ARBEJDSDOKUMENT FRA KOMMISSIONENS TJENESTEGRENE RESUMÉ AF RAPPORTEN OM KONSEKVENSANALYSEN Ledsagedokument til forslag til EUROPA-PARLAMENTETS OG RÅDETS FORORDNING om fastsættelse af en udgiftssporings- og præstationsramme for budgettet samt andre horisontale regler for EU-programmer og -aktiviteter

EN EN
EUROPEAN
COMMISSION
Brussels, 16.7.2025
SWD(2025) 591 final
COMMISSION STAFF WORKING DOCUMENT
EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT REPORT
Accompanying the document
Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE
COUNCIL
establishing a budget expenditure and performance framework and other horizontal
rules for Union programmes and activities
{COM(2025) 545 final} - {SEC(2025) 590 final} - {SWD(2025) 590 final}
Offentligt
KOM (2025) 0545 - SWD-dokument
Europaudvalget 2025
1. WHAT IS THIS INITIATIVE ABOUT?
A strong performance framework is essential to deliver on EU policy priorities and adapt to
evolving challenges, while ensuring transparency and accountability. It has the potential to
enable a more effective communication towards the Parliament, Member States and
stakeholders, demonstrating how the EU budget delivers value and improves citizens’ lives. It
also has potential to contribute to the Commission targets for reducing administrative burden
by at least 25% for all companies and at least 35% for SMEs.
The performance framework of the EU budget refers to the systems and tools designed to
ensure that spending delivers the intended results, and to monitor and report on how
effectively the EU budget is achieving its objectives.
The 2024 Financial Regulation introduces requirements that must be taken into account when
designing the new performance framework. It mandates that all programmes and activities be
implemented (where relevant and appropriate) without doing significant harm to the
environmental objectives and taking into account the principle of gender equality. In addition,
it requires that indicators be designed to allow for data aggregation, and requires transparency
about the publication of data on beneficiaries supported by the EU budget.
The rules of the 2021-2027 performance framework create administrative burdens for
Member States, partner countries and EU institutions, and make it difficult for the
Commission to aggregate performance data at EU budget level, and ensure adequate
transparency and access to information for budgetary authorities and MFF beneficiaries. The
draft impact assessment identifies three problems:
• Insufficient flexibility and excessive complexity of provisions on the programming
and mainstreaming of horizontal priorities: the 2021-2027 EU budget features a
fragmented structure and heterogeneous mainstreaming requirements at MFF and
programme levels. The Do No Significant Harm (DNSH) principle is currently
inconsistently applied across programmes, with multiple technical guidelines creating
complexity for beneficiaries who need to navigate heterogeneous requirements. While
progress has been made in integrating gender equality in certain MFF programmes,
gender mainstreaming remains uneven across EU programmes, including because of the
absence of a common methodology and objectives.
• Inconsistency and complexity of requirements on the monitoring of performance
information: the EU budget is currently not equipped to effectively monitor, at aggregate
level, the financed activities, the volume of expenditure contributing to new horizontal
priorities (e.g. competitiveness) and their outcomes across the MFF. This is due to
differing monitoring rules across programmes, which do not allow to effectively
consolidate and communicate the performance of the EU budget to the budgetary
authorities and citizens, nor to effectively inform policy decisions. The current framework
includes a vast number of performance indicators and varying expenditure tracking
methodologies, creating complexity and administrative burden for beneficiaries, Member
States, implementing partners and EU institutions.
• Fragmentation and duplication in reporting performance information and funding
opportunities: there are multiple legal requirements for performance reporting, including
those related to the budget discharge with the Annual Management and Performance
Report, the draft budget, and reporting requirements under more than 30 programme
regulations. This proliferation of reports results in overlapping content, risk of
inconsistency and administrative burden, and makes it difficult to access and present
information on what the EU budget delivers. In addition, there are more than 15 different
online dashboards presenting information on the performance of programmes, which
generates administrative burden and creates confusion as to how the budgetary authorities
can access information on the performance of the EU budget. At least 10 different portals
(so-called one-stop-shops) display information about available funding opportunities
under EU funds, which makes it difficult for beneficiaries to identify suitable funding
sources under the EU budget.
Building on the lessons of the 2021-2027 EU budget, the post-2027 MFF should reduce
administrative burdens and improve accountability and transparency under a simplified,
single performance framework.
Fragmented
MFF structure
with multiple
mainstreaming
requirements
at MFF and
programme
levels
e.g. earmarking,
conditionality etc
PROBLEM
DRIVERS
PROBLEMS
CONSEQUENCES
Insufficient flexibility
and excessive complexity
of mainstreaming provisions
across the EU budget
Limited flexibility to address
new and emerging priorities
and challenges, and specific
MS and sectors needs
Inconsistency and complexity in
monitoring requirements
across the EU budget
Horizontal
spending
targets
applied at MFF
or programme
level
Mainstreaming
provisions
included in
programmes in
an
inconsistent
way (e.g. DNSH,
gender, working
conditions)
PROGRAMMING
Limited capacity to measure
EU budget impact and inform
policies
High administrative burden
and costs affecting beneficiaries,
Member States, implementing
partners and EU institutions
No common
methodology to track
expenditures for
horizontal priorities across
MFF programmes
> 5 000 - heterogenous,
non-aggregable -
performance indicators
and > 7 000 RRF
milestones and targets
addressing different
needs: draft budget,
monitoring and evaluation,
MS plans, link to funding
MONITORING
13 portals to
inform about
funding
opportunities,
lack of inter-
operability of
databases across
management
modes
20
dashboards of
performance
information on
programmes –
Inconsistent
transparency of
data on
beneficiaries
supported
32 programme-
specific
reporting
requirements on
top of discharge,
draft budget and
strategic planning
- not aligned in
timing and
content
Reduced transparency and
access to information for
budgetary authorities and MFF
beneficiaries
REPORTING
Complexity and rigidity of the EU budget performance provisions
hamper its capacity to deliver on policy priorities
Fragmentation and duplication in
reporting performance information and
funding opportunities
across the EU budget
Problem tree: problem drivers, problems and consequences
2. WHAT IS TO BE ACHIEVED AND WHICH POLICY OPTIONS HAVE BEEN ASSESSED?
Fragmented
MFF structure
with multiple
mainstreaming
requirements
at MFF and
programme
levels
e.g. earmarking,
conditionality etc
PROBLEM
DRIVERS
SPECIFIC
OBJECTIVES
EXPECTED
RESULTS
Increased flexibility and responsiveness
of mainstreaming provisions
across the EU budget
Increased capacity to
address new and emerging
priorities and challenges,
and specific MS and sectors
needs
Simplification and streamlining of
monitoring requirements
across the EU budget
Horizontal
spending
targets
applied at MFF
or programme
level
Mainstreaming
provisions
included in
programmes in
an
inconsistent
way (e.g. DNSH,
gender, working
conditions)
PROGRAMMING
Enhanced capacity to
measure EU budget impact
and inform policies
Reduction of administrative
burden and costs affecting
beneficiaries, Member States,
implementing partners and EU
institutions
No common
methodology to track
expenditures for
horizontal priorities across
MFF programmes
> 5 000 - heterogenous,
non-aggregable -
performance indicators
and > 7 000 RRF
milestones and targets
addressing different
needs: draft budget,
monitoring and evaluation,
MS plans, link to funding
MONITORING
13 portals to
inform about
funding
opportunities,
lack of inter-
operability of
databases across
management
modes
20
dashboards of
performance
information on
programmes –
Inconsistent
transparency of
data on
beneficiaries
supported
32 programme-
specific
reporting
requirements on
top of discharge,
draft budget and
strategic planning
- not aligned in
timing and
content
Increased transparency and
access to information for
budgetary authorities and MFF
beneficiaries
REPORTING
Simplified, coherent and flexible performance framework
enabling to maximize EU budget capacity to deliver on policy priorities post-2027
Harmonization and rationalization of
reporting of performance information
and funding opportunities
across the EU budget
GENERAL
OBJECTIVE
Intervention logic: problem drivers, general objective, specific objectives and expected results
The draft impact assessment identifies three policy options corresponding to possible levels of
harmonization of performance provisions across the three problems identified:
Policy
options
P. Programming and
mainstreaming
M. Monitoring R. Reporting
1
P1: Baseline –
Programme-specific
rules on DNSH and
gender equality
M1: Baseline –
Programme-specific rules
for defining tracking
methodologies and
performance indicators
R1: Baseline –
Programme-specific
reporting requirements,
dashboards and portals
2
P2: Activity-specific
rules: harmonised
provisions across
programmes on DNSH
and gender equality,
with calibrated
harmonisation and
differentiated
operationalisation per
management mode
M2: Single methodology
to track expenditures
through intervention
fields and a limited set of
common mandatory
performance indicators,
with flexibility to adopt
additional programme-
specific performance
indicators
R2: Single performance
report, single portal on
performance
information and funding
opportunities, with
differentiated
operationalisation of the
single portal per
management mode or
sector
3
P3: Activity-specific
rules: fully harmonised
provisions on DNSH
and gender equality
M3: Single methodology
for the EU budget to track
expenditures through
intervention fields, and
fully harmonised list of
performance indicators
R3: Single performance
report, single portal on
performance
information and funding
opportunities, with fully
harmonised
across programmes
(linked to intervention
fields)
operationalisation across
management modes
3. WHAT IS THE PREFERRED OPTION AND WHY?
The table below summarises the comparison of policy options against their ability to achieve
effectiveness, efficiency and coherence:
Policy options -
Programming/
mainstreaming
Policy option P1 Policy option P2 Policy option P3
Effectiveness (=) (+++) (++)
Efficiency (=) (+++) (+)
Coherence (=) (+++) (+)
Policy options -
Monitoring
Policy option M1 Policy option M2 Policy option M3
Effectiveness (=) (+) (+++)
Efficiency (=) (+) (+++)
Coherence (=) (+) (+++)
Policy options -
Reporting
Policy option R1 Policy option R2 Policy option R3
Effectiveness (=) (+++) (++)
Efficiency (=) (+++) (+)
Coherence (=) (++) (+++)
The preferred combination of policy options is P2+M3+R2. This combination would enable
to effectively deliver against horizontal EU policy objectives and principles such as DNSH
and gender equality, yet foreseeing calibrated and proportionate implementation of DNSH,
enabling to comply with the requirement of the Financial regulation to implement DNSH
where feasible and appropriate, while reducing administrative burden and costs for Member
States, implementing partners and beneficiaries. This combination also enables a significant
upgrade of the monitoring of the performance of the EU budget by enabling the aggregation
of indicators across programmes, while achieving significant administrative burden reduction
thanks to the simplification of the existing landscape of performance indicators, reducing
them from ca. 5 000 to ca. 900. This combination of options also enables improved access to
performance information and funding opportunities, while limiting entry costs to develop a
single portal by focusing on merging Commission portals only.
The most appropriate vehicle to operationalize this preferred combination of options appears
to be the development of a single performance framework through a single legal act. Such a
performance regulation would enable to centralize most programming, monitoring and
reporting provisions in a self-standing horizontal act for the post-2027 MFF. The regulation
will include relevant provisions on implementing the DNSH principle (including a technical
guidance setting DNSH criteria for relevant intervention fields), on mainstreaming gender
equality across programmes and management modes, as well as on performance monitoring,
performance reporting through a single report (AMPR) and the single portal. The regulation
will include the single list of intervention fields and associated indicators, replacing e.g. the
several lists of intervention fields and performance indicators currently attached to e.g. the
Common Provisions Regulation, the RRF regulation and other programmes’ legal bases. The
single performance regulation would replace the performance provisions scattered across the
legal bases of more than 50 programmes in the 2021-2027 period. The adoption of this single
regulation is therefore expected to achieve significant simplification for Member States,
implementing partners, partner countries, beneficiaries and EU institutions.
While the proposed regulation does not correspond to a revision of existing legislation in a
strict sense, the preferred policy option is fully in line with the REFIT objectives of
simplification and reduction of red tape. The initiative is expected to result in a significant
reduction of administrative burden and improved efficiency expected from the preferred
combination of options enabling to achieve a significant reduction of regulatory costs. The
significant decrease in the number of performance indicators and the establishment of a single
portal for performance information and funding opportunities significantly reduces
administrative burdens, which directly addresses REFIT’s objective of cutting red tape and
lowering costs for stakeholders, thus encouraging broader participation and engagement. By
tailoring DNSH implementation requirements to be both effective and reasonable, the
preferred combination of options ensures that policy measures are proportionate to their
desired impact. This approach aligns with REFIT’s emphasis on effectiveness and efficiency,
and increases the likelihood of successful compliance by beneficiaries.
4. WHAT ARE THE IMPACTS OF THE PREFERRED OPTION?
I. Overview of Benefits (total for all provisions) – Preferred Option
Description Amount Comments
Direct benefits
P2: Reduction of administrative burden
resulting from the simplification of DNSH
requirements, compared to a programme-
specific approach requiring compliance with
several different DNSH guidance and systems,
sometimes for the same type of projects
EUR 85,5 million Member States administrations at all levels
(reduction of administrative burden linked to
operationalization tasks such as: contribution to the
design of DNSH guidance at EU level, transposing
EU level guidance into national systems, providing
guidance and training to national stakeholders and
beneficiaries, checks of DNSH compliance,
developing national assessment tools, as well as
reporting and coordination of implementation at EU
level)
M3: Reduction of administrative burden as a
result of simplifying expenditure tracking and
indicator monitoring requirements, compared
to the current programme-specific approach,
which relies on a large number of indicators
under the various EU budget programmes.
EUR 700,6 million Member State administrations at all levels
(reduction of administrative burden linked to
operationalization tasks such as: contributing to the
design and management of indicators at EU level,
transposing EU level indicators system into national
systems, data collection and management at national
level, data verification, providing guidance and
training to national stakeholders and beneficiaries
having to report against such indicators, developing
national tools and systems, reporting and
coordination of implementation at EU level)
R2: Reduction of costs linked to the
development and management of performance
dashboards
EUR 24,6 million Commission (reduction of costs as a result of
merging dashboards into a single one, compared to
maintaining the current system which relies on
approximately 20 performance dashboards)
R2: Reduction of costs linked to the
development and management of portals on
funding opportunities
EUR 32 million Commission (reduction of costs as a result of
merging existing portals into one compared to
maintaining the current system which relies upon ca.
12 portals on funding opportunities)
II. Overview of costs – Preferred option
Citizens/Consumers Businesses Administrations
One-off Recurrent One-off Recurrent One-off Recurrent
P2:
activity-
based
approach
to DNSH
Direct
administrative
costs
Could not be costed due to lack of available data
EUR 8,5
million
M3:
single
expenditur
e tracking
and
indicator
monitorin
g
Could not be costed due to lack of available data
EUR 210,2
million
R2: Single
performan
ce portal
Could not be costed due to lack of available data
EUR 1,3
million
R2: Single
portal on
funding
opportunit
ies
Could not be costed due to lack of available data
EUR 3
million
Combination P2+M3+R2 is expected to achieve ca. EUR 623 Mio of administrative costs
savings for Member States administration and the Commission compared to the baseline
scenario. This corresponds to a strong underestimation of expected cost savings, since – as
indicated under section 7 – the quantitative analysis of the impacts of policy options did not
quantify further impacts due to a lack of data. However significant reductions of
administrative and reporting burdens are also expected at the level of EU budget beneficiaries,
such as businesses, enabling to support the competitiveness of the sectors supported by EU
budget programmes.
The preferred policy option is expected to have a positive impact on cost and price
competitiveness, as it is expected to result in significant reductions of compliance and
administrative costs at the level of EU budget beneficiaries such as businesses, enabling to
support the competitiveness of the economic sectors supported by EU budget programmes, in
line with the initiative’s specific objective of a reduction of such administrative burden by at
least 25% (1
). The initiative foresees a calibrated and proportionate approach to implementing
the DNSH principle, which will facilitate compliance by businesses, ultimately supporting
cost and price competitiveness of companies supported by EU funds. The simplification of
performance monitoring provisions and the reduction of the number of indicators would
enable enterprises to face less reporting burden and reduce the costs associated with project
monitoring. A single online portal displaying information on available funding opportunities
is also expected to help businesses to reduce the costs currently allocated to having to
navigate and process multiple portals, ultimately facilitating access to EU funds by
(1
) In line with Communication target of reducing burdens associated with reporting requirements by 25%
beneficiaries in key economic sectors. The initiative is similarly expected to have a limited
but positive impact on international competitiveness, improving the competitive position of
EU firms supported by EU budget programmes compared to non-EU competitors, as EU
companies would be facing less administrative burden associated with mainstreaming,
monitoring and reporting provisions, improving their position vis-à-vis third countries
enterprises.
The initiative will also have a particularly positive impact on SMEs, which often operate with
limited staff and resources and can be disproportionately affected by the complexity of
existing monitoring and reporting requirements under EU funds, and of EU portals displaying
information on funding opportunities, therefore enabling SMEs to become more responsive to
new support opportunities under EU budget programmes. The initiative is particularly
expected to contribute to the Commission commitment to streamline rules and reduce the
administrative burdens by 35% for SMEs by the end of the current mandate.
The preferred policy option is expected to contribute to most SDGs since it is expected to
improve the effectiveness, efficiency and EU added-value of all EU budget programmes and
their contribution to several SDGs. Specific contributions are also expected towards SDGs 5
(Achieve gender equality and empower all women and girls), 13 (Take urgent action to
combat climate change and its impacts) and 15 (Protect, restore and promote sustainable use
of terrestrial ecosystems, sustainably manage forests, combat desertification, and halt and
reverse land degradation and halt biodiversity loss).
5. MEASURING SUCCESS?
A number of actions should be taken to monitor and evaluate the impacts of this initiative:
• The adequacy of the list of intervention fields and performance indicators – to be
adopted as part of the performance regulation – should be monitored by the
Commission in order to assess any potential gaps or shortcomings. As a mitigation
measure, the regulation should contain an empowerment for the Commission to adopt
a delegated act enabling to revise the list, as relevant, during the phase of
implementation of the post-2027 budget.
• The Commission study on assessing the administrative costs and administrative
burden in the management of the Common Provisions Regulation funds (2018 and
2025) should be updated during the phase of implementing the post-2027 budget,
enabling to update the values provided in terms of costs of performance monitoring
and reporting, in particular for Member States authorities. The results of this study
should be used as input for any future impact assessments in view of the following
MFF.
• The monitoring and evaluation of this initiative should be carried out based on a
number of core monitoring indicators, addressing the following aspects for all EU
budget programmes (possibly by expanding the scope of the above study):
o relevance of new single list of intervention fields and indicators in view of
performance monitoring;
o administrative costs of implementing performance provisions – including at
the level of EU budget beneficiaries, such as businesses – regarding
monitoring and reporting, as well as implementation of e.g. the DNSH
principle, as well as costs of access to information of EU budget performance
and funding opportunities, including by beneficiaries, budgetary authorities,
implementing partners, partner countries and EU institutions.