posts / APPF's Committee of Independent Eminent Persons

The APPF's Committee of Independent Eminent Persons:
an early guide

— Louis Drounau, EDCS founder

4 Aug. 2026 — The APPF's Committee of Independent Eminent Persons is about to meet for the first time to weigh on the de-registration of ESN party. Here is what you should know.

On 3 August, Euractiv reported that the European Commission looked to appoint former Commission Secretary-General Alexander Italianer and former Director-General Martine Reicherts as its experts on the Committee of Independent Eminent Persons of the Authority for European political parties and European political foundations (APPF).

This piece of news came as a personal relief as, back in January and mindful of the consequences of the new Regulation on European parties that had just entered into force, I had alerted the Cabinet of Michael McGrath, European Commissioner for Democracy, Justice, the Rule of Law, and Consumer Protection, about the Commission's failure to nominate their experts in a timely manner. Full disclosure, I had used that opportunity to express my own interest for the position.

Given Parliament's recent vote requesting the APPF to open a verification procedure against ESN Party, this month is a very opportune moment to discuss the little we know about the APPF's Committee of Independent Eminent Persons.

Note: In a tragic twist, while researching information for this piece, I found out that Pablo Vázquez, one of the Committee's members, had passed away the day before. Given the consequences of this development, I decided to release this piece early, as it may prove more useful now than later. My heart goes out to Mr Vázquez's family and friends.

What is the Committee of Independent Eminent Persons?

The Committee of Independent Eminent Persons was created by Art. 11 of Regulation 1141/2104, adopted in 2014 and which applied as of 2017 (Art. 41). The Committee was unaffected by the 2018 review of the Regulation, given a broader mandate in 2019, and then retained as is in Art. 16 of recast Regulation 2025/2445, which entered into force in December 2025.

The sole purpose of this Committee is to provide the APPF with an advisory opinion in two specific moments:

1. during a verification procedure relating to the values upon which the Union is founded, as described in Art. 2 TEU; and
2. during a verification procedure relating to infringements of data protection rules.

For more information on the verification procedure relating to the respect for EU values, see our previous post on the matter.

More specifically, the Committee is to give an opinion on:

• any possible manifest and serious breach of the values on which the Union is founded, as referred to in Article 3(1), point (d) and (e), and Article 3(2), point (c) and (d), by a European political party or a European political foundation (Art. 16.3(a)); or
• whether a European political party or a European political foundation has deliberately influenced or attempted to influence the outcome of elections to the European Parliament by taking advantage of an infringement of the applicable rules on the protection of personal data (Art. 16.3(b)).

In practice, however, the Committee has never issued an opinion, and has never even met. This is because no verification procedure had ever been opened until very recently. As previously discussed, recast Regulation 2025/2445 extended the obligation to respect EU values to the member parties and organisations of European parties and foundations — therefore beyond European parties and foundations themselves.

In May, based on this newfound legal basis, the APPF submitted a fact-finding report detailing evidence casting doubt on whether member parties of the Europe of Sovereign Nations party respected EU values.

On 7 July, the European Parliament voted to request the opening of a verification procedure, thereby paving the way for the Committee's first official task.

How does the Committee of Independent Eminent Persons work?

The Regulation mostly focuses on the start of the Committee's work.

With regards to a verification procedure relating to EU values, once one or more of the three main institutions has asked the APPF to initiate a verification, the APPF is to "inform the European political party or European political foundation concerned without undue delay, invite it to submit its observations and give it the opportunity to introduce measures to remedy the situation within one month of receipt of the information" (Art 13.1), a deadline that can be extended if necessary (Art. 13.2).

Upon the expiry of the deadline or when the party or foundation provides their observations and information concerning corrective measures, the APPF shares the party or foundation's submission to the Committee and asks for an opinion on the subject. The committee then gives its opinion within two months of the APPF's request.

With regards to a verification procedure relating to personal data, "if the APPF is informed of a decision of a national supervisory authority", as defined by GDPR, "finding that a natural or legal person has infringed applicable rules on the protection of personal data", and the infringement "is linked to political activities by a European political party or a European political foundation in the context of elections to the European Parliament", the APPF refers the matter to the Committee (Art. 15.2).

In this case, the APPF must request the Committee's opinion within one month of being informed of the decision of the national supervisory authority, and the APPF itself sets a "short, reasonable deadline" for the Committee (Art. 15.3).

Notably, in the former case, the Committee is, since recast Regulation 2025/2445, able to provide an opinion on the actions both of European and national entities, while, in the latter case, the opinion may only concern the activities of European entities.

In both types of verifications, the Committee may request any relevant document or evidence from the APPF, Parliament, the European party or foundation concerned, other political parties, political foundations or other stakeholders, and it may request to hear their representatives (Art. 16.3). This would, among others, cover a fact-finding report by the APPF, which, unlike the party or foundation's submission, is not explicitly mentioned as being shared with the Committee. Surprisingly, the Committee is not empowered to request documents or evidence from the Commission or the Council.

The Regulation also requires that the Committee give "full consideration to the fundamental right of freedom of association and to the need to ensure pluralism of political parties in Europe" in its decisions, referring to Art. 12 of the Charter of Fundamental Rights, and that the decisions be made public without delay (Art. 16.3).

Finally, the Regulation insists on the Committee's independence, stating that its members "shall be independent in the performance of their duties" and shall "neither seek nor take instructions from any institution or government or from any other body, office or agency, and [refrain] from any act which is incompatible with the nature of their duties" (Art. 16.1).

Beyond this, the Regulation does not provide any meaningful details as to the way the Committee should work. According to Art. 16.2, the Committee adopt its own rules of procedure, and, in line with those rules, chooses its Chair from its ranks. Finally, Parliament provides the Committee with an independent secretariat and funding.

How is the Committee of Independent Eminent Persons nominated?

The Committee is composed of six experts, with each of the three main institutions appointing two experts on the Committee "on the basis of their personal and professional qualities" (Art. 16.1).

The Regulation comprises exclusionary criteria to hedge against conflicts of interests: experts cannot be members of the European Parliament, of the Council or of the Commission, cannot hold an electoral mandate, and cannot "be officials or other servants of the European Union or be current or former employees" of a European party or a foundation" (Art. 16.1).

Experts are to be appointed "within six months after the end of the first session of the European Parliament following each election to the European Parliament". Terms are non-renewable, meaning appointees cannot continue sitting on the Committee past their term.

In practice, however, the limited visibility and role of European parties and foundations and the absence of verification procedures seem to have rendered appointments to the Committee a rather low priority for the institutions, leading to extensive delays.

For instance, while Parliament appointed its experts four days before the deadline following the 2024 elections (but it notified the APPF past the deadline), the previous appointment had taken place three months too late. Conversely, while the Council nominated its 2019 experts 25 days before the deadline, its 2024 experts were appointed four months past the deadline.

But the serious offender remains the European Commission which, as of 4 August 2026, still hasn't officially appointed its 2024 experts — over a year and a half too late.

And time is now running out. Assuming there are no undue delays, Parliament's vote on 7 July puts the APPF's referral of the matter to the Committee around 7-10 August, or within a few days. The Commission's appointment is therefore not only extremely late under the Regulation, but right down to the wire with regard to the current process.

Note: the same now also applies to Parliament, as it seeks to fill its unexpected vacancy.

And yet, this remains a far cry from the previous parliamentary term. In 2019, Parliament's constitutive session ended on 4 July, meaning appointments were due by 4 January 2020. Meanwhile, the Commission appointed its experts on 2 October 2023, or 3 years and 9 months too late, and only 8 months before the next elections to the European Parliament.

Who is represented on the Committee?

Institutions have so far only appointed two slates of candidates, so it remains early to draw clear conclusions on the profiles of those selected. Furthermore, given that the appointment letters only contain experts' names, that the APPF does not publish any additional information, and that there is very limited online information on a Committee that has never met, it is sometimes difficult to accurately ascertain the identify of appointees holding commonplace names.

From a gender perspective, the Committee shows strict gender parity. For the 2024 batch, all three institutions appointed gender-diverse tickets. In 2019, by contrast, the Commission's appointment of two women offset the appointment of two men by the Council; since the Commission's appointments took place after the Council's, this may have been a wilful move to ensure the Committee's gender balance.

Given the limited number of appointees, a geographical distribution by member state remains of limited statistic relevance, and is better carried at the subregional level, using the geographical categorisation used for the GRELO2024 study.

In absolute numbers, Western Europe is by far the most represented region, with 5 experts out of 12, or close to 42%. Eastern and Southern Europe follow with 25% and 17% respectively, while Northern and Central Europe trail with a single nomination each (8%).

Pondering by subregional number of member states, Western and Eastern Europe maintain their lead with 34% and 24% respectively, Northern and Southern Europe follow with 16% each, and Central Europe continues to lag under 10%.

Finally, pondering by subregional population, Northern and Eastern Europe take the lead with 28% and 27% respectively; Central Europe edged forward with close to 20%, followed by Western Europe under 16%, and Southern Europe under 10%. Overall, 10 member states out of 27 have seen one or more of their nationals sit on the Committee.

Finally, let us have a look at experts' backgrounds. Overall, beyond the guardrails mentioned above, European institutions are free to choose whomever they please. In the verification architecture, the Committee sits between the legal expertise of the APPF, alone empowered to decide on deregistration, and the political legitimacy of elected representatives in Parliament and in the Council, both able to veto the APPF's decision. Experts purposefully sit outside of institutions and political bodies (at least, at the time of their appointment), and are selected both for their "personal and professional qualities" (Art. 16.1). Of course, this does not prevent political nominations, such as of former MEPs or political advisors.

The Commission displays a unique tendency to appoint from within its pool of former staff members. With the exception of Kolinda Grabar-kitarović, former President and Minister for Europe of Croatia appointed for the 2019 slate, the Commission's appointees include a former Director-General of DG JUST, a former Director-General for Education, Youth, Sport and Culture, and a former Secretary-General and advisor to several Commission presidents.

The European Parliament seemed to share that inclination with the appointment, for its 2019 batch, of a former MEP and of a former Director of Relations with National Parliaments at the European Parliament and Head for Cabinet for EP President Josep Borrell. In 2024, it turned instead to a Spanish political advisor and head of a political foundation, and to a professor at the Institute of European Studies at the University of Wrocław, Poland.

This last appointment is more in line with the Council's track record, with four appointments from European universities, focusing on public law or European affairs — so far exclusively from Germany and Lithuania.

Notably absent from the Committee are civil society representatives. Given the Committee's role in assessing the compatibility with EU values of public statements and behaviours of parties and their representatives, as well as whether entities breached data protection rules to influence elections, experts working on European parties, the strengthening of democracy, transparency, or integrity in politics would bring useful expertise to the Committee's decision-making.

∞

Overall, the APPF's Committee of Independent Eminent Persons remains a rather new and obscure entity. However, the consecutive expansions of its mandate are likely to grant it a more important and visible, starting in the coming days. In line with sound democratic practices, this increase in relevance should translate into more attention and visibility for the Committee's composition and members.