Vastus: Euroopa Komisjoni küsimustik õigusriigi aruande koostamiseks

European Rule of Law Mechanism: input from Member States
2026 Rule of Law Report
The written input from Member States is a key source of information for the annual Rule of Law Report, as clearly set out in the Report’s methodology. As every year, the Commission would hereby like to invite the national contact points to provide their input to the 2026 Rule of Law Report. Based on this input, further targeted questions may follow, as it was the case in previous years, to ensure that the Commission has all relevant information from Member States for the preparation of the 2026 Rule of Law Report. Such further targeted input will be sought in particular in the context of country visits or bilateral contacts, as well as during the consultation on the draft country chapters prior to the Report’s adoption.
The 2026 Rule of Law Report will continue to assess rule of law related developments under the existing four pillars and will follow-up on the implementation of the recommendations to Member States that were issued as part of the 2025 Rule of Law Report. To facilitate the preparation of input by Member States, this year’s questionnaire has been adapted. Member States are asked to provide information about:
(1) developments and measures taken in relation to the recommendations in the 2025 report,
(2) developments that are relevant for updating and following up on the assessment of the topics covered in the 2025 country chapter, as well as any other new developments related to the rule of law.
The input under these points should cover any developments since the adoption of the 2025 Rule of Law Report. The annex to this request for input sets out a checklist/guidelines on relevant topics falling within the Report’s scope to help Member States prepare their input, building on experience from previous years.
Nature of the contribution
The input should preferably be in English and not exceed 30 pages. Relevant legislation or other documents may be referenced with a link (no need to provide the full text). The contributions will be published on the Commission’s website upon explicit consent of the Member States. In order to avoid duplication and excessive administrative burden, please include where applicable explicit references to any relevant contribution already provided by your Member State in a different context (including under Council of Europe, OECD, OSCE and UN bodies or procedures) or to the previous Rule of Law Reports. Contributions should focus on significant developments since the last Rule of Law Report both as regards the legal framework and its implementation in practice.
Type of information to be included
A) Legislative developments
• Newly adopted legislation
• legislative drafts currently discussed in Parliament
• legislative plans envisaged by the Government
B) Policy developments
• Implementation and enforcement of legislation
• evaluations, impact assessment, surveys
• white papers/strategies/actions plans/consultation processes
• follow-up to reports/recommendations of Council of Europe bodies or other international organisations
• important administrative measures
• generalised practices
C) Developments related to the judiciary / independent authorities
• important case law by national courts
• important decision/opinions from independent bodies/authorities
• state of play on terms, nominations and expired mandates for high-level positions (e.g. Supreme Court, Constitutional Court, Council for the Judiciary, Prosecutor General, heads of independent authorities included in the scope of the request for input1)
D) Any other relevant developments
• National authorities are free to add any further information, which they deem relevant; however, this should be short and to the point.
Please also indicate whether the developments reported are linked to the implementation of reforms and investments under the RRP, where applicable.
Please send us your contribution by 23 January 2026 to the following email address: [email protected]. In case you would have any questions or requests for clarifications, please do not hesitate to contact the Commission at the same email address.

Template for input
This template for input indicates the type of contribution sought from Member States for the 2026 Rule of Law Report and provides a suggested format of reply. However, Member States are free to decide on the precise format of their contribution, as long as the key points are covered.
(1) Information on developments and measures taken to implement each of the recommendations addressed to your Member State in the 2025 Rule of Law Report
In the below box, please describe relevant developments and the measures taken with a view to implement the recommendations, following the order of the recommendations as they were addressed to your Member State in the 2025 Rule of Law Report.
Referring to the recommendation on page 15 of the 2025 Rule of Law Report Estonia, which is stating:
“An amendment to the Auditing Activities Act has eased the reporting obligations for civil society organisations. The civic space in Estonia is considered to be open. In 2024, Parliament began discussions on a draft law easing the reporting obligations for civil society organisations by raising the threshold for mandatory auditing requirements for foundations. Previously, any foundation with an annual turnover or asset volume exceeding EUR 15 000 was required to undergo a mandatory financial review. Under the new law, this threshold will increase to EUR 1 million. The law is set to apply retroactively to the financial reports for the 2024 fiscal year. In parallel, some stakeholders have reported issues with funding due to the public spending cuts”

Update: In December 2024, the Estonian Parliament adopted amendments to the Accounting Act and the Auditing Activities Act, significantly easing reporting and auditing obligations for civil society organizations, including foundations and associations. The amendments raised the thresholds for mandatory audits and reviews by approximately 25%, substantially reducing the administrative and financial burden on civil society actors. As a result, only larger organizations are now subject to mandatory external control, while smaller organizations are exempt unless required by other legislation or funders. The amendments entered into force in January 2025 and apply retroactively to annual reports for the 2024 financial year. Where a non-profit organization or a foundation does not exceed the applicable thresholds, no obligation arises to commission a statutory audit or review, unless such an obligation is provided for by other legislation or results from requirements imposed by funders or other legal acts.













(2) Information on:
a. developments that are relevant for updating and following up on the assessment of the topics covered in the respective country chapter of the 2025 Report, including possible clarifications
▪ In the boxes below, describe developments (updates or feedback) related to the topics covered in your country chapter of the 2025 Report (if not already covered under point (1)). You are invited to follow the order of topics as presented in the country chapter and insert direct references to the country chapter text, if convenient; and
b. any other new developments not already covered under points (1) and (2)a. that you consider relevant
▪ The list of topics provided in the Annex can provide guidance for this input.
I. Justice Systems











II. Anti-Corruption Framework










III. Media Pluralism and Media Freedom









IV. Other institutional issues related to check and balances

The enabling framework for civil society
1) On 20 November 2025, the Parliament (Riigikogu) convened an Important National Matter (OTRK) debate dedicated to civil society development and participatory democracy, reaffirming the role of civic space as a structural element of Estonia’s democratic system.
Opening the debate, Igor Taro underlined that an open, inclusive, and resilient civil society is essential for safeguarding democracy, public trust, and internal security. The discussion recognised Estonia’s strong performance in liberal democratic indicators and civic participation, while also identifying structural challenges related to unequal participation, long-term sustainability of civil society organisations, and consistency of public funding practices.
Expert interventions focused on participatory and deliberative democracy, including the institutional role of collective petitions and digital participation platforms in enabling citizen involvement beyond elections. The debate also highlighted the contribution of civil society and volunteers to crisis preparedness and civil protection, framing civic engagement as a component of democratic resilience.
In its conclusions, the Riigikogu put forward two institutional proposals of relevance to civic space governance:
• the initiation of an update of the Estonian Civil Society Development Concept (EKAK), in force since 2002, to ensure its alignment with current democratic, digital, and security contexts; and
• the establishment of a cross-party parliamentary support group for civil society, aimed at strengthening structured dialogue, oversight, and cooperation between Parliament and civil society actors.
2) As of 31 December 2025, the process of updating the Code of Ethics for civil society organisations, led by the Network of Estonian Nonprofit Organizations (NENO) as the strategic partner of the Ministry of the Interior, was in an advanced stage. Meetings with the working group were held both online and in person to assess the need to modernise the Code of Ethics. It was concluded that recent developments, including the increasing use of artificial intelligence, necessitate a review of the Code’s wording and structure. The advocacy specialist consolidated the input received and prepared a revised draft of the Code. The updated version is expected to be finalised in 2026, followed by consultations with civil society organisations, the collection of practical examples, and awareness-raising activities.
3) A shadow report on the allocation of state budget funding to civil society organisations has been completed in 2025, comparing funding practices in the period 2023–2025 with those of ten years earlier. The funding practices of ministries were assessed across six categories: public interest, effectiveness, inclusiveness, transparency, accessibility, and capacity. As a methodological update, the colour-coded system introduced in the previous shadow report was also converted into a five-point scale, allowing for an assessment of changes in average performance.
The analysis indicates an overall trend towards improvement. The cross-sectoral aggregate score of all ministries that have introduced strategic partnership practices has increased by 0.5 points or more. Other ministries likewise show a slight improvement or, at a minimum, stability in their aggregate scores compared to the situation ten years ago. Two ministries constitute exceptions: one was not assessed in the previous shadow report, while the other recorded a decrease of 0.2 points. The report and its conclusions have been shared with all ministries and presented to both the National Audit Office and civil society organisations. In 2026, dissemination of the findings will continue, and the input will also be used in the revision of guidance materials on public funding.
4) An action plan was prepared by the Network of Estonian Nonprofit Organizations for updating the guidance materials on public funding, including an outline for a chapter on strategic partnerships. Support was also provided for the harmonisation of partnership practices through consultations and feedback during the revision of funding regulations in several ministries. In addition, work was initiated on the development of an interim evaluation methodology, which is expected to create the preconditions in 2026 for a systematic assessment of the functioning of strategic partnerships from both the perspective of ministries and that of strategic partners.
As the Parliament adopted amendments to the State Budget Act at the end of 2025 (please see below) that also affect funding for civil society organisations (assessed by Ministry of the Interior and its strategic partners as a step backwards) this may influence the progress of updating the guidance materials. While the Ministry of the Interior and the Network of Estonian Nonprofit Organizations were not able to prevent the amendments in 2025, the latter plans to pursue advocacy activities in 2026 to seek renewed changes.
5) The Parliament adopted amendments to the State Budget Act in December 2025. The amendment includes proposal by the Ministry of Finance which restricts eligibility for operating grants primarily to legal bodies of the central government, effectively shifting civil society organisations towards project-based funding. While the proposal is justified by the need for uniform rules and oversight, civil society organisations were not involved in the drafting of this part of the proposal, nor was the Ministry of the Interior, which is responsible for the field of civil society.
The Network of Estonian Nonprofit Organizations (NENO) engaged in the process of the State Budget Act and the Act Amending the State Budget Act (Bill No. 736 SE in the Riigikogu) on its own initiative in summer 2025, as the amendments affect the rules governing the funding of civil society organisations. Nevertheless, NENO, as the umbrella organisation for the sector, was not involved in the drafting of the bill.
On 27 October 2025, the Ministry of the Interior submitted amendment proposals to the Riigikogu Finance Committee concerning the draft Act on the State Budget Act and the Act Amending the State Budget Act, which had been prepared jointly by the Ministry of the Interior and the Network of Estonian Nonprofit Organizations (NENO). The proposal was not taken into account by the Riigikogu Finance Committee. The amendment sought, at a minimum, to preserve the current situation in which ministries are able in practice to provide operating grants to civil society organisations. NENO noted that if the intention is to genuinely clarify and improve the funding framework for organisations, this would require a thorough discussion and sufficient time. Such a process was not considered realistic within the scope of the current legislative procedure; therefore, the amendment proposal did not pursue broader structural changes (although the withdrawal of points 51–56 of the bill from the legislative process was identified as a possible alternative).
Consequently, two possible approaches to amending the legislation were identified by NENO:
1. To delete paragraphs 2–3 of § 53¹ from point 54 of the bill, which stipulate that only a legal bodies of the central government may be eligible for operating grants, unless otherwise provided by law.
2. To amend paragraph 2 of § 53¹ in point 54 of the bill to stipulate that a legal bodies of the central government, a non-profit association, or a foundation may be eligible for operating grants, unless otherwise provided by law.
Overall, it was emphasised that a pause in the process was necessary which would allow sufficient time to properly discuss the provisions affecting the funding of civil society organisations, with the involvement of all relevant stakeholders.
On the 20 November 2025 Important National Matter (OTRK) debate dedicated to civil society development, the Minister of the Interior, Igor Taro, commented on the situation as follows: “I have a genuine concern that the proposed approach would represent a return to a project-centred model, undermine strategic partnerships, and make cooperation more unstable, particularly in policy areas where civil society organisations function as an ‘extension’ of the state in achieving public objectives. This would not strengthen, but rather weaken, the partnership between the state and civil society.”














Cross-pillar elements: cross-border rule of law issues related to the Single Market
If you are aware of any significant challenges concerning the Single Market faced by businesses or citizens from your Member State in a cross-border context relating to any of the four pillars of the report, including for example issues with market access and the conditions for economic activities, please highlight them in the box below.2









As regards the publication of your written input, please indicate whether you3:
☐ Consent
☐ Do not consent