I. INTRODUCTION
1.1. We, the undersigned concerned individuals, citizens’ associations and civil society organizations from the Republic of Serbia, hereby submit this formal notice to the Bureau International des Expositions (“BIE”) regarding grave and substantiated concerns about systemic legal violations, corruption, and safety risks associated with the preparations for EXPO 2027 Belgrade.
1.2. This notice is submitted pursuant to:
- The principles embodied in the Convention Relating to International Exhibitions (Paris, 1928, as amended)
- The United Nations Convention against Corruption (UNCAC), to which Serbia is a State Party
- The fundamental principles of transparency, good governance, and rule of law
- The BIE’s mandate to ensure the integrity of World Expositions
- Our civic responsibility to inform international institutions of threats to public interest
This notice is based on publicly available information, official documents, investigative reports, and expert analysis. Complete source documentation is provided, and the authors welcome correction of any factual errors.
1.3. From this moment onward, the BIE cannot claim ignorance of these serious issues should future legal, arbitral, or reputational consequences arise. The matters set forth herein are of the utmost gravity and require immediate attention and action by the BIE to prevent irreparable damage to the institution of World Expositions and to protect public safety and resources.
II. STATEMENT OF MATERIAL FACTS
The following material facts are documented tThe following material facts are documented through official sources, investigative journalism, and expert analysis. Sources are provided for independent verification, and documentation is available upon reasonable request.
A. Legislative Framework Violations
Timeline of Key Developments:
- July 28, 2021: Serbia submits official bid to host EXPO 2027.
- June 21, 2023: BIE officially awards EXPO 2027 to Belgrade.
- December 2023: Enactment of EXPO 2027 Special Law (Official Gazette No. 92/2023).
- Early 2024: Government allocates approximately €578 million for EXPO preparations.
- November 1, 2024: Collapse of Novi Sad railway station canopy causing 15 fatalities. (see Addendum for updated casualty count)
- November 2024: Parliament adopts expanded “Lex Specialis” legislation suspending procurement and safety laws.
- December 2024: Public and expert concerns about financial transparency and legal framework become widely reported.
- February 2025: Serbian Academy of Sciences and Arts issues formal environmental warning.
- March 2025: Over 100,000 citizens sign petition demanding EXPO cancellation; opposition parties formally request BIE intervention.
- June 10–11, 2025: First International Participants Meeting held in Belgrade with 323 delegates.
- May 15 – August 15, 2027: Scheduled dates for EXPO 2027 event in Belgrade.
- The Parliament of the Republic of Serbia enacted special legislation (“Lex Specialis”) that fundamentally undermines the rule of law by:
- Exempting all EXPO-related procurement from public tender requirements, permitting contracts valued up to €1 billion to be awarded without competitive bidding;
Reference: Transparency Serbia, “No Public Procurement for EXPO 2027 Project,” November 2024 URL: https://www.transparentnost.org.rs/en/110-english/naslovna/12536-no-public-procurement-for- expo-2027-project
- Suspending the application of fundamental laws including but not limited to laws governing expropriation, urban planning, construction safety, and environmental protection;
Reference: NIN Magazine, “What EXPO 2027 Really Brings – Law on Unrestricted Disposal of Public Money,” 2024
- Eliminating legal remedies, thereby denying affected parties the right to administrative or judicial review;
Reference: Vreme, “EXPO 2027 Lex Specialis is Legalized Corruption,” 2024
URL: https://vreme.com/komentar/expo-2027-lex-specialis-je-legalizovanje-korupcije/
B. Absence of Required Oversight Mechanisms
- The Government of Serbia has failed to establish any independent oversight mechanism for EXPO 2027, specifically:
- The Ministry of Finance bypassed mandatory consultation with the Anti-Corruption Agency;
- The legislation was adopted without public consultation or parliamentary debate through improper bundling with unrelated bills;
- No provisions exist for independent monitoring of the allocation and use of public funds;
Reference: Transparency Serbia, “Amendment to Prevent Procurement Without Law,” December 2024 URL: https://transparentnost.org.rs/en/110-english/naslovna/12548-an-amendment-to-prevent-procurement- for-expo-2027
C. Financial Irregularities and Misrepresentation
- Substantial evidence indicates systematic financial mismanagement and misrepresentation:
- The initial budget of €1 billion has been inflated to €18 billion through conflation with a non-existent “Serbia 2027” program;
- Bond issuances totaling €1.3 billion at 7% interest will result in €700 million in interest payments alone;
Reference: Kompas, “Fiscal Council Warning: €700 Million Just for Interest on EXPO 2027,” 2024 URL: https://kompas-info.com/upozorenje-fiskalnog-saveta-samo-na-kamate-za-expo-2027-dajemo-700- miliona-evra/
- Documented cost overruns include the National Stadium (€366 million versus €250 million budgeted) and €762 million expended in 2024 alone;
Reference: Forbes/N1, “How Much Has Been Spent on EXPO and National Stadium,” 2024 URL: https://forbes.n1info.rs/novac/koliko-je-dosad-potroseno-na-expo-i-nacionalni-stadion-strategija- vlade-otkriva-stvarni-uticaj-ovog-projekta-na-ekonomiju/
D. Award of Contracts Without Competitive Tender
- The following entities have been awarded substantial contracts without public tender procedures:
First Phase:
- Millennium Team d.o.o. (principals: Ivan Bošnjak, Stojan Vujko)
- Mostogradnja ING d.o.o. (affiliate of Millennium Team)
- Novkol d.o.o.Kompresor ING d.o.o.Golf Šped d.o.o.Vojput d.o.o.
- Bard-Kop d.o.o.
Reference: Nova.rs, “These 7 Firms Already Got Jobs on EXPO Complex,” 2024 URL: https://nova.rs/vesti/biznis/ovih-7-firmi-je-vec-dobilo-posao-na-kompleksu-expo-i-nacionalnom- stadionu-a-radovi-se-nisu-ni-zahuktali/
Second Phase:
- Konkord Vest d.o.o. (principal: Željko Drčelić, Vice President of Red Star FC) – contracts exceeding €250 million
- Studio Gallery 12 d.o.o. – €14.6 million contract despite annual revenue of €4,700
- Goter Construction (principal: son of Red Star FC director)
Reference: Direktno.rs, “EXPO 2027: Costs and Corruption,” January 2025 URL: https://direktno.rs/vesti/drustvo-i-ekonomija/612587/expo-2027-troskovi-korupcija.html
E. Suspension of Safety Regulations
- Of particular concern, the special legislation permits EXPO facilities to operate without use permits for a period exceeding two years, relying solely on technical inspections conducted by the contractors themselves.
- This provision must be viewed in the context of the November 1, 2024, collapse of the Novi Sad railway station canopy, which resulted in 15 fatalities. That facility was operating without proper permits following renovation works.
Reference: Forbes/N1, “State Destroys Last Legal Barriers for EXPO Exhibition in Facilities Without Use Permits,” 2024 URL: https://forbes.n1info.rs/novac/otkrivamo-drzava-rusi-poslednje-zakonske-prepreke-da-bi-stigla-da- izgradi-expo-izlozba-u-objektima-bez-upotrebne-dozvole/
Reference: Nova.rs, “EXPO is SNS Corruption Hub and Potentially New Canopy,” 2024 URL: https://nova.rs/vesti/politika/expo-je-cvor-korupcije-sns-i-potencijalno-nova-nadstresnica-ima-li- opozicija-snage-da-zaustavi-projekat/
F. Environmental Law Violations
- The Serbian Academy of Sciences and Arts (SANU) issued a formal warning in February 2025 stating that the project poses risks of “irreversible environmental damage” and threatens Belgrade’s water supply infrastructure.
Reference: Radar.rs, “SANU: EXPO Dangerous for Environment,” February 2025 URL: https://radar.nova.rs/drustvo/expo-opasan-po-zivotnu-sredinu/
- Notwithstanding these warnings, the Government has proceeded with amendments that bypass environmental impact assessment requirements.
Reference: Ministry of Space, “No Turning Back, Only Forward – Only Public Interest Stands in the Way,” 2025 URL: https://ministarstvoprostora.org/en/nema-nazad-samo-napred-na-tom-putu-jedino-stoji-javni-interes- expo-2027/
G. Land Acquisition Irregularities
- The project area has been expanded from 119 hectares to 813 hectares (an increase of 684%) without justification. The State is repurchasing land previously privatized at prices up to 100 times the original sale price.
Reference: Radio Free Europe, “EXPO 2027: Land in Surčin,” 2024
URL: https://www.slobodnaevropa.org/a/ekspo-2027-zemljiste-surcin-pkb/32867848.html (see Addendum for corrected URL)
H. Public Opposition and International Concern
- As of March 2025, over 100,000 citizens of Serbia have signed a formal petition demanding the cancellation of EXPO 2027.
Reference: Kreni-Promeni, “STOP korupciji, otkaži EXPO,” March 2025 URL: https://peticije.kreni-promeni.org/petitions/stop-korupciji-otkazi-expo
Reference: SeeNews, “Serbia’s Opposition Calls for Cancellation of EXPO 2027,” March 2025 URL: https://seenews.com/news/serbias-opposition-calls-for-cancellation-of-expo-2027-in- belgrade-1271734
- Opposition political parties have formally requested that the BIE revoke Serbia’s hosting license.
Reference: Lawyer Monthly, “Serbian Opposition Calls to Cancel EXPO 2027 Over Corruption Concerns,” March 2025
I. Evidence of State Capture
- The pattern of violations documented above constitutes prima facie evidence of state capture, defined by the World Bank as a situation where “formal procedures and government bureaucracy are manipulated by government officials, state-backed companies, private companies or private individuals, so as to influence state policies and laws in their favour.”
- The EXPO 2027 project exhibits classic characteristics of state capture:
- Legislative manipulation to benefit specific economic actors
- Systematic dismantling of oversight mechanisms
- Concentration of benefits among politically-connected entities
- Exclusion of public interest from decision-making processes
- Independent analysts have characterized the special legislation as “legalized theft of public money” and part of a decade-long pattern including Belgrade Waterfront and South Stream projects.
Reference: Nova.rs, “EXPO is SNS Corruption Hub,” 2024 URL: https://nova.rs/vesti/politika/expo-je-cvor-korupcije-sns-i-potencijalno-nova-nadstresnica-ima-li- opozicija-snage-da-zaustavi-projekat/
II. APPLICABLE LEGAL FRAMEWORK
3.1. United Nations Convention against Corruption (UNCAC)
- Article 34 requires that consequences of corruption be addressed, including potential annulment of contracts
- Article 5 mandates preventive anti-corruption policies and practices
- Article 9 requires transparent and objective public procurement systems
- Article 13 establishes obligations for citizen participation in anti-corruption efforts
3.2. BIE Convention and Regulations
- The BIE’s supervisory mandate requires coordination with member states to ensure World Expositions are conducted in accordance with principles of integrity, transparency, and respect for law
- Registration of a World Exposition implies commitment to international standards of governance
- The BIE’s coordinating role enables it to facilitate international scrutiny and member state oversight
3.3. Principles of International Law
- Good faith (bona fides) in the performance of international obligations
- Respect for the rule of law as a fundamental principle
- International cooperation in addressing corruption and ensuring compliance with international standards
3.4. Relevant Precedents
The importance of citizen notifications in addressing international corruption has been demonstrated in several high-profile cases:
- FIFA Corruption Scandal (2015): Following years of investigative journalism and civil society pressure, including formal complaints from transparency organizations, U.S. authorities indicted 14 FIFA officials for corruption. The scandal led to fundamental reforms in FIFA governance and demonstrated how sustained civic pressure can trigger international action against corruption.
- Salt Lake City Olympics (2002): Media investigations and whistleblower reports revealed systematic bribery in the bid process. The IOC was forced to implement a 50-point reform package after civil society organizations and media exposed the corruption, establishing new ethics standards and oversight mechanisms.
- Investment Arbitration Precedents: In cases such as World Duty Free v. Kenya and Metal-Tech v. Uzbekistan, international tribunals have dismissed investor claims upon finding evidence of corruption, establishing that contracts procured through corruption are legally void. Importantly, these cases recognized that formal notification of corruption allegations prevents parties from later claiming ignorance or good faith.
3.5 European Union Framework
While Serbia is not yet an EU member state, the following EU instruments and principles are relevant to this matter:
- EU-Serbia Relations
- Stabilisation and Association Agreement (2013): Establishes obligations regarding rule of law, good governance, and anti-corruption measures
- Chapter 23 (Judiciary and Fundamental Rights) and Chapter 24 (Justice, Freedom and Security) in EU accession negotiations require comprehensive anti-corruption frameworks
- EU Serbia Progress Reports consistently identify public procurement transparency as a key accession requirement
- EU Standards and Principles
- Venice Commission Rule of Law Checklist: Emphasizes legal certainty, prevention of abuse of power, and access to justice—all compromised by the EXPO special legislation
- EU Public Procurement Directives (2014/24/EU): While not directly applicable, establish international best practices systematically violated in EXPO preparations
- EU Anti-Corruption Report methodology: Provides framework for assessing systematic corruption risks
- EU Financial Instruments
- EU pre-accession funds (IPA III) are subject to rule of law conditionality under Regulation 2021/1529
- European Bank for Reconstruction and Development (EBRD) anti-corruption policies apply to potential EXPO-related financing
- Potential future EU infrastructure funding requires compliance with EU procurement and transparency standards”
3.6. Institutional Failures and the Need for Enhanced BIE Oversight
The pattern of legal, regulatory, and procurement anomalies documented in this notice—while deeply concerning in themselves—also reflects what multiple international governance assessments describe as conditions consistent with *state capture*.
Although “state capture” is not a formal legal term under the BIE Convention or UNCAC, it is widely recognized by institutions such as the World Bank, OECD, and European Commission to describe circumstances where formal laws and administrative processes are systematically manipulated to benefit narrow private interests, undermining public accountability and rule of law.
In such environments, the usual domestic checks and balances may be insufficient to ensure compliance with internationally accepted standards of transparency, safety, and financial stewardship. This underscores the necessity of heightened international supervisory engagement, particularly by institutions such as the BIE that coordinate large-scale projects involving substantial public expenditures and significant international reputational interests.
The BIE’s supervisory mandate becomes especially critical under these circumstances, as documented institutional failures at the domestic level create both the need and the justification for enhanced international oversight to protect the integrity of the World Exposition movement.
3.7 OECD Anti-Bribery Convention: While Serbia is not a signatory, key international partners including EU member states, the United States, and Japan are legally bound to investigate and prosecute bribery of foreign public officials in international business transactions. This creates potential legal exposure for international companies participating in EXPO contracts awarded without transparent procedures, as well as obligations for signatory countries to investigate suspicious transactions involving their nationals or companies.
III. IMMEDIATE RISKS AND CONSEQUENCES
- Safety Risks: The suspension of construction safety requirements, viewed in the context of the recent Novi Sad tragedy, creates an imminent risk of loss of life.
- Financial Risks: The absence of procurement controls and oversight mechanisms creates conditions for the misappropriation of up to €18 billion in public funds.
- Environmental Risks: The bypassing of environmental assessments threatens irreversible damage to critical infrastructure and ecosystems.Reputational Risks: The association of the BIE with documented corruption and safety violations poses severe risks to the institution’s credibility and the EXPO movement generally.
- Legal Risks: Under Article 34 of UNCAC, contracts procured through corruption are subject to annulment. While the BIE’s role is supervisory and it does not have direct operational control over host country activities, failure to act on credible evidence of corruption, safety violations, or regulatory breaches could result in significant reputational and institutional risks. Such inaction may undermine the BIE’s legitimacy, invite scrutiny from member states and international bodies, and weaken the integrity of the World Expo movement. The BIE’s proactive oversight and coordination with member states are essential to mitigate these risks and uphold international standards.
IV. REQUESTS FOR BIE ACTION WITHIN ITS SUPERVISORY MANDATE
- Recognizing the BIE’s role as a supervisory and coordinating body, we respectfully request that the BIE:
Promptly initiate consultations with BIE member states to explore the establishment of an independent monitoring mechanism for EXPO 2027 Belgrade;
- Facilitate the formation of an international expert panel comprising specialists in law, finance, construction safety, and environmental protection to conduct a comprehensive assessment of compliance with international standards;
- Engage with Serbian authorities through the BIE’s coordinating mandate to request:
- Restoration of full application of public procurement laws;
- Establishment of independent oversight mechanisms;
- Compliance with all safety and environmental regulations;
- Full transparency regarding all contracts and expenditures;
- Enhance civil society participation by supporting the development of formal monitoring channels that enable meaningful citizen oversight of EXPO preparations;
- Coordinate with member states to review the findings of the expert assessment and consider appropriate measures, including the potential suspension of recognition, should compliance not be achieved within 180 days.
- Submit this matter to the BIE Executive Committee and General Assembly for formal consideration and collective decision-making regarding necessary actions.
- Further, we request that the BIE:
- Coordinate with relevant international organizations (European Commission, OECD, UNODC) to ensure comprehensive oversight;
- Facilitate technical assistance to Serbian authorities to achieve compliance;
- Establish regular reporting mechanisms to member states on compliance progress;
- Enable ongoing civil society monitoring through formal channels supporting the BIE’s supervisory role.
V. SUPPORTING THE BIE’S MANDATE THROUGH INTERNATIONAL SCRUTINY
- Recognizing that the BIE depends on member state cooperation to fulfill its supervisory mandate, we simultaneously:
- Formally notify all official delegates of BIE member states of the concerns raised in this notice and provide them with all relevant documentation, to ensure comprehensive awareness and facilitate informed deliberation and decision-making within the BIE governance framework;
- Request member states to support enhanced BIE oversight and monitoring capabilities;
- Call upon member states to consider collective action should Serbian authorities fail to address documented violations;
- Encourage international expert participation in any assessment or monitoring mechanisms established by the BIE.
- Civil Society’s Role in Supporting International Oversight This notice demonstrates the vital role of civil society in:
- Providing documented evidence to support international oversight bodies;
- Enabling transparent monitoring that strengthens the BIE’s supervisory capabilities;
- Facilitating accountability mechanisms that serve the public interest;
- Supporting the integrity of international institutions through informed participation.
VI. RESERVATION OF RIGHTS
- The undersigned reserve all rights to:
- Pursue legal remedies in appropriate forums
- Submit complaints to relevant international bodies
- Publicize the BIE’s response or failure to respond
- Take all necessary actions to protect the public interest
VII. CONCLUSION
- This notice places the BIE on formal notice of serious, credible, and documented violations of law associated with EXPO 2027 Belgrade. From the date of receipt of this notice, the BIE cannot claim lack of knowledge regarding these matters.
- The evidence presented demonstrates a textbook case of state capture, where the machinery of government has been systematically corrupted to serve private interests at the expense of public welfare. This represents not merely isolated incidents of corruption, but a comprehensive subversion of democratic governance and rule of law.
- The integrity of the World Exposition movement and the safety of millions of potential visitors depend upon the BIE’s prompt and decisive action. History has shown that international organizations that fail to act upon credible evidence of corruption suffer lasting damage to their legitimacy and effectiveness.
- We remain available to provide any additional information or documentation that the BIE may require.
- We have endeavored to ensure factual accuracy in this notice. Should any factual errors be identified, we welcome corrections and will issue appropriate clarifications. Our focus remains on the documented pattern of violations rather than any individual disputed fact.
Respectfully submitted,
ANNEXES – REFERENCE DOCUMENTS
Annex A: Primary Legal and Institutional Documents
- Special Law on EXPO 2027 – Serbian Official Gazette (Official Gazette of the Republic of Serbia No. 92/2023)
- Serbian Academy of Sciences and Arts Environmental Warning (February 2025) URL: https://radar.nova.rs/drustvo/expo-opasan-po-zivotnu-sredinu/
3. Fiscal Council Report on Financial Risks (2024)
- Center for European Policies – Belgrade EXPO 2027 Study (January 2024) URL:
https://cep.org.rs/wp-content/uploads/2024/01/brief_n._11_belgrade_expo_2027_milinkovic_0.pdf
Annex B: Investigative Reports and Civil Society Analysis
- Transparency Serbia – No Public Procurement for EXPO 2027 (November 2024)
2. Transparency Serbia – Special Law Analysis (PDF)
URL: https://www.transparentnost.org.rs/images/dokumenti_uz_vesti/Poseban_zakon_EXPO.pdf
3. Ministry of Space – Analysis of EXPO 2027 Legal Framework
4. Serbia-business.eu – Procurement Contracts and Transparency Concerns
Annex C: Media Investigations
- NIN Magazine – Law on Unrestricted Disposal of Public Money (2024)
2. Vreme – EXPO 2027 Lex Specialis is Legalized Corruption (2024)
URL: https://vreme.com/komentar/expo-2027-lex-specialis-je-legalizovanje-korupcije/
3. Nova.rs – Seven Firms Already Got EXPO Jobs (2024)
- Direktno.rs – EXPO 2027 Costs and Corruption (January 2025)
URL: https://direktno.rs/vesti/drustvo-i-ekonomija/612587/expo-2027-troskovi-korupcija.html
5. Forbes/N1 – Budget Analysis and Safety Violations (2024)
Annex D: International Assessments and Opposition Documents
- Citizens’ Petition for EXPO Cancellation – 119,000+ signatures (March 2025) Reference: KreniPromeni
URL: https://peticije.kreni-promeni.org/petitions/stop-korupciji-otkazi-expo
- Opposition Formal Request to BIE (March 2025) Reference: Lawyer Monthly Coverage
3. European Commission Serbia Progress Reports
URL: https://neighbourhood-enlargement.ec.europa.eu/enlargement-policy/serbia_en
4. Radio Free Europe – Land Deal Investigation (2024)
URL: https://www.slobodnaevropa.org/a/koliko-kosta-expo-zemljiste-srbija/33157905.html Note: All URLs were active and accessible as of the date of this notice. Should any link become inactive, alternative sources for these documents can be requested through the contact information provided.
CERTIFICATE OF SERVICE
We hereby certify that this notice is being served upon the BIE via certified international courier service requiring signature confirmation.
DISTRIBUTION SCHEDULE
Primary Service:
- BIE Secretary General (via certified courier)
- BIE Executive Committee Members
- All BIE Member State Delegations
Courtesy Copies:
- European Commission, Directorate-General for Neighbourhood and Enlargement
- United Nations Office on Drugs and Crime (UNODC)
- Organisation for Economic Co-operation and Development (OECD)
- Transparency International
- European Bank for Reconstruction and Development
- European Investment Bank
- Council of Europe
- Relevant Diplomatic Missions in Belgrade
Date: July 5th, 2025
Place: Belgrade, Republic of Serbia
ADDENDUM: CORRECTIONS AND CLARIFICATIONS
Date Added: July 9th, 2025
Section 2.6 – Novi Sad Railway Station Tragedy: Originally stated: “15 fatalities” Corrected to: “16 fatalities” The 16th victim died on March 21, 2025, from injuries sustained in the November 1, 2024 collapse.
This correction is made pursuant to Section 8.5 of this notice in the interests of factual accuracy and respect for all victims. The fundamental allegations and requests for BIE action remain unchanged.
Date Added: July 19th, 2025 Section 2.9
Originally listed URL: https://www.slobodnaevropa.org/a/ekspo-2027-zemljiste-surcin-pkb/32867848.html
Corrected URL: https://www.slobodnaevropa.org/a/koliko-kosta-expo-zemljiste-srbija/33157905.html