Proposal for a COUNCIL DECISION on the position to be taken on behalf of the European Union in the Committee of the Parties to the Council of Europe Convention on preventing and combating violence against women and domestic violence, at its 19th meeting, on the recommendations and conclusions addressed to certain Parties on their implementation of that Convention, with regard to matters related to institutions and public administration of the Union
Date: 2025-11-19
Institutions: Directorate-General for Justice and Consumers, European Commission
Subjects: EU institution, European convention, gender equality, help for victims, joint body (EU), public administration, recommendation, sexual violence, violence, women's rights

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   EUROPEAN COMMISSION  Brussels, 19.11.2025  COM(2025) 713 final 2025/0367 (NLE)  Proposal for a COUNCIL DECISION on the position to be taken on behalf of the European Union in the Committee of the Parties to the Council of Europe Convention on preventing and combating violence against women and domestic violence, at its 19th meeting,  on the recommendations and conclusions addressed to certain Parties on their implementation of that Convention, with regard to matters related to institutions and public administration of the Union   
 
EXPLANATORY MEMORANDUM 

1. 

SUBJECT MATTER OF THE PROPOSAL 

This  proposal  concerns  the  decision  establishing  the  position  to  be  taken  on  the  Union’s 
behalf  at  the  19th  meeting  of  Committee  of  the  Parties  (‘CoP’  or  ‘the  Committee’)  of  the 
Council  of  Europe  Convention  on  preventing  and  combating  violence  against  women  and 
domestic violence (the ‘Istanbul Convention’ or the ‘Convention’) on 11 December 2025, in 
connection  with  the  envisaged  adoption  of  eight  draft  recommendations  and  one  draft 
conclusion addressed to nine State Parties on their implementation of the Convention.2 

2. 

CONTEXT OF THE PROPOSAL 

2.1. 

The Istanbul Convention 

The Istanbul Convention lays down a comprehensive and harmonised set of rules to prevent 
and  combat  violence  against  women  and  domestic  violence  in  Europe  and  beyond.  The 
Convention entered into force on 1 August 2014. 

The EU signed the Convention on June 2017 and completed the accession procedure with the 
deposit of two instruments of approval on 28 June 2023, triggering the entry into force of the 
Convention for the EU on 1 October 2023. The EU has acceded to the Convention as regards 
matters  falling  within  its  exclusive  competence,  namely  with  regard  to  matters  related  to 
institutions  and  public  administration  of  the  Union 1  and  with  regard  to  matters  related  to 
judicial  cooperation  in  criminal  matters,  asylum  and  non-refoulement 2.  All  EU  Member 
States have signed the Convention and 22 have ratified it 3.  

The Committee of the Parties 

2.2. 
The CoP 4 is  composed of the representatives of the Parties to  the Convention. Parties must 
endeavour  to  nominate,  as  their  representatives,  experts  of  the  highest  possible  rank  in  the 
field of preventing and combating violence against women and domestic violence 5. The tasks 
entrusted to the CoP are listed in Rule 1 of its Rules of Procedure 6. On 1 October 2023, the 
EU became a Party to the Convention and, as such, a member of the CoP (Article 67(1) of the 
Convention). 

1 
Council Decision (EU) 2023/1075 of 1 June 2023 on the conclusion, on behalf of the European Union, 
of  the  Council  of  Europe  Convention  on  preventing  and  combating  violence  against  women  and  domestic 
violence  with  regard  to  institutions  and  public  administration  of  the  Union,  OJ L 143 I,  2.6.2023,  p. 1, 
ELI: http://data.europa.eu/eli/dec/2023/1075/oj. 
2 
Council Decision (EU) 2023/1076 of 1 June 2023 on the conclusion, on behalf of the European Union, 
of  the  Council  of  Europe  Convention  on  preventing  and  combating  violence  against  women  and  domestic 
violence with regard to matters related to judicial cooperation in criminal matters, asylum and non-refoulement, 
OJ L 143 I, 2.6.2023, p. 4, ELI: http://data.europa.eu/eli/dec/2023/1076/oj. 
3 
Status  of  ratifications  on  12  November  2025:    AT  (2013);  BE  (2016);  CY  (2017);  DE  (2017);  DK 
(2014); IE (2019); EL (2018); ES (2014); EE (2017) FI (2015); FR (2014); HR (2018); IT (2013); LU (2018); 
MT (2014); NL (2015); PL (2015); PT (2013); RO (2016); SI (2015); SV (2014), LV (2023). 
4 
violence (coe.int) 
5 
6 

Rule 2.1.b of the Rules of Procedures of the Committee of the Parties. 
Document IC-CP(2015)2, adopted on 4 May 2015. 

Committee of the Parties  - Istanbul Convention Action against violence against women and domestic 

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2.3. 

The monitoring mechanism of the Istanbul Convention 

The  Istanbul  Convention  establishes  a  monitoring  mechanism  to  ensure  its  effective 
implementation  by  the  Parties 7.  The  purpose  is  to  assess  how  the  Convention  is  put  into 
practice  and  to  provide  guidance  to  the  Parties.  The  monitoring  mechanism  consists  of  two 
distinct but interacting bodies: an independent expert body (the Group of Experts on Action 
against Violence against Women and Domestic Violence (‘GREVIO’)); and the CoP. 

GREVIO  is  an  independent  group  of  experts  tasked  with  monitoring  the  Convention’s 
implementation  on  a  country-by-country  basis,  in  accordance  with  Article 66(1)  of  the 
Convention.  The  monitoring  procedure  is  set  out  in  Article 68  of  the  Convention.  In 
accordance with Article 68(1) of the Convention, new Parties are required to submit a report 
(based  on  a  questionnaire  prepared  by  GREVIO)  that  details  the  legislative  and  other 
measures  they  have  taken  to  give  effect  to  the  Convention.  GREVIO  prepares  a  report  on 
those  measures  taken  by  that  Party  concerned  to  implement  the  Convention,  and  makes 
suggestions  and  proposals  on  how  that  Party  may  deal  with  problems  that  have  been 
identified 8. 

The  CoP,  based  on  GREVIO’s  report  and  in  accordance  with  Article 68(12)  of  the 
Convention,  may  adopt  recommendations  addressed  to  the  Party  concerned  on  the 
implementation  of  the  Convention  and  set  a  deadline  for  the  Party  to  submit  a  response  on 
their  implementation  of  the  recommendations.  Based  on  this  provision,  the  CoP  has  been 
adopting recommendations to Parties which differentiate between actions that should be taken 
as soon as possible with a requirement to report back within a three-year period,  and actions 
that while important do not carry the same level of immediacy. At the end of the three-year 
period,  the  Party  must  report  back  to  the  CoP  on  the  progress  made  in  implementing  the 
recommendations  that  were  addressed  to  it.  On  the  basis  of  this  information  and  any 
additional  information  obtained,  the  Secretariat  of  the  Committee 9  prepares  conclusions  on 
the implementation of the recommendations in relation to each Party under review, which the 
CoP adopts. 

As  the  baseline  evaluation  procedure  has  been  completed  for  nearly  all  Parties,  GREVIO 
decided in  late 2022 to  move to  the next  phase  in  its evaluation.  Under  Article 68(3) of the 
Convention,  GREVIO’s  evaluation  procedures  following  the  baseline  evaluation  shall  be 
divided  into  rounds  (‘thematic  evaluation  rounds’).  The  first  thematic  evaluation  round  is 
entitled ‘Building Trust by Delivering Support, Protection and Justice’ which runs from 2023 
to 2031. While the baseline evaluation covered around 60 articles of the Istanbul Convention, 
the new thematic evaluation procedure addresses 20 articles, namely Articles 3, 7, 8, 11, 12, 
14, 15, 16, 18, 20, 22, 25, 31, 48, 49, 50, 51, 52, 53 and 56. These articles set out standards for 
law  enforcement  agencies,  criminal  justice  actors,  the  provision  of  general  and  specialist 
support services for victims, and an overall victim-centred approach. The aim is to provide a 
more in-depth assessment of these areas, focusing on the progress made under each article.  
In paragraph 305 of its Opinion 1/19 of 6 October 2021, Istanbul Convention 10, the Court of 
Justice of the European Union has confirmed that a significant part of the obligations of the 
Convention are, in essence, binding on the Union as regards the staff in its administration and 

7 
Article 1(2) of the Istanbul Convention. 
8 
Article 68(10) of the Istanbul Convention. 
9 
The  applicable  procedure  for  supervising  the  implementation  and  the  reporting  is  defined  in  the 
Framework  for  supervising  the  implementation  of  the  recommendations  addressed  to  state  parties,  which  the 
CoP adopted on 13 April 2021, IC-CP/Inf(2021)2. 
10 

Opinion of the Court of Justice 1/19 of 6 October 2021, Istanbul Convention, EU:C:2021:832. 

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as  regards  the  member  of  the  public  visiting  the  premises  and  buildings  of  its  institutions, 
agencies  and bodies. As regards the  20 specific  provisions that the first  thematic evaluation 
round covers, the Court has confirmed that 17 of those provisions also apply with regard to 
the  Union  and  its  own  public  administration,  namely  all  of  the  above-mentioned  provisions 
except Articles 3, 31 and 48 of the Convention. At the same time, the extent of the Union’s 
obligations should be interpreted bearing in mind its specific nature and powers. In particular, 
since  the  EU’s  public  administration  is  not  endowed  with  law  enforcement  powers, 
recommendations  relating  to  matters  of  law  enforcement,  such  as  the  issue  of  emergency 
barring orders, should be interpreted as requiring to ensure the safety of the victim within the 
limits of its powers, for example by refusing alleged perpetrators access to the premises of the 
institutions. 

At its meeting in December 2024, the CoP adopted a Decision on the recommendations to be 
adopted by the Committee of the Parties in light of GREVIO’s reports adopted as part of its 
first thematic round of evaluation 11.  

To  date,  the  CoP’s  practice  has  been  to  adopt  recommendations  and  conclusions  based  on 
consensus  at  its  meetings  which  take  place  upon  request  12  by  one  third  of  the  Parties,  the 
President of the Committee or the Secretary General, usually twice a year. 

2.4. 

The envisaged acts of the Committee of the Parties 

On 11 December 2025, during its 19th meeting, it is foreseen that the CoP will proceed with 
the adoption of eight draft recommendations (one based on the baseline evaluation procedure 
and  seven  based  on  the  first  thematic  evaluation  round)  as  well  as  one  conclusion 
(respectively  the  ‘draft  recommendations’  and  the  ‘draft  conclusions’,  and  jointly  the 
‘envisaged acts’): 

(1)  Recommendation  on  the  implementation  of  the  Istanbul  Convention  by  the 

United Kingdom, contained in document IC-CP(2025)22prov; 

(2)  Recommendations  on  building  trust  by  delivering  support,  protection  and 
justice  on  the  basis  of  the  Istanbul  Convention  by  Andorra,  contained  in 
document IC-CP(2025)23prov; 

(3)  Recommendations  on  building  trust  by  delivering  support,  protection  and 
justice  on  the  basis  of  the  Istanbul  Convention  by  Belgium,  contained  in 
document IC-CP(2025)24revprov; 

(4)  Recommendations  on  building  trust  by  delivering  support,  protection  and 
justice  on  the  basis  of  the  Istanbul  Convention  by  France,  contained  in 
document  IC-CP(2025)25prov; 

(5)  Recommendations  on  building  trust  by  delivering  support,  protection  and 
justice on the basis of the Istanbul Convention by Italy, contained in document  
IC-CP(2025)26prov; 

(6)  Recommendations  on  building  trust  by  delivering  support,  protection  and 
justice on the basis of the Istanbul Convention by the Netherlands, contained in 
document  IC-CP(2025)27prov; 

11 
12 

Contained in document IC-CP(2024)10 rev 
Article 67(2) of the Convention. 

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(7)  Recommendations  on  building  trust  by  delivering  support,  protection  and 
Istanbul  Convention  by  Portugal 

the  basis  of 

the 

justice  on 
[IC-CP(2025)28prov]; 

(8)  Recommendations  on  building  trust  by  delivering  support,  protection  and 
justice  on  the  basis  of  the  Istanbul  Convention  by  Serbia,  contained  in 
document  IC-CP(2025)29prov; and 

(9)  Conclusions  on  the  implementation  of  recommendations  in  respect  of  Poland 
in  document 

the  Parties,  contained 

the  Committee  of 

adopted  by 
IC-CP(2025)30prov.  

3. 

POSITION TO BE TAKEN ON THE UNION’S BEHALF 

The envisaged acts are addressed to nine Parties and include recommendations (based on the 
baseline  evaluation  procedure  and  the  first  thematic  evaluation  round)  on  measures  to  be 
taken  on  eight  Parties’  implementation  of  the  Convention  as  well  as  conclusions  on  one 
Party’s  implementation  of  previous  recommendations.  They  concern  the  implementation  of 
the Convention’s provisions by relevant institutions and the public administration. The Union 
has acceded to the Convention insofar as it applies to its institutions and public administration 
and has exclusive competence to accept obligations set out in the Convention with regard to 
its own institutions and public administration, within the scope of Article 336 of the Treaty on 
the  Functioning  of  the  European  Union  (TFEU).  It  is  therefore  appropriate  to  establish  the 
position to be taken on the  Union’s behalf in  the CoP with  regard to  institutions and public 
administration  of  the  Union,  as  the  envisaged  acts  are  capable  of  decisively  influencing  the 
content of Union law in that they may affect  the  interpretation  of relevant  provisions of the 
Convention in the future. 

The  draft  recommendations  and  the  draft  conclusions  on  matters  falling  within  the 
competence of the Union with regard to its own institutions and public administration are in 
line  with  the  Union’s  policies  and  objectives  and  do  not  raise  any  concerns  with  respect  to 
Union law. It is therefore proposed that the Union does not object to the adoption of the draft 
recommendations and conclusions at the 19th meeting of the CoP. 

4. 

LEGAL BASIS 

4.1. 

Procedural legal basis 

4.1.1.  Principles 

Article 218(9) of the Treaty on the Functioning of the European Union (TFEU) provides for 
decisions establishing ‘the positions to be adopted on the Union’s behalf in a body set up by 
an  agreement,  when  that  body  is  called  upon  to  adopt  acts  having  legal  effects,  with  the 
exception of acts supplementing or amending the institutional framework of the agreement.’ 

The concept of ‘acts having legal effects’ includes acts that have legal effects by virtue of the 
rules of international law governing the body in question. It also includes instruments that do 
not  have  a  binding  effect  under  international  law  but  that  are  ‘capable  of  decisively 
influencing the content of the legislation adopted by the EU legislature’ 13. 

13 
ECLI:EU:C:2014:2258, paragraphs 61 to 64. 

Judgment  of 

the  Court  of  Justice  of  7 October  2014,  Germany  v  Council,  C-399/12, 

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4.1.2.  Application to the present case 

The CoP is a body set up by the Istanbul Convention. The envisaged acts which the CoP is 
called  upon  to  adopt  constitute  acts  having  legal  effects.  The  envisaged  acts  are  capable  of 
decisively influencing the content of Union law, because they may affect the interpretation of 
the  relevant  provisions  of  the  Istanbul  Convention  in  the  future.  Therefore,  the  procedural 
legal basis for the proposed decision is Article 218(9) TFEU. 

4.2. 

Substantive legal basis 

4.2.1.  Principles 

The  substantive  legal  basis  for  a  decision  under  Article 218(9)  TFEU  depends  primarily  on 
the objective and content of the envisaged act in respect of which a position is taken on the 
Union’s behalf. If the envisaged act pursues two aims or has two components and if one of 
those  aims  or  components  is  identifiable  as  the  main  one,  whereas  the  other  is  merely 
incidental, the decision under Article 218(9) TFEU must be founded on a single substantive 
legal basis, namely that required by the main or predominant aim or component. 

With regard to an envisaged act that simultaneously pursues a number of objectives, or that 
has  several  components,  which  are  inseparably  linked  without  one  being  incidental  to  the 
other,  the  substantive  legal  basis  of  a  decision  under  Article 218(9)  TFEU  will  have  to 
include, exceptionally, the various corresponding legal bases. 

4.2.2.  Application to the present case 

As  regards  the  substantive  legal  basis,  the  EU  has  acceded  to  the  Istanbul  Convention  as 
regards matters falling within its exclusive competence, namely with regard to matters related 
to institutions and public administration of the Union 14 and with regard to matters related to 
judicial cooperation in criminal matters, asylum and non-refoulement  15. The EU’s accession 
to the Istanbul Convention was split into two separate Council decisions to take into account 
the special position of Denmark and Ireland with respect to Title V TFEU. Consequently, the 
decision establishing the position to be taken on the Union’s behalf in the CoP also needs to 
be split into two decisions, when the relevant recommendations or conclusions concern both 
matters.  The  proposed  decision  concerns  matters  related  to  institutions  and  public 
administration  of  the  Union.  Therefore,  the  substantive  legal  basis  for  this  decision  is 
Article 336 TFEU. 

4.3. 

Conclusion 

The legal basis of the proposed decision should be Article 336 TFEU, in conjunction with 
Article 218(9) TFEU.

14 
Council Decision (EU) 2023/1075 of 1 June 2023 on the conclusion, on behalf of the European Union, 
of  the  Council  of  Europe  Convention  on  preventing  and  combating  violence  against  women  and  domestic 
violence  with  regard  to  institutions  and  public  administration  of  the  Union,  OJ L 143 I,  2.6.2023,  p. 1, 
ELI: http://data.europa.eu/eli/dec/2023/1075/oj. 
15 
Council Decision (EU) 2023/1076 of 1 June 2023 on the conclusion, on behalf of the European Union, 
of  the  Council  of  Europe  Convention  on  preventing  and  combating  violence  against  women  and  domestic 
violence with regard to matters related to judicial cooperation in criminal matters, asylum and non-refoulement, 
OJ L 143 I, 2.6.2023, p. 4, ELI: http://data.europa.eu/eli/dec/2023/1076/oj. 

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2025/0367 (NLE) 

Proposal for a 

COUNCIL DECISION 

on the position to be taken on behalf of the European Union in the Committee of the 
Parties to the Council of Europe Convention on preventing and combating violence 
against women and domestic violence, at its 19th meeting,  on the recommendations and 
conclusions addressed to certain Parties on their implementation of that Convention, 
with regard to matters related to institutions and public administration of the Union 

THE COUNCIL OF THE EUROPEAN UNION, 

Having  regard  to  the  Treaty  on  the  Functioning  of  the  European  Union,  and  in  particular 
Article 336, in conjunction with Article 218(9) thereof, 

Having regard to the proposal from the European Commission, 

Whereas: 

(1) 

(2) 

(3) 

The  Council  of  Europe  Convention  on  preventing  and  combating  violence  against 
women  and  domestic  violence  (‘the  Convention’)  was  concluded  by  the  Union  by 
means  of  Council  Decision  (EU)  2023/1075  16  with  regard  to  institutions  and  public 
administration  of  the  Union,  and  by  means  of  Council  Decision  (EU)  2023/107617 
with regard to matters related to judicial cooperation in criminal matters, asylum and 
non-refoulement,  insofar as  such matters fall within the exclusive competence of the 
Union, and entered into force for the Union on 1 October 2023.  

Pursuant  to  Article 66(1)  of  the  Convention,  the  Group  of  experts  on  action  against 
violence  against  women  and  domestic  violence  (‘GREVIO’)  is  to  monitor  the 
implementation of the Convention by the Parties to the Convention (the ‘Parties’). In 
accordance with Article 68(11) of the Convention, GREVIO is to adopt its report and 
conclusions on the measures taken by the Party concerned to implement the provisions 
of the Convention. 

The  Committee  of  the  Parties  (the  ‘Committee’)    is  able  to  adopt  recommendations 
addressed  to  the  Party  concerned,  in  accordance  with  Article 68(12)  of  the 
Convention,  on  the  basis  of  the  report  and  conclusions  of  GREVIO.  Such 
recommendations  are  to  differentiate  between  measures  to  be  taken  as  soon  as 
possible,  with  a  requirement  to  report  back  to  the  Committee  within  a  three-year 
period,  and  measures  which,  while  important,  do  not  carry  the  same  level  of 

16 
Council Decision (EU) 2023/1075 of 1 June 2023 on the conclusion, on behalf of the European Union, 
of  the  Council  of  Europe  Convention  on  preventing  and  combating  violence  against  women  and  domestic 
violence  with  regard  to  institutions  and  public  administration  of  the  Union,  OJ L 143 I,  2.6.2023,  p. 1, 
ELI: http://data.europa.eu/eli/dec/2023/1075/oj. 
17 
Council Decision (EU) 2023/1076 of 1 June 2023 on the conclusion, on behalf of the European Union, 
of  the  Council  of  Europe  Convention  on  preventing  and  combating  violence  against  women  and  domestic 
violence with regard to matters related to judicial cooperation in criminal matters, asylum and non-refoulement, 
OJ L 143 I, 2.6.2023 p. 4, ELI: http://data.europa.eu/eli/dec/2023/1076/oj. 

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immediacy. At the end of that three-year period, the Party concerned is to report back 
to the Committee on the measures taken, within 10 specific areas of the Convention. 
On the basis of that report, and any additional information, the Committee is to adopt 
conclusions  on  the  implementation  of  those  recommendations  prepared  by  the 
secretariat of the Committee. 

Pursuant  to  Article 68(3)  of  the  Convention,  the  evaluation  procedures  following 
GREVIO’s  initial  baseline  evaluation  procedure  are  to  be  divided  into  rounds  (the 
‘thematic evaluation rounds’). The first thematic evaluation round is entitled ‘Building 
Trust  by Delivering Support, Protection and Justice’ and addresses  20  articles of the 
Convention, namely Articles 3, 7, 8, 11, 12, 14, 15, 16, 18, 20, 22, 25, 31, 48, 49, 50, 
51, 52, 53 and 56. At its 17th meeting on 17 December 2024, the Committee adopted a 
decision  on  the  recommendations  to  be  adopted  by  the  Committee  in    light  of  
GREVIO’s reports adopted as part of the first thematic evaluation round contained in 
document  IC-CP(2024)10 rev. 

The Committee, during its 19th meeting on 11 December 2025, is  expected to adopt 
the following draft recommendations (one based on the baseline evaluation round and 
seven  based  on  the  first  thematic  evaluation  round)  and  draft  conclusions  on  the 
implementation  of 
the  ‘draft 
recommendations’ and the ‘draft conclusions’, and jointly the ‘envisaged acts’): 

the  Convention  by  nine  Parties  (respectively 

(4) 

(5) 

(1)  Recommendation  on  the  implementation  of  the  Istanbul  Convention  by  the 

United Kingdom, contained in document IC-CP(2025)22prov; 

(2)  Recommendations  on  building  trust  by  delivering  support,  protection  and 
justice  on  the  basis  of  the  Istanbul  Convention  by  Andorra,  contained  in 
document  IC-CP(2025)23prov; 

(3)  Recommendations  on  building  trust  by  delivering  support,  protection  and 
justice  on  the  basis  of  the  Istanbul  Convention  by  Belgium,  contained  in 
document IC-CP(2025)24revprov; 

(4)  Recommendations  on  building  trust  by  delivering  support,  protection  and 
justice  on  the  basis  of  the  Istanbul  Convention  by  France,  contained  in 
document IC-CP(2025)25prov; 

(5)  Recommendations  on  building  trust  by  delivering  support,  protection  and 
justice on the basis of the Istanbul Convention by Italy, contained in document 
IC-CP(2025)26prov]; 

(6)  Recommendations  on  building  trust  by  delivering  support,  protection  and 
justice on the basis of the Istanbul Convention by the Netherlands, contained in 
document IC-CP(2025)27prov; 

(7)  Recommendations  on  building  trust  by  delivering  support,  protection  and 
justice  on  the  basis  of  the  Istanbul  Convention  by  Portugal,  contained  in 
document IC-CP(2025)28prov; 

(8)  Recommendations  on  building  trust  by  delivering  support,  protection  and 
justice  on  the  basis  of  the  Istanbul  Convention  by  Serbia,  contained  in 
document IC-CP(2025)29prov; and 

(9)  Conclusions  on  the  implementation  of  recommendations  in  respect  of  Poland 
adopted  by  the  Committee  of  the  Parties,  contained  in  document  IC-
CP(2025)30prov. 

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(6) 

(7) 

(8) 

– 

The Union has exclusive competence to accept obligations set out in the Convention 
with  regard  to  its  own  institutions  and  public  administration,  within  the  scope  of 
Article 336 of the Treaty on the Functioning of the European Union. In paragraph 305 
of its Opinion 1/19 of 6 October 2021, Istanbul Convention18, the Court of Justice of 
the  European  Union  held  that  a  significant  part of  the  obligations  of  the  Convention 
relating to the adoption of preventive and protection measures are, in essence, binding 
on the Union as regards the staff in its administration and as regards members of the 
public  visiting  the  premises  and  buildings  of  its  institutions,  agencies  and  bodies. 
Moreover, in paragraph 307 of the same Opinion, the Court held that the Union should 
not  confine  itself  to  establishing  minimum  requirements  or  supporting  measures  but 
should  itself  ensure  that  those  obligations  are  fully  satisfied.  At  the  same  time,  the 
extent  of  the  Union’s  obligations  should  be  interpreted  bearing  in  mind  its  specific 
nature  and  powers.  In  particular,  since  the  Union’s  public  administration  is  not 
endowed  with  law  enforcement  powers,  recommendations  relating  to  matters  of  law 
enforcement, such as the issue of emergency barring orders, should be interpreted as 
requiring the Union to ensure the safety of victims within the limits of its powers, for 
example by refusing alleged perpetrators access to the premises of the institutions. 

The envisaged acts concern the implementation of provisions of the Convention which 
also apply to the Union with regard to its own institutions and public administration. It 
is therefore appropriate to establish the position to be taken on the Union’s behalf in 
the Committee with regard to matters related to institutions and public administration 
of the Union, as the envisaged acts are capable of decisively influencing the content of 
Union  law  in  that  they  may  affect  the  interpretation  of  relevant  provisions  of  the 
Convention in the future.  

As  regards  the  United  Kingdom,  the  draft  recommendation  on  its  implementation  of 
the  Convention  includes  the  need  to:  ensure  appropriate  and  sustainable  financial 
resources for all policies aimed at combating violence against women and sustainable 
funding for relevant civil society organisations (Article 8 of the Convention); equip the 
national  coordinating  bodies  with  the  necessary  mandate,  competence  and  resources 
and  ensure  the  coordination  and  implementation  of  policies  and  measures  to  prevent 
and combat all forms of violence against women and their independent monitoring and 
evaluation, supported by relevant data (Article 10 of the Convention); harmonise data 
collection  systems  and  ensure  the  systematic  collection  of  disaggregated  data  on 
violence  against  women  (Article 11  of  the  Convention);  ensure  training  for  relevant 
professionals on how to adequately respond to violence against women (Article 15 of 
the Convention); remove barriers to accessing general support services (Article 20 of 
the  Convention);  ensure  access  to  specialist  support  services  and  shelters  for  all 
victims  of violence against  women and  domestic violence (Articles 22  and 23 of the 
Convention); reduce secondary victimisation, by ensuring cases are handled efficiently 
without delay (Article 50 of the Convention); and ensure the use of emergency barring 
orders (Article 52 of the Convention). As the recommendation on those matters is in 
line  with  the  Union’s  policies  and  objectives  and  does  not  raise  any  concerns  with 
respect to Union law, the position of the Union should be to not object to its adoption. 

(9) 

As  regards  Andorra,  the  draft  recommendations  on  its  implementation  of  the 
Convention  include  the  need  to:  develop  a  long-term  comprehensive  strategy  to 

18 

Opinion of the Court of Justice 1/19 of 6 October 2021, Istanbul Convention, EU:C:2021:832. 

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prevent and combat all forms of violence against women covered by the Convention; 
to ensure that women’s rights organisations are fully involved in policymaking and to 
regularly  assess  these  policies  on  the  basis  of  detailed  indicators  (Article 7  of  the 
Convention);  improve  the  clarity  of  budgets  for  activities  to  prevent  and  combat 
violence  against  women  and  domestic  violence,  continue  efforts  to  increase  these 
budgets  where  necessary  and  to  ensure  that  women’s  rights  NGOs  are  granted 
sufficient subsidies and time to carry out activities entrusted to them (Article 8 of the 
Convention);  continue  to  extend  the  collection  of  disaggregated  data  on  all  forms  of 
violence covered by the Convention (Article 11 of the Convention); extend prevention 
campaigns to all forms of violence covered by the Istanbul Convention and regularly 
assess their impact (Article 12 of the Convention); ensure sufficient human resources 
and  adequate  qualifications  of  professional  working  on  programme  for  perpetrators, 
devise  minimum  standards  and  introduce  a  specific  programme  for  perpetrators  of 
sexual violence (Article 16 of the Convention); ensure that specialist support services 
meet victims’ needs (Article 22 of the Convention); take measures to guarantee that all 
stakeholders  carry out a  risk assessment for all the forms of violence covered by the 
Convention  and  repeat  this  regularly  (Article 51  of  the  Convention);  ensure  that 
emergency  barring  orders  can  be  issued  without  delay  where  there  is  an  immediate 
danger and establish a clear legal framework that guarantees the proper management 
of emergency barring orders (Article 52 of the Convention); and ensure that victims of 
all the forms of violence covered by the Convention can benefit from protection orders 
and  that  breaches  are  punished  (Article 53  of  the  Convention).  As  those  draft 
recommendations are in line with the Union’s policies and objectives and do not raise 
any  concerns  with  respect  to  Union  law,  the  position  of  the  Union  should  be  to  not 
object to their adoption. 

(10)  As  regards  Belgium,  the  draft  recommendations  on  its  implementation  of  the 
Convention include the need to: ensure greater consistency of policies and measures in 
relation  to  preventing  and  combating  violence  against  women  between  the  different 
levels of authorities in the country (Article 7 of the Convention); ensure that collected 
data are disaggregated and harmonise data  collection (Article 11 of the  Convention); 
ensure  the  practical  implementation  of  the  requirement  to  impart  knowledge  on  the 
principles listed in Article 14 of the Convention at all levels of education (Article 14 
of  the  Convention);  introduce  initial  and  in-service  training  for  all  relevant 
professionals,  and  adopt  and  disseminate  quality  standards  for  training  courses 
(Article 15  of  the  Convention);  step  up  support  for  the  recovery  and  economic 
independence of women victims of violence through relevant measures and implement 
standardised care paths in the healthcare sector to ensure the identification of victims 
and  their  referral  to  appropriate  specialist  support  services  (Article 20  of  the 
Convention);  ensure  access  to  shelters  and  set  up  a  helpline  that  serves  as  a  single 
point  of  contact  (Article 22  of  the  Convention);  ensure  efficient  handling  of  cases,  a 
gender-based  and  victim-centred  understanding  of  violence  against  women;  ensure 
that effective safeguards are in place to prevent the inappropriate use of mediation and 
ensure proper and sufficient sanctions (Articles 49 and 50 of the Convention); ensure 
that emergency barring, protection and restraining orders are available and accessible 
to all victims (Articles 52 and 53 of the Convention); evaluate the implementation of 
existing protection measures and ensure that all measures in place are implemented in 
practice for victims of all forms of violence covered by the Convention (Article 56 of 
the Convention). As those draft recommendations are in line with the Union’s policies 
and objectives and do not raise any concerns with respect to Union law, the position of 
the Union should be to not object to their adoption. 

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(11)  As  regards  France,  the  draft  recommendations  on  its  implementation  of  the 
Convention include the need to: develop  a long-term  overarching  strategy to  prevent 
and combat  all forms  of violence against women covered by the Convention,  ensure 
that adequate resources are allocated to the body coordinating the  policies to prevent 
and combat violence against women, ensure that women’s rights associations are fully 
involved in policymaking and regularly assess these policies on the basis of predefined 
indicators  (Article 7  of  the  Convention);  continue  efforts  to  ensure  adequate  funding 
for policies to prevent and combat all forms of violence against women, improve the 
clarity  of  budgets  allocated  to  these  policies  and  ensure  that  women’s  rights 
organisations  have  sufficient  and  stable  financial  resources  to  carry  out  their  work 
(Article 8 of the Convention); ensure disaggregation of data and set up data collection 
on the number of women and girls who seek help from healthcare services (Article 11 
of the Convention); improve efforts and assess the impact of measures in the area of 
primary  prevention  (Article 12  of  the  Convention);  ensure  that  pupils  have  access  to 
education  on  the  matters  outlined  in  Article 14  of  the  Convention  (Article 14  of  the 
Convention);  ensure  that  all  professionals  in  contact  with  victims  and  perpetrators 
receive  training  on  all  forms  of  violence  against  women  and  that  such  training  is 
assessed (Article 15 of the Convention); adopt and implement minimum standards for 
programmes  for  perpetrators  of  violence  and  assess  their  impact  (Article 16  of  the 
Convention);  ensure  that  coordination  bodies  are  set  up  throughout  the  country  and 
that  the  new  one-stop-shop  facilities  set  up  to  provide  support  for  women  victims 
involve all the bodies concerned (Article 18 of the Convention); ensure that all women 
victims of violence have access to a forensic examination and take further measures to 
prevent  and  combat  violence  against  women  with  disabilities  (Article 20  of  the 
Convention);  ensure  that  specialist  support  is  available  across  the  country,  including 
for women victims of violence and their children residing in shelters, and ensure that 
such services respond to the digital dimension of violence against women (Article 22 
of  the  Convention);  provide  victims  of  sexual  violence  with  medical  care,  trauma 
support,  forensic  examinations  and  psychological  assistance  (Article 25  of  the 
Convention); strengthen the measures taken to encourage women victims of all forms 
of violence covered by the Convention to report such violence and ensure appropriate 
reception  and  support  services,  and  continue  efforts  to  ensure  a  proper  judicial 
response  to  all  forms  of  violence  against  women  (Articles 49  and  50  of  the 
Convention); ensure that risk assessments are conducted systematically in all cases of 
violence  against  women  (Article 51  of  the  Convention);  make  increased  use  of 
protection orders and ensure breaches are punished (Article 53 of the Convention); and 
limit the secondary victimisation to which women victims of violence can be exposed 
to during proceedings (Article 56 of the Convention). As those draft recommendations 
are in line with the Union’s policies and objectives and do not raise any concerns with 
respect  to  Union  law,  the  position  of  the  Union  should  be  to  not  object  to  their 
adoption.  

(12)  As regards Italy, the draft recommendations on its implementation of the Convention 
include the need to: ensure that Italy’s national action plan on violence against women 
addresses  all  forms  of  violence  against  women  and  is  supported  by  a  timeline, 
financial  resources  and  indicators  to  measure  progress,  ensure  effective  consultation 
with  civil  society  and  better  coordinate  the  implementation  of  the  relevant  policies 
(Article 7  of  the  Convention);  ensure  sustainable  and  long-term  funding  for  all  the 
policies  and  measures  aimed  at  preventing  and  combating  violence  against  women, 
while ensuring separate budget and funding lines (Article 8 of the Convention); ensure 
the collection and disaggregation of data by all relevant stakeholders (Article 11 of the 

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Convention);  review  teaching  curricula  and  materials  with  a  view  to  removing 
negative  stereotypes  of  women  and  girls  (Article 14  of  the  Convention);  introduce 
initial  and  in-service  training  for  all  relevant  professionals  on  all  forms  of  violence 
against women (Article 15 of the Convention); ensure the availability of shelters and 
helpline support for all victims (Article 22 of the Convention); ensure timely, adequate 
and  effective  responses  to  reports  relating  to  all  forms  of  violence  against  women 
(Articles 49 and 50 of the Convention); ensure systematic risk assessments for victims 
of all forms  of violence  against women  that are  grounded in  manuals  and  guidelines 
(Article 51  of  the  Convention);  and  ensure  that  emergency  barring  orders  are  issued 
when needed and that breaches causes reaction (Articles 52 and 52 of the Convention). 
As  those  draft  recommendations  are  in  line  with  the  Union’s  policies  and  objectives 
and  do  not  raise  any  concerns  with  respect  to  Union  law,  the  position  of  the  Union 
should be to not object to their adoption. 

(13)  As  regards  the  Netherlands,  the  draft  recommendations  on  its  implementation  of  the 
Convention include the need to: ensure that policies and measures taken in relation to 
preventing  and  combating  violence  against  women  and  domestic  violence  are 
coordinated and that they cover all forms  of violence against women  covered by the 
Convention, assign the role of coordinating body to fully institutionalised entities with 
clear mandates, competences and necessary resources, and ensure the involvement of 
non-governmental  organisations  in  policymaking  (Article 7  of  the  Convention); 
introduce appropriate and sustainable funding for policies and measures on all forms 
of violence against women and domestic violence, introduce separate budget lines and 
funding  lines  that  are  based  on  the  principle  of  gender  budgeting,  and  ensure 
appropriate and sustainable funding for women’s rights organisations (Article 8 of the 
Convention); adapt data categories for the collection of disaggregated data (Article 11 
of the Convention); take measures to impart knowledge on all the principles listed in 
Article 14  of  the  Convention  (Article 14  of  the  Convention);  step  up  training  for  all 
professionals  while  also  drawing  on  the  expertise  of  women’s  rights  organisations 
(Article 15  of  the  Convention);  ensure  access  to  shelters  for  all  victims,  including 
victims of intersectional discrimination (Article 22 of the Convention); take measures 
to  encourage  women  victims  to  report,  including  women  at  risk  of  intersectional 
discrimination (Articles 49 and 50 of the Convention); ensure that risk assessments are 
carried out in cases of domestic violence and other forms of violence against women 
as  part  of  a  multiagency  response  (Article 51  of  the  Convention);  and  ensure  that 
relevant authorities can immediately issue restraining and emergency barring orders in 
cases  of 
those  draft 
recommendations are in line with the Union’s policies and objectives and do not raise 
any  concerns  with  respect  to  Union  law,  the  position  of  the  Union  should  be  to  not 
object to their adoption. 

imminent  danger  (Article 52  of 

the  Convention).  As 

(14)  As  regards  Portugal,  the  draft  recommendations  on  its  implementation  of  the 
Convention  include  the  need  to:  ensure  appropriate  financial  resources  for  the 
implementation  of  national  strategies  and  action  plans,  and  sustainable  funding  for 
women’s  rights  organisations  (Article 8  of  the  Convention);  ensure  training  on 
violence  against  women  for  all  professionals  who  come  into  contact  with  victims 
(Article 15  of  the  Convention);  ensure  that  programmes  for  perpetrators  of  domestic 
and  sexual  violence  are  sufficiently  available,  adopt  minimum  standards  and  are 
continually  evaluated  (Article 16  of  the  Convention);  develop  a  fully  operational 
multiagency coordinated response to all forms of violence against women (Article 18 
of the Convention); set up a helpline for women victims of different forms of violence, 
ensure  shelters  for  victims  of  all  forms  of  violence  against  women  and  ensure  the 

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availability  of  specialist  support  services  (Article 22  of  the  Convention);  ensure  that 
cases  are  investigated  effectively,  enhancing  case-building  efforts  by  moving  away 
from over-reliance on victim statements, and ensure that sanctions are commensurate 
with the gravity of the crime (Articles 49 and 50 of the Convention); and ensure that 
emergency barring orders are issued swiftly and with immediate effect, and strengthen 
the monitoring of protection orders (Articles 52 and 53 of the Convention). As those 
draft recommendations are in line with the Union’s policies and objectives and do not 
raise any concerns with respect to Union law, the position of the Union should be to 
not object to their adoption.  

(15)  As regards Serbia, the draft recommendations on its implementation of the Convention 
include the need to: ensure the effective implementation and monitoring of its relevant 
strategy,  and  to  allocate  sufficient  resources  to  the  competent  body  or  bodies 
responsible  for  the  coordination,  implementation,  monitoring  and  independent 
evaluation  of  policies  and  measures  addressing  all  forms  of  violence  against  women 
(Article 7);  ensure  appropriate  and  sustainable  financial  resources  for  legislation, 
policies and measures aimed at preventing and combating violence against women and 
domestic  violence,  including  for  the  institutions  and  entities  responsible  for  their 
implementation,  as  well  as  use  gender-responsive  budgeting  to  enable  effective 
monitoring  of  public  expenditures  and  guarantee  sustainable  funding  for  women’s 
organisations  that  provide  specialist  support  for  victims  through  long-term  grants 
awarded via transparent procurement procedures (Article 8 of the Convention); ensure 
that collected data are disaggregated by relevant factors and harmonise data collection 
(Article 11  of  the  Convention);  ensure  regular  preventive  measures  aimed  at 
eradicating  gender  stereotypes  and  addressing  gender  inequality  as  a  root  cause  of 
violence  against  women,  and  promote  awareness-raising  campaigns  that  address  all 
forms  of  violence  against  women,  including  their  digital  dimension  targeting  society 
as  a  whole  (Article  12  of  the  Convention);  ensure  systematic  initial  and  in-service 
training  for  all  relevant  professionals  (Article 15  of  the  Convention);  expand  and 
provide  adequate  resources  for  domestic  violence  perpetrator  programmes  and  adopt 
uniform standards (Article 16 of the Convention); improve victims’ access to financial 
support,  housing  and  employment,  and  ensure  free  forensic  examinations  (Article 20 
of  the  Convention);  ensure  shelter  places  for  all  victims,  including  those  facing 
intersectional discrimination (Article 22 of the Convention); ensure the accessibility of 
rape  crisis  or  sexual  violence  referral  centres,  accessible  regardless  of  the  victim’s 
willingness to report the crime (Article 25 of the Convention); encourage the reporting 
of  all  forms  of  violence  against  women,  strengthen  evidence  collection  and  take 
measures  to  ensure  efficient  case-handling  (Articles 49  and  50  of  the  Convention); 
involve all relevant institutions in the risk assessment (Article 51 of the Convention); 
improve  monitoring  and  compliance  with  emergency  and  extended  protective 
measures, and ensure procedural consistency (Articles 52 and 52 of the Convention); 
and  ensure  the  effective  implementation  of  all  victim  protection  measures  and 
safeguard  victims’  right  to  be  properly  informed  (Article 56  of  the  Convention).  As 
those draft recommendations are in line with the Union’s policies and objectives and 
do not raise any concerns with respect to Union law, the position of the Union should 
be to not object to their adoption. 

(16)  As  regards  Poland,  the  draft  conclusions  on  its  implementation  of  the  Convention 
include  the  need  to:  develop  comprehensive  and  coordinated  policies  to  prevent  and 
combat  all  forms  of  violence  against  women  covered  by  the  Convention,  strengthen 
interinstitutional  cooperation  mechanisms  between  authorities  to  ensure  victims’ 
access  to  support  and  protection  mechanisms,  and  conduct  independent  comparative 

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analyses of existing measures and programmes (Article 7 of the Convention); increase 
financial resources for preventing and combating all forms of violence against women, 
ensure the introduction  of dedicated budget  lines  to  measures  to  prevent and combat 
violence against women, provide equitable and stable funding for NGOs, and ensure 
their participation in implementation and monitoring of all relevant policies (Article 8 
of  the  Convention);  allocate  the  necessary  human  and  financial  resources  to  the 
coordinating body for the Convention (Article 10 of the Convention); and ensure the 
collection  of  disaggregated  data  and  harmonise  data  collection  between  relevant 
services (Article 11 of the Convention). As those draft conclusions are in line with the 
Union’s policies  and objectives  and do not  raise  any concerns with  respect  to  Union 
law, the position of the Union should be to not object to their adoption. 

HAS ADOPTED THIS DECISION: 

Article 1 

The  position  to  be  taken  on  behalf  of  the  Union  within  the  Committee  of  the  Parties 
established  under  Article 67  of  the  Council  of  Europe  Convention  on  preventing  and 
combating violence against women and domestic violence, at its 19th meeting, shall be to not 
object to the adoption of the following acts: 

(1)  Recommendation  on  the  implementation  of  the  Istanbul  Convention  by  the 

United Kingdom, contained in document IC-CP(2025)22prov; 

(2)  Recommendations  on  building  trust  by  delivering  support,  protection  and 
justice  on  the  basis  of  the  Istanbul  Convention  by  Andorra,  contained  in 
document IC-CP(2025)23prov; 

(3)  Recommendations  on  building  trust  by  delivering  support,  protection  and 
justice  on  the  basis  of  the  Istanbul  Convention  by  Belgium,  contained  in 
document IC-CP(2025)24revprov; 

(4)  Recommendations  on  building  trust  by  delivering  support,  protection  and 
justice  on  the  basis  of  the  Istanbul  Convention  by  France,  contained  in 
document  IC-CP(2025)25prov; 

(5)  Recommendations  on  building  trust  by  delivering  support,  protection  and 
justice on the basis of the Istanbul Convention by Italy, contained in document  
IC-CP(2025)26prov; 

(6)  Recommendations  on  building  trust  by  delivering  support,  protection  and 
justice on the basis of the Istanbul Convention by the Netherlands, contained in 
document  IC-CP(2025)27prov; 

(7)  Recommendations  on  building  trust  by  delivering  support,  protection  and 
Istanbul  Convention  by  Portugal 

the  basis  of 

the 

justice  on 
[IC-CP(2025)28prov]; 

(8)  Recommendations  on  building  trust  by  delivering  support,  protection  and 
justice  on  the  basis  of  the  Istanbul  Convention  by  Serbia,  contained  in 
document  IC-CP(2025)29prov; and 

(9)  Conclusions  on  the  implementation  of  recommendations  in  respect  of  Poland 
in  document 

the  Parties,  contained 

the  Committee  of 

adopted  by 
IC-CP(2025)30prov.  

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This Decision shall enter into force on the date of its adoption. 

Done at Brussels, 

Article 2 

For the Council 
The President 

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