Published June 14, 2026 | Version v1

Public verifiability of EU grants to non-profit beneficiaries: an entity-level, cross-registry method - The Belgium Pilot, 2014–2024

Authors/Creators

Description

This paper documents the method, sources, validation record and limitations of an entity-level, cross-registry dataset of European Union grants to non-profit beneficiaries registered in Belgium. Grant records published by the European Commission's Financial Transparency System (FTS) for Belgian NGO and non-profit beneficiaries over 2014 to 2024, comprising 22,179 individual grant award rows published under 2,507 beneficiary name strings and totalling €7,887,561,082.54 in committed amounts, were reconciled at legal-entity level against three official Belgian public registries: the Crossroads Bank for Enterprises (CBE) for legal identity, the National Social Security Office (ONSS) for employer registration, and the National Bank of Belgium (NBB) Central Balance Sheet Office for annual-account filings.

A four-layer reconciliation produced 758 verified legal entities, each with at least €500,000 in cumulative committed grants, jointly accounting for €7,288,841,649, equal to 92.41% of the funding universe.

The dataset measures public verifiability, defined as what a citizen can establish about a publicly funded organisation from official public records. It is a citizen-access index, not a compliance index, and it makes no finding on legality, regularity or fraud.

The method was tested before publication through formal notification of five EU institutions and a structured right-of-reply process with the profiled organisations. No data point has been contradicted, and the European Court of Auditors confirmed in writing on 24 April 2026 that the analysis aligns with observations in its Special Report 11/2025.

The paper states the scope limit precisely: the FTS covers EU budget implementation under direct and indirect management only, so the dataset is a documented floor of EU funding to these entities, not a census.

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Belgium Pilot - Methodology.pdf

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Additional details

Dates

Submitted
2026-06-14

References

  • https://www.eca.europa.eu/en/publications/SR-2025-11
  • [2] European Commission, Financial Transparency System, "About" page — coverage statement. ec.europa.eu/budget/financial-transparency-system/about.html
  • [3] Regulation (EU, Euratom) 2024/2509 of the European Parliament and of the Council of 23 September 2024 on the financial rules applicable to the general budget of the Union (recast), OJ L, 2024/2509, 26.9.2024; Article 38. eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202402509
  • [4] Belgian Code of Companies and Associations (Law of 23 March 2019), Articles 3:47–3:51; Royal Decree of 25 May 2024 (filing thresholds for associations).
  • [5] Law of 27 December 2006 and Royal Decree of 30 January 2001 (self-employed registration; accounting Code 61).
  • [6] French Code de commerce, Article L612-4 (statutory auditor for associations receiving ≥ €153,000 in annual public subsidies), cited as comparison
  • [7] Crossroads Bank for Enterprises (FPS Economy); National Social Security Office (ONSS); National Bank of Belgium, Central Balance Sheet Office. Public consultation interfaces.
  • [8] OLAF reply to request for access to documents under Regulation (EC) No 1049/2001, EASE 2025/6050, Ares(2026)185503, 8 January 2026 (no NGO-specific statistics).
  • [9] Commission reply to request for access to documents under Regulation (EC) No 1049/2001, EASE 2025/5328, Ares(2026)989413, 28 January 2026 (Horizon 2020 HR-focused audits of Belgian beneficiaries).
  • [10] European Court of Auditors, written response to EU Money Monitor, 24 April 2026.
  • [11] EU Money Monitor, Belgium NGO Funding Intelligence Pack, Volume I (2026), methodology and data-quality sheet, and published right-of-reply correspondence, money-monitor.eu.