Belgium Pilot · 2026 | Independent Investigation | money-monitor.eu
EU money is public.
The trail is not.
€7.89 billion in EU grants. 758 verified NGOs and not-for-profits. Four official public registries. No EU institution had ever connected them. One journalist did.
€7.29 bn
EU grants to Belgian NGOs mapped and verified, 2014–2024.
758
NGOs & non-profits verified
across 4 public registries
22,179
FTS grant records for Belgian NGOs, 2014–2024.
1,115 / 8
OLAF fraud signals received
vs. investigations concluded
Belgium 2014–2024
5
EU institutions formally
notified · all responses
published verbatim
An independent investigation by Anca Păduraru, founder of EU Money Monitor · Brussels, Belgium
13 May 2026
OLAF released country-level fraud intake data it had not published since 2018. Same data. Same institution. Two different Director-Generals. Six months apart. Two days after institutional escalation. Read more >>
INVESTIGATION | WHO WATCHES THE WATCHDOGS?
Belgium generated 36.1% of OLAF’s EU fraud signals between 2019 and 2024. More than France, Germany, Italy, and Spain combined.
OLAF concluded 6 investigations.
FOI EASE 2025/6477 · OCM data released 13 May 2026 · OLAF Annual Reports 2019–2024
975
/
6
OLAF fraud signals received vs. investigations concluded — EU-27, 2014–2024
Source: OLAF Annual Reports 2014–2024 · FOI EASE 2025/6477, OCM(2026)15968 · Analysis: EU Money Monitor
Belgium: fraud signals received vs. OLAF investigations concluded (2014–2024)
Cumulative totals 2014–2024 — EU-27
EU Money Monitor · EU-27 rate 21.8% = 1,017/4,670. Belgium 0.7% = 8/1,115. Luxembourg 0.0% = 0/347..
The European Anti-Fraud Office – OLAF, is the diagnostic instrument.
The Commission and Parliament rely on OLAF to claim oversight of EU money.
Belgium was also first in the EU for OLAF total criminal referrals to EPPO, 2021-2024. The table showing this data was also removed from the 2025 OLAF Annual Report without explanation. A new FOIA request has been filed. The previous table removed, of the country-level intake, was disclosed under a new Director-General. Both tables showed Belgium first. Both were removed without citing a legal basis.
Last published articles:
Brussels’ transparency lobby faces the transparency test
TI-EU branded Parliament’s NGO oversight group “illegitimate”. EU Money Monitor traced €7.29bn: invisible workforce, partial audits, removed OLAF tables and
OLAF stopped publishing two fraud tables. Belgium was first in both.
Every year, OLAF, the European Anti-Fraud Office, publishes a mandatory annual report. It goes to four EU institutions: Parliament, Council,
⚠ OLAF finally disclosed: 975 fraud signals about Belgium. It closed 6 cases.
For one year I asked the European Anti-Fraud Office (OLAF) to explain the 4 closed cases in Belgium in a
INVESTIGATION | THE PLATFORM
Publication is not verification.
Nor is it transparency.
The EU publishes grant data. EU Money Monitor tests whether that data can be verified against public records: legal identity, workforce, accounts, delivery capacity, and oversight. For the first time, four official public registries are connected at entity level for an entire sector, one member state.
01
Visible
What public records confirm.
What public records confirm. Every figure comes from a named public registry. Every entity can be checked independently. No claim requires access beyond what is already public and free. This is why no institution has disputed a single data point.
FTS · CBE · ONSS · NBB · All public · All free · All verifiable
02
Plausible
What the evidence supports as a legitimate concern.
Named. Sourced. Never extrapolated beyond what the record shows. When 975 fraud signals produce 6 concluded investigations, and the country has no national anti-fraud strategy, the evidence supports one documented finding: a structural oversight gap.
No institution has contradicted a single data point.
03
Provable
What authorities must determine.
EU Money Monitor does the part OLAF, EPPO, and national judicial authorities cannot dismiss: it places verified facts on the public record, entity by entity, source by source, so the system can finally be tested.
Five institutions formally notified. All responses published.
EU Money Monitor does not allege, does not speculate, does not extrapolate. It documents what the public record confirms, names what the evidence supports, and asks institutions to do their part. The same standard. Every institution. Every country. No exceptions.
FINDINGS | The Numbers — Belgium Pilot 2026
What four public databases,
connected for the first time, show for Belgium
Every figure is sourced to a named public document or a formal FOIA reply. No institution has disputed any of them.
The identification gap
990
The EU publishes a name list of who received public money. For 990 NGOs on that Belgian list, no registration number appears – no VAT number. There is no way for any citizen to identify the legal entity behind the grant. The EU’s own rules require that number to be published. For 39.5% of Belgian beneficiary entries, it is not.
FTS Belgium export 05/03/2026 · Financial Regulation (EU, Euratom) 2024/2509 Art. 38
The disclosure floor
83.8%
8 in 10 Belgian NGOs that received EU grants produce no publicly audited accounts. Citizens cannot verify how €3.82 billion was spent. In France, any association receiving €153,000 in public money must have an independent auditor by law. In Belgium, no such rule exists. The threshold is the size of the organisation, not the amount of public money it manages.
NBB Central Balance Sheet Office × FTS DM+IM 2014–2024 · Belgian CSA/WVV Law 23 March 2019 · French Code de commerce Art. L612-4
The EU audit record
0.015%
Between 2017 and 2024, five EU research agencies completed 45 staff cost audits of Belgian NGOs receiving H2020 research grants, and found €1.2 million in ineligible costs. That is the only published HR audit figure for Belgian NGOs across all EU programmes. For Horizon Europe and every other EU programme: zero HR audits of Belgian NGOs concluded.
FOIA EASE 2025/5328 · Commission response Ares(2026)989413 · 28 January 2026 · DG RTD, REA, CINEA, HADEA
The parallel grant load
€5.48bn
251 Belgian NGOs held 10 to 889 EU grants running in parallel in a single year, managing €5.48 billion, three quarters of all verified funding. EU rules require staff hours to be recorded per grant. Nobody adds those hours up across all grants held by the same organisation at the same time. This a question the system was never designed to ask.
FTS EU Financial Transparency System × ONSS · Horizon Europe MGA Art. 6.2.A · FOIA EASE 2025/5328
The invisible workforce
€1.20bn
298 Belgian NGOs with zero to four registered employees managed €1.20 billion in EU grants over a decade. Their workforce, however large in practice, is hired through service companies and recorded in the accounts under the same budget line as rent (Code 61). No name, no rate, no public trace. The people doing this publicly funded work appear in no public record.
FTS × ONSS · Belgian Law 27 December 2006 Arts. 333–336 · Royal Decree 30 January 2001
The filing gap
€1.74bn
285 Belgian NGOs that received EU grants have no financial accounts filed in Belgium. They managed €1.74 billion over ten years. There is no public record of their revenue, their costs, or their payroll. This is not a gap in enforcement. Belgian law simply does not require them to file.
NBB Central Balance Sheet Office × FTS DM+IM 2014–2024 · Belgian CSA/WVV Law 23 March 2019
European Court of Auditors
24 April 2026 · EUMM-ECA-2026-001
Your analysis confirms some of our observations presented in our report No 11/2025, which concern weaknesses in the Commission's transparency regarding the EU funding granted to NGOs."
ECA Press Office · ECA did not verify the legality or regularity of EU funding spent by NGOs.
FINDINGS | The oversight chain
Five institutions. One test.
Can the system see the funding chain?
EU Money Monitor sent formal journalistic notifications to the five institutions responsible for budget control, audit, anti-fraud, prosecution and discharge. No EU institution has contradicted a single finding.
European Court of Auditors
Substantive reply received
“Your analysis confirms some of our observations presented in our report No 11/2025, which concern weaknesses in the Commission’s transparency regarding the EU funding granted to NGOs.”
Caveats: in SR 11/2025 “we did not verify the regularity and legality of EU funding spent by NGOs” and that “there might be valid explanations for what could appear like an anomaly or an issue.”
European Commission
No reply
Addressed by name to the President of the European Commission, the Commissioner for Budget, Anti-Fraud and Public Administration, and twelve named senior officials. The Commission has not denied receipt, has not contested any documented finding. The Code of Good Administrative Behaviour deadline of fifteen working days closed on 6 May 2026.
European Parliament
No reply
The CONT Chair stated publicly in April 2025: “There is still no complete overview of EU funding to NGOs.” The Belgium pilot answers exactly that question for one member state, the second-largest NGO recipient in the Union. A formal letter was sent to twenty named MEPs on 11 May 2026 with a reply deadline of 1 June 2026.
European Anti-Fraud Office
Findings not addressed
OLAF redirected EU Money Monitor to the public citizen fraud portal. No finding addressed. No file reference provided. No responsible official named. The Code of Good Administrative Behaviour deadline of fifteen working days closed on 6 May 2026.
European Public Prosecutor's Office
Acknowledged · PENDING
“Your request will be treated in accordance with the Decision of the College of the EPPO of 7 April 2021 on the Code of Good Administrative Behaviour.”
EPPO was asked how its mandatory competence framework and “sufficient elements” threshold operate where the structural funding record is incomplete, fragmented or not publicly traceable.
Transparency
Stop weaponising transparency. Use it. Prove it. Live it.
Transparency has become a political instrument: deployed selectively, framed as hostility, dismissed as an attack on European values. Transparency is the mechanism by which public institutions demonstrate that the money they manage is going where they said it would go. That is not a political position, it is the foundational condition of institutional legitimacy.
Also, there is a contradiction at the heart of EU civil society that this investigation makes visible. Organisations that claim the moral authority of the public interest, that advocate, advise, shape policy, and speak near power, invoke commercial privacy when asked to account for public money, workforce structures, and the payout flows behind those grants.
Civil society is conduct, not a legal form. It is openness, accountability, and the willingness to be verified. The best organisations should welcome that standard, and want clear evidence that public money paid for public-interest work, not private enrichment dressed as virtue.
The EU’s financial architecture – the Treaties, the Financial Regulation, the Grant Agreement – was built on one assumption: that the public chain of money could be traced. This investigation tests that assumption for one member state, using only the instruments the system already provides. The results are on this page.
EU Money Monitor does not allege, does not speculate, does not extrapolate beyond what the public record shows. This is the only standard under which the findings cannot be dismissed. And none of them has been.
An OLAF that can publicly demonstrate its investigative function is proportionate to fraud signals – with a published denominator, consistently applied – is a stronger institution than one whose annual report has been missing that denominator for six consecutive years. Questions do not weaken institutions. Unanswered questions do.
01
Publication is not verification
The EU publishes grant data. Publishing some data is not the same as making it transparent, nor verifiable. Verification requires connecting that data to legal identity, employer records, and public accounts, at entity level. No EU institution had done this. This investigation did.
02
Transparency is not an attack
Findings here concern the architecture of oversight, not the conduct of any organisation. Every named entity may be operating in full compliance with applicable law. The question is whether the public record makes that verifiable to the citizens who funded it.
03
A stronger EU starts here
We must stop pretending the EU is already perfect if we want to make it better. An EU that can show citizens the full funding chain – who received the money, what they did with it, and how the oversight system verified it – is a more credible Union than one that cannot.
Traceability
The questions citizens are entitled to ask. And institutions must answer.
Every organisation that receives EU grants receives public money — collected from European citizens under a legal promise that it would be managed transparently. These are not investigative questions. They are the questions any citizen is entitled to ask, and that any EU funded entity or institution responsible for public funds should be able to answer.
Who received the money, legally?
Not a name string. A registered legal entity: VAT number, legal form, address, active or ceased. The basic identity check the published grant record often skips.
Does the organisation employ people?
EU grants pay for work. Someone delivers it. A public employer register exists for Belgium. Is this organisation on it — and with how many declared staff?
How is the workforce actually paid?
Declared employees and contractors hired through service companies are both legal. Only one appears in public records. The other is a single line in the accounts, indistinguishable from rent.
How much EU funding does each declared employee carry?
There are only so many hours in a working year. How much public money is each registered person responsible for delivering, and at what point does that number stop being plausible?
How many grants run at the same time?
Organisations hold multiple EU grants simultaneously, from different programmes, managed by different agencies. Nobody totals the workload. Does the declared workforce match the parallel commitments?
What do their public accounts show?
If public money went in, what does the financial record show coming out? Revenue, costs, payroll, result. The floor of what any funder would expect to see.
The Case | five arguments
Five arguments the evidence makes
and no institution has answered.
These are not findings from the Belgian dataset. They are structural arguments about how the EU’s accountability architecture was designed, where it breaks, and what that means for the institutions responsible for it.
01
The funding followed the institutions.
The accountability did not.
Belgium is the second-largest recipient of EU NGO grants in the Union — €7.89 billion over a decade, ahead of France, Spain, the Netherlands, and Italy, despite being smaller in population than any of them. Brussels hosts every EU institution. The funding concentration followed that geography. The accountability architecture that should have accompanied it was never calibrated to it. That gap is structural and documented. It is not a criticism of any organisation. It is a statement about institutional design that the data makes unavoidable.
FTS EU-27 NGO/NFPO pivot · Downloaded 05/03/2026 · Belgium rank 2 of 27 by EU NGO funding · rank 8 of 27 by population
02
"No evidence of wrongdoing" is not exoneration, it is the audit architecture.
In 2025, a coalition of 30 NGO umbrella organisations, led by Transparency International EU, formally boycotted the European Parliament’s NGO Scrutiny Working Group. Their stated position: there is “no evidence of any corruption, misconduct, or wrongdoing.” Fifteen days after their November letter, EPPO searched the College of Europe in Bruges, a Belgian EU-funded entity, and charged three individuals with procurement fraud, corruption, conflict of interest, and violation of professional secrecy. “No evidence” is not exoneration, it is a description of a system never designed to detect wrongdoing.
TI EU / CSO coalition letters 28 April 2025 and 17 November 2025 · FOIA EASE 2025/5328 · FOIA EASE 2025/6050 · OLAF Annual Reports 2019–2024
03
Parliament demanded this dataset in 2020. The Commission committed to build it by 2029. It already exists.
EP Resolution 2020/2126 (points 45, 57–59) demanded a unified, harmonised database for EU NGO funding — cross-programme, cross-DG, entity-level. The Commission committed by 2029. The Belgium pilot demonstrates that four existing official public registries, connected for the first time, already contain that data. The data already exists. The technology was not required. Only the cross-reference was missing.
EP Resolution 2020/2126 points 45, 57–59 · FTS × CBE × ONSS × NBB cross-reference · Belgium pilot completed March 2026
04
Accountability begins abruptly at exactly the threshold Belgian law marks, and nowhere before it.
When employer registration and financial filing data are mapped simultaneously across all 758 entities, accountability does not deteriorate gradually as organisations get smaller. It collapses at a single point. In the bands covering zero to four declared employees, 67–71% of entities file no accounts. Above 50 employees, 77–100% file completely. The crossover appears precisely at ONSS Band 4: 20 to 49 employees, where Belgian law’s mandatory complete-filing thresholds begin to bind. A single change to the standard EU grant agreement template, requiring any beneficiary receiving more than €2 million to publish independently verified accounts, would close this gap without amending a single line of Belgian law.
Dataset × ONSS × NBB · Accountability Inversion · Belgian CSA/WVV Law 23 March 2019 · Royal Decree 25 May 2024
05
The 77-to-1 ratio is built from OLAF's own data. If OLAF disputes it, OLAF disputes its own annual reports.
The OLAF Fraud Index — concluded investigations per €1 billion of EU funding received — is not an external analysis. It is OLAF’s own published data on concluded investigations, divided by the Commission’s own Financial Transparency System data on funding received, applied to every EU member state. Romania: 9.84. Hungary: 12.07. Bulgaria: 12.75. Belgium: 0.13. Luxembourg: 0.00. The 77-to-1 ratio between Belgium and Romania is the mathematical consequence of the Union’s own published records. Any institution wishing to contest it must first identify which of its own figures is incorrect. No institution has done so.
OLAF Annual Reports 2014–2023 · EU Financial Transparency System · FOIA OCM(2026)15968 · Methodology published at money-monitor.eu
Transparency is not what auditors can access. It is what the public can verify.
These five arguments are documented, sourced, and reproducible. Each derives from public records, institutional correspondence, or the EU’s own published data. If you work in EU budget oversight, parliamentary scrutiny, investigative journalism, or academic research and want to explore what they mean for your work — the conversation is open.
The case | The Belgium Pilot
One year. Four registries.
No institutional access.
This is what it produced.
The Belgium investigation generated a body of analytical work that is fully sourced, citable, and reproducible from public records. No claim requires access beyond four official public portals that are free and open to anyone.
Full analytical dataset · PDF + Excel
Belgium NGO Funding Intelligence Pack
The complete analytical output of the Belgium pilot. 758 verified entities. 29 data columns. 14 analytical charts. The only cross-registry NGO funding dataset that exists for any EU member state. Sourced, citable, and built for professional use — by audit firms, parliamentary staff, newsrooms, and academic researchers.
758 entities · 4 official registries · 2014–2024
WATCHLIST: 31 high-risk entities
FOIA documentation pack included
Citable with attribution
Briefings · Sessions · Speaking
Applied
Investigation
The outside-in methodology, brought to your specific context. For a parliamentary committee: what the public record shows about your member state’s NGO funding chain. For a newsroom: how to apply the cross-registry approach to your investigation. For a conference: the findings and their institutional implications, made accessible to any audience. This is the full analysis applied to your question.
Parliamentary committees & DG staff
Investigative newsrooms
Audit & compliance professionals
Academic & policy institutions
Belgium is Volume I
Country Intelligence
EU-27
The same four-registry cross-referencing methodology applies to every EU member state. €54.45 billion in total EU grants to non-profits across the EU-27. Belgium proves the method works. Each country is a new volume — produced to the same standard, with the same verifiable public-record basis, citable and ready for institutional or editorial use.
Germany · €12.32bn · planned
France · €5.54bn · planned
Netherlands · €4.91bn · planned
Commissioned on request
ABOUT
Anca Păduraru
I am Romanian. I moved to Brussels in 2018 because I believe the EU is something worth understanding, defending, and improving. For six years I worked inside EU-funded organisations here. I know how these projects operate from the inside, and I know what the oversight system is not built to see.
“I believe we must stop pretending the EU is already perfect if we want to make it better. I am neither left nor right. My only argument: you wrote the rules to protect EU citizens. Now live by them.”
In 2024 I found a table that OLAF had quietly stopped publishing, the one showing which EU member states generated the most fraud suspicions. Belgium was first. I filed a FOIA request; OLAF said the documents did not exist. I escalated to the OLAF Supervisory Committee and the European Parliament. Under a new Director-General, the data appeared two days later: 975 fraud signals attributed to Belgium between 2019 and 2024, 36.1% of all EU fraud suspicions received across the entire Union. Against that: six concluded investigations.
The 77-to-1 ratio between Belgium and Romania in concluded investigations per billion euros of EU funding received is built entirely from OLAF’s own published figures. No EU institution has explained it.
That discovery sits inside a larger investigation: €7.89 billion in EU grants to Belgian NGOs, cross-referenced for the first time across four official public registries. 758 verified entities, built without institutional access or public funding, four public websites and one year of work. Five EU institutions formally notified. None has disputed a single figure.
I built EU Money Monitor alone, from my kitchen table in Brussels because transparency is not what auditors can access, it is what the public can verify. An EU that can show citizens the full funding chain is a more credible Union than one that cannot. That distinction is the only argument this investigation makes. It is also the one no institution has managed to answer.
Power fearless independent journalism
Keep institutions honest: your support means more pressure on those who think they’re untouchable, more investigations, more evidence.