Court of Justice 11 June 2026, C-631/24 (Opinion of Advocate General Rantos delivered on 11 June 2026.)

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In consolidated appeals arising from the COVID-19 vaccine procurement programme, Advocate General Rantos opines that the General Court did not err in law in annulling Commission decisions that refused wider access to (i) declarations of absence of conflict of interests signed by members of the joint negotiation team and (ii) indemnification provisions in advance purchase and purchase agreements, the Commission having failed to demonstrate that disclosure would specifically and actually undermine the protected interests. On the personal data issue, the Opinion holds that transparency of the Commission's vaccine negotiation process constitutes a sufficiently specific purpose in the public interest within the meaning of Article 9(1)(b) of Regulation 2018/1725, read in conjunction with Article 4(1)(b) of Regulation No 1049/2001, and that anonymised disclosure of conflict-of-interest declarations is insufficient to enable external verification of the impartiality of individual team members. On the commercial interests exception under the first indent of Article 4(2) of Regulation No 1049/2001, the Opinion concludes that the Commission's asserted risks of strategic litigation, competitive disadvantage, and reputational harm were either legally unfounded or purely hypothetical, and accordingly proposes that the relevant grounds of appeal be rejected.AI