COMMISSION STAFF WORKING DOCUMENT Accompanying the document Proposal for a Regulation of the European Parliament and of the Council on the European citizens' initiative
Date: 2017-09-13
Institutions: European Commission, Secretariat-General
Subjects: EU initiative, European citizenship, data collection, data protection, participatory democracy, personal data, petition, power of initiative

EN 

   EN 

   EUROPEAN COMMISSION  Brussels, 13.9.2017  SWD(2017) 294 final   COMMISSION STAFF WORKING DOCUMENT Accompanying the document Proposal for a Regulation of the European Parliament and of the Council on the European citizens' initiative {COM(2017) 482 final}  
 
 
Table of contents 

1. 

Introduction (Political and legal context) ........................................................................................ 4 

2.  Outcome of the review process ....................................................................................................... 5 

2.1.  What are the problems? ........................................................................................................... 5 

2.2.  What are the problem drivers? ................................................................................................ 5 

2.3.  How will the problem evolve? ................................................................................................ 8 

3.  Objectives: What is to be achieved? ................................................................................................ 9 

3.1.  General objectives ................................................................................................................... 9 

3.2. 

Specific objectives ................................................................................................................... 9 

4.  Assessment of the main elements of the Regulation: possible options for revision and preferred 
option ..................................................................................................................................................... 10 

4.1. 

Preparing and launching a citizens' initiative ........................................................................ 10 

4.1.1. 

Citizens' committee / Group of organisers ................................................................ 10 

4.1.2. 

Advice and support to organisers .............................................................................. 14 

4.1.3. 

Registration phase ....................................................................................................... 18 

4.2.  Collecting statements of support and their verification ......................................................... 22 

4.2.1.  Minimum age for signatories ...................................................................................... 22 

4.2.2. 

Data to be provided by signatories and verification by Member States ................. 23 

4.2.3.  Online collection .......................................................................................................... 29 

4.2.4. 

Time period for collection ........................................................................................... 36 

4.3. 

Follow-up of successful initiatives ........................................................................................ 38 

4.3.1. 

Time limit for submission to the Commission ........................................................... 38 

4.3.2. 

Examination procedure ............................................................................................... 38 

4.4.  Communication, awareness-raising and transparency ........................................................... 41 

4.4.1.  General communication and awareness-raising concerning the ECI instrument . 41 

4.4.2. 

Information and transparency with regard to concrete citizens' initiatives .......... 42 

4.4.3. 

Communication with signatories ................................................................................ 44 

4.5. 

Personal data protection ........................................................................................................ 45 

4.6. 

Summary of the main elements of the proposal .................................................................... 47 

4.7. 

ECI procedure as foreseen in the proposal ............................................................................ 49 

Annex 1: REFIT and Monitoring .......................................................................................................... 51 

1.  REFIT (simplification and improved efficiency) .......................................................................... 51 

2.  Monitoring ..................................................................................................................................... 52 

Annex 2: Procedural information .......................................................................................................... 55 
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1.  Lead DG, Decide Planning/CWP references ................................................................................. 55 

2.  Organisation and timing ................................................................................................................ 55 

3.  Evidence, sources and quality ....................................................................................................... 55 

Annex 3: Stakeholder consultation ........................................................................................................ 58 

Annex 4: Current ECI procedure (Regulation (EU) No 211/2011) ....................................................... 65 

Annex 5: Signatories' data requirements according to Member States ................................................. 66 

Annex 6: Requirements to sign up to a European Citizens' Initiative ................................................... 68 

Annex 7: ECI country form that signatories can use depending on their citizenship and residence ..... 73 

Annex 8: Correlation table .................................................................................................................... 76 

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1. 

INTRODUCTION (POLITICAL AND LEGAL CONTEXT) 

This  Staff  Working  Document  accompanies  the  proposal  for  a  Regulation  on  the  European 
citizens' initiative. It synthetises the analyses that have taken place since 2015 on the current 
Regulation (EU) No 211/2011 on the citizens' initiative (ECI Regulation) and on the different 
options  that  have  been  suggested  for  its  revision.  It  is  based  on  extensive  stakeholder 
consultations and a number of studies on specific issues and it takes account of the opinion 
from the REFIT platform as well as of contributions from other EU institutions and bodies.  
The European citizens' initiative (ECI) was introduced by the Treaty of Lisbon1 and has been 
implemented by the ECI Regulation which entered into application in April 2012.  
The ECI is a right enshrined in the Treaty. It aims at enhancing citizens' participation in the 
democratic  life  of  the  Union,  by  allowing  one  million  citizens  to  invite  the  Commission  to 
submit a proposal. The ECI is therefore a tool for participation and for agenda-setting at EU 
level. Thanks to  this instrument, a significant number of EU  citizens  have the possibility to 
directly  ask  the  Commission  to  take  action  on  a  matter  that  they  care  about.  By  making  it 
more accessible, the ECI helps bring the Union closer to citizens. One of the benefits of this 
instrument  is  also  that  it  allows  citizens  to  forge  links  with  like-minded  people  across  the 
Union,  facilitating  pan-European  debates  on  issues  that  are  close  to  citizens'  concerns  and 
helping build an EU-wide public sphere.  
An  estimated  8  million  statements  of  support  have  already  been  collected  by  organisers  of 
citizens'  initiatives  for  their  various  causes  while  three  registered  initiatives  reached  the 
1 million threshold and statements of support for a fourth one are currently being verified by 
the Member States' competent authorities.  
The first triannual report on the application of the ECI Regulation was adopted on 31 March 
2015, in accordance with the review clause foreseen in its Article 22. 
While the ECI has been fully implemented and all the necessary procedures and mechanisms 
are  in  place2  as  proven  by  the  fact  that  three  initiatives  have  managed  to  complete  the  full 
lifecycle of an ECI, from registration through successful collection of required support to the 
formal reply of the Commission, it also appears that the instrument has not achieved its full 
potential.  The  number  of  requests  for  registration  of  citizens'  initiative  received  by  the 
Commission  has  steadily  decreased  since  2012,  before  increasing  again  since  the  end  of 
20163,  partly  as  a  result  of  improvement  measures  implemented  by  the  Commission.  The 
awareness of the instrument among citizens has not reached a satisfactory level as evidenced 
by the fact that 37% of respondents to the public consultation had not heard about the ECI.          
In  its  2015  report,  the  Commission  listed  a  number  of  challenges  arising  in  the 
implementation  of  the  Regulation  in  its  current  form.  It  also  committed  itself  to  further 
analyse the impact of these issues on the effectiveness of the instrument, and to listen to the 
views expressed by stakeholders and other institutions in this regard, with a view to proposing 
measures which would contribute to the improvement of the instrument. 
On top of the Commission's own review report of 2015 analysing the implementation of the 
ECI Regulation, different stakeholders and institutions have carried out their own assessments 
and  evaluations  of  the  instrument  (see  annex  2).  In  particular,  the  European  Parliament 

1 Article 11 of the Treaty on European Union and Article 24 of the Treaty on the Functioning of the European 
Union 
2 A description of the ECI procedure is provided in annex 4. 
3 See figure 3, on page 19 

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adopted  a  Resolution  in  October  20154  suggesting  various  improvements  and  calling  for  a 
revision of the Regulation, and is currently preparing a legislative own-initiative report. The 
ECI has also been subject to an opinion of the REFIT platform5 in June 2016. 
While the Commission has implemented a series of non-legislative measures to facilitate the 
use  of  the  instrument  (notably  partial  registration  of  initiatives,  reinforced  support  and 
assistance  to  the  organisers,  improved  online  collection  software),  more  must  be  done  to 
effectively and efficiently improve the situation, including the revision of the ECI Regulation.  
In line with Priority no 10 of the Juncker Commission – A Union of Democratic change - the 
European  Commission  committed  to  increase  democratic  legitimacy  in  the  EU  through 
enhanced  citizens'  involvement  and  participation.  The  improvement  of  the  ECI  instrument 
based on the experience of the first five years will contribute towards this objective. 

2.  OUTCOME OF THE REVIEW PROCESS 

2.1.  What are the problems? 

The various analyses on the first five years of the ECI implementation converge in concluding 
that  shortcomings  identified  in  the  instrument  as  it  currently  works  undermine  its 
effectiveness and the achievement of its objectives, i.e. to enable citizens to contribute to the 
EU agenda and foster transnational debate and the emergence of a European public sphere.  
The problems identified can be summarised around the following three aspects: 
a) the difficulties for citizens to propose legally admissible initiatives – this is evidenced by 
the relatively high rate of refusals of registration (30% of requests for registration could not be 
registered by the Commission as they were manifestly outside the scope of the Commission's 
competences); 
b)  a  complex  and  burdensome  process  for  organisers  of  initiatives  to  collect  statements  of 
support, as evidenced by the low rate of successful initiatives, i.e. initiatives that manage to 
reach the required number of signatories within the one year collection period; 
c) limited debate and impact so far generated by citizens' initiatives. 

2.2.  What are the problem drivers? 

With a view to encouraging participation by citizens and making the Union more accessible, 
the  current  rules  were  designed  to  be  user-friendly  and  proportionate  to  the  nature  of  the 
citizens’ initiative, striking a balance between rights and obligations. 
The guiding principles were as follows: 
-  The  conditions  aimed  to  ensure  that  citizens'  initiatives  are  representative  of  a  Union 
interest, whilst ensuring that they do not make the instrument too difficult to use.  
- The procedures were meant to be simple and user-friendly, whilst preventing fraud or abuse 
of the system and without imposing unnecessary administrative burdens on the Member 
States. 

4  European  Parliament  resolution  of  28  October  2015  on  the  European  Citizens’  Initiative,  available  at 
http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//TEXT+TA+P8-TA-2015-
0382+0+DOC+XML+V0//EN&language=EN  
5 REFIT Platform Opinion on the submission by a member of the Stakeholder group on the European Citizens' 
Initiative  –  27/28  June  2016  available  at  https://ec.europa.eu/info/files/refit-platform-recommendations-
european-citizen-initiative_en    

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The ECI being the first instrument of its kind implemented at transnational level, those rules 
were  developed  based  on  experience  of  such  instruments  at  national  and  local  level.  It  was 
also  the  first  time  that  such  an  instrument  was  put  in  place  in  the  unique,  Treaty-based 
institutional context of the European Union. 
After  five  years  of  implementation  of  the  ECI,  experience  has  shown  that  several  rules 
currently  foreseen  in  the  ECI  Regulation  have  raised  practical  obstacles  and  may  be 
considered to be unnecessarily restrictive and burdensome for the ECI organisers, signatories 
and Member States' competent authorities, in light of the objectives pursued. This concerns in 
particular  the  specific  rules  governing  the  timeline  of  the  initiatives,  the  obligation  for 
organisers to set up their own online collection systems and get them certified by a Member 
State's authority, the diverging personal data requirements for the ECI signatories and the fact 
that the collected data are under the responsibility of the organisers (members of the citizens' 
committee).  Moreover,  in  relation  to  problem  c)  above,  some  ECI  organisers  and  other 
stakeholders  have  considered  the  follow-up  given  to  the  initiatives  that  have  successfully 
collected  the  required  support  as  insufficiently  substantial  and  inclusive.  Some  stakeholders 
consider the impact achieved so far by the first successful initiatives to be limited.  
The  following  shortcomings  stemming  directly  from  the  provisions  of  the  ECI  Regulation 
contribute  to  generating  the  above  described  problems,  in  particular  the  complex  and 
burdensome process for organisers to collect statements of support (point b) above): 
-  The divergences between the conditions and personal data required from signatories in the 
different Member States (resulting in complexity and the risk of excluding some groups of 
citizens); 

-  The personal liability of citizens who organise initiatives, combined with the lack of legal 
personality of the citizens' committees, acting as a deterrent to the setting up of initiatives 
in view of the responsibility for the collected data;  

-  The link between the date of registration and the start of the 12 months collection period, 
shortening the collection period in practice since in many cases, the organisers have not 
yet finalised the preparation of their online collection system on the date of registration; 

-  The need for the organisers to themselves set up and obtain the certification by national 
authorities  of  their  online  collection systems.  The  Commission's  hosting  offer,  proposed 
beyond its obligations under the ECI Regulation, managed to remove the biggest obstacle, 
namely  the  lack  of  affordable  hosting  providers  on  the  market.  However,  stakeholders 
remain critical with regard to the complexity of the current certification procedure and are 
not fully satisfied with the features offered by the Commission software made available in 
accordance with the ECI Regulation, in particular because it does not offer campaigning 
tools (e.g. the collection of email addresses of signatories, which is currently not foreseen 
in  the  Regulation).  In  addition,  several  Member  States’  competent  authorities  complain 
about  the  burden  of  certifying  online  collection  systems  before  the  registration  of  their 
proposed initiative with the Commission as there is a risk that those systems will not be 
used;  

-  The  verification  by  the  Commission  of  the  translations  of  the  proposed  initiatives 
provided  by  their  organisers  has  proved  to  be  a  cumbersome  process.  Organisers  had 
difficulties to ensure the necessary accuracy of their translations, even on the basis of the 
comments received from the Commission on their first version(s). 

6 

 
 
 
Other  drivers  do  not  directly  stem  from  the  provisions  of  the  ECI  Regulation  or  concern 
elements on which the Regulation is silent. They contribute more towards problem c) above 
(limited debate and impact so far): 

-  The  lack  of  a  specific  time  limit  in  the  Regulation  for  the  submission  of  a  successful 
initiative  to  the  Commission,  which  is  a  potential  source  for  confusion  and  uncertainty 
both for the institutions and the public; 

-  On the occasion of two out of three public hearings organised at the European Parliament, 
no  stakeholders  or  experts  other  than  the  ECI  organisers  themselves  were  invited  to 
actively  participate.  The  public  hearing  is  seen  by  many  as  an  opportunity  to  hear 
stakeholders representing different views and perspectives. This is all the more important 
given that the 3 month period foreseen by the ECI Regulation for the preparation of the 
Commission reply to a successful initiative is very short and leaves little time to analyse 
and  take  into  account  the  input  provided  by  the  hearing  and  organise  stakeholder 
consultations; 

-  Some ECI organisers (and other stakeholders) consider that there is insufficient dialogue 
and  interaction  with  the  Commission  at  different  stages  of  the  ECI's  lifecycle  and  in 
particular  after  the  adoption  of  the  Commission's  Communication  on  the  citizens’ 
initiative. They would like to see the examination and follow-up process more structured 
and to be more extensively involved therein.   

Point  a)  above  (difficulties  for  citizens  to  propose  legally  admissible  initiatives)  seems 
mainly  driven  by  the  lack  of  specific  knowledge  of  the  EU  and  Commission  competences, 
which are Treaty-based, combined with a rather inflexible registration procedure which does 
not  foresee  the  possibility  for  organisers  to  revise  their  proposal,  should  the  Commission 
assess that it falls manifestly outside its powers. 

Finally,  the  low  awareness  about  the  instrument  among  citizens  results  in  low  participation 
and  the  need  for  organisers  to  explain  the  instrument  to  potential  signatories  in  addition  to 
defend  their  cause.  This  is  a  more  horizontal  driver  which  contributes  to  all  three  main 
problems identified. 

Inefficiencies have been observed at several stages of the procedure where there is a margin 
for reducing regulatory costs. This concerns in particular: 
a) the costs related to the setting-up and certification of online collection systems6; 
b)  costs  related  to  1)  producing  translations  of  the  proposed  initiatives  (by  organisers)  and 
their  verification  by  the  Commission,  2)  the  use  of  13  different  forms  (requesting  different 
personal  data)  for  the  collection  of  statements  of  support,  and  3)  the  submission  by  the 
organisers of the collected statements of support to the competent national authorities. These 
costs  depend  to  a  large  extent  on  the  way  the  citizens'  committee  organises  its  campaign 
(number of language versions they can get among their committee, collection in paper and/or 
online, submission to Member States in person/electronically/by mail, etc.) and therefore do 
not easily allow for proper quantification.  

6  A  detailed  assessment  of  costs  according  to  the  different  scenarios  possible  under  the  ECI  Regulation  is 
provided in the study on ICT impacts of the Regulation on the citizens' initiative of June 2015, page 98. 

7 

 
 
 
                                                            
2.3.  How will the problem evolve? 

The Commission has already implemented a number of non-legislative measures to improve 
the implementation of the European citizens' initiative.  

Only a few months after the Regulation  started to  apply, the Commission announced that it 
would  offer  the  hosting  of  the  organisers'  online  collection  systems  on  its  own  servers  and 
assist  them  to  get  their  systems  certified  by  the  relevant  national  authority,  to  address  the 
difficulties  encountered  by  the  first  organisers  to  find  affordable  and  appropriate  host 
providers on the market. While this measure has helped organisers, the Regulation provides 
that the responsibility for online collection systems is for organisers. Moreover, they still need 
to get their systems certified which they often fail to manage before the start of the 12-month 
collection period. 

The  Commission  has  also  progressively  improved  the  advice  and  support  provided  to 
(potential)  organisers  of  initiatives,  including  its  assistance  service  for  the  setting-up  and 
certification of online collection systems based on its servers. It has progressively improved 
the  user-friendliness  of  the  online  collection  software  that  organisers  can  choose  to  use, 
recently  released  a  new  version  of  the  online  collection  software  that  allows  collecting  
statements of support on the street or at organised events with mobile devices instead of paper 
forms, introduced an approach that allows for partial registration of initiatives to reduce the 
rate of refusals, as well as reinforced communication activities on the ECI, including via the 
publication of press releases for each new initiative registered. In addition, the launch of an 
online collaborative platform is planned for 2018 as a pilot project suggested by the European 
Parliament. 

These  measures  have  contributed  to  improving  the  functioning  of  the  instrument,  as 
demonstrated  by  the  number  of  initiatives  using  the  hosting  offered  by  the  Commission 
(33 initiatives  since  2012)  and  the  number  of  initiatives  recently  registered  (10  initiatives 
registered since the end of 2016). 

Nevertheless,  given  that  several  problem  drivers  emerge  directly  from  provisions  of  the 
Regulation, some problems can only be addressed by a revision of the Regulation. 

In  case  no  revision  takes  place,  the  ECI  risks  to  be  used  less  and  less  by  citizens  and 
ultimately becoming obsolete. 

8 

 
 
 
Figure 1: Summary tree 

DRIVERS: 

Lack of knowledge on EU 
and Commission 
competences among 
potential organisers 

Liability risks for organisers  

Inflexible registration 
procedure  

Costs for organisers (online 
systems, translations, etc.) 

Follow-up process to 
successful ECIs not 
inclusive enough 

Impact of successful ECIs so 
far perceived by some 
stakeholders as limited  

Insufficiently flexible 
timeline, especially for the 
collection period 

Diverging conditions and 
data requirements for 
signatories in the different 
Member States 

Low awareness about the instrument among citizens 

PROBLEMS:  

Difficulties for citizens 
to propose legally 
admissible initiatives  

Complex and 
burdensome process 

Limited debate and 
impact so far 

CONSEQUENCES: 

Low number of 
initiatives launched 
and registered 

Low rate of successful 
initiatives 

Low attractiveness of 
the instrument  

3.  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

3.1.  General objectives 

This initiative aims to improve the functioning of the ECI by addressing the shortcomings 
identified  in  its  implementation,  with  the  main  policy  objective  of  achieving  the  full 
potential of the ECI as an instrument to foster debate and citizen participation at European 
level and bring the EU closer to its citizens. 

3.2. 

Specific objectives 

To  reach  the  general  objectives,  there  is  a  need  to  make  the  ECI  more  accessible,  less 
burdensome and easier to use for organisers and supporters. 

9 

 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
Improving the ECI instrument by tackling the identified shortcomings at different stages 
of  the  ECI  lifecycle  should  enhance  its  use  by  EU  citizens  and  thus  allow  them  to 
participate more effectively in agenda-setting at EU level and foster pan-European debates 
on the issues which are of importance to them. 
The rules and procedures need to be made more proportionate to the nature of the ECI, i.e. 
an  instrument  for  citizen  participation  which  does  not  lead  to  a  binding  outcome  (in 
contrast with elections).    

Figure 2: Objectives 

General objectives 

Specific objectives 

4.  ASSESSMENT  OF  THE  MAIN  ELEMENTS  OF  THE  REGULATION:  POSSIBLE  OPTIONS  FOR 

REVISION AND PREFERRED OPTION 

The ECI lifecycle covers successive stages, notably the preparation and launch of a citizens’ 
initiative,  followed  by  the  collection  of  statements  of  support  and  their verification,  and the 
follow-up  of  successful  initiatives. As  barriers to  the  effectiveness  and the  efficiency  of  the 
instrument  have  been  identified  in  each  stage,  a  methodological  assessment  of  each  of  the 
aspects is presented, including solutions to remedy or mitigate the issues concerned. 

4.1. 

Preparing and launching a citizens' initiative 

4.1.1.  Citizens' committee / Group of organisers  

4.1.1.1.Composition of the group of organisers 

Under the current Regulation, a citizens' initiative must be organised by a citizens' committee 
of at least seven EU citizens residing in seven different Member States and of the age to vote 
in European Parliament elections. The committee designates a representative and a substitute 
10 

 
 
 
 
 
 
who  are  contact  persons  and  can  speak  and  act  on  behalf  of  the  committee.  The  committee 
may be composed of more than seven members but those are not formally registered by the 
Commission.  The  citizens'  committee  has  no  legal  personality  and  thus  the  acts  of  each 
member may engage his/her personal responsibility. 

Experience shows that this obligation has served to unite from the start seven members from 
seven  Member  States  and  working  as  an  initial  filter  for  generating  the  minimum 
organisational  potential  which  is  needed  to  run  the  initiative  throughout  its  lifecycle  and  in 
particular  to  run  a  campaign  covering  at  least  seven  Member  States.  The  obligation  also 
confirms  the  European  nature  of  the  initiative  and  has  not  met  with  objections  by  the  main 
stakeholders  in  the  review  process  even  although  some  citizens  have  referred  to  it  as  an 
administrative hurdle. 

During  the  first  five  years  of  implementation,  a  number  of  other  concerns  have  been  raised 
mainly  by  organisers  of  initiatives,  regarding  the  organisation  and  status  of  the  citizens' 
committee. The following issues have been flagged: 

  Members  of  the  citizens'  committee  act  as  individuals  and  therefore  engage  their 
personal  responsibility.  Moreover,  they  can  face  obstacles  to  raise  funds  and/or 
manage applicable procedures related to personal data protection. 

  The check as regards the composition of the committee is only done at the moment of 
registration of the proposed initiative. No mechanism has been foreseen allowing the 
modification  of  the  composition  of  the  citizens'  committee  during  the  subsequent 
stages of the initiative lifecycle. This was originally motivated by the need to maintain 
full transparency towards the public and the competent national authorities as regards 
the  members  of  the  committee,  but  such  a  solution  proved  inflexible  against 
experience. 

  While the committee can be composed of more than seven members, it is currently not 
possible to formally register the additional members (in some cases one or more per 
each of the 28 Member States). This adds to already existing uncertainties as regards 
the status of the committee and its members.  
In practical terms, experience shows that additional persons, not registered as contact 
persons  or  other  committee  members,  would  interact  at  technical  level  with  the 
Commission or other institutions throughout the procedure on behalf of the organisers. 
For legal certainty reasons it is preferable that such persons be clearly identified by the 
organisers. 

 

In  response,  a  limited  number  of  changes  is  being  proposed,  completing  the  existing  rules 
concerning  the  organisation  of  the  citizens'  committee,  which  is  now  called  a  "group  of 
organisers"  to  make  them  more  flexible  while  at  the  same  time  maintaining  the  necessary 
level of legal certainty and transparency. These include: 

  More complete rules for the additional members of the group whose names will now 

be published in the register for information purposes (however without prior check by 
the Commission beyond the seven minimum members); 

  Explicit rules regarding the change in the composition of the group and relevant 

transparency arrangements; 

  More flexibility for the group of organisers to appoint the representative and substitute 
among all its members as well as explicit recognition of the status of natural persons 
not necessarily being part of the group of organisers but authorised to interact on its 
behalf with the Commission and other EU institutions. 

11 

 
 
In addition, it has been foreseen that in case a legal entity is specifically created for an ECI, 
this legal entity substitutes the group of organisers (or its members) in the different aspects of 
initiative management, including registration, collection of statements of support, submission 
to the Commission and examination of the initiative. 
This new formula is an additional option offered to the organisers motivated in the first place 
by the reasons of liability as further explained in section 4.1.1.2 below. 

4.1.1.2. Liability risks 

Several citizens' committees have reported concerns about their liability as organisers, in view 
of  their  personal  responsibility  in  accordance  with  applicable  national  law  for  any  damage 
they cause in the context of organising a citizens' initiative.  

The  main  concern  of  the  organisers  is  related  to  the  potentially  significant  amounts  of 
personal data to be collected from signatories.  

These  data  need  to  be  securely  collected  either  on  paper  or  online,  stored  and  (in  case  the 
required  thresholds  of  signatories  are  reached)  transferred  to  the  competent  Member  States 
authorities for verification. Finally, at the end of the process the organisers are responsible for 
destroying the data concerned. 

It  is  essential  to  ensure  in  this  context  the  respect  of  the  fundamental  right  of  protection  of 
natural persons in relation to the processing of personal data as recognised in Article 8(1) of 
the Charter of Fundamental Rights of the European Union and in Article 16(1) of the Treaty 
on the Functioning of the European Union. Signatories' data need to be protected in particular 
against interception and misuse (for details see section 4.5 below).  

The responsibility of the organisers is defined under the ECI Regulation and under Directive 
95/46/EC7 on personal data protection and can be engaged in cases such as theft, unauthorised 
disclosure  or  misuse  of  the  collected  data.  The  ECI  Regulation  is  fully  coherent  with  the 
general framework on data protection.  

However, the risks related to personal liability and the uncertainty this creates for individual 
organisers may act as a deterrent for the launch of initiatives. The additional difficulty in the 
context of the ECI originates from the fact that the organisers are residents in at least seven 
different countries, and thus different national rules may be applicable to their actions. 

Several options have been proposed and analysed to reduce the burden that the liability today 
constitutes for the organisers: 

 

Introduction of a special European status for the citizens' committee endowed with a 
legal personality. Introduction of such a status would require a specific legal basis in 
the  Treaties,  but  additionally  would  still  need  to  be  legally  anchored  in  a  specific 
national legal system to complete/complement the rules foreseen at EU level (similar 
to  European  Political  Parties  and  European  Groupings  of  Territorial  Cooperation). 
Therefore,  such  a  solution  would  likely  result  in  more  complexity  and  rigidity  for 
organisers.  

7 Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of 
individuals with regard to the processing of personal data and on the free movement of such data 

12 

 
 
 
                                                            
  Limitation  of  the  liability  based  on  the  model  of  Directive  2008/99/EC  on  the 
protection of the environment through criminal law8, with a view to establishing that 
organisers  are  responsible  only  for  acts  which  are  ‘unlawful  and  committed 
intentionally  or  with  at  least  serious  negligence’.  This  solution  has  also  been 
advocated by the European Parliament.   

  Obligation  for  the  citizens'  committees  to  register  as  a  legal  entity  (most  likely:  an 
association) in one of the Member States. However, introducing this as an obligation 
would add rigidity to the current system, obliging the organisers coming from different 
Member  States  to  choose  one  national  law  to  establish  their  association  and  adding 
further formalities before the launch of the initiative. 

  Allowing  existing  organisations  to  organise  initiatives  or  to  be  part  of  the  citizens' 
committees.  This  solution  would  allow  reducing  the  risks  of  engaging  personal 
responsibility  for  the  individuals  organising  the  initiative.  Given  that  the  ECI  was 
intended  as  an  instrument  for  citizens,  debating  grassroots  initiatives  originating 
directly from them, this solution has been discarded at the moment of adoption of the 
current Regulation. 

Several  options  to  reduce  liability  burdens in  an  indirect  way  have  also been  considered, in 
particular:  

  Limiting the amount of personal data requested from signatories. A detailed analysis 

of the extent to which this can be achieved can be found in section 4.2.2. 

  Transferring the responsibility for the online collection to the Commission. This result 
can  be  achieved  in  case  the  online  collection  takes  place  via  a  central  collection 
system  managed  by  the  Commission  which  thus  takes  the  responsibility  for  data 
collection, storage, transfer to national authorities and finally destruction within the set 
time limits.  This  solution is  further analysed in  section 4.2.3. For the purpose of the 
present analysis it is important to note that while this solution has been judged as most 
efficient in view of limiting the liability of the organisers, it has been considered that 
organisers should also retain the possibility, as set out in section 4.2.3, to set up their 
own  and  independent  online  collection  systems  for  which  they  would  remain  fully 
responsible.  

  Limiting  or  transferring  the  responsibility  for  the  collection  in  paper  form.  The  full 
transfer of responsibility for the collection in paper form is not possible, unless such 
collection  takes  place  at  officially  designated  centres,  or  in  presence  of  a  public 
official  or  notary,  which  has  been  considered  as  overly  burdensome  in  view  of  the 
nature  and  objectives  of  the  instrument.  However,  the  responsibility  can  be 
substantially  limited  in  case  the  role  of  the  organisers  is  restricted  to  the  actual 
collection of statements in paper form which they can subsequently scan and upload in 
electronic  form  into  a  central  collection  system  managed  by  the  Commission.  They 
may in such case destroy the statements collected in paper form, after making sure that 
the  quality  of  the  uploaded  scanned  documents  allows  their  good  readability.  The 
Commission  then  takes  over  the  responsibility  for  storage  and  transfer  to  national 
authorities for verification. This solution is further analysed in section 4.2.3.  

  The option of collecting statements of support only online under the responsibility of 
the  Commission  has  been  discarded  as  it  would  unduly  limit  the  accessibility  of  the 

8 Directive 2008/99/EC of the European Parliament and of the Council of 19 November 2008 on the protection 
of the environment through criminal law 

13 

 
 
 
                                                            
instrument  given  the  high  amount  of  statements  of  support  collected  in  paper  form 
(around  45%  for  the  successful  initiatives  so  far).  However,  the  Commission  has 
recently  released  a  new  version  of  the  online  collection  software  that  is  compatible 
with  mobile  devices  such  as  smartphones  or  tablets.  Those  can  be  used  to  collect 
statements of support on the street or at organised events instead of paper forms. 

Taking into account the advantages and disadvantages of each of the options presented above, 
the current proposal comes forward with the following approach combining different aspects 
of direct and indirect reduction of the liability of organisers: 

  Limiting liability indirectly, by limiting the types of data to be collected (see section 

4.2.2 below); 

  Limiting liability indirectly, by allowing the organisers the choice of online collection 
via a central system managed by the Commission. In that case, the Commission will 
also  be  subsequently  responsible  for  the  transfer  of  collected  data  to  Member  States 
for  verification.  The  data  protection  liability  is  thus  transferred  to  the  Commission, 
given that the organisers will not need to have access to those data and process them.  
The  organisers  can  also  choose  to  remain  responsible  only  for  the  statements  of 
support  in  paper  form,  and  if  they  so  choose  only  for  a  limited  time  period  before 
scanning and uploading these statements of support into the central collection system 
managed by the Commission. To further minimise  their  liability, the organisers  may 
also  choose  to  collect  statements  of  support  through  mobile  devices  (submitting  the 
data  directly  to  the  central  online  collection  system  managed  by  the  Commission)  
instead of in paper form; 

  An  explicit  reference  in  the  Regulation  to  the  possibility  of  creating  a  legal  entity 
under  a  national  law  to  be  the  organiser  of  the  initiative  in  order  to  obtain  a  legal 
personality  and  transfer  the  personal  liability  of  the  organisers  to  the  legal  entity, 
without  making  this  solution  mandatory  for  the  organisers.  The  group  of  organisers 
will nevertheless still need to be constituted. 

  On  liability  aspects  beyond  personal  data  protection  (data  protection  liability  being 
governed  by  Regulation  (EU)  2016/6799),  limitation  of  the  liability  following  the 
model of Directive 2008/99/EC on the protection of the environment through criminal 
law, with a view to establishing that organisers are responsible for any damage caused 
in the organisation of an initiative by unlawful acts ‘committed intentionally or with 
serious negligence’.  

4.1.2.  Advice and support to organisers  

4.1.2.1. Advice to (potential) organisers 

In accordance with Article 4(1) of the Regulation, the Commission has established a point of 
contact providing information and assistance as regards the ECI, based in the Europe Direct 

9 Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons 
with regard to the processing of personal data and on the free movement of such data, and replacing Directive 
95/46/EC (hereafter 'General Data Protection Regulation') 

14 

 
 
 
 
 
                                                            
Contact Centre (EDCC) and backed by Commission services10. The Commission informally 
answers  all  questions  from  citizens  and  potential  organisers  via  this  point  of  contact  since 
2012,  including  questions  on  the  admissibility  of  their  envisaged  initiatives.  These 
assessments are provided without prejudice to any formal reply by the Commission following 
a possible request for registration of a proposed citizens' initiative.  

Information and guidance are also provided via a dedicated ECI website, the guide on the ECI 
available  both  online  and  on  paper  and  in  direct  communication  with  organisers,  via  their 
dedicated space (organiser account) on  the ECI website (all these services and materials are 
available in 24 official EU languages) but also by email and in dedicated meetings, hands-on 
trainings, phone and video-conferences whenever necessary. Organisers may also seek advice 
locally  in  Member  States  from  the  Commission  representations  and  the  network  of  Europe 
Direct Information Centres which are equipped with relevant electronic and paper materials.  

In the course of the review process ongoing since 2015, different suggestions have been put 
forward as regards further advice to be offered to the organisers, in particular in view of the 
high  rate of refusals  of registration of the proposed initiatives. Their main suggestions have 
been to: 

  Reinforce  the  advice  service  in  particular  concerning  the  preparation  of  initiatives. 
Different  formats  have  been  suggested  for  such  advice,  either  based  on  existing 
structures,  for  instance  reinforcing  EDCC  service  and  using  national  representation 
offices  of  the  Commission,  or  proposing  new  ones  to  be  built  such  as  a  helpdesk 
independent from EU institutions; 

  Develop  specific  online  helpdesks  and/or  online  platforms  supporting  the  organisers 
possibly  combined  with  a  central  online  collection  system  to  be  managed  by  the 
Commission; 

  Provide reinforced and independent preliminary legal advice as to the formulation and 

admissibility of possible initiatives. 

The legislative proposal takes  on board several suggestions expressed in the review process 
also providing a specific legal basis for the measures which have already been or are currently 
being implemented:  

-  The  provisions  relating  to  a  point  of  contact  are  replaced  by  new  ones  referring  to  a 
provision  of  information  and  assistance  about  the  European  citizens'  initiative  to  organisers 
and citizens.  

-  This  service  is  to  be  complemented  by  an  advice  service,  to  be  offered  via  an  online 
collaborative platform to be funded by the Commission and operated by an external partner 
equipped to provide the expertise needed to assist organisers.  

It  should  be  noted  that  the  launch  of  an  online  collaborative  platform  for  the  ECI  is  being 
prepared  by  the  Commission  under  a  pilot  project  from  the  Parliament11.  As  currently 

10 Statistics regarding the functioning of this service during the first three years of the implementation of the ECI 
can be found in the Commission Report of 2015: http://ec.europa.eu/transparency/regdoc/rep/1/2015/EN/1-2015-
145-EN-F1-1.PDF   
11  Pilot  project:  "New  technologies  and  information  and  communication  technology  (ICT)  tools  for  the 
implementation and simplification of European Citizens’ Initiative (ECI)" 

15 

 
 
 
                                                            
envisaged,  in  addition  to  independent  legal,  technical  and  campaigning  advice  in  particular 
focused  on  supporting  the  initiatives  in  preparation,  the  platform  shall  offer  a  space  for 
discussion and community building. The implementation of the pilot project is being prepared 
over the course of 2017 and it will continue over 2018, with the platform launch intended for 
spring 2018.  

Finally, in line with the stakeholders' suggestions, the proposal envisages that Member States 
establish  in  their  territories  a  contact  point  providing  information  and  assistance  to  help 
(potential)  organisers  setting  up  a  European  citizens’  initiative.  This  will  allow  citizens  to 
benefit  from  customised  advice  and  practical  information  locally,  including  as  regards  the 
aspects  of  the  Regulation  which  Member  States  are  in  charge  of.  Those  contact  points  can 
also  contribute  to  the  dissemination  of  information  around  the  instrument.  To  limit  the 
financial implications of setting-up such contact points, Member States may assign this task to 
competent  authorities  under  the  Regulation  or  existing  information  centres  on  participatory 
democracy or civic rights. 

4.1.2.2. Translations  

In  accordance  with  the  current  ECI  Regulation,  once  their  proposed  initiative  is  registered, 
organisers  can  provide  the  Commission  with  translations  of  their  proposed  initiative  in  any 
official EU languages. Before publication, the Commission verifies that there are no manifest 
and  significant  inconsistencies  between  the  translated  text  and  the  original  version  of  the 
content  of  the  proposed  initiative  (the  title,  the  subject-matter  and  the  objectives).  The 
publication  of  a  translation  allows  the  organisers  to  use  this  language  version  for  the 
description  of  their  proposed  initiative  included  in  the  formal  statement  of  support  forms. 
These  rules  are  aimed  at  ensuring  that  all  citizens  give  their  support  based  on  the  same 
initiative content in all languages. Organisers can also provide translations of the annex and 
draft  legal  act  that  they  may  have  included  in  their  registration  request  to  provide  more 
detailed information on their initiative, as well as translations of the provisions of the Treaties 
they have indicated as relevant for the proposed actions. Those translations are not verified by 
the Commission.  
Until April 2015, on average, proposed initiatives had been translated into 11 languages. Only 
four initiatives had provided translations in all official EU languages. In addition, around one 
third  of  translations  had  to  be revised  (once  or  several  times)  by  the  organisers  before  their 
publication. Organisers had difficulties to ensure the necessary accuracy of their translations, 
even on the basis of the comments received from the Commission on their first version(s).  
Since mid-2015, the European Economic and Social Committee (EESC) offers organisers the 
translation  of  the  content  of  their  proposed  initiatives  into  all  official  EU  languages  except 
Irish.  Most  organisers  have  accepted  this  offer  and  got  the  content  of  their  initiatives 
translated  by  the  EESC.  However,  in  most  cases,  those  translations  were  made  available 
several weeks after the date of registration of the initiative concerned. This delay shows that 
the process remains complex to manage for the organisers (they remain responsible to request 
the translations to the EESC and to then provide them to the Commission) and is also linked 
to the fact that the process cannot start before the registration of the initiative is confirmed.  
While  the  support  of  the  EESC  has  significantly  improved  the  situation,  there  is  still  some 
margin  to  further  simplify  the  procedure  and  reduce  the  burden  for  the  organisers  and  the 
institutions.  Publishing  translations  earlier  in  the  process  would  also  improve  transparency 
and offer wider access to all citizens, thus contributing to increasing participation in citizens' 
initiatives. 
The possible approaches include: 

16 

 
 
(1)  translations  to  be  provided  by  the  organisers  and  verified  by  the  Commission  (initial 
situation under the current Regulation); 
(2) translations to be provided by the organisers without verification by the Commission; 
(3) translations to be provided by the organisers with the help of the EESC; 
(4) translations to be provided by the Commission. 

Approach  (2) is  excluded as  it creates burden for organisers and the absence  of verification 
could lead to a situation where organisers collect support based on a different text depending 
on the language (intentionally or unintentionally).  

Among the three other approaches, the best option seems that the Commission should provide 
the translations of the initiatives' content combined with the fact that the start of the collection 
period  should  not  coincide  with  the  date  of  registration  of  the  initiative.  The  Commission 
would be responsible for publishing the translations in all official EU languages in the register 
after  registration  is  confirmed  and  before  the  start  of  the  collection  period  for  the  initiative 
concerned. The translations of the possible annex and draft legal act would remain optional 
and the responsibility of the organisers. 
The benefits include: 
- no cost borne by the organisers;  
- a simplified procedure for organisers and the Commission compared to the current service 
offered by the EESC upon request by the organisers; 
- all translations available as of the start of the collection period, to the benefit of organisers 
and signatories.   
While the costs will be borne by the Commission, those costs are likely to be comparable to 
the situation where  the Commission  is required to  verify the language versions provided by 
the  organisers  (initial  situation  according  to  the  current  Regulation)  and  overall,  costs  are 
reduced for the public administrations compared to the current offer of the EESC as this offer 
implies translation costs for the EESC and other administrative costs for the Commission to 
handle  the  process  with  the  organisers.  As  the  Commission  is  in  charge  of  the  ECI  register 
where those translations are published, it also seems appropriate that it is the Commission that 
takes care of the translations and publish them directly in the register, without requiring any 
particular action from the organisers.  

4.1.2.3. IT support measures 

Since  2012  the  Commission  has  implemented  a  number  of  measures  to  support  the  online 
collection process – See section 4.2.3 for both the current state of play and the improvements 
envisaged in the proposal. 

The Commission has also developed as part of the ECI register website an organiser account 
to facilitate the exchanges between the Commission and the organisers in particular as regards 
the  translations,  the  updates  of  funding  sources  and  the  submission  of  the  initiative.  In 
addition, the organisers can download in this account pre-completed forms for the collection 
in paper form, for which they can choose: 

- the country (the system then generates the form asking for the relevant data to be provided 
by signatories coming from this country);  

- the language of the form among all the official EU languages; 

17 

 
 
 
 
- the languages of the content of the initiative to be included in the form among the languages 
published in the register for the initiative concerned. 

The  register  will  be  maintained,  while  closer  integration  with  the  central  online  collection 
system is envisaged and new functionalities will be implemented to reflect the new provisions 
concerning  in  particular  the  paper  collection  of  statements  of  support  and  the  reporting  as 
regards the number of collected statements of support. 

4.1.2.4. Funding 

In the review process some stakeholders and in particular the European Parliament invited the 
Commission  to  explore  the  possibility  of  providing  financial  support  to  European  citizens' 
initiatives. Similar suggestions have been advanced by the organisers themselves. 

However,  the  Commission  is  of  the  opinion  that  such  an  approach  would  go  against  the 
principle  of  independence  of  citizens'  initiatives.  Moreover,  EU  funding  would  require 
organisers to take adequate measures to ensure respect of the obligations of the EU Financial 
Regulation, which would introduce additional and relatively burdensome obligations.  

Thus, the Commission has considered it more efficient that the organisers are offered support 
in  kind,  namely  in  form  of  different  services  offered  by  the  Commission  and  explained 
throughout  sections  4.1.2  and  4.2.3  and  including  assistance  and  advice,  translation  service 
and free of charge central online collection system. 

4.1.3.  Registration phase 

The  registration  phase  is  one  of  the  main  stages  of  the  ECI  lifecycle  since  successful 
registration  of  their  proposed  citizens'  initiative  allows  organisers  to  effectively  start  the 
collection  of  statements  of  support  for  their  initiatives  and  related  activities  such  as 
communication campaigns and raising awareness about their initiatives. 

The Regulation foresees a registration phase to ensure coherence and transparency in relation 
to proposed citizens’ initiatives and to avoid a situation where signatures are being collected 
for a proposed citizens’ initiative which does not comply with the conditions laid down in the 
Regulation. To this end, the organisers shall register their initiative with the Commission prior 
to starting the collection of statements of support. 

To  be  registered,  the  proposed  initiatives  have  to  currently  meet  the  conditions  set  out  in 
Article 4(2) of the Regulation, which provides for the following requirements: (i) a citizens’ 
committee has been formed and the contact persons have been designated; (ii) the proposed 
initiative  does  not  manifestly  fall  outside  the  framework  of  the  Commission’s  powers  to 
submit a proposal for a legal act of the Union for the purpose of implementing the Treaties; 
(iii)  the  proposed  initiative  is  not  manifestly  abusive,  frivolous  or  vexatious;  and  (iv)  the 
proposed initiative is not manifestly contrary to the values of the Union as set out in Article 2 
of  the  Treaty  on  European  Union.  Article  4(3)  of  the  Regulation  provides  that  the 
Commission  shall  refuse  the  registration  if  the  conditions  laid  down  in  paragraph  2  are  not 
met. 

18 

 
 
 
 
 
 
 
The  Commission  has  two  months  to  verify  that  the  conditions  listed  under  Article  4(2)  are 
met. The Regulation also foresees the establishment of an official register and website for the 
ECI where the initiatives are registered and made publicly available. 

Since the entry into application of the Regulation in 2012, a total of 47 proposed initiatives 
have been registered by the Commission in a wide range of EU policy areas12. At the same 
time, during the same period of 2012-2017, a total of 21 proposed initiatives did not meet the 
registration  criteria  and  were  not  registered13,  20  of  them  during  the  first  two  years  of 
implementation.  

Figure 3: Registration of initiatives 

2012 

2013 

2014 

2015 

2016 

2017 

Total 

Number  of  requests  for 
registration 

27 

16 

Number  of 
initiatives 

registered 

16 

Number 
requests for registration 

refused 

of 

7 

9 

8 

8 

5 

5 

5 

6 

0 

5 

3 

0 

5 

814 

1 

66 

47 

21 

Source: ECI register 

Six  citizens'  committees  decided  to  bring  proceedings  before  the  General  Court  of  the 
European  Union  as  regards  the  Commission  decisions  refusing  the  registration  of  the 
proposed initiatives. In four of these cases, the General Court has confirmed the Commission 
decisions  refusing  the  registration  of  the  proposed  citizens'  initiatives15.  In  two  cases  the 
General  Court  has  annulled  the  Commission  decisions  refusing  the  registration  of  the 
proposed initiatives16. In both cases the Commission has not appealed the judgements of the 
General Court and has already adopted new decisions on the registration of the initiatives to 
comply with the judgements of the Court. 

The  Commission  report  on  the  application  of  the  Regulation  of  March  2015  acknowledged 
that registration was a major challenge for the organisers as an important number of proposed 
ECIs did not meet the conditions for registration and could not be registered. The importance 
of  implementing  improvements  in  the  registration  has  also  been  raised  by  other  EU 
institutions and bodies as well as by organisers and civil society stakeholders in the context of 
the ECI review process launched in 2015. 

12 http://ec.europa.eu/citizens-initiative/public/welcome  
13 http://ec.europa.eu/citizens-initiative/public/initiatives/non-registered 
14 Two initiatives have been registered following decisions of the General Court of the EU. 
15 "One Million Signatures for "A Europe of Solidarity"", "Right to Lifelong Care: Leading a life of dignity and 
independence is a fundamental right!", "Cohesion policy for the equality of the regions and sustainability of the 
regional cultures" and "Ethics for Animals and Kids" 
16 "Minority SafePack – one million signatures for diversity in Europe" and "Stop TTIP" 

19 

 
 
 
 
 
 
 
 
 
                                                            
Options for improvement have already been considered and implemented by the Commission 
under  the  existing  legal  framework.  Since  2015,  the  decisions  on  the  proposed  citizens' 
initiatives  are  adopted  by  the  College  of  Commissioners.  This  demonstrates  the  importance 
given by the Juncker Commission  to the ECI  and to  the priority of listening to citizens and 
their concerns as raised in the different citizens' initiatives. This also brings benefits in terms 
of  communication  and  awareness-raising  via  for  instance  the  publication  of  press  releases 
after the adoption of decisions by the College of Commissioners.  

In addition, the Commission has more recently implemented a more citizen-friendly approach 
in the registration phase including in particular the possibility of registering initiatives in case 
where  only  part(s)  of  the  initiative  meet  the  conditions  for  registration.  In  these  cases,  the 
Commission  adopts  a  decision  explaining  the  conditions  of  the  registration,  including  the 
elements of the initiative which are registered by the Commission decision and the basis on 
which  statements  of  support  for  the  initiative  may  be  collected.  This  new  approach  has 
already been applied to a set of initiatives registered in the course of 2017. The Commission 
has  also  ensured  full  transparency  by  publishing  all  the  registration  decisions  in  the  ECI 
register website.  

These  improvements  have  contributed  to  the  overall  decrease  of  the  number  of  refused 
requests for registration in the past years. Since the adoption of the Commission report on the 
application of the Regulation in March 2015, a total of 16 initiatives have been registered by 
the Commission while only one request had to be refused. 

The  majority  of  the  contributions  and  responses  to  the  public  consultation  converge  on  the 
need  to  register  the  initiatives  with  the  Commission  prior  to  starting  the  collection  of 
statements of support. This is a safeguard for organisers and citizens to ensure transparency 
and to avoid a situation where signatures are being collected for an initiative which does not 
comply with the conditions laid down by the Treaties and the Regulation. For these reasons, 
options  to  remove  the  ex-ante  admissibility  check  have  been  discarded  and  the  preferred 
option is to maintain this check in the registration of initiatives in the ECI register prior to the 
start of the collection period. 

At  the  same  time,  the  registration  phase  remains  one  of  the  main  challenges  in  the 
implementation of the ECI instrument. Therefore, further options for improvement have been 
considered. The contributions of other EU institutions, bodies and stakeholders in the context 
of the review process and the results of the public consultation converge in the main areas for 
improvement in this phase notably as regards (i) enhanced advice and support to organisers, in 
particular  as  regards  registration  requirements  as  well  as  (ii)  a  more  citizen-friendly 
registration procedure allowing for the possibility of partial registration of initiatives. The two 
aspects  are  considered  complementary  and  are  therefore  both  taken  into  account  in  the 
proposal.  

Some  alternative  suggestions  made  in  the  context  of  the  review  process  have  not  been 
incorporated  in  the  proposal  in  view  of  the  fact  that  the  improvements  foreseen  therein 
already provide for comprehensive improvement of the registration  procedure through more 
flexible  and  citizen-friendly  means.  This  is  the  case  for  instance  of  proposals  regarding  the 
possibility  of  establishing  an  independent  ad  hoc  impartial  committee  or  an  ECI  officer, 
similar to the Hearing Officer for competition law, to advise organisers on the admissibility of 
proposed  initiatives.  The  proposal  addresses  these  suggestions  of  external  advice  and 
flexibility for organisers through the possibility of getting advice via an online collaborative 

20 

 
 
 
 
 
 
 
platform  as  well  as  through  providing  information  and  assessment  to  organisers  by  the 
Commission  on  their  proposed  initiatives  in  certain  cases  and  the  possibility  of  partial 
registration within the procedure itself, without adding complexity and additional layers to the 
registration phase. 

With regard to the requirements for registration of initiatives, the proposal maintains the main 
requirements  which  derive  from  the  scope  of  the  European  citizens'  initiative  under  the 
Treaties. In accordance with Article 11(4) of the Treaty on European Union, not less than one 
million  citizens  who  are  nationals  of  a  significant  number  of  Member  States  may  take  the 
initiative inviting the European 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.  

Consequently, the proposal maintains the main requirement for the registration, providing that 
the  initiative  proposed  by  the  group  of  organisers  does  not  manifestly  fall  outside  the 
framework  of  the  Commission  powers.  This  requirement  is  complemented  with  the 
safeguards regarding: (i) proof that the group of organisers (and the legal entity created for the 
purpose of managing the initiative, if any) meets the requirements under the Regulation  (ii) 
the specific cases of potentially abusive, frivolous or vexatious initiatives; and (iii) initiatives 
manifestly contrary to the values of the Union. 

Against  this  background,  the  proposal  implements  further  improvements  in  the  registration 
phase and contains a set of measures aiming at supporting organisers, in particular with regard 
to:  

 -  Enhanced  advice  and  support  to  organisers  of  initiatives  via  an  online  collaborative 
platform complementing the assistance and information service run by the Commission (see 
section 4.1.2. for more detail); and  

-  A  more  citizen-friendly  registration  procedure,  including  the  possibility  of  providing 
information  to  the  group  of  organisers  as  regards  their  initiative  in  cases  where  the 
requirements for registration are not met by the initiative as well as the option of registering 
initiatives partially under certain conditions.. 

First,  with  regard  to  the  objective  of  making  the  procedure  more  citizen-friendly  and 
addressing the concerns as regards the registration refusals, the proposal foresees that where 
only  part  or  parts  of  an  initiative  meet  the  registration  requirement  on  the  Commission’s 
powers to submit a proposal for a legal act of the Union for the purpose of implementing the 
Treaties, the Commission  informs the group  of organisers  of its assessment and the reasons 
thereof. Organisers have then the possibility of modifying their initiative or  maintaining the 
initial proposal if they so wish. In these cases, the proposal foresees an extension of the time 
limit from 2 to 3 months to give more time to organisers to amend their initiative in light of 
the assessment by the Commission. 

Secondly, the proposal foresees that an initiative can be partially admissible in cases where a 
substantial part of the initiative, including its main objectives, does not fall manifestly outside 
the framework of the Commission’s powers to submit a proposal for a legal act of the Union 
for the purpose of implementing the Treaties. In this regard, the proposal improves the current 
framework by clarifying the conditions for an initiative to be partially admissible as well as 
enhancing  transparency  and  ensuring  that  citizens  are  informed  of  the  conditions  of  the 
registration when considering providing support to the initiative. 

21 

 
 
 
 
 
 
Thirdly,  the  proposal  enhances  transparency  and  publication  of  information  with  regard  to 
registered  initiatives  through  maintaining  the  publication  of  all  the  initiatives  in  the  ECI 
register as well as providing that the Commission shall inform the European Parliament, the 
Council, the European Economic and Social Committee and the Committee of the Regions of 
the registration of initiatives.  

Finally, the proposal also introduces a number of updates and improvements in the Annex II 
form on the required information for registering an initiative. These changes aim to reflect the 
new provisions on the group of organisers and the registration of initiatives and increase the 
maximum number of characters for the initiative content allowing organisers more flexibility 
to describe their proposal. 

4.2.  Collecting statements of support and their verification 

4.2.1.  Minimum age for signatories 

The current ECI Regulation obliges citizens to be of voting age in the European Parliament 
elections to give their support to a citizens' initiative. The voting age in all Member States is 
18 with the exception of Austria where it is set at 16. 
As part of the review process, several stakeholders17 have asked allowing citizens aged 16 and 
17 to support initiatives, beyond Austria. 42% of the respondents to this question of the public 
consultation also supported the idea of harmonising the minimum age at 16. 
While  requiring  the  voting  age  is  the  most  common  approach  for  similar  participatory 
democracy instruments at national or local level, in several cases the minimum age has been 
set below the voting age (16 or 15 years old) to encourage participation of young people and 
stimulate democratic life beyond representative democracy mechanisms. This is especially the 
case for instruments recently introduced or amended.   
For  example,  in  Estonia  since  spring  2014,  citizens  can  send  "collective  initiatives"  to  the 
Parliament for consideration. According  to  the Estonian law, the Parliament has to  consider 
initiatives  that  have  gathered  at  least  1000  signatures  from  citizens  aged  at  least  16.  In 
Luxembourg, the  minimum age  to support  "public petitions"18 is  15 years  old.  In  Germany, 
several Länder have "popular petition" mechanisms for which the minimum age to participate 
is 16 (e.g. Federal state of Berlin, Federal state of Bremen). Similarly, in Belgium, although 
the  nature  of  the  instruments  may  not  be  fully  comparable  to  the  ECI,  the  petition  rights  at 
national  and  regional  level  (Brussels,  Flanders  and  Wallonia)  allow  the  support  of  citizens 
from the age of 16. 
While  at  the  beginning,  the  minimum  age  was  calibrated  to  follow  the  voting  age  for 
European Parliament elections, these examples demonstrate that lowering the minimum age to 
16  can  be  a  useful  way  to  engage  young  people  in  democratic  processes.  In  contrast  with 
elections,  the  ECI  is  of  a  non-binding  nature  and  an  instrument  for  agenda  setting.  In  this 

17  Notably  suggested  by  the  European  Parliament  in  its  report  of  October  2015,  the  European  Economic  and 
Social Committee in its opinion of October 2016 and the ECI Campaign. The ECI Campaign is a coalition of 
citizens, activists and non-governmental organisations, including organisers of citizens' initiatives. 
18  Public  petitions  must  be  of  general  and  national  interest.  As  soon  as  the  public  petition  receives 
4.500 signatures,  a  public  debate  in  the  Petitions  Committee  and  the  relevant  sectorial  Committee  of  the 
Luxembourgish  Chamber  of  Deputies  is  organised  in  the  presence  of  maximum  6  petitioners  and  of  the 
competent Minister. 

22 

 
 
 
 
 
                                                            
context it can be argued to be proportionate to broaden the participation to young people and 
harmonise the minimum age at 16 for all EU citizens.    

Setting  the  minimum  age  at  16  could  create  administrative  burdens  for  Member  States  as 
regards the verification of statements of support provided by citizens aged 16 or 17. However, 
based  on  the  information  available,  most  Member  States  do  not  use  electoral  rolls  for  the 
verification of statements of support. They rather use population registers which normally also 
include citizens between 16 and 18 years old19. In addition, under the current rules, Member 
States  who  verify  their  nationals  are  expected  to  be  able  to  verify  statements  of  support  of 
their nationals residing in Austria from the age of 16.  

Offering young people from the age of 16 the possibility to support a citizens' initiative would 
contribute  to  raising  their  awareness  about  the  EU  and  its  functioning  and  reaching  the 
objective of increasing participation in the democratic debate at EU level, especially among 
the younger generation. 

Based  on  the  above,  giving  such  opportunity  to  the  European  youth  would  be  possible, 
without  creating  a  significant  additional  burden  for  Member  States.  Therefore,  the  proposal 
harmonises the minimum age for signatories of citizens' initiatives at 16. 

4.2.2.  Data to be provided by signatories and verification by Member States  

According to the Regulation, signatories (citizens of the Union) must fulfil the requirement of 
a  link  of  nationality  or  residence  with  a  given  Member  State  and  provide  personal  data, 
allowing  thereby  that  Member  State  to  verify  its  statements  of  support.  These  requirements 
vary from one Member State to another.  

Signatories  can  give  their  support  in  paper  form  or  online,  on  the  basis  of  forms  compliant 
with the model set out in Annex III to the Regulation. The signatories' data requirements set 
out  in  this  Annex  can  be  modified  by  a  Commission  delegated  act  at  the  request  of  the 
Member States concerned. 
Several issues have been raised as regards the requirements set out in this Annex: 

-  the  divergences  in  the  criterion  used  by  Member  States  to  define  the  scope  of  their 
verification  (whether  they  verify  their  nationals,  their  residents  or  both)  prevent  some  EU 
citizens from being able to support a citizens' initiative20; 

- the high amount of personal data required by some Member States, including sometimes a 
personal identification number, could deter citizens from giving their support;  

-  the  different  sets  of  data  make  it  complex  for  organisers  to  organise  the  collection,  in 
particular in paper form. Currently, 13 different forms (requesting different personal data) are 
in use21.  

Since  2012,  the  Commission  has  continuously  encouraged  Member  States  to  simplify  their 
requirements. Several Member States have already responded positively to the Commission's 
calls  for  simplification.  A  modification  of  Annex  III,  which  entered  into  force  in  2013, 

19 See study on data requirements for the European Citizens' Initiative for the registers used 
20 This concerns Irish and British citizens living in Austria, the Czech Republic, France, Portugal, Bulgaria and 
outside the EU. 
21 See annex 5 for the data requirements asked in the different Member States 

23 

 
 
                                                            
contained  changes  suggested  by  Spain,  Ireland,  France,  Luxembourg,  the  Netherlands  and 
Slovenia.  In  particular,  the  Netherlands  opened  the  possibility  for  Dutch  nationals  living 
outside the Netherlands to give their support on a Dutch form, and Spain the possibility for 
non-Spanish  EU  citizens  residing  in  Spain  to  give  their  support  on  a  Spanish  form,  thus 
reducing the number of citizens excluded from their right to support an initiative. A second 
modification, which entered into force in 2015, further simplifies the requirements for Latvia, 
Malta and Sweden. While those changes have contributed to simplify the system, they have 
addressed the issues described above only to a limited extent. 

4.2.2.1. Verification of statements of support by Member States 

To guarantee the legitimacy and credibility of citizens' initiatives, a degree of verification of 
the  statements  of  support  provided  by  signatories  should  be  ensured.  However,  the 
verification  mechanism  should  remain  proportionate  to  the  nature  of  the  instrument  and 
should not create unnecessary burden on Member States.  
The  current  Regulation  provides  that  Member  States  shall  carry  out  the  verification  of 
statements of support on the basis of appropriate checks, in accordance with national law and 
practice and that the authentication of signatures shall not be required (Article 8). The checks 
may  be  based  on  random  sampling  (recital  18).  The  Regulation  also  sets  out  that  only  the 
personal  data  of  the  signatory  necessary  for  the  verification  by  the  Member  States  shall  be 
collected.  
These provisions were designed to leave some flexibility for Member States so that existing 
procedures  at  national  level  could  be  used,  therefore  limiting  the  administrative  burden. 
However, this has led to a situation where the scope of the data requested to signatories and of 
the subsequent verification process differs from one Member State to the other22. In particular, 
while  this  is  not  foreseen  in  the  current  Regulation,  some  Member  States  request data  from 
signatories that are not strictly needed to verify the statement of support and that, according to 
the study on signatories' data requirements, are not verified in practice. Some seem to request 
additional data to discourage impersonation.   
Before analysing the different options possible to simplify the data required from signatories, 
it is important to clarify what the verification of the statements of support by Member States 
should cover.  
Given  the  nature  of  the  ECI  instrument,  it  seems  proportionate  to  consider  that  the  data 
provided by signatories should allow Member States to: 
- identify the signatory in the relevant database/register; 
- verify the eligibility of the signatory, i.e. whether he/she is an EU citizen (national of an EU 
Member State) and of the minimum age;  
- verify that a citizen has given his support only once and within the collection period. 
So far, no instances of significant fraud have been reported. The study has concluded that the 
current verification approach is well designed compared to similar instruments at regional and 
national level. 

Therefore,  the  proposal  does  not  foresee  any  change  in  the  scope  of  the  verification  to  be 
carried  out  by  Member  States  and  the  purpose  of  collecting  personal  data  from  signatories 
remains the same. 

22 See study on data requirements for the European Citizens' Initiative 

24 

 
 
 
                                                            
4.2.2.2. Personal data requirements for signatories 

The current personal data to be provided by signatories vary from Member State to Member 
State, leading to a complex procedure for organisers when collecting statements of support, in 
particular in paper form. All stakeholders, with the exception of some national authorities in 
charge  of  the  verification  of  statements  of  support,  have  voiced  the  view  that,  in  many 
Member States, signatories are required to provide too much data. In particular, as highlighted 
in  the  study  on  signatories'  data  requirements23,  10  Member  States  use  fewer  data  for 
verification  than  signatories  are  required  to  provide.  Considering  that  the  data  should  be 
limited  to  what  is  necessary  to  identify  a  unique  person  in  a  population  register  and  verify 
his/her  age  and  nationality  (as  explained  above),  it  seems  clear,  notably  in  those  Member 
States  where  a  personal  identification  (document)  number  is  required,  that  Member  States 
require  more  data  than  needed.  Based  on  the  identification  number  which  is  unique  to  an 
individual, Member States should be able to identify the person in the relevant register and to 
consult the other data necessary to verify the eligibility of the signatory.  

The  study  on  signatories'  data  requirements  also  showed  that  the  risk  of  reduced  ECI 
participation  due  to  too  many  data  should  be  given  high  priority.  However,  the  study  could 
not establish statistically significant causal links between a reduction in data requirements and 
an  increase  in  the  participation  in  ECIs  although  inferences  can  be  made  based  on  agreed 
indicators that affect participation and upon existing literature and stakeholder consultation.  

As regards the sensitivity of providing some types of data, one of the findings of the study on 
data  requirements  is  that  stakeholders  in  most  Member  States  (21  Member  States)  have  no 
real  concerns  over  the  sensitivity  of  the  signatories'  data  requirements.  However,  where 
concerns  have  been  raised,  they  primarily  relate  to  the  provision  of  personal  identification 
(document) numbers. More generally, the issue of sensitivity appears to relate more to trust in 
the entity collecting the data than to the nature of the data. This level of trust (as regards the 
public authorities and organisers of initiatives) varies from Member State to Member State.  It 
also appears from the results of the public consultation that the sensitivity to provide certain 
data varies from country to country. 

The study on data requirements also highlighted that more data are required for the ECI than 
for  instruments  at  national  or  local  level  with  similar  outcomes,  therefore  questioning  the 
proportionality of the data required with the potential outcome of an ECI.  

The comparison with other similar instruments showed that one of the main strengths of  the 
ECI scheme is that it allows citizens to give support online and in paper form. While different 
mechanisms could be put in place to facilitate the support online and the verification of this 
support while minimising the number of data required (see also the subsequent section on the 
online collection and the use of e-ID), there is a need to streamline the data to be provided by 
signatories  as  they  will  in  any  case  apply  to  those  statements  of  support  provided  in  paper 
form.  

Several  approaches  to  streamline  those  data  requirements  have  been  analysed  as  part  of  the 
study with as main objectives: 

-  to  simplify  and,  as  far  as  possible,  harmonise  the  data  requirements  for  signatories  of 
statements of support, making them more proportionate to the nature of the ECI instrument; 

23 See study on data requirements for the European Citizens' Initiative 

25 

 
 
                                                            
- to ensure that all eligible EU citizens can support an ECI; 

- to ensure an adequate verification process with a minimal burden for Member States;  

- to ensure that the personal data of supporters is safeguarded. 

The  subsequent  section  explains  that  Member  States  should  be  required  to  verify  the 
statements  of  support  for  their  nationals,  ensuring  that  all  eligible  EU  citizens  are  able  to 
support  an  ECI.  It  is  thus  necessary  that  signatories  provide  their  nationality  so  that  their 
statements of support are submitted to the relevant national authority for verification.  

In  view  of  the  objectives  to  be  achieved  and  based  on  the  available  information  on  the 
verification  processes  in  place  in  the  Member  States,  including  the  registers  used  for 
verification  of  the  data provided  and  the  information  contained  in  those  registers,  two  main 
approaches exist:  

Approach (1): signatories should all provide the same data based on the most common set of 
data available in the registers used for verification:  

first names, family names, date of birth and address. 

Approach (2): depending on the Member States, signatories should provide either:  

a/ first names, family names, date of birth and address  

or 

b/  first  names,  family  names  and  last  four  characters  of  a  personal  identification 
(document)  number  –  NB:  the  age  would  be  checked  based  on  information  available  in  the 
register used for the verification. 

Both  approaches  would  significantly  reduce  the  amount  of  personal  data  collected  in  the 
context  of  an  ECI  and  would  therefore  contribute  to  reaching  the  objectives  of  making  the 
data requirements more proportionate to the outcome of an ECI, facilitating the protection of 
the  signatories'  personal  data  and  therefore  reducing  the  potential  liability  issues  for 
organisers. 

Approach (1) has the additional advantage of: 

- ensuring that all citizens must provide the exact same data; 

- requiring simple information from citizens, meaning that they do not need to have their ID 
card or passport with them to give support. In addition, providing this information is generally 
perceived as less sensitive than providing a personal identification (document) number.  

Several shortcomings are also associated with approach (1): 

The  address  is  currently  not  requested  by  12  Member  States.  It  also  seems  that  for  various 
reasons  addresses  are  not  always  a  reliable  data  in  the  population  registers.  They  are  not 
always  regularly  updated,  especially  in  those  countries  where  citizens  are  not  required  to 
declare  their  change  of  address  to  the  authorities.  Citizens  living  outside  their  country  of 
nationality may also not have their address registered with their national authorities. Verifying 
on  the  basis  of  the  address  is  in  those  countries  likely  to  generate  the  invalidation  of 
statements  of  support  that  should  have  been  validated  if  the  register  contained  up-to-date 

26 

 
 
 
 
information on the address of the citizens. As a result, the address should not be used by those 
countries to verify against the register and the verification could only be based on the names 
and dates of birth of signatories. However, names and dates of birth might not be enough in 
some cases to uniquely identify a citizen in the register. 

Furthermore,  providing  the  address  is  seen  as  sensitive  in  some  countries.  In  the  public 
consultation, when asked which data citizens are not willing to provide to give support to an 
initiative,  overall  28%  of  respondents  mentioned  the  address.  The  address  scores  equal  or 
higher than the personal identification (document) in nine countries (eight of them currently 
requiring such a number).  

This  set  of  data  would  also  amount  to  an  increase  in  the  number  of  data  to  be  provided  in 
six Member  States  (those  Member  States  that  require  only  the  names  and  personal 
identification (document) number - currently the set of data mostly used).  

This  approach  may  also  increase  the  administrative  burden  in  those  Member  States  who 
currently use the personal identification (document) number as a basis for their verification.  

Approach (2)  

Compared to the first approach, this approach would provide for a more reliable verification 
process  in  those  countries  where  addresses  cannot  be  used  and  therefore  ensure  a  more 
comparable level of verification in all countries.  

In addition, this approach ensures that there is no increase in the number of data required in 
any  Member  State  (except  Finland  which  only  requires  the  country  of  permanent  residence 
and not the full address but this would be the case in both approaches). 

This approach would also better take into consideration any sensitivities at national level (i.e. 
depending on the Member State, providing the address seems more sensitive than providing 
the last three or four characters of a personal identification (document) number).  

This  approach  is  also  closer  to  the  current  system  where  some  countries  ask  for  a  personal 
identification  (document)  number  and  others  do  not  and  is  therefore  likely  to  create  less 
administrative burden than approach (1) for Member States to adapt their verification process. 

Approach  (2)  has  the  disadvantage  of  proposing  an  approach  that  is  not  fully  harmonised 
across Member States, even if the two sets of data (without any other variations) provide for a 
relatively  simple  approach.  This  option  also  maintains  the  provision  of  part  of  a  personal 
identification (document) number which is considered as sensitive by many citizens  (around 
35% of respondents to the public consultation), although less sensitive than providing the full 
number (around 50% of respondents). The risks associated with the disclosure of those partial 
numbers  are  also  significantly  reduced  compared  to  the  disclosure  of  the  full  numbers.  To 
note  that  providing  only  the  last  four  characters  and  not  the  full  number  might  increase  the 
risk of mistakes by citizens when filling in the information and might increase the burden for 
Member States to carry out the verification process (but probably still less than approach (1)).    

Overall,  the  preferred  option  is  therefore  approach  (2)  given  that  it  would  significantly 
simplify  the  data  to  be  provided  by  signatories.  It  would  facilitate  the  collection  for  the 
organisers who would need to use only two types of forms instead of 13 and would reduce the 
reluctance of citizens to provide their personal data. It will also limit the amount of personal 
data organisers would be responsible for. Finally, compared to approach (1), it will ensure a 

27 

 
 
more  adequate  verification  process  preventing  the  undue  invalidation  of  statements  of 
support, while creating less administrative burdens on Member States.  

The proposal therefore sets out that Member States shall choose the form that allows them to 
carry out the verification process in an appropriate way (i.e. whether they are able to verify 
the  signatories'  addresses  or  not)  and  taking  into  account  any  preference  at  national  level 
related to the sensitivity to provide certain types of data. The Member States shall inform the 
Commission  of  their  choice  at  the  latest  six  months  before  the  entry  into  application  of  the 
Regulation so that the Commission can publish this information in the register and configure 
the  central  online  collection  system  and  the  organiser  account  accordingly  before  the 
Regulation starts to apply.  

4.2.2.3. Criterion to define which Member State is in charge of the verification 

Under  the  current  Regulation,  depending  on  the  Member  State,  they  verify  only  their 
nationals, only their residents or both24. While this has no effect on the vast majority of  EU 
citizens  who  reside  in  their  country  of  nationality,  it  creates  cases  where  some  EU  citizens 
living outside their country of nationality (namely Irish and British citizens living in certain 
EU countries and outside the EU) are unable to support a citizens' initiative. 
Moreover, even if not permitted by the Regulation, in the current situation, some citizens may 
sign the initiative several times, once using the form of their country of nationality and once 
using the form of their country of residence and this cannot be detected by Member States. 
In  view  of  the  purpose  of  the  instrument,  revised  rules  should  have  as  primary  objective  to 
prevent the exclusion of any citizens from the right to support citizens' initiatives. Additional 
objectives include: 
-  simplify  the  collection  process  for  organisers  and  signatories,  making  it  simple  for  all 
citizens to understand which form they should use to give their support; 
- reduce the risk of multiple statements of support that cannot be detected; 
- reduce or at least avoid creating additional administrative burden for Member States. 
Three alternatives to the current situation have been analysed: 
(1) Member States should all verify the statements of support from their residents; 
(2) Member States should all verify the statements of support from their nationals; 
(3) Member States  should  all  verify the statements  of support  from their residents  and their 
nationals. 

All  would  contribute  to  simplifying  the  collection  process  given  that  the  criterion  would  be 
the same for all Member States contrary to the current situation. 
As  regards  the  prevention  of  excluded  citizens,  the  first  option  (residents  only)  should  be 
discarded  as  all  EU  citizens  living  outside  the  EU  would  be  unable  to  give  support  to 
initiatives, thereby significantly increasing the exclusion of citizens. It may also leave some 
citizens without the possibility to give support in those Member States where non-national EU 
citizens are not required to register/do not hold any document or number as of their arrival in 
their  country  of  residence.  The  second  (nationals  only)  and  third  (nationals  and  residents) 

24 For details on the requirements in each country, see annexes 6 and 7.  

28 

 
 
 
 
                                                            
options  both  ensure  that  all  EU  citizens  can  give  their  support.  Using  only  one  criterion 
(namely nationality) has the additional advantages of reducing the risk of undetectable double 
statements of support  and limiting  or  reducing  the administrative burden compared to  using 
both  criteria.  Indeed,  the  third  approach  creates  an  additional  burden  for  both  the  Member 
States  that  currently  verify  the  statements  of  support  only  from  their  residents  and  the 
Member States that currently verify the statements of support only from their nationals and it 
maintains  the  burden  for  the  other  Member  States  to  verify  both  their  nationals  and  their 
residents,  sometimes  with 
in  additional 
databases/registers.  

to  proceed  with  verification 

the  need 

Figure 4: Summary table  

Prevent exclusion  Simplify 

collection process 

risk  of 

Reduce 
undetectable 
double statements 

Reduce 
administrative 
burden 

(1) Residents only 

(-) 

(2) Nationals only 

(+) 

(3)  Residents  and 
nationals  

(+) 

(+) 

(+) 

(+) 

(+) 

(+) 

(-) 

(+) 

(++) 

(-) 

The  second  approach  seems  therefore  to  be  the  most  appropriate  to  reach  the  objectives.  It 
will nevertheless require two Member States (Ireland and the United Kingdom) to establish a 
verification mechanism for their nationals living outside their respective territories (based on 
the information that those citizens live abroad, those Member States should be able to carry 
out verification in their databases of travel documents such as passports).  
In a few cases (Denmark, Belgium, Luxembourg, Germany), it will require that their nationals 
living  outside  the  country  have  informed  their  relevant  national  authorities  of  their  place  of 
residence  whereas  in  the  current  system,  those  citizens  might  have  had  the  possibility  in 
certain countries to give support on the basis of their country of residence.  
From the point of view of the organisers, the use of one criterion will make it easier to explain 
which  form  citizens  must  use,  namely  the  one  of  their  nationality  in  all  cases.  In  addition, 
given that only two types of form will be possible without any deviations, they would simply 
need to carry with them both forms to cover any possible situations (i.e. EU citizens of any 
nationality).  

4.2.3.   Online collection 

The  online collection  of  statements  of  support from  signatories  is  a  fundamental  element  in 
the implementation of the ECI lifecycle. While the ECI Regulation provides that statements of 
support  can  be  collected  both  online  and  on  paper,  online  collection  provides  organisers  of 
citizens' initiatives with more effective and technologically up-to-date mechanisms to obtain 
support for their initiatives from signatories across the EU. This is considered as one of the 
strengths  of  the  ECI  instrument  compared  to  similar  instruments  at  national  and  local  level 
which often do not offer such possibility.  

Moreover,  there  may  be  synergies  between  the  online  collection  process  and  the  online 
campaigns developed by organisers to gather support for their initiatives, for instance through 

29 

 
 
 
 
 
 
dedicated  websites  and  use  of  social  media.  The  existence  of  challenges  for  organisers  as 
regards the tools  and  processes  for the  online  collection  of  statements  of  support  across  the 
EU  hampers  the  chances  for  the  initiative  to  reach  the  1-million  threshold  of  statements  of 
support and consequently the overall functioning of the ECI instrument.  

4.2.3.1. Current rules on online collection systems and support measures 

The ECI Regulation provides for a set of legal requirements in relation to the online collection 
systems. According to Article 6, organisers must build their online collection system and get 
it certified by the competent authority in the Member State where the data collected will be 
stored before starting to collect statements of support online via this system.  

In  view of the fact that organisers  of citizens' initiatives  can potentially  collect the personal 
data of more than one million EU citizens, their online collection systems must in particular 
have  the  necessary  technical  and  security  features  to  protect  these  personal  data.  In 
accordance  with  Article  6(4)  of  the  ECI  Regulation,  online  collection  systems  should  have 
adequate  security  and  technical  features  in  place  in  order  to  ensure  that:  (i)  only  natural 
persons  may  submit  a  statement  of  support  form  online;  (ii)  the  data  provided  online  are 
securely collected and stored, in order to ensure, inter alia, that they may not be modified or 
used for any purpose other than their indicated support of the given citizens’ initiative and to 
protect personal data against accidental or unlawful destruction or accidental loss, alteration 
or unauthorised disclosure or access; and (iii) the system can generate statements of support in 
a form complying with the models set out in Annex III, in order to allow for the verification 
by the Member States in accordance with Article 8(2). 

To  support  organisers  in  the  development  of  their  online  collection  systems,  the  Regulation 
provides that the Commission shall set up and thereafter maintain a software incorporating the 
relevant technical and security features necessary for compliance with the provisions of this 
Regulation  regarding  the  online  collection  systems.  The  Regulation  provides that  the  online 
collection  software  shall  be  open  source  and  made  available  free  of  charge  to  organisers  of 
initiatives. Organisers can use the Commission's software (with or without modifications) or 
another software of their choice. 

The  software  developed  by  the  Commission  provides  a  set  of  functionalities  to  collect 
statements of support online through forms compliant with the ECI Regulation, securely store 
signatories' data and export the data for their subsequent submission to the competent national 
authorities in the Member States. The administration interface enables organisers to configure 
their system, monitor the number of statements of support received and export the data. The 
public  interface  includes  the  electronic  statement  of  support  form  for  signatories  to  support 
the  proposed  initiative.  Once  the  signatory  has  chosen  the  country  he/she  comes  from,  the 
relevant form is dynamically displayed. 

The  software  has  been  available  since  22  December  2011  free  of  charge  and  new  versions 
have been regularly released, progressively improving it, adding new features and keeping it 
up-to-date.  This  includes  the  recent  release  developed  by  the  Commission  as  part  of  the 
commitment to implement a set of improvements for the ECI. This new release contains a set 
of  new  functionalities,  notably  enhancing  the  compatibility  with  mobile  devices  such  as 
smartphones  or  tablets  as  well  as  the  links  with  social  media  and  websites  for  campaign 
purposes25. To ensure transparency, information on new releases and public demos are made 

25 http://ec.europa.eu/citizens-initiative/public/software 

30 

 
 
                                                            
 
available  in  the  JoinUp  website  to  enable  stakeholders'  access  to  updated  information  on 
developments,  discuss  possible  future  ones  and  provide  feedback  on  the  previews.  38 
initiatives  have  used  the  Commission  software  so  far,  including  the  three  successful 
initiatives. 

The Regulation provides that the data obtained through the online collection system shall be 
stored in the territory of a Member State to be chosen by the organisers. To build a complete 
online  system,  organisers  have  to  find  hosting  servers  to  install  their  online  collection 
software.  After  the  entry  into  application  of  the  Regulation  in  2012,  the  first  organisers  of 
initiatives  encountered  substantial  difficulties  to  find  appropriate  and  affordable  host 
providers  to  build  their  systems.  In  view  of  this  obstacle  that  prevented  organisers  from 
starting to collect statements of support online, the Commission took the decision to offer to 
host  organisers'  online  collection  systems  on  its  own  servers,  free  of  charge  and  beyond  its 
obligations under the current Regulation. 

The ECI Regulation provides that the Commission shall adopt technical specifications for the 
implementation of the requirements under article 6(4), though the procedure laid down by the 
Regulation  to  this  end.  These  technical  specifications  are  currently  set  out  in  Commission 
Implementing Regulation (EU) No 1179/2011 of 17 November 2011. 

To  ensure  that  the  online  collection  systems  comply  with  the  above  referred  technical  and 
security requirements, the competent authority in the Member State in which the data will be 
stored  shall  certify  that  the  system  to  be  used  by  the  organisers  complies  with  these 
requirements under the Regulation and the Implementing Regulation before organisers start to 
collect statements of support online.  

Certification  can  be  requested  by  organisers  before  or  after  registering  their  proposed 
initiative with the Commission. The Member State's competent authority has one month from 
the organisers' request to certify the system.  

4.2.3.2. Challenges around the online collection 

The assessment of the implementation of the ECI instrument points to a number of challenges 
in relation to the online collection process, including inter alia the following elements: 

(i) the difficulties  encountered by organisers of initiatives  as well as  the costs to  set-up and 
manage  their  online  collection  systems,  including  as  regards  the  hosting  services  as  well  as 
the certification of the system and its management throughout the procedure; 

(ii)  timeline  issues:  the  starting  date  of  the  collection  period  is  in  all  cases  the  date  of  the 
registration  of  the  proposed  initiative  with  the  Commission,  regardless  of  whether  the 
organisers'  system  has  already  been  certified  or  not.  In  most  cases,  organisers  did  not  have 
their  system  certified  before  the  registration  of  their  initiative  by  the  Commission. 
Consequently, while they could start collecting support on paper, they have had less than 12 
months for online collection. Certifying systems before the registration of the corresponding 
initiatives  is  an  issue  of  concern  for  Member  States'  competent  authorities  as  they  have  to 
carry out the verification without the certainty that the initiative concerned will be registered.  

31 

 
 
                                                                                                                                                                                          
 
(iii)  the  importance  of  increasing  the  effectiveness  of  the  online  collection  process  and  to 
improve the current online collection systems foreseen under the ECI Regulation as a specific 
tool to collect statements of support online; 

(iv)  the  high  requirements  stemming  from  the  technical  specifications  for  online  collection 
systems  under  Commission  Implementing  Regulation  (EU)  No  1179/2011  relating  to  the 
security, processing and management of the personal data by organisers. 

The importance of implementing improvements in the online collection systems for the ECI 
as  well  as  in  the  Commission  online  collection  software  has  also  been  raised  by  other  EU 
institutions  and  bodies  as  well  as  by  organisers  and  civil  society  stakeholders  over  the  past 
years. The improvement of the online collection systems for the ECI has been discussed with 
the national authorities in the meetings of the Expert Group on the ECI. 

4.2.3.3. Possible approaches to the online collection process 

In  the  context  of  the  review  process,  the  Commission  commissioned  a  study  on  the 
assessment  of  ICT  impacts  of  the  ECI  Regulation.  The  study  was  published  in  201526.  The 
objective of the study was to analyse the ECI implementation and any potential improvements 
in  particular  with  regard  to  the  online  collection  process.  The  study  provided  a  set  of 
recommendations  to  improve  the  online  collection  under  the  existing  framework  described 
above, as well as a set of options to be further explored.  

To further investigate the main recommendations, the Commission launched in 2017 another 
study  on  online  collection  systems  and  technical  specifications27  considering  options  for 
improvement  in  the  context  of  the  potential  revision  of  the  ECI  Regulation,  taking  into 
account  the  additional  experience  gathered  in  the  implementation  of  the  ECI  as  well  as  the 
evolution of the situation with regards to technology and security. 

This analysis covers the assessment of the three main approaches: 

  Approach  (1):  update  of  the  current  legal  and  technical  framework  under  the  existing 
Regulation where the online collection is carried out through individual online collection 
systems under the responsibility of the organisers. 

  Approach  (2):  building  on  the existing  framework,  assess  the  potential  improvements  in 
the  most  used  online  collection  systems  where  only  the  online  collection  software  and 
hosting service provided by the Commission are used. 

  Approach  (3):  Setting  up  a  centralised  online  collection  system  for  the  ECI  set-up  and 
managed  by  the  European  Commission  and  made  available  to  organisers  of  citizens' 
initiatives. 

In particular, the set-up of a central online collection system managed by the Commission and 
made  available  free  of  charge  to  organisers  is  one  of  the  main  proposals  raised  by  other 
institutions  and  bodies  as  well  as  by  organisers  and  civil  society  stakeholders  over  the  past 

26 http://ec.europa.eu/citizens-initiative/public/legislative-framework   
27 Study on online collection systems and technical specification pursuant to Regulation (EU) No 211/2011 and 
Commission Implementing Regulation (EU) No 1179/2011. 

32 

 
 
 
 
                                                            
years. It has also been the subject of a proposed citizens' initiative registered in 2012 ("Central 
public online collection platform for the European Citizen Initiative"28). 

The  study  provides  a  detailed  assessment  of  these  three  main  options.  The  assessment 
concludes that approach (3) scores the highest in particular in terms of benefits for organisers 
since the responsibility to set-up and manage the online collection system is shifted from the 
organisers to the Commission. Therefore, taking into account the objectives of the proposal to 
make  the  ECI  more  accessible,  less  burdensome  and  easier  to  use  for  organisers  and 
supporters, approach (3) allows removing obstacles for organisers such as the certification of 
the online collection systems as well as the liability for the online collection of personal data 
since  the  Commission  will  be  responsible  for  the  online  collection  for  the  initiatives 
concerned. Furthermore, a central online collection system also brings benefits to the overall 
online  collection  process  for  the  ECI  in  terms  of  technical  elements  such  as  security 
architecture,  software  development  security,  data  security  and  integrity  and  allows  a  more 
secure protection of the system and the personal data provided by EU citizens in support to 
European citizens' initiatives. 

As  regards  costs  of  implementation,  the  assessment  takes  into  account  that  the  baseline 
scenario whereby the Commission already provides the online collection software as well as 
the  additional  hosting  services  implies  substantial  costs  (see  cost  analysis  in  the  relevant 
sections of the study). The assessment concludes that while the set-up of the new system will 
imply  substantial  costs  in  the  short  term,  over  a  period  of  five  years,  all  three  scenarios 
present  better  performance  than  the  current  situation.  Indeed,  approach  (3)  also  provides  a 
comparative advantage over the other two approaches despite higher initial investment costs. 
In  comparison  to  the  other  approaches,  approach  (3)  provides  the  advantages  of  minimised 
yearly operational and hosting costs, and decreasing maintenance costs in the long run, while 
facilitating deeper integration with the official ECI register and website. 

In  conclusion,  approach  (3)  would  be  the  most  suitable  one,  satisfying  full  and  continuous 
compliance with data protection rules and other existing requirements stemming from the ECI 
Regulation and the technical specifications. It would also contribute to the improvement and 
facilitation of the collection and verification of statements of support, while at the same time 
complying with identified legal, operation, technical, security and costs ideal description for 
identified criteria in this particular context. According to the study, approach (3) is the most 
promising  solution  for  the  future,  making  an  improvement  of  the  online  collection  of  the 
statements of support the most forward-looking and up-to-date to the highest standards. 

This  approach  will  also  allow  for  the  implementation  of  additional  support  measures  for 
organisers,  such  as  the  possibility  for  organisers  to  upload  in  the  system  the  statements  of 
support  collected  in  paper  form,  the  possibility  for  signatories  to  choose  between  various 
methods  to  provide  support  potentially  available  in  their  countries  (e.g.  via  eID)  and  the 
transfer  of  the  collected  statements  of  support  directly  by  the  Commission  to  the  relevant 
Member States' competent authorities for verification and certification.  

Therefore, the proposal foresees that the Commission shall set-up and operate a central online 
collection system for the European citizens’ initiative allowing the collection of statements of 
support  for  initiatives  online  and  provided  free  of  charge  to  organisers  of  initiatives.  The 
proposal  also  provides  that  the  costs  of  setting  up,  operating  and  maintaining  the  central 

28 http://ec.europa.eu/citizens-initiative/public/initiatives/obsolete/details/2012/000011  

33 

 
 
                                                            
online collection system shall be borne by the general budget of the European Union and that 
the system shall comply with Commission Decision (EU, Euratom) 2017/46 on the security of 
communication  and  information  systems  in  the  European  Commission.  The  proposal  also 
foresees that the system should have the necessary accessibility features in compliance with 
the Web Content Accessibility Guidelines (WCAG) ensuring that citizens with disabilities can 
provide support to the initiatives. 

Against this background, one of the elements of the assessment is whether the organisers of 
initiatives  should  still  have  the  possibility  of  setting-up  and  using  online  collection  systems 
different  from  the  one  set-up  and  operated  by  the  Commission.  The  results  of  the  public 
consultation show that 67% of respondents to this question consider that Commission hosting 
of systems should be made permanent but remain optional and another 31% considered that it 
should be transformed into a single online platform for all initiatives without the need for a 
certification.  The  majority  of  respondents  to  the  public  consultation  are  thus  in  favour  of 
making  the  use  of  the  Commission  central  online  collection  system  optional,  leaving  the 
possibility for organisers to use their own online collection systems. To note that when asked 
whether they would use the Commission system or build their own if they were to organise an 
initiative,  87%  of  the  respondents  to  this  question  would  use  the  system  offered  by  the 
Commission. 

In  addition,  leaving  the  possibility  for  organisers  to  choose  between  the  central  system  and 
building  their own system gives them flexibility regarding  how they want  to  carry out  their 
online  collection  and  campaigns  from  an  organisational  and  logistical  point  of  view,  while 
complying with the Regulation. This option also takes into account the fact that over the past 
years,  several  citizens'  committees  have  indeed  used  their  own  online  collection  systems 
instead of using the Commission hosting offer and online collection software.  

Consequently, the proposal maintains the possibility for organisers to set-up their individual 
online collection systems for the ECI and to choose the Member State in which the data will 
be  stored.  At  the  same  time,  the  proposal  ensures  that  the  necessary  technical  and  security 
requirements for these systems are in place in order to protect the personal data collected from 
EU citizens as in the case of the central online collection system set-up and operated by the 
Commission. This includes the adoption of new technical specifications for online collection 
systems  replacing  the  current  technical  specifications  laid  down  by  the  Commission 
Implementing  Regulation  (EU)  No  1179/2011  and  maintaining  the  need  to  obtain  the 
certification of the systems by the competent authorities in the Member State where the data 
collected  will  be  stored  before  the  start  of  the  online  collection  by  the  organisers.  Such 
certification will only be possible after the registration of the initiative. Given that the start of 
collection period  will be  disconnected from the registration date (see section 4.2.4 for more 
detail), organisers should have enough time to build their system and get their system certified 
between the registration and the start of the 12-month collection period.  

4.2.3.4. Electronic identification (eID) 

Regulation  (EU)  No  211/2011  foresees  that  statements  of  support  which  are  electronically 
signed using an  advanced electronic signature, within the meaning of  Directive  1999/93/EC 
on  a  Community  framework  for  electronic  signatures29,  shall  be  treated  in  the  same  way  as 

29 OJ L 13, 19.1.2000, p. 12. 

34 

 
 
                                                            
statements  of  support  in  paper  form.  However,  no  use  of  electronic  signature  has  been 
reported since the entry into application of the Regulation in 2012.  

At  the  same  time,  since  the  adoption  of  the  ECI  Regulation,  there  have  been  important 
developments  in  the  field  of  electronic  identification  in  the  Member  States  and  also  at  EU 
level.  In  particular,  Regulation  (EU)  No  910/2014  on  electronic  identification  and  trust 
services for electronic transactions in the internal market (eIDAS Regulation)30 was adopted 
in 2014 improving the EU legislative framework on electronic identification and trust services 
and  replacing  the  above  mentioned  Directive  1999/93/EC.  The  eIDAS  Regulation  foresees 
inter  alia  that  by  29  September  2018,  public  services  requiring  online  identification  in  all 
Member States must recognise any notified eID from any other Member State.  Accelerating 
the take-up of eIDAS services, including eID and eSignature, is one of the key objectives of 
the  EU  eGovernment  Action  Plan  2016-202031  within  the  framework  of  the  Digital  Single 
Market Strategy for Europe. 

Enabling  citizens  to  make  use  of  electronic  identification  in  order  to  support  European 
citizens'  initiatives  would  have  several  advantages,  facilitating  support  by  citizens  online  as 
well as the verification of the support by Member States.  

The  study  commissioned  by  the  Commission  on  the  assessment  of  ICT  impacts  of  the  ECI 
Regulation in 201532 recommended that solutions to facilitate data entry and validation should 
be  further  investigated,  including  the  use  of  eID,  eSignature  and  the  European  Commission 
Authentication System (ECAS, now called EU Login). The possible use of eID in the context 
of ECI has also been discussed in several meetings of the Expert Group on the ECI including 
based on specific recommendations made by some Member States33.  

In  2016,  the  Commission  launched  an  external  study  on  the  use  of  eID  for  the  ECI34, 
including  a  detailed  assessment  of  legal  and  technical  feasibility  of  options  both  under  the 
current framework and taking into account the potential revision of the ECI Regulation.  

The  study  assesses  a  number  of  potential  technical  solutions  to  allow  citizens  to  support 
initiatives online using electronic identification means. The six analysed solutions have been 
grouped into three categories as follows:  

(i) Solutions considering the use of electronic signatures, including: solution 1: submission of 
statements of support through an electronically signed PDF that the user uploads to the online 
collection  system;  and  solution  2:  direct  integration  of  e-signature  solutions  into  the  online 
collection system, allowing citizens to sign statements of support online. 

(ii)  Solutions  based  on  electronic  identification,  including  solution  3:  direct  integration  of 
national  eID  into  the  online  collection  system  in  order  to  allow  citizens  to  authenticate 

30 http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014R0910&from=EN  
31 Communication from the Commission to the European Parliament and the Council, the European Economic 
and Social Committee and the Committee of the Regions, EU eGovernment Action Plan 2016-2020 Accelerating 
the digital transformation of government, COM(2016)179 final. 
32 http://ec.europa.eu/citizens-initiative/public/legislative-framework  
33 Ibid. 
34 Study on the use of Electronic Identification (eID) for the European Citizens’ Initiative 

35 

 
 
 
 
 
 
 
 
 
                                                            
themselves  and  support  initiatives  online;  and  solution  4:  integration  of  eID  through  the 
eIDAS framework. 

(iii)  complementary  solutions,  aiming  at  easing  the  submission  process  and  attracting  more 
users to the ECI, including: solution 5: allowing EU Login users to pre-fill the data fields with 
the  data  stored  in  their  accounts;  and  solution  6:  connection  with  a  social  network,  namely 
Facebook, by which users would pre-fill the data requirements. 

The study concludes that the most recommended solution to give citizens the option of using 
their eID to support a citizens' initiative is the integration through the eIDAS framework. The 
technical implementation of the solution foresees the connection between the online collection 
system  for  the  ECI  and  the  Member  States  established  through  the  eIDAS  network.  This 
solution facilitates citizens' support to an initiative as well as the quality and reliability of the 
data  for  organisers  and  the  national  authorities  competent  for  the  verification  of  support, 
thereby also bringing improvements to the procedure for the verification and certification of 
statements of support.  

Furthermore,  the  integration  with  eIDAS  is  also  the  most  recommended  approach  from  a 
feasibility point of view as well as in terms of costs, maintainability and scalability. For this 
solution,  the  eIDAS  node  would  be  used  to  grant  secure  access  to  the  Member  States’  eID 
access points. Therefore, this option could be implemented through the integration of the ECI 
online collection system only with one node. 

As  regards  the  inputs  received  in  the  context  of  the  review  process  and  the  results  of  the 
public consultation, several stakeholders called for the introduction of the possibility to sign 
using e-ID and develop synergies with the eIDAS framework. Asked about the use of eID for 
the  ECI  in  the  public  consultation,  67%  of  respondents  consider  that  it  would  make  the 
process more user-friendly.  87% of respondents also agreed that several ways for providing 
support online should be available in parallel to maximise the user-friendliness. 

In  light  of the above,  the proposal foresees the  possibility  for citizens  to provide support  to 
citizens' initiatives via the Commission central online collection system through statements of 
support  electronically  signed  using  electronic  identification  and  electronic  signature  means 
within  the  eIDAS  framework.  In  this  context,  the  proposal  provides  for  the  implementation 
requirements  to  be  ensured  by  the  Commission  and  the  Member  States  and  clarifies  that  in 
this case, citizens shall provide their nationality and Member States shall accept the minimum 
data set for a natural person in accordance with Commission Implementing Regulation (EU) 
2015/1501.  The  possibility  to  support  an  initiative  through  eID  remains  optional, 
complementing  the  possibility  to  support  initiatives  online  through  the  central  online 
collection system, taking into account that not all EU citizens have eID and the differences in 
the level of penetration and use of eID in the different Member States. 

4.2.4.  Time period for collection 

According to the ECI Regulation, organisers have one year to collect statements of support for 
their proposed initiative, as of the date of registration of their initiative by the Commission.  
Due to the uncertainty of the outcome of the registration phase, many organisers do not start 
preparations  for  the  collection  before  getting  confirmation  of  the  registration  of  their 
initiative. In particular, even if the Regulation allows the certification of the organisers' online 
36 

 
 
 
 
 
 
 
 
collection systems before the registration of the initiative concerned, many organisers do not 
invest  time  and  money  in  building  up  and  getting  their  system  certified  before  the 
confirmation  of  registration.  In  addition,  several  Member  States’  competent  authorities  are 
uncomfortable  with  the  possibility  for  organisers  to  request  the  certification  of  their  system 
before  the  registration  of  their  proposed  initiative  with  the  Commission.  Given  the  time 
needed by organisers to set up their system, in  most cases, they have therefore less than 12 
months to collect statements of support from signatories online.  
Likewise, the publication of translations of the proposed initiatives (even with the support of 
the  EESC)  usually  takes  several  weeks  after  the  registration  date  (see  section  4.1.2),  which 
might delay the start of collection campaigns. 
In  addition,  in  the  current  Regulation,  the  organisers  cannot  choose  the  start  date  of  the 
collection  period  while  they  might  be  interested  in  choosing  a  specific  date  for 
communication purposes. 
Several options to remedy those issues have been suggested and analysed, including whether 
organisers  should  be  able  to  choose  the  start  date  of  the  collection,  whether  the  collection 
period should be extended, or both35. 
As part of this analysis, it is important to note the proposed measures that will facilitate the 
collection apart from reviewing the time period provisions, in particular: 
- the possibility for organisers to use the central online collection system made available free 
of  charge  by  the  Commission  from  the  start  of  the  collection  period,  without  the  need  for 
organisers to get any certification; 
-  the  availability  of  the  initiative  content  in  all  official  EU  languages  from  the  start  of  the 
collection period, based on translations provided free of charge by the Commission; 
- reduced and simplified personal data requirements for signatories. 
While  discussing  those  time  limits,  one  should  also  keep  in  mind  that  initiatives  are  often 
linked to topical issues and refer to issues which can lose their relevance over time. Also, the 
context in which people give their support to an initiative may change if the period is too long 
(for example if legislation is amended or adopted in the meantime). It is therefore important 
that  the  time  between  the  request  for  registration  of  an  initiative  and  the  final  reply  by  the 
Commission at the end of the process is not too long. 
There seems to be a consensus among stakeholders that organisers should be able to choose 
the  start  date  of  their  collection  period,  disconnecting  it  from  the  date  of  registration.  This 
should facilitate their preparation and, for those who choose to use their own online collection 
system, this should give them sufficient time to set it up and get it certified.  

To  make  sure  that  initiatives  remain  relevant  throughout  the  procedure  and  in  view  of  the 
various  measures  facilitating  the  collection in  addition  to  the  choice  of  the  start  date  by  the 
organisers, it seems sufficient and reasonable to foresee a maximum of three months between 
the  date  of  registration  and  the  start  of  the  collection  period  and  to  maintain  the  12  month 
collection period.  
The proposal also includes provisions to make sure that the process goes smoothly depending 
on the choice made by the organisers as regards the online collection. 
The organisers shall inform the Commission of the date chosen for the start of the collection 
period at the latest ten working days before that date. In addition, within one month from the 

35  See  synopsis  report  of  stakeholder  consultation  in  annex  3  for  the  opinions  and  suggestions  of  main 
stakeholders. 

37 

 
 
                                                            
registration of their initiative and at the latest ten working days before the date chosen, they 
shall inform the Commission of:  
- whether they will use the central online collection system and if yes: 
- whether they will upload the statements of support collected in paper form into the central 
system.  
The proposal also foresees that the Commission or the group of organisers, depending on the 
option chosen for the online collection, shall close the online collection system at the end of 
the 12 months, i.e. on the same day of the following year. It is understood that given that the 
registration takes place in the CET zone, the closure shall take place at 24:00 CET. 

4.3. 

Follow-up of successful initiatives 

4.3.1.   Time limit for submission to the Commission 

The current Regulation does not foresee a time limit for organisers to submit their successful 
initiative  to  the  Commission,  after  the  verification  of  the  statements  of  support  by  the 
competent  national  authorities.  One  of  the  successful  initiatives  was  submitted  16  months 
after  the  end  of  its  collection  period.  Some  stakeholders,  including  the  Commission  in  its 
report of 2015, the European Parliament and several competent national authorities, raised the 
issue  of  the  absence  of a  time  limit  which  can  create  confusion  and  uncertainty  for  citizens 
and EU institutions. In the public consultation, when asked about such a time limit, two-thirds 
of respondents agreed with setting a deadline. Such deadline would limit the uncertainty and 
make  sure  that  the  Commission  is  invited  to  reply  within  a  reasonable  time  period  after 
citizens have given their support to the initiative.  
57%  of  those  respondents  in  favour  of  a  deadline  consider  that  a  time-limit  of  between  six 
months and one year from the end of the collection should be set. 37% thought that this time 
limit should be less than six months. 

To  address  this  issue,  the  proposal  sets  out  that  the  organisers  shall  submit  their  successful 
initiative  to  the  Commission  within  three  months  of  obtaining  the  last  certificate  from  a 
competent  national  authority.  Given  that  organisers  have  three  months  from  the  end  of  the 
collection period to submit their statements of support to competent national authorities and 
those authorities have maximum three months to proceed with the verification, this means that 
successful  initiatives  should  be  submitted  at  the  latest  nine  months  from  the  end  of  the 
collection period.  While this leaves less  flexibility  for organisers to  choose  when they want 
the  Commission  to  reply  to  their  initiative,  it  brings  benefit  in  terms  of  transparency  and 
reduced uncertainty and is also more in line with the expectations of signatories who support 
an initiative at a certain point in time and expect an answer within a reasonable timeframe.   

4.3.2.   Examination procedure 

The examination and response phase is the last formal step of the ECI procedure. Initiatives 
gathering the necessary number of statements of support can be submitted to the Commission 
in accordance with Article 9 of the Regulation.  

The  procedure  foreseen  in  the  Regulation  contains  a  set  of  actions  to  be  implemented  in 
response  to  a  citizens'  initiative.  In  accordance  with  Article  11,  when  the  Commission  has 
received  a  citizens’  initiative  which  has  gathered  the  required  number  of  signatories  and 
fulfils  the  other  requirements  of  this  Regulation,  the  organisers  have  the  opportunity  to 
38 

 
 
 
 
 
present that initiative at a public hearing at Union level. The public hearing takes place in the 
Parliament and is co-organised by this institution and the Commission.  

The Commission also meets the organisers at an appropriate level to allow them to explain in 
detail  the  matters  raised  by  the  citizens’  initiative.  Finally,  the  Commission  examines  the 
citizens’ initiative and sets out its legal and political conclusions separately. The Commission 
response  should  set  out  the  action  it  intends  to  take  in  response  to  it,  if  any  and  explain  its 
reasons.  To  demonstrate  that  a  citizens’  initiative  supported  by  at  least  one  million  Union 
citizens and its possible follow-up are carefully examined, the Commission response should 
explain in a clear, comprehensible and detailed manner the reasons for its intended action, and 
should  likewise  give  its  reasons  if  it  does  not  intend  to  take  any  action  in  response  to  the 
initiative.  

The  Regulation  also  foresees  a  timeframe  for  the  examination  phase,  stipulating  that  the 
meeting  with  the  organisers,  the  public  hearing  and  the  Commission  reply  in  the  form  of  a 
Communication  shall  take  place  within  three  months  from  the  submission  of  the  initiative, 
which means that the possibility for participation and public debate actions is limited to these 
three months. 

Since the entry into application of the Regulation in 2012, three initiatives have reached the 
necessary  thresholds  under  the  Regulation  and  have  been  submitted  to  the  Commission  for 
assessment and response. 

In  two  cases  "Water  and  sanitation  are  a  human  right!  Water  is  a  public  good,  not  a 
commodity!" ("Right to Water")36 and "Stop vivisection"37, the Commission committed to a 
set of follow-up actions which have been and continue to be implemented38. In the case of the 
initiative  "One  of  us",  the  Commission  concluded  after  the  examination  of  the  citizens' 
initiative  that  the  existing  framework,  which  had  been  recently  debated  and  agreed  by  EU 
Member States and the European Parliament, was appropriate and explained its assessment in 
a Communication39. The Commission makes known its response to successful initiatives and 
the  follow-up  actions  in  the  ECI  website  and  via  other  information  activities.  However, 
experience  shows  that  more  should  be  done  to  inform  citizens  and  signatories  about  the 
follow-up actions to European citizens' initiatives adopted by the Commission. 

While  only  three  initiatives  have  been  successful  so  far  in  reaching  the  examination  and 
response phase of the procedure, the experience in these three cases already provides a set of 
lessons learnt to be considered in the assessment of this last stage of the procedure:  

(i)  The  Commission  report  of  2015  pointed  to  the  need  to  ensure  a  more  balanced 
representation of stakeholders in the public hearing in view of the fact that on occasion of the 
public  hearings  organised  at  the  European  Parliament  for  the  first  two  initiatives,  no 
stakeholders  or  experts  other  than  the  ECI  organisers  themselves  were  invited  to  actively 

36 http://ec.europa.eu/citizens-initiative/public/initiatives/finalised/details/2012/000003 
37 http://ec.europa.eu/citizens-initiative/public/initiatives/finalised/details/2012/000007 
38 http://ec.europa.eu/citizens-initiative/public/initiatives/successful 

39 http://ec.europa.eu/citizens-initiative/public/initiatives/successful/details/2012/000005 

39 

 
 
 
 
 
 
                                                            
 
 
participate. Also, while the Regulation refers to the potential participation of other institutions 
in  the  public  hearing,  if  they  wish  so,  experience  also  shows  that  the  involvement  of  other 
Union  institutions  (and  bodies)  could  be  enhanced.  Therefore,  further  improvements  in  the 
public  hearing  should  be  considered  so  that  it  plays  its  intended  role  as  a  mechanism  for 
dialogue  and  participation  and  exchange  of  views  between  EU  institutions,  organisers  of 
successful ECIs and other stakeholders concerned by the ECIs. 

(ii)  The  three-month  time  period  foreseen  by  the  Regulation  for  the  examination  of  a 
successful  initiative  is  short  and  leaves  limited  time  for  the  public  debate  and  consultation 
phase, as well as for involvement of other stakeholders and that of other EU institutions and 
advisory  bodies.  Furthermore,  sufficient  time  is  needed  for  the  preparation  of  the  public 
hearing to ensure that it is sufficiently inclusive and that relevant stakeholders are represented. 
Finally, the fact that the time limit for the public hearing and the Commission response is the 
same  leaves  limited  margin  for  the  Commission  to  take  into  account  the  discussion  in  the 
public  hearing  as  well  as  to  consider  any  possible  follow-up  dialogue  with  organisers  and 
stakeholders.   

(iii)  As  regards  the  follow-up  to  the  successful  initiatives,  several  stakeholders  (notably  the 
European  Parliament,  the  EESC  and  the  Committee  of  the  Regions)  suggested  that  the 
Commission  should  prepare  a  legal  act  on  the  successful  initiative  within  a  set  time  period 
after a positive reply. This approach does not seem appropriate for the following reasons: 

- It should be noted that pursuant to the Regulation, the Commission can decide which action 
it intends to take in reply to a successful ECI, providing reasons for taking or not taking that 
action.  This  derives  from  the  relevant  provisions  of  the  Treaty  on  European  Union  itself 
which define the ECI as an invitation to 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.  

- Furthermore, as explained by the Commission in its reply to the Parliament resolution on the 
European  citizens'  initiative,  even  in  cases  where  the  Commission  responds  positively,  the 
most  appropriate  follow-up  for  the  different  ECIs,  in  line  with  Better  Regulation  principles 
may  vary  in  terms  of  the  nature  of  actions  to  be  taken,  the  instruments  chosen  and  the 
timeframe  for  their  implementation.  In  this  regard,  it  should  also  be  noted  that  if  the 
Commission decides to follow-up with a legislative proposal, the preparation of such proposal 
needs  to  respect  Better  Regulation  principles  and  allow  sufficient  time  for  carrying  out  the 
necessary  steps  such  as  stakeholder  consultation,  and  impact  assessment  and  evaluation  of 
existing legislation as applicable. 

Therefore,  the  current  rules  as  regards  the  Commission  response  ensure  an  efficient  and 
proportionate  mechanism  for  the  follow-up  to  successful  initiatives.  At  the  same  time, 
experience  shows  that  the  information  to  other  institutions  and  bodies  as  regards  the 
Commission response to successful initiative as well as in particular informing citizens about 
the follow-up actions by the Commission to successful initiatives can be reinforced. 

Against this background, the proposal contains a number of improvements aimed to: 
-  ensure  a  balanced  representation  of  stakeholders  in  the  public  hearing  at  the  European 
Parliament; 
- reinforce the information to other EU institutions and bodies at the start and at the end of the 
examination phase; 

40 

 
 
 
 
 
 
 
-  enhance  public  debate  and  participation  as  well  as  the  exchange  of  views  between  EU 
institutions and organisers of successful ECIs by extending the time period of this phase from 
three to five months. 

Finally,  the  proposal  also  contains  measures  aiming  at  enhancing  the  information  to 
signatories  and  citizens  on  the  response  and  follow-up  to  European  citizens'  initiatives 
including  via  the  collection  of  email  addresses  for  information  purposes  (see  section  4.4.3. 
below  for  more  detail).  As  the  European  citizens'  initiative  is  a  tool  for  participation  in  the 
democratic life of the EU and engagement, it is appropriate that citizens who have signed an 
initiative are informed if they so wish of the outcome of the initiative they have signed.   

4.4.  Communication, awareness-raising and transparency 

4.4.1.  General  communication  and  awareness-raising  concerning  the  ECI 

instrument 

Since its entry into application in 2012, the main communication tool for the ECI has been a 
dedicated  Commission  ECI  website.  Available  in  the  24  official  EU  languages,  it  provides 
general  information  about  the  ECI  in  an  easy  and  accessible  way.  It  offers  moreover 
information about each of the proposed initiatives as described below under section 4.4.2.  

The  Commission  also  informs  citizens  about  the  ECI  through  its  guide  for  citizens  and 
organisers available in both on paper and online versions, the service of the point of contact 
(replying  to  request  via  a  contact  form  and  by  phone)  and  via  its  representation  offices  in 
different Member States40. 

The  Commission  has  progressively  undertaken  additional  actions,  such  as  publishing  press 
releases  on  the  occasion  of  registration  of  each  new  initiative  and  developing  an  RSS  feed 
mechanism  on  its  website.  Implementation  of  more  ambitious  actions  required  budgetary 
appropriations  which  have  been  made  available  for  this  purpose  only  this  year.  The 
Commission  is  thus  currently  preparing  a  communication  campaign  on  the  ECI  to  start  in 
2018 and it is in parallel launching an online collaborative platform for the ECI under a pilot 
project from the Parliament, as further explained under section 4.1.2 above. 

The  Commission  has  always  highlighted  that  communication  and  awareness-raising  on  the 
ECI  is  a  shared  responsibility  of  the  Commission,  Member  States,  other  institutions  and  all 
stakeholders.  

In  this  context  it  is  important  to  mention  the  contribution  of  the  other  EU  institutions  and 
bodies as regards the promotion of the ECI. 

The European Parliament and the European Economic and Social Committee have both set up 
their  own  ECI  related  websites  and  developed  guidance  for  citizens  and  organisers.  The 
European  Parliament  has  furthermore  made  promotional  audio-visual  materials  available 
online. 

In  its  capacity  of  facilitator  representing  the  voice  of  civil  society  and  promoting  different 
forms of citizens' participation, the EESC has been particularly active in supporting the ECI. 

40 These communication channels are also mentioned under section 4.1.2 above, as they serve both the citizens in 
general and the potential ECI organisers. 

41 

 
 
 
 
                                                            
Since 2012 it has hosted a yearly event gathering experts and stakeholders, called "ECI Day". 
It has also organised debates with organisers of several proposed initiatives and offered them 
translation service as further explained under section 4.1.2.2.  

Despite  these  activities,  the  level  of  awareness  about  the  ECI  among  citizens  remains 
unsatisfactory.  Even  among  those  who  have  responded  to  the  Commission's  public 
consultation  about  the  ECI,  37%  had  not  heard  about  the  ECI.  This  lack  of  awareness  has 
been considered as one of the main obstacles in the efficient functioning of the instrument by 
different  stakeholders  and  in  particular  by  the  ECI  organisers.  The  need  to  promote  the 
instrument  and  undertake  larger  awareness-raising  actions  has  thus  been  highlighted  in  all 
contributions to the review process. 

Although  the  communication  activities  do  not  require  any  particular  legal  basis,  the 
Commission  has  therefore  deemed  it  useful  to  highlight  their  continued  importance,  on  a 
lasting  basis  in  the  context  of  the  ECI,  by  proposing  a  specific  new  provision  on 
communication  activities  in  its  proposal  for  a  Regulation.  According  to  this  provision,  the 
Commission  shall  carry  out  communication  activities  to  raise  public  awareness  of  the 
existence of the ECI, thereby contributing to promoting the active participation of citizens in 
the political life of the Union. 

4.4.2.  Information  and  transparency  with  regard  to  concrete  citizens' 

initiatives 

While interactions between initiative organisers and the Commission take place mainly online 
via  the  Commission  ECI  Register,  the  public  interface  of  the  said  register  displayed  on  the 
ECI website allows any interested citizen to directly access the information about all proposed 
initiatives at their different stages of the procedure. 

For each registered initiative the register provides: 

 

 

 

 

 

initiative title and content including subject matter, main objectives and provisions of 
the  Treaties  considered  relevant  by  the  organisers,  as  well  as  their  translations,  if 
available; 
the annex of the proposed initiative and/or proposed draft legal act if organisers have 
foreseen such documents, as well as their translations if available; 
information  concerning  initiative  organisers  including  names  of  the  seven  registered 
members of the citizens' committee and e-mail addresses of its contact persons; 
further references i.e. registration number, date of registration and URL address of the 
organisers' website if any; 
Information on all sources of support and funding, exceeding 500 EUR per year and 
per sponsor which should be provided by the organisers at the time of registration and 
updated regularly afterwards. 

Moreover, the ECI register allows the direct consultation of:  

 

 

initiatives registered since March 2017, decisions on registration, clarifying in case of 
partial registration the scope of admissibility of these initiatives;  
information  on  the  already  accomplished  stages  of  the  procedure,  and  the  stage 
currently  reached,  including  for  successful  initiatives  the  number  of  collected 
statements of support after verification, information about the examination process and 
a  page  presenting  the  follow-up  actions  undertaken  in  response  to  the  initiative  (if 

42 

 
 
 
any). Uncertainty on the status of initiatives having reached the end of collection can 
however happen when organisers do not inform/until they inform the Commission of 
the results of their collection campaign.  

To facilitate the support of initiatives, the register offers direct links to the organisers’ online 
collection systems of the initiatives open for collection.  

Finally,  on  a  dedicated  page,  the  website  allows  the  consultation  of  all  refused  requests  for 
registration and the relevant Commission decisions refusing registration. 

While  all  this  information  allows  already  today  a  high  level  of  transparency  as  regards  the 
initiatives  and  the  procedures  undertaken  by  the  Commission  in  their  respect,  additional 
suggestions and options have been analysed in the scope of the present review: 

  The information on the number of statements of support collected by each initiative is 
today available only to a limited extent.  In case of successful initiatives the collected 
statements  of  support  are  verified  by  the  Member  States  and  the  number  of  valid 
statements  is  published  by  the  Commission.  For  initiatives  being  in  the  process  of 
collection and those closed without success, there is today no obligation for organisers 
to publish this information. While the organisers using the Commission software, may 
optionally choose to display the number of collected (and not yet verified) statements 
of support in real time, there exists no similar mechanism for the collection in paper 
form.  Some  organisers  choose  to  publish  the  relevant  information  on  their  own 
website, and others do not. 
Thus  the  information  is  fragmented,  incomplete  and  it  is  not  available  in  the  ECI 
Register. The resulting lack of transparency hampers the evaluation and monitoring of 
the ECI instrument and impedes the acknowledgement of the organisers' achievements 
as far as they do not reach the final thresholds.  
To  improve  the  transparency  in  this  area  it  is  thus  proposed  that  the  organisers 
regularly provide information as regards the number of collected statements of support 
(both online and on paper) to the Commission for publication in the Register. 

  Citizens' committees of several initiatives requested in the past the publication in the 
ECI register of the names of all their committee members (today the names of only the 
minimum  seven  members  of  the  committee  are  registered  and  displayed).  The 
proposal takes up this suggestion41. 

  As explained under section 4.1.2., the proposal foresees that the translations are made 

available directly by the Commission from the start of the collection period. 

  Finally,  as  regards  financial  transparency,  some  stakeholders  and  in  particular  the 
European  Ombudsman  advocated  a  reinforcement  of  the  current  rules set  out  above. 
However, to date, the Commission has not received any complaint from the public as 
regards the financial transparency of initiatives. As a result, the Commission considers 
that no further measures are justified at this stage.  
The  proposal  however  clarifies  that  organisers  must  provide  information  on  their 
funding sources at least every two months. 

41 See section 4.1.1 above for details 

43 

 
 
 
 
                                                            
4.4.3.  Communication with signatories 

While initiatives' signatories can get informed about the ECI and the progress of the initiative 
they have supported via the ECI register and website (including the RSS feed they can sign up 
to) and via the organisers’ websites, the current Regulation does not foresee any mechanism 
allowing the organisers or the Commission to contact them subsequently in a proactive way. 

Some organisers have been collecting signatories’ email addresses to keep them informed of 
the initiative follow up and further engage them in the campaign, but to date such collection 
had  to  take  place  outside  the  process  foreseen  in  the  ECI  Regulation.  Indeed,  the  current 
Regulation foresees in its Article 12(3) that when the organisers collect signatories' personal 
data  (as  filled  in  in  statements  of  support)  the  purpose  of  this  collection  is  limited  to  the 
verification and certification of the collected statements of support by Member States.   

This  provision  was  criticised  by  many  organisers  who  requested  that  the  possibility  of 
collecting signatories’ e-mail addresses be explicitly foreseen in the Regulation, for reasons of 
legal certainty.  

The proposal includes this suggestion, providing that the organisers and the Commission may 
collect  email  addresses  from  signatories  of  an  initiative  for  the  purposes  of  communication 
and  information  activities  regarding  this  initiative  where  the  data  subject  has  given  explicit 
consent  to  the  processing  of  his  or  her  personal  data  for  such  specific  purposes.  This  will 
allow them to inform the signatories on the progress of this initiative, on new developments 
and/or on any follow up actions. 

It  needs  to  be  noted  that  the  process  of  collection  of  emails  for  communication  purposes  is 
still separate from the collection of statements of support as such. First, because the signatory 
shall  be  allowed  to  choose  whether  he  or  she  would  like  to  be  further  contacted  by  the 
Commission  and/or  by  the  organisers.  Second,  as  email  addresses  are  not  sent  to  Member 
States for verification and need to be kept longer in order to keep signatories informed of the 
Commission response and possible follow-up given to the initiative they have supported for 
enough time after the submission of the initiative to the Commission. Experience with the first 
successful  initiatives  shows  that  there  might  be  a  need  to  inform  signatories  on  follow-up 
measures during several years after the Commission response. As regards this last aspect, the 
Commission proposes that the e-mail addresses shall be kept for: 

- a maximum of 12 months after the end of the collection period for initiatives which have not 
reached the minimum required support; 

- a maximum of 12 months after the submission of the initiative to the Commission for those 
which have reached this support but have been declined by the Commission; 

- a maximum of one month after the withdrawal for withdrawn initiatives; 

- a maximum of three years after the adoption of the Communication by the Commission for  
successful initiatives for which follow-up measures are foreseen in the Commission response.  

44 

 
 
4.5. 

Personal data protection 

Ensuring the appropriate level of personal data protection is an important aspect of the ECI 
implementation given the potential amount of personal data to be collected and processed in 
this context. 

The proposal contains some new provisions regarding data protection issues which focus on 
three aspects: 
-  a  technical  adaptation,  (i)  replacing  references  to  Directive  95/46/EC  with  references  to 
Regulation (EU) 2016/679 (General Data Protection Regulation), the new relevant European 
legal  framework  which  shall  enter  into  force  as  of  25  May  2018  and  (ii)  providing  specific 
references as regards to the processing to be carried out by the Commission in the context of 
the central online collection system based on Regulation (EU) 45/2001, notably in the privacy 
statement of the statement of support form;  
-  some  clarifications  and  adaptations  based  on  the  experience  of  the  implementation  of  the 
ECI Regulation: (i) the fact that the representative of the citizens' committee (now group of 
organisers) - or the legal entity if applicable - shall be considered as data controller; and (ii) 
the revision of the retention periods, notably following the feedback received from Member 
States indicating that the time limit for the destruction of the data was in some cases too short 
to  already  be  informed  of  possible  legal  proceedings  in  relation  to  the  results  of  the 
verification procedure by the competent national authorities;  
- adding a set of specific provisions as regards the collection of email addresses, which given 
the  different  purpose  of  collection  and  the  different  required  retention  periods  cannot  be 
subject to the same rules as the collection of personal data as part of the statement of support. 

For  the  discussion  concerning  the  liability  of  organisers  with  regard  to  the  personal  data 
protection obligations, see section 4.1.1.2 above.  

The entry into force as of 25 May 2018 of the General Data Protection Regulation has notably 
the following implications for the ECI instrument:  
-  the  notification  of  the  competent  data  protection  authority(ies)  by  the  organisers  prior  to 
starting  the  collection  of  statements  of  support  (where  it  was  applicable)  is  not  required 
anymore.  
In  case  the  data  collected  are  to  be  considered  as  special  categories  of  data  (personal  data 
revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade 
union membership), prior to the processing of data, organisers will need to: 
- designate a data protection officer and publish his/her contact details and communicate them 
to the relevant supervisory authority; 
-  carry  out  a  data  protection  impact  assessment  explaining  the  context  and  describing  the 
envisaged data processing, the risks and the measures that will be taken to address those risks; 
- consult the relevant supervisory authority if there are any high risks that are not mitigated. 
The  Commission  will  raise  awareness  about  the  General  Data  Protection  Regulation  and 
provide explanations to organisers prior to the entry into force of this Regulation. 
In the context of the proposal, should the data collected be considered as a special category of 
data,  organisers  will  need  to  comply  with  the  above  requirements  in  case  they  collect 
statements  in  paper  form  or  via  an  individual  online  collection  system.  They  will  not  be 
required to do so as regards to the online collection if they use the central online collection 
system managed by the Commission (and where the Commission will be data controller). 

45 

 
 
 
 
 
4.6. 

Summary of the main elements of the proposal 

  The provisions regarding the group of organisers -which remains at least seven natural 

persons- are clarified and improved including:  

(i)  clarifying  the  conditions  of  the  liability  of  the  group  of  organisers  for  any  damage 
caused  in  the  organisation  of  an  initiative  (unlawful  acts  committed  intentionally  or  at 
least  with  serious  negligence)  without  prejudice  to  the  requirements  under  the  General 
Data Protection Regulation which are fully applicable to the ECI; and 

(ii) possibility for organisers to create a legal entity (in accordance with national law) for 
the  purpose  of  managing  an  initiative  which  should  be  considered  as  the  group  of 
organisers for the purposes of the Regulation. 

  Support  to  organisers  is  enhanced  through  information  and  assistance  measures  -  i.e. 
Commission  helpdesk  and  dedicated  ECI  register  and  website  are  maintained; 
introduction  of  an  online  collaborative  platform  and  points  of  contact  in  the  Member 
States. The Commission will also take care of the translations of the registered initiatives 
into all official EU languages. 

 

Improvements in the registration procedure, including:  

(i)  the  possibility  of  providing  information  to  the  organisers  when  the  initiative  falls 
outside of the Commission powers; and  

(ii)  the  possibility  of  partial  registration  of  initiatives  in  cases  where  only  part  of  the 
initiative  –including  the  main  objectives–  is  not  manifestly  outside  of  the  Commission 
powers to submit a proposal for a legal act for the purpose of implementing the Treaties. 

  The minimum age to support an initiative is harmonised at 16. 

  The personal data to be provided by signatories are simplified via a unified approach 

based on nationality and on the basis of two options covering all Member States. 

  As regards the collection period, the organisers can  choose the starting date of the 12 

month collection period within three months from the registration date.  

  Organisers  should  report  to  the  Commission  at least  every  two  months  their  sources  of 
support  and  funding  above  EUR  500  per  sponsor  and  the  number  of  statements  of 
support they have collected, for publication in the register. 

  The organisers and the Commission can collect the email addresses of the signatories of 
citizens'  initiatives,  subject  to  their  consent,  for  the  purposes  of  communication  and 
information activities.     

  The Commission will set up and operate a central online collection system for the ECI. 
The system will be made available free of charge to organisers and include the possibility 
to  support  initiatives  using  eID,  to  upload  the  paper-based  statements  of  support  in 
scanned version and to transfer the statements of support to the competent authorities in 
the Member States for verification. The processing of personal data via this system will be 
46 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
the  responsibility  of  the  Commission,  further  limiting  the  liability  issues  for  organisers 
should they choose to use it.  

  Organisers remain free to build their own system and get it certified by the competent 
national authority, if they wish so. Certification should take place after the registration of 
the initiative with the Commission. 

  After  the  end  of  the  verification  of  the  statements  of  support  by  the  Member  States' 
competent  authorities,  organisers  have  three  months  to  submit  their  initiative  to  the 
Commission. 

 

Improvements are brought to the examination phase, including: 

(i) Extension of the examination phase from three to five months to allow more time 
for citizen participation and debate and for the preparation of the Commission response. 

(ii)  Publication  and  public  hearing  at  the  European  Parliament  within  three  months 
from the submission of the initiative with explicit provision on balanced representation 
of all stakeholders and representation of other EU institutions and advisory bodies; 

(ii) Commission meets the organisers at an appropriate level within one month from the 
submission  of  the  initiative  and  adopts  a  Communication  in  response  to  the  initiative 
explaining its reasons for taking or not taking action within five months; it also  notifies 
the  Communication  to  the  other  EU  institutions  and  bodies  at  the  end  of  the 
procedure. 

  A  provision  on  communication  activities  is  added  to  raise  awareness  of  citizens  to  the 

European citizens' initiative.  

47 

 
 
 
 
 
 
  
 
 
 
 
 
4.7.  ECI procedure as foreseen in the proposal 

A group of organisers of at least 7 persons residing in 7 Member 
States is set up. Optionally, a legal entity is created*. 

Organisers request the registration of their initiative to the 
Commission. 

Commission registers the initiative (or part(s) of it) and publishes it.  

Commission publishes the translations before the collection starts. 

Max. 3 months 

C
o
m
m

i
s
s
i
o
n
n
e
e
d
e
d

3
m
t
h
s

i
f

i

n
f
o
r
m
a
t
i
o
n
b
y

M
a
x
.
2
m
t
h
s

Organisers  ask relevant national authority 
to certify their online collection system. 

The individual system is certified by the 
relevant national authority. 

M
a
x
.
1
m
t
h

Commission registers the initiative if: 
- (a)(b) group of organisers and legal entity 
(if any) follow the rules; 
- (c) not manifestly outside of Commission 
powers;  
- (d) not manifestly abusive, frivolous or 
vexatious;  
- (e) not manifestly contrary to the EU values 
If all criteria are met except (c) -> 
information by Commission with possibility 
for organisers to revise 
If, after revision, (c) is not fully met but a 
substantial part of the initiative, incl. main 
objectives, comply with (c) -> partial 
registration 

Collection of statements of support  
[start date chosen by organisers] 

- By the Commission online via 
central system 
- By the organisers in paper form 
Optionally, organisers upload 
scanned copies of paper-based 
statements in the central system 

By the organisers: 

- online (via their individual 
system) 

 - in paper form  

At least 1 million statements of support collected from at least 
one quarter of EU countries 

Max. 3 months  

The Commission submits statements collected/uploaded in the central 
system to competent national authorities for verification.  

If applicable, organisers submit those collected via an individual 
system/in paper form to competent national authorities. They can 
choose to use the EU file exchange service. 

The competent national authorities verify and certify the number of 
valid statements of support. 

Max. 3 months  

The organisers submit the valid initiative to the Commission. 

* When such entity is created, 
it replaces the organisers in 
the subsequent steps. 

- Within 1 month: Commission meets organisers  

- Within 3 months: Commission and European Parliament co-organise a 
public hearing at the European Parliament 

- Within 5 months: Commission answers in a Communication, setting 
out its legal and political conclusions, the action it intends to take, if 
any, and its reasons for taking or not taking action. 

M
a
x
.
1
2
m
t
h
s

M
a
x
.
3
m
t
h
s

M
a
x
.
5
m
t
h
s

48 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 1: REFIT AND MONITORING 

1.  REFIT (SIMPLIFICATION AND IMPROVED EFFICIENCY) 

The core of the proposal is to make the ECI more accessible, less burdensome and easier to 
use for organisers and supporters, but also for the other actors like Member States' competent 
authorities and the Commission. As a result, most of the improvements set out in the sections 
above aim to make the instrument more fit for purpose. The need for these improvements is 
also  demonstrated  by  the  many  issues  highlighted  in  the  REFIT  platform  Opinion  of  27/28 
June 201642 that have been taken into consideration.  
In line with the recommendations of this opinion, the proposal includes specifically: 
- the possibility to establish citizens' committees (now groups of organisers) as legal entities; 
- reinforced advice and support measures; 
-  the  possibility  for  organisers  to  use  a  central  online  collection  system  under  the 
responsibility of the Commission and without the need for a certification; 
-  a  period  of  maximum  three  months  between  the  date  of  registration  and  the  start  of 
collection  allowing  organisers  to  prepare  their  campaign  and  their  online  collection  system 
should they decide not to use the central system; 
- simplified forms for the collection of statements of support and a unified approach based on 
the nationality allowing all EU citizens to sign; 
- provisions on communication activities to be carried out by the Commission. 

Moreover, several provisions of the proposal will allow for improved efficiency and savings, 
in particular as regards to the online collection of statements of support, the translations of the 
initiatives,  the  statement  of  support  forms  and  the  submission  of  the  statements  for 
verification  by  the  Member  States'  competent  authorities.  The  emphasis  has  been  put  on 
savings  for  organisers  but  some  also  concern  public  authorities  (the  Commission  and  the 
competent national authorities). 
- Online collection: the Commission will provide a central system for which organisers will 
not need to get a certificate from a national authority. This represents an important saving for 
organisers that will use the central system (costs for organisers have been estimated between 
16 000 and 51 000 EUR under the initial scheme foreseen in the Regulation, i.e. when they do 
not use the Commission hosting) and national authorities (costs have been estimated between 
30 000  and  60 000  EUR  per  certification  exercise)43.  National  authorities  will  nevertheless 
still  need  to  be  prepared  to  certify  systems  when  the  organisers  decide  to  build  their  own. 
However,  they  will  not  be  required  anymore  to  certify  systems  before  confirmation  of 
registration of the initiative concerned by the Commission, saving the costs of certification of 
systems that will potentially never be used (2 cases have been reported since 2012). 
The  Commission  will  bear  the  costs  of  the  central  online  collection  system.  While  this  will 
require an important investment to develop this system, the costs per initiative should stabilise 
overtime  and  not  be  higher than the  current  hosting and  support costs  for  the  same  level  of 

42 REFIT Platform Opinion on the submission by a member of the Stakeholder group on the European Citizens' 
Initiative – 27/28 June 2016 available at https://ec.europa.eu/info/files/refit-platform-recommendations-
european-citizen-initiative_en 
43 See study on Assessment of ICT impacts  of Regulation (EU) No 211/2011 on the citizens' initiative, page 98 
(http://ec.europa.eu/citizens-initiative/files/Final-report-ICT-impacts.pdf)   

49 

 
 
 
                                                            
service, given the absence of a certification procedure, the possibility to integrate it with the 
register  and  the  economies  of  scale  that  will  be  possible  compared  to  the  present  scheme 
where all systems have to be built separately. It is however expected that the central system 
will offer more features, notably the upload of scanned statements of support and the transfer 
of statements of support to national authorities, which are aimed at reinforcing the protection 
of  personal  data,  reducing  the  potential  liability  issues  for  organisers  and  transferring  any 
related costs from the organisers to the Commission. 
- Translations: The Commission will be in charge of the translations of the title and content 
of the registered initiatives, while this  is currently the responsibility of the organisers. They 
may since mid-2015 rely on the service offered to them for free by the European Economic 
and Social Committee.  
While it is difficult to estimate the costs for organisers, it is estimated that the translations will 
cost the Commission 500 EUR per initiative. 
As explained above in section 4.1.2, those costs are likely to be comparable to the situation 
where the Commission is required to verify the language versions provided by the organisers 
(initial  situation  according  to  the  current  Regulation)  and  overall,  costs  are  reduced  for  the 
public  administrations  compared  to  the  current  offer  of  the  EESC  as  this  offer  implies 
translation  costs  for  the  EESC  and  other  administrative  costs  for  the  Commission  to  handle 
the process with the organisers. 
- Statements of support forms: the collection in paper form will be facilitated by the use of 
only two forms instead of the current 13 different forms. Organisers may however still need to 
use  more  sheets  of  paper  depending  on  the  language(s)  in  which  they  want  to  collect 
statements  of  support  in  the  different  countries.  It  has  not  been  possible  to  quantify  those 
savings for organisers.  
-  Submission  of  statements  of  support  to  competent  national  authorities  by  the 
Commission: it is difficult to estimate the costs for organisers as it depends on the way they 
submit the statements of support to the competent authorities (in person, by registered mail, 
electronically). The Commission will take care of the submission when organisers will use the 
central online collection system for all statements of support collected online, as well as for 
those collected in paper form, scanned and uploaded into the system by the organisers when 
they wish so. Organisers will therefore save the costs of this secure transfer of the forms. This 
possibility of transfer will also be offered to organisers not using the central online collection 
system. The Commission will use an already available IT tool (EU file exchange service) to 
securely transfer the files.  

2.  MONITORING  

To  assess  the  extent  to  which  the  new  Regulation  reaches  its  objectives  and  to  address  the 
current  lack  of  data  for  monitoring,  which,  as  mentioned  above,  hampers  the  assessment  of 
the current Regulation, the indicators in the table below have been identified.  
These indicators will be regularly monitored by the Commission and serve as the basis for the 
review of the instrument which will be mainly focussed on the effectiveness and efficiency of 
various technical provisions. 
In  particular,  the  proposal  foresees  that  organisers  of  initiatives  shall  report  to  the 
Commission the number of statements of support they have collected, for publication in the 
Register. This will allow the Commission to better monitor the performance of the Regulation 

50 

 
 
 
without creating a significant additional burden on organisers who in any case have to count 
them to monitor the progress of their collection campaign.  

Figure 5: Monitoring table 

 Operational objectives  

Indicators 

Current situation 

Increase the number of requests 
for registration 

Number  of  requests  received 
by  the  Commission  (source: 
ECI Register) 

13 requests per year on 
average. 

Increase the number of initiatives 
registered by the Commission 

Rate of initiatives registered 
(source: ECI Register) 

70% of requests on average 
over 5 years  

Ensure full 12 months of online 
collection for all initiatives 

Number of initiatives using the 
central online collection 
system (source: system 
managed by Commission) 

70% of initiatives using the 
Commission software and 
servers  

Dates of certification of online 
collection systems compared 
with the start dates of 
collection (source: certificates 
as published by organisers)  

In average around one month 
after the date of registration for 
systems hosted on 
Commission servers 

Increase the average number of 
statements of support collected 
per initiative 

Number of statements of 
support collected per initiative 
at the end of the 12-month 
collection period (source: ECI 
Register, based on information 
to be reported by organisers) 

No exact figure is known by 
the Commission, except for the 
three successful initiatives 

Increase the number of initiatives 
that reach the required number of 
statements of support 

Number of successful 
initiatives (source: ECI 
Register) 

3 initiatives in 5 years 

Increase the number of initiatives 
that are subject to follow-up 
actions from the Commission 

Number of initiatives 
concerned (source: 
Commission) 

2 initiatives in 5 years 

Increase the awareness-raising of 
citizens about the instrument 

Results of surveys on 
awareness of EU citizens on 
their rights (source: 
Eurobarometer) 

Number of participants to 
initiatives (organisers and 
signatories) (source: ECI 

According to the results of 
Flash Eurobarometer 430 of 
October 2015, when asked 
whether EU citizens have the 
right to participate in a 
Citizens’ initiative, two thirds 
of respondents (66%) 
responded in the positive. 

51 

 
 
 
 
 
 
Register) 

Number of citizens kept 
informed by email on the 
instrument/on successful 
initiatives (source: ECI 
Register/online collaborative 
platform) 

Number of participants to the 
online collaborative platform 
(source: online collaborative 
platform) 

52 

 
 
 
 
 
ANNEX 2: PROCEDURAL INFORMATION 

1.  LEAD DG, DeCIDE PLANNING/CWP REFERENCES 

The  lead  service  for  the  revision  of  the  Regulation  (EU)  No  211/2011  on  the  citizens' 
initiative (ECI Regulation) is the Secretariat-General. 

The reference in Decide Planning is: PLAN/2017/1114 - SG - Revision of the Regulation on 
the European citizens' initiative 

This initiative was not foreseen in the Commission Work Programme. 

2.  ORGANISATION AND TIMING 

The  revision  of  the  Regulation  on  the  citizens'  initiative  was  publicly  announced  by  the 
Commission  First  Vice-President  Frans  Timmermans  on  the  occasion  of  the  "ECI  Day" 
Conference  on  11  April  2017,  as  a  result  of  a  two-year  review  process  triggered  by  the 
Commission  Report  on  the  application  of  the  Regulation  on  the  citizens'  initiative  of 
31 March 2015. 

The Roadmap for this initiative was published on 18 May 2017 and was subject to a feedback 
from the public until 15 June 2017. 

A public consultation was carried out between 24 May and 16 August 2017.  

All Commission Directorates-General and Services have been invited to take part in the Inter-
service  Steering  Group  set  up  in  the  context  of  the  revision.  The  Steering  Group  held  two 
meetings on 21 June and 19 July 2017 respectively. In parallel many aspects of the Regulation 
have been discussed directly in bilateral contacts with the relevant Directorates-General and 
services, including DG DIGIT, DG JUST, DG CONNECT, DG BUDG, the Commission Data 
Protection Officer and the Legal Service. 

The  Expert  Group  on  the  citizens'  initiative  composed  of  the  national  authorities  competent 
under the Regulation held a meeting dedicated to the revision of the ECI Regulation on 2 June 
2017. 

The planned adoption date is 12 September 2017. 

3.  EVIDENCE, SOURCES AND QUALITY 

Evidence and external expertise used: 

The Commission analysis draws on the following main sources: 

  Commission Report on the application of the Regulation on the citizens' initiative of 31 

March 2015  

  Commission  study  on  ICT  impacts  of  the  Regulation  on  the  citizens'  initiative  of  June 

2015  

  European Ombudsman own-initiative inquiry of 2013, closed in March 2015 

53 

 
 
  European  Parliament  studies  "European  Citizens'  Initiative  –  First 

lessons  of 
implementation"  (2014)  and  "Implementation  of  the  European  Citizens'  Initiative" 
(2015)  

  Council Presidency note of June 2015  

  Resolution of the European Parliament of October 2015 

  Opinion of the Committee of the Regions of October 2015  

  Opinion of the European Economic and Social Committee of July 2016 

  Conclusions of the "ECI Days" of 13 April 2015, 20 April 2016, 11 April 2017  

  REFIT Platform Recommendations on the citizens' initiative of June 2016  

  Eurobarometer results, as published in March 2016 

  European Ombudsman Strategic Initiative on the ECI of July 2017. 

The sources of analysis include moreover contributions from the public consultation, targeted 
stakeholder consultation activities mostly carried out in the context of the Commission studies 
and  two  petitions  on  the  ECI,  as  described  in  detail  in  the  synopsis  report  of  stakeholder 
consultation (annex 3). 

Due to its institutional nature, the ECI Regulation has no direct significant economic, social or 
environmental  impacts.  Therefore,  no  impact  assessment  was  carried  out  with  regard  to  its 
revision. However, the different options of improvement of  the technical architecture of the 
instrument  have  been  assessed  through  three  different  technical  studies  carried  out  in 
preparation for the revision between October 2016 and August 2017: 

  Study on data requirements for the European Citizens' Initiative;  

 

 Study  on  the  use  of  electronic  identification  (eID)  for  the  European  Citizens' 
Initiative; and 

  Study  on  online  collection  systems  and  technical  specifications  pursuant  to  ECI 
Regulation (EU) No 211/2011 and Implementing Regulation (EU) No1179/201144. 

Quality  of  the  sources  and  expertise  used  for  the  purpose  of  analysis  in  this  Staff  Working 
Document: 

The  following  reservations  need  to  be  stated  as  regards  the  quality  of  the  sources  and 
expertise used for the purpose of analysis in this Staff Working Document: 

  There exists no complete information as regards the number of statements of support 
collected  by  those  initiatives  which  have  not  reached  the  required  minima  of 
statements  of  support,  as  the  organisers  do  not  have  the  obligation  to  share  this 
information  with  the  Commission  and  statements  of  support  in  such  case  are  not 
verified by Member States. 

44 Studies are available on the following page: http://ec.europa.eu/citizens-initiative/public/regulation-review  

54 

 
 
                                                            
  To date, only a few among the competent authorities at national level participating in 
the  expert  group  on  the  ECI  have  actively  contributed  in  providing  input  for  the 
revision process.  

  Moreover, in the context of the technical studies on signatories' data requirements and 
on the e-ID as referred to above, it was difficult to obtain full information regarding 
the relevant national infrastructure.  

  There are strong limitations associated with attempts to quantify impact of signatories' 
data  requirements  on  participation  in  the  ECI.  Whilst  inferences  can  be  made  based 
upon agreed indicators that affect participation, and based upon existing literature and 
stakeholder  consultation,  statistically  significant  causal  links  cannot  be  established 
between a reduction in data requirements and an increase in the participation in ECIs 
by EU citizens. 

 

In the context of the Commission study on assessment of the ICT impacts of the ECI  
Regulation  mentioned  above,  only  very  limited  information  could  be  collected  from 
private software and hosting service providers, due to their limited interest in the ECI 
instrument.  This  potentially  impacts  on  the  reliability  of  the  cost  estimations  in  this 
study as well as in the study on online collection systems carried out in 2017 since it 
re-used the information gathered in the previous study. 

  The level of awareness about the ECI cannot be discerned directly from the results of 
the Eurobarometer survey referred to above and under section 4.6, due to the limited 
nature of the question. The respondents were asked whether EU citizens have the right 
to participate in a citizens’ initiative: while two thirds responded positively, some of 
them may have simply guessed the right answer. 

55 

 
 
 
 
ANNEX 3: STAKEHOLDER CONSULTATION 

Introduction 

The stakeholder consultation for the European Citizens' Initiative (ECI) had two phases: 

- the first phase (2015-March 2017) started with the Commission's report on application of the 
ECI  Regulation  (March  2015)  and  aimed  to  gather  views  on  the  Regulation  and  how  to 
improve it, under the existing or a possibly revised legal framework. 

- the second phase built on these results and gathered input on how to improve and revise the 
Regulation.  

In  addition  to  allowing  stakeholders  to  express  views  on  how  to  revise  the  ECI,  the 
consultation was also an opportunity to raise awareness about the ECI. 

1. Stakeholder groups covered by the consultation activities 

Input from a wide range of stakeholders was collected as described in the consultation strategy: 

- Citizens as signatories/potential signatories of ECI 

- Organisers of ECI 
- Member States' competent authorities45  

-  NGOs/CSOs  (mainly  active  in  the  field  of  participatory/direct  democracy  and  ECI 
promotion/support).  

-  Hosting  and  software  providers  and  IT  experts  involved  in  setting  up  online  collection 
systems.  

- Data protection authorities in Member States  

- Researchers (academia or think tanks)  

- Public authorities managing similar participatory instruments  

Input  also  came  from  other  EU  institutions  that  play  a  role  in  implementing  the  ECI,  in 
particular the European Parliament. 

The above list is based on the stakeholder analysis exercise carried out for the Commission's 
first study46.   

2. Consultation activities and other information sources 

In the first phase, consultation activities (e.g. survey, interviews, workshops) were carried out 
in the context of the studies, ECI Days and the European Ombudsman own-initiative inquiry. 
The  outcome  echoed  the  concerns  of  the  main  stakeholders  –  in  particular  organisers  of 
initiatives and citizens. Relevant documents are:  

- the Commission study on ICT impacts of the ECI Regulation (2015),  

45 These are the authorities represented in the Commission's expert group on the citizens' initiative. 
46 See Commission study on ICT impacts of the Regulation on the citizens' initiative of June 2015, pages 165-
168  

56 

 
 
 
 
 
                                                            
-  two  European  Parliament  studies  "European  Citizens’  Initiative  –  First  lessons  of 
implementation" and "Implementation of the European Citizens’ Initiative",  
- the Ombudsman own-initiative inquiry,  
-  the  conclusions  of  the  "ECI  Days"  organised  by  the  European  Economic  and  Social 
Committee (ECI Day of 13 April 2015 and ECI Day of 20 April 2016),  
- the Council Presidency note of 2015,  
- the Opinion of the Committee of the  Regions of October 2015,  
- the Resolution of the European Parliament of October 2015,  
- the REFIT Platform Opinion of June 2016, and  
- the Opinion of the European Economic and Social Committee of July 2016. 

The second phase included feedback on the roadmap (7 comments), a public consultation (May 
to  August  2017),  a  meeting  with  the  competent  national  authorities  (2  June  2017)  and  a 
meeting between the Commission’s First Vice-President and civil society organisations active 
in the field of participatory democracy and the ECI (30 August 2017). 

In  addition,  two  Commission  studies  involved  targeted  consultations  on  technical  aspects  of 
the instrument and signatories' data requirements. 
Finally, two petitions47 organised by civil society organisations (Mehr Demokratie, Democracy 
International, ECI Campaign and WeMove.EU) on the ECI reform collected respectively over 
40 000 and over 100 000 signatures48.  

For some stakeholder groups, in particular hosting and software providers, it was challenging 
to  obtain  input.  For  the  Commission's  study  on  ICT  impacts  of  the  ECI  Regulation  (2015), 
only 11 hosting providers replied of the 100 who were contacted in 23 countries. 

Only  a  few  competent  national  authorities,  all  represented  in  the  expert  group  on  the  ECI, 
provided  input  to  the  review.  In  some  countries,  it  was  difficult  to  get  information  for  the 
different studies, in particular the one on signatories' data requirements and on e-ID.  
The  public  consultation49  generated  5.323  responses,  98%  from  individuals.  37%  of 
respondents replied that they had not heard of the ECI before, which confirms that the public 
consultation  raised  awareness  and  reached  a  wider  audience  than  previous  activities.  5%  of 
respondents had  already organised an initiative or  collected statements of support,  3%  were 
preparing to launch one, and 6% indicated that they considered doing so but abandoned the 
idea.  

The number of replies per country varies greatly, with more than 30% from France and 25% 
from Germany. For 10 Member States (Slovenia, Lithuania, Estonia, Slovakia, Luxembourg, 
Cyprus,  Bulgaria,  the  Czech  Republic,  Hungary  and  Malta)  there  were  very  few  replies 
(below 20) despite the various communication activities, including via social media.  
The input has been analysed using a data analysis tool50 complemented by manual analysis. 

47 https://act.wemove.eu/campaigns/ECI-change-Eu-democracy-EN?utm_source=civimail-
8121&utm_medium=email&utm_campaign=20170811; https://www.democracy-international.org/eci-final-call 

48 The second petition is still open for signature. 
49 Respondents did not always reply to all the questions of the public consultation. Results (%) are therefore 
calculated on the basis of the total number of replies to each specific question only. 
50  The  tool  used  is  Doris  Public  Consultation  Dashboard,  an  internal  Commission  tool  for  analysing  and 
visualising consultation answers. It relies on open-source libraries using machine-learning techniques and allows 

57 

 
 
 
                                                            
 
Feedback received through social media has also been considered.  
Several civil society organisations organised a joint campaign51 encouraging citizens to reply 
to the public consultation and suggesting answers. 

3. Stakeholder consultation results 

Stakeholders  broadly  agree  on  the  need  to  simplify  the  ECI  and  make  rules  more 
proportionate to the nature of the instrument as presented in the following sections.  

Preparing and launching a citizens' initiative 

a.  Citizens' committee/Group of organisers 

The  main  concern  raised,  in  particular  by  organisers,  is  that  citizens'  committees  which 
organise initiatives do not have legal personality. Committee members therefore bear personal 
responsibility  and  often  face  obstacles  for  fund  raising  and  personal  data  protection 
procedures. 

Several suggestions were made to remedy liability issues:  

- the European Parliament in its resolution of October 2015 and the European Economic and 
Social Committee proposed to limit liability of committee members to acts that are ‘unlawful 
and  committed  intentionally  or  with  at  least  serious  negligence’  based  on  the  model  of 
Directive 2008/99/EC on protection of the environment through criminal law. 

- Various organisers of initiatives and civil society organisations, the European Ombudsman, 
the  Committee  of  the  Regions  and  the  REFIT  platform  proposed  to  give  the  citizens' 
committee legal status. 

-  Most  respondents  to  the  public  consultation  suggested  to  tackle  the  issue  indirectly  by 
reducing the amount of personal data collected from signatories (55% of individuals and 57% 
of  organisations)  and/or  transferring  the  responsibility  for  collecting  statements  of  support 
from organisers to public authorities (46% of individuals and 37% of organisations). 44% of 
organisations and 28% of citizens who replied proposed to allow organisations to be part of 
the citizens' committees.   

b.  Registration phase, advice and support to organisers 

Stakeholders  agreed  that  it  is  difficult  for  citizens  to  propose  initiatives  that  do  not  fall 
manifestly  outside  the  Commission's  competences  and  that  this  results  in  a  high  number  of 
refusals to register. 

Most  of  them  suggest  to  maintain  the  initial  check  (65%  of  respondents  to  the  public 
consultation)  but  to  allow  organisers  to  revise  the  proposal  if  the  Commission's  assessment 
indicates that the initiative partly or fully falls outside the Commission's powers.  

Other  stakeholders,  as  well  as  the  European  Parliament,  suggested  allowing  the  partial 
registration  of  initiatives  (as  the  Commission  is  now  doing).  Others  (civil  society 
organisations, Committee of the Regions) called for the possibility to register initiatives that 

the automatic creation of charts for closed questions, the extraction of keywords and named entities from free-
text answers as well as filtering functions, sentiment analysis and clustering. 
51 https://www.democracy-international.org/please-participate-public-consultation 

58 

 
 
 
 
                                                                                                                                                                                          
would require changing the EU Treaties. Several contributions (European Parliament, EESC, 
Committee  of  the  Regions,  Ombudsman)  suggested  that  the  Commission  provide  more 
detailed reasoning when refusing to register an initiative. 

Stakeholders broadly agreed to strengthen assistance to organisers (83% of respondents to the 
public  consultation)  and  suggested  to  provide  other  types  of  support  such  as  assistance  for 
(re)drafting, translation of initiatives and financial support.  

The REFIT platform proposed to establish an ECI officer, similar to the Hearing Officer for 
competition  law,  who  would  have  an  independent  role  within  the  Commission  to  advise 
organisers on the registration procedure. 

As part of the public consultation, two options were proposed on assistance in the preparatory 
phase and two on support to redraft initiatives. On assistance in the preparatory phase, 56% of 
respondents supported the option of a Commission helpdesk. 77% of respondents supported 
the option of services offered by independent experts (e.g. an online collaborative platform). 
Both  options  for  support  to  redraft  initiatives,  i.e.  independent  experts  and  an  ECI  officer, 
were  considered  equally  beneficial  by  71%  of  organisations,  while  78%  of  individuals 
supported independent experts and 63% an ECI officer. 

Collecting and verifying statements of support 

c.  Minimum age for signatories 

Several  stakeholders, the  European  Parliament,  the  EESC  and  the  ECI  Campaign  suggested 
harmonising  the  minimum  age  to  support  an  initiative  at  16  to  encourage  participation  of 
young people in the democratic life of the Union.  

Almost  half  of  the  organisations  and  42%  of  individuals  that  responded  to  the  public 
consultation  supported  this  suggestion  while  32%  overall  suggested  to  maintain  the  voting 
age. 18% of organisations and 25% of individuals proposed to harmonise age at 18. 

d.  Data to be provided by signatories and verification by Member States 

Stakeholders generally proposed to simplify and harmonise data requirements for signatories. 
Some  competent  national  authorities  nevertheless  find  it  complicated  to  have  a  harmonised 
form in all Member States given different administrative processing systems.  

On  types  of  data  to  be  provided  by  signatories,  the  European  Parliament  and  the  ECI 
Campaign asked to remove personal identification numbers while the EESC proposed to limit 
this requirement. 

For the study on signatories' data requirements, it was challenging to find reliable information 
on  what  personal  data  citizens  find  sensitive  to  provide.  However,  in  21  countries, 
stakeholders  (civil  society  organisations  and  national  authorities  mainly)  indicated  no  issue 
with the type of data required (including countries requiring personal identification numbers). 
Likewise,  30%  of  respondents  to  the  public  consultation  replied  that  none  of  the  proposed 
data  would  be  a  problem.  83  respondents,  of  which  60  were  from  France,  never  signed  an 
initiative because of the personal data requested. Of the 2657 respondents who had supported 
an  initiative,  297  felt  that  too  much  data  was  requested  but  provided  them  in  any  case. 
Overall,  33%  found  the  process  to  support  an  initiative  not  user-friendly,  most  of  them 
because it took them too long. 

However, in the context of the study, where concerns have been raised on the sensitivity to 
provide some data, they primarily relate to personal identification numbers. The results of the 

59 

 
 
 
public consultation confirmed this with around 50% of respondents not willing to provide this 
number (41% among respondents from those countries which currently ask for it). The score 
is even higher as regards the driving license number with 58% of respondents not willing to 
provide it – it is currently not requested in the context of the ECI. Those are followed by the 
last  three  digits  of  the  personal  identification  (document)  number/driving  license  number 
(37%  including  some  respondents  who  selected  it  only  for  the  driving  license  number),  the 
place of birth (33%), the address (28%) and name at birth (27%). 

It is also important  to  note that results differ depending  on the country of nationality of the 
respondent.  For  example,  concerns  about  providing  the  address  score  equal  or  higher  than 
providing  the  personal  identification  (document)  number  in  nine  countries  (eight  of  them 
currently requiring such a number). 

Stakeholders  broadly  agree  that  all  EU  citizens  should  be  able  to  support  an  initiative 
regardless  of  the  country  of  residence.  For  EU  citizens  living  outside  the  EU,  49%  of 
respondents  to  this  question  of  the  public  consultation  (60%  of  organisations)  suggest  they 
should be able to support initiatives, while 42% (34% of organisations) consider that it should 
be  limited  to  citizens  eligible  to  vote  in  European  Parliament  elections.  6%  (4%  of 
organisations) think they should not be allowed at all. 

Some competent national authorities regret the absence of a procedure to verify paper forms 
for collecting signatures. Several national authorities raised concerns about the possibility to 
use  software  different from the one offered by  the Commission, given the increased burden 
caused by electronic files provided in different formats.  

e.  Online collection 

Stakeholders broadly agree to facilitate online collection. 98% of respondents to the relevant 
question in the public consultation, as well as some Member States, the European Parliament 
and the EESC, consider that the Commission should continue to offer its own servers for free. 
The REFIT Platform suggested developing one centralised system. 67% of respondents to the 
question concerned in the public consultation replied that the Commission hosting of systems 
should  be  made  permanent  but  remain  optional.  87% of  respondents  would  prefer  the 
Commission system instead of developing an alternative system.  

Several  stakeholders  (European  Ombudsman,  European  Parliament,  EESC,  ECI  Campaign) 
highlighted the importance that systems address the needs of persons with disabilities. 

Several Member States called for the possibility to sign using e-ID and to develop synergies 
with  eIDAS52.  The  ECI  Campaign  considers  that  the  system  should  allow  for  electronic 
signatures. 67% of respondents to the public consultation think that using e-ID would make 
the  process  more  user-friendly,  while  87%  agreed  that  several  ways  for  providing  support 
online should be offered in parallel. 

On  certification  of  online  collection  systems,  several  national  authorities  suggested  that  the 
request to certify systems should be possible only after the Commission has confirmed that it 
has  registered  the  initiative,  and  to  make  the  technical  specifications  (Implementing 
Regulation (EU) No 1179/2011) more flexible and less burdensome. The ECI Campaign also 
asked for this simplification. 

For  the  central  online  collection  system,  47%  of  respondents  to  the  public  consultation 
considered  that  paper  statements  should  be  sent  to  national  authorities  and  their  number 

52 https://ec.europa.eu/digital-single-market/en/trust-services-and-eid  

60 

 
 
                                                            
reported on the platform during the collection process. 31% think the statements should either 
be  scanned  and  uploaded  or  manually  entered  into  the  central  system,  and  13%  that  paper 
collection should not be allowed. 

f.  Time period for collection 

Stakeholders  broadly  agree  to  revise  the  timeline  of  initiatives.  Most  of  them  (civil  society 
organisations  and  organisers,  several  Member  States,  the  European  Parliament,  EESC, 
Committee of the Regions, European Ombudsman) suggest allowing organisers to choose the 
start date of the collection period within a given time limit. 

Some stakeholders suggested extending the collection period, in addition to (Committee of the 
Regions) or alternatively to (some Member States) the possibility to choose the starting date, 
or  that  it  should  start  on  the  date  of  certification  of  the  online  collection  system  (European 
Ombudsman).  The  REFIT  platform  considered  that  if  the  process  is  not  "streamlined  and 
simplified",  the  collection  period  should  be  extended  to  18  months  or  only  start  after  the 
certification  of  the  online  collection  system.  Among  respondents  to  the  public  consultation, 
27% of  individuals  and  40%  of  organisations  suggested  revising  the  timeline,  mostly 
suggesting an extension to 18 months. 

Follow-up to successful initiatives 

g.  Time limit for submission  

Some stakeholders, the European Parliament and several national authorities, regret the lack 
of a time limit for submitting initiatives to the Commission. Two-thirds of respondents to the 
public consultation suggest setting a deadline (80% of organisations). 

h.  Examination procedure 

Most stakeholders think the Commission should explain in a transparent and detailed manner 
its political decisions and make the examination and follow-up more inclusive. 

Several suggestions were made:  

- the European Parliament, the Committee of the Regions, the European Ombudsman and one 
Member State proposed to reinforce the inclusiveness of the public hearings in the Parliament, 
notably by inviting experts or stakeholders representing different views, an idea supported by 
77% of respondents to the public consultation. The Ombudsman considered that the Council 
should be present at such hearings. 

 - the European Ombudsman, supported by 55% of respondents to the consultation considers 
the  3  months  deadline  for  the  Commission  to  prepare  the  public  hearing  and  to  adopt  the 
Communication too short, preventing wide and transparent consultation. 

- The Ombudsman, supported by 70% of respondents to the consultation, suggested involving 
both Parliament and Council before the Commission takes a position on an initiative. 

- The European Parliament, EESC, Committee of the Regions suggested that the Commission 
start preparing a legal act within 12 months if it agrees to a successful ECI. 

Communication and transparency 

All stakeholders agree on the need to increase awareness of the ECI. This is confirmed by the 
fact  that  37%  of  respondents  to  the  public  consultation  had  not  heard  of  the  tool.  Several 
suggestions were made, notably to: 

- set up information campaigns (European Parliament, several Member States, EESC, REFIT 
61 

 
 
 
Platform), involving local and regional authorities (Committee of the Regions); 

-  create  applications  that  provide  information,  send  notifications  and  allow  online  signing 
(European Parliament); 

The  EESC,  Committee  of  the  Regions  and  the  ECI  Campaign  suggest  facilitating  dialogue 
with citizens by allowing organisers and/or the EU institutions to inform signatories about the 
results achieved. A majority of respondents to the public consultation would like to be kept 
informed about the initiative they supported and its follow-up by the organisers (65%) and the 
Commission (52%). 

The suggestions from stakeholders have been duly taken into account in the revised proposal. 
Some suggestions have not been taken up either because they were considered less effective 
or  efficient  than  others or  because  they  were  not  legally  possible.  Detailed  explanations  are 
provided in the Staff Working Document, notably sections 4.1, 4.2, 4.3 and 4.4. 

62 

 
 
 
 
At any time before starting  
to collect statements online: 

Citizens’ committee asks relevant 
national authority to certify its online 
collection system. 

The system is certified by the relevant 
national authority. 

M
a
x
.

1

m
o
n
t
h

ANNEX 4: CURRENT ECI PROCEDURE (REGULATION (EU) NO 211/2011) 

Commission will not register the 
proposed initiative if: 
it is abusive, frivolous or vexatious or 
it is manifestly contrary to EU values or 
it is manifestly outside the Commission’s 
powers or 
composition of citizens’ committee does 
not follow the rules 

• 
• 
• 

• 

The citizens’ committee is set up and 
nominates a representative and a substitute who 
will be the contact persons. 

The citizens’ committee requests the registration 
of  its proposed initiative to the Commission. 

The Commission registers the proposed 
initiative and makes it public. 

c
o
m
m

i
t
t
e
e

C
i
t
i
z
e
n
s
’

R
e
g
i
s
t
r
a
t
i
o
n

The citizens’ committee collects  
statements of  support  
(in paper form and/or electronically). 

At least 1 million statements of support collected 
from at least ¼ of EU countries (7 out of 27): 
Citizens’ committee asks competent national 
authorities to verify statements of  support. 

The competent national authorities verify and certify 
the number of  valid statements of  support. 

Citizens’ committee submits the finalised 
initiative to the Commission. 

Commission meets organisers and a public 
hearing is organised at the European 
Parliament. Commission answers in a 
Communication. 

C
o
l
l
e
c
t
i
o
n

s
t
a
t
e
m
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s

V
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m
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a
t
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n

S
u
b
m

i
s
s
i
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n
a
n
d

M
a
x
.

2
m
o
n
t
h
s

M
a
x
.

1
2
m
o
n
t
h
s

M
a
x
.

3
m
o
n
t
h
s

M
a
x
.

3
m
o
n
t
h
s

63 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 5: SIGNATORIES' DATA REQUIREMENTS ACCORDING TO MEMBER STATES 

1 

2 

3 

4 

5 

6 

7 

8 

Data required 
1.  Full first names  
2.  Family names 
3.  Nationality 
4.  Personal identification (document) type and number 

1.  Full first names  
2.  Family names 
3.  Residence (street, number, postal code, city, country) 
4.  Date of birth  
5.  Place of birth  
6.  Nationality  
1.  Full first names  
2.  Family names 
3.  Date of birth  
4.  Nationality 
5.  Personal identification (document) type and number 
1.  Full first names  
2.  Family names 
3.  Residence (street, number, postal code, city, country) 
4.  Nationality 
5.  Personal identification number 
1.  Full first names  
2.  Family names 
3.  Name at birth 
4.  Residence (street, number, postal code, city, country) 
5.  Date of birth  
6.  Place of birth  
7.  Nationality 
1.  Full first names  
2.  Family names 
3.  Residence (street, number, postal code, city, country) 
4.  Date of birth  
5.  Nationality 
1.  Full first names  
2.  Family names 
3.  Residence (street, number, postal code, city, country) 
4.  Date of birth  
5.  Place of birth  
6.  Nationality 
7.  Personal identification document type and number  
1.  Full first names  
2.  Family names 
3.  Country of permanent residence 
4.  Date of birth  
5.  Nationality 

Member State(s) 
Czech Republic 
Cyprus 
Latvia 
Lithuania 
Hungary 
Sweden 
Belgium 
Denmark 
Germany 
Estonia 
Luxembourg 

Spain 
Malta 
Portugal 

Croatia 
Poland 

The Netherlands 
Slovakia 

Ireland 
The United 
Kingdom 

France 
Austria 

Finland 

64 

 
 
9 

10 

11 

12 

13 

1.  Full first names  
2.  Family names 
3.  Residence (street, number, postal code, city, country) 
4.  Date of birth  
5.  Place of birth  
6.  Nationality 
7.  Personal identification document type and number 
8.  Issuing authority of the personal identification document 
1.  Full first names  
2.  Family names 
3.  Father's name 
4.  Name at birth 
5.  Date of birth  
6.  Nationality 
7.  Personal identification document type and number 
1.  Full first names  
2.  Family names 
3.  Father's name 
4.  Nationality 
5.  Personal identification number 
1.  Full first names  
2.  Family names 
3.  Residence (street, number, postal code, city, country) 
4.  Date of birth  
5.  Nationality 
6.  Personal identification (document) type and number 
1.  Full first names  
2.  Family names 
3.  Date of birth  
4.  Place of birth  
5.  Nationality 
6.  Personal identification number 

Italy 

Greece 

Bulgaria 

Romania 

Slovenia 

65 

 
 
 
 
 
ANNEX 6: REQUIREMENTS TO SIGN UP TO A EUROPEAN CITIZENS' INITIATIVE 

GENERAL REQUIREMENTS 

To  support  a  European  Citizens'  Initiative,  signatories  must  be  EU  citizens  (nationals  of  an 
EU member state) and be old enough to vote in European Parliament elections (18 except in 
Austria where the voting age is 16). 

DATA REQUIREMENTS 

The  data  that  signatories  are  required  to  provide  in  their  statement  of  support  forms  will 
depend  on  the  EU  member  state  which  they  come  from.  This  is  because  it  is  the  member 
states that are responsible for verifying the validity of signatories' statements of support and 
for  certifying  the  number  of  valid  statements  collected  in  each  country  (organisers  of 
initiatives  are  required  to  collect  a  certain  number  of  signatures  in  at  least  7  EU  member 
states).  

If  a  signatory  lives  in  one  member  state  but  is  a  national  of  another  member  state  or  if  a 
signatory holds the nationality of several member states, they will need to choose the country 
for which their statement of support will be counted.  They should select the country which 
will  be  able  to  verify  the  data  they  provide  in  their  statement  of  support:  depending  on  the 
case, this could be the country that issued the personal identification document number that 
they  provide,  their  country  of  residence  or  their  country  (or  one  of  their  countries)  of 
nationality. In any case, signatories are allowed to sign up to a given initiative only once. 

SPECIFIC REQUIREMENTS FOR EACH MEMBER STATE 

Austria 

Signatories  have  to  provide  one  of  the  following  personal  identification  document 
numbers issued by Austria:  

o  Reisepass (passport)  
o  Personalausweis (identity card)  

Belgium 

Signatories  must  be  residents  in  Belgium  or  Belgian  nationals  residing  outside  Belgium 
provided they have informed the Belgian authorities about their place of residence.  

Bulgaria 

Signatories  have  to  provide  the  following  personal  identification  number  issued  by 
Bulgaria:  

o  Единен граждански номер (personal number)  

66 

 
Croatia 

Signatories  have  to  provide  the  following  personal  identification  number  issued  by 
Croatia: 

o  Osobni identifikacijski broj (personal identification number) 

Cyprus 

Signatories have to provide one of the following personal identification document numbers 
issued by Cyprus:  

o  Δελτίο Ταυτότητας (identity card of national or resident)  
o  Διαβατήριο (passport)  

Czech Republic 

Signatories have to provide one of the following personal identification document numbers 
issued by the Czech Republic:  

o  Občanský průkaz (national identity card)  
o  Cestovní pas (passport)  

Denmark 

Signatories must be residents in Denmark or Danish nationals residing outside Denmark 
provided they have informed the Danish authorities about their place of residence. 

Estonia 

Signatories must be residents in Estonia or Estonian nationals even if they reside outside 
Estonia.  

Finland 

Signatories  must  be  residents  in  Finland  or  Finnish  nationals  even  if  they  reside  outside 
Finland. 

France 

Signatories have to provide one of the following personal identification document numbers 
issued by France:  

o  Passeport (passport)  
o  Carte nationale d'identité (national identity card)  

Germany 

67 

 
Signatories  must  be  residents  in  Germany  or  German  nationals  residing  outside 
Germany provided they have informed the German authorities about their place of residence. 

Greece 

Signatories have to provide one of the following personal identification document numbers 
issued by Greece:  

o  Δελτίο Αστυνομικής Ταυτότητας (identity card)  
o  Διαβατήριο (passport)  
o  Βεβαίωση  Εγγραφής  Πολιτών  Ε.Ε./Έγγραφο  πιστοποίησης  μόνιμης  διαμονής 

πολίτη Ε.Ε. (residence certificate/permanent residence certificate)  

Hungary 

Signatories  have  to  provide  one  of  the  following  personal  identification  (document) 
numbers issued by Hungary:  

o  személyazonosító igazolvány (identity card)  
o  útlevél (passport)  
o  személyi azonosító szám (személyi szám) (personal identification number)  

Ireland 

Signatories must be residents in Ireland. 

Irish nationals living in another member state should select that member state. 

Italy 

Signatories have to provide one of the following personal identification document numbers 
issued by Italy:  

o  Passaporto,  inclusa  l'indicazione  dell'autorità  di  rilascio  (passport,  including 

issuing authority)  

o  Carta  di  identità,  inclusa  l'indicazione  dell'autorità  di  rilascio  (identity  card, 

including issuing authority)  

Latvia 

Signatories have to provide the following personal identification number issued by Latvia:  

o  Personas kods (personal identification number)  

Lithuania 

Signatories  have  to  provide  the  following  personal  identification  number  issued  by 
Lithuania:  

68 

 
o  Asmens kodas (personal number)  

Luxembourg 

Signatories  must  be  residents  in  Luxembourg  or  Luxembourgish  nationals  residing 
outside Luxembourg provided they have informed the Luxembourgish authorities about their 
place of residence.  

Malta 

Signatories have to provide one of the following personal identification document numbers 
issued by Malta:  

o  Karta tal-Identità (identity card)  
o  Dokument ta ’residenza (residence document) 

Netherlands 

Signatories  must  be  residents  in  the  Netherlands  or  Dutch  nationals  even  if  they  reside 
outside the Netherlands. 

Poland 

Signatories have to provide the following personal identification number issued by Poland:  

o  Numer ewidencyjny PESEL (PESEL identification number)  

Portugal 

Signatories have to provide one of the following personal identification document numbers 
issued by Portugal:  

o  Bilhete de identidade (identity card)  
o  Passaporte (passport)  
o  Cartão de Cidadão (citizen's card)  

Romania 

Signatories  have  to  provide  one  of  the  following  personal  identification  (document) 
numbers issued by Romania:  

o  carte de identitate (identity card) 
o  pașaport (passport) 
o  certificat de înregistrare (registration certificate) 
o  carte  de  rezidență  permanentă  pentru  cetățenii  UE  (permanent  residence  card 

for EU citizens) 

o  Cod Numeric Personal (personal identification number)  

69 

 
Slovakia 

Signatories must be residents in Slovakia or Slovakian nationals even if they reside outside 
Slovakia.  

Slovenia 

Signatories  have  to  provide  the  following  personal  identification  number  issued  by 
Slovenia:  

o  Enotna matična številka občana (personal identification number) 

Spain 

Signatories  have  to  provide  one  of  the  following  personal  identification  (document) 
numbers issued by Spain:  

o  Documento Nacional de Identidad (identity card)  
o  Pasaporte (passport)  
o  Número de Identidad de Extranjero, de la tarjeta o certificado, correspondiente 
a  la  inscripción  en  el  Registro  Central  de  Extranjeros  (foreigner’s  identification 
number  (NIE),  of  the  card  or  certificate,  corresponding  to  the  registration  in  the 
Foreigners’ Central Registry) 

Sweden 

Signatories  have  to  provide  the  following  personal  identification  number  issued  by 
Sweden:  

o  Personnummer (personal identification number)  

United Kingdom 

Signatories must be residents in the United Kingdom. 

UK nationals living in another member state should select that member state. 

70 

 
 
ANNEX 7: ECI COUNTRY FORM THAT SIGNATORIES CAN USE DEPENDING ON THEIR CITIZENSHIP AND RESIDENCE   

This table has been elaborated on the basis of the signatory requirements set out by the Member States in Regulation (EU) No 211/ 2011 on the citizens' initiative. 

71 

Legend:CC = Country CodeCCCC/CCxCC* If you are aCitizen ofBelgium (BE)Bulgaria (BG)Czech Republic (CZ)Denmark (DK)Germany (DE)Estonia (EE)Ireland (IE)Greece (EL)Spain (ES)France (FR)Croatia (HR)Italy (IT)Cyprus (CY)Latvia (LV)Lithuania (LT)Luxembourg (LU)Hungary (HU)Malta (MT)Netherlands (NL)Austria (AT)Poland (PL)Portugal (PT)Romania (RO)Slovenia (SI)Slovakia (SK)Finland (FI)Sweden (SE)United Kingdom (UK)NON-EUResident inBelgium (BE)BEBE/ BGBE/ CZBE/ DA*BE/ DE*BE/ EEBEBE/ ELBE/ ESBE/ FRBE/ HRBE/ ITBE/ CYBE/ LVBE/ LTBE/ LU*BE/ HUBE/ MTBE/ NLBE/ ATBE/ PLBE/ PTBE/ ROBE/ SIBE/ SKBE/ FIBE/ SEBExBulgaria (BG)BE*BGCZDA*DE*EExELESFRHRITCYLVLTLU*HUMTNLATPLPTROSISKFISExxCzech Republic (CZ)BE*BGCZDA*DE*EExELESFRHRITCYLVLTLU*HUMTNLATPLPTROSISKFISExxDenmark (DK)BE*/ DABG/ DACZ/ DADADA/ DE*DA/ EEDADA/ ELDA/ ESDA/ FRDA/ HRDA/ ITDA/ CYDA/ LVDA/ LTDA/ LU*DA/ HUDA/ MTDA/ NLDA/ ATDA/ PLDA/ PTDA/ RODA/ SIDA/ SKDA/ FIDA/ SEDAxGermany (DE)BE*/ DEBG/ DECZ/ DEDA*/ DEDEDE/ EEDEDE/ ELDE/ ESDE/ FRDE/ HRDE/ ITDE/ CYDE/ LVDE/ LTDE/ LU*DE/ HUDE/ MTDE/ NLDE/ ATDE/ PLDE/ PTDE/ RODE/ SIDE/ SKDE/ FIDE/ SEDExEstonia (EE)BE*/ EEBG/ EECZ/ EEDA*/ EEDE*/ EEEEEEEE/ ELEE/ ESEE/ FREE/ HREE/ ITEE/ CYEE/ LVEE/ LTEE/ LU*EE/ HUEE/ MTEE/ NLEE/ ATEE/ PLEE/ PTEE/ ROEE/ SIEE/ SKEE/ FIEE/ SEEExIreland (IE)BE*/ IEBG/ IECZ/ IEDA*/ IEDE*/ IEEE/ IEIEIE/ ELIE/ ESIE/ FRIE/ HRIE/ ITIE/ CYIE/ LVIE/ LTIE/ LU*IE/ HUIE/ MTIE/ NLIE/ ATIE/ PLIE/ PTIE/ ROIE/ SIIE/ SKIE/ FIIE/ SEIExGreece (EL)BE*/ ELBG/ ELCZ/ ELDA*/ ELDE*/ ELEE/ ELELELEL/ ESEL/ FREL/ HREL/ ITEL/ CYEL/ LVEL/ LTEL/ LU*EL/ HUEL/ MTEL/ NLEL/ ATEL/ PLEL/ PTEL/ ROEL/ SIEL/ SKEL/ FIEL/ SEELx The use of the corresponding form is subject to the holding of a personal identification (document) number issued by the country concerned (see the (document) number(s) accepted by each country concerned below the table)Only if your national authorities are informed of your place of residenceYou can use the form of the country corresponding to the Country Code indicated (either the one of your country of nationality or the one of your country of residence)You can choose between the forms of the countries corresponding to the Country Codes indicated (your country of nationality and your country of residence) - In any case, you can give your support ONLY ONCE for a given European citizens' initiativeDue to the requirements asked by your country of nationality and your country of residence, you cannot give your support to a European citizens' initiative. In addition, non-EU citizens cannot support a European citizens' initiative. 
 
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If you are aCitizen ofBelgium (BE)Bulgaria (BG)Czech Republic (CZ)Denmark (DK)Germany (DE)Estonia (EE)Ireland (IE)Greece (EL)Spain (ES)France (FR)Croatia (HR)Italy (IT)Cyprus (CY)Latvia (LV)Lithuania (LT)Luxembourg (LU)Hungary (HU)Malta (MT)Netherlands (NL)Austria (AT)Poland (PL)Portugal (PT)Romania (RO)Slovenia (SI)Slovakia (SK)Finland (FI)Sweden (SE)United Kingdom (UK)NON-EUResident inSpain (ES)BE*/ ESBG/ ESCZ/ ESDA*/ ESDE*/ ESEE/ ESESEL/ ESESES/ FRES/ HRES/ ITES/ CYES/ LVES/ LTES/ LU*ES/ HUES/ MTES/ NLES/ ATES/ PLES/ PTES/ ROES/ SIES/ SKES/ FIES/ SEESxFrance (FR)BE*BGCZDA*DE*EExELESFRHRITCYLVLTLU*HUMTNLATPLPTROSISKFISExxCroatia (HR)BE*/ HRBG/ HRCZ/ HRDA*/ HRDE*/ HREE/ HRHREL/ HRES/ HRFR/ HRHRHR/ ITHR/ CYHR/ LVHR/ LTHR/ LU*HR/ HUHR/ MTHR/ NLHR/ ATHR/ PLHR/ PTHR/ ROHR/ SIHR/ SKHR/ FIHR/ SEHRxItaly (IT)BE*/ ITBG/ ITCZ/ ITDA*/ ITDE*/ ITEE/ ITITEL/ ITES/ ITFR/ ITIT/ HRITIT/ CYIT/ LVIT/ LTIT/ LU*IT/ HUIT/ MTIT/ NLIT/ ATIT/ PLIT/ PTIT/ ROIT/ SIIT/ SKIT/ FIIT/ SEITxCyprus (CY)BE*/ CYBG/ CYCZ/ CYDA*/ CYDE*/ CYEE/ CYCYEL/ CYES/ CYFR/ CYHR/ CYIT/ CYCYCY/ LVCY/ LTCY/ LU*CY/ HUCY/ MTCY/ NLCY/ ATCY/ PLCY/ PTCY/ ROCY/ SICY/ SKCY/ FICY/ SECYxLatvia (LV)BE*/ LVBG/ LVCZ/ LVDA*/ LVDE*/ LVEE/ LVLVEL/ LVES/ LVFR/ LVHR/ LVIT/ LVCY/ LVLVLV/ LTLV/ LU*LV/ HULV/ MTLV/ NLLV/ ATLV/ PLLV/ PTLV/ ROLV/ SILV/ SKLV/ FILV/ SELVxLithuania (LT)BE*/ LTBG/ LTCZ/ LTDA*/ LTDE*/ LTEE/ LTLTEL/ LTES/ LTFR/ LTHR/ LTIT/ LTCY/ LTLV/ LTLTLT/ LU*LT/ HULT/ MTLT/ NLLT/ ATLT/ PLLT/ PTLT/ ROLT/ SILT/ SKLT/ FILT/ SELTxLuxembourg (LU)BE*/ LUBG/ LUCZ/ LUDA*/ LUDE*/ LUEE/ LULUEL/ LUES/ LUFR/ LUHR/ LUIT/ LUCY/ LULV/ LULT/ LULULU/ HULU/ MTLU/ NLLU/ ATLU/ PLLU/ PTLU/ ROLU/ SILU/ SKLU/ FILU/ SELUxHungary (HU)BE* / HUBG / HUCZ / HUDA* / HUDE* / HUEE / HUHUEL / HUES / HUFR / HUHR / HUIT / HUCY / HULV / HULT / HULU* / HUHUMT / HUNL / HUAT / HUPL / HUPT / HURO / HUSI / HUSK / HUFI / HUSE / HUHUxMalta (MT)BE*/ MTBG/ MTCZ/ MTDA*/ MTDE*/ MTEE/ MTMTEL/ MTES/ MTFR/ MTHR/ MTIT/ MTCY/ MTLV/ MTLT/ MTLU*/ MTHU/ MTMTNL/ MTAT/ MTPL/ MTPT/ MTRO/ MTSI/ MTSK/ MTFI/ MTSE/ MTMTxNetherlands (NL)BE*/ NLBG/ NLCZ/ NLDA*/ NLDE*/ NLEE/ NLNLEL/ NLES/ NLFR/ NLHR/ NLIT/ NLCY/ NLLV/ NLLT/ NLLU*/ NLHU/ NLMT/ NLNLNL/ ATNL/ PLNL/ PTNL/ RONL/ SINL/ SKNL/ FINL/ SENLxAustria (AT)BE*BGCZDA*DE*EExELESFRHRITCYLVLTLU*HUMTNLATPLPTROSISKFISExxPoland (PL)BE*/ PLBG/ PLCZ/ PLDA*/ PLDE*/ PLEE/ PLPLEL/ PLES/ PLFR/ PLHR/ PLIT/ PLCY/ PLLV/ PLLT/ PLLU*/ PLHU/ PLMT/ PLNL/ PLAT/ PLPLPT/ PLRO/ PLSI/ PLSK/ PLFI/ PLSE/ PLPLxPortugal (PT)BE*BGCZDA*DE*EExELESFRHRITCYLVLTLU*HUMTNLATPLPTROSISKFISExx 
 
 
 
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If you are aCitizen ofBelgium (BE)Bulgaria (BG)Czech Republic (CZ)Denmark (DK)Germany (DE)Estonia (EE)Ireland (IE)Greece (EL)Spain (ES)France (FR)Croatia (HR)Italy (IT)Cyprus (CY)Latvia (LV)Lithuania (LT)Luxembourg (LU)Hungary (HU)Malta (MT)Netherlands (NL)Austria (AT)Poland (PL)Portugal (PT)Romania (RO)Slovenia (SI)Slovakia (SK)Finland (FI)Sweden (SE)United Kingdom (UK)NON-EUResident inRomania (RO)BE*/ ROBG/ ROCZ/ RODA*/ RODE*/ ROEE/ ROROEL/ ROES/ ROFR/ ROHR/ ROIT/ ROCY/  ROLV/  ROLT/  ROLU*/ ROHU/ ROMT/ RONL/ ROAT/ ROPL/ ROPT/ RORORO/ SIRO/ SKRO/ FIRO/ SEROxSlovenia (SI)BE*/ SIBG/ SICZ/ SIDA*/ SIDE*/ SIEE/ SISIEL/ SIES/ SIFR/ SIHR/ SIIT/ SICY/ SILV/ SILT/ SILU*/ SIHU/ SIMT/ SINL/ SIAT/ SIPL/ SIPT/ SIRO/ SISISI/ SKSI/ FISI/ SESIxSlovakia (SK)BE*/ SKBG/ SKCZ/ SKDA*/ SKDE*/ SKEE/ SKSKEL/ SKES/ SKFR/ SKHR/ SKIT/ SKCY/ SKLV/ SKLT/ SKLU*/ SKHU/ SKMT/ SKNL/ SKAT/ SKPL/ SKPT/ SKRO/ SKSI/ SKSKSK/ FISK/ SESKxFinland (FI)BE*/ FIBG/ FICZ/ FIDA*/ FIDE*/ FIEE/ FIFIEL/ FIES/ FIFR/ FIHR/ FIIT/ FICY/ FILV/ FILT/ FILU*/ FIHU/ FIMT/ FINL/ FIAT/ FIPL/ FIPT/ FIRO/ FISI/ FISK/ FIFIFI/ SEFIxSweden (SE)BE*/ SEBG/ SECZ/ SEDA*/ SEDE*/ SEEE/ SESEEL/ SEES/ SEFR/ SEHR/ SEIT/ SECY/ SELV/ SELT/ SELU*/ SEHU/ SEMT/ SENL/ SEAT/ SEPL/ SEPT/ SERO/ SESI/ SESK/ SEFI/ SESESExUnited Kingdom (UK)BE*/ UKBG/ UKCZ/ UKDA*/ UKDE*/ UKEE/ UKUKEL/ UKES/ UKFR/ UKHR/ UKIT/ UKCY/ UKLV/ UKLT/ UKLU*/ UKHU/ UKMT/ UKNL/ UKAT/ UKPL/ UKPT/ UKRO/ UKSI/ UKSK/ UKFI/ UKSE/ UKUKxNON-EUBE*BGCZDA*DE*EExELESFRHRITCYLVLTLU*HUMTNLATPLPTROSISKFISExx 
 
ANNEX 8: CORRELATION TABLE 

Regulation (EU) No 211/2011 

The proposal 

Article 1 and 2 

Article 3(1) 

Article 3(2) 

Article 3(3) 

Article 3(4) 

Article 1 

Article 5(2) 

Article 5(1)(3) 

Article 5(4) 

Article 2 

Article 4(1) first subparagraph 

Article 6(1) 

Article 4(1) second subparagraph 

Articles 6(2) and 4(3) 

Article 4(1) third subparagraph 

Article 4(1) fourth subparagraph 

Article 4(1) fifth subparagraph 

Article 4(2) 

Article 4(3) 

Article 4(4) 

Article 4(5) 

Article 5(1) 

Article 5(2) 

Article 5(3) 

Article 5(4) 

Article 5(5) first subparagraph 

Article 16 

Article 4(4) 

Article 4(1) 

Article 6(3) 

Articles 6(3) (7)  

Articles 6(5) and 18(7) 

Article 7 

Articles 9(2) (5) 

Article 9(1) 

Article 9(2)(3)(6) 

Article 9(4) 

Article 8(1) 

Article 5(5) second subparagraph 

Articles 8(2) and 9(7) 

Article 6(1) first and second subparagraphs 

Article 11(1) 

Article 6(1) third subparagraph  

Article 9(2) fifth subparagraph 

Article 6(2) 

Article 11(2)(3)(6) 

74 

 
 
Article 6(3) 

Article 6(4) 

Article 6(5) 

Article 7(1) 

Article 7(2) 

Article 7(3) 

Article 7(4) 

Article 8(1) 

Article 8(2) 

Article 8(3) 

Article 9 

Article 10(1) 

Article 10(2) 

Article 11 

Article 12 

Article 13 

Article 14 

Article 15(1) 

Article 15(2) 

Article 15(3) and (4) 

Article 16 

Article 17 

Article 18 

Article 19 

Article 20 

Article 21 

Article 11 (3) 

Article 11(4) 

Article 11(5) 

Article 3(1)(a) 

Article 3(1)(b) 

Article 22 

Article 3(2) 

Article 12(1)(2) 

Article 12(4) 

Article 12(5) 

Articles 13 and 16 

Articles 14(1) and 15(1) (2) 

Article 15(2) 

Article 14(2) and (3) 

Article 18(1) to (5) 

Article 5(5) 

Article 5(6) 

Article 19(1) 

Article 19(2) 

Article 19(3) 

Article 22 

Article 23 

Article 23 

Article 23 

Article 21 

Article 20 

75 

 
Article 26 

Article 28 

Annex I 

Annex II 

Annex III 

Annex IV 

Annex V 

Annex VI 

Annex VII 

Article 22 

Article 23 

Annex I 

Annex II 

Annex III 

Annex IV 

Annex V 

Annex VI 

Annex VII 

New provisions in the Proposal: 

Article 4(2)(5)(6) 

Article 5(4)(7) 

Article 6(4)(8) 

Article 8(2)(3) 

Article 10 

Article 12(3) 

Article 15(3) 

Article 17 

Article 18(6) 

Article 27 

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