This article is an integral part of the Coalition prEUgovor report on progress of Serbia in Chapters 23 and 24 for the period from May 2015 to October 2015.
Weaknesses of the AP are visible at the elementary level - there was obviously no linguistic checking of the document prior to publication and opening of public debate, so it contains numerous spelling and stylistic errors, implementers of activities were specified in a wrong or at least incomplete manner (e.g. that the ministries make amendments to law, even though this can be done by the National Assembly only). In a document put up for public debate, no activities whatsoever were planned for 12 recommendations from the EC’s Screening Report (e.g. whistle blowers’ protection, control of public procurement, "information leaks” on investigations, unique corruption statistics, immunity system revision).
This Action Plan contains some identical measures as the Action Plan for Implementation of Anti-corruption Strategy, but with deadlines and implementers defined differently, which will create serious problems with monitoring. Moreover, the “new” Action Plan presents worse solutions for many situations than the current one (e.g. unduly extended deadlines), which should be accepted under no circumstances. The description of current state is incomplete, and there is no mention of serious issues regarding competition and transparency evasion by means of applying of interstate agreements, lack of regulations and transparency in lobbying, non-compliance with certain norms of Public Companies Act, too broad discretionary powers, a large number of unreported corruption cases, vague relationships (in practice) between the authorities that investigate corruption and the executive power when it comes to defining priority cases to be investigated.
Among numerous deficiencies stand out the misconceived concept of the political leadership coordinating between all state authorities in the fight against corruption, the underdeveloped activities for adequate response to reports and requests made by the Agency and for the setting up of efficient oversight mechanisms. Draft Action Plan shows big lack of understanding for the problem of insufficient transparency, because the need to change regulations other than the Free Access to Information of Public Importance Act (deadline for those amendments is unreasonably long) is not recognized, nor are the measures that can be taken without amendments to any law (to begin with, that the Government itself acts upon received requests, that all authorities create and update their complete Information Booklets, that databases on public spending, contracts and agreements made by the Government, ministries and public companies get published and searched through.) The measures to depoliticize public administration are obviously insufficient to accomplish that aim.
 Integral version of the comments made by Transparency Serbia on draft Action Plan for chapter 23 in the field of fight against corruption is available at the TS web page: http://goo.gl/7gpqNO