The Civic Alliance – Latvia (CAL) has issued an opinion to the European Commission on the Democracy Protection Package Directive, which aims to "introduce common standards of transparency and accountability in the internal market for interest representation activities carried out on behalf of third countries". To date, a number of civil society organisations have repeatedly expressed their concerns about this framework to the European Commission in various consultations, meetings and letters. While the Commission's concerns about interference and misinformation are justified, the CAL believes that this Foreign Funding Directive will not achieve its stated objective of exposing covert foreign interference in policy-making. Instead, it is likely to lead to the stigmatisation and harassment of civil society and other legitimate actors that receive funding from sources outside the EU and EEA.

Key points raised in the CAL Opinion: 

• Lack of specificity in regulation: the broad definition of "interest representation activities" and the lack of specificity will open the door to abusive and arbitrary application of the law by authorities wishing to unduly restrict civic space.

• Registration requirements: highlights the lack of clarity on which organisations are required to register under the Directive, which may lead to confusion and difficulties in implementing the Directive.

• High administrative burden: the CAL stresses that the Directive may create an unjustifiably high administrative burden, especially for civil society organisations.

• Stigmatisation and risk of restriction of access: in the view of the CAL, the Directive may contribute to stigmatising civil society organisations as "foreign agents" and make it more difficult for them to access decision-making.

• Impact assessment: The CAL considers that the impact assessment referred to in the Directive has not been carried out in a qualitative and evidence-based manner. 

• Lack of sanctions: The CAL considers that the Directive should provide for sanctions for public officials who engage in campaigns of stigmatisation and harassment of civil society organisations on the basis of the organisations' foreign funding. 

The European Civic Forum's analysis of the Directive in Latvian can be found here.

The CAL opinion can be found here.

The information has been prepared with the financial support of the Society Integration Foundation from the Latvian state budget. The Civic Alliance - Latvia is responsible for the content of the information.