During the public debate on the Draft Law on amendments to the Law on Prevention of Domestic Violence, which was held from November 12th till December 2nd, 2025, without public presentation on proposed amendments, Autonomous Women’s Center submitted comments and suggestions to the draft law.

Autonomous Women’s Center welcomed the amendments to the Law on Prevention of Domestic Violence, taking into account the measures from the Reform Agenda, the obligations undertaken through the ratification of The Council of Europe Convention on Preventing and Combating Violence Against Women and Domestic Violence, as well as the need for harmonization with Directive 2012/29/EU establishing minimum standards on the rights, support, and protection of victims of crime, and EU Directive 2024/1385 on preventing and combating violence against women and domestic violence. However, the amendments to this law should have awaited the amendments to the Criminal Code, to also include recommendations based on the findings from the implementation of the Law, as well as standards from the Victims Directive.

AWC submitted a number of specific proposals for amending the Law on Prevention of Domestic Violence. It was noted that Article 4 would need to be supplemented following the adoption of amendments to the Criminal Code (which is expected to introduce a new criminal offense of misuse of recordings, photographs, portraits, audio recordings or documents of sexually explicit content). It was also necessary to specify that meetings of the Groups for Coordination and Cooperation should also include cases in which the perpetrators of the criminal offenses referred to in Article 4 are minors (through the development of individual plans of protection and support for the victims of such acts).

The addition of new provisions was proposed to ensure alignment with Directive 2012/29/EU, as well as with the 2018 act of the Protector of Citizens which recommended that The Administration for the Execution of Criminal Sanctions, when releasing persons convicted of offenses under Article 4, timely notify the police, social service, and the injured party (victim). The introduction of additional mandatory risk assessment factors was proposed, given that some are often omitted in practice (such as threats with tools or weapons, strangulation, jealousy, control, isolation, violations of protection measures imposed under the Criminal Code, Criminal Procedure Code, and the Misdemeanor Law). The amendment prescribing that a separate risk assessment checklist should be completed for each victim was welcomed, and AWC proposed a more precise provision, including one for cases where minor children are witnesses of reported violence. Provisions regarding the delivery of decisions on the extension of emergency measures (including via the e-Government Portal) were also clarified. It was further proposed that decisions on extended emergency measures and second-instance decisions on appeals, as well as decisions in misdemeanor cases should be delivered directly to victims (not merely informing the victim).

Regarding high-risk cases of serious injury or femicide, it was proposed to clarify that Groups for Coordination and Cooperation have to review cases in which perpetrators could not be found, or are hospitalized, or released from prison, and that individual plans of protection and support be created for the victims in such cases. Given data showing that higher public prosecutors have not participated in the meetings of the Groups for Coordination and Cooperation as prescribed by the Law, it was proposed that Higher Public Prosecutor’s Offices designate a prosecutor who will coordinate actions between higher and basic prosecutor’s offices and ensure consistency in the work of the Groups within their jurisdiction.

The AWC’s comments and proposals are avaliable HERE.