Gong: Ethical Rules for EU Officials Need to be Improved

In order for the European Union to increase citizens’ trust and reduce the risk of corruption, a deeper institutional reform of the existing framework is necessary. The current system is marked by fragmentation, weak oversight and a lack of real sanctions, which means transparency often remains merely formal, while in practice there are no mechanisms for monitoring and sanctioning. 

In recent years, the European Union has faced serious questions related to transparency, conflicts of interest and the political integrity of its institutions and officials. Particularly following the Qatargate Affair, it has become clear that the existing institutional framework is not strong enough to prevent corruption, covert lobbying and the abuse of political influence. 

Although the EU formally possesses a number of mechanisms for safeguarding integrity, including the transparency register, asset declarations and cooling-off rules, their effectiveness remains limited due to fragmentation, inconsistent standards and weak enforcement and sanctioning mechanisms. 

The ethical framework for protecting the integrity of the European Union currently fails to adequately respond to the challenges of conflicts of interest, corporate influence and the revolving-door phenomenon. Although formal mechanisms exist, their fragmentation and weak enforcement limit their real impact. 

Without stronger monitoring, unified rules and independent enforcement of monitoring the conduct of officials, the risk of further reputational crises and citizens' growing distrust toward the European Union will remain high. Reforming the integrity framework is therefore not merely a matter of administrative efficiency, but also a matter of the European Union’s democratic legitimacy. 

Due to this, Gong has prepared an overview of the existing ethical rules for officials of EU institutions, together with recommendations that would help improve the institutional framework governing integrity issues for European Union officials. 

Recommendations for the Improvement of the Ethical Framework for Officials of EU institutions: 

1. Strengthen the newly established European ethics body

The new Interinstitutional Body for Ethical Standards for members of EU institutions and advisory bodies, established in 2023, should be given real investigative and sanctioning powers, rather than merely remaining a coordination mechanism among institutions. The body should:

• have institutional independence from the European Commission and Parliament
• carry out checks on asset declarations and conflicts of interest
• have the ability to launch investigations on its own initiative
• impose sanctions for rule violations
• publish annual reports and oversight results.

Without a mechanism for monitoring, enforcement and sanctioning impermissible conduct, the ethical framework remains merely declarative and dependent on the political will of the very institutions it is meant to oversee.

2. Standardize the rules for all categories of EU officials

A unified integrity-protection regime needs to be established for all senior officials of the European Union, including:

• European Commissioners
• members of the European Parliament
• high-ranking Commission officials
• members of the Council of the EU
• special advisors and senior administrative officials

Different rules for different institutions create legal loopholes and inconsistent standards of accountability. Integrity requirements should be tied to the level of political influence, rather than to institutional affiliation.

3. Strengthen the asset declaration system

The existing system for declaring assets needs to be made more detailed and binding for all senior officials of the European Union. This includes: 

• mandatory reporting of the exact value of assets
• reporting of assets belonging to partners and immediate family members
• more detailed declaration of financial interests, shares, and advisory engagements
• regular audits and random checks
• stricter sanctions for false or incomplete declarations

In doing so, the European Union could look to certain models used by member states, including Croatia, where some aspects of asset declaration are stricter than at the European level.

4. Extend and tighten revolving-door and cooling-off rules 

The revolving-door phenomenon represent the biggest reputational problem for European institutions and requires the strictest regulation. It is necessary to: 

• extend cooling-off periods for former Commissioners and senior officials beyond the current two years for Commissioners and six months for Members of the European Parliament
• prohibit moves into sectors connected to their previous regulatory responsibilities
• include informal advising and strategic consultancy activities in the definition of lobbying
• introduce an obligation to transparently disclose all post-employment activities following work in EU institutions
• establish independent oversight of former officials

Cases such as that of José Manuel Barroso have shown that formal compliance with the rules is not enough if the public still perceives the existence of conflicts of interest and political trading in influence. 

5. Increase the transparency of lobbying 

It is necessary to transform the Transparency register into a fully mandatory system for all EU institutions. In addition, it should: 

• publish all meetings between senior officials and lobbyists
• include think tanks, consultancy firms, and law offices
• increase the financial transparency of lobbying organizations
• provide easier access to data for the public and investigative journalists
• tighten penalties for officials who fail to report meetings, moving beyond the current mild disciplinary and political sanctions listed in their institutions' codes of conduct

6. Strengthen the democratic and media monitoring of European officials 

European institutions often operate outside the intense public scrutiny to which national governments are exposed. Due to this, it is necessary to: 

• increase the availability of data and documents
• strengthen the role of European investigative media
• enable greater civil society participation in overseeing ethical standards
• develop stronger European political accountability toward citizens

The full text of the analysis and recommendations is available below or via this link.