REGULATORY SCRUTINY BOARD OPINION Impact assessment of the performance framework

EUROPEAN COMMISSION
13.06.2025
SEC(2025) 590
REGULATORY SCRUTINY BOARD OPINION
{COM(2025) 545}
{SWD(2025) 590-591}
Impact assessment of the performance framework
Offentligt
KOM (2025) 0545 - SEK-dokument
Europaudvalget 2025
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This opinion concerns a draft impact assessment which may differ from the final version.
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111
regulatory-scrutiny-board@ec.europa.eu
EUROPEAN COMMISSION
REGULATORY SCRUTINY BOARD
Brussels,
RSB
Opinion
Title: Impact assessment of the performance framework
(A) Policy context
The report is part of the post-2027 Multiannual Financial Framework (MFF) package.
Under the Commission’s Political Guidelines, the next MFF sets out to be more focused,
simpler, with fewer programmes and more impactful. Impact assessments for programmes
under the next MFF focus on how to streamline the architecture of the EU budget so as to
achieve its policy objectives more effectively.
The new architecture of the MFF requires adaptations to the current EU budget
performance framework, and builds on three pillars: programming, monitoring, and
reporting. The performance framework of the EU budget is key to ensuring transparency
and accountability, providing budgetary authorities and citizens with a clear view of how
the EU budget is being used and what results are achieved.
Better Regulation Tool #9 acknowledges that ‘the special case of preparing a new
multiannual financial framework is a unique process requiring a specific approach as
regards scope and depth of analysis’. The architecture of the new MFF will be significantly
different from the current structure. Given that at this stage the impact assessment lacks
several key elements the Board has decided, exceptionally, to issue an Opinion without
qualification.
(B) Key issues and recommendations
The Board notes the additional information provided and commitments to make
changes to the report. However, the report still contains significant shortcomings.
The Board makes the following recommendations for the lead Service to rectify:
On scope and coherence: The report is not sufficiently clear on how it links with
other ongoing MFF impact assessments in relation to the establishment of the
monitoring and performance framework and its implementation. It does not justify
why harmonisation and simplification of mainstreaming provisions is limited to only
two policy areas.
The report should better explain the link with the six other MFF impact assessments. It
should clarify to what extent the analysis presented in the impact assessment covers the
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monitoring and performance frameworks of the impact assessments for the other
programmes under the next MFF.
The scope of the intervention linked to the policy mainstreaming is limited to only two
policy areas foreseen in the current Financial Regulation: gender equality and the ‘do no
significant harm’ principle. The report should assess whether and how other horizontal
priorities (e.g. competitiveness, security, digitalisation, preparedness) should also be
mainstreamed reflecting major societal problems and political objectives of the EU.
On the problem definition and on the use of evaluations: The report does not
sufficiently investigate the necessary preconditions for tracking the impact of the EU
budget.
While referring to recent evaluations of spending programmes, the report in its problem
definition does not reflect their frequent conclusions and RSB recommendations in
relation to data availability and need to significantly improve monitoring and evaluation
arrangements. The current performance framework should be critically assessed against
its ability to measure the impact of the EU budget identifying major deficiencies including
underlying reasons, overlaps and inconsistencies, and reflecting the results of such
analysis in the problem definition.
On the intervention logic and objectives: It is not sufficiently clear what is intended
to be achieved by the performance framework.
The objectives of the initiative should be better specified in line with a more detailed
problem definition. The link between budget transparency and accountability with the
policy performance (achieving policy objectives) should be further developed. The report
should better describe what the performance framework intends to achieve and thus better
define the specific objectives in S.M.A.R.T. terms to the extent possible in order to
facilitate continuous monitoring of the fit-for-purpose of individual performance
indicators and the performance framework as a whole.
On options: The content of options is not sufficiently developed to capture not only
budget execution but also impacts of different MFF programmes.
The options the report considers achieving the desired objectives should be developed or
presented in greater detail.
For the programming options, subject to the possibly revised scope, the report should
better explain the mechanisms that would allow for mainstreaming of a range of chosen
policy objectives.
For monitoring, the report should clearly delineate the differences between options,
explain the different processes and methods for establishing and modifying the list of
intervention fields and indicators. It should also be clarified how the lists of performance
indicators are formulated and if the common list of indicators is of equal length and
content in both options. It should further explain what the flexibility is to adopt and use
additional indicators in each of the options.
It should be clarified how the framework can provide a set of meaningful indicators for
each of the MFF funds that would allow for measuring their respective impact, given that
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the framework’s list of indicators is supposed to be usable across instruments/funds.
On cost assessment: The methodology and assumptions used to calculate cost savings
are not sufficiently explained. The report does not provide estimates for
administrative cost savings for other stakeholders including businesses.
The analysis developed in Annex 9 should be transparent on how efficiency is estimated
for the different options and how it impacts the comparison of options. The report should
clarify further the assumptions taken to calculate the correction coefficients (reduction
factors) applied to the estimates of administrative burdens of the options as they are the
key factor distinguishing the impact of different measures in terms of efficiency.
Further efforts should be taken to provide estimates of the administrative burdens on
businesses and their reduction, currently missing from the report.
On governance: The report does not sufficiently describe the governance and
implementation mechanisms.
The report should explain how the governance framework that will be put in place to
ensure that meaningful indictors are included to track the performance and impact of the
EU budget. The report should clarify the process and various steps for adopting and
modifying, when necessary, the performance framework including intervention fields and
indicators.
On monitoring and data: The report does not clarify to what extent the planned
monitoring framework would be sufficient to ensure the availability of data for
monitoring and evaluations of the specific programmes and how its continuous fit-
for-purpose will be ensured.
The report should bring forward how the proposed list of performance indicators would
cover not only outputs and results but also mid to longer-term impacts, which are
necessary for tracking the impact of the budget and for future evaluations, in particular of
effectiveness, efficiency and EU added value, consistent with the Commission’s Better
Regulation requitements. The report should also bring forward how compliance costs will
be monitored, which is necessary, for example, to implement the Commission’s ‘one in
one out’ principle.
The report should establish at which stage and how the data plans as required by the Better
Regulation Toolbox will be developed and what they will cover to ensure relevant and
sufficient data for evaluation purposes. A systematic approach to assessing continued
relevance of indicators, in particular, those linked to performance-based payments, and
gaps in terms of objectives and impacts not sufficiently developed. To this end, the report
should describe how the fit-for-purpose of the established intervention fields and
indicators would be assessed.
After defining the objectives in more S.M.A.R.T. terms, the report should outline
appropriate monitoring and evaluation arrangements which would allow to monitor the
progress on achieving the objectives of the performance framework.
Some more technical comments have been sent directly to the lead Service(s).
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(C) Conclusion
The lead Service should revise the report in accordance with the Board’s
recommendations before launching the interservice consultation.
Full title Performance framework of the 2028-20xx Multiannual Financial
Framework (MFF)
Reference number 2025/MFF/07
Submitted to RSB on 21 May 2025
Date of RSB meeting 11 June 2025
Electronically signed on 13/06/2025 13:22 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121