EUROPAM

European Public Accountability Mechanisms

North Macedonia

Country score (EU Average*)
  • 61(72) Political Financing
  • 83(57) Financial Disclosure
  • 78(49) Conflict of Interest
  • 77(59) Freedom of Information
  • 77(63) Public Procurement
  • 86(66) Anti Money Laundering
  • 67(71) Asset Recovery

Country Facts

IncomeUpper middle
GNI per capita (2011 PPP $)12860.00
Population, total2082958.00
Urban population (% of total)57.10
Internet users (per 100 people)75.20
Life expectancy at birth (years)75.70
Mean years of schooling (years)9.7
Global Competitiveness Index4.0
Sources: World Bank, UNDP, WEF.

Political Financing


Quantitative Data

Primary Metric

201220152016201720202024Trend
Bans and limits on private income42
Public funding62
Regulations on spending50
Reporting, oversight and sanctions92

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness


Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Bans and limits on private income

Bans on donations from foreign interests Yes. See subindicators
Is there a ban on donations from foreign interests to political parties? Yes. Political parties may not be financed by foreign governments, international institutions, bodies and organisations of foreign states, or other foreign persons. (Law on Financing of Political Parties, Art. 20)
Is there a ban on donations from foreign interests to candidates? No. The Electoral Code bans foreign funding of election campaigns, but the rule is framed for election campaign participants rather than candidates as such. (Electoral Code, Art. 83(1))
Bans on corporate donations Yes. See subindicators
Is there a ban on corporate donations to political parties? No. Legal entities may finance political parties up to the statutory annual cap, although several narrower categories of entities are prohibited donors. (Law on Financing of Political Parties, Arts. 16, 20)
Is there a ban on corporate donations to candidates? No. The campaign-finance rules allow legal-entity funding within limits for election campaign participants; there is no clear candidate-specific corporate-donation ban. (Electoral Code, Art. 83(2)-(3))
Is there a ban on donations from corporations with government contracts to political parties? Yes. Private enterprises that at the time of the contribution perform public services for state bodies or public institutions, enterprises, or funds under contract may not finance political parties. (Law on Financing of Political Parties, Art. 20)
Is there a ban on donations from corporations of partial government ownership to political parties? Yes. Political parties may not be financed by enterprises with at least 20% state capital, public institutions and institutions, including those undergoing privatisation. (Law on Financing of Political Parties, Art. 20)
Is there a ban on donations from corporations with government contracts to candidates? No. The contractor ban is stated for financing of political parties, not for candidates as such. (Law on Financing of Political Parties, Art. 20)
Is there a ban on donations from corporations of partial government ownership to candidates? No. The restriction on entities with state ownership is stated for financing of political parties, not for candidates as such. (Law on Financing of Political Parties, Art. 20)
Bans on donations from trade unions No. See subindicators
Is there a ban on donations from Trade Unions to political parties? No. The law bans associations of citizens, religious communities, religious groups, and foundations, but it does not expressly mention trade unions. (Law on Financing of Political Parties, Art. 20; Electoral Code, Art. 83(1))
Is there a ban on donations from Trade Unions to candidates? No. No clear, explicit candidate-specific ban on donations from trade unions was identified.
Bans on anonymous donations Yes. See subindicators
Is there a ban on anonymous donations to political parties? Yes. Political parties may not be financed from anonymous or unidentified sources, and donations whose origin cannot be determined must be transferred to the state budget. (Law on Financing of Political Parties, Arts. 16(3), 20)
Is there a ban on anonymous donations to candidates? No. The Electoral Code bars unidentified sources for election campaign financing, but the rule is framed for election campaign participants rather than candidates as such. (Electoral Code, Art. 83(1), (5))
Other bans on donations Yes. See subindicators
Is there a ban on state resources being given to or received by political parties or candidates (excluding regulated public funding)? No. The law clearly bans certain state resources for political parties and election campaign participants, but no single explicit rule was found that matches political parties or candidates in the exact terms of the indicator. (Law on Financing of Political Parties, Art. 20; Electoral Code, Art. 83(1))
Is there a ban on any other form of donation? Yes. Other prohibited sources include associations of citizens, religious communities, religious groups, foundations, and joint ventures with dominant foreign capital. (Law on Financing of Political Parties, Art. 20; Electoral Code, Art. 83(1))
Donation limits Yes. See subindicators
Is there a limit on the amount a donor can contribute to a political party over a time period (not election specific)? Yes. An individual annual donation may not exceed 30 average net salaries from a natural person or 60 average net salaries from a legal entity, and the amount may not be cumulated more than once yearly. (Law on Financing of Political Parties, Art. 16)
Is there a limit on the amount a donor can contribute to a political party in relation to an election? Yes. For election campaigns, financing from private persons and legal entities is capped at EUR 3,000 and EUR 30,000 respectively in denar equivalent, including money, goods, and services. (Electoral Code, Art. 83(2)-(3))
Is there a limit on the amount a donor can contribute to a candidate? No. The election-specific donation limits are framed for election campaign participants, not for candidates as such. (Electoral Code, Art. 83(2)-(3))

Public funding 

Eligibility criteria for direct public funding to political parties Yes. See subindicators
Eligibility criteria for direct public funding to political parties: Share of votes in previous election Yes. Thirty per cent of the annual public-funding pool is distributed equally among parties that won at least 1% of votes cast in the last parliamentary election at national level or the last local elections in the self-government unit. (Law on Financing Political Parties, Art. 10(1), (4))
Eligibility criteria for direct public funding to political parties: Representation in elected body Yes. Seventy per cent of the annual public-funding pool is distributed to parties whose candidates were elected as members of parliament or local councillors. (Law on Financing Political Parties, Art. 10(2), (5))
Eligibility criteria for direct public funding to political parties: Participation in election No. Mere participation in an election is not stated as a funding criterion; the law requires either at least 1% of votes cast or elected candidates. (Law on Financing Political Parties, Art. 10)
Eligibility criteria for direct public funding to political parties: Number of candidates No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Share of seats in previous election No. Seat numbers are used to calculate the 70% portion of annual public funding after election, not as a standalone eligibility threshold. (Law on Financing Political Parties, Art. 10(2), (5))
Eligibility criteria for direct public funding to political parties: Share of votes in next election No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Registration as a political party No. The funding rule applies to political parties, but registration as a political party is not stated in the funding provision as an eligibility criterion. (Law on Financing Political Parties, Art. 10)
Eligibility criteria for direct public funding to political parties: Share of seats in next election No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Number of members No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Other No. No other explicit eligibility criterion is stated beyond the prior-vote and elected-representative/councillor rules. (Law on Financing Political Parties, Art. 10)
Allocation calculations for direct public funding to political parties Yes. See subindicators
Allocation calculations for direct public funding to political parties: Proportional to votes received No. Annual public funding is not allocated proportionally to votes received; the vote-based rule only determines access to the equal 30% portion. (Law on Financing Political Parties, Art. 10(1), (4))
Allocation calculations for direct public funding to political parties: Equal Yes. Thirty per cent of the annual public-funding pool is allocated equally among parties that meet the 1% vote threshold. (Law on Financing Political Parties, Art. 10(1))
Allocation calculations for direct public funding to political parties: Proportional to seats received Yes. Seventy per cent of the annual public-funding pool is allocated proportionally to the number of elected members of parliament or local councillors. (Law on Financing Political Parties, Art. 10(2), (5))
Allocation calculations for direct public funding to political parties: Flat rate by votes received No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Share of expenses reimbursed No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Proportional to candidates fielded No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Number of members No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Other No. No other allocation formula is stated beyond equal distribution of 30% and seat-proportional distribution of 70%. (Law on Financing Political Parties, Art. 10)
Earmarking provisions for direct public funding to political parties No. See subindicators
Earmarking provisions for direct public funding to political parties: Campaign spending No. Annual public funding may be used solely for party aims defined by law, the party statute and other party acts, but the law does not expressly earmark it for campaign spending. (Law on Financing Political Parties, Art. 9)
Earmarking provisions for direct public funding to political parties: Ongoing party activities No. Annual public funding is not expressly earmarked for ongoing party activities as such. The law only states that it may be used for party aims defined by law, the statute and other party acts. (Law on Financing Political Parties, Art. 9)
Earmarking provisions for direct public funding to political parties: Intra-party institution No. The law requires parties to determine a body competent for the party’s financial operations, but it does not earmark direct public funding for an intra-party institution. (Law on Financing Political Parties, Art. 24)
Earmarking provisions for direct public funding to political parties: Other No. The law contains a general-use clause for annual public funding, but no explicit earmarking rule for another specific spending category. (Law on Financing Political Parties, Art. 9)
Allocation criteria for free or subsidized access to media for political parties Yes. See subindicators
Allocation criteria for free or subsidized access to media for political parties: Equal No. The law does not establish a single equal-allocation rule for free or subsidised media access across political parties. Free presentation and subsidised media access are differentiated by parliamentary status and other categories. (Electoral Code, Arts. 76-a(8), 76-d(5))
Allocation criteria for free or subsidized access to media for political parties: Number of candidates No. No clear rule allocates free or subsidised media access according to the number of candidates. Rules on media access use other criteria. (Electoral Code, Arts. 76-a(8), 76-d(5))
Allocation criteria for free or subsidized access to media for political parties: Share of seats No. The law uses parliamentary-status categories rather than allocation by share of seats. It distinguishes represented and non-represented parties and other parliamentary groupings. (Electoral Code, Arts. 76-a(8), 76-d(5))
Allocation criteria for free or subsidized access to media for political parties: Share of votes in preceding election No. No clear rule allocates free or subsidised media access by a party’s share of votes in the preceding election. (Electoral Code, Arts. 76-a(8), 76-d(5))
Allocation criteria for free or subsidized access to media for political parties: Other Yes. Media access rules use other criteria, including whether parties are represented in Parliament and their parliamentary-status grouping; the order of free presentation is determined by drawing lots. (Electoral Code, Art. 76-a(6), (8); Art. 76-d(5))
Are there provisions for free or subsidized access to media for candidates? Yes. The Code grants free political presentation to participants in the election process and provides budget funding for paid political advertising for election-process participants, which covers presidential candidacies and list submitters under the Code. (Electoral Code, Arts. 59, 60, 76-a(5), 76-e(2))
Are there provisions for any other form of indirect public funding? Yes. See subindicators
Provisions for any other form of indirect public funding: Premises for campaign meetings No. Absent from legal framework
Provisions for any other form of indirect public funding: Space for campaign materials Yes. Election posters may be displayed free of charge at locations determined and marked by municipalities and the City of Skopje, under equal conditions for campaign participants. (Electoral Code, Art. 78(1)-(2), (6))
Provisions for any other form of indirect public funding: Tax relief No. Absent from legal framework
Provisions for any other form of indirect public funding: Free or subsidised transport No. Absent from legal framework
Provisions for any other form of indirect public funding: Free or subsidised postage cost No. Absent from legal framework
Provisions for any other form of indirect public funding: Other No. Other explicit forms of indirect public funding were not clearly established beyond the free poster-space rule. (Electoral Code, Art. 78)
Is the provision of direct public funding to political parties related to gender equality among candidates? No. No rule in the public-funding provisions ties direct public funding for political parties to gender equality among candidates. (Law on Financing Political Parties, Arts. 9-10)
Are there provisions for other financial advantages to encourage gender equality in political parties? No. No separate financial advantage for political parties to encourage gender equality was clearly established in the party-financing rules. (Law on Financing Political Parties, Arts. 9-10)

Regulations on spending 

Is there a ban on vote buying? No. The criminal law penalises coercion, threats and deceit affecting how a person votes, but no clear explicit provision found in force in 2024 specifically bans buying votes as such. (Criminal Code of the Republic of North Macedonia, Art. 160)
Are there bans on state resources being used in favour or against a political party or candidate? Yes. The Electoral Code bars use of facilities, equipment and other property of state bodies and local self-government bodies for election campaigns, subject to a narrow equal-conditions exception, and campaign financing from state and municipal budgets and public enterprises is prohibited except as expressly allowed by law. (Electoral Code, Arts. 82(4)-(6), 83(1))
Are there limits on the amount a political party can spend? Yes. Election campaign organizers may not spend more than 60 denars per registered voter in the relevant district or municipality. (Electoral Code, Art. 84)
Are there limits on the amount a candidate can spend? No. The spending ceiling is set for the election campaign organizer, not expressly for a candidate as a separate legal actor. (Electoral Code, Arts. 71, 84)

Reporting, oversight and sanctions 

Reporting standards Yes. See subindicators
Do political parties have to report regularly on their finances? Yes. Political parties must prepare annual financial statements for the previous year and submit reports on received donations by 31 March. (Law on Financing Political Parties, Arts. 25, 27)
Do political parties have to report on their finances in relation to election campaigns? Yes. An election campaign organizer must submit a financial report on the election campaign with data on total funds, funding sources and expenses. (Electoral Code, Art. 85(1)-(3))
Do candidates have to report on their campaign finances? No. The Electoral Code places the reporting duty on the election campaign organizer rather than on candidates directly. (Electoral Code, Arts. 71, 85)
Is information in reports from political parties and/​or candidates to be made public? Yes. Annual donation reports must be published on the websites of the State Audit Office and the Public Revenue Office, parties must publish annual financial statements on their websites, and campaign finance reports must be published by the State Election Commission on its website. (Law on Financing Political Parties, Arts. 25(5), 27-a; Electoral Code, Art. 85(4))
Must reports from political parties and/​or candidates reveal the identity of donors? Yes. Donation reports must contain the data from the register of donations, and the donation register includes donor-identifying information. (Law on Financing Political Parties, Arts. 17, 25(1)-(3))
Institutions receiving financial reports from political parties and/​or candidates
Institutions receiving financial reports from political parties and/​or candidates: Electoral Management Board Yes. The State Election Commission receives campaign-finance reports and also receives proof that the campaign giro account was opened. (Electoral Code, Arts. 71(1), 85(3))
Institutions receiving financial reports from political parties and/​or candidates: Auditing agency Yes. The State Audit Office receives annual donation reports, annual financial statements and campaign-finance reports. (Law on Financing Political Parties, Arts. 25(3), 26(3), 27(4); Electoral Code, Art. 85(3))
Institutions receiving financial reports from political parties and/​or candidates: Ministry No. Ministries supervise or prescribe forms under the party-financing law, but the reporting provisions do not designate a ministry as a recipient of party or campaign finance reports. (Law on Financing Political Parties, Arts. 27(5), 36)
Institutions receiving financial reports from political parties and/​or candidates: Special institution No. No special anti-corruption body is designated as a recipient of party or campaign finance reports. The State Commission for Prevention of Corruption is only notified in relation to pressure or privileges linked to fundraising. (Law on Financing Political Parties, Art. 22)
Institutions receiving financial reports from political parties and/​or candidates: Court No. Courts are not designated as recipients of financial reports. They appear only in enforcement or misdemeanour proceedings. (Law on Financing Political Parties, Arts. 30-31)
Institutions receiving financial reports from political parties and/​or candidates: Other Yes. Other bodies expressly receiving reports include Parliament, the Public Revenue Office, the Central Register, and for local elections the municipal council or the Council of the City of Skopje. (Law on Financing Political Parties, Arts. 25(4), 26(3); Electoral Code, Art. 85(3), (5))
Political finance oversight Yes. See subindicators
Is it specified that a particular institution(s) is responsible for examining financial reports and/​or investigating violations?
Institution responsible for examining financial reports and/or investigating violations: Court No. Courts adjudicate misdemeanour proceedings and administrative disputes, but the law does not assign them examination of financial reports or investigation of violations. (Law on Financing Political Parties, Arts. 30, 31, 27-b(5), 27-c(3))
Institution responsible for examining financial reports and/or investigating violations: Ministry No. The Ministry of Justice supervises application of the law and adopts certain funding decisions, but the law does not clearly assign it examination of financial reports or investigation of violations. (Law on Financing Political Parties, Arts. 27-b(4), 27-c(2), 36)
Institution responsible for examining financial reports and/or investigating violations: Auditing agency Yes. The State Audit Office conducts annual supervision over the financial and material operations of political parties and may initiate misdemeanour proceedings or report to the public prosecutor when it finds irregularities. (Law on Financing Political Parties, Arts. 26, 27(4))
Institution responsible for examining financial reports and/or investigating violations: Electoral Management Body No. The State Election Commission receives campaign-finance reports and related notifications, but no clear provision was found assigning it examination of financial reports or investigation of violations. (Electoral Code, Arts. 71, 85)
Institution responsible for examining financial reports and/or investigating violations: Institution for this purpose Yes. The State Commission for Prevention of Corruption has an explicit role regarding prohibited pressure or promised benefits in fundraising and may carry the procedure by submitting a motion to competent bodies if it assesses criminal or misdemeanour liability. (Law on Financing Political Parties, Art. 22(3))
Institution responsible for examining financial reports and/or investigating violations: Other Yes. Other bodies also have explicit enforcement roles. When the State Audit Office finds irregularities, it may report them to the competent public prosecutor. (Law on Financing Political Parties, Art. 27(4))
Other institutions with a formal role in political finance oversight
Institutions with a formal role in political finance oversight: Court Yes. Courts have a formal role because the basic court is the competent body for misdemeanours under the party-financing law, and administrative disputes may be brought against certain funding-sanction decisions. (Law on Financing Political Parties, Arts. 27-b(5), 27-c(3), 30, 31)
Institutions with a formal role in political finance oversight: Ministry Yes. The Ministry of Justice formally oversees application of the party-financing law and adopts decisions on suspension or temporary loss of annual public funding on a proposal of the State Audit Office. (Law on Financing Political Parties, Arts. 27-b(4), 27-c(2), 36)
Institutions with a formal role in political finance oversight: Auditing agency Yes. The State Audit Office has a formal oversight role through annual supervision of party finances and by initiating further proceedings when it finds irregularities. (Law on Financing Political Parties, Arts. 26, 27(4))
Institutions with a formal role in political finance oversight: EMB Yes. The State Election Commission has a formal role in campaign-finance oversight because campaign organizers must notify it of the campaign account and submit campaign-finance reports to it. (Electoral Code, Arts. 71(1), 85(3))
Institutions with a formal role in political finance oversight: Institution for this purpose Yes. The State Commission for Prevention of Corruption has a formal role for prohibited fundraising pressure and promised benefits and may submit motions to competent bodies where criminal or misdemeanour liability is indicated. (Law on Financing Political Parties, Art. 22(3))
Institutions with a formal role in political finance oversight: Other Yes. Other institutions also have formal roles, including the Public Revenue Office and Central Register as report recipients under the party-financing law, and the competent public prosecutor where the State Audit Office identifies irregularities. (Law on Financing Political Parties, Arts. 26(3), 27(4))
Sanctions for political finance infractions
Sanctions for political finance infractions: Fines Yes. The law expressly provides misdemeanour fines for breaches of donation, publication and reporting rules. (Law on Financing Political Parties, Arts. 28, 29)
Sanctions for political finance infractions: Loss of public funding Yes. The law expressly allows suspension of annual public funding, temporary loss of annual public funding, loss of funding for the following year in some cases, and denial of budget funds for one year after repeated misdemeanours. (Law on Financing Political Parties, Arts. 20(3), 27-b, 27-c, 32)
Sanctions for political finance infractions: Penal/Criminal No. The party-financing law refers to possible criminal liability and reporting to the public prosecutor, but no clear criminal sanction was found in the cited party-financing provisions themselves. (Law on Financing Political Parties, Arts. 22(3), 27(4))
Sanctions for political finance infractions: Forfeiture Yes. The law requires unlawful or unverified funds to be returned to the donor or transferred to the state budget, which constitutes a clear deprivation of the funds concerned. (Law on Financing Political Parties, Arts. 16(2)-(3), 20(2))
Sanctions for political finance infractions: Deregistration of party No. Absent from legal framework
Sanctions for political finance infractions: Loss of elected office No. Absent from legal framework
Sanctions for political finance infractions: Suspension of political party No. Absent from legal framework
Sanctions for political finance infractions: Loss of nomination of candidate No. Absent from legal framework
Sanctions for political finance infractions: Loss of political rights No. Absent from legal framework
Sanctions for political finance infractions: Other Yes. Other explicit sanctions include suspension of payment of annual public funding until obligations are fulfilled and temporary loss of annual public funding for a defined period. (Law on Financing Political Parties, Arts. 27-b, 27-c, 32)

Legislation

*Last update: 2017


Financial Disclosure


Quantitative Data

Primary Metric

201220152016201720202024Trend
Disclosure items71
Filing frequency100
Sanctions100
Monitoring and Oversight100
Public access to declarations44

Alternative Metric

201220152016201720202024Trend
Head of State84
Ministers92
Members of Parliament78
Civil servants78

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness


Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Head of State

Disclosure items

Spouses and children included in disclosure Yes. The declaration explicitly includes assets and income of the spouse and household family members. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))
Income and Assets
Real estate Yes. A full declaration of income and assets is required for elected officials, including the President. (Article 83, Law on Prevention of Corruption and Conflict of Interest (2019))
Movable assets Yes. Movable property of significant value is included in the declaration. (Article 83, Law on Prevention of Corruption and Conflict of Interest (2019))
Cash Yes. Financial assets (including bank deposits and cash holdings) must be disclosed. (Article 83, Law on Prevention of Corruption and Conflict of Interest (2019))
Loans and Debts Yes. Liabilities must be declared as part of the financial disclosure. (Article 83, Law on Prevention of Corruption and Conflict of Interest (2019))
Income from outside employment/assets Yes. Liabilities must be declared as part of the financial disclosure. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))
Incompatibilities
Gifts received as a public official No . Gifts are regulated elsewhere in the law, but not included as a mandatory item in asset declarations.
Private firm ownership and/or stock holdings Yes. Gifts are regulated elsewhere in the law, but not included as a mandatory item in asset declarations. (Article 83, Law on Prevention of Corruption and Conflict of Interest (2019))
Ownership of state-owned enterprises (SOEs) No. Shareholdings must be declared, but no specific category for SOEs (covered under general assets). (Article 83, Law on Prevention of Corruption and Conflict of Interest (2019))
Holding government contracts No . Absence of legal framework
Board member, advisor, or company officer of private firm No. Functions and positions may need to be declared if they generate income or constitute an interest, but not always as a standalone category. (Article 82 and 83, Law on Prevention of Corruption and Conflict of Interest (2019))
Post-employment No . Absence of legal framework
Simultaneously holding policy-making position and policy-executing position No . Absence of legal framework
Participating in official decision-making processes that affect private interests No . Absence of legal framework
Concurrent employment of family members in public sector No . Absence of legal framework

Filing frequency

Filing required upon taking office Yes. Initial declaration required at the beginning of mandate. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))
Filing required upon leaving office Yes. Final declaration required after leaving office. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))
Filing required annually Yes. Annual updates are mandatory. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))
Ad hoc filing required upon change in assets or conflicts of interest Yes. Changes in assets must be reported. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))

Sanctions

Sanctions stipulated for late filing (fines, administrative, and/or criminal) Yes. Administrative sanctions apply for late submission. (Article 104 and 105, Law on Prevention of Corruption and Conflict of Interest (2019))
Sanctions stipulated for non-filing (fines, administrative, and/or criminal) Yes. Failure to submit declarations leads to sanctions. (Article 104 and 105, Law on Prevention of Corruption and Conflict of Interest (2019))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal) Yes. False declarations are sanctioned (administrative and potentially criminal). (Article 104 and 105, Law on Prevention of Corruption and Conflict of Interest (2019))

Monitoring and Oversight

Depository body explicitly identified Yes. Declarations are submitted to the State Commission for Prevention of Corruption. (Article 17, Law on Prevention of Corruption and Conflict of Interest (2019))
Enforcement body explicitly identified Yes. The same body is responsible for enforcement. (Article 17 and 18, Law on Prevention of Corruption and Conflict of Interest (2019))
Some agency assigned responsibility for verifying submission Yes. The Commission verifies whether declarations are submitted. (Article 88, Law on Prevention of Corruption and Conflict of Interest (2019))
Some agency assigned responsibility for verifying accuracy Yes. The Commission verifies the correctness of data. (Article 88, Law on Prevention of Corruption and Conflict of Interest (2019))

Public access to declarations

Public availability Yes. Asset declarations are publicly accessible. (Article 85, Law on Prevention of Corruption and Conflict of Interest (2019))
Timing of information release specified No . Absence of legal frame work
Location(s) of access specified Yes. Declarations are published in an official public register. (Article 85, Law on Prevention of Corruption and Conflict of Interest (2019))
Cost of access specified No . Absence of legal frame work

Ministers

Disclosure items

Spouses and children included in disclosure Yes. The declaration explicitly includes assets and income of the spouse and household family members. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))
Income and Assets
Real estate Yes. A full declaration of income and assets is required for elected officials, including the President. (Article 83, Law on Prevention of Corruption and Conflict of Interest (2019))
Movable assets Yes. Movable property of significant value is included in the declaration. (Article 83, Law on Prevention of Corruption and Conflict of Interest (2019))
Cash No. Financial assets (including bank deposits and cash holdings) must be disclosed. (Article 83, Law on Prevention of Corruption and Conflict of Interest (2019))
Loans and Debts Yes. Liabilities must be declared as part of the financial disclosure. (Article 83, Law on Prevention of Corruption and Conflict of Interest (2019))
Income from outside employment/assets Yes. Liabilities must be declared as part of the financial disclosure. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))
Incompatibilities
Gifts received as a public official Yes. Gifts regulated and restricted. (Article 58 and 60, Law on Prevention of Corruption and Conflict of Interest (2019))
Private firm ownership and/or stock holdings Yes. Must be declared; restrictions apply. (Article 83, Law on Prevention of Corruption and Conflict of Interest (2019))
Ownership of state-owned enterprises (SOEs) No. Covered under general asset disclosure, not separately specified. (Article 83, Law on Prevention of Corruption and Conflict of Interest (2019))
Holding government contracts Yes. Conflict of interest rules prohibit such situations. (Article 44 and 46, Law on Prevention of Corruption and Conflict of Interest (2019))
Board member, advisor, or company officer of private firm Yes. Secondary activities restricted and must be declared. (Article 48 and 50, Law on Prevention of Corruption and Conflict of Interest (2019))
Post-employment Yes. Cooling-off provisions exist. (Article 52, Law on Prevention of Corruption and Conflict of Interest (2019))
Simultaneously holding policy-making position and policy-executing position Yes. Incompatibility regime prohibits overlaps. (Article 44 and 47, Law on Prevention of Corruption and Conflict of Interest (2019))
Participating in official decision-making processes that affect private interests Yes. Conflict of interest rules apply. (Article 41 and 43, Law on Prevention of Corruption and Conflict of Interest (2019))
Concurrent employment of family members in public sector No. Covered under broader conflict-of-interest provisions. (Article 41 and 43, Law on Prevention of Corruption and Conflict of Interest (2019))

Filing frequency

Filing required upon taking office Yes. Multiple filing obligations exist. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))
Filing required upon leaving office Yes. Mandatory initial declaration. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))
Filing required annually Yes. Mandatory initial declaration. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))
Ad hoc filing required upon change in assets or conflicts of interest Yes. Changes must be reported. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))

Sanctions

Sanctions stipulated for late filing (fines, administrative, and/or criminal) Yes. Administrative fines apply. (Article 105 and 107, Law on Prevention of Corruption and Conflict of Interest (2019))
Sanctions stipulated for non-filing (fines, administrative, and/or criminal) Yes. Sanctions include fines and possible dismissal. (Article 105 and 107, Law on Prevention of Corruption and Conflict of Interest (2019))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal) Yes. Administrative + possible criminal liability. (Article 105 and 107, Law on Prevention of Corruption and Conflict of Interest (2019))

Monitoring and Oversight

Depository body explicitly identified Yes. SCPC receives declarations. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))
Enforcement body explicitly identified Yes. SCPC enforces compliance. (Article 20, Law on Prevention of Corruption and Conflict of Interest (2019))
Some agency assigned responsibility for verifying submission Yes. SCPC checks submission compliance. (Article 20, Law on Prevention of Corruption and Conflict of Interest (2019))
Some agency assigned responsibility for verifying accuracy Yes. SCPC verifies asset accuracy. (Article 20, Law on Prevention of Corruption and Conflict of Interest (2019))

Public access to declarations

Public availability Yes. Declarations published online. (Article 84, Law on Prevention of Corruption and Conflict of Interest (2019))
Timing of information release specified Yes. Publication required but timing not strictly detailed. (Article 84, Law on Prevention of Corruption and Conflict of Interest (2019))
Location(s) of access specified No. SCPC official platform. (Article 84, Law on Prevention of Corruption and Conflict of Interest (2019))
Cost of access specified Yes. Access is free (Article 84, Law on Prevention of Corruption and Conflict of Interest (2019))

Members of Parliament

Disclosure items

Spouses and children included in disclosure Yes. The declaration explicitly includes assets and income of the spouse and household family members. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))
Income and Assets
Real estate Yes. A full declaration of income and assets is required for elected officials, including the President. (Article 83, Law on Prevention of Corruption and Conflict of Interest (2019))
Movable assets Yes. Movable property of significant value is included in the declaration. (Article 83, Law on Prevention of Corruption and Conflict of Interest (2019))
Cash No. Financial assets (including bank deposits and cash holdings) must be disclosed. (Article 83, Law on Prevention of Corruption and Conflict of Interest (2019))
Loans and Debts Yes. Liabilities must be declared as part of the financial disclosure. (Article 83, Law on Prevention of Corruption and Conflict of Interest (2019))
Income from outside employment/assets Yes. Liabilities must be declared as part of the financial disclosure. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))
Incompatibilities
Gifts received as a public official No. Absence of legal framework
Private firm ownership and/or stock holdings No. Absence of legal framework
Ownership of state-owned enterprises (SOEs) No. Covered under general asset disclosure, not separately specified. (Article 83, Law on Prevention of Corruption and Conflict of Interest (2019))
Holding government contracts No. Absence of legal framework
Board member, advisor, or company officer of private firm Yes. Secondary activities restricted and must be declared. (Article 48 and 50, Law on Prevention of Corruption and Conflict of Interest (2019))
Post-employment No. Absence of legal framework
Simultaneously holding policy-making position and policy-executing position No. Absence of legal framework
Participating in official decision-making processes that affect private interests No. Absence of legal framework
Concurrent employment of family members in public sector No. Absence of legal framework

Filing frequency

Filing required upon taking office Yes. Multiple filing obligations exist. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))
Filing required upon leaving office Yes. Mandatory initial declaration. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))
Filing required annually Yes. Mandatory initial declaration. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))
Ad hoc filing required upon change in assets or conflicts of interest Yes. Changes must be reported. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))

Sanctions

Sanctions stipulated for late filing (fines, administrative, and/or criminal) Yes. Administrative fines apply. (Article 105 and 107, Law on Prevention of Corruption and Conflict of Interest (2019))
Sanctions stipulated for non-filing (fines, administrative, and/or criminal) Yes. Sanctions include fines and possible dismissal. (Article 105 and 107, Law on Prevention of Corruption and Conflict of Interest (2019))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal) Yes. Administrative + possible criminal liability. (Article 105 and 107, Law on Prevention of Corruption and Conflict of Interest (2019))

Monitoring and Oversight

Depository body explicitly identified Yes. SCPC receives declarations. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))
Enforcement body explicitly identified Yes. SCPC enforces compliance. (Article 20, Law on Prevention of Corruption and Conflict of Interest (2019))
Some agency assigned responsibility for verifying submission Yes. SCPC checks submission compliance. (Article 20, Law on Prevention of Corruption and Conflict of Interest (2019))
Some agency assigned responsibility for verifying accuracy Yes. SCPC verifies asset accuracy. (Article 20, Law on Prevention of Corruption and Conflict of Interest (2019))

Public access to declarations

Public availability Yes. Declarations published online. (Article 84, Law on Prevention of Corruption and Conflict of Interest (2019))
Timing of information release specified No. Absence of legal framework
Location(s) of access specified No. SCPC official platform. (Article 84, Law on Prevention of Corruption and Conflict of Interest (2019))
Cost of access specified No. Absence of legal framework

Civil servants

Disclosure items

Spouses and children included in disclosure Yes. The declaration explicitly includes assets and income of the spouse and household family members. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))
Income and Assets
Real estate Yes. A full declaration of income and assets is required for elected officials, including the President. (Article 83, Law on Prevention of Corruption and Conflict of Interest (2019))
Movable assets Yes. Movable property of significant value is included in the declaration. (Article 83, Law on Prevention of Corruption and Conflict of Interest (2019))
Cash No. Financial assets (including bank deposits and cash holdings) must be disclosed. (Article 83, Law on Prevention of Corruption and Conflict of Interest (2019))
Loans and Debts Yes. Liabilities must be declared as part of the financial disclosure. (Article 83, Law on Prevention of Corruption and Conflict of Interest (2019))
Income from outside employment/assets Yes. Liabilities must be declared as part of the financial disclosure. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))
Incompatibilities
Gifts received as a public official No. Absence of legal framework
Private firm ownership and/or stock holdings No. Absence of legal framework
Ownership of state-owned enterprises (SOEs) No. Covered under general asset disclosure, not separately specified. (Article 83, Law on Prevention of Corruption and Conflict of Interest (2019))
Holding government contracts No. Absence of legal framework
Board member, advisor, or company officer of private firm Yes. Secondary activities restricted and must be declared. (Article 48 and 50, Law on Prevention of Corruption and Conflict of Interest (2019))
Post-employment No. Absence of legal framework
Simultaneously holding policy-making position and policy-executing position No. Absence of legal framework
Participating in official decision-making processes that affect private interests No. Absence of legal framework
Concurrent employment of family members in public sector No. Absence of legal framework

Filing frequency

Filing required upon taking office Yes. Multiple filing obligations exist. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))
Filing required upon leaving office Yes. Mandatory initial declaration. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))
Filing required annually Yes. Mandatory initial declaration. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))
Ad hoc filing required upon change in assets or conflicts of interest Yes. Changes must be reported. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))

Sanctions

Sanctions stipulated for late filing (fines, administrative, and/or criminal) Yes. Administrative fines apply. (Article 105 and 107, Law on Prevention of Corruption and Conflict of Interest (2019))
Sanctions stipulated for non-filing (fines, administrative, and/or criminal) Yes. Sanctions include fines and possible dismissal. (Article 105 and 107, Law on Prevention of Corruption and Conflict of Interest (2019))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal) Yes. Administrative + possible criminal liability. (Article 105 and 107, Law on Prevention of Corruption and Conflict of Interest (2019))

Monitoring and Oversight

Depository body explicitly identified Yes. SCPC receives declarations. (Article 82, Law on Prevention of Corruption and Conflict of Interest (2019))
Enforcement body explicitly identified Yes. SCPC enforces compliance. (Article 20, Law on Prevention of Corruption and Conflict of Interest (2019))
Some agency assigned responsibility for verifying submission Yes. SCPC checks submission compliance. (Article 20, Law on Prevention of Corruption and Conflict of Interest (2019))
Some agency assigned responsibility for verifying accuracy Yes. SCPC verifies asset accuracy. (Article 20, Law on Prevention of Corruption and Conflict of Interest (2019))

Public access to declarations

Public availability Yes. Declarations published online. (Article 84, Law on Prevention of Corruption and Conflict of Interest (2019))
Timing of information release specified No. Absence of legal framework
Location(s) of access specified No. SCPC official platform. (Article 84, Law on Prevention of Corruption and Conflict of Interest (2019))
Cost of access specified No. Absence of legal framework

Legislation

*Last update: 2017


Conflict of Interest


Quantitative Data

Primary Metric

201220152016201720202024Trend
Restrictions68
Sanctions67
Monitoring and Oversight100

Alternative Metric

201220152016201720202024Trend
Head of State79
Ministers79
Members of Parliament79
Civil servants76

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness


Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Head of State

Restrictions

General restriction on conflict of interest Yes. The President is an “official person” under the anti-corruption law and must act lawfully and with integrity, while taking care of and avoiding conflicts of interest. (Law on Prevention of Corruption and Conflict of Interests, Arts. 3, 4, 8(2), 72)
Accepting gifts Yes. The President may not receive gifts in office except within the statutory gift regime, and gifts that affect or may affect impartial performance must be surrendered. (Law on Prevention of Corruption and Conflict of Interests, Art. 58)
Private firm ownership and/or stock holdings No. There is no blanket ban on owning a private firm or holding shares. The law instead requires disclosure of owned companies, shares, and management roles, and requires transfer of management rights if the official managed a company as owner. (Law on Prevention of Corruption and Conflict of Interests, Art. 45(1)-(5))
Ownership of state-owned enterprises (SOEs) No. There is no general ban on owning shares in state-owned enterprises. The law bars certain management or supervisory roles in entities with dominant state capital, not shareholding as such. (Law on Prevention of Corruption and Conflict of Interests, Arts. 44(4), 49(1))
Holding government contracts No. The law bars business relationships between the official and entities owned by the official or family, and requires reporting certain dealings with state property, but it does not create a blanket ban on all government contracts. (Law on Prevention of Corruption and Conflict of Interests, Arts. 51, 53)
Board member, advisor, or company officer of private firm Yes. The President cannot perform another public office, profession, or party appointment, and the anti-corruption law transfers management rights and bans some company-body roles. (Constitution of the Republic of North Macedonia, Art. 83; Law on Prevention of Corruption and Conflict of Interests, Arts. 44(1), 45, 49(1))
Post-employment Yes. Post-employment restrictions exist. For three years, a former official cannot work for or acquire shares in a supervised or contracting company, and for two years cannot represent others before the former body in covered cases. (Law on Prevention of Corruption and Conflict of Interests, Arts. 47, 48, 50(2))
Simultaneously holding policy-making position and policy-executing position Yes. The Constitution makes the office of President incompatible with any other public office, profession, or appointment in a political party. (Constitution of the Republic of North Macedonia, Art. 83)
Participating in official decision-making processes that affect private interests Yes. If the President participates in a decision on a matter in which he or a close person has a private interest, he must declare the private interest and withdraw before discussion and decision-making. (Law on Prevention of Corruption and Conflict of Interests, Arts. 73, 75)
Assisting family or friends in obtaining employment in public sector Yes. The law expressly forbids an official person from influencing the employment or promotion of a close person in the body where he is elected or appointed or in supervised public entities. (Law on Prevention of Corruption and Conflict of Interests, Art. 56)

Sanctions

Fines are stipulated for violations of COI regulations restricting behavior Yes. Fines are expressly stipulated for violations of the law, including conflict-of-interest duties and incompatibility-related restrictions. (Law on Prevention of Corruption and Conflict of Interests, Arts. 105, 107)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior Yes. Administrative sanctions are expressly stipulated. The State Commission can seek dismissal or termination for appointed or elected officials, and can issue a public warning for an official elected in direct elections who fails to remove the conflict. (Law on Prevention of Corruption and Conflict of Interests, Arts. 77-79)
Penal sanctions are stipulated for violations of COI regulations restricting behavior No. The anti-corruption law does not itself create a specific criminal sanction for these restrictions. It provides misdemeanor sanctions and duties to report suspected criminal offences, but no stand-alone penal offence in this law. (Law on Prevention of Corruption and Conflict of Interests, Arts. 61, 99-107)

Monitoring and Oversight

Monitoring body specified (guidance, training, data tracking) Yes. A monitoring body is specified: tTcollection, and preventive competences. (Law on Prevention of Corruption and Conflict of Interests, Arts. 17, 99)
Enforcement body specified (sanctions, hearings) Yes. The State Commission for Prevention of Corruption initiates conflict-of-interest proceedings, issues decisions, requests removal of conflicts, triggers dismissal or disciplinary procedures, issues public warnings, and starts misdemeanor proceedings. (Law on Prevention of Corruption and Conflict of Interests, Arts. 76-79, 98-99)

Ministers

Restrictions

General restriction on conflict of interest Yes. Ministers are official persons under the anti-corruption law and must act lawfully and with integrity, while taking care of and avoiding conflicts of interest. (Law on Prevention of Corruption and Conflict of Interests, Arts. 3, 4, 8(2), 72)
Accepting gifts Yes. Ministers may not receive gifts in office except within the statutory gift regime, and gifts that affect or may affect impartial performance must be surrendered. (Law on Prevention of Corruption and Conflict of Interests, Art. 58)
Private firm ownership and/or stock holdings No. There is no blanket ban on owning a private firm or holding shares. The law instead requires disclosure of owned companies, shares, and management roles, and requires transfer of management rights if the official managed a company as owner. (Law on Prevention of Corruption and Conflict of Interests, Art. 45(1)-(5))
Ownership of state-owned enterprises (SOEs) No. There is no general ban on owning shares in state-owned enterprises. The law bars certain management or supervisory roles in entities with dominant state capital, not shareholding as such. (Law on Prevention of Corruption and Conflict of Interests, Arts. 44(4), 49(1))
Holding government contracts No. The law bars business relationships between the official and entities owned by the official or family, and requires reporting certain dealings with state property, but it does not create a blanket ban on all government contracts. (Law on Prevention of Corruption and Conflict of Interests, Arts. 51, 53)
Board member, advisor, or company officer of private firm Yes. The Constitution makes the office of minister incompatible with any other public office or profession, and the anti-corruption law transfers management rights and bans some company-body roles. (Constitution of the Republic of North Macedonia, Art. 89; Law on Prevention of Corruption and Conflict of Interests, Arts. 44(1), 45, 49(1))
Post-employment Yes. Post-employment restrictions exist. For three years, a former official cannot work for or acquire shares in a supervised or contracting company, and for two years cannot represent others before the former body in covered cases. (Law on Prevention of Corruption and Conflict of Interests, Arts. 47, 48, 50(2))
Simultaneously holding policy-making position and policy-executing position Yes. The Constitution provides that ministers cannot be Members of Parliament, and that the office of Prime Minister or Minister is incompatible with any other public office or profession. (Constitution of the Republic of North Macedonia, Art. 89)
Participating in official decision-making processes that affect private interests Yes. If a minister participates in a decision on a matter in which he or a close person has a private interest, he must declare the private interest and withdraw before discussion and decision-making. (Law on Prevention of Corruption and Conflict of Interests, Arts. 73, 75)
Assisting family or friends in obtaining employment in public sector Yes. The law expressly forbids an official person from influencing the employment or promotion of a close person in the body where he is elected or appointed or in supervised public entities. (Law on Prevention of Corruption and Conflict of Interests, Art. 56)

Sanctions

Fines are stipulated for violations of COI regulations restricting behavior Yes. Fines are expressly stipulated for violations of the law, including conflict-of-interest duties and incompatibility-related restrictions. (Law on Prevention of Corruption and Conflict of Interests, Arts. 105, 107)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior Yes. Administrative sanctions are expressly stipulated. The State Commission can seek dismissal or termination for appointed or elected officials, and can issue a public warning for an official elected in direct elections who fails to remove the conflict. (Law on Prevention of Corruption and Conflict of Interests, Arts. 77-79)
Penal sanctions are stipulated for violations of COI regulations restricting behavior No. The anti-corruption law does not itself create a specific criminal sanction for these restrictions. It provides misdemeanor sanctions and duties to report suspected criminal offences, but no stand-alone penal offence in this law. (Law on Prevention of Corruption and Conflict of Interests, Arts. 61, 99-107)

Monitoring and Oversight

Monitoring body specified (guidance, training, data tracking) Yes. The State Commission for Prevention of Corruption supervises implementation of the law and has broad monitoring, guidance, data-collection, and preventive competences. (Law on Prevention of Corruption and Conflict of Interests, Arts. 17, 99)
Enforcement body specified (sanctions, hearings) Yes. The State Commission for Prevention of Corruption initiates conflict-of-interest proceedings, issues decisions, requests removal of conflicts, triggers dismissal or disciplinary procedures, issues public warnings, and starts misdemeanor proceedings. (Law on Prevention of Corruption and Conflict of Interests, Arts. 76-79, 98-99)

Members of Parliament

Restrictions

General restriction on conflict of interest Yes. Members of Parliament are official persons under the anti-corruption law and must act lawfully and with integrity, while taking care of and avoiding conflicts of interest. (Law on Prevention of Corruption and Conflict of Interests, Arts. 3, 4, 8(2), 72)
Accepting gifts Yes. Members of Parliament may not receive gifts in office except within the statutory gift regime, and gifts that affect or may affect impartial performance must be surrendered. (Law on Prevention of Corruption and Conflict of Interests, Art. 58)
Private firm ownership and/or stock holdings No. There is no blanket ban on owning a private firm or holding shares. The law instead requires disclosure of owned companies, shares, and management roles, and requires transfer of management rights if the official managed a company as owner. (Law on Prevention of Corruption and Conflict of Interests, Art. 45(1)-(5))
Ownership of state-owned enterprises (SOEs) No. There is no general ban on owning shares in state-owned enterprises. The law bars certain management or supervisory roles in entities with dominant state capital, not shareholding as such. (Law on Prevention of Corruption and Conflict of Interests, Arts. 44(4), 49(1))
Holding government contracts No. The law bars business relationships between the official and entities owned by the official or family, and requires reporting certain dealings with state property, but it does not create a blanket ban on all government contracts. (Law on Prevention of Corruption and Conflict of Interests, Arts. 51, 53)
Board member, advisor, or company officer of private firm Yes. Members of Parliament cannot hold another public office or profession, and the anti-corruption law transfers management rights and bans some company-body roles (Constitution of the Republic of North Macedonia, Art. 63; Law on Prevention of Corruption and Conflict of Interests, Arts. 44(1), 45, 49(1))
Post-employment Yes. Post-employment restrictions exist. For three years, a former official cannot work for or acquire shares in a supervised or contracting company, and for two years cannot represent others before the former body in covered cases. (Law on Prevention of Corruption and Conflict of Interests, Arts. 47, 48, 50(2))
Simultaneously holding policy-making position and policy-executing position Yes. The Constitution provides that the office of Member of Parliament is incompatible with other public offices or professions. (Constitution of the Republic of North Macedonia, Art. 63)
Participating in official decision-making processes that affect private interests Yes. If a Member of Parliament participates in a decision on a matter in which he or a close person has a private interest, he must declare the private interest and withdraw before discussion and decision-making. (Law on Prevention of Corruption and Conflict of Interests, Arts. 73, 75)
Assisting family or friends in obtaining employment in public sector Yes. The law expressly forbids an official person from influencing the employment or promotion of a close person in the body where he is elected or appointed or in supervised public entities. (Law on Prevention of Corruption and Conflict of Interests, Art. 56)

Sanctions

Fines are stipulated for violations of COI regulations restricting behavior Yes. Fines are expressly stipulated for violations of the law, including conflict-of-interest duties and incompatibility-related restrictions. (Law on Prevention of Corruption and Conflict of Interests, Arts. 105, 107)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior Yes. Administrative sanctions are expressly stipulated. The State Commission can seek dismissal or termination for appointed or elected officials, and can issue a public warning for an official elected in direct elections who fails to remove the conflict. (Law on Prevention of Corruption and Conflict of Interests, Arts. 77-79)
Penal sanctions are stipulated for violations of COI regulations restricting behavior No. The anti-corruption law does not itself create a specific criminal sanction for these restrictions. It provides misdemeanor sanctions and duties to report suspected criminal offences, but no stand-alone penal offence in this law. (Law on Prevention of Corruption and Conflict of Interests, Arts. 61, 99-107)

Monitoring and Oversight

Monitoring body specified (guidance, training, data tracking) Yes. The State Commission for Prevention of Corruption supervises implementation of the law and has broad monitoring, guidance, data-collection, and preventive competences. (Law on Prevention of Corruption and Conflict of Interests, Arts. 17, 99)
Enforcement body specified (sanctions, hearings) Yes. The State Commission for Prevention of Corruption initiates conflict-of-interest proceedings, issues decisions, requests removal of conflicts, triggers dismissal or disciplinary procedures, issues public warnings, and starts misdemeanor proceedings. (Law on Prevention of Corruption and Conflict of Interests, Arts. 76-79, 98-99)

Civil servants

Restrictions

General restriction on conflict of interest Yes. Administrative servants are covered by the anti-corruption law as official persons and must act lawfully and with integrity, while taking care of and avoiding conflicts of interest. (Law on Prevention of Corruption and Conflict of Interests, Arts. 3, 4, 8(2), 72)
Accepting gifts Yes. Administrative servants may not receive gifts in office except within the statutory gift regime, and gifts that affect or may affect impartial performance must be surrendered. (Law on Prevention of Corruption and Conflict of Interests, Art. 58)
Private firm ownership and/or stock holdings No. There is no blanket ban on owning a private firm or holding shares. The law instead requires disclosure of owned companies, shares, and management roles, and requires transfer of management rights if the official managed a company as owner. (Law on Prevention of Corruption and Conflict of Interests, Art. 45(1)-(5))
Ownership of state-owned enterprises (SOEs) No. There is no general ban on owning shares in state-owned enterprises. The law bars certain management or supervisory roles in entities with dominant state capital, not shareholding as such. (Law on Prevention of Corruption and Conflict of Interests, Arts. 44(4), 49(1))
Holding government contracts No. The law bars business relationships between the official and entities owned by the official or family, and requires reporting certain dealings with state property, but it does not create a blanket ban on all government contracts. (Law on Prevention of Corruption and Conflict of Interests, Arts. 51, 53)
Board member, advisor, or company officer of private firm Yes. The anti-corruption law transfers management rights and bans some management or supervisory roles, especially in entities with dominant state capital. (Law on Prevention of Corruption and Conflict of Interests, Arts. 44(4), 45, 49(1))
Post-employment Yes. For three years, a former official cannot work for or acquire shares in a supervised or contracting company, and for two years cannot represent others before the former body in covered cases. (Law on Prevention of Corruption and Conflict of Interests, Arts. 47, 48, 50(2))
Simultaneously holding policy-making position and policy-executing position No. Absent from legal framework
Participating in official decision-making processes that affect private interests Yes. If an administrative servant participates in a decision on a matter in which he or a close person has a private interest, he must declare the private interest and withdraw before discussion and decision-making. (Law on Prevention of Corruption and Conflict of Interests, Arts. 73, 75)
Assisting family or friends in obtaining employment in public sector Yes. The law expressly forbids an official person from influencing the employment or promotion of a close person in the body where he is elected, appointed, or employed, or in supervised public entities. (Law on Prevention of Corruption and Conflict of Interests, Art. 56)

Sanctions

Fines are stipulated for violations of COI regulations restricting behavior Yes. Fines are expressly stipulated for violations of the law, including conflict-of-interest duties and incompatibility-related restrictions. (Law on Prevention of Corruption and Conflict of Interests, Arts. 105, 107)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior Yes. Administrative consequences are expressly stipulated. The State Commission can request initiation of disciplinary procedures before the competent body and can seek removal of the conflict or other follow-up under the law. (Law on Prevention of Corruption and Conflict of Interests, Arts. 76-79)
Penal sanctions are stipulated for violations of COI regulations restricting behavior No. The anti-corruption law does not itself create a specific criminal sanction for these restrictions. It provides misdemeanor sanctions and duties to report suspected criminal offences, but no stand-alone penal offence in this law. (Law on Prevention of Corruption and Conflict of Interests, Arts. 61, 99-107)

Monitoring and Oversight

Monitoring body specified (guidance, training, data tracking) Yes. The State Commission for Prevention of Corruption supervises implementation of the law and has broad monitoring, guidance, data-collection, and preventive competences. (Law on Prevention of Corruption and Conflict of Interests, Arts. 17, 99)
Enforcement body specified (sanctions, hearings) Yes. The State Commission for Prevention of Corruption initiates conflict-of-interest proceedings, issues decisions, requests removal of conflicts, triggers dismissal or disciplinary procedures, issues public warnings, and starts misdemeanor proceedings. (Law on Prevention of Corruption and Conflict of Interests, Arts. 76-79, 98-99)

Legislation

*Last update: 2017


Freedom of Information


Quantitative Data

Primary Metric

201220152016201720202024Trend
Scope and Coverage100
Information access and release83
Exceptions and Overrides83
Sanctions for non-compliance33
Monitoring and Oversight83

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness


Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Scope and Coverage

Scope of disclosure

Existence of legal right to access Yes. (1) All legal entities and natural person shall have free access to information. (2) Foreign legal entities and natural persons shall also have free access to information in accordance with this and other law. (Article 4, (1) and (2) Law on Free Access to Public Information)
"Information" or "Documents" is defined Yes. - “public information” is information in any form created or held by the holder of information in accordance with its competencies (hereinafter referred to as: information),// - “document” is any record of information regardless of its physical form or characteristics, written or printed text, maps, schemes, photographs, pictures, drawings, working materials, as well as audio, voice, magnetic or electronic, optical or video recordings in any form, also including portable equipment for automatic data processing with inbuilt or portable memories for storing data in a digital format, (Article 3, Law on Free Access to Public Information)
Proactive disclosure is specified Yes. The holders of information shall be obliged to regularly keep and update the list of information they have at their disposal and publish it in a manner accessible to the public (website, bulletin board and other) (Article 9, Law on Free Access to Public Information)

Coverage of public and private sectors

Executive branch Yes. “holders of information” are the state bodies and other bodies and organizations defined by law, the bodies of the municipalities, the City of Skopje and the municipalities in the City of Skopje, institutions and public services, public enterprises, legal entities and natural persons that exercise public authorizations defined by law and activities of public interest and political parties in the part pertaining to revenues and expenditures, (Article 3, Law on Free Access to Public Information)
Legislative branch Yes. “holders of information” are the state bodies and other bodies and organizations defined by law, the bodies of the municipalities, the City of Skopje and the municipalities in the City of Skopje, institutions and public services, public enterprises, legal entities and natural persons that exercise public authorizations defined by law and activities of public interest and political parties in the part pertaining to revenues and expenditures, (Article 3, Law on Free Access to Public Information)
Judicial branch Yes. “holders of information” are the state bodies and other bodies and organizations defined by law, the bodies of the municipalities, the City of Skopje and the municipalities in the City of Skopje, institutions and public services, public enterprises, legal entities and natural persons that exercise public authorizations defined by law and activities of public interest and political parties in the part pertaining to revenues and expenditures, (Article 3, Law on Free Access to Public Information)
Other public bodies Yes. “holders of information” are the state bodies and other bodies and organizations defined by law, the bodies of the municipalities, the City of Skopje and the municipalities in the City of Skopje, institutions and public services, public enterprises, legal entities and natural persons that exercise public authorizations defined by law and activities of public interest and political parties in the part pertaining to revenues and expenditures, (Article 3, Law on Free Access to Public Information)
Private sector Yes. “holders of information” are the state bodies and other bodies and organizations defined by law, the bodies of the municipalities, the City of Skopje and the municipalities in the City of Skopje, institutions and public services, public enterprises, legal entities and natural persons that exercise public authorizations defined by law and activities of public interest and political parties in the part pertaining to revenues and expenditures, (Article 3, Law on Free Access to Public Information)

Access to specific documents (subject to reactive and/or proactive disclosure)

Draft legal instruments Yes. (1) The holder of information shall be obliged to inform the public via its website by publishing: - data arising from the competences it performs, stipulated by law, - basic data for contact with the holder of information as follows: name, address, telephone number, fax number, e-mail and website, - data on the public official or the responsible person at the holder of information (CV, contact information, etc.), - basic data for contact with the official for mediation with information as follows: name and surname, e-mail and telephone number, - basic data for contact with the person authorized for protected internal reporting as follows: name and surname, e-mail and telephone number, - list of persons employed at the holder of information including position, business e-mail and business telephone number, - the laws pertaining to the competence of the holder of information, related to the register of regulations published in the official gazette, - regulations adopted by the holder of information in accordance with its competence in the form of a by-law: rulebooks (rulebook on internal organization, rulebook on job systematization, rulebook on protected internal reporting and other), decrees, orders, instructions, plans, programs, decisions and other types of acts for the enforcement of laws and other regulations, when authorized for that purpose by the law, - organizational chart of the internal organization, - strategic plans and work strategies of the holders of information, - annual plans and programs for operation, - annual budget and annual accounts, - annual financial plans by quarters and programs for budget implementation, - audit report, - types of services provided by the holders of information (information on the physical availability for the provision of services and information for eservices, data on the legal grounds, the name of the services, the documents and data required for the provision of each service, mechanisms of legal protection and other relevant data), - pricelists of fees for issuing real acts, - the manner of submission of an application for access to information (manner of submission of an oral and written application for access to information, as well an electronic application), - the entire documentation pertaining to public procurements, concessions and public-private partnership agreements, - draft programs, programs, standpoints, opinions, studies and other similar documents pertaining to the acts under the competence of the holder of information, press releases on downloads from their websites in accordance with the legal competences, newsletters, official gazettes if they constitute an obligation under the law, and other, - reports on the operation submitted to the bodies competent for control and supervision, - statistical data on the operation, as well as other information, acts and measures that affect the life and work of the citizens, arising from the competence and the operation of the holder of information, and - other information arising from the competence and the operation of the holder of information. (Article 10, Law on Free Access to Public Information)
Enacted legal instruments Yes. (1) The holder of information shall be obliged to inform the public via its website by publishing: - data arising from the competences it performs, stipulated by law, - basic data for contact with the holder of information as follows: name, address, telephone number, fax number, e-mail and website, - data on the public official or the responsible person at the holder of information (CV, contact information, etc.), - basic data for contact with the official for mediation with information as follows: name and surname, e-mail and telephone number, - basic data for contact with the person authorized for protected internal reporting as follows: name and surname, e-mail and telephone number, - list of persons employed at the holder of information including position, business e-mail and business telephone number, - the laws pertaining to the competence of the holder of information, related to the register of regulations published in the official gazette, - regulations adopted by the holder of information in accordance with its competence in the form of a by-law: rulebooks (rulebook on internal organization, rulebook on job systematization, rulebook on protected internal reporting and other), decrees, orders, instructions, plans, programs, decisions and other types of acts for the enforcement of laws and other regulations, when authorized for that purpose by the law, - organizational chart of the internal organization, - strategic plans and work strategies of the holders of information, - annual plans and programs for operation, - annual budget and annual accounts, - annual financial plans by quarters and programs for budget implementation, - audit report, - types of services provided by the holders of information (information on the physical availability for the provision of services and information for eservices, data on the legal grounds, the name of the services, the documents and data required for the provision of each service, mechanisms of legal protection and other relevant data), - pricelists of fees for issuing real acts, - the manner of submission of an application for access to information (manner of submission of an oral and written application for access to information, as well an electronic application), - the entire documentation pertaining to public procurements, concessions and public-private partnership agreements, - draft programs, programs, standpoints, opinions, studies and other similar documents pertaining to the acts under the competence of the holder of information, press releases on downloads from their websites in accordance with the legal competences, newsletters, official gazettes if they constitute an obligation under the law, and other, - reports on the operation submitted to the bodies competent for control and supervision, - statistical data on the operation, as well as other information, acts and measures that affect the life and work of the citizens, arising from the competence and the operation of the holder of information, and - other information arising from the competence and the operation of the holder of information. (Article 10, Law on Free Access to Public Information)
Annual budgets Yes. (1) The holder of information shall be obliged to inform the public via its website by publishing: - data arising from the competences it performs, stipulated by law, - basic data for contact with the holder of information as follows: name, address, telephone number, fax number, e-mail and website, - data on the public official or the responsible person at the holder of information (CV, contact information, etc.), - basic data for contact with the official for mediation with information as follows: name and surname, e-mail and telephone number, - basic data for contact with the person authorized for protected internal reporting as follows: name and surname, e-mail and telephone number, - list of persons employed at the holder of information including position, business e-mail and business telephone number, - the laws pertaining to the competence of the holder of information, related to the register of regulations published in the official gazette, - regulations adopted by the holder of information in accordance with its competence in the form of a by-law: rulebooks (rulebook on internal organization, rulebook on job systematization, rulebook on protected internal reporting and other), decrees, orders, instructions, plans, programs, decisions and other types of acts for the enforcement of laws and other regulations, when authorized for that purpose by the law, - organizational chart of the internal organization, - strategic plans and work strategies of the holders of information, - annual plans and programs for operation, - annual budget and annual accounts, - annual financial plans by quarters and programs for budget implementation, - audit report, - types of services provided by the holders of information (information on the physical availability for the provision of services and information for eservices, data on the legal grounds, the name of the services, the documents and data required for the provision of each service, mechanisms of legal protection and other relevant data), - pricelists of fees for issuing real acts, - the manner of submission of an application for access to information (manner of submission of an oral and written application for access to information, as well an electronic application), - the entire documentation pertaining to public procurements, concessions and public-private partnership agreements, - draft programs, programs, standpoints, opinions, studies and other similar documents pertaining to the acts under the competence of the holder of information, press releases on downloads from their websites in accordance with the legal competences, newsletters, official gazettes if they constitute an obligation under the law, and other, - reports on the operation submitted to the bodies competent for control and supervision, - statistical data on the operation, as well as other information, acts and measures that affect the life and work of the citizens, arising from the competence and the operation of the holder of information, and - other information arising from the competence and the operation of the holder of information. (Article 10, Law on Free Access to Public Information)
Annual chart of accounts (actual expenditures) Yes. (1) The holder of information shall be obliged to inform the public via its website by publishing: - data arising from the competences it performs, stipulated by law, - basic data for contact with the holder of information as follows: name, address, telephone number, fax number, e-mail and website, - data on the public official or the responsible person at the holder of information (CV, contact information, etc.), - basic data for contact with the official for mediation with information as follows: name and surname, e-mail and telephone number, - basic data for contact with the person authorized for protected internal reporting as follows: name and surname, e-mail and telephone number, - list of persons employed at the holder of information including position, business e-mail and business telephone number, - the laws pertaining to the competence of the holder of information, related to the register of regulations published in the official gazette, - regulations adopted by the holder of information in accordance with its competence in the form of a by-law: rulebooks (rulebook on internal organization, rulebook on job systematization, rulebook on protected internal reporting and other), decrees, orders, instructions, plans, programs, decisions and other types of acts for the enforcement of laws and other regulations, when authorized for that purpose by the law, - organizational chart of the internal organization, - strategic plans and work strategies of the holders of information, - annual plans and programs for operation, - annual budget and annual accounts, - annual financial plans by quarters and programs for budget implementation, - audit report, - types of services provided by the holders of information (information on the physical availability for the provision of services and information for eservices, data on the legal grounds, the name of the services, the documents and data required for the provision of each service, mechanisms of legal protection and other relevant data), - pricelists of fees for issuing real acts, - the manner of submission of an application for access to information (manner of submission of an oral and written application for access to information, as well an electronic application), - the entire documentation pertaining to public procurements, concessions and public-private partnership agreements, - draft programs, programs, standpoints, opinions, studies and other similar documents pertaining to the acts under the competence of the holder of information, press releases on downloads from their websites in accordance with the legal competences, newsletters, official gazettes if they constitute an obligation under the law, and other, - reports on the operation submitted to the bodies competent for control and supervision, - statistical data on the operation, as well as other information, acts and measures that affect the life and work of the citizens, arising from the competence and the operation of the holder of information, and - other information arising from the competence and the operation of the holder of information. (Article 10, Law on Free Access to Public Information)
Annual reports of public entities and programs Yes. (1) The holder of information shall be obliged to inform the public via its website by publishing: - data arising from the competences it performs, stipulated by law, - basic data for contact with the holder of information as follows: name, address, telephone number, fax number, e-mail and website, - data on the public official or the responsible person at the holder of information (CV, contact information, etc.), - basic data for contact with the official for mediation with information as follows: name and surname, e-mail and telephone number, - basic data for contact with the person authorized for protected internal reporting as follows: name and surname, e-mail and telephone number, - list of persons employed at the holder of information including position, business e-mail and business telephone number, - the laws pertaining to the competence of the holder of information, related to the register of regulations published in the official gazette, - regulations adopted by the holder of information in accordance with its competence in the form of a by-law: rulebooks (rulebook on internal organization, rulebook on job systematization, rulebook on protected internal reporting and other), decrees, orders, instructions, plans, programs, decisions and other types of acts for the enforcement of laws and other regulations, when authorized for that purpose by the law, - organizational chart of the internal organization, - strategic plans and work strategies of the holders of information, - annual plans and programs for operation, - annual budget and annual accounts, - annual financial plans by quarters and programs for budget implementation, - audit report, - types of services provided by the holders of information (information on the physical availability for the provision of services and information for eservices, data on the legal grounds, the name of the services, the documents and data required for the provision of each service, mechanisms of legal protection and other relevant data), - pricelists of fees for issuing real acts, - the manner of submission of an application for access to information (manner of submission of an oral and written application for access to information, as well an electronic application), - the entire documentation pertaining to public procurements, concessions and public-private partnership agreements, - draft programs, programs, standpoints, opinions, studies and other similar documents pertaining to the acts under the competence of the holder of information, press releases on downloads from their websites in accordance with the legal competences, newsletters, official gazettes if they constitute an obligation under the law, and other, - reports on the operation submitted to the bodies competent for control and supervision, - statistical data on the operation, as well as other information, acts and measures that affect the life and work of the citizens, arising from the competence and the operation of the holder of information, and - other information arising from the competence and the operation of the holder of information. (Article 10, Law on Free Access to Public Information)

Information access and release

Procedural access

Universal access (agencies, citizens and non-citizens) Yes. (1) All legal entities and natural person shall have free access to information. (2) Foreign legal entities and natural persons shall also have free access to information in accordance with this and other law. (Article 4, (1) and (2) Law on Free Access to Public Information)
Type of request is specified (written, electronic, oral) Yes. (1) The applicant may apply for access to information in an oral, written or electronic manner. (Article 12, Law on Free Access to Public Information)
Assistance to requesters must be provided by law (includes barriers due to language differences, illiteracy, complexity of requests, etc.) Yes. (2) The official appointed for mediation with information shall be obliged to provide adequate assistance to the applicant with the supplementation of the request. (Article 17, Law on Free Access to Public Information)
Cost of access is specified (free, request fees, photocopying costs, other administrative costs) Yes. (1) The insight into the required information is free of charge. (2) The applicant for information shall pay a fee in the amount of the material costs for the received transcript, photocopy or electronic record ofthe information. (3) The Government of the Republic of Macedonia, upon a proposal of the Ministry of Finance, shall define the amount of the fee for the material costs for the provided information by the holders of information. (4) The holder of information shall adequately publish the amount of the fee referred to in paragraph (3) of this Article (in the official newsletter of the holder of information, on the website, bulletin board and other), and it shall provide it for insight to every applicant before the submission of the request. (5) If the request refers to a greater scope of information, the holder of the information may ask the applicant to pay the fee for covering the costs for obtaining the information in advance. (Article 28, Law on Free Access to Public Information)

Deadlines for release of information

20-day response deadline Yes. (1) The holder of the information shall be obliged to immediately respond to the applicant’s request and no later than 20 days as of the day ofreceipt of the request. (Article 21, Law on Free Access to Public Information)
Agency granted right to extend response time Yes. (1) In the event that the holder of the information has to provide partial access to the information pursuant to Article 6 paragraph (4) of this Law or, due to the size of the required information it takes it longer than the deadline stipulated in Article 21 of this Law, the deadline can be extended for up to 30 days as of the day of receipt of the request. (Article 22, Law on Free Access to Public Information)
Maximum total response time of no more than 40 days No. (1) In the event that the holder of the information has to provide partial access to the information pursuant to Article 6 paragraph (4) of this Law or, due to the size of the required information it takes it longer than the deadline stipulated in Article 21 of this Law, the deadline can be extended for up to 30 days as of the day of receipt of the request. (Article 22, Law on Free Access to Public Information)

Exceptions and Overrides

Exemptions to disclosure

Existence of secrecy/states secrets law Yes. Law on Classified Information (Закон за класифицирани информации) Official Gazette of the Republic of North Macedonia Nos. 9/2004, 113/2007, 145/2010, 80/2012, 41/2014, 21/2018, 83/2018 (Law on Classified Information (Закон за класифицирани информации) Official Gazette of the Republic of North Macedonia Nos. 9/2004, 113/2007, 145/2010, 80/2012, 41/2014, 21/2018, 83/2018)
Existence of personal privacy/data law Yes. Law on Personal Data Protection (Закон за заштита на личните податоци) Official Gazette of the Republic of North Macedonia No. 42/2020 (Law on Personal Data Protection (Закон за заштита на личните податоци) Official Gazette of the Republic of North Macedonia No. 42/2020)
Specific exemptions to disclosure Yes. (1) The holders of information may reject the application for access to: 1) information which, based on the law, represents classified information with an adequate degree of classification; 2) personal data the disclosure of which would mean violation of personal data protection; 3) information the disclosure of which would mean violation of the confidentiality of the tax procedure; 4) information acquired or compiled for the purposes of an investigation, a criminal or misdemeanor procedure, for conducting an administrative or civil procedure, and the disclosure of which would have harmful consequences for the course of the procedure; 5) information that endangers the rights arising from industrial or intellectual property (patent, model, sample, trademark and service mark, designation of origin of the product). (Article 6 (1), Law on Free Access to Public Information)
Public Interest test: Specified exemptions to disclosure may be overridden in cases where disclosure of information benefits the public interest. Yes. (3) By way of derogation from paragraph (1) of this Article, the holders of information shall approve access to the information after the compulsorily conducted test of harmfulness which shall establish that, with the disclosure of such information, the consequences for the interest that is being protected are minor as compared to the public interest, defined by law, which would be achieved with the disclosure of such information. (Article 6 (3), Law on Free Access to Public Information)

Appeals

Appeals allowed within public entities No. Absent from legal framework (Absent from legal framework)
Independent, non-judicial appeals mechanism, e.g., information commissioner. Does not include Ombudsman unless appeals decisions are binding. Yes. (1) The applicant shall be entitled to an appeal to the Agency against the decision whereby the holder of the information rejected or denied the request, within 15 days as of the day of receipt of the decision. (Article 27 (1), Law on Free Access to Public Information)
Judicial appeals mechanism Yes. (3) If the Agency fails to adopt a decision upon the applicant’s appeal against the first-instance decision within the deadline referred to in paragraph (2) of this Article, and it also fails to adopt a decision within seven days after the repeated request, the applicant may initiate an administrative dispute. (Article 27 (3), Law on Free Access to Public Information)

Sanctions for non-compliance

Administrative sanctions are specified for violations of disclosure requirements No. Absent from legal framework (Absent from legal framework)
Fines are specified for violations of disclosure requirements Yes. Article 38 A fine in the amount of EUR 500 in MKD equivalent shall be imposed for a misdemeanor on the public official or the person in charge of the holder of information if he/she does not appoint an official for mediation when exercising the right to free access to information and fails to inform the public about such official pursuant to Article 8 paragraphs (1) and (2) of this Law. Article 39 A fine in the amount of EUR 250 in MKD equivalent shall be imposed for a misdemeanor on the official with the holder of information if he/she: - acts in contravention of Article 6 paragraph (3) of this Law, - does not regularly keep and update the list of information held thereby and does not publish it in a manner that is available to the applicant, pursuant to Article 9 of this Law, - does not provide any assistance during the information search pursuant to Article 11 of this Law, - requests an explanation from the applicant for information which is in contravention of Article 16 paragraph (5) of this Law, - unreasonably fails to provide access to the information pursuant to Articles 21 and 22 of this Law within the envisaged deadline of 20 days,that is, 30 days, - does not keep records pursuant to Article 8 paragraph (3) and Article 36 paragraph (2) of this Law, - charges the access to the required information which is in contravention of Article 10 paragraph (3) of this Law, 4 - fails to implement the Agency’s decision within 15 days as of its receipt pursuant to Article 27 paragraph 4 of this Law, - fails to prepare an annual report on the implementation of this Law and fails to submit it to the Agency pursuant to Article 36 of this Law. (Article 39 and 40 Law on Free Access to Public Information)
Criminal sanctions are specified for violations of disclosure requirements No. Absent from legal framework (Absent from legal framework)

Monitoring and Oversight

Information officers must be appointed in public agencies Yes. (1) Every holder of information for mediation shall appoint one or several officials when exercising the right to free access to information. (Article 8 Law on Free Access to Public Information)
Public body that is responsible for applying sanctions Yes. (1) The Misdemeanor Commission in the Agency shall conduct the misdemeanor procedure and issue the misdemeanor sanctions for the misdemeanors defined in this Law. (Article 40 Law on Free Access to Public Information)
Public body that is responsible for public outreach (raising public awareness) Yes. The Agency shall perform the following: - conduct administrative procedures and decide on appeals against the decisions whereby the holder of the information rejected or denied the applicants' requests for access to information, - ensure the implementation of the provisions of this Law, - prepare and publish a list of holders of information, - provide opinions on draft laws that regulate the free access to information, - develop policies and provide guidelines on exercising the right to free access to information, - conduct misdemeanor procedures through the Misdemeanor Commission that decides upon misdemeanors in accordance with the law, - undertake activities for educating the holders of information on the right to free access to information that they hold, - cooperate with the holders of information in the exercise of the right toaccess to information, - prepare an annual report on its operation and submit it to the Assembly of the Republic of Macedonia, - perform activities of international cooperation concerning the fulfillment of international obligations of the Republic of Macedonia, participate in the implementation of projects of international organizations and cooperate with the bodies of other countries and institutions in the sphere of free access to public information, - promote the right to free access to public information, and - perform other tasks stipulated in this and other law. (Article 30 Law on Free Access to Public Information)
Nodal agency for RTI (implementation support/compliance within public sector). Does not include Ombudsman. Yes. The Agency shall perform the following: - conduct administrative procedures and decide on appeals against the decisions whereby the holder of the information rejected or denied the applicants' requests for access to information, - ensure the implementation of the provisions of this Law, - prepare and publish a list of holders of information, - provide opinions on draft laws that regulate the free access to information, - develop policies and provide guidelines on exercising the right to free access to information, - conduct misdemeanor procedures through the Misdemeanor Commission that decides upon misdemeanors in accordance with the law, - undertake activities for educating the holders of information on the right to free access to information that they hold, - cooperate with the holders of information in the exercise of the right toaccess to information, - prepare an annual report on its operation and submit it to the Assembly of the Republic of Macedonia, - perform activities of international cooperation concerning the fulfillment of international obligations of the Republic of Macedonia, participate in the implementation of projects of international organizations and cooperate with the bodies of other countries and institutions in the sphere of free access to public information, - promote the right to free access to public information, and - perform other tasks stipulated in this and other law. (Article 30 Law on Free Access to Public Information)
Ombudsman involvement in implementation is specified by law No. Absent from legal framework (Absent from legal framework)
Reporting of data and/or implementation is required Yes. (1) The official person of the holder of information shall be obliged to prepare an annual report on the implementation of this Law and submit it to the Agency by 31st January in the current year for the previous year and post it on the website of the holder of public information. (Article 36 Law on Free Access to Public Information)

Legislation

*Last update: 2017


Public Procurement


Quantitative Data

Primary Metric

201220152016201720202024Trend
Scope99
Information availability94
Evaluation81
Open competition75
Institutional arrangements36

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness


Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Scope

Threshold - lowest PP

What is the minimum contract value above which the public procurement law is applied? (Product type GOODS) EUR 1,000. Below EUR 1,000: small-value procurement (simplified direct procedure); EUR 1,000 to simplified open procedure threshold: simplified open procedure; above simplified open procedure threshold: full open/restricted/negotiated procedures; above EU-equivalent upper threshold (~EUR 135,000 classical sector): full procedures with international publication options through ESPP. (PPL 2019, Art. 40; sub-legal acts)
What is the minimum contract value above which the public procurement law is applied? (Product type WORKS) EUR 5,000. Below EUR 5,000: small-value procurement; EUR 5,000 to simplified open threshold: simplified open procedure; above simplified open threshold: full procedures; above EU-equivalent works upper threshold (~EUR 5,350,000): full procedures with international publication options. (PPL 2019, Art. 40; sub-legal acts)
What is the minimum contract value above which the public procurement law is applied? (Product type SERVICES) EUR 1,000. Below EUR 1,000: small-value procurement for services; EUR 1,000–simplified open threshold: simplified open procedure; specific/social services follow a light-touch regime above EUR 10,000; above the upper EU-equivalent threshold: full procedures. (PPL 2019, Art. 40; sub-legal acts)

Threshold - by PP type

What are the minimum application thresholds for the procurement type? (Entity: PUBLIC SECTOR) EUR 1,000. Classical sector contracting authorities: below lower thresholds – small-value procedure; above EU-equivalent upper thresholds – full procedures with international publication options through ESPP. (PPL 2019, Art. 40(1)(a))
What are the minimum application thresholds for the procurement type? (Entity: UTILITIES) EUR 1,000. Sectoral contracting authorities in water, energy, transport and postal services follow higher upper thresholds aligned with Directive 2014/25/EU; the PPL 2019 specifically provides for these differences at Art. 40(1)(b). (PPL 2019, Art. 40(1)(b))
What are the minimum application thresholds for the procurement type? (Entity: DEFENCE) EUR 1,000. North Macedonia has not transposed Directive 2009/81/EC on defence and security procurement; defence-related contracts may benefit from exemptions under Arts. 22–26 of the PPL 2019; the EC 2024 Report does not specifically flag this gap but the absence of a transposing law is a standard WB region issue. (PPL 2019, Arts. 22–26 and 40)

Threshold - by product type

What are the minimum application thresholds for the procurement type? (Product type GOODS) EUR 1,000. Below EUR 1,000: small-value procurement; EUR 1,000 to simplified open threshold: simplified open procedure; above simplified open threshold and below upper threshold: full open procedure; above EU-equivalent upper threshold: full procedures with broader international publication options. (PPL 2019, Art. 40)
What are the minimum application thresholds for the procurement type? (Product type WORKS) EUR 5,000. Below EUR 5,000: small-value procurement; EUR 5,000–simplified open threshold: simplified open; above simplified open threshold and below upper threshold: full open procedure; above EU-equivalent upper threshold: full procedures. (PPL 2019, Art. 40)
What are the minimum application thresholds for the procurement type? (Product type SERVICES) EUR 1,000. Same structure as goods for standard services; specific/social services follow a light-touch regime with a EUR 10,000 lower threshold; above the EU-equivalent upper threshold (~EUR 750,000 for specific services): full light-touch regime procedures. (PPL 2019, Art. 40)

Information availability

Publishing and record keeping

Is there a requirement that tender documents must published in full? Yes. All tender documentation must be published and accessible on the ESPP from the date of notice publication; access is free and unrestricted; the PPL 2019 requires full electronic availability of tender documents; failure to publish is a misdemeanour under Art. 181. (PPL 2019, Arts. 41 and 63; Rulebook on the Manner of Using the ESPP (OG No. 64/2019))
Are any of these documents published online at a central place? Yes. ESPP (Electronic System for Public Procurements): https://e-nabavki.gov.mk/PublicAccess/Home.aspx (three-language portal: Macedonian, English, Albanian); Open Data section: https://e-nabavki.gov.mk/opendata-announcements.aspx; national open data portal: data.gov.mk; PPB website: www.bjn.gov.mk; ESPP is the mandatory single publication platform for all procurement procedures. (PPL 2019, Art. 31 and 41; Rulebook on ESPP (OG No. 64/2019))
Is it mandatory to keep all of these records? -Public notices of bidding opportunities, -Bidding documents and addenda, -Bid opening records, -Bid evaluation reports, -Formal appeals by bidders and outcomes, -Final signed contract documents and addenda and amendments, -Claims and dispute resolutions, -Final payments, -Disbursement data (as required by the country’s financial management system) Yes. Contracting authorities must maintain complete procurement files; the PPL 2019 and sub-legal acts define retention obligations; the Law on Free Access to Information (OG No. 101/2019) additionally requires that "the entire documentation for public procurements, for concessions and for public-private partnership agreements" be published on the authority's website (Art. 10(1)(18)), going beyond most comparators in Western Balkans; compliance monitoring is carried out by the PPB. (PPL 2019; Law on Free Access to Information OG No. 101/2019, Art. 10(1)(18))
Are contracts awarded within a framework agreement published (ie mini contracts)? Yes. Call-off contracts under framework agreements are published on the ESPP as assigned contracts and can be exported to CSV via the ESPP open data section; however, individual mini-contract data is not always complete or consistently structured; the ESPP open data section shows aggregate contract data by contracting authority and economic operator including framework call-offs. (PPL 2019, Arts. 91–96; ESPP open data section)

Sub-contracting

Is it mandatory to publish information on subcontractors (ie names) in some cases? Yes. The PPL 2019 requires tenderers to declare subcontractors in their tender; contracting authorities must verify that declared subcontractors meet the applicable qualification criteria; subcontractor information is documented in the procurement file and published through the ESPP as part of contract documentation; however, there is no dedicated separate public register of subcontractors. (PPL 2019, Arts. 108–111)
If yes, what is the threshold for publication (i.e. the % of total contract value subcontracted)? For example, if the threshold is 75%, and you have subcontracted out only 40% of your contract, no disclosure is required. Consultant will insert 75% in the short answer column. 0%. All known subcontractors must be declared regardless of the proportion subcontracted; no percentage threshold triggers or exempts the disclosure obligation. (PPL 2019, Arts. 108–111)

Evaluation

Preferential treatment

Is there a ban on mentioning specific companies or brands in tender specification/call for tender? Yes. Technical specifications may not refer to a specific manufacturer, origin, process, trademark, patent, type, or place of production in a way that would favour or eliminate certain operators or products; such references are allowed only if justified by the subject of the contract and must include "or equivalent"; aligned with Art. 42 of Directive 2014/24/EU. (PPL 2019, Arts. 58–62)
Is there a preferential treatment for small-to-medium enterprises (SMEs)? No. No explicit preferential treatment for SMEs exists in the PPL 2019; the principles of equal treatment and non-discrimination apply; however, lot division provisions allow contracting authorities to divide contracts into lots, facilitating SME access; in 2023, SMEs (small and medium combined) won 21,784 out of 34,238 contracts (63.6% by number, 53.5% by value) demonstrating de facto participation without preferential treatment. (PPL 2019, Art. 4; ESPP open data 2023)
Is there a preferential treatment for local/national companies? (companies from other EU MS are considered foreign companies) No. Principles of equal treatment, non-discrimination and open competition apply; foreign economic operators receive equal treatment; since 30 October 2023 GPA accession, North Macedonia must additionally extend non-discriminatory treatment to GPA-party country suppliers in covered procurement. (PPL 2019, Art. 4; WTO GPA accession 30 October 2023)
Is there a specific set of rules for green/sustainable procurement? No. The PPL 2019 permits inclusion of environmental criteria in technical specifications and award criteria but does not mandate green procurement; the EC 2024 Report and civil society note that green public procurement (GPP) is not systematically implemented; no standalone GPP strategy has been adopted (unlike Albania); GPP and MEAT adoption are both targets identified in EC recommendations. (PPL 2019, Arts. 58–62 and 99–107; EC 2024 Report)

Bid evaluation

Are there restrictions on allowable grounds for tenderer exclusion? Yes. PPL 2019 establishes mandatory exclusion grounds: final criminal conviction for organised crime, corruption, fraud, terrorist financing, child labour, human trafficking; non-payment of taxes and social contributions; bankruptcy/insolvency/liquidation; false declarations; PPL 2019 also includes discretionary exclusion grounds: grave professional misconduct; anti-competitive agreements; conflict of interest; significant deficiencies in prior contract performance; these grounds are aligned with EU Directive 2014/24/EU Art. 57. (PPL 2019, Arts. 112–117)
Are some bids automatically excluded? e.g., lowest/highest price; unusually low price, etc. No. For abnormally low tenders, the contracting authority must request written clarification from the tenderer before any exclusion; exclusion is not automatic; the contracting authority may reject the tender only after assessing the justification provided; this is aligned with EU Directive 2014/24/EU Art. 69. (PPL 2019, Art. 106)
Is scoring criteria published? Yes. Contracting authorities must publish award criteria and their relative weights in the tender documents from the date of notice publication; the PPL 2019 establishes MEAT (most economically advantageous tender) as the mandatory award criterion – this is one of the most significant reforms vs. PPL 2007, which allowed lowest price as the default; MEAT may be determined on the basis of price, cost-effectiveness (life-cycle costing) or best price-quality ratio; in practice, however, lowest price still dominates (used in 95% of procedures in H1 2023); EC 2024 Report recommends increasing use of MEAT. (PPL 2019, Art. 99; EC 2024 Report)
Are decisions always made by a committee? Yes. An Evaluation Commission (Комисија за евалуација) must be established for each procurement procedure; the commission must consist of an odd number of members (minimum 3) with professional expertise relevant to the subject of the contract; external experts may be co-opted; the commission issues a written, reasoned decision. (PPL 2019, Arts. 80–85)
Are there regulations on evaluation committee composition to prevent conflict of interest? Yes. PPL 2019 includes explicit conflict-of-interest provisions for evaluation commission members; members must declare any conflict of interest and recuse themselves; contracting authorities must implement measures to prevent, detect and eliminate conflicts of interest; the State Commission for Prevention of Corruption (DKSK) monitors conflict-of-interest compliance in procurement and published a dedicated Mapping Report (October 2024) on corruption generators in public procurement. (PPL 2019, Arts. 21 and 80–85; DKSK Report October 2024)
Is some part of evaluation committee mandatorily independent of contracting authority? No. There is no legal requirement for evaluation committee members to be independent of the contracting authority; members are generally officials of the contracting authority; external experts may be engaged where required but this is not mandatory. (PPL 2019, Arts. 80–85)
Are scoring results publicly available? Yes. Award decisions and the reasoning for contract awards are published on the ESPP; contracting authorities must notify all tenderers of the award decision and its reasons; the ESPP open data section provides aggregate award data downloadable in CSV format (including by economic operator and contracting authority); all assigned contracts are visible on the ESPP; however, the EC 2024 Report notes that insufficient justification of decisions remains a persistent challenge in practice. (PPL 2019, Arts. 99–107; ESPP open data section)
Does the law specify under which conditions the tender can be cancelled? Yes. A contracting authority may cancel a procedure if: no tender was submitted; no tender is acceptable; circumstances have fundamentally changed after the procedure was initiated; a fundamental error occurred in the preparation of tender documents; there are overriding public interest reasons; the cancellation notice must be published on the ESPP and reasons communicated to all tenderers. (PPL 2019, Art. 98)

Open competition

CFT publication

Does the law specify the location for publicizing open calls for tenders? Yes. ESPP: https://e-nabavki.gov.mk/PublicAccess/Home.aspx; Official Gazette of the Republic of North Macedonia (for above-threshold procedures); all open procedure notices are published on the ESPP as the mandatory single platform; publication on the ESPP is the exclusive channel; failure to publish is a misdemeanour (Art. 181 PPL 2019). (PPL 2019, Art. 41; Rulebook on ESPP (OG No. 64/2019))
Does the law specify the location for publicizing restricted calls for tenders? Yes. ESPP: https://e-nabavki.gov.mk; same requirements as for open procedures; the restricted procedure is published on the ESPP. (PPL 2019, Art. 41; Rulebook on ESPP)
Does the law specify the location for publicizing negotiated calls for tenders? Yes. ESPP: https://e-nabavki.gov.mk; negotiated procedures with prior publication are published on the ESPP; negotiated procedures without prior publication are reported on ESPP after contract award; the EC 2024 Report flags that non-transparent negotiated procedures continue to be used more than warranted (approximately EUR 11 million of contracts via non-transparent negotiation in H1 2023). (PPL 2019, Art. 41; Rulebook on ESPP)

Minimum # of bidders

What is the minimum number of bidders for restricted procedures? 5. For restricted procedures above the upper EU-equivalent threshold: minimum 5 candidates invited; for restricted procedures below the upper threshold: minimum 3 candidates; aligned with Directive 2014/24/EU Art. 65. (PPL 2019, Art. 46)
What is the minimum number of bidders for negotiated procedures? 3. The minimum number of candidates for the competitive procedure with negotiation (with prior publication) is 3. (PPL 2019, Arts. 48–50)
What is the minimum number of bidders for competitive dialogue procedures? 3. The minimum number of participants in competitive dialogue is 3, aligned with Directive 2014/24/EU. (PPL 2019, Art. 51)

Bidding period length

What are the minimum number of days for open procedures? 35. For open procedures above the upper EU-equivalent threshold: minimum 35 days from notice publication to tender deadline; for simplified open procedures (below upper threshold): minimum 15 days; for urgent cases: reduced time limits per PPL provisions; for small-value procedures: minimum time limits per sub-legal acts. (PPL 2019, Arts. 63–68)
What are the minimum number of days for restricted procedures? 30. Minimum 30 days from notice publication for submission of requests to participate; minimum 30 days from invitation to tender for submission of offers (above upper threshold); reduced time limits for urgent cases. (PPL 2019, Arts. 69–71)
What are the minimum number of days for competitive negotiated procedures? 30. Minimum 30 days for the candidacy stage; time limits for subsequent negotiation rounds set by the contracting authority proportionate to the complexity of the contract. (PPL 2019, Arts. 72–74)

Institutional arrangements

Institutions and regulations

Does the law specify the main EXCEPTIONS preventing the application of the public procurement law for tenders/organisations? Yes. The PPL 2019 does not apply (Arts. 22–26) to: (1) contracts covered by specific international procedure rules required by international organisations or international financing institutions; (2) procurement procedures governed by specific international treaties concluded for the stationing of troops; (3) contracts for intelligence activities or classified contracts required for essential state security interests; (4) acquisition of weapons, munitions and war material to the extent required for essential security interests; (5) R&D services where the contracting authority does not exclusively benefit from the results; (6) certain audio-visual and broadcasting services; (7) arbitration and conciliation services; (8) employment contracts; (9) certain civil protection and civil defence services; (10) financial services related to issue, purchase, sale and transfer of securities; (11) contracts for public passenger transport by rail or metro where concluded as public service concessions; concessions and PPP contracts are governed by separate legislation. (PPL 2019, Arts. 22–26)
Does the law specify the main types of institutions that must apply the public procurement law? Yes. The PPL 2019 (Art. 9) applies to: (a) state administration bodies (ministries, agencies, inspectorates, regulatory bodies); (b) local self-government units (82 municipalities + City of Skopje); (c) public enterprises; (d) legal persons established for purposes of general interest (not of an industrial or commercial character) financed/controlled by contracting authorities; (e) sectoral contracting authorities conducting activities in water, energy, transport and postal services; the PPB maintains a registry of contracting authorities. (PPL 2019, Art. 9)
Does the law specify the main procedure types or procurement methods permitted? Yes. Small-value procurement; Simplified open procedure; Open procedure; Restricted procedure; Competitive procedure with negotiation (with prior publication); Negotiated procedure without prior publication; Competitive dialogue; Innovation partnership; Design contest; Innovation partnership is included in PPL 2019 for the first time; the EC 2024 Report recommends increased use of MEAT and more open procedures. (PPL 2019, Arts. 41–55)
Is there a procurement arbitration court dedicated to public procurement cases? Yes. The State Appeals Commission (SAC / Државна комисија за жалби по јавни набавки – DKZJN) is an independent state body appointed by the National Parliament; it serves as the first-instance administrative review body for complaints against procurement procedures and award decisions; complaints may be filed electronically via the ESPP (introduced by PPL 2019); the SAC may issue interim measures (also a PPL 2019 innovation); SAC decisions are subject to judicial review before the Administrative Court; in addition, if the Administrative Court annuls a SAC decision, the Administrative Court itself must decide the case (to accelerate the review process – introduced by PPL 2019). (PPL 2019, Arts. 132–168; Karanovic & Partners analysis 2019)
Is there a procurement regulatory body dedicated to public procurement? Yes. The Public Procurement Bureau (PPB / Биро за јавни набавки – BJN) is a state administration body within the Ministry of Finance with legal entity status; it develops and maintains the regulatory framework, issues sub-legal acts, manages/upgrades the ESPP, publishes standard model tender documents, annual reports and training programmes; the PPB has a sector for control and supervision with only 8 employees as of mid-2023 – critically understaffed (documented by civil society and EC); the EC 2024 Report identifies low PPB institutional capacity as a key remaining challenge. (PPL 2019, Arts. 9–20; civil society monitoring reports 2023)
Does the law specify procurement advisors' profession (i.e. degree to be obtained, official list of members of the professional association) and its role in the tendering process (e.g. right to draft tender documentations, conduct market research identifying bidders)? No. The PPL 2019 does not establish a regulated profession of procurement adviser (no mandatory certification, no official register of procurement professionals); qualification of evaluation commission members is defined generically as professional expertise relevant to the subject of the contract; the EC 2024 Report recommends capacity building for contracting authorities and economic operators through continuous training. (PPL 2019, Arts. 80–85; EC 2024 Report)
Is disclosure of final, beneficial owners required for placing a bid? No. The PPL 2019 does not currently require beneficial ownership disclosure as a precondition for bidding; however, the OGP Action Plan 2024–Dec. 2024 includes a commitment to publish the names of beneficial owners of companies participating in public tenders and companies awarded procurement contracts through the ESPP, linking the Central Register of North Macedonia (CRRNM) with the ESPP; this commitment is classified as having "substantial potential for results" by the OGP Independent Reporting Mechanism (IRM). (PPL 2019; OGP Action Plan 2024–Dec. 2024; OGP IRM Review 2024)

Complaints

Is there a fee for arbitration procedure? Yes. The PPL 2019 establishes review fees payable to the SAC on a graduated scale (approximate values in EUR equivalent): (a) EUR 300–500 for contracts up to EUR 15,000; (b) EUR 1,000–1,500 for contracts EUR 15,001–130,000; (c) EUR 2,000–2,500 for contracts EUR 130,001–1,000,000; (d) EUR 4,000 for contracts above EUR 1,000,000; fees are refundable if the complaint is upheld; the exact fees are set by sub-legal act and denominated in MKD (with EUR equivalents). (PPL 2019, Arts. 147–150; sub-legal acts)
Is there a ban on contract signature until arbitration court decision (first instance court)? Yes. When a complaint is filed with the SAC, the contracting authority must automatically suspend continuation of the procurement procedure and may not sign the contract until the SAC issues its decision; the suspension is automatic from the date of SAC receipt of the complaint; the SAC may also issue interim measures (PPL 2019 innovation) to prevent or preserve specific procedural acts. (PPL 2019, Arts. 140–146; Karanovic & Partners 2019)
What is the maximum number of days until arbitration court decision from filing a complaint in the case of awarded contracts? 15. The SAC must issue its decision within 15 working days of receipt of the complaint and all required documentation; for complex cases, the deadline may be extended by an additional 5 working days; the total maximum time limit is therefore 20 working days; the Administrative Court must then decide within 30 days if the SAC decision is challenged. (PPL 2019, Arts. 155–160)
Is there a requirement to publicly release arbitration court decisions ? Yes. The SAC is required to publish all its decisions; SAC decisions are accessible on the SAC website; decisions may also be accessed through the ESPP complaint system introduced by PPL 2019; bidders are informed of complaints filed against their procedures through the ESPP notification system; the State Commission for Prevention of Corruption (DKSK) also publishes findings related to corruption in procurement, including its October 2024 mapping report on corruption generators. (PPL 2019, Arts. 155–168; DKSK Report October 2024)

Legislation

Law on Free Access to Public Information (English)pdf
Public Procurement Lawmissing file:
Rulebook on the Manner of Using the Electronic System for Public Procurementmissing file:

*Last update: 2017


Anti Money Laundering


Quantitative Data

Primary Metric

201220152016201720202024Trend
Risk-based approach100
Sanctions for natural persons100
Sanctions for legal persons100
Pecuniary sanctions for obliged entities80
Beneficial ownership of legal persons and legal arrangements76
Supervision of obliged entities100
Financial Intelligence Units (FIUs)83
Mutual legal assistance (MLA) and International Cooperation100

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness


Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Country score

Risk-based approach

Each Member State shall be legally required to prepare a national risk assessment that outlines appropriate steps to identify, assess, understand and mitigate the risks of money laundering and terrorist financing affecting it. Yes. (1) The Republic of North Macedonia shall conduct a national risk assessment of money laundering, financing of terrorism, financing the proliferation of weapons of mass destruction and other related risks, for the purpose of identifying, assessing, understanding and reducing the risk related to money laundering and financing of terrorism and shall update it every four years at the least. (Article 3, (1)., AML Law 2022)
Member states shall be legally required to keep the national risk assessment up to date and review it at least every 4 years. Yes. (1) The Republic of North Macedonia shall conduct a national risk assessment of money laundering, financing of terrorism, financing the proliferation of weapons of mass destruction and other related risks, for the purpose of identifying, assessing, understanding and reducing the risk related to money laundering and financing of terrorism and shall update it every four years at the least. (Article 3, (1)., AML Law 2022)
Member states should legally designate an authority or mechanism to co-ordinate actions to assess risks. Yes. 2) The Council for Combating Money Laundering and Financing of Terrorism referred to in Article 125 of this Law shall be responsible for coordination of the activities for conducting the national risk assessment in the Republic of North Macedonia and preparation of a report on national risk assessment of money laundering and financing of terrorism. (3) The Council for Combating Money Laundering and Financing of Terrorism referred to in this Law shall submit the report on the national risk assessment of money laundering and financing of terrorism to the Government of the Republic of Macedonia for adoption. (4) The report on the national risk assessment as well as all amendment and supplements to the report shall be published on the internet site of the Office. The published report does not contain confidential data in accordance with the Law. (Article 3, (2), (3), (4), AML Law 2022)

Sanctions for natural persons

The following conduct, when committed intentionally, is punishable as a criminal offence: the conversion or transfer of property, knowing that such property is derived from criminal activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person’s action; Yes. (1) A person who shall release in circulation, receive, take over, exchange or break into small change larger amount of money or another property which they acquired through criminal activity, or conversion, modification, transfer or, who shall cover up the criminal source of money, location, movement or ownership, shall be punished with imprisonment of one to ten years. (2) The punishment from paragraph 1 shall also apply for a person who shall own or use property or objects acquired through crime or counterfeiting of documents, failing to report facts or in another manner covering the source of it, or in some other manner covers up such origin, or shall cover up their location, movement or ownership. (3) If the crime from paragraphs 1 and 2 is committed in banking activity, financial work or other economic work, or if the transaction has been divided in order to avoid the legal obligation to report, the perpetrator shall be punished with imprisonment of at least three years. (Article 273, (1) - (3) Criminal Code)
The following conduct, when committed intentionally, is punishable as a criminal offence: the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity; Yes. (1) A person who shall release in circulation, receive, take over, exchange or break into small change larger amount of money or another property which they acquired through criminal activity, or conversion, modification, transfer or, who shall cover up the criminal source of money, location, movement or ownership, shall be punished with imprisonment of one to ten years. (2) The punishment from paragraph 1 shall also apply for a person who shall own or use property or objects acquired through crime or counterfeiting of documents, failing to report facts or in another manner covering the source of it, or in some other manner covers up such origin, or shall cover up their location, movement or ownership. (3) If the crime from paragraphs 1 and 2 is committed in banking activity, financial work or other economic work, or if the transaction has been divided in order to avoid the legal obligation to report, the perpetrator shall be punished with imprisonment of at least three years. (Article 273, (1) - (3) Criminal Code)
The following conduct, when committed intentionally, is punishable as a criminal offence: the acquisition, possession or use of property, knowing at the time of receipt, that such property was derived from criminal activity. Yes. (1) A person who shall release in circulation, receive, take over, exchange or break into small change larger amount of money or another property which they acquired through criminal activity, or conversion, modification, transfer or, who shall cover up the criminal source of money, location, movement or ownership, shall be punished with imprisonment of one to ten years. (2) The punishment from paragraph 1 shall also apply for a person who shall own or use property or objects acquired through crime or counterfeiting of documents, failing to report facts or in another manner covering the source of it, or in some other manner covers up such origin, or shall cover up their location, movement or ownership. (3) If the crime from paragraphs 1 and 2 is committed in banking activity, financial work or other economic work, or if the transaction has been divided in order to avoid the legal obligation to report, the perpetrator shall be punished with imprisonment of at least three years. (Article 273, (1) - (3) Criminal Code)
Aiding and abetting, inciting and attempting a money laundering offence is punishable as a criminal offence. Yes. Article 19 (1) A person that intentionally starts the perpetration of a crime, but who does not complete it, shall be punished for an attempted crime for which according to the law a sentence could be pronounced of five years of imprisonment or a more severe punishment, and for the attempt of some other crime only when the law explicitly prescribes the punishment of an attempt. (2) The perpetrator shall be punished for an attempt within the limits of the punishment prescribed for the crime, and he may be punished more leniently.//// Article 22 If two or more persons, by participation in an act of perpetration or with any other particular contribution to the commission of a crime, commit jointly a crime, each one of them shall be punished with the punishment that is prescribed for that crime. Instigation Article 23 (1) A person that instigates, with intent, another to committing a crime, shall be punished as if he had perpetrated the crime himself. (2) A person that instigates, with intent, another to commit a crime, for which a sentence of five years of imprisonment or a more severe sentence could be pronounced, and there is not even an attempt of this crime, shall be punished as for an attempted crime. (Article 19, 22, 23 Criminal Code)
Money laundering offences are punishable by a maximum term of imprisonment of at least four years. Yes. (1) A person who shall release in circulation, receive, take over, exchange or break into small change larger amount of money or another property which they acquired through criminal activity, or conversion, modification, transfer or, who shall cover up the criminal source of money, location, movement or ownership, shall be punished with imprisonment of one to ten years. (2) The punishment from paragraph 1 shall also apply for a person who shall own or use property or objects acquired through crime or counterfeiting of documents, failing to report facts or in another manner covering the source of it, or in some other manner covers up such origin, or shall cover up their location, movement or ownership. (3) If the crime from paragraphs 1 and 2 is committed in banking activity, financial work or other economic work, or if the transaction has been divided in order to avoid the legal obligation to report, the perpetrator shall be punished with imprisonment of at least three years. (Article 273, (1) - (3) Criminal Code)
A prior or simultaneous conviction for the criminal activity from which the property was derived is not a prerequisite for a conviction for money laundering offences Yes. (10) If there are actual or legal hindrances to determine the previous punishable criminal act and prosecution of its perpetrator, the existence of such act shall be determined based on the actual circumstances of the case and existence of a founded suspicion that the property has been acquired with such act. (11) The knowledge of the perpetrator, i.e. their duty and opportunity to know that the property has been acquired with a punishable act may be determined based on the objective actual circumstances of the case. (Article 273, (10) (11) Criminal Code)
A conviction for money laundering offences is possible where it is established that the property was derived from a criminal activity, without it being necessary to establish all the factual elements or all circumstances relating to that criminal activity, including the identity of the perpetrator; Yes. (1) A person who shall release in circulation, receive, take over, exchange or break into small change larger amount of money or another property which they acquired through criminal activity, or conversion, modification, transfer or, who shall cover up the criminal source of money, location, movement or ownership, shall be punished with imprisonment of one to ten years. (2) The punishment from paragraph 1 shall also apply for a person who shall own or use property or objects acquired through crime or counterfeiting of documents, failing to report facts or in another manner covering the source of it, or in some other manner covers up such origin, or shall cover up their location, movement or ownership. (3) If the crime from paragraphs 1 and 2 is committed in banking activity, financial work or other economic work, or if the transaction has been divided in order to avoid the legal obligation to report, the perpetrator shall be punished with imprisonment of at least three years.

Sanctions for legal persons

Legal persons can be held liable for the breaches of Regulation (EU) 2024/1624 or Regulation (EU) 2023/1113 committed on their behalf or for their benefit by any person, acting individually or as part of a body of that legal person and having a leading position within that legal person, based on any of the following: a power to represent the legal person; an authority to take decisions on behalf of the legal person; an authority to exercise control within the legal person. Yes. (1) In the cases determined by law, the legal entity shall be held liable for the criminal act committed by the legal entity, within the legal entity in behalf of, on the account of or for the benefit of the legal entity. (Article 28-a (1), Criminal Code)
Legal persons can be held liable where the lack of supervision or control has made possible the commission of any money laundering offences for the benefit of that legal person by a person under its authority. Yes. (2) The legal entity shall be held liable for the criminal act, resulting in significant property benefit or in significant damages caused to another person, committed by its employee or representative of the legal entity if: 1) the execution of a conclusion, order or another decision or approval of an administrative body, management body or a supervisory body represents committing a criminal act or 2) the criminal act was provoked by lack of mandatory supervision by the administrative body, the management body or the supervisory body or 3) the administrative body, the management body or the supervisory body has not prevented the criminal act or covered it or failed to report it before the initiation of a criminal procedure against the perpetrator. (Article 28-a (2), Criminal Code)
Legal persons held liable are punishable by criminal or non-criminal fines. Yes. (12) If the criminal act from paragraph (1) is perpetrated by a legal entity they shall be punished with a fine. (Article 273 (12), Criminal Code)
Legal persons held liable are punishable by other sanctions, such as: exclusion from entitlement to public benefits or aid; temporary or permanent exclusion from access to public funding, including tender procedures, grants and concessions; temporary or permanent disqualification from the practice of commercial activities; placing under judicial supervision; a judicial winding-up order; temporary or permanent closure of establishments which have been used for committing the offence. Yes. (1) Court may decide to prohibit exercise of certain profession or individual business activity, of duties or affairs related to disposing, using, managing or handling or keeping property to a perpetrator punished to a sentence of imprisonment or to a conditionally sentenced one, if the perpetrator has abused his/her profession, business or duties for the purpose of committing the crime and if the nature of the crime committed and the circumstances under which it has been committed, raise a suspicion that the perpetrator would abuse their position to commit another crime. (Article 38-b, Criminal Code)

Pecuniary sanctions for obliged entities

In the event of a breach of Regulations (EU) 2024/1624 and (EU) 2023/1113, where obligations apply to legal persons, pecuniary sanctions can be imposed and administrative measures can be applied not only to the legal person, but also to the senior management and to other natural persons who under national law are responsible for the breach. Yes. Chapter VIII (Chapter VIII, Criminal Code)
Pecuniary sanctions shall be imposed on obliged entities for serious, repeated or systematic breaches, whether committed intentionally or negligently, of the requirements laid down in the following provisions of Regulation (EU) 2024/1624: Chapter II (Internal policies, procedures and controls of obliged entities); Chapter III (Customer due diligence); Chapter V (Reporting obligations); Article 77 (Record retention). Yes. Chapter VIII (Chapter VIII, Criminal Code)
Supervisors are able to apply administrative measures to an obliged entity, where they identify: breaches of Regulation (EU) 2024/1624 or Regulation (EU) 2023/1113, either in combination with pecuniary sanctions for serious, repeated and systematic breaches, or on their own; weaknesses in the internal policies, procedures and controls of the obliged entity that are likely to result in breaches of the requirements; that the obliged entity has internal policies, procedures and controls that are not commensurate with the risks of money laundering, its predicate offences or terrorist financing to which the entity is exposed. Yes. 1) The financial intelligence officers performing supervision in accordance with the provisions of this Law shall initiate a procedure for corrective measures in case of identified irregularities in the operation of the entity that do not have features and elements of misdemeanors described in this Law, but are inadequate or incomplete implementation of measures and actions to prevent money laundering and/or finacing of terrorism that may affect the entity's exposure to the risk of money laundering and finacing of terrorism. (2) In the cases referred to in paragraph (1) of this Article, the financial intelligence officers performing supervision may issue a report to the entity with a recommendation(s) for elimination of the identified deficiencies with deadlines for action. (3) Within ten days from the expiration of the deadlines referred to in paragraph (2) of this Article, the entity shall be obliged to submit to the Office a report on the undertaken activities and documented evidence that it has acted in accordance with the measures referred to in paragraph (2) of this Articl (Article 165, AML Law)
Where obliged entities fail to comply with administrative measures applied by the supervisor within the applicable deadlines, supervisors are able to impose periodic penalty payments in order to compel compliance with those administrative measures. No. Absent from legal framework (Absent from legal framework)
Supervisors are required to publish on their website, in an accessible format, decisions imposing pecuniary sanctions, applying administrative measures or imposing periodic penalty payments. Yes. (1) In order to prevent and discourage the activities which are considered misdemeanors in accordance with this Law, the supervisory bodies referred to in this Law shall make public the information on the pronounced misemeanour sanctions on the basis of an effective judgment, unless the publication of the information may impede the conduct of the pre-investigation or criminal procedure. (2) The information referred to in paragraph (1) of this Article shall contain data on: - the misdemeanant, that is: the name and head office of the legal entity, name and surname of the responsible person in the legal entity, name and surname of the natural person, the person who exercises public powers and the authorized officer, - the misdemeanor: description of the action that constitutes a misdemeanor, and - the misdemeanor imposed. (3) The information referred to in paragraph (2) of this Article shall be published on the Internet site of the Office and it shall be available during a period of three years as of the day ofpublication. (Article 175, AML Law)

Beneficial ownership of legal persons and legal arrangements

Beneficial ownership information must be held in a central register in the Member State where the legal entity is created or where the trustee of an express trust or person holding an equivalent position in a similar legal arrangement is established or resides, or from where the legal arrangement is administered. Yes. (1) A register of beneficial owners (hereinafter: a register) shall be established for the purpose of ensuring transparency of the ownership structure of the legal entities, containing information and data on the beneficial owners in accordance with this Law. (2) The Central Register of the Republic of Macedonia (hereinafter: register’s administrator) shall establish, keep, maintain and manage the register in electronic form. (Article 29, AML Law 2022)
Member States shall ensure that the entities in charge of the central registers are empowered to request from legal entities, trustees of any express trust and persons holding an equivalent position in a similar legal arrangement, and their legal and beneficial owners, any information necessary to identify and verify their beneficial owners, including resolutions of the board of directors and minutes of their meetings, partnership agreements, trust deeds, power of attorney or other contractual agreements and documentation. No. Absent from legal framework (Absent from legal framework)
Where no person is identified as the beneficial owner, the central register shall include: (a) a statement that there is no beneficial owner or that the beneficial owners could not be determined, accompanied by a corresponding justification (b) the details of all natural persons who hold the position of senior managing officials in the legal entity equivalent to the following information: all names and surnames, place and full date of birth, residential address, country of residence and nationality or nationalities of the beneficial owner, number of identity document, such as passport or national identity document, and, where it exists, unique personal identification number assigned to the person by his or her country of usual residence, and general description of the source of such number Yes. (4) If a natural person(s) cannot be determined as a beneficial owner(s) by the application of paragraph (1) item 1) of this Article or the entity is not sure that the natural person(s) identified in accordance with paragraph (1) item 1) of this Article is(are) the beneficial owner(s), in that case the person(s) identified by applying paragraph (1) item (2) of this Article shall be considred beneficial owner(s). (Article 20, AML Law 2022)
Entities in charge of the central registers are required to verify, within a reasonable time upon submission of the beneficial ownership information, and on a regular basis thereafter, that such information is adequate, accurate and up to date. No. Absent from legal framework (Absent from legal framework)
Competent authorities, if appropriate and to the extent that such requirement does not interfere unnecessarily with their functions, are required to report to the entities in charge of the central registers any discrepancies they find between information available in the central registers and the information available to them. No. Absent from legal framework (Absent from legal framework)
The information contained in the central registers must include any change to the beneficial ownership of legal entities and legal arrangements and to nominee arrangements, following their first recording in the central register. Yes. (5) The register’s administrator shall keep and manage the register in the manner that: - in addition to the last status of the data on the beneficial owners, all previous entries, changes in the data and deletions according to the time and type of occurrence are also kept and - the data in the register are available ten years after the deletion of the legal entity from the competent register (Article 31, AML Law 2022)
The entity in charge of the central register is empowered, whether directly or by application to another authority, including judicial authorities, to carry out checks, including on-site inspections at the business premises or registered office of legal entities, in order to establish the current beneficial ownership of the entity and to verify that the information submitted to the central register is accurate, adequate and up-to-date. No. Absent from legal framework (Absent from legal framework)
Where verification leads an entity in charge of a central register to conclude that there are inconsistencies or errors in the beneficial ownership information, the entity in charge of a central register is able to withhold or refuse to issue a valid certificate of proof of registration, or to suspend the validity of an existing certification of proof of registration. No. Absent from legal framework (Absent from legal framework)
The entity in charge of the central register is empowered to, whether directly or by application to another authority, including judicial authorities, apply effective, proportionate and dissuasive measures or impose such pecuniary sanctions for failures, including of a repeated nature, to provide the central register with accurate, adequate and up-to-date information about their beneficial ownership. Yes. (1) Fine in the amount of EUR 10,000 to 15,000 in MKD equivalent shall be imposed for a misdemeanor on the legal entity (large trader) referred to in Article 28 paragraph (1) of this Lawif: - it does not possess and does not keep adequate, accurate and updated data on the beneficial owner in accordance with Article 28 paragraph (2) and - it does not enter the data on the beneficial owner/s, as well as the data on the changes in the beneficial owner/s, in the register in accordance with Article 31 of this Law. (Article 192 (1) AML Law 2022)
Competent authorities have immediate, unfiltered, direct and free access to the information held in the interconnected central registers without alerting the legal entity or legal arrangement concerned. These competent authorities include: self-regulatory bodies in the performance of supervisory functions of AML rules; tax authorities; national authorities with designated responsibilities for the implementation of Union restrictive measures; AMLA for the purposes of joint analyses; EPPO; OLAF; Europol and Eurojust when providing operational support to the competent authorities of Member States. Yes. (1) The data that are entered in the register shall be available directly and on the basis of an electronicaccess to the following: 1) The Office; 2) The courts; 3) The bodies in accordance with Article 130 paragraph (1) and Article 151 paragraph (1) of this Law; 4) The entities referred to in Article 5 of this Law; 5) other legal and natural persons. (2) The competent bodies referred to in paragraph (1) items 1), 2) and 3) of this Article may provide all data contained in the register free of charge, in a timely manner in accordance with the Law on Central Registry, as well as forward them to the competent bodies and financial intelligence units of other countries in accordance with their competencies determined by law. (Article 33, AML Law 2022)
Beneficial ownership information held in central registers may be made available to obliged entities upon payment of a fee, which shall be limited to what is strictly necessary to cover the costs of ensuring the quality of the information held in the central registers and of making the information available. Those fees shall be established in such a way as not to undermine effective access to the information held in the central registers. Yes. (3) The entities referred to in paragraph (1) item 4) of this Article shall have timely access to all data contained in the register in accordance with the Law on Central Registry and use them to perform their competencies in accordance with this Law. (4) The data in the register on the name and surname, month and year of birth, citizenship, country of stay, ownership share or another form and type of ownership or control, in a form of information, and in accordance with the Tariff of the register administrator shall be publicly available to the legal entities and natural persons referred to in paragraph (1) item 5) of this Article. (Article 33 (3), (4), AML Law 2022)
Any natural or legal person that can demonstrate a legitimate interest in the prevention and combating of money laundering, its predicate offences and terrorist financing has access to the following information on beneficial owners of legal entities and legal arrangements held in the interconnected central registers, without alerting the legal entity or legal arrangement concerned: the name of the beneficial owner; the month and year of birth of the beneficial owner; the country of residence and nationality or nationalities of the beneficial owner; for beneficial owners of legal entities, the nature and extent of the beneficial interest held; for beneficial owners of express trusts or similar legal arrangements, the nature of the beneficial interest. Yes. (1) The data that are entered in the register shall be available directly and on the basis of an electronicaccess to the following: 1) The Office; 2) The courts; 3) The bodies in accordance with Article 130 paragraph (1) and Article 151 paragraph (1) of this Law; 4) The entities referred to in Article 5 of this Law; 5) other legal and natural persons. (2) The competent bodies referred to in paragraph (1) items 1), 2) and 3) of this Article may provide all data contained in the register free of charge, in a timely manner in accordance with the Law on Central Registry, as well as forward them to the competent bodies and financial intelligence units of other countries in accordance with their competencies determined by law. (Article 33, AML Law 2022)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: persons acting for the purpose of journalism, reporting or any other form of expression in the media, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing; Yes. Information is publicly available (Article 33, AML Law 2022)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: civil society organisations, including non-governmental organisations and academia, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing; Yes. Information is publicly available (Article 33, AML Law 2022)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: natural or legal persons likely to enter into a transaction with a legal entity or legal arrangement and who wish to prevent any link between such a transaction and money laundering, its predicate offences or terrorist financing; Yes. Information is publicly available (Article 33, AML Law 2022)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: Member States’ public authorities in the context of public procurement procedures, in respect of the tenderers and operators being awarded the contract under the public procurement procedure; Yes. Information is publicly available (Article 33, AML Law 2022)
Member States shall ensure that the information provided by central registers does not lead to the identification of any person consulting the register where such persons are: persons acting for the purpose of journalism, reporting or any other form of expression in the media, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing; Yes. Information is publicly available (Article 33, AML Law 2022)
Member States shall ensure that the information provided by central registers does not lead to the identification of any person consulting the register where such persons are: civil society organisations that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing. Yes. Information is publicly available (Article 33, AML Law 2022)
Where entities in charge of central registers decide to grant access to beneficial ownership information, they shall issue a certificate granting access for 3 years. Entities in charge of central registers shall respond to any subsequent request to access beneficial ownership information by the same person within 7 working days. Yes. Information is publicly available (Article 33, AML Law 2022)
Member States shall ensure that entities in charge of central registers shall only refuse a request to access beneficial ownership information on one of the following grounds: the applicant has not provided the necessary information or documents pursuant to paragraph 1; a legitimate interest to access beneficial ownership information has not been demonstrated; where on the basis of information in its possession, the entity in charge of the central register has a reasonable concern that the information will not be used for the purposes for which it was requested or that the information will be used for purposes that are not connected to the prevention of money laundering, its predicate offences or terrorist financing; one or more of the situations referred to in Article 15 applies; the legitimate interest to access beneficial ownership information granted by the central register of another Member State does not extend to the purposes for which the information is sought; where the applicant is in a third country and responding to the request to access information would not comply with the provisions of Chapter V of Regulation (EU) 2016/679. Yes. Information is publicly available (Article 33, AML Law 2022)
In exceptional circumstances to be laid down in national law, where the access to beneficial ownership information would expose the beneficial owner to disproportionate risk of fraud, kidnapping, blackmail, extortion, harassment, violence or intimidation, or where the beneficial owner is a minor or otherwise legally incapable, Member States shall provide for an exemption from such access to all or part of the personal information on the beneficial owner. Member States shall ensure that such exemptions are granted on a case-by-case basis upon a detailed evaluation of the exceptional nature of the circumstances and confirmation that those disproportionate risks exist. The right to an administrative review of the decision granting an exemption and the right to an effective judicial remedy shall be guaranteed. Yes. Information is publicly available (Article 33, AML Law 2022)

Supervision of obliged entities

Each Member State shall ensure that all obliged entities established in its territory are subject to adequate and effective supervision. To that end, each Member State shall appoint one or more supervisors to monitor effectively, and to take the measures necessary to ensure compliance by the obliged entities with Regulations (EU) 2024/1624 and (EU) 2023/1113. Yes. (1) Supervision over the application of the measures and actions determined by this Law shall be performed by the supervisory bodies in the sense of this Law, as follows: 1) The National Bank of the Republic of North Macedonia in relation to banks, savings houses, exchange offices and remittance service providers (fast money transfer) and other financial institutions providing payment services in accordance with law; Disclaimer: This is an unofficial text of the Law on the prevention of money laundering and financing of terrorism. For the official text of the law, please see the Official Gazette of the Republic of North Macedonia 2) the Insurance Supervision Agency in relation to legal entities and natural persons performing insurance, representation and/or mediation in life insurance with savings and/or investment component and other related insurance with savings and/or investment component such as: insurance companies; insurance brokerage and representation companies and insurance agents; 3) the Securities and Exchange Commission of the Republic of North Macedonia in relation to brokerage houses, banks with licenses to operate with securities, persons providing services to investment advisers, investment advisory companies, companies for management of open, closed and private investment funds and open , closed and private investment funds; 4) the Agency for Supervision of Fully Funded Pension Insurance in relation to companies that manage voluntary pension funds; 5) The Public Revenue Office in relation to organizers of games of chance, legal entities and natural persons that perform the following services: real estate brokerage, giving advice in the field of taxes and legal entities that perform the activity of receiving pledge of movable objects and real estate; 6) the Postal Agency in relation to JSC Post of North Macedonia; 7) the Commission of Notaries within the Notary Chamber of the Republic of North Macedonia in relation to notaries public and 8) the Commission of Lawyers within the Bar Association of the Republic of North Macedonia in relation to lawyers and law firms. (Article 151, AML Law 2022)

Financial Intelligence Units (FIUs)

Each Member State shall establish an FIU in order to prevent, detect and effectively combat money laundering and terrorist financing. Yes. (1) The Office shall be a unit of financial intelligence of the Republic of North Macedonia, established for the purpose of collecting and analyzing reports for suspicious transactions and other information of importance for the prevention and detection of money laundering and financing of terrorism and submitting the results of the analysis and other additional relevant information to the competent bodies in cases of grounds for suspicion of money laundering and financing of terrorism. (Article 75 AML Law 2022)
The FIU as the central national unit shall be responsible for receiving and analysing suspicious transaction reports and other information relevant to money laundering, associated predicate offences or terrorist financing. Yes. (1) The Office shall be a unit of financial intelligence of the Republic of North Macedonia, established for the purpose of collecting and analyzing reports for suspicious transactions and other information of importance for the prevention and detection of money laundering and financing of terrorism and submitting the results of the analysis and other additional relevant information to the competent bodies in cases of grounds for suspicion of money laundering and financing of terrorism. (Article 75 AML Law 2022)
The FIU shall be responsible for disseminating the results of its analyses and any additional relevant information to the competent authorities where there are grounds to suspect money laundering, associated predicate offences or terrorist financing. Yes. (1) The Office shall be a unit of financial intelligence of the Republic of North Macedonia, established for the purpose of collecting and analyzing reports for suspicious transactions and other information of importance for the prevention and detection of money laundering and financing of terrorism and submitting the results of the analysis and other additional relevant information to the competent bodies in cases of grounds for suspicion of money laundering and financing of terrorism.
The FIU shall be operationally independent and autonomous, which means that the FIU shall have the authority and capacity to carry out its functions freely, including the ability to take autonomous decisions to analyse, request and disseminate specific information. It shall be free from any undue political, government or industry influence or interference. No. (2) The Office shall be a state administrative body within the Ministry of Finance, with the capacity of a legal entity (Article 75 (2), AML Law 2022)
The FIU, regardless of their organisational status, is authorised to have access to the information that they require to fulfil their tasks, including financial, administrative and law enforcement information. Yes. (4) For the purpose of exercising its competencies, the Office shall have timely, direct or indirect electronic access to data, information and documentation which are at the disposal of the entities, the state bodies and institutions, and other legal entities or natural persons in accordance with the provisions of this Law. (Article 75 (4) AML Law 2022)
FIUs are empowered to take urgent action, directly or indirectly, where there is a suspicion that a transaction is related to money laundering or terrorist financing, to suspend or withhold consent to that transaction. Yes. tencies, - to prepare and submit reports to the competent state bodies whenever there are grounds for suspicion that a crime of money laundering or financing of terrorism has been committed, - to prepare and submit a notification to the competent state bodies about existence of grounds for suspicion that another crime has been committed, - to issue a written order to the entity on the basis of which the transaction is temporarily kept on hold, (Article 75 (3) AML Law 2022)

Mutual legal assistance (MLA) and International Cooperation

Member States shall ensure that the FIU to whom the request is made is legally required to use the whole range of its available powers which it would normally use domestically for receiving and analysing information when it replies to a request for information from another FIU. Yes. (1) The Office shall cooperate internationally with financial intelligence units from other states through exchange of relevant data, information and documentation, spontaneously or upon request, for the purposes of preventing and detecting money laundering and finacing of terrorism in accordance with the provisions of this Law. (2) The international exchange of relevant data, information and documentation referred to in paragraph (1) of this Article shall be made on the basis of: - a request for exchange of data, information and documentation which the Office submits to the financial intelligence unit of another state, - a request for exchange of data, information and documentation which the Office receives by the financial intelligence unit of another state, - submission of data, information and documentation of the Office to the financial intelligence unit of another state or Disclaimer: This is an unofficial text of the Law on the prevention of money laundering and financing of terrorism. For the official text of the law, please see the Official Gazette of the Republic of North Macedonia - submission of data, information and documentation from a financial intelligence unit of another state to the Office. (3) The Office shall cooperate internationally with financial intelligence units of other states regardless of their organizational form, the type of related offenses even when the related offenses have not been prescribed as such at the time of the exchange of data, information and documentation. (4) The Office may conclude agreements for cooperation with financial intelligence units of other states, as well as with international organizations involved in the fight against money laundering and finacing of terrorism for the purpose of preventing and detecting money laundering and financing of terrorism. The signing of agreements for cooperation shall not be a precondition for the Office to cooperate internationally with financial intelligence units of other states. (Article 142 AML Law 2022)
Member States shall ensure that FIUs are legally required to exchange, spontaneously or upon request, any information that may be relevant for the processing or analysis of information by the FIU related to money laundering, its predicate offences, or terrorist financing, and the natural or legal person involved, regardless of the type of predicate offences that may be involved, and even if the type of predicate offences that may be involved is not identified at the time of the exchange. Yes. (1) For the purpose of exercising its competencies, the Office may submit a request for exchange of data, information and documentation to a financial intelligence unit of another state in accordance with the provisions of this Law. (2) The appropriate known facts that point out to money laundering and/or finacing of terrorism, the reasons and the purpose for which the requested data and information are to be used should be elaborated in the request for exchange of data, information and documentation referred to in paragraph (1) of this Law. (3) The Office shall be obliged to use the data, information and documentation provided in accordance with paragraph (1) of this Article for exercising its competencies in accordance with this Law, in accordance with the limitations and the conditions set out by the financial intelligence unit of the state which has provided them. (4) The Office may exchange the data, information and documentation provided in accordance with paragraph (1) of this Article with competent bodies after it obtains a previous consent by the financial intelligence unit of the state which has provided them and in accordance with their limitations and terms. (5) The data, information and documentation provided in accordance with paragraph (1) of this Article shall be classified and shall be marked at least with the same level of classification determined by the financial intelligence unit of the state which has provided them. (Article 143 AML Law 2022)

Legislation

*Last update: 2017


Asset Recovery


Quantitative Data

Primary Metric

201220152016201720202024Trend
Asset Offices0
Confiscation89
International cooperation50

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness


Qualitative Data

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Country score

Asset Offices

Each Member State shall legally designate at least one asset recovery office to facilitate cross-border cooperation in relation to asset-tracing investigations and to conduct asset recovery functions in both criminal matters and civil or administrative matters. No. North Macedonia has specialised units in police, prosecution and Ministry of Finance and is introducing a civil confiscation mechanism, but there is no authority formally designated in law as an “asset recovery office” in the sense of Council Decision 2007/845/JHA. (Criminal Code, Law on Criminal Procedure and Law on Property Confiscation in Civil Cases (no explicit ARO designation).)
Each Member State shall legally designate at least one competent authority to function as an asset management office for the purpose of the management of frozen and confiscated property until the disposal of that property further to a final confiscation order. No. Management and disposal of seized/confiscated property is handled through general enforcement and state‑property bodies under the new civil confiscation law and existing enforcement rules; (Law on Property Confiscation in Civil Cases and enforcement legislation (no explicit AMO).)

Confiscation

Member States shall take the necessary measures to enable the freezing of property necessary to ensure a possible confiscation of that property. The freezing measures shall consist of freezing orders and immediate action. (Freezing measures) Yes. The Law on Criminal Procedure allows temporary securing and confiscation of objects and property: objects that are to be confiscated or may serve as evidence are temporarily seized and entrusted to the court, and temporary securing covers freezing, seizure and holding of funds, bank accounts, (Law on Criminal Procedure (2010), Article 203 (temporary securing and confiscation of objects and property, including freezing of funds and bank accounts).)
Member States shall take the necessary measures to enable the confiscation, either wholly or in part, of instrumentalities and proceeds stemming from a criminal offence subject to a final conviction, which may also result from proceedings in absentia. (Conviction based confiscation) Yes. The Criminal Code provides that no one may retain indirect or direct proceeds of crime: confiscation of property and material profits and confiscation of objects is a separate criminal‑law measure, (Criminal Code, Article 97 (confiscation of property and property benefit obtained by a criminal offence) and Article 98 (confiscation of objects).)
Member States shall take the necessary measures to enable the confiscation of property the value of which corresponds to instrumentalities or proceeds stemming from a criminal offence subject to a final conviction, which may also result from proceedings in absentia. (Confiscation of equivalent value) Yes. Confiscation covers property into which the proceeds of crime have been transformed or converted, and property acquired from legitimate sources if proceeds have been intermingled, (Criminal Code, Article 97‑a and related provisions (confiscation of proceeds of crime, including transformed and intermingled property).)
Member States shall take the necessary measures to enable the confiscation of proceeds, or other property the value of which corresponds to proceeds, which, directly or indirectly, were transferred by a suspected or accused person to third parties, or which were acquired by third parties from a suspected or accused person. (Third-party confiscation) Yes. Confiscation may be ordered from third persons where they hold property that is the direct or indirect proceeds of crime, including cultural heritage and natural rarities, as well as objects to which the damaged party is personally attached, (Criminal Code, Article 98 and related provisions (confiscation of objects and property from third persons).)
Member States shall take the necessary measures to enable the confiscation, either wholly or in part, of property belonging to a person convicted of a criminal offence where the offence committed is liable to give rise, directly or indirectly, to economic benefit, and where a national court is satisfied that the property is derived from criminal conduct. (Extended confiscation) Yes. Extended confiscation was introduced in 2009 and is reflected in Chapter 7: for certain serious offences, the court can confiscate property and profits that exceed lawful income and are presumed to originate from criminal activities, (Criminal Code, Articles 97–100 (extended confiscation of assets and proceeds, including indirect and direct benefits and assets acquired through crime).)
Member States shall take the necessary measures to enable the confiscation of instrumentalities, proceeds or property, or proceeds or property transferred to third parties, where criminal proceedings have been initiated but could not be continued because of illness, absconding, or death of the accused or the limitation period of the offence is below 15 years and has expired. (Non-conviction based confiscation) Yes. A new Law on Property Confiscation in Civil Cases entered into force in September 2024, introducing a civil forfeiture mechanism that allows targeting assets suspected of being derived from criminal activities, even without a criminal conviction, (Law on Property Confiscation in Civil Cases (2024),)
Confiscation without a prior conviction shall be limited to cases where, in the absence of the circumstances above, it would have been possible for the relevant criminal proceedings to lead to a criminal conviction for, at least, offences liable to give rise, directly or indirectly, to substantial economic benefit, and where the national court is satisfied that the instrumentalities, proceeds or property to be confiscated are derived from, or directly or indirectly linked to, the criminal offence in question. (Non-conviction based confiscation) Yes. The civil confiscation law complements existing criminal confiscation and allows lower evidentiary thresholds while still requiring a civil‑court assessment that assets are unlawfully acquired and linked to criminal activities, thereby creating a non‑conviction (Law on Property Confiscation in Civil Cases (2024),)
Member States shall take the necessary measures to enable the confiscation of property identified in the context of an investigation in relation to a criminal offence, provided that a national court is satisfied that the identified property is (i) derived from criminal conduct committed within the framework of a criminal organisation and (ii) that conduct is liable to give rise, directly or indirectly, to substantial economic benefit. A ‘criminal offence’ in this case is punishable by deprivation of liberty of a maximum of at least four years. (Confiscation of unexplained wealth) Yes. The combination of extended confiscation under the Criminal Code and the new civil confiscation law allows authorities to target and confiscate property whose lawful origin cannot be demonstrated and which is suspected to be derived from organised crime and corruption, acting as an unexplained‑wealth (Criminal Code, Articles 97–100 (extended confiscation of assets disproportionate to lawful income); Law on Property Confiscation in Civil Cases (2024) (civil forfeiture of unlawfully acquired property).)
Member States are legally required to adopt a national strategy on asset recovery and update it at regular intervals of no longer than five years. (Deadline of 24 May 2027) No. North Macedonia has updated its confiscation framework and introduced civil asset forfeiture, but there is no explicit statutory national asset recovery strategy with a mandatory five‑year update obligation as of 31.12.2024. (No explicit national asset recovery strategy provision in the Criminal Code, Law on Criminal Procedure or Law on Property Confiscation in Civil Cases.)

International cooperation

To facilitate cross-border cooperation, Member States shall legally require measures to enable the swift tracing and identification of instrumentalities and proceeds, or of property which is, or might become, the object of a freezing or confiscation order in the course of proceedings in criminal matters. Yes. The Law on Criminal Procedure provides for mutual legal assistance in identifying, tracing and freezing or seizure of proceeds, property and assets and instrumentalities of crimes for the purpose of eventual forfeiture, (Law on Criminal Procedure (2010), provisions on international cooperation and Article 203‑a (temporary measures for confiscation and seizure at the request of foreign authorities).)
Member States shall legally require the necessary measures to ensure that their asset recovery offices provide, upon request from an asset recovery office in another Member State, any information that those asset recovery offices have access to, and that is necessary for the performance of the tasks of the asset recovery office requesting that information No. Information exchange on assets is handled via mutual legal assistance and police/FIU channels rather than through a single designated asset recovery office with explicit ARO‑to‑ARO (Law on Criminal Procedure (international cooperation provisions); no specific ARO)
Member States may legally allow for cost-sharing agreements with other Member States on the execution of freezing and confiscation orders. No. North Macedonian legislation on mutual legal assistance and confiscation does not contain a specific statutory clause allowing cost‑sharing (No explicit cost‑sharing provision identified in Law on Criminal Procedure or confiscation‑related)
Countries should be able to share confiscated property with other countries, in particular when confiscation is directly or indirectly a result of co-ordinated law enforcement actions Yes. Domestic courts may renounce confiscated property and property interests or seized objects in favour of a foreign state under conditions defined by international agreements, and may request temporary measures and enforcement abroad, (Law on Criminal Procedure (2010),)

Legislation

*Last update: 2017