COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the document Proposal for a Regulation of the European Parliament and of the Council on the statute and funding of European political parties and European political foundations (recast)

Tilhører sager:

Hovedtilknytning: Forslag til Europa-Parlamentets og Rådets Forordning om statut for og finansiering af europæiske politiske partier og europæiske politiske fonde (omarbejdning) {SEC(2021) 577 final} - {SWD(2021) 359-60 final} ()

Aktører:

1_EN_impact_assessment_part1_v4.pdf

https://www.ft.dk/samling/20211/kommissionsforslag/kom(2021)0734/forslag/1832171/2487385.pdf

EN EN
EUROPEAN
COMMISSION
Brussels, 25.11.2021
SWD(2021) 359 final
COMMISSION STAFF WORKING DOCUMENT
IMPACT ASSESSMENT REPORT
Accompanying the document
Proposal for a Regulation of the European Parliament and of the Council
on the statute and funding of European political parties and European political
foundations (recast)
{COM(2021) 734 final} - {SEC(2021) 577 final} - {SWD(2021) 360 final}
Offentligt
KOM (2021) 0734 - SWD-dokument
Europaudvalget 2021
1
Table of Contents
LIST OF ABBREVIATIONS.......................................................................................................................3
LIST OF REGISTERED EUROPEAN POLITICAL PARTIES AND THEIR AFFILIATED
FOUNDATIONS ..........................................................................................................................................4
FOREWORD................................................................................................................................................5
1. BACKGROUND AND POLICY CONTEXT..........................................................................................6
1.1. Policy and legal context.....................................................................................................................6
1.2. Current challenge.............................................................................................................................10
1.3. Procedural issues and consultation of interested parties..................................................................11
2. PROBLEM DEFINITION ..................................................................................................................13
2.1. The problems that require action .....................................................................................................14
2.2. Problem drivers...........................................................................................................................21
2.3. Who is affected by the identified problems and in what ways?.......................................................25
3. WHY SHOULD THE EU ACT?............................................................................................................29
3.1. Legal basis .......................................................................................................................................29
4. OBJECTIVES.........................................................................................................................................30
4.1. General policy objectives.................................................................................................................30
4.2. Specific policy objectives ................................................................................................................31
4.3. Consistency with other EU policies and with the Charter of Fundamental Rights of the European
Union ......................................................................................................................................................34
4.3.1. European Democracy Action Plan............................................................................................34
4.3.2. Conference on the Future of Europe and European Electoral Act............................................34
4.3.3. Commission’s Gender Equality Strategy 2020-2025................................................................35
4.3.4. Charter of Fundamental Rights of the European Union............................................................35
5. POLICY OPTIONS ................................................................................................................................36
5.1. Baseline scenario .............................................................................................................................36
5.2. Options for further in-depth assessment ..........................................................................................38
6. ANALYSIS OF FEASIBILITY AND IMPACTS OF THE POLICY OPTIONS..................................39
6.1. Impacts of policy option 2 ...............................................................................................................40
6.2. Impacts of policy option 3 ...............................................................................................................43
7. COMPARISON OF THE POLICY OPTION PACKAGES AND PREFERRED OPTION..................50
7.1. Overview..........................................................................................................................................50
7.2. Preferred option ...............................................................................................................................52
2
8. MONITORING AND EVALUATION ..................................................................................................53
Annex I: Procedural Information................................................................................................................55
LEAD DG, DECIDE PLANNING/CWP REFERENCES .....................................................................55
ORGANISATION AND TIMING .........................................................................................................55
CONSULTATION OF THE RSB ..........................................................................................................55
Annex II: Stakeholders’ Consultation.........................................................................................................59
CONSULTATION STRATEGY............................................................................................................59
INFORMAL CONSULTATION WITH STAKEHOLDERS ................................................................59
FEEDBACK TO ROADMAP/INCEPTION IMPACT ASSESSMENT............................................60
OPEN PUBLIC CONSULTATION .......................................................................................................61
Annex III: Who is affected by the initiative and how?...............................................................................74
Annex IV: Description of the analytical methods used ..............................................................................76
Annex V: Bibliography...............................................................................................................................77
3
LIST OF ABBREVIATIONS
AFCO European Parliament Committee on Constitutional Affairs
APPF Authority for European political parties and foundations
BUDG European Parliament Committee on Budgetary Control
CoFE Conference on the Future of Europe
ECA European Court of Auditors
EDAP European Democracy Action Plan
EPRS European Parliament Research Service
EU European Union
EUCJ European Union Court of Justice
EUPF European political foundation
EUPP European political party
EUPP/F European political parties and foundations
EUPP/F
Regulation
Regulation 1141/2014 on the statute and funding of European political parties
and European political foundations
INGE European Parliament Special Committee for foreign interference in all
democratic processes in the EU, including disinformation
GAG Council Working Party of General Affairs
NGO Non-governmental organisation
OSCE/ODIHR Office for Democratic Institutions and Human Rights of the Organisation for
Security and Co-operation in Europe
REPRESENT Research Centre for the Study of Parties and Democracy
TEU Treaty on the European Union
TFEU Treaty on the Functioning of the European Union
4
LIST OF REGISTERED EUROPEAN POLITICAL PARTIES AND THEIR AFFILIATED
FOUNDATIONS
European People’s Party (EPP) Wilfried Martens Centre for European Studies
Party of European Socialists (PES) Foundation for European Progressive Studies (FEPS)
Alliance for Liberals and Democrats
for Europe Party (ALDE)
European Liberal Forum (ELF)
European Democratic Party (EDP) Institute of European Democrats (IED)
European Free Alliance (EFA) Coppieters Foundation
European Green Party (EGP) Green European Foundation (GEF)
Identité et Démocratie Parti (ID) Identité et Démocratie Fondation
European Christian Political
Movement (ECPM)
Sallux – ECPM Foundation
European Conservatives and
Reformists Party (ECR)
New Direction – The Foundation for European Reform
Party of the European Left (PEL) Transform Europe
5
FOREWORD
The present impact assessment supports the revision of Regulation No 1141/2014 on the statute
and funding of European political parties and European political foundations pursuant to Article
38 of the Regulation (evaluation clause). Due to the specificities of the Regulation, the impact
assessment has a number of limitations.
First and foremost, the Regulation is very young (adopted in 2014 but in force only since 2017)
and has only been applied at one election to the European Parliament in 2019. Therefore,
evidence on its way of functioning is limited. Some of its provisions, namely on sanctions and
the verification mechanism for compliance with EU values, have never been applied. In these
cases, the impact assessment drew on feedback from stakeholders (European political parties and
foundations, the European Parliament’s Authorising Officer, the Authority for European political
parties and foundations, international organisations) to propose changes to the current rules. The
impact assessment also draws on two external studies on the evaluation of the current EUPP/F
Regulation and the possible impacts of its revision.
In addition, the Regulation applies to a very limited number of actors: 20 European political
parties and foundations in the entire EU, the Authority for European political parties and
foundations and the European Parliament’s Authorising Officer. Therefore, the revision of the
Regulation is not expected to have the impacts usually analysed in most impact assessments:
environmental, economic and social impacts. The working assumption in the impact assessment
is that most of its impacts will be observed in the area of fundamental rights and democracy.
Also, given the limited number of actors, the causal links between modifications in the regulation
and impacts are assessed qualitatively rather than quantitatively.
6
1. BACKGROUND AND POLICY CONTEXT
1.1. Policy and legal context
European political parties (hereinafter, EUPPs) are transnational party alliances whose objective
is to ‘contribute to forming European political awareness and express the will of citizens in the
Union’1
.
The first EUPPs were formed between 1974 and 1976 in the run-up to the first direct elections to
the European Parliament. They were first legally recognised in the Treaty of Maastricht, but it
was the Treaty of Nice that allowed for the regulation of their governance and financing2
.
Consequently, Regulation 2004/20033
defined the conditions for recognising EUPPs and laid
down the rules governing their funding from the EU budget. They thus gained their financial
independence from political groups in the European Parliament4
. Regulation No 2004/2003 was
amended in 2007 allowing EUPPs to use some of their finances for campaigning in the run-up to
the elections to the European Parliament. The 2007 amendment also extended the Regulation’s
scope to European political foundations (hereinafter, EUPFs), which are think tanks affiliated to
EUPPs.
In 2011, the European Parliament evaluated Regulation No 2004/2003 and identified room for
improvement regarding internal party democracy and conditions for access to funding. The
Commission came forward with a legislative proposal in 2012 whose objective was ‘to increase
the visibility and recognition, efficiency, transparency and accountability of European political
parties and foundations’5
.
Regulation No 1141/2014 on the statute and funding of European political parties and European
political foundations6
(hereinafter, EUPP/F Regulation) was adopted in 2014 and entered into
force on 1 January 2017. Funding under the EUPP/F Regulation commenced for activities
starting from the 2018 financial year. It established a European legal personality for European
political parties and foundations (hereinafter EUPP/F), defined the criteria for their registration
1
Article 10(4) TEU
2
Article 191(2) of the Treaty of Nice.
3
Regulation (EC) No 2004/2003 of the European Parliament and of the Council of 4 November 2003 on the
regulations governing political parties at European level and the rules regarding their funding, OJ L 297, 15.11.2003.
Available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32003R2004
4
Until then, political groups channeled their appropriations to EUPPs who also relied on them for human resources
and office space. This practice was criticised by the European Court of Auditors, Special report No 13/2000 on the
expenditure of the European Parliament's political groups. OJ C 181, 28.06.2000. Available at: https://eur-
lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:C:2000:181:0001:0016:EN:PDF
5
Proposal for a Regulation of the European Parliament and of the Council on the statute and funding of European
political parties and European political foundations, COM(2012)499 final of 12.09.2012. Available at: https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52012PC0499&qid=1627213933830
6
Regulation (EU, Euratom) No 1141/2014 of the European Parliament and of the Council of 22 October 2014 on
the statute and funding of European political parties and European political foundations, OJ L 317, 4.11.2014.
Available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014R1141
7
and set out rules for their governance. It also created an independent oversight body, the
Authority for European political parties and foundations (hereinafter, APPF), and strengthened
the control mechanisms. Simultaneously, specific provisions on contributions from the budget to
European political parties were introduced in the Financial Regulation by Regulation No
1142/20147
. These provisions are now found in 221 to 232 of the Financial Regulation8
.
The EUPP/F Regulation was amended twice in order to address, in the run-up to the 2019
elections to the European Parliament, its most critical loopholes by a limited number of targeted
amendments:
 The first of these amendments9
, following a request by the European Parliament, aimed at
increasing the transparency of the links between European and national political parties,
and tightened the conditions for registration as a European political party, rendering it
contingent upon the applicant being supported by seven national political parties from
seven different Member States. Therefore, unlike in the past, individual parliamentarians
could no longer support an application for registration. As a result of this, in 2018 the
APPF deregistered two EUPPs10
and one affiliated EUPF11
, because they did not provide
proof that they satisfied the tightened minimum representation requirements.
 The second amendment12
was triggered by the ‘Facebook/Cambridge Analytica’ case and
was adopted in the framework of the Commission’s 2018 European elections package13
7
Regulation (EU, Euratom) No 1142/2014 of the European Parliament and of the Council of 22 October 2014
amending Regulation (EU, Euratom) No 966/2012 as regards the financing of European political parties (OJ L 317,
4.11.2014, p. 28).
8
Regulation (EU, Euratom) 2018/1046 of the European Parliament and of the Council of 18 July 2018 on the
financial rules applicable to the general budget of the Union, amending Regulations (EU) No 1296/2013, (EU) No
1301/2013, (EU) No 1303/2013, (EU) No 1304/2013, (EU) No 1309/2013, (EU) No 1316/2013, (EU) No 223/2014,
(EU) No 283/2014, and Decision No 541/2014/EU and repealing Regulation (EU, Euratom) No 966/2012 (OJ L
193, 30.07.2018, p.1).
9
Regulation (EU, Euratom) 2018/673 of the European Parliament and of the Council of 3 May 2018 amending
Regulation (EU, Euratom) No 1141/2014 on the statute and funding of European political parties and European
political foundations, OJ L 114I, 4.5.2018. Available at: https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=celex:32018R0673
10
Decision of the Authority for European Political Parties and European Political Foundations of 13 September
2018 to remove Alliance for Peace and Freedom from the Register, OJ C 417, 16.11.2018. Available at: https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.C_.2018.417.01.0011.01.ENG&toc=OJ:C:2018:417:TOC
Decision of the Authority for European Political Parties and European Political Foundations of 29 August 2018 to
remove Alliance of European National Movements from the Register, OJ C 417, 16.11.2018. Available at:
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.C_.2018.417.01.0009.01.ENG&toc=OJ:C:2018:417:TOC
11
Decision of the Authority for European Political Parties and European Political Foundations of 13 September
2018 to remove Europa Terra Nostra from the Register, OJ C 418, 19.11.2018. Available at: https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.C_.2018.418.01.0004.01.ENG&toc=OJ:C:2018:418:TOC
12
Amending Regulation (EU, Euratom) 2019/493 of the European Parliament and of the Council of 25 March 2019
amending Regulation (EU, Euratom) No 1141/2014 as regards a verification procedure related to infringements of
rules on the protection of personal data in the context of elections to the European Parliament, OJ L 85I , 27.3.2019.
Available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32019R0493.
8
aimed at securing free and fair elections. The amendment introduced a verification
procedure aimed at imposing sanctions on EUPP/Fs that deliberately influence, or
attempt to influence, the outcome of elections to the European Parliament by taking
advantage of data protection breaches. This amendment also granted the APPF additional
resources and enhanced its independence.
These amendments were adopted through the ordinary legislative procedure in a record time,
since the provisions had to be in place in time for the elections to the European Parliament of
May 2019.
In July 2019, President von der Leyen announced a new European Democracy Action Plan in her
Political Guidelines14
, to address challenges to democracy, including increasing threats of
external interference in European elections. The action plan, adopted on 3 December 2020,
announced inter alia a legislative proposal to ensure greater transparency on paid political
advertising and the review of the legislation on the financing of European political parties. The
two initiatives are planned for adoption in the Commission’s Work Programme for 2021 before
the end of 202115
. The initiative on paid political advertising complement the revision of the
EUPP/F Regulation by providing for specific requirements for EUPPs to use political ads and a
review process for the Authority to take note of breaches of the rules visible on the basis of
EUPP disclosures.
The European Parliament’s resolution on stocktaking of European elections16
also proposed to
amend the EUPP/F Regulation in order to allow EUPP/F to fully participate in the European
political space, to campaign, to be able to use campaign funds and stand in elections to the
European Parliament, to increase the transparency of their funding (especially as regards the
management of funds from the EU budget and when funding comes from member parties), and
to prohibit donations from private and public bodies from non-EU Member States. It stressed,
nonetheless, that, with a view to fostering pan-European political bonds, membership fees from
political parties located in countries belonging to the Council of Europe could be allowed
provided that this takes place within a framework of enhanced transparency.
13
Content of the 2018 electoral package available at:
https://ec.europa.eu/commission/presscorner/detail/en/IP_18_5681
14
Communication from the Commission to the European Parliament, the Council, the European Economic and
Social Committee and the Committee of the Regions on the European Democracy Action Plan, COM/2020/790
final. Available at: https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A790%3AFIN&qid=1607079662423
15
Communication from the Commission to the European Parliament, the Council, the European Economic and
Social Committee and THE Committee of the Regions Commission Work Programme 2021 A Union of vitality in a
world of fragility, COM/2020/690 final. Available with its annexes at: https://ec.europa.eu/info/publications/2021-
commission-work-programme-key-documents_en
16
European Parliament’s Resolution A9-0211/2020 on stocktaking of European elections (rapporteur P. Durand).
Available at: https://www.europarl.europa.eu/doceo/document/A-9-2020-0211_EN.html
9
Pursuant to Article 38 of the EUPP/F Regulation, its application shall be evaluated in 2021. The
revision clause calls on the European Parliament to publish its evaluation by 31 December 2021
and, no more than six months after the publication of that report, the Commission has to present
a follow-up report, which may be accompanied by a legislative proposal to amend it.
The European Parliament’s Committee on Constitutional Affairs (hereinafter, AFCO) is working
on its own-initiative report pursuant to Article 38 of the EUPP/F Regulation. The draft report,
which is currently planned for adoption during the second plenary session of October 2021,
points out the remaining legal obstacles that may be preventing EUPP/Fs from achieving their
full potential as active players in the European democracy. The draft report calls, inter alia, for:
 distribution of funding based on the number of votes obtained during the latest elections
to the European Parliament, as opposed to the number of seats obtained as a result of
those same elections;
 lowering of the co-financing threshold for EUPP from the current 10% to 5%;
 recognition of different kinds of membership for EUPPs (e.g., associate membership with
political parties located in accession and neighboring countries, as well as in former EU
Member States);
 simplification of the current double accounting system, which is widely considered as
being too burdensome.
On 12 July 202, the European Parliament Committee on Budgetary Control (hereinafter, CONT)
adopted an opinion to the AFCO report, in which:
 calls for the transparency of funding and insists that funding should exclusively support
political activities in line with Article 2 TEU;
 sees the possibility for improvements, particularly regarding the level of detail and
comparability of the requested information on EUPP activities in campaigns to the
elections to the European Parliament;
 suggests reducing the required own resources for EUPP to 5% of the eligible expenditure;
 calls on the Commission to clearly define the requirements related to the visibility of the
affiliation of national political parties to EUPP.
This impact assessment supports the legislative proposal that the Commission intends to adopt
pursuant to Article 38 of the EUPP/F Regulation and to the Commission’s political priorities. It
draws on the outcome of the informal consultations that the Commission carried out with the
main stakeholders, the outcome of the open public consultations on the European Democracy
Action Plan and on the revision of the EUPP/F Regulation, and two external studies on the
evaluation of the current EUPP/F Regulation and the possible impacts of its revision.
AFCO is also working on a separate legislative own initiative report on the reform of the
European electoral law. Mr Ruíz Devesa’s (S&D/ES) draft report of 1 July 2021 proposes the
10
introduction of an EU-wide constituency in which lists would be headed by each political
family’s candidate for the position of President of the Commission. The draft report also
suggests including ‘common provisions governing expenditure linked to the electoral campaign
for the elections to the European Parliament for each entity admitted for the purpose of tabling a
list of candidates for members of the European Parliament in the EU-wide constituency’. It
therefore calls for strong coordination with the upcoming revision of the EUPP/F Regulation.
However, the scope of AFCO’s report is broader and its adoption has been postponed to 2022 in
order to accommodate the outcome of the Conference on the Future of Europe. Bearing this in
mind, the revision of the EUPP/F regulation should remain neutral and accommodate any of the
possible outcome of the Conference, notably as regards the possibility of introducing a lead
candidate system or transnational lists.
1.2. Current challenge
One of the Commission’s six headline ambitions is ‘A new push for European democracy’. This
implies fostering the European dimension of European elections and increasing the link between
citizens and European decision-making processes.
Increasing citizens’ turnout at the elections to the European Parliament remains a challenge.
Currently, 55% of Europeans ‘totally agree’ that ‘the voice of EU citizens should be more taken
into account for decisions relating to the future of Europe’. Way above all other items, ‘voting in
European elections’ is seen as the main way of making sure one’s voice is heard by decision-
makers at EU level. While the, turnout was 50.6% of EU citizens in 2019, which represents a
sharp increase compared to the 42.6% turnout in 2014, it remains lower than at national
elections17
and far from participation levels seen before 1999. It is expected that a greater
visibility and activity of EUPPs would contribute to foster citizens’ participation in the election
to the European parliament.
EUPP/F should play an important role in increasing European citizens’ involvement in European
politics. According to International IDEA18
, however, they face a specific challenge in achieving
this objective because European institutional and electoral frameworks do not provide the same
structure and tools for EUPP as their national counterparts are used to working with, and which
enable national parties to attract the attention and interest of citizens or to be featured in the
media. Any possible revision of the EUPP/Fs Regulation should take this specificity into
account.
The Commission’s report on the 2019 elections to the European Parliament19
points to the
multiple challenges faced by the European democracy, not only from within the EU but also
17
Special Eurobarometer 500, Future of Europe (October-November 2020). Available at:
https://www.europarl.europa.eu/at-your-service/files/be-heard/eurobarometer/2021/future-of-europe-2021/en-key-
findings.pdf
18
Van Hecke S. at al., (2018), Reconnecting European Political Parties with European Union Citizens, International
IDEA Discussion paper 6/2018. https://www.idea.int/sites/default/files/publications/reconnecting-european-
political-parties-with-european-union-citizens.pdf
19
Communication from the Commission to the European Parliament, the Council, the European Economic and
Social Committee and the Committee of the Regions, Report on the 2019 elections to the European Parliament,
11
from outside, such as rising extremism, election interference, the spread of manipulative
information and threats against journalists.
Foreign interference has become a major security challenge for democracies. The EU provides
no exception and, in the last few years, has significantly stepped up its efforts to counter this
threat. A specific type of foreign interference is the foreign funding of political parties, be it
national or European. At the national level, regulations banning or limiting foreign funding are
currently in place in most Member States, but there is still significant variation across them20
. At
EU level, the recent reforms of the EUPP/F Regulation have banned contributions from abroad.
Notwithstanding such changes to political parties’ regulations, cases of foreign funding are still
being reported in several Member States, with foreign actors exploiting regulatory loopholes to
channel funds or provide other types of support21
. Furthermore, the European Parliament’s
resolution on stocktaking of European elections22
highlighted the need to strengthen some of the
rules applicable to the EUPP/F in order to prevent external interference, in particular by
improving transparency as regards sources of funding for EUPP so as to tackle indirect funding
by foreign interests channeled through national means or private donations. This challenge will
have to be taken into consideration when assessing the possibilities for allowing membership
fees from member parties located in non-EU countries.
1.3. Procedural issues and consultation of interested parties
From the outset, the Commission aimed at a very inclusive approach, identifying and consulting
the main stakeholders throughout the preparation of its legislative proposal23
.
Between November 2020 and June 2021, the Commission reached out to all EUPP/Fs, as well as
to the APPF and the European Parliament’s Authorising Officer for an initial, informal exchange
of views. During the same period, the Commission also engaged in a wide ranging outreach
exercise with the co-legislators, notably through the Member States’ representatives in the
Council Working Party on General Affairs (hereinafter, GAG) and AFCO Members and
coordinators of political groups in the Parliament.
The Commission also met with a number of experts, such as the representatives of the Office for
Democratic Institutions and Human Rights of the Organisation for Security and Co-operation in
Europe (hereinafter, OSCE/ODIHR), the Research Centre for the Study of Parties and
Democracy (hereinafter, REPRESENT) and the European Democracy Consulting, for a
COM(2020)252. Available at: https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52020DC0252&qid=1627216994733
20
Bressanelli, E. (2021), Investing in destabilisation: How foreign money is used to undermine democracy in the
EU, https://www.europarl.europa.eu/meetdocs/2014_2019/plmrep/COMMITTEES/INGE/DV/2021/06-
22/Investingindestabilisation_EXPO_STU2021653631_EN.pdf
21
INGE Working document on covert funding of political activities by foreign donors of 22 April 2021 (rapporteur
Sandra Kalniete). Available at: https://www.europarl.europa.eu/doceo/document/INGE-DT-689654_EN.pdf
22
Idem footnote 14.
23
For details, see Consultation Strategy in Annex II.
12
discussion on the revision of the EUPP/F Regulation and the Commission’s initiative on the
transparency of paid political advertising.
The roadmap/inception impact assessment on the revision of the EUPP/F Regulation was
published for comments between 17 March and 14 April 2021, and public consultation was open
for feedback between 30 March and 22 June 2021.
In that framework, 21 replies were received, 19 online and two by email, from 14 Member
States. Of the 19 online respondents, seven were EU citizens, six were non-governmental
organisations (hereinafter, NGO), one was a representative of a national authority in a Member
State, one represented a research organization, one represented a company and three represented
other organisations. The two replies received by email were submitted by a Member State and an
NGO. While the consultation received limited number of replies, 62.5% of the respondents found
the EUPP/F Regulation either useful or very useful. Almost half of the respondents (47.4%)
believed that EUPP do not fulfil their role in representing European citizens, and almost 80% of
the respondents considered that EUPP lacked visibility for European citizens.
In addition, the Commission also drew on the feedback received, between 15 July and 15
September 2020, to the open public consultation on the European Democracy Action Plan
(hereinafter, EDAP) that showed broad support to the scope of the revision of the EUPP/F
Regulation.
The full analysis of the feedback received via these three channels can be found in Annex II.
13
2. PROBLEM DEFINITION
Based on the informal consultations with relevant stakeholders, the open public consultation and
the analysis of the application of the EUPP/F Regulation, the Commission could identify a
number of shortcomings in the current regime. These shortcomings are linked to a) the funding
of EUPP/F and b) EU values, democracy and transparency, and c) enforcement and
administrative burden. The Commission considers that the problems identified under the funding
provisions of the Regulation are the most pertinent in the Regulation’s underperformance. The
remaining loopholes in the financial provisions, undermine EUPP/Fs financial viability, their
ability to fulfill their constitutional mission, and allow increased risk of potential foreign
interference and weak financial management.
Figure 1 – Identified problems and their drivers
14
2.1. The problems that require action
Problems
Funding provisions
- EUPP/F's limited capacity to
autofinance
- Remaining risk of interference via
donations
- Impossibility of EUPP/F to accept
membership fees from members from
non-EU countries
EU values, democracy and
transparency
- Inability to fulfil EUPP/F’s mission to
shape the European political space
-Lack of gender balance in European
politics
-Missing guarantees for the respect of EU
values by EUPP/Fs
Enforcement and administrative
burden
- Authority not sufficiently equipped to
fulfil its potential
-Excessive administrative burden
- Perceived legal uncertainty
- EU's financial interests not sufficiently
safeguarded
Problem drivers
Regulatory
failure
Funding provisions
- Simplistic categorisation of types of
revenues
- Loopholes in transparency regime for
donations
- Restrictive financial rules
EU values, democracy and
transparency
- Lack of visibility for EUPP/Fs at national level
- EUPPs' limited role at national level
- Regulation doesn't actively promote gender
balance
- Non-operational verification mechanism for
EU values
Enforcement and administrative
burden
- Lack of investigative powers for APPF
- Rigidity of the sanctions regime
- Lack of resources for APPF
- Double accounting requirement
- Unclear division of responsibilities between APPF and EP
Authorising Officer
- Unclear rules on eligibility during deregistration
15
a) Funding provisions
i) Article 17(4) of the EUPP/F Regulation establishes a ceiling for public funding for EUPP
at 90% of their total eligible expenditure. For EUPF, this ceiling is set at 95% of their
total eligible expenditure24
. This means that EUPP/F have to secure, respectively, 10%
and 5% of their expenditure from own resources.
EUPP have been entitled to annual funding from the EU budget since 2004, and EUPF
since 2007. The total amount of EU funding for EUPP/F has significantly increased over
time. While EUPP benefited from EUR 6.5 million of EU funding in 2004, this amount
rose to EUR 46 million in 2021, with a peak in the 2019 election year when EUR 50
million was earmarked for them. At the same time, EU funding for EUPF increased from
EUR 5 million in 2008 to EUR 23 million in 2021.
Figure 2 – Level of EU funding for European political parties and foundations
Source: European Parliament Research Service
If EUPP/F do not manage to collect the matching own resources, their EU funding would
be lowered until it corresponds to 90% and 95% of the total expenditure, respectively.
This means that, if EUPP/F wanted to benefit from the increased budgetary resources,
they would have to secure more own resources over the years, in absolute terms. This,
however, has proven problematic not only for smaller political parties and foundations,
but even for the larger ones (see Figure 3 below)25
.
24
Before the 2018 amendment of the EUPP/F Regulation, the ceiling for both EUPP and EUPF was set at 85% of
their total eligible expenditure.
25
I. Anglmayer (2021), Statute and funding of European political parties under Regulation 1141/2014 -ex post
evaluation, p.10. Available at:
https://www.europarl.europa.eu/RegData/etudes/STUD/2021/662646/EPRS_STU(2021)662646_EN.pdf
16
Figure 3 – Maximum eligible contribution and final contribution to EUPPs from the
EU budget per year
Source: W. Wolfs, based on the reports of the Secretary-General of the European
Parliament and Financial Overviews of the European Parliament’s DG FINS26
The European Parliament’s study on the ex-post evaluation of the EUPP/F Regulation27
argued that this budgetary pressure had led to ‘questionable practices’ and ‘creative
solutions’ regarding the financial management of these organisations and pointed to
irregularities identified by the European Parliament’s Authorising Officer and the
European Court of Auditors28
.
ii) The EUPP/F Regulation does not provide enough guarantees against unwanted foreign
interference in European politics. Foreign actors may be able to circumvent the current
provisions through intermediaries based in EU Member States, using funds originating
from non-EU Member States. For most EUPPs, donations only constitute a small share of
own resources but, as shown in the graph below, the risk of foreign interference is real in
case of those EUPPs that rely heavily on them.
Figure 4 – Own resources structure of European political parties (2018-2019)
26
Wolfs W. (2021), Impact assessment study – Revision of Regulation 1141/2014, unpublished.
27
I. Anglmayer (2021), Statute and funding of European political parties under Regulation 1141/2014 -ex post
evaluation. Available at:
https://www.europarl.europa.eu/RegData/etudes/STUD/2021/662646/EPRS_STU(2021)662646_EN.pdf
28
European Court of Auditors, Opinion 5/2017 concerning the proposal for a regulation of the European Parliament
and of the Council amending Regulation (EU, Euratom) No 1141/2014 of the European Parliament and the Council
of 22 October 2014 on the statute and funding of European political parties and European political foundations, para.
11 and 12. Available at: https://www.eca.europa.eu/en/Pages/DocItem.aspx?did=44564
€ -
€ 2
€ 4
€ 6
€ 8
€ 10
€ 12
€ 14
€ 16
EPP PES ALDE EGP PEL EDP EFA ECPM ECRP IDP
Millions
Max. Contribution 2018 Final Contribution 2018 Max. Contribution 2019 Final Contribution 2019
17
Source: W. Wolfs, based on the financial reports of the European political parties and
foundations29
iii) Currently EUPP/Fs have members from outside the EU (see Annex VI for the list of non-
EU countries where EUPP/F’s members come from). Until the entry into force of the
EUPP/F Regulation, it was common practice for non-EU members to contribute
membership fees to the revenues of European political parties. Under the current EUPP/F
Regulation, and in order to safeguard against foreign interference, EUPP/F cannot accept
membership fees from their member parties located in non-EU Member States. This
prohibition was confirmed by ruling T-107/19 of the European Union Court of Justice
(hereinafter, EUCJ) of 25 November 202030
. The prohibition under the current regime,
however, hinders the EUPP/F auto-financing capacity, especially in the light of the UK
withdrawal from the EU, due to which EUPP/F have lost some of their long-standing
national affiliates. In addition to the financial problem it causes, EUPP/F argue that this
prohibition sends the wrong political message both to their previous, pro-European
members and to their members in candidate and neighbourhood countries.
b) EU values, democracy and transparency
i) The mission of EUPP/F is to contribute to shaping a truly European political space, while
Eurobarometer surveys consistently show a lack of European political awareness among
citizens. For instance, 43% of EU citizens would be more inclined to turn out on
29
Wolfs W. (2021), Impact assessment study – Revision of Regulation 1141/2014, unpublished.
30
Judgment of the General Court of 25.11.2020, Alliance of Conservatives and Reformists in Europe/European
Parliament, T-107/19, EU:T:2020:560. Available at:
https://curia.europa.eu/juris/document/document.jsf;jsessionid=D94B8C2205E30C3FDCC31F18436119E5?text=&
docid=234334&pageIndex=0&doclang=en&mode=lst&dir=&occ=first&part=1&cid=1694530
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
EPP PES ALDE EGP PEL EDP EFA ECRP ECPM IDP
Membership Fees Donations Contributions in kind
Other Income Reserves used as revenue
18
election’s day if they were better informed about the EU and its impact on their daily
life31
. In addition, in a Eurobarometer survey following the 2019 elections to the
European Parliament, respondents said having chosen their party of reference almost
equally based on the party’s proposals on European (43%) versus national (42%) issues.
The other main reason for choosing a party was that the respondent always votes for them
(40%)32
. This indicates a need to strengthen the European dimension of the elections to
the European Parliament and the ability of EUPP/F to promote European political
awareness.
ii) The Venice Commission33
recommends that the internal functions and processes of
political parties should generally be free from State interference. They make
recommendations for additional actions in three areas: national minorities, people with
disabilities and gender.
Article 3 of the EUPP/F Regulation, laying down the recommendations for registration, is
already aligned with the recommendations of the Venice Commission on minorities.
Concerning people with disabilities, there is a specific recommendation of the Council of
Europe, which is also in line with Article 21 of the current Regulation, on non-
discrimination. Gender is the area where the Venice Commission goes the furthest in its
recommendations, referring to national best practices, including mandatory gender
quotas.
The European Parliament, in its report34
on the 2012 Commission proposal35
for the
EUPP/F Regulation, called for ensuring gender equality in the composition and in the
formation of the European political parties and within their affiliated European political
foundations while fully respecting internal party democracy. The European Parliament’s
amendments, however, were not retained during the interinstitutional negotiations. In
2018 and 2019, during the previous two revisions of the EUPP/F Regulation, both
Council and Parliament were reluctant to touch upon internal party democracy issues and
could only agree to a voluntary measure on gender equality in Recital 5, which has
proven insufficient to ensure gender parity.
31
Special Eurobarometer 477 (2018) – Democracy and Elections. Available at:
https://ec.europa.eu/commfrontoffice/publicopinion/index.cfm/Survey/getSurveyDetail/search/477/surveyKy/2198
32
European Parliament Special Eurobarometer 91.5. Available at: https://www.europarl.europa.eu/at-your-
service/files/be-heard/eurobarometer/2019/post-election-survey-2019-complete-results/executive-summary/en-post-
election-survey-2019-executive-summary.pdf
33
European Commission for Democracy through Law (Venice Commission) & OSCE Office for Democratic
Institutions and Human Rights (2020), Guidelines on Political Party Regulation (2nd edition), paragraph 61.
Available at: https://www.venice.coe.int/webforms/documents/default.aspx?pdffile=CDL-AD(2020)032-e
34
Available at https://www.europarl.europa.eu/doceo/document/A-7-2013-0140_EN.pdf
35
COM(2012) 499, available at https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52012PC0499&from=EN
19
The World Economic Forum’s Global Gender Gap Report36
found that the gender gap in
political empowerment remains globally the largest of the four gaps tracked37
, with only
22% closed to date, having further widened since the 2020 edition of the report by 2.4
percentage points. At the current rate of progress, the World Economic Forum estimates
that it will take 145.5 years to attain gender parity in politics. While there has been a
positive trend towards gender balance in the composition of the European Parliament
after the 2019 elections, there is still progress to be made in achieving gender parity. As
of January 2021, the percentage of female Members of the European Parliament stood at
38.9% compared to 16.6% in the first directly elected legislature in 197938
. This is above
the world average for national parliaments and above the European average for national
parliaments, which stands at 30.5%. However, the European Parliament’s Research
Service (hereinafter, EPRS) points to large differences between Member States, and
identifies the low share of women among candidates as an underlying cause in countries
with a low proportion of female Members elected to the European Parliament. This, in
turn, may be due to internal political party processes. It appears that EUPPs missed an
opportunity to encourage their national member parties to promote gender balance on
party lists39
. In addition, gender parity in EUPP/F governing bodies has not been
achieved either.
Figure 5 – Share of men and women in EUPP/F governing bodies
Source: W. Wolfs, based on Register of the Authority for European political parties
36
World Economic Forum (2021), Global Gender Gap Report 2021. Available at:
http://www3.weforum.org/docs/WEF_GGGR_2021.pdf
37
The three other tracks being economic participation and opportunity, educational attainment, and health and
survival.
38
Shreeves R. with Boland N. (2021), Women in politics in the EU – State of play. Available at:
https://www.europarl.europa.eu/RegData/etudes/BRIE/2021/689345/EPRS_BRI(2021)689345_EN.pdf
39
Only two of the six largest European political parties had mentioned gender equality in their election manifesto
and none had called specifically for the adoption of gender quotas.
65,05%
34,95%
European political parties
Men Women
67,29%
32,71%
European political foundations
Men Women
20
and European political foundations40
iii) The EUPP/F Regulation’s mechanism to verify the EUPP/F compliance with EU values
has never been triggered to date. However, the Commission’s Annual Rule of Law
Report for 202041
identified serious challenges, cases where the resilience of rule of law
safeguards is being tested and where shortcomings become more evident. This raises the
question of whether or not the current mechanism is fit for purpose.
c) Enforcement and administrative burden
i) The EUPP/F Regulation established, for the first time, an independent supervisory body,
the APPF, in order to ensure an impartial oversight over the activities of EUPP/F. Due to
various factors discussed in Section 2.2 of this impact assessment (see below), the APPF
is currently not sufficiently equipped to fulfil its potential.
ii) The EUPP/F Regulation inflicts substantial administrative burden on EUPP/F, linked, on
the one hand, to the use of the International Accounting Standards and, on the other hand,
to the triple verification procedure involving the external auditor, the APPF and the
Authorising Officer of the European Parliament. While significant variations exist across
EUPP/F, they spend around 1 260 h (approximately 0.78 full time equivalent) on an
annual basis on administrative tasks, with an additional EUR 20 000 spent on tasks that
are outsourced. Out of these EUR 20 000, EUPP/Fs spend on average more than EUR 8
00042
on the preparation of the annual financial statements in accordance with the
international accounting standards, which is usually an outsourced task. While this can be
manageable for the middle-sized and larger EUPP/F – although their expenses are on
average also higher because of their larger size – it puts a particular strain on the
functioning of the smaller ones. With regard to triple verification process of the accounts,
the examination of the financial reports by both the APPF and the Authorising Officer of
the European Parliament (in addition to the assessment of the external auditor) leads to
the double spending of EU taxpayers’ money. In addition, the APPF and the European
Parliament’s Authorising Officer have sometimes applied a diverging interpretation of
the rules, leading to an increased workload and legal uncertainty for the EUPP/F43
.
iii) Throughout the consultation process, EUPP/Fs signalled a perceived legal uncertainty
due to the unclear division of responsibilities between the APPF, on the one hand, and the
European Parliament’s Authorising Officer, on the other.
40
Wolfs W. (2021), Impact assessment study – Revision of Regulation 1141/2014, unpublished.
41
Communication from the Commission to the European Parliament, the Council, the European Economic and
Social Committee and the Committee of the Regions, 2020 Rule of Law Report - The rule of law situation in the
European Union, COM/2020/580 final. Available at: https://eur-lex.europa.eu/legal-
content/EN/TXT/?qid=1602583951529&uri=CELEX%3A52020DC0580
42
Wolfs W. (2021), Impact assessment study – Revision of Regulation 1141/2014, p. 5, unpublished.
43
Based on data received from European political parties and foundations for the external impact assessment study
conducted by W. Wolfs, Katholieke Universiteit of Leuven, in June 2021.
21
iv) At the informal consultations conducted by the Commission, both the APPF and the
European Parliament’s Authorising Officer indicated that the protection of financial
interests of the EU was not sufficiently ensured in case of the deregistration of an EUPP
or EUPF.
2.2. Problem drivers
The above identified problems derive from a regulatory failure, i.e. the existing Regulation has
failed to achieve its objectives (which remain valid) and has proven needlessly costly. The
specific problem drivers can be grouped up according to a) funding provisions, b) EU values,
democracy and transparency and c) enforcement and administrative burden.
a) Funding provisions
i) The reasons for EUPP/F’s difficulty raising own resources are twofold:
 The EUPP/F Regulation acknowledges only two categories of revenues; namely,
contributions and donations. This means that everything which is not a membership
contributions is considered as a donation, which are subject to a very stringent legal
regime. EUPP/F argue that this categorisation is too simplistic and excludes the
possibility to raise own resources from other sources such as sponsorship, publication
fees, participation fees, sales, etc. The draft report prepared by AFCO also underlines that
the categories of revenue are defined too narrowly in the EUPP/F Regulation44
.
 At the same time, the EUPP/F Regulation does not allow for contributions and donations
coming from countries outside the EU. This has particular consequences following the
UK withdrawal from the EU, as EUPP/F could not continue collecting membership fees
from some of their traditional members45
.
ii) The EUPP/F Regulation contains some loopholes in its transparency regime for donations. Its
Article 20 prohibits certain types of donations (namely, donations from non-EU countries,
anonymous donations, donations exceeding EUR 18 000). However, these prohibitions are
not accompanied by corresponding enforcement powers for the APPF46
. In addition, NGO
voiced their concern over the delays in the publication of information related to donations47
.
They advocate for the real-time publication of such information, especially in electoral
period, to avoid foreign interference in elections so citizens can cast their ballot in an
informed manner. OSCE/ODIHR also points out to these delays in the publication of
44
Point 13 of the draft report prepared by AFCO. Available at:
https://www.europarl.europa.eu/doceo/document/AFCO-PR-692733_EN.pdf
45
Based on the Commission’s informal consultations with EUPP/F.
46
See for instance the intervention of M. Adam, Director of the APPF, in AFCO on 15 June 2021.
47
Kergueno, R. (2017), Fraud and boats: funding European political parties. Available at:
https://transparency.eu/boatfraud/
22
information related to donations and advocate for more frequent reporting on donations (and
also contributions)48
.
iii) The APPF considers contributions from non-EU Member States to be inadmissible based on
current case law49
that confirms that entities from outside the EU cannot make financial
contributions to EUPP50
. This hampers EUPP/F’s meaningful relations with longstanding
partners and previous members and, consequently, they feel limited in fulfilling their mission
to promote democratic values beyond the EU’s borders.
b) EU values, democracy and transparency
i) A reason why EUPP/F cannot fulfil their potential to create a truly European political spaces
could be their lack of visibility at national level. Despite the obligation set out in Article
18(2a) for national affiliates to display the logo of the EUPP they are member of, the
European Democracy Consulting found that all EUPPs have national member parties, which
do not display their logo on their webpage, with the only exception of the European
Democratic Party. Moreover, 85% of national member parties do not display the logo of their
EUPP of affiliation in a “clear and user-friendly” manner, if we define this as the top screen
of national parties’ webpages. EUPP logos are over-represented in the bottom screen, with
close to 58% of logos found there. An overwhelming majority of logos are clearly “not
visible” (60%, and over 69% if we include websites not displaying any logo). Focusing only
on logos ‘clearly visible’ or ‘moderately visible’, 71% logos fail the test, and up to 78%, if
we include websites not displaying any logo51
.
Another limitation for EUPPs to perform their democratic function could be associated with
the current prohibition to fund, directly or indirectly, elections, political parties, candidates or
other foundations at national level52
. To address the ambiguity of ‘indirect funding’, in the
run-up to the 2019 elections to the European Parliament, the APPF and the European
Parliament’s Authorising Officer developed five principles for campaigns for the elections to
the European parliament, the respect of which would mean eligibility for EU funding53
.
48
OSCE Office for Democratic Institutions and Human Rights (2021), Submission to the European Commission and
to the European Parliament, Preliminary Comments on Reforming Regulation 1141/2014 of the European
Parliament and of the Council on the statute and funding of European political parties and European political
foundations (unpublished).
49
Judgment of the General Court of 25.11.2020, Alliance of Conservatives and Reformists in Europe/European
Parliament, T-107/19, EU:T:2020:560. Available at:
https://curia.europa.eu/juris/document/document.jsf;jsessionid=D94B8C2205E30C3FDCC31F18436119E5?text=&
docid=234334&pageIndex=0&doclang=en&mode=lst&dir=&occ=first&part=1&cid=1694530. See paragraphs 155-
162 of the judgement.
50
Annual activity report 2020 of the APPF. Available at:
http://www.appf.europa.eu/cmsdata/238104/2020_AnnualActivityReport_AuthorityEUPPsEUPFs.pdf
51
https://eudemocracy.eu/logos-project
52
Article 22(2) of the EUPP/F Regulation.
53
Annual Activity Report 2020 of the APPF, p. 15. Available at:
http://appf.europa.eu/cmsdata/238104/2020_AnnualActivityReport_AuthorityEUPPsEUPFs.pdf
23
While this has improved legal certainty to a certain extent, it did not allow for the increased
direct involvement of EUPP/F in campaigns in Member States.
ii) Currently, the EUPP/F Regulation does not contain any transparency obligation on gender
parity; co-legislators only agreed to a voluntary measure in Recital 5. While there has been a
positive trend towards gender balance in the European Parliament throughout the years,
voluntary measures have proven insufficient to ensure gender parity.
iii) The verification mechanism foreseen in Article 10(3) of the EUPP/F Regulation is too
complex to be triggered. The APPF can only inform the European Parliament, the
Commission and the Council about its doubts concerning compliance by a specific EUPP or
EUPF with EU values, but cannot start the verification process without the request by the
European institutions to act54
. The APPF should also consider the opinion of the committee
of independent eminent persons. Finally, the APPF’s decision to de-register a non-compliant
EUPP can be overruled by the European Parliament and the Council within a three-month
period on grounds related to the assessment of compliance with the conditions for
registration. The procedure, thus, includes several thresholds that make the enforcement of
the compliance requirement more difficult. Furthermore, the exact object of the verification
mechanism is unclear. Namely, the EUPP/F Regulation does not specify if only the
compliance of EUPP/F themselves should be verified, or also that of their national member
parties. These weaknesses have a negative impact on the effectiveness of the compliance
mechanism, and on the ability of the EU institutions to hold EUPP/F accountable for a
potential breach of respect for the EU’s fundamental values. The mechanism, therefore, only
constitutes a limited deterrence for EUPP/F.
c) Enforcement and administrative burden
i) The APPF is currently not sufficiently equipped to fulfil its potential:
 The EUPP/F Regulation does not provide it with sufficient investigative powers in case
of donations55
. The APPF has advocated for clarifying its powers with regard to donors
from the European Union (i.e., natural and legal persons) because those actors may act as
strawmen to channel funds to EUPP/F, but have no legal obligation to cooperate with the
APPF. In addition, the EUPP/F Regulation does not set out minimum documentation
standards or internal control mechanisms for accepting donations, so the APPF
sometimes lacks the evidence to effectively verify donations as well as mean to obtain it.
In the same vein, in its submission to the Commission and the European Parliament,
OSCE/ODIHR also pointed to the discrepancy between national best practices and the
54
Article 10(3) of the EUPP/F Regulation.
55
Current tasks of the APPF include: decision on the registration and de-registration of European political parties
and foundations; verifies that the conditions for registration are being complied with; establishes and manages a
register of European political parties and foundations; exercises control of compliance by European political parties
and European political foundations with specific obligations (in cooperation with the European Parliament and by
the competent Member States); imposes financial sanctions; publishes specific information on its website, in line
with Article 32.
24
EUPP/F Regulation provisions on the powers of the APPF and urged for endowing it
with legal enforcement powers, so it can investigate and pursue potential violations56
.
 So far, the APPF has never made use of the sanction regime. According to some views,
this could be due to the rigidity of the regime that does not allow the APPF to either
prioritise the breaches of the EUPP/F Regulation that should be pursued or to modulate
the level and nature of sanctions to make it proportionate to the nature of the breach,
including in cases of neglect.
 The APPF also warns about its limited resources in its budgetary plan for 2021: “Most
recent experience suggests that the Authority’s new setting is sufficient to handle the day-
today, ordinary operations. However, the Authority comes under significant strain when
faced with extraordinary or non-recurrent work streams such as formal investigations,
litigation before the Union Courts and, potentially, verification procedures of matters
related to European elections or matters affecting the respect for the values on which the
Union is founded on the part of European political parties or European political
foundations, as introduced by the European legislator”57
.
Table 1 – Total Resources Allocated to the APPF (direct support from the European
Parliament
+ APPF budget item)
2021 EUR 1 542 825
2020 EUR 1 539 200
2019 EUR 1 546 000
Source: APPF Draft Budgetary Plans58
ii) The introduction of double accounting standards, operated at the 2018 revision of the
EUPP/F Regulation, is seen by all actors involved as unnecessary, ineffective, costly and
unfit for the nature of EUPP/F. Stakeholders agree that the administrative cost linked to the
introduction of the International Accounting Standards for such small organisations
outweighs the benefits. In practice, eight out of ten EUPPs are based in Belgium, so the
comparability of accounts is largely ensured. In addition, the APPF concluded, in its 2020
Annual Activity Report, that the use of templates prepared by the APPF has significantly
56
OSCE/ODIHR (2021), Submission to the European Commission and to the European Parliament, Preliminary
Comments on Reforming Regulation 1141/2014 of the European Parliament and of the Council on the statute and
funding of European political parties and European political foundations (unpublished).
57
APPF Draft budgetary plan for 2021, p. 1. Available at:
http://www.appf.europa.eu/cmsdata/216549/Draft%20budgetary%20plan%202021.pdf
58
APPF Draft budgetary plan for 2020. Available at:
http://www.appf.europa.eu/cmsdata/214214/Draft_budgetary_plan_2020.pdf and APPF Draft budgetary plan for
2019. Available at: http://www.appf.europa.eu/cmsdata/214215/Draft_budgetary_plan_2019.pdf
25
increased the comparability of the different EUPPs’ and EUPFs’ submissions, and has also
helped to harmonise the APPF’s checks of the different files59
.
iii) The perceived legal uncertainty derives from Article 24(1) of the EUPP/F Regulation which
states that ‘control of compliance by European political parties and European political
foundations with their obligations under this Regulation shall be exercised, in cooperation,
by the Authority, by the Authorising Officer of the European Parliament and by the
competent Member States’. The fact that control is not concentrated in the hand of a single
body sometimes results in diverging interpretations of the provisions.
iv) Regarding the protection of the financial interest of the EU following the deregistration of a
European political party or foundation, the EUPP/F Regulation is currently unclear on the
eligibility of their expenditure during the three-month period that the EUPP/F Regulation
foresees for the entry into force of a deregistration decision. In addition, the Regulation is not
in line with Article 297 TFEU that stipulates that ‘(...) decisions which specify to whom they
are addressed, shall be notified to those to whom they are addressed and shall take effect
upon such notification’.
2.3. Who is affected by the identified problems and in what ways?
The EUPP/F Regulation applies to a limited number of actors; namely, the ten registered EUPP
and their ten affiliated EUPF, the APPF and the Authorising Officer of the European Parliament.
By setting criteria for registering as a EUPP, the EUPP/F Regulation has an impact on pan-
European political movements that currently do not meet the required criteria. These movements,
therefore, do not benefit from the European legal statute established by the EUPP/F Regulation
and, thus, from EU funding.
European Political Parties
As of April 2021, ten EUPPs are officially registered with the APPF (see Figure 6). These are the
main actors affected by the shortcomings identified in the current legal regime.
Figure 6 – EUPPs registered with the APPF
59
APPF Annual Activity Report 2020. Available at:
http://www.appf.europa.eu/cmsdata/238104/2020_AnnualActivityReport_AuthorityEUPPsEUPFs.pdf
26
Source: APPF60
The EUPP/F Regulation currently recognises contributions and donations as possible sources of
own resources for EUPPs. At the same time, it sets out a 10% co-financing rate that EUPPs need
to collect in order to match the public funding they receive. These two provisions together have a
negative effect particularly on small EUPPs that would need additional resources to meet the co-
financing rate, but these possible revenue sources (sponsorships, participation fees, etc.) are
currently not recognised by the EUPP/F Regulation. Therefore, EUPP/F Regulation currently
limits the ability of EUPPs to obtain funding.
The current rules prohibit contributions from member parties located in countries outside the EU.
This prohibition, coupled with the restrictive definition of membership, poses a problem to some
EUPPs that have full or auxiliary members from, for instance, the UK or neighbourhood
countries. This problem is at the same time financial (lower level of contributions) and political
(not being able to send the message that they are equal members of the European political
family). Besides, the lack of transparency of donations might cause unfair advantages to those
abusing the system.
The ambiguity of the provisions on indirect funding and the eligibility of expenditure limit the
possibility of EUPPs to closely work together with their national member parties, especially on
campaigns. This, in turn, does not allow for EUPP to fulfil their potential in awareness raising on
European issues in Member States and limits their visibility at national level. This legal
constraints also prevent EUPP from, on the one hand, educating citizens on the European cause
and, on the other hand, providing training to those who would like to go into politics. Citizens’
education and better prepared political activists and candidates would, however, be indispensable
for strengthening European democracy.
Double accounting standards increase administrative burden for EUPP without offering real
added value. As they are generally small organisations with limited human and financial
resources, this additional administrative burden may limit their capacity to carry out their core
tasks.
60
http://appf.europa.eu/appf/en/parties-and-foundations/registered-parties
27
Some EUPP feel that they face difficulties receiving immediate legal remedy in disputes in the
absence of an in between appeal instance against the APPF decisions before the EUCJ. This
means that disputes either may stay without legal resolution, or legal remedy is only available in
years’ time.
European Political Foundations
Currently, ten EUPF are registered with the APPF (see Figure 7). They must be affiliated to a
EUPP and they play a vital role in both complementing the objectives of that party and in
observing, analysing and contributing to debates on various political topics. Typically, this
involves organizing trainings, seminars, conferences and conducting studies on issues relevant
for European public policies61
.
Figure 7 – EUPFs registered with the APPF
61
See information on the European Parliament’s website on contracts and grants:
https://www.europarl.europa.eu/contracts-and-grants/en/political-parties-and-foundations/european-political-
foundations
28
Source: APPF62
However, the restricted definition of revenue sources, contributions versus donations, does not
allow EUPF to properly raise funding. The current definition of contributions does not recognise
two-tier memberships; this is not just a financial issue for them, but also a matter of messaging.
It also limits their choice of partners for certain activities. In addition, the prohibition of
contributions from members located in countries outside the EU has a similar effect on them as
on EUPP.
Current rules on the eligibility of expenditure and indirect funding does not allow for fulfilling
their mission, namely providing training for future candidates (in particular female candidates)
and awareness raising on European political issues. It also hinders proper cooperation with their
national members. Also, some EUPFs complained about a lack of legal certainty as the current
ambiguity of the definition of indirect funding leaves room for interpretation. This again hinders
the organisation of certain activities that their mission would require.
Some EUPFs claim that the current undifferentiated sanctions regime may negatively affect the
smaller among them because, for a relatively small irregularity, the sanction may cause
bankruptcy. This, in turn, has a negative impact on political plurality.
EUPFs share the same concern as EUPPs regarding double accounting requirements and the
availability of legal remedies (see above).
The Authority for European political parties and foundations
The current provisions do not provide sufficient investigative powers to the APPF to trace the
origin of donations. Furthermore, the lack of a more nuanced regime on sanctions impedes the
APPF’s capacity to ensure proper enforcement of the rules contained in the EUPP/F Regulation.
While the available human resources are sufficient to handle day-to-day operations, the APPF
reported of coming under strain when faced with multiple overlapping tasks or with
extraordinary or non-recurrent work streams such as litigation before the EU courts or formal
proceedings pursuant to the EUPP/F Regulation63
.
Citizens
62
http://appf.europa.eu/appf/en/parties-and-foundations/registered-foundations
63
Annual Activity Report 2020 of the APPF (2021). Available at:
http://www.appf.europa.eu/cmsdata/238104/2020_AnnualActivityReport_AuthorityEUPPsEUPFs.pdf
29
The ‘Future of Europe Special Eurobarometer 2020’ identified that the main way for citizens to
make sure their voice is heard at EU level is voting at elections to the European Parliament every
five years. But, at the same time, there is a desire for ‘ordinary citizens’ to be involved in policy-
and decision-making at the EU level64
. This is in stark contrast to the declining trend of voters
turnout in the elections to the European Parliament until 2009 and 2014.
This discrepancy may be explained by the fact that citizens may not identify clearly the political
actors at the EU level, including the EUPPs and their link with their national parties. As
identified earlier, not all Member States permit national parties to display the logo of the EUPP
they are associated with on their ballot and, oftentimes, the link between national and European
political parties is not fully transparent. This makes it more challenging for citizens to understand
the relation between the national and European political parties and creates additional distance to
the decisions taken at EU level.
In addition, the lack of fair gender representation negatively affects citizens, in particular
women. While slightly more than 50% of the European population is female, on average only
38.9% of their European political representatives are so, with large variations per Member States.
This leads to underrepresentation of women in European politics and is not in line with Article
23 of the EU Charter on Fundamental Rights65
.
European Parliament and other institutions
The identified shortcomings of the legislation impact not only on the individual EUPP/F but also
on the European Parliament and the other European institutions. Lack of transparency and
misuse of funds, in particular, challenge the credibility of the EU and its democratic
representation and could lead to European citizen’s reduced trust in policy- and decision-making
at EU level.
3. WHY SHOULD THE EU ACT?
3.1. Legal basis
The legal basis of the initiative is Article 224 of the Treaty on the Functioning of the European
Union (hereinafter, TFEU) which provides that "the European Parliament and the Council,
acting in accordance with the ordinary legislative procedure, shall lay down the regulations
governing political parties at European level referred to in Article 10(4) of the Treaty on
European Union and in particular the rules regarding their funding".
Since the TFEU provides for the establishment of the rules governing EUPPs by way of a
regulation, any change to the rules currently in place, the EUPP/F Regulation, must be
established at EU level in application of Article 224 TFEU.
64
https://www.europarl.europa.eu/at-your-service/files/be-heard/eurobarometer/2021/future-of-europe-2021/en-key-
findings.pdf
65
Charter on Fundamental Rights of the European Union (2000). Available at:
https://www.europarl.europa.eu/charter/pdf/text_en.pdf
30
The EUPP/F Regulation’s revision clause contained in its Article 3866
provides for the European
Parliament to adopt a report on the application of the EUPP/F Regulation by the end of 2021, and
the Commission to present a report on the same matter within six months of the adoption of the
Parliament’s report, possibly accompanied with an amending legislative proposal, if appropriate.
It should be taken into account in this context that any modification concerning fundamental
rules of electoral law67
applicable to the EUPP/F must be in place at least one year before the
2024 elections to the European Parliament; namely, by May 2023 at the latest.
The proposal fully complies with the principle of subsidiarity, since the EU level is the only one
at which rules governing the statute and funding of EUPP/F can be laid down. As it has been
established in the previous sections of this impact assessment, although the EUPP/F Regulation
has provided a useful legal framework for the functioning of EUPP/F up to date, existing
loopholes and inefficiencies necessitate further targeted amendments.
The proposal does not go beyond what is necessary to achieve the long-term objective of
developing and strengthening European democracy and the legitimacy of the EU institutions, by
seeking to make EUPP/F more effective and accountable democratic actors. It therefore complies
with the principle of proportionality as well.
4. OBJECTIVES
4.1. General policy objectives
The initiative at stake has three general policy objectives:
 Improve the legislative framework that enables EUPP/F to fulfil their mission in forming
European political awareness by ensuring the democratic principles laid down in Article
10 TEU.
 Ensure EUPP/F’s higher level of compliance with the EU values, as enshrined in Article
2 TEU.
66
Article 38 – Evaluation
The European Parliament shall, after consulting the Authority, publish by 31 December 2021 and every five years
thereafter a report on the application of this Regulation and on the activities funded. The report shall indicate, where
appropriate, possible amendments to be made to the statute and funding systems.
No more than six months after the publication of the report by the European Parliament, the Commission shall
present a report on the application of this Regulation in which particular attention will be paid to its implications for
the position of small European political parties and European political foundations. The report shall, if appropriate,
be accompanied by a legislative proposal to amend this Regulation.
67
See Code of Good Practice in Electoral Matters: Guidelines and Explanatory Report - Adopted by the Venice
Commission at its 51st and 52nd sessions (Venice, 5-6 July and 18-19 October 2002). Available at:
https://rm.coe.int/090000168092af01. See also the Compilation of Venice Commission opinions and reports
concerning the stability of electoral law, 14.9.2020, CDL-PI(2020)020. Available at:
https://www.venice.coe.int/webforms/documents/?pdf=CDL-PI(2020)020-e.
31
 Better ensure the sound financial management of EUPP/F, the appropriate enforcement of
the Regulation and decrease the level of administrative burden.
4.2. Specific policy objectives
a) Specific objectives contributing to enabling EUPP/F to fulfil their mission in
forming European political awareness, by ensuring the democratic principles, laid
down in Article 10 TEU
The proposal aims at adapting funding rules to (i) allow EUPP to play an active role in national
campaigns on EU-relevant issues and (ii) ensure that EUPP/F can maintain meaningful relations
with their member parties located in countries outside the EU, while providing the necessary
safeguards against unwanted foreign interference.
The enforcement of the provisions enhancing the link between national and European political
parties, and thus the degree of visibility of the latter, should be also improved. These two specific
objectives would improve the visibility of EUPPs and allow them to form a common European
political awareness.
b) Specific objectives contributing to ensuring European political parties’ and
foundations’ compliance with the EU values, as enshrined in Article 2 TEU
The initiative also aims at promoting gender balance in European politics, and at operationalising
the verification mechanism for EUPP/F compliance with EU values by simplifying it and making
it easier to apply.
c) Specific objectives contributing to sound financial management, strengthened
enforcement and decreased administrative burden
The initiative aims at adapting the typology of revenues to expand the categories of own
resources to allow participation fees, sponsorships, publication fees, etc. This would help
EUPP/F to secure the 10% co-financing rate to match the EU funding they receive and, thus,
improve their financial viability.
The initiative aims at tightening the transparency regime for donations in order to avoid
unwanted foreign interference through intermediaries. A due diligence mechanism for EUPP/F
requiring that they know the source of donations before accepting them would increase the level
of self-compliance with the EUPP/F Regulation, would allow the APPF to better investigate
cases of alleged irregularities, and would improve financial transparency of the system overall.
The initiative aims at further empowering the APPF so it can better carry out its supervisory
functions.
The initiative also aims at cutting the level of administrative burden for EUPP/F. Reduced
administrative burden will allow these relatively small organisations to devote more resources to
their core activities on democracy building.
32
It also aims at increasing the level of legal certainty provided by the EUPP/F Regulation by
further clarifying the division of tasks and responsibilities between the APPF and the
Authorising Officer of the European Parliament. Greater clarity would help to avoid both
functional overlaps and diverging interpretations of the legal provisions, which could help
EUPP/F identify activities that can benefit from public funding clearly distinguishing them from
those that cannot.
Finally, the initiative aims at better protecting the financial interests of the EU by aligning the
rules on the entry into force of the deregistration decision with the Treaty on the Functioning of
the EU.
Figure 8 – General and specific policy objectives
General
objective
1
Enable
European
political
parties
to
form
European
political
awarness
(Art.
10
TEU)
Enable EUPPs to play a more active role in
national campaign on EU issues
Better means to enforce visibility of link
between EUPPs and national parties
Adapt funding provisions to have meaningful
relations with actors outside the EU (while
safeguarding against foreign interference)
33
General
objective
2
Compliance
with
EU
values
(Art.
2
of
TEU)
Improve gender balance in
political representation
Ensure a fully operational
mechanism under Art 10.3
General
objective
3
Sound
financial
management,
enforcement
and
administrative
burden
Adapt the typology of own
resources
Tighten transparency regime
for donations
Empower the Authority
regarding investigations and
sanctions
Administrative simplification/
cutting red tape
Improve legal certainty
Safeguard the EU's financial
interests
34
4.3. Consistency with other EU policies and with the Charter of Fundamental Rights of the
European Union
4.3.1. European Democracy Action Plan
This revision is one of the items contained in EDAP68
, the action plan announced by President
von der Leyen in her July 2019 Political Guidelines69
in view of addressing current challenges to
democracy, including increasing threats of external interference in the elections to the European
Parliament. EDAP, which was adopted on 3 December 2020, announced inter alia a legislative
proposal to ensure greater transparency on paid political advertising and the review of the
legislation on the funding of EUPP. Both initiatives are therefore strongly interlinked. The
political advertising initiative considers the use of political advertising in all elections, covering a
number of problems and relevant actors including service providers in the internal market and
EUPPs. It will provide for specific requirements for EUPPs to use political ads, in particular
creating a common repository for political ads for EUPPs, and a review process, for the
Authority to take note of breaches of the rules visible on the basis of EUPP disclosures. The
relevant provisions defining the powers of the Authority will be amended accordingly, to ensure
full coherence between these two complementary initiatives. The lead service for the initiative on
transparency of paid political advertising is Directorate-General for Justice and Consumers, and
its adoption is planned for Q4 2021. .
4.3.2. Conference on the Future of Europe and European Electoral Act
The proposal for the revision of the EUPP/F Regulation will be drafted in a neutral way in order
to cater for any future potential developments in the context of the institutional strand of the
Conference on the Future of Europe (hereinafter, CoFE), in particular regarding transnational
lists and the lead candidate system.
The vast majority of stakeholders concur that, if the relevant parties were to agree on the
introduction of transnational lists and/or a legal formalisation (in whatever form) of the lead
candidate system, this would have impacts on and consequences for EUPPs. But, at the same
time, there is a general understanding that the revision of the EUPP/F Regulation would not be
the appropriate framework to address these issues.
This neutrality will also allow for consistency with the potential reform of the EU’s Electoral Act
that is currently on hold awaiting the outcome of the discussions at the CoFE.
68
Communication from the Commission to the European Parliament, the Council, the European Economic and
Social Committee and the Committee of the Regions on the European democracy action plan, COM/2020/790 final.
Available at: https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A790%3AFIN&qid=1607079662423
69
President von der Leyen (2019), A Union that strives for more – my agenda for Europe. Available at:
https://ec.europa.eu/info/sites/default/files/political-guidelines-next-commission_en_0.pdf
35
4.3.3. Commission’s Gender Equality Strategy 2020-2025
By adding specific provisions to promote gender equality in European politics, the initiative is
fully consistent with the Commission’s Gender Equality Strategy 2020-202570
that urges for
equal opportunities in participation for representative democracy at all levels – European,
national, regional and local. In addition, the Strategy states that ‘the Commission will promote
the participation of women as voters and candidates in the 2024 European Parliament elections,
in collaboration with the European Parliament, national parliaments, Member States and civil
society, including through funding and promoting best practices. European political parties
asking for EU funding are encouraged to be transparent about the gender balance of their
political party members’.
4.3.4. Charter of Fundamental Rights of the European Union
The revision of the EUPP/F Regulation is in line with the principles laid down in the Charter of
Fundamental Rights of the European Union71
as regards political participation:
 Freedom of assembly and of association (Article 12, EU Charter of Fundamental
Rights)
“1. Everyone has the right to freedom of peaceful assembly and to freedom of association at all
levels, in particular in political, trade union and civic matters, which implies the right of
everyone to form and to join trade unions for the protection of his or her interests.”
“2. Political parties at Union level contribute to expressing the political will of the citizens of
the Union.”
 Right to vote and to stand as a candidate at elections to the European Parliament
(Article 39)
“1. Every citizen of the Union has the right to vote and to stand as a candidate at elections to the
European Parliament in the Member State in which he or she resides, under the same conditions
as nationals of that State.“
“2. Members of the European Parliament shall be elected by direct universal suffrage in a free
and secret ballot”.
70
Communication from the Commission to the European Parliament, the Council, the European Economic and
Social Committee and the Committee of the Regions, A Union of Equality: Gender Equality Strategy 2020-2025,
COM(2020) 152 final, p. 14. Available at: https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52020DC0152&from=EN
71
Available at: https://www.europarl.europa.eu/charter/pdf/text_en.pdf
36
Increasing transparency will ensure that this right is respected and that citizens have the ability to
check if their political will is expressed by the party they support at EU level as stipulated in
Article 12 and 39.
 Non-discrimination (Article 21)
“1. Any discrimination based on any ground such as sex, race, colour, ethnic or social origin,
genetic features, language, religion or belief, political or any other opinion, membership of a
national minority, property, birth, disability, age or sexual orientation shall be prohibited.”
“2. Within the scope of application of the Treaties and without prejudice to any of their specific
provisions, any discrimination on grounds of nationality shall be prohibited.”
 Equality between men and women (Article 23)
“Equality between men and women must be ensured in all areas, including employment, work
and pay. The principle of equality shall not prevent the maintenance or adoption of measures
providing for specific advantages in favour of the under-represented sex.”
Adding a gender dimension to the revision of the EUPP/F Regulation would ensure compliance
with Article 21 and 23 to guarantee a balanced representation of both sexes in political parties.
The principle allows for measures that lead to a better representation.
5. POLICY OPTIONS
5.1. Baseline scenario
The baseline scenario is to maintain the status quo and do not revise Regulation 1141/2014 as
last amended by Regulation (EU, Euratom) 2019/493. However, this policy option leaves the
problems identified above unresolved and may not be fit for future developments.
In view of the upcoming European elections in 2024, the baseline would not allow for higher
visibility for European political parties and more interaction between the European and national
political parties. The baseline scenario would therefore hinder the achievement of general
objective 1 to form European political awareness. In addition, current prohibition to receive
membership fees from affiliates from non-EU countries would continue to pose a political and
financial problem for EUPP/F. While the number of EU citizens served by the EUPP/Fs has
reduced by over 10% since Brexit, their membership has not changed72
, neither has their
democracy building mission, which goes beyond EU’s borders.
Recently, foreign party funding has been used to unsettle the EU and its Member States73
. Russia
and China are the most visible players in the field, but ultraconservative organisations in the
USA have also actively financed and coordinated far-right movements in Europe, particularly in
72
The EUPP/F Regulation does not prohibit membership from non-EU countries, see Annex VI.
73
E. Bressanelli (2021), Investing in destabilisation: How foreign money is used to undermine democracy in the EU,
https://www.europarl.europa.eu/RegData/etudes/STUD/2021/653631/EXPO_STU(2021)653631_EN.pdf
37
the run-up to the 2019 elections to the European Parliament74
. This trend is expected to remain
and become even more prominent in the coming years. Keeping the status quo and the current
loopholes in the transparency regime for donations in Regulation 1141/2014, coupled with the
inability of the APPF to investigate, would therefore expose EUPP/F to this risk.
At the same time, public information on the financial statements of EUPP/F would remain
scattered and delays in their publication may persist. For this reason, transparency for the citizens
would not be sufficiently ensured.
Difficulties in raising own resources would further undermine the financial viability of EUPP/F.
The restrictive categorisation of revenues and the need to match the 10% and 5% co-financing
rate may lead to irregularities, as identified by the European Parliament’s Authorising Officer in
the past75
.
The current Regulation does not contain binding provisions on gender equality and therefore
does not ensure coherence with the Commission’s Gender Equality Action Plan 2020-2025.
The rigid sanctions regime may lead to disproportionately high sanctions for smaller breaches.
This may impede its use in order to avoid undermining the financial viability of European
political parties and foundations.
The EUPP/F Regulation should be coherent with possible changes to the 1976 European
Electoral Act following the ongoing work in the AFCO Committee on its amendment, which
may include the introduction of a common European constituency, should the discussions in the
CoFE point in that direction. The current EUPP/F Regulation could not ensure coherence with
this development as it would not provide the appropriate legislative framework for EUPPs
regarding campaigning for the lead candidates and on transnational lists. Furthermore, the
current EUPP/F Regulation cannot ensure coherence with the objectives of the European
Democracy Action Plan, and in particular the legislative initiative on transparency of political
advertising, as for the time being it does not contain specific rules for the use of political
advertising by the EUPPs, and does not provide the Authority with the necessary oversight.
powers.
Stakeholders’ views on the baseline scenario
While all stakeholders agree that the EUPP/F Regulation provides a useful legal framework for
the statute and funding of EUPP/Fs, wide consensus has emerged that the Regulation needs
targeted amendments to address the identified loopholes.
74
Rudolph J. and Morley, T. Covert Foreign Money. Financial loopholes exploited by authoritarians to fund
political interference in democracies, p. 1.
75
I. Anglmayer (2021), Statute and funding of European political parties under Regulation 1141/2014 -ex post
evaluation. Available at:
https://www.europarl.europa.eu/RegData/etudes/STUD/2021/662646/EPRS_STU(2021)662646_EN.pdf
38
5.2. Options for further in-depth assessment
Option 2 focuses on the revision of the funding provisions in the Regulation. The Commission
considers that the problems identified under the funding provisions of the Regulation are the
most pertinent in the Regulation’s underperformance. This option is strictly aligned with the
commitment undertaken by President von der Leyen in her Political Guidelines to put forward
legislative proposals under the European Democracy Action Plan to ensure greater transparency
on paid political advertising and clearer rules on the financing of EUPPs76
. The impact of the
additional provisions are analyzed in the impact assessment on the initiative on transparency of
paid political advertising. 77
Option 3 goes beyond the mere revision of the funding provisions to also include other aspects of
the Regulation that, according to the Commission’s analysis and input received from
stakeholders, could benefit from targeted improvement in the text of the Regulation. This option
includes the reduction of administrative burden, strengthening enforcement and the sanctions
regime, operationalising the verification mechanism for EU values and promoting gender
equality.
Table 2 – Overview of policy options
Area of problem Option 1
Baseline
scenario
Option 2 Option 3 Objective
Funding
provisions
No change
Addressing
difficulties
matching the co-
financing rate
Tightening the
transparency
regime for
donations
Facilitating
meaningful
relations with
actors outside the
Addressing
difficulties
matching the co-
financing rate
Tightening the
transparency
regime for
donations
Facilitating
meaningful
General
objective 3
General
objective 3
General
objective 1
76
President von der Leyen (2019), A Union that strives for more – my agenda for Europe. Available at:
https://ec.europa.eu/info/sites/default/files/political-guidelines-next-commission_en_0.pdf
77
SWD No….
39
Area of problem Option 1
Baseline
scenario
Option 2 Option 3 Objective
EU relations with
actors outside the
EU
EU values,
democracy and
transparency
No change No change
Improving
visibility
Helping European
political parties
fulfil their
constitutional
mission
Improving gender
balance
Simplifying the
verification
mechanism for
compliance with
EU values
General
objective 1
General
objective 1
General
objective 2
General
objective 2
Enforcement and
administrative
burden
No change No change
Empowering the
Authority
Reducing
administrative
burden
Improving legal
certainty
Better protecting
the EU’s financial
interests
General
objective 3
General
objective 3
General
objective 3
General
objective 3
6. ANALYSIS OF FEASIBILITY AND IMPACTS OF THE POLICY OPTIONS
40
Due to the specific character of the Regulation, namely that it has direct impact on 20
organisations (10 EUPPs and their 10 affiliated EUPFs), the APPF and the Authorising Officer
of the European Parliament, the policy options will have negligible environmental, economic and
social impacts. The impact assessment will therefore focus on the options’ impacts in the area of
fundamental rights and democracy.
6.1. Impacts of policy option 2
Option 2 focuses on addressing the shortcomings of the funding provisions of the Regulation
identified in section 2.1. The funding provisions constitute the core of the EUPP/F Regulation,
and tackling the identified shortcomings in this area would already contribute to some specific
objectives under general objectives 1 and 3, should the Commission decide to propose a more
targeted amendment of the Regulation. More specifically, the proposed changes would better
ensure the financial viability of EUPP/Fs and would promote sound financial management, while
also creating further safeguards against foreign interference.
Two alternative measures were considered to address the difficulty of European political
parties and foundations fulfilling the co-financing obligation under Article 17(4):
a) recognising additional categories of own resources
b) lowering even further the co-financing rate
Measure a) would not only provide European political parties and foundation with increased
flexibility to generate own revenue, but also corresponds better to their political organisation and
activities.
However, a number of risks have been identified with this measure. The introduction of a new
category of revenue also entails the risk that it is used as a loophole to circumvent the limitations
imposed on donations and contributions. Addressing these loopholes might require a too
complex revenue structure imposing administrative burden on European political parties and
foundations.
To mitigate these risks, it is proposed to impose a ceiling on the total revenue generated through
“other own resources” in analogy to member contributions. This latter threshold should be
sufficiently low in order to minimize the risk of interference. This solution would be the easiest
to implement for European political parties and foundations and would cause the smallest
administrative burden on them. Coupled with a ceiling, the measure would therefore not only be
effective, but also efficient.
Measure b) would lower the required own resources to receive the entire contribution/grant
amount, reducing the internal budgetary pressure on European political parties and foundations.
Table 1 simulates the impact of lowering the co-financing obligation from the current 10% to 5%
and 2% illustrating the reduced internal budgetary pressure on the parties.
Table 3 – Simulation of required own resources to match maximum contribution
41
Max. Contribution
2019
10% Own
Resources
5% Own
Resources
2% Own
Resources
EPP € 15 832 805 € 1 759 201 € 833 306 € 323 118
PES € 13 051 506 € 1 450 167 € 686 921 € 266 357
ALDE € 4 564 976 € 507 220 € 240 262 € 93 163
EGP € 3 566 561 € 396 285 € 187 714 € 72 787
PEL € 2 782 092 € 309 121 € 146 426 € 56 777
EDP € 1 070 523 € 118 947 € 56 343 € 21 847
EFA € 1 355 784 € 150 643 € 71 357 € 27 669
ECPM € 927 892 € 103 099 € 48 836 € 18 937
ECRP € 4 422 345 € 491 372 € 232 755 € 90 252
IDP € 2 425 515 € 269 502 € 127 659 € 49 500
Source: W. Wolfs78
However, the measure would have a negative impact on EUPP/F’s relations with citizens. The
co-financing obligation has been introduced in order to incentivise parties to strengthen their
financial ties in society. It was already reduced by the 2018 amendment of the Regulation from
15% to 10% for EUPPs and 5% for EUPFs. Easing the co-financing obligation even further
would also substantially lower this incentive, while the visibility and connectedness of European
political parties and foundations with European citizens and civil society is already rather
limited. In addition, lowering the co-financing obligation increases the probability that the
European political parties and foundations will financially become almost entirely dependent on
public resources, creating an over-dependency on state support. This is a situation that should be
avoided, according to the existing international guidelines79
. For this reason, while the measure
would be effective regarding general objective 3, it would not be coherent with general objective
1.
To address the remaining risk of foreign interference through donations, two alternative
measures are considered:
a) due diligence mechanism for European political parties and foundations
b) introduction of overall ceiling for donations
Measure a) has the potential to strengthen the verification of the identity of the donors, increase
the overall transparency of their income and reduce the risk of foreign interference. European
political parties and foundations would authenticate that the natural person or entity from whose
account the donation was made, was indeed the actor that wanted to make the donation. This is
78
Wolfs W. (2021), Impact assessment study – Revision of Regulation 1141/2014, unpublished.
79
European Commission for Democracy through Law (Venice Commission) & OSCE Office for Democratic
Institutions and Human Rights (2020), Guidelines on Political Party Regulation (2nd edition), pp. 64-65. Available
at: https://www.venice.coe.int/webforms/documents/default.aspx?pdffile=CDL-AD(2020)032-e
42
in line with the provisions on donations in the Regulation (Article 20) that are aimed at
maximum transparency and – among others – preventing anonymous donations. For this reason,
the measure would be effective in contributing to general objective 3. However, such a due
diligence mechanism also implies an increased administrative workload for the parties. To
ensure the efficiency of the measure, the due diligence mechanism could be limited to larger
donations only (with a value above EUR 12 000). As such, a balance would be struck between
increasing transparency and control of the donation regime for EUPPs, while keeping the
additional administrative workload limited.
Measure b) would introduce an overall ceiling on donations comparable to the ceiling for
contributions from members (capped at 40% of the total annual budget of the EUPP/F). Unless
the ceiling for donations is kept substantially low (e.g. 5% or less of the total annual budget), this
solution would not solve the main identified problem, namely the possibility for foreign entities
to use donors as an instrument for unwanted influence. Setting an overall ceiling on donations
might have an additional adverse effect of depriving the EUPP/F of a broad and diversified
donor base. In some cases, where EUPPs rely substantially on donations, setting such a low
ceiling on donations would substantially limit the fund-raising ability of this EUPP, while the
risk of undue interference is currently limited. For this reason, the effectiveness and efficiency of
measure b) is considered lower than that of measure a).
To ensure EUPP/F meaningful relations with actors outside the EU, while providing the
necessary safeguards against unwanted foreign interference, two alternative measures are
considered:
a) amend the provisions related to contributions from members to allow such contributions
from frmembers of the Council of Europe.
b) add specific criteria that parties in third countries have to fulfil for membership eligibility
Measure a) would send a political message to their affiliates from non-EU members allowing for
meaningful cooperation with them. It would also reduce the difficulty for EUPP/F to have
sufficient own resources due to their inability to collect membership fees from non-EU countries.
The measure is therefore considered to be effective. This measure would however increase the
risk of foreign interference, which, in turn would increase the political cost of the measure
thereby risking its efficiency and also its coherence with the measure on strengthening the
transparency regime for donations to safeguard against interference. This risk could be mitigated
by capping the revenue from contributions from non-EU members at a certain level, for example
at 5% or 10% of the total own resources.
Measure b) would entail adding specific criteria that member parties from third countries must
fulfil in order to be eligible to make membership contributions. Such criteria could include
provisions that point to ‘like-minded political formations’ or ‘political formations sharing the
core values of the European political party’. However, such provisions can leave room for
interpretation which makes a proper legal assessment of compliance with these provisions more
difficult. For this reason, the measure is considered less efficient than measure a).
43
Cost, administrative burden reduction and simplification potential of Option 2
As Option 2 introduces more complex reporting obligations on EUPP/Fs, it would generate
additional administrative cost for them, and also for the APPF and the European Parliament’s
Authorising Officer, who control their financial statements. In case these additional costs are not
offset by simplification in other areas, they might take away funds from their core business,
namely their political activities.
Stakeholders’ views on option 2
EUPP/Fs argued for diversifying the categories of own resources throughout the informal
consultation process and at the hearing organised by the AFCO Committee on 22 June 2021 on
the application of the EUPP/F Regulation. They also called for the revision of the EUPP/F
Regulation to allow for a meaningful cooperation with likeminded parties in non-EU countries.
The APPF has advocated for the introduction of a due diligence mechanism for EUPP/Fs
regarding donations in order to close existing loopholes in their transparency regime. The APPF,
however, cautioned against allowing for contributions from member parties in non-EU countries.
The European Parliament’s AFCO Committee, in its draft report, called for broadening the
categories of own resources to improve the financial viability of EUPP/Fs. The draft report also
considered that EUPP/Fs should be open to membership from parties or individuals from
neighbourhood countries and allowed to receive their contributions, provided that full
transparency is ensured.
OSCE/ODIHR, in their submission to the Commission and the European Parliament, calls for
reviewing the overall amount of public funding available to European political parties so they
can effectively carry out their activities. They also advocate for progressively decreasing the
maximum ratio of public-to-private funding of EUPPs.
6.2. Impacts of policy option 3
Option 3 would allow for tackling all identified shortcomings in the impact assessment in
addition to those tackled under option 2, contributing to achieving all general objectives. This
section does not repeat the proposed solutions under option 2, but focuses on the measures
proposed to tackle the problems identified in sections 2.1.b and 2.1.c .( i.e. concerning EU
values, democracy and transparency; and enforcement and administrative burden).
To improve the visibility of the link between European political parties and national
member parties, two measures are considered:
a) introducing sanctions for non-compliance
b) clearly defining the requirements for the visibility of the European political party of
affiliation
44
Measure a) would entail including non-compliance in the list of non-quantifiable infringements
in the sanction regime (Article 27). This would mean that if one or more member parties do not
publish the logo and programme of the EUPP of affiliation on their websites (as required by
Article 18(2a)), this might lead to a financial sanction on the latter. By modulating the sanction
that the EUPP might face, the measure would remove the disproportional possibility of a total
loss of funding for the European political party. It would still act as a deterrent, and would
therefore increase the effectiveness of the regulatory framework.
Measure b) would indeed have a positive effect on the visibility of the European political party,
as its logo would be placed on the website on a more prominent place than has been the case
until now. However, the measure would not tackle the disproportionality of the consequences of
non-compliance. On the contrary, the specification of the provisions might even increase the
chances of non-compliance, thus potentially resulting in EUPP losing their entire EU funding.
For this reason, measure b) alone is not considered sufficiently effective to address the identified
problem.
To address European political parties’ inability to fulfil their constitutional mission, two
measures are considered:
a) allowing EUPPs to use their funds to act in national referendum campaigns on EU issues
b) introducing a campaign grant for European political parties to be used in a fixed period
before the European elections
Under Measure a) EUPPs take on the function comparable to civil society organisations and
campaign in favour or against the content of the referendum question. This possibility would
increase their visibility for EU citizens and would contribute to the development of a European
political space. It is considered that European political parties would have a limited capacity to
influence the final outcome of the referenda. The sums set out in Table 2 indicate that the
financial potential for expenditure on referendum campaigns is not excessive: at current funding
levels, expenses of maximum a few €100 000 can be expected, considering that the European
parties will not concentrate all their financial resources on one referendum campaign. While such
amounts are limited for referendum campaigns in larger member states – during the EU
membership referendum in the UK, a total of approximately €38 million was spent on all
campaigns combined –80
they can make a difference in referendum campaigns in smaller
member states. In the EU membership referendum in Latvia in 2003 for example, all national
parties combined only spent approximately €350 000, meaning that campaign expenses from the
European political parties in such cases hold the potential to influence the outcome of the
elections.81
Table 4 – Selection of total campaign expenditure in EU referenda
80
The Electoral Commission (2019), Campaign spending at the EU referendum. Available at:
https://www.electoralcommission.org.uk/who-we-are-and-what-we-do/elections-and-referendums/past-elections-
and-referendums/eu-referendum/campaign-spending-eu-referendum
81
Although scientific evidence on campaign spending effects on referendum outcomes is diverse.
45
Year Country Referendum Total Expenditure
2003 Latvia EU membership €350 000
2005 Netherlands EU Constitution €3 790 000
2005 Spain EU Constitution €14 461 763
2016 UK EU Membership €38 036 000
Source: W. Wolfs, based on M. van Klingeren, M. Orozco, J. van Spanje, C. De Vreese (2015)82
However, there are still countries that will not allow campaigns from ‘third parties’ in the run-up
to referenda. This can be solved by either an imposed harmonisation of the referendum campaign
rules in the members states (in analogy to the measures taken for the introduction of the EU legal
status for EUPPs), or by acknowledging that EUPPs should obey the national provisions. The
latter solution would recognise the principle of subsidiary and allow EU countries to determine
their own rules in this respect, but would also create an inequality between Member States, as
some will allow the involvement of EUPPs (as ‘third parties’) in the referendum campaigns,
while others will prohibit it83
.
The measure would also entail the risk of indirect funding to national parties, as national political
parties usually take a clear position on the referendum question trying to use the referendum
campaign for increasing their own electoral support. For these reasons, the measure is considered
to be effective in increasing the visibility of EUPP/F, but limited in efficiency and coherence
with other provisions of the Regulation.
Measure b) is similar to measure a) but would allow European political parties to use EU funds
in electoral campaigns in the run-up to European elections by introducing a campaign grant. This
would only be allocated in European election years in addition to the annual operating grant and
could only be used in a fixed period before the European elections. As the campaign grant would
not be tied to the prohibition on indirect support to national political parties, European political
parties could realise their full political potential during the electoral campaigns for the European
Parliament. The main counterargument that EU funds could be used to influence national politics
is not relevant in this context, since European elections should revolve around European issues,
and not around domestic issues.
The campaign grant could also contribute to addressing the limited capacity of EUPPs to find
sufficient own resources to match EU funds if it contained a co-financing obligation of 0%. The
total funding sum of the operational grants does not have to be increased during election years,
and the co-financing obligation of this operational grant can be kept at 10%. The campaign grant
82
M. van Klingeren, M. Orozco, J. van Spanje, C. De Vreese (2015) Party Financing and Referendum Campaigns in
EU Member States, Study for the AFCO Committee, pp. 70-86. Available at:
https://www.europarl.europa.eu/RegData/etudes/STUD/2015/519217/IPOL_STU(2015)519217_EN.pdf
83
To some extent, this inequality is already present, as some member states allow for national referendums, whereas
in other countries this possibility does not exist.
46
could also use a different distribution key than the operational grants thereby creating a level-
playing field where the electoral support from European citizens is based on the strength of the
political argument and policy proposals of EUPPs, and not on the differences in their financial
resources. Finally, a separate and more stringent transparency regime should apply during the
campaign period comprising of the real time publication of data on European political parties’
accounts. This regime should encompass expenditure on political advertising to ensure coherence
with the initiative on the transparency of political advertising under the EDAP.
However, similarly to referenda, seven Member States (Belgium, Croatia, Estonia, Lithuania,
Poland, Portugal and Spain) currently ban campaign expenditure of third parties during the
elections. The potential willingness of these countries to exempt EUPPs from this ban could be
explored further.
For these reasons, the measure is considered to be effective and be more coherent with the other
provisions of the Regulation and other initiatives under the EDAP. Its coherence with national
legislation, however, should be further explored with Member States.
To promote gender balance in European politics, two alternative measures are considered:
a) introducing a transparency obligation for gender balance at European elections
b) introducing a transparency obligation on gender representation for EUPP/F
Measure a) would entail the re-introduction of the provision that the Commission proposed at the
2018 amendment of the Regulation: ‘A European political party shall include in its application
evidence demonstrating that its member parties have continuously published on their websites,
during 12 months preceding the moment at which the applications is made […] on the gender
representation among the candidates at the last elections to the European Parliament and
among the Members of the European Parliament’. This measure would link the transparency
obligation on gender to application for EU funding and could potentially be a powerful tool to
promote gender balance. The political viability of this measure, however, may be limited as it
was rejected by the co-legislators during the interinstitutional negotiations on the 2018
amendment of the Regulation.
Measure b) would increase the accountability of the European political parties and foundations
with regard to gender balance to the citizens. It could provide them with the necessary incentives
to improve their internal gender balance. By providing a good example to their national
members, EUPPs may incentivise their national members to improve gender balance in their
governing structures and on electoral lists. However, as the measure does not publicly expose
gender balance in national member parties, it is expected to be less effective than measure a) and
does not ensure coherence with international standards that argue against interference with
internal party democracy 84
. Nor is the measure coherent with the Commission’s Gender Equality
84
European Commission for Democracy through Law (Venice Commission) & OSCE Office for Democratic
Institutions and Human Rights (2020), Guidelines on Political Party Regulation (2nd edition). Available at:
https://www.venice.coe.int/webforms/documents/default.aspx?pdffile=CDL-AD(2020)032-e
47
Strategy 2020-2025 that calls for transparency about gender equality in the member parties of
EUPPs85
.
To operationalise the verification mechanism for the compliance with EU values, two
alternative measures are considered:
a) lowering the threshold to act by empowering the APPF to launch the mechanism
b) clarifying the obligation for compliance with EU values by the members of a EUPP/F
Measure a) would simplify the procedure that currently only allows for action from the APPF on
the receipt of a request either from the European Parliament, the European Commission or the
Council of Ministers. It would increase the effectiveness of the mechanism and ensure its
impartiality as the APPF is an independent oversight body. However, the current mechanism is
the result of a delicate balance, struck by the co-legislators during the negotiations on the
previous amendment of the EUPP/F Regulation in 2018. Modifying this might jeopardize the
timeline for adoption of the current revision, ahead of the next elections to the European
Parliament in 2024.
Measure b) would mean that the mechanism can be applied more broadly. This measure may
however raise problems with regard to proportionality as the entire EUPP could be de-registered
due to the activities of a single affiliate. For this reason, this measure is considered less efficient
than measure a). To mitigate this problem, an additional step could be included in the mechanism
before the APPF’s final decision to de-register the European political party where the APPF
makes recommendations for rectifying the non-compliant behavior. This may however make the
process lengthier and in the end less effective.
To further empower the APPF, three measures are considered:
a) foreseeing additional resources
b) modulating the sanctions regime
c) increasing the Authority’s investigative powers
Measure a) is a prerequisite for the empowerment of the APPF that currently functions with 8
full time staff members. However, the Commission has a limited role in increasing the APPF’s
budget as the final decision lies with the budgetary authority (Council and European Parliament).
Measure b) foresees increasing the level of discretion of the APPF in assessing any potential
infringements. As various stakeholders argue that the inflexibility of the sanctions regime
decreases its practical usefulness, providing the APPF with the possibility to impose more
85
Communication from the Commission to the European Parliament, the Council, the European Economic and
Social Committee and the Committee of the Regions, A Union of Equality: Gender Equality Strategy 2020-2025,
COM(2020) 152 final. Available at: https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52020DC0152&from=EN
48
gradual sanctions proportionate to the breach, is expected to improve the practical application of
the sanctions regime. The introduction of a rectification period for some infringements could also
increase the flexibility of the regime without significantly increasing administrative burden. For
this reason, the measure is considered to be effective and efficient.
Measure c) would empower the APPF to request more information directly from donors. This
would improve the governance and good administration of the funding for EUPP/F, which
should result in a decrease of misuse of EU funds, which in turn should improve public trust in
the spending of EU funds in particular, and the functioning of the EU institutions in general. For
this reason, the measure is considered to be effective. The measure would also be coherent with
the due diligence mechanism proposed to tackle foreign interference through donations as the
Authority would be able to investigate on any irregularities identified through the mechanism.
To reduce administrative burden, it is considered to abolish the double accounting standards.
The added value of the obligation to use the international accounting standards is very limited,
since it does not provide much additional information that cannot be derived from the other
documents submitted to the APPF and the European Parliament’s Authorising Officer at the end
of the financial year86
. Neither are they necessary to compare the finances of the various
EUPP/F, since the European Parliament provides detailed templates that allow for a detailed
comparison regardless of the financial seats of the EUPP/F, while eight out of ten EUPPs are
based in Belgium. Removing the obligation to use the international accounting standards will
consequently reduce the regulatory burden on EUPP/F without any negative impact on
transparency. The indirect effect on EUPP/F will save resources that can be allocated to their
core political and policy work. For this reason, the measure is considered to be effective,
efficient and coherent with the other provisions foreseen in the revision.
To tackle the perceived legal uncertainty a single measure is considered, namely to clarify the
division of responsibilities between the European Parliament’s authorising officer and the APPF
in order to make it more efficient. According to the Venice Commission, any oversight agency
for political parties should be independent and non-partisan87
. In addition, the Venice
Commission also finds it essential that the funding of campaign and party finances is overseen
86
Within six months after the end of the financial year, European political parties and foundations must submit their
final reports to the Authority, the European Parliament and the National Contact Point of the Member State. This
final report consists of:
- the annual financial statement with all revenue and expenditure, assets and liabilities, both in accordance with
the national legislation of the member state in which they have their seat, and in accordance with the
international accounting standards as defined in Article 2 of Regulation 1606/2002;
- the report of the external auditor on the annual financial statements;
- an overview of the donations and membership contributions during the financial year.
87
European Commission for Democracy through Law (Venice Commission) & OSCE Office for Democratic
Institutions and Human Rights (2020), Guidelines on Political Party Regulation (2nd edition), paragraph 61.
Available at: https://www.venice.coe.int/webforms/documents/default.aspx?pdffile=CDL-AD(2020)032-e
49
by the same body, to ensure consistency88
.To align the Regulation with these international
guidelines, it is proposed to clarify the division of their respective responsibilities with a view to
eliminating overlaps and reducing the regulatory burden on parties. It would also improve legal
certainty by eliminating the possibility of diverging interpretations of the provisions. For these
reasons, the measure is considered to be effective and efficient. When clarifying the delineation
of responsibilities, coherence with the provisions in the Financial Regulation on the
responsibilities of Authorising Officers must be ensured.
To improve the protection of the EU’s financial interests, a single measure is considered,
namely aligning the entry into force of deregistration decisions with Article 297 TFEU. This
measure would eliminate the lack of clarity on the eligibility for funding due to the delayed entry
into force of the Authority’s deregistration decisions and would therefore ensure the appropriate
protection of the EU’s financial interest. In addition to being effective, the measure would ensure
coherence with the Treaty on the Functioning of the European Union. In order to give sufficient
time to the deregistered European political party or foundation to reconvert to a national entity
before losing its European legal status, one effect of deregistration, i.e. the loss of European legal
personality could be postponed to three months following notification of the decision to the
addressee, thereby ensuring its proportionality.
Cost, administrative burden reduction and simplification potential of Option 3
Option 3 included all the cost identified under Option 2, however it puts in place mitigating
measures to offset them. The abolition of the International Financial Reporting Standards would
free substantial resources to comply with the more complex financial reporting obligation.
Eliminating overlaps and reducing the regulatory burden on parties by clarifying the division of
responsibilities between the APPF and the European Parliament’s Authorising Officer, would
add to the simplification potential of this option. Furthermore, a more streamlined verification
mechanism for compliance with EU values would contribute to simplifying the Regulation.
Stakeholders’ views on policy option 3
EUPP/Fs called for facilitating joint activities with their national members so they can better
fulfil their constitutional mission. They also urged for clarifying the division of responsibilities
between the APPF and the European Parliament’s Authorising Officer to increase legal certainty.
The APPF has advocated for a modulated sanctions regime, increasing its investigative powers
and the alignment of the entry into force of deregistration decisions with Article 297 TFEU.
88
European Commission for Democracy through Law (Venice Commission) & OSCE Office for Democratic
Institutions and Human Rights (2020), Guidelines on Political Party Regulation (2nd edition), paragraph 271.
Available at: https://www.venice.coe.int/webforms/documents/default.aspx?pdffile=CDL-AD(2020)032-e
50
European Parliament’s AFCO Committee, in its draft report, called for an increased visibility for
EUPP/Fs at national level, including both the visibility of party affiliation and the ability of
EUPPs to participate in national referendum campaigns on EU matters. The report also urged for
ensuring EUPP/Fs compliance with EU values. The draft report also called for clarifying the
hybrid status of the APPF.
OSCE/ODIHR, in its submission to the Commission and the European Parliament, also called
for further empowering the APPF with regard to investigations, and for strengthening its
independence. They also called for including gender representation in the transparency
requirements. The submission urged for increased transparency during the electoral campaign
period.
All stakeholders consulted agreed on the need to remove the obligation for EUPP/Fs to present
financial statements in accordance with the International Financial Reporting Standards.
7. COMPARISON OF THE POLICY OPTION PACKAGES AND PREFERRED OPTION
7.1. Overview
Regarding the problems identified, inaction from the Commission foreseen by the baseline
scenario is the least favourable. Option 2 addresses the most pressing problems identified with
funding, and would partially contribute to achieving general objectives 1 and 3. More
specifically, the proposed changes would better ensure the financial viability of EUPP/Fs and
would promote sound financial management, while also creating further safeguards against
foreign interference. For this reason, this option is considered more effective than the baseline
scenario, as it addresses the difficulty of European political parties and foundations in fulfilling
the co-financing obligation under Article 17(4). Furthermore it allows for meaningful relation of
EUPP/Fs with actors outside the EU, while at the same safeguarding against unwanted foreign
interference. Option 3 would be more effective than the baseline scenario and more effective
than Option 2, because it would tackle all identified problems and would fully contribute to
achieving all general objectives. In addition, it is more coherent with other EU policies, such as
the Commission’s Gender Equality Strategy for 2020-2025 and it also aligns the provisions on
deregistration with the Treaty on the Functioning of the European Union. This option also
ensures better coherence with the legislative initiative on transparency of paid political
advertising (prepared by DG JUST) thanks to the newly envisaged campaign grant and its more
stringent transparency regime. This option is also considered to be efficient as the additional
administrative burden created, would be offset by the simplification foreseen by the abolition of
the double accounting standards.
The baseline scenario would not be favourable for any of the stakeholder groups identified as the
problems would persist. Option 2 would create a more favourable situation for all stakeholders as
it would increase the financial viability of EUPP/F, provide the APPF with more information on
donations, increase transparency for citizens and would ensure better financial management and
therefore more credibility for European institutions. Option 3 would create the most favourable
situation for all stakeholders. In addition to better financial viability, EUPP/F would benefit from
less administrative burden and more legal certainty. The APPF would be further empowered to
investigate donations and impose sanctions if necessary. Citizens would receive more
51
information on European matters and could hold EUPP/F more accountable, and women
representation at EU level would be fostered. The credibility of European institutions would be
higher due to the additional transparency measures under this option.
Table 5 – Comparison of options for effectiveness, coherence and efficiency
Baseline scenario
(Option 1)
Option 2 Option 3
Effectiveness in addressing the identified problems
Funding provisions 0 1 1
EU values,
democracy and
transparency
0 0 1
Enforcement and
administrative burden
0 0 1
Coherence
European Democracy
Action Plan (incl.
initiative on the
transparency of paid
political advertising)
0 0.5 1
Conference on the
Future of Europe and
European Electoral
Act
0 0 1
Commission’s
Gender Equality
Strategy 2020-2025
0 0 1
Charter of
Fundamental Rights
0.5 0.75 1
Efficiency
Potential to reduce
administrative burden
0 0 1
Simplification 0 0 1
52
7.2. Preferred option
Option 3 is the preferred option as it tackles all identified problems in a comprehensive manner
and ensures maximum positive impact on all stakeholder groups.
Following the analysis of the alternative measures considered in chapter 6, option 3 should
include the following measures:
a) Funding provisions
EUPP/F’s difficulty to match EU funds with a 10% and 5% co-financing rate will be addressed
by introducing an additional category of own resources. This measure will include a ceiling on
revenues from own resources to mitigate the risk of foreign interference and ensure its coherence
with other measures addressing this issue. In addition, contributions from members from the
Council of Europe would be allowed to ensure EUPP/F’s meaningful cooperation with their non-
EU members and affiliates. This measure would be accompanied by a cap on the revenues from
contributions from non-EU members, and the measure to clarify that EUPP/Fs must ensure that
their members located outside the EU comply with equivalent values to those listed in Article 2
of the TEU, in order to limit the risk of foreign interference, while allowing for meaningful
relations with longstanding partners and promoting democratic values beyond EU’s borders.
Finally, a due diligence mechanism will improve the transparency of donations to minimise the
risk of foreign interference from this source.
While the mix of measures adds requirements to the accounting and reporting system for
EUPP/F, the abolition of the international double accounting standards should offset the
administrative burden created here. In addition, the improved transparency regime and financial
viability for EUPP/F would justify this choice.
b) EU values, democracy and transparency
Regarding the visibility of the link between EUPPs and national member parties, the two
measures analysed in chapter 6 (sanctions for non-compliance and clear definition of visibility
requirements) could actually be complementary. While it was found that clarifying the criteria of
visibility would alone not be sufficient, with a more adapted and operational sanctions regime it
could increase the effectiveness of the regulatory framework.
To ensure the meaningful cooperation between EUPPS and their national affiliates, both the
possibility for EUPPs to use EU funds in national referendum campaigns on EU issues, and the
creation of a campaign grant for EUPPs to be used in a fixed period ahead of the European
elections could be granted. Both have the capacity to reinforce cooperation between the
European and national level and therefore increase the visibility of EUPPs. In addition, the more
stringent transparency regime would support other measures under the revision to ensure public
accountability and fighting foreign interference.
To promote gender equality, the Commission will retable its proposed measure at the 2018
revision of the Regulation as it is expected to bring better results for gender balance at European
elections than regulating transparency for the governing bodies of EUPP/F.
53
To ensure compliance with EU values, the EUPP/F Regulation will be amended in order to
clarify that the respect for EU fundamental values should apply to both the EUPP itself, as well
as its member parties. While this would not make the verification mechanism for compliance
with EU values lighter, it would still make it more enforceable, as it would bring more clarity
and legal certainty. .
c) Enforcement and administrative burden
To further empower the APPF, two of the three measures analysed in chapter 6 will be retained.
The investigative powers of the APPF will be increased so it can request information directly
from donors. The modulation of the sanctions regime will also increase the level of discretion
of the APPF in assessing any potential infringements. These measures, together with the
introduction of a due diligence mechanism under the funding provisions and the clarification of
responsibilities between the APPF and the European Parliament’s Authorising Officer, will
enable the APPF to better detect irregularities and sanction them. However, these measures will
require additional human and financial resources for the APPF. While the Commission does not
have the power to address this issue under the revision of the Regulation, it will propose
increasing the APPF’s budget to the budgetary authority.
To reduce the current administrative burden caused by the use of international double
accounting standards, the revision will require EUPP/F to keep their accounts according to the
national system of the Member State of registration only. This measure will support all the other
measures in the revision by freeing human and financial resources in EUPP/F so they can
concentrate on their core activities or on complying with the Regulation in a more effective way.
The clarification of responsibilities between the APPF and the European Parliament’s
Authorising Officer would be retained as it will increase legal certainty for EUPP/F and reduce
administrative burden both on citizens and EU institutions.
The entry into force of deregistration decisions will be aligned with Article 297 TFEU as it will
improve the protection of the financial interests of the EU.
It is expected that the chosen measures strike the right balance between creating an enabling
legislative framework for EUPP/F so they can contribute to creating European political
awareness while ensuring a more stringent oversight over them, without creating significant
additional administrative burden.
8. MONITORING AND EVALUATION
Table 7 below sets out the monitoring indicators per specific objective. The indicators will be
applied on a 1- or 5-year term to track the progress made towards the achievement of the specific
objectives set for this revision.
Table 7 – Monitoring indicators per specific objective
Specific objectives Proposed indicators
54
Improved financial viability of European
political parties and foundations (specific
objective: adapt the category of own resources
and meaningful relations with non-EU
members)
The amount of European political parties and
foundations that received less EU funds than
earmarked due to the inability to raise the 10%
co-financing / year
Transparency of donations (specific objective:
tightening the transparency regime for
donations)
Number of irregularities detected by the APPF /
year
European political parties fulfilling their
constitutional mission
a) Effective participation of EUPPs in
campaigns for national referenda on EU
matters that took place in a 5 year cycle
b) number of cross-EU campaigns that
European political parties ran in the run-up
of the European elections
Improving visibility of affiliation Proportion of member parties that do not display
the logo of their European party of affiliation in
a ‘clear and user-friendly’ manner / year
Operational verification mechanism for
compliance with EU values
Cases opened by the APPF / 5 years
Improving gender balance a) Proportion of female candidates at European
elections
b) Proportion of female Members of European
Parliament
Empowerment of the APPF a) Number of irregularities detected by the
Authority / year
b) Number of actions taken under the new,
modulated sanctions regime / year
Reduced administrative burden Working hours spent on the preparation of the
annual financial statements and accompanying
notes / 5 year
Legal certainty Number of requests for clarifications submitted
by EUPP/Fs to the APPF and the Authorising
Officer of the European Parliament / 5 year
55
Annex I: Procedural Information
LEAD DG, DECIDE PLANNING/CWP REFERENCES
This Impact Assessment Report was prepared by Unit SG.F.1 ‘Relations with the European
Parliament and Consultative Committees’ of the European Commission’s Secretariat-General.
The Decide Planning reference of the initiative is PLAN/2020/9262. This initiative is part of the
Commission’s 2021 Work Programme89
. Furthermore, parts of the initiative represent actions
proposed by the European Commission to implement the European Democracy Action Plan90
.
ORGANISATION AND TIMING
Several services of the Commission with an interest in the initiative have been involved in the
development of this analysis.
Three Inter-Service Steering Group (ISSG) meetings, consisting of representatives from various
Directorates-General of the Commission, were held in 2020 and 2021.
The first meeting took place on 7 December 2020, attended by DG BUDG, CNECT, COMM,
JRC, JUST, LS and the Secretariat-General (SG). The second meeting was held on 1 July 2021
with the same representatives. The third meeting was held in the same format on 22 July 2021.
This was the last meeting of the ISSG before the submission to the Regulatory Scrutiny Board on
25 August 2021. The meetings were chaired by SG.F.1. SG.F.1 considered the comments made
by DGs in the final version of the impact assessment. ISSG Members gave their green light to
the impact assessment on 29 and 30 July through written procedure.
CONSULTATION OF THE RSB
SG.F.1 held an upstream meeting with the members of the Regulatory Scrutiny Board on 17 June
2021. The Impact Assessment report was examined by the Regulatory Scrutiny Board on 22
September 2021. The Board gave a positive opinion with reservation.
Table 1: Changes introduced to the Impact Assessment report
RSB meeting comments Reflection in text
The report is not sufficiently clear how this
initiative links with the one on transparency
of political advertising.
Section 4.3.1 has been updated to clarify
the links between the two initiatives.
89
https://ec.europa.eu/info/publications/2021-commission-work-programme-key-documents_en
90
https://ec.europa.eu/info/strategy/priorities-2019-2024/new-push-european-democracy/european-democracy-
action-plan_en
56
The report does not sufficiently analyse and
substantiate with evidence the key problems
it aims to tackle. It does not sufficiently
explain the order of magnitude of the
problems nor the order of importance – if
any – among the objectives.
The report now clarifies why the problems
linked to the funding provisions are
considered to be the most urgent to tackle.
The report contains quantified information
on administrative burden, gender
(dis)parity and some aspects of funding to
underpin the problems the initiative tries to
tackle. The foreword explains the
methodological limitations that the
initiative faces due to the specificities of
the EUPP/F Regulation.
The report does not sufficiently bring out
feasible alternative options. It does not
establish clearly the links between problem
drivers, objectives and options.
The report has been updated regarding the
hierarchy of identified problems, which
clarifies the choice of options.
The report does not sufficiently analyse the
heightened foreign interference risks of
extending membership of European political
parties and foundations to all members of the
Council of Europe. It does not explore
feasible alternative extensions of EUPP/F
membership.
The report has been updated to explain that
the membership of EUPP/Fs already
includes countries from the Council of
Europe, in some cases it goes even beyond
it (see new Annex VI). Opening up the
possibility to collect contributions from
members from Council of Europe countries
strikes a balance between a complete ban
and the reality of current membership. A
complementary ceiling on the proportion
of contributions from non-EU countries
vis-à-vis the total amount of contributions
from members will be introduced to
mitigate the risk of foreign interference.
On top of the above listed main recommendations of the RSB, the amended SWD also addresses the
more detailed set of comments made by the RSB:
The report should better explain the planned
interaction with the parallel initiative on
transparency of political advertising and how
this might affect the scope of the revision. It
should consider how to better incorporate
this initiative in its baseline and policy
options.
As indicated above, Section 4.3.1 has been
updated to clarify the links between the
two initiatives. The baseline scenario has
also been updated and now refers to the
initiative on the transparency of paid
political advertising.
57
The report should make better use of
objective evidence to explain the relative
importance of the problems and be more
specific which of the identified problems are
the most pertinent in the Regulation’s
underperformance. It should consider
potential risks for interference or corruption
in the current financing system. It should
justify why the lack of gender balance is
more problematic than other imbalances in
political representation. It should be clearer
on how the current funding provisions
prevent EUPP/Fs from fulfilling
their tasks.
A hierarchy of problems has been established,
stating that the problems related to the funding
provisions are the most urgent to address. The
report proposes measures to tackle interference
though donations by strawmen. The report
creates the link between funding provisions
and the EUPP/Fs’ ability to fulfil their mission.
Additional language has been introduced to
explain ensuring gender equality through the
EUPP/F Regulation has been on the agenda
since 2013. The report contains quantitative
evidence that gender equality has not been
achieved in the European Parliament.
The baseline should include the fact that the
number of EU citizens served by EUPP/Fs
has reduced by over 10% since Brexit. The
report should provide a more encompassing
set of feasible policy options to achieve the
objectives. It should justify the need for an
option that does not address all objectives
and whether all objectives have the same
importance. It should be clear how the policy
options each address the objectives and
what the link is with the problems identified.
The baseline has been updated with a reference
to Brexit. Further clarification has been added
regarding the choice of policy options.
The report should be more systematic in
comparing all feasible options according to
the Better Regulation criteria of
‘effectiveness’, ‘efficiency’ and ‘coherence’,
as well as according to the impacts of these
options. The report should explain better
why impacts in
the area of fundamental rights are defined
according to the definition by the Venice
Commission of the Council of Europe
instead of the definition of the EU Charter of
Fundamental Rights.
Table 5 has been updated to compare
options based on effectiveness, coherence
and efficiency. The report still contains
reference to the Venice Commission that
has targeted guidelines for the functioning
and financing of political parties, which
serve as best practices in this area.
The report should analyse better how
extending the membership of EUPP/Fs to the
47 members of the Council of Europe could
create new risks, particularly related to
unwanted foreign interference from actors
identified in the report. The report should
look into alternative definitions of
membership to establish meaningful relations
with relevant external actors.
The report has been updated to explain that
the membership of EUPP/Fs already
includes countries from the Council of
Europe, in some cases it goes even beyond
it (see new Annex VI). Opening up the
possibility to collect contributions from
members from Council of Europe countries
strikes a balance between a complete ban
and the reality of current membership. A
58
complementary ceiling on the proportion
of contributions from non-EU countries
vis-à-vis the total amount of contributions
from members will be introduced to
mitigate the risk of foreign interference.
The report should analyse more thoroughly
the impacts of the different options in
terms of costs, administrative burden
reduction and simplification potential. The
report should be more detailed in explaining
the type and magnitude of costs of each of
the options and how these costs compare to
the options’ expected benefits.
An additional box has been added at the end of
options 2 and 3 on their costs, administrative
burden and simplification potential.
The report should make better use of all
feedback received from stakeholders and in
particular illustrate better how different
stakeholder groups view the different policy
options and the associated costs and benefits.
An additional box has been added at the end of
options 2 and 3 presenting stakeholders’ views
on them.
59
Annex II: Stakeholders’ Consultation
CONSULTATION STRATEGY
The consultation activities has fed into the European Commission’s revision of Regulation
1141/2014 on the statute and funding of the EUPP/F. In order to collect the views of all
stakeholders, the European Commission has built its consultation strategy on the following
components:
 Wide-ranging informal consultations with main stakeholders
 Feedback to Roadmap/Inception Impact Assessment
 Open Public Consultation on the revision of the Regulation
 Open Public Consultation in the framework of the European Democracy Action Plan
INFORMAL CONSULTATION WITH STAKEHOLDERS
The Commission conducted a series of informal meetings with selected stakeholders, in order to
gather feedback from their experience with the current regulation, as well as to explore their
views on the need and opportunities for further revision. The Commission reached out to:
‒ All European political parties registered with the APPF,
‒ All European political foundations registered with the APPF,
‒ The APPF,
‒ The Directorate General for Finance at the European Parliament.
Six European political parties and eight European political foundations expressed willingness to
meet the Commission.
All European political parties highlighted the administrative burden, caused by the double
accounting standard requirement. Five out of the six consulted parties were specifically against
the use of the International Financial Reporting Standards (IFRS). Three out of six parties
complained of the lack of coherence between the Authority and the Authorising Officer of the
European Parliament, with one of them even suggesting delegating all control powers to the
Authority. Three out of the six consulted parties complained that the categorization of the
sources of revenues is too restrictive and advocated introducing a new category of ‘own
resources’. All of the consulted parties suggested a more nuanced approach allowing for
contributions/membership fees from members from non-EU countries. Two parties signaled
difficulties fulfilling the co-financing obligation. Five out of the six consulted parties signaled
the need to clarify the definition of indirect funding, and pointed to the fact that the current too
restrictive interpretation impeded the proper interaction with their national affiliates. One
consulted party suggested lowering the registration criteria.
60
Seven out of eight consulted European political foundations took a stance against the use of
the International Financial Reporting Standards (IFRS). Three foundations signaled issues with
the co-financing rate. One of them pointed out the difficulties to raise the matching 5% co-
financing, and two preferred that the co-financing obligation should be abolished. Six political
foundations suggested the introduction of a new category of revenues - ‘own resources’. Three
foundations suggested the introduction of an intermediate level of appeal for the decisions of the
Authority. Three political foundations advocated allowing membership fees from non-EU
countries. One political foundations stressed the need for a more nuanced sanctioning regime.
They also called for the possibility to widen the scope of the foundations to democracy
education. Three foundations talked about the ambiguity of the definition of indirect financing.
They complained that currently they cannot properly carry out their functions due to the too
restrictive interpretation of its definition.
The Commission consulted the Director of the Authority for the European political parties
and foundations and took into consideration his experience in implementing the Regulation.
The Commission met twice with the team of the European Parliament’s Authorising Officer
and discussed the possibilities for technical improvements to the financial provisions of the
Regulation.
In addition, the Commission met representatives of the Office for Democratic Institutions and
Human Rights of the Organisation for Security and Co-operation in Europe
(OSCE/ODIHR), the Research Centre for the Study of Parties and Democracy (REPRESENT)
and the European Democracy Consulting for a discussion on the revision of Regulation
1141/2014 and the Commission’s upcoming initiative on the transparency of political advertising
on 10 May 2021. OSCE/ODIHR followed up the meeting with a submission to the European
Commission and to the European Parliament with their preliminary comments on the revision of
the Regulation. The submission provides an overview of the relevant provisions of the latest
OSCE/ODIHR-Venice Commission Guidelines on Political Party Regulation, outlines relevant
practices in OSCE participating States and includes 40 recommendations to improve the existing
legal framework.
FEEDBACK TO ROADMAP/INCEPTION IMPACT ASSESSMENT
The Commission received 8 replies to the roadmap/inception impact assessment, including
feedback from AFCO Member Mr BOESELAGER (Greens/DE, elected from European political
movement Volt Europa), European Free Alliance and its affiliated Coppieters foundation. Mr
BOESELAGER called for a broad overhaul of Regulation 1141/2014 so EUPPs can fully deliver
on their role in creating a ‘healthy European democracy’. The European Free Alliance and the
Coppieters Foundation recommended allowing income from its members outside the EU,
clarifying the definitions of contributions and donations and establishing additional sources of
income, reviewing the distribution key for budget distribution among European political parties
and foundations, strengthening European political parties’ and foundations European legal
personality, adding an intermediary step for appeals, and abolishing double accounting standards.
Citizens argued for more transparency and voiced their concern over the timing of the proposal.
61
OPEN PUBLIC CONSULTATION
Disclaimer: the analysis uses aggregated results, as the distribution of responses did not change
per type of respondent for the majority of questions. Whenever, it was justified by diverging
views, responses were analysed by individual groups. The individual comments were left
anonymous not to cause a bias in the analysis.
62
1. Approach
The public consultation took place between 30 March 2021 and 22 June 2021.
The first part of the questionnaire aimed at getting an insight into the respondents’ profiles and
feeling of involvement and representation in European political parties. The second section dealt
with transparency and funding for European political parties and foundations, as well as with
sanctions, representation and gender balance. Several open questions invited the respondents to
elaborate on their opinions, share issues they encountered and provide suggestions for
improvement of the Regulation.
The questionnaire was translated into all official EU languages and uploaded on the Have Your
Say platform of the European Commission.
2. Responses to the public consultation
2.1. Respondent profile
Throughout the consultation period and within the timeframe provided, 19 respondents filled in
the online questionnaire and two respondents sent their contribution via e-mail. The table below
shows the typology of the participating stakeholders for those who responded the online
EUSurvey: seven were EU citizens, one was a Member State, six were non-governmental
organisations, one was a research organization, and there were one company and three other
organisations. The two contributions received by mail included one non-governmental
organisation and one national authority.
Given the small number of
respondents, the following answers
cannot be seen as a representative
sample and have to be analysed with
caution. However, all viewpoints
mentioned will be taken into account
for the review of the Regulation.
In terms of country of origin, the
respondents came from various
geographical areas of Europe, including one contribution from Georgia, many non-governmental
organisations representing many or all EU Member States.
All respondents that filled out the
questionnaire were familiar with the
difference between European political
parties and European Parliament’s
political groups.
0
1
2
3
4
Country of origin
0 2 4 6 8
Academic/research institution
Company/business organisation
EU citizen
Non-governmental organisation…
Other
Public authority
I am giving my contribution as
63
2.2. Representation of European citizens
Almost half of the respondents believed that
European political parties do not fulfil their
role in representing European citizens. When
elaborating on the underlying reasons for their
choice, almost all respondents mentioned (i)
the lack of visibility of the parties to citizens
and (ii) their inability to mobilize citizens,
partly because no individual membership is
possible. Comments focussed on the visibility
of the connection between national and
European political parties. In addition,
respondents saw a lack of homogeneity within
European political parties and an affiliation mostly with national parties and topics rather than
with European issues. To some European citizens, the role of the European political parties was
seen as too vague and the parties invisible.
Those respondents agreeing European political parties represent citizens stressed the importance
of the role of European political parties in linking national parties with the European level,
representing a large number of citizens of various backgrounds and improving the role of
democracy in EU decision-making.
When asking if respondents felt better
represented by national or European political
parties on a European level, half-selected
European. When specifically looking at the
sample of EU citizens responding to the
consultation, slightly more respondents felt
represented by the European political party.
43%
57%
4. Citizens - At the European level,
do you feel more represented by
European political parties or
national parties?
National parties European parties
42,1%
47,4%
10,5%
3. Do you believe European political
parties fulﬁl their role to represent
European citizens?
Yes No No opinion
64
72% of all respondents felt involved in
European politics. This percentage was the
same amongst EU citizens filling in the survey
and went up to 84% amongst participating
non-governmental organisations.
When asked what they felt were the most
critical issues to be addressed by the revision
of the Regulation, one respondent mentioned
registration requirements and suggested to
replace the current requirements by (i)
lowering the number of Member States in
which the party needed to be represented and
(ii) defining ‘presence’ based on “citizens’ or
members signatures with a minimum number
per Member State based on their population”. The need for transnational lists and for greater
publicizing of initiatives in which citizens can get involved in (such as consultations) were
raised.
2.3. Organisation of electoral campaign, visibility and financing
25% of the respondents considered the
Regulation very useful. Disclosure of finances
was highlighted as one important point to be
revised as well as participation of European
citizens in European political party life and in
the foundations.
37.5% of the respondents found the Regulation
useful. They pointed out the importance of the
Regulation, was as well as the need “to increase
civic participation and inclusiveness of
elections, increase the voter turnout, highlight
the link between national and European
political parties and strengthen the European
dimension of European elections”. This
included that “The members of the European
Parliament should be elected on the basis of a
single electoral law that applies in all EU
Member States. To increase the European
dimension and enhance the democratic legitimacy of the European elections, transnational lists
with lead candidates need to be established.” Transparency and improving control over European
political parties were other points mentioned by respondents.
One of the four respondents with a neutral impression (accounting for 37.5% of the respondents)
also pointed towards the need for clearer rules on electoral campaign financing and on the
financing of joint activities with national political parties, and lack of visibility of European
12,5%
37,5%
37,5%
25,0%
6. What is your impression of the
usefulness of Regulation 1141/2014
on the statute and financing of
European political parties and
foundations in terms of organising
European electoral campaigns?
Not useful Neutral Useful Very useful
72,2%
27,8%
5. Do you feel involved in European
politics?
Yes No
65
political parties. They suggested a separate fund for campaign financing and a digital reporting
system as possible solutions. The other respondents highlighted the need for reform and lack of
visibility towards citizens. In addition, respondents asked for “some clarifications on donations
and ‘other own resources’, donations from a third country, indirect funding, different types of
membership, right to appeal”.
Only one citizen pointed towards the fact that the Regulation is currently not useful, especially as
regards campaigning, explaining that it “only allows European political parties to spend money
on European elections campaign. When campaigning, however, European political parties must
not finance national parties or candidates" campaigns (prohibition of indirect funding), thus
making difficult the organisation of any common and, for the meaning of European citizens,
useful activity”.
79% of respondents believed that European political parties are not sufficiently visible for
European citizens. They reasoned that this is partially related to the issue of not allowing for
indirect funding for activities at national level, with a need for clear roles for these joint activities
and potentially a separate fund for EU election campaigns. They pointed towards the large
distance between citizens and European political parties, but also as regards the work of the
European Commission and the European Parliament and their roles in general. Suggestions to
improve the visibility of the European political parties included better usage of European
political party logos on ballots and national political parties websites, endorsement of the
European political parties’ programme by national political parties, discussions of EU issues at
national elections, separate European and national elections and engagement with civil society
especially outside the “Brussels bubble”.
Additional suggestions included EU education
in school curricula and more media attention to
European political parties by for instance
hosting televised debate rounds between the
different European political party group
leaders. The lead candidate system and the
organisation of primaries were mentioned as a
way of increasing visibility.
On funding, about 42% of respondents
believed that European political parties receive
an adequate level of funding, while 11%
believe they are overfunded, and 32% that they
are underfunded.
The next question addressed the framework’s ability to counter potential financial abuse. Those
giving a low ranking to the sufficiency of the Regulation (with a score of 1, or not very
sufficient) stressed the importance of transparency and that the economic sanctions are
impossible to apply in practice and do not serve the intended purpose.
42%
32%
11%
16%
8. Do you believe that European
political parties receive the
adequate level of funding?
Yes
No, they are underfunded.
No, they are overfunded.
No opinion
66
0
2
4
6
8
1 2 3 4 5
9. On a scale from 0 (not sufficient) to 5 (very
sufficient), is the current framework,
provided by Regulation 1141/2014 sufficient
to counter potential financial abuse by
European political parties and foundations?
Limitations to just core activities,
better user-friendliness and
transparency of the data, and the
financial account management
were mentioned by other
respondents (with a score of 2). In
addition, the need for adapting the
definitions of ‘donations’, to add a
category of “‘other own resources’
which includes sponsorship,
contributions joint activities,
conference fees, sales of publications” and of ‘indirect funding’, to better allow for training
activities, were highlighted by several respondents. On the question on whether there might be a
need for additional measures to counter foreign influence on European political parties, half of
the respondents responded yes, a quarter no.
Opinions were very widespread on the
question of adequate financial information on
European political parties and foundations,
with the same number of respondents stating
currently provided information is sufficient, as
those stating it was not. In addition 89.5% of
respondents stated that financial information
on EUPPFs should be available in an online
database with none of the respondents
opposing this view.
Additional replies provided suggestions on
how to increase transparency of European political parties and foundations in terms of funding.
One suggestion included to have stricter rules on identifying donors, and giving more details on
itemized spending and income. Overall, several respondents stressed the need for user-
friendliness of the audit reports and donations website. Putting in place a system that allows for
crosschecking financial data with other public
data and cooperating with national authorities
were suggested to increase transparency.
68.4% of respondents were in favour of adapting
the level of sanctions in proportion to the level
of abuse.
63.2% of the respondents were in favour to
adjust or renew the ceilings for donations and
contributions. 21.1% were against this proposal,
and 15.8% had no opinion on the matter.
All respondents agreed that European political
foundations should be allowed to organise
0
2
4
6
not at all
0
not very
1
2 3 4 very
much 5
11.a. On a scale from 0 to 5, do you
think sufficiently detailed
information is publicly available on
the financial accounts of European
political parties and foundations?
63,2%
21,1%
15,8%
13. a. In the current Regulation
there is a threshold of EUR 18 000
per year per donor, but NO overall
ceiling; For contributions (=
membership fees) there is a
ceiling of 40% of the European
political parties' budget, but NO
threshold per contribution.
Yes No No opinion
67
seminars, conferences, study days or other educational or promotional events in the Member
States to promote themselves, as well as the European Union and its principles and policies.
One contribution suggested to either raise the ceiling or introduce an additional category for
funding, especially in the context of events.
Open answers were given on question 14: Are there any other suggestions on the financing of
European political parties and foundations you would like to make?
Maximum transparency, definitions for donations and indirect funding and cyber-security were
repeated issues for this response. Donations from third-countries were in particular need for
review to reflect the nature of the European democratic space but, at the same time, avoid foreign
interference. For protection against foreign interference, one national authority suggested that
the means to identify donors could be improved.
One respondent suggested the reduction of the co-financing rate for European political parties
from 10 to 0% and a lowering of the threshold for donations. Another respondent suggested
different forms of party funding with a mixture of lump sums, member-based and vote-based
funding and/or matching private funding. One national authority strongly urged for capping
donations and contributions with as minimum revision a cap on donations.
A system of appeal for decisions made by the Authority on Political Parties and Foundations was
mentioned three times. One contribution proposed to create a mechanism of administrative
recourse against its decisions, to have an alternative, and less costly alternative, to the Court of
Justice of the European Union. In addition, it was suggested that the mandate and resources of
the Authority on Political Parties and Foundations could be reviewed to strengthen its
investigative and sanctioning powers.
The contribution of a Member State sent by e-mail was strongly in favour of prohibiting direct or
indirect funding of European political parties by foreign powers (through national parties or
private donations), and pointed to the Declaration of France, Lithuania and Latvia on the
protection of democracies of 28 September 2020. In addition, it suggested recommendations to
Member States to ban foreign funding of national political parties and electoral campaigns.
However, it was pointed out from another organisation’s contribution that a prohibition of
indirect funding should not extend to participation in generalised training or networking
activities, which would create a barrier for young people to participate and engage in all levels of
politics.
In addition, other types of funding should be considered especially in the context of projects.
These could include sponsorships, project based revenues, or participant fees in activities. The
current lack of clarity has, for instance, consequences for participation of members from third
countries in events and their participation fees.
Finally, one more comment extended to the question of membership and to add an additional
category, such as observer, to avoid members without voting rights falling into the category of
donations.
68
31,6%
52,6%
15,8%
17. When visiting the websites of
national political parties, is it clear
to you which European political
party they belong to (if applicable)?
Yes No No opinion
16. When voting for a national list of
candidates at European elections,
do you know which European
political party they belong to?
Yes No opinion No
Two thirds of the respondents indicated that
they voted based on their national party
preferences during European elections.
Almost three quarters of the respondents knew
to which European political party belonged
the candidates on the national list that they
voted for.
However, half of the respondents pointed out that, when visiting the website of a national
political party, it was not clear to them which European political party they belong to.
66,7%
33,3%
15. When voting for European
elections, do you decide on your
vote based on European or national
political party preferences?
National parties European parties
69
0,0% 10,0%20,0%30,0%40,0%50,0%60,0%70,0%80,0%90,0%
100,0%
Establishing mandatory gender quotas in European
political parties and foundations
Use targets for gender representation
Make funding for European political parties and
foundations conditional on reaching gender targets
Gender Representation: Which of the following measures
would you be in favor of?
The need for improved visibility of the link
between the European and the national party
level was underlined by 89.5% of respondents,
who agreed that greater visibility was needed
to show the affiliation between national and
European political parties. Several suggested
ensuring that the European political party logo
was also on the national party’s ballot sheet,
their website, campaign and information
material and social platform and including
information on their respective European
political party in their official material. Three
respondents mentioned trans-national and fully
European lists in this context.
One contribution mentioned, in addition, that, in general, the transparency requirements for
online advertising of digital platforms should be strengthened, including to make it possible to
identify the natural or legal person on whose behalf the advertisement is displayed.
58% of the respondents felt that it was
necessary to improve gender representation in
European political parties, as opposed to
42.1% of respondents that were against this
view.
One contribution sent by mail explicitly stated
the support of gender parity.
57,9%
42,1%
19. Do you think it is necessary to
improve gender representation in
European political
parties/foundations?
Yes No
89,5%
10,5%
18. Is there a need to further
improve the visibility of affiliations
between national and European
political parties?
Yes No
70
Among the proposed measures for improved gender representation, the use of targets received
the highest support (40% of the respondents in favour). Conditional funding or mandatory gender
quotas only reached above 20%. None of the proposed actions were supported by a majority of
the respondents.
These stances are reflected in the following
question. Almost 60% of the respondents were
against using funding incentives for creating a
gender balance. Their main reasoning included
a focus on competence, merit and ability rather
than on gender or artificial quotas. Gender
balance was seen as something that needed to
be grown ‘naturally’ or already in the political
parties running for EU election.
Of those in favour for financial incentives,
several stressed this as a temporary measure
because current change is too slow. Examples
of the five EU countries tying their finances to
gender balance were given. One respondent
stressed that quotas and limitations were not a
recommendable path to follow but rather the
support of empowerment and support schemes
for female talents. This was also brought up in
a second response with the suggestion to link public funding to gender-related activities.
21. Are there any other suggestions on the transparency of gender representation that you
would like to make?
Overall, comments on the topic were very mixed. When asked for additional suggestions on
transparency of gender representation, one respondent stated concern that this issue was leading
to tensions in the relations between party members and was pointing rather to the topic of
discrimination in general.
One contributing non-governmental organisation suggested that “EuPPs should make public how
gender balance quotas are implemented in their parties in the annual activity reports and their
websites. EuPP should also be obliged to disclose their membership gender representation. At all
levels of leadership and at all governmental levels, there needs to be a certain gender balance”.
On the question of using software tools to assist
monitoring and detecting financial
irregularities, 84.2% of the respondents agreed
that this should be encouraged.
23,5%
58,8%
17,6%
20. Would you support using
funding incentives or penalties to
promote gender balance in
European political parties, for
instance in senior leadership
positions and among endorsed
candidates?
Yes No No opinion
84,2%
5,3%
10,5%
21.a. Should the use of software
tools to assist in monitoring and
detecting financial irregularities be
further encouraged?
Yes No No opinion
71
Almost half of the respondents indicated that more data should be made available for this
purpose. One third of the respondents stated that the available data is sufficient.
Additional points made included the need to
clarify the rules for the admission of
members of European political foundations
in order to limit the risks of foreign
interference.
47,4%
31,6%
21,1%
21.b. Are the currently available
data sufficient or should the
publication of more data be
mandated?
More publication of data is needed
Available data is enough
No opinion
72
3. Annex
The following provides a breakdown of responses and additional graphs for the questions that
were not visualized in the main text.
The majority of contributions came from individuals or micro and small companies. Only three
contributions were from medium and large companies.
0 1 2 3 4 5 6 7 8 9
Individual
Large (250 or more)
Medium (50 to 249 employees)
Micro (1 to 9 employees)
Small (10 to 49 employees)
Organisation size
Yes
2. Are you familiar with the
differences between
European political parties
and European parliamentary
groups?
4. At the European level,
do you feel more
represented by European
political parties or national
parties?
National parties
European parties
73
52,6%
26,3%
21,1%
10. Do you think that
additional measures are
necessary to counter foreign
(non-EU) influence on
European political parties
and foundations?
Yes No No opinion
13.b. Should the European
political foundations be allowed
to organise seminars,
conferences, study days or other
educational and promotional
events in the Member states to
promote themselves and the
European Union, its principles
and policies?
Yes
68,4%
12. Currently, the Regulation
foresees a fixed amount of
sanctions in case of abuse.
Should the Regulation adapt the
level of sanctions proportionate
to the level of abuse?
Yes No No opinion
89,5%
0,0%
10,5%
11.b. Should all financial
account information for
European political parties
and foundations be
publicly available in an
online database?
Yes No No opinion
74
Annex III: Who is affected by the initiative and how?
Overview of benefits – preferred option
Description Amount Comments
Increased financial viability for
EUPP/Fs
n/a Co-financing obligation would
be easier to match for EUPP/Fs
Decreased risk of foreign
interference through
intermediaries making
donations
n/a The due diligence mechanism
would make it easier for the
APPF to track donors
Meaningful relations with
likeminded affiliates outside the
EU
n/a Promoting democratic values
beyond the EU’s borders.
Improved visibility of affiliation
between EUPPs and national
member parties
n/a Raising awareness of the
existence and activities of
EUPPs and strengthening the
link between the national and
European level
Greater opportunities for
EUPP/Fs to fulfil their
constitutional role and raise
European political awareness
n/a The possibility to participate in
campaigns would allow for
bringing European political
issues in the forefront of
European elections and in
national referenda on European
issues
Promoting gender balance in a
more explicit manner
n/a Increased transparency on
gender balance is expected to
create peer pressure
Increased respect for EU values n/a More operational verification
mechanism should increase
compliance with EU values
Increased compliance with the
Regulation
n/a The modulated sanctions
regime and the strengthened
APPF would better address
infringements.
Reduced administrative burden n/a The proposal addresses
inefficiencies.
More legal certainty n/a Clearer division of labour
between the APPF and the
Authorising Officer of the
European Parliament.
EU’s financial interests better
protected and coherence with
TFEU guaranteed.
n/a
75
Overview of costs – Preferred option
Citizens EUPP/Fs APPF / EP Authorising
Officer
One off Recurrent One off Recurrent One off Recurrent
Funding
provisions
Direct
costs
n/a n/a n/a More
complex
financial
reporting
obligations
n/a More
complex
verification
process
Indirect
costs
n/a n/a n/a n/a n/a n/a
EU values,
democracy
and
transparency
Direct
costs
n/a n/a n/a More
complex
financial
reporting
obligations
n/a More
complex
financial
reporting
obligations
Indirect
costs
n/a n/a n/a n/a n/a n/a
Enforcement
and
administrative
burden
Direct
costs
n/a n/a n/a n/a n/a n/a
Indirect
costs
n/a n/a n/a n/a n/a n/a
76
Annex IV: Description of the analytical methods used
Due to the specificities described in the foreword, notably the limited number of actors involved,
the impact assessment used rather a qualitative methodology. No sophisticated statistical tools,
such as modelling were used.
Evidence was collected through the consultation of main stakeholders (interviews using open
questions) and through the 3-month long open public consultation (see Annex II).
This evidence was complemented by desk based research, carried out both by the Commission
services and two external studies. Financial data used was publicly available on the website of
the European Parliament or on website of the APPF, or taken over from the European
Parliament’s ex-post evaluation study on the application of the Regulation91
. The full
bibliography of the consulted literature can be found in Annex V.
91
Anglmayer I. (2021), Statute and funding of European political parties under Regulation 1141/2014 -ex post
evaluation. Available at:
https://www.europarl.europa.eu/RegData/etudes/STUD/2021/662646/EPRS_STU(2021)662646_EN.pdf
77
Annex V: Bibliography
AFCO Committee’s draft report on the application of Regulation (EU, Euratom) No 1141/2014
on the statute and funding of European political parties and European political foundations
(2021/2018(INI)), rapporteurs C. Goerens and R. Wieland. Available at:
https://www.europarl.europa.eu/doceo/document/AFCO-PR-692733_EN.pdf
Anglmayer I. (2021), Statute and funding of European political parties under Regulation
1141/2014 -ex post evaluation. Available at:
https://www.europarl.europa.eu/RegData/etudes/STUD/2021/662646/EPRS_STU(2021)662646_
EN.pdf
Annual Activity Report 2020 of the APPF (2021). Available at:
http://www.appf.europa.eu/cmsdata/238104/2020_AnnualActivityReport_AuthorityEUPPsEUPF
s.pdf
APPF Draft budgetary plan for 2019. Available at:
http://www.appf.europa.eu/cmsdata/214215/Draft_budgetary_plan_2019.pdf
APPF Draft budgetary plan for 2020. Available at:
http://www.appf.europa.eu/cmsdata/214214/Draft_budgetary_plan_2020.pdf
APPF Draft budgetary plan for 2021, p. 1. Available at:
http://www.appf.europa.eu/cmsdata/216549/Draft%20budgetary%20plan%202021.pdf
Bressanelli E. (2021), Investing in destabilisation: How foreign money is used to undermine
democracy in the EU, Study for the INGE Committee. Available at:
https://www.europarl.europa.eu/RegData/etudes/STUD/2021/653631/EXPO_STU(2021)653631
_EN.pdf
Charter on Fundamental Rights of the European Union (2000). Available at:
https://www.europarl.europa.eu/charter/pdf/text_en.pdf
Code of Good Practice in Electoral Matters: Guidelines and Explanatory Report - Adopted by the
Venice Commission at its 51st and 52nd sessions (Venice, 5-6 July and 18-19 October 2002).
Available at: https://rm.coe.int/090000168092af01
Communication from the Commission to the European Parliament, the Council, the European
Economic and Social Committee and the Committee of the Regions, 2020 Rule of Law Report -
The rule of law situation in the European Union, COM/2020/580 final. Available at: https://eur-
lex.europa.eu/legal-content/EN/TXT/?qid=1602583951529&uri=CELEX%3A52020DC0580
Communication from the Commission to the European Parliament, the Council, the European
Economic and Social Committee and the Committee of the Regions, A Union of Equality:
Gender Equality Strategy 2020-2025, COM(2020) 152 final. Available at: https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52020DC0152&from=EN
78
Communication from the Commission to the European Parliament, the Council, the European
Economic and Social Committee and the Committee of the Regions, Report on the 2019
elections to the European Parliament, COM(2020)252. Available at: https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52020DC0252&qid=1627216994733
Communication from the Commission to the European Parliament, the Council, the European
Economic and Social Committee and THE Committee of the Regions Commission Work
Programme 2021 A Union of vitality in a world of fragility, COM(2020)690 final. Available
with its annexes at: https://ec.europa.eu/info/publications/2021-commission-work-programme-
key-documents_en
Communication from the Commission to the European Parliament, the Council, the European
Economic and Social Committee and the Committee of the Regions on the European democracy
action plan, COM(2020)790 final. Available at: https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A790%3AFIN&qid=1607079662423
Compilation of Venice Commission opinions and reports concerning the stability of electoral
law, 14.9.2020, CDL-PI(2020)020. Available at:
https://www.venice.coe.int/webforms/documents/?pdf=CDL-PI(2020)020-e
Decision of the Authority for European Political Parties and European Political Foundations of
29 August 2018 to remove Alliance of European National Movements from the Register, OJ C
417, 16.11.2018. Available at: https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.C_.2018.417.01.0009.01.ENG&toc=OJ:C:2018:417:TOC
Decision of the Authority for European Political Parties and European Political Foundations of
13 September 2018 to remove Alliance for Peace and Freedom from the Register, OJ C 417,
16.11.2018. Available at: https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.C_.2018.417.01.0011.01.ENG&toc=OJ:C:2018:417:TOC
Decision of the Authority for European Political Parties and European Political Foundations of
13 September 2018 to remove Europa Terra Nostra from the Register, OJ C 418, 19.11.2018.
Available at: https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.C_.2018.418.01.0004.01.ENG&toc=OJ:C:2018:418:TOC
European Commission for Democracy through Law (Venice Commission) & OSCE Office for
Democratic Institutions and Human Rights (2020), Guidelines on Political Party Regulation (2nd
edition). Available at:
https://www.venice.coe.int/webforms/documents/default.aspx?pdffile=CDL-AD(2020)032-e
European Court of Auditors, Opinion 5/2017 concerning the proposal for a regulation of the
European Parliament and of the Council amending Regulation (EU, Euratom) No 1141/2014 of
the European Parliament and the Council of 22 October 2014 on the statute and funding of
European political parties and European political foundations, para. 11 and 12. Available at:
https://www.eca.europa.eu/en/Pages/DocItem.aspx?did=44564
79
European Court of Auditors, Special report No 13/2000 on the expenditure of the European
Parliament's political groups. OJ C 181, 28.06.2000. Available at: https://eur-
lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:C:2000:181:0001:0016:EN:PDF
European Parliament’s Resolution A9-0211/2020 on stocktaking of European elections
(rapporteur P. Durand). Available at: https://www.europarl.europa.eu/doceo/document/A-9-
2020-0211_EN.html
INGE Committee’s Working document on covert funding of political activities by foreign donors
of 22 April 2021 (rapporteur S. Kalniete). Available at:
https://www.europarl.europa.eu/doceo/document/INGE-DT-689654_EN.pdf
Judgment of the General Court of 25.11.2020, Alliance of Conservatives and Reformists in
Europe/European Parliament, T-107/19, EU:T:2020:560. Available at:
https://curia.europa.eu/juris/document/document.jsf;jsessionid=D94B8C2205E30C3FDCC31F18
436119E5?text=&docid=234334&pageIndex=0&doclang=en&mode=lst&dir=&occ=first&part=
1&cid=1694530
Kergueno, R. (2017), Fraud and boats: funding European political parties. Available at:
https://transparency.eu/boatfraud/
Merten H., Poguntke T. at al (2021), Study on the Evaluation of Regulation 1141/2014 on the
Statute and Financing of European Political Parties and European Political Foundations,
unpublished.
OSCE/ODIHR (2021), Submission to the European Commission and to the European
Parliament, Preliminary Comments on Reforming Regulation 1141/2014 of the European
Parliament and of the Council on the statute and funding of European political parties and
European political foundations (unpublished).
President von der Leyen (2019), A Union that strives for more – my agenda for Europe.
Available at: https://ec.europa.eu/info/sites/default/files/political-guidelines-next-
commission_en_0.pdf
Shreeves R. with Boland N. (2021), Women in politics in the EU – State of play. Available at:
https://www.europarl.europa.eu/RegData/etudes/BRIE/2021/689345/EPRS_BRI(2021)689345_
EN.pdf
Special Eurobarometer 477 (2018) – Democracy and Elections. Available at:
https://ec.europa.eu/commfrontoffice/publicopinion/index.cfm/Survey/getSurveyDetail/search/4
77/surveyKy/2198
Special Eurobarometer 91.5, The 2019 European elections: Have European elections entered a
new dimension? Available at: https://www.europarl.europa.eu/at-your-service/files/be-
heard/eurobarometer/2019/post-election-survey-2019-complete-results/executive-summary/en-
post-election-survey-2019-executive-summary.pdf
80
Special Eurobarometer 500, Future of Europe (October-November 2020). Available at:
https://www.europarl.europa.eu/at-your-service/files/be-heard/eurobarometer/2021/future-of-
europe-2021/en-key-findings.pdf
The Electoral Commission (2019), Campaign spending at the EU referendum. Available at :
https://www.electoralcommission.org.uk/who-we-are-and-what-we-do/elections-and-
referendums/past-elections-and-referendums/eu-referendum/campaign-spending-eu-referendum
Van Hecke S. at al., (2018), Reconnecting European Political Parties with European Union
Citizens, International IDEA Discussion paper 6/2018.
https://www.idea.int/sites/default/files/publications/reconnecting-european-political-parties-with-
european-union-citizens.pdf
Van Klingeren M., Orozco M., van Spanje J., De Vreese C. (2015), Party Financing and
Referendum Campaigns in EU Member States, Study for the AFCO Committee, pp. 70-86.
Available at:
https://www.europarl.europa.eu/RegData/etudes/STUD/2015/519217/IPOL_STU(2015)519217_
EN.pdf
Wolfs W. (2021), Impact assessment study – Revision of Regulation 1141/2014, unpublished.
World Economic Forum (2021), Global Gender Gap Report 2021. Available at:
http://www3.weforum.org/docs/WEF_GGGR_2021.pdf
81
Annex VI: Membership in EUPPs
Affiliated parties from outside the EU
Political
parties
Former EU
Member
States
EFTA
countries
Candidate
countries
Neighbourhood
countries
(Eastern
Partnership)
Council of
Europe
members
Others
European
People’s Party
(EPP)
- Norway (1
associated
and 1
observer
member)
Switzerland
(1 associated
member)
Albania (1
associated
member)
Montenegro
(1 associated
member)
North
Macedonia (1
associated
member)
Serbia (2
associated
members)
Armenia (2
observer
members)
Belarus (3
observer
members)
Georgia (2
observer
members)
Moldova (3
observer
members)
Ukraine (4
observer
members)
Lebanon (2
partners)
Morocco (2
partners)
Albania (1
associated
member)
Armenia (2
observer
members)
BiH (4 observer
members)
Georgia (2
observer
members)
Moldova (3
observer
members)
Montenegro (1
associated
member)
North
Macedonia (1
associated
member)
Norway (1
associated and
1 observer
member)
Serbia (2
associated
members)
Switzerland (1
associated
member)
Ukraine (4
observer
members)
Kosovo (1
observer
member)
Party of UK (2 full Iceland (1 Albania (1 Armenia (1 Albania (1
82
Affiliated parties from outside the EU
Political
parties
Former EU
Member
States
EFTA
countries
Candidate
countries
Neighbourhood
countries
(Eastern
Partnership)
Council of
Europe
members
Others
European
Socialists
(PES)
members) associate)
Norway (1
full member)
Switzerland
(1 associate)
associate)
North
Macedonia (1
associate)
Montenegro
(2 associates)
Serbia (1
associate)
Turkey (2
associates)
observer)
Georgia (1
observer)
Moldova (1
associate)
Egypt (1 observer)
Israel (2
observers)
Palestine (1
observer)
Tunisia (1
observer)
Morocco (1
observer)
associate)
Andorra (1
observer)
BiH (1
associate)
Georgia (1
observer)
Iceland (1
associate)
Moldova (1
associate)
Montenegro (2
associates)
North
Macedonia (1
associate)
Norway (1 full
member)
San Marino (1
observer)
Serbia (1
associate)
Switzerland (1
associate)
Turkey (2
associates)
UK (2 full
members)
Alliance for
Liberals and
Democrats for
Europe Party
(ALDE)
UK (1 full
and 1
affiliate
member)
Iceland (1 full
member)
Norway (1
full member)
Switzerland
(1 full
member)
Montenegro
(1 full
member)
North
Macedonia (1
full member)
Armenia (2
affiliates)
Azerbaijan (1
affiliate)
Belarus (1
affiliate)
Georgia (2
affiliates)
Moldova (1 full
member)
Ukraine (2 full and
2 affiliate
members)
Andorra (1 full
member)
Armenia (2
affiliates)
Azerbaijan (1
affiliate)
BiH (1 full and 1
affiliate
member)
Georgia (2
affiliates)
Iceland (1 full
member)
Moldova (1 full
member)
Gibraltar (1
affiliate)
Kosovo (1
full member)
83
Affiliated parties from outside the EU
Political
parties
Former EU
Member
States
EFTA
countries
Candidate
countries
Neighbourhood
countries
(Eastern
Partnership)
Council of
Europe
members
Others
Montenegro (1
full member)
North
Macedonia (1
full member)
Norway (1 full
member)
Russia (2
affiliates –
Yabloko and
Partiya
Narodnoy
Svobody)
Switzerland (1
full member)
Ukraine (2 full
and 2 affiliate
members)
UK (1 full and 1
affiliate
member)
European
Democratic
Party (EDP)
- San Marino (1
affiliated
member)
European Free
Alliance (EFA)
UK (4) Serbia (1) Serbia (1)
UK (4)
Nagorno
Karabakh (1)
European
Green Party
(EGP)
UK (2 full
members)
Norway (1
full member)
Switzerland
(1 full
member)
Albania (1 full
member)
Montenegro
(1 candidate)
North
Macedonia (1
full member)
Turkey (1
candidate)
Azerbaijan (1
associate
member)
Belarus (1
associate
member)
Georgia (1 full
member)
Moldova (1 full
member)
Ukraine (1 full
member)
Andorra (1 full
member)
Azerbaijan (1
associate
member)
Georgia (1 full
member)
Moldova (1 full
member)
Montenegro (1
candidate)
North
Macedonia (1
full member)
Norway (1 full
member)
84
Affiliated parties from outside the EU
Political
parties
Former EU
Member
States
EFTA
countries
Candidate
countries
Neighbourhood
countries
(Eastern
Partnership)
Council of
Europe
members
Others
Russia (1
associate
member)
Turkey (1
candidate)
Ukraine (1 full
member)
UK (2 full
members)
Identité et
Démocratie
Parti (ID)
UK (1
member)92
UK (1 member)
European
Christian
Political
Movement
(ECPM)
UK (1 full
member
and 1
associate)
Switzerland
(1 full
member)
Macedonia (1
full member)
Serbia (1
associate
member)
Armenia (1
associate)
Georgia (1 full
member and 1
associate)
Moldova (1 full
member and 3
associate)
Ukraine (1 full
member)
Armenia (1
associate)
Georgia (1 full
member and 1
associate)
Macedonia (1
full member)
Moldova (1 full
member and 3
associate)
Serbia (1
associate
member)
Switzerland (1
full member)
Ukraine (1 full
member)
UK (1 full
member and 1
associate)
European
Conservatives
and
UK (2 full
members)
Iceland (1 full
member)
Albania (1 full
member)
Macedonia (1
Azerbaijan (1 full
member)
Armenia (1 full
Albania (1 full
member)
Azerbaijan (1
Australia (1
full member)
Canada (1
92
This is according to their webpage. According to the information on the APPF’s website, the ‘For Britain’ is no
longer member.
85
Affiliated parties from outside the EU
Political
parties
Former EU
Member
States
EFTA
countries
Candidate
countries
Neighbourhood
countries
(Eastern
Partnership)
Council of
Europe
members
Others
Reformists
Party (ECR)93
full member)
Montenegro
(1 full
member)
Serbia (1 full
member)
member)
Belarus (1 full
member) Georgia
(1 full member)
Moldova (1 full
member)
Israel (1 full
member)
Tunisia (1 full
member)
full member)
Armenia (1 full
member)
Georgia (1 full
member)
Iceland (1 full
member)
Macedonia (1
full member)
Moldova (1 full
member)
Montenegro (1
full member)
Serbia (1 full
member)
UK (2 full
members)
full member)
Columbia (1
full member)
Faroe
Islands (1
full member)
Kenya (1 full
member)
Kosovo (1
full member)
New
Zealand (1
full member)
Northern
Cyprus (1
full member)
Tanzania (1
full member)
USA (1 full
member)
Party of the
European Left
(PEL)
UK (1 full
member, 1
partner)
Switzerland
(1 full
member)
Turkey (1 full
member)
Belarus (1 full
member)
Moldova (1 full
member)
Moldova (1 full
member)
Switzerland (1
full member)
Turkey (1 full
member)
UK (1 full
member, 1
partner)
Northern
Cyprus (2
observers)
93
Table completed based on the latest information on the APPF’s webpage – here all of these parties seem to be
full members. However, the party’s statute talks about 5 membership categories… ECR’s webpage is also unclear
about the categories of membership: https://ecrparty.eu/about#parties
86
*** *** ***