On 12 November, the European Commission adopted the first-ever EU Strategy for Civil Society, marking the end of a process that ECNL has closely followed and actively shaped. This is a symbolic moment, positioning civil society as "at the core of our democracies". The real test lies ahead: how will these commitments translate into meaningful implementation? In this blog, we outline some pathways and offer our comparative expertise to support this process.
A timely framing – but exposing a geopolitical blind spot
At a time of attacks and repressions on activists, civil society and dissent globally, the Strategy sends a crucial signal by recognising a priority of cooperation with and enabling environment for civil society organisations (CSOs) throughout the EU and its enlargement countries. This reflects ECNL's position that the EU has both a responsibility and an opportunity to reclaim normative leadership by embedding human rights, rule of law, civic space and democratic resilience at the core of its strategies.
However, the Strategy lacks broader geopolitical framing that today's moment demands and should strive to not merely protect what exists but actively rebuild a democratic infrastructure and present a vision of society which is participatory, rights-based, pluralist and just. This can be achieved by fostering a more coherent approach as the EU adopts policies that also affect civil society.
Dialogue mechanisms: with or without teeth?
The establishment of a Civil Society Platform and annual summits represents a step toward institutionalised civil dialogue. The Platform promises "a regular and structured framework" for engagement with CSOs working on democracy, rule of law, equality and fundamental rights. The Strategy also commits to facilitating dialogue between donors and CSOs to identify funding gaps and ensure complementarity.
Yet, architecture alone doesn't guarantee impact. The Platform's success hinges on operational and governance details that remain vague and are to be defined in the upcoming months. What will be the role of CSOs in setting up the Platform and how will this framework function in practice? Is it merely a systematisation of existing participatory mechanisms or will it create genuinely inclusive channels for participation? What capacity will be dedicated to managing it? Will there be dedicated contact points on civil society across all EU institutions and agencies to ensure a meaningful power-sharing mechanism? Most critically, what impact will Platform decisions and input actually have on EU policy?
Monitoring infrastructure – where is the action?
The Strategy recognises that effective monitoring is essential for supporting and protecting CSOs. It commits to creating an online knowledge hub in cooperation with the Fundamental Rights Agency (FRA), strengthening early warning systems in enlargement countries and continuing the rule of law monitoring.
The proposed knowledge hub must be carefully designed. With existing and robust CSO-led monitoring tools, FRA should build on and amplify the work of these tools already carrying out civic space monitoring with EU financial support, such as MACS, providing systematic evidence and guidance on civic space within the EU or the CSO Meter, assessing civil society environment in the Eastern Partnership region. The added value of their documentation and methodologies must be integrated, not replaced. Co-development and co-management models, similar to the Council of Europe's Platform for the Safety of Journalists with its "trusted flagger" approach, could ensure the hub remains responsive to civil society needs. More importantly, particular attention must be paid to the link between the monitoring outputs and EU-level responses to the restrictions identified.
How will principles translate to practice?
The 10 guiding principles for participation included in the Strategy set an important framework, but without accountability mechanisms remain aspirational. How will the Commission ensure that comprehensiveness "throughout policymaking stages" actually happens? What recourse do CSOs have when engagement is superficial or tokenistic? The institutionalisation of in-country consultation of CSOs in association agreement processes is a positive step for non-EU accession countries, but similar standardisation and binding internal procedures are needed across all institutions and policy areas. It would send a clear political signal if the European Parliament and Council also commited to adhering to the guiding principles and related procedures. It should apply to ongoing initiatives, such as the omnibus proposals that risk hard-won protections without meaningful consultation.
The security paradox
Indicative to the geopolitical blind spot identified above, the Strategy is silent on how the EU's own security architecture constrains civic space. Counter-terrorism measures, anti-money laundering regulations and other security-driven policies have long-standing and well documented negative impacts on CSOs, from financial exclusion to surveillance. The Strategy mentions some regulations affecting CSOs briefly in the context of preventing denial of financial services, but fails to address the broader systemic challenges. This is not an abstract concern: it affects CSOs' ability to operate, access funding, and support human rights defenders daily. Therefore, it is important to recognise and address this: not only during the implementation of the Strategy, but also during the development and implementation of other regulatory frameworks and policy documents, such as the new EU AML/CTF Package.
Digital threats in the shadows
The Strategy is also remarkably silent on extensively documented digital threats to civic space and activists. Emerging technologies and AI are increasingly used for surveillance and monitoring of CSOs without adequate safeguards, disproportionately affecting protesters and human rights defenders. The intersection of technology and civic space restrictions deserves explicit attention during the implementation of the Strategy.
Incomplete protection for human rights defenders
While the Strategy acknowledges transnational repression (TNR) and mentions visa guidance for human rights defenders, it lacks comprehensive mechanisms for cross-border protection of human rights defenders (HRDs) within the EU. There is no clear coordinated approach at the EU level and between Member States on addressing cases of transnational repression of HRDs from third countries residing in the EU, either. Notably, the Strategy suggests that monitoring by EU SEE addresses TNR, but without explaining how it addresses TNR enabled within EU Member States themselves. Moreover, systematic approaches to administrative obstacles HRDs face, including access to financial services should be included as well.
A path forward: commitments to implementation
At a time of global democratic backsliding and authoritarian resurgence, the EU needs to define not just which civic infrastructure it wants to support, but what kind of democratic and civic resilience it wants to foster as a counterweight to these trends. What is needed now is a clear action with specific deadlines and responsibilities to transform the Strategy commitments from paper into practice. ECNL remains committed to supporting this process through our comparative expertise. Three priorities should guide the next phase:
- Develop the Civil Society Platform with civil society, creating a tool that is user-friendly, integrates lessons learned, and is genuinely responsive to people's needs. We are happy to share diverse resources to build upon, including our work on new dimensions for public participation and AI for public participation. If the Commission uses AI tools on the Platform, we recommend leveraging ECNL's Framework for Meaningful Engagement (FME 2.0) and the Blueprint for rights-centered AI in public participation, with concrete recommendations for designing AI tools that strengthen rather than undermine public trust in democratic processes.
- Move from protective to transformative actions, grounding implementation in a bold vision of participatory, rights-based, pluralist democracy, not just defending what exists. We encourage extending the early warning approach beyond enlargement countries to EU Member States themselves, consistent with the Strategy's preventive model. Additionally, expert support in designing the knowledge hub is needed that truly facilitates access to existing monitoring and ensures complementarity with ongoing efforts.
- Address the security and digital civic space nexus explicitly, through proposed mechanisms, acknowledging how EU policies themselves sometimes constrain the very space they claim to protect. Policies should be coherent, and the EU must ensure its security architecture does not repeat the post-9/11 errors of marginalising human rights but rather engages civil society as a key actor to safeguard human security, resilience and democratic integrity.
The coming months and years will be crucial to ensure the proposed Strategy implements genuine political will to strengthen civil society and its spaces for action. At times of increased attacks on civic actions and space, half-measures simply will not do.
ECNL will continue monitoring the Strategy's implementation and offer our expertise to ensure its commitments become a reality. We invite diverse partners and communities affected to join this effort.