25/03/2026
On 18 March, The European Environmental Bureau (EEB), Europe’s largest network of environmental NGOs, filed a formal complaint with the European Ombudswoman alleging the EU Commission committed maladministration in handling of the proposals for the National and Regional Partnership (NRP) and the Common Agriculture Policy (CAP) for the period 2028 to 2034.
To substantiate its claim, the EEB cites the failure to conduct an adequate impact assessment and therefore demonstrate that decisions were based on the best available evidence. Similarly a climate consistency assessment required by Article 6(4) of the EU Climate Law has not been carried out. Finally, the Commission failed to organise a dedicated public consultation on the CAP.
Environmental NGOs warn that this disregard of the Better Regulation Framework results in concerning lack of due diligence. The lack of assessments and public consultations decreases the transparency of these decisions and their consequences. As a result, neither policymakers, nor citizens have access to information about the impact these legislations will have on farmers, rural communities and the environment.
This is not the first time that the Ombudswoman is asked to examine these claims . Similar complaints have been filed against the Commission in 2024, regarding the handling of the CAP “simplification” and the first Omnibus package. In both cases, the Ombudswoman declared that the Commission committed maladministration. While only advisory in nature, this landmark decision is an important win for NGOs, public watchdogs, expert communities and engaged citizens. It raises concerns about legality of the simplification agenda and its implication for EU democracy.
In her recommendations for the Commission, the Ombudswoman asked it to ensure a predictable, consistent and non-arbitrary application of the Better Regulation rules and that future urgent preparation of legislative proposals is always transparent, evidence-based, and inclusive. She also recommended to carry out climate assessments for all legislative proposals and to clarify minimum standards for stakeholder consultation in urgent procedures.
The Ombudswoman especially criticises how the Commission used a very broad definition of “urgency”, allowing it to bypass its own internal checks. According to Teresa Anjinho, taking these shortcuts has consequences, among others in terms of weakening public trust. She recognises the vital role of impact assessments and public consultations in facilitating participation, which lies at the very core of EU democracy. Failure to conduct any of these elements sets a concerning precedent and deepens the marginalisation of citizens and civil society in policymaking processes.
This case illustrates a broader, emerging pattern where deregulatory agenda and sidelining of civil society become dominant in EU policymaking. The Good Lobby joins the EEB in calling on the Commission to adhere to its own rules to ensure transparent, inclusive, and evidence-based policymaking. In the face of the external and internal challenges faced by the EU, upholding democratic integrity is crucial.