European Ombudswoman Teresa Anjinho has opened an inquiry to examine how the European Commission ensures that its ‘reality checks’ meetings with stakeholders follow transparency requirements for decision-making.

Reality checks are a new consultation tool under which the Commission seeks information directly from stakeholders it has itself identified to learn about any hurdles they face when implementing EU rules.   

The Commission says that as the reality checks are for gathering factual information, data, or expertise they are therefore exempt from the transparency rules that normally govern meetings between the Commission and interest representatives.

The complainant, a civil society organisation, argues that all stages of EU decision making must be covered by meaningful transparency measures.

As a first step in the inquiry, the Ombudswoman has set out a series of questions to the Commission regarding reality checks.

These include how it ensures that such meetings remain within the scope of gathering factual information and do not become broader consultations, which are subject to standard transparency measures applicable to meetings with lobbyists.

The Ombudswoman has also asked the Commission to provide a list of all of the reality checks it carried out in 2025 and 2026, as well as information on how it ensures that business interests do not dominate the discussions, and how it ensures that civil society organisations have timely access to what has been discussed in reality check meetings.  

 She has asked the Commission to reply by 18 September 2026.

Background

Transparency measures for meetings between Commissioners and interest representative, and for meetings between senior Commission staff and interest representative are set out in two Commission Decisions (2024/3081 and 2024/3082).

Article 3 of each decision sets out exemptions from the transparency measures, noting that the decision shall not cover “meetings organised for the purposes of making submissions: in response to direct and specific requests from the Commission, its representatives or staff, for factual information, data or expertise.