EUROPEAN COMMISSION Brussels, 7.10.2020 SWD(2020) 530 final COMMISSION STAFF WORKING DOCUMENT Analytical document accompanying the COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL A Union of Equality:

















EU Roma strategic framework for equality, inclusion and participation and its accompanying proposal for a revised Council recommendation on national Roma strategic frameworks for equality, inclusion and participation {COM(2020) 620 final} - {COM(2020) 621 final}



Table of contents glossary 1.Introduction 2.Political, legal and economic context 2.1.Political, legal and economic context 2.2.Aligning EU funds and policy 3.Problem definition 3.1.What are the problems? 3.2.What are the problem drivers? 4.Why should the EU act? 4.1.Legal basis 4.2.Subsidiarity: Necessity of EU action 4.3.Subsidiarity: Added value of EU action 5.Stakeholder Consultations 6.Objectives: What is to be achieved? 6.1.General objectives 6.2.Specific objectives 7.policy options and final policy choice

7.1.Policy options considered for this initiative 7.2.Description of the policy options and their key advantages and disadvantages 7.3.Additional considerations regarding the policy choice and retained option 8.other methodological information 8.1.Expected Impacts 8.2.Reflecting the lessons learnt from the COVID-19 pandemic and related needs of marginalised Roma communities in the post-2020 initiative 8.3.Targets and monitoring 9.Intervention Logic for ex-post evaluation Annex 1: Stakeholder Consultations Annex 2. Baselines for EU headline indicators Annex 3. EU mainstreaming and funding initiatives glossary Term or acronym Meaning or definition AI Amnesty International CCME Churches’ Commission for Migrants in Europe CEU Central European University CoE Council of Europe COMECE Commission of the Bishops’ Conferences of the European Community CPR Common Provisions Regulation CRR Centre for Reproductive Rights CSRs Country Specific Recommendations DG Directorate-General DG AGRI DG Agriculture DG CNECT DG Communications Network, Content and Technology DG COMM DG Communication DG EAC DG Education, Youth, Sport and Culture DG ECFIN DG Economic and Financial Affairs DG EMPL DG Employment, Social Affairs and Inclusion DG ENV DG Environment DG ESTAT DG European Statistics DG HOME DG Migration and Home Affairs DG HR DG Human Resources and Security DG JRC DG Joint Research Centre DG JUST DG Justice and Consumers DG MOVE DG Mobility and Transport DG NEAR DG Neighbourhood and Enlargement Negotiations DG REFORM DG for Structural Reform Support DG REGIO DG Regional and Urban Policy DG RTD DG Research and Innovation DG SANTE DG Health and Food Safety DG SG DG Secretariat General DG SJ DG Legal Service EAPN European Anti-Poverty Network EaSI Employment and Social Innovation Programme EEAS European External Action Service EC European Commission ECMI European Centre for Minority Issues EEB European Environmental Bureau EESC European Economic and Social Committee EFC European Foundation Centre EFTA European Free Trade Association ENAR European Network Against Racism ENS European Network on Statelessness EP European Parliament EPHA European Public Health Organisation EPSCO Employment, Social Policy, Health and Consumer Affairs Council EQUINET European Network of Equality Bodies ERDF European Regional Development Fund ERGO Network European Roma Grassroots Organisations Network ERIAC European Roma Institute for Arts and Culture ERIO European Roma Information Office ERRC European Roma Rights Centre ERTF European Roma and Travellers Forum ESF European Social Fund ESF+ European Social Fund Plus ESIF/ESI Funds European structural and investment funds ETUCE European Trade Union Committee for Education EU-MIDIS European Union Minorities and Discrimination Survey EURoma European network on social inclusion and Roma under structural funds FEANTSA European Federation of National Organisation working with the homeless fn Footnote FRA European Union Agency for Fundamental Rights FSG Fundación Secretariado Gitano Habitat Habitat for Humanity IPA Instrument for Pre-Accession Assistance ISG Inter-service Group (EC internal) ISSA International Step-by-Step Association IRU International Romani Union MFF Multiannual Financial Framework NEETs Not in employment, education or training NGO(s) Non-governmental organisation(s) NRCP(s) National Roma contact point(s) NRIS National Roma integration strategies and integrated sets of policy measures ODIHR OSCE Offices for Democratic Institutions and Human Rights OHCHR United Nations Human Rights Office of the High Commissioner OPC Open public consultation OPRE Operational Platform for Roma Equality OSCE Organisation for Security and Cooperation in Europe OSF Open Society European Policy Institute Phiren Amenca Phiren Amenca International Network RAA Roma Active Albania RED Racial Equality Directive REDI Roma Entrepreneurship Development Initiative REF Roma Education Fund ternYpe ternYpe International Roma Youth Network UNDP United Nations Development Programme UNICEF United Nations Children’s Fund UNSG United Nations Secretary-General WHO World Health Organization



1.Introduction This document accompanies the EU Roma strategic framework for equality, inclusion and participation 2021-2030 and the Commission proposal for a Council Recommendation on national Roma strategic frameworks for equality, inclusion and participation - as adopted by the Commission on 6 October 2020.

As set out in the roadmap for the initiative, no impact assessment was carried out. Instead, this document serves to explain the chosen policy approach, the consultation activities carried out and the intervention logic. The expected impacts strongly depend on the level of commitment to Roma equality and inclusion that Member States agree to in the Council recommendation and the national Roma strategic frameworks put in place thereafter. The initiative aims to raise commitment by proposing a portfolio of indicators with associated measures and targets for Member States to include in their national Roma strategic frameworks according to the specific situation of their Roma communities, as evidenced by data (wherever available). Nonetheless, an impact assessment cannot predict the level of ambition to which Member States are willing to commit. In addition, besides the general challenges of quantifying and monetising equality, non-discrimination and respect for fundamental rights, carrying out an impact assessment in the area of Roma equality and inclusion faces serious limitations in terms of ethnic data collection in the Member States. 2.Political, legal and economic context 2.1.Political, legal and economic context The ‘EU Framework for national Roma integration strategies up to 2020’ (‘the (EU) Framework’) – adopted by the Commission on 5 April 2011 is ending. Its main objectives were to tackle the socio-economic exclusion of Roma in the EU and enlargement countries by promoting their equal access to education, employment, health and housing. The Framework invited Member States to design national Roma integration strategies and set achievable national goals to meet four EU Roma integration goals: 1. Ensure that all Roma children complete, as a minimum, primary school education. 2. Cut the employment gap between Roma and the rest of the population. 3. Reduce the gap in health status between the Roma and the rest of the population. 4. Close the gap between the share of Roma with access to housing and to public utilities (such as water, electricity, and gas) and that of the rest of the population. For the enlargement region, the Framework included the Commission’s commitment to help the region to improve the inclusion of Roma under the Instrument for Pre-Accession (IPA), strengthen the involvement of civil society, and closely monitor progress in the framework of the enlargement process. In 2013, Member States adopted the Council Recommendation on effective Roma integration measures in the Member States, reinforcing the EU Framework and constituting the first EU soft law instrument explicitly targeting Roma. The Recommendation: ·provided guidance to Member States to make their measures for Roma integration more effective and strengthen implementation of their National Roma Integration Strategies (NRIS); ·recommended that Member States take effective policy measures to ensure equal treatment for Roma, including equal access to education, employment, healthcare and housing; indicated specific measures allowing for each of the four goals — ensuring equal access to education, employment, healthcare and housing — to be met; ·set out that these goals could be achieved either through mainstream or targeted measures, including specific ones to prevent or compensate for disadvantages, or by a combination of both, paying special attention to the gender dimension; ·reinforced the focus on anti-discrimination, referring explicitly to antigypsyism, and extended the work on Roma integration to new horizontal and structural areas beyond employment, education, health and housing; ·called on Member States to combat all forms of discrimination, including multiple discrimination, faced by Roma children and women, and fight violence, including domestic violence, against women and girls, trafficking in human beings, underage and forced marriages, and begging involving children, in particular through the enforcement of legislation; and ·called on Member States to communicate to the Commission on an annual basis, starting from 2016, the measures taken in line with the Recommendation and progress achieved in implementing the strategies. The Western Balkan partners endorsed the processes launched by the 2011 EU framework for National Roma Integration Strategies and, with the support of the European Commission and of the Regional Cooperation Council, took part in National Roma Integration Strategies, annual reporting on its implementation, Roma Country Seminars, National Platforms, Roma surveys, and established National Contact Points. In doing so, they have gone beyond their initial commitments and have demonstrated their capacity to align with requirements initially intended only for EU Member States. The Western Balkans partners, similarly to the EU Member States Semester process, present annual Economic Reform Programmes (ERP), including reforms to boost competitiveness and improve conditions for inclusive growth and job creation. ERPs report on social inclusion, poverty reduction and equal opportunities, including Roma.

Council Conclusions of 8 December 2016 asked the Commission ‘to carry out a mid-term evaluation of the EU framework for national Roma integration strategies up to 2020 and to propose a post 2020 strategy on Roma integration, and include therein a proposal for a revision of the Council Recommendation’. The Commission carried out the mid-term evaluation of the Framework, adopted in December 2018 a report on the evaluation and published the evaluation Staff Working Document . The table below summarises the main findings of the mid-term evaluation. Table 1: Summary of the findings of the mid-term evaluation with assessment by evaluation criterion Evaluation criterion Overall assessment Detailed assessment RELEVANCE Positive with limitations Four priority areas were and remain key Some shortcomings in initial design Positive for equity between Roma and non-Roma Negative for not targeting specific subgroups among Roma EFFECTIVENESS Limited regarding progress towards Roma integration goals Some progress towards the education goal No progress towards the employment goal Limited progress towards the health goal No progress towards the housing goal Positive regarding coordination Positive regarding EU-level governance Positive at EU and national level in promoting cooperation Limited alignment of NRIS and capacity of NRCPs despite some improvements COHERENCE & EFFICIENCY Positive at EU level Coherence between EU framework and several EU policy, funding and legal instruments (Europe 2020, ESIF, antidiscrimination legislation, enlargement) Variable mainstreaming into other policy instruments (insufficient, for example, under the European Pillar of Social Rights, Youth Guarantee) Limited at national level & Limited regarding reported and monitoring systems Insufficient mainstreaming into national public policies NRIS contributed to fighting discrimination, hate speech and hate crime in some MS, while their contribution was minor in others. National funding allocated to the extent required by co-financing of ESIF. Limitations in implementation and alignment of ESIF with Roma integration goals. Reporting developed gradually, focusing on measures rather than results. Weaknesses to be addressed. Comparable data for several, but not all Member States Civil monitoring by coordinated NGO coalitions piloted since 2017 Costs and benefits not conclusively evaluable, quantifiable and attributable. While costs are short- to mid-term, the majority of potential benefits are long-term. EU ADDED VALUE Positive Political Governance Financial Limited sustainability requires continued EU engagement Assessment categories: very positive / positive limited negative very negative unsorted The evaluation demonstrated that the Framework’s ambition of ‘putting an end to the exclusion of Roma’ had not been achieved. The Commission’s evaluation report concluded, inter alia, ‘the evaluation has shown that the EU Framework is the beginning of a process that, despite many limitations and taking into account the massive task involved, has shown positive results and an initial change in trends’. This clearly showed its EU added value, in particular by placing Roma inclusion high on EU and national agendas and mobilising EU policy, legal and funding instruments. Without it, Roma inclusion would have received lower political commitment, less financial support and attention at national levels. It also underlined that ‘while the initial phase has achieved some tangible, albeit insufficient results, the evaluation submits that the overall process be strengthened and become better focused, with an emphasis on improved political commitment, the introduction of specific measurable targets and rigorous monitoring, and more effective implementation supported by sufficient funding and participatory governance systems’. Since the finalisation of the evaluation, the Council, the European Parliament (EP) and EU-level and national civil society organisations have all called on the Commission to propose a strengthened EU Roma policy initiative for post-2020. In February 2019, the European Parliament adopted a Resolution on ‘the need for a strengthened post-2020 Strategic EU framework for National Roma Inclusion Strategies and stepping up the fight against anti-Gypsyism’. The Resolution calls on the Commission ‘to act on the calls made by Parliament, the Council and numerous NGOs and experts and propose a Strategic EU Framework on National Roma Inclusion Strategies for the post-2020 period (…)’. In September 2019, to enable better and informed policy making, the Commission adopted the 2019 report on the implementation of the National Roma Integration Strategies, focusing on lessons learnt from the implementation of Roma inclusion measures and national strategies . In October 2019, EPSCO adopted Council Conclusions on the Economy of Wellbeing inviting the Commission to ‘RENEW the commitment on Roma inclusion by developing new policy initiatives, including the adoption of a post-2020 European Framework Strategy’. Detailed information about the contributions from EU-level, national and local civil society organisations is included in Annex 1 summarising stakeholder consultations. Reacting to these calls in January 2020, the Commission included a new initiative on Roma equality and inclusion in the ‘Strong Social Europe for Just Transitions’ Communication and its Work Programme for 2020 and published a roadmap. The adjusted Work Programme for 2020 reconfirmed this initiative. Additionally beneficial for the new initiative is also the context created by the European Green Deal . With its potential to reshape profoundly Europe’s political landscape, governance and economy, it requires environmental, climate and social transitions, guided by the goal of reducing inequalities. The COVID-19 pandemic demonstrated the extreme exposure of excluded and marginalised Roma communities to both short-term negative health and fundamental right impacts and mid-term socio-economic impacts, and the urgent need for a more efficient and comprehensive policy response with guidance from the European level. The use of restrictive measures in the legitimate aim of protecting public health in some Member States reinforced discrimination and violence against marginalised Roma. The spread of fake news, the improper narratives of political figures and ethnicisation of the issue in the media, portraying Roma living in settlements or ghettoes as a public threat or their use as scapegoats accentuated fear and hate against the Roma. When it comes to the EU legal framework, the Racial Equality Directive prohibits discrimination including harassment based on racial or ethnic origin . The Charter of fundamental rights of the EU prohibits discrimination on any grounds including on race and ethnic origin and ensures the protection of the rights of the child . In addition, the Council Framework Decision 2008/913/JHA obliges Member States to criminalise hate speech and hate crime, including against Roma , while Directive 2012/29/EU establishes minimum standards on the rights, support and protection of victims of crime , paying particular attention to victims who have suffered from biased or discrimination-motivated crimes. The Audio-visual Media Services Directive calls upon the Member States to ensure that audio-visual media services do not contain incitement to violence or hatred directed against a group of persons or a member of a group based on any of the grounds referred to in Article 21 of the EU Charter, which include race and ethnic origin . 2.2.Aligning EU funds and policy The EU’s main instrument of investment in people and implementation of the European Pillar of Social Rights, the European Social Fund Plus (ESF+) shall support, complement and add value to Members States’ policies to ensure equal opportunities, access to the labour market, fair working conditions, social protection and inclusion. In particular, Principle 1 on quality and inclusive education, Principle 3 on equal opportunities, Principle 4 on active support to employment, Principle 19 on access to adequate housing, and Principle 20 on access to essential services should serve as a basis for programming both mainstream and targeted measures. Support for Roma communities should come under all specific objectives, with the ultimate goal of inclusion of Roma into mainstream education, the mainstream labour market, mainstream healthcare, mainstream housing and essential services and mainstream society in general. Exclusion of Roma from the specific objectives would constitute discrimination on the ground of ethnic origin, forbidden by the Council Directive 2000/43/EC. The principle of explicit but not exclusive targeting requires guarantees that the interventions reach Roma but also other marginalised communities. The aim of targeted programmes is to provide additional support to promote effective equal access for Roma and other marginalised communities facing similar disadvantages to rights and mainstream services. The gravity of the individual challenges in each policy area and the interdependence of the problems calls for a multi-dimensional integrated approach, combining investments in employment, education, healthcare and housing. Within these policy areas, ESF investments must be coherent with other EU funds and programmes, including ERDF, EAFRD, InvestEU, EaSI and the new Recovery and Resilience Facility. Therefore, Roma inclusion should be addressed through multiple specific objectives by different funds in an integrated manner. Likewise, outcomes-based funding from the relevant facilities and any of the available resources could promote and support comprehensive and multi-focal interventions. The latter have a preventative scope, seeking to intervene at the root cause level, involve local communities in the co-design and co-production of projects, promote transparency and accountability for results achieved, as well as innovation and collaboration of involved stakeholders. In the case of marginalised groups including Roma, there is a clear need of reinforced administrative capacity at the local level, including capacity and capability building for local authorities and grassroots civil society organisations. This point is crucial for effective participative planning, ownership, efficient and transparent management and sustainable implementation. 2.2.1.The 2014-2020 programming period The European Structural and Investment Funds (ESI Funds) contributed to the implementation of the EU Framework for National Roma Integration Strategies (NRIS) up to 2020. To increase the effectiveness of the funds, the Cohesion Policy regulatory framework included ex-ante conditionalities. Under the social inclusion objective, one of the conditionalities required the existence of a national Roma integration strategy. Generally, tangible and visible Roma inclusion measures receive support by ESI Funds in the 2014-2020 period responding to the challenges identified. The complex needs of Roma communities accounted for the promotion of an integrated approach, coordinating different measures supported by several funding streams, such as the European Social Fund (ESF), the European Regional Development Fund (ERDF), the European Agricultural Funds for Rural Development (EAFRD) and others.

The ESF played a significant role in supporting the implementation of National Roma Integration Strategies during the 2014-2020 programming period. The negotiations of this period’s operational programmes paid particular attention to putting in place the right policy framework for Roma integration as well as securing the clear correspondence between the Country Specific Recommendations on Roma integration and ESF programming. The assessment of modifications to ESF operational programmes has also considered this. The 2014-2020 specific investment priority on Roma integration has allowed 10 Member States, including those with a Country Specific Recommendation on Roma, to program more than €1.5 billion for the integration of marginalised communities, including Roma. In addition, the other ESF investment priorities on social inclusion as well as the other thematic objectives on employment and education can also be mobilised in favour of Roma. By the end of 2019, the ESF has supported 3.9 million participants who were migrants, of a foreign background or part of a marginalised community, such as the Roma. However, implementation on the ground is lagging behind, with big gaps between available allocations to these investment priorities and selected operations. Concerning evaluation, an overarching issue highlighted by a recent study is the lack of robust evidence on the impact of interventions. A rigorous implementation of a results-focused approach might improve investments on Roma inclusion. The ERDF financed several important Roma integration areas, such as access to inclusive (non-segregated) early childhood education and care, primary education, infrastructure developments in health and social services, support to regeneration of deprived urban and rural areas, and non-segregated housing actions. Overall, €21.5 billion ERDF has been allocated to measures mentioned above, which fall under the growth objective in the 2014-2020 period. The EAFRD has supported the basic services development in rural areas and local bottom up initiatives under LEADER. In this sense, 14 billion euros EARD has been allocated to those measures under the programming period 2014-2020 under the Common Agricultural Policy. Tackling segregation in housing and education is a complex and critical issue, challenging for both ERDF and ESF measures. Taking into account these challenges, the Roma policy objectives and the EU anti-discrimination law provisions, the Commission prepared a guidance for Member States on the use of EU Funds in tackling educational and spatial segregation. Its aim is to help in designing calls to support building inclusive education and housing measures for Roma, and in response to the infringement procedures launched against Czechia, Hungary, and Slovakia. Member States (Czechia, Hungary, Romania) receive support on the implementation of the guidance note from contracted experts. Additionally, the 2014-2020 programming period saw a reinforcement of both the urban and territorial dimensions of the Cohesion Policy. Accordingly, several Member States prioritised addressing the needs of people living in disadvantaged micro-regions or segregated neighbourhoods. Hungary and Slovakia launched comprehensive programs for Roma. They targeted Roma communities by using territorial indicators (e.g. most deprived micro-regions, localities with high density of Roma people) and introduced complex measures. Romania used a newly introduced tool, i.e. the community-led local development, for Roma integration measures. The IPA II programme played a significant role in supporting the implementation of national Roma integration policies in the Western Balkans and Turkey during the 2014-2020 period. The amount of funds has significantly increased compared to IPA I, especially concerning regional projects. IPA financed a broad number of important Roma integration areas. Especially important has been the assistance in the fields of education, housing, local level and support to CSO. 2.2.2.The 2021-2027 programming period The new Recovery and Resilience Facility will support investments and reforms essential to a lasting recovery and foster economic and social resilience and social cohesion. In order to receive support, Member States will have to draw up recovery and resilience plans addressing the economic and social impacts of the crisis; the digital and green transitions and the relevant priorities identified in Country Specific Recommendations under the European Semester. Support will be provided in several policy areas (including those covered by the sectoral objectives in this framework) and will take account of the effective inclusion of disadvantaged groups, including Roma. In the Commission proposals for the 2021-2027 Common Provisions Regulation (“CPR”) and ESF+ Regulation, Article 6(1) of the ESF+ proposal ensures that all programmes shall promote equal opportunities for all, without discrimination based on sex, racial or ethnic origin, religion or belief, disability, age or sexual orientation throughout their preparation, implementation, monitoring and evaluation. Paragraph (2) of the same article calls on Member States and the Commission to support specific targeted actions to promote equality and non-discrimination. Specific objective (viiia) under Article 4(1) ESF+ refers to promoting the socio-economic integration of marginalised communities, such as the Roma. This specific objective is linked to the thematic enabling condition 4.3.2 of a National Roma Integration Strategy (Annex IV CPR), whose criteria have been identified based on the findings of the 2018 evaluation of the EU Framework and the 2019 report on implementation at national level. The criteria to be met relate to: a) the need to prevent and eliminate segregation; b) reflecting diversity among Roma (gender dimension, situation of Roma youth); c) arrangements for monitoring, evaluation and review of Roma inclusion measures, including setting a baseline, and measurable targets; d) arrangements for mainstreaming at regional and local level; and e) arrangements to ensure that design, implementation, monitoring and review is in cooperation with Roma civil society and other stakeholders. Member States programming under specific objective (viiia) will have to ensure compliance with the thematic enabling condition on Roma. Specific objective (viiia) will also count towards the obligatory thematic concentration for all Member States related to social inclusion, as stated in Article 7(3) ESF+ proposal: ‘Member States shall allocate at least 25% of their ESF+ resources under shared management to the specific objectives for the social inclusion policy area set out in points (vii) to (xi) of Article 4(1), including the promotion of the socio-economic integration of third country nationals’. Moreover, to enhance the link with the European Semester, Article 7(2) ESF+ proposal includes an obligation that ‘Member States shall allocate an appropriate amount of their ESF+ resources under shared management to address challenges identified in relevant country-specific recommendations adopted in accordance with Article 121(2) TFEU and Article 148(4) TFEU and in the European Semester falling within the scope of the ESF+ as set out in Article 4’. Therefore, Member States with challenges in the field of Roma inclusion within their Annex D and Country Specific Recommendations should thoroughly address these through the ESF+. Concerning partnership, Article 8(1) of the ESF+ Regulation calls on Member States to ensure adequate participation of social partners and civil society organisations in the delivery of employment, education and social inclusion policies supported by the ESF+ strand under shared management. Furthermore, according to Article 8(2), an appropriate amount of ESF+ resources under shared management must be allocated in each programme for the capacity building of social partners and civil society organisations. Therefore, support for the capacity building of civil society organisations, including those representing Roma communities, remains a priority. The Code of conduct on partnership remains in force for the preparation of the post-2020 programmes and throughout all the stages of implementation. The 2021-2027 Instrument for Pre-Accession Assistance will continue to support reforms and alignment with EU requirements at regional and national levels by the enlargement countries. Additional relevant EU funds, such as the Neighbourhood, Development and International Cooperation Instrument, may also be mobilised in the programming period 2021-2027 to support socio-economic inclusion, equality and participation of Roma in the neighbourhood region. Lastly, according to the draft CAP Strategic Plan regulation, the CAP specific objective 8 will be dedicated to “promote employment, growth, social inclusion and local development in rural areas, including bio-economy and sustainable forestry’. 3.Problem definition

3.1.What are the problems? Despite the existence of policy, legal and funding frameworks at national and EU level, the marginalisation of Roma persists and many of the estimated 10-12 million Roma in Europe continue to face inequalities, socio-economic exclusion, antigypsyism and discrimination in their daily lives. There is a risk that the mid- to long-term effects of the COVID-19 pandemic, including adverse socio-economic impacts, hit the most rights-deprived and marginalised Roma communities the hardest, contributing to further inequalities and discrimination. Reducing inequalities and preventing their possible further increase because of the crisis, overcoming exclusion and discrimination, and achieving inclusive prosperity and equity require long-term commitments. Structural changes need time and real impact, such as impact resulting from the better education of Roma children, which may not become visible for at least another generation. Too many Roma face extreme poverty, unemployment, sub-standard education in segregated schools and classes, inadequate housing, poor health and wellbeing. Social exclusion reinforces resentment against Roma, making their marginalisation socially acceptable and bolstering antigypsyism. Roma women, in particular, continue to fare worse than Roma men and women in the general population in key areas such as health, education and employment . Many Roma also face specific geographical vulnerabilities linked to rural remoteness. The Roma integration indicators scoreboard (2011-2016) presents changes in the situation of Roma in nine EU Member States as recorded by two surveys of the Fundamental Rights Agency (FRA) carried out in 2011 and in 2016. It uses 18 indicators in four main thematic areas (education, housing, employment and health) and the crosscutting area of poverty. For the Western Balkans, surveys carried out in 2011 and 2017 followed the FRA methodology. In addition, new survey data for five Member States with a lower share of Roma communities confirmed the overall trends in socio-demographic situation and experiences of discrimination identified in the surveys covering Member States with larger Roma population. Overall, progress in Roma integration has been limited since the Framework’s adoption in 2011, albeit with significant differences across policy areas and countries. While there has been some progress in education and health, the employment and housing conditions recorded no progress. In education, the progress achieved between 2011 and 2016 related to improvements in early school-leaving, early childhood education and compulsory schooling. However, the situation with respect to segregation has further deteriorated and, based on the Racial Equality Directive, the Commission has initiated infringement procedures over the school segregation of Roma children against three countries. Roma poverty risk and self-perceived health status has improved between 2011 and 2016, but medical coverage continues to be limited. Access to employment did not improve in any statistically significant way and the share of young Roma not in employment, education or training has even increased. The housing situation remains difficult. Roma women and children continue to be victims of violence, including trafficking in human beings. In Western Balkans, the regional Roma survey data of 2011 and 2017 show that little progress toward Roma inclusion was achieved in the five priority areas identified by the Commission: education, employment, health, housing and essential services, and documentation. Notably, data show a substantial deterioration in labour force participation and employment across Western Balkans, with a consequent lack of progress in narrowing the gaps relative to non-Roma neighbours. Discrimination and antigypsyism continue to contribute to severe disadvantages in all spheres of life, despite evidence of a reduction in Roma’s discrimination experiences when accessing some service areas. Roma keep facing deep-rooted negative public perceptions and prejudice. In October 2019, the Commission released the most recent Eurobarometer survey results on the perception of Roma in the general population, following up Eurobarometer surveys in 2012 and 2015. The results reveal that acceptance of Roma in different spheres of life has improved. Sixty-four percent of Europeans (10 percentage points more than four years before) would feel comfortable working with a Roma colleague and 48% (nine percentage points more than four years before) would welcome Roma as the partner of their children. There are however significant differences between the Member States. At the same time, 61% of the respondents feel that discrimination against Roma is widespread in their country, with this ground considered as more widespread than any other is. Only 19% (albeit seven percentage points more than in 2012) of the respondents think their country's efforts to integrate its Roma population are effective. Data from the 2019 Balkan Barometer issued by the Regional Cooperation Council reveal that although there is an overall minor, but positive trend since 2017 towards the inclusion of Roma into Western Balkan societies, Roma in the Western Balkans remain victims of negative socio-economic biases and continue to profit from fewer affirmative actions than other minorities in the societies. Approximately 75% of the Western Balkans populations respond positively towards working or doing business with Roma while 20% would feel comfortable welcoming Roma as a partner or a partner of their children. However, about 66% express a feeling of discomfort when faced with this latter scenario. Furthermore, the unprecedented COVID-19 outbreak came to widen the longstanding exclusion, poverty and discrimination against Roma. In response to the crisis, some Member States and the enlargement countries put in place both mainstream and targeted emergency and preventive measures to protect their population, including marginalised Roma communities. However, several emergency measures, such as hand washing with warm water, proved a challenge for the 30% of Roma living in households with no tap water. Compliance with personal hygiene recommendations was also questionable, as 40% of Roma lack sanitary facilities in their dwellings. In some Member States, up to 80% of Roma live in cramped, overcrowded neighbourhoods, which made physical distancing, a key element of preventive public health measures, next to impossible. In remote rural territories, Roma face even more disadvantages: isolation, high concentration of poor people and lack of population diversity, absence of alternative solutions in case of unavailability of basic public services, high risk of exploitation and abuses. The lack of economic activity locally, the limits in municipality’s own margin of manoeuvre (including means, political will or competences), and insufficient public transport prevents the population from benefitting from job and education opportunities in neighbouring urban centres. Additionally, the mid-term socio-economic impacts of the pandemic risk engendering further inequalities for the Roma. For instance, remote learning through digital education is most often not accessible and/or affordable for marginalised Roma children, lacking adequate or any IT equipment, and/or internet connection or sometimes, even electricity. Absent effective targeted support measures, inequalities in education risk further deepening. In addition, due to the containment measures, Roma women’s disproportionate exposure to domestic violence and abuse heightened their vulnerability during the health crisis. Many Roma living in segregated settlements found themselves cut from any source of income and formal or informal economic activity, leading to rising unemployment and poverty. The COVID-19 outbreak halted most business activities, which led to income and job losses. For the Roma working in Western European Member States in the highly insecure non-formal sector (seasonal jobs, unregulated contracts) and generally lacking financial buffers (i.e. savings), the consequences were dire. The loss of jobs pushed waves of Roma to return to their (predominantly Eastern European) home countries. Against a background of ineffective access to social protection, many Roma EU mobile workers saw themselves deprived of any social or unemployment benefits. Moreover, on top of the current experiences of discrimination across the EU, once returned at home, they faced new instances of discrimination, which translated into heightened insecurity, online and offline hate comments, and scapegoating. Overall, the difficulties Roma in Europe face can be summarised as follows: Rights oPersisting inequality and discrimination (including stereotypes, hate speech, scapegoating of Roma, lack of recognition by the majority population of such instances of discrimination) Equitable (re)distribution oInsufficient Roma participation in quality mainstream (including distant) education oInsufficient Roma participation in paid, quality and sustainable (self-) employment, with high rates of Roma working in the informal sector

oInsufficient Roma access to adequate desegregated housing and essential services oPoor Roma health and insufficient Roma access to quality health and preventive services oInter-generational transmission of poverty and material deprivation among Roma oInsufficient access to financial services Representation oLack of participation of Roma in policy- and decision-making (including political representation), lack of civic engagement and electoral participation 3.2.What are the problem drivers? Roma exclusion and inequality has existed for centuries, with problem drivers often interrelated, varying according to specific country situations, depending on external factors and needing comprehensive approaches. Problem drivers and hence the need for public intervention relate to behavioural biases, equity (of endowments, process and outcomes). They are also connected to governance/regulatory problems and the inter-generational transmission of poverty. More specifically, the problem drivers can be grouped as follows: Related to behavioural biases ·Antigypsyism, stereotypes and prejudice among the general public. These can be due to a number of co-existing factors, such as the portrayal of Roma in education, political narratives and media, coupled with a general lack of knowledge and awareness (of the mutual benefits of Roma equality and inclusion and the challenges of exclusion and discrimination, including general ignorance about slavery, deprivation of rights, persecution and Holocaust). Rising populism in Europe (further exacerbated in times of crises, like during the COVID-19 pandemic, which saw an ethnicisation of the issue in the media) also plays an important role ·As a result of such narratives and attitudes, lack of trust among Roma towards mainstream institutions and non-Roma, but also lack of rights awareness and underreporting of discrimination and hate crime ·Stereotypes and prejudice within Roma communities (as well as traditional expectations towards Roma women) Related to lack of equity as driver ·Territorial inequalities related to lacking basic infrastructures and basic services in some rural areas affecting also, but not only, Roma population ·Specific obstacles to equal participation in education, such as misdiagnosis and misplacement of Roma children in special education or other forms of school and class segregation, including unequal or no access to online and/or distance learning ·Specific obstacles to equal participation in vocational training and employment, such as ineffective outreach of employment services, discrimination by employers, overrepresentation of Roma in parallel systems (such as public work schemes not leading to the formal labour market) or concentration of Roma in socio-economically disadvantaged regions ·Specific obstacles to equal access to social protection services due to the high participation of Roma in informal labour markets and limited access to decent jobs ·Specific obstacles to Roma access to healthcare services, such as lack of medical insurance, lack of identity documents, discrimination by health professionals, segregation in healthcare facilities, health impacts of living in segregated areas, overcrowded housing (as proven by experience with barriers to preventive measures related to the COVID-19 pandemic), suffering from environmental hazards ·Specific obstacles to Roma access to adequate housing and basic infrastructure (water supply, sewage, road access, etc.), spatial segregation with regard to the location of housing, discrimination by landlords and public authorities, but also poverty leading to reduced financial means for repair works, renovation, payment of bills

·Specific obstacles to Roma access to financial services, with few financial institutions trusting Roma and thus precluding support needed through, e.g. microfinance ·High share of Roma children living in low work-intensity households Related to governance ·Political commitment to Roma equality and inclusion at national level depends on political will of changing governments ·Lack of national quantitative and/or qualitative goals against which to monitor, measure and evaluate ·Public interventions failing to achieve objectives/poorly implemented/enforced/out of date/lacking relevance (for example, by not addressing the needs of EU mobile and migrant Roma and diversity overall as rendered obvious during the COVID-19 crisis) ·Lack of capacity of local, regional, national authorities to ensure outreach to disadvantaged/Roma, effective safeguards and inclusive public services, lack of capacity and ability to structure and implement projects ·Lack of good practices and working models for inclusion, which in turn contributes to the lack of political will and imagination and lower levels of investment ·Lack of rights awareness and civic duties among Roma, as well as lack of mutual reciprocity in obligations ·Insufficient evidence to monitor the approach of law enforcement when Roma are affected as victims (e.g. forced labour, trafficking in human beings, usury, child rights, domestic violence) ·Lack of Roma empowerment, lack of cooperation and trust among Roma and non-Roma, and among stakeholders of Roma inclusion Related to inter-generational transmission of poverty ·Roma families trapped in a cycle of poverty often have either limited or no resources, no buffers to rely on in times of crises, no means to get out of poverty and provide themselves and their children with a better future. Low income and lack of basic financial literacy lead to barriers such as the impossibility to cover even bare necessities in times of crises, let alone pay for early education and care, schooling and school material, transportation, housing and utilities such as water and electricity, and access to finance and microfinance institutions to create or support micro or small businesses ·Lower ‘mental bandwidth’ associated with living in scarcity, which also impedes long-term planning ability and hampers resilience The chart below summarises the problem drivers and problems this initiative addresses. Chart 1: Problem drivers and problems Problem drivers Behavioural bias: Antigypsyism, discrimination, stereotypes and prejudice in the majority population. Stereotypes and prejudice in Roma communities. Governance: changing political will and commitment; lack of Roma empowerment, trust and cooperation; failing public interventions etc. Inter-generational transmission of poverty Equity: Specific obstacles to equal participation in education and employment as well as to equal access to health and housing. Problems Lack of Roma participation in policy and decision-making Poor Roma health and insufficient access to healthcare Insufficient Roma access to housing and essential services Insufficient Roma participation in quality mainstream education Persisting inequality and discrimination of Roma Poverty among Roma Insufficient Roma participation in paid employment; loss of human capital Dfs Sdf Fds 4.Why should the EU act?

4.1.Legal basis Articles 2 and 3(3) TEU, Articles 10 and 19(1) TFEU; Article 21(1) of the Charter of Fundamental Rights. 4.2.Subsidiarity: Necessity of EU action Underlying shared values, such as equality and fundamental rights, and common objectives, such as economic prosperity, social cohesion and solidarity between Member States, call for a European role in Roma equality and inclusion policies. In addition, transnational mobility of Roma across EU Member States, in the context of freedom of movement and of the migration of Roma from third countries, makes Roma inclusion a joint EU-level objective. The COVID-19 pandemic demonstrated the extreme exposure of excluded and marginalised Roma communities to both short-term negative health impacts and medium term socio-economic impacts. Many Roma communities suffered disproportionately because of their overall limited access to basic hygiene and sanitary infrastructure, limited access to clean water and healthcare services, high levels of economic precariousness, overcrowded households and segregated, overcrowded settlements or camps. There is also a clear risk that, because of the mid-term socio-economic impacts of the pandemic, inequalities will further increase. Distance and digital education, for instance, is often not accessible and/or affordable for marginalised Roma children, thus aggravating inequalities in education. The lockdown cut many Roma living in segregated settlements from any source of income and (formal or informal) economic activity, leading to rising poverty. Europe needs to ensure that the most disadvantaged do not disproportionately carry the burden of the pandemic and inequalities widen. Stopping targeted EU action on Roma inclusion is likely to reduce political commitment and focus on Roma inclusion in both the EU Member States and enlargement countries, and lead to a sharp decrease in available funding. Stopping EU action is also likely to result in less and looser monitoring of the situation of Roma. At present, the effects of the EU Framework are unlikely to last after 2020 if there is no further EU guidance, monitoring and support. Most of the current national policies and structures created around the NRIS (NRCPs, systems of coordination, monitoring and reporting, systems of consultation with civil society and Roma organisations) would stop or would be less functional and become more symbolic, if the EU Framework did not continue after 2020. There is need for increased efforts at national level as well as more time to consolidate working structures, to align and mobilise further other policy, legal and financial instruments and to monitor better the impact of policies to feed policy learning and review. This view was also supported by a majority of the respondents to the public consultation (almost 60%), who believe that the EU still has a major role to play in supporting national, regional and local authorities as they cannot effectively improve the situation of Roma on their own. It is important, however, to take into consideration that while all countries face challenges with guaranteeing inclusion and equality for Roma population, the scale and relevance of the challenges is different in two dimensions: ·Intensity: Intensity refers to the size and share (percentage) of the Roma population, but also to the extent to which they suffer a legacy of exclusion and discrimination. Roma exclusion tends to be more intense in economically less developed countries with a higher level of poverty among the general population. ·Specificity: There are specific problem drivers and specific issues that especially apply to some countries, but not to all (intra-EU mobility, migration, spatial segregation, problems with civil documents, etc.). Chart 2: Intensity and specificity In terms of policy responses, following the adoption of the EU Framework in 2011, Member States either adopted a specific strategy for Roma integration or are using a “set of measures” inscribing the topic into mainstream policies. The preferred courses of action differ also in terms of balance between the use of mainstream and targeted measures for Roma inclusion, allocation of specific funding, setting of baselines, use of national goals and related indicators as well as mandate and structure of the National Roma Contact Points. 4.3.Subsidiarity: Added value of EU action The evaluation of the Framework clearly demonstrated the added value of EU action and the need for continuation. In particular, EU action so far has: (i) put Roma inclusion on the political EU and national agendas; (ii) raised attention to Roma issues in countries with smaller Roma populations; (iii) strengthened existing structures for Roma integration and contributed to the creation of new ones; (iv) ensured stability through its multiannual character; (v) provided policy guidance, monitoring and reporting frameworks supporting greater accountability and transparency; (vi) provided opportunities for mutual exchange and cooperation; (vii) enabled — through its comprehensive approach — Roma inclusion to be addressed from various policy perspectives as well as collaboration between different political and governmental levels; and viii) ensured that European Structural Investment Funds (ESIF) support implementation of the NRIS. While highlighting this clear EU added value, the evaluation also identified weaknesses, pointing to specific reform priorities that should guide a reinforced and revised strategic framework. ‘The evaluation finds that without the EU Framework, Roma issues would receive less attention in the EU policy agenda. In some countries, NRIS may cease to exist; in others, they may become weak, further reducing political commitment to Roma inclusion. The ending of the Framework would result in less and looser monitoring and reporting. Some current national policies and targeted structures would stop or turn less functional and more symbolic’. With regard to the enlargement region, the evaluation concluded that the objectives of the Framework have equally been promoted in the enlargement countries and finds that enlargement countries should be guided by a future EU Framework; this would allow for the use of further guidance and conditionalities during the accession process.

5.Stakeholder Consultations Activities carried out to consult stakeholders for the preparation of the initiative and its results are summarised in Annex 1. 6.Objectives: What is to be achieved? Taking into account all of the above, the Commission identified the following general and specific EU-level objectives in the area of Roma equality, inclusion and participation for the EU strategic framework 2021-2030. 6.1.General objectives To contribute to promoting equality and combatting exclusion of Roma with their active involvement. 6.2.Specific objectives In order to reach the general objectives, the initiative puts forward seven mutually reinforcing specific objectives. These include three horizontal objectives, linked to the three main political priorities (general objectives) of the EU Roma strategic framework for equality, inclusion and participation: ·Equality: Fight and prevent antigypsyism and discrimination ·Inclusion: Reduce poverty and exclusion and close the socio-economic gap between Roma and the general population ·Participation: Promote participation by empowerment, cooperation and trust Four sectoral objectives underline the continued relevance of the four policy areas of the framework. With regard to education, employment, healthcare, housing, as well as essential services, all three horizontal goals (ensuring substantive equality, socio-economic inclusion and participation of Roma) are relevant: ·Increase effective access to quality inclusive mainstream education ·Increase effective access to quality and sustainable employment ·Improve Roma health and increase effective access to quality healthcare and social services ·Increase effective access to adequate desegregated housing and essential services Table 2: Hierarchy of policy objectives General Specific Contribute to promoting equality ·Fight and prevent antigypsyism and discrimination of Roma ·Promote participation by empowerment, cooperation and trust Contribute to combating exclusion of Roma ·Increase effective access to quality inclusive mainstream education ·Increase effective access to quality and sustainable employment ·Improve Roma health and increase effective access to quality healthcare and social services ·Increase effective access to adequate desegregated housing and essential services ·Reduce poverty and exclusion to close the socio-economic gap between Roma and non-Roma

7.policy options and final policy choice 7.1.Policy options considered for this initiative The baseline scenario considered was that the EU Framework ended in 2020 and the Commission adopted an identical Framework providing for a continuation of the current policy approach for the time after. This option was purely hypothetical, as the adoption of an identical EU Framework would ignore the learnings from the evaluation. It would have implied, inter alia, not addressing key findings such as the need for a reinforced approach regarding discrimination and antigypsyism and the importance of addressing the diversity within the Roma population. The following policy options were considered in more detail: ·No new EU level initiative (‘do less’) ·Option focusing on ‘doing differently’ - Antigypsyism ·Option focusing on ‘doing differently’ - Anti-poverty ·Option presenting a reinforced comprehensive policy approach to Roma equality inclusion and participation building on the current EU Framework and the evaluation findings (‘do better’) ·Option to renew and strengthen Member States’ commitment to Roma equality, inclusion and participation building on the 2013 Council Recommendation (‘do more’) ·A combined option (‘do more and better’) 7.2.Description of the policy options and their key advantages and disadvantages The first step was the examination of the coherence between the thematic focus of each option with the specific objectives of the initiative. The table below summarises coherence between policy content of the policy options considered and the specific objectives in a simplified manner (√ = coherent; √√ = very coherent; - = not coherent). The table considers coherence and not potential effectiveness. Only options 5, 6 and 7 had the potential to be strongly coherent with all seven specific objectives set out for this initiative. Table 3: Potential coherence between areas covered by options and specific objectives OPTIONS Specific objectives addressed HORIZONTAL SECTORAL antigypsyism and discrimination poverty participation education employment health housing 1. No new EU Roma initiative - - - - - - - 2. Continuation of EUFW for NRIS as it is – baseline - √ √ √√ √√ √√ √√ 3. Single focus on antigypsyism √√ - √√ - - - - 4. Single focus on poverty - √√ - √ √ √ √ 5. Reinforced comprehensive policy approach √√ √√ √√ √√ √√ √√ √√ 6. Stepped up political commitment of MS √√ √√ √√ √√ √√ √√ √√ 7.Combined option √√ √√ √√ √√ √√ √√ √√ The second step was the detailed consideration of each potential option.

7.2.1.No new EU level initiative (‘do less’) The EU Framework ends in 2020 and the Commission could have decided not to replace it. Other key instruments would have remain in place, such as the Race Equality Directive, the Charter of Fundamental Rights, the Framework Decision on combating racism and xenophobia, and the 2013 Council Recommendation on effective Roma integration in the Member States. In addition, there would also have been the relevant general EU policies (such as the European Semester, anti-trafficking measures, etc.) and EU programmes, such as the European Structural and Investment Funds (ESIF) and/or their successors, including relevant specific objectives and enabling conditions but also instruments of international organisations such as the Council of Europe’s thematic action plan for 2021-2025. Without a new initiative at EU level, however, there would have been a risk of disconnection between general EU policies and programmes, on the one hand, and efforts in the area of Roma equality, inclusion and participation, on the other. That would have also led to inconsistency between the ESF+ enabling condition for the specific objective on integration of marginalised communities requiring the existence of a national Roma inclusion strategic policy framework and the non-existence of a corresponding EU Framework in that area. In addition, the 2013 Council Recommendation might have become less effective, if not revised in order to accommodate for policy learning. Some of its elements (such as Commission monitoring based on Member States’ reports) would have become dysfunctional or stopped working in the absence of an EU instrument. At national level, National Roma Integration Strategies (NRIS) or integrated sets of policy measures within their broader social inclusion policies currently exist in all Member States (except Malta) and the enlargement countries. However, many of them expire in 2020 as their lifespan followed that of the EU Framework. National Roma-specific or general laws, policies and funding programmes relevant for Roma inclusion are in place but risked discontinuation. The evaluation confirmed that an EU-level initiative was key for political commitment at national level. Giving continuity to the processes triggered by the 2011 EU Framework is in itself a value, as much of the policies and instruments have resulted in structures, practices and monitoring cycles that have incrementally improved over the years. One could mention, for example, the reporting tool for Member States or the coordinated civil monitoring at EU level feeding the Commission’s monitoring, guidance and support activities or the respective consultation processes and participation structures at national and EU levels. Changing the policy direction and scaling down existing structures and practices would have disrupted this incremental process. 7.2.2.Option focusing on ‘doing differently’: tackling antigypsyism Instead of a new EU Framework, the Commission could have envisaged a new initiative focusing exclusively on antigypsyism, either separately as considered during the preparations of this policy package in 2018-2019 or within the broader EU anti-racism initiative. The scenario would have asked Member States to acknowledge antigypsyism as a specific form of racism and strengthen non-discrimination and the fight against antigypsyism in national anti-racism strategies. Moreover, it could have asked Member States to specify explicitly which general anti-discrimination measures or measures in other areas address antigypsyism and how. Member States could have been asked to include specific measures to address both Roma (rights awareness, facilitating access to legal remedy or building identity) and the general public in their national Roma and/or wider anti-racism strategies (e.g. by raising awareness about historical discrimination, segregation and persecution). For instance, one could add processes about the recognition of the persecution and extermination of Roma during 1933-1945 and the public representation of Roma culture, including Truth and Reconciliation processes at national level. Before turning to the implications of such a policy choice, the particular nature of the phenomenon of antigypsyism warrants some further conceptual clarifications. As explained above, antigypsyism is a specific form of racism, an ideology founded on racial superiority, a form of dehumanisation and institutional racism nurtured by historical discrimination, expressed, among others, through violence, hate speech, exploitation, stigmatisation and the most blatant kind of discrimination. Used in a narrow sense, it refers to anti-Roma attitudes or the expression of negative stereotypes in the public sphere or hate speech. In a broader sense, it implies hidden manifestations as part of a broad spectrum of discriminatory expressions and practices. As stated, antigypsyism ‘is not just another type of racial discrimination. It is, at the same time similar, different and intertwined with racism’. Indeed, as highlighted by the European Commission against Racism and Intolerance (ECRI), whose field of action covers all groups subject to racism in Europe, Roma constitute their ‘most frequent customer’. It is when dealing with their situation in any given country that ECRI employs, almost exclusively, words like ‘segregation’ and ‘exclusion’. This preoccupying situation, fact-based from ECRI’s country-specific reports, translates into Roma not enjoying equal dignity, being discriminated, targets of racist violence and facing persistent intolerance. The specificities of anti-Roma racism could be summarised as follows: ·The persistence of prejudice: a historically and geographically permanent racism that has endured for centuries without waning; ·The systemisation: a systematic, regular, repetitive racism, to the point where it almost seems to indicate a sort of ‘acceptance of that kind of racism’ within society; ·The violent nature of manifestations of racism towards Roma: a racism commonly put in practice, facilitated to a certain extent by the notion of impunity in the minds of perpetrators. For instance, racist statements or the use of violence never condemned by politicians at local or state level, with sometimes the politicians being the perpetrators themselves (the scapegoating of Roma and the public statements feeding anti-Roma sentiment during the COVID-19 pandemic are the latest in a long line of such manifestations); ·The generalisation ‘all Roma are alike’: common to other racialized groups but with the specificity of ‘common punishment’ – a crime committed by a Roma individual leads to the punishment of the entire community; ·A certain ‘hypocrisy’ when addressing the phenomenon and often a blame put on the victims of discrimination. For example, the same authorities blaming Roma for not sending their children to school are forcibly evicting Roma families whose children were attending school or the situation where authorities support segregation or the enrolment in schools for mentally disabled. To effectively combat these phenomena, analysing the features and manifestations of racism and intolerance is a necessary step but insufficient. Recognising that antigypsyism exists as a specific form of racism is the first step, followed by naming it, widely addressing through reinforced focus, and lastly, having the support of the Roma community. In view of its widespread nature and deep roots in social and cultural attitudes and institutional practice, antigypsyism has caught the attention of the academia as well, with significant work to date on anti-Roma racism and their link to the exclusion and marginalisation mechanisms. However, the understanding of how contemporary forms of antigypsyism differ from earlier ones and the difficulties in challenging them have received less attention. Indeed, the acceptance of antigypsyism as almost ‘normal’, not requiring any attention is evident in the face of the existing social and political debate on all forms of anti-Semitism, xenophobia, Islamophobia, afro-phobia, etc. and the accompanying efforts for advocacy, legal restrictions, education, and more. Even the lack of an adequate term to describe the resentment against Roma for many decades attest to the so-called ‘reasonable antigypsyism’. In the face of this evidence, researchers have begun to discuss about the so-called ‘invisibilisation of anti-Roma racism’. Reportedly, this trend to ‘invisibilise’ the racializing dimensions of Roma’s marginal living conditions is deemed a feature of the ‘de-politicisation’ of societal problems facing the Roma.

Instead, the evaluation suggested a strengthened, clearer focus on fighting antigypsyism and discrimination. This would complement and not replace the focus on social inclusion, increasing the effectiveness of policies and strengthening the enforcement of anti-discrimination and hate crime legislation. Taking into account the various features of antigypsyism would support Member States in responding effectively to discrimination and racism faced by Roma. Replacing the social inclusion approach would have led to a loss for mainstream social policies at EU and national level of their capacity to compensate for disadvantages Roma face. Being a radical shift from current policy, it would have disrupted the ongoing learning processes launched by the EU Framework. The approach also risked reinforcing an ethnic conception of Roma inclusion, further fuelling anti-liberal and/or anti-European populists against Roma (isolation of Roma as an example of undeserved protection by supposedly interfering forces from Brussels). Moreover, strong positions from a variety of stakeholders (civil society included) alerted on the dangers of ignoring the multiple, reissued calls for an explicit focus on antigypsyism (together with the focus on social inclusion and fighting poverty). Such dangers would outweigh the risks of focusing rather solely on antigypsyism as policy option. Addressing antigypsyism under a possible broader EU policy approach to racism could serve as an important mainstreaming initiative to complement the EU strategic framework’s focus on equality by fighting antigypsyism while contributing to the effectiveness of efforts to promote Roma inclusion and participation. Additionally, one should note that, in light of the experience with the proposal for a horizontal Equal Treatment Directive (negotiated for over 10 years), the adoption of a new EU law specifically in the field of fighting antigypsyism would not be realistic. The EU has adopted a number of binding legal instruments to ensure equality and non-discrimination that are crucial for fighting antigypsyism: the Racial Equality Directive and the Framework Decision on combatting Racism and Xenophobia, already transposed by Member States. The Race Equality Directive already prohibits both direct and indirect discrimination based on ethnicity. Efforts should be rather devoted to enforcement of the existing legislation, its correct application, guidance and training, where necessary, and financial support for the effective implementation and enforcement of legislation at the national level. It is also of utmost importance to support continuously the work of equality bodies, including by following up the implementation of the Commission Recommendation on standards for equality bodies. 7.2.3.Option focusing on ‘doing differently’: Anti-poverty Instead of a new EU Framework, the Commission could have envisaged a new initiative focusing exclusively on combating poverty. The initiative could have promoted social inclusion among disadvantaged groups, with or without specific targeting of Roma. The initiative could have asked Member States to address most extreme social exclusion and poverty more effectively in their national social inclusion strategies and to design specific measures for the most disadvantaged. These could have covered the whole life cycle with enhanced social protection, development of human capacities and activation for employment programmes. Presenting such an initiative would, however, not have been in line with the findings of the evaluation which concluded that ‘(…) the lack of a specific non-discrimination goal and targeted strategies and action to fight antigypsyism were among the key weaknesses. While discrimination and social exclusion reinforce each other, any Roma can be exposed to discrimination, but not all are socially excluded’. An initiative not taking a rights-based and targeted approach risked diluting policies for Roma into policies targeted at socially excluded people, without any differentiation. It would not have taken into account their specific needs and discrimination experiences nor included explicit safeguards to ensure that mainstream policies effectively reached out to Roma. Roma inclusion would have risked being understood as the exclusion of the poor. A combined approach of compensating for socio-economic disadvantages and tackling discrimination would have been compromised. Stakeholders confirmed this view during the 1 October 2019 workshop , when replies to a SLIDO question showed that 90% of the participants shared the view that a new post-2020 EU initiative should address antigypsyism, discrimination and socio-economic inclusion simultaneously. The expert recommendations made at the Austrian EU Presidency Conference on antigypsyism held in November 2018 expressed the same view. Participants confirmed therein that, to ensure effectiveness of social inclusion policies, the fight against discrimination and antigypsyism should feature as an additional priority area in a future EU Framework. 7.2.4.Option presenting a reinforced comprehensive policy approach to Roma equality inclusion and participation (‘do better’) The Commission’s initiative has to take into account the key lessons learnt from the evaluation: Table 4: Translating evaluation results into reform priorities for more effective strategies 1. Strengthen focus on equality to complement the socio-economic inclusion approach The four policy areas (education, employment, health and housing) and the integrated approach across these areas continue to be key for Roma socio-economic inclusion. However, there is need for a clear focus on equality with a specific objective on non-discrimination and fighting antigypsyism. The focus on fighting antigypsyism and discrimination should also be a crosscutting priority that complements but does not replace the inclusion approach. This joint focus should ensure that Roma have effective access to economic and social justice. 2. Promote participation by empowerment and building cooperation and trust Strategies should encourage meaningful Roma participation at all stages of policy-making at local, national and EU level, promote political, economic and cultural participation of Roma and a sense of belonging as full members of society. Additionally, they should promote empowerment and capacity building of Roma, civil society, as well as public authorities, and build cooperation and trust between stakeholders and between Roma and non-Roma. 3. Combine effective mainstreaming and Roma targeting The new EU strategic framework aims to combine effective mainstreaming and targeting. It promotes inclusive reform of mainstream policies, also under the European Semester, when enforcing the Racial Equality Directive and when negotiating the use of 2021-2027 EU funds. Governments are encouraged to follow a twin approach of making mainstream services inclusive and providing additional targeted measures. The aim of targeting is to provide additional support to promote effective equal access for Roma to mainstream rights and services. This should be reflected in future strategies, which should serve as planning instruments for using national and EU funds for Roma-targeted action and inclusive mainstream reform. 4. Reflect diversity among Roma Member States should ensure that strategies cover all Roma on their territory and reflect the needs of diverse groups. They should bear in mind how different aspects of identities might combine to increase discrimination. They should set qualitative and quantitative objectives addressing diversity in terms of age, gender, sexual orientation, disability, mobility and other dimensions in all relevant areas. While inclusion measures should target marginalised Roma, measures promoting participation should address all Roma, and measures fighting antigypsyism should reach out to society. 5. Ensure a common but flexible approach to national strategies

The new EU strategic framework should remain flexible to accommodate country differences, while increasing Member States’ accountability and commitment to full implementation of the strategies. The size and intensity of the challenges Roma face in various Member States should be reflected by differentiated objectives, levels of investment, types of policy solutions and EU level support across different Member States. 6. Improve target setting, data collection, monitoring and reporting to enable policy learning A common portfolio of indicators with accompanying quantitative and/or qualitative objectives for the national level to measure output, outcome and impact has the potential to improve effective progress towards Roma equality, inclusion and participation. The EU strategic framework proposes the use of specific, measurable, ambitious and realistic targets, including common EU headline targets, the latter complemented by nationally set targets in line with specific challenges based on available data. There is need for regular collection of data to feed reporting, monitoring, reinforce transparency and accountability and promote policy transfer and learning. In line with the results of the evaluation, the focus of such an initiative would be on the areas of education, employment, health and housing as well as on fighting poverty and exclusion, advancing non-discrimination and the fight against antigypsyism, including through increasing Roma participation. In addition, building on the evaluation, country differences in terms of the situation of the Roma should be considered. A pragmatic proposal for such an initiative could be a ‘common, yet differentiated approach’. As outlined above, all countries face challenges in terms of equality, inclusion and participation of Roma, variable in terms of intensity and specificity. Policy responses by Member States to a new EU level initiative could therefore vary. While adhering to minimum commitments, Member States could be advised to choose additional specific actions, in line with the respective challenges that Roma face in each country. The Commission could thus propose a common EU Framework with shared minimum commitments, but at the same time different degrees of political commitment according to the specific situation of the countries and the respective challenges that Roma face. Account taken of these differences, statistically representative quantitative equality data collection can support policy design and measurement of progress in several countries, while not in others. Similarly, several Member States will opt for using targeted 2021-2027 EU funding (in combination with mainstream EU and targeted or mainstream national funds) to support the implementation of their strategies, while others will use mainstream EU or national funds. In countries where Roma make up for a significant share of the population, promoting their equality and inclusion has a clear economic significance. It justifies the use of EU funds for both Roma targeted action and inclusive mainstream reforms, the need for data collection to support policy design, monitoring and review, and the need for more EU guidance and support. In terms of ambition, two sub-options for such a ‘do better’ initiative exist, one with purely qualitative EU-level objectives and another with quantitative (and qualitative) EU-level objectives. In both cases, Member States could be asked to translate EU-level objectives into national objectives: 7.2.4.1.A new EU Framework presenting a reinforced comprehensive policy approach to Roma equality, inclusion and participation - setting qualitative EU-level objectives This sub-option has the disadvantage of setting out qualitative EU-level objectives only, similar to the current EU Framework and its four Roma integration goals, which risks not being specific and measurable enough to monitor progress. 7.2.4.2.An initiative presenting a reinforced comprehensive policy approach to Roma equality, inclusion and participation - setting out qualitative and quantitative EU-level objectives This sub-option could set qualitative and quantitative EU-level objectives and propose differentiated national quantitative and qualitative objectives taking into account country differences. To facilitate take-up at national level, a portfolio of quantitative and qualitative indicators applicable to diverse country situations and agreed with Member States could complement it. This sub-option would provide for improved monitoring, reporting and evaluation arrangements. 7.2.5.Option to renew and strengthen Member States’ commitment to Roma equality, inclusion and participation (‘do more’) Importantly, both sub-options presented under 7.2.4 would leave out a critical issue identified as weakness of the current EU Framework, namely the fragmentation in implementation due to its voluntary nature. The low take up of the Roma Integration Goals included in the 2011 EU Framework was a particular reality across Member States. To mitigate this issue, the Commission could decide to present an initiative aiming at a higher level of ambition and increased Member States’ commitment to progress further and faster in Roma equality, inclusion and participation. To this end, the Commission could propose to revise the 2013 Council Recommendation. In terms of ambition, two sub-options are possible, differentiating from the degree of Member States’ acceptance: 7.2.5.1.An initiative reflecting policy learning from the evaluation and aiming at a renewed Member States’ commitment towards more effective national measures through a soft-law instrument but not endorsing the use of SMART qualitative or quantitative targets and indicators for monitoring progress (similar to the 2013 Council Recommendation on effective Roma integration) The benefit of such a soft law initiative includes a renewed and strengthened commitment by Member States to improved national strategic frameworks for Roma equality, inclusion and participation, continued guidance on the design and implementation of national strategies and its governance structures, such as the National Roma Contact Points. However, it would not address the advantages of sub-option 7.2.5.2. 7.2.5.2.An initiative reflecting the findings of the evaluation and aiming at a renewed Member States’ commitment towards more effective national measures through a soft-law instrument and endorsing the use of SMART qualitative and/or quantitative objectives towards EU headline targets via the use of indicators adjustable to diverse country situations This sub-option would in addition mean a clear commitment from Member States for monitoring progress towards national quantitative and/or qualitative objectives as their contribution towards meeting EU level objectives and headline targets. The political commitment would thus be stronger than in the 2013 Council Recommendation on effective Roma integration. This would be in line with the findings of the evaluation of the EU Framework, which stressed the importance of country-specific objectives and working towards common goals. The collection of data for qualitative/process indicators is not standardised. However, since 2016 Member States have started reporting to the Commission on process indicators relevant to the 2013 Council Recommendation’s substantive policy areas. The development of a reporting and monitoring system at EU level, in addition to national monitoring systems (in line with the minimum core requirements for national strategic frameworks) are the pathways to achieving the common goals in the seven specific objectives. Thus, the portfolio of indicators developed in the context of the Working Party on Roma indicators and reporting coordinated by the FRA encompasses both criteria. First, it reflects the criterion of setting quantitative outcome indicators. Second, it responds to the criterion of developing process indicators by looking at the institutional set-up (compliance with the EU Framework for national strategic frameworks), proposing types of measures and assessing the quality of the decision-making.

In light of the EU objectives and headlines targets, the Commission proposal for a draft Council Recommendation calls on Member States to include national quantitative and/or qualitative targets in their national strategic frameworks, adapted to the national circumstances and the options related to the collection of available ethnically disaggregated (or proxy) equality data. ‘According to the evaluation, complementing the four priority areas with a focus on fighting discrimination and antigypsyism as both a crosscutting requirement and a separate area and specifying a portfolio of individually adaptable Roma integration objectives with accompanying targets and indicators would improve the framework’s effectiveness and relevance. Country-specific targets could be selected from a detailed list of optional targets and indicators per area (differentiated targets in a common framework). Governments should update their objectives and priorities according to their national circumstances based on data’. 7.2.6.A combined option (‘do more and better’) Such an initiative would combine two or more of the above options or build on elements of several of the scenarios above. Such an option could, in particular, combine the ‘do better’ with the ‘do more’ options in a comprehensive and integrated approach, while strengthening the focus on fighting antigypsyism, including a specific objective on fighting poverty among Roma as well as a specific objective on promoting meaningful participation of Roma. A combined option would address the need for close cooperation between and comprehensive approaches of all stakeholders. In doing so, it would equip all stakeholders, including Roma themselves, with what they need to achieve faster progress towards Roma equality, inclusion and participation. Different levels of political ambition of such a combined initiative are possible, depending on the EU’s and national commitment in terms of target setting. A combination of sub-options 7.2.4.2 and 7.2.5.2, namely, an EU strategic framework initiative with qualitative and quantitative EU-level and national objectives, would be most suited to address the magnitude of the challenges, as it is the most ambitious option. Building on the current EU Framework, an ambitious new EU strategic framework would send a strong political signal from the Commission and provide a strong EU added value. In addition, presenting an ambitious proposal for a revised Council Recommendation for national Roma strategic frameworks on equality, inclusion and participation at the same time with the EU strategic framework could ensure that Member States and the Commission work hand in hand. This would entail a commitment by Member States to set national quantitative and/or qualitative targets towards meeting the EU level objectives and headline targets. A combined option has the potential to increase significantly coherence and effectiveness. In particular, effectiveness would be strengthened if the Communication sets out EU level objectives and headline targets, and the Recommendation confirms Member States’ commitments to include in their strategies clear national contributions towards these common targets. 7.3.Additional considerations regarding the policy choice and retained option The last step consisted of the examination of the coherence between the options and the political support for the post-2020 initiative, as expressed publicly by Council, the European Parliament and civil society. Key reference documents, such as the EPSCO Council Conclusions of 24 October 2019 on the Economy of Wellbeing or the February 2019 European Parliament Resolution on ‘the need for a strengthened post-2020 Strategic EU Framework for National Roma Inclusion Strategies and stepping up the fight against anti-Gypsyism’ were supportive of a new initiative. However, they were not explicit about the expected policy instruments with which the Commission should deliver the requested initiatives. As already set out above, the EPSCO Council Conclusions of 8 December 2016 entitled ‘Accelerating the Process of Roma Integration’ clearly asked the Commission ‘to propose a post 2020 strategy on Roma integration, and include therein a proposal for a revision of the Council Recommendation’. Only the combined option (option 7) would be fully coherent with this request. Based on the above, the options discarded were the following: ·No new EU level initiative (‘do less’) ·Option focusing on ‘doing differently’: Antigypsyism ·Option focusing in ‘doing differently’: Anti-poverty ·Option presenting a reinforced comprehensive policy approach to Roma equality inclusion and participation (‘do better’) ·Option to renew and strengthen Member States commitment to Roma equality, inclusion and participation (‘do more’) Consequently, the retained option was the one combining the comprehensive policy approach with stepped up political commitment of Member States through a revised soft-law initiative. Accordingly, that was the reason why the roadmap for the initiative published between 17 February and 16 March 2020 announced a Communication presenting the post-2020 EU strategic framework accompanied by a proposal for a revised Council Recommendation as the likely type of initiative.

8.other methodological information 8.1. Expected Impacts While respecting the Commission’s Better Regulation Guidelines, a detailed assessment of the economic, social, fundamental rights and environment impacts was not carried out. The main reasons for this decision were as follows: ·The expected impacts strongly depend on the level of commitment to Roma equality, inclusion and participation agreed to by the Member States, namely, the ambition reflected in the Council Recommendation once adopted and the national strategic frameworks put in place thereafter. The initiative aims to raise commitment by proposing a set of specific objectives and a portfolio of qualitative and quantitative indicators with associated types of measures, which are for Member States to include in their national strategic frameworks according to their Roma communities’ specific situation. Nevertheless, an impact assessment cannot predict the level of ambition to which Member States would be willing to commit in the end. ·In addition to general challenges of quantifying and monetising equality, non-discrimination and respect for fundamental rights, carrying out an impact assessment in the area of Roma equality, inclusion and participation would face serious limitations in terms of ethnic data collection in the Member States. However, as the evaluation of the 2011-2020 EU Framework found, the situation of the disadvantaged represents a loss of human capital and resources for Europe’s economies. It is clear, that the disadvantages faced by the Roma, which the initiative aims to tackle, bear an impact on Europe’s economies and societies. Indeed, in countries with a higher share of Roma, they represent a growing proportion of the school age population and the future workforce. Therefore, achieving equality, inclusion and participation of Roma is not only a joint responsibility but also an opportunity. Roma will benefit in terms of recognition, rights, redistribution of resources, better life outcomes and representation that is more effective. Europe’s economies and aging societies will also see positive impacts. Progress in socio-economic inclusion and equality of Roma has the potential to decrease labour and skills shortages in times of adverse demographic developments, reduce social expenditures and be beneficial for the economy. The latter benefits will be particularly visible in terms of productivity growth through better education and upskilling of a previously excluded young Roma labour force. This could benefit employers, through an increased and better skilled labour pool, in times of shrinking labour supply. It could also improve sustainability of pension systems in ageing societies thanks to upskilled Roma participating in the labour market. Progress in equality and inclusion can also have fiscal benefits such as increased contributions to national budgets (increased tax payment, social security, indirect taxes, such as VAT or excise tax) and affect the use of public goods and services (reduced take-up of social welfare, unemployment or child support benefits). Positive economic and financial consequences of Roma equality and inclusion could in turn foster a climate of greater openness within and less discriminatory attitudes by the majority population. This could have positive consequences for European society, in particular with regard to tolerance, respect for minorities and social cohesion. The initiative has positive consequences for the protection of fundamental rights. It reinforces implementation of the EU Charter of Fundamental Rights, in particular Article 21, which prohibits discrimination on any grounds, including race and ethnic origin. Finally, the initiative pays specific attention to marginalised Roma living in environmentally degraded areas and Roma employees working under less favourable environmental conditions. Evidence consistently shows higher rates of illness and mortality among Roma linked to poor housing conditions, higher exposure to air, water and ground pollution, poor diets, higher vulnerability to food insecurity’. Such living conditions turned dire with the advent of the COVID-19 pandemic, which saw national and local authorities take confinement measures/actions that pushed marginalised Roma into further exclusion and segregation. 8.2.Reflecting the lessons learnt from the COVID-19 pandemic and related needs of marginalised Roma communities in the post-2020 initiative From the outbreak of the unprecedented health crisis, the Commission called on Member States to ensure protection of the most exposed disadvantaged groups, insisting on the increased exposure of Roma communities and the need to deliver safely the much-needed support. As an immediate response to the crisis, the Commission proposed several instruments of potential support to disadvantaged groups such as Roma. The COVID-19 Response Investment Initiative (CRII) and the COVID-19 Response Investment Initiative Plus (CRII+) enabled the rapid mobilisation of available allocations under the European Structural and Investment Funds and the Fund for European Aid to the Most Deprived (FEAD). The EU Solidarity Fund provided additional assistance of up to €800 million to the worst affected countries in order to alleviate the financial burden of the immediate response measures. NRCPs were encouraged to coordinate with Managing Authorities the planning and implementation of EU funded emergency and midterm measures. The EURoma transnational learning network of ESF managing authorities and NRCPs also launched a survey among its members on the use and planned use of EU funds for Roma-targeted measures in the COVID-19 context. When it comes to the enlargement countries, the COVID-19 response has been notable in the Western Balkans as well as Turkey including the targeting of disadvantaged communities and the Roma. For the Western Balkans, the European Commission took significant initiatives to support the region to tackle the COVID-19 crisis. The ‘Commission Communication on the support to the Western Balkans in tackling COVID-19 and the post-pandemic recovery’ secured important financial support to address the immediate health crisis and resulting humanitarian needs. During March–May 2020, the RCC Roma Integration Action Team coordinated regular meetings with each Western Balkan country, in close cooperation with the NRCPs and the Commission. The objective of the meetings was to coordinate the efforts of different stakeholders, to propose targeted and mainstream measures when needed and to ensure that disadvantaged Roma needs remain known and are high in the country agenda when deciding on the COVID-19 responses. Beside the financial back-up and targeted assistance, the Commission engaged in an intensive dialogue with stakeholders to assess the impact of the crisis on marginalised Roma. The NRCPs, which proved their strong coordination role, EU-level civil society networks, and implementers of projects directly funded by the Commission reported on immediate and mid-term priority measures for the current 2014-2020 and the future 2021-2027 financial programming period and how updated national strategic frameworks could help mitigate negative impacts of the pandemic in marginalised Roma communities. Civil Society Organisations (CSOs) sent updated information on a regular basis. Subsequent videoconferences and follow-up input brought additional information on the situation in Member States and short and longer-term measures suggested to address it. NRCPs and civil society representatives drew attention to the following emergency response measures (already implemented in some Member States and enlargement countries): ·Provide access to clean water; ·Provide access to free health services for all in need including those without health insurance, targeting physical and mental health; ·Provide access to sanitation, protective gear and medicines;

·Provide access to mass testing according to health conditions and level of risk of people living in dense settlements; ·Provide access to information on virus-spread prevention through different means of communication and in Romani language (leaflets, posters, word of mouth, TV, radio, social media); ·Provide access to safe quarantine measures to avoid virus spread including access to food and housing meeting conditions for self-isolation; ·Provide testing (without stigmatisation), particularly in dense and challenged localities; ·Provide facilities, access to Wi-Fi and additional support to build digital skills for distance education; ·Strengthen the position of health mediators, education mediators and other field workers, the gatekeepers in Roma communities; ·Ensure continuity of basic utility services during the pandemic; ·Subsidise consumption costs for the most disadvantaged and those who have lost income; ·Ensure that social welfare is extended to cover informal workers, EU mobile Roma who have recently returned; ·Protect people affected by temporary loss of income, informal entrepreneurs and precarious workers. In addition to the emergency responses, mid- and long-term measures required to eradicate the longer-term socio-economic impact of the COVID-19 crisis, as suggested by NRCPs and civil society representatives , should fit into the main priority areas: ·Health: make public health investment including marginalised Roma a top political priority, with special funding to sustain sanitation measures initiated during the crisis; expand primary health coverage; improve access to all levels of healthcare and preventive care, implement mass vaccination programmes; and strengthen the position of Roma health mediators through education and provision of necessary equipment; monitor the quality of health services including on instances of discrimination; ·Employment: support the utilisation of active labour market policies, social economy and social enterprises to absorb and strengthen workplace-related skills of Roma at risk of poverty; recognition of workers who are part of non-formal economy (easier access to legal status for migrant workers, if needed); accelerate the transition of young people from education to employment through coaching, mentoring, traineeships, business incubators, and dual education; support schemes for businesses providing employment to disadvantaged people, including socially responsible public procurement; support financial literacy; ·Education: compensate all pupils from socially deprived backgrounds by strengthening social bonds through extracurricular activities such as outdoor school (educational) trips, school educational trips with non-Roma peers, free school club access; strengthen the work of school psychologists and social educators; compensatory tutoring of all children in need (including marginalised Roma) by community centres or local NGOs to mitigate the effects of the crisis on school performance; improvement of IT skills for Roma children, teachers and parents from marginalised communities; provision of broadband access, adequate digital infrastructure, teaching material and Roma education mediators equipped for distance learning; provision of distance learning premises (with IT and internet access) within the marginalised localities such as public libraries or community centres; scholarships for Roma to become teachers; ·Housing and essential services: improve access to water supply and sanitation, make a priority for Membe