Bosnia and Herzegovina has satisfactorily implemented only two out of the 25 recommendations outlined in the Fifth Round Evaluation Report by the Group of States Against Corruption (GRECO). Of the remaining 23 recommendations, 15 have been partially implemented, while eight have not been addressed at all.

GRECO acknowledges some positive developments in Bosnia and Herzegovina’s highest executive functions. The adoption of the 2024-2028 Anti-Corruption Strategy and the accompanying Action Plan for its implementation is seen as a step forward. However, while integrity checks have been established for the Chairperson of the Council of Ministers, ministers, and their deputies, they do not extend to chiefs of staff and advisers, including those working for members of the Presidency of Bosnia and Herzegovina.

“Although the names and areas of responsibility of some chiefs of staff and advisers are available online, the information should cover all nine ministries and be more comprehensive,” GRECO stated.

Conflict of interest law and its shortcomings

The Law on Conflict of Interest has been adopted, incorporating provisions on gift acceptance, incompatibilities, external activities, post-employment restrictions, and conflicts of interest. However, GRECO criticizes the fact that the Commission for Conflict of Interest, responsible for monitoring and enforcing the law, has not yet started its work.

In addition, GRECO has expressed concerns over the Law on Freedom of Access to Information, noting that some provisions do not align with the Council of Europe Convention on Access to Official Documents and need to be revised.

Preventing conflicts of interest and transparency issues

A unified system for asset and financial interest declarations has been established, requiring senior executive officials (PTEF) to immediately inform the Commission on Conflict of Interest upon discovering a potential conflict. However, several key issues remain unresolved, including:

• Establishing clear rules on how senior officials interact with lobbyists.
• Implementing measures to make the legislative process more transparent.
• Ensuring adequate financial and human resources for the Agency for Prevention of Corruption and Coordination of the Fight Against Corruption (APIK).

Concerns over police integrity and public oversight

GRECO emphasizes the need for a formalized integrity check mechanism for all police officers, focusing on identifying potential conflicts of interest.

Authorities are also expected to take additional steps to ensure transparency and public oversight in the selection of senior leadership positions. Further efforts are required to enhance gender balance, staff rotation, and whistleblower protection.

Future steps and compliance deadline

GRECO acknowledges that the adoption of the national Anti-Corruption Strategy should “pave the way for drafting action plans for the Border Police of Bosnia and Herzegovina (GPBiH) and the State Investigation and Protection Agency (SIPA).” The new GPBiH Code of Ethics, accompanied by practical guidelines, is considered a positive achievement, while SIPA is still working on its own ethical framework, with tangible results yet to be seen.

“Further progress will need to be achieved in the next 18 months to reach an adequate level of compliance with these recommendations,” GRECO stated, calling on the head of Bosnia and Herzegovina’s delegation to submit additional information by the end of May 2026.