Author: Фондација Метаморфозис

  • Open your AIs: responsible use of AI tools by youth organisations discussed in Strasbourg

    Youth organisations across Europe are taking a proactive step toward ensuring ethical and human rights-based use of artificial intelligence. The study session, “Open your AIs: responsible use of AI tools by youth organisations”, is taking place at the European Youth Centre Strasbourg (EYCS) from 23 to 27 June 2025 with the aim to spark critical discussions around Artificial Intelligence (AI) ethics and empower youth groups to adopt internal standards rooted in the protection of young people’s rights.
    As AI tools increasingly shape how youth organisations operate, this initiative underscores the need for conscious and informed usage by that ensuring technology serves young people rather than putting their rights at risk. The study session also draws on the principles of the Council of Europe’s newly adopted AI Convention, helping prepare the youth sector to act as advocates and watchdogs in this rapidly evolving landscape.
    The study session pursues three key objectives: helping youth organisations remain vigilant and responsible when integrating AI into their work; supporting them to become vocal advocates for AI ethics within their structures and among their beneficiaries and building knowledge to navigate and contribute to key policy processes like the EU AI Act and the Council of Europe’s AI Convention, especially considering growing concerns around AI-driven discrimination.

    By bridging policy with practice, the study session aims to position youth organisations as meaningful contributors to ethical AI governance and protectors of young people’s digital rights.
    The study session is truly remarkable experience for the participants, offering a unique opportunity to engage also with staff members of the Council of Europe secretariat from various Units. They met representatives who shared insights into the organisation’s work on the AI Convention, the intersection of artificial intelligence with hate speech and hate crime, and the various forms of support available through the European Youth Foundation. Participants also explored pathways for meaningful youth advocacy at multiple levels, learning how they could get involved in the Council of Europe’s distinctive co-management structure either by applying to join the Advisory Council on Youth or by ensuring representation through their organisational networks.
    Many participants reflected on this meeting saying that the exchange was impactful, affirming the importance of including young people in policy-making processes that shape their today and the future.

    Link to the original text: Open your AIs: responsible use of AI tools by youth organisations discussed in Strasbourg – Youth

    The study session is organised within the Youth for Democracy programme in cooperation with Connect International in with partner Curiosite Centre de Formation and expertise of Metamorphosis Foundation.

  • Building a Resilient and Trusted Information Ecosystem Requires Collective Action

    Disinformation, information manipulation, and foreign influence (FIMI) continue to erode public trust, deepen social divisions, and weaken North Macedonia’s democratic processes and EU aspirations. Without decisive and coordinated action, the information manipulation industry will keep evolving, outpacing regulation and exploiting systemic vulnerabilities.
    This was the central message of today’s validation meeting in Skopje, which focused on the draft report “Enablers and Incentives of Election-Related FIMI in North Macedonia.” The event brought together representatives of public institutions, media, civil society, and international organizations to review the findings and strengthen the report through participatory dialogue.
    In her opening remarks, Khushbu Agrawal from International IDEA highlighted the broader scope of the initiative:
    “This report by our partner Metamorphosis is part of a larger project on FIMI supported by Global Affairs Canada. While it’s not the first report on the topic in the country, we are trying to create a ‘one-stop shop’ that consolidates all relevant knowledge and research related to electoral FIMI in North Macedonia, particularly the vulnerabilities and incentives that enable it to take root and thrive”, said Agrawal.
    Goran Rizaov, Program Manager for Information and Media Integrity at Metamorphosis and co-author of the report, presented the methodology developed by International IDEA, based on distinguishing enablers and incentives of FIMI.
    “Despite other things, we also aimed to explain how gender-based disinformation, the use of AI, and global linkages are leveraged to manipulate information in an election context. Political polarization, often along ethnic or interethnic lines, as well as systemic corruption, weaken institutional resilience. Implementation of electoral reforms is poor, and misuse of public resources remains widespread”, said Rizaov.
    Matej Trojachanec, Goran Rizaov and Despina Kovachevska | Photo: Vancho Dzambaski, CC BY
    Despina Kovachevska and Matej Trojachanec, researchers from Metamorphosis, and also co-authors of the report presented the insights on societal enablers and social networks, with additional focus on gender narratives and AI-generated disinformation.
    Kovachevska emphasized the use of fear-based messaging targeting women and LGBTI+ communities:
    “We’ve seen narratives claiming that if North Macedonia joins the EU, children will be turned transgender, or girls will be forced to dress like boys. In pro-Russian disinformation, Ukrainian women are portrayed as heroes staying to fight, while men are shown as cowards fleeing. When attacking President Zelensky, disinformation often targets his wife and her alleged spending. There’s a broader theme of contrasting the ‘traditional mother’ with the ‘Western woman’—single, selfish, and even demonized through religious narratives”, Kovachevska said.
    “These gendered narratives build on fear: fear of vaccines, fear of the West, fear of ‘moral decay’. Low media literacy, which is in decline, allows such manipulative content to flourish,” she added.
    Rizaov also spoke about the fragility of the media landscape:
    “Independent outlets are nearly unsustainable. There’s an illusion of pluralism due to the high number of media outlets, but in reality, they are often politically or commercially aligned. Copy-paste journalism dominates mainstream media. If all you’re doing is copying content, manipulation can easily slip through—especially if it originates from a powerful center of influence”, said Rizaov.
    Trojachanec explored how social media algorithms and generative AI are shaping the disinformation ecosystem:
    “The platforms amplify extreme content based on user behavior. While we haven’t yet seen deepfakes targeting local politicians, we’ve identified AI-generated videos promoting fake medicines, often using voices cloned from well-known doctors. These are mostly adapted from Bulgarian-language templates, making them relatively easy to detect. Still, the use of AI in this context remains limited—for now.”
    The event concluded with a set of policy recommendations aimed at public institutions, the media sector, tech platforms, and civil society. These focus on improving legislation, media independence, digital transparency, and public awareness, while calling for stronger cross-sectoral cooperation and alignment with EU regulatory standards.

  • Metamorphosis took part in a public hearing regarding key laws of the digital realm

    Today, June 19, 2025, the Committee on transport, digital transformation, environment and spatial planning held its 35th session. A public debate was held at the session on the topic “Draft Law Reform Package for the Digital Transformation of the Republic of North Macedonia,” and the following draft laws were reviewed and discussed: Draft Law on Electronic Communications; Draft Law on the Security of Network and Information Systems; Draft Law on Archives and Archival Activities; and Draft Law Amending and Supplementing the Law on Electronic Documents, Electronic Identification and Trust Services.
    In addition to the members and deputy members of the Commission, MPs, the Minister of Digital Transformation, and representatives of line ministries, agencies, constituent bodies, and the business and academic communities, the public hearing was also attended by representatives of civil society. Filip Stojanovski, Partnership and Resource Development Director, and Marijana Jancheska-Ugarkovikj, Project Manager, presented the recommendations and suggestions of the Metamorphosis Foundation regarding the draft laws under discussion.

    In her address, Ms. Jancheska-Ugarkovikj emphasized that the Metamorphosis Foundation for Internet and Society supports the process of adopting the package of four laws and welcomes the Parliament’s initiative to include civil society organizations in the process of structured discussions to improve the draft text of the proposed laws.
    In her address, Jancheska emphasized that it is important that all envisaged legal solutions are aligned with European regulations, but also adapted to the local context in order to respond to the real challenges of citizens, institutions, and the private sector. She also pointed out the need for clear obligations for the implementation of security measures by institutions, transparency in the processing of sensitive information, accountability of service providers and interoperability of technical solutions.
    The Metamorphosis Foundation believes that digital transformation is not just a technological tool, but a prerequisite for efficient, transparent, and accountable administration. To this end, it is necessary to systematically involve civil society organizations and experts in all phases of reforms–from design to evaluation–as well as invest in the capacities of public administration and promote digital literacy among all categories of citizens.

  • First Meeting of the National Consultative Mechanism for the Reform Agenda (NCM-RA)

    The implementation of the Reform Agenda in North Macedonia requires an inclusive approach and input from all relevant stakeholders to ensure its successful implementation. To this end, the European Policy Institute – EPI, in cooperation with the Ministry for European Affairs, on May 19, organized the First Meeting of the National Consultative Mechanism for the Reform Agenda 2024-2027–a new national platform that enables a structured, transparent, and inclusive evidence-based dialogue between state institutions, civil society organizations, chambers of commerce, academia, and other relevant factors for the implementation and monitoring of the Reform Agenda within the framework of the EU Growth Plan for the Western Balkans.
    Mila Josifovska Danilovska and Marijana Jancheska-Ugarkovikj, from the Metamorphosis Foundation, participated in the meeting. Jancheska-Ugarkovikj presented the findings of the Metamorphosis research on the progress made so far in the field of digitalization, as a key area in the Reform Agenda. The research presents the results from 2025 divided into key sub-areas of digitalization: digitalization and cybersecurity, as well as the planned activities for 2026 and 2027.
    Jancheska-Ugarkovikj, in addition to presenting the achievements, shared with the attendees the recommendations that emerged from the public policy document. Greater inclusiveness is needed, especially in digital accessibility for people with disabilities, in accordance with the National Strategy 2023–2030. Furthermore, the involvement of civil society organizations and experts in all phases of the envisaged reforms should be strengthened–from design to evaluation, while transparency and timely communication should also be ensured when creating regulations. In order to implement the commitments of the Reform Agenda in depth, it is necessary to invest in training and technical support for the administration for efficient implementation, as well as to adapt laws to the local context, instead of mechanically adopting European regulations. At the same time, digital literacy should be actively encouraged among all categories of citizens.
    Digitalization is not just a technical tool–it is a prerequisite for efficient, transparent, and accountable administration. As the Metamorphosis Foundation, we remain committed to following the process and contributing to reforms that will be in the interest of all citizens.

  • Second cybersecurity training for civil society organizations

    On May 7, 2025, the Metamorphosis Foundation organized a one-day training on improving cybersecurity in civil society organizations. The training was aimed at civil society organizations that actively work with vulnerable categories of citizens and face increased risks in the digital space.
    Fifteen representatives of civil society organizations had the opportunity to learn about the concept of digital fingerprinting, the importance of antivirus protection, creating and maintaining strong passwords, using password managers, as well as practical advice for strengthening cybersecurity and developing habits for regular cyber hygiene.
    This training is part of the project “CyberShield: Empowered Citizens for Cyber ​​Resilience,” which aims to increase the awareness and resilience of citizens and organizations to cyber threats, through education, public information, and practical resources. The project envisages three such trainings, the first of which was held on April 9, while the last, third training, will be held on June 4. In addition to the trainings, the project will also prepare podcasts and videos to promote public awareness and understanding of the importance of cybersecurity.
    The aim of the project is to emphasize the importance of regular cyber hygiene and effectively dealing with cyber threats such as phishing, social engineering, malware, identity theft, etc. Through joint efforts, the project aims to ensure that these topics receive adequate attention, resources, and responses to the challenges brought by the digital age.

    The project “CyberShield: Empowered Citizens for Cyber Resilience” is supported by the National Interventions grant for the regional project “SMART Balkans—Civil Society for Shared Society in the Western Balkans” implemented by Centar za promociju civilnog društva (CPCD) (Center for Civil Society Promotion), Center for Research and Policy Making (CRPM) and the Institute for Democracy and Mediation (IDM), and financially supported by the Ministry of Foreign Affairs of the Kingdom of Norway.

  • Metamorphosis Foundation Featured in Global Campaign for World Press Freedom Day

    On this World Press Freedom Day, the global IFEX network has launched the “Meeting the AI Moment” campaign, spotlighting civil society efforts to counter disinformation in the age of artificial intelligence. The Metamorphosis Foundation is among the featured organisations in the campaign, with its innovative approach to youth engagement and media literacy offering a compelling model for navigating the challenges of AI-powered misinformation.
    As AI continues to reshape the global information landscape—bringing both opportunities and threats—civil society organisations like Metamorphosis are stepping up to ensure that press freedom not only survives but evolves. The “Meeting the AI Moment” campaign emphasizes the critical role of such organisations in fostering informed, resilient societies at a time when synthetic media, deepfakes, and AI-generated content are increasingly being weaponized to distort public discourse and undermine trust.
    In North Macedonia, where media literacy remains one of the lowest in Europe and disinformation campaigns target everything from public health to elections, Metamorphosis has long been at the forefront of countering harmful narratives. Through a multi-pronged approach that includes media platforms like Meta.mk, fact-checking services such as Truthmeter, and regional cooperation via the Western Balkans Anti-Disinformation Hub, the Foundation has developed a robust toolkit to defend the information space.
    A standout initiative featured in the IFEX campaign is Cyber Shakes—a series of youth-focused events launched in 2023 to explore the impact of emerging technologies on information integrity. Held in informal venues such as cafés and nightclubs, Cyber Shakes bring experts and young people together to discuss everything from deepfakes to data privacy, using interactive tools like quizzes and influencer-led promotions to spark meaningful dialogue.
    One such event, “Deepfake or Reality,” held in early 2024, offered a dynamic mix of expert panels and live audience engagement. Participants—including journalists, computer science academics, and tech editors—guided young attendees through real and manipulated images, encouraging them to question and analyze visual content in a digital age. The event also opened the floor for young people to voice their growing concerns about AI misuse, including the disturbing rise of sexualized deepfakes and online harassment.
    “We didn’t ask them to come to us—we went to them,” said Goran Rizaov, Programme Manager for Information and Media Integrity at Metamorphosis. “The goal was not to lecture, but to create a space where young people could ask questions and share concerns. Many already knew about the risks of AI, but what they lacked was a platform to talk openly and find others who felt the same.”
    Feedback from these events is shaping Metamorphosis’s future strategy. Plans are underway for a new series of youth- and elderly-oriented events combining education and entertainment to further unpack complex topics like conspiracy theories, surveillance, and AI ethics. Metamorphosis also remains committed to regional cooperation, continuing to expand its leadership within the Western Balkans Anti-Disinformation Hub.
    Crucially, the Foundation maintains a balanced stance on technology. “We emphasize the positive potential of AI when used ethically,” said Rizaov. “Our aim isn’t to scare people—it’s to equip them with the knowledge to use technology wisely, while being aware of the risks.”
    Through its contributions to IFEX’s “Meeting the AI Moment” campaign, Metamorphosis Foundation reaffirms its commitment to empowering citizens, especially the youth, with the critical thinking skills and media literacy needed to defend press freedom in an AI-driven world.

  • Youth, Ethics, and Artificial Intelligence: Metamorphosis in preparation for a study session in Strasbourg

    This past weekend, the Metamorphosis Foundation actively participated in the preparations for the study session “Open your AIs,” which will be held in June at the European Youth Centre in Strasbourg, under the auspices of the Council of Europe.

    This study session is an opportunity for young people to explore key issues related to the ethics and responsible use of artificial intelligence. Through the exchange of ideas, discussions, and practical activities, participants will create tools, strategies, and recommendations that they can directly apply in the work of youth organizations.
    The study session is organized within the framework of the Youth for Democracy program in collaboration with Connect International alongside the partner Curiosité – Centre de Formation and supported by the expertise of the Metamorphosis Foundation.

    We look forward to welcoming 20 young leaders from across Europe to join us in contributing to the creation of a more inclusive and just digital future, grounded in the protection of human rights.
    The call for participation is open until May 9th. More information is available at the following link.

  • Evaluating North Macedonia’s Media Law Reforms—A Partial Step Toward European Standards

    North Macedonia is undergoing reforms to its media legislation, aiming to align with European Union (EU) standards. The Metamorphosis Foundation welcomes the initiative of the Government of Republic of North Macedonia to align national media legislation with European standards, particularly in the context of Chapter 23 of the EU acquis and the European Media Freedom Act (EMFA). While the proposed amendments to the Media Law can represent a step in the right direction by extending the regulatory framework to online media, they raise concerns that they only partially address the systemic issues in the media environment and do not sufficiently comply with EMFA provisions. We therefore call for a comprehensive, inclusive reform process aimed at the adoption of a new Media Law that fully reflects European norms and ensures the protection of media freedom, editorial independence, and journalists’ rights.
    Moreover, while a whole new Media Law had already been already drafted with the help of experts from the EU during the previous years, for unknown reasons and without providing public explanation, the Government choose to only amend the existing old law addressing only part of the burning issues, instead of proposing the comprehensive new law.
    This position paper evaluates the proposed changes, highlighting both advancements and persistent challenges, and offers recommendations to ensure comprehensive media freedom and alignment with EU directives.

  • Call for participants to join our study session “Open your AIs” in Strasbourg

    Are you working in a youth organisation and interested in the ethical use of Artificial Intelligence (AI) tools? Do you want to explore how AI impacts youth participation, human rights, and democracy?
    Join the “Open your AIs” study session and become part of a community of young changemakers ready to tackle the future of AI with a critical and rights-based approach.
    The study session is a space for participants to explore key challenges related to AI, exchange ideas, and co-create practical tools, strategies, or recommendations that can directly support their work in youth organisations. Study session organised within the Youth for Democracy programme in cooperation with Connect International in with partner Curiosite Centre de Formation and expertise of Metamorphosis Foundation.
    And we are looking for 20 participants from across Council of Europe member states.
    By participating, you will:

    Boost your organization’s digital capacity – Learn how to critically assess and responsibly integrate AI tools into your daily work and projects.
    Explore the ethical side of AI – Reflect on the benefits, risks, and ethical dilemmas posed by AI and how they affect young people and our societies.
    Spark meaningful conversations – Get practical tools and strategies to help bring AI ethics into your programmes and engage young people in shaping their digital future.
    Understand the digital policies that matter – Build your knowledge of the EU AI Act, the Council of Europe’s AI Convention, and how youth organisations like yours can be part of shaping inclusive and fair AI governance.

    When?
    Arrival day 22nd June 2025
    Departure day 28th June 2025
    Where?
    In the facility of the Council of Europe called the European Youth Center Strasbourg in France.
    Who?

    Are you between 18 and 30 years old?
    Member of youth organisation or youth worker?
    Are you a resident in one of the Council of Europe member states?
    Are you looking forward to learning more about digital and youth policies of the Youth Sector of the Council of Europe?
    Do you want to better understand how Artificial Intelligence is shaping the lives of young people?
    Are you interested in ethical, human rights-based approaches to technology?

    Then, apply for the study session by the 9th of May 2025 through this form.
    Cost
    Accommodations, meals, visa costs and travel and subsistence costs are covered by the Youth Department of the Council of Europe.
    The participants’ contribution will be 50 euros a fee, which they will be asked to transfer via bank transfer to Connect International at least 3 weeks before the beginning of the study session.
    Timeline of the application process:
    Deadline for application: 9th May 2025
    Information about your application status: 15th May 2025
    Link to the original call: Call for participants to join our study session “Open your AIs” in Strasbourg | Connect INTERNATIONAL

  • The Platform of Civil Society Organizations in the Fight against Corruption responds to the recommendations of the SCPC presented in the Report of the Anti-Corruption Review of the Law on Free Access to Public Information

    The Platform of Civil Society Organizations in the Fight against Corruption responds to the recommendations of the State Commission for Prevention of Corruption (SCPC), presented at a public session of the SCPC, and conveyed through media outlets, within the framework of the anti-corruption review of the Law on Free Access to Public Information.
    Instead of contributing to greater transparency, accountability, and the fight against corruption, the SCPC, through its alleged indications of “regulatory risks,” sends seriously worrying signals for the closure of institutions and creates opportunities for limiting the public’s right to know. Such recommendations not only undermine the role of the SCPC as a key institution for preventing corruption, but also directly open up space for new corrupt abuses, especially in the area of ​​public procurement.

    Reduced transparency–increased risks of corrupt and harmful public procurement

    First, the SCPC recommends “reexamining the article regulating the obligation to publish all public procurement documentation. The SCPC believes that the term “all documentation” in relation to public procurement is not precisely defined, which may result in the publication of confidential information and the violation of the rights of third parties.”
    The Platform points out that the application of the provision of the Law on Free Access to Public Information, the entire documentation pertaining to public procurements, concessions and public-private partnership agreements, (Article 10, paragraph 1, line 18) has so far enabled increased transparency and access to relevant documents by civil society organizations and media outlets. In this way, abuses committed in a large number of tender procedures for which court proceedings are being conducted were disclosed, but also possible corrupt and harmful public procurements were prevented.
    The SCPC should also have taken into account that the protection of confidential data in public procurement is already regulated in the Law on Public Procurement (Article 30). We also point out to the SCPC that the Law on Free Access to Public Information regulates partial access, as well as provides for exceptions in cases where protection of information with a degree of secrecy is required. We remind the SCPC and the public that in January 20205 a regression was already made in the protection against corruption in public procurement with the amendments to the Law on Public Procurement in such a way that the administrative control of public procurement carried out by the Public Procurement Bureau was abolished. In conditions when, according to the assessments of all relevant international and domestic stakeholders, corruption in public procurement is widespread and with the historically highest state budget, new borrowing and daily indications of misuse of public money, the SCPC makes recommendations to limit transparency, thus undermining the role of a key institution for preventing corruption.

    Recommendations with long-term negative consequences affecting independence

    The SCPC provides guidelines for prescribing and specifying a procedure, as well as setting a deadline for the Assembly of the Republic of North Macedonia in cases where it determines the termination of the function and the dismissal of the Director of the Agency for Protection of the Right to Free Access to Public Information and the deputy, before the expiration of the mandate.

    For the Platform, this recommendation is politically motivated because it was given immediately after an attempt by MPs in the Assembly of the Republic of North Macedonia to adopt amendments to the Law on Free Access to Public Information that envisaged the early dismissal of the Director of the Agency in the event that the parliamentary majority does not adopt the annual work report. And we point out to the SCPC that independent regulatory bodies, such as the Agency for the Protection of the Right to Free Access, and the SCPC itself, have a mandate longer than the mandate of elected officials in the executive branch, in order to ensure independence from parties and political influence. The given recommendation is already regulated in the Law on Free Access to Public Information that in the event of termination of the function or dismissal of the Director of the Agency, until the election of a new Director of the Agency, the function of Director of the Agency is performed by the Deputy Director, with all the authorities that the Director had. So the only argument for this recommendation by the SCPC cannot be “possible procrastination, selectivity, and uncertainty in the management of the institution.”

    Proposals to introduce criteria that will reduce existing transparency

    The SCPC refers to the obligation of information holders to regularly update a list of information they have and to publicly publish it. The SCPC considers that this provision “does not have precise criteria for which information should be published, nor in what manner and in what format, which leaves wide discretion to the information holders to decide what to publish and how. The SCPC considers that this is a “risk of limited transparency with the possibility of selective publication or concealment of information of public interest.”
    The Platform is concerned that the SCPC found a risk of limited transparency in conditions where the Law on Free Access to Public Information establishes the form for publishing information and documents, namely: (a) information is published in any form that was created by or is held by the holder of the information in accordance with their competencies, and (b) access is provided to a document regardless of its physical form or characteristics—written or printed text, maps, diagrams, photographs, images, drawings, sketches, working materials, as well as audio, voice, magnetic or electronic, optical or video recordings in any form, including portable devices for automatic data processing with built-in or portable memories for storing data in digital form (Article 3). Additionally, it is concerning that the SCPC demonstrates a lack of understanding of the matter when it states that “there are no clear criteria for which information must be published.” The Law on Free Access establishes that all information created by and held by institutions, except for the exceptions (Article 6), is public information. It even introduces the concept of “proactive transparency,” which means that certain information must be published without being requested. What kind of criteria the SCPC recommends is unclear, and it is even more concerning that they speak about format without taking into account the announced start of the process for drafting the Law on Open Data and Reuse of Public Sector Information.

    Overdue recommendations during an active process for amendments to the Law

    The SCPC has determined that there is disproportionate liability for the misdemeanor provisions. Only a 500 euro fine is foreseen for the manager if they fail to appoint an official for information mediation and fail to provide information to the public about that person, but a 250 euro fine is also foreseen for the official for multiple misdemeanors–updating the list of information, assisting applicants, respecting deadlines for responding to requests. The SCPC recommended that the misdemeanor liability between the manager and the official for information in the Agency be clearly demarcated, in accordance with their actual responsibilities.
    For the Platform, it is indicative that the SCPC points to alleged “regulatory risks” in the Law on Free Access to Public Information, for which the start of amending the Law was announced 5 months ago, i.e. on November 21, 2024, and public consultations are currently underway through ENER on the proposed amendments. The SCPC pointed to a disproportionality in the responsibility of responsible and official persons, but there are no proposals that specifically recommend it. We point out that civil society has been advocating for the existence of provisions for misdemeanor liability of responsible persons who unreasonably fail to provide access to information or prevent the official from implementing the second-instance decision to provide access to information.
    Hence, the Platform believes that proposed solutions that may negatively impact the fight against corruption are unacceptable and contrary to European commitments to democratic, inclusive, and expert public policymaking.
    Additionally, the Platform is concerned that the review of the Law on Free Access by the SCPC lacks key aspects of anti-corruption review, such as the involvement of multiple actors, i.e., during the preparation of the Report, they have not ensured cooperation with the civil society that would ensure independence and objectivity in the analysis.
    We remind you that the anti-corruption review of (draft) laws is a preventive mechanism aimed at detecting, preventing, and minimizing the risks regarding the possibility of corruption and conflict of interest that may result in the implementation of laws. With such guidelines, the SCPC not only does not advance the system for preventing corruption, but also risks giving legitimacy to policies and practices that lead to the capture of institutions and the inaccessibility of information of public interest, which is currently information of a public nature.
    We call on the competent institutions, especially the Ministry of Justice and the Parliament, to take into account the existing legal mechanisms and not give in to guidelines that limit transparency, which is a key tool in the fight against corruption.

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