EN    EN EN 
EN    EN  EUROPEAN COMMISSION 
Brussels, 31.3.2010 
SEC(2010) 370 
  
COMMISSION STAFF WORKING DOCUMENT 
Outcome of the public consultation on the Green Paper on a European 
Citizens' Initiative 
 
  
Accompanying document to the 
 
Proposal for a 
 
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
 
on the citizens’ initiative 
  
{COM(2010) 119 final} 
EN 2   EN I. I NTRODUCTION  
One of the major innovations of the Treaty on  European Union as amended by the Lisbon 
Treaty, is to introduce the citizens' initiative. Th e Treaty provides that "not less than one 
million citizens who are nationals of a signifi cant number of Member States may take the 
initiative of inviting the Commission, within the framework of its powers, to submit any 
appropriate proposal on matters where citizens consider that a legal act of the Union is 
required for the purpose of implementing the Treaties"1. 
The procedures and conditions for such a citizens' initiative need to be set out in a Regulation 
of the European Parliament and of the Council to be adopted through the ordinary legislative 
procedure on a proposal from the Commission2. 
Given the importance of this new provision of  the Treaty for citizens, civil society and 
stakeholders across the EU, and considering the complexity of some of the issues to be 
addressed, the Commission launched a broad public  consultation with the adoption of a Green 
Paper on 11 November 20093. The consultation ended on 31 January 2010. A public hearing 
was also organised for all respondents to  the Green Paper on 22 February 2010. 
The consultation was structured around 10 key i ssues for which the Green Paper outlined the 
possible options and possible adva ntages and disadvantages of these options. On that basis 
respondents were invited to indicate whethe r they agreed with the Commission's initial 
assessment and whether they had alternative proposals and suggestions. 
The consultation elicited 329 replies from a br oad range of stakeholders, including 160 
individual citizens, 133 orga nisations and 36 public authorities. Many interesting and 
innovative ideas and suggestions we re put forward by stakeholders. 
The responses broadly underlined the need for the procedures and conditions for the citizens' 
initiative to be simple, user-friendly and accessi ble to all EU citizens and that they should be 
proportionate to the nature of the citizens' initiative.  
The responses also confirmed that a number of re quirements are needed in order to ensure that 
the instrument remains credible  and is not abused and that these requirements should ensure 
uniform conditions for supporting a ci tizens' initiative across the EU.  
II. G ENERAL COMMENTS  
Most of the contributions highlight the fact that the citizens' initiative is an important step for 
European democracy and the constr uction of a European public spa ce. They consider that this 
new instrument of participatory democracy coul d potentially be a good opportunity to bridge 
the gap between the European Commission and EU citizens, encouraging a dialogue between 
them and stimulating the fee ling of a European identity. 
                                                 
1 Article 11, paragraph 4, of the Treaty on European Union. 
2 Article 24 of the Treaty on the Functioning of the European Union. 
3 Green Paper on a European Citizens' Initiative - COM(2009) 622. 
EN 3   EN Nevertheless, to fully take advantage of the oppor tunity offered by the ci tizens' initiative as 
the first transnational instrume nt of participatory democrac y, many respondents believe that 
there should not be unnecessary obstacles which could make the use of the instrument too 
difficult or even impossible. That is why, generally, the contributors call for simple 
procedures accessible to all EU citizens; it should be easy to pres ent and support an initiative.  
Considering the difficulty in fixing thresholds and other requirements without any concrete 
experience, several contributors,  in particular among the orga nisations, are in favour of a 
revision clause within the Regulation, which woul d give the possibility to make some changes 
after a certain period of time (2 to 5 years).  
III. O VERVIEW OF THE RESULTS OF THE CONSULTATION FOR THE 10 KEY ISSUES 
RAISED BY THE GREEN PAPER  
1. Minimum number of Member States from which citizens must come 
Concerning the "significant numbe r of Member States" required by the Treaty, many options 
are proposed by the contributors, from 1 to 27 Member States. Among them, the proposal of 
one third of the Member States enjoys consid erable support among contri butors. A number of 
respondents, mainly amongst organisations, al so support a lower threshold, primarily one 
quarter of Member States.  
2. Minimum number of signat ures per Member State  
Respondents, including individual citizens, or ganisations or public authorities, generally 
favour a minimum number of citizens per Member State to ensure that a citizens' in itiative is 
genuinely representative of a Union interest. A number of re spondents agree that a threshold 
of 0.2% of the total populati on of each Member State could be a good approach although 
many support a lower threshold ( 0.1% in particular). Neverthe less, several respondents argue 
that there should not be this kind of threshold as it is not exp licitly required by the Treaty.  
A system of sliding scale is also proposed by so me contributors, with different modalities. In 
this kind of flexible system, if the minimu m percentage is not reached in the minimum 
number of States, it can be compensated by a hi gher number of participating Member States.  
Finally, a number of respondents, notably amon gst the smallest and largest Member States, 
advocate a different approach to setting the threshold altogether, arguing that a set percentage 
for all Member States is not equitable, sinc e it is much easier, for instance, to collect 
statements of support from 1.000 citizens (representing 0.2% of the population) in 
Luxembourg than 160.000 in Germany, and theref ore easier to count sm all Member States 
than large ones. 
3. Eligibility to support a citize ns' initiative - minimum age  
Respondents broadly support fixing a minimum ag e for supporting a citizens' initiative. Many 
consider that it should be linked to the age to vote in the European Parliament elections. Some 
respondents, however, consider th at the minimum age should be the same in all the Member 
States, either 16 or 18. A minimum age of 16  is proposed by a number of contributors, 
principally citizens and organisa tions, in order to encourage th e civic participation of the 
younger generation and foster greater interest  and debate among young people in European 
issues. They argue that the ci tizens' initiative is not an el ection but only an agenda-setting 
EN 4   EN initiative, and that it could be a good way for you ng people to learn about citizenship and take 
part in the political debate a nd the decision-making process. 
4. Form and wording of a citizens' initiative 
Respondents tend to agree that the promoters of  an initiative should st ate the subject matter 
and the objectives of their proposal in an unambiguous way. Thus, many respondents invite 
the Commission to provide a template to be filled in by the organisers and requiring the 
necessary information. A significan t number of contributors suggest  that organisers should be 
required to provide the legal basis of the propos al. Many also think that there should be the 
possibility to add a draft lega l act but that it should not be  mandatory as this kind of 
requirement would prevent ordinary citizen s from participating in the debate.  
Moreover, many contributors think that the organisers should be offered neutral support and 
guidance, including legal advice, in the preparat ion of initiatives. In addition some consider 
that the translations of the in itiative in all offici al languages of the Union should also be 
provided. The respondents suggest different authorities to provide  this support: the European 
Commission, the European Parliament, th e European Ombudsman, the Commission 
representations in the Member States, the Europe Direct centres, and others. 
5. Requirements for the collection, verificati on and authentication of signatures 
Respondents broadly support the idea of a common set of pro cedural requirements for the 
collection, verification and authenti cation of signatures so as to  ensure a uniform process and 
the same conditions across the EU and to preser ve the European-wide nature of the citizens' 
initiative. However, others th ink that priority should be gi ven to national systems already 
existing.  
For many respondents, there should not be differe nt procedures in the 27 Member States in 
relation to the collection process, since it would make it too complicated for the organisers to 
comply with the different requirements. Furtherm ore, many contributors insist on the fact that 
the Member States should not be allowed to im pose restrictions or re quirements which would 
make the collection process more difficult. They consider that there should not be any specific 
restrictions placed on how statements of support are collected and they would like citizens of 
the Union to be able to sign up to an initia tive anywhere – for ex ample in the street - 
regardless of where they live or come from. 
The possibility of online signatu res is called for almost unanim ously, being in line with the 
development of an e-society and since it would gr eatly facilitate the collection of signatures. 
Only a few contributors would prefer pape r-based signatures, considering that online 
signatures are not secure enough. 
Those in favour of online collection of signatu res propose different systems to ensure the 
verification and authentication of the signatures and to avoid multiple signatures from one person (CAPTCHA
4, e-mail confirmation, IP address, pa ssword received by email after an 
online registration which would allow the au thentication of the person by means of the 
personal data provided, etc.; identification by use of Passport Number, EU Driving License 
Number, Voting Roll Number, ID Card number, etc.).  The idea of a European citizen's 
smartcard allowing e-signatures is proposed  several times to solve this problem.  
                                                 
4  Challenge-response test used in computing to ensure that the response is not generated by a computer. 
EN 5   EN 6. Time limit for the collection of signatures 
Almost all contributors among i ndividual citizens, organisations  and public authorities think 
that a time limit should be fixed for the collec tion of signatures. Most  respondents agree that 
one year would be a suitable  time limit although there are also many respondents who favour 
either a longer period (18 months) or a shorte r one (6 months). Those in favour of a short 
time-limit (less than one year) think that given the possibilities offered by Internet and the 
media, it should be possible to mobilize peopl e and collect one million signatures very 
quickly. In contrast, those in  favour of longer time-limits argue that a campaign in 27 
countries requires a lot of time and resources.   
7. Registration of proposed initiatives 
Contributors generally favour a mandatory system of registration of pro posed initiatives on a 
specific website provided by the European Comm ission. This website should work as a tool 
for communication and transparency, which w ould also help to bring the European 
Commission closer to the citizens.  
Others suggest that the site could be hoste d by other authorities su ch as the European 
Ombudsman, the European Parliament or the Court of Justice of the European Union. 
8. Requirements for organisers - Transparency and funding 
Respondents generally consider that organisers  of an initiative should provide information on 
the funding and support they have received to ensu re that the citizens are fully aware of what 
and who is involved. Some contri butors think that only financ ial support exceeding a certain 
amount should be declared to av oid overburdening the organisers.  
Moreover, the provision of information on fundi ng and support is often seen as a means to 
ensure that initiatives are of  a citizen-driven nature.  
On the question of funding, some contributors, mainly among the organisations, are of the 
opinion that the European Union should provide financial support to the organisers to keep 
this instrument in the hands of citizens and to prevent it from being dependent on private 
financing. For some of them, this could take th e form of legal advice an d / or assistance with 
the translation of the initiative.  
9. Examination of citizens' initiatives by the Commission 
Contributors broadly favour a time limit for the examination of the initiative by the 
Commission once the required number of signature s has been collected. Many agree that a 6-
month time limit would be appropriate alt hough some also suggest a shorter period. 
However, the consultation generated different views as regards the issue of assessing the 
admissibility of proposed initiatives.  
On the one hand, there is a tendency amongst res pondents, in particular  among organisations 
and public authorities, to consider that the ad missibility of a citizens' initiative should be 
checked before signatures are collected, prefer ably at the moment of  the registration and 
within a fixed time limit. They believe that this would avoid a considerable waste of resources as well as frustration among citizens having signed up to successful but ultimately inadmissible initiatives. Some also favour this  option in order to prevent the launching of 
EN 6   EN initiatives that would be contrary to the valu es of the Union or the Charter of Fundamental 
Rights. There is also concern about public aut horities having to make use of public resources 
in order to carry out checks for initiatives that ultimately would not be admissible. Some have pointed out that this would be particularly pr oblematic for initiatives that would go against the 
values of the Union and of the constitution of their Member State. 
However, amongst those who supp ort such an early admissibil ity check, there are different 
views as to who should be responsible for carryi ng out such a check, some considering that it 
should be the Commission and othe rs favouring an independent body. 
On the other hand, others are against an ex-ante admissibility check altogether in the name of 
freedom of expression and considering that the debate created across Eu rope by an initiative 
is more important than the immediate result. Th ey do not think it would be appropriate for the 
Commission to be able to prev ent, from the outset, a public de bate and campaign from taking 
place on a citizens' initiative, even if it is not within the framework of its powers. 
10. Initiatives on the same issue 
As for the successive presentation of citizen s' initiatives on the same issue, respondents 
generally do not think it is neces sary to regulate this issue.