On 13 May 2026, four days before the International Day Against Homophobia, Transphobia and Biphobia, the European Commission adopted a formal Communication in response to the European Citizens’ Initiative “Ban on conversion practices in the European Union.” The response is a moment for CTOE to reflect and to scrutinise and criticize the structural limits of citizen participation in the European Union’s agenda.
What ACT achieved is extraordinary. The ECI collected over 1,2 millions verified signatures reaching one million in under ten days and met the required levels in eleven Member States. This campaign demonstrated that horizontal democracy, the capacity of citizens to connect, organise and make themselves heard across borders is still alive and quite strong.
The European Commission’s response, however, doesn’t match the level of commitment and energy poured by citizens into this initiative. What the Commission committed to is a non-binding Recommendation, to be adopted by 2027. It will not propose any EU binding legislation, nor will it classify conversion practices as “euro-crimes” – all measures that the ECI explicitly called for, and that the European Parliament’s plenary endorsed in March 2026 and further supported. in April 2026, when MEPs adopted a report on the situation of fundamental rights in the EU, which officially urged the European Commission to propose a legal ban on conversion practices across all Member States. The Parliament position has been clear: it stands with the citizens who signed this initiative. The Commission’s choice to ignore that alignment, it is a political position, and it places the Commission in open tension with both the democratic mandate expressed by over one million citizens and the position of the directly elected institution of the European Union.
What the Commission offers is not law. A recommendation has no enforcement mechanism, no sanctions and no timeline beyond 2027. It leaves 19 EU countries still without a legal ban on conversion therapy. A value-based Union should uplift its Members, not being dragged down by conservatism.
The ACT campaign is a case study for the broader paradox of the European Citizens’ Initiative as a democratic instrument. Since the ECI was introduced with the Lisbon Treaty and powered in April 2012, 128 initiatives have been registered. The response to ACT constitutes the 13th formal European Commission response to an ECI. Not a single one has resulted in legislation fully satisfying its requests. ECIs have led to partial victories: a Recommendation, a study, an awareness campaign. At worst, they have met delay, or institutional dismissal.
The ECI was designed to be a “transnational instrument of participatory democracy”, a tool for citizens to place issues directly onto the EU’s legislative agenda. In reality, the Commission has full discretion over whether and how to act. The ECI creates an obligation to respond, but it does not create an obligation to legislate. What the tool produces is just mobilisation without mandate.
There is a systemic problem in participatory democracy when the mechanism of participation is systematically disconnected from a binding outcome. Citizens are called to mobilise, use their time and pour in their hope and then they are being told that the institution was never obliged to do what they asked. This asymmetry is not neutral, it is a structural problem.
No protection for campaigners
Another problematic aspect that comes out from this democratic tool and not spoken about is the personal cost borne by those who lead the campaigns and the absence of institutional protection for those who do. ACT’s campaigners and the LGBTIQ+ individuals and activists who made this ECI possible did not operate from a position of safety. The communities affected by conversion practices are also among those most exposed to harassment and violence. The ECI process does not protect organisers from the online abuse, the intimidation, or the hostility that campaigns of this nature attract, particularly when they touch issues of sexual orientation and gender identity in a polarised political environment. The Commission does not offer protection or safety, just a symbolic solidarity.
The European Parliament, and now the Commission, have all expressed their support for ACT’s campaign. But words from institutions are not the same as the protection those institutions own to civil society actors that are working to make these values come true. The Union of Equality must be more than just a slogan. It must translate into enforceable rights and into laws and not just recommendations, to ensure LGBTIQ+ people across all twenty-seven Member States are protected.
The Commission’s response of 13 May 2026 is a step, and steps matter. But they are not enough. While the ACT campaign demonstrated the strength of transnational civic mobilisation and the demand for protections against conversion practices across the European Union, we as CTOE are not satisfied with the solution proposed by the Commission and neither with the structural limits of the European Citizens Initiative. A mechanism which mobilises millions of citizens yet isn’t followed up by binding legislative action, which poses risks of weakening democratic trust and participation. The Commission’s justification for not proposing binding legislation, the risk of non-unanimity among Member States does not uphold to scrutiny.
As Niccolò Milanese, European Alternatives Director, states: “The European Commission needs to have the courage to lead the argument for binding legislation on issues which affect Europeans deeply. The Commission says it accepts that conversion therapy is torture, but it lacks the determination to take the argument to those member states that still permit it. The legislative process works like that: the Commission proposes, then Parliament and Council debate. If the Commission refuses to play this role because it is scared that not everyone will agree, it is failing in its responsibilities towards European citizens. The need to find unanimity cannot be an excuse for not trying.”