Coalition 27 calls on the Ministry of Environmental Protection to improve the Draft Nature Protection Programme by setting more ambitious goals, concrete measures for nature conservation and restoration, clear success indicators, and by ensuring greater support from other sectors (agriculture, energy, mining, forestry). The Nature Protection Programme is an opportunity for the systemic conservation of biodiversity and further alignment with European standards in the field of nature protection, an opportunity that remains unused in its current form.

Today marks the end of the public consultation on the Draft Nature Protection Programme of the Republic of Serbia 2026-2031, with an Action Plan until 2028. The Draft Programme represents an important step towards systematic nature protection planning, but in its current form it is not sufficiently ambitious, does not include clear implementation mechanisms, and significantly lags behind contemporary European approaches in the field of biodiversity conservation.

The Programme is being adopted amid growing pressures on natural resources across the country, while the share of Serbia’s territory under protection remains low (less than 11%), and the system for managing protected areas is still centralised and insufficiently functional. In such circumstances, the proposed Programme does not provide an adequate response to identified systemic weaknesses and key challenges in the field of nature protection. 

The Programme lacks a clear commitment that nature protection should not be seen as a barrier to development, but rather as an integral part of sustainable economic and social development, the sustainable and equitable use of natural resources, and long-term environmental security. The document itself notes that, in certain sectors, nature protection is still viewed as a limitation rather than a prerequisite for sustainable development.

The analysis of the implementation of the previous programme clearly indicates that insufficient integration of nature protection into sectoral policies is one of the key causes of nature degradation and biodiversity loss in Serbia. The proposed Programme addresses this issue only through the development of guidelines and recommendations for integrating nature and biodiversity protection into other sectors. Instead of recommendations, the Programme should provide for binding integration instruments, particularly in the areas of spatial planning, construction, mining, and energy, which place significant pressures on nature and biodiversity in Serbia.

The general objective of the Programme also reflects a lack of ambition and should not be framed as the “improvement of the nature protection system”, since the system itself is not the goal but an instrument for achieving concrete results. Even a well-designed system can remain ineffective if it is subject to political and administrative influences that limit the implementation of nature protection measures. The focus of the Programme should be more clearly directed towards ensuring that habitats and species are in a favourable conservation status, as well as towards the effective management of nature and biodiversity.

The concept of good governance implies the involvement of various stakeholders, functional cooperation mechanisms, transparency, and the application of best practices that enable the achievement of nature protection results regardless of institutional changes. The Draft Programme insufficiently recognises the role of scientific research organisations and civil society organisations as partners in implementing measures, although these actors play a significant role in monitoring, education, developing innovative approaches, and involving the public in nature protection processes.

Of particular concern is that the Programme places excessive focus on procedural activities rather than on concrete nature restoration measures and clear mechanisms for improving the state of biodiversity. In many cases, there is a lack of precise success indicators, a clear division of responsibilities, and a defined financial framework for the implementation of planned activities, which further undermines the implementation and monitoring of the Programme.

The analytical part of the document largely fails to recognise modern approaches that are the focus of European nature protection policies, such as nature-based solutions, ecosystem and landscape restoration, and integrated natural resource management. Although certain European Union policies are mentioned in a declarative manner, these are not translated into concrete measures and guidelines that would enable more effective nature protection in Serbia.

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