Action Plan: Montenegro Action Plan 2018-2020
Action Plan Cycle: 2018
Lead Institution: MPA The Secretariat General (SG) to the Government of Montenegro (GoM) The Union of Municipalities (UoM) Local self-governments The Tax Administration (TA) NGOs
Support Institution(s): NA
Policy AreasE-Government, E-petitions, Local Commitments, Public Participation, Regulatory Governance, Sustainable Development Goals
Commencement and completion dates: January 2019 - December 2019
MPA The Secretariat General (SG) to the Government of Montenegro (GoM) The Union of Municipalities (UoM) Local self-governments The Tax Administration (TA) NGOs
The issue at stake
Ineffective implementation of the legal framework for policy development reduces the quality of public consultations as an essential part of the process, and in turn demotivates citizen participation. A particular challenge in this context is the reporting on consultation processes and timely feedback to participants in such processes, which led to the process being perceived as closed and one-sided. By way of their layout and functionality, webpages of local self-governments should contain the set of information/data and services in line with the minimum standards to be met, which should be collected in separate Guidelines for Technical Specifications of web portals. Lack of data on customer satisfaction with provision of public services affects successful reforming of public services and may have an adverse impact on public trust in the government and lead to biased evaluation of its work. Mandatory social insurance payments (mandatory retirement and disability contributions, mandatory health insurance and unemployment insurance) fall underthe rights and obligations of workers and employers under the Law on Mandatory
Social Insurance Contributions (Official Gazette of Montenegro 13/07, 79/08, 86/09, 78/10, 14/12, 62/13, 08/15, 22/17). Citizens need quick access to check whether and in what amounts such payments have been made without any administrative hurdles or any need to physically visit relevant institutions.
The above commitment requires opening new online tools for public consultations in policy-making process – a userfriendly and quick means of interactions between the public administration and business association, CSOs, the academia and the general public. It is expected that e-Participation and e-Petitions tools will be used more by individuals and institutions in developing and revising policies, and for filing petitions at the local and central levels. Standardisation of web-based portals facilitates communication processes, creates a relevant online information and service tools at the local level aimed at achieving greater consistency. Measuring customer satisfaction with public services implies assessing expectations, service quality and effects of service delivery in different areas of customer experience to give timely feedback to public institutions by examining citizen attitudes in service efficiency, staff approachability, usefulness of the information obtained, etc. “Does Your Employer Pay Contributions?” online service and mobile app will ensure timely information and response by workers to protect their labour rights through inspection of data on payments of mandatory contributions, registration/deregistration dates, updating of other data and preliminary checks of M4 forms without any need physically visit the relevant service provider.
How will it help address the issue
Fostering e-democracy implies additional encouragement of citizens in a social process and passing of decisions affecting their lives and community viability. E-participation enables more transparent and easier involvement in public consultation processes in shaping public policies in line with applicable legislation. E-petition, as a free online tool for petition generation and endorsement, and delivery to decision-makers, offers an additional option for proposing solutions for better functioning of a community or parts thereof.
Standardised local self-government portals will bring closer and make more consistent the online presentations of municipalities, adding to recognisability and boosting interactions with citizens, opening in functional terms new channels for feedback on various aspects of public policies and service provision. Surveys of citizens and business satisfaction with services provided by the administration and public institutions will be used to optimise business processes and streamline existing administrative and other procedures and relieve the red tape for citizens and businesses. Detection and reporting of infrastructural problems foster civic responsibility, help increase safety, protect environment and by extension, improve living and working conditions. Introduction of the online service and mobile application “Does Your Employer Pay Contributions?" provides for the necessary level of control and responsibility of citizens/workers for protection of own rights.
Its relevance to OGP values
The above commitment (with the accompanying actions) is fully compatible with the principles of transparency and public participation, since it has practical consequences to daily lives of common people and their guaranteed rights.
Compatibility with SDGs Reference to SDG 16: ‘Peace, Justice and Strong Institutions’ 16.6 – Develop effective, accountable and transparent institutions at all levels 16.7 – Ensure responsive, inclusive, participatory and representative decision-making at all levels The actions to be taken under this commitment will reinforce decision-making by policy-makers in consultations with members of the public, the civil society, businesses, the academia and other stakeholders. This commitment is consistent with the GoM’s strategic orientations as set in the 2018-2020 PAR Strategy and the 2018- 2020 Strategy for Creating an Enabling Environment for the Work of NGOs and the accompanying Action Plan, as well as the DEU-supported project “Technical Cooperation for the Development of Institutional Mechanisms for the Cooperation between the Government and Civil Society Organisations in Montenegro” in reference to the component on strengthening legislative and institutional framework for public consultations.
Actions with verifiable results and implementation dates
2.1. e-Participation’ (MPA) - €20,000 - at least 30 public calls for consultations with the interested public published annually - at least 30 public calls for consultations on draft laws published annually - at least 100 comments provided by the interested public using this service in 2019 - at least 50 public calls for NGO participation to working groups published - the 2019 annual report on the implementation of the Decree on Selecting NGO Representatives to Working Bodies of State Administration Authorities and Public Consultations while Drafting Laws and Strategies made with the recommendations and evaluations in line with the findings
2.2. e-Petitions (MPA and SG to GoM) – €30,000 - extend the platform to include local self-government units and upgrade the service, putting in place the assumptions for its further upgrade -e-Petitions introduced a the local level
2.3. Standardisation of local self-governments’ web portals (MPA and UoM) - €1,150 - guidelines developed – Standardised Guidelines for local web portals - training for implementing the Standardised Guidelines delivered - monitor the implementation of the Standardised Guidelines in line with the recommendations for minimum standards in regard to the web portal contents (information posted, services available, databases, local budget, etc.)
2.4. Customer satisfaction surveys at the point of service, and result analysis using appropriate tools – €2,000 - 4 institutions where customer satisfaction survey tools will be installed in 2019 identified - customer satisfaction survey tools in place for 30% of services provided in each institution covered - presentation of findings and recommendations
2.5. Ensure citizen participation in detection and addressing infrastructure issues at the local and central levels (MPA, LSG, NGO) - €15,000 - an online tool for reporting infrastructural issues/deficiencies or launching initiatives developed - 20% more reports - 80% reports acted upon
2.6. Set up the “Does Your Employer Pay Contributions?" application and the online tool for checking M4 forms(Tax Administration, Pension and Disability Fund) – €20,000 - the tool available at the web portal and Tax Administration and Pension and Disability Fund’s webpages - generate statistical reports on the use of the tool to be published in Tax Administration’s annual activity reports
Points of contact
Responsible person in the implementing entity Mirjana Begović, Marija Janković, MPA
Title/Department The Directorate for e-Government and Information Safety The Directorate for Good Governance and Interactions with NGOs
e-mail / phone mirjana.begovic@MPA.gov.me marija.jankovic@MPA.gov.me
IRM Midterm Status Summary
Language of the commitment as it appears in the action plan:
“The above commitment requires opening new online tools for public consultations in policy-making process a user- friendly and quick means of interactions between the public administration and business association, CSOs, the academia and the general public. It is expected that e-Participation and e-Petitions tools will be used more by individuals and institutions in developing and revising policies, and for filing petitions at the local and central levels.
Standardization of web-based portals facilitates communication processes, creates a relevant online information and service tools at the local level aimed at achieving greater consistency.
Measuring customer satisfaction with public services implies assessing expectations, service quality and effects of service delivery in different areas of customer experience to give timely feedback to public institutions by examining citizen attitudes in service efficiency, staff approachability, usefulness of the information obtained, etc.
Does “Your Employer Pay Contributions?” online service and mobile app will ensure timely information and response by workers to protect their labor rights through inspection of data on payments of mandatory contributions, registration/deregistration dates, updating of other data and preliminary checks of M4 forms without any need physically visit the relevant service provider.”
2.1. e-Participation (online public consultations on Governments portal).
2.3. Standardization of local self-governments web portals.
2.4. Customer satisfaction surveys at the point of service, and result analysis using appropriate tools.
2.5. Ensure citizen participation in detection and addressing infrastructure issues at the local and central levels.
2.6. Set up the “Does Your Employer Pay Contributions?" application and the online tool for checking M4 forms.
Start Date: November 2018
End Date: August 2020
Context and Objectives
The commitment enhances public participation in different cycles of policy-making in Montenegro. Firstly, it introduces public consultation mechanisms and online petitions at the local level. Secondly, it standardizes local government data portals and government data on tax spending to comply with international standards. Finally, it includes customer satisfaction surveys to inform public service delivery and detect infrastructure issues through an online public participation tool.
Montenegro adopted a decree on public consultations in July 2018 and created an online participation platform to facilitate public consultations.  However, citizens still face difficulties in accessing data on local government services and tax spending. Moreover, according to a 2019 SIGMA monitoring report on public services in Montenegro, there is currently no consistent practice for collecting data on user satisfaction to improve service delivery.  Furthermore, the 2019 Balkan Barometer indicates that Montenegrins are less satisfied with public service accessibility via digital channels than with public services in general. 
The commitment proposes several activities to address these issues. It commits to publish at least 60 calls for public consultations and receive at least 100 public comments in 2019. It also calls for extending the government’s e-petition portal (Citizen’s Voice e-Petition) to include local self-governments units. Lastly, the government plans to conduct citizen satisfaction surveys to identify recommendations in four institutions and introduce a new online tool for reporting infrastructure issues at the local and central levels.
Indicators are clear and use specific targets to measure the effects of the new tools. The commitment is relevant to the OGP value of civic participation, as it creates new possibilities for the public to engage in policymaking by extending the e-petitions portal to include local self-government units.
Overall, this commitment has a moderate potential impact on public participation in Montenegro. Importantly, this commitment prioritizes local government, which according to a study of Civic Alliance, has proven to be the “natural start” for citizen participation processes in Montenegro.  This commitment could improve opportunities for citizens to submit petitions and comment on draft laws. The government’s Citizen’s Voice e-Petition  portal was created in 2012 with the support of UNDP, but has seen limited use.  The proposed reduction of the minimum number of votes a petition must receive in order to require the government to respond (from 6,000 to 3,000) could reinvigorate use of the portal.  Furthermore, the extension of the portal to include local self-government units could improve opportunities for participation at the local level.
However, many of the initiatives proposed in the commitment (such as the standardization of data and the use of services to improve service delivery) are already part of public administration reforms and the Law of Administrative Procedures.  Additionally, the government’s reluctance to address authentic public initiatives in the past causes doubts about the government’s intention to address public initiatives going forward.  A representative of the Center of Democratic Transition supported this statement and provided an example of a previous petition from civil society that proposed the government remove the secrecy classification from the Housing Commission Act, which was dismissed.  Furthermore, according to a representative of the Institute of Certified Accountants (ISRCG), currently only citizens with electronic certificates can access the information under Milestone 2.6, and in next three years, a new IT system will provide this information. Parallel with this new IT system, the planned introduction of a new ID system will include electronic certificates. At the moment, without these two components, the Tax Administration will not allow access to such information due to the EU’s General Data Protection Regulation (GDPR). 
Given the potential impact of this commitment to improving citizen participation, the IRM recommends carrying it forward to the next action plan. However, it is important that the government responds to all e-petitions that meet the minimum threshold of votes. Moreover, the government could conduct citizen dialogue or communication campaigns to promote trust, as some reports and NGO representatives have identified a lack of confidence in models of public participation.  Lastly, the IRM recommends rolling out legally required consultations on all draft laws and cover bylaws.
 OECD, Monitoring Report: The Principles of Public Administration (May 2019), http://www.sigmaweb.org/publications/Monitoring-Report-2019-Montenegro.pdf.
 Regional Cooperation Council, Balkan Barometer 201 – Infographics (2019), https://www.rcc.int/pubs/87/balkan-barometer-2019--infographics.
 Edin Koljenović, Analysis: Implementation of online tools for e-Participation in Montenegro (Boris Raonić, Apr. 2015), http://www.gamn.org/images/docs/en/Analysis-Implementation-of-online-tools-for-e-Participation-in-Montenegro.pdf.
 PR Service, “‘Citizen's Voice e-Petition’ platform is active again” (2 Apr. 2019), http://www.mju.gov.me/en/search/197879/Citizen-s-Voice-e-Petition-portal-is-active-again.html.
 UNDP Montenegro, “Democratic society & accountable institutions” (accessed 4 Feb. 2020), https://www.me.undp.org/content/montenegro/en/home/ourwork/democraticgovernance/in_depth.html.
 PR Service, “‘Citizen's Voice e-Petition’ platform is active again.”
 Representative of NGO Institut Alternativa, interview by IRM researcher, 11 Sept. 2019.
 Milena Gvozdenovic, Centre for Democratic Transition, emails with IRM staff, 14 Feb. 2020.
 Information provided to the IRM by Igor Pavicevic, Institute of Certified Accountants, during the pre-publication period of this report, 19 March 2020.
 Edin Koljenović, Analysis: Implementation of online tools for e-Participation in Montenegro.
National Identification Document (NID)
ME0057, 2018, Access to Justice
ME0058, 2018, E-Government
Proactive Publication of Information
ME0059, 2018, Access to Information
Efficient Collection of Administrative Fees
ME0060, 2018, Access to Justice
Electronic Tax Returns
ME0061, 2018, E-Government
Improved Anticorruption Policies
ME0062, 2018, Access to Information
Non-Governmental Participation in the Privatisation Council
ME0001, 2012, Public Participation
Establishment of Electronic Enterprise Registration
ME0002, 2012, E-Government
Merging of Inspectorates and Extracting Them from Ministries and Administration Authorities
ME0003, 2012, Private Sector
Implementation of New Building Permit Legislation
ME0004, 2012, Private Sector
Establishment of Special Body to Support Investment and Development Projects
ME0005, 2012, Private Sector
Create e-Register of Licenses
ME0006, 2012, E-Government
Adopt Regulations for Registry Maintenance
ME0007, 2012, Legislation & Regulation
Development of an Action Plan with Measures to Improve Regulatory Framework in Montenegro
ME0008, 2012, Legislation & Regulation
Quarterly Evaluation of Implementation of That Action Plan
ME0009, 2012, Legislation & Regulation
Train Civil Servants in RIA
ME0010, 2012, Capacity Building
Apply RIA in Preparation of the Work Programme of the Government
ME0011, 2012, Legislation & Regulation
‘Full RIA’ Is Implemented for All Laws
ME0012, 2012, Legislation & Regulation
Employment of Foreigners Reform
ME0013, 2012, Citizenship & Immigration
Concessions and Public-Private Partnership: Regulatory Framework
ME0014, 2012, Legislation & Regulation
Concessions and Public-Private Partnership: Regulation on Procedure
ME0015, 2012, Legislation & Regulation
Affirm and Advance Existing Functions of the E-Government Portal
ME0016, 2012, E-Government
e-Government Portal: More Complex Electronic Services Available at the Portal and Acceptance of Electronic Documentation
ME0017, 2012, E-Government
e-Government Portal: Enable Citizens to Have an Active e-Participation in Creation of Laws and Other Strategic Documents
ME0018, 2012, E-Government
Established Online Platform for e-Petitions
ME0019, 2012, E-Government
e-Petitions: Online Platform Is Made Fully Efficient
ME0020, 2012, E-Government
Southeast Europe Regional Forum
ME0021, 2012, Capacity Building
ME0022, 2012, Public Participation
Direct Contact with Non-Governmental Organisations
ME0023, 2012, Civic Space
Systems to Improve Direct Contact with Citizens
ME0024, 2012, Public Participation
Free Access to Information
ME0025, 2012, Access to Information
Plain Administrative Language
ME0026, 2012, Capacity Building
Preventing Conflicts of Interest: Raising Public Awareness
ME0027, 2012, Anti-Corruption
Preventing Conflicts of Interest: Training for Public Officers and Public Campaigns
ME0028, 2012, Anti-Corruption
Preventing Conflicts of Interest: Political Independency of the Commission for Prevention of the Conflict of Interest
ME0029, 2012, Anti-Corruption
ME0030, 2012, Anti-Corruption
Application of Code of Ethics: Establish an Ethical Board, as an Independent Body
ME0031, 2012, Anti-Corruption
Application of Code of Ethics: Code of Ethics Training for Civil Servants
ME0032, 2012, Anti-Corruption
Application of Code of Ethics: Ensure Application of the Code of Ethics Through Operation of Disciplinary Bodies and Periodic Check
ME0033, 2012, Anti-Corruption
Application of Code of Ethics: Strengthen Tax Administration and Customsadministration Internal Control Mechanisms
ME0034, 2012, Anti-Corruption
Transparency of Criteria for Employment, Bonuses, and Promotion in the Public Sector
ME0035, 2012, Anti-Corruption
Reporting on Unpermitted Building Construction
ME0036, 2012, Infrastructure & Transport
Protection of Persons Reporting Corruption
ME0037, 2012, Anti-Corruption
Procurement Corruption: Help Desk
ME0038, 2012, Anti-Corruption
Procurement Corruption: Regulation and Awareness-Raising
ME0039, 2012, Anti-Corruption
Establishing Central Public Procurement Bodies
ME0040, 2012, Anti-Corruption
Electronic Public Procurement System
ME0041, 2012, Anti-Corruption
Budget Transparency: Amend the Organic Law on Budget with Precise Deadlines and Specific Fiscal Rules
ME0042, 2012, Fiscal Openness
Budget Transparency: Presentation of the Annual Budget and Its Revisions in a Visually Comprehensible and Simple Manner
ME0043, 2012, Fiscal Openness
Budget Transparency: Identify and Develop Performance Indicators
ME0044, 2012, Fiscal Openness
Budget Transparency: Amend the Chart of Accounts to Improve the Expenditure Control
ME0045, 2012, Fiscal Openness
Budget Transparency: Improve Cooperation Between the Internal Audit System and State Audit Institution
ME0046, 2012, Fiscal Openness
Combatting All Forms of Discrimination: Carry Out Activities Defined in the Signed Memorandum of Cooperation with the NGOs
ME0047, 2012, Civic Space
Combatting All Forms of Discrimination: Trainings for Police Officers for Professional Conduct with LGBT Persons
ME0048, 2012, Capacity Building
Combatting All Forms of Discrimination: Trainings for Police Officers Related to Disabled Persons
ME0049, 2012, Capacity Building
Combatting All Forms of Discrimination: Free-Up Public Traffic Areas Used by Disabled. Define Procedures for Control of Passengers & Vehicles
ME0050, 2012, Human Rights
Combatting All Forms of Discrimination: Adjust the Security Centre in Accordance with Disabled Persons’ Needs and Appoint a Contact Person
ME0051, 2012, Human Rights
Improving Media Freedoms
ME0052, 2012, Civic Space
Corporate Social Responsibility (CSR)
ME0053, 2012, Private Sector
Support to CSR in Montenegro
ME0054, 2012, Private Sector
Organisation of Workshops on Corporate Social Responsibility
ME0055, 2012, Capacity Building
Development of Manual
ME0056, 2012, Capacity Building