations from last year were not met and remain valid. In the coming year, 
Bosnia and Herzegovina should in particular: 

→  adopt  and  implement  a  new  strategy  on  intellectual  property  and  implement  the  strategy  on  the 
11 

 
 
enforcement of intellectual property rights; 

→  further align the legal framework on copyright and related rights with the EU acquis and amend the 

Law on patents, trademarks and trade secrets; 

→  continue  taking  steps  to  increase  coordination  and  capacity  to  enforce  intellectual,  industrial  and 
commercial  property  rights  and  to  strengthen  collaboration  with  the  European  Union  Intellectual 
Property Office. 

Chapter 8: Competition policy 

Bosnia and Herzegovina has some level of preparation on competition policy. There was no progress in 
this area. The country has not yet removed ethnic-based decision-making procedures and vetoes from the 
Competition Council and State Aid Council. 

The  Commission’s  recommendations  from  last  year  were  not  implemented  and  remain  valid.  In  the 
coming year, Bosnia and Herzegovina should in particular: 

→  amend the Law on competition and the Law on State aid to revise the voting procedures in line with 

the EU acquis (Opinion key priority 4.g); 

→  improve  the  enforcement  record  of  the  State  Aid  Council  by  ensuring  that  State  aid  measures  are 

notified by granting authorities before they are approved; 

→  in line with the Stabilisation and Association Agreement, ensure that the State Aid Council operates 

independently and align the existing aid schemes with the EU acquis. 

Chapter 9: Financial services 

Bosnia  and  Herzegovina  is  between  having  some  level  of  preparation  and  a  moderate  level  of 
preparation on financial services. There was no progress in this area. Coordination in supervision and 
enforcement  needs  to  significantly  improve.  The  overall  level  of  preparedness  in  the  securities  market 
remains low. 

The  Commission’s  recommendations  from  last  year  were  not  implemented  and  remain  valid.  In  the 
coming year, Bosnia and Herzegovina should in particular: 

→  continue the work towards full alignment of the banking regulation with the amended versions of the 
Capital  Requirements  Directive  and  Regulation  and  with  the  Bank  Resolution  and  Recovery 
Directive; 

→  Continue efforts in aligning regulation of non-banking sectors, including the regulation on investment 

funds and on the financial market infrastructures; 

→  introduce consolidated supervision of banking groups and overall financial holdings, including across 

entities and in the Brčko District. 

Chapter 28: Consumer and health protection 

Bosnia and Herzegovina is at an early stage of preparation on consumer protection and public health. 
No progress was made in this area. 

The  Commission’s  recommendations  from  last  year  were  not  implemented  and  remain  valid.  In  the 
coming year, Bosnia and Herzegovina should in particular: 

→  align tobacco control legislation with the EU acquis at all levels and start enforcing it, and urgently 

ratify the protocol to eliminate illicit trade in tobacco products; 

12 

 
 
→  further  align  state-level  legislation  with  the  acquis  on  all  health-related  issues,  most  urgently  on 
substances  of  human  origin  and  on  medicines  for  human  use,  and  establish  an  oversight  system  to 
ensure efficient coordination across the whole country; 

→  further align the state-level Law on consumer protection and product safety with the EU acquis. 

CLUSTER 3: COMPETITIVENESS AND INCLUSIVE GROWTH 

Chapter 10: Digital transformation and media 

Bosnia and Herzegovina is at an early stage of preparation on digital transformation and the media. No 
progress was achieved. The legislation and strategic framework are not in place and are not aligned with 
the EU acquis. In June 2024, Bosnia and Herzegovina joined the Digital Europe Programme; the related 
agreement is yet to be ratified by Parliament.  

The  Commission’s  recommendations  from  last  year  were  not  implemented  and  remain  valid.  In  the 
coming year, Bosnia and Herzegovina should in particular: 

→  complete  phase  two  of  the  digital  switchover  and  adopt  a  framework  strategy  for  access  to  the 

broadband network; 

→  develop  and adopt  a law  on  electronic  identity  and trust  services  for  electronic transactions,  with a 
single  supervisory  body  for  the  whole  country,  in  line  with  the  EU  Digital  Identity  Framework 
Regulation; develop a legislative framework on cybersecurity in line with the EU acquis; 

→  develop  and  adopt  a  law  on  electronic  communications  and  electronic  media  in  line  with  the  EU 
acquis, in particular aligning legislations with the European Electronic Communications Code and the 
Audio-visual and Media Services Directive. 

Chapter 16: Taxation 

Bosnia  and  Herzegovina has  some  level  of  preparation  on taxation.  No  progress  was  achieved in the 
reporting  period.  Countrywide  harmonisation  remains  insufficient,  hindering  progress  towards  a  single 
economic space. 

The  Commission’s  recommendations  from  last  year  were  not  implemented  and  remain  valid.  In  the 
coming year, Bosnia and Herzegovina should in particular: 

→  bring the legislation on the value added tax (VAT) and on excise duties in line with the EU acquis, 

particularly on excise duties on beer; 

→  make  progress  on  putting  in  place  the  electronic  signature  (e-signature)  in  order  to  ensure 

interoperability of taxation services countrywide; 

→  start  preparations  for  interconnection  and  interoperability  with  the  related  common  EU  taxation  IT 

systems. 

Chapter 17: Economic and monetary policy 

Bosnia  and  Herzegovina  is  at  an  early  stage  of  preparation;  limited  progress  was  made  under  this 
chapter. A new governing board of the Central Bank was appointed in December 2023. Cooperation and 
coordination of macroeconomic and fiscal policies remain a challenge, as evidenced by the difficulties in 
preparing  and  carrying  out  the  Economic  Reform  Programme  (ERP).  Monetary  policy  underpins 
economic stability, but the full independence of the Central Bank has yet to be ensured. 

13 

 
 
 
The  Commission’s  recommendations  from  last  year  were  only  partially  implemented  and  therefore 
remain largely valid. In the coming year, Bosnia and Herzegovina should in particular: 

→  maintain  the  integrity  of  the  currency  board  arrangement  and  ensure  the  central  bank’s  full 

independence; 

→  strengthen the analytical capacities of all institutions responsible for fiscal accounting and planning, 
and improve procedures for preparing the ERP in order to ensure timely submission and compliance 
with the requirements; 

→  adopt the global fiscal framework and the budgets of all levels of government in a timely manner. 

Chapter 19: Social policy and employment 

Bosnia  and  Herzegovina  has  some  level  of  preparation  in  the  area  of  social  policy  and  employment. 
There  was  limited  progress  in  this  area.  Serious  challenges  remain  to  be  addressed  as  regards 
employment, social dialogue, social inclusion and protection, and on reducing poverty. Steps were taken 
by adopting a roadmap for  the de-institutionalisation of children and establishing a Council for persons 
with disabilities. 

The  Commission’s  recommendations  from  last  year  were  only  partially  implemented  and  therefore 
remain valid. In the coming year, Bosnia and Herzegovina should in particular: 

→  develop and adopt a countrywide employment strategy as a policy framework, while putting in place 

additional capacity for implementation and monitoring; 

→  finalise and adopt the Youth Guarantee implementation plan in line with the EU model and guidance, 

and prepare for the piloting to start in 2026; 

→  introduce a uniform minimum level of maternity leave benefits and protection throughout the country, 

starting by harmonising the definitions of maternity, paternity and parental leave. 

Chapter 20: Enterprise and industrial policy 

Bosnia and Herzegovina remains at an early stage of preparation in the area of enterprise and industrial 
policy.  Limited  progress  was  made  with  the  adoption  of  entrepreneurial  legislation  in  the  entities  and 
Brčko District. The investment environment remains unsatisfactory in spite of limited progress. 

The Commission’s recommendations from last year were not implemented and therefore remain valid. In 
the coming year, Bosnia and Herzegovina should in particular: 

→  adopt  regulation  allowing  mutual  recognition  of  licences  and  certificates  between  the  entities  and 
ensure that e-registration of companies and business registries across the country are interconnected 
and fully operational, including e-signature/e-stamps; 

→  adopt countrywide guidelines to harmonise SME support, aligned with the Small Business Act paying 
particular attention to implementing financial support to start-ups and micro, small and medium-sized 
enterprises in the innovation and digital sector; 

→  accelerate  improvements  to  the  investment  environment  to  attract  sustainable  investments  that 

integrate with the domestic industrial tissue. 

Chapter 25: Science and research 

Bosnia and Herzegovina has some level of preparation on science and research. No progress was made. 
Research capacities remain very limited. 

14 

 
 
The Commission’s recommendations from last year were not implemented and therefore remain valid. In 
the coming year, Bosnia and Herzegovina should in particular: 

→  develop a new strategy and action plan for scientific development; 

→  develop and adopt a smart specialisation strategy; 

→  improve  reporting  on  research  and  innovation  statistics  by  reporting  on  at  least  24  European 

Innovation Scoreboard indicators. 

Chapter 26: Education and culture 

Bosnia  and  Herzegovina  is  at  an  early  stage  of  preparation  on  education  and  culture.  There  was  no 
progress in this area. 

The Commission’s recommendations from last year were not implemented and therefore remain valid. In 
the coming year, Bosnia and Herzegovina should in particular: 

→  extend and update the action plan for the national qualifications framework (NQF); 

→  ensure  a  fully  functional  system  of  (re-)accreditation  of  higher  education  institutions  and  study 

programmes across the country; 

→  ensure  continued  participation  in  international  assessment  studies11  and  implement  findings  to 

improve PISA results. 

Chapter 29: Customs union 

Bosnia  and  Herzegovina  has  some  level  of  preparation  on  customs  union.  Customs  legislation  is  not 
fully aligned with the EU acquis. There was no progress in this area. 

The Commission’s recommendations from last year were not implemented and therefore remain valid. In 
the coming year, Bosnia and Herzegovina should in particular: 

→   continue  preparations  to  apply  the  common  transit  procedure  and  connect  its  transit  system  to  the 
common  IT  infrastructure  of  the  new  computerised  transit  system  (NCTS),  and  start  preparations 
towards  achieving  interconnection  and  interoperability  of  its  customs  IT  systems  with  the  EU 
electronic customs environment;  

→  strengthen the administrative and operational capacity of the Indirect Taxation Authority; 
→  increase  post-clearance  checks  based  on  risk  analysis,  expand  use  of  simplified  procedures  for 
reliable  economic  operators  and  upgrade  interconnectivity  and  interoperability  with  the  EU’s  IT 
systems and requirements. 

CLUSTER 4: THE GREEN AGENDA AND SUSTAINABLE CONNECTIVITY 

Chapter 14: Transport policy 

Bosnia and Herzegovina has  some level of preparation in this area, with  no progress  achieved in the 
reporting period. 

11 Programme for International Student Assessment – PISA, Trends in International Mathematics and Science Study 
–  TIMSS,  Progress  in  International  Reading  Literacy  Study  –  PIRLS,  International  Computer  and  Information 
Literacy Study – ICILS, Teaching and Learning International Survey – TALIS. 

15 

 
 
 
 
The Commission’s recommendations from last year were not implemented and therefore remain valid. In 
the coming year, Bosnia and Herzegovina should in particular: 

→  establish a lead agency for road safety and a countrywide system to collect data on road crashes; 

→  bolster the independence, strengthen the capacity and ensure sufficient funding of all bodies at state 

and entity level in the area of transport; 

→  adopt  a strategic  framework  and legislation  to  implement  intelligent  transport  systems  (ITS)  on  the 

core networks. 

Chapter 15: Energy 

The country remains at an early stage of preparation on energy. No progress was made. 

The Commission’s recommendations from last year were not implemented and therefore remain valid. In 
the coming year, Bosnia and Herzegovina should in particular: 

→  adopt  gas  and  electricity  laws  and  bylaws  at  state  and  entity  levels  in  compliance  with  the  third 
energy  package  and  adopt  and  implement  the  electricity  integration  package,  and  ensure  the  full 
alignment  of  entity-level  laws  on  electricity  and  gas  to  ensure  coupling  with  the  EU  electricity 
market; 

→  adopt  state-level  legislation  and  improve  entity-level  legislation  on  renewable  energy  and  energy 

efficiency in line with the Energy Community Treaty requirements; 

→  finalise and adopt the national energy and climate plan (NECP) 2021-2030, in line with the Energy 

Community 2030 energy and climate targets. 

Chapter 21: Trans-European Networks 

Bosnia and Herzegovina has some level of preparation on trans-European networks. There was limited 
progress in this area, with the continuation of the Corridor Vc motorway development.  

The  Commission’s  recommendations  from  last  year  were  only  partially  implemented  and  therefore 
remain valid. In the coming year, Bosnia and Herzegovina should in particular: 

→  continue developing the planned extension of the TEN-T and TEN-E core networks in line with the 

identified priorities; 

→  accelerate  the  implementation  of  connectivity  reform  measures  and  continue  to  regularly  adopt 

amended multiannual maintenance plans for the road and rail core networks; 

→  align the legislation with the EU acquis on guidelines for trans-European energy infrastructure. 

Chapter 27: Environment and climate change 

Bosnia and Herzegovina is between an early stage and some level of preparation on the environment 
and  climate  change  and  made  limited  progress.  On  environment,  the  Council  of  Ministers  adopted  a 
decision on the quality of liquid petroleum fuels, while on climate change Bosnia and Herzegovina still 
needs  to  adopt  a  state-level  climate  law  and  a  countrywide  climate  strategy  along  with  a  2050  climate 
neutrality target to align with the EU climate acquis. 

The  Commission’s  recommendations  from  last  year  were  only  partially  implemented  and  therefore 
remain valid. In the coming year, Bosnia and Herzegovina should in particular: 

→  put  in  place  an  integrated  action  plan  to  ensure  coordinated  implementation  of  the  countrywide 

16 

 
 
environmental  approximation  strategy  and  its  monitoring,  adopt  a  country-level  climate  law,  and 
adopt countrywide environmental protection and climate strategies in line with the EU acquis; 

→  formalise  a  procedure  for  the  merit-based,  transparent  appointment  of  a  focal  point  for  Bosnia  and 
Herzegovina to ensure the country’s undisputed representation in environmental conventions to which 
Bosnia and Herzegovina is a signatory; 

→  update  the  nationally  determined  contribution  (NDC)  and  urgently  implement  the  monitoring, 
reporting, verification and accreditation (MRVA) package, with a view to introducing carbon pricing 
and aligning with the EU emissions trading system (ETS). 

CLUSTER 5: RESOURCES, AGRICULTURE AND COHESION 

Chapter 11: Agriculture and rural development 

Bosnia  and  Herzegovina  is  at  an  early  stage  of  preparation  on  agriculture  and  rural  development;  it 
made  limited  progress  in  this  area.  Bosnia  and  Herzegovina  endorsed  the  ‘Strategic  plan  for  rural 
development of Bosnia and Herzegovina 2023-2027 – framework document’ in October 2024. 

The Commission’s recommendations from last year were not implemented and therefore remain valid. In 
the coming year, Bosnia and Herzegovina should in particular: 

→  adopt  a  multi-annual,  country-wide  strategy  for  agriculture  and  rural  development,  and  harmonise 

support measures across the country in line with the EU acquis; 

→  adopt  a  state-level  law  on  organic  production,  a  state-level  law  on  quality  policy,  as  well  as  the 

implementing legislation on wine, in line with the EU acquis; 

→  set up the administrative structures required for the common agricultural policy. 

Chapter 12: Food safety, veterinary and phytosanitary policy 

Bosnia  and  Herzegovina  has  some  level  of  preparation  in  this  area.  No  progress  was  made  over  the 
reporting period. 

The Commission’s recommendations from last year were not implemented and therefore remain valid. In 
the coming year, Bosnia and Herzegovina should in particular: 

→  introduce  an  inter-laboratory  comparative  test  system  as  regular  practice,  particularly  for  notifiable 
diseases; increase the administrative capacity of inspection services and laboratories; and increase the 
number of checks; 

→  speed  up  preparation  for  national  reference  laboratories  in  hygiene,  veterinary  and  phytosanitary 

inspections, and food and foodstuff analysis, in line with the EU acquis; 

→  adopt state-level laws on food, on animal health, on animal welfare and on plant health, in line with 

the EU acquis; adopt the OECD seed schemes, particularly for agricultural seeds and forestry. 

Chapter 13: Fisheries and aquaculture 

Bosnia  and  Herzegovina  is  at  an  early  stage  of  preparation  in  this  area;  no  progress  was  made.  The 
country still needs to prepare, adopt and implement a countrywide fisheries and aquaculture strategy in 
line with the EU acquis. 

17 

 
 
 
The Commission’s recommendations from last year were not implemented and therefore remain valid. In 
the coming year, Bosnia and Herzegovina should in particular: 

→  prepare  and  adopt  a  countrywide  strategy  on  fisheries  and  aquaculture  with  a  view  to  aligning  the 

legislation with the EU acquis; 

→  harmonise the methodology for data collection for fish and fishery and aquaculture products across 

the country and establish the relevant statistics system. 

Chapter 22: Regional policy and coordination of structural instruments 

Bosnia  and  Herzegovina  remains  at  an  early  stage  of  preparation  on  regional  policy  and  the 
coordination of structural instruments. No progress was made during the reporting period. Therefore, last 
year’s recommendations remain valid. 

In the coming year, Bosnia and Herzegovina should: 

→  develop  and  adopt  a  countrywide  strategic  framework  guiding  preparations  for  structural  and 

cohesion funds and regional development; 

→  urgently appoint a national IPA coordinator (NIPAC) for the Instrument for Pre-accession Assistance 
(IPA) III with the authority and mandate to effectively coordinate the use of EU funds, and strengthen 
institutional and administrative capacity to manage EU funds; 

→  improve  public  investment  management  and  adopt  an  updated  single  country  project  pipeline 

covering priority sectors, based on a sound, transparent and inclusive methodology. 

Chapter 33: Financial and budgetary provisions 

Bosnia  and  Herzegovina  is  at  an  early  stage  of  preparation  on  financial  and  budgetary  provisions.  No 
progress was made. 

The Commission’s recommendations from last year were not implemented and therefore remain valid. In 
the coming year, Bosnia and Herzegovina should in particular: 

→  strengthen capacity and inter-agency cooperation to combat tax and customs fraud; 

→  bolster the capacity of the Indirect Tax Authority to effectively implement customs legislation; 

→  adopt a master plan for the production of national accounts for Bosnia and Herzegovina. 

CLUSTER 6: EXTERNAL RELATIONS 

Chapter 30: External relations 

Bosnia  and  Herzegovina  has  reached  some  level  of  preparation  on  external  relations.  There  was  no 
progress  in  the  last  year  and  the  capacity  to  tackle  key  challenges  in  trade  policy  has  yet  to  be 
strengthened. 

The Commission’s recommendations from last year were not implemented and therefore remain valid. In 
the coming year, Bosnia and Herzegovina should in particular: 

→  finalise its accession to the World Trade Organization (WTO); 

→  implement  the  2021-2024  Common  Regional  Market  action  plan,  in  particular  by  urgently 
implementing the  Central European Free Trade Agreement (CEFTA) additional protocol 5 on trade 

18 

 
 
 
facilitation and the additional protocol 6 on trade in services,  take the necessary steps to implement 
additional  protocol  7  on  dispute  settlement  and  implement  actions  under  the  new  action  plan  for 
2025-2028; 

→  start the process of establishing a development and humanitarian aid policy. 

Chapter 31: Foreign, security and defence policy 

Bosnia  and  Herzegovina  has  some  level  of  preparation  in  the  area  of  common  foreign,  security  and 
defence  policy.  There  was  good  progress,  as  Bosnia  and  Herzegovina  reached  and  maintained  full 
alignment with EU common foreign and security policy, notably on statements and restrictive measures 
following Russia’s war of aggression against Ukraine. Implementation of restrictive measures remains a 
challenge  due  to  political  obstructions.  Bosnia  and  Herzegovina  continued  to  participate  in  EU  crisis 
management missions and operations under the common security and defence policy. 

The recommendations from last year remain  largely valid. In the coming year, Bosnia and Herzegovina 
should in particular: 

→  maintain  full  alignment  with  EU  common  foreign  and  security  policy,  ensure 

thorough 
implementation  of  restrictive  measures  stemming  from  EU  alignment,  and  make  further  efforts  to 
close space for foreign interference and information manipulation; 

→  align legislation  and  procedures  with  EU  standards  on  marking  and  deactivation  of  small arms  and 

light weapons, including for seized and confiscated weapons; 

→  appoint a political director and European correspondent in the Ministry for Foreign Affairs. 

1.3  ASSESSMENT  OF  THE  IMPLEMENTATION  OF  THE  STEPS  SPECIFIED  IN  THE  COMMISSION’S 
RECOMMENDATION FOR CANDIDATE STATUS   

Step  1:  ensure  a  track  record  in  the  functioning  at  all  levels  of  the  coordination  mechanism  on  EU 
matters, including by developing and adopting a national programme for the adoption of the EU acquis. 

The Directorate for European Integration finalised the programme for EU integration, and submitted it to 
the  European  Commission  in  March  2024.  This  programme  for  EU  integration  is  a  key  step  towards 
putting in place the national programme for the adoption of the EU acquis (NPAA); it should be revised 
in  line  with  the  Commission  comments  provided,  in  view  of  agreement  with  the  Commission  on  the 
NPAA. The Council of Ministers should urgently appoint the national IPA coordinator (NIPAC) for IPA 
III. 

Step 2: adopt, as a matter of priority, integrity amendments in the existing Law on the High Judicial and 
Prosecutorial Council. 

The  Parliament  adopted  the  integrity  amendments  to  the  HJPC  Law  in  September  2023.  Certain 
provisions  that  hampered  the  right  of  international  experts  to  access  personal  data  were  corrected  in 
January  2024.  Judicial  institutions  are  now  setting  up  the  structures  to  conduct  the  integrity  checks  on 
judicial office holders and HJPC members, establishing a robust system of asset declaration verification 
with close external monitoring. 

Step 3: adopt a new law on the High Judicial and Prosecutorial Council and adopt the law on the Courts 
of Bosnia and Herzegovina 

The  draft  new  Law  on  the  HJPC  should  be  brought  in  line  with  the  June  2024  interim  opinion  of  the 
Venice  Commission.  Bosnia  and  Herzegovina  should  submit  the  revised  draft  for  a  follow-up  opinion, 

19 

 
 
 
and fully align the draft law with its recommendations before adoption by Parliament. The new law on the 
HJPC should also ensure the right of the HJPC to access all information necessary to perform integrity 
checks.   

The Ministry of Justice is finalising the  draft Law on the Courts of Bosnia and Herzegovina,  on which 
political  agreement is still pending.  Bosnia  and  Herzegovina  should  submit the draft law to the  Venice 
Commission for a follow-up opinion, prior to adoption by Parliament. 

Step 4: adopt the law on prevention of conflict of interest.  

The new law on the prevention of conflict of interest was adopted by Parliament in March 2024. The law 
aims to improve the level of compliance with European standards at state level and  is a substantial step 
forward,  although  it  is  not  yet  fully  in  line  with  European  standards.  It  should  now  be  effectively 
implemented. 

Step 5: take decisive steps to strengthen the prevention and fight against corruption and organised crime. 

A  law  on  anti-money  laundering  and  countering  terrorism  financing  (AML/CFT)  was  adopted  by 
Parliament  in  February  2024.  It  improves  provisions  on  risk  assessment  and  provides  for  a  permanent 
coordinating body of all authorities in charge of preparing it, in line with the EU acquis. 

A  risk  assessment  for  the  AML/CFT  on  virtual  assets  accompanied  with  an  action  plan  for  2024-2027 
was adopted by the Council of Ministers in February 2024. 

Bosnia and Herzegovina authorities have finalised the draft new law on personal data protection, which is 
a  precondition  for  the  entry  into  force  of  the  Eurojust  cooperation  agreement.  The  Ministry  of  Civil 
Affairs is expected to submit the draft law to the Council of Ministers for adoption, prior to submission 
for parliamentary procedure.  

A  strategy  and  action  plan  on  public  procurement  2024-2028  has  been  adopted  by  the  Council  of 
Ministers in March 2024 with the main purpose of drafting a new public procurement law. 

Bosnia  and  Herzegovina  should  strengthen  cooperation  among  law  enforcement  agencies,  and  adopt  a 
strategic approach towards fighting serious and organised crime. 

In January 2024 the Court of Bosnia and Herzegovina confirmed on appeal the sentence in the Novalić et 
al.  case  related  to  public  procurement  fraud,  including  against  the  then-acting  Prime  Minister  of  the 
Federation entity. This is a first final court ruling on high level corruption. 

Step 6: decisively advance work to ensure effective coordination, at all levels, of border management and 
migration management capacity, as well as ensuring the functioning of the asylum system. 

Migration  management  continues  to  improve,  although  it  still  requires  substantial  improvements.  The 
Council  of  Ministers  adopted  a  migration  strategy  and  action  plan.  The  Parliament  adopted  a  Law  on 
in  August  2023.  Reception  capacities  are  sufficient.  Readmission  agreements  and 
foreigners 
implementing protocols are implemented overall satisfactorily. Bosnia and Herzegovina needs to assign 
an appropriate budget for migration management, continue efforts for the return of irregular migrants to 
their countries of origin and take further steps to ensure a functioning asylum system.  Obstacles persist to 
ensuring quality and effective access to asylum procedures.  

In  December  2023  the  Council  of  Ministers  adopted  the  negotiating  mandate  on  the  Frontex  status 
agreement. The Presidency endorsed it in February 2024. Negotiations started in May and an agreement 
in principle was reached on the text in September 2024. 

In  January  2024  Bosnia  and  Herzegovina  further  aligned  with  the  EU  visa  policy  by  removing  Oman 
from its list of visa-free countries. 

20 

 
 
The  authorities  of  Bosnia  and  Herzegovina  finalised  the  draft  new  law  on  border  control,  aimed  at 
improving compliance with European standards. The Ministry of Security is expected to submit it to the 
Council of Ministers for adoption.  

A new draft strategy and action plan 2024-2029 on integrated border management, aimed at aligning with 
the EU acquis, are ready for adoption by the Council of Ministers.  

Step  7:  ensure  prohibition  of  torture,  notably  by  establishing  a  national  preventive  mechanism  against 
torture and ill-treatment. 

In October 2019 the Constitutional Court repealed the reference to death penalty in the Constitution of the 
Republika  Srpska  entity.  In  August  2023  the  Parliament  amended  the  Law  on  the  human  rights 
Ombudsman  to  designate  it  as  national  preventive  mechanism  against  torture  and  ill-treatment  –  an 
international obligation of the country.  

Step 8: guarantee freedom of expression and of the media and the  protection of journalists, notably by 
ensuring the appropriate judicial follow-up to cases of threats and violence against journalists and media 
workers. 

All prosecutors’ offices and law enforcement agencies have appointed contact points for journalists, to be 
publicised on the platform safejournalists.net.  

As a first step to urgently address the financial situation of the state-level public broadcaster, in February 
2024  the  Council  of  Ministers  granted  it  funds  from  the  revenues  of  the  Communication  Regulatory 
Agency. A working group is being established to draft a new law on the public broadcasting system.  

   

21 

 
 
 
 
2. 

CLUSTER 1: THE FUNDAMENTALS OF THE ACCESSION PROCESS  

2.1. 

FUNCTIONING OF DEMOCRATIC INSTITUTIONS AND PUBLIC ADMINISTRATION REFORM   

2.1.1.   Democracy  

The  functioning  of  democratic  institutions  is  undermined  by  persistent  discriminatory  elements  in  the 
constitutional  structure  and  by  the  persistent  breaching  of  the  legal  and  constitutional  order  by  the 
Republika Srpska entity. The entity continues not to implement the decisions of the Constitutional Court, 
calling into question the authority and integrity of the Court.  

Bosnia and Herzegovina needs to bring its constitutional framework in line with European standards and 
ensure the functionality of its institutions to be able to take on EU obligations. While a decentralised state 
structure is compatible with EU membership, Bosnia and Herzegovina will need to reform its institutions 
to be able to effectively participate in EU decision-making and to fully implement and enforce the acquis.  

Elections  

Local elections took place on 6 October 2024 based on the state-level election law, as amended yet again 
by  decision  of  the  High  Representative  in  March  to  introduce  integrity  measures.  According  to  the 
preliminary  findings  of  the  OSCE/ODIHR  election  observation mission,  the  elections  were  competitive 
and  efficiently  managed,  though  with  insufficient  efforts  to  generate  public  engagement,  and  in  an 
environment lacking social and political cohesion.  

In April 2024, the Republika Srpska entity adopted a separate election law, aiming to take over a range of 
competences from the state-level Central Election Commission. The Constitutional Court suspended it in 
July, upon entry into force, and repealed it in September. Its eventual application would undermine the 
constitutional  order  of  Bosnia  and  Herzegovina  and  the  functionality  of  its  institutions,  and  challenge 
legal certainty in view of future elections. 

In  April  2024,  the  Republika 
Srpska entity also adopted a law 
on  referenda,  which  envisages 
the  Central 
bypassing 
Election 
and 
establishing  a  separate  voters’ 
registry.  This  law  is  also  under 
the 
the 
Constitutional Court. 

of 
Commission 

scrutiny 

of 

Parliament  is  yet  to  address 
OSCE/ODIHR  and  GRECO 
recommendations 
improve 
the  integrity  of  the  electoral 
process and increase public trust 
in  it,  including  on  the  transparency  of  political  party  financing  and  the  registration  of  political  parties 
across  the  country.  Parliament  needs  to  urgently  adopt  constitutional  and  electoral  reforms  to  ensure 
equality and non-discrimination of all citizens.  

to 

The  judicial  prosecution  of  reported  cases  of  electoral  fraud  has  been  weak.  The  Central  Election 
Commission  (CEC)  needs  to  strengthen  its  audit  capacity  to  monitor  compliance  on  political  party 
financing. Political parties should respect its independence and refrain from threatening to dismiss CEC 
members.  

Political parties lack democratic internal policies and structures. There are no women among the leaders 
of parliamentary parties, and few in other leadership positions.  

22 

 
 
Legislation across the country should be aligned with the gender equality law, to increase women’s public 
and political participation. 

Parliament  

The Parliamentary Assembly of Bosnia and Herzegovina adopted 14 laws in 2023 (of which 4 in urgent 
procedure),  and  8  in  the  first  8  months  of  2024  (of  which  7  in  urgent  procedure),  compared  with  7  in 
2022. The Parliament adopted the 2024 budget only in July. Entity assemblies made considerable use of 
urgent  legislative  procedures.  Parliamentary  oversight  of  the  executive  is  very  weak,  and  there  is  no 
parliamentary  monitoring  of  compliance  with  the  recommendations  of  independent  institutions. 
Parliamentary oversight of the executive remains weak also in entities and cantons. 

The Federation entity assembly appointed a state-level constitutional judge in May 2024. The Republika 
Srpska entity assembly should also swiftly appoint the vacant judges to the Constitutional Court of Bosnia 
and  Herzegovina  to  ensure  its  full  composition  and  unhindered  functioning.  The  Law  on  immunity 
adopted  in  April  2024  in  the  Republika  Srpska  entity  curtails  the  judicial  accountability  of  political 
representatives, while its retroactive application challenges legal certainty and adversely affects the rule 
of law. 

EU integration  

The policy dialogue with the EU continued within the seventh cycle of sectoral subcommittees under the 
Stabilisation and Association Agreement (SAA). The Stabilisation and Association Committee was held 
in  September  2024,  although  the  subcommittee  on  trade,  industry,  customs  and  taxation  was  cancelled 
since  Bosnia  and  Herzegovina  could  not  submit  a  discussion  paper.  The  Council  of  Ministers  should 
urgently  take  measures  to  facilitate  policy  dialogue  within  the  SAA  bodies,  including  by  simplifying 
procedures, empowering its Directorate for European Integration (DEI) to submit preparatory documents 
to  the  Commission  without  unnecessary  and  lengthy  political  adoption,  and  appointing  permanent 
delegates  to  sectoral  subcommittees.  No  action  has  yet  been  taken  on  the  recommendations  the 
Commission  addressed  to  the  Council  of  Ministers  in  May  2022.  The  Stabilisation  and  Association 
Parliamentary Committee (SAPC) held sessions in October 2023 and in March 2024. 

Coordination on EU matters requires effective use of the legislation and political commitment, including 
to  develop  countrywide  sector  strategies  and  ensure  harmonised  alignment  with  the  EU  acquis.  The 
Council of Ministers needs to improve the functioning of the coordination mechanism. The Directorate 
for European Integration should step up their role in assessing countrywide alignment with the EU acquis, 
in view of EU accession negotiations.  

As an outstanding obligation under the SAA, Bosnia and Herzegovina needs to develop and agree with 
the Commission a national plan for the adoption of the acquis (NPAA) that reflects the role that all levels 
of  government  play in  aligning  with  and  enforcing  the  EU  acquis.  The  programme  for  EU  integration, 
prepared by the Directorate for European Integration and submitted to the Commission in March 2024, is 
a key step towards putting in place the national plan for the adoption of the  acquis. The programme for 
EU  integration  should  be  revised  in  line  with  the  comments  provided,  in  view  of  agreement  with  the 
Commission  on  the  NPAA.  The  Council  of  Ministers  should  urgently  appoint  the  national  IPA 
coordinator (NIPAC) for IPA III. 

Preparations have continued in view of accession negotiations. The Commission held a first introductory 
meeting in April 2024 in Brussels to explain the screening process, which is the first stage of accession 
negotiations.  Bosnia  and  Herzegovina  has  received  the  explanatory  materials  on  the  EU  acquis.  To  be 
able  to  speak  with  one  voice  during  negotiations,  Bosnia  and  Herzegovina  needs  to  appoint  a  chief 
negotiator and their team, who may present the countrywide level of alignment with the EU acquis. 

Governance   

23 

 
 
Presidency  members  continued  to  present  diverging  stances.  The  Council  of  Ministers  took  action  to 
adopt  EU-related  reforms,  in  particular  prior  to  the  Commission  report  in  March  2024.  Entity 
governments worked regularly. Executive authorities are in place at all levels following the setting up of 
the last cantonal governments by March 2024. The Republika Srpska entity continued not to recognise the 
rulings of the Constitutional Court, in breach of the constitutional and legal order, calling into question 
the authority and integrity of the Constitutional Court. The entity leadership continued with secessionist 
rhetoric. Independent institutions remain weak. 

Civil society  

The Republika Srpska entity government withdrew its draft law on ‘foreign agents’ in May 2024. Such a 
law should not be reintroduced, as it would adversely affect democratic values and fundamental freedoms, 
and would mark a step backwards. The criminal penalties for defamation in the Republika Srpska entity 
continue  to  severely  impact  the  environment  for  civil  society  and  restrict  freedom  of  expression  and 
media  freedom  and  to  have  a  chilling  effect  on  media  freedom;  defamation  is  yet  to  be  decriminalised 
across the country. 

The  legislation  on  public  consultations  is  uneven  across  the  country.  Meaningful  and  systematic 
consultations must be ensured. The e-consultation web platform is underutilised and is not in use at entity 
or cantonal level, where most legislation of public interest is adopted. Some 7 years after its adoption in 
2017,  the  Council  of  Ministers  still  needs  to  enact  its  Charter  on  cooperation  with  civil  society 
organisations. 

Grassroots  civil  society  organisations  advocate  proactively  for  policy  changes.  Activists  dealing  with 
issues  perceived  as  sensitive  (such  as  anti-corruption,  women’s  rights,  rights  of  LGBTIQ  persons, 
migrants, environmental protection) continued to be subject to threats and attacks.  

A framework for the transparent and impartial distribution of public funds to associations is needed across 
the country. Civil society organisations that provide services to disadvantaged groups in place of public 
authorities should receive appropriate public funding. Women’s associations in particular play a key role 
in  reaching  out  to  the  most  vulnerable,  including  victims  and  survivors  of  domestic  and  gender-based 
violence. There is no state-level legal framework on volunteering, which is regulated by the entities and 
the Brčko District.  

2.1.2. Public administration reform  

Strategic framework for public administration reform 

The  strategic  framework  on  public  administration  reform  2018-2022  has  been  extended  until  2027. 
Implementation has been very low (16%), although the monitoring report and other IT and data tools have 
improved.  The  action  plan  2023-2027,  revised  to  include  a  credible  costing  of  reforms,  is  pending 
adoption  Bosnia and Herzegovina has put in place a PAR common platform, a coordination committee 
for  PAR  and  supervisory  teams  at  all  administrative  levels,  which  is  a  positive  step  towards  ensuring 
political  support  and  decision-making.  The  newly  established  structures  need  to  ensure  efficiency  to 
advance  public  administration  reforms.  The  coordination  committee  met  for  the  first  time  at  prime 
ministers’  level  in  February  2024.  Higher  governmental  budgetary  contributions  for  2024-2025  are 
needed  for  financial  sustainability.  The  weak  capacities  of  entity-level  PAR  coordinators  continue  to 
hinder reforms. 

Policy development and coordination 

The policymaking system across sectors  remains fragmented, with no systematic improvement on the 
legal or institutional framework needed to ensure a countrywide approach to policymaking and budgeting. 
State-level institutions need to be strengthened in steering countrywide policies. The legislation at state 
level on countrywide sectoral strategic planning is pending adoption. The Council of ministers adopted a 

24 

 
 
decision  on  the  procedure  for  mid-term  planning,  monitoring  and  reporting  in  the  institutions  of  BiH. 
However it does not provide for a co-ordinated whole-of-government medium-term priorities setting. The 
institutional  framework  remains  fragmented  with  insufficiently  delineated  quality  oversight  functions. 
The  delay  in  designating  a  single  state-level  institution  in  charge  of  annual  and  medium  term  policy 
planning  undermines  a  whole-of-government  approach  in  strategic    policy  and  budgeting  processes  for 
EU integration issues. The country still lacks a methodology with strong quality assurance and a conflict 
resolution  mechanism  for  harmonised  and  coordinated  legislative  alignment  with  the  EU  acquis.  
Effective  monitoring  and  alignment  with  annual  budgets  and  government  working  plans,  and  credible 
costing on sectoral policies need to be ensured. 

Implementation  of  the  legal  framework  for  inclusive  and  evidence-based  policy  development  across 
different  levels  of  government  remains  weak.  The  state-level  e--consultation  system  was  improved  by 
introducing  an  obligation  for  institutions  to  publish  reports.  The  administrative  capacity  to  use  e-
-consultation  platforms  should  be  improved  at  all  levels  of  government.  The  lack  of  progress  in 
developing common standards for monitoring and reporting hampers public and government scrutiny of 
sectoral policy implementation. 

Public financial management 

All levels of government advanced in implementing the comprehensive strategy for the reform of public 
financial  management.  The  comprehensive  PFM  monitoring  report  for  2023  is  pending  adoption;  the 
timely adoption of such reports remains a challenge. Bosnia and Herzegovina should apply a countrywide 
approach on PFM monitoring, with a higher number of horizontal coordinated activities at each level of 
government than is the case (7%). This needs to be reflected  in the revised action plan for 2024, which is 
pending adoption. Despite progress, the PFM system still needs to put in place basic elements such as the 
regular adoption of a state budget,  and ensure credible costing of sectoral and cross sectoral policies in 
annual and medium term. Adopting a credible medium-term budget framework in line with international 
standards and related fiscal framework remains a challenge. Outstanding PFM reforms include: (i) better 
linking  the  annual  strategic  planning  and  budgeting  processes  in  the  annual  and  medium  run;  (ii) 
strengthening capacities on public investment management; and (iii) continuing to implement the laws on 
programme budgeting and adopting similar legislation in the  Republika Srpska entity. Institutions at all 
levels need to improve the functioning of public internal financial control and public procurement, as well 
as the monitoring of fiscal risks related to public companies. Budget transparency remains insufficient.  

Public service and human resources management 

The state-level Law on civil service, adopted in March 2024, aims to improve transparency in recruitment 
and to introduce human resource management tools. Civil service laws are still not harmonised with one 
another,  and  merit  principles  are  not  enshrined  in  the  recruitment,  promotion  and  dismissal  of  civil 
servants. 

There  was  no  progress  on  ensuring  a  depoliticised  and  professional  civil  service.  The  criteria  for 
dismissals,  disciplinary  procedures  and  appeals  set  out  in  the  legislation  continue  to  be  insufficiently 
applied. The digitalisation of state-level recruitment is ongoing. Entity-level laws do not require the best 
candidate to be appointed, allowing political appointees to influence recruitment, particularly for senior 
positions.  At  cantonal  level,  the  final  selection  continued  to  depend  on  ethnic  background  rather  than 
merit.  The  excessive  use  of  acting  positions  continued,  especially  in  the  Republika  Srpska  entity. 
Constitutional rules on the general representation of the population in public administration should not be 
interpreted as requiring strict ethnic proportionality in the civil service, and the legislation should ensure 
that ethnic criteria do not prevail over professional criteria in recruitment. 

The  quality  and  capacity  of  human  resources  management  (HRM)  remain  weak  and  highly 
fragmented.  The  forum  of  directors  of  civil  service  agencies  was  re-established  in  October  2023  to 
coordinate human resources management strategies and monitoring. The Federation entity and its cantons 

25 

 
 
continued to implement the 2022-2027 strategy for the development of HRM. The state-level institutions 
and the Republika Srpska entity still need to do the same. Transparent monitoring and planning of HRM 
performance  and  related  capacity  and  data  on  HRM  needs  to  be  strengthened;  the  Federation  entity 
adopted a human resources monitoring methodology in June 2024. 

Civil  servants’  remuneration  remained  inconsistent  across  the  country  due  to  differences  in  salary 
legislation,  job  classification,  pay  grades  and  the  lack  of  job  evaluations,  all  of  which  hinder  fairness. 
Criteria for awarding salary supplements are unclear, and no information is published on average salary 
levels  by  job  category.  A  broad  salary  reform  is  required  across  all  levels  of  government,  as  is  the 
harmonisation of civil service job descriptions. 

Civil service agencies need more resources for training and professional development. Overall, there has 
been  no  progress  in  making  performance  appraisal  a  more  useful  tool  to  justify  promotions  or  to 
distinguish good performance from bad. 

There continues to be no system for gathering and consolidating data on the integrity of civil servants. 
There  has  been  no  legislative  development in  the  Federation  entity  on  whistle-blower  protection,  or  on 
declaration of assets in the Republika Srpska entity. 

Accountability of administration 

No progress was made in setting out the functions of administrative bodies at all levels of government or 
in clarifying responsibilities between ministries and subordinate bodies. 

The  state-level  Law  on  freedom  of  access  to  information  still  needs  to  be  brought  fully  in  line  with 
international  standards  on  the  independence  of  the  appeals  process,  while  the  Brčko  District  needs  to 
adopt  its  own  law  in  this  field.  The  Council  of  Ministers  adopted  in  April  2024  a  guide  for  access  to 
information to ensure effective access to this right, while in May 2024 the Ministry of Justice introduced a 
register of requests for access to information. Rules on data protection and access to information are still 
interpreted  in  a  way  that  protects  private  rather  than  public  interests  across  levels  of  government. 
Ombudsman  recommendations  towards  public  authorities  remain  mostly  focused  on  ensuring  access  to 
information, although with a slight decrease in 2023 compared with 2022.  

Service delivery to the public and businesses 

There  was  no  progress  in  amending  and  harmonising  the  legal  framework  for  user-oriented 
administration  across  the  country.  There  is  no  comprehensive  countrywide  policy  on  service  delivery 
and clear institutional functions at any level of government together with a catalogue on e-service. The 
absence  of  electronic  signature  infrastructure  for  the  public  continued  to  impede  further  digitalisation. 
Some progress was made in the Federation entity on digital transformation, criteria and benchmarks for 
increased  cooperation  among  authorities.  Encouraging  user-oriented 
one-stop  shops,  and  on 
administration, including by adopting the action plan on PAR and completing a coherent legal framework, 
would facilitate the establishment of an interoperable e-signature system across the country and facilitate 
the emergence of a single digital market in Bosnia and Herzegovina. 

2.2.   RULE OF LAW AND FUNDAMENTAL RIGHTS  

2.2.1.  Chapter 23: Judiciary and fundamental rights  

The EU’s founding values include the rule of law and respect for human rights. An effective (independent, 
high-quality  and  efficient)  judicial  system  and  an  effective  fight  against  corruption  are  of  paramount 
importance, as is the respect for fundamental rights in law and in practice.  

Functioning of the judiciary  

26 

 
 
 
Strategic documents 

Bosnia and Herzegovina lacks strategic documents as it still needs to adopt a new justice sector reform 
strategy  and  related  action  plan.  The  draft  text  pending  adoption  by  the  Council  of  Ministers  is  the 
product of an inclusive consultation process and should be supported by sufficient budgetary allocations 
and  an  efficient  governance,  monitoring  and  performance  reporting  mechanism,  with  the  possibility  to 
adopt  corrective  actions.  The  reform  programme  for  2024-2026  of  the  High  Judicial  and  Prosecutorial 
Council  (HJPC)  focuses  on  more targeted  reforms,  particularly  on  comprehensive  monitoring  based  on 
transparent evaluation mechanisms. The HJPC should adopt an accompanying action plan. 

Management body 

The  HJPC  functions  adequately  as  the  judiciary’s  single  self-governance  body.  It  should  ensure 
independence  and  integrity  in  the  method  of  appointing  its  members  by  reinstating  randomisation  for 
ethnicity and gender. The budget of the HJPC needs to be increased to establish a functioning department 
for asset declaration and verification, and to enable gradual transition of the entire HJPC staff to the 2027 
state  budget.  The  HJPC  initiated  measures  for  better  judicial  response  to  cases  of  domestic  violence, 
attacks  on  returnees,  protection  of  journalists  and  activists,  and  the  fight  against  organised  crime  and 
corruption.  However,  the  HJPC  needs  to  improve  the  enforcement  of  its  decisions  through  closer 
collaboration  with  presidents  of  courts  and  chief  prosecutors  and  through  the  use  of  accountability 
mechanisms.  

Independence and impartiality 

The  independence  and  impartiality  of  the  judiciary  needs  improvement.  This  applies  to  courts  and 
prosecutors’  offices,  both  at  higher  level  and  at  first  instance.  Public  trust  is  further  eroded  by  media 
reports  on  public  appearances  by  judicial  office  holders,  including  HJPC  members,  in  the  company  of 
individuals  suspected  of  crimes.  The  HJPC  and  all 
courts and prosecutors’ offices should increase efforts 
to  restore  public  trust  in  the  judiciary,  addressing  in 
particular the length (up to 7 years) of criminal trials 
that  involve  judges  and  prosecutors,  including  those 
in  management  positions  charged  of  corruption.  The 
HJPC  and 
judiciary  should  efficiently  and 
effectively  process  corruption  cases  involving  their 
own  peers.  Undue  internal  and  external  pressure 
continues.  The 
threat-reporting  mechanism  and 
subsequent  public  reactions  of  the  HJPC  must  be 
reviewed  to  ensure  consistency.  The  HJPC  rarely 
receives requests for protection from undue influence 
from judges and prosecutors in case of threats against 
their  independence.  The  new  Law  on  the  HJPC  should  address  the  limited  impact  of  HJPC  actions  to 
defend  the  independence  of  judges  or  prosecutors.  A  security  strategy  for  the  judiciary  and  an 
accompanying action plan are pending adoption.  

the 

The case management system (CMS) provides efficient randomised case allocation when used. No reason 
was given for why half of the cases were manually reallocated, which is of serious concern. 

The  Federation  entity  assembly  appointed  one  constitutional  judge  in  May  2024,  filling  one  of  the 
vacancies. The Republika Srpska entity assembly should swiftly appoint two judges to the Constitutional 
Court of Bosnia and Herzegovina, ensuring its full composition and functioning. The  Republika Srpska 
entity should fully recognise and enforce Constitutional Court decisions, repealing any legislation to the 
contrary which is in breach of the constitutional and legal order.  

Accountability 

27 

 
 
The  accountability  of  the  judiciary  needs  to  be  improved.  In  January  2024,  Bosnia  and  Herzegovina 
revised the integrity-related amendments to the Law on the HJPC to remove the restriction to accessing 
personal data for external experts tasked with monitoring the asset declaration system. The right of the 
HJPC to request additional information from natural and legal persons still needs to be strengthened by 
law,  in  line  with  European  standards,  to  ensure  that  the  HJPC  can  effectively  access  all  necessary 
information to exercise its functions. 

Judicial  integrity  plans  are  in  place  in  almost  all  courts  and  prosecutors’  offices,  albeit  with  limited 
results.  HJPC  should  regularly  assess  their  effectiveness  as  a  preventive  anti-corruption  tool  and 
communicate the impact of their measures publicly. Judicial and prosecutorial ethics codes are in place 
and  form  part  of  the  curriculum  for  initial  training, 
but  they  need  to  be  significantly  improved.  Causing 
damage to the reputation and integrity of the judiciary 
is  now  deemed  a  violation  of  the  ethics  code;  the 
HJPC  should  monitor  the  impact  of  the  related 
disciplinary measures.  

Graph 3: Bosnia and Herzegovina -
Disciplinary procedures - outcome of 
procedures - 2023

28

40

24

23

20

Disciplinary  procedures  continue  to  have  little 
dissuasive effect despite their relatively high number. 
To  address  serious  breaches  of  judicial  integrity, 
HJPC disciplinary bodies should: (i) better select and 
prioritise  disciplinary  cases;  (ii)  improve  rules  on 
evidence  in  disciplinary  hearings;  and  (iii)  amend 
internal  guidelines  to  improve  the  reasoning  and  transparency  of  disciplinary  decisions,  thus  ensuring 
consistency and (iv) ensure that the severity of sanctions has a deterring effect. 

Sanctions pronounced

Prosecutors

Source: CEPEJ

Completed

Initiated

Judges

5

5

0

9

Quality of justice 

interview 

questions, 

the  HJPC  updated 

The  quality  of  justice  needs  to  be  improved.  Legal  safeguards  for  the  independence  of  judicial 
appointments  carried  out  by  the  HJPC  are  in  place  and  were  improved  with  the  September  2023 
amendments  to  the  Law  on  the  HJPC,  introducing  the  right  to  appeal  the  appointment  decision. 
Consequently,  the  reasoning  behind  appointment  decisions  should  also  be  improved  in  practice;  their 
publication on the HJPC website is 
a legal requirement. To improve the 
the 
process, 
database  of  written  examinations 
and 
and 
developed  guidelines  for  interview 
panels.  Further  improvements  need 
to be introduced in the new Law on 
the  HJPC.  These  should  consist  in: 
(i)  annual  entry  appointments  to 
separate  the  recruitment  process 
from  specific  vacancies;  (ii)  career 
and  promotions  based  on  seniority 
requirements 
and  an  effective 
appraisal of performance; and (iii) a 
guarantee that ethnic criteria do not 
prevail  over  professional  criteria  in  recruitment.  The  HJPC  had  introduced  some  of  these  regulatory 
solutions,  but  they  were  challenged  in  court;  this  further  reinforces  the  need  for  legislative  changes. 
Introducing guidelines on drafting better quality indictments could additionally help prosecutors. 

The  performance  appraisal  system  is  ineffective,  as  all  court  presidents  and  chief  prosecutors  were 

28 

 
 
found to have successfully performed their functions. These results lack nuance and do not contribute to 
the system serving its intended purpose. In February 2024, the HJPC approved new rules on performance 
appraisal. It should adopt criteria to enable balanced consideration of quantitative and qualitative criteria 
in the appraisal of judicial management.  

Training for judges and prosecutors is handled by entity-level training centres, coordinated by the HJPC. 
Their  division  of  responsibilities  needs  to  be  clarified  and  the  HJPC’s  coordination  role  needs  to  be 
strengthened.  Selecting  competent  trainers,  devising  training  programmes,  assessing  trainers  and 
evaluating  the  impact  of  training  should  be  closely  monitored  and  improved  where  needed.  The  total 
budget for training in 2023 was 13.4% lower than in 2022.  

The  case  management  system  (CMS)  produces  reliable,  detailed  statistics  and  reports  on  case  flow, 
human resources and duration, contributing to timely judicial data delivered to CEPEJ. The HJPC needs 
to step up its oversight and management on the basis of reliable statistical data on the performance of the 
judicial system, including on case reallocations. For this, a tailored judicial management training with a 
component on data analysis should be provided to HJPC members, court presidents and chief prosecutors. 
The  HJPC  adopted  a  mid-term  judicial  ICT  strategy  and  laid  the  groundwork  for  a  regional  ICT  hub 
aiming to further digitalise the judiciary.  

The  justice  system  still  lacks  transparency.  The  HJPC  has  maintained  its  efforts,  adopting  a 
communication strategy and revising its rules on publishing judicial decisions online. The HJPC should 
further  promote  the  consistent  publication  of  hearing  schedules  and  judicial  acts.  The  HJPC  online 
database now includes over 26 000 court decisions, with analytical functionalities.  

There were limited results on the harmonisation of jurisprudence, with only 2 positions adopted by the 
panels  for  the  harmonisation  of  judicial  practice.  The  HJPC  should  closely  monitor  the  impact  of  the 
panels’  work.  The  HJPC  database  of  appellate  court  legal  positions  should  further  serve  as  a  tool  for 
securing uniform judicial practice across the country. Ultimately, the country needs to establish a judicial 
body  capable  of  ensuring consistent interpretation  of  the  law  and  harmonisation  of  case law  across the 
country (Opinion key priority 4.e). 

In 2023, the total budget for the judiciary, including the HJPC, was EUR 183.2 million, an increase of 
0.73% of GDP compared with 2022. Although the budget is now at the same level as the median value for 
the  Western  Balkans,  the  funds  remain  insufficient  for  investments.  Ensuring  sufficient  financing  of 
judicial  institutions  is  a  responsibility  of  the  executives  at  all  levels  of  government.  This  leads  to 
difficulties in budget planning and negotiations over budget inequalities, which have a negative effect on 
equal access to justice. The HJPC role in budget planning and negotiations for judicial institutions should 
be strengthened in the new Law on the HJPC.  

The  Ministry  of  Justice  still  needs  to  adopt  the 
mediation strategy proposed by the HJPC in 2022 as 
resolution 
the  alternative  dispute 
part  of 
mechanisms.  The 
legislative 
strategy  outlines 
training  for  mediators,  and  promotes 
changes, 
mediation among court users and with the public.  

Efficiency 

250
200
150
100
50
0

Graph 5: Bosnia and Herzegovina  -
Alternative dispute resolution - 2023 

202

120

136

The  efficiency  of  justice  needs  to  be  improved.  The 
length  of  court  proceedings  in  first-instance  cases 
(excluding utility cases) further fell to 361 days in the 
first quarter of 2024 but is still excessive and hampers 
the  citizens’  right  to  trial  within  a  reasonable  time. 
The  Federation  entity  still  needs  to  adopt  a  law  to 
protect this right. The enforcement and impact of such laws should be monitored. The HJPC and judicial 
29 

Finalised court-
related
mediations

Settlement
agreements

Mediation cases

Source: CEPEJ

Mediators

 
 
management  should  ensure  that  judges  and  prosecutors  comply  with  the  respective  rules  on  civil 
proceedings and update those rules as needed.  

There  is  a  backlog  of  over  2  million  pending  court  cases,  including  some  1.7  million  cases  of  unpaid 
utility bills, which continues to hinder efficiency of justice. The backlog of non-utility cases fell slightly 
by  2%  compared  with  2022.  Entity-level  legislation  needs  urgent  amendment  to  increase  efficiency  in 
transferring the enforcement of small and uncontested claims from courts to professional bailiffs. Entity 
and  cantonal  governments  did  not  secure  sufficient  funds  for  enforcement  departments  in  courts  or  for 
access to information on debtor’s properties. Entity-level laws and regulations on enforcement have to be 
amended urgently to increase efficiency.  

Graph 6.1: Bosnia and Herzegovina -
Efficiency of courts (%) 

118

116

102

101

101

96

108

103

120

100

80

60

40

20

0

Graph 6.2: Bosnia and Herzegovina -
Disposition time (days)

613

606

255

246

253

241

74

56

700
600
500
400
300
200
100
0

1st
instance

2nd
instance

1st
instance

2nd
instance

1st
instance

2nd
instance

1st
instance

2nd
instance

Criminal cases

Non-criminal cases*

Criminal cases

Non-criminal cases*

Clearance rate in 2022 %
Clearance rate in 2023 %

Disposition time 2022 (days)
Disposition time 2023 (days)

* Civil and commercial cases, administrative
cases, non-litigous cases, other cases

Source:CEPEJ

* Civil and commercial cases, administrative
cases, non-litigous cases, other cases

Source:CEPEJ

The  changes  to  the  prosecutorial  quota  did  not  deliver  positive  outcomes  and  the  performance  of  the 
prosecutorial system has not been satisfactory. Indictments continued to decline in 2023. The HJPC needs 
to assess the reasons for this and readjust the quotas as needed. 

Domestic handling of war crime cases 

(IRMCT 

Bosnia  and  Herzegovina 
cooperates  closely  with 
the  International  Residual 
Mechanism  for  Criminal 
Tribunals 
/ 
submitting 
Mechanism), 
70%  of  all  requests  for 
assistance from the region 
to 
the  Mechanism’s 
Prosecutor  in  2023  (40% 
in 2022). In January 2024, 
the  Ministry  of  Justice 
and  the  Registry  of  the 
a 
Mechanism 
memorandum 
of 
understanding  to  provide 

signed 

Graph BIH 1: Bosnia and Herzegovina - Processing of war crime 
cases

100,00

1210

1000

500

0

571

-53,00

395

-67,00

243

178

25

n/a

n/a

n/a

July 2013

2021

261

152

12

2022

209

-73,00

322

149

8

2023

100,00

0,00

-100,00

Complex cases
Less complex cases transferred to lower levels
Cases with unavailable suspects
Total number of pending cases
Percentage of the decrease Source: High Judicial and Prosecutorial Council 

30 

n/a: not available

 
 
 
 
information on war crimes convictions by the International Criminal Tribunal for the former Yugoslavia 
(ICTY)  and  its  successors.  The  authorities  must  now  ensure  their  swift  introduction  into  domestic 
criminal  records.  The  deadline  for  implementing  the  revised  National  War  Crime  Strategy  must  be 
extended beyond 2025 and efforts to fulfil its objectives need to intensify.  

Regional judicial cooperation in processing war crime cases improved slightly through more systemic 
use of available tools, particularly the bilateral protocols on cooperation between prosecutors’ offices in 
the region. Institutional cooperation with Serbia and with Montenegro remains effective and productive, 
while cooperation with Croatia continues to face a number of impediments. Improving the support system 
for victims and witnesses of war crimes by responding to their needs efficiently and in a timely manner 
would increase their support for judicial proceedings and increase their sense of having contributed to the 
delivery of justice. 

80

60

40

40

38

100

85,0

58,50

57,00

86,00

courts 

taking 

advantage 

in  Bosnia 

Graph BiH 2: Bosnia and Herzegovina -
War crime indictments filed / confirmed 

the  end  of  2023,  94 
By 
individuals  were  not  available 
to 
and 
Herzegovina.  Holding  multiple 
citizenships,  these  individuals 
often  reside 
in  neighbouring 
countries.  They  escape  justice 
by 
of 
prohibitions  in  those  countries 
against  extradition  of their  own 
nationals 
criminal 
offences  of  genocide,  crimes 
and  war 
against  humanity 
crimes.  They  also  benefit  from 
neighbouring  jurisdictions’  lack 
of  progress  in  addressing  the 
question.  Such 
crimes 
individuals include Novak Djukić, Duško Kornjača and Tomislav Kovač in Serbia, and Sakib Mahmuljin 
in Türkiye. 

Final
conviction rate
%
(Entity/Brcko
District)

Confirmed
indictments
(Entity/Brcko
District)

Final
conviction rate
% (State level)

Filed 
indictments –
overall

Confirmed
indictments
(State level)

Source: High Judicial and Prosecutorial Council 

57,50

the 

for 

2021

2022

2023

67,0

in 

21

15

13

22

16

13

25

20

0

Fight against corruption  

Track record 

There  were  no  changes  in  the  fight  against  corruption  in  the  reporting  period,  and  efforts  remained 
insufficient  to  establish  a  track  record  of  proactive  investigations,  prosecutions  and  final  convictions. 
Progress in tackling high-level corruption needs to be seriously stepped up. The former Prime Minister of 
the  Federation  entity  received  a  final  conviction,  and  the  former  Minister  of  Security  a  first-instance 
conviction. Indictments were confirmed against the head of one Sarajevo municipality, against Sarajevo’s 
former mayor, and against the former Minister of Human Rights and Refugees. Investigations are ongoing 
against  other  senior  officials.  It  is  essential  that  prosecution  and  judicial  services  ensure  independent, 
effective  and  impartial  judicial  follow-up  in  these  cases,  which  are  of  great  public  resonance  and  raise 
concern about the state of corruption in the country. It is imperative for law enforcement agencies and the 
judiciary in Bosnia and Herzegovina to take a more proactive stance in combating organised crime and 
corruption, free from outside interference. 

31 

 
 
The state-level Commission on Conflict of Interest established in March 2023 remained ineffective and 
pronounced  no  sanctions.  Following  the  entry  into  force  of  the  new  Law  on  conflict  of  interest, 
Parliament failed to appoint the members of the related commission by the legal deadline of June 2024; 
new members were appointed by the House of Peoples in October 2024 and remain to be confirmed by 
the  House  of  Representatives.  Many  more state-level  officials  complied  with their  obligation to  submit 
financial reports for the verification of asset declarations (425 out of 550); however, those who did not 
submit  a  financial  report  faced  no  proceedings,  reports  nor  sanctions.  There  are  marked  differences  in 
compliance across the country. In the Republika Srpska entity the figure for submitting financial reports 
remains very low (136 out of 4 000), while in the Federation entity the rules on conflict of interest are not 
enforced. The positive trend continued with tangible results in the Brčko District and Sarajevo Canton, 
with a relatively high number of proceedings and sanctions initiated for conflict of interest. Tuzla Canton 
also demonstrated good results in verifying asset declarations. 

Institutional framework  

The institutional framework on the fight against corruption is not fully in place, and needs to be improved 
regarding both preventive measures and law enforcement. Corruption prevention bodies continued to be 
ineffective and uncoordinated. The Agency for the Prevention of Corruption and the  Coordination of the 
Fight against Corruption (APIK) should exercise its legal competence as the main coordinator and central 
point  for  anti-corruption  activities  in  Bosnia  and  Herzegovina.  The  Agency  should  play  a  much  more 
proactive role in implementing GRECO recommendations and aligning with international standards. 

The  independence  of  corruption  prevention  bodies  at  entity  and  cantonal  level  and  their  human  and 
material  resources  need  to  be  significantly  strengthened.  The  anti-corruption  offices  of  Sarajevo  and 
Tuzla cantons continued tangible efforts and remain a good example.  

The  audit  department  of  the  Central  Election  Commission  needs  more  capacity  to  monitor  compliance 
with  political  party  financing  laws.  The  Permanent  Committee  for  the  Fight  against  Corruption 
established  by the  House  of  Representatives  of  Bosnia  and  Herzegovina in  2022  still  needs  to fulfil its 
mission as a key mechanism of parliamentary oversight.  

The criminal justice policy and the institutional and legislative frameworks across the country are largely 
ineffective  and  inadequate  for  the  fight  against  corruption.  This  is  due  in  part  to  insufficient  law 
enforcement  capacity  to  investigate  and  also  to  penalties  that  do  not  sufficiently  ensure  deterrence. 
Crucial efforts to trace and freeze illegal gains from criminal activities and to require criminals to forfeit 
their  gains  remain  inadequate.  Financial  investigations  are  infrequent,  and  the  use  of  extended 
confiscation  provisions  is  almost  non-existent,  hindering  the  effective  disruption  of  criminal  networks. 
Deep legal fragmentation and frequent conflicts of jurisdiction, leading to transfers of cases, have slowed 
down proceedings and reduced efficiency. The police is not proactive in launching investigations, which 
also proceed slowly. In 2023, as in 2022, no law enforcement agency, including the State Investigation 
and Protection Agency (SIPA), submitted any report on high-level corruption to the Prosecutor’s Office 

32 

 
 
 
of  Bosnia  and  Herzegovina.  The  highly  formalistic  manner  in  which  SIPA  enforces  actions  to  obtain 
evidence,  including  in  high-level  corruption  cases,  remains  a  cause  of  serious  concern.  Systemic 
shortcomings  in  operational  cooperation  between  law  enforcement  agencies  and  the  very  limited 
exchange of intelligence are a persistent challenge. Plea agreements need to be used strategically to co-opt 
defendants  in  obtaining  information  and  evidence,  and  should  require,  where  relevant  and  viable,  asset 
forfeiture  or  payment  of  damages  to  the  injured  party.  In  the  few  high-level  corruption  cases  reported, 
selective  judicial  follow-up  and  legal  mistakes,  negligence,  abuse  of  procedures,  political  pressure, 
questionable court decisions and verbal attacks on the prosecution continued to take place, including at 
state  level.  Pressure,  interference  and  verbal  attacks  on  judicial  office  holders  continued,  without  a 
systemic and efficient response by the HJPC, as illustrated in a number of high-level cases.  

Investigations are seriously hampered by the lack of cooperation between law enforcement agencies and 
prosecutors’  offices  and  by  the  lack  of  effective  monitoring  by  prosecutors  of  the  work  of  police.  The 
selective unwillingness of the police, including at state level, to cooperate with prosecutors, particularly in 
high-level corruption cases, is a cause of serious concern.  

Diverging  views  on  the  authority  of  state-level  prosecution  offices  to  issue  instructions  to  entity 
prosecution  offices  hamper  the  efficiency  of  investigations  and  proceedings  in  high-level  corruption 
cases. Such conflicting legal views must be remedied immediately. 

The  special  anti-corruption  departments  within  prosecution  offices  at  state  level  and  in  the  Republika 
Srpska entity must start to deal effectively with high-level corruption cases. Their independence must be 
significantly  strengthened.  Specialised  departments  have  not  yet  been  set  up  in  the  Federation  entity 
Prosecutor’s Office and Supreme Court.  

A  specialised  team  of  prosecutors  at  the  Prosecutor’s  Office  of  Bosnia  and  Herzegovina  continued  to 
investigate  cases  efficiently  based  on  evidence  from  the  SKY  ECC  communications  tool.  This  led  to 
tangible  results  in  initiated  investigations  and  confirmed  indictments.  Prosecutors  are  expected  to 
demonstrate  firm  determination  to  prioritising  and  finalising  investigations  of  mid-  and  high-level 
corruption cases arising out of the SKY ECC tool and to ensure efficient judicial follow-up in those cases. 
The deputy director of SIPA remains at large after illegally crossing the border to escape an arrest warrant 
for suspected abuse of position and corruption.  

Strategic documents  

Strategic  documents  are  partly  in  place.  In  June  2024,  Bosnia  and  Herzegovina  adopted  a  state-level 
strategy and action plan on anti-corruption for 2024-2028, as the previous one had expired in 2019. As the 
adopted strategy relates mainly to the state level, entities and cantons need to update and align their own 
strategies  with  the  principles  of  the  state-level  strategy,  with  sufficient  funding  and  strong  monitoring 
mechanisms to ensure their implementation.  

Legal framework 

The  legal  framework  on  the  fight  against  corruption  is  not  fully  in  place,  and  needs  to  be  improved 
regarding  both  preventive  measures  and  law  enforcement.  The  lack  of  harmonisation  of  the  legal 
framework across the country continued to hamper the fight against corruption. In March 2024, Bosnia 
and Herzegovina adopted a state-level Law on the prevention of conflict of interest. This is a substantial 
step forward compared with the legislation previously in place. However, the law still needs to be fully 
aligned with European standards, particularly in the areas of incompatibilities, sanctions, and the election 
and composition of the Commission on Conflict of Interest. All levels of government need to fully align 
their legislation on conflict of interest with European standards and to implement the law in good faith. 

The legislative framework on the protection of whistle-blowers is still incomplete and not fully in line 
with  the  EU  acquis.  Notably,  the  Federation  entity  still  lacks  legislation  on  whistle-blower  protection, 
although such protection is present in the Sarajevo Canton. Where applicable, very few or no requests for 

33 

 
 
protection were received, with the exception of Sarajevo Canton, where 7 requests out of 8 were granted. 

Data  protection  laws  continued  to  be  interpreted  in  a  way  that  protects  private  rather  than  public 
interests,  hindering  the  prevention  and  repression  of  corruption.  There  is  no  legislation  to  effectively 
prevent  and  address  corruption  in  the  private  sector  and  no  regulation  of  lobbying.  Barely  1  out  of  15 
GRECO  recommendations  has  been  satisfactorily  implemented  in  the  fourth  evaluation  round.  The 
authorities  need to fulfil the  outstanding  recommendations,  particularly  on  political  party  financing  and 
conflict of interest.  

A beneficial ownership register of legal persons needs to be established, ensuring a central access point to 
the competent authorities. 

Fundamental rights  

International human rights instruments  

Bosnia and Herzegovina has ratified all major European and international human rights instruments. The 
country  needs  to  advance  in  addressing  the  accepted  recommendations  from  the  November  2019 
Universal Periodic Review ahead of the next cycle in January 2025. The country should replicate the data 
collection  methodology  of  the  EU  Agency  for  Fundamental  Rights  and  is  encouraged  to  seek  observer 
status in the agency. 

European Court of Human Rights  

During  the  reporting  period,  the  European  Court  of 
Human  Rights  (ECtHR)  found  breaches  of  the 
European  Convention  on  Human  Rights  in  regard  to 
the  right  to a  fair trial,  the  protection  of  property,  and 
the  general  prohibition  of  discrimination.  There  are 
four  cases  under  enhanced  supervision  by 
the 
Committee  of  Ministers,  all  related  to  electoral  rights. 
The Sejdić and Finci, Zornić, Šlaku, Pilav and Pudarić 
rulings  (Sejdić-Finci  case  law)  require  constitutional 
amendments  to  ensure  political  equality  among  all 
citizens;  a  grand  chamber  decision  is  pending  on  the 
Kovačević case on active voting rights. The country has 
made  progress  on  addressing  other  structural  reforms 
raised by Court judgements; efforts need to continue. 

Promotion and enforcement of human rights  

Graph 8: Bosnia and Herzegovina - ECtHR 
Judgments 

1000

303

162

100

10

1

New
allocated
applications

130

49

9

2

6

2

Judgments Breaches

Pending
applications

16.06.2022 - 15.06.2023
16.06.2023 - 01.09.2024

Source: ECtHR

rights, 

human 

Bosnia and Herzegovina still lacks 
a comprehensive policy framework 
on  the  promotion  and  enforcement 
including 
of 
countrywide  strategies  on  human 
rights,  non-discrimination  and  the 
protection 
minorities. 
of 
Consequently,  the  protection  of 
human 
remains  uneven 
across  the  country.  The  Human 
Rights  Ombudsman is the equality 
body  of  Bosnia  and  Herzegovina. 
Its 
and 
consensual  decision-making  rules 

composition 

tripartite 

rights 

5000

0

Graph 9: Bosnia and Herzegovina - Promotion and 
enforcement of human rights

2850

2794

428

30,14

n/a

356

49,59

n/a

2023

2024

Ombudsperson

Complaints
Decisions
Recommendations to the authorities
Implementation of the recommendations by the authorities (% of the total)

34 

n/a: not available

Source: Ombudsman annual report

Main themes: access to information and police 

 
 
need  revision  to  ensure  effective  functioning.  The  Ombudsman  should  act  more  proactively,  and  its 
independence needs to be strengthened. While only half of its recommendations have been complied with, 
the Ombudsman has not opened any minor offence proceedings for non-compliance in the past 9 years, 
despite  having  the  power  to  do  so,  nor  has  it  initiated  or  intervened  in  administrative  or  judicial 
proceedings.  

Prevention of torture and ill-treatment 

40

70

32

to 

the 

80
70
60
50
40
30
20
10
0

Graph 10: Bosnia and Herzegovina - Torture / Ill treatments 
/ Excessive use of force

Bosnia  and  Herzegovina  still 
to  ensure  compliance 
needs 
with Article 17 of the Optional 
Protocol 
the  Convention 
Against  Torture.  The  August 
2023  amendments  to  the  Law 
on 
Ombudsman, 
designating  it  as  a  national 
preventive  mechanism  against 
torture    and  ill-treatment,  are 
yet  to  be  implemented.  The 
numerous 
ill-
reports 
treatment  need  to  be  handled 
effectively.  There  is  no  law 
laying 
countrywide 
criteria on the rights of civilian 
victims  of  wartime  torture,  a 
pending obligation under the Convention against Torture. Entity-level laws on victims of wartime torture 
need to be improved. A Council of Ministers decision is required to address the August 2019 decision of 
the UN Committee against Torture on providing redress to victims of wartime torture through an effective 
reparation  scheme,  including  compensation and  a formal  apology.  The  Republika  Srpska  entity  has  not 
taken measures to waive court fees for victims of wartime torture. As a worrying consequence, victims 
continue to face repossession of property for defaulting on payments.  

Source: Ministry of Justice and Ministry of Interior

Administrative decisions

Criminal convictions

Reported cases

down 

n/a: not available

Prisons

Police

2022

2022

2023

2024

2023

2024

of 

13

10

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

1

9

Execution of criminal sanctions  

in 

no 

and 

There is no countrywide strategy 
on  the  execution  of  criminal 
sanctions 
reliable 
statistics,  which  is  concerning. 
The  relevant  laws  need  to  be 
harmonised  across  the  country 
line  with 
and  brought 
European 
international 
standards.  Prison  directors  need 
to  be  appointed  based  on  merit. 
prison 
Detention 
reintegration 
regimes 
be 
to 
programmes 
improved,  and  an  effective 
probation system should be introduced.  

facilities, 

need 

and 

and 

There is no policy framework on transitional justice and dealing with the past. Bosnia and Herzegovina 
is expected to act in a sovereign manner to promote an environment conducive to reconciliation in order 
to overcome the legacies of the war (Opinion key priority 5).  

35 

 
 
Political leaders continued to engage in historical revisionism, including genocide denial and glorification 
of war criminals, while contesting established facts and the independence or impartiality of international 
and domestic tribunals. The September 2024 changes to the history curriculum for primary schools in the 
Republika Srpska entity on the 1992-1995 war is yet another example of the unconstructive politicisation 
of  education  in  Bosnia  and  Herzegovina,  promoting  biased  accounts  of  the  war,  especially  regarding 
heroes and victims. 

The Criminal Code needs to be amended to regulate genocide denial and glorification of war criminals in 
line with the EU acquis. The first two court proceedings are under way under the 2021 Law imposed by 
former  High  Representative  Inzko  criminalising  denial  of  genocide  and  glorification  of  war  criminals. 
The March 2024 electoral amendments excluded those convicted of war crimes from running for public 
office. Wartime victims continue to face numerous challenges. A state-level law  setting their minimum 
rights across the country is yet to be adopted. In August 2023, the Federation entity adopted a new law 
giving the status of civilian victims of war to children born of wartime-related sexual violence. Positive 
examples of trust building continue to be reported at local level. (For missing persons, see Section 3 – 
Good neighbourly relations and regional cooperation) 

Protection of personal data  

400

300

200

206

290

294

to 

to 

investigate 

Graph 12: Bosnia and Herzegovina - Data protection

The  legislation  on  data  protection  is  not  aligned  with  the  EU  acquis  –  the  General  Data  Protection 
Regulation  (GDPR)  and  the 
Law  Enforcement  Directive 
–  with 
the 
regard 
authorities’  processing  of 
to  prevent, 
personal  data 
or 
detect, 
prosecute  criminal  offences 
or 
criminal 
execute 
penalties;  alignment  is  also 
free 
lacking 
movement  of  data.  The 
independence and the human 
and  financial  resources  of 
the Personal Data Protection Agency did not increase. The Agency needs to better balance the protection 
of  privacy  with  the  general  public  interest,  notably  media  freedom,  electoral  integrity,  and  the  fight 
against  corruption.  While  the  state-level  Parliament  must  consult  the  Agency  on  legislative  proposals, 
other legislative assemblies are still not required to do so. 

Declarations of
data breaches

Administrative
sanctions

Source: Personal Data Protection Agency

Complaints
received

Inspections

Decisions

the 

2022

2023

on 

164

257

111

100

75

14

17

17

0

Freedom of religion or belief  

Freedom  of  thought,  conscience  and  religion  is  still  generally  upheld,  although  there  are  cases  of 
discrimination,  hate  speech  and  hate  crimes  on  religious  grounds.  Cases  of  attacks  continue  to  occur 
frequently in minority return areas.  

-------------------------------------------------------------------------------------------------------------------------------
-------------------------- 

Freedom of expression  

Intimidation of journalists  

Political pressure, intimidation and threats against journalists continued, including constant verbal attacks 
and  nationalist  rhetoric,  creating  a  hostile  environment  for  media  freedom.  High-level  politicians 
continued their  public  attacks  and  disparaging remarks  against  journalists,  analysts and  media  workers, 
particularly against women. The authorities continued to downplay the issue, with no public statements 
36 

 
 
on these issues, and institutional follow-up is weak. No official countrywide data is collected on threats 
and attacks against journalists and media workers and their judicial follow-up. These statistics should also 
be disaggregated by sex. 

In  2023,  the  BH  Novinari  journalists’  association  received  84  complaints,  and  the  Ombudsman  7, 
concerning violations of journalists’ rights. Authorities are expected to act swiftly and demonstrate zero 
tolerance for threats or attacks against the media, including by ensuring effective police investigation and 
judicial prosecution leading to final convictions.  

Legislative environment  

Freedom of expression and media freedom are in principle guaranteed by the Constitution and laws, but 
implementation  remains  insufficient.  Criminal  penalties  for  defamation,  reintroduced  in  the  Republika 
Srpska entity in July 2023, continue to severely impact freedom of expression and of the media and to 
have  a  chilling  effect.  Defamation  should  be  decriminalised  across  the  country.  To  prevent  an 
environment  that  forces  journalists  to  self-censor,  courts  should  ensure  expedient  processing  of 
defamation  cases  and  consistent  case  law  on  awarded  damages.  Sarajevo  Canton  is  still  considering  a 
draft  law  which  would  introduce  disproportionate  sanctions  for  the  online  dissemination  of  undefined 
‘fake  news’;  if  adopted,  this  provision  could  be  abused  to  restrict  online  communications  and  to 
intimidate reporters. Any such norms must fully respect freedom of expression standards. (For freedom of 
access to information see Section 2.1.1).  

Implementation of legislation/institutions  

The Communications Regulatory Agency (CRA) still lacks full political and financial independence. The 
procedure  to  appoint  its  management  does  not  guarantee  pluralistic  representation  of  stakeholders  and 
independence  from  the  regulated  sector  and  from  political  influence.  Parliament  is  yet  to  confirm  the 
newly appointed board of the agency. The high number of strategic lawsuits against public participation 
(SLAPP) further fuels self-censorship.  

Public service broadcaster  

The state-level public service broadcaster Radiotelevizija Bosne i Hercegovine (BHRT) does not function 
adequately and is still in serious danger of shutting down, due to years-long deprivation of stable funding 
and lengthy litigation in entity courts over the debts of entity-level public broadcasters. State and entity-
level public broadcasters remain exposed to political influence, in particular through politically controlled 
steering boards. The Federation entity assembly has not appointed a director or filled the steering board 
vacancies for the FTV public broadcaster since 2013. The Republika Srpska entity’s public channel RTRS 
spreads  Russian  disinformation,  including  on  Russia’s  aggression  on  Ukraine  and  on  Bosnia  and 
Herzegovina’s  EU  path.  Banja  Luka-based  provider  M-tel  continued  to  carry  the  signal  of  the  RT 
channel,  despite  the  country  aligning  with  EU  sanctions  prohibiting  the  broadcasting  of  these  Russian 
state-sponsored media. (See also Chapter 10 – Digital transformation and media). 

Economic factors 

No steps were taken to adopt legislation on media ownership transparency (including on the prevention of 
hidden  media  concentration)  or  on  advertising,  or  to  adopt  criteria  for  distributing  subsidies.  The 
advertising practices of publicly companies such as telecom and advertising agencies linked to political 
parties  continue to  harm media  integrity.  Local  broadcasters  that  receive funding  from local  authorities 
remain subject to political pressure and influence. 

Internet  

Online platforms are used to spread hate speech and disinformation, as self-regulation of online media has 
a limited effect. Criminal prosecution is limited to the incitement of religious and ethnic hatred online.  

37 

 
 
Professional organisations and working conditions 

Journalism  remains  a  precarious  profession,  with  low  wages  and  little  job  security.  Labour  rights  are 
barely respected, unionisation is low, and there are no branch collective agreements for media workers. 
Consequently,  many  journalists  receive  a  salary  significantly  lower  than  average  while  also  working 
overtime.  The  situation  is  even  worse  for  women  journalists.  Compliance  with  the  Press  and  Online 
Media Council’s media code remains inconsistent.  

Freedom  of  artistic  expression  is  guaranteed  by  legislation  and  generally  respected.  While  no  formal 
restrictions exist, the environment for reconciliation-related themes is challenging.  

-------------------------------------------------------------------------------------------------------------------------------
-------------------------- 

Freedom of assembly and association  

Laws  on  freedom  of  assembly  are  still  not  harmonised  across  the  country  and  are  not  in  line  with 
European  standards,  in  particular  on  grounds  for  restriction  and  responsibility  of  organisers.  In  the 
reporting period, three cantons (Zenica-Doboj, Una-Sana, Canton 10) adopted legislation aiming to align 
with European standards, following the example of the Brčko District. 

Freedom  of  association  continues  to  face  challenges,  despite  being  legally  guaranteed.  Human  rights 
defenders  continue  to  be  subject  to  threats,  harassment,  verbal  abuse  and  even  physical  attacks.  The 
authorities fail to condemn and properly investigate such attacks. The draft law in the Republika Srpska 
entity targeting civil society as ‘foreign agents’ was withdrawn by the entity government in May 2024. 
Such  a  draft  law  should  not  be  reintroduced,  as  it  would adversely affect  civil society  and  mark  a  step 
backwards.  The  authorities  need  to  promote  an  enabling  environment  for  civil  society  and  ensure 
effective consultation on legislative proposals. 

Labour and trade union rights are covered in Chapter 19 – Social policy and employment.   

Property rights  

No steps were taken to update and interconnect the entity-level cadastral and land registry databases and 
no  solution  was  found  to  pending  repossession  cases.  The  Commission  for  Real  Property  Claims  of 
Displaced Persons and Refugees is inoperative. There is no legislative framework on restitution claims, 
which are handled case by case. The Federation entity needs to amend its legislation in line with several 
ECtHR  cases  on  occupancy  rights  over  military  apartments  which  are  still  pending  implementation 
(Đokić, Mago, Alekšić cases). 

Non-discrimination  

There is no countrywide non-discrimination strategy. The 2009 Law on the prohibition of discrimination 
is still not applied effectively. In 2023, the courts received 2 560 discrimination cases (979 in 2022), with 
1 890  completed  (455  in  2022).  Discrimination  is  still  under-reported,  particularly  in  the  workplace. 
Judicial practice lacks uniformity on burden of proof, is excessively lengthy, and final decisions are not 
enforced. The Ombudsman registered 187 cases of discrimination in 2023, a stable figure compared with 
recent  years,  mostly  for  workplace  and  ethnic  discrimination.  Disputes  over  education  continue,  while 
systemic  solutions  are  not  in  place  to  ensure  inclusive  and  non-discriminatory  education.  The  common 
core  curriculum  is  not  completed  and  is  not  applied  throughout  the  country,  and  the  availability  of 
teaching  of  the  national  groups  of  subjects  (language  and  literature,  history,  geography,  religion,  and 
nature and society) remains limited. No progress was made on eliminating the practice of ‘two schools 
under one roof’, which is in breach of the 2014 and 2021 rulings of the Federation entity Supreme Court. 
Despite  Constitutional  Court  decisions,  the  name  of  the  Bosnian  language  is  still  not  recognised  in 
schools in the Republika Srpska entity, leading to recurrent friction.  

38 

 
 
Legislation on hate crimes is harmonised across the country’s four criminal codes. Entity-level legislation 
criminalises  hate  speech  only  when  causing  national,  racial  and  religious  hatred  and  still  needs  to  be 
aligned with the EU acquis. There are very few indictments and convictions, due to failure to identify acts 
as hate crimes and the high burden of proof to establish intent. In addition, case law is inconsistent. Hate 
speech remains present in official discourse, and there is no monitoring or enforcement of its prohibition 
in online media. The Council of Europe Convention on cybercrime and its additional protocol are only 
partially implemented.  

Gender equality  

Legislation  on  gender  equality  is  still  not  harmonised  across  the  country  or  effectively  enforced.  The 
2023-2027  gender  action  plan  adopted  in 
October  2023  lacks  funding  and  monitoring, 
while  a  new  action  plan  on  women,  peace 
and security has been pending adoption since 
2023. Despite being required by law, gender 
impact  assessments  are  still  not  carried  out. 
While  the  country  has  developed  a  partial 
gender  equality  index,  the  institutional  data 
collection, 
gender-based 
violence,  needs  to  improve  to  identify  and 
target  systematically  the  relevant  gender 
gaps. Cases of gender-based violence leading 
up  to  the  murder  of  women  (femicide) 
continued  to  garner  public  attention  and 
spark protests, exposing systemic institutional shortcomings.   

including 

on 

Women  from  ethnic  minorities,  particularly  Roma12  women,  and  women  in  rural  areas,  face  additional 
obstacles  in  accessing  services,  evading  violence,  assuming  visibility  and  leadership  roles,  and  face 
additional  discrimination.  Improvements  are  particularly  needed  on  issuing  and  enforcing  protective 
measures, on continuous and comprehensive victim support, on legal aid and on safe accommodation in 
order  to  effectively  align  with  the  Victims’  Rights  Directive  and  the  Directive  on  combating  violence 
against women and domestic violence. All levels of government urgently need to transpose the remaining 
obligations  from the  Istanbul  Convention,  including  by  amending their  criminal legislation.  Bosnia and 
Herzegovina still needs to address the August 2020 decision of the UN Committee on the Elimination of 
Discrimination against Women on providing all forms of redress to victims of wartime sexual violence. 
The  country  also  needs  to  accelerate  the  prosecution  of  crimes  of  sexual  violence,  secure  witness 
protection  and  provide  reparation  to  women  victims  of  war  crimes.  Women’s  rights  organisations 
experience resistance against their advocacy and their members receive threats. (See also Chapters 19 and 
28; on women victims of trafficking, see Chapter 24) 

Rights of the child  

The legal framework is largely in line with international standards, although implementation varies across 
different levels of government. No steps have yet been taken by Bosnia and Herzegovina to develop and 
adopt a new action plan on protecting the rights of the child to succeed the one for 2015-2018. In 2023, 
the  Ombudsman  received  231  complaints  on  children’s  rights,  confirming  a  slow  upward  trend.  The 
country needs to accelerate the transition towards community-based care and urgently develop and adopt 
a deinstitutionalisation strategy to this end. Measures are required to prevent family separation, provide 
foster  care  and  alternative solutions, and  support  children  leaving care institutions  at the  age  of 18.  No 

12 In line with the terminology of European institutions the umbrella term  ‘Roma’ is used here to refer to a number 
of different groups, without denying the specificities of these groups. 

39 

 
 
 
measures were taken to address child exploitation and child begging, despite urgency, or to collect precise 
and  consistent  data  on  violence  against  children,  which  is  still  under-reported.  On  child  poverty  in 
general, no measures were taken. Roma children are particularly vulnerable to the worst  forms of child 
labour. Unaccompanied migrant children face specific challenges, such as accessing safe accommodation 
and  asylum  procedures.  As  of  September  2024,  there  are  264  unaccompanied  and  separate  children 
among the migrant population in Bosnia and Herzegovina. The country needs to ensure that all children 
have health insurance. 

Bosnia  and  Herzegovina  needs  to  strengthen  the  implementation  of  child-friendly  justice,  including  for 
children  belonging  to  minorities,  migrant  children  and  children  with  disabilities.  Entity-level  laws  on 
juvenile  justice  have  still  not  been  fully  implemented  or  harmonised  with  each  other.  There  are  no 
separate  units  for  juveniles  during  pre-trial  detention  and  in  police  stations:  this  is  a  serious  breach  of 
international law that urgently needs to be remedied. The use of alternative measures needs to be stepped 
up to ensure detention is used only as a last resort. Only limited reintegration measures are available to 
juveniles  upon  release.  As  of  September  2024,  there  were  28  minors  in  prisons.  In  April  2024,  the 
Ombudsman  published  a  special  report  on  underage  marriages,  concluding  that  impoverished  children, 
especially in the Roma community, are at higher risk.  

Persons with disabilities  

Persons  with  disabilities  are  among  the  most  vulnerable  members  of  society.  While  the  legal  and 
institutional  framework  is  largely  aligned  with  the  UN  Convention  on  the  Rights  of  Persons  with 
Disabilities  (UNCRPD),  the  lack  of  dedicated  funds  prevents  improvements.  A  significant  number  of 
recommendations  and  observations  of  the  UN  Committee  on  the  Rights  of  Persons  with  Disabilities 
received  in  2017  remain  unaddressed.  Persons  with  disabilities  may  still  be  deprived  of  their  legal 
capacity through judicial process, in violation of international conventions; the country needs instead to 
develop  models  for  ‘supported  decision  making’  which  promotes  the  independence  and  autonomy  of 
persons  with  disabilities,  in  line  with  the  UNCRPD.  The  country  needs  to  move  from  a  status-based 
approach  to  one  based  on needs,  with  a  uniform  definition  of  disability  in  line with  the  UNCRPD  and 
with harmonised eligibility criteria, rights and standards of social protection across the country. Persons 
with  disabilities  continue  to  face  hurdles  in  accessing  education,  healthcare,  employment  and  social 
assistance.  The  Council  for  Persons  with  Disabilities  needs  to  be  further  involved  in  all  relevant 
processes.  The  authorities  also  need  to  improve  data  collection,  including  sex-disaggregated  data. 
Children with disabilities remain one of the most marginalised and excluded groups, facing stigma and 
discrimination along  with inadequate  services, especially  in health and  education.  Many  continue  to  be 
placed  in  residential  institutions,  which  is  a  severe  violation  of  their  rights  under  international 
conventions.  Bosnia  and  Herzegovina  needs 
implement  a 
deinstitutionalisation  strategy  to  move  towards  independent  living  and  inclusion  in  the  community  of 
persons  with  disabilities.  Both  entities  and  the  Brčko  District  have  endorsed  roadmaps  for 
deinstitutionalisation, developed in cooperation with UNICEF.  

to  urgently  develop,  adopt  and 

LGBTIQ persons  

Bosnia  and  Herzegovina  needs  to  implement  the  action  plan  on  the  rights  of  lesbian,  gay,  bisexual, 
transgender, intersex and queer (LGBTIQ) persons. The fifth Sarajevo Pride took place peacefully in June 
2024. Hate crimes and hate speech against LGBTIQ persons remain insufficiently prosecuted, despite the 
existing  legal  provisions.  No  steps  were  taken  to  recognise  and  ensure  the  enjoyment  of  same-sex 
couples’ social and economic rights, including the right to a family life. Intersex and transgender persons 
continue to be particularly marginalised. There was insufficient institutional follow-up on the March 2023 
physical  attacks  on  LGBTIQ  activists  in  Banja  Luka.  Harmful  comments  by  high-level  politicians  and 
public  figures  against  the  LGBTIQ  community  contributed  to  these  developments.  In  July  2024,  the 
Republika  Srpska  entity  government  proposed  to  remove  gender  identity  as  a  protected  ground  in  its 

40 

 
 
criminal code; if adopted, this proposal would reduce the existing rights and make the code no longer in 
line with the state-level legislation on anti-discrimination. 

Procedural rights and victims’ rights  

The  procedural  rights  and  victim’s  rights  of  suspects,  accused  persons,  witnesses  and  victims  are 
generally  upheld,  although  access  remains  uneven  across  the  country,  particularly  for  witnesses  and 
victims. The four criminal procedure codes have yet to be further harmonised, and their enforcement is 
inconsistent. Bosnia and Herzegovina needs to ensure the essential procedural right to immediate access 
to  a  lawyer  in  police  detention.  The  Federation  entity  law  protecting  the  right  to  be  tried  within  a 
reasonable time is still pending adoption. Legislation is not in line with the EU acquis on victims’ rights 
and  compensation  to  victims  of  crime,  although  services  intended  to  fulfil  these  rights  are  available. 
Without comprehensive coverage and minimum common standards, the right to legal aid is still upheld 
unevenly, to the detriment of the most vulnerable. The legislative framework needs to be completed in the 
Federation entity and Central Bosnia and Herzegovina-Neretva cantons. A needs assessment would help 
identify  and  address  the  main  gaps  and  ensure  effective  access  to  justice  irrespective  of  one’s  place  of 
residence.  

Protection of minorities 

No progress was made towards adopting a countrywide strategy on persons belonging to minorities, and 
their  participation  in  political  and  public  life  remains  low.  The  National  Minorities  Councils  should 
proactively  develop  practical,  political  and legislative  initiatives. Minority members  still cannot run for 
the Presidency and House of Peoples, in breach of the ECtHR (Sejdić-Finci case law), pending adoption 
of constitutional reforms to ensure the political equality and non-discrimination of all citizens of Bosnia 
and Herzegovina.  

Roma  

The  Roma are the most  vulnerable  and  disadvantaged  minority.  Anti-Roma  stereotypes  and prejudices, 
discrimination  and  anti-gypsyism  still  hinder  their  social  inclusion.  The  country  has  not  allocated 
sufficient funding to implement the action plan on Roma inclusion (EUR 700 000 for 2024, same as for 
2023). There is limited progress in implementing the Poznań Declaration commitments. Discrimination in 
employment  remains  rampant,  and  unemployment  among  the  Roma  is  very  high.  Roma  women  in 
particular  face  multiple  forms  of  discrimination.  Roma  women’s  rights  are  also  violated  in  cases  of 
domestic  violence,  early  marriages,  trafficking  in  human  beings  and  labour  exploitation  of  children. 
Compulsory  education enrolment rates  have  increased,  but the number of  drop-outs remains  very high. 
While education is not segregated, there is no teaching in the Romani language, and the public awareness 
of Roma culture is very limited. In 2023, the Tuzla Canton was the first to introduce the Romani language 
as  an  elective  subject  in  the  school  curriculum.  Around  two  thirds  of  Roma  have  access  to  healthcare; 
children outside education and elderly Roma face the biggest hurdles.  

Refugees and internally displaced persons 

Bosnia  and  Herzegovina  hosts  around  90 000  refugees  and  internally  displaced  persons following  the 
conflict  in  the  1990s,  with  990  families  (3 351  people)  still  living  in  one  of  the  45  collective  centres 
across the country and in  alternative accommodation. The authorities need to address their housing needs 
with sustainable solutions. To complete the process of return and fulfil its obligations to allow closure of 
Annex  VII  of  the  Dayton Peace  Agreements,  Bosnia  and  Herzegovina  should  ensure that  returnees  are 
able  to  enjoy  their  rights  and  should  harmonise  their  access  to  services  and  resources.  Bosnia  and 
Herzegovina  also  needs  to  provide  adequate  humanitarian  assistance  and  protection  (including  shelter, 
food  and  medical  assistance)  and  effective  access  to  the  asylum  procedure  for  asylum  seekers  and 
migrants.  

41 

 
 
2.2.2.  Chapter 24: Justice, freedom and security  

The  EU  has  common  rules  for  border  control,  visas,  external  migration  and  asylum.  Schengen 
cooperation  entails  the  lifting  of  border  controls  inside  the  EU.  There  is  also  cooperation  in  the  fight 
against  organised  crime  and  terrorism,  and  judicial,  police  and  customs  cooperation,    all  with  the 
support of the EU Justice and Home Affairs agencies. 

Fight against organised crime 

Bosnia  and  Herzegovina  has  continued  to  align  its  legal  framework  on  organised  crime  with  the  EU 
acquis, notably with the adoption of legislation on anti-money laundering. 

Institutional set-up and legal alignment 

Police  legislation  needs  to  be  further  aligned  with  European  standards,  as  a  lack  of  harmonisation 
hampers  police  operational  capacities,  accountability  and  integrity  at  all  levels.  Police  oversight 
mechanisms via independent parliamentary boards need to be further strengthened. Standardised selection 
criteria  are  needed  to  minimise  political  interference,  particularly  for  top  police  positions.  The 
professionalism,  integrity  and  accountability  of  law  enforcement  agencies  need  to  be  significantly 
improved.  

The  legal  framework  on  the  fight  against  organised  crime  is  partially  aligned  with  the  EU  acquis.  A 
strategy for 2023-2026 is being implemented through action plans, except in the Republika Srpska entity. 
Bosnia and Herzegovina should establish capacities for asset management at the state level and establish 
or designate an asset recovery office at state level, to improve capacity and effectiveness and to facilitate 
operational cooperation with EU Member States. Extended and third-party confiscations are possible but 
rarely used. The law does not allow confiscation of assets in the absence of previous court conviction. 

The legal framework on trafficking in human beings is yet to be aligned with the EU acquis. A strategy 
and action plan 2024-2027 is pending adoption. The detection and identification of victims of trafficking 
in  human  beings  and  their  compensation  need  to  improve.  Noticeable  improvements  in  coordination, 
thanks  to  a  dedicated  section  in  the  Prosecutor’s  Office  of  Bosnia  and  Herzegovina,  resulted  in  an 
increased  number  of  investigations  and  indictments.  Multi-agency  training  courses  on  working  with 
victims  have  increased.  In  particular,  in  2023,  there  were  seven  investigations  against  eight 
persons,  one  criminal  charge raised  against  two persons,17  convictions against  24  individuals 
for trafficking in human beings. 

Bosnia  and  Herzegovina  needs  to  further  align  its  legislation  on  cybercrime  with  the  EU  acquis. 
Specifically,  it  should  sign  the  second  additional  protocol  to  the  Budapest  Convention  on  Cybercrime. 
The country needs to complete the strategic framework on fighting cybercrime; a strategy is only in place 
in the Republika Srpska entity.  

A new Law on anti-money laundering and countering terrorism financing (AML/CFT) was adopted 
in February 2024, improving provisions on risk assessment and providing for a permanent coordinating 
body,  in  line  with  the  EU  acquis.  Bylaws  still  need  to  be  adopted.  In  February  2024,  the  Council  of 
Ministers adopted a risk assessment for AML/CFT on virtual assets and an action plan for 2024-2027. A 
beneficial ownership register of legal persons, with a central access point for the competent authorities, 
has yet to be established. There is no progress in establishing a central register of bank accounts 
in BiH. 

The  strategy  for  the  control  of  small  arms  and  light  weapons  (SALW)  will  expire  by  end-2024  and 
needs  to  be  replaced.  The  country  is  implementing  the  objectives  of  the  EU  action  plan  on  firearms 
trafficking,  in  line  with  the  regional  roadmap,  and  has  improved  firearms  detection  capacities  and 
destruction. Bosnia and Herzegovina needs to further align its legislation on firearms with the EU acquis. 

Implementation and enforcement capacity 

42 

 
 
The  capacity  to  effectively  dismantle  criminal  organisations  is  seriously  hampered  by  the  lack  of 
harmonised criminal legislation, and exacerbated by the systemic lack of institutional coordination. There 
was  some  progress  on  joint  operations  tackling  serious  and  organised  crimes.  However,  there  is  still 
limited  exchange  of  intelligence.  Bosnia  and  Herzegovina  increased  its  participation  in  EMPACT,  the 
European multidisciplinary platform against criminal threats, with 8 operational actions in 2022 and 12 in 
2023. 

Bosnia and Herzegovina needs to prepare a new serious and organised crime threat assessment (SOCTA) 
in line with Europol methodology and step up the fight against transnational organised crime, in particular 
through increased involvement in EMPACT.  

In seven organised crime cases, plea bargain agreements were concluded with 66 individuals.  

There is no overall policy for timely and systematic financial investigations. While the number of such 
investigations increased compared with 2022, their use remains limited. The HJPC issued guidelines to 
chief  prosecutors  on  mandatory  financial  investigations  in  corruption,  organised  crime  and  money 
laundering cases. These guidelines need to be implemented effectively.  

Graph 14: Bosnia and Herzegovina - Serious and organised crime* 
cases

3264

2593

3000

2000

2689

2520

2924

2288

2394

2179

2956

2342

2500

2254

For  money  laundering 
stand-alone 
as 
a 
investigations 
crime, 
and 
convictions 
declined  slightly  and 
remain insufficient.  

0

77

224

225

166

228

230

208

474

336

204

735

150

2021

1000

Serious
crimes

Serious
crimes

Organised
crimes

Organised
crimes

Organised
crimes

freezing, 
The 
and 
management 
confiscation 
of 
criminal  assets  are 
not  used  effectively. 
The  value  of  assets 
confiscated  pursuant 
to  court  verdicts  in 
2023 
to 
over  EUR 8 million 
(EUR  9  million 
in 
Extended 
2022). 
was 
confiscation 
proposed  in  12  cases,  two  first-instance  court  decisions  were  made,  and  there  were  no  second-instance 
court  decisions  in  2023.  Confiscation  of  property  from  third  parties  was  proposed  in  13  cases,  in  four 
cases a first-instance court decision was made, and there were no second-instance court decisions in 2023.  

Number of individuals / legal entities under Investigation
Individuals / legal entities indicted
Final court decision
Final convictions

*Data  on  serious  crime  cases  stem  from  the  aggregation  of  cases  of  money  laundering,  cybercrime,  production  and  trafficking  of  drugs, 
firearms related offenses, terrorism, trafficking in human beings and smuggling of persons. Corruption cases are showcased in Chapter 23. 

Source: National data collected via the organised
crime and corruption track record (OCCTR) e-platform

Serious
crimes

amounted 

2023

2022

Intelligence-led  policing  should  be  systematically  used.  While  cooperation  among  law  enforcement 
remains  insufficient,  there  was  some  progress,  including  operations  coordinated  via  Europol’s  Secure 
Information Exchange Network Application (SIENA) system. Bosnia and Herzegovina’s use of Europol 
products and services increased after the contact point commenced operation in June 2023.  

Tools  for  practical  cooperation  between  prosecutors’  offices  and  the  police  are  in  place  but  require 
structural improvements to guarantee effective follow-up, prevent procedural delays and introduce good 
practices. Further upgrades are needed in the quality of reports, in the collection, analysis and sharing of 
data, and in the capacity of specialised joint investigation teams.  

The electronic data exchange system for the records of police authorities and prosecution offices needs to 

43 

 
 
be  made  fully  functional.  Forensic  capacity  remains  fragmented.  There  is  no  operational  countrywide 
DNA database, and DNA-profiling capacity is limited. There is limited swift exchange of forensic data 
with  other  countries.  The  creation  of  a  new  automated  fingerprint  information  system  (AFIS)  is  long 
overdue.  

Law  enforcement  agencies  still  lack  sufficient  and  trained  staff  to  fight  trafficking  and  smuggling  of 
human beings, although the capacity of the Prosecutor’s Office increased. Evidentiary proceedings still 
require additional standardisation. The task force for fighting trafficking in human beings ensured solid 
coordination  efforts  between  prosecution  and  law  enforcement  agencies,  with  a  noticeable  increase  in 
convictions.  International  cooperation  improved.  Bosnia  and  Herzegovina  takes  part  in  the  Global 
Alliance against Migrant Smuggling, launched in November 2023. 

The authorities should strengthen their capacity to effectively tackle  cybercrime, including online child 
sexual  abuse.  Through  EMPACT,  law  enforcement  authorities  strengthened  cooperation  in  the  fight 
against sexual abuse of children. Convictions remain very few, with suspended sentences in over half the 
cases.  

On firearms control, seizure of explosives and weapons increased, but the country still needs to establish 
a firearms focal point and align the criminal codes with the UN Firearms Protocol.  

Pronounced convictions in 2023 included 41 prison sentences (35 in 2022, 23 in 2021), 37 fines (22 in 
2022, 32 in 2021) and 124 suspended sentences (160 in 2022, 168 in 2021).  

Since 2021, Bosnia and Herzegovina needs to revise the working arrangement for cooperation with the 
EU Agency for Law Enforcement Training (CEPOL). 

Cooperation in the field of drugs  

Institutional set-up and legal alignment 

Cooperation in the field of drugs needs to be improved.  The strategy on drugs expired in 2023 without 
being implemented and has not been replaced. In December 2023, Sarajevo Canton adopted a 2024-2028 
strategy  on  drugs  and  an  action  plan.  The  legal  framework  is  only  partly  aligned  with  the  EU  acquis, 
notably for minimum rules on drug-related criminal offences and sanctions. By law, the entire quantity of 
drugs seized must be presented as evidence in court proceedings, rather than just a sample, which creates 
risks. 

Bosnia and Herzegovina cooperates with the European Union Drugs Agency (EUDA); it should designate 
a correspondent agent and put in place a working arrangement with EUDA.  

Bosnia and Herzegovina should: (i) establish a national drug observatory; (ii) provide information in line 
with EUDA requirements; (iii) adopt 
legislation  on  new  psychoactive 
substances  and  introduce  an  early 
warning  system;  and  (iv)  establish  a 
focal  point  for  drug  issues  for  the 
entire country.  

Graph 15: Bosnia and Herzegovina - Cases related to 
production and trafficking of drugs

2089

2160

2380

2163

2277

1951

1796

2344

1976

1854

2114

2500

1884

2000

Implementation  and  enforcement 
capacity  

Bosnia  and  Herzegovina  remains 
both  a  transit  country  and  final 
destination  for  drugs.  The  list  of 
criminalised psychoactive substances 
has not been updated since 2011.  

1500

1000

500

0

Number of
individuals /
legal entities
under
Investigation
44 

Individuals /
legal entities
indicted
2021

Final court
decision

Final convictions

2022

2023

Source: National data collected via the organised
crime and corruption track record (OCCTR) e-platform

 
 
Fight against terrorism  

Bosnia and Herzegovina is progressing towards its objectives in the fight against terrorism. 

Institutional set-up and legal alignment  

Anti-terrorism  legislation  is  not  yet  completely  aligned  with  the  EU  acquis  and  international  law. 
Criminal  legislation  needs  to  be  amended  to  align  the  list  of  criminal  offences  and  ensure  stricter 
sanctions for  terrorism  offences.  Laws  on the  protection  of  critical infrastructure  (in  place  so  far  in  the 
Republika Srpska entity only) should be developed and adopted at all levels of government. Legislation 
on explosives precursors still needs to be aligned with EU acquis. 

A  strategy  against  terrorism and violent extremism is  in  place since  November  2022,  with action  plans 
adopted at all levels in 2023 and a coordination body to monitor implementation. Implementation of the 
bilateral  arrangement  with  the  EU  under  the  Joint  Action  Plan  on  counter  terrorism  for  the  Western 
Balkans advanced, but many actions are yet to be implemented.  

Implementation and enforcement capacity  

Coordination,  cooperation  and  intelligence  sharing  among  security  agencies  need  to  become  more 
structured and efficient. 

Around 160 citizens of Bosnia and Herzegovina, including women and children, are estimated to remain 
in Syria and Iraq. Three foreign terrorist fighters returned to Bosnia and Herzegovina between 2023 and 
2024 and were arrested upon arrival. 

In 2023, six investigations were initiated for terrorism against seven individuals. In March 2024, the state-
level court sentenced one person to three years of imprisonment for organising a terrorist group. No final 
conviction was delivered. In the first semester of 2024 one person was indicted for planning a terrorist 
attack. 

Security agencies and local authorities need to develop a coordinated approach to prepare the release from 
prison of terrorism offenders who have served their sentences. Very limited assistance is available to help 
them disengage from violent extremism. 

Bosnia and Herzegovina needs to further develop the capacity to investigate and prosecute the financing 
of  terrorism  and  to  counter  terrorist  content  online.  The  country  should improve  collaboration  with  the 
internet referral unit at Europol to deal with terrorist content online, and adopt a more proactive approach 
to exchange information via the Europol contact point. 

Civil  society  and  the  institutions  responsible  for  labour,  social  welfare,  education,  young  people  and 
health at all levels of government need to be more effectively included in preventive efforts.  

Judicial cooperation in civil and criminal matters  

The 

for  mutual 

Judicial  cooperation  in  civil  and 
to  be 
criminal  matters  needs 
legislative 
improved. 
framework 
legal 
assistance 
in  civil  and  criminal 
matters  is  in  place  but  not  always 
applied  effectively.  Bosnia  and 
Herzegovina still needs to accede to 
certain instruments under the Hague 
conference  on  private  international 
law.  The  number  of  processed 

Graph 16: Bosnia and Herzegovina - Requests for 
mutual assistance in civil and criminal matters

5000

4000

3000

2000

1000

0

1700

1230

793

n/a

n/a

n/a

n/a

n/a

n/a

3511

3920

3435

1860

1651

2108

1812

1824

1611

2021

45 

2022

Civil

2023

2021

2022

2023

Criminal

Incoming requests

Outgoing requests

n/a: not available

Source: Ministry of Justice 

 
 
requests for mutual assistance in civil matters increased, while in criminal matters the numbers remained 
stable; the processing time is adequate. 

In October 2024, the Presidency authorised signing the agreement on judicial cooperation with Eurojust. 
As  a  prerequisite  for  judicial  cooperation  with  Eurojust,  Bosnia  and  Herzegovina  needs  to  align  its 
legislation on data protection with the EU acquis. The country participates in a Eurojust-led project but 
was  not  part  of  any  joint  investigation  teams  under  the  project.  The  Prosecutor’s  Office  of  Bosnia  and 
Herzegovina signed a working arrangement with the European Public Prosecutor’s Office in November 
2023. 

Legal and irregular migration 

Improvements need to continue in the management of legal and irregular migration. 

Institutional set-up and legal alignment 

The legal framework, including the Law on foreigners, is broadly aligned with the EU acquis. There is no 
budget to implement the strategy and action plan on migration and asylum 2021-2025.  

Implementation and enforcement capacity 

27429

15740

34409

intention 

40000
35000
30000
25000
20000
15000
10000
5000
0

Graph 17: Bosnia and Herzegovina - Number of irregular 
movements

Bosnia and Herzegovina did not advance in taking over responsibility for the management of temporary 
reception centres. The competent agencies remain significantly understaffed and only limited funding is 
to  manage  migration, 
available 
effectiveness. 
impacts 
which 
Coordination 
sharing  of 
and 
responsibility  in  hosting  asylum 
seekers  and  migrants  among  all 
levels  of  government 
remain 
insufficient.  In  2023,  more  people 
entered the country irregularly than 
in  2022;  27 915  people  expressed 
the 
to  seek  asylum 
(25 705 in 2022). A total of 64 115 
migrants were registered as staying 
in  the  four  EU-funded  temporary 
reception  centres  in  the  Una-Sana 
and  Sarajevo  cantons  throughout 
2023,  with  an  additional  13 000 
estimated  outside  centres.  The 
Service  for  Foreigners’  Affairs  of  the  Ministry  of  Security  does  not  register  all  migrants  staying in  the 
reception centres. In 2023, Bosnia and Herzegovina had capacity to host over 4 500 people at any time, 
which is sufficient; The highest daily occupancy rate was 3 043 people. The multi-purpose reception and 
identification centre in Lipa, near Bihać, is operational, but the detention unit within the centre is not, as 
the legal framework is not in place yet. 

5382 4343 2341

Source: Ministry of Security

3987 2161

n
a
t
s
i
n
a
h
g
f
A

n
a
t
s
i
n
a
h
g
f
A

n
a
t
s
i
n
a
h
g
f
A

h
s
e
d
a
g
n
a
B

h
s
e
d
a
g
n
a
B

o
c
c
o
r
o
M

n
a
t
s
i
k
a
P

d
n
u
r
u
B

14442

11038

2486

7135

2021

2022

2023

a
i
r
y
S

a
t
o
T

a
t
o
T

a
t
o
T

l

l

l

i

l

l

In  2023,  a  total  of  2 013  Ukrainian  refugees  resided  in  Bosnia  and  Herzegovina.  They  are  granted 
temporary residence on humanitarian grounds for 6 months, which can be extended.  

Bosnia  and  Herzegovina  needs  to  improve  the  legal  framework  and  implementation  procedures  for 
voluntary  and  forced  return,  which  remain  mostly  based  on  donors’  assistance.  In  2023,  Bosnia  and 
Herzegovina  carried  out  123  voluntary  returns  and  43  forced  returns.  The  absence  of  diplomatic 
representation of countries of origin, and of cooperation to ensure identity documents for non-voluntary 
returns, continue to pose a challenge.  

46 

 
 
Implementation  of  readmission  agreements  is  overall  satisfactory.  Accelerated  readmission  procedures 
with  neighbouring  countries  remain  suspended,  except  with  Croatia.  In  2023,  Bosnia  and  Herzegovina 
accepted  2 458  migrants  returned  from  Croatia  under  the  bilateral readmission agreement.  Cooperation 
with  neighbouring  countries  is  necessary  to  ensure  efficient management  of  the external  borders,  while 
respecting fundamental rights and international obligations.  

Asylum  

Bosnia and Herzegovina needs to guarantee access to quality and effective asylum procedures. 

Institutional set-up and legal alignment 

The  Law  on  asylum  is  broadly  aligned  with  the  EU  acquis  and  good  practices.  Cooperation  with  the 
European  Union  Asylum  Agency  (EUAA)  is  satisfactory,  but  a  new  roadmap  needs  to  be  signed.  The 
Asylum Sector of the Ministry of Security remains understaffed.  

Implementation and enforcement capacity 

The number of asylum applications in 2023 
remained  low,  compared  to  the  number  of 
people who expressed the intention to apply 
for asylum.  

Bosnia  and  Herzegovina  should  make  its 
compatible  with 
systems 
fingerprint 
EURODAC 
cases  of 
standards.  No 
refoulement  were  reported  in  the  reporting 
period.  

180
160
140
120
100
80
60
40
20
0

Further alignment is needed, particularly to 
ensure 
of 
applications for international protection and 
systematic access to procedural guarantees.  

standardised 

examination 

Graph 18: Bosnia and Herzegovina - Asylum 
applications 

167

149

146

33

e
y
i
k
r
ü
T

16

n
a
t
s
i
n
a
h
g
f
A

29

29

29

n
a
t
s
i
k
a
P

l

a
t
o
T

e
y
i
k
r
ü
T

i

e
n
a
r
k
U

15

a
i
s
s
u
R

46

25

16

l

a
t
o
T

a
i
s
s
u
R

e
y
i
k
r
ü
T

l

a
t
o
T

n
a
t
s
i
n
a
h
g
f
A

Further  alignment 
is  also  needed  on 
strengthening  the  asylum  and  reception 
systems in line with the Common European Asylum System and European standards.  

2021

2022

2023

Source: Ministry of Security

The  processing  time  of  asylum  requests  improved  but  remains  long.  Out  of  146  applications  lodged  in 
2023, 4 people received a refugee status. The budget for integration of refugees is sufficient. The Delijaš 
asylum centre has good reception conditions but is underutilised, with an average of 10 occupants for a 
capacity of 154 beds.  

Visa policy  

Visa  policy  still  needs  to  be  aligned  with  the  EU  visa  policy.  Pending  full  alignment,  Bosnia  and 
Herzegovina should apply additional security measures, such as increasing the capacity of border guards 
and engaging in dialogue with third countries and other relevant parties (e.g. airlines) to increase situation 
awareness, information exchange and prevention, including the legal measures on exit, control of name 
change and criminalisation of assistance to irregular migration. Visa application and issuing procedures 
are harmonised with the EU acquis. The country should introduce biometric visa applications and allow 
commercial  intermediaries.  Bosnia  and  Herzegovina  still  does  not  have  a  fully  functional  central  visa 
information system.  

Bosnia and Herzegovina needs to fully align with EU visa policy by terminating visa-free regimes with 
Azerbaijan, Kuwait,  Saudi  Arabia  (seasonal),  Qatar,  Türkiye,  Russia  and  China.  The  country  removed 
visa-free  agreements  with  Bahrein  in  September  2023  and  Oman  in  January  2024.  Seasonal  visa 

47 

 
 
exemption measures are not in line with the EU acquis.  

According to Eurostat, in 2023, 1 605 asylum applicants from Bosnia and Herzegovina were registered in 
the EU27 (-28% compared to 2 220 in 2022). 

Travel documents policy still requires additional control mechanisms on procurement and manufacturing 
of  biometric  travel  documents.  There  is  full  alignment  with  EU  standards  on  security  features  and  on 
procedures for applying for and issuing travel documents, notably biometric passports. 

Schengen and external borders  

Institutional set-up and legal alignment 

The  legislation  on  the  management  of  external  borders  is  not  aligned  with  the  EU  acquis.  Bosnia  and 
Herzegovina needs to adopt a new law on border control, in line with the EU acquis, and a new strategy 
and action plan for integrated border management.  

Negotiations for a status agreement, which would allow Frontex to deploy border management teams of 
the European Border and Coast Guard standing corps with executive powers to Bosnia and Herzegovina, 
started  in  May  and  were  finalised  in  September  2024,  while  negotiations  for  an  updated  working 
arrangement with Frontex have not yet started.  

Bosnia  and  Herzegovina  still  needs  to  establish  an  advanced  passenger  information  /  passenger  name 
record (API/PNR) system. The Joint Risk Analysis Centre improved its business processes, establishing 
clearer structure, business rules and procedures in the Border Police at all operational levels.  The centre 
continued  its  progress  on  police  data  exchange  with  neighbouring  countries  and  EU  Member  States. 
Bosnia  and  Herzegovina  needs  to  establish  a  national  coordination  centre  in  line  with  the  Frontex 
Regulation. 

Implementation and enforcement capacity 

The  Border  Police  is  understaffed,  with  a  quarter  of  vacancies  not  filled.  Inter-agency  cooperation  on 
fighting irregular migration continued, with support for border surveillance operations. Joint preventive 
operations were carried out against human trafficking and smuggling in temporary reception centres, with 
increased detection of smuggling cases. Police cooperation with neighbouring countries continued, with 
joint operations taking place. 

Border  infrastructure  and  equipment  are  yet  to  be  improved.  The  new  joint  border  crossings  with 
Montenegro  simplified  border  checks.  Bosnia  and  Herzegovina  needs  to  close  illegal  border  crossings, 
particularly on the border with Montenegro. The Border Police has adequate access to international police 
databases  at  border  crossings,  including  the  INTERPOL  database  on  stolen  and  lost  travel  documents. 
The  central  investigation  office  within  the  Border  Police  has  increased  investigations  on  human 
smuggling  but  lacks  staff  to  support  their  investigative  capacities.  The  Border  Police  has  an  anti-
corruption plan and officers attend regular training.  

Euro counterfeiting (criminal law aspect) 

The relevant legislation is not in line with the EU acquis on the suppression of counterfeit currency. The 
criminal codes need to be further aligned with the EU Directive on the protection of the euro and other 
currencies  against  counterfeiting.  Law  enforcement  and  judicial  authorities  are  in  place  to  deal  with 
counterfeit money.  

48 

 
 
2.3. ECONOMIC CRITERIA  

2.3.1 The existence of a functioning market economy 

Economic governance 

Economic  governance  remained  negatively  affected  by  resurfacing  political  tensions.  Policy 
formulation and implementation are seriously hampered by highly politicised decision-making processes, 
institutional  fragmentation  and  insufficient  cooperation  between  key  stakeholders,  leading  to  lengthy 
delays  in  overdue  structural  reforms.  For  example,  recurring  delays  in  approving  the  state-level  budget 
and in appointing the vacant judges to the Constitutional Court had a significant negative impact on the 
functioning  of  state-level  institutions,  such  as  the  judiciary.  The  2024-2026  Economic  Reform 
Programme (ERP)  was again  submitted  with  a significant  delay  and  its  quality  suffered  from a  lack  of 
internal  consistency  and  cooperation  between  the  various  stakeholders.  Fiscal  policy  focused  on  short-
term  issues  while  neglecting  longer-term  challenges  such  as  raising  the  country’s  growth  potential 
through investment. 

Implementation  of 
the  policy  guidance 
jointly  adopted  at  the  May  2023  Economic 
and  Financial  Dialogue  has  been  partial. 
Some  effort  has  been  made  to  cushion  the 
impact  of  external  shocks  and  increase  public 
investment.  The  analytical  capacities  of 
governmental  institutions  remained  limited, 
including in the field of statistics. After a delay 

49 

Table 2.1:202120222023Bosnia and Herzegovina - Key economic figuresGDP per capita (% of EU-27 in PPS)1)32343535real GDP growth 2)2.47.33.71.9Activity rate of the population aged 15-64 (%), total55.259.159.159.8      female43.346.746.347.0      male67.071.471.872.3Unemployment rate of the population aged 15-64 (%), total21.117.515.413.2      female24.222.219.916.7      male19.114.512.710.9Employment of total population (annual growth %)*2.50.91.42.9Nominal wages (annual growth %)2.34.411.713.0Consumer price index (annual growth %)0.02.014.06.1Exchange rate against EUR1.961.961.961.96Current account balance (% of GDP)-3.9-1.8-4.3-2.7Net foreign direct investment, FDI (% of GDP)2.12.73.03.3General government balance (% of GDP)0.5-0.3-0.4-1.2General government debt (% of GDP)36.633.929.326.92015-20 averageTable 2.1:202120222023Bosnia and Herzegovina - Key economic figuresGDP per capita (% of EU-27 in PPS)1)32343535real GDP growth 2)2.47.33.81.6Activity rate of the population aged 15-64 (%), total55.259.159.159.8      female43.346.746.347.0      male67.071.471.872.3Unemployment rate of the population aged 15-64 (%), total21.117.515.413.2      female24.222.219.916.7      male19.114.512.710.9Employment of total population (annual growth %)*2.50.91.42.9Nominal wages (annual growth %)2.34.411.713.0Consumer price index (annual growth %)0.02.014.06.1Exchange rate against EUR1.961.961.961.96Current account balance (% of GDP)-3.9-1.8-4.3-2.8Net foreign direct investment, FDI (% of GDP)2.12.73.03.3General government balance (% of GDP)0.5-0.3-0.4-1.2General government debt (% of GDP)36.633.929.326.9Notes: 1) Eurostat2) Expenditure side GDPSource: Eurostat, national sources2015-20 average* There is no comparable time series for the age group 15-64-6-4-20246810201820192020202120222023Graph 2.1: Bosnia and Herzegovina -Real GDP growth and contributionsPriv. cons.Gov. cons.GFCFStocksNet exportsReal GDP growthSource: WiiW% y-o-y 
 
 
of two and a half years, a new central bank governing board has been appointed. Partial progress has been 
achieved  on  simplifying  business  registration,  licencing  and  permitting  procedures,  but  there  was  no 
progress on harmonising them countrywide, resulting in increasing economic fragmentation. 

Macroeconomic stability 

a 

2023, 

reflecting 

After  a  strong  rebound  from  the  pandemic-
induced  recession,  economic  activity  slowed 
in 
deteriorating 
international environment and the impact of 
high  inflation.  Annual  output  growth  slowed 
from  3.8%  in  2022  to  1.9%  in  2023.  This 
mostly  reflects  weaker  than  expected  external 
demand,  while  domestic  demand  performed 
better  than  expected,  supported  by  relatively 
low  interest  rates  and  an  expansionary  fiscal 
policy.  In  2023  and  the  first  half  of  2024,  the 
main  driver  of  output  growth  was  private 
consumption,  increasing  by  1.6%  year  on  year 
and 2.2% respectively, contributing 1.4 and 1.1 percentage points to overall output growth. Government 
consumption increased by 1.4% and 2.1% respectively. In the first half of 2024 real GDP growth picked 
up slightly to 2.4% year on year, from 2.2% in the same period a year before, mainly driven by domestic 
demand. 

A  slow  pace  of  catch-up  with  EU  living 
standards  points  to  significant  structural 
weaknesses.  GDP  growth  averaged  3%  over 
the  last  decade.  This  is  slow  considering  the 
country’s relatively low GDP per capita, which 
stood  at  35%  of  the  EU-27  average  in  2023, 
only  4 percentage  points  higher  than  in  2017 
than  most  other 
and  significantly 
lower 
countries.  The  main 
Western  Balkan 
the  slow  speed  of 
is 
underlying  reason 
structural reforms to strengthen the functioning 
of 
the 
labour  and  product  markets  and 
country’s institutional and legal framework. 

The current account deficit shrunk to 2.7% 
of  GDP  in  2023,  benefiting  from  weaker  import  growth  and  lower  import  prices.  Trade  dynamics 
were  weak  in  2023,  but  lower  export  revenues  were  more  than  compensated  by  falling  import  values, 
higher income from service exports (especially tourism) and higher remittances. The main drivers were 
lower exports of base metals and mineral products amid lower foreign demand from Germany, Italy and 
Croatia, which together account for about 40% of total exports. Net inflows of foreign direct investments 
(FDI) stood at 3.3% of GDP in 2023, largely unchanged from previous years. The main FDI inflows were 
in the electricity, financial and petroleum and coal sectors (about 10% of total inflows each). In the first 
half of 2024, the 4-quarter moving-average current  account deficit stood at  3.6% of GDP,  compared to 
3.8% a year before, reflecting muted export growth but resilient imports.  

Annual headline inflation continued to decelerate, from 14.0% in 2022 to 6.1% in 2023.  In the first 
seven  months  of  2024,  annual  inflation  fell  further  to  1.9%  on  average.  The  main  drivers  were  still 
relatively high price rises for food and non-alcoholic beverages and for household equipment. Transport 
prices,  a  key  inflation  driver  during  2022,  continued  to  decline.  High  nominal  wage  growth  of  13%  in 

50 

-8-404-20-1001020192020202120222023Graph 2.2: Bosnia and Herzegovina -Current account selected components and FDIPersonal transfers (= Workers' remittances)Goods and services trade balanceCurrent account balance (rhs)Net FDI (rhs)% of GDPSource:Central Bank of Bosnia and Herzegovina and Agency for statistics 
 
2023 and 9.8% in the first seven months of 2024 risk to keep upward domestic price pressures in the near 
future. The absence of a published indicator of core inflation impedes the analysis of inflation dynamics.  

The fiscal outcome in 2023 benefited from stronger than anticipated revenue growth, but current 
spending  has  been  adjusted  accordingly,  weakening  the  fiscal  position.  The  main  sources  for  the 
better  than  expected  revenue  performance  were:  (i)  indirect  taxes  boosted  by  resilient  household 
spending;  (ii)  social  contributions  from  higher  wages  and  increased  employment;  and  (iii)  profit  taxes 
partly  due  to  significant  energy  price-driven 
profits  in  the  largely  state-owned  electricity 
production sector. On the spending side, social 
transfers  and  collective  consumption  rose 
strongly.  Public  investment  remained  at  3.5% 
of  GDP.  The  general  government  debt  ratio 
declined  from  29.3%  at  end-2022  to  26.9%  at 
end-2023, benefiting from strong nominal GDP 
growth.  However,  permanent 
in 
current spending have weakened the country’s 
fiscal  position.  Debt  rollover  needs  remain 
substantial  in  the  light  of  tighter  financing 
conditions. 

increases 

Overall,  Bosnia  and  Herzegovina’s  macroeconomic  policy  mix  does  not  adequately  address  the 
country’s  main  challenges  such  as  accelerating  the  economic  convergence  process.  As  Bosnia  and 
Herzegovina’s  currency  board  regime  limits  the  room  for  monetary  policy,  fiscal  policy  is  one  of  the 
country’s key macroeconomic policy tools to manage aggregate demand. However, this policy tool is not 
used  sufficiently.  Instead,  available  fiscal  space  tends  to  be  used  for  consumption  purposes,  and 
benefitting  from  temporary,  post-COVID  strong  revenue  growth  the  authorities  approved  significant 
permanent  expenditure  increases,  impeding  the  country’s  fiscal  liquidity  position.  Furthermore,  the 
effectiveness  of  fiscal  policy  in  strengthening  the  country’s  growth  potential  is  severely  limited  by 
insufficient  cooperation  among  the  various  fiscal  policy  stakeholders  and  by  the  absence  of  an 
independent  and  competent  fiscal  council.  The  lack  of  timely  fiscal  data  consolidated  at  country  level 
constrains the assessment of the country’s underlying budgetary position. 

Functioning of product markets 

Business environment 

The business environment continues to suffer from a weak rule of law, political uncertainty and the 
country’s  economic  and  institutional  fragmentation.  Property  rights  are  largely  well  established, 
although implementing them remains cumbersome in some areas, such as real estate registration. In other 
areas, ownership by foreign entities is limited. Enforcing contracts remains difficult, in particular to settle 
commercial disputes, and there is a substantial backlog in court cases. Political disputes over the powers 
of the Constitutional Court of Bosnia and Herzegovina and delays in nominating court judges undermine 
confidence in the legal system. Doing business across the entire country is still impeded by technical and 
administrative obstacles, such as the need to obtain the same licences or permits in each entity or local 
government  area  and  to  pay  a  range  of  different  local  taxes  and  fees.  This  increases  the  costs  of 
establishing a company, prevents competition and deters investors, hindering the functioning of a single 
economic space. As the pace of alignment with the EU acquis differs between the entities, the country’s 
economic  and  legal  fragmentation  has  actually  further  deteriorated.  Economic  and  social  dialogue 
between the authorities and social partners is underdeveloped, which has a negative impact on the quality 
of  adopted  legislation.  Overall,  only  very  limited  progress  has  been  achieved  to  improve  the  business 
environment.  

51 

 
 
The informal economy continues to account for a significant share of economic activity. Although 
increased labour market inspections have helped encourage employment registration, the informal sector 
is  estimated  to  still  account  for  up  to  one  third  of  GDP.  Undeclared  work  provides  substantial 
(unregistered) employment and income but distorts competition and erodes the tax base. This means that 
rates  for  taxes  and  social  security  contributions  have  to  be  higher  than  is  otherwise  necessary.  It  also 
results  in  lower  pension  benefits,  increases  the  poverty  risk  for  older  people  and  adds  to  an  already 
significant fiscal burden on registered labour. This in turn impedes formal employment and limits Bosnia 
and  Herzegovina’s  international  competitiveness.  Corruption  is  still  prevalent  in  many  areas.  In  this 
respect, the adoption of a state-level law on preventing conflict of interest is a step in the right direction. 
However,  the  track  record  of  convictions  for  high-level  corruption  remains  limited  and  the  legal  and 
institutional anti-corruption framework has overall deteriorated during recent years. 

State influence on product markets 

State  influence  in  the  economy  is  still  significant  and  progress  in  reducing  the  State’s  role  has 
remained  limited.  Although  most  of  the  temporary  measures  related  to  the  energy  price  shock  have 
expired,  the  impact  of  the  public  sector  on  factor  allocation  remained  high,  in  particular  in  the  labour 
market, due to the State’s significant role as an employer in public administration, health and education 
and in publicly owned enterprises. Overall, these areas account for about one third of total employment. 
Some  publicly  owned  enterprises  have  a  special  legal  status  and  different  treatment  when  it  comes  to 
paying social contributions, accumulating payment arrears (accounting for some 4% of GDP according to 
IMF  estimates)  or  paying  wage  premiums.  This  puts  them  at  an  advantage  compared  with  private 
companies. However, support continues for poorly performing publicly owned enterprises  and oversized 
public administration. The efficiency and quality of public services and access to them is limited by poor 
human resource management and accountability. Public procurement procedures continue to be complex 
and  administrative  capacity  and  competition  remain  low.  This  facilitates  corruption  and  leads  to  a 
preference for domestic suppliers, which is incompatible with the EU acquis (see also Chapter 5 – public 
procurement). There is still a wide range of regulated prices. The official level of State aid is relatively 
low  (at  1.1%  of  GDP  in  2022.  Data  for  2023  is  not  available  yet.),  although  significant  indirect  state 
support continues to undermine the level playing field. State aid control is still hindered by only partial 
legal alignment with EU standards and the lack of consistent enforcement of State aid rules throughout 
the country. The State Aid Council’s powers and capacities remain limited, leaving room for distortions 
of competition. 

Privatisation and restructuring 

Publicly owned companies still account for a significant proportion of the economy, but no progress 
was achieved on their restructuring and privatisation. There are over 550 publicly owned enterprises 
at  entity  and  municipal  level,  employing  around  10%  of  the  total  workforce,  with  assets  worth  an 
equivalent of 100% of GDP. The officially recorded total debts of these companies stand at 26% of GDP 
(IMF, 2019). Many public enterprises are in poor financial shape and require both explicit and implicit 
budgetary support, placing a heavy burden on public finances and thus on taxpayers. The monitoring and 
managing  of  fiscal  risks  is  still  insufficient.  The  economic  governance  of  publicly  owned  companies 
suffers  as  a  result  of  often  highly  politicised  board  appointments.  Initial  steps  to  address  some  of  the 
payment  arrears  and  –  in  the  Republika  Srpska  entity  –  to  improve  the  governance  and  oversight  of 
publicly owned enterprises have been taken, but the impact of these steps remains very limited. 

Functioning of the financial market 

Financial  sector  stability  has  been  maintained,  but  important  challenges  remain.  Despite  some 
progress  in  addressing  systemic  risks,  the  financial  sector’s  safety  net  does  not  meet  international 
standards, for example, missing a country-wide stability fund. The alignment with the EU’s Anti-Money 
Laundering Directive (AML/CFT) has remained partial. Furthermore, certain local banks risk to become 
subject  to  US  sanctions  or  crypto-asset  lawsuits,  which  could  have  a  negative  impact  on  the  country’s 
52 

 
 
financial  sector as a  whole.  The complexity of the  institutional  set-up  hinders  adequate financial  sector 
supervision. For example, the Standing Committee for Financial Stability, which plays a pivotal role in 
the  sector’s  supervision,  has  not  met  since  March  2022.  Economically,  the  sector’s  profitability  and 
liquidity has been high, benefiting from a strong increase in deposits (7.2% and 7.8% in 2023 and in the 
first  seven  months  of  2024)  and  high  interest  rate  differentials.  Nominal  credit  growth  accelerated, 
increasing  by  5.0%  and  8.5%  in  2023  and  the  first  seven  months  of  2024,  respectively.  However,  the 
credit financing maturity structure has deteriorated. Non-performing loan ratios as an indicator for credit 
risks continued to decline, reaching 3.5% in Q2-2024. However, credit risks appear markedly higher in 
some  smaller,  domestically  owned  banks.  The  size  of  the  non-bank  financing  sector  and  of  the  capital 
markets  remained  small,  with  a  stock  market  capitalisation  of  about  23%  of  GDP  in  2023.  For  many 
micro and small companies, gaining access to credit remained difficult. 

Functioning of the labour market 

The labour market remained resilient, but high unemployment rates, low labour participation and 
labour  shortages  point  to  persistent  structural  issues.  Registered  annual  employment  growth 
decelerated  from  2.3%  in  2022  to  1.4%  in 
2023 and 0.4% in the first half of 2024, while 
the  unemployment  rate  (according  to  the 
Labour  Force  Survey)  dropped  from  15.4% 
in  2022  to  13.3%  in  Q2-2024.  However, 
youth unemployment (age group 15-24) rose 
slightly from 29.1% in Q2-2023 to 30.4% in 
Q2-2024.  A  relatively  high  inactivity  rate 
among  women  contributes  to  an  overall 
rather  low  activity  rate.  The  amount  of 
informal  employment  remains  high.  Labour 
out-migration  remained  significant,  leading 
to  labour  supply  shortages  and  a  negative  impact  on  the  country’s  medium-term  growth  potential.  In 
response  to  those  shortages,  the  authorities  have  further  increased  available  quotas  for  foreign 
employment permits. The share of long-term unemployment remained particularly high, at about 75% of 
unemployed  people  looking  for  a  job  for  more  than  1  year.  Key  driving  factors  are  skills  mismatches, 
insufficient job opportunities and a high tax wedge (i.e. high taxation of earnings from labour). Officially 
recorded wages rose by some 6% in real terms in 2023 and of 7.6% the first seven months of 2024, which 
is above productivity improvements. Strong minimum wage increases could increase inflation and have a 
negative impact on the country’s external competitiveness. Overall, governmental policies to address the 
country’s labour market challenges have been insufficient. 

2.3.2 The capacity to cope with competitive pressure and market forces within the Union 

Education and innovation 

Education  outcomes  are  not  well-matched  with  market  needs.  Despite  sizeable  public  spending  on 
education (some 5% of GDP, when also including foreign donations), the education system continues to 
fail to provide the country’s labour force with the skills and knowledge necessary for smooth integration 
into  the  labour  market.  These  are  important  factors  for  a  particularly  high  youth  unemployment  rate 
according to the Labour Force Survey (30.4% in Q2-2024), twice the overall unemployment rate and one 
of the highest in the region. Insufficient coordination among the numerous stakeholders leads to a lack of 
common standards for various levels of education and to differences in the quality of teachers’ training 
and  performance  evaluation.  Participation  in  early  childhood  education  and  care  is  significantly  lower 
than in the EU and elsewhere in the region. The illiteracy rate remains around 3%,  affecting women in 
particular.  The  country  has  stopped  participating  in  the  PISA  (Programme  for  International  Student 
Assessment) evaluation, abandoning an important source of information for improving education policy. 
53 

203040506070010203040201820192020202120222023Graph 2.4: Bosnia and Herzegovina -Labour market trends (15-64 age group)Unemployment rate (lhs)Participation rate (rhs)Employment rate (rhs)Source: BiH Agency of Statistics 
 
Upskilling  strategies  to  increase  the  workforce’s  skill  levels  are  not  sufficiently  developed  and  lack 
sufficient providers. Investment in research and development has remained insufficient, while the lack of 
coordination among the various stakeholders results in overall poor spending efficiency. However, local 
administrations have taken some action to modernise education curricula and increase available funds. No 
progress has been achieved in improving the functioning of science and technology parks.  

Physical capital and quality of infrastructure 

Bosnia and Herzegovina’s capital endowment remains inadequate. Continued political stalemates and 
uncertainties, as well as insufficient work on prioritising the most important projects, continued to have a 
negative  impact  on  investment,  impeding  the  country  from  achieving  a  higher  growth  trajectory.  The 
growth  of  gross  fixed  capital  formation  slowed  to  1.2%  in  2023,  with  the  investment’s  share  in  GDP 
dropping  slightly  to  26.6%  in  2023.  Net  foreign  direct  investment  stood  at  3.3%  of  GDP  in  2023, 
significantly lower than in other countries in the region. Due to Bosnia and Herzegovina’s high energy 
intensity and heavy reliance on lignite coal, the level of CO2 emissions is a major concern, in particular in 
the light of the EU’s upcoming carbon border adjustment mechanism (CBAM), which is likely to have a 
significant impact on the country’s exports. Despite some positive developments on entity level, a reliable 
and  secure  energy  supply  is  still  impeded  by  the  lack  of  a  single  regulatory  framework  to  attract 
investment  in  a  low-carbon  energy  sector.  The  country  has  started  to  prepare  a  National  Energy  and 
Climate  Plan  (NECP),  which  however  is  not  adopted  yet.  Environmental  standards  have  remained  low 
and are often neglected. This is detrimental to the health (and thus productivity) of the labour force and is 
an  additional  factor  driving  brain  drain.  There  has  been  some  (largely  foreign-financed)  progress  in 
improving road infrastructure and some local initiatives to attract and promote investment. 

Digitalisation  of  the  economy  is  a  key  challenge  but  is  hampered  by  fragmented  decision-making 
and a lack of funding. Issues include the continuing lack of countrywide harmonisation of e-signatures 
and  the  necessary  coordination,  cooperation  and  data  exchange  between  different  administrative 
authorities.  A  new  law  on  electronic  identification  and  trust  services  for  electronic  transactions  with  a 
single supervisory body for the whole country in line with the EU acquis is still lacking. 

Sectoral and enterprise structure 

Bosnia  and  Herzegovina’s  production  structure  continued  to  shift  gradually  from  agriculture, 
industry and public administration towards tourism, trade and IT services. Between 2018 and 2023, 
the share of value added in trade, transport, tourism and IT rose from 23.7% to 26.7%, while the share of 
agriculture,  industry  and  public  administration  dropped  from  40.8%  to  37.6%.  The  number  of  active 
companies increased in 202213, mainly driven by micro companies (0-9 employees) in the service sector. 
Some 93% of all companies are small and micro businesses (i.e. with less than 50 employees). Overall, 
the speed of structural change has been limited. 

Economic integration with the EU and price competitiveness 

Trade  and  investment  integration  with  the  EU  remained  high.  Over  the  last  5  years,  trade  shifted 
towards  neighbouring  countries  such  as  Serbia,  although  the  country’s  traditional  export  markets 
(Germany,  Italy,  Croatia, Austria)  clearly remain  the  main  destination.  The  share  of  the  EU-27  in  total 
merchandise exports rose from 72.2% in 2018 to 73.0% in 2023, while the share of Central European Free 
Trade  Agreement  (CEFTA)  countries  increased  from  15.3%  in  2018  to  18.0%  in  2023.  Bosnia  and 
Herzegovina’s openness to trade (exports and imports as a percentage of GDP) increased from 98.4% in 
2018  to  102.2%  of  GDP  in  2023  but  remains  relatively  low  given  the  small  size  of  its  economy.  The 
export  structure  is  not  very  diversified  and  relies  mainly  on  basic  metals,  machinery  and  chemical 
products.  The  EU  integration  of  the  country’s  financial  and  capital  markets  is  also  still  rather  low, 
although a large part of the banking sector is owned by European banks. About two thirds of the foreign 

13 No data for 2023 available. 

54 

 
 
 
direct investment (FDI) stock originate from EU countries. 

Bosnia and Herzegovina’s overall price competitiveness has continued to deteriorate slightly. This is 
reflected  in  an  appreciation  of  the  real  effective  exchange  rate,  resulting  from  the  strengthening  of  the 
euro,  to  which  the  domestic  currency,  the  Convertible  Mark  (KM),  is  pegged.  Furthermore,  the  recent 
relatively  high  wage  increases  could  have  a  negative  effect  on  the  country’s  international  price 
competitiveness. 

2.4. PUBLIC PROCUREMENT, STATISTICS AND FINANCIAL CONTROL 

Chapter 5: – Public procurement 

EU  rules  ensure  that  public  procurement  of  goods,  services  and  works  in  any  Member  State  is 
transparent and open to all EU companies on the basis of non-discrimination and equal treatment. 

Institutional set-up and legal alignment 

The legal framework is partially in line with the EU acquis. The Council of Ministers adopted the 2024-
2028 public procurement strategy and action plan in March 2024 with the main purpose of drafting a new 
public procurement law. In July 2024,  Parliament amended  the Law on  public procurement to improve 
efficiency  of  the  legal  protection  mechanism  in  public  procurement  procedures.  Eight  bylaws  on  the 
implementation and improvement of the public procurement system were adopted. The legal framework 
on concessions and public-private partnerships remains highly fragmented and not aligned with the EU 
acquis. 

The  Public  Procurement  Agency  has  insufficient  staff  to  implement,  monitor  and  support  public 
procurement policy. Better coordination is needed with the Competition Council and with the audit and 
judiciary institutions. 

The procurement practice remains formalistic. The exchange of information and submission of tenders is 
not conducted electronically, as per EU standards. Some upgrading of the e-procurement portal enabled 
the opening of public procurement data with new functionalities. The portal needs to be further developed 
and used to increase transparency. The mandatory use of e-auctions needs to be revised to improve the 
integrity and  efficiency  of the  procurement  process. While  the  e-procurement  system  is  robust,  it lacks 
user-friendly features and full e-communication functionalities to achieve its full impact. 

Implementation and enforcement capacity 

In 2023, the public procurement market represented 10.31% of the country’s GDP, a decrease of 0.34 
percentage  points  compared  with  2022.  The  average  number  of  bids  per  tender  remains  low  at  1.93  in 
2023. 

55 

025507520162017201820192020202120222023Graph 2.5a: Bosnia and Herzegovina -Exports of goodsEUCEFTAOtherSource: WiiW% ofGDP025507520162017201820192020202120222023Graph 2.5b: Bosnia and Herzegovina -Imports of goodsEUCEFTAOtherSource: WiiW% ofGDP 
 
 
 
In  monitoring the award and  implementation  of  contracts,  the  administrative  capacity  of  the  Public 
Procurement Agency is insufficient to fulfil its tasks. Its role should be strengthened to identify potential 
weaknesses and irregularities in procurement procedures. Statistics show a slight decline in the use of the 
negotiated procedure without prior publication (6.05% in 2023 compared with 6.69% in 2022). Over half 
of tenders (55.62%) received only one bid, and  86.5% of public contracts used price as the only award 
criterion, which is high. No mechanism has been put in place to regularly coordinate the interpretation of 
public procurement legislation between the key institutions involved. 

The  capacity  to  manage  public  procurement  processes  is  weak.  Specialised  procurement  functions 
need  to  be  established in each contracting  authority. More  efforts are  needed  to  improve  integrity  and 
avoid conflicts of interest in the public procurement process, which remains prone to irregularities and 
vulnerable  to  corruption.  The  Public  Procurement  Agency  organised  specialised  training  for  most 
contracting  authorities  and  strengthened  its  cooperation  with  prosecutors  and  civil  society  to  monitor 
violations  of  procurement  rules.  Cooperation  with  the  courts  and  with  civil  society  needs  to  further 
increase. The first high-level corruption case on public procurement ended with final convictions (Novalic 
et al.). 

Efficient remedy system 

The legislation on the right to appeal is broadly in line with the EU  acquis. The Procurement Review 
Body faces insufficient technical capacity) and a high volume of appeals), compounded by problems with 
case  law  accessibility,  prolonged  appeals  and  legal  loopholes  disrupting  procurement  processes.  The 
Procurement Review Body needs to significantly improve the transparency of its decision-making. 

Chapter 18: Statistics 

 European  statistics  are  developed,  produced  and  disseminated  by  EU  Member  States,  guided  by  the 
principles  and  quality  criteria  elaborated  in  Regulation  on  European  statistics,  such  as  professional 
independence, impartiality, reliability, transparency and confidentiality. Common rules are provided for 
the methodology, production and dissemination of statistical information, which are further specified in 
sectoral legislation that constitute the EU acquis on statistics. 

As  regards  statistical  infrastructure,  the  law  on  statistics  still  needs  to  be  aligned  with  European 
standards and integrate the principles of the European statistics code of practice. The Agency for Statistics 
of  Bosnia  and  Herzegovina  (BHAS)  needs  to  strengthen  its  coordination  with  other  data  producers  of 
official statistics.  

On  classifications  and  registers,  the  statistical  business  register  is  in  place,  but  data  received  from 
administrative sources remains insufficient. The main statistical classifications are in place. However, the 
equivalent  to  NUTS  II  regions  has  only  been  provisionally  defined  and  is  accepted  by  the  European 
Commission  until  Bosnia  and  Herzegovina  finalises  the  entire  classification  and  includes  in  it  the 
definition of the equivalent to NUTS III level as well. 

On  macroeconomic  statistics,  the  production  of  national  accounts  continues  to  deviate  from  the  EU 
acquis, and a master plan needs to be agreed among the three statistical institutes. Regarding the transition 
to  the  European  system  of  national  and  regional  accounts  (ESA)  2010  methodology,  Bosnia  and 
Herzegovina needs to provide the Commission with its GDP per capita figures, harmonised at NUTS II 
level. The sector classification is complete except for the sub-sectors of the general government sector.  

As  regards  government  finance  statistics  and  excessive  deficit  procedure  (EDP)  tables,  Bosnia  and 
Herzegovina should continue efforts to comply with ESA 2010, in particular to improve sector coverage, 
timeliness,  and  coverage  of  transactions.  Government  finance  statistics  and  excessive  deficit  procedure 
tables are sent to Eurostat on a regular basis, although not fully in line with ESA 2010. The series of GDP 

56 

 
 
data  at  state  and  entity  level  must  be  methodologically  harmonised.  The  country  does  not  transmit 
harmonised indices of consumer prices data to Eurostat.  

On business statistics, short-term statistics for industry, construction and services need to be established 
in line with the EU acquis. Preliminary results of structural business statistics for 2022 were published in 
November 2023 and submitted to Eurostat for the first time.  Foreign affiliates statistics still need to be 
aligned with the EU acquis. 

On social statistics, a full-scale survey of income and living conditions is conducted annually. A labour 
force  survey  is  conducted  regularly  and  data  are  now  being  published  more  timely.  Eurostat  started  to 
include quarterly data from the BiH labour force surveys 2021-2023 in its public datasets from 15 March 
2024.  On  gender  statistics,  in  February  2024  BHAS  issued the publication Women and  Men in  Bosnia 
and  Herzegovina.  For  the  first  time,  a  survey  on  structure  of  earning  was  conducted  in  2023  and  the 
results  were published and sent to Eurostat in June 2024. The national statistical office and the entities 
statistical institutes need to improve the collection of sex-disaggregated data and statistics, including data 
about  persons  with  disabilities  (and  their  labour  market  participation),  as  well  as  about  occupational 
accidents and occupational diseases. The BHAS established cooperation with the HJPC for the production 
of divorce, marriage and crime offenders’ indicators. 

On  agricultural  statistics,  the  agricultural  census  was  postponed  to  October  2025.  A  roadmap  for  the 
development of agricultural statistics was finalised in December 2023. 

Regarding environmental statistics, the Agency for Statistics partially reported environmental protection 
expenditures to Eurostat for the time series 2017-2021. 

As  for  energy  statistics,  further  work  is  needed  to  improve  the  quality  of  data  in  line  with  EU 
requirements.  Monthly  reporting  on  crude  oil  imports  is  done.  A  statistical  pilot  survey  of  oil  and  oil 
derivatives  was  conducted  to  establish  a  register  of  data  providers/reporting  units.  In  line  with  the 
regulations on energy statistics, monthly oil data will be sent to Eurostat starting with the reference year 
2024.  A  survey  on  household  energy  consumption    was  conducted  in  June  2024.  The  Agency  for 
Identification  of  Documents,  Registers  and  Data  Exchange  (IDDEEA)  has  continued  to  improve 
transport statistics and started cooperation with the Directorate of Civil Aviation. 

Chapter 32: Financial control 

The  EU  promotes  the  reform  of  national  governance  systems  to  improve  managerial  accountability, 
sound financial management of income and expenditure, and external audit of public funds. The financial 
control  rules  protect  the  EU’s  financial  interests  against  fraud  in  the  management  of  EU  funds  and 
protect the euro against counterfeiting. 

Public internal financial control 

All  levels  of  government  continued  to  implement  the  comprehensive  strategic  framework  for  public 
internal  financial  control  (PIFC)  alongside  their  respective  2020-2025  PIFC  strategies.  Annual  PIFC 
reports  for  2023  were  adopted  at  state  and  entity  level.  The  IT  tool  has  been  used  across  all  levels  to 
produce the monitoring reports. 

Managerial  accountability  is  embedded  in  the  main  policy  framework  on  public  administration  and 
public finance management but is only narrowly defined to cover financial responsibilities. Delegation of 
authority  remains  limited  to  higher  political  echelons  and  not  to  the  managerial  level  of  civil  servants. 
Fragmented  and  unaccountable  administrative  structures  and  the  lack  of  a  coordinated  countrywide 
approach on policymaking undermine assessment of performance. (See Section 2.1.1 - Democracy) 

The  legal  framework  for  the  functioning  of  internal  control  is  largely  in  place  at  all  levels  of 
government, but remains weakly implemented, and even more so over public companies and particularly 

57 

 
 
at  entities  level.  The  PFM  system  and  legal  framework  needs  to  integrate  better  the  PIFC  law  and 
requirements.  Lack  of  reporting  on  fiscal  risks  of  such  companies  in  the  annual  PIFC  reports  and 
ineffective fiscal oversight function over public companies undermine internal control. Legal provisions 
on internal control are still not well integrated in the general regulations on public finance management, 
business  processes  and  management  information  systems  at  all  levels  of  government  and  in  the  public 
companies. 

Internal audit practice is in line with international standards. Although all central harmonisation units 
(CHUs) have made efforts to oversee the process, the best results in  the implementation of their annual 
plans are visible at the state level. At the state level, steps were undertaken to establish quality assessment 
procedures; however, quality assurance remains not ensured in practice and managers weakly respond to 
recommendations.  Problems  persist  with a fragmented  system of  internal  audit.  The  Brčko  District still 
has to establish an internal audit function. Although training improved, capacities in IT technologies and 
experienced staff remains weak. The capacities of CHUs need to be improved to support institutions in 
implementing PIFC recommendations. 

External audit 

The  functional,  operational  and  financial  independence  of  state  audit  offices  is  set  out  in  the  legal 
framework and is yet to be anchored in the Constitution. 

The  institutional  capacity  of  supreme  audit  institutions  needs  to  be  strengthened  at  all  levels  of 
government. All supreme audit institutions have a broad mandate, which covers financial, compliance and 
performance audit. They need to improve the quality of audit work in providing compliance assurance 
and  increasing  the  number  of  performance  audits,  which  remained  stable,  with  a  slight  increase  in  the 
Federation entity. 

The  impact  of  the  audit  work  of  all  supreme  audit  institutions  varies.  State-level  institutions  and  the 
Federation  entity  implement  40%  of  recommendations  and  the  Republika  Srpska  entity  60%.  Supreme 
audit institutions need to establish closer partnerships with the parliaments to improve the implementation 
of recommendations by the governments.   Some progress was noted at state level under the new 2022-
2025  communications  strategy,  by  publishing  a  citizens’  audit  guide  and  organising    roundtables  with 
public stakeholders to increase awareness of audit work; more needs to be done at entity level. While the 
Federation entity has adopted a communication strategy, the Republika Srpska entity still needs to adopt 
its own communication strategy and undertake efforts in this regard. 

Protection of the EU’s financial interests 

The legal framework is yet to be aligned with the EU acquis. The Ministry of Finance and Treasury is the 
contact point for cooperation with the European Anti-Fraud Office (OLAF). 

Protection of the euro against counterfeiting  

Bosnia  and  Herzegovina  has  not  ratified  the  1929  Geneva  Convention  for  the  suppression  of 
counterfeiting currency. The legal framework is yet to be assessed against the EU acquis.  

3. GOOD NEIGHBOURLY RELATIONS AND REGIONAL COOPERATION  

Good neighbourly relations and regional cooperation form an essential part of Bosnia and Herzegovina’s 
European  integration  process.  They  contribute  to  stability,  reconciliation  and  a  climate  conducive  to 
addressing open bilateral issues and the legacies of the past.  

Bosnia  and  Herzegovina  maintained  its  involvement  in  a  number  of  regional  cooperation  initiatives 
such  as  the  Central  European  Free  Trade  Agreement  (CEFTA),  the  Energy  Community,  the  Transport 
Community,  the  South-East  European  Cooperation  Process  (SEECP)  and  the  Regional  Cooperation 

58 

 
 
 
Council, of which it hosts the seat14. Bosnia and Herzegovina chaired the Western Balkans Fund (WBF) 
in 2024. 

The fourth annual EU-Western Balkans Summit took place in Brussels in December 2023, reaffirming 
the  EU  membership  perspective  of  the  Western  Balkans  and  exploring  measures  to  further  advance 
gradual integration.  

Bosnia  and  Herzegovina  has  actively  engaged  in  the  regional  dimension  of  the  Growth  Plan  for  the 
Western Balkans, participating in both ministerial and leaders’ meetings. 

On  the  Common  Regional  Market (CRM), the  Berlin  Process  summit  took  place  in  October  2023  in 
Tirana,  for  the  first  time  in  the  Western  Balkans.  Bosnia  and  Herzegovina  signed  the  fourth  mobility 
agreement  on  the  recognition  of  professional  qualifications  concerning  nurses,  veterinary  surgeons, 
pharmacists and midwives, adopted at the summit and it was ratified in October 2024. In November 2023, 
Bosnia  and  Herzegovina  ratified  two  out  of  three  regional  mobility  agreements  signed  at  the  Berlin 
Process summit of November 2022. The country needs to swiftly ratify the third mobility agreement on 
freedom of movement with identity cards. The roadmap for roaming between the Western Balkans and 
the EU entered the first phase of implementation. Twelve  major decisions were agreed by the CEFTA 
Joint Committee in October 2024.  

Bosnia and Herzegovina continued to cooperate closely with Croatia, Montenegro and Serbia under the 
Sarajevo  Declaration  Process  to  find  sustainable  solutions  for  refugees  and  persons  displaced  by 
conflicts  in  the  1990s.  In  November  2023,  Sarajevo  hosted  the  closing  conference  of  the  Regional 
Housing  Programme.  Bosnia  and  Herzegovina  should  ensure  co-financing,  as  it  had  committed  to 
completing  the remaining housing  units  and  supporting  up  to  3 100 families.  It  should  also take  socio-
economic integration measures to ensure sustainable returns.  

Despite  progress,  7 608  people  are  still  missing  as  a  result  of  the  conflict  in  the  1990s.  52  missing 
persons were identified in 2023, and 4 in 2024. Regional efforts are needed through the missing persons 
group established in 2018 under the Berlin Process to strengthen cooperation.  

Bosnia and Herzegovina generally maintains good  bilateral relations with other enlargement countries 
and neighbouring EU Member States.  

Relations with Albania were upgraded. Albania opened an embassy in Sarajevo in December 2023 and 
the two countries continued to exchange high-level visits. Trade flows remain low.  

There  are  no  official  relations  with  Kosovo,  as  Bosnia  and  Herzegovina  does  not  recognise  Kosovo’s 
independence and the two maintain a strict visa regime. Bilateral meetings took place occasionally on the 
margins of regional and multilateral summits. An initiative to simplify the visa procedure for citizens of 
Kosovo is still pending.  

Bilateral  relations  with  Montenegro  are  good,  with  occasional  high-level  bilateral  visits.  The  agreed 
border demarcation is yet to be physically marked.  

Relations  with  North  Macedonia  are  good,  with  occasional  high-level  bilateral  visits.  Several  bilateral 
agreements  are  in  place,  including  on  cooperation  on  EU  integration,  and  from  November  2023  on 
economic cooperation.  

14  Bosnia  and  Herzegovina  also  actively  participates  in  initiatives  such  as  the  Brdo-Brijuni  Process,  the  Central  European 
Initiative,  the  Adriatic-Ionian  Initiative,  the  EU  Strategies  for  the  Danube  Region  and  for  the  Adriatic-Ionian  Region,  the 
Migration,  Asylum,  Refugees  Regional  Initiative  (MARRI),  the  Regional  School  of  Public  Administration  (ReSPA),  the 
Regional  Youth  Cooperation  Office  in  the  Western  Balkans  (RYCO),  the  South  East  European  Cooperation Process  (SEECP) 
and the Western Balkans Fund. 

  This  designation  is  without  prejudice  to positions  on  status  and  is  line  with  UNSCR  1244/1999  and  the  ICJ  Opinion on  the 
Kosovo declaration of independence. 

59 

 
 
 
Relations with Serbia are good and overall stable, even though the UN General Assembly resolution on 
the Srebrenica genocide led to political tensions. The two countries need to reach an agreement on state 
borders, including on two dams on the Drina river and a part of the Belgrade-Bar railway. Some 11 312 
citizens of Serbia voted from Bosnia and Herzegovina in Serbia’s parliamentary elections in December 
2023.  As  a  signatory  to  the  Dayton/Paris  Peace  Agreement,  Serbia  respects  Bosnia  and  Herzegovina’s 
sovereignty  and territorial integrity,  while  developing  and  publicly  promoting special  relations  with the 
Republika  Srpska  entity.  Senior  Serbian  officials  attend  the  unconstitutional  entity  celebrations  on 
9 January. Serbia established a joint parliamentary forum with the entity and held an ‘all-Serb assembly’ 
in Belgrade in June 2024, whose declaration on ‘the common future of the Serbian people’ was endorsed 
by  a  joint  government  session  and  subsequently  approved  by  both  assemblies  of  Serbia  and  of  the 
Republika Srpska entity. 

Türkiye  is  a  strong  international  supporter  of  Bosnia and  Herzegovina  and  exchanges  at  high  level  are 
frequent.  The  two  countries  reaffirmed  their  commitment  to  building  the  Sarajevo-Belgrade  highway, 
which Türkiye committed to finance.  

Relations  with  Georgia  are  good  and  without  open  issues.  The  two  countries  enjoy  visa-free  regime. 
Trade flows remain low.  

Relation with the Republic of Moldova are good, with sporadic bilateral contacts. A visa-free regime is in 
force since 2016. While both countries are part of CEFTA, trade flows remain low.  

Bosnia  and  Herzegovina  supports  the  territorial  integrity  and  sovereignty  of  Ukraine,  condemning 
Russia’s war of aggression. Bilateral relations are generally good  but have been affected by the neutral 
stance on Russia’s war of aggression against Ukraine by officials from the Republika Srpska entity. This 
also  resulted  in  significant  hindrances  to  implementing  restrictive  measures  against  Russia.  Bosnia  and 
Herzegovina took part the Ukraine Peace Summit in June 2024. Trade flows with Ukraine remain low. 

Relations  with  Croatia  are  good  overall,  although  affected  by  outstanding  bilateral  issues.  High-level 
bilateral  visits  took  place.  There  are  open  issues  concerning  land  and  sea  borders,  as  the  1999  border 
agreement has not been ratified by either side. Implementation of the 2001 succession agreement has been 
affected by issues on private property and acquired rights. Bosnia and Herzegovina continued to object to 
Croatia’s  plan  to  build  a  facility  for  radioactive  waste  at  Trgovska  Gora  near  the  border.  Some  35 000 
citizens of Croatia voted from Bosnia and Herzegovina in Croatia’s parliamentary elections in April 2024. 

4. 

ABILITY TO ASSUME THE OBLIGATIONS OF MEMBERSHIP  

CLUSTER 2: INTERNAL MARKET 

This cluster covers: the free movement of goods (Chapter 1); freedom of movement for workers (Chapter 
2); right of establishment and freedom to provide services (Chapter 3); free movement of capital (Chapter 
4);  company  law  (Chapter  6);  intellectual  property  law  (Chapter  7);  competition  policy  (Chapter  8); 
financial services (Chapter 9), and consumer and health protection (Chapter 28). 

Chapter 1: Free movement of goods 

The  free  movement  of  goods  ensures  that  many  products  can  be  traded  freely  across  the  EU  based  on 
common rules and procedures. Where products are governed by national rules, the principle of the free 
movement of goods prevents these rules from creating unjustified barriers to trade. 

60 

 
 
 
General principles 

Bosnia  and  Herzegovina  does  not  have  a  legislative  and  institutional  framework  for  the  production, 
distribution  and  marketing  of  industrial  products  in  place.  No  consistent  countrywide  approach  or 
strategy exists for alignment in this area and the conflicting regulations have not been repealed. 

Non-harmonised area 

No steps were taken to align with the obligations of Articles 34-36 of the Treaty on the Functioning of 
the European Union. No specific body is empowered to provide notifications of technical regulations. 

Harmonised area: quality infrastructure 

The  legal  bases  and  administrative  structures  to  ensure  technical  regulations,  standards,  conformity 
assessment, accreditation, metrology and market surveillance are not aligned with the EU acquis and are 
fragmented. There is still no countrywide strategy for the quality infrastructure in place and coordination 
among competent institutions remains weak. The standardisation, accreditation, and market surveillance 
bodies are understaffed. 

In  2023,  the  Institute  for  Standardisation  adopted  1 207  European  standards  as  national  standards. 
However, conflicting mandatory ex-Yugoslav standards have still not been systematically withdrawn. 

On  accreditation,  the  designation  of  conformity  assessment  bodies  and  conformity  assessment 
procedures  are  not  applied  consistently  throughout  the  country.  There  are  183  conformity  assessment 
bodies  in  Bosnia  and  Herzegovina,  comprising  94  testing  laboratories,  5  medical  and  9  calibration 
laboratories, 6 product certification bodies and 69 inspection bodies. 

The Institute of  Metrology  needs to cooperate and coordinate its activities with the entities’ metrology 
institutions.  Rules  on  metrology  are  not  applied  evenly  across  the  country,  undermining  legal  certainty 
and the single economic space. 

Market surveillance is still largely based on mandatory standards and pre-market inspections. In 2023, 
232  market  surveillance  inspections  were  done  on  197  products,  leading  to  3 790  products  being 
withdrawn from the market (of which 3 004 were destroyed). 

Harmonised area: sectoral legislation 

On  the  EU  ‘new  and  global  approach’  product  acquis,  no  alignment  with  the  EU  acquis  has  taken 
place over the past 12 years in Bosnia and Herzegovina. Legislation designed to align with the EU acquis 
is not applied across the country as its legislative framework is fragmented. The Republika Srpska entity 
implements its legislation separately, contrary to a Constitutional Court ruling.  

There  was  no  progress  on  alignment  with  the  EU  ‘old  approach’  product  acquis,  including  on 
registration,  evaluation,  authorisation  and  restriction  of  chemicals  (REACH)  and  on  strengthening 
administrative  capacity  in  this  area,  or  on  classification,  labelling  and  packaging  (CLP),  or  with 
procedural measures.  

There are no anti-corruption measures in place to monitor risks in product safety and no transparency of 
public bodies when inspecting products in the areas of market surveillance and conformity assessment. 

Chapter 2: Freedom of movements for workers 

Citizens of one Member State have the right to work in another Member State and must be given the same 
working and social conditions as other workers. 

Regarding access to the labour market, to work in Bosnia and Herzegovina an EU citizen must obtain a 
work permit and meet certain conditions (with several exceptions) as provided by the Law on foreigners. 
Legislation  in  the  entities  and  the  Brčko  District  is  not  yet  fully  harmonised  with  the  state-level  law. 

61 

 
 
Employment in the public administration is reserved for citizens of Bosnia and Herzegovina. Bosnia and 
Herzegovina still lacks a countrywide database of  vacancies which will be needed to join the European 
Employment Services (EURES) network. 

The coordination of social security schemes remains fragmented, with limited administrative capacity 
and lack of cooperation among authorities. Bosnia and Herzegovina has agreements on social security in 
place with 18 EU Member States. No new agreements were finalised in the reporting period; contacts are 
ongoing with Germany, Italy and Poland. 

There was no progress on the European Health Insurance Card (EHIC). 

Chapter 3: Right of establishment and freedom to provide services 

EU natural and legal persons have the right to establish themselves in any Member State and to provide 
cross-border  services.  For  certain  regulated  professions,  there  are  rules  on  mutual  recognition  of 
qualifications. EU rules on postal services focus on improving the quality of universal service, gradual 
market opening to competition, and the establishment of an independent regulator. 

The legislation on the right of establishment and on the freedom to provide cross-border services is 
not  aligned  with  the  EU  acquis.  No  progress  was  made  to  develop  a  countrywide  law  on  services  that 
covers its principles, and no screening of sector-specific legislation took place to prepare it. No point of 
single contact was established. A register of service-related legislation was created identifying 717 laws, 
bylaws  and  regulations  to  be  amended  and  aligned  with  the  EU  Services  Directive.  Still  lacking  is  a 
countrywide inventory of administrative and technical steps that businesses need to operate, with the aim 
to abolish those requirements that hamper a single economic space. Strong coordination among all levels 
of government is a prerequisite to managing legislative alignment in this area. 

The legal framework for postal services is partly aligned with the EU acquis. A state-level strategy needs 
to be prepared to develop the postal market for full opening to competition. A new postal law at the state 
level needs to be developed and adopted to ensure consistent countrywide alignment and implementation 
of the EU postal acquis, including the Postal Services Directive and the Regulation on cross-border parcel 
delivery  services.  The  institutional  and  administrative  capacity  of  the  Agency  for  Postal  Traffic  needs 
strengthening to monitor and enforce the new postal market rules. 

The legislation does not provide for the mutual recognition of qualifications for regulated professions 
as  required  by the  EU  acquis.  The  planned  general roadmap  for alignment  with  the  EU  acquis has not 
been implemented. Citizens who request the recognition of their professional qualifications cannot refer 
to any contact point or e-governance facility for assistance. Bosnia and Herzegovina needs to draw up a 
detailed list of regulated professions. 

Chapter 4: Free movement of capital 

In  the  EU,  capital  and  investments  must  be  able  to  move  without  restrictions,  with  common  rules  for 
cross-border  payments.  Banks  and  other  economic  operators  apply  certain  rules  to  support  the  fight 
against money laundering and terrorist financing. 

As regards capital movements and payments, Bosnia and Herzegovina continues to apply full current 
account  convertibility.  Long-term  capital  transactions  are  mostly  liberalised,  but  restrictions  remain  for 
short-term ones. Institutional investors are subject to limitations on investment in foreign securities. 

The  state-level  law  on  foreign  direct investments  does  not  provide  for  equal treatment of foreign and 
domestic natural persons for the acquisition of real estate, which depends on reciprocity. This should have 
been remedied by 2021, in line with SAA commitments. Foreigners also cannot own agricultural land. 

The  Central  Bank  of  Bosnia  and  Herzegovina  (CBBH)  has  operated  a  modern  payment  system  since 
2019. Bosnia and Herzegovina still needs to adopt legislation to align with the EU  acquis on payments 
62 

 
 
(Payment  Services  Directive  2,  the  Electronic  Money  Directive  2  and  the  SEPA  Regulation).  Payment 
services need to be further liberalised and modernised. The system should be open to operators other than 
banks, including electronic money institutions, of which none have been licensed so far.  The Republika 
Srpska  entity  adopted  a  Law  on  electronic  money  in  January  2024,  regulating  issuers  and  requiring  a 
license  by  the  entity’s  banking  agency.  A  law  on  the  same  topic  should  be  adopted  in  the  Federation 
entity.  

A new law on anti-money laundering and countering terrorism financing (AML/CFT) was adopted in 
February 2024, with a view to aligning with the EU acquis. Implementing legislation is yet to be adopted. 
In February 2024 the Council of ministers adopted a risk assessment for the AML/CFT on virtual assets 
accompanied with an action plan for 2024-2027. A beneficial ownership register of legal persons in line 
with the EU acquis has yet to be established, and a central access point to the competent authorities is yet 
to be ensured. 

Chapter 6: Company law 

The EU has common rules on the formation, registration and disclosure requirements of a company, with 
complementary rules for accounting and financial reporting and statutory audit. 

On  company  law  and  corporate  governance,  Bosnia  and  Herzegovina’s  legislation  is  aligned  to  a 
limited  extent  with  the  EU  acquis.  The  existing  legislation  needs  to  be  reviewed  and  amended  to 
harmonise company law across the country. The different business registers in the entities and the Brčko 
District  are  neither  interconnected  nor  coordinated,  making  it  difficult  for  companies  to  operate 
throughout the country, and are not in line with the EU acquis. Bosnia and Herzegovina needs to simplify 
and harmonise the requirements for businesses and companies to register and operate across the country 
in  a  single  economic  space.  Further  harmonisation  is  needed  on  the  use  of  digital  tools,  cross-border 
operations  (mergers,  divisions,  conversions),  and  shareholder  rights,  including  the  encouragement  of 
long-term shareholder engagement. 

On company reporting, Bosnia and Herzegovina’s legislation is aligned to a limited extent with the EU 
acquis.  Further    alignment  with  the  EU  acquis  is  needed  across  the  board,  especially  on  corporate 
sustainability  reporting,  country-by-country  reporting  and 
listed 
companies,  whereas  there  is  partial  alignment  as  regards  financial  reporting  as  the  legislation  in  both 
entities and the Brčko District prescribes the use of international financial reporting standards (IFRS) for 
annual and consolidated accounts of all legal persons. Bosnia and Herzegovina still needs to designate, in 
line  with  EU  acquis  requirements,  one  single  supervisory  body  to  take  ultimate  responsibility  for  the 
oversight of statutory auditors across the country. 

transparency  requirements  for 

Chapter 7: Intellectual property law 

The EU has to a large extent harmonised rules for the legal protection and enforcement of intellectual 
property rights (IPR), covering notably patents, trade mark and designs, biotechnological inventions and 
pharmaceuticals, trade secrets, (craft and industrial) geographical indications, supplementary protection 
certificates, copyright and related rights. 

The intellectual property strategy has expired and has not yet been replaced.  

The legal framework on copyright and related rights is moderately aligned with the EU acquis. Some 
preparations started to further align with the EU acquis on copyright and related rights on digital single 
market, orphan works, and collective rights management. 

On industrial property rights, the legislative framework is partly aligned with the EU acquis. Although 
preparations started, further alignment is needed on patents, trademarks and trade secrets,  as well as on 
topographies of semiconductor products and industrial designs.  The country has still not acceded to the 
European Patent Convention as required by the SAA. 
63 

 
 
Regarding  enforcement,  a  platform  for  electronic  data  exchange  for  the  enforcement  of  intellectual 
property rights was made operational in April 2024. 

In the reporting period, the Indirect Taxation Authority (ITA) received 78 requests for customs measures 
based  on  protected  trademarks,  one  on  design,  one  on  patent  and  one  on  copyrights  or  related  rights 
protection. It issued 96 decisions on the temporary detention and seizure of goods. The State Investigation 
and  Protection  Agency  (SIPA)  investigated  31  cases,  of  which  17  were  closed.  One  operational  action 
was carried out and one report was submitted to the State-level Prosecutor’s Office.  

The  administrative  and  judicial  capacity  of  enforcement  institutions  on  intellectual  property  rights  is 
insufficient  and  their  coordination  needs  to  improve.  Training  and  awareness-raising  on  intellectual 
property rights should continue, in particular for court officers. 

Bilateral collaboration with the European Union Intellectual Property Office is ongoing in the framework 
of inter alia an MoU, focusing mainly on convergency of common practices, technical and operational 
support with harmonisation of acquis and examination guidelines, as well as integration into EUIPO data 
bases and networks. 

Chapter 8: Competition policy 

EU  rules  protect  free  competition.  They  include  antitrust  rules  against  restrictive  agreements  between 
companies and abuse of dominant position, and also include rules on concentrations between companies 
which  would  significantly  impede  effective  competition.  EU  rules  also  set  out  a  system  of  State  aid 
control. Governments are only allowed to grant State aid if restrictive conditions are met, with a view to 
preventing distortion of competition. 

Antitrust and mergers 

The legislative framework on antitrust and mergers is broadly aligned with the EU acquis. The Law on 
competition  of  Bosnia  and  Herzegovina  largely  mirrors  the  rules  in  the  EU  treaties  on  restrictive 
agreements and abuse of dominant position. It still needs to be brought in line with the most recent EU 
acquis, including implementing legislation. 

As for the institutional framework, the functioning of the Competition Council is significantly impeded 
by  ethnic-based  decision-making  procedures,  which  require  decisions  to  be  supported  by  at  least  one 
representative  of  each  constituent  people  to  have  legal  effect.  The  Law  on  competition  needs  to  be 
amended, notably to revise the voting procedures in line with the EU acquis. 

Regarding  enforcement  capacity,  the  staff  of  the  Competition  Council  needs  to  increase  its  expertise 
through training. 

On  implementation,  in  2023  the  Competition  Council  took  11  decisions  on  concentrations:  five  were 
approved and six cases were rejected as not following reporting conditions. It issued 13 expert opinions 
and  conducted  27  investigations  into  potential  violations  of  the  Law  on  competition,  and  8  based  on 
reports  on  public  procurement.  The  Competition  Council  should  improve  its  enforcement  record,  in 
particular  on  cartels,  by  conducting  more  on-site  inspections  and  by  raising  awareness  on  its  leniency 
programme, and on mergers by imposing remedies where necessary. The judiciary’s capacity to handle 
complex  competition  cases  is  improving  but  needs  to  be  further  strengthened.  To  tackle  unfair 
competition in the market, cooperation with other regulatory bodies needs to increase. 

State aid 

The legislative framework on State aid, including the Law on the State aid system, is partially aligned 
with the EU acquis and SAA provisions. The implementing legislation is not developed evenly across the 
country. The EU acquis on de minimis aid, on services of general economic interest and on the purpose 
and  conditions  for  granting  State  aid  needs  to  be  adopted  at  state  level  and  by  the  Brčko  District.  A 
64 

 
 
regional aid map has not yet been drawn up and the existing aid schemes have not been aligned with the 
EU acquis and the SAA provisions. 

As for the institutional framework, the functioning of the State Aid Council is significantly impeded by 
ethnic-based  decision-making  procedures,  which  require  decisions  to  be  supported  by  at  least  one 
representative of each constituent people to have legal effect. The Law on State aid needs to be amended, 
particularly to revise the voting procedure in line with the EU acquis. While the Republika Srpska entity 
has appointed new members of the State Aid Council, the Federation entity is yet to do so, and the present 
members  continue to  provisionally  perform  their  tasks.  Their  expiration of mandate does not affect  the 
legality of adopted decisions, however, it still impacts the effective functioning of the State Aid Council. 

The enforcement capacity of the State Aid Council is insufficient. Sessions are held once a month and 
only  remotely.  With  only  seven  staff  members,  its  secretariat  is  not  able  to  fulfil  its  tasks.  Its  capacity 
needs to be increased and developed through training. In its current form, the State Aid Council is unable 
to fulfil its mandate. 

On implementation, the State Aid Council issued four decisions during the reporting period. Most State 
aid measures are put in place by granting authorities without notification or prior approval. Transparency 
of State aid measures is not ensured in Bosnia and Herzegovina. 

Liberalisation 

Concerning liberalisation, the Law on competition and the Law on State aid apply to public undertakings 
and undertakings with special or exclusive rights. Bosnia and Herzegovina needs to ensure that these rules 
are being enforced. The rules on financing services of general economic interest are not fully aligned with 
the EU acquis. 

Chapter 9: Financial services 

EU  rules  aim  to  ensure  fair  competition  among,  and  the  stability  of,  financial  institutions,  namely 
banking,  insurance,  supplementary  pensions,  investment  services  and  securities  markets.  They  include 
rules on authorisation, operation and supervision of these institutions. 

In the area of  banking and financial conglomerates, the institutional and legal framework is in place, 
with  a  good level  of  alignment  with the  previous  versions  of  Capital  Requirements  Regulation  and  the 
Capital  Requirements  Directive  (CRR/CRD  IV)  although  work  is  needed  to  ensure  alignment  with  the 
latest version of the Regulation and of the Directive.  

To ensure financial stability, Bosnia and Herzegovina needs to improve cooperation among the banking 
agencies,  central  bank,  deposit  insurance  agency  and  relevant  ministries  (a  memorandum  of 
understanding  to  that  end  is  yet  to  be  signed),  and  to  adopt  a  common  methodology  to  determine 
systematically important banks. 

The country continued implementing the methodology for the supervisory review and evaluation process 
(SREP),  identifying  risks  and  corrective  measures  for  individual  banks.  To  be  complete,  the  legal 
framework must strengthen  supervisors’  corrective  and  enforcement  powers  and  introduce  consolidated 
supervision of banking groups across the entities.  

Regarding bank resolution, institutional and legal obstacles to swift and effective resolution of banks need 
to  be  reduced.  Bosnia  and  Herzegovina  should  establish  a  resolution  fund  in  line  with  the  Bank 
Resolution  and  Recovery  Directive  (BRRD)  to  ensure  adequate  resources  are  available  to  efficiently 
handle potential crises.  

Regarding insurance and occupational pensions, entities’ legislation on compulsory vehicle insurance 
were further aligned with a view to achieving a countrywide harmonised approach to the liberalisation of 
the insurance market. Some incremental preparatory steps were made for the transition to a Solvency II-

65 

 
 
based  regulatory  framework.  The  Insurance  Agency  of  Bosnia  and  Herzegovina  prepared  a  conformity 
analysis of the entity laws with the Solvency II Directive. No progress was made on voluntary pensions. 
Alignment with the EU acquis governing financial supervision of institutions for occupational retirement 
provision has yet to be addressed. 

In  terms  of  financial  market  infrastructure,  the  country  developed  a  2024-2026  roadmap  for  the 
alignment of legislation governing securities market with the EU acquis. Nevertheless, the legislation is 
still not in line with the EU acquis. 

The  entity-level  legislation  and  regulatory  bodies  on  securities  markets  and  investment  services 
remains neither harmonised across the country nor aligned with the EU acquis. Coordination between the 
entities  needs  to  improve  to  ensure  consistent  alignment  with  key  areas  of  the  EU  securities  market 
acquis.  Bosnia  and  Herzegovina  has  not  reported  progress  on  investment  funds  in  the  past  year,  and 
would need to undertake further steps to ensure full alignment with the most recent EU acquis, including 
on  alternative  investment  fund  managers  and  undertakings  for  collective  investment  in  transferable 
securities. 

On digital finance, the presence of fintech start-ups is marginal compared with traditional banks, which 
are  perceived  as  the  main  financial  institutions.  Without  a  legal  and  regulatory  framework  for  digital 
identity, banks can only offer hybrid solutions. Further development will require a comprehensive reform. 

On  sustainable  finance,  the  strategic  priorities  for  2023-2025  envisage  measures  for  risk  assessment, 
supervision  and  international  cooperation,  as  well  as  the  establishment  of  rules  for  managing  climate-
related and environmental risks in the banking sector. Preparatory activities were held. The Central Bank 
of Bosnia and Herzegovina joined the Sustainable Banking and Finance Network in 2024. 

Chapter 28: Consumer and health protection 

EU  rules  protect  consumers’  economic  interests  and  also  ensure  product  safety,  prevent  dangerous 
imitations and establish liability for defective products. The EU also guarantees a high level of protection 
of  public  health  and  in  particular  also  ensures  high  common  standards  for  tobacco  control,  blood, 
tissues,  cells  and  organs,  and  medicines  for  human  and  veterinary  use.  The  EU  also  has  rules  for 
upholding  patients’  rights  in  cross-border  healthcare  and  in  preparing  for  and  responding  to  cross-
border health threats, including communicable diseases. 

Consumer protection 

On horizontal aspects, the state-level Law on consumer protection dates from 2006 and is not aligned 
with the latest EU acquis. Country-wide alignment with the latest EU acquis is needed to address rapidly 
changing  developments  in  this  area,  including  on  digital  markets  and  to  address  the  risk  of  unequal 
protection  of  consumers  across  the  country.  Administrative  capacities,  notably  of  the  Ombudsman 
institution need to be further improved. The legal framework for consumer credit and distance marketing 
of  financial  services  is  also  not  aligned  with  the  EU  acquis.  The  Ombudsman’s  office  for  consumer 
protection issued decisions and provided legal advice in 1 384 consumer complaints in 2023. 

No  proposal  on  an  annual  state  consumer  protection  programme  was  prepared  by  the  Consumer 
Protection Council, and the legal framework for product safety is still not aligned with the EU  acquis. 
However,  the  state-level  Market  Surveillance  Agency  has  initiated  a  reactive  market  surveillance 
mechanism  based  on  the  information  on  unsafe  products  and  has  started  publishing  notifications  on 
unsafe products on its website. The weekly reports of the EU Safety Gate Rapid Alert System are further 
displayed on the website of the Agency.   

Public health 

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On  public  health,  no  progress  was  made  in  drafting  a  health  strategy  at  state  level  or  in  the  Brčko 
District. There is no state-level health information strategy, and no progress was made on e-health. On 
tobacco control policies, legislation in the entities and the Brčko District is not aligned with the relevant 
EU  acquis.  The  Federation  entity  Law  on  tobacco  control  entered  into  force  in  May  2023,  but  its 
implementation is lagging behind.  Bosnia and Herzegovina does not fully implement the World Health 
Organization (WHO) Framework Convention on tobacco control due to the lack of systematic monitoring 
and has still not ratified the protocol to eliminate illicit trade in tobacco products. 

There  was  no  progress  on  alignment  with  the  EU  acquis  on  medicinal  products  for  human  use,  on 
medicines  for  veterinary  use,  or  on  medical  devices.  Patients  have  only  limited  access  to  certain 
medicines,  due  to  long  registration  and  control  procedures.  Overlapping  legislation  is  in  place  at  state 
level  and  in  the  Republika  Srpska  entity,  despite  Constitutional  Court  rulings.  The  legal  framework  on 
blood,  tissues,  cells  and  organs  is  not  aligned  with  the  EU  acquis,  and  the  necessary  administrative 
capacity  to  apply  it  is  absent.  There  is  only  very  limited  cooperation  between  the  entities’  transfusion 
institutes, and no countrywide oversight system to ensure efficient coordination. 

Legislation  on  serious  cross-border  health  threats,  including  communicable  diseases,  is  not  aligned 
with  the  EU  acquis.  Coordination  between  the  entities  and  the  state  level  on  communicable  disease 
surveillance  and  response  needs  to  be  strengthened.  Bosnia  and  Herzegovina’s  participation  in  the 
technical activities of the European Centre for Disease Control and Prevention (ECDC) remains limited. 
The legislation is not aligned with the EU acquis on patient’s rights in cross border health care.  

Measures  to  promote  healthy  lifestyles  and  prevent  non-communicable  diseases  are  partially 
implemented by the competent institutions of the entities and the Brčko District. 

On  preventive  measures,  on  cancer  screening,  both  entities  have  cancer  registers  but  there  is  no 
countrywide cancer control plan or early detection programme. The Republika Srpska entity has an early 
detection programme. There was no progress on mental health, on drug abuse prevention and harm-
reduction,  or  on  nutrition  and  physical  activity.  Civil society  groups take  part  in activities  to reduce 
alcoholism and prevent alcohol-induced disorders. 

On health inequalities, access to healthcare is still a key challenge, especially for marginalised groups 
including  Roma  people,  women  from  rural  areas  and  women  with  disabilities.  Women  and  girls  face 
problems  with  access  to  healthcare  due  to  lack  of  health  insurance  and  poorly  organised  services, 
especially on sexual and reproductive health. Conditions in hospitals and maternity hospitals need to be 
improved  and  obstetric  violence  eliminated.  Specialised  support  for  victims  of  sexual  violence  is  not 
available  across  the  country,  with  only  three  crisis  centres,  all located in  the  Federation  entity.  Despite 
improvements in addressing gender-based violence, a multi-sectoral response mechanism for victims still 
needs to be developed. (See also Chapter 19 – Social policy and employment) 

Corruption  in  the  health  sector  is  a  persistent  issue  significantly  affecting  the  delivery  of  healthcare 
services.  The  COVID-19  pandemic  exposed  irregularities  in  the  procurement  of  medical  supplies  and 
equipment.  Corruption  in  the  patient-doctor  relationship  in  the  healthcare  sector  presents  significant 
challenges  to  the  delivery  of  fair  and  effective  medical  services.  Addressing  this  issue  requires 
comprehensive  reforms,  including  strengthening  the  legal  framework,  boosting  transparency  and 
accountability mechanisms, and encouraging a culture of integrity within the healthcare profession. 

CLUSTER 3: COMPETITIVENESS AND INCLUSIVE GROWTH 

This cluster covers: Digital transformation and media (Chapter 10); Taxation (Chapter 16); Economic and 
monetary  policy  (Chapter  17);  Social  policy  and  employment  (Chapter  19);  Industrial  policy  (Chapter 

67 

 
 
 
20), Science and research (Chapter 25); Education and culture (Chapter 26); and Customs union (Chapter 
29). 

Chapter 10: Digital transformation and media 

The EU supports the smooth functioning of the internal market for electronic communications, electronic 
commerce and audiovisual services. The rules protect consumers and support the universal availability of 
modern services. 

On  electronic  communications,  Bosnia  and  Herzegovina  made  no  progress  in  aligning  the  legislation 
with the EU acquis, including on broadband cost reduction. Bosnia and Herzegovina has not developed a 
broadband strategy, even though it introduced the 4G network in 2019. The granting of radio spectrum 
licenses  for  5G  mobile  communications  is  not  likely  to  take  place  before  2026.  The  Communications 
Regulatory  Agency  (CRA)  still  lacks  financial  and  political  independence.  The  mandate  of  its  board 
expired at the end of 2017 and Parliament has still not appointed new board members.  

On digital services, Bosnia and Herzegovina made no progress in adopting a countrywide strategy and 
action  plan  for  the  development  of  an  information  society.  Bosnia  and  Herzegovina  has  no  open  data 
policy  in  place.  Alignment  is  needed  with  the  Digital  Services  Act  and  Digital  Markets  Act  to  ensure 
predictability.  Bosnia  and Herzegovina  should  also  align  with the  European  interoperability  framework 
and  the  Interoperable  Europe  Act.  There is  no  coordinated and  jointly  planned approach  for  the  digital 
transformation  of  public  services  throughout  the  country,  with  very  limited  data  exchange  between  the 
services. 

On digital trust and cybersecurity, Bosnia and Herzegovina does not have a comprehensive legislative 
framework  on  the  security  of  networks  and  information  systems.  Bosnia  and  Herzegovina  remains  the 
only  country  in  the  region  without  a  countrywide  strategy  on  cybersecurity.  The  Ministry  of  Security 
failed  to  set  up  a  working  body  for  drafting  a  strategy  and  needs  to  urgently  prioritise  this.  No 
countrywide  single  point  of  contact  has  been  designated.  Bosnia  and  Herzegovina  needs  to  establish  a 
network of computer security incident response teams (CSIRTs) to facilitate strategic cooperation and the 
exchange  of  information.  The  lack  of  a  comprehensive  legislative  or  strategic  framework  for 
cybersecurity poses a potential threat to Bosnia and Herzegovina, which needs to be urgently addressed. 
The country needs to continue the implementation of the 5G Cybersecurity Toolbox measures, including 
assessing the risk profile of suppliers and putting in place appropriate restrictions and/or exclusions for 
high-risk suppliers. No progress was made in adopting a Law on electronic identity and trust services for 
electronic transactions with a single supervisory body for the whole country, in line with the EU acquis. 
Nor  was  there  any  progress  on  ensuring  the  interoperability  of  electronic  signature  throughout  the 
country. 

As  regards  media,  the  Communications  Regulatory  Agency  adopted  bylaws  to  improve  the  alignment 
with the EU acquis. Bosnia and Herzegovina met the requirements for continuing its participation in the 
MEDIA  and  cross-sectoral  strands  of  the  Creative  Europe  programme.  TV  stations  in  Bosnia  and 
Herzegovina  suspended  analogue  terrestrial  broadcasting,  prompting  public  broadcasting  services  to 
acquire  equipment  for  the  switch  to  digital  terrestrial  broadcasting.  Bosnia  and  Herzegovina  failed  to 
introduce a suitable model to collect broadcasting fees that would ensure the public broadcasting system’s 
financial  sustainability  and  political  independence.  The  country  should  establish  the  Public  Services 
Broadcasting  Corporation as  prescribed  by  law  to  ensure  compliance.  Additionally, it  should  revise the 
financing model for local public broadcasters in order to reduce opportunities for political pressure and 
influence. (See also Chapter 23 – Freedom of expression) 

Chapter 16: Taxation 

EU rules on taxation cover value added tax, excise duties and aspects of corporate taxation. They also 
cover  cooperation  between  tax  administrations,  including  the  exchange  of  information  to  prevent  tax 
68 

 
 
evasion. 

The  legislative  framework  for  indirect  taxation  is  partially  aligned  with  the  EU  acquis.  In  November 
2023,  the  Law  on  the  value  added  tax  (VAT)  was  amended  in  line  with  the  Directive  on  the  common 
system of value added tax, increasing the threshold for mandatory VAT registration to some EUR 50 000. 
Since  January  2024,  all  VAT  taxpayers  are  submitting  tax  declarations  electronically,  using  qualified 
digital signature.  

As regards excise duties on tobacco, alcohol and energy, and general rules for the production, keeping, 
storage,  movement  and  controls  on  products  that  are  subject  to  excise  duties,  full  alignment  of  the 
legislation with the EU acquis is needed. 

On direct taxation, the tax and social contribution regimes in the two entities have continued to diverge, 
hindering progress towards a single economic space. There was no progress in the field of direct taxation 
in the Federation entity, as new legislation is yet to be adopted. 

On  administrative  cooperation  and  mutual  assistance,  Bosnia  and  Herzegovina  has  ratified  the 
OECD/Council of Europe Convention on mutual administrative assistance in tax matters. The country has 
not yet committed to automatically exchanging financial account information based on the OECD single 
global standard. Bosnia and Herzegovina has signed and implemented 38 double taxation agreements, of 
which 19 with EU Member States. 

Concerning  operational capacity and digitalisation, further improvement of coordination, cooperation 
and  data  exchange  is  needed  among  Bosnia  and  Herzegovina’s  various  tax  administrations.  The 
administrative capacity and staffing levels of the Indirect Taxation Agency (ITA) should be strengthened. 
The  country  needs  to  increase  alignment  and  improve  cooperation  between  the  Indirect  Taxation 
Authority and the tax administrations, including through joint audits. The ability of ITA to fulfil its vital 
countrywide  role  must  be  ensured.  The  Tax  Administration  of  the  Federation  entity  took  initial  steps 
towards interoperability and recognition of e-signature by adjusting the IT system to enable the use of e-
signatures issued by accredited bodies in BiH. 

Chapter 17: Economic and monetary policy 

EU rules require the independence of central banks and prohibit them from directly financing the public 
sector.  Member  States  coordinate  their  economic  policies  and  are  subject  to  fiscal,  economic  and 
financial surveillance. 

As regards monetary policy, the currency board anchors the convertible mark (BAM) to the euro.  The 
Central Bank’s objective of currency stability remains in contrast with the primary objective of monetary 
policy in the EU, which is price stability. 

The  Law  on  the  Central  Bank  does  not  ensure  the  bank’s  unconditional  independence  and  is  not  fully 
aligned  with  the  EU  acquis  as  regards  the  prohibition  of  monetary  financing.  In  December  2023,  the 
Presidency  appointed  a  new  governor  and  governing  board  for  the  Central  Bank  for  a  6-year  mandate, 
with 2.5 years of delay. Preserving the integrity of the currency board arrangement and the independence 
of the central bank remains crucial. 

Regarding  economic  policy,  fiscal  rules  remain  at  entity  level  and  there  is  no  independent  fiscal 
institution to monitor and enforce compliance countrywide. 

The  alignment  of  the  underlying  statistical  framework  with  the  requirements  and  definitions  of  the 
European system of national and regional accounts (ESA 2010) is limited. The medium-term budgetary 
framework  is  supposed  to  form  the  base  of  the  country’s  annual  budgets.  However,  it  remains 
insufficiently developed and due to its delayed adoption this planning tool does not fulfil its purpose. The 
country should regularly adopt the global fiscal framework in time, to provide guidance and ensure the 

69 

 
 
timely adoption of the annual budget by all levels of government. The country’s Fiscal Council does not 
comply with the EU acquis requirements, notably lacking institutional independence. The Central Bank 
has committed to preparing the excessive deficit procedure (EDP) notification for 2023 by October 2024. 

Bosnia and Herzegovina’s  Economic Reform Programme (ERP)  improved only marginally  in quality 
and  was again submitted with a  substantial  delay.  The  policy  guidance, jointly  agreed  at the July  2023 
Economic  and  Financial  Dialogue  between  the  EU  and  the  Western  Balkans  and  Türkiye,  was 
implemented  to  a  partial  extent.  The  capacity  to  design,  implement  and  monitor  structural  reforms 
remains  very  limited,  while  insufficient  political  support  contributes  to  delays  in  formulating  the 
countrywide reform programme. The coordination institution (the Directorate for economic planning of 
the Council of Ministers) still lacks sufficient resources, powers and political support to efficiently handle 
the process. 

Chapter 19: Social policy and employment 

EU rules in the social field include minimum standards for labour law, equality, health and safety at work 
and non-discrimination. They also promote social inclusion and social protection, and social dialogue at 
EU level. 

The labour laws, in place at the level of the entities and the Brčko District, guarantee a minimum level of 
protection  to  all  employees.  To  fully  meet  EU  standards,  the  legal  framework  requires  further 
improvement  in  several  areas,  notably  as  regards  the  protection  of  workers  from  discrimination. 
Implementation  remains  inadequate,  especially  on  social  dialogue,  protection  of  workers  and  the 
enforcement of labour inspections. 

Laws  on  health  and  safety  at  work  are  in  place  in  the  entities  and  the  Brčko  District.  The  bylaws 
regulating specific aspects of occupational safety and health need to be adopted and harmonised with the 
EU  acquis  throughout  the  country.  Enforcement  and  implementation  of  legislation  remain  partial, 
especially when it comes to inspection capacity, prevention of injuries, investment in safety and training, 
and risk assessment. Data collection and dissemination on work-related injuries and diseases needs to be 
improved. No countrywide data is collected on accidents and fatalities, and the entities did not yet present 
official data for 2023 on the issue. 

Social  dialogue  is  weak  at  all  levels,  with  no  significant  improvements.  Social  partners  are  not 
sufficiently involved in the implementation of policies and have only limited capacities. Capacity building 
of  social  partners  will  need  to  be  addressed.  There  are  no  general  collective  agreements,  but  only  few 
concluded branch and sectoral collective agreements, mainly in the public sector. Entity-level Economic 
and Social Councils operate unevenly, and there is no such body at state level. Significant gaps remain in 
ensuring freedom of association for trade unions and the right to collective bargaining which should be 
addressed as a matter of priority. 

The  Federation  entity  adopted  its  2023-2030  employment  strategy  in  late  2023.    There  is  still  no 
countrywide  strategy  for  employment  policy,  while  both  entities  now  have  strategies  that  embed  the 
Youth Guarantee. 

Long-term,  structural  unemployment  prevails,  marking  a  mismatch  between  the  education  system  and 
labour market needs. Labour emigration to the EU continued. 

There  has  been  no  progress  in  preparations  for  using  the  European  Social  Fund.  (See  Chapter  22  - 
Regional policy and coordination of structural instruments) 

Public employment services (PES) continue improving their services to jobseekers, but their capacities 
remain weak. Public employment services are responsible for the administration of social benefits, which 
further limits their ability to fulfil their core task of assisting active jobseekers. Registration with a public 
employment service gives access to several social benefits, including basic health insurance. Therefore, 

70 

 
 
even  workers  in  the  informal  sector  and  those  not  actively  searching  for  a  job  have  high  incentives  to 
register  as  unemployed.  Bosnia  and  Herzegovina  needs  to  swiftly  complete  and  adopt  the  Youth 
Guarantee implementation plan. The level of informal employment remains high. 

On  social  inclusion  and  protection,  there  are  no  countrywide  strategies  on  poverty  reduction,  social 
inclusion  and  protection,  nor  is  there  a  state-level  monitoring  system.  For  persons  with  disabilities, 
institutional  care  is  still  prevalent,  accessibility  remains  a  challenge  including  to  public  buildings,  and 
there  are  only  few  community  services  to  support  independent  living.  The  social  protection  system 
remains underdeveloped and ineffective. Without proper data collection, social assistance is neither well 
targeted nor needs-based. A large number of people is not covered by public health insurance and as such 
is not entitled to basic healthcare, while eligibility conditions and coverage differ among entities, districts 
and cantons. Cooperation between social service centres and employment services is not well established. 
The transformation of institutions for social protection is still ongoing. 

Deinstitutionalisation  requires  comprehensive  reform  of  financing  of  new  services  for  both  capacity 
building  and  support  for  social  service  centres  across  the  country.  Both  entities  and  the  Brčko  District 
have  endorsed  a  roadmap  for  deinstitutionalisation,  developed  in  cooperation  with  UNICEF  and  the 
Ministry of Civil Affairs, focusing on improving the position and status of institutionalised children. (See 
Chapter 23 – section on fundamental rights) 

The scope and duration of maternity, paternity and parental leave remains uneven throughout the country, 
and wage compensation remains an issue. Bosnia and Herzegovina should adopt countrywide measures to 
improve the living conditions of older people, as well as a new action plan for children. A Council for 
persons with disabilities was set up in July 2023. The EU statistics on income and living conditions (EU-
SILC),  stemming  from  surveys  conducted  in  2022-2023,  are  still  not  available  in  Bosnia  and 
Herzegovina. 

labour 

There are no comprehensive strategies or action plans on non-discrimination in employment and social 
policy, which is hampered 
by  the  fragmentation  of 
the  social  system  and 
weak  coordination  and 
among 
cooperation 
administrative 
bodies. 
laws 
Although 
within the country address 
the 
non-
discrimination  at  work, 
EU 
alignment 
be 
legislation 
public 
ensured.  Most 
bodies 
have 
mechanisms  for  dealing 
of 
with 
complaints 
mobbing 
and 
discrimination in line with non-discrimination law. 

with 
must 

issue 

not 

do 

of 

The  principle  of  equal  opportunities  and  equal  treatment  of  men  and  women  in  matters  of 
employment and social policy is regulated by the laws on gender equality and anti-discrimination, and 
by the entity-level labour laws, but enforcement remains low. Rights prescribed by the EU Directive on 
work-life balance for parents and carers are only partially recognised through legislation regulating labour 
and  social  security  at  various  levels  of  government.  However,  this  has  not  been  done  in  a  harmonised 
manner or fully aligned with the Directive. Bosnia and Herzegovina needs to focus more on care policies, 

71 

 
 
specifically, maternity and paternal leave, care services, care related social transfers, family-friendly work 
arrangements  and  infrastructure.  The  country  needs  to  establish  uniform  minimum  maternity  leave 
benefits  across  the  country  and  harmonise  the  definition  of  maternity,  paternity  and  parental  leave  to 
eliminate  discrimination  and  harmonise  relevant  benefits  in  public  and  private  sectors.  Women  are 
estimated to earn on average 78% to 85% of a man’s salary for the same position. A new  countrywide 
Gender Action Plan was adopted in October 2023 for the period 2023-2027. 

Chapter 20: Enterprise and industrial policy 

EU  industrial  policy  strengthens  competitiveness,  facilitates  structural  change  and  encourages  a 
business-friendly environment that stimulates small and medium-sized enterprises (SMEs). 

During the reporting period, the entities and Brčko District continued to provide subsidies, tax relief and 
guarantees to alleviate the impact of negative economic trends caused by the shortages of raw materials, 
increased energy prices and disruption of supply chains. 

In  November  2023  the  Federation  entity  adopted  legislation  on  entrepreneurial  infrastructure  and  on 
encouraging the development of small businesses, while in December 2023 the Brčko District adopted a 
law on entrepreneurial infrastructure. In January 2024, the Republika Srpska entity adopted a 2024-2027 
action  plan  for  SMEs  innovation,  and  appointed  a  new  SME  development  council.    Bosnia  and 
Herzegovina has not adopted countrywide guidelines for harmonisation of SME support  in line with the 
Small Business Act, therefore the level of harmonisation of the legislation with the EU acquis remains to 
be assessed.  

On  enterprise  and  industrial  policy  principles,  there  is  no  countrywide  development  strategy  and  no 
state-level body promoting the consistency of policy with industrial strategies. 

Limited steps were taken to improve the business environment and to attract investments. High barriers to 
starting a business, rules on taxes and para-fiscal (i.e. non-tax) charges and regulatory differences across 
various  levels  of  government  continue  to  be  addressed.  The  Federation  entity  adopted  the  bylaws  to 
introduce the electronic registration of businesses, which has started in Travnik. However, the systems of 
electronic  registration  of  businesses  are  not  yet  fully  functional  and  interoperable  across  the  country, 
including all  preconditions  related  to  e-signature/e-stamp.  (See  chapter  10  -  Digital transformation  and 
media)  

Bankruptcy proceedings are not resolved in a timely manner, with  insufficient emphasis on companies’ 
rehabilitation and reorganisation. 

The  investment  environment  and  the  level  of  competitiveness  remain  unsatisfactory.  The  resolution  of 
commercial  disputes  remains  weak  and  arbitration  weakly  developed.  Improving  the  patent  application 
might  contribute  to  raise  the  extremely  low  business  investment  in  innovation  activities.  Oversight  and 
governance  of  public  enterprises  still  need  to  be  strengthened  to  put  public  companies  on  an  equal 
footing with other enterprises, contributing to improve the investment environment. The Republika Srpska 
entity  still  lacks  a  single  register  of  public  companies,  and  the  Federation  entity  has  not  yet  established 
oversight and management units. There is room to align alternative dispute resolution mechanisms with EU 
standards and best practices. 

Preparations for the green and digital transitions, resilience, and global competitiveness of industry 
are  at  a  very  early  stage.  Energy  diversification  is  slowly  progressing  but  a  greater  focus  on  green 
investments is required, notably in manufacturing.  The  financial support for introducing innovations in 
green  and  digital  sectors  needs  to  be  improved,  in  particular  for  SMEs,  including  start-ups.  The 
forthcoming  Sustainable  Development  Strategy  for  the  period  2024-30  should  ensure  that  the  focus  is 
increasingly on attracting high-quality investment conditioned on co-operation with domestic enterprises. 

72 

 
 
The  severe  drop  in  public  support  to  business  R&D  needs  to  be  reversed,  as  business  expenditure  on 
R&D  is  already  very  low.  Higher  value  exports  also  declined  as  a  result  of  reduced  innovations  in 
trademark applications and knowledge-intensive services exports. Government support needs to improve 
accountability  for  the  use  of  public  funds.  The  capacity  and  funding  to  perform  monitoring  and 
evaluations of enterprise and industrial policy measures are still limited, and the statistical data remain 
insufficient. 

As  for  enterprise  and  industrial  policy  instruments,  no  progress  was  made  in  aligning  with  the  EU 
acquis the legislation against late payments in commercial transactions. 

Bosnia and Herzegovina participates in the SME pillar of the EU Single Market programme and signed an 
Association Agreement in July 2023. 

As regards sectoral policies, the Federation entity adopted in October 2023 its tourism strategy valid until 
2027. In January 2024 the Republika Srpska entity amended its Law on hospitality and the action plans to 
implement the industrial and SME development strategies. The level of harmonisation with the EU acquis 
and standards remains to be assessed for all adopted legislation in the sector. 

Chapter 25: Science and research 

The EU provides significant support for research and innovation. All Member States can participate in 
the EU’s research and innovation programmes and benefit from them, especially where there is scientific 
excellence and a solid investment in research and innovation. 

The  legislative  framework  on  research  and  innovation  policy  remains  fragmented  and  needs  to  be 
improved.  Bosnia  and  Herzegovina  needs  to  develop  and  adopt  a  new  strategy  and  action  plan  for 
scientific development. The estimated total allocations for research and innovation remain below 0.3% of 
GDP, which is far below the new priorities of the European research area. A smart specialisation strategy 
still needs to be developed and adopted. Bosnia and Herzegovina is included in the European Innovation 
Scoreboard with a score of 33.1% in 2024. The Country’s performance is below the average of ‘emerging 
innovators’ (48%) and the performance gap with the EU is increasing. Further progress should be made to 
ensure  reliable  and  comprehensive  statistics  on  research  and  innovation,  useful  for  instance  for  the 
European Innovation Scoreboard and the European Research Area. 

As regards international cooperation and framework programmes, Bosnia and Herzegovina takes part 
in Horizon Europe as an associated country. It received EUR 3.2 million in 2023, more than doubling the 
amount received in 2022. 

Chapter 26: Education and culture 

The  EU  supports  cooperation  in  education  and  culture  through  funding  programmes  and  the 
coordination  of  Member  State  policies  through  the  ‘open  method  of  coordination’.  The  EU  and  the 
Member  States  must  also  prevent  discrimination  and  ensure  quality  education  for  children  of  migrant 
workers, including those from disadvantaged backgrounds. 

On education and training, Bosnia and Herzegovina needs to move from a content-oriented towards a 
competency-based  approach  to  education.  Transformation  and  harmonisation  of  curricula  is  needed  to 
ensure systemic regulation of learning and teaching process.  

Bosnia and Herzegovina is partially participating in the 2023 ICILS and 2023 TIMSS assessments, as the 
Republika Srpska entity and the West Herzegovina Canton did not join them. The country dropped out of 
the 2021 PIRLS. After failing to participate in two PISA rounds (2022 and 2025), preparations to join the 
2029 PISA need to intensify. No systemic measures have been taken to address the findings of the 2018 
PISA and 2019 TIMSS. In the absence of a countrywide approach, some cantons have started reforming 
their curriculum based on student learning outcomes to improve quality in line with recommendations.  

73 

 
 
Although  the  legal  framework  is  in  place,  there  is  still  no  mechanism  to  systematically  measure  or 
monitor  the  quality  of  education  inputs,  outputs  or  outcomes,  and  data  does  not  feed  into  the 
policymaking process. Due to demographic changes, the number of students enrolled at almost all levels 
of education is gradually declining. 

Regarding inclusiveness, the education of children with special needs remains a challenge, particularly in 
terms of ensuring the necessary infrastructure, provisions, transportation and school assistants to support 
both  children  and  teachers.  While  some  positive  steps  were  undertaken  through  the  roadmap  for 
improving  inclusive  education,  all  education  authorities  should  step  up  the  implementation  of  the 
roadmap to ensure all recommendations are met. 

There  continued  to  be  limited  effort  in  supporting  the  digital  transformation  of  education  and  training, 
including on digital skills without a countrywide coordinated approach. Authorities need to enhance their 
efforts  towards  effective,  coherent  and  inclusive  digital  transformation  of  the  education  and  training 
systems,  including  the  capacity  of  the  systems  to  develop  digital  skills,  in  line  with  the  EU  digital 
education action plan 2021- 2027. 

A  countrywide  policy  document  on  vocational  education  and training  (VET)  has been  in  place since 
2021, based on the Riga conclusions. However, no noticeable progress followed. Preparations for joining 
the European Alliance for Apprenticeships (EAfA) should be accelerated. Measures to promote life-long 
learning of adults also need to be stepped up. 

Bosnia and Herzegovina’s national qualifications framework (NQF) is not yet referenced to the European 
qualifications framework (EQF), nor is there a mechanism for the validation of prior learning. With the 
appointment  of  representatives  from  the  Republika  Srpska  entity  in  October  2023,  the  inter-sector 
commission  for  the  NQF  was  finally  established.  Cooperation  further  improved  between  the  two 
accreditation agencies, one at state level and one in the Republika Srpska entity. However, accreditation 
of  study  programmes  remains  challenging.  Bosnia  and  Herzegovina  needs  to  further  improve  quality 
assurance in higher education. 

Bosnia  and  Herzegovina  benefits  from  the  international  dimension  of  the  2021-2027  Erasmus+ 
programme. The country is participating in all the working groups 2021-2025 of the European Education 
Area  (Bologna  Process).  As  part  of  the  enhanced  partnership  with  the  region,  Bosnia  and  Herzegovina 
can  apply  for  the  calls  of the  European  Universities  Initiative,  and  four  Bosnian  universities  have  been 
selected as partners in funded alliances. 

On sports, Bosnia and Herzegovina continued to participate in the European week of sport. 

In  the  area  of  culture,  Bosnia  and  Herzegovina  continues  to  implement  measures  under  the  UNESCO 
Convention on the protection and promotion of the diversity of cultural expression. The country still has 
to  ensure  a  permanent  solution  to  the  legal  status  and  financing  for  the  seven  cultural  institutions  of 
significance  for  Bosnia  and  Herzegovina.  Bosnia  and  Herzegovina  continues  to  participate  fully  in  the 
Creative Europe programme. 

The  budget  allocation  for  culture  at  all  levels  of  government  may  be  increased  with  longer-term, 
multiannual funding decisions to provide financial stability for cultural creation and operation. Bosnia and 
Herzegovina  may  benefit  from  establishing  formal  partnership  structures  enabling  transparent  and 
organised participation in cultural policy-making. 

74 

 
 
Chapter 29: Customs union 

All Member States are part of the EU customs union and follow the same customs rules and procedures. 
This  requires  legislative  alignment  as  well  as  adequate  implementing  and  enforcement  capacity  and 
access to and interoperability with the  EU electronic customs environment. 

The Indirect Taxation Authority is in charge of implementing the customs legislation and policies, which 
should  be  further  aligned  with  the  EU  acquis  on  customs  including  the  Union  Customs  Code.  Two 
companies  have  been  recognised  as  authorised  economic  operators  (AEOs).  The  customs  tariff  and  
classification of goods are aligned with the EU’s combined nomenclature. The country continues to apply 
the Pan-Euro Mediterranean Convention and has begun adopting the transitional rules of origin in trade 
with the EU. 

Bosnia and Herzegovina is an observer in the Common Transit Convention and intends to join it once it 
has  met  all  legal  and  technical  requirements,  including  upgrading  its  new  computerised  transit  system 
(NCTS),  which  has  been  operational  since  August  2022.  The  next  step  is  connecting  NCTS  to  the 
common  EU  infrastructure.  Bosnia  and  Herzegovina  should  continue  aligning  with  the  EU  acquis  its 
provisions concerning customs enforcement of intellectual property rights. The country should implement 
the  CEFTA  additional  protocol  5  concerning  the  mutual  recognition  of  AEO  programs  and  improve 
cooperation and use of anti-fraud tools to combat cross-border smuggling of tobacco products and other 
illicit  activities.  Accession  to  the  World  Health  Organization’s  Protocol  to  eliminate  illicit  trade  in 
tobacco products is recommended. (See also Chapter 28 – Consumer and health protection) 

The administrative and operational capacity of the Indirect Taxation Authority should be substantially 
strengthened,  especially  in  operational  posts.  Due  to  an  inadequate  risk  management  system,  customs 
authorities still perform 60% of checks physically. Bosnia and Herzegovina needs to align its customs IT 
systems with EU requirements to achieve interoperability with the common customs IT systems.  

CLUSTER 4: THE GREEN AGENDA AND SUSTAINABLE CONNECTIVITY 

This cluster covers Transport (Chapter 14); Energy (Chapter 15); Trans-European networks (Chapter 21); 
and Environment and climate change (Chapter 27). 

Chapter 14: Transport policy 

The  EU  has  common  rules  on  technical  and  safety  standards,  security,  social  standards,  State  aid  and 
market liberalisation in road transport, railways, inland waterways, multimodal transport, aviation and 
maritime transport. 

Regarding the general EU transport acquis, Bosnia and Herzegovina implements its transport strategy 
valid until 2030; an updated strategy with more realistic actions and deadlines is pending adoption. The 
reforms  in  the  transport  sector  have  been  insufficient  for  several  years.  The  country  should  speed  up 
proper implementation in all modes of transport. Activities mostly relate to infrastructure projects while 
little  or  no  attention is  given  to  delivering  on  the  commitments contained  in the  Transport  Community 
Treaty (TCT), its five actions plans and elements arising from the smart and sustainable mobility strategy 
for the Western Balkans. For larger transport agglomerations, sustainable urban mobility plans should be 
developed following EU practice, respecting environmental and social standards. 

An overall strategy for an intelligent transport system (ITS) covering all modes of transport is yet to be 
adopted and appropriate resources should be allocated for its implementation. 

On  road  transport,  the implementation  of  road  safety legislation remains  a concern,  as the number  of 
accidents and fatalities remains very high. Discrepancies persist between domestic and WHO data. The 
Ministry  of  Communications  and  Transport  still  needs  to  establish  a  lead  agency  for  road  safety  and a 

75 

 
 
 
countrywide  system  to  collect  data  on  road  crashes.  No  progress  was  made  on  transport  of  dangerous 
goods. The legislation on road infrastructure safety management is yet to be aligned with the EU acquis, 
including  on  inspections  and  audits.  Alignment  on  social  and  market  rules  in  road  transport  is  also 
needed; the transition towards smart tachograph technology has been a first step. 

On rail transport, half of the railway infrastructure remains unsafe, outdated and unreliable, and cannot 
enable suitable international transit. Bosnia and Herzegovina still needs to fully align the law on railways 
with  the  fourth  EU  railway  package,  notably  to  open  the  railway  market,  separate  infrastructure 
management and transport operations, and reinforce the independence and administrative capacity of the 
regulatory  body,  the  safety  authority  and  the  investigation  body.  The  country  still  needs  to  adopt  a 
multiannual maintenance plan for the entire network. Bosnia and Herzegovina should use modern ITS to 
build  or  rebuild  railway  sections.  At  entity  level,  the  railway  legislation  aiming  to  provide  non-
discriminatory access to  the  network  needs  to  be  brought  in  line  with  the  EU  acquis.  No  progress  was 
made on negotiating protocols on railway border crossing procedures with Croatia. 

On  maritime  transport, Bosnia  and  Herzegovina  remains  at  an  early  stage  of  preparation.  It  needs  to 
prepare  and  adopt  legislation  on  maritime  transport  in  line  with  the  EU  acquis  enabling  the  country  to 
become a maritime shipping flag holder. 

On inland waterway transport, Bosnia and Herzegovina should adopt its state-level legislation in line 
with the EU acquis, to ensure the safety of navigation on inland waterways and its maintenance. 

No progress was made on civil aviation. The 2009 Law on civil aviation still needs be aligned with the 
requirements  of  the  European  Common  Aviation  Area  Agreement  (ECAA).  Bosnia  and  Herzegovina 
urgently needs to address the chronic lack of adequately trained and qualified staff and the institutional 
set-up within the Bosnia and Herzegovina Directorate of Civil Aviation (BHDCA), which increases the 
risks of safety oversight. 

Bosnia and Herzegovina has not started to develop its policy, institutions, legal and regulatory framework 
on combined / intermodal transport. 

No progress was made regarding EU passenger rights in all modes of transport. 

Chapter 15: Energy 

EU energy policy covers energy supply, infrastructure, the internal energy market, consumers, renewable 
energy,  energy  efficiency,  nuclear  energy  and  nuclear  safety,  radiation  protection  and  nuclear 
safeguards. 

Bosnia  and  Herzegovina  needs  to  strengthen  countrywide  cooperation  and  coordination,  increase 
administrative capacity and financial resources, and improve the fragmented and inconsistent legislative 
and regulatory framework to align with and implement the EU acquis. Bosnia and Herzegovina needs to 
finalise and adopt the national energy and climate plan (NECP) 2021-2030 without further delays. 

No progress was made in establishing a compliant legal framework governing the security of supply in 
electricity which needs to be redirected from coal to renewables. No progress was made in the gas and oil 
sectors., including on drafting legislation on emergency oil stocks.  

Bosnia  and  Herzegovina  needs  to  rectify  all  identified  violations  of  the  EU  acquis  and  of  the  Energy 
Community Treaty acquis that are subjects of infringement procedures. 

To  ensure  the  opening  of  internal  energy  market,  Bosnia  and  Herzegovina  still  needs  to  adopt 
outstanding  gas  and  electricity  legislation.  Bosnia  and  Herzegovina  is  delayed  in  aligning  with  and 
implementing  the  electricity  integration  package,  which  is  a  precondition  for  market  integration.  This, 
among others, includes unbundling and certification of the transmission system operator, appointing the 
nominated electricity market operator (NEMO) and establishing the power exchange and day-ahead and 

76 

 
 
intra-day  markets.  The  entity-level  laws  need  to  be  fully  harmonised  with  this  legal  framework  and  be 
implemented. 

Regarding security of supply for natural gas, although only 3% of the energy supply comes from gas, the 
country remains fully dependent on one single source from Russia. Full implementation of the Regulation 
on the security of gas supply is pending, including development of risk assessment, preventive action plan 
and emergency plan, as per Energy Community acquis. 

The country still needs to adopt and enforce a new law for the restructuring, certification, and operation of 
the gas transmission system operator in line with the third energy package. 

On  retail  market,  the  gas  market  remains  closed  without  adequate  regulatory  oversight  and  lacks 
transparency,  particularly  on  setting  prices  for  end  consumers.  For  electricity,  the  independence  of 
regulatory authorities at all levels is still hampered by political interference. 

On hydrocarbons, in December 2023 the Council of Ministers adopted a decision on the quality of liquid 
petroleum  fuels  regulating  the  market  of  petroleum  products,  addressing  Energy  Community 
requirements. 

A state-level legal framework is still lacking on renewable energy, although both entities are preparing 
secondary  legislation.  Both  entities  and  the  Brčko  District  need  to  launch  renewable  energy  support 
scheme auctions. An electronic register on issuance, cancellation and trade of guarantees of origin is in 
place  in  the  Republika  Srpska  entity;  the  Federation  entity  is  conducting  procurement  procedures  to 
introduce the same.  

Despite large capacity, there are only three wind parks in place and an increasing number of solar plants. 
Hydropower  planning  is  still  being  carried  out  without  complying  with  the  Espoo  Convention.  Despite 
existing  legal  obligations,  environmental  impact  assessments  are  still  not  consistently  prepared,  which 
lead to protests and court challenges (see Chapter 27 – Environment and climate change). 

On energy efficiency, no progress was made in aligning legislation with EU requirements. Incentives for 
energy efficiency measures must be gender- and class-balanced. 

Bosnia and Herzegovina made no progress on nuclear energy, nuclear safety and radiation protection. 
Bosnia and Herzegovina joined the European radiological data exchange platform (EURDEP) while it is 
yet  to join the  European  Community  urgent  radiological  information  exchange  (ECURIE).  On  nuclear 
safeguards,  upon  EU  accession,  the  existing  systems  of  accountancy  and  control  of  nuclear  materials 
would  need  to  be  adapted  to  accommodate  for  the  safeguard  provisions  (Chapter  7)  of  the  Euratom 
Treaty. 

Chapter 21: Trans-European Networks 

The  EU  promotes  trans-European  networks  (TENs)  in  the  areas  of  transport,  telecommunications  and 
energy to strengthen the internal market and contribute to growth and employment. 

On transport networks, Bosnia and Herzegovina should accelerate the implementation of connectivity 
reform measures and continue adopting multiannual maintenance plans for the entire road and rail core 
networks.  More  efforts  are  required  to  strengthen  mutual  relations  and  cross-border  cooperation  with 
neighbouring countries on border crossing agreements. 

The  revised  Trans-European  transport  network  (TEN-T)  2004  Regulation  establishes  a  new  Western 
Balkans-Eastern  Mediterranean  European  transport  corridor  which  includes  Bosnia  and  Herzegovina. 
Bosnia and Herzegovina should continue with the  development of the planned extension of the TEN-T 
and Trans-European networks for energy (TEN-E) core networks in line with the priorities identified in 
the  economic  and  investment  plan  for  the  Western  Balkans,  the  Green  Agenda  and  the  Transport 
Community’s 5-year rolling work plan. 

77 

 
 
Priority  connectivity  projects  on  the  indicative  maps  of  the  TEN-T  core  network  have  been  planned 
through  the  single  project  pipeline  which  has  not  been  updated  since  2019,  putting  into  question  its 
continued  relevance.  In  relation  to  the  Corridor  Vc  motorway,  while  the  subsection  Pocitelj–  Zvirovici 
was opened in September 2024, the Federation entity still needs to close the financing gap to complete the 
construction  of  the  motorway.  As  regards  the  two  infrastructural  investments  located  in  the  Republika 
Srpska entity (Corridor Vc road and rail), the Commission has taken no decision on the issue yet and will 
assess when the time is ripe to proceed with the signature of the contribution agreements. An agreement is 
still pending with Croatia on the category of the Svilaj border crossing. The border crossing at Gradiška is 
awaiting completion of the access expressway on Croatian territory. 

On rail infrastructure, the main design for railway route 9a Tuzla–Zvornik has been finalised,  as well as 
technical documentation and the tender file for the Visoko–Konjic section of Corridor Vc. Design studies 
for the Doboj–Rasputnica–Miljacka railway section are under preparation. Effort is needed to accelerate 
progress  in  the  rail  core  network  where  investments  continue  to  be  limited.  On  the  navigability  of  the 
Sava river, rehabilitation activities are ongoing, including in the Brčko Port, and demining activities just 
started. 

On energy networks, Bosnia and Herzegovina needs to align with the revised TEN-E Regulation by the 
end  of  2024,  as  per  the  Energy  Community  requirements.  Bosnia  and  Herzegovina  should  finalise  its 
single project pipeline to also include the energy sector. Bosnia and Herzegovina still needs to develop its 
regional electricity connections in line with the Green Agenda for the Western Balkans and  the Central 
and South-Eastern Europe Energy Connectivity (CESEC) action plan on electricity and renewable energy. 

Chapter 27: Environment and climate change 

The EU promotes strong climate action, sustainable development and protection of the environment. EU 
rules  contain  provisions  addressing  climate  change,  water  and  air  quality,  waste  management,  nature 
protection, industrial pollution, chemicals, noise and civil protection. 

Environment 

Horizontal  legislation  is  aligned  with  the  EU  acquis  to  a  limited  extent.  No  progress  was  made  to 
advance  in  this  sector,  including  with  implementing  countrywide  environmental  approximation  and 
environmental  protection  strategies,  aligning  with  horizontal  directives  (on  environmental  impact 
assessment – EIA, strategic environmental assessment  – SEA, environmental liability, infrastructure for 
spatial information  – INSPIRE, and environmental crime), and strengthening access to information and 
public participation in decision-making in line with obligations under the Espoo Convention. Bosnia and 
Herzegovina  should  ensure  the  quality  of  the  preparation  and  implementation  of  environmental 
investments – including  the transparency of procedures, compliance with EIA/SEA and other elements of 
the  horizontal  acquis  –  notably  to  ensure  that  there  is  an  institutional  structure  in  place  to  deliver 
coordinated, strategic planning for environmental investments.  

On  air  quality,  in  December  2023  the  Council  of  Ministers  adopted  a  decision  on  quality  of  liquid 
petroleum  fuels  to  align  with  the  Sulphur  Directive  and  comply  with  Energy  Community  obligations. 
Bosnia  and  Herzegovina  still  needs  to  develop  a  countrywide  strategy  to  combat  air  pollution 
systematically and efficiently. 

Bosnia and Herzegovina still needs to adopt a countrywide strategy for waste management, focusing on 
circular  economy,  the  EU  plastic  strategy  and  the  Directive  on  single-use  plastics.  Bosnia  and 
Herzegovina still needs to align with the Landfill Directive as well as with the acquis on sewage sludge, 
batteries, packaging, polychlorinated biphenyls / polychlorinated terphenyls and end-of-life vehicles. 

On water quality, a consistent and harmonised countrywide strategy and sustainable investment plan on 
water management and urban wastewater management are still missing. Specific plans for implementing 
EU legislation on drinking water, urban wastewater and flood risk management still need to be adopted. 
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Bosnia  and  Herzegovina  still  needs  to  adopt  a  roof  report  on  river  basin  management  plans,  on  flood 
hazards and risks plans, as well as a revised action plan for flood protection and river management. 

On  nature  protection,  the  country  still  needs  to  adopt  the  list  of  potential  Natura  2000  sites  and 
implementing  legislation  and  set  up a  biodiversity monitoring  system.  The  Convention  on  international 
trade in endangered species of wild fauna and flora (CITES) needs to be fully implemented.  Bosnia and 
Herzegovina should prepare legislation to ratify and become a party to the Nagoya Protocol to the 1992 
Convention on biological diversity. 

Regarding  industrial  pollution  control  and  risk  management,  the  pollutants  release  and  transfer 
register  (PRTR)  protocol  to  the  Aarhus  Convention  still  needs  to  be  ratified.  Bosnia  and  Herzegovina 
needs  to  ensure  the  implementation  of  its  national  emissions  reduction  plan  (NERP).  The  country  still 
needs to  align  with the  directives on  industrial  emissions,  eco-labelling  and  eco-management  and  audit 
schemes,  as  well  as  with  the  Seveso  III  Directive  on  the  control  of  major-accident  hazards  involving 
dangerous substances. 

On  chemicals,  the  country  needs  to  ensure  full  alignment  with  EU  Regulations  (on  registration, 
evaluation,  authorisation  and  restriction  of  chemicals  –  REACH,  on  classification,  labelling  and 
packaging  of  substances  and  mixtures  –  CLP,  and  on  biocidal  products  –  BPR),  and  appoint  the 
responsible bodies. Bosnia and Herzegovina still needs to implement the Rotterdam Convention on trade 
of hazardous chemicals, to which it is a party. There has been no progress in acceding to the Minamata 
Convention on mercury. 

Significant further efforts are still needed to align with the EU acquis on environmental noise. 

Bosnia  and  Herzegovina  actively  participates  in  the  Union  Civil  Protection  Mechanism  (UCPM).  The 
country  should  establish  trans-European  services  for  telematics  between  administrations  (TESTA)  as  a 
precondition for connecting to the common emergency communication and information system (CECIS). 
The European single emergency number 112 still needs to be introduced countrywide. In April 2024, the 
Federation  entity  introduced  the  112  number  and  designated  the  Federal  Police  Administration  as  the 
institution in  which the  number  will  be  maintained; the  Republika  Srpska entity  and  the  Brčko  District 
also need to establish the single emergency number. 

Climate change 

Bosnia and Herzegovina still needs to adopt a state-level climate law and a countrywide climate strategy 
along  with  a  2050  climate  neutrality  target  to  align  with  the  EU  climate  acquis.  The  country  should 
implement  commitments  under  the  Energy  Community’s  decarbonisation  roadmap,  starting  with  full 
implementation  of  the  monitoring,  reporting,  verification  and  accreditation  (MRVA)  package  by 
December  2025  with  a  view  to  introduce  carbon  pricing  and  to  align  with  the  EU  ETS.  Bosnia  and 
Herzegovina needs to finalise and adopt its 2021-2030 national energy and climate plan without further 
delays. 

Bosnia  and  Herzegovina  needs  to  step  up  the  implementation  of  its  revised  nationally  determined 
contribution for 2020-2030 (NDC) submitted in 2021 to the United Nations Framework Convention on 
Climate Change (UNFCCC), and submit an updated NDC. No progress has been made in aligning with 
the directives on fuel quality, ozone depleting substances, fluorinated gases, carbon capture and storage or 
on other relevant legislation. Following ratification of the Kigali amendment to the Montreal Protocol on 
substances that  deplete the  ozone  layer  in 2021,  Bosnia and  Herzegovina  is  urgently required  to  freeze 
hydrofluorocarbon production and use, to achieve the aim of an 80% reduction by 2045. 

Consideration also ought to be given to aligning with major upgrades of the EU climate policy as a result 
of  the  Fit  for  55  package.  The  country  still  needs  to  significantly  reinforce  its  administrative  and 
inspection capacities in the  sector  and structural reforms  need to be implemented  to ensure meaningful 
implementation of the required measures. 

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The  country  should  include  a  gender  perspective  and  gender-sensitive  assessments  of  the  impact  of 
climate change in all green policies and laws at all levels of government. 

CLUSTER 5: RESOURCES, AGRICULTURE AND COHESION 

This  cluster  covers:  agriculture  and  rural  development  (Chapter  11);  food  safety,  veterinary  and 
phytosanitary policy (Chapter 12); fisheries and aquaculture (Chapter 13); regional policy & coordination 
of structural instruments (Chapter 22); and financial & budgetary provisions (Chapter 33). 

Chapter 11: Agriculture and rural development 

The  EU’s  common  agricultural  policy  supports  farmers  and  ensures  Europe’s  food  security.  It  helps 
tackle climate change and the sustainable management of national resources; maintains rural areas and 
landscapes  across  the  EU;  and  keeps  the  rural  economy  alive  by promoting  jobs  in  farming,  agri-food 
industries and associated sectors. This requires strong management and control systems. There are also 
common EU rules for marketing standards, quality policy and organic farming. 

On horizontal issues, there was no progress in setting up the administrative structures required for the 
common  agricultural  policy  (CAP),  including  a  paying  agency,  and  in  developing  elements  of  an 
integrated administration and control system (IACS) or a farm sustainability data network (FASDN). The 
country needs to substantially improve the data collection and processing system for planning agricultural 
and rural development policies, and ensure its implementation, monitoring and reporting. In October 2024 
Bosnia and Herzegovina endorsed the ‘Strategic plan for rural development for Bosnia and Herzegovina 
2023-2027  -  framework  document’.  The  country  still  needs  to  develop  a  fully-fledged  multiannual 
country-wide  strategy  on  agriculture  and  rural  development.  Bosnia  and  Herzegovina  still  needs  to 
improve  sector  coordination  and  strengthen  administrative  capacity  at  all  levels  of  government.  The 
country still needs to set up the necessary institutional structures to benefit from the Instrument for Pre-
accession Assistance for Rural Development (IPARD). Bosnia and Herzegovina still needs to put in place 
the  institutional  and  administrative  structure  to  proceed  with  payments  in  line  with  the  EU  acquis  and 
develop farm advisory services. 

As regards the common market organisation (CMO), there was no progress in preparing and setting up 
the regulatory framework in line with the EU acquis. Bosnia and Herzegovina still needs to adopt bylaws 
to implement the state-level Law on the organisation of the market of wine and set up a register of grapes 
and wine producers and a vineyard register.  

Bosnia and Herzegovina made no progress in harmonising rural development programmes and support 
measures.  

No  progress  was  noted  on  quality  policy.  The  country  still  needs  to  improve  and  align  the  legal 
framework with the EU acquis and ensure clarity in the distribution of competences. 

There was no progress on organic farming. The country still needs to adopt a state-level law on organic 
production,  in  line  with  the  EU  acquis,  and  a  regulatory  framework  harmonised  across  all  levels  of 
government. 

Chapter 12: Food safety, veterinary and phytosanitary policy 

EU hygiene rules for foodstuff production ensure a high level of food safety. Animal health and welfare 
and  the  safety  of  food  of  animal  origin  are  safeguarded  together  with  the  quality  of  seeds,  plant 
protection material, the protection against harmful organisms and animal nutrition. 

On general food safety, food safety rules and specific rules for feed, Bosnia and Herzegovina has yet to 
ensure compliance with public and animal health requirements, in particular related to  official controls 
80 

 
 
 
for  the  export  of  beef,  sheep  and  goat  meat  to  the  EU,  and  to  ensure  reliable  certified  animal  health 
statements of the export certificates. A reliable central database for animals and official controls is not yet 
in place, and the surveillance of notifiable diseases is not regularly implemented.  A system of reference 
laboratories  is  still  not  in  place,  and  existing  laboratories  are  still  not  accredited  to  detect  notifiable 
diseases. 

Improving  the  official  controls  system  remains  crucial,  particularly  for  animal  identification  and  the 
registration of holdings to ensure data reliability. Alignment has yet to be ensured for the surveillance of 
notifiable  diseases,  particularly  for  early  detection  system  and  raising  awareness  among  farmers.  The 
inter-laboratory comparative test system is still not set up, nor is the system of reference laboratories for 
food and feed analysis, official controls for hygiene, and animal and plant health. Bosnia and Herzegovina 
has  yet  to  fulfil  the  criteria  for  the  export  of  table  eggs  to  the  EU,  or  fully  implement  its  updated 
Salmonella control plan. 

The alignment with the EU acquis of the state-level laws on food (2004) and veterinary medicine (2002) 
remains low. Further work is still necessary to prepare and adopt state-level laws on official controls, on 
animal health and on animal welfare. Moreover, additional efforts are needed to implement the hygiene 
package. 

On  veterinary  policy,  the  country  has  yet  to  substantially  strengthen  the  control,  prevention  and 
eradication  of  transmissible  animal  diseases,  as  well  as  to  improve  the  monitoring  and  surveillance  of 
brucellosis and rabies, which are not yet eradicated. Further efforts are needed to improve coordination 
for  the  management  of  the  outbreak  of  African  swine  fever.  The  management  of  animal  disease 
notification  and  outbreak  information, and the  central  animal  identification and registration  systems for 
sheep, goats, pigs and horses are yet to be aligned with the EU acquis. 

Regarding the placing on the market of food, feed and animal by-products, Bosnia and Herzegovina 
has yet to align its food and feed control system with the EU acquis. Further reforms are still necessary at 
all levels of the government, particularly concerning inspection services and laboratories. The country has 
not yet prepared a national strategy and set up an effective system for managing animal by-products. 

Concerning phytosanitary policy, the country has yet to adopt key state-level laws, notably the new plant 
health  law  and  a  state-level  law  on  official  controls.  The  adoption  of  programmes  for  surveillance  of 
quarantine pests for all agriculture crops remains important, not only for potatoes which are exported to 
the  EU.  The  country  must  align  its  state  legislation  with  the  EU  acquis  concerning  the  rules  for  the 
authorisation of plant protection products in commercial form and for their placing on the market, use and 
control.  Reforms  are  still  needed  for  Bosnia  and  Herzegovina  to  issue  plant  passports,  to  adopt  OECD 
seed schemes and to set up national reference laboratories providing phyto-sanitary checks. Surveys, early 
detection and eradication of pests must be strengthened. 

On genetically modified organisms (GMOs), the level of alignment with the EU  acquis remains low. 
Inspection  services  at  all  levels  of  the  government  need  to  be  strengthened  and  country’s  reference 
laboratory for testing, controlling and monitoring the presence of GMOs in food and feed is yet to be set 
up. 

Chapter 13: Fisheries and aquaculture 

The common fisheries policy lays down rules on fisheries management, protects living resources of the 
sea and limits the environmental impact of  fisheries. This includes setting catch quotas, managing fleet 
capacity, rules on control and inspection, rules on markets and aquaculture and support for fisheries and 
coastal communities. Further, it promotes a sustainable aquaculture. 

Bosnia  and  Herzegovina  needs  to  develop  a  countrywide  policy  framework  (strategy)  and  a  state-level 
legislation on inland and marine fisheries, and on aquaculture to prepare for the EU’s common fisheries 
policy (CFP).  

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Bosnia  and  Herzegovina  needs  to  substantially  strengthen  its  institutional  capacity  and  administrative 
structures to support small-scale and/or inland fisheries and aquaculture. 

No progress was made on resource and fleet management. Bosnia and Herzegovina still needs to set up 
a fleet register and  a system for management and control of fishing activities in line with the CFP. On 
inspection  and  control,  the  country  still  needs  to  improve  and  harmonise  the  data  on  catches  and 
landings  per  type  of  fishery  and  improve  methodologies  and  planning  for  data  collection.  Bosnia  and 
Herzegovina has yet to align structural and State aid measures with the EU acquis. 

Concerning market policy, Bosnia and Herzegovina still needs to establish most of the provisions of the 
EU acquis on the common market organisation in fishery and aquaculture products, among others setting 
up a framework to recognise producers’ organisations. 

Regarding international agreements, Bosnia and Herzegovina continues to cooperate with the General 
Fisheries Commission for the  Mediterranean (GFCM) as part of the Food and Agriculture Organization 
(FAO), to which it is a cooperating non-contracting party. 

On aquaculture there was no progress in the reporting period. 

Chapter 22: Regional policy and coordination of structural instruments 

Regional policy is the EU’s main tool for reducing regional disparities and investing in sustainable and 
inclusive socio-economic growth. It operates through ‘shared management’ between the Commission and 
EU  Member  States.  The  implementation  of  cohesion  policy  programmes  requires  appropriate 
administrative capacity on programme and project level, the establishment of systems of sound financial 
management and control and also the fulfilment of other EU acquis elements such as environmental or 
public procurement legislation. 

On the legislative framework, in the areas underpinning regional development (See chapters 5, 8, 15, 19, 
27, 32), Bosnia and Herzegovina needs to increase alignment with the EU  acquis and standards, and to 
commit to regional development reforms across the country, including definition of the planning regions 
(e.g.  NUTS)  and  their  powers,  statistical  profile  and  financing.  The  country  needs  to  adopt  a  strategic 
framework to guide the process. 

The institutional framework for the management of EU funds is not yet in place. The country has not 
appointed a national IPA coordinator (NIPAC) for IPA III to steer the programming and the use of the EU 
funds, and to drive reforms under this chapter. There is no countrywide system for regional development. 
The  coordination  mechanism  is  underperforming  due  to  institutional  and  administrative  fragmentation 
and lack of quality statistical and administrative data to support a common strategic vision. 

The administrative capacity for programming and managing EU pre-accession funds remains weak due 
to  delays  in  the  public  administration  reform,  limited  understanding  of  the  EU  regional  and  cohesion 
policy, and lack of permanent training capacity on EU matters. 

On  programming,  Bosnia  and  Herzegovina  prepared  an  IPA  2024  package  which  was  adopted  by  the 
Commission, and developed a Reform Agenda under the Reforms and Growth Facility, which it has not 
submitted yet. Under the mechanism for financing projects of local authorities set up in 2023, in February 
2024 the Federation entity established the legal framework to prepare and select capital investments. The 
Republika Srpska entity needs to finalise the same process. Bosnia and Herzegovina needs to improve the 
planning  of  capital  investments  across  the  country  and  ensure  that  up-to-date  single  project  pipeline 
guides  EU’s  and  domestic  investments  in  a  coherent  way.  Bosnia  and  Herzegovina  continues  to  gain 
experience  in  programming  and  implementation  of  regional  policy  through  participation  in  4  EU 
cooperation  programmes  (INTERREG)  –  the  cross-border,  transnational  and  interregional  programmes 
covering the Adriatic and Ionian region and the Danube region.  

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Regarding  monitoring  and  evaluation,  Bosnia  and  Herzegovina  needs  to  significantly  improve  the 
quality  of  the  monitoring  and  reporting  on  the  use  of  the  EU  funds,  and  to  ensure  a  higher  rate  of 
implementation  of  recommendations  from  the  SAA  process  (now  at  25%)  and  the  IPA  Monitoring 
Committee. 

On the financial management, control and audit system, Bosnia and Herzegovina needs to put in place 
a  roadmap  for  establishing  the  management  and  control  systems  for  the  structural  and  cohesion 
instruments and ensure its implementation. 

Chapter 33: Financial and budgetary provisions 

This chapter covers the rules governing the funding of the EU budget (‘own resources’). These resources 
mainly  consist  of:  (i)  contributions  based  on  the  gross  national  income  of  each  Member  State;  (ii) 
customs  duties;  (iii)  the  non-recycled  plastic  resource  and  (iv)  a  resource  based  on  value-added  tax. 
Member States must have the appropriate administrative capacity to adequately coordinate and ensure 
the correct calculation, collection, payment and control of own resources. 

There was no progress in improving the capacity of the Indirect Tax Authority (ITA) and in implementing 
an accounting system for customs duties to distinguish between recovered debts and outstanding debts, in 
line with the EU’s traditional own resources accounting. The VAT law is yet to be aligned with the EU 
acquis, notably on special schemes and exceptions. 

On the gross national income (GNI) resource, Bosnia and Herzegovina makes use of the definitions and 
accounting  rules  of  ESA  2010  to  compile  its  GNI.  Setting  up  a  countrywide  accounts  system  is  a 
longstanding priority that should be tackled with urgency, notably by adopting a master plan to that aim, 
in line with ESA 2010. 

In  terms  of  administrative  infrastructure,  there  was  no  progress  in  providing  sufficient  human  and 
administrative resources to ensure the full and correct application of EU rules concerning payments into 
the EU budget. Better coordination among administrative structures and implementing rules are needed to 
ensure correct forecasting, calculation, accounting, collection, payment and monitoring of own resources. 

CLUSTER 6: EXTERNAL RELATIONS 

This cluster covers: external relations (Chapter 30); foreign, security and defence policy (Chapter 31). 

Chapter 30: External relations 

The  EU  has  a  common  commercial  policy  towards  third  countries,  based  on  multilateral  and  bilateral 
agreements and autonomous measures. There are also EU rules on humanitarian aid and development 
policy. 

On the common commercial policy, the adoption of a decision on the quality of liquid petroleum fuels in 
February  2024  should  be  conducive  to  the  conclusion  of  negotiations  with  Russia  and  to  Bosnia  and 
Herzegovina’s accession to the WTO. 

Bosnia and Herzegovina needs to urgently implement CEFTA additional protocol 5 on trade facilitation 
and  CEFTA  additional  protocol  6  on  trade  in  services.  Bosnia  and  Herzegovina  should  negotiate  and 
adopt  the  additional  protocol  7  on  dispute  settlement,  thus  contributing  to  implement  the  2021-2024 
Common Regional Market action plan. 

Bosnia and Herzegovina should cease discriminating against EU medicines manufactures and adopt rules 
on defining the lists of essential medicines to ensure transparency and legal clarity regarding procedures 
across the whole country. 

83 

 
 
 
Bosnia  and  Herzegovina  applies  export  controls  on  dual-use  goods  in  accordance  with  its  legislation, 
which needs to be aligned with the latest EU acquis, namely the 2021 Regulation on export controls and 
its annual updates as regards the list of dual-use items.  

As  regards  bilateral  agreements  with  third  countries,  Bosnia  and  Herzegovina  needs  to  further 
strengthen  its  administrative  capacity  and  improve  cooperation  and  coordination  among  all  levels  of 
government  to  ensure  consistency  of  implementation  and  enforcement.  The  country  has  37  bilateral 
investment treaties in force, including with 18 Member States. 

There  was  no  progress  in  the  areas  of  development  policy  and  humanitarian  aid.  The  country  is  a 
recipient  of  aid  programmes  and  has  so  far  provided  humanitarian  aid  only  ad hoc.  Bosnia  and 
Herzegovina  is  encouraged  to  establish  a  legal  framework  covering  international  cooperation  and 
development  policy as  well  as  humanitarian  aid,  in  accordance  with  EU  policies  and  principles,  and to 
build dedicated administrative structures. 

Chapter 31: Foreign, security and defence policy 

Member  States  must  be  able  to  conduct  political  dialogue  under  the  EU  foreign,  security  and  defence 
policy,  align  with  EU  statements,  take  part  in  EU  actions,  and  apply  agreed  sanctions  and  restrictive 
measures. 

The political dialogue between the EU and Bosnia and Herzegovina on foreign and security policy issues 
continued,  including  at  high  level.  In  February  2024,  Bosnia  and  Herzegovina  hosted  the  10th  EU-
Western Balkans meeting of political directors on common foreign and security policy  (CFSP). In June 
2024, the country participated in a working lunch with members of the Foreign Affairs Council. 

The  implementation  of  the  now-expired  2018-2023  foreign  policy  strategy  was  affected  by  frequent 
divergent positions within the Presidency, also in relation to Russia’s war of aggression against Ukraine, 
the Middle East or the UN General Assembly resolutions. The action plan on women, peace and security 
needs to be finalised and adopted. 

Bosnia and Herzegovina still needs to appoint a political director and a European correspondent within 
the Ministry of Foreign Affairs. Rules and practices based on ethnic quotas in appointing the diplomatic 
and  consular  staff  have  a  negative  impact  on  the  capacity  of  the  ministry,  adversely  affecting  the 
country’s foreign policy objectives. 

Bosnia and Herzegovina has reached and maintained full alignment with the EU  common foreign and 
security policy, signalling its clear commitment to the EU path. 

Bosnia and Herzegovina aligned with the EU positions at the United Nations General Assembly (UNGA), 
the  OSCE  and  the  Council  of  Europe  on  Russia’s  war  of  aggression  against  Ukraine,  including  co-
sponsoring a joint statement condemning Russia’s war of aggression against Ukraine at the UN in January 
2024. However, in May 2024, Russia opened a political office of its embassy in Banja Luka, reinforcing 
contacts  with  the  Republika  Srpska  entity.  Since  the  expulsion  of  Russian  diplomats  from  several 
countries  after  the  invasion  of  Ukraine,  the  number  of  Russian  diplomatic  personnel  in  Bosnia  and 
Herzegovina has increased. In June 2024, Bosnia and Herzegovina participated in the Summit on Peace in 
Ukraine hosted by Switzerland. 

Alignment with EU restrictive measures following Russia’s war of aggression against Ukraine remains a 
matter  of  political  contestation  as  one  member  of  the  Presidency  advocates  for  a  neutral  stance.  This 
resulted in significant political hindrances to their implementation by the competent ministries, including 
not  banning  flights  from  Russia  or  the  broadcast  of  Russian  state-sponsored  media.  Bosnia  and 
Herzegovina should continue to strengthen its capacity to implement and enforce international restrictive 
measures,  including  EU  sanctions  it  has  aligned  to,  also  by  setting  up  a  functioning  interdepartmental 
working group. 

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Bosnia and Herzegovina supports all EU measures and instruments for conflict prevention. 

On  non-proliferation,  Bosnia  and  Herzegovina  is  not  yet  a  participating  state  of  multilateral  export 
control  regimes.  In  February  2024,  the  Council  of  Ministers  adopted  a  decision  on  implementation  of 
targeted financial sanctions of the United Nations Security Council related to the financing of terrorism 
and the financing of the proliferation of weapons of mass destruction. Alignment with the EU Common 
Position  2008/944  on  arms  export  control  is  largely  complete,  with  further  work  required  on  end  user 
certificates. Bosnia and Herzegovina is a party to the Arms Trade Treaty, but is still to establish effective 
measures to prevent diversion of arms and ammunition. 

Regarding cooperation with international organisations, Bosnia and Herzegovina is an active member 
of  the  major  international  organisations,  including  the  United  Nations,  the  Council  of  Europe  and  the 
OSCE. Bosnia and Herzegovina has been participating in NATO’s membership action plan since 2019. 

Bosnia and Herzegovina maintains a bilateral immunity agreement with the United States, granting US 
citizens exemptions from the jurisdiction of the International Criminal Court, which does not comply 
with the EU common positions on the integrity of the Rome Statute or related EU guiding principles on 
bilateral immunity agreements. Alignment with the EU position is therefore needed. 

As regards the control of small arms and light weapons (SALW), Bosnia and Herzegovina continued to 
implement the 2018 regional roadmap. The country needs to adopt a new SALW strategy and action plan 
by  the  end  of  the  year.  While  some  progress  was  achieved  by  the  Brčko  District  Police,  Bosnia  and 
Herzegovina  still  needs  to  mark  and  register  all  weapons  of  the  various  security  forces  into  a  single 
registry to ensure adequate traceability. 

In  terms  of  security  measures,  the  country  continued  to  implement  the  agreement  with  the  EU  on 
security procedures for exchanging and protecting classified information. 

Bosnia  and  Herzegovina  does  not  have  an  overall  assessment  or  a  policy  framework  for  addressing 
hybrid  threats  and  remains  vulnerable  to  serious  cyber-attacks  that  targeted  its  public  institutions  in 
2023 and 2024. Banja Luka-based provider M-tel continued to carry the signal of the RT channel, despite 
Bosnia  and  Herzegovina’s  alignment  with  relevant  EU  sanctions  on  Russia.  Bosnia  and  Herzegovina 
needs  to  make  further  efforts  on  closing  space  for  foreign  information  manipulation  and  interference 
(FIMI), including disinformation, taking actions towards building societal resilience against all forms of 
hybrid threats. 

On the common security and defence policy (CSDP), Bosnia and Herzegovina continued to contribute 
to the EU Training Mission (EUTM) in the Central African Republic. Bosnia and Herzegovina is invited 
to  further  step  up  participation  in  CSDP  military  missions  and  operations.  Bosnia  and  Herzegovina 
contributes to regional cooperation in military medicine through the Balkan Medical Task Force (BMTF). 

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ANNEX I – RELATIONS BETWEEN THE EU AND BOSNIA AND HERZEGOVINA 

The Stabilisation and Association Agreement (SAA) entered into force in June 2015. Policy dialogue in 
the joint bodies under the agreement continued. The SA Committee was held in September 2024, closing 
the  seventh  cycle,  although  the  subcommittee  on  trade,  industry,  customs  and  taxations  had  to  be 
cancelled as Bosnia and Herzegovina could not submit a discussion paper. The country also participates 
in  the  economic  and  financial  dialogue  between  the  EU  and  the  Western  Balkans  and  Türkiye;  joint 
recommendations were adopted at ministerial level in May 2024. 

Under  the  SAA  and  its  Interim  Agreement  (which  commenced  application  in  2008)  there  has  been 
progressive  trade  liberalisation  and  mutual  duty-free  access  for  most  goods.  Since  2000,  Bosnia  and 
Herzegovina has also been benefiting from autonomous trade measures. The country joined the Central 
European Free Trade Agreement (CEFTA) in  2007. The EU is Bosnia and Herzegovina’s main trading 
partner, accounting for 64% of its trade in goods (73% of exports and 59% of imports), for a total trade 
volume of EUR 14.6 billion in 2023. 

Bosnia and Herzegovina applied for EU membership in February 2016, and in May 2019 the Commission 
adopted  its  Opinion  setting  out  14  key  priorities  in  the  areas  of  democracy/functionality,  rule  of  law, 
fundamental rights and public administration reform. In December 2022, the European Council granted 
Bosnia and Herzegovina candidate country status on the understanding that a number of steps are taken, 
as  outlined  in  the  October  2022  Commission  recommendation.  In  line  with  the  Commission’s 
recommendation,  in  December  2023  the  European  Council  decided  that  it  will  open  accession 
negotiations with Bosnia and Herzegovina, once the necessary degree of compliance with the membership 
criteria  is  achieved.  Following  the  Commission’s  report  on  progress  in  Bosnia  and  Herzegovina,  the 
European  Council  decided  on  21 March  2024  to  open  accession  negotiations  with  Bosnia  and 
Herzegovina. The European Council invited the Commission to prepare the negotiating framework with a 
view  to  its  adoption  by  the  Council  the  moment  all  relevant  steps  set  out  in  the  Commission’s 
recommendation of October 2022 are taken. 

Visa liberalisation  for citizens of  Bosnia and Herzegovina travelling  to the Schengen area has been in 
force  since  December  2010,  and  a  readmission  agreement  has  been  in  force  since  2008.  The 
Commission’s sixth report under the visa suspension mechanism in October 2023 concluded that Bosnia 
and Herzegovina continues to meet the visa liberalisation benchmarks. 

Bosnia  and  Herzegovina  has  achieved  full  alignment  with  EU  common  foreign  and  security  policy 
(CFSP)  positions  and  declarations.  The  country  continued  to  participate  in  EU  crisis  management 
missions  and  operations  under  the  common  security  and  defence  policy  (CSDP).  The  EU  continued  to 
deploy considerable resources in Bosnia and Herzegovina. The combined  EU Delegation in Bosnia and 
Herzegovina and office of the EU Special Representative continued to be instrumental in communicating 
EU priorities to citizens and in pursuing EU objectives. The EUFOR Althea military operation remained 
deployed in the country, retaining deterrence capacity to support a safe and secure environment. The UN 
Security Council extended EUFOR Althea’s executive mandate until November 2024. 

The  Armed  Forces  of  Bosnia  and  Herzegovina  benefit  from  EUR 20  million  in  assistance  from  the 
European Peace Facility (EPF), which increases their capacity to participate in CSDP military missions 
and  operations.  Their  demining  battalion,  which  is  essential  for  achieving  a  mine-free  Bosnia  and 
Herzegovina,  received  EPF  support  to  purchase  vehicles  and  metal  detectors.  The  Armed  Forces  of 
Bosnia  and  Herzegovina  also  received  EPF  support  in  chemical,  biological,  radiological  and  nuclear 
(CBRN)  protection,  and  take  part  in  the  EUR 6  million  EPF  Balkan  Medical  Task  Force  assistance 
measure. 

The EU is the main donor of financial assistance to Bosnia and Herzegovina, with EUR 539.6 million 
under the Instrument for Pre-accession (IPA) II (2014-2020) and EUR 309.8 million under IPA III 2021-
2024.  The  fundamentals  of  EU  accession  –  good  governance,  rule  of  law  and  human  rights  –  receive 

86 

 
 
43.97%  of  the  IPA  III  assistance,  while  56.03%  target  sustainable  and  inclusive  growth.  EU  assistance 
also includes funding for civil society and co-financing for participation in Union programmes.  

Since  2009,  Bosnia  and  Herzegovina  also  received  EU  assistance  of  EUR 1.104  billion  through  the 
Western  Balkans  Investment  Framework  (WBIF),  leveraging  total  investments  of  EUR 6.7  billion. 
Overall,  under  the  Economic  and  Investment  Plan  (EIP),  Bosnia  and  Herzegovina  benefits  from 
EUR 1 billion  of  IPA  funds,  mobilising  additional  funding  of  EUR 2.9  billion  for  priority  high-impact 
projects.  

Under the new Reform and Growth Facility, Bosnia and Herzegovina may benefit from up to EUR 1.085 
billion  in  loans  and  grants.  Disbursements  will  follow  delivery  on  reforms  as  set  out  in  the  Reform 
Agenda that the country is expected to agree with the European Commission.  

The EU provides support to strengthen Bosnia and Herzegovina’s resilience to hybrid threats, including 
cyber threats and foreign information manipulation and interference (FIMI). 

Bosnia  and  Herzegovina  participates  in  three  cross-border  cooperation  programmes,  as  well  as  in 
transnational cooperation for the Adriatic-Ionian region and the Danube region.  

Bosnia  and  Herzegovina  participates  in  eight  EU  programmes:  Fiscalis  2020,  Customs  2020, 
Competitiveness  of  Enterprises  and  Small  and  Medium-Sized  Enterprises  Programme  (COSME), 
Erasmus+,  Creative  Europe,  Europe  for  Citizens,  Horizon  2020 and  the  Health  Programme  2014-2020. 
To enhance access to EU initiatives and funds, Bosnia and Herzegovina is participating as an observer in 
a pilot project under the Technical Support Instrument. 

87 

 
 
 
 
Note 

Note 

ANNEX 2 – STATISTICAL DATA 

STATISTICAL DATA (as of 5/09/2024) 
Bosnia and Herzegovina 

Basic data 
Population (thousand) 
Total area of the country (km²) 

National accounts 
Gross domestic product (GDP) (million national currency) 
Gross domestic product (GDP) (million euro) 
GDP (euro per capita) 
GDP per capita (in purchasing power standards (PPS)) 
GDP per capita (in PPS), relative to the EU average (EU-27 = 100) 
Real GDP growth rate: change on previous year of GDP volume (%) 
Employment growth (national accounts data), relative to the previous year (%) 
Labour productivity growth: growth in GDP (in volume) per person employed, relative to the 
previous year (%) 
Unit labour cost growth, relative to the previous year (%) 
**3 year change (T/T-3) in the nominal unit labour cost growth index (2015 = 100) 
Labour productivity per person employed: GDP (in PPS) per person employed relative to EU 
average (EU-27 = 100) 
Gross value added by main sectors 
Agriculture, forestry and fisheries (%) 
Industry (%) 
Construction (%) 
Services (%) 
Final consumption expenditure, as a share of GDP (%) 
Gross fixed capital formation, as a share of GDP (%) 
Exports of goods and services, relative to GDP (%) 
Imports of goods and services, relative to GDP (%) 
Gross fixed capital formation by the general government sector, as a percentage of GDP (%) 

Business 
Industrial production volume index (2015 = 100) 
Number of active enterprises (number) 
Birth rate: number of enterprise births in the reference period (t) divided by the number of 
enterprises active in t (%) 

Note 

88 

2011 
3 843 i 
51 209 w 

2018 
3 500 i 
51 209 w 

2019 
3 492 pi 
51 209 w 

2020 
: 
51 209 w 

2021 
: 
51 209 w 

2022 
3 464 pi 
51 209 w 

2011 
26 231 
13 412 
3 490 i 
7 800 
30.0 i 
1.0 
: 
: 

: 
: 
: 

8.0 
21.3 
4.8 
65.8 i 
106.3 
22.0 
32.0 
55.8 
: 

2011 
95.8 w 
: 
: 

2018 
33 942 
17 354 
4 958 i 
10 000 
32.4 i 
3.8 
: 
: 

: 
: 
: 

6.9 
23.8 
4.8 
64.6 i 
93.0 
22.4 
42.0 
56.4 
: 

2019 
35 785 
18 297 
5 240 i 
10 500 
32.7 i 
2.9 
: 
: 

: 
: 
: 

6.5 
22.9 
5.0 
65.6 i 
91.7 
22.7 
40.0 
54.5 
: 

2018 
109.4 w 
68 085 
11.1 p 

2019 
103.5 w 
67 981 
10.4 p 

2020 
34 728 
17 756 
: 
10 100 
32.8 i 
-  3.0 
: 
: 

: 
: 
: 

7.0 
22.8 
5.4 
64.7 i 
92.7 
22.1 
34.6 
47.9 
: 

2020 
96.8 w 
66 873 
: 

2021 
39 145 
20 015 
: 
: 
: 
7.4 
: 
: 

: 
: 
: 

6.0 
24.6 
5.1 
64.3 i 
87.5 
21.5 
42.6 
53.9 
: 

2022 
45 618 
23 324 
6 733 i 
: 
: 
4.2 
: 
: 

: 
: 
: 

5.7 
24.2 
5.2 
64.9 i 
86.1 
22.1 
48.1 
61.9 
: 

2021 
106.2 w 
70 794 pw 
: 

2022 
107.9 w 
: 
: 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Death rate: number of enterprise deaths in the reference period (t) divided by the number of 
enterprises active in t (%) 
People employed in SMEs as a share of all persons employed (within the non-financial 
business economy) (%) 
Value added by SMEs (in the non-financial business economy) (EUR million) 
Total value added (in the non-financial business economy) (EUR million) 

: 

: 

: 
: 

10.3 p 

3.8 p 

: 

: 

69.1 iw 

69.1 iw 

69.6 iw 

69.1 iw 

5 269 iw 
8 393 

5 780 iw 
9 040 

5 677 iw 
8 829 

6 775 iw 
10 689 pw 

: 

: 

: 
: 

Inflation rate 
Consumer price index (CPI), change relative to the previous year (%) 

Balance of payments 
Balance of payments: current account total (million euro) 
Balance of payments current account: trade balance (million euro) 
Balance of payments current account: net services (million euro) 
Balance of payments current account: net balance for primary income (million euro) 
Balance of payments current account: net balance for secondary income (million euro) 
Net balance for primary and secondary income: of which government transfers (million euro) 
**3 year backward moving average of the current account balance relative to GDP (%) 
**Five year change in share of world exports of goods and services (%) 
Net balance (inward - outward) of foreign direct investment (FDI) (million euro) 
Foreign direct investment (FDI) abroad (million euro) 
of which FDI of the reporting economy in the EU-27 countries (million euro) 
Foreign direct investment (FDI) in the reporting economy (million euro) 
of which FDI of the EU-27 countries in the reporting economy (million euro) 
**Net international investment position, relative to GDP (%) 
Year on year rate of change in gross inflow of remittances (in national currency) from migrant 
workers (%) 

Public finance 
General government deficit / surplus, relative to GDP (%) 
General government gross debt relative to GDP (%) 
Total  government revenues, as a percentage of GDP (%) 
Total government expenditure, as a percentage of GDP (%) 

Note 
1) 

Note 

2) 
2) 3) 
4) 
2) 3) 
4) 
3) 
3) 

Note 

2011 
3.7 w 

2018 
1.4 w 

2019 
0.6 w 

2020 
-  1.1 w 

2021 
2.0 w 

2022 
14.0 w 

2011 
- 1 269.8 
- 4 001.9 
814.6 
107.6 
1 809.8 
45.1 
: 
: 
344.6 w 
-  4.1 w 
: 
340.4 w 
193.6 w 
-  56.2 w 
7.7 iw 

2011 
: 
: 
: 
: 

2018 
-  559.3 
- 3 845.5 
1 335.6 
-  99.6 
2 050.2 
15.1 
-  4.2 
30.5 
491.0 w 
16.4 w 
-  14.4 w 
507.4 w 
290.8 w 
-  41.5 w 
8.4 i 

2018 
: 
: 
: 
: 

2019 
-  474.1 
- 4 071.4 
1 430.2 
-  30.8 
2 198.0 
49.1 
-  3.5 
25.0 
377.8 w 
19.7 w 
-  26.1 w 
397.4 w 
207.7 w 
-  36.8 w 
8.4 i 

2019 
: 
: 
: 
: 

2020 
-  501.3 
- 3 204.5 
836.3 
-  98.4 
1 965.3 
66.7 
-  2.9 
15.2 
357.4 w 
70.5 w 
32.1 w 
427.9 w 
267.7 w 
-  33.5 w 
7.3 i 

2020 
: 
: 
: 
: 

2021 
-  355.2 
- 3 666.0 
1 396.5 
-  254.5 
2 168.9 
32.4 
-  2.4 
21.4 
539.0 w 
71.3 w 
32.2 w 
610.3 w 
238.0 w 
-  28.9 w 
7.8 i 

2021 
: 
: 
: 
: 

2022 
- 1 011.2 
- 5 206.6 
1 997.7 
-  269.8 
2 467.5 
30.6 
-  3.0 
16.5 
688.7 w 
65.6 w 
16.0 w 
754.3 w 
371.5 w 
-  25.8 w 
7.9 i 

2022 
: 
: 
: 
: 

Financial indicators 
Gross external debt of the whole economy, relative to GDP (%) 
Gross external debt of the whole economy, relative to total exports (%) 
Money supply: M1 (banknotes, coins, overnight deposits, million euro) 
Total credit by monetary financial institutions to residents (consolidated) (million euro) 

Note 
3) 
3) 
5) 6) 
7) 8) 

2011 
71.2 iw 
222.3 w 
3 162.6 w 
7 619.2 w 

2018 
64.6 iw 
153.9 w 
6 209.7 w 
9 962.9 w 

2019 
62.5 iw 
156.2 w 
6 775.2 w 
10 620.9 w 

2020 
63.3 iw 
182.9 w 
7 697.6 w 
10 403.5 w 

2021 
57.2 iw 
134.4 w 
9 166.2 w 
10 776.7 w 

2022 
51.4 iw 
106.7 w 
10 163.8 w 
11 283.2 w 

89 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
**Annual change in financial sector liabilities (%) 

**Private debt, consolidated, relative to GDP (%) 
Interest rates: day-to-day money rate, per annum (%) 
Euro exchange rates: average of period (1 euro = … national currency) 
Trade-weighted effective exchange rate index, 42 countries (2015 = 100) 
**3 year change (T/T-3) in the trade-weighted effective exchange rate index, 42 countries 
(2015 = 100) 
Value of reserve assets (including gold) (million euro) 

External trade in goods 
Value of imports: all goods, all partners (million euro) 
Value of exports: all goods, all partners (million euro) 
Trade balance: all goods, all partners (million euro) 
Terms of trade (export price index / import price index * 100) (number) 
Share of exports to EU-27 countries in value of total exports (%) 
Share of imports from EU-27 countries in value of total imports (%) 

Demography 
Crude rate of natural change of population (natural growth rate): number of births minus 
deaths (per thousand inhabitants) 
Infant mortality rate deaths of children under one year of age (per thousand live births) 
Life expectancy at birth: male (years) 
Life expectancy at birth: female (years) 

Labour market 
Economic activity rate for persons aged 20–64: proportion of the population aged 20–64 that 
is economically active (%) 
*Employment rate for persons aged 20–64: proportion of the population aged 20–64 that are 
in employment (%) 
Male employment rate for persons aged 20–64 (%) 
Female employment rate for persons aged 20–64 (%) 
Employment rate for persons aged 55–64: proportion of the population aged 55–64 that are 
in employment (%) 
Employment by main sectors 
Agriculture, forestry and fisheries (%) 
Industry (%) 
Construction (%) 
Services (%) 

9) 
10) 
9) 
11) 

5) 
5) 

Note 

12) 

Note 

Note 
13) 

13) 

13) 
13) 

13) 

13) 
13) 
13) 

13) 

1.3 w 

9.1 w 

8.0 w 

3.7 w 

9.9 w 

2.5 w 

60 w 
 w 
1.956 
98.3 w 
0.0 iw 

58 w 
 w 
1.956 
103.4 w 
0.0 iw 

59 w 
 w 
1.956 
104.1 w 
0.0 iw 

59 w 
 w 
1.956 
106.2 w 
0.0 iw 

: 
 w 
1.956 
107.6 w 
0.0 iw 

: 
 w 
1.956 
109.2 w 
0.0 iw 

-  16.9 

569.4 

478.0 

637.1 

1 377.8 

72.8 

2011 
7 938 
4 204 
- 3 735 
92.1 iw 
70.0 iw 
59.1 iw 

2011 
-  0.9 

: 
: 
: 

2018 
9 855 
6 085 
- 3 770 
102.7 iw 
72.2 iw 
59.7 iw 

2018 
-  2.4 p 

: 
: 
: 

2019 
9 969 
5 876 
- 4 093 
102.3 iw 
72.3 iw 
61.1 iw 

2020 
8 634 
5 379 
- 3 254 
105.6 iw 
72.4 iw 
60.8 iw 

2021 
11 042 
7 298 
- 3 744 
104.4 iw 
72.8 iw 
58.9 iw 

2019 
: 

2020 
: 

2021 
: 

: 
: 
: 

: 
: 
: 

: 
: 
: 

2011 
58.3 w 

2018 
58.4 w 

2019 
59.0 w 

2020 
62.3 bw 

2021 
63.4 b 

42.5 w 

47.7 w 

49.7 w 

52.5 bw 

52.6 b 

53.7 w 
31.4 w 
27.0 w 

: 
: 
: 
: 

59.5 w 
35.8 w 
32.6 w 

15.7 w 
23.5 w 
8.7 w 
52.1 w 

61.6 w 
38.0 w 
36.2 w 

18.0 w 
23.8 w 
7.9 w 
50.3 w 

64.9 bw 
40.0 bw 
35.4 bw 

12.0 bw 
23.9 bw 
9.5 bw 
54.7 bw 

66.0 b 
39.1 b 
35.6 b 

9.4 bi 
24.4 bi 
9.1 bi 
57.0 bi 

2022 
14 641 
9 190 
- 5 451 
98.5 iw 
73.6 iw 
56.9 iw 

2022 
-  4.2 p 

: 
: 
: 

2022 
63.6 

53.9 

67.7 
40.0 
36.3 

7.3 i 
25.4 i 
9.2 i 
58.2 i 

90 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
13) 
14) 
15) 
13) 
14) 
15) 
13) 
13) 
13) 
13) 
13) 

People employed in the public sector as a share of total employment, persons aged 20–64 
(%) 

People employed in the private sector as a share of total employment, persons aged 20–64 
(%) 

Unemployment rate: proportion of the labour force that is unemployed (%) 
Male unemployment rate (%) 
Female unemployment rate (%) 
Youth unemployment rate: proportion of the labour force aged 15–24 that is unemployed (%) 
Long-term unemployment rate: proportion of the labour force that has been unemployed for 
12 months or more (%) 
Unemployment rate for persons (aged 25–64) having completed at most lower secondary 
education (ISCED levels 0-2) (%) 
Unemployment rate for persons (aged 25–64) having completed tertiary education (ISCED 
levels 5-8) (%) 

Social cohesion 
Average nominal monthly wages and salaries (national currency) 
Index of real wages and salaries (index of nominal wages and salaries divided by the 
inflation index) (2016 = 100) 
GINI coefficient 
Poverty gap 
*Early leavers from education and training: proportion of the population aged 18–24 with at 
most lower secondary education who are not in further education or training (%) 

Standard of living 
Number of passenger cars relative to population size (number per thousand population) 
Number of mobile phone subscriptions relative to population size (number per thousand 
population) 
Mobile broadband penetration (per 100 inhabitants) 
Fixed broadband penetration (per 100 inhabitants) 

Infrastructure 
Density of railway network (lines in operation per thousand km²) 

Length of motorways (kilometres) 

Education, innovation and research 
Public expenditure on education relative to GDP (%) 
*Gross domestic expenditure on R&D relative to GDP (%) 

91 

15.4 
12.6 
19.8 
35.1 
11.4 

25.1 

10.7 

2022 
1 122 w 
: 

: 
: 
3.6 

19.6 w 

18.4 w 

17.2 w 

19.1 bw 

19.8 bw 

19.0 w 

80.4 w 

81.6 w 

82.8 w 

80.9 bw 

80.2 bw 

81.0 w 

27.6 w 
26.1 w 
30.0 w 
57.9 w 
22.3 w 

18.5 w 
17.3 w 
20.5 w 
38.8 w 
15.2 w 

15.9 w 
13.8 w 
19.0 w 
33.8 w 
12.1 w 

15.9 bw 
14.2 bw 
18.6 bw 
36.6 bw 
11.9 bw 

17.4 b 
14.4 b 
22.0 b 
38.3 b 
13.4 

13) 

29.1 w 

19.1 w 

: 

19.5 bw 

24.7 b 

13) 

13.5 w 

13.9 w 

10.9 w 

10.9 bw 

11.3 b 

Note 
16) 

17) 

13) 

Note 

Note 

Note 

2011 
816 w 
: 

33 w 
: 
8.0 w 

2011 
192.0 
825.8 ew 

: 
: 

2011 
20.1 iw 

35 w 

2011 
: 
: 

2018 
879 w 
: 

: 
: 
5.4 w 

2018 
263.0 p 
989.9 w 

52.7 w 
20 w 

2018 
19.9 iw 

198 

2018 
3.9 iw 
0.19 iw 

2019 
921 w 
: 

: 
: 
3.8 w 

2020 
956 w 
: 

: 
: 
4.7 w 

2021 
998 w 
: 

: 
: 
4.7 

2019 
269.0 pi 
1 075.5 w 

2020 
268.0 pi 
1 010.0 w 

2021 
284.0 p 
1 095.5 ew 

2022 
292.0 p 
1 110.1 w 

44.7 w 
21 w 

2019 
19.9 iw 

198 

2019 
4.0 iw 
0.19 

46.7 w 
22 w 

2020 
19.9 iw 

218 

2020 
4.3 iw 
0.20 

52.6 ew 
23 ew 

2021 
19.9 iw 

218 

2021 
4.2 iw 
0.19 

60.6 w 
26 w 

2022 
19.9 iw 

231 

2022 
: 
: 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Government budget appropriations or outlays on R&D (GBAORD), as a percentage of GDP 
(%) 
Percentage of households who have internet access at home (%) 

Environment 
*Index of greenhouse gas emissions,  CO2 equivalent (1990 = 100) 
Energy intensity of the economy (kg of oil equivalent per 1 000 euro GDP at 2015 constant 
prices) 
Electricity generated from renewable sources relative to gross electricity consumption (%) 
Road share of inland freight transport (based on tonne-km) (%) 

Energy 
Primary production of all energy products (thousand TOE) 
Primary production of crude oil (thousand TOE) 
Primary production of solid fuels (thousand TOE) 
Primary production of gas (thousand TOE) 
Net imports of all energy products (thousand TOE) 
Gross inland energy consumption (thousand TOE) 
Gross electricity generation (GWh) 

Agriculture 
Agricultural production volume index of goods and services (at producer prices) (2015 = 100) 
Utilised agricultural area (thousand hectares) 
Livestock numbers: live bovine animals (thousand heads, end of period) 
Livestock numbers: live swine (thousand heads, end of period) 
Livestock numbers: live sheep and live goats (thousand heads, end of period) 
Raw milk available on farms (thousand tonnes) 
Harvested crop production: cereals (including rice) (thousand tonnes) 
Harvested crop production: sugar beet (thousand tonnes) 
Harvested crop production: vegetables (thousand tonnes) 

Source: Eurostat and/or the statistical authorities in Bosnia and Herzegovina 

Note 

18) 

Note 

Note 

: 

: 

2011 
82.5 w 
: 

31.8 w 
64.0 w 

2011 
: 
: 
: 
: 
: 
: 
: 

0.06 

69.2 

2018 
82.9 w 
456.8 

41.5 
78.7 w 

2018 
5 672 
0 
3 659 
0 
1 814 i 
7 478 
19 160 

0.09 

72.0 

2019 
82.8 w 
429.3 

45.5 
77.4 w 

2019 
5 405 
0 
3 403 
0 
1 979 i 
7 230 
17 493 

0.09 

72.8 

2020 
74.7 w 
435.2 

49.3 
78.8 w 

2020 
5 237 
0 
3 329 
0 
1 805 i 
7 108 
16 874 

0.18 p 

75.5 

2021 
76.3 w 
420.4 

46.3 
78.8 w 

2021 
5 223 
0 
3 121 
0 
2 002 i 
7 374 
18 536 

: 

: 

2022 
: 
399.8 

: 
78.4 w 

2022 
5 313 
0 
3 348 
0 
1 921 i 
7 310 
16 381 

2011 
: 
1 731.9 e 
455.0 e 
577.0 
1 086.0 i 
: 
1 131.3 e 
0.0 
276.2 e 

2018 
: 
1 779.6 e 
438.0 
542.0 e 
1 085.0 i 
: 
1 764.1 e 
0.0 
298.7 e 

2019 
: 
1 806.3 e 
430.0 e 
543.0 e 
1 085.0 i 
: 
1 685.6 e 
0.0 
298.8 e 

2020 
: 
1 845.6 e 
427.0 e 
547.0 e 
1 085.0 i 
: 
1 966.8 e 
0.0 
323.7 e 

2021 
: 
1 865.8 e 
339.5 
569.6 
1 083.2 i 
: 
1 425.1 e 
0.0 
292.7 e 

2022 
: 
1 116.7 b 
339.2 
471.6 
1 041.6 i 
: 
1 173.7 b 
0.0 
238.2 b 

: = not available 
b = break in series 
e = estimated value 
n =  not significant value 
p = provisional 
i = Eurostat estimate 

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w= data supplied by and under the responsibility of the national statistical authority and published on an "as is" basis and 
without any assurance as regards their quality and adherence to EU statistical methodology 
* = Europe 2020 indicator 
** = Macroeconomic Imbalance Procedure (MIP) indicator 

Footnotes: 

1)  Consumer price inflation 
2)  Based on IMF balance of payments manual, Asset - Liability Approach 
3)  Based on IMF balance of payments manual, sixth edition. 
4)  Based on IMF balance of payments manual, sixth edition and OECD Benchmark Definition of Foreign Direct Investment - 4th 

edition 

5)  Revision: NEER base period 2015=100 
6)  M1 money supply comprises cash outside banks and transferable deposit in domestic currency of all domestic sectors 

(except central government deposits). 

7)  Based on IMF monetary and financial statistics manual, 2000. 
8) 

In accordance with the Decision on Credit Risk Management and Determination of Expected Credit Losses, from supervisory 
body, since January 1, 2020, commercial banks have re-recorded some of the bank's balance sheet receivables on of 
balance sheet records, which caused a decrease in loan of approximately 400 millions KM in private enterprises and 
household sectors. 

9)  Data for monetary financial institutions. 

10) 

Includes data for the central bank and other banks for the end of December 2022, while data for other financial institutions 
are given for the end of September 2022. 

11)  Money market is not yet  established in Bosnia and Herzegovina. 
12)  Paasche export and import unit value indices 
13)  Up to (and including) year 2020, the public sector comprises NACE Rev. 1.1 Sections L, M and N; from year 2022 onwards, 
the public sector includes NACE Rev. 2 Sections O, P and Q. The private sector comprises the other NACE Sections, 
respectively. 

14)  The public sector includes NACE Rev. 2 Sections O, P and Q while the private sector includes other NACE Sections. 
15)  From January 2021, the Agency for Statistics of Bosnia and Herzegovina began to apply the new, redesigned methodology 

of the Labour Force Survey. The redesign of the survey took place on the basis of and in accordance with the new 
Regulation of the European Parliament and the Council, which entered into force on 1 January 2021. With the introduction of 
the new, redesigned methodology of the Labour Force Survey from January 2021, the series of data published in the 
previous year was interrupted. 

16)  Net earnings. 
17)  Total household consumption expenditure (rather than income) is used for the calculation. 
18)  Data not collected on inland waterways. Road share of inland freight transport based on road and rail transport. 

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