The complainants, a group of civil society organisations, were concerned that the European External Action Service (EEAS) does not ensure that EU civilian missions assess human rights risks before providing support to non-EU countries, including the possible transfer of surveillance capabilities. The complainants contended that EU civilian missions should carry out prior risk and impact assessments to ensure that their support does not result in human rights violations.

Based on the inquiry, the Ombudsman found that the ‘human rights due diligence’ process recommended in the EEAS Human Rights Guidelines for all EU civilian mission activities constitutes an acceptable alternative to a standalone human rights impact assessment (HRIA), provided that its methodology is similar to a HRIA. As the Ombudsman identified a number of shortcomings in the EEAS Human Rights Guidelines, she closed the inquiry, making detailed suggestions to address these shortcomings.