Brussels – With the glitter and dust of the long-awaited proposal eventually settled, it is time to take stock of the lights and shadows of the Commission’s newly presented communication on the pre-enlargement policy reviews.
From the gradual integration of current candidate countries into the EU’s Internal Market to a new set of safeguards in the Accession Treaties of future member states. From partially limiting Ukraine’s market access for sensitive agricultural products to the use of passerelle clauses to move towards qualified majority voting (QMV) in selected areas of the Council’s decision-making.
Delving deeper into the communication can help us understand where the weakest points of this strategy lie, and which elements could provide the foundation for a new approach to both enlarging and reforming the Union.
Nothing completely new, yet not useless
Especially on governance, the vast majority of the proposed elements are well-known “since the Belgian Presidency of the Council in 2024,” Maria Gargano, researcher at the Egmont Institute, explains to The New Union Post. Passerelle clauses, enhanced cooperation and greater use of qualified majority voting, especially during the intermediate stages of the enlargement process, are all “familiar.” What could be “highly promising, or at the very least proactive,” is the pledge to review proposals that are currently blocked, in light of the possible use of enhanced cooperation.
Michael Emerson, Associate Senior Research Fellow at the Centre for European Policy Studies (CEPS), agrees that there are “some useful proposed advances” in the methodology, including the indicative roadmaps for Montenegro, Albania, Moldova and Ukraine to be detailed in the 2026 Enlargement Package. However, as they are expected to specify only when clusters should be closed, rather than when countries could finally join, “two cheers only, not three,” he highlights.
Are 15-year safeguards just postponing the problems?
The shadows emerge when considering the suggestions for admitting new members without the risk of them backsliding on the commitments undertaken during the accession negotiations. Apart from revisiting the three existing sectoral safeguards used in previous enlargements, the Commission proposed establishing a new institutional safeguard to address “serious breaches” of EU values, which would be available for the first 15 years after accession.
Such a safeguard “buys the Union time,” notes Corina Stratulat, Associate Director of the European Policy Centre (EPC). But if the Union does not close its own enforcement gaps, what will make the ordinary mechanisms sufficient fifteen years later?
There is a persuasive case for an additional credible safeguard. It can “reassure existing members and make ratification politically possible,” while protecting citizens in new member states “against governments dismantling the institutions strengthened during accession.” It must also be noted that the Commission does not propose unlimited discretion in its use, and this should be carefully reflected in the new Accession Treaties “and applied when political pressure rises.”
At the same time, fifteen years extends “well beyond an initial adjustment period” that normally brings a certain level of asymmetry and that can be justified only by the normal need for a transition to membership. More importantly, time does not itself protect democratic institutions, and backsliding is not confined to new members. “When the special clause expires, the underlying weakness may remain,” and whether the safeguard also builds a more resilient Union “depends on what the EU does with that time.”
A step forward, but not enough for a Treaty change
With all their potential limitations, accession safeguards may represent the first building block of a credible programme to strengthen governance enforcement across the European Union. As highlighted by Janis Emmanouilidis, EPC Deputy Chief Executive, the communication on pre-enlargement policy reviews “is a step forward,” particularly because the Commission proved to be “more concrete about internal reform.”
However, being more concrete does not necessarily mean that this is enough, as the EU executive falls short of adopting an approach that does not simply remain “within the boundaries of what seems politically achievable today.” And this could represent a problem within the Council.
Emmanouilidis offers two examples in this regard. Activating the passerelle clause – a legal mechanism that allows a shift in decision-making procedures without a formal amendment of the Treaties – itself requires a unanimous decision, while allowing it to be activated by some form of super-qualified majority would make it a more credible instrument. The same can be said for replacing the unanimity requirement for activating the suspension clause under Article 7 of the Treaty on European Union with a super-qualified majority, making the mechanism harder to block.
It is clear that both reforms would require Treaty change. Yet, while the Commission “now explicitly supports Treaty change where needed,” it refrains from exploiting the possibilities of “where and how the Treaties themselves should be reformed.”
Financial strains and the Ukraine issue
Another area where the Commission lacked ambition is strengthening Europe’s common financial capacity – “whether inside or outside the Union framework,” Emmanouilidis warns. An enlarged Union operating in a “far more demanding strategic environment” would need more financial resources to provide essential European public goods than the proposed €43.2 billion under the new Global Europe Instrument within the 2028–2034 Multiannual Financial Framework (MFF).
“The temptation to avoid another difficult institutional debate is understandable, but avoiding the debate will not make the delivery gap disappear.” More importantly, if the status quo is set to remain, the risk is that anti-European and illiberal forces – such as Alternative für Deutschland in Germany and Rassemblement National in France – will be able to promote their vision more forcefully, “shifting power back to national capitals and hollowing out the EU from within.”
On the financial side of the communication, there is another issue that deserves more detailed analysis (it will be explored here soon, stay tuned). For Ukraine, the Commission warns that targeted arrangements should significantly limit financial support and market access for sensitive agricultural products. As EPC’s Stratulat told The New Union Post, this could become both a practical way to ease opposition among existing members and a source of political friction with Kyiv. “The design will determine whether it helps secure accession or undermines the promise of membership.”
What pre-enlargement gradual integration can achieve
A final interesting point concerns the gradual integration of the current candidate countries. The Commission’s proposal doubles down on market convergence “as an interim step to membership” and, to make that offer more credible, proposes tighter timelines with target dates for accession “as an add-on,” Dimitar Bechev, Senior Fellow at Carnegie Europe, highlights.
It is true that the proposal is not entirely new, as frontloading the benefits of the Single Market has already been experimented with, particularly through the Growth Plans for the Western Balkans and Moldova. However, if EU membership becomes a long and drawn-out prospect, prioritising market integration “could boost growth on all sides and forge closer political and institutional bonds.”
Yet compliance with EU standards remains a critical priority in Brussels. Market access comes with strings attached in areas such as judicial reform, anti-corruption, government accountability and regulatory alignment. Here, legal questions arise. Would non-EU members accept the jurisdiction of the European Court of Justice, unlike the members of the European Economic Area (EEA)?
If these proposals are implemented, they will de facto create something close to associate EU membership – an arrangement whereby a country is deeply integrated into the Union, with some voice in its institutions and the option of joining at a later date, as recently debated following a letter by German Chancellor Friedrich Merz. It is not clear, in any case, how countries such as Serbia, Türkiye and Georgia will stop playing both sides with China and Russia and commit fully to EU membership.
Heather Grabbe, Senior Fellow at Bruegel, echoes this question when analysing the strategic alignment with EU values, laws and interests required of the candidates. From now on, deeper economic integration depends not just on meeting technical standards and complying with EU rules, but also on being “a reliable ally in foreign policy and security, both before and after becoming a member.”
In practice, this could mean “a clear penalty” for governments choosing to serve Russian interests, with application of EU sanctions on Russia “an important test of alignment.” The three aforementioned countries all fail this test. Grabbe points to the elections in Serbia on 25 October as a potential first test of the Commission’s more geopolitical approach. At the same time, this attitude could show voters the benefits of having pro-European governments, as in Moldova.
The founding idea is that countries with strong democratic fundamentals and the rule of law are less vulnerable to foreign interference. By improving governance, the rule of law and respect for EU values before accession, the hope in Brussels is to make the candidates “less easy prey and avoid the takeover of state institutions by a single party.” Not least, reducing opportunities for corruption is also “vital” to ensure the proper use of EU funds.
