Identity Provisions in Agreements: Medicine that Cures or Kills?

Europe's Futures

Ioannis Armakolas, PhD (Cantab), is a Europe’s Futures Fellow at the IWM (2020-21). He is Assistant Professor at the University of Macedonia and Senior Research Fellow & Head of the South-East Europe Programme at the Hellenic Foundation for European and Foreign Policy (ELIAMEP). He also edits the journal ‘Southeast European and Black Sea Studies’ published by Routledge. 

The Prespa Agreement signed in June 2018 has been hailed as the most hopeful development for Southeast Europe in several years. For many it signalled a possible new era of renewed efforts for the stabilisation, reform and full integration of the Western Balkans in Western institutions, and especially the EU. Interestingly, the agreement was also celebrated for resolving in a creative way the complex identity component, which was at the core of the name dispute between Athens and Skopje. Three years on, the political circumstances have changed. In North Macedonia, on the heels of ratification of the Prespa Agreement and the country’s full membership to NATO, Zoran Zaev’s SDSM successfully competed in the July 2020 elections to win another tenure with its coalition partner DUI. But the reignited dispute with Bulgaria and the still uncertain start of accession negotiations, together with some failings in the domestic policy scene, has turned the political mood sour. In Greece, only four months after the ratification of the agreement, elections brought to government New Democracy, a party that was fierce opponent of the agreement, while in opposition. Overall, after the first period of enthusiasm, uncertainty and scepticism has been instilled in the process of implementing the Prespa Agreement (Armakolas, Petkovski and Voudouri 2020). 

However, in that context of the waning enthusiasm for the implementation of the agreement, it is important to examine the evolution of the celebrated identity provisions and contemplate the political significance of this difficult compromise and the lessons to be learned for other disputes. The question is of significance for the settlement of other disputes in the region. As European integration advances in the Western Balkans questions of identity, culture and historical interpretation will increase in significance. One cluster of reasons has to do with the numerous interlocking identity disputes that are linked to the violent collapse of the Yugoslav state, with the unsettled nature of political relations and unreconciled nations and national narratives. Another reason is because, these previously peripheral questions in European integration, have been forced into the conditionality agenda. Greece’s successful instrumentalisation of EU enlargement to tackle such questions (Armakolas and Triantafyllou 2017) has probably elevated this agenda to a higher level. And the recent Bulgarian blocking of North Macedonia’s accession talks purely on questions of identity and historical narratives shows that member states are determined to follow this path also in the future. Similarly, it is important to understand the dynamics of creative ambiguity, which was an approach adopted for reaching the Prespa Agreement. This is because creative ambiguity has been deemed central in EU’s conflict resolution efforts, including the mediation efforts in the Serbia-Kosovo dispute (Bieber 2015; Kartsinaki 2020; Troncota 2018). 

Prespa Agreement’s ‘Elephant in the Room’: Creative ambiguity, its promise and limits

The great innovation of the Prespa Agreement was that it managed to address the ‘Elephant in the Room’, the complex and sensitive identity issues that were at the heart of the diplomatic dispute between Greece and North Macedonia. In essense, the Prespa Agreement allowed both sides to find their own ‘space’ in the text, depending on their respective sensitivies. The most crucial provisions of the agreement (e.g. Article 7) were specifically designed for the two sides to reach an agreement without being left disenchanted and with a feeling of national embarassment. Both sides introduced in the text of the agreement elements satisfying their own ‘identity needs’.

For North Macedonia, it was important that the agreement included provisions about the Macedonian language and nationality, both issues in which Skopje insisted and it had stipulated as informal ‘red lines’ in the negotiations. For Greece it was important that heritage and historical interpretation questions were tackled head on. For Greek negotiators it was very important that “North Macedonia has given up its claim on the ancient Macedonian history, which is one of the central tenets of Greek national identity, thus fully recommitting itself to its Slavic heritage.” (Armakolas and Petkovski 2019, 3) Greece also achieved to include in the agreement a provision classifying Macedonian among the Slavic languages and clearly separating it from ancient Macedonia, a point that was meant to reassure those in Greece who did not feel comfortable with the recognition of a language named ‘Macedonian’ by Athens. Overall, the agreement attempted to “delimit the meanings of the terms ‘Macedonian’ and ‘Macedonia’ enabling both sides to find their own space for use, but also to learn how to develop in the future their respective identities in non-exclusive ways.” (Armakolas and Petkovski 2019, 3)    

For the opposition in the two countries things were from the outset straight-forward. Both North Macedonia’s VMRO-DPMNE and Greece’s New Democracy felt compelled to oppose the agreement. For the former because it had invested for years in nationalist discourse and hostility towards Greece and remained bitter about the way that the decade-long rule of PM Nikola Gruevski was ended by the SDSM-DUI alliance. For New Democracy, the party that was in government in Greece when the name dispute started in the 1990s, because political trust with the government had hit rock bottom. The Greek government of the time was made up of parties SYRIZA and Independent Greeks, whose fortunes were tied to the populist anti-austerity social mobilisation and the fierce opposition to parties implementing the bail-out agreements. During the period of Greece’s severe economic crisis polarisation and social division reached record levels. New Democracy was unwilling to ease up pressure on the SYRIZA-led government, especially on an issue that was very sensitive to its own voters (Armakolas and Siakas 2021). The identity provisions gave both VMRO-DPMNE and New Democracy the necessary ammunition to hit hard on the two leftist parties that struck the deal. In fact, for New Democracy the identity provisions (the so-called ‘ethnicity and language’ issue) offered the silver bullet argument for opposing an agreement that was in fact in line with the official Greek position and one that included far-reaching provisions that had not been secured by Greek negotiators in any previous round of negotiations. 

That identity provisions were necessary, but also a potential ‘hot potato’ for the two governments became clear early on. For example, the use of the adjective ‘Macedonian’, which constitutes the core of the compromise but simultaneously has identity implications, remained contested even after the signing of the agreement. Creative ambiguity allowed the problem to be practically overcome for a while. But it soon became clear that it was still a contested issue for both parties. The Greek side under SYRIZA government appeared to accept the term, but it was clear that for Greek public discourse, after thirty years of resisting the term, this was still unpalatable. Under SYRIZA bilateral agreements that were drafted also in Macedonian language were signed. Moreover, probably for the first time in decades the term Macedonian language appeared in official documents of the Greek state, as for example when the National Intelligence Agency of Greece advertised the hiring of personnel and included Macedonian as one of the preferred languages to be spoken by applicants. But even during SYRIZA government the adjective ‘North Macedonian’, to describe people or things from North Macedonia, was in frequent use and was considered by many Greek officials as more fitting. 

In contrast, in North Macedonia officials almost took offense whenever internationals would use the term ‘North Macedonian’ considering that the agreement makes clear that such term is ungrounded and ‘Macedonian’ or ‘of North Macedonia’ should be used instead. Even during the period of enthusiasm with the Prespa Agreement, PM Zoran Zaev and his close associates were publically the most vocal supporters of the idea that the country should get used to the idea of the new name and the rest of the provisions and should actively try to incorporate in everyday talk and public discourse. When problems started to arise, especially in the context of the stalled EU accession process and some domestic policy failures, Zaev received criticism for ‘overdoing it’ in the implementation of provisions that had to do with identity and symbols. 

Moreover, not long after the ratification of the agreement, the two governments appeared to have a thinly-veiled disagreement over identity provisions.  The two sides issued official instructions for media and state organisations in the broader sense - in the Greek case including insitutions under the jurisdiction of Ministries, such as universities, sports and cultural associations The instructions were supposed to explain the use of terms ostensibly settled by the Prespa Agreement. But each side focused on issues of its own concern, highlighting or overlooking different aspects accordingly. The side of North Macedonia insisted on demonstrating that the term ‘North Macedonian’ is incorrect and improper; it also adopted an expansive understanding of the adjective ‘Macedonian’ insisting that it was the appropriate term to describe all things associated to the newly named country, except its official organs and other public entities (Government of the Republic of North Macedonia 2019a; 2019b). 

On its part, the side of Greece cautioned against the use of the adjective ‘Macedonian’ and explained that the correct formulation is ‘of North Macedonia’. It also urged all delegations from Greece in international fora to react boldly in cases when the adjective ‘Macedonian’ is used (Ministry of Foreign Affairs of the Hellenic Republic 2019). It was clear that the two sides had not fixed a joint understanding of the use of terms for all cases and instances, which, if communicated as such, would clarify issues once and for all. Instead, the instructions not only left issues unaddressed, but even allowed readers to draw diverging conclusions about the use of controversial terms.

But the goodwill and trust that had been built between the two governments, and especially the leaders who have reached the agreement, meant that this disagreement was not allowed to slow down the process of building bilateral ties. In essense, the two sides agreed to disagree on the issue and pressed on with the implementation of the agreement. Not long after this disagreement over the adjective, the Greek PM Tsipras made the historic visit to North Macedonia, where more bilateral agreements were signed in a single day than in the previous three decades of diplomatic relations of the two countries (Armakolas, Petkovski, Voudouri 2020).

Three years on: Identity provisions between necessity and peril

Three years on, identity provisions remain a source of friction and a key resource for those still opposing the agreement. In Greece, the conservative New Democracy government tries to walk on a tightrope: it has accepted the agreement as a de jure international obligation and a de facto political reality. It even tries to cautiously rely on the agreement to strengthen relations with North Macedonia. At the same time, it maintains a low key opposition to the identity provisions, reminding on every occasion its own rejection of the agreement when in opposition. But it is clear that this is a token reminder that is necessary for not alienating its own voters. At the same time though, even those government officials who accept the benefits of the agreement, do not feel very comfortable to make full use of the identity provisions. Some also still find the use of the new name hard to digest. And then there are the more hard-liners in the party, the forces that pressure the government to break the policy of good relations with North Macedonia. For them identity provisions are a constant reservoir of discontent. The identity provisions and the agreement in general are also rallying point for those conservative forces to the right of Greece’s PM Mitsotakis in their effort to re-shape the discourse and political practice in a more nationalist fashion.

In North Macedonia the issue is even more acute. Securing Macedonian identity was one of the two main objectives promoted by the Zaev government as arguments for advocating the Prespa deal – the other being membership in Western institutions. But the latter objective has stalled after the initial success of entering NATO and North Macedonia has still not managed to start EU accession negotiations. Ominously, the blocking of accession negotiations has brought back to the centre of political bickering identity questions. In spite of Zaev government’s expectations of identity guarantees from the Prespa Agreement, it is specifically issues of identity, history and heritage that are at the centre of Bulgaria’s demands from Skopje. 

North Macedonia’s opposition VMRO-DPMNE decries all the concessions made on identity issues for an elusive promise of European integration. It considers that they have led to a slippery slope that will bring further major concessions in the future, and that the door for all these was opened with the Prespa Agreement. And even at the level of society, popular frustration with the governmental record and the failure to open EU accession negotiations diminishes motivation for acceptance of the more painful Prespa provisions. The official name North Macedonia is not uniformly used in media and public discourse. As a matter of fact, quite the opposite is the case. As frustration builds, few feel compelled to use the new name as they did in the first post-Prespa period, while the opponents of the agreement have refused to use it all along. 

Overall, identity provisions are possibly an unavoidable feat for addressing the remaining complex and multifaceted disputes in Southeast Europe. But they will tend to include a measure of creative ambiguity to bring compromise closer and to satisfy parties in an agreement. And creative ambiguity typically works better when solutions are designed than when they are actually implemented. At the same time, these provisions will tend to be a source of friction in national constituencies, they will tend to offer ammunition to political and societal opponents to the agreements, and they will also potentially generate political tensions between the signatories, no matter how much goodwill they have built. 

What is then to be done?

There are no silver bullet solutions because the modalities that will work are likely to be case-specific, bespoke arrangements to address the particular needs for implementation of specific agreements. Thus, the first and foremost that is required, a kind of no-brainer of course, is political attention by signatories and their international backers. Parties and other stakeholders need to be ready to devise solutions that will prevent the misuse of identity provisions or limit their negative consequences. One such solution is for stakeholders, aware of the forthcoming difficulties, to design already from the outset a positive agenda for building societal trust. Such agenda should be comprehensive and detailed, containing concrete steps, milestones and planned outcomes. The agenda will aim to offset the negative side effects of identity provisions and to build constituences of support. It should also boldly aim to facilitate the building of societal bridges between the two sides, with explicit ambition to increase trust. For all these, governments engaged in negotiations to settle long-standing disputes should receive political support and expert advice by the EU and the US. The latter two offer political support and mediation for resolving the core elements of the disputes. But they should pay more attention and offer expert advice also on the post-agreement dynamics of the identity provisions. 

Further, governments and their international backers should seek the active involvement of civic agents of change who can become the vanguard of this future-oriented endeavour. Grassroots initiatives of youth, multiple, scattered and usually lacking political support, should be aided and funds, typically in short supply, be made more available. IPA and other cross-border EU funds should facilitate dispersed youth and civil society initiatives. But the bureaucratic machinery and programming of EU bodies are notoriously slow, and thus could not be the immediate answer to the problem. Unless advance planning is made to introduce cross-border societal trust building in the relevant budget cycles; an advisable but not always feasible prospect. This is where international private and Western countries’ financial assistance could be fitting. They are faster to adjust in their programming and easier to direct funds, not to generic civil society, but specifically to cross-border groups and initiatives for trust and reconciliation. 

In addition, academic and scientific cooperation in the context of relevant European programmes should be stimulated. There is no guarantee that scholarly cooperation will be devoid of national interest considerations. But scientific research will always be a safer bet for positive influence in public discourse than pseudo-scholarship that abounds in Balkan media. The Macedonia name dispute is a good case in point. Media on both sides of the dispute have given ample space to amateur historians and scientists who poisoned public discourse with nationalist theories that most professional scholars consider biased and unscientific. And once public opinions were formed in an exclusivist and nationalist way, to change them was an uphill struggle. Even professional scholarship that was not tainted by nationalism did not have the ability and instruments to challenge rigid popular stereotypes.  

Lessons for future agreements

What has become clear is that identity provisions are too important politically and too ambiguous or elusive by nature to be expected that they will be settled once and for all through the legal provisions of an international agreement. Other, less sensitive and controversial provisions are served well by legally binding texts and their bureaucratic implementation thereof. But identity issues require creative policy making post-agreement and active engagement by agents of change at both the top and the grassroots level.   

Moreover, identity provisions and creative ambiguity serve the short term purpose of reaching an agreement, but can be highly detrimental to long-term stability unless genuine societal trust and reconciliation is resolutely put into the policy agenda. However, this will always be an unpopular endeavour. Political leaderships, sensitive to political and electoral cost, will be unwilling to enter a ‘second round’ of unpopular moves. And it could be too much to ask for. Even reaching the initial agreement requires courageous leadership that will be vulnerable domestically, regardless of the international praise, as the cases of Zaev and Tsipras have amply shown. 

To conclude, there are two courses of action that could be contemplated to rectify this problem; and ideally both of them should be implemented in any given case. One is that leaders negotiating agreements should ensure that these are comprehensive enough to contain a full-fledged positive and conciliatory agenda, comprising roadmaps, milestones and well-thought off strategies for implementation of sensitive identity provisions. Relying on the work of government-appointed expert commissions will not suffice, as the experience of both the Greece-North Macedonia and the Bulgaria-North Macedonia commissions has shown. Leaders, and their international backers, should avoid the temptation to leave this part for later. The ‘later’ will likely never be as easy as politicians who reach an agreement think. They had better address this seemingly second order problem together with swallowing the bitter pill of the main agreement. They will carry the political cost anyway. And they stand better chances to pull through the difficulties of implementation if they had made some difficult-to-digest decisions early on. 

The second course of action is to empower civic actors, grassroots groups, youth initiatives and cooperation by epistemic communities, who are willing to do groundwork for building cross-border trust and facilitate reconciliation. These grassroots agents of change will function as proxy for societal support, which is slower and more complicated to generate. Grassroots civic activity will often do the legwork for governments that must be seen by voters to maintain their ‘patriotic credentials’ intact. And they will do so often without political support, for exactly the same reason. Such civic work then can be made possible by the comprehensive provisions in the agreement and through the support of the EU and the US. 


Armakolas, Ioannis and Petkovski, Ljupcho. “Blueprint Prespa? Lessons learned from the Greece-North Macedonia agreement.” Friedrich-Ebert-Stiftung – Skopje Office. June, 2019.

Armakolas, Ioannis and Triantafyllou, Giorgos. “Greece and EU enlargement to the Western Balkans: understanding an ambivalent relationship.” Southeast European and Black Sea Studies, volume 17, issue 4 (2017): 611-629.

Armakolas, Ioannis, and Siakas, George. “‘Why Did It Take so Long?’ Exploring Greek Public Opinion as an Obstacle to the Settlement of the Macedonia Name Dispute.” Nationalities Papers (2021): 1–20.

Armakolas, Ioannis, Petkovski, Ljupcho and Voudouri, Alexandra. “The Prespa Agreement one year after ratification: from enthusiasm to uncertainty?.” Eurothink – Center for European Strategies. February, 2020. 

Bieber, Florian. “The Serbia-Kosovo Agreements: An eu Success Story?.” Review of Central and East European Law, volume 40, issue 3-4 (2015): 285–319.

Government of the Republic of North Macedonia. “Prespa Agreement - Media Guidelines.” February 23, 2019a.

Government of the Republic of North Macedonia. “Q & A on Prespa agreement.”  February 23, 2019b.

Kartsonaki, Argyro. “Playing with Fire: An Assessment of the EU’s Approach of Constructive Ambiguity on Kosovo’s Blended Conflict.” Journal of Balkan and Near Eastern Studies, volume 22, issue 1 (2020): 103-120.

Ministry of Foreign Affairs of the Hellenic Republic, Ελληνική Δημοκρατία, Υπουργείο Εξωτερικών: Σχέσεις Ελλάδας-Βόρειας Μακεδονίας – Εφαρμογή της Συμφωνίας των Πρεσπών ως προς το όνομα και τις ορολογίες της γειτονικής χώρας. Athens, 15.2.2019

Troncotă, Miruna. “‘The association that dissociates’ – narratives of local political resistance in Kosovo and the delayed implementation of the Brussels Agreement”, Southeast European and Black Sea Studies, volume 18, issue 2 (2018): 219-238.