Review reports from the EACEA issued in November 2025 concerning 3 Erasmus+ funded projects carried out by WYA Europe in 2024, alleged that aspects of WYA Europe’s educational materials and approach constituted a breach of EU values. The criticism did not concern how projects were managed or implemented, but instead mounted objections to the content of the educational discussions and projects that were completed. In particular, the EACEA reports objected to materials and activities affirming that human dignity and life begins at conception, that biological sex is an objective scientific reality, that reproductive health should include fertility education and informed consent, and the emphasis on the family as the fundamental unit of society. The EACEA reports also criticized WYA for not supporting and promoting abortion and surrogacy.
The WYA Europe response (December 4th 2025) directly challenged both the conclusions and the methodology applied by the EACEA. Our responses explain that the Agency’s concerns arise not from contractual failures but from disagreement with positions expressed in lawful educational discussions carried out within approved projects. Disagreement on topics and issues is outside of the competence of EACEA review processes.
The EACEA itself confirms this point in each review. They note that the dispute “does not concern financial management or contractual obligations, but rather disagreement with viewpoints expressed in educational discussions.” While individuals within the EACEA are free to hold any position they want, the EACEA as a review institution has no competence to determine whether certain scientific facts and ethical viewpoints should be permissible within EU-funded activities.
The problems for the EACEA
A central criticism in the review reports concerns content and educational materials addressing the beginning of human life. The reviewers identify as problematic that project materials affirm that life begins at fertilisation and connect this to broader educational positions presented in training and publications.
The EACEA report highlighted one program deliverable, “Life Begins at Fertilization: Emphasized that life begins at fertilization, highlighting the unique and extraordinary nature of conception.” They argued that this content forms part of a broader problem they characterised as: “one-sided and biased material on sexual and reproductive health rights.”
They further claimed that project activities“systematically omit certain topics or present them in a negative way (for example, in relation to comprehensive sexuality education, oral contraception, abortion and surrogacy)” and that “The presentation of these topics lacks balance and does not reflect the expectation of scientifically accurate, evidence-based, non-judgmental and comprehensive sexuality education.”
WYA Europe activities and statements reflect basic biological science regarding fertilization and embryonic development. Fertilization produces a genetically distinct human organism, a fact recognized in standard embryology and developmental biology. Presenting this scientific reality in youth education activities cannot reasonably constitute a breach of EU values. Our materials introduce young participants to the biological process of conception and early human development precisely so that discussions about human dignity, inter-personal relationships, responsibility and reproductive health are grounded in scientific fact.
A second point criticized in the review reports concerned WYA’s affirmation of the family as a foundational social institution. The reviewers object not to specific project deliverables but to the fact that the WYA Charter, contains a particular understanding of family and human dignity: “Among other things, the Charter states ‘that the intrinsic dignity possessed by every human being from conception to natural death is the foundation of everyone’s right to life’ and ‘that the fundamental unit of human society is the family’.”
Additional review comments focused on the WYA Brussels Declaration on the Family and warned that: “Further explanation should be provided, because this ‘declaration’ could be invoked in order to suggest that same sex and single parents do not count as proper ‘families’.”
Our response clarified that these positions do not represent ideological innovation but reflect language long established in international law. Article 16(3) of the Universal Declaration of Human Rights recognizes that “the family is the natural and fundamental group unit of society and is entitled to protection by society and the State.” Similar formulations appear in Article 23 of the International Covenant on Civil and Political Rights and Article 10 of the International Covenant on Economic, Social and Cultural Rights, both binding instruments ratified by EU Member States.
Gender and… more biology
A separate line of criticism in the review reports concerns questions of gender in WYA Europe’s educational materials and publications. The EACEA reviewers argue that WYA’s materials do not reflect the approach promoted in current EU policy frameworks on gender and LGBTIQ inclusion.
The reports explicitly criticize WYA publications for rejecting the idea that gender can be separated from biological sex. As the reviewers state: “On Gender, it rejects the claim that gender can contradict biological sex. The EU LGBTIQ+ Equality Strategy 2020-2025 and 2026-2030 separates and protects both sex and gender.” One review states: “The term ‘gender’ refers to a very narrow conception: it refers only to one of two poles, either ‘women’ or ‘men’. Nothing is said about LGBTQ+ people.”
The reports further claim that such positions conflict with program expectations on inclusion and diversity, concluding that: “Those listed statements restrict scientific accuracy and information and do not foster inclusion and diversity as described in the Erasmus+ Inclusion and Diversity Strategy. In fact, they constitute discriminations linked to gender identity and gender expression.”
Our responses make clear that human reproduction, fertility, and many aspects of health and personal development education necessarily rely on biological distinctions between men and women. Explaining these biological facts and differences between male and female bodies in educational settings is not an ideological statement but a reflection of established scientific understanding.
Moreover, EU primary law itself recognizes the distinction between women and men as a foundational legal category. Article 2 of the Treaty on European Union which defines the Union’s fundamental values explicitly affirms that EU societies are those in which “equality between women and men prevail.” The Charter of Fundamental Rights of the European Union similarly guarantees equality between women and men in Article 23. These provisions demonstrate that the legal framework underlying EU programs is built on the recognition of sex as a meaningful legal and social category.
Our responses therefore underline that our Declarations and educational materials referring to women and men in biological terms are consistent with the language of EU law itself. Recognizing biological sex does not deny respect or dignity to any individual; rather, it reflects the legal and biological realities upon which many areas of health policy, social protection and equality law are constructed.
Is anything missing from reproductive health discussions?
In the review of the Women’s Health Goes Digital project, the reviewers argue that the project’s reproductive health materials do not sufficiently reflect the needs of all potential audiences, in particular mentioning groups such as LGBTIQ persons and single women. The report suggests that by focusing strongly on certain approaches to reproductive health, the project risks leaving out other perspectives that should be addressed within EU-funded educational actions.
These claims fail in two ways. First is the idea that excellence in health care for women should vary or be dependent on various sub-groups identifications. Women deserve the best knowledge-based, and science and evidence-based care in all stages of life, and regardless of group or affiliation. We believe that excellence in healthcare should be provided to every [single] woman, regardless of marital or other status or group. The position of the EACEA is astonishing.
Second, our response further clarifies that this interpretation ignores the contractual scope of the project itself. The action was approved and funded as a project specifically focused on women’s mental and reproductive health in digital environments: “It is not designed as a universal sexuality education program addressing all possible audiences, issues or categories. The absence of certain content is not an omission; it reflects the project’s defined thematic scope.”
The reply therefore concludes that the criticism arises from evaluating deliverables against expectations that do not appear in the Grant Agreement. As the response notes, “Evaluating the deliverable against criteria outside the Grant Agreement exceeds the bounds of contractual review.” In other words, the project is not faulted for failing to implement agreed activities, but for not transforming into a broader program that it was never contractually required to become.
Surrogacy
The treatment of surrogacy in the reviews was serious enough to warrant a specific response. WYA Europe submitted a separate additional response on 22 December 2025, focused exclusively on correcting what it considers a fundamental legal error in the Agency’s reasoning. A detailed public explanation of this issue is also available in this article on the WYA website.
The EACEA review argues that project materials“systematically omit certain topics or present them in a negative way (for example, in relation to … abortion and surrogacy).” Our response is unambiguous: “WYAE cannot accept this interpretation.” Surrogacy is not an EU value. It is a practice that is illegal in the majority of European Union Member States. Conditioning compliance with EU values on favorable or non-critical treatment of surrogacy seems contrary to EU law and fundamental freedoms.
What are the compliance benchmarks?
A central point of dispute in all three review procedures concerns the benchmarks used by EACEA to assess compliance with EU values, and in particular the introduction of policy documents that are not legally binding into what is formally a contractual compliance review.
The review reports explain that, beyond the Treaty framework and the grant agreement itself, the experts relied on what they describe as a broader “reference frame of guidance beyond the general framework of the TFEU, the EU Financial Regulation and the grant agreements themselves.” This additional guidance explicitly includes European Parliament resolutions on sexual and reproductive health and rights, LGBTIQ rights, and related policy strategy documents.
In practice, this means that the compliance assessment does not rely only on binding provisions such as Article 14 of the Grant Agreement or Article 2 TEU, but also on policy documents and resolutions which are political documents and are not a source of law nor can they be understood to create binding legal obligations for WYA Europe as a beneficiary of an Erasmus+ grant. The reports repeatedly reference European Parliament resolutions requiring access to comprehensive sexuality education, universal access to contraception, and access to abortion services as part of the framework used to judge project compliance. The consequence is visible in the compliance conclusions themselves. The reports state that project materials are problematic because they are “one-sided and biased,” that “the presentation lacks balance and does not reflect an evidence-based, comprehensive, and non-judgmental sexuality education,” and that omission or negative presentation of topics such as abortion is at odds with EU values.
On the contrary, our responses stress that these expectations are not contained in the grant agreements. The contractual obligation under Article 14.2 of the Grant Agreement requires beneficiaries to respect fundamental EU values, but these values are clearly defined in binding legal texts, not in the cherry-picked political resolutions referenced by the EACEA reviewers.
As recalled in the review letters themselves, Article 14 refers directly to Article 2 of the Treaty on European Union, which states that those are “respect for human dignity, freedom, democracy, equality, the rule of law and respect for human rights, including the rights of persons belonging to minorities… in a society in which pluralism, non-discrimination, tolerance, justice, solidarity and equality between women and men prevail.”
Our responses underline that WYA’s activities are explicitly grounded in these principles. Educational programs promote human dignity, dialogue, respect among participants, and non-discrimination in access to activities. For this reason, our responses object to the introduction of additional compliance benchmarks after grants had already been awarded and projects implemented. In several cases, the political resolutions and policy strategies cited in the reviews were adopted only after the projects had already been carried out. Beneficiaries cannot reasonably be assessed against standards that were neither contractual obligations nor legally binding requirements at the time activities took place. Otherwise, the consequence is uncertainty for civil society organizations participating in EU programs and undermining trust in the fairness and inclusivity of EU funding procedures.
Where can one find WYA’s positions?
The EACEA reviewers further allege that WYA Europe failed to sufficiently disclose its positions during the grant application stage, particularly regarding questions related to abortion and the beginning of human life.
They argue that while project proposals referred to themes such as human dignity and sexual health education, they did not explicitly state positions which later appeared in educational materials and publications. The Youth Act review report states: “The organisation mentions human dignity and sexual health education without describing its positions such as its opposition to abortion… and the fundamental idea that life begins at conception.”
The implication drawn by the reviewers is that the Agency approved the projects without being fully informed about the deeper framework guiding WYA’s educational approach, and that certain positions only became visible at the implementation stage.
We firmly reject this allegation. Project applications described objectives, activities and deliverables as required under the grant procedures. The significant body of public statements and positions taken by WYA were transparently available on our website and other platforms at the time of the application, and remain publicly accessible on these platforms today.
The WYA Charter, which includes the affirmation that human dignity exists from conception, is openly accessible and has long formed the basis of the organization’s work, since its founding in 1999. Nothing in the application process veiled these principles, and nothing in project implementation contradicted the approved work programs.
The very fact that EACEA reviewers were able to cite these positions directly from WYA’s publicly available materials demonstrates our commitment to openness and transparency. Suggesting that WYA somehow hid its positions is therefore unfounded: the organization’s principles have always been openly stated and accessible, and formed a transparent foundation for the projects implemented under Erasmus+.
Was the review criticism aiming to introduce a new, retroactive, expectation? Must applicants anticipate and explicitly declare positions that are not prohibited by EU law and that do not constitute contractual non-compliance? The responses conclude that grant evaluations must assess whether activities correspond to approved project descriptions, not whether beneficiaries fully align with evolving policy preferences or disclose any anticipated reservations with their broader worldview.
Conclusion
The implications of our case go beyond our own WYA Europe activities. It is unacceptable that educational material grounded in scientific facts and legitimate, lawful ethical positions can be treated as a breach of fundamental EU values. What was alleged in this review process is not a legitimate ground for non-compliance with the Grant Agreement, especially when the projects have been implemented as agreed. Affirming such conclusions risk turning EU funding programs into mechanisms that are exclusive, undemocratic, politically selective and disconnected from binding legal standards, and discourage or prevent civil society organizations across Europe from participating in programs that should remain open, fair and governed by law rather than ideological preference.
At stake is therefore not simply the future of a small number of projects, but whether EU youth programs remain spaces where pluralism, open discussion and diverse ethical perspectives are respected among civil society organizations working with young people across Europe.
World Youth Alliance Europe is committed to principles of freedom and plurality, which ensure EU grant and EU program access are available to all, subject to compliance with grant agreements and applicable law, and not based on ideological alignment. Young people benefit from exposure to debate and diversity of viewpoints, and youth programs should encourage critical thinking and dialogue rather than avoid complex ethical questions.
The Commission’s forthcoming response will therefore be decisive. Given that the projects were implemented according to their grant agreements and that the alleged breaches stem from political disagreement and ideological misinterpretations of fundamental EU values rather than contractual non-compliance, the only legally coherent outcome of this process would be to set aside the review conclusions. The EACEA must affirm that the positions expressed by WYA when it comes to beginning of life, the fundamental role of the family, criticism of surrogacy, etc. are legally protected perspectives within the EU, in line with fundamental EU values, and clearly confirm that beneficiaries of EU funded programs cannot be penalized for expressing viewpoints that remain fully within the limits of EU law and fundamental freedoms.
Read the full responses by WYA in the attachments below.
WHGD_Response to the EACEA Review Report and Review Letter
WYAE OG 2024_Response to the EACEA Review Report and Review Letter
