KOMF has submitted a contribution to the Draft Concept Document on the Law on Preschool Education in the framework of the public consultation process. 

KOMF considers that the current law on pre-school education drafted in 2006 is not in line with the policies, practices and standards of developed countries in terms of child protection in pre-school institutions. The law does not define the establishment and implementation of the Child Protection Policy at preschool institutions as a key tool to ensure a safe and protective environment for children. Child Protection Policy is an internal policy for pre-school institutions developed to ensure the highest standards of behaviour and professional practices so that children are protected and safe in pre-school institutions. 

KOMF proposes that the law should foresee drafting and implementation of a Child Protection Policy at preschool institutions which:

  • Provides clear guidelines to recognise the forms and symptoms of abuse
  • Establishes a concrete and effective system for the prevention and protection of children from harm
  • Establishes fast and effective response and reporting system in case of suspicion or eventual abuses
  • Guarantees periodic training’s for the purpose of their awareness as well
  • Ensures monitoring and continuous review of policy implementation within the pre-school institution


In any country of the world, including Kosovo, children are abused or neglected. Very often the abuser is someone close to the child, or even someone within the institution who has the duty to take care of and protect the children. Currently, pre-school institutions in Kosovo do not have a Child Protection Policy, therefore they do not have a system for child prevention and protection, nor an internal reaction and reporting system. Therefore, child protection policies will include preventive actions to minimise the risk to children and to establish response actions in order to identify, report and address incident cases.

Kosovo should ensure that pre-school institutions have a Child Protection Policy to show its commitment to child protection. Additionally, this Policy will ensure that:

  • Children will be protected from abuse, exploitation and neglect by guardians, educators, and those who have access to their personal information and/or who have contact with children.
  • Personnel within preschool institutions will be protected. Information on child protection and actions to be taken in cases of childhood symptoms or cases of ill-treatment will be added.
  • Safe recruitment of staff working in educational institutions.
  • The principles of the Convention on the Rights of the Child will be applied.

In the absence of a policy, each pre-school institution is most vulnerable to suspicion and abuse whether it is false or true.