The Complete EU Transparency Guide for NGOs and EU-Funded Organisations

1. The Legal Framework

The foundation of all EU visibility and transparency obligations for the 2021–2027 programming period is the Common Provisions Regulation (EU) 2021/1060 — commonly abbreviated as CPR. This single regulation governs seven major EU structural and investment funds: the European Regional Development Fund (ERDF), the European Social Fund Plus (ESF+), the Cohesion Fund (CF), the Just Transition Fund (JTF), the European Maritime, Fisheries and Aquaculture Fund (EMFAF), the Asylum, Migration and Integration Fund (AMIF), the Internal Security Fund (ISF), and the Border Management and Visa Instrument (BMVI). It also covers Interreg programmes under the European Territorial Cooperation framework.

Within the CPR, three provisions are particularly critical for beneficiary organisations:

Article 47 establishes the Union emblem obligation in a single sentence: all beneficiaries, managing authorities and Member States must use the Union emblem in accordance with Annex IX when carrying out visibility, transparency and communication activities. It is the foundational requirement from which all specific obligations flow.

Article 50 sets out the full responsibilities of beneficiaries in detail — including the requirement to display the correct emblem and written statement on all project-related materials (Article 50(1)(a)), to publish information about the project on websites and social media (Article 50(1)(b)), and to install permanent plaques or billboards above the relevant cost thresholds (Article 50(1)(c)). Article 50(3) is the financial enforcement provision: it specifies the consequence when a beneficiary fails to meet the obligations set by Article 47 and Article 50(1)–(2). This is the source of the "3% rule" discussed later in this guide.

Annex IX of CPR 2021/1060 provides the technical specifications for the Union emblem — font requirements, colour rules, sizing, and placement standards. Articles 47 and 50 establish the legal obligation; Annex IX specifies exactly how to meet it. When auditors and managing authorities assess compliance, both the article requirements and the Annex IX technical specifications form the basis of their check.

It is important to understand who these rules apply to and who they do not. The CPR obligations apply to all beneficiaries receiving support from the seven funds listed above — NGOs, charities, social enterprises, local authorities, universities, private companies, and any other legal entity that receives a grant from these sources. There is no de minimis threshold below which the obligations disappear entirely, though the specific requirements do scale with the total cost of the operation (see the Physical Display Requirements section).

The managing authority for each programme — typically a ministry, regional government, or designated agency in the relevant member state — is responsible for implementing these obligations and ensuring beneficiaries comply with them. They are the counterparty you deal with, and they are the body that applies any financial corrections for non-compliance.

One further distinction worth noting: this guide addresses the 2021–2027 programming period. Organisations still reporting on or being audited for projects from the 2014–2020 programming period are subject to the earlier CPR (EU) 1303/2013 and its Annex XII, which has similar but not identical requirements. If you are managing obligations across both periods, verify which regulation applies to each specific project.

2. The Union Emblem Requirement

Of all the obligations in Annex IX, the Union emblem requirement is the most visible, most frequently checked, and most commonly violated. It applies universally — to every operation, regardless of size, sector, or fund — and there is no flexibility in its application.

The requirement has two inseparable components that must appear together:

First, the Union emblem itself: the circle of twelve gold stars on a blue background. This must be the official version, reproduced according to the European Commission's visual identity guidelines. A stylised, distorted, recoloured or otherwise modified version does not satisfy the requirement. The official emblem files are available from the European Commission's website in multiple formats.

Second, a written statement that must appear immediately next to the emblem — not on a separate page, not in the footer while the emblem is in the header, but genuinely proximate to it. The statement must read either "Funded by the European Union" or "Co-funded by the European Union". These are the only two options. No other formulation satisfies the legal requirement.

"The statement 'Funded by the European Union' or 'Co-funded by the European Union' shall be written in full and placed next to the emblem." — CPR 2021/1060, Annex IX, point 1.2

The emblem must be at least as large as any other logo displayed on the same material. If your organisation's logo appears at 80px height, the Union emblem must appear at no less than 80px height. If your managing authority's logo or a national fund logo also appears, the Union emblem must match or exceed the largest of these. This proportionality rule is frequently violated on co-branded materials where the EU emblem is placed smaller than partner logos.

The scope of where the emblem and statement must appear is broad. Annex IX specifies: all documents and communication materials related to the operation; the project website; social media; press releases; publications; audiovisual materials; events. In practice, this means any output produced as part of or in connection with the funded project must carry the correct branding.

The distinction between "Funded by" and "Co-funded by" reflects the financial reality of your project. If EU funding is the sole public source, "Funded by the European Union" is appropriate. If other public bodies (national government, regional authority, other donors) also contribute to the project's public support, "Co-funded by the European Union" is the more accurate — and technically required — formulation. Check your grant agreement if you are uncertain which applies.

For multilingual organisations or cross-border projects, the statement should appear in the language appropriate to the communication's intended audience. A report published in Irish and English should carry the statement in both languages. A project event held in Slovakia should display the statement in Slovak.

3. Physical Display Requirements

In addition to the universal emblem requirement that applies across all materials and communications, CPR 2021/1060 Article 50(1)(c) establishes specific physical display requirements that depend on the total cost of the operation. These are the plaque and billboard requirements — the rules about what must physically appear at a project's location.

The threshold that determines which requirement applies is the total cost of the operation — the full eligible project budget including the EU contribution, national public co-financing, and the beneficiary's own contribution. This is the basis set out in Article 50(1)(c) of CPR 2021/1060. Check how "total cost" is defined in your specific programme documentation, as programme rules may provide further technical specifications.

The word "durable" in the regulation is deliberate and consequential. A durable plaque is not a printed paper notice in a plastic sleeve, nor a temporary banner. It must be made of materials designed to last the duration of the project and beyond — typically metal, acrylic, ceramic tile, or similar permanent materials. The regulation requires the plaque to remain in place for a "reasonable period" after the project concludes; your grant agreement will specify the exact duration, which is often several years post-completion.

The timing requirement is equally important and often misunderstood: the plaque must be installed once physical implementation begins, not when the project ends. For infrastructure projects, this means when construction commences. For equipment purchases, when the equipment is acquired and in use. Installing a plaque at project closure does not satisfy the requirement — the obligation exists throughout the life of the project.

For projects operating across multiple sites — for example, a community training programme delivered at five venues — the plaque or poster requirement applies at each location where the funded activity takes place. One central display at headquarters does not satisfy the obligation if beneficiaries and members of the public encounter the funded activity at other sites.

4. Communication Obligations

The visibility requirements described in the previous sections form part of a broader set of communication obligations that apply throughout the life of a funded project. It is a common misconception that these obligations are primarily about launch announcements or final reports. In fact, Annex IX makes clear that the obligations apply continuously, from the start of the project to its conclusion and beyond.

The project website — or the dedicated project pages on your organisation's main website — must include: the Union emblem displayed prominently; the written acknowledgment ("Funded by the European Union" or "Co-funded by the European Union"); and a short description of the operation, including its aims, expected results, and highlights of the financial support from the Union. This description does not need to be lengthy, but it must be substantive. A single sentence naming the fund is insufficient; auditors look for a genuine narrative about what the project is, what it aims to achieve, and that EU money is involved.

Social media activity related to the project must also carry the EU emblem and acknowledgment. This does not mean every post your organisation ever makes — only posts that are related to the funded operation. However, in practice, organisations running active projects should create a standard template for project-related posts that automatically includes the correct branding. A social media image template, a pinned account banner, and standardised hashtag practice are all effective approaches.

All events related to the funded operation must display the EU emblem. For in-person events, this means banners, exhibition stands, signage, and screen backgrounds. For online events and webinars, this means slides, virtual backgrounds, and registration pages. The obligation applies to kick-off meetings, mid-project conferences, public consultations, training sessions, and closing events equally.

Press releases and media materials must carry the EU emblem and the written acknowledgment. When issuing a press release about project milestones, funding announcements, or results, the EU acknowledgment must appear clearly — not buried in the small print at the end, but integrated into the document in a way that makes the EU's contribution visible.

All written publications — reports, brochures, fact sheets, guidance documents, toolkits, newsletters, and academic papers — produced in connection with the operation must carry the emblem and statement. The same applies to presentations and audiovisual materials: slide decks, videos, podcasts, infographics, and any other media produced as an output of the project.

A common practical question is what happens when project staff change. If a new communications officer joins mid-project, they need to be briefed on the EU visibility requirements as part of onboarding. The organisation, not the individual, bears responsibility for compliance — managing authorities assess the organisation's materials as a whole, regardless of staff turnover. Maintain a documented record of your visibility requirements as part of your project management documentation so that institutional knowledge is not lost when personnel change.

5. The 3% Penalty Rule

The 3% penalty rule is the enforcement mechanism that gives the CPR's visibility obligations real financial weight. Understanding how it works in practice is essential for any beneficiary organisation managing risk.

The managing authority — not the European Commission directly — applies the financial correction. This means the penalty is determined at member state or programme level, and managing authorities have discretion in how they apply it within the bounds set by the regulation. The regulation requires them to take into account the principle of proportionality, which means the severity of the correction should reflect the severity and extent of the non-compliance.

In concrete terms: a single document missing the EU emblem, discovered during an otherwise compliant project check, is treated very differently from a finding that an organisation has never displayed the EU emblem anywhere throughout a multi-year project. Managing authorities are expected — and required — to calibrate their response accordingly. However, proportionality does not mean insignificant non-compliance is automatically excused; it means the correction is scaled to fit the breach.

Consider the financial significance with real numbers. On a €400,000 ESF+ grant, a 3% correction represents €12,000 of funding that can be cancelled — meaning the organisation must repay or absorb that amount. On a €1.2 million ERDF infrastructure project, 3% amounts to €36,000. On a €2.5 million programme, 3% is €75,000. These are not hypothetical numbers; corrections at this level have been applied across EU member states for visibility non-compliance.

The penalty is applied per operation — the specific funded project or action. If your organisation runs multiple operations funded by EU structural funds, each is assessed and corrected separately. Non-compliance on Operation A does not trigger a correction on Operation B, but you cannot shelter one operation's issues behind another's compliance record.

A further point that catches many organisations off guard: the penalty can be applied retroactively to completed projects. EU funding programmes have audit windows that typically extend several years after project closure. An audit finding from a project that ended three years ago can still result in a financial correction being applied today, including the visibility non-compliance penalty. This is why building a compliance documentation file from day one — and maintaining it after the project ends — is not optional risk management but essential practice.

6. What Auditors Actually Check

Understanding what auditors actually look for — and how the verification process works in practice — is as important as understanding the formal rules. The formal requirements tell you what you must do; understanding the audit process tells you what evidence you need to demonstrate that you did it.

The European Court of Auditors' Special Report 11/2025 on EU fund transparency found that EU fund managers rely "mainly on self-declarations" for compliance verification. This finding has significant practical implications. In most programmes, you will be asked to declare compliance through a signed statement or form, rather than having each piece of compliant material individually inspected at the time of production. This means the primary enforcement mechanism, at the moment of production, is the beneficiary's own declaration of compliance.

This structure creates a compliance dynamic worth understanding clearly. Because real-time spot checks are rare, there is a temptation — which the ECA explicitly flagged — to treat visibility compliance as a box-ticking exercise. The ECA found that EU fund managers "do not proactively search for potential breaches." This generates a false sense of security: organisations that are non-compliant may go unchallenged for extended periods, which can feel like implicit approval. It is not.

When a formal audit or verification check does occur — whether triggered by a routine programme audit cycle, a complaint, a media report, or a random sampling exercise — the auditors will request documentary evidence. The documents they typically request include:

• Signed compliance declarations submitted during the project
• Photographs of physical plaques or posters, with installation dates
• Screenshots of the project website showing the EU emblem and acknowledgment
• Copies of published reports, brochures, and communications materials with correct EU branding
• Event photographs showing EU emblem display
• Social media screenshots from project-related posts
• Press releases and media materials with the required acknowledgment

Auditors assess the totality of the evidence. A missing screenshot can be compensated for by strong evidence in other areas. Conversely, if multiple evidence categories show consistent non-compliance, the likelihood of a financial correction increases substantially.

The practical consequence of the ECA's finding is this: build your documentation file from day one, not when you receive an audit notice. When an audit notice arrives — often giving you 10 to 20 working days to produce evidence — is not the moment to begin gathering and organising materials from across two or three years of project activity. Maintain a living compliance file throughout the project that captures evidence as you go, updated each time you produce a new compliant output or communication.

A good compliance file includes: a folder of dated screenshots showing the website at key points throughout the project; a folder of all published materials with the correct EU branding; a log of events with photographic evidence; copies of any press releases; and your internal template files showing that the correct wording is embedded in your standard materials.

7. The EU Financial Transparency System

The EU Financial Transparency System (FTS), accessible at ec.europa.eu/budget/fts, is the European Commission's public database of grants and contracts awarded under direct management by EU institutions. It is a genuinely useful tool for civil society, journalists, researchers, and funders seeking to understand how EU money flows — but its scope is significantly narrower than many people assume.

The FTS contains detailed records of EU direct management funding: grants, contracts, prizes, and contributions awarded directly by the European Commission, rather than channelled through member state authorities. The database provides recipient name, award amount, project purpose, country, and approximately 38 data points per entry. It is searchable by organisation name, fund, country, year, and several other parameters.

The programmes covered by the FTS include Horizon Europe, Erasmus+, Creative Europe, the LIFE programme, various health programmes, and other centrally managed EU initiatives. If your organisation receives a direct Commission grant under any of these programmes, you should verify that your entry appears correctly in the FTS — with accurate information about your organisation's name, country, and the amounts received.

However — and this is critical — the FTS does not cover shared management funds. ERDF, ESF+, the Cohesion Fund, the JTF, and the other funds governed by CPR 2021/1060 are managed by member states, not directly by the Commission. Beneficiary data for these funds is published not in the FTS but on the national or regional programme websites operated by managing authorities in each member state.

This fragmentation has significant practical consequences. The ECA Special Report 2025-11 found that compiling complete information about a single NGO's EU funding across all sources is "practically impossible" because the data is distributed across dozens of national and regional systems with no common interface, no standardised search functionality, and inconsistent data quality. A journalist, auditor, or institutional funder trying to understand the full picture of an organisation's EU funding would need to check the FTS for direct grants, then identify every national programme website relevant to that organisation's member state and region, then search each separately.

What does this mean in practice for your organisation?

• If you receive direct management grants (Horizon, Erasmus+, etc.), verify your FTS entries are accurate and complete.
• If you receive shared management grants (ERDF, ESF+, etc.), verify your entry on the relevant national programme website operated by your managing authority. These are typically listed on the programme's official website under a section titled "List of Beneficiaries" or similar, as required by Annex IX of CPR 2021/1060.
• Be aware that external stakeholders seeking information about your EU funding may find fragmented or inaccurate information through these systems — proactive disclosure on your own website is both good practice and, in many cases, a compliance requirement.

8. Visibility vs. Transparency

The EU's framework uses the words "visibility," "communication," and "transparency" but treats them largely as a unified set of obligations. It is worth drawing a clearer distinction between these concepts — because the distinction matters for how organisations should think about their obligations beyond the minimum legal requirements.

Visibility, as used in CPR 2021/1060, is fundamentally about confirmation: confirming to the public that EU money was used to fund a specific activity. The emblem, the written statement, the plaque at the project site — these are signals that say "EU funding was here." Visibility is about attribution: crediting the source of public money in a way that allows citizens to see how EU funds are being deployed across their region and member state.

Transparency, in its fuller meaning, goes considerably further. Genuine transparency is the degree to which an organisation's operations, decisions, financial management, and impacts are genuinely understandable to its stakeholders — beneficiaries, staff, funders, communities, and the general public. An organisation can have impeccable EU visibility compliance — the correct emblem on every document, a durable plaque at every site, a perfectly worded acknowledgment on every social media post — and still be fundamentally opaque about how it operates.

The gap between visibility and transparency is not merely academic. Consider a funded organisation that meets every Annex IX requirement but whose project beneficiaries cannot access clear information about how project decisions are made, how complaints are handled, or how funds are distributed internally. The EU logo confirms that public money was spent. It says nothing about whether that money was spent well, or whether the people it was meant to serve had any meaningful say in how it was used.

This distinction matters for several practical reasons:

• Compliance protects your grant. Meeting EU visibility requirements is essential — the 3% penalty is real, audits happen, and non-compliance creates legal and financial risk. Compliance is the floor, and you must be on the right side of it.
• Genuine transparency builds trust and resilience. Organisations that are genuinely transparent — that communicate clearly with their beneficiaries, publish understandable accounts of how decisions are made, and engage honestly with failures as well as successes — build a kind of institutional credibility that compliance alone cannot provide.
• Funders increasingly look beyond compliance. Institutional funders, foundations, and increasingly the EU's own evaluation frameworks are beginning to ask not only "did you display the logo?" but "can you demonstrate that your organisation operated with genuine accountability to your beneficiaries?"

Vedomia's approach to this distinction is grounded in the belief that internal transparency — clarity within an organisation about how decisions are made, how resources are allocated, and how performance is assessed — is what enables meaningful external transparency. An organisation that cannot explain its own processes to its own staff cannot credibly explain them to external stakeholders. The visibility requirements in CPR 2021/1060 are the starting point; genuine transparency is the goal.

The practical question to ask yourself is not only "are we compliant?" but "if a curious outsider looked at our communications, would they understand not just that we received EU funding, but what we did with it, what we achieved, and how our organisation makes decisions?" The answer to the first question is a legal requirement. The answer to the second is a measure of your organisation's genuine accountability.

9. Your Compliance Checklist

Use this checklist to verify that your organisation meets the core CPR 2021/1060 visibility and communication requirements. Each item corresponds to a specific obligation in Annex IX or Article 47. Work through this list at project launch, and review it at each significant project milestone.

1. EU emblem on all project documents The official Union emblem (circle of twelve stars on blue) appears on all documents related to the funded operation — reports, presentations, correspondence, publications, and any other written materials.
2. Correct written statement, written in full "Funded by the European Union" or "Co-funded by the European Union" appears next to the emblem, written in full. No abbreviations. No alternative formulations.
3. Emblem at least as large as any other logo On all co-branded materials, the Union emblem is at minimum the same size as the largest other logo displayed — including your own organisation's logo and any partner or managing authority logos.
4. Project website includes emblem, acknowledgment and operation description The website (or dedicated project pages) shows the EU emblem, the required written statement, and a substantive short description of the operation including its aims, expected results, and the financial support from the Union.
5. Social media posts carry the EU emblem and acknowledgment All posts related to the funded project include the EU emblem and the required written acknowledgment. A standard post template with correct branding is in use.
6. Published reports, brochures and presentations carry correct branding All written publications and slide presentations produced in connection with the operation carry the Union emblem and the written statement in the required format.
7. Project events display the EU emblem At all events — whether in-person or online — related to the funded operation, the EU emblem is prominently displayed on signage, banners, slides, or virtual backgrounds.
8. Permanent plaque or billboard installed (if ERDF/CF and total cost over €500,000) A durable plaque or billboard bearing the Union emblem and statement is installed at the project site. The threshold is based on the total cost of the operation (Article 50(1)(c) CPR 2021/1060), not public support received. Installation was completed once physical implementation began, not at project closure.
9. Permanent plaque or billboard installed (if ESF+, JTF, EMFAF, AMIF, ISF, BMVI or Interreg and total cost over €100,000) A durable plaque or billboard is installed and bears the correct EU branding. The threshold is the total cost of the operation under Article 50(1)(c) CPR 2021/1060 — not public support received.
10. A3 poster displayed if below the relevant threshold If the total cost of the operation falls below the plaque threshold, at least one A3 poster (or equivalent electronic display) carrying the EU emblem and statement is displayed in a publicly visible location at the project site.
11. Documentation file maintained and up to date A project compliance file is actively maintained containing: dated photographs of plaques/posters, dated screenshots of the website, copies of compliant materials, signed declarations, and records of communication activities.
12. Communications staff know the exact required wording All team members responsible for producing external communications, social media content, publications, or event materials have been briefed on the exact required EU acknowledgment wording and have access to the official emblem files.

10. Frequently Asked Questions