ISSN 1831-0834
EUROPEAN
COURT OF AUDITORS
2013
EN
Special Report No 13
EU DEVELOPMENT ASSISTANCE 
TO CENTRAL ASIA

EU DEVELOPMENT ASSISTANCE 
TO CENTRAL ASIASpecial Report No 13  2013
(pursuant to Article 287(4), second subparagraph, TFEU)
EUROPEAN COURT OF AUDITORS
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Special Report  No 13  2013
More information on the European Union is available on the Internet ( http://europa.eu ).
Cataloguing data can be found at the end of this publication.
Luxembourg: Publications Office of the European Union, 2013
ISBN 978-92-9241-474-0
doi:10.2865/66801
© European Union, 2013
Reproduction is authorised provided the source is acknowledged.
Printed in Luxembourg
CONTENTS
Paragraph
 ABBREVIATIONS
I–VII  EXECUTIVE SUMMARY
1–14  INTRODUCTION
3–6  THE EUROPEAN UNION AND CENTRAL ASIA
7–14 EU DEVELOPMENT ASSISTANCE
13–14  REVIEWS BY THE COUNCIL AND THE EUROPEAN PARLIAMENT
15–17  AUDIT SCOPE AND APPROACH
18–81  OBSERVATIONS
18–36 ALLOCATION OF THE BUDGET
19–21  THE COMMISSION SET BROAD OVERALL PRIORITIES FOR ITS SPENDING
22–23   THE COMMISSION DEPARTED IN SOME RESPECTS FROM BEST PRACTICE WHEN PLANNING AND ALLOCATING 
ASSISTANCE …
24–30  … BUT IN PRACTICE TOOK REASONABLE DECISIONS ABOUT ALLOCATION
31 AID LEVELS MIRRORED RELATIVE PROSPERITY
32–35  AID WAS ALLOCATED TO TOO MANY SECTORS …
36 … BUT IT REFLECTED THE COMMISSION’S STRATEGIC PRIORITIES
37–62 PUTTING THE POLICY INTO EFFECT
38–39  THE COMMISSION PROVIDED AID THROUGH A RANGE OF DELIVERY MODES
40–44  NUMEROUS SMALL PROJECTS AND FINANCING INSTRUMENTS: A MANAGEMENT CHALLENGE
45–51  LITTLE FOCUS ON ADMINISTRATIVE COSTS3
Special Report No 13/2013 – EU Development Assistance to Central Asia
52 OBJECTIVES AND INDICATORS: A MIXED PICTURE
53–58  BUDGET SUPPORT: THE COMMISSION COULD HAVE BEEN MORE RIGOROUS …
59–62  … AND IT DID NOT DECISIVELY LINK IT WITH CONDITIONS DESIGNED TO MINIMISE CORRUPTION
63–81 IMPLEMENTING AND REPORTING
64–67  IMPLEMENTATION SLOW OVERALL BUT VARIABLE  …
68–72  … WITH THE REGIONAL PROGRAMMES FAILING TO ACHIEVE A GENUINE REGIONAL DIMENSION
73–77  LEARNING FROM EXPERIENCE: SUCCESSES BUT ALSO MISSED OPPORTUNITIES
78–81  REPORTING: ON ACTIVITY RATHER THAN RESULTS
82–86  CONCLUSIONS
87 RECOMMENDATIONS
 ANNEX I  — GENERAL INFORMATION ABOUT THE CENTRAL ASIAN REPUBLICS
 ANNEX II  — PROGRAMMES EXAMINED
 ANNEX III  — COMMISSION ADMINISTRATIVE COSTS
REPLY OF THE COMMISSION AND THE EEAS4
Special Report No 13/2013 – EU Development Assistance to Central Asia
BOMCA : Border Management Programme in Central Asia
CADAP : Central Asia Drug Action Programme
CRIS : Common Relex Information System
DCI : Development Cooperation Instrument
EBRD : European Bank for Reconstruction and Development
EEAS : European External Action Service
EIDHR : European Instrument for Democracy and Human Rights
ENPI : European Neighbourhood and Partnership Instrument
EU: European Union
GDP : Gross domestic product
IfS: Instrument for Stability
IMF : International Monetary Fund
Inogate : Interstate Oil and Gas Transport to Europe Programme
MDGs : Millennium Development Goals
NGO : Non- governmental organisation
ODA : Official development assistance
OECD : Organisation for Economic Cooperation and Development
OSCE : Organisation for Security and Cooperation
PCA : Partnership and Cooperation Agreement
PEFA : Public Expenditure and Financial Accountability
PFM : Public financial management
PPP : Purchasing power parity 
RRM : Rapid reaction mechanism
RSP : Regional Strategy Paper
SBS : Sector budget support
SMART : Specific, measurable, achievable, relevant and time -boundABBREVIATIONS5
Special Report No 13/2013 – EU Development Assistance to Central Asia
TACIS : Technical Assistance to the Commonwealth of Independent States
TFEU : Treaty on the Functioning of the European Union
Traceca : Transport Corridor Europe–Caucasus–Asia Programme
Unicef : United Nations Children’s Fund
US dollar/USD : United States dollar6
Special Report No 13/2013 – EU Development Assistance to Central Asia
EXECUTIVE SUMMARY
I.
The audit assessed how the Commission and the 
European External Action Service (EEAS) planned and 
managed development assistance to the Central Asian 
republics (Kazakhstan, Kyrgyzstan, Tajikistan, Turkmen-  
istan and Uzbekistan) in the period 2007–12.
II.
The audit found that the Commission and the EEAS 
made serious efforts, in challenging circumstances, 
to plan and put into effect the programme of EU 
development assistance to Central Asia set out in the 
Regional Strategy Paper (RSP) of April 2007. Planning 
and allocation of assistance were generally satisfac -
tory. Implementation was less so.
III.
The Commission discussed priorities with partner 
countries and sought to align its spending plans with 
their national priorities. The geographical distribution 
of aid took account of relative prosperity. Projects cho -
sen for EU support all contributed towards meeting 
the broad objectives set out in the regional strategy 
paper. However, the Commission provided assistance 
to a larger number of sectors than is consistent with 
best practice.
IV.
The Commission made use of a variety of delivery 
modes in implementing its plans. It included a large 
number of small projects, which placed a greater 
administrative burden on delegations. Managing the 
programme was also made more difficult by the wide 
range of financial instruments involved and multiple 
lines of reporting, which makes it difficult to establish 
how much the EU has spent per sector and per coun -
try in Central Asia. The Commission has not attempted 
to assess the overall administrative costs of its devel -
opment assistance programme in Central Asia.V.
The Commission could and should have been more 
rigorous in managing its budget support programmes 
in Tajikistan and Kyrgyzstan and tied these to specific 
anti- corruption measures. Disbursement decisions 
were based on partner countries’ commitments to 
reform rather than on progress achieved.
VI.
Implementation was slow overall, though with some 
significant variations. The regional programmes did 
not achieve a genuine regional dimension; a signifi -
cant share consisted merely of ‘multi- country’ facil-  
ities available to each partner country individually. 
The Commission set up arrangements to enable it to 
learn from experience and improve its programmes 
over time. This process yielded useful results, although 
in some cases they were not always available on time, 
and in others useful recommendations were not taken 
on board. Its reports focused on activity rather than 
results.
VII.
This report sets out recommendations on how lessons 
learnt from experience gained in the 2007–12 period 
could be drawn for the future EU cooperation with 
this region.7
Special Report No 13/2013 – EU Development Assistance to Central Asia
1. This report discusses the planning and management of European Union 
(EU) development assistance to the five Central Asian republics (Kazakh -
stan, Kyrgyzstan, Tajikistan, Turkmenistan and Uzbekistan) during the 
period 2007–12 (see the  Map ).INTRODUCTION
MAP
CENTRAL ASIA
BAYKONUR COSMODROME
SIACHEN GLACIERVyatka
Qezel OwzanSeym
Syr  Darya
Amu  DaryaErtis
HelmandChulym
Chulym
Chulym
Irtysh
Katun
IndusKr
Lake
Balqash
Ysyk
Köl
Kara
Bog
GolCaspian
Sea
AFGHANISTANARMENIA
AZERBAIJANCHINARUSSIA
GEORGIA
INDIAIRANKAZAKHSTAN
KYRGYZSTANMONGOLIA
PAKISTANTAJIKISTANTURKMENISTANUKRAINE
UZBEKISTANTura
UralOb
Naryn
YarkantBiyaDon
ErtisTom’
TarimChulym
IleIrtysh
OkaKhopr
EsilKatunIshimVol
Volga
KrToxkanUfa
Syr DaryaVerkhniy Yenisey
Atrek (Atrak)Ertix (Irtysh)
Aral
Sea
Ashgabat DushanbeBishkekTbilisiAstana
Yerevan
BakuTashkent
Tehran
KabulMoscow
QarshiOshFargonaNamanganKurgan
Oostanay Kokshetau
ZhezqazghanPetropavlovsk
Taldyqorghan
DasoguzUrgentchIzhevsk
Oral
RashtTurkmenbasy
BukharaNukusQyzylorda
MaryChärjewRostov
na DonuPenza
VoronezhChelyabinsk
AstrakhanOrenburgSaratovOmskTyumen
Aqtobe
AtyrauPavlodar
Semey Oskemen
TabrizShymkentZhambyl
HeratSamarqandTomsk
VolgogradUfaYekaterinburg
SamaraKazan
Novosibirsk
BarnaulKrasnoyarsk Perm
Almaty
MashhadUrumqi
Qoqon
Qonduz
BaghlanTolyatti
ZaysanOrskRubtsovsk
Temirtau
Beyneu
AqtauMagnitogorskNovokuznetsk
Rudny
KashgarQaraghandy50˚ 60˚ 70˚ 80˚ 90˚
50˚
40˚
80˚ 70˚ 60˚ 50˚40˚50˚50˚ 50˚ 60˚ 70˚ 80˚ 90˚
50˚
40˚
80˚ 70˚ 60˚ 50˚40˚50˚40˚
0 200 400 600 800 km
0 100 200 300 400 500 mi
Source:  Based on UN Central Asia map No 3763, Rev. 7, December 2011. Responsibility for the adaptation lies entirely with the European 
Court of Auditors.8
Special Report No 13/2013 – EU Development Assistance to Central Asia
2. The five states, which became independent countries with the collapse 
of the Soviet Union in 1991, differ markedly in terms of population 
size, territorial area, endowment with natural resources and prosperity.  
Kazakhstan and Turkmenistan have large reserves of oil and gas, exports 
of which are reflected in their relatively high GDP per head. In terms of 
the achievement of the Millennium Development Goals (MDGs) the situ -
ation is diverse (see Annex I  for more detailed information about each 
of the countries). There is also variation in their relative willingness to 
cooperate and integrate with the rest of the world.
THE EUROPEAN UNION AND CENTRAL ASIA
3. The EU has been actively engaged with the countries of Central Asia 
since they became independent. The Commission’s 2002 to 2006 Strat -
egy Paper for Central Asia set out key objectives of the assistance strat -
egy. These were to promote the stability and security in Central Asian 
countries and to assist in their pursuit of sustainable economic develop -
ment and poverty reduction.
4. For the 2007–13 period, the European Commission (EC) set out its plans 
for development assistance in a regional strategy paper it adopted in 
April 20071. The EU’s policy towards Central Asia during the period to 
which the audit relates was agreed by the European Council in June 2007 
and is set out in the Council document ‘European Union and Central 
Asia: Strategy for a New Partnership’2 which endorsed the Commission’s 
approach.
5. Through the Council’s Strategy and the Commission’s assistance pro -
gramme, the EU defined the priorities for its cooperation with the region 
as a whole, highlighting security and stability as its main strategic inter -
ests. The strategy advocated active cooperation with the Central Asian 
states in order to promote peace, democracy and economic prosperity. 
In particular it:
 — proposed to make full use of a wide range of instruments, pro -
grammes, cooperation agreements3 and political dialogue;
 — sought to balance bilateral approaches with actions aimed at tack -
ling common regional challenges4;
 — identified seven main policy areas of particular importance5; and,1 European Commission, 
Regional Strategy Paper for 
assistance to Central Asia for 
the 2007–13 period.
2 Adopted by the European 
Council of 21–22 June 2007 
(Council document 
No 11177/1/07). Published by 
the Council in October 2007 
as ‘European Union and 
Central Asia: Strategy for 
a New Partnership’ (ISBN 978-
92-824-2244-1).
3 Currently Partnership and 
Cooperation Agreements 
(PCA) are in force with 
Kazakhstan, Kyrgyzstan, 
Tajikistan and Uzbekistan. At 
end May 2013, the PCA with 
Turkmenistan was not yet 
ratified.
4 Examples of common 
regional challenges 
are organised crime, 
human, drugs and arms 
trafficking, terrorism and 
non-proliferation issues, 
inter -cultural dialogue, 
energy, environmental 
pollution, water 
management, migration, 
border management and 
transport infrastructure.
5 Namely (i) good 
governance, the rule 
of law, human rights 
and democratisation; 
(ii) education and training; 
(iii) economic development, 
trade and investment; 
(iv) transport and energy; 
(v) environmental 
sustainability and water 
management; (vi) facing 
shared threats and 
challenges; (vii) intercultural 
dialogue.9
Special Report No 13/2013 – EU Development Assistance to Central Asia
 — increased the EU budget assistance for the 2007–13 financial per -
spective to around 750 million euro over the period6.
6. The European Commission opened a delegation in Kazakhstan in 1993; 
and upgraded sub -offices in Kyrgyzstan and Tajikistan to full EU delega -
tions at the end of 20097. In 2012 an EU delegation was established in 
Uzbekistan. In 2005, the European Council appointed a Special Repre -
sentative in Central Asia8 whose mandate was to promote good relations 
between the EU and Central Asian countries and to strengthen stability, 
cooperation, democracy and respect for human rights in the region as 
well as enhancing the EU’s effectiveness and visibility in the region.
EU DEVELOPMENT ASSISTANCE
7. Between 1991 and 2013 the EU allocated more than 2,1 billion euro in 
development and humanitarian assistance to these countries, of which 
750 million euro was for the 2007–13 period. During the 2007 to 2012 
period, the Commission paid 435 million euro in development assistance 
to Central Asia, of which Kyrgyzstan and Tajikistan have been the main 
beneficiaries (see  Graph 1 ).6 The EU assistance is mainly 
implemented through the 
Development Cooperation 
Instrument (DCI) (Regulation 
(EC) No 1905/2006 of 
the European Parliament 
and of the Council of 
18 December 2006 
establishing a financing 
instrument for development 
cooperation (OJ L 378, 
27.12.2006, p. 41)).
7 In 2011, the total number 
of staff dealing with 
development assistance in 
the three delegations was 74.
8 Council Decision 
2012/328/CFSP of 
25 June 2012 appointing 
the European Union Special 
Representative for Central 
Asia (OJ L 165, 26.6.2012, 
p. 59).
GRAPH 1
EU PAYMENTS TO CENTRAL ASIA, 2007–12 BY COUNTRY AND FOR THE REGION  
(IN MILLION EURO AND PERCENTAGE)
Source:  Court analysis of data from the Commission’s CRIS database.Kazakhstan
47,4
11 %
Kyrgyzstan
108,5
25 %
Tajikistan
109,5
25 %Turkmenistan
14,4
3 %Uzbekistan
22,0
5 %Central Asia Region
133,1
31 %10
Special Report No 13/2013 – EU Development Assistance to Central Asia
8. During the early years of this period, spending mainly took place under 
the Technical Assistance to the Commonwealth of Independent States 
(TACIS programme), whose main objectives were to promote transition 
to the market economy and to reinforce democracy and the rule of law.
9. As from 2007, TACIS was replaced by the Development Cooperation In -
strument (DCI), whose primary objectives are poverty reduction, sustain -
able economic and social development, and the integration of develop -
ing countries in the world economy. During this period, funds were also 
provided through other instruments such as the European Instrument for 
Democracy and Human Rights (EIDHR) and the Instrument for Stability 
(IfS) including the Rapid Reaction Mechanism (see Graph 2 ).
10.  The EU budget for development assistance to the Central Asia countries 
averaged 89 million USD in the years 2010 and 2011, compared with 
175 million USD by the United States, 165 million USD by Turkey, 124 mil -
lion USD by Japan and 109 million USD by Germany9.9 Based on the Official 
Development Assistance 
statistics published by 
the Organisation for 
Economic Cooperation and 
Development.
GRAPH 2
EU PAYMENTS TO CENTRAL ASIA, 2007–12 BY FINANCING INSTRUMENT  
(IN MILLION EURO)
Source:  Court analysis of data from the Commission’s CRIS database.0102030405060708090
2007 2008 2009 2010 2011 2012
Other Financing Instrument pre 2007 TACIS IfS (and RRM) EIDHR DCI Thematic DCI-ASIE11
Special Report No 13/2013 – EU Development Assistance to Central Asia
11.  In terms of overall economic significance, development assistance rep -
resents a small proportion of overall financial flows to the region. In 
particular, in the cases of Kazakhstan, Turkmenistan and Uzbekistan, the 
Official Development Assistance (ODA)10 represents less than 5 % of the 
annual foreign direct investments (FDI) and less than 0,2 % of the an -
nual gross domestic product (GDP). From 1991 to 2011, the European 
Bank for Reconstruction and Development (EBRD) had also committed 
5 945 million euro, in the form of loans, equity and guarantees, to the 
five countries, including 408 million euro in 2011.
12.  The Commission’s Directorate -General for Development and Cooper-
ation (EuropeAid) and, since 2011, the European External Action Service 
(EEAS)11 are responsible for formulating EU development policy, for the 
multi-annual planning of the external aid instruments, and defining sec -
toral policies for such external aid. This is done from Brussels with the 
assistance of the EU delegations in the partner countries.
REVIEWS BY THE COUNCIL AND THE EUROPEAN PARLIAMENT
13.  The Council regularly reviews progress in the implementation of the 
EU strategy for Central Asia. In its latest review12 the Council concluded 
that the strategy remains valid and that progress has been made in its 
implementation. Nevertheless, the Council considered that EU efforts 
should become more targeted and should contribute to the visibility 
and impact of the EU actions in Central Asia.
14.  In a 2011 report13 the European Parliament concluded that EU funds were 
insufficient to allow the EU to have an impact in all of the Council’s seven 
priority areas14 and urged better definition of the policy priorities. The 
Parliament emphasised that partner countries must comply with inter-  
national standards of democracy, governance, rule of law and human 
rights. Against the background of concerns about corruption, the Parl-  
iament called on the Commission to present a report — which is still 
pending — on the use of sector budget support in Kyrgyzstan and 
Tajikistan.10 Based on OECD statistics, 
in 2010 and 2011, the total 
average annual ODA to 
Kazakhstan, Turkmenistan 
and Uzbekistan was 
484 million USD, compared 
to the average annual FDI 
11 093 million USD in the 
same period and the GDP 
(in purchasing power parity) 
347 billion USD cumulatively 
for the three countries, as 
reported by the EBRD and the 
World Fact Book respectively.
11 The EEAS took the 
responsibilities over from 
the former Commission 
Directorate -General RELEX.
12 Council of the European 
Union, Council conclusions 
on Central Asia, 3179th 
Foreign Affairs Council 
meeting, Luxembourg, 
25 June 2012, and Council 
document No 11455/12.
13 European Parliament 
resolution of 
15 December 2011 on the 
state of implementation 
of the EU Strategy for 
Central Asia, Strasbourg, 
P7_TA(2011)0588.
14 The Council set out 
the following priorities: 
(a) good governance, the 
rule of law, human rights 
and democratisation; 
(b) education and training; 
(c) economic development, 
trade and investment; 
(d) transport and energy; 
(e) environmental 
sustainability and water 
management; (f ) facing 
shared threats and 
challenges; (g) intercultural 
dialogue.12
Special Report No 13/2013 – EU Development Assistance to Central Asia
15.  The audit assessed how the EEAS and the Commission planned and man -
aged development assistance to Central Asia, in the period 2007 to 2012, 
in particular assistance paid under the DCI, which was the main financing 
instrument. The audit asked:
 — whether, in allocating its budget, the Commission followed best 
practice and respected its declared priorities for development as -
sistance in Central Asia;
 — whether the Commission delivered development assistance in an 
appropriate way;
 — whether the Commission successfully implemented its aid policy, 
developed it in the light of experience and reported appropriately.
 Other aspects of the EU strategy, such as policy dialogue, were not in -
cluded in the scope of the audit.
16.  Audit work was carried out between June and November 2012. The audit 
assessment was based on documentary review and analysis and inter -
views. Visits were made in October 2012 to Kyrgyzstan, Tajikistan and Uz -
bekistan, during which the auditors interviewed EU delegation staff, rep -
resentatives of national authorities, Member States’ embassies, technical 
experts, civil society organisations, other donors and stakeholders. The 
auditors examined a total of 21 support programmes (19 country-specific 
and two regional programmes, see Annex II15).
17.  The audit made use of analyses from other sources, e.g. studies and 
reports by other donors. The Court carried out a survey on donor coor -
dination and on other donors’ perceptions of the EU’s work in the field, 
which was sent to other donors’ senior country-resident staff in each of 
the five Central Asian republics16.15 Selected so as to cover 
70 % of development 
cooperation instrument 
spending in the 2007–11 
period in Kyrgyzstan and 
Uzbekistan, and the sector 
budget support programmes 
in Tajikistan.
16 Of the 91 recipients of the 
survey, 28 replied.AUDIT SCOPE AND APPROACH13
Special Report No 13/2013 – EU Development Assistance to Central Asia
ALLOCATION OF THE BUDGET
18.  Paragraphs 19 to 36 below examine how the Commission allocated the 
EU budget: to what extent it followed best practice and followed its 
declared priorities for development assistance in Central Asia.
THE COMMISSION SET BROAD OVERALL PRIORITIES FOR ITS 
SPENDING
19.  As explained in paragraph 4, in line with the EU’s policy for Central Asia, 
the Commission’s Regional Strategy Paper (RSP) set out its spending 
priorities. It recalled that poverty reduction is the primary objective of 
EU development policy, with the promotion of good governance and 
greater respect for human rights as complementary objectives17. It iden -
tified three priority sectors for EU development assistance:
 — promoting regional cooperation, in particular networks and market 
integration, the environment, border and migration management, 
customs, the fight against organised crime and cross-border cooper-  
ation between individuals and within civil society;
 — reducing poverty and increasing living standards, in particular 
through community development and targeted rural development 
schemes; and reforms in agriculture and social protection;
 — promoting democratisation, human rights, good governance and 
economic reform.
20.  The Commission set itself the target of spending 30–35 %, 40–45 % and 
20–25 % respectively of its total budget on these three objectives.
21.  The Commission then split the period into two sub -periods (2007–
10 and  2011–13) and drew up an indicative programme for the first 
period which included more detailed plans for the allocation of aid 
and the identification of specific priorities. The Commission carried out 
a mid-term review in 2010 and concluded that no significant adjust -
ments were necessary. Based on the review, it prepared its expenditure 
plans for 2011–13.17 Joint statement by 
the Council and the 
representatives of the 
governments of the 
Member States meeting 
within the Council, the 
European Parliament and the 
Commission on European 
Union Development Policy, 
The European Consensus on 
Development (OJ C 46, of 
24.2.2006, p. 1).OBSERVATIONS14
Special Report No 13/2013 – EU Development Assistance to Central Asia
THE COMMISSION DEPARTED IN SOME RESPECTS FROM BEST 
PRACTICE WHEN PLANNING AND ALLOCATING ASSISTANCE …
22.  Recognised best practice in the allocation of development aid, as set out 
in, for example, the EU Consensus on Development, the Paris Declaration 
on Aid Effectiveness18 and the EU Code of Conduct on Complementarity 
and Division of Labour in Development Policy19 includes the principles 
that:
 — development priorities — set out in country strategies, policy dia -
logues and development cooperation programmes — should flow 
from clear analysis of recipient country national development strat -
egies, institutions and procedures;
 — if aid is to be fully effective, recipient countries should own the 
development strategies and programmes supported by donors;
 — EU donors should aim at focusing their active involvement in a par -
ticular country on a maximum of three sectors each.
23.  The RSP and indicative programmes provide only limited justification for 
the Commission’s detailed choice of spending priorities, for example in 
respect of how much should be spent on regional and how much on 
bilateral programmes; or why particular sectors or programmes were 
expected to produce the best value for money in relation to the EU 
objectives. In reality there was a considerable degree of continuity with 
previous patterns of spending in the countries concerned.
… BUT IN PRACTICE TOOK REASONABLE DECISIONS ABOUT 
ALLOCATION
24.  On the other hand the Commission’s allocation of expenditure in most 
respects represented a reasonable attempt to apply the RSP priorities.
25.  Continuity in the distribution of spending permitted the Commission 
to make optimal use of its previous experience particularly in Tajikistan 
and Kyrgyzstan.18 OECD, Paris Declaration 
on Aid Effectiveness, 2005 
(http://www.oecd.org/dac/
effectiveness/34428351.pdf ).
19 Council of the European 
Union, 9558/07, Brussels, 
15 May 2007.15
Special Report No 13/2013 – EU Development Assistance to Central Asia
26.  The Commission took care to ensure that its spending allocations were 
satisfactorily in line with those of other donors, avoiding overlaps and 
contributing to donor coordination. Three quarters of respondents to 
the Court’s survey of donors commended the choices of sectors to sup -
port. Two thirds considered that the Commission chose good quality 
programmes to support, particularly in the sectors of human rights and 
promotion of civil society .
27.  The Commission faced particular challenges in terms of coordination 
with partner countries:
 — Kazakhstan, Turkmenistan and Uzbekistan, not being Paris Declar-  
ation adherents, have not produced needs assessments for devel -
opment assistance or poverty reduction strategies in the form used 
in the EU’s programming ;
 — the RSP stated that the purpose of the EU’s development assistance 
was to support implementation of its political strategy, noting that 
the EU strives to promote prosperity, solidarity, human rights and 
democracy, decent work, security and sustainable development 
worldwide. For the partner governments, human rights, good gov -
ernance and development goals such as poverty reduction are not 
always of the highest priority;
 — National programming documents can lack clear focus. For exam -
ple, in Kyrgyzstan the action plan of the Country Development 
Strategy for the 2009 to 2011 period included 508 actions in 19 dif -
ferent sectors.
28.  Notwithstanding these difficulties, the Commission discussed aid prior-  
ities with the governments of the recipient countries and sought to align 
its spending with national plans, where they were available. The results 
of this process were reflected in the RSP and the indicative programmes.
29.  The programmes and projects which the Court examined in Kyrgyzstan 
and in Tajikistan were in line both with the Commission strategy and, 
so far as could reasonably be established, with the priorities of these 
recipient governments. For example:
 — in Kyrgyzstan, the support provided by the Commission to the edu -
cation sector from 2009 onwards assisted the government in plans 
to reform and develop the country’s education system;16
Special Report No 13/2013 – EU Development Assistance to Central Asia
 — in Tajikistan the Commission’s support for social protection fitted 
well with the government’s priority for the social sector, which was 
to increase the quantity and quality of social services for the poor 
and to achieve the relevant Millennium Development Goals.
30.  In Uzbekistan, likewise, the projects examined by the Court (for example 
support to reform the criminal justice system and improve the mater -
nal and child health systems) were in line with the country’s needs as 
defined by the government. On the other hand, alignment with needs 
identified by the government did not necessarily translate into full sup -
port by the authorities in the implementation of projects. For example, 
international experts working on the reform of criminal justice were 
denied access to prisons and court cases. In order to secure the gov -
ernment’s cooperation in its programme to reduce infant malnutrition, 
the Commission had to emphasise the promotion of healthy diets for 
mothers and children, as the Uzbek government did not admit that mal -
nutrition existed.
AID LEVELS MIRRORED RELATIVE PROSPERITY
31.  The Commission earmarked the highest levels of aid to the countries 
it perceived to be most in need and most willing and capable of best 
use of aid, namely Tajikistan and Kyrgyzstan. The allocation to these 
two countries was three times higher per head than for the other three 
recipients (see Table 1  and Annex I ).
TABLE 1
TOTAL AID ALLOCATED FOR THE DEVELOPMENT COOPERATION INSTRUMENT (DCI) IN 
CENTRAL ASIA UNDER RSP 2007–13 AND GDP PER CAPITA
AreaTotal allocations 2007–13
(million euro)GDP per capita in 2007
(current US dollar)
Kazakhstan 74 6 771
Kyrgyzstan 106 722
Tajikistan 128 563
Turkmenistan 53 2 606
Uzbekistan 71 830
Region 242
Total 674
Source:  EU–Central Asia Development Cooperation, European Commission, 2011 and the World Bank, World Development Indicators.17
Special Report No 13/2013 – EU Development Assistance to Central Asia
AID WAS ALLOCATED TO TOO MANY SECTORS …
32.  The Commission’s approach was however less satisfactory in respect of 
the number of sectors to which it paid assistance.
33.  As indicated in paragraph 22, a guiding principle of development policy 
to which the Commission has subscribed is that EU donors should aim to 
focus their efforts on a maximum of three sectors in any partner country, 
so as to optimise results and reduce transaction costs.
34.  Notwithstanding the small size of its development assistance programme 
in Central Asia, the Commission did not apply this principle rigorously. It 
selected four sectors for assistance in Kyrgyzstan (governance, agricul -
ture and rural development, education and social protection); in Tajik -
istan five sectors (governance, agriculture and rural development, social 
protection, private sector and health); and in Uzbekistan six (private 
sector, governance, health, agriculture and rural development, environ -
ment and energy and education).
35.  In addition, the Commission channelled EU development assistance 
money to various additional sectors through regional and thematic pro -
grammes. These programmes supported sectors such as energy, trans -
port, environment, water, border management and the fight against 
drugs, rule of law, democracy and human rights, private sector develop -
ment and higher education.
… BUT IT REFLECTED THE COMMISSION’S STRATEGIC PRIORITIES
36.  An analysis of the Commission’s database by the Court identified no 
significant instances where aid was provided to a national programme 
which did not address one of the wide objectives of reducing poverty 
and improving governance; many national programmes are directed at 
both poverty reduction and good governance. The amounts contracted 
by the end of 2012 respected the priorities set out in the RSP (see para -
graph 20).18
Special Report No 13/2013 – EU Development Assistance to Central Asia
PUTTING THE POLICY INTO EFFECT
37.  Paragraphs 38 to 62 below examine the methods by which the Commis -
sion delivered aid: its choice of delivery modes, the attention which the 
Commission gave to administrative costs, whether programmes included 
clear objectives and performance indicators to permit monitoring; and 
the Commission’s design and management of the budget support pro -
vided in two of the Central Asian republics.
THE COMMISSION PROVIDED AID THROUGH A RANGE OF DELIVERY 
MODES
38.  The Commission implemented its aid programmes in a number of ways, 
according to circumstances (see examples in Box 1 ):
 — contribution agreements with international organisations, where 
these had developed activities in the partner countries and were 
accepted as partners by the authorities;
 — budget support where it was eligible, given that, where conditions 
allow, it is the preferred method of development cooperation  accord -
ing to the European Consensus on Development20;
 — grants to non- governmental organisations (NGOs) where civil  
society was active;
 — service contracts (and a few works contracts), in particular tech -
nical assistance, where the aim was convergence with European 
standards and good practices, in combination with sector budget 
support.20 Paragraph 113 of the 
European Consensus on 
Development.19
Special Report No 13/2013 – EU Development Assistance to Central Asia
EXAMPLES OF PROGRAMMES FINANCED BY THE EU
Contribution agreement with an international organisation
The support to prison reform project  aims at improving prison management and social reintegration of 
offenders, by developing a prison reform programme in Kyrgyzstan. Enhancing hygiene and supporting 
income -generating activities are also among the actions provided by the programme. The overall budget 
of the action implemented by the United Nations Office on Drugs and Crime is 2,78 million euros of which 
the EU contributes to 2,5 million euros.
Budget support programme
The sector policy support programme in social protection and public finance management  in Kyr -
gyzstan is funded through geographical and thematic financing instruments. The 7- year strategy paper allo -
cated 53 million euros to the programme. The social protection component aims to develop a more efficient 
social assistance system that would improve the conditions of vulnerable people and deprived children. 
In parallel, the public finance management component aims to assist the Kyrgyz government to improve 
its annual budget process in terms of transparency, accountability, predictability and its internal controls.
Grant to a non‑governmental organisation
The Commission co -financed 80 % of a project on the strengthening of children and families in need  with  
200 000 euro. The project is implemented by the Uzbek division of SOS Children’s Villages, an international 
NGO present in Uzbekistan since 1996. The contract was signed in 2011 as part of the institution building 
partnership programme, which aimed to improve the living standards of vulnerable groups in Uzbekistan 
by strengthening the cooperation between NGOs and local authorities.
Service contract: technical assistance programme combined with a sector budget support 
programme
Tajikistan. Since 2007, in order to support the social protection sector budget support programme, the 
Commission has developed a  technical assistance and capacity development programme  focusing on: 
(a) improvement of the targeting and rationalisation of the social benefit schemes; (b) the development 
of social services; (c) the modernisation of the residential care institutions system; (d) the development of 
labour market policy. The overall budget of the programme is 5 million euro, and it was contracted out to 
seven European consultancy firms with contracts varying from 90 000 euro to 2,5 million euro.BOX 120
Special Report No 13/2013 – EU Development Assistance to Central Asia
39.  The Commission made use of all these delivery modes (see Table 2 ).
NUMEROUS SMALL PROJECTS AND FINANCING INSTRUMENTS: 
A MANAGEMENT CHALLENGE
40.  As indicated in Table 2 , grants and service contracts constituted a large 
proportion by number (but a small proportion by value) of the Commis -
sion’s aid efforts in Central Asia. The administrative implications of such 
a high number of programmes can be considerable21.
41.  The EU delegation in Kyrgyzstan was managing 56 contracts at the time 
of the audit. The delegation reported that it was significantly constrained 
in its ability to visit the places where the contracts’ activities were im -
plemented. The delegation was also providing support22 for another 99 
contracts managed by the headquarters services.21 For example, with 
grant programmes, the 
Commission staff, including 
those in the delegations, 
have to manage the entire 
project cycle, i.e. drafting and 
issuing calls for proposals, 
briefing participants, drawing 
up and signing contracts, 
monitoring and supervising 
implementation, managing 
financial and payment cycles, 
arranging audits, evaluations 
and reporting.
22 This type of support 
involves providing feedback 
on the proposals submitted 
by the beneficiaries, 
coordinating the activities 
of the project in the country 
and representing them by 
participating in committees, 
seminars, etc.
TABLE 2
AMOUNTS CONTRACTED UNDER THE DCI AND DCI‑THEMATIC PROGRAMMES 
BETWEEN 2007 AND UP TO END OF 2012 BY DELIVERY MODE
Number of contracts/  
agreements signedAmount contracted  
up to end of 2012
(million euro)% of the total 
(by value)
Contribution agreements 33 128 36 %
Budget support 
programmes15 98 28 %
Grants to NGOs 143 61 17 %
Service and works contracts 244 66 19 %
435 353 100  %
Source:  Court analysis of data from the Commission’s CRIS database.21
Special Report No 13/2013 – EU Development Assistance to Central Asia
42.  The Commission provides development assistance in Central Asia 
through various financing instruments. The Development Cooper-  
ation Instrument is the main source of funds, through its geographic 
programme for Asia as well as through five thematic DCI instruments: 
Food Security, Non-State Actors and Local Authorities in Development, 
Migration and Asylum, Environment and Sustainable Management of 
Natural Resources including Energy, and Investing in People. Five global 
instruments also provide funding to Central Asia (see paragraph 8) as 
well as the European Neighbourhood and Partnership Instrument (ENPI), 
which fall under the responsibility of different parts of the Commission’s 
headquarters.
43.  This panoply of sources of finance added further complexity to the man -
agement of EU spending, both within delegations and centrally. For 
example, for 31 of the 56 contracts which the delegation in Kyrgyzstan 
was managing at the time of the audit, it liaised with EuropeAid’s geo -
graphical unit for Central Asia. For the remaining 25, it liaised with six 
other units in EuropeAid and one unit in the EEAS. The delegation’s 
support for the other 99 contracts required it to liaise with 11 units in 
EuropeAid, two other EU delegations (in Kazakhstan and Tajikistan), the 
EEAS, and the Commission’s Directorates- General for Research and In -
novation, and Economic and Financial Affairs.
44.  The proliferation of spending instruments also makes it difficult to es -
tablish (without time -consuming ad hoc exercises) how much the EU 
has spent per country and per sector in Central Asia:
 — the Commission’s Common RELEX Information System (CRIS) 
does not identify spending per partner country in the regional 
programmes23;
 — CRIS reports do not include the country component of regional and 
global programmes, particularly under the European Instrument 
for Democracy and Human Rights (EIDHR) and the Instrument for 
Stability (IfS);
 — finally, the Commission does not specify spending in Central Asian 
countries under programmes financed by the European Neighbour -
hood and Partnership Instrument24.23 See the European Court 
of Auditors Special Report 
No 5/2012 on the Common 
External Relations Information 
System ( www.eca.europa.eu ).
24 Such as the Transport 
Corridor Europe–Caucasus–
Asia (Traceca) and the 
Interstate Oil and Gas 
Transport to Europe (Inogate).22
Special Report No 13/2013 – EU Development Assistance to Central Asia
LITTLE FOCUS ON ADMINISTRATIVE COSTS
45.  The provision of development assistance, often in difficult circumstances, 
can be a labour -intensive and costly activity. Decisions about what and 
how to spend need to balance considerations of likely results on the one 
hand and costs on the other, with results (particularly in a sensitive area 
like Central Asia) judged from a comprehensive perspective . Nonetheless, 
the costs of administering segments of an aid budget are something of 
which an aid agency can reasonably be expected to be aware.
46.  The Commission manages administrative costs by a combination of 
methods, including workload assessments for each delegation. However, 
the Commission has not set up a system for reporting on the overall 
administrative cost involved in delivering its development assistance, 
at regional or country level.
47.  The Court estimated the administrative cost of the Commission’s de -
velopment activities in Central Asia on the basis of Commission data. 
The Court included in its estimate the staff cost and administrative cost 
associated with the development assistance staff in headquarters and 
delegations. Support expenditure (e.g. Europa Houses25, consultancy and 
monitoring services) was also included.
48.  The Court calculated that relevant administrative costs in 2011, the lat -
est complete year at the date of the audit, were 10,5 million euro (see 
Annex III ). Out of this, 6,6 million euro (63 %) was for development co -
operation work (staff salaries and other operational expenditure) in the 
three delegations that were then open (see paragraph 6); headquarters 
staff costs were 1,8  million  euro (17 %) and various support expenditure 
(including the cost of consultancy to support the identification and 
formulation of projects, results -oriented monitoring and evaluation and 
also costs related to Europa Houses) was 2,1 million euro (20 %)26.
49.  This sum represents 14,6 % of the development spending in Central Asia 
in 2011 (71,7 million euro)27. The percentage should be regarded as an 
order of magnitude rather than as a precise estimate: the arithmetic is 
sensitive for example to changes in the level of annual disbursements.25 Europa Houses, set up by 
the Commission, are acting as 
technical support offices for 
EU actions and increase the 
awareness and visibility of EU 
policies in countries where 
there is no EU delegation.
26 Costs relating to technical 
assistance associated with 
the implementation of 
specific projects in partner 
countries were not included 
in support expenditure in the 
calculation.
27 Excluding consultancy 
costs relating to identifying 
projects, results- oriented 
monitoring and evaluation 
from the calculation would 
reduce this figure to 12,7 %.23
Special Report No 13/2013 – EU Development Assistance to Central Asia
50.  In addition, the individual budgets of programmes included adminis -
trative costs. For example, the Court’s examination of 20 grants and 
contribution agreements with international organisations showed that, 
on average, 6 % of their budgets were identified as general administra -
tive costs. For budget support programmes, the corresponding figures 
were much lower in percentage terms. The cost of the regular progress 
reviews which were contracted to external experts added up to 1,1 % 
of the programme’s budget in Tajikistan and about 1,6 % in Kyrgyzstan.
51.  Since the Commission does not report an indicator for administrative 
costs, it is not possible to compare these estimates with the cost it incurs 
in running aid programmes elsewhere in the world. The Court however 
notes with concern that the Commission appears to have imperfect in -
formation on administrative costs representing a substantial proportion 
of the cost of its development assistance spending in Central Asia.
OBJECTIVES AND INDICATORS: A MIXED PICTURE
52.  The Court’s examination of programmes in the three countries visited 
revealed a mixed picture in so far as setting SMART objectives (and 
the indicators to assess them) was concerned, as the examples below 
illustrate:
 — in Tajikistan six out of seven technical assistance programmes exam -
ined had well- defined output targets for the preparation of sector 
studies, strategies, guidelines and recommendations to the govern -
ment. On the other hand, the technical assistance programme sup -
porting the Ministry of Finance had vaguely formulated objectives;
 — in Kyrgyzstan the food security information programme contained 
vague indicators, such as ‘food security information is generally ac -
cepted to be accurate and timely’ , ‘adequate numbers of staff are 
trained’ and, ‘usefulness of crop forecast’ . On the other hand, the 
programme for ‘operationalising good governance for social justice’  
defined quantified targets;
 — in Uzbekistan two out of the four programmes examined had quan -
tifiable objectives but no benchmarks and baselines were defined 
to allow assessment of the added value of the programmes.24
Special Report No 13/2013 – EU Development Assistance to Central Asia
BUDGET SUPPORT: THE COMMISSION COULD HAVE BEEN MORE 
RIGOROUS …
53.  Sector budget support (SBS) constitutes a transfer of EU resources to the 
national treasury of a beneficiary country in support of sector -specific 
policy goals and reform objectives. The Commission’s development assis -
tance in Central Asia included SBS to Kyrgyzstan and Tajikistan in favour 
of social protection, under which it paid, in the period 2007 to 2012, 
39,4 million euro and 24,4 million euro respectively.
54.  The Commission requires any country which receives budget support 
to put in place a relevant and credible programme to improve public 
financial management (PFM)28. In order to ensure that a sector budget 
support programme achieves its objectives, both in terms of sector de -
velopment and PFM improvements, the Commission attaches conditions. 
The Commission makes payments of budget support in tranches spread 
over several years, subject to the country’s fulfilling these conditions, 
which need to be clear and to be rigorously enforced if they are to be 
effective.
55.  The Commission followed this pattern in its budget support programmes 
in Tajikistan and Kyrgyzstan. Both governments had a PFM programme; in 
both cases the Commission made SBS disbursements conditional upon 
progress in carrying it out.
56.  In 2007, the Commission suspended the Tajik SBS programme for 2 years 
because the International Monetary Fund (IMF) discovered that the Min -
istry of Finance had issued guarantees that were putting the state budg -
et and macro -economic stability at risk. The programme was resumed 
in 2009 following agreement with the IMF. The Commission’s reaction 
contributed to the resolution of the issue.28 Based on the weaknesses 
and strengths identified by 
the PEFA (Public Expenditure 
and Financial Accountability) 
assessment. The PEFA-PFM 
Performance Measurement 
Framework is a tool to assess 
the PFM system in a country 
using 28 indicators.25
Special Report No 13/2013 – EU Development Assistance to Central Asia
57.  However, in other respects the Commission’s enforcement of PFM condi -
tions was insufficiently rigorous. The Commission disbursed its budget 
support in Kyrgyzstan in three tranches29, each of which was preceded 
by an assessment of progress towards PFM objectives30. The Commission 
assessed that progress had been slow, but justified the disbursement of 
each of the three tranches mainly because it considered that the Kyrgyz 
government remained committed to further reforms. There was no clear 
evidence for this opinion. A core part of the Commission’s reasoning 
for its disbursement decisions is based on its assessment of the partner 
countries’ commitment to reform rather than on the actual progress 
achieved31.
58.  With regard to SBS for social protection during the period 2007–09 in 
Tajikistan, the Commission had not defined strict deadlines by which 
the government had to comply with the conditions. As a result, the 
partner country did not have an incentive to press forward with required 
reforms, and implementation of the reforms required from government 
was delayed. However, the Commission addressed this weakness in the 
subsequent sector budget support programme.
… AND IT DID NOT DECISIVELY LINK IT WITH CONDITIONS DESIGNED 
TO MINIMISE CORRUPTION
59.  Corruption is a serious problem in the republics of Central Asia. In Trans -
parency International’s Corruption Perceptions Index, all were rated at 
less than 28 out of 100 in 2011, with Kyrgyzstan, Turkmenistan and Uz -
bekistan in the bottom 10 % of the 182 countries surveyed. Besides 
that, international organisations regularly report that the anti -corruption 
strategies of Kyrgyzstan and Tajikistan are progressing poorly32.
60.  Such pervasive corruption may affect the Commission’s reputation and 
reduce the effectiveness of the support programmes.
61.  PFM programmes can be used to combat corruption. The Tajik and Kyrgyz 
PFM programmes contained measures aimed at improving the efficiency 
and transparency of government financial management which could 
be expected to assist in reducing corruption, such as improved internal 
controls, procurement procedures and internal auditing in the public 
administration.29 June 2008, 
December 2010, July 2011.
30 The Commission 
used reports by external 
consultants as input for these 
assessments.
31 This practice diverges from 
the Court’s recommendation 
in the Special Report 
No 11/2010 ‘The 
Commission’s management 
of general budget support 
in ACP , Latin American 
and Asian countries’: The 
Commission should support 
disbursement decisions 
with a more structured and 
formalised demonstration of 
satisfactory progress during 
the period concerned by 
clearly setting the criteria 
against which progress is to 
be assessed and specifying 
the progress made and the 
reasons why progress may 
not have been according to 
plan.
32 Organisation for 
Economic Cooperation and 
Development (OECD) reports: 
Istanbul Anti- Corruption 
Action Plan, Second Round of 
Monitoring, Kyrgyz Republic, 
Progress Report, 24/2/2012 
and Istanbul Anti- Corruption 
Action Plan, Second Round 
of Monitoring, Tajikistan, 
Progress Report, 16/2/2012.26
Special Report No 13/2013 – EU Development Assistance to Central Asia
62.  The Commission implements PFM, technical cooperation and justice 
reform programmes, which certainly have a positive impact on the pre -
vention of corruption. However, the Commission did not attempt to 
tie its budget support programmes directly to specific anti- corruption 
measures, for example criminalisation of corruption, corruption preven -
tion measures and strengthening public institutions’ accountability.
IMPLEMENTING AND REPORTING
63.  Paragraphs 64 to 81 below examine three aspects of the Commission’s 
management of its aid policy over the audited period: to what extent and 
how rapidly the Commission succeeded in implementing its aid policy, 
whether it modified its programmes in the light of experience and the 
way in which it reported on its provision of development assistance in 
Central Asia.
IMPLEMENTATION SLOW OVERALL BUT VARIABLE …
64.  As at the end of 2012, 50 % of overall planned commitments for the 
2007–13 period under the DCI–Asia instrument had been contracted 
and 27 % paid (see Table 3 ).
TABLE 3
AreaTotal allocations 2007–13
(million euro)Contracted amounts 
2007–12Disbursed amounts 
2007–12
Kazakhstan 74 60 % 28 %
Kyrgyzstan 106 73 % 45 %
Tajikistan 128 65 % 32 %
Turkmenistan 53 21 % 13 %
Uzbekistan 71 28 % 9 %
Region 242 42 % 26 %
Total 674 50 % 27 %
Source:  EU–Central Asia Development Cooperation, European Commission, 2011 and data extracted from CRIS.CENTRAL ASIA REGIONAL STRATEGY 2007–13. DCI–ASIA IMPLEMENTATION AS OF 
31.12.2012  — CONTRACTS AND DISBURSEMENTS27
Special Report No 13/2013 – EU Development Assistance to Central Asia
65.  The audit identified cases in which there were long delays in getting 
programmes under way. For example, in the sample of programmes ex -
amined in Uzbekistan, it took, on average, 2 years to sign the financing 
agreement and 1  year to start the implementation of the programme. 
Heavy bureaucratic procedures in recipient administrations, difficulties in 
finding suitable fundable activities and complex Commission procedures 
contributed to delaying the strategy implementation. About three quar -
ters of the respondents to the Court’s survey of aid donors said that the 
Commission’s procedural and legal requirements were too complicated.
66.  Speed of implementation varied significantly among recipient countries. 
Progress has been particular slow in Turkmenistan and Uzbekistan. This 
was mostly due to the differences in priorities and approaches to devel -
opment cooperation between the EU and these countries. In addition, 
important political events, such as the Andijan events in Uzbekistan in 
May 2005, slowed development cooperation activities during the first 
3 years of the period examined, and it was difficult for the Commission 
to compensate for the time lost.
67.  In Kyrgyzstan and Tajikistan implementation was faster. This reflects the 
improvement in development cooperation between the EU and the two 
countries, which are both Paris Declaration adherents. During the period 
examined, a significant part of the assistance to these partner coun -
tries was provided through sector budget support. During the period 
2007 to 2012, the Commission provided budget support amounting to 
24,4 million euro for Tajikistan (22 % of the aid provided) and 39,4 mil-
lion euro for Kyrgyzstan (36 % of the aid).
… WITH THE REGIONAL PROGRAMMES FAILING TO ACHIEVE 
A GENUINE REGIONAL DIMENSION
68.  As set out in its RSP , and in conformity with the EU strategy, the Com -
mission committed about one third of the strategy budget to regional 
programmes aiming to achieve leverage for its political efforts to pro -
mote regional cooperation (see paragraphs 19 to 20). Although this was 
consistent with the strategy objectives, the regional programmes have 
not achieved the ‘genuine regional dimension both in terms of joint 
implementation and in terms of regional impact’ envisaged by its de -
velopment strategy33.33 European Commission, 
Regional Strategy Paper for 
Assistance to Central Asia for 
the 2007–13 period.28
Special Report No 13/2013 – EU Development Assistance to Central Asia
69.  Running regional programmes added an extra layer of difficulty for the 
Commission. It needed to obtain agreement from all beneficiary coun -
tries at each stage of programme preparation, though the degree of 
political commitment to regional programmes varied from country to 
country and from programme to programme.
70.  A considerable share of the regional funds of the RSP34 have been com -
mitted to programmes such as Erasmus and Tempus (36 %) and the 
Investment Facility for Central Asia programme (29 %). These ‘multi- coun -
try’ programmes mainly replicate similar activities in more than one ben -
eficiary country rather than promote cooperation between the Central 
Asian republics.
71.  The Border Management Programme for Central Asia (BOMCA) provides 
an example of varying participation among recipient countries. BOMCA 
focuses on border management reform. With a total commitment of 
33,7 million euro from 2003 until 2014, its long-term strategic goal is the 
adoption of EU standards and good practices in the field of integrated 
border management. BOMCA is implemented by the United Nations 
Development Programme, based in Bishkek with offices in each of the 
five republics.
72.  Kyrgyzstan and Tajikistan are relatively committed to participation in 
BOMCA. However, after almost 10 years of implementation, Uzbekistan 
and Turkmenistan participated selectively in the regional capacity-build -
ing activities, and were unwilling to share their professional experience 
with the other countries.34 RSP allocated 
242 million euro to the 
regional cooperation.29
Special Report No 13/2013 – EU Development Assistance to Central Asia
LEARNING FROM EXPERIENCE: SUCCESSES BUT ALSO MISSED 
OPPORTUNITIES
73.  In 2010 the Commission carried out a mid-term review (see paragraph 21) 
in order to assess whether the priorities and the delivery modes used 
during the first indicative programme 2007–10 were still appropriate. As 
a result of the mid-term review the 2011–13 indicative programme took 
into account new developments in the partner countries, such as the 
gradual development of civil society, the need for technical assistance 
programmes to be combined with budget support and institutional re -
form programmes, the requirement to support local production and 
infrastructure.
74.  The indicative programme also included some new types of programmes 
that had been tested in other geographical regions, such as the invest -
ment facility programme35. The Commission did not however take the 
opportunity to give higher priority to promoting twinning and second -
ment of staff between EU and Central Asian administrations, a priority 
identified in the Council’s strategy for EU–Central Asian relations.
75.  The Commission made significant efforts to learn from experience and 
improve programmes during the period examined. The relative stability 
and continuity of the Commission’s support in terms of priority sectors, 
delivery modes and programmes meant that lessons learnt could be 
taken into account. Bilateral programmes, such as the one to improve 
mother and child health services in Uzbekistan (see Box 2 ) and the sec -
ond launch of the Institution Building and Partnership Programme im -
proved from lessons learnt in previous phases. The  Central Asia Drug 
Action Programme (CADAP) also provides an example of a regional pro -
gramme in which lessons learnt led to improved alignment with the 
needs of the partner countries.
76.  On the other hand, two Results- Oriented Monitoring (ROM) reports, as -
sessing the impact and sustainability of the BOMCA phase-7 programme, 
were made available only after the subsequent phase had been designed.35 Programmes initiated 
earlier in Africa (2007) and in 
Neighbourhood countries 
(2008).30
Special Report No 13/2013 – EU Development Assistance to Central Asia
77.  The budget support programmes in Kyrgyzstan and Tajikistan followed 
earlier, comparable programmes in support of food security. The Com -
mission reviewed experience of these earlier programmes in 2008 and 
made improvements in sector -specific areas and in the use of technical 
assistance to support the programmes. However the Commission did 
not take on board useful recommendations such as the following:
 — to put the programmes on a multiannual basis, as 1 year is a very 
short period to allow for overall progress assessment and aid 
predictability;
 — to define clearly the conditions for releasing payments;
 — to focus on a few key areas, with two or three conditions spread 
across several years.
BOX 2
UZBEKISTAN
The improvement of mother and child care services  is a programme which focuses on the achievement of 
Millennium Development Goal (MDG) 4 — Reduction of child mortality and MDG 5 — Improvement of maternal 
health. The programme started in 2007 with a budget of 3,5  million  euros and is implemented by the United 
Nations Children’s Fund (Unicef ) with the cooperation of the Uzbek Ministry of Health. Following a positive 
assessment of the programme made in 2010, the Commission decided to finance the second phase of the 
programme with an additional budget of 7,2 million euros.31
Special Report No 13/2013 – EU Development Assistance to Central Asia
REPORTING: ON ACTIVITY RATHER THAN RESUL TS
78.  The Commission produces two key annual reports relevant to its devel -
opment assistance. First, the Director -General of EuropeAid produces an 
annual activity report on the directorate -general’s activities. Second, the 
Commission publishes an annual report on EU development and exter -
nal assistance policies and their implementation. Both reports contain 
a chapter on development aid to Central Asia.
79.  The annual activity reports contain  seven indicators for Central Asia36. 
Though of general relevance to the success of EU development assis -
tance in Central Asia, these indicators are different from those set in the 
Regional Strategy Paper and the indicative programmes; nor are they 
directly linked to the intended results of the Council’s new partnership 
strategy for Central Asia.
80.  The Central Asia section in each year’s annual report on EU development 
and external assistance policies is narrative in style. Although it contains 
some examples, it provides little information on measurable results of EU 
activities and their impact on the population, does not present indica -
tors relevant to the EU’s activities and does not compare achievements 
with targets. The report generally avoids references to difficulties and 
obstacles to the implementation of the EU’s objectives.
81.  None of the reports produced compares the distribution of spending 
with the distribution set out in the RSP (see paragraph 20) or provides 
information about administrative costs (see paragraphs 45 to 51).36 These indicators are: 
(i) Partnership cooperation 
agreements: Number of PCAs 
ratified; (ii) Democratisation/
Rule of law — Number of 
countries moving towards 
elections up to OSCE norms 
and Council of Europe/Venice 
Commission standards; 
(iii) Education initiative for 
Central Asia: Number of CA 
countries associated with 
the Bologna process; (iv) 
Environment/water/energy: 
Countries adopting national 
climate change strategies 
and implementing the EU’s; 
(v) MDG 1 — Percentage 
of Central Asia population 
under poverty level; (vi) MDG 
4 — Infant mortality; (vii) 
MDG 6 — Combat against 
HIV/AIDS, malaria and other 
diseases.32
Special Report No 13/2013 – EU Development Assistance to Central Asia
82.  The Commission and the EEAS made serious efforts, in challenging cir -
cumstances, to plan and put into effect the programme of EU develop -
ment assistance to Central Asia set out in the Regional Strategy Ppaper 
of April 2007. Planning and allocation of assistance were generally sat -
isfactory. Implementation was less so.
83.  The Commission discussed priorities with partner countries and sought 
to align its spending plans with their national priorities. The geographical 
distribution of aid took account of relative prosperity. Projects chosen 
for EU support all contributed towards meeting the broad objectives set 
out in the Regional Strategy Paper. However, the Commission provided 
assistance to a larger number of sectors than is consistent with best 
practice.
84.  The Commission made use of a variety of delivery modes in imple -
menting its plans. It included a large number of small projects, which 
placed a greater administrative burden on delegations. Managing the 
programme was also made more difficult by the wide range of financial 
instruments involved and multiple lines of reporting, which makes it dif -
ficult to establish how much the EU has spent per sector and per country 
in Central Asia. The Commission has not attempted to assess the overall 
administrative costs of its development assistance programme in Central 
Asia.
85.  The Commission could and should have been more rigorous in managing 
its budget support programmes in Tajikistan and Kyrgyzstan and tied it 
to specific anti -corruption measures. Disbursement decisions were based 
on partner countries’ commitments to reform rather than on progress 
achieved.
86.  Implementation was slow overall, though with some significant vari -
ations. The regional programmes did not achieve a genuine regional 
dimension; a significant share consisted merely of ‘multi- country’ facili -
ties available to each partner country individually. The Commission set 
up arrangements to enable it to learn from experience and improve its 
programmes over time. This process yielded useful results, although in 
some cases they were not always available on time, and in others use -
ful recommendations were not taken on board. Its reports focused on 
activity rather than results.CONCLUSIONS33
Special Report No 13/2013 – EU Development Assistance to Central Asia
87.  Assuming that European Union development assistance programmes in 
Central Asia will continue37, the Court recommends that in planning and 
implementing the future development assistance the Commission and 
EEAS should draw on experience from the 2007–12 period. In particular, 
the Commission and EEAS should:
 — design any future regional programmes so that they are likely to 
achieve a genuine regional dimension;
 — concentrate all assistance provided on a small number of sectors;
 — set up a system for calculating and reporting on the overall ad -
ministrative cost involved in delivering its development assistance;
 — define and apply robust and objectively verifiable conditions for 
any continuing budget support programmes, in particular giving 
sufficient attention to support for anti- corruption mechanisms;
 — improve programme design and delivery in the light of lessons 
learnt and changing circumstances;
 — report on results and impact in a way that allows comparison with 
plans and objectives.
This Report was adopted by Chamber III, headed by Mr Karel PINXTEN, 
Member of the Court of Auditors, in Luxembourg at its meeting of 
15 October 2013.
For the Court of Auditors
Vítor Manuel da SILVA CALDEIRA
President37 COM(2011) 840 final of 
7 December 2011.RECOMMENDATIONS
34
Special Report No 13/2013 – EU Development Assistance to Central Asia
ANNEX I
Country Kazakhstan Kyrgystan Tajikistan Turkmenistan Uzbekistan Source
General
Area ('000 sq.km.) 2 725 200 143 488 447 1
Population (in '000, July 2013 estimate) 17 736 5 548 7 910 5 055 28 661 1
Population growth (July 2013 estimate) 1,20 % 0,97 % 1,79 % 1,15 % 0,94 % 1
Economy
GDP (PPP in billion US dollar,  
2012 estimate)231,3 13,47 17,72 47,55 104,7 1
GDP per capita (PPP in US dollar) 13 040 2 430 2 240 9 410 3 650 1
GDP growth, 2011 7,5 % 5,7 % 7,4 % 14,7 % 8,3 % 2
Official development assistance (ODA)
ODA received per capita (in US dollar) 18 65 55 7 7 3
EU ODA per capita (in US dollar) 1,0 5,6 4,0 1,9 0,4 4
Corruption and institutional reforms
Corruption Perceptions Index  
(0 worst to 100 best)28 24 22 17 17 5
Civil society (1 best to 7 worst) 6,00 4,75 6,00 7,00 7,00 6
Judicial framework and independence 
(1 best to 7 worst)6,50 6,25 6,25 7,00 7,00 6
Democracy score (1 best to 7 worst) 6,54 6,00 6,18 6,93 6,93 6
Sources:  
1 The World Fact Book , Central Intelligence Agency, updated 2013.
2 European bank for Reconstruction and Development (EBRD), Transition Indicators 2012.
3 World Bank 2012, annual average based on data for 2008, 2009 and 2010.
4  Court’s estimate based on the average annual disbursements from 2007 to 2012 from the CRIS database (the regional programmes 
are evenly distributed among the partner countries).
5 Transparency International, Corruption Perception Index, 2012.
6 Freedom house, Nations in Transit, 2012.GENERAL INFORMATION ABOUT THE CENTRAL ASIAN REPUBLICS35
Special Report No 13/2013 – EU Development Assistance to Central Asia
ANNEX II
InstrumentDecision 
numberProgrammeAmount 
committed 
(in thousand 
euro)
Kyrgyzstan
DCI -ASIE 19225 Support to Economic Diversification in Kyrgyzstan, Agroprocessing 1 600 
DCI -ASIE 19222 Support to Prison Reform in Kyrgyzstan 3 000 
DCI -ASIE 19241 Support to the Kyrgyz Education Sector 5 500 
DCI -ASIE 19237Sector Policy Support Programme — Social Protection and PFM — Kyrgyzstan 
2007/099 000 
DCI -ASIE 21363Sector Policy Support Programme — Social Protection and PFM — Kyrgyz Republic 
2007–09 — 3rd allocation9 000 
DCI -ASIE 20590 Operationalising good governance for social justice 3 000 
DCI -ASIE 22484 Sector Policy Support Programme, Social Sector — Kyrgyzstan 2010 13 000 
DCI -ASIE 21058 Border Management in Central Asia — Phase 8 (BOMCA 8) 8 000 
DCI -ASIE 19812 Central Asia Drug Action Programme Phase 5 (CADAP 5) 5 000 
DCI -FOOD 19169Sector Policy Support Programme — Social Protection and PFM — Kyrgyzstan 
2007/099 000 
DCI -FOOD 21863Support to the Improvement of a Food Security Information System in the Kyrgyz 
Republic2 000 
Total 68 100 
Tajikistan
DCI-ASIE 21994 Human Development Support Programme  26 000
DCI-ASIE 19236 Sector Policy Support Programme — Social Protection, Tajikistan 2007/09 9 000
DCI-ASIE 19667 Technical Assistance to Support the Social Sector Policy in Tajikistan  5 000
DCI-ASIE 20325 Public Finance Management Modernisation Project  2 000
DCI-FOOD 19168 Food Security Programme — Tajikistan — 2007  9 000
DCI-FOOD 21365 Support to the Social Safety Nets — Global Food Facility Programme (Tajikistan) 7 750
Total 58 750
Uzbekistan
DCI -ASIE 20509 Support to Criminal Judicial Reforms in Uzbekistan 10 000
DCI -ASIE 22308 Institution Building and Partnership Programme  2 200
DCI -ASIE 22311Strengthening the Bi-cameral Parliamentary System and Networking with Regional 
Authorities 2 000
DCI -ASIE 22373 Improvement of the Mother and Child Health Services in Uzbekistan — Phase II 6 700
Total 20 900
Source:  EuropeAid’s CRIS Data Warehouse. PROGRAMMES EXAMINED36
Special Report No 13/2013 – EU Development Assistance to Central Asia
INTRODUCTION
1. The Court estimated the administrative costs incurred by the Commission in disbursing aid in Central 
Asia. 
2. The Court took into account the following cost elements:
 — staff costs: salaries, allowances and pensions of Commission officials, contract staff and local 
staff working on Central Asia development assistance, both at headquarters and in the EU 
delegations;
 — office, equipment and other running costs associated with those staff in headquarters and in 
the delegations;
 — support expenditure related to Central Asia development assistance incurred by the Commis -
sion for its own purposes (rather than those of the recipient country), including consultancy 
work to support the identification and formulation of projects, result-oriented monitoring and 
evaluation and also costs related to Europa Houses1. 
SOURCES AND CALCULATION METHOD
3. The Court identified the following annual costs:
1 Costs relating to technical assistance associated with the implementation of specific projects in partner countries are not included.COMMISSION ADMINISTRATIVE COSTSANNEX III37
Special Report No 13/2013 – EU Development Assistance to Central Asia
ESTIMATED ADMINISTRATIVE COST OF THE PLANNING AND 
IMPLEMENTATION OF EU DEVELOPMENT ASSISTANCE TO 
CENTRAL ASIA
DescriptionThousand 
euroSource/comment
Administrative cost at headquarters
(Cost attributed to development assistance)1 786 Figure for 20111
Administrative cost of delegations
(Cost attributed to development assistance)6 611 Figure for 20112
Sub-total 8 397
Support expenditure
— Europa Houses
— Identification and formulation of projects
— Results-oriented monitoring
— Evaluations700
560
700
145Annual averages calculated 
by the audit team, based on 
CRIS data for contracts since 
2007 (for ROM 2008–11).
Sub-total 2 105
Total 10 502
1  Based on the standard cost of employing officials as used in legislative financial statements. 
The standard cost is provided by the Commission’s Directorate-General for the Budget and 
comprises salaries and allowances together with office and equipment costs. 
2  For officials and contractual agents the cost is based on an average for those stationed in dele-  
gations. For local agents and local running costs it is the real costs recharged by EEAS which 
are used. 
LIMITATIONS 
4. Some administrative expenditure is not included; employer’s pension costs are included only for 
local staff in delegations and not for officials and contract staff.
5. No amounts are included for support provided by other Commission units (administration, training, 
IT, etc.) or the EEAS.
6. The figures are for the year 2011. The delegations in Kazakhstan, Kyrgyzstan and Tajikistan were fully 
operational during that year. There were Europa Houses in both Uzbekistan and Turkmenistan.ANNEX III38
Special Report No 13/2013 – EU Development Assistance to Central Asia
REPLY OF THE COMMISSION 
AND THE EEAS
EXECUTIVE SUMMARY
II.
The Commission and EEAS would like to underline that the 
objective difficulties of Central Asian countries to advance 
with the reform agenda and their institutional framework 
are among the main limiting factors for the implementa -
tion of development cooperation.
III.
The Commission and the EEAS undertook specific efforts, 
notably for MIP 2011–13, to concentrate the areas of inter -
vention for bilateral assistance. The additional sectors stem 
from the regional and thematic components: these are an 
integral part of the DCI Regulation, which the Commission 
has to fully implement. 
IV.
The Commission and the EEAS would like to recall the 
following: 
 — the decision of the modality of implementation is the result 
of a specific analysis and integrated evaluation for each pro -
gramme, and it includes a consultation and quality scrutiny 
process;
 — the Commission is working to reduce the number of small-
size projects, which originate mainly from the thematic pro -
grammes, where the actions have intrinsic limited dimensions;
 — the financial instruments stem from the established legal basis; 
reporting on the implementation necessarily involves different 
geographic and thematic services at headquarters;
 — the information on spending for different programmes and 
instruments is available;
 — the Commission is already using different tools to evaluate the 
administrative costs involved with development cooperation.
V.
The Commission and the EEAS would like to underline that 
ongoing budget support programmes are linked to spe -
cific corruption prevention measures. 39
Special Report No 13/2013 – EU Development Assistance to Central Asia
REPLY OF THE COMMISSION 
AND THE EEASEligibility criteria for budget support require a holistic 
approach based on credibility and positive implementation 
which are by nature general. Satisfactory progress should 
be based on a dynamic approach, looking at past and 
recent policy performance benchmarked against reform 
expectations, but allowing for shocks and corrective meas -
ures and refining the objectives and targets if necessary.
VI.
The Commission and the EEAS would like to underline 
that the objective difficulties of Central Asian countries to 
advance with the reform agenda and their institutional and 
political framework are among the main limiting factors for 
the implementation of development cooperation.
The Commission and the EEAS recall the peculiarity of 
Central Asia regional programmes, which provided oppor -
tunities for dialogue and promote good neighbourhood 
relations and regional cooperation. A genuine regional 
dimension is not always feasible in the given present Cen -
tral Asia political conditions.
The Commission, whenever relevant, has always taken on 
board the recommendations resulting from the implemen -
tation of the programmes. 
VII.
The Commission and the EEAS will devote specific atten -
tion to the Court’s recommendations and follow them up 
for future cooperation actions in all cases in which this is 
relevant and feasible. INTRODUCTION
13.
The Council’s recommendations, that EU efforts should 
become more targeted and should contribute to the vis -
ibility and impact of the EU actions in Central Asia, have 
been duly acknowledged. Actions include an EU lead role 
on flagship initiatives taken by EU Member States them -
selves — France and Germany for Rule of Law, Italy and 
Romania for Environment and Water, with Finland taking 
an active supportive role. 
EU impact and visibility are also enhanced when entrusting 
the implementation of EU assistance programmes directly 
to consortia of EU Member States or EU agencies — for 
instance in rule of law, border management and fight 
against drugs, education and environment, and for invest -
ment facilities through EU financing institutions (EBRD, 
European Investment Bank, Kreditanstalt für Wiederaufbau, 
Agence Française de Développement).
14.
With a view to the European Parliament’s conclusions, the 
Commission and the EEAS recall that the country alloca -
tions derive from the EU Budget Authorities’ final deci -
sions, while policy priorities are ultimately decided by the 
EU Council. 
The development and cooperation framework is not 
intended to cover all the policy components of the 
EU Central Asia Strategy. Development cooperation is 
focused on supporting the implementation of the strat -
egy in selected areas, namely Rule of Law, Education and 
Environment/Water.
The EU Central Asia Strategy establishes a joint agenda 
for enhanced cooperation, followed up by regular sector 
policy dialogue. Priority areas have been agreed with EU 
Member States and Central Asian countries and they do 
include rule of Law, Democracy and Human rights.
In 2012, the Commission adopted a new set of budget 
support guidelines, which include specific requirements 
to improve the reporting standards and it also addresses 
concerns of corruption. A regular evaluation of budget 
support operations is carried out in the context of each 
disbursement request for Tajikistan and Kyrgyzstan. This 
documentation is available to the Parliament. 40
Special Report No 13/2013 – EU Development Assistance to Central Asia
REPLY OF THE COMMISSION 
AND THE EEASOBSERVATIONS
23.
The Court criticises that the Regional Strategy Paper and 
indicative programmes provide only limited justification 
for the Commission’s detailed choice of spending priorities, 
both in terms of choice of focal sectors and of how much 
should be spent on regional and how much on bilateral 
programmes. While this might not be spelled out in detail 
in the policy documents, these choices have been made 
carefully and in line with the relevant programming and 
strategy papers.
The choice of allocating financial resources to different 
sectors is a fine balancing exercise between focusing on 
fewer sectors and evaluating the risk of concentrating aid 
funds on too narrow a range of sectors. These decisions are 
dynamic in their nature and have evolved along the pro -
gramming period 2007–13. Moreover, the key principle for 
programming the regional-bilateral mix has been the com -
plementarity between policy goals, more specific at coun -
try level — e.g. poverty alleviation, social services deliv -
ery, local development — and more cross-cutting issues 
of regional nature. During the programming period, the 
prominence of the bilateral envelopes over the regional 
one has always been recognised. Building on experience 
from previous programmes, the Commission discussed 
aid priorities with the governments of the recipient coun -
tries and sought to align its cooperation framework with 
national plans, where they were available. 
It is correct that continuity of support, where relevant, 
was an important factor in this exercise since it is one of 
the key objectives to ensure the sustainability of reforms. 
The sector-wide approach chosen by the EU to promote 
reforms requires a degree of continuity in its own engage -
ment and support. 
It has to be underlined that the programming exercise was 
carried out in spite of objective constraints in Central Asia; 
notably the fact that the majority of Central Asian coun -
tries do not have elaborated national development strat-  
egies nor do they adhere to the framework for develop -
ment and cooperation (Paris Declaration).30.
The Court’s observation reflects the overall difficult politi -
cal and institutional context in Uzbekistan. Despite the 
difficulties generated by periods of political tensions 
between the EU and Uzbekistan, the structural limitations 
of the country’s approach to development cooperation, 
and the absence of an EU Delegation on the ground, EU 
development cooperation has nevertheless been able to 
implement concrete actions in Uzbekistan in the period 
2005–12. 
Specific efforts have been made in recent years to increase 
the degree of ownership by the Uzbek authorities on coop -
eration programmes, and this has resulted in innovative 
operations such as Judicial Reform and Sustainable Rural 
Development. 
32.
Please see reply to paragraph 34.
34.
The Commission fully agrees with the aid effectiveness 
principle of focusing aid efforts on a maximum of three 
sectors in programming its assistance to each partner 
country. It undertook all efforts to comply with this and 
other aid effectiveness principles during the programming 
period 2007–13. 
For Kyrgyzstan, the MIP 2011–13 identifies Education, Rule 
of Law and Social Protection/Income Generation as focal 
sectors for bilateral cooperation. As support for reform of 
the state benefit system is directly linked to support to 
income generation for the poor, the projects in this area 
are considered to cover the same sector. Projects in other 
sectors correspond to MIPs from earlier periods. 
For Tajikistan, the MIP 2011–13 identifies PFM, social sec -
tors (Health and Social protection), and Private Sector 
Development as the focal sectors for intervention. Since 
PFM is treated as a cross-cutting issue, there are de facto 
three focal sectors. Projects in other sectors correspond to 
MIPs from earlier periods.41
Special Report No 13/2013 – EU Development Assistance to Central Asia
REPLY OF THE COMMISSION 
AND THE EEASFor Uzbekistan, the MIP I for 2007–10 defines two focal sec -
tors: Increasing Living Standards through Rural and Local 
Development Schemes and Good Governance/Rule of Law. 
MIP II 2011–13 identifies three focal sectors: Raising Living 
Standards through Rural and Local Development Schemes; 
Rule of Law and Justice Reform; Enhancing Trade, Business 
Climate, and SMEs. Thus, both MIPs have covered de facto 
the same two areas, namely: Increasing Living Standards 
through Rural and Local Development schemes; and Gov -
ernance and Rule of Law. 
The mention of Environment, Energy and Education refers 
to areas which are mainly dealt with through actions at 
regional Central Asia level for all five countries. 
35.
The Commission has striven to provide complementary 
assistance in areas of high priority for the partner coun -
tries, so as to enhance impact and results. 
The specific regional and thematic components are an 
integral part of the DCI Regulation, which the Commission 
has to fully apply. The sectors covered under the regional 
programme are part of the Central Asia programming doc -
ument and follow a comprehensive policy approach in line 
with Central Asia partner countries’ needs. Human rights 
issues are dealt with under the EIDHR.
41.
The 56 reported contracts include not only the mainstream 
cooperation programmes (>1 000 000 euro), but also ancil -
lary service contracts such as Short-term Technical Assis -
tance (STTA), Audit, etc. for a maximum of 200 000 euro 
each. They also include contracts under financial instru -
ments other than the DCI, i.e. EIDHR, IfS, Nuclear Safety 
and others.The Commission would also like to underline two add-  
itional important structural features: many actions (STTA, 
monitoring, evaluation, and others) can be carried out 
only through service contracts following tenders under 
competition rules in line with the EU Financial Regulation. 
Furthermore, NGO grants/thematic programmes, also with 
civil society and local actors, receive limited amounts of 
funding by definition and are by nature of small size. 
Many of the 99 contracts identified by the Court at the 
time of its audit, only require limited and sporadic feed -
back from the Delegation in Bishkek, being often of global 
coverage. 
43.
Regarding the Court’s assessment on the panoply of 
sources of finance (see also point 84), the Commission 
notes that the number of instruments employed is justified 
by their nature, since under the DCI it is mandatory to con -
centrate only on a limited number of sectors which require 
long-term strategic cooperation. Thematic instruments and 
specific instruments, such as IfS, allow for the possibility to 
tackle other issues, requiring immediate action but outside 
the limited scope of the key sectors selected.
The reporting line is unique and it is only through the 
External Assistance Management Report to EuropeAid.
44. First indent
Concerning the Court’s remarks about national spending 
within a regional programme, the Commission would like 
to underline that the logic of a regional programme is pre -
cisely aimed at avoiding a mere addition of country parts, 
and therefore no country-based breakdown of budget is 
provided for reasons of principle, neither in the formula -
tion nor during implementation. This is in fact what Central 
Asian countries request and to which the Commission has 
always resisted in view of the intrinsic nature of regional 
programmes, i.e. a project that invests resources into 
joint activities and exchange of experiences to facilitate 
integration. 42
Special Report No 13/2013 – EU Development Assistance to Central Asia
REPLY OF THE COMMISSION 
AND THE EEAS44. Second indent
Regarding the Court’s findings, the Commission comments 
that, once contracted, CRIS can extract the information 
(without prejudice to the points presented above). Before 
contracting, breakdowns are indicative. CRIS therefore 
has the information regarding the country component of 
programmes following a global call, with the exception of 
regional contracts for the reason indicated above. 
44. Third indent
In recent years, the framework for regional cooperation 
with Central Asian countries was further consolidated 
through their participation in the European Neighbour -
hood Regional Programme (East) supporting reforms 
and modernisation in core sectors of their development 
agenda where they face similar challenges, notably edu-  
cation, energy, transport, environment, water, fight against 
drugs, or for improving business climate and attracting EU 
investments. These provided a stimulus for strengthen -
ing the impact of EU cooperation and delivering concrete 
results. 
The Court’s report is relevant for ENPI countries (under 
the responsibility of Directorate F in DEVCO) as concerns 
the two programmes Inogate and Traceca which are the 
only two programmes to cover the ENPI region and are 
extended over Central Asia. While the sectoral focus of 
these two programmes is extremely clear, the Commis -
sion agrees that, the regional initiatives organised being 
shared over all the participating countries, it is not pos -
sible to identify exactly how much funding goes to each 
country without a time-consuming and tedious analysis of 
project activities and related costs. In addition, the nature 
and spirit of regional programmes is to promote collabora -
tion on a multi-country level and not to have allocations to 
individual countries that might result in competition spirit 
rather than cooperation. 
45.
The decision on where and how to spend development 
budgets depends on multiple criteria (political considera -
tions, geopolitics, needs in a specific countries, security, 
reliability of beneficiary countries and implementing part -
ners, etc.) and should not be examined only in the light of 
administrative costs in a specific region or country. If the Commission decisions were only guided by the 
level of administrative costs, it would need to refrain from 
developing aid through the comparatively most expensive 
modalities of aid, such as through NGOs organisations, and 
from assisting the least-developed countries, which would 
be contrary to the purpose of our policy.
46.
The Commission monitors closely its administrative costs 
and undertakes efforts to reduce them whenever possible 
(MFF, budgetary reductions in chapter V, regular workload 
assessments, revised staff regulation, performance mon-  
itoring, etc). 
A system for calculating and assessing costs relating to 
policies exists at the level of the EU institutions, within the 
ABB framework. For reasons of coherence, if the Court of 
Auditors wants to question this system, which was agreed 
by the budgetary authority, this should be done at an insti -
tutional level and not in the context of an individual policy.
47.
See reply to point 45.
48.
See reply to point 45.
49.
The Commission considers that as a result of the defin-  
ition used, the level of administrative costs evaluated by 
the Court of Auditors is overestimated. Indeed, the Court 
includes in its calculation costs that are part of the actions, 
such as the technical assistance related to the identifica -
tion, formulation and evaluation of projects and the aggre -
gation of results (ROM), which are not considered admin -
istrative cost but part of the project implementation cycle.
50.
See reply to point 45.
51.
See reply to points 45 and 46.43
Special Report No 13/2013 – EU Development Assistance to Central Asia
REPLY OF THE COMMISSION 
AND THE EEAS52.
In its new programmes, the Commission aims to further 
remediate this weakness as data collection and statistical 
systems in the partner countries have improved.
52. First indent
Given the absence of an official PFM strategy at that spe -
cific moment and the ongoing work on it, as well as the 
uncertainty due to the freezing of the Budget Support pro -
gramme owing to the misreporting on the international 
reserve use by the National Bank of Tajikistan and the stop 
of the IMF programme in 2008, broader objectives were 
identified. 
Thus, the Commission had to ensure its flexibility in 
responding adequately to these difficulties. This allowed 
a margin of manoeuvre and space to include technical 
assistance to support to reform groundwork, especially in 
social reforms and PFM.
52. Second indent
With a view to supporting further overall reforms in the 
food security sector, the indicators remained relatively 
vague. However, due in part to this flexibility, the pro -
gramme could help pave the way for important reforms 
in areas such as the household surveys, the information 
collection system on food prices and the training of data 
collectors.
52. Third indent
The nature of the sampled projects and the Uzbek environ -
ment makes it difficult to determine solid baselines. How -
ever, indicators have been made as specific as possible. 
The Commission would like also to underline that in the 
specific Uzbek conditions a sector policy approach is not 
feasible. Therefore, there are clear limitations in terms of 
the possibility to predefine benchmarks and baselines in 
a broad and long-term perspective. 54.
To be eligible for budget support, a country must reply to 
four criteria:
 — a well-defined national or sectoral development or reform 
policy, 
 — a stable macroeconomic framework, 
 — good public financial management or a credible and relevant 
programme to improve it,
 — transparency and oversight of the budget (budget inform-  
ation must be made publicly available). The fourth eligibility 
criterion has been introduced in 2012. 
57.
A distinction must be made, on the one hand, between 
the eligibility criteria for budget support, which require 
a holistic approach based on credibility and positive imple -
mentation and which are by nature general, and, on the 
other hand, the specific conditions, attached to variable 
tranches, which must indeed be clear and specific. Eligibil -
ity criteria must be met before and during the programme, 
while conditions need to be fulfilled before payments are 
made.
Satisfactory progress should be based on a dynamic 
approach, looking at past and recent policy performance 
benchmarked against reform expectations, but allowing 
for shocks and corrective measures and refining the objec -
tives and targets if necessary. For some criteria (notably 
PFM), progress against initial reform milestones is particu -
larly important; for others (macroeconomic, for example), 
maintaining stability-oriented policies is sufficient to con -
firm eligibility. Donors must acknowledge the complexity 
of reforms and define targets that are more reasonable and 
better sequenced. For example, progress in PFM reform in 
both countries receiving Budget Support has been slower 
than expected. Indeed PFM reform plans, initially largely 
prepared by external donors, were far too ambitious and 
underestimated the local capacities to implement them. To 
remedy this, PFM reforms and action plans were revised to 
be more realistic and additional Technical Assistance was 
provided. 44
Special Report No 13/2013 – EU Development Assistance to Central Asia
REPLY OF THE COMMISSION 
AND THE EEASThe annual Budget Support reviews, the joint Donor-Gov -
ernment working groups and the external monitoring are 
additional tools put in place to better promote and moni -
tor progress.
58.
Indeed earlier programmes were not very strict in terms of 
deadlines by which the government had to comply with 
the conditions, and it is clear that the floating tranche 
mechanisms should be avoided. This has been remedied in 
new programme design, through the scheduling of strict 
timetables for the reviews and time-bound indicators. 
60.
The Commission is fully aware of the corruption problem in 
Central Asia and it is addressing it from the perspective of 
the different sectoral programmes, with a specific empha -
sis on transparency, accountability and efficient manage -
ment of public finance. It is clear that Development and 
Cooperation cannot ‘per se’ eradicate habits and cultural 
attitudes, which are deeply rooted in the social behaviour.
61.
The steady improvement in financial control and public 
procurement systems pursued in the context of budget 
support programmes effectively reduces the scope for 
corruption. Corruption and fraud are continuously moni -
tored through the risk assessment framework introduced 
through the 2012 EU Budget Support Guidelines. 
In response to a key recommendation from the Court, the 
Commission has developed an improved risk management 
framework. The framework aims at identifying and manag -
ing in a structured way the specific risks related to budget 
support. The framework is to be updated at least annu -
ally and used continuously during the programme cycle. 
It is a central tool in the new budget support governance 
structures. Risks levels determine referral to the Budget 
Support Steering Committee, chaired by the Director-Gen -
eral, and the risk framework is a key input in the decision 
-making process. A new format for Delegations’ Public Finance Manage -
ment Annual Monitoring Reports, including a new assess -
ment scheme for PFM reform progress, was introduced in 
June 2010. The comparison of achievements with clear and 
realistic priority objectives for the short (next 12 months) 
and medium term (next three years) by the recipient gov -
ernment promotes structured and formalised assessment. 
In the new 2012 Budget Support Guidelines, the Commis -
sion has introduced a more rigorous assessment of the 
three current eligibility criteria covering a stable macro -
economic framework (with a stronger focus on domestic 
resource mobilisation), national/sector policy and reform, 
and public financial management (with provision to 
require short-term measures before starting budget sup -
port operations where PFM is weak). It has also introduced 
a more rigorous approach to selecting and defining perfor -
mance indicators with an emphasis on the use of results-
oriented indicators that reflect recognised principles of 
best practice. 
62.
The Commission would like to stress that ongoing pro -
grammes are linked to specific corruption prevention 
measures, for example: contributing to payroll auto-  
mation as part of the overall PFM reform which contributes 
to end the habit of ‘ghost employees’ in the public sec -
tor. Such measures contribute directly to the prevention 
of corruption and the strengthening of public institutions’  
accountability. Moreover, the PEFA report of 2012 credited 
explicitly the social sector reforms with direct reduction of 
corruption levels, and support to these reforms is the focus 
of the EU intervention in Tajikistan. Donors are also coordi -
nating their efforts (division of labour) contributing to dif -
ferent reforms fighting corruption, in particular to support 
of the development of internal and external audit: DFID/
WB concentrated on external audit (twinning agreement 
with UK external audit office) and the EU on Public Internal 
Financial Control (PIFC). 45
Special Report No 13/2013 – EU Development Assistance to Central Asia
REPLY OF THE COMMISSION 
AND THE EEAS64.
The Commission and the EEAS would like to underline that 
all first level commitments will be fully finalised by end 
of 2013, according to the full amounts as planned in MIP . 
Contracting and payments will follow in due course.
65.
The Commission and the EEAS recall that the procedures 
for the preparation and approval of development coop -
eration are fixed in the established EU legal basis and the 
Financial Regulation. The Commission underlines that two 
milestones depend directly on the Uzbek authorities, i.e. 
the counter-signature of the Financing Agreement (overall 
political approval) and the approval of the Terms of Refer -
ence (technical approval). Both are essential requirements 
subject to specific time constraints, which need to be 
taken into account. In the project sample, the Court has 
selected programmes (Parliament and IBPP) which were 
already defined in 2008, but then Uzbekistan refused to 
countersign the AAP 2008. The programmes were then rep -
resented with updates and fine-tuning for financing under 
the 2010 APP and budget. The time elapsed — more than 
two years — between the earlier preparation (in 2008) and 
the final re-presentation and approval (in 2010) cannot be 
added up.
66.
The analysis of project implementation in Uzbekistan 
should take into account the overall difficult context. 
Despite the difficulties generated by periods of political 
tensions between the EU and Uzbekistan, the structural 
limitations of the country’s approach to development 
cooperation, and the absence of an EU Delegation on the 
ground, the EU development cooperation has been able to 
plan and implement concrete actions in Uzbekistan in the 
period 2005–12.
In Turkmenistan, heavy administrative and approval pro -
cedures often hamper speedy programme definition and 
implementation.68.
Concerning the Court’s assessment on regional pro -
grammes, the Commission and the EEAS would like to 
underline that the EU political objectives are to encour -
age good neighbourly relations between partner countries 
in a region fraught with tensions, and to provide a com -
mon reference framework for policy reform agenda in key 
sectors. 
The degree of political commitment to regional pro -
grammes varies greatly from country to country and from 
programme to programme, making it difficult to make gen -
eralisations or draw conclusions valid for all five countries. 
Although regional programmes cannot avoid the propen -
sity for their ‘nationalisation’ by each beneficiary country, 
the different fora, training opportunities and seminars are 
the best means available to promote good neighbourhood 
relations and regional cooperation. 
The complex regional political dynamics (rivalries among 
countries, etc.) should also be taken into consideration as 
a factor influencing genuine regional integration. Uzbek-  
istan’s selective participation/commitment, for example, is 
based on the politically sensitiveness of its relations with 
its neighbours, like Tajikistan, regardless of the technical 
nature of the programme. 
70.
Despite the fact that multi-country programmes such as 
Erasmus, Tempus and the Investment Facility for Central 
Asia (IFCA) replicate similar activities in more than one 
beneficiary country, these programmes provide a basis 
for positive benchmarks and emulation among the coun -
tries of the region, where results and achievements serve 
as basis for further progress on the different sector reform 
agenda, e.g. water, environment, energy, knowledge 
exchange. Concerning Tempus, the Commission and the 
EEAS are of the view that the programme does promote 
inter-regional cooperation. There are several projects with 
Central Asian universities’ participation from more than 
one country. 46
Special Report No 13/2013 – EU Development Assistance to Central Asia
REPLY OF THE COMMISSION 
AND THE EEASCommon reply to paragraph 71 and 72
The Commission and the EEAS can confirm a high partic-  
ipation of all Central Asian countries in regional forums 
and dialogues, workshops, joint study visits, etc., which 
shows that there is initial willingness of regional coopera -
tion and dialogue. Clear examples of that are the Central 
Asia Border Security Initiative meetings (led by Austria) and 
the Issyk-Kul border management initiative (even Turkmen -
istan participated in the last meeting), as well as Central 
Asia Regional Information and Coordination Centre. In fact, 
the Commission considers that the commitment of ben -
eficiary countries to CADAP is even higher than to BOMCA 
(ROM 2012 on CADAP in which Kazakhstan was graded 
even ‘A’ on impact prospects due to its high commitment). 
The cautious attitude from Turkmenistan and Uzbekistan 
concerning border-related regional activities is partly due 
to the specific programme components supporting coun -
tries with the highest needs for support, i.e. Tajikistan and 
Kyrgyzstan. For example, in the case of component four 
of the current BOMCA 8, only Tajikistan and Kyrgyzstan 
receive material infrastructure support, as the other three 
countries are fully capable of providing for their own infra -
structure. Some special components, such as the one on 
Tajik-Afghan border under BOMCA 7, was designed logic-  
ally only for Tajikistan. All the countries are participating 
in the other components, notably training and capacity 
building sector. Some absences from Turkmenistan partic-  
ipants are mainly due to the difficult and long bureaucratic 
process of authorisation for travel abroad. 
74.
The Strategy’s Third Progress report highlighted that EU 
Member States’ involvement in the implementation of EU 
assistance brings much higher impact and results. In fact, 
this is a development already taking place for several pro -
grammes and countries in Central Asia, as specifically pro -
moted by the Commission during the last years. 
The implementation via consortium Member States can 
represent indeed the best way to transfer the EU value 
added and know-how. ‘Twining’-like operations may also 
be targeted in the next programming period. However, 
such an instrument cannot just be copied for a different 
region but would need to be specifically adapted to the 
Central Asian partner countries.76.
The Commission agrees that the comprehensive analysis 
of lessons learned is essential for constant improvement 
of operations. This is precisely why the Commission is cur -
rently developing an IT platform, which will give access to 
operational information (including ROM, project and pro -
gramme evaluation) over the whole project cycle. In par -
ticular, this will considerably facilitate the incorporation of 
ROM conclusions into the Quality Support Group process. 
77. First indent 
The Commission has already incorporated longer dur-  
ations into new programme design. However, it should be 
noted that, while earlier programmes were funded through 
annual commitments, they contributed effectively to the 
same programme objectives and results.
77. Second indent 
The general conditions for budget support correspond to 
processes which cannot be fully predetermined, whereas 
the special conditions for the release of payments need to 
be specific and clear. In the new programmes, the Commis -
sion is addressing this issue, in parallel with the improve -
ment of data collection and statistical systems in the part -
ner countries.
77. Third indent 
The Commission is already focusing on a reduced number 
of areas and conditions in programmes covering longer 
periods.
79.
The indicators selected for the annual activity report (as 
per footnote 36) cover, to the extent possible, both overall 
policy and development cooperation-related objectives. 
Because of the annual evaluation; they cannot be seen as 
a mere replication of the indicators presented in the long-
term strategic documents. Nonetheless, some of them 
refer to overarching development objectives, ref. to MDGs 
targets (Indicators v,vi,vii). Moreover, these indicators are 
linked with the EU Central Asia Strategy: Indicators (ii), (iii) 
and (iv) are directly reflecting the three policy initiatives of 
the Central Asia Strategy. Indicator (i) on PCA refers to the 
key document at the core of the contractual relations with 
the partner countries.47
Special Report No 13/2013 – EU Development Assistance to Central Asia
REPLY OF THE COMMISSION 
AND THE EEAS80.
The preparation of the Annual Report on the European 
Community’s Development and External Assistance Pol-
icies and their Implementation is a legal obligation; the 
report is adopted by the College. The Council issues con -
clusions on it every year, on which the Commission then 
bases its report of the following year. In recent years, 
the Council has acknowledged the Commission’s efforts 
towards an increasing focus on results. In 2012, the Council 
commended the Commission for its efforts to achieve the 
objectives of strengthening accountability and transpar -
ency, and a results-oriented EU development policy and 
external assistance. 
The Commission understands that in the next DCI Regula -
tion there probably will be an increased focus on results.
81.
The Annual Report is meant for information to the public 
with a user friendly and concise format; therefore, it is not 
the appropriate place for detailed administrative and finan -
cial reporting. CONCLUSIONS
82.
The Commission and the EEAS would like to underline 
that the objective difficulties of Central Asian countries 
to advance with the reform agenda and their institutional 
framework are among the main limiting factors for the 
implementation of development cooperation.
83.
The Commission and the EEAS undertook specific efforts, 
notably for MIP 2011–13, to concentrate the areas of inter -
vention for bilateral assistance. The additional sectors stem 
from the regional and thematic components: these are an 
integral part of the DCI Regulation, which the Commission 
has to fully implement.
84.
The Commission and the EEAS would like to recall the 
following: 
 — the decision of the modality of implementation is the result 
of a specific analysis and integrated evaluation for each pro -
gramme, and it includes a consultation and quality scrutiny 
process,
 — the Commission is working to reduce the number of small-
size projects, which originate mainly from the thematic pro -
grammes, where the actions have intrinsic limited dimensions,
 — the financial instruments stem from the established legal basis; 
reporting on the implementation necessarily involves different 
geographic and thematic services at HQ,
 — the information on spending for different programmes and 
instruments is available,
 — the Commission is already using different tools to evaluate the 
administrative costs involved with development cooperation.
85.
The Commission and the EEAS would like to underline that 
ongoing budget support programmes are linked to spe -
cific corruption prevention measures. 48
Special Report No 13/2013 – EU Development Assistance to Central Asia
REPLY OF THE COMMISSION 
AND THE EEASEligibility criteria for budget support require a holistic 
approach based on credibility and positive implementation 
which are by nature general. Satisfactory progress should 
be based on a dynamic approach, looking at past and 
recent policy performance benchmarked against reform 
expectations, but allowing for shocks and corrective meas -
ures and refining the objectives and targets if necessary.
86.
The Commission and the EEAS would like to underline 
that the objective difficulties of Central Asian countries to 
advance with the reform agenda and their institutional and 
political framework are among the main limiting factors for 
the implementation of development cooperation.
The Commission and the EEAS recall the peculiarity of 
Central Asia regional programmes, which provided oppor -
tunities for dialogue and promote good neighbourhood 
relations and regional cooperation. A genuine regional 
dimension is not always feasible in the given present Cen -
tral Asia political conditions.
The Commission, whenever relevant, has always taken on 
board the recommendations resulting from the implemen -
tation of the programmes. RECOMMENDATIONS
87. First indent 
The Commission and the EEAS will implement the recom -
mendation to the extent possible in Central Asia, provided 
that the individual countries can agree on joint objec -
tives and programmes (e.g. BOMCA, CADAP). Regional 
funds remain also useful to support multi-country activ-  
ities in a more efficient way, e.g. for blending purposes or  
academic mobility.
87. Second indent 
The Commission and the EEAS are already concentrating 
assistance for each country programme and the regional 
programmes under the DCI instrument. This is without 
prejudice to the specific nature of thematic instruments, 
which have been designed with specific objectives by the 
budgetary authority.
87. Third indent 
The Commission and the EEAS do not accept the recom -
mendation. The Commission and the EEAS consider that 
setting up a new system for calculating and reporting 
on the overall administrative cost involved in delivering 
its development assistance is not necessary. Indeed, the 
Commission and the EEAS would refer to the existing ABB 
system, which already contains information about admin -
istrative costs. Any change to it should be tackled at an 
institutional level and agreed with the budgetary authority.
87. Fourth indent 
The Commission and the EEAS are already applying robust 
and objectively verifiable conditions for budget sup -
port programmes as foreseen in the new budget support 
guidelines.
87. Fifth indent
The Commission and the EEAS take into account exper-  
ience to improve programme design and delivery on 
a continuing basis through the Quality Support Group 
reviews and on the basis of the feedback received from 
monitoring and evaluation results.49
Special Report No 13/2013 – EU Development Assistance to Central Asia
REPLY OF THE COMMISSION 
AND THE EEAS87. Sixth indent 
The Commission and the EEAS are already devoting spe -
cific attention to the overall results and impact of devel -
opment cooperation with more targeted and sustainable 
interventions, linked to the advancement of the policy 
dialogue and an effective transfer of relevant EU know-
how and policy advice. However, the Commission and the 
EEAS consider that there is room for improvement and 
shall strive to enhance reporting on results and impact in 
the future, following the announced trend for the new DCI 
regulation.50
Special Report No 13/2013 – EU Development Assistance to Central Asia
European Court of Auditors
Special Report No 13/2013
EU Development Assistance to Central Asia
Luxembourg: Publications Office of the European Union
2013 — 50 pp. — 21 × 29.7 cm
ISBN 978-92-9241-474-0
doi:10.2865/66801

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QJ-AB-13-014-EN-C
EUROPEAN COURT OF AUDITORS
THE COURT EXAMINED HOW THE EUROPEAN COMMISSION (EC) AND THE EURO -
PEAN EXTERNAL ACTION SERVICE (EEAS) PLANNED AND MANAGED DEVELOPMENT 
ASSISTANCE TO THE CENTRAL ASIAN REPUBLICS (KAZAKHSTAN, KYRGYZSTAN, 
TAJIKISTAN, TURKMENISTAN AND UZBEKISTAN) IN THE PERIOD 2007–12. IN CHAL -
LENGING CIRCUMSTANCES, PLANNING AND ALLOCATION OF ASSISTANCE WERE 
GENERALLY SATISFACTORY. IMPLEMENTATION WAS LESS SO. THE COURT MAKES 
A NUMBER OF RECOMMENDATIONS. THE EC AND THE EEAS SHOULD DESIGN 
ANY FUTURE REGIONAL PROGRAMMES SO THAT THEY ARE LIKELY TO ACHIEVE A   
GENUINE REGIONAL DIMENSION. THEY SHOULD CONCENTRATE ALL ASSISTANCE 
PROVIDED ON A SMALL NUMBER OF SECTORS. FOR ANY CONTINUING BUDGET 
SUPPORT PROGRAMMES, THEY SHOULD DEFINE AND APPLY ROBUST AND OBJEC -
TIVELY VERIFIABLE CONDITIONS, IN PARTICULAR GIVING SUFFICIENT ATTENTION 
TO SUPPORT FOR ANTI-CORRUPTION MECHANISMS.