EU agencies play a central role by implementing EU policies and providing technical, scientific, and legal expertise across key sectors. Any perception that their public servants pursue private interests that conflict with their duties can undermine public trust in their work. The European Ombudsman has consistently highlighted the risks of the “revolving door” phenomenon - where staff move to external roles, particularly in the private sector. Even a small number of high-profile cases can trigger public disquiet and reputational damage, as reflected in recent inquiries.

At the same time, the EU administration must attract skilled professionals to address priorities such as sustainability, digitalisation, and security. Measures such as cooling-off periods and job restrictions can affect career flexibility, especially in fields like law, finance or technology.

Against this background, this inquiry examined, from a systemic point of view, how EU agencies handle revolving door cases. The aim was to identify good practices and possible shortcomings in the policies and practices in place. To this end, the Ombudsman conducted a detailed review of the policies put in place by 15 EU agencies and inspected 54 files on individual cases dealt with by nine EU agencies. The Ombudsman inquiry team met with representatives of five EU agencies to clarify outstanding matters.

Almost all EU agencies that submitted documentation to the Ombudsman said that they had adopted the European Commission’s approach to implementing the legal obligations of staff transitioning to private-sector roles, whether upon departure or during unpaid leave. However, the Ombudsman found that some EU agencies have more detailed and comprehensive guidance on the implementation of these legal obligations than others. Differences that the Ombudsman identified concern how agencies deal with late or incomplete notifications of post-service activities, how agencies assess such notifications, the nature of the mitigating measures imposed, the transparency of decisions on notified post-service activities and how any obligations arising from them are monitored, as well as how agencies train staff on their ethics obligations.

Furthermore, the Ombudsman found that the rules and policies governing the post-mandate activities of non-staff, that is, members of the agencies’ Management Boards or Boards of Supervisors, differ markedly. Most agencies’ Board members are appointed by national authorities and represent their respective Member States, meaning that they remain subject to national ethics rules, which vary across Member States. To address potential conflicts of interest and reputational damage arising from revolving door moves, only a few of the governing bodies from the EU agencies examined in this inquiry have adopted policies regulating post-mandate activities of (former) Board members.

To assist EU agencies in further strengthening their rules on revolving door moves, the Ombudsman set out a series of good practice guidelines:

• A strong integrity framework begins with prevention: equipping staff and Board members with clear guidance, regular training, and ongoing awareness initiatives to ensure full understanding of ethical obligations is essential.
• This is reinforced by robust standard operating procedures for handling revolving door situations, which provide a clear, step-by-step approach to notifications, assessments, and compliance.
• Transparent criteria for restricting post-service or post-mandate roles must be established upfront, so that individuals are fully aware of limitations before joining.
• When a move to the private sector is signalled, agencies should act swiftly - by conducting thorough risk assessments, identifying potential conflicts of interest, and taking immediate precautionary steps such as revoking access rights or reassigning responsibilities where necessary.
• Decision-making should be fair, transparent, and well-documented, allowing individuals to comment on proposed restrictions while ensuring that risks are effectively managed through proportionate measures such as cooling-off periods, lobbying bans or, where needed, outright prohibitions.
• Timely, reasoned decisions must clearly outline rights of appeal.
• Beyond thorough decision-making, accountability depends on strong enforcement. This includes publishing summaries of authorised activities, actively monitoring compliance with imposed conditions, and upholding confidentiality obligations.
• Where breaches are suspected, agencies must respond promptly - establishing the facts, and pursuing disciplinary action in serious cases - to maintain trust and safeguard institutional integrity.

The Ombudsman concludes that EU agencies can learn a lot from each other’s practices. The Ombudsman intends to apply these good practice guidelines to cases that may be brought to her attention in the future.

The case concerned how the EU Agency for Law Enforcement Cooperation (Europol) dealt with the moves of two of its former staff members to Thorn (a private entity developing AI-based software solutions to detect child sexual abuse material online) while the EU was considering adopting rules on the matter. The complainant raised concerns about potential conflicts of interest with the moves.

The Ombudsman found that how Europol had dealt with the move of one staff member to the private sector amounted to maladministration. However, in the course of the inquiry, Europol indicated its willingness to revise its existing processes. The Ombudsman welcomed this, and asked Europol to report back, within six months, indicating how the revision addresses the shortcomings identified in this inquiry.

The case concerned the move of a former vice-president (former VP) of the European Investment Bank (EIB), who was also chair of the European Investment Fund (EIF), to become the chief executive officer (CEO) of the ‘national promotional bank’ in Italy, his Member State of origin.

National promotional banks act as financial intermediaries between the EIB Group and small scale projects that benefit from EIB Group investments. As such, the complainant was concerned that the former VP’s move raised conflict of interest risks.

The Ombudsman inquired into the issue and found that, weeks before the former VP was appointed as CEO of the national promotional bank, he participated in approving financing agreements between both the EIB and the EIF and the national promotional bank in Italy. This occurred despite the fact that the EIB chief compliance officer had advised that he should abstain from any business with the national promotional bank while his appointment procedure to that bank was underway. The chief compliance officer referred to a related decision of the EIB’s ethics and compliance committee (ECC) in 2018.

Against this background, the Ombudsman took the view that how the EIB dealt with the risks of conflicts of interest was inadequate, and constituted maladministration. To address this, the Ombudsman proposes that the EIB strengthen the ECC’s role in relation to intended post-mandate activities of (former) EIB management committee members, including where the post-mandate activities are with an entity defined as having a public service capacity. Specifically, the ECC should be in a position to impose measures to mitigate any risks of conflicts of interest that are identified. The Ombudsman also proposed that the EIB make ECC decisions public shortly after they are adopted, to improve monitoring and enforcement of the compliance with conditions imposed by the ECC on post-mandate activities of former management committee members. The Ombudsman is confident that with these improvements, the EIB can avoid similar issues arising in future.

As the EU is increasingly entrusted with greater powers in areas from defence to healthcare, public trust in the administration is essential. Any perception that public servants pursue private interests that conflict with their public work is therefore highly damaging. The European Ombudsman has long identified the ‘revolving doors’ phenomenon as one that can damage public trust if not adequately managed. Even a small number of high profile moves can generate significant public disquiet and cause reputational damage. This strategic inquiry looked at 100 European Commission ‘revolving door’ files to identify areas for improvement and to guide the rest of the EU administration for the future.

The Ombudsman’s inquiry found genuine improvements since she had last examined the issue, including guidance on how to conduct more rigorous examinations of each move.

That said, in some instances, the Commission approved requests from former senior staff members to take up activities, despite reservations as to whether the conditions imposed on the moves would mitigate the potential risks (such as conflicts of interest and access to knowledge or contacts within the administration). The Ombudsman believes that such moves should be authorised only where the activity can be made subject to restrictions that adequately mitigate the risks and which can credibly be monitored and enforced.

Where such restrictions and enforcement are not possible, the Commission should temporarily forbid former staff members from taking up the intended jobs. Not doing so risks underestimating the corrosive effects over time of having such officials bring their knowledge and networks to related areas in the private sector, and the related reputational damage to the EU.

When approving an activity with mitigating measures, the Commission should explore the full range of measures available. For instance, the Commission could make its approval of a new job conditional upon the staff member obtaining a commitment from the new employer that the restrictions imposed by the Commission are made public on the new employer’s website. As a minimum, the Commission should require the (former) staff member to submit evidence that the restrictions imposed were shared with the new employer.

The difficulties encountered by the Commission in monitoring compliance led the Ombudsman to reiterate her suggestion that the Commission makes public in a more timely way information on all post-service activities of senior former staff members that it assesses. This would improve public scrutiny of these decisions, which is essential for monitoring purposes.

The European Ombudsman has long identified ‘revolving doors’, whereby public officials move to the private sector, as a phenomenon that can potentially damage public trust if not managed properly.

This own-initiative inquiry sought to look at how the European Central Bank (ECB) deals with revolving door moves of its staff members.

Given the ECB's role in ensuring price stability and supervising financial and credit institutions, any moves by (former) ECB staff members to private financial or credit institutions, in particular those that fall under the ECB’s supervision, can pose conflict of interest and reputational risks, and cause public disquiet.

The Ombudsman’s inquiry assessed one specific case, which had raised public concerns, and also reviewed 26 cases of requests by staff members to take up occupational activities, either while on unpaid leave or after finishing work with the ECB. In all but one of the files reviewed ECB staff members moved to the private sector, including entities and banks that are under ECB supervision.

The Ombudsman concluded that the ECB should apply a more robust approach in relation to revolving door moves of its (former) middle ranking and senior staff to private sector jobs, in particular in the financial industry.

To address shortcomings that arose in the individual case and more generally in how the ECB tackles this challenge, the Ombudsman set out a series of suggestions on how the ECB can strengthen its rules, including in the context of the ongoing revision of the ECB’s Ethics Framework.

Specifically, the ECB should widen the scope of those staff who are subject to stricter notification and/or cooling-off requirements or opt for a general minimum requirement for all staff akin to the provisions of the EU Staff Regulations related to post-service occupational activities.

The ECB should also lengthen, from six months to one year, the prohibition on former senior ECB staff members lobbying their former colleagues.

The ECB should further improve its monitoring of the compliance of (former) staff members with their ethics obligations and conditions imposed by the ECB, for example by making public the conditions for authorising the post-employment activities of former senior staff members so that alleged breaches can be flagged.

The Ombudsman furthermore suggested that, where the ECB considers that a request from a staff member to take up an occupational activity while on unpaid leave poses risks that cannot be adequately mitigated by restrictions or when restrictions cannot be effectively monitored or enforced, it should not authorise such a request.

 

The case concerned the decision of the European Investment Bank to approve a request made by a former vice-president and member of its Management Committee (MC) (the ‘former VP’) to become a non-executive board member of a Spanish energy utility company, which received loans from the EIB.

The complainants, two Members of the European Parliament, raised concerns that the move gave rise to the risk of conflicts of interest. The EIB argued that the former VP had not been involved in the negotiation and implementation of the financing agreements between the EIB and the company.

The Ombudsman found that, in approving the move, the EIB did not properly manage the risk of conflicts of interest to which the former VP’s request arguably gave rise. However, given the EIB has, in the meantime, made improvements to the relevant ethics rules to address these matters, the Ombudsman determined that no further inquiries were justified.

Nonetheless, the Ombudsman made suggestions for improvement with a view to strengthening how the EIB assesses ‘revolving door’ moves by members of its MC to the private sector, and how it ensures compliance where its Ethics and Compliance Committee authorises a move but applies conditions on the individual and their activities.