COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL establishing a budget expenditure tracking and performance framework and other horizontal rules for the Union programmes and activities

EN EN
EUROPEAN
COMMISSION
Brussels, 16.7.2025
SWD(2025) 590 final
COMMISSION STAFF WORKING DOCUMENT
IMPACT ASSESSMENT REPORT
Accompanying the document
Proposal for a
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
establishing a budget expenditure tracking and performance framework and other
horizontal rules for the Union programmes and activities
{COM(2025) 545 final} - {SEC(2025) 590 final} - {SWD(2025) 591 final}
Offentligt
KOM (2025) 0545 - SWD-dokument
Europaudvalget 2025
1
1. INTRODUCTION .................................................................................................................................2
2. PROBLEM DEFINITION .....................................................................................................................4
2.1. What are the problems and their drivers? ..........................................................4
2.2. How likely is the problem to persist? ..............................................................14
3. WHY SHOULD THE EU ACT? .........................................................................................................14
3.1. Legal basis .......................................................................................................14
3.2. Subsidiarity: Necessity of EU action ...............................................................14
3.3. Subsidiarity: Added value of EU action ..........................................................15
4. OBJECTIVES: WHAT IS TO BE ACHIEVED? ................................................................................15
4.1. General objectives............................................................................................15
4.2. Specific objectives ...........................................................................................15
5. WHAT ARE THE AVAILABLE POLICY OPTIONS? .....................................................................16
5.1. What is the baseline from which options are assessed?...................................17
5.2. Description of the policy options.....................................................................18
5.3. Options discarded at an early stage.....................................................................25
6. WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ............................................................25
6.1. Economic impacts......................................................................................26
6.2. Social impacts...........................................................................................29
6.3. Environmental impacts .............................................................................31
7. HOW DO THE OPTIONS COMPARE?.............................................................................................32
7.1. Effectiveness....................................................................................................32
7.2. Efficiency.........................................................................................................35
7.3. Coherence ........................................................................................................38
7.4. Comparison summary ......................................................................................39
8. PREFERRED OPTION .......................................................................................................................42
8.1. Preferred policy option ....................................................................................42
8.2. REFIT (simplification and improved efficiency) ............................................43
8.3. Application of the ‘one in, one out’ approach .................................................43
9. HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? ..................................43
ANNEX 1: PROCEDURAL INFORMATION.............................................................................................45
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT).................................................52
ANNEX 3: WHO IS AFFECTED AND HOW? ...........................................................................................57
ANNEX 4: SME CHECK .............................................................................................................................64
ANNEX 5: COMPETITIVENESS CHECK .................................................................................................67
ANNEX 6: POLICY MAINSTREAMING AND PROGRAMMING ARCHITECTURE OF THE 2021-
2027 BUDGET ....................................................................................................................................69
ANNEX 7: MONITORING FRAMEWORK OF THE 2021-2027 BUDGET............................................116
ANNEX 8: REPORTING FRAMEWORK OF THE 2021-2027 BUDGET...............................................150
ANNEX 9: ANALYSIS OF IMPACTS OF POLICY OPTIONS...............................................................190
2
1. INTRODUCTION
Legal and political context
The true value of the EU budget lies in the tangible impact it delivers on the ground.
Through performance budgeting1
, the EU ensures that every euro is spent effectively and
efficiently, enabling European citizens to get better value for money. The performance
framework of the EU budget is also key to ensure maximum 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.
The implementation of the current and previous EU programmes, as demonstrated by
relevant programme evaluations, has shown that the complexity of the funding
architecture is the major factor hindering the impact of the EU budget. Currently, many
programmes may finance the same activities, but without the same rules and conditions and
there is insufficient flexibility to respond to unforeseen needs. This leads to inefficiencies and
administrative burden for beneficiaries, Member States (MS) and the Commission. In addition,
a difficult budgetary situation – with the start of NextGenerationEU repayments, the increasing
number of EU priorities and the tight fiscal situation of MS – reinforces the need to reduce
identified inefficiencies and administrative burden. The Political Guidelines acknowledge that
‘our spending is spread over too many overlapping programmes – many of which fund the
same things but with different requirements and difficulties to combine funding effectively’.
The Guidelines set out that the new long-term budget needs to be more focused, simpler, with
fewer programmes and more impactful. In line with the Political Guidelines, the College
adopted on 11 February 2025 the Communication ‘The road to the next multiannual financial
framework’, which states that ‘the next long-term budget will have to address the complexities,
weaknesses and rigidities that are currently present and maximise the impact of every euro it
spends’. The Communication also underlines that flexibility is key in guaranteeing the budget’s
ability to respond to a changing reality.
The post-2027 MFF will need to be fit for delivering on EU political priorities such as
competitiveness, security and defence, migration, the green and digital transition, clean
industry, and research and innovation, while also adapting to the evolving needs of the
EU, upholding EU values and ensuring social fairness. The increasing number of policy
priorities that the EU budget will have to address calls for maximising its impact and
performance, in line with the highest standards of financial management. The post-2027 budget
will therefore require a high-quality performance framework to develop its full potential, taking
into account the lessons learned from the 2021-2027 MFF. This performance framework will
need to be designed to strengthen the capacity to deliver against EU policy priorities, respond
flexibly to new realities, ensure accountability, and allow the EU to communicate effectively
with stakeholders and citizens about the EU budget and how it adds value to the lives of EU
citizens.
1
Performance budgeting can be defined as the ‘systematic use of performance information to inform budget
decisions, either as a direct input to budget allocation decisions or as contextual information to inform budget
planning’ Tryggvadottir, Á. and I. Bambalaite (2024), ‘OECD performance budgeting framework’
3
Performance framework of the EU budget
The performance framework of the budget is based on the Financial Regulation, which
sets out a number of performance requirements for the EU budget, as well as programmes
legal basis. It was further framed by the 2021 Communication from the Commission on the
performance framework for the EU budget under the 2021-2027 MFF2
.
This impact assessment report focuses on the performance framework of the EU budget,
which is based on three pillars:
1. Programming horizontal policy priorities such as gender equality and the green transition,
across all EU budget programmes, at all stages of the EU budget decision and
implementation process – preparation, design, implementation, monitoring and evaluation;
2. Monitoring of expenditures contributing to certain horizontal priorities of the EU budget,
and their outputs and results, with evaluations assessing impact;
3. Reporting on the performance of the EU budget including its contribution to and impact
on horizontal priorities: EU budget performance information is reported annually through
relevant reports and dashboards of indicators. Information on funding opportunities – e.g.
calls for proposals – is also displayed through relevant portals.
Performance in the 2021-2027 budget
Under the interinstitutional agreement (IIA) accompanying the 2021-2027 MFF3, the
European Parliament, the Council and the Commission committed to integrate
horizontal priorities into the EU budget, including through spending targets for climate and
biodiversity. The IIA commits in particular to:
• Spend at least 30% of all resources available under the 2021-2027 MFF and
NextGenerationEU on addressing climate change;
• Support biodiversity with a view to working towards the ambition of providing 7.5 % in
2024 and 10 % in 2026 and in 2027 of annual spending;
• Develop a new gender equality expenditure tracking methodology and mainstreaming of
that objective as a pilot as of 2023;
• Report annually on the implementation of the United Nations Sustainable Development
Goals in all relevant programmes.
While the 2021-2027 MFF benefits from a more modern performance framework4, there
remains room for enhancement, notably in terms of simplification, consistency and better
understanding of the results of the EU budget. The post-2027 MFF offers a key opportunity to
address these challenges and maximise the impact of the EU budget, building upon the findings
of the mid-term evaluations of programmes implemented since 2027.
The post-2027 MFF will also need to be aligned with recent legal developments, including
the 2024 Financial Regulation recast5
– which includes new requirements on the principles
2
SWD(2021) 133 final
3
Interinstitutional Agreement between the European Parliament, the Council of the European Union and the
European Commission, 2020 EUR-Lex - 32020Q1222(01) - EN - EUR-Lex
4
Communication on the EU budget performance framework 2021-2027 - European Commission
5
Regulation (EU, Euratom) 2024/2509, Regulation - EU, Euratom - 2024/2509 - EN - EUR-Lex
4
of DNSH, gender equality, performance indicators as well as transparency rules regarding
beneficiaries of EU budget programmes. The impact assessment focuses therefore on the
mainstreaming of the gender equality and DNSH principles because these are legal
requirements. Other policy objectives (such as competitiveness and defence) will be supported
through the steering mechanism of the post-2027 MFF, which will enable to identify and
mainstream relevant priorities across programmes, and through the specific design of
individual programmes such as the European Competitiveness Fund and the policy objectives
of the National and Regional Partnership Plans Fund6
.
This impact assessment aims at defining the performance framework for all EU budget
programmes post-2027, including for the purpose of monitoring and evaluation.
2. PROBLEM DEFINITION
Problem tree: problem drivers, problems and consequences
2.1. What are the problems and their drivers?
2.1.1. Problem 1: Insufficient flexibility and excessive complexity of mainstreaming
provisions
The establishment of a modern performance framework across the EU budget has
enhanced the clarity of programmes intervention logic and understanding of their results.
Through a tracking methodology that accurately identifies green investments – applied
consistently across Cohesion Funds and the Recovery and Resilience Facility (RRF) – and
robust delivery mechanisms, spending objectives and tools – such as climate proofing of
investments or environmental safeguards in the Common Agricultural Policy (CAP), the EU
6
This impact assessment does not consider SDGs as a priority to be mainstreamed per se due to the fact that SDGs
are by definition embracing multiple other priorities, and of a high-level nature.
5
budget has enhanced its capacity to achieve its climate ambitions. This enabled the EU budget
to provide a significant contribution to implementing the Paris Agreement7
, the European
Green Deal8
and the European Climate Law9
.
However, the EU budget operates within a relatively fixed framework which can limit its
ability to adapt to evolving policy priorities and emerging needs, given the long-term
nature of the MFF. Some mainstreaming provisions of the 2021-2027 MFF have an impact
on flexibility, making it more difficult to respond to complex economic and geopolitical issues,
such as crises, pandemics, war and natural disasters, which demand a responsive and agile
budgetary approach10
. This weighs on the EU budget's ability to respond to pressing policy
priorities while simultaneously advancing key long-term objectives, such as the green and
digital transitions and gender equality.
The overlap of several programmes with similar policy scopes and different delivery
models, and limitations to align the EU budget with cross-cutting priorities creates
inefficiencies (cf. Annex 6). The biodiversity spending target and gender equality provisions
of the IIA were not fully matched with the necessary mainstreaming requirements in spending
programmes, leading to inconsistent approaches. As a result, while the climate target is on track
to be achieved, current projections indicate that the 2026 and 2027 biodiversity ambition will
be challenging to meet11
. Divergences have also been observed in how the 'DNSH' principle
has been applied across programmes.12
Problem driver 1: A fragmented MFF structure with multiple mainstreaming requirements at
MFF and programme levels
The 2021-2027 budget features heterogeneous mainstreaming requirements at MFF and
programme levels. Funding is scattered across several EU funds which rely upon a variety of
mainstreaming provisions – defined through programme regulations – which are fixed for the
whole MFF duration, such as programme-level spending targets, budget earmarking and
ringfencing, enabling conditions and conditionality requirements. This may generate barriers
when needing to reallocate funding to the mainstreaming of new priorities in the context of a
complex and dynamic geopolitical and economic environment.
Similar actions are often supported through a variety of mainstreaming tools. For
instance, energy efficiency investments are subject to different conditions under the European
Regional Development Fund (ERDF), Just Transition Fund (JTF), InvestEU, and the
Modernisation Fund. Likewise, renewable energy projects receive funding from multiple
sources – InvestEU, ERDF, and Horizon Europe – each with its own requirements.
7
https://unfccc.int/sites/default/files/english_paris_agreement.pdf
8
https://commission.europa.eu/document/daef3e5c-a456-4fbb-a067-8f1cbe8d9c78_en
9
https://eur-lex.europa.eu/EN/legal-content/summary/european-climate-law.html
10
EU Budget Policy Brief – Lessons for a Future-Proof EU Budget, 2140592d-a44b-4d93-a00b-
4910e9b29584_en
11
AMPR – Annex I – 3. Horizontal policy priorities in the EU, https://op.europa.eu/en/publication-detail/-
/publication/7ebd8cea-2ebe-11ef-a61b-01aa75ed71a1/language-en
12
JRC, The implementation of the ‘DNSH’ principle in selected EU instruments, 2023,
https://publications.jrc.ec.europa.eu/repository/handle/JRC135691
6
Figure: Green mainstreaming toolbox
Problem driver 2: Differences between spending targets applied at MFF and programme level
While being effective in raising general awareness vis-à-vis policy priorities, as well as
contributing to agreed EU objectives and international commitments, horizontal
spending targets – such as the climate and biodiversity targets of the 2021-2027 MFF –
can hamper the responsiveness of the EU budget to address new needs and priorities.
Spending targets have supported investment predictability and helped meet the EU climate and
biodiversity objectives, while contributing to reinforcing industrial competitiveness, energy
security and strategic independence. The climate and biodiversity targets have also helped the
EU to meet its international obligations under the Paris Agreement and the Global Biodiversity
Framework. However, setting a horizontal spending target limits the objectives that can be
financed in the different programmes – which may have different priorities and less potential
to contribute to spending targets set at the beginning of the MFF (e.g. Ukraine facility). Any
spending target set at horizontal level can only work if there is a corresponding alignment of
the policy objectives financed by the programmes. Some programmes such as LIFE and the
EMFAF reached respectively 49% and 28% biodiversity contribution, exceeding the
biodiversity spending target, focusing on nature restoration measures (for LIFE) and on
protecting marine biodiversity and incentivising sustainable fishing (for EMFAF). However,
the multiplicity of objectives to be mainstreamed – such as in the case of external action funds
such as the Neighbourhood, Development and International Cooperation Instrument (NDICI-
Global Europe)13
– may make it challenging to achieve programmes spending targets.
Problem driver 3: Heterogenous mainstreaming provisions included in programmes
Mainstreaming provisions – such as on DNSH, gender equality, climate, biodiversity –
are included in MFF programmes in a heterogenous way14. While this enables to tailor
requirements to the specificities of programmes, it generates complexities and burden for MS
and project beneficiaries such as Small and Medium Enterprises (SMEs) and other businesses
which have to deal with divergent requirements. As a result, beneficiaries face potential
13
Regulation - 2021/947 - EN - EUR-Lex, Article 8.8 (list of objectives to be mainstreamed under NDICI)
14
Full overview of the tools available in the swd_2022_225_climate_mainstreaming_architecture_2021-2027.pdf
and in the Biodiversity tracking methodology for each programme 2021-2027
Ringfencing
Dedicated
programmes
Earmarking (e.g.
strands, budget lines)
Programme target
EU budget-wide target
Programme
design
Objectives
Incentives
Enabling conditions
Reforms incentives
Do no
significant harm
Exclusion list
Technical Guidance
Climate proofing
Environmental impact
assessment
Performance
Framework
Tracking methodology
Monitoring/Indicators
Reporting
7
uncertainties and a lack of predictability, which may negatively impact the competitiveness of
key sectors supported by EU funds, as highlighted by the evaluations15
of a number of EU
budget programmes, as also echoed by the results of the Open Public Consultation.
A number of addition structural reasons hinder mainstreaming, such as the diversity of
management modes, the design and complexity of programmes governance structure, which
can make it difficult to ensure consistent application of horizontal principles across all levels
of policy and implementation. The differences between Member States and third countries in
terms of legal frameworks and political priorities also present additional challenges. These are
often compounded by limited administrative capacity in certain Member States and regions.
The DNSH principle has been applied in a number of EU programmes under the 2021-
2027 period16 but its application remains heterogenous17. The principle is mandatory only
for some programmes and its application faces varying degrees of integration18
. As a result, the
same type of intervention is subject to different DNSH requirements depending on the rules
applying under each programme, which can lead to consistency challenges and difficulties in
channelling multiple sources of funding towards strategic investments19
. The operationalisation
of DNSH through varying technical guidances results in a parallel application of different sets
of technical criteria for similar projects financed under different programmes. As shown by the
evaluations of some programmes, implementing DNSH can generate administrative burden
and may complicate access to funding20
. MS considered that the application of the principle
would have benefited from further guidance21
. Some programmes take into account the
proportionality principle e.g. through DNSH conditions (SCF22
, RRF) or through a monetary
threshold (InvestEU). While several programmes use exclusion lists, including InvestEU,
ERDF, such lists are not aligned, resulting in complexities for beneficiaries and limiting
synergies between programmes. The inclusion of DNSH – where feasible and appropriate in
accordance with the relevant sector-specific rules – in the recast Financial regulation requires
a new approach to operationalise the principle across EU funds.
The biodiversity spending target is likely to be missed due to a lack of policy design tools
and spending targets under sectorial regulations. Current programming suggests that the
target is likely to be missed, with 7.3% of MFF funds dedicated to biodiversity in 2024, and
7.8% and 7.9% expected in 2026 and 2027 respectively. Biodiversity investments account for
2% of green transition investments under the RRF23
, and 6% under the cohesion policy funds.
The Commission’s pledge24
to double external action support to biodiversity by 2027 – through
NDICI-Global Europe and IPA III – is nonetheless on track to be achieved. Biodiversity
finance is likely to continue to rely mostly upon public sources, notably on the MFF, to fulfil
15
Interim evaluation of the InvestEU programme, 2024 – Mid-term evaluation of the RRF, 2024
16
Full overview by tool and by programme available in the climate mainstreaming architecture 2021-2027:
swd_2022_225_climate_mainstreaming_architecture_2021-2027.pdf.
17
Mainstreaming in the post-2027 Multiannual Financial Framework | Think Tank | European Parliament
18
Bruegel study ‘Greening the EU budget: why climate mainstreaming needs reform’, 2025 – European
Parliament ‘Performance and mainstreaming framework for the EU budget – Empirical evidence, analysis and
recommendations’, 2024
19
The implementation of the ‘DNSH’ principle in selected EU instruments, Joint Research Centre, 2023
20
Interim evaluation of the InvestEU programme, 2024
21
ECA special report 13/2024: Absorption of funds from the Recovery and Resilience Facility
22
DNSH technical guidance to the SCF, 2025
23
European Commission (2024), Recovery and Resilience Scoreboard
24
2021 State of the Union Address by President von der Leyen
8
the EU biodiversity commitments until the next decade, including in the context of the
Kunming Montreal Global Biodiversity Framework.
Mainstreaming of gender equality into MFF programmes has seen progress but remains
uneven across the EU budget. A number of programmes have achieved significant progress,
such as NDICI–Global Europe12
and through the Gender Action Plan III13
which set a target
requiring 85% of actions to have gender equality as a principal or significant objective and at
least 5% of those actions to have gender equality as principal objective. Similarly, the Common
Provisions Regulation (CPR) introduced gender equality as a thematic enabling condition,
establishing it as a prerequisite for the effective implementation of EU funds’ specific objective
on gender balanced labour market participation. Horizon Europe and the European Social Fund
also provide explicit gender equality objectives and legal provisions to achieve gender equality.
Nonetheless, in 2023 only 11% of the EU budget is assessed as actively contributing to gender
equality, including due to limited consideration of gender equality in the impact assessments
and the design of some EU funds. Despite the positive trend in gender scores 1 and 225
between
2021-2023, in 2023 a substantial portion of the EU budget (69%) is assessed as not contributing
to gender equality.
Figure: Gender mainstreaming toolbox
2.1.2. Problem 2: The inconsistency and complexity of monitoring requirements hamper the
measurement of the EU budget contribution to policy priorities.
The monitoring requirements of the EU budget are inconsistent, which limits capacity to
measure EU budget performance and inform policy making (cf. Annex 7). The monitoring
of cross-cutting priorities – such as climate, biodiversity and gender equality – has improved
but the current tracking system remains heterogeneous. The performance framework is also not
fully equipped to measure progress of the EU budget’s contribution to cross-cutting priorities
through aggregable performance indicators. Monitoring provisions complexity generates
administrative burden and costs affecting beneficiaries, MS, partner countries, implementing
partners and EU institutions26
, as also echoed by the results of the Open Public Consultation.
25
Score 2 tags interventions primarily aimed at improving gender equality; Score 1 tags interventions with
significant but secondary gender equality objectives; Score 0 tags gender-neutral interventions; and Score 0* tags
interventions with potential gender impact, but for which there is insufficient data available.
26
2024 European Parliament study ‘Performance and mainstreaming framework for the EU budget: Empirical
evidence, analysis and recommendations’
9
Problem driver 1:
The monitoring framework of the EU budget is based on different methodologies to track
expenditures contributing to horizontal priorities across funds. Tracking methodologies
differ between programmes i.e. expenditures allocated to a given intervention type – e.g.
ecosystem restoration – are challenging to measure across MFF programmes because of a lack
of harmonised intervention fields at MFF level. Tracking methodologies differ between policy
priorities, such as under the CAP whereby different methodologies are used for climate and
biodiversity27
. This lack of consistency also hinders the potential to assess and compare
budgetary performance between programmes and MS. Tracking methodologies were mostly
developed after the start of the 2021-2027 period, reducing the potential of programming
decisions to rely on ex-ante expenditure tracking. The European Court of Auditors (ECA) has
made a number of recommendations28
so as to reinforce the consistency of expenditure
monitoring.
On gender equality, expenditure monitoring has significantly improved but continues to
rely on a variety of approaches, and does not sufficiently enable to monitor the impacts
of spending. The gender equality tracking methodology was introduced in 2022 – i.e. after the
adoption of the basic acts of the 2021-2027 budget – which resulted in a variety of approaches
across programmes. Some adopted specific tracking methods, such as the CPR tracking
method, the RRF method based on flagging relevant measures, and the Common Foreign and
Security Policy marker. In 2023, gender score 0* still represents 20% of the EU budget,
showing a decreasing but structural limitation in data collection. The lack of gender-
disaggregated data also remains a challenge, as a number of programmes do not collect or
report indicators broken down by gender, which makes it challenging to evaluate the actual
impact of gender-related investments and make informed decisions about future funding.
Problem driver 2:
There are more than 5 000 – heterogenous, non-aggregable – performance indicators and,
under the RRF, around 7 000 milestones and targets, defined to address different needs
such as assessing performance in the context of the draft budget, monitoring and
evaluation of programmes and MS plans, and payments. Performance indicators are
defined in programme regulations, in dedicated delegated acts as well as in staff working
documents, work programmes and agreements with implementing partners. The CAP and
Cohesion policy funds have developed systems using a limited and aggregable set of indicators,
corresponding to around 360 indicators. In the CAP, the approach even prevents the collection
of MS specific indicators. In cohesion policy, common indicators are used to set targets in
national and regional programmes, with a subset of indicators defined for use in corporate
reporting. The ESF+ uses a monitoring system with a limited set of common indicators and 38
indicators to monitor support in the area of material deprivation, as well as 3 934 additional
programme-specific indicators as part of MS programmes. The RRF uses 14 – common – core
performance indicators aimed at tracking progress towards the Facility’s objectives and, as part
of the performance-based feature of the instrument, 7 129 indicators used as milestones and
27
The methodologies use different approaches e.g. direct payments are counted as 3% under the biodiversity
methodology vs. 40% under the climate one. The climate methodology is less granular than the biodiversity
methodology (Bruegel study ‘Greening the EU budget: why climate mainstreaming needs reform’, 2025).
28
ECA Special report 14/2024 ‘Green transition – Unclear contribution from the Recovery and Resilience
Facility’, Report 09/2022 ‘Climate spending in the 2014-2020 EU budget Not as high as reported’, Report 13/2020
‘Biodiversity on farmland: CAP contribution has not halted the decline’
10
targets to measure progress towards the achievement of a reform or an investment, measuring
outputs and results and triggering corresponding payments. Programmes using indicators to
guide disbursement decisions are an exception, as the vast majority of funds use indicators for
information gathering and monitoring purposes. Indicators are also used in the context of
programmes evaluations29
, which sometimes lack adequate indicators and data to assess the
progress and success of programmes at different stages of their intervention logic. The
management of indicators datasets generates administrative burden for EU institutions and
beneficiaries, as demonstrated by some programmes evaluations30
.
A number of programmes use similar yet slightly different indicators to report on similar
outputs – e.g. regarding high-speed connectivity31
. This fragmented approach results in a large
number of non-aggregable indicators at EU budget level32
, which reduces possibilities to
measure EU budget performance across programmes and to inform policies33
. There are also
significant question marks on the usefulness of a large number of indicators, which provide
unclear added-value while generating significant administrative burden for MFF beneficiaries,
MS, partner countries and EU institutions34
.
The balance between output, result and impact indicators has improved in the 2021-2027
programming period but is not optimal. All three types of indicators are essential to assess
programme performance and follow a different timeline: output indicators provide insight into
what the programme directly finances and its immediate activities (e.g. construction of an
electrified railway); result indicators track the immediate effects of these outputs (e.g. number
of people using the newly constructed railways); and impact indicators measure trends in the
long-term objectives addressed by the intervention (e.g. greenhouse gas emissions avoided). A
comprehensive monitoring framework covering the main policy areas and the most significant
effects with results and impacts is crucial35
.
29
as per Article 34 of the Financial Regulation
30
Mid-term evaluation of the RRF - European Commission and InvestEU programme – interim evaluation
31
For instance, connectivity is measured in the RRF by ‘additional dwellings with internet access provided via
very high-capacity networks’, while CEF measures ‘new connections to high capacity networks for socio-
economic drivers and high quality connections foA recent European r local communities’, and InvestEU uses
‘additional households, enterprises or public facilities that obtained access to high-speed internet’.
32
European Parliament study ‘Performance and mainstreaming framework for the EU budget - Empirical
evidence, analysis and recommendations’, 2024
33
Mainstreaming in the post-2027 Multiannual Financial Framework | Think Tank | European Parliament
34
European Commission 2024, European Union's external financing instruments (2014-2020 and 2021-2027)
35
2025 Council recommendation on the discharge to be given to the Commission in respect of the implementation
of the general budget of the European Union for the financial year 2023
11
Figure: Understanding the different types of performance indicators
Impact indicators are not designed in a manner that facilitates the measurement of long-
term outcomes of programmes beyond their expiration. Visibility of programmes
performance after their expiration needs to improve, particularly for measures funded across
programming periods, such as large-scale infrastructure investments under CEF, research-
funded projects, or ecosystem restoration. One of the challenges linked to measuring impacts
is that benefits often accrue over longer periods than the MFF, for example in the case of
infrastructure projects.
Programme evaluations have provided further information on the fitness for purpose of
the existing framework to measure impacts. The interim evaluations of Erasmus+ and
Creative Europe found that existing indicators are effective for monitoring outputs like
participant numbers and projects funded, but less adequate for capturing long-term impacts,
such as systemic educational reforms or cultural diversity, due to data quality issues and
attribution challenges. Recommendations included simplifying indicator sets, enhancing
qualitative metrics, and improving data collection to better assess performance and impact.
Significant additional data are collected by MS through administrative registers, either
as beneficiary-level data under EU budget programmes or as administrative data
collected under other legal bases. Such registers include national agencies registers or
national statistical office databases. Such data – including information on e.g. location, gender,
enterprise size – is a rich source of analysis and policy learning but is not available in a single
structured framework and therefore remains insufficiently exploited in the context of
performance monitoring.
2.1.3. Problem 3: The fragmentation and duplication in reporting performance information
and funding opportunities across the EU budget leads to reduced transparency and high
administrative burden.
The 2021-2027 performance framework improved reporting, focusing on four areas:
• streamlining – by merging the Programme Statements – Working document I of the Draft
Budget and the Programme Performance Overview into a single, more focused document
annexed to the Annual Management and Performance Report (AMPR);
12
• integrating performance in the annual budgetary cycle – publishing the draft annual
budget proposal and the AMPR on the same day ensures that decisions on next year’s
budget can take into account the results achieved in the previous year.
• providing financial information – including on transfers, contributions from other
countries and stakeholders, and decommitments – moving away from traditional budgetary
presentation based on headings.
• providing context and assessments of how the programmes are performing.
Yet the sheer abundance of documents results in an overload of data, leading to confusion
and potential inconsistencies (cf. Annex 8). The fragmentation and duplication of information
generates administrative burden and reduced transparency for beneficiaries, MS budgetary
authorities, implementing partners and EU institutions.
Problem driver 1:
Reporting requirements – in the context of the discharge, draft budget, strategic
planning, and other programme-specific reports – are not aligned in timing and content.
The reporting framework is fragmented, as it is set by fund-specific regulations in addition to
the Financial Regulation. The Commission provides extensive reporting on the EU budget
performance through the programme performance statements annexed to both the AMPR
(discharge) and the Draft Budget, as well as 32 additional annual reports on specific funds.
This high number of reports increases risks of inconsistencies and reduces transparency for
other EU institutions and MS budgetary authorities36
. Overall the reports prepared by the
Commission are underused as input in steering budgetary decisions despite the significant
resources that are employed in producing them.
Problem driver 2:
The Commission reports performance information through over 20 different publicly
available online dashboards37. Efforts have been made during the 2021–2027 period to
36
2024 European Parliament study ‘Performance and mainstreaming framework for the EU budget: Empirical
evidence, analysis and recommendations’
37
including 4 dashboards published by DG BUDG: EU Financial Transparency System; EU Funded projects | EU
Funding & Tenders Portal; EU Spending and Revenue 2021-2027; Programme Performance Statements
13
enhance transparency and harmonise data publication, such as for the CAP and Cohesion policy
(AgriFood Data Portal, Cohesion Open Data Platform). However, as the organisation and
management of data – as well as the type and granularity of data – are not standardised across
funds, it is not possible to compile information at EU budget level38
. Existing dashboards do
not allow a centralised view of EU budget allocations nor results achieved by sector, such as
transport or education, or by cross-cutting priority, such as climate action or gender
equality3940
. While generating administrative burden, the current reporting system does not
allow for an overview of all EU-funded projects within a specific territory – be it a city, region,
or state.
The recast of the Financial regulation reinforces transparency requirements across the
EU budget as from the next MFF, in particular by requiring to make available on
a centralised website information on recipients of funds financed from the budget41
. The
regulation provides several details regarding the information to be published, the process of
publishing, and the rules for processing data, including personal data. A number of EU funds
under direct and indirect management publish such information through the Financial
Transparency System. However, there is no comprehensive reporting of information on
beneficiaries for programmes under shared management. While the process of obtaining the
necessary information remains subject to sector-specific rules, information still has to be
centralised through a single website as required by the Financial regulation.
Information about funding opportunities is scattered through a large number of portals
due to a lack of interoperability of databases across EU funds. For example, information
about EU funding opportunities for many programmes in direct and indirect management is
made available under the Funding & Tender Portal42
. Information is made available through
several other portals, such as Access to EU Finance43
, the Enterprise Europe Network44
and the
EU Rural toolkit45
. As a result, project promoters cannot easily gain an overview of funding
opportunities available in their region or sector, as they must already be familiar with the
specific funds that could support their projects in order to apply. This lack of visibility
generates confusion, undermines transparency and reduces beneficiaries’ ability – including
local organizations and SMEs – to identify suitable funding sources and access financing under
the EU budget. The fragmentation of portals also augments the likelihood for beneficiaries to
apply and obtain funding from different EU sources for the same project. 72% of respondents
to a Commission survey indicated that they would see value in a one-stop-shop combining EU
and national funding46
.
38
Performance-based Programmes under the post-2027 MFF | Think Tank | European Parliament
39
2024 European Parliament study ‘Performance and mainstreaming framework for the EU budget: Empirical
evidence, analysis and recommendations’
40
For example, it is not possible to obtain information as to how many beneficiaries obtained funding for education
across all EU programmes, or how many kilometres of railways were built.
41
Article 38 of the Financial regulation
42
EU Funding & Tenders Portal
43
https://youreurope.europa.eu/business/finance-funding/getting-funding/access-finance/search/
44
https://een.ec.europa.eu/about-enterprise-europe-network/advice-support/access-eu-funding-programmes
45
https://funding.rural-vision.europa.eu/finder?lng=en
46
2024 Commission STEP taskforce survey on ‘Access to EU funding – users perspective’
14
2.2. How likely is the problem to persist?
The limited ability to aggregate information at the level of the MFF continues
undermining the ability to assess the performance of the EU budget and support an
informed-based EU budget implementation. The issue of inefficient and burdensome
monitoring of performance is therefore likely to persist unless corrective action is taken.
As long as the performance framework remains defined by provisions scattered across
various legal bases of different programmes, ensuring the coherence of these provisions,
rules, and principles will remain a significant challenge. This issue was evident during the
2021–2027 period, when efforts to harmonise provisions across programmes achieved only
limited success. Without a unified performance framework upfront, it would be challenging to
steer the mainstreaming of horizontal priorities in the EU budget in a consistent way and to
form a clear understanding of the EU budget's overall achievements. The current lack of
consistency of performance provisions undermines beneficiaries’ ability to effectively leverage
the financing opportunities offered by the EU budget, in particular for sectors that can be
supported by different EU budget programmes.
3. WHY SHOULD THE EU ACT?
3.1. Legal basis
The legal basis for acting in this area is Article 322(1) TFEU, which requires the adoption of
regulations laying down the financial rules which determine the procedure to be adopted for
establishing and implementing the budget and for presenting and auditing accounts.
In addition, the 2024 recast Financial Regulation requires the principles of DNSH and gender
equality to be taken into account in the next generation of programmes in the post-2027 MFF,
where feasible and appropriate in accordance with the relevant sector-specific rules. Article 38
of the Financial Regulation also foresees new requirements regarding the publication of
information on EU budget recipients and operations, including through a centralised website.
Article 33 of the Financial Regulation further requires appropriations to be used in accordance
with the principle of sound financial management and thus respecting the principles of
economy, efficiency, effectiveness, and focus on performance. It also requires performance
indicators to be aggregable and comply with the RACER standard and, where applicable, be
broken down by gender.
3.2. Subsidiarity: Necessity of EU action
The EU operates a trillion euro budget, holding the potential to drive significant impact
both within the Union and globally, provided it is used and targeted efficiently, in line
with political guidelines. It is essential to have a strong and effective performance framework
in place in order to ensure that the EU budget delivers greater impact in priority areas and that
its effects are measurable, transparent, and capable of driving continuous improvement through
scrutiny and learning. EU action is more particularly necessary based on the following aspects:
• Fulfilment of Treaty objectives: EU action is justified on grounds of subsidiarity in line
with Article 317 of the TFEU, which requires sound financial management. The TFEU also
requires horizontal obligations such as the integration of environmental and climate action
in EU policies and funding programmes. Article 8 of the TFEU also emphasises the need
to promote equality between men and women.
15
• International obligations on climate change and biodiversity: a coherent performance
framework supporting green mainstreaming is necessary at EU level based on its
international obligations under e.g. the United Nations Framework Convention on Climate
Change and the Convention on Biological Diversity.
3.3. Subsidiarity: Added value of EU action
Designing a more efficient performance framework, including the integration of existing
data sources in a coherent manner, necessarily entails the development of a horizontal
approach at EU level so as to maximise the performance of investments contributing to
EU priorities. Making use of the EU budget in favour of e.g. climate, biodiversity and gender
equality has added value, especially for measures that cannot be adequately financed from
national budgets or the private sector, because of the transboundary nature and scale of
challenges, territorial cohesion, just transition needs or uneven levels of climate and
environmental action and fiscal capacity.
4. OBJECTIVES: WHAT IS TO BE ACHIEVED?
4.1. General objectives
The general objective of this initiative is to propose a simplified, coherent and flexible
performance framework for the post-2027 MFF in order to maximise the EU budget
capacity to deliver on policy priorities and effectively assess the performance of EU
budget programmes, while ensuring alignment with the new requirements of the recast
Financial Regulation.
The initiative aims in particular at achieving:
• Increased flexibility and responsiveness of mainstreaming provisions across the
EU budget: the initiative should aim at simplifying and harmonising the provisions
enabling to mainstream horizontal policy priorities across Union programmes so as to
ensure consistency across the EU budget.
• Simplification and streamlining of monitoring requirements across the EU budget
: the initiative should enable to simplify and harmonise expenditure tracking across
Union programmes, enabling to aggregate data across programmes and ultimately
improving the monitoring of the EU budget performance. The initiative should also
enable to streamline the system of performance indicators at MFF level, enabling to
better assess performance, monitoring and evaluation, assessing implementation of MS
plans, funding and payments.
• Harmonisation and rationalisation of reporting performance information and
funding opportunities across the EU budget: the initiative should address the current
fragmentation and duplication in reporting performance information and funding
opportunities across the EU budget. The initiative should enable to harmonise reporting
requirements, rationalise existing systems of dashboard providing performance
information, and harmonise information on available funding opportunities and calls
under the EU budget.
4.2. Specific objectives
This impact assessment aims at evaluating available policy options according to their
ability to deliver on the following specific objectives:
16
1. Increased capacity to address current and future policy priorities, and specific MS and
sectors needs;
2. Reduction of administrative burden and costs affecting EU budget beneficiaries, MS,
partner countries, implementing partners and EU institutions by at least 25%;
3. Enhanced capacity to measure EU budget impact, and inform policies and programmes
management;
4. Increased transparency and access to information for MS budgetary authorities and EU
budget beneficiaries.
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
Objectives tree: problem drivers, general and specific objectives, expected results
5. WHAT ARE THE AVAILABLE POLICY OPTIONS?
The draft impact assessment identifies three possible levels of harmonisation 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
M2: Single methodology to
track expenditures through
intervention fields and a
limited set of common
mandatory performance
indicators, with flexibility to
R2: Single performance
report, single portal on
performance information
and funding opportunities,
with differentiated
operationalisation of the
17
and differentiated
operationalisation per
management mode
adopt additional programme-
specific performance
indicators
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
across programmes (linked to
intervention fields)
R3: Single performance
report, single portal on
performance information
and funding opportunities,
with fully harmonised
operationalisation across
management modes
5.1. What is the baseline from which options are assessed?
Under a baseline situation, the performance provisions set at programme level under the 2021-
2027 period would continue regarding the three identified problems. The baseline does
nonetheless not correspond to a ‘no-policy-change’ scenario, but to a dynamic baseline, as the
performance framework of the EU budget will automatically need to undergo adaptations to
reflect the new architecture of the post-2027 EU budget, which would entail fewer
programmes. If many of the current numerous programmes are consolidated, such programmes
will necessarily result in changes in terms of monitoring and reporting on performance. More
details on the expected impacts of this baseline options are available under Annex 9.
Policy option P1: Programming/mainstreaming of horizontal priorities – Programme-
specific rules on DNSH and gender equality:
Under this option, the mainstreaming of EU policy objectives – e.g. gender equality, climate
and environment – into programming would follow a programme-based approach.
The requirement from the financial regulation to implement programmes and activities taking
into account the principles of DNSH to the environment and gender equality, where feasible
and appropriate and in accordance with sector-specific rules, would be fulfilled using a
programme-based approach, as applied in the 2021-2027 period. Specific DNSH and gender
equality requirements would be established for each EU budget programme, even if the
architecture of the post-2027 MFF features a lower number of programmes than in the 2021-
2027 period.
A specific DNSH guidance or set of requirements would be developed for each EU budget
programme to allow for tailored implementation of the DNSH principle. As a result, a given
intervention – i.e. category of activity – may be subject to different DNSH requirements
depending on the rules applying under each programme.
Gender equality would be mainstreamed through provisions varying across programmes, such
as enabling conditions and other programme-specific requirements.
Policy option M1: Monitoring of expenditures and indicators – Programme-specific rules
for defining tracking methodologies and performance indicators:
This baseline policy option foresees maintaining a programme-based approach towards
monitoring the performance of the EU budget.
18
Programme-specific methodologies would track expenditures contributing to EU policy
objectives. Some programmes would use intervention fields to monitor expenditures, while
other programmes would use different approaches, sometimes requiring a subjective
assessment at project officer level for each intervention and priority.
Programme-specific performance indicators would be adopted e.g. through programmes legal
acts. Programmes would apply different rules for identifying and reporting relevant
expenditures, as well as different sets of performance indicators, therefore limiting the
possibility to aggregate data and evaluate performance at EU budget level.
Policy option R1: Reporting of performance information – Programme-specific reporting
requirements, dashboards and portals:
This baseline policy option foresees maintaining a programme-specific approach to the
reporting of performance information across the EU budget.
Existing performance reporting requirements would be maintained, including heterogeneous
requirements across programmes legal bases.
The multiple dashboards displaying performance information would be maintained.
Transparency requirements regarding the collection, storage and publication of data on
beneficiaries funded by the EU budget would continue to vary across management modes.
Portals informing beneficiaries on funding opportunities would continue through multiple entry
points, with possible adjustments to reflect the architecture of the post-2027 budget.
5.2. Description of the policy options
The impact assessment assesses three combinations of measures i.e. P2+M2+R2, P2+M3+R2
and P3+M3+R3 against the baseline i.e. P1+M1+R1. This section focuses on the description
of each individual policy option.
Programming/mainstreaming of horizontal priorities:
• Policy option P2: Activity-specific rules – harmonised provisions across programmes
on DNSH and gender equality, with calibrated harmonisation and differentiated
operationalisation per management mode
This option foresees operationalising the support for key horizontal policy objectives – such as
gender equality – and implementing the DNSH principle through a harmonised activity-based
approach.
Harmonised DNSH criteria would be set, following a single activity-based approach across the
budget, contrary to the programme-based guidance in place in 2021-2027. Economic activities
would be subject to harmonised DNSH requirements defined upfront by type of intervention,
where feasible and appropriate and in accordance with sector-specific rules. Under this single
system, MS, implementing partners, project promoters and other final recipients would have a
clear understanding of the applicable DNSH requirements for each intervention type. While
this option relies upon the adoption of a single DNSH guidance across programmes, it takes
into account the proportionality principle as well as the specificities of programmes
management modes (direct, indirect, shared), the type of support (e.g. grants, guarantees, loans)
and the size of the project. The application of the principle would also be adapted to external
action to take into account differences in the environmental and climate legislation of partner
19
countries. The guidance defining DNSH conditions applying to each group of intervention
fields could also consider a bespoke approach for example in the case of sensitive sectors (such
as certain defence and security activities).
In line with the Financial Regulation, programmes and activities will need to be implemented
taking into account the principle of gender equality, where feasible and appropriate and in
accordance with sector-specific rules. Under this policy option, gender equality requirements
would be set at EU budget level, supported by a single guidance and provisions tailored to
management modes, enabling to support compliance by MS, partner countries and
implementing partners with the gender equality requirements of the Financial Regulation. This
option foresees mainstreaming gender equality into a number of programmes for which gender
equality is assessed as specifically relevant and appropriate. Specific gender equality
provisions would be included into the design of programmes, for example by requiring MS to
demonstrate how their national plans contribute to gender equality or by including gender
equality provisions in the evaluation procedure of calls for proposals for programmes under
direct management. The single guidance would support the mainstreaming of gender equality
during the programming and implementation phases of the funds in a consistent way.
In addition, EU budget expenditure promoting gender equality would be monitored through a
single methodology applying a system of gender scores building on the 2021-2027
methodology as well as the OECD methodology. Performance indicators would be
disaggregated by gender where relevant, in line with the Financial Regulation.
Under this policy option, the programming and mainstreaming of horizontal priorities across
programmes would be done through harmonised provisions at EU budget level, but with
differentiated operationalisation per management mode, tailored for example to:
- work programmes, calls, procurements or contracts under direct management;
- work programmes and agreements with implementing partners under indirect management;
- MS to make a DNSH and gender equality assessment under shared management;
- the approach for implementing the DNSH and gender equality principle would also be
differentiated between internal and external action.
• Policy option P3: Activity-specific rules: fully harmonised provisions on DNSH and
gender equality
Similar to policy option P2, this option foresees operationalising the support for key horizontal
policy objectives – such as gender equality – and implementing the DNSH principle through a
harmonised activity-based approach, where feasible and appropriate in accordance with the
relevant sector-specific rules, supporting alignment with the new requirements of the recast
Financial Regulation.
As under option P2, under this policy option harmonised gender equality requirements would
be set at EU budget level.
This option foresees implementing DNSH through a single activity-based approach applying
to the entire budget, similar to option P2. DNSH requirements would be defined upfront for
each type of intervention, through a single DNSH guidance including technical criteria tailored
to the nature of the activity. Unlike option P2, this option foresees a fully harmonised approach
whereby DNSH technical criteria would apply uniformly to all intervention fields as well as to
20
all management modes (direct, indirect, shared management), all internal and external action,
and all types of support (grants, guarantees, loans).
Monitoring of performance:
• Policy option M2: Single methodology to track expenditures and a limited set of
common mandatory indicators, with flexibility to adopt additional programme-
specific performance indicators
This option foresees the development of a single and simplified expenditure monitoring system
applicable to all MFF programmes. The new system would use a harmonised classification of
interventions financed by the EU budget – through intervention fields – providing a
comprehensive, aggregated view of how EU funds are allocated. This system would be the
basis to estimate expenditures contributing to cross-cutting policy objectives (e.g. climate
mitigation and adaptation, biodiversity), by applying percentage-based coefficients (e.g. 0%,
40%, 100%) to these intervention fields.
The single list of intervention fields would build on existing intervention fields e.g. in cohesion,
and EU strategic objectives and priorities. The system would take into account the specificities
of programmes management modes (direct, indirect, shared), distinctions between internal vs.
external action, and the type of support (e.g. guarantees, grants, loans). The list of intervention
fields would enable to capture new financing areas, as the list could be revised during the
implementation phase of the MFF, as relevant. MS would programme measures in their plans,
assigning a given intervention field to each measure.
This option foresees the adoption of a short set of common indicators mandatory across
programmes – similar to shared management programmes having common indicators used by
all MS in 2021-2027, such as the 14 common indicators of the RRF. This would enable
aggregation at EU budget level for a small number of output and result indicators with a view
to monitoring the effects of the EU budget towards common strategic objectives. MS,
implementing partners and the Commission would collect data on such common indicators and
regularly report their figures for the purpose of corporate reporting.
In addition to this short list of mandatory common indicators across EU budget programmes,
this policy option foresees the development of a standardised, yet indicative, set of performance
indicators at MFF level – including output and result indicators. These indicators would be
directly linked to the new set of intervention fields. Such indicators would be available for use
by EU budget programmes under direct, indirect and shared management, but offering
flexibility to adopt additional programme-specific performance indicators tailored to the
specific needs of programmes. For example, programme-specific indicators could be adopted
for the purpose of assessing performance47
, for the purpose of evaluation of programmes48
, and
to monitor implementing partners in the context of shared management49
and in the context of
financing not linked to costs50
– in cases where a data gap is identified. In the case of
47
as per Article 33 of the Financial Regulation
48
as per Article 34 of the Financial Regulation
49
as per Article 158 of the Financial Regulation
50
as per Article 125 of the Financial Regulation
21
performance-based forms of funding, additional targets or steps – tailored to the specific nature
of the concerned measures – could be adopted by Member States and third countries as part of
their plans. Indicators would be defined based on a common methodology, following the Better
Regulation Toolbox, including the RACER51
approach and other criteria52
.
This option further relies on the obligation for MS to share with the Commission key data at
beneficiary level, enabling to exploit data collected by MS to operate each policy, including
information on e.g. location, gender, enterprise size of the beneficiaries.
• Policy option M3: Single methodology for the EU budget to track expenditures
through intervention fields, and fully harmonised list of performance indicators
across programmes (linked to intervention fields)
Similar to option M2, this option foresees a single expenditure monitoring system applicable
to all programmes, relying upon a harmonised list of intervention fields covering all activities
financed by the MFF. The system would enable to estimate the EU budget contribution to
priorities, such as climate, by applying percentage-based coefficients (e.g. 0%, 40%, 100%) to
these intervention fields. For example, in the case of programmes under shared management,
MS would programme measures in their plans, assigning a given intervention field to each
measure or sub-measure in the plan.
This option foresees the development of a standardised set of – mainly output and result –
performance indicators at EU budget level. This approach would reduce the overall number of
performance indicators, and ensure alignment with the new requirements of the recast Financial
Regulation requiring to aggregate performance indicators across programmes. Relevant
performance indicators would be attributed to each intervention field. As under option M2, a
common methodology would be defined for each indicator based on the Better Regulation
Toolbox guidance on the development of indicators.
Similar to option M2, in the case of performance-based forms of funding, MS, partner
countries, and implementing partners would define performance steps or milestones using the
pre-defined output indicators linked to relevant intervention fields as part of the single list. In
a financing not linked to costs scheme, fulfilling such steps or milestones – through reporting
against relevant output and result indicators – would trigger payments, not linked to
expenditure of MS. In exceptional cases where a measure would deliver an output not covered
by the single list, additional performance steps or milestones – tailored to the measure
specificities – could be adopted. The specificities of financial instruments (repayable support)
51
Relevant, Acceptable, Credible, Easy and Robust
52
E.g. attributable (changes in the indicator should be attributable to the initiative; data should be easily available
and of a good quality, ideally at national or regional level), timeliness (indicators should capture the effects due
to the initiative within a reasonable length of time, taking into account the frequency of measuring indicators),
baseline and target value (the indicator should be based on a clear baseline and assumptions to derive the target
value from the baseline), metadata (indicators definition should include a unit of measurement, the source of the
data, entities in charge of data collection and reporting, frequency of data collection/reporting, and any other
information relevant to facilitate data sharing, use and aggregation)
22
would be taken into account. The set of common intervention fields would also enable the
Commission to report its external support to the OECD DAC53
.
Unlike option M2, this option foresees a fully harmonised approach whereby a single common
set of indicators would apply to all programmes. This would result in a reduction of the overall
number of performance indicators across the EU budget, ensuring consistency across
programmes. Output and result indicators would be specific to each policy area and related
intervention fields, ensuring effective monitoring of the outcomes of funding for each type of
activity while allowing aggregation of data across EU funds. Different from option M2, the
single list of performance indicators would not merely be indicative but would constitute the
indicators for monitoring the performance of EU budget programmes, as well as the indicators
used as performance steps or targets in performance-based forms of funding used for e.g. MS
plans or under external action. Member States would be required to report on at least one output
indicator (used as target) and at least one result indicator for each measure of their plan. The
single list of indicators would also serve as indicators used for the purpose of evaluations of
programmes. This option does not foresee any short set of common indicators against which
reporting would be mandatory across programmes, since all funds would use the single set of
indicators.
Because the common list will include ca. 500 intervention fields reflecting the objectives of
programmes, and because the list will include indicators attached to each intervention field,
there will be several indicators available to monitor the achievement of programme objectives
and therefore enable robust evaluations.
This option relies on the obligation for MS to share with the Commission key data at
beneficiary level, enabling to exploit data collected by MS to operate each policy, including
information on e.g. location, gender, enterprise size of the beneficiaries. The Commission
would calculate output and result indicators based on these data, where feasible, further
reducing administrative burden on MS, and optimizing the monitoring of the performance of
EU budget programmes. This option also entails increased use of Member States administrative
registers as a way of collecting further data useful for performance monitoring. It also foresees
modernising data collection processes and strengthening the use of artificial intelligence (AI)
to achieve further efficiency gains as well as modernizing data sharing and improving
interoperability of databases. This is likely to help modernise data collection, help Member
States to allocate projects to intervention fields, and contribute to the cleaning, processing, and
analysis of performance data, while also enhancing data quality and reliability control
mechanisms. AI may also help in the future in terms of inter-operability of databases, in a
context where performance information remains scattered across several Commission
databases, which limits aggregation of indicators across programmes.
AI is evolving at fast pace hence it remains difficult to anticipate the exact role that it will play
in operationalizing the performance framework of the post-2027 budget. Yet it is expected to
help modernise data collection, such as by helping Member States to allocate projects to
intervention fields, and to contribute to the cleaning, processing, and analysis of performance
53
Development Assistance Committee of the Organisation for Economic Co-operation and Development
23
data, while also enhancing data quality and reliability control mechanisms. AI may also help
in the future in terms of inter-operability of databases, in a context where performance
information remains scattered across several Commission databases, which limits aggregation
of indicators across programmes. Lastly, future AI tools could also help make the reporting of
performance information more interactive for the end users.
Figure: Possible architecture of intervention fields, tracking coefficients, and indicators
24
Figure: Example of a measure in a MS plan, and subsequent aggregation with data from other MS, and
data from Competitiveness and external action funds
Reporting of performance:
• Policy option R2: Single performance report, single portal on performance
information and funding opportunities, with differentiated operationalisation of the
single portal per management mode or sector
This option foresees harmonised requirements on performance reporting. Under this option,
there would no longer be programme-specific reporting requirements, consolidating all EU
budget performance information into the AMPR, i.e. merged with the Programme Statements
accompanying the Draft Budget prepared by the Commission.
Performance information on the EU budget would be publicly accessible through a single
online portal presenting a dashboard of what the EU budget achieves. This platform would
provide comprehensive insights, including on budget implementation, expenditure monitoring
by intervention field and horizontal priorities, and performance indicators. The portal could be
modelled after the existing Open Data Platform for cohesion, ensuring transparency and ease
of access for citizens and budgetary authorities. This policy option foresees a differentiated
operationalisation per management mode or programme, whereby the single portal would
enable to display specific data regarding dedicated areas and sectors, and performance
information presenting specific programmes achievements.
The recast Financial Regulation reinforces transparency requirements across the EU budget as
from the next MFF, including by requiring a centralised website with information on
beneficiaries and operations. This option foresees harmonising rules for transparency across
programmes regarding collecting, storing and publishing data on beneficiaries and operations
supported by the MFF, including publication of data through the single portal.
Existing portals providing information on available funding opportunities would be replaced
by the single portal centralising all information under the EU budget, improving transparency
and access to information, in particular for project promoters and potential beneficiaries.
Building upon the approach followed with the Funding & Tenders and the STEP portals, this
centralised system would address the shortcomings identified in the current system, such as the
complexity of navigating multiple portals, lack of interoperability, and unequal access to
25
funding information, particularly for SMEs and small organisations. The single portal would
serve as a single entry point enabling applicants to directly submit their financing applications
through the portal. AI advisory support could provide advice on appropriate funding source
identification for potential beneficiaries. This option foresees a differentiated
operationalisation per management mode or programme, whereby the single portal could
display programme-specific information regarding available funding opportunities. The portal
would also include links redirecting users to more specific sources such as portals hosted e.g.
by MS and regions.
• Policy option R3: Single performance report, single portal on performance
information and funding opportunities, with fully harmonised operationalisation
across management modes
Similar to policy option R2, this option foresees a single performance report, consolidating all
EU budget performance information into the AMPR, merged with the Programme Statements
accompanying the Draft Budget.
Performance information on the EU budget would be publicly accessible through a single
online portal. Data on beneficiaries and operations supported by the EU budget would be
managed and published in a harmonised way across all management modes through the single
portal. Unlike policy option R2, the single portal would not include sections regarding specific
policy areas or sectors.
Similar to option R2, under this option a single portal centralising all information on available
funding opportunities would replace existing portals. Unlike option R2, this option foresees a
fully harmonised approach whereby the single portal would not display programme-specific
information on funding opportunities. The portal would also integrate and replace portals
hosted e.g. by MS and regions.
5.3. Options discarded at an early stage
The impact assessment focuses on assessing three combinations of measures i.e. P2+M2+R2,
P2+M3+R2 and P3+M3+R3 against the baseline i.e. P1+M1+R1. Other combinations of
measures are discarded in the impact assessment, such as combining fully harmonised
programming provisions with a reporting approach relying upon differentiated
operationalisation of the single portal per management mode or sector. Combining a fully
harmonised reporting approach with a monitoring system differentiated across programmes
would also not be a realistic option, given that reporting performance information across the
EU budget in a fully harmonised way would not be feasible if monitoring approaches – and
resulting performance indicators – are partly heterogeneous across programmes.
6. WHAT ARE THE IMPACTS OF THE POLICY OPTIONS?
This section assesses the economic, social and environmental impacts of policy options P2,
M2, R2 and P3, M3, R3 against the baseline i.e. policy options P1, M1, R1. Annex 3 further
describes the practical implications of the initiative – in particular for EU budget beneficiaries,
MS, partner countries and implementing partners as well as EU institutions – as well as the
costs and benefits of the initiative, and expected impacts in terms of contributions to the UN
SDGs. Annexes 5 and 10 provide further details in relation to the impacts of the initiative on
competitiveness and SMEs respectively. Annex 9 includes a qualitative analysis of policy
options P1, M1 and R1 as well as a quantitative analysis of the impacts of all policy options.
26
6.1. Economic impacts
a. Impacts of options on programming/mainstreaming of horizontal priorities:
Policy option Economic impacts
P2: Activity-
specific rules:
harmonised
provisions across
programmes on
DNSH and gender
equality, with
calibrated
harmonisation
and differentiated
operationalisation
per management
mode
A single DNSH guidance would enable MS, partner countries and beneficiaries – including
businesses – to achieve cost reductions. Economic benefits would be achieved by reducing
the resources currently required to apply multiple DNSH guidances and sometimes
contradictory requirements, enabling higher predictability and facilitating access to EU funds.
Option P2 follows a calibrated and proportionate approach – whereby DNSH provisions
would be implemented in a differentiated manner depending on the management mode, and
the type of action (internal vs. external) – which is expected to reduce administrative burden
and facilitate compliance. A single DNSH guidance would require one-off costs for the
Commission to develop a set of technical criteria and provide technical support to MS on the
new DNSH approach, but it would reduce resources by the Commission to develop and
implement multiple DNSH guidances, reducing the need for capacity building to MS and
beneficiaries, as the technical criteria would be the same across programmes. Exempting a
list of intervention fields from DNSH checks in the cased of defence and security would
reduce the resources needed by the Commission to develop technical criteria across the list
of intervention fields, since part of the list would not require developing such criteria.
This option also foresees a harmonised approach towards gender equality, which is expected
to achieve efficiency gains compared to 2021-2027 where beneficiaries must navigate and
comply with heterogeneous requirements, e.g. in the case of activities eligible under different
EU funds. It would also have positive economic impacts due to the role of gender equality in
enhancing competitiveness and inclusivity, in the context of the Union of Equality.
Competitiveness: Option P2 would support the competitive growth of companies and
economic sectors supported by EU funds and support international competitiveness vis-à-vis
third countries. Harmonising DNSH and gender equality requirements would facilitate
regulatory compliance by businesses and enhance market responsiveness. This would reduce
the complexity of compliance, enabling beneficiaries – e.g. businesses – to devote fewer
resources to navigating regulatory landscapes, enabling time and cost savings.
SMEs: Implementing a harmonised approach to DNSH and gender equality across the EU
budget is expected to bring benefits for SMEs, which are particularly challenged by complex
regulations and administrative burdens. The calibrated approach foreseen under option P2 is
expected to help SMEs by reducing the need to comply with varying requirements, ultimately
facilitating their access to EU funds, though this may also reduce incentives for SMEs to
innovate.
P3: Activity-
specific rules:
fully harmonised
provisions on
DNSH and gender
equality
Similar to P2, this option would enable cost reductions by MS, partner countries and
beneficiaries – including businesses – linked to the single DNSH guidance.
Unlike policy option P2, this option foresees full harmonisation of DNSH requirements,
which would bring full clarity on DNSH implementation, but would generate administrative
burden and complicate compliance by MS, partner countries and beneficiaries, achieving
reduced economic benefits compared to option P2, including because of a lack of
differentiated implementation per management mode. Systematic DNSH checks to all
interventions financed by the EU budget would increase the resources needed by the
Commission to develop technical criteria across the whole list of intervention fields, without
exceptions.
This policy option also foresees a harmonised approach towards gender equality
requirements. This would enable MS and beneficiaries to achieve efficiency gains compared
to 2021-2027 where beneficiaries must navigate and comply with heterogeneous
requirements, in particular if eligible under different EU funds.
27
Competitiveness: A fully harmonised DNSH and gender equality approach would simplify
implementation by MS, partner countries and beneficiaries – including businesses – which
would facilitate regulatory compliance. Full harmonisation of DNSH requirements is
nonetheless likely to complicate implementation by beneficiaries, since DNSH requirements
would apply to all intervention fields supported by EU funds, to all management modes and
to all types of action (internal and external) in a similar way, which is likely to create barriers
to accessing EU funds. A fully harmonised approach may therefore undermine the
competitive growth of companies and economic sectors supported by EU funds.
SMEs: Similar to policy option P2, the harmonised and simplified approach to DNSH and
gender equality mainstreaming across EU funds is expected to bring several benefits for
SMEs, which are particularly challenged by complex regulations and administrative burdens.
A fully harmonised approach to DNSH is nonetheless likely to make it more difficult for
SMEs to access EU funds, because all projects would be subject to DNSH checks, resulting
in maintaining certain barriers to entry and reducing success rates in funding applications,
reducing opportunities for SMEs to mobilise additional capital.
b. Impacts of options on monitoring of performance:
Policy option Economic impacts
M2: Single
methodology to
track expenditures
through
intervention
fields, and a
limited set of
common
mandatory
indicators, with
flexibility to
adopt additional
programme-
specific
performance
indicators
This option would enable to achieve cost reductions linked to a harmonised classification of
activities financed by the EU budget – so as to enable simple tracking of expenditures through
intervention fields – and a simplified set of performance indicators at MFF level.
This option also foresees the possibility to adopt additional programme-specific performance
indicators, which would result in the adoption of further indicators. Compared to option M1,
this option is likely to reduce administrative burden but only to a certain extent, as MS, partner
countries and beneficiaries as well as the Commission and EU agencies would also deal with
additional indicators per programme, though the new architecture of the post-2027 MFF and
the reduction of the number of EU budget programmes is expected to slightly reduce
monitoring burdens. The adoption of programme-specific indicators may enable to adopt
more specific indicators in view of evaluations, ultimately enabling more effective policy
steering, and higher benefits to the economic sectors supported by the EU budget. At the same
time, this option would limit indicators aggregation across programmes, which would reduce
the ability to steer EU budget support to the most strategic sectors for the EU economy. The
adoption of a limited but mandatory set of common indicators is expected to generate
administrative burden as MS, third countries, implementing partners, beneficiaries and the
Commission would have to report against this additional set of common indicators.
Competitiveness: This option could enable to track contributions to new EU priorities such
as competitiveness, but programme-specific indicators would reduce the ability to aggregate
competitiveness-relevant indicators across funds. Programme-specific indicators – translated
in contracts or grant agreements – is overall expected to generate administrative burdens and
hinder the competitiveness of companies and economic sectors supported by EU funds.
SMEs: SMEs, often limited by resources and staff, are expected to benefit from reduced
complexity in indicators reporting requirements, but the adoption of programme-specific
indicators may maintain administrative burden on SMEs, maintaining complex indicators
monitoring and reducing access to EU funds.
M3: Single
methodology for
the EU budget to
track expenditures
through
intervention
fields, and fully
This option would achieve cost reductions due to the harmonised classification of activities
financed by the MFF and a simplified set of performance indicators at MFF level. While the
system would entail entry costs, MS, third countries and the Commission would in the longer
run reduce resources allocated to dealing with expenditure tracking and indicators monitoring.
Reducing the number of performance indicators would enable beneficiaries to face less
reporting burden and reduce the costs associated with project monitoring. In cases where a
measure addresses a dimension not covered by the single list, this policy option foresees the
28
harmonised list of
performance
indicators across
programmes
(linked to
intervention
fields)
possibility for MS to adopt e.g. milestones and targets – tailored to their specificities – as part
of their national plans, which would achieve economic benefits by enabling to tailor
milestones and targets to MS specific investment and reform needs in key economic sectors.
Competitiveness: This option could enable to track contributions to new EU priorities such
as competitiveness. A simplified approach to indicators in contracts or grant agreements is
expected to reduce administrative burden and support the competitiveness of economic
sectors supported by EU funds. By allowing companies to reduce compliance and monitoring
costs, this option would enhance companies’ efficiency and support the competitiveness of
EU businesses, including in terms of international competitiveness vis-à-vis third countries.
SMEs: This option would achieve reduced complexity in monitoring and reporting by SMEs.
Access to EU funds would increase by lowering entry barriers and facilitating reporting
processes, leading to faster approvals and payments to participating SMEs.
c. Impacts of options on reporting of performance:
Policy option Economic impacts
R2: Single
performance
report, single
portal on
performance
information and
funding
opportunities,
with
differentiated
operationalisation
of the single
portal per
management
mode or sector
This option would achieve cost reductions linked to harmonised performance reporting,
consolidating all information into the AMPR. The Commission would achieve efficiency
gains and reduce the resources currently allocated to preparing multiple reports. Other EU
institutions – e.g. European Parliament – budgetary authorities and interested stakeholders
would reduce the costs currently allocated to navigating and processing multiple reports on
the performance of the EU budget. The new system would promote transparency of
performance information and efficient data utilisation for policy decisions.
A single online portal displaying EU budget performance information would also enable MS
and beneficiaries to reduce the costs currently allocated to navigating and processing multiple
dashboards. A single entry point would enable MS, partner countries and beneficiaries to
reduce the costs currently allocated to navigating multiple portals on available funding
opportunities, facilitating access to EU funds by beneficiaries in key economic sectors. The
Commission would also reduce the costs currently allocated to the management of multiple
dashboards and portals, though the development of such a single portal would require one-
off costs for the Commission to develop the new system.
The single portal would enable to display specific data regarding specific economic sectors,
which may deliver economic benefits by increasing transparency and access to information
by stakeholders in relevant economic sectors. The simple inclusion of links to MS and regions
portals is expected to have limited resources implications for the Commission, while
facilitating access to information on funding opportunities available to beneficiaries in
relevant economic sectors, potentially achieving economic benefits.
Competitiveness: A single portal on information on EU budget performance and funding
opportunities could streamline processes and simplify navigation, ultimately reducing costs
and enhancing the competitiveness of businesses supported by the MFF.
SMEs: SMEs, which operate with limited staff and resources, are disproportionately affected
by the complexity of existing EU portals displaying information on funding opportunities.
With a single portal, SMEs could quickly access information, helping them to become more
responsive to new support opportunities and secure funding under EU funds.
R3: Single
performance
report, single
portal on
performance
information and
funding
opportunities,
Similar to option R2, this option would achieve cost reductions linked to harmonised
requirements on performance reporting. The Commission would achieve efficiency gains and
reduce the resources allocated to preparing performance reports.
A single online portal displaying performance information would enable MS, other EU
institutions (e.g. Parliament), partner countries and beneficiaries to reduce the costs currently
allocated to navigating multiple dashboards. This option would also enable to reduce costs
thanks to the single portal providing information on funding opportunities, including for the
Commission, though the development of such a portal would require entry costs.
29
with fully
harmonised
operationalisation
across
management
modes
Unlike option R2, the single portal would not display specific data regarding e.g. specific
economic sectors, which is expected to deliver reduced economic benefits by reducing
transparency and access to information by stakeholders active in relevant economic sectors.
The single portal would also integrate and replace specific sources such as portals hosted e.g.
by MS and regions, which would entail higher entry costs than option R2 in particular for the
Commission. Such a system would nonetheless significantly increase access to information
on funding opportunities available to beneficiaries in relevant economic sectors.
Competitiveness: Similar to option R2, a single portal on EU budget performance and funding
opportunities would provide a single entry point, reduce costs, and enhance the
competitiveness of businesses supported by EU funds. A portal not displaying specific data
on e.g. key economic sectors may nonetheless reduce transparency and access to information
by stakeholders in economic sectors, which may negatively affect competitiveness.
SMEs: Similar to option R2, a single portal is likely to help SMEs to quickly access
information, enabling faster decision-making and efficiency gains, helping them to become
more responsive to new support opportunities under EU budget programmes.
6.2. Social impacts
a. Impacts of options on programming/mainstreaming of horizontal priorities:
Policy option Social impacts
P2: Activity-
specific rules:
harmonised
provisions across
programmes on
DNSH and gender
equality, with
calibrated
harmonisation
and differentiated
operationalisation
per management
mode
Under this option, gender equality requirements would be systematically embedded in the EU
budget and in the design of relevant programmes. This would enhance the overall efficiency
and inclusivity of EU programmes, fostering equitable outcomes for all citizens both in EU
MS and partner countries. This approach aligns with the EU's broader commitment to
inclusivity and equity, ensuring that gender consideration are integrated consistently at all
levels of planning, implementation, and evaluation.
Under this option, the programming and mainstreaming of gender equality would be
differentiated per management mode, which is expected to have positive social impacts by
enabling an effective mainstreaming approach across EU budget programmes.
P3: Activity-
specific rules:
fully harmonised
provisions on
DNSH and gender
equality
Similar to option P2, this option foresees embedding gender equality requirements in the EU
budget and in the design of relevant programmes. Such an approach is expected to achieve
social outcomes by fostering the inclusivity of EU programmes.
Unlike option P2, this option foresees a fully harmonised approach to gender equality
mainstreaming without differentiation per management mode. This is expected to have lower
positive social impacts as it may result in less effective mainstreaming of gender.
b. Impacts of options on monitoring of performance:
Policy option Social impacts
M2: Single
methodology to
track expenditures
and a limited set
of common
mandatory
indicators, with
Under this option, EU budget expenditure promoting gender equality would be monitored
through a single methodology applying a system of 'gender scores' building on the 2021-2027
methodology as well as the OECD methodology. Performance indicators would also be
disaggregated by gender where relevant, in line with the requirements of the Financial
Regulation. Gender disaggregated data is likely to help identify areas where gender disparities
exist under sectors or areas supported by EU funds, which may help addressing the unique
30
flexibility to
adopt additional
programme-
specific
performance
indicators
needs and challenges faced by gender groups. This option would therefore achieve social
outcomes by enabling to consistently assess the contribution of EU funds to gender equality.
This option foresees the possibility to adopt additional programme-specific indicators, which
may deliver benefits in terms of adopting more specific indicators regarding fundamental
rights and social aspects. This option is nonetheless likely to reduce indicators aggregation
across programmes, including social indicators, which would reduce the ability to steer EU
budget support to fundamental rights and social priorities.
M3: Single
methodology for
the EU budget to
track expenditures
through
intervention
fields, and fully
harmonised list of
performance
indicators across
programmes
(linked to
intervention
fields)
Similar to option M2, expenditure promoting gender equality would be monitored through a
single methodology applying a system of 'gender scores' across programmes. The fully
harmonised list of performance indicators would enable to aggregate indicators across
programmes, including social indicators, enabling to enhance the policy steering of EU
budget support to fundamental rights and social priorities. Performance indicators would be
disaggregated by gender where relevant, which would achieve social outcomes by more
consistently assessing the contribution of programmes to gender.
This option foresees a differentiated operationalisation of indicators per management mode,
allowing to adopt e.g. milestones and targets tailored to MS specific needs in their plans.
Similar to option M2, this option would deliver higher social outcomes than option M1, e.g.
if MS were to adopt social-related milestones and targets addressing specific fundamental
rights and social challenges at national level.
c. Impacts of options on reporting of performance:
Policy option Social impacts
R2: Single
performance
report, single
portal on
performance
information and
funding
opportunities,
with
differentiated
operationalisation
of the single
portal per
management
mode or sector
Consolidated reporting requirements – through a single performance report – would improve
transparency of information, including regarding the EU budget contribution to social
priorities such as gender equality. This is likely to achieve positive social outcomes as it
would increase access to information for budgetary authorities and MS on how the EU budget
contributes to gender equality, which may help policymakers to adopt more inclusive and
equitable policies, ensuring that the diverse needs of all gender groups are considered in the
management of EU budget programmes.
This option would facilitate access to information on EU budget funding opportunities
through a single portal. Access by beneficiaries looking for support in the field of social
objectives and equality would be facilitated, which would have a positive social impact.
This option foresees a differentiated operationalisation per management mode or programme,
whereby the single portal would enable to display specific data regarding dedicated areas and
sectors. This may enable to provide the opportunity for displaying information on social- and
equality-related aspects, which would enable to better integrate social considerations back
into the management of EU budget programmes.
R3: Single
performance
report, single
portal on
performance
information and
funding
opportunities,
with fully
harmonised
operationalisation
across
Similar to option R2, this option foresees a single performance report which would enable
improved transparency of information regarding the contribution of the EU budget to gender
equality, which is likely to achieve positive social outcomes.
This option would also facilitate access to information on funding opportunities, including
for beneficiaries in the field of EU social objectives and equality.
Unlike option R2, this option foresees a fully harmonised operationalisation across
management modes, whereby the single portal would not display specific data regarding
dedicated areas and sectors. This may limit possibilities to display information on social- and
equality-related aspects, which would reduce opportunities to integrate social considerations
back into the management of EU budget programmes.
31
management
modes
6.3. Environmental impacts
a. Impacts of options on programming/mainstreaming of horizontal priorities:
Policy option Environmental impacts
P2: Activity-
specific rules:
harmonised
provisions across
programmes on
DNSH and gender
equality, with
calibrated
harmonisation
and differentiated
operationalisation
per management
mode
Under this option, the harmonised approach to DNSH would reduce the potentially
detrimental environmental impact of programmes. This would align projects supported by the
EU budget with EU environmental objectives, such as the European Green Deal, the EU
Climate Law or the Nature Restoration Regulation. By applying the same criteria across
programmes, all funded projects would adhere to environmental safeguards, reducing the risk
of harmful practices. Harmonised DNSH criteria would make it easier for beneficiaries to
understand and comply with environmental requirements, integrating environmental aspects
into project design. The differentiated approach by management mode and by type of action
(internal vs. external) is also likely to enable more effective implementation of the DNSH
principle. The exemptions from DNSH checks – for defence and security – may nonetheless
result in not applying DNSH to projects with potentially environmentally harmful effects.
P3: Activity-
specific rules:
fully harmonised
provisions on
DNSH and gender
equality
Similar to option P2, a harmonised approach to DNSH would reduce the risks of detrimental
environmental impact of EU funds. Simplified DNSH criteria would make it easy for
beneficiaries to understand and comply with environmental requirements. Unlike option P2,
DNSH technical criteria would apply uniformly to all intervention fields, there would be no
differentiation by management mode and by type of action (internal vs. external), which is
likely to lead to less effective implementation of the DNSH principle than option P2. The
absence of exemptions from DNSH checks – for defence and security – would nonetheless
result in systematic DNSH application including to projects with potentially environmentally
harmful effects, which is likely to achieve higher environmental outcomes.
b. Impacts of options on monitoring of performance:
Policy option Environmental impacts
M2: Single
methodology to track
expenditures and a
limited set of common
mandatory indicators,
with flexibility to
adopt additional
programme-specific
performance indicators
Under this option, EU budget expenditure contributing to environmental objectives –
such as climate mitigation, adaptation, and biodiversity – would be monitored through a
common methodology. This option would achieve environmental outcomes by
consistently assessing the contribution of programmes to environmental priorities.
This option foresees the possibility to adopt additional programme-specific indicators,
including regarding environmental aspects. This option is nonetheless likely to reduce
indicators aggregation across programmes, including environmental indicators, reducing
the ability to steer EU budget support to environmental priorities.
M3: Single
methodology for the
EU budget to track
expenditures through
intervention fields, and
fully harmonised list
of performance
indicators across
programmes
Similar to option M2, this option would enable to efficiently monitor EU budget
expenditure contributing to environmental objectives such as climate mitigation,
adaptation, and biodiversity, enabling to achieve positive environmental impacts. The
list of indicators fully harmonised across funds would enable to aggregate indicators
across programmes, including environmental indicators, and enhance the policy steering
of EU budget support to environmental priorities. The adoption e.g. milestones and
targets tailored to MS specific needs in their plans would deliver environmental
outcomes, in particular in case MS were to adopt green milestones and targets addressing
specific climate and environment challenges at national level.
32
c. Impacts of options on reporting of performance:
Policy option Environmental impacts
R2: Single
performance report,
single portal on
performance
information and
funding opportunities,
with differentiated
operationalisation of
the single portal per
management mode or
sector
This option would enable to improve transparency of information regarding the EU
budget contribution to climate mitigation, adaptation, and biodiversity. Access to
information on EU budget funding opportunities would be facilitated, including for
beneficiaries looking for support in the field of environmental objectives.
This option foresees a differentiated operationalisation per management mode or
programme, whereby the single portal would enable to display specific data regarding
dedicated areas and sectors. This may enable to display more detailed information on
climate and environmental aspects, which would enable to better integrate environmental
considerations and challenges back into the management of EU budget programmes.
R3: Single
performance report,
single portal on
performance
information and
funding opportunities,
with fully harmonised
operationalisation
across management
modes
Similar to option R2, this option would enable to improve transparency of information
regarding the EU budget contribution to climate mitigation, adaptation, and biodiversity,
and to facilitate access to information on EU budget funding opportunities, including for
beneficiaries looking for support in the field of environmental objectives.
Unlike option R2, this option foresees a fully harmonised operationalisation across
management modes, whereby the single portal would not display specific data regarding
dedicated areas and sectors. This may limit possibilities to display information on
climate and environment, which would reduce opportunities to integrate environmental
considerations into the management of programmes, compared to option R2.
7. HOW DO THE OPTIONS COMPARE?
This section compares the three possible combinations of policy options i.e. P2+M2+R2,
P2+M3+R2 and P3+M3+R3 – against the baseline i.e. P1+M1+R1 – by assessing the
effectiveness, the efficiency and the coherence of each combination of policy options. Sections
7.1 to 7.3 compare individual policy options, enabling to draw a summary comparison of
possible combinations under section 7.4.
The assessment is based on a system of rating:
= (neutral): the policy option has no significant contribution to effectiveness, efficiency or
coherence.
+ (low positive): the policy option contributes modestly to efficiency, effectiveness or
coherence.
++ (moderate positive): the policy option significantly supports efficiency, effectiveness or
coherence.
+++ (high positive): the policy option strongly advances efficiency, effectiveness or coherence.
7.1. Effectiveness
The effectiveness of the policy options described under section 5 is examined against the policy
objectives identified in section 4, building upon the findings of section 6, and based on the
operational objectives presented in the table below. As specific objective 2 relates to the
reduction of administrative burden, this aspect is treated in a general way under section 7.1
(Effectiveness) and assessed in more details under section 7.2 (Efficiency).
33
Specific objectives Operational objectives
SO1: Increased capacity to address current
and future policy priorities, and specific
MS and sectors needs
- Increase capacity to mainstream gender equality across EU
budget programmes
- Increase capacity to implement the Do No Significant Harm
principle across EU budget programmes
SO2: Reduction of administrative burden
and costs affecting EU budget beneficiaries,
MS, partner countries, implementing
partners and EU institutions by at least
25%
- Reduce costs linked to administrative and reporting burden
affecting beneficiaries, MS, implementing partners and EU
institutions by at least 25%54
SO3: Enhanced capacity to measure EU
budget impact, and inform policies and
programmes management
- Increase capacity to aggregate performance data across EU
budget programmes
- Increase availability of expenditure tracking data and indicators
fit for measuring the performance of EU budget programmes
- Increase availability of performance information to inform
policies and EU budget programmes management
SO4: Increased transparency and access to
information for MS budgetary authorities
and EU budget beneficiaries
- Improve transparency of performance information by
harmonising and centralising Commission reports
- Improve access to information by harmonising and centralising
dashboards displaying performance information
- Improve access to information by harmonising and centralising
portals displaying information on funding opportunities
• Programming/mainstreaming:
The following table provides the assessment of the effectiveness of policy options P1, P2 and
P3 against the operational objectives associated to specific objectives 1 and 255
:
Specific
objective
Policy option P1 Policy option P2 Policy option P3
1 (=) (+++) (++)
2 (=) (+++) (+)
SO1: Both options P2 and P3 are expected to increase the EU budget capacity to mainstream
gender equality and implement the DNSH principle due to their activity-specific approach
relying upon harmonised provisions across programmes. Option P2 is expected to score higher
due to its differentiated operationalisation per management mode, enabling to tailor gender
equality mainstreaming and DNSH implementation to programmes management modes
(direct, indirect, shared management), types of support (e.g. grants, guarantees, loans) and
internal vs. external action.
SO2: Policy option P2 appears to score the highest compared to other options due to its
calibrated approach to implementing the DNSH principle, due to the exemption from DNSH
checks – for defence and security. Such a proportionate approach to implementing the DNSH
principle is expected to generate a significant reduction of costs linked to administrative and
reporting burden affecting beneficiaries, MS, implementing partners and EU institutions
compared to option P3.
54
In line with Commission target of reducing burdens associated with administrative requirements by 25%
55
Specific objectives 3 and 4 are not relevant to comparing options P1, P2 and P3.
34
• Monitoring:
The following table provides the assessment of the effectiveness of policy options M1, M2 and
M3 against the operational objectives associated to specific objectives 2 and 356
:
Specific
objective
Policy option M1 Policy option M2 Policy option M3
2 (=) (+) (+++)
3 (=) (+) (+++)
SO2: Policy option M3 also ranks higher in terms of enabling a significant reduction of costs
linked to administrative and reporting burden affecting beneficiaries, MS, implementing
partners and EU institutions compared to option M2. As described under section 6, option M3
is expected to streamline reporting processes and reduce associated costs, including for
businesses – such as SMEs – supported by EU budget programmes.
SO3: Both options M2 and M3 are expected to increase the EU budget capacity to increase
availability of expenditure tracking data due to the proposed harmonised methodology to track
expenditures through a single list of intervention fields. Policy option M3 appears to score the
highest compared to other options due to its fully harmonised list of performance indicators –
linked to intervention fields – across programmes. While policy option M2 presents the
advantage of enabling the adoption of additional programme-specific performance indicators
in case of specific needs, the effectiveness of option M2 is expected to score lower regarding
the operational objective of increasing the capacity to aggregate performance data across EU
budget programmes, because the single list of performance indicators would only be used on a
voluntary basis per programme, and because programme-specific indicators are expected to
vary across funds, similar to the challenges faced in monitoring performance under the 2021-
2027 period. Comparatively, policy option M3 scores higher because it should enable to
develop a list of performance indicators sufficiently comprehensive and detailed to address the
monitoring needs of all EU funds, while enabling aggregation of data across programmes,
enabling to develop a more robust set of performance indicators enabling to assess EU budget
performance, support financing not linked to cost schemes and effectively evaluate
programmes.
• Reporting:
The following table provides the assessment of the effectiveness of policy options R1, R2 and
R3 against the operational objectives associated to specific objectives 2, 3 and 457
:
Specific
objective
Policy option R1 Policy option R2 Policy option R3
2 (=) (+++) (+)
3 (=) (+++) (++)
4 (=) (++) (++)
SO2: Option R3 ranks higher in terms of enabling a reduction of costs linked to administrative
and reporting burden affecting beneficiaries, MS, implementing partners and EU institutions,
compared to option R2. As described under section 6, option R3 is expected to streamline
56
Specific objectives 1 and 4 are not relevant to comparing options M1, M2 and M3.
57
Specific objective 1 is not relevant to comparing options R1, R2 and R3.
35
reporting processes and reduce associated costs, including for businesses – such as SMEs –
supported by EU budget programmes.
SO3: Both options R2 and R3 are expected to increase the availability of performance
information to inform sectoral and regional policies and programmes management, thanks to
the annual preparation of a single performance report replacing programme-specific reports.
Option R2 ranks nonetheless higher than R3 as the single portal would enable to display
specific data regarding dedicated areas and sectors, and performance information presenting
specific programmes achievements.
SO4: Both options R2 and R3 are expected to improve the transparency of performance
information by harmonising and centralising Commission reports on the performance of the
EU budget, facilitating access to information by MS budgetary authorities and other EU
institutions (e.g. European Parliament). Both options would also enable to achieve increased
transparency of information on beneficiaries and operations through the publication of such
data via the single portal, compared to the baseline. Thanks to the creation of a single portal,
both options R2 and R3 are expected to result in improved access to information by
harmonising dashboards displaying performance data, and to information on funding
opportunities. Option R2 may be considered as ranking higher than R3 as the single portal
would enable to display specific data regarding dedicated areas and sectors, increasing
transparency vis-à-vis MS and stakeholders active in such sectors. Option R3 is nonetheless
expected to score significantly high as it would enable to integrate e.g. MS and regions portals
on funding opportunities in a single portal, enabling beneficiaries to access information through
a single entry point at EU level, compared to option R2 which foresees only the integration of
links redirecting to MS portal.
7.2. Efficiency
The efficiency of the policy options described under section 5 is examined against:
- the expected costs of each policy option, i.e. the reduction of administrative burden
foreseen, and the percentage reduction of such administrative burden compared to objective
of 25%58
, based on the quantitative analysis presented under Annex 9. The analysis focuses
on the costs of each policy option in particular for MS administrations and the Commission,
including entry costs of transitioning to a new system, and potential cost savings and
efficiency gains resulting from reduced administrative burden linked to a harmonised and
simplified performance framework across the EU budget;
- the expected economic (including regarding competitiveness and SMEs), social and
environmental impacts of each policy option, building upon the findings of section 6.
• Programming/mainstreaming:
Policy option P1 Policy option P2 Policy option P3
Costs
Total costs linked to
administrative burden
(=)
EUR 200 million
(+++)
EUR 110 million
(+)
EUR 176 million
Percentage reduction
compared to objective of
25%
0% 45% 12%
58
In line with specific objective 2
36
Benefits
Economic impacts
(including competitiveness
and SMEs)
(=) (+++) (+)
Social impacts (=) (++) (+)
Environmental impacts (=) (+) (++)
Policy option P2 appears to deliver the greatest benefits in terms of reducing costs linked to
administrative burden, exceeding largely the objective of a 25% reduction, reflecting the
expected simplification of DNSH implementation by MS, implementing partners and
beneficiaries, as well as the proportionate approach foreseen under this option.
Option P2 also scores highest in terms of economic impacts, as MS and beneficiaries – such as
businesses – would achieve economic benefits by reducing the resources currently required to
apply multiple DNSH guidances, enabling to achieve higher predictability of projects
implementation and facilitating access to EU funding. Option P2 also ranks higher than option
P3 due to its calibrated and proportionate approach to implementing the DNSH principle,
which is likely to facilitate compliance by businesses, including SMEs, ultimately supporting
the competitiveness of economic sectors supported by EU funds.
Policy option P2 also scores highest in terms of social impacts, as gender equality would be
systematically mainstreamed across EU budget programmes. Yet gender equality
mainstreaming would be differentiated per management mode, which might have positive
social impacts as it would enable more effective mainstreaming across programmes.
In terms of environmental impacts, option P3 achieves the highest benefits as this option does
not foresee any exemptions from DNSH checks for defence and security. Such a systematic
application of DNSH checks, including to defence and security projects with potentially
environmentally harmful effects, is likely to achieve higher environmental outcomes.
• Monitoring:
Policy option M1 Policy option M2 Policy option M3
Costs
Total costs linked to
administrative burden
(=)
EUR 1 401 million
(+)
EUR 1 345 million
(+++)
EUR 841 million
Percentage reduction
compared to objective of
25%
0% 4% 40%
Benefits
Economic impacts
(including competitiveness
and SMEs)
(=) (+) (+++)
Social impacts (=) (+) (++)
Environmental impacts (=) (+) (++)
Policy option M3 appears to deliver the greatest benefits in terms of reducing costs linked to
administrative burden, exceeding largely the objective of a 25% reduction, while option M2
would result in a limited reduction of administrative burden costs i.e. 4%. This reflects the
expected simplification of expenditure tracking and reduction in the number of unique
indicators, e.g. from ca. 5 000 to ca. 900, resulting in a reduction of administrative burden. This
reflects the expected efficiency gains linked to option M3, including reduced data collection,
management and quality control efforts by MS authorities, the processing of indicators by the
Commission, and an improvement in procedural clarity.
37
Option M3 also appears as scoring highest in terms of economic impacts, as beneficiaries and
implementing partners would reduce resources allocated to dealing with multiple expenditure
tracking and indicators monitoring systems, even though this option would entail significant
entry costs. The reduction of the number of indicators would enable beneficiaries such as
businesses – including SMEs – to face less reporting burden and reduce the costs associated
with project monitoring, ultimately supporting the competitiveness of economic sectors
supported by EU funds. Comparatively, under option M2, MS, partner countries and
beneficiaries would deal with both the harmonised list of indicators and additional indicators
per fund. The reporting burden would be slightly lower than under option M1, but would
remain relatively significant, though the reduction of the number of EU funds post-2027 is
expected to slightly reduce monitoring burdens.
Option M3 also appears as scoring highest in terms of fundamental rights, social and
environmental impacts, as this option would enable to aggregate indicators across programmes,
including social and environmental indicators, enabling to enhance the policy steering of EU
budget support to social and green priorities. Option M3 foresees a differentiated
operationalisation of indicators per management mode, which would allow MS to adopt e.g.
environment- and social-related milestones and targets addressing specific fundamental rights
and green challenges at national level, which is expected to deliver higher social and
environmental outcomes than option M1.
• Reporting:
Policy option R1 Policy option R2 Policy option R3
Costs
Total costs linked to
administrative burden
(=)
EUR 70.0 million
(+++)
EUR 15.9 million
(+)
EUR 29.8 million
Percentage reduction
compared to objective of
25%
0% 77% 57%
Benefits
Economic impacts
(including competitiveness
and SMEs)
(=) (++) (++)
Social impacts (=) (++) (+)
Environmental impacts (=) (++) (+)
Option R2 appears to deliver the greatest benefits in terms of reducing costs linked to
administrative burden, exceeding largely the objective of 25%. This reflects a reduction of the
costs of development and management of performance dashboards and portals on funding
opportunities by the Commission as a result of merging into a single portal, compared to
maintaining the current system of ca. 20 performance dashboards and 13 portals on funding
opportunities. While option R2 presents costs linked to the integration or development of
specific pages displaying data related to dedicated areas and sectors, its overall costs are smaller
than option R3 as it relies on a simple re-direction towards MS portals. Option R3 foresees
significant entry costs linked to integrating MS portals into an EU-wide system and operating
costs for the Commission, MS and beneficiaries.
Options R2 and R3 reach equivalent scores in terms of economic impacts. A single online
portal on information on funding opportunities would enable MS, partner countries and
beneficiaries to reduce the costs allocated to navigating multiple dashboards and portals,
ultimately facilitating access to EU funds by beneficiaries in key economic sectors. Under
option R2, the single portal would enable to display performance data regarding e.g. specific
38
economic sectors, which may deliver higher economic benefits than option R3 by improving
access to information by stakeholders active in such sectors. On the contrary, under option R3
the single portal would integrate and replace portals hosted e.g. by MS and regions, which
would increase access to information on funding opportunities available to beneficiaries in
relevant economic sectors. This would have a particularly positive impact on SMEs, which
operate with limited staff and can be disproportionately affected by the multiplicity of EU
portals, therefore enabling SMEs to become more responsive to new support opportunities
under EU funds. Option R3 may ultimately deliver slightly higher benefits to the
competitiveness of economic sectors supported by EU funds.
Similarly, options R2 and R3 reach equivalent scores in terms of social and environmental
impacts. Under option R3 the single portal would not display specific data regarding dedicated
areas and sectors, which may limit possibilities to display information on social and
environmental aspects, potentially reducing opportunities to better integrate social and
environmental considerations and challenges back into the management of EU budget
programmes, compared to option R2. On the contrary, option R3 scores higher as it would
facilitate access to information on EU budget funding opportunities, including for beneficiaries
in the field of EU social and environmental policies.
7.3. Coherence
Policy options are assessed against their coherence with:
- EU policy objectives and principles, such as the EU budget support to gender equality, and
the Commission’s commitment to achieve simplification and reduction of administrative
and reporting burden in particular regarding businesses, and;
- legislative framework, such as the Financial Regulation requirements in relation to e.g.
gender equality, implementation of the DNSH principle, and indicators.
• Programming/mainstreaming:
Policy option P1 Policy option P2 Policy option P3
Coherence with
strategic EU
policy
objectives
(=) (+++) (+)
Coherence with
legislative
framework
(=) (+++) (+)
Option P2 scores highest in terms of coherence with the Commission commitment to achieve
simplification and reduction of administrative and reporting burden in particular regarding
businesses, due to its calibrated and proportionate approach to implementing the DNSH
principle. Options P2 and P3 also display significant coherence with horizontal EU policy
objectives and principles, as these two options are expected to increase the EU budget ability
to support gender equality in line with the Union of Equality objective. Due to its harmonised
yet calibrated approach, option P2 scores highest in terms of compliance with the Financial
Regulation on the need to apply DNSH across the EU budget where feasible and appropriate
and in accordance with the relevant sector-specific rules.
• Monitoring:
39
Policy option M1 Policy option M2 Policy option M3
Coherence with
strategic EU
policy
objectives
(=) (+) (+++)
Coherence with
legislative
framework
(=) (+) (+++)
Option M3 scores highest in terms of coherence with the Commission’s commitment to achieve
simplification and reduction of administrative and reporting burden in particular regarding
businesses, due to its fully harmonised list of performance indicators. Option M3 also scores
highest in terms of compliance with the Financial Regulation, which requires indicators to be
relevant, accepted, credible, easy, robust and based on widely recognised scientific evidence
and an effective, transparent and comprehensive methodology, as well as allowing for
aggregation of data across programmes.
• Reporting:
Policy option R1 Policy option R2 Policy option R3
Coherence with
strategic EU
policy
objectives
(=) (++) (+++)
Coherence with
legislative
framework
N/A N/A N/A
Option R3 scores slightly higher than R2 in terms of coherence with the Commission’s
commitment to achieve a reduction of administrative burden, as the single portal would
integrate and replace specific sources such as MS portals, which would facilitate access to
information on funding opportunities available to beneficiaries in relevant economic sectors.
Both options R2 and R3 would achieve increased coherence with the Financial Regulation
which reinforces transparency requirements on beneficiaries supported by EU funds, as both
options foresee the publication of such data through the single portal.
7.4. Comparison summary
The table below summarises the comparison of policy options against their ability to achieve
effectiveness, efficiency and coherence, building upon the findings of sub-sections 7.1, 7.2 and
7.3:
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 (=) (+) (+++)
40
Coherence (=) (+) (+++)
Policy options -
Reporting
Policy option R1 Policy option R2 Policy option R3
Effectiveness (=) (+++) (++)
Efficiency (=) (+++) (+)
Coherence (=) (++) (+++)
This comparison shows the need for possible trade-offs and synergies between options:
- Programming/mainstreaming: while option P2 foresees potentially slightly lower
environmental benefits, it scores high in terms of effectiveness and efficiency factors linked
to reducing administrative burden and coherence with EU policy objectives and legislative
framework. Options P2 and P3 are also expected to achieve significant synergies with
option M3 as DNSH guidance would be developed taking into account the intervention
fields of the mandatory list to be used under option M3.
- Monitoring: while option M2 presents the advantage of enabling the adoption of additional
programme-specific performance indicators in case of specific needs, its effectiveness
scores lower regarding the need to increase the capacity to aggregate performance data
across EU funds, because the single list of performance indicators would only be used on
a voluntary basis by programmes, and because programme-specific indicators are expected
to vary across programmes, similar to the challenges faced in monitoring performance
under the 2021-2027 period. Comparatively option M3 is expected to enable aggregation
of data across funds, yet it risks resulting in discontinuing certain indicators that were
needed under some programmes. Such a risk should be mitigated by developing a list of
performance indicators sufficiently comprehensive to address the monitoring needs of all
EU funds, support financing not linked to cost schemes and effectively evaluate
programmes. Option M3 is also expected to achieve synergies with options R2 and R3 as
the single portal would be the logical vehicle to display data collected under a single
monitoring framework.
- Reporting: in terms of trade-offs, option R3 scores slightly higher in terms of coherence
with the Commission’s commitment to achieve simplification and reduction of
administrative burden because it would provide a fully harmonised portal on funding
opportunities, also integrating MS portals. Option R2 scores nonetheless slightly higher
overall, because it achieves higher effectiveness and efficiency, mainly due to its
significantly lower entry costs i.e. reduced costs of development of a single portal compared
to R3 which is ambitious but significantly more expensive to develop.
In terms of sensitivity analysis, the above comparison may need to be nuanced due to the
uncertainty attached to certain findings and conclusions:
- In contrast with impact assessments linked to specific EU budget programmes, where
impacts are typically predicted based on macro-economic modelling, the quantitative
analysis of this impact assessment focuses on assessing reductions of administrative costs
for MS administrations. The analysis particularly faced data availability limitations, as
quantitative information on administrative burden linked to performance is scarce beyond
the qualitative findings of e.g. programmes evaluations. The analysis is based on a
combination of data available from studies and estimates by Commission services,
including reduction factors enabling to calculate expected reductions of administrative
41
costs for each policy option. Any variations in the assumptions underpinning such factors
is likely to have significant impacts on the costs estimated for each policy option.
- Moreover, while the quantitative analysis focused on assessing reductions of costs for EU
institutions and MS authorities, significant reductions of administrative burden are also
expected – from options P2, P3, M2, M3, R2, R3 – at the level of beneficiaries, including
businesses. Quantifying such reductions was nonetheless not possible due to a lack of
available data. The quantitative analysis would also have benefitted from data on the
administrative costs of monitoring performance in the case of direct and indirect
management. These shortcomings should be addressed in the future so as to fill the data
gap, in particular in the context of new Commission priorities and the commitment to
reduce administrative and reporting burden (cf. section 9).
- The analysis of economic, social and environmental impacts provided under section 6 is
also of a qualitative nature given the lack of quantitative data available.
Policy options P2, M3 and R2 conform to the principles of subsidiarity and proportionality
given the size and nature of the identified problems:
- Policy option P2 foresees that DNSH and gender equality are applied consistently across
all budget programmes, fostering coherence while accommodating diverse management
modes (direct, indirect, shared), type of support and internal vs. external action. This would
give MS and implementing partners the flexibility to adapt to their specific circumstances,
in line with the subsidiarity principle. Option P2 conforms to the proportionality principle
because of its calibrated approach to DNSH.
- Option M3 respects subsidiarity by giving MS the autonomy to adopt country-specific
milestones and targets in their plans if needed, and by avoiding over-reporting by MS,
implementing partners and beneficiaries.
- Option R2 respects subsidiarity by allowing for differentiated operationalization per
management mode, ensuring that specific areas or sector needs are taken into account in
the single portal. The single portal would simplify access for beneficiaries and MS,
reducing administrative burden in line with the proportionality principle. By merging
reporting requirements into a consolidated AMPR, option R2 further eliminates redundant
processes, achieving proportionality.
Building upon the analysis and comparison of individual policy options, the table below
summarises the comparison of combinations of policy options against their ability to achieve
effectiveness, efficiency and coherence:
P1+M1+R1 P2+M2+R2 P2+M3+R2 P3+M3+R3
Effectiveness (=) (++) (+++) (++)
Efficiency (=) (++) (+++) (++)
Coherence (=) (++) (+++) (++)
The table below also provides a comparison of the administrative costs attached to each
combination of policy options:
P1+M1+R1 P2+M2+R2 P2+M3+R2 P3+M3+R3
Total costs linked
to administrative
burden
EUR 1 671 Mio EUR 1 471 Mio EUR 967 Mio EUR 1 049 Mio
42
Combination P2+M3+R2 appears as achieving the highest effectiveness, efficiency and
coherence as it combines individual policy options scoring best. Both combinations
P2+M2+R2 and P3+M3+R3 score relatively well, but P2+M2+R2 scores lower than
combination P2+M3+R2 in terms of effectiveness of the performance monitoring system of
the EU budget as it limits possibilities to aggregate indicators across programmes, and in terms
of reduction of administrative burden because it would likely result in the adoption of a high
number of programme-specific indicators. Combination P3+M3+R3 also scores lower than
combination P2+M3+R2 because it achieves less proportionality in implementing DNSH and
complying with the Financial Regulation requirements, and entails significant entry costs to
develop and high operating costs to run a single portal on funding opportunities.
8. PREFERRED OPTION
8.1. Preferred policy option
In view of the analysis under section 7, the preferred combination of options is P2+M3+R259
.
This combination would enable to effectively deliver against horizontal EU principles such as
DNSH and gender equality, yet foreseeing calibrated and proportionate implementation of
DNSH, enabling to comply with the Financial Regulation requirement to implement DNSH
where feasible and appropriate, while reducing administrative burden for MS, implementing
partners and beneficiaries. This combination also enables a significant upgrade of EU budget
performance monitoring by enabling 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.
Combination P2+M3+R2 is expected to achieve ca. EUR 623 Mio of administrative costs
savings for MS administration and the Commission compared to the baseline. This number
corresponds however to a strong underestimation of expected cost savings, since the
quantitative analysis of the impacts of policy options did not quantify all impacts due to a lack
of data. However significant reductions of costs are also expected for beneficiaries, such as
businesses, supporting the competitiveness of the sectors supported by EU funds.
The most appropriate vehicle to operationalize this preferred combination of options appears
to be a single performance framework through a single legal act. Such a performance regulation
would enable to centralise 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 an empowerment to adopt a technical guidance setting DNSH criteria), 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,
59
Annexes 6, 7 and 8 provide further details on the proposed operationalisation of each element of the preferred
combination.
43
developed by Commission services with the aim to ensure an extensive coverage of all
interventions supported by the EU budget.
The regulation will serve as the overarching performance framework for all EU budget
programmes post-2027. All programme regulations will include a dedicated recital ensuring a
cross-reference to the performance regulation. By reflecting all interventions supported under
EU budget programmes, the list of intervention fields and indicators will reflect programmes
objectives, enabling the use of such indicators in the context of programme evaluations, in
addition to performance monitoring and payments.
8.2. REFIT (simplification and improved efficiency)
While the proposed regulation does not correspond to a revision of existing legislation stricto
sensu, the preferred policy option is fully in line with the REFIT objective of simplification
and reduction of red tape. Section 7 describes extensively the expected reduction of
administrative burden and improved efficiency expected from the preferred combination of
options enabling to achieve a significant reduction of regulatory costs.
Policy options
P2. Programming and
mainstreaming
M3. Monitoring R2. Reporting
Costs per policy option
Percentage of reduction
of administrative burden
costs compared to
baseline
EUR 110 million
45%
EUR 841 million
40%
EUR 15.9 million
77%
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.
Proportionate DNSH requirements also align with REFIT’s emphasis on effectiveness and
efficiency, and increases the likelihood of successful compliance by beneficiaries. By
upgrading the monitoring mechanism and enabling the aggregation of indicators across funds,
the framework improves transparency and accountability, which also aligns with the REFIT
goal of making EU interventions more results-oriented. The expected improved access to
performance information and funding opportunities also resonates with the REFIT principle of
improving users experience by making systems more accessible.
8.3. Application of the ‘one in, one out’ approach
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. The single list of
intervention fields and performance indicators will replace the several lists of intervention
fields and performance indicators currently attached to e.g. the CPR, the RRF regulation and
other programmes legal bases.
9. HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED?
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, and assess whether the new monitoring framework is
44
adequate in terms of effectiveness, efficiency and added value of interventions supported by
the EU budget. Such monitoring will take place during the implementation phase of the post-
2027 MFF, including during the preparation of the annual reports on the performance of the
EU budget, as requested in the Financial Regulation. As a mitigation measure, the regulation
will 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 budget. As relevant, the
Commission will assess the fitness for purpose of the list, identify any potential gaps, and may
propose updates to the list. At the same time, any updates of the list should be kept to a
minimum in order to preserve the ability to aggregate and compare data over the MFF duration.
The Commission study on assessing the administrative costs and burden in the management of
CPR funds (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. Such a study should estimate the administrative costs of monitoring performance in
the case of direct and indirect management, in addition to shared management. 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):
• relevance of intervention fields and indicators in view of performance monitoring;
• 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, costs of access to information of EU budget
performance and funding opportunities, including by beneficiaries, budgetary authorities,
implementing partners, partner countries and EU institutions.
45
ANNEX 1: PROCEDURAL INFORMATION
1. Lead DG, Decide Planning/CWP references
DG BUDG is the lead Directorate General, in close coordination with the Secretariat General,
for this initiative on the Performance framework of the post-2027 Multiannual Financial
Framework.
2. Organisation and timing
The work on the Impact Assessment on the Performance framework of the post-2027
Multiannual Financial Framework was coordinated with other Commission services through
an Inter-Service Group (ISG). The ISG was established on 9 January 2025. Representatives of
the Secretariat General (SG), Legal Service (LS), Reform and Investment Task-Force (SG
REFORM), Directorate-General for Regional and Urban Policy (REGIO), Directorate-General
for Employment, Social Affairs and Inclusion (EMPL), Directorate-General for Agriculture
and Rural Development (AGRI), Directorate-General for Maritime Affairs and Fisheries
(MARE), Directorate General for Research and Innovation (RTD), Directorate-General for
Communications Networks, Content and Technology (CNECT), Directorate-General for
Enlargement and Eastern Neighbourhood (ENEST), Directorate-General for International
Partnerships (INTPA), Directorate-General for Environment (ENV), Directorate-General for
Climate Action (CLIMA), Directorate-General for Justice and Consumers (JUST), Directorate-
General for Migration and Home Affairs (HOME), Directorate-General for Economic and
Financial Affairs (ECFIN), Directorate-General for Internal Market, Industry,
Entrepreneurship and SMEs (GROW), Directorate-General for Education, Youth, Sport and
Culture (EAC), Directorate-General for Mobility and Transport (MOVE), Joint Research
Centre (JRC), and Directorate-General for Eurostat (ESTAT) were appointed to the ISG. The
ISG met four times, first on 22 January 2025, and the final meeting before the submission of
the draft Impact Assessment to the Regulatory Scrutiny Board took place on 10 April 2025.
Other ISG meetings were held on 13 February and 12 March 2025. Several rounds of written
consultations took place since January 2025, with the last round ending on 8 May.
A number of other Commission services were also consulted on specific aspects of the impact
assessment such as Directorate-General for European Civil Protection and Humanitarian Aid
Operations (ECHO), Directorate-General for Energy (ENER), Directorate-General for Health
and Food Safety (SANTE), Directorate-General for Competition (COMP), Directorate-General
for the Middle East, North Africa and the Gulf (MENA) and Directorate-General for Defence
Industry and Space (DEFIS).
3. Consultation of the RSB
The Draft Impact Assessment report was presented to the Regulatory Scrutiny Board during an
upstream meeting on 1st April 2025.
The Draft Impact Assessment report was submitted to the Regulatory Scrutiny Board on 21
May 2025. It received an opinion without qualification on 13 June 2025.
46
The Board made comments in relation to the following areas, which were addressed in the final
version of the impact assessment as follows:
RSB comment Follow-up rectification of the impact assessment
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
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.
Clarified in sections 1 and 8.
The impact assessment focuses on the mainstreaming of the
gender equality and Do No Significant Harm principles
because these are legal requirements under the Financial
Regulation (Article 33). Other policy objectives (such as
competitiveness and defence) will be supported through the
steering mechanism, which will enable to identify and
mainstream relevant priorities, and through the specific
design of individual programmes such as the
competitiveness fund and the policy objectives of the
national and regional partnership plans.
The regulation will serve as the overarching performance
framework for all EU budget programmes post-2027. All
programme regulations will include a dedicated recital
ensuring a cross-reference to the performance regulation. By
reflecting all interventions supported under EU budget
programmes, the list of intervention fields and indicators will
reflect programmes objectives, enabling the use of such
indicators in the context of programme evaluations, in
addition to performance monitoring and payments.
Problem definition and 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
Clarified in section 2. Programme evaluations reviewed in
the context of the impact assessment provided relatively
limited information available on the fitness for purpose of
the existing framework to measure impacts. A second review
of evaluations – as well as relevant ECA audit findings –
was carried out to better identify and describe issues linked
to data availability and quality for monitoring and evaluation
purposes, with particular attention to corresponding RSB
47
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.
feedback, and taking into account the criteria on indicators of
the recast Financial Regulation.
Objectives and intervention logic
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.
Clarified in sections 7 and 9. The objectives are intended to
provide strategic direction. Integrating quantified elements in
the specific objectives (cf. section 4.2) has been particularly
challenging, except for objective SO2 linked to reducing
administrative burden and costs affecting EU budget
beneficiaries, Member States, third countries, implementing
partners and EU institutions – which includes a target value
of 25%, in line with the Commission target of reducing
burdens associated with administrative requirements.
For other specific objectives linked to increasing capacity to
address current and future policy priorities (SO1), enhancing
capacity to measure EU budget impact (SO3), and increasing
transparency and access to information for budgetary
authorities and beneficiaries (SO4), setting precise
quantitative targets is much more challenging. Instead,
section 7.2 of the impact assessment identifies a number of
operational objectives for each of the specific objectives in
order to clarify what is intended to be achieved.
Progress on the achievement of SO3 and SO4 will be
monitored by assessing the adequacy of the common list of
intervention fields and performance indicators in order to
identify any potential gaps or shortcomings, as well as
during the preparation of the annual reports on the
performance of the EU budget, as requested in the Financial
Regulation. To this effect, the regulation will contain an
empowerment for the Commission to adopt a delegated act
enabling to revise the list of intervention fields and
indicators, during the phase of implementation of the post-
2027 budget.
Options
The content of options is not
sufficiently developed to capture
Clarify in Annexes 6, 7 and 8 (future operationalization of
the preferred policy option). Additional elements were
48
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 the framework’s list of
indicators is supposed to be usable
across instruments/funds.
included to further reflect the construction of the
Performance Regulation, which will include articles (e.g. on
expenditure tracking and performance monitoring) setting
out rules for each management mode i.e. ‘differentiated’ or
‘calibrated’ operationalisation. Such articles define for
example how Member States will have to pick output
indicators from the common list to define milestones and
targets in their plans, as well as result indicators to enable for
additional performance monitoring.
Annex 9 further includes an estimation of the baseline policy
option, but an estimation of the current MFF baseline could
be added in terms of current administrative burden and
administrative costs.
Because the common list will include ca. 500 intervention
fields reflecting the objectives of programmes, and because
the list will include indicators attached to each intervention
field, there will be several indicators available to monitor the
achievement of programme objectives and therefore enable
robust evaluations. The list of indicators focuses on output
and result indicators, as including relevant and available
impact indicators remains a challenge. A methodology was
developed with the support of the JRC to define intervention
fields and related indicators. The list is based on a system of
classification by policy area, covering the interventions of all
programme intervention areas post-2027. The indicators
linked to intervention fields will correspond to and enable to
measure the outputs and results that are intended to be
produced by all interventions in programmes.
The ‘short set of indicators mandatory across programmes’
under option M2 refers to common indicators on output and
results achieved by programmes, similar to the 14 common
indicators of the RRF. Options M2 and M3 refer to
flexibility for Member States and third countries to adopt
output indicators outside the common list in case certain
measures of their plans justify tailored targets. Generally,
under their plans, it will be mandatory for Member States to
report on at least one output indicator (used as target) and at
least one result indicator – for each measure of their plan.
Adopting an additional mandatory list of common indicators
was assessed as delivering limited benefits in a context
where the next MFF will evolve towards a performance-
based delivery model.
Regarding option R3, the single performance report (AMPR)
will continue to be prepared by relevant Commission
services. Simplification is expected from the fact that there
will no longer be programme specific performance reports as
49
currently provided for in the legal bases of a number of
programmes.
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.
Clarified in section 7 and Annex 9.
The report provides qualitative analysis of impacts for
beneficiaries, including businesses, in section 6. The
quantitative analysis of policy options did not estimate
administrative cost savings expected for other stakeholders
including businesses due to a lack of data. Section 9 of the
impact assessment proposes to assess expected costs savings
for beneficiaries such as businesses. Annex 9 was amended
to further explain the reduction factor, including linked to the
expected decrease of the number of indicators from over 5
000 to ca. 900.
The sensitivity analysis was reinforced in section 7, and a
sensitivity analysis included in Annex 9. Section 7.2 of the
impact assessment assesses the efficiency of the policy
options based on the quantitative analysis presented under
Annex 9 (reduction of administrative costs). The analysis
focuses on the costs of each policy option in particular for
Member State administrations and the Commission,
including entry costs of transitioning to a new system, and
potential cost savings and efficiency gains resulting from
reduced administrative burden linked to a harmonised and
simplified performance framework across the EU budget.
The assessment of the efficiency of each policy option also
takes into account the expected economic (including
regarding competitiveness and SMEs), social and
environmental impacts of each policy option, building upon
the findings of section 6.
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.
Annex 1 added, and further clarifications added to section 8.
The concept and architecture of the list of intervention fields
and indicators has been developed in the context of an
interservice group gathering relevant Commission services,
building upon scientific and methodological support by the
JRC, with the aim to ensure an extensive coverage of all
interventions supported by the EU budget. The list of
intervention fields and indicators will be included in annexes
to the Performance Regulation. The relevance of the list will
be monitored over time, and the Commission will be
empowered to adopt a Delegated Act should any revisions be
needed.
Monitoring and data
50
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.
Clarified in Annex 7. The new list of indicators aims at
setting up a performance framework for the EU budget while
enabling to conduct programme monitoring and evaluation.
By establishing a direct link between intervention fields and
indicators, the common list will provide more information
than currently on the link between ‘how much do we spend’
and ‘what do we achieve’, which will be relevant in the
context of programme monitoring and evaluation. The
methodology for developing indicators also focuses on
ensuring that indicators are drafted to measure what we
actually achieve with EU investments, therefore ensuring a
causal link between programmes objectives and the new
common set of indicators. Because all management modes
and programmes will use the same set of intervention fields
and indicators, the new system will enable to compare the
effectiveness, efficiency and added value of programmes’
budget interventions. The initiative focuses on monitoring
outputs and results because of the lack of availability of
meaningful long-term impact indicators beyond outputs and
results, though some of the result indicators of the common
list may also be seen as impact indicators (e.g. GHG
emissions avoided).
51
What are the available AI tools to
modernise data collection and
interoperability of databases?
Clarified in section 5. AI is evolving at fast pace hence it
remains difficult to anticipate the exact role that it will play in
operationalizing the performance framework of the post-2027
budget. Yet it is expected to help modernise data collection,
such as by helping Member States to allocate projects to
intervention fields, and to contribute to the cleaning,
processing, and analysis of performance data, while also
enhancing data quality and reliability control mechanisms. AI
may also help in the future in terms of inter-operability of
databases, in a context where performance information
remains scattered across several Commission databases,
which limits aggregation of indicators across programmes.
Lastly, future AI tools could also help make the reporting of
performance information more interactive for the end users.
4. Evidence, sources and quality
The Commission collected extensive information and evidence to support the analysis
underpinning the problem definition, for example in terms of mapping of existing performance
provisions across EU budget programmes. Beyond analysing the legal basis and acts adopted
in the context of EU budget programmes, it carried out an extensive review of available
literature, including reports from the European Court of Auditors and the European Parliament.
The Commission also collected information relevant in the context of the quantitative and
quantitative analysis of the impacts of policy options, such as regarding the costs and benefits
of managing existing performance dashboards and portals as well regarding the costs and
benefits of creating a single performance portal.
52
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT)
Introduction
The Commission actively engaged the stakeholders in the process of the initiative and
consulted them on the effectiveness of the performance framework of the 2021-2027 EU
budget, both through a number of events and through an Open Public Consultation. The key
findings of this consultation are summarised below.
1. Overview of the relevant stakeholder consultations
The following relevant consultations of stakeholders have taken place or are planned, including
workshops and ongoing studies:
• Citizens panel on the new European budget: From March to May 2025, the
Commission organised a Citizens' Panel on a New European Budget as a way for
citizens to engage with the EU institutions and have their say on the EU policymaking
process. The event included three sessions gathering 150 randomly selected citizens to
help the EU decide how to spend its money in future, including an in-person session
from 28-30 March, a second online session (April 25-27), and a third and final session
in Brussels (May 16-18) where 2 volunteers officially handed in their
recommendations. The participants, coming from all 27 EU countries and representing
the EU’s diversity, reflected on where the EU Budget could bring the most added-value
to Europeans. In parallel, the Citizens' Engagement Platform, an online discussion
forum, enabled additional contributions from the general public.
• Annual Budget Conference: The event brought together high-level speakers –
European and global policymakers, researchers, representatives of think tanks, civil
society and businesses leaders – who debated a broad range of topical questions on 20
and 21 May 2025.
• Tour d’Europe: During the first half of 2025, Commissioner for Budget Piotr Serafin
travelled across the European Union to consult decision-makers, regions, citizens,
businesses and other relevant stakeholders on the EU budget. These trips featured visits
of many EU-funded projects in diverse fields – from education to research, defence to
agriculture and more.
• Hearing with social partners on the next MFF: On 17 June 2025, the Commission
(DG EMPL and DG BUDG) met with several representatives of the EU social partners
with a view to discussing the challenges and guiding principles for the next MFF.
A number of recommendations were made in the context of those consultations. A wide array
of topics was identified as priorities such as defence and security, migration and border
management, education and workforce, climate and sustainability and healthcare, social
policies. The need to simplify EU budget-related procedures which currently generate
significant administrative burden and costs was also a recurrent theme throughout the
discussions and featured in the recommendations, as well as the need for transparency and
accountability in spending EU funds.
Furthermore, recommendations were made in relation to the importance of mainstreaming
green and social priorities in the EU budget and ensuring that EU-funded projects do no harm
53
to the environment and the climate, the need to support gender equality, as well as the need to
support SMEs to foster employment and reduce dependencies.
2. Results of the Open Public Consultation
On 12 February 2025, the Commission published the Open Public Consultations on the post-
2027 MFF, including a dedicated consultation on the performance of the EU budget, open until
6 May 2025. The consultation was based on an online questionnaire addressing the various
dimensions of performance of the EU budget. The questionnaire focused in particular on:
- the tools used to promote horizontal priorities and principles (e.g. gender equality,
digitalisation, climate and biodiversity, the ‘do no significant harm’ to climate and
environmental objectives) across the EU budget, to ensure that EU spending is geared
towards those objectives, also sometimes referred to as ‘mainstreaming’;
- performance framework, including the tools to monitor and report how effectively the
EU budget is achieving its objectives.
The questionnaire included 34 questions in total, focusing on the effectiveness of the above-
mentioned tools, including also specific questions on the mainstreaming of gender equality and
of the Do No Significant Harm principle, and existing monitoring tools such as indicators, as
well as reports, dashboards and portals used to report performance information and inform
potential beneficiaries about funding opportunities.
In total 555 stakeholders submitted their feedback, representing the views of a group of EU
citizens (128), non-governmental organisations (124), public authorities (111), academic and
research institutions (45), business associations (40), companies and businesses (36),
environmental organisations (7), trade unions (6), non-EU citizens (3), and others (55).
Respondents originated from 26 Member States and 8 non-EU countries, with the main 10
countries of origine being the following ones (in decreasing order): Germany, Belgium,
Poland, France, Italy, Spain, Finland, Netherlands, Sweden, Romania.
Overall the feedback to the Open Public Consultation supports the problem definition of the
impact assessment, in particular regarding climate and gender equality mainstreaming across
EU budget programmes, implementation of the DNSH principle as well as monitoring through
indicators and the need for transparency of performance information, calling for a more
structured and accountable approach to integrating horizontal EU priorities into the MFF.
Several respondents placed emphasis on shifting towards an impact-oriented approach, with a
focus on aligning the framework with strategic goals like sustainability, climate action, digital
transformation, social inclusion and health equity, also highlighting the need for increased
funding and co-financing rates to support these objectives. Several stakeholders highlighted
the need for alignment of the EU budget with broader societal goals such as sustainability,
gender equality, and biodiversity. Stakeholders further highlighted the need for "strategic
reserve" mechanisms within the budget for adaptability in unforeseen circumstances.
Respondents generally highlighted the need for standardisation and simplification of
performance and mainstreaming provisions, also ensuring that policies are responsive to local
contexts and needs. Stakeholders provided additional elements to the problem definition, in
particular regarding the need for stakeholders’ involvement in performance processes as well
as emphasising the need for capacity building. Respondents also highlighted the need for
binding indicators and spending targets to ensure that cross-cutting priorities are effectively
54
integrated into all EU funds and programmes, in particular in relation to gender equality and
biodiversity. Several stakeholders further highlighted the need to create a centralised,
multilingual portal to enhance transparency and accessibility of funding information.
Respondents to the consultation provided additional details on a number of key areas:
- Promotion of the principle of gender equality across the EU budget: the responses to
the question of how the EU budget could better support gender equality reveal a
complex landscape of hurdles and proposed actions, reflecting diverse perspectives
from various stakeholders. Stakeholders, including civil society organizations, public
authorities, and private sector representatives, have highlighted the need for more
targeted and flexible approaches to gender equality, emphasising the importance of
context-specific solutions and the integration of gender considerations across all EU
funding mechanisms. The data indicates a significant concern over administrative
burdens and the effectiveness of current gender equality measures. Another significant
hurdle is the perception of Gender Equality Plans as ‘box-ticking exercises’ that lack
substantial impact. Furthermore, the data points to structural issues such as
"geographical isolation, depopulation, and limited economic diversification", which
disproportionately affect women in certain regions. Stakeholders also advocate for the
integration of "intersectionality" into gender equality initiatives i.e. considering how
various social identities, such as ethnicity, age, and sexual orientation, intersect with
gender to create unique experiences of discrimination and disadvantage. A recurring
theme is the tension between the need for comprehensive data collection and the
administrative burden it imposes, while a number of respondents emphasised the need
for inclusivity in gender data collection including to capture data related to non-binary
and transgender individuals. Many stakeholders argue for a more streamlined approach
that balances the need for accountability with practical implementation as well as
gender-responsive budgeting and capacity building for managing authorities and
programme stakeholders. Additionally, there is a call for greater involvement of civil
society and equality bodies in the planning and oversight of gender equality initiatives,
suggesting a collaborative approach could enhance the effectiveness of EU-funded
projects. There is a call for "dedicated funding" for gender equality projects and
policies. Stakeholders also emphasise the importance of "monitoring and
accountability" mechanisms to track the progress and impact of gender equality
initiatives. Respondents further place emphasis on dedicating specific funding to
Women's Rights Organizations.
- Promotion of the principle of ‘do no significant harm’ to climate and environmental
objectives across the EU budget: the responses to the consultation identify a number of
challenges and recommendations related to the implementation of the DNSH principle.
Stakeholders provided insights into the challenges and potential solutions for
effectively integrating the DNSH principle into EU funding mechanisms. The primary
hurdles identified include excessive administrative burdens, inconsistent application
across programmes, and a lack of clear guidance. Stakeholders argue that the current
compliance demands are overly complex and discourage participation, particularly
55
from small and medium-sized enterprises (SMEs) and local entities. At the same time,
several respondents highlighted the need to maintain the "DNSH horizontal principle
as a mandatory requirement" for the green transition. In response, stakeholders have
suggested a range of actions, such as the need for a more consistent and harmonised
application of the DNSH principle across all EU programs and funding mechanisms
through a single, harmonised DNSH guidance with an evidence-based exclusion list,
simplifying documentation and compliance processes, providing sector-specific
guidelines, and enhancing training and capacity-building efforts. Stakeholders have
also advocated for the development of clear and ambitious exclusion lists to prevent
inherently harmful projects from receiving EU funding, excluding funding for activities
that undermine climate and biodiversity goals, such as nuclear power and fossil fuels.
A number of stakeholders also recommended the integration of DNSH into the entire
project lifecycle, with robust monitoring and reporting mechanisms. The analysis
highlights both areas of consensus and divergence among stakeholders, with some
advocating for more stringent enforcement and others calling for greater flexibility.
Responses by stakeholders further reflect a divergence in opinions regarding a potential
expansion of the DNSH principle to include social and economic dimensions, though a
number of stakeholders recommended a human rights-based, intersectional approach to
DNSH.
- Promotion of horizontal priorities across the EU budget: Stakeholders emphasise the
importance of aligning EU funding with strategic priorities such as climate action,
digital transformation, and social equity. Several respondents the systematic
mainstreaming of climate and gender equality across EU budget programmes.
- Monitoring how effectively the EU budget is achieving its objectives, including through
indicators: various stakeholders provided contributions on the effectiveness of the EU
budget monitoring system, particularly its reliance on indicators. A recurring theme is
excessive bureaucratic requirements, administrative burden and complexities
associated with the collection and reporting of indicators under EU funds, particularly
from smaller entities. Several respondents highlighted the need to balance flexibility
with accountability, calling for simplification while maintaining rigorous
accountability standards, and including suggestions for introducing consequences for
underperformance alongside incentives for success. Respondents regretted the lack of
standardisation and coherence across different EU funds, creating significant hurdles.
Stakeholders also raised the issue of overemphasis on output indicators and inadequacy
of current indicators to capture the true impact of EU funds, particularly in areas like
environmental protection and social inclusion, and the need to shift towards assessing
outcomes and long-term impacts. Many stakeholders pointed to issues such as lack of
granularity, enforcement, and the exclusion of negative impacts. These hurdles are
interlinked with the actions proposed, which often call for methodological
improvements and greater alignment with policy objectives. Stakeholders from
Germany, Belgium, and other EU countries have highlighted the disconnect between
the indicators used and the actual outcomes they are meant to measure. This disconnect
is often attributed to the complexity and lack of specificity in the indicators, which can
56
lead to administrative burdens and a failure to capture qualitative outcomes. Several
respondents also highlighted challenges linked to performance-based payments and the
risks associated with unclear achievement criteria. Stakeholders from various sectors,
including public institutions, private companies, and civil society organizations, have
expressed concerns about the current framework's ability to effectively support
innovation and address emerging priorities. In response, proposed actions emphasise
the need for simplification, flexibility, and a more tailored approach to performance
evaluation. Several stakeholders call for harmonisation of rules across different EU
funds. The actions proposed by stakeholders frequently emphasise the need for a more
integrated and transparent approach, with calls for the inclusion of qualitative
assessments and the alignment of indicators with broader EU objectives. Respondents
further highlighted the need to involve local and regional stakeholders in the design and
implementation of performance frameworks, suggesting this as a means to increase
transparency and accountability. A number of stakeholders emphasised the need for
improved data collection and digitalized reporting systems for evidence-based
evaluations, and recommended the development of a single audit system to streamline
processes and ensure consistent standards. Some respondents stressed the importance
of enhanced transparency and feedback loops to incorporate lessons learned into future
policy designs. Some stakeholders also highlighted the need for flexibility in the choice
of indicators to better reflect sectoral and regional specificities, and the need for
indicators to better reflect the need to support socially vulnerable groups.
- Access to funding: several stakeholders called for a centralised, multilingual portal to
enhance transparency and accessibility of funding information. Respondents further
recommended making EU funding mechanisms accessible and inclusive, particularly
for marginalized communities.
Stakeholders provided additional elements to the problem definition, in particular regarding
the need for stakeholders involvement in performance processes as well as emphasising the
need for capacity building.
The legal proposal developed as a result of this initiative – i.e. a horizontal regulation on budget
performance – built upon the results of the Open Public Consultation by addressing several of
the key concerns expressed by stakeholders. This includes strengthening the EU budget legal
framework to ensure consistent and proportionate implementation of the gender equality and
DNSH principles, while ensuring the effective mainstreaming of green and social priorities.
This also includes streamlining the monitoring framework of the EU budget with a view to
increasing the ability to measure the EU budget performance while limiting administrative
burden.
57
ANNEX 3: WHO IS AFFECTED AND HOW?
This annex explains the practical implications of a single performance framework applying at
EU budget level, based on implementation of the preferred policy option as described in
Section 8 of the main impact assessment report.
1. Practical implications of the initiative
The initiative aims at developing a simplified, coherent and flexible performance framework
for the post-2027 Multiannual Financial Framework, enabling to achieve simplification and
reduce administrative burden and costs affecting EU budget beneficiaries, Member States,
partner countries, implementing partners and EU institutions.
The single performance framework would have the following key practical implications:
For EU budget beneficiaries (including businesses), Member States, partner countries and
implementing partners:
The initiative is expected to achieve cost reductions linked to the development of:
- a single guidance on the application of the DNSH principle, including criteria following
a single activity-based approach applying to the entire budget i.e. Member States and
beneficiaries such as businesses would achieve a reduction of the resources currently
required to apply the multiple DNSH guidances and sometimes contradictory
requirements, enabling to achieve higher predictability of projects implementation and
facilitating access to EU funding;
- a harmonised classification of activities financed by the EU budget – so as to enable
simple tracking of expenditures through intervention fields – and a simplified and
standardised set of performance indicators at MFF level i.e. Member States managing
authorities would reduce resources currently allocated to dealing with multiple
expenditure tracking and indicators monitoring systems. The reduction of the number
of performance indicators would enable beneficiaries, including businesses, to face less
reporting burden and therefore to reduce the costs associated with project monitoring;
- harmonised requirements on performance reporting, consolidating all EU budget
performance information into the Annual Management Performance Report, which
would enable Member States, budgetary authorities and interested stakeholders to
reduce the costs currently allocated to having to navigate and process multiple reports
on the performance of EU budget programmes;
- a single online portal displaying EU budget performance information would enable
Member States, partner countries and beneficiaries to reduce the costs currently
allocated to having to navigate and process multiple dashboards. Businesses – such as
SMEs are particularly expected to benefit from such a single entry point, potentially
improving access to EU funds. The single portal would also provide information on
available funding opportunities centralising all information under the EU budget,
enabling Member States, partner countries and beneficiaries to reduce the costs
58
currently allocated to having to navigate and process multiple portals. A 2024
Commission STEP taskforce survey on ‘Access to EU funding – users perspective’
shows that 72% of respondents indicated that they would see value in a one-stop-shop
combining EU and national funding.
For EU institutions:
The initiative would enable to achieve cost reductions linked to the development of:
- a single guidance on the application of the DNSH principle, including criteria following
a single activity-based approach applying to the entire budget i.e. EU institutions – in
particular the Commission – would achieve a reduction of the resources currently
required to develop and implement the multiple DNSH guidances, reducing the need
for providing capacity building and technical support to Member States and
beneficiaries to implement DNSH;
- a harmonised classification of activities financed by the EU budget – so as to enable
simple tracking of expenditures through intervention fields – and a simplified and
standardised set of performance indicators at MFF level i.e. EU institutions – in
particular the Commission – would reduce resources currently allocated to calculating
and aggregating expenditures based on multiple tracking methodologies, as the new
system would be simpler yet enabling to track contributions to several priorities, as
relevant. The streamlining of the existing – multiple, and sometimes overly heavy –
indicators monitoring systems;
- harmonised requirements on performance reporting, consolidating all EU budget
performance information into the Annual Management Performance Report, which
would enable the Commission to achieve efficiency gains and reduce the resources
allocated to preparing such reports, removing duplication of information and reporting
processes. It would also enable other EU institutions – e.g. European Parliament – to
reduce the costs currently allocated to having to navigate and process multiple reports
on the performance of EU budget programmes. The new system would provide
comprehensive insights into EU budget performance, promoting transparency and
efficient data utilization for policy decisions;
- a single online portal displaying information on EU budget performance and available
funding opportunities centralising all information under the EU budget, enabling the
Commission to reduce the costs currently allocated to the management of multiple
dashboards and portals.
The initiative would nonetheless trigger initial one-off costs linked to the development of the
above-mentioned tools and components as part of the new harmonised performance framework
e.g. the development of the IT infrastructure necessary to run the new single dashboard and
portal. Adapting to the new provisions is also likely to generate transition costs linked to the
phase of stakeholders adapting to the new system. Such entry costs are expected to affect EU
institutions as well as beneficiaries (including potential compliance costs for businesses),
Member States, partner countries and implementing partners.
59
Example: indicators on renewable energy (additional capacity) for which EU budget
beneficiaries, Member States, partner countries and implementing partners would benefit from
harmonisation across MFF programmes so as to allow for simplification and aggregation of
performance data at EU budget level
Programme Indicator Measurement
Recovery and
Resilience Facility
Additional operational capacity installed for renewable
energy
Megawatts (MW)
European Regional
Development Fund
(ERDF)
Additional capacity of renewable energy production Megawatts (MW)
InvestEU
Additional renewable and other safe and sustainable
zero and low-emission energy generation capacity
installed
Megawatts (MW)
Regional Policy
(European Regional
and Development
Fund and Cohesion
Fund)
Additional renewable energy produced MWh/year
2. Summary of costs and benefits
The estimates of the expected costs and benefits are partial given the lack of available
quantitative data on costs associated with the administrative burden that EU institutions, EU
budget beneficiaries, Member States, partner countries and implementing partners are facing
in terms of monitoring, reporting and communicating performance of the EU budget and
specific programmes, and complying with a number of requirements e.g. regarding
implementation of the Do No Significant Harm principle. The methodology used for
calculating the costs of each policy option is presented under Annex 9.
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 (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
EUR 700,6 million Member State administrations (reduction of
administrative burden linked to
operationalization tasks such as:
60
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.
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)
Indirect benefits
P2, M3, R2: Indirect
benefits from expected
reduction of administrative
burden
Could not be costed due to lack of available data Implementing partners, third countries and
beneficiaries
(1) Estimates are gross values relative to the baseline for the preferred option as a whole (i.e. the impact of
individual actions/obligations of the preferred option are aggregated together); (2) Please indicate in the
comments column which stakeholder group is the main recipient of the benefit;(3) For reductions in regulatory
costs, please describe in the comments column the details as to how the saving arises (e.g. reductions in adjustment
costs, administrative costs, regulatory charges, enforcement costs, etc.;);.
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
61
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
(1) Estimates (gross values) to be provided with respect to the baseline; (2) costs are provided for each
identifiable action/obligation of the preferred option otherwise for all retained options when no preferred
option is specified; (3) If relevant and available, please present information on costs according to the
standard typology of costs (adjustment costs, administrative costs, regulatory charges, enforcement
costs, indirect costs;).
The total benefits of the initiative are estimated at EUR 842,7 Mio and the total costs are
estimated at EUR 220 Mio. The initiative would therefore result in total net benefits of EUR
622,6 Mio.
III. Application of the ‘one in, one out’ approach – Preferred option(s)
[M€]
One-off
(annualised total net present
value over the relevant period)
Recurrent
(nominal values per year)
Total
Businesses
New administrative
burdens (INs)
Cf. section II
Removed administrative
burdens (OUTs)
Net administrative
burdens*
Adjustment costs**
Citizens
New administrative
burdens (INs)
Removed administrative
burdens (OUTs)
Net administrative
burdens*
Adjustment costs**
Total administrative
burdens***
62
(*) Net administrative burdens = INs – OUTs;
(**) Adjustment costs falling under the scope of the OIOO approach are the same as reported in Table 2 above. Non-
annualised values;
(***) Total administrative burdens = Net administrative burdens for businesses + net administrative burdens for citizens.
3. Relevant sustainable development goals
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,
13 and 15.
IV. Overview of relevant Sustainable Development Goals – Preferred Option(s)
Relevant SDG Expected progress towards the Goal Comments
SDG 5 – Achieve gender
equality and empower all
women and girls
Increase in EU budget support to gender equality The new gender provisions will support the
systematic mainstreaming of gender across
EU budget programmes
SDG 13 – Take urgent action
to combat climate change
and its impacts
Improved tracking of EU budget expenditures
contributing to climate action
The new tracking system will enabling to
monitor contributions to both climate
mitigation and adaptation
SDG 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
Improved tracking of EU budget expenditures
contributing to biodiversity
The new tracking system will enabling to
monitor contributions to biodiversity both on
land and at seas (thereby also contributing to
SDG 14)
63
64
ANNEX 4: SME CHECK
Based on interservice group discussions, this initiative is relevant for SMEs.
1. Identification of affected businesses and assessment of relevance
Are SMEs directly affected?
(Yes/No) In which sectors?
Yes – in all sectors supported by EU budget programmes e.g.
agriculture, rural development, research and innovation,
regional development, environment and climate action, digital
transformation, culture and creative industries, education and
youth, transport and energy infrastructure, health
Estimated number of directly
affected SMEs
ca. 16,3 million60
(the exact number is not available, but the
initiative will precisely enable to aggregate performance data
on e.g. the number of SMEs supported across all EU budget
programmes, which is not possible in the 2021-2027 period)
Estimated number of employees
in directly affected SMEs
ca. 59,4 million61
Are SMEs indirectly affected?
(Yes/No) In which sectors? What
is the estimated number of
indirectly affected SMEs and
employees?
Yes – in all sectors supported by EU budget programmes, as
projects supported by the EU budget and promoted by other
types of beneficiaries are also likely to have impacts for SMEs
60
This estimate is calculated, using the number of SMEs in the 2021-2027 and 2014-2020 EU budget – MFF and
RRF – as a proxy for the post-2027 budget. This estimate is derived from the Financial Transparency System,
which estimates that 26148,32 private companies were supported by direct and indirect management programmes
in 2023, from data on the number of beneficiaries of the CAP (Europa website, Beneficiaries of CAP funds) and
a 2018 European Commission report which noted that 93% of EU farms are classified as SMEs based on
employment and turnover criteria, and from the 9th Cohesion Report (2024), which states that Cohesion Policy
supported over 4.4 million businesses during 2014–2020, as well as the Implementation of the Recovery and
Resilience Facility report (COM(2023)545), which states that by December 2022, the RRF had supported 1.43
million enterprises. The estimate also takes into account Eurostat’s Structural Business Statistics, which shows
that 99,8% of EU companies are SMEs. This estimate is likely to be an underestimate as it does not include the
number of SMEs supported by other EU funds.
61
This estimate is calculated based on the 9th
Cohesion Report (2024), which estimates the total number of SME
employees at 83.3 million and the total number of SMEs at 22.8 million i.e. 3.65 employees per SME on average.
65
2. Consultation of SME stakeholders
How has the input from the SME
community been taken into
consideration
The input from the SME community has been taken into
consideration through an Open Public Consultations on the
post-2027 MFF, including a dedicated consultation on the
performance of the EU budget, running from 12 February 2025
to 6 May 2025. The consultation received several contributions
from companies and businesses, including SMEs, which were
integrated into the initiative. The SME community was also
indirectly consulted via the European Citizens Panel on a new
EU Budget, which made recommendations on the need to
support SMEs and the need to simplify administrative
procedures linked to EU budget programmes, which is one of
the objectives of the initiative.
Are SMEs’ views different from
those of large businesses?
Information not available as the OPC results do not differentiate
between SMEs and other businesses.
3. Assessment of impacts on SMEs62
What are the estimated direct
costs for SMEs of the preferred
policy option?
SMEs supported by EU budget programmes are likely to face
limited entry costs linked to transitioning to the new
performance framework e.g. monitoring and reporting
performance based on partly new indicators, new DNSH and
gender mainstreaming provisions, new single portal on funding
opportunities.
What are the estimated direct
benefits/cost savings for SMEs of
the preferred policy option
The preferred policy option is expected to generate significant
cost savings linked to the reduction of compliance and
administrative costs by SMEs supported by EU budget
programmes. The initiative foresees a calibrated and
proportionate approach to implementing the DNSH principle,
which will facilitate compliance by SMEs, in particular as the
initiative foresees exempting certain projects from DNSH
checks i.e. in the fields of defence and security. The
simplification of performance monitoring provisions and the
reduction of the number of indicators would enable SMEs 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 SMEs to reduce the costs currently allocated to having
to navigate and process multiple portals, ultimately facilitating
access to EU funds by SMEs in key economic sectors. Overall
the initiative will have a particularly positive impact on SMEs,
which often operate with limited staff and resources and can be
disproportionately affected by the complexity of monitoring
and reporting requirements under EU funds. The preferred
62
This section summarizes impacts on SMEs from a qualitative perspective, as no quantitative information was
available.
66
policy option will therefore enable SMEs to become more
responsive to new support opportunities under EU budget
programmes (cf. section 6 of the impact assessment for more
details).
The harmonised performance framework of the post-2027
budget will also enable to better assess the impacts of the EU
budget on SMEs, as the monitoring system would enable to
assess how many SMEs are supported by the EU budget as well
as other SME-relevant performance information.
4. Minimising negative impacts on SMEs
Are SMEs disproportionately
affected compared to large
companies? (Yes/No)
If yes, are there any specific
subgroups of SMEs more
exposed than others?
SMEs are not expected to be disproportionately affected by the
initiative compared to large companies.
5. Contribution to the 35% burden reduction target for SMEs
Are there any administrative
cost savings relevant for the
35% burden reduction target for
SMEs?
The preferred policy option is expected to significantly
contribute to the Commission commitment to streamline rules
and reduce the administrative burdens by 35% for SMEs by the
end of the current mandate.
67
ANNEX 5: COMPETITIVENESS CHECK
1. Overview of impacts on competitiveness
Dimensions of
Competitiveness
Impact of the initiative (++ /
+ / 0 / - / -- / n.a.)
References to sub-sections of
the main report or annexes
Cost and price competitiveness ++ Sections 6, 7 and 8
Annexes 3 and 9
International competitiveness + Section 6
Capacity to innovate n.a.
SME competitiveness ++ Sections 6, 7 and 8
Annexes 3 and 9
2. Synthetic assessment
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%63
. 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 beneficiaries in key
economic sectors. The quantitative analysis presented under Annex 9 focuses on expected
reductions of costs for Member States authorities and the Commission due to a lack of
quantitative data on impacts on beneficiaries such as businesses, but the initiative is expected
to generate significant cost savings and efficiency gains for 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. For the above-mentioned reasons, EU
companies would be facing less administrative burden associated with mainstreaming,
monitoring and reporting provisions, improving their position vis-à-vis third countries
enterprises. This assessment should nonetheless be nuanced as the initiative will also apply to
non-EU companies supported by EU budget programmes e.g. under external action funds,
meaning that such companies would equally benefit from the new performance framework.
63
In line with the Communication target of reducing burdens associated with reporting requirements by 25%
68
While the initiative is not expected to have any significant impact on businesses capacity to
innovate, the reductions in administrative costs expected from the initiative may enable
businesses to free up resources to the benefit of increased resources dedicated to innovation.
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 future performance
framework will also enable to measure e.g. how many SMEs are supported by the EU budget
overall, which is currently very challenging as indicators differ from one programme to the
other, making aggregation of data difficult.
3. Competitive position of the most affected sectors
The initiative is expected to have positive effects on the competitiveness of all sectors
supported by EU budget programmes, since the new performance framework will apply to all
EU funds. Affected sectors include e.g. agriculture, rural development, regional development,
environment and climate action, research and innovation, digital transformation, culture and
creative industries, education and youth, transport and energy infrastructure, health.
As indicated above, a quantitative analysis of impacts on businesses supported by EU budget
programmes could not be carried out due to a lack of available data.
69
ANNEX 6: POLICY MAINSTREAMING AND PROGRAMMING
ARCHITECTURE OF THE 2021-2027 BUDGET
6.1 Climate and biodiversity mainstreaming
Since 2014, the EU budget has increased its support for climate objectives by mainstreaming
climate across all the relevant MFF programmes.64
Mainstreaming entails embedding
horizontal policy goals into all phases of the policy cycle of the relevant programmes, including
preparation, design, programming, implementation, monitoring and evaluation. This means,
for example, that instead of establishing a separate and dedicated fund for climate and energy
objectives, these policies priorities can be integrated into existing EU funds, such as the
cohesion funds. Since 2021, this mainstreaming approach has also been extended to
biodiversity65
. A more advanced approach – ‘green budgeting’ – has also been adopted in the
EU budget as part of the increased emphasis on impact and performance in the current MFF.
The mainstreaming approach has been further complemented with the inclusion of budgetary
targets, first at EU budget level, and then at programme level. Under the inter-institutional
agreement (IIA) accompanying the 2021-2027 Multiannual Financial Framework, the
European Parliament, the Council and the Commission agreed to allocate at least 30% of all
resources available under the 2021-2027 Multiannual Financial Framework and
NextGenerationEU to measures addressing climate change, and to support biodiversity
objectives with 7.5% of annual spending in 2024, and 10% in 2026-2027.66
This approach has
effectively raised the climate and biodiversity focus of MFF programmes under the EU budget
– although the level of success varies across programmes and priorities.
Budget earmarking – and target setting in particular – is only one of the elements of a wider
‘mainstreaming toolbox’ aimed at reinforcing climate and biodiversity objectives within the
EU budget. The EU budget’s contribution to climate and biodiversity objectives ultimately
depends on how effectively these various tools are integrated and coordinated.
Several tools were embedded in the design of 2021-2027 EU budget programmes to strengthen
their contribution to the EU’s green objectives. For instance, the green architecture of the
Common Agriculture Policy was reinforced. ‘Eco-schemes’ were introduced in the Common
Agricultural Policy67
to encourage farmers to adopt greener farming practices by providing
additional income support, in addition to a wide range of tools, including agri-environmental-
climate measures, green investments and Natura 2000 payments. In Horizon Europe, thematic
clusters68
– such as the cluster on ‘Climate, Energy, and Mobility’ and the ‘Clean Hydrogen
Partnership’ – complement the programme’s bottom-up approach by steering research and
innovation efforts towards environmental goals. Within Cohesion policy funds, thematic
64
https://eur-lex.europa.eu/resource.html?uri=cellar:d0e5c248-4e35-450f-8e30-
3472afbc7a7e.0011.02/DOC_4&format=PDF
65
Interinstitutional Agreement of 16 December 2020 between the European Parliament, the Council of the
European Union and the European Commission on budgetary discipline, on cooperation in budgetary matters and
on sound financial management, as well as on new own resources, including a roadmap towards the introduction
of new own resources
66
Ibid.
67
Regulation - 2021/2115 - EN - EUR-Lex
68
Regulation - 2021/695 - EN - EUR-Lex
70
enabling conditions for climate and biodiversity ensure that the right frameworks are in place
to maximize the impact of green investments.69
InvestEU supports green objectives mainly
through its dedicated sustainable infrastructure window70
. In addition, a number of programmes
were introduced with the primary objective of addressing various dimensions of green
priorities, such as the Modernisation Fund71
and the Social Climate Fund72
.
An overview of the different tools available and their application across funds are presented in
Tables 1 and 2.
69
Regulation - 2021/1060 - EN - EUR-Lex
70
Regulation - 2021/523 - EN - EUR-Lex
71
EUR-Lex - 02003L0087-20240301 - EN - EUR-Lex
72
Regulation - 2023/955 - EN - EUR-Lex
71
Table: Green policy mainstreaming elements in the 2021-2027 MFF programmes
Programme % climate
achieved 2014-
2020/projected
2021-2027
% biodiversity
achieved 2014-
2020/projected
2021-2027
Green mainstreaming elements
Horizon Europe 30% (35% target)
35%
5%
8%
Legal basis and earmarking
- 35% climate target (recital)
- Earmarking of budget for clusters (e.g. “energy, climate, transport” cluster)
Governance
- Horizon Europe Strategic Plan ensuring follow up on the 35% climate target
- 10% of total Horizon Europe budget for 2025-2027 dedicated to biodiversity (Strategic
Plan)
Policy design
- Missions on climate adaptation; climate neutral cities; restore our ocean and waters;
- Joint undertakings on: Circular Bio-based Europe; Clean Aviation; Clean Hydrogen;
Europe’s Rail; Single European Sky ATM Research;
- EIT cluster on urban mobility; climate change; future of food; sustainable energy; raw
materials;
- Screening of topics for DNSH compliance (Article 5 (2) (p))
- Climate proofing integrated on a topic-by-topic basis (i.e. infrastructures and
innovation projects)
72
- Climate related enabling conditions are inherent in program calls focusing on
environmental sustainability and innovation.
- Biodiversity tracking by a handbook to facilitate attribution of markers to biodiversity
relevant projects.
Euratom
Research and
Training
Programme
0% (fusion not
part of
methodology)
35%
0
0
Legal basis and earmarking
- Earmarking of budget towards fusion research objective
International
Thermonuclear
Experimental
Reactor (ITER)
0% (fusion not
part of
methodology)
100%
0
0
InvestEU 0%
30%
0
0
Legal basis and earmarking
- 30% climate target (recital)
- 60% of investments under “sustainable infrastructure” policy window budget
earmarked for climate and environment
Policy design
- Exclusion list of activities (Annex Vb)
- Sustainability proofing (guidance of Commission takes into account DNSH)
- Projects that fall under the Environmental Impact Assessment Directive need to be
screened regardless the total project cost and proofing performed, if necessary
73
- Integration of the EU taxonomy framework where possible
- Dedicated scheme for just transition territories
- Climate and environment tracking of expenditures (assess whether InvestEU
operations contribute to green objectives)
Connecting
Europe Facility
(CEF), including
Military Mobility
71%
77% (60% target)
0
0
Legal basis and earmarking
- 60% climate target (recital and article 4)
- Decarbonization of energy sector objective; sustainable transport objective
- Earmarking per objective
- Methodology in the recital
Policy design
- Environmental Impact assessment
- Reporting for Trans-European Network for Energy and assessment during the
procurement process for Trans-European Networks for Transport with DNSH
- Screening of projects (energy and transport) during selection phase
- Climate proofing for infrastructure projects
Digital Europe
Programme
0
4%
0
0
No specific provisions
Single Market
Programme
4% (COSME)
4%
0
0
No specific provisions
74
European Space
Programme
35% (Copernicus)
35%
6%
6%
Policy design
- Copernicus monitoring contributes to both mitigation and adaptation efforts
EU Secure
Connectivity
Programme
NA NA No specific provisions in place
Regional Policy
Funds (ERDF and
Cohesion)
20%
35%
4%
6%
Legal basis and earmarking
- At least 30% for ERDF and 37% for CF (Recital 6 ERDF and CF Regulation).
- Art 5 “a greener, low-carbon transitioning towards a net zero carbon economy and
resilient Europe by promoting clean and fair energy transition, green and blue
investment, the circular economy, climate change mitigation and adaptation, risk
prevention and management, and sustainable urban mobility;” policy objective
- For ERDF, all regions and Member States must concentrate at least 30% of their
allocation to PO2 (greener, low-carbon transitioning towards net zero carbon economy
and resilient Europe)
- Art 6 “climate target adjustment mechanism”
- Art 15 “enabling conditions” (i.e. in water, waste and circular economy and nature /
biodiversity)
- “do no significant harm” should be taken into account (applied by the national
authorities in the assessment of the investment priorities contained in the programmes
before adoption) (Article 9 (4) CPR)
- Intervention fields methodology in CPR annex I
- For ERDF/CF: Exclusion list for ineligible activities (article 7)
- Common output and result indicators for ERDF and CF (include environmental
indicators)
75
Policy design
- Climate proofing mandatory for infrastructures project (lifespan of at least 5 years)
- Climate enabling conditions applied
- Strategic Environmental Assessment (most of cohesion policy subject to an SEA
Support to the
Turkish Cypriot
Community
4%
0%
0%
1%
Recovery and
Resilience
Facility
43% 2% Legal basis and earmarking
- Recital 23 climate framework
- Recital 32 consistency with Semester and National Energy and Climate Plans
- Recital 76 reporting
- Art 16 climate target (37%)
- Art 18(e) National plan – climate
- Annex VI methodology
- 30% Green bonds
Policy design
- DNSH as an eligibility criterion
- Climate-related enabling conditions on green targets
76
Technical
Support
Instrument
0
7%
0
1%
No specific provisions in place
Union Civil
Protection
Mechanism
35%
15% (2021-2024
period)
0
2%
No specific provisions in place
EU4Health
Programme
0
0
0
0
Policy design
- Two measures included in 2024 related to the health risks that are a consequence of
climate change
Emergency
Support
Instrument (ESI)
0
0
0
0
No specific provisions in place
European Social
Fund +
8%
5%
0
0
Legal basis and earmarking
- Art 5 “a greener, low-carbon transitioning towards a net zero carbon economy and
resilient Europe by promoting clean and fair energy transition, green and blue
investment, the circular economy, climate change mitigation and adaptation, risk
prevention and management, and sustainable urban mobility” policy objective
- Secondary theme for tracking of “green” (reported as climate with 100% coefficient)
Erasmus + 0 0 Policy design
- Prioritisation of the green transition in cooperation activities
77
4% 0 - Promotion of green practices at the level of projects throughout the programme
- Funding rules for learning mobility: sustainable travel is the default option,
encouraging participants to prioritise green travel as their first choice when planning
their trip. 23% of the mobilities which took place in 2023 were carried out in an
environmentally friendly way (vs 13% in 2021).
European
Solidarity Corps
(ESC)
0
5%
0
0
Policy design
- Environmental sustainability and climate goals is one of the four transversal priorities
of the programme.
- Corps projects should promote environmentally sustainable and responsible behaviour
among participants. The Corps contributes to equipping young Europeans with the
necessary skills to develop innovative practices to bring about change, in line with the
objectives for the green transition and sustainable development.
- Funding rule for volunteering mobility: sustainable travel is the default option,
encouraging participants to prioritise green travel as their first choice when planning
their trip.
- Between 2021-2023, 4 280 projects tackled environment and climate change with 2
709 organisations involved and 4 077 participants using green travel. 31% of the
participants declared that they are more aware of environmental issues.
Justice
Programme
0
0
0
0
No specific provisions in place
Creative Europe 0
12%
0
0
No specific provisions in place
78
Citizens,
Equality, Rights
and Values
Programme
0
0
0
0
No specific provisions in place
Communication 0
1%
0
0
No specific provisions in place
Common
Agricultural
Policy (CAP)
26%
39%
16%
17%
Legal basis and earmarking
- 40% climate target (recital 94)
- Earmarking of budget for ecoschemes (25% pillar I) and “expenditures for climate,
biodiversity and environment” in pillar II (35%)
- 15% of expenditure from fruit and vegetable Operational Programme dedicated to
environmental and climate friendly investments
Governance
- CAP strategic plans – covering EAGF and EAFRD – approved by the Commission,
and dialogues with Member States
- Targets set for CAP support for climate adaptation, for GHG emission reduction and
carbon storage, renewable energy, preserving habitats and species investments for
climate, afforestation, biodiversity, etc.
- Biannual performance review
Policy design
79
- Good agricultural and environmental conditions and Statutory Management
Requirements (applying to all area payments under the CAP i.e. 87% of EU
agricultural utilised area in 2023)
- Eco-schemes, agri-environment-climate measures and green investments under pillar II
(ringfencing)
- Advice, cooperation and knowledge transfer
- Eligibility conditions for investments in irrigation, compatible with Water Framework
Directive
- Consistency between coupled income support and Water Framework Directive
European
Maritime
Fisheries and
Aquaculture Fund
(EMFAF)
15%
53%
14%
30%
Legal basis and earmarking
- 30% climate target (recital)
- “do no significant harm” should be taken into account (Article 9 (4) CPR)
Regional
Fisheries
Management
Organisations
(RFMO) and
Sustainable
Fisheries
Partnership
Agreements
(SFPA)
8%
9%
3%
12%
No specific provisions in place
Programme for
Environment and
48% 50% Legal basis and earmarking
80
Climate Action
(LIFE)
61% 49% - 60% climate target (recital)
- Earmarking of budget per objective
- Recital 29 refers to DNSH
Policy design
- Each strand has a strong link with different green dimensions
- Green assist (technical support)
Just Transition
Fund (JTM)
NA
100%
0
0
Legal basis and earmarking
- 100 % climate relevant as per regulation
- DNSH must be taken into account (Article 9(4) CPR)
Policy design
- Climate proofing for infrastructures project (lifespan of at least 5 years)
- Enabling conditions for just transition plans aligned with climate neutrality goals
Asylum,
Migration and
Integration Fund
(AMIF)
No specific provisions in place
81
Integrated Border
Management
Fund (IBMF)
No specific provisions in place
Internal Security
Fund (ISF)
No specific provisions in place
Nuclear Safety
and
decommissioning
(incl. For
Bulgaria and
Slovakia)
No specific provisions in place
European
Defence Fund
(EDF)
No specific provisions in place
Neighbourhood,
Development and
International
Cooperation
Instrument
(NDICI Global
Europe)
18% (average of
past programmes)
28%
5%
8%
Legal basis and earmarking
- 30% climate target (recital) + EUR 4 bn from SOTEU
- 7 bn EUR to biodiversity from NDICI and IPA III over 2021-2027 i.e. doubling
compared to 2014-2020 (political commitment via SOTEU)
- Projects environmental screening (incl. climate and biodiversity) with environmental
impact assessment for sensitive environmental actions (Article 25)
- Exclusion list for activities incompatible with Paris Agreement, promote fossil fuels or
cause significant effects on environment
82
Humanitarian Aid
(HUMA)
10%
19%
0
0
No specific tools in place
Overseas
Countries and
Territories (OCT)
(including
Greenland)
23%
22%
NA
11%
No specific tools in place
Macro-Financial
Assistance
(MFA)
NA NA No specific provisions in place
Instrument for
Pre-Accession
Assistance (IPA
III)
18%
27%
2%
4%
Legal basis and earmarking
- 20% climate target (recital)
- Doubling biodiversity support from NDICI and IPA III from 2014-2020 to 2021-2027
(political commitment via SOTEU) i.e. reaching 7 bn EUR
Ukraine Facility NA NA Legal basis and earmarking
- At least 20% of the overall amount corresponding to support under the Ukraine
investment framework and to investment under the Ukraine plan to contribute to green
objectives
- Do no harm
Innovation Fund NA NA Legal basis and earmarking
83
- The entire budget is dedicated to climate action (Article 10a §8): actions that
contributes substantially to mitigating climate change.
- DNSH principle will be applied as 2025 onward (Article 10e).
- Stringent environmental criteria are in place (Article 10a). One of the evaluation
criteria for the selection of projects for grants programme is GHG avoidance.
Modernisation
Fund
NA NA Legal basis and earmarking
- Member States have to spend 80% of national envelope on green projects
- DNSH applied from 2025 onward (Article 10e)
Policy design
- Enabling conditions implicitly included
Green budgeting toolbox definitions
Area Area Definition
Overall
Strategy
Mainstreaming Mainstreaming refers to the integration of a particular priority into EU policies and
budget. In various contexts, such as gender mainstreaming or green mainstreaming, it
involves ensuring that considerations related to that priority are included in all decision-
making processes, rather than being treated as a separate or peripheral concern.
Green budgeting Green budgeting is an approach that incorporates environmental considerations into the
budgeting process. It aims to align public financial management with environmental
goals, ensuring that government budgets reflect commitments to sustainability and
84
climate action. This approach is more sophisticated as not only involves a tracking
methodology for expenditures, but also accounting for impacts, and purposely allocating
funds to green initiatives
Legal
Ringfencing
Dedicated programme In terms of legal ringfencing of resources, horizontal target, programme target,
earmarking (i.e. dedicating a specific portion of a programme to a particular policy area
or objective) and dedicated programme (e.g. Innovation fund or LIFE) represent different
degrees to dedicate specific resources towards green priorities. Through the continuum
of these options, there are different degrees of flexibility.
Earmarking (e.g. dedicated strand, budget
lines)
Programme Target
EU budget-wide target
Programme
design
Objectives Inclusion of specific objectives dedicated to green priorities ensures that resources are
dedicated (also through the link between objective and budget line, where possible), and
specific actions for operationalization foreseen
Incentives For instance, in the Common Agricultural Policy, ecoschemes are a specific programme
action that incentivizes beneficiaries in the green transition.
Enabling conditions Enabling conditions are a key element of cohesion policy for 2021-2027. They build on the ex-
ante conditionalities from the 2014-2020 period to ensure that the necessary conditions for the
effective and efficient use of the funds are in place.
For instance, if the special objective ‘promoting a gender balanced labour market
participation, equal working conditions and a better work-life balance including through
access to affordable childcare and care for dependent persons’ is selected, then the
enabling condition 4.2. ‘National strategic framework for gender equality’ needs to be
fulfilled.
Milestones/targets One of the key features of the Recovery and Resilience Facility is its performance-based
nature. RRF funds are disbursed when Member States have satisfactorily fulfilled key steps in
the implementation of the reforms and investments included in the recovery and resilience
85
plans. These key implementation steps are referred to as milestones and targets. Milestones
represent a qualitative implementation step, targets a quantitative implementation step.
Such milestones and targets can also be set to fulfil specific green requirement, such as
the deployment of a certain amount of solar panels or a reform on a given environmental
policy. They can also be linked to specific targets for outputs or results that are in line
with overall policy objectives.
Do no
significant
harm
Exclusion list List of activities or interventions that cannot be eligible for financing. For instance, the
CPR provides for an exclusion of financing for activities related to coal or oil.
Technical guidance A guidance to apply the DNSH principle, in a specific programme according to rules.
Climate proofing The process of assessing and ensuring that projects and policies are resilient to the
impacts of climate change. In the context of the EU budget, climate proofing involves
evaluating how proposed investments or expenditures will be affected by climate change
and ensuring that they contribute to climate adaptation and mitigation goals.
Environmental impact assessment EIA is a process used to evaluate the potential environmental effects of a proposed
project or development before it is approved. In the EU budget context, it is a legal
requirement for certain projects to assess their environmental impacts, including effects
on biodiversity, air and water quality, and climate change.
Performance
framework
Tracking methodology This refers to the systematic approach used to monitor the allocation and implementation
of EU budget funds, particularly in relation to specific objectives such as climate action
and biodiversity. Tracking methodologies help ensure transparency and accountability
by providing a framework for assessing how funds are spent and provide updates on their
implementation.
Monitoring/indicators Monitoring involves the ongoing assessment of projects and policies to ensure they are
on track to meet their objectives. Indicators are specific metrics used to measure progress
and performance. In the context of the EU budget, monitoring and indicators are essential
86
for evaluating the effectiveness of funding in achieving goals such as sustainability,
economic growth, and social inclusion.
Reporting Reporting refers to the process of documenting and communicating the results of
monitoring and evaluation activities. In the context of the EU budget, reporting is crucial
for transparency and accountability, as it provides stakeholders with information on how
funds are being used, the outcomes achieved, and the overall impact of EU budgetary
measures. This includes regular reports from the European Commission to the budgetary
authority, including through the Annual Management Performance Report.
87
Table: EU budget green financing overview73
Programme Climate average contribution
(2021-27) per year
in EUR billion
Biodiversity average
contribution (2021-27) per year
in EUR million
Horizon Europe 4 674 993
ITER 649
Connecting Europe
Facility
3 492
Cohesion Policy Funds 16 170 2 413
European Social Fund + 878
Common Agricultural
Policy (CAP)
20 837 9 189
LIFE 470 384
NDICI Global Europe 3 500 929
IPA III 584 84
Other 3 326 46
Total 54 579 14 430
Recovery and Resilience
Facility (2021-2024)
91 900 1 631
Innovation fund (2021-
2030)
4 000
Social climate fund 9 286
Modernization fund (2021-
2030)
5 700
73
DB2025 data
88
Total ETS 18 986
Total 165 465 16 061
Comment: The data available for the 2021-2027 period show that the EU budget is on track to reach its 30% target
for climate mainstreaming, thanks to the strong performance of the Recovery and Resilience Facility and the
REPowerEU initiative, which are also contributing to clean air objectives. All data used in this report use expected
commitment appropriations. For biodiversity mainstreaming, while the projection for 2024 is close to the target,
the 2026 and 2027 targets will be more difficult to achieve.
6.2 Gender equality mainstreaming
Under the inter-institutional agreement accompanying the 2021-2027 Multiannual Financial
Framework, the Commission is required to report on the mainstreaming of gender equality
across relevant EU budget programmes. The incorporation of gender mainstreaming provisions
into the 2021–2027 MFF has seen progress in some areas but remains uneven and incomplete
across EU budget programmes. A number of MFF programmes have made notable progress.
For instance, the NDICI–Global Europe Regulation74
and the Gender Action Plan75
set a target
requiring 85% of new actions to have gender equality as a principal or significant objective.
Similarly, the Common Provisions Regulation introduced gender equality as a thematic
enabling condition, establishing it as a prerequisite for the effective implementation of EU
funds’ specific objectives. The Common Agricultural Policy 2023-2027 introduced a specific
74
Regulation - 2021/947 - EN - EUR-Lex
75
join-2020-17-final_en.pdf --> to be checked
89
reference to gender equality and the need to enhance the participation of women in farming in
one of its nine specific objectives. Horizon Europe, the EU's flagship research and innovation
programme, positions gender equality as a cross-cutting principle. From 2022 onward, public
bodies, research organisations, and higher education institutions have been required to
implement a Gender Equality Plan76
to access funding, creating a multiplier effect for gender
equality promotion. Meanwhile, the Recovery and Resilience Facility77
also requires Member
States to explain how their plans contribute to gender equality.
However, despite these positive developments, significant gaps and limitations remain. The
preparation phase of many programmes did not adequately incorporate gender considerations.
Impact assessments and ex-ante evaluations of MFF programmes often failed to identify the
relevance of gender equality or define specific objectives, resulting in design shortcomings.
For instance, the inclusion of gender as a specific objective of programmes is inconsistent
across the EU budget. This lack of integration partly explains the current situation, where 69%
of EU budget programmes are assigned a gender score of 078
. Also for certain programmes
such as the Common Agricultural Policy, although Member States were provided with the
framework to design specific interventions in favour of women79
, one of the CAP main
missions is to support farmers regardless of their gender.
At the same time, the late introduction of the methodology80
for tracking gender-related
expenditure – after programme implementation began – further complicated efforts to establish
a coherent gender mainstreaming and tracking approach.
Fragmentation has arisen from divergent methods of integrating gender objectives, designing
mainstreaming measures, and applying tracking methodologies. The misalignment between
programme design and tracking requirements has compounded these difficulties, further
impeding the establishment of a cohesive and effective approach to gender mainstreaming
across the MFF.
Table: Gender policy mainstreaming elements in the 2021-2027 programmes
Programme Gender mainstreaming elements
Horizon Europe Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
76
COUNCIL DECISION (EU) 2021/764 of 10 May 2021 establishing the Specific Programme implementing
Horizon Europe – the Framework Programme for Research and Innovation, and repealing Decision 2013/743/EU
Publications Office
77
Regulation - 2021/241 - EN - rrf - EUR-Lex
78
Annual Management and Performance Report for the EU budget – Annex I – 3. Horizontal policy priorities in
the EU
79
The majority of Member States imposed the requirement that at least 50% of women must be represented in
LEADER decision making bodies.
80
https://commission.europa.eu/strategy-and-policy/eu-budget/performance-and-reporting/horizontal-
priorities/gender-equality-mainstreaming_en
90
Recitals and dedicated articles. The gender requirements for research organisations applying for
EU funding include having a Gender Equality Plan (GEP), integrating gender considerations
into research content, and ensuring gender balance within teams and boards. Integration of sex
and gender analysis is mandatory in all topics of calls for proposals unless on-relevance of
gender is justified. The Commission provides guidance and training to support GEP
implementation and has introduced an EU Award for Gender Equality Champions. There is also
dedicated funding for gender studies and women innovators, with a focus on promoting gender
equality across various research and innovation programmes.
Euratom
Research and
Training
Programme
(Euratom)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
Recital: Gender equality is a cross-cutting priority in the Euratom programme, as stated in
recital 2 of the Council regulation. The Euratom programme is promoting gender equality
through sustainable institutional change by requesting that applicants (public bodies, research
organisations and higher education establishments) have in place a gender equality plan as an
eligibility criterion for research proposals (requirement shared with Horizon Europe). In its
2030 strategy, the Joint Research Centre declares itself as an equal opportunity employer
committed to the objective of being fully gender balanced.
ITER Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
F4E has set targets to improve gender balance internally, particularly in managerial positions.
The representation of female managers has progressed from 10% to 21% between 2018 and
2023.
InvestEU Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
Recitals and dedicated articles. Gender equality as supported objective. Regulation requires to
estimate social impact of projects (incl. gender equality). Various projects focusing on gender
equality (the gender smart advisory initiative, European Investment Fund equity financing).
Connecting
Europe Facility
(CEF)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
Recitals and dedicated articles: gender equality should be taken into account in CEF, articles on
inclusivity of those with accessibility issues.
Digital Europe
Programme
Gender tracking methodology:
In line with the Commission’s methodology to track gender-equality-related expenditure, the
programme has been attributed a score of 0*, which means that the programme’s impact on
91
gender will be determined ex post, once sufficient information from the programming and
implementation phase is available.
Gender requirements: Recitals and dedicated articles. The contribution from DEP to gender
equality in the first set of work programmes may be relevant for the training initiatives to
promote advanced digital skills organised under the 'advanced digital skills’ specific objective,
in line with Article 7 of the Digital Europe regulation, according to which gender balance should
be taken into account.
Single Market
Programme
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
Recitals and dedicated articles: attention to female entrepreneurs, and addressing needs of
vulnerable consumers and underrepresented groups.
EU Anti-Fraud
Programme
(Anti-Fraud)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
Financial support from the programme, OLAF encouraged the Member State authorities to
aspire to a better gender balance in their selection of training participants to these events.
Cooperation in
the field of
taxation
(Fiscalis)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
Score 0*: relates to the remaining types of expenditure, i.e. collaboration activities, training,
studies and communication, for which a potential to promote gender equality has been
identified.
Cooperation in
the field of
customs
(Customs)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
Recital states that gender equality should be taken into account when selecting experts.
European Space
Programme
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
Recitals and dedicated articles.
EU Secure
Connectivity
Programme
Gender tracking methodology:
Commission gender equality tracking methodology
92
Gender requirements:
The regulation establishing the programme states that the programme should contribute to the
development of advanced skills in space-related fields and support education and training
activities, along with promoting equal opportunities, gender equality and women’s
empowerment. The Commission promotes and encourages increased participation of women
and establishes equality and inclusion goals in tenders documentation. The Commission also
supports initiatives to raise awareness of gender equality in the area of space.
Regional Policy
Funds (ERDF
and Cohesion)
Gender tracking methodology:
Cohesion policy uses a ‘categorisation’ information system, which specifically focuses on the
gender equality dimension to capture information on the gender contribution of the 2021-2027
programmes. These multiannual thematic allocations are used to calculate the indicative share
of investments under each annual commitment as set above. Commission gender equality
tracking methodology.
Gender requirements:
Recitals and dedicated articles. Based on the adopted programmes, close to 10% of the planned
EU amounts will be used to support interventions the principal objective of which is to improve
gender equality or interventions that have gender equality as an objective.
Support to the
Turkish Cypriot
Community
(TCC)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
The programme contributes to gender equality (promoting the inclusion of women in social and
economic life; SDGs, supporting the development of rural/remote areas; supporting the drafting
of legal texts on equality issues (lesbian, gay, bisexual, transgender and intersex issues, anti-
trafficking, domestic violence, patients’ rights); providing direct support to civil-society
organisations addressing equality issues, promoting gender equality education, prevention of
domestic violence and sexual health education in schools).
Recovery and
Resilience
Facility (RRF)
Gender in legal basis:
Mitigating the social and economic impact of the COVID-19 crisis on women is an objective
of the RRF, as set out in Article 4 of the RRF Regulation81
. The RRF Regulation requires
Member States to explain how the measures in their RRPs contribute to gender equality and
equal opportunities for all, and the mainstreaming of these objectives.
Gender tracking methodology:
The Commission, in consultation with Member States, has assigned a tag to measures with a
focus on gender equality, based on the methodology set out in the delegated act on social
expenditure reporting under the RRF (Delegated Regulation (EU) 2021/2105). Following the
respective amendments performed in 2023, the RRPs now include 136 measures with a gender
tag. Follows Commission gender equality tracking methodology.
Gender requirements:
Mitigating the social and economic impact of the COVID-19 crisis on women is a clear
objective of the RRF, as set out in Article 4 of its founding regulation. The RRF regulation
81
REGULATION (EU) 2021/241 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 12
February 2021 establishing the Recovery and Resilience Facility
93
requires Member States to explain how the measures in their RRPs contribute to gender equality
and equal opportunities for all and the mainstreaming of these objectives.
Technical
Support
Instrument (TSI)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
Recitals and dedicated articles: in line with the principles of the gender equality strategy 2020-
2025, TSI contributes to gender equality and equal opportunities for all and for the
mainstreaming of these objectives.
Pericles IV Gender tracking methodology:
Commission gender equality tracking methodology
Union Civil
Protection
Mechanism
(UPCM)
Gender tracking methodology:
The voted budget implementations committed to the mechanism are 0* category. This mark
will be reviewed at the end of the multiannual financial framework cycle in order to categorise
funds under scores of either 0 or 1.
Gender requirements:
Recitals and dedicated articles. The Commission commits to gender-sensitive civil protection,
including addressing specific vulnerabilities and exchanging information on the issue of support
for victims of gender-based violence during disasters. The Commission promotes gender
equality through the disaster risk cycle and raises awareness of the principles of non-
discrimination and inclusiveness. It also promotes a gender-inclusive approach in response
activities and ensures that the gender component is considered.
EU4Health
Programme
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
Recitals and dedicated articles to tackle health inequalities. Some actions – for example cancer
screening for breast cancer and cervical cancer, and vaccination coverage for human
papillomaviruses – that focus on women’s health may provide relevant information for the
purpose of the gender tracking of the EU4Health programme, which for the time being has been
assigned a score of 0*. Several indicators that focus on male-related diseases – such as prostate
cancer, and the increase in vaccination coverage for human papillomaviruses in boys – may
provide relevant information on gender equality.
Emergency
Support
Instrument (ESI)
Gender tracking methodology:
Commission gender equality tracking methodology
European Social
Fund + (ESF+)
Gender tracking methodology:
The amounts provided correspond to those earmarked for the gender codes of the common
provisions regulation: ‘01’ for gender targeting (corresponding to a score of 2), ‘02’ for gender
mainstreaming (corresponding to a score of 1) and ‘03’ for gender neutral (corresponding to a
score of 0).
94
Gender requirements:
Dedicated articles and recitals. Gender equality is also a horizontal priority for the direct
management strand of the ESF+, and should be taken into account in all activities. Under ESF+
shared management, Member States were obliged to programme targeted actions aimed at
promoting gender equality. Member States and the Commission shall ensure that equality
between men and women, gender mainstreaming and the integration of a gender perspective are
taken into account and promoted throughout the preparation, implementation, monitoring,
reporting and evaluation of programmes. Gender equality is one of six thematic enabling
conditions used for the first time in the 2021-2027 period. This means that gender equality is a
prerequisite for the effective and efficient implementation of the specific objective ‘promoting
a gender-balanced labour market participation, equal working conditions, and a better work-life
balance including through access to affordable childcare, and care for dependent persons’.
Member States have to assess in their programmes whether the enabling conditions linked to
the selected specific objectives were fulfilled.
Erasmus+ Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
Recitals and dedicated articles. In line with the principles of the 2020-2025 gender equality
strategy, Erasmus+ contributes to fostering equality. The programme seeks, among other aims,
to help overcome gender stereotypes in education and educational careers and to strengthen the
promotion of participation of women in the area of science, technology, engineering and
mathematics education, especially in engineering, information and communication technologies
and advanced digital skills. For instance, the programme contributes to fostering gender balance
in higher education institutions, across fields of study and in leadership positions, while in the
vocational education and training sector it supports targeted measures promoting gender balance
in traditionally ‘male’ or ‘female’ professions and addressing gender and other stereotypes.
European
Solidarity Corps
(ESC)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
Recitals and dedicated articles: gender equality in humanitarian response, provide equal
opportunities, focus on social inclusion and equal opportunities.
Justice
Programme
Gender tracking methodology:
The justice programme is part of the pilot methodology developed by the Commission to
measure the contribution of the EU budget to gender equality.
Gender requirements:
Recitals and dedicated articles, promote gender equality (art.4).
Citizens,
Equality, Rights
and Values
Programme
(CERV)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
95
Recitals and dedicated articles. Promotion of gender equality, non-discrimination and equality,
fight violence, including gender-based violence, equality mainstreaming in civil dialogue.
Creative Europe Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
Recitals and dedicated articles. Under the creative Europe programme, special attention is given
to applications presenting adequate strategies to ensure gender balance, which was introduced
as a cross-cutting priority in all strands of the programme starting with the 2021 annual work
programme.
Communication Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
The working group on equality - created in March 2021 - produced a working plan on equality,
and monitors its implementation.
Common
Agricultural
Policy (CAP)
Gender tracking methodology:
Commission gender equality tracking methodology
Tracking of the expenditure by gender for farm beneficiaries, as from financial year 2024
Gender requirements:
Under CAP 2014-2022, the gender perspective was considered during the preparation and
implementation of the rural development programmes. Gender equality was specifically sought
in the rural development policy through the possibility to submit thematic subprogrammes for
women in rural areas (although no Member States had done so), the possibility to target rural
development support to women through the application of selection criteria, and the obligation
to respect ex ante conditionality on gender equality.
The CAP 2023-2027 went further and introduced a specific reference to the need to enhance
the participation of women in farming and strengthen the inclusion of women into rural
economy within the specific objective (h) (Art. 6 of 2021/2115). This provides Member States
with the policy and funding framework for the design of specific interventions in favour of
women. As an illustration, Spain introduced enhanced payments for young women farmers
under EAGF and Ireland provides young women farmers with a possibility to receive higher
payments under EAFRD. Furthermore, the majority of Member States committed to include at
least 50% of women into LEADER decision making bodies. In addition, the majority of
Member States included organisations representing the interests of women in their monitoring
committees. In this context, Regulation 2021/2115 requires Member States to establish a
partnership that includes relevant bodies, including those responsible for gender equality and
non-discrimination.
European
Maritime
Fisheries and
Aquaculture
Fund (EMFAF)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
96
Recitals and relevant articles in CPR.
Programme for
Environment
and Climate
Action (LIFE)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
The LIFE programme does not directly target gender equality, since its main objective is linked
to climate and environment spending. A gender dimension is considered in some areas of
intervention to identify how men and women relate to the environment and to climate action in
different ways, thus addressing specific gender vulnerabilities (e.g. inherent to harmful
chemicals such as endocrine disruptors and persistent organic pollutants).
Just Transition
Mechanism
Gender tracking methodology:
The JTM uses a categorisation information system, which focuses specifically on the gender
equality dimension, to capture information on the gender contribution of the 2021-2027
programmes.
Gender requirements:
Recitals and relevant articles in CPR.
Asylum,
Migration and
Integration Fund
(AMIF)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
Recitals and dedicated articles and CPR. The programme is committed to the horizontal
approach of the EU budget, in which equality between women and men, rights and equal
opportunities for all and the mainstreaming of these objectives should be taken into account and
promoted throughout the preparation, implementation and monitoring of relevant programmes,
as stipulated in Article 6 of the programme regulation (Regulation (EU) 2021/1147). In order
to receive payments from the Commission, Member State programmes will have to comply with
a number of horizontal-enabling conditions, one of which concerns the effective application and
implementation of the EU Charter of Fundamental Rights, including the equality of men and
women. The programme regulation specifically stipulates that eligible actions need to take into
account the human rights-based approach to the protection of migrants, refugees and asylum
seekers and should, in particular, ensure that special attention is paid to, and a dedicated
response is provided for, the specific situation of vulnerable persons, in particular women,
unaccompanied minors and victims of trafficking in human beings.
Integrated
Border
Management
Fund (IBMF)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
Recitals, dedicated articles and CPR. To receive payments, Member States programmes have
to comply with a number of horizontal enabling conditions, one of which concerns the effective
application and implementation of the EU Charter of Fundamental Rights, including the
equality of women and men. The horizontal enabling conditions must be fulfilled throughout
the entire programming period, and Member States must report on their application to the
programme monitoring committee and the Commission.
97
As regards the types of action supported, training and knowledge sharing habitually tackle
gender-specific issues, which is why they are financial interventions that may have potential to
impact gender equality, among other areas.
Internal Security
Fund (ISF)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
Recitals, dedicated articles and CPR. To receive payments from the Commission, Member
States’ programmes have to comply with several horizontal enabling conditions, one of which
concerns the effective application and implementation of the EU Charter of Fundamental
Rights, including the equality of men and women. Horizontal enabling conditions must be
fulfilled throughout the entire programming period, and Member States must report on their
application to the programme monitoring committee and the Commission. As regards the types
of action supported by the programme, training and knowledge sharing habitually tackle gender-
specific issues, which is why they are considered to be financial interventions that may have
potential to impact gender equality, among other areas.
Nuclear Safety
and
Decommissioning
(NSD)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
The gender equality perspective was considered in developing Council Regulation (EU)
2021/100.
European
Defence Fund
(EDF)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
Recital, seek balanced composition of expert groups.
Regulation on
Supporting
Ammunition
Production
(ASAP)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
No specific provisions.
EU Defence
Industry
Reinforcement
Through
Common
Procurement Act
(EDIRPA)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
On equality, diversity and inclusion, EDIRPA is not directly targeted at gender equality
initiatives. Nevertheless, indirect contributions supporting the gradual raising of awareness
about gender equality are continually being made as opportunities arise. For instance, gender
equality aspects receive special mentions in communication activities and at events on various
matters relating to EDIRPA.
Neighbourhood,
Development and
International
Gender tracking methodology:
98
Cooperation
Instrument
(NDICI Global
Europe)
OECD DAC methodology
Gender requirements:
Recitals and dedicated articles. According to the NDICI – Global Europe regulation, at least
85% of new initiatives implemented should have gender equality as a principal or a significant
objective, as defined by the gender equality policy marker of the Development Assistance
Committee of the Organisation for Economic Co-operation and Development. At least 5% of
these actions should have gender equality and women’s and girls’ empowerment as a principal
objective. In 2020, the gender action plan III (2021-2025), a joint communication from the
Commission and the High Representative of the Union for Foreign Affairs and Security Policy,
was adopted with the same objective of 85% towards the total number of adopted initiatives,
following the Development Assistance Committee’s methodology. A significant number of EU
delegations have a gender analysis at country level, along with a sector analysis, and they have
put measures in place to ensure the use of gender-specific and sex-disaggregated data, which
are essential tools to ensure quality mainstreaming into new initiatives.
European
Instrument for
International
Nuclear Safety
Cooperation
(INSC)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
The INSC promotes gender equality through its training, tutoring and education programme,
where the participation of partner countries is conditional upon the gender-balanced registration
of students.
Humanitarian
Aid (HUMA)
Gender tracking methodology:
Commission gender equality tracking methodology. Humanitarian aid has some impact on
gender equality (therefore, scores 0 and 0* could not be assigned), but gender equality is also
not the principal objective of the programme (therefore score 2 could not be assigned).
Gender requirements:
Mainstreaming gender and age is done across sectors of intervention, outlining the approach to
gender and gender-based violence in humanitarian crises in the staff working document
‘Gender: Different needs, adapted assistance’. The EU is a member of the ‘Call to action on
protection from gender-based violence in emergencies’ initiative and reported on the
commitments made on the road map for 2021-2025. Focus on conflict-related sexual violence
was increased in response to observations in several recent and ongoing crises.
Common
Foreign and
Security Policy
(CFSP)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
All civilian CSDP missions, except the newly established EU Partnership Mission in Moldova
and the Gulf of Guinea initiative, have gender equality as an important objective (Development
Assistance Committee gender equality marker 1)
Overseas
Countries and
Territories
(OCT) (including
Greenland)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
The DOAG programme states that gender equality should be mainstreamed into all initiatives
as a key contribution to the successful achievement of the SDGs. New initiatives aim to ensure
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that gender aspects are considered to the extent possible, notably through sex-disaggregated
data.
Macro-Financial
Assistance
(MFA)
Gender tracking methodology:
Commission gender equality tracking methodology
Instrument for
Pre-Accession
Assistance (IPA
III)
Gender tracking methodology:
The Commission’s gender expenditure tracking methodology for the EU budget is in line with
the Development Assistance Committee’s gender equality policy marker methodology. Score 2
equals G2 and implies that gender equality is principal objective; score 1 equals G1 and implies
that gender equality is a significant objective; score 0 equals G0 and means that gender equality
is not targeted. The use of the Organisation for Economic Co-operation and Development
gender marker is also aligned with the methodology established by the gender action plan III.
Gender requirements:
Recitals and dedicated articles. The gender action plan III (2021-2025) defines clear objectives
and targets concerning gender mainstreaming in policies and programmes. The plan establishes
that, by 2025, at least 85% of all new external actions should have gender equality and women’s
and girls’ empowerment as a significant objective or as a principal objective, and that at least
one action with gender equality as a principal objective should be supported in each country
and region. Such objectives apply to actions funded under IPA III, as established by recital 27
of the IPA III regulation and the IPA III programming framework. In 2023, the European
Commission and the European External Action Service adopted a joint midterm report on the
implementation of the gender action plan III.
Reform and
Growth Facility
for the Western
Balkans
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
Activities under the facility mainstream gender equality.
Ukraine Facility Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
Activities under the facility mainstream gender equality and non-discrimination, where
relevant.
European
Globalisation
Adjustment
Fund for
Displaced
Workers (EGF)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
The EGF regulation provides for the Commission and Member States to ensure that equality
between men and women and the integration of the gender perspective are integral parts of and
promoted during all stages of the implementation of the financial contribution from the EGF.
To that end, Member States formally confirm the respect of this principle at the time of
application, when they provide gender-disaggregated information on the workers targeted for
assistance. As relevant, the Commission requests that Member States provide further
information on the gender aspect in the course of its assessment of an application. This is,
however, a general principle applied across the implementation and final reporting of the EGF
100
cases, and estimating budget contributions is not relevant. Evaluations of the EGF include an
analysis of both gender disaggregated data and qualitative information (beneficiary surveys,
interview with implementers, etc.) regarding possible gender discrimination. In the course of
EGF evaluations, external contractors conduct case studies on EGF cases, also taking the gender
perspective into account. Past evaluations did not detect gender discrimination in either the
delivery of measures or the targeting of beneficiaries. In many cases, authorities aim to help
participants overcome gender stereotypes when looking for a new job.
EU Solidarity
Fund (EUSF)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
No specific provisions on gender equality.
Innovation Fund
(IF)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
No specific provisions on gender equality.
Brexit
Adjustment
Reserve (BAR)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
No specific provisions on gender equality. However, the objectives of the reserve should be
pursued in line with the principles set out in the European Pillar of Social Rights, including the
inherent contribution to the elimination of inequalities and to the promotion of gender equality
and gender mainstreaming, while ensuring respect for fundamental rights.
Social Climate
Fund (SCF)
Gender tracking methodology:
Commission gender equality tracking methodology
Gender requirements:
No specific provisions on gender equality.
Table: Gender expenditure per programme (per gender score82):
Programme
Gender Score 2021-2023
0 0* 1 2
82
The gender scoring methodology assesses the gender equality relevance of interventions: Score 2 refers to
interventions the principal objective of which is to improve gender equality, Score 1 refers to interventions having
gender equality as an important and deliberate objective (but not as the main reason for the intervention), Score
0* refers to interventions having the potential to contribute to gender equality, and Score 0 corresponds to
interventions not having a significant bearing on gender equality.
101
Horizon Europe
1143.3 29867.8 4841.4 215.3
3% 83% 13% 1%
Euratom Research and Training
Programme 0 820.4 0 0
0% 100% 0% 0%
ITER
2123.8 0 0 0
100% 0% 0% 0%
InvestEU
0 2366.2 0 0
0% 100% 0% 0%
Connecting Europe Facility
0 13906.4 0 0
0% 100% 0% 0%
Digital Europe Programme
0 3701.4 0 0
0% 100% 0 0
Single Market Programme
0 1903.9 0 0
0% 100% 0 0
EU Anti-Fraud Programme
73.3 0 0 0
100% 0% 0% 0%
Fiscalis
88.1 19.8 0 0
82% 18% 0 0
Customs
354.7 22.2 0 0
94% 6% 0 0
European Space Programme
1977.1 4053.3 0 0
33% 67% 0 0
EU Secure Connectivity Programme
0 186.3 0 0
0% 100% 0 0
Regional Policy Funds (ERDF and
Cohesion) 79945.6 0 710.1 8014.1
90% 0% 1% 9%
Support to the Turkish Cypriot
Community
0 98.8 1.1 0
102
0 99% 1% 0
Recovery and Resilience Facility
627111.3 0 13947.1 7917.8
97% 0% 2% 1%
Technical Support Instrument
0 335.4 0 20.4
0% 94% 0% 6%
Pericles IV
2.4 0 0 0
100% 0% 0% 0%
Union Civil Protection Mechanism
0 789.6 0 0
0% 100% 0% 0%
EU4Health Programme
1729.1 178.1 0 0
91% 9% 0% 0%
Emergency Support Instrument
224 7.7 0 0
97% 3% 0% 0%
European Social Fund +
1448.9 2352.7 27249.8 1324.9
4% 7% 84% 4%
Erasmus+
0 6799.1 2030.3 938.3
0% 70% 21% 10%
European Solidarity Corps
0 306.8 0 114.6
0% 73% 0% 27%
Justice Programme
20.6 96.8 12.4 0.3
16% 74% 10% 0%
Citizens, Equality, Rights and
Values Programme 35.4 102.1 304.7 86
7% 19% 58% 16%
Creative Europe
0 983.8 0 61.8
0% 94% 0% 6%
Communication
0 322.8 0 0
0% 100% 0% 0%
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Common Agricultural Policy
0 160930.8 0 0
0% 100% 0% 0%
European Maritime Fisheries and
Aquaculture Fund (EMFAF) 2300.4 40.6 0 0
98% 2% 0% 0%
LIFE
2248 5.5 0
99.80% 0.20% 0%
Just Transition Mechanism
10283.2 3779.1 106.3
73% 27% 1%
Asylum, Migration and Integration
Fund (AMIF) 0 3371.9 0 0
0% 100% 0% 0%
Integrated Border Management
Fund (IBMF) 2253.6 231.2 0 0
91% 9% 0% 0%
Internal Security Fund
534.6 95.7 0 0
85% 15% 0 0
Nuclear Safety and
Decommissioning 166.4 0 0 0
100% 0% 0% 0%
European Defence Fund
945.7 1891.4 0 0
33% 67% 0% 0%
ASAP
0 0 0 0
0% 0% 0% 0%
EDIRPA
0 0 0 0
0% 0% 0% 0%
Neighbourhood, Development and
International Cooperation
Instrument
3125.8 0 30944.2 952
9% 0% 88% 3%
European Instrument for
International Nuclear Safety
Cooperation (INSC)
15 0 100.9 0
13% 0% 87% 0%
Humanitarian Aid
0 0 7017.9 0
104
0% 0 100% 0
Common Foreign and Security
Policy 1085.5 0 837.6 0
56% 0% 44% 0
Overseas Countries and Territories
(OCT) (including Greenland) 74 0 127.1 0
37% 0% 63% 0
Macro-Financial Assistance
0 630.8 0 0
0% 100% 0 0
Instrument for Pre-Accession
Assistance (IPA III)
3420.0 0 2557 83.6
56% 0% 42% 1%
Reform and Growth Facility for the
Western Balkans 0 0 0 0
0% 0% 0% 0%
Ukraine Facility
0 0 0 0
0% 0% 0% 0%
European Globalisation Adjustment
Fund for Displaced Workers 0 44.3 0 0
0% 100% 0% 0%
EU Solidarity Fund
1059 0 0 0
100% 0% 0% 0%
Innovation Fund
0 6611.7 0 0
0 100% 0% 0%
Brexit Adjustment Reserve
1991.1 0 0 0
100% 0% 0% 0%
Social Climate Fund
0 0 0 0
0 0 0 0
743988.1 243069.8 94466.1 19835.4
69% 21% 8% 2%
105
Gender equality mainstreaming under the post-2027 programmes
The integration of gender equality across all EU budget programmes is a cornerstone of the
Union’s commitment to inclusive and sustainable development and an essential element
towards building a Union of Equality and promote equal opportunities for all. In line with the
Gender Equality Strategy post 2025, gender mainstreaming is embedded into the performance
framework as a horizontal principle. The Financial Regulation requires that all EU budget
programmes and activities, where feasible and appropriate, are implemented taking into
account the principle of gender equality in accordance with an appropriate gender
mainstreaming methodology.
There are several mechanisms to mainstream cross-cutting policy priorities into programmes
(‘mainstreaming toolbox’). One of them is by means of a robust performance framework, with
performance indicators, expenditure-tracking methodology and reporting requirements that
make it possible to identify investments and measures that contribute to that priority. Another
tool is the design of the programmes, including by setting policy-specific objectives that guide
the programming of the actions that get support from the EU budget. This section of the impact
assessment deals with the latter point. The question hereby examined is when gender should
be included as a specific objective in the programmes for the next MFF.
To answer this question, guidance can be drawn from the Gender mainstreaming toolkit by the
European Institute for Gender Equality (EIGE) as a starting point.83
In accordance with this
document, an initiative is likely to impact on gender equality if the following two conditions
are met: (1) The ultimate target group is people, considering both individuals and legal entities;
and (2) the proposed initiative affects women and men regarding their access to and/or control
of resources and it has an impact on the social situation or position of women and men, by
either improving or harming it. It points out that the impact may be direct (regulating or
affecting people’s access to resources) or indirect (the measure affects people indirectly, as
they are behind companies that may be subject to the measures). Gender analysis provides
elements to discern these impacts.
This EIGE analysis provides some general considerations for any public initiative, be it a law,
policy or programme. For the purposes of determining the gender relevance of an EU budget
programme, this has to be read in conjunction with the wording of the Financial Regulation,
which requires to take into account gender equality ‘where feasible and appropriate’, the
principle of proportionality, and also the gender equality methodology currently applied to the
EU budget, whereby certain interventions are given a ‘score 0’ where they do not have a
significant bearing on gender equality.
EU spending instruments do not influence gender equality outcomes in the same way and with
the same intensity, because of their objectives or the policy areas they focus on. Some
programmes operate in technical or regulatory domains (e.g. administrative cooperation or anti-
fraud) and their interventions are not expected to have a significant bearing on gender equality.
In such cases, the introduction of gender-specific objectives might not have a significant added-
value.
83
https://eige.europa.eu/sites/default/files/documents/eige_gender_impact_assessment_gender_mainstreaming_too
lkit.pdf
106
From this perspective, gender-specific policy objectives should be included in programmes
with potentially direct impacts, and not included in programmes with indirect impacts only.
This approach ensures the performance framework is more focused, targeted, and meaningful
– supporting genuine integration of gender equality in programmes where it can make most
difference. It also ensures that the scoring system remains an effective policy tool, rather than
a merely administrative exercise.
The table below summarises the gender relevance for programmes under the next MFF. If a
programme does not seem to have a significant gender relevance, in the sense that gender
considerations do not seem substantially pertinent to the programme’s logic, activities, or
expected results, it can be concluded that gender should not feature as a specific objective in
that programme. The fact that gender is not explicitly included as an objective of a programme
would not preclude that programme from supporting projects with a gender dimension.
Moreover, the classification may be revisited should the scope or delivery mechanisms of these
programmes evolve to include elements relevant to gender equality.
Programme Gender
relevant?
Justification of whether gender
mainstreaming is relevant and appropriate
National and Regional
Partnership Plans
Yes Gender mainstreaming will be relevant for
National and Regional Partnership Plans, given
their wide scope and the number of different
policies with a gender dimension that such
agreements will support, including for instance
social policies and cohesion, which are
ultimately aimed at supporting people in
different ways. Integrating a gender perspective
will lead to more inclusive, efficient, and
resilient projects, in addition to helping to
target diverse needs, supporting sustainable
development, and aligning with EU priorities
on equality and social cohesion. Moreover,
National and Regional Partnership Plans will
provide an opportunity to address gender
inequalities in Member States not only through
investments but also national reforms.
European Competitiveness
Fund
Yes Gender mainstreaming will be relevant for the
EU Competitiveness Fund. The Fund will aim
at supporting several strategic sectors, such as
the clean and digital transition and health.
Evidence shows that gender inclusive policies
enhance innovation, productivity, and
economic resilience, which are core drivers of
competitiveness. Historically, overlooking
gender disparities has limited talent potential
and stifled growth in those sectors. Looking
forward, as the EU aims for a more sustainable,
digital, and equitable economy, integrating
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gender perspectives ensures that policies and
investments are effective, fair, and future proof.
Research framework
programme
Yes Gender mainstreaming should be applied to the
research framework programme to reinforce
the EU's commitment to equality, diversity, and
inclusion in research and innovation. As a
cross-cutting priority, gender equality ensures
equal opportunities, enhances research quality
through diverse perspectives, and is already
embedded as a requirement in Horizon Europe.
Continuing and strengthening this approach
will help sustain progress, improve the societal
relevance of research outcomes, and ensure fair
participation across the european research area.
Global Europe Instrument Yes Gender is relevant for the EU external action
funds as it ensures that gender equality is
systematically integrated into all aspects of
external action policy and programming.
Persistent gender disparities have hindered
inclusive development, stability, and
peacebuilding efforts—areas central to EU
external actions. Forward-looking, gender
mainstreaming aligns with the EU’s strategic
priorities and international commitments, such
as the Sustainable Development Goals and the
Gender Action Plan III, by promoting equitable
outcomes, empowering women and girls, and
enhancing the effectiveness, accountability, and
sustainability of EU-funded interventions
worldwide.
Connecting Europe Facility No Gender mainstreaming is not particularly
relevant for the Connecting Europe Facility
(CEF). In the CEF Transport strand, the
primary focus is on large-scale infrastructure
projects such as railway corridors, which are
fundamentally different from local or regional
infrastructure where gender relevance might be
more pronounced. Additionally, CEF does not
finance passenger train stations, which could
have more direct implications for gender
equality by affecting passengers. Consequently,
the emphasis on large-scale infrastructure
projects and the areas funded by CEF present
108
limited opportunities for addressing gender-
specific needs within this framework. CEF
2021-2027 has been assigned a score of 0 for
its contribution to gender equality.
Erasmus – European
Solidarity Corps
Yes Gender mainstreaming is relevant for both
Erasmus and European Solidarity Corps. These
programmes have aimed to promote inclusion,
diversity, and equal opportunities—values that
are undermined without a gender-sensitive
approach. Forward-looking, gender
mainstreaming is essential to foster truly
equitable access and participation for all,
empower underrepresented groups, and prepare
young people to become active, inclusive
citizens in a rapidly evolving European society.
It strengthens the impact and social fairness of
these initiatives.
Creative Europe – Citizens,
equality, rights and values
Yes Gender mainstreaming is relevant for the
Creative Europe – Citizens, equality, rights and
values fund because it ensures inclusive and
equitable participation in cultural and civic life,
promotes fair representation, combats
stereotypes, and strengthens democracy by
fostering inclusion and participation.
Integrating gender perspectives enhances the
fund’s impact, ensuring it supports a vibrant,
pluralistic, and just European society.
Union Civil Protection
Mechanism
Yes Gender mainstreaming is relevant for the Union
Civil Protection Mechanism because it ensures
that disaster risk reduction and response
measures address the different needs,
vulnerabilities, and strengths of all genders.
Historically, women, girls, and other
marginalized groups have often faced greater
risks and barriers during emergencies due to
unequal access to resources, decision-making,
and protection. Looking forward, integrating
gender perspectives enhances the effectiveness,
equity, and sustainability of disaster response
by promoting inclusive planning, empowering
diverse community roles, and ensuring that no
group is left behind in resilience-building
efforts.
109
Single Market Programme + No The gender dimension does not seem relevant
for this programme, given its objectives. Its
target group is national public administrations
rather than individuals or legal entities in a
socio-economic sense. The programme focuses
on administrative efficiency, regulatory
compliance, and fraud prevention. As such, it is
not expected to have a significant impact on the
social situation or position of women and men,
and therefore does not present a clear gender-
differentiated effect.
Justice programme Yes Gender mainstreaming is relevant for the EU
Justice programme as it addresses long-
standing gender disparities in access to justice,
protection from gender-based violence, and
equal treatment under the law. It will also
support the EU’s commitment to equality, non-
discrimination, and inclusive justice systems,
enabling more effective responses to evolving
social challenges. By embedding gender
considerations, the programme promotes fairer
legal outcomes and strengthens democratic
values across member states.
Euratom Research and
Training - ITER
No The gender dimension does not seem relevant
for these programmes, given their objectives.
The Euratom Research and Training and ITER
programmes fund advanced nuclear research,
including the development of nuclear fusion
technologies. They involve international
scientific partnerships, long-term engineering
efforts, and support to public research
institutions. Unlike other areas of research and
innovation, there does not seem to be a clear
gender dimension from the perspective of the
content of the research.
Instrument for Nuclear
Safety cooperation and
decommissioning
No The gender dimension does not seem relevant
for this programme, given its objectives. This
programme supports actions to improve nuclear
safety within the EU and in partner countries,
including regulatory cooperation, capacity
building, and technical assistance. Its focus is
on aligning safety practices with international
standards and supporting institutional
development in the nuclear sector. Its target
group consists of institutional actors. The
110
programme does not seem to have a significant
gender impact.
Nuclear decommissioning
LT
No The gender dimension does not seem relevant
for this programme, given its objectives. This
programme supports the safe and efficient
decommissioning of nuclear facilities in
Lithuania, in line with EU safety standards and
environmental protection objectives. Its
implementation is highly technical, involving
infrastructure dismantling, radioactive waste
management, and site remediation. Its target
group comprises national implementing bodies
and specialised contractors. The programme
focuses on technical operations such as
dismantling infrastructure and managing
radioactive waste. Therefore, it does not
generate significant gender-differentiated
impacts.
Turkish-Cypriot Community Yes Gender mainstreaming is relevant for the EU
Turkish-Cypriot Community programme as it
ensures inclusive development by addressing
historical gender inequalities and promoting
equal participation in social, economic, and
political life. It acknowledges the
underrepresentation and systemic challenges
faced by women within the community. By
integrating gender perspectives into all stages
of programming, the initiative can more
effectively meet the diverse needs of the
community and contribute to long-term,
inclusive growth.
Overseas Countries and
Territories (incl. Greenland)
Yes Gender mainstreaming is relevant for the EU
Overseas Countries and Territories (OCTs)
programme, including Greenland, both in terms
of addressing past inequalities and shaping a
more equitable future. Historically, gender
disparities in access to resources, decision-
making, and opportunities have been prevalent
in many OCTs, and gender mainstreaming
ensures that policies and projects take these
disparities into account. By integrating gender
equality into development planning, the EU can
foster more inclusive growth and address
gender specific challenges, while promoting
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social justice and human rights across its
territories.
Pericles No The gender dimension does not seem relevant
for this programme, given its objectives. The
Pericles programme aims to prevent and
combat counterfeiting of the euro through
training, technical assistance, and the
strengthening of operational cooperation
among competent national and European
authorities. Its beneficiaries are public
authorities such as police forces, financial
crime units, customs, and judicial institutions.
Pericles is narrowly focused on financial
security and protection against organised crime.
It does not target people. The technical nature
of its interventions and the institutional profile
of its actors provide no leverage for pursuing
gender equality outcomes.
The Performance Regulation will set out dedicated rules regarding the mainstreaming of gender
equality across EU budget programmes. It will also include dedicated articles setting out
specific provisions for each management mode, providing for the systematic integration of
gender equality in Member States and third countries plans, in calls under direct management
as well as by implementing partners under indirect management.
6.4 Do No Significant Harm
Following adoption of the IIA for the 2021-2027 MFF – which refers to the contribution of the
Union budget to the European Green Deal and the ‘do no harm’ principle – the ‘do no
significant harm’ (DNSH) principle has been applied across an increasing number of MFF
programmes, with the respective approaches listed in the Climate Mainstreaming SWD
112
(2022)84
. Specifically the RRF Regulation provides that no measure included in a Member
State’s Recovery and Resilience Plan (RRP) should lead to significant harm to any of the six
environmental objectives within the meaning of Article 17 of the EU Taxonomy Regulation85
.
The InvestEU Fund uses sustainability proofing guidance to operationalise the DNSH
principle. In addition, the DNSH principle will be applicable in different forms to the
Modernisation and Innovation Fund from 2025 (applying the Taxonomy delegated acts when
technical screening criteria have been developed for the concerned activity) and the Social
Climate Fund from 2026 (through the development of a dedicated guidance).
The Financial Regulation recast86
further states that ‘programmes and activities shall, where
feasible and appropriate in accordance with the relevant sector-specific rules, be implemented
to achieve their set objectives without doing significant harm to the environmental objectives
of climate change mitigation, climate change adaptation, the sustainable use and protection of
water and marine resources, the transition to a circular economy, pollution prevention and
control and the protection and restoration of biodiversity and ecosystems’.
While the DNSH principle has been applied to most relevant programmes, the approach has
not been coordinated nor harmonised between these programmes. A 2023 study by JRC
examined the approach to DNSH operationalisation in-depth for a select number of
programmes, illustrating the varied landscape of DNSH operationalization under the 2021-
2027 policy cycle87
.
Overall, the implementation of the DNSH principle across various EU budget programmes
under the 2021-2027 period presents a complex design with varying degrees of integration and
operational depth. As the JRC report notes,88
this heterogeneity in DNSH application may lead
to inconsistent results and create challenges for implementation.
Depth and complexity of DNSH implementation: Some programmes have thoroughly
integrated DNSH into their operational frameworks, while others have not implemented it or
have done so to a lesser extent. The differences can be attributed to the varying legal bases and
the specific objectives of each programme. For instance, programmes with a strong
environmental focus like LIFE have a more detailed approach, while others, such as the Fiscalis
programme, may not address DNSH due to the nature of their activities. In addition, the depth
and complexity vary even between programmes with a similar approach towards DNSH.
Inconsistencies and fragmentation across MFF programmes: Due to the variance in
approach towards DNSH, there is a notable inconsistency and fragmentation in how DNSH is
applied. The same type of interventions might be treated differently across programmes, which
84
COMMISSION STAFF WORKING DOCUMENT Climate Mainstreaming Architecture in the 2021-2027
Multiannual Financial Framework
85
Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment
of a framework to facilitate sustainable investment
86
Regulation (EU, Euratom) 2024/2509 of the European Parliament and of the Council of 23 September 2024 on
the financial rules applicable to the general budget of the Union (recast)
87
Beltran Miralles, M., Gourdon, T., Seigneur, I., Arranz Padilla, M. and Pickard Garcia, N., The implementation
of the ‘Do No Significant Harm’ principle in selected EU instruments, Publications Office of the European Union,
Luxembourg, 2023, doi:10.2760/18850, JRC135691.
88
The implementation of the ‘Do No Significant Harm’ principle in selected EU instruments, Joint Research
Center, JRC Publications Repository - The implementation of the ‘Do No Significant Harm’ principle in selected
EU instruments
113
may generate challenges for beneficiaries eligible under different EU budget programmes. For
example, an energy efficiency project might be subject to strict DNSH requirements under the
LIFE Programme but not under another programme with a different legal basis. Additional
technical guidances for some funds have led to the parallel application of several sets of
technical criteria, creating complexities for project implementers who must navigate both the
DNSH criteria from EU fund guidance and the EU Taxonomy.
Challenges faced by Member States and beneficiaries: The diverging application of DNSH
has resulted in additional administrative burden. Member States and project beneficiaries,
including businesses, face heterogeneity in requirements, leading to uncertainties and a lack of
predictability. This can impact the competitiveness of sectors supported by EU funds, as they
grapple with the administrative complexities associated with different DNSH applications. In
addition, inconsistent approaches limit the synergies among EU funding instruments and hinder
the overall contribution to the EU climate and environmental objectives. These divergences
can prevent the efficient combination of support from different Union funds
Future applications of DNSH: The financial regulation recast acknowledges the challenges
by stipulating that DNSH should be applied where "feasible and appropriate." This provision
aims to provide some flexibility and recognizes the need for a balanced approach to applying
DNSH across diverse programmes, suggesting a more harmonised and streamlined application
in the future.
Table: DNSH application in the 2021-2027 programmes
Programme DNSH application
Horizon Europe DNSH is integrated at project level and screened during the co-creation
of work programs, though not uniformly applied across all parts of the
program.
InvestEU The InvestEU Regulation establishes the need for the operations to be
funded to go through a sustainability proofing process, and the related
guidance needs to take appropriate account do no significant harm. The
InvestEU Regulation does not lay down that the operations must comply
with the DNSH principle. However, the sustainability proofing
methodology has integrated to some extent the DNSH principle. There
is an exemption from sustainability proofing for projects below a
specific threshold (generally 10 million euro)
Connecting
Europe Facility
(CEF)
Applied through environmental legislation compliance, climate
proofing, and sustainability criteria in project selection.
European Space
Programme
Incorporates DNSH through specific templates for downstream
Copernicus services to ensure they do not harm the environment.
Regional Policy
Funds (ERDF,
CF, ESF+)
DNSH is operationalized through screenings, environmental
assessments, climate proofing, and monitoring within operational
programs.
114
Recovery and
Resilience
Facility (RRF)
Follows technical guidance on DNSH, with ex ante assessments that
national plans do no significant harm to environmental objectives within
the meaning of Article 17 of the EU Taxonomy Regulation.
Technical
Support
Instrument (TSI)
Not directly applicable as the programme provides expertise, i.e. not
direct funding, but it ensures that support activities do not contradict
DNSH principles.
Common
Agricultural
Policy (CAP)
Integrated through strategic planning and reviews, with provisions to
avoid environmentally harmful activities.
European
Maritime,
Fisheries and
Aquaculture Fund
(EMFAF)
Ensures compliance through conditions and exclusion of operations that
could cause harm, guided by its regulation.
LIFE Programme
Embeds DNSH in each sub-programme, with stringent screening
against the EU Taxonomy's environmental objectives.
Just Transition
Mechanism
(JTM)
Assigns a 100% climate coefficient to all investments, reflecting the
focus on supporting regions transitioning towards a green economy.
Neighbourhood,
Development and
International
Cooperation
Instrument
(NDICI Global
Europe)
Adopts a positive approach, excluding activities not aligned with
climate commitments, with mandatory environmental screenings and
mainstreaming DNSH through an ex-ante screening of projects.
Social Climate
Fund (SCF)
Additional guidance with annexes providing technical screening criteria
for activities covered by the fund to comply with DNSH.
Figure: JRC 2023 study on DNSH
115
DNSH application under the post-2027 programmes
The Performance Regulation will set out dedicated rules regarding the application of the DNSH
principle across EU budget programmes, including the development of a technical guidance to
support future implementation. It will also include dedicated articles setting out specific
provisions for each management mode, providing for the systematic integration of DNSH in
Member States and third countries plans, in calls under direct management as well as by
implementing partners under indirect management.
116
ANNEX 7: MONITORING FRAMEWORK OF THE 2021-2027 BUDGET
7.1 Tracking of expenditures in the EU budget
7.1.1.1 Tracking of expenditures contributing to horizontal priorities
The interinstitutional agreement on the 2021-2027 MFF introduced the following horizontal
commitments: a climate spending target (30% of the EU budget), a biodiversity spending target
(7.5% in 2024 and 10% in 2026-2027), report on the EU budget contribution to Sustainable
Development Goals (SDGs), as well as the requirement to monitor gender equality expenditure.
The latter is analysed in detail under subsection 7.1.2 ‘Gender equality tracking’. However,
the monitoring of cross-cutting priorities still requires further refinement. While significant
progress has been made – figures reflecting the EU budget's contributions to key priorities are
now more robust and reliable thanks to substantial structuring efforts – challenges remain.
On the one hand, a unified tracking system to monitor the current crosscutting issues has yet to
be established. For green priorities, the Common Agricultural Policy and external funds still
do not fully align with the intervention field methodology. External funds continue to rely on
the OECD methodology based on Rio Markers, which focuses on the intent behind projects
rather than their concrete, expected outcomes. This can lead to inconsistent project tagging and
discrepancies in reporting. On the other hand, beyond the horizontal commitments introduced
in the interinstitutional agreement, the European Commission is not able to track expenditures
of additional cross-cutting priorities such as digitalisation, competitiveness, or defence, thus
aligning financial instruments more closely with strategic EU priorities and future-proofing
budgetary planning.
On green priorities, agreed in the interinstitutional agreement, methodologies for climate and
biodiversity should be developed ‘on the basis of an effective, transparent and comprehensive
methodology’. To this end, the Commission decided to move away from the ‘OECD Rio
markers’ approach used in 2014-2020 and to develop a new distinct approach based on ‘EU
coefficients’. This approach is based on a list of activities with specific coefficients decided
ex-ante. Such an approach enhances the transparency and accountability of how green
expenditures are tracked and diminish the discretionality of the agent assigning the coefficient.
As today, this new approach has nonetheless been only partially integrated into the EU budget,
as many basic acts and programmes deviate from this approach, as later formalized in the
communication on the performance framework of the EU budget under the 2021-2022
multiannual financial framework. The new methodological approach still assigns three
different coefficients (0%, 40% or 100%) based on a list of predefined activities, but also
integrating the taxonomy where relevant. The Commission has published a climate
mainstreaming architecture staff working document89
, where it has outlined the principles of
its methodology, including the integration of the ‘do no (significant) harm’ principle.
89
COMMISSION STAFF WORKING DOCUMENT Climate Mainstreaming Architecture in the 2021-2027
Multiannual Financial Framework, 968be999-7fd5-45ac-8c1b-0c9edcce2c15_en
117
On biodiversity, a dedicated tracking methodology90
was developed in 2021, using a similar
approach to the climate methodology. In 2023, the Commission complemented the tracking
methodology with a specific methodology for the Common Agricultural Policy, taking into
consideration the adopted strategic plans. More details are available in the Biodiversity
Financing and Tracking Report.91
On SDGs, although the European Commission, in its 2021 Inter-Institutional Agreement,
mandated annual reporting on the EU's contribution to the SDGs92, this requirement has been
met with challenges due to the high-level, cross-sectoral nature of the SDGs. Fragmentation
across MFF programs is evident, with some EU programs like Horizon Europe explicitly
incorporating SDGs in their objectives, while others only reference them indirectly or omit
them entirely.93
This inconsistency undermines a unified, coherent approach to aligning EU
financial instruments with global sustainability commitments and makes it difficult to gauge
the collective impact of EU programs on the SDGs. Additionally, the annual reports produced
by the Commission, as required by the IIA, offer limited added value because of their broad,
over-arching nature. These reports present high-level summaries that do not provide the
actionable insights necessary to promote policy coherence or address specific gaps in SDG
implementation.94
Table: Contribution to SDGs in the 2021-2027 programmes
Programme Sustainable Development Goal Total
Horizon SDG: 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16,
17
17
Euratom / 0
ITER SDG: 7, 8, 9, 13, 17 5
InvestEU SDG: 1, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15 14
CEF SDG: 7, 9, 11, 13 4
Digital Europe SDG: 3, 4, 8, 9, 13, 16 6
Single market SDG: 7, 8, 9, 11, 12, 13, 16 7
Anti-fraud SDG: 10, 16 2
90
https://circabc.europa.eu/ui/group/3f466d71-92a7-49eb-9c63-6cb0fadf29dc/library/b29ffe93-f385-4f9b-b6b7-
4695a1266edd/details?download=true
91
European Commission, Biodiversity financing and tracking, Biodiversity financing and tracking - Publications
Office of the EU
92
European Parliament and Council, Interinstitutional Agreement on Budgetary Matters, 2021.
93
European Commission, Analysis of SDG Mainstreaming in EU Programmes, 2022.
94
European Commission, Annual Report on SDG Contributions, 2023.
118
Fiscalis SDG: 8, 9 2
Customs SDG: 8, 9 2
EU Space SDG: 2, 3, 5, 6, 7, 9, 11, 13, 14, 15, 17 11
Secure
Connectivity
SDG: 5, 9 2
Regional policy SDG: 1, 3, 4, 5, 6, 7, 8, 9, 11, 12, 13, 15 12
TCC SDG: 2, 3, 4, 5, 6, 7, 8, 9, 11, 12, 14, 15, 16 13
RRF SDG: 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16 16
TSI SDG: 1, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 15, 16 14
Pericles IV SDG: 8, 9 2
UCPM SDG: 3, 6, 11, 13, 14, 15 6
EU4Health SDG: 3 1
ESI SDG: 3 1
ESF+ SDG: 1, 2, 3, 4, 5, 7, 8, 10, 11, 12, 13 11
Erasmus SDG: 3, 4, 5, 8, 11, 12, 13, 16 8
ESC SDG: 3, 4, 5, 8, 10, 11, 13 7
Justice SDG: 3, 5, 10, 16 4
CERV SDG: 4, 5, 8, 10, 16, 17 6
Creative SDG: 3, 4, 5, 8, 10, 11, 12, 16, 17 9
Communication SDG: 2, 3, 4, 5, 6, 7, 8, 9, 11, 13, 14, 15, 16 13
CAP SDG: 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 12, 13, 15, 17 14
EMFAF SDG: 1, 2, 3, 5, 14 5
Fisheries SDG: 14 1
Life SDG: 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16 16
119
JTM SDG: 1, 3, 4, 5, 7, 8, 9, 10, 11, 12, 13, 15 12
AMIF SDG: 3, 4, 10, 15, 16 5
IBMF SDG: 10 1
ISF SDG: 16 1
ND LT SDG: 12 1
NSD SDG: 12 1
EDF SDG: 7, 8, 9 3
ASAP SDG: 9 1
EDIRPA / 0
NDICI Global
Europe
SDG: 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16,
17
17
INSC SDG: 5, 11, 16 3
HUMA SDG: 1, 2, 3, 4, 5, 6, 13, 17 8
CFSP SDG: 5, 16 2
OCT SDG: 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16,
17
17
MFA / 0
IPA III SDG: 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 15, 16, 17 14
Western Balkans
Facility
/ 0
Ukraine Facility / 0
EGF SDG: 4, 5, 8, 10 4
EUSF SDG: 3, 10, 13 3
IF SDG: 7, 9, 13 3
BAR / 0
120
Modernisation
Fund
/ 0
SCF / 0
Digital expenditure tracking remains ad-hoc and inconsistent. Unlike climate and biodiversity,
digital tracking does not have a standardised framework and primarily relies on Reporting from
the Recovery and Resilience Facility (RRF).95
This fragmentation complicates efforts to track
progress comprehensively across the EU's policy priorities and budget.
Lastly, at present, the European Commission is not equipped to effectively track other
horizontal priorities like digitalisation, competitiveness, or security. This is a significant gap,
as these areas are increasingly crucial in shaping policies that drive economic growth, enhance
regional stability, and ensure the EU’s adaptability to global challenges. Tracking these
priorities would provide valuable insights into financial allocations and their impacts, guiding
strategic investments and policy adjustments. The absence of such tracking mechanisms limits
the EU's ability to align its financial strategies with broader socio-economic goals effectively.
Figure: Possible functioning of single methodology to track expenditures through
intervention fields, and common set of indicators in the post-2027 programmes
95
European Commission, Ad-hoc Digital Spending Reports, 2023.
121
Figure: Example of intervention fields, policy priorities and indicators under the single
methodology in the post-2027 programmes
Figure: Monitoring provisions per management mode in the post-2027 programmes
122
7.1.2. Gender equality tracking
The Interinstitutional Agreement for the 2021-2027 Multiannual Financial Framework (MFF)
required the Commission to develop a methodology to measure the relevant EU budget
expenditure supporting gender equality. However, the agreement did not set out any spending
targets for gender equality, contrary to other priorities (climate and environment). The
Commission developed this methodology in the context of the Draft Budget 2023 in 2022 and
it has implemented it since. It is based on assigning the following gender scores to budget
interventions.
EU budget methodology to estimate expenditure contributing to gender equality:
Gender score 2:
Interventions whose principal objective is to
improve gender equality;
Gender score 1:
Interventions that have gender equality as an
important and deliberate objective but not as
the main reason for the intervention;
Gender score 0:
Non-targeted interventions (interventions
that are expected to have no significant
bearing on gender equality);
Gender score 0*:
Interventions with potential gender impact,
but for which there is insufficient data
available
Since its implementation in 2022, the gender tracking methodology has enhanced transparency
by identifying budget contributions to gender equality (scores 1 and 2) across EU programmes.
This has also led to a significant decline in score 0* from 95% to 20% in 2023, reflecting
improved implementation and data availability. Additionally, interventions under scores 1 and
2 have increased substantially, with score 1 quadrupling and score 2 tripling since 2021.
Nevertheless, the introduction of the new gender tracking methodology in 2022, after the
adoption of the 2021–2027 programmes basic acts, has led to inconsistencies and difficulties
in aligning data, tracking and monitoring with a coherent set of gender equality objectives. This
is largely due to the timing and design misalignment. When the methodology was introduced,
the basic acts for many programmes had already been finalized, leaving little room to
incorporate gender considerations into their structure. As a result, many programmes were not
designed with the tracking methodology's requirements in mind, leading to fragmented
approaches across different programmes.
This delay and misalignment created a lack of cohesion in the EU's approach to gender
expenditures monitoring. Various programmes adopted different tracking methodologies, such
as the Common Provisions Regulation tracking methodology, the Recovery and Resilience
Facility flagging methodology, and the Common Foreign and Security Policy marker system.
These divergent methodologies make it challenging to implement a consistent tracking system
across the entire EU budget, further complicating the evaluation of how funds contribute to
gender equality.
Consequently, a significant portion of the EU budget – 69% – is assessed as not contributing
to gender equality (score 0). This indicates that the potential for the EU budget to support
123
gender equality remains underutilized. Moreover, 20% of the budget is classified as score 0*,
representing measures with the potential for significant impact on gender equality, but where
the actual impact remains unclear. Notably, a large part of this score 0* budget corresponds to
the Common Agricultural Policy, which began implementation under its new regulation in
2023.96
Another critical issue is the lack of gender-disaggregated data. Many EU budget programmes
do not collect or report data broken down by gender, making it challenging to evaluate the real
impact of gender-related investments. This is particularly the case for programmes under
shared and indirect management, where the availability of gender-disaggregated data is not
necessarily foreseen by programme regulations and implementation agreements. Without such
data, it is difficult to measure contributions to gender-equality, assess the effectiveness of
programmes, and make informed decisions about future funding. This lack of clarity hampers
the EU's ability to ensure that its budget actively contributes to advancing gender equality and
adds to the significant challenges in implementing a coherent gender mainstreaming and
tracking approach. The absence of such data in the current EU budget has resulted in a
significant data gap on gender equality. However, the financial regulation – Article 33.3 – now
mandates the collection of gender-disaggregated data, aiming to address this gap and improve
the evaluation and impact of gender-related initiatives moving forward.
The Financial Regulation – Article 33 – explicitly mandates that EU budget programmes be
implemented, where feasible and appropriate, taking into account the principle of gender
equality and in accordance with an appropriate gender mainstreaming methodology.
Gender equality tracking under the post-2027 programmes
A single, harmonised gender equality tracking methodology could be established, building
upon the existing Commission gender tracking system. Integrating this methodology into a
horizontal framework would ensure that programmes incorporate gender equality requirements
and scoring system from the design stage.
A standardised gender tracking methodology would offer significant advantages, particularly
in enhancing coherence and reducing administrative burdens for beneficiaries, Member States
and EU institutions. A single methodology – based on the existing Commission system and
aligned with the OECD framework – would create a harmonised approach, ensuring consistent
assessment across all programmes. Such harmonisation would improve data comparability and
facilitate more accurate evaluations, leading to stronger evidence-based decision-making. A
single methodology would also replace multiple programme-specific tracking methods,
streamlining monitoring and reporting processes.
Applying the revised methodology across MFF programmes would also guarantee that gender
tracking considerations are integrated from the outset. This proactive approach addresses a
fundamental weakness of the current system, where gender tracking is often applied
inconsistently or only retrospectively. A single methodology could also help clarify the
treatment of complex elements, such as tracking zero-cost reforms, which are currently
insufficiently analysed.
Under the single methodology, the tracking of expenditure promoting gender equality in the
next MFF would be carried out using the system of gender scores, also making a connection to
96
Annual Management and Performance Report for the EU budget – Annex I – 3. Horizontal policy priorities in
the EU
124
intervention fields for tracking expenditures. Unlike other areas such as climate and
biodiversity, the promotion of gender equality could be done throughout most interventions
(e.g. digital trainings could encourage female participation, or grant funding could require
enterprises to have a gender equality plan in place). Therefore, the list of intervention fields
could include fields for gender score 2 actions specifically i.e. interventions for which gender
equality would be the main objective.
Other EU budget interventions – tagged through a dedicated intervention field - would be
tagged with a gender score of 0, 1 or 2 based on their specific design. The relevance of working
with all intervention fields to identify categories expected to be relevant for gender equality
due to their direct impact on persons (score 1) or with potential to support gender equality
objectives if implemented in a way that is responsive to gender equality objectives should be
explored. This may also be useful for intervention fields non relevant for gender equality (score
0), i.e. the possibility to pre-determine some intervention fields as non-relevant for gender
equality should also be considered.
In summary, adopting a unified gender tracking methodology aligned with the OECD
framework would resolve the inconsistencies, inefficiencies, and complexities that hinder the
current system. This transition provides an opportunity to enhance coherence, improve
programme design and implementation, and reduce administrative burden, thereby advancing
the EU’s commitment to gender equality in a more effective and transparent manner.
Under direct management programmes, the Commission would apply the gender tracking
methodology to the EU budget programmes and interventions fields.
Under shared management programmes, national authorities would assign a gender score to
interventions – a practice in place already in the Common Provisions Regulation funds in the
2021-2027 period. For instance, the categorisation of the gender equality dimension occurs at
the level of a specific objective within a programme, reflecting a targeted approach to ensuring
that gender considerations are adequately addressed. Even in cases where an entire programme
may not appear to contribute directly to gender equality, Member States managing authorities
are responsible for identifying and highlighting actions or smaller sections of the programme
specifically aimed at advancing gender equality. Financial data on the cost of selected
operations and declared expenditure is reported to the Commission five times per year. This
reporting is organised by categorisation dimension, meaning that each submission updates the
amounts associated with gender-targeted or gender-mainstreaming actions within cohesion
policy programmes. The Commission then reviews this data, enabling regular monitoring of
the financial commitment to gender equality and supporting evidence-based adjustments to
enhance the integration of gender perspectives across EU-funded programmes. Additionally,
for each score, a brief narrative explanation should be provided, particularly for measures
categorized as score 0 (not gender relevant), to ensure that these measures do not inadvertently
harm gender equality.
Under indirect management, agreements with implementing partners would include specific
provisions for applying the methodology. This would include requirements for assessing and
tagging gender-relevant measures and conducting impact assessments. The Commission would
oversee and verify that implementing partners adhere to the gender analysis requirements and
reporting standards.
Finally, the recast Financial Regulation now requires the collection of gender-disaggregated
data, where appropriate. Gender-disaggregated indicators would allow for systematic tracking
of how resources are allocated and the differential impacts on women and men. Incorporating
125
gender-disaggregated data into performance frameworks would enable to enhance
transparency, enable more accurate assessments of gender-related investments, and inform
evidence-based decision-making. Ensuring that indicators are disaggregated by gender would
strengthen the EU’s capacity to measure progress and adjust strategies to meet gender equality
objectives effectively.
One of the policy options that is sometimes recommended is to introduce a negative score to
track expenditures contributing negatively to gender equality i.e. harming gender equality. The
Commission’s gender tracking methodology is inspired by the OECD approach, which does
not incorporate negative scoring. Maintaining alignment with the OECD is crucial for ensuring
consistency with internationally recognized standards. Introducing negative scores would
create a divergence from this established framework, undermining the comparability of gender
equality efforts at the international level and potentially leading to confusion within EU
institutions and among member states. inconsistency could complicate both the tracking and
reporting processes, making it more challenging to evaluate progress in a way that aligns with
global benchmarks. Introducing negative scoring could have unintended negative
consequences. It may discourage innovation by making programme designers hesitant to
explore new or unconventional approaches for fear of being penalized for unforeseen gender-
related outcomes. Gender equality impacts are often complex and context-dependent, and
applying negative scores risks oversimplifying these dynamics. This could lead to
misrepresentations of how programmes interact with gender equality objectives, ultimately
undermining the nuanced understanding necessary for effective policy making. The emphasis
should instead be on enhancing positive contributions to gender equality rather than on
penalization. A constructive approach that focuses on identifying and amplifying programmes
that contribute positively to gender equality will foster a more supportive and forward-looking
policy environment. Programmes can be subjected to continuous monitoring and periodic
reviews to ensure they remain aligned with gender equality goals. If any issues arise,
adjustments can be made based on these reviews, promoting an adaptive and flexible
framework that encourages improvement without resorting to punitive measures. Finally, from
a legal and policy coherence perspective, the introduction of negative scoring is unnecessary.
The EU already has robust gender equality frameworks and legal commitments in place, and
the current methodologies, combined with the emphasis on gender relevance in programme
design, are fully aligned with these commitments. Adding negative scoring mechanisms could
create unnecessary complexity and legal ambiguities, potentially leading to overlaps or
conflicts with other evaluation tools and reporting mechanisms. This could dilute the
effectiveness of existing strategies aimed at promoting gender equality. In conclusion,
maintaining methodological consistency with the OECD, recognizing the inherent gender
relevance in EU budget programmes, and avoiding the potential risks associated with negative
scoring all point to the conclusion that such a mechanism is neither necessary nor beneficial.
The focus should remain on fostering positive contributions to gender equality through
proactive design and continuous improvement rather than through punitive tracking measures.
Adopting a single and harmonised gender expenditure tracking framework would help address
the inefficiencies and complexities inherent in the current fragmented system, which relies on
a complex patchwork of tracking mechanisms. A unified framework would enable:
1. Simplification and streamlining: By eliminating multiple programme-specific tracking
systems, a single methodology would simplify monitoring requirements, reduce
administrative burdens, and promote efficiency.
126
2. Improved coherence and consistency: A harmonised framework, aligned with the
OECD standards, would ensure uniform application of tracking methodologies across
all EU programmes. This coherence would enhance data comparability, support more
accurate progress evaluation, and enable evidence-based decision-making.
3. Proactive integration into programme design: Embedding the unified tracking
framework in a single framework upfront would ensure that gender expenditure
tracking considerations are incorporated during programme design rather than
retroactively. This integration would address inconsistencies and improve the overall
impact assessment.
The adoption of such a harmonised gender expenditure tracking framework will be essential
for simplifying and streamlining monitoring requirements across the EU budget. It represents
a critical step towards achieving greater transparency, efficiency, and alignment with the EU’s
strategic priorities, thereby ensuring a more effective allocation of resources and advancing
overarching policy goals.
127
7.2 Indicators supporting the monitoring of performance of the EU budget
Performance indicators are defined in programme regulations, in dedicated basic acts,
delegated acts as well as in other documents such as staff working documents, work
programmes and agreements with implementing partners. As a result, around 1 200 core
performance indicators have been introduced, out of which 76 are used to report on the
Cohesion Fund, ERDF, EAGF and EAFRD i.e. two thirds of the MFF, with the other ca. 1 100
indicators being used in the context of programmes corresponding to the other third of the MFF
and the RRF. In addition, information is being collected based on ca. 7 000 indicators
corresponding to milestones and targets under the RRF.
The sheer abundance of information and reporting documents continues to create an overload
of data, leading to confusion, potentially inconsistent reporting, and a high administrative
burden at all levels: beneficiaries, Member States, implementing partners, and the European
Institutions’ services, who must collect, compile and review the data and various reports. This
situation, already described and criticised by the European Court of Auditors97
, the European
Parliament Research Service98
and the OECD99
in the period 2014-2020, has been improved in
the 2021-2027 period but not fully addressed. It remains a source of questions from
beneficiaries, Member States and project beneficiaries, who point out that both the information
they are required to provide at the stage of calls for proposals as well as at the stage of reporting
causes administrative burden to the point that puts the relevance of participating in such calls
to question100
. A study on administrative costs and burden linked to ESIF funds estimates that
gathering information on the progress and results of the project (including financial information
and indicator data) and submission of that information to the authorities (monitoring and
reporting) is the most burdensome requirement for Member States and beneficiaries101
.
Some indicators are specifically used in the context of direct performance-based budgeting –
such as under the RRF, where payments are triggered by fulfilling milestones and targets, or
under the CAP, where result indicators are used to establish targets that, if unmet, may lead to
payment suspensions or deductions. These indicators play a direct role in EU budget
implementation by guiding disbursement decisions. However, programmes using indicators for
this purpose are an exception, as the vast majority of indicators are used for information
gathering and monitoring purposes. Their number raises questions about the relevance and
added value of several indicators, while the management of such indicators data sets generates
significant administrative burden for EU institutions, Member States and MFF beneficiaries.
The information thus collected is not always aggregable. This is because indicators were
defined separately per programme. As a consequence, a number of MFF programmes,
including those that pursue the same or similar policy objectives, use similar yet slightly
different indicators to report on sometimes very similar outputs (e.g. measuring numbers of
dwellings, buildings or houses, or measuring high-speed connectivity or 5G). This fragmented
97
https://www.eca.europa.eu/Lists/ECADocuments/annualreports-2017/annualreports-2017-EN.pdf
98
Sapała, M. Briefing European Parliamentary Research Service. Performance budgeting – A means to improve
EU spending, March 2018
99
Downes, R., D. Moretti and S. Nicol (2017), "Budgeting and performance in the European Union: A review by
the OECD in the context of EU budget focused on results", OECD Journal on Budgeting, vol. 17/1
100
InvestEU and RRF midterm evaluations, among others.
101
https://ec.europa.eu/regional_policy/information-sources/publications/studies/2018/new-assessment-of-esif-
administrative-costs-and-burden_en
128
and heterogeneous approach leads to a proliferation of heterogenous and non-aggregable
indicators, which reduces possibilities to measure EU budget impact as a whole and to inform
policies. At the same time, in many cases, there are no indicators that could be used to measure
the progress towards the core aim of the activity.
In addition to this, impact indicators or even result indicators are not designed in a manner that
would facilitate the measurement of long-term outcomes of programmes beyond their
expiration. Visibility of programmes performance after their expiration could potentially be
improved, particularly for measures funded across the duration of an MFF, such as large-scale
infrastructure investments under CEF.
Finally, the balance between output, result and impact indicators remains suboptimal despite
having improved compared to previous programming periods. All three levels are essential for
a comprehensive assessment of programme performance: output indicators provide insight into
what the programme directly finances and its immediate activities (e.g. construction of an
electrified railway); result indicators track the immediate effects of these outputs (shift from
reliance on fossil fuels to the use of electricity as an energy source.); impact indicators measure
the ultimate objectives of the intervention (greenhouse gas emissions avoided). Achieving the
right balance among these indicators is crucial, yet this alignment has not been fully realised.
129
Table 8: Reporting of indicators in the 2021-2027 MFF programmes
Programme
Legal set up
Status
Core
perfor
mance
indicat
ors
defined
in legal
basis
Core
perfor
mance
indicat
ors
NOT
defined
in legal
basis
M&E
indicat
ors
defined
in legal
basis
Indicat
ors
defined
in
Delegat
ed Acts
M&E
indicat
ors
used,
includi
ng
those
not
defined
in the
legal
basis
Total
numbe
r of
indicat
ors102
AMIF Article 33; no delegated act was adopted;
indicators do not impact payments
Qualitative and quantitative
indicators to report on the progress
of the Fund towards the
achievement of the specific
objectives. Indicators are used for
the midterm evaluation. Used by
Member states for their annual
performance report.
15 41 41
102
Total = number of core performance indicators defined in legal basis OR number of M&E indicators defined in legal basis (when data is in the table because M&E indicators
include core performance indicators) + number of indicators defined in Delegated Acts + number of M&E indicators used, including those not defined in the legal basis
130
Anti-Fraud Article 12; no delegated act was adopted;
indicators do not impact payments
Qualitative and quantitative
indicators to report on the progress
of the programme towards the
achievement of the general and
specific objectives. Mixed of
results and output indicators.
4 4
ASAP No indicators in the legal basis; no delegated
act was adopted; indicators do not impact
payments
0
BMVI Article 27; no delegated act was adopted;
indicators do not impact payments
Qualitative and quantitative
indicators to report on the progress
of the Fund towards the
achievement of the specific
objectives. Indicators are used for
the midterm evaluation. Used by
Member States for their annual
performance report.
14 40 40
Brexit Reserve No indicators in the legal basis; no delegated
act was adopted; indicators do not impact
payments
Output indicators to measure
performance will become
available through the
reports of Member States.
0
CAP 2021/2115: Article 7, 142
2021/2116: Article 42; a delegated act was
adopted; indicators impact payments
- Output indicators for monitoring
- Result indicators for milestones
and targets in CAP strategic plans
- Context indicators to assess the
baseline situation for preparation
of the CAP strategic plans
29 149 11
(conte
xt
indicat
ors on
comm
160
131
- Impact indicators for evaluations
- Not achieving the targets may
result in reduction of payments to
MS (Article 41(2) of 2021/2116)
odities
)
CCEI Article 12; a delegated act was adopted;
indicators do not impact payments
Qualitative and quantitative
indicators to report on the progress
of the instrument towards the
achievement of the general and
specific objectives
5 11 16
CEF Article 22; no delegated act was adopted;
indicators do not impact payments
- Quantitative indicator to report
on the progress of the CEF
towards the achievement of the
general and specific objectives.
- Mainly output indicators
(number of actions).
-Indicators are divided in 3 fields:
energy, transport and digital.
16 51 67
Citizens,
Equality, Rights
and Values
Article 16 ; no delegated act was adopted;
indicators do not impact payments
Quantitative indicators to report
on the progress of the Programme
towards the achievement of the
general and specific objectives.
Mixed of results and output
17 17
Civil Protection Article 3; no delegated act was adopted;
indicators do not impact payments
Quantitative indicators used for
monitoring, evaluating and
reviewing as appropriate the
application of this Decision
4 20 24
132
Cohesion
(ERDF and
Cohesion Fund)
Article 8; no delegated act was adopted;
indicators do not impact payments
Indicators used by Member states
to report on the progress of the
ERDF and CF. Programme-
specific indicators can be added.
The core set of indicators should
be the basis on which the
Commission should report on the
progress towards the achievement
of specific objectives.
47 161 161
Creative Europe Article 20; no delegated act was adopted;
indicators do not impact payments
Report on the progress of the
Programme towards the
achievement of the objectives
22 22
Customs Article 13; a delegated act was adopted;
indicators do not impact payments
Mainly qualitative indicators to
report on the progress of the
Programme towards the
achievement of the general and
specific objectives. Rely on index
(gathering of different indicators).
In DA, more quantitative
indicators
15 28 43
Decision on the
Overseas
Association,
including
Greenland
Recital 42; no delegated act was adopted;
indicators do not impact payments
Indicators for the evaluation 4 4
Digital Europe
Programme
Article 25; no delegated act was adopted;
indicators do not impact payments
Qualitative and quantitative
indicators to monitor the
14 298 312
133
implementation and to report on
the progress of the Programme
towards the achievement of the
specific objectives.
10 indicators - not foreseen by the
legal basis - are for mid-term and
ex post evaluation, mainly
quantitative; 12 contextual
indicators in the framework of the
Digital Decade Policy
Programme; 276 topic level
indicators to monitor performance
on a specific topic to capture
technical details, or where
individual topics are not directly
covered by higher level indicators
EDF Article 28; no delegated act was adopted;
indicators do not impact payments
Qualitative and quantitative
indicators to report on the progress
of the Fund towards the
achievement of the specific
objectives
10 10
EFSD+ Article 41; a delegated act was adopted;
indicators do not impact payments
Indicators will be the framework
for carrying out the monitoring
and reporting tasks (output,
outcome and impact indicators)
19 283 302
EGF Article 19; no delegated act was adopted;
indicators do not impact payments
Qualitative and quantitative
indicators to report on the progress
13 13
134
of the EGF towards the
achievement of the objectives.
They are also used for the purpose
of the final report and biennial
report.
Emergency
Support
Instrument
No indicators in the legal basis; no delegated
act was adopted; indicators do not impact
payments
0
EMFAF Article 46; no delegated act was adopted;
indicators do not impact payments.
Additionally, the Managing authority shall
provide the Commission with operation-
level implementation data defined in an
implementing act.
- For reporting, no impact on
payments.
- 22 common result indicators and
1 output indicator. There are 12
core performance indicators
(some overlap with common result
indicators) to be used by the
Commission in compliance with
its reporting requirement pursuant
to paragraph (iii) of point (h) of
Article 41(3) of the Financial
Regulation. -A total of 27 unique
indicators defined in the
regulation
- Operation level data to be
reported are further defined in a
CIR.
12 27 27
135
Erasmus+ Article 23; a delegated act was adopted;
indicators do not impact payments
Qualitative and quantitative
indicators to report on the progress
of the Programme towards the
achievement of the general and
specific objectives. Mixed of
results and output indicators
15 12 27
ERDIPA No indicators in the legal basis; no delegated
act was adopted; indicators do not impact
payments
0
ESF+ Article 17 - For general support from the
ESF+ strand (shared)
Article 23 - For Priorities addressing
material deprivation (shared)
Article 32 - For EaSi strand (direct)
No delegated act was adopted; indicators do
not impact payments
Qualitative and quantitative
indicators to monitor progress in
implementation (for Member
States). Also use to assess
milestones and target (article
17.3). For EaSi strand, to report on
the progress of the EaSI strand
towards the achievement of the
specific objectives. Progress in
achieving the milestones is taken
into account in the mid-term
review (CRR Art. 18(1).
76103
3934
104
4010
EU Secure
Connectivity
Article 41; no delegated act was adopted;
indicators do not impact payments
Qualitative and quantitative
indicators to monitor the
implementation and to report on
39 39
103
indicators on persons are broken down by gender and all indicators are broken down by category of regions
104
programme specific indicators (1890 output indicators and 2044 result indicators)
136
the progress of the Programme
towards the achievement of the
specific objectives
EU Solidarity
Fund
No indicators in the legal basis; no delegated
act was adopted; indicators do not impact
payments
2 2
EU Space Article 101; no delegated act was adopted;
indicators do not impact payments
Qualitative and quantitative
indicators to monitor the
implementation and to report on
the progress of the Programme
towards the achievement of the
specific objectives and for
multiannual plan.
36 36
EU4Health Article 19; no delegated act was adopted;
indicators do not impact payments
quantitative indicators to monitor
the implementation and to report
on the progress of the Programme
towards the achievement of the
specific objectives.
Several purpose: Core
performance to monitor
Programme’s annual performance
and progress towards its
objectives.
Key performance indicators serve
as a reference for the annual
performance reporting
action-level indicators that are
23 42 65
137
available to monitor the outputs
and results of each action funded.
Other indicators for the
EU4Health dashboard
Euratom Article 12; no delegated act was adopted;
indicators do not impact payments
Qualitative and quantitative
indicators to report on an annual
basis on the progress of the
Euratom Programme towards the
achievement of the objectives
34 34
European
Instrument for
International
Nuclear Safety
Cooperation
Article 14; no delegated act was adopted;
indicators do not impact payments
Indicators to measure
achievements of the objective of
the Instrument. Indicators are
included in Multiannual indicative
programmes.
3 3
European
Solidarity Corps
Article 20; a delegated act was adopted;
indicators do not impact payments
Qualitative and quantitative
indicators to report on the progress
of the Programme towards the
achievement of the general and
specific objectives. Mixed of
results, output and impact
indicators
14 5 19
Financial
Statement for
Macro Financial
Assistance
No indicators in the legal basis; no delegated
act was adopted; indicators do not impact
payments
0
138
Fiscalis Article 14; a delegated act was adopted;
indicators do not impact payments
Mainly qualitative indicators to
report on the progress of the
Programme towards the
achievement of the general and
specific objectives. Rely on index
(gathering of different indicators).
In DA, more quantitative
indicators
16 24 40
Fisheries
agreements
No specific performance indicators are
defined in the SFPAs; indicators do not
impact payments
- The progress of the programmes
is followed on the basis of
quantifiable indicators for
periodic monitoring
5 5
Horizon Europe Article 50; no delegated act was adopted;
indicators do not impact payments
Qualitative and quantitative
indicators to report on an annual
basis on the progress of the
Programme towards achievement
of the objectives, within the
framework of a database.
Additional indicators can be used
to monitor individual Programme
parts
30 151 181
Humanitarian
Aid Programme
No indicators in the legal basis; no delegated
act was adopted; indicators do not impact
payments
20 20
Innovation Fund No delegated act was adopted; indicators do
not impact payments
14 14
139
InvestEU Article 28; a delegated act was adopted;
indicators do not impact payments
Output, outcome and impact
indicators. No impact on payment.
M&E framework to be established
to track progress towards the
Union's objectives.
36 200 236
IPA III Article 13; no delegated act was adopted;
indicators impact payments
Qualitative and quantitative
indicators for monitoring the
implementation and progress of
IPA III towards the achievement
of the specific objectives. The
annual assessment of the
implementation of the IPA should
be done based on indicators.
Indicators are included in IPA
programming framework. Where
the relevant indicators show a
significant regression or persistent
lack of progress by a beneficiary
the scope and intensity of
assistance should be modulated
accordingly (Article 8).
The result framework is used for
the annual Commission
communication on the Union’s
enlargement policy and the
Commission’s assessments of the
economic reform programmes.
18 122 140
140
ISF Article 27; no delegated act was adopted;
indicators do not impact payments
Qualitative and quantitative
indicators to report on the progress
of the Fund towards the
achievement of the specific
objectives. Indicators are used for
the midterm evaluation. Used by
Member states for their annual
performance report.
15 33 33
ITER No indicators in the legal basis; no delegated
act was adopted; indicators do not impact
payments
2 2
JTF 2021/1056: Article 12
2021/1229: Article 16; no delegated act was
adopted; indicators impact payments
Qualitative and quantitative
indicators are used for the final
performance report, the
Commission may make financial
corrections where less than 65 %
of the target set out for one or
more output indicators is
achieved.
Programme-specific indicators for
territorial just transition fund
For loan facility, including output
indicators is an eligibility criterion
(Article 9 2021/1229). There are
also indicators to monitor the
implementation of the Facility and
101 101
141
its progress towards the
achievement of the objectives
Justice Article 13; no delegated act was adopted;
indicators do not impact payments
Qualitative and quantitative
indicators to report on the progress
of the Programme towards the
achievement of the general and
specific objectives. Mixed of
results and output indicators
12 12
LIFE Article 19; no delegated act was adopted;
indicators do not impact payments
Qualitative and quantitative
indicators to report on the progress
of the Programme towards the
achievement of the general and
specific objectives and specific
project level indicators to be
described in multiannual work
programmes or calls for proposals
for tracking requirement (the latter
with a focus on Natura 2000 and
the emissions of certain
atmospheric air pollutants). Also
use for mid-term evaluation.
19 13 32
NDICI Global
Europe
Article 41; no delegated act was adopted;
indicators impact payments
Qualitative and quantitative
indicators to report on progress of
the Instrument towards the
achievement of the specific
objectives. They should be in line
with SDGs. Indicators are used to
19 1836 1855
142
assess progress within the
framework of the annual report
and present it. Indicators are used
for the final evaluation. Indicators
are included in programming
documents which shall be results-
based and should be linked to
targets. Indicators are also
included in Multiannual indicative
programmes. Disbursement of the
budget support shall be based on
indicators demonstrating
satisfactory progress being made
towards achieving the objectives
agreed with the partner country.
Nuclear
Decommissioni
ng
Article 10; no delegated act was adopted;
indicators do not impact payments
Qualitative and quantitative
indicators to report on the progress
of the Programme towards the
achievement of the objectives.
Should be defined in the
multiannual work programme and
be related to objectives laid down
in this work programme.
2 2
Nuclear
Decommissioni
ng (Lithuania)
Article 10; no delegated act was adopted;
indicators do not impact payments
Qualitative and quantitative
indicators to report on the progress
of the Programme towards the
achievement of the objectives.
Should be defined in the
2 2
143
multiannual work programme and
be related to objectives laid down
in this work programme.
Pericles Article 12; no delegated act was adopted;
indicators do not impact payments
Qualitative and quantitative
indicators to monitor the
implementation and to report on
the progress of the Programme
towards the achievement of the
specific objectives. Used also for
the evaluation (final and mid-
term)
5 5
Reform and
growth facility
for the Western
Balkans
Article 13; no delegated act was adopted;
indicators do not impact payments
The Reform Agendas should be
results-based and include
indicators for assessing progress
towards the achievement of
general and specific objectives of
the Facility. The indicators shall
be expected to contribute to the
Commission’s monitoring of the
Facility. The Reform Agendas set
out the reforms to be implemented
by the beneficiary concerned, the
investment areas to be supported
and the payment conditions. shall
only be used by the Commission
to assess the progress towards the
achievement of the general and
13 610 623
144
specific objectives, not payment
conditions
RRF Article 19; a delegated act was adopted;
indicators impact payments
Indicators used by Member States
to report in the framework of the
European Semester, and to report
to the Commission. They are also
used for the Recovery and
Resilience Scoreboard, and the
annual report of the RRF made by
the Commission.
14 7129 7143
Single market Article 17; a delegated act was adopted;
indicators do not impact payments
Qualitative and quantitative
indicators to monitor the
implementation and to report on
the progress of the Programme
towards the achievement of the
specific objectives. Mix of output
and results indicators
16 53 69
Social Climate
Fund
Article 24; no delegated act was adopted;
indicators impact payments
Qualitative and quantitative
indicators for reporting on the
progress and for the purpose of
monitoring and evaluation of the
Fund towards the achievement of
the objectives. Indicators are used
in the framework of the Social
Climate Plans (additional
indicators can be set by plans).
Article 20: Where the milestones
39 39
145
and targets have not been
satisfactorily achieved the
Commission shall reduce the
amount of the financial allocation
proportionately. It should be
possible for the Member States to
use relevant common indicators to
set out the milestones and targets
in their Plans.
TSI Article 14; no delegated act was adopted;
indicators do not impact payments
Quantitative indicators to monitor
the implementation and to report
on the progress of the Programme
towards the achievement of the
specific objectives.
5 5
Turkish Cypriot No indicators in the legal basis; no delegated
act was adopted; indicators do not impact
payments
5 5
Ukraine Facility Article 17; no delegated act was adopted;
indicators impact payments
The Ukraine Plan shall include
indicators for assessing progress
towards the achievement of the
general and specific objectives.
The assessment of the Ukraine
Plan determine the reforms and
investments to be implemented by
Ukraine, the conditions laid down
in the Ukraine Plan, the total and
annual maximum amounts for
0 150 150
146
non-repayable financial support
and the total and annual indicative
maximum amounts of the loan
support, the instalments...
the indicators for assessing
progress towards the achievement
of the general and specific
objectives shall be defined in the
Council implementing decision
TOTAL 849 28 450 146 14870 16212
147
Proposed monitoring of performance indicators under the post-2027 programmes
Types of indicators Degree of standardisation
across EU budget
programmes
Indicators used to monitor the progress in the achievement
of objectives, including mainstreamed ones, where
relevant (Article 33(2)(b) of the Financial regulation
Standardised
No programme-specific
indicators
Indicators as referred to in Article 125(1)(a) of the
Financial regulation used when the form of the Union
contribution is not linked to the costs of the relevant
operations, and as referred to in Article 241 of the
Financial regulation in the context of budget support.
Standardised as a general rule,
with possibility to define ad
hoc indicators when necessary
Indicators referred to in Article 16 “Performance
framework” of the Common Provision regulation 2021-
2027 used by the Member States in the context of the
Cohesion funds and the Home funds, and indicators
referred to in Articles 7 and 142 of the CAP Strategic plan
regulation.
Standardised
No additional indicators
No Member State-specific
indicators
Indicators as referred to in Article 34 of the Financial
regulation used for evaluations
Standardised
No additional indicators
Indicators as referred to in Article 158(7) of the Financial
regulation used in the context of indirect management
Standardised
No additional indicators
Project or call level indicators (budgetary related) Standardised
No additional indicators
Thanks to standardisation at the EU budget level, the overall performance of the EU budget
could be effectively monitored. Programmes would not be allowed to create specific indicators
that cannot be aggregated with those of other programmes. For example, if two programmes
support digitalisation, they must use the same set of indicators – such as “additional dwellings
and enterprises with broadband access of very high capacity” – rather than varying definitions
like “additional households with broadband access of at least 30 megabits per second” or
“dwellings with access to very high-capacity internet networks, including 5G networks and
gigabit speeds” as done in the 2021-2027 period.
At the same time, this pre-defined list of indicators would be linked to intervention fields used
to track expenditures for all programmes. The indicators would be designed so that they would
capture specificities of interventions falling under any particular intervention field.
Intervention field Output indicators Result indicators
Renewable energy: solar m2
of solar panels installed
Peak capacity of solar panels
installed
Renewable energy produced
148
Support to the unemployed Number of participants
trained
Number of job search
services provided
Number of participants in
employment after taking part
Number of participants
reporting salary increase
after taking part
Examples for illustrative purpose only
Because of indicators being linked to the intervention field, any type of intervention, regardless
of the programme under which it would be implemented, would be monitored by one output
and one result indicator. For example, an intervention that involves support to employment
would always be monitored by a result indicator that measures how many participants were in
employment after taking part (and not for example how many participants were actively
looking for employment). This approach would allow to compare and aggregate similar
interventions across different programmes. For example, if a similar intervention would be
implemented under the Social Climate Fund, a programme supporting youth and a programme
supporting rural development, it would be possible to aggregate the data coming from the three
programmes and understand how much the EU budget as a whole is contributing towards
labour mobility.
The above approach will require designing indicators in a harmonised and coordinated manner,
based on the indicators that are already being used. The entire list of indicators and the way
they are linked to intervention fields would have to be agreed on simultaneously, before the
programmes’ implementation would begin. This would necessarily mean that the number of
indicators would be much limited than currently, since the same or similar indicators would be
defined as one single indicator that would be used across all programmes. Where appropriate,
the indicators would have to allow for the calculation of high-level impact indicators, such as
GHG emissions avoided. The indicators would be introduced at the beginning of programmes’
implementation and would apply to all relevant programmes.
As a general rule, harmonisation will be needed with regards to indicators for triggering
payments, for evaluation, or for monitoring implementing partners under indirect management,
nor at the call or project level. In principle, only the predefined list of indicators should be used
to minimise the administrative burden on final beneficiaries, implementing partners, and
Member States while ensuring a comprehensive overview of the EU budget’s activities and
impact across programmes.
However, the preferred policy option foresees a differentiated operationalization of indicators
per management mode. Such an option would allow for the use of tailored indicators, for
example in the case of shared management, where e.g. milestones and targets – tailored to
Member States specificities and needs – could be integrated into future plans. The single,
uniform set of indicators would therefore cater for payments triggered in ‘financing not linked
to costs’ schemes as well as evaluations, enabling streamlined monitoring of performance,
effective evaluation of programmes as well as management of programmes.
The list of intervention fields will be developed by identifying relevant policy areas and
relevant interventions supported by EU budget programmes. Corresponding output and result
indicators will be developed for each intervention field, building upon existing indicators,
selecting the most relevant ones, as well as coefficients enabling to track contributions to e.g.
climate mitigation, adaptation and environment.
149
The list of intervention fields relies upon a combination of activity-oriented and policy-oriented
intervention fields, along with varying levels of granularity, reflecting the complex nature of
the EU budget, varying degrees of information availability, differing levels of implementation
and programmable actions, as well as a differentiation between tracking coefficients for climate
mitigation, adaptation and environment. The tracking approach also builds upon the
intervention field approach developed in the context of the 2021-2027 Common Provisions
Regulation, ensuring that all intervention fields as they appear in the current CPR are covered
by the proposed list. In addition, data requirements as they are currently existing regarding type
of beneficiary have been included, though oftentimes only to a limited and targeted degree.
This deviates from a more in-depth data collection approach and has been incorporated in this
way to reduce data collection burdens. The tracking approach also relies upon the need for
coherence with the OECD DAC classification, used for reporting by external relations
programmes.
The Performance Regulation will set out dedicated rules regarding the monitoring of
performance across EU budget programmes. It will also include dedicated articles setting out
specific provisions for each management mode, providing for monitoring rules in Member
States and third countries plans, in calls under direct management as well as by implementing
partners under indirect management. The regulation will for example define that Member
States will be required to pick one output indicator from the common list to define milestones
and targets in their plans, as well as one result indicator to enable for additional performance
monitoring.
The new list of indicators aims at setting up a performance framework for the EU budget while
enabling to conduct programme monitoring and evaluation. By establishing a direct link
between intervention fields and indicators, the common list will provide more information than
currently on the link between ‘how much do we spend’ and ‘what do we achieve’, which will
be relevant in the context of programme monitoring and evaluation. The methodology for
developing indicators also focuses on ensuring that indicators are drafted to measure what we
actually achieve with EU investments, therefore ensuring a causal link between programmes
objectives and the new common set of indicators. Because all management modes and
programmes will use the same set of intervention fields and indicators, the new system will
enable to compare the effectiveness, efficiency and added value of programmes’ budget
interventions. The initiative focuses on monitoring outputs and results because of the lack of
availability of meaningful long-term impact indicators beyond outputs and results, though
some of the result indicators of the common list may also be seen as impact indicators (e.g.
GHG emissions avoided).
150
ANNEX 8: REPORTING FRAMEWORK OF THE 2021-2027 BUDGET
8.1 Reports on performance of the EU budget
The Commission is required to report annually on the performance of the EU budget in the
following context:
• Discharge procedure: Integrated Financial and Accountability Reporting (IFAR),
which includes the AMPR, and its annex ‘programme performance statements’;
• Draft Budget procedure: the Statement of Estimates includes EU budget
expenditure for horizontal priorities, and working document 1 includes (the same)
‘programme performance statements’;
• Strategic planning and programming cycle (SPP): which includes the Annual
Activity Reports, prepared by every single AoD, which describes each service
progress on their multiannual policy objectives. The Annual Activity Reports are
also a key part of the discharge procedure.
• Programme regulations: programme-specific requirements such as the RRF annual
report.
Figure: Performance reporting requirements under the 2021-2027 period
The Commission provides extensive reporting on the performance of the EU budget, primarily
through the programme performance statements. These statements are annexed to both the
Annual Management and Performance Report (discharge) and the Draft Budget, so as to ensure
alignment and minimise overlap between the two procedures. Despite this comprehensive
reporting, the Commission produces 33 additional annual reports on MFF programmes, which
are usually prescribed by the programme-specific regulation. The annual reports are usually a
very detailed presentation of facts and figures concerning implementation. In addition to this,
budgetary information is included in some other reports, such as the yearly General report.
The proliferation of reports results in overlapping content, as well as unsynchronised timelines
and cut-off dates. This high number of reports requires significant resources and increases the
risk of inconsistent narratives. These reports are used only to a limited degree as input in
151
preparing decisions on the management of programmes, with the exception of a few
programmes such as the RRF and the CAP.
152
Table 9: Reporting obligations in the 2021-2027 programmes
Programme Reporting
obligations in
regulations /
Article in the
regulation
Nature of the obligation and content of the report Other report from Commission
without legal obligations
Horizon
Europe
YES: Article
50
Nature:
The Commission shall monitor continuously the management and
implementation of the Programme. Data shall also be made publicly
available in an accessible manner on the Commission's website
according to the latest update.
Database should include:
- Data for projects funded
- time-bound indicators to report on an annual basis towards
achievement of the objectives
- information (such as the level of mainstreaming SSH, the ratio
between lower and higher TRLs in collaborative research, the progress
on the participation of widening countries, the geographical
composition of consortia in collaborative projects, the evolution of
researchers’ salaries, the use of a two-stage submission and evaluation
procedure, ...)
- the levels of expenditure disaggregated at project level, including per
intervention area;
- the level of oversubscription, in particular the number of proposals
and per call for proposals, their average score, the share of proposals
above and below quality thresholds.
Content:
153
Presenting an overview on evaluated proposals (incl. success rates)
and detailed statistics and data on funded projects and their
participants in EU R&I programmes, broken down by countries and
regions, research domain/programme part, organisation type, etc.
https://ec.europa.eu/info/funding-
tenders/opportunities/portal/screen/opportunities/horizon-dashboard
Euratom
Research and
Training
YES: Article
12
Nature:
The Commission shall monitor continuously the management and
implementation of the Euratom Programme.
Data shall be made publicly available in an accessible manner on the
Commission’s webpage in accordance with the latest update of those
data.
ITER NO
InvestEU YES: Article
28.3
Nature:
In accordance with Article 41(5) of the Financial Regulation, the
annual report shall provide information on the level of implementation
of the Programme with respect to its objectives and performance
indicators. Where the Union has granted a budgetary guarantee, the
Commission shall attach to the draft budget a working document
presenting for each budgetary guarantee and for the common
provisioning fund such as reference to the budgetary guarantee and its
basic act, the counterparts for the budgetary guarantee, the budgetary
guarantee’s contribution to the achievement of the objectives of the
budgetary guarantee as measured by the indicators established...
For that purpose, each implementing partner shall provide on an
annual basis the information necessary to allow the Commission to
Commission has developed a
dashboard.
https://investeu.europa.eu/investeu
-programme/investeu-
fund/investeu-indicators_en
154
comply with its reporting obligations, including information on the
operation of the EU guarantee.
Connecting
Europe
Facility
YES: Article
12
Nature:
Biennial report - The Commission shall also present progress reports
every two years.
Information on the implementation of the CEF, clarifying whether the
different sectors are on track, whether the total budgetary commitment
is in line with the total amount allocated, whether the on-going projects
are sufficiently complete, and whether it is still feasible and
appropriate to deliver them.
Digital
Europe
Programme
NO A DIGITAL Dashboard has been
developed:
https://dashboard.tech.ec.europa.eu/
qs_digit_dashboard_mt/public/exten
sions/CNECT_DIGITAL_dashboar
d/CNECT_DIGITAL_dashboard.ht
ml
Single
Market
Programme
NO
EU Anti-
Fraud
Programme
(Anti-Fraud)
YES: Article
12
Nature:
Annual report - The Commission shall report annually on the
performance of the Programme to the European Parliament and to the
Council in the framework of its Annual Report on the protection of the
Union’s financial interests – Fight against fraud.
Content:
Objectives, amount, projects, achievements
155
https://anti-fraud.ec.europa.eu/system/files/2023-07/pif-report-
2022_en_0.pdf
Cooperation
in the field of
taxation
(Fiscalis)
YES: Recital
16
Nature:
Annual progress reports should be issued to monitor the progress
made.
Those reports should include a summary of the lessons learnt and,
where appropriate, of the obstacles encountered, in the context of the
activities of the Programme that have taken place in the year in
question.
Content:
Implementation, projects description, lessons learnt, amount,
performance indicators
https://taxation-customs.ec.europa.eu/document/download/da84bf38-
a09f-4747-9c4d-
e784da690487_en?filename=SWD_2024_119_F1_STAFF_WORKI
NG_PAPER_EN_V2_P1_3386794.PDF
Cooperation
in the field of
customs
(Customs)
YES: Recital
20
Nature:
Annual progress reports should be issued to monitor the progress
made.
Those reports should include a summary of the lessons learnt and,
where appropriate, of the obstacles encountered, in the context of the
activities of the Programme that have taken place in the year in
question.
Content:
Implementation, projects description, lessons learnt, amount,
performance indicators
https://taxation-customs.ec.europa.eu/document/download/d98e2e28-
5ca8-40cc-982f-
156
c4da233f305a_en?filename=swd_2024_120_f1_staff_working_pape
r_en_v3_p1_3383195-1.pdf
European
Space
Programme
NO
EU Secure
Connectivity
Programme
NO
Regional
Policy Funds
(ERDF and
Cohesion)
NO High level report - Commission
published a Report on economic,
social and territorial cohesion. It
deals with the European Social Fund
(ESF+), the European Regional
Development Fund (ERDF) and the
Cohesion Fund (CF). It presents the
state-of-play of EU Cohesion
situation through economic
indicators in several fields (diversity,
green transition, digital transition,
innovation, governance...), explains
initiatives led by the EU, some
progress and achievements thanks to
EU support. One section deals with
Cohesion Policy's impacts, but
remains high level.
https://european-social-fund-
plus.ec.europa.eu/en/publications/ni
157
nth-report-economic-social-and-
territorial-cohesion
Support to
the Turkish
Cypriot
Community
(TCC)
YES: Article
10
Nature:
Annual report - The Commission sends each year a report on the
implementation of Community assistance under this instrument.
The report shall contain information on the actions financed during the
year and on the findings of monitoring work, and shall give an
assessment of the results achieved in the implementation of the
assistance.
Content:
--> Programming, implementation mechanisms, implementation,
progress by objectives, financial execution, monitoring, audit and
controls, consultations with government
Aid Report 2022
Recovery and
Resilience
Facility
(RRF)
YES: Article
31
Nature:
The Commission provides an annual report on the implementation of
the Facility.
The annual report includes information on the progress made with the
recovery and resilience plans of the Member States concerned under
the Facility, implementation of the milestones and targets, the status
of payments and suspensions thereof, contribution of the Facility to
the climate and digital targets, performance of the Facility based on
the common indicators, expenditure financed by the Facility under the
six pillars.
Content:
Progress with the RRPs at aggregate and MS level, including revision
- RePowerEU
- Financing through EU bonds and green bonds
158
- Status of M&T and payments
- Contribution to climate and digital targets
- Performance based on common indicators
- Expenditure under the six pillars, and social exp.
- Contribution of the facility the key RRF objectives
- Available information on final recipients
- Policies to improve competitiveness
- Controls and audit
- Communication and dialogues
- Mid-term evaluation
187852c2-07e0-4bef-af3f-5719b9077f2e_en
Technical
Support
Instrument
(TSI)
YES: Article
15
Nature:
Annual report - The Commission provides an annual report on the
implementation of this Regulation.
The annual report shall include information on:
-requests for support submitted by Member States
-the analysis of the application of the criteria used to analyse the
requests for support submitted by Member States;
-cooperation and support plans;
-special measures adopted;
-the implementation of support measures, where appropriate also at
national and regional level; and
-the communication activities carried out by the Commission.
Content:
Request for support, projects supported, amount, execution of projects,
cooperation and support plan, communication activities
technical support instrument 2021
Pericles IV YES: Article
12
Nature:
159
Annual report - The Commission provides annual information on the
results of the Pericles IV programme taking into account the
quantitative and qualitative indicators set out in the Annex.
Content:
Commitments under annual work programme, implementation of
actions, monitoring of the quantitative and qualitative indicators.
EUR-Lex - 52024DC0259 - EN - EUR-Lex
Union Civil
Protection
Mechanism
(UPCM)
YES: Article
34
Nature:
Biennial report- Every two years, the Commission submits a report on
operations and progress made. The report shall include information on
progress made towards the Union disaster resilience goals, capacity
goals and remaining gaps, taking into account the establishment of
rescEU capacities and provide an overview of the budgetary and cost
developments relating to response capacities, and an assessment of the
need for further development of those capacities.
Content:
Demand of assistance, actions taken, key findings.
EUR-Lex - 52024DC0130 - EN - EUR-Lex
EU4Health
Programme
NO
Emergency
Support
Instrument
(ESI)
YES: Article 8 Nature:
12 months after activation report - At the latest 12 months after the
activation of the emergency support for a specific situation, the
Commission shall present a report and, where appropriate, proposals
to terminate it.
Content:
160
Budget, implementation, communication, actions financed,
performance.
REPORT FROM THE COMMISSION TO THE COUNCIL
European
Social Fund +
(ESF+)
NO High level report - Commission
published a Report on economic,
social and territorial cohesion. It
deals with the European Social Fund
(ESF+), the European Regional
Development Fund (ERDF) and the
Cohesion Fund (CF). It presents the
state-of-play of EU Cohesion
situation through economic
indicators in several fields (diversity,
green transition, digital transition,
innovation, governance...), explains
initiatives led by the EU, progress
and achievements thanks to EU
support. One section deals with
Cohesion Policy's impacts, but
remains high level.
https://european-social-fund-
plus.ec.europa.eu/en/publications/ni
nth-report-economic-social-and-
territorial-cohesion
Erasmus+ YES: Article
23
An annual report is published by the
Commission on Erasmus
Erasmus+ annual report 2022 -
Publications Office of the EU
161
European
Solidarity
Corps (ESC)
YES: Article
230
A report on the period 2021-2023
was published by the Commission
with key figures (projects,
participants, budget commitments),
testimonials, examples of projects.
European solidarity corps -
Publications Office of the EU
Justice
Programme
YES: Article
13
Nature:
Annual report - The Commission reports on the performance of the
Programme annually to the European Parliament and to the Council,
within the existing reporting mechanisms, in particular the EU Justice
Scoreboard.
The Commission reports on the use of the funds allocated to each
specific objective, specifies the types of action that have received
funding, including actions linked to the promotion of gender equality.
Content:
Key findings on efficiency, quality and independence of justice.
THE 2024 EU JUSTICE SCOREBOARD
Citizens,
Equality,
Rights and
Values
Programme
(CERV)
NO
Creative
Europe
NO Annual report - Creative Europe
report: state-of-play, political
priorities, applications, projects,
amounts...
162
Creative Europe 2021-2022 -
Publications Office of the EU
Common
Agricultural
Policy (CAP)
YES Nature:
Biennial performance review - Based on information from the annual
performance reports prepared by MS. In case targets are substantially
missed, the Commission is to provide an explanation and follow-up
actions. The added value of the performance clearance is considered
by Member States and the Commission as low compared to the
administrative burden it generates.
European
Maritime,
Fisheries and
Aquaculture
Fund
(EMFAF)
NO
Regional
Fisheries
Management
Organisations
and
Sustainable
Fisheries
Partnership
Agreements
NO There are references to the SFPAs
and RFMOs in the annual report of
the Common Fisheries Policy (e.g.
Communication from the
Commission to the European
Parliament and the Council -
Sustainable fishing in the EU: state
of play and orientations for 2024 and
Commission staff working
document accompanying the
document Communication from the
Commission to the European
Parliament and the Council -
163
Sustainable fishing in the EU: state
of play and orientations for 2024)
Programme
for
Environment
and Climate
Action
(LIFE)
YES: Article
19
Nature:
The contribution of the LIFE Programme to Union climate and
biodiversity objectives shall be reported regularly in the context of
evaluations and the annual report.
Just
Transition
Mechanism
(JTM)
YES: Article
16
Nature:
Annual report - By 31 October of each calendar year, starting with
2022, the Commission shall issue a report on the implementation of
the Facility. That report shall provide information on the level of
implementation of the Facility with respect to its objectives, conditions
and performance indicators
Content:
Budgetary framework, implementation, communications activities,
lessons learnt
EUR-Lex - 52023DC0713 - EN - EUR-Lex
Asylum,
Migration
and
Integration
Fund (AMIF)
NO The Commission shall ensure that
the summaries provided by Member
States are translated into all official
languages of the Union and made
publicly available. (Article 35)
https://home-
affairs.ec.europa.eu/funding/asylum
-migration-and-integration-
funds/asylum-migration-and-
164
integration-fund-2021-
2027_en#annual-performance-
reports-from-the-member-state-
programmes
Border
Management
and Visa
Instrument
NO The Commission shall ensure that
the summaries provided by Member
States are translated into all official
languages of the Union and made
publicly available. (Article 29)
https://home-
affairs.ec.europa.eu/funding/borders
-and-visa-funds/integrated-border-
management-fund-border-
management-and-visa-instrument-
2021-27_en#annual-performance-
reports-from-the-member-state-
programmes
Customs
Control
Equipment
Instrument
YES: Recital
26
Nature:
Annual Report - Annual progress reports should, as part of the
performance reporting system, be issued to monitor the
implementation of the Instrument. Those reports should include a
summary of the lessons learnt and, where appropriate, of the obstacles
encountered, and shortfalls discovered in the context of the activities
of the Instrument that took place in the year in question. Those annual
progress reports should be communicated to the European Parliament
and the Council.
165
Content:
Implementation, project description, lessons learnt, amount,
performance indicators.
https://taxation-customs.ec.europa.eu/document/download/ef4ea7c1-
dc66-4a92-99fc-
2baf6f102e85_en?filename=SWD_2023_251_F1_STAFF_WORKI
NG_PAPER_EN_V2_P1_2823669.PDF
Internal
Security
Fund (ISF)
NO The Commission shall ensure that
the summaries provided by Member
States are translated into all official
languages of the Union and made
publicly available. (Article 30)
https://home-
affairs.ec.europa.eu/funding/internal
-security-funds/internal-security-
fund-2021-2027_en#annual-
performance-reports-from-the-
member-state-programmes
Nuclear
Decommissio
ning
(Lithuania)
YES: Article
10
Nature:
Annual report - At the end of each year, the Commission shall draw
up a progress report on the implementation of the work carried out in
the previous years, including the rate of activities resulting from calls
for tenders, and shall present it to the European Parliament and to the
Council.
Content:
Programme framework, budgetary implementation, progress,
performance, activities from call tenders.
166
NDAP Progress report 2021
Nuclear
Safety and
Decommissio
ning (NSD)
YES: Article
10
Nature:
Annual report - At the end of each year, the Commission shall draw
up a progress report on the implementation of the work carried out in
the previous years, including the rate of activities resulting from calls
for tenders, and shall present it to the European Parliament and to the
Council.
Content:
Programme framework, budgetary implementation, progress,
performance, activities from call tenders.
NDAP Progress report 2021
European
Defence Fund
(EDF)
NO The Commission shall monitor the
implementation of the Fund on a
regular basis and shall report
annually on progress made,
including how lessons identified and
lessons learned from the EDIDP and
the PADR are taken into account in
the implementation of the Fund, to
the European Parliament and to the
Council. To that end, the
Commission shall put in place
necessary monitoring arrangements.
(Article 28)
Regulation on
Supporting
Ammunition
YES: Article
23
Nature:
Evaluation report - By 30 June 2024, the Commission shall draw up a
report evaluating the implementation of the measures set out in this
Regulation and their results, as well as the opportunity to extend their
167
Production
(ASAP)
applicability and provide for their funding, particularly with regard to
the evolution of the security context. The evaluation report shall build
on consultations of the Member States and key stakeholders and be
communicated to the European Parliament and to the Council.
Content:
Implementation, work programme and calls preparation, application
and progress, evaluation and recommendations.
defence-industry-space.ec.europa.eu/document/download/d980180b-
0749-45d5-b857-e7864adef4b2_en?filename=ASAP Implementation
Report.pdf
EU Defence
Industry
Reinforcemen
t Through
Common
Procurement
Act
(EDIRPA)
YES: Article
14
Nature:
Evaluation report - The Commission shall monitor the implementation
of the Instrument and shall report on progress made. To that end, the
Commission shall put in place the necessary monitoring arrangements.
By 31 December 2026, the Commission shall draw up a report
evaluating the impact and effectiveness of the actions taken under the
Instrument (the ‘evaluation report’) and shall submit it to the European
Parliament and to the Council. The evaluation report shall build on
consultations with Member States and key stakeholders and shall
assess the progress made towards the achievement of the objectives
set out in Article 3. It shall evaluate potential bottlenecks in the
functioning of the Instrument and, in particular, the contribution of the
Instrument to:
(a)cooperation between Member States and associated countries,
including the creation of new cross-border cooperation;
(b)the participation of SMEs and mid-caps in the actions;
(c)the creation of new cross-border cooperation between contractors
and subcontractors in supply chains throughout the Union;
168
(d)the strengthening of the EDTIB’s competitiveness and the
adaptation, modernisation and development to allow it to address, in
particular, the most urgent and critical defence products needs;
(e)the overall value of common procurement contracts for the most
urgent and critical defence products supported by the Instrument.
Neighbourho
od,
Development
and
International
Cooperation
Instrument
(NDICI
Global
Europe)
YES: Article
41
Nature:
The Commission shall examine the progress made in implementing
the Instrument. Starting from 2022 onwards, the Commission shall, in
a timely manner by 30 November each year, submit an annual report
on progress towards the achievement of the objectives of the
Instrument by means of indicators, including, but not limited to, those
set in Annex VI, reporting on the ongoing activities, results delivered
and the effectiveness of the Regulation. That report shall also be
submitted to the European Economic and Social Committee and to the
Committee of the Regions. The regulation foresees further details
which should be include in this report;
Content:
Achievements and reporting on SDGs, implementation, and detailed
annexes on results and financial statistics, including detailed SDG
reporting.
2023 Annual report on the implementation of the European Union's
external action instruments in 2022 - Publications Office of the EU
European
Instrument
for
International
Nuclear
NO
169
Safety
Cooperation
(INSC)
Humanitaria
n Aid
(HUMA)
YES: Article
19
Nature:
Annual report - At the close of each financial year, the Commission
submits an annual report with a summary of the operations financed in
the course of that year. The summary shall contain information
concerning the agencies with which humanitarian operations have
been implemented. The report shall also include a review of any
outside assessment exercises which may have been conducted on
specific operations.
Content:
Achievements and reporting on SDGs, implementation
2023 Annual report on the implementation of the European Union's
external action instruments in 2022 - Publications Office of the EU
Common
Foreign and
Security
Policy (CFSP)
NO
Overseas
Countries
and
Territories
(OCT)
(including
Greenland)
YES: Article
86
Nature:
Annual report - The Commission submits a report every year starting
in 2022 on the implementation and results of that financial
cooperation.
Content:
Achievements and reporting on SDGs, implementation...
2023 Annual report on the implementation of the European Union's
external action instruments in 2022 - Publications Office of the EU
170
Macro-
financial
Assistance
(MFA)
YES –
Example:
Covid – Article
8
Nature:
Annual report - By 30 June of each year, the Commission shall submit
to the European Parliament and to the Council a report on the
implementation of this Decision in the preceding year, including an
evaluation of that implementation. The report shall:
(a) examine the progress made in implementing the Union’s macro‐
financial assistance;
(b) assess the economic situation and prospects of the partners, as well
as progress made in implementing the policy measures referred to in
Article 3(1);
(c) indicate the connection between the economic policy conditions
laid down in the MOU, the partners’ on‐going economic and fiscal
performance and the Commission’s decisions to release the
instalments of the Union’s macro‐financial assistance.
Content:
Implementation, disbursements, operational assessment, evaluation
EUR-Lex - 52024DC0240 - EN - EUR-Lex
Instrument
for Pre-
accession
Assistance
(IPA III)
YES: Article
13
Nature:
Annual report - Article 41 of Regulation (EU) 2021/947 in relation to
monitoring and reporting shall apply to this Regulation mutatis
mutandis. The annual report referred to in Article 41(5) of Regulation
(EU) 2021/947 (NDICI Global Europe) shall also contain information
on commitments and payments per instrument (IPA, IPA II and IPA
III). In addition, the annual report shall contain information on the
commitments for specific objectives.
Content:
Achievements and reporting on SDGs, implementation
171
2023 Annual report on the implementation of the European Union's
external action instruments in 2022 - Publications Office of the EU
Reform and
growth
facility for the
Western
Balkans
YES: Article
25
Nature:
Annual report - The Commission shall provide an annual report to the
European Parliament and the Council on progress towards the
achievement of the objectives of this Regulation. That annual report
shall also address synergies and complementarities of the Facility with
other Union programmes, in particular support provided under
Regulation (EU) 2021/1529, with a view to avoiding the duplication
of assistance and double funding.
Ukraine
Facility
YES: Article
39
Nature:
Annual report - The Commission shall provide simultaneously to the
European Parliament and the Council an annual report on progress
towards the achievement of the objectives.
European
Globalisation
Adjustment
Fund for
Displaced
Workers
(EGF)
YES: Article
21
Nature:
Biennial report - By 1 August 2021 and every two years thereafter, the
Commission shall submit to the European Parliament and to the
Council a comprehensive, quantitative and qualitative report on the
activities. The regulation foresees further details which should be
include in this report;
Content:
Applications submitted, decisions adopted, measures funded, results
achieved, financial execution, qualitative assessment.
EUR-Lex - 52023DC0482 - EN - EUR-Lex
European
Union
Solidarity
Fund (EUSF)
YES: Article
12
Nature:
Annual report - Before 1 July the Commission shall present to the
European Parliament and to the Council a report on the activity of the
Fund in the previous year. This report shall in particular contain
information relating to Articles 3, 4 and 8 of the regulation.
172
Content:
Applications, financing and closures.
COM_COM(2020)0034_EN.pdf
Innovation
Fund (IF)
YES: Article
10a
Nature:
Annual report - By 31 December 2023 and every year thereafter, the
Commission shall report to the Climate Change Committee referred to
in Article 22a(1) of this Directive, on the implementation of the
Innovation Fund, providing an analysis of projects awarded funding,
by sector and by Member State, and the expected contribution of those
projects towards the objective of climate neutrality in the Union
Brexit
Adjustment
Reserve
(BAR)
YES: Article
17
Nature:
By June 2024, the Commission shall inform the European Parliament
and the Council on the state of play of the implementation process of
this Regulation, based on available information.
By 30 June 2027, the Commission shall carry out an evaluation to
examine the effectiveness, efficiency, relevance, coherence and Union
added value of the Reserve. The Commission may make use of all
relevant information already available in accordance with Article 128
of the Financial Regulation.
By 30 June 2028, the Commission shall submit to the European
Parliament, to the Council, to the European Economic and Social
Committee and to the Committee of the Regions a report on the
implementation of the Reserve.
Content:
Implementation, allocation, next steps, measures undertaken...
SWD_2024_154_Officially_TRANSMITTED_20.06.2024.pdf
173
Social
Climate Fund
(SCF)
NO
174
Reporting requirements under the post-2027 programmes
Under the preferred policy option, all reporting requirements would be simplified and
consolidated through the Annual Management and Performance Report. This would first
require consolidating and aligning legal provisions regulating all aspects of reporting, financial,
performance and activity of services.
The reporting would be done at the same period. This would mean that under the current
provisions of the Financial regulation and taking into account current practice, where the draft
budget is presented early105
, the reporting deadline would be 30 June each year, which includes
any information that needs to be provided along with the draft budget.
Reporting would be consolidated at the level of the entire budget. All information related to
implementation, financial or substantive, would be reported within one report, allowing for
correlations between financial and substantive implementation to be made where relevant. No
separate reporting would be done at the programme level. If more detailed information is
necessary or where information needs to be updated more frequently, dashboards could be used
to allow this.
Some separate reporting would be kept because the object of reporting is technically not
implementation of budgetary interventions, such example being the Annual Activity Report.
No information provided in one report would be repeated in another report. Rather, cross-
cutting references to clusters of information between reports could be included when necessary.
This would require that all reporting is produced roughly within the same timeframe.
The above approach would reduce the reporting burden, since it would reduce the need to
multiply the effort on providing the same type of information in view of different cut-off dates
and potentially different methods of calculation. The possibility of error would decrease, both
because data would no longer be provided in several reports, as well as because services could
provide more resources to reporting if it is to be done less often. The insight and useability of
such reporting could increase because information would be gathered at one place. By
maintaining financial and performance reporting being bundled with draft budget, they could
have a true impact on budgetary decisions, as well as on management of programmes, leading
to a true performance-based budgeting.
To a degree, some parts of reporting have already been consolidated by linking the preparation
of the Annual Management and Performance Report to the draft budget. The experience with
such approach is positive as administrative burden is less than it would be had an additional
document have to be produced to be attached to the draft budget.
105
Under the Financial regulation, the deadline for presenting the draft budget is 1 September each year
175
8.2 Reporting tools and systems
There are at least 20 dashboards providing information related to the EU budget and its
performance. In addition to the four dashboards published by DG Budget106
, there are 16
programme-specific dashboards publicly available. They can be roughly categorised in three
groups: a) Qlik Sense-based dashboards, b) cohesion-related dashboards, and c) others.
The organisation of the information they provide – as well as the type and granularity of data
– is not standardised. The dashboards generally provide output data, with some exceptions –
e.g. the Common Agricultural Policy dashboard provides a number of contextual indicators,
such as the prices of agricultural commodities.
Because the type of information that is provided depends on the programme, as well as because
the organisation of the data is not standardised, it is not possible to easily compile information
thus obtained. Moreover, the information included in the dashboards, even if compiled, does
not provide information on contribution to cross cutting policy objectives. Indicators
programmes are also often not standardised.
For example, it is not possible to obtain information as to how many beneficiaries obtained
funding for education across all EU programmes; or how many kilometres of railways were
built. From these dashboards, it is also not possible to obtain information as to how much
funding was provided towards cross-cutting objectives, such as climate action or gender
equality. Similarly, information cannot be grouped by categories such as time-period (i.e. how
many outputs of certain type were provided across the budget in a certain timeframe) or by
place of implementation (e.g. how many EU-funded activities took place in a certain Member
State, region or city).
Providing information in a fragmented way or providing the same information via different
dashboards also increases risks of publishing incoherent information or leading to
misinterpretation. Lastly, such multiplication of effort is inefficient as far as use of EU
Institutions resources is concerned.
106
The four dashboards published by DG BUDGET are EU Financial Transparency System; EU Funded projects
| EU Funding & Tenders Portal; EU Spending and Revenue 2021-2027; Programme Performance Statements
176
Table: Reporting dashboards in the 2021-2027 MFF programmes
Programme
Content Summary Link
1. EU Financial Transparency System
Qlik Sense dashboard
https://ec.europa.eu/budget/financial-transparency-
system/index.html
2. EU Spending and Revenue 2021-2027
Qlik Sense apps in a webpage
https://commission.europa.eu/strategy-and-policy/eu-
budget/long-term-eu-budget/2021-2027/spending-and-
revenue_en
3. Programme Performance Statements
https://commission.europa.eu/strategy-and-policy/eu-
budget/performance-and-reporting/programme-performance-
statements_en
4.
EU Funded projects | EU Funding &
Tenders Portal
EU Funded projects | EU Funding & Tenders Portal
5. Horizon Europe
Presenting an overview on evaluated proposals (incl. success rates)
and detailed statistics and data on funded projects and their
participants in EU R&I programmes, broken down by countries and
regions, research domain/programme part, organisation type, etc.
https://ec.europa.eu/info/funding-
tenders/opportunities/portal/screen/opportunities/horizon-
dashboard
6. InvestEU
The graphs show the implementation of the InvestEU Fund. Data
are based on the operational reporting of the InvestEU implementing
partners and are regularly updated as data are available.
Non-interactive graphs but also a link to Qlik Sense
https://investeu.europa.eu/investeu-programme/investeu-
fund/investeu-indicators_en
7. Connecting Europe Facility (CEF)
CEF Data Hub: The dashboard presents data about all Grant
Agreements (GA) managed by the European Climate, Infrastructure
and Environment Executive Agency (CINEA)
https://dashboard.tech.ec.europa.eu/qs_digit_dashboard_mt/p
ublic/sense/app/3744499f-670f-42f8-9ef3-
0d98f6cd586f/sheet/4c9ea8df-f0f9-4c0d-b26b-
99fc0218d9d9/state/analysis
177
8. Digital Europe Programme
The Dashboard currently features two profiles: the DIGITAL
Country Profile and the DIGITAL Projects Profile.
https://dashboard.tech.ec.europa.eu/qs_digit_dashboard_mt/p
ublic/extensions/CNECT_DIGITAL_dashboard/CNECT_DI
GITAL_dashboard.html#country
9.
Regional Policy Funds (ERDF and
Cohesion Fund)
Cohesion Open Data Platform
An aggregated presentation of Cohesion Policy 2021-2027 (ERDF
/ ESF+ / CF / JTF) under the "investment in jobs and growth" goal
is available on this page.
https://cohesiondata.ec.europa.eu/funds/erdf/21-27
https://kohesio.ec.europa.eu/fr/
10.
Recovery and Resilience Facility
The Recovery and Resilience Scoreboard gives and overview of
how the implementation of the Recovery and Resilience Facility
(RRF) and the national recovery and resilience plans is progressing.
NextGenerationEU Green Bond Dashboard:
Information about the NextGenerationEU green bonds allocations
across Member States, expenditure categories and intervention
fields.
https://ec.europa.eu/economy_finance/recovery-and-
resilience-scoreboard/index.html
https://commission.europa.eu/strategy-and-policy/eu-
budget/eu-borrower-investor-relations/nextgenerationeu-
green-bonds/dashboard_en
11.
European Social Fund+
Comprehensive overviews of the EU's main agricultural products,
in the form of dashboards, integrating in one view graphs and tables
of relevant market data for selected products, such as production,
prices, trade, use and stocks.
https://cohesiondata.ec.europa.eu/funds/esf_plus/21-27
12.
Erasmus+
Qlik Sense. Presents regularly updated data stories of the Erasmus+
programme to provide an easy-to-use overview of the programme's
activities and results.
https://webgate.ec.europa.eu/eacdashboard/sense/app/c553d9
e9-c805-4f7a-90e4-103bd1658077/overview
13.
Common Agricultural Policy
Two parts:
1. Financing part, non-interactive but downloadable graphs/charts
2. Comprehensive overviews of the EU's main agricultural products,
in the form of dashboards, integrating in one view graphs and tables
of relevant market data for selected products, such as production,
prices, trade, use and stocks.
https://agridata.ec.europa.eu/extensions/DataPortal/dashboard
s.html
https://agriculture.ec.europa.eu/data-and-
analysis/financing/cap-expenditure_en
EU budget execution - overview | Cohesion Open Data
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14.
European Maritime, Fisheries and
Aquaculture Fund
Cohesion Open Data Platform
An aggregated presentation of Cohesion Policy 2021-2027 (ERDF
/ ESF+ / CF / JTF) under the "investment in jobs and growth" goal
is available on this page.
https://cohesiondata.ec.europa.eu/funds/emfaf/21-27
https://emff-datahub.eismea.eu/
15.
LIFE
Qlik Sense dashboard
https://dashboard.tech.ec.europa.eu/qs_digit_dashboard_mt/p
ublic/sense/app/8298c020-48a6-4b84-91f4-
f6f2665c0f99/overview
16.
Just Transition Mechanism
Cohesion Open Data Platform
An aggregated presentation of Cohesion Policy 2021-2027 (ERDF
/ ESF+ / CF / JTF) under the "investment in jobs and growth" goal
is available on this page.
https://cohesiondata.ec.europa.eu/funds/jtf/21-27
17.
Asylum, Migration and Integration Fund
Cohesion Open Data Platform
An aggregated presentation of Cohesion Policy 2021-2027 (ERDF
/ ESF+ / CF / JTF) under the "investment in jobs and growth" goal
is available on this page.
https://cohesiondata.ec.europa.eu/funds/amif/21-27
18.
Integrated Border Management Fund
Cohesion Open Data Platform
An aggregated presentation of Cohesion Policy 2021-2027 (ERDF
/ ESF+ / CF / JTF) under the "investment in jobs and growth" goal
is available on this page.
https://cohesiondata.ec.europa.eu/funds/bmvi/21-27
19.
Internal Security Fund
Cohesion Open Data Platform
An aggregated presentation of Cohesion Policy 2021-2027 (ERDF
/ ESF+ / CF / JTF) under the "investment in jobs and growth" goal
is available on this page.
https://cohesiondata.ec.europa.eu/funds/isf/21-27
20.
Innovation Fund
Qlik Sense dashboard
https://dashboard.tech.ec.europa.eu/qs_digit_dashboard_mt/p
ublic/sense/app/6e4815c8-1f4c-4664-b9ca-
8454f77d758d/sheet/bac47ac8-b5c7-4cd1-87ad-
9f8d6d238eae/state/analysis
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The recast of the Financial regulation also reinforces transparency requirements across the EU
budget as from the next MFF, in particular by requiring to make available on a centralised
website information on recipients of funds financed from the budget. Article 38 of the
regulation provides several details regarding the content of the information to be published, the
process of publishing, and the rules for processing of data, including personal data. A number
of EU budget programmes under direct and indirect management publish such information
through the Financial Transparency System. However, there is no comprehensive reporting of
information on beneficiaries for programmes under shared management. While the process of
obtaining the necessary information remains subject to sector-specific rules, information still
has to be centralised through a single website as required by the Financial regulation. In
addition to this, reporting for programmes under shared management needs to be provided for.
Displaying performance information via a single portal under the post-2027 programmes
The preferred policy option foresees the centralisation of performance data on the EU budget
through a single online dashboard. This platform would provide comprehensive insights,
including budget implementation information, expenditure monitoring by intervention field
and horizontal priorities, and key performance indicators. Additionally, it could feature
information on beneficiaries. The dashboard would be modelled after the existing Open Data
Platform for cohesion policy funds and the Recovery and Resilience Scoreboard, ensuring
transparency and ease of access.
This option will require a detailed mapping of the information displayed via existing
dashboards, and an assessment of what information needs to be included. A uniform design of
the dashboard could be developed, as well as functionalities that would allow for displaying an
overview of performance information across the EU budget. Such a dashboard could include
relevant analytical tools enabling to analyse data across Member States and objectives.
Such a dashboard would build upon the new standardised system of intervention fields and
performance indicators. Taking into account presentation and IT systems upfront would allow
to design a dashboard with relevant options for data presentation and analysis.
Stakeholders would have access to a wider array of information, meeting diverse needs
regardless of the reason for their visit to the dashboard. This information would be of higher
quality, offering a comprehensive view of performance data and enhancing transparency and
accountability toward stakeholders. Furthermore, maintaining a single dashboard is likely to
require fewer resources and reduce administrative burden on the Commission.
The preferred policy option also foresees increased alignment with the Financial Regulation
requirements regarding the collection, storage and publishing of data on beneficiaries and
operations supported by the EU budget. All EU budget programmes – under all management
modes – would publish such information through the new single dashboard.
While facilitating access to information via a single dashboard, the preferred policy option
foresees a differentiated operationalization per management mode or programme, whereby the
single dashboard would enable to display specific data regarding dedicated areas and sectors,
and performance information presenting specific programmes achievements.
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8.3 Portals informing project promoters and potential applicants about funding
opportunities
Currently, information about EU funding opportunities is fragmented and not readily available
to project promoters. There is no single website, nor portal that comprises an overview of all
EU funding opportunities.
The preliminary mapping of portals and one-stop-shops – informing potential beneficiaries
about EU funding opportunities – and their current expansion demonstrate the need for a more
user-centric approach (see table below).
The proliferation of information portals addressing the needs of specific constituencies is
essentially dictated by the complexity of the EU budget implementation framework, namely
the large number of MFF programmes, 140 different types of actions and a lack of
harmonisation of publication modalities across the three management modes.
While the Funding & Tender Portal covers information about grants and procurements under
directly and some indirectly managed programmes, information on upcoming funding
opportunities at national level is published on Member States national portals and calls are
published on regional websites (around 400). Information about other repayable forms of
funding (equity, loans, guarantees) that are channelled through implementing partners – i.e. the
EIB group, national promotional banks and the network of local financial intermediaries acting
across the European Union – are spread across multiple websites. To remediate this situation,
the Access to EU Finance portal redirects users to the local financial intermediaries in the
Member States while the InvestEU Portal, which brings together investors and project
promoters under a single EU-wide platform, provides visibility and matchmaking opportunities
for investment projects within the EU, Norway and Iceland.
Extensive outreach and a dedicated survey answered by some 500 industry organizations and
private companies implemented by the Commission STEP Task Force in 2024 has shown that:
• A significant majority of users, regardless of their experience with EU funds, struggle
to understand and identify available funding opportunities;
• The current dispersion of information across multiple websites and one-stop-shops
hinders accessibility;
• Most project applicants rely heavily on external assistance (i.e., consultants) to navigate
EU funding opportunities, resulting in additional costs for stakeholders before they
even begin the application process.
The preliminary mapping of portals – informing potential beneficiaries about EU funding
opportunities – shows that the Commission and/or implementing partners currently operate at
least 11 portals. Additionally, 6 new portals are under development (see table below).
From a technical point of view, the lack of harmonisation and standardisation of publication
requirements as well as the lack of inter-operability of databases of funding opportunities
across management modes prevents development of an intelligent search engine that would
provide project promoters with an exhaustive guidance on the specific EU funding
opportunities for which their projects may be eligible.
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For example, information about EU funding opportunities for programmes in direct and
indirect management is made available under the Funding & Tender Portal107
. However,
navigating the funding landscape to access relevant documents is time-consuming and difficult
without extensive knowledge, due to the numerous sources and absence of a centralised
repository108
. It can lead to missed opportunities or oversight of critical details, rendering the
efforts of potential applicants inefficient. There is also no structured service to orient the
applicants towards the appropriate form of support (grant, equity, loan). Therefore, potential
applicants must already be familiar with the specific programmes that could support their
projects to apply. This lack of visibility undermines the ability of project promoters to access
financing under EU budget programmes and results in unequal access to EU funding, in
particular small organizations such as SMEs which are likely to have less resources to navigate
existing portals and access procedures109
.
To address such complexity, public and private organizations in the Member States have
developed services, resulting in a highly diverse national offer. Certain countries, such as
France (e.g. via BPI France) and the Netherlands (e.g. via InvestNL), have established national
service points and allocated significant resources to facilitate access to EU funding for national
companies. However, not all Member States offer such services. Additionally, national
promotional banks, institutions, and networks of financial intermediaries have invested in
specific tools to navigate the EU financial landscape (e.g. Unicredit in Italy).
Specific advice is also available at EU level, notably through programmes such as the Horizon
Policy Support Facility, LIFE, EU4Health, the Innovation Fund, and the InvestEU Advisory
Hub. In doing so, the Commission supports potential applicants through various ‘one-stop-
shops' often focusing on individual sectors or areas (e.g., bio-, clean-tech). At EU level, there
is no effective user-centric IT tool available to support project promoters across the whole EU
funding landscape. Potential applicants must search by programme or groups of programmes,
which assumes that they know which programmes objectives fit their investment needs in the
first place. There is no systematic coordination between the various actors (experts in the
Member States, in executive agencies, or in financial institutions) delivering access to funding
support. This also leads to the duplication of information linked to funding opportunities and/or
calls under the same programmes under several portals. As illustrated below, programmes such
as InvestEU are reflected under multiple portals.
To summarise, the current landscape of portals generates confusion, undermines transparency
and reduces project promoters’ ability – including local organizations and SMEs – to identify
suitable funding sources.
107
EU Funding & Tenders Portal
108
In the 2024 STEP Task Force industry outreach, 24% of stakeholders reported difficulties in accessing and
navigating EU funding. When asked, "Is information on EU funding easy to find?", respondents who only
searched for information rated it 4.95/10, while those with both search experience and application experience
rated it slightly higher at 5.6/10.
109
In the 2024 STEP Task Force industry outreach, stakeholders highlighted that SMEs struggle with a lack of
clear information on funding opportunities and often rely on external consultancies due to the high resource
demands of the process.
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Table: Portals and One-Stop-Shops on EU funding opportunities in the 2021-2027 period
Portal Commission
DG in
charge
Type of
funding
Content
Funding and
Tenders Portal
RTD Direct The Funding & Tenders Portal is the main entry point for funding programmes and procurement
options managed by the European Commission and other EU institutions and agencies.
Programmes involved: approx. 40 programmes (e.g., AMIF, CEF, CREA, ERASMUS, EU4H
etc.)
Link: https://ec.europa.eu/info/funding-tenders/opportunities/portal/
Strategic
Technologies
for Europe
Platform (STEP)
BUDG Direct +
Indirect
+ Shared
The STEP funding dashboard below is an interactive guide, offering a continuously updated
state-of-play of funding opportunities supported by the EU budget and dedicated to projects
related to strategic technologies contributing to STEP objectives.
Programmes involved: STEP uses resources across 11 EU funding programmes (Horizon,
EU4Health, IF, EDF, DEP, ERDF, CF, ESF+, JTF, RRF, InvestEU)
Link: https://strategic-technologies.europa.eu/get-funding_en
Net-Zero
Europe Platform
GROW Direct +
Indirect
+ Shared
Under development. The Net-Zero Industry Act (NZIA) establishes the Net-Zero Europe Platform
(Platform) to support the implementation of NZIA. The platform includes representatives from the
Commission and the EU countries, with the Commission chairing. It monitors progress towards
the Act’s objectives.
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Net-Zero Desk CLIMA tbd Under development.
Access to EU
Finance
GROW Indirect The portal helps to apply for loans and venture capital supported by the European Union.
EU funds: InvestEU, ESIFs, EIB, EIF, RRF. EFSE
Link: https://youreurope.europa.eu/business/finance-funding/getting-funding/access-
finance/search/
Batteries One-
Stop-Shop
GROW Direct +
Shared
Access to EU public finance for start-ups and scale-ups in the battery value chain. Co-founded by
the EU in cooperation with EIT InnoEnergy. (European Battery Alliance)
Link: https://www.eba250.com/one-stop-shop/
Hydrogene One-
Stop-Shop
GROW Direct Under development.
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InvestEU
Advisory Hub
ECFIN Indirect The InvestEU Advisory Hub is the central entry point for project promoters and intermediaries
seeking advisory support and technical assistance.
EU Funds: InvestEU
Link: https://investeu.europa.eu/investeu-programme/investeu-advisory-hub_en
Enterprise
Europe Network
GROW Direct +
Shared
The Enterprise Europe Network offers comprehensive support to small and medium-sized
enterprises (SMEs) in accessing and applying for various EU funding programmes:
- Identify EU funding programmes;
- Guidance through the funding process;
- Finding research partners;
- Business innovation strategies
EU funds: Horizon Europe, LIFE, Erasmus+, Single market Programme, ERDF
Link: https://een.ec.europa.eu/about-enterprise-europe-network/advice-support/access-eu-
funding-programmes
Innospace
Platform
RTD / EIC
+EISMEA
Direct Innospace Platform is a computer platform which aims to provide for an AI-based virtual European
Innovation Space (the Innospace) open to all interested stakeholders and parties, and include a
specific EIC AI-based sub-platform (the EIC Space) providing for the implementation and
management of all EIC instruments and operations.
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On hold
New European
Innovation
Agenda
RTD Direct The New European Innovation Agenda aims at providing access to finance for deep tech scale-ups
On hold
EU Rural toolkit AGRI / JRC Direct +
Indirect
+ Shared
The EU Rural toolkit is a portal which guides to EU funding and support opportunities for rural
areas in the European Union. It aims to help local authorities, institutions and stakeholders,
businesses and individuals to identify and take advantage of existing EU funds, programmes and
other funding and support initiatives, and to foster development in rural territories.
EU funds: Single Market Programme (SME pillar, Euroclusters), Citizens, Equality, Rights and
Values programme, LIFE, Horizon Europe (Cluster 2, 5 and 6), CEF (5G), JTF, Creative, European
Solidarity Corps, AMIF, Erasmus+, EMFAF, ERDF, ESF+, Interreg, CF, EAFRD, InvestEU
Link: https://funding.rural-vision.europa.eu/finder?lng=en
InvestEU
Guarantee &
Equity products
ECFIN / EIF Indirect The InvestEU Guarantee & Equity Products is a portal describing and providing information on
guarantees categories offer by the programme by the EIB within the framework of InvestEU.
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EU funds: InvestEU
https://engage.eif.org/investeu/guarantees
Biotech One-
Stop-Shop
GROW tbd Under development. Better support for scale-up and ease of navigating regulations: the
Commission is developing the EU Biotech and Biomanufacturing Hub, an operational tool for
biotech and biomanufacturing companies to navigate through the regulatory framework and identify
support to scale up.
Erasmus+ and
European
Solidarity
applications
EAC Direct Portal for application for Erasmus+ and European Solidarity Corps actions managed by the
Erasmus+ National Agencies.
EU funds: Erasmus+ and European Solidarity Corps
Erasmus+ and European Solidarity Corps platform
Procurement,
grants, and
prizes organized
by EUSPA
EU Agency
for Space
Programme
Indirect List of procurement opportunities and grants financed under Space regulation and launched by
EUSPA.
EU funds: EU Space Programme, Horizon Europe
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Procurement, grants, and prizes | EU Agency for the Space Programme
Transnational
calls portal
European
Competence
Centre for
Social
Innovation
Direct List of calls related to social experimentation and social innovation.
EU funds: ESF+ (EaSI strand)
https://socialinnovationplus.eu/transnational-calls/funding/transnational-calls/
Displaying funding opportunities – available under EU funds – via a portal under the
post-2027 programmes
The preferred policy option involves transitioning from the current fragmented system of
multiple portals to a unified, single portal that centralises all EU funding opportunities and
calls, following the approach used with the Strategic Technologies for Europe Platform
(STEP) portal. This centralised system would address many of the shortcomings identified
in the current system, such as the complexity of navigating multiple portals, lack of
interoperability, and unequal access to funding information, particularly for SMEs and
small organisations.
The new portal would consolidate the data from all current portals into a single, unified
database, integrating funding opportunities from the various EU funding programmes and
across management modes. A centralised IT platform would host the portal, ensuring that
all users (public and private sector, SMEs, research institutions, etc.) access the same
database and interface, for which the STEP Portal is a testing ground experiment. This
would require developing the IT infrastructure, including scalable cloud-based solutions,
to handle potentially large volumes of data and users. Here, the EU Funding & Tender
Portal110
, for example, could be used as a starting point. The implementation could be
designed in stages, starting with the harmonised publication of funding opportunities by
all contracting authorities. To that end, the new portal would need to:
- make available standardised electronic forms and templates in all official
languages of the Union (following the example of the TED portal for
procurements);
- allow for an electronic exchange of data, in accordance with Article 148 of the
Financial Regulation, enabling the encoding and transmission of information
by all contracting authorities;
- allow for the automatic allocation of unique identifiers for each publication;
develop virtual assistance for the identification of relevant EU funding
opportunities by project applicants.
With a single entry point, beneficiaries would no longer need to navigate multiple,
disparate portals. The portal would act as a one-stop shop where all funding opportunities
and calls are listed in a centralised location, with a more intuitive and user-friendly
interface, similar to what has been done with the STEP portal. This would vastly improve
user experience by reducing the need to search through multiple systems. There would be
fewer instances of duplicated content, and beneficiaries would be able to access the correct,
up-to-date information without encountering redundant or conflicting data.111
By simplifying access to EU funding opportunities, the portal would help address the issue
of unequal access, particularly for small and medium-sized enterprises (SMEs) and less-
resourced organisations. These organisations would find it easier to identify and apply for
relevant funding opportunities without the burden of navigating complex systems.
110
https://ec.europa.eu/info/funding-tenders/opportunities/portal/screen/home
111
In the 2024 STEP Task Force industry outreach, 72% of respondents saw value in a one-stop-shop
integrating EU and national funding, citing benefits such as easier discovery, time savings, and greater
clarity. Additionally, nearly 89% of users reported finding the information they needed on the STEP Portal.
189
In the second stage of implementation, the single portal would provide a single entry point
enabling applicants to directly submit their project applications in one place and in line
with harmonised rules of procedure.
The portal conceived as an ‘EU funding shopping mall’ could offer advanced search
functions and personalized recommendations, helping users find the most relevant
opportunities based on their specific projects and needs. The portal could also integrate
AI-driven tools, such as chatbots and virtual assistants, to provide real-time guidance on
the available funding options, helping users navigating the system and answering
frequently asked questions about eligibility, application processes, and requirements. It
could feature an advanced guidance system that leads beneficiaries through a step-by-step
process to identify the most suitable funding programs for their needs (e.g., grants, loans,
equity) and provide access to sector-specific support through dedicated advisory services
(e.g. include links to specialized EU-level support services, such as Horizon Europe
advisory services for research, or InvestEU advisory services for investment projects).112
This would ensure that users are not overwhelmed by the complexity of funding options
and can receive tailored advice. Key features would include user-friendly design, direct
application, smart filtering of opportunities, automatic notifications, updates across the
application process, and dynamic profiling.
A key technical requirement would be to standardise the data from current portals. This
would involve creating common data formats and metadata across different funding
programs to ensure consistency and accuracy. For example, aligning the way funding calls
are categorised (e.g., by type of support, sector, or target group) across all programs. All
funding calls, deadlines, eligibility criteria, and application details would be presented in
a standardised format, making it easier for users to compare opportunities across different
programs. Automatic integration of data on all Union programmes would ensure that
beneficiaries always have access to the most up-to-date information, reducing the risk of
missed opportunities due to outdated data.
The centralisation will also enable the Commission to reduce administrative burden and
management costs by consolidating resources and streamlining operations. This approach
will lead to greater operational efficiency and cost savings, while ensuring that the data
remains accurate, up-to-date, and consistent across all funding initiatives.
A centralised portal would allow for better tracking and monitoring of user engagement,
funding application trends, and system performance contributing to enhanced business
intelligence. This could guide future policy decisions and improvements to the portal’s
functionality, ensuring that the system evolves to meet the needs of users.
The preferred policy option foresees a differentiated operationalization per management
mode or programme, whereby the single portal would enable to display programme-
specific information regarding available funding opportunities. The portal would also
include links redirecting users to more specific sources such as thematic or national portals
hosted e.g. by Member States and regions.
112
In the 2024 STEP Task Force industry outreach, users identified AI's greatest value in keeping them
informed (74.7%), supporting them during onboarding (76%), and assisting with applications (69.6%).
190
ANNEX 9: ANALYSIS OF IMPACTS OF POLICY OPTIONS
1. Assessment of impacts of policy options P1, M1 and R1 (baseline)
A. Economic impacts
For EU budget beneficiaries, Member States, partner countries and implementing
partners:
Policy option Economic impacts
P1: Baseline –
Programme-specific
rules on DNSH and
gender equality
This option corresponds to using different DNSH requirements and guidances
across MFF programmes. As a result, in cases where the same type of projects
are eligible for funding under different EU funds, different DNSH
requirements may apply depending on the rules applying under each
programme. Such heterogeneity can help better adapting DNSH requirements
to the specificities of each programme, but can generate costs linked to the
complexities and implementation burden expected to be faced by Member
States, partner countries and project beneficiaries such as businesses which
have to deal with divergent requirements sometimes for a single project.
This option also foresees programme-based gender equality requirements. For
Member States and beneficiaries – such as businesses – eligible under
different EU budget programmes, this is expected to generate complexities
and administrative burden, as they would have to manage and implement
heterogeneous rules.
Competitiveness: Implementing heterogeneous DNSH requirements may
generate price pressures i.e. navigating such complex requirements is likely to
increase production costs, which may lead to higher prices for goods and
services. This can reduce businesses competitiveness, especially if
competitors – inside or outside the EU – are not subject to the same stringent
requirements or are able to absorb these costs more easily. Compliance with
heterogeneous DNSH requirements may also lead to reducing market access
and ultimately reduce competitiveness. While some markets may value and
even require sustainable practices, others may prioritise cost over
sustainability. For businesses, especially those in highly price-sensitive
markets, adherence to complex DNSH provisions can limit market access or
the ability to compete effectively on pricing. The heterogeneity of DNSH
requirements from one programme to the other is also expected to generate
uncertainties and a lack of predictability for beneficiaries such as businesses,
which is likely to negatively impact the competitiveness of economic sectors
supported by EU funds.
Small and Medium Enterprises: SMEs are expected to be directly confronted
with such challenges. SMEs often have limited financial resources compared
to larger companies i.e. implementing complex and heavy DNSH
requirements is likely to require investments in new processes which can be
costly. Navigating the regulatory requirements associated with DNSH can be
complex, requiring significant time and effort to understand and implement
compliant practices. As SMEs are likely to lack the necessary expertise and
manpower to comply with complex DNSH requirements, hiring external
consultants or dedicating existing staff to such activities can be a significant
burden. In some cases, adhering to the DNSH principle may require
substantial changes to existing business models, production processes, or
191
supply chains, which can be expensive and disruptive, even though a change
of business model to be DNSH compliant may also have a positive long-
lasting impact on the sustainability of the company’s business model.
Developing or adopting innovative solutions to align with complex DNSH
provisions may also require IT, and research and development capabilities,
that SMEs might not possess. Overall, while the DNSH principle aims to
promote sustainable practices, the costs and compliance challenges associated
with the heterogenous requirements – in place in the 2021-2027 period – can
disproportionately affect SMEs, potentially hindering their growth and
competitiveness in the market.
The adaptation of the sector-specific guidances developed under the 2021-
2027 period to the architecture and new programmes in the post-2027 MFF
would also trigger one-off costs linked to the transition required for MFF
beneficiaries – including businesses such as SMEs – to adapt to the new
guidances.
M1: Baseline –
Programme-specific
rules for defining
tracking methodologies
and performance
indicators
This option would result in programme-specific methodologies to track
expenditures supported by the EU budget, as well as multiple sets of
performance indicators across MFF programmes. Member States, partner
countries and beneficiaries – including businesses – would deal with multiple
expenditure tracking and indicators monitoring systems. The reporting burden
is expected to remain relatively high and generate costs associated with project
monitoring, though the new architecture of the post-2027 MFF and the
reduction of the number of EU budget programmes is expected to slightly
reduce reporting burdens.
Competitiveness: Maintaining a relatively heterogeneous and complex
approach to reporting performance via indicators in contracts or grant
agreements under EU budget programmes is expected to perpetuate
administrative burdens and hinder the competitiveness of economic sectors
and companies supported by EU budget programmes. Different – and
sometimes heavy – sets of indicators for each programme may create a
complex reporting environment, in particular for large organisations and
companies supported by various EU budget programmes. Under direct and
indirect management programmes, diverse reporting standards may require
beneficiaries to develop extensive data management infrastructures and
expertise to ensure compliance. This can lead to higher compliance costs
associated with hiring specialised staff or consultants and investing in multiple
reporting systems. Complex reporting frameworks may also increase the
likelihood of errors in data collection and reporting. Mistakes can lead to
compliance issues, delays in funding disbursement, and potential penalties,
negatively impacting financial stability and reputation of EU budget
beneficiaries. Overall, a complex reporting environment can limit the ability
of businesses to innovate, grow, and remain competitive in the global market.
Simplification and harmonisation of indicators reporting standards would
therefore be beneficial for beneficiaries, including businesses.
Small and Medium Enterprises: SMEs, which often operate with limited staff
and financial resources, can be disproportionately affected by the complexity
of indicators reporting requirements under EU budget programmes. The need
to comply with heavy requirements may divert resources from innovation and
business development, thus stifling growth potential. The complexity of
reporting requirements may also deter SMEs from participating in EU-funded
programmes. The perceived or actual administrative burden may outweigh the
benefits, restricting access to valuable funding opportunities.
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R1: Baseline –
Programme-specific
reporting requirements,
dashboards and portals
This option would result in maintaining the current costs linked to maintaining
a programme-specific approach to the reporting of performance information
across the EU budget, maintaining the current system of multiple dashboards
displaying performance information, and maintaining existing portals
informing beneficiaries about funding opportunities. This option is expected
to result in a continuation of the costs currently allocated by Member States,
budgetary authorities and interested stakeholders to having to navigate and
process multiple reports, dashboards and portals on the performance of EU
budget programmes and funding opportunities.
Competitiveness: Maintaining multiple portals displaying information on the
performance of EU budget programmes and funding opportunities is expected
to maintain the current costs of navigating and using several sources of
information, ultimately hindering the competitiveness of businesses supported
by EU budget programmes. This option is expected to rely upon several entry
points for relevant data and resources, maintaining potential navigation
challenges for businesses and resource implications related to the time and
effort spent searching for information across multiple platforms. Businesses
would continue to face costs associated with managing multiple accounts,
software tools, and consulting services needed to track and apply for diverse
funding opportunities. This option is therefore expected to maintain the
challenges observed during the 2021-207 period for beneficiaries – including
businesses – thereby limiting the competitiveness of economic sectors
supported by EU budget programmes both a European and global scale.
Small and Medium Enterprises: SMEs, which often operate with limited staff
and financial resources, are disproportionately affected by the complexity of
existing EU portals displaying information on funding opportunities. Under
this baseline option, SMEs would continue to face challenges in accessing
information, limiting their ability to be responsive to new support
opportunities and hindering their access to funding under EU budget
programmes.
For EU institutions:
Policy option Economic impacts
P1: Baseline –
Programme-specific rules
on DNSH and gender
equality
This option corresponds to using different DNSH requirements and guidances
across MFF programmes. This would require adapting the sector-specific
guidances developed under the 2021-2027 period to the architecture and new
programmes in the post-2027 MFF, which would trigger significant costs linked
to the development and implementation of such guidance by the Commission.
M1: Baseline –
Programme-specific rules
for defining tracking
methodologies and
performance indicators
This option would result in programme-specific methodologies to track
expenditures supported by the EU budget, as well as multiple sets of performance
indicators across MFF programmes. Having programme-specific methodologies
may allow a more granular monitoring tailored to specific programmes, and
indicators that are closely aligned with the intervention logic of each programme.
At the same time, such an approach would result in relatively significant costs and
administrative burden – in particular for the Commission – linked to the
development and management of several ad hoc methodologies to track
expenditures across programmes, as well as linked to the collection of data,
management and processing of a large number of heterogeneous and non-
aggregable performance indicators.
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R1: Baseline –
Programme-specific
reporting requirements,
dashboards and portals
This option would result in maintaining the cost observed in the 2021-2027 period
linked to multiple requirements on performance reporting, which would not enable
the Commission to achieve efficiency gains nor reduce the resources allocated to
preparing such reports, maintaining duplication of information and reporting
processes. It would also result in EU institutions – e.g. European Parliament –
continuing to face costs allocated to having to navigate and process multiple
reports on the performance of EU budget programmes. Maintaining the current
system would is likely to result in maintaining an intermediate level of
transparency and data utilisation for policy decisions.
This option would also result in a continuation of the costs linked to the
management of several online dashboards and portals displaying EU budget
performance information and information on available funding opportunities
centralising all information under the EU budget. This would maintain the costs
currently faced by the Commission to manage multiple dashboards and portals.
B. Social impacts
Policy option Social impacts
P1: Baseline –
Programme-specific
rules on DNSH and
gender equality
Under this option, gender equality mainstreaming provisions would be applied
at programme level. While progress has been made in integrating gender
equality into the 2021–2027 Multiannual Financial Framework (MFF), gender
mainstreaming would remain fragmented and inconsistent across
programmes. This reliance on heterogeneous tools such as earmarking and
conditionality has led to uneven results, with some initiatives achieving
notable success while others exhibit limited or no focus on gender equality.
This option risks perpetuating these challenges, undermining the EU’s broader
commitment to gender equality.
M1: Baseline –
Programme-specific
rules for defining
tracking methodologies
and performance
indicators
This option would result in programme-specific methodologies to track EU
budget expenditures supporting gender equality, as well as performance
indicators that cannot systematically be disaggregated by gender. This option
would therefore limit the Commission’s ability to achieve social outcomes as
it would make it more difficult to assess the contribution of EU budget
programmes to gender equality.
R1: Baseline –
Programme-specific
reporting requirements,
dashboards and portals
Maintaining multiple reporting requirements – through several performance
reports – would result in maintaining the level of transparency of information
regarding the performance of the EU budget observed during the 2021-2027
period, including regarding the EU budget contribution to social priorities
such as gender equality. Such an approach is likely to achieve no additional
social outcomes as it would not enable to increase access to information for
budgetary authorities and Member States on how the EU budget contributes
to gender equality, which may ultimately limit policymakers’ ability to adopt
more inclusive and equitable policies as part of the management of EU budget
programmes.
This option would also result in maintaining the level of access to information
on EU budget funding opportunities, through multiple portals. Access by
beneficiaries looking for support in the field of social objectives such as
equality – including gender equality – would be maintained as under the 2021-
2027 period, which is expected to have no positive social impact.
C. Environmental impacts
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Policy option Environmental impacts
P1: Baseline –
Programme-specific
rules on DNSH and
gender equality
Under this option, the complexity of DNSH requirements and guidances –
across EU budget programmes – is expected to result in uneven and
insufficient implementation of the DNSH principle across the EU budget.
Such a system is expected to lead to potentially detrimental environmental
effects and may increase the risk of support of potentially environmentally
harmful activities by the EU budget.
M1: Baseline –
Programme-specific
rules for defining
tracking methodologies
and performance
indicators
This option would result in programme-specific methodologies to track EU
budget expenditures supporting environmental objectives – such as climate
mitigation, adaptation, and biodiversity. This option would therefore limit the
Commission’s ability to achieve environmental outcomes as it would make it
more difficult to assess the contribution of EU budget programmes to
environmental objectives.
R1: Baseline –
Programme-specific
reporting requirements,
dashboards and portals
This policy option would result in maintaining the level of transparency of
information regarding the performance of the EU budget observed during the
2021-2027 period, including regarding the EU budget contribution to climate
mitigation, adaptation, and biodiversity.
This policy option would also result in maintaining the level of access to
information on EU budget funding opportunities, including for beneficiaries
looking for support in the field of environmental objectives.
2. Quantitative analysis of impacts of policy options
The analysis presents the estimated quantitative impacts of the policy options considered
in the context of the impact assessment of the performance framework for the post-2027
Multiannual Financial Framework. It aims at quantifying the impacts of each policy
option, the ultimate objective being to assess options 2 and 3 against the baseline i.e. option
1. This analysis of expected reductions of administrative costs supports the analysis of
efficiency of each policy option as presented under Section 7.2 of the impact assessment.
The analysis focuses on the costs of each policy option, and potential cost savings and
efficiency gains resulting from reduced administrative burden linked to a harmonised and
simplified performance framework across the EU budget. In contrast with impact
assessments linked to specific EU budget programmes, where investments impacts are
typically predicted based on macro-economic modelling, this quantitative analysis assesses
reductions of administrative costs and burdens for EU Member States, including national
administrations and beneficiaries. The analysis does not include an assessment of the
impacts of the policy options on non-EU countries supported by EU external action funds
due to a lack of available data, but it is expected that the policy options will also have
significant impacts on programming, monitoring and reporting requirements in partner
countries.
The quantitative analysis addresses the three dimensions of the impact assessment:
- programming and mainstreaming of horizontal priorities and principles: the
analysis focuses on the administrative burden linked to implementing the Do No
Significant Harm (DNSH) principle;
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- monitoring of performance: the analysis focuses on the administrative burden
linked to the monitoring of performance through a single list of intervention fields
and performance indicators;
- reporting of performance information: the analysis focuses on the administrative
burden linked to the development of a single portal displaying performance
information and funding opportunities available under the EU budget.
The quantitative impacts presented in this analysis are based on a set of assumptions and
estimates made by the Commission, derived from available data, and should be considered
indicative, considering the lack of available data. The actual impacts of policy options may
vary depending on future developments and the availability of new information.
A. Programming of horizontal priorities and principles
The policy options foresee three levels of harmonising DNSH requirements across the EU
budget, from a programme-based approach (P1) to a fully harmonised DNSH approach
across all programmes (P3).
The quantitative analysis focuses on the anticipated reduction of administrative burden for
Member States administrations 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. The analysis relies
upon a quantification of the number of full-time equivalent (FTE)113
employees or
consultants in charge of the operationalization of the DNSH principle in the 27 Member
States administrations for a duration of 7 years. Such operationalization tasks may include
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.
A reduction factor is applied to policy options P2 and P3, reflecting the expected
simplification of DNSH implementation and the corresponding decrease in administrative
burden. This reduction factor is an estimate by the Commission in the absence of quantified
data, reflecting the reduction of administrative burden achieved by reducing the number of
DNSH guidances and approaches, moving from a programme-based approach to a
harmonised activity-specific approach based on a single guidance applying to all EU
budget programmes. The single guidance reduces the risks of confusion and allows
projects to be subject to a single set of DNSH conditions irrespective of the programme
providing support. Compared to option P3, the reduction factor applied to policy option P2
further reflects the proportionate approach foreseen under this option, expected to further
reduce administrative burden. This includes the exemption of DNSH checks foreseen for
defence and security, and the differentiated operationalization per management mode and
type of action (internal vs. external) which is expected to further facilitate implementation.
113
The average cost of an FTE policy officer in EU Member State administrations is estimated at EUR 50,273
per year, based on Eurostat’s 2020 average hourly labour cost for public administration, reflecting variations
across EU Member States.
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The estimation also includes an entry costs factor corresponding to the costs of
transitioning to policy option 2 or 3. The entry cost factor attached to option P2 is lower
than the entry cost factor attached to option P3, because P3 would entail the development
of technical DNSH guidance by the Commission in consultation with Member States for
all interventions and sectors of the common list of intervention fields, and the deployment
and training of Member States covering the scope of such an extensive guidance.
Comparatively option P2 applies DNSH checks to less interventions and projects, entailing
lower entry costs for Member States.
Policy option P1
(baseline)
Policy option P2
(harmonised but
proportionate DNSH)
Policy option P3
(fully harmonised DNSH)
Number of EU Member
States: 27
Number of FTEs per year
and per MS: 18114
MFF duration (years): 7
Total cost: EUR 171
million
Number of EU Member
States: 27
Number of FTEs per year
and per MS: 18
MFF duration (years): 7
Reduction factor: 0.5115
Entry costs factor: 1.1
Total cost: EUR 94 million
Number of EU Member
States: 27
Number of FTEs per year and
per MS: 18
MFF duration (years): 7
Reduction factor: 0.8
Entry costs factor: 1.2
Total cost: EUR 151
million
Based on the above analysis, policy option P2 appears to deliver the greatest benefits
in terms of reducing costs linked to administrative burden.
114
The average number of 18 FTEs – per year and per Member State – corresponds to FTEs dedicated to
DNSH implementation for all EU budget programmes (including RRF, cohesion policy funds, InvestEU)
and for all national administrations i.e. both national and sub-national administrations of the Member States.
This estimation is based on an extrapolation of data from the Technical Support Instrument assistance in
implementing the DNSH principle in selected Member States (Spain, Italy, Cyprus) (source: SG REFORM).
115
The reduction factors applied to policy options P2 (0.5) and P3 (0.8) are assumptions based on estimations
by Commission services. These factors reflect anticipated efficiencies in administrative processes due to the
simplification and harmonisation of DNSH requirements, representing the best available estimate in the
absence of comprehensive data. The factors used in the case of options P2 and P3 reflect the expected
reduction of costs linked to programme-specific DNSH approaches and guidances from 13 in the 2021-2027
period to a single approach and guidance applying to all EU budget programmes post-2027. The factor
attached to option P3 could therefore have been set at 1/13, but this was considered as a strong
underestimation of costs due to uncompressible administrative costs below a certain number of DNSH
approaches, hence the factor was set at 0.8. The factor applied to P2 (0.5) reflects a further reduction of the
number of projects expected to be subject to DNSH compliance checks.
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Under policy options P2 and P3, significant reductions of administrative burden are also
expected at the level of EU budget beneficiaries, including businesses such as Small and
Medium Enterprises (SMEs), but quantifying such a reduction was not possible due to a
lack of available data. Significant cost reductions are nonetheless foreseen for
beneficiaries, as a simplified approach to DNSH would streamline compliance processes,
reduce the complexity and time required to navigate varying programme-specific
requirements, and lower the costs and resources needed for documentation, reporting, and
verification, facilitating access to EU budget programmes.
B. Monitoring of performance
The policy options foresee three levels of harmonising the monitoring of expenditures and
performance indicators across the EU budget, from a programme-based approach (M1) to
a fully harmonised list of intervention fields and performance indicators across all
programmes (M3).
The quantitative analysis focuses on the reduction of administrative burden expected to be
achieved by Member State administrations as a result of simplifying expenditure tracking
and indicator monitoring requirements. This is compared to the current programme-
specific approach, which relies on a large number of indicators under the various EU
budget programmes, requiring extensive monitoring and reporting. The analysis therefore
assesses the costs linked to each policy options in relation to a the tasks carried out by
Member States administrations, 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.
The analysis relies upon a quantification116
of the administrative costs linked to reporting
and monitoring tasks for the Common Provisions Regulation funds in the 2021-2027
period, extrapolated to the entire EU budget117
. The analysis would have ideally required
specific data on administrative costs for other EU budget programmes, including funds
under direct or indirect management, but such data was not available. A similar analysis
was conducted following a slightly different approach, based on the number of full-time
equivalent (FTE) employees or consultants in charge of the monitoring and reporting of
indicators, using the mid-term evaluation of the Recovery and Resilience Facility, which
led to results of a similar order of magnitude.
Similar to section A, a reduction factor is applied to policy options M2 and M3, reflecting
the expected simplification of expenditure tracking and reduction in the number of unique
indicators, e.g. from ca. 5 000 in the 2021-2027 period to ca. 900, resulting in a reduction
of the administrative burden. This reduction factor is an estimate by the Commission in the
116
Draft study ‘ASSESSMENT OF THE ADMINISTRATIVE COSTS AND ADMINISTRATIVE
BURDEN IN THE MANAGEMENT OF THE COMMON PROVISIONS REGULATION FUNDS 2021-
2027’ March 2025.
117
The size of the post-2027 MFF being unknown at the stage of drafting the impact assessment, the estimate
uses the size of the 2021-2027 MFF as a proxy for the size of the post-2027 MFF.
198
absence of further quantitative data, which captures expected efficiency gains, including
reduced data collection and quality control efforts through the adoption of standardised
metadata, the automatic processing of some indicators by the Commission, reduced follow-
up on Member States and an improvement in procedural clarity. The reduction factor used
in the case of option M3 is lower than the factor used for M2, because M3 is expected to
achieve significant higher reduction of the number of performance indicators and of the
administrative burden linked to performance monitoring across EU budget programmes.
The estimation also includes an entry cost factor corresponding to the costs of transitioning
to policy option M2 or M3. The entry cost factor attached to option M2 is lower than the
entry cost factor attached to option M3, reflecting higher costs of transitioning to a fully
harmonised system of performance monitoring.
Policy option M1
(baseline)
Policy option M2
(single list of intervention
fields, single non-mandatory
list of indicators + limited set
of common indicators)
Policy option M3
(single list of intervention fields,
fully harmonised list of indicators
+ limited set of common
indicators)
Estimated costs of reporting,
monitoring and evaluation, in
EUR per million EUR spent:
EUR 1 957
Ratio corresponding to
monitoring and reporting
costs: 2/3118
Size of 2021-2027 MFF:
EUR 1 074 000 million
Total cost: EUR 1 401
million
Estimated costs of reporting,
monitoring and evaluation, in
EUR per million EUR spent:
EUR 1 957
Ratio corresponding to
monitoring and reporting
costs: 2/3
Size of 2021-2027 MFF:
EUR 1 074 000 million
Costs reduction factor: 0.8119
Entry costs factor: 1.2
Estimated costs of reporting,
monitoring and evaluation, in
EUR per million EUR spent:
EUR 1 957
Ratio corresponding to
monitoring and reporting
costs: 2/3
Size of 2021-2027 MFF:
EUR 1 074 000 million
Costs reduction factor: 0.5
Entry costs factor: 1.3
118
This ratio corresponds to an assumption based on estimations by Commission services whereby, out of
the amount of EUR 1957 spent for the purpose of reporting, monitoring and evaluation per million EUR
spent, 2/3 is dedicated to the tasks in the scope of policy options M2 and M3 i.e. tracking of expenditures
and monitoring of indicators (including management and data collection).
119
The reduction factors applied to policy options M2 (0.8) and M3 (0.5) are assumptions based on
estimations by Commission services. These factors reflect anticipated efficiencies in administrative
processes due to the simplification and harmonisation of performance monitoring requirements, representing
the best available estimate in the absence of comprehensive data. The factor used in the case of option M3
reflects the expected reduction of costs linked to programme-specific monitoring approaches and sets of
indicators, reflecting a reduction of indicators from over 5 000 in the 2021-2027 period to less than 1 000
post-2027. The factor attached to option M3 could therefore have been set at 0,2, but this was considered as
a strong underestimation of costs due to uncompressible administrative costs below a certain amount of
indicators, hence the factor was set at 0.5. The factor applied to M2 (0.8) reflects a more limited expected
reduction of administrative burden due to the fact that programmes would keep the flexibility to adopt – a
potentially significant number of – programme-specific indicators in addition to the common list.
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Total cost: EUR 1 345
million
Total cost: EUR 911 million
Based on the above analysis, policy option M3 appears to offer the greatest benefits in
terms of reducing the costs associated to administrative burden.
Under policy options M2 and M3, significant reductions of administrative burden are also
expected at the level of EU budget beneficiaries, including businesses such as Small and
Medium Enterprises (SMEs), which would result from streamlined monitoring and
reporting requirements, in particular under direct management programmes. Quantifying
such a reduction of administrative burden was nonetheless not possible due to a lack of
available data. Significant cost reductions are nonetheless foreseen for beneficiaries, as
simplifying monitoring requirements under EU budget programmes would decrease the
number of indicators tracked, simplifying data collection and submission processes, and
saving time and resources, particularly for small businesses with limited capacity, reducing
resources required for extensive compliance documentation.
C. Reporting of performance information
This section focuses on dashboards enabling to report performance information and portals
displaying information on available funding opportunities.
1. Dashboards displaying performance information
The policy options foresee three levels of harmonising the reporting of performance
information across the EU budget, from a baseline situation whereby performance
information is displayed through several – often programme-specific – dashboards (R1) to
a single and fully harmonised dashboard (R3).
The quantitative analysis focuses on the reduction of costs linked to the development and
management of performance dashboards, expected to be achieved by the Commission as a
result of merging dashboards into a single one, compared to maintaining the current system
which relies on approximately 20 performance dashboards. The analysis is based on a
quantification of the costs of developing and maintaining performance dashboards, using
the costs of existing dashboards as a benchmark120
.
A factor is applied to policy option R2, to account for the expected costs linked to the
integration or development of specific pages displaying data related to dedicated areas and
sectors. The analysis also assumes higher annual management and maintenance costs per
dashboard in the case of a single – larger – dashboard than in the case of several – smaller
– dashboards.
Policy option R1 Policy option R2 Policy option R3
120
Including performance SAP BPC tool and dashboards (source: DG BUDG)
200
(baseline) (single dashboard with
harmonised performance
information across the EU
budget + pages displaying
specific data regarding
dedicated areas and sectors)
(single dashboard with fully
harmonised performance
information across the EU
budget)
Initial development costs:
EUR 0
Annual management costs
per portal: EUR 0.2 million
Number of portals: 20
MFF duration (years): 7
Total cost: EUR 28.0
million
Initial development costs:
EUR 0.65 million
Annual management costs
per portal: EUR 0.4 million
Number of portals: 1
MFF duration (years): 7
Factor reflecting the costs of
displaying specific data
regarding dedicated areas
and sectors121
: 2
Total cost: EUR 6.9 million
Initial development costs:
EUR 0.65 million
Annual management costs per
portal: EUR 0.4 million
Number of portals: 1
MFF duration (years): 7
Total cost: EUR 3.5 million
Based on the above analysis, policy option R3 appears to offer the greatest benefits in terms
of reducing costs associated with the development and maintenance of the performance
information dashboard.
Under policy options R2 and R3, significant reductions of administrative burden are also
expected at the level of Member States and budget authorities as well as beneficiaries and
stakeholders, which would benefit from facilitated access to performance information
compared to the current system which requires navigating several dashboards. Quantifying
such a reduction of administrative burden was nonetheless not possible due to a lack of
available data.
2. Portals displaying information on available funding opportunities
The policy options foresee three levels of harmonising portals displaying information on
available funding opportunities across the EU budget, from a baseline situation whereby
performance information is displayed through several – sometimes programme-specific –
portals (R1) to a single and fully harmonised portal replacing Member States portals (R3).
121
The factor applied to policy option R2 (2) is an assumption based on estimations by Commission services.
This factor reflects the expected increase of costs for the Commission to develop the necessary IT adaptations
so that the single dashboard would enable to display specific data regarding dedicated areas and sectors
supported by the EU budget.
201
The quantitative analysis focuses on the reduction of costs linked to the development and
management of portals expected to be achieved by the Commission as a result of merging
existing portals into one compared to maintaining the current system which relies upon ca.
12 portals on funding opportunities. The analysis relies upon a quantification of the costs
of developing and maintaining existing portals developed by the Commission, using as a
benchmark the costs of existing portals122
.
A factor is applied to policy option R3, reflecting the expected costs linked to the
integration of Member States portals into an EU-wide system, rather than a simple re-
direction towards Member States portals as foreseen under policy option R2. The analysis
also assumes higher annual management and maintenance costs per portal in the case of a
single – larger – portal than in the case of several – smaller – portals.
Policy option R1
(baseline)
Policy option R2
(single portal with
harmonised information on
funding opportunities across
the EU budget + redirection
to Member States portals)
Policy option R3
(single portal with harmonised
information on funding
opportunities across the EU
budget + integration of Member
States portals)
Initial development costs:
EUR 0
Annual management costs
per portal: EUR 0.5 million
Number of portals: 12
MFF duration (years): 7
Total cost: EUR 42 million
Initial development costs:
EUR 3 million
Annual management costs
per portal: EUR 1 million
Number of portals: 1
MFF duration (years): 7
Total cost: EUR 10 million
Initial development costs:
EUR 3 million
Annual management costs per
portal: EUR 1 million
Number of portals: 1
MFF duration (years): 7
Factor reflecting the expected
costs of the integration of
Member States portals into an
EU-wide system123
: 3
Total cost: EUR 30 million
Based on the above analysis, policy option R3 appears to deliver the greatest benefits in
terms of reducing costs associated with the development and maintenance of the funding
opportunities portal
122
Including Funding and Tenders portal and YourEurope (source: DG RTD, DG BUDG)
123
The factor applied to policy option R3 (3) is an assumption based on estimations by Commission services.
This factor reflects the expected increase of costs for the Commission to develop the necessary IT adaptations
so that the single portal would integrate Member States portals into an EU-wide system.
202
Under policy options R2 and R3, significant reductions of administrative burden are also
expected at the level of beneficiaries, which would benefit from facilitated access to
information on available funding opportunities across EU budget programmes compared
to the current system which requires navigating several portals. Quantifying such a
reduction of administrative burden was nonetheless not possible due to a lack of available
data.
3. Total costs of policy options on reporting
Policy option R1 Policy option R2 Policy option R3
Total cost: EUR 70.0 million Total cost: EUR 16.9 million Total cost: EUR 32.8 million
Overall policy option R2 appears to deliver the greatest benefits in terms of reducing
costs associated with the development and maintenance of the performance dashboard and
the funding opportunities portal.
D. Overview table of costs per policy option and percentage of reduction of
administrative burden costs
Policy
options
P. Programming and
mainstreaming
M. Monitoring R. Reporting
1
P1: EUR 171 million
0%
M1: EUR 1 401 million
0%
R1: EUR 70.0 million
0%
2
P2: EUR 94 million
45%
M2: EUR 1 345 million
4%
R2: EUR 16.9 million
77%
3
P3: EUR 151 million
12%
M3: EUR 911 million
40%
R3: EUR 32.8 million
57%
E. Sensitivity analysis
The above quantitative analysis should be nuanced due to the uncertainty attached to
certain assumptions used in the calculation:
- In contrast with impact assessments linked to specific EU budget programmes, where
impacts are typically predicted based on macro-economic modelling (RHOMOLO
model), the quantitative analysis of this impact assessment focuses on assessing
reductions of administrative costs for MS administrations. The analysis particularly
faced data availability limitations, as quantitative information on administrative burden
203
linked to performance is scarce beyond the qualitative findings of e.g. programmes
evaluations.
- The analysis is based on a combination of data available from studies and estimates by
Commission services, including reduction factors enabling to calculate expected
reductions of administrative costs for each policy option. Any variations in the
assumptions underpinning such factors is likely to have significant impacts on the costs
estimated for each policy option.
- While the quantitative analysis focused on assessing reductions of costs for EU
institutions and MS authorities, significant reductions of administrative burden are also
expected – from options P2, P3, M2, M3, R2, R3 – at the level of beneficiaries,
including businesses. Quantifying such reductions was nonetheless not possible due to
a lack of available data.
- The quantitative analysis would also have benefitted from data on the administrative
costs of monitoring performance in the case of direct and indirect management. These
shortcomings should be addressed in the future so as to fill the data gap, in particular
in the context of new Commission priorities and the commitment to reduce
administrative and reporting burden (cf. section 9).