Request for access to documents related to EU funding and financial transfers to Ukraine (2022–2025)
Dear Budget,
I am a journalist working for an independent news platform in the Netherlands, NieuwRechts. In this capacity, I would like to submit a request for access to documents under Regulation (EC) No 1049/2001 regarding public access to European Parliament, Council and Commission documents.
I kindly request access to:
1. A complete list of EU financial transfers, grants, loans, and guarantees issued to Ukraine or Ukrainian entities since 1 January 2022, including but not limited to:
• Funds disbursed via the European Peace Facility
• Humanitarian and civil support programmes
• Reconstruction and infrastructure programmes
• Funds from the EU Ukraine Facility (€50 billion), including signed contracts and recipients
• Military and dual-use equipment funding
2. All documents detailing:
• The conditions and oversight mechanisms attached to such transfers
• Involvement of intermediary institutions (e.g. EIB, EBRD, national agencies)
• Beneficiaries at state, regional or local level (e.g. ministries, municipalities, NGOs, contractors)
3. Any internal audits, impact assessments, or risk reports related to:
• The disbursement of EU funds to Ukraine since 2022
• Measures taken to prevent misuse, corruption or fraud
If certain parts of the requested documents are confidential, I am willing to accept partial access or redacted versions, in accordance with Article 4(6) of Regulation 1049/2001.
I kindly request a response within the statutory time limit.
Thank you for your assistance.
Yours sincerely,
Marit Nubé
Journalist – NieuwRechts
Dear Sir or Madam,
We are writing to you concerning your request for access to documents sent
on 11/04/2025 and registered on 11/04/2025 under case number 2025/2063.
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 Budget - 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 Budget,
Thank you for your message. My postal address is as follows:
[Name] Cvandaag
[Street] Arthur van Schendelstraat 650
[ZIP Code] 3511 MJ Utrecht
Yours faithfully,
Marit Nubé
Dear Sir or Madam,
We hereby acknowledge the receipt of your request for access to documents
sent on 11/04/2025 and registered on 15/04/2025 under the case number
2025/2063.
We will handle your request within 15 working days as of the date of
registration. The time-limit expires on 13/05/2025. 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 Budget - 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 2025/2063.
Please acknowledge the receipt of this message by return email.
Kind regards,
Hello,
Please find attached a message concerning your request for access to
Commission documents registered under the above case number 2025/2063.
Please acknowledge the receipt of this message by return email.
Kind regards,
Hello,
Please find attached a message concerning your request for access to
Commission documents registered under the above case number 2025/2224.
Kind regards,
DG ENEST ACCDOC Team
Hello,
We are writing concerning your request for access to Commission documents
registered on 23/04/2025 under case number 2025/2223.
We are currently working on your request. However, we have not yet been
able to gather all the elements necessary to carry out a full analysis of
your request. We will not be able to send you the reply within the
prescribed time limit expiring on 13/05/2025.
In order to retrieve the documents requested, large files have to be
examined
Therefore, in line with Article 7(3) of [1]Regulation (EC) No 1049/2001,
we need to extend this time limit by 15 additional working days. The new
time limit expires on 04/06/2025.
We apologise for any inconvenience this may cause.
Kind regards,
European Commission
Service for Foreign Policy Instruments (FPI)
Access to Documents
References
Visible links
1. https://eur-lex.europa.eu/legal-content/...
Hello,
We are writing concerning your request for access to Commission documents
registered on 11 April 2025 under case number EASE 2025/2063. The case was
split and attributed to DG ENEST under case number EASE 2025/2063 on 23
April 2025.
We are currently working on your request. However, we have not yet been
able to gather all the elements necessary to carry out a full analysis of
your request. We will not be able to send you the reply within the
prescribed time limit expiring on 13 May 2025, due to internal
consultations.
Therefore, in line with Article 7(3) of [1]Regulation (EC) No 1049/2001,
we need to extend this time limit by 15 additional working days. The new
time limit expires on 4 June 2025.
We apologise for any inconvenience this may cause.
Kind regards,
DG ENEST ACCDOC Team
References
Visible links
1. https://eur-lex.europa.eu/legal-content/...
Dear Ms NUBE,
We are writing concerning your request for access to Commission documents
registered on 15 April 2025 under case number 2025/2501.
We are currently working on your request. However, we have not yet been
able to gather all the elements necessary to carry out a full analysis of
your request. We will not be able to send you the reply within the
prescribed time limit expiring on 13 May 2025.
The application concerns documents held by different Services, which have
been consulted.
Therefore, in line with Article 7(3) of [1]Regulation (EC) No 1049/2001,
we need to extend this time limit by 15 additional working days. The new
time limit expires on 4 June 2025.
We apologise for any inconvenience this may cause.
Kind regards,
DG ECFIN D2
References
Visible links
1. https://eur-lex.europa.eu/legal-content/...
Hello,
We are writing concerning your request for access to Commission documents
registered on 11 April 2025 under case number EASE 2025/2063.
Your request has been split and attributed to different Commission
services. The Directorate-General for Enlargement and the Eastern
Neighbourhood (DG ENEST) was attributed the split case under case number
EASE 2025/2224 on 23 April 2025.
We would like to kindly remind you to reply to the clarification request
sent on 13 May 2025.
If you do not reply within 7 working days of receiving the clarification
request, we will close this case in line with our detailed rules for the
application of Regulation (EC) No 1049/2001.
Kind regards,
DG ENEST ACCDOC Team
Hello,
We are writing concerning your request for access to Commission documents
registered on 11 April 2025 under case number EASE 2025/2223.
Your request has been split and attributed to different Commission
services. The Service for Foreign Policy Instruments (FPI) was attributed
the split case under case number EASE 2025/2223 on 23 April 2025. After an
assessment of your request, we consider that the following area may be
within the scope of FPI (please see point below):
1. A complete list of EU financial transfers, grants, loans, and
guarantees issued to Ukraine or Ukrainian entities since 1 January 2022,
including but not limited to:
• Funds disbursed via the European Peace Facility
As per the formulation of the question, FPI does not hold this kind of
documents as the funds via EPF are not issued directly to Ukraine or
Ukrainian entities.
Therefore, in line with Article 6(2) of Regulation (EC) No 1049/20011
regarding public access to documents, we invite you to send us more
detailed information on the documents you request which may be held by
FPI.
The 15 working days to reply to your request will start running only when
you reply to this message. If you do not reply within 7 working days, we
will close this case in line with our detailed rules for the application
of Regulation (EC) No 1049/2001.
Kind regards,
FPI ACCDOC Team
Hello,
We are writing concerning your request for access to Commission documents
registered under case number EASE 2025/2224.
We would like to once more kindly remind you to reply to the clarification
request sent on 13 May 2025.
We invite you to reply no later than 23 May 2025. If no response is
recieved, this case will be closed in line with our detailed rules for the
application of Regulation (EC) No 1049/2001.
Kind regards,
DG ENEST ACCDOC Team
Hello,
We are writing concerning your request for access to Commission documents
registered on 23 April 2025 under case number EASE 2025/2224, which is
handled by DG ENEST.
On 13 May 2025, we asked you to clarify the scope of your request since it
was not clear. We sent reminders on 20 May 2025 and 22 May 2025.
Since you have not replied to our clarification request, we could not
start handling it and we have closed this case.
Kind regards,
DG ENEST ACCDOC Team
Hello,
We are writing concerning your request for access to Commission documents
registered on 11 April 2025 under case number EASE 2025/2223.
Your request has been split and attributed to different Commission
services. The Service for Foreign Policy Instruments (FPI) was attributed
the split case under case number EASE 2025/2223 on 23 April 2025.
We would like to kindly remind you to reply to the clarification request
sent on 21 May 2025.
If you do not reply within 7 working days of receiving the clarification
request, we will close this case in line with our detailed rules for the
application of Regulation (EC) No 1049/2001.
Kind regards,
FPI ATD Team
Dear Ms. Nubé,
We are writing to you concerning your request for access to Commission
documents for case 2025/2501, registered on 15/04/2025.
On 13/05/2025, we extended the time-limit for replying to your request to
04/06/2025.
Unfortunately, we will not be able to send you the reply within this
extended time limit since the reply is still under validation.
However, we assure you that we are doing our best to send a reply to your
request as soon as possible.
We regret this delay and sincerely apologize for any inconvenience this
may cause.
Yours sincerely,
DG ECFIN, D.2
Hello,
We are writing concerning your request for access to Commission documents
registered on 23/04/2025 under case number 2025/2223, handled by FPI.
On 21/05/2025 we asked you to clarify the scope of your request since it
was not clear. We sent a reminder on 28/05/2025.
Since you have not replied to our clarification request, we could not
start handling it and we have closed this case.
Kind regards,
European Commission
Service for Foreign Policy Instruments (FPI)
Access to Documents
Dear Ms Nubé,
Please find attached a message concerning your request for access to
Commission documents registered under the above case number 2025/2501.
Please acknowledge the receipt of this message by return email.
Kind regards,
DG ECFIN, Access to Documents Team