Combating violence against women and domestic violence
78 submissions from 71 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 884 submissions on this file. Shown here: the 78 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
CommitteeFEMM
Published in the Official Journal · 24 May 2024
Signed · 14 May 2024
Approval of the EP's first reading position by the Council (adoption of the legislative act) · 7 May 2024
Discussions within the Council or its preparatory bodies · 30 Apr 2024
Discussions within the Council or its preparatory bodies · 26 Apr 2024
Who showed up
5 submissions from industry — companies and their trade associations — against 70 from civil society: NGOs, consumer organizations, environmental groups and trade unions.
Industry 5Civil society 70Public authorities, academia, other 3
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
18 of 71
in the EU Register
71
full-time lobbying staff
€4.2M+
declared costs a year
31
EP accreditations declared
Self-declared to the EU Transparency Register (snapshot 2 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 18 May 2022 — it ran from 23 Mar 2022.
The Fédération Nationale Solidarité Femmes (FNSF) is a network of 73 associations specialising in supporting women victims of gender-based violence in the reception and accommodation centre. It has created and manages the national listening line 3919 Violences Women Info. 1.
Filed in French · English published by the European Commission
Feedback by SekswerkExpertise Netherlands, Dutch platform to advance the rights of sex workers The Dutch association SekswerkExpertise is a network of over 40 (former) sex workers, social workers, health professionals, psychologists, academics, researchers, jurists and other experts on prostitution and human trafficking.
The Fédération Nationale Solidarité Femmes (FNSF) is a network of 73 associations specialising in supporting women victims of gender-based violence in the reception and accommodation centre. It has created and manages the national listening line 3919 Violences Women Info. 1.
Filed in French · English published by the European Commission
OII Europe highly welcomes the Commission’s proposal, as it addresses the widespread inequity still prevalent in our societies of which gender-based and domestic violence and the specific vulnerability of women and sex and gender minorities are one of the most horrifying aspects.
We support the statement by WAVE (05/18/2022) and repeat the demands formulated there: 1. Include in the Directive a comprehensive whole-of-society approach to preventing GBV against Women and Girls. 2. Root the EU Directive on a rights-based approach instead of a needs-based approach and make the Directive’s articles gender-responsive/transforming 3.
Autonomous Women’s House Zagreb – women against violence against women (AWHZ) is a women-led non-profit NGO whose mission is to provide support and help to women who have survived intimate partner and domestic violence and to empower women’s position in the society.
The focus of the directive is to criminalise GBV. While this gives a strong signal that GBV is unacceptable in the European Union, it is an insufficient tool to combat violence and to protect victims, as the title of the draft directive promises. Criminalisation is not a solution that actually works, and it is not cost-efficient (see attachment). What does work and what is cost-efficient is prevention, i.e.
In the past years, throughout Europe, violence against lesbians has increased as shown by EL*C Report on “Lesbophobia as an intersectional form of violence” (https://europeanlesbianconference.org/wp-content/uploads/2021/10/Lesbophobia-3.pdf), compiled in collaboration with EL*C member organisations and summarising 5 years of research on this field.
TGEU welcomes the legislative initiative to combat violence against women and domestic violence. Such violence, especially against marginalised communities including trans people is widespread and devastating and increased during the pandemic. TGEU welcomes the comprehensive approach to providing specialised support to victims of violence, including training of professionals and staff providing support services.
1. On behalf of association Vilnius Women’s House we call for serious reconsideration and improvement of draft version of the Directive. Together with the WAVE we highly recommend the holistic approach to combating violence against women, that means the victim/survivor centered approach.
Centre for Women War Victims - ROSA believes that the proposed Directive will contribute towards the eradication of violence against women and girls. Experiences of women survivors in Croatia confirm the fact that 1 in 3 of women in Europe are affected by physical and/or sexual violence.
Since 1991, the PRO support centre is an organisation that provides low-threshold support and counselling for sex workers and victims of trafficking in human beings. We consider it important to make gender-based violence subject to specific regulation (more inclusive treatment, gender diversity). In our work we have seen that sex workers are at increased risk of becoming victims of gender-based violence.
Filed in Finnish · English published by the European Commission
The EU Dog & Cat Alliance urges the European Commission to acknowledge in the proposed Directive the barrier that pets can represent for people escaping domestic abuse so that this is taken into consideration in EU Member States’ efforts to protect people experiencing domestic abuse.
On 8 March 2022, the European Commission published a proposal for an EU Directive on combating violence against women and domestic violence, aiming to support and protect victims/survivors, guarantee access to justice, and hold offenders to account.
Ingka Group welcomes the proposal of a Directive on combating violence against women and domestic violence. We believe leading companies must take responsibility and utilise their resources to raise awareness and tackle issues that affect employees and customers alike.
The European Sex Workers’ Rights Alliance (ESWA) welcomes the proposal of the Directive. In particular, ESWA applauds that attention is paid to the recognition that victims face heightened risk due to intersecting forms of discrimination and in particular for recognizing that undocumented migrant women and women sex workers are at increased risk of violence against women (VAW) and domestic violence (DV), and require…
We welcome this Proposal for a Directive to combat violence against women and domestic violence, and believe this draft Directive addresses a number of key concerns for the elimination of gender-based violence and the achievement of gender equality.
1. Keep sex workers included in the Article 35! Listing sex workers as a group with specific needs and at increased risk of gender based violence in the Directive can improve the position of sex workers as victims in Europe.
The Directive includes measures rendering existing protection provisions more efficient enhancing victims’ rights on EU level. Indicatively the significant: a) the capacity of national equality bodies to have legal standing to act on behalf of victims of violence in judicial proceedings; b) visits of a child with a domestic violence offender holding parental responsibility must take place at supervised neutral…
The European Forum for Restorative Justice (EFRJ) highly welcomes and supports the proposed Directive on violence against women and domestic violence (VAW). It is a very important step forward in preventing such crimes, to strengthen victims’ access to justice and to support their appropriate protection throughout the EU.
The End FGM European Network (End FGM EU) represents 32 organisations across 15 European countries. End FGM EU strongly welcomes the first ever Proposal for a Directive to combat violence against women and domestic violence. This is a key milestone in the EU’s battle against gender-based violence, for victims support and the achievement of gender equality.
We have three main demands, which can be retrieved in a longer form in the attached document: Keeping sex workers included in Article 35: Listing sex workers as a group with specific needs and at increased risk of gender based violence in the Directive can improve the position of sex workers as victims in the entire EU. We however, expect a backlash against mentioning sex workers in the Art. 35.
IPPF EN very much welcomes the first ever proposed EU law to combat violence against women and domestic violence. This draft Directive proposes a wide range of crucial measures to combat violence at all stages, from prevention to prosecution. The Directive will help protect women and girls in the EU from forms of violence that affect them disproportionately.
PICUM welcomes the Commission’s proposal on combatting violence against women and domestic violence. We welcome the recognition of the multifaceted and intersectional realities of gender-based violence and the strong focus on the provision of support services to victims.
The European Disability Forum (EDF) welcomes the proposal of a Directive on combating violence against women and domestic violence which comes as a first step to fill significant legislative gaps on violence against women and girls across the EU. We also welcome the inclusion of women and girls with disabilities in the proposal.
The European Women’s Lobby (EWL) recognises that this Directive proposal is a historic landmark and that it fills significant legislative gaps on violence against women and girls (VAWG) across the EU, especially on the legal definition of rape, the recognition of female genital mutilation as a criminal offence and the prosecution of key forms of online violence.
EL*C welcomes the initiative of the European Commission to tackle the lack of specific legal instruments addressing gender based violence and domestic violence at EU level. In order to tackle completely this phenomena and in line with the intersectionality approach chosen by the Commission in its Gender Equality Strategy, it is particularly important to take into consideration the specific positions of…
• Article 82(2) and Article 83(1) TFEU cannot be legal basis for taking legislative action by the EU in order to unify substantive criminal law of Member States. Furthermore, in practice, the planned imposition of unified definitions of crimes on Member States would be a violation of the treaty rule provided for in Article 67(1) TFEU.
women@thewell welcomes this opportunity to engage with the European Commission inception impact assessment proposal for a legislative initiative on preventing and combatting gender-based violence and domestic violence. women@thewell is a women-only frontline service located in Kings Cross, London, dedicated to supporting women whose lives are affected by or at risk of being affected by prostitution to exit.
NANE Women’s Rights Association and our partner PATENT (People Opposing Patriarchy) Association – NGOs with decades of experience in responding to violence against women (VAW) – welcome the European Commission’s current initiative.
Response of the Greek League for Women’s Rights to the Commission’s public consultation on its initiative «Combating gender-based violence – protecting victims and punishing offenders» Athens, 12 January 2021 The Greek League for Women’s Rights (GLWR), the first exclusively feminist organisation in Greece, established in 1920, and having always among its priorities the elimination of all forms of violence against…
ICRSE welcomes the possibility to provide feedback to the European Commission’s public consultation on Gender-based and domestic violence. We would like to take up this opportunity and provide recommendations based on our 15 years of experience and cooperation with sex worker-led organisations working at local and national levels.
Asociación La Sur – Feminicidio.net welcomes this opportunity to engage with the European Commission inception impact assessment proposal for a legislative initiative on preventing and combatting gender-based violence and domestic violence.
The Collectif Féministe Contre le Viol (CFCV) welcomes this opportunity to engage with the European Commission’s proposal for an initial impact assessment for a legislative initiative on preventing and combating gender-based violence and domestic violence.
Filed in French · English published by the European Commission
The Portuguese Platform for Women’s Rights welcomes this opportunity to engage with the European Commission inception impact assessment proposal for a legislative initiative on preventing and combating male violence against women and girls and domestic violence. The Portuguese Platform for Women’s Rights is the biggest umbrella-organization of women’s rights NGOs in Portugal with 29 member organizations.
The EOS – Association for Studies, Cooperation and Development welcomes this opportunity to engage with the European Commission inception impact assessment proposal for a legislative initiative on preventing and combatting gender-based violence and domestic violence.
PICUM is a network of 167 organisations that has worked for nearly twenty years to advance the rights and improve the situation of people who are undocumented across a variety of areas, including access to health care, access to justice, the rights of undocumented workers, labour migration, the rights of children, families and youth, as well as fundamental rights in the context of immigration detention and return.
Recognizing that Violence against women is a widespread human rights violation in EU Region Recognizing that “domestic violence is a significant problem during COVID-19 related lockdown. Most domestic violence occurs within the home, thus, requiring people to stay at home to avoid COVID-19 transmission unsurprisingly led to increased rates of violence.”in “The gendered impact of the COVID-19 crisis and post-crisis…
Transgender Europe (TGEU) welcomes the European Commission’s initiative to provide uniform standards for preventing gender-based and domestic violence and thereby work towards the EU accession to the Istanbul Convention. With regards to the options presented in the inception impact assessment, TGEU strongly supports option 3 with its holistic approach to end gender-based violence and domestic violence.
The Fondation Scelles welcomes this opportunity to engage with the European Commission inception impact assessment proposal for a legislative initiative on preventing and combatting gender-based violence and domestic violence. The Fondation Scelles is an independent, non-profit organisation, recognized of public utility, with a special consultative status with ECOSOC.
Victim Support Europe (VSE) supports the Commission’s recognition of the importance of standing up for victims of all crimes in general, and victims of GBV and DV in particular. In their future response, we invite the EU to: • Ensure the full and effective implementation of the existing EU legislation and policy instruments, in particular the Victims’ Rights Directive, the Victims’ Rights Strategy and the Gender…
Gender-based and domestic violence are serious crimes that can cause long term physical, psychological and social harm to the victim. Lumos therefore welcomes the European Commission’s initiative to address the issue of gender-based and domestic violence and to protect victims and punish offenders.
Resistenza Femminista welcomes this opportunity to engage with the European Commission inception impact assessment proposal for a legislative initiative on preventing and combatting gender-based violence and domestic violence.
Fundació Aroa welcomes the European Commission’s (EC) initiative on preventing and combatting gender-based violence and domestic violence. By integrating in EU law the standards of the Istanbul Convention, this initiative will provide legislative outputs of critical importance to ensure women's and girl's rights and could save countless lives, prevent significant trauma and reduce also the socioeconomic impact of…
Associazione Iroko welcomes this opportunity to engage with the European Commission inception impact assessment proposal for a legislative initiative on preventing and combating gender-based violence and domestic violence. Iroko is an Italian-based NGO that has, for over 20 years, campaigned on behalf of and provided assistance to victims/survivors of domestic violence, prostitution, and sex trafficking.
CECIF-ECICW The CECIF (European Centre of the International Women’s Council) federation welcomes the European Commission’s proposal to provide uniform standards for preventing gender-based and domestic violence, protecting victims and punishing offenders.
Filed in French · English published by the European Commission
proFem – center for victims of domestic and sexual violence, NGO based in Prague, Czech Republic, welcomes this initiative. We have been working with victims and survivors of GBV from 1994. In our opinion, holistic legislation is needed in this area.
TERRE DES FEMMES – Menschenrechte für die Frau e.V. welcomes this opportunity to engage with the European Commission inception impact assessment proposal for a legislative initiative on preventing and combatting gender-based violence and domestic violence. TERRE DES FEMMES is a women`s rights NGO based in Berlin, Germany, and this year we celebrate our 40th anniversary.
Creación Positiva is an NGO based in Barcelona that has been working for over 18 years from a gender and intersectional feminist perspective in order to give effect to sexual rights. From our perspective we believe this initiative should include the following: • Take into account that one of the most problematic elements regarding the institutional responses to gender-based violence is institutional violence which…
Equality Now welcomes the EU initiative to provide uniform standards for preventing gender-based violence, protecting victims and punishing offenders Equality Now is an international feminist and human rights organisation working to end violence and discrimination against women and girls across the world.
According to women, the world is a Belgian side active in research, training and advocacy, for over 15 years we have been working with women’s organisations, human rights NGOs, prostitution survivors, development associations and federations and NGOs in Europe, Latin America and French-speaking Africa. To denounce the links between globalisation, prostitution and violence against women.
Filed in French · English published by the European Commission
ILGA-Europe, a regional network fighting for the rights of LGBTI people across Europe and Central Asia with over 600 member organisations in 54 countries, welcome the commitments made by the previous initiatives such as the EU Gender Equality Strategy 2020-2025, the EU LGBTIQ Equality Strategy, the Action Plan on Gender Equality and Women's Empowerment in External Action 2021–2025 (GAP III) and Victims’ Rights…
Terre des Hommes Netherlands welcomes the EU initiative to provide uniform standards for preventing gender-based violence, protecting victims and punishing offenders. We take note of the three proposed policy options. We strongly recommend pursuing and strengthening further the third policy option. Please find attached our feedback to the inception impact assessment.
The Women’s Regards Association appreciates the European Commission’s proposal for an initial impact assessment for a legislative initiative on preventing gender-based violence and domestic violence. Women’s eyes, set up in 1998 under the French law of 1901, are NGOs with the United Nations ECOSOC and OING at the International Organisation of La Francophonie.
Filed in French · English published by the European Commission
Include prostitution and sexual exploitation in legislative action on preventing and combatting gender-based violence and domestic violence. Concerted action at EU level is urgently needed to ensure adequate protection of women’s right to live a life free from violence, no matter where they live in the EU.
Herzwerk welcomes this opportunity to engage with the European Commission inception impact assessment proposal for a legislative initiative on preventing and combatting gender-based violence and domestic violence. As an organization that has worked directly with people in prostitution and survivors of human trafficking in Vienna since 2007, gender-based violence is a very important topic for us.
CIAMS, the International Coalition for the Abolition of the Substitution Maternity, welcomes this opportunity to contribute to the European Commission’s legislative initiative on preventing and combating gender-based violence and domestic violence.
Filed in French · English published by the European Commission
The Hungarian Women’s Lobby (HWL) welcomes this opportunity to engage with the European Commission inception impact assessment proposal for a legislative initiative on preventing and combatting gender-based violence and domestic violence. The Hungarian Women's Lobby is an umbrella organisation of 20 Hungarian human rights based women’s NGOs, established in 2003.
ACF- Association Against Femicide ACF is a Portuguese non-governmental organization, founded in December 2018, working in the field of Gender-Based Violence and Domestic Violence. ACF works actively to prevent and combat femicide, as the most extreme form of GBV women undergo. Our mission is to support the families of the victims of this heinous crime and accompany them through the healing process.
In Catalonia, on 12/24/20, the reform of the 2008 Gender Violence Law was approved. This reform makes it a benchmark law and an example of good practice. The reform incorporates in the Law a new definition of sexual violence, institutional violence against women, harm to children and pets as form of gender violence, violence against women politicians, digital gender violence, and the need for government…
EU DisinfoLab is an independent non-profit organisation focused on tackling sophisticated disinformation campaigns and documenting the disinformation phenomenon in Europe. Beyond our research, we aim to serve as a gathering place for experts and organisations to exchange best practices, cooperate, and develop new approaches to countering disinformation and misinformation.
Summary of the contribution by the Netherlands Institute for Human Rights. As the Inception impact assessment reiterates, gender-based violence and domestic violence remain common in all EU Member States. This holds true also for the Netherlands, as was pointed out in, among others, the GREVIO baseline evaluation published in January 2020.
Succeeding in gender equality (REFH) welcomes this opportunity to contribute to the European Commission’s legislative initiative on preventing and combating gender-based violence and domestic violence. REFH aims to alert and act, together, against all forms of discrimination and gender-based violence. The main field of action is nursery education in higher education and research.
Filed in French · English published by the European Commission
Sexual Violence Centre Cork, Ireland has been working with victims of gender-based violence in Ireland for nearly forty years and this work informs our submission to the European Commission. We welcome the opportunity to engage with the Commission on this issue and we urge you to take all steps necessary to end gender-based violence. About Us Sexual Violence Centre Cork is based in Cork, Ireland.
Women against Violence Europe (WAVE) is a network of over 160 women’s NGOs working towards ending violence against women in 46 European countries. The WAVE Network has been working for over 25 years to promote and strengthen the human rights of women and children in general and prevent violence against women and children in particular.
Our equal rights & opportunities observatory works in conjunction with the volunteers’ NGO that has first-hand contact with supposed victims, as well as potential victims. Our experience has demonstrated that many victims shun away from official local social welfare offices, and even more from police stations, especially in small towns and/or urban districts, afraid of being identified by their aggressor and/or…
From our perspective as researchers who are involved with themes such as intimate partner violence and abuse, domestic violence and abuse, and gender, we advise to apply a gendersensitive approach. Furthermore, we advise to not mainly focus on physical and sexual violence but to also include psychological and economic abuse, as these forms of violence have detrimental effects as well, occur frequently, decrease…
The Belgian Federal Observatory on Violence against Women (OFVFF) welcomes the Commission 's initiative to prevent violence against women and prosecute their perpetrators when they have been inflicted. The Istanbul Convention is today the legal instrument on which we can rely to combat all forms of violence against women. An initiative that would lead to a European directive will save lives.
Filed in French · English published by the European Commission
Femmes pour le Dire, Femmes pour Agir (FDFA) based in Paris welcomes this opportunity to engage with the European Commission inception impact assessment proposal for a legislative initiative on preventing and combating gender-based violence and domestic violence. FDFA is an ONG created in 2003 by Maudy Piot to fight against the double discrimination : being a woman and living with a disability.
CAP International welcomes this opportunity to engage with the European Commission inception impact assessment proposal for a legislative initiative on preventing and combatting gender-based violence and domestic violence. Our organisation is a coalition of 33 grassroots NGOs from 26 countries providing direct support and assistance to victims of prostitution.
Kaspersky welcomes the Commission’s approach of asking different stakeholders for feedback about the planned legislative proposal to prevent and combat specific forms of gender-based violence. We are therefore very pleased to provide feedback on the Inception Impact Assessment of the initiative.
It is a profoundly consolidated opinion of AIGA that the phenomenon of gender-based and domestic violence is rooted in the concept, deeply rooted in modern societies, of gender differentiation, and in what has always been conceived as subordination of ‘Women’ to ‘Uomo’.
Filed in Italian · English published by the European Commission
Opinion now deeply consolidated AIGA that the phenomenon of gender violence and domestic violence has its roots in the concept, explained in moderate societies, the difference between genres, and d in which it has been granted as the subordination ‘Woman’ compared to ‘Man’.
Filed in Italian · English published by the European Commission
Women’s lobby of Slovenia welcomes this opportunity to engage with the European Commission inception impact assessment proposal for a legislative initiative on preventing and combatting gender-based violence and domestic violence. Our organisation is the only feminist umbrella organisation in Slovenia, uniting 9 feminist human rights NGOs, out of them 4 are dealing explicitly with violence against women.
Swedish Women of the Left/Svenska Kvinnors Vänsterförbund welcomes this opportunity to engage with the European Commission inception impact assessment proposal for a legislative initiative on preventing and combatting gender-based violence and domestic violence. Our organisation has been active in furthering women’s rights since 1914. To prevent the sexual exploitation of women has been on the agenda all along.
The European Women’s Lobby (EWL) welcomes the European Commission’s (EC) initiative on preventing and combatting gender-based violence and domestic violence. By integrating in EU law the standards of the Istanbul Convention, this initiative is of the utmost importance as resulting legislation could save countless lives and prevent significant trauma and violence in the lives of women and girls across Europe.
As an organization from Germany that supports women who exit prostitution, we want to point to the need to consider ‘trafficking and sexual exploitation of women and children’, as it is named in Article 83.1 Eurocrimes, as a form of violence against women and girls (VAWG) and to take this already listed crime as basis for the new law.
The European Women’s think tank Gender Five Plus, which I have the honour to chair, fully supports the Committee for this initiative, which we have long awaited. Option 3 must be chosen. It corresponds to our analysis in the document “Ending VIOLENCE AGAINST WOMEN THE ISTANBUL CONVENTION AND BEYOND” published on our website at the attached CIU adress…
Filed in French · English published by the European Commission
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.