EN EN

EUROPEAN COMMISSION

Strasbourg, 6.10.2026 COM(2026) 705 final

COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN

PARLIAMENT, THE EUROPEAN COUNCIL, THE COUNCIL, THE EUROPEAN

ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE

REGIONS

Preparing for a wider Union

{SWD(2026) 705 final}

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Preparing for a wider Union

I. Preparing the Union for enlargement

Enlargement strengthens Europe. It is a long-term investment in Europe’s peace, security,

prosperity and global standing. It increases the Union’s political and economic weight, its

capacity to safeguard its interests and its ability to promote its values.

Russia’s war of aggression against Ukraine and wider threats to European security have made

enlargement a geopolitical imperative. Europe has a direct and immediate interest in bringing

enlargement countries into the Union. A more democratic, stable, and wider Europe also brings

clear benefits to our citizens. By extending the rule of law, democracy and prosperity across

our continent, enlargement can strengthen the Single Market, create new opportunities for trade

and investment, and support economic growth through more consumers and greater innovation.

For Europeans, this means more jobs, more business opportunities, better connected

infrastructure and stronger supply chains. It would also bring mutual opportunities to boost

energy security, transport links and environmental protection.

The accession process remains strictly merit-based and requires sustained progress in

implementing the reforms necessary for membership. In parallel, the Union must advance its

own preparations and further develop gradual integration, bringing tangible benefits to citizens

and businesses ahead of accession.

In her 2023 State of the Union address, President von der Leyen called on the Union to match

the determination of enlargement countries and announced pre-enlargement policy reviews.1

The Granada Declaration that same year set out the parallel responsibilities of enlargement

countries to advance their reforms and of the Union to undertake the necessary internal

preparations.2 The Union must also ensure that its policies, institutions and financing are ready

for enlargement. Both tracks must advance so that the Union and future Member States are

ready for accession.

The Commission’s March 2024 Communication translated that principle into a work

programme covering four areas: values, policies, the budget and governance.3 In June 2024,

the European Council adopted a roadmap for future work on internal reforms and invited the

Commission to present in-depth policy reviews with operational elements in those four areas.4

The Political Guidelines for 2024–2029 committed the Commission to proposals to strengthen

the Union’s capacity to act.5 In parallel, the European Parliament set out its position through

1 Von der Leyen, Ursula, 2023 State of the Union Address – Answering the call of history, Strasbourg,

13 September 2023. 2 European Council, The Granada Declaration, 6 October 2023 3 European Commission, Communication on pre-enlargement reforms and policy reviews, 2024, COM(2024) 146

final. 4 European Council, ‘European Council meeting (27 June 2024) conclusions’, EUCO 15/24, 27 June 2024. 5 Von der Leyen, Ursula, Europe’s Choice – Political Guidelines for the Next European Commission 2024–2029,

18 July 2024.

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its 2023 proposals for Treaty reform and its 2025 report and resolution on the institutional

consequences of enlargement negotiations.6

This Communication responds to the European Council’s mandate, draws on the Parliament’s

position and sets out the policy orientations and proposed actions arising from the reviews.

These proposed actions prepare the Union’s governance, policies and budget for enlargement

and strengthen the protection of its values and the rule of law.

Reinforced gradual integration supports candidate countries’ preparations for membership

through earlier participation in selected Union policies, provided conditions are met, helping

to build administrative capacity and deliver tangible benefits to citizens and businesses ahead

of accession. These efforts form part of a broader process of adaptation, as EU policies continue

to evolve in response to new challenges and a changing geopolitical environment. The prospect

of future enlargement is an integral part of this ongoing reflection on the Union’s policies and

their future development.

Roadmaps for the most advanced negotiating countries will set out clear priorities with

timelines and deliverables, to help the most advanced candidates complete the necessary

reforms and guide the work in the Council. This clarity will help us seize the momentum of

enlargement and prepare for a stronger Union.

Safeguards in accession treaties should ensure continued fulfilment of commitments

undertaken during accession negotiations and provide targeted remedies where serious

shortcomings risk undermining the proper functioning of the Union. Together, these elements

connect the Union’s internal preparations with candidates’ progress towards membership.

II. The pre-enlargement policy reviews

The Commission reviewed the full range of Union policies and areas where enlargement could

affect policy design, implementation or financing. The policy reviews show that the Union can

accommodate a larger membership through targeted adaptations within the existing Treaty

framework and accession treaties.

The accompanying Staff Working Document presents the in-depth sectoral analysis and reform

orientations.7 The assessment does not prejudge the timing or sequence of future accessions,

which will depend on each country’s progress on meeting the conditions for membership and

ratification of the accession treaty by all contracting States in accordance with their respective

constitutional requirements. It distinguishes the adaptations required by enlargement from

ongoing reforms that already take account of the prospect of a larger Union. The Commission

will continue to integrate enlargement considerations when developing policies and adapt

existing frameworks as required. A larger membership adds specific requirements where it

6 European Parliament, resolution of 22 November 2023 on proposals of the European Parliament for the

amendment of the Treaties, 2022 (2022/2051(INL)). European Parliament, resolution of 22 October 2025 on the

institutional consequences of the EU enlargement negotiations (2025/2041(INI)). 7 SWD(2026) 705.

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changes policy targets or allocations, increases the number of regulated entities, extends

common networks and information systems or creates substantial investment needs.

Across policy areas, administrative capacity and implementation are the most recurrent

requirements, both within the EU and in the enlargement countries. Skills, regulatory and

supervisory capacity, interoperable systems and cooperation between administrations must and

will be strengthened before accession. The reviews also point to the benefits of strengthened

gradual integration during the accession process, including for the administrative capacity of

future members.

Given the geopolitical environment, it is imperative for the EU to adapt its governance and

make its decision-making swifter and more effective. By making the most of the possibilities

under the Treaties, the Union will enhance its capacity to act, prepare for future members and

become, in general, fit for the future.

1. Governance

The Lisbon Treaty was designed to improve the functioning of an enlarged Union and to cater

for further enlargements. It extended qualified-majority voting and the ordinary legislative

procedure, introduced the double-majority system in the Council, set the ceiling and principles

for the composition of the European Parliament and provided rules for the composition of the

Commission. It also provided mechanisms through which decision-making can be further

adapted, including passerelle clauses, and facilitated recourse to enhanced cooperation.

These provisions give the Union a broad basis for preparing future enlargements. The

Commission supports Treaty change where needed. In parallel, the Union should make full use

of the possibilities offered by the existing Treaties to strengthen its capacity to act and prepare

for future enlargement.8

Extending qualified-majority decision-making

Qualified-majority voting is already the general rule under the Treaties, but unanimity remains

applicable in several key policy areas.

Passerelle clauses allow the European Council or the Council, subject to the conditions in the

Treaties, to replace unanimity with qualified-majority voting or a special legislative procedure

with the ordinary legislative procedure. Their activation requires unanimity and, in certain

cases, the consent of the European Parliament and national Parliaments. They nonetheless offer

themost direct route to more effective decision-making within the existing Treaty framework.

As set out in previous Communications, the Commission will continue to advocate their use in

areas such as restrictive measures (sanctions), human rights and civilian Common Security and

Defence Policy missions; measures against tax fraud, tax evasion and tax avoidance; fiscal

measures in energy policy; and social protection.9

8 European Commission, Communication on Putting Vision into Concrete Action, 2022, COM(2022) 404;

European Commission, Communication on pre-enlargement reforms and policy reviews, 2024, COM(2024) 146. 9 See Communications ‘A stronger global actor: a more efficient decision-making for EU Common Foreign and

Security Policy’ – COM(2018) 647; ‘Towards a more efficient and democratic decision making in EU tax policy’

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The Treaties provide further flexibility in areas where unanimity applies. In the Common

Foreign and Security Policy, for instance, Member States may use constructive abstention

instead of blocking a decision. Article 31(2) of the Treaty on European Union (TEU), in turn,

permits qualified-majority voting within the Council in defined circumstances, including for

initiatives based on a European Council decision defining the Union’s strategic interests and

objectives and decisions implementing a Council decision defining a Union action or position.

Making full use of these provisions, subject to the conditions laid down in the Treaties, would

enable the Union to act more swiftly and effectively, including on sanctions and civilian

Common Security and Defence Policy missions.

Greater use of qualified-majority voting could be accompanied by appropriate safety measures

for essential national interests. The Union’s legal and political framework already provides

mechanisms that combine more effective decision-making with respect for national

sensitivities:

• Emergency brake provisions enable a Member State to refer a matter subject to qualified-

majority voting to the European Council where it considers that essential national interests

are at stake, in the areas where the Treaties provide for such a possibility.10

• The Ioannina mechanism requires the Council to continue discussions and seek a

satisfactory solution where several Member States oppose a decision, without creating a

right of veto.

These mechanisms can make decision-making more effective while respecting Member States’

essential national interests. The Commission stands ready to engage with the European

Parliament and the Council on appropriate and proportionate safeguards to accompany the

activation of passerelle clauses, taking account of the specific policy area and the essential

national interests concerned.

Optimising current practices

Beyond formal voting rules, the Council often seeks consensus even where qualified-majority

voting applies. Consensus may strengthen political ownership, but it can also delay action.

The Commission therefore invites the Council to make fuller use of qualified-majority voting

where the Treaties provide for it. Clearer timetables, earlier identification of outstanding issues

and timely referral to ministers should facilitate agreement and enable decisions to be taken

without undue delay. The Commission invites the Council to consider reflecting these

objectives in its working methods, in full respect of its institutional autonomy.

These considerations are particularly relevant to the negotiation and conclusion of international

agreements. Recourse to mixed agreements, which require ratification by Member States as

well as conclusion by the Union, can make the process more complex and lengthy. Where an

agreement can be concluded by the Union alone, unnecessary recourse to a mixed agreement

- COM(2019) 8; ‘A more efficient and democratic decision making in EU energy and climate policy’ -

COM(2019) 177; and ‘More efficient decision making. in social policy: Identification of areas for an enhanced

move to qualified majority voting’ - COM(2019) 186. 10 See Article 48 TFEU, Article 82(3) TFEU, and Article 83(3) TFEU.

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should be avoided, in full respect of the allocation of competences under the Treaties.

Appropriate arrangements should ensure Member States’ involvement, including in the work

of bodies established under the agreement. Similarly, when endorsing non-binding

arrangements with third countries or international organisations proposed by the Commission,

the Council should apply qualified majority voting as its default decision-making rule. The

Council’s current practice of requiring a consensus unnecessarily hinders the EU's ability to act

swiftly and effectively on the international stage.

The same issue arises in accession negotiations. Under Article 49 TEU, the Council acts

unanimously on applications for membership. As a matter of practice and under the current

negotiating frameworks, the Council also acts by unanimity when taking intermediate

decisions. The Commission recommends that the Council agree to use qualified-majority

voting for the opening of negotiating clusters and other intermediate decisions in accession

negotiations. Accession would continue to require a unanimous decision by the Council after

consultation of the Commission and consent of the European Parliament, together with

ratification of the accession treaty by all contracting States in accordance with their respective

constitutional requirements.

Moving forward through enhanced cooperation

When the objectives of a Union policy cannot be attained within a reasonable period by the

Union as a whole, the Treaties provide another means of advancing these objectives: enhanced

cooperation.

Enhanced cooperation enables a group of at least nine Member States to establish closer

cooperation in a specific policy area, subject to the conditions laid down in the Treaties.11

Enhanced cooperation has already proved its value. It notably enabled the European Public

Prosecutor’s Office and the Ukraine Support Loan for 2026-2027. These examples show that

differentiated integration can advance common European objectives within the Union’s

institutional framework. The European Public Prosecutor’s Office also shows that successful

cooperation can attract additional Member States over time.

Drawing on this experience, the Commission will review pending proposals to identify where

enhanced cooperation could help overcome a persistent blockage, while allowing delivery on

the objectives of the underlying proposals. The review will assess compliance with the Treaty

conditions, and the readiness of potential participants.

Preparing the institutions for a larger Union

Effective governance also requires institutions that remain fit for purpose. The Treaties and

future accession treaties provide the framework for integrating new Member States and making

the necessary adjustments.

For the Commission, the Treaties provide for a College comprising two thirds of the number

of Member States, based on strictly equal rotation, unless the European Council decides

11 The mechanism is set out in Article 20(2) TEU and Articles 326 to 334 TFEU.

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otherwise. The European Council has so far retained one national from each Member State,12

and the Commission has adapted accordingly, notably through the introduction of the role of

Executive Vice-President. Both models offer advantages. A smaller College allows broader

portfolios and simpler coordination. The current model gives the College first-hand knowledge

of political, economic and administrative realities across the Union. The Treaty default solution

of a smaller College remains available as the Union grows.

The Treaties limit the European Parliament to 750 Members plus the President and require

degressive proportionality. The composition of the European Parliament for the 2024–2029

parliamentary term leaves some scope to accommodate representatives of new Member States

within the Treaty ceiling. Further enlargements will nevertheless require a review of the

allocation of seats. The Parliament will need to balance their representation with its capacity to

function effectively. It is responsible for proposing its future composition, with the final

decision taken unanimously by the European Council.13

The European Council and Council face no equivalent numerical ceiling: each Member State

retains its seat. A larger membership, however, increases demands on Council formations and

preparatory bodies. Working methods, coordination and operational capacity will need to adapt

accordingly.

The Commission will work with the European Parliament and the Council to identify the

decisions required before each accession. This work will aim to reconcile effective functioning

with appropriate representation of citizens and Member States, while respecting each

institution’s responsibilities and procedural autonomy.

These preparations will extend to the practical capacity to operate in a larger Union. Staffing

and recruitment, translation and interpretation, legal revision, secure digital systems and

meeting facilities all require advanced planning. Union agencies must have the expertise and

operational capacity to work with additional national authorities, while Union delegations will

have to cater for additional coordination and external representation needs. The Commission

will coordinate these preparations with the other institutions and bodies.

The Commission’s wider examination of its internal functioning through the ongoing Large

Scale Review will also support enlargement readiness.

Next steps

The Commission will:

12 European Council Decision (EU) 2024/2997 of 28 November 2024 appointing the Commission. Based on

Article 17(5) TEU, the European Council decision of 2013 (Decision 2013/272/EU) sets the number of members

of the European Commission equal to the number of EU Member States. Article 2 provides that the European

Council will review the decision in advance of either of these two milestones, whichever comes first: (1) the

appointment of the subsequent Commission: Decision 2013/272/EU was renewed in 2019 (Decision 2019/1989)

and 2024 (Decision 2024/2997) maintaining the 1-to-1 member ratio; or (2) the accession of the 30th Member

State (if a new country joins the EU and increases the total number of Member States to 30, the European Council

is legally obligated to review the decision before the first Commission following that enlargement takes office). 13 The current practice is that the number of seats for each Member State (and therefore the total number of MEPs

for each legislature) is decided ahead of each election of the European Parliament. At the request of the European

Council, the Parliament is currently preparing a report on a permanent system for the distribution of the seats, see

https://www.europarl.europa.eu/doceo/document/AFCO-PR-758177_EN.pdf .

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• Systematically identify policy initiatives where passerelle clauses should be activated and

issue recommendations to the Council accordingly.

• Encourage greater use of qualified-majority voting where the Treaties allow.

• Review pending proposals and encourage recourse to enhanced cooperation where policy

objectives and legal conditions are met.

• Work with the European Parliament and the Council on the institutional and operational

adjustments required for future accessions.

2. Values and the rule of law

Respect for the rule of law, fundamental rights and democracy are conditions for membership

and foundations of the Union’s functioning.14 These foundations must be effectively protected

in every Member State to ensure mutual trust, judicial cooperation and sound management of

Union funds. Independent courts and effective remedies also protect citizens’ rights and give

businesses confidence that common rules will be applied throughout the Single Market.

To provide this protection, the accession process must establish more than legal alignment.

Institutions must work effectively in practice and reforms must endure. Monitoring, incentives

and enforcement should therefore form a continuous framework extending beyond accession.

This is a responsibility shared by current and future Member States: the Union must apply its

instruments effectively, while enlargement countries establish a sustained record of reform

before accession.

Safeguarding the rule of law before and after accession

This requirement is reflected in the Fundamentals cluster, which opens first, closes last and

determines the overall pace of negotiations.15 Enlargement countries must notably establish

functional democratic institutions, independent and effective justice systems, prevent and

prosecute corruption, uphold fundamental rights including non-discrimination, gender-

equality, and the rights of persons belonging to minorities, protect media freedom and pluralism

and maintain effective checks and balances. In addition, the 2020 revised enlargement

methodology requires anti-corruption work to be mainstreamed through a strong focus in

relevant negotiating chapters.16 Legislative and institutional reforms must produce credible

results.

The annual Enlargement Reports assesses progress made in these reforms and the state of

preparedness in meeting the conditions for membership. The Rule of Law reports complement

that assessment by involving some candidate countries in the same preventive cycle as Member

States on the basis of objective and merit-based criteria. Building on the participation of

14 Articles 2 and 49 TEU. 15 The fundamentals cluster covers the core values and principles on which the EU is built. It includes the EU

acquis related to the rule of law and fundamental rights, the functioning of democratic institutions, public

administration reform, and economic criteria. 16 European Commission, Communication on Enhancing the accession process - A credible EU perspective for

the Western Balkans, 2020, COM(2020) 57 final.

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Albania, Montenegro, North Macedonia and Serbia, the Commission will progressively

include further candidates as and when they become ready.

The recommendations in the enlargement package should guide Union support and gradual

integration. Financial assistance and access to selected benefits should remain linked to

measurable progress, notably through objective-based financing instruments.17 Follow-up will

identify the outstanding reforms and responsible authorities, target technical assistance at

identified implementation gaps and assess results in the next reporting cycle. Incentives must

reflect verified progress, including the independence and effectiveness of the institutions

concerned. This approach has already been implemented under the current objective-based

facilities for Ukraine, the Western Balkans, and Moldova. For the next Multiannual Financial

Framework, the objective-based plans will remain the main implementation vehicle for

enlargement partners, linking payments to the delivery of reforms (including in the area of the

rule of law and anti-corruption) and investments, and, once they become Member States, also

in line with the relevant provisions of the National and Regional Partnership Plans.

The European Public Prosecutor’s Office now forms part of the acquis. This entails that new

Member States must also participate effectively in the office from the date of their accession.

The Commission will assess and, where possible, facilitate countries’ progress in the legal and

operational preparations needed during the negotiations. These include, in particular,

preparatory steps for the appointment of the European Prosecutor and the European Delegated

Prosecutors, as well as any necessary alignment of national criminal rules and procedures so

as to allow the European Public Prosecutor’s Office to effectively exercise its competences in

the territory of the new Member State.

After accession, the Union’s full rule of law toolbox will be deployed to ensure continued

compliance, with a monitoring of the rule of law situation in all Member States under the Rule

of Law report, including recommendations to guide further reforms if needed.

To respond to rule of law challenges, the available legal instruments also include infringement

proceedings, budgetary conditionality, incentives and safeguards notably under the

Multiannual Financial Framework and Article 7 TEU. The basis for more timely and efficient

procedures is an early identification of rule of law concerns. This is the core purpose of the

Rule of Law report, which sets up a cycle for cooperation and support to Member States. The

Commission will continue to draw on evidence from monitoring under the Rule of Law Report,

the tracking of the implementation of its recommendations, as well as infringement proceedings

and assessments of risks to the Union budget to identify persistent breaches earlier. It will

17 Current and future financial instruments include: REGULATION (EU) 2024/792 OF THE EUROPEAN

PARLIAMENT AND OF THE COUNCIL of 29 February 2024 establishing the Ukraine Facility; REGULATION

(EU) 2024/1449 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 14 May 2024 on

establishing the Reform and Growth Facility for the Western Balkans; REGULATION (EU) 2025/535 OF THE

EUROPEAN PARLIAMENT AND OF THE COUNCIL of 18 March 2025 establishing the Reform and Growth

Facility for the Republic of Moldova; REGULATION (EU) 2021/1529 of the European Parliament and of the

Council of 15 September 2021 establishing the Instrument for Pre-Accession assistance (IPA III); REGULATION

(EU) 2021/947 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 9 June 2021 establishing the

Neighbourhood, Development and International Cooperation Instrument – Global Europe, amending and

repealing Decision No 466/2014/EU and repealing Regulation (EU) 2017/1601 and Council Regulation (EC,

Euratom) No 480/2009.

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continue to assess the appropriate response under the relevant instruments, in accordance with

their respective legal requirements, and ensure that their application is coherent and

complementary.

Article 7 addresses a clear risk of a serious breach of the values in Article 2 TEU and, where a

serious and persistent breach is established, allows the Union to suspend rights deriving from

membership, including Council voting rights. Article 7 must retain its central role in addressing

the most serious breaches. Its high procedural thresholds – notably the four-fifths majority and

unanimity requirements – and the absence of set timeframes can, however, hamper timely

action and the effectiveness of this instrument to intervene in real time against serious breaches

of the Article 2 values. A more effective handling of Article 7 procedures, including possible

timeframes, could be explored with the Parliament and the Council. Such issues could be laid

down in interinstitutional arrangements within the existing Treaties. In its discussions with the

Council on Article 7 procedures, the Commission will seek more regular consideration of

outstanding concerns and clearer follow-up to hearings. The accession safeguards proposed in

Part IV would provide additional, temporary instruments.

Protecting fundamental rights

Enlargement extends the protection of the Charter of Fundamental Rights to new Member

States. Enlargement countries must therefore prepare for its effective application before

accession. This requires courts and other relevant independent authorities to be afforded the

protection of their prerogatives, as well as the power and resources needed to enforce these

rules. Along these lines, enlargement countries must be in a position to effectively uphold

fundamental rights enshrined in the Charter of Fundamental Rights, including non-

discrimination, gender equality and the rights of persons belonging to minorities. Upon

accession, they must also comply with the general obligation that all Member States have to

ensure compliance with the Charter of Fundamental Rights of the European Union and to

respect Article 2 TEU values when implementing the EU budget.

The Commission will strengthen cooperation between enlargement country authorities, the EU

Agency for Fundamental Rights and relevant Union networks. Monitoring and technical

assistance will focus on practical enforcement of fundamental rights, including equality and

non-discrimination, data protection and the rights of persons in vulnerable situations. Article

19(1) of the Treaty on the Functioning of the EU (TFEU) requires unanimity in the Council for

the adoption of measures to combat discrimination, following the consent of the European

Parliament.

The Commission will assess whether recourse to the general passerelle clause in Article 48(7)

TEU could facilitate decision-making in this area, strengthen the protection of equality and

non-discrimination, and will make recommendations as appropriate. Safeguards in the

Multiannual Financial Framework proposals, notably the Charter Horizontal Enabling

Condition under the National and Regional Partnership Plans Regulation, are important tools

in ensuring that the Charter of Fundamental Rights is upheld.

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Strengthening democratic resilience

Reforms must also strengthen resilience to threats facing Member States and enlargement

countries alike. Foreign information manipulation and interference, cyberattacks, and pressure

on independent media and civil society cross borders. Vulnerabilities in enlargement countries

can affect the Union, already before accession.

To address these shared threats, the Commission associates enlargement countries with the

implementation of the European Democracy Shield and the work of the European Centre for

Democratic Resilience.18 Such cooperation – together with the High Representative/Vice-

President wherever appropriate – covers electoral integrity, foreign information manipulation

and interference, transparency of political advertising, media freedom, the protection of

journalists and human rights defenders, civic space, media literacy and support for independent

fact-checking, and citizen participation. This cooperation helps authorities and independent

actors identify threats, exchange information and improve their preparedness and response,

while protecting freedom of expression. Reforms that ensure democratic resilience should form

part of accession monitoring and guide technical and financial support. Close cooperation

before accession will strengthen the Union’s collective resilience.

Next steps

The Commission will:

• Extend the Rule of Law Report to other enlargement countries as and when they become

ready.

• Use the enlargement package to identify outstanding reforms, target technical assistance

and assess implementation in the following reporting cycle.

• Strengthen cooperation with enlargement countries on the practical enforcement of

fundamental rights. Focus assistance on the independence and capacity of enforcement

bodies and access to effective remedies.

• Continue to foster practical cooperation with enlargement countries under the European

Democracy Shield, including in the framework of the European Centre for Democratic

Resilience, covering threat assessment, information exchange, support for independent

media and other areas of mutual interest.

• Assess and support countries’ progress – in close cooperation with the European Public

Prosecutor’s Office – on the legislation and operational capacity required for effective

participation in the Office as of accession.

• Engage with the European Parliament and the Council on Article 7 TEU procedures.

18 European Commission, Joint Communication on a European Democracy Shield: Empowering Strong and

Resilient Democracies, 2025, JOIN(2025) 791 final.

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3. Policies

With reliable and effective authorities and respect for common rules, enlargement can

strengthen the impact of Union policies through greater scale. A larger Single Market, better

access to critical raw materials such as rare earths, and enhanced industrial capacities create

opportunities for trade, investment and growth. Stronger energy, transport and digital networks

reduce dependencies and increase security. Wider judicial, police and civil protection

cooperation improves the response to cross-border crime and crises. Future members’

capabilities can strengthen the Union’s external action and defence preparedness.

These gains require effective implementation of common rules and cross-border cooperation,

adequate administrative capacity and targeted investment. The accompanying Staff Working

Document provides the detailed analysis of opportunities and challenges arising from

enlargement, resulting policy gaps and options for policy adaptation. The principal sectoral

conclusions are as follows.

• Freedom, security and justice. Enlargement would extend the Union’s external borders

and widen judicial and law enforcement cooperation. This requires operational cooperation

on security and migration management, effective preparations regarding border

management, asylum and migration systems and trusted participation in common

information systems. Readiness must be tested in practice and accompanied by effective

judicial oversight and data-protection and fundamental rights safeguards.

• Single Market. A larger market would widen opportunities for trade and investment. These

benefits depend on uniform application of the acquis, comparable levels of protection and

effective enforcement, including market surveillance, customs, competition and state aid,

public health, consumer protection and product safety. Demonstration of full and effective

enforcement capacity by candidate countries’ administrations and regulators will be

required before full participation. If appropriate, transitional measures applicable to the free

movement of workers and allowing for gradual opening of EU labour markets after

accession could be envisaged, as in previous enlargement rounds.

• Competitiveness and inclusive growth. Enlargement would strengthen the Union’s

industrial and innovation base and broaden its pool of skills. Closer integration, when

paired with the necessary investment and prioritisation, can strengthen strategic industrial

sectors, European value chains, cooperation in research and innovation and EU policies on

education and skills, cybersecurity and the digital sphere. This requires full alignment with

the Union’s economic security approach and strengthening the investment and

administrative capacity needed to participate effectively in these policies. Integration in the

Customs Union poses particular implementation and investment challenges and requires a

proactive approach ahead of accession accordingly.

• A decarbonised economy and sustainable connectivity. A stronger, larger EU brings an

extended commitment to decarbonise our economy, as well as to clean energy transition

that ensures energy security, while protecting natural resources and boosting the circular

economy. It would boost the EU’s leadership in decarbonisation, clean industries and clean

tech. Integrating energy and transport networks would diversify supply, improve cross-

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border connections and strengthen resilience. This requires substantial investment in energy

diversification, operational systems, interconnections and corridors, compatible market and

technical rules and cooperation between regulators, system operators and neighbouring

Member States. Planning, monitoring and implementation instruments must also be

adapted so that enlargement supports the Union’s energy, climate and environmental

objectives throughout the accession process. Enlargement countries must gradually work

towards attaining the EU objectives and standards in these three policies.

• Cohesion, agriculture and rural development, food and fisheries. Enlargement would

increase both development opportunities and disparities within the Union. Investment

should support convergence, connectivity and structural reform, with allocations reflecting

the framework agreed for the Union budget. National, regional and local authorities must

have the capacity to manage, control and implement EU resources effectively. Future

members would also add substantial agricultural production and strengthen the Union’s

food security potential, while also increasing pressures on markets, and needing income

support to be catered for. Preparations must ensure full compliance with food safety, animal

and plant health, animal welfare, as well as marketing and environmental standards. They

must also strengthen the capacity to administer agricultural support and manage crises.

Fisheries and maritime policies will likewise require effective implementation of common

rules and adequate administrative and control capacity. For Ukraine, the scale, structure

and very high levels of productivity of the agricultural sector warrant the examination of

targeted arrangements that would significantly limit financial support and market access

for sensitive agricultural products, while supporting Ukraine in regaining access to its

historic third-country export markets.

• External relations, security and defence. Future members would add geopolitical weight

and, in some cases, significant operational experience and industrial capacity to the Union’s

external action, defence and security. This means that they must be in full and sustained

alignment with the Common Foreign and Security Policy, including sanctions. Alignment

in this area remains insufficient among certain enlargement countries. Preparations will

connect candidates’ capabilities with defence industrial cooperation, military mobility and

joint work on cyber and hybrid threats.

• Administrative policies. Strong administrative cooperation and capacity, including a solid

anti-fraud framework, are essential for effective implementation of EU rules. Sustained

simplification efforts, interoperable IT systems and pre-accession support and coordination

tools should help enlargement countries prepare for accession.

Next steps

The Commission will:

• Continue to identify, as accession negotiations advance, the legislative adaptations,

administrative preparations and investments required in each policy area, drawing on the

reviews and the accompanying Staff Working Document.

• Work with national administrations, regulators and Union agencies to assess enforcement

capacity and test participation in common information systems before accession.

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• Prepare country-specific support and transitional arrangements where the negotiations

establish a need, including in agriculture, the movement of workers and services, and

participation in common systems (and specify the purpose, duration and review conditions

for those arrangements).

• Reflect the targeted arrangements for Ukraine in the area of agriculture in the Draft

Common Positions related to Cluster 5: Resources, agriculture and cohesion, at an

appropriate moment.

4. Budget

The budget must provide for the policy adaptations and investments identified in the reviews.

The Union budget must support reforms and convergence before accession, accommodate new

Member States without disrupting EU priorities, and protect the Union’s financial interests

throughout. The Commission has made a proposal for a modern Multiannual Financial

Framework for 2028–203419 to help the Union to deliver on its priorities, in particular our

preparations for future enlargement of the Union. The next Multiannual Financial Framework

constitutes the main response to the budgetary questions raised in the March 2024

Communication.20 The Global Europe instrument will cover EU external action financing

under the next Multiannual Financial Framework,21 providing support to help candidate

countries and potential candidates progress along this path. The next Multiannual Financial

Framework also provides support under National and Regional Partnership Plans22 and other

programmes, such as the European Competitiveness Fund,23 from which new Member States

will be able to benefit.

The EU budget also includes a mechanism for the revision of the Multiannual Financial

Framework in the event of accession of new Member States to the Union.24 The main effects

are likely to concern expenditure on agriculture, home affairs and cohesion policy, as well as

new Member States’ contributions to the Union budget, taking account of any transitional or

other arrangements agreed in the accession negotiations.

Financing preparation for membership

Preparation for these funding arrangements begins before accession. Union support helps

candidate countries implement reforms, strengthen administrative capacity and narrow

19 European Commission, Proposal for a Council Regulation laying down the multiannual financial framework

for the years 2028 to 2034, 2025, COM(2025) 571. 20 European Commission, Communication on pre-enlargement reforms and policy reviews, 2024, COM(2024) 146

final. 21 European Commission, Proposal for a Regulation of the European Parliament and of the Council establishing

Global Europe, COM(2025) 551 final. 22 European Commission, Proposal for a Regulation of the European Parliament and of the Council establishing

the European Fund for economic, social and territorial cohesion, agriculture and rural, fisheries and maritime,

prosperity and security for the period 2028-2034 and amending Regulation (EU) 2023/955 and Regulation (EU,

Euratom) 2024/2509, COM(2025) 565 final. 23 European Commission, Proposal for a Regulation on establishing the Europea Competitiveness Fund,

COM(2025) 555 final. 24 European Commission, Proposal for a Regulation laying down the multiannual financial framework for the

years 2028 to 2034, COM(2025) 571 final, Article 11.

14

economic, social and territorial disparities. It also prepares them to apply Union policies and

manage Union funds after accession. The Growth Plans for the Western Balkans and Moldova

and the Ukraine Facility already link financial support to agreed reforms and investments.

Disbursements depend on the fulfilment of defined conditions. This rewards progress and

directs resources towards reforms that advance convergence and accession preparation.

Building on this experience, the proposed Global Europe instrument will place support for

candidate countries within a more coherent and flexible framework. It will combine grants,

loans, budgetary guarantees and technical assistance. Support will be tailored to each country’s

needs, accession progress and the Union’s strategic interests. Loans and guarantees can

leverage the impact of the Union budget and help mobilise further public and private

investment.

Objective-based plans should link this support to reforms and investments. They should also

prepare enlargement countries for the planning, management and control systems that apply to

Member States. In parallel, enlargement countries will progressively participate in Union

spending policies, avoiding a sudden shift at the point of accession.

Preparing accession financial packages

As negotiations approach completion, the Commission will set out the funding transition in a

financial package specific to each country’s accession timeline. Such financial packages would

follow the same approach.

The Commission presented Montenegro’s financial package on 30 June 2026, providing the

first application of this approach.25 Before accession, each candidate country will prepare a

Global Europe Plan keeping in mind the requirements of the proposed National and Regional

Partnership Plans. Upon accession, new Member States will be fully integrated under a

National and Regional Partnership Plan. At the moment of accession, the Global Europe plan

would become part of the National and Regional Partnership Plan as the unallocated

component, and additional envelopes for the Cohesion Policy, Common Agricultural Policy,

Home affairs, and Interreg will be added. This would ensure continuity of implementation of

key reforms and investments, avoid implementation gaps at a critical juncture of Montenegro’s

membership and allow Montenegro to fully participate in the Union budget. Additional

commitment appropriations would avoid reducing funding foreseen for existing Member States

and the transfer of resources already available for Montenegro under Global Europe would

partially offset the costs.

This first package illustrates the method for identifying and accommodating financial

implications as negotiations advance. It neither prejudges the timing of accession nor the

outcome of the Multiannual Financial Framework and accession negotiations, nor the potential

financial packages for other candidates at a later time. It estimates the new Member State’s

allocations and specifies a transition from pre-accession funding to inclusion under the internal

Union programmes. It also identifies the financial impact on the Multiannual Financial

Framework, and addresses own resources, administrative expenditure and any temporary

25 European Commission, Communication on financial package for the accession negotiations with Montenegro,

2026, COM(2026) 334 final.

15

compensation or other financial arrangements, such as the phasing-in of Common Agricultural

Policy support and home funds. The agreed accession terms will provide the basis for the

Commission’s proposal to revise the Multiannual Financial Framework when accession occurs,

if necessary.

Protecting Union funds

The transition from external to internal Union funding requires enlargement countries to be

able to manage Union funds effectively and accountably. They need sound public financial

management, transparent procurement, effective internal control and independent audit. They

must also be able to prevent, detect, investigate and prosecute fraud, corruption and other

irregularities, recover irregular expenditure and cooperate effectively with the Commission, the

European Public Prosecutor’s Office, the European Anti-Fraud Office and other anti-fraud

actors. All this should be tested and demonstrated before accession.

Support under the objective-based plans must remain conditional on reform progress and

improvement of national financial control processes. Payments should be suspended or reduced

where conditions are not met, for instance where serious deficiencies affect financial

management. Technical assistance should address weaknesses identified through accession

monitoring and improve the country’s administrative capacity.

After accession, these controls will be backed by the Union’s budget-protection instruments,

within their respective scopes. The Financial Regulation and programme-specific rules cover

audits, payment suspensions, financial corrections and recoveries. Infringement proceedings

address failures to comply with Union law. The general regime of conditionality addresses rule

of law breaches that affect or seriously risk affecting the Union budget.

Next steps

The Commission will:

• Prepare, under the proposed Global Europe instrument, objective-based country plans that

link accession reforms and investment with the disbursement of funds, with particular

emphasis on progress on the fundamentals.

• Take forward negotiations on Montenegro’s financial package and present other country-

specific packages as other accession negotiations approach completion. Specify

commitment appropriations, funding transitions and the resulting changes to the

Multiannual Financial Framework.

• Support enlargement countries in strengthening their capacity to manage Union funds,

collect own resources, detect, prevent, investigate and prosecute fraud, corruption and other

irregularities, and recover amounts unduly spent through technical assistance, audits and

accession monitoring.

16

III. Reinforcing gradual integration

Union policies have been examined to anticipate a larger membership, and candidates that meet

the relevant conditions should participate earlier in areas of shared interest, in a mutually

beneficial way. Gradual integration supports implementation of the EU acquis and economic

and social convergence during the accession preparations, while allowing citizens and

businesses to benefit progressively from closer integration with the Union. It does not replace

but complements and reinforces the accession process, and should be designed to contribute to

progress in the accession agenda as a whole. It also builds administrative capacity and mutual

trust, helps prepare for membership, while remaining conditional and reversible.

1. A coherent, strategic and predictable approach

The 2020 revised enlargement methodology provides the basis for this approach.26 It opened

the way to closer integration into selected Union policies, the Single Market and Union

programmes, frontloading tangible benefits and obligations of membership before accession.

To make fuller use of these possibilities, earlier participation should be organised through a

coherent, merit-based and reversible framework. Access must be conditional on progress in

accession preparations, readiness in the policies concerned and strategic alignment with the

Union. Candidate countries demonstrating comparable level of preparation in a given policy

area should have access to comparable opportunities. Transparent access conditions should

guide candidates’ reform priorities.

A common framework must be flexible enough to accommodate different routes to

participation. The appropriate pathway depends on each candidate country’s level of

preparation, and the sectors in which earlier participation would bring the greatest mutual

benefits. The applicable legal framework also matters. The Deep and Comprehensive Free

Trade Areas with Ukraine and Moldova provide possibilities that differ from those available

under the Stabilisation and Association Agreements with the Western Balkans.

Whatever the pathway, deeper integration requires sustained alignment with the Union’s

values, acquis and strategic interests of both the EU and its Member States. Respect for EU

values and principles, full alignment with the Common Foreign and Security Policy, including

the implementation of sanctions, should inform both access to integration opportunities and

their continuation. It remains a key requirement for membership. Participation must be

supported by the capacity to enforce the relevant obligations and flanked by mechanisms that

protect the autonomy and uniform interpretation of EU law.

Building on the findings of the policy reviews, the Commission will map existing gradual

integration instruments across policies and enlargement countries and identify opportunities

for gradual integration in specific sectors. These may require legislative adaptations or

administrative measures, and will ultimately depend on the enlargement countries’ decisions to

align and implement Union law ahead of accession.

26 European Commission, Communication on Enhancing the accession process - A credible EU perspective for

the Western Balkans, 2020, COM(2020) 57 final.

17

2. Priorities for deeper integration prior to accession

Single Market, competitiveness and economic security

The Single Market is the first priority for economic convergence. Earlier integration would

open opportunities for Union businesses, strengthen European value chains and reduce

strategic dependencies. The Commission will identify where regulatory alignment, including

with the social acquis, and enforcement capacity allow deeper participation in research,

innovation and industrial cooperation, and wider market access accordingly. Priority should go

to opportunities that advance accession preparations and meet shared economic and strategic

needs, including on the basis of existing agreements for closer economic integration into the

Single Market.

Agreements on Conformity Assessment and Acceptance of Industrial Products, for instance,

should advance where the required alignment has been achieved.

The framework should also accommodate emerging strategic sectors such as semiconductors,

quantum technologies, biotechnology, artificial intelligence and space. Participation will

depend on the rules of each programme and, where relevant, security requirements.

As industrial and market integration deepens, participation in sensitive sectors must be

accompanied by alignment with acquis on investment screening, export controls, sanctions

implementation and the protection of sensitive technologies. Assessments of access should

consider strategic alignment, critical dependencies and the capacity to manage risks to

infrastructure and supply chains. Where those conditions are not met, the scope of participation

should be adjusted under the applicable instrument.

Energy, transport and digital connections

Deeper economic integration also depends on the energy, transport and digital connections that

allow European networks to operate efficiently across a wider Union. Progressive participation

in the TEN-T and TEN-E networks should be supported by investment in cross-border links

and cooperation between regulators, system operators and neighbouring Member States.

Priorities are to secure more diverse energy supplies, resilient transport routes and secure,

interoperable digital infrastructure.27

Transport links require the same combination of investment and operational cooperation,

supported by common technical standards and more efficient cross-border procedures.

Enlargement countries and neighbouring Member States should identify bottlenecks and

prepare the infrastructure and administrative improvements together. This will help ensure that

investment in one part of a corridor improves the reliability of the route as a whole.

The reliability of these networks also depends on secure digital infrastructure and

cybersecurity.

Security, defence and resilience

Protecting critical networks and responding to common threats also require closer security and

defence cooperation before accession. Priorities include defence industrial cooperation,

27 European Commission, Communication on the REPowerEU Plan, 2022, COM(2022) 230.

18

military mobility, cybersecurity and the response to hybrid threats, as well as contributions to

Common Security and Defence Policy missions where appropriate. Participation should reflect

sustained strategic alignment and the capacity to meet the relevant obligations.

For defence industrial cooperation, Security Action for Europe28 and the European Defence

Industry Programme29 provide opportunities for common procurement and closer industrial

cooperation, including with Ukraine, under their respective participation and eligibility rules.

Further opportunities with Ukraine could include building on the association of Ukraine to

European Defence Fund to support defence industry innovations, as well as joint European

Defence Projects of Common Interest (EDPCIs) to reinforce the EU’s defence technological

and industrial base.

Benefits for citizens and businesses

Closer integration must also bring tangible benefits in the daily lives of European citizens and

businesses.

The experience of existing EU programmes demonstrates the added value of bringing people

closer together and fostering gradual integration, notably through Creative Europe, Horizon

Europe and Erasmus+.

Payments and roaming also show how meeting common requirements can deliver such benefits

through the Single Euro Payments Area (SEPA) and Roam Like at Home.

Albania, Moldova, Montenegro, North Macedonia and Serbia have started participating in

SEPA schemes, enabling more efficient cross-border euro payments through participating

providers.

Ukraine and Moldova joined Roam Like at Home on 1 January 2026, extending domestic

roaming conditions to their citizens and Union travellers.

The Council’s June 2026 authorisation of negotiations to extend Roam Like at Home to the

Western Balkans provides a basis for further progress. The Commission will pursue the

necessary agreements and preparations, with participation conditional on regulatory and

operational readiness.

Beyond payments and communications, recognition of qualifications and education and

mobility programmes will widen opportunities for work, study and research, while cooperation

in health and civil protection will improve crisis preparedness. The Commission will support

preparations for further integration and clear information for citizens and businesses.

3. Progressive association with the Union’s institutions and working structures

Delivering these benefits requires closer administrative cooperation. Participation should

therefore extend progressively from Union policies and programmes to Union bodies. This will

28 Council Regulation (EU) 2025/1106 of 27 May 2025 establishing the Security Action for Europe (SAFE)

through the Reinforcement of the European Defence Industry Instrument. 29 Regulation (EU) 2025/2643 of the European Parliament and of the Council of 16 December 2025 establishing

the European Defence Industry Programme and a framework of measures to ensure the timely availability and

supply of defence products.

19

help candidate country administrations build capacity and allow Union institutions and

agencies to test cooperation with future members.

The revised enlargement methodology already envisages observer participation for candidate

countries in key Union meetings. Building on this approach, participation should extend, where

conditions are met, to Union agencies, networks and operational structures in fields where the

candidate has achieved the necessary alignment and implementation capacity. Before

accession, observers would contribute to policy preparation and operational cooperation

without taking part in Union decision-making. Greater observer participation in expert groups

and agency activities should familiarise candidate administrations with Union working

methods and strengthen their capacity to apply Union policies.30

The Commission proposes that appropriate information, consultation and observer

arrangements be put in place following the final Intergovernmental Conference concluding the

accession negotiations, ahead of signature of the accession treaty. It will work with the

European Council and the Council on corresponding arrangements for their meetings and

preparatory bodies. This stage should enable the acceding country to follow developments in

Union policies, prepare its positions and assume its institutional responsibilities at accession,

while respecting institutional autonomy and confidentiality.

Following signature, involvement should deepen further. Under its Rules of Procedure, the

European Parliament may invite the parliament of an acceding country to appoint observers.

The Commission will examine structured political participation in relevant Commission

activities, in full respect of the Treaties, the Commission’s institutional autonomy and the

principle of collegiality. If at this stage candidate countries are also compliant with the Single

Market legislation, preparations would have been completed. Thought should therefore be

given to how candidate countries in this situation could already participate in relevant parts of

the Single Market.

Earlier enlargements offer experience for these preparations. In 2004, after accession,

Commissioners from the new Member States were paired with incumbent Commissioners

without holding separate portfolios until the new Commission took office. Pre-accession

participation cannot, however, confer membership of the College or decision-making rights.

4. Making gradual integration operational

The Commission will launch annual gradual integration dialogues with enlargement partners

progressing with accession-related reforms. Each dialogue will review participation in gradual

integration mechanisms, and identify further opportunities. The follow-up will specify the

outstanding requirements, responsible authorities and technical or financial support needed for

the next stage. Subsequent dialogues will review delivery against these steps.

A dedicated share of support under the proposed Global Europe instrument should finance the

gradual integration needs identified through the dialogues. It would support the investments,

administrative capacity, regulatory implementation and information systems required for

30 For instance, EUIPO, with the EU budget support, started recently to collaborate with intellectual property

offices of some enlargement partners and to offer them support on acquis alignment, capacity building and

enforcement of the EU acquis related to intellectual property.

20

effective participation in Union policies and programmes. Country plans should identify these

needs and sequence financing with the reforms and operational preparations on which

participation depends.

Financing and earlier participation must be matched by continued compliance. Every gradual

integration measure should specify the relevant acquis, the conditions for participation and the

monitoring arrangements. Participation must include continued alignment with an evolving

acquis, effective controls and cooperation with Union bodies.

Where these obligations are not fulfilled, participation must remain reversible. Access should

be suspended or withdrawn where warranted. Corrective measures should be proportionate and

confined to the policy area concerned where the shortcoming is sector-specific. Broader

backsliding on fundamentals or strategic alignment may justify a wider response under the

applicable instruments. Conditions for suspension and restoration should be stated in advance.

Decisions should identify the breach, explain the scope of any restriction and specify the

corrective action required to restore participation.

Next steps

The Commission will:

• Present the mapping and put forward a coherent, strategic and predictable approach to

gradual integration for consultation with Member States.

• Launch annual gradual integration dialogues with enlargement partners progressing with

accession-related reforms. Agree follow-up on outstanding requirements, further

opportunities, responsible authorities and the support needed for delivery.

• Expand participation in Union programmes, agencies, expert groups and operational

structures in line with accession progress. Identify the tasks and administrative preparations

needed for effective participation, subject to the applicable rules.

• Work with the European Parliament, European Council and Council to establish

appropriate information, consultation and observer arrangements after the final

Intergovernmental Conference, and examine further institutional participation following

signature of the accession treaty.

• Identify in country plans under the proposed Global Europe instrument the investments,

capacity and systems required for gradual integration.

• Include enlargement countries in the design of new measures to protect the EU market.

IV. Safeguards in future accession treaties

The track record of compliance built through the negotiation process must continue after

accession. Membership brings wider rights and responsibilities. As the reviews underline, the

enlarged Union depends on effective implementation of common rules. The accession process

establishes durable compliance with the rule of law, democracy and fundamental rights;

21

accession treaty safeguards provide a means of responding to serious failures to maintain that

compliance after accession.These safeguards should complement the Union’s general

instruments by providing temporary and targeted remedies.

1. Purpose and common principles

As announced in the 2025 Communication on EU enlargement policy,31 future accession

treaties should contain stronger safeguards against serious backsliding on commitments

undertaken during negotiations, particularly on the rule of law, democracy and fundamental

rights. The Commission proposes a common framework for these safeguards.

Within this framework, safeguards should have clear grounds for activation and defined periods

of application. Decisions should be duly reasoned and based on objective, solid evidence.

Measures should be subject to judicial scrutiny and regular review, and should be amended or

lifted when the conditions justifying them cease to apply.

Safeguard measures should be proportionate to the nature, gravity and effects of the

shortcomings identified and should not go beyond what is necessary to address them. Measures

should normally target the sector concerned. Where shortcomings are systemic, a broader

response may be warranted within the scope of the relevant safeguard clause. Their scope and

application should strike a balance between protecting the functioning of the Union and

preserving the rights arising from membership.

2. Sectoral safeguards and monitoring before accession

Future accession treaties should retain the three policy safeguards developed through previous

enlargements:

• The economic safeguard clause for serious difficulties affecting a sector of the economy or

a geographical area.

• The internal market safeguard clause for serious breaches to the functioning of the internal

market, threats to the Union’s financial interests, or an imminent risk thereof, caused by

failures to fulfil commitments undertaken during accession negotiations.

• The justice and home affairs safeguard clause for serious shortcomings, or an imminent

risk of such shortcomings, in transposing or implementing the acquis covered by the clause,

including judicial cooperation and mutual recognition.

These safeguards are temporary by design. Previous accession treaties made them available for

three years after accession. Future treaties should significantly extend this period to allow

sufficient time to establish a reliable implementation record. The treaty should also permit

extension of that activation period under defined conditions, on the basis of a Commission

assessment.

The period during which a safeguard clause may be invoked should be distinguished from the

duration of measures adopted under that clause. Measures adopted before the expiry of the

activation period may continue to apply thereafter only for as long as the conditions justifying

31 European Commission, Communication on EU enlargement policy, 2025, COM(2025) 690 final

22

them persist. They should be reviewed regularly and amended or lifted in accordance with the

conditions laid down in the accession treaty.

To support the use of these safeguards, the Commission will assess, from the closure of

negotiations all the way to accession, whether commitments are being implemented and

maintained. It will report regularly to the European Parliament and the Council.

Future accession treaties should also include a general monitoring clause for the period between

signature and accession. This pre-accession monitoring should draw, among others, on the

Commission’s monitoring tables and reports all the way up to accession. Monitoring should

identify shortcomings early and specify the corrective action required. Where serious issues of

concern arise, the Council, acting on a Commission proposal, should be able to adopt

appropriate measures focused on those commitments. The accession treaty should allow

appropriate measures to be decided prior to accession and, where necessary, to take effect from

the first day of membership.

Where monitoring identifies backsliding before the first day of membership and targeted

measures would be insufficient, a postponement clause could provide a last resort instrument.

It would allow accession to be postponed on the basis of a Commission assessment. The clause

should use objective criteria and set a proportionate postponement period. The decision-making

arrangements remain to be specified. The Commission would reassess the outstanding

shortcomings during that period.

3. Institutional safeguard clause

Breaches affecting institutional functioning or membership obligations require protection

beyond sectoral safeguards. These could be addressed through a temporary institutional

safeguard clause, which would address serious breaches of Article 2 TEU values and of the

principle of sincere cooperation. In addition, breaches to the rule of law principles and to the

Charter of Fundamental Rights affecting the implementation of EU funds will be addressed

through the horizontal conditionalities established as part of the National and Regional

Partnership Plans that candidate countries will implement from day one of joining the Union.

Furthermore, the Conditionality Regulation will continue to apply to the entire EU budget.

The response to such breaches should reflect their nature, gravity and effects, and could extend

to suspension of voting rights in the Council in particularly serious cases. Measures should

target the affected policy where possible; systemic shortcomings could justify a broader

response.

Measures would follow a Commission proposal or a reasoned request of Member States. They

would be deemed adopted unless the Council rejected them by qualified majority within a

specified period.

The clause would apply for 15 years after accession. Any measures would be subject to judicial

scrutiny and regular review by the Council. Measures should be reviewed regularly and

amended or lifted when the issues justifying them have been remedied.

The safeguard would complement, not replace, Article 7 TEU. It would provide a temporary,

accession-specific mechanism for exceptional situations during the first years after accession.

23

Article 7 would retain its central role in protecting the Union’s values. Use of the safeguard

must be coordinated with other procedures so that the response is effective and the combined

measures remain proportionate.

4. Complementary arrangements

Full application of the Schengen acquis requires a separate Council decision once the necessary

conditions have been verified. The Commission proposes explicit consideration of rule of law

conditions relevant to mutual trust, including the functioning of justice, anti-corruption

arrangements, policing and border management. These conditions should be assessed in

relation to implementation of the Schengen acquis through the applicable evaluation and

decision-making procedures.

A further option concerns the exercise of decision-making rights during the first years of

membership. A new Member State would undertake, for a limited period, not to oppose Council

and European Council decisions concerning future enlargements and relating to bilateral

disputes. Bilateral issues unrelated to accession criteria should be addressed through

appropriate bilateral or international mechanisms. The commitment would be set out in a

declaration accompanying the accession treaty.

The negotiations may also establish a need for transitional arrangements for free movement of

workers and services, agriculture, sensitive products, funding and participation in common

systems and networks. They should address identified risks and remain proportionate, time-

limited and subject to review where appropriate. Where objective circumstances warrant and

the candidate country agrees, an accession treaty may also provide for specific arrangements –

such as sector-specific safeguard clauses – extending beyond the standard transitional period,

including in agriculture, subject to regular review.

To bring these arrangements into the negotiations, the Commission will submit proposals for

Union positions under Chapter 34 on Institutions, Chapter 35 on Other issues, Chapter 33 on

financial and budgetary provisions and the relevant sectoral chapters where relevant. The

proposals will include the necessary Treaty provisions, annexes and commitments, starting

with Montenegro’s accession arrangements.

Next steps

The Commission will:

• Propose safeguard clauses in accession treaties as appropriate.

• Submit proposals for Union positions under Chapters 34 and 35, including draft treaty

provisions on the above-mentioned safeguards.

• Apply this approach first to Montenegro’s accession arrangements.

V. Turning preparedness into delivery

This Communication and the pre-enlargement reviews set out ways to achieve the Union’s

long-term ambitions and address key questions related to its priorities and policies as well as

its capacity to act in a wider Union. They identify the types of changes and reforms that the EU

24

should consider to make its policy and governance framework future-proof and to harvest the

mutual benefits of enlargement.

The Commission invites the European Parliament and the Council to take forward the

institutional preparations and policy measures within their responsibilities. It will work with

Member States and enlargement countries to connect these preparations with progress in

negotiations, expand gradual integration in strategic areas of mutual interest, and define the

safeguards to be agreed in accession treaties.

To involve citizens and stakeholders in these preparations, the Commission will organise

dialogues – including through the Union’s delegations network – with citizens, businesses,

social partners and civil society in current and future Member States on the mutual benefits of

enlargement, the adaptations required and the safeguards accompanying it.

Building on the experience with previous enlargements, the Commission will propose, in the

2026 enlargement Communication, indicative roadmaps providing a pathway for the next steps

in the accession processes of the most advanced negotiating countries Montenegro, Albania,

Moldova and Ukraine, provided they maintain the pace of reforms.

These roadmaps will prejudge neither the outcome nor the speed of negotiations but will

provide an anchor for the negotiations both for the candidate countries and for the Council.

Based on the revised enlargement methodology that provides for greater predictability, such

roadmaps will allow for better prioritisation, sequencing and monitoring of the process. In line

with the own-merits principle, the pace of accession negotiations will continue to depend on

the negotiating countries progressing and completing the required reforms necessary to meet

the conditions of EU membership.

The accession process will remain rigorous and merit-based, with participation, benefits and

obligations tied to reform delivery, implementation capacity and strategic alignment. But

rigorous and merit-based do not mean slow in delivering for europeans. Citizens and businesses

– from Member States and enlargement countries alike – must be able to experience the

tangible benefits of Europe at every stage of the process.

EN EN

EUROPEAN COMMISSION

Strasbourg, 6.10.2026 SWD(2026) 705 final

COMMISSION STAFF WORKING DOCUMENT

Accompanying the document

COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN

PARLIAMENT, THE EUROPEAN COUNCIL, THE COUNCIL, THE EUROPEAN

ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE

REGIONS

Preparing for a wider Union

{COM(2026) 705 final}

1

STAFF WORKING DOCUMENT – ACCOMPANYING THE COMMUNICATION

‘PREPARING FOR A WIDER UNION’

EXECUTIVE SUMMARY .................................................................................................................................. 3

INTRODUCTION ................................................................................................................................................ 6

1. PREPARING FOR AN EXPANDED AREA OF FREEDOM, SECURITY AND JUSTICE .............. 7

1.1 FREE MOVEMENT OF PERSONS, JUSTICE AND CONSUMER POLICIES................................................................ 7 1.2 HOME AFFAIRS POLICIES ............................................................................................................................. 11

2. A LARGER AND STRONGER SINGLE MARKET ................................................................................. 19

2.1 FREE MOVEMENT OF WORKERS ................................................................................................................... 21 2.2 FREE MOVEMENT OF GOODS........................................................................................................................ 25 2.3 FREEDOM TO PROVIDE SERVICES ................................................................................................................ 27 2.4 FREE MOVEMENT OF CAPITAL ..................................................................................................................... 29 2.5 HEALTH POLICY .......................................................................................................................................... 31 2.6 COMPETITION POLICY ................................................................................................................................. 34

3. COMPETITIVENESS AND INCLUSIVE GROWTH ............................................................................... 36

3.1 ENTERPRISE AND INDUSTRIAL POLICY ........................................................................................................ 36 3.2 RESEARCH AND INNOVATION ...................................................................................................................... 38 3.3 EDUCATION, YOUTH, SPORT AND CULTURE POLICIES .................................................................................. 42 3.4 DIGITAL POLICIES ....................................................................................................................................... 46 3.5 CUSTOMS UNION ........................................................................................................................................ 52 3.6 TAXATION POLICY ...................................................................................................................................... 57 3.7 ECONOMIC POLICIES ................................................................................................................................... 61

4. A DECARBONISED ECONOMY AND SUSTAINABLE CONNECTIVITY ......................................... 64

4.1 CLIMATE AND EMISSION REDUCTION POLICY .............................................................................................. 64 4.2 ENERGY POLICY .......................................................................................................................................... 72 4.3 MOBILITY AND TRANSPORT ........................................................................................................................ 79 4.4 ENVIRONMENT POLICIES ............................................................................................................................. 86

5. COHESION, AGRICULTURE AND RURAL DEVELOPMENT, FOOD AND FISHERIES ............... 90

5.1 REGIONAL AND COHESION POLICY .............................................................................................................. 90 5.2 AGRICULTURE AND RURAL DEVELOPMENT ................................................................................................. 95 5.3 FOOD SAFETY, VETERINARY AND PHYTOSANITARY POLICY ...................................................................... 102 5.4 FISHERIES AND MARITIME POLICY............................................................................................................. 105

6. EXTERNAL RELATIONS - A STRONGER EU IN WORLD AFFAIRS ........................................ 108

6.1 COMMON FOREIGN AND SECURITY POLICY ............................................................................................... 108 6.2 COMMON SECURITY AND DEFENCE POLICY ............................................................................................... 116 6.3 EUROPEAN DEFENCE READINESS ............................................................................................................... 119 6.4 SPACE CAPABILITIES ................................................................................................................................. 122 6.5 TRADE POLICY AND ECONOMIC SECURITY ................................................................................................ 124 6.6 CIVIL PROTECTION AND HUMANITARIAN POLICY ...................................................................................... 129

7. ADMINISTRATIVE POLICIES ........................................................................................................... 131

7.1 EU’S LANGUAGE REGIME AND CAPACITY ................................................................................................. 131 7.2 EUROPEAN STATISTICAL SYSTEM ............................................................................................................. 135 7.3. COMMUNICATING ABOUT THE EU ........................................................................................................... 138 7.5 ANTI-FRAUD POLICY ................................................................................................................................. 143

2

7.6 DIGITAL GOVERNMENT POLICIES .............................................................................................................. 145 7.7 SIMPLIFICATION AND IMPLEMENTATION ................................................................................................... 147

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EXECUTIVE SUMMARY

This staff working document provides the key findings of the Commission’s in-depth sectoral

policy reviews along the seven examined policy clusters. It covers EU sectoral policies that

require specific preparations for enlargement and support the EU’s and enlargement countries’

readiness to tackle the impact of enlargement, grasp key opportunities or critical policy

challenges, and contribute to the pursuit of the EU’s strategic priorities as it enlarges to

welcome new members. It presents EU policy changes and reforms that should help to ensure

that an enlarged Union will remain fit for the future.

Freedom, security and justice

Enlargement has the potential to strengthen the effectiveness of EU justice and home affairs

policies ranging from better cooperation on criminal investigations, including information

exchange, to the protection of consumer rights and the broadening of the geographical scope

of EU fundamental rights. Enlargement would also expand the Schengen area of free

movement and help to manage migration more effectively, in line with the new Pact on

Migration and Asylum, becoming part of the Common European Asylum System. To unlock

this potential, gradual integration of enlargement countries could be deepened in the EU-wide

law enforcement cooperation and border management. This and further cooperation measures

with enlargement partners would also help combat terrorism and organised crime and other

cross-border crimes, including crimes affecting the Union’s financial interests, more

effectively. As part of a more transparent and merit-based approach for full Schengen

integration, advanced enlargement countries could be integrated into the Schengen evaluation

and monitoring mechanism framework before accession.

Single market

The EU can stand to benefit from enhanced mobility, trade, and competition, as well as

supported modernisation and development, through a larger, more diversified single market

resulting from enlargement. For these benefits to materialise swiftly, there is the need for

phased, rules-based gradual integration of enlargement countries into EU structures and

governance mechanisms. Opportunities should also be exploited to support administrative

capacity before accession, such as by leveraging the European Supervisory Authorities in the

financial sector and the Anti-Money Laundering Authority for checks on the administrative

capacity of enlargement countries. Existing single market support tools, including the Single

Market Enforcement Taskforce, could be strengthened already before enlargement, while

certain support tools, such as the Internal Market Information System, or the Single Digital

Gateway can be selectively opened to enlargement countries. Transitional measures have been

applied to manage free movement of workers in previous enlargement rounds and could apply

to future enlargements as well.

Competitiveness and inclusive growth

The EU's competitiveness would be enhanced through enlargement via the removal of trade

barriers, opportunities for scaling up production and access to key inputs, strengthened

infrastructure and connectivity, and thus an enhanced capacity of the Union to compete and

respond to crises. In line with the EU’s pro-active approach on economic security, it will be

important that enlargement countries embrace the EU’s economic security approach and

gradually align with relevant EU legislation while benefiting from effective EU support in the

implementation of policies and programmes relevant to economic security. Gradual integration

can be beneficial in several other areas and through a variety of initiatives, such as by

associating enlargement countries to specific Important Projects of Common European Interest,

to digital and cybersecurity cooperation, including in roaming and Digital innovation hubs, and

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to the Customs Union’s reformed framework, along with associating all enlargement countries

to the Erasmus+ programme.

Green agenda and sustainable connectivity

A larger EU would have a stronger voice on the global stage and give a stronger contribution

to reducing greenhouse gas emissions globally and improving environmental and public health

protection, along with benefiting from more opportunities for energy security and stronger

transport connectivity. A gradually integrated energy and transport connectivity with

enlargement countries is essential for the security and competitiveness of those countries and

of the EU. This can be achieved by facilitating the participation of enlargement countries in

cross-border energy cooperation and include enlargement considerations in the review of the

EU energy security framework, along with the further development of the trans-European

Transport Corridors in enlargement countries and fostering investment in environment

infrastructure.

Agriculture and cohesion

Addressing disparities across regions and the potential impact on the single market for

agricultural products brought by the membership of large producing countries comes with

challenges. At the same time enlargement, if prepared well, allows the EU and enlargement

countries to reap benefits such as greater food security and agri-food competitiveness or a

stronger link between necessary reforms and public investment. In an expanded EU, cohesion

policy will play a key role in supporting convergence and integration into the single market

through an investment and reform agenda, with regions at the centre and focusing on joint

priorities, including promoting economic, social and territorial cohesion.

To prepare for and effectively address the challenges that farmers in the EU and enlargement

countries will face, gradual integration of enlargement countries together with the adoption of

EU production methods and standards will also be essential. Continuity should also be given

to the implementation of the Deep and Comprehensive Free Trade Areas agreements with

Ukraine and with Moldova, providing for opening the EU market for agricultural products in

parallel with the enlargement countries’ alignment with EU standards. Well targeted pre-

accession support and effective administrative capacity building will be essential. At the same

time, on agriculture and access to the market for sensitive agricultural products, transitional

measures and periods may have to be considered

External relations

Enlargement would make the EU stronger and more influential on the global stage, with an

expanded internal market giving the EU greater weight in global trade and politics.

Enlargement would increase the EU’s collective defence capabilities, joint capacity to counter

hybrid threats and shared ability to safeguard its economic security. To maximise the impact

of the EU in international affairs, it is important that enlargement countries align with the EU

common foreign and security policy. This would also facilitate further cooperation in the area

of security and defence already before accession. To develop defence capabilities, enlargement

countries could be progressively associated to defence and defence industrial initiatives. In

addition, the EU and enlargement countries could benefit from closer cooperation on advancing

mutual resilience by gradually associating enlargement countries to relevant EU preparedness

initiatives and actions to counter hybrid threats.

Administrative policies

Effective implementation of EU rules is crucial for a well-functioning and enlarged Union. The

Commission’s enhanced drive for simplification will help accelerate compliance with EU laws,

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benefiting both current and future member states. Pre-accession support and operational tools

like TAIEX and Twinning will be essential in supporting enlargement countries build the

required administrative capacity, ensuring they are well-prepared for accession and

membership obligations. Effective communication on the benefits and challenges of

enlargement is also crucial, both in current EU Member States and in enlargement countries,

to make EU enlargement a success.

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INTRODUCTION

This Staff Working Document accompanies the Communication ‘Preparing for a wider

Union’1. It provides the key findings and reform orientations from the in-depth sectoral policy

reviews. The reviews assessed the extent to which EU policies and governance will be affected

by future enlargements. They examined the EU policy changes and reforms needed to ensure

that an enlarged Union will remain fit for the future. They are an important step within the

broader, longer-term and dynamic EU reform agenda. Several related initiatives have been

already presented, while others are scheduled for adoption following the reviews2. The policy

reviews are distinct from the monitoring of the enlargement countries3 preparations for EU

membership while reflecting the close links and interactions between the two exercises4.

The Commission services and European External Action Service (EEAS) conducted a

comprehensive analysis across all policy areas to assess to what extent these may be impacted

by enlargement. Impacts can be directly triggered by the prospect of enlargement, or they can

be an indirect result when enlargement intensifies the policy and governance challenges faced

by the current Union at 27. Following an initial impact screening, a more detailed examination

was undertaken, concentrating on aspects where significant impacts on policies are most likely.

For other areas, it was generally concluded that policies are either well-suited for enlargement

or that the impacts are small. These findings are not included in this Staff Working Document

in principle to avoid an overly long document. As a result, it is important to note that this

document does not enumerate all the screened policies or activities managed by the

Commission or by extension, EU institutions in specific sectors.

The Commission's analysis focuses on the general impact of enlargement without considering

and addressing specific scenarios in terms of sequencing or time-horizons. This approach

ensures that the exercise does not pre-empt the accession process, which is strictly merit-based.

The Commission primarily considered potential enlargement impacts based on the current state

of the sectoral policy while reflecting the expected effects of several related reform initiatives

that were recently proposed.

When it comes to the budgetary impacts of enlargement on policies, the focus is on expected

funding needs, while indicating, if relevant, how the next generation of funding programmes

may already anticipate for such needs5. In this context it should be noted that the proposed

2028-2034 multiannual financial framework (MFF) regulation 6 includes a revision clause,

which would allow the Commission to take account of the expenditure requirements resulting

1 COM (2026) 705. 2 Such as the Competitiveness Compass, the vision for Agriculture and Food, the Clean Industrial Deal, the White

Paper for European Defence Readiness 2030 and the proposals for the next Multiannual Financial Framework for

2028-2034. See for example COM (2025) 45, COM (2025) 46, COM (2025) 75, JOIN (2025) 120, COM (2025)

500, COM (2025) 570, COM (2025) 870. 3 Enlargement countries include Albania, Bosnia and Herzegovina, Moldova, Montenegro, North Macedonia,

Serbia, Ukraine, Kosovo*, Georgia and Türkiye. The accession process of Georgia is de facto halted, in line with

European Council conclusions. Accession negotiations with Türkiye, a candidate country and a key EU partner

in many areas of joint interest, have been at standstill since 2018, in line with the European Council conclusions.

*This designation is without prejudice to positions on status and is in line with UNSCR 1244/1999 and the ICJ

Opinion on the Kosovo declaration of independence. 4 COM 2025 (690). 5 The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only

and does not prejudge the next Multiannual Financial Framework. The source of financing and scope of Union

financial commitment in the post-2027 period remain subject to the outcome of interinstitutional negotiations on

the MFF 2028-2034 and thereafter shall be determined through the annual budgetary procedure. All appropriations

and staffing allocations as of 2028-2034 are indicative. 6 COM (2025) 571.

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from new countries joining the EU. This ensures that the EU will be able to adjust its financial

framework to respond to the expenditure needs arising from enlargement. In this vein, the

Commission on 30 June 2026 adopted a financial package for Montenegro, proposing how EU

funding and budget-related policies could apply after Montenegro becomes an EU Member

State and how to ensure a smooth transition of the new Member State into internal policies7.

The key results of the in-depth sectoral policy reviews are presented along several key thematic

clusters. Each cluster brings together several closely interrelated policy areas. The clusters are

broadly structured in line with the revised enlargement methodology of 2020. In addition, there

is also a dedicated chapter on administrative policies.

1. PREPARING FOR AN EXPANDED AREA OF FREEDOM, SECURITY AND JUSTICE

1.1 Free movement of persons, justice and consumer policies

The EU’s policies on the free movement of persons, justice and consumers aim to foster a fair,

safe and just society where citizens can move and reside freely within the territory of Member

States8. Justice policy aims to ensure that EU citizens can enjoy fundamental rights and has

provided EU judicial authorities with opportunities for cooperation and EU companies with

legal certainty to operate in the single market. Consumer policy aims to make the EU citizens’

daily life easier in different key areas of the economy. Effective consumer protection also

ensures that the single market functions properly: it safeguards consumers’ rights and promotes

fairer markets.

Expanding the EU will help uphold and further these goals. The reforms that are taking place

in the enlargement countries in these areas may also encourage existing Member States to do

more, learn from recent lessons and replicate good practices.

1.1.1 Challenges and opportunities

Enlargement would increase judicial cooperation and deepen the existing forms of judicial

collaboration. This includes cooperation at the international level in the context of the Council

of Europe, the United Nations Commission on International Trade and the Hague Conference

on Private International Law, where the EU will be able to adopt a stronger common position.

On judicial cooperation in civil matters, enlargement would expand the application of the

acquis already adopted based on mutual trust with benefits for citizens and businesses. On

judicial cooperation in criminal law, enlargement would extend cooperation based on existing

instruments, thereby strengthening the EU’s collective ability to investigate and prosecute

cross-border crime. Based on the experience of an EU with 27 countries, cross-border judicial

cooperation requires mutual trust between Member States on their compliance with EU law

and with the fundamental rights recognised at Treaty level. This is particularly the case for

mutual recognition instruments based on several Framework Decisions, such as the European

Arrest Warrant and for the rules on cross-border access to electronic evidence.

Enlargement would enable the wider use of certain cross-border investigative tools, such as the

European Investigation Order. In addition, Eurojust, as the agency responsible for supporting

7 COM (2026) 334. 8 This chapter covers the policies for consumers, free movement, equality and non-discrimination and anti-

corruption. The justice policies on rule of law, fundamental rights and democracy are discussed in Chapter II.2 of

the Communication.

8

the competent authorities of the Member States in this area, would optimise its work for the

benefit of the new Member States, going beyond the current strategic partnerships in targeted

areas of serious and cross-border crime. Furthermore, enlargement would allow the European

Public Prosecutor’s Office (EPPO) to conduct its investigations and prosecutions of crimes

affecting the Union’s financial interests in more Member States. Given that the EPPO

Regulation ceased to be a measure under enhanced cooperation and has become part of the

acquis9, new Member States will be required to participate in the EPPO.

The addition of new Member States would significantly increase the number of limited liability

companies and partnerships covered by EU company law rules10. This would lead to more

cross-border operations (mergers, divisions, conversions) and searches for company

information in the Business Register Interconnection System, requiring increased cross-border

cooperation between business registers.

Enlargement would bring tangible benefits to consumers, such as a greater choice of goods

and services at competitive prices. At the same time, specific challenges for consumers in

enlargement countries, including lower incomes and limited use of digital financial services,

would need to guide future EU consumer policies. Cost of living concerns, and being able to

afford everyday expenses, are already prevalent among consumers in the EU, and may increase

in an expanded EU. Affordability is the top perceived barrier to sustainable consumption across

the EU. For consumers in the new Member States with less spending power, this factor may be

even more important.

Enlargement would also lead to more products circulating in the EU market. Coupled with a

rise in online trade from third countries, this will require such products to be checked for

conformity with the General Product Safety Regulation. Sufficient administrative and

organisational structures and enforcement will need to be ensured in the new Member States

(for instance, the establishment of a new infrastructure of market surveillance authorities and

Safety Gate system). Related to product safety, consumers in the enlargement countries will be

protected against the harms caused by unsafe and defective products, including AI systems and

software, under the revised Product Liability Directive. Additionally, while enlargement could

present an opportunity to fight against industrialised fraud in these countries, a low level of

enforcement could also lead to more notifications on consumer fraud.

Extending EU equality and non-discrimination legislation to the enlargement partners is

expected to have several positive implications. These will include aligning protection from

discrimination on all grounds with the EU standards, reinforced fight against biases and

stereotypes and improved access to public services and social inclusion. In this context,

enlargement can also help address human rights issues related to treatment of migrants, asylum-

seekers and refugees, especially in the Western Balkans. Enlargement could also exacerbate

current challenges faced by the EU on equality and related matters. Given the significant

challenges faced by the large Roma population in some enlargement countries, sustained efforts

in this area by the new Member States will remain essential. Efforts are also needed in

combatting discrimination faced by other ethnic minorities. Furthermore, enlargement

countries experience challenges in upholding the right to non-discrimination, including

9 Commission Decision (EU) 2026/1701 10 July 2026 confirming the participation of Hungary in the enhanced

cooperation on the establishment of the European Public Prosecutor’s Office and Commission Notice concerning

the effects of Commission Decision (EU) 2026/1701 of 10 July 2026 on Regulation (EU) 2017/1939

implementing enhanced cooperation on the establishment of the European Public Prosecutor’s Office, which

ceases to be an act under enhanced cooperation and becomes part of the acquis. 10 Limited liability companies, their cross-border branches and partnerships currently amount to 16, 4 and 2

million, respectively.

9

tackling violence, hatred and discrimination as well as in ensuring equality of LGBTIQ+

persons, exacerbated by narratives against them, and in ensuring the full participation of

persons with disabilities in the economy, education and society at large. At the same time, most

enlargement countries support policies to strengthen gender equality and to prevent and address

gender-based and domestic violence and all, except for Kosovo due to its status, are Parties to

the Istanbul Convention11.

Expanding the EU will help to fight corruption. With EU instruments to be applied to the new

Member States, positive effects in protecting democracy, the economy and security are

expected. The fight against corruption is prioritised in the accession process, looking at both

prevention and repression of corruption.Issues in enlargement countries range from weak

institutional cooperation in corruption cases, insufficient staffing of authorities that investigate

corruption to legal frameworks that create a high risk of corruption (e.g. in public procurement).

This was evidenced by the annual enlargement reports and the Rule of Law reports, which now

also include four enlargement countries12.

1.1.2 Impact of enlargement on free movement of persons, justice and consumer policies

Policy aspects

From a purely legal perspective, enlargement might not have any immediate impacts on the

policies concerned, as the current EU legal framework is fit for an expanded EU. However,

the administrative burden for Member States in implementing the policies may increase in

some areas. For example, in the case of free movement of persons, a higher number of mobile

EU citizens also implies additional work for the authorities dealing with residence registrations

and cross-border social security coordination. Already today, some Member States face

difficulties in providing timely services to mobile EU citizens and their family members, with

LGBTIQ+ persons, persons with disabilities and families facing additional obstacles.

Institutional aspects

Enlargement may imply more complex decision-making in areas covered by unanimity. These

areas include, among others, family law, measures on identity cards, equality and certain areas

of non-discrimination, EU legal forms for companies, and the amendment of Regulation (EU)

2017/1939 on the establishment of the European Public Prosecutor’s Office (EPPO). The

European Council’s unanimous decision is also required to extend the competence of the EPPO

to serious crimes with a cross-border dimension other than crimes affecting the financial

interests of the EU13.

Budgetary aspects

Currently, the two main EU programmes in this field, the Citizens, Equality, Rights and

Values (CERV) programme and the Justice programme, are both already open for

participation by enlargement countries. Some of the enlargement countries have negotiated,

signed and ratified agreements with the EU enabling them to participate.

The accession of new countries to the EU might entail new actions with beneficiaries from

these countries. Under the current rules, this would imply a growing base of applicants. This

would possibly make some of the calls for projects more competitive. In addition, the co-

11 Council of Europe Treaty Series - No. 210 - Council of Europe Convention on preventing and combating

violence against women and domestic violence, Istanbul, 11.V.2011. 12 COM (2026) 900, SWD (2026) 928, (Albania); SWD (2026) 929, (Montenegro); SWD (2026) 930, (North

Macedonia); SWD (2026) 931(Serbia). 13 Article 86(4) TFEU.

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financing requirements could be more challenging for civil society organisations (CSOs)

promoting equality, in particular for LGBTIQ+ persons, and those working to reach out to

persons with a minority racial or ethnic background, in the current global context where

corporate partnerships and funding from other governments, including third countries, is at

stake.

Considering that recent EU law and upcoming legislative initiatives in the area of justice all

now have significant digitalisation elements, enlargement might require more resources for

justice policies together with needs and policy priorities for judicial training, judicial

cooperation and access to justice.

Enlargement would require adequate administrative and financial resources to ensure the

effective implementation of EU justice and consumer policies. A significant effort would be

needed to align the enforcement efficiency and / or compliance in new Member States with that

of current Member States. This would concern in particular authorities, such as consumer

enforcement bodies and associations, data protection authorities, judicial bodies, alternative

dispute resolution bodies. The resources needs of relevant EU agencies and bodies, for

example, the EPPO, Eurojust, the European Data Protection Board, the EU Agency for

Fundamental Rights, and European Institute for Gender Equality would also need to be further

re-assessed. In the new MFF 2028-2034 proposal it is proposed that decentralised agencies be

reinforced while maintaining budget flexibility to be able to adjust.

In light of the EU’s reinforced emphasis on the fight against corruption across the Union with

the new EU Anti-Corruption Directive and the upcoming first EU Anti-Corruption Strategy,

sufficient resources will be needed to help enlargement countries meaningfully improve their

fight against corruption and keep them up to speed with the changing regulatory landscape,

both in providing expertise and building capacity.

1.1.3 Policy gaps and delivery risks

The effectiveness of some instruments in an expanded EU will depend on the level of trust and

compliance that can be ensured between a higher number of Member States, by way of

example, in the field of judicial cooperation in civil law matters, in criminal law14 and in

company law. The principle of mutual trust is based on the premise that EU Member States

share a set of common values and is therefore closely related to the rule of law and values

policy strand discussion and the gaps and measures identified in this context.15

1.1.4 Reform orientations

To reduce the administrative burden resulting from the possible need to register EU citizens

making use of the right to free movement, the Commission could explore to what extent

available and upcoming policy instruments (Single Digital Gateway, EU Digital Identity

Wallet, digital travel credentials, the European Social Security Pass, ESPASS) could be (better)

utilised. This approach is enlargement-neutral, meaning that it is expected to bring benefits to

Member States even in the absence of the addition of new Member States.

14 EU criminal law has some particularities as it includes several Framework Decisions such as the European

Arrest Warrant. These instruments (except for the conventions and international agreements with third countries)

are based on the principle of mutual recognition, i.e. enabling a judicial authority to transmit a decision directly

to an authority in another EU country and to have it recognised and executed without any further formality (with

some exceptions) and provide for a detailed framework for cross-border cooperation between Member States. 15 See Chapter II.2 of the Communication.

11

Establishing robust monitoring mechanisms (including through comprehensive data

collection, which could be conducted in partnership with the EU Fundamental Rights Agency)

will be needed in all areas related to equality and non-discrimination.

The EU anti-corruption policy area is expected to be further developed in the coming years,

based on a strategy to be presented in 2026. The EU Directive on combating corruption entered

into force on 31 May 2026. An enlargement of the EU may require a revision of those initiatives

to reflect the nature of corruption risks in enlargement partners.

1.2 Home affairs policies

Home affairs policies contribute to a safer, more resilient and prosperous Europe. They

strengthen cross-border cooperation on law enforcement and border management and help to

fight terrorism, organised crime and drug trafficking. They are essential to protect critical

infrastructure and strengthen the resilience of critical in the online and offline dimension. They

fight hybrid threats and create conditions for stability, trust and freedom of movement, which

are key foundations for economic growth and social cohesion. They also underpin an effective,

sustainable, humanitarian safe European migration policy. This includes legal migration,

integration as well as addressing, in line with EU and international law, including fundamental

rights. The Pact on Migration and Asylum together with the new Common European system

on returns provide for a comprehensive migration framework.

A key overarching objective of home affairs policies is to ensure the integrity and security of

the Schengen area. The Schengen system involves the abolishment of checks at the internal

borders and the coordinated implementation of a single comprehensive set of rules at external

borders, in third countries and within the Schengen area to ensure a high level of security and

freedom for its citizens. As a core element of EU membership, full application of the Schengen

acquis will allow for economic growth, cross-border exchanges and increased prosperity in an

expanded EU. As laid down in the Negotiating Frameworks, new Member States will not join

the Schengen area upon accession but only after a subsequent Council decision, confirming

that all conditions are met.

1.2.1 Impact of enlargement on home affairs policies

Policies in the home affairs area would likely be impacted to some degree as a result of

enlargement.

Enlargement could enhance the effectiveness of home affairs policies. This would happen by

encouraging greater regional and cross-border cooperation and integrating new perspectives

and resources into the EU’s migration, security frameworks and, overall, into Schengen

cooperation. However, due to variable geometry participation in the relevant EU acquis, certain

areas may inevitably face challenges and/or are particularly sensitive to a possible incomplete

and/or incorrect implementation of the acquis, legally or in practice.

On the management of borders and irregular migration, the EU’s integrated border

managementpolicy would cover a larger (geographical) area and the EU’s external borders

would include new neighbouring countries. This could bring risks such as increased migratory

pressure and changes in the pattern of migratory routes, affecting irregular migration and

associated human rights risks, acts of sabotage and hybrid attacks, including through the

instrumentalisation of migrants, requiring effective common response and integrated border

management, while ensuring full respect of fundamental rights. The Western Balkans are likely

to continue to play an important role both as a transit and destination region. Nonetheless, the

Western Balkans also give the EU a more evenly distributed external frontier, allowing for

12

greater shared responsibility, promoting solidarity and strengthening the EU's burden-sharing

system.

Once new Member States have joined the EU, they are automatically entitled and obliged to

join the Schengen area without internal borders. Joining the Schengen area in full would

lead to transformative changes, due to geographical expansion. Considering a different security

and migratory environment, a more fundamental review of the Schengen system in terms of

external border and internal security aspects may be necessary. To ensure that new Member

States can fully benefit from the Schengen system, ongoing efforts to improve implementation,

including through the Schengen evaluation and monitoring mechanism, need to be maintained

and stepped up.

A wider Schengen area could impact migrant smuggling and trafficking in human beings.

The removal of internal border controls may have an impact on the Eastern Mediterranean

migratory route; the Western Balkans region may become not only a transit region but also a

destination region. The countries in the region would have to rapidly adapt to these

developments and, in line with the relevant legal provisions, and human rights obligations,

consolidate national capacity, strengthen internal and cross-border cooperation and exchange

information. Effectively detecting, investigating and prosecuting migrant smuggling and

trafficking in human beings is already a challenge for enlargement countries in the Western

Balkans region. They receive substantial assistance from the EU with some successes, as

evidenced by the reduction of irregular migration through the Western Balkan region.

Sustained efforts to prevent, detect and combat migrant smuggling and trafficking in human

beings and to protect the victims across the enlarged EU will be necessary, in line with the EU

Strategy on combatting trafficking in human beings.

As migrant smuggling and trafficking in human beings are of serious concern, the EU is

committed to strengthening cooperation in the framework of the Global Alliance to Counter

Migrant Smuggling, through a comprehensive whole-of-route approach. The Global Alliance

Joint Declaration, presented in December 2025, and endorsed by 62 partners including the

Western Balkans, is a signal of a political commitment to tackle migrant smuggling and

irregular migration based on the whole-of-route approach. These political commitments will

be operationalised in the Global Alliance Work Plan for 2026-2028, focusing in particular on

strengthening the legal framework and capacity of partner countries to tackle these phenomena,

to fight digital smuggling, follow-the-money and irregular migration by air.

Under the Pact on Migration and Asylum the Asylum Procedure Regulation and the Asylum

and Migration Management Regulation in particular are relevant for enlargement. As regards

the Asylum Procedure Regulation, provisions related to adequate capacity for the mandatory

border procedure (both at EU and national level) and related to the EU list of safe countries of

origin are of importance. The Asylum and Migration Management Regulation establishes a

comprehensive set of rules in the area of determining the Member State responsible for

examining an application for international protection registered in the Member States and

introduces a permanent solidarity mechanism (minimum thresholds for solidarity measures).

The 5-year European Asylum and Migration Management Strategy adopted on 29 January

2026 establishes further strategic vision, which needs enlargement countries, aligning their

migration management goals with those of the EU16.

The EU Agency for Asylum would need to develop significant capacities to support

operational challenges in the enlarged areas. This would also require tailoring dedicated

technical assistance tools, guidelines, and country of origin information material. The ongoing

16 COM (2026) 45.

13

assistance provided to enlargement countries might be transformed into operating plans to

ensure enhanced support.

Frontex (the European Border and Coast Guard Agency) will need to review its activities on

operational cooperation (e.g. situational awareness, risks and vulnerability assessment). It will

also need to develop its capacities to support the new Member States in protecting the expanded

external borders. Such border management support would take place in line with the conditions

set out in the European Border and Coast Guards Regulation17 and therefore upon request by

Member States. Nearly all enlargement partners already host Frontex operations under status

agreements. They all exchange information, including risk analysis information with Frontex,

and therefore we have already gained a good insight and are prepared for their future roles. The

new Member States must contribute to the operational capabilities of Frontex with staff and

equipment in numbers to be determined in due time. To that end, the European Border and

Coast Guard Regulation would need to be amended.

Enlargement would result in strengthened cross-border cooperation over the medium to long

term in the area of fight against drug trafficking, counterterrorism and prevention of

violent extremism. It would bolster the EU's overall capacity to respond to complex and

transnational security challenges and create a more unified and resilient approach to preventing

and combating terrorism. The new Joint Action Plan on Preventing and Countering of

Terrorism and Violent Extremism, signed during the Justice and Home Affairs Ministerial in

October 2025 in Sarajevo, sets an adequate framework to improve the counterterrorism

capacities and enhance cooperation with the Western Balkans partners. Within the Joint Action

Plan architecture, the EU Knowledge Hub on prevention of radicalisation will keep supporting

the partners through regional activities, while progressively integrating them into the general

EU prevention framework.

The enlargement countries’ authorities would also have better access to Europol’s tools,

analyses, services and, most notably, to the agency’s relevant databases in compliance with its

legal mandate. Granting these countries access to advanced capabilities, such as secure

information processing and analysis services and tools, forensic capabilities including on

crypto assets, and artificial intelligence-enabled applications will boost the EU’s capacity to

conduct major cross-border investigations in those regions. They will also be fully integrated

in the threat assessment cycle led by the agency. Enlargement would also expand the

geographical scope of Europol’s operations with regard to anti-terrorism policies.

When it comes to internal security, enlargement presents opportunities and challenges. Due

to the inherently transnational nature of organised crime, the enlargement countries are already

of key relevance for this policy area. Organised criminal groups are active in several

enlargement countries and use them as hubs for their activities. These are active in areas like drug and arms trafficking, trafficking in human beings and the smuggling of goods. The

Western Balkans region remains a key source and transit route for illicit trade flows, for

instance for firearms or drugs. Despite efforts in these countries to fight organised crime, their

institutional capacity is often still insufficient, including their ability to conduct financial

investigations. However, the alignment with and effective implementation of existing anti-

money laundering and asset recovery legislation and the future new EU legal framework on

organised crime, which enlargement countries will be required to convert into national law

upon joining the Union, will strengthen the countries' capacities to more effectively counter the

17 Regulation (EU) 2019/1896 of the European Parliament and of the Council of 13 November 2019 on the

European Border and Coast Guard and repealing Regulations (EU) No 1052/2013 and (EU) 2016/1624. OJ L 295,

14.11.2019, p. 1–. ELI: http://data.europa.eu/eli/reg/2019/1896/oj

14

threats posed by criminal networks.

In parallel, increased operational cooperation among the relevant authorities of EU Member

States and the enlargement countries, including in relation to financial investigations and asset

recovery, is crucial to step up efforts in fighting organised crime. As the impact of digitalisation

grows stronger over time, enlargement countries will need to continue to update their capacity

to fight cybercrime and retrieve and exchange digital evidence.

At the same time, the ongoing work to tackle corruption issues in enlargement countries needs

to continue to avoid that it hampers their capacity to tackle organised crime. Enhanced and

effective law enforcement cooperation will therefore become indispensable for maintaining

internal security. This will be the case in particular in an expanded Schengen area without

internal border controls. In parallel, increased cooperation will help to combat organised crime

in Europe in general. Enlargement countries already display a willingness to engage and

cooperate actively with EU Member States in the European Multidisciplinary Platform

Against Criminal Threats (EMPACT). The platform offers enlargement countries a practical

bridge between strategic alignment with the EU security acquis and concrete operational

cooperation against serious and organised crime. By fully integrating enlargement countries

in the EMPACT cycle, they can better align with EU priorities their national priorities in

fighting crimes, strengthen intelligence-led policing, and build experience in multi-agency and

cross-border operations.

Another tool to step up cooperation with enlargement countries on combatting crime are the

Operational Task Forces between Member States and coordinated by Europol, where third

countries can participate. As highlighted by the EMPACT firearms and explosives operational

action plan, several enlargement countries have been involved in past or current armed

conflicts, making the availability of illegal firearms, ammunition and explosives a potential

concern for their regions. The impact in the mid- to long term could be an increase in illicit

firearms and other small arms and light weapons (SALW) within the EU stemming from

enlargement countries.

Effective cross-border information exchange will also be essential in tackling organised

crime. Instruments such as the Prüm II Regulation and the Directive on information exchange

between law enforcement authorities will play a central role in enabling swift and secure data

sharing between existing and future Member States18. The gradual integration of enlargement

countries into these legal and operational frameworks would be a crucial step towards aligning

their systems with EU standards. This would contribute directly to the EU’s internal security

and its collective ability to tackle serious and organised crime effectively.

There are several policy areas that would remain largely unaffected by the accession of new

Member States and can be considered 'fit for enlargement'. These include EU visa lists, the EU

legal migration directives, the Union Resettlement and Humanitarian Admission Framework,

the law enforcement cooperation acquis, organised crime and drugs policies, the fight against

cybercrime, preventing and combating child sexual abuse, e-evidence, combating migrant

smuggling and trafficking in human beings, as well as the mandates of Europol and the EU

Agency for Law Enforcement Training (CEPOL).

18 The Directive improves the conditions for timely and efficient sharing of criminal intelligence between Member

States, setting clear obligations and deadlines for information responses. Complementing this, the Prüm II

Regulation significantly improves the automation and scope of data exchange (such as fingerprints, DNA profiles,

facial images, police records, and vehicle registration data) among Member States’ law enforcement authorities.

It also streamlines access to these datasets via a central router, ensuring faster cross-border exchanges.

15

Institutional aspects

The policy making process might become more challenging in operational law enforcement

cooperation, governed by unanimity19.A more transparent and predictable process along with

robust requirements may also be envisagedtowards integrating a new Member State into the

Schengen area with the focus on meeting all established conditions for full participation20.

Budgetary aspects

The Commission Communication on ‘The road to the next multiannual financial framework’21

underscores the importance of safeguarding a high level of freedom and security for our

citizens, while ensuring the effective functioning of the Schengen area, including through

reinforced presence and cooperation in third countries, as regional stability has a direct impact

on the EU’s external borders and shapes both migratory and security risks. Considering the

critical importance of strengthening the EU’s capacity in this context, the Commission proposal

of 16 July 2025 triples financial support – amounting to EUR 81 billion – for the Home Affairs

area under the next MFF 2028-2034, of which EUR 21,5 billion is addressed to the HOME

agencies.

EU enlargement would require financial investments and carry budgetary implications that

need to be considered in a timely manner. This includes the question on how these will help

bridge gaps and enhance the effectiveness of policies in an enlarged Union and Schengen area.

Timely identification of the required funding and human resources will be key to adequately

addressing the significant opportunities and challenges which enlargement represents for

migration and border management, as well as for internal security, thereby contributing to a

well-functioning Schengen area. It will be important to ensure sufficient flexibility in the

structure and implementation of funding to allow a common EU response tailored to pressing

needs and new challenges. The Commission proposal of 16 July 2025 provides for the

possibility to use the EU facility, including for the Home Affairs area, to meet flexibility needs

in the 2028-2034 financial period.

In the area of border management and considering the implications for the Schengen area as a

whole, funding needs would likely increase. In particular, the protection and integrated

management of Ukraine’s external border would require adequate support. The full alignment

of enlargement countries’ visa policy with EU standards and the implementation of the rules

on interoperability of IT systems and digitalisation of travel documents (once in place at EU

level) would also require EU support. Direct financial benefits and savings would be available

once these countries are part of the Schengen area without internal frontiers. In the short and

mid-term, for example, technical upgrades and update of the numerous outdated border

crossing points in terms of IT infrastructure for border checks, as well as upgrading

infrastructure, equipment and training in line with EU standards point to investment needs in

those new Member States whose national administrations might not be adequately prepared.

As countries progress towards full Schengen integration, dedicated technical, administrative

and financial resources might be required, both at national and central level, for the setting-up

and operation of fully functioning large-scale IT systems.

On EU home affairs agencies (e.g. Frontex, European Union Agency for Asylum), eu-LISA,

Europol), potential transitions towards more centralised solutions would also have financial

implications: in terms of impact on their work, adequate resources would be needed to meet an

increasing number of requests for operational and technical assistance. While central solutions

19 Articles 87 and 89 TFEU. 20 Unanimity requirement issues are covered in greater detail in Chapter II.1 of the Communication. 21 COM (2025) 46.

16

would entail increased costs at EU level for certain agencies, such as eu-LISA, such solutions

would lead to a decrease of national costs (currently also supported by EU funding for current

Member States).

Additional resources could be needed by eu-LISA and Europol to ensure that infrastructure

for the exchange of data (routers, SIENA) are available to an increased number of countries.

Europol would also need resources to carry out additional tasks to support future Member

States in monitoring and referring terrorist content online, including through the extension of

access to PERCI (platform developed to support the implementation of the Regulation on

terrorist content online and transmitting referrals), which would require technical adaptations

as well as capacity building in new Member States (i.e. organisation of Internet Referral Days).

In addition, Europol might need to expand its support measures (i.e. training, technical

assistance, capacity-building support and knowledge sharing initiatives) to future Member

States regarding actions aimed at tackling child sexual abuse, as well as other crime areas such

as organised crime, cybercrime or financial crime.

For CEPOL, enlargement is expected to increase demand for training and resources, including

notably the increased need for training tailored to the specific needs of law enforcement

officials in new Member States (such as limited resources, underdeveloped institutional

frameworks, different modalities, gaps in technical expertise and potentially in the national

training offer for implementing EU policies/tools), and to the language and cultural diversity

of a larger area and operational strain on existing platforms (current e-learning platforms,

training networks, and exchange programmes).

Enlargement would have an impact in terms of resources when it comes to the EU Drugs

Agency (EUDA) as the countries will have to appoint a national focal point who will be part

of the agency’s information network on drugs and drug addiction (Reitox) and participate in

the EU Early Warning System. The countries will also have to continue the efforts to set-up

and ensure the functioning of their national early warning systems and national drug

observatories to participate in the work of EUDA.

Enlargement is also likely to pose greater demands on the preparation of the EU Terrorism

Situation and Trend Report (TE-SAT), as larger membership will result in more data to collect,

process, and analyse. This will require enhanced analytical capabilities and potentially the

adoption of new methodologies to ensure timely and comprehensive assessments.

1.2.2 Policy gaps and delivery risks

Some current EU policies might require adaptations in an expanded EU due to increasing

complexities and challenges that call for assessing current governance models and the impact

on migration management, triggering the need to evaluate mechanisms and thresholds.

On Schengen cooperation (including policies on border management, visas, large-scale IT-

systems, police cooperation and return of third-country nationals in irregular stay), which is a

shared competence, Member States have a crucial role to play in implementation. The future

enlargement of the EU and the resulting wider Schengen area, together with the obligation to

deliver on the Treaty-based policy objective to offer citizens an area of freedom, security and

justice without internal frontiers, may justify moving towards a more centralised approach

based on more effective common governance. This would need to happen in respect of Member

States’ competences (and sensitivities). The geopolitical situation of some enlargement

partners may also require reflection on the nature of border management, adapting to new

operational needs.

It will also be crucial to ensure consistent and accurate implementation of rules under the Pact

17

on Migration and Asylum to avoid unauthorised onwards movements both from and to the

new Member States.

On counterterrorism, the integration of new Member States will require updates to the EU’s

counter-terrorism frameworks to accommodate additional stakeholders, potentially requiring

increased resources and coordination efforts also at the Europol’s European Counter-

Terrorism Centre.

1.2.3 Reform orientations

To fully realise the benefits of a wider Schengen, the EU should use the time ahead to deepen

and strengthen Schengen, ensuring it can operate effectively with more members and is adapted

to the new geopolitical environment. In this context, full implementation of the structural

reforms identified through the Schengen evaluation and monitoring mechanism is imperative,

building on ongoing efforts to ensure Schengen rules are implemented to the highest standards.

A stronger Schengen governance framework is essential to ensure the implementation of

these reforms, as well as strengthen mutual trust and mutual recognition. This will allow an

area without internal borders to be created and maintained.

As new Member States will eventually be required to join the Schengen area without internal

borders, new approaches with more transparent and robust requirements should be considered

to allow for a well-supported integration process into the Schengen area, ensuring that it

delivers benefits both for new Member States and for the Schengen area as a whole.

The period between accession to the EU and the actual lifting of internal border control varied

in the past between three years for Austria to more than nine years for Croatia and 18 years for

Bulgaria and Romania. The integration of Bulgaria and Romania into the Schengen area merits

renewed reflection on the need to revise the provision on the full application of the Schengen

acquis in Accession Treaties. While following its assessment of technical readiness the

Commission confirmed that both Member States were ready to become part of the Schengen

area in 2011 as set out in their Accession Treaty, the Council only considered that all ‘necessary

conditions’ were met in December 2024. A new merit-based process that matches the reality

of how integration into the Schengen area works in practice is to be established, which is

grounded in common, objective and transparent criteria. This would better reflect evolving

realities and strengthen – not erode – the mutual trust needed for a well-functioning Schengen

area.

A more centralised approach could be considered towards border management via for

example additional roles and responsibilities for EU agencies, accompanied by a revised

governance model. This would make these agencies more operational and more accountable.

The upcoming revision of the Frontex mandate will strengthen the Agency and make it more

agile and effective, preparing the ground for the future, including for the enlargement.

Reflection will be required on border management, in particular with regards to new

operational needs arising from the geopolitical situation of some enlargement countries and the

role of agencies in that regard.

EU agencies and bodies active in the justice and home affairs area(Eurojust, Frontex, Europol,

CEPOL, eu-LISA, the EU Drugs Agency, the European Union Asylum Agency, EPPO) will

need to adapt, possibly take on additional roles, and deepen inter-agency cooperation and safe

and secure information exchange between Member States, enlargement countries, agencies and

international organisations.

In relation to the Pact on Migration and Asylum, the Asylum Procedure Regulation does

not require substantive amendments. However, specific changes would need to be reflected in

18

the implementing decision establishing individual adequate capacity as well as the maximum

number of applications a Member State is required to examine in the border procedure per year.

Some parameters in the Asylum and Migration Management Regulation would require

reconsideration, in addition to technical adjustments. The Regulation establishes a mechanism

for solidarity and lays down the criteria and mechanisms for determining the Member State

responsible for examining an application for international protection (previous Dublin rules).

The solidarity mechanism entails a Commission proposal for a Council Implementing Decision

establishing the Annual Solidarity Pool to address the migratory situation in the upcoming year,

identifying the total annual number of required relocations (minimum 30 000) and the financial

contributions (minimum EUR 600 million) at EU level. The proposal must also set out the

indicative contributions of each Member State for the relevant solidarity cycle. This will be

done by applying the reference key, which is calculated based on the population size and GDP

of each Member State. Should new countries join the EU, the reference key would also apply

to them.22 Further reflection would be required as to whether the minimum thresholds will

suffice for the needs of a higher number of Member States. In addition, Annex I to the European

Union Agency for Asylum Regulation would also need to be amended to indicate the number

of experts that each country is obliged to provide for the Asylum Reserve Pool. The Agency’s

monitoring methodology would also need to be revised, and in particular the monitoring

programme that sets out the Member States to be monitored each year, in accordance with

Article 15 of the Regulation.

Enlargement countries need to be committed to strengthening internal security. They would

need to enhance their operational law enforcement cooperation with EU Member States and

Agencies to tackle the most pressing criminal threats and dismantle high-risk criminal

networks. Closer cooperation on security matters with enlargement countries will be required.

In its recent ProtectEU – a European Internal Security Strategy, the Commission has called for

the accelerated integration of enlargement countries into the EU's security architecture

and announced that it will support enlargement countries to better respond to threats, to increase

operational cooperation and information exchange, and to ensure alignment with EU values,

principles, legislation and tools.

Specifically on drugs, the 2025 EU Drugs Strategy and the EU Action Plan against drug

trafficking 23 reaffirmed that the EU will collaborate with enlargement partners to align

strategies against organised crime networks, improve drug information systems, and strengthen

operational cooperation. As part of this, the development of national drug observatories and

early warning systems for new psychoactive substances, in line with EU law will be

supported.24 The European Drugs Agency will support promoting evidence-based, integrated,

and balanced drug policies.

To ensure an accelerated integration of enlargement countries into EU’s security architecture,

the EU should systematically involve and support enlargement partners ensuring their access

to tools, guidance, and capacity-building opportunities. Similarly, the Commission will also

explore cooperation with enlargement countries on port security, and has already taken steps

22 The formula for the reference key in Annex I to the Regulation does not have to be changed as it is flexible

regarding the overall number of Member States), and they could equally benefit from solidarity if assessed by the

Commission as being under migratory pressure. Their accession would also affect the indicative contributions of

all Member States for a given reference number of relocations and financial contributions, since the solidarity

effort is spread over a larger number of Member States) and would require reflection as to whether the minimum

thresholds will suffice for the needs of a higher number of Member States. 23 COM (2025) 744. 24 COM (2025) 743.

19

to include them, for instance as observers in European Ports Alliance meetings.

New and specific EU initiatives are expected to be announced as part of the next EU action

plan on firearms trafficking, with specific actions focussing on enlargement countries. The

conditions for enlargement countries regarding policy on firearms, including specific strategies

and action plans, should align as closely as possible with the EU action plan. The state of play

regarding the harmonisation of their legislation with the EU acquis and the establishment of

National Firearms Focal Points could also be a consideration when preparing their national

action plans. The EU could consider a programme for improving expert co-operation in

preventing and combating corruption in particular in ports, with a focus on restricting the

influence of organised crime groups.

2. A LARGER AND STRONGER SINGLE MARKET

Enlargement would bring with it a larger single market, with the potential for greater economies

of scale. It will facilitate the free movement of workers, goods, services and capital, and boost

mobility and trade. The process of gradual integration of enlargement countries into the

single market and EU value chains is ongoing and can boost convergence and spur investment

and trade25. Furthermore, despite significant efforts to remove barriers between the existing EU

countries, many barriers persist, and new ones arise, and this will continue in the context of

enlargement.

The Single Market Strategy 26 therefore proposes a ‘highway’ to the single market, a

structured framework to boost the inclusion of the Western Balkans, Ukraine and Moldova,

which would include closer regulatory alignment and facilitating the integration of their

industries into European value chains ahead of EU accession. The Strategy also announced that

future legislative initiatives will provide simpler rules. This objective is particularly relevant in

the context of enlargement, where the single market acquis will need to remain effective,

coherent and easy to implement across a larger and more diverse Union. One example is the

revision of the EU public procurement framework through the Public Procurement Act27,

which aims to make public investment more efficient by simplifying procurement procedures,

establishing a consistent, coherent legal framework, and creating a digital EU procurement

marketplace.

The Single Digital Gateway,28 one of the existing single market support tools, is not yet fully

optimised to address the complexity of the Single Market. These challenges highlight the need

for upgrades and better coordination of tools to support enlargement. In particular, there is a

need to support early legal and technical alignment in enlargement countries, with a focus on

the Once-Only Technical System and the establishment of eID schemes, envisaged under the

Electronic Identification, Authentication and Trust Services (eIDAS) regulations. For the

25 COM (2024) 146, COM (2024) 690. 26 COM (2025) 500. 27 COM (2026) 590, SWD (2026) 590, SWD (2026) 591, SWD (2026) 592. 28 The Single Digital Gateway provides seamless online access to information, administrative procedures, and

assistance services across policy areas. It is built on three main pillars: the Information Pillar, which ensures

multilingual content on rights and obligations via the ‘Your Europe’ portal; the Digitalisation Pillar, which

requires key administrative procedures to be fully available online; and the Once-Only Technical System (OOTS),

facilitating the automated exchange of official documents across borders. The decentralised design of the Gateway

allows new Member States to integrate into the Information Pillar without structural changes, and OOTS is

designed to be scalable, minimising disruption. With enlargement, the number of national pages submitted to

‘Your Europe’ will likely increase, raising translation costs and increasing validation processes. Legal and

technical barriers may also delay their integration into OOTS unless early evidence mapping, and technical

alignment begin before accession.

20

Internal Market Information (IMI) System29 (including the SOLVIT module), readiness of the

enlargement countries to fully implement the acquis in the policy areas covered is essential for

being able to gain access to the system and cooperate effectively with the other authorities from

the EU. The Single Market Strategy has called on Member States to strengthen their SOLVIT

Centres, focusing on staffing, expertise, the network of contacts and the capacity to influence

other national authorities. In addition, the Strategy also calls on Member States and the

Commission to follow up on systemic issues that are evidenced through the cases that the

SOLVIT network deals with.

The Single Market Enforcement Taskforce (SMET) has successfully addressed sector-

specific barriers by encouraging the exchange of best practices among Member States. The

Single Market Strategy has announced a political reinforcement of SMET via an annual high-

level political meeting that brings together Member States’ ministers responsible for the single

market, high-level single market Sherpas and the Commission’s Executive Vice-President in

charge of the single market. They will provide strategic steer for SMET’s work and political

support for the implementation of jointly identified solutions to address barriers, including any

resulting from enlargement.

Overall, increasing resources for translation, validation, and training at EU level would ensure

that single market tools function optimally in an enlarged single market. Enlargement would

also trigger the need for enhanced resources to manage and upgrade IT support tools (e.g. the

Technical Regulation Information System (TRIS) database on single market transparency; the

IMI System; Single Digital Gateway) considering translation of existing content, community

management, testing, training and user assistance needs. The Single Market Strategy already

announced general measures for boosting digitalisation of the single market and improving

interoperability. For example, for the IMI System there are plans to facilitate its further and

continuous expansion to new legal areas, including by simplifying the procedure for this

expansion as well as building a generic, reusable IMI portal to connect businesses to IMI,

piloting an IMI notification hub and connecting IMI with other systems. Overall, the Strategy

emphasises the objective of streamlining data exchange and digital reporting via a cohesive

ecosystem of existing and future digital solutions.

Enlargement adds challenges to the enforcement architecture set out in the Single Market

Strategy, which rests on the principle thatapplication and enforcement of the single market

rules is a shared responsibility of the Commission and the Member States, including authorities

from national to regional and municipal level. For new Member States, genuine joint ownership

of the single market must be actively built, so that compliance is embedded as a structural

responsibility and not perceived merely as an obligation arising at the point of accession or

imposed by the Commission. This is particularly relevant when conducting a thorough

assessment of proportionality before adoption of national rules and in the context of prior

notifications to the Commission, in particular under the Single Market Transparency Directive

with respect to goods. Furthermore, as the Commission remains the guardian of the Treaties,

enlargement entails additional enforcement work at EU level to ensure the respect of the single

market principles, with direct implications for the Commission's own enforcement workload

and resourcing needs.

The Commission continues to monitor single market barriers and as announced in the Single

Market Strategy, would consider proposing a Single Market Barriers Prevention Act, if

29 The Internal Market Information System is a horizontal digital tool that facilitates administrative cooperation

across 21 policy areas to support the implementation and enforcement of single market rules.

21

necessary, based on the assessment of the functioning of existing preventive tools and taking

into account an enlarged single market.

2.1 Free movement of workers

2.1.1 Impact of enlargement on labour markets

Enlargement would have impact on labour markets. . With enlargement, ‘new’ mobile EU

citizens will move in this Single Market. The larger pool of skills could help current Member

States address possible labour shortages resulting from demographic change30 and skills

mismatches. At the same time, the reverse could also be expected with the ‘new’ citizens

acquiring new skills during their stay abroad, which could benefit the economies of the new

Member States when they return.

The impacts of free movement of workers on the labour markets of current Member States are

not that unusual, and experience has shown that they can be handled effectively. Moreover,

mobility of workers from enlargement countries already occurs today to a lesser extent under

the regime applicable to third country nationals31 and will be further facilitated by the proposal

for a Directive on the recognition of qualifications of third country nationals 32 , recently

proposed as part of the Fair Labour Mobility Package. While further analysis of demography

and other trends might need to be considered, as a first indication it is realistic to assume that

outward mobility from the enlargement countries after accession would not exceed the mobility

trends in those countries that joined last (Romania, Bulgaria and Croatia)33 .

Gradual integration provides several promising avenues for incorporating enlargement

countries into relevant activities and initiatives before accession. All enlargement countries are

participating in the European Qualifications Framework (EQF) and have developed national

qualifications frameworks. So far, six enlargement countries have referenced to the EQF,

establishing links between their national frameworks and the European framework. To further

support up and reskilling, the Union of Skills aims to continue the implementation of Individual

Learning Accounts and to strengthen and streamline the Pact for Skills to support strategic

sectors, including through Large Scale Partnerships. The Commission is also calling on

members of the Pact for Skills to at least double their commitments. Stakeholders of

enlargement countriesare eligible and can be further encouraged to join the Pact and take part

in the activities of Large-Scale partnerships. A regional skills partnership in the cultural and

creative industries sector has been established with stakeholders from the Western Balkans. To

further encourage the uptake up and re-skilling actions in the region more Pact for Skills

regional skills partnerships can be established. With 45 countries already participating in the

European Alliance for Apprenticeship, including all enlargement countries, and more countries

expected to join, the internationalisation of the Alliance is also encouraging greater learning

30 In this context, it is also worth noting that the median age in the countries concerned (approx. 40 years) is lower

than in the EU-27 (44.5 years). 31 As regards the assessment of impacts on free movement of workers, one unknown element is linked to the fact

that there are already approx. 4.3 million Ukrainians who are currently in the EU, benefitting from temporary

protection and with the right to access the EU labour market. Moreover, already before Russia’s war of aggression

against Ukraine, Ukrainians were the biggest nationality being issued first-time residents permits in the EU for

work purpose. It is not possible to estimate what the situation, numbers and status of current beneficiaries of

temporary protection would be at the potential date of accession of Ukraine and how this would shape/impact

labour mobility from Ukraine into the EU (and vice-versa). 32 COM (2026) 990. 33 This assumption takes into account that, although income per capita levels and income differentials vis-à-vis

the EU average may still be lower in the enlargement countries, significant outward migration from these countries

has already taken place, thereby reducing the potential for additional outward mobility following accession.

22

mobility among apprentices. This enables young people and adult learners to gain valuable

cross-border experience, enhance their skills and employability, while helping companies

access a more skilled and adaptable workforce.

Beyond qualifications frameworks, enlargement would inevitably increase the diversity of

professional regulations across the Union. To ensure that increased mobility does not encounter

disproportionate administrative or legal barriers, enlargement countries must prepare to fully

incorporate and implement the relevant acquis, particularly regarding the mutual recognition

of professional qualifications34 and the future Skills Portability Act framework when adopted.

Early alignment, institutional capacity building, and transparency in regulated professions will

be essential to facilitate smooth cross-border practice, maintain high service and public safety

standards, and maximise the mutual benefits of a larger, integrated European workforce.

At the same time, new Member States would likely face significant labour market and social

challenges upon accession, notably in terms of possessing adequate structural capacities to

implement effective labour market and social policies. Enlargement could therefore affect the

overall EU aggregates on most labour market and social figures. If average wages or labour

standards in new Member States would be lower than in the other Member States, companies

may also outsource to the new Member States labour-intensive tasks that can be delocalised,

which may in turn affect jobs and wages in the current Member States. At the same time,

experience shows that the net economic effect of work and labour reallocation between new

and current Member States should be positive in the longer term.

The countries fully participating in the Employment and Social Innovation strand of the

European Social Fund Plus, the EU’s main instrument for investing in people, are Serbia,

Montenegro, Moldova and Ukraine. The agreement with Bosnia-Herzegovina is already

provisionally applicable as of 2 September 2025.

Enlargement would increase the number of social security systems in the EU. To ensure that

the free movement of workers is matched by seamless social security coordination, it is

crucial that the social security systems of the new Member States are adequately prepared for

EU social security coordination in all relevant branches - in particular the reimbursement of

sickness benefits with the European Health Insurance Card (EHIC) for persons staying

temporarily in another Member State, pensions, unemployment benefits - and fully ready for

participation in the Electronic Exchange of Social Security Information (EESSI35) system and

the proposed European Social Security Pass (ESSPASS).

Budgetary aspects

The overall impact of enlargement on the performance of employment, social affairs and

inclusion policies on the ground is expected to require significant efforts in terms of

implementation and support from the EU and from new Member States for it to function well.

This would help to prevent risks such as a worsening of EU aggregates on most labour markets

and social figures or risks of brain drain. Overall, there are financial support needs that would

allow for capacity building in several areas, including for example labour law, social dialogue

and occupational safety and health, vocational education and training (VET) and adult learning

(to support the mobility of VET learners and adult learning/upskilling and reskilling).

As the EU prepares to welcome new members, the challenges posed by regional disparities will

necessitate a strategic shift of how funds are allocated and managed. The National and Regional

Partnership (NRP) Plans will be a means for Member States and regions to propose relevant

34 Directive 2005/36/EC. 35 COM (2026) 980.

23

investments, reforms and other tailored interventions to better support tomorrow's challenges

through EU funds under shared management36. The NRP Plans will cover cohesion policy

including social policy, regional policy, common agricultural policy, fisheries and maritime

policy, migration, border management and internal security. Furthermore, the NRP Plans will

empower new Member States to actively participate in their growth journey, fostering a greater

sense of ownership and accountability. By emphasizing the importance of tailored strategies

based on needs on the ground and the integration of a performance-based delivery system, the

EU can create a more cohesive and resilient Union that benefits all Member States and regions,

current and new alike. It is proposed that at least 14% of the financial envelope of the NRP

Plans will be dedicated to social objectives. This would correspond to at least EUR 100 billion.

After accession, new Member States would need to continue supporting their less developed

regions and address the specific needs of other territories, such as just transition or regions

suffering from demographic decline. The countries would also need to be covered by support

for social economy / social enterprises (currently provided under ESF+, ERDF, InvestEU).

This is possible under the NRP Plans and the EU facility will provide budgetary guarantees to

promote microfinance and social enterprise finance.

Support to ensure sufficient administrative capacities for the implementation of EU funds,

including for the monitoring and evaluation of supported activities is provided for in the

proposal on the NRP Plans Regulation37. Administrative capacity at national, regional and local

levels is critical for enlargement countries. Resilient, innovative, and well-organised

institutions are essential for effective public investments, competitiveness and quality public

services.

With an additional number of Member States, the Commission will have additional human and

financial resources needs in view of additional work on extension of EU rules and initiatives,

enforcement and greater membership and participation in existing networks, data collection,

technical integration of statistics in IT systems and technical support overall. Furthermore,

relevant decentralised agencies would need to provide services to an extended number of

countries, which would imply additional operational costs.

2.1.2 Policy gaps and delivery risks

The effectiveness of the policies can be affected if not enough attention is paid, during the

accession process, to preventing possible adverse effects (such as a worsening of EU

aggregates on most labour market and social figures; risks of brain drain and social dumping)

and if no corresponding investments are made.

The analysis has also highlighted a lack of data on key indicators across all main policy areas

in several of the enlargement countries assessed. For instance, lack of recent data on the labour

markets of many enlargement countries will make it more difficult to use evidence to develop

EU policies in the future. The lack of information also concerns platform work as well as

policies that are being considered, such as the right to disconnect. This would require further

capacity building and efforts to ensure the necessary systems are in place to help the

enlargement countries under assessment to meet the data collection and reporting obligations

of EU Member States.

Other examples include the area of social security coordination and professional

qualifications , where a recurring gap identified in past enlargement dossiers concerned the

36 COM (2025) 565. 37 COM (2025) 565.

24

potentially low level of national preparedness. This includes a lack of adequate administrative

structures and capacity, insufficient budgetary resources, limited digital readiness, inadequate

capacity-building and expertise developed well in advance, as well as insufficient staff

allocation and IT system development.

2.1.3 Reform orientations

In the last three enlargement rounds, transitional measures applicable to free movement of

workers allowed for gradual opening of the right to free movement of workers of newly joining

Member States after their accession to the EU. This helped mitigate unintended consequences

on host economies in the short term38. It can be expected that a similar approach regarding

transitional measures will be taken in the next enlargement rounds.

Built-in flexibility in the design of transitional measures is key to ensure that these can adapt

to developments and the individual situations of the Member States. It is important that the

transitional measures envisioned allow each Member State to decide whether to apply national

measures to regulate the access of workers from new Member States to their labour markets

upon accession or whether to apply EU law instead. In the framework of accession negotiations,

Member States have already agreed to include transitional measures providing this type of

flexibility for the drafting of the Accession Treaty with Montenegro.

In view of future enlargements, and if established by the Council in the EU Common Position

for the opening of the chapter on free movement of workers, the Commission can assess ex

ante the impact of the opening of labour markets to new Member States’ nationals and, as a

result, evaluate the necessity for any such transitional measures, which can help Member States

to develop bespoke solutions considering their need for skills intelligence, attracting talent and

consider demographic aspects and sectoral needs.

Enlargement countries already have access to ‘Europass’, designed to improve the free

moment of workers and the transparency of skills and qualifications for European citizens.

Additionally, as enlargement countries align with the EU acquis, the European Labour

Authority can conclude cooperation arrangements with enlargement countries prior to their

accession to involve them when appropriate in some of its activities39. This could further

smoothen their integration into the EU labour market.

On social security coordination and on recognition of professional qualifications, early

cooperation and experience-sharing between new Member States and existing ones on

administrative and technical alignment and development would help reduce bottlenecks at a

later stage. The Skills Portability Act40 should be put in place quickly at EU level to strengthen

the transparency and portability of qualifications and skills, including through digital tools, and

allow enlargement countries to take full advantage of the potential of the single market.

The Union of Skills41 aims to accelerate the education and skills transformation that Europe

urgently needs to tackle skills gaps. It is paramount to closely link enlargement countries to

these reforms and initiatives, as they also face similar challenges to the EU. In this context,

investing in adult learning is crucial to address labour shortages and skills gaps. The

Commission, in cooperation with the International Labour Organization and the European

38 https://ec.europa.eu/social/BlobServlet?docId=7191&langId=en 39 One such Arrangement was concluded with Moldova in May 2025.

40 COM (2026) 992. The initiative is made up of three actions: the digitalisation of qualifications and skills

(Action 1), the modernisation and digitalisation of the recognition system for regulated professions (Action 2),

and measures to improve the recognition of the qualifications and skills of third-country nationals (Action 3). 41 COM (2025) 90.

25

Training Foundation is supporting the preparation or implementation of the Youth Guarantee

in the Western Balkans, Ukraine and Moldova with an aim to support the schools-to-work

transition of young people not in education, employment or training (NEETs). Implementation

by Moldova of Union of Skills-related initiative is discussed in the context of the EU – Moldova

High Level Dialogue on Education, Skills, Labour, Social and Child Policies launched in June

2025.

Investing in skills will be crucial for enlargement countries to boost their competitiveness in

view of their integration into the single market as well as to ensure economic social and

territorial cohesion. To support national reforms and address emerging challenges, the

Commission has proposed several initiatives under this strategy, some of which are particularly

relevant for the school sector. These include the Action Plan on Basic Skills and the STEM

Education Strategic Plan, which were delivered together with the Union of Skills

Communication.

As part of the Union of Skills initiative, an Education Package including actions on basic

skills and EU Teachers and Trainers Agenda as well as an EU VET Strategy will be launched

in 2026. These initiatives will also be relevant for the enlargement countries to support their

efforts in strengthening and modernising VET in line with EU priorities.

2.2 Free movement of goods

2.2.1 Impact of enlargement on free movement of goods policies

Common standards, rules and trust among national authorities are a prerequisite for effective

free movement of goods in the single market. To this end, the preparedness of authorities is

crucial. Authorities that perform well is key for authorisations (for instance in the automotive,

medicines and chemicals sectors), certification by notified bodies accredited by accreditation

bodies, and in market surveillance.

Enlargement would have a substantial impact on market surveillance policies.While

Regulation 2019/1020 on market surveillance can accommodate new Member States,

enlargement may exacerbate existing challenges, particularly on cooperation and trust among

authorities. As market surveillance authorities have responsibilities limited to their respective

national borders, and each candidate country has at least one such authority, they can effectively

be incorporated into the present system. The revision of the EU market surveillance Regulation

should support better product compliance also in an expanded EU. Similarly, the Union Product

Compliance Network, established under the Regulation and comprising representatives from

these authorities, can maintain its effective functioning. Authorities of enlargement countries

can already participate as observers in the EU-wide Administrative Cooperation Groups for

various product groups, among others.

Nevertheless, incorporating new countries may introduce specific challenges and aggravate

existing issues, particularly on cooperation, trust and the utilisation of IT tools. The current

system relies on the principle of mutual recognition of investigations of products conducted by

various authorities (when a product is found to be non-compliant with EU legislation by one

authority, this is recognised by other Member States, who can act on this information). These

investigations and their outcomes are recorded in the Information and Communication

System on Market Surveillance (ICSMS), which is used by authorities across the EU to share

information. Equally important is cross-border mutual assistance, whereby an authority can ask

its counterparts to perform enforcement measures in their respective Member State to prevent

non-compliant products from being placed on the market. These principles and actions rely on

26

mutual trust between authorities, sound procedures and enforcement, and competent

inspectors.

2.2.2 Policy gaps and delivery risks

The main challenges lie in the potential sub-optimal preparedness of new Member States and

a potential lack of trust in the effectiveness of their enforcement capacities.Even if those

concerns are unfounded, failing to address them could undermine the broader market

surveillance system and exacerbate current deficiencies. Authorities in the existing EU

countries may hesitate to use mutual assistance and cross-border enforcement tools in the new

Member States and might avoid recording investigations in the ICSMS due to concerns about

sensitive information leakage. The latter already faces challenges to its use by Member States,

due to competing national systems, all with similar missions and objectives.

As regards the EU-27, the existing standardisation framework struggles to meet market and

policy needs, in particular in the field of green and digital transformation of EU industry.

Recent evaluation of Regulation 1025/2012 revealed certain weaknesses in implementation

concerning timeliness, inclusiveness and access to standards. Also, the EU product

framework needs to be protected from abuse and would benefit from further legal clarity and

the use of digital solutions.

2.2.3 Reform orientations

To address these challenges, several initiatives can be undertaken using available tools, and

targeted policy changes can be considered.

To build mutual trust and working methods between current Member States and enlargement

countries, the Commission could further encourage and enable new Member States to take the

opportunity to actively engage, as far as practicable and security concerns permitting, in

cooperative networks and groupings of market surveillance and relevant authorities. These are

namely the EU Product Compliance Network and the Consumer Safety Network. To this

end, financial and technical support for the Technical Assistance and Information Exchange

(TAIEX) can be leveraged. Furthermore, to demonstrate their competency, professionalism,

and proper enforcement, enlargement countries can use the ICSMS and the Safety Gate Portal

as their primary tools for managing market surveillance. This approach can help prevent

duplications with domestic systems. If domestic systems are already in place, these countries

can be encouraged to transition to the Commission's systems, possibly with training and

guidance by the Commission.

The proposal for a European Product Act wouldstrengthens market surveillance rules in the

EU, including by tapping into synergies with capacities of the EU and national customs and

market surveillance authorities and by strengthening the role of the EU in market surveillance

activities.

In addition, the proposal for a revision of the Standardisation Regulation increases the speed

and flexibility of the standardisation process, ensure a stakeholder-driven process, improve

access to standards and strengthen the EU's role as the global standard-setter. It will also

contribute to the effective functioning of the EU product legislation framework. These actions

should also help to maximise the benefits from an extended single market.

27

2.3 Freedom to provide services

2.3.1 Impact of enlargement on free movement of services policies and challenges

While the Services Directive remains fit for purpose overall, its full effectiveness depends on

improved implementation at the national level. Harmonising rules across an increasingly

diverse EU will be even more challenging. The Services Directive is largely based on broad

legal principles. These grant significant regulatory discretion to Member States, resulting in

minimum regulatory harmonisation.

On professional qualifications,institutions in new Member States that offer training in the

seven professions for which minimum training requirements are set in EU law may face

challenges. Investments in educational infrastructure (including professional practice in

hospitals for certain health professions) may be necessary to meet minimum training

requirements. Accession may also alter statistics, such as the number of specific professionals

moving to practice their profession in other Member States. This may influence the overall

direction of EU policies in this domain. The existing EU countries already experience

challenges in lengthy and complex recognition procedures, while automatic recognition only

applies to a few professions.

Budgetary aspects42

Prospective enlargement could impact the budgetary needs for single market-related actions

currently financed under the Single Market Programme (SMP), implying potential adjustments

in terms of priority setting, resources focus and design of the programme activities in line with

the orientations set out in the Commission’s MFF Communications. Nine association

agreements have been signed since 2021 with enlargement countries 43 . All enlargement

countries participate in the SME pillar of the SMP with support to businesses being a high

priority, complemented by participation by some countries in the areas of mainly market

surveillance, standardisation, competition policy, consumer protection and product safety, and

European statistics.

Effective implementation of EU standards, compliance with EU rules, and strengthened

cooperation between authorities will also constitute challenges to be addressed, partly via

targeted support, training, and initiatives fostering collaborative opportunities. In general,

efforts to accompany reconstruction after a crisis or the transition to fully functioning market

economies in all enlargement countries would require assistance via capacity building and

training.

The Commission’s proposals for the MFF 2028–2034 set a strengthened framework for single

market policies in place through inter alia the European Competitiveness Fund, under which

support to SMEs will continue, and a new Single Market and Customs Programme (SMCP).

As proposed by the Commission, the SMCP would provide a consolidated basis to channel

support towards businesses, regulatory cooperation, data collection and other actions relevant

to integration, including in areas such as administrative capacity, awareness raising among

businesses, consumers and citizens, cooperation between authorities, and the digitalisation of

public services. The SMCP would also provide support to the Customs Union, which

constitutes the foundation of the Union as well as a fundamental enabler and guardian of the

Single Market. The SMCP proposal also covers EU tax and anti-fraud policy, which are key to

improving the functioning of the Single Market.

42 This budgetary aspects section covers also the free movement of goods section 2.1. 43 Albania, Bosnia and Herzegovina, Kosovo, Montenegro, North Macedonia, Serbia, Türkiye, Moldova, Ukraine.

28

The proposed establishment of a new European Competitiveness Fund is intended to strengthen

the competitiveness of the EU, following the relevant recommendations of the Draghi report.

A larger Union would entail higher overall needs to integrate new markets, align industrial

capacities, and foster competitive ecosystems across more Member States. Funding from the

European Competitiveness Fund could, in principle, support activities such as cross-border

industrial innovation projects and capacity-building initiatives that include new Member

States, helping to strengthen value chains and competitiveness throughout the single market.

By targeting strategic sectors and supporting the development of industrial value chains, the

European Competitiveness Fund could contribute to addressing the challenges and

opportunities associated with a larger Union, while complementing other dedicated instruments

aimed at enlargement countries.

2.3.2 Reform orientations

Strengthening regulatory convergence can be beneficial to the EU, also as a preparedness

measure for enlargement:

To better align Member States’ services rules and ease the integration of new Member States,

the EU can more effectively utilise, and strengthen as appropriate, single market support tools

(cfr. above under Single Market).

As also announced in the Single Market Strategy, the Commission adopted in March 2026 a

legislative proposal on EU Inc. 44 to establish ‘28th regime’, providing common rules to

facilitate the digital setup of businesses and their operations across the single market. The

proposal for an EU Inc. corporate legal framework provides faster (within 48 hours), cheaper

(maximum EUR 100) and fully digital company registration, simplified procedures throughout

the company life cycle, easier digital share transfers and capital operations, support for modern

financing instruments, and the possibility for Member States to allow access to public equity

markets. It also introduces fully digital insolvency procedures and automatic transmission of

company data to relevant authorities in line with the “once-only principle,” while including

safeguards against fraud and abuse. Moreover, it will provide a common optional scheme for

employee stock options with harmonised deferred taxation, which will enable EU Inc.

companies to attract the best talents.

To address existing regulatory and administrative restrictions to services across the Member

States, the Single Market Strategy also announced an initiative to facilitate the provision of

pan-EU services by providers authorised or certified in one Member State based on EU law,

potentially including the harmonisation of such authorisation and certification schemes. It also

committed the Commission to develop legal guidance and recommendations to Member States

to provide clarity on the right to provide cross-border services on a temporary basis. The Single

Market Strategy also announced an initiative to facilitate the cross-border provision of

industry-related services such as installation, maintenance and repair services. This will be

in addition to sector-specific services’ initiatives that will focus on services sectors which are

the most relevant for the twin transitions and could bring the highest economic added value

and replace diverging national rules that create legal fragmentation.

On professional qualifications, the EU could investigate enhancements including through

potential legislative adjustments. The Skills Portability Act45 has highlighted the importance

of greater use of digital tools measures to make the procedures for the recognition of

professional qualifications faster and more efficient; extend automatic recognition schemes,

44 COM (2026) 321.45 COM (2026) 992.

29

for instance via Common Training Frameworks; and explore common rules for recognition and

validation of qualifications and skills of third country nationals. In addition, the Commission

could assess changes in the minimum training requirements of sectoral professions and into the

possibility of introducing common training frameworks or tests for more professions. This

domain has the potential for gradual integration. Western Balkan partners are bound by

mobility agreements encompassing minimum EU training requirements. Such agreements

could serve as a basis for pilot frameworks on mutual recognition with the EU.

Opportunities for gradual integration also exist in additional areas, such as e-commerce

related services including parcel delivery services and tourism. On postal services, the Deep

and Comprehensive Free Trade Areas with Ukraine and Moldova offer one of several possible

pathways for integration, while e-commerce related services including parcel delivery services

and tourism are highlighted as priority areas for gradual integration under the Growth Plan for

the Western Balkans.

2.4 Free movement of capital

2.4.1 Impact of enlargement on free movement of capital and financial services policy

The governance and decision-making processes of the several European authorities competent

in this domain46, which cooperate with national competent authorities, will become more

complex, given the increased variety in the state of development of financial markets and

experience in the sector. It may also become more difficult and challenging to reach consensus

in enlarged European Supervisory Authorities where currently the final decision-making body,

the Board of Supervisors is composed of one representative per each national competent

authority.

For the above reasons, while the EU financial services policy is fit for future enlargement

overall, there would be merit in involving the European Supervisory Authorities and the Anti-

Money Laundering Authority in the pre-accession phase to assess and help consolidate and

strengthen enlargement countries’ supervisory capacities. At the same time, joining these

Authorities, subject to the degree of advancement and a decision by the governing bodies after

signature of the Accession Treaty,can allow these countries to strengthen their ability to

cooperate with other Member States on supervisory matters.

On sanctions, anti-money laundering and countering the financing of terrorism, EU

policies are fit for enlargement. However, (unanimous) decision-making in the Council on

sanctions may become even more challenging in an enlarged Union.

On free movement of capital, where there is no EU-level secondary legislation, a greater

number of Member States could entail the need for increased efforts in monitoring the correct

application of EU law and preventing barriers to market integration.

Upon accession, investor-State dispute settlement clauses in extra-EU bilateral investment

treaties (BITs)between current and new Member States will become contrary to EU law, in

light of the Achmea case-law. The Commission’s recent policy has been to only authorise

bilateral investment treaties between Member States and (potential) candidates which provide

for automatic and full termination upon accession of the latter.

46 European Banking Authority; the European Insurance and Occupational Pensions Authority; the European

Securities and Markets Authority; the European Systemic Risk Board; the Single Resolution Board; the Single

Supervisory Mechanism; the Anti-Money Laundering Authority.

30

Over the past year, Montenegro, Albania, Moldova, North Macedonia and Serbia have joined

the geographical scope of Single Euro Payments Area (SEPA) schemes47. This allows their

financial institutions to participate in SEPA payment schemes, easing and speeding up Euro

transfers. To join SEPA, countries must align with key EU financial rules, including on Anti-

money laundering and countering the financing of terrorism, thereby facilitating gradual

integration into the EU single market.

Given the overall favourable financial stability environment to date, the 2024 Vienna Initiative

Bank Lending Survey found that cross-border banking groups overall intended to expand or

maintain exposure to the Central, Eastern and South-Eastern European region, including to

enlargement countries. In most of the countries in the region, the banking markets are

concentrated. At the same time, they belong to a region that continues to undergo economic

and social developments. Accession of new Member States from the region could provide good

opportunities for growth and profitability for EU financial institutions, while improving access

to finance, reducing costs for consumers and increasing competition in the enlargement

countries. However, with stronger ties between new Member States and the rest of the EU, the

risk of contagion may also increase, therefore making the case for appropriate supervision in

new Member States.

Budgetary aspects

The European supervisory authorities and the Anti-Money Laundering Authority would need

additional, non-recurring resources to assist the Commission in carrying out pre-enlargement

administrative capacity checks. The Commission would also need additional resources to

support new Member States and monitor compliance with the Treaty provisions on free

movement of capital and the correct implementation of the financial services legislation.

2.4.2 Policy gaps and delivery risks

A lack of sufficient supervisory capacity and expertise in new Member States could pose a risk

to the application of EU legislation and the orderly functioning of the single market, and with

it to investor protection, market integrity and financial stability. It is therefore important that

before accession, the Commission is fully satisfied that candidate country supervisors have

sufficient administrative capacity for the implementation and enforcement of the acquis in the

field of financial services.

2.4.3 Reform orientations

Due to their role in the European system of financial supervision, the European supervisory

authorities and the Anti-Money Laundering Authority are best placed to perform such checks

and ensure that no gaps remain. By assisting the Commission in the pre-enlargement phase, the

authorities should check whether the framework and administrative capacity of enlargement

countries can ensure that the rules applicable to the financial sector in enlargement countries

are adequately implemented and enforced to preserve financial stability and to ensure

confidence in the financial system as a whole, as well as effective and sufficient protection for

financial services consumers.

Some of the European supervisory authorities already provide technical assistance in assessing

confidentiality and professional secrecy or supporting the Commission, where applicable, with

the assessment of regulatory and supervisory equivalence with the EU of certain enlargement

47 The SEPA project was launched by the European banking and payment industry represented by the European

Payments Council (EPC).

31

countries, such as that of Montenegro and Albania. Such types of assessment typically span

between one and three years. For planning and efficiency purposes, to avoid duplication with

pre-enlargement efforts, it is to be considered when and if such upcoming/ongoing technical

assessments should take place. This could simultaneously help enlargement countries integrate

their markets within the EU and gradually strengthen their regulatory and supervisory

capacities.

The EU should also continue supporting gradual integration of enlargement countries into

SEPA schemes, as they meet the necessary conditions.

2.5 Health policy

Health protection directly impacts, beyond citizens, the single market and external trade. The

relevant EU acquis aims to deliver resilient, modernised, innovation-based, and digitalised

health systems. This ensures quality, safe, efficacious and accessible medicinal products,

medical devices and life-saving treatments, and maintains prevention, preparedness, quality

and safety oversight, surveillance systems and response mechanisms. Under a ‘One Health’

approach, innovation and access to market of animal vaccines and other alternatives to

minimise the use of antimicrobials is crucial for addressing antimicrobial resistance, zoonoses

and other major diseases with zoonotic potential.

Prevention, preparedness and response to serious cross-border threats to healthis a key part

of the EU’s preparedness policy, with the risk of serious cross-border threats to health being

further amplified by the globalised and highly interconnected nature of our societies and

economies. Maintaining and reinforcing a strong health crisis prevention, preparedness and

response framework through an all hazard and ‘One Health’ approach is crucial for protecting

the safety of EU citizens and safeguarding public health.

It will be essential for enlargement countries to establish robust and sustainable health systems

capacity, quality and safety oversight, surveillance and reporting mechanisms, as well as

response capacities. The same applies to the capacity of the relevant authorities dealing with

medicinal products for human and veterinary use and medical devices. The EU will assist

enlargement countries to align with EU standards and build administrative capacity and

expertise to participate fully to all relevant EU networks when they join the EU. Establishing

administrative capacity and health-system arrangements are also necessary to ensure the

implementation of Directive 2011/24/EU on the application of patients' rights in cross-border

healthcare.Tobacco consumption continues to be the leading cause of preventable cancer. The

tobacco control legislation is a key component of the EU cancer prevention policy. To tackle

tobacco and nicotine consumption and contribute to the objectives of Europe’s Beating Cancer

Plan, it will be essential for EU enlargement countries to ensure alignment with and the

implementation of the Tobacco Products Directive 2014/40/EU and Tobacco Advertising

Directive 2003/33/EC.

2.5.1 Impact of enlargement on health policy and prevention of, preparedness for and

response to cross-border health threats

Enlargement could affect the EU's efforts to uphold its all hazard and ‘One Health’ approach,

critical for the protection of the health of humans, animals, plants and the environment and the

integrity of the single market.

From a competitiveness standpoint, a larger EU population creates an economy of scale that

makes the EU a more attractive market for the pharmaceutical industry. Expanding the EU will

32

boost the health and social care sectors and increase the potential for health innovation and

entrepreneurship. With regard to the availability of critical medicines in the EU, the Critical

Medicines Act48, acknowledges the value of exploring international strategic partnerships with

third countries, especially enlargement countries, that may contribute to diversifying supply

sources and strengthening the resilience of supply chains. Furthermore, the Act will introduce

the possibility for Member States to request the Commission’s support to purchase certain

medicines together. An enlargement country may participate in such EU collaborative

procurement initiatives upon invitation by the participating EU Member States when the

Union has entered into a bilateral agreement with that enlargement country.

As observed during the COVID-19 pandemic, varying levels of preparedness and policy

approaches across Member States trigger difficulties in coordinating crisis response. A unified

approach in an enlarged EU could therefore be a challenge. However, the new Member States

would have to report about the status of preparedness to the Commission and would undergo a

public health emergency preparedness assessment that would result in action plans and hence

improve their overall preparedness. Also, experts would join the disease networks of ECDC

and this would ensure a closer collaboration and exchange of surveillance data based on agreed

case definitions.

Enlargement would also provide an opportunity to strengthen supply chains for medical

countermeasures and critical medicines thanks topotential new suppliers offering new

capacities, greater diversification and less strategic dependence on non-EU countries regarding

the manufacturing of critical medicines. There could also be opportunities for increased

participation in joint procurement either improving access to medical countermeasures under

the Joint Procurement Agreement49 and/or enhancing availability of critical medicines and

medicines of common interest via the proposed collaborative procurement tools under the

Critical Medicines Act.

Enlargement would increase the EU’s population and geographic coverage, making stronger

surveillance systems essential for the early detection of and response to emerging threats.

Increased participation in wastewater and environmental surveillance networks, under the

coordination of the European Centre for Disease Prevention and Control, as well as in EU

reference laboratories, and including through initiatives like the Global Consortium for

Wastewater and Environmental Surveillance for Public Health (GLOWACON) or the EU

Sentinel system, would improve the collection and sharing of information on emerging

biological and chemical threats50.

Enlargement might also have an impact on the EU’s efforts to strengthen its role in the World

Health Organization (WHO), of which the EU is not a member, only its Member States.

Budgetary aspects

Enlargement would require an adequate budget for EU health policies.Current funding (under

the EU4Health Programme, the Single Market Programme, operational programmes under

cohesion policy) supports multiple important health policy objectives including but not limited

to prevention, health promotion, digitalisation, health system resilience, disease surveillance

and crises preparedness as well as workforce/expert training. Under the current MFF, some

48 Political agreement in May 2025. 49 C(2014) 2258: Albania, Bosnia and Herzegovina, Moldova, Montenegro, North Macedonia, Serbia, Kosovo

and Ukraine are already participating countries to the joint procurement agreement to procure medical

countermeasures, 50 Enlargement countries can also already participate in wastewater and environmental surveillance networks,

such as GLOWACON. Ukraine is already a part of the joint action EU WISH.

33

enlargement countries are already benefitting from participation in actions funded by the

EU4Health programme. The European Commission signed association agreements with

authorities from Ukraine, Moldova, Montenegro, Bosnia and Herzegovina and North

Macedonia that opens access to EU4Health funding for these countries.

Besides EU4Health, some enlargement countries are already associated to the other main

instruments used under the current MFF to finance activities in health, including health

emergency preparedness and response (Horizon Europe, Union Civil Protection Mechanism

(UCPM)) and are consulted as part of the respective programme committees.

The instruments proposed under the MFF 2028-2034 relevant for health, including health

emergency preparedness and response (notably the European Competitiveness Fund; the new

Horizon Europe programme; the National and Regional Partnership Plans; UCPM and Union

support for health emergency preparedness and response (UCPM/HER) 51 ) allow for the

association and participation of enlargement countries.

With enlargement, decentralised agencies, notably the European Medicines Agency (EMA),

the European Centre for Disease Prevention and Control (ECDC), the European Food Safety

Authority (EFSA), the European Chemicals Agency (ECHA for biocides), would need to

provide services to an extended number of Member States, which would imply additional

operational and operating costs.

The Commission will similarly need to manage an increased workload to provide technical

assistance and capacity-building support, respond to queries of stakeholders, which will require

additional staff, budget, and infrastructure to support the integration of future Member States

into the EU's health. For example, marketing authorisation and pharmacovigilance is an area

where enlargement would directly increase the workload of EMA and of the Commission. The

Commission will also need to increase capacity to perform controls (including audits, fact-

finding missions and other assessment activities) to evaluate the implementation of relevant

Union legislation. The intensity of controls required in future Member States will increase the

demand profile significantly and require an upward adjustment of the allocated resources.

2.5.2 Policy gaps and delivery gaps

The main gaps relate to the capacity (and absorption facility) of the new Member States to

implement effectively the EU acquis, considering their current level of administrative, IT and

operational preparedness (for those areas where data is available) to establish a well-

functioning and sustainable health system based on the required EU standards that will be

capable to respond to health emergencies, such as epidemics.

2.5.3 Reform orientations

Revisions of several important pieces of legislation in the field of health are ongoing to simplify

and streamline processes and improve their effectiveness, with a view to making them fit for

the future and enlargement:

The adoption and timely implementation of the revision of the pharmaceutical legislation and

the Critical Medicines Act, will be crucial to ensure fair and equitable access to safe, efficacious

and quality medicines and improve availability and security of supply, faster entry of generics

and biosimilar medicines products on the market, and reward the placing of a medicinal product

51 COM (2025) 548.

34

in all Member States (those measures may be important for smaller Member States and those

with fewer financial resources).

In the field of medical devices, evaluation and revision of legislation52 is currently ongoing as

well, with a view to simplifying EU rules, aiming to ensure availability of safe and innovative

devices to support competitiveness and safeguarding a high level of patient safety and public

health protection.

The proposal for a European Biotech Act53 aims to strengthen the competitiveness of the health

biotechnology sector, by establishing the conditions for research, development and timely

placing on the Union market and production of health biotechnology innovations, products and

services and simplifying and streamlining the Union legislative frameworks.

As part of the gradual integration process, extended participation of enlargement countries as

observers in the European Medicines Agency Working Groups and in the networks of the

European Centre for Disease Prevention and Control will support capacity building in the area

of health and strengthen their technical expertise.

To ensure that high quality and safety health standards are in place upon the accession of new

Member States, the Commission will grant enlargement countries access to the Early Warning

and Response System for serious cross-border threats to health once the necessary

administrative arrangements are in place.

Otherwise, the current policy framework in health policy and health emergency prevention,

preparedness and response can be considered as fit for enlargement.

2.6 Competition policy

Competition policy is an important lever to strengthen Europe’s competitiveness. Rigorous and

effective enforcement of the antitrust, merger and State aid rules protects fair competition and

incentivises companies to innovate and become more efficient. At the same time, in the global

race to develop technologies and breakthrough innovations, competition policy needs to keep

pace with evolving markets and innovation, be better geared to common goals and allow

companies to scale up in global markets while ensuring a level playing field in the single

market. As the EU looks to enlargement, a robust competition policy based on clear rules will

be crucial in ensuring that the enlargement countries can integrate smoothly into the single

market, while also safeguarding healthy and undistorted competition.

2.6.1 Impact of enlargement on competition policy

Policy impacts

The enlargement of the EU will significantly increase the size of the single market – with tens

of millions more consumers and businesses of all sizes and sectors – from SMEs, start-ups and

semi-subsistence farms to large conglomerates and corporations, also including State-Owned

52 Proposal for a Regulation of the European Parliament and of the Council amending Regulations (EU) 2017/745

and (EU) 2017/746 as regards simplifying and reducing the burden of the rules on medical devices and in vitro

diagnostic medical devices, and amending Regulation (EU) 2022/123 as regards the support of the European

Medicines Agency for the expert panels on medical devices and Regulation (EU) 2024/1689 as regards the list of

Union harmonisation legislation referred to in its Annex I (COM/2025/1023 final).

EUR-Lex: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025PC1023. 53 https://health.ec.europa.eu/publications/proposal-regulation-establish-measures-strengthen-unions-

biotechnology-and-biomanufacturing-sectors_en

35

Enterprises. It will require the continued and effective enforcement of the competition rules to

protect a level playing field and fair competition in the enlarged single market.

The most significant enforcement impacts of enlargement can be expected for State aid, while

for the merger area only limited impact is expected. As regards antitrust, the main impact will

be on coordination needs between the Commission and national competition authorities within

the European Competition Network (ECN) and national courts, given an increased number of

national competition authorities. It will also have a marginal impact on the number of

Commission antitrust cases and their complexity due to the higher number of Member States.

For State aid, a more significant impact is expected on the review of existing State aid schemes

and their compatibility with the EU acquis and the assessment of notifications of new aid

measures. In the medium term, there will also be an impact on State aid guidelines and

regulations which may need to be revised to reflect updates of relevant EU sectoral

legislation54 . For example, the State aid agricultural guidelines and block exemptions are

usually revised in regular cycles to reflect changes in the Common Agricultural Policy (CAP).

There may also be a more technical impact on instruments that rely on input from the Member

States. A set of guidelines rely on data from Member States (GDP figures, reference rates) and

they would need to be revised to factor in new economic data. If the EU‘s average GDP declines

because of enlargement, this may directly impact the designation of regions under the Regional

aid Guidelines. The exact impact will depend on the direction and the extent of changes

introduced also to the overall EU regional policy.

Budgetary aspects

Enlargement would create additional enforcement work for the Commission and potentially

additional human resources needs, if rationalisation measures do not free up the resources

needed. For State aid, the number of notifications, complaints and general requests for guidance

is likely to increase. For antitrust, the economies of the new Member States may initially merit

more intense enforcement than for current Member States, also coming with a possible increase

in formal complaints and market information letters.55 Antitrust investigations may become

more complex, in particular where they cover several Member States in markets with a national

dimension (e.g. pharmaceuticals, consumer goods, telecommunications). The number of cases

in which the Commission is consulted by national competition authorities and needs to

collaborate with national courts may also increase.

In addition, enlargement would trigger the need for adequate financing of activities and

increased human, financial and IT resources in the Commission, currently funded by the Single

Market Programme:

• National competition authorities and the Commission exchange information via the ECN2

IT tool. Enlargement would also affect IT capabilities, with an increased need for access

and a higher level of exchanges. Given that the enlargement countries will not yet have

experience with this tool, there is likely to be an increased need for IT assistance.

54 Concerning State aid, it is, first, useful to distinguish between the assessment of the existence of State aid and

the compatibility assessment. Whereas the Commission has no discretion to decide whether State aid exists and

is bound by the jurisprudence of the Court of Justice, it has discretion in its compatibility assessment when

applying Article 107(3) TFEU. Thus, an analysis as to whether State aid rules and policy are “enlargement proof”

can only concern those areas where the Commission has discretion and can make choices, i.e. in the compatibility

analysis. Second, State aid compatibility rules may be impacted by changes in sectoral legislation. 55 Citizens and undertakings who prefer not to submit a formal complaint can send market information letters to

the Commission to provide information on a specific market where they have concerns regarding compliance with

EU competition rules.

36

• With enlargement, adequate support will be needed for continued capacity building

activities (meetings/trainings for key stakeholders such as national competition authorities,

training of judges on competition law and awareness raising for specialised target

audiences, e.g. the business community) as well as for the operation of the European

Competition Network.

2.6.2 Policy gaps, delivery risks and reform orientations

Based on the experience of previous enlargement rounds, developing competition law

enforcement, know-how and culture to ensure the effective and consistent application of the

law takes a long time and requires adequate financial support.

State aid guidelines and regulations may have to be revised to reflect the potential changes of

EU legislation post-enlargement in the various policy areas.

3. COMPETITIVENESS AND INCLUSIVE GROWTH

3.1 Enterprise and industrial policy

EU industrial policy serves as a roof area that draws together a range of policy initiatives that

aim to strenghten the EU’s competitiveness. It includes nine drivers of competitiveness in the

EU: a functioning single market, access to private capital, public investment and infrastructure,

research and innovation, energy, circular economy, digitalisation, education and skills, trade

and open strategic autonomy. It is a domain in which EU and national competences are strongly

connected, with an important role for policy making at national level.

The main challenges to Europe’s competitiveness, such as high energy prices and

overcapacities in third countries, affect the industrial fabric across the EU. It is therefore, in

this context even more important to strengthen the EU industrial policy and foster the

coordination of policies and initiatives across the EU and between Member States. For this

reason, the Commission adopted a Clean Industrial Deal, a proposal for a European

Competitiveness Fund and for an Industrial Accelerator Act and deploys a Competitiveness

Coordination Tool, among other things.

The EU is developing targeted policies under the main axes and overarching objectives of its

industrial policy: closing the innovation gap; decarbonisation and competitiveness; reducing

excessive dependencies and increasing security. Upon accession, new Member States will also

benefit from the initiatives that have been launched in line with this renewed industrial logic –

namely the European Chips Act, the Critical Raw Materials Act and the Net Zero Industry Act.

3.1.1 Impact of enlargement on the EU enterprise and industrial policy

Enlargement would have a significant impact on the industrial structure in the EU, primarily in

terms of greater heterogeneity. Enlargement countries generally come from an overall lower

economic base than the EU average, with lower wages and significant potential to grow their

economies to converge with the EU-27. Some have economies that rely on traditional industry

sectors, in particular energy intensive industries, whilst others are more oriented towards

services. The economies of most enlargement countries are rather carbon-intensive (apart from

Albania, relying mainly on hydropower) and have low levels of energy efficiency.

It is expected that enlargement would create a rise in productivity in the new Member States

and entail a significant economic adjustment across the EU. A significant uptick in investment

37

activity in the run-up to and after enlargement is likely in the new Member States, typically in

sectors where they have a comparative advantage (e.g. labour costs). Also, it is possible that

the competitiveness of some industrial sectors will be challenged once they are in the EU, for

instance due to lower carbon-efficiency. Vice versa, this new competition may affect the

relative position of these industries in the 27 Member States.

Budgetary aspects

The Commission will need more human resources because EU rules and initiatives on industry

will apply to more Member States. EU Agencies work will also face a higher workload (e.g.

the European Chemicals Agency (ECHA) will have to manage additional registrations of

substances).

3.1.2 Policy gaps, delivery risks and reform orientations

At present, the competitiveness of several EU industrial sectors is under pressure. An increased

heterogeneity of industry coming with future enlargement would make it even more important

to strengthen the EU’s industrial policy toolbox and to involve enlargement countries.

There are several opportunities to strengthen partnerships with enlargement countries in

various forms. In October 2023, upon request from Member States, the Commission put in

place the Joint European Forum for Important Projects of Common European Interest

(IPCEIs), where Commission and Member States collaborate closely to identify areas of

strategic EU interest for potential future IPCEIs and work to increase their effective design,

assessment and implementation. IPCEIs are not limited to specific industry sectors. Inviting

enlargement countries to participate to specific meetings of the Forum could be a way to

prepare them to participate to IPCEIs.

In addition, there is an opportunity to continue the EU’s work on strategic industrial

partnerships, such as the strategic raw materials partnership with Serbia and Ukraine and the

Industrial Policy Dialogues already ongoing with Ukraine. In line with the Western Balkans

Growth Plan, through bilateral dialogues on industrial cooperation, the EU will target strategic

industries such as raw materials, batteries, and machinery, while advancing regulatory

integration for their early and gradual access to the single market and enhancing business

cooperation for further integration in EU industrial ecosystems. For example, work on the

Agreements on Conformity Assessment and Acceptance of Industrial Products (ACAA) is

underway with Ukraine, Moldova and Serbia with the possibility offered to all Western

Balkans to start the process to conclude an ACAA. In its Action Plan to secure a competitive

and decarbonised steel and metals industry in Europe56 the Commission said that it would

consider creating EU partnerships with non-EU countries, especially enlargement countries, as

they integrate into the single market and move towards EU membership. The Commission also

noted that a strategic approach to strengthening supply chain resilience could involve

investing in partner countries and redefining industrial collaborations to create a more

sustainable and resilient steel production sector. The EU bioeconomy strategy also called for

integrating enlargement countries and immediate neighbours into EU bio-based value chains,

with a view to establish regional bioeconomy hubs, diminish reliance on external raw materials,

and enhance EU's strategic autonomy.

56 COM (2025) 125.

38

3.2 Research and innovation

Research and Innovation (R&I) is one of the key drivers of competitiveness. Enlargement

countries are fully associated with the EU's Framework Programmes for Research and

Innovation. Some of these countries have been associated for over a decade, enabling them to

develop their R&I capacity to participate in the EU’s Framework programmes for research and

innovation. Over the years, EU R&I policies have influenced and guided national and regional

research ecosystems in these countries, helping to bridge the policy gap between these

countries and the EU. Different support and guidance instruments are available to them under

the current Framework Programme for R&I - Horizon Europe, such as the European Research

Area, Widening, Innovation, and the Policy Support Facility or the Global Service Facility for

International cooperation to further strengthen regional cooperation. The EU already supports

the participation of Moldova and Ukraine through dedicated financial support to the Horizon

Europe Offices in the respective countries. Organisations from the enlargement countries are

also participating in several EU Missions in Horizon Europe, including the Mission ‘Climate

Neutral and Smart Cities’, the Mission ‘Restore our ocean and waters’, the Mission for

‘Adaptation to Climate Change’ as well as the Mission on ‘Cancer’.

The participation of the enlargement countries located in the Black Sea region and in the

Western Balkans in Horizon Europe is increasing. Initiatives like the Danube and Black Sea

lighthouse of the EU Mission ‘Restore our Ocean and Waters’ supports freshwater and marine

research and innovation, bringing together community and sectoral stakeholders from the

Black Sea region. There are additional new calls targeted at the Black Sea under the Horizon

Europe Work Programme 2026-27.

In addition, several enlargement countries are also participating in some EU Partnerships, such

as Biodiversa+, the European High-Performance Computing Joint Undertaking and the

Sustainable Blue Economy Partnership.

The Black Sea also features among the targeted sea-basins of the Sustainable Blue Economy

partnership. Four additional calls for proposals planned under this partnership, provide

additional possibilities for cooperation for enlargement countries in the region. Cooperation

opportunities will also grow under the BIOEAST initiative (Central and Eastern European

initiative for knowledge-based agriculture, aquaculture and forestry in the bioeconomy) which

currently covers eleven EU widening countries. There are plans to expand activities towards

Ukraine, Moldova and the Western Balkans in knowledge-based agriculture, forestry and

aquaculture in the bioeconomy.

Enlargement countries are also increasing efforts to cooperate in the area of Research

Infrastructures by participating in different European Research Infrastructures Consortia

(ERIC) such as the CESSDA-ERIC, the DARIAH-ERIC, the ESS-ERIC, the DANUBIUS-

ERIC and the ELI-ERIC.

3.2.1 Impact of enlargement on research and innovation policy

Enlargement would strengthen the European Research Area by broaden the talent pool for

innovation. New Member States will bring skilled professionals, researchers, and entrepreneurs

in sectors such as IT, engineering, agri-food and environmental sciences, which will increase

scientific capacity and collaboration potentials. The free movement of talent within the EU, in

line with the ambitions of the Letta report on the Future of the Single Market on the promotion

of the fifth freedom (the free movement of research, innovation, knowledge, and education),

will enhance the exchange of knowledge and expertise, fostering cross-border collaborations

and accelerating innovation uptake across the Union. Moreover, enlargement would also

39

support the alignment of research policy, ethical standards, and open sciences practices across

the European continent. Cooperation with Ukraine on fission research is vital for bringing the

EU’s research excellence and nuclear safety culture to the Ukrainian nuclear sector.

Enlargement would be expected to bring the same excellence and safety culture to the sectors

using ionising radiation for non-power purposes in the other countries as well.

When it comes to challenges to be addressed, enlargement would bring increased diversity in

the R&I landscape, with different needs and capacities 57 . Enlargement countries have

earmarked below 1% of GDP for R&D. In some enlargement countries the respect of academic

freedom and freedom of scientific research as well as the autonomy of research institutes, is in

decline. The disparity of R&D capacity and level in enlargement countries compared to the EU

will require further efforts to reduce research and innovation disparities and divide within the

EU, while upholding the non-negotiable EU standards in this area, including as regards

academic freedom and the independence of research institutes.

Enlargement would have a greater impact on R&I policies and investment in the enlargement

countries, rather than on the EU policies. This is because enlargement countries already

participate in EU policies and programmes as follows: (i) they participate to the ERA

governance bodies as observers; (ii) they are participating on equal footing in Horizon Europe

through their association to Horizon Europe (iii) they are anchored in the European Innovation

Ecosystems and (iv) they participate in research and technology infrastructures and open

science initiatives, with different level of advancement. To meet the objectives of the 'widening

policy’, new Member States may increase their participation in Horizon Europe and in

widening projects in particular. From an institutional viewpoint, enlargement increases the

challenges in reaching unanimity in Council on nuclear research matters governed by the

Euratom treaty, due to a larger number of Member States.

Budgetary aspects

Boosting the national R&I ecosystems of new Member States to reach the EU average would

require mobilising public and private investments and instituting reforms that support stronger

levels of scientific excellence, more science-business linkages and better innovation

performance.

Enlargement would require investing in enlargement countries in research technology and

infrastructure and capacity. This includes notably Ukraine funding needs to rebuild research

infrastructures and facilities damaged during Russia’s war of aggression (e.g. the research

facility in Kharkiv).

With the change of status of enlargement countries as EU Member States in the governance

bodies of the EU Framework Programme for R&I, specific needs may emerge. For example,

specific scientific research may be needed on new issues (e.g. war-caused environmental

damage). Moreover, there is a need to envisage capacity building measures for new Member

57 According to the 2025 European Innovation Scoreboard (EIS), enlargement countries perform below 70% of

the EU average, despite some improvements notably in terms of ‘Attractive Research System and Linkages’ and

‘Investments in information technologies’ over the period 2018-2025. On three other dimensions, ‘Finance and

support’, ‘Firm investments’, and ‘Trade impacts’, the EU neighbouring countries continue to face difficulties,

struggling to mobilise sufficient funding and financial support for innovation activities, while the challenging

global context adds to the constrains in trade of innovative products. Regarding open science policy, monitoring

data shows that enlargement countries are lagging significantly behind developments in EU Member States. For

example, of the enlargement countries providing data to the EOSC Open Science Observatory, only one has

reported that they have a national policy for open science in place.

40

States to improve their R&I capacity and their levels of participation in the Framework

Programme for R&I Horizon Europe.

While Ukraine already participates actively in the Euratom Research and Training Programme,

enlargement can be expected to result in a further increase in beneficiaries interested in nuclear

research collaboration, particularly in novel areas such as non-electrical applications of nuclear

energy (district heating, industrial heat, propulsion) and in medical applications of ionising

radiation. Support in the area of nuclear security, safeguards and chemical, biological,

radiological and nuclear materials (CBRN), which already extend to some enlargement

countries, would need to be reinforced to address the increased demand stemming from

enlargement. Alongside these areas, the EU should also ensure that enlargement would support

its strategic focus on accelerating nuclear fusion development, given its long-term importance

for the decarbonisation objectives of an expanded Union.

3.2.2 Policy gaps and delivery risks

Enlargement countries are fully associated to and actively participating in Horizon Europe.

They are closely involved in its implementation. However, they face challenges in developing

robust innovation ecosystems, particularly in terms of instruments and resources available for

R&D, including for research and infrastructure, and access to and retention of skilled talent.

The countries also have a poor level of performance in terms of intellectual assets, including

patents, trademarks, and design applications.These gaps in national policies may hinder them

from increasing their participation in the EU R&I programme and policy and may hinder their

sustainable growth and competitiveness.

3.2.3 Reform orientations

To further prepare for enlargement, the EU could increase its support for targeted investment

and capacity building initiatives in research and innovation in enlargement countries. This

will help them to harmonise their national policies with EU policies, mainly as regards adapting

to the ERA and regulatory alignment to reduce barriers to innovation. This would be in line

with existing efforts by the European Commission, such as the Policy Support Facility under

Horizon Europe, which already provides tailored support for policy reform and capacity

building in research and innovation systems, i.e. support will be provided to Moldova in 2026.

Under the Global Support Facility for international cooperation, enlargement countries receive

tailored support in different fields such as Science-business cooperations or training for

Innovation Hubs and innovative SMEs.

In addition, Horizon Europe’s 2025 work programme included a topic on ‘Support for R&I

policy making in the EU enlargement countries’ for the further integration of these countries

into the European Research Area and into the European Innovation Area, highlighting the

strategic importance of the enlargement countries and facilitating actions aiming to support the

region’s EU integration process. The project Policy ENLARGE has successfully launched its

activities in April 2026. Besides others, it will support the structured R&I policy dialogue with

enlargement countries and will offer tailored capacity building support for R&I reforms,

digitalisation, technology transfer, and evidence-based decision-making.

Under the European Innovation Council (EIC) Pre-Accelerator call under the EIC Work

Programme 2025, entities from enlargement countries successfully participated. Projects with

startups from Serbia, Moldova, Georgia and Ukraine will launch in 2026.

Smart Specialisation supports regions in their innovation strategies, boosting growth and

prosperity, promoting knowledge-based economic development and targeted R&I policies

41

building on territorial specificities, unique potentials and emerging niches. Following the

success of Smart Specialisation in the EU, many enlargement countries have developed Smart

Specialisation Strategies to strengthen their innovation ecosystems and prepare for the

integration into the European Research Area. Further support could be provided to ensure the

successful implementation and renewal of Smart Specialisation in enlargement countries.

Further support could also focus on increasing the participation of enlargement countries in

widening projects under Horizon Europe, to strengthen their R&I research and innovation

capacity and foster deeper integration into the European Research Area. The EU could also

consider providingcapacity-building support to strengthen innovation ecosystems in new

Member States for example by increasing their involvement in the Regional Innovation

Scheme of the European Institute for Technology and in the Regional Innovation Valleys

initiative. The EU could also help to promote knowledge valorisation through stronger

collaboration between industry and academia, the development of legal and policy frameworks

to manage intellectual assets including IP management, and by better connecting research with

standardisation.

The EU can further assist enlargement countries in thedevelopment of their long-term national

and regional research and innovation agendas to support participation in R&I partnerships and

networks as highlighted in the Draghi report on the Future of European competitiveness and in

the recent expert report on research, technology and innovation to boost European

competitiveness58.

The EU could also consider introducing targeted actions for enlargement countries to support

early-stage startups and scaleups to close the innovation gap, particularly in country-specific

smart specialisation domains and, overall, in emerging sectors such as digital transformation,

clean energy, and AI59. The Commission Startups and Scaleup Strategy60 emphasises the

importance of gradual integration of enlargement countries in the EU’s startups and scaleups

ecosystem, to boost our autonomy and resilience. Namely it points out that the Commission

will leverage and reinforce existing instruments and develop new instruments to invest in

European security and defence startups and scaleups, in line with the White Paper on Defence

and based on the Omnibus Defence Simplification Package. These instruments could include

more flexible and adaptive funding approaches for emerging defence innovators, including also

from Ukraine, such as targeted support to single entities. Already today, Ukraine is eligible to

participate in the EIC STEP Scale Up Defence Scheme.

Public-private partnerships can also be further encouraged to facilitate access to finance and

create more investment opportunities for startups in every region. There is also an opportunity

to strengthen further local investors networks and better connect them to the EU markets,

including by giving them opportunity to join the EIC Trusted Investors Network, which was

set up to support investment by the EIC.

To improve the use of innovation procurement in new Member States, the EU could provide

further capacity building resources to public authorities, helping them better understand and

use innovation procurement tools and strengthen the governance of innovation ecosystems via

smart specialisation processes. Creating a more transparent and accessible procurement process

in line with the EU regulatory framework on public procurement will ensure that startups and

scaleups in new regions can tap into public markets and grow their businesses.

58 https://op.europa.eu/en/publication-detail/-/publication/2f9fc221-86bb-11ef-a67d-01aa75ed71a1/language-en 59 For instance, the European Innovation Council Work Programme 2025, under Horizon Europe, included a call

for the support of Ukrainian tech innovators. 60 COM (2025) 270.

42

3.3 Education, youth, sport and culture policies

The Political Guidelines of President von der Leyen for 2024-2029 call for reinforced

cooperation with the EU’s international partners. Support to enlargement countries remains a

top priority, also in the areas of education, youth, sport and culture policies, that are very closely

linked to enlargement. Enlargement countries are reforming their policies to approximate to

EU standards and targets, particularly those set by the European Education Area (EEA). In

particular, alignment is necessary to make sure that upon accession, enlargement countries can

benefit effectively, and contribute to, EU programmes designed to foster cooperation.

Additionally, these policies promote EU values and the EU identity, human rights, and the rule

of law, supporting the EU's goal of creating an integrated, democratic and larger EU. Erasmus+,

the EU’s flagship programme for education, training, youth and sport, is a crucial instrument

in supporting policy development and bringing enlargement countries closer to the EU, as is

the Creative Europe programme in the field of culture.

Currently, the international dimension of the Erasmus+ programme supports capacity building

for the benefit of enlargement countries in the fields of higher education, vocational education

and training, youth and sport. In addition, a dedicated capacity building scheme has been

underway since late 2025 to prepare enlargement countries for their association to the

Erasmus+ programme. Two TAIEX workshops were organised in November 2025 and March

2026 for participants from appointed ministries that will become Erasmus+ national authorities

responsible for designating and supervising the future Erasmus+ national agencies. The

workshops aimed at building their capacities to monitor and supervise the future agencies with

knowledge of the programme’s indirect management rules. Further assistance is ongoing to

help them identify and set up their Erasmus+ agencies. From 2027 onwards, additional events

and support measures will be organised to engage potential beneficiaries and stakeholders, and

to assist the newly established Erasmus+ national agencies in taking up their roles.

3.3.1 Impact of enlargement on education, youth, sport and culture policies

Whilst EU policies already broadly apply to enlargement countries, and these countries are

parties to relevant international conventions, enlargement would further diversify the

education, youth, sport and culture landscape, bringing a range of more profound needs,

capacities (e.g., in terms of affordability of learning mobility), and opportunities.

On education, enlargement countries, except Kosovo, have been invited to join the working

groups under the EEA Strategic Framework and have appointed representatives. The EU

cooperation in education and training is based on the open method of coordination; enlargement

countries are partially participating in it already for example, as part of the EEA Strategic

framework working groups. Therefore, no major adjustments to the functioning of the Strategic

Framework are expected to be necessary in anticipation of enlargement. Moreover, most

enlargement countries participate in eTwinning and have joined the networks for Eurydice and

the European Qualifications Framework, Europass and Euroguidance networks. Other

networks, such as the one for adult learning coordinators, are progressively opening to

enlargement countries. In addition, all enlargement countries, besides Kosovo, are part of the

European Higher Education Area under the Bologna Process, ensuring that their higher

education policies are aligned and compatible with EU initiatives. North Macedonia, Serbia

and Türkiye are associated to Erasmus+, while all other enlargement countries benefit from the

international dimension of the programme. As of 2023, higher education institutions from the

Western Balkans can take part as full partners in European Universities alliances. Higher

education institutions from other enlargement countries can take part as associated members to

43

alliances (more than 30 Ukrainian higher education institutions are currently associated). In

addition, Western Balkans Ministerial-level dialogues on education have been held regularly

and will now be extended to cover all enlargement countries.

On youth, through the Youth action plan in EU external action for 2022-2027, the EU works

to build partnerships with young people outside the EU, including in Eastern Neighbourhood

and Western Balkan countries. The priorities of the action plan mirror those of the EU Youth

Strategy (i.e., engage, empower, connect) and are funded through the NDICI-Global Europe

Instrument and the Instrument for Pre-Accession Assistance (IPA), including their contribution

to the Erasmus+ programme.

The European Commission is increasingly involving young people from enlargement countries

in EU initiatives aiming at strengthening youth participation. In the context of the EU Youth

Dialogue, the EU’s largest consultation mechanism for young people, National Youth Councils

from enlargement countries are now able to participate in webinars, contribute with expert

statements to the consultation reports and are invited to the EU Youth conferences.

Furthermore, youth-led organisations from eight enlargement partners61 are observers in the

President’s Youth Advisory Board, which advises the Commission President on issues that are

relevant for young people.

The Youth Wiki, the encyclopaedia of national youth policies, is gradually opening to

enlargement countries. The Western Balkans countries not associated to Erasmus+ (Albania,

Bosnia and Herzegovina, Kosovo* and Montenegro) are eligible for mobility projects for youth

workers, youth exchanges and youth participation activities under Erasmus+ ‘Key Action 1’,

while all enlargement countries are eligible for capacity building in the field of youth projects

under Erasmus+ ‘Key Action 2’.

As regards the European Solidarity Corps, North Macedonia and Türkiye are associated while

the other enlargement countries are not.

Furthermore, all Western Balkans economies except Kosovo are State Parties to the United

Nations Convention on the Rights of the Child and take part in the Joint Council on Youth of

the Council of Europe (CoE). The EU CoE Youth Partnership supports youth development in

the Western Balkans, promoting European integration, and fostering a more inclusive,

democratic, and active generation of young people in the region.

On sport, enlargement countries participate actively in EU initiatives, in particular the

European Week of Sport. Moreover, all enlargement countries except Moldova are members

of the CoE’s Enlarged Partial Agreement on Sport and have joined the CoE’s Anti-Doping

Convention. Inclusion is one of the key objectives of EU sport policy, and all enlargement

countries are parties to the UN Convention on the Rights of Persons with Disabilities.

Moreover, all nine enlargement countries are eligible for capacity building projects in the field

of sport under Erasmus+.

On culture, all enlargement countries except Türkiye participate in the Creative Europe

Programme, the EU’s flagship programme supporting the cultural and creative sectors 62 .

61 Albania, Bosnia and Herzegovina, Kosovo*, Moldova, Montenegro, North Macedonia, Serbia, and Ukraine. 62 Six enlargement countries (Albania, Bosnia and Herzegovina, Montenegro, North Macedonia, Serbia and

Ukraine) fully participate in the programme, while another two participate partially in the programme (Georgia in

the Culture and Cross-Sectorial strands and partially in the MEDIA strand; Kosovo only the Culture strand). After

deciding not to renew its participation in the programme in 2021, Moldova officially expressed its interest to join

the current programme on 4 February 2025, thus entering the first step of association which is envisaged as of 1

January 2026 (for the Culture strand; participation in the Media and Cross-Sectorial strand will be contingent

44

Consequently, these countries have taken part in several projects and flagship initiatives, such

as the European Capital of Culture action and other prizes and awards supported by the

Programme63. Eastern Partnership enlargement countries benefit from the EU4Culture II -

Sustainable Creative Ecosystems programme. The Western Balkans benefit from the Culture

and Creativity for the Western Balkans programme (CC4WBs). Enlargement countries are also

associated to the European Heritage Hub initiative 64 . Furthermore, a Western Balkans

Ministerial-level dialogue on culture took place in 2022 and 2024. So far, exchanges have

shown good alignment of policy priorities, while pointing to a need for further support in terms

of capacity building and professionalisation of administrations and cultural professionals in the

region. Moreover, almost all enlargement countries are parties 65 to a key international

instrument, the UNESCO 2005 Convention on the Protection and Promotion of the Diversity

of Cultural Expressions, to which the EU is also a party in its own right, alongside the Member

States.

Budgetary aspects

As regards the programmes Erasmus+, Creative Europe and the European Solidarity Corps,

enlargement is expected to have a mechanical impact, in the sense of a higher number of

potential beneficiaries, in the order of tens of thousands of potential new beneficiaries per year.

Considering the nature of the Erasmus+ and European Solidarity Corps programmes in terms

of implementation mode (with 80% of the budget being disbursed through indirect

management, association to the programme requires the setting up of a national agency in the

country concerned), there is a need for investment in guidance, assistance and resources, to

ensure compliance with the key principle of sound financial management and respect of EU

values. This investment, which started with the TAIEX workshops mentioned above, and that

will continue with additional capacity building measures, is also aimed at ensuring proper

financial management of EU funds.

A larger community of countries will mean more national agencies (and national authorities)

to coordinate and more funds to be disbursed in indirect management. Overall, the support

work by the Commission will gradually increase, demanding as well increases in financial and

technical resources.

The next Erasmus+ programme (2028-2034) will contribute to preparedness of enlargement

countries in education, training, youth and sport. It will allow to bring enlargement countries

closer to EU Member States and as such reinforce the EU’s education, youth and sport policies

implementation. Capacity building is one of the two pillars of the Commission proposal for the

new Erasmus+, the other one being learning opportunities for all. In the future programme,

upon written confirmation from the Union, that according to the elements submitted to the Union, Moldova meets

the conditions set out in Directive 2010/13/EU as referred to in Article 9(2) of the Creative Europe Regulation).

The agreement associating Moldova to Creative Europe was signed on 2 September 2025. 63 For instance, the title of European Capital of Culture is open to a city in an EFTA/EEA country and (potential)

candidate country every three years since 2020. In 2022 Novi Sad, in Serbia, was the first European Capital of

Culture taking place in the Western Balkans. Skopje 2028 will be the second city holding the title in the region.

The ongoing competition for the 2030 title has the cities of Lviv (Ukraine) and Nikšić (Montenegro) running for

the title, whose final selection will take place in October 2025. 64 All Western Balkan partners were associated to the European Year of Cultural Heritage 2018 and are currently

invited to the Cultural Heritage Expert Group (multi-stakeholder forum for policy exchange created as a legacy

of the Year). However, their level of participation remains rather limited for now. Partners from the Western

Balkans as well as Ukraine, Moldova and Georgia are also covered by the European Heritage Hub initiative, an

EU-funded pilot project bringing together cultural heritage stakeholders from across Europe. 65 Currently, most enlargement partners have either acceded (Albania, Türkiye) or ratified (Bosnia and

Herzegovina, Montenegro, North Macedonia, Moldova, Serbia, Ukraine) the Convention. However, a few, such

as Georgia (approval pending) and Kosovo (not a Party), remain exceptions.

45

capacity building activities will support partnerships for cooperation, including international

partnerships (funded by the Global Europe instrument), as well as partnerships for excellence

and innovation. Capacity building will also contribute to policy development, including

experimentation, preparation and implementation of the Union’s policy agendas and tools

covering skills, education and training, youth and sport. Enlargement countries will benefit

from all the opportunities of the new programme, for capacity building as well as for learning

opportunities, once associated to Erasmus+. Before becoming associated, enlargement

countries will receive support to improve their education, training, youth and sport systems

thanks to the programme’s international dimension.

3.3.2 Policy gaps and delivery risks

Gaps in this policy area may relate to potentially lower levels of preparedness by enlargement

countries. On the other hand, EU policies as such are, overall, fit for enlargement.

Most of the education systems in enlargement countries are not yet as effective and inclusive

as those in the EU-27. While challenges also exist in current Member States, key gaps in

enlargement countries relate to early childhood education and care, foundational skills, basic

and advanced digital skills and competences, education equality, inclusivity of education,

higher education, including challenges to academic freedom, risks of brain drain in the light of

demographic trends and war-related issues. There is also a need to evaluate the capacity of

enlargement countries to deliver quality data education statistics and data, including on EEA

targets.

On sports, ethnic divisions and historical conflicts might create barriers to social cohesion,

women and girls face additional barriers to participation in sports due to cultural norms and

gender stereotypes, and their facilities might be inadequate.

On culture, there are particular needs concerning protection and restoration of cultural heritage

in Ukraine; and medieval monuments in danger in Kosovo.

Overall, the capacity of administrations is key as relevant programmes require compliance

with the principle of sound financial management, and in the case of association to Erasmus+

specifically the setting up of a national agency to manage funds under indirect management.

3.3.3 Reform orientations

In view of enlargement, the EU can further strengthen initiatives for integration in existing

programmes and capacity building support.

On education, enlargement may have to be taken into account when setting new EU level

targets. Also, the integration of new Member States could shine more light on different issues

in education policy. These issues would accordingly be higher on the EU agenda and may

require tailored policy measures and targeted interventions to uphold EU standards, using (after

accession) the instruments available in the EEA Strategic framework such as peer counselling

or the Learning Lab on Investing in Quality Education and Training. Enlargement countries

can already now make use of their membership of the EEA strategic framework working groups

to address these issues, including through participation in peer-learning activities or technical

assistance (via TAIEX for example). The EU Action Plan on Basic Skills, the Science,

Technology, Engineering, Mathematics (STEM) Education Strategic Plan and the EU Teachers

Agenda support national reforms in enlargement countries by providing common goals,

tackling shared challenges and contributing to increasing skill levels.

46

On youth policy, increased action might be required to address (the risks of) brain drain in new

Member States. Solutions could include initiatives to increase the engagement of young people

in society and democratic processes, providing more opportunities for young people to

experience exchanges, cooperation, cultural and civic activities in a European context and

further empowering youth, especially via youth work opportunities. Also, considering post-war

issues for Ukrainian citizens, the EU may need to put an added focus on managing, for instance,

issues such as post-traumatic stress disorder among young people, and a higher proportion of

persons with disabilities in the population, which may affect education and employability. As

long as Russia’s war of aggression continues, there is also a need for continuing support

regarding young Ukrainians now living in the EU.

For culture, enlargement countries may draw inspiration from the strategic framework for

culture, the Culture Compass for Europe, for their policy making and reform.

In the area of sport, the European Sports Model can serve as an inspiration to drive policy

making and reforms in line with EU values.

Aiming to have all enlargement countries associated to Erasmus+, additional assistance in the

set-up of national agencies and engagement of potential beneficiaries is required. There is also

a need to step up capacity building to higher education institutions, in line with the STEM

action plan.

3.4 Digital policies

Digital transformation has proven to be a gamechanger for society’s ability to tackle major

challenges, from productivity and economic growth, to fighting climate change and improving

public services. Digital technologies and infrastructure, along with local and regional enablers

such as the European Digital Innovation Hubs, are at the heart of the EU’s progress and

ambitions. At the same time, to realise the untapped potential of the digital transformation, the

EU must address new challenges to its democracies, economies and societies. The EU must

strive to shape a competitive, resilient and inclusive digital future, exploiting its strengths to

maintain or attain leadership in strategic technologies, to establish essential assets for

technological sovereignty and resilience, and to foster the commercialisation of deep tech

innovation. The EU must also further strengthen its cyber-resilience to protect its industries,

citizens and public administrations against internal and external threats. At the same time, the

EU is taking steps to optimise the application of the digital rulebook. A proposal for a Digital

omnibus66 was presented by the Commission in November 2025 with the AI part of the

proposal having been fast-tracked and entered into force in July 2026 67 . The immediate

objective is to ensure that compliance with the rules comes at a lower cost, delivers on the same

objectives, and brings in itself a competitive advantage to responsible businesses.

The International Digital Strategy for the EU, published in June 2025, sets out the EU's vision

for strengthening its international digital cooperation68. The Strategy proposes to advance the

international harmonisation of key digital transformation policies. Investing in secure digital

connectivity and boosting innovation are also at the heart of the EU’s cooperation with

enlargement and neighbourhood countries, via instruments such as Deep and Comprehensive

Free Trade Agreements and Stabilisation and Association Agreements. These trade agreements

66 COM (2025) 837. 67 Regulation (EU) 2026/1744 of the European Parliament and of the Council of 8 July 2026 amending

Regulations (EU) 2024/1689, (EU) 2018/1139 and (EU) 2023/1230 as regards the simplification of the

implementation of harmonised rules on artificial intelligence (Digital Omnibus on AI). 68 JOIN (2025) 140.

47

and other related instruments such as the Growth Plans for the Western Balkans, the Reform

and Growth Facility for Moldova and the Ukraine Facility set a strategic basis for the gradual

integration of enlargement countries into the digital single market.

Actions under the International Digital Strategy include promoting secure connectivity in

enlargement countries, notably the alignment with the EU 5G Cybersecurity Toolbox and

support to adopting legislative frameworks that would allow for the imposition of exclusions

and/or restrictions on high-risk suppliers. The Commission has proposed such restrictions at

EU level as part of the proposal for a revised Cybersecurity act in January 202669.

As regards artificial intelligence, the Strategy promotes cooperation on AI safety with EU

international partners including the Western Balkans, Ukraine and Moldova. The EU also

supports scientific cooperation and development of AI-based local digital twins underpinning

urban reconstruction in Ukraine. Under the GovTech4all framework partnership agreement,

enlargement countries can benefit from the development and piloting of AI solutions in the

public sector to enhance decision making, service delivery and internal administrative tasks.

In October 2025, the EuroHPC Joint Undertaking has selected for funding the first Moldovan

AI Factory Antenna (FAIMA) linking the country’s innovation ecosystem to PIAST AI

Factory in Poland. FAIMA will provide local stakeholders in Moldova with seamless access to

AI-optimised supercomputing resources, trusted data facilities, and advanced AI services. It

will focus mainly on agriculture and viticulture, healthcare and medical imaging, public

administration/e-government services, and cybersecurity/ICT, together with cross-cutting

activities supporting AI adoption by SMEs and startups. Similarly, in the Western Balkans two

AI Factory Antennas have been announced, one in North Macedonia (VEZILKA) and one in

Serbia (SAIFA), connected to the Pharos and IT4LIA AI Factories in Greece and Italy.

The EU aims to advance cooperation on cybersecurity with partner countries, including the

Western Balkans, Ukraine and Moldova. Cybersecurity is already part of the Digital Dialogue

with the Western Balkans. Amendments to the Association Agreements related to the

participation of Ukraine and Moldova in the Digital Europe Programme will also pave the way

to extend the EU Cybersecurity Reserve to both countries. In July 2025, Council has authorised

the use of the EU Cybersecurity reserve for Moldova and in June 2026 it has authorised the use

of the EU Cybersecurity reserve for Ukraine. Based on the rules in the EU Cyber Solidarity

Act, the Western Balkans also have the possibility to take part in the EU Cybersecurity

Reserve70.

When it comes to digital public services, the Strategy aims to advance towards mutual

recognition of electronic signatures and other trust services with third countries, including

Ukraine, Moldova and the Western Balkans. This includes developing a set of tools and

services implementing trust anchors for the global recognition of trust services and digital

identities and removing digital barriers by reusing and replicating the European Trust Services

infrastructure in their territory. In July 2025, Moldova has joined the EU Third Countries’

Trusted List for the validation of electronic signatures from non-EU countries. This allows the

easy validation of signatures and seals from organisations and individuals in the EU, making it

easier for EU and Moldovan companies and people to do business together. The process of

joining the EU Third Countries Trusted List has also started for Albania, Montenegro, North

Macedonia and Serbia.

69 COM (2026) 11. 70 The EU Cybersecurity Reserve is designed to support Member States and EU institutions, bodies and agencies

(EUIBAs), as well as under certain conditions Digital Europe Programme (DEP) associated countries in

responding to large-scale equivalent or significant cybersecurity incidents.

48

The EU also aims to cooperate with Ukraine, Moldova and the Western Balkans to prepare the

onboarding and development of interoperable solutions for online administrative procedures

and the Once-Only Technical System within the scope of the Single Digital Gateway. These

services make it easier for companies and individuals to do business, work and live in EU

countries.

The Strategy also aims to support the alignment of EU enlargement countries with the key EU

rules on online platforms, the Digital Services Act and the Digital Markets Act.

On data, theData Union Strategycalls for promoting EU approaches and mutually beneficial

collaboration with enlargement countries and closest neighbors71.

3.4.1 Impact of enlargement on digital markets and policies

Impact on the EU’s digital market

Enlargement would create a larger single market, which will in turn provide companies with

further opportunities to scale up and allow consumers to benefit from more competition.

Expanded cross-border interoperability of electronic identities and Trust services would

benefit citizens, governments and businesses alike. It will create opportunities for more

resilient networks and safe and secure data flows across an enlarged EU. This covers also

interoperability of digital Wallets between EU Member States and Western Balkan partners, in

line with the gradual integration objective under the Growth Plan. The precondition is for the

Western Balkan countries to have their own Wallets and be aligned with the EU methodology.

Initiatives that can be considered of preparedness for enlargement have been announced or are

already underway. One such initiatives aims to strengthen digital links in the Black Sea region

via secure, high-capacity Internet connections.

The roaming policy will be extended to millions more people and give users the possibility to

benefit from roaming travelling on a much larger territory. The elimination of roaming

surcharges is expected to generate a much greater increase in roaming traffic from EU

consumers in the third country joining the ‘Roam Like At Home’ area and vice versa. A similar

effect was observed within the EU when, between 2016 and 2019, EEA data roaming

consumption grew 17 times. Expanding the roaming policy poses challenges in terms of

revenue adjustments for operators, infrastructure investments, and regulatory compliance

which requires the renegotiation of wholesale agreements between EU and third country

(candidate country) operators, the modification of billing systems, compliance with

transparency requirements for consumers, the introduction of regulated fair use policies

mechanisms and participation in market monitoring exercises. For each country that joins the

‘roam like at home’ area, the operators concerned will need to make new adjustments. An

increase in roaming traffic may also translate into increased infrastructure investment needs.

EU operators may need to upgrade infrastructure to handle increased data and call volumes,

especially in popular travel destinations. Seasonality plays a significant role in this dynamic,

including for enlargement countries that are tourism destinations.

Importantly, the roaming policy can be extended to the association partners before enlargement,

subject to incorporation of the EU roaming acquis into their national legislation and Council

endorsement. This has already been achieved for Ukraine and Moldova who joined the ‘roam

like at home area’ as of 1 January 202672. Ukraine and Moldova have far-reaching Association

71 COM (2025) 835. 72 Decision No 2/2025 of the EU-Ukraine Association Committee in Trade Configuration of 16 July 2025 on the

European Union and Ukraine granting each other internal market treatment with respect to the sector of roaming

49

Agreements in place with the EU enabling gradual integration for roaming,in the wider

telecommunications sector, as well as in other sectors73. The process to extend ‘roam like at

home’ to the Western Balkans countries is ongoing. with Council having approved the opening

of negotiations with Albania, Bosnia and Herzegovina, Kosovo*, Montenegro, North

Macedonia and Serbia in June 2026.

A larger EU would impact cybersecurity policies and more widely the cyber posture of the

EU, as this is a domain with many cross-border dependencies and potential spillovers in case

of incidents. Enlargement would also mean that the new Member States would have access to

the EU cybersecurity cooperation platforms (e.g. NIS Cooperation Group, EU CyCLONe and

the CSIRTs Network), where effective cooperation depends on the level of trust towards

Member States, which will take time to build. Many enlargement countries have faced major

cyber threats over the past years and can provide valuable insights. The effective

implementation of the EU 5G Cybersecurity Toolbox and the revised Cybersecurity Act by

enlargement countries, a requirement to fulfil as part of the accession process, would enhance

the overall level of cybersecurity of the EU’s 5G networks. Moreover, the future Member

States will have access to cybersecurity funding opportunities that currently are only accessible

to Member States74.

Impact on EU digital policies

Most EU policies and legislation can be considered fit for enlargement. The operational

readiness of new Member States to adopt and implement the Digital Services Act (DSA) and

the Digital Markets Act (DMA), and to address the challenges related to the independence of

media regulators, the rule of law, civic space and the protection of fundamental rights is closely

linked to the fundamentals of the accession process and is assisted via TAIEX support.

Some specific impacts on the policy itself might be observed in the area of roaming. More

national market dynamics will need to be considered when defining wholesale roaming caps

and while possibly redefining the safeguard mechanisms that ensure sustainability of roaming

policies for operators. One impact of enlargement could be that market dynamics do not

improve, and that further regulation is needed in the future (beyond 2032), putting at risk the

proportionality of the intervention 75 . Based on the experience of the EEA, no special

arrangements/safeguards were needed. For some countries the impact will have already been

anticipated before enlargement, through the gradual market integration process.

on public mobile communications networks [2025/1742] (OJ L, 2025/1742, 18.8.2025, ELI:

http://data.europa.eu/eli/dec/2025/1742/oj). Decision No 1/2025 of the EU-Republic of Moldova Association Council of 4 August 2025 as regards the further

market opening with respect to the sector of roaming on public mobile communications networks and amending

Annex XXVIII-B (Rules applicable to telecommunication services) to the Association Agreement between the

European Union and the European Atomic Energy Community and their Member States, of the one part, and

Moldova, of the other part (decision to be published soon in the Official Journal of the European Union, part L). 73 These are the sectors available for regulatory approximation for Ukraine in view of gradual integration ahead

of accession to the EU. For Moldova, there is no limited list of sectors available for regulatory approximation. 74 Third countries are currently excluded from projects funded under the Digital Europe programme specific

objective 3 (Cybersecurity), while third countries that have a DEP-association agreement, can benefit from the

other specific objectives of the programme. 75 It must be noted that the RLAH policy is based on an intrusive form of market intervention. In short: "the EU”

is price regulating roaming services both at retail and wholesale level, an intervention uncommon to a market

economy. As established by the Court of Justice in the landmark decision on roaming (C-58/08), the intervention

is proportionate as it serves the wider benefit of consumers protection, and subsidiarity is ensured in view of the

smooth functioning of the internal market, but to ensure proportionality the Court concluded that the intervention

has to be limited in time. The roaming rules are in place until 2032, subject to further reviews.

50

Budgetary aspects

On the budgetary side, increased number of Member States would entail increased budgetary

needs to cover potential geographical gaps and ensure access to digital infrastructure across the

Union. Potential benefits would be reflected in investments in priorities such as European

supercomputers, AI factories and Gigafactories, data spaces and cloud, testing and

experimentation facilities, Digital Innovation Hubs, semiconductor pilot lines and advanced

digital skills across the Union. These investments help support EU’s efforts to prevent strategic

dependencies from third countries that are not part of the EU’s international strategic partners.

It would also imply increased needs for cybersecurity support. EU funding for digital policies

overall would be in the future available via the European Competitiveness Fund.

Budgetary resources would be required to address the digital connectivity infrastructure

needs in the new Member States, such as those linked to the Ukrainian reconstruction.

Currently, except for cross-border links, infrastructure on the territory of third countries is not

eligible for Connecting Europe Facility (CEF) funding, even for countries associated to the

programme.

For a set of policies, enlargement would not trigger impacts on the policy but on the investment

needs in the new Member States. For radio spectrum, introducing changes in the spectrum

use may entail significant investments in new communications networks and in transferring

certain services to new bands, which may require replacement of expensive equipment.

EU support may be needed for new Member States to modify and modernise their

communications infrastructure. Similarly, adequate resources and infrastructure may be needed

to support new Member States’76 digital identities and trust services and to ensure that they

have measures in place for the common level of cybersecurity and for implementing the

cybersecurity acquis, prior to joining the EU (a cybersecurity governance mechanism

including the necessary national-level bodies and structures, security requirements and incident

reporting obligations for entities from critical sectors, measures for exclusions or restrictions

on high-risk suppliers in 5G Networks and product security requirements). It would also be

important to maintain the principles, set out in the Commission Communication from 15 June

2023 providing the baseline for EU funding for 5G Networks, also included in the Reform

Agendas of the enlargement countries, which refer to the necessary steps for the

implementation of the 5G toolbox and in particular, the adoption of legal frameworks and

enforcement of measures of the EU 5G Cybersecurity Toolbox.

Enlargement would overall trigger the need for additional resources in the Commission to

handle the additional enforcement work and a larger participation in existing networks and

groups.

3.4.2 Policy gaps and delivery risks

Gaps mainly relate to a potential lower level of national preparedness (in terms of

infrastructure, digital-readiness and administrative capacity) to align fully to EU policies,

including when it comes to media freedom and pluralism.

For roaming specifically, currently, Commission services lack a legal basis for collecting the

extensive data on roaming with third countries (enlargement countries) necessary to conduct a

76 Pursuant to the EU digital identity framework, current and new Member States would need to have interoperable

digital identity schemes. New Member States will need to ensure that their digital identities and trust services

provide the required levels of security and trust.

51

proper assessment of the impact of enlargement, making it difficult to predict the possible

impact on the definition of wholesale caps.

On cybersecurity, due to legal restrictions, it is at present not possible to involve experts from

the enlargement countries in the EU cooperation platforms, nor has been possible so far for

them to benefit from EU funding programmes specific to cybersecurity.

3.4.3 Reform orientations

On electronic communications, the Review of the electronic communications framework and

its possible consolidation into a single instrument (the Commission proposal for a Digital

Networks Act 77 was presented in January 2026) would reduce administrative burden and

facilitate alignment with the EU acquis for enlargement countries.

The Roaming Regulation is a temporary intervention, subject to several reviews. Any impacts

of the extension of the EU roaming regime to enlargement countries would need to be

considered in the review. However, it would require extensive data collection. To collect

relevant data from enlargement countries before accession, the EU would need a specific legal

basis.

On cybersecurity, early involvement of enlargement countries in activities increasing the EU’s

cybersecurity capacities, including via closer partnership with the EU Cybersecurity

Agency (ENISA), would help foster the necessary trust. Cooperation in this field hinges

significantly on the trust established between experts, which goes beyond the broader political

relationships between participating countries. The Cyber Solidarity Act envisages the

possibility of granting access to the EU Cybersecurity Reserve to third countries associated

with the Digital Europe Programme, if their association agreements provide for it. This access

is subject to the following conditions: i) the enlargement countries must be associated with this

part of the programme; ii) the European Commission must assess the measures for cyber

resilience and cyber crisis management of the third country; and iii) a subsequent implementing

decision by the Council is required. The Reserve provides these countries with an opportunity

to leverage the EU's resources for incident response and partial access to the relevant funding

mechanism for cybersecurity.

Ensuring full alignment with DSA and DMA remains of the essence. Support measures do exist

already, and enlargement countries can be encouraged to make best use of them. Namely, an

enhanced utilisation of TAIEX will be beneficial for alignment with EU legislation on online

platforms and media(Audiovisual Media Services Directive, European Media Freedom Act

and the Recommendation on safety of journalists) which has an increasingly important digital

component. Countries in the Eastern Partnership can make use of EU4Digital78. Support from

the EU side helps align with the whole-of-society approach underpinned at EU level for

detecting, raising awareness and building resilience against foreign information manipulation

and interference (FIMI) and disinformation via a multistakeholder approach that involves civil

society and fact-checking organisations, media literacy practitioners and researchers.

The EU is also supporting the establishment of new European Digital Innovation Hubs

(EDIHs) in enlargement countries via targeted calls as fully-fledged members of the EDIH

network, helping to drive the digital transformation of SMEs, mid-caps, and public entities

based on local needs. These hubs will make full use of the AI infrastructure set out in the AI

Continent Action Plan to serve clients in both the private and public sectors.

77 COM (2026) 16. 78 Armenia, Azerbaijan, Georgia, Republic of Moldova, Ukraine.

52

3.5 Customs Union

A well-functioning Customs Union is essential to the EU’s competitiveness, sustainability,

safety and resilience. The EU customs authorities are the guardian of the EU’s external borders

for goods, playing a major role in the security of the supply chains and the level playing field

with the single market. Customs protect the financial interests of the EU and its Member States

by collecting customs duties and other taxes (excise duties and VAT). Customs implement

trade measures that protect the EU against unfair trade practices. Customs authorities also

uphold and enforce, together with other authorities, EU rules and regulatory requirements on

product compliance including health and safety, environmental protection, intellectual property

rights, fisheries and agriculture.

Given recent developments, such as in e-commerce, the fight against smuggling of drugs and

cigarettes, the circumvention of EU sanctions and increased use of tariffs as a trade weapon,

the role of customs in protecting and controlling the EU external borders for goods and in

combating customs fraud has become increasingly important.

The EU Customs Union will be strengthened over the next decade, thanks to the Customs

Reform which entered into force in September 202679.

The Customs Reform includes the withdrawal of the duty exemption on low-value

consignments ─ de minimis ─ and the upcoming gradual implementation of the reformed

Union Customs Code, which aims to reinforce the integrity of the single market and boost

border security, including in the context of e-commerce. The Customs reform also provides for

more harmonisation in the implementation of customs risk management and controls to ensure

effective EU-wide protection, irrespective of where the goods cross the external borders, as

well as the establishment of a new EU Customs Authority and an EU Customs Data Hub,

providing a single digital system for economic operators and better possibilities for sharing

customs data between competent authorities.

3.5.1 Impact of enlargement on Customs policy

Customs Union, EU customs territory and the protection of the external borders for goods

Enlargement would change the external borders of the EU customs territory80 . The current

external land border between the EU and enlargement countries will become an internal land

border through which goods can move without customs procedures.

New Member States will be responsible for customs controls and procedures at the land, air,

or maritime external borders on their national territory. Therefore, it is important that the new

Member States are fully ready, as from day one of their accession, to apply all the EU rules and

procedures on customs controls, duty collection and supervision of goods crossing the EU

external borders and to take measures to combat customs fraud effectively, according to high

standards of integrity and performance. Potential deficiencies in new Member States’ capacity

to supervise and control their part of the external border could, due to the free movement of

goods within the Customs Union, directly impact the integrity of the single market, the

financial interests of the EU and its Member States, and the security and safety of EU citizens.

79 Regulation (EU) No 2026/2108 of the European Parliament and of the Council of 16 September 2026

establishing the Union Customs Code and the European Union Customs Authority and Regulation (EU) No

952/2013 80 There will be an impact on the land borders. The current external land borders between the EU and third

countries will become internal borders, while new external land borders will be created (for example, between

Ukraine and Russia). The international airports and ports of the new Member States (for example Odessa in

Ukraine, Durres in Albania or Bar in Montenegro) will become the EU’s new external maritime and air borders.

53

The geopolitical situation of some enlargement countries may require a reflection on how to

protect the EU Customs Union in relation to parts of the national territory where the national

authorities do not exercise control.

Digital customs procedures

The EU customs policy is the most digitalised EU policy. It involves many digital systems,

high volumes, and critical real-time operations81. Enlargement would impact the effectiveness

of EU policies if future Member States do not have the necessary capacity and resources and

could create ‘weak links’ if (cyber) security is not ensured.

EU Customs Reform

The EU Customs Reform could facilitate the integration of new Member States into the

Customs Union by providing them with the opportunity to operate with the new tools (in

particular, the central EU Customs Data Hub) and with the support of the new EU Customs

Authority as from the date of accession (see further under “Reform Orientation”).

Traditional Own Resources (customs duties)

Enlargement countries rely heavily on the EU for both imports and exports, whereas the EU's

trade with these countries is relatively small compared to other partners. In absolute terms, the

EU exports more to these enlargement countries than it imports from them. Consequently, the

effect of enlargement on the EU's traditional own resources (customs duties) is likely to be

minimal when considering the trade between the EU and enlargement countries. However,

individual Member States, particularly those bordering enlargement countries, could be more

affected.

At the same time, without the necessary administrative capacity and capability to enforce tariff

measures, enlargement countries may encounter challenges in safeguarding the EU's own

resources, as they could be exploited as entry points for evading duty payments.

Budgetary aspects

Under the current multiannual financial framework (MFF), all enlargement countries 82

participate in the Customs programme83. The programme allows these countries to cooperate

with Member States’ customs authorities and get acquainted with EU legislation and good

practices including on the measurement of performance. Enlargement countries already at

81 The EU has built and manages 111 fully interoperable Customs digital systems complemented by national

systems interconnecting all 27 Member States. In 2025 an average of 212 items were declared per second, with

an estimated annual total of around 5.9 billion of e-commerce items (goods bought online and directly delivered

to the consumer in EU), around 630.9 million imported items and 580 million items exported from the EU.

https://taxation-customs.ec.europa.eu/customs/eu-customs-union-facts-and-figures_en 82 Albania, Bosnia and Herzegovina, Georgia, Kosovo, Moldova, Montenegro, North Macedonia, Serbia, Türkiye,

Ukraine. 83 The Customs programme is a cooperation programme for customs authorities, which supports the development

and operation of central digital customs systems and cooperation between customs authorities, as well as between

those authorities and the European Commission, by means of collaborative and training activities aimed at

reinforcing the harmonised functioning of a modern Customs Union. Under the current MFF and its previous

iterations, the programme automatically includes all EU Member States contributing indirectly through their

national contributions to the EU budget. In line with the approach established at corporate level for EU funding

programmes, in return for their participation in the programme, enlargement countries must pay a financial

contribution. Assuming that in the future MFF the financial contribution related modalities linked with the

participation in an EU programme would remain unchanged, in case of enlargement, the revenues associated to

the payment of this financial contribution would no longer exist in the current format. Enlargement countries

would be full members of the programme as a Member State, where participation to the programme is covered by

their national contribution to the EU budget.

54

present have access to training courses in customs policy and procedures (including in some

cases in their national language). They are not invited to all collaborative activities organised

under the programme, as some programme aspects relate to elements that cannot be shared

with non-EU countries, even in a pre-accession stage.

Most of the budget under the current Customs programme is dedicated to the development,

operation, and maintenance of central and decentralised digital customs systems managed by

the Commission, including the common communication network/common system interface

(CCN/CSI) to the national systems. Most of these central and decentralised EU customs

systems are not yet used by enlargement countries84.

The impact of enlargement on budgetary needs under the current scope of the Customs

programme will already occur before EU accession, both on collaborative activities (additional

trainings, project group meetings, and activities) and for digital systems. This is because

sufficient time will be needed before accession for customs services and traders to implement

the customs procedures and digital tools needed as part of the EU Customs Union.

In this respect, there will be a need for resources both before and after accession, stemming

from the participation of additional Member States in the EU digital customs systems. These

include:

• Support and technical assistance: resources for guiding the enlargement countries in various

workshops and missions, as well as developing a comprehensive plan of actions;

• Resources for connecting additional countries to the EU customs infrastructure e.g.

connectivity to the CCN/CSI;

• Costs for preparing the access to the central and decentralised customs systems (including

adapting environments, documentation, configurations, training, testing, etc.);

• Operational costs: budget needed for the operation and maintenance of the EU central and

decentralised systems for additional countries.

Also, the development by enlargement countries of national components or systems based on

EU requirements, including migrating their existing data to the new/adapted systems, will

require funding. These national developments are not included in the scope the current Customs

programme and are to be covered by the national budget.

The major upcoming internal EU development envisaged under the customs reform, notably

the transition towards the new EU Customs Data Hub, will have an impact on enlargement

countries. The budgetary needs to support enlargement would depend on the timeline of both

EU accession and the implementation of the EU Customs Reform. The impact and needs may

vary on whether countries will join in the current environment and will then transition to the

new environment or can directly join the EU Customs Data Hub (see under ‘Reform

orientations’).

Resources will also be needed to assess the enlargement countries’ capacity to effectively

protect the EU external borders for goods already before accession, for example through

monitoring visits (see under ‘Reform orientations’). The work providing a monitoring

mechanism has already started under the current Customs programme, allowing for a

coordinated support, efficiently covering customs policy and its implementation. This support

is expected to continue also under the future Single Market and Customs Programme 85

proposed for the new MFF for the period 2028-2034.

84 Except for New Computerised Transit System (NCTS) and the digital system for mutual recognition with the

EU AEO programme, as well as the connection to the CCN/CSI. 85 COM (2025) 590.

55

The proposed Single Market and Customs Programme should continue supporting

digitalisation, human competency building, collaborative activities including for enlargement

countries. It is expected to provide funding for the deployment of reliable and state-of-the-art

customs control equipment for enlargement countries and to address crisis situations in the EU,

an action to be implemented by the EU Customs Authority.

3.5.2. Policy gaps and delivery risks

Two major gaps in the current customs legislation that already affect the existing EU-27

countries, would – if not remedied – make the integration of new Member States in the Customs

Union more complex. These gaps, largely addressed by the EU Customs Reform, relate to: (i)

the complexity of the Union Customs Code’s digitalisation model, and (ii) the divergent

implementation of the customs legislation by Member States86.

The impact of these gaps on the EU’s capacity to cope with enlargement is that in addition to

connecting to the central digital systems, each candidate country is required to develop and

maintain its own national components for decentralised systems as well as fully national

systems in line with EU requirements. This is a significant investment for countries with limited

budgetary resources and administrative capacity. The lack of harmonised implementation and

enforcement capacity within the EU will make integration more complex as it would not

provide a conducive environment for new Member States who will be directly responsible for

protecting the EU external borders for goods.

Furthermore, the experience of the Member States that have joined the EU starting from 2004

has shown that customs administrations needed extensive legal, human competency and

capacity and IT preparation prior to accession. Enlargement countries face major financial,

personnel and technical support needs for collaborative activities, trainings, customs control

equipment and connection to the customs IT environment, to prepare their integration in the

Customs Union.

3.5.3. Reform orientations

Prior to accession, the Commission, with the support of the Member States and the EU

Customs Authority, will step up its activities, using the Customs programme, to ensure that

enlargement countries have the necessary capacity and capability to manage and oversee their

section of the new external border for goods, as well as to implement and enforce tariff

measures and EU rules on prohibitions and restrictions. The purpose is to ensure smooth

integration of new Member States in the Customs Union and its reformed legal framework

and digital tools.

The timely and effective implementation of the EU Customs Reform isacrucial contribution

for the enlargement process. The reform is aimed at transforming the way customs work

through an EU Customs Authority managing a central Data Hub, with a revised set of rules on

customs processes and common risk and data management. The EU Customs Authority will

be a new, operational EU actor, supporting and coordinating the activities of national customs

authorities, including in areas like training or performance measurement. It will also issue

operational guidance and develop common standards. This will contribute to a more uniform

application of customs legislation as well as non-financial measures such as prohibitions and

restrictions, and enlargement countries could benefit from this as well.

86 See also the Impact Assessment Report accompanying the customs reform proposal: https://eur-

lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52023SC0140

56

Furthermore, the reform can provide an opportunity for enlargement countries to operate with

the new central EU Customs Data Hub and with the support of the new EU Customs Authority

from the date of accession. This could make integration and enlargement easier and less costly.

Enlargement countries will be able to make use of the functionalities of the EU Customs Data

Hub, starting with the Data Hub for e-Commerce, from the date of their accession. However,

as the timeline for accession may precede the full operation of the EU Customs Data Hub for

all customs procedures, some enlargement countries may need to join the Customs Union

during the transition to the new environment, together with the current Member States.

Three scenarios for enlargement countries could be envisaged, depending on the date of

accession:

• Full adherence to the current EU customs systems and the way they are implemented

(decentralised, centralised, national) under the current Union Customs Code and the EU

Single Window Environment for Customs, except for the e-commerce transactions which

will be handled through the Data Hub for e-commerce from July 2028;

• For countries acceding to the EU before the EU Customs Data Hub has become fully

operational and the current EU digital customs architecture is sunset: mix of adherence to

current EU customs systems and, in parallel, for some customs procedures moving together

with the current Member States to the new central EU Customs Data Hub under the

Customs reform, though allowing for a customised approach depending on the country and

the timeline for accession;

• For countries acceding to the EU after the EU Customs Data Hub has become fully

operational: full transition to the central EU Customs Data Hub allowing less progressed

countries, considering also the timeline for accession, to proceed at their own pace and

avoid unnecessary highly costly developments at national level for only a limited period.

The EU Customs Reform will also strengthen the Customs Union Performance (CUP) tool87

currently managed by the Commission in close cooperation with Member States, by providing

it with a legal basis. Some enlargement countries88 already contribute to the CUP activities.

Their contribution is currently voluntary, like the contributions from the Member States. A

reinforced monitoring mechanism based on the CUP tool could support and complement the

EU accession preparations and be supplemented with other evaluations tools such as

questionnaires and monitoring activities carried out under the Customs programme. The EU

Customs Authority could play a role in the implementation of this mechanism.

Furthermore, as a strategic approach and long-term planning for the gradual integration of

enlargement countries into the Customs Union, a gradual approach could be considered.

Each progressive step should contribute to achieving the final objective, which should be EU

87 The CUP tool is used by the Commission (and in national customs administrations) for assessing the functioning

of customs in terms of effectiveness, efficiency, and uniformity (aiming at equivalent outcome from the national

implementation of customs legislation). The CUP mechanism is an evolving performance framework, and it can

be used for mapping performance at national level and comparing among countries with similar trade, risks, and

external borders (land, air, maritime). In the enlargement context, the CUP data could be used to compare

indicators provided by enlargement countries with those of similar Member States to identify performance gaps,

strengths, and weaknesses, and to set recommendations and targets for improvement. A first indicator could be

the ability to participate to the CUP expert group and provide at least 85% of the requested indicators (assessing

the readiness of their data systems). Digging deeper, visualisations could be developed to map the performance

of enlargement countries within the existing Member States’ range of performance. 88 Albania, Kosovo*, Moldova, Montenegro, North Macedonia, Serbia, and Türkiye. Moldova joined the CUP

network in 2024 and submitted data for the first time in 2026 (2025 data). Montenegro also sent 2025 data, after

rejoining in 2024. Kosovo is submitting data since 2023. Ukraine is an observing member since 2024. Bosnia

Herzegovina is not a CUP member anymore because they were not able to send in data.

57

accession. Creating legal frameworks aimed at improving connectivity or “Green Lanes”

between the EU and enlargement countries, enabling EU Member States to share customs data

with enlargement countries without compromising security, could reduce waiting times at

borders for legitimate trade and accelerate the enlargement countries’ integration into EU

supply chains. The European Commission, the EU Customs Authority, and the EU Member

States will be able to share customs data with enlargement countries under strict conditions set

out in EU legislation, as set out in the recently agreed in the Customs Union reform. This will

strengthen the enlargement countries’ capacity to prevent and detect illicit trade flows as well

as to control goods covered by prohibitions and restriction regulations.

Gradual integration in customs could also be achieved, for example, through agreements on

mutual recognition of customs controls, including security measures; agreements on providing

advanced access to certain EU customs-related databases and systems; or agreements on

removing specific controls at borders on certain types of goods based on equivalence with EU

standards on goods. Setting up systems for mutual recognition of authorised economic

operators, as already in place with Moldova, facilitates customs procedures for trusted

operators. North Macedonia, Serbia, Türkiye, Ukraine, Georgia, Moldova and Montenegro

have already joined the Common Transit Convention, which simplifies customs transit

procedures for goods moving between the EU and several third countries. The EU should step

up its support for other enlargement countries to accede to the Convention.

3.6 Taxation policy

Taxation is a key policy area for enlargement countries. Properly designed, well-functioning,

non-discriminatory tax systems in Member States are fundamental for ensuring a level playing

field for business and for citizens’ mobility in the internal market. Domestic resource

mobilisation will be essential for new Member States to finance a variety of competing public

policy goals in a context in which these countries will be part of the parameters set under the

EU’s fiscal governance framework while being confronted with a set of megatrends (such as

an ageing population, climate change, decarbonisation of the economy, security challenges).

3.6.1 Impact of enlargement on taxation policy, policy gaps and delivery risks

Enlargement would extend the scope of application of the cross-border administrative

cooperation mechanisms laid down in the EU tax legislation. This will trigger additional

exchanges and cooperation between EU tax administrations and international partners. For

example, if new Member States’ tax and revenue administrations initially have more limited

administrative and IT capacities, it will be essential to put in place the necessary IT tools and

ensure their interoperability with the EU IT systems, to preserve the integrity and performance

of the single market. Strengthening administrative capacities will be crucial to administer and

enforce national tax laws and curb tax fraud and avoidance, thus preventing a widening of the

tax compliance gap. New Member States will need to step up their administrative and

enforcement capacity in order to control external borders for taxation (VAT and excise duties)

and customs purposes; to control intra-EU transactions in the context of indirect taxation; and

to abolish tax barriers to uphold the fundamental freedoms related to intra-EU movements

towards individuals and businesses (taxpayers). Although enlargement should bring additional

resources to the EU budget from new Member States, a lack of adequate preparedness could

also mean that higher risks of tax fraud and tax avoidance increase in proportion with the

additional taxpayers and the volume of cross-border trade.

At EU level, it will be essential to carefully assess any VAT related derogation requests, in

particular those that would potentially impact fiscal neutrality and competition in intra-EU

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trade given that VAT is a harmonised indirect tax, a prerequisite for the proper functioning of

the single market. It is also key to ensure the minimum effective taxation of multinational and

large domestic groups.

In addition, the decision-making process might be slower, and more complex given the

unanimity rule required for taxation policy.

Direct taxation policies

The impact of enlargement on direct taxation is assessed as being none to small for certain

aspects, and more significant for other parts of the acquis. For a large part of the policy field,

i.e. cross-border administrative cooperation, dispute settlement and refund of excess

withholding taxes, vigilance is needed to ensure operational and IT capacity for the policy to

function in practice89.

Regarding minimum effective taxation (so-called Pillar 2), enlargement countries are member

of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting and have an

interest to prepare for Pillar 2 implementation to fulfil their international obligations and ensure

compliance with the OECD monitoring mechanism.

Regarding the Code of Conduct Group, for issues of harmful tax regimes (soft law),

potentially harmful tax regimes in most of the enlargement countries have been screened as

part of the EU listing process (list of non-cooperative jurisdictions for tax purposes) and are

addressed as part of the accession process. Moreover, the EU enlargement countries are part of

the regular monitoring under the OECD Global Forum on transparency and exchange of

information for tax purposes, the forum on harmful tax practices and the inclusive framework

on base erosion and profit shifting (BEPS).

Indirect taxation policies

Enlargement may pose challenges to the effectiveness of the regulatory framework, if not

addressed properly. Regarding

• VAT: there could be risks of further fragmentation within the single market, potentially

causing distortions of competition and legal uncertainty in important sectors. More Member

States could mean over time the potential for a rise in derogation requests, where countries

seek deviations from standard VAT rules, or from inconsistencies in how existing

exemptions or other general provisions are interpreted and applied. Both trends could

undermine the uniformity of application essential for the single market. Inconsistent

transposition of these provisions might affect fiscal neutrality and own resources,

complicating intra-EU trade.

89 For cross-border administrative cooperation between tax authorities, enlargement implies that more taxpayers

and natural or legal persons with a reporting duty would fall within the scope of the cooperation mechanism and

that tax authorities of new Member States become involved in the relevant cooperation mechanism. The volume

of exchanges is substantial and based on requirements for national IT systems and national administrative capacity.

As regards settlement of tax disputes between tax authorities on double taxation stemming from double taxation

treaties, tax authorities of new Member States need to be sufficiently prepared to provide tax (legal) certainty for

economic operators active in cross-border operations across the EU. On faster and safer tax relief of excess

withholding taxes paid by investors cross-border, the FASTER directive will make withholding tax procedures in

the EU more efficient and secure so that investors get their excess withholding taxes paid back swifter. At the

same time, FASTER will also ensure that the possibility of committing fraud with withholding taxes is tackled.

Enlargement would therefore have a positive impact on this direct taxation policy field, as it will extend its scope

of application. Its operationalisation is underway and financial intermediaries have in place the necessary

automated procedures and tax authorities need to be able to issue digital tax residence certificates and verify

information on compliance.

59

• Excise duties: there could be increased risks of distortion of competition in the single

market including increase of smuggling of excisable products, and of revenue loss for those

Member States which apply high excise duties.

• Energy taxation: there could also be a risk of discrepancies among Member States (e.g.

lower taxation of mineral oils for transport and, to a lesser extent, heating fuels for industrial

purposes) leading to so-called ‘tank tourism’. The revision of the Energy Taxation Directive

(ETD) is being negotiated in Council. Due to the unanimity voting in Council on taxation

matters, further policy developments in an enlarged EU could also be affected by the state

of energy systems and energy transition in new Member States.

• IT systems’ compatibility and digitalisation: integrating the IT systems of new Member

States into existing EU systems can be complex due to differences in technology and data

management practices.

At the same time, if enlargement is properly managed, the combined tax bases of Member

States would grow and diversify, which could strengthen the EU’s own-resources revenue. A

broader cumulative tax base across Member States would also improve fiscal resilience,

helping absorb economic shocks more effectively and stabilising the overall system.

Budgetary aspects

Under the current MFF, the (potential) enlargement countries90 participate in the Fiscalis

programme (2021 – 2027)91 . The programme offers to these countries the possibility to

cooperate with EU Member States’ tax authorities and to get acquainted with the sector-specific

EU legislation and operational good practices.

Tax administrations of enlargement countries already participate in the programme’s

collaborative activities and have access to tax training courses funded by the programme.

There is potential for an increased use of the available training courses by enlargement

countries and, consequently, an increasing need to translate the existing eLearning modules in

the languages of the enlargement countries92 which will require dedicated translation resources

as well as new face-to-face training events to be organised to cover their training needs. In

addition, increase in expenditure could be expected to develop EU-level training products

(eLearning modules or similar) specifically targeting enlargement countries’ needs either in

relation to transposing the EU tax legislation or acquiring practices related to EU digital

systems and other operational aspects.

The financial impact would be important when it comes to ensuring access to and extending

the application of the central components of the European Electronic Systems in the area of

taxation, because of the integration and participation of new Member States in these systems.

This entails changes to existing systems at EU level that are supposed to be developed before

the accession, and at Member States level and coordination with both Member States and

Enlargement countries with the need of testing those systems. DG TAXUD has estimated

amounts for preparation, configuration, connectivity, conformance and deployment to

operations.

90 Albania, Bosnia and Herzegovina, Georgia, Kosovo, Moldova, Montenegro, North Macedonia, Serbia, Ukraine.

Türkiye does not participate in the programme. 91 Regulation (EU) 2021/847 of 20 May 2021 establishing the ‘Fiscalis’ programme for cooperation in the field

of taxation and repealing Regulation (EU) No 1286/2013 (Article 5). 92 Currently, some of the EU eLearning modules are only translated into Macedonian, Serbian and Turkish.

Moldova is using the modules translated in Romanian.

60

The Fiscalis programme is the sole source of funding for these EU systems (for EU Member

States only, and not for enlargement countries). The number of tax European electronic systems

to be designed, developed, and operated supporting the operation of taxation policy at EU level

is continuously increasing. Currently, there are around 30 operational EU digital tax systems

of which the common EU level components are managed through the Fiscalis programme.

Integrating the national IT systems of enlargement countries with these existing EU systems

can be complex and would require increased financial resources.

The tools used under the programme (collaborative activities (grants), procurement contracts)

are flexible enough to allow the Commission and participating countries to come forward with

initiatives, should a new policy priority emerge.

Overall, the Commission and Member States would likely need to invest in technical support

through the Fiscalis programme or future external action-related instruments to ensure that EU

enlargement countries have developed adequate capacities and tools to effectively fight against

tax avoidance, tax evasion, and tax fraud in line with the EU rules.

Finally, as part of the transition process for all enlargement countries towards fully functioning

market economies, the new single market and customs programme proposed for the 2028-2034

MFF is expected to boost the approximation of legislation in the enlargement countries, provide

capacity building, including improving operational capacities and digital integration as well as

provide targeted awareness raising.

3.6.2. Reform orientations

On indirect taxation, introducing new derogations should be avoided, as these could have an

impact on fiscal neutrality and competition in intra-EU trade and help new EU countries to

ensure their preparedness for implementing digital and simplified tax compliance. New

performance indicators may be needed to monitor adequately the effectiveness of tax collection

and to support closing loopholes in the fight against tax avoidance, evasion and fraud.On

VAT, a more detailed timeline and roadmaps for the gradual approximation to the EU acquis

is being developed with enlargement countries. Also, in the area of excise duties, it could be

helpful to identify the areas where existing national legislation falls shorth of harmonised EU

rules and then develop with the enlargement countries concerned an action plan with a

timetable for the implementation of the EU acquis, with progress assessed at regular intervals.

To help prevent tax evasion and ensure proper collection of VAT and excise duties at EU level,

the Commission could consider proposing enhanced anti-fraud measures in VAT and

excise duties legislation. The enlargement countries are for the first time being included in the

annual 2025 EU VAT Gap report of the Commission93.

The enlargement countries can be further encouraged and supported to participate in customs

and taxation trainings currently available as e-learning modules, training events and learning

materials.

Exploring governance options to facilitate decision-making at EU level in all the taxation

fields, including by removing the unanimity rule would afford more flexibility to the taxation

policy development and could provide additional pathways for harmonisation94 .

93 https://op.europa.eu/en/publication-detail/-/publication/b5c7403b-d67f-11f0-8da2-01aa75ed71a1/language-en. 94 See Chapter II.1 on governance in the Communication.

61

3.7 Economic policies

The European Semester is the overarching framework for economic and fiscal policy

coordination within the EU. It is an annual cycle designed to ensure that national economic,

social, and budgetary policies are analysed and assessed collectively. It encompasses the

macroeconomic imbalance procedure, created to prevent and correct risks to macroeconomic

developments.

Since the spring of 2024, EU fiscal policies have been coordinated under the new economic

governance framework, which aims to strengthen Member States’s debt sustainability and

promote sustainable and inclusive growth in all Member States through growth-enhancing

reforms and priority investments.

EU Member States, except Denmark, are legally committed to adopting the single currency.

For all new Member States as well as for the other Member States that have not yet adopted

the euro and have committed themselves to do so, the Commission submits a convergence

report to the Council at least every two years, on the progress made.

3.7.1 Impact of enlargement on EU economic policies

With enlargement, there would be greater economic diversity across the EU and regarding

the macroeconomic imbalance procedure (MIP). New Member States would require close

supervision as they will have lower per capita GDP and may face risks of high inflation linked

to the economic catching up process. If these risks are not well managed, they could lead to

unsustainable dynamics and abrupt adjustments. It is possible that some new Member States

are placed under the excessive deficit procedure. In the context of the European Semester, the

inclusion of new Member States will introduce a greater diversity of economic structures, fiscal

capacities, and reform priorities, potentially adding complexity to EU level policy

coordination.

In enlargement countries, the European Semester is reflected in the annual submission of

economic reform programmes and the subsequent multilateral economic policy discussions

between the EU and enlargement countries which adopts policy recommendations. In the case

of the Western Balkans and Moldova, the Economic Reform Programmes focus on the

medium-term macro-fiscal framework and are supplemented by the Reform Agendas related

to the new Western Balkans and Moldova Plans respectively. The Reform Agendas identify a

set of priority reforms, broken down into measurable steps which will serve as payment

conditions. In the case of Ukraine, the Ukraine Plan, the main tool for delivering the Facility,

sets out the government’s priorities, the sequencing of key reforms and investment priority

areas, which will bring about economic growth and resilience, foster its integration into the

single market, and ensure that Ukraine gradually align its legislation with the EU acquis.

Enlargement would have an impact on international relations and on participation in fora such

as the IMF, World Bank, G7, and G20. Nevertheless, close economic cooperation with new

Member States would be an opportunity for the EU to strengthen its voice in international

settings. Specifically, as regards the IMF, coordination will be done with more countries, and

the EU voting share within the Fund in absolute terms will become slightly larger. However,

many of the enlargement countries are IMF debtors, which might make EU coordination on

IMF policy items more challenging.

Article 140 (1) TFEU establishes a set of four criteria for adopting the euro, which are further

developed in Protocol No 13 on the convergence criteria annexed to the Treaties:

62

(i) the 12-month average inflation rate not exceeding the reference value calculated in

accordance with the Treaty (inflation criteria);

(ii) the country not being subject to an excessive deficit procedure under Article 126(6)

(fiscal criteria);

(iii) participation in the exchange rate mechanism of the European Monetary System (ERM

II) for a minimum period of two years, during which the country must maintain the

value of its currency against the euro close to a central rate, without severe tensions

(exchange rate criteria); and

(iv) the long-term interest rate not exceeding the reference value calculated in accordance

with the Treaty (interest rate criteria).

Article 140 (1) TFEU also requires an examination of the compatibility of a Member State’s

national legislation with Articles 130 and 131 of the Treaty and with the Statute of the European

System of Central Banks and of the European Central Bank. It also calls for an examination of

other factors relevant for economic integration and convergence.

As it was the case with past enlargements, enlargement would not require a change in the

criteria for adopting the euro established in Article 140 (1) TFEU. However, the fact that two

enlargement partners (Kosovo and Montenegro) have unilaterally adopted the euro as their sole

legal tender, as a matter of national law, before the formal euro adoption process, pursuant to

Article 140 TFEU, raises issues for the interpretation of the exchange rate and long-term

interest rate criteria for these countries. The exchange rate criterion can be regarded as a market

test for both the central rate and for the extent of convergence in general. Complementing this,

the long-term interest rate convergence criterion also reflects a positive view of the markets

regarding the sustainability of convergence in terms of low currency and default risk premia.

If the enlargement country in question does not have its own currency the two tests cannot be

applied and/or interpreted in the usual way. Absent these market-based tests, alternative

solutions will need to be found to ensure that the ‘euroised’ country has achieved a high

degree of sustainable convergence before joining the euro area95.

Budgetary aspects

Whilst enlargement countries have access to guarantees through the European Fund for

Sustainable Development Plus (EFSD+), as new Member States they would have access to the

Invest EU Programme (or its successor in the Competitiveness Fund under the next MFF),

the internal investment programme of Member States, and this may affect the availability of

this funding (or its successor).

New Member States would also become shareholders of the EIB, which would entail rights

and obligations in line with the statute of the EIB.

Following their accession to the EU, new EU Member States that have not yet joined the euro-

area and face difficulties regarding their balance of payments would become eligible for

financial assistance through the Balance of Payments Facility currently operating with a

ceiling of EUR 50bn. If the number of potential beneficiaries increases, there would be a

95 The Commission developed a solution to address the exceptional situation of Montenegro in order to ensure

that the convergence assessment applied to Montenegro is equivalent in economic terms to that applied to other

Member States and duly allows to assess Montenegro’s compliance with the high degree of sustainable

convergence required by Article 140 TFEU. The Commission has proposed an in-depth examination of ‘other

factors’ relevant to economic integration and convergence, as mentioned in the last subparagraph of Article 140(1)

TFEU. The Council’s Eurogroup Working Group (EWG) expressed its support for the Commission’s proposal

for an adjusted convergence assessment framework for Montenegro.

63

potential decrease in available amounts for the seven non-euro area Member States that

currently have access to financial assistance from this Facility96.

In a baseline scenario, the accession of new Member States would increase demand on the

Pericles programme – the instrument for combating euro counterfeiting, both in terms of

Commission procured actions and in terms of possible applications from authorities of new EU

Member States. Inadequate support to competent authorities in these countries would

undermine the homogeneous level of protection of the euro in the EU and create opportunities

for organised crime.

The Commission provides support to enlargement countries through the Macro-Financial

Assistance (MFA), a mechanism that provides financial aid (loans and grants) to partner

countries experiencing a balance of payment crisis. Enlargement would reduce the number of

members benefiting from this support, as new Member States will no longer be eligible. At the

end of 2024, close to 80% of the outstanding amounts of MFA loans belonged to enlargement

countries.97

Enlargement would also trigger the need for adequate resources within the Commission, to

among other things handle a larger number of Member States as part of the European Semester,

close supervision of new Member States as part of the macroeconomic imbalance procedure,

as well as continuous engagement and possibly technical assistance in view of the reformed

fiscal framework.

3.7.2 Policy gaps, delivery risks and reform orientations

The main gaps are not related to policies but to preparedness in the enlargement countries.

Continued technical support remains of the essence (notably for alignment with the recently

reformed fiscal framework), but no major changes to the policies seem needed. The

Commission could also, in line with its overarching priorities, explore policy simplification

options, including the option of ensuring greater consistency in regulations as a follow up to

the revision of the economic governance framework. Simpler rules will facilitate their effective

application in both current and future Member States.

As explained above, for the assessment of the exchange rate and the long-term interest rate in

the case of Montenegro that has unilaterally adopted the euro as its sole legal tender, as a matter

of national law, before EU accession, the Commission has designed an adjusted convergence

assessment framework that is economically equivalent to that applied to other Member States.

4. A DECARBONISED ECONOMY AND SUSTAINABLE CONNECTIVITY

4.1 Climate and emission reduction policy

The European Green Deal sets out how to make Europe the first climate-neutral continent by

2050, boosting the economy, improving people's health and quality of life, caring for nature,

96 This amount is currently available for seven Member States, representing approximately 2% of these MS’

combined GDP in 2023. The accession scenario could increase the number of potential beneficiaries to 16, albeit

adding mostly smaller economies. This would in turn reduce the proportion of BoP Facility funding in relation to

potential beneficiaries' combined GDPs. Nonetheless, given both the backstop nature of the BoP Facility (i.e. it is

only there for times of crisis) and the generally small size of the economies of the potential countries joining the

EU, there does not appear to be any imminent need to increase the size of the ceiling. 97 This excludes the exceptional MFA+ assistance to Ukraine, which is treated separately given its specific nature

and scale.

64

and leaving no one behind98. To stay course on the goals set out in the European Green Deal,

decarbonise our economy and bring down energy prices, as part of its 2024-2029 priorities, the

Commission presented a Clean Industrial Deal99 to make our industry competitive and create

quality jobs. The Clean Industrial Deal brings together climate action and competitiveness

under one overarching growth strategy, with a commitment to accelerating decarbonisation,

reindustrialisation and innovation, thereby reinforcing Europe’s resilience. It outlines specific

measures to turn decarbonisation into a growth driver for European industries by focusing on

energy-intensive industries and clean tech.

Enlargement of the EU wouldboostits leadership in decarbonisation and amplify the EU's

voice on the global stage, strengthening the EU’s global contribution to reducing greenhouse

gas emissions. The EU framework also includes instruments that distribute EU-wide efforts

and between Member States to allow the Union to meet its binding emission reduction

objectives – in areas such as energy efficiency and renewable energy, power sector and energy

intensive industries, land use-change and forestry. Integrating countries which are at an earlier

stage of decarbonisation compared to the EU comes with the need to ensure fair and balanced

impact and support across current and future Member States but also brings benefits to drive

investment and growth in employment in the new Member States.

4.1.1 Impact of enlargement on the climate and emission reduction policy

Enlargement could have a significant impact on the achievement of EU’s legally binding

climate targets and on the Emissions Trading System, the ‘cap and trade’ mechanisms for

emissions that support the transformation of the EU economy in line with its climate ambitions.

EU’s climate targets and the European Climate Law

Regulation (EU) 2021/1119 establishing the framework for achieving climate neutrality (the

European Climate Law) sets into law the objective for the EU to become climate-neutral at

the latest by 2050. It also sets the intermediate target of reducing net greenhouse gas (GHG)

emissions by at least 55% by 2030 compared to 1990 levels and provides for the setting of a

climate target for 2040.

In February 2024, the Commission presented its detailed assessment for a 2040 climate target

for the EU100. In March 2026, the EU adopted an amendment101 to the European Climate Law,

setting a legally binding 2040 target of 90% reduction in net GHG emissions compared to 1990

levels. From 2036 onwards, high-quality international credits may be used up to a limit of 5%

of 1990 EU net emissions to make an adequate contribution towards the EU 2040 target in a

way that is both ambitious and cost-efficient. The reaching of the different, overarching targets

of the EU will be affected by future enlargement. If more countries join the European Union,

more GHG emissions and removals would be covered by the EU’s climate targets. Overall,

this could have a positive impact on global climate ambition, as more countries would apply

ambitious climate legislation that results in significant domestic GHG emissions reduction and

more removals. The Commission has published detailed assessments of the impacts of the EU’s

98 COM (2019) 640. 99 COM (2025) 85. 100 COM (2024) and SWD (2024) 63. 101 Regulation (EU) 2026/667 of the European Parliament and of the Council of 11 March 2026 amending

Regulation (EU) 2021/1119 as regards the setting of a Union intermediate climate target for 2040.

65

climate targets102. At the time of assessment, it was not yet possible to assess the impact of

future accession.

Enlargement countries have higher carbon intensities than the current EU average. For

example, over 60% of primary energy production in Bosnia and Herzegovina and in Serbia

comes from coal103, compared to the EU average of around 16% of primary energy production

coming from solid fossil fuels in 2022. Integrating enlargement countries could reduce their

emissions significantly, provided they invest in clean energy and modernisation of their

infrastructure to meet EU requirements. Moreover, such investment efforts will need to

continue also once they become EU Member States.

Based on current emissions and projections of enlargement countries, the EU target for 2030

(-55% compared to 1990 levels) remains achievable. Due to significant deindustrialisation after

1990, enlargement countries have substantially decreased their total emissions. At the same

time, climate policy instruments with 2030 national targets104 may require adaptations to reflect

the inclusion of new countries.

Reaching the EU targets for 2040 (90%) and 2050 (climate neutrality) might require a change

in distribution of effort by current and/or new Member States, to ensure that the overall EU

goal is achieved. Accession may lead to a redistribution of the ambition effort based on Member

States’ respective capacities, as is the current approach in the climate policy instruments with

national targets from the Fit-for-55 package. The magnitude of the impact on existing Member

States’ efforts will depend on the GDP of the enlargement country in question and on its

emission size and opportunities for abatement and their costs.

With the 2040 target now legally binding, the Commission is preparing the policy proposals

for the post-2030 policy framework105 needed to reach the 2040 target considering, among

other things, fairness, technological neutrality and cost-efficiency, strengthening EU

competitiveness, ensuring a just transition and improving environmental sustainability. The

impacts on policymaking are significant but appear manageable, if enlargement is

appropriately considered in the design phase of the climate policy framework, including in

terms of timing and sequencing of enlargement. Synergies with other policy areas are also

important in this context – e.g. with energy, transport, industry and agriculture.

The European Climate Law also requires the relevant EU institutions and Member States to

ensure continuous progress in enhancing adaptive capacity, strengthening resilience and

reducing vulnerability to climate change. Member States are to implement national adaptation

strategies and plans, regularly update them and include related updated information in reports.

The Commission has adopted a Union strategy on adaptation to climate change in any review

of which an enlarged EU would need to be considered. The Commission is developing a new

integrated framework for European climate resilience and risk management, expected to be

adopted during the second half of 2026.

EU Emissions Trading System

102 The 2050 climate-neutrality objective (in-depth analysis in support of the Clean Planet for all Communication,

COM (2018) 773; 2030 climate target (2030 Climate Target Plan impact assessment, SWD (2020) 176); the

recommended climate target for 2040 (impact assessment on a 2040 Climate Target, SWD (2024) 63). 103 See IEA country pages (e.g. Serbia). 104 Namely the Effort Sharing Regulation – Regulation (EU) 2018/842 and the Regulation on land use, land use

change, and forestry, LULUCF – Regulation (EU) 2018/841. 105 The Commission has proposed updates to the EU ETS directive in July 2026. A revision of national targets

and flexibilities in the EU climate policy framework is due in Q4 2026.

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The overall impact of future enlargement on the EU Emissions Trading System (EU ETS -

Directive 2003/87/EC) is expected to be considerable, with new countries having to join the

system once they are EU Member States. The EU ETS is the cornerstone of the EU’s policy to

tackle climate change, by cost-effectively reducing GHG emissions. It is based on the cap-and-

trade principle. The system allows trading emission allowances, so that the total emissions of

the covered activities remain within the cap and the least-cost measures can be used to reduce

emissions. The current (fourth) phase of the EU ETS runs from 2021 to 2030. For this period,

the EU has set a target to decrease GHG emissions by 62%, compared to 2005 levels. The

system applies to power plants, a wide range of energy-intensive industrial sectors, flights

within the EU and the European Economic Area and departing flights to Switzerland and the

United Kingdom, and maritime transport. In July 2026, the Commission proposed an

amendment106 to the ETS directive, to make the system the innovation and investment engine

for EU competitiveness, while continuing to support the delivery of the EU's 2040 climate

target.

A new separate, stand-alone ETS (named ‘ETS2’) has been set up to cover from 2028 the CO2

emissions from fuel combustion in buildings, road transport and additional sectors that

correspond to industrial activities not covered by the existing ETS (‘ETS1’).

The inclusion of new countries in the EU ETS would result in a larger carbon market, with

both increased supply and increased demand of allowances. In 2020, the GHG emissions of the

equivalent sectors covered by ETS1 (stationary installations) in the Energy Community

Contracting Parties107 represented approximately 19% of the EU ETS1 stationary installations

emissions. Including new EU countries in the EU ETS would increase the size of the market in

a non-negligible way, even though such increase depends on the countries joining the EU

(Ukraine representing a high share of those emissions) and timing of accession.

The effects of extending the EU ETS to countries at a less advanced stage of economic

development and decarbonisation needs to be carefully assessed, both in terms of impacts on

new Member States and in terms of impacts on the EU ETS. This includes impact on market

functioning, ambition and carbon price, given that the initial abatement costs are expected to

be lower in new EU countries than in the rest of the EU. Such impacts have not been analysed

so far and require both qualitative and quantitative assessment. The impacts would also vary

depending on which countries join the EU – with higher impacts expected from the integration

of larger countries and from countries whose economies are very carbon intensive. Moreover,

timing is important: the later the integration to the EU ETS, the greater the risks of a

decarbonisation gap with the current EU ETS participants.

Enlargement requires a revision of the cap to cover the emissions from the activities subject to

EU ETS in the new Member States, and linked to that, changes to the Market Stability Reserve

and other key ETS building blocks, such as carbon leakage protection and market oversight

measures. In addition, the distribution of ETS revenues as well as existing solidarity

mechanisms under the EU ETS would need to be reviewed. This is expected to be a key aspect,

affecting both new and current Member States.

In the new EU countries, strong administrative capacity will be needed to set up, implement

and properly enforce the EU ETS legislation, and in particular the rules on monitoring,

reporting, verification of GHG emissions and accreditation of verifiers, ensure the surrendering

106 COM (2026) 616. 107 The Energy Community is an international organisation bringing together the EU and nine neighbouring

enlargement countries or potential candidates, to create an integrated regional energy market based on a legally

binding framework. The 9 Energy Community contracting parties are Albania, Bosnia and Herzegovina, North

Macedonia, Kosovo, Montenegro, and Serbia, Georgia, Moldova and Ukraine.

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of allowances, manage the accounts in the Union registry as well as the free allocations rules.

Also, implementation and enforcement of the relevant financial services legislation (EU ETS

allowances being financial instruments) is a pre-requisite to prevent market abuse, money

laundering and other forms of malpractice in an enlarged EU ETS.

The impact of enlargement on the EU ETS for the maritime sector would be multifaceted.

Environmentally, it would contribute to emission reductions and to the shift towards greener

maritime practices. Economically, it could spur investments in energy-efficient technologies

and towards more sustainable practices, helping modernise the fleet, and the maritime sector

in general, and improve the competitiveness of the industry. Politically, it would signal a wider

commitment to reaching the EU’s climate goals and further aligning with EU regulations.

Enlargement would likely have a significant impact for both the EU ETS Directive and MRV

regulations in the maritime sector. Increased coverage of emissions from ships, more

comprehensive data collection (linked to the need for administrative capacity), and more

stringent compliance measures are expected.

For ETS aviation, as for the general EU ETS, enlargement would have a positive impact on

global climate ambition and reduce risk of carbon leakage/competitive distortion, but it may

require a redesign of the EU’s climate policy108.

F-gas and ODS Regulations

The impacts of future enlargement on the fluorinated greenhouse gases (F-gases) Regulation

(Regulation (EU) 2024/573) and on the Ozone Depleting Substances (ODS) Regulation

(Regulation (EU) 2024/590) are expected to be small, requiring technical adjustments

(recalculating the EU baseline; a limited number of additional undertakings that would need to

be registered) but no policy changes. Enlargement would positively impact global ambition.

Enhanced cooperation with customs would be needed and would be of benefit, to ensure

effective controls at the borders.

CO2 standards for vehicles, fuel quality, car labelling

Rules on CO2 standards for vehicles (Regulation (EU) 2019/631 and Regulation (EU)

Regulation (EU) 2019/1242), Fuel Quality Directive (Directive 98/70/EC) and Car Labelling

Directive (Directive 1999/94) aim to contribute to the decarbonisation of the road transport

sector, to reach the EU’s GHG targets for 2030 and beyond and help reach the goals of the

Paris Agreement. The CO2 standards and Car Labelling rules are currently being revised as

part of the Automotive package initiative with a view to supporting the industry in the transition

to zero-emission mobility, while maintaining the climate targets and offering more flexibility

to the EU industry. Enlargement would positively impact ambition. From a climate perspective,

wider implementation of the vehicle CO2 standards could bring further reductions in CO2

emissions in the road transport sector and accelerate the shift towards zero-emission mobility

in new Member States. Economically, enlargement could drive investments in zero-emission

mobility technologies including infrastructure, help modernise the vehicle fleet and make their

automotive industries more competitive.

The impacts of enlargement on the policies setting CO2 standards for vehicles are expected to

be small. Enlargement would not require changes to the vehicle CO2 standards, but there will

be impacts on implementation, with more reporting authorities, more vehicles in the EU fleet

and more vehicle manufacturers to which the standards would apply. This would translate into

108 For example, the support contract for the impact assessment looks at international partners in general, and

prospective enlargement countries will receive special attention, including exploring how to facilitate these

countries’ process of joining the ETS.

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a slight increase in administrative burden for the Commission and the European Environment

Agency (EEA). Similarly, the accession of the new Member States countries is expected to

have small impact on the Fuel Quality Directive and the Car Labelling Directive, limited to

implementation, including extended monitoring and reporting coverage, implying additional

resources in the Commission and the EEA.

Climate resilience and risk management are vital for a competitive, secure and prosperous EU.

In light of impacts of climate change, the EU and Member States need to build capacity to

adapt, strengthen just resilience and reduce vulnerability, and this is even more crucial for

enlargement countries, which are among the most vulnerable in Europe to the effects of

biodiversity loss, pollution and climate change.

The EU’s international commitments

The EU’s objective of achieving climate neutrality by 2050 as enshrined in the European

Climate Law is in line with the objectives of the Paris Agreement, to which the EU and its

Member States individually are parties. All enlargement countries are parties to the United

Nations Framework Convention on Climate Change (UNFCCC) and the Paris Agreement,

except Kosovo and have nationally determined contributions in place. Enlargement would

impact the EU international climate commitments in relation to, for example, the UNFCCC,

the Paris Agreement, and the Montreal Protocol, with apositive impact on global climate

ambition. Nevertheless, the risks described above in relation to the EU targets would also apply

in the context of meeting EU’s contributions under these agreements – e.g. achieving the

nationally determined contributions under the Paris Agreement.

As new Member States join the EU, their status in international/UN contexts would change.

The EU and its Member States are all considered developed countries under the UNFCCC and

Paris Agreement obligations, whereas most enlargement countries are considered developing

countries. For the purposes of the UNFCCC and the Paris Agreement, new EU Member States

would no longer be considered recipients of climate finance and would be expected to

contribute to climate finance as donors, including to the collective quantified goals agreed

under the Paris Agreement.

Enlargement would have positive impacts on EU’s stance in climate negotiations as the EU

would speak on behalf of a larger number of countries. Enlarging the EU would also have an

impact on its influence in UN geographic groups – especially when only four109 out of the 23

members of the UN Eastern European Group would not be EU Member States.

EU enlargement would have positive impacts on the role of the EU in international

organisations, by increasing the diversity of voices, strengthening the EU's collective position

and voting power, and expanding EU’s ability to advocate for higher sustainable regulatory

standards. An enlarged Union may have even greater leverage to push for ambitious global

standards in the International Maritime Organization (IMO) and at the International Civil

Aviation Organization (ICAO), in relation to decarbonisation and climate change.

Budgetary aspects

Under the next MFF 2028-2034, it will be important to ensure sufficient funding for EU climate

priorities in new Member States, to ensure emissions reductions across all sectors of the

economy and increased resilience and adaptation to the negative effects of climate change. This

funding would inter alia support development of renewable generation, energy efficiency

improvement actions, including resilient grid development, in particular for the

decommissioning of thermal power plants, mine closures, modernisation and decarbonisation

109 Armenia, Azerbaijan, Belarus, and Russian Federation.

69

of the industry, decarbonisation of transport, and early warnings, just transition measures and

measures to adapt and enhance resilience to climate-related hazards, such as among others

floods, heatwaves and wildfires. While these budgetary implications are further described in

other sections of this SWD, the budgetary aspects presented below refer to specific funds under

the EU Emissions Trading System.

The Innovation Fund, the Modernisation Fund, the Social Climate Fund (SCF) and in the future

the Industrial Decarbonisation Bank as proposed in the ETS review in July 2026 will also have

an important role to play. These instruments are fully funded by EU ETS 1 and, as regards

SCF, mostly by EU ETS 2 revenues. The financing of the Innovation and Social Climate Fund

from external assigned revenue to the EU budget is not changed under the Commission’s MFF

proposal. In 2028, the SCF would however be incorporated in the National and Regional

Partnership Plans.

The Innovation Fund, established by Directive 2003/87/EC, aims to support innovation in

low-carbon technologies and processes across all Member States. Applying the ETS Directive

to new Member States would result in more countries becoming eligible for the Innovation

Fund, as projects in these new Member States would become eligible. The impact on the size

of the Innovation Fund would be proportional, since its resources are defined in the ETS

Directive based on allowances. However, specific figures regarding the impact of enlargement

on the fund are unavailable. Estimating this impact is challenging due to the need to rely on

assumptions about market developments, such as carbon price and other policy factors, like the

volume of the Carbon Border Adjustment Mechanism (CBAM) allowances transferred to the

Innovation Fund.

The Modernisation Fund was also established in the ETS Directive, to support the

modernisation of energy systems and the improvement of energy efficiency in 13 lower-income

EU Member States110. The beneficiary Member States and the distribution of funds among

them are set in the ETS Directive. Thus, whether and to what extent any of the new Member

States should benefit from it would have to be decided. There are currently no estimates of the

impact of enlargement on the fund.

The new Member States will participate in the new ETS covering buildings, road transport and

additional sectors (ETS2) that will be in place in the EU as of 2028 and thus will also participate

in the Social Climate Fund (SCF), contributing to and benefiting from its funding. The timing

of accession is relevant because the SCF is established for the period 2026 to 2032. Hence, any

enlargement taking place after 2032 will not impact the SCF. However, the end date in 2032

could make SCF implementation challenging in the case of new Member States acceding to

the EU before the end of this decade as they need to ramp up the domestic systems to be able

to access the fund.

All EU Member States participate in the SCF. Hence, applying the same principle, enlargement

would increase the number of countries participating in the SCF. Since the SCF is financed by

pooling revenues from the auctioning of ETS2 allowances, which the new Member States will

also implement, the resources that they will receive will partly be generated by revenues raised

in those same countries. However, the SCF allocation methodology ensures that resources are

redistributed in favour of lower-income Member States with larger energy, transport, poverty

and population exposure challenges (based on energy and transport poverty indicators and GNI

adjustment, see methodology in Annex II of the SCF Regulation).

Finally, it is to be noted that the SCF Regulation contains a commitment for budgetisation of

110 Bulgaria, Czechia, Estonia, Greece, Croatia, Latvia, Lithuania, Hungary, Poland, Portugal, Romania, Slovenia

and Slovakia.

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the SCF in the post-2027 multiannual financial framework (MFF), in the event an ETS-based

own resource is agreed (SCF Regulation, Article 27(4)). Under the 2025 proposal of the

Commission on the new MFF for 2028-2034, it is proposed that the SCF financing will remain

as external assigned revenues from the ETS2, while the SCF will be included in a separate

chapter in the proposed National Regional and Partnership Plans. The allocation of SCF

resources to the Member States would not change.

4.1.2 Policy gaps and delivery risks

In general, EU climate policies can be extended to the new Member States without the need to

fill considerable gaps in EU legislation. This is in particular the case for EU climate legislation

that links with single market provisions, in relation to which enlargement would extend the

coverage of the applicable rules, standards and targets – CO2 standards for cars and vans and

for heavy duty vehicles, F-gas Regulation, ODS regulation, or the Fuel Quality Directive.

Nevertheless, considerable governance, administrative and technical expertise needs to be built

in the enlargement countries to implement and monitor the EU systems. These gaps in

implementation and enforcement are currently significant in enlargement countries and need

to be filled in. As national authorities of enlargement countries will play an essential role in the

implementation of certain decarbonisation policies, the development, modernisation and safe

digitalisation of their national systems is necessary for them to duly comply with regulatory

requirements.

Costs for administration are also expected to be significant and need to be taken into

consideration in the accession process for the individual enlargement countries. This is

particularly relevant for the increased monitoring and compliance costs for both EU and

enlargement countries, and the costs of joining the necessary infrastructure and permit systems,

organisations and agencies, including at international level. Enlargement countries can already

benefit from the expertise and network of the EEA, as the six Western Balkans partners,

Moldova and Ukraine are among the EEA cooperating countries. Accessing the networks and

expertise available to EEA members would greatly increase the ability of enlargement

countries to benefit from the work of the EEA and be closely linked with the EU systems.

For policies that define targets and obligations at Member State level and the EU ETS, any

gaps related to defining respective targets and obligations for new Member States will need to

be addressed at the time of accession.

Regarding EU ETS, although carbon pricing is expected to result in an increase in investments

and net employment gains in the new Member States, it will entail social and economic

repercussions for countries at an earlier stage of decarbonisation. This may require tailor-made

solutions to ensure their smooth integration upon accession and soften the impacts of the EU

high carbon price on their economy while ensuring fair distribution of benefits, opportunities

and burdens of the clean transition throughout the EU. The EU ETS solidarity mechanisms

might have to be revisited. Further, insufficient administrative capacity to implement and

enforce EU-ETS legislation in new Member States may pose an important risk for the EU

carbon market integrity.

4.1.3 Reform orientations

In view of the policy gaps and risks identified above, a set of reform orientations may be

considered. Several revisions of key EU climate legislation (and implementing legislation) are

needed to reflect the accession of new Member States.

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ETS Directive: Several changes to the ETS Directive would likely be needed. The cap (an

essential element which determines ambition and the carbon price) should be revised to cover

emissions in the new Member States. Linked to that, changes might need to be made to the

Market Stability Reserve and carbon leakage measures. Market oversight is an important aspect

to ensure the integrity of the system (i.e. anti-money laundering safeguards, and the avoidance

of market manipulation among other things). The solidarity mechanisms may need to be

reviewed, e.g. expansion of volumes available and changes to Modernisation Fund and Social

Climate Fund.

Effort Sharing Regulation (ESR): Achieving the Union’s 2030 ESR target is the result of the

sum of all national efforts, which is relevant to pre-2030 accessions. To avoid changing the

EU-wide target and renegotiating the targets of the current 27 Member States,111 a pragmatic

approach could be to exempt new Member States from joining the ESR pre-2030, and set

individual ad hoc 2030 targets for them, making it unnecessary to change the existing ESR

framework, yet ensuring that the new Member State has its own tailor-made and separate share

of effort to be made, so as to contribute towards the EU ambition.

LULUCF Regulation: As for ESR, the impact of a pre-2030 accession could be significant as

it would require setting targets for new Member States, contributing to the EU land-based net

carbon removals target. The same approach as for ESR above could be considered, that is,

setting parallel and ad hoc 2030 targets for new Member States that join the EU before 2030.

Governance Regulation: As Contracting Parties to the Energy Community, enlargement

countries already implement an adapted version of the regulation. For the purposes of the 2030

framework, to ensure compliance with EU planning and reporting obligations, the provisions

of the Governance Regulation may have to be temporarily modulated in a tailor-made manner

for new Member States through the Accession Treaty (e.g. by setting an ad hoc deadline by

which the new Member State will have to submit its integrated National energy and climate

plan following accession). This is particularly important due to the interlinkage of the

Governance Regulation with other EU Regulations, notably LULUCF, ESR, the Renewable

Energy Directive and the Energy Efficiency Directive.

Fluorinated greenhouse gases Regulation: Recalculation of the EU baseline and registration

of a limited number of undertakings will be required (a technical procedure that does not entail

policy changes). Enhanced cooperation with customs would be needed to ensure effective

controls at the borders.

As the details of post-2030 EU climate policy framework are yet to be determined for EU-

27, with a review of key building blocks of climate legislation due in 2026, climate policy in

the Union should strive to consider, to the extent possible, the perspective of an enlarged Union

and the resulting re-distribution of efforts. The 2024-2029 priorities of the Commission

announced a new Clean Industrial Deal, with concrete actions to turn decarbonisation into a

driver of growth for European industries. The Clean Industrial Deal focuses mainly on two

closely linked sectors: energy-intensive industries and clean tech, with circularity a key

element. It states that the gradual integration of enlargement countries in the single market is

one horizontal enabler necessary for a competitive economy. The enlargement aspects will

need to be considered in detail in the analytical preparatory work for the several strands of

policies announced as part of the Clean Industrial Deal.

111 Also, the inclusion of a new Member State would require identification which installations would be subject

to the ETS1 in such countries, determining their new Member States ESR emissions in the ESR sectors in 2005,

and setting the annual emission allocations of the new Member States for the years up to 2030.

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4.2 Energy policy

The European Union's energy policy is centred around ensuring a secure, affordable, efficient

and clean sustainable energy supply for people and businesses, as stressed in the recent Action

Plan for Affordable Energy.112 Key priorities include investing in clean energy, improving

energy efficiency, enhancing system flexibility, reducing dependency on fossil fuels and

diversifying energy sources to reduce one-sided dependency on specific suppliers, notably

Russian fossil fuels and nuclear fuels. These objectives align with the EU's objective to achieve

climate neutrality by 2050. Nuclear power will continue providing low-carbon energy in the

EU in the Member States that choose to use it, complementing renewable energy. As regards

renewables, the revised Renewable Energy Directive raises the EU's binding renewable target

for 2030 to a minimum of 42.5% share of renewables in the energy mix, with the aspiration to

reach 45%. In the nuclear sector, in line with the REPowerEU Plan, the EU Member States

are diversifying their nuclear fuel value chains to avoid dependences on any single supplier.

Ukraine has diversified its nuclear fuel value chain away from Russia and is receiving its

nuclear fuel from an alternative supplier. Development of domestic value chains is key also for

the EU and is ongoing for advanced nuclear technologies such as small modular reactors, for

example through the Strategy for the development and deployment of Small Modular Reactors

(SMRs) in Europe113 and the European Industrial Alliance on Small Modular Reactors.

The European Union has also identified faster electrification as a priority, as set out in the

Electrification Action Plan114. It includes an indicative target to raise electrification to 46%

by 2040, which will be assessed in the context of the post-2030 Energy Union package.

Following up on the Action Plan for Affordable Energy, work on EU-level tripartite

agreements has also started. These agreements bring relevant actors of a specific energy sector

around a set of non-binding commitments to create an investment climate that supports cost-

effective energy production, reliable energy supply, and long-term economic growth for

stakeholders involved. The first one was signed in June 2026 to support the development of

energy storage in the long-term115.

For countries aspiring to join the EU, aligning with EU energy policies is crucial for integration,

decarbonisation and energy security. The Energy Community plays a pivotal role in this

process. By adopting EU energy legislation, contracting parties of the Energy Community

commit to creating a stable regulatory framework, attracting investment, enhancing energy

security and accelerating decarbonisation. This framework also gives them the opportunity to

join the EU electricity markets before accession (e.g. the Electricity Integration Package

enables market coupling with the EU). In addition, the Contracting Parties of the Energy

Community also progressively apply the EU acquis on security of supply. This helps ensure

a comparable level of preparedness, risk assessment and crisis response to that of EU Member

States, thereby reducing security-of-supply risks in the enlargement region and lowering the

likelihood of spillover or domino effects on the EU’s own security of supply. Additionally,

alignment of enlargement countries’ legislation with the Euratom acquis has started under the

respective Stabilisation and/or Association Agreements and is advancing in the framework of

accession negotiations. This facilitates the accession process and contributes to a more

integrated and resilient European energy market.

112 COM (2025) 79. 113 COM (2026) 117. 114 COM (2026) 595. 115 https://energy.ec.europa.eu/strategy/affordable-energy/eu-level-tripartite-agreements_en

73

Enlargement is an opportunity for the internal energy market. A larger and integrated energy

system holds benefits for all including improved systemic energy efficiency, increased

competitive generation capacity and cost-effective flexibility in the system. Moreover, a larger

EU can improve the functioning of the single market and reduce dependence on external energy

sources, given the renewable energy potential of the enlargement countries. Enlargement also

promotes cross-border infrastructure trade and energy flows, strengthening European energy

security through increased interconnectivity and sustainability across a wider geographical

area. The EU energy system would benefit from increased availability of low-carbon and low-

marginal-cost energy, contributing both to affordability, decarbonisation and resilience of the

EU energy system.As a result of increased scale, an enlarged EU could bring increased

opportunities to manufacture, within the single market, net-zero technologies and their

components, reducing dependencies.

The natural resources in enlargement countries, skilled workforce and academic systems can

help the clean energy transition and, in the long run, also strengthen the EU’s economic

resilience and the competitiveness of EU companies in the supply chains. Moreover, with

enlargement, the EU will gain in size and influence with new members fully benefiting from

opportunities of demand aggregationand joint purchasing of natural gas and the mechanism to

support the market development of hydrogen. At the same time, with enlargement, new

challenges would arise related to the phase-out of dependencies on fossil fuels, particularly

coal, as well as Russian gas.

Preparedness in enlargement countries will be key for ensuring the necessary level playing

field in the EU single market and to making progress towards the decarbonisation of the EU

energy sector, via:

• adequate implementation and effective enforcement of legislation,

• independence and efficiency of regulatory authorities, and

• good governance of and cooperation between all relevant authorities to prevent fraud and

corruption in line with the EU energy, climate and competition policy and legislation.

Improved governance of the energy sector and the development of competitive energy markets

in enlargement countries are necessary for improving liquidity of energy markets. This will

enable new market entrants, clean technologies and know-how and attract the necessary

investments.

4.2.1 Impact of enlargement on EU energy policy and policy gaps

Energy-related emission reduction targets policies

Enlargement is expected to have a considerable impact on the achievement of energy targets

related to the 2030 and 2040 climate targets116. The enlargement countries (their renewables

share and potential, and their energy efficiency share) are not currently included in the EU’s

2030 targets. However, within the Energy Community framework they have set their own

national 2030 targets for renewables and energy efficiency. The enlargement countries have

largely implemented the ‘Clean energy package’ from 2018. The European Commission did

not take enlargement countries into account in its impact assessment on the 2040 climate

targets.

116 For the 2030 emission reduction targets related to energy, the current EU goal is to achieve a 42.5% share of

renewable energy in final energy consumption, supported by national contributions of varying ambition levels.

For the energy efficiency target, it is binding for EU countries to collectively ensure an 11.7% reduction in energy

consumption by 2030.

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For energy efficiency, the latest recastof the Energy Efficiency Directive(Directive (EU)

2023/1791) has not yet been incorporated into the Energy Community acquis (it will ideally

be included in the Energy Community framework as of 2026/2027) nor into the enlargement

countries’ legislative frameworks. A legislative proposal for a new post-2030 energy

efficiency framework is currently being prepared. Depending on the progress of enlargement,

possible 2040 EU energy efficiency targets could potentially encompass new Member States.

For renewable energy, the EU target is underpinned by national contributions, set at varying

levels. If the new Member States were to contribute to the overall EU target, this would,

depending on the ambition of the contribution, require of them either more or less efforts in

terms of market reforms, creating a conducive environment for renewable investment, and

speeding up of permitting procedures and grid extension and modernisation. This is also valid

for the energy efficiency targets. A proposal for the post-2030 renewable energy framework

is currently being prepared. Depending on the progress of enlargement, potential 2040 EU

renewable energy targets could potentially encompass new Member States.

Impacts on the internal market for electricity and gas

The impact of enlargement on electricity and gas market policies is projected to be significant.

On electricity markets, enlargement would necessitate changes of the operational systems,

such as the market coupling algorithm and allocation, requiring further developments to handle

the additional complexity. It also necessitates a thorough upfront check on transposition and

implementation of EU laws and a strong governance framework, as any issue arising within

one Nominated Electricity Market Operator or a Transmission System Operator (TSO) could

impact significantly the outcome of the market coupling for the EU as a whole. The ability of

enlargement countries to cooperate between each other will also be key, as being part of the

EU integrated electricity market requires TSOs to cooperate with each other to ensure the safety

of operations. In addition, the Commission would need to assess whether State aid support,

including capacity mechanisms of enlargement countries, complies with the EU’s acquis, do

not result in market distortions and constitute undue State aid. Physical electricity flows and

electricity trades might change because of enlargement, whilst key principles such as no

discrimination between internal and external flows would remain.

On the security of electricity and gas supply, there could be impact on regional and cross-

border cooperation, and on new or enlarged risk groups also in light of decarbonisation and EU

efforts to phase out Russian fossil fuels, which some enlargement countries still rely on. The

Commission plans to revise the EU energy security framework considering gas, electricity

and oil security of supply, including the gas storage measures. Therefore, in the event of a

revision, a new assessment of the related impact of the future legislative framework will need

to be made in due course.

Euratom acquis

The Euratom acquis will apply to new Member States irrespective of their energy mix (with a

graded approach applied depending on country’s nuclear energy profile). Of all enlargement

countries, the most important impact on Euratom is expected from the accession of Ukraine, a

country with a large civil nuclear industry (145 operating reactors, with plans to build

additional ones). The main challenges stemming from the accession of Ukraine are:

• Ensuring the highest levels of nuclear safety and protection from radiations during and

after the war, including at the currently Russian occupied Zaporizhzhia Nuclear Power

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Plant (‘NPP’ and the New Safe Confinement at the Chornobyl NPP117. It still needs to be

assessed if and how the existing financial support to enlargement countries’ nuclear sector

(such as Euratom loans, Instrument for Nuclear Safety Cooperation, Foreign Policy

Instruments) will be continued upon their accession.

• Existing assistance programmes for decommissioning are not fit to address the legacy of

the Chornobyl disaster and war consequences118.

• The accession of Ukraine would result in a substantial increase in volume and number of

activities required under the Euratom Treaty (Chapter 7 “Safeguards”) for the Commission

to be able to monitor that nuclear materials are not diverted from their intended (civil) uses

and that provisions relating to supply and safeguarding obligations stemming from

international agreements are complied with. Amongst others, this would imply an increase

in the number of safeguard activities, such as nuclear accountancy verifications, safeguards

inspections, installation and maintenance of safeguards-specific equipment and operational

technologies and reporting activities vis-à-vis the International Atomic Energy Agency as

well as third countries in the remit of nuclear cooperation agreements with third

countries119.

• Ukraine has in place nuclear cooperation agreements with certain third countries. In line

with the Euratom Treaty, Ukraine will be required to undertake jointly with the

Commission the necessary negotiations with these countries in order to ensure that the

rights and obligations stemming from the latter’s bilateral nuclear cooperation agreements

shall as far as possible be assumed by the Community. This might involve extensive

additional legal checks and negotiations with the third countries involved.

Furthermore, Ukraine will have to comply with the Euratom Treaty supply requirements set

out in Chapter 6. In addition to acceding to the Euratom Supply Agency (ESA) - which will

involve the transfer of a capital share and the appointment of members to ESA’s Advisory

Committee - Ukraine must also adhere to the contractual provisions and the security-of-supply

policy and diversification measures including of any future new-build projects, such as the

proposed new units at the Khmelnytskyi nuclear power plant, also in accordance with the

European Energy Security Strategy120.

In addition, in accordance with the Euratom Treaty, all enlargement countries' agreements or

contracts with third parties notified before the prescribed deadline will have to be assessed for

117 Numerous events continue to occur with the Russian military aggression, such as shelling, air attacks,

difficulties with staffing levels and working conditions and losses of off-site power supply, which have impacted

nuclear safety at the various NPPs in the country. At the end of the hostilities, the EU contribution to restore safe

conditions for Ukraine’s power generation, including nuclear, needed for the country’s recovery should be highly

visible. Priority should be given to the full restoration of offsite power and cooling water at the ZNPP as a safety-

critical requirement. The limits imposed by these issues alone could mean that (re-)commissioning and operation

remain unlikely for several years, whilst restoration and refurbishment are undertaken, alongside demilitarisation,

demining and the preparation of a comprehensive safety assessment, ideally subject to international peer review.

Due to a Russian drone attack, the New Safe Confinement (NSC) was damaged. A structured and timely repair

programme is required to restore the NSC main functions, which are to protect the environment from release of

radiation and allow for the safe dismantling and decommissioning of the destroyed Chornobyl reactor. 118 Currently funding is provided via the European Instrument for International Nuclear Safety Cooperation

(INSC). 119 Sufficient Euratom Safeguards as well as respective technology will be needed and this should be taken into

consideration in the discussions on resources and budget allocations. 120 COM (2014) 330.

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possible grandfathering. Trilateral negotiations121 will be also needed, as appropriate, to ensure

the accession of the new Member States to the Comprehensive Safeguards Agreement

INFCIRC/193122 and the Additional Protocol (INFCIRC/193/Add.8). The impact on EU policy

of the accession of enlargement countries other than Ukraine would be significantly smaller,

since they are non-nuclear power countries (except for Türkiye, which is expected to start

operating an NPP – a 99.2% investment by Russia’s Rosatom – on its territory in the near future

and has announced plans to expand its nuclear fleet) and mostly generate smaller amounts of

radioactive waste from industry, medicine and research activities (Serbia has two old research

reactors). The European Commission should be ready to assist the countries with such small

inventories in addressing the issues related to the lack of trained staff and financial resources.

Trans-European Networks, Infrastructure

The current geopolitical situation has heightened the need for strengthening cross-border

energy infrastructure. As the EU is moving away from Russian gas, and fossil fuels in general,

and has set itself ambitious decarbonisation targets, significant investments are needed in

energy infrastructure to integrate growing amounts of renewable energy, support electrification

and enable energy to flow efficiently.

Europe’s energy networks are confronted with insufficient grid capacity, as well as challenges

linked to infrastructure planning, delays in project implementation, and security. In response,

the Commission presented the European Grids Package123 on 10 December 2025, consisting

of a proposal to revise the Regulation on guidelines for trans-European energy infrastructure

(TEN-E Regulation) and a proposal to accelerate and streamline permit granting procedures

for grids, renewables, storage and recharging stations projects, by amending the Renewable

Energy Directive, the Electricity Market Design and the Gas Directive.

With enlargement, additional capacities will be needed for the implementation of TEN-E and

the (current) Connecting Europe Facility, energy strand.

Cross-border energy interconnections are crucial to developing a resilient, interconnected

and secure energy system and an integrated energy market within the EU and beyond and to

achieve climate neutrality by 2050.

The accession of new countries will likely require the assessment of a significant increase in

cross border needs across all infrastructure categories under the TEN-E process124. Currently,

certain projects with candidate countries are already eligible under TEN-E, however, they are

limited to certain infrastructure categories and mainly assessed taking into consideration the

121 Between the European Commission (on behalf of Euratom), Ukraine and the International Atomic Energy

Agency (IAEA). 122 OJ L 51, 22.2.1978, p.1. 123 COM (2025) 1005. 124 Concerning hydrogen, infrastructure needs of candidate countries are particularly difficult to assess given the

early stage of the hydrogen market development across Europe. However, in Ukraine, Moldova, Bosnia and

Herzegovina, Serbia and North Macedonia, hydrogen could play a role in the decarbonisation and phase out of

Russian fossil energy imports. To enable the flow of hydrogen from production areas abundant with renewable

energy sources towards consumption centres, cross-border infrastructure will be needed, including storage. Given

its renewable potential and existing natural gas infrastructure that carries potential for repurposing, Ukraine is

expected to become one of the major hydrogen suppliers to the EU, as identified inter alia by the second PCI/PMI

list.

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benefits to the EU solely125. Data availability from enlargement countries will be critical in

ensuring smooth implementation of the TEN-E.

In addition to the need for additional support, there is currently a gap in the qualifying criteria

for Cross-Border Renewable Energy projects. The Renewable Energy Directive (‘RED’) laid

down requirements to cooperation with third countries, such as the presence of a physical link

between the participating countries and a scope limited to electricity projects.

Budgetary aspects

Overall, financial support needs in the energy sector due to enlargement are expected to

increase significantly. This is largely attributable to the remaining gaps in the legislative and

regulatory frameworks of enlargement countries – despite significant progress in alignment

thanks notably to the Energy Community - as well as insufficiently developed infrastructure,

coupled with their limited administrative capacity to implement and enforce EU energy

legislation, the state of development of renewable generation and their level of energy

efficiency improvement actions. Upon accession, enlargement countries would become

eligible for NRPP funding as Member States, with their allocations determined according to

the applicable allocation methodology and parameters, including those relating to economic,

social and territorial cohesion and less-developed regions. Support could also be provided by

dedicated financial instruments for cross-border infrastructure projects. Funding energy in the

context of future EU enlargement may present certain challenges.

It is expected that once the enlargement countries join the EU, significantly larger financial

resources could be required to adequately address all energy infrastructure needs identified

within the TEN-E process, supporting the development and integration of the energy market

across the expanding EU. Higher number of projects applying for EU financial support under

the energy strand of the Connecting Europe Facility (CEF-E) would have a strong budgetary

impact on the instrument.

The transposition and implementation of the large EU body of energy and Euratom rules

would require significant resources and administrative capacity in the enlargement countries,

including for example for market surveillance in the implementation of ecodesign and energy

labelling rules. However, even for legislation that is already ambitious for the EU-27 (e.g. the

Energy Performance of Buildings Directive) enlargement would not trigger the need to

revise EU rules and policies. Support by the EU level (and the Commission in particular)

might be needed in the implementation phase not least due to the limited overall level of

consumer empowerment and the insufficient development and transparency of the retail

market.

Resource needs within the Commission would be triggered by the larger number of Member

States, the need for extended monitoring and enforcement and increased participation in

existing networks and groups. Regulatory agencies will face increased workloads, risking

delays or suspension of core tasks if further rationalisation is not realistic. In particular, the

impact on the resources of the EU Agency for the Cooperation of Energy Regulators (ACER)

could be significant for areas such as REMIT Regulation on Wholesale Energy Market Integrity

125 Given the economic and strategic importance of the integration of the energy markets between the EU and

countries of the EEA and the Energy Community, the proposal for a revised TEN-E Regulation (COM/2025/1006)

presented under the Grids Package proposed to take into account the benefits and costs brought about by a cross-

border infrastructure to the third country if it concerns the Energy Community or the EEA during the assessment

of PMI candidate projects. This means that benefits of cross-border projects accruing to the Union as well as to

the EEA country or Energy Community Contracting Party are proposed to be taken into account.

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and Transparency and other tasks, including some currently performed by the Energy

Community.

It is important to note that enlargement energy projects, be it infrastructure, energy efficiency

or energy performance of buildings or energy security-related upgrades, often involve high

upfront costs, customised solutions and a lack of standardisation. Thus, traditional financing

models may fall short, requiring more complex approaches to be developed such as public-

private partnerships (PPPs) and crowdfunding. Investors' risk aversion and regulatory

uncertainties, coupled with monetary risks such as currency volatility and inflation, further

complicate financing.

4.2.2. Reform orientations

In view of the delivery gaps and risks identified above, a set of reform orientations can be

considered:

• Energy-related climate targets

To facilitate the accession of candidate countries before 2030 while preserving the Union´s

collective targets renewable energy and energy efficiency targets for the remainder of the 2030

framework new Member States could be exempted from contributing to it while compelled to

achieve ad hoc national targets that would be provided for in the Accession Treaty on the basis

of the levels already committed into their NECP and in line with the 2030 Energy Community

framework. Such ad hoc targets would strive to prepare the new Member State’s integration

into the Union’s post 2030-framework.

On the 2040 horizon, as part of the reflections on the 2040 net greenhouse gas emission

reduction framework and as a result of having amended the European Climate Law to set a

legally binding 2040 target of 90% reduction in net GHG emissions compared to 1990 levels,

preparatory modelling and if relevant the underpinning Impact Assessment should encompass

the impact of the possible accession of enlargement countries. In addition, the accession of new

Member States will require the Commission to include those countries to the estimates on

investment needs to reach the headline targets, on both the supply and demand side. The

investment gap will also have to be updated accordingly.

Recalibrating the targets upon accession might also be needed. New Member States will have

to reflect this in their NECPs, to be submitted in due time pursuant to the Governance

Regulation.

• Security of supply

The EU may need to provide technical assistance to the enlargement countries to help them

to integrate the EU acquis. In particular, this would entail supporting the countries with their

Gas Risk Assessments, Preventive Action Plans and Emergency Plans. Such assistance has

already started with Ukraine and Moldova, where the Commission has helped these countries

with the modelling of their Gas Risk Assessment.

The EU, supported by the Energy Community and in collaboration with the competent

authorities of the enlargement countries will have to monitor the security of supply situation in

these countries. Such monitoring is already in place, to some extent, for countries such as

Moldova and Ukraine. As enlargement could increase pressure on imports and transit

infrastructure, it might be necessary to ensure that these countries’ gas infrastructure is

sufficiently interconnected to the EU gas system not to create bottlenecks.

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• Electricity and gas markets

The EU would need to ensure robust monitoring even before enlargement, under the Energy

Community framework. The Commission, supported by the Energy Community Secretariat

will need to assess the implementation of the existing legal framework and the progress in

fulfilling regulatory and competition conditions. After enlargement, given the importance of

the internal energy market, the Commission will need to ensure close monitoring of compliance

with EU acquis by the new Member States and address any issues, if need be and as applicable,

through pre-infringement administrative dialogue and infringement action. This may require

additional resources in the Commission.

It will also be essential to provide technical assistance to new Member States to develop and

implement the relevant regulatory framework and ensure their active participation in the

internal market, including mainstreaming of private operators into the existing structures of the

gas and electricity markets and, in the future, for hydrogen. This will entail the participation of

enlargement countries as observers in the existing platforms and protocols for the cross-border

operation of the electricity and gas infrastructure. On electricity, the market coupling algorithm

providing the day-ahead and intraday trading schedules might need to be strengthened to handle

this additional complexity.

• Trans-European Networks

Technical assistance and capacity building for implementing the TEN-E Regulation

throughout the accession process and after, would enable enlargement countries in

implementing the TEN-E Regulation. This will help bridge the existing gaps in data

availability, quality, skills and exchange and ensure that cross-sectoral infrastructure planning

across future EU Member States (both current and new ones) can take place on an equal

footing. Regarding the scope and governance of the TEN-E process, the accession of new

countries to the EU may require adaptations to the TEN-E Regulation, such as adjustments to

the composition of energy infrastructure priority corridors and their memberships.

• Euratom and nuclear energy

In some areas such as radioactive waste and spent fuel management, and for specific countries,

a transitional period may be necessary. The EU might need to assist Ukraine with funding

for its post-war recovery. It may also need to assist other enlargement countries (not producing

nuclear energy) in addressing skills gap the nuclear sector, as concerns nuclear safety/ security/

safeguards, and in establishing adequate infrastructure to effectively address issues related to

radioactive waste and its management and comply with requirements in this field.

4.3 Mobility and transport

Reliable transport infrastructure links will help bring economic benefits for both the EU and

enlargement countries, even before accession. These benefits will stem from facilitating

stronger and smoother economic exchanges. As already demonstrated in response to Russia’s

war of aggression against Ukraine, well-functioning transport links are critical to ensure

increased economic exchanges benefiting both the EU and enlargement countries, and their

gradual integration in the EU single market 126 . In the context of enlargement, the future

Member States will bring new and diverse realities, such as in relation to the organisation,

capacity and operation of mobility systems.

126 More information: https://transport.ec.europa.eu/ukraine/eu-ukraine-solidarity-lanes_en.

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4.3.1 Impact of enlargement on mobility and transport policy

The EU acquis on mobility and transport does not need to be modified substantially to be

enlargement-ready, as the policies would apply automatically to new Member States and/or

additional transport operators. Therefore, overall, the EU mobility and transport policy

framework is considered fit for enlargement. However, enlargement is expected to have a

significant impact on the support mechanisms to implement these policies, such as funding

streams for building and upgrading infrastructure and for administrative capacity. Special

attention needs to be paid to coordinated implementation of cross-border sections between EU

Member States and enlargement countries, like it has been ensured through the Connecting

Europe Facility (CEF) to date.

Beyond the regulatory framework, the main impact can be expected on EU market operations

and operators in the road and rail transport sectors, where current EU operators might be

challenged by new entrants from new Member States. These new entrants might continue to

benefit from a more preferential treatment in their home markets, especially if transition

periods are negotiated as part of the accession process.

TEN-T policy and transport infrastructure

The EU’s transport infrastructure planning policy is based on Regulation (EU) 2024/1679 (the

‘TEN-T Regulation’), setting out the network and the European Transport Corridors, and

the requirements that the infrastructure needs to meet by 2030, 2040, and 2050. Several

European Transport Corridors were extended to the Westerns Balkans, Moldova and Ukraine,

thus they are already part of the governance system of the trans-European Transport Network

(TEN-T).

By signing high-level agreements, Ukraine, Moldova and Western Balkans committed

themselves to implementing indicative TEN-T network on their territories. However, even in

case of full and timely implementation of ongoing and mature projects supported through

Connecting Europe Facility, it is estimated that full compliance with the 2030 deadline for

completing the ‘Core Network’127 will not be achieved, given the current state of several

infrastructure components and the substantial investments needed to reach EU standards.

Overall, implementation of TEN-T requirements differs between countries. For example,

Moldova’s and Albania’s rail electrification rates are at 0%, while in Bosnia and Herzegovina

and Montenegro they are at 70-90%. As Ukraine and Moldova use the wide gauge for their rail

network, it would require massive investment to change it to the standard European gauge and

to ensure interoperability with the EU, estimated at around EUR 15 billion128 in total, including

approximately EUR 3,5 billion for priority cross-border corridors in the next financial period.

The road network in the enlargement countries faces maintenance challenges and requires

fundamental upgrades and redesign of the network.

In its EU Black Sea Strategy, the Commission has announced that transport corridors will be

part of the future Connectivity Agenda linking Europe with Central Asia through the South

Caucasus. This Agenda will be implemented in line with the EU’s trans-European transport

network Regulation, and through partnerships with participating countries and regions.

Military mobility

127 The TEN-T core network includes the most important connections between major cities and nodes and must

be completed by 2030. The extended core network needs to be completed ten years later, in 2040. The

comprehensive network connects all regions of the EU to the core network and needs to be completed by 2050. 128 Strategy for the EU integration of the Ukrainian and Moldovan rail systems, July 2023.

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Enlargement can significantly influence the military mobility plans of the EU, considering the

current geo-political situation. The EU military network and priority military mobility corridors

spans across the EU territory, the relevant Council Decisions would have to be revised to cover

new Member States upon enlargement. As opposed to the TEN-T network and European

Transport Corridors, there is no indicative military network or priority military mobility

corridors in the enlargement countries. The EU has already identified improving military

mobility and dual use infrastructure in the Black Sea region as a key priority for the EU’s

security and for the security and reconstruction of Ukraine. To this end, the European Transport

Corridors expanding to neighbouring third countries shall also ideally be developed and

upgraded for a dual use, i.e. for a civilian and military use. The Black Sea Strategy points to

the need to urgently upgrade the dual use transport infrastructure along the existing military

mobility network and to the importance of EU Black Sea and EU Danube ports of embarkation

and debarkation, as well as the connecting rail and road infrastructure.

The Commission has presented in November 2025 a military mobility package aiming to

create an EU-wide military mobility area by 2027 bringing the EU one step closer towards a

‘Military Schengen’. Part of the package is a proposal for a Regulation on military mobility

introducing EU level harmonised rules and clear procedures for cross-border military

movements. In the interest of smooth military movements towards and from their territories,

enlargement countries should prepare to align their legislation to these upcoming EU rules129.

Early operational cooperation should be envisaged to ensure that national legislative

frameworks and dual-use transport infrastructure planning are fully aligned with upcoming EU

standards, particularly along critical corridors in the Black Sea region. A crucial element of

security of the eastern border regions is the integration of the railway systems of Ukraine and

Moldova into the EU network by deploying the European standard gauge, which is an

important enabler of military mobility and economic resilience.

Sustainable, smart and inclusive mobility

Overall, enlargement would have limited potential impact on the EU’s sustainable and smart

mobility legal framework (Alternative Fuels Infrastructure Regulation (AFIR), Clean

Vehicles Directive, Intelligent Transport Systems Directive)130. However, implementation of

the legislation in the new Members States can be challenging considering the relatively low

current level of implementation of sustainable and smart mobility and their limited capacity

and resources, triggering also the need for extensive and accurate monitoring by the

Commission.

The provisions on transport decarbonisation in the European Green Deal, specifically in the

Fit for 55 legislative package, are considered fit for enlargement, as they apply directly to

economic operators. This is relevant to the targets set in ReFuelEU Aviation and FuelEU

Maritime Regulations (e.g. share of sustainable aviation fuels that each operator needs to use

in 2030 and beyond; the greenhouse gas intensity of the marine fuels used in shipping). It will

generally benefit existing EU operators when their competitors from new Member States apply

EU rules as this will ensure a fully level playing field.

129 The proposal for a Regulation on Military Mobility provides that the Military Mobility Transport Group may

invite, where relevant, in accordance with its rules of procedure and with due respect to the security and defence

interests of the Union and its Member States, Ukraine, Moldova and countries of European Economic Area to

attend meetings as observers. 130 In particular, the requirements for refuelling and recharging infrastructure under AFIR can be applied directly.

While new Member States could negotiate the implementation pace of AFIR as part of accession negotiations, no

impact is expected either on existing EU legislation including EU targets, nor for current Member States in terms

of alternative fuels recharging and refuelling infrastructure that they would need to deploy on their territory.

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In multimodal transport, the new CountEmissions EU Regulation131 provides a harmonised

framework to help transport and hub entities quantify GHG emissions of passenger and freight

operations. Early uptake in enlargement countries will help build interoperable reporting

capacity in transport chains ahead of accession.

More substantial impacts could be felt in the availability of resources to meet additional

demand (e.g. for alternative fuels and associated infrastructure). The aviation and maritime

fleets of the enlargement countries are relatively small compared to the fleets already operating

in the EU. Some already need to comply with existing EU rules in so far as they operate to/from

EU ports/airports. Enlargement would extend the geographical scope of the rules, and thus

requirements will potentially affect more operators/routes. When it comes to alternative fuels

recharging and refueling infrastructure, the massive need for investments in enlargement

countries could create further opportunities for European companies. At the same time,

infrastructure being a critical asset for the EU, careful considerations should be given to

investments by third country operators, in line with applicable EU rules.

The enlargement would also extend the area of application of the EU passenger rights acquis,

in all modes of transport, including for persons with reduced mobility and persons with

disabilities, benefiting both EU and accession countries’ citizens.

EU policies on land transport

Expected impact on the land transport acquis132 is limited because overall, the existing legal

framework is sufficiently robust to accommodate new Member States without specific

adjustments. However, effects would be felt in terms of financial and human resources at EU

level (Commission and European Railway Agency, ERA) to support implementation of the EU

rules and for supporting national administrations and enforcement follow-up actions (cfr.

budgetary impacts). Potential competitive pressure from new market entrants from new

countries could occur in the road and, to a lesser extent, in the rail markets. To ensure a smooth

transition, the design of time-bound specific transitional arrangements for market access may

be considered, balancing needs for progressive market integration, reciprocity and the stability

of the internal transport market.

For road and rail transport, the Western Balkan countries have committed to adopting the EU

acquis in full within the Transport Community Treaty (except for road market access rules).

As a result, these rules are directly applicable in new Member States, with no specific needs

for adaptation.

This includes the recently adopted Regulation on the use of railway infrastructure capacity133

and, once adopted, the Passenger Package proposed by the Commission, encompassing

initiatives on rail ticketing and on multimodal booking, as well as the amendment of the rail

passenger rights Regulation.

On road transport, many enlargement countries already apply some EU rules, by virtue of their

participation in international agreements, such as the AETR (European Agreement concerning

the work of crews of vehicles engaged in international road transport). At the same time,

enlargement could increase the need for enforcement efforts by existing Member States

131 Regulation (EU) 2026/1030 of the European Parliament and of the Council of 29 April 2026 on the greenhouse

gas emissions accounting of transport services. 132 Rules on rail market organisations (and future rules on railway infrastructure capacity); rail safety; road

transport (rules for market access for freight and passenger transport, social rules, road charging, etc). 133 Regulation (EU) 2026/1184 of the European Parliament and of the Council of 20 May 2026 on the use of

railway infrastructure capacity in the single European railway area, amending Directive 2012/34/EU and repealing

Regulation (EU) No 913/2010.

83

(checking compliance with applicable rules by individual new operators) and by the

Commission (e.g. management of the posting portal handling notifications on posting of

drivers). Notably, the EU concluded Road Transport Agreements with Ukraine and Moldova,

which have been renewed, and which have significantly facilitated freight transport by road

between the parties to the agreement.

All enlargement countries closely cooperate with the EU on road safety. However, they are

significantly lagging compared to the EU standards and do not have fully comparable

organisational capacities in place. EU support, starting with the European and Eastern

Partnership and Western Balkans Road Safety Observatories, will be required to help these

countries improve road safety, as they generally record higher road fatalities per million

inhabitants than all current EU Member States. Updated EU rules on driving licences134 were

formally adopted in October 2025. This major update introduces several key changes to road

safety and licensing, including digital licences and accompanied driving, and must be fully

applied by November 2029.

Aviation policy

To a very large extent, the current policy framework is considered fit for enlargement.

However, enlargement would have a significant impact on the resources necessary both within

the Commission, the European Union Aviation Safety Agency (EASA) and support

mechanisms for new Member States, which will need to properly apply and enforce the legal

framework. Some of the enlargement countries have already observer status at EASA, and

additional resources will be required for EASA to carry out periodic inspections in new

Member States to ensure the full implementation of the EU aviation safety acquis under its

competence and by national authorities. In 2024, the reformed Single European Sky regulation

introduced ownership and control rules to entities providing air navigation services that have

to be carefully assessed in the view of enlargement. The economic performance and charging

scheme also requires additional resources as the Commission must approve a new performance

plan for each Member State.

Market integration based on EU or EU-inspired rules has started pursuant to existing EU air

services agreements with all countries concerned. In particular, the European Common

Aviation Area Agreement, which covers six western Balkan countries, provides for regulatory

convergence of those countries with the EU aviation legislation in all areas and this process

has already been underway for many years. Similar regulatory convergence processes are

ongoing under the Common Aviation Area Agreements between the EU and Moldova and

Ukraine. Some minor adaptations will be required on market organisation and oversight, and

in international aviation agreements. New Member States will have to become parties to the

existing EU-level agreements with third countries.

Maritime and inland waterways transport policy

In terms of safety, almost all the maritime enlargement countries (except Albania and

Moldova) are already part of the institutional structures, such as the International Maritime

Organization and the Paris and Black Sea Memoranda of Understanding (MoU) for port State

control and therefore apply global-level safety rules, which form the basis of the EU maritime

safety acquis.

134 Directive (EU) 2025/2205 of the European Parliament and of the Council of 22 October 2025 on driving

licenses, amending Regulation (EU) 2018/1724 of the European Parliament and of the Council and Directive (EU)

2022/2561 of the European Parliament and of the Council, and repealing Directive 2006/126/EC of the European

Parliament and of the Council and Commission Regulation (EU) No 383/2012.

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The legal framework is considered largely fit for enlargement.

While ships under the Ukrainian and Moldovan flag have recently been removed from the so-

called ‘blacklist’ of the Paris MoU, significant further action will have to be taken by both

maritime administrations to build on this progress. This will entail significant additional efforts

from Commission and the European Maritime Safety Agency (EMSA) to support these

administrations in their task of improving capacity and safety standards. Minimal changes

would be needed on maritime transport policies. In relation to inland waterways, some

enlargement countries are members of the International River Commissions (Serbia, Bosnia

and Herzegovina) and are already participating (Serbia, Ukraine) as observers to CESNI

working groups. Alignment with the EU acquis (technical standards for barges/ships and

certificates for boat masters and crew) could be done without major adaptations.

Institutional aspects

Enlargement could impact the speed of coordination of the EU positions in international

organisations (e.g. International Civil Aviation Organization, International Maritime

Organization, Intergovernmental Organisation for International Carriage by Rail), where in

some cases consensus is required in Council (and unanimity in case of Article 218(9)

procedures). Sometimes this is already difficult to achieve among the current Member States

due to different interests. The process could become more complex with a larger number of

Member States. In addition, Council decision-making on military mobility and dual use of

infrastructure aspects can fall under unanimity requirements and enlargement could slow down

decision-making.

Budgetary aspects

Enlargement is expected to significantly impact EU support for infrastructure funding.

Continued EU level financing for key transport infrastructure projects (along the TEN-T)

would be beneficial to the current and future Member States. Through the Connecting Europe

Facility (CEF) - Transport, the EU already supports projects that contribute to the

development of the trans-European transport network, i.e. border crossing areas between the

Member States and enlargement countries, mainly in Ukraine and Moldova, as well as

integration of their rail networks with the one of the EU. Such support is complemented by the

Ukraine Facility and the Reform and Growth Facility for the Republic of Moldova. In the

Western Balkans, significant EU funding for transport infrastructure has been allocated through

the Western Balkans Investment Framework, most recently with additional funds from the

Reform and Growth Facility.

Given the state of infrastructure in enlargement countries, significant resources – by means of

grants and loans – beyond what is currently available, would be necessary to meet EU

infrastructure standards. While rail and road cross-border connectivity should remain a priority,

a gradual deployment of European track gauge railways in Ukraine and Moldova would require

considerable investment (currently estimated at EUR 3,5 billion on parts of corridors in

Ukraine to Lviv, Kovel and preparatory phases to Kyiv as well as to Chisinau in Moldova). For

Ukraine, there will be funding and workforce needs for the reconstruction of the obsolete,

damaged and destroyed transport infrastructure located on TEN-T and beyond. In addition, and

due to the war in Ukraine some EU Member States changed their prioritisation in the

development of the TEN-T network, focusing on east-west connectivity and military mobility.

This re-prioritisation of infrastructure investments has created an additional investment gap

which has been factored in the proposal for the next MFF, to ensure continued EU-level support

and management of coordinated infrastructure projects between two or more countries as

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signalled already in the Competitiveness Compass, combined with sufficient national support

to meet EU required standards across Member States.

Considering these challenges, strengthened CEF resources will be necessary to address the

cross-border gaps and in particular the integration of the railway systems, essential for

economic resilience and security of the EU.

Funding reflections would also need to factor in the needs for upgrading transport infrastructure

and building new facilities (such as alternative fuels infrastructure for roads, rail, ports and

airports, including refuelling and recharging stations), digitalisation efforts (introduction of the

European Rail Traffic Management System ERTMS, and the European Electronic Toll Service

EETS), and improving working conditions (e.g. safe and secure parking areas).

The realisation of enlarged transport corridors will also depend on actions to ensure safety and

security. The Black Sea Strategy has announced that the EU will work towards Black Sea

shores and the region becoming mine-free, building on and coordinating with the existing

trilateral demining initiative by Bulgaria, Romania and Türkiye.

Investments in greening and digitalisation of transport and the related infrastructure are

supported under the next MFF proposals. The EU budget could also be used to help bringing

the national/regional/local transport infrastructure to EU standards. In preparation for

enlargement, it will be important to mobilise financing instruments to address the substantial

needs in the transport sector including external instruments (under the current MFF this

includes the Instrument for Pre-accession Assistance (IPA III), the Reform and Growth

Facilities for Moldova and the Western Balkans, the Ukraine Facility and the Europe Pillar of

the Global Europe instrument under the next MFF). Given the limited capacity of the countries

to absorb these substantial network investments through increased tariffs, traditional financing

models may need to be supplemented. The post-2027 funding framework should look to

leverage a combined mix of centralised instruments, dedicated recovery reserves and public-

private partnerships (PPPs) to de-risk and accelerate these strategic gauge-conversion projects.

For transport decarbonisation, it may be necessary to reassess policies that support

implementation, primarily targeted at support for infrastructure development and support for

industrial operators to meet legal requirements (e.g. purchasing alternative fuels). Potential

changes could affect available resources and flexibility under the Innovation Fund, the

Alternative Fuel Infrastructure Facility under the Connecting Europe Facility, the European

Climate Social Fund, or Invest EU, among others.

On military mobility, considerations would need to be made for funding for dual-use transport

infrastructure and mobile assets to put in place a connected and secure military mobility

network and reinforce the EU’s capabilities, as proposed by the Commission in the 2028-2034

MFF package. Given the trans-national importance of such projects, centrally managed EU

funding, should be mobilised.

Enlargement would also require considering the administrative capacity needs in the new

Member States, as the potential new beneficiaries have limited experience in managing EU

funds and grant agreements and could benefit from additional support for the implementation

of projects and related monitoring, both at EU and national level. This could include support

for the synchronised implementation of strategic projects for the development of seamless and

interoperable TEN-T corridors, as well as for developing electronic Freight Transport

Information (eFTI) hubs and European Maritime Single Windows.

In the Commission and in the relevant EU agencies (ERA, EASA, EMSA), needs for increased

resources will stem from a larger pool of regulated entities and the efforts required to ensure

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proper implementation and enforcement of the rules and support capacity building in the new

Member States, including for setting up relevant IT systems.

4.3.2 Policy gaps and delivery risks

While most of the EU transport acquis is considered fit for enlargement, the main gaps

relate to the support policy framework and to ensure that infrastructure meets the required

standards (see Budgetary aspects). Other gaps, minor in magnitude, can be identified in a

limited number of legal acts, where some adaptations will be needed.

In aviation policy, there would be a need to further clarify provisions on the independence of

the Independent Supervisory Authorities under the Airport Charges Directive and the

functioning and decision-making process of slot coordinators, under the Slots Regulation. The

Commission would also need to seek authorisations to re-negotiate some existing air transport

agreements to include the new Member States. For new Member States to comply with the

ownership and control rules recently introduced under the Single European Sky Regulation in

2024, transitional periods may be considered. Transitional arrangements may also be put in

place to avoid the revision of the EU-wide performance targets for the remainder of reference

periods and facilitate the integration of new Member States’ in the Union’s performance

scheme for air navigation services and network functions (the performance and charging

scheme), depending on new Member States’ date of accession. The need to ensure sufficient

resources to cope with the implementation of the performance and charging scheme should be

also carefully addressed. The availability of sufficient resources for EASA is a risk factor in

terms of effective implementation of the EU acquis in future new Member States, in particular

where enlargement countries have a substantial aviation industry.

In maritime policy, no specific regulatory gaps have been identified, while for inland

waterway transport these seem to be limited to the need to update the list of EU waterways

divided geographically into zones.

In relation to logistics and the digitalisation of transport documents, changes might be

needed, primarily for the Commission to adapt the electronic Freight Transport Information

(eFTI) and European Maritime Single Window environment datasets.

In land transport policy, while no specific regulatory gaps have been identified, new market

entrants coming from new Member States could add competitive pressure. Transitional periods

and/or safeguard mechanisms, such as transitional measures on cabotage, may need to be

designed in Accession Treaties to manage competitive pressure on incumbent operators while

ensuring the progressive integration of operators from new Member States into the single

market.

More significant gaps are linked to the availability of resources in national administrations.

4.3.3 Reform orientations

No major reforms seem needed, but rather the regulatory adaptations listed in the above section

on gaps.

4.4 Environment policies

The EU's environmental legislation has been crafted to address both global challenges and the

diverse needs of its Member States. As a global leader in addressing environmental

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degradation, the EU develops policies underpinned by science and aligned with multilateral

environmental agreements, ensuring its policies help achieve global sustainability goals.

Simultaneously, the EU recognises the varied environmental conditions across Member States,

allowing for tailored implementation. Flexible frameworks such as the European Green Deal,

the LIFE programme - the EU's funding instrument for the environment and climate action -

and cohesion policy funds support Member States within their different economic and

environmental contexts. This approach balances ambitious goals with policies that respect the

unique needs of each Member States and the EU as a whole.

4.4.1 Impacts of enlargement on environment policy

Policy impacts

The EU relies on uniform environmental standards to ensure an equal standard of life and

wellbeing to its citizens and at the same time a level playing field within the single market and

its policies. Upon accession, there may be a gap between the levels of environmental protection

in current and new Member States. This could pose challenges to effective policy enforcement

and market integration. It could also bring competitive disadvantages for existing EU

businesses facing higher compliance costs (e.g., investments in cleaner technology, pollution

control, waste management, and compliance monitoring). Weaker environmental regulations

or enforcement in one or more Member States may lead to the production of goods that do not

meet EU sustainability standards (due to, for example, higher emissions, pollution-intensive

production processes). If these goods enter the single market at lower prices, it can distort

competition and discourage businesses in the EU from making green investments. Last,

environmental degradation (e.g. air or water pollution) in one or more Member States could

have effects on the single market. For example, lax regulations in one country might lead to

cross-border pollution affecting neighbouring EU countries, which could also disrupt trade

relations and increase regulatory disputes.

At the same time, enlargement countries possess vast areas of untouched nature which would

contribute considerably to biological diversity in the EU. To keep these assets and, at the same

time, develop and manage an economically and environmentally sustainable transition, is a

major challenge ahead. As regards environmental protection under the common agricultural

policy (CAP), enlargement also presents opportunities to further reduce the environmental

footprint of the agricultural sector in the enlargement countries. Among other factors, this is

due to notable differences between some enlargement countries and the EU in areas such as

pesticide and fertiliser use as well as phytosanitary standards for fruits and vegetables.

EU environmental legislation is overall ‘fit for enlargement’. Yet, enlargement would bring

greater heterogeneity to the EU.

On waste and circular economy, enlargement offers an opportunity to increase and strengthen

the single market for circular and secondary raw materials. At the same time, the EU targets

forthe re-use and recycling of municipal waste, the recycling of packaging waste, and the

reduction of the landfilling of municipal waste may not be met by current enlargement countries

at the time of their accession to the EU.

On industrial pollution, it will require significant investments and time for enlargement

countries to ensure that their industrial plants comply with the relevant EU requirements, e.g.

by installing abatement technologies or modernising installations.

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The same is valid for urban wastewater treatment, water and air quality monitoring and water

and air quality improvement measures, which rely heavily on investments in infrastructure

combined with the capacity to maintain the economic viability and operation of these plants.

Further, because of new Member States becoming subject to the rules on intra-EU shipments

of waste, it will become easier to ship waste - including hazardous and problematic waste135 -

to new Member States, as compared to old Member States, if the new Member States have

lower treatment costs or if tools to discourage incineration or landfilling (such as taxes) are not

in place or not as effective. A similar trend has been observed in the last few years, where

significant volumes of waste (especially low-quality waste destined for cement kilns or waste-

to-energy plants) have been shipped from western European Member States to central and

eastern European Member States. In addition, it will also be essential to prevent the risk of an

increase in illegal shipments of waste to future Member States, as there could be initially less

control on their movements when those countries become part of the single market. Waste

trafficking is one of the most serious forms of environmental organised crime and criminal

networks are agile in exploiting new opportunities.

Budgetary aspects

Investments in the environment area are primarily supported through the cohesion policy (e.g.

waste and circular economy, water and air) and the Common Agricultural Policy

(biodiversity, soil and forests). As recognised in the section on cohesion policy, new Member

States might require significant investments into basic services and infrastructure to close the

compliance gap and speed-up convergence with EU environmental standards.

Further, as mentioned in the section on agriculture, enlargement would put pressure on CAP

support, including for the transition to environmentally sustainable practices. At present, the

CAP is the main contributor to environmental protection in agriculture.

The LIFE programme is currently the only key dedicated instrument to support the

implementation of EU environmental, climate and energy policy and legislation. Ukraine,

Moldova and North Macedonia are already associated to the LIFE programme and Montenegro

and Serbia have expressed interest to join. Enlargement may generate additional financing and

implementation needs in the area of nature and biodiversity. These may arise, inter alia, from

the extension of the Natura 2000 network, related designation, management, restoration and

monitoring requirements, and the need to strengthen administrative and implementation

capacity in candidate countries. The transboundary character of many ecosystems in the

Western Balkans may also require enhanced cross-border cooperation. These considerations

could be taken into account in the future programming and implementation of relevant EU

funding instruments.

In addition to the already mentioned needs in the areas of waste and circular economy, water

and industrial pollution, new Member States are expected to face specific challenges in

implementing relevant environmental policies and legislation, which may be due to limited

governance capacity, lack of resources, and insufficient governmental capabilities for

monitoring and enforcement. To mitigate these risks before accession, it is being envisaged to

couple budget allocation with targeted technical assistance and capacity building to support the

implementation of EU environmental and climate policies in new Member States. This

135 The current rules make a distinction between shipments within the EU and export to non-OECD countries. The

rules for shipments of waste to non-OECD countries are much stricter: the export of hazardous and ‘problematic’

waste (like mixed household waste) to these countries is already banned. From 2026/2027, new rules will impose

stricter requirements on the export of all other types of waste. All enlargement countries are non-OECD countries

and therefore subject to these strict rules.

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approach has proven successful in the past, such as in the case of Ukraine under the Phoenix

initiative for capacity building to help rebuild cities in a high-quality, sustainable and inclusive

way136.

For the Commission and the European Environment Agency (EEA), enlargement would trigger

across all environment policy areas the need for resources to ensure effective monitoring,

compliance promotion and enforcement functions.

4.4.2 Policy gaps and delivery risks

The main gap in this policy area is the potentially insufficient preparedness of enlargement

countries and pre-accession support.

These risks are real as at present those countries’ environmental problems are far more severe

than those faced by existing Member States. For example, some of the highest air pollution

levels in Europe have been recorded across the Western Balkans due to coal-powered industrial

installations and domestic heating. This can impair the actual compliance of operators and

installations with the EU rules, beyond the mere alignment of national legislation with the EU

acquis. Although the EU has already supported enlargement countries investing in their

transition137, this support may need to continue and be scaled up as needed after accession to

help these countries meet the costly needs for infrastructure in particular in the waste and water

management sectors and power sector and ensure that they can quickly close any compliance

gap with EU standards.

At the same time, current gaps in administrative capacity in enlargement countries, affecting

also their capacity to absorb cohesion policy funding, can impact the ability to make the

investment needed to ensure compliance.

4.4.3 Reform orientations

Rather than making policy changes, the EU should strengthen pre-accession support and

ensure its continuity after accession, for all enlargement countries and across all

environmental sectors (cross-cutting legislation, air quality, water quality, waste management,

chemical, industrial pollution and risk management, noise, etc.). Below are some examples of

systems of support already in place:

• On waste and circular economy, preparing institutional, administrative and policy

frameworks and a solid strategic foundation complemented by costed action plans/project

pipelines will be vital for the EU to maintain its level of ambition.

• On industrial pollution, pre-accession instruments should support enlargement countries

in their preparations to meet requirements related to de-pollution/industrial pollution, in

particular the revised Industrial and Livestock Rearing Emissions Directive, the Medium

Combustion Plant Directive (MCPD) and the Seveso-III Directive - so that industrial plants

in new Member States meet the emission limit values and requirements of the best available

techniques, the MCPD limit values and the industrial safety standards, e.g. by installing the

136 In 2023, the New European Bauhaus (NEB) community together with Ukrainian partners (Covenant of Mayors

East, Ro3kvit, ReThink) launched a capacity-building programme for Ukrainian municipalities to prepare for

post-war reconstruction. These and other NEB activities in Ukraine were boosted through the ‘Phoenix’ initiative

which developed and put at the disposal of Ukrainian cities cutting-edge expertise from the NEB community in

affordable and sustainable reconstruction. It also connects Ukrainian cities with like-minded ones in the EU to

exchange experiences on their way to climate neutrality and more energy efficiency. It combines funding from

the Horizon Europe Mission for Climate-Neutral and Smart Cities and from the LIFE programme. 137 E.g. ‘Economic and Investment Plan for the Western Balkans’.

90

necessary abatement technologies or modernising the installations. Similarly, the pre-

accession process is an opportunity for enlargement countries to put in place the appropriate

national laws and institutional capacities to ensure that they meet the legislative

requirements, ranging from well-equipped permitting authorities and appropriate

monitoring frameworks to public participation, transparency, enforcement and

compensation requirements.

• On the Nitrates Directive, in some cases, the system of monitoring and protection of waters

will need significant further development to be brought up to EU standards entailing

increased oversight by the Commission.

Finally, transitional measures, granting new Member States additional time to comply with

obligations in certain areas of the EU environmental acquis, may need to be included in the

accession treaties, based on enlargement countries’ requests and/or following the

Commission’s assessment.

5. COHESION, AGRICULTURE AND RURAL DEVELOPMENT, FOOD AND FISHERIES

5.1 Regional and cohesion policy

As with previous enlargement rounds, the next round will significantly affect cohesion policy.

With this comes the need for a comprehensive reflection on the future role and functioning of

cohesion policy within a larger EU. In an expanded EU, cohesion policy138 will play a key role

in the Commission’s broader convergence, investment and reform agenda, with regions at the

centre. For 2028-2034, Member States will develop national and regional partnership plans

with key reforms and investments, focusing on joint priorities, including promoting economic,

social and territorial cohesion. This will help build administrative capacity, well-functioning

institutions and trust. Cohesion policy will be needed to facilitate a smooth integration of the

new Member States in the single market. This is important not only to ensure their ability to

effectively benefit from cohesion policy funds after EU accession, but even more so to ensure

that the overall benefits that enlargement can bring for both new and current Member States

can fully materialise.

5.1.1 Impact of enlargement on cohesion policy

The accession of some or all enlargement countries to the EU will affect the EU’s average GDP

per capita and may thus have a significant impact on the allocation of cohesion policy139. As

pointed out in the 9th Cohesion Report, the disparities between the existing Member States and

the set of enlargement countries included in the simulation140 are not very different from those

observed in relation to the 2004 enlargement, when 10 new countries joined the EU (see Figures

138 For the 2021-2027 MFF: European Regional Development Fund, the Cohesion Fund, as well as the Just

Transition Fund and the Public Sector Loan Facility under the Just Transition Mechanism. 139 For the purposes of these calculations, Eurostat data were used for EU-27 countries and for those enlargement

countries for which regional data were available. National data sources were used for regional GDP and population

figures for Bosnia and Herzegovina, Georgia, Moldova and Ukraine. GDP for these countries was converted into

EU purchasing power standards (PPS) using World Bank figures in purchasing power parity terms (current

international dollars) and the regional share of GDP in each country. All data refer to 2021 and are regularly

subject to revisions. 140 Countries included in the simulation: Albania, Bosnia and Herzegovina, Georgia, Kosovo, Moldova,

Montenegro, North Macedonia, Serbia, and Ukraine.

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1 and 2 below)141.

Note: the EU aggregates in the first two rows include the UK, while the EU36/EU27 aggregates in the last row do not include the UK.

Figure 1 – GDP per head in regions in the EU and enlargement countries in 2004

Figure 2 – GDP per head in regions in the EU and candidate partners in 2021

141 See 9th Cohesion Report, COM (2024) 149 and SWD (2024) 79.

Increase in

area

Increase in

population

Increase in total

GDP (PPS)

Change in per

capita GDP (PPS)

Average per

capita GDP

EU25/EU15 (2004 data - EU15=100) 22.2% 19.2% 9.7% -8.0% 92.0

EU27/EU25 (2007 data - EU25=100) 8.6% 6.1% 2.5% -3.4% 96.6

EU36/EU27 (2021 data - EU27=100) 21.8% 15.1% 4.8% -8.9% 91.1

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However, there would likely be an impact on less developed EU regions that are close to the

current 75% threshold. With a new, lower EU average GDP per person, their GDP per head

will be higher in relative terms. This would have an impact on the population in less developed

regions in some Member States, and potentially on the level of resources earmarked for them.

Socio-economic disparities are likely to widen both between Member States upon accession

and within countries. Previous enlargement experience suggests that within acceding countries,

large cities, notably capital cities, grow more quickly than the EU average, while more

peripheral or rural territories generally grow more slowly, leading to increasing disparities at

national level. Therefore, cohesion policy remains much needed, as the main instrument to

reduce such disparities.

The enlargement countries are highly reliant on coal and other carbon-intensive energy sources,

which poses a significant challenge as they work to align their national legislation with the EU

acquis and the climate objectives. Achieving compliance will require a fundamental

transformation of their energy systems and industrial sectors. This transition will be particularly

demanding for regions that are already economically and socially vulnerable and ensuring a

just transition will be essential to maintain social cohesion and build public support for the

broader reform process.

Already at present, the EU actively supports cross-border, transnational and inter-regional

cooperation between Member States and bordering enlargement countries, through Interreg

programmes. The nature of some of these programmes, and their financing, will change upon

accession (cross-border programmes will become ‘internal’ to the EU and the funding will

come exclusively from internal EU budget lines).

The link to reforms

Over the past two programming periods, the EU has focused on making cohesion policy more

effective, most notably through stronger and more structural links between investments and

reforms. These links and mechanisms have provided solid ground for cohesion policy

investments to be fully embedded in national and regional policy frameworks and legislation.

The financial sustainability of projects has also been strengthened, for example through

comprehensive transport planning and multiannual plans for the budgeting and prioritisation

of investments in research and innovation infrastructure. These mechanisms have triggered

policy reforms - for example in the health sector and public procurement - and the delivery of

relevant country-specific recommendations. They ensured a direct link between cohesion

policy investments and EU level policies. They contributed to the transposition and

implementation of EU legislation and helped to tackle barriers to investment in the EU.

In addition, cohesion policy investments have been programmed jointly by the Commission

and Member States based on robust socio-economic analyses within the European Semester.

The national and regional partnership plans for 2028-2034 will continue to be programmed to

respond to the challenges identified in the European Semester process and country-specific

recommendations as well as in other key policy documents adopted by the Commission, while

also reflecting the unique needs of individual countries and regions.

Administrative capacity

Most enlargement countries have limited experience of regional development and need to

develop their administrative capacity to manage structural funding. The quality of institutions

– including respect for the rule of law, and administrative capacity – is crucial for the return on

public and private investment. There is a strong correlation between the quality of governance

and the impact of Cohesion Policy investments. Improving the quality of governance at

national, regional and local level can increase the effectiveness of national and European

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policies and investments. The main gap identified in relation to the implementation of cohesion

policy in an expanded EU is linked to the (lack of) capacity to manage substantial amounts of

cohesion policy funding, with the required level of legal assurance. Experience has shown that

acquiring the capacity to effectively manage funds takes time.

Some enlargement countries (Montenegro, Albania, North Macedonia, Moldova), do not have

regional administrative units. In these countries, the management of cohesion policy is

expected to primarily involve the national level and will require substantial strengthening of

government functions across all aspects of fund management. Serbia and Bosnia and

Herzegovina are larger and have clear regional divisions. Ukraine is by far the largest and is

currently developing a regional development legal framework, albeit with very limited

implementation experience and reduced capacity.

There are weaknesses (performance on rule of law, transparency, and corruption risks) in the

national systems critical for ensuring the regularity of public expenditure and the required level

of assurance and compliance (procurement, State aid, sound financial management). These

gaps, if not addressed properly, affect both implementing authorities and beneficiaries but

would also affect the EU more broadly upon enlargement. Therefore, it is particularly important

to take measures to strengthen public administration and build capacity in order to improve

governance at all levels. This is one of the key objectives of the proposals under the 2028-2034

MFF package.

Territorial and interregional cooperation challenges

Upon accession, there will be new external borders. Some of those will pose new challenges

in terms of cooperation. Borders with Russia and Belarus will continue to cause difficulties,

and this over a much larger territory. Additional external programmes would need to be set up

along the external borders of new Member States. For borders between Western Balkans

countries, the scope of Interreg might need to be adjusted to maximally support reconciliation

in territories recently affected by tensions and conflicts.

The current Interreg cooperation partnerships will need to undergo significant changes. In

particular, the need will arise to set up new programmes with new Member States (circa 10

new programmes). At the same time, some of the existing Interreg programmes will transition

from being external border cooperation to internal border cooperation programmes – a

transition with broad budgetary, operational and geo-political implications.

5.1.2. Policy gaps and delivery risks

Enlargement countries may face different development challenges compared to the current

Member States. Over successive programming periods, funding under cohesion policy has

gradually moved away from basic infrastructure investments and is now more closely aligned

with the EU objectives. While the priority policy areas (such as competitiveness,

decarbonisation, environmental protection, digitalisation and social cohesion) that will drive

the investments and reforms in the next programming period pertain to both current Member

States and enlargement countries, new Member States may also require investments into basic

services and infrastructure to speed-up convergence and the integration process. Finding the

right balance between necessary reforms and investments is likely to be challenging.

The main gap identified in relation to the implementation of cohesion policy in an expanded

EU is linked to the lack of administrative capacity in enlargement countries to programme

and implement a plan per country, covering key reforms and investments, in full partnership

with national, regional and local authorities. The capacity to implement sectoral policy

reforms on a wide range of topics will also prove challenging. There is also uncertainty

94

whether all new Member States would have the fiscal capacity to mobilise the amounts

necessary to co-finance EU-supported investments.

Due to its specific nature, current pre-accession support is not aligned with the founding

principles of shared management and cohesion policy – e.g. territoriality and place-based

support and the application of the partnership principle in the implementation of the funds. In

its proposal for the 2028-2034 framework, the Commission integrates pre-accession support

into the Global Europe Instrument, applying the partnership principle. It will provide a single

comprehensive toolbox allowing to build tailor-made support for each enlargement partner

while allowing to better respond to changing political realities. The Global Europe regulation

also allows for greater alignment of pre-accession support with sectoral policies through an

implementing regulation, which will detail further rules related to the implementation of pre-

accession assistance in a way that credibly prepares candidate countries and potential

candidates for EU membership and management of EU funds. Through this, it will also

strengthen complementarity with internal policies, including Interreg, ensuring that

enlargement assistance aligns with the cohesion logic and is anchored in joint ownership.

5.1.3. Reform orientations

The MFF proposals for 2028-2034, will further improve the effectiveness and efficiency of

cohesion policy via comprehensive national and regional partnership plans supporting key

investments and reforms. This enables the application of tailor-made requirements taking into

account Member States and regions’ specific difficulties, needs and challenges as they change

over time.

There is a need to explore means to adapt the EU’s pre-accession assistance to bring it closer

to the needs of a ‘strengthened cohesion and growth policy with regions at its centre […]

designed and implemented in partnership with national, regional and local authorities’142. The

recently created Ukraine Facility and the Reform and Growth Plans and Facilities for the

Western Balkans and Moldova are useful in helping enlargement countries align with the

concept of developing individualised plans for each country, with key reforms and investments

clearly identified. The main adjustments could consist in ensuring a stronger link between the

pre-accession assistance currently available to enlargement countries, and the obligations that

will stem from implementing cohesion policy under shared management upon accession.

The Global Europe proposal stipulates the adoption of an implementing regulation to lay down

uniform conditions for the implementation of the regulation in enlargement countries - in

relation to the design and content of the performance-based plans, performance, structures and

control systems to be set up in preparation of accession, also as part of the management of

structural, agricultural and cross-border cooperation funds. This approach will play a crucial

role in ensuring consistency between pre-accession support and post-accession implementation

structures. This follows previous practice as implementing regulations have also been used

previously, under both IPA II and IPA III.

Given the significant needs in terms of capacity building at all government levels and in civil

society in enlargement countries, a major effort is needed to strengthen institutions and

administrations, in particular on rule of law, transparency and the fight against corruption.

While financing reforms are a positive step towards building better societies, investing in

general administrative capacity to improve public administration at all levels is also an

142 COM (2025) 46.

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important factor in line with the OECD/SIGMA principles of public administration143. These

principles were designed by the OECD and the Commission to guide the enlargement countries

in their reform efforts to address the shortcomings in their public administrations and meet the

EU requirements on one of the fundamentals aspects of the accession process. Moreover, pre

accession assistance that helps close the gaps and meet the needs is essential. It should be

considered to allow enlargement countries – at an early stage – to become associated

participants in existing technical assistance platforms as well as those under the 2028-2034

MFF that help current Member States with implementation challenges.

Overall, it is important to continue working with enlargement countries to align public

investments with appropriate policies. Effective past practices could be replicated, such as

twinning between public administrations. For the 2004 enlargement, part of the pre-

accession assistance was implemented using a model that resembled shared management as

closely as possible, which was the main management mode for structural and agricultural funds

at the time. This could be considered as an option again, aligning implementation modalities

between internal and external funds to the extent possible, to prepare enlargement countries for

managing structural and agricultural funds going forward.

Peer-based capacity building is already taking place as part of the implementation of the

Interreg programmes between Member States and enlargement countries. Although the final

responsibility for programme implementation lies with the Member States, the partner

countries fulfil their functions on an equal footing and take part equally in all steps of the

implementation cycle, including financial control and audit. This could be preserved until

accession.

5.2 Agriculture and rural development

An expanded EU has the potential to be a stronger global agri-food actor. At the same time,

EU farmers will experience increased pressure within the single market. Enlargement would

significantly increase the EU’s surface area of agricultural land. Adding farms that range in

size from less than one hectare to several hundred thousand hectares, presents significant

challenges for the common agricultural policy, which currently is designed to deliver for an

EU of 27 Member States.

As underlined in the Commission’s Vision for Agriculture and Food, preparing for and

effectively addressing the challenges for EU farmers will be essential to reap the opportunities

offered by enlargement144.

5.2.1. Impact of enlargement on agriculture and rural development policy

Impacts on the EU agricultural sector

An expanded EU will likely have a strengthened strategic autonomy in food and feed

compared to the EU-27. It will be a bigger player on the global agricultural commodity market

- with an increased EU agri-food production and export capacity - and a larger contributor

to global food security.

Such increase in production is expected to come primarily from the increase in the EU’s

agricultural area. Adding the current Ukrainian production of soybeans and sunflower seeds

143 OECD/SIGMA principles of public administration can be found on

https://www.sigmaweb.org/en/publications/the-principles-of-public-administration_7f5ec453-en.html 144 COM (2025) 75.

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would increase the respective EU-27 production levels by up to 150%. A sharp increase in the

production of maize (+50%) and wheat (+28%) could also be expected.

This would contribute to increasing the supply and use of EU-grown protein and oilseeds,

reducing the EU dependency, and contributing to a stronger, more resilient and more

autonomous European agri-food system. This would be in line with the objectives of the Protein

Action Plan145 adopted on 7 July 2026 that emphasised that the accession of Ukraine alone

could reduce the EU’s trade deficit in plant-based protein from 13.9 million tonnes to 4.7

million tonnes and increase the EU’s self-sufficiency in plant-based protein from 76% to 86%.

Improving agricultural productivity in the enlargement countries after accession could

gradually reduce the yield gap with the EU-27, thanks to better access to advice, technologies,

genetics, and investment. Overall, EU production would increase strongly compared to the EU-

27, in the arable crop, poultry, fruits and vegetables sectors. For beef and dairy, the increase

would be more limited, as enlargement countries are expected to reduce their production after

accession. This reduction might be only partially offset by an increase in production in the EU-

27.

By improving their logistics through better infrastructure, the enlargement countries, and

particularly Ukraine, could boost their exports to the EU-27 countries and to the rest of the

world after accession. They could also increase their imports. Exports from EU-27 countries to

markets of all enlargement countries are also expected to increase. Overall, the expanded EU

would export more key commodities compared to the EU-27, becoming the leading global

exporter of wheat, barley and sunflower oil. This would allow the expanded EU to increase its

contribution to global food security compared to the EU-27.

Enlargement would impact the single market for agricultural products, primarily considering

the production and export capacity of Ukraine. Most EU farmers will face an increased

competition in the single market. Some production might shift from one Member State to

another, as it has happened after previous enlargement rounds. For cereals, sugar, poultry and

eggs, and fruit and vegetables, the impact would initially be felt throughout the EU-27,

particularly in regions neighbouring Ukraine, as already experienced after the adoption of

autonomous trade measures with Ukraine. As an illustration, in 2021 (before Russia’s war of

aggression against Ukraine), the production capacity of Ukraine for soft wheat was 32 million

tonnes compared to the overall EU-27 production of 130 million tonnes. During the 2023-2024

campaign Ukraine exported 6.5 million tonnes of soft wheat to the EU-27, out of total exports

of 18 million tonnes, corresponding to two thirds of the EU’s total imports of soft wheat (9.6

million tonnes). Although the Russian war of aggression severely disrupted Ukraine’s

traditional export routes, which partly explains the substantial EU import volumes for 2023-

2024, this reflects the large export capacity of Ukraine. At the same time, this could have a

positive impact on livestock production in the EU, contributing to lower feed costs.

Small farms in the Western Balkans countries that have a low competitiveness level would also

be impacted. For beef and dairy, the impact would be felt primarily in the enlargement countries

after accession.

In the short term, enlargement might impact agri-food prices due to the competition from

specialised, export-oriented farms in enlargement countries that benefit from economies of

scale and lower input costs. However, many current EU farms can be expected to adjust to the

new market environment.

145 COM (2026) 355.

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Enlargement is expected to lead to a structural adjustment of farms across the expanded EU,

which could accelerate the on-going decrease in the number of farms, particularly in the

enlargement countries after accession. The impact could be particularly strong in less

competitive areas such as in the Western Balkans where – except for Serbia – most farms are

in mountainous areas. This could have a positive impact on the modernisation of farms but

would create issues related to land abandonment and further depopulation in rural areas across

the EU. As a result of this structural adjustment, the share of the rural population working in

agriculture-related jobs in the enlargement countries (e.g. in Ukraine, 20% of the working

population is currently employed in agriculture) is expected to slowly decrease.

Nevertheless, the expanded EU would have a significantly higher number of farms compared

to the EU-27. The vast majority would be very small, (semi-)subsistence, household farms that

would struggle to comply with EU standards and to adapt to climate change; a few tens of

thousands would be medium sized to big family farms, with 10 to a few thousand hectares.

Several thousand will be very big, competitive, export-oriented corporate farms, essentially

located in Ukraine, some belonging to agro-holdings.

EU rural areas will also significantly increase in an expanded EU, and so will the rural

population (the share of the rural population in the enlargement countries ranges from 30% in

Ukraine to 57% in Moldova). In enlargement countries, particularly in the Western Balkans,

rural areas are expected to continue facing depopulation, a lack of skilled and trained labour,

as well as an ageing population. Lack of public and digital services hinders the attractiveness

of these regions. This contributes to the rapid decline in young people's interest in agriculture.

In an expanded EU, all Member States will continue to face the negative impacts from climate

change.More EU farmers, both in the EU-27 and in enlargement countries, will be impacted

by droughts, floods, hailstorms and other adverse weather events throughout any year, as well

as by animal diseases. This will weigh on their capacity to invest and adapt to transition to a

more sustainable farm system. Land abandonment in less competitive regions may lead to a

reduction of biodiversity, while ploughing pastures due to a reduction in livestock numbers in

the enlargement countries after accession would liberate carbon dioxide in the atmosphere.

Ukraine’s extensive soil surface means that the EU would have greater potential for carbon

storage. Enlargement represents an opportunity to modernise livestock production in

enlargement countries, to reduce greenhouse gas emissions and meet EU animal welfare

standards.

Impacts on the Common Agricultural Policy

The current Common Agricultural Policy (CAP) is designed to address a large array of

challenges, with the support of a comprehensive policy toolbox, including: (i) direct payments;

(ii) the possibility to introduce capping, degressivity and targeting of those payments; (iii) agri-

environmental and climate measures; (iv) support for investment and to areas with natural

constraints; and (v) additional rural development measures. The CAP requires Member States

to choose and further tailor policy measures based on a strategic, performance-focused

approach that builds on the national strengths and weaknesses identified after a thorough

analysis. CAP strategic plans are tailor-made to the Member States’ needs and are approved by

the Commission. In this sense, the CAP is an agile and flexible policy, able to adapt to current

and future challenges, if sufficient resources are available for its implementation, along with

appropriate transition measures, similar to those taken in previous enlargement rounds (such

as the phasing-in of CAP support in enlargement countries over a certain period of time after

accession or effective safeguard mechanisms for sensitive products).

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If several countries were to join the EU under current rules, this would significantly increase

the CAP’s funding needs, driven primarily by two key factors: the number of farmers and the

agricultural area to be covered. However, the current CAP is designed and financed for an

EU of 27 Member States, based primarily on a family farm model.

Within the current policy framework, a significant share of CAP support would be granted to

thousands of large (above 1000 hectares) competitive farms, notably in Ukraine (where they

cover more than 15 million hectares, more than the size of the utilised agricultural area of

Poland).This would put additional pressure on the CAP budget and in particular on family

farms, which are at the core of the EU agricultural model, leading to a reduction in the diversity

of farms in the EU and impacting existing EU-27 farms. This could also undermine the long-

term resilience of the EU food system, if production and food sovereignty are centralised in

a few Member States.

With increased competition in the single market, enlargement could impact theeffectiveness

and the efficiency of existing policy toolssupporting the competitiveness, resilience and

sustainability of the agricultural sector – from direct payments to agri-environmental and

climate measures, sectoral support, measures supporting areas with natural constraints, young

farmers schemes and crisis management measures.

With the number and scale of risks expected to increase in an expanded EU (adverse climate

events, disease outbreaks), the pressure on the current agricultural reserve is likely to increase

further. The increase in export-oriented farms, primarily in Ukraine, would also make the

current tools less effective in case of trade tensions as volumes destined for third markets would

put pressure on the EU domestic market.

Other tools provided by the common market organisation and the Unfair Trading Practices

Directive aim to improve the functioning of the food chain to address the shortcomings of the

single market, would remain essential in an enlarged single market.

In an expanded EU support for young farmers will become even more critical and certain

sectors will need targeted support.

Incentives would also be needed to transition to more sustainable practices, and to promote

various practices such as organic farming, agro-ecological practices, precision farming, agro-

forestry or carbon farming, as well as animal welfare improvements.

Current rural development tools would be less effective in view of the massive challenges

faced by the rural areas in enlargement countries such as migration to cities, an ageing

population and lack of public services. Very large farms, particularly in Ukraine, could also

benefit disproportionately from rural development funds, including investment aids.

The administration of the CAP as well as market monitoring and shared management in

an expanded EU would require appropriate resources, both for the Commission and the

enlargement countries after accession. New Member States will have to put in place a variety

of administrative structures and strengthen their administrative capacity with appropriate

structures and staff ahead of accession.

Budgetary aspects

Under the current MFF the CAP is jointly funded by the European Agricultural Guarantee Fund

(EAGF) and the European Agricultural Fund for Rural Development (EAFRD), with the major

share of funds being subject to strategic planning in each Member State for the three main

policy instruments, namely direct payments interventions (EAGF), sectoral interventions

(EAGF) and rural development interventions (EAFRD). Outside of the CAP strategic plans,

the EAGF also finances exceptional measures, public intervention and private storage, school

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schemes, promotion and the Programme of Options Specifically Relating to Remoteness and

Insularity (POSEI).

If several countries were to join the EU, this would significantly increase the number of farmers

and the agricultural area to be covered by the CAP, these two factors being the main immediate

drivers of CAP funding needs (see above).

Currently, enlargement countries provide investment support, support for the purchase of

inputs, e.g. diesel or fertilisers, as well as direct payments to their farmers, mostly livestock

producers, in the form of coupled support. The total level of support cannot be compared to the

levels of support in the EU: Ukraine’s national budget for agriculture was EUR 150 million in

2024 (broadly the same as in 2021, before the war), comparable to North Macedonia’s

agricultural budget. Moldova increased its annual agricultural budget to EUR 98 million in

2024.

The following elements are deemed important when considering enlargement related funding

needs:

• The proposed NRP methodology for the calculation of the Union financial contribution for

each Member State, that considers a series of socio-economic variables.

• Crisis management support. As enlargement would increase significantly the EU’s

agricultural area, pressure on the use of what is currently the agricultural reserve, and the

Unity Safety Net in the future, would inevitably increase.

• Need for technical assistance. Enlargement countries funding needs after accession, will

relate to ensuring proper administration, implementation and monitoring in relation to the

CAP; and access to advisory services, networks and capacity building. Enlargement

countries will need to be able to contribute properly to the common collection of EU

agricultural data after accession. In this context, adequate funding for CAP technical

assistance on the Commission’s own initiative would need to be ensured in view of

enlargement.

As highlighted above, depending on the final modalities and if no specific arrangements or

transitional measures are envisaged, enlargement might have a substantial impacton the CAP.

This policy area is likely to be one of the most impacted by enlargement, given the considerable

expansion of the agricultural area, and the addition of a high number of farms with a wide

variety of needs from generational renewal, innovation, training and advice to investment for

modernisation to deal with challenges such as complying with high phytosanitary standards.

In view of this expected impact, a CAP that is fit for purpose must provide targeted support to

farmers who need it most, promote positive environmental and social outcomes through

rewards and incentives for ecosystem services and support the right enabling conditions for

thriving rural areas. It must become simpler, targeted and find the right balance between

incentives, investment and regulations, and ensure that farmers have a fair and sufficient

income.

5.2.2 Policy gaps and delivery risks

In light of the impacts described above, the main policy gaps linked to enlargement identified

are in line with the policy gaps related to the current CAP as identified in the Strategic Dialogue

on the Future of EU Agriculture146 and in the Vision for Agriculture and Food.

146 European Commission (2024) Strategic Dialogue on the Future of EU Agriculture.

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Enlargement would require adjustments, as well as gradual transition to ensure preparedness.

The CAP proposal under the 2028-2034 MFF gives the direction. It provides a significant

contribution by proposing mandatory degressivity and capping, introducing the minimum and

maximum aid per hectare, extending the support for small farmers and offering the possibility

to create synergies with cohesion policy through the national and regional partnerships plans,

to better target the support towards farmers who need it the most, and by giving more leeway

to Member States in designing the details of the CAP measures. It also gives further incentives

for farmers and rural communities to adopt sustainable practices.

Appropriate transitional periods should be considered, as in previous enlargement rounds, such

as the phasing-in of CAP support in enlargement countries after accession or effective

safeguard mechanisms for sensitive products. The specific situation of Ukraine with respect to

the ongoing war and the resulting needs for reconstruction as well as the specific scale and

situation of Ukraine’s agricultural sector will require specific treatment.

In addition, the current CAP tools may not be able to address all the needs of the many farms

in enlargement countries that may not manage to adapt to the EU requirements in terms of

production standards and marketing requirements among others.

With most enlargement countries having farm structures characterised by a significant number

of farms with low yields, low-income levels, limited management skills and an ageing farming

population, support to promote viable farm incomes and resilience of the agricultural sector

will be crucial.

Special attention will likely need to be given to supporting the large number of very small

farms in the enlargement countries. Similarly, additional support under rural development will

be relevant to promoting generational renewal, innovation, training and advice, as well as

offering investment support for modernisation and dealing with, for example, the challenge of

complying with high phytosanitary standards. Enlargement countries with, for instance,

agricultural production in mountainous areas will need rural development support for natural

or other area-specific constraints after accession.

As a result of geopolitical tensions, the EU’s Eastern border regions most affected by Russia’s

war of aggression against Ukraine are rural areas of particular vulnerability and concern and

need particular support. Socio-economic decline and increasing depopulation will have

additional security implications here, while these mostly rural areas are of strategic importance

for the EU’s security.

In an expanded EU, farmers may also have to be supported to generate additional sources of

income (i.a. bioeconomy, carbon farming, renewable energy production, nature credits). This

would be particularly true for some farm types (e.g. livestock production) or in certain regions

(mountains). Equally, the balance between regulation, investments and incentives may need to

be reviewed.

To help achieve the European Green Deal targets, with the objective to contribute to the broader

goal of a climate-neutral and resilient EU by 2050, farmers in enlargement countries would

need funding under direct payments and rural development after accession. This would enable

them to commit to and ensure a transition to sustainable agricultural practices beneficial for the

climate and the environment. Incentives would be needed to promote various practices such as

organic farming, agro-ecological practices, precision farming, agro-forestry or carbon farming,

as well as animal welfare improvements, depending on the climatic and environmental situation

and current agricultural practices in each enlargement country.

Considering the challenge of attracting young farmers, in particular in rural areas of

enlargement countries where depopulation is a big challenge, and the vital need to ensure the

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EU’s future food sovereignty, more measures could be needed to address the multifaceted

challenge of generational renewal. The Commission Communication on the generational

renewal in agriculture adopted on 21 October 2025 is an important contribution to the debate

in that context147.

On sectoral support, it must be thoroughly analysed whether the current public storage

mechanism is apt to handle future interventions. Also, as of 2023, all public intervention and

private storage measures are financed under the agricultural reserve, which accommodates also

funding for exceptional measures and is limited (at least EUR 450 million per year).

In view of increased risks, in a world marked by geopolitical and geoeconomic tensions,

existing risk and crisis management tools may not be fit for purpose during crises unless more

is done at farm level to anticipate and mitigate the impacts of market crises, weather events and

climate change in general. The capacity of those tools should be commensurate to the

challenges. The adoption of the Fertiliser Action Plan148 is an important step in strengthening

EU’s food security in times of geopolitical shocks and supply disruptions.

Currently there is a lack of tools to ensure the proper functioning of the single market in view

of the expected surge in intra-EU-trade in agri-food products. This is particularly the case for

Member States or regions neighbouring Ukraine, as shown by the experience of the

autonomous trade measures.

Against the background of enlargement, simplifying the CAP will be crucial for future Member

States to implement it and for farmers to comply with all its requirements.

5.2.3 Reform orientations

To address the policy gaps identified above, the below policy options have been identified to

make the CAP fit for enlargement:

• Simplifying CAP support and better target those farmers who need it most, finding the

appropriate balance between regulation, investments, incentives and additional sources of

financing and strengthening the use of measures such as degressivity and capping, taking

into account different structural and sectoral realities of Member States as proposed in the

2028-2034 MFF package.

• Considering appropriate transitional arrangements as in the previous enlargement rounds,

such as the phasing-in of CAP support in enlargement countries after accession or effective

safeguard mechanisms for sensitive products.

• Developing dedicated tools to address the challenges of the (very) small/subsistence farms,

in particular in the enlargement countries, and to facilitate access to diversified and new

complementary sources of income, for all farms, in addition to direct payments and

payments for ecosystem services.

• Ensuring that all farmers have sufficient resources and investment capacity to finance and

de-risk the sustainability transition, and that policies reward good practices and approaches

tailored to specific needs.

• Enacting measures related to sectoral support.

• Reviewing and strengthening the toolbox to better manage risks and crisis, as well as

reducing strategic dependencies and derisking supply chains.

• Continuing the simplification of the policy, notably via digitalisation, to contribute to the

competitiveness of EU farmers while preserving the contribution to societal objectives.

147 COM (2025) 872. 148 COM (2026) 310.

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• Promoting gradual integration of enlargement countries into the single market, particularly

through their adoption of EU product and production standards, to prepare for and

effectively address the challenges and reap the opportunities of enlargement.

• Continuing targeted pre-accession assistance for agriculture and rural development, such

as under the current Instrument for Pre-accession Assistance for Rural Development

programmes, in the post-2027 period, and extending the list of beneficiary countries to

cover all enlargement countries and target the support to those farmers, rural food

processors and other eligible beneficiaries who need it the most.

• Providing capacity-building and pre-accession technical assistance to the enlargement

countries.

The proposals for the 2028-2034 MFF package already address several of the above

orientations such as the transition payments, the new cascading mechanism for crisis measures,

the doubling of the agricultural reserve now named “Unity Safety Net”, the streamlining of

sectoral support covering more sectors.

5.3 Food safety, veterinary and phytosanitary policy

The EU is globally recognised for maintaining the highest standards on food safety and

producing high-quality food. Enlargement of the EU offers significant benefits for both current

and future Member States. However, to safeguard and strengthen these standards and protect

our way of life, coordinated actions, common investments and joint reforms are necessary in

enlargement countries to accelerate progress in this field.

A well-structured and sustainable system of official controls must be in place to safeguard the

implementation of the EU acquis in the areas of food and feed safety, animal health and

welfare, plant health and protection, genetically modified organisms (GMOs) and the

protection of consumers’ rights. Appropriate resources are needed for a network of public

authorities operating in all relevant sectors, staffed with competent and trained personnel to

perform the official controls and supported by the necessary infrastructure including official

laboratories and border control posts that complying with the EU requirements.

5.3.1 Impact of enlargement on the level of protection, food safety, veterinary and

phytosanitary policy

The EU stands to benefit from upholding its food safety, veterinary, and phytosanitary

policies in an expanded EU. Enlargement countries represent significant imports of agricultural

commodities into the EU (EUR 16 billion in 2022). In 2022, these imports were primarily

plant-based (95% of the total value). Ukraine is also a notable exporter of poultry meat and

eggs. Overall, the significant size of Ukraine’s agricultural sectors will present distinct

challenges in the context of enlargement.

For the expanded Single Market to function properly, trust between and in national authorities,

their official control systems, including at the new external borders and the effective

enforcement of EU policies on food safety, animal and plant health is essential to ensure

continued food and feed product safety as well as free movement of animals, plants, and related

products.

To ensure the current level of protection, it is vital for new Member States to ensure a strong

and sustainable capacity within the competent authorities managing the authorisation of

regulated products that are used in the agri-food sector, such as veterinary medicines, pesticides

or biocides. The same applies to the control of foodborne zoonoses and to the implementation

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of the EU’s One Health policy actions that ensure prudent use of antimicrobials in animals and

addressing antimicrobial resistance.

Additionally, the animal health status in the EU might be affected by diseases as rabies, highly

pathogenic avian influenza and African swine fever, particularly among large livestock

populations. This is critical as most EU trading partners do not recognise or properly implement

regionalisation. New Member States need to elevate their standards to avoid posing public and

animal health, environmental, trade and reputational risks to the EU.

New Member States must put in place an efficient system of official controls related to the

protection of animals at farm, during transport and at the time of slaughter and killing. In this

regard, certain farming sectors would need to consider investment costs for modernisation to

comply with the EU acquis on animal welfare (e.g. protection of laying hens, broilers, calves

and pigs).

Participation of enlargement countries as observers in expert groups, such as the Animal

Welfare Expert Group and the EU Animal Welfare Platform, has started to foster effective

policy implementation, and to avoid potential future distortion of competition and

fragmentation of the internal market due to different animal welfare practices.

Budgetary aspects

Overall, there are areas in which the effective implementation of the EU acquis by new Member

States would depend partly on adequate support from the EU level. These areas are listed

below:

• Plant health, to ensure the same level of protection and standards as the EU-27 for the

protection of crops, fruits, vegetables, flowers, ornamentals and forest from quarantine

pests.

• Plant and forest reproductive material to deliver the quality standards required by EU

legislation.

• Plant protection products, to ensure effective protection and fair competition via

competent authorities that have sufficient human and technical capacities; maximum

residue levels, to ensure the same level of protection and effective control at the EU’s

external borders.

• Ensuring a high level of protection for animal health via adequately staffed and

competent authorities.

• Infrastructure upgrades to ensure the modernisation of the agri-food sector, particularly

establishments producing food and feed and the strengthening of official controls.

• Infrastructure upgrades to comply with EU legislation and ensure compatibility with

Europe-wide IT systems and databases, e.g. rapid alert systems. Building or improving the

border controls posts in the EU’s future borders. Improving the official laboratory network

to cover the EU requirements on analysis and to reach the necessary quality of laboratory

results (e.g. for accreditation of labs, selection and characterisation of methods).

• Surveys to prevent and manage outbreaks of pests, certification, infrastructure for food

safety and high sustainability standards.

Currently the Food Chain strand of the Single Market Programme supports the surveillance,

eradication or containment of animal diseases, zoonoses and plant pests, actions for fighting

antimicrobial resistance and reduction of food waste, IT system developments, updates and

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integration, and expert trainings through Better Training for Safer Food Programme149. In

addition, almost all enlargement countries are associated to the Food Chain strand of the Single

Market Programme through veterinary programmes on highly pathogenic avian influenza,

African swine fever and rabies.

Under the current funding rules, the budgetary impact and needs, would not be linear, as new

Member States may initially have a lower sanitary status than the EU-27 (e.g. for veterinary

matters and knowing that none of the enlargement countries has eradicated Mycobacterium

tuberculosis complex or brucellosis, and only few have been officially declared free of rabies

in their territories). For plant health, there would be increased risks due to the increased size of

the agricultural sector. Enlargement would therefore require an adequate budget for food safety,

veterinary and phytosanitary policies.

Funding needs exist also regarding support to the improving capacity of competent authorities,

upgrading laboratories (implementation/development of national reference laboratories and

other official laboratories) and setting up or completing the system of safe collection and

disposal / processing of animal by products. EU reference laboratories and their networks will

also have an increase in budgetary requirements, as regards operational expenditure and human

resources.

Decentralised agencies, (the European Medicines Agency (EMA), the European Centre for

Disease Prevention and Control (ECDC), the European Food Safety Authority (EFSA), the

European Chemicals Agency (ECHA) for Biocides and the Community Plant Variety Office

(CVPO)) would need to provide services to a larger number of countries, which would imply

higher operational and operating costs.

There is also a need to increase the Commission’s own capacity to perform controls (including

audits, fact-finding missions and other assessment activities) to evaluate the implementation of

Union legislation. The intensity of controls required in new Member States will increase the

demand profile significantly and require an upward adjustment of allocated resources. The

instruments proposed under the new MFF targeting health and food safety are designed to

accommodate the association and appropriate participation of enlargement countries, as is

currently the case. These instruments are, in particular the proposed regulations on a European

Competitiveness Fund, on a European Fund for economic, social and territorial cohesion,

agriculture and rural, fisheries and maritime, prosperity and security (National and Regional

Partnership Plans), on a new Horizon Europe programme, on the Union Civil Protection

Mechanism and Union support for health emergency preparedness and response).

5.3.2 Policy gaps, delivery risks and reform orientations

The main gaps relate to the potential lack of capacity of new Member States to implement the

EU acquis effectively.

Enlargement might impact the reflections on the review of the governance of the World

Organisation for Animal Health, of which only the Member States, not the EU itself, are

members.

149 https://health.ec.europa.eu/funding/eu4health-programme-2021-2027-vision-healthier-european-

union/association-agreement-ukraine_enhttps://health.ec.europa.eu/funding/eu4health-programme-2021-2027-

vision-healthier-european-union/association-agreement-

moldova_enhttps://health.ec.europa.eu/funding/eu4health-programme-2021-2027-vision-healthier-european-

union/association-agreement-montenegro_enhttps://health.ec.europa.eu/funding/eu4health-programme-2021-

2027-vision-healthier-european-union/association-agreement-bosnia-and-herzegovina_en

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As regards food safety and sustainability, enlargement would make it more complex to adopt

common approaches, including in legislative processes, and could lead to less overall support

for certain EU policies, primarily on GMOs (as some future Member States have very

restrictive GMO policies in place) and pesticides.

To address the gaps, the EU should provide appropriate technical and administrative

capacity-building support to enlargement countries/new Member States.

The planned modernisation of the EU legislation for on-farm animal welfare should allow

to assess its fitness for enlargement.

5.4 Fisheries and maritime policy

The common fisheries policy (CFP) governs EU fishing and aquaculture by setting catch

limits and conservation measures to ensure long-term sustainability. It aims to maintain fish

stocks, minimise ecological impacts and support fishing communities. Central to the CFP is

the principle of maximum sustainable yield, ensuring healthy fish populations and economic

viability. Annual fishing opportunities are based on scientific advice and multiannual

management plans, addressing ecosystem needs and regional cooperation. Some management

plans are also agreed upon and implemented by regional fisheries management organisation

(RFMOs). For stocks shared with third countries, such as those in the Mediterranean and Black

Sea, this is done by the General Fisheries Commission for the Mediterranean (GFCM), whereas

the International Commission for the Conservation of Atlantic Tunas is responsible for

managing tuna and tuna-like species in the Atlantic Ocean and the Mediterranean Sea. The CFP

also emphasises effective regional cooperation among Member States. Effective monitoring

and enforcement are crucial for CFP implementation.

5.4.1 Impact of enlargement on the EU’s fisheries and maritime policy

Regarding fisheries management, after the accession of Albania and Montenegro, the entire

Adriatic Sea region would be considered exclusively as EU waters. This would make the

process smoother and the approach more holistic. Also, the role of the EU in the Black Sea

would be significantly strengthened with the accession of new Member States bordering the

Black Sea. Relevant enlargement countries already collaborate, including with the EU, in

RFMOs150.

The inclusion of new Member States could alter market dynamics within the EU, potentially

affecting supply chains and competition whilst creating opportunities for market access for

fishery and aquaculture products. However, this would not impact the principles, measures and

functioning of the common market organisation policy, which would remain fit for purpose,

regardless of the size of the EU market and the number of operators.

Expanded external maritime borders would bring both benefits and challenges,

necessitating a careful evaluation of risks and opportunities on a country-by-country and sea

basin basis. Key considerations will include energy security, hybrid and cyber threats,

migration, border control, coastguard cooperation, marine pollution, threats to critical maritime

infrastructure and freedom of navigation. Looking particularly at the Black Sea, enlargement

could have a significant impact on maritime security. Enlargement may also create the need to

150 In the Mediterranean Sea basin, Albania and Montenegro are already full contracting parties of GFCM and are

actively working in close cooperation with the EU for the sustainable management of fisheries stocks. Similarly,

in the Black Sea basin two countries (Ukraine and Georgia) have fishing fleets registered and operating actively

and cooperating with the GFCM.

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negotiate new or more fishing opportunities with third countries under sustainable fisheries

partnership agreements. Ukraine could be interested in fishing in the Atlantic Ocean and

Montenegro has expressed interest in fishing activities in non-EU waters, although currently it

does not have an external fleet.

With more Member States, the EU’s collective bargaining power in international

negotiations and agreements could increase. This would contribute to more ambitious

international fisheries governance agenda with stronger conservation measures and stronger

control policies being adopted globally. The EU would also have more weight in maritime

regional cooperation, where collaboration already occurs with enlargement countries under

the EU Strategy for the Adriatic and Ionian Region and the Common Maritime Agenda for the

Black Sea.

Finally, enlargement could bring new opportunities for research and innovation in maritime

affairs, fisheries and aquaculture, to advance sustainable practices and technologies.

Overall, enlargement is anticipated to have a minimal impact on the CFP. The CFP can be

seamlessly extended to cover new Member States without significant policy adaptations.

Notably, some enlargement countries (Albania, Montenegro, Türkiye, Ukraine) are already

members of some RFMOs and adhere to relevant recommendations, which are also applicable

to Member States. These enlargement countries are thus in the process of aligning their

legislation with EU rules, because of the EU’s efforts to uphold a level playing field

internationally and in RFMOs.

Enlargement is expected to impact specific technical aspects of the CFP, necessitating

targeted modifications in respect to:

• Access to waters, where new access arrangements will need to be made for the new

Member States, detailing the geographical zones and species. This process is complex and

necessitates extensive consultations with the countries concerned.

• Capacity ceilings, where appropriate fishing capacity ceilings will need to be determined

for new Member States to prevent overfishing and ensure sustainable practices. This

process may require significant data collection and analysis, and an agreement on fair and

equitable quotas.

Budgetary aspects

The main impacts on financing and funding needs relate to:

• Maritime regional cooperation: An enlarged EU is likely to have increased funding needs

for projects that are aligned with the objectives of these regional cooperation strategies.

• Maritime spatial planning: In the past, the Commission has supported regional processes

through the European Maritime, Fisheries and Aquaculture Fund(EMFAF) or Interreg

direct expenditure-funded projects (EUR 41 million of EMFF-EMFAF in 2014-2023). For

regional cooperation to work well, such projects should also involve new Member States.

The Commission’s ongoing evaluation of the current EMFAF funding and the CFP (concerning

Member States only) will help determine the best use of the budget available in the next

programming period. The results of the CFP evaluation were published in April 2026151.

Enlargement countries cannot use EMFAF support running until 2027.

151 SWD (2026) 120.

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In the Commission proposal for the 2028-2034 MFF, the CFP would be implemented under

National and Regional Partnership Plans, allowing for a more flexible, ambitious and impactful

approach to reach the EU’s policy priorities, including for new Member States.

New Member States will also be responsible for implementing the EU Maritime Security

Strategy (EUMSS), specifically through the actions listed in the EUMSS Action Plan. Under

the EMFAF (heading on maritime surveillance) Member States were able to request support to

reinforce maritime surveillance, including via establishing connections to the Common

Information Sharing Environment for the maritime domain (CISE). In the new MFF, maritime

security and surveillance as well as regional cooperation can be financed through the National

and Regional Partnership plans, as well as via the European Competitiveness Fund.

5.4.2 Policy gaps and delivery risks

In principle the CFP is expected to continue delivering results after enlargement, without the

need for major policy changes. The main gap in this policy area might be the potential lack

of preparedness by enlargement countries to align their legislation to EU rules and to join the

fight against illegal, unreported and unregulated fishing, a key strand of the CFP.

5.4.3 Reform orientations

Considering the potential preparedness gaps in new Member States, efforts by the

Commission will be especially needed in: (i) the control, monitoring and inspection of fishing

activities; (ii) the enforcement of fisheries legislation; and (iii) the fight against illegal,

unreported and unregulated fishing. Additionally, specific support from the Commission

appears necessary, particularly in aquaculture, to ensure that its growth in new Member States

aligns with EU policy objectives, coordination and planning. Support can also cover market

surveillance, phytosanitary controls and maritime cybersecurity. Future Member States will

need guidance to implement the EUMSS, including for their integration into the Common

Information Sharing Environment for the maritime domain (CISE). For the moment CISE is

open only to Member States.

The future Black Sea maritime security hub will leverage the contributions of EU and Black

Sea countries, thus delivering strengthened maritime security and safety, and protection of

critical maritime infrastructure and of the marine environment, in an expanded EU. A roadmap

is being prepared, in collaboration with relevant services, and with the involvement of Member

States. The hub will promote maritime situational awareness and information sharing on the

Black Sea, real-time monitoring from space to seabed, and early warning of potential threats

and malicious activities. It will aim, among other things, to: (i) broaden coast guard

cooperation; (ii) gives Ukraine and like-minded littoral states access to EU information-sharing

platforms and services by EU agencies whenever possible; and (iii) monitor critical maritime

infrastructure, including submarine cables, offshore installations, gas and wind energy

operations off the Romanian and Bulgarian shores, and related maritime capabilities.

Rather than major policy changes, technical modifications to the CFP are needed to include

capacity ceiling for new Member States and adopt transitional rules (ordinary regulatory

procedure). Additionally, introducing permanent cessation, where appropriate, can serve as a

measure for new Member States to adjust and reduce their capacities in line with the existing

CFP.

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6. EXTERNAL RELATIONS - A STRONGER EU IN WORLD AFFAIRS

6.1 Common foreign and security policy

The European Union’s Common Foreign and Security Policy (CFSP) forms an integral part of

its external action152 . The CFSP seeks to preserve peace, reinforce international security,

uphold international law, promote multilateralism, as well as boost international cooperation.

It aims to promote democracy, the rule of law and human rights and fundamental freedoms.

Based on the principles and objectives set out in the Treaty, the European Council identifies

the strategic interests and objectives of the EU. UN Security Council Resolutions, notably the

authorisations providing for executive actions, are also an important legal basis for CFSP

actions.

6.1.1 Impact of enlargement on common foreign and security policy

Enlargement is likely to have a significant impact on the future of EU foreign policy, security

and defence. It will also impact economic and trade relations.

An enlarged EU would mean:

• a bigger, stronger and more influential EU in the world;

• new external borders and a new immediate neighbourhood;

• Member States with recent experience in fighting back foreign aggression and managing

post-conflict challenges;

• potentially new and more diverse strategic and geopolitical interests among Member States;

• new capabilities for the Common Security and Defence Policy (CSDP), increasing the

military, industrial and capability basis, but also new security needs and commitments (see

dedicated section); and

• if current practices are maintained, reaching unanimity would become more challenging,

notably on the main CFSP tools, consisting of restrictive measures, CSDP operations and

missions and military assistance measures, due to increased diversity of Member States’

positions.

There are also areas where adaptations of current practices and procedures are needed to

ensure capacity to handle a new geopolitical reality. This will include extended external borders

and migratory pressure, as well as unresolved conflicts.

Mixed agreements153 require the practice of common accord within the Council as well as

ratification in accordance with the constitutional legal orders of Member States. With an EU

membership of over 30 countries, difficulties in concluding such agreements may become more

pronounced. Crucially, this would make the need to move away from unanimous decision-

making in Council even more relevant to ensure the EU positioning as a strong foreign policy

actor.

It will also become more challenging for the EU to rely on the common position of its Member

States in the field of external representation, particularly in cases where Member States are

required to act in the interest of the Union in areas falling under EU competences (e.g. when

152 Defined in Title V of the Treaty on the European Union (TEU) and Part Five of the Treaty on the Functioning

of the European Union (TFEU). 153 As regards international agreements, in areas of external competence that are shared between the Union and

the Member States (such as the areas of environment, consumer protection and energy), the Council’s predominant

practice has been to conclude such agreements as ‘mixed’, whereby Member States are separate contracting parties

alongside the EU.

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rules of international organisations do not allow the EU to be a party or to be represented in a

body of the organisation).

a) Overall CFSP alignment

Alignment with the common foreign and security policy is a strong signal of enlargement

countries’ strategic choice. Enlargement countries’ alignment reinforces the EU’s global

influence and security already during the accession process, as it adds to the scale, reach and

effectiveness of EU CFSP. At the same time, it has the potential to positively influence the

countries’ own security. Alignment is especially important for restrictive measures, not only as

a political signal, but also because they are more effective if applied widely.

Alignment, including by becoming a Party to the Rome Statute remains insufficient among

certain enlargement countries. Albania, Bosnia and Herzegovina, Montenegro and North

Macedonia maintain full alignment with the CFSP154, while Moldova and Ukraine have an

advanced level of alignment. Kosovo continues to fully align voluntarily. Georgia and Serbia

still have significant progress to make. Georgia and Türkiye’s alignment rates remain low.

Substantial policy alignment issues need to be addressed as part of the enlargement process,

and not after. Cooperation should be underpinned by EU values, mutual trust and constructive

relations, while fully respecting the strategic and security interests of the Union and its Member

States.

b) EU borders and neighbourhood

New and extended borders

An enlarged EU would see significant extension of the external border with Russia and

Belarus –roughly doubling in length. There would be new borders with Armenia and

Azerbaijan, thus expanding the EU’s neighbourhood towards Central Asia.

Such extension of the external borders would provide new opportunities to improve the control

of goods and people. It would also come with new challenges including in the areas of

organised and cross-border crime, drug trafficking, prevention of irregular migration, migrant

smuggling and trafficking in human beings.

A longer border with or exposure to Russia – in Ukraine, Moldova, Georgia – could also

significantlyincrease the EU's exposure to Russian influence and interference. This would

intensify security threats and strategic challenges. Russia already deploys different forms of

traditional and hybrid campaigns such as the instrumentalisation of migrants against the EU

border155, cyberattacks targeting critical infrastructures and FIMI and disinformation to polarise

societies, attack EU values and undermine democratic institutions. At the same time Ukraine’s

and Moldova’s unique experience in countering Russian aggression and relentless hybrid,

including cyber and FIMI, attacks could also benefit the enlarged Union and contribute to its

security. Ukraine’s lessons could directly inform the EU’s policy- and law-making in respective

areas and help the EU boost its longer-term resilience.

The EU enlargement to include Ukraine, Moldova and Georgia may raise the need for new

cross-border cooperation mechanisms, with countries becoming immediate EU neighbours

154 Statements by the High Representative on behalf of the EU and Council decisions on restrictive measures. 155 Member States bordering Belarus reported over 8.000 irregular border crossings last year, with over 28.000

irregular border crossing attempts prevented.

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with e.g. Armenia and Azerbaijan, offering new opportunities, such as the completion of the

Trans-Caspian Trade Corridor (see below).

In addition, the EU’s policy towards Russia could be affected by more pronounced views

among the future Member States.This could notably concern those that have been suffering

under Russia’s war of aggression (Ukraine) or intensified hybrid campaign (Moldova,

Ukraine). On the other side, there are countries that still maintain close economic and political

relations with Russia (particularly Serbia).

Russia’s war of aggression against Ukraine has a geopolitical impact on the region and

reshaped Europe’s security architecture. In this context, Ukraine's EU accession has become

a shared geostrategic priority, both for Ukraine and for the EU.

Finally, EU enlargement has the potential to hold significant strategic implications for the

unification of the EU's geopolitical space from the Baltic Sea to the Black Sea and to the

Eastern Mediterranean. It would not only deepen European integration but also strengthen

the EU's collective security, economic resilience, and political influence in regions marked by

geostrategic competition. For enlargement to contribute effectively to this objective, it must

remain firmly anchored in the Union’s shared values and principles, while fostering

commitment to advancing the Union’s and its Member States’ collective interest. It can create

a more cohesive and contiguous strategic space, enhancing its ability to address shared

challenges such as energy security, migration, and cross-border cooperation. A unified strategic

space would reinforce the EU's role as a global actor, ensuring stability and prosperity, while

countering external pressures and fostering long-term peace and development.

New neighbourhood priorities

Significant effects will only materialise in the long term, as new Member Stateswill transition

to the status of 'development partners'. It is unlikely that new Member States will be able to

devote significant budgets or national development policies during the initial years after

accession. Finally, since development cooperation is a shared competence, no changes in the

regulatory framework are in principle to be expected156.

However, neighbourhood policy and priorities evolve continuously and may in any case be

subject to further revision by the time the new Member States will join. Unresolved conflicts,

and bilateral disputes as well as ethnic issues that could complicate relations among (current

and new) Member States and between Member States and new neighbouring countries must be

factored in our policy and to the extent possible addressed timely. Regional integration and

cooperation would need to be rethought to reflect a new broader scope. This means further

strengthening EU’s partnerships with Central Asia and the South Caucasus.

Regional cooperation programmes could be adapted for the new neighbourhood reality,

notably in Central Asia. In line with the Global Gateway strategy, infrastructure projects in the

areas of energy and transport, such as the Trans-Caspian Trade Corridor, could receive further

support and funding from the EU Member States for example. With a target of 13 days of transit

time and over 850 000 containers shipped annually by 2040157, the corridor could significantly

boost Europe-Asia trade and the economies of the transit countries.

This would opportunely complement the EU global efforts on the matter, at a time where the

European Union strengthens its partnerships with the countries in North Africa, the Middle

East and the Gulf, including through triangular cooperation through Global Gateway projects

156 In accordance with Article 4(3) and (4) TFEU, the exercise of the EU’s parallel competence must not prevent

Member States from exercising their own competences. 157 Data from the EBRD study.

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for the Mediterraneanor the India-Middle-East-Europe corridor. The future EU Member States,

which will be directly or indirectly connected to these corridors, notably through the TEN-T

networks or under the Black Sea Strategy, will increase the potential and opportunities of all

these projects.

At the same time, the EU’s enlargement towards the East could be perceived by Russia as a

further weakening of its own position, in what used to be a traditional Russian zone of

influence.158 Given its influence in the South Caucasus and Central Asia, notably through the

Russia-led Eurasian Economic Union and the Collective Security Treaty Organisation, Russia

could increasing its pressure and (mis)use its leverage to discourage any further EU

enlargement and/or deepening of partnerships. China’s growing alignment with Russia further

strengthens this dynamic, alongside Russia’s ambitions to create a new Eurasian security

architecture.

The presence of small groups of ethnic minorities of Central Asian populations in some

enlargement countries, as well as minority groups from enlargement countries living in Central

Asian countries add a new potential dimension to future relations, and thus to the EU policy

towards the region.

c) External influence

Russian influence/presence in the enlargement countries and immediate neighbourhood

Enlargement would directly challenge Russia’s influence, as the accession negotiations would

require countries like Georgia and Serbia to fully align with CFSP and to the EU acquis (for

example, on sanctions, energy, trade, foreign investments, visa policy) and to end a series of

agreements with Russia (i.e. gas supply with Gazprom in Serbia).

Russia historically maintained influence particularly in parts of Eastern Europe and in the

Western Balkans and South Caucasus. Russia has used a ‘targeted investment/high gain’

approach to influence these countries, leveraging energy dependence, trade 159 , military

presence 160 and foreign information manipulation and interference. Russia is expected to

continue trying to exert influence on a large scale, particularly in Ukraine and Moldova and in

158 In the Caucasus, Armenia remains heavily vulnerable to Russia’s influence due to its dependency on Russia’s

energy (Gazprom Armenia owns Armenia’s entire gas distribution infrastructure), the presence of Russian military

and due to the Armenian diaspora in Russia (3 million). Russia is also Azerbaijan’s third largest trading partners

and first country for Azerbaijan’s imports (18.3% of all Azeri imports). 159 In 2024 Russia was the 4th largest world trade partner for the WB6, with 2.2% of total trade exchanges (EU –

1st place with 65.3%, China – 2nd place with 9.8%, Türkiye – 3rd place with 6%), Eurostat figures,

https://webgate.ec.europa.eu/isdb_results/factsheets/region/details_western-balkans-6_en.pdf.

Russia represented the 5th largest world trade partner for Moldova with, 3.7% of total trade exchanges (EU – 1st

place with 53.7%, Ukraine – 2nd place with 13.1%, China – 3rd place with 8.1%, Türkiye – 4th place with 6.9%),

Eurostat figures, https://webgate.ec.europa.eu/isdb_results/factsheets/country/details_moldova_en.pdf

Russia represented the 3rd world partner for Georgia with 11.1% of total trade exchanges (EU – 1ST place with

20.9%, Türkiye 2nd – place with 11.1%). Eurostat figures,

https://webgate.ec.europa.eu/isdb_results/factsheets/country/details_georgia_en.pdf

Russia represented the 10th largest world trade partner for Ukraine with 1.8% of total trade exchanges (USA –

1st place with 16.7%, China – 2nd place with 14.6%, UK – 3rd place with 10.1%, Switzerland – 4th place with

6.4%, Türkiye – 5th place with 4.1%, Norway – 6th place with 3.6%, Japan – 7th place with 2.6%, South Korea

– 8th place with 2.6%, India – 9th place with 2.2%). Eurostat figures,

https://webgate.ec.europa.eu/isdb_results/factsheets/country/details_ukraine_en.pdf 160 E.g. remnants of the 14th Guards Army stationed in the territory of the break-away region of Transnistria

(Moldova) and military bases (unknown number) in Abkhazia and South Ossetia (Georgia).

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some parts of Western Balkans. This influence will among others consist of information

manipulation and interference.

In terms of presence of the Russian citizens in enlargement countries, Serbia, Montenegro and

Georgia have witnessed surges after the start of Russia’s full-scale invasion of Ukraine in 2022.

In Serbia, Interior Ministry figures from January 2025 refer to more than 48 000 Russians

holding temporary residence permits. The fast-track acquisition of visa-free travel rights to the

EU for nationals of Russia by granting them Serbian citizenship poses potential security risks.

While Moldova has taken important steps to free itself from the energy dependency on Russia,

the region of Transnistria remains highly dependent on Russian-paid gas supplies.

In the Western Balkans, Russia's energy influence is greatest in Serbia, North Macedonia

and Bosnia and Herzegovina, where in 2024 it supplied from 76% (Serbia) to almost 100 %

(Bosnia and Herzegovina, North Macedonia) of gas needs and owns several commercial assets.

Türkiye also continues to import significant amounts of oil and gas from Russia and cooperates

with Russia on the development of nuclear energy.

The disinformation spread by the Russian-sponsored media outlets in Serbia is affecting public

opinion also in neighbouring countries. Russia is likely to continue using hybrid tactics

including FIMI, including by engineering new issues of difference between the EU and the

countries in question. These efforts might seek to foment distrust towards the EU among

different population groups, potentially leading to increased regional tensions and further

attempts to obstruct enlargement. Russia’s attempts to manipulate the public debate in

enlargement countries so far show the likelihood of further foreign information manipulation

and interference incidents.

The European External Action Service’s strategic communication task forces dedicated to

Eastern Europe and Central Asia and the Western Balkans have been actively working since

2015/2017 to monitor, analyse and respond to FIMI attempts targeting the EU interests and

policies in the two regions. The task forces have been also engaging in strengthening the EU’s

strategic communication towards the regions and in communicating the benefits of EU

enlargement to EU-based audiences. As the enlargement process advances, there will be a need

for scaling up and deepening this line of work.

In the Black Sea region, the establishment of a network for joint response mechanisms could

be considered to reduce the space for FIMI and disinformation campaigns, including in rural

and border areas. This could draw inspiration from the EU Rapid Alert System the network

where EU Member States and EU institutions share information and coordinate responses to

FIMI.

China’s influence/presence in the enlargement countries and immediate neighbourhood

Enlargement may have a considerable impact on EU-China relations and on the

implementation of the EU’s China policy. The EU is seeking to de-risk and strengthen

economic security, tackle the heavily imbalanced economic relationship with China and unfair

Chinese trade practices and address China’s continuous and growing support to Russia’s war

of aggression against Ukraine. Currently, only Serbia maintains a comprehensive strategic

partnership with China, spanning economic, political and security domains161.

China is a major trading and investment partner for most of the enlargement countries (who

are in most cases running substantial trade deficits). China has invested heavily in several of

161 Serbia is the only country in Europe that is purchasing advanced weapons systems from China and China has

overall become Serbia’s main arms supplier.

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these countries, notably in costly infrastructure projects through its Belt and Road Initiative162.

Many enlargement countries have accrued substantial public debt to China. This creates

economic dependencies.

China has been building its presence in the information environment, including in the EU’s

enlargement and neighbourhood regions, through increased media presence, elite capture,

economic incentives (positive and negative and including leveraging on trade and business

relations), information suppression and use of overseas Chinese communities.

China continues expanding its state-controlled media footprint including through an increasing

number of social media channels or soft power instruments (among which the Confucius

Institutes).

The enlargement process is and will remain a target of information manipulation and

interference campaigns by Russia, China and their local proxies.

d) Sanctions

EU enlargement is likely to have a significant impact on the related decision making on CFSP,

including on restrictive measures (sanctions). As a general principle, EU unanimity is required

for the adoption of EU sanctions and for their periodical renewal.

New Member States would need to adopt and implement all existing EU sanctions (including

trade sanctions and around 6 000 listings, some of which concern citizens of the current

enlargement countries) upon accession. Enlargement countries are required to align with prior

EU sanctions by the time of accession.

As the EU expands, it is likely to become increasingly heterogeneous, with new Member States

bringing their own foreign policy orientations, economic/industrial interests, historical

relationships, and political priorities to the table. On the one hand, when it comes to trade

sanctions, this diversity may lead to more complex and nuanced process of arriving at

unanimous decisions. An enlarged EU may therefore struggle to achieve consensus on

sanctions, potentially weakening their overall ambition and effectiveness as a CFSP tool. On

the other hand, if the EU can overcome these challenges, their impact could be amplified by

the increased economic weight and global reach of a larger EU.

A larger EU would also have a beneficial effect on reducing jurisdictions available to malign

actors to circumvent trade sanctions via non-EU countries. As part of the EU's acquis, new

Member States would be bound to implement EU sanctions, thereby closing potential loopholes

that could be exploited to undermine also the EU’s sanctions effectiveness.

New Member States would also be entitled to propose new measures, including those currently

adopted only at national level. Note that Ukraine currently has over 23 000 national listings in

place163. New Member States would bring along expertise and knowledge of certain geographic

areas which is often an asset in preparation of new measures.

Furthermore, the EU maintains five sanctions regimes164 in support of Ukraine, two in support

of Moldova, and one in view of the situation in Bosnia and Herzegovina and one in response

162 For example, the Bar–Boljare Highway - Section Smokovac-Uvač-Mateševo in Montenegro. The first 41-

kilometer-long phase was built by China Road and Bridge Corporation with a loan from China’s Exim Bank. Or

the Belgrade Centre–Stara Pazova railway and the Novi Sad–Subotica-Kelebija (state border) railway (both

sections of Belgrade-Budapest railway) both financed through a loan by Chinese Exim Bank. For more

information: https://www.geodata.it/en/sectors/portfolio-road/item/barboliare.html. 163 https://drs.nsdc.gov.ua/ 164 As of March 2025.

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to Türkiye's unauthorised drilling activities in the Eastern Mediterranean. Some of these

regimes would need to be closed, revised, or ‘transferred’ under a different sanctions

framework (e.g. the Russia’s destabilising actions regime or EU Global Human Rights

Sanctions regime), possibly still before accession.

e) Multilateral and human rights

In certain contexts, the EU might benefit from representing a larger membership in

negotiations/decisions in international fora, provided there is a united EU position. In many

multi-lateral contexts, every vote counts. Most enlargement countries already fully align with

the EU statements and voting positions in multilateral fora including in the UN General

Assembly (UNGA), UN Human Rights Council, Council of Europe or the Organization for

Security and Cooperation in Europe (OSCE). EU enlargement would hence not significantly

change the support for EU initiatives or priorities. At the same time, the EU’s internal position-

making is likely to become more complex.

The enlarged EU would however benefit from wider participation of EU Member States in two

different regional groups, with an impact on the selection of members of the governing bodies

in UN fora. There might also be an opportunity to have increased representation for EU

Member States in the governing bodies or office holder functions, which could translate into

an increased influence/information flow. The enlarged EU would increase its geopolitical

weight and would benefit from expanded diplomatic networks of newly acceding Member

States.

The potential additional difficulties to reach the required EU consensus in the Council and

locally in EU coordination led by the EU Delegations on conclusions, statements and EU

positions for negotiations in international organisations would need to be addressed, given the

persistent lack of alignment by some enlargement countries with important foreign policy and

human rights topics.

f) EU diplomatic presence in enlargement countries

On accession, the nature and function of the EU presence in enlargement countries will change.

The EU Delegations will be turned into Commission Representations. This would affect the

number of staff as well as their status (they would no longer be diplomatic staff in a non-EU

country), institutional origin (Commission rather than EEAS staff) and function

(communication, promotion of internal policies, etc. rather than diplomatic or assistance

activities). However, the diplomatic presence in the new neighbouring countries could be

scaled up to address the evolving political/geographical challenges and the policy priorities of

the EU external action.

The overall review of the EU network of representations, in terms of presence, function and

numbers and categories of staff involved will also have budgetary consequences, including in

relation to infrastructure and security requirements. This would have to be carefully assessed

with a view to generate possible efficiency gains. For example, there can be opportunities to

identify further synergies where there is an EU Special Representative office.

Budgetary aspects of external action165

165 To avoid repetitions this budgetary section includes also other external policies such as economic security and

trade policy, the policy aspects of which will be discussed in separate chapters further below.

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In the MFF 2028-2034, Global Europe,the proposed new external action financing instrument

will allow the EU to offer targeted support to our partners, combining all available instruments

in the EU’s financial toolbox into a comprehensive package, adaptable to the specific needs of

each partner and our mutual interests124. Enlargement countries will benefit from technical

assistance and financial support for delivery of reforms, and support to strategic investments

to help them progress on their path to join the Union and accelerate economic convergence

even before joining the Union.

The proposed Global Europe instrument consolidates the EU’s external action financing, into

a single instrument, with enlargement countries, as well as Neighbourhood East partners

covered under one pillar (the Europe pillar). This will allow the Union to better react to

changing geopolitical realities (such as enlargement countries backsliding on democratic

reforms) than under the current MFF, where these countries are covered by two distinct

instruments (IPA III and NDICI). Within the Europe pillar, Global Europe incorporates

performance-based orientations for all enlargement countries and Eastern Neighbourhood

countries, in its design, which avoids the need for creating ad hoc facilities’. It is based on a

mix of financial and policy tools, which would allow for a stronger performance orientation,

including financial support for the delivery of reforms and investments (through non-repayable

support and loans), gradual integration into the single market and capacity building and

alignment with the EU’s body of law. Stronger conditionality for EU funds is proposed to be

provided by linking payments to meeting conditions set out in the national performance-based

plans developed by the enlargement countries, which are agreed with the EU. This approach

can help establish a clear link between disbursing EU funds and reform and investment efforts

aligned to the objectives of the Europe Pillar.

In its proposal of Multiannual Financial Framework (MFF) for 2028-2034, the Commission

has proposed a dedicated Ukraine Reserve which will be established over and above the MFF

ceilings and may be mobilised for the sole purpose of support to Ukraine. This support will be

implemented according to the rules of the Global Europe instrument, but the funding will come

on top of the envelope for the Europe pillar.

The instrument for nuclear safety cooperation and decommissioning (INSC-D), merging the

current INSC (external component) and Decommissioning Programme (internal component),

will continue the EU’s commitment to contribute to nuclear and radiation safety in partner

countries. Its aim is to promote high levels of nuclear safety, radiation protection, safe

management of spent nuclear fuel and radioactive waste and the application of efficient and

effective safeguards. This objective will be achieved by transferring EU related expertise and

best practice to the key stakeholders in partner countries, including by building partnerships

with nuclear regulatory authorities and their technical support organisations. The enlargement

countries may benefit from funding under the instrument. The indicative financial envelope for

the implementation of the Instrument for the period from 1 January 2028 to 31 December 2034

is proposed to be EUR 966 000 000 in current prices, while support to Ukraine may be provided

through the Ukraine Reserve.

The upcoming MFF will need to ensure that future Member states are able to take up

responsibilities and be able to implement EU funding as of day 1. Therefore, the toolbox

included in Global Europe should be used to its full extent by the candidates, adapting to the

different needs of the enlargement process166. This is particularly relevant for the performance-

based plans, which will serve as an important preparatory tool for the management of internal

166 Structures for the management of pre-accession assistance will be defined in line with the implementation

modalities used for internal funds to credibly prepare enlargement countries and potential candidates for

accession. These elements will be included in an implementing regulation adopted under Global Europe.

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funds under the NRPPs. The recently adopted Communication on the financial package for

Montenegro outlines the transition from a Global Europe Plan towards an NRPP, ensuring a

smooth transition and continuity of funding and ongoing reform and investment efforts.

6.1.2 Reform orientations

To continue delivering on its global ambitions, the EU needs to be able to take decisions in

a faster and more efficient way. While enlargement would reinforce the need to find avenues

for more flexibility in CFSP decision-making, the need to reform decision-making in CFSP

away from the general requirement for unanimity goes beyond EU enlargement. The collective

aim would be to ensure the credibility, consistency and effectiveness of the EU’s external

action, while ensuring continued Member States’ ownership. In this sense, a debate on a more

efficient CFSP decision-making needs to be held before the future possible enlargements take

place, not after.

To maintain the enlargement momentum and allow for smooth transition of new Member States

into the EU, candidates and potential candidates should be involved in further CFSP/CSDP

cooperation and gradually participate in relevant cooperation frameworks and initiatives. Work

towards this goal is already ongoing in particular with Western Balkans partners.

In particular onforeign information manipulation and interference, a more targeted and robust

response is needed, entailing commensurate resource allocation for information resilience,

including institution building, government-civil society cooperation, media development,

media literacy, bilateral and multilateral cooperation (among enlargement countries and

between them and the EU and its Member States).

In view of enlargement, the High representative in cooperation with the Commission would

need to take steps as regards closing EU Delegationsin the new Member States, ending CSDP

missions and operations and the mandates of the EU Special Representatives, analysing the

resources and assets to be transferred to the future Commission Representation Offices, closing

residual contracts of local staff and other services and infrastructure and relocating EEAS and

Commission expatriate staff as necessary, among others. The preparation of the Union’s

administrative capacity should also take account of the implications of enlargement for the

remaining EU Delegations, including the additional coordination and external representation

demands arising from a larger Union.

6.2 Common security and defence policy

The Common Security and Defence Policy(CSDP)is an integral part of the CFSP. It includes

the progressive framing of a common EU defence policy and aims at allowing the EU to

enhance its military capacities and deploy missions and operations outside the EU. These

missions concern peacekeeping, conflict prevention and to strengthen international security in

accordance with the principles of the UN Charter.

6.2.1 Impact of enlargement on the common security and defence policy and European

Peace Facility

Enlargement would further strengthen the CSDP through better integration of new Member

States in the EU common security and defence policy, structures and instruments. The new

Member States will bring their own experience, resources and capabilities, further reinforcing

EU security and defence. Four of the candidates are NATO allies (Albania, Montenegro, North

Macedonia and Türkiye). At the 2008 Bucharest summit, NATO welcomed Ukraine's and

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Georgia's Euro-Atlantic aspirations for membership in NATO. Georgian authorities do not

currently actively pursue the membership to the EU and NATO, while Ukraine is transitioning

towards full interoperability with NATO.

Accession of Ukraine to the EU should be perceived as a boost for the collective military

capacity of EU Member States. Ukraine has spent EUR 53.7 billion, or about 26% of its GDP

in 2025, on defence. The estimated strength of Ukraine's military is 980 000 soldiers - though

of course the current circumstances are exceptional. Ukraine is also bringing its experience of

fighting an enemy availing itself of the most advanced equipment, arms and ammunition.

Ukraine has a unique battlefield experience and has generated advanced capabilities in

conventional warfare, drones, electronic warfare, in countering hybrid, cyber and FIMI threats,

Ukraine has also strong capacities in developing, testing and scaling innovative defence

technologies. EU-Ukraine security and defence cooperation is deepening, in line with the EU-

Ukraine Joint Security Commitments signed in June 2024. The integration of Ukraine’s and

the EU’s defence industrial sectors is advancing, contributing to strengthening both Ukraine's

defence capabilities and the EU’s defensive technological and industrial base, underpinning

European security. There is also a big potential of engaging the Ukrainian military and veterans

in the EU’s military training programmes and civilian and military CSDP missions.

New Member States will have to be fully integrated in the relevant structures (e.g. European

External Action Service/European Union Military Staff (EUMS)/ Military Planning and

Conduct Capability (MPCC)/Civilian Planning and Conduct Capability (CPCC). Like the

overall CFSP, the most important implications will be on decision-making, which is currently

governed by unanimity. In that regard, it would seem useful to move as much as possible

towards QMV for decisions in the Council. The appointment of EU Special Representatives

legally requires only QMV, although unanimity has traditionally been preferred, with very few

exceptions. For civilian CSDP missions, under Article 48(7) TEU, the European Council might

adopt a decision authorising the Council to act by QMV. For military operations of missions or

the European Peace Facility, no departure from unanimity is possible under the current Treaty.

In operational terms, future enlargement would affect engagement with some of the new

Member States. The ongoing CSDP missions and operations deployed in the territory of some

of the enlargement countries will have to be terminated, as well as the EU Special

Representatives Offices. While some of the actions could be continued under different EU

instruments, CSDP missions and operations can be conducted only outside the EU. This will

be the case for the European Union Force (EUFOR) Operation ALTHEA in Bosnia and

Herzegovina, EU Rule of Law Mission in Kosovo167, EU Monitoring Mission in Georgia, EU

Advisory Mission for Civilian Security Sector Reform in Ukraine, EU Military Assistance

Mission Ukraine, and EU Partnership Mission in Moldova.

Enlargement countries have contributed to CFSP and CSDP missions. Further to their

operational support, new Member States’ experience in countering FIMI will contribute to the

EU’s efforts tostrengthen CSDP missions and operations’ resilience. Ukraine and Moldova’s

expertise addressing FIMI for years could be beneficial to support the monitoring and analytical

capabilities of CSDP missions and operations. Furthermore, their experience addressing FIMI

in conflict-affected environments can also contribute to develop training capacity for

information environment analysis and crisis communication in high-risk area of operation.

167 The discontinuation of the European UnionRule of Law Mission in Kosovoentails a specific difficulty, as the

mission is used as a conduit to support financially the judicial proceedings of the Kosovo Specialist Chambers

(KSC) and Specialist Prosecutor’s Office (SPO) located in a Member State. A different form of funding would

very likely need to be provided in the case of Kosovo’s accession.

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As regards cyber threats and hybrid attacks, the Western Balkans region, as well as Ukraine

and Moldova, are increasingly being target by malicious cyber and hybrid activities, with a risk

of spill-over to the EU. To prevent, deter and respond to such activities, the EU is supporting

enlargement countries in strengthening their resilience (e.g. through capacity building and

supporting legislative and policy developments) and engaging to strengthen their and our

collective posture. The EU holds regular dedicated dialogues (e.g. with Ukraine) and ensures

cyber and hybrid issues are sufficiently reflected in the agenda of broader security dialogues.

Such investment as well as the regular participation of enlargement countries in relevant

Council Working Parties and Cyber Ambassadors meetings will enable new Member States to

be swiftly integrated into the EU’s cyber ecosystem. The EU and its Member States benefit

from the enlargement countries’ experiences in countering hybrid threats (e.g. Ukraine and

Moldova).

The future enlargement may have a positive impact on the EU’s partnerships with

international and regional organisations, as well as on the EU’s engagement in multilateral

fora. For instance, the EU’s enlargement with existing NATO allies will increase the number

of common members of both organisations and will further strengthen EU-NATO cooperation

by improving mutual understanding and increasing the weight of the EU allies in NATO, thus

positively influencing the dynamics of EU-NATO cooperation.

Budgetary aspects

Following enlargement, the termination/transformation of some ongoing CSDP missions and

operations (and some EU Special Representatives) might free parts of the CFSP budget. At the

same time, the enlarged EU, with new security needs, might also require new CFSP actions to

be launched. New members will contribute to the CFSP budget, as part of the EU budget, and

in line with their overall national contributions in the framework of the EU Own Resources

Decision.

Enlargement could translate in higher availability in financial resources in the Global Europe

instrument due mostly to a reduction in the number of missions and operations and of military

assistance measures funded through the European Peace Facility. Ministries, agencies, and

other entities of new Member States could become implementing actors for assistance

measures in countries outside the EU. In particular, the contribution of the Ukrainian Armed

Forces and other state services into the CSDP mission and operation may be substantial. The

new Member States will also have to contribute to the budget of the European Peace Facility.

6.2.2 Reform orientations

As part of a reinforced EU perspective to the enlargement countries, the candidates and

potential candidates should gradually participate in relevant EU structures and programmes

ahead of EU membership. This could include:

• ramping up support for security and resilience in theregion (i.e. Security and Defence

Partnerships, European Centre for Democratic Resilience, EPF assistance measures based

on the orientations set by EU Member States, contribution to CSDP missions);

• increased cooperation to counter the threat of military invasion or aggression;

• tackle destabilising factors such as hybrid threats, including malign third-party influence,

malicious cyber activities, FIMI and disinformation and instrumentalisation of migration

and other types of threats, notably using the Hybrid Toolbox, for instance sanctions,

restrictive measures or the deployment of Hybrid Rapid Response Teams;

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• support for enlargement countries to aligning their legislative and policy frameworks

to counter hybrid threats including FIMI and cyber threats (FIMI Toolbox, Hybrid

Toolbox, and the Cyber Diplomacy Toolbox). This notably includes encouraging partners

to partner around sanctions and statements along the Cyber Diplomacy Toolbox, as well

as restrictive measures in response to Russia´s destabilizing activities, and to further align

with the EU on the ongoing work around norms going on in international fora such as the

newly established permanent UN Global Mechanism housing multilateral discussions on

responsible state behaviour in cyberspace;

• leverage the SAFE instrument and European Defence Industry Programme (EDIP)

including Ukraine Support Instrument (USI) for collaborative opportunities to invest into

new defence technologies;

• prevent the carry-over of unresolved bilateral issues and mitigating its effects in an

enlarged EU.

• strengthen the modernisation, capacity development and geopolitical alignment of the

armed forces of enlargement partners including through the strategic use of European

Peace Facility assistance measures based on the strategic orientations set by EU Member

States, as is already the case for Moldova, Albania, Bosnia and Herzegovina, Montenegro

and North Macedonia, as well as the Balkan Medical Task Force. This may also increase

to enhancing operational effectiveness and regional integration.

6.3 European defence readiness

6.3.1 Impact of enlargement on European defence readiness policies

Enlargement countries, in particular Ukraine, have rich experience with their defence being

challenged with full scale war and invasion by Russia which has provided them with valuable

insights and expertise that can be shared within the EU. However, to seamlessly integrate into

the EU's defence structures, markets and supply chain, these countries would need to adapt

their industrial bases to a certain degree as their defence industries are affected by the specific

gaps and dependencies. This process would have considerable implications for the

development and implementation of defence policies, including defence industrial policies, at

both the national and EU levels.

The full integration of enlargement countries' defence markets into the EU internal market

for defence is likely to be complex and challenging as developing EU internal market for

defence and accession negotiations will be two parallel processes. However, the EU already

undertook several steps and measures bringing in particular Ukraine defence technological and

industrial base (DTIB) closer to EU’s.

The 2024 European Defence Industrial Strategy (EDIS) proposed a range of measures to

encourage Member States to invest more, better, together and European. It aims to create the

conditions for the EU’s defence industry to meet Member States’ demands over time and at

sufficient scale.

The 2025 White Paper for European Defence Readiness 2030 builds on this approach and

offers solutions to strengthen the defence industry by closing important gaps and ensuring long-

term readiness. It also suggests ways for Member States to invest heavily in defence, buy

necessary equipment, and support the industry’s growth over time.

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The strategy aims to not only support European defence industrial readiness, but also to

strengthen Ukraine and Ukrainian DTIB by associating Ukraine to EU defence industry

initiatives and tools, aiming at full membership in the future.

To ensure matchmaking between the Union’s start-ups and innovators and Ukraine’s industry

and armed forces, an EU Defence Innovation Office (which will transition into European

Defence Industry Office) was set up in Kyiv. This office is already delivering and could be

scaled up to provide additional support and profit from Ukraine’s war experience and to further

expand defence industrial cooperation. To stimulate cooperation between the Ukrainian and

the European industry and to foster dedicated information exchange on standards and on

respective lessons learned, the EU also organises EU-Ukraine Defence Industry Forums.

The European Defence Industry Programme (EDIP) is a dedicated instrument which

supports and reinforces our defence industry’s ability to meet the demand of national armed

forces over the next ten years. EDIP and its Ukraine Support Instrument (USI) will provide

the possibility for Ukraine to participate in joint procurement alongside Member States and for

the Ukrainian defence industry to be supported in its industrial ramp-up and in rapid defence

innovation through BraveTech EU initiative which is partly financed by European Defence

Fund (EDF) – BraveTech EU (EDF) and USI BraveTech EU (USI). This will support the

integration of the Ukrainian defence industry to the European DTIB. The EDIP Regulation

entered into force in December 2025 and the EDIP working programme was adopted on 30

March 2026, making available a budget of EUR 1.5 billion for the period 2026-2027 (with 300

mln EUR envelope for USI). This integration will also be increased through Ukraine’s

association to the EDF, allowing for besides support for BraveTech EU to fully participate in

EDF calls for Ukraine entities. It will also help building European Defence Projects of

Common Interest (EDPCIs) with Ukraine, and contribute to the acceleration of work on

Ukraine-inspired industrial collaboration projects, such as Freyja or BliksemEXO, to reinforce

EU’s defence technological and industrial base.

On 27 May 2025, the Council adopted Regulation (EU) 2025/1106 establishing the Security

and Action for Europe (SAFE) through the reinforcement of the European Defence Industry

Instrument. SAFEprovides loans up to 150 billion to Member States to support common

procurements of defence products for their own armed forces and for Ukraine. Through specific

bilateral agreements, SAFE could be opened for the DTIB of other enlargement countries. All

enlargement countries, including Ukraine are eligible to participate in common procurement.

19 Member States have requested SAFE loans. Ukraine was invited to join Member States and

place contracts with EU and Ukrainian defence industry. Ukraine is therefore fully involved in

the SAFE instrument and benefits from it, bringing the Ukrainian DTIB closer to the European

DTIB. This is in line with Commission commitment to treat Ukraine as much as possible as a

Member State in Union programmes supporting defence industry. The EU may conclude

bilateral or multilateral agreements with like-minded countries, namely acceding countries,

enlargement countries other than Ukraine and potential candidates to facilitate common

procurement under the SAFE instrument.

The Preserving Peace - Defence Readiness Roadmap 2030 puts forward specific objectives

and milestones on how to strengthen Europe’s defence capacities by 2030, in particular through

Member States engaging in capability coalitions, launching European Readiness Flagships and

further strengthening the EDTIB. Progress will be measured annually based on indicators. The

roadmap outlines continued support and strengthened cooperation with Ukraine, which

remains Europe’s first line of defence and is key for Europe’s defence effort. Other candidates,

not least because of their geographic position, will also play an important role for Europe’s

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security. Therefore, it is important to consider ways to link them early on with defence

readiness actions.

To boost innovation and the development of new technologies for defence, the European

Commission has adopted the EU Defence Transformation Roadmap, which includes strands

on strong cooperation with the Ukrainian DTIB.

As mentioned above, in 2025 the Commission, in partnership with Ukraine, launched the

BraveTechEU initiative to accelerate defence innovation by building on battlefield-proven

technologies and strengthening cooperation between EU and Ukrainian defence tech start-ups,

scale-ups and SMEs. It provides a new framework for joint development, testing, and

deployment of cutting-edge defence solutions.

In February 2026, Regulation (EU) 2026/467 of the European Parliament and of the Council

of 24 February 2026 implementing enhanced cooperation on the establishment of the Ukraine

Support Loan for 2026 and 2027 (UASL) was adopted, dedicating EUR 90 billion to address

both Ukraine’s immediate macroeconomic needs and its urgent security requirements, with an

indicative split of EUR 30 billion for budgetary assistance and EUR 60 billion for defence

procurement. The conditions for acceding and enlargement countries to participate in UASL

are similar with the ones for participation in SAFE.

Budgetary aspects

There has been a strong growth in industry participation in the European Defence Fund (EDF)

over the past years. This growth, coupled with the increased focus on defence and security in

Europe, has led to an increase in the number of EDF applications, beneficiaries, and

participating regions. This, in turn, will likely result in a growing competition for available

funds. As the EDF Programme Committee holds annual discussion about EDF’s prioritisation

of topics and the allocation of resources, these discussions are expected to be more extensive

due to the enlargement.

The intervention logic of both the Ammunition Production Regulation (ASAP) and the

European Defence Industry Reinforcement through common Procurement Act (EDIRPA)

ceased to exist in 2025 and arebeing replaced by the European Defence Industry Programme

(EDIP)for 2025-2027. In the MFF 2028-2034, these activities will be financed under the

European Competitiveness Fund. The Commission proposal provides the possibility to

associate enlargement countries under strict conditions.

6.3.2 Reform orientations

The EU could seek to:

• Continue the integration of the Ukrainian defence technological and industrial base

into the EU’s base, while benefiting from the unique Ukrainian experience and innovative

edge.

• Strengthen defence innovation, including rapid innovation, in close cooperation with

Ukrainian partners and as outlined in the EU Defence Transformation Roadmap.

• Develop mutually beneficial engagement, cooperation and know how transfer in the

field of security and defence with enlargement countries to promote peace, security and

stability on our continent and beyond, as outlined in the White Paper for European Defence

Readiness 2030 and the European Defence Readiness Roadmap 2030. Provide support to

Ukrainian military’s and veterans’ involvement in relevant EU-level activities.

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• Once the proposed Regulation on Military Mobility is in place it is key that its provisions

will be effectively applied in the accession countries. As outlined in the Joint White Paper,

Ukrainian military mobility corridors shall be effectively connected to the European

military mobility corridors.

6.4 Space capabilities

6.4.1 Impact of enlargement on EU’s space policy

An enlarged EU territory offers strategic geographic positions (e.g. for tracking stations).

Enlargement would give the EU possibility to expand ground infrastructure for global

satellite navigation (Galileo, EGNOS), for the Copernicus Earth observation programme and

for Space Situational Awareness infrastructure 168 . Expanded territorial coverage would

improve the operational integrity of the services and potentially facilitate new international

partnerships.

Enlargement would also enable more efficient use of satellite resources (via pooling and

sharing) and enhance national sovereignty and independence in satellite communications.

The accession of Ukraine could bring added value thanks to the country’s long-term experience

in the space industry, allowing it to develop expertise also evidenced in remote sensing and in

Earth observation satellites.

With enlargement, the EU’s space policy will cover more Member States and increase the

number of companies involved through the procurement process, including for security-

sensitive technologies. This could bolster EU competitiveness in that area.

Enlargement would trigger the need for enhanced external border and maritime

surveillance, as well as internal security monitoring. A longer border with Russia will trigger

also extended use of the Copernicus Security Service. Some of the Copernicus services will

have to cover enlarged service areas. More customers for secure connectivity and the Galileo

Public Regulated Service (PRS) will require additional screening of eligibility of new

participants in procurement. Regarding Govsatcom and IRIS², additional participants would

also reduce the available capacity for other Member States.

Secure access to critical space-relevant raw materials is important for the resilience of EU

space value chains. This aspect has been acknowledged in the Critical Raw Materials Act. Few

of the countries negotiating accession to the EU, such as Ukraine or Serbia, are resource-rich

and have mineral deposits or mining of space-relevant critical raw materials.

The generated data and services and the benefits of the current EU Space Programme mostly

have no geographical boundaries and are generally freely accessible to users worldwide (the

Galileo Open Service, Copernicus data etc.). While some restrictions apply to sensitive data or

services due to security concerns, enlargement is unlikely to have a significant influence on the

programme in the short term. Some exceptions exist however, such as the EGNOS services or

the Galileo High Accuracy Service which provide improved services to EU Member States

plus EGNOS / Galileo Participating States; for such services enlargement may require the

deployment of more stations in the new EU territories. Enlargement would also increase the

geographical area to be covered by Copernicus with localised and specific services for Member

States. In the long term, future enlargement could lead to a larger number of institutional

168 The Space Situational Awareness (SSA) Programme is a critical component of the EU Space Programme,

providing a comprehensive understanding of space hazards that could benefit in several areas from future

enlargement.

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and civil users of space data, particularly in case when space data and services are used to

fulfil requirements set by sectorial legislation.

Budgetary aspects

The accession of new Member States will unlock participation in the current EU Space

Programme and Union Secure Connectivity Programme, and in particular in the future

European Competitiveness Fund opening new avenues for collaboration, including for global

partnerships and innovation. Furthermore, the involvement of additional companies through

the procurement process, including for security-sensitive technologies, could bolster EU

competitiveness.

In line with the EU Space Strategy for Security and Defence and the Niinistö's report, the

Commission’s proposal for the European Competitiveness Fund includes as an additional

component in the next MFF an EU Earth Observation governmental service for enhanced

situational awareness in support of preparedness, decision-making and the action of the EU

and Member States in the fields of security and defence, as well as a service for radio

frequencies interferences and activities for an autonomous and competitive access to space.

It’s worth mentioning that on 9 March 2026 the Council authorised the opening of negotiations

for Ukraine accession to Govsatcom.

6.4.2 Policy gaps, delivery risks and reform orientations

The main impact of enlargement on EU space policies relates to increased user needs and the

need for enhanced security in this domain. In addition, enlargement would require the

potential deployment of new EGNOS or Galileo stations to provide the same services in all the

EU territories. There is likely a need to strengthen the expertise of administrations in

enlargement countries to effectively participate to the governance of the EU Space Programme

(Space Programme Committee, EUSPA Administrative Board).

Considering the current geopolitical shifts, the prospective of enlargements call for a strong

emphasis on strengthening the security of the EU. The 2023 Space Strategy for Security and

Defence already identified the urgent need to devise a revised framework adapted to the

challenges prompted by recent geopolitical changes and which collectively enhances the

resilience of space systems and services in the EU.

Acting on this need, the resilience pillar of the legislative proposal on the EU Space Act169 aims

to create a baseline for resilience applicable to all space segments. A higher level of

cybersecurity of satellites and more resilient space missions will allow space infrastructure to

better withstand cyberattacks and enable space operators to be more prepared and agile when

handling security incidents. With enlargement expanding the size of the internal market, higher

amounts of space-based data will be generated by potentially more spacecraft and space

systems. The resilience rules in the EU Space Act proposal contribute to fine-tuning the EU’s

stance towards preparedness and awareness and allow an adjustment to the dynamics of an

enlarged single market of space activities.

As part of the overall EU policy on critical raw materials, the potential of critical raw

materials for space (and defence) could be further leveraged by the pre-enlargement policies.

Enlargement countries like Ukraine have space (and defence) critical raw materials deposits

such as rare-earths or titanium. Triggering respective import diversification and investments in

mining, space (and defence) grade refining, metalworking and alloying will be considered in

169 Proposal for a Regulation of the European Parliament and of the Council on the safety, resilience and

sustainability of space activities in the Union Brussels, 25.6.2025 COM (2025) 335 final 2025/0335 (COD).

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enlargement discussions. In addition, the Commission proposal for the European

Competitiveness Fund introduces new services and components to enhance the security and

resilience of the EU and Member States as the EU Earth Observation governmental service, a

service for radio frequencies interferences and activities for an autonomous and competitive

access to space.

6.5 Trade policy and economic security

6.5.1 Impact of enlargement on trade policy and economic security and policy gaps

a) Trade policy

Trade policy both projects and contributes to the EU’s economic and geopolitical strength.With

its important economic and geopolitical implications, enlargement would have a significant

impact on trade policy and on relations with trade partners across the world. This would take

place in the current challenging context of rising global tensions and risk of fragmentation of

the global economy. This context makes it even more imperative to safeguard the stability of

the rules-based global trading system with a reformed Word Trade Organization (WTO) at the

core and build new and stronger trade and investment partnerships with third countries.

A larger EU could be a stronger actor in the world and a more attractive trade partner and thus

have more bargaining power when negotiating trade agreements and dealing with trade

partners.

The EU has exclusive competence over its trade policy, which will continue to apply also across

the enlarged EU. However, enlargement may impact that policy in several important ways.

Acceding countries will become part of the EU’s existing trade agreements, which will require

certain adjustments.

EU regulations in the area of trade have direct effect and will hence apply directly in acceding

countries and do not require any transposition.

Impact on the EU’s position in the WTO

The EU itself and all 27 EU Member States are members of the World Trade Organization

(WTO). The EU represents the EU Member States at the WTO170 and holds 27 votes there.

Two considerations stand out. First, some of the enlargement partners are not yet members of

the WTO, which might cause some challenges; and second, certain steps will have to be taken

to ensure consistency between enlargement countries and the EU as a whole.

Regarding enlargement countries who are members of the WTO (most of them), on

enlargement, the EU would not only be expanding its geographic territory but also the number

of votes in the WTO, as the EU holds exclusive competence on common commercial policy

170 The Council common position on Chapter 30 states the following:“The EU is a customs union within the

meaning of WTO provisions. The EU and all its Member States are members of the WTO. In view of the EU

acquis on its common commercial policy, [country] will need to become a WTO member before joining the EU.

Moreover, once a member of the WTO, [country] needs to ensure that its national positions are progressively

aligned with the EU positions, to facilitate the transition to the additional EU membership in the WTO and to

obtain the capacity to implement EU commitments on the day of the accession to the EU. The EU encourages

[country] to step up its negotiations and adopt necessary legislative reforms needed to join the WTO”. The

common position however stipulates that “in case [country] encounters unreasonable blockings in its WTO

membership bid, the EU will return to this chapter, as appropriate”.

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and speaks with one voice in the WTO. EU Member States do retain competences in some

areas, notably relating to the WTO’s budget.

In case of an accession to the EU, the existing tariff schedule of the acceding country that is

already WTO member will be withdrawn, and the EU will have to initiate the relevant General

Agreement on Tariffs and Trade (GATT) procedure for establishing the adapted tariff schedule

of the enlarged customs union. Regarding trade in services and government procurement, the

national commitments and reservations of the enlargement countries under the General

Agreement on Trade in Services (GATS) and the Agreement on government Procurement

(GPA), respectively, will have to be integrated in the EU schedules.

Regarding enlargement partners who are not yet WTO members (Serbia, Kosovo and

Bosnia and Herzegovina), prior to their accession to the EU, the EU should be associated to

and make all efforts to support their WTO accession negotiations, to ensure that the outcome

and the commitments these partners have to make towards the WTO are compatible with EU

law and policy. This is already the case for Serbia as well as Bosnia and Herzegovina, whereas

Kosovo has not applied for WTO membership yet (mainly due to status issues).

The scenario of a possible accession to the EU prior to WTO accession remains untested but

cannot be excluded (in case of possible unreasonable blockings of WTO accession).

Impact on the EU’s bilateral engagement – FTAs and other forms of engagement

For agreements under the EU's exclusive competence, the acceding Member States will be

covered as of the date of entry into force of the accession treaty, given that EU free trade

agreements (FTAs) apply to the territories where EU Treaties apply. This means that the other

party to the agreement will immediately have access to the market of the new Member State(s)

under the conditions set out in the EU’s trade agreement with that country. Therefore, it is

important to conclude all necessary adjustments in advance. For mixed agreements, the new

Member State will need to accede to the agreements.

Any impacts on, and adjustments to, bilateral FTAs would in particular concern specific parts

of FTAs, including: i) schedules for services/investment; ii) procurement commitments which

include member-specific commitments; iii) list of geographical indications; iv) authentic

languages.

Sustainable Investment Facilitation Agreements will also apply to new Member States.

These agreements cover commitments across the EU on transparency and administrative

procedures applicable to foreign direct investment and will not need renegotiation with the

accession of new Member States. Regarding digital trade rules, they are not directly tied to

market access negotiations, as they fall under a purely regulatory title in the EU’s FTAs. Since

no market access or market opening is involved, the focus will be on acceding countries'

acceptance of the EU's regulatory requirements.

Investment agreements between the acceding countries and specific EU Member States must

be terminated no later than at the date of accession (including the effects of any sunset clause

provision). Agreements between acceding countries and non-EU countries, however, would

need to be grandfathered. One notable multilateral investment agreement is the Energy Charter

Treaty (ECT), to which the Western Balkans and Ukraine are members. It will be necessary to

ensure that, similar to their bilateral investment treaties (BITs) with EU Member States, these

countries terminate the effects of investment protection provisions under the ECT with EU

Member States to avoid intra-EU disputes.

Trade defence instruments

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As from the date of accession, existing EU trade defence measures will automatically apply to

the new Member States, while all trade defence measures applied individually by the acceding

countries will automatically lapse. This approach has been consistently followed in all previous

enlargements and follows from the fact that the EU is a Customs Union with common external

tariffs. If an acceding country applies additional instruments such as surveillance concerning

imports from outside the EU, which are not applied by the EU, these instruments will also cease

to apply as from the date of accession.

The Commission usually publishes a notice in the Official Journal informing stakeholders of

this fact shortly before the accession date. Stakeholders have the possibility to request a review

of such measures under defined circumstances, as was the case during the enlargements in 2004

(OJ 2004/C 91/02) and 2006 (OJ 2006/C 297/04).

Regarding the expired steel safeguard, there was no issue because enlargement did not occur

before the expiry of the measure on 30 June 2026. However, Regulation (EU) 2026/1384 of

the European Parliament and of the Council of 17 June 2026 addressing the negative trade-

related effects of global overcapacity on the Union steel market and amending Regulation (EU)

2020/2170 which started applying on 1 July 2026 has a potential impact on enlargement as it

applies to all third countries. The impact of this new measure is nevertheless more limited for

preferential partners of the EU such as enlargement countries, as these partners have access to

additional quantities of tariff-rate quotas compared to non-preferential partners (see in

particular Commission Implementing Regulation (EU) 2026/1457 of 29 June 2026 on the

distribution of tariff quotas opened under Regulation (EU) 2026/1384 of the European

Parliament and of the Council addressing the negative trade-related effects of global

overcapacity on the Union steel market and amending Regulation (EU) 2020/2170).

As for trade defence investigations, these are conducted by the Commission under the

applicable EU Regulations. It is difficult to assess the position that these countries will take

regarding individual consultations on trade defence cases (e.g., supportive, neutral, or not

supportive), which could influence the overall outcome of TDC/SFGC votes.

Dispute settlement

Certain acceding countries have ongoing disputes at the WTO, e.g. Ukraine currently has 16

active cases: 12 as a complainant (including three against EU Member States) and four as a

respondent. Ukraine must abandon all its WTO disputes against other Member States before

joining the EU, as pursuing those disputes at the WTO level after accession to the EU would

be incompatible with the Treaties. Regarding Ukraine’s disputes against other countries, it

should be ascertained first whether it is in the interest of the EU to pursue those disputes. It

may well be that Ukraine has taken legal position the EU does not agree with or that go against

EU’s policy. If necessary, Ukraine should be asked to abandon them. In addition, where the

disputes are worth pursuing, the Commission should assume the representation of Ukraine or,

at the very least, be closely associated.

b) Economic security

The 2023 European Economic Security Strategy (ESS) is built upon three pillars. First,

promoting EU competitiveness; second, protecting the EU from disruption triggered by non-

EU actors; and third, partnering with the broadest range of countries, allowing EU businesses

to diversify and to access centres of growth. The ESS focuses also economic security risk

assessments and mitigation on four initial risk areas: supply chain resilience and energy

security; critical infrastructure, technology leakage and security; weaponisation of economic

dependencies and economic coercion. Building on the ESS, the 2025 Communication on

Strengthening EU Economic Security indicates six initial priority high risk areas where the

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Commission will concentrate its efforts in immediate to short term, in close cooperation with

Member States, industry and trusted partners, which includes also candidate countries171. The

Communication also calls for integrating risks and opportunities for the EU’s economic

security in the Commission’s implementation of policies and programmes with EU’s

neighbourhood and enlargement countries and regions. Notably, candidate countries are on a

path to become future EU Member States, therefore their alignment on economic security

policy as well as gradual integration into the single market, is essential to ensure their

successful accession, while enhancing the EU’s ability to address both existing and new risks.

On the one hand, expanding to new economies will increase the size of the internal market

expand the options for EU companies to produce of certain critical products in new Member

States and less dependent on extra-EU supplies, and will make the EU more attractive to

suppliers and investors from abroad. It will also enhance the resilience of supply chains across

various sectors and open further opportunities for EU businesses, thanks to the resources of

critical materials in the future Member States.

On the other hand, it remains to be seen to what extent the economies that would join the EU

distinguish themselves with research centres and tech leaders in edge technologies that are

relevant for our economic security in advanced technologies (e.g. AI, semiconductors,

quantum, biotech) or in areas that are relevant for our security of supply or resilient supply

chains (e.g. in raw materials, food supplies, in energy sources, etc.). Also, if the enlargement

allows the EU to attract such assets and reinforce our resilience or indispensability in key

supply chains or technologies, certain measures would need to be ensured in these countries in

line with the applicable EU measures, rules and policies, also the TFDI Screening Regulation

(as applicable at the time), in particular research security, protection of technologies and

infrastructure, enforcement of export control, screening of foreign direct investment (FDI) or

other economic security relevant tools.

Economic security risk assessments and mitigation; incorporation of new Member States

The European Economic Security Strategy has established a risk assessment process to identify

vulnerabilities and analyse the impact and likelihood of them materialising. Risks are assessed

across four risk categories referred to above. On this basis, acceding Member States would

have to contribute to the joint risk assessment and adapt targeted and proportionate mitigation

measures in a way that is coherent with the European Economic Security Strategy.

Both risk assessment measures and risk mitigation measures are based on an analysis taking

into account data and economy environment of the 27 EU Member States. Enlargement could

have significant impacts on the nature of EU vulnerabilities and could help to reduce some of

them through strengthening the EU´s capacities. It could, however, also exacerbate some of the

EU’s vulnerabilities if the acceding countries suffer from strategic dependencies in critical

sectors or challenges to resilience of their supply chains, if their critical infrastructure are

vulnerable to physical or cyber-attacks or if their critical technologies are not sufficiently

protected from technology leakage.

Therefore, adaptation of the risk assessments and design of mitigation measures will be needed

to reflect the nature of an enlarged economy its vulnerabilities, and the optimal approach to

risk mitigation. Dynamic alignment will be needed as regards the measures the EU takes as

171 These are: i) strengthening supply chain resilience and counteracting high-risk dependencies in critical goods,

services and technologies, including raw materials and energy security, ii) attracting value-added inbound

investment iii) supporting a vibrant defence and space industrial base and other high-risk industrial sectors, iv)

developing and maintaining leadership across critical technologies v) preventing access to sensitive information