European Union agencies manage "revolving door" cases differently, warns the European Ombudsman.
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The European Ombudsman warned that EU agencies manage "revolving door" cases inconsistently, following an investigation that covered 15 agencies and led to the publication of a set of best practice guidelines to strengthen the rules regarding conflicts of interest and the transition to the private sector of former employees and members of governing bodies.
In brief
The European Ombudsman analyzed the policies of 15 EU agencies regarding "revolving door" cases and reviewed 54 files from these agencies. The investigation identified significant differences between agencies regarding notifications, mitigation measures, monitoring compliance with conditions, and ethical training of staff. Only seven of the 15 agencies analyzed had rules regarding conflicts of interest arising from the post-mandate activities of board members. Only four of the 15 monitored compliance with restrictions imposed on former staff members regarding post-service activities. The Ombudsman issued best practice guidelines and announced that they would also apply them in future investigations regarding specific "revolving door" cases.
The European Ombudsman, Teresa Anjinho, concluded an ex officio investigation into how EU agencies manage "revolving door" cases, that is, situations where former members of management staff or members of governing bodies move to positions in the private sector after the end of their mandate or activity in the agency. The investigation examined the policies of 15 agencies, included inspections of 54 files from these agencies, and meetings with representatives of five agencies to clarify specific aspects.
The Ombudsman's central finding is that, although some agencies have adopted detailed and comprehensive guidelines, there are significant variations between institutions in key areas. These concern how agencies handle late or incomplete notifications regarding post-service activities, the type and extent of mitigation measures imposed, how compliance with these measures is monitored, and the training provided to staff regarding ethical obligations.
The investigation also highlighted marked differences in the rules governing the post-mandate activities of members of governing bodies, such as members of boards of directors or supervisory boards. The Ombudsman found that only a few of the agencies analyzed had adopted policies to regulate such activities, and the published summary states that seven of the 15 had rules for managing conflicts of interest arising from the post-mandate activities of board members.
Documents published by the institution also show that only four of the 15 agencies monitored compliance with restrictions imposed on former staff members regarding post-service activities. The Ombudsman also identified differences regarding the transparency of decisions made in individual cases and the type of measures used to reduce the risks of conflicts of interest.
Following the investigation, the Ombudsman established two general conclusions. The first is that EU agencies should adopt a robust procedure for assessing notifications made by former senior staff members who wish to take up positions in the private sector close to their former duties. The second is that agencies that do not have an internal policy for preventing conflicts of interest in the case of board members who are not part of the staff should encourage governing bodies to adopt one. These conclusions are reiterated in letters sent to the targeted agencies.
To support a more uniform approach, the Ombudsman adopted a set of best practice guidelines regarding prevention, notification, assessment, mitigation measures, transparency, and compliance monitoring. The guidelines recommend, among other things, the existence of a standard step-by-step procedure, training and regular awareness campaigns, clear criteria for prohibiting or restricting certain post-service functions, rapid response when a transition to the private sector is announced, publication of information about the authorized activities of former senior staff members, and monitoring compliance with imposed conditions.
The guidelines also recommend the use of a wide range of measures, from periods of incompatibility and prohibitions on contact or lobbying, to temporary bans when risks cannot be sufficiently mitigated. For former board members, the Ombudsman proposes notifying post-mandate activities for two years after the end of the mandate and a rapid assessment of risks even before the new activity begins. At the same time, the institution recommends publishing on the agencies' websites information regarding the authorized activities of former senior staff members and former board members.
Teresa Anjinho announced that her office will apply these guidelines in any future investigations regarding specific "revolving door" cases. In the institution's public communication, it is stated that such situations, if not managed properly, risk affecting the integrity of public administration and undermining public trust in the decisions made by the EU administration.
The theme is placed by the Ombudsman in the broader context of transparency and administrative accountability. The annual report for 2025 shows that investigations into transparency and accountability represented 38% of the total, remaining the largest category of investigations. In the same report, the institution explicitly mentions the ex officio investigation into the 15 agencies and the publication of the new guidelines as part of the effort to ensure a uniform approach at the level of European administration.
The 15 agencies analyzed include, among others, the European Union Aviation Safety Agency, the European Chemicals Agency, the European Food Safety Authority, the European Union Agency for Cybersecurity, the European Medicines Agency, the European Banking Authority, the European Insurance and Occupational Pensions Authority, the European Securities and Markets Authority, the European Union Intellectual Property Office, the European Defence Agency, and the Single Resolution Board.
In brief
The European Ombudsman analyzed the policies of 15 EU agencies regarding "revolving door" cases and reviewed 54 files from these agencies. The investigation identified significant differences between agencies regarding notifications, mitigation measures, monitoring compliance with conditions, and ethical training of staff. Only seven of the 15 agencies analyzed had rules regarding conflicts of interest arising from the post-mandate activities of board members. Only four of the 15 monitored compliance with restrictions imposed on former staff members regarding post-service activities. The Ombudsman issued best practice guidelines and announced that they would also apply them in future investigations regarding specific "revolving door" cases.
The European Ombudsman, Teresa Anjinho, concluded an ex officio investigation into how EU agencies manage "revolving door" cases, that is, situations where former members of management staff or members of governing bodies move to positions in the private sector after the end of their mandate or activity in the agency. The investigation examined the policies of 15 agencies, included inspections of 54 files from these agencies, and meetings with representatives of five agencies to clarify specific aspects.
The Ombudsman's central finding is that, although some agencies have adopted detailed and comprehensive guidelines, there are significant variations between institutions in key areas. These concern how agencies handle late or incomplete notifications regarding post-service activities, the type and extent of mitigation measures imposed, how compliance with these measures is monitored, and the training provided to staff regarding ethical obligations.
The investigation also highlighted marked differences in the rules governing the post-mandate activities of members of governing bodies, such as members of boards of directors or supervisory boards. The Ombudsman found that only a few of the agencies analyzed had adopted policies to regulate such activities, and the published summary states that seven of the 15 had rules for managing conflicts of interest arising from the post-mandate activities of board members.
Documents published by the institution also show that only four of the 15 agencies monitored compliance with restrictions imposed on former staff members regarding post-service activities. The Ombudsman also identified differences regarding the transparency of decisions made in individual cases and the type of measures used to reduce the risks of conflicts of interest.
Following the investigation, the Ombudsman established two general conclusions. The first is that EU agencies should adopt a robust procedure for assessing notifications made by former senior staff members who wish to take up positions in the private sector close to their former duties. The second is that agencies that do not have an internal policy for preventing conflicts of interest in the case of board members who are not part of the staff should encourage governing bodies to adopt one. These conclusions are reiterated in letters sent to the targeted agencies.
To support a more uniform approach, the Ombudsman adopted a set of best practice guidelines regarding prevention, notification, assessment, mitigation measures, transparency, and compliance monitoring. The guidelines recommend, among other things, the existence of a standard step-by-step procedure, training and regular awareness campaigns, clear criteria for prohibiting or restricting certain post-service functions, rapid response when a transition to the private sector is announced, publication of information about the authorized activities of former senior staff members, and monitoring compliance with imposed conditions.
The guidelines also recommend the use of a wide range of measures, from periods of incompatibility and prohibitions on contact or lobbying, to temporary bans when risks cannot be sufficiently mitigated. For former board members, the Ombudsman proposes notifying post-mandate activities for two years after the end of the mandate and a rapid assessment of risks even before the new activity begins. At the same time, the institution recommends publishing on the agencies' websites information regarding the authorized activities of former senior staff members and former board members.
Teresa Anjinho announced that her office will apply these guidelines in any future investigations regarding specific "revolving door" cases. In the institution's public communication, it is stated that such situations, if not managed properly, risk affecting the integrity of public administration and undermining public trust in the decisions made by the EU administration.
The theme is placed by the Ombudsman in the broader context of transparency and administrative accountability. The annual report for 2025 shows that investigations into transparency and accountability represented 38% of the total, remaining the largest category of investigations. In the same report, the institution explicitly mentions the ex officio investigation into the 15 agencies and the publication of the new guidelines as part of the effort to ensure a uniform approach at the level of European administration.
The 15 agencies analyzed include, among others, the European Union Aviation Safety Agency, the European Chemicals Agency, the European Food Safety Authority, the European Union Agency for Cybersecurity, the European Medicines Agency, the European Banking Authority, the European Insurance and Occupational Pensions Authority, the European Securities and Markets Authority, the European Union Intellectual Property Office, the European Defence Agency, and the Single Resolution Board.
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