The Autonomous Women's Center submitted to the Ministry of Labor, Employment, Veterans and Social Affairs comments and suggestions for amendments to the Proposal of the National Strategy for Prevention and Combating Gender-Based Violence against Women and Domestic Violence for the period 2021-2025.

The most serious objection to the Strategy Proposal is given for the chapter related to the goals and measures for their realization, which is its central part and the basis for the future development of two action plans. The poor relationship between the specific objectives and the proposed measures was pointed out, which will have negative consequences on the planning of activities. Although the specific objectives cover areas that are different in scope and complexity, this is generally not reflected in the number of measures. Also, the measures are uneven in their comprehensiveness / scope (both within the same and between different specific objectives) and do not reflect the recommended priorities for action from the GREVIO report sent to the Republic of Serbia in January 2021.

Another important issue pointed out concerns the assessment of the financial resources needed to implement the Strategy. The way it is formulated clearly indicates that it is not a public policy document that has the capacity to improve the situation and (at least part of) the identified problems, nor does it respond to GREVIO's recommendation that the Serbian authorities gradually start reducing dependence on international donors in this area, thus showing their financial responsibility and independence in action. This calls into question the implementation of measures and activities and indicates that international and intergovernmental organizations operating in Serbia will continue to be the main bearers of activities in this field.

It was especially pointed out that, although non-governmental and women's organizations are mentioned many times in the Strategy Proposal (most often as implementers of various activities and sources of information), there is no analysis of problems related to their functioning and relations with other public sector bodies and institutions. which would eliminate problems and contribute to the recognition, encouragement and support of their work and establish more effective cooperation with all relevant actors, in accordance with Art. 9 of the Convention and the GREVIO Recommendations in paragraph 38.

The comments on the details, which you can see HERE, indicate the necessary changes and additions to the Strategy Proposal.