European Commission reaffirms LIFE Programme funding commitment for 2025-27; commission strengthens transparency measures for NGO grant activities

The LIFE Programme, adopted by the European Parliament and the Council in 2021, plays a key role in implementing environmental, climate and energy legislation and policies. LIFE supports a wide range of beneficiaries in EU Member States, including private companies, local authorities, research foundations and civil society organisations.

The LIFE multiannual work programme 2025-27 provides the framework for its implementation for the years to come. The Commission followed the appropriate procedure for the preparation of and vote on the work programme in the LIFE Committee, consisting of Member States' representatives, which delivered a positive opinion.

Funding for NGOs is explicitly provided for in the LIFE Regulation, with the aim to improve governance of environmental, climate change and energy transition matters, including by enhancing stakeholder involvement at all levels, capacity-building, communication and awareness. The Commission remains fully committed to ensuring a healthy and vibrant civil society, also by supporting its functioning and its involvement in policy making.

At the same time, the Commission has recognised that in some cases work programmes submitted by the NGOs and annexed to the operating grant agreements contained specific advocacy actions and undue lobbying activities. The Commission has taken action to prevent such cases in the future and will take further measures to strengthen transparency and include appropriate safeguards. In particular:

• The Commission already published guidanceSecretariat-General Directorate-General for Budget Legal Service Guidance on funding for activities related to the development, implementation, monitoring and enforcement of Union legislation and policy 1 GUIDANCE ON FUNDING FOR ACTIVITIES RELATED TO THE DEVELOPMENT, IMPLEMENTATION, MONITORING AND ENFORCEMENT OF UNION LEGISLATION AND POLICY 1. BACKGROUND AND PURPOSE OF THE GUIDANCE NOTE The Commission finances under the objectives of several spending programmes support to entities, including civil society organisations, for the development, implementation, monitoring and enforcement of Union legislation and policy. The Commission attaches great importance to the support of a pluralistic and vibrant civil society, including through its programmes and funding opportunities, which include capacity building and involvement of civil society as specific funding objectives, with a view to contributing to Union policies. While support for policy development activities including enhancing the involvement of civil society organisations remains an important and legitimate funding objective that should not be subject to unnecessary constraints, careful consideration should be given to the type of activities that the Union should not finance to advance these objectives. Experience shows that additional guidance to the services to frame such activities would be most useful. The description and definition of these activities is without prejudice to any existing obligations of transparency and ethics1. Relevant measures including suspension of implementation and/or payments, termination and recovery, could be taken upon clear proof that entities have breached such obligations. This note aims at providing guidance on the type of activities the Union should not require as condition for funding as part of policy and legislation development, policy implementation, monitoring and enforcement in line with the objectives of the relevant basic acts. The guidance should be taken into account by the responsible authorising officers when drafting documents for Union award procedures, when assessing compliance with criteria under such procedures and when establishing relevant contractual arrangements involving Union financing. Authorising officers shall make sure that applicants are made appropriately aware of the requirements resulting from this guidance, in accordance with Art. 194 (1) of the Financial Regulation. The responsible authorising officers shall make an assessment and take necessary measures to ensure alignment with the guidance, in particular in regard to activities financed under Union 1 Article 14.1 of the corporate Model Grant Agreement. 2 award procedures that are related to designing, assessing and monitoring the implementation of EU policy and EU legislation. 2. GUIDANCE ON ACTIVITIES RELATED TO THE DEVELOPMENT, IMPLEMENTATION, MONITORING AND ENFORCEMENT OF UNION LEGISLATION AND POLICY This guidance applies to all spending programmes. Development, implementation, monitoring and enforcement of Union legislation and policy potentially includes a wide range of possible activities that could benefit from EU funding. Avoidance of any reputational risk should be one of the guiding principles when examining whether a given activity should be financed by a Union programme or not. Some of these activities support the capacity-building of entities, associations and organisations, including civil society organisations, contributing to a vibrant pluralistic society. Such activities include, but are not limited to, analytical or research work in the form of policy briefs or other papers; providing guidance or sharing of good practices; workshops, conferences, trainings or awareness raising campaigns; communication and dissemination activities, etc. In principle, such activities do not present a reputational risk. However, funding agreements requiring beneficiaries to undertake specifically detailed activities directed at EU institutions and some of their representatives may entail a reputational risk for the Union. Such specific activities can include sending letters, organising meetings or providing advocacy material to EU institutions or specific members of an institution; or identifying specific members or officials of an institution to evaluate or describe their positions, or to discuss specific political content or outcome. Work plans submitted by applicants should be carefully assessed to establish whether they could create such reputational risk if incorporated into a grant agreement. Freedom of expression and transparency should remain the main guiding principles for organisations exercising this type of activities, in line with relevant legal requirements. In view of this, presenting specific positions to an EU institution or some of its members, including examining and explaining the impact of a given policy or policy proposal, should be entirely the choice of the entity concerned but not mandated as a requirement or condition for Union financing2. In all cases, the entity concerned shall remain fully and solely responsible for their own views. 2 This will not preclude the financing of activities supporting civil society’s contribution to the definition or implementation of European Union policies, political dialogue with partner countries and reporting. 3 When deciding on award of funding, authorising officers are therefore to consider that activities targeting directly (members of) EU institutions for a specific political content should not be mandated as a requirement or condition for Union financing. 4 Electronically signed on 06/05/2024 19:53 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121 on the type of activities that should not be included when receiving funding as part of policy and legislation development, implementation, monitoring and enforcement. The grants should comply with the LIFE objectives and support the participation of civil society in European policy-making and democratic debate, while avoiding lobbying that targets specific policies or MEPs. This guidance is applicable to all EU funding and is already implemented by all Commission services and relevant agencies.
• In the multiannual work-programme 2025-2027, the Commission has included further safeguards to ensure that operating grants do not require specific and detailed activities that directly target Union institutions or their staff or members, and that clarify that beneficiaries retain full responsibility for their views and for presenting these views to Union institutions. The Commission is working closely with the Court of Auditors – which is currently finalising its recommendations on how to further improve the transparency of NGO funding in the implementation of EU funding programmes – including through appropriate mechanisms.
• The Commission will review the transparency arrangements for beneficiaries of grants funded by the EU budget, including in relation to the disclosure requirements under the EU transparency register.
• The Commission is committed to ensure that the LIFE evaluation committee members are independent and free from conflicts of interest. It is mandatory for the members to sign declarations on absence of conflict of interest before engaging with the assessment of proposals, and mitigation measures are in place in case conflicts of interest are identified. CINEA will review the selection procedure for members of the LIFE evaluation committee and will implement any necessary steps to ensure full transparency. 
• While working on a possible review, the MoU between CINEA and the Commission services responsible for LIFE will be implemented rigorously to ensure clarity in the respective responsibilities in the grant award procedure.

The Commission is committed to maintaining an open and collaborative dialogue with the European Parliament and stands ready to provide further clarifications on any remaining issues.