The first wave: Conservative political promises in 2024
In the run-up to the 2024 European Parliament elections, promises were made by right-wing political groups, including the EPP, to implement stricter controls over how EU funds granted to NGOs are spent on advocacy. Subsequently, in autumn 2024, the Ursula von der Leyen-led Commission took action, distributing directives to organizations benefitting from the LIFE Programme. These directives explicitly stated that lobbying and advocacy-related expenses are ineligible for EU grant coverage. Lobbing activities, according to the guidelines, include “organising meetings or providing advocacy material” to specific EU institutions or officials, or “identifying specific members or officials of an institution to evaluate or describe their positions, or to discuss specific political content or outcome.”
The LIFE Programme (L'Instrument Financier pour l'Environnement) is the European Union's primary funding instrument dedicated to environment and climate action since its establishment in 1992. Its core mission is to support EU environmental and climate policies, contributing significantly to the goals of the European Green Deal. The current 2021–2027 phase co-finances projects across four key areas: Nature and Biodiversity, Circular Economy, Climate Action, and the Clean Energy Transition. LIFE provides grants to public bodies, NGOs, and private companies.
The guidelines sent in autumn 2024 marked the first concrete action signalling the EPP’s intent to curb advocacy by environmental NGOs. Civil society organisations interpreted the measure as a political warning rather than a purely administrative clarification.
At the beginning of December 2024, 31 environmental Civil Society Organisations (CSOs) sent an open letter to the European Commission strongly protesting the guidelines. They stressed that civil society engagement is vital for a healthy European democracy, as CSOs act as a bridge between citizens and policymakers. They represent the voices of millions of citizens and are essential for ensuring transparency and public trust in policy decisions. They argued that restricting funding for advocacy is a direct contradiction of Article 11 of the Treaty on the European Union (TEU) and undermines the Aarhus Convention on public participation. The letter urges the European Commission to reconsider and withdraw the new guidance restricting advocacy funding.
The European Commission did not issue a press release or a direct response to the letter. However, its position was clearly communicated through a Commission Statement on the LIFE Programme published on 1 April 2025. Here the Commission defends its new guidance as a necessary move to address issues of "undue lobbying" and transparency, while simultaneously reaffirming its overall commitment to the legal role of civil society in the EU.
January 2025: Parliamentary debate escalates scrutiny
The conservative campaign against environmental NGOs intensified in 2025. At the beginning of the year, the Dutch tabloid Telegraaf published information according to which, in several cases, the old European Commission used EU funds through LIFE to pay CSOs to lobby for its own proposals.
A group of MEPs across right-wing groups, led by Monika Hohlmeier (CSU/EPP), took up the matter, having a heated discussion about it in January 2025. The debate was submitted by a request from the centre-right EPP and the right-wing European Conservatives and Reformists Group (ECR). Hohlmeier, referring to further material from whistleblowers, proposed freezing the payment of the entire €15.6 million package from LIFE to a group of specialized non-profit organisations.
The organizations concerned defended themselves and claimed that no agreement with any of the officials regarding lobbying existed and that no one was able to prove it. Patrick ten Brink, Secretary General of the European Environmental Bureau (EEB) – a network of around 180 environmental citizens' organisations – asserted that any claims that the organisations “are lobbying on behalf of the European Commission or not complying with the transparency rules are misleading and unfounded”. On top of that, he stated that “the real scandal for Europe lies in the growing calls to shrink civic space”. Representatives of other NGOs also pointed out that they receive only a few hundred thousand euros per year from the multi-billion-euro LIFE Programme, and only a small portion of this money goes to lobbying.
April 2025: European Court of Auditors review
On 7 April 2025, the European Court of Auditors published a report on LIFE-funded NGOs. The report found no evidence of irregularities or misuse concerning the selection process for these NGOs or the way the EU grants are ultimately deployed. There was no finding of “undue lobbying activities” or any suggestion that the Commission pays NGOs to lobby the European Parliament. The auditors found only minor transparency gaps in contracts.
Despite these findings, EPP and allied MEPs continued framing advocacy as a problem that justified stricter funding restrictions.
June 2025: CONT working group established
On June 19, 2025, the European Parliament approved the formation of a Scrutiny Working Group on NGO financing within the Budgetary Control Committee. Driven by the centre-right EPP, the proposal also garnered backing from the right-wing European Conservatives & Reformists (ECR) and the far-right Patriots for Europe (PfE) group.
The working group consists of 13 members and is supposed to examine all aspects relating to the financing of advocacy activities by NGOs and other entities receiving EU funding. Chaired by EPP MEP Niclas Herbst, the group was dominated by conservative and right-wing MEPs, raising concerns about the political nature of the review.
Implications for NGOs and civil society
Since autumn 2024, political initiatives, led by EPP, in the European Parliament and from the Commission have sought to restrict NGO advocacy under the LIFE Programme. Audits confirm no misuse of funds, yet these measures threaten NGOs’ ability to participate in policy processes and raise potential breaches of civil society rights under the Aarhus Convention and the EU Charter.
Sources:
EN; 28/11/2024; Commission tells NGOs EU money is not for lobbying; (Politico)
EN; 05/12/2024; Joint civil society letter to EU Commission on EU LIFE funding; (Coalition Clean Baltic)
EN; 05/12/2024; Open letter from Environmental Civil Society Organisations to the European Commission; (European Environmental Bureau)
EN; 13/12/2024; Defunding NGOs that lobby the EU will be profoundly undemocratic; (EUobserver)
EN; 23/01/2025; Under attack: Reaction to misinformation regarding NGO funding; (EEB)
CZ; 13/02/2025; Unijní pravice vytáhla proti ekologickým neziskovkám, vybrala si spor o lobbing; (Deník Referendum)
EN; 13/03/2025; Just the Facts: Why is environmental NGO funding at risk in the EU?; (European Movement Ireland)
EN; 01/04/2025; Commission statement on the LIFE Programme; (European Commission)
EN; 07/04/2025; ECA Report: No Scandal – But the Commission Needs to Invest in a More Understandable Database; (European Environmental Bureau)
EN; 12/05/2025; Evidence supporting Commission statement about ‘undue lobbying activities’ by NGOs receiving grants under the LIFE programme; (European Parliament)
EN; 17/07/2025; European Parliament creates official working group to scrutinise NGO funding; (Philanthropy Europe Association)
