COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the document Proposal for a Regulation of the European Parliament and of the Council on the statute and funding of European political parties and European political foundations (recast)
Date: 2021-11-25
Institutions: European Commission, Secretariat-General
Subjects: EU financing, European legal status, European party, foundation, freedom of association, freedom of expression, party financing

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 25.11.2021  SWD(2021) 359 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT REPORT  Accompanying the document Proposal for a Regulation of the European Parliament and of the Council on the statute and funding of European political parties and European political foundations (recast) {COM(2021) 734 final} - {SEC(2021) 577 final} - {SWD(2021) 360 final}  
 
 
Table of Contents 
LIST OF ABBREVIATIONS ....................................................................................................................... 3 

LIST OF REGISTERED EUROPEAN POLITICAL PARTIES AND THEIR AFFILIATED 
FOUNDATIONS .......................................................................................................................................... 4 

FOREWORD ................................................................................................................................................ 5 

1. BACKGROUND AND POLICY CONTEXT .......................................................................................... 6 

1.1. Policy and legal context ..................................................................................................................... 6 

1.2. Current challenge ............................................................................................................................. 10 

1.3. Procedural issues and consultation of interested parties .................................................................. 11 

2.  PROBLEM DEFINITION .................................................................................................................. 13 

2.1. The problems that require action ..................................................................................................... 14 

2.2. 

Problem drivers ........................................................................................................................... 21 

2.3. Who is affected by the identified problems and in what ways? ....................................................... 25 

3. WHY SHOULD THE EU ACT? ............................................................................................................ 29 

3.1. Legal basis ....................................................................................................................................... 29 

4. OBJECTIVES ......................................................................................................................................... 30 

4.1. General policy objectives ................................................................................................................. 30 

4.2. Specific policy objectives ................................................................................................................ 31 

4.3. Consistency with other EU policies and with the Charter of Fundamental Rights of the European 
Union ...................................................................................................................................................... 34 

4.3.1. European Democracy Action Plan ............................................................................................ 34 

4.3.2. Conference on the Future of Europe and European Electoral Act ............................................ 34 

4.3.3. Commission’s Gender Equality Strategy 2020-2025 ................................................................ 35 

4.3.4. Charter of Fundamental Rights of the European Union ............................................................ 35 

5. POLICY OPTIONS ................................................................................................................................ 36 

5.1. Baseline scenario ............................................................................................................................. 36 

5.2. Options for further in-depth assessment .......................................................................................... 38 

6. ANALYSIS OF FEASIBILITY AND IMPACTS OF THE POLICY OPTIONS .................................. 39 

6.1. Impacts of policy option 2 ............................................................................................................... 40 

6.2. Impacts of policy option 3 ............................................................................................................... 43 

7. COMPARISON OF THE POLICY OPTION PACKAGES AND PREFERRED OPTION .................. 50 

7.1. Overview .......................................................................................................................................... 50 

7.2. Preferred option ............................................................................................................................... 52 

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8. MONITORING AND EVALUATION .................................................................................................. 53 

Annex I: Procedural Information ................................................................................................................ 55 

LEAD DG, DECIDE PLANNING/CWP REFERENCES ..................................................................... 55 

ORGANISATION AND TIMING ......................................................................................................... 55 

CONSULTATION OF THE RSB .......................................................................................................... 55 

Annex II: Stakeholders’ Consultation ......................................................................................................... 59 

CONSULTATION STRATEGY ............................................................................................................ 59 

INFORMAL CONSULTATION WITH STAKEHOLDERS ................................................................ 59 

FEEDBACK TO ROADMAP/INCEPTION IMPACT ASSESSMENT............................................ 60 

OPEN PUBLIC CONSULTATION ....................................................................................................... 61 

Annex III: Who is affected by the initiative and how? ............................................................................... 74 

Annex IV: Description of the analytical methods used .............................................................................. 76 

Annex V: Bibliography ............................................................................................................................... 77 

2 

 
 
 
 
LIST OF ABBREVIATIONS 

AFCO 

APPF 

BUDG 

CoFE 

ECA 

EDAP 

EPRS 

EU 

EUCJ 

EUPF 

EUPP 

European Parliament Committee on Constitutional Affairs 

Authority for European political parties and foundations 

European Parliament Committee on Budgetary Control 

Conference on the Future of Europe 

European Court of Auditors 

European Democracy Action Plan 

European Parliament Research Service 

European Union 

European Union Court of Justice 

European political foundation 

European political party 

EUPP/F 

European political parties and foundations 

EUPP/F 
Regulation  

Regulation 1141/2014 on the statute and funding of European political parties 
and European political foundations 

INGE 

GAG 

NGO 

European Parliament Special Committee for foreign interference in all 
democratic processes in the EU, including disinformation 

Council Working Party of General Affairs 

Non-governmental organisation 

OSCE/ODIHR  Office for Democratic Institutions and Human Rights of the Organisation for 

Security and Co-operation in Europe 

REPRESENT  Research Centre for the Study of Parties and Democracy 

TEU 

TFEU 

Treaty on the European Union 

Treaty on the Functioning of the European Union 

3 

 
 
 
 
 
 
 
 
 
LIST OF REGISTERED EUROPEAN POLITICAL PARTIES AND THEIR AFFILIATED 
FOUNDATIONS 

European People’s Party (EPP) 

Wilfried Martens Centre for European Studies 

Party of European Socialists (PES) 

Foundation for European Progressive Studies (FEPS) 

Alliance for Liberals and Democrats 
for Europe Party (ALDE) 

European Liberal Forum (ELF) 

European Democratic Party (EDP) 

Institute of European Democrats (IED) 

European Free Alliance (EFA) 

Coppieters Foundation 

European Green Party (EGP) 

Green European Foundation (GEF) 

Identité et Démocratie Parti (ID) 

Identité et Démocratie Fondation 

European Christian Political 
Movement (ECPM) 

European Conservatives and 
Reformists Party (ECR) 

Sallux – ECPM Foundation 

New Direction – The Foundation for European Reform 

Party of the European Left (PEL) 

Transform Europe 

4 

 
 
 
 
FOREWORD 

The present impact assessment supports the revision of Regulation No 1141/2014 on the statute 
and funding of European political parties and European political foundations pursuant to Article 
38 of the Regulation  (evaluation  clause).  Due to  the specificities of the Regulation, the impact 
assessment has a number of limitations. 

First and foremost, the Regulation is very young (adopted in 2014 but in force only since 2017) 
and  has  only  been  applied  at  one  election  to  the  European  Parliament  in  2019.  Therefore, 
evidence on its way of functioning is limited. Some of its provisions, namely on sanctions and 
the  verification  mechanism  for  compliance  with  EU  values,  have  never  been  applied.  In  these 
cases, the impact assessment drew on feedback from stakeholders (European political parties and 
foundations, the European Parliament’s Authorising Officer, the Authority for European political 
parties and foundations, international organisations) to propose changes to the current rules. The 
impact assessment also  draws on two external studies on the evaluation  of the current EUPP/F 
Regulation and the possible impacts of its revision. 

In  addition,  the  Regulation  applies  to  a  very  limited  number  of  actors:  20  European  political 
parties  and  foundations  in  the  entire  EU,  the  Authority  for  European  political  parties  and 
foundations  and  the  European  Parliament’s  Authorising  Officer.  Therefore,  the  revision  of  the 
Regulation  is  not  expected  to  have  the  impacts  usually  analysed  in  most  impact  assessments: 
environmental, economic and social impacts. The working assumption in the impact assessment 
is  that  most  of  its  impacts  will  be  observed  in  the  area  of  fundamental  rights  and  democracy. 
Also, given the limited number of actors, the causal links between modifications in the regulation 
and impacts are assessed qualitatively rather than quantitatively. 

5 

 
 
1. BACKGROUND AND POLICY CONTEXT 

1.1. Policy and legal context 

European political parties (hereinafter, EUPPs) are transnational party alliances whose objective 
is to ‘contribute to forming European political awareness and express the will of citizens in the 
Union’1.  

The first EUPPs were formed between 1974 and 1976 in the run-up to the first direct elections to 
the European Parliament. They were first  legally recognised in  the Treaty  of Maastricht, but  it 
was  the  Treaty  of  Nice  that  allowed  for  the  regulation  of  their  governance  and  financing2. 
Consequently,  Regulation  2004/20033  defined  the  conditions  for  recognising  EUPPs  and  laid 
down  the  rules  governing  their  funding  from  the  EU  budget.  They  thus  gained  their  financial 
independence from political groups in the European Parliament4. Regulation No 2004/2003 was 
amended in 2007 allowing EUPPs to use some of their finances for campaigning in the run-up to 
the elections to the European Parliament. The 2007 amendment also extended the Regulation’s 
scope to European political foundations (hereinafter, EUPFs), which are think tanks affiliated to 
EUPPs. 

In 2011, the European Parliament  evaluated Regulation  No 2004/2003  and identified  room for 
improvement  regarding  internal  party  democracy  and  conditions  for  access  to  funding.  The 
Commission came forward with a legislative proposal in 2012 whose objective was ‘to increase 
the  visibility  and  recognition,  efficiency,  transparency  and  accountability  of  European  political 
parties and foundations’5. 

Regulation No 1141/2014 on the statute and funding of European political parties and European 
political  foundations6  (hereinafter,  EUPP/F  Regulation)  was  adopted  in  2014  and  entered  into 
force  on  1  January  2017.  Funding  under  the  EUPP/F  Regulation  commenced  for  activities 
starting  from  the  2018  financial  year.  It  established  a  European  legal  personality  for  European 
political parties and foundations (hereinafter EUPP/F), defined the criteria for their registration 

1 Article 10(4) TEU 

2 Article 191(2) of the Treaty of Nice. 

3  Regulation  (EC)  No  2004/2003  of  the  European  Parliament  and  of  the  Council  of  4  November  2003  on  the 
regulations governing political parties at European level and the rules regarding their funding, OJ L 297, 15.11.2003. 
Available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32003R2004 

4 Until then, political groups channeled their appropriations to EUPPs who also relied on them for human resources 
and office space. This practice was criticised by the European Court of Auditors, Special report No 13/2000 on the 
expenditure  of  the  European  Parliament's  political  groups.  OJ  C  181,  28.06.2000.  Available  at:  https://eur-
lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:C:2000:181:0001:0016:EN:PDF  

5 Proposal for a Regulation of the European Parliament and of the Council on the statute and funding of European 
political parties and European political foundations,  COM(2012)499 final of 12.09.2012.  Available at:  https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52012PC0499&qid=1627213933830  

6 Regulation (EU, Euratom) No 1141/2014 of the European Parliament and of the Council of 22 October 2014 on 
the  statute  and  funding  of  European  political  parties  and  European  political  foundations,  OJ  L  317,  4.11.2014. 
Available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014R1141  

6 

 
 
                                                           
and  set  out  rules  for  their  governance.  It  also  created  an  independent  oversight  body,  the 
Authority  for  European  political  parties  and  foundations  (hereinafter,  APPF),  and  strengthened 
the control mechanisms. Simultaneously, specific provisions on contributions from the budget to 
European  political  parties  were  introduced  in  the  Financial  Regulation  by  Regulation  No 
1142/20147. These provisions are now found in 221 to 232 of the Financial Regulation8. 

The  EUPP/F  Regulation  was  amended  twice  in  order  to  address,  in  the  run-up  to  the  2019 
elections to the European Parliament, its most critical loopholes by a limited number of targeted 
amendments: 

  The first of these amendments9, following a request by the European Parliament, aimed at 
increasing the transparency of the links between European and national political parties, 
and  tightened  the  conditions  for  registration  as  a  European  political  party,  rendering  it 
contingent  upon  the  applicant  being  supported  by  seven  national  political  parties  from 
seven different Member States. Therefore, unlike in the past, individual parliamentarians 
could  no  longer  support  an  application  for  registration.  As  a  result  of  this,  in  2018  the 
APPF deregistered two EUPPs10 and one affiliated EUPF11, because they did not provide 
proof that they satisfied the tightened minimum representation requirements. 

  The second amendment12 was triggered by the ‘Facebook/Cambridge Analytica’ case and 
was adopted in the framework of the Commission’s 2018 European elections package13 

7  Regulation  (EU,  Euratom)  No  1142/2014  of  the  European  Parliament  and  of  the  Council  of  22  October  2014 
amending Regulation (EU, Euratom) No 966/2012 as regards the financing of European political parties (OJ L 317, 
4.11.2014, p. 28). 

8  Regulation  (EU,  Euratom)  2018/1046  of  the  European  Parliament  and  of  the  Council  of  18  July  2018  on  the 
financial rules applicable to the general budget of the Union, amending Regulations (EU) No 1296/2013, (EU) No 
1301/2013, (EU) No 1303/2013, (EU) No 1304/2013, (EU) No 1309/2013, (EU) No 1316/2013, (EU) No 223/2014, 
(EU)  No  283/2014,  and  Decision  No  541/2014/EU  and  repealing  Regulation  (EU,  Euratom)  No  966/2012  (OJ  L 
193, 30.07.2018, p.1). 

9  Regulation  (EU,  Euratom)  2018/673  of  the  European  Parliament  and  of  the  Council  of  3  May  2018  amending 
Regulation  (EU,  Euratom)  No  1141/2014  on  the  statute  and  funding  of  European  political  parties  and  European 
political 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=celex:32018R0673 

foundations, 

Available 

4.5.2018. 

114I, 

OJ 

at: 

L 

10  Decision  of  the  Authority  for  European  Political  Parties  and  European  Political  Foundations  of  13  September 
2018 to remove Alliance for Peace and Freedom from the Register, OJ C 417, 16.11.2018. Available at: https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.C_.2018.417.01.0011.01.ENG&toc=OJ:C:2018:417:TOC 

Decision of the Authority for European Political Parties and European Political Foundations of 29 August 2018 to 
remove  Alliance  of  European  National  Movements  from  the  Register,  OJ  C  417,  16.11.2018.  Available  at: 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.C_.2018.417.01.0009.01.ENG&toc=OJ:C:2018:417:TOC 

11  Decision  of  the  Authority  for  European  Political  Parties  and  European  Political  Foundations  of  13  September 
2018  to  remove  Europa  Terra  Nostra  from  the  Register,  OJ  C  418,  19.11.2018.  Available  at:  https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.C_.2018.418.01.0004.01.ENG&toc=OJ:C:2018:418:TOC  

12 Amending Regulation (EU, Euratom) 2019/493 of the European Parliament and of the Council of 25 March 2019 
amending Regulation (EU, Euratom) No 1141/2014 as regards a verification procedure related to infringements of 
rules on the protection of personal data in the context of elections to the European Parliament, OJ L 85I , 27.3.2019. 
Available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32019R0493. 

7 

 
 
                                                           
aimed  at  securing  free  and  fair  elections.  The  amendment  introduced  a  verification 
procedure  aimed  at  imposing  sanctions  on  EUPP/Fs  that  deliberately  influence,  or 
attempt  to  influence,  the  outcome  of  elections  to  the  European  Parliament  by  taking 
advantage of data protection breaches. This amendment also granted the APPF additional 
resources and enhanced its independence. 

These  amendments  were  adopted  through  the  ordinary  legislative  procedure  in  a  record  time, 
since the provisions had to  be in  place in  time for the  elections to  the European Parliament of 
May 2019.  

In July 2019, President von der Leyen announced a new European Democracy Action Plan in her 
Political  Guidelines14  ,  to  address  challenges  to  democracy,  including  increasing  threats  of 
external  interference  in  European  elections.  The  action  plan,  adopted  on  3  December  2020, 
announced  inter  alia  a  legislative  proposal  to  ensure  greater  transparency  on  paid  political 
advertising and the review of the legislation on the financing of European political parties. The 
two initiatives are planned for adoption in the Commission’s Work Programme for 2021 before 
the  end  of  202115.  The  initiative  on  paid  political  advertising  complement  the  revision  of  the 
EUPP/F Regulation by providing for specific requirements for EUPPs to use political ads and a 
review  process  for  the  Authority  to  take  note  of  breaches  of  the  rules  visible  on  the  basis  of 
EUPP disclosures. 

The  European  Parliament’s  resolution  on  stocktaking  of  European  elections16  also  proposed  to 
amend  the  EUPP/F  Regulation  in  order  to  allow  EUPP/F  to  fully  participate  in  the  European 
political  space,  to  campaign,  to  be  able  to  use  campaign  funds  and  stand  in  elections  to  the 
European  Parliament,  to  increase  the  transparency  of  their  funding  (especially  as  regards  the 
management of funds from the EU budget and when funding comes from member parties), and 
to  prohibit  donations  from  private  and  public  bodies  from  non-EU  Member  States.  It  stressed, 
nonetheless, that, with a view to fostering pan-European political bonds, membership fees from 
political  parties  located  in  countries  belonging  to  the  Council  of  Europe  could  be  allowed 
provided that this takes place within a framework of enhanced transparency. 

13 
https://ec.europa.eu/commission/presscorner/detail/en/IP_18_5681 

Content 

2018 

the 

of 

electoral 

package 

available 

at: 

14  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and 
Social  Committee  and  the  Committee  of  the  Regions  on  the  European  Democracy  Action  Plan,  COM/2020/790 
final. 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A790%3AFIN&qid=1607079662423 

Available 

at: 

15 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee and THE Committee of the Regions Commission Work Programme 2021 A Union of vitality in a 
world of fragility, COM/2020/690 final. Available with its annexes at: https://ec.europa.eu/info/publications/2021-
commission-work-programme-key-documents_en  

16  European  Parliament’s  Resolution  A9-0211/2020  on  stocktaking  of  European  elections  (rapporteur  P.  Durand). 
Available at: https://www.europarl.europa.eu/doceo/document/A-9-2020-0211_EN.html  

8 

 
 
                                                                                                                                                                                           
Pursuant to Article 38 of the EUPP/F Regulation, its application shall be evaluated in 2021. The 
revision clause calls on the European Parliament to publish its evaluation by 31 December 2021 
and, no more than six months after the publication of that report, the Commission has to present 
a follow-up report, which may be accompanied by a legislative proposal to amend it.  

The European Parliament’s Committee on Constitutional Affairs (hereinafter, AFCO) is working 
on  its  own-initiative  report  pursuant  to  Article  38  of  the  EUPP/F  Regulation.  The  draft  report, 
which  is  currently  planned  for  adoption  during  the  second  plenary  session  of  October  2021, 
points  out  the  remaining  legal  obstacles  that  may  be  preventing  EUPP/Fs  from  achieving  their 
full potential as active players in the European democracy. The draft report calls, inter alia, for:  

  distribution of funding based on the number of votes obtained during the latest elections 
to  the  European  Parliament,  as  opposed  to  the  number  of  seats  obtained  as  a  result  of 
those same elections;  

 

 

lowering of the co-financing threshold for EUPP from the current 10% to 5%;  

recognition of different kinds of membership for EUPPs (e.g., associate membership with 
political parties located in accession and neighboring countries, as well as in former EU 
Member States); 

  simplification  of  the  current  double  accounting  system,  which  is  widely  considered  as 

being too burdensome.  

On 12 July 202, the European Parliament Committee on Budgetary Control (hereinafter, CONT) 
adopted an opinion to the AFCO report, in which: 

  calls for the transparency of funding and insists that funding should exclusively support 

political activities in line with Article 2 TEU; 

  sees  the  possibility  for  improvements,  particularly  regarding  the  level  of  detail  and 
comparability  of  the  requested  information  on  EUPP  activities  in  campaigns  to  the 
elections to the European Parliament; 

  suggests reducing the required own resources for EUPP to 5% of the eligible expenditure; 

  calls on the Commission to clearly define the requirements related to the visibility of the 

affiliation of national political parties to EUPP.  

This  impact  assessment  supports the legislative  proposal  that the Commission  intends to  adopt 
pursuant to Article 38 of the EUPP/F Regulation and to the Commission’s political priorities. It 
draws  on  the  outcome  of  the  informal  consultations  that  the  Commission  carried  out  with  the 
main  stakeholders,  the  outcome  of  the  open  public  consultations  on  the  European  Democracy 
Action  Plan  and  on  the  revision  of  the  EUPP/F  Regulation,  and  two  external  studies  on  the 
evaluation of the current EUPP/F Regulation and the possible impacts of its revision. 

AFCO  is  also  working  on  a  separate  legislative  own  initiative  report  on  the  reform  of  the 
European  electoral  law.  Mr  Ruíz  Devesa’s  (S&D/ES)  draft  report  of  1  July  2021  proposes  the 

9 

 
 
introduction  of  an  EU-wide  constituency  in  which  lists  would  be  headed  by  each  political 
family’s  candidate  for  the  position  of  President  of  the  Commission.  The  draft  report  also 
suggests including ‘common provisions governing expenditure linked to the electoral campaign 
for the elections to the European Parliament for each entity admitted for the purpose of tabling a 
list  of  candidates  for  members  of  the  European  Parliament  in  the  EU-wide  constituency’.  It 
therefore  calls  for  strong  coordination  with  the  upcoming  revision  of  the  EUPP/F  Regulation. 
However, the scope of AFCO’s report is broader and its adoption has been postponed to 2022 in 
order to accommodate the outcome of the Conference on the Future of Europe. Bearing this in 
mind, the revision of the EUPP/F regulation should remain neutral and accommodate any of the 
possible  outcome  of  the  Conference,  notably  as  regards  the  possibility  of  introducing  a  lead 
candidate system or transnational lists.  

1.2. Current challenge  

One of the Commission’s six headline ambitions is ‘A new push for European democracy’. This 
implies fostering the European dimension of European elections and increasing the link between 
citizens and European decision-making processes.  

Increasing  citizens’  turnout  at  the  elections  to  the  European  Parliament  remains  a  challenge. 
Currently, 55% of Europeans ‘totally agree’ that ‘the voice of EU citizens should be more taken 
into account for decisions relating to the future of Europe’. Way above all other items, ‘voting in 
European  elections’  is  seen  as  the  main  way  of  making  sure  one’s  voice  is  heard  by  decision-
makers  at  EU  level.  While  the,  turnout  was  50.6%  of  EU  citizens  in  2019,  which  represents  a 
sharp  increase  compared  to  the  42.6%  turnout  in  2014,  it  remains  lower  than  at  national 
elections17  and  far  from  participation  levels  seen  before  1999.  It  is  expected  that  a  greater 
visibility and activity of EUPPs would contribute to foster citizens’ participation in the election 
to the European parliament. 

EUPP/F should play an important role in increasing European citizens’ involvement in European 
politics. According to International IDEA18, however, they face a specific challenge in achieving 
this objective because European institutional and electoral frameworks do not provide the same 
structure and tools for EUPP as their national counterparts are used to working with, and which 
enable  national  parties  to  attract  the  attention  and  interest  of  citizens  or  to  be  featured  in  the 
media.  Any  possible  revision  of  the  EUPP/Fs  Regulation  should  take  this  specificity  into 
account. 

The  Commission’s  report  on  the  2019  elections  to  the  European  Parliament19  points  to  the 
multiple  challenges  faced  by  the  European  democracy,  not  only  from  within  the  EU  but  also 

17  Special  Eurobarometer 
https://www.europarl.europa.eu/at-your-service/files/be-heard/eurobarometer/2021/future-of-europe-2021/en-key-
findings.pdf 

(October-November 

2020).  Available 

500,  Future 

of  Europe 

at: 

18 Van Hecke S. at al., (2018), Reconnecting European Political Parties with European Union Citizens, International 
IDEA  Discussion  paper  6/2018.  https://www.idea.int/sites/default/files/publications/reconnecting-european-
political-parties-with-european-union-citizens.pdf  

19  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and 
Social  Committee  and  the  Committee  of  the  Regions,  Report  on  the  2019  elections  to  the  European  Parliament, 

10 

 
 
                                                           
 
from  outside,  such  as  rising  extremism,  election  interference,  the  spread  of  manipulative 
information and threats against journalists.  

Foreign interference has become a major security  challenge for democracies. The EU provides 
no  exception  and,  in  the  last  few  years,  has  significantly  stepped  up  its  efforts  to  counter  this 
threat.  A  specific  type  of  foreign  interference  is  the  foreign  funding  of  political  parties,  be  it 
national or European. At the national level, regulations banning or limiting foreign funding are 
currently in place in most Member States, but there is still significant variation across them20. At 
EU level, the recent reforms of the EUPP/F Regulation have banned contributions from abroad. 
Notwithstanding such changes to political parties’ regulations, cases of foreign funding are still 
being reported in several Member States, with foreign actors exploiting regulatory loopholes to 
channel  funds  or  provide  other  types  of  support21.  Furthermore,  the  European  Parliament’s 
resolution on stocktaking of European elections22 highlighted the need to strengthen some of the 
rules  applicable  to  the  EUPP/F  in  order  to  prevent  external  interference,  in  particular  by 
improving transparency as regards sources of funding for EUPP so as to tackle indirect funding 
by foreign interests channeled through national means or private donations. This challenge will 
have  to  be  taken  into  consideration  when  assessing  the  possibilities  for  allowing  membership 
fees from member parties located in non-EU countries.  

1.3. Procedural issues and consultation of interested parties  

From the outset, the Commission aimed at a very inclusive approach, identifying and consulting 
the main stakeholders throughout the preparation of its legislative proposal23. 

Between November 2020 and June 2021, the Commission reached out to all EUPP/Fs, as well as 
to the APPF and the European Parliament’s Authorising Officer for an initial, informal exchange 
of  views.  During  the  same  period,  the  Commission  also  engaged  in  a  wide  ranging  outreach 
exercise  with  the  co-legislators,  notably  through  the  Member  States’  representatives  in  the 
Council  Working  Party  on  General  Affairs  (hereinafter,  GAG)  and  AFCO  Members  and 
coordinators of political groups in the Parliament.  

The Commission also met with a number of experts, such as the representatives of the Office for 
Democratic Institutions and Human Rights of the Organisation for Security and Co-operation in 
Europe  (hereinafter,  OSCE/ODIHR),  the  Research  Centre  for  the  Study  of  Parties  and 
Democracy  (hereinafter,  REPRESENT)  and  the  European  Democracy  Consulting,  for  a 

COM(2020)252. 
content/EN/TXT/?uri=CELEX%3A52020DC0252&qid=1627216994733   

Available 

at: 

https://eur-lex.europa.eu/legal-

20  Bressanelli,  E.  (2021),  Investing  in  destabilisation:  How  foreign  money  is  used  to undermine democracy in the 
EU, 
https://www.europarl.europa.eu/meetdocs/2014_2019/plmrep/COMMITTEES/INGE/DV/2021/06-
22/Investingindestabilisation_EXPO_STU2021653631_EN.pdf    

21 INGE Working document on covert funding of political activities by foreign donors of 22 April 2021 (rapporteur 
Sandra Kalniete). Available at: https://www.europarl.europa.eu/doceo/document/INGE-DT-689654_EN.pdf  

22 Idem footnote 14. 

23 For details, see Consultation Strategy in Annex II. 

11 

 
 
                                                                                                                                                                                           
discussion  on  the  revision  of  the  EUPP/F  Regulation  and  the  Commission’s  initiative  on  the 
transparency of paid political advertising.  

The  roadmap/inception  impact  assessment  on  the  revision  of  the  EUPP/F  Regulation  was 
published for comments between 17 March and 14 April 2021, and public consultation was open 
for feedback between 30 March and 22 June 2021.  

In  that  framework,  21  replies  were  received,  19  online  and  two  by  email,  from  14  Member 
States.  Of  the  19  online  respondents,  seven  were  EU  citizens,  six  were  non-governmental 
organisations (hereinafter, NGO), one was a representative of a national authority in a Member 
State, one represented a research organization, one represented a company and three represented 
other organisations. The two replies received by email were submitted by a Member State and an 
NGO. While the consultation received limited number of replies, 62.5% of the respondents found 
the  EUPP/F  Regulation  either  useful  or  very  useful.  Almost  half  of  the  respondents  (47.4%) 
believed that EUPP do not fulfil their role in representing European citizens, and almost 80% of 
the respondents considered that EUPP lacked visibility for European citizens.  

In  addition,  the  Commission  also  drew  on  the  feedback  received,  between  15  July  and  15 
September  2020,  to  the  open  public  consultation  on  the  European  Democracy  Action  Plan 
(hereinafter,  EDAP)  that  showed  broad  support  to  the  scope  of  the  revision  of  the  EUPP/F 
Regulation.  

The full analysis of the feedback received via these three channels can be found in Annex II. 

12 

 
 
 
 
 
2.  PROBLEM DEFINITION  

 Based on the informal consultations with relevant stakeholders, the open public consultation and 
the  analysis  of  the  application  of  the  EUPP/F  Regulation,  the  Commission  could  identify  a 
number of shortcomings in the current regime. These shortcomings are linked to a) the funding 
of  EUPP/F  and  b)  EU  values,  democracy  and  transparency,  and  c)  enforcement  and 
administrative burden. The Commission considers that the problems identified under the funding 
provisions of the Regulation are the most pertinent  in  the Regulation’s underperformance. The 
remaining  loopholes  in  the  financial  provisions,  undermine  EUPP/Fs  financial  viability,  their 
ability  to  fulfill  their  constitutional  mission,  and  allow  increased  risk  of  potential  foreign 
interference and weak financial management. 

Figure 1 – Identified problems and their drivers 

13 

 
 
Problems

Funding provisions

- EUPP/F's limited capacity to 
autofinance

- Remaining risk of interference via 
donations

- Impossibility of EUPP/F to accept 
membership fees from members from 
non-EU countries

EU values, democracy and 
transparency

- Inability to fulfil EUPP/F’s mission to 
shape the European political space

-Lack of gender balance in European 
politics

-Missing guarantees for the respect of EU 
values by EUPP/Fs

Enforcement and administrative 
burden

- Authority not sufficiently equipped to 
fulfil its potential

-Excessive administrative burden

- Perceived legal uncertainty

- EU's financial interests not sufficiently 
safeguarded

Problem drivers

Regulatory 
failure

Funding provisions

- Simplistic categorisation of types of 
revenues

- Loopholes in transparency regime for 
donations

- Restrictive financial rules

EU values, democracy and 
transparency

- Lack of visibility for EUPP/Fs at national level 

- EUPPs' limited role at national level

- Regulation doesn't actively promote gender 
balance

- Non-operational verification mechanism for 
EU values

Enforcement and administrative 
burden
- Lack of investigative powers for APPF

- Rigidity of the sanctions regime

- Lack of resources for APPF

- Double accounting requirement

- Unclear division of responsibilities between APPF and EP 
Authorising Officer

- Unclear rules on eligibility during deregistration

2.1. The problems that require action 

14 

 
 
 
 
a)  Funding provisions 

i) 

Article 17(4) of the EUPP/F Regulation establishes a ceiling for public funding for EUPP 
at  90%  of  their  total  eligible  expenditure.  For  EUPF,  this  ceiling  is  set  at  95%  of  their 
total  eligible  expenditure24.  This  means  that  EUPP/F  have  to  secure,  respectively,  10% 
and 5% of their expenditure from own resources. 

EUPP have been entitled to annual  funding from the EU budget since 2004, and EUPF 
since 2007. The total amount of EU funding for EUPP/F has significantly increased over 
time. While EUPP benefited from EUR 6.5 million of EU funding in 2004, this amount 
rose  to  EUR  46  million  in  2021,  with  a  peak  in  the  2019  election  year  when  EUR  50 
million was earmarked for them. At the same time, EU funding for EUPF increased from 
EUR 5 million in 2008 to EUR 23 million in 2021. 

Figure 2 – Level of EU funding for European political parties and foundations 

Source: European Parliament Research Service 

If EUPP/F do not manage to collect the matching own resources, their EU funding would 
be lowered until it corresponds to 90% and 95% of the total expenditure, respectively. 

This  means  that,  if  EUPP/F  wanted  to  benefit  from  the  increased  budgetary  resources, 
they  would  have  to  secure  more  own  resources  over  the  years,  in  absolute  terms.  This, 
however, has proven problematic not  only  for smaller political  parties and foundations, 
but even for the larger ones (see Figure 3 below)25. 

24 Before the 2018 amendment of the EUPP/F Regulation, the ceiling for both EUPP and EUPF was set at 85% of 
their total eligible expenditure. 

25  I.  Anglmayer  (2021),  Statute  and  funding  of  European  political  parties  under  Regulation  1141/2014    -ex  post 
at: 
evaluation, 
https://www.europarl.europa.eu/RegData/etudes/STUD/2021/662646/EPRS_STU(2021)662646_EN.pdf  

Available 

p.10. 

15 

 
 
 
 
 
                                                           
Figure 3 – Maximum eligible contribution and final contribution to EUPPs from the 
EU budget per year 

s
n
o

i
l
l
i

M

€ 16 

€ 14 

€ 12 

€ 10 

€ 8 

€ 6 

€ 4 

€ 2 

€ -

EPP

PES

ALDE

EGP

PEL

EDP

EFA

ECPM

ECRP

IDP

Max. Contribution 2018

Final Contribution 2018 Max. Contribution 2019

Final Contribution 2019

Source: W. Wolfs, based on the reports of the Secretary-General of the European 
Parliament and Financial Overviews of the European Parliament’s DG FINS26 

The European Parliament’s study on the ex-post evaluation of the EUPP/F Regulation27 
argued  that  this  budgetary  pressure  had  led  to  ‘questionable  practices’  and  ‘creative 
solutions’  regarding  the  financial  management  of  these  organisations  and  pointed  to 
irregularities  identified  by  the  European  Parliament’s  Authorising  Officer  and  the 
European Court of Auditors28.  

ii) 

The  EUPP/F  Regulation  does  not  provide  enough  guarantees  against  unwanted  foreign 
interference  in  European  politics.  Foreign  actors  may  be  able  to  circumvent  the  current 
provisions  through  intermediaries  based  in  EU  Member  States,  using  funds  originating 
from non-EU Member States. For most EUPPs, donations only constitute a small share of 
own resources but, as shown in the graph below, the risk of foreign interference is real in 
case of those EUPPs that rely heavily on them.  

Figure 4 – Own resources structure of European political parties (2018-2019) 

26 Wolfs W. (2021), Impact assessment study – Revision of Regulation 1141/2014, unpublished. 

27 I. Anglmayer (2021), Statute and funding of European political parties under Regulation 1141/2014  -ex post 
evaluation. Available at: 
https://www.europarl.europa.eu/RegData/etudes/STUD/2021/662646/EPRS_STU(2021)662646_EN.pdf  

28 European Court of Auditors, Opinion 5/2017 concerning the proposal for a regulation of the European Parliament 
and of the Council amending Regulation (EU, Euratom) No 1141/2014 of the European Parliament and the Council 
of 22 October 2014 on the statute and funding of European political parties and European political foundations, para. 
11 and 12. Available at: https://www.eca.europa.eu/en/Pages/DocItem.aspx?did=44564  

16 

 
 
 
 
 
                                                           
100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

EPP

PES

ALDE

EGP

PEL

EDP

EFA

ECRP

ECPM IDP

Membership Fees

Donations

Contributions in kind

Other Income

Reserves used as revenue

Source: W. Wolfs, based on the financial reports of the European political parties and 
foundations29 

iii) 

Currently EUPP/Fs have members from outside the EU (see Annex VI for the list of non-
EU  countries  where  EUPP/F’s  members  come  from).  Until  the  entry  into  force  of  the 
EUPP/F  Regulation,  it  was  common  practice  for  non-EU  members  to  contribute 
membership fees to the revenues of European political parties. Under the current EUPP/F 
Regulation, and in order to safeguard against foreign interference, EUPP/F cannot accept 
membership  fees  from  their  member  parties  located  in  non-EU  Member  States.  This 
prohibition  was  confirmed  by  ruling  T-107/19  of  the  European  Union  Court  of  Justice 
(hereinafter,  EUCJ)  of  25  November  202030.  The  prohibition  under  the  current  regime, 
however, hinders the EUPP/F auto-financing capacity, especially in the light of the UK 
withdrawal  from  the  EU,  due  to  which  EUPP/F  have  lost  some  of  their  long-standing 
national affiliates. In addition to the financial problem it causes, EUPP/F argue that this 
prohibition  sends  the  wrong  political  message  both  to  their  previous,  pro-European 
members and to their members in candidate and neighbourhood countries.  

b)  EU values, democracy and transparency 

i) 

The mission of EUPP/F is to contribute to shaping a truly European political space, while 
Eurobarometer surveys consistently show a lack of European political awareness among 
citizens.  For  instance,  43%  of  EU  citizens  would  be  more  inclined  to  turn  out  on 

29 Wolfs W. (2021), Impact assessment study – Revision of Regulation 1141/2014, unpublished. 

30  Judgment  of  the  General  Court  of  25.11.2020,  Alliance  of  Conservatives  and  Reformists  in  Europe/European 
Parliament, 
at: 
https://curia.europa.eu/juris/document/document.jsf;jsessionid=D94B8C2205E30C3FDCC31F18436119E5?text=&
docid=234334&pageIndex=0&doclang=en&mode=lst&dir=&occ=first&part=1&cid=1694530  

EU:T:2020:560. 

T-107/19, 

Available 

17 

 
 
 
 
 
                                                           
election’s  day  if  they  were  better  informed  about  the  EU  and  its  impact  on  their  daily 
life31.  In  addition,  in  a  Eurobarometer  survey  following  the  2019  elections  to  the 
European  Parliament,  respondents  said  having  chosen  their  party  of  reference  almost 
equally based on the party’s proposals on European (43%) versus national (42%) issues. 
The other main reason for choosing a party was that the respondent always votes for them 
(40%)32. This indicates a need to strengthen the European dimension of the elections to 
the  European  Parliament  and  the  ability  of  EUPP/F  to  promote  European  political 
awareness. 

ii) 

The  Venice  Commission33  recommends  that  the  internal  functions  and  processes  of 
political  parties  should  generally  be  free  from  State  interference.  They  make 
recommendations  for  additional  actions  in  three  areas:  national  minorities,  people  with 
disabilities and gender.  

Article 3 of the EUPP/F Regulation, laying down the recommendations for registration, is 
already  aligned  with  the  recommendations  of  the  Venice  Commission  on  minorities. 
Concerning people with disabilities, there is a specific recommendation of the Council of 
Europe,  which  is  also  in  line  with  Article  21  of  the  current  Regulation,  on  non-
discrimination. Gender is the area where the Venice Commission goes the furthest in its 
recommendations,  referring  to  national  best  practices,  including  mandatory  gender 
quotas.  

The  European  Parliament,  in  its  report34  on  the  2012  Commission  proposal35  for  the 
EUPP/F  Regulation,  called  for  ensuring  gender  equality  in  the  composition  and  in  the 
formation of the European political parties and within their affiliated European political 
foundations while fully respecting internal party democracy. The European Parliament’s 
amendments,  however,  were  not  retained  during  the  interinstitutional  negotiations.  In 
2018  and  2019,  during  the  previous  two  revisions  of  the  EUPP/F  Regulation,  both 
Council and Parliament were reluctant to touch upon internal party democracy issues and 
could  only  agree  to  a  voluntary  measure  on  gender  equality  in  Recital  5,  which  has 
proven insufficient to ensure gender parity.  

Special 

31 
– 
https://ec.europa.eu/commfrontoffice/publicopinion/index.cfm/Survey/getSurveyDetail/search/477/surveyKy/2198  

Eurobarometer 

Democracy 

Elections.  

Available 

(2018) 

477 

and 

at: 

32  European  Parliament  Special  Eurobarometer  91.5.  Available  at:  https://www.europarl.europa.eu/at-your-
service/files/be-heard/eurobarometer/2019/post-election-survey-2019-complete-results/executive-summary/en-post-
election-survey-2019-executive-summary.pdf  

33 European Commission for Democracy through Law (Venice Commission) & OSCE Office for Democratic 
Institutions and Human Rights (2020), Guidelines on Political Party Regulation (2nd edition), paragraph 61. 
Available at: https://www.venice.coe.int/webforms/documents/default.aspx?pdffile=CDL-AD(2020)032-e 
34 Available at https://www.europarl.europa.eu/doceo/document/A-7-2013-0140_EN.pdf 
35 COM(2012) 499, available at https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52012PC0499&from=EN 

18 

 
 
                                                           
The World Economic Forum’s Global Gender Gap Report36 found that the gender gap in 
political empowerment remains globally the largest of the four gaps tracked37, with only 
22%  closed  to  date,  having  further  widened  since  the  2020  edition  of  the report  by  2.4 
percentage points. At the current rate of progress, the World Economic Forum estimates 
that  it  will  take  145.5  years  to  attain  gender  parity  in  politics.  While  there  has  been  a 
positive  trend  towards  gender  balance  in  the  composition  of  the  European  Parliament 
after the 2019 elections, there is still progress to be made in achieving gender parity. As 
of January 2021, the percentage of female Members of the European Parliament stood at 
38.9% compared to 16.6% in the first directly elected legislature in 197938. This is above 
the world average for national parliaments and above the European average for national 
parliaments,  which  stands  at  30.5%.  However,  the  European  Parliament’s  Research 
Service  (hereinafter,  EPRS)  points  to  large  differences  between  Member  States,  and 
identifies the low share of women among candidates as an underlying cause in countries 
with  a  low  proportion  of  female  Members  elected  to  the  European  Parliament.  This,  in 
turn,  may  be  due  to  internal  political  party  processes.  It  appears  that  EUPPs  missed  an 
opportunity  to  encourage  their  national  member  parties  to  promote  gender  balance  on 
party  lists39.  In  addition,  gender  parity  in  EUPP/F  governing  bodies  has  not  been 
achieved either. 

Figure 5 – Share of men and women in EUPP/F governing bodies 

European political parties

European political foundations

34,95%

65,05%

32,71%

67,29%

Men Women

Men Women

Source: W. Wolfs, based on Register of the Authority for European political parties  

36  World 
http://www3.weforum.org/docs/WEF_GGGR_2021.pdf  

Economic 

Forum 

(2021),  Global  Gender  Gap  Report 

2021.  Available 

at: 

37 The three other tracks being economic participation and opportunity, educational attainment, and health and 
survival. 

38  Shreeves  R.  with  Boland  N.  (2021),  Women  in  politics  in  the  EU  –  State  of  play.  Available  at: 
https://www.europarl.europa.eu/RegData/etudes/BRIE/2021/689345/EPRS_BRI(2021)689345_EN.pdf  

39 Only two of the six largest European political parties had mentioned gender equality in their election manifesto 
and none had called specifically for the adoption of gender quotas. 

19 

 
 
 
 
 
                                                           
and European political foundations40 

iii) 

i) 

ii) 

The EUPP/F Regulation’s mechanism to verify the EUPP/F compliance with EU values 
has  never  been  triggered  to  date.  However,  the  Commission’s  Annual  Rule  of  Law 
Report for 202041 identified serious challenges, cases where the resilience of rule of law 
safeguards is being tested and where shortcomings become more evident. This raises the 
question of whether or not the current mechanism is fit for purpose. 

c)  Enforcement and administrative burden 

The EUPP/F Regulation established, for the first time, an independent supervisory body, 
the APPF, in order to ensure an impartial oversight over the activities of EUPP/F. Due to 
various factors discussed in Section 2.2 of this impact assessment (see below), the APPF 
is currently not sufficiently equipped to fulfil its potential. 

The EUPP/F Regulation inflicts substantial administrative burden on EUPP/F, linked, on 
the one hand, to the use of the International Accounting Standards and, on the other hand, 
to  the  triple  verification  procedure  involving  the  external  auditor,  the  APPF  and  the 
Authorising Officer of the European Parliament. While significant variations exist across 
EUPP/F,  they  spend  around  1  260  h  (approximately  0.78  full  time  equivalent)  on  an 
annual basis on administrative tasks, with an additional EUR 20 000 spent on tasks that 
are outsourced. Out of these EUR 20 000, EUPP/Fs spend on average more than EUR 8 
00042  on  the  preparation  of  the  annual  financial  statements  in  accordance  with  the 
international accounting standards, which is usually an outsourced task. While this can be 
manageable  for  the  middle-sized  and  larger  EUPP/F  –  although  their  expenses  are  on 
average  also  higher  because  of  their  larger  size  –  it  puts  a  particular  strain  on  the 
functioning of the smaller ones. With regard to triple verification process of the accounts, 
the examination of the financial reports by both the APPF and the Authorising Officer of 
the European Parliament (in addition  to the assessment  of the external  auditor) leads to 
the  double  spending  of  EU  taxpayers’  money.  In  addition,  the  APPF  and  the  European 
Parliament’s  Authorising  Officer  have  sometimes  applied  a  diverging  interpretation  of 
the rules, leading to an increased workload and legal uncertainty for the EUPP/F43. 

iii) 

Throughout  the  consultation  process,  EUPP/Fs  signalled  a  perceived  legal  uncertainty 
due to the unclear division of responsibilities between the APPF, on the one hand, and the 
European Parliament’s Authorising Officer, on the other.  

40 Wolfs W. (2021), Impact assessment study – Revision of Regulation 1141/2014, unpublished. 

41 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee and the Committee of the Regions, 2020 Rule of Law Report - The rule of law situation in the 
European Union, COM/2020/580 final. Available at: https://eur-lex.europa.eu/legal-
content/EN/TXT/?qid=1602583951529&uri=CELEX%3A52020DC0580 
42 Wolfs W. (2021), Impact assessment study – Revision of Regulation 1141/2014, p. 5, unpublished. 

43 Based on data received from European political parties and foundations for the external impact assessment study 
conducted by W. Wolfs, Katholieke Universiteit of Leuven, in June 2021. 

20 

 
 
 
                                                           
iv) 

At  the  informal  consultations  conducted  by  the  Commission,  both  the  APPF  and  the 
European  Parliament’s  Authorising  Officer  indicated  that  the  protection  of  financial 
interests of the EU was not sufficiently ensured in case of the deregistration of an EUPP 
or EUPF. 

2.2.  Problem drivers  

The above identified problems derive from a regulatory failure, i.e. the existing Regulation has 
failed  to  achieve  its  objectives  (which  remain  valid)  and  has  proven  needlessly  costly.  The 
specific  problem  drivers  can  be  grouped  up  according  to  a)  funding  provisions,  b)  EU  values, 
democracy and transparency and c) enforcement and administrative burden. 

a) Funding provisions 

i)  The reasons for EUPP/F’s difficulty raising own resources are twofold:  

  The  EUPP/F  Regulation  acknowledges  only  two  categories  of  revenues;  namely, 
contributions  and  donations.  This  means  that  everything  which  is  not  a  membership 
contributions  is  considered  as  a  donation,  which  are  subject  to  a  very  stringent  legal 
regime.  EUPP/F  argue  that  this  categorisation  is  too  simplistic  and  excludes  the 
possibility  to  raise  own  resources  from  other  sources  such  as  sponsorship,  publication 
fees, participation fees, sales, etc. The draft report prepared by AFCO also underlines that 
the categories of revenue are defined too narrowly in the EUPP/F Regulation44.  

  At the same time, the EUPP/F Regulation does not allow for contributions and donations 
coming  from  countries  outside  the  EU.  This  has  particular  consequences  following  the 
UK withdrawal from the EU, as EUPP/F could not continue collecting membership fees 
from some of their traditional members45. 

ii)  The EUPP/F Regulation contains some loopholes in its transparency regime for donations. Its 
Article  20  prohibits  certain  types  of  donations  (namely,  donations  from  non-EU  countries, 
anonymous  donations,  donations  exceeding  EUR  18  000).  However,  these  prohibitions  are 
not  accompanied  by  corresponding  enforcement  powers  for  the  APPF46.  In  addition,  NGO 
voiced their concern over the delays in the publication of information related to donations47. 
They  advocate  for  the  real-time  publication  of  such  information,  especially  in  electoral 
period,  to  avoid  foreign  interference  in  elections  so  citizens  can  cast  their  ballot  in  an 
informed  manner.  OSCE/ODIHR  also  points  out  to  these  delays  in  the  publication  of 

Point 

44 
https://www.europarl.europa.eu/doceo/document/AFCO-PR-692733_EN.pdf  

prepared 

report 

draft 

the 

13 

of 

by 

AFCO. 

Available 

at: 

45 Based on the Commission’s informal consultations with EUPP/F. 

46 See for instance the intervention of M. Adam, Director of the APPF, in AFCO on 15 June 2021. 

47  Kergueno,  R. 
https://transparency.eu/boatfraud/  

(2017),  Fraud 

and  boats: 

funding  European  political  parties.  Available 

at: 

21 

 
 
 
                                                           
information related to donations and advocate for more frequent reporting on donations (and 
also contributions)48.  

iii) The APPF considers contributions from non-EU Member States to be inadmissible based on 
current  case  law49  that  confirms  that  entities  from  outside  the  EU  cannot  make  financial 
contributions  to  EUPP50.  This  hampers  EUPP/F’s  meaningful  relations  with  longstanding 
partners and previous members and, consequently, they feel limited in fulfilling their mission 
to promote democratic values beyond the EU’s borders. 

b) EU values, democracy and transparency 

i)  A reason why EUPP/F cannot fulfil their potential to create a truly European political spaces 
could  be  their  lack  of  visibility  at  national  level.  Despite  the  obligation  set  out  in  Article 
18(2a)  for  national  affiliates  to  display  the  logo  of  the  EUPP  they  are  member  of,  the 
European Democracy Consulting found that all EUPPs have national member parties, which 
do  not  display  their  logo  on  their  webpage,  with  the  only  exception  of  the  European 
Democratic Party. Moreover, 85% of national member parties do not display the logo of their 
EUPP of affiliation in a “clear and user-friendly” manner, if we define this as the top screen 
of  national  parties’  webpages.  EUPP  logos  are  over-represented  in  the  bottom  screen,  with 
close  to  58%  of  logos  found  there.  An  overwhelming  majority  of  logos  are  clearly  “not 
visible” (60%, and over 69% if we include websites not displaying any logo). Focusing only 
on logos ‘clearly visible’ or ‘moderately visible’, 71% logos fail the test, and up to 78%, if 
we include websites not displaying any logo51. 

Another limitation for EUPPs to perform their democratic function could be associated with 
the current prohibition to fund, directly or indirectly, elections, political parties, candidates or 
other  foundations  at  national  level52.  To  address  the  ambiguity  of  ‘indirect  funding’,  in  the 
run-up  to  the  2019  elections  to  the  European  Parliament,  the  APPF  and  the  European 
Parliament’s Authorising Officer developed five principles for campaigns for the elections to 
the  European  parliament,  the  respect  of  which  would  mean  eligibility  for  EU  funding53. 

48 OSCE Office for Democratic Institutions and Human Rights (2021), Submission to the European Commission and 
to  the  European  Parliament,  Preliminary  Comments  on  Reforming  Regulation  1141/2014  of  the  European 
Parliament  and  of  the  Council  on  the  statute  and  funding  of  European  political  parties  and  European  political 
foundations (unpublished). 

49  Judgment  of  the  General  Court  of  25.11.2020,  Alliance  of  Conservatives  and  Reformists  in  Europe/European 
Parliament, 
at: 
https://curia.europa.eu/juris/document/document.jsf;jsessionid=D94B8C2205E30C3FDCC31F18436119E5?text=&
docid=234334&pageIndex=0&doclang=en&mode=lst&dir=&occ=first&part=1&cid=1694530. See paragraphs 155-
162 of the judgement. 

EU:T:2020:560. 

T-107/19, 

Available 

50 
http://www.appf.europa.eu/cmsdata/238104/2020_AnnualActivityReport_AuthorityEUPPsEUPFs.pdf  

activity 

Annual 

APPF. 

report 

2020 

the 

of 

Available 

at: 

51 https://eudemocracy.eu/logos-project  

52 Article 22(2) of the EUPP/F Regulation. 

53 Annual Activity Report 2020 of the APPF, p. 15. Available at:  
http://appf.europa.eu/cmsdata/238104/2020_AnnualActivityReport_AuthorityEUPPsEUPFs.pdf  

22 

 
 
 
                                                           
While this has improved legal certainty to a certain extent, it did not allow for the increased 
direct involvement of EUPP/F in campaigns in Member States. 

ii)  Currently,  the  EUPP/F  Regulation  does  not  contain  any  transparency  obligation  on  gender 
parity; co-legislators only agreed to a voluntary measure in Recital 5. While there has been a 
positive  trend  towards  gender  balance  in  the  European  Parliament  throughout  the  years, 
voluntary measures have proven insufficient to ensure gender parity. 

iii) The  verification  mechanism  foreseen  in  Article  10(3)  of  the  EUPP/F  Regulation  is  too 
complex  to  be  triggered.  The  APPF  can  only  inform  the  European  Parliament,  the 
Commission and the Council about its doubts concerning compliance by a specific EUPP or 
EUPF  with  EU  values,  but  cannot  start  the  verification  process  without  the  request  by  the 
European institutions to act54. The APPF should also consider the opinion of the committee 
of independent eminent persons. Finally, the APPF’s decision to de-register a non-compliant 
EUPP  can  be  overruled  by  the  European  Parliament  and  the  Council  within  a  three-month 
period  on  grounds  related  to  the  assessment  of  compliance  with  the  conditions  for 
registration.  The  procedure,  thus,  includes  several  thresholds  that  make  the  enforcement  of 
the compliance requirement more difficult. Furthermore, the exact object  of the verification 
mechanism  is  unclear.  Namely,  the  EUPP/F  Regulation  does  not  specify  if  only  the 
compliance of EUPP/F themselves should be verified, or also that of their national member 
parties.  These  weaknesses  have  a  negative  impact  on  the  effectiveness  of  the  compliance 
mechanism,  and  on  the  ability  of  the  EU  institutions  to  hold  EUPP/F  accountable  for  a 
potential breach of respect for the EU’s fundamental values. The mechanism, therefore, only 
constitutes a limited deterrence for EUPP/F. 

c) Enforcement and administrative burden 

i)  The APPF is currently not sufficiently equipped to fulfil its potential: 

  The EUPP/F Regulation does not provide it with sufficient investigative powers in case 
of donations55. The APPF has advocated for clarifying its powers with regard to donors 
from the European Union (i.e., natural and legal persons) because those actors may act as 
strawmen to channel funds to EUPP/F, but have no legal obligation to cooperate with the 
APPF.  In  addition,  the  EUPP/F  Regulation  does  not  set  out  minimum  documentation 
standards  or  internal  control  mechanisms  for  accepting  donations,  so  the  APPF 
sometimes lacks the evidence to effectively verify donations as well as mean to obtain it. 
In  the  same  vein,  in  its  submission  to  the  Commission  and  the  European  Parliament, 
OSCE/ODIHR  also  pointed  to  the  discrepancy  between  national  best  practices  and  the 

54 Article 10(3) of the EUPP/F Regulation. 

55 Current tasks of the APPF include: decision on the registration and de-registration of European political parties 
and  foundations;  verifies  that  the  conditions  for  registration  are  being  complied  with;  establishes  and  manages  a 
register of European political parties and foundations; exercises control of compliance by European political parties 
and European political foundations  with specific obligations (in cooperation with the European Parliament and by 
the  competent  Member  States);  imposes  financial  sanctions;  publishes  specific  information  on  its  website,  in  line 
with Article 32. 

23 

 
 
 
                                                           
EUPP/F  Regulation  provisions  on  the  powers  of  the  APPF  and  urged  for  endowing  it 
with legal enforcement powers, so it can investigate and pursue potential violations56. 

  So far, the APPF has never made use of the sanction regime. According to some views, 
this  could  be  due  to  the  rigidity  of  the  regime  that  does  not  allow  the  APPF  to  either 
prioritise the breaches of the EUPP/F Regulation that should be pursued or to modulate 
the  level  and  nature  of  sanctions  to  make  it  proportionate  to  the  nature  of  the  breach, 
including in cases of neglect. 

  The APPF also  warns about  its limited resources in  its budgetary plan for 2021:  “Most 
recent experience suggests that the Authority’s new setting is sufficient to handle the day-
today, ordinary operations. However, the Authority comes under significant strain when 
faced  with  extraordinary  or  non-recurrent  work  streams  such  as  formal  investigations, 
litigation  before  the  Union  Courts  and,  potentially,  verification  procedures  of  matters 
related to European elections or matters affecting the respect for the values on which the 
Union  is  founded  on  the  part  of  European  political  parties  or  European  political 
foundations, as introduced by the European legislator”57.   

Table 1 – Total Resources Allocated to the APPF (direct support from the European 
Parliament 
+ APPF budget item) 

2021 

2020 

2019 

EUR 1 542 825 

EUR 1 539 200 

EUR 1 546 000 

Source: APPF Draft Budgetary Plans58 

ii)  The  introduction  of  double  accounting  standards,  operated  at  the  2018  revision  of  the 
EUPP/F  Regulation,  is  seen  by  all  actors  involved  as  unnecessary,  ineffective,  costly  and 
unfit for the nature of EUPP/F. Stakeholders agree that the administrative cost  linked to the 
introduction  of  the  International  Accounting  Standards  for  such  small  organisations 
outweighs  the  benefits.  In  practice,  eight  out  of  ten  EUPPs  are  based  in  Belgium,  so  the 
comparability of accounts is largely ensured.   In addition, the APPF  concluded, in its 2020 
Annual  Activity  Report,  that  the  use  of  templates  prepared  by  the  APPF  has  significantly 

56  OSCE/ODIHR  (2021),  Submission  to  the  European  Commission  and  to  the  European  Parliament,  Preliminary 
Comments on Reforming Regulation 1141/2014 of the European Parliament and  of the Council on the statute and 
funding of European political parties and European political foundations (unpublished). 

57 APPF Draft budgetary plan for 2021, p. 1. Available at:  
http://www.appf.europa.eu/cmsdata/216549/Draft%20budgetary%20plan%202021.pdf  

58 APPF Draft budgetary plan for 2020. Available at:  
http://www.appf.europa.eu/cmsdata/214214/Draft_budgetary_plan_2020.pdf and APPF Draft budgetary plan for 
2019. Available at:  http://www.appf.europa.eu/cmsdata/214215/Draft_budgetary_plan_2019.pdf  

24 

 
 
 
 
                                                           
increased the comparability of the different  EUPPs’ and EUPFs’ submissions,  and has also 
helped to harmonise the APPF’s checks of the different files59. 

iii) The perceived legal uncertainty derives from Article 24(1) of the EUPP/F Regulation which 
states  that  ‘control  of  compliance  by  European  political  parties  and  European  political 
foundations with their obligations under this Regulation shall be  exercised, in cooperation, 
by  the  Authority,  by  the  Authorising  Officer  of  the  European  Parliament  and  by  the 
competent Member States’. The fact that control is not concentrated in the hand of a single 
body sometimes results in diverging interpretations of the provisions. 

iv)  Regarding the protection of the financial interest of the EU following the deregistration of a 
European  political  party  or  foundation,  the  EUPP/F  Regulation  is  currently  unclear  on  the 
eligibility  of  their  expenditure  during  the  three-month  period  that  the  EUPP/F  Regulation 
foresees for the entry into force of a deregistration decision. In addition, the Regulation is not 
in line with Article 297 TFEU that stipulates that ‘(...) decisions which specify to whom they 
are  addressed,  shall  be  notified  to  those  to  whom  they  are  addressed  and  shall  take  effect 
upon such notification’.  

2.3. Who is affected by the identified problems and in what ways?  

The EUPP/F Regulation applies to a limited number of actors; namely, the ten registered EUPP 
and their ten affiliated EUPF, the APPF and the Authorising Officer of the European Parliament. 

By  setting  criteria  for  registering  as  a  EUPP,  the  EUPP/F  Regulation  has  an  impact  on  pan-
European political movements that currently do not meet the required criteria. These movements, 
therefore, do not benefit from the European legal statute established by the EUPP/F Regulation 
and, thus, from EU funding. 

European Political Parties 

As of April 2021, ten EUPPs are officially registered with the APPF (see Figure 6). These are the 
main actors affected by the shortcomings identified in the current legal regime. 

Figure 6 – EUPPs registered with the APPF 

59 APPF Annual Activity Report 2020. Available at: 
http://www.appf.europa.eu/cmsdata/238104/2020_AnnualActivityReport_AuthorityEUPPsEUPFs.pdf  

25 

 
 
 
 
 
                                                           
 
Source: APPF60 

The EUPP/F Regulation currently recognises contributions and donations as possible sources of 
own resources for EUPPs. At the same time, it sets out a 10% co-financing rate that EUPPs need 
to collect in order to match the public funding they receive. These two provisions together have a 
negative effect particularly on small EUPPs that would need additional resources to meet the co-
financing  rate,  but  these  possible  revenue  sources  (sponsorships,  participation  fees,  etc.)  are 
currently  not  recognised  by  the  EUPP/F  Regulation.  Therefore,  EUPP/F  Regulation  currently 
limits the ability of EUPPs to obtain funding.  

The current rules prohibit contributions from member parties located in countries outside the EU. 
This prohibition, coupled with the restrictive definition of membership, poses a problem to some 
EUPPs  that  have  full  or  auxiliary  members  from,  for  instance,  the  UK  or  neighbourhood 
countries. This problem is at the same time financial (lower level of contributions) and political 
(not  being  able  to  send  the  message  that  they  are  equal  members  of  the  European  political 
family).  Besides,  the  lack  of  transparency  of  donations  might  cause  unfair  advantages  to  those 
abusing the system. 

The ambiguity of the provisions on indirect funding and the eligibility of expenditure limit the 
possibility of EUPPs to closely work together with their national member parties, especially on 
campaigns. This, in turn, does not allow for EUPP to fulfil their potential in awareness raising on 
European  issues  in  Member  States  and  limits  their  visibility  at  national  level.  This  legal 
constraints also prevent EUPP from, on the one hand, educating citizens on the European cause 
and, on the other hand, providing training to those who would like to go into politics. Citizens’ 
education and better prepared political activists and candidates would, however, be indispensable 
for strengthening European democracy. 

Double  accounting  standards  increase  administrative  burden  for  EUPP  without  offering  real 
added  value.  As  they  are  generally  small  organisations  with  limited  human  and  financial 
resources, this additional administrative burden  may limit their  capacity  to  carry out  their core 
tasks. 

60 http://appf.europa.eu/appf/en/parties-and-foundations/registered-parties  

26 

 
 
 
 
                                                           
Some EUPP feel that they face difficulties receiving immediate legal remedy in disputes in the 
absence  of  an  in  between  appeal  instance  against  the  APPF  decisions  before  the  EUCJ.  This 
means that disputes either may stay without legal resolution, or legal remedy is only available in 
years’ time. 

European Political Foundations 

Currently, ten EUPF  are registered with  the APPF (see Figure 7). They  must be affiliated to  a 
EUPP  and  they  play  a  vital  role  in  both  complementing  the  objectives  of  that  party  and  in 
observing,  analysing  and  contributing  to  debates  on  various  political  topics.  Typically,  this 
involves  organizing  trainings,  seminars,  conferences  and  conducting  studies  on  issues  relevant 
for European public policies61.   

Figure 7 – EUPFs registered with the APPF 

See 

information 

61 
https://www.europarl.europa.eu/contracts-and-grants/en/political-parties-and-foundations/european-political-
foundations  

Parliament’s  website 

European 

contracts 

and 

the 

on 

on 

grants: 

27 

 
 
 
 
 
 
 
 
 
 
     
    
 
                                                           
Source: APPF62 

However,  the  restricted  definition  of  revenue  sources,  contributions  versus  donations,  does  not 
allow EUPF to properly raise funding. The current definition of contributions does not recognise 
two-tier memberships; this is not just a financial issue for them, but also a matter of messaging. 
It  also  limits  their  choice  of  partners  for  certain  activities.  In  addition,  the  prohibition  of 
contributions from members located in countries outside the EU has a similar effect on them as 
on EUPP. 

Current rules on the eligibility of expenditure and indirect funding does not allow for fulfilling 
their mission, namely  providing training for future candidates (in  particular female  candidates) 
and awareness raising on European political issues. It also hinders proper cooperation with their 
national members. Also, some EUPFs complained about a lack of legal certainty as the current 
ambiguity of the definition of indirect funding leaves room for interpretation. This again hinders 
the organisation of certain activities that their mission would require. 

Some EUPFs claim that the current undifferentiated sanctions regime may negatively affect the 
smaller  among  them  because,  for  a  relatively  small  irregularity,  the  sanction  may  cause 
bankruptcy. This, in turn, has a negative impact on political plurality. 

EUPFs  share  the  same  concern  as  EUPPs  regarding  double  accounting  requirements  and  the 
availability of legal remedies (see above). 

The Authority for European political parties and foundations 

The  current  provisions  do  not  provide  sufficient  investigative  powers  to  the  APPF  to  trace  the 
origin of donations. Furthermore, the lack of a more nuanced regime on sanctions impedes the 
APPF’s capacity to ensure proper enforcement of the rules contained in the EUPP/F Regulation. 

While  the  available  human  resources  are  sufficient  to  handle  day-to-day  operations,  the  APPF 
reported  of  coming  under  strain  when  faced  with  multiple  overlapping  tasks  or  with 
extraordinary  or  non-recurrent  work  streams  such  as  litigation  before  the  EU  courts  or  formal 
proceedings pursuant to the EUPP/F Regulation63. 

Citizens  

62 http://appf.europa.eu/appf/en/parties-and-foundations/registered-foundations  
63 Annual Activity Report 2020 of the APPF (2021). Available at: 
http://www.appf.europa.eu/cmsdata/238104/2020_AnnualActivityReport_AuthorityEUPPsEUPFs.pdf  

28 

 
 
 
 
                                                           
The ‘Future of Europe Special Eurobarometer 2020’ identified that the main way for citizens to 
make sure their voice is heard at EU level is voting at elections to the European Parliament every 
five years. But, at the same time, there is a desire for ‘ordinary citizens’ to be involved in policy- 
and decision-making at the EU level64. This is in stark contrast to the declining trend of voters 
turnout in the elections to the European Parliament until 2009 and 2014.  

This discrepancy may be explained by the fact that citizens may not identify clearly the political 
actors  at  the  EU  level,  including  the  EUPPs  and  their  link  with  their  national  parties.  As 
identified earlier, not all Member States permit national parties to display the logo of the EUPP 
they are associated with on their ballot and, oftentimes, the link between national and European 
political parties is not fully transparent. This makes it more challenging for citizens to understand 
the relation between the national and European political parties and creates additional distance to 
the decisions taken at EU level. 

In  addition,  the  lack  of  fair  gender  representation  negatively  affects  citizens,  in  particular 
women.  While  slightly  more  than  50%  of  the  European  population  is  female,  on  average  only 
38.9% of their European political representatives are so, with large variations per Member States. 
This leads to underrepresentation of women in European politics and is not in line with Article 
23 of the EU Charter on Fundamental Rights65.  

European Parliament and other institutions  

The identified shortcomings of the legislation impact not only on the individual EUPP/F but also 
on  the  European  Parliament  and  the  other  European  institutions.  Lack  of  transparency  and 
misuse  of  funds,  in  particular,  challenge  the  credibility  of  the  EU  and  its  democratic 
representation and could lead to European citizen’s reduced trust in policy- and decision-making 
at EU level. 

3. WHY SHOULD THE EU ACT?  

3.1. Legal basis 

The legal basis of the initiative is Article 224 of the Treaty on the Functioning of the European 
Union  (hereinafter,  TFEU)  which  provides  that  "the  European  Parliament  and  the  Council, 
acting  in  accordance  with  the  ordinary  legislative  procedure,  shall  lay  down  the  regulations 
governing  political  parties  at  European  level  referred  to  in  Article  10(4)  of  the  Treaty  on 
European Union and in particular the rules regarding their funding". 

Since  the  TFEU  provides  for  the  establishment  of  the  rules  governing  EUPPs  by  way  of  a 
regulation,  any  change  to  the  rules  currently  in  place,  the  EUPP/F  Regulation,  must  be 
established at EU level in application of Article 224 TFEU.  

64  https://www.europarl.europa.eu/at-your-service/files/be-heard/eurobarometer/2021/future-of-europe-2021/en-key-
findings.pdf  

Charter 

65 
https://www.europarl.europa.eu/charter/pdf/text_en.pdf 

Fundamental 

Rights 

on 

of 

the 

European  Union 

(2000).  Available 

at: 

29 

 
 
                                                           
The EUPP/F Regulation’s revision clause contained in its Article 3866 provides for the European 
Parliament to adopt a report on the application of the EUPP/F Regulation by the end of 2021, and 
the Commission to present a report on the same matter within six months of the adoption of the 
Parliament’s report, possibly accompanied with an amending legislative proposal, if appropriate. 
It  should  be  taken  into  account  in  this  context  that  any  modification  concerning  fundamental 
rules of  electoral  law67  applicable to  the EUPP/F  must be in  place  at  least one  year before the 
2024 elections to the European Parliament; namely, by May 2023 at the latest. 

The proposal fully complies with the principle of subsidiarity, since the EU level is the only one 
at  which  rules  governing  the  statute  and  funding  of  EUPP/F  can  be  laid  down.  As  it  has  been 
established in the previous sections of this impact assessment, although the EUPP/F Regulation 
has  provided  a  useful  legal  framework  for  the  functioning  of  EUPP/F  up  to  date,  existing 
loopholes and inefficiencies necessitate further targeted amendments.  

The  proposal  does  not  go  beyond  what  is  necessary  to  achieve  the  long-term  objective  of 
developing and strengthening European democracy and the legitimacy of the EU institutions, by 
seeking to make EUPP/F more effective and accountable democratic actors. It therefore complies 
with the principle of proportionality as well.  

4. OBJECTIVES  

4.1. General policy objectives 

The initiative at stake has three general policy objectives:  

 

Improve the legislative framework that enables EUPP/F to fulfil their mission in forming 
European political awareness by ensuring the democratic principles laid down in Article 
10 TEU. 

  Ensure EUPP/F’s higher level of compliance with the EU values, as enshrined in Article 

2 TEU. 

66 Article 38 – Evaluation  

The European Parliament shall, after consulting the Authority, publish by 31 December 2021 and every five years 
thereafter a report on the application of this Regulation and on the activities funded. The report shall indicate, where 
appropriate, possible amendments to be made to the statute and funding systems.  

No  more  than  six  months  after  the  publication  of  the  report  by  the  European  Parliament,  the  Commission  shall 
present a report on the application of this Regulation in which particular attention will be paid to its implications for 
the position of small European political parties and European political foundations. The report shall, if appropriate, 
be accompanied by a legislative proposal to amend this Regulation. 

67  See  Code  of  Good  Practice  in  Electoral  Matters:  Guidelines  and  Explanatory  Report  -  Adopted  by  the  Venice 
Commission  at  its  51st  and  52nd  sessions  (Venice,  5-6  July  and  18-19  October  2002).  Available  at: 
https://rm.coe.int/090000168092af01.  See  also  the  Compilation  of  Venice  Commission  opinions  and  reports 
at: 
concerning 
https://www.venice.coe.int/webforms/documents/?pdf=CDL-PI(2020)020-e. 

CDL-PI(2020)020. 

14.9.2020, 

Available 

electoral 

stability 

law, 

the 

of 

30 

 
 
                                                           
  Better ensure the sound financial management of EUPP/F, the appropriate enforcement of 

the Regulation and decrease the level of administrative burden. 

4.2. Specific policy objectives 

a)  Specific  objectives  contributing  to  enabling  EUPP/F  to  fulfil  their  mission  in 
forming  European  political  awareness,  by  ensuring  the  democratic  principles,  laid 
down in Article 10 TEU 

The proposal aims at adapting funding rules to (i) allow EUPP to play an active role in national 
campaigns on EU-relevant issues and (ii) ensure that EUPP/F can maintain meaningful relations 
with  their  member  parties  located  in  countries  outside  the  EU,  while  providing  the  necessary 
safeguards against unwanted foreign interference. 

The enforcement of the  provisions enhancing the link between national  and European political 
parties, and thus the degree of visibility of the latter, should be also improved. These two specific 
objectives would improve the visibility of EUPPs and allow them to form a common European 
political awareness. 

b)  Specific  objectives  contributing  to  ensuring  European  political  parties’  and 

foundations’ compliance with the EU values, as enshrined in Article 2 TEU  

The initiative also aims at promoting gender balance in European politics, and at operationalising 
the verification mechanism for EUPP/F compliance with EU values by simplifying it and making 
it easier to apply. 

c)  Specific  objectives  contributing  to  sound  financial  management,  strengthened 

enforcement and decreased administrative burden 

The  initiative  aims  at  adapting  the  typology  of  revenues  to  expand  the  categories  of  own 
resources  to  allow  participation  fees,  sponsorships,  publication  fees,  etc.  This  would  help 
EUPP/F  to  secure  the  10%  co-financing  rate  to  match  the  EU  funding  they  receive  and,  thus, 
improve their financial viability. 

The  initiative  aims  at  tightening  the  transparency  regime  for  donations  in  order  to  avoid 
unwanted  foreign interference through intermediaries. A due diligence mechanism for EUPP/F 
requiring that they know the source of donations before accepting them would increase the level 
of  self-compliance  with  the  EUPP/F  Regulation,  would  allow  the  APPF  to  better  investigate 
cases of alleged irregularities, and would improve financial transparency of the system overall. 

The  initiative  aims  at  further  empowering  the  APPF  so  it  can  better  carry  out  its  supervisory 
functions. 

The  initiative  also  aims  at  cutting  the  level  of  administrative  burden  for  EUPP/F.  Reduced 
administrative burden will allow these relatively small organisations to devote more resources to 
their core activities on democracy building.  

31 

 
 
It  also  aims  at  increasing  the  level  of  legal  certainty  provided  by  the  EUPP/F  Regulation  by 
further  clarifying  the  division  of  tasks  and  responsibilities  between  the  APPF  and  the 
Authorising  Officer  of  the  European  Parliament.  Greater  clarity  would  help  to  avoid  both 
functional  overlaps  and  diverging  interpretations  of  the  legal  provisions,  which  could  help 
EUPP/F identify activities that can benefit from public funding clearly distinguishing them from 
those that cannot. 

Finally, the initiative aims at  better protecting the financial  interests of  the EU by aligning  the 
rules on the entry into force of the deregistration decision with the Treaty on the Functioning of 
the EU. 

Figure 8 – General and specific policy objectives 

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t
s
i
n
m
d
a

i

Adapt the typology of own 
resources

Tighten transparency regime 
for donations

Empower the Authority 
regarding investigations and 
sanctions

Administrative simplification/ 
cutting red tape

Improve legal certainty

Safeguard the EU's financial 
interests

33 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
4.3. Consistency with other EU policies and with the Charter of Fundamental Rights of the 
European Union 

4.3.1. European Democracy Action Plan 

This revision is one of the items contained in EDAP68, the action plan announced by  President 
von der Leyen in her July 2019 Political Guidelines69 in view of addressing current challenges to 
democracy, including increasing threats of external interference in the elections to the European 
Parliament. EDAP, which was adopted on 3 December 2020, announced inter alia a legislative 
proposal  to  ensure  greater  transparency  on  paid  political  advertising  and  the  review  of  the 
legislation  on  the  funding  of  EUPP.  Both  initiatives  are  therefore  strongly  interlinked.  The 
political advertising initiative considers the use of political advertising in all elections, covering a 
number  of  problems  and  relevant  actors  including  service  providers  in  the  internal  market  and 
EUPPs.  It  will  provide  for  specific  requirements  for  EUPPs  to  use  political  ads,  in  particular 
creating  a  common  repository  for  political  ads  for  EUPPs,  and  a  review  process,  for  the 
Authority  to  take  note  of  breaches  of  the  rules  visible  on  the  basis  of  EUPP  disclosures.  The 
relevant provisions defining the powers of the Authority will be amended accordingly, to ensure 
full coherence between these two complementary initiatives. The lead service for the initiative on 
transparency of paid political advertising is Directorate-General for Justice and Consumers, and 
its adoption is planned for Q4 2021.  . 

4.3.2. Conference on the Future of Europe and European Electoral Act 

The proposal for the revision of the EUPP/F Regulation will be drafted in a neutral way in order 
to  cater  for  any  future  potential  developments  in  the  context  of  the  institutional  strand  of  the 
Conference  on  the  Future  of  Europe  (hereinafter,  CoFE),  in  particular  regarding  transnational 
lists and the lead candidate system.  

The  vast  majority  of  stakeholders  concur  that,  if  the  relevant  parties  were  to  agree  on  the 
introduction  of  transnational  lists  and/or  a  legal  formalisation  (in  whatever  form)  of  the  lead 
candidate  system,  this  would  have  impacts  on  and  consequences  for EUPPs.  But,  at  the  same 
time, there is a general understanding that the revision of the EUPP/F Regulation would not be 
the appropriate framework to address these issues.   

This neutrality will also allow for consistency with the potential reform of the EU’s Electoral Act 
that is currently on hold awaiting the outcome of the discussions at the CoFE.  

68  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and 
Social Committee and the Committee of the Regions on the European democracy action plan, COM/2020/790 final. 
Available 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A790%3AFIN&qid=1607079662423  

at: 

69  President  von  der  Leyen  (2019),  A  Union  that  strives  for  more  –  my  agenda  for  Europe.  Available  at: 
https://ec.europa.eu/info/sites/default/files/political-guidelines-next-commission_en_0.pdf 

34 

 
 
                                                           
4.3.3. Commission’s Gender Equality Strategy 2020-2025 

By adding specific provisions to  promote gender equality in  European politics,  the initiative is 
fully  consistent  with  the  Commission’s  Gender  Equality  Strategy  2020-202570  that  urges  for 
equal  opportunities  in  participation  for  representative  democracy  at  all  levels  –  European, 
national, regional and local.  In addition, the Strategy states that  ‘the Commission will promote 
the participation of women as voters and candidates in the 2024 European Parliament elections, 
in  collaboration  with  the European Parliament,  national  parliaments,  Member States and civil 
society,  including  through  funding  and  promoting  best  practices.  European  political  parties 
asking  for  EU  funding  are  encouraged  to  be  transparent  about  the  gender  balance  of  their 
political party members’. 

4.3.4. Charter of Fundamental Rights of the European Union 

The revision of the EUPP/F Regulation is in line with the principles laid down in the Charter of 
Fundamental Rights of the European Union71 as regards political participation: 

  Freedom of assembly and of association (Article 12, EU Charter of Fundamental 

Rights) 

“1. Everyone has the right to freedom of peaceful assembly and to freedom of association at all 
levels,  in  particular  in  political,  trade  union  and  civic  matters,  which  implies  the  right  of 
everyone to form and to join trade unions for the protection of his or her interests.” 

“2. Political parties at Union level contribute to expressing the political will of the citizens of 
the Union.” 

  Right  to  vote  and  to  stand  as  a  candidate  at  elections  to  the  European  Parliament 

(Article 39) 

“1. Every citizen of the Union has the right to vote and to stand as a candidate at elections to the 
European Parliament in the Member State in which he or she resides, under the same conditions 
as nationals of that State.“ 

“2. Members of the European Parliament shall be elected by direct universal suffrage in a free 
and secret ballot”. 

70  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and 
Social  Committee  and the  Committee of the  Regions,  A Union of Equality: Gender Equality Strategy 2020-2025, 
COM(2020) 
https://eur-lex.europa.eu/legal-
final, 
content/EN/TXT/PDF/?uri=CELEX:52020DC0152&from=EN 

Available 

152 

14. 

at: 

p. 

71 Available at: https://www.europarl.europa.eu/charter/pdf/text_en.pdf 

35 

 
 
                                                           
 
Increasing transparency will ensure that this right is respected and that citizens have the ability to 
check  if  their  political  will  is  expressed  by  the  party  they  support  at  EU  level  as  stipulated  in 
Article 12 and 39. 

  Non-discrimination (Article 21) 

“1. Any discrimination based on any ground such as sex, race, colour, ethnic or social origin, 
genetic features, language, religion or belief, political or any other opinion, membership of a 
national minority, property, birth, disability, age or sexual orientation shall be prohibited.” 

“2. Within the scope of application of the Treaties and without prejudice to any of their specific 
provisions, any discrimination on grounds of nationality shall be prohibited.” 

  Equality between men and women (Article 23) 

“Equality  between  men and  women  must  be  ensured  in  all  areas,  including  employment,  work 
and  pay.  The  principle  of  equality  shall  not  prevent  the  maintenance  or  adoption  of  measures 
providing for specific advantages in favour of the under-represented sex.” 

Adding a gender dimension to the revision of the EUPP/F Regulation would ensure compliance 
with Article 21 and 23 to guarantee a balanced representation of both sexes in political parties. 
The principle allows for measures that lead to a better representation. 

5. POLICY OPTIONS 

5.1. Baseline scenario 

The baseline scenario is to  maintain the status  quo and do not  revise Regulation  1141/2014  as 
last  amended  by  Regulation  (EU,  Euratom)  2019/493.  However,  this  policy  option  leaves  the 
problems identified above unresolved and may not be fit for future developments. 

In  view  of  the  upcoming  European  elections  in  2024,  the  baseline  would  not  allow  for  higher 
visibility for European political parties and more interaction between the European and national 
political  parties.  The  baseline  scenario  would  therefore  hinder  the  achievement  of  general 
objective  1  to  form  European  political  awareness.  In  addition,  current  prohibition  to  receive 
membership fees from  affiliates from  non-EU countries would continue to pose a political  and 
financial  problem  for  EUPP/F.  While  the  number  of  EU  citizens  served  by  the  EUPP/Fs  has 
reduced  by  over  10%  since  Brexit,  their  membership  has  not  changed72,  neither  has  their 
democracy building mission, which goes beyond EU’s borders.  

Recently, foreign party funding has been used to unsettle the EU and its Member States73. Russia 
and  China  are  the  most  visible  players  in  the  field,  but  ultraconservative  organisations  in  the 
USA have also actively financed and coordinated far-right movements in Europe, particularly in 

72 The EUPP/F Regulation does not prohibit membership from non-EU countries, see Annex VI. 
73 E. Bressanelli (2021), Investing in destabilisation: How foreign money is used to undermine democracy in the EU, 
https://www.europarl.europa.eu/RegData/etudes/STUD/2021/653631/EXPO_STU(2021)653631_EN.pdf   

36 

 
 
                                                           
the run-up to the 2019 elections to the European Parliament74. This trend is expected to remain 
and become even more prominent in the coming years. Keeping the status quo and the current 
loopholes  in  the  transparency  regime  for  donations  in  Regulation  1141/2014,  coupled  with  the 
inability of the APPF to investigate, would therefore expose EUPP/F to this risk. 

At  the  same  time,  public  information  on  the  financial  statements  of  EUPP/F  would  remain 
scattered and delays in their publication may persist. For this reason, transparency for the citizens 
would not be sufficiently ensured. 

Difficulties in raising own resources would further undermine the financial viability of EUPP/F. 
The restrictive categorisation of revenues and the need to match the 10% and 5% co-financing 
rate may lead to irregularities, as identified by the European Parliament’s Authorising Officer in 
the past75. 

The  current  Regulation  does  not  contain  binding  provisions  on  gender  equality  and  therefore 
does not ensure coherence with the Commission’s Gender Equality Action Plan 2020-2025. 

The rigid  sanctions  regime may lead to  disproportionately high sanctions for smaller breaches. 
This  may  impede  its  use  in  order  to  avoid  undermining  the  financial  viability  of  European 
political parties and foundations. 

The  EUPP/F  Regulation  should  be  coherent  with  possible  changes  to  the  1976  European 
Electoral  Act  following  the  ongoing  work  in  the  AFCO  Committee  on  its  amendment,  which 
may include the introduction of a common European constituency, should the discussions in the 
CoFE point in  that direction. The current  EUPP/F Regulation  could  not  ensure coherence with 
this  development  as  it  would  not  provide  the  appropriate  legislative  framework  for  EUPPs 
regarding  campaigning  for  the  lead  candidates  and  on  transnational  lists.  Furthermore,  the 
current  EUPP/F  Regulation  cannot  ensure  coherence  with  the  objectives  of  the  European 
Democracy  Action  Plan,  and  in  particular  the  legislative  initiative  on  transparency  of  political 
advertising,  as  for  the  time  being  it  does  not  contain  specific  rules  for  the  use  of  political 
advertising  by  the  EUPPs,  and  does  not  provide  the  Authority  with  the  necessary  oversight. 
powers. 

Stakeholders’ views on the baseline scenario 

While all stakeholders agree that the EUPP/F Regulation provides a useful legal framework for 
the  statute  and  funding  of  EUPP/Fs,  wide  consensus  has  emerged  that  the  Regulation  needs 
targeted amendments to address the identified loopholes. 

74  Rudolph  J.  and  Morley,  T.  Covert  Foreign  Money.  Financial  loopholes  exploited  by  authoritarians  to  fund 
political interference in democracies, p. 1. 

75 I. Anglmayer (2021), Statute and funding of European political parties under Regulation 1141/2014  -ex post 
evaluation. Available at: 
https://www.europarl.europa.eu/RegData/etudes/STUD/2021/662646/EPRS_STU(2021)662646_EN.pdf  

37 

 
 
                                                           
5.2. Options for further in-depth assessment 

Option 2 focuses on the revision of the funding provisions in the Regulation.  The Commission 
considers  that  the  problems  identified  under  the  funding  provisions  of  the  Regulation  are  the 
most  pertinent  in  the  Regulation’s  underperformance.  This  option  is  strictly  aligned  with  the 
commitment undertaken  by President  von der  Leyen in  her Political  Guidelines to  put  forward 
legislative proposals under the European Democracy Action Plan to ensure greater transparency 
on  paid  political  advertising and  clearer  rules  on  the  financing  of  EUPPs76.  The  impact  of  the 
additional provisions are analyzed in the impact assessment on the initiative on transparency of 
paid political advertising. 77  

Option 3 goes beyond the mere revision of the funding provisions to also include other aspects of 
the  Regulation  that,  according  to  the  Commission’s  analysis  and  input  received  from 
stakeholders, could benefit from targeted improvement in the text of the Regulation. This option 
includes  the  reduction  of  administrative  burden,  strengthening  enforcement  and  the  sanctions 
regime,  operationalising  the  verification  mechanism  for  EU  values  and  promoting  gender 
equality. 

Table 2 – Overview of policy options 

Area of problem 

Option 1 
Baseline 
scenario 

Funding 
provisions 

No change 

Option 2 

Option 3 

Objective 

Addressing 
difficulties 
matching the co-
financing rate 

Addressing 
difficulties 
matching the co-
financing rate 

General 
objective 3 

Tightening the 
transparency 
regime for 
donations 

Facilitating 
meaningful 
relations with 
actors outside the 

Tightening the 
transparency 
regime for 
donations 

Facilitating 
meaningful 

General 
objective 3 

General 
objective 1 

76  President  von  der  Leyen  (2019),  A  Union  that  strives  for  more  –  my  agenda  for  Europe.  Available  at: 
https://ec.europa.eu/info/sites/default/files/political-guidelines-next-commission_en_0.pdf  

77 SWD No…. 

38 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
Option 2 

Option 3 

Objective 

Area of problem 

Option 1 
Baseline 
scenario 

EU 

EU values, 
democracy and 
transparency 

relations with 
actors outside the 
EU 

Improving 
visibility 

Helping European 
political parties 
fulfil their 
constitutional 
mission 

Improving gender 
balance  

Simplifying the 
verification 
mechanism for 
compliance with 
EU values 

General 
objective 1 

General 
objective 1 

General 
objective 2 

General 
objective 2 

Empowering the 
Authority 

General 
objective 3 

Reducing 
administrative 
burden 

General 
objective 3 

Improving legal 
certainty 

General 
objective 3 

Better protecting 
the EU’s financial 
interests 

General 
objective 3 

No change 

No change 

Enforcement and 
administrative 
burden 

No change 

No change 

6. ANALYSIS OF FEASIBILITY AND IMPACTS OF THE POLICY OPTIONS  

39 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Due  to  the  specific  character  of  the  Regulation,  namely  that  it  has  direct  impact  on  20 
organisations (10 EUPPs and their 10 affiliated EUPFs), the APPF and the Authorising Officer 
of the European Parliament, the policy options will have negligible environmental, economic and 
social impacts. The impact assessment will therefore focus on the options’ impacts in the area of 
fundamental rights and democracy. 

6.1. Impacts of policy option 2  

Option  2  focuses  on  addressing  the  shortcomings  of  the  funding  provisions  of  the  Regulation 
identified in section 2.1. The funding provisions constitute the  core of the EUPP/F Regulation, 
and tackling the identified shortcomings in  this area would already contribute to  some specific 
objectives  under  general  objectives  1  and  3,  should  the  Commission  decide  to  propose  a  more 
targeted  amendment  of  the  Regulation.  More  specifically,  the  proposed  changes  would  better 
ensure the financial viability of EUPP/Fs and would promote sound financial management, while 
also creating further safeguards against foreign interference. 

Two alternative measures were considered to address the difficulty of European political 
parties and foundations fulfilling the co-financing obligation under Article 17(4): 

a)  recognising additional categories of own resources 

b)  lowering even further the co-financing rate 

Measure  a)  would  not  only  provide  European  political  parties  and  foundation  with  increased 
flexibility to generate own revenue, but also corresponds better to their political organisation and 
activities.  

However, a number of risks have been identified with this measure. The introduction of a new 
category of revenue also entails the risk that it is used as a loophole to circumvent the limitations 
imposed  on  donations  and  contributions.  Addressing  these  loopholes  might  require  a  too 
complex  revenue  structure  imposing  administrative  burden  on  European  political  parties  and 
foundations.  

To mitigate these risks, it is proposed to impose a ceiling on the total revenue generated through 
“other  own  resources”  in  analogy  to  member  contributions.  This  latter  threshold  should  be 
sufficiently low in order to minimize the risk of interference. This solution would be the easiest 
to  implement  for  European  political  parties  and  foundations  and  would  cause  the  smallest 
administrative burden on them. Coupled with a ceiling, the measure would therefore not only be 
effective, but also efficient. 

Measure  b)  would  lower  the  required  own  resources  to  receive  the  entire  contribution/grant 
amount, reducing the internal budgetary pressure on European political parties and foundations. 
Table 1 simulates the impact of lowering the co-financing obligation from the current 10% to 5% 
and 2% illustrating the reduced internal budgetary pressure on the parties. 

Table 3 – Simulation of required own resources to match maximum contribution 

40 

 
 
 
Max. Contribution 
2019 
€ 15 832 805 
€ 13 051 506 
€ 4 564 976 
€ 3 566 561 
€ 2 782 092 
€ 1 070 523 
€ 1 355 784 
€ 927 892 
€ 4 422 345 
€ 2 425 515 

EPP 
PES 
ALDE 
EGP 
PEL 
EDP 
EFA 
ECPM 
ECRP 
IDP 

10% Own 
Resources 
€ 1 759 201 
€ 1 450 167 
€ 507 220 
€ 396 285 
€ 309 121 
€ 118 947 
€ 150 643 
€ 103 099 
€ 491 372 
€ 269 502 

5% Own 
Resources 
€ 833 306 
€ 686 921 
€ 240 262 
€ 187 714 
€ 146 426 
€ 56 343 
€ 71 357 
€ 48 836 
€ 232 755 
€ 127 659 

Source: W. Wolfs78 

2% Own 
Resources 
€ 323 118 
€ 266 357 
€ 93 163 
€ 72 787 
€ 56 777 
€ 21 847 
€ 27 669 
€ 18 937 
€ 90 252 
€ 49 500 

However, the measure would  have a negative impact  on EUPP/F’s relations with  citizens. The 
co-financing  obligation  has  been  introduced  in  order  to  incentivise  parties  to  strengthen  their 
financial ties in society. It was already reduced by the 2018 amendment of the Regulation from 
15%  to  10%  for  EUPPs  and  5%  for  EUPFs.  Easing  the  co-financing  obligation  even  further 
would also substantially lower this incentive, while the visibility and connectedness of European 
political  parties  and  foundations  with  European  citizens  and  civil  society  is  already  rather 
limited.  In  addition,  lowering  the  co-financing  obligation  increases  the  probability  that  the 
European political parties and foundations will financially become almost entirely dependent on 
public resources, creating an over-dependency on state support. This is a situation that should be 
avoided, according to the existing international guidelines79. For this reason, while the measure 
would be effective regarding general objective 3, it would not be coherent with general objective 
1.  

To  address  the  remaining  risk  of  foreign  interference  through  donations,  two  alternative 
measures are considered: 

a)  due diligence mechanism for European political parties and foundations 

b)  introduction of overall ceiling for donations 

Measure a) has the potential to strengthen the verification of the identity of the donors, increase 
the  overall  transparency  of  their  income  and  reduce  the  risk  of  foreign  interference.  European 
political parties and foundations would authenticate that the natural person or entity from whose 
account the donation was made, was indeed the actor that wanted to make the donation. This is 

78 Wolfs W. (2021), Impact assessment study – Revision of Regulation 1141/2014, unpublished. 
79  European  Commission  for  Democracy  through  Law  (Venice  Commission)  &  OSCE  Office  for  Democratic 
Institutions and Human Rights (2020), Guidelines on Political Party Regulation (2nd edition), pp. 64-65. Available 
at: https://www.venice.coe.int/webforms/documents/default.aspx?pdffile=CDL-AD(2020)032-e 

41 

 
 
 
 
 
 
 
                                                           
in  line  with  the  provisions  on  donations  in  the  Regulation  (Article  20)  that  are  aimed  at 
maximum transparency and – among others – preventing anonymous donations. For this reason, 
the  measure  would  be  effective  in  contributing  to  general  objective  3.  However,  such  a  due 
diligence  mechanism  also  implies  an  increased  administrative  workload  for  the  parties.  To 
ensure  the  efficiency  of  the  measure,  the  due  diligence  mechanism  could  be  limited  to  larger 
donations only (with a value above EUR 12 000). As such, a balance would be struck between 
increasing  transparency  and  control  of  the  donation  regime  for  EUPPs,  while  keeping  the 
additional administrative workload limited. 

Measure  b)  would  introduce  an  overall  ceiling  on  donations  comparable  to  the  ceiling  for 
contributions from members (capped at 40% of the total annual budget of the EUPP/F). Unless 
the ceiling for donations is kept substantially low (e.g. 5% or less of the total annual budget), this 
solution would not solve the main identified problem, namely the possibility for foreign entities 
to  use donors as  an instrument for unwanted influence. Setting an overall ceiling  on donations 
might  have  an  additional  adverse  effect  of  depriving  the  EUPP/F  of  a  broad  and  diversified 
donor  base.  In  some  cases,  where  EUPPs  rely  substantially  on  donations,  setting  such  a  low 
ceiling  on  donations  would  substantially  limit  the  fund-raising  ability  of  this  EUPP,  while  the 
risk of undue interference is currently limited. For this reason, the effectiveness and efficiency of 
measure b) is considered lower than that of measure a). 

To  ensure  EUPP/F  meaningful  relations  with  actors  outside  the  EU,  while  providing  the 
necessary  safeguards  against  unwanted  foreign  interference,  two  alternative  measures  are 
considered:  

a)  amend the provisions related to contributions from members to allow such contributions 

from frmembers of the Council of Europe. 

b)  add specific criteria that parties in third countries have to fulfil for membership eligibility 

Measure a) would send a political message to their affiliates from non-EU members allowing for 
meaningful  cooperation  with  them.  It  would  also  reduce  the  difficulty  for  EUPP/F  to  have 
sufficient own resources due to their inability to collect membership fees from non-EU countries. 
The measure is  therefore considered to  be effective. This  measure would however increase the 
risk  of  foreign  interference,  which,  in  turn  would  increase  the  political  cost  of  the  measure 
thereby  risking  its  efficiency  and  also  its  coherence  with  the  measure  on  strengthening  the 
transparency regime for donations to safeguard against interference. This risk could be mitigated 
by capping the revenue from contributions from non-EU members at a certain level, for example 
at 5% or 10% of the total own resources.   

Measure b) would entail adding specific criteria that member parties from third countries must 
fulfil  in  order  to  be  eligible  to  make  membership  contributions.  Such  criteria  could  include 
provisions  that  point  to  ‘like-minded  political  formations’  or  ‘political  formations  sharing  the 
core  values  of  the  European  political  party’.  However,  such  provisions  can  leave  room  for 
interpretation which makes a proper legal assessment of compliance with these provisions more 
difficult. For this reason, the measure is considered less efficient than measure a).  

42 

 
 
 
Cost, administrative burden reduction and simplification potential of Option 2 

As  Option  2  introduces  more  complex  reporting  obligations  on  EUPP/Fs,  it  would  generate 
additional  administrative  cost  for  them,  and  also  for  the  APPF  and  the  European  Parliament’s 
Authorising Officer, who control their financial statements. In case these additional costs are not 
offset  by  simplification  in  other  areas,  they  might  take  away  funds  from  their  core  business, 
namely their political activities. 

Stakeholders’ views on option 2 

EUPP/Fs  argued  for  diversifying  the  categories  of  own  resources  throughout  the  informal 
consultation process and at the hearing organised by the AFCO Committee on 22 June 2021 on 
the  application  of  the  EUPP/F  Regulation.  They  also  called  for  the  revision  of  the  EUPP/F 
Regulation to allow for a meaningful cooperation with likeminded parties in non-EU countries. 

The  APPF  has  advocated  for  the  introduction  of  a  due  diligence  mechanism  for  EUPP/Fs 
regarding donations in order to close existing loopholes in their transparency regime. The APPF, 
however, cautioned against allowing for contributions from member parties in non-EU countries.  

The  European  Parliament’s  AFCO  Committee,  in  its  draft  report,  called  for  broadening  the 
categories of own resources to improve the financial viability of EUPP/Fs. The draft report also 
considered  that  EUPP/Fs  should  be  open  to  membership  from  parties  or  individuals  from 
neighbourhood  countries  and  allowed  to  receive  their  contributions,  provided  that  full 
transparency is ensured. 

OSCE/ODIHR,  in  their  submission  to  the  Commission  and  the  European  Parliament,  calls  for 
reviewing  the  overall  amount  of  public  funding  available  to  European  political  parties  so  they 
can  effectively  carry  out  their  activities.  They  also  advocate  for    progressively  decreasing  the 
maximum ratio of public-to-private funding of EUPPs. 

6.2. Impacts of policy option 3  

Option  3  would  allow  for  tackling  all  identified  shortcomings  in  the  impact  assessment  in 
addition  to  those  tackled  under  option  2,  contributing  to  achieving  all  general  objectives.  This 
section  does  not  repeat  the  proposed  solutions  under  option  2,  but  focuses  on  the  measures 
proposed  to  tackle  the  problems  identified  in  sections  2.1.b  and  2.1.c  .(  i.e.  concerning  EU 
values, democracy and transparency; and enforcement and administrative burden). 

To improve the  visibility  of  the  link  between  European  political  parties  and  national 
member parties, two measures are considered: 

a)  introducing sanctions for non-compliance 

b)  clearly defining the requirements for the visibility of the European political party of 

affiliation 

43 

 
 
 
Measure a) would entail including non-compliance in the list of non-quantifiable infringements 
in the sanction regime (Article 27). This would mean that if one or more member parties do not 
publish  the  logo  and  programme  of  the  EUPP  of  affiliation  on  their  websites  (as  required  by 
Article 18(2a)), this might lead to a financial sanction on the latter. By modulating the sanction 
that  the  EUPP  might  face,  the  measure  would  remove  the  disproportional  possibility  of  a  total 
loss  of  funding  for  the  European  political  party.  It  would  still  act  as  a  deterrent,  and  would 
therefore increase the effectiveness of the regulatory framework.  

Measure b) would indeed have a positive effect on the visibility of the European political party, 
as  its  logo  would  be  placed  on  the  website  on  a  more  prominent  place  than  has  been  the  case 
until now. However, the measure would not tackle the disproportionality of the consequences of 
non-compliance.  On  the  contrary,  the  specification  of  the  provisions  might  even  increase  the 
chances  of  non-compliance,  thus  potentially  resulting  in  EUPP  losing  their  entire  EU  funding. 
For this reason, measure b) alone is not considered sufficiently effective to address the identified 
problem. 

To  address  European  political  parties’  inability  to  fulfil  their  constitutional  mission,  two 
measures are considered: 

a)  allowing EUPPs to use their funds to act in national referendum campaigns on EU issues 

b)  introducing a campaign grant for European political parties to be used in a fixed period 

before the European elections 

Under  Measure  a)  EUPPs  take  on  the  function  comparable  to  civil  society  organisations  and 
campaign  in  favour  or  against  the  content  of  the  referendum  question.  This  possibility  would 
increase their visibility for EU citizens and would contribute to the development of a European 
political space. It is considered that European political parties would have a  limited capacity to 
influence  the  final  outcome  of  the  referenda.  The  sums  set  out  in  Table  2  indicate  that  the 
financial potential for expenditure on referendum campaigns is not excessive: at current funding 
levels,  expenses  of  maximum  a  few  €100 000  can  be  expected,  considering  that  the  European 
parties will not concentrate all their financial resources on one referendum campaign. While such 
amounts  are  limited  for  referendum  campaigns  in  larger  member  states  –  during  the  EU 
membership  referendum  in  the  UK,  a  total  of  approximately  €38  million  was  spent  on  all 
campaigns  combined  –80  they  can  make  a  difference  in  referendum  campaigns  in  smaller 
member  states.  In  the  EU  membership  referendum  in  Latvia  in  2003  for  example,  all  national 
parties combined only spent approximately €350 000, meaning that campaign expenses from the 
European  political  parties  in  such  cases  hold  the  potential  to  influence  the  outcome  of  the 
elections.81  

Table 4 – Selection of total campaign expenditure in EU referenda 

80  The  Electoral  Commission 
(2019),  Campaign  spending  at 
https://www.electoralcommission.org.uk/who-we-are-and-what-we-do/elections-and-referendums/past-elections-
and-referendums/eu-referendum/campaign-spending-eu-referendum 

referendum.  Available  at: 

the  EU 

81 Although scientific evidence on campaign spending effects on referendum outcomes is diverse. 

44 

 
 
                                                           
Year 

2003 

2005 

2005 

2016 

Country 

Latvia 

Referendum 

Total Expenditure 

EU membership 

€350 000 

Netherlands 

EU Constitution 

€3 790 000 

Spain 

UK 

EU Constitution 

€14 461 763 

EU Membership 

€38 036 000 

Source: W. Wolfs, based on M. van Klingeren, M. Orozco, J. van Spanje, C. De Vreese (2015)82 

However, there are still countries that will not allow campaigns from ‘third parties’ in the run-up 
to referenda. This can be solved by either an imposed harmonisation of the referendum campaign 
rules in the members states (in analogy to the measures taken for the introduction of the EU legal 
status  for  EUPPs),  or  by  acknowledging  that  EUPPs  should  obey  the  national  provisions.  The 
latter solution would recognise the principle of subsidiary and allow EU countries to determine 
their own rules in  this  respect,  but  would  also  create an inequality between Member States,  as 
some  will  allow  the  involvement  of  EUPPs  (as  ‘third  parties’)  in  the  referendum  campaigns, 
while others will prohibit it83.   

The measure would also entail the risk of indirect funding to national parties, as national political 
parties  usually  take  a  clear  position  on  the  referendum  question  trying  to  use  the  referendum 
campaign for increasing their own electoral support. For these reasons, the measure is considered 
to  be  effective  in  increasing  the  visibility  of  EUPP/F,  but  limited  in  efficiency  and  coherence 
with other provisions of the Regulation. 

Measure b) is similar to measure a) but would allow European political parties to use EU funds 
in electoral campaigns in the run-up to European elections by introducing a campaign grant. This 
would only be allocated in European election years in addition to the annual operating grant and 
could only be used in a fixed period before the European elections. As the campaign grant would 
not be tied to the prohibition on indirect support to national political parties, European political 
parties could realise their full political potential during the electoral campaigns for the European 
Parliament. The main counterargument that EU funds could be used to influence national politics 
is not relevant in this context, since European elections should revolve around European issues, 
and not around domestic issues.  

The  campaign  grant  could  also  contribute  to  addressing  the  limited  capacity  of  EUPPs  to  find 
sufficient own resources to match EU funds if it contained a co-financing obligation of 0%. The 
total funding sum of the operational grants does not have to be increased during election years, 
and the co-financing obligation of this operational grant can be kept at 10%. The campaign grant 

82 M. van Klingeren, M. Orozco, J. van Spanje, C. De Vreese (2015) Party Financing and Referendum Campaigns in 
EU  Member 
at: 
AFCO 
https://www.europarl.europa.eu/RegData/etudes/STUD/2015/519217/IPOL_STU(2015)519217_EN.pdf  

Committee, 

Available 

States, 

70-86. 

Study 

pp. 

the 

for 

83 To some extent, this inequality is already present, as some member states allow for national referendums, whereas 
in other countries this possibility does not exist. 

45 

 
 
 
 
                                                           
could  also  use  a  different  distribution  key  than  the  operational  grants  thereby  creating  a  level-
playing field where the electoral support from European citizens is based on the strength of the 
political argument and policy proposals of EUPPs, and not on the differences in their  financial 
resources.  Finally,  a  separate  and  more  stringent  transparency  regime  should  apply  during  the 
campaign  period  comprising  of  the  real  time  publication  of  data  on  European  political  parties’ 
accounts. This regime should encompass expenditure on political advertising to ensure coherence 
with the initiative on the transparency of political advertising under the EDAP. 

However,  similarly  to  referenda,  seven  Member  States  (Belgium,  Croatia,  Estonia,  Lithuania, 
Poland,  Portugal  and  Spain)  currently  ban  campaign  expenditure  of  third  parties  during  the 
elections. The potential willingness of these countries to exempt EUPPs from this ban could be 
explored further. 

For these reasons, the measure is considered to be effective and be more coherent with the other 
provisions of the Regulation and other initiatives  under the EDAP.  Its  coherence with  national 
legislation, however, should be further explored with Member States. 

To promote gender balance in European politics, two alternative measures are considered: 

a)  introducing a transparency obligation for gender balance at European elections 

b)  introducing a transparency obligation on gender representation for EUPP/F 

Measure a) would entail the re-introduction of the provision that the Commission proposed at the 
2018 amendment of the Regulation: ‘A European political party shall include in its application 
evidence demonstrating  that its member parties have continuously published on their websites, 
during 12 months  preceding  the moment  at  which the applications is  made […] on the gender 
representation  among  the  candidates  at  the  last  elections  to  the  European  Parliament  and 
among  the  Members  of  the  European  Parliament’.  This  measure  would  link  the  transparency 
obligation on gender to  application for EU funding and could potentially be a powerful tool to 
promote  gender  balance.  The  political  viability  of  this  measure,  however,  may  be  limited  as  it 
was  rejected  by  the  co-legislators  during  the  interinstitutional  negotiations  on  the  2018 
amendment of the Regulation. 

Measure b) would increase the accountability of the European political parties and foundations 
with regard to gender balance to the citizens. It could provide them with the necessary incentives 
to  improve  their  internal  gender  balance.  By  providing  a  good  example  to  their  national 
members,  EUPPs  may  incentivise  their  national  members  to  improve  gender  balance  in  their 
governing  structures  and  on  electoral  lists.  However,  as  the  measure  does  not  publicly  expose 
gender balance in national member parties, it is expected to be less effective than measure a) and 
does  not  ensure  coherence  with  international  standards  that  argue  against  interference  with 
internal party democracy 84. Nor is the measure coherent with the Commission’s Gender Equality 

84  European  Commission  for  Democracy  through  Law  (Venice  Commission)  &  OSCE  Office  for  Democratic 
Institutions  and  Human  Rights  (2020),  Guidelines  on  Political  Party  Regulation  (2nd  edition).  Available  at: 
https://www.venice.coe.int/webforms/documents/default.aspx?pdffile=CDL-AD(2020)032-e 

46 

 
 
                                                           
Strategy  2020-2025  that  calls  for  transparency  about  gender  equality  in  the  member  parties  of 
EUPPs85. 

To  operationalise  the  verification  mechanism  for  the  compliance  with  EU  values,  two 
alternative measures are considered: 

a)  lowering the threshold to act by empowering the APPF to launch the mechanism 

b)  clarifying the obligation for compliance with EU values by the members of a EUPP/F 

Measure a) would simplify the procedure that currently only allows for action from the APPF on 
the receipt of a request  either from  the European Parliament, the European Commission  or the 
Council  of  Ministers.  It  would  increase  the  effectiveness  of  the  mechanism  and  ensure  its 
impartiality as the APPF is an independent oversight body. However, the current mechanism is 
the  result  of  a  delicate  balance,  struck  by  the  co-legislators  during  the  negotiations  on  the 
previous  amendment  of  the  EUPP/F  Regulation  in  2018.  Modifying  this  might  jeopardize  the 
timeline  for  adoption  of  the  current  revision,  ahead  of  the  next  elections  to  the  European 
Parliament in 2024.  

Measure  b)  would  mean  that  the  mechanism  can  be  applied  more  broadly.  This  measure  may 
however raise problems with regard to proportionality as the entire EUPP could be de-registered 
due to the activities of a single affiliate. For this reason, this measure is considered less efficient 
than measure a). To mitigate this problem, an additional step could be included in the mechanism 
before  the  APPF’s  final  decision  to  de-register  the  European  political  party  where  the  APPF 
makes recommendations for rectifying the non-compliant behavior. This may however make the 
process lengthier and in the end less effective. 

To further empower the APPF, three measures are considered: 

a)  foreseeing additional resources 

b)  modulating the sanctions regime 

c)  increasing the Authority’s investigative powers 

Measure a) is  a prerequisite for the  empowerment  of the APPF that  currently  functions with  8 
full time staff members. However, the Commission has a limited role in increasing the APPF’s 
budget as the final decision lies with the budgetary authority (Council and European Parliament). 

Measure  b)  foresees  increasing  the  level  of  discretion  of  the  APPF  in  assessing  any  potential 
infringements.  As  various  stakeholders  argue  that  the  inflexibility  of  the  sanctions  regime 
decreases  its  practical  usefulness,  providing  the  APPF  with  the  possibility  to  impose  more 

85  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and 
Social  Committee  and the  Committee of the  Regions,  A Union of Equality: Gender Equality Strategy 2020-2025, 
https://eur-lex.europa.eu/legal-
Available 
COM(2020) 
content/EN/TXT/PDF/?uri=CELEX:52020DC0152&from=EN  

final. 

152 

at: 

47 

 
 
                                                           
gradual sanctions proportionate to the breach, is expected to improve the practical application of 
the sanctions regime. The introduction of a rectification period for some infringements could also 
increase the flexibility of the regime without significantly increasing administrative burden. For 
this reason, the measure is considered to be effective and efficient. 

Measure  c)  would  empower  the  APPF  to  request  more  information  directly  from  donors.  This 
would  improve  the  governance  and  good  administration  of  the  funding  for  EUPP/F,  which 
should result in a decrease of misuse of EU funds, which in turn should improve public trust in 
the spending of EU funds in particular, and the functioning of the EU institutions in general. For 
this reason, the measure is considered to be effective. The measure would also be coherent with 
the  due  diligence  mechanism  proposed  to  tackle  foreign  interference  through  donations  as  the 
Authority would be able to investigate on any irregularities identified through the mechanism. 

To reduce administrative burden, it is  considered to  abolish the double accounting standards. 
The added value of the obligation to use the international accounting standards is very limited, 
since  it  does  not  provide  much  additional  information  that  cannot  be  derived  from  the  other 
documents submitted to the APPF and the European Parliament’s Authorising Officer at the end 
of  the  financial  year86.  Neither  are  they  necessary  to  compare  the  finances  of  the  various 
EUPP/F,  since  the  European  Parliament  provides  detailed  templates  that  allow  for  a  detailed 
comparison  regardless  of  the  financial  seats  of  the  EUPP/F,  while  eight  out  of  ten  EUPPs  are 
based  in  Belgium.  Removing  the  obligation  to  use  the  international  accounting  standards  will 
consequently  reduce  the  regulatory  burden  on  EUPP/F  without  any  negative  impact  on 
transparency.  The  indirect  effect  on  EUPP/F  will  save  resources  that  can  be  allocated  to  their 
core  political  and  policy  work.  For  this  reason,  the  measure  is  considered  to  be  effective, 
efficient and coherent with the other provisions foreseen in the revision. 

To tackle the perceived legal uncertainty a single measure is considered, namely to clarify the 
division of responsibilities between the European Parliament’s authorising officer and the APPF 
in order to make it more efficient. According to the Venice Commission, any oversight agency 
for  political  parties  should  be  independent  and  non-partisan87.  In  addition,  the  Venice 
Commission also finds it essential that the funding of campaign and party finances is overseen 

86 Within six months after the end of the financial year, European political parties and foundations must submit their 
final reports to the Authority, the European Parliament and the National  Contact Point of the Member State. This 
final report consists of: 

- 

- 

- 

the annual financial statement with all revenue and expenditure, assets and liabilities, both in accordance with 
the  national  legislation  of  the  member  state  in  which  they  have  their  seat,  and  in  accordance  with  the 
international accounting standards as defined in Article 2 of Regulation 1606/2002; 

the report of the external auditor on the annual financial statements; 

an overview of the donations and membership contributions during the financial year. 

87 European Commission for Democracy through Law (Venice Commission) & OSCE Office for Democratic 
Institutions and Human Rights (2020), Guidelines on Political Party Regulation (2nd edition), paragraph 61. 
Available at: https://www.venice.coe.int/webforms/documents/default.aspx?pdffile=CDL-AD(2020)032-e 

48 

 
 
                                                           
by  the  same  body,  to  ensure  consistency88.To  align  the  Regulation  with  these  international 
guidelines, it is proposed to clarify the division of their respective responsibilities with a view to 
eliminating overlaps and reducing the regulatory burden on parties. It would also improve legal 
certainty by eliminating  the possibility of diverging interpretations of the  provisions. For these 
reasons, the measure is considered to be effective and efficient. When clarifying the delineation 
of  responsibilities,  coherence  with  the  provisions  in  the  Financial  Regulation  on  the 
responsibilities of Authorising Officers must be ensured. 

To  improve  the  protection  of  the  EU’s  financial  interests,  a  single  measure  is  considered, 
namely  aligning  the  entry  into  force  of  deregistration  decisions  with  Article  297  TFEU.  This 
measure would eliminate the lack of clarity on the eligibility for funding due to the delayed entry 
into force of the Authority’s deregistration decisions and would therefore ensure the appropriate 
protection of the EU’s financial interest. In addition to being effective, the measure would ensure 
coherence with the Treaty on the Functioning of the European Union. In order to give sufficient 
time to the deregistered European political party or foundation to reconvert to a national entity 
before losing its European legal status, one effect of deregistration, i.e. the loss of European legal 
personality  could  be  postponed  to  three  months  following  notification  of  the  decision  to  the 
addressee, thereby ensuring its proportionality. 

Cost, administrative burden reduction and simplification potential of Option 3 

Option  3  included  all  the  cost  identified  under  Option  2,  however  it  puts  in  place  mitigating 
measures to offset them. The abolition of the International Financial Reporting Standards would 
free  substantial  resources  to  comply  with  the  more  complex  financial  reporting  obligation. 
Eliminating overlaps and reducing the regulatory burden on parties by clarifying the division of 
responsibilities  between  the  APPF  and  the  European  Parliament’s  Authorising  Officer,  would 
add  to  the  simplification  potential  of  this  option.  Furthermore,  a  more  streamlined  verification 
mechanism for compliance with EU values would contribute to simplifying the Regulation.  

Stakeholders’ views on policy option 3 

EUPP/Fs  called  for  facilitating  joint  activities  with  their  national  members  so  they  can  better 
fulfil their constitutional mission. They also urged for clarifying the division of responsibilities 
between the APPF and the European Parliament’s Authorising Officer to increase legal certainty. 

The APPF has advocated for a modulated sanctions regime, increasing its investigative powers 
and the alignment of the entry into force of deregistration decisions with Article 297 TFEU. 

88 European Commission for Democracy through Law (Venice Commission) & OSCE Office for Democratic 
Institutions and Human Rights (2020), Guidelines on Political Party Regulation (2nd edition), paragraph 271. 
Available at: https://www.venice.coe.int/webforms/documents/default.aspx?pdffile=CDL-AD(2020)032-e 

49 

 
 
 
 
 
                                                           
European Parliament’s AFCO Committee, in its draft report, called for an increased visibility for 
EUPP/Fs  at  national  level,  including  both  the  visibility  of  party  affiliation  and  the  ability  of 
EUPPs to participate in national referendum campaigns on EU matters. The report also urged for 
ensuring  EUPP/Fs  compliance  with  EU  values.  The  draft  report  also  called  for  clarifying  the 
hybrid status of the APPF. 

OSCE/ODIHR,  in  its  submission  to  the  Commission  and  the  European  Parliament,  also  called 
for  further  empowering  the  APPF  with  regard  to  investigations,  and  for  strengthening  its 
independence.  They  also  called  for  including  gender  representation  in  the  transparency 
requirements.  The  submission  urged  for  increased  transparency  during  the  electoral  campaign 
period. 

All stakeholders consulted agreed on the need to remove the obligation for EUPP/Fs to present 
financial statements in accordance with the International Financial Reporting Standards. 

7. COMPARISON OF THE POLICY OPTION PACKAGES AND PREFERRED OPTION 

7.1. Overview  

Regarding  the  problems  identified,  inaction  from  the  Commission  foreseen  by  the  baseline 
scenario is the least  favourable. Option 2 addresses the most pressing problems identified with 
funding,  and  would  partially  contribute  to  achieving  general  objectives  1  and  3.  More 
specifically,  the  proposed  changes  would  better  ensure  the  financial  viability  of  EUPP/Fs  and 
would  promote  sound  financial  management,  while  also  creating  further  safeguards  against 
foreign  interference.  For  this  reason,  this  option is  considered  more  effective  than  the  baseline 
scenario, as it addresses the difficulty of European political parties and foundations in fulfilling 
the co-financing obligation under Article 17(4). Furthermore it allows for meaningful relation of 
EUPP/Fs with actors outside the EU, while at the same safeguarding against unwanted foreign 
interference.  Option  3  would  be  more  effective  than  the  baseline  scenario  and  more  effective 
than  Option  2,  because  it  would  tackle  all  identified  problems  and  would  fully  contribute  to 
achieving all general objectives. In addition, it is more coherent with other EU policies, such as 
the Commission’s Gender Equality Strategy for 2020-2025 and it also  aligns the provisions on 
deregistration  with  the  Treaty  on  the  Functioning  of  the  European  Union.  This  option  also 
ensures  better  coherence  with  the  legislative  initiative  on  transparency  of  paid  political 
advertising (prepared by DG JUST) thanks to the newly envisaged campaign grant and its more 
stringent  transparency  regime.  This  option  is  also  considered  to  be  efficient  as  the  additional 
administrative burden created, would be offset by the simplification foreseen by the abolition of 
the double accounting standards.  

The baseline scenario would not be favourable for any of the stakeholder groups identified as the 
problems would persist. Option 2 would create a more favourable situation for all stakeholders as 
it would increase the financial viability of EUPP/F, provide the APPF with more information on 
donations, increase transparency for citizens and would ensure better financial management and 
therefore more credibility for European institutions. Option 3 would create the most favourable 
situation for all stakeholders. In addition to better financial viability, EUPP/F would benefit from 
less administrative burden and more legal certainty. The APPF would be further empowered to 
investigate  donations  and  impose  sanctions  if  necessary.  Citizens  would  receive  more 

50 

 
 
information  on  European  matters  and  could  hold  EUPP/F  more  accountable,  and  women 
representation at EU level would be fostered. The credibility of European institutions would be 
higher due to the additional transparency measures under this option. 

Table 5 – Comparison of options for effectiveness, coherence and efficiency 

Baseline scenario 
(Option 1) 

Option 2 

Option 3 

Effectiveness in addressing the identified problems 

Funding provisions 

EU values, 
democracy and 
transparency 

Enforcement and 
administrative burden 

Coherence  

European Democracy 
Action Plan (incl. 
initiative on the 
transparency of paid 
political advertising) 

Conference on the 
Future of Europe and 
European Electoral 
Act 

Commission’s 
Gender Equality 
Strategy 2020-2025 

Charter of 
Fundamental Rights 

Efficiency 

Potential to reduce 
administrative burden 

Simplification 

0 

0 

0 

0 

0 

0 

1 

0 

0 

0.5 

0 

0 

0.5 

0.75 

0 

0 

0 

0 

51 

1 

1 

1 

1 

1 

1 

1 

1 

1 

 
 
 
 
 
 
 
7.2. Preferred option 

Option 3 is the preferred option as it tackles all identified problems in a comprehensive manner 
and ensures maximum positive impact on all stakeholder groups. 

Following the analysis of the alternative measures considered in chapter 6, option 3 should 
include the following measures: 

a)  Funding provisions 

EUPP/F’s difficulty to match EU funds with a 10% and 5% co-financing rate will be addressed 
by introducing an additional category of own resources. This measure will include a ceiling on 
revenues from own resources to mitigate the risk of foreign interference and ensure its coherence 
with  other  measures  addressing  this  issue.  In  addition,  contributions  from  members  from  the 
Council of Europe would be allowed to ensure EUPP/F’s meaningful cooperation with their non-
EU members and affiliates. This measure would be accompanied by a cap on the revenues from 
contributions from non-EU members, and the measure to clarify that EUPP/Fs must ensure that 
their members located outside the EU comply with equivalent values to those listed in Article 2 
of  the  TEU,  in  order  to  limit  the  risk  of  foreign  interference,  while  allowing  for  meaningful 
relations  with  longstanding  partners  and  promoting  democratic  values  beyond  EU’s  borders. 
Finally, a due diligence mechanism will improve the transparency of donations to minimise the 
risk of foreign interference from this source. 

While  the  mix  of  measures  adds  requirements  to  the  accounting  and  reporting  system  for 
EUPP/F,  the  abolition  of  the  international  double  accounting  standards  should  offset  the 
administrative burden created here. In addition, the improved transparency regime and financial 
viability for EUPP/F would justify this choice. 

b)  EU values, democracy and transparency 

Regarding  the  visibility  of  the  link  between  EUPPs  and  national  member  parties,  the  two 
measures  analysed in  chapter 6  (sanctions  for non-compliance and  clear  definition of visibility 
requirements) could actually be complementary. While it was found that clarifying the criteria of 
visibility would alone not be sufficient, with a more adapted and operational sanctions regime it 
could increase the effectiveness of the regulatory framework. 

To ensure the meaningful cooperation between EUPPS and their national affiliates, both the 
possibility for EUPPs to use EU funds in national referendum campaigns on EU issues, and the 
creation  of  a  campaign  grant  for  EUPPs  to  be  used  in  a  fixed  period  ahead  of  the  European 
elections  could  be  granted.  Both  have  the  capacity  to  reinforce  cooperation  between  the 
European and national level and therefore increase the visibility of EUPPs. In addition, the more 
stringent transparency regime would support other measures under the revision to ensure public 
accountability and fighting foreign interference.  

To  promote  gender  equality,  the  Commission  will  retable  its  proposed  measure  at  the  2018 
revision of the Regulation as it is expected to bring better results for gender balance at European 
elections than regulating transparency for the governing bodies of EUPP/F. 

52 

 
 
To  ensure  compliance  with  EU  values,  the  EUPP/F  Regulation  will  be  amended  in  order  to 
clarify that the respect for EU fundamental values should apply to both the EUPP itself, as well 
as  its  member  parties.  While  this  would  not  make  the  verification  mechanism  for  compliance 
with  EU values lighter, it  would still make it more enforceable,  as it would  bring more clarity 
and legal certainty.  . 

c)  Enforcement and administrative burden 

To further empower the APPF, two of the three measures analysed in chapter 6 will be retained. 
The investigative powers of the APPF will be increased so  it can request  information  directly 
from donors. The modulation of the sanctions regime will also increase the level of discretion 
of  the  APPF  in  assessing  any  potential  infringements.  These  measures,  together  with  the 
introduction of a due diligence mechanism under the funding provisions and the clarification of 
responsibilities between the APPF and the European Parliament’s Authorising Officer, will 
enable the APPF to better detect irregularities and sanction them. However, these measures will 
require additional human and financial resources for the APPF. While the Commission does not 
have  the  power  to  address  this  issue  under  the  revision  of  the  Regulation,  it  will  propose 
increasing the APPF’s budget to the budgetary authority. 

To  reduce  the  current  administrative  burden  caused  by  the  use  of  international  double 
accounting standards, the revision will require EUPP/F to  keep their accounts according to  the 
national system of the Member State of registration only. This measure will support all the other 
measures  in  the  revision  by  freeing  human  and  financial  resources  in  EUPP/F  so  they  can 
concentrate on their core activities or on complying with the Regulation in a more effective way. 

The  clarification  of  responsibilities  between  the  APPF  and  the  European  Parliament’s 
Authorising Officer would be retained as it will increase legal certainty for EUPP/F and reduce 
administrative burden both on citizens and EU institutions.  

The entry into force of deregistration decisions will be aligned with Article 297 TFEU as it will 
improve the protection of the financial interests of the EU.  

It  is  expected  that  the  chosen  measures  strike  the  right  balance  between  creating  an  enabling 
legislative  framework  for  EUPP/F  so  they  can  contribute  to  creating  European  political 
awareness  while  ensuring  a  more  stringent  oversight  over  them,  without  creating  significant 
additional administrative burden. 

8. MONITORING AND EVALUATION 

Table  7  below  sets  out  the  monitoring  indicators  per  specific  objective.  The  indicators  will  be 
applied on a 1- or 5-year term to track the progress made towards the achievement of the specific 
objectives set for this revision. 

Table 7 – Monitoring indicators per specific objective 

Specific objectives 

Proposed indicators 

53 

 
 
 
Improved financial viability of European 
political parties and foundations (specific 
objective: adapt the category of own resources 
and meaningful relations with non-EU 
members) 

Transparency of donations (specific objective: 
tightening the transparency regime for 
donations) 

European political parties fulfilling their 
constitutional mission 

Improving visibility of affiliation 

Operational verification mechanism for 
compliance with EU values 

The amount of European political parties and 
foundations that received less EU funds than 
earmarked due to the inability to raise the 10% 
co-financing / year 

Number of irregularities detected by the APPF / 
year 

a)  Effective participation of EUPPs in 

campaigns for national referenda on EU 
matters that took place in a 5 year cycle 

b)  number of cross-EU campaigns that 

European political parties ran in the run-up 
of the European elections 

Proportion of member parties that do not display 
the logo of their European party of affiliation in 
a ‘clear and user-friendly’ manner / year 

Cases opened by the APPF / 5 years 

Improving gender balance 

a)  Proportion of female candidates at European 

elections 

b)  Proportion of female Members of European 

Parliament 

Empowerment of the APPF 

a)  Number of irregularities detected by the 

Reduced administrative burden 

Legal certainty 

Authority / year 

b)  Number of actions taken under the new, 
modulated sanctions regime / year 

Working hours spent on the preparation of the 
annual financial statements and accompanying 
notes / 5 year 

Number of requests for clarifications submitted 
by EUPP/Fs to the APPF and the Authorising 
Officer of the European Parliament / 5 year 

54 

 
 
 
 
Annex I: Procedural Information 

LEAD DG, DECIDE PLANNING/CWP REFERENCES  

This  Impact  Assessment  Report  was  prepared  by  Unit  SG.F.1  ‘Relations  with  the  European 
Parliament  and  Consultative  Committees’  of  the  European  Commission’s  Secretariat-General. 
The Decide Planning reference of the initiative is PLAN/2020/9262. This initiative is part of the 
Commission’s  2021  Work  Programme89.  Furthermore,  parts  of  the  initiative  represent  actions 
proposed by the European Commission to implement the European Democracy Action Plan90. 

ORGANISATION AND TIMING 

Several  services of the Commission with  an interest  in  the initiative have been involved in  the 
development of this analysis.  

Three Inter-Service Steering Group (ISSG) meetings, consisting of representatives from various 
Directorates-General of the Commission, were held in 2020 and 2021.  

The  first  meeting  took  place  on  7  December  2020,  attended  by  DG  BUDG,  CNECT,  COMM, 
JRC, JUST, LS and the Secretariat-General (SG). The second meeting was held on 1 July 2021 
with the same representatives. The third meeting was held in the same format on 22 July 2021. 
This was the last meeting of the ISSG before the submission to the Regulatory Scrutiny Board on 
25 August 2021. The meetings were chaired by SG.F.1. SG.F.1 considered the comments made 
by DGs in the final version of the impact assessment. ISSG Members gave their green light to 
the impact assessment on 29 and 30 July through written procedure. 

CONSULTATION OF THE RSB 

SG.F.1 held an upstream meeting with the members of the Regulatory Scrutiny Board on 17 June 
2021.  The  Impact  Assessment  report  was  examined  by  the  Regulatory  Scrutiny  Board  on  22 
September 2021. The Board gave a positive opinion with reservation. 

Table 1: Changes introduced to the Impact Assessment report 

RSB meeting comments 
The report is not sufficiently clear how this 
initiative links with the one on transparency 
of political advertising.  

Reflection in text 
Section 4.3.1 has been updated to clarify 
the links between the two initiatives. 

89 https://ec.europa.eu/info/publications/2021-commission-work-programme-key-documents_en  

https://ec.europa.eu/info/strategy/priorities-2019-2024/new-push-european-democracy/european-democracy-

90 
action-plan_en 

55 

 
 
                                                           
The report does not sufficiently analyse and 
substantiate with evidence the key problems 
it aims to tackle. It does not sufficiently 
explain the order of magnitude of the 
problems nor the order of importance – if 
any – among the objectives. 

The report does not sufficiently bring out 
feasible alternative options. It does not 
establish clearly the links between problem 
drivers, objectives and options. 

The report does not sufficiently analyse the 
heightened foreign interference risks of 
extending membership of European political 
parties and foundations to all members of the 
Council of Europe. It does not explore 
feasible alternative extensions of EUPP/F 
membership. 

The report now clarifies why the problems 
linked to the funding provisions are 
considered to be the most urgent to tackle. 

The report contains quantified information 
on administrative burden, gender 
(dis)parity and some aspects of funding to 
underpin the problems the initiative tries to 
tackle. The foreword explains the 
methodological limitations that the 
initiative faces due to the specificities of 
the EUPP/F Regulation. 
The report has been updated regarding the 
hierarchy of identified problems, which 
clarifies the choice of options. 

The report has been updated to explain that 
the membership of EUPP/Fs already 
includes countries from the Council of 
Europe, in some cases it goes even beyond 
it (see new Annex VI). Opening up the 
possibility to collect contributions from 
members from Council of Europe countries 
strikes a balance between a complete ban 
and the reality of current membership. A 
complementary ceiling on the proportion 
of contributions from non-EU countries 
vis-à-vis the total amount of contributions 
from members will be introduced to 
mitigate the risk of foreign interference. 

On top of the above listed main recommendations of the RSB, the amended SWD also addresses the 
more detailed set of comments made by the RSB:  

The report should better explain the planned 
interaction with the parallel initiative on  
transparency of political advertising and how 
this might affect the scope of the revision. It  
should consider how to better incorporate 
this initiative in its baseline and policy 
options. 

As indicated above, Section 4.3.1 has been 
updated to clarify the links between the 
two initiatives. The baseline scenario has 
also been updated and now refers to the 
initiative on the transparency of paid 
political advertising. 

56 

 
 
 
 
The report should make better use of 
objective evidence to explain the relative  
importance of the problems and be more 
specific which of the identified problems are 
the most pertinent in the Regulation’s 
underperformance. It should consider 
potential risks for interference or corruption 
in the current financing system. It should 
justify why the lack of gender balance is 
more problematic than other imbalances in 
political representation. It should be clearer 
on how the current funding provisions 
prevent EUPP/Fs from fulfilling  
their tasks. 
The baseline should include the fact that the 
number of EU citizens served by EUPP/Fs 
has reduced by over 10% since Brexit. The 
report should provide a more encompassing 
set of feasible policy options to achieve the 
objectives. It should justify the need for an 
option that does not address all objectives 
and whether all objectives have the same 
importance. It should be clear how the policy 
options each address the objectives and  
what the link is with the problems identified. 
The report should be more systematic in 
comparing all feasible options according to  
the Better Regulation criteria of 
‘effectiveness’, ‘efficiency’ and ‘coherence’, 
as well as according to the impacts of these 
options. The report should explain better 
why impacts in  
the area of fundamental rights are defined 
according to the definition by the Venice  
Commission of the Council of Europe 
instead of the definition of the EU Charter of  
Fundamental Rights. 
The report should analyse better how 
extending the membership of EUPP/Fs to the 
47 members of the Council of Europe could 
create new risks, particularly related to 
unwanted foreign interference from actors 
identified in the report. The report should 
look into alternative definitions of 
membership to establish meaningful relations 
with relevant external actors. 

A hierarchy of problems has been established, 
stating that the problems related to the funding 
provisions are the most urgent to address. The 
report proposes measures to tackle interference 
though donations by strawmen. The report 
creates the link between funding provisions 
and the EUPP/Fs’ ability to fulfil their mission. 
Additional language has been introduced to 
explain ensuring gender equality through the 
EUPP/F Regulation has been on the agenda 
since 2013. The report contains quantitative 
evidence that gender equality has not been 
achieved in the European Parliament. 

The baseline has been updated with a reference 
to Brexit. Further clarification has been added 
regarding the choice of policy options. 

Table 5 has been updated to compare 
options based on effectiveness, coherence 
and efficiency. The report still contains 
reference to the Venice Commission that 
has targeted guidelines for the functioning 
and financing of political parties, which 
serve as best practices in this area. 

The report has been updated to explain that 
the membership of EUPP/Fs already 
includes countries from the Council of 
Europe, in some cases it goes even beyond 
it (see new Annex VI). Opening up the 
possibility to collect contributions from 
members from Council of Europe countries 
strikes a balance between a complete ban 
and the reality of current membership. A 

57 

 
 
complementary ceiling on the proportion 
of contributions from non-EU countries 
vis-à-vis the total amount of contributions 
from members will be introduced to 
mitigate the risk of foreign interference. 
An additional box has been added at the end of 
options 2 and 3 on their costs, administrative 
burden and simplification potential. 

An additional box has been added at the end of 
options 2 and 3 presenting stakeholders’ views 
on them. 

The report should analyse more thoroughly 
the impacts of the different options in  
terms of costs, administrative burden 
reduction and simplification potential. The 
report should be more detailed in explaining 
the type and magnitude of costs of each of 
the options and how these costs compare to 
the options’ expected benefits. 
The report should make better use of all 
feedback received from stakeholders and in  
particular illustrate better how different 
stakeholder groups view the different policy  
options and the associated costs and benefits.  

58 

 
 
 
 
 
Annex II: Stakeholders’ Consultation 

CONSULTATION STRATEGY 

The  consultation  activities  has  fed  into  the  European  Commission’s  revision  of  Regulation 
1141/2014  on  the  statute  and  funding  of  the  EUPP/F.  In  order  to  collect  the  views  of  all 
stakeholders,  the  European  Commission  has  built  its  consultation  strategy  on  the  following 
components:  

  Wide-ranging informal consultations with main stakeholders 

  Feedback to Roadmap/Inception Impact Assessment  

  Open Public Consultation on the revision of the Regulation 

  Open Public Consultation in the framework of the European Democracy Action Plan 

INFORMAL CONSULTATION WITH STAKEHOLDERS 

The Commission conducted a series of informal meetings with selected stakeholders, in order to 
gather  feedback  from  their  experience  with  the  current  regulation,  as  well  as  to  explore  their 
views on the need and opportunities for further revision. The Commission reached out to: 

‒  All European political parties registered with the APPF, 

‒  All European political foundations registered with the APPF, 

‒  The APPF, 

‒  The Directorate General for Finance at the European Parliament. 

Six European political parties and eight European political foundations expressed willingness to 
meet the Commission. 

All  European  political  parties  highlighted  the  administrative  burden,  caused  by  the  double 
accounting standard requirement. Five out of the six consulted parties were specifically against 
the  use  of  the  International  Financial  Reporting  Standards  (IFRS).  Three  out  of  six  parties 
complained of the lack  of coherence between the Authority  and the Authorising Officer of the 
European  Parliament,  with  one  of  them  even  suggesting  delegating  all  control  powers  to  the 
Authority.  Three  out  of  the  six  consulted  parties  complained  that  the  categorization  of  the 
sources  of  revenues  is  too  restrictive  and  advocated  introducing  a  new  category  of  ‘own 
resources’.  All  of  the  consulted  parties  suggested  a  more  nuanced  approach  allowing  for 
contributions/membership  fees  from  members  from  non-EU  countries.  Two  parties  signaled 
difficulties  fulfilling  the  co-financing  obligation.  Five  out  of  the  six  consulted  parties  signaled 
the need to clarify the definition of indirect funding, and pointed to the fact that the current too 
restrictive  interpretation  impeded  the  proper  interaction  with  their  national  affiliates.  One 
consulted party suggested lowering the registration criteria.  

59 

 
 
Seven out  of eight  consulted  European political  foundations  took  a stance  against the use of 
the International Financial Reporting Standards (IFRS). Three foundations signaled issues with 
the  co-financing  rate.  One  of  them  pointed  out  the  difficulties  to  raise  the  matching  5%  co-
financing, and two preferred that the co-financing obligation should be abolished. Six political 
foundations suggested the introduction of a new category of revenues  - ‘own resources’. Three 
foundations suggested the introduction of an intermediate level of appeal for the decisions of the 
Authority.  Three  political  foundations  advocated  allowing  membership  fees  from  non-EU 
countries.  One  political  foundations  stressed  the  need  for  a  more  nuanced  sanctioning  regime. 
They  also  called  for  the  possibility  to  widen  the  scope  of  the  foundations  to  democracy 
education. Three foundations talked about the ambiguity of the  definition of indirect financing. 
They  complained  that  currently  they  cannot  properly  carry  out  their  functions  due  to  the  too 
restrictive interpretation of its definition.  

The Commission consulted the Director of the Authority for the European political  parties 
and foundations and took into consideration his experience in implementing the Regulation.  

The Commission met twice with the team of the European Parliament’s Authorising Officer 
and  discussed  the  possibilities  for  technical  improvements  to  the  financial  provisions  of  the 
Regulation.   

In addition, the Commission met representatives of the Office for Democratic Institutions and 
Human  Rights  of  the  Organisation  for  Security  and  Co-operation 
in  Europe 
(OSCE/ODIHR), the Research Centre for the Study of Parties and Democracy (REPRESENT) 
and  the  European  Democracy  Consulting  for  a  discussion  on  the  revision  of  Regulation 
1141/2014 and the Commission’s upcoming initiative on the transparency of political advertising 
on  10  May  2021.  OSCE/ODIHR  followed  up  the  meeting  with  a  submission  to  the  European 
Commission and to the European Parliament with their preliminary comments on the revision of 
the  Regulation.  The  submission  provides  an  overview  of  the  relevant  provisions  of  the  latest 
OSCE/ODIHR-Venice  Commission  Guidelines  on  Political  Party  Regulation,  outlines  relevant 
practices in OSCE participating States and includes 40 recommendations to improve the existing 
legal framework. 

FEEDBACK TO ROADMAP/INCEPTION IMPACT ASSESSMENT 

The  Commission  received  8  replies  to  the  roadmap/inception  impact  assessment,  including 
feedback from AFCO Member Mr BOESELAGER (Greens/DE, elected from European political 
movement  Volt  Europa),  European  Free  Alliance  and  its  affiliated  Coppieters  foundation.  Mr 
BOESELAGER called for a broad overhaul of Regulation 1141/2014 so EUPPs can fully deliver 
on their role in  creating  a ‘healthy European democracy’. The European Free Alliance and the 
Coppieters  Foundation  recommended  allowing  income  from  its  members  outside  the  EU, 
clarifying  the  definitions  of  contributions  and  donations  and  establishing  additional  sources  of 
income, reviewing the distribution key for budget distribution among European political parties 
and  foundations,  strengthening  European  political  parties’  and  foundations  European  legal 
personality, adding an intermediary step for appeals, and abolishing double accounting standards. 
Citizens argued for more transparency and voiced their concern over the timing of the proposal. 

60 

 
 
OPEN PUBLIC CONSULTATION  

Disclaimer:  the analysis uses aggregated results, as the distribution of responses did not change 
per  type  of  respondent  for  the  majority  of  questions.  Whenever,  it  was  justified  by  diverging 
views,  responses  were  analysed  by  individual  groups.  The  individual  comments  were  left 
anonymous not to cause a bias in the analysis. 

61 

 
 
1.  Approach 

The public consultation took place between 30 March 2021 and 22 June 2021. 

The first part of the questionnaire aimed at getting an insight into the respondents’ profiles and 
feeling of involvement and representation in European political parties. The second section dealt 
with  transparency  and  funding  for  European  political  parties  and  foundations,  as  well  as  with 
sanctions, representation and gender balance. Several open questions invited the respondents to 
elaborate  on  their  opinions,  share  issues  they  encountered  and  provide  suggestions  for 
improvement of the Regulation. 

The questionnaire was translated into all official EU languages and uploaded on the Have Your 
Say platform of the European Commission. 

2.  Responses to the public consultation 

2.1. Respondent profile 

Throughout the consultation period and within the timeframe provided, 19 respondents filled in 
the online questionnaire and two respondents sent their contribution via e-mail. The table below 
shows  the  typology  of  the  participating  stakeholders  for  those  who  responded  the  online 
EUSurvey:  seven  were  EU  citizens,  one  was  a  Member  State,  six  were  non-governmental 
organisations,  one  was  a  research  organization,  and  there  were  one  company  and  three  other 
organisations.  The  two  contributions  received  by  mail  included  one  non-governmental 
organisation and one national authority. 

I am giving my contribution as

Public authority
Other

Non-governmental organisation…

EU citizen
Company/business organisation
Academic/research institution

the 

number 

of 
small 
Given 
respondents,  the  following  answers 
cannot  be  seen  as  a  representative 
sample and have to be analysed with 
caution.  However,  all  viewpoints 
mentioned will be taken into account 
for the review of the Regulation. 

In  terms  of  country  of  origin,  the 
from  various 
respondents  came 
geographical areas of Europe, including one contribution from Georgia, many non-governmental 
organisations representing many or all EU Member States. 

6

0

4

8

2

Country of origin

All  respondents  that  filled  out  the 
questionnaire  were  familiar  with  the 
difference between European political 
parties  and  European  Parliament’s 
political groups. 

4

3

2

1

0

62 

 
 
 
2.2. Representation of European citizens 

10,5%

3. Do you believe European political 
parties fulﬁl their role to represent 
European citizens?

Almost  half  of  the  respondents  believed  that 
European  political  parties  do  not  fulfil  their 
role  in  representing  European  citizens.  When 
elaborating on the underlying reasons for their 
choice,  almost  all  respondents  mentioned  (i) 
the  lack  of  visibility  of  the  parties  to  citizens 
and  (ii)  their  inability  to  mobilize  citizens, 
partly  because  no  individual  membership  is 
possible.  Comments  focussed  on  the  visibility 
the  connection  between  national  and 
of 
European  political  parties. 
addition, 
respondents saw a lack of homogeneity within 
European  political  parties  and  an  affiliation  mostly  with  national  parties  and  topics  rather  than 
with European issues. To some European citizens, the role of the European political parties was 
seen as too vague and the parties invisible. 

No opinion

42,1%

47,4%

In 

Yes

No

Those respondents agreeing European political parties represent citizens stressed the importance 
of  the  role  of  European  political  parties  in  linking  national  parties  with  the  European  level, 
representing  a  large  number  of  citizens  of  various  backgrounds  and  improving  the  role  of 
democracy in EU decision-making. 

if 

respondents 

When  asking 
felt  better 
represented  by  national  or  European  political 
parties  on  a  European  level,  half-selected 
European.  When  specifically  looking  at  the 
sample  of  EU  citizens  responding  to  the 
consultation,  slightly  more  respondents  felt 
represented by the European political party. 

4. Citizens - At the European level, 
do you feel more represented by 
European political parties or 
national parties?

43%

57%

National parties

European parties

63 

 
 
 
 
5. Do you feel involved in European 
politics?

72%  of  all  respondents  felt  involved  in 
European  politics.  This  percentage  was  the 
same amongst EU citizens filling in the survey 
and  went  up  to  84%  amongst  participating 
non-governmental organisations.  

27,8%

72,2%

When  asked  what  they  felt  were  the  most 
critical  issues  to  be  addressed  by  the  revision 
of  the  Regulation,  one  respondent  mentioned 
registration  requirements  and  suggested  to 
replace 
(i) 
lowering  the  number  of  Member  States  in 
which  the  party  needed  to  be  represented  and 
(ii)  defining  ‘presence’  based  on  “citizens’  or 
members  signatures  with  a  minimum  number 
per  Member  State  based  on  their    population”.  The  need  for  transnational  lists  and  for  greater 
publicizing  of  initiatives  in  which  citizens  can  get  involved  in  (such  as  consultations)  were 
raised. 

requirements  by 

the  current 

Yes

No

2.3. Organisation of electoral campaign, visibility and financing 

6. What is your impression of the 
usefulness of Regulation 1141/2014 
on the statute and financing of 
European political parties and 
foundations in terms of organising 
European electoral campaigns?

the 

respondents  considered 

25%  of 
the 
Regulation  very  useful.  Disclosure  of  finances 
was  highlighted  as  one  important  point  to  be 
revised  as  well  as  participation  of  European 
citizens  in  European  political  party  life  and  in 
the foundations.  

12,5%

37,5%

25,0%

37,5%

37.5% of the respondents found the Regulation 
useful.  They  pointed  out  the  importance  of  the 
Regulation, was as well as the need “to increase 
civic  participation 
inclusiveness  of 
and 
elections,  increase  the  voter  turnout,  highlight 
link  between  national  and  European 
the 
political  parties  and  strengthen  the  European 
dimension  of  European  elections”.  This 
included  that  “The  members  of  the  European 
Parliament  should  be  elected  on  the  basis  of  a 
single  electoral  law  that  applies  in  all  EU 
Member  States.  To  increase  the  European 
dimension and enhance the democratic legitimacy of the European elections, transnational lists 
with lead candidates need to be established.” Transparency and improving control over European 
political parties were other points mentioned by respondents.  

Very useful

Not useful

Neutral

Useful

One of the four respondents with a neutral impression (accounting for 37.5% of the respondents) 
also  pointed  towards  the  need  for  clearer  rules  on  electoral  campaign  financing  and  on  the 
financing  of  joint  activities  with  national  political  parties,  and  lack  of  visibility  of  European 

64 

 
 
political parties. They suggested a separate fund for campaign financing and a digital reporting 
system as possible solutions. The other respondents highlighted the need for reform and lack of 
visibility towards citizens.  In addition, respondents asked for “some clarifications on donations 
and  ‘other  own  resources’,  donations  from  a  third  country,  indirect  funding,  different  types  of 
membership, right to appeal”. 

Only one citizen pointed towards the fact that the Regulation is currently not useful, especially as 
regards campaigning, explaining that it “only allows European political parties to spend money 
on European elections campaign. When campaigning, however, European political parties must 
not  finance  national  parties  or  candidates"  campaigns  (prohibition  of  indirect  funding),  thus 
making  difficult  the  organisation  of  any  common  and,  for  the  meaning  of  European  citizens, 
useful activity”.   

79%  of  respondents  believed  that  European  political  parties  are  not  sufficiently  visible  for 
European  citizens.  They  reasoned  that  this  is  partially  related  to  the  issue  of  not  allowing  for 
indirect funding for activities at national level, with a need for clear roles for these joint activities 
and  potentially  a  separate  fund  for  EU  election  campaigns.  They  pointed  towards  the  large 
distance  between  citizens  and  European  political  parties,  but  also  as  regards  the  work  of  the 
European  Commission  and  the  European  Parliament  and  their  roles  in  general.  Suggestions  to 
improve  the  visibility  of  the  European  political  parties  included  better  usage  of  European 
political  party  logos  on  ballots  and  national  political  parties  websites,  endorsement  of  the 
European political parties’ programme by national political parties, discussions of  EU issues at 
national  elections,  separate  European  and  national  elections  and  engagement  with  civil  society 
especially  outside 
the  “Brussels  bubble”. 
Additional  suggestions  included  EU  education 
in school curricula and more media attention to 
European  political  parties  by  for  instance 
hosting  televised  debate  rounds  between  the 
different  European  political  party  group 
leaders.  The  lead  candidate  system  and  the 
organisation  of  primaries  were  mentioned  as  a 
way of increasing visibility. 

8. Do you believe that European 
political parties receive the 
adequate level of funding?

16%

42%

11%

32%

Yes

No, they are underfunded.

No, they are overfunded.

No opinion

funding,  about  42%  of 

respondents 
On 
believed that European political parties receive 
an  adequate  level  of  funding,  while  11% 
believe they are overfunded, and 32% that they 
are underfunded. 

The next question addressed the framework’s ability to counter potential financial abuse. Those 
giving  a  low  ranking  to  the  sufficiency  of  the  Regulation  (with  a  score  of  1,  or  not  very 
sufficient)  stressed  the  importance  of  transparency  and  that  the  economic  sanctions  are 
impossible to apply in practice and do not serve the intended purpose.  

65 

 
 
 
8

4

6

9. On a scale from 0 (not sufficient) to 5 (very 
sufficient), is the current framework, 
provided by Regulation 1141/2014 sufficient 
to counter potential financial abuse by 
European political parties and foundations?

Limitations  to  just  core  activities, 
better 
and 
user-friendliness 
transparency  of  the  data,  and  the 
financial  account  management 
other 
were  mentioned 
respondents (with a score of 2). In 
addition, the need for adapting the 
definitions of ‘donations’, to add a 
category of “‘other own resources’ 
sponsorship, 
which 
activities, 
contributions 
conference  fees,  sales  of  publications”  and  of  ‘indirect  funding’,  to  better  allow  for  training 
activities, were highlighted by several respondents. On the question on whether there might be a 
need for additional measures to counter foreign influence on European political parties, half of 
the respondents responded yes, a quarter no. 

includes 

joint 

by 

1

0

2

5

4

2

3

11.a. On a scale from 0 to 5, do you 
think sufficiently detailed 
information is publicly available on 
the financial accounts of European 
political parties and foundations?

6
4
2
0

not at all
0

not very
1

2

3

4

very
much 5

Opinions  were  very  widespread  on 
the 
question  of  adequate  financial  information  on 
European  political  parties  and  foundations, 
with  the  same  number  of  respondents  stating 
currently provided information is sufficient, as 
those  stating  it  was  not.  In  addition  89.5%  of 
respondents  stated  that  financial  information 
on  EUPPFs  should  be  available  in  an  online 
database  with  none  of 
respondents 
opposing this view. 

the 

Additional  replies  provided  suggestions  on 
how to increase transparency of European political parties and foundations in terms of funding. 
One suggestion included to have stricter rules on identifying donors, and giving more details on 
itemized  spending  and  income.  Overall,  several  respondents  stressed  the  need  for  user-
friendliness of the audit reports and donations website. Putting in place a system that allows for 
crosschecking  financial  data  with  other  public 
data  and  cooperating  with  national  authorities 
were suggested to increase transparency. 

13. a. In the current Regulation 
there is a threshold of EUR 18 000 
per year per donor, but NO overall 
ceiling; For contributions (= 
membership fees) there is a 
ceiling of 40% of the European 
political parties' budget, but NO 
threshold per contribution. 

15,8%

21,1%

63,2%

Yes

No

No opinion

68.4% of respondents were in favour of adapting 
the  level  of  sanctions  in  proportion  to  the  level 
of abuse. 

63.2%  of  the  respondents  were  in  favour  to 
adjust  or  renew  the  ceilings  for  donations  and 
contributions. 21.1% were against this proposal, 
and 15.8% had no opinion on the matter. 

All  respondents  agreed  that  European  political 
foundations  should  be  allowed  to  organise 

66 

 
 
seminars,  conferences,  study  days  or  other  educational  or  promotional  events  in  the  Member 
States to promote themselves, as well as the European Union and its principles and policies. 

One  contribution  suggested  to  either  raise  the  ceiling  or  introduce  an  additional  category  for 
funding, especially in the context of events. 

Open answers were given on question 14: Are there any other suggestions on the financing of 
European political parties and foundations you would like to make? 

Maximum transparency, definitions for donations and indirect funding and cyber-security were 
repeated  issues  for  this  response.  Donations  from  third-countries  were  in  particular  need  for 
review to reflect the nature of the European democratic space but, at the same time, avoid foreign 
interference.    For  protection  against  foreign  interference,  one  national  authority  suggested  that 
the means to identify donors could be improved. 

One  respondent  suggested  the  reduction  of  the  co-financing  rate  for  European  political  parties 
from  10  to  0%  and  a  lowering  of  the  threshold  for  donations.  Another  respondent  suggested 
different  forms  of  party  funding  with  a  mixture  of  lump  sums,  member-based  and  vote-based 
funding  and/or  matching  private  funding.  One  national  authority  strongly  urged  for  capping 
donations and contributions with as minimum revision a cap on donations. 

A system of appeal for decisions made by the Authority on Political Parties and Foundations was 
mentioned  three  times.  One  contribution  proposed  to  create  a  mechanism  of  administrative 
recourse against its decisions, to have an alternative, and less costly alternative, to the Court of 
Justice of the European Union. In addition, it was suggested that the mandate and resources of 
the  Authority  on  Political  Parties  and  Foundations  could  be  reviewed  to  strengthen  its 
investigative and sanctioning powers. 

The contribution of a Member State sent by e-mail was strongly in favour of prohibiting direct or 
indirect  funding  of  European  political  parties  by  foreign  powers  (through  national  parties  or 
private  donations),  and  pointed  to  the  Declaration  of  France,  Lithuania  and  Latvia  on  the 
protection of democracies of 28 September 2020. In addition, it suggested recommendations to 
Member States to ban foreign funding of national political parties and electoral campaigns. 

However,  it  was  pointed  out  from  another  organisation’s  contribution  that  a  prohibition  of 
indirect  funding  should  not  extend  to  participation  in  generalised  training  or  networking 
activities, which would create a barrier for young people to participate and engage in all levels of 
politics. 

In  addition,  other  types  of  funding  should  be  considered  especially  in  the  context  of  projects. 
These  could  include  sponsorships,  project  based  revenues,  or  participant  fees  in  activities.  The 
current  lack  of  clarity  has,  for  instance,  consequences  for  participation  of  members  from  third 
countries in events and their participation fees. 

Finally,  one  more  comment  extended  to  the  question  of  membership  and  to  add  an  additional 
category, such as observer, to avoid members without voting rights falling into the category of 
donations. 

67 

 
 
15. When voting for European 
elections, do you decide on your 
vote based on European or national 
political party preferences?

Two  thirds  of  the  respondents  indicated  that 
they  voted  based  on  their  national  party 
preferences during European elections. 

33,3%

66,7%

National parties

European parties

16. When voting for a national list of 
candidates at European elections, 
do you know which European 
political party they belong to?

Almost three quarters of the respondents knew 
to  which  European  political  party  belonged 
the  candidates  on  the  national  list  that  they 
voted for. 

Yes

No opinion

No

However,  half  of  the  respondents  pointed  out  that,  when  visiting  the  website  of  a  national 
political party, it was not clear to them which European political party they belong to. 

17. When visiting the websites of 
national political parties, is it clear 
to you which European political 
party they belong to (if applicable)?

15,8%

31,6%

52,6%

Yes

No

No opinion

68 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
18. Is there a need to further 
improve the visibility of affiliations 
between national and European 
political parties?

10,5%

89,5%

Yes

No

The  need  for  improved  visibility  of  the  link 
between  the  European  and  the  national  party 
level was underlined by 89.5% of respondents, 
who  agreed  that  greater  visibility  was  needed 
to  show  the  affiliation  between  national  and 
European  political  parties.  Several  suggested 
ensuring that the European political party logo 
was  also  on  the  national  party’s  ballot  sheet, 
their  website,  campaign  and 
information 
material  and  social  platform  and  including 
information  on 
their  respective  European 
political  party  in  their  official  material.  Three 
respondents mentioned trans-national and fully 
European lists in this context. 

One  contribution  mentioned,  in  addition,  that,  in  general,  the  transparency  requirements  for 
online advertising of digital  platforms should be strengthened, including to  make it possible to 
identify the natural or legal person on whose behalf the advertisement is displayed. 

19. Do you think it is necessary to 
improve gender representation in 
European political 
parties/foundations?

42,1%

57,9%

Yes

No

58%  of  the  respondents  felt  that  it  was 
necessary to improve gender representation in 
European  political  parties,  as  opposed  to 
42.1%  of  respondents  that  were  against  this 
view.  

One contribution sent by mail explicitly stated 
the support of gender parity.  

Gender Representation: Which of the following measures 
would you be in favor of?

Make funding for European political parties and
foundations conditional on reaching gender targets

Use targets for gender representation

Establishing mandatory gender quotas in European
political parties and foundations

0,0% 10,0%20,0%30,0%40,0%50,0%60,0%70,0%80,0%90,0%100,0%

69 

 
 
 
 
 
Among  the  proposed  measures  for  improved  gender  representation,  the  use  of  targets  received 
the highest support (40% of the respondents in favour). Conditional funding or mandatory gender 
quotas only reached above 20%. None of the proposed actions were supported by a majority of 
the respondents. 

20. Would you support using 
funding incentives or penalties to 
promote gender balance in 
European political parties, for 
instance in senior leadership 
positions and among endorsed 
candidates?

17,6%

23,5%

58,8%

Yes

No

No opinion

These  stances  are  reflected  in  the  following 
question. Almost 60% of the respondents were 
against  using  funding  incentives  for  creating  a 
gender balance. Their main reasoning included 
a focus on competence, merit and ability rather 
than  on  gender  or  artificial  quotas.  Gender 
balance  was  seen  as  something  that  needed  to 
be grown ‘naturally’ or already in the political 
parties running for EU election. 

Of  those  in  favour  for  financial  incentives, 
several  stressed  this  as  a  temporary  measure 
because  current  change  is  too  slow.  Examples 
of the five EU countries tying their finances to 
gender  balance  were  given.  One  respondent 
stressed that quotas  and  limitations were not  a 
recommendable  path  to  follow  but  rather  the 
support of empowerment  and support schemes 
for female talents. This was also brought up in 

a second response with the suggestion to link public funding to gender-related activities. 

21. Are there any other suggestions on the transparency of gender representation that you 
would like to make? 

Overall,  comments  on  the  topic  were  very  mixed.  When  asked  for  additional  suggestions  on 
transparency of gender representation, one respondent stated concern that this issue was leading 
to  tensions  in  the  relations  between  party  members  and  was  pointing  rather  to  the  topic  of 
discrimination in general. 

One contributing non-governmental organisation suggested that “EuPPs should make public how 
gender  balance  quotas  are  implemented  in  their  parties  in  the  annual  activity  reports  and  their 
websites. EuPP should also be obliged to disclose their membership gender representation. At all 
levels of leadership and at all governmental levels, there needs to be a certain gender balance”. 

21.a. Should the use of software 
tools to assist in monitoring and 
detecting financial irregularities be 
further encouraged?

10,5%

5,3%

84,2%

Yes

No

No opinion

On the question of using software tools to assist 
monitoring 
financial 
irregularities,  84.2%  of  the  respondents  agreed 
that this should be encouraged. 

detecting 

and 

70 

 
 
Almost  half  of  the  respondents  indicated  that  more  data  should  be  made  available  for  this 
purpose. One third of the respondents stated that the available data is sufficient. 

21.b. Are the currently available 
data sufficient or should the 
publication of more data be 
mandated?

Additional  points  made  included  the  need  to 
the  rules  for  the  admission  of 
clarify 
members of European political foundations 
in  order 
the  risks  of  foreign 
to 
interference.   

limit 

21,1%

31,6%

47,4%

More publication of data is needed

Available data is enough

No opinion

71 

 
 
 
 
 
 
 
 
 
 
3.  Annex 

The following provides a breakdown of responses and additional graphs for the questions that 
were not visualized in the main text. 

Organisation size

Small (10 to 49 employees)

Micro (1 to 9 employees)

Medium (50 to 249 employees)

Large (250 or more)

Individual

0

1

2

3

4

5

6

7

8

9

The majority of contributions came from individuals or micro and small companies. Only three 
contributions were from medium and large companies. 

2. Are you familiar with the 
differences between 
European political parties 
and European parliamentary 
groups?

4. At the European level, 
do you feel more 
represented by European 
political parties or national 
parties?

Yes

National parties

European parties

72 

 
 
 
 
 
 
 
10. Do you think that 
additional measures are 
necessary to counter foreign 
(non-EU) influence on 
European political parties 
and foundations?

21,1%

26,3%

52,6%

11.b. Should all financial 
account information for 
European political parties 
and foundations be 
publicly available in an 
online database?

10,5%

0,0%

89,5%

Yes

No

No opinion

Yes

No

No opinion

12. Currently, the Regulation 
foresees a fixed amount of 
sanctions in case of abuse. 
Should the Regulation adapt the 
level of sanctions proportionate 
to the level of abuse?

13.b. Should the European 
political foundations be allowed 
to organise seminars, 
conferences, study days or other 
educational and promotional 
events in the Member states to 
promote themselves and the 
European Union, its principles 
and policies?

68,4%

Yes

No

No opinion

Yes

73 

 
 
 
 
 
Annex III: Who is affected by the initiative and how? 

Overview of benefits – preferred option 
Amount 

Description 
Increased financial viability for 
EUPP/Fs 
Decreased risk of foreign 
interference through 
intermediaries making 
donations 
Meaningful relations with 
likeminded affiliates outside the 
EU 
Improved visibility of affiliation 
between EUPPs and national 
member parties 

n/a 

n/a 

n/a 

n/a 

Greater opportunities for 
EUPP/Fs to fulfil their 
constitutional role and raise 
European political awareness 

n/a 

Promoting gender balance in a 
more explicit manner 

n/a 

Increased respect for EU values  n/a 

Increased compliance with the 
Regulation 

n/a 

Reduced administrative burden  n/a 

More legal certainty 

EU’s financial interests better 
protected and coherence with 
TFEU guaranteed. 

n/a 

n/a 

74 

Comments 
Co-financing obligation would 
be easier to match for EUPP/Fs 
The due diligence mechanism 
would make it easier for the 
APPF to track donors 

Promoting democratic values 
beyond the EU’s borders. 

Raising awareness of the 
existence and activities of 
EUPPs and strengthening the 
link between the national and 
European level 
The possibility to participate in 
campaigns would allow for 
bringing European political 
issues in the forefront of 
European elections and in 
national referenda on European 
issues 
Increased transparency on 
gender balance is expected to 
create peer pressure 
More operational verification 
mechanism should increase  
compliance with EU values  
The modulated sanctions 
regime and the strengthened 
APPF would better address 
infringements. 
The proposal addresses 
inefficiencies. 
Clearer division of labour 
between the APPF and the 
Authorising Officer of the 
European Parliament. 

 
 
 
 
Overview of costs – Preferred option 
EUPP/Fs 

Citizens 

APPF / EP Authorising 
Officer 

n/a 

Recurrent  One off 
More 
complex 
financial 
reporting 
obligations 
n/a 

n/a 

More 
complex 
financial 
reporting 
obligations 
n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

Recurrent 
More 
complex 
verification 
process 

n/a 

More 
complex 
financial 
reporting 
obligations 
n/a 

n/a 

n/a 

Funding 
provisions 

Direct 
costs 

One off 
n/a 

Recurrent  One off 
n/a 

n/a 

Indirect 
costs 
Direct 
costs 

EU values, 
democracy 
and 
transparency 

Indirect 
costs 
Direct 
costs 
Indirect 
costs 

Enforcement 
and 
administrative 
burden 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

75 

 
 
 
 
 
 
 
 
Annex IV: Description of the analytical methods used 

Due to the specificities described in the foreword, notably the limited number of actors involved, 
the impact  assessment used rather  a qualitative  methodology.  No sophisticated statistical  tools, 
such as modelling were used. 

Evidence  was  collected  through  the  consultation  of  main  stakeholders  (interviews  using  open 
questions) and through the 3-month long open public consultation (see Annex II). 

This evidence was complemented by desk based research, carried out both by the Commission 
services and two external studies. Financial data used was publicly available on the website of 
the  European  Parliament  or  on  website  of  the  APPF,  or  taken  over  from  the  European 
Parliament’s  ex-post  evaluation  study  on  the  application  of  the  Regulation91.  The  full 
bibliography of the consulted literature can be found in Annex V. 

91 Anglmayer I. (2021), Statute and funding of European political parties under Regulation 1141/2014  -ex post 
evaluation. Available at: 
https://www.europarl.europa.eu/RegData/etudes/STUD/2021/662646/EPRS_STU(2021)662646_EN.pdf 

76 

 
 
 
 
 
 
 
 
 
 
                                                           
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Van  Hecke  S.  at  al.,  (2018),  Reconnecting  European  Political  Parties  with  European  Union 
Citizens, 
6/2018. 
https://www.idea.int/sites/default/files/publications/reconnecting-european-political-parties-with-
european-union-citizens.pdf   

International 

Discussion 

IDEA 

paper 

Van  Klingeren  M.,  Orozco  M.,  van  Spanje  J.,  De  Vreese  C.  (2015),  Party  Financing  and 
Referendum  Campaigns  in  EU  Member  States,  Study  for  the  AFCO  Committee,  pp.  70-86. 
at: 
Available 
https://www.europarl.europa.eu/RegData/etudes/STUD/2015/519217/IPOL_STU(2015)519217_
EN.pdf  

Wolfs W. (2021), Impact assessment study – Revision of Regulation 1141/2014, unpublished. 

World  Economic  Forum 
http://www3.weforum.org/docs/WEF_GGGR_2021.pdf  

(2021),  Global  Gender  Gap  Report  2021.  Available  at: 

80 

 
 
 
 
Others 

Kosovo (1 
observer 
member) 

Annex VI: Membership in EUPPs 

Affiliated parties from outside the EU 

Political 
parties 

Former EU 
Member 
States 

EFTA 
countries 

Candidate 
countries 

Neighbourhood 
countries 
(Eastern 
Partnership) 

Council of 
Europe 
members 

European 
People’s Party 
(EPP) 

- 

Norway (1 
associated 
and 1 
observer 
member) 
Switzerland 
(1 associated 
member) 

Albania (1 
associated 
member) 
Montenegro 
(1 associated 
member) 
North 
Macedonia (1 
associated 
member) 
Serbia (2 
associated 
members) 

Armenia (2 
observer 
members) 
Belarus (3 
observer 
members) 
Georgia (2 
observer 
members) 
Moldova (3 
observer 
members) 
Ukraine (4 
observer 
members)  

Lebanon (2 
partners) 
Morocco (2 
partners) 

Albania (1 
associated 
member) 
Armenia (2 
observer 
members) 
BiH (4 observer 
members) 
Georgia (2 
observer 
members) 
Moldova (3 
observer 
members) 
Montenegro (1 
associated 
member) 
North 
Macedonia (1 
associated 
member) 
Norway (1 
associated and 
1 observer 
member) 
Serbia (2 
associated 
members) 
Switzerland (1 
associated 
member) 
Ukraine (4 
observer 
members) 

Party of 

UK (2 full 

Iceland (1 

Albania (1 

Armenia (1 

Albania (1 

81 

 
 
 
 
 
 
 
 
 
 
 
 
Affiliated parties from outside the EU 

Political 
parties 

Former EU 
Member 
States 

EFTA 
countries 

Candidate 
countries 

Neighbourhood 
countries 
(Eastern 
Partnership) 

Council of 
Europe 
members 

Others 

European 
Socialists 
(PES) 

members)  associate) 
Norway (1 
full member) 
Switzerland 
(1 associate) 

associate) 
North 
Macedonia (1 
associate) 
Montenegro 
(2 associates) 
Serbia (1 
associate) 
Turkey (2 
associates) 

observer) 
Georgia (1 
observer) 
Moldova (1 
associate) 

Egypt (1 observer) 
Israel (2 
observers)  
Palestine (1 
observer) 
Tunisia (1 
observer) 
Morocco (1 
observer) 

Alliance for 
Liberals and 
Democrats for 
Europe Party 
(ALDE) 

UK (1 full 
and 1 
affiliate 
member) 

Iceland (1 full 
member) 
Norway (1 
full member) 
Switzerland 
(1 full 
member) 

Montenegro 
(1 full 
member) 
North 
Macedonia (1 
full member) 

Gibraltar (1 
affiliate) 
Kosovo (1 
full member) 

associate) 
Andorra (1 
observer) 
BiH (1 
associate) 
Georgia (1 
observer) 
Iceland (1 
associate) 
Moldova (1 
associate) 
Montenegro (2 
associates) 
North 
Macedonia (1 
associate) 
Norway (1 full 
member) 
San Marino (1 
observer) 
Serbia (1 
associate) 
Switzerland (1 
associate) 
Turkey (2 
associates) 
UK (2 full 
members) 
Andorra (1 full 
member) 
Armenia (2 
affiliates) 
Azerbaijan (1 
affiliate) 
BiH (1 full and 1 
affiliate 
member) 
Georgia (2 
affiliates) 
Iceland (1 full 
member) 
Moldova (1 full 
member) 

Armenia (2 
affiliates) 
Azerbaijan (1 
affiliate) 
Belarus (1 
affiliate) 
Georgia (2 
affiliates) 
Moldova (1 full 
member) 
Ukraine (2 full and 
2 affiliate 
members) 

82 

 
 
 
 
 
 
Affiliated parties from outside the EU 

Political 
parties 

Former EU 
Member 
States 

EFTA 
countries 

Candidate 
countries 

Neighbourhood 
countries 
(Eastern 
Partnership) 

Council of 
Europe 
members 

Others 

Montenegro (1 
full member) 
North 
Macedonia (1 
full member) 
Norway (1 full 
member) 
Russia (2 
affiliates – 
Yabloko and 
Partiya 
Narodnoy 
Svobody) 
Switzerland (1 
full member) 
Ukraine (2 full 
and 2 affiliate 
members) 
UK (1 full and 1 
affiliate 
member) 
San Marino (1 
affiliated 
member) 
Serbia (1) 
UK (4) 
Andorra (1 full 
member) 
Azerbaijan (1 
associate 
member) 
Georgia (1 full 
member) 
Moldova (1 full 
member) 
Montenegro (1 
candidate) 
North 
Macedonia (1 
full member) 
Norway (1 full 
member) 

Nagorno 
Karabakh (1) 

Norway (1 
full member) 
Switzerland 
(1 full 
member) 

Serbia (1) 

Albania (1 full 
member) 
Montenegro 
(1 candidate) 
North 
Macedonia (1 
full member) 
Turkey (1 
candidate) 

Azerbaijan (1 
associate 
member) 
Belarus (1 
associate 
member) 
Georgia (1 full 
member) 
Moldova (1 full 
member) 
Ukraine (1 full 
member) 

83 

European 
Democratic 
Party (EDP) 
European Free 
Alliance (EFA) 
European 
Green Party 
(EGP) 

- 

UK (4) 

UK (2 full 
members) 

 
 
 
 
 
 
 
 
 
 
Affiliated parties from outside the EU 

Political 
parties 

Former EU 
Member 
States 

EFTA 
countries 

Candidate 
countries 

Neighbourhood 
countries 
(Eastern 
Partnership) 

Council of 
Europe 
members 

Others 

Russia (1 
associate 
member) 
Turkey (1 
candidate) 
Ukraine (1 full 
member) 
UK (2 full 
members) 
UK (1 member)   

Armenia (1 
associate) 
Georgia (1 full 
member and 1 
associate) 
Macedonia (1 
full member) 
Moldova (1 full 
member and 3 
associate) 
Serbia (1 
associate 
member) 
Switzerland (1 
full member) 
Ukraine (1 full 
member) 
UK (1 full 
member and 1 
associate) 
Albania (1 full 
member) 
Azerbaijan (1 

Australia (1 
full member) 
Canada (1 

Identité et 
Démocratie 
Parti (ID) 
European 
Christian 
Political 
Movement 
(ECPM) 

UK (1 
member)92 

UK (1 full 
member 
and 1 
associate) 

Switzerland 
(1 full 
member) 

Macedonia (1 
full member) 
Serbia (1 
associate 
member) 

Armenia (1 
associate) 
Georgia (1 full 
member and 1 
associate) 
Moldova (1 full 
member and 3 
associate) 
Ukraine (1 full 
member) 

European 
Conservatives 
and 

UK (2 full 
members) 

Iceland (1 full 
member) 

Albania (1 full 
member) 
Macedonia (1 

Azerbaijan (1 full 
member)  
Armenia (1 full 

92 This is according to their webpage. According to the information on the APPF’s website, the ‘For Britain’ is no 
longer member. 

84 

 
 
 
 
 
 
 
                                                           
Affiliated parties from outside the EU 

Political 
parties 

Former EU 
Member 
States 

EFTA 
countries 

Candidate 
countries 

Neighbourhood 
countries 
(Eastern 
Partnership) 

Council of 
Europe 
members 

Others 

Reformists 
Party (ECR)93 

full member) 
Montenegro 
(1 full 
member) 
Serbia (1 full 
member) 

member) 
Belarus (1 full 
member) Georgia 
(1 full member) 
Moldova (1 full 
member) 

Israel (1 full 
member) 
Tunisia (1 full 
member) 

Party of the 
European Left 
(PEL) 

UK (1 full 
member, 1 
partner) 

Switzerland 
(1 full 
member) 

Turkey (1 full 
member) 

Belarus (1 full 
member) 
Moldova (1 full 
member) 

full member) 
Columbia (1 
full member) 
Faroe 
Islands (1 
full member) 
Kenya (1 full 
member) 
Kosovo (1 
full member) 
New 
Zealand (1 
full member) 
Northern 
Cyprus (1 
full member) 
Tanzania (1 
full member) 
USA (1 full 
member) 
Northern 
Cyprus (2 
observers) 

full member)  
Armenia (1 full 
member) 
Georgia (1 full 
member) 
Iceland (1 full 
member) 
Macedonia (1 
full member) 
Moldova (1 full 
member) 
Montenegro (1 
full member) 
Serbia (1 full 
member) 
UK (2 full 
members) 

Moldova (1 full 
member) 
Switzerland (1 
full member) 
Turkey (1 full 
member) 
UK (1 full 
member, 1 
partner) 

93 Table completed based on the latest information on the APPF’s webpage – here all of these parties seem to be 
full members. However, the party’s statute talks about 5 membership categories… ECR’s webpage is also unclear 
about the categories of membership: https://ecrparty.eu/about#parties  

85 

 
 
 
 
 
 
 
 
 
 
 
 
                                                           
***     ***     *** 

86