This position paper outlines several issues that deserve further reflection in order to calibrate the policy in a way it delivers on full democratic transformation of the EaP countries and societies.

Deliver on stronger and democratic governance

As the Communication rightly outlines, so far the results of the policy in the area of democratic governance, rule of law, fight against corruption as well as support and promotion of independent media and enabling environment for civil society have not been optimal. It is explicitly mentioned in the text of Communication (p.3) that the partner countries need to improve their performance. Different elements of democratic governance are now split into a number of priority areas/EaP Platforms as a way of ensuring that democratic, accountable governing practises become a key principle of the entire EaP policy. Public administration reform is moved to the Resilient, fair and inclusive societies area (4.5) as well as media and civil society, that featured as cross-cutting deliverables since 2017. Electoral processes and “protection of citizens’ rights” and human rights are also explicitly mentioned there (4.5). The part on accountable institutions, the rule of law and security (4.2) covers judiciary reform, tackling corruption, and combatting organised crime and security. At the same time, the Communication comes short on detail and specific benchmarks for activities targeting the identified insufficiencies.

• The language on backsliding and stagnation of reforms is strong but somehow vague. EU funding should be “adjusted downward” (p. 4) in such cases but explicit commitment to call out the violations or support the civil society that is doing so is missing, as well as specific standards and benchmarks linking the EU support to the implementation of EaP countries’ human rights obligations and conditions for civil society to operate. Without such articulated strong link, sustainable improvements in these areas are questionable. EaP CSF has been also consistently calling for establishing a practice of transferring EU funding from noncompliant governments to civil society actors, not only for preserving the civil society funding in case of EaP governments misconduct.
• The wording on judicial reforms that are to be based on the alignment with European standards should be further specified by introducing a clear reference to EU Justice Scoreboard as a tool to assess the state of judiciary in EaP countries, with strong focus on the transparent selection and promotion of judges and fair disciplinary proceedings in judiciary.
• In the part on independent media and fact-based information, the Communication mentions the Action Plan against disinformation, in which many specific actions EaP CSF supports are suggested. The fact-checking initiatives are important and are also explicitly mentioned. At the same time, reinforcing the production of quality content should be prioritised.
• High-level corruption cases in EaP countries show that the stolen assets are often invested in the EU member states. There should be a commitment from the EU side dedicated to this side of this problem. More consistent support to civil society organisations and investigative journalists in their effort to monitor fraud and money laundering should be also articulated as they are often on the frontline, investigating and blowing the whistle.

Use smartly the primacy of economic development within the resilience framework

Support to the economic development, propelled by green/environmental and digital transformations, is designed to lie at the heart of the new resilience framework for EaP, with other policy objectives playing supporting roles. The part of the Communication dedicated to the economic development (4.1.) is the most detailed, with specific actions to be taken. The improvements to governance are linked to the economic benefits they can bring rather than being promoted as desirable objectives in and of themselves. With such logic in place, the EU should use such approach as a smart tool to leverage the important issues.

• Link the support to the membership of EaP countries in WTO (p.5) to specific commitments improving the enabling environment for civil society and civil society dialogue with the national stakeholders.
• Launch further initiatives supporting further intra-EaP/ regional cooperation. In the view of references to the Black Sea Strategy and other strategies, reconsider setup of a EU macroregional strategy for EaP countries (similar to the macro-strategy for the Danube region), with a policy framework allowing countries located in the same region to jointly tackle and find solutions to problems or to better use the potential they have in common.
• Reflect on current needs of EaP countries struggling with Covid-19 crisis by offering emergency financial package to save the vital parts of their economies and to underpin the sectors where the EaP countries suffer from deficiencies and thus possible shortages due to closed borders – for example, food security and healthcare equipment and services should be supported.

Think big on Green transformation but be realistic in its implementation

Green/environmental transformations feature prominently in the Communication (4.3 and mainstreamed as new cross-cutting priority) with reference to growing demand in EaP countries for the green agenda and activities. However, green transformation is at a very early stage in the region, driven rather by the EU reform agenda, environmental CSOs and minority segments of the population rather than by genuine demand from the majority of EaP citizens  and/or governments. Reform set to improving people’s quality of life, for example in the area of waste management and many others, is desirable but public demand should not be taken for granted.

• Environmental awareness remains very low. Treat the citizens as a target group of comprehensive communication activities first, using the support and work of the civil society, before taking them for allies.
• Reaching for the low-hanging fruits in environmental and climate resilience (4.3) is a realistic approach that can bring certain advantages but should not lead to leaving out difficult but more consequential reform (following the experience in the rule of law and democratic governance area) like strengthening of environmental governance, which is at the source of environmental mismanagement in the region.
• Strengthen implementation of the EU Third Energy Package in EaP countries (4.1.3), both at the level of primary and secondary legislation, as well as its implementation, which will be the real challenge. This will include the establishment of independent energy regulators in EaP countries, further liberalisation of energy markets, and unbundling of transmission system operators in gas and electricity sectors. Focus on promoting open competition on energy market so that the consumers can benefit from it.

Go beyond youth for effective multipliers of messages

The focus on youth is very prominent in the text of the Communication. Young people are considered as key multipliers in the EaP societies, which resonates with the EaP CSF recommendations. At the same time, youth-centred approach should be paired with a targeted approach for other groups and age groups so that the messages are properly channelled, especially to other segments of society.

• Reach out to different non-English speaking segments of society through campaigns informing citizens about the opportunities stemming from AA/DCFTA implementation, raising awareness about the benefits of EU integration and linking them to the positive impact on labour markets. Farmers, owners of SMEs, categories of population who benefit from DCFTA implementation should not be forgotten and be the primary targets of similar campaigns, as well as consumers, who benefit from improved phytosanitary standards. Local beneficiaries of EU funding could provide testimonies to their communities, facilitating a personal exchange of ideas over a faceless broadcasting of information.
• Focus on messages built on the narrative of the common European history.
• Integrate better the EaP Youth Forum in structured youth policy dialogue within a network of EaP youth councils, but make sure these activities are balanced by including truly independent youth organisations into the structured policy dialogue.
• Support the EU Delegations with more staff locally who will not only oversee the design and implementation of the projects, but continuously look for opportunities to increase the presence and visibility of the EU on the ground.
• Organise high-level meetings (Ministerial meetings and Summits) in EaP countries to enhance the EU’s visibility among the local public and signal presence and commitment to the region.

Make gender a truly cross-cutting deliverable

Out of the newly outlined cross-cutting deliverables – ecological transformation, digital transformation, youth and gender – the latter comes out underrepresented in the text of the Communication. On top of references in the future policy approach (3.) and part on human rights protection (4.5.4), it is explicitly mentioned only in relation to tackling the digital skills gap and raising awareness in gender inequalities via the Young European Ambassadors.

• Include gender mainstreaming into employability activities targeting youth and SMEs and focus more on gender-based discrimination on job market and within employment policies. Enhanced engagement in this sphere would strengthen EU visibility and bring direct benefits to citizens.
• Underline that CSOs are playing a vital role in the rights-based gender agenda in the region. The development of cross-regional initiatives and actions is equally important as local policies and services. Together with the support from bilateral and international organisations the work of CSOs is the catalyst of reforms in the area of elimination of violence against women and domestic violence.