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Introduction
Since 2022, the new momentum in the EU enlargement process has manifested in a level of dynamism unseen for nearly a decade. The increased prominence of enlargement on the EU’s agenda has been driven primarily by security considerations following Russia’s full-scale invasion of Ukraine in February 2022, unpredictability in the relation with the US administration and push for advancing Europe’s strategic autonomy, and the EU’s broader attempt to position itself as a geopolitical actor, particularly under Ursula von der Leyen’s second term at the helm of the European Commission.
The desire for a stronger, more capable and actionable Union has also been apparent in discussions about the EU’s internal reform and concrete initiatives at the EU level, particularly during the Belgian Presidency of the Council of the EU in 2024 when the roadmap for the EU’s internal reforms was adopted. While the prospect of accepting new members to the club can serve as a catalyst for speeding up the internal institutional reform debates and their materialisation into concrete steps, adapting the Union to modern-day challenges and realities is needed regardless of enlargement.
In the context of surging far-right nationalism and populism across Europe, it is also clear that the next EU enlargement must be done right - to strengthen the Union and Europe instead of weakening and fragmenting it further, and to showcase the benefits of European integration instead of giving more ammunition to anti-EU forces (both inside and outside) in the bloc. The challenge is thus how to balance the geopolitical urgency for the next EU enlargement with protection of the Union, its fundamental values and its effective functioning.
The desire for a stronger, more capable and actionable Union has also been apparent in discussions about the EU’s internal reform and concrete initiatives at the EU level, particularly during the Belgian Presidency of the Council of the EU in 2024 when the roadmap for the EU’s internal reforms was adopted. While the prospect of accepting new members to the club can serve as a catalyst for speeding up the internal institutional reform debates and their materialisation into concrete steps, adapting the Union to modern-day challenges and realities is needed regardless of enlargement.
The challenge is thus how to balance the geopolitical urgency for the next EU enlargement with protection of the Union, its fundamental values and its effective functioning.
In the context of surging far-right nationalism and populism across Europe, it is also clear that the next EU enlargement must be done right - to strengthen the Union and Europe instead of weakening and fragmenting it further, and to showcase the benefits of European integration instead of giving more ammunition to anti-EU forces (both inside and outside) in the bloc. The challenge is thus how to balance the geopolitical urgency for the next EU enlargement with protection of the Union, its fundamental values and its effective functioning.
Tectonic shifts in the enlargement discussion: moving from if to how
This dilemma lies at the core of the recent proposals put forward by EU institutions and Member States on how to innovate the enlargement process. In March 2026, the European Commission informally introduced a controversial concept of “reversed enlargement” - a fast-track model under which a candidate country (primarily Ukraine) would become a formal EU member first, while being gradually integrated into EU policies, institutions, and funds thereafter. While the suggestion was rejected by the EU Member States, the enlargement Commissioner Marta Kos called on the governments to come up with their own proposals on how to advance the process. Simultaneously, the Commissioner repeatedly referred to the need for a system of safeguards designed to protect the Union and new members against democratic and rule of law backsliding after accession.
Over the following few months, three non-papers and a separate proposal by German Chancellor Merz emerged, injecting new ideas into the debate on how to dynamise the process and how to ensure a smooth widening of the bloc. The goal of this analysis is to examine each of these proposals, particularly from the perspective of democratic conditionality, and assess their implications for strengthening the rule of law and democracy in the candidate countries.
Over the following few months, three non-papers and a separate proposal by German Chancellor Merz emerged, injecting new ideas into the debate on how to dynamise the process and how to ensure a smooth widening of the bloc. The goal of this analysis is to examine each of these proposals, particularly from the perspective of democratic conditionality, and assess their implications for strengthening the rule of law and democracy in the candidate countries.
Interactive graphicselect a step to see both sides
The jargon, decoded
Five steps between cooperation and membership
Gradual integration, observer status, associated membership, reversed enlargement: the debate has produced a vocabulary faster than it has produced agreement. Most of these terms describe a rung on the same ladder, distinguished by what a country gains and by how much leverage the Union keeps. Gradual integration is the exception - it is not a rung but the umbrella approach for how steps 2 to 4 are implemented, covering sectors, institutions, policies and funds alike. Select a step to see what it gives and what it costs the EU in leverage.
Gradual integration — the umbrella for steps 2 to 4
Select a step
The higher a country climbs before formal accession, the more of the Union’s leverage has already been spent - which is why every step above the first raises the question of what conditions come attached.
Compiled by EUCRTA from the four 2026 proposals and the Commission’s informal concept. Steps 2 to 4 are not a formal sequence in EU law - they describe how the current proposals stack up against each other.
The status quo for the Western Balkans: a Stabilisation and Association Agreement, political dialogue, trade preferences and pre-accession assistance. This is the baseline the whole debate is trying to move beyond, after more than a decade of stagnation in the enlargement process.
What the country gains
- Preferential trade access and a contractual framework for cooperation
- Pre-accession funding and technical support
- Structured political dialogue with the EU
What the EU keeps
- Effectively all of its leverage: nothing of substance has been granted in advance
- The full conditionality of the accession process still lies ahead
The workhorse of the current debate, and the step most of the proposals want to develop. A candidate is admitted to parts of the internal market and to EU programmes, sector by sector, in line with how far it has aligned with the relevant acquis. Note that this is sectoral integration specifically: gradual integration is the wider approach, which also covers institutions, policies and funds, and so spans steps 2 to 4.
What the country gains
- Access to specific sectors: Green Lanes, the energy and electricity markets, the Digital Single Market, transport and logistics
- Participation in EU programmes and in competitiveness and industrial strategies
- Instruments such as the ACAA agreement and Authorised Economic Operator status, plus youth mobility
What the EU keeps
- In principle, the power to withdraw benefits if a country backslides - the reversibility principle appears in the Franco-German paper and is implied in the others
- In practice, no proposal defines what counts as backsliding, who establishes it, or what triggers a reversal
Proposed by
- The Franco-German non-paper, as a structured and tailor-made incentive toolbox
- The Friends of the Western Balkans non-paper, in the greatest sectoral detail
- Chancellor Merz’s letter, as privileged internal market access for the Western Balkans and Moldova
A country is present where EU decisions are prepared, without taking part in taking them. Chancellor Merz’s letter raises this for the Western Balkans as the counterpart to the far deeper institutional integration it proposes for Ukraine.
What the country gains
- Possible observer status in all relevant EU institutions
- Joint meetings with representatives of the Commission and the European Parliament
- Familiarity with EU decision-making, administrative practice and political culture before accession
- Attendance and the ability to follow proceedings, but not the speaking rights that step 4 would carry
What the EU keeps
- All formal decision-making power: observers do not vote
- Access can be extended or withheld without touching market or budget arrangements
Worth noting
- The asymmetry is deliberate: Ukraine is offered seats and a voice, the Western Balkans are offered a place in the room
- What “possible observer status in all relevant EU institutions” would mean in practice is not clear. Read broadly it would include observer status in the European Parliament and potentially in the agencies or the Commission, where Western Balkan countries can already participate fully or as associated members in some cases. The German chancellery does not appear to have specified what it intends here.
The genuinely new idea in the 2026 debate, pitched by Chancellor Merz for Ukraine in May 2026. A country takes part in the EU’s institutions and receives a security commitment while the accession process continues in parallel. Early institutional participation had until then appeared mainly in think tank proposals, not in government positions.
What the country gains
- Participation in Council meetings, with speaking rights - in practice near-full participation, minus the vote
- An Associate Member of the European Commission
- Associate Members of the European Parliament
- An Associate Judge at the Court of Justice of the European Union (CJEU)
- A security guarantee resting on a political commitment by member states to extend Article 42(7) TEU
- Step-by-step application of the acquis, subject to Council approval, and gradual access to direct management funds
What the EU keeps
- Formal decision-making power, since associate seats carry no vote
- A snap-back mechanism or sunset clause, mentioned in relation to Ukraine but not designed - triggered by backsliding on the fundamentals or significant structural reversals in the accession process
- Little else: this is the point at which the question of remaining leverage becomes acute, because much of what membership offers has already been handed over
The counter-argument
- Sitting inside EU institutions, and especially inside the Court of Justice, could produce a positive socialisation effect - embedding candidates in European practice and helping them internalise European values rather than merely comply with them
The destination - and, from a conditionality perspective, the weakest point in the whole system. Once a country is in, the accession process is no longer available as a lever, and the instruments the Union holds against its own members are far blunter.
What the country gains
- A vote in the Council and a veto in policy areas requiring unanimity
- Full access to the internal market, EU funds, the Common Agricultural Policy and Cohesion Policy
- Commissioners, MEPs and judges with full rights
What the EU keeps
- Today: sectoral safeguard clauses and transitional measures, normally limited to three years after accession, and the Article 7 TEU procedure, which has proved slow and politically hard to use
- Under the Dutch-led paper: non-regression clauses, safeguards for Article 2 TEU values, suspension of cooperation in specific policy areas, an acquis monitoring mechanism, the Rule of Law Report as a practical instrument, temporary limits on voting rights in unanimity areas, and safeguards applying beyond the three-year window
- The catch: those new instruments would bind only newly acceding states, creating a two-track membership
Informally floated by the European Commission in March 2026 and rejected by the member states, this concept inverts the ladder rather than climbing it. A candidate country, primarily Ukraine, would become a formal EU member first, and phase into policies, institutions and funds gradually afterwards.
Why it was tabled
- The security situation after Russia’s full-scale invasion of Ukraine demanded a fast, visible answer that the ordinary accession timetable could not deliver
Why it did not survive
- It spends the Union’s leverage entirely up front: membership is granted before alignment, and no substitute instrument was proposed
- Member states rejected it, after which enlargement Commissioner Marta Kos invited governments to put forward their own proposals - which is what produced the four documents in this analysis
What it left behind
- The Commissioner’s parallel call for a system of safeguards to protect the Union and new members against democratic and rule of law backsliding after accession, which the Dutch-led non-paper then took up
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Chancellor Merz's proposal of associated membership for Ukraine
German Chancellor Merz’s proposal for an “associated membership”, presented to Ukraine and to EU institutions in May 2026, represents a strong political signal meant to integrate Ukraine (and, to some extent also other candidate countries) practically into the EU immediately while the accession process leading to formal membership continues in parallel.
Although it calls for an immediate opening of all negotiation clusters with Ukraine, the proposal rests on the assumption that the country’s process towards joining the EU will likely be lengthy, despite the security situation requiring a more immediate and innovative solution. Thus, rather than waiting until all formal accession conditions have been fulfilled, the proposal seeks to establish an early form of Ukraine’s political and institutional integration with the EU (“associate membership”) that would gradually evolve into full membership in the Union and help accelerate the accession process.
A particularly innovative aspect of the proposal is its elaboration of early institutional participation. This constitutes a new element that has so far been largely absent from the existing gradual integration approach, apart from occasional references and proposals advanced primarily by think tanks and the expert community. Together with the proposed security guarantee, based on a political commitment by Member States to extend the application of Article 42 paragraph 7 of the Treaty on European Union (TEU) to Ukraine, early institutional participation is presented as one of the key added values of the associated membership model. The Merz letter proposes concrete mechanisms, such as Ukrainian participation in Council meetings, the position of an Associate Member of the European Commission or Associate Members of the European Parliament, and an Associate Judge at the Court of Justice of the European Union (CJEU).
Although it calls for an immediate opening of all negotiation clusters with Ukraine, the proposal rests on the assumption that the country’s process towards joining the EU will likely be lengthy, despite the security situation requiring a more immediate and innovative solution. Thus, rather than waiting until all formal accession conditions have been fulfilled, the proposal seeks to establish an early form of Ukraine’s political and institutional integration with the EU (“associate membership”) that would gradually evolve into full membership in the Union and help accelerate the accession process.
A particularly innovative aspect of the proposal is its elaboration of early institutional participation. This constitutes a new element that has so far been largely absent from the existing gradual integration approach, apart from occasional references and proposals advanced primarily by think tanks and the expert community. Together with the proposed security guarantee, based on a political commitment by Member States to extend the application of Article 42 paragraph 7 of the Treaty on European Union (TEU) to Ukraine, early institutional participation is presented as one of the key added values of the associated membership model. The Merz letter proposes concrete mechanisms, such as Ukrainian participation in Council meetings, the position of an Associate Member of the European Commission or Associate Members of the European Parliament, and an Associate Judge at the Court of Justice of the European Union (CJEU).
Interactive graphicswitch between Ukraine and the Western Balkans
A seat before membership
Who would sit where, and with what rights
Early institutional participation is the genuinely new element in the 2026 enlargement debate - until now it had been advanced primarily by think tanks rather than governments. The Franco-German non-paper also mentions institutional integration, but Chancellor Merz’s letter is the only proposal that lists concrete ideas, and it offers Ukraine and the Western Balkans two very different things.
Show
Council of the EU
Where member states legislate and decide
Ukraine
Participation in Council meetings, with speaking rights
Participates, no vote
Western Balkans
Possible observer status in all relevant EU institutions
Observer
European Commission
Proposes legislation, manages funds, assesses progress
Ukraine
An Associate Member of the European Commission
Associate seat
Western Balkans
Joint meetings with European Commission representatives
Joint meetings
European Parliament
Co-legislator, and the EU’s directly elected chamber
Ukraine
Associate Members of the European Parliament
Associate seats
Western Balkans
Joint meetings with European Parliament representatives
Joint meetings
Court of Justice of the EU
Interprets EU law and binds every member state to it
Ukraine
An Associate Judge at the Court of Justice of the EU
Associate seat
Western Balkans
Not proposed
Not proposed
Security guarantee
Not an institution, but the other headline offer in the same letter
Ukraine
A political commitment by member states to extend the application of Article 42(7) TEU, the mutual assistance clause, to Ukraine
Political commitment
Western Balkans
Not proposed
Not proposed
Why it might work
Advanced institutional integration could generate a positive socialisation effect. By sitting inside EU institutions before accession - and especially inside the Court of Justice - candidates would become embedded in EU decision-making, administrative practice and political culture, which could help them internalise European values rather than merely comply with rules.
What observer status would actually mean
Unclear. Read broadly, “possible observer status in all relevant EU institutions” would include observer status in the European Parliament and potentially in the agencies or the Commission - bodies in which Western Balkan countries can in some cases already participate fully or as associated members. The German chancellery does not appear to have specified what it intends in practice.
Why it might not
The letter appears to treat institutional participation itself as the incentive for further reform. That may not be strong enough without meaningful financial conditionality - and it leaves open what leverage the EU retains once a candidate already enjoys a significant share of the benefits of membership.
All figures in this graphic come from Chancellor Merz’s May 2026 proposal, the only document that lists concrete institutional roles. The Franco-German non-paper also mentions institutional integration, as one area of its toolbox, and invites the Commission to elaborate it; the Friends of the Western Balkans non-paper (May 2026) advocates phased institutional participation without specifying the phases. Compiled by EUCRTA.
↑ interactive graphic · the analysis continues below
The proposal foresees a step-by-step application of the acquis, subject to Council approval. From a financial perspective, the proposal envisages a gradual access to EU’s direct management funds (meaning those administered by the European Commission and its agencies), linked to progress in the accession negotiations. However, additional benefits offered in this area may be relatively limited, as Ukraine already participates in the vast majority of EU programmes under direct management.
Although the proposal is centred on Ukraine as a special case, the letter to EU institutions also addresses the Western Balkans and Moldova. It proposes early integration measures, such as privileged access to the EU’s internal market, enhanced sectoral integration, and advanced institutional integration. For the Western Balkans specifically, the letter mentions the possibility of granting observer status in all relevant EU institutions, alongside joint meetings with representatives of the European Commission and the European Parliament.
Although the proposal is centred on Ukraine as a special case, the letter to EU institutions also addresses the Western Balkans and Moldova. It proposes early integration measures, such as privileged access to the EU’s internal market, enhanced sectoral integration, and advanced institutional integration. For the Western Balkans specifically, the letter mentions the possibility of granting observer status in all relevant EU institutions, alongside joint meetings with representatives of the European Commission and the European Parliament.
Democratic conditionality perspective
While the letter does not provide details of the conditionality provisions attached to the associate membership, it does appear to treat benefits granted under the model as reversible (referred to as a snap-back mechanism or sunset clause in relation to Ukraine) in the event of backsliding on the fundamentals or significant structural reversals in the accession process.
A key question, however, concerns the leverage the EU would retain if Ukraine or other candidate countries already enjoyed access to a significant share of benefits associated with full membership.
That being said, advanced institutional integration of the candidates could generate a positive socialisation effect. By participating in EU institutions before full accession, especially if involved in bodies such as the Court of Justice of the EU, candidates could become more familiar and more deeply embedded in the EU’s decision-making processes, administrative practices and political culture. Such participation could potentially facilitate not only their eventual transition to full membership but also the internalisation of European norms and values.
A key question, however, concerns the leverage the EU would retain if Ukraine or other candidate countries already enjoyed access to a significant share of benefits associated with full membership.
A key question, however, concerns the leverage the EU would retain if Ukraine or other candidate countries already enjoyed access to a significant share of benefits associated with full membership.
In this respect, the proposal leaves open important questions regarding the effectiveness of conditionality throughout the remainder of the accession process - what would be the incentive for candidates to continue with difficult reforms if they already enjoy the benefits of access to the EU’s internal market, programmes and institutions? The proposal appears to assume that institutional participation itself should serve as an incentive stimulating further reforms and alignment with the EU acquis. This might not, however, constitute a strong enough motivation unless combined with meaningful financial conditionality and credible mechanisms for withdrawing benefits in cases of backsliding.That being said, advanced institutional integration of the candidates could generate a positive socialisation effect. By participating in EU institutions before full accession, especially if involved in bodies such as the Court of Justice of the EU, candidates could become more familiar and more deeply embedded in the EU’s decision-making processes, administrative practices and political culture. Such participation could potentially facilitate not only their eventual transition to full membership but also the internalisation of European norms and values.
Franco-German non-paper: a new momentum for enlargement
The non-paper introduced by France and Germany shortly before the EU-Western Balkans Summit in Tivat in June 2026 identifies two key dimensions in which the enlargement process should evolve. First, it advocates for streamlining and simplifying the accession process by removing unnecessary procedural hurdles, for example by merging certain procedural steps. Second, it seeks to provide stronger incentives for reforms through a more developed gradual integration approach, allowing candidate countries to benefit from closer integration before full membership.
The non-paper further elaborates on several new ideas for gradual integration, particularly in the area of the EU’s internal market access, participation in EU programmes, and participation in EU institutions. These incentives are presented as part of a more structured “toolbox”, with access clearly and directly linked to the fulfilment of accession criteria and progress in formal accession negotiations. At the same time, the paper stresses that gradual integration incentives should be tailored to each candidate country. To operationalise this approach, the governments invite the European Commission to present concrete proposals for advancing gradual integration.
The non-paper further elaborates on several new ideas for gradual integration, particularly in the area of the EU’s internal market access, participation in EU programmes, and participation in EU institutions. These incentives are presented as part of a more structured “toolbox”, with access clearly and directly linked to the fulfilment of accession criteria and progress in formal accession negotiations. At the same time, the paper stresses that gradual integration incentives should be tailored to each candidate country. To operationalise this approach, the governments invite the European Commission to present concrete proposals for advancing gradual integration.
Democratic conditionality perspective
An important safeguard included in this proposal is the principle that gradual integration “should build on the progress made in the accession process and be reversible in case of backsliding in the reform process and with regard to the EU core values and principles”. However, beyond this reversibility principle, the paper offers relatively little detail on the broader question of democratic conditionality.
Similarly, the call to open all negotiation clusters for which the European Commission has issued a positive recommendation would, in practice, also imply opening of Cluster 3 with Serbia. This would represent a return to a rather technocratic understanding of the accession process, centred on the fulfilment of technical benchmarks rather than a horizontal focus taking into account progress on the fundamentals which is increasingly present under the revised enlargement methodology.
Ultimately, the devil lies in the details. The proposal does not specify what exactly constitutes backsliding in the reform process, nor how such backsliding would be assessed, or which criteria would trigger the suspension or reversal of gradual integration benefits. For example, it remains unclear whether democratic backsliding identified by the European Commission (as was the case in the EC’s 2025 Serbia country report) would automatically trigger the suspension or withdrawal of integration measures.
More fundamentally, integration into technical policy areas, and particularly into the EU’s internal market, cannot rely solely on the fulfilment of technical criteria under individual negotiating chapters. Such integration must go hand in hand with broader progress throughout the accession process, including compliance with rule of law requirements and continued alignment under Cluster 6 (external relations). These fundamentals are equally important for safeguarding the integrity and functioning of the Single Market, including its resilience to interference and economic or political influence from external adversaries such as Russia and China. Comparisons with EEA and cooperation with other non-EU members, such as Norway or Iceland, fall short when confronted with their different contexts - in the case of EEA or EFTA countries, a key pillar of the cooperation is trust in their legal and political systems, as well as a substantial foreign policy alignment with the EU.
Similarly, the call to open all negotiation clusters for which the European Commission has issued a positive recommendation would, in practice, also imply opening of Cluster 3 with Serbia. This would represent a return to a rather technocratic understanding of the accession process, centred on the fulfilment of technical benchmarks rather than a horizontal focus taking into account progress on the fundamentals which is increasingly present under the revised enlargement methodology.
Ultimately, the devil lies in the details. The proposal does not specify what exactly constitutes backsliding in the reform process, nor how such backsliding would be assessed, or which criteria would trigger the suspension or reversal of gradual integration benefits. For example, it remains unclear whether democratic backsliding identified by the European Commission (as was the case in the EC’s 2025 Serbia country report) would automatically trigger the suspension or withdrawal of integration measures.
More fundamentally, integration into technical policy areas, and particularly into the EU’s internal market, cannot rely solely on the fulfilment of technical criteria under individual negotiating chapters. Such integration must go hand in hand with broader progress throughout the accession process, including compliance with rule of law requirements and continued alignment under Cluster 6 (external relations). These fundamentals are equally important for safeguarding the integrity and functioning of the Single Market, including its resilience to interference and economic or political influence from external adversaries such as Russia and China. Comparisons with EEA and cooperation with other non-EU members, such as Norway or Iceland, fall short when confronted with their different contexts - in the case of EEA or EFTA countries, a key pillar of the cooperation is trust in their legal and political systems, as well as a substantial foreign policy alignment with the EU.
Non-paper on post-accession safeguards led by the Netherlands
The non-paper signed by Benelux countries, France and Germany, builds on the acknowledgement that enlargement is a geostrategic investment for the EU and that the current political momentum should be maintained and translated into concrete results. It reflects on the changed geopolitical situation and evolution of the Union since previous rounds of enlargement, and proposes adapting future accession treaties to contemporary challenges.
The non-paper also argues that enlargement needs to strengthen both the Union and the security of its neighbourhood, thereby helping to build political and public support for accepting new members. Enlargement should therefore go hand in hand with the EU’s own internal reforms aimed at safeguarding the Union’s capacity to act and uphold its fundamental values, including by strengthening its rule of law toolbox.
To achieve this, the document proposes developing a general template for future accession treaties and a catalogue of safeguard options from which measures could be selected, tailored and complemented depending on the circumstances of each acceding country. Rather than prescribing a fixed model, the non-paper suggests considering the full range of available options (putting all options on the table) and initiating an open discussion on the most appropriate steps. The underlying message is clear: the EU must enlarge, but it must do so in a way that strengthens rather than weakens the Union.
The proposal is structured around four main components. First, it builds upon existing sectoral safeguards and transitional measures from previous enlargement rounds. Second, it introduces additional safeguards to protect the EU’s fundamental values under Article 2 TEU. Third, it explores options to safeguard the Union’s capacity to act, particularly with regard to its decision-making capacity. Finally, it proposes safeguards against conduct that runs counter to the principle of sincere cooperation under Article 4 TEU.
With regard to existing safeguard clauses, the non-paper suggests both expanding their scope and prolonging the duration of mechanisms used in previous enlargements. This includes broadening safeguards to areas such as internal security, resilience against foreign interference and economic security, as well as building on previously introduced transitional periods related primarily to the labour market and access to EU funds, including the Common Agricultural Policy (CAP) and Cohesion Policy. It also envisages a monitoring mechanism linked to the implementation of the EU acquis, potentially with more intensive monitoring in the immediate post-accession period. While this idea seems to be developed primarily in relation to the free movement of workers, it could equally be extended to other key areas (including the fundamentals).
The proposal recognises that the Union needs stronger instruments to address any backsliding on EU values, particularly the rule of law, quickly and effectively. The paper therefore proposes dedicated post-accession non-regression and safeguard clauses allowing the EU to adopt protective measures in the event of serious shortcomings or backsliding by a Member State in upholding EU values, including the rule of law, democratic principles, and media freedom. At the same time, it argues that the conditions for invoking such a safeguard should be clarified, together with the range of measures that could be adopted, such as the suspension of cooperation in specific policy areas. Unlike previous safeguard clauses, these mechanisms should also remain applicable beyond the traditional three-year post-accession period.
The non-paper furthermore suggests discussing the possibility of temporary deviations from certain procedural rules under Article 7 TEU. In parallel, the paper argues that the Rule of Law Report should be further developed as a practical monitoring instrument and proposes that participation in the European Public Prosecutor's Office (EPPO) should become a precondition for EU accession, serving as an additional safeguard for the rule of law. It also underlines that Schengen accession should remain a separate process, with a robust rule of law track record remaining a fundamental prerequisite.
With respect to the EU's capacity to act, the non-paper emphasises that internal EU reforms should proceed in parallel with enlargement. It also raises the possibility of introducing temporary limitations on the voting rights of new Member States, particularly in policy areas subject to unanimity, as a means of safeguarding the Union's decision-making capacity during the initial post-accession period.
Finally, the proposal argues that accession treaties should explicitly recall the obligation to respect the principle of sincere cooperation under Article 4 TEU and should consider introducing mechanisms to address conduct that undermines this principle, thereby protecting the Union's ability to function effectively.
The non-paper also argues that enlargement needs to strengthen both the Union and the security of its neighbourhood, thereby helping to build political and public support for accepting new members. Enlargement should therefore go hand in hand with the EU’s own internal reforms aimed at safeguarding the Union’s capacity to act and uphold its fundamental values, including by strengthening its rule of law toolbox.
To achieve this, the document proposes developing a general template for future accession treaties and a catalogue of safeguard options from which measures could be selected, tailored and complemented depending on the circumstances of each acceding country. Rather than prescribing a fixed model, the non-paper suggests considering the full range of available options (putting all options on the table) and initiating an open discussion on the most appropriate steps. The underlying message is clear: the EU must enlarge, but it must do so in a way that strengthens rather than weakens the Union.
The underlying message is clear: the EU must enlarge, but it must do so in a way that strengthens rather than weakens the Union.
The proposal is structured around four main components. First, it builds upon existing sectoral safeguards and transitional measures from previous enlargement rounds. Second, it introduces additional safeguards to protect the EU’s fundamental values under Article 2 TEU. Third, it explores options to safeguard the Union’s capacity to act, particularly with regard to its decision-making capacity. Finally, it proposes safeguards against conduct that runs counter to the principle of sincere cooperation under Article 4 TEU.
With regard to existing safeguard clauses, the non-paper suggests both expanding their scope and prolonging the duration of mechanisms used in previous enlargements. This includes broadening safeguards to areas such as internal security, resilience against foreign interference and economic security, as well as building on previously introduced transitional periods related primarily to the labour market and access to EU funds, including the Common Agricultural Policy (CAP) and Cohesion Policy. It also envisages a monitoring mechanism linked to the implementation of the EU acquis, potentially with more intensive monitoring in the immediate post-accession period. While this idea seems to be developed primarily in relation to the free movement of workers, it could equally be extended to other key areas (including the fundamentals).
The proposal recognises that the Union needs stronger instruments to address any backsliding on EU values, particularly the rule of law, quickly and effectively. The paper therefore proposes dedicated post-accession non-regression and safeguard clauses allowing the EU to adopt protective measures in the event of serious shortcomings or backsliding by a Member State in upholding EU values, including the rule of law, democratic principles, and media freedom. At the same time, it argues that the conditions for invoking such a safeguard should be clarified, together with the range of measures that could be adopted, such as the suspension of cooperation in specific policy areas. Unlike previous safeguard clauses, these mechanisms should also remain applicable beyond the traditional three-year post-accession period.
The non-paper furthermore suggests discussing the possibility of temporary deviations from certain procedural rules under Article 7 TEU. In parallel, the paper argues that the Rule of Law Report should be further developed as a practical monitoring instrument and proposes that participation in the European Public Prosecutor's Office (EPPO) should become a precondition for EU accession, serving as an additional safeguard for the rule of law. It also underlines that Schengen accession should remain a separate process, with a robust rule of law track record remaining a fundamental prerequisite.
With respect to the EU's capacity to act, the non-paper emphasises that internal EU reforms should proceed in parallel with enlargement. It also raises the possibility of introducing temporary limitations on the voting rights of new Member States, particularly in policy areas subject to unanimity, as a means of safeguarding the Union's decision-making capacity during the initial post-accession period.
Finally, the proposal argues that accession treaties should explicitly recall the obligation to respect the principle of sincere cooperation under Article 4 TEU and should consider introducing mechanisms to address conduct that undermines this principle, thereby protecting the Union's ability to function effectively.
Interactive graphicopen a component to read its measures
Anatomy of the most developed proposal
What the EU would keep in its hands after a country joins
Of the four proposals, only the Dutch-led non-paper signed by the Benelux countries, France and Germany focuses on the period after accession. Rather than prescribing a fixed model, it proposes a general template for future accession treaties and a catalogue of safeguard options to be selected from and tailored country by country. Its four components are explained below.
The underlying message is blunt: the EU must enlarge, but it must do so in a way that strengthens rather than weakens it. Enlargement is framed as a geostrategic investment, to be accompanied by the Union’s own internal reform and a stronger rule of law toolbox.
- Broadening the safeguards to new areas: internal security, resilience against foreign interference and economic security
- Building on transition periods used before, applied primarily to the labour market and to access to EU funds, including the Common Agricultural Policy and Cohesion Policy
- A monitoring mechanism tied to implementation of the EU acquis, potentially more intensive in the period immediately after accession
- Developed mainly with the free movement of workers in mind, but equally extendable to other key areas - including the fundamentals
The core of the paper, and the reason it matters most from a democratic conditionality perspective. It recognises that the Union needs stronger instruments to address backsliding on EU values quickly and effectively.
- Dedicated post-accession non-regression and safeguard clauses, allowing the EU to adopt protective measures where a member state seriously backslides on EU values, the rule of law, democratic principles or media freedom
- Acknowledging the need to clarify the conditions for invoking such a safeguard, and the range of measures available, such as suspending cooperation in specific policy areas - the paper itself does not provide that clarification, it says it is needed
- Unlike previous safeguard clauses, remaining applicable beyond the traditional three-year post-accession period
- Discussing the possibility of temporary deviations from the procedural rules under Article 7 TEU, the procedure that has proved slow and politically hard to use
- Developing the Rule of Law Report into a practical monitoring instrument rather than an annual stocktake
- Making participation in the European Public Prosecutor’s Office a precondition for EU accession, as an additional safeguard for the rule of law
- Keeping Schengen accession a separate process, with robust rule of law performance a continuing prerequisite
- The EU’s internal reform should proceed in parallel with enlargement, not after it
- Temporary limitations on the voting rights of new member states, particularly in policy areas requiring unanimity, as a way of protecting decision-making during the initial post-accession period
This is the proposal’s sharpest edge: a new member would join the table without the full weight of a vote.
- Accession treaties should explicitly recall the obligation of sincere cooperation under Article 4 TEU
- Introducing mechanisms capable of addressing conduct that undermines that principle, protecting the Union’s ability to function effectively
The limitation
These safeguards would apply only to newly acceding member states, creating a form of differentiated or two-track membership. That raises questions of fairness, and leaves relatively limited additional leverage for addressing rule of law backsliding among existing member states.
EUCRTA Further work on post-accession safeguards has to go hand in hand with the broader debate on EU internal reform and on strengthening rule of law instruments that apply to all member states. Robust monitoring, non-regression principles and enforceable consequences for violating EU fundamental values should ultimately bind the whole Union, not only its newest members.
Compiled by EUCRTA from the non-paper signed by the Benelux countries, France and Germany, led by the Netherlands, June 2026.
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Democratic conditionality perspective
Overall, the Benelux non-paper presents a comprehensive and comparatively detailed proposal, placing particular emphasis on strict safeguards and mechanisms to address potential democratic backsliding, as well as other internal threats to the Union. Compared with the other proposals discussed, it offers the most developed framework for post-accession conditionality and protecting the Union against potential risks arising after enlargement.
At the same time, one important limitation remains: the proposed new safeguard mechanisms would apply only to newly acceding Member States, thereby potentially creating a form of differentiated or two-track system of membership. Imposing additional constraints exclusively on newly acceded countries, while maintaining relatively limited leverage for addressing rule of law backsliding among existing Member States, creates a risk of undermining the principle of equality among members and, potentially, the political legitimacy of the enlargement process itself. Thus, it is crucial that further work on the post-accession safeguards and additional conditionality for new members goes hand in hand with the broader discussion about the EU’s internal reform and the strengthening of rule of law instruments applicable equally and effectively to all Member States.
At the same time, one important limitation remains: the proposed new safeguard mechanisms would apply only to newly acceding Member States, thereby potentially creating a form of differentiated or two-track system of membership. Imposing additional constraints exclusively on newly acceded countries, while maintaining relatively limited leverage for addressing rule of law backsliding among existing Member States, creates a risk of undermining the principle of equality among members and, potentially, the political legitimacy of the enlargement process itself. Thus, it is crucial that further work on the post-accession safeguards and additional conditionality for new members goes hand in hand with the broader discussion about the EU’s internal reform and the strengthening of rule of law instruments applicable equally and effectively to all Member States.
Friends of the Western Balkans non-paper on the advancement of gradual integration
The non-paper focuses on strengthening the gradual integration approach as both an incentive for reforms and a means of enhancing the European Union's geoeconomic position and strategic autonomy. Rather than treating gradual integration as an ad hoc measure, the proposal argues that it should become a more systematic instrument within the enlargement process, rewarding reform progress while simultaneously strengthening the EU's geopolitical and economic resilience.
The non-paper places particular emphasis on gradual integration into major sectors of the EU’s Single Market. Such integration should remain merit-based and, where necessary, proceed gradually, depending on the level of alignment with the EU acquis. The proposal identifies a wide range of areas in which accelerated sectoral integration could be pursued. These include the full implementation of Green Lanes; accelerated integration into the energy and electricity markets, the Digital Single Market, and the transport and logistics sectors; participation in the EU’s competitiveness and industrial strategies, as well as the critical raw materials policies; implementation of the Agreement on Conformity Assessment and Acceptance of Industrial Products (ACAA); the extension of Authorised Economic Operator (AEO) status to candidate countries; and measures facilitating youth mobility.
At the same time, the proposal extends beyond the Single Market and also advocates for deeper gradual integration in other policy areas, most notably the Common Foreign and Security Policy (CFSP) and through phased institutional participation.
To operationalise this approach, the non-paper calls on the European Commission to present concrete proposals for sectoral integration into the Single Market. It also invites the Commission to clarify procedures for assessing whether a candidate country has reached a sufficient level of preparedness in the relevant negotiating chapters, as well as the safeguards that could be activated in the event of significant setbacks.
The non-paper places particular emphasis on gradual integration into major sectors of the EU’s Single Market. Such integration should remain merit-based and, where necessary, proceed gradually, depending on the level of alignment with the EU acquis. The proposal identifies a wide range of areas in which accelerated sectoral integration could be pursued. These include the full implementation of Green Lanes; accelerated integration into the energy and electricity markets, the Digital Single Market, and the transport and logistics sectors; participation in the EU’s competitiveness and industrial strategies, as well as the critical raw materials policies; implementation of the Agreement on Conformity Assessment and Acceptance of Industrial Products (ACAA); the extension of Authorised Economic Operator (AEO) status to candidate countries; and measures facilitating youth mobility.
At the same time, the proposal extends beyond the Single Market and also advocates for deeper gradual integration in other policy areas, most notably the Common Foreign and Security Policy (CFSP) and through phased institutional participation.
To operationalise this approach, the non-paper calls on the European Commission to present concrete proposals for sectoral integration into the Single Market. It also invites the Commission to clarify procedures for assessing whether a candidate country has reached a sufficient level of preparedness in the relevant negotiating chapters, as well as the safeguards that could be activated in the event of significant setbacks.
Democratic conditionality perspective
Overall, the proposal remains relatively vague on the design of its conditionality framework. While it states that access to the Single Market should be granted once a candidate country has demonstrated a high level of alignment with the relevant sectoral acquis as well as “robust and credible” implementation of the rule of law, it provides little detail as to what exactly this should mean in practice. It is also not clear from the proposal how these conditions would be assessed, monitored or enforced in practice, or under what circumstances safeguards would be triggered. Compared with the other proposals, the approach therefore appears rather technical and pragmatic, focusing primarily on expanding opportunities for sectoral gradual integration while leaving many of the key institutional and conditionality questions unresolved.
Interactive graphicselect a cell to read the detail
Four proposals, compared
What each enlargement proposal actually does
Since March 2026, one Commission concept and four government proposals have set out how to speed up EU enlargement. They agree on the destination and diverge sharply on the safeguards. Select any cell to see the detail.
Central element, developed
Present but thin
Not addressed
Not applicable
| scroll → | Reversed enlargement March 2026 Rejected by member states | Associated membership May 2026 | New momentum for enlargement June 2026 | Post-accession safeguards June 2026 | Advancing gradual integration May 2026 |
|---|---|---|---|---|---|
| Primary addressee | Ukraine | Ukraine, with measures for the Western Balkans and Moldova | All candidate countries | All future member states | Western Balkans |
| Faster, simpler procedure | |||||
| Internal market access before membership | |||||
| Institutional participation before membership | |||||
| Access to EU funds before membership | |||||
| Benefits reversible if a country backslides | |||||
| Safeguards after accession | |||||
| Democratic conditionality: how developed |
Select a cell
Every cell in the table carries the detail behind the label. Select one to read what the proposal actually says on that point.
Assessment by EUCRTA, based on the texts of the four proposals and the Commission’s informal concept. Labels describe how far each document develops a given element, not whether the idea is good.
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Conclusion
The renewed geopolitical urgency of EU enlargement creates a strong case for accelerating the process and offering candidate countries greater access to EU policies, markets and institutions already prior to full membership. However, faster and more flexible integration must not come at the expense of democratic transformation, in order not to risk eroding the very fundamental principles and functioning of the Union while potentially having adverse effects on democracy and stability in its closest neighbourhood. On the contrary, to exercise the transformative power of enlargement, the more benefits candidates receive before accession, the stronger and more enforceable democratic and rule of law conditionality must become.
Interactive graphicselect a proposal to see why it sits there
The central trade-off
The more a candidate gets before joining, the stronger conditionality has to be
Each proposal offers candidate countries some benefits prior to full membership. What differentiates them is whether the conditions attached to these gradually advancing benefits can keep pace, and ensure the EU maintains strict conditionality throughout the process. Compared against each other, most of the current proposals sit significantly below the line of balance between benefits and conditions.
Select a proposal
Choose any of the five numbers to see why it sits where it does.
Positions are EUCRTA’s reading of the five documents, not a measured index. They express how much each proposal frontloads the benefits of membership relative to how precisely it defines the conditions, the assessment and the consequences of backsliding.
Far right, close to the floor. Nothing is frontloaded more completely than membership itself: the candidate joins first and phases into policies, institutions and funds afterwards. And nothing is left more open, because once a country is a member the accession process is no longer available as a lever and only the Union’s much weaker instruments against existing members remain. The member states rejected the concept, but the enlargement Commissioner’s call for governments to table their own ideas is what produced the four proposals that followed.
High on benefits, low on conditions. It offers the most far-reaching institutional integration of any proposal - a Council seat, an Associate Commissioner, Associate MEPs, an Associate Judge at the Court of Justice - plus a political security guarantee under Article 42(7) TEU, all before formal accession. A snap-back mechanism and sunset clause are mentioned but not designed. The open question is what incentive remains to continue difficult reforms once the internal market, the programmes and the institutions are already accessible. The proposal seems to treat institutional participation itself as the incentive, which may not be a strong enough motivation without meaningful financial conditionality and credible mechanisms for withdrawing benefits in cases of backsliding.
Middle on both. It ties gradual integration to accession criteria and negotiation progress and includes an explicit reversibility principle, which puts it above the others in the frontloading group. But it defines neither what counts as backsliding, nor who establishes it, nor what triggers a reversal. Its call to open every cluster with a positive Commission recommendation - cluster 3 with Serbia included - points back towards a technocratic reading of accession built on technical benchmarks rather than the horizontal focus on the fundamentals in the revised methodology.
The most concrete list of benefits, the least concrete conditions. Green Lanes, energy and electricity markets, the Digital Single Market, transport and logistics, ACAA, Authorised Economic Operator status, critical raw materials, youth mobility: the sectoral offer is spelled out in detail. The condition attached is a high level of alignment with the sectoral acquis and robust and credible implementation of the rule of law, with no definition of what that means, how it would be assessed or monitored, or when safeguards would fire.
The only proposal in the upper half, and the only one that barely frontloads anything. Non-regression clauses, safeguards for Article 2 TEU values covering the rule of law, democratic principles and media freedom, EPPO participation as a precondition for accession, the Rule of Law Report developed into a monitoring instrument, temporary limits on the voting rights of new members, and safeguards applicable beyond the traditional three-year window. Its limitation is not vagueness but scope: the new mechanisms would bind only newly acceding states, creating a two-track membership and adding little leverage over backsliding among existing members.
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Gradual integration needs to remain firmly tied not only to technical alignment with the acquis, but also to demonstrable progress on democracy, the rule of law and other fundamentals. Reversibility must be credible, underpinned by clear benchmarks and concrete consequences for backsliding that can be applied swiftly and efficiently. Otherwise, frontloading the membership benefits risks reducing the EU’s leverage and weakening the transformative power of the accession process. After more than a decade of stagnation, the enlargement process needs to be accelerated, but not at the expense of democracy and the rule of law, either within the EU or in candidate countries.
Crucially, strict conditionality cannot end at the moment of accession. The EU needs effective mechanisms to prevent and respond to democratic and rule of law backsliding after membership has been achieved. Yet stronger safeguards should not create a permanent distinction between new and old Member States. Robust monitoring, non-regression principles and enforceable consequences for violations of EU fundamental values should ultimately apply consistently to all Member States.
Reversibility must be credible, underpinned by clear benchmarks and concrete consequences for backsliding that can be applied swiftly and efficiently.
Crucially, strict conditionality cannot end at the moment of accession. The EU needs effective mechanisms to prevent and respond to democratic and rule of law backsliding after membership has been achieved. Yet stronger safeguards should not create a permanent distinction between new and old Member States. Robust monitoring, non-regression principles and enforceable consequences for violations of EU fundamental values should ultimately apply consistently to all Member States.
Interactive graphicselect a block to read what it contains
Stages where each proposal applies
Conditionality has three moments. No single proposal covers all of them
Democratic conditionality can bite before a country joins, at the moment the accession treaty is written, and after membership is in place. Laid out across those three moments, the proposals divide neatly: four focus on the road to accession, one centres on what happens once a country is inside. Select any block to see what it contains.
1Before accessionthe negotiating process
2At accessionthe treaty itself
3After accessionmembership in place
Reversed enlargementCommission, informal, March 2026, rejected
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Membership granted first
Phasing in, never designed
Associated membershipChancellor Merz, Germany, May 2026
Deepest pre-accession integration
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New momentum for enlargementFrance and Germany, June 2026
Streamlining plus an incentive toolbox
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Advancing gradual integrationFriends of the Western Balkans, May 2026
Sectoral single market integration
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Post-accession safeguardsBenelux, France, Germany, Dutch-led, June 2026
EPPO as a precondition
Treaty template and safeguard catalogue
Non-regression clauses and monitoring
EUCRTA’s position
A continuous system of democratic conditionality, spanning the entire integration process - before, during and after accession. And after accession, applying to all member states, not only the newest ones.
Select a block
The empty cells are the point. Three of the five documents say nothing about what happens at or after accession, and only one addresses the moment the accession treaty is written.
Assessment by EUCRTA, based on the texts of the four proposals and the Commission’s informal concept.
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The objective should therefore be a continuous system of democratic conditionality spanning the entire integration process - before, during and after EU accession. A larger Union will only be a stronger Union if these standards are credibly enforced across the EU as a whole.
Documents
Read the documents
The four proposals in full
None of the four was published as an official EU document - a non-paper is by definition informal. These are the texts as they became available.
- Associated membership for Ukraine
- A New Momentum for Enlargement
- A catalogue of safeguard options
- Advancing gradual integration
The European Commission’s “reversed enlargement” concept of March 2026 is not listed: it was floated informally and never published as a document.
