The Investigation · Belgium Pilot · Volume I · 2026
The
CHAIN
Nobody connecting the dots.
Five accountability stages between Commission disbursementand Parliament discharge.
Eighteen documented findings. EU money flows through five accountability stages At each stage, a finding from the public record, and a question for the institution responsible.
FTS universe · 2014–2024
€7.89 bn
Verified NGOs/NFPOs
758
FTS grant records
22,179
Cross-checked registries
4
Coverage
92.41%
European Commission · Financial Transparency System
01
PUBLICATION.
Not identification.
The Commission cannot reliably identify 1 in 4 of its own published beneficiaries, and has confirmed that its risk-scoring tool cannot identify NGOs at all.
Question to the Commission
How does the Commission verify grant eligibility before awarding new grants to entities it cannot cleanly identify in its own FTS database, when Arachne cannot identify NGOs and verification relies mainly on self-declarations?
On the institutional record
25%
Finding 1.1
The name string problem
The EU Financial Transparency System lists 2,507 Belgian NGO/NFPO name strings for 2014–2024. 5,548 of 22,179 grant records (25.01%) carry no Belgian identifier or VAT number. 990 name strings have zero VAT coverage across every grant row. After deduplication, 758 distinct legal entities are confirmed – 92.41% of funding.
FTS Belgium 2014–2024 · downloaded March 2026 · Recast Financial Regulation 2024/2509 Art. 38
"Self-declarations"
Finding 1.2
Arachne cannot identify NGOs
The Commission’s written reply to ECA SR 11/2025 admits, in its own words, that Arachne, the Commission’s own risk-scoring tool, “cannot be used to sufficiently identify NGOs, nor link them directly to a potential breach of EU values.” Risk identification of recipients “relies mainly on self-declarations.”
Commission Replies to ECA Special Report 11/2025 · 2025
2029
Finding 1.3
The remediation horizon
The Commission has accepted the ECA’s recommendation to fix the FTS publication gap. The Commission’s stated target for reliable beneficiary identification: 2029. Until then, the public record carries the gap and the Commission’s verification continues to rely on self-declarations under Articles 199 and 201 of Financial Regulation 2024/2509.
Commission Replies to ECA SR 11/2025 · Articles 199 & 201 Financial Regulation 2024/2509
Crossroads Bank for Enterprises · ONSS · National Bank of Belgium
02
LEGAL ENTITY - public registries exist. The chain cannot be reconstructed from them.
Belgium is the EU’s second-largest NGO recipient — ahead of France, Spain, the Netherlands, Italy, Austria, and Denmark. Yet across four registries, 391 of 758 verified entities, managing €2.66 billion, score in the lowest public-verifiability tier.
Question to the Commission
For the 285 beneficiaries managing €1.74 billion for whom no financial filing is traceable: what documents did the Commission retain to satisfy Article 199 and 201 capacity-assessment requirements? Does a self-declaration, unverified against any public registry, constitute adequate ex-ante verification of financial capacity?
On the institutional record
€1.20bn
Finding 2.1
The ghost workforce
126 of 758 NGOs managing €678M are not registered as employers anywhere in Belgium. A further 172 declare 1–4 employees. Together: 298 NGOs, €1.20 billion, 0–4 people on the public employment register.
ONSS × FTS cross-reference 2026 · Belgian Law 27/12/2006
€1.74bn
Finding 2.2
The financial filing gap
285 of 758 NGOs (37.6%) have no financial filing in the National Bank of Belgium. Their revenue, costs, and payroll are publicly invisible. Filing thresholds scale to entity size — not to public money managed.
€1.74bn · no public accounts · 285 NGOs · NBB × FTS · CSA/WVV Royal Decree 25/05/2024
16.2%
Finding 2.3
The disclosure floor
Of 473 NGOs that do file, only 123 — 16.2% — file Complete accounts. 301 file Simplified or Micro: the same format as a corner shop. Belgium has no public-funding disclosure trigger. France requires a statutory auditor above €153,000 in public subsidies.
€1.59bn
Finding 2.4
The invisible middle
477 NGOs in the €1–10M tier manage €1.59 billion. 192 have no NBB filing. Many hold 10+ simultaneous grants from different DGs. Each is individually invisible to ECA sampling. Collectively they are the void.
51.8%
Finding 2.3
The transparency score
755 NGOs scored on a 0–7 composite index: employer registration, filing quality, parallel grant load. 391 (51.8%) score LOW, managing €2.66 billion. Only 75 (9.9%) reach Good. The largest recipient — €718M, 889 simultaneous grants — scores 0.13 of 7.
EU project officers · DGs · executive agencies
03
WORKFORCE - EU grants fund people. The people are invisible.
60–80% of every EU grant is personnel cost. The Commission’s confirmed HR audit coverage across the entire €7.89bn universe, in 8 years, is 0.015%. The arithmetic is not an opinion.
Question to the Commission
What is the Commission’s consolidated HR audit coverage figure across all programmes and all DGs for Belgian non-profit beneficiaries? When will Horizon Europe HR audits begin? On what basis does the Commission provide assurance of personnel-cost regularity under Article 317 TFEU where no coverage figure exists?
On the institutional record
889
Finding 3.1
The parallel grant load
251 NGOs hold 10 or more simultaneously active EU grants in a single year, managing €5.48 billion (75.1% of all verified funding). One entity peaks at 889 parallel grants. No EU institution aggregates declared hours across an entity’s full portfolio.
€3.40bn
Finding 3.2
The HR blind spot — Code 61
Under Belgian Royal Decree 30/01/2001, contractor labour is booked under Code 61 — alongside rent and IT. No name, no rate, no public trace. 652 NGOs below 50 ONSS employees manage €3.40 billion, entirely outside Belgian statutory audit scope.
0.015%
Finding 3.3
The EU audit record
Commission FOIA reply, 28 January 2026: 45 HR-focused audits of Belgian non-profits, 2017–2024. H2020 only. Horizon Europe: zero. Against €7.89bn: 0.015% coverage in 8 years.
Member State NAFS · OLAF
04
The anti-fraud detection architecture has staggering limits
Belgium received €31.16 billion in EU funding over 10 years. No comprehensive anti-fraud strategy. 8 OLAF investigations concluded over 12 years. The country-level intake table disappeared in 2019.
Question to OLAF
Arachne cannot identify NGOs. FTS reliability deferred to 2029. 0.015% HR audit coverage in 8 years. Belgium has no NAFS. “No statistical data exists” on NGOs. 2,252 OLAF dismissals 2022–2024, Court could not confirm EPPO receipt (ECA SR 26/2025, EU-wide). Does OLAF assert this architecture is consistent with Articles 1, 3 and 17 of Regulation 883/2013 and Article 325 TFEU?
On the institutional record
77:1
Finding 4.1
The Belgium–Romania comparator
Per €1bn of EU funding: Belgium 0.13 concluded investigations · Romania 9.84. Asymmetry of 77-to-1. Belgium generated 975 OLAF cases 2019–2024 — 36.1% of all EU cases — and had 8 concluded investigations over 12 years. Fewer than Congo (7 in one period). Same Union, same regulation, same Treaty.
NO NAFS
Finding 4.2
Belgium has no national anti-fraud strategy
Commission 35th PIF Report (2023): only 10 of 27 member states have a National Anti-Fraud Strategy covering all sectors. Belgium is not among them. Belgium ranks 2nd in the EU for NGO grants — ahead of France, Spain, Italy, the Netherlands. Article 325 TFEU obliges the Commission to coordinate Member State action.
2019. 2025
Finding 4.3
The disappeared tables
OLAF published country-level fraud allegation intake figures every year through 2018. From 2019: gone. No legal basis, no replacement metric. A FOIA recovered the data on 13 May 2026 — Belgium: 975 cases in the hidden period. In 2025 OLAF deleted a second table that was placing Belgium first: OLAF to EPPO referrals per member state.
ECA · European Parliament · CONT · EPPO
05
OLAF dismissed 2,252 allegations between 2022 and 2024. ECA could not confirm they reached EPPO.
Parliament grants annual discharge for the EU budget. The ECA itself could not determine whether EPPO received 2,252 allegations OLAF dismissed between 2022 and 2024.
European Parliament — CONT
The PIF Report CONT uses for discharge documents that Belgium has no sector-wide NAFS. Belgium is the EU’s second-largest NGO recipient. OLAF holds no NGO-specific statistics. 391 entities managing €2.66 billion score in the lowest verifiability tier. On what documented basis does the Committee consider the current anti-fraud architecture adequate?
On the institutional record
2,252
Finding 5.1
The 2,252 dismissals
ECA Special Report 26/2025 documented that between 2022 and 2024, OLAF dismissed 2,252 allegations before referring them to EPPO. The Court found it could not determine whether those cases were properly communicated to EPPO, because OLAF and EPPO case-management systems are not interlinked.
"No overview"
Finding 5.2
The CONT Chair's standing admission
CONT Chair, April 2025: “There is still no complete overview of EU funding to NGOs.” The Belgium pilot answers that question for the EU’s second-largest NGO recipient. CONT received formal notification on 16 April 2026. No reply.
1 June 2026
Finding 5.3
The statutory evaluation deadline
Article 19(1) Reg. 883/2013: the Commission must submit an OLAF evaluation report to Parliament and Council. Statutory deadline: 1 June 2026. EU Money Monitor’s submissions (EUMM-OLAF-CFE-2026-001 and 002, Initiative 16893) proposes legislative remedies drafted as statutory text.
Five links. Eighteen findings. One investigation.
The institutional record — five institutions notified, replies and silences logged with file references and verbatim quotes — is on the next page. The full dataset and the live entity-level dashboard are the instruments built from this work.
“You cannot confirm the absence of wrongdoing in a system never designed to detect it”.
EU Money Monitor · Belgium NFPO Pilot · 2026