Transparency of EU funding granted to NGOs : despite progress, the overview is still not reliable. Special report No 11, 2025.
Date: 2025-04-10
Institutions: European Court of Auditors
Subjects: EU aid, EU programme, administrative transparency, compliance audit, distribution of EU funding, financial audit, financial transparency, implementation of the budget, non-governmental organisation, non-profit organisation, performance audit, report

SPECIAL REPORT 11/2025 

EN 

Transparency of EU funding granted to NGOs 
Despite progress, the overview is still not reliable 

 
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Contents 

Paragraph 

 01-15 | Main messages

01-06  |  Why this area is important

07-15  |  What we found and recommend

 16-64 | A closer look at our observations

16-43  |  Despite improvements, transparency of EU funding granted to
NGOs is undermined by the lack of a reliable overview 

17-24  |  The identification and registration of entities as NGOs are not always

consistent and reliable 

25-38  |  Despite a more streamlined granting process, issues with the completeness

and accuracy of data remain 

39-43  |  The lack of a reliable overview of EU spending on NGOs hampers useful

analysis 

44-64  |  Managers of EU funds verify recipients’ transparency, but do not
proactively check whether they comply with EU values 

45-51  |  Calls for proposals in our sample were transparent

52-57  |  Respect of EU values is not proactively verified

58-64  |  Transparency practices vary widely in our sample, with larger NGOs

performing better 

Annexes 

Annex I – About the audit 

EU support for NGOs and the applicable transparency requirements 

EU funding granted to NGOs 

Annex II – EU legal basis for transparency requirements for selected EU 

programmes 

3 

Annex III – Basic information on entities in our sample 

Annex IV – Description of the methodology we used to assess NGOs’ 

voluntary transparency 

Annex V – Results of our assessment of NGOs’ voluntary transparency 

Abbreviations 

Glossary 

The Commission’s replies 

Timeline 

Audit team 

 
 
 
 
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01 

Main messages 

Why this area is important 

01 The Treaty on European Union emphasises the importance of transparent and ongoing 

dialogue with civil society organisations, of which non-governmental organisations (NGOs) 
are a subset. NGOs are diverse in terms of size or areas of activity, working mostly on social 
inclusion, equal opportunities, gender equality, climate and environmental protection, and 
research and innovation. 

02 Public transparency is about providing citizens with proper information so that they can 

hold public decision-makers to account. This means that fulfilling transparency 
requirements includes knowing not only to whom, why and for what purpose EU funds 
were granted, but also how they were used, the amounts involved, and whether fund 
recipients respect EU values (see Figure 1). 

 
 
Figure 1 | Public transparency is about providing information for 
accountability 

Public transparency 

5 

“Who”
Information on NGOs’ legal 
and financial independence, 
and their activities, e.g. if they 
respect EU values

“How much” 
Complete, reliable, easily 
accessible, understandable 
and reusable information on 
“how much” EU funding was 
granted to NGOs, including 
through different NGOs 
and/or other entities in the 
case of sub-granting or 
consortia

“Why” and for “what”
A clear and transparent 
selection process, providing 
information on “why” NGOs 
receive money, and for “what” 
purpose

”How “ 
Clearly know “how” EU funds 
were spent by monitoring 
compliance with reporting 
requirements

Source: ECA, based on international organisations’ standards on public transparency (the Organisation for 
Economic Co-operation and Development, the International Monetary Fund and Transparency International). 

03 The Treaty lays down the values of human dignity, freedom, democracy, equality, the rule 
of law and human rights, including rights of persons belonging to minorities, as the 
foundation of the EU. Respecting these EU values is a contractual obligation for recipients – 
including NGOs – in order to receive EU funds. 

04 In general, the EU budget finances activities irrespective of whether they are carried out by 
NGOs or other types of entity. NGOs receive most of their EU funding through grants and 
must adhere to the transparency requirements that apply to all recipients. During the 
2021-2023 period covered by our audit (see Figure 2), the Commission reported 
committing €4.8 billion to NGOs in internal policies. Furthermore, for the European Social 
Fund Plus (ESF+) and the Asylum, Migration and Integration Fund (AMIF), the two funds 
under shared management that are included in the scope of our audit, member state 
authorities reported granting €2.6 billion. For these policies, EU funding commitments 
totalled €7.4 billion. 

 
 
 
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Figure 2 | NGOs received less than 4 % of funding from the EU budget for 
the selected internal policies during the 2021-2023 period 

From the Commission (direct/indirect management)

4.8 Funding granted to NGOs

0.3 NGO operating grants

From member states (shared management)

(billion euros)

94.4  All funding

95.1 All ESF+ funding

2.2 ESF+ funding granted to NGOs

5.5  All AMIF funding

0.4 AMIF funding granted to NGOs

Source: ECA, based on the Financial Transparency System and financial data received from managing 
authorities. 

05 Public interest in improving transparency requirements for EU-funded NGOs has increased 
since the “Qatargate” scandal in 2022. The European Parliament resolution adopted in 
January 2024 called for greater transparency and accountability of EU funding granted to 
recipients, including NGOs. With the aim of increasing the transparency of NGO recipients 
of EU funds, the EU Financial Regulation as updated on 23 September 2024 defined an 
NGO as “a voluntary, independent from government, non-profit organisation, which is not 
a political party or a trade union”. 

06 Following our 2018 report on the transparency of EU funding granted to NGOs, with a 
focus on external action, this audit assesses the transparency of EU funding granted to 
NGOs in EU internal policies, specifically examining whether the Commission, its 
implementing partners and member states: 

—  collected and disclosed reliable data on EU funding granted to NGOs; and 

—  appropriately assessed key transparency requirements for NGOs in receipt of EU 

funds, as well as whether they respect EU values. 

For more background information, and details of the audit scope and approach, see 
Annex I. 

 
 
 
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What we found and recommend 

07 Overall, our audit shows that EU funding granted to NGOs in internal policies was not 

sufficiently transparent, although we have observed improvements in this regard since our 
previous special report in 2018. In general, the Commission and other implementing 
bodies verify key transparency requirements (see Annex II) before granting EU funds to 
NGOs, but do not proactively check compliance with EU values. 

08 Despite improvements, such as the Commission’s introduction of a common registration 

system for grant applicants, the transparency of EU funding granted to NGOs is 
undermined by the lack of a reliable overview. We observed that what qualifies as an NGO 
was not always understood in the same way by the Commission, its implementing 
partners, and member state authorities. The listing of NGOs in the Financial Transparency 
System, which is the main transparency tool for first-level recipients of EU funds under 
direct and indirect management, is based on self-declaration. The Commission continues 
to check some elements of an NGO’s classification, i.e. whether an NGO is a private entity 
and non-profit. However, important aspects of an NGO status were not checked, such as a 
government influence through its representatives in governance bodies and whether self-
declared NGOs are not pursuing their members’ commercial interests. This approach 
contributes to some entities having an incorrect NGO classification in the Financial 
Transparency System. The 2024 Financial Regulation definition of an NGO is not sufficient 
in itself to address this issue, as some operational aspects remain open to interpretation 
(see paragraphs 17 to 24). 

Recommendation 1 

Improve guidance on classifying non-governmental organisations 

The Commission should facilitate consistent understanding and application of the 
definition of non-governmental organisations across all management modes, by 
issuing guidance to clarify the criteria for: 

(a)  “independence from government” beyond a prerequisite of being a private 

entity; and 

(b)  NGO status when an entity is pursuing its members’ commercial interests. 

Target implementation date: 2025 

09 We observed that the Commission improved the way it collected and managed 

information on EU funding granted to recipients, including NGOs, and the way it disclosed 
that information through the Financial Transparency System. Nevertheless, we found 

 
 
 
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weaknesses affecting the relevance, comparability and timeliness of this information, such 
as incorrect classification of recipients as NGOs, incomplete coverage of all recipients of EU 
funds, and infrequent updates. Incomplete coverage of all recipients is largely due to the 
Commission’s publication, in line with the Financial Regulation, of commitments made to 
first-level recipients only (see paragraphs 25 to 34). 

10 Member state authorities do not monitor and report on EU funding granted to NGOs; as 
this information is not required by EU law, it is not readily available. On their websites, 
member state authorities disclose to the public only information on amounts that have 
been committed (see paragraphs 35 to 38). The updated Financial Regulation requires 
that, as from 2028, information on EU funds granted to recipients, including NGOs, under 
shared management programmes, should be published on a centralised website, together 
with information on direct and indirect management modes. This new requirement is 
expected to improve the completeness of information on recipients of EU funds, but 
cannot ensure the full comparability of financial data from all management modes as there 
is no requirement to report payments received under shared management, for example 
(see paragraph 39). 

11 Overall, we found that there is no reliable overview of EU funding granted to NGOs. This 
information is published on multiple systems, websites and databases, resulting in a 
fragmented approach, which hampers transparency and limits insights into the role of 
NGOs in EU policy-making and programme implementation. Moreover, without this 
information, it is more difficult to assess whether EU funds are overly concentrated on a 
small number of NGOs and whether such concentration aligns with EU policy objectives 
(paragraphs 40 to 43). 

Recommendation 2 

Improve the quality of information on EU spending in the Financial 
Transparency System 

To ensure that the information disclosed in the Financial Transparency System is 
comparable and useful, the Commission should improve its completeness and 
timeliness by increasing the frequency of updates and covering second-level recipients 
of EU funds for direct and indirect management. 

Target implementation date: 2029. 

12 We also assessed whether the managers of EU funds appropriately checked NGOs’ 

compliance with key legislative transparency requirements (see Annex II). We observed 

 
 
 
 
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that, overall, the transparency requirements of the Financial Regulation and sectoral 
legislation for accessing EU funds were adhered to. The Commission and other 
implementing bodies appropriately published calls for proposals, making them accessible 
to interested parties and transparent to the public (see paragraphs 45 to 49). 

13 NGOs can receive grants to support their operating costs. Consequently, these operating 
grants finance NGOs’ various activities which may include advocacy. We found that the 
Commission did not clearly disclose to the public the information it held on NGOs’ 
advocacy activities that were financed through this type of grants. During our audit, the 
Commission issued guidance that grant agreements should not require recipients to lobby 
EU institutions. The implementation of this guidance was outside the scope of our audit 
(see paragraphs 50 to 51). 

14 The recipients of EU funds, including NGOs, are required to respect EU values. We found 
that the managers of EU funds do not proactively search for potential breaches of EU 
values. Instead, they mainly rely on self-declarations and do not use other available data 
sources. For example, checks on financial dependency and funding sources, which can 
provide useful information about ‘who stands behind an NGO’, were not carried out. 
Starting in mid-2023, the Commission provided awareness activities and guidance for its 
staff on the obligation for recipients to respect EU values. However, there is no guidance on 
how to assess potential cases of non-compliance with the obligation to respect EU values 
(see paragraphs 52 to 57). 

Recommendation 3 

Strengthen verification of compliance with EU values 

The Commission should explore the feasibility of developing the current systems to 
include risk-based verification of recipients’ (including NGOs’) compliance with EU 
values, in order to detect potential breaches. 

Target implementation date: 2028. 

15 Our assessment of practices in a sample of NGOs benefiting from EU funds showed that 

they differed significantly in how transparent they were towards the public. Administrative 
capacity was an obvious factor affecting their level of transparency. The presence of 
accreditation arrangements which are not linked to reporting obligations related to EU 
funds also enhanced NGOs’ transparency (see paragraphs 58 to 64). 

 
 
 
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02 

A closer look  
at our observations 

Despite improvements, transparency of EU 
funding granted to NGOs is undermined by the 
lack of a reliable overview 

16 In line with the international definition of public transparency (see Annex I, paragraph 06, 
and Figure 1), we would expect the Commission, the member state authorities and 
implementing partners to provide the public with reliable and timely information on the 
amounts of EU funds granted to NGOs and for what purpose. To ensure this transparency, 
they should: 

—  use the same criteria to allow for consistency in determining what an NGO1 actually 
is. It is important to understand exactly to “whom” EU funds are awarded, and to 
facilitate consistent and reliable reporting on EU funding granted to NGOs; 

—  use IT systems that collect reliable, complete, and up-to-date financial data; and 

—  publish information on EU funding granted to NGOs in a machine-readable format 

that allows further data analysis yielding more robust information, such as 
consolidated data on funds spent from all EU programmes per recipient. 

1  Regulation 2024/2509, recital 8. 

 
 
 
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The identification and registration of entities as NGOs are not 
always consistent and reliable 

17 In January 2022, the Commission provided a definition of an NGO when it updated its 

publicly available guideline on how to legally validate entities participating in EU funding or 
tenders under direct and indirect management. In addition to being a non-profit 
organisation, an NGO must be independent from government. However, in their calls for 
proposals to award operating grants, the Commission departments and agencies defined 
criteria for NGOs differently. As a result, an organisation considered to be an NGO in one 
competition for grants may be excluded in another (see Box 1). 

Box 1 

Commission departments and agencies use different criteria to 
differentiate NGOs from other types of entity 

The calls for proposals for grants financed from the Erasmus+, ESF+ and LIFE 
programmes in the 2021-2023 period were managed, respectively, by the European 
Education and Culture Executive Agency (EACEA), the Directorate-General for 
Employment, Social Affairs and Inclusion (DG EMPL) and the European Climate, 
Infrastructure and Environment Executive Agency (CINEA). The calls specified that 
NGOs must be not only independent from government but also non-profit. However, 
these bodies stipulated further criteria: 

—  EACEA: independent of political parties and commercial organisations; 

—  DG EMPL: independent of industry, commercial and business or other conflicting 

interests; and 

—  CINEA: independent of other public authorities, political parties and commercial 

interest. 

18 We asked the member states’ managing authorities for the ESF+ and AMIF whether their 
national legislation included a definition of an NGO. About a quarter of EU member states 
reported having legal definitions of an NGO in their national legislation, albeit often with a 
different scope. Box 2 gives examples of national NGO definitions. 

 
 
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Box 2 

Examples of NGO definitions in EU member states 

In Greece, organisations known as NGOs are voluntary, not-for-profit, and have a 
public-benefit purpose. They are independent from the State, local governments, 
public- and private-law bodies, commercial and professional organisations and 
associations, trade unions, and political organisations and parties. This independence 
is demonstrated by the fact that no legal person belonging to the public sector may 
participate in the organisation’s management bodies and general meetings. 

In Lithuania, NGOs must be independent from the State or lower-level self-governing 
institutions and bodies, act for the benefit of the public or a group thereof, and cannot 
have political or religious aims. In addition, organisations are not classified as NGOs if 
they are controlled by: 

— 

religious communities; 

—  municipalities; or 

—  other entities which are not NGOs themselves and hold more than 30 % of votes 

or participation in the organisations’ general assembly. 

In Poland, NGOs are organisations which are non-profit and are not enterprises 
(including public enterprises), research institutions, banks or part of the public finance 
sector. Political parties and their foundations, trade unions, and employers’ and 
employees’ associations cannot be NGOs, either. 

19 Figure 3 gives an overview of which member states have their own legal definition of 

NGOs. 

 
 
Figure 3 | A few member states have their own legal NGO definitions 

13 

Member state 
has definition of NGOs

Yes

No

Source: ECA, based on replies to the questionnaires we sent to the managing authorities. 

20 In September 2024, the EU’s co-legislators adopted the Commission’s proposal to include a 
definition of an NGO in the updated EU Financial Regulation (Annex I, paragraph 03). The 
aim of this definition is to enhance transparency about recipients of EU funds which are 
NGOs2. The definition covers the most essential criteria for NGOs, i.e. that they should be 
independent from government and non-profit. The organisations considered to be NGOs 
in the light of the EU definition may not always be NGOs in their member states. 

21 For the purposes of direct and indirect management, the Commission records recipients as 
NGOs in its central accounting system, based on self-declaration after validating an entity 
as non-profit and private, which is then disclosed in the Financial Transparency 
System (FTS); see Annex I, paragraph 08. The Commission considers NGOs to be 
independent from government if they are not public bodies. This interpretation does not 
consider an important aspect of an NGO’s independence, namely controlling participation 
by governments in NGO governance bodies. In addition, the Commission checks the 
applicants’ non-profit status based on documents they submit, confirming their legal form 
or purpose, or whether they have a legal or statutory obligation not to distribute profits to 

2  Regulation 2024/2509, recital 8. 

 
 
 
 
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shareholders or individual members3. However, the Commission does not check whether 
NGOs pursue their members’ commercial interests (see Box 3). 

Box 3 

Example of an entity being registered as an NGO despite pursuing its 
members’ commercial interest 

In our sample, we identified an entity which was marked as an NGO in the FTS. The 
entity is a research organisation which, aside from research and innovation activities, 
provides advanced technical services for the textile industry and integral services for 
the cosmetics industry. It employs more than 250 staff and has offices worldwide. 

The entity is a private, non-profit organisation, but it clearly pursues the commercial 
interests of its mostly profit-oriented members, and so should not had been 
considered as an NGO. In response to our survey, it also stated that it is not an NGO. 

22 Although the Commission checks the main aspects of the NGO definition, these checks are 
not complete. We found that more than 90 % (over 70 000) of entities to which payments 
were made in the accounting system in the 2021-2023 period were not categorised as an 
NGO or non-NGO, as this field was left blank (optional for recipients). We believe this 
increases the risk of recipients being categorised incorrectly for reporting purposes, 
directly impacting the quality of the information available to the public through the FTS. 

23 Based on our observations above, we consider that the EU definition of an NGO is not 
sufficient in itself to fully address the risk of incorrect classification of NGOs, as the 
following aspects of their practical application are not sufficiently clear: 

(a)  rules on what should be understood by “independent from government”, for example 
by setting a threshold for governmental control over organisations’ governance 
bodies; 

(b)  rules on how NGO status is to be verified in the event that NGOs pursue their 

members’ commercial interests; and 

(c) 

the entities excluded from the definition of an NGO. The current NGO definition 
excludes political parties and trade unions, but not other similar types of organisation 
so as to ensure equal treatment (e.g. foundations and associations established by 
political parties and trade unions as de facto integral parts thereof; employers’ 

3  Rules for Legal Entity Validation, LEAR Appointment and Financial Capacity Assessment, 

Commission, 1 February 2024. 

 
 
 
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associations by analogy with trade unions, or the entity types being independent 
from governments beyond the formal status of private body). 

24 Such insufficient clarity provides room for a broad interpretation of the definition of an 

NGO by organisations that implement the EU budget. Consequently, the way the definition 
is applied to EU funding may not be consistent across all EU programmes and management 
modes. 

Despite a more streamlined granting process, issues with the 
completeness and accuracy of data remain 

Direct management 

25 In our previous special report on the transparency of EU funding to NGOs with a focus on 
external action4, we found that the Commission had varying granularity of information on 
the funding provided to recipients under direct management programmes, due to the 
different systems its departments used. However, the Commission’s system for the 
granting process has since become more uniform, mainly due to the rollout of the SEDIA 
project in 2017 which allows for digital communication and exchanges with applicants. This 
means that the same documents from recipients/applicants are brought together by the 
Commission’s IT system – the eGrants suite – when managing direct grants. We confirmed 
this improvement, as 29 out of 30 NGOs from our direct management sample were 
registered in eGrants, and included the same type of information on recipients (e.g. 
documents identifying recipients, financial statements, and grant applications and 
evaluations). 

26 We cross-checked the financial data that were publicly available in the FTS (see Annex I, 

paragraph 08) against the information kept in eGrants and other systems and sources, such 
as the EU Transparency Register (EUTR), in order to verify their reliability. We found several 
weaknesses which impact the accuracy of the Commission’s FTS in relation to EU funding 
to NGOs under direct management: 

—  eight entities (over 25 % of our sample) were incorrectly marked as NGOs: Three of 
these entities included organisations dependent on government, such as a public-
private partnership (a collaborative agreement between government entities and 
private-sector companies) or a national research institute (see Box 4). The fourth one 
represented its members’ commercial interests which were not compatible with 
being an NGO. Three additional recipients did not consider themselves as NGOs in 

4  Special report 35/2018, paragraphs 41-42. 

 
 
 
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their responses to our survey, and another was registered as a non-NGO on the 
Commission’s Funding and Tenders (F&T) portal; 

Box 4 

Example of a research institute being marked as an NGO even though it 
is dependent on government 

A national research institute pursues international research on energy and the 
bioeconomy. It ranks among the largest research institutes in Europe. 

The institute is registered as a private, non-profit limited liability company. When 
applying for an EU grant, it self-declared as an NGO. However, the institute’s 
operations are closely tied to government. The State provided a guarantee for the 
institute to secure its financial capacity, and its highest governance body is exclusively 
composed of representatives of the member state authorities. 

—  entities incorrectly marked as non-NGOs: When cross-checking the FTS database 

against other registers at EU level, i.e. the EUTR and the information we received from 
the national managing authorities for ESF+ and AMIF, we found 70 entities that were 
not marked in the Commission’s accounting system as NGOs, despite indications from 
the other registers that they were. 

27 In line with the requirements of the Financial Regulation, the Commission discloses the 
information on first-level transactions to individual recipients. Grant agreements may 
provide for the possibility of some of the EU funds being granted to another entity. In our 
sample, we identified one recipient receiving funding from the Citizens, Equality, Rights 
and Values (CERV) programme which regranted some amounts to another entity. 
According to the Commission, for the CERV programme in 2022 and 2023, the “regranted” 
amounts were €3.9 million and €3.7 million, respectively. These amounts represent 2 % of 
committed CERV funding for these years. 

28 We also found differences between amounts disclosed in the FTS and what was 

contractually agreed between the Commission and its recipients. In one of the grant 
agreements in which an NGO in our sample participated, the Commission contractually 
committed €549 million, but the FTS showed only €317 million. The Commission noted 
that it only disclosed cumulative annual budgetary commitments, meaning that the full 
grant amount is set to appear in the FTS in the last year of the contract. However, this was 
not always the case for the Commission’s other commitments, where it disclosed entire 
amounts agreed in the contracts as soon as they took effect. 

 
 
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29 The Commission updates its FTS annually, by June each year, as required by the Financial 
Regulation. This means that the information on amounts committed per year-end is 
disclosed with a delay; this may be up to one and a half years, as amounts committed in 
January of year n will be disclosed only by June of year n+1. Furthermore, the Commission 
does not update the financial information in the FTS following amendments to grant 
agreements in its annual updates. In our direct management sample, we identified three 
cases (10 % of our sample) where the information in the FTS was not up-to-date for this 
reason. In two cases, the financial information following amendments to grant agreements 
was not disclosed in the FTS and, in the third case, the commitment from a signed grant 
agreement was disclosed with a one-year delay. 

Indirect management 

30 For indirect management, for Erasmus+ and the European Solidarity Corps (ESC), the 

Commission established the Project Management Module (PMM), a web-based IT system 
where implementing partners report information. The PMM covers a project’s full lifecycle, 
from application to final payments. The Commission monitors the information, extracts 
data to perform further analysis, and then uses the information in its annual activity 
reports and annexes. Through the PMM, the Commission has access to individual project 
documentation. 

31 Despite improvements in the data recording system for these two specific programmes, we 
found that the public information about recipients of EU funds from indirect management 
programmes in the FTS was incomplete. This is because the FTS discloses financial 
information only about first-level transactions, i.e. between the Commission and its 
implementing partners. The latter are required to publish information on their websites 
about EU funding they have distributed to final recipients, some of which are NGOs. Unlike 
in the case of shared management, they are not required to publicly disclose this 
information in a machine-readable format which would allow consolidation and big data 
analysis. 

32 In the 2021-2023 period, for Erasmus+ and the ESC, the Commission committed 

€1 363 million to its implementing partners, and this amount was marked in the FTS as 
going to NGOs. However, the information from the Commission’s PMM for the three 
selected implementing partners shows that only 10 % of the amounts they received was 
transferred to NGOs, while 90 % went to other types of recipients. The Commission also 
makes payments to non-NGO implementing partners which may subsequently transfer the 
funds to NGOs. The Commission did not monitor the amounts transferred in this way to 
NGOs. 

 
 
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33 The three implementing partners we selected for further examination followed different 
procedures to disclose information on the EU funding they manage. Table 1 shows the 
information that they provided about grants awarded. 

Table 1 | Differences in how the selected implementing partners disclose 
information on the EU funding they manage 

Information 

In Germany 

In Poland 

In Slovenia 

Application number 

Erasmus code 

Applicant name 

Location (city) 

Project title 

Budget 

Points awarded 

Outcome of 
assessment 

Format 

Order 

Source: ECA. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Not machine-
readable 

Year and action 

Not machine-
readable 

Year, action and 
budget range 

Not machine-
readable 

Year and action 

34 According to the Commission, Erasmus+ and the ESC programmes together have 54 

implementing partners, which are located in the EU and third countries associated with the 
programmes. This means that the information on their final recipients is scattered across 
many information sources using different formats. Furthermore, the implementing 
partners do not distinguish between types of final recipient, so it is not possible to obtain 
reliable consolidated information about the EU funds granted to NGOs under this 
management mode. 

Shared management 

35 As regards shared management, while national authorities are required to disclose 

information on the amount of EU funds they have committed to recipients, they are not 
required to record the share for NGOs. This means that information on EU funding for 
NGOs under shared management is not readily available. In addition, member states have 
different criteria – or none at all – for identifying EU recipients as NGOs, leading to data 
that is neither homogeneous nor complete (see paragraphs 18 and 19). 

 
 
 
 
 
 
 
 
 
 
 
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36 We also found that the national databases in the three member states we visited list 

neither co-recipients in the case of consortia nor the amounts paid to recipients, as only 
committed amounts are disclosed. However, these databases are more frequently updated 
than the Commission’s FTS, and they also disclose information about amendments to grant 
agreements. 

37 As managing authorities are not required to publish information specifically on EU funding 
granted to NGOs, we asked all managing authorities in the member states for the selected 
programmes (AMIF and ESF+) to provide information about amounts of EU funding 
committed to NGOs. We received this information from all but Germany and France; 
see Figure 4. 

—  The German authorities stated that Germany does not have any specific legislation, 
registration or identification numbers for NGOs. Moreover, there is no separate 
allocation of ESF+/AMIF funding to NGOs in the 2021-2027 multiannual financial 
framework (MFF). 

—  The French authorities produced no financial data, as France has no legal definition 

for NGOs that operate in the country. 

 
 
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Figure 4 | Member states show significant differences in the amounts 
granted to NGOs during the 2021-2023 period from ESF+ and AMIF 

Member state

ESF+

AMIF

(million euros)

Spain

Germany *

France *

Sweden

Czechia

Lithuania

Austria

Greece

Estonia

Ireland

Croatia

Finland

Bulgaria

Belgium

Hungary

Luxembourg

Denmark

Romania

Latvia

682 

392 

334 

230 

252 

112 

47 

48 

34 

23 

10 

11 

3 

1 

2 

2 

54 

158 

46 

49 

5 

30 

76 

3 

6 

6 

1 

0.1 

2 

* For Germany and France, we analysed the information on recipients of the AMIF and ESF+ funds as published by the 
national (or “domestic” if also regional) authorities in order to estimate the amounts contracted to NGOs. 
** Italy, Cyprus, Malta, Netherlands, Poland, Portugal, Slovenia, and Slovakia reported no amounts contracted. 

Source: ECA, based on the financial data received from the national managing authorities. 

38 For our sample, we reconciled the amounts that the managing authorities provided with 

the underlying documents, i.e. grant decisions, and found no discrepancies. 

The lack of a reliable overview of EU spending on NGOs 
hampers useful analysis 

39 The previous paragraphs show that there is no comprehensive and reliable overview by 
policy area and all management modes for the EU funding committed or paid to NGOs. 
The updated Financial Regulation requires the Commission to have a single website which 
consolidates, centralises and publishes financial information on EU spending under all 

 
 
 
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three management modes5. This should be available from the post-2027 MFF. Until this 
requirement is met, and provided NGOs are correctly registered, obtaining reliable 
information on all EU funds that NGOs have received is practically impossible. 

40 Furthermore, the absence of a common identifier makes it more difficult to cross-check 
and consolidate financial data on EU spending. We have already made an observation on 
the lack of a common identifier in our previous special report on blacklisting. We reported 
that this causes problems for identifying counterparties and matching their records against 
the various registers. 

41 A reliable overview of EU funding granted to NGOs would not only increase the 

transparency of EU spending, but would also make it possible to analyse the concentration 
of EU funds. Such analysis could be useful, for example, for the purposes of mitigating the 
risk that over-concentration of EU funds in a small number of NGOs prevents wider 
participation in EU policy-making or programme implementation. 

42 Notwithstanding the limitations of the financial data available, our analysis shows that a 
large part of EU funding granted to NGOs under direct management went to a small 
number of NGOs. Of over 4 400 NGOs, 30 received more than 40 % of total funds during 
the 2014-2023 period (i.e. €3.3 billion). Figure 5 shows the concentration of EU funding 
granted to NGOs in various policy areas. 

5  Regulation 2024/2509, Article 38. 

 
 
 
22 

Figure 5 | A substantial portion of funding from the EU budget is directly 
granted to the 30 largest NGOs by the Commission in each selected policy 
area 

100 %

75 %

50 %

25 %

0 %

Share of 30 largest recipients 
Share they would have if equally distributed

94 %

80 %

36 %

53 %

52 %

43 %

10 %

5 %

Health

Research

Education

27 %

10 %

2 %

1 %

Environment
and climate

Investing in
people

Other

Total no.
of recipients*:            89

306                        663                     300                   1 594                   2 649

* Some NGOs received payments from more than one fund. 

Source: ECA, based on financial data from the Commission’s accounting system. 

43 In 2024, the co-legislators agreed to the Commission’s proposal to introduce very low-
value grants as a new category of grant, the aim being to facilitate access to funding for 
smaller projects. According to the Commission, this should make the concentration less 
acute. Applicants for such grants – including NGOs – will need to supply fewer documents 
(e.g. no need to demonstrate financial capacity to implement a project). 

Managers of EU funds verify recipients’ 
transparency, but do not proactively check 
whether they comply with EU values 

44 The Financial Regulation and sectoral legislation lay down specific transparency 

requirements for accessing EU funds (see Annex II). The Commission, member states and 
implementing bodies should verify that, as EU recipients, NGOs comply with these 
transparency requirements before being granted EU funds and throughout the duration of 
the grant contract. In this section, we examine whether the Commission, its implementing 
partners and member state authorities: 

— 

ran open calls for grants in a transparent way; and 

—  verified that EU fund recipients respect EU values. 

 
 
 
23 

Lastly, we also assessed the transparency of the NGOs in our sample in terms of how they 
present information about their donors and activities. 

Calls for proposals in our sample were transparent 

45 We reviewed the EU legal framework for the programmes included in our audit scope, and 
identified requirements contributing to public transparency (Annex II provides references 
to legal acts). We found that these requirements were consistent between the 
management modes under which the EU budget is implemented. 

46 When publishing calls for proposals, the granting authorities (our sample included the 

Commission, three implementing partners and six managing authorities for AMIF and ESF+ 
in the selected member states) require applicants to provide several documents so that 
their legal status (e.g. statutes and legal representatives) and financial capacity can be 
assessed. As well as assessing applicants’ capacity to complete a project, these documents 
provide the granting authorities with some information about the potential recipients of 
the funds. 

47 Our survey asked NGOs if they think EU and national transparency requirements in calls for 
proposals are excessive. Over 90 % of NGOs that responded did not. Those that did were 
mostly smaller NGOs. They mainly pointed to cumbersome national requirements for 
reporting on how the funds they received were used. 

48 We examined the transparency of calls for proposals in which the sampled 90 NGOs were 
successful. Overall, we found these calls were transparent, as they were available to 
potentially interested parties as well as to the public. The published criteria for accessing 
EU funds were clear. 

49 We also examined the Commission’s and implementing bodies’ checks and decisions on 
applications in order to ascertain how transparent they were when the recipients of EU 
funds were being selected. The Commission’s documentation in eGrants, which is 
standardised across all departments and agencies, provides a sufficient level of information 
about the decisions on how funding is granted (i.e. “why” the NGOs received the money). 
However, in the three member states we visited, we observed different levels of 
transparency in the selection process. In Sweden, the methodology used to assess grant 
applications leaves evaluators more room for discretion than in Germany and Spain, both 
of which provide more guidance on how to assess grant applications (see Box 5). 

 
 
24 

Box 5 

The transparency of the selection process in member states varies 

In Germany, managing authorities keep detailed documentation on how scores were 
awarded. These scores are divided into sub-categories, and detailed justifications are 
provided for each. Projects exceeding the minimum threshold receive funding. 
However, the documentation on the selection process is not publicly available. 

In Spain, managing authorities use the award criteria and the objective criteria 
published in the calls for proposals for evaluating applicants and applicants’ scores. To 
assign points to each project, they use an assessment form that calculates the total 
score based on these pre-defined parameters. 

In Sweden, the detailed assessment methodology for the call criteria is described in 
the managing authorities’ internal guidelines, but these are not publicly available. The 
scoring system does not define, for example, what a “strong” or “weak” project is, 
even though this is a criterion for awarding funding. The managing authorities 
assigned these scores by comparing projects and using their professional judgment. 

50 Some of the EU operating grants awarded to NGOs may finance advocacy activities such as 
lobbying. In our sample, we came across two cases of operating grants financed by the LIFE 
programme which included advocacy activities with policymakers (see Box 6). Both NGOs 
are registered in the EUTR as interest representatives; however, the information in F&T 
does not disclose any such activities. Even if there are no legal requirements to disclose 
advocacy activities included in operating grants for NGOs, we consider that their sensitive 
nature, when funded by the EU, requires additional transparency. 

Box 6 

Operating grants where advocacy activities were not disclosed 

For the two operating grants, F&T provides a standardised presentation of the 
objectives of such grants in less detail than signed grant agreements, which describe 
specific work and actions an NGO needs to perform for the funding it receives. One of 
our selected operating grants included advocacy activities such as holding meetings 
with members of the European Parliament and high-level representatives of the 
Commission. This information was not disclosed in F&T. 

51 During our audit work, in order to mitigate reputational risk for the EU, the Commission 

issued guidance in May 2024 that grant agreements should not require recipients to lobby 

 
 
EU institutions. As our audit covered EU funding granted to NGOs until the end of 2023, we 
did not examine the implementation of this guidance. 

25 

Respect of EU values is not proactively verified 

52 The Treaty on European Union lays down the values of human dignity, freedom, 
democracy, equality, the rule of law and human rights, including rights of persons 
belonging to minorities6, as the foundation of the EU. Since the beginning of the 2021-
2027 MFF, respecting EU values has been a contractual obligation for recipients, including 
NGOs, in order to receive EU funds. We would thus expect all EU grant contracts to include 
the obligation to respect EU values for all recipients’ activities, not just for those funded by 
the EU. In addition, we expect the Commission and implementing bodies to proactively 
verify compliance with the obligation to respect EU values. Assessing recipients’ 
compliance with EU values is crucial for the EU’s credibility. 

53 In the direct management funds we selected, the Commission uses a corporate grant 
agreement model which includes the obligation for recipients to respect EU values in 
general, not just for the activities funded by the EU. Recipients are required to provide self-
declarations that they respect EU values. For indirect management, the Commission has 
applied a similar approach since 20247. For shared management, there are differences in 
how national authorities require recipients - including NGOs - to respect EU values. This 
means that the situation is less uniform than for direct and indirect management. Table 2 
shows the differences in how the managers of EU funds verify compliance with EU values. 

Table 2 | The Commission and member states’ managing authorities verify 
compliance with EU values differently 

Stage 

Compliance with EU values 

Direct 

Indirect (1) 

Shared (2) 

The Commission/managing authorities 
check if an NGO’s statutes are in line 
with EU values (admission criteria) 

Application 

The Commission/managing authorities 
proactively check whether the project is 
in line with EU values (eligibility criteria) 

The project gets more points if it aims 
to develop EU values (award criteria) 

 

 

 

 

 

 

(3) 

 

(4) 

6  Treaty on European Union, Article 2. 

7  Erasmus+ programme guide as of 28 November 2023. 

 
 
 
26 

Stage 

Compliance with EU values 

Direct 

Indirect (1) 

Shared (2) 

Grant 
agreement/ 
decision 

Monitoring 

Respecting EU values is an obligation for 
the grant agreement/decision 

Failure to comply 
with EU values is a 
reason for recovering 
funds from a 
recipient 

regarding the 
funded project 

regarding an 
NGO’s other 
activities 

 

 

 

 

 

 

 

 

 

(1) For programmes managed by the Directorate-General for Education, Youth, Sport and Culture from 2024 onwards. 
(2) For the three member states that we visited, i.e. Germany, Spain and Sweden. 
(3) As a criterion for admission, only Spanish managing authorities check whether an NGO respects EU values. 
(4) Only Spanish managing authorities from AMIF have award criteria linked to the development of EU values. 

Source: ECA. 

54 Contracts or grant decisions require recipients - including NGOs - to respect EU values. The 
Commission and other implementing bodies rely mainly on applicants’ self-declarations. 
Some Commission departments and the other bodies that implement the EU budget do 
not systematically use complementary information, unless, according to the Commission, it 
is brought to their attention. In our sample, apart from ex-ante checks (e.g. whether 
recipients’ statutes comply with EU values), checks on exclusion situations, and applicants’ 
declarations, there is no evidence that other sources of information had been used. 

55 In order to mitigate the reputational risk for EU funding entities that do not respect EU 
values, the Commission has provided training and presentations since mid-2023. It also 
issued internal guidance in 2024 about what should be done if EU values are not 
respected. Potential action ranged from payment suspensions to grant reductions or 
terminations, but there was no mention of how compliance with this obligation should be 
checked or how to assess the seriousness of non-compliance. In the case of shared 
management, for example, the Swedish authorities informed us that they had not yet 
received any guidance, and would only investigate if they suspected non-compliance. 

56 Unlike other private, for-profit entities, for which information on ultimate owners is 

required, NGOs are not owned, meaning that the question of who “stands behind them” is 
not easy to answer. Current EU legislation does not require the Commission and other 
implementing bodies to check NGOs’ sources of funding. When, the legislatively required 
financial stability check is carried out, it provides an opportunity for managers of EU funds 
to assess the NGO’s sources of funding, thereby enabling them to identify ‘who stands 
behind them’ and any conflict of interests or the risks undermining NGOs’ independence 
from specific donors. Our sample did not show any evidence that such a check on funding 
sources had been carried out. 

 
 
27 

57 We carried out additional verifications, such as checking external data providers’ databases 

(based on publicly available data) and directly asking NGOs, and found that public 
authorities were the main source of funding for most recipients. We obtained information 
for 51 of the 90 entities in our sample. More than 85 % of these 51 NGOs were financed 
mostly from public sources in 2022 and 2023, and the fact that the EU budget was the 
main source of funding for half of them highlights the need for thorough checks of 
recipients’ compliance with EU values. 

Transparency practices vary widely in our sample, with larger 
NGOs performing better 

58 We assessed the transparency of the NGOs we sampled by reviewing the information they 
disclosed about themselves to the public. Our assessment of publicly available information 
was based on the transparency standards of the Expert Council on NGO Law of the 
Conference of International NGOs of the Council of Europe, and the approach by two 
Spanish organisations: La Coordinadora de ONG para el desarrollo (CONGE) and a private 
foundation that acts as an independent NGO evaluator (Fundación Lealtad). We focused 
on areas that provide information about who NGOs are and what they do. We grouped 
them into four transparency sections: governing bodies; missions, visions and values; social 
base and support; and planning and reporting. Annex IV provides detailed information 
about the methodology we used to assess NGOs’ transparency and on features that 
contribute to better scoring. 

59 NGOs differ significantly in their degree of voluntary transparency. On a scale of 0 to 100, 
we arrived at a total average score of 55 points for the NGOs in our sample. However, 
individual scores ranged from 5 to 90 points; see Annex III. Our assessment shows that 
NGOs scored well as regards disclosing information on governing bodies and their 
missions, visions and values. However, they tend to be less transparent about their social 
base, support and financial statements. Although NGOs usually indicate their main donors, 
they rarely include the amounts donated and the periods concerned. Figure 6 provides a 
summary of our assessment of NGOs’ total voluntary transparency, and Annex V provides 
detailed results for each section we considered when assessing voluntary transparency. 

 
 
Figure 6 | Small NGOs obtain lower scores than medium and large NGOs in 
our assessment of voluntary transparency 

average score 47

28 

15

10

5

0

15

10

5

0

15

10

5

0

0-10

11-20

21-30

31-40

41-50

51-60

61-70

71-80

81-90

91-100

average score 61

0-10

11-20

21-30

31-40

41-50

51-60

61-70

71-80

81-90

91-100

SMALL NGOs
(up to 25 staff)

Shared management
Indirect management
Direct management

MEDIUM NGOs
(between 
26 and 100 staff)

average score 68

LARGE NGOs
(more than 100 staff)

0-10

11-20

21-30

31-40

41-50

51-60

61-70

71-80

81-90

91-100

Note: The average scores are based on the sample of 90 recipients. The graphics show the information on 80 NGOs which 
we were able to classify by size. Each brick represents an NGO from the sample. 

Source: ECA. 

60 We found that the key factor determining the level of NGO transparency is size, especially 
in terms of administrative capacity. Small NGOs in our sample - i.e. those employing fewer 
than 25 people - obtained an average of 47 points, which is below the average for the 
entire sample (55 points); large NGOs with more than 100 staff averaged 68 points. Seven 
organisations in our sample had no permanent staff, as they only hired staff to carry out 
projects for which funding had been received. 

61 In Spain, one of the three member states we visited, we came across different 

accreditation processes that NGOs can carry out in addition to the reporting obligations 
that arise from contractual agreements, EU law, and national legislation. The accreditation 
processes relate to the NGOs’ management, governance, and transparency. NGO 
accreditation processes in Spain aim to verify the origin of public and private funding 
sources, social base and support (including the groups and entities that support their work, 
such as individuals, donors and volunteers), major donors, and the networks to which 
NGOs belong. 

62 The Spanish NGOs in our shared management sample scored 71 points on average. This 
indicates that an accreditation process could act as an incentive for NGOs to be more 
transparent. Of 10 Spanish NGOs, five have transparency accreditations, four being 

 
 
 
29 

medium-sized NGOs and one small. For comparison purposes, the German and Swedish 
NGOs’ scores were close to the average, with one large NGO from Germany also having 
this type of accreditation. 

63 Undergoing an accreditation process with a view to obtaining a transparency certificate is 
not widespread among EU-funded NGOs. In our sample of 90 recipients, we identified 
eight NGOs that have transparency certification, which was carried out by private entities 
independent from the NGOs. Two different Spanish organisations specialising in NGO 
governance and transparency certified five Spanish NGOs, while a Swedish organisation 
specialising in NGO fundraising certified one NGO from Sweden. We also found one NGO 
from Germany and another from Belgium with transparency certificates granted by 
certifying organisations in their respective countries. 

64 We found no material differences in NGOs’ voluntary transparency scores linked to the 

management mode they were financed under. NGOs financed under indirect management 
scored slightly less, mostly because they are small, with many employing fewer than five 
people. The reason for this is that the part of our sample covering the indirect 
management mode is financed from Erasmus+ and the ESC in which small NGOs are often 
recipients. 

This report was adopted by Chamber V, headed by Mr Jan Gregor, Member of the Court of 
Auditors, in Luxembourg at its meeting of 25 February 2025. 

For the Court of Auditors 

Tony Murphy 
President 

 
 
 
 
 
 
 
30 

Annexes 

Annex I – About the audit 

EU support for NGOs and the applicable transparency 
requirements 

01 The Treaty on European Union highlights the importance of open, transparent and regular 
interaction with representative associations and civil society1, of which NGOs are a 
subgroup. While examples of civil society organisations include trade unions, employers’ 
associations and religious institutions, the characteristic specific to NGOs is that they are 
expected to operate independently of government influence. NGOs are mostly involved in 
the areas of social inclusion, equal opportunities, gender equality, climate and 
environment protection, and research and innovation, either under EU external action, or 
EU internal policies. The Commission is committed to supporting civil society organisations 
in their role in democratic policy-making and a stronger Europe, through EU funding and 
various policy initiatives2. 

02 The Organisation for Economic Co-operation and Development (OECD) defines NGOs as 

any non-profit entity organised to pursue shared objectives and ideals, without significant 
government-controlled participation or representation3. In some member states, NGOs are 
defined by law, and in others by the nature of their activities. In our 2018 special report on 
EU funding for NGOs, with a focus on external action, we stated that while the term “NGO” 
was widely used, there was no common definition within the scope of EU-funded 
activities. We recommended that the Commission should establish clear criteria for 
identifying NGOs so as to make the financial data on EU funding for NGOs more reliable. 
We also recommended improving the information on funds implemented by NGOs so as to 

1  Treaty on European Union, Article 11. 

2  Commission’s website. 

3  Development Assistance Committee Members and Civil Society, OECD, 2020, page 28. 

 
 
31 

ensure it was published accurately, and verifying the application of rules for sub-granting. 
The Commission has largely implemented these recommendations4. 

03 In September 2024, the EU’s co-legislators updated the Financial Regulation, defining an 
NGO in Article 2(49) in the following terms: “‘non-governmental organisation’ means a 
voluntary, independent from government, non-profit organisation, which is not a political 
party or a trade union”. As the definition was introduced to increase transparency 
surrounding those recipients of EU funds which are NGOs5, the co-legislators also stipulate 
that EU grant applicants will be required to state whether they satisfy this definition. 

04 NGOs are not a homogeneous group. They can be small organisations carrying out 

activities at local level, or large international NGOs present in many countries. Some NGOs 
have annual budgets of less than €10 000 and employ staff only to carry out specific 
projects, while other organisations have an annual budget of more than €1 billion and 
several thousand staff. 

05 NGOs can receive EU grants, for example to implement an EU project. At the same time, 
they can also be “interest representatives” (organisations, associations, groups, and self-
employed individuals) who carry out certain activities to influence EU policy and decision-
making. As of June 2024, over 3 500 NGOs, platforms, networks and similar registered in 
the EUTR. Over 900 of them received EU grants in the 2021-2023 period6. After the 
“Qatargate” scandal in 2022, pressure to strengthen transparency standards for NGOs in 
receipt of EU funding grew. With this concern in mind, the European Parliament adopted a 
resolution in January 20247 urging improved transparency and accountability in the 
distribution of EU funding to recipients, including NGOs. 

06 Based on international standards8, public transparency is about providing citizens with 

proper information so that they can hold public decision-makers to account. Transparency 
is about knowing not only to whom, why and for what purpose EU funds were granted, but 

4  ECA’s Report on the performance of the EU budget – Status at the end of 2021. 

5  Regulation 2024/2509, recital 8. 

6  The official portal for European data. 

7  European Parliament resolution of 17 January 2024 on the transparency and accountability of 

non-governmental organisations funded from the EU budget (2023/2122(INI). 

8  OECD (2017), OECD Budget Transparency Toolkit: Practical Steps for Supporting Openness, 
Integrity and Accountability in Public Financial Management, OECD Publishing, Paris; the 
International Monetary Fund; and Transparency International. 

 
 
 
32 

also how they were used, and the amounts involved. Meeting transparency requirements 
includes the factors illustrated in Figure 1. 

07 The Financial Regulation lays down transparency as one of its guiding budgetary principles, 
requiring the Commission to make information on EU funds available in an appropriate and 
timely manner9. It contains specific transparency requirements for the Commission and 
bodies that implement the EU budget to publish information about recipients of EU funds 
under direct management. In the case of grant and contract management procedures, 
additional transparency requirements are stipulated in the Financial Regulation and 
sectoral legislation. Some member states have their own additional transparency 
requirements. NGOs may also self-regulate regarding their transparency practices, and 
provide information on their own initiative. Annex II provides further information on EU 
transparency requirements. 

08 The FTS is a publicly available database on recipients of funding from the EU budget. It 
discloses the financial information on first-level transactions under direct and indirect 
management. It is the main transparency tool for recipients of EU funds subject to these 
two management modes. Marking an entity as an NGO in FTS is based on self-declaration 
by recipients of EU funds. Implementing partners and member state authorities are 
required to publish on their websites the information on EU funding they have granted to 
recipients. Figure 1 presents key IT systems that the Commission and other implementing 
bodies use to disclose information on EU funding. 

9  Regulation 2024/2509, article 38. 

 
 
 
33 

Figure 1 | Multiple IT systems are used to disclose information on EU 
funding 

Direct management
(Erasmus+ ESF+, Horizon Europe, LIFE, 
CREA, CERV, Euratom)

Indirect management
(Erasmus+ and ESC)

Shared management 
(ESF+ and AMIF)

The key 
IT systems

LIFE dashboard

Horizon dashboard

Financial 
Transparency 
System 

Implementing 
partners’ 
websites

Managing 
authorities’ 
websites

Cohesion Open 
Data Platform

A  B  A  C    /    S  U  M  M A

European 
Commission

Member states

eGrants suite

DG EAC’s
system suite & PMM

SFC

F & T Portal

Recipients

Implementing 
partners

Managing
authorities

Money and information flows
Granting EU funds
Disclosing information about EU grants

Owners of IT systems
European Commission
Implementing partners 
Managing authorities

Source: ECA. 

Recipients

Recipients

ABAC:  Accrual Based Accounting System (the Commission’s accounting system until 31 December 2024)

F&T Portal: Funding and Tenders Portal

PMM: Project Management Module

SFC: System for Fund Management in the European Union

SUMMA: The Commission’s accounting system (from 1 January 2025)

EU funding granted to NGOs 

09 EU funding granted to NGOs is provided mostly in the form of grants for which various 
types of recipients are eligible. NGOs must therefore comply with the EU transparency 
requirements (Annex II) that apply to all types of recipients. 

10 In the 2021-2023 period, the Commission stated in its FTS that it had committed 
€3.4 billion to NGOs from the funding it managed directly for internal policies and 
€1.4 billion for actions managed indirectly through its implementing partners. Together, 
these amounts, which were received by 5 000 NGOs, represent 5 % of all directly and 
indirectly managed spending in internal policies. Of these amounts, the Commission 
targeted €261 million solely at NGOs, in the form of operating grants. 

11 Information on EU funding granted to NGOs under shared management programmes is 
not consolidated and available at EU level. At our request, the member states reported 

 
 
 
34 

that they had granted €2.6 billion from the two largest EU funding sources to around 7 500 
NGOs in the 2021-2023 period: 

—  €2.2 billion from the ESF+, over 2 % of the total of €95.1 billion committed until the 

end of 2023; and 

—  €0.4 billion from AMIF, more than 7 % of the total of €5.5 billion committed until the 

end of 2023. 

Audit scope and approach 

12 Given the European Parliament’s call for greater transparency and accountability of EU 

funding, the important role of NGOs in democratic policy-making and the objective of the 
2024 Financial Regulation to improve transparency around NGO recipients of EU funds 
(see paragraph 03), we decided to assess the transparency of EU funding granted to NGOs 
in EU internal policies. 

13 We specifically examined whether the Commission, its implementing partners and 

member states: 

—  collect and disclose reliable data on EU funding granted to NGOs; and 

—  appropriately assessed key transparency requirements for NGOs in receipt of EU 

funds, as well as whether they respect EU values. 

14 The scope of our audit covered funding for EU internal policies for the 2021-2023 period. 
We looked at EU funding granted to NGOs under all modes of management: direct or 
indirect (through implementing partners) by the Commission, and under shared 
responsibility with member states (through national or regional authorities). In this report, 
we use the term ‘internal policies’ for all EU programmes other than external action 
(Heading 6: Neighbourhood and the World). The audit included the following key EU 
internal policies and programmes with NGO funding: 

— 

— 

“Investing in people, social cohesion and values”: ESF+, Erasmus+, ESC, CREA and 
CERV; 

“Research and innovation”: Horizon Europe and Euratom Research and Training 
Programme; 

— 

“Asylum, migration and integration”: AMIF; and 

— 

“Environment and climate action”: LIFE. 

 
 
35 

15 We excluded EU external policy from the scope of our audit because it was covered by our 

2018 report on EU funding granted to NGOs10, and then followed up in 202111. 

16 We assessed the reliability of the information published by the Commission, its 

implementing partners, and the member states’ authorities on EU funding for NGOs by 
reconciling it with underlying data for a random sample of 90 recipients. Figure 2 describes 
the sample selection and its stratification. Our sample covered all three management 
modes with 30 recipients for each mode (see Annex III). To obtain NGOs’ views about the 
EU’s transparency requirements, we sent a survey to our sample of recipients and 
consulted an additional four NGOs or associations of NGOs. We also assessed whether this 
information was easy to use for the purposes of further analysis. In addition, we assessed 
the main systems that the Commission, its implementing partners and member state 
authorities use to collect information about all EU funding. 

Figure 2 | Our sample selection 

Direct management

Indirect management

Selection of EU programmes: 
Erasmus+ and the European Solidarity Funds 
managed by DG EAC

Shared management

Selection of EU programmes: 
ESF+ and AMIF

2021-2023 payments to NGOs 
from the Commission’s financial and accounting system (ABAC)

2021-2023 commitments to NGOs 
from the ESF+ and AMIF funds as reported by the 
managing authorities

€3.3 billion

€1.5 billion

€2.6 billion

1st stage sampling

Main sample 
24 recipients

8 recipients
operating grant

2nd stage sampling  (sub-samples of recipients)

Selection of 
3 implementing partners (NGOs)

Selection of 
3 member states

Germany

Germany

Poland

Slovenia

Spain

Sweden

30

5

12

13

10

10

10

Source: ECA. 

Sample of 90 recipients

17 To obtain evidence as to whether managers of EU funds assessed key transparency 

requirements for NGOs appropriately (see Annex II), we examined not only the procedures 
put in place but also the way they checked our sample of 90 recipients. This included 
assessing whether the grant decisions were justified in a transparent manner, and 
contained a similar level of information for the various EU funds. We also examined 

10  Special report 35/2018. 

11  Report on the performance of the EU budget – Status at the end of 2021. 

 
 
 
 
36 

whether the systems put in place by managers of EU funds to check recipients’ compliance 
with EU values is sound and capable of detecting possible breaches. 

18 To complement our work further, we interviewed staff from the Commission’s Directorate-
General for Budget; DG EMPL; the Directorate-General for Research & Innovation; the 
Directorate-General for Migration & Home Affairs; CINEA; EACEA; the European Research 
Council Executive Agency, and the European Health and Digital Executive Agency. We also 
sent questionnaires to national and regional authorities in order to obtain information 
about EU funding granted to NGOs that was under shared management and about 
national transparency requirements, and the related systems of checks. 

19 We selected three member states for audit visits (Germany, Spain and Sweden). Our key 

selection criterion was the materiality of EU funding committed to NGOs in these countries 
in the 2021-2023 period, our aim being to obtain a balanced analysis. In addition, we used 
data analysis techniques to carry out cross-checks between the relevant systems, 
databases and portals containing financial information on EU funding for NGOs. 

 
 
 
37 

Annex II – EU legal basis for transparency 
requirements for selected EU programmes 
EU regulations setting out transparency requirements 

Transparency 
requirement 

Financial Regulation 
– 2018 

Common Provisions 
Regulation 

Legal base for other 
EU programmes 

To award grants 
following published 
calls for proposals 

To publish 
information on 
recipients and other 
information 

Art. 189 

Art. 49 

Art. 38 

Art. 48 

Visibility of EU funds 

Art. 63(1), Art. 154(2) 
and Art. 201 

Arts. 46 and 47 

Art. 21 of R. 
1293/2013 (LIFE) 

Art. 51 of R. 
2021/695 (Horizon 
Europe) 

Art. 25 of R. 
2021/817 (Erasmus+) 

Art. 22 of R. 
2021/888 (European 
Solidarity Corps) 

Art. 20 of R. 
2021/692 (Citizens, 
Equality, Rights and 
Values) 

Art. 23 of R. 
2021/818 (Creative 
Europe) 

To acknowledge the 
receipt of EU funding 

Art. 50 

Source: ECA. 

 
 
 
 
 
 
 
 
38 

Annex III – Basic information on entities in our 
sample 
Information on entities included in our sample, covering 14 countries 

Sample 
reference 

Country 

EU 
programme 

Grant amount 
(in thousand 
euros) 

Size (number 
of staff) 

Transparency 
certification 

Our 
transparency 
score – total 

DM01 

DM02 

DM03 

DM04 

DM05 

DM06 

DM07 

DM08 

DM09 

DM10 

DM11 

ES 

ES 

BE 

BE 

FR 

SE 

AT 

DE 

BE 

BE 

DE 

DM12 

MT 

DM13 

DE 

DM14 

DM15 

DM16 

DM17 

DM18 

DM19 

DM20 

DM21 

DM22 

PT 

AT 

SK 

DE 

IT 

IT 

EL 

DE 

BE 

5 460 

large 

Horizon 
Europe 

Horizon 
Europe 

2 241 

Erasmus+ 

140 

Horizon 
Europe 

4 187 

large 

small 

small 

Erasmus+ 

2 220 

medium 

CREA 

ERASMUS+ 

Horizon 
Europe 

CREA 

ESF+ 

Horizon 
Europe 

Horizon 
Europe 

Horizon 
Europe 

Horizon 
Europe 

CERV 

CERV 

CERV 

Erasmus+ 

LIFE 

ISF 

160 

280 

7 317 

1 153 

174 

975 

small 

not available 

large 

small 

small 

large 

1 061 

small 

8 865 

large 

1 625 

503 

257 

525 

86 

large 

small 

small 

small 

not available 

1 580 

not available 

283 

small 

EURATOM 

102 000 

not available 

Erasmus+ 

125 

small 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

YES 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

80 

65 

60 

5 

50 

55 

65 

60 

90 

40 

80 

15 

90 

90 

60 

20 

55 

70 

30 

35 

75 

50 

 
 
Sample 
reference 

Country 

EU 
programme 

39 

Size (number 
of staff) 

Transparency 
certification 

Our 
transparency 
score – total 

Grant amount 
(in thousand 
euros) 

1 023 

255 

483 

816 

165 

700 

700 

ESF+ 

CREA 

CREA 

ESF+ 

ESF+ 

LIFE 

LIFE 

Horizon 
Europe 

1 300 

Erasmus+ 

213 200 

Erasmus+ 

200 722 

small 

small 

small 

small 

small 

medium 

medium 

large 

large 

large 

Erasmus+ 

7 665 

not available 

Erasmus+ 

151 

Erasmus+ 

Erasmus+ 

ESC 

ESC 

ESC 

Erasmus+ 

Erasmus+ 

Erasmus+ 

ESC 

Erasmus+ 

Erasmus+ 

Erasmus+ 

Erasmus+ 

ESC 

Erasmus+ 

Erasmus+ 

Erasmus+ 

Erasmus+ 

23 

60 

28 

7 

28 

44 

120 

10 

48 

309 

29 

39 

60 

30 

57 

29 

400 

32 

small 

small 

small 

not available 

small 

small 

not available 

small 

small 

small 

small 

small 

small 

small 

small 

small 

small 

small 

small 

DM23 

DM24 

DM25 

DM26 

DM27 

DM28 

DM29 

DM30 

IM01 

IM02 

IM03 

IM04 

IM05 

IM06 

IM07 

IM08 

IM09 

IM10 

IM11 

IM12 

IM13 

IM14 

IM15 

IM16 

IM17 

IM18 

IM19 

IM20 

IM21 

IM22 

BE 

FR 

BE 

BE 

SE 

BE 

DE 

IL 

DE 

PL 

SI 

SI 

SI 

SI 

SI 

SI 

SI 

SI 

SI 

SI 

SI 

SI 

SI 

PL 

PL 

PL 

PL 

PL 

PL 

PL 

NO 

NO 

NO 

NO 

YES 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

35 

25 

40 

55 

70 

75 

55 

80 

70 

60 

45 

65 

40 

40 

55 

65 

60 

50 

70 

65 

45 

55 

55 

30 

5 

45 

50 

45 

85 

60 

 
 
Sample 
reference 

Country 

EU 
programme 

Grant amount 
(in thousand 
euros) 

Size (number 
of staff) 

Transparency 
certification 

Our 
transparency 
score – total 

40 

IM23 

IM24 

IM25 

IM26 

IM27 

IM28 

IM29 

IM30 

SM01 

SM02 

SM03 

SM04 

SM05 

SM06 

SM07 

SM08 

SM09 

SM10 

SM11 

SM12 

SM13 

SM14 

SM15 

SM16 

SM17 

SM18 

SM19 

SM20 

SM21 

SM22 

SM23 

PL 

PL 

PL 

PL 

DE 

DE 

DE 

DE 

DE 

DE 

DE 

DE 

DE 

DE 

DE 

DE 

DE 

DE 

ES 

ES 

ES 

ES 

ES 

ES 

ES 

ES 

ES 

ES 

SE 

SE 

SE 

Erasmus+ 

Erasmus+ 

Erasmus+ 

Erasmus+ 

Erasmus+ 

Erasmus+ 

Erasmus+ 

Erasmus+ 

AMIF 

AMIF 

AMIF 

AMIF 

AMIF 

ESF+ 

ESF+ 

ESF+ 

ESF+ 

ESF+ 

AMIF 

AMIF 

AMIF 

AMIF 

AMIF 

ESF+ 

ESF+ 

ESF+ 

ESF+ 

ESF+ 

ESF+ 

ESF+ 

ESF+ 

25 

52 

29 

250 

291 

810 

731 

400 

1 771 

9 742 

small 

small 

small 

small 

not available 

not available 

not available 

small 

medium 

medium 

12 142 

small 

1 922 

not available 

707 

3 648 

2 866 

290 

large 

not available 

large 

not available 

23 559 

medium 

63 

95 

156 

49 

159 

84 

13 591 

46 670 

33 800 

18 506 

4 000 

2 253 

5 512 

269 

not available 

medium 

large 

medium 

small 

large 

medium 

large 

medium 

medium 

small 

large 

large 

large 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

YES 

NO 

NO 

NO 

YES 

NO 

YES 

NO 

NO 

NO 

NO 

YES 

YES 

YES 

NO 

NO 

NO 

45 

50 

45 

65 

35 

60 

70 

45 

40 

40 

75 

25 

65 

50 

60 

50 

45 

55 

85 

85 

80 

70 

50 

75 

80 

90 

85 

15 

50 

80 

50 

 
 
41 

Sample 
reference 

Country 

EU 
programme 

Grant amount 
(in thousand 
euros) 

Size (number 
of staff) 

Transparency 
certification 

Our 
transparency 
score – total 

SM24 

SM25 

SM26 

SM27 

SM28 

SM29 

SM30 

Source: ECA. 

SE 

SE 

SE 

SE 

SE 

SE 

SE 

ESF+ 

ESF+ 

AMIF 

AMIF 

AMIF 

AMIF 

AMIF 

1 238 

1 353 

5 536 

818 

280 

5 654 

1 809 

medium 

medium 

large 

large 

large 

large 

medium 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

15 

35 

70 

50 

35 

70 

85 

 
 
 
 
42 

Annex IV – Description of the methodology we 
used to assess NGOs’ voluntary transparency 
In our assessment of the sampled NGOs, we examined the information that enables the 
public to understand who those NGOs are and what they do. 

We searched for information on how the NGOs work, and how this work is done (financial 
and human resources); what the internal processes, decisions and results obtained are; 
and how this information is openly and clearly circulated so that any interested party can 
find it easily. 

The methodology 
To develop our methodology, we considered the transparency standards of the Expert 
Council on NGO Law standards of the Conference of International NGOs of the Council of 
Europe, and the approaches of two Spanish organisations: CONGE and the Fundación 
Lealtad. 

We split the assessment into four sections, similar to CONGE’s transparency and good 
government method (see ‘governing body’, ‘mission, vision and values’, ‘social base and 
support’ and ‘planning and reporting’), as it covers the Council of Europe’s main applicable 
standards and provides specific questions for each section. We evaluated publicly available 
information for the 90 NGOs in our sample, and awarded a maximum of 100 points for 
each section (see Table). The total score is the average of the scores obtained in each of 
the four sections. 

ECA assessment grid for NGO voluntary transparency measures 

Governing body 

Mission, vision and values 

Area | Question | Maximum points 

Is the composition of the governing body accessible and 
publicly available? 
Are links/ties with other institutions made known? 
Is the organisation chart accessible and publicly available? 
Are statutes and relevant regulations accessible and publicly 
available? 
Are the mission, vision and values accessible, publicly available, 
and in line with EU values? 
Is information on historical changes accessible and publicly 
available? 

30 

30 
10 

30 

75 

10 

 
 
Area | Question | Maximum points 

Are codes of conduct (in-house or subscribed) accessible, 
publicly available, in line with EU values, and equipped with 
mechanisms for managing potential conflicts of interest 
properly? 
Do the groups and entities that formally support the work of 
the NGO appear publicly on its website? 
Are quantitative data about the NGO’s staff publicly available? 
Is there a public and accessible list of the networks or 
federations to which the NGO belongs? 
Is a list of public and private legal entities that finance the NGO 
accessible and publicly available? 
Are channels accessible for requesting information and 
submitting complaints about the NGO? 
Is information on the territorial implementation of the NGO 
(headquarters) accessible and publicly available? 
Is there a public and accessible list of public aid and public and 
private subsidies? 
Is strategic planning accessible and publicly available? 
Are the NGO’s annual accounts accessible and publicly 
available? 

Is there an accessible and publicly available activity report? 

Does the NGO report on the origin and application of the funds 
it receives? 
Do activity reports provide information on all programmes and 
projects? 

Is the NGO’s financial investment policy publicly available? 

43 

15 

25 

15 

15 

10 

15 

10 

10 

20 

25 

15 

15 

15 

10 

Social base and support 

Planning and reporting 

Source: ECA, based on CONGE’s transparency and good government method. 

 
 
 
 
44 

Annex V – Results of our assessment of NGOs’ 
voluntary transparency 
We assessed a sample of recipients. Figure 1 shows the size of the NGOs we selected. 

Figure 1| The majority of our sample consists of small NGOs 

Small NGOs (up to 25 staff)
59 %

Large NGOs 
(more than 100 staff)
20 %

Source: ECA, based on our survey of NGOs. 

Medium NGOs 
(between 26 and 100 staff)
21 %

Governing body 
This section presents an average total of 65 points and a median of 70, driven by high 
scores achieved by NGOs funded through direct and shared management. Regardless of 
size and management mode, a few NGOs scored between 91 and 100 points. The lowest 
scores – 40 or less – were obtained by small NGOs that are mostly funded by indirect 
management. 

The disclosure of links or ties with other institutions and the availability of statutes 
contributed significantly to higher scores. 

 
 
 
Figure 2 | Transparency scores for the ‘Governing Body’ section 

45 

15

10

5

0

15

10

5

0

15

10

5

0

average score 58

0-10

11-20

21-30

31-40

41-50

51-60

61-70

71-80

81-90

91-100

average score 67

0-10

11-20

21-30

31-40

41-50

51-60

61-70

71-80

81-90

91-100

average score 76

0-10

11-20

21-30

31-40

41-50

51-60

61-70

71-80

81-90

91-100

SMALL NGOs
(up to 25 staff)

Shared management
Indirect management
Direct management

MEDIUM NGOs
(between 
26 and 100 staff)

LARGE NGOs
(more than 100 staff)

Note: The average scores are based on the sample of 90 recipients. The graphics show the information on 80 NGOs, one 
brick each, which we were able to classify by size. 

Source: ECA. 

Mission, vision and values 
Information being available online resulted in better total average and median scores (64 
and 63, respectively). In this section, eight NGOs scored the maximum of 100 points (six 
under direct management and two under shared). Conversely, small NGOs had the lowest 
scores, with 11 obtaining 30 points or less. 

Clearly expressing its mission, vision and values was decisive in order for an NGO to obtain 
a high score. This makes it possible not only to establish the identity of an NGO, but also to 
ensure the relevance of an NGO definition. 

 
 
 
Figure 3 | Transparency scores for the ‘Mission, vision and values’ section 

46 

15

10

5

0

15

10

5

0

15

10

5

0

average score 53

0-10

11-20

21-30

31-40

41-50

51-60

61-70

71-80

81-90

91-100

average score 71

SMALL NGOs
(up to 25 staff)

Shared management
Indirect management
Direct management

MEDIUM NGOs
(between 
26 and 100 staff)

0-10

11-20

21-30

31-40

41-50

51-60

61-70

71-80

81-90

91-100

average score 77

LARGE NGOs
(more than 100 staff)

0-10

11-20

21-30

31-40

41-50

51-60

61-70

71-80

81-90

91-100

Note: The average scores are based on the sample of 90 recipients. The graphics show the information on 80 NGOs, one 
brick each, which we were able to classify by size. 

Source: ECA. 

Social base and support 
The varied scores in this section show that the transparency practices in our sampled 
NGOs differ. Most of the 28 NGOs that scored more than 71 points were funded through 
indirect management (15 NGOs), including a single score of 100 points. The 15 NGOs with 
40 points or less resulted in a lower average (58) than for previous sections, but the 
median (65) remains aligned. 

Showing who is behind an NGO, whether groups/entities, hired staff or donors was critical 
in order to obtain a higher score. 

 
 
 
Figure 4 | Transparency scores for the ‘Social base and support’ section 

47 

15

10

5

0

15

10

5

0

15

10

5

0

average score 61

0-10

11-20

21-30

31-40

41-50

51-60

61-70

71-80

81-90

91-100

average score 59

0-10

11-20

21-30

31-40

41-50

51-60

61-70

71-80

81-90

91-100

average score 58

0-10

11-20

21-30

31-40

41-50

51-60

61-70

71-80

81-90

91-100

SMALL NGOs
(up to 25 staff)

Shared management
Indirect management
Direct management

MEDIUM NGOs
(between 
26 and 100 staff)

LARGE NGOs
(more than 100 staff)

Note: The average scores are based on the sample of 90 recipients. The graphics show the information on 80 NGOs, one 
brick each, which we were able to classify by size. 

Source: ECA. 

Planning and reporting 
This section presents the lowest results, with a total average score of 33 and a median of 
25, mostly because 49 NGOs score 40 points or less, with 35 scoring 20 points or less. The 
absence of publicly available annual accounts, the report on the origin and application of 
the funds, and activity reports providing information for all programmes and projects in 
several of the cases we analysed explain the low average score. 

 
 
 
Figure 5 | Transparency scores for the ‘Planning and reporting’ section 

48 

15

10

5

0

15

10

5

0

15

10

5

0

average score 20

0-10

11-20

21-30

31-40

41-50

51-60

61-70

71-80

81-90

91-100

average score 45

0-10

11-20

21-30

31-40

41-50

51-60

61-70

71-80

81-90

91-100

SMALL NGOs
(up to 25 staff)

Shared management
Indirect management
Direct management

MEDIUM NGOs
(between 
26 and 100 staff)

average score 56

LARGE NGOs
(more than 100 staff)

0-10

11-20

21-30

31-40

41-50

51-60

61-70

71-80

81-90

91-100

Note: The average scores are based on the sample of 90 recipients. The graphics show the information on 80 NGOs, one 
brick each, which we were able to classify by size. 

Source: ECA. 

 
 
 
 
 
49 

Abbreviations 

AMIF: Asylum, Migration, and Integration Fund 

CINEA: European Climate, Infrastructure and Environment Executive Agency 

CERV: Citizens, Equality, Rights and Values 

CONGE: La Coordinadora de ONG para el desarrollo 

CREA: Creative Europe 

DG EMPL: Directorate-General for Employment, Social Affairs, and Inclusion 

EACEA: European Education and Culture Executive Agency 

ESC: European Solidarity Corps 

ESF+: European Social Fund Plus 

EUTR: EU Transparency Register 

F&T: Funding and Tenders portal 

FTS: Financial Transparency System 

MFF: Multiannual financial framework 

NGO: Non-Governmental Organisation 

OECD: Organisation for Economic Co-operation and Development 

PMM: Project Management Module 

SEDIA: Single Electronic Data Interchange Area 

 
 
 
 
50 

Glossary 

Civil society : Part of society, distinct from government and business, that consists of 
associations and other groupings representing shared interests in the public domain. 

Commitment : Amount earmarked in the budget to finance a specific item of expenditure, 
such as a contract or grant agreement. A commitment requires an underlying commitment 
appropriation. 

Council of Europe : International organisation, comprising 47 European countries, that 
promotes democracy and protects human rights and the rule of law in Europe. Not an EU 
institution. 

Database : Structured set of data stored electronically and available for consultation and 
extraction. 

Direct management : Management of an EU fund or programme by the Commission 
alone, in contrast to shared management or indirect management. 

eGrants: The Commission’s online platform for managing EU research grants throughout 
their lifecycle. 

First-level transaction: Payment/commitment made by the Commission to a recipient or 
implementing partner. A subsequent payment/commitment from these funds made by the 
recipient or implementing partner to another organisation (“second-level recipient”) is 
known as a “second-level transaction”. 

Grant: EU budget support for the costs incurred by a beneficiary for an eligible project or 
programme, usually not repayable. 

Indirect management : Method of implementing the EU budget whereby the Commission 
entrusts implementation tasks to other entities (such as non-EU countries and 
international organisations). 

Managing authority : National, regional, or local authority (public or private) designated by 
a member state to manage an EU-funded programme. 

Operating grant: Financial support to cover the operating costs of an organisation pursuing 
an EU policy objective. 

Shared management : Method of spending the EU budget in which, in contrast to direct 
management, the Commission delegates to a member state while retaining ultimate 
responsibility. 

 
 
 
51 

The Commission’s replies 

https://www.eca.europa.eu/en/publications/sr-2025-11 

Timeline 

https://www.eca.europa.eu/en/publications/sr-2025-11 

 
 
 
 
 
52 

Audit team 

The ECA’s special reports set out the results of its audits of EU policies and programmes, or 
of management-related topics from specific budgetary areas. The ECA selects and designs 
these audit tasks to be of maximum impact by considering the risks to performance or 
compliance, the level of income or spending involved, forthcoming developments and 
political and public interest. 

This performance audit was carried out by Audit Chamber V – Financing and administering 
the Union, headed by ECA Member Jan Gregor. The audit was led by ECA Member Dr 
Laima Liucija Andrikienė, supported by Tomas Mackevičius, Head of Private Office and 
Aldona Drėgvaitė, Private Office Attaché; Margit Spindelegger and Jindřich Doležal, 
Principal Managers; Tomasz Kokot, Head of Task; Sara Danif and Anthony Balby, Auditors, 
Sara Pérez Miguel, Assistant Auditor. Jesús Nieto Muñoz provided graphical support. 

From left to right: Aldona Drėgvaitė, Sara Danif, Tomasz Kokot, Laima Liucija Andrikienė, 
Tomas Mackevičius, Sara Pérez Miguel and Jindřich Doležal.

 
 
 
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HTML 

ISBN 978-92-849-4849-9 

ISSN 1977-5679 

doi:10.2865/5545347 

QJ-01-25-021-EN-Q 

PDF 

ISBN 978-92-849-4850-5 

ISSN 1977-5679 

doi:10.2865/4238002 

QJ-01-25-021-EN-N 

 
 
 
 
 
 
 
HOW TO CITE 

European Court of Auditors, special report 11/2025: “Transparency of EU funding granted 
to NGOs – Despite progress, the overview is still not reliable”, Publications Office of the 
European Union, 2025. 

 
 
 
2 

Transparency gives citizens the information they need to 
hold public decision-makers to account. NGOs play an 
important role in EU policy-making. We assessed the 
transparency of EU funding granted to NGOs in EU internal 
policies. We found, that despite improvements, the 
transparency of EU funding granted to NGOs has been 
hampered by inconsistent classification of NGOs and issues 
impacting data quality. We also found that the Commission 
and other bodies do not proactively check recipients’ 
compliance with EU values, and that certain advocacy 
activities were funded by the Commission in a way that was 
not fully transparent. We recommend that the Commission 
classify NGOs consistently, improve the quality of EU 
spending data, and actively verify compliance with EU 
values. 

ECA special report pursuant to Article 287(4), second 
subparagraph, TFEU. 

EUROPEAN COURT OF AUDITORS 
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Tel. +352 4398-1 

Enquiries: eca.europa.eu/en/contact 
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