What changed

Follow-up to the European Parliament non-legislative resolution on the transparency and accountability of non-governmental organisations funded from the EU budget

PA_NonLeg

Rapporteur : Markus PIEPER (EPP / DE)

SUGGESTIONS

Reference number: 2023/2122 (INI) / A9-0446/2023 / P9_TA (2024)0036

The Committee on Foreign Affairs calls on the Committee on Budgetary Control, as the committee responsible, to incorporate the following suggestions into its motion for a resolution:

Date of adoption of the resolution: 17 January 2024

– having regard to its resolution of 8 March 2022 on the shrinking space for civil society in Europe,

Competent Parliamentary Committee: Committee on Budgetary Control (CONT)

A. whereas Article 11 of the Treaty on European Union (TEU) and Article 15 of the Treaty on the Functioning of the European Union (TFEU) requires the EU institutions to conduct their work as openly and transparently as possible in order to promote good governance and ensure the participation of civil society; whereas the European Economic and Social Committee, composed, inter alia, of representatives of civil society organisations and exercising advisory functions, should assist Parliament, the Council and the Commission, in line with Article 300(1) TFEU;

Brief analysis/ assessment of the resolution and requests made in it:

B. whereas, under the Neighbourhood, Development and International Cooperation Instrument – Global Europe (NDICI), ‘civil society organisations’ (CSOs) are defined as a wide range of actors with multiple roles and mandates, which may vary over time and across institutions and countries; whereas CSOs include all non-state, not-for-profit independent and non-violent structures through which people organise the pursuit of shared objectives and ideals, whether political, cultural, religious, environmental, social or economic, which operate at local, national, regional or international levels and which comprise urban and rural, and formal and informal organisations;

Transparency and accountability of non-governmental organisations (NGOs) funded by the European Union (EU) budget has been a topic of interest for the Union institutions and is a guiding principle for the Commission in how the EU budget is spent, in line with existing legal requirements.

C. whereas, in Article 2(48) of its proposal of 16 May 2022 for a regulation of the European Parliament and of the Council on the financial rules applicable to the general budget of the Union (recast) (COM(2022)0223), the Commission defines a ‘non-governmental organisation’ (NGO) as ‘a voluntary, independent from government, non-profit organisation, which is not a political party or a trade union’;

The current resolution reflects the European Parliament’s acknowledgement of the vital role played by NGOs in representing civil society and defending the rule of law and democratic values, fighting corruption and promoting human rights and democracy in EU and non-EU countries and the importance of ensuring that these organisations continue to be entitled to receive Union funding. Simultaneously, the European Parliament invites the Commission to guarantee more transparency and accountability for this type of organisation, by e.g. streamlining and simplifying procedures to allow funding for NGOs, ensuring that the Early Detection and Exclusion System (EDES) is fully operational and that only organisations respecting EU values receive Union funding, strengthening transparency and accountability along the funding chain, introducing further obligations for the disclosure of information, developing the user-friendliness of the Financial Transparency System (FTS) database and streamlining databases.

D. whereas interest representatives, including NGOs, should be subject to scrutiny, due diligence and transparency rules, in particular with regard to financing, with proportional criteria and non-cumbersome procedures, in particular for small NGOs;

Response to requests and overview of action taken, or intended to be taken, by the Commission:

E. whereas strengthening transparency requirements for legal entities, including NGOs, carrying out lobbying or advocacy activities with EU institutions should contribute to tracing foreign interference;

Streamlining and simplifying procedures to allow adequate funding for NGOs

F. whereas the Commission has strong mechanisms for the control of the expenditure of NGOs funded from the EU budget, among the strictest in Europe; whereas recent corruption allegations against Members and former Members of the European Parliament involved an NGO which was not registered in the Transparency Register;

The Commission agrees with the European Parliament and recognises the importance of NGOs in defending European and democratic values. The Commission further agrees that a balanced approach between requirements specifically for NGOs and facilitating their adequate and transparent funding needs to be ensured. For this purpose, as a rule, Union funding is awarded following transparent publicly open calls for proposals allowing all relevant applicants to submit a proposal. In the most relevant policy areas, such as under the Citizens, Equality, Rights and Values (CERV) programme, civil society organisations active in promoting and protecting the rule of law, fundamental rights and democracy at national, regional and local levels are encouraged to participate in calls specifically designed to build their capacity and sustainability. Support under the Neighbourhood, Development and International Cooperation Instrument – Global Europe (NDICI-GE) aims, inter alia, to protect human rights defenders in the most difficult circumstances and urgent situations. It recognises the need for assistance in particular to local human rights defenders and civil society, including through a dedicated mechanism to carry out their work unhindered. Under the instrument, grants may be directly awarded to human rights defenders to finance urgent protection actions and needs and to civil society organisations (paragraph 5).

G. whereas on 13 September 2023, the European Parliament amended its Rules of Procedure with a view to strengthening integrity, independence and accountability;

The Commission also understands the call to further simplify and streamline the funding procedures to allow smaller NGOs, including at local level, to apply and benefit from EU funding. To facilitate access to funding for smaller projects, the co-legislators agreed to introduce the very low value grants as a new category of grants as part of the political agreement on the Financial Regulation recast. Applicants for such grants, including NGOs, will need to supply fewer documents to the Commission, for example they will no longer need to complete a declaration on honour, and they will not have to demonstrate financial capacity to implement the action. Moreover, the greatest reduction in reporting for small beneficiaries can be achieved with greater use of simplified forms of financing, as these remove the need for financial reporting (paragraphs 7 and 41).

Importance of the role of NGOs in promoting and protecting human rights and democracy

The Commission provides regular training courses to all staff involved in grant management, including general training on financial rules and technical training on grant management. The Commission has, for the 2021-2027 programming period, introduced a single electronic procedure for all phases of the grant process in almost all funding programmes – thus simplifying procedures for staff and applicants, in particular by standardising the procedures and needed documents for applying across all programmes. In addition to the publicly available guidelines (such as the Annotated Model Grant Agreement), funding programmes also have the possibility to assist applicants or beneficiaries through technical assistance initiatives, training covering reporting and financial rules and by publishing simple and clear information, including FAQs on how to apply. Some programmes provide Programme Desks/Contact Points in Member States which can assist applicants directly (paragraphs 7 and 41).

1. Commends the essential role that NGOs and CSOs working for the promotion and protection of human rights, democracy and the rule of law play in societies around the world; highlights, in this regard, the crucial work of these organisations in promoting and defending human rights and democracy, combating all forms of discrimination, fighting for a clean, healthy and sustainable environment, informing individuals and groups, especially the most vulnerable, about their rights and standing up for them when those rights are violated, denouncing human and civil rights violations, promoting intercultural dialogue, civic engagement and public participation, countering disinformation and hate speech, collecting public interest information and holding governments and elected representatives accountable to citizens, and fighting corruption and impunity for human rights abuses;

Also, with the objective to streamline procedures and to increase transparency of Union funding, the Commission acknowledged the need for a harmonised definition of NGOs in line with recommendations from the European Parliament and the European Court of Auditors. A common definition for NGOs has been politically agreed as part of the Financial Regulation recast. The new definition will be reflected in the Commission documents, procedures and systems after the Financial Regulation recast enters into force (paragraphs 16 and 18).

2. Highlights the serious risks that people working for human rights NGOs face in their activities around the world, including threats against them and their families, intimidation and all forms of harassment, including through online channels and social media, abusive legal proceedings and prosecution, arbitrary detention, violence, torture, disappearances, killings and executions, which can force them into exile;

Ensuring that the Early Detection and Exclusion System is fully operational and that only organisations respecting EU values receive Union funding

3. Is alarmed by the fact that some governments in third countries, whose aim is to shrink civil society space and silence dissenting voices, have adopted legislation based, inter alia, on security, counter-terrorism and the fight against foreign interference, that imposes discriminatory obligations on human rights NGOs and their workers, stigmatises, restricts or bans their activities, including by closing these NGOs, freezing their assets, deterring their donors from contributing funds or depriving them from access to funding; believes that the EU should lead by example in this context;

The Commission agrees that only organisations which comply with the European Union (EU) values originating from the Treaty on the European Union and the EU Charter of Fundamental Rights should receive funding. For this reason, when implementing the budget, the Commission ensures at all stages (pre-signature, implementation, ex-post checks) that only organisations, including NGOs, and projects compatible with EU values receive support. As regards the pre-signature stage, the Commission implements rigorous selection processes and ex-ante checks based on objective criteria in line with the call conditions. The established checks are threefold. The Commission checks the existence of an exclusion situation, including the situation of being in a grave professional misconduct, which may capture behaviours contrary to EU values. Secondly, applicants to EU funds are already required to explicitly declare whether their organisation, the persons having powers of representation or decision-making or control, the beneficial owners or the persons who are essential for the award/implementation of the action are in one of the exclusion situations, including grave professional misconduct (which may include violation of EU values). Third country applicants established outside the jurisdiction of EU law also have to explicitly declare their compliance with general principles including fundamental rights and values. Additionally, depending on the policy areas of the programme, the Commission may also include specific eligibility criteria in calls for proposals for the projects to comply with and promote EU values and reject projects which do not comply with these criteria (point J and paragraphs 20, 28 and 33).

Transparency and accountability of human rights NGOs funded by the EU external action budget

The Commission recalls that it designed its internal control framework in line with Article 36 of the Financial Regulation and it ensures that the budget is implemented in compliance with the principles of effective and efficient internal control, pursuant to the principle of sound financial management. To prevent errors and irregularities before the authorisation of operations and to mitigate risks of non-achievement of objectives, ex-ante controls are systematically applied to each operation in line with Article 74 of the Financial Regulation. The Commission internal control design takes into account – amongst others – proportionality, costs of control, and ex-post checks and mitigation measures for identified weaknesses. In the Annual Activity Reports of all services, the Commission transparently reports on its assessment of internal control and mitigation measures regarding weaknesses identified by the Internal Audit Service, external audits, and/ or the European Court of Auditors (paragraph 23).

4. Underlines the importance of ensuring, as far as possible, transparent and accessible information on the beneficiaries, including NGOs, of EU external action funds dedicated to human rights and democracy support and to the related EU-funded projects which are implemented worldwide; recognises that NGOs have been calling for further transparency at EU level for years; acknowledges the risky and life-threatening conditions faced by some human rights defenders and NGOs in non-EU countries; believes, in this regard, that confidentiality and data protection must be ensured in order not to put them at risk;

In addition, based on the current Financial Regulation, the Early Detection and Exclusion System is already fully operational and applicable to persons or entities that receive Union funds in direct and indirect management which act as a participant, recipient or a capacity provider, regardless of the status of such a person or entity. Therefore, these persons or entities, including NGOs, may already be subject to EDES measures provided they fall within its scope. The Financial Regulation recast will further strengthen the EDES system by specifically adding as part of the exclusion criteria the ground “incitement to discrimination, hatred or violence against a group of persons or a member of a group or similar activities that are contrary to the values on which the Union is founded enshrined in Article 2 TEU” into the broader notion of grave professional misconduct. This will further reinforce the current set up (point J and paragraphs 20, 28, 33 and 46).

5. Welcomes the cessation of EU funding and the recovery of funds paid to a few organisations whose actions were contrary to EU values; calls on the Commission to continue its efforts to ensure that EU funds do not finance organisations that do not respect EU values as set out in Article 2 TEU; also calls on the Commission to develop more flexible strategies of supporting civil society actors in repressive environments, which have difficulties benefiting from assistance;

The recommendations stemming from the 2021 Commission Discharge have been addressed by the Financial Regulation recast as politically agreed, including the extension of EDES’ scope to shared management funds and funds disbursed under direct management with Member States (applicable as from 1 January 2028). The reinforcement of the system will lead to more effective and efficient exclusions in the future. As far as the publication of the list of excluded entities is concerned, the Financial Regulation envisages the possibility to publish the information on the exclusion to reinforce the deterrent effect of the measure. However, any publication cannot take place if there is a need to preserve the confidentiality of an investigation or of a national judicial proceeding if the publication would cause disproportionate damage to the person/entity to be excluded and in case of protection of personal data. The proportionality of a publication needs to be assessed on a case-by-case basis, taking into account the severity of misconduct, including aggravating factors on one side and the potential disproportionate damage to the person or entity, preservation of confidentiality of other proceedings or personal data (paragraph 50).

6. Calls for the EU and its Member States to be fully transparent about the allocation of funds to third countries for cooperation in migration matters, and to ensure that migration-related European funding, training or other forms of support to third countries neither directly or indirectly facilitate the perpetration of human rights violations, nor reinforce and perpetuate impunity for such violations; urges that any EU or Member State-funded migratory cooperation project or initiative be made subject to thorough and independent ex ante human rights impact assessments and monitoring throughout the project, and for the results of such assessments and monitoring to be disclosed to the European Parliament;

The Commission would like to clarify that internationally accepted audit standards (e.g., INTOSAI) and Regulation (EC) No 1049/2001 regarding public access to documents define audit reports of ongoing audits as confidential information that cannot be disclosed to third parties. Only once the procedure is finalised, can information be made available to third parties.

7. Calls on the Commission to improve the clarity and organisation of information and data available in the Financial Transparency System (FTS) on the beneficiaries of EU-funded projects, including in the field of human rights and democracy support; stresses that requiring beneficiaries to disclose all funding sources must take into account the situation of the countries and the environment in which they operate, in order to ensure that the publication of the information and data under the FTS does not put them at risk;

As regards access status for the European Anti-Fraud Office (OLAF), in line with Article 129 of the Financial Regulation, any person or entity receiving Union funds shall fully cooperate in the protection of the financial interests of the Union and shall, as a condition for receiving the funds, grant the necessary rights and access required for OLAF to comprehensively exert their respective competences. In the case of OLAF, such rights shall include the right to carry out investigations, including on-the-spot checks and inspections. The relevant provisions of Financial Regulation recast as politically agreed, applicable as from 1 January 2028, envisage interconnection of EDES with the data-mining and risk-scoring tool, to which OLAF will have access within the exercise of its competences. As a result, the data from EDES shall be included in the data-mining and risk-scoring tool (paragraph 51).

8. Recommends that the legal obligations on transparency and financial accountability be applied identically to all NGOs and other interest representatives benefiting from EU funding;

Transparency and accountability along the funding chain

9. Points out that NGOs receiving EU funding must be transparent about the funding received; notes that their work gives visibility to the EU’s support in different ways, through various communication channels, including official websites; underlines that these differences could sometimes also depend on the fact that, in some countries ruled by certain authoritarian and illiberal regimes and with reduced civic spaces, the dissemination of such information may put NGOs at risk; calls for the establishment of harmonised but flexible approaches to make EU funding for human rights and democracy support more visible to the public, while avoiding putting at risk NGOs that operate in precarious contexts;

In accordance with the provisions of the Financial Regulation, the Commission discloses information on recipients of EU funding implemented under direct management via the Financial Transparency System (FTS). The term ‘recipient’ means a beneficiary, a contractor, a remunerated external expert or a person or entity receiving prizes or funds under a financial instrument or implementing Union funds pursuant to point (c) of the first subparagraph of Article 62(1) of the Financial Regulation. The FTS goes beyond the scope of the requirements to enhance transparency by publishing the beneficiaries of EU funding implemented under ‘indirect management’ (paragraphs 21, 22, 39 and 42).

10. Denounces the use of organisations sponsored by third country governments (government-organised NGOs (GONGOs)) to spread disinformation and false narratives related, in particular, to human rights issues;

Financial support to third parties (FSTP) is a limited and effective way in which beneficiaries can implement EU funded actions. However, the Commission does not have a contractual relationship with such recipients of financial support – instead, it is the responsibility of the beneficiary to implement the financial rules correctly and with no margin for discretion, and this can be checked during ex-post and ex ante controls. It is not possible to record the recipients and amounts in the FTS as this information is not collected systematically. Collecting such information would add a significant additional burden to the beneficiaries of EU grants and would counteract the simplification agenda for access to EU funding that has been consistently demanded by stakeholders as well as the co-legislators. Given the rules in place that ensure sound financial management through the obligation to extend relevant conditions under the responsibility of the beneficiary also to FSTP recipients, putting additional micro-reporting requirements in place would not be proportionate. Rule compliance is controlled through cost-effective ex-post checks, reviews, and audits (paragraph 42).

11. Stresses that the funding by third countries of EU-based legal entities, including NGOs, carrying out lobbying or advocacy activities within the EU and aiming to influence the EU’s foreign policymaking, may at times expose these entities to malign external influences; believes that transparency requirements should not, however, stigmatise legitimate foreign funding; recalls, in this regard, the findings of its resolution of 1 June 2023 on foreign interference in all democratic processes in the European Union, including disinformation, and of 13 July 2023 on recommendations for reform of the European Parliament’s rules on transparency, integrity, accountability and anti-corruption, highlighting the risks of foreign interference and disinformation stemming from some NGOs funded by non-EU countries; calls for further reflection on the future strategy and approaches of the EU institutions to detecting and preventing risks of corruption and foreign interference in EU policymaking; highlights that in the context of recent corruption allegations against some Members and former Members of the European Parliament, an NGO not registered in the EU Transparency Register and whose stated purpose was to carry out advocacy activities in the human rights field, is suspected to have been used as a vector of foreign interference; considers that there is a public interest in knowing the financial sources, including non-EU funding, of all stakeholders active in the fields of lobbying or advocacy, while any measures in this regard need to be proportional, preventing any unintended limitations on fundamental rights;

The Financial Regulation recast as politically agreed strengthens transparency and accountability by widening the scope of transparency obligations to all methods of EU budget implementation, including shared and indirect management. Following the political agreement for the Financial Regulation recast, the Commission will make information on recipients of EU funds managed in all management modes (direct, shared, indirect and Resilience and Recovery Facility – type of instruments) available on a centralised website as from 2028. The recast also enhances consistency and coherence of data between Member States by creating an obligation for Member States to give the Commission access to relevant data on recipients of EU funds. In addition, it specifies that for shared management, "recipients" shall be understood as references to recipients, contractors, subcontractors and beneficiaries as referred to in sector-specific rules, and information for such recipients shall be published provided sector-specific rules require their collection and storage. As regards the transparency on the allocation of funds, according to the political agreement reached by the co-legislators, the list of compulsory data for publication includes the amount committed and, in case of a commitment with multiple recipients, the breakdown of this amount per recipient where available (paragraphs 21, 22, 38 and 39).

12. Welcomes the progress made in the use of the EU Transparency Register and is committed to continuing its work to expand the scope of the Register and strengthen the monitoring of the data it contains; points out that, as a general rule, annual financial data on the sources of funding, including EU grants and domestic and non-EU donations, of registered legal entities are made publicly available under the EU Transparency Register; stresses that, since 12 July 2023, the participation of ‘interest representatives’ as invited active guests at Parliament’s events is conditional on their prior registration in the EU Transparency Register, except if registration is likely to endanger an individual’s life or personal safety or the existence of the entities concerned or where other compelling reasons require confidentiality; recalls that the EU Transparency Register (Annex II) requires that NGOs provide their main sources of funding by category, including EU funds; stresses that the measures requiring NGOs to disclose all funding sources must take into account the situation of NGOs operating in countries under authoritarian and illiberal regimes, in particular when the disclosure of such information could put them and their work at risk because of the application of repressive legislation such as ‘foreign agents’ laws and similar provisions; regrets the fact that registration imposes a heavy bureaucratic burden on small CSOs based in other continents, which do not usually work or conduct advocacy activity in the working places of the EU institutions; calls for an assessment of the new measures, in order to avoid unintended limitations on fundamental rights for civil society and to ensure that the adopted measures are proportional and fair, in consultation with CSOs;

All Union beneficiaries signing a corporate model grant agreement under directly managed programmes have a visibility of funding obligation. The lack of compliance with corporate communication rules (visibility requirements) as set out in the model grant agreement signed constitutes a specific breach of its obligations by the beneficiary and can lead to grant reductions imposed by the authorising officers, or other consequences such as suspension or termination of the agreement. Such a course of action can only be taken after allowing the beneficiary the opportunity to be heard and provide observations (paragraph 40).

13. Recalls its own decision adopted on 13 September 2023, to make amendments to Parliament’s Rules of Procedure with a view to strengthening integrity, independence and accountability; recognises, however, that the EU institutions, including the European Parliament, should be more diligent in ensuring greater transparency, integrity and accountability regarding their framework for interaction with entities to be listed in the EU Transparency Register; calls, in this regard, for increased scrutiny by Parliament’s services in order to enforce Parliament’s amended Rules of Procedure relating to integrity, independence and accountability; acknowledges that further resources are needed to strengthen the transparency and the accountability of all lobbying or advocacy activities of legal persons or entities, including human rights NGOs;

Introducing further obligations for the disclosure of information

14. Calls for all EU institutions to be far stricter in their implementation, enforcement and supervision of adherence to the current provisions on the EU Transparency Register; also calls for the strengthening of the EU Transparency Register by increasing the budget and staff allocated to it, so that it is able to offer support to all applicants and registrants, particularly small entities and NGOs, throughout the registration process and verify the information they provide more thoroughly; calls on the Commission to present proposals to enhance the transparency of interest representation and to ensure that lobbying or advocacy activities, in particular on behalf of third country governments, their budgets and their policy scope are properly disclosed under the EU Transparency Register and that sanctions are provided for in the event of false declarations.

In line with the Interinstitutional Agreement of 20 May 2021 between the European Parliament, the Council and the Commission on a mandatory Transparency Register (IIA), the Commission and the other two signatory institutions require interest representatives interacting with the institutions and which do not represent commercial interests to declare their main sources of funding as well as the amount of each contribution above EUR 10 000 exceeding 10 % of the total budget and the name of the contributor in their declarations in the Transparency Register. This helps to provide transparency of the sources of funding for such actors, be that from third countries or other sources.

ANNEX: LIST OF ENTITIES OR PERSONS FROM WHOM THE RAPPORTEUR HAS RECEIVED INPUT

The Commission proposal for the ‘Defence of Democracy’ Package of 12 December 2023 further aims to enhance transparency and democratic accountability of interest representation activities on behalf of third countries. The package includes a proposed Directive (COM/2023/637 final) whose aim is to establish mandatory national registration lists for all entities, including NGOs, undertaking interest representation activities on behalf of third countries. Entities would be required to inter alia declare the third country on whose behalf it is acting and the annual amounts covering all the tasks carried out with the objective of influencing the development, formulation or implementation of the proposal, policy or initiative targeted by the interest representation activity, for a full year of operations.

The following list is drawn up under the exclusive responsibility of the rapporteur. The rapporteur has received input from the following entities or persons in the preparation of the opinion, until the adoption thereof in committee:

As regards imposing a general obligation to declare the sources of funding, the Commission believes that such reporting in the application would add a significant burden to the applicants and deter them further from applying for EU funding. As mentioned earlier, the Commission is committed to reducing the information required from applicants, especially for low value grants and this suggestion would run counter to this objective. Lastly, the purpose and benefit of such information is not clear as it would not affect the eligibility for the specific grant (paragraphs 25, 30, 33,45 and 48).

Entity and/or person

Concerning reporting on lobbying activities, the transparency standards that apply to interest representatives at the level of the EU institutions are set out in the IIA. The implementation of strict transparency standards at the Commission includes the obligatory registration of interest representatives in the Transparency Register prior to meetings held with Commissioners, their cabinet members and Directors-General and information about these meetings is also published.

HUMAN RIGHTS AND DEMOCRACY NETWORK

Reporting on lobbying activities in the Transparency Register is required for all actors that partake in certain lobbying activities as determined by the EU institutions and referred to as “conditionality measures”. Registered interest representatives are required to update their registrations at least once a year to ensure that the information is relevant and up-to-date and the content is also subject to ad-hoc screening by the Transparency Register Secretariat.

CIVIL SOCIETY EUROPE

The Commission publishes information on all meetings held between its senior decision-makers at political and administrative level with interest representatives, including NGOs, engaging in activities covered by the Transparency Register. That information is easily accessible in this Register. Publication of meetings is now being extended at the European Parliament to cover meetings with all MEPs (from 1 November 2023). The Commission also requires registration prior to participation of lobbyists in its expert groups and makes public their contributions to Commission initiatives such as public consultations and roadmaps (paragraphs 25 and 48).

INFORMATION ON ADOPTION IN COMMITTEE ASKED FOR OPINION

On the request to impose the same disclosure requirements on all types of organisations from the Transparency Register, the Commission may not, on its own initiative, impose disclosure requirements on Transparency Register applicants or registrants other than those set out in the relevant IIA. All decisions and conditions relating to the Transparency Register are taken jointly by the European Parliament, Council and Commission. According to the IIA, registrants are organised according to different interests represented to increase the transparency of their lobby activities. For example, a) when an entity represents its own interests, it is relevant to ask for information about lobby spending, affiliation and intermediaries, b) when a consultancy or law firm represents clients it is relevant to ask for information about revenues/ lobby subject per client; c) when an NGO represents non-commercial interests, it is relevant to know more about their funding and sources of funding. The same information can therefore not be asked of these three distinct categories (paragraph 44).

Date adopted

The interinstitutional Secretariat of the Transparency Register is made up of 10 full-time equivalent staff (figures from 2022) from the three participating institutions (European Parliament, Council, Commission). That staff is tasked with assessing the eligibility and data quality of all new applications for registration before they can be validated and published. The currently applicable information requirements that applicants and registrants must satisfy are set out in Annex II to the IIA. The Secretariat provides guidance and helpdesk support to applicants and registrants, who remain ultimately responsible for the accuracy of the information provided in the register. Registrants must update their information at least once annually and are invited to do so every 6 months. The Transparency Register is a public tool, which provides information to the public about lobbying activities. A secure access is provided to registrants via EU Login, to ensure that only the relevant persons can update the information pertaining to the organisation. By default, the information requirements do not include information that could endanger the life or safety of a natural person or the existence of an NGO. Therefore, such information is normally not disseminated to the public through the public register. In case of any specific real and serious threats encountered in naming its financial sources including the names of their budget contributors, any NGO concerned can take contact with the interinstitutional Secretariat of the Transparency Register (paragraph 43).

16.11.2023

The Transparency Register was significantly revised in 2021 with the adoption of the IIA. The IIA has strengthened disclosure requirements for funding information. Changing or extending the scope of the register further, including by introducing additional financial disclosure requirements for applicants and registrants, would require a change of the interinstitutional legal framework. In case of any specific real and serious threats encountered in naming its financial sources including the names of their budget contributors, any NGO concerned can take contact with the interinstitutional Secretariat of the Transparency Register (paragraph 45).

Result of final vote

Transparency and user-friendliness of FTS, streamlining databases

+:

The Commission welcomes the recommendation for a more frequent cycle of FTS publications and acknowledges its potential benefits for the EU citizen, thus will further explore the streamlining of the publication process. The current publication frequency has been selected based on a cost benefit analysis as it involves extensive data quality verifications. The FTS has already implemented more than 20 data quality/consistency checks in the form of a dashboard allowing for the verification of the data. The dashboard automatically detects potential data quality issues and has significantly improved the verification process.

–:

Regarding data extraction, the Financial Transparency System provides the possibility of data extraction. The Commission is working on additional features to improve the user experience in the future. The Commission recalls again that the disclosure of funding from other sources on the FTS portal would lead to extreme complications and disproportionate administrative burden for beneficiaries (paragraphs 25, 30, 31 and 32).

0:

Concerning the streamlining of databases, the Commission recalls that different EU systems have different purposes and functions, they could operate on different IT infrastructure and thus are not always suitable nor practical to interconnect. For instance, the Commission has already undertaken efforts to align further e-Grants and FTS. However, regarding the link between FTS and the Transparency Register: the purpose of the Transparency Register is to list organisations that try to influence the law-making and policy implementation process of the EU institutions, while the purpose of FTS to publish the beneficiaries of EU funding; being enlisted on the Transparency Register does not imply receiving EU funding. Linking FTS and the Transparency Register can therefore only be partially achieved (paragraphs 31, 32 and 35).

39

The Commission recalls that in line with the Financial Regulation recast as politically agreed, data on recipients and on beneficial owners will be included in the data-mining and risk-scoring tool and it will be applicable to all management modes. In addition, interconnection with other databases, including EDES, are envisaged on the basis of interoperability (paragraph 37).

5

3

Members present for the final vote

Alexander Alexandrov Yordanov, François Alfonsi, Maria Arena, Petras Auštrevičius, Anna Bonfrisco, Reinhard Bütikofer, Susanna Ceccardi, Włodzimierz Cimoszewicz, Anna Fotyga, Giorgos Georgiou, Raphaël Glucksmann, Andrius Kubilius, Ilhan Kyuchyuk, Antonio López-Istúriz White, Thierry Mariani, Marisa Matias, David McAllister, Vangelis Meimarakis, Sven Mikser, Francisco José Millán Mon, Alessandra Moretti, Kostas Papadakis, Tonino Picula, Isabel Santos, Mounir Satouri, Jordi Solé, Dominik Tarczyński, Hilde Vautmans, Charlie Weimers, Isabel Wiseler-Lima

Substitutes present for the final vote

Dacian Cioloş, Georgios Kyrtsos, Gabriel Mato, Juozas Olekas, Pina Picierno, María Soraya Rodríguez Ramos, Mick Wallace, Elena Yoncheva

Substitutes under Rule 209(7) present for the final vote

Karolin Braunsberger-Reinhold, Charles Goerens, Eero Heinäluoma, Maria-Manuel Leitão-Marques, Dan-Ştefan Motreanu, Paul Tang, Eugen Tomac, Lucia Vuolo, Juan Ignacio Zoido Álvarez

FINAL VOTE BY ROLL CALL IN COMMITTEE ASKED FOR OPINION

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