Access to Documents Request – EU Funding for Electronic Border Barrier Poland
Dear Migration and Home Affairs,
Under the right of access to documents in the EU treaties, as developed in Regulation 1049/2001, I am requesting documents which contain the following information:
All documents held by DG HOME that relate to the funding of any part of the electronic barrier infrastructure on the Polish-Belarusian border, including but not limited to:
Applications for EU funding submitted by Poland;
Internal assessments, evaluations, or correspondence concerning those applications;
Grant agreements, contracts, or decisions approving funding;
Progress reports, monitoring documents, or final reports submitted by the beneficiaries;
Documents relating to the technical components funded, including surveillance systems, sensors, cameras, communication networks, or other digital infrastructure;
Any exchanges between DG HOME and national authorities on this topic.
Please include documents from January 2016 to the present.
Yours faithfully, Peter Teunissen
Dear Sir or Madam,
We are writing to you concerning your request for access to documents sent
on 29/05/2025 and registered on 02/06/2025 under case number 2025/2924.
Since you have not indicated your postal address, we are not able to start
handling your request. The 15 working days to reply to your request will
start running only when you send us your postal address.
You can send your postal address by replying to this e-mail. If we do not
receive your reply we may close this case.
Please note that you can submit a request for access to Commission
documents via the portal [1]'Request a Commission document', which does
not require you to indicate your postal address.
Why do we need your personal postal address?
Since 1 April 2014, the submission of a postal address became a mandatory
feature when submitting an application for access to Commission documents
via an e-mail. We would like to explain why we need your postal address in
order to register and handle your application for access to documents when
submitted via e-mail:
• Firstly, to obtain legal certainty as regards the date you received
the European Commission reply to your application for public access to
documents. Article 297 of the Treaty on the Functioning of the
European Union (TFEU) states that 'decisions which specify to whom
they are addressed, shall be notified to those to whom they are
addressed and shall take effect upon such notification.' In line with
this provision, if the Commission does not grant full access to the
requested documents, it notifies the reply to the applicant via
registered mail with acknowledgement of receipt or via delivery
service. This requires an indication of a valid postal address by the
applicant;
• Secondly, to apply correctly the [2]Data Protection Regulation (EU)
2018/1725. Knowing whether the applicant is an EU resident (or not) is
necessary for deciding which conditions shall apply for the
transmissions of personal data to applicants for access to documents.
These conditions are not the same for recipients established in the
Union and for recipients in third countries. As the vast majority of
the documents requested contain personal data, the Commission cannot
ensure the correct application of the data protection rules in the
absence of a postal address;
• Thirdly, to apply correctly [3]Regulation (EC) No 1049/2001. Article
4(1)(b) of that Regulation refers to the protection of the privacy and
integrity of the individual and has to be applied in line with the
Data Protection Regulation;
• Fourthly, to protect the interest of other citizens and safeguard the
principle of good administration. The Commission has to treat all
citizens equally by ensuring that the legal framework for public
access to documents is respected. For example, it has to verify
whether Article 6(3) of Regulation (EC) No 1049/2001 is being evaded
by introducing several requests under different identities. Indeed, in
its Ryanair judgment ([4]EU:T:2010:511), the General Court confirmed
that Article 6(3) of Regulation (EC) No 1049/2001 cannot be evaded by
splitting an application into several, seemingly separate, parts. In
addition, the Commission has to make sure that the legal framework is
respected and the right of access to documents is not abused by making
requests under an invented identity.
The considerations above show that the request for and the consequent
processing of the applicant's postal address is not only appropriate, but
also strictly necessary for the performance of a task carried out in the
public interest within the meaning of Article 5(1)(a) of Data Protection
Regulation, namely providing a smooth and effective access to documents.
Yours faithfully,
Directorate-General for Migration and Home Affairs - Access to Documents
European Commission
References
Visible links
1. https://www.ec.europa.eu/transparency/do...
2. https://eur-lex.europa.eu/legal-content/...
3. https://eur-lex.europa.eu/legal-content/...
4. https://eur-lex.europa.eu/legal-content/...
Dear Sir,
As we did not reply to our request (ref [1]Ares(2025)4390942 of 2/06/2025)
to provide your postal address, we will proceed to the closure of your
request.
Best regards,
HOME Access to documents team
References
Visible links
1. https://webgate.ec.testa.eu/Ares/documen...
Dear Sir or Madam,
We hereby acknowledge the receipt of your request for access to documents
sent on 29/05/2025 and registered on 02/06/2025 under the case number
2025/2924.
We will handle your request within 15 working days as of the date of
registration. The time-limit expires on 22/07/2025. We will let you know
if we need to extend this time limit for additional 15 working days.
To find more information on how we process your personal data, please see
[1]the privacy statement.
Yours faithfully,
Directorate-General for Migration and Home Affairs - Access to Documents
European Commission
References
Visible links
1. https://ec.europa.eu/info/principles-and...
Hello,
Please find attached a message concerning your request for access to
Commission documents registered under the above case number 2025/2924.
Please acknowledge the receipt of this message by return email.
Kind regards,
Dear Migration and Home Affairs,
Please pass this on to the person who reviews confirmatory applications. I am hereby submitting a confirmatory application under Article 7(2) of Regulation (EC) No 1049/2001 concerning my access to documents request entitled “Access to Documents Request – EU Funding for Electronic Border Barrier Poland.”
This confirmatory application challenges the initial decision refusing access to the following documents: 3.3, 3.4, 3.5, 3.7, and 3.8, as well as the heavily redacted document “4 Assessment Report BMVI 1.4.2.”
In the initial decision, the Commission stated that these documents contain commercially sensitive information of the Member States that submitted them, including methodologies, internal organisation, strategies, price breakdowns, and other proprietary details with competitive value. It also cited potential implications for public security, arguing that disclosure could reveal vulnerabilities at the EU’s external borders and the types of equipment and systems used for border management.
However, I respectfully submit that:
The reasoning provided does not sufficiently justify a refusal of access under Article 4(2) or Article 4(1)(a) of Regulation (EC) No 1049/2001. The Commission’s decision relies on broad and general statements about potential harm, without demonstrating how disclosure of specific information would concretely and reasonably undermine commercial or public security interests.
There is an overriding public interest in transparency regarding EU funding for border infrastructure and surveillance systems, particularly in relation to human rights compliance, public spending accountability, and adherence to EU legal standards. Full or greater access to these documents would serve this public interest.
The refusal of even partial access is disproportionate. The decision asserts that no meaningful partial access can be granted without undermining protected interests, yet the Commission has not demonstrated that targeted redactions could not adequately protect sensitive information while allowing public scrutiny of non-sensitive elements.
The “4 Assessment Report BMVI 1.4.2” has been excessively redacted, to the point where its substance and evaluative content are effectively inaccessible. Excessive redactions frustrate the purpose of Regulation 1049/2001 and should be reconsidered in favour of a more proportionate approach.
The budget sections of the released documents are entirely empty, which is inconsistent with the principles of transparency and accountability concerning the use of EU funds. Even aggregate or high-level budgetary data could and should be disclosed without infringing commercial or security interests.
For these reasons, I respectfully request that the European Commission review its initial decision and grant full or at least greater partial access to the requested documents, in accordance with Regulation (EC) No 1049/2001 and the principle of the widest possible access to documents.
Sincerely Peter Teunissen
A full history of my request and all correspondence is available on the Internet at this address: https://www.asktheeu.org/request/access_...
Dear Sir or Madam,
We hereby acknowledge the receipt of your confirmatory request for case
2025/2924, sent on 10/11/2025 and registered on 10/11/2025.
We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 01/12/2025. We will let
you know if we need to extend this time limit for additional 15 working
days.
Yours faithfully,
Secretariat-General - Access to Documents
European Commission
Dear Mr Teunissen,
We are writing concerning your confirmatory request for access to
Commission documents for case EASE 2025/2924, registered on 10 November
2025.
We are currently working on your confirmatory request. However, the
necessary services consultations, including with the Legal Service of the
European Commission, are still ongoing at the moment. We will thus not be
able to send you the reply within the prescribed time limit expiring
today.
Therefore, in line with Article 8(2) of Regulation (EC) No 1049/2001, we
need to extend this time limit by 15 additional working days. The new time
limit expires on 22 December 2025.
We apologise for any inconvenience this may cause.
Kind regards,
SG.A.2 Access to Documents Team
Dear TEUNISSEN , Peter ,
Please find attached the electronic version of European Commission
Decision C(2026) 798 as adopted by the European Commission on 03/02/2026
concerning the request 2025/2924.
In accordance with the Terms and Conditions of this portal, please note
that this decision is being formally notified pursuant to article 297 TFEU
through this electronic platform only.
Yours sincerely,
Access to docuemnts team - SG.A.2