By WYA Staff
Brussels, [April 11] — The European Commission has clarified that compliance with “EU values” in Erasmus+ project reviews must be grounded in Article 2 of the Treaty on European Union and assessed within the framework of the Grant Agreement, and cannot be based on non-binding political documents. This confirms concerns previously raised by World Youth Alliance Europe (WYA Europe) in its formal responses to the review procedures. The Commission’s clarification therefore calls into question the methodology used by the European Education and Culture Executive Agency (EACEA) in its review of projects implemented by WYA Europe.
This clarification follows recent parliamentary scrutiny of the review procedures concerning WYA Europe’s Erasmus+ projects. Parliamentary Question E-10-2026-000297, raised by MEP Karlo Ressler and co-signed by Lukas Mandl, Massimiliano Salini, Bert-Jan Ruissen, Davor Ivo Stier, Miriam Lexmann, Željana Zovko, Loránt Vincze, Tomislav Sokol, Isabel Benjumea Benjumea, Matej Tonin, Christophe Gomart, Paulius Saudargas asked how compliance with EU values under Article 14 of the Erasmus+ Grant Agreement should be interpreted, including whether such assessments may rely on non-binding political documents.
In her written answer issued March 24th, 2026, Executive Vice-President of the European Commission Roxana Mînzatu confirmed that compliance with EU values, as reflected in Article 14 of the Erasmus+ Grant Agreement, must be grounded in Article 2 of the Treaty on European Union and assessed within the framework of the Grant Agreement. The Commission further explicitly clarified that such assessments cannot be based on non-binding political positions, strategies, or resolutions that are not referenced in the Grant Agreement.
This follows earlier concerns raised by Members of the European Parliament, when fifteen MEPs, led by Paolo Inselvini and including Lukas Mandl, Massimiliano Salini, Bert-Jan Ruissen, Davor Ivo Stier, Miriam Lexmann, Željana Zovko, Loránt Vincze, Tomislav Sokol, Isabel Benjumea Benjumea, Matej Tonin, Christophe Gomart and Paulius Saudargas, formally called on the European Commission to clarify the methodology, criteria and respect for political neutrality in the review procedures concerning WYA Europe’s projects.
This clarification directly addresses concerns raised by WYA Europe in response to review procedures affecting three Erasmus+ projects: Women’s Health Goes Digital (WHGD), WYA Europe Operating Grant 2024 and Youth Act 2024.
In its previous communications, WYA Europe demonstrated that the EACEA reviews rely on a constructed “reference frame” derived from non-binding political documents, including European Parliament resolutions and Commission strategies. These instruments were used as normative benchmarks to assess compliance with EU values, despite not forming part of the legal framework of the Grant Agreements.
The Commission’s response confirms that such an approach is not consistent with the applicable legal standard.
Methodology Based on Non-Binding Documents
The review reports explicitly introduce a “reference frame of guidance beyond the general framework of the TFEU, the EU Financial Regulation and the grant agreements themselves.” This framework is composed primarily of non-binding political instruments, including resolutions on sexual and reproductive health and rights and LGBTIQ issues, as well as recent Commission policy strategies.
WYA Europe has consistently argued that this methodology substitutes the legal standard set out in the Treaties with a set of evolving political positions. The Commission’s clarification now confirms that non-binding documents cannot serve as the basis for assessing compliance with EU values under Article 14 of the Grant Agreement.
Lawful Views Cannot Constitute Non-Compliance
The review reports also characterised certain positions held by WYA Europe as “one-sided” or “biased,” including the recognition that life begins at conception, the view that gender is intrinsically linked to biological sex, that the family is the fundamental unit of society, as well as critical perspectives on practices such as surrogacy.
However, the Commission explicitly confirmed that beneficiaries of EU programmes may hold and express all views that are consistent with the values set out in the Treaties and the Charter of Fundamental Rights. This includes lawful ethical, philosophical, and scientific positions that fall within the scope of freedom of thought and conscience.
In particular, WYA Europe noted that the review’s treatment of critical perspectives on surrogacy as “one-sided” would effectively require beneficiaries to present arguments in favour of a practice that is prohibited or strictly limited in a majority of EU Member States due to concerns related to human dignity and the protection of women and children.
Review Procedures Cannot Produce Legal Effects
In light of the Commission’s clarification, WYA Europe considers that the methodology applied by EACEA is fundamentally flawed. By relying on non-binding political documents and applying standards not foreseen in the Grant Agreements, the review procedures are affected by a structural legal error.
WYA Europe has formally written to EACEA regarding each of the affected projects, noting that no final decision has been communicated for over four months following the submission of its responses. We have clearly requested that the review procedures be set aside in their entirety, as they cannot lawfully produce effects under the Grant Agreements.
Commitment to EU Values and Legal Certainty
WYA Europe remains fully committed to the fundamental values of the European Union, including human dignity, pluralism, and the rule of law. We will continue to advocate for the proper and lawful implementation of EU programmes, in accordance with the Treaties and the contractual framework agreed with beneficiaries.
The recent clarification by the European Commission represents an important step in ensuring that evaluation processes respect legal certainty, institutional neutrality, and the respect for lawful perspectives within the European Union.
