The new Shadow Report of Coalition 27 indicates that the state of the environment in Serbia continues to improve slowly and insufficiently, despite the adoption of certain laws and strategic documents. The same pattern is repeated across most chapters - delays in drafting and implementing legislation, weak oversight, lack of sanctions for irregularities, and insufficient political will to address problems in a systemic way.

The newly adopted Law on Air Protection does not appear sufficient to address the structural causes of pollution. Civil society organizations particularly highlight issues related to local air quality monitoring, the lack of connection with the National Emission Reduction Plan (NERP), and the fact that oversight and penalty provisions have not been significantly improved. Air pollution remains one of the biggest health risks for citizens of Serbia.

Irresponsible waste management is increasingly coming due, as a consequence of a poorly designed system. The number of landfill fires is rising, along with pollution and health risks. The closure of the “Duboko” sanitary landfill in Užice demonstrates how deep a systemic failure can be: millions of euros of public funds have been lost, and citizens are left without a solution for waste disposal.

Although the goal of water sector policies is to achieve good water status, delays in drafting key documents, low levels of public participation, and weak implementation of legislation are preventing progress. Many plans remain in draft form, and ineffective enforcement in practice further distances Serbia from European standards.

Despite a slight increase in the total surface area of protected areas (9.34% of Serbia’s territory), pressures on nature persist and continue to grow. Progress in developing new policies is minimal, and the implementation of existing ones is insufficient. The increase of 0.69% compared to the previous Report, when it stood at 0.5%, is a step forward, but still inadequate for the needs of biodiversity conservation.

In the previous year, a serious problem was identified regarding overlapping competences between sanitary inspection and environmental protection inspection. As the two institutions declare themselves not responsible, toxic products intended for widespread use continue to be available on the market, directly threatening public health, especially children's health. Information on the implementation of international conventions in this field is not publicly accessible, and administrative capacities remain insufficient.

Serbia still lacks a functional climate policy system. Although a legislative framework exists, implementation is significantly delayed due to the absence of by-laws, the Action Plan for the Low-Carbon Development Strategy has not been adopted, and the draft Environmental Protection Strategy does not set ambitious decarbonization goals. The share of renewable energy in gross final energy consumption decreased from 26.3% (2020) to 25.43% (2023), further distancing Serbia from the 2030 target of 33.6%.

The state of forestry remains nearly unchanged. Illegal logging, inadequate management of private forests, and weak inspection capacities remain the biggest challenges. Although the drafting of a new law on placing timber on the market has begun, a large number of actors (individuals) remain outside the process. Afforestation shows slight growth, but damage caused by storms and windthrow remains significant.

Industrial pollution remains one of the most complex areas of environmental protection. According to the EU Report 2025, Serbia’s alignment with the EU acquis remains only partial. It is necessary to accelerate the drafting of a new Law on Integrated Pollution Prevention and Control and to strengthen the application of BAT technologies. Currently, only 44% of industrial installations hold integrated permits, indicating a serious slowdown in the process.

The findings of the new Shadow Report show that Serbia still lacks an effective environmental protection system. Without institutional accountability, stronger oversight, rule-of-law enforcement, and the involvement of all stakeholders. from local communities to industry, no policy will have real impact. Coalition 27 calls on institutions to urgently improve environmental governance, ensure consistent implementation of regulations, and guarantee citizens’ right to a healthy environment.

The Shadow Report “Systemic Error” covers the period from May 2024 to May 2025 and includes detailed recommendations for each area of Chapter 27. The report can be downloaded HERE.

The Shadow Report was presented at an event that brought together representatives of civil society, the EU Delegation, experts, and media at the Miljenko Dereta Space. The event was opened by representatives of Coalition 27, as well as Andrea Vidal, Programme Manager for Environment and Climate Change at the EU Delegation to Serbia, and Paul Collins, First Secretary and Head of the National Environmental Protection Programme and Climate Reform Support at the Embassy of Sweden in Belgrade.

The event is part of the European Green Diplomacy Week, a global EU campaign that promotes cooperation in the fight against climate change and inspires climate action.

Coalition 27 consists of eight civil society organizations: Alternative for Safer Chemicals, Belgrade Open School, BirdLife Serbia, Climate Action Network Europe (CAN Europe), Environmental Improvement Centre, Environmental Engineering Association, Young Researchers of Serbia, and WWF Adria – Serbia. These organizations jointly work to improve environmental protection and strengthen democratic processes through monitoring the implementation of EU standards in Serbia.

Photos from the event can be viewed HERE.

Photo credit: Zorica Popović, BOS.