No.021-01-1421/2026-02 Date: 17.6.2026.

MINISTRY OF SPORTS
Marko Kešelj, State Secretary

Belgrade 11000
Bulevar Mihajla Pupina 2

Subject: Opinion on the Draft Strategy for the Development of Sports in the Republic of Serbia for the period from 2026 to 2035

Dear Mr. Kešelj,

The Commissioner for the Protection of Equality has received the Draft Strategy for the Development of Sports in the Republic of Serbia for the period from 2026 to 2035 (hereinafter: the Draft Strategy), for the purpose of providing an opinion.

In this regard, we would first like to inform you that the Commissioner has also reviewed in detail the Ex Ante Analysis of the Strategy for the Development of Sports in the Republic of Serbia for the period from 2026 to 2035[1], prepared by the Ministry of Sports. This document comprehensively considers the importance of advancing equality and combating all forms of discrimination in the field of sports, proceeding from the relevant international standards and the national anti-discrimination framework. Particular attention has been devoted to the National Strategy for the Prevention and Protection against Discrimination for the period 2022–2030, with its general objectives being properly recognized and integrated into the analysis. The Ex Ante Analysis also takes into account the United Nations Sustainable Development Goals, particularly Goal 5, which concerns achieving gender equality and empowering all women and girls. The Commissioner particularly commends the complex consideration of potential discriminatory forms of conduct in the field of sports and the clear position that discrimination in sports and society is not acceptable conduct and that equal treatment and equality constitute the starting and necessary foundation for the development of every individual.

From the perspective of its competences, the Commissioner analyzed the submitted strategy, particularly those parts concerning equality and non-discrimination (2. Overview and analysis of the existing situation, 2.12. Women in sports, etc.), as well as the general and specific objectives and the proposed measures.

In this regard, we point out that, during the preceding period, we considered several issues indicating the existence of obstacles to the full and equal participation of certain groups in sports. Thus, in a recommendation of measures[2] addressed in January 2026 to the Ministry of Sports, as well as to the Olympic Committee and the Sports Federation of Serbia, attention was drawn to the need to improve the position of female athletes during pregnancy and after childbirth, particularly in cases in which a sports scholarship represents their only source of income, so that pregnancy and parenthood do not result in the interruption of their sporting careers or place female athletes in a less favorable position compared with other athletes. We therefore consider that it is necessary to consider measures that will contribute to reconciling the family and professional lives of female athletes and provide appropriate forms of support during pregnancy and after childbirth.

In addition, in 2025, the Commissioner recommended that the Ministry of Sports specifically define, in the strategic document for the development of sports, an area or objective relating to the development of women’s sports and their promotion at all levels, taking into account the different personal characteristics of women in sports, such as age, health status, disability and similar characteristics, with the aim of broadening participation in and improving women’s sports, achieving gender equality and preventing and combating gender-based violence in sports. It was also recommended that, when designing measures and activities for the implementation of this objective, consideration be given to the need to increase investment in women’s sports and to ensure and allocate funds for these purposes. An important part of the Draft Strategy is devoted to advancing gender equality, as well as improving the position of certain groups at greater risk of discrimination, and combating gender-based violence in sports. The analysis also points to the need for greater participation by women in leadership positions and governing bodies, as well as greater investment in women’s sports. The statistics provided concerning the comparison of the participation of women and men in sports from the earliest childhood are alarming. Bearing in mind how thoroughly the situation has been considered in the Draft Strategy, we believe that it is necessary to further strengthen the measures that will lead to gender equality in sports, particularly in the part concerning the need for greater investment in women’s sports and greater participation by women in governing bodies. The Commissioner points to an example of good practice and the International Olympic Committee document “Women in the Olympic Movement”[3], which states that the IOC recognizes that gender equality is a critical component of effective sports administration and continues to support the promotion of women and girls in sports at all levels and in all structures beyond the field of play. It was noted that substantial progress had been made in appointing women to key decision-making positions, both within the IOC administration and its governing bodies (as of January 2024, 43 out of 106, or 40.6%, of active IOC members were women, while, as of October 2023, women chaired 14 out of 33 IOC commissions, or 42%, and held 50% of positions on IOC commissions). In 2022, the IOC Women in Sport Commission was renamed the IOC Gender Equality, Diversity and Inclusion Commission in order to reflect its focus on advancing gender equality and the inclusion of women in all their diversity. In order to support the implementation of Olympic Agenda 2020+5, the IOC adopted 21 gender equality and inclusion objectives for the period 2021–2024 in May 2021. The equality review project established a roadmap for future progress in five focus areas: participation, leadership, safe sport, portrayal and resource allocation and three areas of IOC responsibility: the IOC as an organization, the IOC as the owner of the Olympic Games and the IOC as the leader of the Olympic Movement. In the Gender Equality and Inclusion Progress Report for the period 2021–2024, published in 2025, the International Olympic Committee confirmed that gender equality constitutes one of the fundamental principles of the Olympic Movement and an essential condition for good governance in sports. The report particularly emphasizes that the equal participation of women in governing bodies and decision-making positions is a key prerequisite for achieving genuine gender equality. The IOC states that one of its strategic objectives is to further strengthen women’s participation in the governing and leadership structures of sports, confirming the position that the principle of gender equality does not relate exclusively to participation in sporting competitions, but also to equal representation in governance and decision-making processes.

The Commissioner has also drawn attention to the position of deaf male and female athletes, bearing in mind a submission from the Sports Federation of the Deaf of Serbia that pointed to the specific challenges faced by this category of athletes. Namely, the Sports Federation of the Deaf of Serbia addressed a letter to the Commissioner for the Protection of Equality in which, among other things, it provided a detailed explanation of the position of the Sports Federation of the Deaf of Serbia, as well as of competing athletes who have this type of disability. It was stated that, bearing in mind the fact that the Law on Sports does not recognize the Federation as an organization of athletes with disabilities, it is necessary to amend certain provisions of Articles 103, 104, 123 and 140 of the Law on Sports. The submission of the Sports Federation of the Deaf indicates that the umbrella organization under whose auspices persons with hearing disabilities compete, the International Committee of Sports for the Deaf – Deaflympics, has signed a memorandum with the International Olympic Committee providing for the understanding and recognition of this organization as equal and equivalent to organizations such as the International Olympic Committee and the International Paralympic Committee. The International Committee of Sports promotes its fundamental objectives in its statute. These objectives include the Committee being the only international organization representing deaf athletes; developing and promoting sports, as well as competitions within the Community of Deaf Athletes; developing new forms of training and expanding the existing opportunities for deaf persons to participate in sports at the international level.^[4] In addition, the Deaflympics are the only competition in the world conducted in sign language.^[5] The organization and implementation of competitions in which deaf male and female athletes participate are specific, given the fact that these are persons who, in the majority of cases, do not have another disability, which means that they cannot compete in competitions intended for persons with physical disabilities because they do not fulfil the conditions necessary for participation. In this regard, an initiative was submitted to the Ministry and is available at the following link: https://ravnopravnost.gov.rs/192-23-inicijativa-upucena-ministarstvu-sporta/. On that occasion, it was emphasized that, among other things, it was necessary to improve the legal framework in the field of sports. Blind chess players have also pointed to the necessity of amending the Law on Sports. The European Court of Human Rights considered the position of blind chess players from the perspective of a violation of the right to equality. By way of reminder, in the case of the blind chess players – Negovanović and Others v. Serbia[6] the European Court of Human Rights ruled that the state had discriminated against them regarding the benefits and awards enjoyed by other athletes who win medals. The Court found that they should be paid the accrued and all future financial benefits and/or awards to which they would have been entitled had they won medals at a Chess Olympiad for sighted chess players. Unlike other athletes with disabilities and leading chess players who had achieved the same or similar sporting results, the applicants were denied certain financial benefits and awards for achievements, as well as formal recognition through an honorary diploma. The European Court found that, although it was legitimate for the authorities to focus on the highest sporting achievements and the most important competitions within their system of awards, there was no objective and reasonable justification for treating the applicants differently based on their disability.[7] Following the judgment, the Commissioner received a letter stating that the national team of blind and partially sighted chess players had won a bronze medal at the Chess Olympiad for Blind and Partially Sighted Chess Players and that an application for a national sports award and a financial prize had been submitted within the prescribed period, but that the Ministry had still not decided on the application at that time. The letter pointed out that the specific case concerned the same matter, that is, the same factual circumstances based on which the European Court of Human Rights had delivered a judgment finding discriminatory treatment of the applicants. In this regard, the Commissioner addressed a recommendation of measures to the competent Ministry to undertake all necessary measures and actions within its competences so that blind and partially sighted chess players who had won medals at the Chess Olympiad for Blind and Partially Sighted Chess Players would be treated equally with other chess players who had won medals at the Chess Olympiad in the procedure for exercising the right to a national sports award and/or financial prize. In this regard, the Ministry informed the Commissioner that it had adopted a decision to commence work on preparing a Draft Law on Amendments and Supplements to the Law on Sports and that it had conducted consultations with all interested stakeholders. It was further stated that proposals had been submitted, among others, by the National Sports Federation of Blind and Partially Sighted Persons of Serbia and the Sports Federation of the Deaf of Serbia, which proposed amendments and supplements to certain articles of the law. A representative of the Paralympic Committee of Serbia was also appointed to the working group for preparing the Draft Law. Regarding the judgment of the European Court of Human Rights, consultations were held twice with representatives of the State Attorney’s Office Department for the Representation of the Republic of Serbia before the European Court of Human Rights bearing in mind the complexity of the case and with the aim of finding the most effective manner of executing the judgment. Finally, it was noted that, during the preparation of the Draft Law, it was also necessary to analyze the existing situation and the proposals submitted by all relevant sports stakeholders in order to determine the scope of and need for amendments to the legislation governing sports, which would contribute to the adoption of higher-quality legislation, and that it was necessary to assess the financial effects that the amendments to the law would have on the budget of the Republic of Serbia.[8]

In addition, the Commissioner has drawn attention to the position of male and female athletes with intellectual and mental difficulties who participate in the Special Olympics system.

Bearing the above in mind, we consider that, when planning measures and activities, particular consideration should be given to determining which regulations in the field of sports need to be amended or supplemented in order to remove the existing obstacles and improve the position of persons at increased risk of discrimination and social exclusion. This may also be achieved by providing for appropriate activities in the Action Plan, but it is first necessary for the Draft Strategy to clearly identify the existing problems and challenges. In this regard, we believe that the recommendations, opinions and initiatives of the Commissioner for the Protection of Equality can additionally shed light on the aspects that need to be improved and indicate the measures that must be undertaken in order to eliminate the identified problems in practice and further advance equality and protection against discrimination.

COMMISSIONER FOR THE PROTECTION OF EQUALITY

Milan Antonijević

[1] More at: https://www.mos.gov.rs/storage/2024/09/ex-ante-analiza-strategije-razvoja-sporta-srbije-2026-2035-1.pdf

[2] https://ravnopravnost.gov.rs/rs/1196-25-ministarstvo-sporta/

[3] https://stillmed.olympics.com/media/Documents/Olympic-Movement/Factsheets/Women-in-the-Olympic Movement.pdf?displayAsWebView=true%3FdisplayAsWebView%3Dtrue

[4] More at: http://deaflympics.com/icsd

[5] More at: http://www.ciss.org/deaf-sports-an-empowerment-perspective

[6] Negovanović and Others v. Serbia – 29907/16, 30022/16, 30322/16 et al. Judgment 25.1.2022

[7] More at: https://ravnopravnost.gov.rs/rs/preporuka-mera-za-ostvarivanje-ravnopravnosti-ministarstvu-omladine-i-sporta/

[8] More at: https://ravnopravnost.gov.rs/rs/preporuka-mera-za-ostvarivanje-ravnopravnosti-ministarstvu-omladine-i-sporta/