A company that receives EU money is a contractor; it discloses according to its legal form. An advocacy NGO that lives on EU money claims something more: to represent citizens and the public interest. That claim opens institutional doors and creates an authority no ordinary contractor claims.
The authority to speak for citizens and the refusal to show citizens the receipts cannot live in the same organisation.
The NGO disclosure rules were written for small associations that needed protection from excessive paperwork. The same legal forms now carry organisations managing tens of millions in EU grants, running dozens of parallel grants and declaring as little as one full-time employee.
The exclusion is explicit. The EU’s accounting directive created a harmonised framework for specified limited-liability companies and left non-profits outside its scope. Companies enter a common disclosure architecture by legal form; associations and foundations depend on a national patchwork that often does not scale with the public money entrusted to them.
⚠️ For NGOs, the result is protection from public view.
If non-profits can receive lighter public-disclosure duties than companies while exercising public-interest authority and receiving large EU grants, asking for stronger visibility is not “an attack on civil society”; it is equal treatment of public money.
The politics excuses no one. The right built an NGO scrutiny working group and turned it into a political weapon. The Socialists, Renew, the Greens and the Left walked out and called it a “witch hunt”.
Neither side counted the money. Neither side brought in more than opinions and political beliefs.
The €7.29 billion traced by this investigation, contracted to Belgian NGOs and non-profits, has no political party. Neither do the taxpayers who funded it. Neither should EU anti-fraud oversight.
“Witch hunt” is what powerful people call accountability: the revolving door turns both ways
“We managed to convince them”.
Nick Aiossa, director of Transparency International EU (TI-EU), was describing a lobbying success. “Them” meant four political groups in the European Parliament: the Socialists and Democrats, Renew Europe, the Greens/EFA and the Left.
What TI-EU had convinced them to do was boycott Parliament’s Scrutiny Working Group on NGOs, the body created to examine Commission grant agreements with NGOs and other entities.
Aiossa called the group “a political, theatrical witch hunt”. In his written response to EU Money Monitor, he confirmed that TI-EU had “successfully advocated for some political groups to boycott the illegitimate Scrutiny Working Group on NGOs”.
An organisation founded to defend integrity in the EU institutions had declared illegitimate a parliamentary accountability mechanism formally established within those institutions to examine public money.
The organisation said that advocacy was funded exclusively by private foundations. This investigation does not allege that European Commission grants financed the boycott campaign.
The boycott came first. Parliament’s budget verdict came later.
In April 2025, a letter signed by Civil Society Europe, Transparency International EU and the European Environmental Bureau told Parliament there was “no evidence of corruption, wrongdoing or maladministration”. The Belgian Official Gazette records TI-EU director Nicholas Anthony Aiossa not only representing TI-EU, but also among Civil Society Europe’s administrators since 21 June 2023. The later boycott letter argued again that the working group had established no misuse of EU funds, breach of rules or maladministration.
Parliament’s final resolution on the Commission’s management of the 2024 EU budget then echoed the same NGO defence architecture, aligned around the same claims carried by the April three-signatories letter.
The rapporteur for Parliament’s resolution was Daniel Freund.
Before entering Parliament, Freund spent almost five years at Transparency International EU as Head of Advocacy for EU Integrity and worked on EU Integrity Watch, TI-EU’s platform for making lobbying meetings and financial interests visible.
Open that platform today. In the 10th-legislature results displayed by Integrity Watch, Transparency International EU is first among organisations in Freund’s declared meeting results.
The watchdog’s own tool now places the watchdog at the top of its former employee’s meeting record.
The dates are declared and public. The official 2024 discharge procedure file records Freund meeting the Transparency International EU on 5 November 2025, after he had become rapporteur. Parliament’s separate MEP meeting register records TI-EU meeting Freund and, separately, Erik Marquardt on 17 November under “CONT Scrutiny Working Group”, the date carried by the boycott letter. On 6 May 2026, the register records TI-EU among the organisations meeting Freund under “Attack against civil society”, the day Aiossa’s “we managed to convince them” interview was published.
These are declared meetings on public registers. They establish timing and subject.
Lobbying Parliament is lawful. Freund declared the meetings. The resolution for which he served as rapporteur also demanded robust, proportionate and risk-based scrutiny of every recipient of EU money and warned that selective transparency undermines trust in the discharge process.
But the institutional proximity is part of the public record. The revolving door did not have to be hidden. It was registered.
And the sentence Parliament adopted still requires examination.
The Commission’s review “found no breaches of the law”. That records the result of the review performed. It does not tell citizens how many agreements were examined, which programmes or years were covered, what tests were applied or what limits the review had.
⚠️ It is not a documented clean bill of health for the entire NGO funding system.
The political fight produced a verdict. It did not produce a public map of the money: who received it, what legal entity stood behind the name, what workforce appeared in national records, what accounts were published, and how many EU grants were running at the same time.
EU Money Monitor built one.
Belgium: where €7.29 billion meets the public record
Between 2014 and 2024, the European Commission’s Financial Transparency System recorded €7.89 billion in grant commitments to Belgian-registered NGOs and non-profits. Belgium ranks second in the EU, behind Germany and ahead of France, Spain and the Netherlands.
That concentration is not accidental. Brussels hosts the European institutions and the advocacy platforms, international networks and European-level associations built around them. This is not merely a Belgian funding system; it is a large part of the EU civil-society funding system operating through Belgian legal entities.
The Commission published the money through 22,179 grant rows under 2,507 beneficiary name strings.
EU Money Monitor connected those records to three Belgian public registries: the Crossroads Bank for Enterprises for legal identity, the National Social Security Office for employer registration, and the National Bank of Belgium for financial filings.
The result is the Belgian NGO Funding Intelligence Pack: 758 verified legal NGOs/NFPOs receiving at least €500,000 in total over the period, together representing €7.289 billion, or 92.41% of the full Belgian total.
The first test was the most basic: who received the money?
Of the 2,507 beneficiary name strings published by the Commission, 990 carried no Belgian VAT number or identifier in any grant record. Separately, 1,103 combined multiple names or spelling variations in a single entry. Before the sector could be examined, the beneficiaries first had to be identified.
The second test was equally basic: what workforce is visible behind the grants?
Some 126 NGOs, collectively contracted for €680 million, were not registered as employers with the Belgian social-security authority. A further 172 declared between one and four employees. Together, 298 NGOs with no more than four workers visible in Belgium’s public employer register managed €1.20 billion in EU grants.
That does not mean those organisations had no workforce. They may operate through consultants, foreign employees, secondees, partners, volunteers or related entities. It means those delivery structures cannot be reconstructed from the Belgian employer register alone.
The third test was the public financial record.
For 285 NGOs managing €1.74 billion, no annual account was traceable through the National Bank’s standard public register. Another 301 NGOs, managing €1.87 billion, filed only simplified or micro accounts. Only 123 of the 758 filed complete accounts.
These figures do not establish fraud, misconduct or illegality. They establish that the three most basic public questions: who received the money, what workforce appears behind it, and what financial record citizens can consult, cannot be answered consistently from the systems that already exist.
NGO scrutiny begins with missing public information, not with political suspicion.
Belgium is the pilot. The method is designed to be repeated. The organisations’ own replies now show what sits behind the registry gaps: employment abroad, consultants, service contracts, related entities, cascade funding, partners and network delivery.
The registries reveal the gap, the organisations explain it.
The money is public. The workforce is not.
Five organisations were selected for detailed profiling from the 758 verified Belgian entities. The criteria were applied uniformly: high EU grant volume contracted in the organisation’s name and EU grants running in parallel (Source: EU Financial Transparency System), low visible employer or payroll footprint against that volume, and expenditure concentrated under services lines.
Each organisation received the figures drawn from its own public filings, each was asked to identify any factual error. Each was also asked the basic public-interest question: who performed the publicly funded work, under what contractual structure, and where can citizens verify it?
The public registries show one picture. The replies show another.
The registry picture is simple: EU grant amount, legal entity, employer footprint, payroll, services expenditure, filing format.
The organisational picture is wider, and much harder to verify from outside: foreign employees, consultants, field experts, in-house service contracts, cascade funding, public procurement, partner delivery, donor reports, internal controls and audits.
Both pictures can be true. Only one is public.
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