Who Does the Malta Women’s Lobby Think It Is? Recommendations Are Not Government Orders
By Ashley Galea
The Malta Women’s Lobby needs to tell the public the truth about what GREVIO actually is, because statements suggesting that the Maltese Government is somehow legally obliged to implement every recommendation issued through the Istanbul Convention monitoring process are misleading.
Following Malta’s second femicide prosecution in the past six weeks, the Malta Women’s Lobby has demanded that Government publish an “immediate, time-bound plan” to implement GREVIO’s recommendations.
The demands include tougher bail safeguards, sustained funding for shelters, mandatory specialist training for judges, police and prosecutors, education on consent, permanent reviews of femicides and improved data collection.
Those are political demands. The Lobby is perfectly entitled to make them.
But there is a very important question it should also answer:
Who do they think they are?
Because a recommendation is not a government order.
GREVIO – the Group of Experts on Action against Violence against Women and Domestic Violence – is an independent expert monitoring body. Its role is to evaluate how countries are implementing the Istanbul Convention and publish its findings.
It is not a court.
It does not issue judgments against governments.
It does not have the power to fine Malta.
And it does not possess some magical legal mechanism allowing it to order the Maltese Government to introduce whatever policies GREVIO recommends.
The Council of Europe itself explains that the monitoring system consists of two bodies: GREVIO, which evaluates implementation, and the Committee of the Parties, which adopts recommendations concerning measures to implement GREVIO’s findings and supervises those recommendations.
That distinction matters.
The Istanbul Convention creates obligations for states that ratify it. Malta ratified the Convention in 2014. But that does not turn every subsequent recommendation by an expert monitoring body into directly enforceable Maltese law.
The Committee of the Parties can adopt recommendations addressed to a state and supervise their implementation. The Council of Europe’s own rules describe these as recommendations concerning measures to be taken by the state concerned.
So when the Women’s Lobby tells Government to implement the recommendations, it should be clear about what it is actually asking for:
It demands that the Government act on the recommendations. It is not enforcing a court order.
And this is where the Lobby’s own history makes its latest statement even more extraordinary.
In March 2023, MaltaToday reported that the Malta Women’s Lobby said it felt ignored by Government because only three of its 30 proposals had been implemented.
Three out of 30.
Those 30 proposals came from the Lobby’s own 2022 election “Femifesto”, covering issues including the gender pay gap, abortion and domestic abuse. According to the Lobby, the three measures the Government took up were a femicide statute, paternity leave, and a gender equality strategy.
But here is the crucial point:
Those 30 proposals were the Women’s Lobby’s proposals. They were not 30 legally binding instructions the Government had to obey.
So perhaps the Lobby should explain the distinction.
When the Women’s Lobby makes 30 proposals to a government and only three are adopted, does it regard the other 27 as Government failures because Government refused to follow the Lobby’s wishes?
And when GREVIO makes recommendations following its monitoring process, does the Lobby now expect the public to believe that those recommendations automatically become legally enforceable government orders?
Who do they think they are, and where exactly does their supposed authority come from?
There is nothing wrong with campaigning.
There is nothing wrong with demanding political action.
There is nothing wrong with arguing that the Government should adopt particular measures.
What is unacceptable is blurring the line between a recommendation, a political demand and a legally binding obligation.
The distinction becomes even more important because the latest Women’s Lobby statement follows the publication of GREVIO’s latest Malta evaluation on 17 September 2026. The Council of Europe confirms that GREVIO’s role is to evaluate the measures taken by Malta and that the Committee of the Parties subsequently deals with recommendations arising from that monitoring process.
The Women’s Lobby is therefore perfectly entitled to say:
“We want Government to implement these recommendations.”
It should not, however, create the impression that GREVIO has issued legally enforceable orders that Malta has no choice but to obey.
That is not how the monitoring mechanism works.
And the distinction is not some obscure technicality.
It matters enormously when organisations seek to influence public policy, legislation and the criminal justice system.
The public deserves to know whether something is:
• a legal obligation under a treaty;• a recommendation from an international monitoring body;• a recommendation subsequently adopted by the Committee of the Parties;• a proposal made by an NGO;• or simply a political demand being made by an advocacy organisation.
They are not the same thing.
The Council of Europe itself describes GREVIO as an independent expert body and the Committee of the Parties as the political body responsible for adopting recommendations based on GREVIO’s reports.
That should be the end of the argument.
The Women’s Lobby can campaign as aggressively as it wishes for Government to adopt every recommendation.
But it should stop presenting recommendations as legally enforceable commands.
Because if an organisation that campaigns for changes to Maltese law wants to be taken seriously, it has a responsibility to be exceptionally precise about what the law actually says.
Another uncomfortable question hangs over the Lobby’s own record.
In 2023, it complained that 27 of its 30 proposals had not been implemented.
So what exactly was Government supposed to have done?
Treat an NGO’s election manifesto as binding legislation?
Of course not.
They were proposals.
Political demands.
Policy recommendations.
The Government was free to accept some, reject others, amend others and take different approaches.
The same basic intellectual honesty should apply when discussing GREVIO.
Recommendations are recommendations.
The Government can be pressured, criticised and politically challenged for failing to act on them.
But they do not become Maltese law simply because the Malta Women’s Lobby wants them implemented.
If the Lobby wants to campaign for change, let it campaign.
If it wants to demand action, let it demand action.
But if it wants to lecture the Government and the Maltese public about what the law requires, then it needs to start telling the truth about the difference between law, monitoring, recommendations and political demands.
Because on an issue this serious, the public deserves facts rather than advocacy dressed up as legal authority.