Special Report The External Borders 
Fund has fostered 
financial solidarity  
but requires better 
measurement of results 
and needs to provide 
further EU added valueEN 2014  NO 15
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EN 2014  NO 15
Special Report The External Borders 
Fund has fostered 
financial solidarity 
but requires better 
measurement of results 
and needs to provide 
further EU added value
(pursuant to Article 287(4), second subparagraph, TFEU)
02
 Contents
Paragraph
 Glossary
I–VI  Executive summary
1–19  Introduction
1–10  The External Borders Fund
11–13  The EBF in context
14–19  Roles and responsibilities
20–24  Audit scope and approach
25–74  Observations
26–29  The EBF has contributed to external border management, but the  
overall result could not be measured and low implementation in some  
Member States limits impact
26–28  Programmes and projects geared towards the EBF’s priorities but the overall  
result could not be measured
29 Low implementation in some Member States
30–47  Whilst the EBF has fostered financial solidarity, further EU added value  
has been limited
32–34  Partially ineffective system for reinforcing specific priorities
35–40  Little support of operational cooperation between Member States
41–44  EBF mechanism to address specific weaknesses at strategic border points  
and emergency mechanism were partially effective
45–47  Support for projects which would have been financed nationally in any case,  
lacking a proper needs assessment or containing significant ineligible costs
03 Contents
48–65  Strategic and operational weaknesses in EBF programming and  
implementation at Member State and Commission level
49–51  Programmes not embedded in national strategies for border control and visas …
52–55  … lacking SMART objectives and measurable indicators
56–57  Annual programming requirements leading to excessive administrative  
burden and implementation difficulties
58–60  Some Member States’ project selection procedures did not ensure that  
their actual needs are met
61–65  Inadequate procurement procedures in Member States putting sound  
financial management at risk
66–74  Weaknesses in responsible authorities’ monitoring and serious  
deficiencies in the ex post  evaluations by the Commission and  
Members States do not allow an adequate assessment of the  
funds’ overall achievements
67–70  Lack of adequate monitoring and reporting of projects by Member States
71–74  Delays and serious deficiencies in the ex post  evaluations at both  
Member State and Commission level
75–83  Conclusions and recommendations
76–78  The EBF has contributed to external border management, but the overall  
result could not be measured  due to the lack of SMART objectives and  
serious  deficiencies in evaluation
79–80  The EBF has fostered financial solidarity but further EU added value has been limited
81 Strategic weaknesses in EBF programming 
82–83  Weaknesses in EBF implementation
 Annex — Audited projects
 Reply of the Commission
04
 Glossary
annual programme : A Member State’s work programme implementing its multiannual programme.
Community actions : EBF co-financed projects which support cooperation between Member States. Project themes 
are defined in the Commission’s annual work programme and call for proposals. Community actions are directly 
managed by the Commission and implemented by Member States.
DG Home Affairs : The directorate-general (DG) of the European Commission in charge of the policy area known as 
‘home affairs’.
emergency actions : EBF co-financed projects to support Member States in duly substantiated emergency 
situations requiring urgent action at external borders. Emergency actions are directly managed by the Commission 
and implemented by Member States.
EMSA : The European Maritime Safety Agency supports the European Commission and Member States in the 
development and implementation of EU legislation on maritime safety, pollution by ships and maritime security. 
It has also been given operational tasks in the field of oil pollution response, vessel monitoring and in long range 
identification and tracking of vessels.
EU added value : The value which the EBF creates which is additional to that which would otherwise have been 
created by Member States acting alone. This includes financial solidarity whereby Member States who bear, for 
the benefit of the EU, a heavier financial burden receive more funding. EU added value is further generated by 
supporting specific EU priorities, cooperation between Member States or targeting the most urgent problems 
i.e. the most threatened border areas.
eu-LISA : European Agency for the Operational Management of Large-Scale IT Systems in the Area of Freedom, 
Security and Justice.
Eurosur : The European Border Surveillance System provides a platform for information exchange and cooperation 
between Member States’ border control authorities, as well as with Frontex.
EUSatCen : The European Union Satellite Centre is an EU agency in the area of defence and security supporting 
decision-making of the European Union by providing analysis of satellite imagery and other data.
Frontex : European Agency for the Management of Operational Cooperation at the External Borders of the Member 
States of the European Union. Frontex coordinates Member States operations at border areas under significant 
migratory pressure, performs risk analysis and supports border guard training.
Internal Security Fund (ISF) Borders and Visas : The ISF Borders and Visas was established for the period 2014–20 
and incorporates the EBF.
management and control system : Set of procedures and practical arrangements for a Member State to implement 
the SOLID Funds.
SMART objectives : Objectives which are SMART are specific, measurable, achievable, relevant and timely.
05 Glossary
Schengen acquis : The common set of Schengen rules to be applied by Schengen states, including control at land, 
sea and air borders (airports), issuing of visas, police cooperation and protection of personal data.
Schengen area : An area consisting of 26 European countries that have abolished passport and immigration controls 
at their common borders. It consists of 22 EU Member States and the four member countries of the European Free 
Trade Association (EFTA).
Schengen Catalogue on External borders control, Return and readmission : Issued by the Council of the 
European Union, this contains recommendations and best practices in order to assist both Schengen Member States 
and Schengen Acceding States to apply the Schengen acquis correctly.
Schengen evaluations : Verifications carried out by the Council, checking whether the Schengen acquis  is 
correctly applied. Following the adoption of Council Regulation (EU) No 1053/2013 of 7 October 2013 establishing 
an evaluation and monitoring mechanism to verify the application of the Schengen acquis , the Commission will 
henceforth take the lead role.
Schengen information system (SIS II) : A large-scale IT system that is used by border guards as well as by police, 
customs, visa and judicial authorities throughout the Schengen area to exchange data such as information on 
persons who may have been involved in a serious crime or may not have the right to enter or stay in the EU.
SOLID programme : The ‘General programme on solidarity and management of migration flows for the 
period 2007–13’, consisting of four funds (European Fund for the Integration of Third-country Nationals, European 
Refugee Fund, European Return Fund and External Borders Fund). In this report the term ‘fund’ is used to refer to 
the External Borders Fund.
specific actions : Based on an annual work programme and directly managed by the Commission, specific actions 
should contribute to the development of the European integrated border management system by addressing 
weaknesses at strategic border points identified in a Frontex risk analysis.
visa information system (VIS) : A large-scale IT system that allows Schengen states to exchange visa data.
06
 Executive  
summary
I
The External Borders Fund (EBF) is the main EU 
financial instrument in support of external border 
management, amounting to 1,9 billion euro for the 
2007–13 period. The EBF’s overall aim is to help current 
and prospective Schengen states to ensure uniform, 
effective and efficient controls at their common exter -
nal borders.
II
The Court’s audit focused on processes related to the 
EBF’s effectiveness, EU added value and the achieve -
ment of the objectives of programmes and projects. It 
examined the design, programming and implementa -
tion, as well as the monitoring and evaluation.
III
The audit showed that the EBF has contributed to 
external border management and that it has fostered 
financial solidarity. However, further EU added value 
was limited and the overall result could not be meas -
ured due to weaknesses in the responsible authorities’ 
monitoring and serious deficiencies in the ex post 
evalu  ations by the Commission and the Member 
States.
IV
Member States’ programmes were not embedded in 
national strategies for border control and visas and 
lacked SMART objectives and measurable indicators. 
Project selection procedures did not ensure that the 
actual needs of the Member States were met and inad -
equate procurement procedures in Member States put 
sound financial management at risk.
V
The audit found serious weaknesses in management 
of the fund in key Member States (Greece, Spain, Italy 
and, for the early funding years, Malta). Low imple -
mentation in some countries limited the fund’s effec -
tiveness. These weaknesses lead to the risk that border 
management is not adequately strengthened where it 
is most needed.VI
The Court focuses its recommendation in four areas.
(a) Ensuring the availability of information on  
overall results  
Member States should set measurable targets 
for output, outcome and, where possible, impact 
indicators and indicators should be recorded from 
the start of the programme using appropriate IT 
systems. The Commission should ensure that its 
evaluation report presents stakeholders with an 
informed and timely analysis of underlying data.
(b) Increasing the EU added value of the fund  
The Commission should provide Frontex with 
relevant, comprehensive and timely information 
regarding implementation of the EBF, the Intern -
al Security Fund and subsequent instruments. 
The recording of co-financed assets in Frontex’s 
equipment pool should be made obligatory for 
those assets which might be useful to its needs. 
Furthermore, Member States and the Commission 
should concentrate more on establishing common 
application centres and other forms of consular 
cooperation rather than the renovation, adapta -
tion or equipping of consulates.
(c) Embedding the EBF in a national strategy 
for border management  
Member States should develop comprehensive 
national strategies on border management based 
on a risk analysis following the common inte -
grated risk analysis model and this should be an ex 
ante condition to receive support from the Internal 
Security Fund or subsequent instruments.
(d) Strengthening the implementation of the fund  
Administrative capacity, including in respect of 
procurement, should be strengthened, particularly 
in key Member States.
07
 Introduction
The External Borders 
Fund
01 
The External Borders Fund (EBF) is the 
main European Union (EU) financial in -
strument in support of external border 
management, amounting to 1,9 billion 
euro for the 2007–13 period1. Its overall 
aim is to help current and prospective 
Schengen states to ensure uniform, 
effective and efficient controls at the 
external borders of the Member States 
of the European Union.
02 
Within the Schengen area, internal 
controls have been abolished with the 
consequence that external border se -
curity of any one state affects all of the 
others. Due to the countries’ differing 
geographical situations, the responsi -
bilities for border controls vary con -
siderably. The EBF aims to establish 
financial solidarity between Member 
States2 by supporting those for which 
the control of the EU’s external borders 
represents a heavy burden.
03 
There are currently 28 Member States 
implementing the EBF (see Figure 1 ). 
All EU Member States except for the 
Ireland, Croatia, and UK participate in 
the EBF3.04 
The general aims of the EBF are to 
support:
(a) the efficient organisation of border 
controls;
(b) the efficient management of the 
flows of persons at the external 
borders, in conformity with the 
Schengen acquis  and the princi -
ples of respectful treatment and 
dignity;
(c) the uniform application of the rele -
vant EU legislation; and
(d) the improvement of Member 
States’ consular services in third 
countries as regards the flows of 
third-country nationals into the 
territory of the Member States and 
the cooperation between Member 
States in this regard.
05 
The EBF’s contribution to external bor -
der management is to be achieved by 
focusing on five priorities ( Figure 2 ). 
These have been defined by the Com -
mission in the ‘strategic guidelines’4. 
Member States have to address at least 
three of them in their EBF multiannual 
programmes. Within each of the five 
priorities, the Commission has identi -
fied a number of areas with particular 
importance to the EU (‘specific priori -
ties’) and for which the Member States 
can receive a higher EBF co-financing 
rate (see paragraph 9).1 Decision No 574/2007/EC of 
the European Parliament and 
of the Council of 23 May 2007 
establishing the External 
Borders Fund for the 
period 2007 to 2013 as part of 
the general programme 
‘Solidarity and management 
of migration flows’ (OJ L 144, 
6.6.2007, p. 22).
2 Based on established practice 
in this area the term ‘Member 
States’ in this report is used to 
mean the countries 
participating in the EBF, 
regardless of whether they are 
EU Member States or 
associated states.
3 Bulgaria and Romania have 
participated since 2010, as 
have three associated states 
(Iceland, Norway  and 
Switzerland).  Liechtenstein 
has paid a contribution to the 
fund since 2012 but waived 
the right to participate due to 
its lack of external borders and 
consulates. 
4 Commission Decision 
2007/599/EC of 
27 August 2007 implementing 
Decision No 574/2007/EC as 
regards the adoption of 
strategic guidelines for 2007 
to 2013 (OJ L 233, 5.9.2007, 
p. 3).
08 Introduction
Countries participating in the EBF
PortugalSpainFrance
GreeceItalyLuxembour gBelgiumNetherlands
Romania
Bulgaria
CyprusSwitz erland
CroatiaGerman yPoland
AustriaLiech tenst ein
Hungar yCzech Republic
Slovakia
SloveniaEstonia
Latvia
Lithuania
Ireland Unit ed
KingdomIceland
Finland
SwedenNorway
EBF participating state since 2007
EBF participating state since 2010, future Schengen state
EBF participating state since 2010 and Schengen state, but non-EU Member
EBF contributing but non-participating state since 2012
Non-EBF participating StateMaltaFigure 1
Source:  European Court of Auditors.
09 Introduction
EBF priorities and specific priorities 
Priority 1
Support for the further gradual establishment of 
the common integrated border management 
system as regards the checks on persons at and the 
surveillance of the external borders
Priority 2
Development and implementation of the 
national components of a European 
Surveillance System for the external borders 
and of a permanent European Patrol Network at 
the southern maritime borders of the EUPriorities Speci/f_ic priorities
  upgrading of the national communication systems to make them 
 interoperable with other Member States
 purchase/upgrading of interoperable equipment taking into account 
 the results of the common integrated risk analysis
 purchase/upgrading of equipment to contribute to Frontex operations
 establishing/upgrading a national coordination centre coordinating 
 all national authorities carrying out external border control tasks 
 establishing/upgrading a single national surveillance system of the 
 external border 
 purchase/upgrading of equipment for detection, identiﬁcation and 
 intervention at the borders provided the need has been clearly identiﬁed 
 at European level
 promoting cooperation between consular services within and between 
 Member States in the visa ﬁeld
 developing and establishing limited representation, co-location or 
 common visa application centres for reception and processing  of visa applications
 investments linked to the Schengen Information System (SIS)
 investments linked to the Visa Information System (VIS)
 implementing the common core curriculum for border guards’ 
 training at national level
 enhancing the quality of the national input into the common 
 integrated risk analysis model 
 
 
  
 
 
 
 
 
 Priority 3
Issuing of visas and tackling of illegal 
immigration by enhancing Member States’ 
consular and other services in third countries
Priority 4
Establishing IT systems required to implement 
the EU border and visa legislation
Priority 5
Eﬀective and eﬃcient application of relevant 
EU legal instruments in the ﬁeld of 
external borders and visasFigure 2
Source:  Based on Commission Decision 2007/599/EC.
10 Introduction
06 
Expenditure by priority for 2007–10 
is shown in Figure 3 . Based on the 
Member States’ plans for 2011–13, the 
allocation for priority 1 is expected to 
increase to 37 % while the allocation 
for priority 2 is expected to decrease 
to 36 %, the other priorities remaining 
stable.07 
The measures funded by the EBF 
include investment in infrastructure 
at border crossing points, purchase of 
equipment for intervention at borders 
(such as vehicles, boats and aircraft), 
cooperation initiatives in the field of 
consular services, investment in the 
Schengen information system (SIS) 
and visa information system (VIS), staff 
training, pilot projects and studies.Figure 3EBF expenditure annual programmes 2007–10 per priority1
National components of a European 
Surveillance System for the external border (Priority 2); 229 million euro; 42 %Gradual establishment of the common integrated border management system (Priority 1); 160 million euro; 29 % Visas and tackling of illegal immigration 
(Priority 3); 20 million euro; 4 %
IT systems in the /f_ield of external 
borders and visas 
(Priority 4); 104 million euro; 19 %
Eﬀective and eﬃcient application of 
EC  acquis on external borders and visas 
(Priority 5); 33 million euro; 6 %
1 The latest available final expenditure data concern the annual programme 2010. Due to the 2,5 year eligibility period, funds from this annual 
programme could be spent up until the end of June 2012 and had to be subsequently verified by Member States and the Commission. Reports 
on later annual programmes have not been finalised yet.
Source:  European Commission.
11 Introduction
08 
Under the EBF 7,3 % has been set aside 
for Community actions, which mainly 
support cooperation between Member 
States, emergency actions (as part of 
the Community actions) and specific 
actions which address weaknesses at 
strategic border points.
09 
The EBF’s basic contribution is 50 % of 
the total cost of actions or 75 % for ac -
tions in Cohesion Fund countries or in 
‘specific priority’ areas, rising to 80 % 
for specific actions and 90 % for Com -
munity and emergency actions.10 
Table 1  shows the allocations to 
national programmes, per Member 
State, and to Community, emergency 
and specific actions. The share of the 
biggest EBF recipients is illustrated in 
Figure 4 .Figure 4Member States’ share of EBF allocations
Greece, 13 %
France, 7 %
Slovenia, 3 %Finland , 3 %Hungar y, 4 %Romania, 4 %Poland , 4 %
Malta, 4 %German y, 5 %Italy , 16 %
Others (belo w 3 %), 19 %Spain, 18 %
Source:  European Commission.
12 Introduction Table 1EBF allocations from 2007 to 2013
Allocations 2007–13 in euro Share of total
Spain 289 394 768 17,92  %
Italy 250 178 433 15,49 %
Greece 207 816 755 12,87 %
France 116 220 276 7, 2 0  %
Germany 76 099 991 4,71 %
Poland 71 787 665 4,45 %
Malta 70 441 716 4,36 %
Romania159 467 068 3,68 %
Hungary 59 295 401 3,67 %
Finland 51 264 631 3,18 %
Slovenia 49 532 286 3,07 %
Bulgaria138 131 686 2,36 %
Netherlands 38 035 209 2,36 %
Lithuania231 674 480 1,96 %
Cyprus 30 017 404 1,86 %
Estonia 27 129 191 1,68 %
Portugal 23 948 902 1,48 %
Belgium 19 944 180 1,24 %
Switzerland117 677 832 1,09 %
Latvia 16 830 844 1,04 %
Czech Republic 15 853 542 0,98 %
Austria 13 875 936 0,86 %
Norway111 479 299 0,71 %
Sweden 10 887 663 0,67 %
Slovakia 8 675 910 0,54 %
Denmark 7 874 409 0,49 %
Luxembourg 598 220 0,04 %
Iceland1444 240 0,03 %
Total 1 614 577 936 100,00 %
Community/emergency actions 91 214 322
Specific actions 45 000 000
Special transit scheme Lithuania2108 000 000
Commission technical assistance 2 794 774
EBF total 1 861 587 032
1 Bulgaria, Iceland, Norway, Romania and Switzerland have participated in the EBF since 2010.
2 The allocation shown for Lithuania does not include the special transit scheme (STS). The STS is related to fees foregone and additional 
costs incurred due to the crossing of citizens of Russia to and from Kaliningrad region and amounts to 15 million euro annually for 2007–
10 and 16 million euro for 2011–13.
Source:  European Commission.
13 Introduction
The EBF in context
11 
Most expenditure related to external 
border management is funded nation -
ally5. Member States are responsible 
for the management of their external 
borders, applying the common rules 
established in the Schengen acquis . The European Agency for the Manage -
ment of Operational Cooperation at 
the External Borders of the Member 
States of the European Union (Frontex) 
coordinates cooperation between 
Member States and provides risk 
analyses and training. Thus the EBF 
is one piece of the jigsaw in the area 
of external border management (see 
Figure 5 ).5 Complete and reliable 
information on Member 
States’ national expenditure 
on external border 
management is not available. Figure 5Stakeholders and influences in the area of border management and visas
Member State actions 
ﬁnanced nationallyBORDER CONTROL AND VISAS
Actions of non-EU 
Member States
Council/Commission Schengen evaluationsExternal factors:
international conﬂicts
environmental disasters
economic crises
Return
EU cooperation 
with non-EU 
Member StatesMember State actions
funded by EBF
Member State actions funded 
by international funds
Frontex Member States  
working together
Other EU agencies:
eu-LISA, EUSatCen, EMSA
Integra tion Asylum
Source:  ECA.
14 Introduction
12 
The EBF is part of the ‘General pro -
gramme on solidarity and manage -
ment of migration flows for the 
period 2007–13’ (SOLID programme) 
managed by DG Home Affairs. The 
SOLID programme is designed to 
improve the management of migratory 
flows at EU level and to help share the 
financial burden resulting from the 
integrated management of common 
external borders and implementation 
of common policies on immigration 
and asylum6.
13 
External factors, such as the recent 
upheavals in north Africa, together 
with ongoing political and economic 
crises in other parts of the world, have 
resulted in massive migrant streams 
which have put considerable pressure 
on the EU’s external borders. Search 
and rescue operations are not among 
the EBF’s priorities, however in the 
course of border surveillance patrols 
EBF co-financed equipment can be 
(and has been) used for saving lives 
at sea.Roles and responsibilities
14 
The EBF is mainly implemented 
through shared management7. Ac-
cording to this principle, the Member 
States are responsible for the imple -
mentation (operational and financial) 
of the funded actions while the Com -
mission remains responsible for overall 
budget execution. The Commission 
adopts strategic guidelines setting out 
the EU programming framework. Each 
participating Member State prepares 
a multiannual programme applying 
these strategic guidelines on the basis 
of its own needs.
15 
The multiannual programme is imple -
mented through annual programmes. 
Both are subject to the Commission’s 
approval. Member States submit final 
reports after the completion of each 
annual programme.
16 
The Commission is also responsible 
for ensuring that the Member States 
have set up adequate management 
and control systems, that appropriate 
information, publicity and follow-up 
is provided for the funded projects 
and that actions are consistent with, 
and complementary to, other relevant 
Union policies and initiatives.6 Other elements of the SOLID 
programme are the European 
Refugee Fund (ERF); the 
European Fund for the 
integration of third-country 
nationals (EIF) and the 
European Return Fund. The EIF 
and ERF featured in the Court’s 
Special Report No 22/2012 
‘Do the European Integration 
Fund and European Refugee 
Fund contribute effectively to 
the integration of third-
country nationals?’  
(http://eca.europa.eu).
7 7,3 % of the fund has been 
managed directly by the 
Commission. The directly 
managed parts of the EBF 
include the Community 
actions, (including emergency 
actions) and specific actions. 
15 Introduction
17 
Member States’ implementation is 
monitored by the Commission through 
desk reviews of management and 
control systems descriptions and of 
progress and final reports and by audit 
and monitoring visits.
18 
At Member State level, the manage -
ment and control system comprises 
the following8.
(a) The responsible authority (RA), 
responsible for managing and 
implementing the multian -
nual programme. In particular, it 
submits multiannual and annual 
programmes to the Commission, 
selects operations and verifies 
the eligibility of the expenditure 
claimed by the final beneficiaries9.
(b) The audit authority (AA) performs 
audits to verify the functioning 
of the management and control 
systems10.
(c) The certifying authority (CA) certi -
fies that the expenditure declared 
complies with the applicable 
rules11 .
19 
The national co-financing can be 
subject to national control and audit 
depending on the Member State’s 
administrative procedures.8 The Court’s Special Report 
No 22/2012 found that the 
three-authorities structure led 
to disproportionate 
administrative burden. For the 
2014–20 justice and home 
affairs funds the Commission 
proposed to abolish the 
certifying authority.
9 Articles 28 and 29 of Decision 
No 574/2007/EC.
10 Article 32 of Decision 
No 574/2007/EC.
11 Article 31 of Decision 
No 574/2007/EC.
16
 Audit scope and  
approach
20 
The main audit question was to as -
sess whether the EBF has contributed 
effect  ively to external border manage -
ment. This has been broken down into 
the following sub-questions.
(a) Have the programmes and pro -
jects effectively supported the 
EBF’s priorities in external border 
management?
(b) Has the EBF provided financial 
solidarity between Member States 
and addressed the fund’s specific 
priorities, and thereby delivered 
EU added value?
(c) Have the EBF’s programming 
and implementation proced -
ures contributed to the fund’s 
effectiveness?
(d) Are the Member States and the 
Commission using monitoring and 
evaluation appropriately to im -
prove the effectiveness of the EBF?
21 
The audit covered:
(a) the shared management parts of 
the EBF managed and implement -
ed by Member States; and
(b) the Community actions (including 
emergency actions) and specific 
actions directly managed by the 
Commission and implemented by 
Member States.22 
The audit focused on processes related 
to the EBF’s effectiveness, EU added 
value and the achievement of the ob -
jectives of projects and programmes. 
It sought to examine the design, 
programming and implementation as 
well as the monitoring and evaluation 
of EBF-funded measures. The audit 
did not perform a detailed analysis of 
the management and control sys -
tems in the Member States12, nor did 
it undertake a direct measurement of 
impact achieved through EBF-funded 
measures, but based its assessment on 
monitoring and evaluation data from 
Member States and the Commission.
23 
The audit was based on;
(a) a documentary review of the multi -
annual and annual programmes’ 
final reports (covering the 2007–
10 programmes) and contributions 
to the evaluations of five selected 
Member States13, Commission 
reports on the allocation of resour -
ces, the Commission’s intermediate 
report on results achieved and its 
draft ex post  evaluation; Council 
documents and selected Frontex 
studies and documents;
(b) interviews and the collection of in -
formation on the spot at the level 
of the Commission, the responsible 
authorities and final beneficiaries 
in the five selected Member States; 
interviews were also conducted 
with other stakeholders, such 
as the Council in the case of the 
Schengen evaluations14, Frontex 
and the EU Agency for Fundamen -
tal Rights;12 The management and control 
system of SOLID funds 
featured in Special Report 
No 22/2012. 
13 Greece, Spain, Italy, Malta and 
Poland. The selection of 
Member States was based on 
the EBF allocation; a risk 
assessment based on 
information from Commission 
audits and monitoring reports 
as well as information from 
Frontex; and the need for 
a balance between the main 
external border risk areas in 
the Mediterranean and the 
eastern border, since around 
60 % of the EBF goes to the 
southern border 
(Mediterranean and Spain’s 
Canary Islands) and 
approximately 25 % to the 
eastern border. Together the 
selected Member States 
represent 55 % of the total EBF 
allocation. 
14 The Schengen evaluations are 
verifications that the 
Schengen rules are correctly 
applied by current and future 
Schengen states. The 
Schengen evaluations were 
carried out by the Council as 
an intergovernmental process. 
Based on the adoption of 
Council Regulation 
(EU) No 1053/2013 of 
7 October 2013 establishing 
an evaluation and monitoring 
mechanism to verify the 
application of the Schengen 
acquis and repealing the 
Decision of the Executive 
Committee of 
16 September 1998 setting up 
a standing committee on the 
evaluation and 
implementation of Schengen 
(OJ L 295, 6.11.2013, p. 27), the 
Commission will take the lead 
role.
17 Audit scope and approach 
(c) on-the-spot visits to 31 completed 
projects in the selected Member 
States based on a judgmental 
(non-random) sample (see Annex ) 
covering annual programmes 
from 2007 to 2010;
(d) a desk review of seven completed 
projects15 directly managed by 
the Commission based on a judg -
mental (non-random) sample 
covering annual work programmes 
from 2007 to 2011 (see Annex );
(e) a separate audit16 that took place 
in one of the selected Member 
States (Spain) that touched on 
the EBF.24 
The audit was carried out against 
the background of the Commission’s 
proposals for the 2014–20 funding 
period, which will create the Internal 
Security Fund as a successor to the 
EBF17, providing for financial sup -
port for the management of external 
borders and visas. The proposals will 
involve changes in both content and 
the management and control system. 
Where relevant, these proposals were 
taken into account in this audit.15 Three emergency action 
projects, two other 
Community action projects, 
two specific action projects.
16 In the framework of the 
Court’s 2013 statement of 
assurance.
17  Regulation (EU) No 515/2014 
of the European Parliament 
and of the Council of 16 April 
2014 establishing, as part of 
the Internal Security Fund, the 
instrument for financial 
support for external borders 
and visa and repealing 
Decision No 574/2007/EC 
(OJ L 150, 20.5.2014, p. 143).
18
 Observations
25 
The Court presents its main audit find -
ings in four sections. The first section 
shows that the EBF has contributed to 
external border management but the 
overall result could not be measured. 
The second section focuses on the 
EBF fostering financial solidarity and 
its EU added value. Programming and 
implementation are discussed in the 
third section. Finally, monitoring and 
evaluation are dealt with in the fourth 
section.
The EBF has contributed 
to external border man -
agement, but the overall 
result could not be meas -
ured and low implemen -
tation in some Member 
States limits impact
Programmes and projects 
geared towards the EBF’s pri -
orities but the overall result 
could not be measured
26 
Multiannual programmes and an -
nual programmes in the five selected 
Member States were generally in line 
with, and contributed to, all five EBF 
priorities ( Figure 2 ). However, given 
the weaknesses in the monitoring 
in these Member States and serious 
deficiencies in the ex post  evaluations 
(see paragraphs 71 to 73) at both 
Member State and Commission level, it 
was not possible for the Court to make 
an adequate assessment of the fund’s 
overall achievements.27 
Most audited projects supported the 
achievement of the EBF’s priorities. 
Out of 31 projects audited on the 
spot (see Annex ) in the five selected 
Member States, five supported the EBF 
priorities only partially (because they 
included project expenditure which 
was ineligible18 or relevance of that 
expenditure to the EBF could not be 
determined)19. One further project’s20 
contribution to achieving the priori -
ties went against the EBF’s aims21 by 
not complying with the principle of 
respectful treatment and dignity (see 
paragraph 60).
28 
Most projects achieved their intended 
output but measurable targets and 
indicators were not set (see para -
graphs 52 to 54) and reports did not 
adequately demonstrate the outcome 
and impact achieved (see Figure 6  
for examples of output, outcome and 
impact indicators).18 A proposal for fuel vouchers 
was accepted by the 
Commission although 
contrary to the guidelines 
issued to Member States at the 
time. These guidelines were 
amended retrospectively 
in 2012.
19 Member States’ projects 
Nos 2, 9, 19, 21, 22 in the 
Annex .
20 Member States’ project No 25 
in the Annex .
21 Article 3(1)(b) of Decision 
No 574/2007/EC.
19 Observations
Low implementation in some 
Member States
29 
The average implementation rate of 
the EBF national programmes 2007–10 
was 87,6 %. However problems existed 
in a small number of Member States 
(Figure 7 ). In particular this is the 
case in Greece where planning and 
implementation failed to the extent 
that only 43 % of its EBF allocation was 
implemented22.22 According to the final reports 
of Greece’s annual 
programmes. Impac tInput
Output
Outcome• EBF and national funds mobilised for the implementation of an action (project).
• That which is accomplished directly with the money allocated to an action. 
For example: the purchase of aircraft, document veri/f_ication machines, etc.
• Change that arises from the implementation of an action. Outcomes include results achieved with the output. For example: patrol missions /f_lown by the aircraft or documents veri/f_ied at the borders.
• Final, high-level eﬀects of the action (long term). These are subject to a wide range of other (external) in/f_luences. For example, aircraft used in patrol missions lead to the detection of irregular migration activities, veri/f_ication of documents lead to an increase in the detection of false documents presented at borders.Examples of output, outcome and impact indicatorsFigure 6
Source:  ECA examples, based on the Commission’s model whereby results are referred to as outcomes.
20 Observations Figure 7EBF implementation rate 2007–10
30 % 40 % 50 % 60 % 70 % 80 % 90 % 100 %Greece
Czech Republic
Netherlands
Denmark
Bulgaria
Hungary
Sweden
Portugal
Slovenia
Belgium
Romania
France
Iceland
Poland
Finland
Malta
Austria
Lithuania
Italy
Slovakia
Spain
Latvia
Estonia
Norway
Cyprus
Germany
Average
Source:  Calculation made by the Commission in the framework of the ex post  evaluation on both closed programmes and, where programmes 
were not closed, on estimations by Member States. Bulgaria, Iceland, Norway and Romania provided data only for 2010 annual programmes. 
Denmark and Poland did not provide data on 2010 programme implementation. The implementation rates for Cyprus and the Czech Republic 
were not final. Denmark did not provide implementation rates for total budget. No data for Luxembourg and Switzerland. The Greek figure is 
based on the final reports of its annual programmes.
21 Observations
Whilst the EBF has fos -
tered financial solidarity, 
further EU added value 
has been limited
30 
The Court sought to establish whether 
the EBF’s aim of fostering financial 
solidarity was achieved. It also sought 
evidence that the EBF delivered further 
EU added value, notably by targeting 
the specific priorities (see Figure 2 ), 
supporting cooperation between 
Member States or by being directed at 
the most urgent problems.
31 
The EBF allocations clearly helped to 
spread the Member States’ financial 
burden caused by the introduction of 
the Union’s integrated management 
of common external borders. Member 
States having a higher relative burden receive higher EBF aid (see Figure 4 ). 
However, the Court found that the 
EBF’s further EU added value was lim -
ited due to:
(a) a partially ineffective system for 
reinforcing specific priorities;
(b)  little support of operational 
co operation between Member 
States;
(c) ill-designed mechanisms for re -
sponding to specific weaknesses 
at strategic border points and 
partially effective mechanisms to 
respond to emergencies; and
(d) the support of programmes and 
projects which would have been 
financed nationally in any case, 
lacking a proper needs assessment 
or containing significant ineli -
gible costs in some of the projects 
audited.Photo 1Three EBF co-financed class 300 all-weather vessels of the 
Italian Coast Guard operating from Lampedusa, Italy
Source:  ECA.

22 Observations
Partially ineffective system for 
reinforcing specific priorities
32 
The Commission has drawn up stra -
tegic guidelines to define priorities, 
complemented by specific priorities 
for implementing the EBF in the Mem -
ber States which have EU added value 
and to provide incentives therefor. 
Projects supporting specific prior -
ities such as SIS, VIS ( Box 1 ), consular 
cooperation and Eurosur were eli -
gible for a higher co-financing rate. 
However, this incentive (75 % instead 
of the standard 50 %) is ineffective 
in the 15 Cohesion Fund countries23 
(which account for approximately 60 % 
of EBF allocation) because they re -
ceive 75 % co-financing anyway. Some 
Member States (Spain and Malta) 
confirmed that specific priorities 
were not a factor in designing their 
programmes.
33 
In addition, three out of 12 specific 
priorities had not been clearly formu -
lated by the Commission24 or lacked practicality, further limiting their 
ability to deliver EU added value. 
Since the 2011 annual programmes, 
the Commission has tried to focus EBF 
funding on specific priorities but, due 
to a lack of monitoring, there is no evi -
dence that this has increased their use.
34 
However, due to the lack of a system 
for monitoring the use of specific 
priorities and a reliable and adequate 
ex post  evaluation at Commission level, 
the full extent of support for actions 
with ‘high’ EU added value could not 
be determined by the Court.
Little support of operational 
cooperation between  
Member States
35 
In two specific areas where the EBF 
was intended to support cooperation 
between Member States, namely con -
sular cooperation and Frontex oper -
ations, limited results were achieved.23 Four of the five Member States 
selected for the Court’s audit 
are Cohesion Fund countries.
24 For example a specific priority 
on the purchase of equipment 
stated that the need for such 
equipment had to be ‘clearly 
identified at European level’. 
However the Court found that 
the meaning of this 
requirement was not clear to 
the Commission or Member 
States.
EBF contribution to SIS II and VIS
Despite the lack of monitoring the Court found evidence of the EBF’s contribution to the specific priorities 
establishing the SIS II and VIS IT systems. During its on-the-spot visits to such projects the Court found that 
EBF support was deemed to be crucial to the development of the national systems25. However, the delays and 
changes in IT systems at EU level26 impacted on the EBF’s efficiency and effectiveness since amendments had 
to be carried out and equipment purchased could not be used27.
25 Of the estimated 330 million euro cost of developing national systems, the EBF contributed 95 million euro.
26 Court of Auditors Special Report No 3/2014 ‘Lessons from the European Commission’s development of the second generation Schengen 
information system (SIS II)’ (http://eca.europa.eu).
27 For example, 110 handheld devices (50 personal digital assistants (PDAs) financed out of AP 2007 and 60 out of 2008) could not be used by police 
patrols to connect to SIS II because the planned security solution was not practicable and SIS II was not ready. In 2014 the Maltese authorities 
were working on resolving this problem.Box 1
23 Observations
36 
The goal of the EBF (within its prior -
ity 3) to fund the development of 
consular cooperation, and common 
application centres in particular, has 
only been achieved to a limited extent 
despite the 90 % co-financing rates 
available under Community actions. 
Only two common applications cen -
tres were funded (see Box 2  for one 
example) and only one Member State 
(France) planned a consular cooper -
ation project through other forms of 
cooperation (such as colocation or out -
sourcing). Instead, Member States used 
the EBF to renovate, adapt and equip 
their own national consulates — some -
times in the same countries. The use 
of the EBF in such a manner failed to 
exploit economies of scale and benefit 
from cooperation between Member 
States to improve visa application pro -
cedures and prevent visa fraud.
37 
The second area of cooperation where 
the EBF had only a limited impact is 
the support of  operations coordinated 
by Frontex through the increase in the 
number of assets at its disposal .  The strategic guidelines contain a spe -
cific priority which was designed to 
reinforce Frontex’s operational capa -
city. However, as with other specific 
priorities, the incentive mechanism 
had little effect (see paragraph 32) and 
its results have not been measured.
38 
The Court verified whether EBF co-
financed assets were recorded in the 
Frontex equipment pool. This would 
support Frontex in its planning and 
implementation of (joint) opera -
tions ( Box 3 ). Even though many EBF 
co-financed assets would be suitable 
for Frontex missions, there is no legal 
obligation to record EBF co-financed 
equipment in the equipment pool. 
The Court found that only two out 
of a sample of 16 aircraft and patrol 
vessels were so recorded. This limits 
Frontex’s ability to plan and imple -
ment (joint) operations.
‘Maison Schengen’ common applications centre in Kinshasa, Democratic Republic 
of the Congo
Financed by two Community action projects (2007 and 2009, total EBF funding 845 704 euro), the Belgian–
Portuguese initiative’s aim was to create the first Schengen common visa application centre. Each participat -
ing Member State remains responsible for the back-office processing. However, the application processes are 
centralised, allowing multiple Member States to pool and share resources. This centralisation supports better, 
more efficient and more humane reception of visa applicants and the fight against ‘visa shopping’28 and fraud. 
At the end of 2013, the centre represented 17 Schengen states.
28 The practice of submitting further visa applications to other EU Member States when a first application has been rejected.Box 2
24 Observations
39 
Moreover, in spite of the Commis -
sion’s legal obligation and Frontex’s 
requests, Frontex did not receive any 
information from the Commission on 
the implementation of the fund (such 
as assets purchased) until June 2013, 
thereby further limiting its planning 
and operational ability and its checks 
to prevent double-financing of oper -
ational costs.
40 
For the period 2014–20, the Commis -
sion has proposed to incentivise only 
two priorities of national programmes, 
by increasing EU co-financing to 90 % 
and by providing additional funding. Specific actions are abolished. The 
priorities to be incentivised are the 
ones where the Court found limited 
EU added value, namely consular 
cooper  ation and the fund’s contribu -
tion to Frontex operations. While the 
enhanced involvement of Frontex is 
planned in the fund’s management, 
comprehensive information exchange 
between the agency and the Commis -
sion in both shared and direct man -
agement-programme implementation 
is not envisaged. In addition, there is 
still no general obligation that EBF-
funded assets should be entered into 
the Frontex technical equipment pool.Example of good practice putting assets at the disposal of Frontex operations
The two assets in the Court’s sample registered in Frontex’ equipment pool were aircraft of the Armed Forces 
of Malta.
Despite facing regular migration pressure itself, Malta made one of its EBF-procured surveillance aircraft avail -
able for 90 hours for a specific Frontex joint operation in Spain in October 2012.Box 3
Photo 2  
Fixed-wing maritime patrol aircraft co-financed 
by the EBF to enhance the border control 
capabilities of the Armed Forces of Malta
© Armed Forces of Malta.

25 Observations
EBF mechanism to address 
specific weaknesses at  
strategic border points and 
emergency mechanism were 
partially effective
41 
One element of the EBF’s potential EU 
added value is its ability to be directed 
at the most urgent problems, which 
are typically the most threatened 
border areas or general emergency 
situations. In order to judge the effect -
iveness of the EBF’s mechanism to re -
spond to emergencies and to address 
specific weaknesses at strategic border 
points, the Court examined the rele -
vant funding streams of the EBF. The 
audit showed that the specific actions 
were used as a simple ‘top-up’ for the Member States’ annual programmes. 
The Member States and the Commis -
sion failed to ensure coordination 
between these different parts of the 
EBF, resulting in the loss of an over -
view of which project is funded, where 
and why.
42 
Furthermore, the Court found that part 
of the emergency actions were used 
for non-emergency situations or were 
poorly managed (see Box 4 ).
Partially effective system of funding for emergencies at the external borders
Case 1: Supporting actions which were not emergencies
The 2011 emergency actions were entirely used for eight projects totalling about 7,5 million euro to support 
Member States in their final stages of SIS II development, even though that project had begun in 2001. More -
over, in one case the expenditure had already been financed by the Member State.
Case 2: Example of poor management of emergency projects
The 2010 emergency actions consisted of three projects granted to Italy for about 4 million euro to deal with 
the migration inflow due to the Arab Spring, of which the Court audited two. One of these projects was to 
fund internal transportation of migrants29. Its application did not contain any reference to the number of 
migrants that could be transported, making assessment of value for money impossible. The actual number 
of migrants transported was not reported and was only submitted after a specific request from the Commis -
sion, without information on the transportation time targets set or any other details which would enable the 
project to be evaluated. In addition, only half of the project budget was implemented and no reasons for this 
were given in the project’s final report. The other audited project30 also suffered from a lack of quantifiable 
targets and appropriate reporting.
29 Project No 3 (‘Internal transportation of migrants (Shifts)’).
30 Project No 2 (‘Reinforcement of transportation means to patrol the border crossing points area and the area close to the CIE (Recars)’) under 
emergency actions, see Annex .Box 4
26 Observations
43 
Under the EBF 10 million euro was 
available annually for projects address -
ing specific weaknesses at strategic 
border points. These specific actions 
were not included in the Commis -
sion’s EBF proposal but inserted by 
the Council. The procedure to select 
the projects was lengthy and the 
implementation period (6 months) 
was far too short for projects involving 
procurement of specialised equipment such as helicopters, resulting in a low 
implementation rate. Greece, for ex -
ample, despite its needs, was not able 
to implement nine out of 11 approved 
projects under 2008–10 specific action 
programmes. Of the two Italian spe -
cific action projects audited in detail, 
the Court found that some elements 
were used outside the border areas 
and others were completely outside 
the EBF’s scope (see Box 5 ).
Specific actions used outside the border area
The Court examined one project from the 2009 specific actions and one from 2010. Both were implemented 
by the Italian Ministry of the Interior, the end user of the equipment being the police.
2009 specific actions: Six months’ rental of vehicles to be used at the Italian southern maritime borders
The project responded to the call for tenders which specified the territorial scope as ‘the maritime border 
of Italy (Mediterranean Sea and Sicilian Sea)’. The grant application stated that the project would ‘increase 
the effectiveness of surveillance activity in the ports area and coastline of the central Mediterranean region’. 
However all 137 cars were delivered to CIEs (identification and expulsion centres) located as far north as Turin, 
Milan and Bologna and were not involved in surveillance of the external border. The Commission nevertheless 
approved the costs (final grant amount 950 688 euro).
2010 specific actions: Border patrolling
The project planned to purchase police vehicles (the application is inconsistent as to how many cars should 
be purchased and their use) for patrolling the maritime borders in the south of Italy and especially the south-
western coastline. However the vehicles were used close to the CIEs31 and CARAs (asylum and refugee centres). 
In the evaluation of the final report the Commission noted that the allocation of 22 of 43 vehicles purchased 
 under the project was not in line with the territorial scope of the call for proposals as they were used (as 
above) in/around CIEs and CARAs. The related costs (337 405 euro) were subsequently considered ineligible by 
the Commission (final grant amount 560 259 euro out of 1 192 559 euro approved).
31 CIEs and CARAs are located throughout Italy, both in coastal areas and inland.Box 5
27 Observations
44 
Given these inherent design restric -
tions in the legislation and the imple -
mentation problems, the Commission 
took the decision not to carry out any 
specific actions in 2013.
Support for projects which 
would have been financed 
nationally in any case,  
lacking a proper needs 
assessment or containing 
significant ineligible costs
45 
The Court found that, in two of the five 
Member States in the Court’s sample 
(Greece and Spain), many projects had 
already been financed, or would have 
been financed, nationally in any case 
at the time they were included in the 
annual programmes. This was also the 
case for one of the three audited emer -
gency actions, where the project appli -
cation already stated that the Member 
State had set the budget aside to fully 
finance it. Although the fund’s rules 
allow this practice and it increases the 
implementation rate, the replacement 
of national expenditure of a Member 
State by EU funds would put at risk any 
EU added value. In the cases identified 
above there was no EU added value.46 
In three Member States in the Court’s 
sample (Greece, Italy and Poland) the 
EU added value of certain projects 
could not be established due to the 
lack of an adequate assessment of the 
needs the projects aimed to address. 
In two Member States (Greece and 
Italy), the fund had limited EU added 
value since some projects consisted 
of operating support such as fuel and 
consumables for equipment rather 
than building the Member States’ ca -
pacity in external border management. 
While support for such costs is permit -
ted and might be justified in emer -
gency situations, the fund is intended 
to support principally the building of 
capacity32, e.g. through infrastructure 
or procurement of equipment, not to 
finance running costs.
47 
The EU added value of the EBF is 
further limited by the high amount of 
ineligible costs in some of the projects 
audited, resulting from expenses that 
are not in line with the fund’s prior -
ities or from equipment not working 
or operating as or where it should. In 
most cases found by the Court, these 
irregularities were not detected by 
the national management and control 
systems in place (for examples relative 
to paragraphs 45 to 47 see Box 6 ).32 See Articles 3 and 4 of 
Decision No 574/2007/EC and 
Commission note to the SOLID 
Committee 18 October 2010.
28 Observations
Examples of projects with low or unknown EU added value
Funding projects already financed
A Greek project to procure 75 police patrol and passenger vehicles was included in a revision to Greece’s 2009 
annual programme in March 2011, after the vehicles had been acquired and financed from the national 
budget.
Lack of needs assessment and ineligible costs
In Italy, the Court audited a project (2010 annual programme) procuring 355 operational vehicles for the 
Guardia di Finanza for their tasks on the detection and identification of immigrants at sea borders. The final 
beneficiary could not fully demonstrate how the number of vehicles needed was determined or on what basis 
they had been allocated to the different units. The numbers bought under the project increased primarily due 
to extra funds being available. The Court found cars are also used for ‘regular’ police work.
In view of the lack of a needs assessment for the 355 vehicles and the fact that Italy purchased a total of 
1 084 vehicles under the 2007–10 annual programmes, there is a risk that EBF financing is spent on projects 
not responding to EBF priorities and that urgent needs are not met.
In another Italian project which was set up to extend software and fibre-optic cable infrastructure between 
police offices in central and northern Italy the Court was provided with contradictory information by the 
Italian authorities on the costs of the overall investment and on how the eligible costs were calculated. As 
a result it was unable to determine the extent to which the 22 million euro declared as eligible costs (to be co-
financed 50 % by the EBF) in the 2007 annual programme was related to the EBF.
Similar problems were found in Malta for a 2007 annual programme project totalling approximately 
540 000 euro where the Member State was not able to demonstrate why certain costs (mainly relating to 
building works) were apportioned to the project.Box 6
29 Observations
Strategic and operational 
weaknesses in EBF  
programming and imple -
mentation at Member 
State and Commission 
level
48 
The Court assessed key processes 
for the fund’s effectiveness, namely 
programming and project selection, 
and found that programmes are not 
embedded in national strategies and 
lack SMART objectives and measurable 
indicators. Programming requirements 
lead to an excessive administrative 
burden. In certain Member States, 
project selection procedures did not 
adequately ensure that the Member 
States’ needs were met. In addition, 
the audit found weaknesses in pro -
curement procedures, putting finan -
cial management at risk. Photo 3A police patrol vehicle in Greece co-financed by EBF
Source:  ECA.

30 Observations
Programmes not embedded 
in national strategies for  
border control and visas …
49 
In the selected Member States, the 
Court examined whether the multi -
annual programme and the annual 
programmes were based on a national 
strategy for border management and 
visa matters and if they were coord -
inated with national, other EU and 
international funds. According to the 
third version of the Schengen cata -
logue on external borders control, 
return and readmission such a strategy 
‘should clearly delegate tasks’ and in -
clude ‘the assessments of the working 
environment, risks and threats, analy -
ses of resources needed, as well as 
action and development plans’. Only 
when such a comprehensive assess -
ment exists can maximum efficiency 
and effectiveness be obtained from 
the EBF. The Court also analysed, on 
the basis of the Schengen evalu  ations, 
whether such a national strategy was 
based on the common integrated risk 
analysis model (CIRAM)33 assessing 
relative risks posed by different threats 
for border and visa management.
50 
In four out of the five Member States 
in the Court’s sample (that is, ex -
cept Poland) the Court found that 
the multiannual programme and, as 
a result, the annual programmes are 
not embedded in a comprehensive 
strategy, simply because no such 
strategy  exists. While there were many 
individual strategy papers, these often remained confined to a single 
authority. Although the multiannual 
programmes were obliged to contain 
a section on complementarity be -
tween national and EBF funding, the 
Court found that explanations were 
incomplete or non-existent. In all five 
Member States a common integrated 
risk analysis is only in the develop -
ment stage or is not used at all. This 
lack of a comprehensive view based 
on a risk analysis means that neither 
the Commission nor Member States 
can objectively determine whether the 
measures financed by the EBF fit into 
the general strategy of the Member 
States or target actual needs, and why 
they were selected to be financed by 
the EBF.
51 
In three Member States (Spain, Malta 
and Poland) the Court found evidence 
that the EBF was not appropriately 
coordinated with other EU funds34 or 
with other international funds35. This 
risks a loss in efficiency and effec -
tiveness for the funds involved since 
they could each be targeting similar 
actions.
... lacking SMART objectives 
and measurable indicators
52 
The Court examined whether multian -
nual and annual programmes and pro -
jects included SMART objectives and 
indicators which are relevant, measur -
able and paired with a target value.33 Risk analysis model developed 
by Frontex and Member 
States, used by Frontex and 
recommended for Member 
States’ use.
34 For example the European 
Regional Development Fund 
(ERDF).
35 For example US support for 
border management projects.
31 Observations
53 
The five Member States in the Court’s 
sample did not include SMART object -
ives and measurable indicators in their 
multiannual and annual programmes 
or projects. Most programme and pro -
ject descriptions lacked target  values. 
In addition, in Greece targets for 
the 2008, 2009 and 2010 annual pro -
grammes were only set after the pro -
jects had been implemented, thereby 
making them redundant. An analysis 
of 2012 annual programmes showed 
improvements in the formulation of in -
dicators for three Member States, but 
for two of these no progress was made 
on establishing targets for indicators.54 
Although it can be difficult to estab -
lish outcome and impact indicators 
for border management and visas, the 
Commission has shown in guidance 
notes that it is possible. Due to the 
absence of obligatory common indica -
tors, Member States used differing sets 
of indicators, not only between pro -
grammes but also for similar measures, 
making proper evaluation impossible. 
Despite the low quality of the object -
ives and indicators in the Member 
States’ programmes, the Commission 
nevertheless approved them, in view 
of the need to implement the fund 
(see Box 7 ).
Examples of vague and inappropriate indicators
One project consisted of the procurement of two medium-sized vessels for sea patrols and was funded by 
the Spanish 2008 annual programme. Similar to other audited projects in Spain36, the Court found indicators 
which were not relevant, not recorded and/or set without appropriate consultation with the final beneficiary 
by the responsible authority.
The ‘expected results’ of the project were very vague and mostly without explanation as to how they could 
be measured e.g. ‘enhanced efficacy and efficiency of the resources dedicated to sea patrol missions’, ‘better 
security conditions on missions’ and ‘greater border security’. The only measurable expected result was a ‘re -
duction in the number of vessels illegally reaching Spanish-European coasts’. However, the difficulty with this 
indicator is that the causal link between action and results needs to be carefully examined.
36 Member States’ projects Nos 7, 8, 9, 11 and 12 in the Annex.Box 7
32 Observations
55 
The Commission has already reacted 
to some of the weaknesses caused 
by the lack of common indicators by 
proposing obligatory common indica -
tors for the funding period 2014–20. 
Member States will have to develop 
programme-specific indicators.
Annual programming 
requirements leading to an 
excessive administrative 
burden and implementation 
difficulties
56 
While the intention was tighter 
 supervision of the programmes put in 
place by the responsible authorities, 
the requirement to produce annual 
programmes in addition to multian -
nual programmes led to an excessive 
administrative burden at both Member 
State and Commission level as well as 
significant delays. The initial submis -
sion of poor quality programmes by 
the Member States — frequently not 
respecting the requirements set out 
in the legal bases — caused delays in 
approval of annual programmes. The 
time lag between the first submis -
sion and the final version of annual 
programmes averaged 6½ months. As 
a result, the implementation time for 
projects was often severely reduced.
57 
The EBF’s annual programmes also 
did not fit well with the lengthy 
procurement procedures needed for 
sophisticated equipment. As a result, 
projects were delayed or could not be 
financed by the fund. In recognition 
of the abovementioned difficulties, 
only multiannual programmes will be 
established in the 2014–20 funding 
period.Some Member States’  
project selection procedures 
did not ensure that their 
actual needs are met
58 
The Court examined the procedure 
used by Member States to select 
projects. Serious weaknesses in the 
project selection procedures were 
found in Italy and, for the early years 
only, in Malta, putting into question 
whether the most relevant projects 
were selected.
59 
In Italy, allocation of funds between 
public entities and subsequent project 
selection had several flaws. Due to 
a complete lack of audit trail, the Court 
could not verify on what basis the 
allocation between final beneficiaries 
was decided for the 2007 and 2008 an -
nual programmes. For later years, 
the reasons given by the responsible 
authority for the distribution of the al -
location were either misleading or not 
subsequently applied to the distribu -
tion of the resources. As a result, the 
increasingly high allocation for the 
Ministry of the Interior — Department 
of Public Security — Central Directo -
rate for Immigration and Border Police 
— the body in which the responsible 
authority is housed — to the detri -
ment of other bodies such as the Coast 
Guard could not be justified. The same 
ministry was also the only Italian body 
to have benefited from emergency 
and specific actions between 2007 
and 2012, even though several other 
forces (under different ministries) are 
involved in Italy’s border management. 
The exclusion or marginalisation of the 
other authorities risks that their needs 
are not met.
33 Observations
60 
The selection and subsequent fund -
ing of a temporary detention centre in 
Greece did not comply with the princi -
ple of respectful treatment and dignity 
(see Box 8 ).
Funding for a detention centre in Greece
The Court examined the rental costs of a temporary detention centre at Pagani (also known as the Mytilini 
Special Facility for Irregular Migrants) on the island of Lesbos. The project was implemented by the responsi -
ble authority (Ministry of Public Order and Citizen Protection).
The responsible authority included the project in a late revision to the 2008 annual programme, for ‘hosting 
of migrants in hotels and rooms’. However, what was actually financed was the rent of the Pagani centre from 
1 January 2008 to 30 June 2010 at a total cost of 267 405 euro.
The centre was repeatedly criticised by human rights organisations for its poor conditions. Originally a stor -
age site for goods, it was converted to accommodate 300 persons. In 2008, there were 720 migrants detained 
in the facility. Conditions were described as ‘abominable’ and ‘a health hazard for staff and detainees alike’37. 
In October 2009, upon visiting the centre, UNHCR called for the centre to be shut down. Between late Octo -
ber 2009 and June 2010 the centre was gradually deactivated.
At the time of the decision to fund the project, the unacceptable conditions were widely known. The Greek 
authorities, however, provided a misleading project description to the Commission, which, upon analysis of 
the final report, now plans to deduct the expenditure from the final payment.
37 Report to the government of Greece on the visit to Greece carried out by the European Committee for the Prevention of Torture and Inhuman or 
Degrading Treatment or Punishment (CPT) from 23 to 29 September 2008 (CPT/INF (2009)20).Box 8
Inadequate procurement 
procedures in Member States 
putting sound financial  
management at risk
61 
The Court audited the procurement 
procedures in 11 projects. In eight of 
these the procedures did not satisfy the relevant legal provisions or were 
conducted in a way which did not 
ensure that value for money was 
achieved. One procurement proced -
ure, the acquisition of patrol dogs 
in Greece, failed completely due to 
an inadequate procedure. Although 
the 40 vehicles were delivered in 
May 2012, the dogs had not been pro -
cured as at June 2014.
34 Observations
62 
The main weakness was the fact 
that three Member States did not 
adequately justify their use of the 
exception clause for defence and 
security procurements. For example, 
under its 2007 annual programme, 
Spain procured two fixed-wing aircraft 
for maritime patrols and the fight 
against irregular immigration at a cost 
of 50 million euro. The Spanish au -
thorities declared the procurement to 
be ‘secret’ and used the negotiated 
procedure without prior publication, 
inviting only one supplier. Less re -
strictive procedures could have been 
used without compromising security. 
In other Member States similar pro -
curements were made using open 
tendering.
63 
Other weaknesses in procurement 
procedures were the subsequent use 
of the same supplier without adequate 
competition and a lack of capacity and 
knowledge of public administration.
64 
The responsible authorities’ verifica -
tion of procurement procedures in 
four out of the five Member States 
(all except Poland) was inadequate or 
non-existent despite large parts of EBF 
being spent using procurement.65 
As a result, there is a risk that high-
value actions in certain programmes 
of the EBF, such as the procurement of 
aircraft and vessels, may not provide 
value for money.
Weaknesses in 
responsible authorities’ 
monitoring and serious 
deficiencies in the ex post 
evaluations by the 
Commission and Member 
States do not allow an 
adequate assessment of 
the fund’s overall 
achievements
66 
The Court sought to determine 
 whether Member States and the Com -
mission use monitoring and evaluation 
to assess and improve the effective -
ness of the EBF. It found that moni -
toring and evaluation were seriously 
constrained by the lack of SMART 
objectives and measurable indica -
tors, that there is a lack of adequate 
monitoring and reporting of projects 
at Member State level and that evalu -
ation is delayed and suffers from ser -
ious deficiencies.
35 Observations
Lack of adequate monitoring 
and reporting of projects by 
Member States
67 
In all of the Member States in the 
Court’s sample, the responsible 
authority did not carry out sufficient 
and/or adequate monitoring which 
would have enabled it to follow the 
implementation of projects and 
determine deviations from set object -
ives. Where they existed, monitoring reports lacked important informa -
tion such as results achieved against 
indicators or targets set or significant 
changes in the project execution 
stage. In Greece, there was no moni -
toring during project implementation 
for 2007–09 because projects were 
generally introduced into the annual 
programme after they had been car -
ried out. Although some on-the-spot 
checks were carried out, no checklists 
were available to show that qualita -
tive aspects of funded projects were 
verified.Photo 4An EBF co-financed cabin on the Spanish–Moroccan 
 border in El Tarajal, Ceuta
Source:  ECA.

36 Observations
68 
In all five Member States, both at pro -
ject level and for annual programmes, 
the final reports did not report sat -
isfactorily on indicators or targets 
achieved. In three Member States 
there were several inconsistencies and 
errors in the final reports impacting 
on the reliability of the data. Spain did 
not require final project reports until 
the 2010 annual programme and only 
started monitoring during implemen -
tation from the 2009 annual pro -
gramme. At the time of the audit (Feb -
ruary 2014), Greece still did not require 
final project reports, which seriously 
restricts the information available on 
the project results achieved. Italy’s 
responsible authority has announced 
its intention to introduce monitoring 
visits as a result of the Court’s audit.
69 
None of the Member States in the 
Court’s sample had set up an appropri -
ate IT system from the start of the fund 
to record indicators. While three Mem -
ber States (Spain, Italy and Malta) have 
started developing an IT system that 
supports the RA management in the 
second half of the funding period, only 
the Italian system has a function that 
allows indicators and their values to be 
recorded. The Commission’s guidance 
did not explain the benefits of such IT 
systems and opportunities for ex -
change of best practices were lost.
70 
The reporting by Member States 
on Community actions and specific 
actions shows a similar lack of infor -
mation on results achieved, often 
failing to include even the most basic 
information.Delays and serious deficien -
cies in the ex post  evalu -
ations at both Member State 
and Commission level
71 
The Commission, in partnership with 
the Member States, is responsible 
for evaluating the fund in order to 
assess the relevance, effectiveness 
and impact of its actions. The first of 
the two ex post  evaluations, cover -
ing 2007–10, was due to be delivered 
by the Commission to the European 
Parliament and other institutions by 
31 December 2012.
72 
The Court analysed the contributions 
of the Member States in the Court’s 
sample to this evaluation and found 
a series of omissions, errors and 
inaccuracies in all five national evalu -
ation reports. As a result, the reliabil -
ity of the overall ex post  evaluation 
report is significantly reduced. Part 
of the reason for the limited amount 
of quantified information provided 
by the Member States was that the 
type of data to be reported was only 
established by the Commission in 2011. 
By this point all actions for inclusion 
in the evaluation had started and 
most had finished, and consequently 
Member States’ were unable to adapt 
indicators to be collected. This led to 
a general weakness in the quality of 
quantitative information presented in 
the evaluation, as well as inefficiency 
and additional work in compiling data 
retroactively.
37 Observations
73 
In analysing the Commission’s ex post  
evaluation report, the Court found 
summaries of a large amount of both 
qualitative and quantitative informa -
tion which had been collected from 
the Member States. However, the 
presentation of the data is descrip -
tive in nature, without analysis of their 
significance. For example, data are pre -
sented without any useful baseline or 
benchmark information or in a format 
which does not offer additional under -
standing (e.g. ‘number of systems ac -
quired or upgraded’). Furthermore, the 
evaluation omits to deal with Commu -
nity actions, emergency actions and 
specific actions, thereby further dimin -
ishing its value. Consequently, the ex 
post evaluation cannot be considered 
a useful or reliable report to assess the 
effective impact of the EBF.74 
Despite an extended deadline, only 
eight out of the 28 Member States sent 
their contribution to the Commission 
on time, thereby encroaching upon 
the time available for the Commission 
and its external contractor to work 
with the data. Delays also occurred at 
Commission level. At the time of the 
conclusion of the Court’s audit work 
(March 2014), and more than 1 year 
after the deadline, the report had not 
yet been adopted by the Commission, 
limiting the availability of information 
for EBF stakeholders.
38
 Conclusions and 
recommendations
75 
The audit showed that the EBF has 
contributed to external border man -
agement and fostered financial soli -
darity. However its further EU added 
value was limited, overall results could 
not be measured due to weaknesses in 
the responsible authorities’ monitoring 
and there were serious deficiencies in 
the ex post  evaluations by the Commis -
sion and the Member States. Crucially, 
the audit found serious weaknesses 
in the management of the fund in key 
Member States, i.e. in Greece, Spain, 
Italy and, for the early funding years, 
Malta. These weaknesses carry the 
risk that border management is not 
adequately strengthened where it is 
most needed.
The EBF has contributed to 
external border manage -
ment, but the overall result 
could not be measured due 
to the lack of SMART object -
ives and serious deficiencies 
in evaluation
76 
The Court found that it was not able 
to assess the extent to which the EBF 
has supported the fund’s priorities. 
Member States’ programmes lacked 
SMART objectives and measurable 
indicators which, together with the 
lack of common indicators, made 
proper evaluation by the Commission 
impossible. Despite the low quality 
of the objectives and indicators, the 
Commission approved the Member 
States’ programmes in view of the 
need to implement the fund (see 
paragraphs 53 to 54).77 
Responsible authorities did not or only 
insufficiently monitored the achieve -
ment of results. Monitoring and final 
reports lacked relevant information 
on effectiveness and/or information 
was unreliable. None of the Member 
States in the Court’s sample had an 
IT system to collect monitoring data 
from the start. Only Italy was develop -
ing such a system for future use (see 
paragraph 72). The Member States’ 
contributions to the ex post evaluation 
and the Commission’s report suffered 
delays and had serious deficiencies 
(see paragraph 73).
78 
The Commission has proposed ob -
ligatory common indicators for the 
2014–20 funding period and Member 
States will have to develop their own 
programme-specific indicators.
Recommendation 1
The Commission should:
— ensure that all indicators to be 
used are relevant, measurable and, 
where possible, paired with a tar -
get value;
— ensure that indicators are collected 
from the start and, where not al -
ready in place, that IT systems are 
developed;
39 Conclusions and recommendations
— provide clear guidelines to Mem -
ber States so that they have a com -
mon understanding of obligatory 
indicators so that aggregation for 
monitoring and evaluation pur -
poses will be possible;
— deliver its evaluation report on 
time and present stakeholders 
with an analysis of underlying 
data.
Recommendation 2
Member States should:
— have appropriate expertise avail -
able in the administration for 
the design and application of 
SMART objectives and measurable 
indicators;
— set targets for output, outcome 
and, where possible, impact 
indicators;
— collect actual values of indicators 
from the start of the programme 
using appropriate IT systems and 
ensure that information is reliable;
— apply their experience with similar 
IT systems gained in the Structural 
Funds field.The EBF has fostered finan -
cial solidarity but further EU 
added value has been limited
79 
The Court found that the EBF helped 
to spread the Member States’ financial 
burden arising from the integrated 
management of external borders but 
that further EU added value of the 
fund was limited:
(a) in consular cooperation;
(b) in support of Frontex operations;
(c) on emergency actions and specific 
actions;
(d) by funding actions which were 
or would have been financed 
nationally.
The fund’s full potential was not 
exploited due to weaknesses in the 
design of the incentive system.
80 
 For the period 2014–20, the Commis -
sion has proposed to incentivise con -
sular cooperation and the fund’s con -
tribution to Frontex operations. While 
the enhanced involvement of Frontex 
is planned in the fund’s management, 
comprehensive information exchange 
between the Agency and the Commis -
sion in both shared and direct man -
agement programme implementation 
is not envisaged. In addition, there is 
still no general obligation that EBF/ISF 
funded assets which would be of use 
to Frontex should be entered into the 
Frontex technical equipment pool.
40 Conclusions and recommendations
Recommendation 3
To support consular cooperation:
— the Member States and Commis -
sion should concentrate more on 
establishing common application 
centres and other forms of con -
sular cooperation rather than the 
renovation, adaptation or equip -
ping of consulates.
Recommendation 4
To support the work of Frontex:
— the legislator should consider mak -
ing the entering of relevant ISF co-
financed assets into  Frontex’s tech -
nical equipment pool obligatory;
— the Commission should provide 
Frontex with relevant, compre -
hensive and timely information 
regarding EBF/ISF implementation 
in the Member States, such as pro -
grammes, annual implementation 
reports and evaluations, as well as 
information on directly managed 
programmes and projects. Infor -
mation should take into account 
the option of ‘operating support’ 
introduced with the new 2014–
20 framework and a robust system 
to avoid double funding needs to 
be put in place.Strategic weaknesses in EBF 
programming
81 
The audit found that four out of five 
Member States do not programme the 
EBF as part of their comprehensive 
national strategy on border and visa 
management. In all Member States in 
the Court’s sample a common integrat -
ed risk analysis is only under develop -
ment or is not used at all.
Recommendation 5
The national EBF programmes should 
be based on a comprehensive strategy 
for border management, with Member 
States basing their strategy on a risk 
analysis using the CIRAM.
Recommendation 6
The legislator should consider making 
compliance with Schengen catalogue 
recommendations on strategy and risk 
analysis an ex ante  condition for receiv -
ing future ISF support.
41 Conclusions and recommendations
Weaknesses in EBF 
implementation
82 
In the three principal recipient Mem -
ber States (Greece, Spain and Italy) the 
Court found recurrent deficiencies in 
EBF planning, implementation, moni -
toring and evaluation, impacting on 
the effectiveness of the EBF.
83 
In the Member States in the Court’s 
sample (apart from Poland) the Court 
found inadequate procurement pro -
cedures which put the sound financial 
management of the fund at risk.Recommendation 7
Administrative capacity needs to be 
strengthened, for example through 
focused training by the Commission or 
through sharing best practices be -
tween Member States.
Recommendation 8
Member States should strengthen ad -
ministrative capacity in procurement 
and carry out the procurement of EBF/
ISF assets through the most transpar -
ent procedures available.
This Report was adopted by Chamber IV, headed by Mr Milan Martin CVIKL, 
Member of the Court of Auditors, in Luxembourg at its meeting of 24 June 2014.
 For the Court of Auditors
 Vítor Manuel da SILVA CALDEIRA
 President

42
 Annex AnnexAudited projects
Final beneficiary Project nameAnnual 
programmeTotal final EBF 
expenditure 
in euro1
Malta
1 Malta Police — Police 
Immigration SectionStrengthening of Immigration Police capacity for border surveillance and patrols 
The aim of this project was to enhance the operational capabilities and 
surveillance possibilities of the Immigration Police, particularly in combating the 
phenomenon of illegal immigration by providing the necessary equipment.2007 491 567
2 VISET Malta plc Bringing the sea passenger terminals in line with the Schengen acquis 
requirements (VISET)
The project’s objective was to bring the passenger handling facilities at the Port 
of Valletta in line with the Schengen acquis  requirements and best practices.2007 540 234
3 Ministry of Foreign Affairs Setting up a new high-risk/high-volume mission and its preparation for 
capturing biometrics
The aim of this project was to fully refurbish the recently acquired premises 
housing the new consular section in Moscow. The refurbishment project was 
intended to include the necessary security features and enable the mission to 
prepare itself for eventual biometric capture.2007 285 335
4 Armed Forces of Malta Procurement of inshore patrol vessels for the Armed Forces of Malta
The project provided the Armed Forces of Malta with replacement inshore patrol 
craft in order to have enhanced presence at sea and more rapid intervention 
capabilities.2008 7 200  000
5 Malta Police Migration from SIS1 to SIS2 and from SIReNE1to SIReNE2
The overall objective was to finalise the final chapter of the integration of the 
Schengen information system II with national police systems.2008 2 037 810
6 Armed Forces of Malta Enhancing the border control capabilities of the Armed Forces of Malta — 
Procurement of a fixed-wing maritime patrol aircraft
The aim of this project was to enhance the border control capabilities with the 
procurement of a fixed-wing maritime patrol aircraft.2009 7 269 636
1 The figures shown for Greece are those verified and reported by the RA. They have not been approved by the Commission yet.
43 Annex Annex
Final beneficiary Project nameAnnual 
programmeTotal final EBF 
expenditure 
in euro1
Spain
7 Ministry of the Interior: DG for 
Infrastructures and Material 
for SecurityTechnical support for the Schengen information system
Specialised technical support for the Schengen information system, for the 
correction, perfection and evolution of this system.2010 129 129
8 Ministry of the Interior: 
National Police Corps, part of 
the Directorate-General for 
National Police and Guardia 
CivilAcquisition of operational equipment for external border control
The purpose of the action was to provide the border  crossing points with state-
of-the-art equipment (such as equipment for document inspection or UV lamps) 
in order to increase the quality and efficiency of border control.2007 274 885
9 Ministry of the Interior: 
Directorate-General for 
Infrastructures and Material 
for Security (DGIMS)Acquisition of two medium-sized vessels for sea patrol (20 metre)
This acquisition aimed to enhance the surveillance and intervention capacity 
of the Guardia Civil Maritime Service at sea, permitting the Maritime Service 
to successfully complete its missions, especially the fight against illegal 
immigration, by allowing swift action within territorial waters. These patrol 
vessels were planned to be used in the Mediterranean coastal area. 2008 2 143 680
10 Ministry of the Interior: 
Directorate-General for 
Infrastructures and Material 
for Security (DGIMS)Work and refurbishment of the cabin filters of the border crossing in El Tarajal in 
the city of Ceuta
Works and refurbishment supporting National Police Corps officers’ work on 
access and exit control of the persons in the national territory.2010 36 426
11 Ministry of the Interior: 
Directorate-General for 
Infrastructures and Material 
for Security (DGIMS)Refurbishing, upgrading and reconstruction works in the border perimeter 
between Spain and Morocco (Ceuta and Melilla)
This project supported the funding of CCTV camera equipment, border-drainage 
facilities, turnstiles in Ceuta and also a watchtower in Melilla.2010 164 386
12 Ministry of the Interior: 
Directorate-General of the 
Police and Civil Guard, area 
Civil GuardUpgrading for the two aircraft for maritime patrol and fight against irregular 
immigration, bound for the Air Service of the Guardia Civil (bought under the EBF 
annual programme 2007)
The purchase of the two aircraft was co-financed under the EBF 2007 annual 
programme and had an overall contract value of 50 million euro. This purchase 
was also included in the Court’s audit of the subsequent upgrade project.
According to the annual programme 2010, ‘the aircraft, due to numerous 
surveillance hours, need an upgrade for them to be able to perform surveillance 
activities, such as structural upgrade works and the acquisition of basic spare 
par t s’.2010 6 398 873
13 General Services Directorate 
Ministry of Foreign AffairsRefurbishment and adaptation of consulates
The project concerns the adaptation, expansion, redesign and relocation of 
consulates to ensure that they are properly furnished, that the employees are 
safe and that the visa applications process is efficient.2010 835 695
1 The figures shown for Greece are those verified and reported by the RA. They have not been approved by the Commission yet.
44 Annex AnnexFinal beneficiary Project nameAnnual 
programmeTotal final EBF 
expenditure 
in euro1
Poland
14 Ministry of Foreign Affairs Providing consular offices with equipment and software for biometric data 
collection
The purpose of the project was to provide consular offices with equipment and 
software for biometric data collection (e.g. fingerprint scanners). The project 
was financed out of two annual programmes. 2007 and 2008 389 604
15 Polish Border Guard Raising the qualifications of personnel who carry out border protection 
operations using aircraft
Provision of specialised aircraft training courses for Border Guard pilots and 
mechanics to operate particular types of aircraft (Sokol and Kania helicopters, 
Skytruck aeroplane), including night-vision goggle training and training as 
instructors. The project was financed out of three annual programmes.2007–10 803 034
16 Polish Border Guard Provision of the Border Guard with specialised means of transport
The project consisted of the acquisition of vehicles for the Border Guard services 
and was financed out of two annual programmes.2008 and 2009 3 571 588
17 Podkarpacie Voivodship Reconstruction of building for detailed control at the entry to the country in the 
road border crossing Medyka–Szegine
Enlargement of building for controlling vehicles at Medyka–Szegine border 
crossing point with Ukraine, increasing number of vehicle inspection bays from 
one to four and providing new equipment for inspection.2009 645 113
18 Polish Border Guard Extension and maintenance of teleinformation platform of the Border Guard to 
implement SIS II and VIS
The project consisted of four subprojects, as follows.
(1)  Development and maintenance of a system for the replication and 
reproduction of data — phase 1.
(2)  Modernisation and maintenance of a system for recording conversations.
(3)  Modernisation and maintenance of a hardware and software platform for 
support system requirements.
(4)  Purchase of computer workstations for the needs of the Border Guard 
Central Database.2010 1 078 749
1 The figures shown for Greece are those verified and reported by the RA. They have not been approved by the Commission yet.
45 Annex AnnexFinal beneficiary Project nameAnnual 
programmeTotal final EBF 
expenditure 
in euro1
Italy
19 Ministry of the Interior 
(Polizia di Stato)Strengthening the transfer network infrastructure and extending SIA and VISA 
procedure to the benefit of the immigration offices and Border Police offices 
operating in central and northern Italian regions
The action was aimed at the planning, supply and implementation of 
a telecommunication system for the extension of the optical fibre network by 
the additional circa 2 600 km necessary to link Border Police offices, Questure 
and police stations and enhancement and extension of the anti-immigration 
information system (SIA) in central and northern Italy.2007 11 023 303
20 Corps of the Port Captaincies 
(Coast Guard)Acquire four offshore patrol vessels
This action is a continuation of a project from the 2007 annual programme. Both 
projects cover the purchase of four automatically self-righting and unsinkable 
class 300 all-weather vessels.
The four patrol vessels operate in the territorial waters around Sicily and 
Sardinia.2008 3 866 000
21 Ministry of the Interior 
(Polizia di Stato)Purchase fuel vouchers needed to support additional activities for prevention 
and control closely related to the current immigration emergency in southern 
Italy
Purchasing fuel vouchers for diesel and petrol fuel intended for cars of the 
border police. The fuel allows the cars to do extra patrols in reaction to the flow 
of migrants from north Africa (Arab Spring/regime changes in countries such as 
Libya and Tunisia).2009 572 312
22 Guardia di Finanza Purchase of operational vehicles
The goal of the project was to provide the Guardia di Finanza with motor 
vehicles for performing the tasks related to the detection and identification of 
immigrants at sea borders in the context of the fight against illegal immigration. 
355 vehicles were bought.2010 3 612 768
23 Ministry of the Interior 
(Polizia di Stato) Purchase of a fixed-wing aircraft for the border police 
The purchase of a second aircraft (first aircraft purchased out of annual 
programme 2009) for the border police to ensure coordination of operational 
activities, especially in relation to the management of crisis situations, which can 
occur without warning in certain locations of the national territory.2010 3 377 748
1 The figures shown for Greece are those verified and reported by the RA. They have not been approved by the Commission yet.
46 Annex AnnexFinal beneficiary Project nameAnnual 
programmeTotal final EBF 
expenditure 
in euro1
Greece
24 Ministry of Citizen Protection/
Hellenic PoliceThe incorporation of the common training standard for the country’s police 
personnel
The project aimed to incorporate Frontex’s common training standard into 
Greece’s police training system, by training 448 participants in three levels of 
courses. The common standard provides for basic and periodic training of police 
officers and border guards involved in managing migrant flows.2007 600  079
25 Ministry of Public Order and 
Citizen ProtectionRental costs of temporary detention centre on the island of Lesbos
The project concerned the cost of renting a temporary detention centre at 
Pagani, close to Mytilini on the island of Lesbos.2008 200 554
26 Ministry of Citizen Protection/
Hellenic PolicePurchase of patrol passenger vehicles
The project aims to purchase 75 vehicles (split between patrol cars in police 
livery and unmarked passenger cars) to be used for patrols of the roads close to 
the border, aiming at controlling and protecting the external borders from the 
illegal entry of immigrants.2009 1 115 807
27 Ministry of Citizen Protection/
Hellenic PolicePurchase of 4x4 police patrol vehicles (jeep type)
A total of 69 police patrol vehicles were procured through this project. These 
vehicles will be used for patrols in inaccessible and mountainous border regions 
aiming to prevent illegal immigrants from entering Greek territory.2009 1 275 989
28 Ministry of Foreign Affairs Support for the installation of the visa information system
The objective of the action was to co-finance the implementation of N-VIS and 
NET-VIS IT systems, regarding costs for system design, implementation, roll-out 
and personnel training. It is part of a multiannual action aiming to install the EU 
visa information system (VIS) in Greece’s consulates.2009 2 984 335
29 Ministry of Citizen Protection The construction and upgrading of border infrastructure at the external land 
borders with Albania and Turkey for police services involved in border control
The purpose of this action was to improve the border infrastructure at the 
Greek–Albanian and the Greek–Turkish borders by construction of two new 
stations in Delvinaki and in Feres.2010 2 117 706
30 Ministry of Citizen Protection/
Hellenic PolicePurchase of police patrol dogs and police vehicles for their transportation
The project aimed to provide around 40 police dogs and vehicles for their 
transportation, with the purpose of detecting irregular migrants trying to cross 
the external land border. The vehicles envisaged were station wagons with four-
wheel drive, to operate in rough terrain at the border.2010 880 268
31 Ministry of Citizen Protection/
Hellenic PoliceSupport of the operational costs related to the implementation of integrated 
border management system at the land Greek–Turkish borders and initial 
reception and detention centres for illegal immigrants in Evros region
Operational running costs of the Hellenic police services, including maintenance 
costs for the patrol vehicles/vessels and other equipment, fuels and spare parts 
for vehicles/vessels involved in border control activities. Also photographic film, 
printing of photos, fluorescent lamps, tyres, a boiler .2010 706 011
1 The figures shown for Greece are those verified and reported by the RA. They have not been approved by the Commission yet.
47 Annex AnnexEmergency actions, Community actions and specific actions
Final beneficiary Project nameAnnual work 
programmeFinal EBF 
expenditure 
in euro
Emergency actions
1 Police Grand Ducale de 
Luxembourg, LuxembourgUpgrade of LU NS.SIS II from development to full-scale production setup at ICD 
3.0 level
Procurement of hardware and basic software licences to upgrade development 
set-up on the back-up site to full production deployment. This upgrade is 
necessary to meet the milestones on the way to the SIS II entry into operation. 2011 575 857
2 Ministry of the Interior, 
Central Directorate for 
Immigration and Border 
Police, Public Security 
Department, ItalyReinforcement of transportation means to patrol the border crossing points area 
and the area close to the CIE (RECARS)
The project consisted of the purchase of 40 police vehicles to provide the 
reinforcement of means of transport within the maritime Border Police Offices 
and immigration offices. The action aimed to contribute to the increase of 
police surveillance capacity in the south of Italy and in the areas in all the 
Italian territory, particularly close to the southern Centre for Identification and 
Expulsion (CIE).2010 1 367 856
3 Ministry of the Interior, 
Central Directorate for 
Immigration and Border 
Police, Public Security 
Department, ItalyInternal transportation of migrants (Shifts)
The action consisted in the organisation of displacements of migrants from 
Lampedusa by air, land or sea, to identify and get assistance to the migrants in 
several different places duly equipped.2010 1 665 247
Community actions
4 Belgian State Federal 
Public Service Foreign 
Affairs, Foreign Trade and 
Development Cooperation, 
BelgiumSchengen visa application centre Kinshasa
The aim of the project was to create the first real Schengen common visa 
application centre. While each participating Member State would be responsible 
for the back office operations, the application processes are centralised allowing 
multiple Member States to pool and share resources in the Democratic Republic 
of the Congo (DRC). Belgium’s partner in the project was Portugal (Ministerio Dos 
Negocios Estrangeiros).2007 395 349
5 Belgian State Federal 
Public Service Foreign 
Affairs, Foreign Trade and 
Development Cooperation, 
BelgiumMaison Schengen Kinshasa
Continuation of the project ‘Schengen visa application centre Kinshasa’  
from 2007 since this project suffered delays and could not be fully executed 
within the 2007 annual work programme. At the end of 2013, the centre 
represented 17 Schengen states.2009 450 356
48 Annex AnnexFinal beneficiary Project nameAnnual work 
programmeFinal EBF 
expenditure 
in euro
Specific actions
6 Italian Ministry of the Interior, 
Department of Public Security 
— Central Directorate for 
Immigration and Border 
Police, ItalySix months’ rental of vehicles to be delivered at the Italian southern maritime 
borders (CAR2 )
The project provided for the rental of 137 well equipped vehicles to provide 
a reinforcement of means within the maritime border police offices to improve 
police surveillance capability in the south of Italy. The increase of vehicles 
available for patrolling the coastline would enable to intercept migrants 
attempting to illegally cross the border.2009 950 688
7 Italian Ministry of the Interior, 
Department of Public Security 
— Central Directorate for 
Immigration and Border 
Police, ItalyBorder patrolling (Bor-trol)
The plan was to purchase 80 police vehicles to provide a reinforcement of 
means within the maritime border police offices to improve police surveillance 
capability in the south of Italy, especially on the south-western coastline where 
a particular situation has occurred. 43 vehicles were eventually procured.2010 560 259
49
III
In addition to fostering financial solidarity, the 
crucial financial support to Member States to imple -
ment top priority projects such as SIS II, VIS and 
Eurosur have demonstrated that the fund had real 
European added value.
Nevertheless the initial problems in setting up indi -
cators in national programmes and the deficiencies 
in the midterm evaluation made it difficult to get an 
accurate picture of the achievements of the fund.
IV
There was no obligation to embed the EBF pro -
gramming in a national strategy for border control 
and visas.
Beneficiaries of the EBF are almost exclusively 
national authorities having an exclusive compe -
tence in the area, therefore for the EBF the selection 
of the beneficiaries was generally straightforward.
However, some Member States have to strengthen 
their procurement procedures in order to fully 
comply with the principle of sound financial 
management.
V
For Spain and Greece, some aspects of the man -
agement of the fund can qualify as serious weak -
nesses, in particular the low implementation rate 
for Greece, but this is only valid for the first years 
of implementation of the fund and was mostly due 
to the late adoption of the legal base of the fund 
capacity and lengthy procurement procedures.
For Malta and Italy, the novelty of the fund and the 
inexperience of the responsible authorities can 
largely explain the issues found by the Court.Executive summary
I
According to recital 4 of the EBF decision, the EBF 
was conceived as a ‘ Community financial solidarity 
mechanism in order to support the Member States 
who bear, for the benefit of the Community a lasting 
and heavy financial burden ’.
Given this clear rationale underlying the establish -
ment of the fund, the assessment of the EU added 
value of the fund should be carried out in the first 
place on the fund’s ability to increase capacities of 
the Member States, especially those facing a heavier 
burden than others, to fulfil their roles and obliga -
tions to ensure uniform, effective and efficient con -
trols at the external borders of the Member States 
of the European Union and applying the Schengen 
acquis .
Bearing in mind that the Schengen zone represents 
an EU added value in its own right, the EBF was 
enshrined in the basic logic of the Schengen gov -
ernance whereby the obligation for the protection 
of EU external borders lies with individual Member 
States. Therefore the reinforcement of the capaci -
ties of the Member States in question through 
EBF investment in their own efforts to control the 
borders seems to be the best way to ensure the 
effective management of the EU external borders, 
especially to address particular migratory pressure.
The legislator, during the decision-making process 
for the establishment of the fund, decided delib -
erately not to include the principle of additionality 
under Article 8 of the EBF decision, listing the prin -
ciples of assistance as opposed to the initially pro -
posed text of the Commission. Therefore, contrary 
to Structural Funds, the principle of additionality 
was not enshrined in the design of the EBF, which 
was supposed to be governed by the principles of 
complementarity, consistency and compliance.Reply of the  
Commission
Reply of the Commission 50
VI (d)
The Commission agrees with the fact that public 
procurement procedures should be strengthened in 
some Member States and is already paying particu -
lar attention to this point.
Introduction
11
For large Member States, the Commission agrees 
that most expenditure may be financed nationally 
but this might be much less true for small Member 
States receiving a relatively high EBF allocation, 
which can have a huge leverage effect on the Mem -
ber State investment capacity in this area.
The fund is a key tool which gives concrete expres -
sion to financial solidarity between Member States 
for the management of the external borders of the 
Schengen area.
Observations
26
The Commission acknowledges that even if partial 
information coming from different sources (final 
reports, ex post  evaluation) is available and allowed 
for the measurement of some results of the fund, 
the overall result of the fund could not be meas -
ured so far. This will be done in the context of the 
final ex post  evaluation. There were weaknesses in 
monitoring and evaluation in a few Member States 
in the first annual programmes, in particular a lack 
of SMART indicators. This was linked to the nov -
elty of the fund and the lack of experience of the 
responsible authorities concerned. The situation has 
improved since 2012.VI (a)
The Commission considers that the recommenda -
tion relating to indicators has been implemented 
in the legal base of the Internal Security Fund with 
compulsory indicators in respect of the period 
2014–20.
On the second issue, the Commission accepts the 
recommendation and is confident that the final 
evaluation report will address it.
VI (b)
The Commission accepts the first part of the recom -
mendation (information of Frontex on EBF imple -
mentation) and considers that it has been imple -
mented in the legal basis of the Internal Security 
Fund regulation in respect of the period 2014–20.
However, the Commission can only partially agree 
that co-financed assets should be systematically 
recorded in the Frontex equipment pool. The regis-
tration and putting at the disposal of Frontex of 
equipment are ruled by Frontex regulations and not 
by the fund’s legal base. The Commission will pro -
mote common application centres and other funds 
of consular cooperation in addition to renovations, 
adaptation and/or equipping of consulates.
Items purchased under the ISF Borders and Visas 
specific actions which will correspond to Frontex 
needs will have to be registered in Frontex’s equip -
ment pool.
VI (c)
The Commission disagrees with making ISF sup -
port conditional on the elaboration of a national 
strategy. Conditionality as regards the Schengen 
acquis  has been introduced in the ISF legal base for 
operating support.
Reply of the Commission 51
30
The EBF was enshrined in the basic logic of the 
Schengen governance, where the obligation for the 
protection of EU external borders lies with indi -
vidual Member States. Therefore the reinforcement 
of the capacities of the Member States in question 
through EBF investment in their own efforts to 
control the borders seems to be the best way to 
ensure the effective management of the EU exter -
nal borders, especially to address particular migra -
tory pressure.
While the creation of additional capacities through 
the cooperation of Member States was also encour -
aged and supported by the fund, this aspect has 
been considered as an ancillary element.
31 (a) 
Please see replies to points 32–34. The specific pri -
orities were largely used by Member States in their 
programmes, even by Member States which did not 
need it to increase their co-financing rates (cohe -
sion countries).
31 (c)
The EBF mechanism to support emergencies under 
the Community actions was largely effective given 
the specific situations and circumstances where the 
emergency interventions were activated. Relevant 
funding was provided in response to some major 
emergency situations and effectively supporting 
projects in Member States facing particular pres -
sure, such as Italy and Greece, contributing to the 
improvement of the situation on the ground.
However, the Commission agrees with the Court 
observation as regards the design of the EBF spe -
cific actions.27
Out of the five projects identified by the Court, 
three (projects 9, 21 and 22) fully support EBF 
priorities and only support eligible expenditure. In 
particular, the purchase of patrolling boats (pro -
ject 9) by the Spanish authorities for the maritime 
external borders surveillance was fully eligible for 
the fund as it was deployed on maritime external 
borders. The fact that it was not deployed in the 
most risky external maritime borders does not make 
it ineligible and is linked to the management of 
means of surveillance by the Spanish authorities in 
the context of a fleet.
The Commission is aware of the problems relat -
ing to the project mentioned in paragraph 60 and 
ineligible costs will be deducted from the eligible 
expenditure when closing the annual programme.
28
There has been a real improvement regarding the 
use of indicators by Member States since the annual 
programmes 2011. Initial problems were due to 
the lack of experience and difficulty for Member 
States to set measurable indicators at program -
ming stage, despite initial guidance provided by the 
Commission.
29
The overall EBF implementation rate is satisfactory 
in spite of the fact that it was a new fund. Regarding 
Greece, the first annual programmes show quite a 
low implementation rate due to limited administra -
tive capacity and lengthy procurement procedures 
which have been addressed since then with the 
assistance of the Commission in order to, inter alia, 
increase the absorption rate of EU funds, and it is 
expected that these efforts would have positive 
results on implementation from 2011.
Reply of the Commission 52
34
In line with reply to point 32, the Commission 
monitors the extent to which the specific priorities 
are applied by reviewing the concrete activities 
financed under specific priorities as part of the gen -
eral work performed on the closure packages under 
each individual annual programme, as well as part 
of the general monitoring activities carried out by 
the Commission on national programmes (including 
monitoring missions).
Box 1
As replied to points 33 and 34, the Commission per -
formed monitoring of the use of specific priorities 
as part of the monitoring of annual programmes 
implemented by Member States at the stages of 
draft programme analysis and during the imple -
mentation and at closure.
The successful launch of VIS and SIS II in all Mem -
ber States demonstrates the crucial role of the 
fund in the achievement of these two large-scale 
IT projects. Despite the challenging environment 
surrounding the development and launching of 
both systems, the flexibility offered by the EBF (in 
particular through revisions) allowed the smooth 
financing of SIS II and VIS.
36
Initiatives by Member States remained limited and 
Member States preferred to finance renovations 
and upgrading of their visa sections under their 
annual programmes in order to comply with the 
requirements of the visa code and of the VIS regula -
tion, which is also crucial to ensure proper external 
border management.31 (d)
In the first years of implementation of the fund 
some projects which have been funded by the EBF 
would have anyway been funded by national funds. 
Given the fact that this was the first generation of 
funds in this area, this was almost unavoidable, in 
order not to lose the first years’ allocations. The 
eligibility of costs is assessed at the time of closure 
in accordance with shared management principles 
(not at programming stage). Moreover, the Commis -
sion is carrying out audits which lead to financial 
corrections when appropriate.
32
The EBF’s strategic guidelines, adopted by the 
Commission, established a framework ensuring that 
the fund is programmed and subsequently imple -
mented in line with the relevant EU policies and 
built around the fund’s five priorities.
Even if the specific priorities did not bring an 
additional financial incentive for cohesion coun -
tries such as Malta and Spain, Member States have 
widely used the specific priorities in their program -
ming: nearly 720 million euro was programmed 
accordingly, representing 45 % of the total 2007–
13 EBF allocations for all Member States.
33
Some elements/requirements of the specific prior -
ities are open to interpretation, however, for most of 
the specific priorities (9 out of 12), the requirements 
were clear and allowed their effective application 
by Member States during the programming process.
Regarding the refocusing of the EBF programming 
on a few key strategic priorities (VIS, SISII, Eurosur, 
consular cooperation, state-of-the-art equipment), 
while the relevant reporting still needs to be ana -
lysed, the successful launch of VIS, SIS II and Eurosur 
in all Member States demonstrated the contribution 
of the EBF in this respect.
Reply of the Commission 53
This explains why legislators have not established 
this condition in the EBF Decision. In the Inter -
nal Security Fund Borders and Visas 2014–20, the 
obligation to register in the Frontex pool of equip -
ment has been introduced, but only for equipment 
purchased through specific earmarked funding for 
equipment necessary for Frontex joint operations, 
which is the best way to strike a balance between 
putting obligations on Member States and provid -
ing Frontex with appropriate equipment for its joint 
operations.
39
In accordance with article 53 (3) of the EBF Deci -
sion, the Commission communicates to the Agency 
all the approved  final reports on the implementa -
tion of annual programmes. The information was 
transmitted to Frontex with some delay, bearing in 
mind that most of annual programmes relating to 
the 2007–10 period were closed in 2012–13.
However, this did not limit Frontex’s planning and 
operational ability as Frontex’s yearly operational 
planning is based on information from Member 
States in bilateral annual talks, and in terms of the 
availability of technical assets it relies on the infor -
mation from the Frontex pool of technical means.
40
In order to step up the efforts for the exchange of 
information with Frontex, the CIRCABC electronic 
platform was established in 2014 by the Commis -
sion to organise and transmit the necessary infor -
mation and to create a permanent repository of EBF 
documents which can be easily used by different 
services/units within Frontex.
This platform will ensure the full accessibility of the 
EBF final reports and other relevant information on 
EBF funding, most notably the ongoing EBF annual 
programmes, projects financed under EBF Commu -
nity and specific actions.The reasons why the fund had a limited effect on 
the development of consular cooperation projects 
have been analysed and lessons have been learnt 
for the next programming period. In particular, 
the scope of the consular cooperation has been 
extended to other forms of consular cooperation 
than the common application centres as provided 
for by the visa code (colocation, representation, 
outsourcing), giving more possibilities to Member 
States. This is now reflected in the legal base of the 
Internal Security Fund (Borders and Visas — specific 
actions) for the period 2014–20.
37
The EBF was not conceived to directly support 
‘operations coordinated by Frontex ’ but to support 
efforts of Member States to manage the external 
borders of the European Union and in particular 
those most exposed to migratory pressure. Joint 
operations are financed from the Frontex’s own 
budget. Nevertheless, the Commission proposed 
specific priority 3(1) to increase the capacity of 
Member States to take part in and/or contribute to 
operational cooperation coordinated by Frontex. 
Nearly 30 million euro was earmarked in the MS 
2007–13 annual programmes of Member States 
(nearly 2 % of the total EBF allocation for MS) under 
this specific priority.
38
Not all equipment purchased by Member States 
with EBF support would be systematically needed 
by Frontex for its joint operations. In addition, the 
registration in the Frontex pool and the putting at 
disposal of the equipment are regulated by found -
ing Frontex regulations, therefore issues relating 
to the availability of technical means can only be 
solved within the context of Frontex regulation.
Reply of the Commission 54
42
Even if the legal framework for emergency actions 
under Community actions was not ideal, the 
finan  cing of the actions under this mechanism 
was always legitimate and corresponded to an 
emergency/crisis situation. The lessons learnt from 
2007–13 were applied in the 2014–20 Internal Secu -
rity Fund.
The lack of some information in the grant applica -
tion does not automatically mean that the action 
was poorly managed. This must be assessed in the 
light of the unpredictable context in which these 
actions are managed, which make them different 
from a normal Community action, in particular as 
regards ex ante  detailed information to be provided 
on the expected results of the action financed.
Box 4, Case 1
The financing of SIS II final development steps for 
some countries constituted an emergency because 
a failure or delay on the part of a single MS in com -
pleting the SIS II tests scheduled in the second half 
of 2011 would have resulted in a delay for the entire 
project.
Accordingly, providing financial support to those 
Member States whose readiness to complete tests 
in 2011 depended on it represented an emergency 
action within the meaning of Article 7(c) of the EBF 
legal basis
This is why the Commission made significant efforts 
in 2011 to mitigate the risk of delay by Member 
States in adhering to the SIS II schedule because of 
a lack of financial resources to complete the devel -
opment and testing of the national SIS II compo -
nents. The Commission invited national authorities 
to give higher priority to SIS II under their existing 
EBF national allocations. It also organised a call for 
interest for emergency actions under the Com -
munity actions of the EBF, under which an extra 
7.5 million euro was provided to the eight Member 
States most in need of additional resources (coun -
tries with very low EBF allocations and/or whose 
EBF resources were absorbed by other key priorities 
in the area of external borders).On the top of making available the EBF docu -
ments, the Commission also offered to come with 
more targeted information, in particular, country 
fiches on EBF 2007–13 APs for each MS will be 
provided. In addition, some thematic fiches (i.e. on 
trainings, Eurosur) could also be made available if 
appropriate.
Information will be provided by the Commission 
to Frontex on measures to be financed via shared 
and centralised management. Effective informa -
tion exchange will require also that Frontex shares 
with the Commission information from its annual 
bilateral and other talks with Member States, and 
the Commission has asked for this on a number of 
occasions.
41
Specific actions have been included in the course of 
the negotiation of the legal base and were not part 
of the initial Commission proposal. Experience has 
shown that the legal framework for the implemen -
tation of specific actions presented several flaws 
which have proven to be detrimental to the smooth 
implementation of these actions: the very cumber -
some process leading to the definition of geograph -
ical areas concerned by specific actions (with the 
problem of quickly shifting risks which could not be 
immediately taken into account) and the very short 
period for implementation.
Therefore the Commission can agree with the fact 
that specific actions were not well designed from 
the beginning.
The use of Community actions to finance emer -
gency actions and the possibility to revise annual 
programmes to address urgent situations have 
been used to their full in the case of certain Mem -
ber States facing high migratory pressure. From a 
European added-value point of view this can hardly 
be criticised as actions which were financed were 
carried out to the benefit of the whole Schengen 
area on sections of external borders for which the 
level of security was put at risk in a context of high 
migratory pressure. It must be underlined that 
Member States indirectly affected by migratory cri -
sis were also supporting the allocation of additional 
funds through emergency funding in order to help 
frontline Member States such as Italy or Greece.
Reply of the Commission 55
Box 5, 2009 specific actions
Although the call for proposals for specific actions 
2009 limited the territorial scope to the maritime 
border of Italy, during project implementation the 
beneficiary formally requested the geographical 
extension of the project to areas indirectly affected 
by the emergency migratory pressure triggered by 
the Arab Spring, namely areas of centres for iden -
tification and expulsion (CIE) where the migrants 
were being transferred. This project covered the 
period March–August 2011, during which the migra -
tion outflows from Tunisia following the Tunisian 
and Libyan revolutions reached their peak. In their 
request for amendment the Italian authorities spe -
cifically mentioned the need to relieve the burden 
on southern areas (about 40 000 migrants reached 
the Italian border) by transporting the migrants 
to other accommodation centres throughout the 
national territory and to ensure adequate secur  ity 
around these centres with the increased presence 
of vehicles. In a context of massive arrivals in the 
selected area in the call, it was crucial to transfer 
migrants to places where they could be screened 
properly in order to relieve the infrastructures 
located in the eligible areas. Therefore, this exten -
sion granted by the Commission remained in the 
scope of the objectives of the funds and was not 
departing from the geographical focus mentioned 
in the specific call as the situation in these areas 
was dependant on action in other areas. As a result, 
the Commission consistently considered eligible 
and accepted costs related to areas beyond the 
southern maritime border upon evaluation of the 
final cost claim.
Box 5, 2010 specific actions
In the context of this project, the financing of cars 
deployed beyond the areas identified in the Frontex 
risk analysis report was not justified. Consequently, 
the cost of the cars deployed outside the eligible 
areas has been rejected by the Commission.Box 4, Case 2
The project’s objective was to ‘ensure transporta -
tion by air, land and sea of migrants arriving at the 
coasts of southern Italy during the summer of 2011’. 
At the time the situation of the submission of the 
Shifts project, the consequences of the critical situa -
tion in countries such as Libya were still unpredicta -
ble thus not allowing to have a clear vision of future 
developments in the exact number of migrants 
and asylum seekers to expect in Italy. In addition, 
it was impossible to predict how many additional 
places would become available in the mainland 
reception facilities, where and how many migrants 
would have to be. Achievement of progress for this 
type of emergency action could be measured only 
on an ex post  basis due to the difficulty of setting 
indicators in a context of unpredictable events and 
a challenging operational environment. The other 
audited project concerns the purchase of vehicles 
for patrolling purposes. Transportation of migrants 
was a secondary objective. Hence, the Commission 
considers that, unlike for the project Shifts, the 
number of migrants transported was not a relevant 
indicator for evaluating the action.
43
Lessons have been learnt from the problems 
encountered in the implementation of specific 
actions and this mechanism will not exist anymore 
in the Internal Security Fund for the 2014–20 period.
Some actions under the 2008–10 were implemented 
outside the border areas specified in the calls for 
proposals. However, for the first one, the deroga -
tion was explicitly requested by the beneficiary and 
the Commission accepted as the derogation was 
directly linked to measures to address the situation 
in the border areas concerned (please see explana -
tion below for Box 5). For the second one, as noted 
by the Court (Box 5, 3rd paragraph), the Commis -
sion has taken the necessary measures to recover 
the cost of cars which were deployed outside the 
border areas eligible under the call concerned.
Reply of the Commission 56
In that context, the Commission believes that the 
EU added value of the fund also lies in assisting 
Member States facing a crisis situation because of 
increased migratory pressure.
47
The fact that ineligible expenditure is not detected 
by the national management and control systems 
does not necessarily mean that they are paid by the 
national fund. Where the Commission detects defi -
ciencies in the national management and control 
systems, financial corrections may be applied.
Box 6, Lack of needs assessment and 
ineligible costs
The purchase of 355 vehicles was fully justified 
by the huge flow of migrants that tried to enter 
Italian territory following the Arab Spring in 2011 
(62 692 people identified against 9 573 in 2009 and 
4406 in 2010). These cars were not only needed to 
monitor the coastline but also to prevent second -
ary movements from the coastal regions to the 
inland regions and fulfil all the missions relating to 
the transportation of apprehended third country 
nationals towards retention centres, courts, etc. Of 
course these missions implied a use of the vehicles 
which was not strictly limited to the external bor -
ders but which was fully justified given the emer -
gency context where the apprehension of irregular 
migrants having just crossed the external borders 
is not a matter of normal law enforcement but of 
border and migration management.
Given the absolute unpredictable nature of the 
Arab Spring, it was impossible for the Italian 
authorities to carry out a needs assessment on the 
adequate number of cars required to cope with the 
sudden flow of irregular migrants in 2011.45
Regarding the 2007 and 2008 annual programmes, 
it must be underlined that the late adoption of the 
EBF legal base, and consequently the late adop -
tion of EBF multiannual programmes and 2007 and 
2008 annual programmes, gave no other choice 
for many Member States but integrating in the first 
annual programmes already decided actions. In 
case of serious under-implementation of the first 
annual programmes, the Commission and Member 
States would have been criticised for not using the 
opportunity offered by the fund and this would 
have damaged the reputation of the fund and 
jeopardised its launching. In addition, had Member 
States waited to launch the public procurement 
procedure needed to purchase equipment, the 
funds available under the 2007 and 2008 annual 
programmes would have been lost, as was mostly 
the case in Greece.
46
National authorities usually spend their resources 
on relevant projects in this very sensitive area, 
which therefore have European added value as 
these investments serve the interests of the Mem -
ber States participating in the Schengen area.
The nature of the costs financed by the fund does 
not necessarily limit the added value of related 
projects. The actions financed in Greece and Italy 
consisted of helping to deploy additional surveil -
lance capacities and not of financing costs which 
would have normally been incurred in a non-crisis/
emergency context.
The EBF focused in its first years of implementation 
on the long-term objective of capacity building 
in the Member States (2007–10). Later on, it was 
necessary to adapt to the pressure imposed by the 
emergency context due to political unrest in the 
south Mediterranean region, and to respond in an 
effective way by strengthening the operational 
dimension of the fund. Therefore, the Commission 
decided to support certain projects aiming at rein -
forcing the surveillance capacities linked to emer -
gency situations in Greece and Italy.
Reply of the Commission 57
51
DG Home Affairs systematically consulted other 
Commission departments on the content of annual 
programmes, thereby mitigating the risk of target -
ing similar actions. The Commission is not aware of 
any double funding of the same project by two EU 
financial instruments.
53
For the preparation of the first annual programmes, 
most responsible authorities did not have experi -
ence in managing EU funds. The task of the respon -
sible authorities to request from beneficiaries to 
commit themselves on measurable targets proved 
to be difficult in a field of activity where account -
ability might not be as developed as in other areas 
due to safety/public security reasons.
54
Although the Commission insisted vis-à-vis Member 
States on the necessity to get measurable indicators 
(at least input indicators), it did not block the adop -
tion of the first annual programmes because some 
actions were lacking measurable indicators, as this 
would have been disproportionate and would have 
anyway not resulted in a substantial improvement 
of the indicators for the first annual programmes 
(2007 and 2008) which were adopted together. 
Nevertheless, in the course of the adoption of the 
annual programmes, progress has been noted as 
regards the indicators inserted by Member States 
from 2012. For example, the initial Spanish annual 
programmes contained very few quantified indica -
tors, whereas as from the 2012 and 2013 annual pro -
grammes many result and impact indicators were 
quantified, showing measurable targets.
55
For the next programming period, Member States 
will have to report in a compulsory manner on 
common indicators. In addition, programme-  
specific indicators will be defined in accordance 
with national programme specificities. Reporting 
on indicators will be managed through an IT system 
developed by the Commission.48
Due to time constraints for adopting the pro -
grammes, some of them lacked SMART indicators. 
The elaboration of national strategies was not 
a legal obligation imposed by the EBF on Member 
States to receive support from the fund. For one 
Member State the selection of beneficiaries could 
have been better documented, but this did not 
affect the effectiveness of the fund. The Commis -
sion is aware of the risk linked to public procure -
ment and is applying financial corrections where 
necessary.
49
The obligations/requirements described by the 
Court are not included in the EBF legal base. The 
third version of the Schengen catalogue is not 
a binding instrument which would have imposed 
the obligation on Member States to have a national 
strategy for the management of the external bor -
ders to receive support from the EBF. 
50
Member States are responsible for the preparation 
of their multiannual programme and their annual 
programmes. The multiannual programmes con -
tained three parts (situation in the Member State, 
analysis of the requirements and strategy to achieve 
the objectives) which in most cases allowed the 
Commission to understand the situation, require -
ments and strategy of the Member States, even if 
the quality varied from one country to the other. It 
must be noted that the CIRAM has been developed 
by Frontex in the past years and was not available 
at the time of the preparation of the multiannual 
programmes. In addition, given that the situation 
regarding border management may be subject to 
change in time due to changing irregular migra -
tion routes, the approach has to be adapted to 
reality, which explains the revision of multiannual 
programmes and annual programmes as new needs 
have appeared and priorities have changed dur -
ing the programming period. Complementarity 
has always been checked by the Commission when 
adopting annual programmes with other depart -
ments managing EU funds, and no major problems 
of complementarity were raised.
Reply of the Commission 58
Regarding participation in specific actions and 
emergency measures, each relevant public author -
ity could apply directly for funding without 
involving the responsible authority. So the lack of 
participation in these instruments of Italian public 
authorities other than the one institutionally con -
nected with the responsible authority should not 
be regarded as an exclusion or marginalisation but 
as a prominent institutional role of the Ministry of 
the Interior (in collaboration with other public enti -
ties such as the Marina Militare, Guardia di Finanza, 
Capitaneria di Porto, Ministry of Foreign Affairs) in 
the management of the external borders.
60
Following the assessment of the relevant final 
implementation report by the Commission, this 
specific project was found in breach of the basic 
principles of the fund. Therefore, the respective 
costs will be deduced from the final payment of the 
EBF annual programme concerned.
In both stages of the involvement of the Commis -
sion in the EBF implementation, namely the adop -
tion of national programmes and their final closure, 
the Commission pays particular attention that the 
EBF projects implemented by Member States are 
in compliance with EU law, including the respect of 
fundamental rights.
61
The acquisition of patrol dogs was initially part of 
the same procurement procedure as the patrol cars. 
When Greece realised that the two components 
(dogs and cars) could not be procured together, 
they went on with purchasing the cars and the 
dogs’ acquisition was postponed.
62
The use of the exception clause for defence and 
security procurements is a valid option if the condi -
tions provided by the legal framework on procure -
ment to use this possibility are met.56
Annual programmes represent a disproportionate 
administrative burden for Member States and for 
the Commission under the 2007–13 period. Nev -
ertheless, it was deliberately chosen by the Com -
mission because on the one hand it could respond 
quickly to changing situations at the external 
borders and on the other hand it allowed better 
scrutiny of the eligibility of actions considering the 
novelty of the fund and the inexperience of respon -
sible authorities as inherent risks.
57
The experience gained by Member States through -
out the programming period 2007–13 allows 
shifting to a multiannual programme management 
framework for the 2014–20 period. As pointed out 
by the Court, this will facilitate the implementa -
tion of the procurement of large and sophisticated 
equipment, which can be very lengthy.
58
Given the specific nature of EBF beneficiaries 
(public bodies in charge of border management 
and visa issuance) and their rather limited number 
in each Member State, in many Member States the 
selection of relevant projects has to be centralised. 
However, at the same time it was often carried out 
or approved with the participation of high politi -
cal level guaranteeing the use of the EBF allocation 
to address the most relevant priorities and needs 
faced by the Member State.
59
The fund is allocated between the different pub -
lic entities which are in charge of external border 
management.
Reply of the Commission 59
65
In case of insufficient verification of procurement 
procedures and/or the use of inappropriate pro -
curement procedures, there might be a risk of lower 
value for money, which is why the Commission pays 
particular attention to this issue and applies finan -
cial corrections where necessary.
66
Regarding the lack of SMART indicators, the Com -
mission acknowledges that, despite its guidance 
to Member States, it has been really difficult to 
get reliable outcome and impact indicators for the 
reasons explained at points 53 and 54. This also 
explains why it was not really possible to exploit the 
reporting by Member States on indicators included 
in the first annual programmes for the 2007–10 
evaluation and that the evaluation had to be carried 
out on the basis of an ad hoc questionnaire sent to 
Member States for the purpose of the evaluation.
67
The obligations of responsible authorities regard -
ing monitoring have not always sufficiently been 
respected. The Commission has nevertheless 
observed that the situation has improved in most 
Member States since 2010. This is nevertheless miti -
gated by the fact that most beneficiaries of the EBF 
are large public entities which have to comply with 
checks by ministries of finance in order to proceed 
to the payment by the national treasury/ministry of 
finance (check against delivered equipment, com -
pliance with orders, etc.).
68
Most Member States are carrying out monitoring 
visits (on-the-spot) even if the situation is varying 
from one Member State to another. For Italy, these 
on-the-spot controls, although carried out ex post , 
have represented 50 % of the total of the alloca -
tion between 2007 and 2012. For Spain, as from 
2010 monitoring visits took place on a regular basis.Clear messages have been regularly sent by the 
Commission to Member States on the need to 
comply with the relevant legal framework and to 
properly document the reasons why a negotiated 
proced  ure was used by the beneficiaries and not 
open or restricted procedures. The Commission 
also applies project-specific corrections or, where 
appropriate, flat-rate financial corrections when 
it identifies in the context of closures of annual 
programmes irregular procurement procedures or 
a lack or insufficient documentation on the jus -
tification of the choice of procedures which can 
reveal a systemic deficiency in the management 
and control system. These financial corrections are 
calculated with the same rules as for the Structural 
Funds. In addition, ex post  audit strategy will com -
plement the efforts to reduce the risk of residual 
errors in the declared expenditure that were not 
detected at the time of closure.
63
This issue is regularly checked by the Commission 
at the stage of closures and through ex post  audits. 
Financial corrections are applied when irregularities 
in procurement procedures are detected.
64
The Commission regularly draws the attention 
of the responsible authorities to the necessity of 
verifying the legality of the procurement proced -
ures concerning contracts for which expenditure is 
declared to the fund. Such verifications fall within 
the scope of the responsible authority’s manage -
ment verifications. The responsible authorities are 
becoming more and more aware of the import  ance 
of ensuring that the beneficiaries provide well-
documented justification and supporting reason -
ing when opting for less transparent procedures, 
as supporting documentation with their claim for 
reimbursement for expenditure incurred. Further -
more, as part of the audit work, the audit authority 
also verifies if public procurement procedures have 
been correctly applied.
Reply of the Commission 60
73
The evaluation reports (which have been improved 
following the remarks made by the Court during 
the audit) contain quantitative data which gives 
an interesting overview of the assets purchased or 
developed with the help of the fund. The Commis -
sion acknowledges that, however, because of lack 
of time and insufficient information available, it 
was difficult to go beyond a descriptive analysis of 
what has been achieved by Member States with the 
fund during the first 4 years of its implementation. 
That is why the Commission thinks that the overall 
results of the fund could be partially measured.
The ex post  evaluation that will be carried out in 
2015 will include a detailed chapter on specific and 
Community actions, taking account of the results 
on the 2007–10 periods.
74
Delays occurred at the level of the Member States 
in the transmission of Member State reports. 
Additional verifications and requests for clarifica -
tions had to be sent by the Commission to Mem -
ber States, which triggered additional delays. The 
report was published on the website of the Com -
mission in May 2014.69
Setting up an IT system to record indicators was not 
an obligation in the basic act in the implementing 
rules of the fund. Nevertheless, the Commission 
encouraged Member States to develop a comput -
erised system to record data on projects during 
its monitoring visits and fostered the exchange of 
best practices in this area. For example, during the 
SOLID Committee of 11 May 2012, a Member State 
presented an example of best practices in this area 
(electronic management of the funds) to other 
Member States.
70
While in some cases the reports received from cer -
tain Member States have limitations in the informa -
tion provided, in particular in terms of quantifiable 
data on deliverables and outputs within the frame -
work of the project, this is mitigated by additional 
exchanges with the beneficiary until satisfactory 
information is received. Templates for applications 
and final reporting have been modified to address 
this issue for EBF Community actions and specific 
actions.
72
Lessons have been learnt from the evaluation 
process which has been audited by the Court. In 
particular the main lesson learnt has been that the 
involvement of an external entity which will be in 
charge of the entire evaluation process is to be pre -
ferred. The ex post  evaluation 2011–13 will therefore 
be carried out through a quite different process. In 
addition, the directly managed actions, which were 
not fully included in the scope of the evaluation, 
will be included in the next ex post  evaluation.
In addition, the lack of common indicators on which 
Member States should have reported from the start 
made the definition of indicators compulsory at 
the time of the midterm review. Member States had 
to collect data from beneficiaries on these indica -
tors which explain delays. For future evaluations of 
the Internal Security Fund, common indicators and 
programme-specific indicators will be used for the 
evaluation, making it easier and more effective.
Reply of the Commission 61
Some multiannual programmes and first annual 
programmes were indeed approved without being 
equipped with robust SMART indicators. The possi -
ble non-adoption of the programmes for this single 
reason would have been extremely damaging to 
the Member States concerned and to the fund’s 
reputation (and to the European Union), and would 
have been considered as a purely bureaucratic and 
rigid approach.
77
Slovenia developed an integrated tool to manage 
the fund and collect data from the start. Other 
countries did so whereas there was no legal obliga -
tion to put in place such a system. Some systems 
already exist in some Member States.
Regarding the content of the ex post  evaluation, 
most of the issues spotted by the Court have been 
corrected in the final version.
Recommendation 1
The Commission considers that this recommenda -
tion has already been implemented in the legal 
bases of the new funds. Additional guidelines will 
be provided to Member States.
Recommendation 2
This recommendation is addressed to Member 
States and is supported by the Commission.
79
The Commission acknowledges that the fund’s 
legal framework was not well designed as far as 
the specific actions are concerned. The Commis -
sion also acknowledges that the fund, while offer -
ing opportunities to finance consular cooperation 
through Community actions, did not obtain signifi -
cant results in that respect. Although the initiative 
of such actions mainly relies on Member States, this 
has been taken into account when elaborating the 
design of the new Internal Security Fund in order 
to provide an additional incentive for the establish -
ment of consular cooperation mechanisms.Conclusions and recommendations
75
The added value of the fund is related to the 
financial solidarity established through Member 
States facing drastically different situations at their 
external borders. In doing so, the fund has created 
a tangible solidarity between the countries most 
exposed to migratory pressure at the borders and 
the ones less exposed. Thanks to the allocation 
mechanism, the bulk of resources were directed to 
the most exposed countries (mostly south Mediter -
ranean ones). In addition, European added value 
is also represented by the fact that major projects 
for the Schengen area were supported successfully 
by the fund (VIS, SIS II and Eurosur). Regarding the 
weaknesses found by the Court, these are mainly 
due to an insufficient administrative capacity in the 
first years of implementation of the fund for one 
Member State, and for others to a lack of experience 
in the responsible authority and beneficiaries in the 
management of EU funds rather than systemic and 
persistent deficiencies. They are also linked with the 
delayed launch of the fund due to the late adoption 
of legal bases. In the opinion of the Commission, 
the situation of Italy and Malta cannot be qualified 
as showing ‘serious weaknesses’ in the manage -
ment of the fund.
76
The fund has supported the fund’s priorities, 
namely SIS II, VIS and Eurosur. The lack of SMART 
indicators for some programmes, due to the inex -
perience of responsible authorities in managing 
EU funds, did not prevent the use of the fund by 
Member States to support the fund priorities. This 
was achieved through close scrutiny of the Commis -
sion on annual programme content and appropri -
ate guidance (in particular as from 2010) allowing 
directing the programmes resources towards the 
fund’s priorities.
Reply of the Commission 62
Recommendation 4
First indent: While this recommendation is broadly 
addressed to the legislator, the Commission does 
not accept it. The fund was conceived in the first 
place as a burden-sharing mechanism supporting 
Member States’ capacities as the most effective way 
to fulfil their own roles and obligations for control 
of EU external borders. In the Internal Security 
Fund, equipment corresponding to Frontex’s needs 
for its operations that will be purchased under 
a specific earmarked financial component (specific 
actions) will have to be entered in the Frontex tech -
nical equipment pool.
Second indent: The Commission accepts this 
recommendation. Measures have already been 
implemented to put this cooperation/exchange of 
information into practice.
Recommendation 5
This recommendation is addressed to Member 
States. The elaboration of a comprehensive strategy 
for external borders to prepare the EBF multiannual 
programme was not an obligation stemming from 
the EBF’s legal base or of any other legal act.
Recommendation 6
The Commission does not accept this recommenda -
tion. The Commission would however point out that 
the Internal Security Fund (Borders and Visas) has 
integrated conditionality, and funding of operat -
ing support will depend on compliance with the 
Schengen acquis .
Recommendation 7
The Commission accepts this recommendation 
without prejudice to the respective roles of the 
Commission and of the Member States in shared 
management.
Recommendation 8
This recommendation is addressed to Mem -
ber States. The Commission supports this 
recommendation.80
Frontex will be very closely associated with the 
implementation of the new Internal Security Fund. 
According to the legal base, it will be consulted on 
the draft national programmes of Member States 
(Article 9.4 of the ISF borders regulation) and on 
actions to remedy weaknesses detected in the 
context of a Schengen evaluation (Article 12). Input 
by Frontex will also be crucial for the midterm 
review allocation (Article 8) and Frontex will play 
a key role in the allocation of specific actions, in 
particular for equipment to be put at disposal of its 
joint oper  ations. As the work on 2014–20 national 
programmes has already started, Frontex is already 
involved in these processes. An electronic informa -
tion exchange platform has already been put in 
place to facilitate exchanges of documents between 
the Commission and Frontex.
The registration in the Frontex pool of equipment 
and the putting at disposal of equipment for Fron -
tex operations are regulated by Frontex regulations 
and not by the fund. Not all equipment purchased 
by Member States with EBF support would be sys -
tematically needed by Frontex for its joint opera -
tions. In the Internal Security Fund, equipment cor -
responding to Frontex’s needs for its operations will 
be purchased under the specific actions and will be 
entered in the Frontex technical equipment pool.
For Frontex equipment refer to recommendation 4.
Recommendation 3
The Commission partially agrees with this recom -
mendation. The Commission will promote the 
establishment of common application centres and 
other forms of consular cooperation in add  ition 
to the renovation, adaptation and equipment of 
consulates. Renovating/equipping a consulate that 
processes hundreds of visas per day might make 
more sense sometimes than financing a consular 
cooperation action that concerns a few hundred 
visa applications per year. Renovating and equip -
ping big consular posts so that they could process 
the applications in a more client-friendly, speedy 
manner with the help of state-of-the-art (IT) equip -
ment is equally important to supporting consular 
cooper  ation projects. Moreover, ‘equipping’ can 
also mean VIS-related equipment, which is an 
important priority. Irrespective of stepping up 
consular cooperation, MSs should roll out the VIS 
worldwide in accordance with the roll-out schedule.
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QJ-AB-14-015-EN-C  ISSN 1831-0834
The aim of the External Borders Fund (EBF) 
is to help Member States ensure uniform, 
effective and efficient controls at their 
common external borders.
The Court’s audit examined the EBF’s 
effectiveness and the achievement of its 
objectives.
The Court found that the EBF has fostered 
financial solidarity by concentrating 
assistance on Member States who bear 
a heavier financial burden.
However, further EU added value was limited, 
and the overall result could not be measured 
due to weaknesses in monitoring and ex post 
evaluations. Furthermore, the audit found 
serious weaknesses in the management of the 
fund in key Member States, which might mean 
that border management is not adequately 
strengthened where it is most needed. 
EUROPEAN
COURT
OF AUDITORS