Built with courage in Brussels. Just not blinded by it.

BELGIUM is the starting point because it is the EU’s NGO capital. Over 2.300 ASBLs and AISBLs manage billions in EU funds here. These are the official numbers from 2014 to 2023 (EU Financial Transparency System):

6th

most EU-funded EU member (after Spain, Italy, France, Germany, Poland – in this order). €31.16 billion.

1st

place in “Private companies” funding, (Germany, France, Spain, Italy, Netherlands, Poland come after Belgium). €21.13 billion.

2nd

in allocated sums exclusively attributed to NGOs and NFPOs. First is Germany – received €11.89 B; Belgium – received €7.87 billion.

Belgium's
Unique FUNDING Profile

67.8% EU funding allocated to private sector entities.
No national anti-fraud office

As the heart of EU institutions, Belgium presents a unique profile in EU direct management funding that demands closer scrutiny.

Belgium Funding Profile
€31.156 M

Total Funding

€5.982 M

NFPO Funding

€1.883 M

NGO Funding

67.8%

Private Sector

Pilot Investigations are whistleblower-initiated, evidence-based case studies that expose where EU and Belgian oversight systems fail to protect public money.

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Belgium received €31 billion in EU funds over ten years, yet OLAF concluded only 4 (four) fraud investigations – less than Congo, Uganda, Zambia, Kosovo, Syria.

 FACTS:

  • No explanation on case selection criteria.
  • No national anti-fraud office in Belgium.
  • No public data on how many allegations are made or rejected.

What we demand:

  1. OLAF to publish case selection criteria and strategic priorities.
  2. OLAF to disclose rejection rates by country.
  3. European Commission to propose mandatory anti-fraud offices in every member state.
  4. European Commission to explain oversight of countries with low investigation rates

Status:
🔴 No action taken by OLAF or by the European Commission.

A Brussels NGO director earns €25.000/month from EU funds — a systemic failure in NGO financial oversight?

 FACTS:

  • Staff of 11, only 3 full-time employeess.
  • “Micro-AISBL” – no public financials.
  • 40 EU-funded projects; even 184 hours / month reported per executive.

What we demand:

  1. Audit of executive compensation and HR practices in EU-funded NGOs.
  2. Conditionality of EU funding for NGOs to disclose leadership pay, board remuneration, and financial statements.
  3. EU-wide minimum standards for annual public reporting on executive pay, board payments, and service contracts for EU-funded NGOs, as called for by ECA, OLAF, and the EP.

Status:
🔴 No audit, director still in position, no accountability, no sector-wide reforms.

Formal, well-documented, supported by evidence fraud complaints, get ignored by Belgian and EU authorities.

 FACTS:

  • SPF Finance, SPF Emploi and ONSS fully dismissed and ignored fraud suspicions.
  • OLAF deemed the case as “liable for criminal prosecution” reffering it to EPPO – who denied competence.

What we demand:
*Who watches the Watchdogs

  1. EU audit to review national and EU anti-fraud bodies: publish yearly, country-level data on complaints received, cases opened and closed, reasons for closure, and outcomes.
  2. Binding EU standards for institutional accountability and whistleblower response, with external review and sanctions for non-compliance.

Status:
🔴 No oversight | 🔴 No public complaint statistics | 🔴 No binding standards

A continuously updated, citizen-driven record of Belgian NGOs and non-profits receiving major EU funding and displaying red flags in their official filings (Time frame: 2014-2023).

Every entry is based on verified public data — staff numbers, annual accounts, funding totals, and compliance with Belgian and EU transparency laws.

This map makes no accusations: it documents patterns that anyone can check, exposing where transparency breaks down and oversight is needed. We add one new EU-funded NGO to the map every day — a continuous, citizen-driven effort to build Europe’s most complete transparency record.

FACTS:

➤ Registered as Importance 1: officially declares 1–4 employees in Belgium.

➤ Reportedly spent €9.2 million — over 95% of its 2023 operating budget — on “services and miscellaneous goods”.

➤ Declared just €7.146 in employee wages for 1.552 hours worked — for a multi-million euro operation.

Potential red flag:
For an organization managing multi-million euro projects, the employee footprint is implausibly low. It strongly suggests that most “staff” are paid as consultants, service providers, or via external contracts, not as employees — raising compliance issues under Belgian labor law and EU grant rules.

FACTS:

➤ Registered as Importance 1: officially declares only 1–4 employees in Belgium, despite listing 8 staff on its own website.

➤ Received over €10.28 million in direct EU funding between 2014 and 2023, with annual grants often exceeding €1 million for single projects.

➤ Has filed only one annual account with the Belgian National Bank (NBB)—for the year 2013—using the abbreviated “schéma abrégé” model, with no subsequent filings available despite ongoing multi-million euro funding.

Potential red flag:
An organization managing multi-million euro EU projects and coordinating a pan-European enforcement network. The declared employee footprint is implausibly low and the absence of up-to-date annual accounts is a serious transparency concern. 

FACTS:

➤ Registered as Importance 2: officially declares 5–9 employees in Belgium, listing a team of 15 people on the website.

➤ 2023 personnel costs: €739.421 for 9.6 FTEs, with 15.353 hours worked.

➤ However, “services and miscellaneous goods” spending is €1.699.704 in 2023 — more than double the personnel costs and over half of all operating expenses.

Potential red flag:
Despite a declared payroll of 9–10 employees, the disproportionately high “services” spending and lack of transparency about its composition suggest possible heavy reliance on external contracts, consultants, or partner organizations.

FACTS:

➤ Registered as Importance 1: officially declares only 1–4 employees in Belgium, despite being the Brussels hub for a global NGO with a staff of over 160 worldwide.

➤ Received €13.36 million in direct EU funding since 2014, with annual grants regularly exceeding €4 million.

➤ Has filed only four annual accounts with the Belgian National Bank, using the “modèle abrégé” (abbreviated or micro-AISBL) format, which provides minimal detail on HR, consultant, or project-level costs.

➤ 2023 Belgian account shows €383,066 in personnel costs for an average of 3.2 FTE (very high for the NGO sector), and €4.4 million in “services and miscellaneous goods” — over 90% of total operating expenses — without any public breakdown.

Potential red flag:
An organization managing multi-million-euro EU projects. The overwhelming reliance on “services” spending, minimal payroll, and use of abbreviated accounts strongly suggest that most operational work is handled by external consultants, partner entities, or global staff not reported in Belgium.

FACTS:

➤ Registered as Importance 1: officially declares only 1–4 employees in Belgium (nano/micro-AISBL), despite coordinating major EU research projects.

➤ Received over €7.68 million in direct EU funding between 2019 and 2022, with multiple large grants under the Euratom Research and Training Programme.

➤ Has not filed a single annual account with the Belgian National Bank (NBB) since transferring its activities from France to Belgium in 2018.

➤ Provides no annual reports, or financial statements on its website.

Potential red flag:
Despite handling multi-million-euro EU projects, ENEN operates with a minimal declared Belgian staff and has failed to file legally required annual accounts for several years. The total absence of public financial or HR transparency makes it impossible to know how EU funds are managed, who actually delivers the work, or whether Belgian and EU rules on accounting, employment, and grant spending are being respected.

FACTS:

➤ Registered as Importance 1: officially declares only 1–4 employees in Belgium, despite managing €6.55 million in EU grants for major international justice projects.

➤ The Brussels entity files annual accounts in the micro-AISBL format, reporting just 1.8 FTE in 2024 (1 FTE in 2023), with €172.962 in personnel costs for 2024 and only €124.859 in 20236.

➤ For 2024, over €584.656 was spent on “other operating charges” (autres charges d’exploitation) — more than triple the payroll.

➤ The Belgian entity is tightly linked to the US-based ICTJ Inc., with significant intra-group financial flows, but without detailed disclosure of the nature or terms of these transactions.

Potential red flag:
While the Brussels office is the legal recipient of multi-million euro EU grants, the declared Belgian staff is minimal and the vast majority of costs are channeled through “other charges”. The lack of transparency about who actually delivers project work, creates a significant barrier to public and regulatory scrutiny.

FACTS:

➤ Registered as Importance 1: officially declares only 1–4 employees in Belgium, yet publicly lists an 11-person secretariat and coordinates over 275 member organizations and “22+” simultaneous EU-funded projects.

➤ Reporting nearly 2 FTE lobbyists in the EU Transparency Register, has received €5.12 million in direct EU funding since 2014.

➤ Despite this substantial turnover and its pivotal role in EU-funded projects, it maintains nano-AISBL (micro-entity) status and has never published any annual accounts in the Belgian National Bank’s Central Balance Sheet Office.

➤ The Board of Directors (15 corporate members, each paying €20.600/year) and “Policy Advisory Committee” are dominated by representatives of multinational corporations, while other member categories have much less representation.

Potential red flag:
A combination of a large, corporate-dominated membership, significant annual revenues from both EU grants and membership fees, and persistent failure to file legally required annual accounts creates a major transparency and accountability gap. The organization’s declared nano-AISBL status is inconsistent with its financial scale and operational footprint.

FACTS:

➤ Registered as Importance 1: officially declares only 1–4 employees in Belgium (nano/micro-AISBL), despite coordinating major EU projects.

➤ Received €6.73 million in direct EU funding since 2018, including a single €4.58 million grant in 2023 for the “WYDE Political Parties” project.

➤ The only annual account filed with the Belgian National Bank (NBB) is from 2019, and it is not a standard year-end account but a statement of assets and liabilities at transfer”, required when ENoP moved its registration from Luxembourg to Belgium.

➤ Provides no annual reports, or financial statements on its website.

Potential red flag:
Persistent classification as a micro-entity, absence of annual accounts or social balance since its 2019 transfer to Belgium, and lack of any public breakdown of HR or consultancy costs are all inconsistent with Belgian legal requirements for AISBLs receiving multi-million-euro EU grants. This structure makes it impossible for the public to verify who actually delivers EU-funded work, how funds are spent, or whether labor and transparency obligations are being respected.

FACTS:

➤ Registered as Importance 1: officially declares only 1–4 employees in Belgium since February 2020.

➤ Received €3.53 million in contracted EU funding since 2014, with three major grants for conservation and anti-trafficking projects in Africa, as confirmed by the EU Financial Transparency System and Qlik dashboard.

➤ No annual accounts have ever been filed with the Belgian National Bank (NBB) — the Central Balance Sheet Office confirms “no results” for Conservation Justice, despite ongoing activity and substantial EU funding.

➤ No public disclosure of Belgian payroll, HR structure, or financial statements. The organization’s board and statutes are published in the Moniteur belge, but there is no evidence of Belgian-based staff or local payroll.

Potential red flag:
Persistent micro-entity status, total absence of annual accounts or Belgian payroll disclosures, and ongoing management of multi-million-euro EU-funded projects are all inconsistent with Belgian ASBL legal requirements and EU grant transparency standards. The lack of any public financial reporting or HR transparency makes it impossible for the public to verify how EU funds are managed, who delivers the work, or whether Belgian labor, accounting, and grant rules are respected. 

FACTS:

➤ Registered as Importance 1: officially declares only 1–4 employees in Belgium (nano/micro-AISBL).

➤ Received €3.67 million in direct EU funding between 2017 and 2023.

➤ No annual accounts have ever been filed with the Belgian National Bank (NBB).

➤ No annual reports, financial statements, or breakdown of project spending are published on the official website.

➤ The organization’s website and public profiles list a network of European regions and partners, but do not disclose the  governance/board composition.

Potential red flag:
Despite managing €3.67 million in EU grants and acting as a key Brussels-based network for regional startup policy, SERN maintains micro-AISBL status with only 1–4 declared Belgian employees and has never filed annual accounts. There is no public disclosure of financial statements, making it impossible for citizens to verify how EU funds are managed. The lack of transparency raises questions about oversight, accountability, and the real operational footprint of SERN in Belgium.

FACTS:
➤ Registered as Importance 5: officially declares 50+ employees in Belgium.

➤ €3.511.003 for 45.7 FTE (79,310 hours worked). 2023 “services and miscellaneous goods” spending: €3.527.628 — almost exactly equal to payroll, and over 49% of total operating expenses.

➤ 2023 income: €7.136.750, of which €5.656.915 from projects — mainly EU grants.

Only one annual account (for 2023) has ever been filed with the Belgian National Bank (NBB).

➤ CEPS Foundation (Fondation Centre for European Policy Studies, BE0863021173): separate legal entity at the same address, with 0 employees and no annual accounts filed at NBB.

Potential red flag:
Despite its scale, large payroll, and €25 million in EU grants, CEPS has only filed one annual account (for 2023) with the Belgian National Bank. Nearly half of all operating expenses in 2023 (€3.5 million) went to “services and miscellaneous goods”, but the annual account provides no public breakdown of these costs, limiting transparency on the use of consultants, subcontractors, or external partners. 

FACTS:

➤ Registered as Importance 1: officially declares 1–4 employees in Belgium (micro-AISBL), despite naming over 15 team members on their website. The employer registration is marked as “suppressed” (de-registered) since 15/11/2021.

➤ Received a single €16.3 million grant awarded in 2023 under the Digital Europe Programme — an exceptionally large sum for a micro-AISBL.

➤ 2023 annual account (the only one ever filed): €9.756 personnel costs with no FTEs reported. €5.063.026 in assets at year-end 2023, up from €2.942.021 in 2022, reflecting a dramatic increase in receivables and cash.

➤ The €16.3 million DS4SSCC project (Digital Europe Programme) lists OASC as the lead beneficiary, but there is no public breakdown of how the grant is distributed, spent, or managed among the consortium partners.

Potential red flag:
Persistent micro-entity status, total absence of annual accounts or Belgian payroll disclosures, and ongoing management of multi-million-euro EU-funded projectss. The lack of any public financial reporting or HR transparency makes it impossible for the public to verify how EU funds are managed, who delivers the work, or whether Belgian labor, accounting, and grant rules are respected. 

Chart 1: the amount of EU funding VS OLAF investigations, 2014-2023

Which EU member should we look into next, based on their number of OLAF investigations and funding in 10 years, from 2014 to 2023?

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