Within the public consultation process, we submitted comments, proposals and suggestions to the Ministry of Finance on the Draft Strategy for Improving Public Procurement and Public-Private Partnership Policy for the period 2026–2030.
In our submission, we highlighted the need to strengthen the legal framework for preventing corruption in the public procurement system, in particular by clearly defining the competences of the Agency for the Prevention of Corruption (APC) with regard to verifying the accuracy of declarations on the absence of conflicts of interest in tender procedures. Taking into account the planned improvements to the legislative framework and the planned interconnection of the Public Procurement Portal (CEJN) with the APC’s databases, we consider it necessary to introduce a clear legal obligation to verify such declarations in order to ensure their substantive oversight.
We also proposed further development of digital solutions through the introduction of a “red flags” module, including the establishment of a publicly accessible list of bidders who have breached contractual obligations or who are subject to European Union sanctions. In addition, we recommended that the Strategy provide for the enhancement of CEJN to enable the downloading of data and documentation in open formats.
Furthermore, we pointed to the need to introduce advanced and specialised training programmes for police officers responsible for detecting and investigating corruption in the field of public procurement, with the aim of strengthening institutional capacities and ensuring more effective criminal prosecution of corruption.
Our comments on the Draft Strategy (in Montenegrin) are available here.