Frontloading – A New Term in the Enlargement Policy Jargon

The EU is well known for coining new terms to explain innovative proposals through which it seeks to achieve its goals. In the context of enlargement policy, the term frontloading will increasingly be heard from now on. Although somewhat vague, it can best be understood as shifting the focus of negotiations to the very beginning of the process, so that the implementation of reform steps begins even before the formal opening of clusters. Since this approach allows technical negotiations to continue even in the absence of political unanimity among member states, Denmark – currently holding the presidency of the Council of the EU and the country behind this idea – argues that this represents a “new approach to enlargement.” An outline of this approach is provided below.

Ukraine (and Moldova) in focus

Although this approach had been in development for months, its “revelation” took place on 11 December 2025 at an informal meeting of EU Ministers for European Affairs in Lviv, Ukraine. The Council meeting was held there, given that, during that period, member states’ decisions were largely focused on providing strong political, financial, economic, humanitarian, military, and diplomatic support to Ukraine. While there is broad unity regarding this type of support, one of the EU’s key challenges has been the prolonged inability of member states to reach unanimity on opening negotiating clusters for Ukraine. Although Ukraine holds candidate status and has formally opened accession negotiations, Hungary has remained the sole member state strongly opposing further progress in Ukraine’s accession process. This has also posed a significant obstacle for Moldova, which has been blocked “as part of the package”. Despite repeated efforts by Member States to win Hungary over, these attempts have proven unsuccessful. It is at this point that Denmark stepped in with a creative solution.

Namely, having assumed the helm of the EU Council for the eighth time, Denmark committed to drawing on its extensive experience and strong credibility to break the deadlock. By emphasising, at the very outset of its mandate, that enlargement would be among its core priorities, Denmark clearly set the tone for its presidency. This was particularly noteworthy given that enlargement had not traditionally featured among Denmark’s principal political priorities. However, since the onset of Russia’s aggression against Ukraine, Denmark has adopted a markedly firmer position in favour of deeper EU integration, increased joint spending, and the expansion of the Union’s borders. Against this backdrop, Denmark was determined to identify a solution to the Ukrainian case. In practical terms, this meant that if Hungary could not be persuaded, alternative ways of circumventing its veto would need to be explored. Naturally, any immediate solution would have to be regarded as a temporary measure, as many Member States are awaiting political developments in Hungary, with parliamentary elections scheduled for April 2026.

Unlocking the negotiations

Denmark’s efforts built on the European Commission’s successful undertaking to respond, at maximum speed, to the requirements related to the screening of the degree of alignment of national legislation with the EU acquis. According to the Commission’s assessment, all six negotiating clusters are ready to be opened for Ukraine. However, it is not the Commission that decides on the opening of clusters, but the Council, where decisions are taken unanimously. Aware of how problematic it can be when a single member state abuses its veto power, especially at a time when Ukraine is striving to resist Russian aggression, Denmark, in agreement with all other Member States except Hungary, introduced an approach that allows technical negotiations in certain clusters to begin without a formal political decision on their opening. This arrangement was implemented informally, with the presiding country creatively using its procedural powers.

Specifically, instead of waiting for unanimity for the EU to adopt common positions on clusters – which specify what the Union expects candidate countries to fulfil in order to make further progress in the negotiations – the document was, on this occasion, issued by the presiding country itself, in its own name. In other words, it was a draft common position formally issued by the presidency alone, but whose content had been agreed by all Member States except one. Until now, the EU had strictly prohibited the transmission of such documents to candidate countries before negotiations on the relevant clusters had formally begun – a constraint that has now been effectively overcome. The aim was to enable Ukraine and Moldova to begin implementing all necessary reforms without waiting for Hungary to give the green light. In practice, the process has officially remained at the same stage as before, while unofficially – but substantively – these candidate countries now have a clear roadmap outlining everything that needs to be done on the path to EU membership.

De facto opening of clusters

With this kind of creative solution, Ukraine has been de facto enabled to open as many as three negotiating clusters, and the same applies to Moldova. Among them is Cluster 1 (Fundamentals), which covers the most demanding and most significant reforms. As with candidates from the Western Balkans, this cluster is opened first in order to place core reforms at the forefront, and progress achieved in this area determines whether, and to what extent, other clusters will be opened or individual chapters closed. In line with the revised enlargement methodology, in order for this cluster to be opened at all, Ukraine and Moldova had to meet the opening benchmarks, which included the adoption of roadmaps on the rule of law, public administration and democratic institutions, as well as an action plan on national minorities – documents that were positively assessed by the European Commission. In addition to this cluster, Cluster 2 (Internal Market) and Cluster 6 (External Relations) were also included. Ukraine and Moldova can already work on these clusters, and may even complete them in full, meaning that once Hungary lifts its blockade, their formal opening and closing could take place almost simultaneously.

With these advances, Ukraine and Moldova have surpassed the entire Western Balkans, except Montenegro and Albania, in terms of the number of (technically) opened clusters. Serbia, which until recently stood shoulder to shoulder with Montenegro, has thus been pushed, for example, to fifth place in terms of progress towards EU membership. This gap could widen further given that, as Cyprus takes over the Presidency of the Council of the EU, there is an informal agreement to open the remaining three clusters with Ukraine, and potentially Moldova, by mid-2026. Should Orban suffer an electoral defeat, it can be expected that technical negotiations will soon receive their political endorsement as well, meaning that unanimity among member states for the formal opening of negotiations would be achieved. All of this illustrates the extent to which geopolitical pressures can act as a powerful incentive for the Union to resort to creative solutions in order to overcome unilateral blockages in the accession process of candidate countries. For now, the only open question remains whether, and to what extent, this innovative approach can also be applied to the Western Balkans. The coming year, 2026, may soon provide an answer to that question.