A Letter to European Commission Vice-President for Values and Transparency
Published: Feb 25, 2021 Reading time: 6 minutesIn a letter addressed to Vera Jourova, European Commission Vice-President for Values and Transparency, People in Need, along with seven other European organizations, have provided a number of recommendations for an effective implementation of the Citizens, Equality, Rights and Values (CERV) programme.
With 1,5 billion EUR allocated for the years 2021-2027, CERV is an important tool for fostering European values projects. To maximise its impact and accessissiblity, we offered 14 steps that should be undertaken by the Commission.
The letter was co-signed by 150 plus organizations across the European Union and beyond.
Dear Vice-President Věra Jourová,
Civil society organisations (CSOs) across the EU have long advocated for greater and more
accessible European financial support for projects fostering European values at the local,
national and transnational levels. This is why, as members of the civil society, we welcome
the unprecedented decision of the EU Council and the European Parliament to allocate
over 1.5 billion EUR for the Citizens, Equality, Rights and Values (CERV) programme under
the 2021-2027 Multiannual Financial Framework.
We highly appreciate that the draft regulation on CERV programme clearly stresses the
importance of funds’ accessibility to civil society actors, including grassroots CSOs, who
address challenges to European values locally. We are also glad that emphasis has been
put on flexible support to CSOs which foster democracy, the rule of law and fundamental
rights, as reflected by the creation of the new ‘Union values’ strand (Article 2 of the draft
regulation).
We warmly welcome the commitment to implement the Programme in a “user-friendly
way”, and we can only agree with the statement that “particular attention should be paid
to accessibility [of the CERV programme] to civil society organisations at transnational,
national, regional and local level, including local grass root civil society organisations as
well as to the capacity of beneficiaries [which] should include consideration of the use of
financial support to third parties, where appropriate” (Recital 18).
Expectations are high and we understand that full and effective implementation of this
ambitious Programme will be challenging. Thus, we express regret over the fact that the
Commission has not organised a consultation with CSOs on the implementation of the
Programme, particularly in the context of the preparations of the 2021 Annual Work
Programme. We do encourage the Commission to do so for the rest of the programming
period.
Indeed, drawing on our vast experience in promoting and protecting European values as
civil society actors, and our experience related to various grant programs for civil society
financed by private, public and intergovernmental entities, we wish to make a number of
recommendations in the interest of maximising the CERV Programme’s accessibility and
effectiveness. We encourage you to take them into consideration:
- 1. A significant part of CERV funds should be distributed via national or regional
intermediaries (grant programme operators) or consortia of several
intermediaries. Intermediaries should be selected from among individual civil
society organisations, networks or consortia in an open, transparent and
competitive procedure based on their earlier experience, independence and
engagement with civil society, as well as with grant programmes.
- 2. The Programme should strengthen national networks and associations of
grassroots CSOs to boost resilience of the civil society sector.
- 3. Financing projects aimed at promoting and safeguarding EU values, including
through awareness raising and educational activities, is more important than
ever. However, for CSOs to have the capacity and resources to engage in such
activities, it is crucial for the Programme to also provide core funding to support
CSOs own existence and operations, in particular for organisations which operate
on local or national level. It should also help build capacity of CSOs, as well as
support their institutional development and resilience.
- 4. National and cross-border partnerships of applicants are welcome but should not
be preferred to applications submitted by individual CSOs. Applicant
organisations should be allowed to partner with informal groups.
- 5. Grant application and reporting procedures should be user-friendly and
accessible to all kinds of eligible civil society actors, including those with limited
administrative capacity.
- 6. Grants should be divided into small, medium and large ones, to enhance access
to funding for organizations from different regions with various levels of capacity
and experience. Application procedures for small grants should be simplified.
- 7. The timeframe for the implementation of proposals under action or operating
grants should be flexible – for some of the programmatic objectives, the usual
timeframe of 2-3 years may not be suitable to build capacity and ensure
sustainability of the sector.
- 8. Application processes should be divided into two stages: (1) submission of a
short project concept note and indicative budget; (2) submission of the full
project proposal. Between the two stages, CSOs with less capacity should receive
assistance (in the form of workshops or consultation provided e.g. by external
contractors) in order to enable them to develop their ideas into fully-fledged
projects. Submission of formal documents (e.g. issued by tax authorities) should
not be required until the signature of contract.
- 9. The co-funding requirement should be applied depending on the size of projects.
Smaller and medium-sized projects implemented by grassroots CSOs should be
exempted from the co-funding requirement or it should be reduced to maximum
5%. In-kind and voluntary work should be recognised as an alternative for own
financial contribution. Greater use of lump sums should be applied, and more
flexibility as regards the use of the budget should be allowed. Beneficiaries
should be able to receive funds in their local currency, which would reduce risks
related to fluctuation of exchange rates.
- 10. The disbursement system of the grants should not undermine cash flow of grant
beneficiaries. Beneficiaries should not be expected to pre-finance the
implementation of projects. A new instalment should be disbursed when 70% of
the previous instalment has been used up.
- 11. All information and procedures related to the Programme, including application
forms, instructions for applicants and Q&As should be available in all official EU
languages. The Commission should organise webinars in local languages for
potential applicants to provide orientation on the Programme.
- 12. A Programme Council should be set up as the highest decision-making authority
of the Programme. Civil society organisations, appointed in consultation with
European networks of CSOs or with national associations of CSOs, should take
part in the Council and participate in the oversight of the implementation of the
Programme.
- 13. Independent experts, with expertise and proven knowledge of the sector,
appointed in consultation with European networks of CSOs or with national
associations of CSOs, should take part in the assessment of grant applications
(steps would have to be taken to avoid conflicts of interest).
- 14. The Commission should organize information campaigns on the CERV
Programme in EU member states in partnership with local CSOs and Programme
operators (rather than PR companies).
We hope these suggestions can prove useful in developing work programmes and calls for proposals so that the Programme can give effective support to CSOs against the background of the current challenges they face across the EU. We also highly recommend the Good Grantmaking Guide, that summarises the experience of Central European grantmaking foundations under the umbrella of the Environmental Partnership Association.
We remain ready and open to consult with you through any means about the possible design and modalities of the Programme setup.
Yours sincerely,
Raffaella Bolini & Jean Marc Roirant, Co-Presidents, European Civic Forum – EU Network
Balázs Dénes, Executive Director, Civil Liberties Union for Europe – EU Network
Karolina Dreszer-Smalec, President, National Federation of Polish NGOs – Poland
Ewa Kulik-Bielińska, Director, Stefan Batory Foundation – Poland
Veronika Móra, Director, Hungarian Environmental Partnership Foundation – Hungary
Šimon Pánek, CEO, People in Need – Czech Republic
Márta Pardavi, Co-Chair, Hungarian Helsinki Committee – Hungary
Ionuț Sibian, Managing Director, Civil Society Development (CSDF) – Romania