The Autonomous Women's Center (AWC) participated in the public consultation on the Draft Programme for the Prevention and Protection of Children from Violence for the period 2026–2030 and its accompanying Action Plan for 2026–2028. Our analysis of these documents shows that the proposed measures do not provide a sufficiently strong basis for improving the child protection system or ensuring accessible and effective support services for children affected by violence. Nor do they ensure compliance with Serbia's international obligations.
It is particularly concerning that the new strategic document is being adopted simultaneously with amendments to key legislation, even though public consultations on those laws have already been completed. The proposed legislative amendments do not meet the standards set by the Convention on the Rights of the Child, the Istanbul Convention, relevant European Union directives, or the recommendations of international monitoring bodies binding on the Republic of Serbia.
The Programme was prepared without ex-post and ex-ante impact assessments, following the Government's decision to amend the Regulation on the Methodology for Public Policy Documents. As a result, it is not based on an evaluation of the previous strategy's implementation or on an assessment of the expected impact, costs and benefits of the proposed measures. Consequently, the document resembles a list of planned activities rather than an evidence-based strategic framework with measurable outcomes.
The Draft Programme fails to adequately address the needs of child victims and child witnesses of violence. It lacks measures aimed at strengthening legal, psychological and social support services, as well as measures to protect children who have lost a parent as a consequence of femicide or other forms of domestic violence. At the same time, the proposed amendments to several key laws do not ensure alignment with European standards on child protection in criminal, family and other institutional proceedings.
The analysis also identifies significant shortcomings in the proposed institutional framework. The Draft Programme incorrectly assigns the coordination role to social welfare centres, although the existing legal framework entrusts this responsibility to the public prosecutor's office through established coordination mechanisms. Instead of strengthening existing mechanisms, the Programme proposes creating new ones, resulting in overlapping responsibilities and placing additional pressure on systems that have long been operating with insufficient human resources.
Another major concern is that the Draft Programme does not include measures for developing a system of accessible support services for child victims and witnesses of all forms of violence, despite this being one of the most significant weaknesses of the current system. AWC pointed out that two groups of children have been unjustifiably excluded from the proposed activities: child witnesses of all forms of violence and children whose mothers have been victims of femicide. We therefore proposed the inclusion of activities aimed at developing specialised support services for these children.
The Programme also fails to provide for comprehensive data collection on child victims and witnesses of violence, children killed as a result of violence, and children who have lost parents due to femicide. It likewise does not envisage improvements to judicial statistics that would enable monitoring of children's rights throughout judicial proceedings. Furthermore, it remains questionable whether the "Čuvam te" ("I Protect You") platform should become the central database of an integrated national data collection system. Its primary purpose is to provide children with an accessible and child-friendly mechanism for reporting violence, while also serving as a source of information on prevention, protection and available support services.
The proposed Action Plan further illustrates a number of weaknesses. Most activities focus on developing analyses, models, guidelines and standards, while concrete support measures for children are postponed to later stages. The proposed timelines leave very limited time for the actual implementation of training, protection and support measures during the initial phase of the Programme. In addition, the planned number of trainings and trained professionals is disproportionately low compared to the needs of the system. Baseline values are missing for many indicators, target values are set too low, or they measure only the adoption of legislation rather than the quality of legal reforms and their compliance with international standards.
A further significant shortcoming is the absence of a clear financial framework. Neither the Programme nor the Action Plan includes a transparent estimate of the financial resources required for implementation. Both documents were submitted for public consultation before consultations on financing had been completed, making it impossible to assess whether the planned activities can realistically be implemented.
AWC believes that both the Draft Programme and the Action Plan require substantial revision in order to become evidence-based, fully aligned with international standards, and genuinely responsive to the needs of child victims and witnesses of all forms of violence. Without these improvements, there is a serious risk that the new strategic framework will fail to bring meaningful progress in protecting children and will remain a policy document without the legal, institutional and financial foundations necessary for effective implementation.
You can see the document with AWC comments and suggestions HERE.
