Disclaimer: 

This explainer summarises the study Pathways to Gradual Integration: A Comparative Analysis of the EU Association Framework, authored by Sokol Zeneli and Gresa Smolica. For the full analysis, legal detail, and sources, read the complete study on our website. 

What is Gradual Integration?

Gradual integration has become one of the central pillars of the European Union's renewed enlargement strategy. Rather than waiting until full membership, candidate countries can progressively access selected EU markets, institutions and programmes as they implement reforms. Following Russia's full-scale invasion of Ukraine in 2022, this approach gained further momentum as enlargement became not only a technical process, but also a geopolitical priority. Its objective is to provide more concrete benefits earlier in the accession process, sustaining reform momentum while bringing candidate countries closer to the EU. 

This renewed approach also reflects the EU's efforts to revitalise an enlargement process that had slowed considerably during two decades of enlargement fatigue phenomenon. Despite some Western Balkan 6 (WB6) countries holding an EU membership perspective for more than two decades, accession has become increasingly prolonged and uncertain. In response, the European Commission introduced a revised enlargement methodology in 2020, placing greater emphasis on gradual integration as a way to reward reforms with concrete benefits before full accession.

However, not all candidate countries enter this process with the same legal tools. The agreements governing the relationship between the EU and candidate countries differ significantly in their design and scope, creating unequal opportunities for integration even before accession. This raises an important question: why do some countries appear to move closer to the EU faster than others despite having a shorter membership perspective? The following explainer examines how these different legal frameworks shape pathways to gradual integration across Europe.

As illustrated in Figure 1, gradual integration can be understood through three main pathways: access to the EU Single Market, participation in EU institutions and programmes, and financial support for reforms. 

Figure 1: Three Pathways for Gradual Integration 

Source: Authors' own creation

Why are candidate countries treated differently?

The path to EU membership is shaped not only by political will and reforms, but also by the legal agreements that structure the relationships with the Union. The WB6 and the Associated Trio (Ukraine, Moldova, and Georgia) are governed by different agreements with the EU, each reflecting different political and historical circumstances. The Stabilisation and Association Agreements (SAA) signed by the WB countries were introduced as a response to the Yugoslav wars, with the goal of promoting political stability, regional cooperation and eventual accession to the EU. On the other hand, the Associated Trio are linked to the EU through Association Agreements and Deep and Comprehensive Free Trade Areas (AA/DCFTAs). Such agreements were originally designed around the idea of "integration without membership", providing deep economic integration without a formal accession perspective.

The differences in these agreements are more than just legal technicalities. Their designs shape how countries access EU markets, institutions, and programmes before full membership. Therefore, the three countries with a shorter history of candidacy may, paradoxically, have stronger tools for gradual integration than long-standing candidates in the Western Balkans.

Pathway 1: Access to the EU Single Market

Among the various forms of gradual integration, access to the EU Single Market offers some of the most immediate benefits for candidate countries, as it directly affects trade, investment, and business opportunities. The EU Single Market, one of the biggest global markets, seeks to guarantee the free movement of goods, services, capital, and people across participating nations. As a result, products can be sold across borders without additional tariffs, quotas, or technical barriers; businesses or individuals can provide services without bureaucratic constraints; investments and money transfers can flow freely without capital control; and citizens of these countries can live, work, or study in any of the member states. These freedoms are intended to stimulate trade, attract investment, and generate economic benefits for businesses and citizens.

As shown in Table 1, access to the benefits of the Single Market is not identical for all candidate countries. The AA/DCFTAs governing the Associated Trio were specifically designed to facilitate deep economic integration, linking regulatory reforms more directly to market access. By contrast, the SAAs of the WB6 provide a less automatic path, often requiring additional political decisions and separate agreements to unlock similar benefits. The difference is particularly visible in the case of the EU's "Roam Like at Home" initiative. While Ukraine's progress toward joining the EU roaming area is embedded within its broader process of legal alignment with EU rules, the WB6 have largely relied on separate agreements between the EU and telecommunications operators to gradually reduce roaming charges, with the objective of eliminating additional roaming fees by 2028. This illustrates a broader reality of gradual integration: implementing reforms is important, but the legal framework itself often determines how quickly countries can gain the benefits of European integration. Without clearer legal pathways to market access, the WB6 risk remaining in a "stabilisation loop", where reforms do not always translate into concrete integration benefits. 

Table 1: Key Differences between the AA/DCFTAs and SAA Frameworks for Access to the EU Single Market

Source: Zeneli, S. & Smolica, G. (2026)

Pathway 2: Participation in EU Institutions and Programmes

Gradual integration extends beyond markets and also includes participation in EU institutions, agencies, and programmes. According to some estimates, candidate countries can potentially engage with up to 333 EU agencies, bodies and programmes, illustrating the broad scope of gradual integration beyond formal membership. Here too, important differences emerge between the two legal frameworks. The AA/DCFTAs governing Ukraine, Moldova and Georgia provide clearer legal pathways for participation in EU programmes and administrative structures, often linking access directly to regulatory reforms. By contrast, the SAAs of the WB6 rely more heavily on broad cooperation clauses, meaning that integration into EU bodies frequently requires separate political agreements and negotiations. The recent integration of several Western Balkan countries into the Single Euro Payments Area (SEPA) illustrates this dynamic. While SEPA membership promises faster and cheaper cross-border euro payments, access to it has largely been driven by the EU Growth Plan and domestic reforms in areas such as payment services and anti-money laundering legislation, rather than by the SAA framework itself. This suggests that, unlike market integration, access to EU institutions and programmes depends not only on legal agreements, but also on administrative capacity and political willingness on both sides.

Pathway 3: Financial Support for Reforms

Financial support has become another important pathway for gradual integration, as the EU increasingly uses funding as an incentive for reforms. Historically, the WB6 and the Associated Trio relied on traditional financial instruments, such as the Instrument for Pre-accession Assistance (IPA) for the WB6 and Türkyie and the European Neighbourhood Instrument (ENI) for the Associated Trio. While these funds supported institution-building and development projects, they often lacked strong incentives for deep reforms. Over time, however, the EU shifted towards a more performance-based approach, linking financial support directly to reform progress. Today, the WB6 benefit from the EU Growth Plan and its Reform and Growth Facility, while Ukraine and Moldova receive support through instruments such as the Ukraine Facility and Moldova Growth Plan. Under these initiatives, governments receive funding only after the European Commission verifies that agreed reforms, ranging from rule of law and digitalisation to green transition and economic governance, have been implemented. In this sense, financial instruments have evolved from simple development aid into a key mechanism for accelerating gradual integration and bringing candidate countries closer to the EU before membership.

Why does this matter?

These differences matter because gradual integration is increasingly becoming the EU’s preferred approach to enlargement. For the WB6, however, the challenge lies in ensuring that reforms produce visible and tangible rewards. Without clear pathways linking regulatory alignment to market access and institutional participation, the region risks experiencing reform fatigue and losing confidence in the accession process. Ultimately, the credibility of enlargement depends not only on candidate countries implementing reforms, but also on the EU delivering predictable and meaningful integration opportunities.

Conclusion

The analysis presented in this explainer reveals an important paradox of the EU enlargement process. While the WB6 have held a membership perspective for over two decades, their legal framework often provides fewer opportunities for gradual integration than the agreements governing Ukraine, Moldova and Georgia. As a result, countries with a shorter history of candidacy may in some areas possess stronger tools for accessing EU markets, institutions and programmes before full membership. At the same time, the emergence of new financial instruments, such as the EU Growth Plan for the Western Balkans and the Ukraine Facility, demonstrates the EU’s increasing reliance on reform-based incentives to advance integration.

Ultimately, gradual integration can strengthen the credibility of the enlargement process by allowing candidate countries to experience some of the benefits of EU membership before accession. Yet, for this approach to succeed, reforms must be accompanied by clear, predictable and fair pathways to integration. If the EU expects candidate countries to align with its rules and standards, it must also ensure that these efforts are rewarded with concrete progress on the road toward membership.

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