174 Nyman-Metcalf and Papageorgiou/Implementation of rulings by regional courts genuine integration to show. It has been said to rather provide parameters for future integration than a proper inter-governmental forum in which to solve concrete issues.28 The weak implementation possibilities of the AU contributes to its limited role, which although growing has not changed dramatically since its inception. In an effort to enhance enforcement, the African Commission has increased possibilities in its Rules of Procedure to refer communications to the African Court if it considers that the state concerned has not complied with or is unwilling to comply with its recommendations.29 The Commission can also refer serious and massive human rights violations to the Court.30 However, like in the European system, the development is toward the political organs of the AU monitoring enforcement.31 The AU’s Human Rights Strategy identifies among its strategic objectives the importance of ensuring effective implementation of human rights instruments and decisions. The Strategy’s 2012-2016 action plan called for strengthening the collaboration on the implementation of findings of African human rights bodies.32 The African human rights system is interesting in a global comparison as it emphasises the collective rights of peoples as well as those of individuals and it is the strongest on developing actio popularis to permit groups to support protection of human rights. Before the establishment of the Court, the Commission was vested with the competence to issue advisory opinions, rule on interpretation and deal with complaints from state parties and individuals, groups and NGOs. In theory, this should allow for a genuine actio popularis human rights monitoring system, including the possibility for those not directly concerned to complain about a human rights violation. In practice, there were many obstacles to strong enforcement of rights: The Commission had to reach unanimous decisions, the violation had to be part of a systematic pattern of gross human rights violations and even if a case passed these hurdles, there were no effective enforcement mechanisms to ensure that the guilty state would change its ways.33 Views on the African human rights system set up through the African Charter vary between it being an expression of taking rights seriously to doubts about any effectiveness of the system. One of the criticisms 28 T Maluwa ‘Fast-tracking African Unity or making haste slowly?’ (2004) 51 Netherlands International Law Review (2004) 231. 29 African Commission’s Rules of Procedure, rule 118. 30 African Commission’s Rules of Procedure, rule 84. 31 Article 29(2) of the African Court statute stipulates that the Council of Ministers shall be notified of judgments and monitor execution on behalf of the Assembly of the AU. Article 30 of the statute states that States parties undertake to comply with the judgment in any case to which they are parties within the time stipulated by the Court and to guarantee its execution. See M du Plessis ‘Implications of the AU decision to give the African Court jurisdiction over international crimes’ Institute for Security Studies, Paper 235 (June 2012) 2. 32 Guidelines on the Role of NHRIs in Monitoring Implementation of Recommendations of the African Commission on Human and Peoples’ Rights and Judgments of the African Court on Human and Peoples’ Rights (2016) 7. 33 Nowak (n 15 above) 203–214.