COMMISSION STAFF WORKING DOCUMENT 2022 Rule of Law Report Country Chapter on the rule of law situation in Estonia Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2022 Rule of Law Report The rule of law situation in the European Union

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COMMISSION
Luxembourg, 13.7.2022
SWD(2022) 506 final
COMMISSION STAFF WORKING DOCUMENT
2022 Rule of Law Report
Country Chapter on the rule of law situation in Estonia
Accompanying the document
Communication from the Commission to the European Parliament, the Council, the
European Economic and Social Committee and the Committee of the Regions
2022 Rule of Law Report
The rule of law situation in the European Union
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ABSTRACT
The digitalisation of the justice system in Estonia, which is already well advanced, continued
to improve, including in the field of criminal proceedings. This high level of digitalisation has
allowed the justice system to continue working efficiently, with some further improvements
in criminal cases. Challenges have been identified as regards the workload of judges, as
illustrated by a survey conducted among judges. To address these challenges and to even-out
the workload between courts, a new regime was created for transfer of cases. Concerns have
been raised about the effect of the application of this new regime because it may require
judges to travel to hold hearings in cases they were assigned. Court fees have been
significantly increased but citizens can rely on a number of safeguards, including exemption
from court fees for cases with the highest social significance, such as child support disputes,
labour and pension related disputes.
The anti-corruption network effectively supports the implementation of the 2021-2025 Anti-
Corruption Action Plan. The criminal justice system for investigating and prosecuting
corruption continues to function well. The Guidelines on Lobbying are being implemented
and the first evaluation of their effectiveness is still ongoing. There are shortcomings in the
implementation of the Guidelines on Conflicts of interest, including the lack of evaluation of
their implementation, which does not allow to verify and monitor whether they have met their
objectives. The first feedback on the implementation of the Anti-Corruption Act extending
the obligation to declare interests to ministers’ political advisers and the deputy secretaries-
general of ministries is positive. The draft law that would strengthen the powers of the
Political Parties’ Financing Surveillance Committee is under preparation. The Government
has proposed a comprehensive law to protect whistleblowers, which is currently being
discussed in Parliament.
Estonia has amended the media law to strengthen the independence of the media regulator
and enhance the transparency of media ownership, including beneficial owners. The right of
access to information is protected by the Constitution, yet actual disclosure practices vary
between public bodies. There is legislation in place that foresees detailed procedures for
operating TV and radio licenses without media-specific quantitative rules for market entry or
operation. Legislative safeguards for the independence of public service media are in place.
Since the 2021 Rule of Law Report, the comprehensive framework for the protection of
journalists has remained stable.
A project creating a new digital platform to further improve the process of enactment of laws
entered its first implementation phases. As a consequence of the COVID-19 pandemic, new
legislation provides a broader basis for measures to address health emergencies and exercise
supervision. The Cohesive Estonia Development Plan 2021-2030 replaces or integrates all
previous strategies and plans related to Civil Society Organisations, and extends the duration
of the previous programme.
2
RECOMMENDATIONS
It is recommended to Estonia to:
 Ensure that the guidelines on the conflict of interests are subject to an effective
verification, monitoring and enforcement mechanism.
 Continue the efforts in effective implementation of the guidelines on lobbying.
 Ensure consistent and effective practical implementation of the right of access to
information taking into account European standards on access to official documents.
 Continue advancing with the digital platform to make the legislative process even more
visible and inclusive for public consultation.
3
I. JUSTICE SYSTEM
The Estonian court system consists of three levels: four County Courts (hearing all civil,
criminal and misdemeanour matters) and two Administrative Courts at first instance, two
Circuit Courts at second instance (reviewing decisions of County and Administrative Courts),
and the Supreme Court at the highest instance, which reviews court judgments by way of
cassation proceedings and is also the court of constitutional review. The Supreme Court
administers its own budget and operations, while the courts of first and second instance are
administered in cooperation between the Council for Administration of Courts and the
Ministry of Justice. The Council for Administration of Courts is a non-permanent body1
,
which has powers, among others, related to the judicial map, the resources of the judiciary
and participates in the discussion on administration of the courts. Judges of first and second
instance courts are appointed by the President of the Republic on the proposal of the Supreme
Court (en banc)2
. The Prosecutor’s Office is a government agency under the Ministry of
Justice, which is independent in the performance of its duties. It is managed by the Prosecutor
General, particularly as regards the appointment and career of prosecutors3
. The Estonian Bar
Association is an independent, self-governing professional association4
. Disciplinary
proceedings against lawyers can be initiated before the Court of Honour5
by any interested
person or by the board of the Bar Association6
. Estonia participates in the European Public
Prosecutor’s Office (EPPO).
Independence
The level of perceived judicial independence in Estonia has decreased, yet continues to
be high among the general public and average among companies. Overall, 60% of the
general population and 47% of companies perceive the level of independence of courts and
judges to be ‘fairly or very good’ in 20227
. According to data in the 2022 EU Justice
Scoreboard, the level has decreased for both the general public and for companies, both in
comparison to 2021 (66% for the general public and 57% for companies), and in comparison
to 2016 (62% for the general public and 72%).
The effects of the application of the new regime for the transfer of cases, intended to
address the excessive workload, raise concerns in relation to the transfer of judges. On 7
July 2021, the Presidents of the Tallinn and Tartu Circuit Courts of Appeal made use of the
1
The Council does not function on a permanent basis and has four regular sessions, as well as extraordinary
sessions whenever needed. See 2020 Rule of Law Report, Country Chapter on the rule of law situation in
Estonia, p.3.
2
The Supreme Court en banc is the highest body of the Supreme Court. It is comprised of all 19 justices of
the Supreme Court. The Supreme Court en banc is convened and chaired by the Chief Justice of the
Supreme Court.
3
The Prosecutor General exercises supervisory control in the prosecutor's office, and chief prosecutors
exercise supervisory control in district prosecutor's offices.
4
§ 2(1) of the Bar Association Act.
5
§ 15(1) and § 15(3) of the Bar Association Act - The Court of Honour consists of four sworn lawyers elected
by the general assembly of the Bar Association, two judges elected by the Court en banc and one jurist
designated by the council of the Law Faculty of the University of Tartu.
6
§ 16(1) of the Bar Association Act.
7
Figures 50 and 52, 2022 EU Justice Scoreboard. The level of perceived judicial independence is categorised
as follows: very low (below 30% of respondents perceive judicial independence as fairly good and very
good); low (between 30-39%), average (between 40-59%), high (between 60-75%), very high (above 75%).
4
amendments reported last year8
, which extended the possibility to transfer a case to another
county or administrative court9
. This amendment was introduced to address the excessive
workload in certain courts and is meant to be used as an extraordinary measure and not as
standard practice10
. Upon a request of the President of Harju County Court, the presidents of
the two circuit courts decided to transfer 543 cases to the County Courts of Viru and Pärnu11
.
If not all cases can be handled in written proceedings, this could result in a significant
number of cases for which judges may need to travel to hold hearings in the court where the
cases were originally filed, possibly for a longer period. Concerns have been raised that such
transfers of cases could result in temporarily transferring judges, for the duration of the
hearings, without their consent, to another city12
.
Quality
The improvements in the digitalisation of justice continue with the introduction of a
speech recognition software. As noted in the 2020 and 2021 Rule of Law Reports, Estonia
is among the best performing Member States when it comes to digitalisation of justice13
. This
high level of digitalisation has contributed to the efficiency and quality of the justice system.
Furthermore, a new electronic tool has been introduced. On 19 November 2021, the speech
recognition software ‘SALME’ was introduced to the Council for the Administration of
Courts14
. The main goal of this software is to save time on writing protocols, especially in
hearings in criminal matters. In its current form, the software can process only in Estonian,
but the goal is to expand it to other languages. Currently, the software is available for
criminal proceedings, but the Ministry of Justice plans to expand the use to civil and
administrative proceedings. Different types of trainings, general and in-house, support the
improvements in the digitalisation of justice15
.
Challenges have been identified as regards workload of judges. In 2021, a survey
conducted among judges disclosed the perceived potential detrimental effects of the
excessive workload on the quality of justice16
. The survey shows the effects of the increasing
workload17
in the Estonian justice system18
. The increase of workload per judge was also
8
See 2021 Rule of Law Report, Country Chapter on the rule of law situation in Estonia, p.3.
9
§ 45(1) of the Courts Act - Referral of a matter from a county court is allowed only to another county court
and from an administrative court only to another administrative court.
10
Explanatory memorandum of the Courts Act for §45(1) - if it is evident that it is not possible to ensure
administration of justice pursuant to the requirements in the court.
11
Order No 11-1/21/30 of 7 July 2021 - On a request by the President of Harju County Court for referral of
cases pursuant to Section 451 of the Courts Act.
12
Information received from the Estonian Association of Judges in the context of the country visit to Estonia.
13
Figures 42 to 49 from the 2022 EU Justice Scoreboard.
14
Contribution from the Supreme Court and Council for the Administration of Courts for the 2022 Rule of
Law Report, p. 12.
15
Information received from the Ministry of Justice, Supreme Court and Estonian Judges Association in the
context of the country visit to Estonia.
16
Estonian Judges Association (2022), Workload survey for I-II level judges. The survey was prepared and
conducted by the Estonian Association of Judges. The survey was conducted at the end of 2021 and the
summary of the responses was issued on 20 January 2022. It was answered by 112 out of 241 (the total
number of all cases in Estonia for this number of judges is 51 244, as per the Council for the Administration
of Courts) judges and covered questions related to the workload.
17
About half of the respondents have considered, occasionally or often, leaving their job due to the excessive
workload. About 90% of the respondents consider that workload is a stress factor, which to some degree
affected their abilities to perform their duties. See also on 10 February 2022, the statistics for the workload
5
illustrated by the Yearbook of Estonian Courts, where a summary of the data shows that at
first instance courts the workload of judges varies between 227 and 447 cases that a judge has
per year19
. The main factors affecting the workload of judges, according to the same survey
as well as other stakeholders20
, are legislative changes that increased the workload but not the
available positions of judges, the increased complexity of cases, the excessive number of
cases and the low quality of procedural documents submitted by the parties to the
proceedings. Moreover, due to an upcoming retirement wave21
, the justice system could face
challenges filling in the vacant positions22
. In June 2022, one of the main topics at the
General Assembly of all judges in Estonia will be the increase in workload and how the
situation can be improved.
Court fees have been significantly increased with a number of safeguards. As of 1
January 2022, the court fees in Estonia were increased by 40% on average. This is the first
increase of the court fees since 2011. The 2022 EU Justice Scoreboard shows that the court
fees in consumer and commercial cases are already among the higher ones in the EU23
.
According to the Government, the economic growth of Estonia since the last revision of court
fees, as reflected in the increase of GDP, has justified this measure24
. The increase was not
accompanied by other reforms, such as a reform of the available legal aid scheme. According
to stakeholders, the increase could also be seen as a way to decrease the workload of the
courts by disincentivising cases from being brought before the courts, while making
alternative dispute resolution more attractive25
. In certain cases, related to family matters,
such as divorce or disputes over the custody of a child, a mandatory alternative dispute
resolution was introduced. The State Fees Act also lists a number of exceptions from
payment of the fees for each of the areas affected by the increase; some of the areas with the
highest social significance, such as child support disputes, labour and pension related
disputes, are exempted from court fees altogether26
. The Estonian justice system also allows a
of courts for 2021 was released, Council for the Administration of Courts (2022), Statistics for the workload
of courts for 2021.
18
The Minister of Justice confirmed that there is an increase of workload in civil cases, administrative cases
and stated that the workload of circuit courts is the highest of the last years.
19
This data concerns only civil and criminal cases. The lowest average workload of a judge per year relates to
Pärnu county court in criminal cases, while the highest average workload of a judge per year relates to Harju
county court in civil cases. – Summary of the Procedural Statistics of the County, Administrative and Circuit
Courts in 2020: about Resolved Matters (incl. Paperless Procedure) and the Average Workload of a Judge.
20
Information received from the Supreme Court and Estonian Judges Association in the context of the country
visit to Estonia.
21
About 1/3 of all judges in Estonia are expected to retire in the next 2 years. Moreover, in 2022, there are 20
judges eligible for retirement. - Information received from the Supreme Court and Estonian Judges
Association in the context of the country visit to Estonia.
22
This is already the case for positions in the field of criminal law. – Information received from the Estonian
Judges Association in the context of the country visit to Estonia.
23
Figures 26 and 27, 2022 EU Justice Scoreboard. The two figures present court fees in specific consumer and
commercial case scenario, respectively. The data in the 2022 edition of the Scoreboard present the situation
before the reform.
24
Input from Estonia for the 2022 Rule of Law Report, p.1.
25
Information received from the Estonian Judges Association and Estonian Bar Association in the context of
the country visit to Estonia.
26
§ 22 of the State Fees Act.
6
party to challenge court fee rates before the Constitutional Review Chamber of the Supreme
Court on a case-by-case basis27
.
Efficiency
The justice system continues to work efficiently, with some further improvements in
criminal cases. The length of proceedings and pending cases are among the shortest in the
EU28
. In 2021, civil cases were resolved with a similar efficiency as in 2020 in county courts
(in 101 days on average), criminal cases were resolved fairly faster than in 2020 (on average,
in 192 days in general criminal proceedings, 24 days in simplified proceedings, and 44 days
in misdemeanour cases)29
. In the first instance courts, administrative cases were resolved with
a similar efficiency as in 2020 (on average 127 days)30
. The average processing time for
appeals was 162 days in civil cases, 66 days in criminal cases and 40 days in administrative
cases. The length of court proceedings in civil, commercial and administrative cases is
shorter than average in the EU (measured in disposition time) and the number of pending
cases are amongst the lowest in the EU. Compared to 2020, the clearance rate increased
slightly above 100%, which means that courts were generally able to cope with incoming
cases31
.
II. ANTI-CORRUPTION FRAMEWORK
The anti-corruption institutional set-up has not changed compared to the 2021 Rule of Law
Report. The Ministry of Justice is in charge of the preparation, oversight and coordination of
the anti-corruption Action Plan 2021-2025. The Anti-Corruption Select Committee exercises
parliamentary scrutiny over the implementation of anti-corruption measures. The Political
Parties’ Financing Surveillance Committee oversees political parties’ funding. The
Corruption Crimes’ Office of the National Criminal Police is a specialised unit responsible
for carrying out investigations on corruption cases, and the Internal Security Service is
responsible for investigating corruption offences committed by higher state officials and
higher local government officials in six larger municipalities. The Prosecutor’s Office
supervises and directs pre-trial criminal investigation proceedings on corruption offences and
represents the public prosecution in courts.
The perception among experts and business executives is that the level of corruption in
the public sector in Estonia remains relatively low. In the 2021 Corruption Perceptions
Index by Transparency International, Estonia scores 74/100 and ranks 6th
in the European
27
See Art. 15, para 1, second sentence of the Constitution, everyone is entitled to petition the court that hears
his or her case to declare unconstitutional any law (or a provision thereof) relevant (applicable) in the case.
See also Art. 152 of the Constitution, the courts refuse to give effect to the applicable law (or a provision
thereof) that conflicts with the Constitution (para 1), and the Supreme Court declares invalid any law or
other legislation or administrative decision that conflicts with the letter and spirit of the Constitution (para
2).
28
Figures 6-10 and 17-24, 2022 EU Justice Scoreboard.
29
See 2021 Rule of Law Report, Country Chapter on the rule of law situation in Estonia, p. 5 - In 2020,
criminal cases were resolved on average in 226 days in general criminal proceedings, 28 days in simplified
proceedings and 46 days in misdemeanour cases. In the first instance courts, administrative cases were
resolved in an average of 123 days. In the first instance courts, administrative cases were resolved in an
average of 123 days.
30
Input from Estonia for the 2021 Rule of Law Report, p.4.
31
Figures 11-16, 2022 EU Justice Scoreboard.
7
Union and 13th
globally32
. This perception has improved33
over the past five years34
. The
2022 Special Eurobarometer on Corruption shows that 43% of respondents consider
corruption widespread in their country (EU average 68%) and 12% of respondents feel
personally affected by corruption in their daily lives (EU average 24%)35
. As regards
businesses, 33% of companies consider that corruption is widespread (EU average 63%) and
9% consider that that corruption is a problem when doing business (EU average 34%)36
.
Furthermore, 38% of respondents find that there are enough successful prosecutions to deter
people from corrupt practices (EU average 34%)37
, while 50% of companies believe that
people and businesses caught for bribing a senior official are appropriately punished (EU
average 29%)38
.
The extended anti-corruption network effectively supports the implementation of the
2021-2025 Anti-Corruption Action Plan. The network, which was originally composed of
anti-corruption coordinators from each ministry, was in the last years expanded to additional
stakeholders and it is now composed of 29 members39
. In 2021, the network met six times.
The tasks of the network, mainly related to developing and sharing best practices, supporting
cooperation and mutual learning and exchanging experience, inlcude now also monitoring the
activities foreseen by the Action Plan40
. According to the authorities and civil society, the
network is a key player in the implementation of the Action Plan41
. The cooperation between
authorities and organisations participating in the network is considered good by both42
.
The criminal justice system for investigating and prosecuting corruption continues to
function well. In 2021, the criminal justice system proved again to be effective in identifying
32
Transparency International (2022), Corruption Perceptions Index 2021, p. 2-3. The level of perceived
corruption is categorised as follows: low (the perception among experts and business executives of public
sector corruption scores above 79); relatively low (scores between 79-60), relatively high (scores between
59-50), high (scores below 50).
33
In 2015 the score was 70, while in 2020 the score was 75. The Score significantly increases/decreases when
it changes more five points; improves/deteriorates (changes between 4-5 points); is relatively stable (changes
from 1-3 points) in the last five years.
34
The Eurobarometer data on corruption perception and experience of citizens and businesses as reported last
year is updated every second year. The latest data set is the Special Eurobarometer 523 (2022) and the Flash
Eurobarometer 507 (2022).
35
Special Eurobarometer 523 (2022). The Eurobarometer data on citizens’ corruption perception and
experience is updated every second year. The previous data set is the Special Eurobarometer 502 (2020).
36
Flash Eurobarometer 507 (2022). The Eurobarometer data on business attitudes towards corruption as is
updated every second year. The previous data set is the Flash Eurobarometer 482 (2019).
37
Special Eurobarometer 523 (2022).
38
Flash Eurobarometer 507 (2022).
39
The network is composed of all ministries, the Estonian Chamber of Trade and Commerce, Transparency
International Estonia, Prosecutors Office, Police and Border Guard, Internal Security Service, Forum of
Responsible Business, Network of Estonian Nonprofit Organizations, Estonian Health Insurance Fund, State
Audit Office and the Anti-Corruption Select Committee of the Parliament. Occasionally, depending on the
topic, also other bodies are invited to participate, e.g. the Estonian Centre for Integrity in Sports. Information
received from the Ministry of Justice in the context of the country visit to Estonia.
40
The Anti-corruption Action Plan 2021-2025, point 4.
41
According to the Anti-corruption Action Plan 2021-2025, point 4, the anti-corruption network’s main
objectives are to develop and share best practices, support cooperation and mutual learning and exchange
experience, in addition to monitoring the activities foreseen by the Action Plan.
42
Information received from the Ministry of Justice and Transparency International in the context of the
country visit to Estonia.
8
corruption cases43
. During 2021, a final verdict was reached in relation to three corruption
cases on political party financing and bribery44
, and four more were brought to court45
. As
regards the case involving the Porto Franco development project in Tallinn that led to the
resignation of the previous Government in January 2021, the proceedings are still ongoing.
To further support investigation and prosecution of corruption cases, further specialised
expertise, notably regarding procurement and audit has been created46
. Furthermore, specific
anti-corruption trainings for prosecutors and judges take place once per quarter on average,
focusing on a variety of topics47
. In addition, members of the Internal Security Service
participate in the European Union Agency for Law Enforcement Training (CEPOL) financial
investigation and money laundering trainings.
Discussions on legislative transparency and integrity with regard to lobbying are
ongoing. Between March and May 2022, the Anti-Corruption Select Committee of the
Parliament organised a series of three roundtables with the participation of external
stakeholders48
to discuss legislative transparency and integrity with regard to lobbying. As a
second step, concrete recommendations are to be drafted based on the discussions that were
carried out49
.
The Guidelines on Lobbying are being implemented and the first evaluation of their
effectiveness has been carried out. The Ministry of Justice, together with Transparency
International Estonia and the relevant network, have carried out an analysis of the
implementation of these Guidelines on lobbying50
. The assessment concluded that certain
measures are needed, such as ensuring accuracy and timeliness of information51
. The ranking
of “best performers” will be published by the autumn of 2022; this is expected to encourage
and support the further implementation of the Guidelines on lobbying. According to the
authorities and stakeholders52
, the preliminary conclusion is that the ministries generally
follow the Guidelines adequately, while there are some gaps in the way they are implemented
by the government agencies and top officials53
. At the same time there is no enforcement
mechanism in case the Guidelines on lobbying are not followed.
There are shortcomings in the implementation of the Guidelines on Conflicts of Interest.
The Guidelines for ministers and their advisers to avoid conflicts of interest have been in
43
Opening of three cases related to high-level officials from the local and national administration were
reported. See also 2021 Rule of Law Report, Country Chapter on the rule of law situation in Estonia, p. 7.
44
Information received from the. Prosecutor’s Office in the context of the country visit to Estonia.
45
Only one could be considered high-level corruption.
46
The Northern District Prosecutor's Office and the Office of the Prosecutor General have created a position
for a specialised consultant with financial knowledge, which is used also in corruption proceedings.
Information recieved from the Ministry of Justice following the country visit to Estonia.
47
Such as financial investigations in connection with fraud and corruption cases, anti-money laundering,
virtual assets, detection of corruption, procurement procedures, corruption indications and red flags.
Information received from the Ministry of Justice in writing following the country visit to Estonia.
48
The participants include, among others, Group of States against Corruption of the Council of Europe
(GRECO) and Transparency International Estonia.
49
Information received from the Anti-Corruption Select Committee in writing following the country visit to
Estonia.
50
Estonian Government (2021), Good Practice in Communicating with Lobbyists for Officials. Summary of
lobby meetings.
51
E.g. a uniform format in which data are to be made public, possible technical platform to share information
52
Information received in the context of the country visit in Estonia from the Ministry of Justice and
Transparency International Estonia.
53
Information received from the Ministry of Justice in the context of the country visit in Estonia.
9
force since March 2021. They require the minister or adviser to familiarise themselves with
the Guidelines and encourage the completion of a dedicated online course54
. However, no
evaluation of their efficacy is planned and no measures are foreseen in case the Guidelines
are not followed55
. In view of ensuring proper implementation, in February 2022 the Minister
of Justice reminded all ministers and their advisers that they must participate and pass the test
in the e-training course56
. GRECO assessed that the rules on ‘revolving doors’, included in
the guidelines, represent a concrete and positive step forward57
. However, overall, the
Guidelines lack an effective verification and monitoring mechanism. The lack of evaluation
of the implementation of the Guidelines does not allow to assess whether they have met their
objectives. Also, the Guidelines lack an enforcement mechanism. The draft legislation on
‘revolving doors’ is currently under consideration by the Government. The draft foresees a
cooling off period after the term of office of the Government members has expired58
.
The first feedback on the implementation of the Anti-Corruption Act is positive. Last
year, the obligation to declare interests was extended to ministers’ political advisers and the
deputy secretaries-general of ministries59
. According to GRECO, the amendments as
presented to the Parliament were a positive development60
. Overall, the initial feedback on
the implementation of the amendments to the Anti-Corruption Act that entered into force in
April 2021 indicates their usefulness in terms of drawing attention to registering the
declarations of interest and ensuring clarity of the role of political advisors61
.
The Minister of Justice will soon submit the draft law aimed at strengthening the
powers of the Political Parties’ Financing Surveillance Committee. In October 2021, the
Ministry of Justice published a ‘legislative intent’62
to amend the Political Parties Act with a
view to increase the powers of the Political Parties’ Financing Surveillance Committee. The
draft law would extend the investigating powers of the Committee through a legal basis for
requesting documents, information and explanations from third parties. Currently, the
Committee can make such requests but the third parties are under no obligation to respond.
Furthermore, the draft law would introduce a deadline for returning prohibited donations and
would introduce compulsory enforcement of Committee’s request to transfer the value of
these donations into state budget. Finally, political parties and members of political parties
would be prohibited from using public funds for political activities of the party. Currently,
54
Estonian Government (2021), Guidelines for Ministers and their advisers to avoid conflicts of interest, paras.
12-13.
55
Information received from the Ministry of Justice in the context of the country visit to Estonia.
56
The turnout for the completion of the online course has not been promising: As of 23 February 2022, 1737
public officials have passed the e-test for the Moodle online course. In addition, there are between 4700-
7800 views for each training video in YouTube, depending on the topic, however, there is no disaggregated
data on how many of them are actually from public officials concerned by the Guidelines for conflict of
interest.
57
GRECO Fifth Evaluation Round – Compliance Report, p. 6 and 7.
58
Written contribution from the Ministry of Justice in the context of the country visit.
59
Act amending the Anti-Corruption Act 323 SE of 6.04.2021. The Ministry of Justice has identified that even
before those rules were introduced several ministries had a practice of encouraging their deputy ministers to
declare their assets, Information received from the Ministry of Justice in the context of the country visit to
Estonia.
60
GRECO Fifth Evaluation Round – Compliance Report, p. 8-9. The new amendment entered into force on the
23 April 2021.
61
Written contribution received from the Anti-Corruption Select Committee in the context of the country visit
to Estonia.
62
A legislative intent is the first step in the legislative process, and outlines the subject matter, objective,
regulatory options, impact and proposed outline of legislation to be drafted.
10
this only applies during periods of election campaigns. Following the public consultation, the
Ministry of Justice is preparing the draft law and envisages to send it to the Government by
August 2022, before tabling it at Parliament63
.
On whistleblower protection, the legislative procedure for a new comprehensive
regulation is ongoing. On 17 January 2022, the Legal Affairs Committee adopted the draft
Act on the Protection of Whistleblowers64
which was a positive step according to both the
Government and the stakeholders65
. The draft establishes the conditions and scope of
protection for whistleblowers who have become aware of an infringement in the course of
their employment. The draft stipulates the conditions and scope for obtaining protection, and
the means and channels for notification. It contains provisions on safeguarding the
confidentiality of whistleblowers also in corruption cases66
.
III. MEDIA PLURALISM AND MEDIA FREEDOM
In Estonia, the freedom of expression finds legal and formal protection in the Constitution67
.
Secondary legislation expressly ensures the right of journalists to protect their sources, fosters
media freedom in the radio and television sector68
and provides safeguards for the
independence of the public service broadcaster69
. The right to information is explicitly
recognised in the Constitution, in the Public Information Act70
and in the Personal Data
Protection Act71
. Legislation has been adopted to transpose the revised Audio-Visual Media
Services Directive (AVMSD)72
.
Estonia has adopted legislation to strengthen the independence of the media regulator –
the Consumer Protection and Technical Regulatory Authority. Amendments to the
Media Services Act and amendments to other associated acts73
, transposing the revised
AVMSD74
, which were under preparation during the previous two Rule of Law Reports75
,
were formally adopted on 16 February 2022 and are being implemented. The amended Media
Services Act entails changes in functions and competences of the national media regulator,
which has been operating as an administrative body of the Ministry of Economic Affairs and
Communications. A specific provision validates the independent and impartial status of the
media regulator in carrying out its tasks, aiming to fulfil the requirements on independence
63
Information received from the Ministry of Justice in the context of the country visit to Estonia.
64
Draft Whistleblower Protection Act 504 SE.
65
Information received from the Ministry of Justice during the country visit to Estonia.
66
This initiative has been proposed in view of aligning the national legislation with the Directive (EU)
2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons
who report breaches of Union law; Information received from the Ministry of Justice in the context of the
country visit to Estonia.
67
Constitution of the Republic of Estonia, § 44-46.
68
Media Services Act, §15 and 13.
69
Estonian Public Broadcasting Act.
70
Public Information Act.
71
Personal Data Protection Act.
72
Complete transposition of the AVMSD was notified to the Commission on 14 March 2022. Estonia ranks
4th in the 2022 Reporters without Borders World Press Freedom Index compared to 15th in the previous
year.
73
Act on Amendments to the Media Services Act and Amendments to Other Associated Acts 327 SE.
74
Directive (EU) 2018/1808 of the European Parliament and of the Council of 14 November 2018 amending
Directive 2010/13/EU.
75
2020 Rule of Law Report, Country Chapter on the rule of law situation in Estonia, p. 8; 2021 Rule of Law
Report, Country Chapter on the rules of law situation in Estonia, p. 9.
11
enshrined in the revised AVMSD76
. The media regulator reports that it is able to carry out its
tasks efficiently and that it has undergone a structural change at the end of 2021 and now
benefits from the support of a new information society division77
.
Amendments to media law enhance transparency of media ownership. The transposition
of the relevant provisions of the revised AVMSD78
introduce for the first time a specific
obligation for media companies to disclose their ownership structure, including beneficial
ownership79
. General information related to entrepreneurship, including information on
beneficial ownership of general and limited partnerships, private and public limited
companies and commercial associations80
, is electronically made available to the public for
free in the Business Register81
.
Restrictions to media ownership and concentration are limited in practice. TV and radio
companies must obtain a licence from the media regulator to operate. The detailed procedures
for operating licenses, including the grounds for their termination, are provided for in the
Media Services Act. That act does not lay down any quantitative rules for market entry or
operation, but does not allow for a license to be granted in connection with a dominant
influence over the management or if this substantially harms competition in the media
services market82
. The media regulator, which grants such activity licences, reports that
controlling concentration of media companies is primarily a task for the competition
authorities. The abovementioned provision has not been used to deny a licence for any TV or
radio company so far, and terminations of licences are very rare83
.
The independence of public service media is foreseen by law. Rules for the independence
and general conditions of employment of members of the Management Board of the public
service media are laid down in the Public Broadcasting Act. Members of the Management
Board are appointed by the Public Broadcasting Council composed of members of the
Parliament and four external experts. Political influence is minimised by the fact that a two-
thirds majority practically requiring acceptance across different political parties is needed for
the Public Broadcasting Council to appoint or dismiss members of the Management Board.
Furthermore, according to stakeholders, the dismissal rules are robust and difficult to abuse84
.
However, the MPM 2022 points out that apart from the general diversity requirement for the
Council, the Public Broadcasting Act does not provide any specific safeguards for the
appointment procedure for the Director General of the public service media85
. There is no
regulatory body to monitor the fulfilment of the public service remit but the Supervisory
Board reports annually to the Parliament’s cultural committee on the activities of the public
service media. The public service media’s provision of online news, which is not clearly
prescribed in law, has generated complaints concerning unfair competition among certain
76
Art. 30 of the revised AVMSD.
77
Information received from the Consumer Protection and Technical Regulatory Authority in the context of
the country visit to Estonia.
78
Art. 5 of the revised AVMSD.
79
In the 2020 Rule of Law Report, it was noted that in Estonia there were no specific legal provisions
requiring disclosure of ownership information and that it had raised some concerns (p. 8).
80
Pursuant to Subsections 77(1), (2) and (3) of the Money Laundering and Terrorist Financing Prevention Act.
81
Business Register is available here: https://rik.ee/en/e-business-register.
82
§ 32 of the Media Services Act.
83
Information received from the Consumer Protection and Technical Regulatory Authority in the context of
the country visit to Estonia.
84
Information received from the public service media in the context of the country visit to Estonia.
85
2022 Media Pluralism Monitor, country report for Estonia, p. 16.
12
stakeholders in the private media sector86
. The ability of the public service media to produce
public service content is threatened by staff reductions caused by insufficient funding and
current staff working beyond their capacity87
.
The right of access to information is protected by the Constitution, yet its practical
implementation continues to be subject to divergences amongst authorities. As
mentioned in the 202088
and 202189
Rule of Law Reports, stakeholders indicated that the
public administration tends to deny and/or delay access to public information in certain
cases90
. The reasons often relate to strict interpretation of data protection rules and delays
caused by a requirement for centralised responses to journalist enquiries which was further
aggravated by the COVID-19 pandemic91
. The MPM 2022 maintains a medium risk with
regard to the protection of right to information92
.
The comprehensive framework for the protection of journalists has remained stable.
Since the 2021 Rule of Law Report, the situation regarding the protection of journalists has
remained stable. The MPM 2022 notes that there have been no attacks nor public smear
campaigns against journalists93
but certain instances of defamation continue to be
criminalised94
. The Estonian procedural law95
provides for comprehensive measures to deal
with malicious actions and parties to proceedings, which can help to safeguard journalists
against abusive lawsuits96
. The Association of Journalists has launched an information
campaign to encourage journalists to report any threats to freedom of the press they may
experience97
. Challenges for journalists are particularly linked to fewer jobs in local papers,
although paid digital subscriptions have increased substantially98
. One alert has been
86
ERR news, Private media enterprises file ERR complaint with European Commission (8 September 2020);
2022 Media Pluralism Monitor, country report for Estonia, p. 22.
87
Information received from the public service media in the context of the country visit to Estonia.
88
2020 Rule of Law Report, Country Chapter on the rule of law situation in Estonia, p.8.
89
2021 Rule of Law Report, Country Chapter on the rule of law situation in Estonia, p.10.
90
According to Article 3 of the 2009 Council of Europe Convention on Access to Official Documents, any
limitation to the right of access to official documents, such as a limitation aiming to protect privacy and
other legitimate private interests, should be set down precisely in law, be necessary in a democratic society
and be proportionate to the stated objective; access to information contained in an official document should
not be refused if there is an overriding public interest in disclosure; parties to the Convention are encouraged
to consider setting time limits beyond which the limitations to the right of access to official documents
would no longer apply.
91
Information received from the Estonian Press Council and the Estonian Association of Journalists in the
context of the country visit to Estonia and 2022 Media Pluralism Monitor, country report for Estonia, pp. 9-
10. See also the 2020 Rule of Law Report, Country Chapter on the rule of law situation in Estonia, pp. 8-9
and the 2021 Rule of Law Report, Country Chapter on the rule of law situation in Estonia, p. 10.
92
2022 Media Pluralism Monitor, country report for Estonia, p. 9.
93
2022 Media Pluralism Monitor, country report for Estonia, p. 10.
94
Penal Code § 247, 275 and 305.
95
Code of Civil Procedure, § 45, 162, 168, 169, 200, 371(2), 383, 391, 423(2); Input from Estonia for the 2022
Rule of Law Report, p. 6.
96
For example, the court may reject or dismiss a statement of claim, if, based on the factual circumstances
presented as the cause of the court claim, a violation of the claimant's rights is impossible, or the court claim
has not been filed for protecting the claimant's right or interest protected by law, or with an aim subject to
legal protection by the state, or if the objective sought by the claimant cannot be achieved by the court claim.
97
Information received from the Estonian Association of Journalists in the context of the country visit to
Estonia.
98
Information received from the Estonian Association of Journalists and written contribution received by the
Ministry of Culture in the context of the country visit to Estonia; Estonian Media Companies Association
(2021), Statistics 2021.
13
published on the Council of Europe’s Platform to promote the protection of journalism and
safety of journalists99
. This concerned one case where fines were imposed by a court of first
instance on two journalists and a news outlet after they published information about pre-trial
criminal proceedings without seeking permission or informing the prosecutor’s office, which
is required under the law100
. The implications of the ruling101
were considered by journalists
to constitute an undue interference with the right to free speech and allegedly undermine
press freedom102
. The decision has since then been overturned by the appeal court103
.
IV. OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES
Estonia is a parliamentary republic with a single-chamber Parliament, where the Supreme
Court’s Constitutional Review Chamber can carry out ex-post constitutional review,
including, under certain conditions, based on a constitutional complaint104
. In addition to the
justice system, the Office of the Chancellor for Justice (ombudsperson), which has an A-
status accreditation from GANHRI105
, plays a role106
in the system of checks and balances.
Involvement of the public and stakeholders in public affairs is supported by advanced
Information and Communication Technology tools.
The project creating a new digital platform to further improve the process of enactment
of laws entered its first implementation phases. The Ministry of Justice continued the work
on the ‘Co-creation workspace project’, which aims to create a new digital platform to
improve the law-making process and improve stakeholders’ involvement in it. Even though
the current public consultation process in Estonia already takes place via an online platform,
the new project, which would replace the current online platform for public consultation, is
meant to improve the visibility of the ongoing procedures and encourage wider public
participation. Stakeholders have expressed optimism in the new platform as it would allow
them to have better overview of the ongoing open procedures for public consultations107
.
Phase I of the project offers drafters of legislation a workspace, which allows multiple
99
Council of Europe, Platform to promote the protection of journalism and safety of journalists, Estonia
100
§ 214 of the Criminal Procedure Code stipulates that information concerning pre-trial proceedings can be
disclosed only with the permission of and to the extent specified by a Prosecutor's Office and further subject
to a number of conditions. With the exception of accused or suspected parties to those pre-trial criminal
proceedings, failure to comply with said procedure may be subject to a fine.
101
Harju County Court, order of 14 April 2022, 1-22-1949.
102
European Federation of Journalists Estonia (2022), Criminal fines for journalists over public interest
reporting send dangerous signal; ERR and Estonian Association of Media Enterprises (2022), Private media
firms join ERR in public address on press freedoms.
103
The court of appeal ruled that the imposition of fines is discretionary and the court of first instance had failed
to demonstrate that they were justified in this specific case. Tallinn Circuit Court, order of 14 June 2022, 11-
22-1949. On 28 June 2022, the order of the Tallinn Circuit Court was appealed and is currently pending
before the Supreme Court.
104
§ 4 of the Constitutional Review Court Procedure Act - A complaint can be referred to the Supreme Court’s
Constitutional Review Chamber by the President of the Republic, the Chancellor of Justice, a local
government council and the Parliament.
§ 9 of the Constitutional Review Court Procedure Act - Constitutional review on the basis of court judgment
or court ruling is also possible.
105
Global Alliance of National Human Rights Institutions.
106
The Chancellor of Justice has a broad and strong mandate, including acting as the National Preventive
Mechanism under the UN Convention Against Torture and the National Monitoring Mechanism under the
UN Convention on the Rights of Persons with Disabilities. It also performs the functions as the
Ombudsperson for Children.
107
Information received from the Open Estonia Foundation, Human Rights Center Estonia and Estonian
Institute of Human Rights in the context of the country visit to Estonia.
14
editors/creators to work on the same document on the platform. From January 2022, Phase II
and III have been launched in parallel. They focus on internal cooperation between public
authorities, launching the new platform for public consultation, and on procedures regarding
EU law initiatives108
.
New legislative amendments have provided a broader basis for measures to address
health emergencies and exercise supervision. In the course of 2021, the Parliament passed
additional amendments to the Communicable Diseases Prevention and Control Act. Previous
amendments gave the Health Board and the Government powers to adopt measures for the
prevention and control of the COVID-19 pandemic109
. The 2021 amendments foresee that in
the event of a particularly dangerous infectious disease and an unavoidable necessity, the
Health Board and the Government may also close public institutions and private
establishments or restrict their activities temporarily. Besides setting the conditions for
prohibiting meetings and events, the Act also allows requirements to be established for
holding them. The new amendments also allow for involving the police and other law
enforcement agencies in the performance of the functions of the Health Board in emergencies
and emergency situations related to infectious disease epidemics. Up until these amendments
were enacted, there had been no regulation of the involvement of law enforcement authorities
and the Health Board110
. Furthermore, according to the amendments, people could also be
held criminally liable for breaching other requirements established by the Government or the
Health Board111
. As mentioned in the 2021 Rule of Law Report, all COVID-19 pandemic-
related Orders of the Government contain information on how they can be legally
challenged112
. During 2021, there were 68 complaints, one of which was closed with a final
decision, five others were closed for other reasons, in two cases there has been a judgment
but it has not become final yet and in three cases the judgments of the first instance courts
have been appealed. In 45 cases, a decision on interim relief has been made. All requests by
applicants for interim relief have been denied or decisions for interim relief have been
appealed by the Government and have been overturned by the Circuit Court113
.
On 1 January 2022, Estonia had one leading judgment of the European Court of
Human Rights pending implementation114. At that time, Estonia’s rate of leading
judgments from the past 10 years that remained pending was only at 5% and the average time
108
Written contribution from the Ministry of Justice in the context of the country visit.
109
§ 28 of the Communicable Diseases Prevention and Control Act. Amendments adopted on 12 May 2021.
110
The Health Board has been able to cooperate with them only through applications for professional assistance
or exchange of officials. The new amendments will simplify and speed up the involvement by allowing the
Government to decide on the involvement of a law enforcement agencies at the proposal of the Health
Board.
111
§ 27 and § 28 of the Communicable Diseases Prevention and Control Act.
112
“This Order can be appealed by filing a challenge pursuant to the procedure provided by the Administrative
Procedure Act within 30 days as of the day the relevant person became or should have become aware of the
Order. This Order can also be appealed by filing an action with an administrative court pursuant to the
procedure provided for in the Code of Administrative Court Procedure within 30 days as of the date of
publication of this Order”.
113
Written contribution from the Ministry of Justice in the context of the country visit.
114
The adoption of necessary execution measures for a judgment by the European Court of Human Rights is
supervised by the Committee of Ministers of the Council of Europe. It is the Committee’s practice to group
cases against a State requiring similar execution measures, particularly general measures, and examine them
jointly. The first case in the group is designated as the leading case as regards the supervision of the general
measures and repetitive cases within the group can be closed when it is assessed that all possible individual
measures needed to provide redress to the applicant have been taken.
15
that the judgment had been pending implementation was only 3 months115
. The case, pending
since September116
, concerns a failure to conduct an effective criminal investigation into
allegations of abuse117
. On 1 July 2022, the number of leading judgments pending
implementation has increased to three118
.
The civic space in Estonia remains open119 and the Cohesive Estonia Development Plan
2021-2030 replaces or integrates all previous strategies and plans. On 18 November 2021,
the Cohesive Estonia Plan 2021-2030 was adopted. The plan integrates or substitutes all
previous plans that were adopted on the same topic. The Cohesive Estonian Development
Plan120
aims, among others, at supporting the activities of Civil Society Organisations
(CSOs). The new plan, developed with the engagement of Civil Society Organisations does
not substantially differ from the previous programme121
, but its duration is extended from five
to ten years. Furthermore, the work of CSOs is supported through the National Foundation of
Civil Society, which is a state-financed civil society fund, development and support centre
that focuses on helping CSOs build their capacity to function purposefully and effectively122
.
However, the budget of the fund has not increased for years123
.
115
All figures are calculated by the European Implementation Network and are based on the number of cases
that are considered pending at the annual cut-off date of 1 January 2022. See the Contribution from the
European Implementation Network for the 2022 Rule of Law Report, p. 3.
116
The applicant’s representatives have requested the reopening of the proceedings, which is pending.
117
Judgment of the European Court of Human Rights of 22 June 2021, R.B. v. Estonia, 22597/16, pending
implementation since 2021.
118
Data according to the online database of the Council of Europe (HUDOC)
119
See rating given by Civicus, Estonia. Ratings are on a five-category scale defined as: open, narrowed,
obstructed, repressed and closed.
120
While the 2020 Rule of Law Report noted the development of the Civil Society Development Plan 2021-
2030, and the 2021 Report mentioned the launch of the Civil Society Programme 2021-2024 to replace it, in
2021, Estonia adopted the Cohesive Estonian Development Plan, which integrates a number of development
plans and strategies.
121
The plan contains actions such as promoting the ability of NGOs to collect donations, including providing
support and counselling to NGOs; making the funding for NGOs more transparent; supporting capacity
building of NGOs through offering a diversity of funding opportunities and reducing the dependency on
project grants; Estonian Government (2021), Cohesive Estonia Development Plan 2021-2030, pp. 29-31.
122
Input from Estonia for the 2022 Rule of Law Report, p. 13.
123
Information received from the Open Estonia Foundation, Human Rights Center Estonia and Estonian
Institute of Human Rights in the context of the country visit to Estonia.
16
Annex I: List of sources in alphabetical order*
* The list of contributions received in the context of the consultation for the 2022 Rule of Law Report
can be found at https://ec.europa.eu/info/publications/2022-rule-law-report-targeted-stakeholder-
consultation_en.
Centre for Media Pluralism and Media Freedom (2022), Monitoring Media Pluralism in the Digital
Era in the year 2021 – Country report: Estonia.
Civicus, Monitor tracking civic space – Estonia https://monitor.civicus.org/country/estonia/.
Council for the Administration of Courts (2022), Statistics for the workload of courts for 2021
https://www.kohus.ee/sites/default/files/dokumendid/I%20ja%20II%20astme%20kohtute%202021.a
%20menetlusstatistika_1.pdf.
Council of Europe, Platform to promote the protection of journalism and safety of journalists –
Estonia https://fom.coe.int/en/pays/detail/11709506.
Court of Harju (2021), President of the Court of Harju, Order No 11-1/21/30 - On a request by the
President of Harju County Court for referral of cases pursuant to Section 451 of the Courts Act, 7
July 2021.
Court of Harju, order of 14 April 2022, 1-22-1949.
Directive (EU) 2018/1808 of the European Parliament and of the Council of 14 November 2018
amending Directive 2010/13/EU.
Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the
protection of persons who report breaches of Union law.
Directorate-General for Communication (2019), Flash Eurobarometer 482: businesses' attitudes
towards corruption in the EU.
Directorate-General for Communication (2020), Special Eurobarometer 502: corruption.
Directorate-General for Communication (2022), Flash Eurobarometer 507: businesses’ attitudes
towards corruption in the EU.
Directorate-General for Communication (2022), Special Eurobarometer 523: corruption.
ERR and Estonian Association of Media Enterprises (2022), Private media firms join ERR in public
address on press freedoms.
Estonian Government (2021), Cohesive Estonia Development Plan 2021-2030.
Estonian Government (2021), Good Practice In Communicating With Lobbyists For Officials
https://www.korruptsioon.ee/en/conflict-interests/good-practice-communicating-lobbyists.
Estonian Government (2021), Guidelines For Ministers And Their Advisers To Avoid Conflicts Of
Interest https://www.korruptsioon.ee/en/conflict-interests/guidelines-ministers-and-their-advisors-
avoid-conflicts-interest.
Estonian Government (2022), Input from Estonia for the 2022 Rule of Law Report.
Estonian Judges Association (2022), Workload survey for I-II level judges.
Estonian Media Companies Association (2021), Statistics 2021
https://meedialiit.ee/statistika/statistika-2021/.
European Commission (2020), 2020 Rule of Law Report, Country Chapter on the rule of law situation
in Estonia.
European Commission (2021), 2021 Rule of Law Report, Country Chapter on the rule of law situation
in Estonia.
European Commission (2022), 2022 EU Justice Scoreboard.
17
European Court of Human Rights, judgment of 22 June 2021, R.B. v. Estonia, 22597/16,
ECLI:CE:ECHR:2021:0622JUD002259716.
European Federation of Journalists Estonia (2022), Criminal fines for journalists over public interest
reporting send dangerous signal.
European Implementation Network (2022), Contribution from the European Implementation Network
for the 2022 Rule of Law Report.
GRECO (2021), Fifth evaluation round – Compliance report on Preventing corruption and promoting
integrity in central governments (top executive functions) and law enforcement agencies.
Ministry of Justice, The Anti-corruption Action Plan 2021-2025
https://www.korruptsioon.ee/et/tegevuskava-aruanne-2021.
Ministry of Justice (2022), Written contribution from the Ministry of Justice in the context of the
country visit.
Reporters without Borders (2022) – Estonia https://rsf.org/en/estonia.
Supreme Court and Council for the Administration of Courts (2022), Contribution from the Supreme
Court and Council for the Administration of Courts for the 2022 Rule of Law Report.
Transparency International (2022), 2021 Corruption Perception Index.
Summary of lobby meetings -
https://www.korruptsioon.ee/sites/www.korruptsioon.ee/files/elfinder/dokumendid/kokkuvote_lobiko
htumistest_2021_kve_lplik.pdf.
18
Annex II: Country visit to Estonia
The Commission services held virtual meetings in February 2022 with:
 Anti-corruption Select Committee
 Consumer protection and Technical Regulatory Authority
 Estonian Association of Journalists
 Estonian Association of Judges
 Estonian Bar Association
 Estonian Institute of Human Rights
 Estonian Internal Security Service
 Estonian Public Broadcasting
 Estonian Press Council
 Human Rights Center Estonia
 Ministry of Culture
 Ministry of Finance
 Ministry of Foreign Affairs
 Ministry of Interior
 Ministry of Justice
 Office of the Chancellor of Justice
 Open Estonia Foundation
 Political Party Financing Surveillance Committee
 National Audit Office
 the Police and Border Guard Board
 The Prosecutor’s Office
 The Supreme Court and Council for the Administration of Courts
 Transparency International Estonia
* The Commission also met the following organisations in a number of horizontal meetings:
 Amnesty International
 Article 19
 Civil Liberties Union for Europe
 Civil Society Europe
 European Centre for Press and Media Freedom
 European Civic Forum
 European Federation of Journalists
 European Partnership for Democracy
 European Youth Forum
 Free Press Unlimited
 Human Rights Watch
 ILGA Europe
 International Federation for Human Rights (FIDH)
 International Press Institute
 Open Society European Policy Institute (OSEPI)
 Osservatorio Balcani e Caucaso Transeuropa
 Philea
 Reporters Without Borders
 Transparency International Europe