Lithuania: a documented cross-border inconsistency affecting a migrant woman human rights defender and a women-led CSO

Case submitted for the Verian study commissioned by the European Parliament Committee on Women’s Rights and Gender Equality (FEMM) on changes in the funding environment for women’s rights civil society organisations in the EU

Purpose of this submission This case is submitted to support inclusion of a documented Lithuanian example in the FEMM study and to identify an EU-level policy gap relevant to the next Multiannual Financial Framework and the Gender Equality Strategy.

 

Executive summary

In 2026, the Lithuanian Erasmus+ National Agency excluded Adliga Women at Risk Solidarity Fund, a women-led Lithuanian legal entity, from an EU funding procedure for a project specifically designed to strengthen the democratic participation, civic confidence and peer leadership of migrant and refugee women in Lithuania. The application requested a total Erasmus+ grant of EUR 11,819 for institutional and methodological capacity-building, including development of the six-module Women Civic Circles Lithuania programme and a planned first full pilot cycle for approximately 20 migrant and refugee women.

The exclusion was not based on fraud, corruption, misuse of EU funds, financial irregularities or an established lack of administrative capacity by Adliga. Instead, the Agency relied on a national-security assessment concerning Adliga’s Belarusian founder and director, Volha Karach, and transferred that personal assessment to the legal entity. The Agency also acknowledged that it had not conducted an individual risk and operational-capacity assessment of Adliga before excluding it.

The case acquires a broader civic-space and gender dimension because the later VSD letter does more than mention Our House and Karach alongside an asylum case. It constructs a single official narrative in which Belarusian asylum seekers are said to use Our House’s public profile and information-dissemination capabilities, and in the same reasoning VSD states that information provided by Karach should be assessed critically and reiterates that she poses a threat to state security. The document identifies no fraud, espionage, corruption, misuse of public funds or other criminal conduct by Our House or Adliga. The concrete organisational conduct described is assistance to asylum seekers through legal procedures, advocacy, visibility and information channels. In Prasanava’s case, Lithuanian authorities themselves recognised a sufficiently real risk of harm in Belarus to engage non-refoulement. The issue is therefore not fabrication of a non-existent danger, but the role of a migrant woman human-rights defender and her organisations in helping people facing recognised risks resist removal and seek protection.

The documented sequence raises a structural question for EU funding policy: can a migration- or security-related assessment of a migrant woman founder follow her into unrelated areas of public administration and become a de facto funding barrier for the women-led civil society organisation she manages, even where no financial wrongdoing by that organisation has been established?

The Lithuanian treatment is also difficult to reconcile with experience elsewhere in the EU funding system. In 2026, Our House is listed as a partner in the Erasmus+ youth project “European Youth Peace Week”, administered through FI01 – Finnish National Agency for Education, with activities running from May to December 2026. The application identifies Our House (OID E10046708) as a Lithuanian partner and includes Belarusian refugees residing in Lithuania among the target participants. The submitting organisation confirms that this forms part of an established cooperation track record with its Finnish partner. This comparison matters because it suggests that the alleged “unmanageable” risk is not inherent in the capacity of Karach or the organisations she leads to participate in EU-funded work; rather, it arises from the way the Lithuanian National Agency has translated a migration-related security assessment into a funding exclusion.

The mechanism in one line

Refugee-rights advocacy

Adverse security-related characterisation

Personal assessment of migrant woman leader

Assessment transferred to women-led legal entity

Exclusion from EU funding

1. Funding exclusion of a project for migrant women

Adliga Women at Risk Solidarity Fund submitted an Erasmus+ application entitled “From Displacement to Democratic Participation: Building Nonviolent Civic Leadership Among Migrant Women in Lithuania”. The Lithuanian National Agency later excluded the organisation from the grant-award procedure. The application requested a total Erasmus+ grant of EUR 11,819. The funding was designed to strengthen Adliga’s institutional and methodological capacity to create and embed Women Civic Circles Lithuania, a six-module programme for migrant and refugee women, with a planned first full pilot cycle involving approximately 20 women. [1]

The National Agency’s reasoning was derived from an earlier national-security assessment concerning Volha Karach as an individual. The Agency expressly treated the individual exclusion/security situation of the organisation’s leader as a basis capable of being transferred to the organisation. [1]

What is absent from the record is equally important. The administrative complaint notes that the decision did not establish that Adliga had misused EU funds, committed financial irregularities, fraud or corruption, breached Erasmus+ rules, failed contractual obligations, or lacked the administrative and financial capacity to implement the project. [2]

The Agency further acknowledged that an individual risk and operational-capacity assessment of Adliga had not been performed because the application had already been rejected at an earlier stage. [3]

Core funding concern The activity attracting adverse security-related attention is not alleged financial misconduct. The documented context is the organisations’ involvement in asylum and legal-status cases, including the case of a Belarusian woman whose right to international protection Our House helped to defend.

 

2. What the VSD letter actually links

The significance of the VSD letter of 7 August 2026 is not merely that it mentions Our House and Volha Karach in the same document as an asylum case. The letter itself constructs a direct narrative connection between the organisation’s assistance to Belarusian asylum seekers, its public and informational capacity, and VSD’s adverse security assessment of Karach.

VSD alleges that Yuliya Prasanava was using activities at Our House in connection with her asylum procedure. It then states that this was “not the first identified case” in which Belarusian asylum seekers allegedly made use of the public profile and information-dissemination capabilities of Our House. In the same reasoning, VSD states that information provided by Volha Karach should be assessed critically and reiterates its conclusion that Karach poses a threat to Lithuanian state security. [6]

This connection is crucial. The VSD letter does not explain what possible relevance Karach’s alleged security threat has to fraud, espionage, corruption, misuse of public funds or the financial integrity of Our House or Adliga. Instead, the concrete conduct it identifies is the organisation’s ability to help Belarusian asylum seekers use legal procedures, public advocacy, information channels and organisational visibility in order to defend themselves against removal from Lithuania.

The concern arising from the document is therefore not simply that a security assessment happens to coexist with refugee-rights work. VSD itself places Karach’s adverse security status inside an official narrative whose substantive subject is the effectiveness of Our House in helping Belarusian asylum seekers defend their legal status. If assistance to people in asylum proceedings has no relationship to why Karach is treated as a security threat, the letter does not explain why these matters are joined in the same official reasoning.

The case of Yuliya Prasanava makes the contradiction particularly stark. Prasanava is a Belarusian woman, mother of six children and an artisan; one of her children is a minor with a disability. Our House assisted her in defending her right to international protection. On 14 January 2026, the Supreme Administrative Court of Lithuania held that the Migration Department had failed to prove that she abused the procedure for granting international protection and ordered the case to be re-examined. [5]

More importantly, the Lithuanian authorities do not maintain that Prasanava faces no danger in Belarus or that Our House fabricated a non-existent protection need. The subsequent Migration Department decision recognised that the risk of harm to her in Belarus was sufficiently real to engage the principle of non-refoulement. [7]

This distinction matters fundamentally. The dispute is not about Our House inventing persecution where none exists. Lithuanian authorities themselves recognise a real risk upon return. The conflict arises around the fact that Our House uses its legal expertise, public profile, advocacy channels and organisational capacity to help people facing that recognised risk resist removal and seek protection.

In the submitting organisations’ assessment, this is why the VSD correspondence is so important for understanding the subsequent funding problem. It provides documentary evidence that the same human-rights activity – helping Belarusian migrants and refugees defend themselves against removal – is being treated as part of an adverse security narrative surrounding both Our House and its director. That adverse personal assessment then moved into a completely different administrative sphere and was used against Adliga Women at Risk Solidarity Fund in an Erasmus+ funding procedure.

If the concern were genuinely that Karach posed a security threat independent of her refugee-rights work, the VSD letter would require an explanation of the security conduct concerned. Instead, the concrete conduct described in the letter is the use by asylum seekers of Our House’s visibility, information channels and advocacy capacity to defend their protection claims.

The document therefore creates an obvious causal question that the Lithuanian authorities have not answered: if Karach’s alleged security threat is unrelated to her and Our House’s effectiveness in protecting Belarusian asylum seekers, why does VSD itself rely on those asylum cases, the organisation’s visibility and its information capacity when reiterating the adverse assessment of Karach?

The people ultimately affected are migrant and refugee women

The immediate administrative target of the funding exclusion was Adliga. The substantive impact, however, falls on migrant and refugee women in Lithuania.

Adliga’s Erasmus+ application was explicitly designed around women in vulnerable and crisis situations, particularly migrant and refugee women from Belarus, Ukraine and Russia living in Lithuania. The application identifies displacement, insecure legal status, trauma, language barriers, economic precarity, social isolation, disrupted careers and childcare responsibilities as barriers faced by these women.

The organisation sought Erasmus+ capacity-building precisely because its existing experience was not yet sufficiently systematised to provide these women with a sustainable, trauma-informed civic-education programme. The application requested a total grant of EUR 11,819 to strengthen staff competences and institutional capacity, create the six-module Women Civic Circles Lithuania model, develop a Facilitation Guide, introduce quality-assurance methods and support implementation of a first full pilot cycle expected to involve approximately 20 migrant and refugee women.

The funding exclusion therefore affects women twice. First, a migrant woman human-rights defender is subjected to an additional migration/security vulnerability that a Lithuanian citizen heading an equivalent organisation would not face. Second, the resulting exclusion weakens the institutional capacity of a women-led organisation whose beneficiaries are themselves migrant and refugee women.

The mechanism is therefore: human-rights assistance to migrants and refugees -> adverse security characterisation of a migrant woman defender -> personal assessment transferred to a women-led organisation -> exclusion from Erasmus+ capacity-building -> weaker institutional capacity -> reduced ability to provide structured support to migrant and refugee women in Lithuania.

A gendered and intersectional funding barrier

This case illustrates an intersectional funding barrier rather than a conventional funding cut.

Adliga is women-led. Its founder and director is herself a migrant woman and woman human-rights defender. Its principal constituency includes migrant and refugee women. The excluded Erasmus+ project was specifically designed to strengthen the organisation’s ability to support the democratic participation, civic confidence and peer leadership of those women.

Gender, migrant status, third-country-national status, human-rights-defender status and organisational leadership therefore intersect at several levels.

A Lithuanian citizen leading an otherwise identical organisation cannot face the same structural vulnerability arising from the possibility that her right to remain in Lithuania may be questioned and then converted into a supposed financial risk for the organisation.

This creates a structural asymmetry between citizen-led and migrant-led women’s rights organisations. Both may be formally eligible for EU funding, but only the migrant-led organisation can have the migration status of its director transformed into an alleged organisational financial-risk factor.

The asymmetry is particularly striking here because Karach’s residence permit was subsequently renewed without restriction and she continues to reside lawfully in Lithuania.

This raises a fundamental question for the next Multiannual Financial Framework: Is formal eligibility sufficient if migrant and refugee women-led organisations do not enjoy effective equality of access to EU funding?

EU funding rules should not reproduce the very structural inequalities that EU gender-equality and inclusion funding is intended to address.

A contradiction inside Erasmus+ inclusion policy

There is a profound policy contradiction. Erasmus+ itself requires beneficiary organisations to promote inclusion and diversity, ensure fair and equal conditions, and actively involve participants with fewer opportunities. Adliga designed its project precisely around those priorities. Its application explicitly identifies “Reception and integration of refugees and migrants”, “Inclusion, promoting equality and non-discrimination” and “Promoting gender equality” as project topics.

Yet the migrant women-led organisation seeking to implement those inclusion objectives was itself excluded through a mechanism that treated the migration/security status of its own migrant woman director as an organisational financial risk.

In other words, an organisation can be encouraged by EU policy to reach migrant women with fewer opportunities while simultaneously becoming more vulnerable because its own leadership comes from the same migrant community.

The EU cannot coherently encourage civil society to include migrant women while allowing migrant women’s own status to become a barrier when they themselves establish and lead the organisations providing that inclusion.

3. From migration/security assessment to a funding restriction

The relevance to FEMM is the spill-over between administrative spheres. A security assessment originating in migration/asylum proceedings concerning a Belarusian woman human rights defender was later relied on in a funding procedure involving a separate Lithuanian women-led legal entity.

The National Agency’s decision expressly relied on Karach’s security status, and the later administrative challenge argues that the Agency did not establish a concrete legal or factual mechanism explaining how one individual’s migration status would make a Lithuanian legal entity unable to implement a project, undergo audit, or return funds if necessary. [2]

The Agency also built part of its financial-risk argument on a hypothetical future possibility that Karach’s residence permit might not be renewed. The challenge records the resulting chain: possible non-renewal of residence permit → possible inability to continue as director → possible organisational disruption → possible inability to control or recover EU funds. [2] This is a particularly revealing element of the case because it converts the contingent migration status of a third-country national woman into an alleged financial risk for a separate Lithuanian legal entity.

That hypothetical scenario did not materialise. Lithuania itself continues to authorise Karach’s lawful residence. Her residence permit was renewed again in 2026 for another year without barriers or restrictions, and she continues to reside in Lithuania legally. The renewed permit covers the planned implementation period of the Erasmus+ project. This matters because the Lithuanian National Agency relied on possible future loss of legal residence as part of its financial-risk narrative, while the competent Lithuanian migration authorities in fact renewed her lawful residence without difficulty. The funding exclusion therefore cannot be explained simply by an inability of Karach to remain lawfully present in Lithuania; it produced a real and immediate restriction on a women-led organisation on the basis of a migration-related scenario that did not occur.

The equal-treatment question is therefore unavoidable: would the same funding barrier have arisen if the founder and director had been a Lithuanian citizen whose right to remain in Lithuania could not be questioned, withdrawn or used as a proxy for the organisation’s financial reliability? In this case, Karach’s lawful residence was renewed without difficulty, yet her status as a migrant woman remained part of the logic used to justify exclusion from funding.

Equality test Would the same funding barrier have arisen if the founder and director had been a Lithuanian citizen with no migration status capable of being questioned, withdrawn or used as a proxy for organisational financial risk?

 

4. Cross-border inconsistency within the EU funding ecosystem

The case also reveals a striking inconsistency between EU funding channels. After the Erasmus+ exclusion, Adliga was selected for EUR 7,500 in EU CERV-funded support under WE-EMPOWER II for “Living Stories, Civic Voices: Co-Creating Spaces for Migrant Women’s Democratic Participation in Lithuania”. [9]

Thus, one EU-funded mechanism supports Adliga precisely for migrant women’s democratic participation, while another EU programme administered nationally excludes the same women-led organisation after transferring a migration-related national-security assessment of its Belarusian director into the funding sphere.

A further cross-border comparison

The Lithuanian exclusion is difficult to reconcile with Our House’s continuing participation in Erasmus+ activity administered in another Member State. The 2026 “European Youth Peace Week” project is administered through FI01 – Finnish National Agency for Education. Its formal application lists Our House as a partner organisation, identifies a seven-month project period from 11 May to 10 December 2026, and includes a total project grant budget of EUR 46,882. The project design expressly includes Belarusian refugees living in Lithuania and assigns Our House a substantive role in youth work, advocacy and financial reporting.

The same Erasmus+ application records Our House’s prior KA152-YOU experience as a partner: five partner applications and one granted project. In addition, earlier Erasmus+ documentation from 2023 shows Our House formally mandated as a partner in another youth-mobility project administered by the German National Agency. The evidence therefore points to a broader record of normal participation in Erasmus+ cooperation outside the Lithuanian exclusion at issue here.

Comparative reality check

EU / national mechanism	Observed treatment
Lithuanian Erasmus+ National Agency	Adliga excluded after Karach’s migration/security assessment was treated as an alleged risk to EU financial interests; no organisational fraud or financial misconduct established.
CERV / WE-EMPOWER II	Adliga selected for EUR 7,500 to implement a project on migrant women’s democratic participation, with reporting, control and recovery obligations.
Finnish Erasmus+ (2026)	Our House listed as partner in “European Youth Peace Week”, administered by FI01 – Finnish National Agency for Education; seven-month project period and EUR 46,882 total project budget.
Other Erasmus+ experience	The 2026 application records Our House as having five KA152-YOU partner applications and one granted project; 2023 documentation also shows formal partnership in an Erasmus+ project administered in Germany.
Lithuanian migration authorities (2026)	Karach’s residence permit renewed for another year without restrictions; lawful residence continues through the planned Lithuanian Erasmus+ project period.

 

If the alleged risk were genuinely inherent in Karach’s or her organisations’ capacity to manage or participate in EU-funded activities, why is it not visible in the repeated experience of other EU funding mechanisms and other Erasmus+ National Agencies?

5. Why this is an EU-level structural issue

The issue is not whether Verian or FEMM should decide the legality of the pending Lithuanian proceedings. They should not. The policy relevance lies in the structural vulnerability the case exposes.

• Migrant and refugee women may formally have the right to establish and lead civil society organisations while remaining uniquely exposed to migration-status decisions that citizens do not face.
• If an individual migration/security assessment can be transferred to a legal entity without a separate finding of organisational financial misconduct, migration status can operate as an indirect funding barrier.
• Organisations that actively challenge deportations or support asylum claims face a chilling risk if security-related assessments generated around such work can later influence unrelated funding decisions. Here the concern is concrete: VSD itself joins Our House’s effectiveness in asylum cases with its adverse assessment of Karach, while the same personal assessment later became relevant to Adliga’s exclusion from EU funding. The downstream effect falls on migrant and refugee womenbecause the excluded grant was designed to build Adliga’s capacity to provide structured, trauma-informed civic education to that group.
• Small women-led organisations are particularly exposed because the founder/director is often also the principal public representative; attributing the individual’s migration/security status to the organisation can therefore exclude the entire organisation from funding.
• The lack of transparent, reviewable safeguards is especially serious where security information is partly inaccessible to the person concerned while the consequences extend into funding and organisational reputation.

6. What we ask FEMM/Verian to take from this case

1. Include the Lithuanian case as a concrete national example of a funding barrier affecting a migrant women-led CSO, with emphasis on the spill-over from migration/security assessment to EU funding exclusion.
2. Examine whether the next Multiannual Financial Framework needs explicit safeguards requiring a separate, individual and proportionate assessment of the legal entity’s actual financial risk before exclusion on grounds linked to a founder or director.
3. Examine whether migration status or migration-related security assessments can create indirect discrimination or disproportionate barriers for migrant and refugee women-led organisations.
4. Recognise refugee-rights advocacy, including assistance in asylum, legal-status and deportation cases, as protected civil-society and human-rights activity. EU funding safeguards should prevent such advocacy – especially where authorities themselves recognise a real risk upon return – from being converted into an adverse security characteristic or a funding penalty for women-led organisations carrying out that work.
5. Consider whether the European Commission should issue guidance to nationally administering authorities on preventing the use of migration status as a proxy for organisational financial unreliability.
6. Examine cross-border consistency in nationally administered EU programmes where the same organisation or leadership is accepted as a normal project partner by one National Agency but excluded by another on the basis of a migration-related security assessment unrelated to proven financial misconduct.

7. Possible policy questions arising from the case

Is the Commission aware of cases in which a national Erasmus+ agency has excluded a migrant women-led organisation from EU funding on the basis of a migration-related national-security assessment concerning its founder or director, despite no finding of fraud, financial misconduct or misuse of EU funds by the organisation and without an individual financial-risk assessment of the legal entity?

Does the Commission consider it compatible with the principles of proportionality, equal treatment, non-discrimination and sound financial management to treat the possible future non-renewal of a third-country national director’s residence permit as a basis for excluding a separate EU-based legal entity from funding, without establishing how that event would prevent audit, control or recovery of EU funds?

What safeguards ensure that civil society organisations assisting migrant and refugee women in asylum and deportation proceedings are not disadvantaged in access to EU funding as a consequence of legitimate human-rights advocacy?

Will the Commission consider guidance or monitoring under the next MFF to ensure that migration/security assessments concerning individual founders are not automatically transformed into exclusion grounds for migrant and refugee women-led organisations without an individualised assessment of the organisation itself?

8. Primary documentation available

• Lithuanian Erasmus+ National Agency exclusion decision and subsequent explanation/appeal decision.

2026 Erasmus+ KA122-ADU application for Adliga, including the total requested grant of EUR 11,819, Women Civic Circles Lithuania design, approximately 20-woman pilot target, gender-equality/inclusion topics and the project’s focus on migrant and refugee women in Lithuania.

• Administrative appeals and complaints concerning Adliga’s exclusion from the Erasmus+ grant-award procedure.
• State Security Department letter No. 18-8437 of 7 August 2026 concerning Yuliya Prasanava, Our House and Volha Karach (with English translation).
• Migration Department Decision No. 26S160506 of 11 August 2026 concerning Yuliya Prasanava (with English translation).
• Relevant Supreme Administrative Court material concerning Prasanava, including the finding that the Migration Department failed to prove abuse of the international-protection procedure.
• Documentation concerning Adliga’s EUR 7,500 CERV-funded WE-EMPOWER II project on migrant women’s democratic participation.
• 2026 Erasmus+ KA152-YOU application “European Youth Peace Week”, administered through FI01 – Finnish National Agency for Education, listing Our House as partner organisation and recording the project budget and prior Erasmus+ partner experience.
• 2023 Erasmus+ partnership mandate and youth-exchange documentation showing Our House’s formal participation in a project administered by the German National Agency.

Primary documentation is available upon request. We are not asking the study to determine the legality of the pending Lithuanian proceedings. We submit the case as evidence of a potential structural gap in EU funding safeguards.

Source notes

[1] Švietimo mainų paramos fondas (Lithuanian Erasmus+ National Agency), decision/appeal explanation No. SE-1453, 24 July 2026; Erasmus+ KA122-ADU application “From Displacement to Democratic Participation: Building Nonviolent Civic Leadership Among Migrant Women in Lithuania”, total grant requested EUR 11,819; planned Women Civic Circles Lithuania pilot approximately 20 migrant and refugee women.

[2] Adliga Women at Risk Solidarity Fund, complaint to the Lithuanian Administrative Disputes Commission, 23 August 2026, especially sections on separate legal personality, absence of financial misconduct, migration-status hypothesis and causation.

[3] Lithuanian National Agency explanation acknowledging that the organisation’s individual risk and operational-capacity assessment was not performed because the application had already been rejected at an earlier stage.

[4] Migration Department Decision No. 26S160506, 11 August 2026, unofficial English translation: factual context of Prasanava’s volunteer work for Our House and recognition of a real risk of harm upon return.

[5] Supreme Administrative Court of Lithuania, order of 14 January 2026 in administrative case No. eA-1399-789/2026, as reproduced in the Migration Department decision: failure to prove abuse of the international-protection procedure.

[6] State Security Department of the Republic of Lithuania, Letter No. 18-8437, 7 August 2026 (Migration Department receipt No. 9K-17438), unofficial English translation.

[7] Migration Department Decision No. 26S160506, 11 August 2026, unofficial English translation, summary and reasoning concerning non-refoulement and alleged use of Our House’s public profile/information capacity.

[8] Adliga complaint to the Lithuanian Administrative Disputes Commission: subsequent renewal of Volha Karach’s residence permit covering the planned Erasmus+ project period.

[9] Adliga complaint and supporting memorandum: WIDE+ / WE-EMPOWER II CERV-funded project “Living Stories, Civic Voices: Co-Creating Spaces for Migrant Women’s Democratic Participation in Lithuania”, EUR 7,500.

[10] Erasmus+ KA152-YOU application “European Youth Peace Week”, Form ID KA152-YOU-1F5A5F9F: FI01 – Finnish National Agency for Education; Our House (OID E10046708) listed as partner; project period 11 May–10 December 2026; total project budget EUR 46,882; historical KA152-YOU partner record shown in the application.

[11] Erasmus+ 2023 partnership mandate for project “Menschenrechte in Zeiten des Krieges: Reflektionen zu Demokratie und Asyl”, Form ID KA152-YOU-C766B323, submitted to DE04 – JUGEND für Europa in Germany, together with 2023 youth-exchange programme and photo-report documentation.