EUROPEAN COMMISSION Brussels, 14.10.2019 SWD(2019) 374 final COMMISSION STAFF WORKING DOCUMENT EVALUATION Accompanying the document Report from the Commission to the Council and to the European Parliament for the interim evaluation of the Programme for the Competitiveness of Enterprises and Small and Medium-sized enterprises {COM(2019) 468 final}



COMMISSION STAFF WORKING DOCUMENT EVALUATION Accompanying the document Report from the Commission to the Council and to the European Parliament for the interim evaluation of the Programme for the Competitiveness of Enterprises and Small and Medium-sized enterprises 1.Introduction Purpose and scope 2.Background to the intervention Description of the intervention and its objectives 3.Implementation / state of Play Description of the current situation 4.Method 4.1.Short description of methodology 4.2.Limitations and robustness of findings 5.Analysis and answers to the evaluation questions 5.1.Relevance 5.2.Effectiveness 5.3.Efficiency 5.4.Coherence

5.5.EU added value 6.Conclusions AND LESSONS LEARNED Annex 1: Procedural information Annex 2: Stakeholder consultation Annex 3: Methods and analytical models Annex 4: Interim Evaluation of the International Intellectual Property Rights (IPR) SME Helpdesk, a specific COSME measure



Glossary Term or acronym Meaning or definition COSME The Programme for the Competitiveness of Enterprises and small and medium-sized enterprises (COSME) (2014 - 2020) SME Small and medium-sized enterprises CIP The Competitiveness and Innovation Programme (CIP) (2007-2013) EIP The Entrepreneurship and Innovation Programme (EIP) (2007-2013) MFF Multi-annual Financial Framework EIF The European Investment Fund EASME The Executive Agency for SMEs LGF Loan Guarantee Facility EFG Equity Facility for Growth EEN The Enterprise Europe Network EYE The Erasmus for Young Entrepreneurs IPR SME Helpdesk Intellectual Property rights for SMEs Helpdesks IPR Intellectual Property rights EFSI The European Fund for Strategic Investments SO Specific Objective MS Member States WP Work Programme EU European Union R&I Research and Innovation KETs Key Enabling Technologies FC Framework Conditions in the Single Market GA Grant agreements IOs Intermediary Organisations TA Thematic Area OPC Open Public Consultation SBA Small Business Act 1.Introduction Purpose and scope This evaluation assesses the relevance, effectiveness, coherence, efficiency and EU added-value of the Programme for the Competitiveness of Enterprises and small and medium-sized enterprises (COSME) (2014 - 2020) from 2014 to 2016, in conformity with article 15.3 of its basic act : “By 2018 at the latest, the Commission shall establish an interim evaluation report on the achievement of the objectives of all the actions supported under the COSME programme at the level of results and impacts, the efficiency of the use of resources and its European added value, with a view to a decision on the renewal, modification or suspension of the measures. The interim evaluation report shall also address the scope for simplification, its internal and external coherence, the continued relevance of all objectives, as well as the contribution of the measures to the Union priorities of smart, sustainable and inclusive growth. It shall take into account evaluation results on the long-term impact of the predecessor measures and shall feed into a decision on a possible renewal, modification or suspension of a subsequent measure.” The interim evaluation contributed to the preparation of the future programme in the next Multi-annual Financial Framework for the period 2021-2027. The performance of the delegated entities (The European Investment Fund (EIF) and the Executive Agency for SMEs (EASME) is an important aspect of the assessment of the efficiency and effectiveness criteria and for addressing the scope for simplification. This evaluation will feed into the mid-term evaluation of EASME that will analyse in more depth the performance of the Agency in implementing the programmes delegated to it. The evaluation covers the 28 Member States of the European Union and the COSME participating countries. The article 6 of the COSME regulation allows third countries to participate in the programme. In 2016, the following countries participate in COSME: Albania, Montenegro, the Republic of North Macedonia, Iceland, Turkey, Serbia, Moldova and Armenia . Ukraine and Bosnia signed the international agreement for participation to COSME in respectively May and June 2016, pending ratification by the national parliaments , but these agreements were not in force during the period contemplated by this evaluation. 2.Background to the intervention Description of the intervention and its objectives The Programme for the Competitiveness of Enterprises and small and medium-sized enterprises (COSME) (2014 - 2020) is the successor of the Competitiveness and Innovation Programme (CIP) (2007-2013) . With a total budget of EUR 2.3 billion, COSME aims to contribute to the Commission’s top political priority of creating more growth and jobs. It also aims to support the creation and growth of small and medium-sized enterprises, and promote the competitiveness of EU enterprises and entrepreneurship. SMEs are the main source of economic growth and job creation in the EU. They constitute 99% of European businesses, provide two out of three private sector jobs and contribute more than half of the total value-added created by businesses in the EU. The impact assessment accompanying the proposal for the 2014-2020 COSME programme identified the following main problems SMEs are facing across the EU:

·Cross-border regulatory fragmentation; ·Excessive administrative burden for starting a business; ·Lack of entrepreneurship spirit in the EU; ·Difficulties to access to finance; ·Significant barriers when doing business across borders inside and outside Europe. To respond to these market failures and address the problem, the COSME Regulation sets two general objectives and four specific objectives to address these problems. General objectives: 1.To strengthen the competitiveness and sustainability of the EU's enterprises, particularly SMEs and 2.To encourage entrepreneurial culture and promoting the creation and growth of SMEs. Specific objectives (SOs): 1.(SO 1) Easing access to finance for SMEs, both through guarantees and equity (at least 60% of the total budget); 2.(SO 2) Helping SMEs access to markets and internationalise (indicative 21.5% of the total budget); 3.(SO 3) Creating a favourable environment for enterprises and support their competitiveness (indicative 11% of the total budget); 4.(SO 4) Promoting entrepreneurship (indicative 2.5% of the total budget). The remaining 5% of the total budget are available for administrative expenditures in particular for the EASME subsidy, horizontal IT tools, corporate communication. The Commission delegates the implementation of COSME to the Executive Agency for SMEs (EASME) for all objectives with the exception of the implementation of the financial instruments under specific objective 1 entrusted to the European Investment Fund (EIF).

The diagram in the next page shows the intervention logic of the COSME programme: 3.Implementation / state of Play Description of the current situation COSME is the successor of the EIP pillar of the Competitiveness and Innovation Framework Programme (CIP). CIP ran between 2007 and 2013 with a budget envelope of EUR 3.6 billion . Its objectives were to contribute to strengthening productivity, innovation capacity, and sustainable growth. It comprised three ‘pillars’: the Entrepreneurship and Innovation Programme (EIP), the Information Communication Technologies Policy Support Programme (ICT-PSP), and the Intelligent Energy Europe Programme (IEE). The EIP accounted for slightly less than 60% of the CIP budget. In the 2014-2020 programming period, the innovation activities (including ICT-PSP and IEE) were transferred to Horizon 2020, while the activities under the EIP programme were largely transferred to COSME. The EIP supported access to finance for SMEs, the Enterprise Europe Network (established in 2008 by integrating two former networks: the Euro Info Centres and the Innovation Relay Centres, Erasmus for Young Entrepreneurs, the IPR Helpdesks for SMEs, and activities aimed at fostering entrepreneurship culture and creating better framework conditions for SMEs operating in the EU. It also provided actions to support innovation in enterprises (including eco-innovation) and innovation governance and culture. While EIP under CIP strived ‘to support entrepreneurship and innovation and to promote the development and growth of SMEs across the EU’, COSME takes a more targeted approach and aims at improving the business environment to enhance competitiveness by focusing on framework conditions, entrepreneurship, access to finance and/or markets. All references to innovation are left out in COSME, while special attention to tourism has been introduced. . In most cases, the specific actions that were implemented or piloted in the EIP programme are continued also in COSME, with only minor changes. More substantial changes have been introduced in the financial instruments and the EEN services, listed in Table 1 , below. Focus area Under EIP Under COSME Financial instruments Three financial instruments: ·the High Growth and Innovative SME Facility (GIF) ·the SME Guarantee Facility (SMEG), and ·the Capacity Building Scheme (CBS) Two financial instruments: ·EFG was created as a translation of GIF2 with adjusted terms and conditions of investment ·The LGF is a direct translation of the SMEG Windows on loans, microcredit and securitization ·The CBS was discontinued because of a low take up EEN Key focus is on facilitating cooperation among SMEs ·Key focus is on facilitating access to markets and internationalization (within the EU) ·More customized services to SMEs ·Expansion of the online services ·Advisory services as an additional service Source: Technopolis Group, based on CIP/EIP and COSME programme documents The final CIP evaluation concluded that the programme objectives related directly to the needs, problems and issues they were intended to address. In addition, the concentration of actions on areas where EU action could make a difference had been identified as a positive shift. CIP also proved to be flexible and able to respond to emerging issues. However, stakeholders raised the issue of fragmentation due to the financing of many small activities and the evaluation recommended a continued need to justify each small-scale measure separately, a need to strengthen mechanisms for the overall coordination of actions (to avoid unnecessary proliferation and achieve greater synergies), and a need to improve the monitoring and communication of the aims and achievements of small scale measures. It pointed out that in general, the indicators chosen to monitor the implementation and results of the actions were not all responding to the SMART criteria. Questions were also raised concerning synergies across the three components of CIP, and issues were spotted in relation to the coherence of the programme, amongst which the coherence of the Financial Instruments with the support offered by the Structural Funds. The need to further develop and improve the monitoring system was a major finding in the final EIP evaluation, which recommended the development of “a clear overall monitoring system that regularly provides data in an easily accessible and standard format”. The evaluation team noted that there was a very limited synergy or overlap with financial instruments on a national level and that the various financial instruments of the Commission were still seen to be fragmented and overlapping. Both the interim and final evaluation of the EIP highlighted that there was some sort of competition between venture capital and loan guarantee schemes under the ERDF and under the EIP programme. The EIP final evaluation considered that the demand-driven approach to the financial instruments could give way to one that is more pro-active and especially one that concentrates on promoting facilities in countries not yet covered. Finally, the EIP evaluation raised the danger of having too many small activities funded by the EIP programme and noted the absence of “a mechanism that could ensure greater coordination and synergies among the different activities”. It proposed to establish an enhanced co-ordination function in the management of the programme that would have the SBA as a major reference point and focus on “an active exploitation of the potential synergies, both within the Programme and with external actions”. The COSME programme is implemented through annual work programmes, which are set up according to the Commission's policy priorities and approved through the examination procedure by the Member States' Committee. The budget execution rates of COSME are good. . The operational budget available in 2014 (EUR 247 million), was executed at 99.87%; in 2015 the operational budget available (EUR 329 million) was executed at 99.38%; in 2016 the operational budget available (EUR 336 million) was executed at 96.69%. The implementation structures for the financial instruments and the Enterprise Europe Network were in place and delivering. The total authorized appropriations for 2016 amount to EUR 298 million. (There was a further reinforcement of EUR 550 million of the financial instruments through EFSI (see section below). From 2016, the programme has integrated priorities of the Single market strategy, particularly the priority to support SMEs, start-ups and scaling-ups. Access to Finance - specific objective 1

60% of the Programme’s resources are allocated to the COSME Financial Instruments, the Loan Guarantee Facility (LGF) and the Equity Facility for Growth (EFG). They build on the success of the CIP Financial Instruments (2007-2013) which helped to mobilise more than EUR 20 billion of loans and EUR 3 billion of venture capital to over 380,000 SMEs in Europe. The COSME financial instruments operate in conjunction with the financial instruments set up under Horizon 2020 as part of a single debt financial instrument and a single equity financial instrument respectively, supporting the growth of enterprises and their R&I activities. They can also complement financial instruments set up under the European Structural and Investment Funds. The calls for expression of interest for the financial instruments published in 2014 have generated a strong interest from financial intermediaries across the EU and non-EU Member State countries participating in COSME, especially for the LGF. The strong market demand for the LGF continued in 2015, with the consequence that the whole 2014-2015 budget available was exhausted by mid-2015. Thanks to the guarantee provided by the European Fund for Strategic Investment (EFSI) the EIF could continue to sign COSME LGF guarantee agreements in the second half of 2015. At the end of 2016, almost 143 000 SMEs in 21 participating countries received financing for almost EUR 5.5 billion under the enhanced LGF. The COSME LGF enhancement thanks to the EFSI guarantee continued in 2016 and 2017, with a positive effect on financing made available to riskier SMEs at a much earlier moment in time as would have been the case with the COSME budget only, thereby speeding up the financing of the real economy. Given the specific features inherent to an equity facility, with more complex due diligence and fund raising processes, signature of fund agreements took more time. The first five transactions under EFG, out of which three multi-stage funds in combination with the InnovFin Equity Facility for Early Stage set up under Horizon 2020, have been signed end of 2015. First investments into SMEs took place in 2016 under these agreements. The total budget foreseen for the financial instruments under the 2016 work programme (EUR 295.3 million) was fully implemented. Under specific objective 1, COSME also finances surveys to measure the access to finance situation in Europe , awareness raising means about the EU financial instruments , as well as other support actions on access to finance for about EUR 1 million each year. Access to markets – specific objective 2 COSME helps European enterprises and, in particular SMEs, to do business in the Single market as well as to export outside Europe. More than two thirds of the COSME budget for access to markets is devoted to the Enterprise Europe Network (EEN), which helps SMEs to find business, technology and research partners in the EU and third countries. It also promotes the participation of SMEs in EU funding programmes such as Horizon 2020 and the European Investment and Structural Funds. The EEN started its activities as planned on 1/1/2015 (the activities in 2014 were still covered by the CIP programme). 92 consortia were selected as a result of two calls for proposals. The Network currently includes 525 organisations in the EU and 80 organisations in the eight COSME participating countries; they signed framework partnership agreements covering a seven year period and specific grant agreements for the operational periods 2015-2016 and 2017-2018. The Network (about 3.000 staff members) involved, on yearly basis, more than 200.000 SMEs in local events, provided specialised advisory services to 70.000 SMEs on access to finance, IPR business and technology, resource efficiency services etc. About 25.000 SMEs participate in matchmaking events every year resulting in about 2.500 international partnerships signed between SME.

Starting from July 2017, the EEN is implementing an action focused on start-ups/scaling up, a priority of the Single Market Strategy, for a budget of EUR 2.6 million. The EEN scale-up advisors will help young European SMEs scaling up their activities in the Single Market by training, mentoring, coaching and innovation and internationalisation services. Under specific objective 2 COSME also funds several other smaller projects; the most important are: ·The Your Europe Business portal for about EUR 0,5 million per year; ·The intellectual property rights (IPR) helpdesks in China, Latin America and south east Asia for EUR 7,2 million; ·The EU Japan Centre for Industrial Cooperation EUR 2,7 million per year; ·Improved points of single contacts in the Member States for EUR 1 million; ·Improving access to SMEs in public procurement, EUR 1 million. Improve framework conditions for businesses – specific objective 3 COSME funds actions aiming at facilitating SMEs' access to IPR, public procurement, clusters and digital technologies, cutting red tape and promoting the "Think Small First" principle and improving the competitiveness of strategic sectors which have a strategic importance for the European economy including, tourism. The Commission implements this objective through a wide variety of smaller actions, through calls for proposals and calls for tenders such as: ·The E-Skills for competitiveness and Innovation, about EUR 3 million per year;

·The Cluster internationalization program for SMEs, ranging from EUR 3,5 to 5 million per year; ·The Cluster Excellence programme for EUR 1,5 million per year; ·Modernization of Industry activities (Key Enabling Technologies, Advanced Manufacturing, etc.) for EUR 5 million per year on average; ·Several activities to support SMEs in industrial sectors (Construction, Chemistry, Aeronautics, Defense, the food supply chain, Resource Efficiency, Design, Bio Based Products, …); ranging from EUR 5 to 8 million per year; ·The monitoring and follow-up of the SME policy, for EUR 5 million per year on average: oThe SME Performance Review; oThe SME assembly; oThe SME Envoys Network; oThe outreach tools like Business Planet on Euronews and the SME portal; ·EU REFIT platform for regulatory burden reduction, EUR 0,5 million on average per year ·The support to Tourism sector for a budget ranging from EUR 5 to 9 million per year; ·The promotion of the social economy and social entrepreneurship, for a budget ranging from EUR 0.5 to EUR 2 million per year. Between 2014 and 2016, EUR 109.3 million were allocated to this objective, representing 12% of the financial envelope. The first calls under this objective were published at the end of 2014 and considering the period of execution, most of the actions only started producing results after the time scope for this evaluation. The High-level Group on administrative burden contributed to the exchange of good practices and the follow-up up and paved the way for the EU REFIT platform. The SME Performance Review provided an overview of the European SMEs and detailed information on the implementation of the Small Business Act. The Member States-specific information was fed into the European Semester country specific recommendations. The network of SME Envoys, the annual SME Assembly and the European SME week provided fora for awareness raising and exchange of good practices in all areas of the Small Business Act. Last but not least, the 4th season of business planet on Euronews TV started on 12 June 2015. The e-skills for jobs campaign covered 30 countries, involving 384 organisations and gathering more than 300.000 participants with some 115 million people exposed to the campaign. The call for proposals "Design based consumer goods" (with an available budget of EUR 4 million) resulted in 10 SME projects awarded to develop innovative, digital solutions to improve design processes and communication in the textile and clothing value chain, innovative products embedding digital technologies to products and new business models addressing environmental and societal challenges.

The tourism initiatives contributed to strengthening the competitiveness of the European tourism sector. The initiatives dedicated to the increase of senior and young tourists' flows contributed to generate an extension of the tourism season. Actions to enhance tourism accessibility contributed to improving facilities and services for tourists with special access needs. The visibility of European Destinations of Excellence has been improved, which will trigger higher numbers of potential tourist arrivals and local spill-over revenues for the destinations and tourism operators. Awareness-raising activities and events generated a better visibility and up-take of tourism initiatives. In 2014-2016, the Clusters Go International calls involved 25 European Strategic Cluster Partnerships (ESCPs), representing 145 cluster organisations across 23 European countries and more than 17,000 European SMEs. 15 out of the 25 selected ESCPs were funded. The other 10 partnerships were awarded the ESCP label and encouraged to continue their partnerships on a voluntary basis, without COSME funding. The 15 co-funded partnerships account for approximately 95 clusters reaching out to over 10,300 European SMEs. WATIFY is an awareness raising campaign launched by the European Commission in 2014 seeking to promote digital entrepreneurship and modernisation of the European industry. Implemented in two distinct phases, the campaign sought to reach SMEs, public authorities and other intermediaries across Europe and inform them about opportunities brought by digitalisation. Entrepreneurship and Entrepreneurial culture – specific objective 4 COSME supports exchanges among European educators and trainers to develop best practices in entrepreneurship education in the EU. The programme focuses on groups such as young people, women or senior entrepreneurs in order to benefit from mentoring or other tailored schemes. The main tool is the Erasmus for Young Entrepreneurs mentoring programme, which helps new entrepreneurs acquire and build entrepreneurial skills and knowledge, and to further develop their business activity by learning from experienced entrepreneurs. It started in 2009 as a pilot and is now a key action in the COSME programme. It is implemented through yearly call for proposals resulting in the signature by EASME of grant agreements (GA) for 24 month periods. In general there are always a high number of good projects that cannot be financed because of a lack of funding. For the Call 2014 (cycle 7): 111 proposals submitted, 15 projects selected involving 111 organizations from 28 COSME countries; 40 projects for a volume of approx. 14 million EUR could not be funded due to budget constraints For the 2015 call, 105 proposals were submitted, with 17 proposals selected involving 128 organisations. In 2014 the original budget of EUR 5,5 million was reinforced by nearly one million to award more proposals. In 2015, the budget was increased up to EUR 7,8 million and in 2016 it is intended to increase it up to at least EUR 8,7 million. The implementation of the activities started on 1/2/2015 with network of 175 Intermediary Organisations (IOs) in 32 countries (26 Member States and 6 COSME countries). By the end of 2016, 11.000 entrepreneurs’ profiles were accepted and 4.200 matches involving over 8.400 entrepreneurs were established. Under this specific objective COSME also funds several other smaller projects; the most important are: ·Entrepreneurship education from EUR 0,4 to EUR 1 million on average per year; ·Women’s entrepreneurship, for EUR 0,5 to EUR 1 million on average per year; ·Senior’s entrepreneurship for EUR 0,5 to EUR 1 million on average per year; ·Digital Entrepreneurship, EUR 2,5 million in 2015; ·Support to Migrant Entrepreneurship, EUR 1,5 million per year. 4.Method

4.1.Short description of methodology This Staff Working Document is supported by three external studies, one for the whole programme and two separate evaluations of the IPR SME helpdesks and WATIFY.. The methodological framework for this evaluation builds upon the evaluation criteria of relevance, efficiency, effectiveness, coherence and EU added-value. These evaluation criteria assess the relationships between the various components of the intervention logic presented on p.9. Taking account that this is an interim evaluation, most of the expected mid-term results are not yet measurable. Therefore, the primary focus was on the extent to which the programme sets the building blocks for reaching the intended mid- and long-term results and impacts. This implies an emphasis on the adequacy and quality of the programme design, i.e. the formulated objectives, the invested resources, and the activities implemented – in other words, the relevance and coherence criteria. In terms of effectiveness, the assessment focused on the attainment of the expected outputs and short-term outcomes, and the enabling factors or barriers for the attainment of the outcomes and expected results, such as the capacity of the programme to reach and involve the stakeholders needed. The evaluation covers all actions of the programme with a sense of proportionality for the four specific objectives of COSME. The evaluation focusses on the main actions of the COSME Programme: ·The financial instruments: Loan Guarantee Facility and Equity Facility for Growth; ·The Enterprise Europe network, for which an evaluation was already performed for the 2008-2014 period, adding the two years of activity (2015-2016) under the COSME programme; ·The Erasmus for Young Entrepreneurs, with the support of an existing study. Together, these instruments represent more than 80% of the budget of the programme and constitute the principal actions for three of the four specific objectives. The remaining 20% of COSME budget is implemented through a variety of smaller actions across the four specific objectives. In order to evaluate the four specific objectives of the programme , the supporting study contractor was asked to select a sample of representative activities on the following basis: ·The assessment of the relevance, coherence, and efficiency in implementation criteria covers all actions. ·The Assessment against the effectiveness criterion focuses on the Key Actions, complemented by four case studies. ·The European added-value and the efficiency / cost-effectiveness criteria remain covered through the analysis of the Key Actions only. The Key Actions include: the financial instruments (LGF and EFG), the Enterprise Europe Network services, the SME Policy actions, the Cluster Internationalisation programme, and the Erasmus for Young Entrepreneurs programme. Actions covered through case studies are: the Vulcanus scheme in the EU-Japan Centre action; the e-skills/digitisation actions, the Tourism actions (grants), and the Women Entrepreneurship action. A mix of quantitative and qualitative methods for the evidence collection and analysis was used to allow for a proper triangulation of the evidence collected, ensuring the robustness of the findings. Methodological approach Tools & methods Number Qualitative methods Desk research 260+ Interviews 120 Case studies 4 Workshop 1 Qualitative targeted consultation 7 Quantitative methods Targeted consultation 7 Public consultation 1 Statistical analyses of secondary data 4 Technopolis, December 2017, https://ec.europa.eu/docsroom/documents/28084

The desk research encompassed a broad range of sources, ranging from programme and policy documents to market studies, impact assessments and preceding and/or other evaluations with the analysis of more than 260 documents. 120 interviews were organised to collect background and context information on facilitators and barriers for the attainment of the expected effects as well as the eventual unintended effects. Four case studies were conducted on SO2 – Access to market (the trainee programme “Vulcanus in Japan”, run by the EU-Japan Centre), SO3 – Favourable environment (the Tourism programme and the E-skills for competitiveness and innovation actions) and SO4 – Entrepreneurship (the Women Entrepreneurship action). Seven ‘Qualitative’ targeted consultations were implemented where the population is lower than 100. However, the small numbers did not allow for meaningful statistical analysis. The questionnaires mostly include open-ended questions, geared at collecting qualitative information to complete the information gathered by interviews. Seven ‘classical’ targeted consultations were implemented where the population was higher than 100, allowing for meaningful and robust statistical data analyses. The questionnaires mostly include close-ended questions and only a few open-ended questions. The responses were analysed through descriptive statistics, in several cases also included cross-analyses. The public consultation was a 12-week internet-based questionnaire. More than 190 inputs and 15 position papers have been received from Business and trade associations, Citizens of the EU, non-profit organisations, Financial intermediaries (private equity, business angels, venture capital funds, banks, promotional banks, guarantee institutions), Intermediary structures such as incubators/clusters/innovation & growth agencies and Public authorities (member states, European agencies). Four types of analyses were conducted on secondary data: ·The portfolio analysis entailed the analysis of the COSME budget distribution over the different structural components of the programme, ie the Strategic Objectives and their operational (sub)objectives, the policy mix used in the programme (i.e. the policy instruments) and the modes of implementation. ·The composition analysis focused on the stakeholders that benefit of the COSME programme funding. The outcomes of this analysis informed especially the analysis of effectiveness, in terms of the capacity of the programme to attract the type of stakeholders needed for the attainment of the desired effects and the analysis of cost-effectiveness ·The time-to-grant analysis, based on EASME management data, and the success rate analysis of the open calls for grants, based on the EASME proposal database, were conducted to feed into the assessment of the COSME efficiency in the implementation of the programme. ·The cost-effectiveness analysis (CEA) entailed quantifying the not-monetised benefits that would be generated by one Euro of total costs. The methodology for the WATIFY study used desk research, media and social media analysis, surveys (for a total of 1673 responses) and interviews (45) to collect triangulated data. 4.2.Limitations and robustness of findings The supporting study, despite the limitations presented below, provided robust evidence in relation to the five evaluation criteria. It allows to take stock of progress made since the beginning of the programme , it evidences what works well and what doesn't and has implemented sufficient mitigating measures to contrast the below identified limitations. Data availability and reliability of the data analyses The COSME regulation foresees the publication of a yearly monitoring report. At the time of the evaluation, in 2017, only the 2014 monitoring report was published, the 2015 report was only available in a draft version and the 2016 data was partially available. Besides, the variety of implementation modes (financial instruments, contracts, grants) and the diversity of actions implied different data sources and there is not a consolidated source of data besides the monitoring report. On top of that, except for access to finance, the enterprise Europe network or the Erasmus for young entrepreneurs that are long-standing activities inherited from the CIP programmes, most COSME actions were ongoing and not finalised. This represent about 20% of the programme and a substantial part of the objective 3, framework conditions and competitiveness and a less substantial part of access to markets and of entrepreneurship. Consequently, a major challenge for this evaluation was the difficulty to obtain the needed data and the quality of the data provided. While the contractor succeeded in collecting all data needed for the portfolio analysis, data that could be collected in relation to the profile of the programme beneficiaries was limited to some action lines. Even though these action lines accounted for about 80% of the budget committed, it implies that the data related to the geographical and sectoral profile of other activities of the programme beneficiaries had to be estimated. Overall, the data collected through the seven targeted consultations can be considered as reliable; the survey population resulted representative for the overall population (or in the case of the LGF SME beneficiaries, sufficiently representative for the target sample). There is one exception: in the case of the consultation targeting EEN SME clients, data on the profile of these beneficiaries was not available, so no stratified random sample could be created (as was done for the LGF beneficiaries, instead). The distribution of the questionnaire to the SMEs by the intermediaries implied also that the evaluation had no control over the process; the lack in data on the profile of the EEN SME clients hindered a quality control of the representativeness of the survey population.

Taking this uncertainty on the reliability of the data into account, the contractor complemented and triangulated the information collected through this survey with the (preliminary) data from the EEN Performance Enhancement System (PES) database and with the other monitoring data provided by EASME. The requirement to contact the SME beneficiaries of the larger actions (in the case of the EFG even for the ‘qualitative’ consultation) only by using a cascade approach, i.e. through the intermediaries, deserves a specific note. The fact that the contractors' study team did not have direct control over the number of SME clients that were invited to participate in the survey resulted problematic in some cases. In the case of the survey to the LFG beneficiaries, it implied that the contractor did not receive any response from the beneficiaries located in France because the financial intermediary did not circulate the survey before the deadline, despite the contractors' best efforts. In the case of the EFG qualitative consultation, only three out of five intermediaries were available for collaboration and the team received only four completed questionnaires (out of 12) from the EFG SMEs. In the case of the EEN clients' SMEs, the number of respondents from COSME-participating third countries was too low to make a meaningful analysis. The contractor therefore endorsed the recommendation made by the CIP and EIP final evaluation teams to ensure in the future the possibility for evaluation teams directly to contact beneficiary SMEs. As regards WATIFY, the main weakness of the methodology lied with the limited availability of data for the first phase of the campaign (2014-2015). Yet the monitoring data collected was sufficient to formulate answers to the evaluation questions and in some cases, present comparisons between the two phases of the campaign. Therefore, adequate triangulation of qualitative and quantitative data collected both throughout the campaign’s implementation and during this external evaluation, allows for the formulation of evidence-based answers to the evaluation questions. 5.Analysis and answers to the evaluation questions 5.1.Relevance ·How relevant is the COSME programme to the stakeholders (public and private) and the EU citizen? Both intermediaries and beneficiary SMEs consider the financial instruments in COSME to be relevant to their needs, both in terms of the conditions set and the size of the financing offered - even though there are some issues remaining. The objective of the LGF is to help the financial intermediaries provide more loans and leases to riskier SMEs, thus expanding the range of SMEs they can finance. The ‘on demand’ principle and flexibility in the design of the programme aim at facilitating the adaptation to the market needs and to the needs of financial intermediaries. The programme supports all kinds of SMEs that face difficulties in accessing debt finance, without considering any specific sector or any specific country base, but rather the SMEs’ level of risk for the lending sector. COSME takes a flexible approach and allows any institution implementing the LGF to increase its activity with ‘high risk’ or ‘higher risk’ SMEs as per its own definition of risk. This greatly facilitates the take up of the LGF. Nevertheless, financial intermediaries mentioned that some needs are not sufficiently supported by the LGF, in their responses to the targeted consultation and/or interviews. The subordinated loans for more than EUR 150k to an innovative SME cannot be supported under InnovFin nor under COSME and the loans over EUR 1.5 million (assuming a 50% guarantee rate). The surveyed LGF intermediaries also considered the time limitations to the guarantees (a minimum of 12 months and maximum of five years for guarantee amounts above EUR 1.5 million and 10 years for those below) to be inadequate for the needs of financial intermediaries and SMEs. The objective of the EFG is to crowd-in more capital for pan-European operations at the growth and expansion stage. Interviewed stakeholders regarded this focus of the EFG instrument as appropriate. The flexibility to crowd-in the pan European Fund(s)-of-Funds is also regarded as relevant. However, the clause that the EFG can invest in a VC (only) up to 25% of the total amount is viewed by funds and the EIF as suboptimal for creating an attractiveness effect for other private investors. In comparison, EFSI can invest up to 50%. The single web portal on EU finance (to be accessed through Your Business Europe or www.accesstofinance.eu ) addresses the information asymmetry failure. It provides contact details of around 1,500 intermediaries and information on all financial instruments under the new EU programmes 2014-2020 (COSME, EaSI, InnovFin under Horizon 2020, Life and the EU Investment Plan under EFSI, and the new financial instruments supported by European Structural and Investment Funds). It also provides information on how to access financial instruments from 12 different EU programmes in 39 countries, and on EU financial instruments with a clean-tech investment focus for climate-change objectives. The portal reached 150,000 monthly page views in 2015. According to the surveyed SMEs that benefited from the the EEN services, the network addressed three major failures: ·The broad range of information services, covering a.o. H2020 funding opportunities, information on financing opportunities and opportunities to increase competitiveness and innovativeness in the Single Market and beyond, address the clear (and ongoing) information asymmetry failure SMEs face to enhance their competitiveness ·Through its advisory services, the EEN also addresses the capability failure, i.e. the SMEs’ need for know-how on management processes, customer needs and how to enter foreign markets ·The Network also addresses networking failures by helping SMEs to find (international) cooperation partners and by providing an avenue for intermediary organisations to collaborate. Confirmation of the relevance of the EEN services to SMEs can be found in the importance attributed to these actions by the SME clients ( Figure 1 ). In general, the SMEs’ view on the extent to which Network services address their needs is quite positive.

Source: Technopolis, December 2017, https://ec.europa.eu/docsroom/documents/28084 ; p.36 The tourism actions addressed the information asymmetry and networking failures. More than 60% of survey respondents thought the programme largely covered these failures. While the COSME actions therefore show a particularly high level of relevance for the SMEs in the Tourism sector, the responses also show two major gap areas: the exploitation of synergies between the tourism offer and other industries, and the enhancement of skills among tourism providers and their employees. In the field of Entrepreneurship, the COSME programme includes information and awareness-raising measures, several portals and support services, networks to share knowledge and best practices, strategic intelligence platforms and measures to develop entrepreneurial human capital. Besides the Erasmus for Young Entrepreneurs (EYE) programme, COSME also funded actions on digital entrepreneurship, women’s entrepreneurship, migrant entrepreneurship, senior entrepreneurship and entrepreneurship education, and early warning/ second starters. EYE has a high level of relevance to the needs of the respective target groups, with no major gaps identified. A large numbers of Host and New Entrepreneurs who had participated in the EYE programme during the 2014-2016 period were surveyed. These (potential) entrepreneurs assessed the extent to which a series of barriers to entrepreneurship were present in their country today. Their responses provide widespread confirmation of the existence of market and systemic failures in this area. The large majority (jointly, 92%+) agreed that entrepreneurs face obstacles to setting up businesses, that new businesses struggle to survive and grow, and that there is a lack of effective policy support related to entrepreneurship. There was also a widespread (though less strongly held) belief that there is a lack of entrepreneurial culture, weak entrepreneurial spirit, and low levels of entrepreneurial firm creation in Member States. Figure below shows that more than 90% of these survey respondents agreed that COSME – through its largest entrepreneurship action, the EYE programme - helped to address all these areas to some extent, and particularly the lack of entrepreneurial culture and spirit. Source: Technopolis, December 2017, https://ec.europa.eu/docsroom/documents/28084 ; p.38In the field of Internationalisation, the emerging markets are covered in COSME through the clusters internationalisation and IPR Helpdesks. A survey undertaken by the ECCP platform with the ESCPs’ project coordinators shows that, by June 2016, in the early phases of the implementation of the partnerships, 47.4% of them had selected USA as a target for international cooperation. Further popular markets targeted included Brazil, Canada, China, Japan and Mexico. These are in line with the EU largest trade partners. Other actions such as the EU’s Low-Carbon Business Actions (LCBAs) in Brazil and Mexico, supported through the EU Foreign Partnership Instrument are examples of other approaches targeting the matching and direct funding of businesses from emerging European industries with partners from new emerging geographical markets . The 2015 Flash European Barometer on Internationalisation of SMEs showed that SMEs considered the complicated administrative procedures, high delivery costs, and difficulties in identifying business partners abroad to be key bottlenecks for internationalisation. A fourth area of concern is the perceived high investment cost. COSME actions such as the EU-Japan Centre and the IPR Helpdesks are very relevant in reducing the administrative burden. Actions providing support to identifying business partners, such as the European Strategic Cluster Partnership (ESCP) – Clusters Go International programme (further: ‘Cluster Internationalisation’) and the business missions organised in the context of the European Cluster Collaboration Platform (ECCP) and the EU-Japan centre are very relevant to the overall need of SMEs in building trust in finding suitable partners. The COSME actions do not address the fourth barrier, which is the high costs that come with building trust in finding suitable partners. A potential upgrade of the programme could therefore include other types of support, such as demonstration projects, feasibility studies and knowledge-acquisition activities. For the EU citizen, the relevance of the programme is mainly related to economic growth. The major drivers for economic growth constitute the key focus of COSME. COSME shows limited relevance for topics beyond the economic sphere, though, when considering numbers of actions funded and budget allocated to them. The high-level objectives related to inclusive and sustainable growth are addressed mainly in an indirect manner. The programme relevance related to sustainable development is therefore mainly an indirect one. For example, among the Venture Capital (VC) funds that received EFG funding, about three quarters are focusing on the ICT sector and clean technologies. Societal goals are also the funding purpose of many national promotional banks that signed an agreement for the LGF. Sustainable growth was explicitly pursued also through the Network focus on ‘Measures to increase SME access to energy efficiency, climate and environmental expertise’. ·To what extent are the initial objectives of the COSME programme (still) pertinent to the needs and problems it was designed to address? According to the supporting study, the four specific objectives are still relevant. First, despite the economic recovery in the EU, access to finance remains an issue for SMEs; the situation remains uneven among countries. In addition, the negative correlation between finance and firm size, age, and degree of innovation that emerged from the 2014 Survey on the Access to Finance of Enterprises (SAFE) seems to persist. The 2017 ECB survey, for example, shows that in the euro area large enterprises continue to experience easier access to finance than SMEs, except in the case of equity financing. The explicit objective of the LGF is to help the financial intermediaries in providing more loans and leases to riskier SMEs that have difficulties in obtaining funding through the traditional banking system. LGF directly addresses the financing gap; the limits set to the tickets also ensure that the facility is of specific interest to SMEs. The objective of the EFG, instead, is to cover the needs of start-ups and SMEs in general in their growth and expansion stage. Second, a 2015 EC Staff Working Document indicated that in the field of internationalisation, performance among EU SMEs shows limited progress. While the percentage of EU-based SMEs with extra-EU imports and exports of goods improved since 2008, the European Commission reported in 2014 that only 25% of EU-based SMEs were engaged in export activities and an even smaller share of SMEs (7%) exported beyond the EU. Third, reflecting the considerations made in the EC Staff Working Document, both the 2015 and the 2016 Annual Growth Surveys (AGS) show that pursuing structural reforms in the MS is key to modernising EU economies and ensuring better framework conditions for business. Further removing regulatory barriers to the Single Market, establishing the Digital Single Market and continuing the REFIT process for simplifying existing legislation have been highlighted as priorities for 2015; according to the 2016 AGS, increasing transparency, efficiency and accountability in public procurement, ensuring open and competitive product service markets, and modernising the public administration remain further challenges in the EU.

Fourth, fostering an entrepreneurial spirit among the European citizen has been a major policy objective during the last two decades. The SBA factsheet 2016 informs that at the EU28 level, there has been continuous (yet moderate) progress since 2008. Early stage entrepreneurial activity and entrepreneurship intentions have steadily increased since 2008; however, the factsheet emphasises, “more policy efforts are needed to turn entrepreneurship into a desirable career choice and to promote education as a means to develop an entrepreneurial attitude”. ·How has the programme adapted to the political priorities, for instance to the new single market strategy and its particular objective to support start-ups and scaling-ups? The policy context of the COSME programme starts with the Europe 2020. The policy basis of the COSME programme is the SBA Review of 2011. The Entrepreneurship Action Plan that was published in the same year (2011), as well as the Single Market Strategy and the Start-up and Scale-up Initiative, both launched in 2016, constitute the other building blocks for the strategic decision-making on the COSME Programme. The Single Market Strategy sets the need to support SMEs in the context of the many obstacles that SMEs, start-ups and young entrepreneurs are facing, such as access to finance, the complexity of VAT regulations, aspects of company law and how to comply with various regulatory requirements in different markets. The Start-up and Scale-up Initiative was set up in November 2016 to “reduce barriers for young businesses in the Single Market”. It followed shortly upon the launch of the Single Market Strategy and aligns with the COSME objectives, namely providing SMEs with a better access to finance and a better business environment. It echoes the continuous work of the Commission to foster better regulation (through actions such as REFIT and the High-Level Group on Administrative Burden). The European Commission Investment Plan for Europe approved in 2014, also contributes to the COSME policy context. The portfolio of actions in the COSME programme has achieved a high level of policy relevance. COSME responds particularly well to the priorities set out in the recent Single Market Strategy and Start-up and Scale-up Initiative (2016), setting a pronounced focus on support to start-ups, scale-ups, and second starters, but includes also several of the priorities defined by the Juncker Commission. The Entrepreneurship Action Plan 2020 guides the design and implementation of the COSME entrepreneurship actions. The flexibility in the COSME programme allows it to respond in a swift manner to emerging high-priority topics by launching new actions addressing new or more emphasised priorities, and by steering more budget towards areas that constitute a priority area of rising importance. The WATIFY campaign is underpinned by several key initiatives. The holistic Europe 2020 Strategy includes A Digital Agenda for Europe as one of its pillars. The objective of the Digital Agenda for Europe is to accelerate innovation, economic growth and quality of life by maximising the social and economic potential of ICT usage. Therefore, the Digital Single Market (DSM) strategy, launched in 2015, provides businesses and individuals with access to online activities without restrictions. The DSM specifically aims to: 1) provide better access for consumers and businesses in reaching online goods across Europe; 2) create favourable conditions for digital networks and services; and 3) maximise the growth potential of the European Digital Economy. The DSM strategy encompasses the Digitising European Industry initiative, which consists of five pillars and provides a set of measures to help industry, SMEs, researchers and public authorities to maximise their gains from digitalisation as well as to support and link up national level actions to apply a coherent integrated approach to digitisation across the EU. Overall, the WATIFY campaign helps to put into action EU policy objectives in the field of industry digitisation and thus has strong relevance against EU policy context. 5.2.Effectiveness ·To what extent is the COSME Programme progressing towards its specific objectives? The financial instruments have been effective in reaching their outputs, even though progress is modest for the EFG. The LGF reached a considerable number of SMEs, proposed overall more favourable financing terms, demonstrated leverage in SME financing, and increased the supply of debt finance in most Member States. According the mid to long term objectives set in the annex of the COSME regulation for the LGF were to get by 2020 a Value of financing mobilised ranging from EUR 14,3 billion to EUR 21,5 billion and a number of firms receiving financing which benefit from guarantees from the COSME programme ranging from 220 000 to 330 000. The European Investment Fund (EIF) has – in the time-period evaluated – managed to assign around EUR 611.7m (including the EFSI enhancement) allowing for a volume of EUR 5.5bn in debt financing provided to 140,000 SMEs for the LGF. It signed EFG agreements with nine financial intermediaries contributing a total of EUR 101m to the selected funds, which in turn provided 12 SMEs with risk capital to support their expansion and growth. The EFG is hereby falling behind on its targeted commitments. Geographically, the beneficiary SMEs are concentrated in the more mature financial markets. The Enterprise Europe Network (EEN) has shown a strong capacity to reach SMEs throughout Europe, including 150,000 SMEs that participated in the EEN co-operation and advisory services. Thanks to the EEN services, over 8,000 SMEs set up co-operation agreements with SMEs ‘across the border. The EEN services mainly supported SMEs in improving the quality of their goods and services, leading to (expected) growth in turnover and especially, entry to new (geographical) markets, both in Europe and beyond. The Impact Evaluation of the Network (2008-2014) concluded that the average net effect for SMEs participating in the Network was 3.1% increased annual growth. This result is confirmed in the COSME interim evaluation where SMEs present an overall growth rate that is nearly 6.5 percentage points higher than a comparison group. Surveyed SMEs argued that the core role of the Network is to help companies grow and find new partners, and that the Network services are adequate in doing so, which is further reflected in the high rates of satisfaction where 86% of SME clients surveyed are satisfied with the Network’s services and 93% would recommend its services to others. The evaluation of the IPR SME helpdesks reveals that the action is very relevant and that results indicate it could reach its objective on the medium and long term. Evidence shows that it has been well designed to make EU SMEs aware about their Intellectual Property Rights (IPR) in third countries' markets and contributes to the overall objective of the COSME programme. In April 2017 the IPR SME helpdesks had registered 3154 helpline users. With 1347 registered helpline users against 1000 targeted, China performs well. The Latin-America also with 1217 registered against 800 targeted. Due to the belated implementation of its helpline, the South-East HD reached only 590 users against 1000 targeted. The EU-Japan Centre for industrial cooperation was effective in fostering industrial and trade cooperation between the EU and Japan. Its objective is to facilitate and foster the cooperation between European and Japanese companies and clusters by providing policy analysis, services to businesses, SME support (e.g. on tax and public procurement), organising information events and knowledge-sharing opportunities as well as networking activities.

Activity Nr of activities / stakeholders reached Policy seminars and analysis events In 2014, eleven events; 2015 ten events were held; in total, close to 3,000 participants Company visits to address the practical adaptation of Japanese management and production systems to Europe Around five company visits per year, lasting one day each Webinars to inform EU SMEs of possible partnering opportunities and support for improving EU manufacturers’ competitiveness Average nr of participants per webinar: 107 Cluster matchmaking events to inform EU SMEs of Japanese clusters and the opportunities for cluster-to-cluster partnerships Since 2014, three actions per year, attracting between fifteen to twenty SME Source: EU-Japan Centre for Industrial Cooperation. Activity Report for Fiscal Year 2015 Under the framework conditions and competitiveness objective, most of the actions were still under implementation at the time of the evaluation. Nevertheless several actions such as the SME envoy Network, the Clusters Go international or the Tourism actions, have reached the milestones in terms of outputs set in the COSME yearly work programmes. Overall, stakeholders are satisfied with the results of the SME policy actions. The Envoys perceive the network as a highly valuable EU-level forum where ideas and practices are exchanged. The SME Performance Review as well as the factsheets are used by the national representatives and are considered to be of high quality. Many events are organised throughout Europe during the SME Week, and the SME Assembly gathers stakeholders from all MS. The main outreach tool, Business Planet, is broadcasted on Euronews. There is a general perception that the activities organised at the EU-level contribute to a convergence of SME policies across COSME countries. For the Tourism actions, the consulted stakeholders and beneficiaries indicated as direct results the creation of new strategic partnerships across borders and more visibility in international markets of touristic destinations in the EU. The Tourism actions are geared towards the involvement of actors along the value chain. Based on the data available, they directly involved about 100 companies, active in the tourism sector, 50 private enterprises active in other sectors and 200 organisations ( mainly business associations active in tourism), public agencies, user organisations, and professional service providers (e.g. marketing specialists). The "Clusters Go International" actions show good potential to lead to an improved strategic position in global value chains and an enhanced access to potential inward investors as survey respondents and interviewees alike highlighted that the activities are based on a strategic analysis. The limited budget is flagged as a hurdle for their internationalisation activities and was reported by 90% of the clusters as an important bottleneck. In October 2017, the Clusters Go International action involved 25 European Strategic Cluster Partnerships (ESCPs), launched under the "Clusters Go International action representing 145 cluster organisations across 23 European countries and more than 17,000 European SMEs. Only 15 out of the 25 selected ESCPs were funded due to budget constraints. They account for approximately 95 clusters reaching out to over 10,300 European SMEs. The Clusters Go International action succeeded in involving a high number of clusters, some even at a voluntary level, testifying the high interest in this action in the EU cluster community. Moreover, projects show overall good progress in reaching the outputs expected, such as partnership agreements. The overall achievements of the 1st generation of European Strategic Cluster Partnerships (ESCPs) for going international 2016-2017 prove their success in supporting SME internationalisation. Over a 24 months period, they involved 2000 SMEs in activities targeting international third-markets generating 85 concrete business cooperation cases with international partners. 370 Cluster-to-Cluster events and 3010 Business-to-Business events have been conducted, whilst 39 Memoranda of Understanding and 45 collaboration projects implemented between EU clusters and international peer organisations. The interest in the action remained high for 2018-2019 with 23 new partnerships established since . The e-skills action reached the outputs expected. Stakeholders interviewed were positive. In 2016, it covered 21 different countries where events were organised and many stakeholders and high-level policy-makers were involved, including members of the European Parliament. Stakeholders and survey respondents unanimously indicated the effective engagement of various stakeholders such as education and training organisations, employees and entrepreneurs as the most important factor in driving progress towards an enhanced awareness and especially an enhanced availability of digital skills. The two WATIFY campaigns managed to achieve 4 of the 5 specific objectives: to promote the transformation of industry through advanced technologies by sharing success stories ; to stimulate digital entrepreneurial culture by identifying and promoting digital transformation of SMEs and digital start-ups and their success (or failure) stories at pan-European, national, regional and local levels; to spark and support new business ideas in the digital economy and boost their successful commercialisation; and to strengthen business confidence in the application and added value of digital and key enabling technologies, business processes and new business models. However, WATIFY 2 did not succeed in supporting Europe’s regions to translate their smart specialisation strategies in the area of digital and key enabling technologies. Neither desk research, nor interviews were fruitful in collecting information on the support provided by WATIFY to regions for the translation of their smart specialisation strategies into actual projects. Under the Entrepreneurship objective, the Erasmus for Young Entrepreneurs (EYE) was successful in reaching its expected outputs and outcomes. It involved in total around 2,000 New Entrepreneurs and we estimate that after approximately a year and a half, it led to the creation of 250 new companies, EUR 5 million of additional turnover, and about 1,000 new jobs. The most prominent weakness of this action line lies in the small scale of its activities. ·What are the factors driving or hindering progress and how do they link with different actions of the programme? The key factor of success for COSME is to rely on an extended network of intermediaries that ensures proximity to SMEs and to stakeholders. This is particularly the case for the EEN, the clusters or EYE but also for the financial instruments. The LGF has reached a high level of take-up thanks to the flexibility of its design. However, financial intermediaries report high administrative costs for entering into an agreement with the EIF and complying with its requirements are problematic. The threshold of EUR 150 000 above which the financial intermediaries must check if the SME does not meet any of the innovation criteria for funding under the H2020 InnovFin instrument creates the negative effect of inducing the intermediaries to limit their financial offer to this threshold. Most important, the threshold is deemed inadequate to the needs of many SMEs. The EFG is falling behind on its targeted commitments. The growth projects of these SMEs mainly focus on expansion in the existing (local) markets and the development of new products and services. The key barrier identified in the supporting study is the maturity of Venture Capital markets in the EU. Geographically, the beneficiary SMEs are so far concentrated in the more mature financial markets. The effectiveness of the EEN services relate to the profile of the EEN member organisations and their embeddedness in their national and regional environments. There is a close relationship between the services provided in the context of COSME and these organisations’ ‘usual’ services. The credibility of the organisation in delivering quality services is a primary condition for the use of the EEN services by SMEs. Another enabling factor is the proximity of the members to the local SMEs, as well as the potential for knowledge sharing and information. However, SMEs are not always aware that the EU funds EEN services and SMEs awareness of the existence of the Network could be improved. Despite the success of the Erasmus for Young Entrepreneurs, the entrepreneurship objective does not seem to have a strategic focus in COSME work programmes. Actions originate from different places and are then managed across multiple Commission services, with only informal and unstructured interaction across them. Except for the financial instruments and the EEN, the fragmentation of the programme into many smaller activities for 20% of the programme reduces the potential impact of actions. This is particularly the case for EYE and for the Clusters. ·To what extent is the Programme contributing to the five union priorities for a sustainable and inclusive growth? The COSME intervention logic indicates that contributions by the COSME programme to the higher-level EU policy priorities are expected in four areas: an increase in ‘Jobs and growth’, an enhanced ‘Business creation and growth’, a strengthened ‘Global competitiveness of the SMEs’, and an increase in ‘Inclusive and Sustainable Growth’. In the graphs below we first set these data in the context of statistical data related to the SMEs’ employment shares at the sectoral level ( Figure 2 ) and the developments from this perspective in recent years ( Figure 3 ). Sectors with the highest shares of COSME beneficiaries are highlighted in dark red; those with high shares are highlighted in pink.

This analysis suggests that COSME has a high potential for contributing to the attainment of the Jobs and Growth objective in sectors that are the most important for the EU economy. However, as explained in the relevance section, its potential to reach impact in relation to global and societal challenges is limited. The main COSME Instruments, such as the Enterprise Europe Network or the Loan Guarantee Facility target all SMEs without distinction of sector or activity. This universal offer means that the support to policy objectives such as Climate change, Gender Mainstreaming or Youth Unemployment can only be indirect and due to undesired effects. Source: Annual report on European SMEs 2015/2016; Eurostat, Statistical Offices & DIW Econ Source: Annual report on European SMEs 2015/2016; Eurostat, Statistical Offices & DIW Econ 5.3.Efficiency ·Are the costs generated by the programme proportionate to the benefits generated? COSME is operating at a reasonable level of efficiency overall, with its principal components all being implemented in line with the specific objectives and timetables set out in the annual work programmes. The feedback from beneficiaries is generally positive with some exceptions. A substantial majority is reporting a good cost-benefit ratio for their individual participations. For example, more than two thirds of EEN respondents (68%, 158 respondents) reported that the benefits outweigh the time investment. Surveyed beneficiaries report some issues of administrative burden. For example, half of the Cluster Go International (CGI) Participants responding to the survey thought the duration of the CGI project funding was not appropriate; about 40% of them thought the funding needed for the internationalisation activities was not correctly estimated. The financial intermediaries indicated that the reporting requirements are burdensome and risk reducing the attractiveness of the LGF. They also argued that the EFG’s administrative burden is substantially higher than is normal in the Venture Capital (VC) sector. After three years of experience under the COSME programme, the IPR SME helpdesks has been showing effectiveness and should now focus the resources to gain in efficiency. To that effect, improved service quality is needed, as well as tackling the problems of insufficient promotion of activities and improving partnering services. There is no need for additional means in order to achieve more impact, however the use of the current ones could be optimised. The fact that intermediaries act as multipliers, can be seen as an efficiency lever, provided the visibility increases concurrently thanks to more promotion efforts. The strategy to reach the critical mass of SMEs needs to be improved. The evaluation concludes on the need for continued funding for the three regions and considers extending this type of service to India. The two WATIFY campaigns cost EUR 1,6 million and allowed to reach some 200,000 participants through an initial and closing event, matchmaking events, awareness raising campaign, video clips and case studies. Participants to the matchmaking events insisted on their usefulness and even asked for more of these events. On the awareness raising events there could have been less for the same effect and usefulness. For the launching and closing events, the co-organisers mentioned that it generated some administrative burden. Surveyed SMEs agreed that their participation has resulted or will result in a number of benefits for their company: their increased competitiveness in the market, higher profit margin, higher quality of their products, more clients, new business partnerships, support in introducing technological changes and funding opportunities for technological changes. Overall beneficiaries found the campaigns useful and cost-effective. Several potential improvements were identified: The delayed launch of the WATIFY website prior to the launch of the second campaign created obstacles for the promotional activities; The timing in organizing the events caused some inefficiencies and unexploited potential; The significant Facebook presence in countries outside the EU Member States or COSME programme countries for the second phase of WATIFY shows that this communication channel could have been used in a more efficient way. ·What are the regulatory/administrative costs and the benefits for the different stakeholders? COSME’s contribution to EASME for the period 2014-2016 was EUR 21,7m, which covered the operational (administrative) aspects of the programme. This is approximately EUR 7,2 million per year and represents 6.6% of the budget committed to COSME in the same period, excluding the budget for ‘Access to Finance’ managed by EIF. For the EEN, approximately 600 Network member organisations are grouped in consortia organised at the national or regional level that have been selected through open calls. On average, approximately 5.5% of the COSME budget made available to the Network member organisations is dedicated to management/coordination activities. The EYE European Partnerships (EPs) are consortia of Intermediary Organisations officially awarded by EASME, following an open call for proposals. Their staff costs are included in the grant provided by COSME The European Investment Fund (EIF): The EIF acts as entrusted entity for the implementation of the COSME financial instruments through a mandate given by the Commission. For the period 2014-2016, the costs for the COSME implementation by the EIF amounted in a total of EUR 4.5 million for EFG and EUR 17 million for the LGF. These figures corresponded for EFG to 2.6% of the total EU budget committed and for LGF to 4.5%.

The supporting study presented several Cost Effectiveness Analysis in terms of number of SMEs reached, the increase in turnover or the employment generated. For example: Each EUR 1 million invested in the EEN has led to an increase in employment of circa 377 people among client SMEs. This is based on an increase of two employees per company in the period 2014-2016 (calculated from our SME client survey), the total number of companies supported (210,000), and the additionality factor. Each EUR 1 million invested in LGF has led to an increase in employment of circa 235 people among client SMEs. The evaluators further estimated – after accounting for the additionality – that for each EUR 1 million invested into the LGF (effects fully attributable to the Loan Guarantee Facility): ·additional employment of 491 will be created; ·additional EUR 22 million in turnover will occur in treated SMEs; ·470 SMEs will be supported. Each EUR 1 million invested in EYE has led to an increase in employment of 33 people among SMEs (Hosts) and New Entrepreneurs. Again, this a very positive result; however, it implies that EEN and LGF are more cost-effective than EYE in terms of supporting job creation. The Cluster Go International action reached 3,800 SMEs per EUR 1 million invested. ·How efficient is the implementation structure and governance of the programme? The main strength of COSME is the clarity of its work programme descriptions, leading to a relatively small share of ineligible proposals responding to the calls for grants. No major administrative bottlenecks were identified and the simplification measures that were introduced were overall considered as positive, even though the new IT system clearly had some teething problems. A major weakness of the programme design is the unbalanced distribution and strong fragmentation of the budget available. As stipulated by the COSME regulation, the large majority of the COSME budget (80%) is used for the two key actions. The remaining 20% of the budget is spread over a large number of small actions. This fragmentation negatively influences the potential for cost-efficiency in the programme implementation and accentuates the limits in strategic steering and coordination of the programme. Competition in some COSME calls can be quite high, especially for the smaller actions, which can be considered a direct consequence of the funding fragmentation. This places an additional burden on applicants, which can be particularly problematic for SMEs and may lead to a narrowing of the applicant base, both geographically and sectorally. Regarding the contribution of EASME to an efficient management of the COSME programme, two issues can be noted. First, the time-to-grant for the open calls was shorter than the target set by EASME. Second, the number of small actions delegated to the agencies requires the involvement of a proportionally higher number of staff than for bigger actions such as the EEN. In addition, surveyed beneficiaries indicated also the difficulties in using the EASME IT systems in the first years of the programme and the user-friendliness of the IT tools. Another major weakness of the programme is the quality of data management. The lack in quality and especially completeness of the data on the beneficiaries of the programme constitutes a major hurdle for an efficient management of the programme implementation. The spread of the implementation responsibilities over the many actors involved (the EIF, EASME and in 2014-16, about 15 DG GROW units) creates a considerable challenge to efficient programme management and coordination, with a risk of weakened programme oversight. It also makes it very much harder to evaluate the programme. The various reporting systems’ focus on activities and outputs is equally problematic. A stronger attention for the collection of data on the profile of the beneficiaries is needed to allow for a proper monitoring of the programme outcomes and progress towards reaching its objectives. 5.4.Coherence ·Are the different actions of COSME implemented coherently between them? Overall, the COSME programme shows a good level of internal coherence: efforts are increasingly being made to create synergies and no substantial overlaps could be identified. The EEN services are the most-often mentioned targets for synergies. The risk is to overcharge the EEN with responsibilities to which the Network cannot respond in an efficient way, and with the risk of losing the focus on its core activities. More synergies could be created by taking a more integrated, cross-thematic approach. The communication activities related to the financial instruments created a certain abundance of information; those related to the entrepreneurship actions appeared to be run in isolation from each other. The assessment is positive in relation to the synergies and complementarities created between the Your Europe Business portal and the EEN services, and between other COSME activities geared towards internationalisation such as the EEN and Clusters Go International programme.

There is a positive coherence in relation to the complementarities and synergies created between Clusters Go International with other COSME activities geared towards internationalisation and the emerging markets of the main EU trade partners are covered through the action . A better cooperation between the IPR SME helpdesks and the Cluster Internationalisation actions should be a priority for the future. The interaction between the three helpdesks should be maintained, as well as with other COSME initiatives (mainly the EEN) and other EU and national initiatives. ·How are the different COSME actions overlapping/synergizing with the activities of ESI funds, H2020, EFSI, EASI and other EU programmes? The division of tasks between COSME and H2020 is clear and we noted no significant overlaps between COSME and H2020 or other EU activities. Nevertheless, there is room for the creation of more synergy and complementarities, especially for the SME internationalisation activities. Overlaps between the COSME LGF and financial instruments established under ESIF may occur when addressing similar SMEs in the regions. The latter was also highlighted in the independent Evaluation of the EFSI Regulation, which was concluded on 4 June 2018, namely that there is a risk of competition between ESIF financial instruments and LGF, and even indirectly EFSI. The more than 625 members of the EEN help about 250.000 SMEs per year to increase their competitiveness and innovativeness in the Single Market and beyond by offering integrated services. There is a clear market failure for SMEs regarding information, funding, accessing new markets and networking to internationalize their business outside the home country. Network organisations provide information on funding opportunities made available by the various EU programmes such as COSME financial instruments, Horizon2020 SME Instrument and Structural Funds. The Cluster Go international can also play a major role to incentivise European SMEs across regional industrial ecosystems to enter into joint business projects with partners in third countries for other related actions, such as the EU’s Low-Carbon Business Actions in Brazil and Mexico, supported through the EU Foreign Partnership Instrument . ·To what extent has the coherence been maximised in view of national programmes? The interplay between the EU, national and regional levels of support for SMEs is not always synergistic and complementary, even though no substantial overlaps were identified. Especially for actions where proximity to the SME communities is a strong enabling factor, better coordination with national and regional actions would further improve coherence. This is especially the case for the EEN services and the COSME actions supporting cluster organisations. Both EFG and LGF have adopted a bottom up approach, have the flexibility to combine with national programmes and appear to be rather complementary with other schemes. However, Surveyed LGF intermediaries see both complementarities (9 out of 16 intermediaries) and overlaps (10 out of 16) of the LGF instrument with national level actions. Coherence with initiatives at the national/regional levels is a topic of relevance especially for the EEN services. The Network builds on regional players that are embedded in the local environment. The survey with SME clients of the Network shows that most clients were unsure whether the Network services are complementary to, or overlap with, existing national or regional support in their own country; the findings from the survey with Network members showed similar results. During the interviews, the Network intermediaries explained that they actively seek this complementarity. For example, when prioritising their activities, they aim to focus only on those services that are not yet available in their region. Moreover, many intermediaries explained that they have a good collaboration with other stakeholders that provide services to SMEs in the region; they organise joint events or activities, and actively seek to coordinate their actions. These national and regional stakeholders include ministries, municipalities, chambers of commerce, EU info centres, specialists in IPR, lawyers, etc. By means of signposting, the Network intermediaries refer SMEs to other stakeholders in the field and vice versa when relevant. In conclusion, while just over half of the Network clients and members feel that the Network services are complementary to services provided at national or regional level, there is scope for improvement. In the context of the Cluster internationalisation programme, interviewees indicated that there is no clear coordination between EU-level and national level cluster policies, which is perceived as problematic especially in the context of the limited funding available for the cluster internationalisation actions in COSME. The interviewees considered that the limited COSME funding for CGI might be considered as an incentive for clusters to co-invest also their own resources to achieve the desired results. They emphasised that this approach does not sufficiently take account of the diverging levels of funding for clusters in the EU Member States. According to these interviewees, this approach hinders a level playing field for cluster organisations in countries without direct cluster policies. They therefore emphasised the need for an improved coherence and creation of complementarity in the EU funding for cluster internationalisation with the availability of national level funding. In this context, it is to be noted that only 3% of the CGI participating clusters are located in EU13 countries. The complementarity of WATIFY with similar national initiatives emerges from its European character. Besides these initiatives of a more cross-cutting nature, there are ones focused on specific topics / sectors. Some countries that used WATIFY materials agreed that while there are similar initiatives to WATIFY, it is important to have a European initiative encouraging enterprises to digitalise. Internally, the WATIFY campaign was overall coherent (in terms of there not being conflicting events or activities organised). There is a complementary aspect between awareness raising and matchmaking events. The latter were organised under WATIFY umbrella, and often included the cooperation with local or regional stakeholders. The former, in contrast, were organised by various actors in different European countries, and were used by WATIFY as platforms to introduce and promote the campaign, its objectives and messages. 5.5.EU added value ·What is the added-value of the programme and actions being conducted at the EU level? COSME has a good level of European added-value. The European dimension constitutes the very essence of the design of its actions and is crucial for their implementation and effectiveness. In most cases, the ‘subsidiarity’ of these actions, i.e. the benefit of their implementation at the European rather than national or regional levels, is therefore very high. While many national and regional initiatives also seek to strengthen the competitiveness of SMEs, the scale of support through COSME and its availability to financial and business support intermediaries in every EU Member State are quite distinct and highly additional. In several cases, the EU level actions have not only been additional to, but have also helped in enhancing national, regional and local level measures. Indeed, COSME provides important financial leverage that allows national and regional intermediaries to provide lending products, which have a higher risk profile compared to their normal product offering, and it allows offering support to a substantially bigger number of businesses than they might otherwise be able to service. Furthermore, national support programmes, especially in smaller markets, have higher leverage when combined with an EU-level programme. However, the added-value of the LGF suffers from the non-targeted approach, which so far has implied that the support did not sufficiently reach the less mature financial markets. In terms of EFG financing, intermediaries very clearly stated that EU action is additional, despite that as recognised by the independent Evaluation of the EFSI Regulation, which was concluded on 4 June 2018, there were initial overlaps with the Expansion and Growth Window under the EFSI Equity instrument. Despite that the two instruments largely have the same investment focus, operations have been allocated to EFSI since it has greater resources and can offer more favourable conditions. Moreover, the analysis from the supporting study reveals that the financing – supported by the LGF for example – also has triggered an additional investment from 21 % to 29 % as shown in the figure below.

Source: COSME Interim Evaluation (Technopolis, based on survey data) Further, by taking into account the actual value of the principal financing received by those SMEs, the evaluators have estimated that LGF has de facto triggered approximately EUR 1,25 billion as additional investments as shown in the figure below. Source: COSME Interim Evaluation (Technopolis, based on survey data) The distribution in the two figures above is based on the SME definition. From the graphical presentation in both figures, it is evident that whereas the medium or large enterprises trigger higher additional investment percentage wise, i.e. 29 %, the smaller, but more numerous, the enterprises are, the greater value of additional investments will flow in the EU economy, i.e. EUR 959 million. The supporting study also has identified via a dedicated survey that 65 % of the respondent SMEs are of the opinion that they would have borne negative consequences for their business plans in absence of LGF support. Source: COSME Interim Evaluation (Technopolis, based on survey data) As shown in the figure above, these negative consequences for 65 % of the SMEs mean de facto that 44 % would have continued their business project on a smaller scale and 21 % would not have been able to implement their business plans at all. The European dimension is at the core of the Enterprise Europe Network. It allows for the attainment of a scale and quality of the services, and in some cases, even the implementation of the service as such, that would otherwise not be possible. The EEN’s role as an intermediary, involving Chambers of Commerce and national/regional innovation agencies, provides the advantage of a gateway for reaching SMEs; its EU added-value could be strengthened by focusing on those services that build upon the transnational characteristics of the Network itself, i.e. the internationalisation and single market penetration. Options to ensure an appropriate level of co-financing and/or funding from EU funds could be examined. The IPR SME helpdesks add value at EU level by developing and broadening their expertise to all EU SMEs. In order that any SME in any EU MS have access to an equivalent quality of IPR service, it is of specific value to be able to offer them an IPR one-stop-shop to accompany them in their globalisation projects. The Cluster Go International program (with its fostering of European partnerships among clusters in order jointly to develop and implement internationalisation strategies) shows very high EU added value, where the scale and depth of support goes well beyond the support that can be offered to European SMEs through national or regional initiatives . A separate evaluation of cluster initiatives from 2014 concluded for instance that the European cluster initiatives "generated added value through structuring cluster cooperation contributing to the emergence of European meta-clusters" and have reached out to a wide range of clusters, while flagging out that they lacked the financial means to involve SME sufficiently.

·To what extent and why do the issues addressed by the programme continue to require action at EU level? The enhanced added-value for the Union of the proposed financial instruments lies in addressing market failures that cannot be addressed by Member States. Funding at the supranational level in Europe allows the continent to match levels of funding seen in the United States. A discontinuation of the instruments would set at risk the current positive developments. We have seen in the analysis of relevance that the market gap on access to finance for SMEs is still an issue despite the progress made. According to LGF intermediaries, if LGF support were no longer available, SMEs would face more difficulties in getting access to finance. It could be expected that fewer SMEs would get a loan or that interest rates and collateral requirements would rise. The effect of a hypothetical termination of the LGF support on financial intermediaries would be a reduction of activities, both in terms of a lower volume of (counter) guarantees provided and in terms of a reduced number of products offered to higher risk SMEs. The EFG intermediaries considered action at the European level to be crucial for the European equity market to gain maturity. Equity markets in Europe are still relatively weak and only a few larger Member States can sustain their own equity markets. The EEN member organisations stated in the survey that the quality, the coverage and the variety of services in their own country or region would decrease or stop if the Commission would lower funding. Full regional coverage and the principle of reciprocity are essential for the effectiveness of the Network. Therefore, if even only a small number of regions would not able to continue their support offer, it would have negative impacts on the service delivery in other parts of the Network as well. On Entrepreneurship, there is still substantial room for further improvement, with data persistently showing relatively low levels of entrepreneurial interest and activity, as well as high rates of failure and slow rates of growth amongst newly established firms. Also in the case of the other COSME action lines, the ‘benefit of their implementation at the European rather than national or regional levels, is very high. This is especially the case for those actions where the European scale is of critical importance for the attainment of positive effects also at the national and regional levels. Examples of such actions are those related to eSkills, the Tourism actions bringing together actors in European value chains, the Clusters Go International programme fostering European partnerships among clusters in order jointly to develop and implement internationalisation strategies. Multiple barriers still exist preventing SMEs from undergoing digital transformation. Considerable differences between the MS are still present resulting regions lagging behind in terms of digital transformation. The interviewed stakeholders agreed that a campaign such as WATIFY is needed and met market needs. Last, but not least, the SME policy actions providing strategic information as well as network opportunities for national policy-makers, fostering improved SME policy-making throughout Europe as well as an enhanced convergence. The scale and depth of support that COSME offers goes well beyond the support that can be offered to European SMEs through national or regional initiatives. 6.Conclusions and Lessons Learned ·What is working/what is not working, how it links to the intervention? COSME actions are highly relevant in addressing the challenges related to fostering economic growth and creating employment opportunities and is strongly aligned to the evolving needs of SMEs. COSME supports competitiveness and growth of all SMEs. The strength of the programme lies in its focus on enhancing the SMEs’ capacities for growth and in its attention to the SMEs’ needs for concrete information and knowledge that are of immediate and practical use in their business practices. The programme also addresses in a direct and concrete manner the need of young entrepreneurs to strengthen their entrepreneurship skills. However, this approach limits the possibility of specifically addressing other issues. Its two major actions, LGF and EEN, accounting for about 80% of the total budget committed, target all SMEs without making distinctions to reflect the programme’s ‘inclusive and sustainable growth’ and ‘global competitiveness’ policy objectives. The two major actions can therefore create only ‘unintended’ effects in those areas. As a result, the relevance of COSME for policy objectives such as gender mainstreaming or climate change is limited. The strength of the programme lies in particular in the use of intermediaries who have a direct and longstanding contact with SMEs for the implementation of the programme. COSME exploits the proximity of these intermediaries to SMEs and facilitates the integration of services provided by COSME with services provided by these intermediaries in their national and regional contexts. This allows for the provision of customised SME support tailored to the needs and challenges of specific sectors, such as tourism, textiles, creative industries etc. and to reach a high multiplier effect of actions. COSME has thus a good level of European added-value. The European dimension constitutes the very essence of the design of COSME actions. Moreover, COSME actions have helped to enhance national, regional and local level measures for SME support and the teaming up of actors across EU value chains to boost internationalisation and industrial modernisation. The feedback from beneficiaries is generally positive with a substantial majority reporting a good cost-benefit ratio for their participation. COSME is complementary to other EU policy instruments and programmes supporting business, without significant overlaps. It is the only EU programme designed to support SMEs' competitiveness and growth. Its ‘non-targeted’ offering addresses the basic needs of enterprises, facilitating access to finance, fostering cooperation and providing access to advice. It responds to existing needs, because a financing gap continues to exist in Europe, depending on the national context, and information asymmetries, specifically those related to market opportunities in the European Single Market and the global market, continue to require policy intervention for facilitating knowledge transfer and exchange as well as cross-border co-operation; The supporting study highlights several aspects to be improved: First, as stipulated by the COSME regulation, some 80% of the budget is used for promoting SMEs' access to finance and access to markets. The remaining 20% is allocated between a number of smaller actions with a limited budget and with a low cost-benefit ratio regarding the implementation. EASME (Executive Agency for SMEs) implements 35% of the overall programme budget, with two flagship COSME actions (Enterprise Europe Network and Erasmus for Young Entrepreneurs) as well as a host of smaller projects. The fragmentation of actions and limitations in terms of budget (as flagged out for the EYE and cluster measures) hampers the effective implementation . Second, while COSME is successful in fostering economic growth and the creation of employment opportunities, there is scope for strengthening its responsiveness to EU objectives related to EU global competitiveness and sustainable and inclusive growth. COSME's main instruments are designed to address all SMEs, independently of their sector and industrial specialisations. They only indirectly address challenges such as climate change, gender mainstreaming or youth unemployment. Third, while there are no major overlaps with other policy initiatives, there is scope for creating further synergies with other EU, national and regional actions. Fourth, in relation to monitoring the evaluation points out to a lack of centralised data about implementation and indicators are mostly based on outputs rather than on long-term effects. Some efforts are still needed to centralise the data that at present is dispersed between the coordinating of the programme, the units managing individual actions and the delegated entities. ·Lessons learned: While acknowledging – based on the available evidence – the strength of the COSME financial instruments to deliver a financial support to the SMEs that most needed it, several areas for improvement are identified:

·Better links between financial instruments and other parts of the future SME programme; ·Better co-ordination between financial instruments and national EU schemes; ·Discontinuation of the EUR 150 000 threshold which has a negative impact on the efficient delivery of the guarantee facility and created significant administrative burden. A future EU loan guarantee facility should help to ensure a more level playing field for SMEs in those countries where, according to current studies, the needs among SMEs are highest. The existing Equity Facility for Growth is considered to be effective. Nevertheless, it appears necessary to reduce the number of financial instruments and to align the Equity Facility for Growth with the equity facilities established under EFSI. The limitation of budget beyond the financial instruments and the EEN creates a high competition between the remaining actions. It represents 20% of the budget for a high number of actions. A fragmented budget reduces the potential impact of these actions and it creates a high competition in the published calls. There is still scope for simplification. Stakeholders report a good cost-benefit ratio for their participation in the programme but report that IT systems could be more user-friendly and there is administrative burden for participating in the programme actions. At the level of coherence, while actions are rather synergetic with other EU programmes or complement well national and regional instruments for SME support, there are still some overlaps. Finally, the lack of a centralised database for the implementation of the programme reduces the effectivity of monitoring and evaluation as well as the visibility of the programme. ·Does actual performance meet expectations? COSME in the period 2014-2016 produced positive results. The programme implementation is on track to reach the objectives set out