REGULATORY SCRUTINY BOARD OPINION Impact assessment on the Global Europe instrument

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EUROPEAN COMMISSION
13.6.2025
SEC(2025) 548
REGULATORY SCRUTINY BOARD OPINION
Impact assessment on the Global Europe instrument
{COM(2025) 551 }
{SWD(2025) 552-553}
Offentligt
KOM (2025) 0551 - SEK-dokument
Europaudvalget 2025
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This opinion concerns a draft impact assessment which may differ from the final version.
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111
regulatory-scrutiny-board@ec.europa.eu
EUROPEAN COMMISSION
REGULATORY SCRUTINY BOARD
Brussels,
RSB
Opinion
Title: Impact assessment on the Global Europe instrument
(A) Policy context
The Global Europe Instrument is part of the post-2027 Multiannual Financial Framework
(MFF) package and will bring together several external policy funding instruments from
the current MFF (the NDICI-Global Europe, the IPA III, humanitarian aid, the Ukraine
facility and the Reform and growth facilities for the Western Balkans and Moldova) in
one framework in order to meet the challenges of an increasingly difficult, fragile and
volatile geopolitical context, while continuing to promote the EU’s interests and values.
Under the Commission’s Political Guidelines, the next MFF sets out to be more focused,
simpler and more impactful. Better Regulation Tool #9 acknowledges that ‘the special
case of preparing a new multiannual financial framework is a unique process requiring a
specific approach as regards scope and depth of analysis’. The architecture of the new
MFF will be significantly different from the current structure. Given that at this stage the
impact assessment lacks several key elements, the Board has decided, exceptionally, to
issue an Opinion without qualification.
(B) Key issues and recommendations
The Board notes the additional information provided and commitments to make
changes to the report. However, the report still contains significant shortcomings. The
Board makes the following recommendations for the lead Service(s) to rectify:
On scope and intervention logic: The intervention logic is not consistent with the issues
raised in the report. The scope of the report covers the implementation architecture
rather than the policy substance.
Unless the financial architecture is aligned with the policy objectives, desired synergies are
unlikely to materialise. Furthermore, without this, relevant result and impact indicators and
an evaluation and monitoring framework to allow for the effectiveness and efficiency of the
intervention to be evaluated in the future cannot be established.
Since the Global Europe Instrument is assumed to build on the current funding programmes
having redundancies, the report should analyse at least the baseline of the current funding
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landscape for external action, notably which parts of it should be discontinued or re-
oriented. The intervention logic should be revised to better account for the issues facing
external action funding. If the trade off between predictability/flexibility is demonstrated to
be the key problem, it should be unpacked and the current narrative revised, since the
options proposed in the report do not respond to the need of rebalancing this trade-off.
The report should give a clear indication of the current order of magnitude of the split
between programmed and non programmed funding and indicate why and in which areas
of external action this is a problem. It should analyse the need for a better alignment between
pre accession and neighbourhood funding in cases of backsliding as well as between country
programmed funding and humanitarian emergency aid in other contexts. It should clearly
set out other flexibility issues relating to: (i) the lack of a mechanism to revisit already
programmed funds; (ii) inflexibility arising from mainstreaming requirements; and (iii) the
rigidity of the structure of the budget for external programmes. The revision of the
intervention logic should better reflect the sub-objectives outlined under the specific
objectives and the formulation of additional policy options should be adjusted to align with
them, the specific and the general objective. The objectives should be defined in a
S.M.A.R.T. manner.
On the use of evaluations and the problem definition: The evidence base of the
problem description is not comprehensively developed and relies too heavily on
conclusions from previous evaluations that are not sufficiently substantiated by robust
evidence. The link between the problem definition, objectives and the options is
neither clear nor complete.
When referring to evaluations the report should clearly state the relevant conclusions
reached in those evaluations, and how strongly the conclusions are supported by a reliable
evidence base, taking also into account opinions from the RSB.
The problem definition should make clear which identified problems constitute societal
problems that justify a public intervention, and which problems are perceived shortcomings
of already existing public interventions. The problem description should also be revised and
made more granular to address better the challenges of effectiveness, predictability,
flexibility, coherence and simplification facing external funding. Additional evidence
should be presented to demonstrate the identified problems, and causal links between the
problems and problem drivers. Quantitative evidence should be presented on the magnitude
of identified problems. The public consultation should be better integrated throughout the
report including with a differentiation of stakeholders’ views and impacts on them.
On options: The options offer limited choice to policy makers and are not aligned with
and do not address all of the problems. The report does not assess whether the
tradeoffs between flexibility and predictability on the one hand, and complexity and
simplicity of the funding landscape on the other hand, provide sufficient analytical
dimensions to adequately identify options and fully assess their impacts.
The full range of measures and policy options needed to tackle identified problems and
achieve the objectives should be developed. The first is deficient while the remainder are
two variants of the same option addressing only one sub-problem (financing of Ukraine).
In addition, it is unclear how measures linked to “geographisation”, be it at country or at
regional level, would enhance the flexibility of non-programmable funding. Given that the
option of full programming has been discarded, logically so too should the first option (full
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flexibility) since it is inconsistent with the objective of adjusting the balance between
predictability and flexibility. The policy measures and their grouping into options should
be revised to align with an amended and more granular problem definition.
The analysis of impacts on key assessment criteria should also be revised. The report should
include more precise analysis of concrete measures, such as the use of financial instruments
and leveraging using private and public capital, performance-based funding and
governance, and propose options which best address key problems and identified objectives.
The issue of Ukraine should be addressed separately, not to be confused with other issues.
The report should discuss whether other analytical dimensions would be needed to establish
a full range of options and fully assess them, including how they contribute to the general
and specific objectives of the programme.
The report should clarify the preferred option, if any, and present a consistent basis for
policy decision makers. Annex 3 should be revised to focus on main categories of costs and
benefits and identify impacts on all relevant stakeholder groups.
On the analysis of unintended consequences: The report does not analyse the
unintended consequences that can result from the intervention, and in particular if they
can be adverse and entail costs for various stakeholders.
On governance: The report does not sufficiently describe the governance mechanisms.
It should clarify these, including how funding decisions will be taken, by whom and, at what
stage, in each of the policy options, and how the risk of policy dilution is addressed. It
should indicate criteria to be used for allocation decisions.
On coherence: The report does not specify how the Global Europe instrument fits with
wider objectives of other parts of the next MFF particularly on the link between
internal and external policies. Horizontal aspects vis-à-vis other MFF files should be
addressed throughout the report. This should cover monitoring, governance, coherence and
simplification as well as links with, in particular, the European Competitiveness Fund,
where further synergies are envisaged. It should also analyse how Global Europe will relate
to Member State interventions in the field of external action.
On future monitoring and evaluation: The report is unclear what monitoring and
evaluations arrangements will be put in place to measure the achievement of objectives
and EU budget impact. After defining the objectives in SMART terms the report should
outline appropriate evaluation and monitoring arrangements which would allow to monitor
the progress on achieving the objectives. The report should include a requirement for the
data plan which would ensure that different types of data building on appropriate methods
and modern tools for data collection, retrieval and analysis are available for the evaluation
of effectiveness, efficiency and EU added value without increasing administrative burden.
It report should be cleard how the specific indicators relevant to the objectives of the
instrument will be identified and used in the performance monitoring.
Some more technical comments have been sent directly to the lead Service(s).
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(C) Conclusion
The lead Service(s) should revise the report in accordance with the Board’s
recommendations before launching the interservice consultation.
Full title Impact assessment report accompanying the Commission
proposal for the basic act of the Global Europe instrument
Reference number 2025/MFF/03
Submitted to RSB on 14 May 2025
Date of RSB meeting 4 June 2025
Electronically signed on 13/06/2025 11:59 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121