The Commission's €1.8 trillion budget proposal does not say "we are cutting NGOs." But, if cuts happen, they will come through structural design, fewer dedicated funding lines, weaker earmarks, and more money routed through national governments. Civil society coalitions warn it could be slow defunding dressed up as simplification.

The MFF reorganises the EU budget from 52 programmes to 16, folding cohesion, social, and agricultural spending into 27 national partnership plans. The protected headings are defence, competitiveness, and digital and green transitions. Civil society is not one of them.

"We are in a moment of changing priorities and a changing environment for the union," says Eulàlia Rubio, Senior Research Fellow at the Jacques Delors Institute. "We have a lot of fragmentation inside the union. That makes it much more difficult and to a certain extent it is reflected in the negotiations."

Support for democracy and civic resilience, Rubio adds, is precisely the kind of heading "in which there are no big defenders among member states, no one is really seeing major cuts there."

The Commission points to AgoraEU, an €8.58 billion programme merging CERV and Creative Europe, as proof of its commitment to civil society and media freedom. Nominally bigger than its predecessors, it has a critical omission. The draft regulation does not explicitly mandate operating grants, the multi-year funding that allows NGOs to do advocacy, watchdog work, and strategic litigation. Without a legal guarantee, future work programmes could simply drop them.