EUROPEAN COMMISSION Brussels,12.6.2018 SWD(2018) 340 final COMMISSION STAFF WORKING DOCUMENT Interim Evaluation of the Internal Security Fund - Borders and Visa 2014-2017 Accompanying the document Report from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions on interim evaluation of the Asylum, Migration and Integration Fund and the Internal Security Fund

{COM(2018) 464 final}

{SWD(2018) 339 final}

{SWD(2018) 341 final}



Table of contents Abbreviations Executive summary 1. Introduction 2. Background to the intervention 2.1 Baseline 2.2 Description of ISF-BV and its objectives 3. Implementation / State of Play 3.1 Description of the implementation process 3.2 Description of the implementation status 16 4. Method 27 4.1 Short description of methodology 27 4.2 Evaluation questions 28 4.3 Limitations and robustness of findings 28 5. Analysis and answers to the evaluation questions 30 5.1 How effective has ISF-BV been so far? 30 5.2 How efficient has ISF-BV been so far? 37

5.3 How much simplification and reductions of administrative burden has ISF-BV brought so far? 40 5.4 How relevant has ISF-BV been so far? 44 5.5 How coherent and complementary has ISF-BV been so far? 49 5.6 What is the EU added value of ISF-BV so far? 54 5.7 How sustainable are the actions implemented under ISF-BV so far? 57 6. Conclusions and issues for further consideration 59 6.1 Effectiveness 59 6.2 Efficiency 61 6.3 Simplification of management procedures and reduction of administrative burden 61 6.4 Relevance 62 6.5 Coherence and complementarity 62 6.6 EU Added Value 63 6.7 Sustainability 64 Annex 1: Procedural information 65 Annex 2: Stakeholder consultation 66 Annex 3: Cost/benefit analysis 71 Annex 4: Evaluation questions 74



Abbreviations AMIF Asylum Migration and Integration Fund BCPs Border crossing points CIPS Specific programme Prevention, Preparedness and Consequence Management of Terrorism and Other Security-related Risks DG CONNECT DG Communications Networks, Content & Technology DG HOME Directorate-General for Migration and Home Affairs DG MOVE DG Mobility and Transport DG NEAR DG Neighbourhood and Enlargement Negotiations DG TAXUD DG Taxation and Customs Union EBCGA European Border and Coast Guard Agency (Frontex) EBF External Borders Fund EES Entry/Exit System EIF European Fund for the Integration of Third-Country Nationals EMAS Emergency assistance ERF European Refugee Fund EU European Union eu-LISA European Agency for the operational management of Large-Scale IT Systems in the area of freedom, security and justice Eurostat Statistical office of the European Union FTD Facilitated Transit Document FTE Full-time Equivalent FRTD Facilitated Rail Transit Document IBM Integrated border management ISEC Specific programme prevention of and fight against organised crime ISF Internal Security Fund ISF-BV ISF Borders and Visa ISF-P ISF Police ISS Internal security strategy MFF Multiannual financial framework IOM International Organisation for Migration Member States Member State(s) participating in ISF-BV incl. SAC PNR Passenger name record RF European Return Fund RTP Registered traveller programme SAC Schengen associated countries SOLID General programme solidarity and management of migration flows SFC2014 Shared Fund Management Common System of the Commission SSL Security and safeguarding liberties programme

List of countries AT Austria BE Belgium BG Bulgaria CH Switzerland CY Cyprus CZ Czech Republic DE Germany DK Denmark EE Estonia EL Greece ES Spain FI Finland FR France HR Croatia HU Hungary IS Iceland IT Italy LI Liechtenstein LT Lithuania LU Luxembourg LV Latvia MT Malta NL Netherlands NO Norway PL Poland PT Portugal RO Romania SE Sweden SI Slovenia SK Slovakia UK United Kingdom Executive summary This Commission staff working document (SWD) examines the impact of the Internal Security Fund — Borders and Visa (ISF-BV) covering the period between 1 January 2014 and 30 June 2017 against eight evaluation criteria: (i) effectiveness, (ii) efficiency, (iii) simplification and reduction of administrative burden, (iv) relevance, (v) coherence, (vi) complementarity, (vii) EU added value and (viii) sustainability. For the programming period 2014-2020, EUR 2.609 billion was allocated for the management of the EU’s external borders and visa policy. The Fund aimed to establish financial solidarity between Member States by supporting those countries that would experience a heavy burden in implementing the common standards for control of the EU’s external borders. The assessment focuses on the performance of the ISF-BV’s financial support for the management of the EU’s external borders, including at the level of the various individual policy themes which are major constituents of the concerned EU policy such as organising controls and managing the flows of people at the EU’s external borders. During the implementation period under review, migration conditions changed to another paradigm as Europe experienced a sudden and unexpected increase in migratory pressure on its southern and south-eastern external borders. Therefore, as the migration and security conditions underpinning the design of the funding instrument in 2011 changed drastically, new needs and funding priorities arose in order to further protect the EU’s external borders, an area where the absence of internal border controls was significant. The evaluation concludes that ISF-BV support is essential for carrying out the investments required to improve the EU’s external border management systems. The ISF-BV is contributing crucially to the application of the Schengen acquis considering the increase of migration flows since 2011, especially in 2014 and 2015. The Fund is tackling fragmentation by supporting the development and improvement at the national level of large IT systems, such as the Visa Information System and the second generation Schengen Information System (SIS II), as well as contributing to their coherent and effective use throughout all Member States. The ISF-BV is also encouraging a better use of resources by increasing the capacity of Member States to undertake border surveillance and by developing consular cooperation between Member States. The evaluation gave evidence that, in the challenging migration and security context described above, the funding instrument is, overall, flexible enough to respond to the changing needs resulting from the migration crisis by shifting resources to the affected Member States, also through emergency assistance (EMAS). Lastly, the evaluation has found that the ISF-BV is prompting or contributing to the set-up of comprehensive management and control systems, through (i) good coordination with the European Commission, (ii) applying stringent procurement procedures, and (iii) ex post audits of projects and monitoring arrangements. Therefore, the ISF-BV is promoting the reasonable use of EU financing in the field of border management. Based on the interim evaluation, the following conclusions have been drawn. §ISF-BV’s effectiveness has been impacted by the migration and security crisis, which put enormous pressure on the EU’s external borders and caused some Member States to reintroduce temporary internal border control measures. Regarding the common visa policy, the Fund has helped to implement it through better consular coverage, harmonisation of procedures, facilitating legitimate travel, organising information exchanges and training courses and supporting the development of common IT systems. The Fund has also contributed to the development of integrated border management policy, which increased solidarity among Member States by co-financing equipment used in Frontex joint operations. It has also contributed to the development of the EU’s acquis on border management, the European Border Surveillance system (EUROSUR), and border management IT systems. However, consular cooperation and cooperation with third countries attracted less attention from Member States than expected.

§The results of ISF-BV so far have been achieved at a reasonable cost in terms of both human and financial resources, but the administrative burden appears to be the main factor undermining efficiency. Even if national programmes have been very slow to begin, the Fund’s overall implementation appears to be on track, as EMAS bridged the funding gap and catered to immediate needs. This was facilitated by the flexible approach applied to EMAS management. §The management and control measures have been considered to be appropriate and efficient, with stringent mechanisms to ensure fraud and irregularities are prevented. §There is little evidence, at this stage, that the administrative burden has been significantly reduced, though ISF-BV has led to simplification relative to the past. Several new administrative and managerial procedures were introduced, taking into account the lessons learnt from the previous funds, including the adoption of the Better Regulation guidelines and toolbox and the collection of indicators in order to ensure a more appropraiate measure of performance. §ISF-BV is relevant and its original rationale and objectives remain largely valid even though the migration crisis has brought much more focus on how the EU’s external borders are managed. Member States are calling for more flexibility measures. §The Fund has been found to be coherent with and complementary to other national and EU interventions. §The Fund’s EU added value has been illustrated both from a policy and financial perspective. §Many ISF-BV actions are long-term actions by their nature, since they are generally designed to remain operational beyond the Fund’s support, while the sustainability of other actions relies on other sources of national or EU funding. Training activities and other cooperation mechanisms have also contributed to the increased sustainability of actions.

0.Introduction This Commission SWD presents the interim evaluation of the Internal Security Fund — Borders and Visa (ISF-BV) in line with Article 57 of Regulation (EU) No 514/2014 of the European Parliament and of the Council, the Commission Delegated Regulation (EU) 2017/207 and the Better Regulation Guidelines.

Member States submitted to the Commission interim evaluation reports on the implementation of actions and progress towards achieving the objectives of their national programmes by 31 December 2017. On the basis of these reports, the Commission must submit an interim evaluation report on the implementation of Regulation (EU) No 513/2014, Regulation (EU) No 514/2014 and Regulation (EU) No 515/2014 to the European Parliament, to the Council, to the European Economic and Social Committee and to the Committee of the Regions by 30 June 2018. The purpose of the interim evaluation of the ISF-BV is to: 1) ensure transparency and accountability in the ISF’s implementation, the general objective of which is to ensure a high level of security within ‘an area of freedom, security and justice’; and 2) help make the future implementation of EU instruments in the fields covered by ISF more relevant, effective, efficient, and sustainable and enable them to provide EU added value and simplification measures as well as reduce administrative burden. This evaluation looks at the progress made in implementing the programme, and assessed whether corrective actions are needed to make sure that the programme delivers as planned. It also contributed to the preparation of the next generation of funding instruments (the successors of ISF-BV), under the post-2020 multiannual financial framework (MFF). This evaluation covers all EU Member States, except Ireland and the United Kingdom that do not participate in ISF-BV. In addition, the evaluation covers Switzerland, Iceland, Liechtenstein and Norway, who are associated with the programme due to the fact that they fully implement the Schengen acquis. The evaluation covers the period from 1 January 2014 until 30 June 2017 and covers the national programmes of the participating countries, including specific actions and technical assistance as well as Union actions and emergency assistance.

1.Background to the intervention 1.0Baseline Policy context

One of the EU’s overarching objectives is to offer its citizens ‘an area of freedom, security and justice with respect for fundamental rights and the different legal systems and traditions of the Member States’ (Art. 67 TFEU). It has been on top of the EU policy agenda since the Tampere Council Conclusions in 1999. To achieve this goal, the Member States have to make a common effort to invest in the protection and security of their common external borders. The Schengen area is one of the EU’s greatest achievements. It is an area without internal borders where the people are ensured of the right to free movement without being subjected to border checks. Schengen states have improved and tightened controls at their common external borders on the basis of common rules to ensure the security of those living or travelling in the Schengen area and to prevent illegal entry, while facilitating legitimate travel. The Schengen acquis provides for common rules and procedures to be applied by signatory states with regard to short-term visas and border controls. Therefore, all signatory states needed to contribute to ensuring a high and uniform level of control on individuals and surveillance of the EU external borders. The consolidation and functioning of the Schengen area requires an overall border policy architecture at the EU level supporting the components of the common integrated border management (IBM) strategy. The IBM concept encompasses three dimensions: §a common corpus of legislation, in particular the Schengen Borders Code as well as the Regulation on local border traffic; §operational cooperation between Member States, including cooperation as coordinated by Frontex; §solidarity between Member States and the EU through the establishment of an External Borders Fund. However, the burden borne to implement the common standards for control of the EU’s external borders varied significantly from Member States to Member States. These variations were explained through the differences between Member States in terms of (i) the geography of their external borders, (ii) the number of border crossing points (BCPs), (iii) the level of migratory pressure, (iv) the risks and threats encountered and (v) the number of Schengen visa applications received. The Council identified the External Borders Fund (EBF), the first funding instrument that deals with borders, as one of the three dimensions of IBM. The EBF’s general objectives were to increase the efficiency of control and management of flows of people at the external borders, as well as unify the implementation of the EU legislation on the crossing of external borders and improve the management of activities organised by consular services. The EBF was implemented under shared management arrangements, by means of annual national programmes. It also funded Community and specific actions, which were managed at the initiative of the European Commission (direct management) and implemented by the Member States. The EBF was one of the four EU funding instruments established in 2007 as part of the framework programme on Solidarity and Management of Migration Flows (SOLID). It was also part of a wider policy package which also included the Frontex Agency, the Schengen Borders Code and the Schengen Evaluation Mechanism. The EBF, backed by funding of EUR 1.82 billion, intended to fully support the following five priorities: a)creating a common integrated border management system to carry out checks on people and for the surveillance of the external borders; b)further developing and implementing the national components of a European Surveillance System for the EU’s external borders and a permanent European Patrol Network for the southern maritime borders; c)issuing visas and tackling illegal immigration; d)establishing the IT systems required to implement EU border and visa legislation; and e)promoting the effective and efficient application of EU border and visa legislation.

The work towards achieving the IBM is a long-term and complex process, which benefitted from the support of the EBF. However, not all components were covered by the Fund. For instance, the consolidation and the functioning of the Schengen Area requires the Member States to acquire and develop the skills and obtain the equipment and technology necessary to be operational within IBM at EU level. Also, while being implemented, the EBF had to face the following challenges indicated in the table below. Policy challenges in the area of border management and visa §The length of the external border and the number and nature of border crossing points vary widely between Member States. The responsibilities for border control differ considerably from Member States to Member States, resulting in some of them bearing a disproportionate share of the associated costs. Therefore, Member States at the EU’s periphery with long borders and with many border crossing points have bigger responsibilities than other Member States to prevent irregular migration, facilitate bona fide cross-border movements and provide security. §Member States do not only issue visas in their own interest, but they have a common interest in applying common standards as people holding a visa or residence permit from an Member States can move freely to other countries. §To promote solidarity, the EBF aimed towards achieving a fair share of the responsibilities between Member States taking into account the financial burden arising from the introduction of integrated management of the EU’s external borders. In addition, the future ISF-BV fund was also to address and tackle certain needs and priorities that the EBF was not able to deal with, such as: a)further developing an integrated border management system; b)strengthening the operational capabilities of the Member States within EUROSUR; c)maintaining the large-scale IT systems (i.e. Schengen Information System II, Visa Information System or the functioning of an IT agency); d)developing new IT systems, such as the Entry-Exit System (EES) or the registered traveller programme (RTP); e)control measures within the area of free movement; and f)support inter-agency cooperation. In a parallel development, the internal security strategy (2010-2014) (ISS) enabled the EU to improve the preparedness and respond to existing and emerging threats to the overall European society. Significant progress was made under the fourth strategic objective of the ISS; strengthening security through border management. In relation to this objective, four key actions were identified: 1) exploit the full potential of EUROSUR; 2) boost Frontex’s contribution at the external borders; 3) undertake common risk management for moving goods across external borders, and 4) improve inter-agency cooperation at national level. The results under the actions above were: a) the entry into force at the end of 2013 of EUROSUR;

b) a new Schengen governance legislation; c) introduction of the Schengen Information System II; d) Visa Information System; and e) legislative proposals for an EES and an RTP (which would later become the Passenger name record (PNR)). Also, the ISS identified future challenges for the EU, both at an internal and external level, related to social crises, people’s mobility, demographic changes and/or political instability. Therefore, the ISS outlined the following challenges that future strategies and funds should tackle in the coming years: a) address the further increase in the amount of people coming to the EU; b) ensure all Member States sufficiently control their corresponding section of the external borders; c) ensure solidarity mechanisms are put in place to support Member States under pressure; d) support the adoption of the EES and RTP; e) ensure the Schengen Information System II operates effectively; f) explore the feasibility of establishing a European System of Border Guards and; g) devise a strategy and action plan for the security of the supply chain and risk management, and contribute to its implementation. In addition, Member States identified the following key risks and problems at the EU external borders in 2014:(i) large numbers of illegal border crossings at the external land and sea border; (ii) document frauds to circumvent border control measures; and (iii) cross-border crimes and travellers who intend to commit crime or terrorism within the EU. The 2015 European Agenda on Security was launched almost in parallel with the beginning of ISF-BV’s implementation. Since then, the Agenda has been providing strategic direction for the Fund in areas where financial support would bring more added value, such as: a)further development, improvement and optimisation of the Schengen Information System;

b)the interlinking of the Schengen Information System with Interpol’s database on stolen and lost travel documents (SLTD); c)common risk indicators to support the work of national border authorities when conducting checks on people; d)unifying standards of border management; and e)complementary measures to improve security in relation to the movement of goods. Funding context The share of funding for home affairs in the EU budget was relatively small but it has steadily grown (over the period 2007-2013 it amounted to EUR 6.45 billion or 0.77 % of the total EU budget. It covered the financing programmes, and it provided funding for large-scale IT systems (Visa Information System, Schengen Information System, Eurodac) and the agencies). The spending during this period was characterised by heavy ‘back-loading’, increasing from EUR 500 million in 2007 to EUR 1.5 billion in 2013. Such funding and the corresponding increase enabled the EU to tackle several policy challenges during 2007-2013, as described above. The table below represents a comparative overview between the EBF and ISF-BV in relation to the budget, participation and objectives. General programme Policy area Fund / Specific programme Budget, participation & objectives Previous funds Current funds General programme Solidarity and Management of Migration Flows (93 % to 96 % shared management; remainder under centralised direct management) Asylum European Refugee Fund (ERF III) EUR 614 million, all Member States except DK §Support and encourage Member States in receiving refugees and displaced persons §Emergency measures to address sudden mass influx if migrants and asylum seekers Asylum Migration and Integration Fund (AMIF, 2014-2020) EUR 3.137 million (initial), all Member States except DK §Strengthen and develop all aspects of the CEAS §Support legal migration to the Member States and promote effective integration of third-country nationals §Strengthen fair and effective return strategies and contribute to combating illegal immigration §Strengthen solidarity and responsibility sharing between Member States, particularly those most affected by the migratory flows Integration of legally residing TCNs, legal migration European Fund for the Integration of Third-Country Nationals (EIF) EUR 825 million, all Member States except DK §Support the integration of non-EU immigrants into European societies Return European Return Fund (RF) EUR 676 million, all Member States except DK §Improve return management §Encourage development cooperation between Member States and countries of return Integrated border management and visa External Borders Fund, (EBF) EUR 1.820 million, all Member States (including RO & BG and the Schengen associated states from 2010) except the UK and IE §Financial solidarity among Schengen countries §Manage efficient controls and the flows at the external borders §Improve management of the consular authorities Internal security Fund (ISF, 2014-2020) EUR 3.764 million (initial) ISF-Borders and Visa All Member States except IE and UK plus the Schengen associated states CH, IS, LI, NO §Ensuring a high level of security in the EU and facilitate legitimate travel §Visa and support integrated border management ISF-Police All Member States except DK and UK §Ensure a high level of security in the EU, fight against crime, manage risks and crisis General programme Security and Safeguarding Liberties (centralised direct management) Prevention of and fight against organised crime Specific programme Prevention of and Fight against Organised Crime (ISEC) EUR 600 million, all Member States §Crime prevention, law enforcement, witness protection and support, victims protection Combating terrorism and other security-related risks Specific programme Prevention, Preparedness and Consequence Management of Terrorism and Other Security-related Risks (CIPS) EUR 140 million, all Member States §Protection of citizens and critical infrastructure from terrorist attacks and other security incidents The four different SOLID funds complemented each other and provided a holistic approach to home affairs funding. However, there were weaknesses, identified by the ex post evaluations, and the European Court of Auditors special reports, as well as during the Commission’s impact assessment that accompanied its proposals for the 2014-2020 generation of home affairs funds. Those weaknesses included: (i) a lack of effective monitoring and evaluation systems; (ii) a lack of common indicators with measurable targets; (iii) high administrative burdens; and (iv) delays in providing evaluation reports at both at Member States and Commission level. To counter these weaknesses, recommendations were proposed which included, among others: ·the adoption of a broader framework to: oallow the funds to adapt to the Member States objectives and changing needs; oto focus on pressing issues and where needs are the largest; ·a harmonised approach across all EU funding streams;

·the improvement of monitoring and evaluation tools and capacities at EU, Member States and project levels; ·the improvement of sustainability by awarding funding based on innovation and sustainability of proposals. The EBF ex post evaluation’s final report and the EBF SWD also identified several issues, lessons and recommendations to be considered, which are detailed in the table below. Table 3: Lessons learnt from the EBF and how ISF-BV approached them Lessons learnt from the EBF ex post evaluation … Under ISF-BV … The EBF had a complex architecture, as it consisted of four broad objectives, numerous specific objectives and five priorities. The aim was to keep the Fund concrete and operational but this was not achieved. èThe architecture was simplified as ISF-Borders and Visa includes only two specific objectives (one for Borders and one for Visa) supported by seven operational objectives. There were difficulties linked to evaluation limitations when assessing the EBF’s overall effectiveness at EU level. The lack of an initial baseline and the fact that the EBF’s monitoring and evaluation system did not allow for detailed monitoring and assessment of the Fund’s performance. Set indicators were rather weak and monitoring data were not fully reliable. èA list of common indicators has been included in the Fund’s legal base. Moreover, Delegated Regulation (EU) 2017/207 was adopted in October 2016 on the common monitoring and evaluation framework for ISF-Borders and Visa. The following was adopted to improve the monitoring of the Fund: a)a set of evaluation questions and indicators were included in the framework mentioned above; b)a guidance document on the monitoring and evaluation framework for Member States was created; c)a common template for Member States to submit the evaluation reports and; d)an Evaluation Network was created for Member States staff and the Commission to discuss and resolve evaluation-related matters. The EBF was implemented through a strategic multiannual programme covering the whole programming period. However, annual programmes were adopted yearly, which was considered by some Member States a heavy administrative burden. èA single multiannual national programme which covers the period 2014-2020 was introduced. This speeds up the funding process and decreases administrative burden by allowing Member States to apply national eligibility rules with some added flexibility. Eligibility limitations were detected that prevented some actions from being implemented. èThere is operating support by which Member States can cover staff costs at border crossing points. The specific actions did not have a clear targeted focus. This was also administratively complicated to implement and resulted in an overlap with EMAS and projects implemented under the annual programme. èIt was decided to abolish the specific action under direct management in the ISF-BV and to include such actions in shared management to allow Member States to have more ownership and flexibility. Member States showed little interest in developing projects related to consular cooperation. èThere is a 90 % co-financing rate in NATIONAL PROGRAMMEs. Countries receiving small volumes of funds had higher management costs. èA threshold has been set to ensure that each Member States is allocated a more appropriate amount of funding, relative to its needs, as a starting block and the allocation percentage for technical assistance has been slightly increased. Thus, ISF-BV is building on the lessons learnt from its predecessor, the EBF, in providing support to Member States for managing the EU’s external borders and the EU’s visa policy. For instance, ISF-BV has a larger scope than the EBF, which was more limited to border control and visa policy. Through ISF-BV the EU can, for example, support verification measures within the area of free movement which were not carried nearby the external borders. It can also support inter-agency cooperation and the building of connections across the different law enforcement authorities, including those working within the territory of a Member State (police, border guards, customs, etc.) under an internal security agenda. ISF-BV can also support operational activities in the Member States related to borders and visa such as staff costs, etc. This SWD, notwithstanding its main purpose of ensuring transparency and accountability, and contributing to the Fund’s relevance, effectiveness and efficiency, is also looking to analyse the extent to which the recommendations that came out of the ex post evaluations of SOLID have been taken into account in ISF-BV. 1.1Description of ISF-BV and its objectives In a nutshell ISF-BV aims at ensuring a high level of security in the Union while facilitating legitimate travel, through a uniform and high level of control of the external borders and the effective processing of Schengen visas, in compliance with the Union’s commitment to fundamental freedoms and human rights, and is expression of and implemented by the principle of solidarity and fair sharing of responsibility within the EU. The legal base of ISF-BV is Regulation (EU) No 515/2014 adopted by the European Parliament and the Council on 16 April 2014, and it is based on Article 77(2) of the TFEU. General and specific objectives of the ISF-BV

The objectives for the ISF-BV are set out in Article 3 of the Regulation - the general objective of the Fund ‘ …shall be to contribute to ensuring a high level of security in the Union while facilitating legitimate travel, through a uniform and high level of control of the external borders and the effective processing of Schengen visas, in compliance with the Union’s commitment to fundamental freedoms and human rights’. This general objective is further broken down in two specific objectives on visa policy and border management: Specific objective 1: supporting a common visa policy Applying common visa standards has become essential as people holding a visa or residence permit in the Schengen area can move freely from one Member States to another. Therefore, all Member States share a common interest in ensuring that the EU’s visa policy is efficiently and securely applied. Therefore, the ISF-BV supports, through this specific objective, capacity building in the Member States in order to sufficiently implement the common visa policy. Specific objective 2: supporting integrated border management An efficient border control is crucial to ensuring the free movement of legally residing third-country nationals and EU citizens as well as ensuring internal security. As peripheral Member States control a significant length of the EU’s external borders, their responsibilities for border control have become overwhelming. In this regard, ISF-BV supports, through this specifc objective, (i) the further harmonisation of the border management, (ii) the sharing of information between the Member States, and (iii) the sharing of information between the Member States and the Frontex Agency. To fulfil the specific objectives a number of operational objectives were defined. Table 4: ISF-BV operational objectives Operational objectives (a) To promote the development, implementation and enforcement of policies to ensure that people, regardless of their nationality, are not subject to checks when crossing the EU’s internal borders, and to ensure efficient monitoring and checks are carried out on people crossing the EU’s external borders. (b) To gradually establish an integrated management system for external borders, based on solidarity and responsibility, particularly through: I.strengthening external border checks and surveillance systems, and inter-agency cooperation between border guards, customs, migration, asylum and law enforcement authorities of Member States at the external borders, including in the maritime border areas; II.measures within the Member States territories on the management of external borders and the necessary supporting measures on document security, identity management and the interoperability of acquired technical equipment; III.any measures that also help prevent and combat cross-border crime at external borders concerning the movement of people, including trafficking in human beings and human smuggling. (c) To promote the development and implementation of the common policy on visas and other short-stay residence permits, and different forms of consular cooperation to ensure better consular coverage and harmonised practices on visa issuing. (d) To set up and run IT systems, their communication infrastructure, and equipment that support the common visa policy, border checks and border surveillance at the external borders. These IT systems should fully comply with personal data protection law. (e) To boost situational awareness at the external borders and the reaction capabilities of Member States; (f) To ensure the EU’s acquis on borders and visas is efficiently and uniformly applied, including the effective functioning of the Schengen evaluation and monitoring mechanism; (g) To boost actions by the Member States that are helping to strengthen cooperation between Member States operating in third countries concerning the flows of third-country nationals into the Member States’ territory. These actions include preventing and tackling of illegal immigration, as well as cooperating with third countries in full compliance with the objectives and principles of the EU’s external action and humanitarian policy 1.1.0Global resources According to the legal base, the initial global resources for implementing ISF-BV in the period 2014-2020 were set at EUR 2.76 billion, whereas the reprogrammed amount stands at EUR 2.61 billion, as shown in the below figure. Further details in relation to the Fund’s implementation and its management modes are explained in Section 3 of this SWD.

The funds allocated to NATIONAL PROGRAMMEs (65 % of the total reprogrammed resources, including the Special Transit Scheme (STS) for Lithuania, and to technical assistance at the initiative of the Commission (0.46 % of the total) have remained unchanged. In response to unforeseen needs caused by the migration crisis, significant differences were made to funds allocated to EMAS (the amount increased from an initial allocation of 1.3 % to 14.8 % of the total fund). Furthermore, UAs have decreased by a quarter so more EMAS can be provided. The Member States received an additional amount of EUR 192 million to purchase equipment to be used in Frontex joint operations. As for the funds available for IT systems, the overall allocation of EUR 791 million has not changed - only the part to be implemented via ISF-BV has been reduced to EUR 145.7 million with the remaining amount to be implemented via the ‘Smart Borders’ and ‘Schengen Information System II’ budget lines managed by the Commission as well as directly by two EU agencies (eu-LISA and Frontex). Figure 1: Initial and reprogrammed global resources for 2014-2020 (EUR million) 1.1.1Eligible actions and beneficiaries All Member States (except IE and the UK) and as well as IS, LI, NO and CH participate in the Fund’s implementation. The Fund’s beneficiaries include federal and national authorities, local public bodies, non-governmental and humanitarian organisations, private and public law companies, education and research organisations. The ISF-BV supports actions in or by Member States, with a special focus on the ones shown in the table below, but maintains a wide scope to ensure full coverage of needs. Table 5: ISF-BV eligible actions ISF-BV ELIGIBLE ACTIONS a) infrastructure, buildings and systems required at border crossing points and for surveillance; b) operating equipment, means of transport and communication systems; c) IT and communication systems to manage migration flows efficiently; d) infrastructure, buildings, communication and IT systems and operating equipment; e) training in the use of the equipment and systems referred to in points (b), (c) and (d) and the promotion of quality management standards and training of border guards; f) secondment of immigration liaisons officers and document advisers to third countries; g) studies, training, pilot projects and other actions that gradually establish an integrated management system for external borders; h) studies, pilot projects and actions that aim to implement the recommendations, operational standards and best practices resulting from the operational cooperation between Member States and EU agencies. The Fund can also support actions in relation to or in third countries, such as: IT systems, training, promoting the development and implementation of the common policy on visas or boosting situational awareness. It also contributes to the financing of technical assistance at the initiative of the Member States and the Commission. 1.1.2The Intervention Logic

The intervention logic (see Figure 2) of the ISF-BV Fund is defined in order to understand what the Fund is aiming to achieve and how it will be achieved, by presenting the causal and logical links between problems, needs, objectives and eligible actions, as well as the connections between results and impacts. The implementation process is further explained in section 3.1. Figure 2: Intervention logic for the interim evaluation of ISF-BV

2.Implementation / State of Play 2.0Description of the implementation process ISF-BV is being implemented either by the Member States (shared management), directly by the Commission (direct management), or indirectly by entrusting the budget implementation task to a third party (indirect management).

Under shared management, resources are allocated through national programmes to be implemented in close cooperation with competent authorities and institutions. Member States implement national programmes which contribute to the EU’s policy objectives but which are also tailor-made according to their national context. This ensures a level-playing field among Member States, reduces the adverse effects of competition for funding, and brings predictability to funding allowing Member States to better plan their actions. Some actions, due to their nature, such as transnational actions, innovative projects, support to civil society, and actions requiring funds to be mobilised quickly are implemented under direct management by the Commission. Aside from actions to pursue the Fund’s specific objectives, within national programmes, each Member States ‘may use up to 40 % of the amount allocated to finance Operating Support to the public authorities responsible for accomplishing the tasks and services that constitute a public service for the Union’. In addition to the basic amount allocated to national programmes, Member States may also receive additional resources for the implementation of specific actions (SAs). SAs respond to EU priorities, in particular: ‘the setting up of consular cooperation mechanisms between at least two Member States’ (SA1), and ‘the purchasing of means of transport and operating equipment that are considered necessary for the deployment during the joint operation by the European Border and Coast Guard Agency (EBCGA, hereinafter referred to as Frontex) and that shall be put at the disposal of the Agency’ (SA2). Shared management also includes the ‘Special Transit Scheme’. This is a financial instrument that the EU granted to Lithuania to support the management of people transiting between the Kaliningrad region and the rest of the Russian Federation, through EU territory, by means of the Facilitated Transit Document (FTD) and the Facilitated Rail Transit Document (FRTD). At the beginning of the programming period, all Member States had a policy dialogue with the Commission to enable them to prepare their national programmes. Based on the outcome of these dialogues, the Member States submitted their multiannual national programmes. The Commission examined these programmes, consulted Frontex and eventually approved each national programme. To implement their national programmes, Member States had to set up a management and control system. The Commission follows the implementation under shared management by examining the annual implementation reports (AIRs) and accounts submitted by the Member States. A mid-term review of national programmes was planned for the middle of the programming period, i.e. in 2018. In addition, in order to evaluate the programmes, Member States are expected to submit two national evaluation reports: an interim evaluation report by the end of 2017 and an ex post evaluation report by the end of 2023. The Commission will take these reports into account in its interim and ex post evaluations of the Fund, which are to be sent to the European Parliament, the Council, the Economic and Social Committee and the Committee of the Regions by 30 June 2018 and 20 June 2024 respectively. A small amount of money equal to 5 % of the total national allocation plus EUR 0.5 million is reserved in the national programmes for technical assistance. Moreover, each Member States needs to establish a partnership with relevant stakeholders including, other public authorities, international organisations, NGOs and social partners in order to prepare, implement, monitor and evaluate the national programmes. Stakeholders meet regularly in a monitoring committee set up to follow the national programme’s implementation. For direct management, it is the Commission that centrally and directly supervises budget implementation through EMAS and UAs. Funds are earmarked by the EU through calls for proposals, procurement, and direct awards, as planned in the annual work programme. Under indirect management, the Commission entrusts, through delegation agreements, budget implementation tasks to Member States (or to bodies designated by them), international organisations, Member States development agencies, EU agencies, and other bodies, because they are best placed to carry out those activities and also because of the limited human and administrative resources available in the Commission. 2.1Description of the implementation status 2.1.0Shared management According to the legal base, the total programmed EU contribution for shared management was EUR 2.496 billion consisting of EUR 1.705 billion for national programmes and EUR 791 million for the development of (existing and/or new) IT systems that support the management of migration flows across the external borders. The allocation to national programmes was further broken down to:

·EUR 1.276 billion to national programmes, of which up to 40 % is available for operating support, with EUR 128 million to be distributed under the mid-term review; and ·EUR 147 million for specific actions; and ·EUR 154 million for the Special Transit Scheme. Regarding funds allocated to IT systems, only EUR 145.7 million will be provided via ISF-BV, with the remaining amount expected to be provided through the ‘Smart Borders’ and ‘Schengen Information System II’ budget lines managed by the Commission as well as directly by two EU agencies (eu-LISA and Frontex). At the end of the interim evaluation period 26 national programmes were approved and the resources allocated for adopted national programmes stood at EUR 1.533 billion. By 31 December 2016, Member States had drawn down EUR 584 million of the total EU resources available for the period 2014-2020 for national programmes that were adopted, with an implementation rate of 38 %. Total payments cleared under the accounts for 2014-2016 amounted to EUR 178 million, resulting in a very low payment rate of 12 %. Figure 3: ISF-BV shared management: Allocation of global resources to shared management 2014-2020 (EUR million) Disaggregating data by ISF-BV’s objectives as reflected in the Shared Fund Management Common System of DG HOME (SFC2014), resources have been earmarked for specific objective Borders (with 55.9 % of the planned EU commitment/available EU resources for adopted national programmes), followed by operating support (with 20.7 %), STS (with 9.7 %) and specific objective Visa (with 9.6 %). 4.1 % was dedicated to technical assistance. Figure 4: ISF-BV — EU planned resources 2014-2020 under the specifc objectives for adopted national programmes (EUR million)

For specific objective Visa, the Member States that spent the highest amounts on financed projects related to this objective are France, Spain, Cyprus, and Italy, with EUR 24.1, 11.2, 9.6, and 8 million respectively. Member States that spent the lowest amounts are Estonia, Liechtenstein, and Iceland, with projects funded for less than EUR 1 million. ·Three Member States (Belgium, the Netherlands and Spain) have developed activities to strengthen consular cooperation through new or improved infrastructure and buildings (co-locations, common application centres, representations and other infrastructural means). In particular, a total number of 4 actions — out of the 35 expected by national programmes — were put in place: 2 from the Netherlands and 1 each from Belgium and Spain. ·Eight Member States have engaged in activities aimed at developing and improving consulates’ physical structures and equipment, to help them perform visa-issuing services in a more effective and efficient way. Specifically, 156 consulates — out of the 911 expected to be covered by national programmes — have been developed or upgraded, of which: 85 belong to Belgium, 39 to Estonia, 13 to France, and the remaining 19 to Cyprus (9), Finland (6), Spain (2), Sweden (1), and Austria (1). In terms of the implementation rate, according to the annual implementation reports for 2016, 7 Member States display a rate between 1 % and 100 %. ·Seven Member States have already assigned Immigration Liaison Officers and other professionals with specialised functions, to maintain direct contacts with host Member States, enabling the effective implementation of EU measures to tackle illegal migration and improve information-sharing mechanisms with the host Member States. Member States have deployed 105 officers — out of the 392 expected to be covered by national programmes, of which: 30 belong to Germany, 23 to France, 20 to the Netherlands, and the remaining 32 to Austria (14), Belgium (8), Spain (7), and Hungary (3). For specific objective Borders, the Member States that spent the highest amounts on projects related to this objective were Italy, Greece, and Spain, with EUR 142.3, 124.2, 102.1 million respectively. In the remaining 16 Member States projects were financed for less than EUR 45 000 in each country. 11 Member States have not provided data under the referred indicator. As regards border control, 8 Member States have developed or upgraded 1 414 (out of the 12 454 expected to be covered by the national programmes) infrastructure and equipment items aimed at strengthening border checks and surveillance. According to the AIRs for 2016, the remaining 22 Member States have not implemented any actions yet. In terms of the implementation rate, as shown by Figure 4, the operating support displays the highest values (48 %), followed by STS (38 %), borders (37 %), visa (28 %), and technical assistance (27 %). Regarding the payment rate, STS displays the highest values (31 %), followed by operating support (22 %), borders (6 %), technical assistance (6 %), and visa (6 %). Figure 5: ISF-BV — EU planned resources 2014-2020 for adopted national programmes, Member States commitment 2014-2016, account amounts (EUR million), implementation and payment rate, by objective The implementation rate, on the other hand, shows that Member States are actually much more advanced in their implementation on the ground and that the difference between the two rates is expected to be claimed in the financial records over the following years. In addition, breaking up data by Member States (Figure 6), ES (EUR 208 million), EL (EUR 194 million), IT (EUR 188 million) and LT (EUR 180 million) are the four Member States which have the highest value of available resources for their adopted national programme. Overall, these Member States have been allocated 50 % of the total available EU resources 2014-2020.

In terms of the implementation rate, EE has attained a percentage of 87 %, followed by MT (83 %), AT (69 %), BG (66 %), LV (61 %) and BE (61 %). 18 Member States have currently achieved an implementation rate of between 12 % and 60 %. Finally, 2 Member States have not committed resources, displaying a rate of 0 %. The payment rates vary significantly across Member States: only 1 Member States, EE, has attained a percentage of 50 %, 16 Member States have currently achieved a payment rate between 1 % and 26 %, whereas 5 Member States display a payment rate under 1 %. Finally, 4 Member States display a payment rate of 0 %. Figure 6: Available EU resources 2014-2020 for adopted national programmes, Member States commitment (2014-2016) and accounts amounts (2014-2016), by Member States (EUR million), including top-ups. Taking into consideration the annual accounts for 2017 submitted by the Member States in mid-February, we can conclude that the overall payment rate improved from 12 % to 24 %, with Italy, Lithuania, Spain and many other Member States making significant improvements as illustrated in the figure below.



Figure 7: ISF-BV payments 2015-2017 (EUR million) 2.1.1Direct management

The AWPs for 2014-2017 allocated a total amount of EUR 414 million for EMAS (EUR 372 million) and UAs (EUR 42 million). Over the period 2014-2017, 90 % of resources have been allocated for EMAS, whereas only 10 % was allocated for UAs. UAs have been planned by the EU to allow for transnational actions or actions of particular interest to the EU to be funded. These actions concern the general, specific, and operational objectives set by Art. 3 of Regulation (EU) 515/2014. EMAS actions have been planned to allow Member States to address urgent and specific needs in emergency and unpredictable situations requiring a timely and effective response. The original planned amount envisaged for EMAS was multiplied by 11. Therefore, the reason behind the disproportionate planning between UAs and EMAS may be found in the need to properly face the unexpected and unprecedented migratory flows, which put significant pressure on the most affected Member States, during 2015 and 2016. By 30 June 2017, a total of 123 actions (46 EMAS and 77 UAs) were financed under the direct management for a total amount of EUR 383 million out of the EUR 414 million planned for resources for the 2014-2017 AWPs. In terms of the implementation rate, beneficiaries spent 6 % of total committed resources (EUR 271 million), with a total payments amounting to EUR 17 million. Table 6: AWPs planned resources, by different implementation mechanisms AWP 2014 AWP 2015 AWP 2016 AWP 2017 Total Action grants €9 163 194 €45 800 000 €249 983 495 €77 976 516 €382 923 205 Procurement €1 600 000 €1 667 000 €2 200 000 €2 690 000 €8 157 000 Delegation agreement €4 500 000 - €5 000 000 €2 300 000 €11 800 000 Other €450 000 €3 580 000 €2 750 000 €4 260 000 €11 040 000 Total €15 713 194 €51 047 000 €259 933 495 €87 226 516 €413 920 205 Emergency assistance measures Over the period 2014-2017, the EU allocated a total amount of EUR 371.6 million to cover the priorities and objectives set by AWPs for EMAS. By 30 June 2017, 7 Member States, 1 EU Agency and 1 international organisation were beneficiaries of a total of 46 EMAS actions. The total committed resources amount to EUR 257.5 million, while payments, including both pre-financing and final payments, for completed actions stand at EUR 12.8 million. The pre-financing paid on ongoing EMAS actions amounted to EUR 143.7 million. It is important to highlight that, for EMAS measures, the maximum possible co-financing rate of eligible costs is up to 100 %. In terms of the overall implementation rate, it stood at 5 % as of 30 June 2017, which is due to the fact that only 7 EMAS projects out of 46 had been completed by that time. However, when we look at the implementation of those 7 completed projects, it stands at an impressive rate of 95 %. Most EMAS actions were financed in 2015 (17) and 2016 (22) — the years when the migratory crisis peaked. IT and EL were the main beneficiaries of EMAS actions, with 18 and 17 measures financed respectively. Considering the financial support provided to each Member States, BG, IT and EL are the main beneficiaries under EMAS, with an initial grant amount of EUR 124.8, 59.5 and 55.9 million respectively, followed by SI (EUR 4.9 million), HR (EUR 4.0 million), FR (EUR 1.7 million), and HU (EUR 1.5 million). As regards other organisations, UNHCR has received EUR 4.1 million and EASO has received EUR 1.1 million.

Figure 8: Distribution of EMAS by Member States, by committed and paid amounts by June 30.2017 (EUR million) Based on the type of measures put in place, EMAS can be grouped as follows: 1.improvement of operational capacities (28 out of 46 measures); 2.acquisition and purchase of transport, operating equipment (such as search and rescue and border surveillance equipment, photo-finger printers), and IT systems for a better and appropriate reaction to the emergency situation (8 out of 46 measures); 3.support to staff and costs to keep equipment fit to address emergencies (7 out of 46 measures); 4.linguistic and intercultural mediation services (3 out of 46 measures). EMAS has also contributed to the Greek hotspots by providing funds for food, shelter, medicines and transport at the hotspots and funds for strengthening the fingerprinting capacity. Union Actions Over the period 2014-2017, the EU planned a total amount of EUR 42.3 million to meet the priorities and objectives set by AWPs for UAs. A total number of 77 UAs have funded beneficiaries based in nine Member States. It should be noted that 7 out of the 77 actions are being implemented via action grants with none completed by 30 June 2017, with the remaining ones being implemented via procurement of services directly by the Commission. ØAction grants

The total committed resources for the seven action grants amounted to EUR 3.8 million, while the implementation rate as of 30 June 2017 stood at 0 % with no final payments made by that date. The pre-financing paid to date amounted to EUR 1.2 million. It is important to highlight that, for such measures, the maximum possible co-financing rate for eligible costs is up to 95 %. Based on the type of measures put in place, action grants can be grouped as follows: 1.EUROSUR (two projects in ES and PT); 2.Visa processing (one project in DE); 3.Regional cooperation on border management (two projects in BG and EL); 4.Schengen Masterlist Border Control Pilot (two projects in NO and PT) Figure 9: Distribution of action grants by identified clusters, by committed amounts by June 30 2017 (EUR thousand) ØProcurement The total committed resources for 70 actions falling under the category of procurement, administrative arrangements and service level agreements amounted to EUR 9.4 million while payments on completed actions amounted to EUR 4.2 million, which corresponded to 52 completed actions out of 70 and an implementation rate of 45 % as of 30 June 2017. Procurement essentially covers services that the Commission purchased directly and focuses primarily on the financing of different evaluation mechanisms, most of which are linked to the Schengen evaluation. Most of the contracts were concluded in 2015 and 2016. Due to the nature of procurement, most contractors are based close to the Commission’s headquarters. Therefore, Belgium is the Member States with the most contracts (57), followed by France (9), Germany (3) and Luxembourg (1). Based on the type of measures put in place, procurements can be grouped as follows:

1.evaluation mechanisms, mainly Schengen evaluations (41 procurements); 2.IT Systems for border management (9); 3.visa processing (1); 4.immigration liaison officers (2); 5.press brochure on Schengen (3); 6.webworks (1); 7.others (13). Figure 10: Distribution of UAs by identified clusters, by committed and paid amounts by June 30 2017 (EUR thousand) 2.1.2Indirect management The 2014-2017 AWPs allocated, as of 30 June 2017, a total amount of EUR 12 million for indirect management instruments, out of which 42 % of the overall amount was allocated for 2016, 38 % for 2014, and only 20 % for 2017. Operationally, 81 % of the overall resources provided for through the AWPs have been allocated, for a total amount of EUR 9.5 million. By 30 June 2017 a total amount of EUR 7.9 million was paid as pre-financing with no final payment made by the cut-off date. In particular, during the period 2014-2017, the EU entrusted budget implementation tasks, through delegation agreements to the following bodies.

§eu-LISA in order to carry out the ‘Smart Borders Pilot’ testing phase, in the context of a ‘Proof of Concept’ exercise, as part of the Smart Borders Package adopted by the Commission on 28 February 2013. To implement the given tasks, the EU entrusted a total amount of EUR 3.5 million, with EUR 3.3 million in pre-financing. §The International Centre for Migration Policy Development (ICMPD) to implement the action ‘Mobility Partnership Facility’, in order to support mobility partnerships and common agendas for migration and mobility, in the context of the Global Approach to Migration and Mobility (GAMM). The action has been put in place under different financial instruments (AMIF, ISF-Police and ISF-BV) for a total estimated amount of EUR 5.5 million, of which a maximum of EUR 1 million was entrusted under the ISF-BV, with EUR 800 thousand paid in pre-financing up to 30 June 2017. §UNHCR for implementing the action ‘Support to Greece for the development of the hotspot/relocation scheme as well as for developing asylum reception capacity’, helping to create 20 000 reception places. The action has been put in place under different financial instruments (AMIF and ISF-BV) for a total estimated amount of EUR 83.3 million, of which EUR 5 million has been entrusted under the ISF-BV, with EUR 3.75 million paid in pre-financing up to 30 June 2017.

3.Method 3.0Short description of methodology This evaluation assesses how the Fund has worked so far and informs the national authorities, the EU institutions, the stakeholders and the general public about the key achievements and limitations of ISF-BV. It does attempt to explain how the Member States and the Commission plan to address weaknesses and overcome obstacles identified, to ensure that during the second half of the implementation period corrective actions are taken and the impact of any weaknesses are minimised. This forward-looking aspect of the interim evaluation will also contribute to the preparation of the next generation of funding instruments going beyond 2020. Similarly to the ex post evaluation of the EBF, the predecessor programme, this evaluation was carried out by an external consulting firm Ernst & Young between September 2017 and February 2018. It was coordinated by the HOME Funds Evaluation Team in Unit E3 of the Commission’s Directorate-General for Migration and Home Affairs with the support of an Inter-Service Steering Group comprising other Commission services. The Commission’s evaluation relied on an external study. It required a systemic synthesis of the evidence regarding the ISF-BV’s implementation. The methodology for data collection included both desk and field research. The data collected was subject to quantitative and qualitative analysis. Desk research essentially consisted of a review of:

·the relevant legislative documents (i.e. EU Treaties, ISF-BV Regulation); ·policy documents (i.e. European agendas on migration and on security; ·Commission communications; ·ex post evaluations of SOLID funds (in particular the EBF); ·Member States national programmes; ·AIRs; ·national interim evaluation reports (NIERs); ·grant agreements; ·final technical implementation reports; ·final financial implementation reports; ·mission reports from monitoring visits to beneficiaries carried out by the Commission staff; ·ex post audit reports; ·results of the mid-term review: and ·minutes from policy dialogues preceding the set-up of ISF-BV. The analysis also relied on statistical data from SFC2014 for shared management actions and on ABAC data for direct and indirect management actions. Field research covered different tools used to include multiple stakeholders categories according to the consultation strategy presented in Annex 2. It consisted of 50 phone interviews — exploratory phone interviews conducted during the inception phase and phone interviews with national responsible authorities (RAs), delegated authorities (DAs) and with relevant Commission services and agencies. Interviews at national level covered all Member States with external borders and that issued high number of visas, ensuring geographical and EU funding balance. An online survey was also carried out to address a wider number of stakeholders, including audit authorities (AAs), beneficiaries of multiannual programmes and union actions, members of the monitoring committees and experts. The response rate to the survey was almost 15 %. Moreover, eight case studies were produced with a close focus on six Member States (BG, EL, ES, FI, IT, and LT), EUROSUR (covering both direct and shared management) and consular cooperation (specific action). The case studies illustrate practical examples of projects carried out by Member States with ISF-BV support. Finally, information gathered through the targeted public consultation, launched by the Commission in December 2017 was also analysed. Information was triangulated to ensure validity and robustness. 3.1Evaluation questions

In line with the Better Regulation guidelines, this interim evaluation addresses evaluation questions structured around the five evaluation criteria of effectiveness, efficiency, relevance, coherence and EU added value, as well as the criteria of complementarity, sustainability, and simplification and reduction of administrative burden introduced by the Horizontal regulation. The complete list of evaluation questions as set in the legal base can be found in Annex 4. An overview of the answers to the evaluation questions can be found in Annex 4. 3.2Limitations and robustness of findings A first limitation of this interim evaluation concerns its timing: it is taking place only 3 years after the ISF-BV was launched, with many national programmes only being approved after delays, while most projects have only just started, making their assessment very challenging. Therefore, the evidence on the results and impact of the Fund is very limited. Nonetheless, this evaluation is not able to produce a full picture of the programme’s results and impacts and cannot draw final conclusions, as insufficient time has lapsed since the beginning of the programming period and the Fund is still being implemented. Concerning the indicators, limitations include issues related to data availability and the measurability of impacts (for example, most of the ISF-BV’s indicators focus on outputs). Often, these indicators are not linked to the Fund’s specific objectives. Therefore it is really difficult to attribute the observed changes to the Fund. The information gathered though primary sources is limited, since stakeholders have no clear idea of the results brought about by the Fund. Therefore the gathering of information focused more on procedural issues, providing a very general perspective on the Fund’s implementation, with sporadic examples found on the ground. Also, the reliability of Member States indicators was rather low as in many cases common indicators were not available or equal to 0. This hindered the statistical analysis of the Fund’s implementation and financial progress as well as the data comparison across Member States. In some cases, misalignment of data was noted between the national programmes, AIRs and in the NIERs. Concerning the period covered by the interim evaluation, for shared management actions the cut-off date was 31 December 2016, which is linked to the period covered by the latest set of accounts submitted by the Member States and cleared by the Commission. For actions under direct and indirect management, the cut-off date was 30 June 2017. The different cut-off dates did not allow the Fund to carry out a parallel assessment and comparison of results achieved under different implementation modes. Another limitation has been the lack of benchmarks to compare performance, mainly because AMIF and ISF are the first home affairs programmes to have a common monitoring and evaluation framework and a set of indicators (common, result and impact). In addition, many of these indicators have been viewed as being not relevant or not easy to populate with data and maintain. The contextual exogenous factors linked to the migration crisis itself are also a significant limitation. The Fund adapted itself to the changing needs, which made it difficult to evaluate its functioning and implementation against its initial design. Furthermore, while most of the interviews were conducted as planned, the response rate to both the online survey (15 %) and the Open Public Consultation (OPC, only four respondents) was very low. This hindered data triangulation, allowing comparison only for those issues for which responses were provided. Therefore, in some cases, evidence is based only on desk research, in other cases the documentary analysis is triangulated with interviews, and in fewer cases triangulation also included the survey and the OPC. Regarding the STS operated by Lithuania, it should be noted that the Lithuanian national interim evaluation report does not contain an evaluation of the scheme. Wherever there are references made to the STS throughout this document, they are solely based on the interviews carried out by the external consultant with the relevant stakeholders.

In the evaluation, these limitations were mitigated to the extent possible. The analysis of the evidence has allowed the Commission’s services to identify problems with data availability and quality that could be overcome over the course of the interim evaluation. Conclusions have been drawn, where possible, based on the triangulation of evidence from various data sources, indicated transparently. The use of multiple information sources made it possible to have an overview of the implementation state-of-play and of the Fund’s results. When answers were not provided to the online survey, information was gathered through the analysis of the national documents and, in some cases, confirmed (or not) by interviewees. The low number of participants to the surveys was counterbalanced by the analysis of national interim evaluation reports. Even though these reports were often not exhaustive, they made it possible to gather information on all Member States, and identify trends and divergences across them. Whenever possible, the ex post evaluations of the predecessor SOLID programmes have been used as a benchmark.



4.Analysis and answers to the evaluation questions 4.0How effective has ISF-BV been so far? This evaluation question aims to provide an insight into whether ISF-BV is on track to meet its objectives. The borders and visa instrument has two specific objectives — one linked to a common visa policy and the other to supporting integrated border management. Overall there are seven operational objectives — four of which are relevant for the common visa policy and six of which are relevant for the integrated border management. There are evaluation questions (see Annex 4) addressing each operational objective (see Table 4). 4.0.0Effectiveness in supporting a common visa policy In a nutshell Shared management The EU has a common visa policy for short-stay visits to the Schengen area, comprising of a set of harmonised rules setting out (i) the countries whose nationals require a visa to travel to the EU and those who do not, (ii) the procedures and conditions for issuing short-stay visas, (iii) a uniform format for visa stickers and (iv) a common Visa Information System that records all visa applications and decisions. EU Member States are among the world’s leading tourist destinations — the number of visa applications processed by Member States has increased considerably over the last 8 years and continues to expand. Since 2009, applications for EU visas have risen 50 % — from 10.2 million to 15.2 million in 2016 coupled with increased costs of processing of visa applications. The EU’s common visa policy has also been affected by the migration crisis with increased pressure on consular staff worldwide and an increasing need for cooperation on irregular migration and return. Overall, the Fund has significantly contributed towards the achievement of a common visa policy, as confirmed both by the stakeholders and by the implementation results of the national evaluation reports. The following five aspects of the common visa policy were addressed in the evaluation: 1) facilitation of legitimate travel; 2) better consular coverage and harmonised practices on visa issuance;

3) implementation of EU’s acquis on visas; 4) cooperation between Member States; and 5) IT systems and communications infrastructure and equipment. The Fund contributed to the facilitation of legitimate travel, strengthening Members States’ national capacities by, for instance: (i ) co-financing projects for strengthening national capacity to verify the authenticity of documents used for visa applications, (ii) developing information systems for coordinating visa applications, and (iii) procuring security equipment for consular representations in third countries. All this leads to Member States being in a better position to grant visas to those visa applicants with legitimate applications. In particular, projects under the Fund supported the purchase of technical equipment (e.g. document checking devices, communication equipment) to make the processing of Schengen visa applications more efficient and to support national information-sharing platforms to combat visa abuse and document fraud. Training also supported legitimate travel, by providing consular staff with technical and up-to-date information on visa issues and related systems. As regards consular cooperation, the ex post evaluation of the EBF revealed that Member States showed little interest in developing projects in this area mainly due to (i) the perceived high cost of common visa application centres or (ii) perceived issues linked to cost-sharing with other Member States resulting in Member States choosing to keep their representations in third countries. The Commission decided to incentivise this area through offering co-financing at a rate of 90 % in the national programmes under ISF-BV, while the scope was extended beyond common application centres to include other types of consular cooperation in addition to refurbishment, adaptation and/or equipping of consulates. Despite these measures, the Fund’s contribution towards consular cooperation has been quite limited so far, with many Member States not implementing any projects in the area yet. However, those Member States that have carried out consular cooperation activities gave positive feedback on the Fund’s contribution. For instance, it helped increase consular coverage by supporting the establishment of new consular posts and other forms of cooperation (e.g. joint training courses, joint consular offices) that incentivised Member States to establish consular representation agreements to improve visa processing and to promote a common approach to visa issuance. The use of the Visa Information System facilitated the exchange of both information on fraudulent visa documents and best practices on implementing Schengen standards. Training courses also contributed towards harmonising practices on visa issuance. Many Member States reported that visa harmonisation was supported through a better exchange of information and best practices being shared between Member States. There were difficulties in implementing joint projects between Member States due to the different national eligibility rules of expenditure, checks, and other rules related to the posting of staff. In particular, Member States involved in specific actions on consular cooperation asked for standard and clearer eligibility and expenditure rules at EU level to harmonise and ease the management of such actions. Currently, it is not possible to assess the effectiveness of the specific action as only a few projects have started and even those are in their initial stages. However, it is interesting to note that most Member States considered the needs addressed by the specific actions — harmonisation of visa issuance and increasing visibility and consular coverage of Member States — as particularly appropriate in light of current migration pressure. Ensuring the correct and uniform application of the Union’s acquis on visa has been supported either through mixed projects also pursuing other objectives, or through projects targeted specifically to this objective. Training courses targeted staff responsible for visa issuing and consular officials, police, and border guards engaged in developing and implementing the common visa policy. In some cases, training courses aimed to disseminate best practices among consular officials and to provide them with specific language courses or knowledge on the changing legal situation at EU level in the field of visa. Some Member States organised training sessions for consular services on security (e.g. illegal migration) and document verification (i.e. document fraud detection, counterfeit or forged travel documents, and documents necessary for visa application). Other training courses supported the implementation of the EU common visa policy and the Schengen acquis, concerning in particular the Community Code on Visas (Visa Code), including instructions for running Visa Information System and IT systems. Training was also aimed at improving the quality of services provided to visa applicants, to ensure equal treatment of third-country nationals in the visa-issuing process. A number of Member States have used the Fund to strengthen cooperation with third countries. Most projects in this area improved the exchange of information between authorities along the migration routes and on the return of illegal migrants. Furthermore, the Fund helped to tackle illegal migration by supporting the Member States in deploying temporary liaison officers and visa experts in consulates in third countries, who were directly responsible for the fight against fraudulent documentation or through consulates regularly consulting with each other in order to detect counterfeit documents. Responsible authorities involved in cooperation actions with third countries gave positive feedback on the actions implemented. The development of a common visa policy was also supported by means of establishing and operating IT systems, with particular regard to national Visa Information System, in order to ensure an efficient and smoother visa processing. The use of new technologies enabled the authorities to comply with the changing technical/legal requirements of the common visa policy, including the introduction of the biometric passports and related compliance checks. The development of IT systems was often accompanied by staff training measures so as to ensure that consular officials, police and border guards have sufficient technical expertise, as well as to ensure sustainability. Operating support guarantees the capacity and uninterrupted functioning of the systems and maintenance of equipment. This is a key factor for ensuring security since well-functioning IT systems are crucial for promptly detecting potential threats. Operational shortcomings may lead to the security system being jeopardised. The operating support for Visa measures also proved to be useful in covering staff costs and other running costs related to the EU common visa policy’s implementation, notably by strengthening national capabilities in the visa application process.

Direct management For direct management, only one action grant and one procurement were dedicated to the area of visa processing. However no conclusions can be drawn so far as they had not been finalised during the period covered by the interim evaluation. Examples of different types of visa projects implemented by the Member States The Fund supported the development of a Visa Information System in many Member States (AT, BE, BG, CZ, ES, FR, LT, LV, and RO). In Spain, the visa-issuing procedures were boosted by: (i) including a Visa Information System in most consulates, (ii) improving and developing new functionalities in the national scheme for visas and VISMail; and (iii) developing measures complementary to Schengen Information System II. France has implemented a website https://france-visas.gouv.fr for visa applications that is already in use in 37 countries to facilitate the process of visa applications and to harmonise procedures. In Austria, the Ministry of Foreign Affairs deployed experts to diplomatic representations to conduct web-based and onsite legal and technical training for staff dealing with Visa Information System, providing targeted knowledge on legal and technical innovations relating to the Visa Information System rollout. Moreover, it provided regional training courses for consular staff focused on legal and technical visa issues and IT systems. In Finland, cooperation was boosted by means of strong support provided by the Immigration Liaison Officer (ILO) network through the training of embassy personnel involved in the visa granting process. ILOs help prevent illegal immigration by investigating the background of visa applicants and by examining the authenticity of documents. Furthermore, ILOs support the training of embassy personnel. 4.0.1Effectiveness in supporting integrated border management Under the integrated border management concept the evaluation looked into progress made and the Fund’s contribution in the following six aspects: 1) absence of any checks on people when crossing the internal borders; 2) efficient checks on people and efficient monitoring of external border crossings; 3) gradual establishment of an integrated management system for external borders based on solidarity and responsibility sharing; 4) application of EU’s acquis on border management; 5) boosting of situational awareness at the external borders; and 6) setting up and running IT systems including communication infrastructure and equipment. Overall, the Fund contributed towards the overall objective on integrated border management, as confirmed both by the stakeholders and by the implementation results of the national evaluation reports.

In term of addressing the operational objective of ‘promoting the development, implementation and enforcement of policies with a view of ensuring the absence of any controls on persons, whatever their nationality, when crossing the internal borders and to carry out check on persons and monitoring efficiently the crossing of external borders’ the effectiveness of ISF-BV was greatly influenced by the security and migration crisis at the beginning of the programming period. The unprecedented flow of migrants into the EU during this initial phase of the Fund’s implementation, who crossed the EU’s external border unchecked, resulted in secondary movements of non-registered irregular migrants across the Schengen Area. This caused a severe strain on the Schengen Acquis, since the absence of internal border control is directly linked to the effectiveness of the controls at the external borders of the EU. As a consequence of the secondary movements and the security crisis, some Member States had to temporarily reintroduce internal border controls therefore affecting the Fund’s effectiveness. Moreover, the crisis put a specific focus on the management of the EU’s external borders. However, the Fund contributed towards the effectiveness of the border controls at the external borders by supporting measures focused on the replacement/upgrading of: ·border control equipment (e.g. work stations, portable computers, border check stamps, communication equipment, copiers, specialised biometric identification equipment, optronic devices, mobile equipment for border offices); and ·surveillance (e.g. development of electronic surveillance systems, thermovision cameras, USB microscopes that make it possible to verify documents at distance, aerial vehicles). Border management capacity was addressed by means of introducing automated border control (ABC) gates that speeded up the checks at the border crossing points. The ABC gates can be linked to national and international IT systems making the information exchange more efficient. Member States have also introduced the Public Key Directory, as a central repository for exchanging information required to authenticate ePassports and to verify the authenticity of travel/identification documents. Further projects are carried out in the following fields: ·modern technical equipment for border surveillance, including engineering appliances and the TETRA communication system; ·document verification devices such as document testing equipment for faster and more efficient processes; ·mobile scanning vehicles; ·mobile application for carrying out border checks; and ·purchase of document readers for portable border control devices. With the Fund’s support Member States carried out training activities in the area of border management, with the aim of improving staff awareness and competencies in relation to border management and the use of related IT information systems. The Fund supported the implementation of the EU’s acquis by co-financing training activities and programmes, which helped to improve the technical, operational and linguistic skills of the staff responsible for border management. Furthermore, this objective was indirectly supported by actions aimed at facilitating the cooperation and exchange of information with other Member States since such interventions strengthened the awareness of the Member States obligations at EU level and supported harmonised practices among Member States. Solidarity and responsibility sharing between the Member States is expressed mainly through joint operations; cooperation between Member States under EUROSUR and through cooperation with Frontex. So far some EUR 200 million has been spent on specific actions to support the purchase of Frontex equipment by 14 Member States, to be used in Frontex-coordinated joint operations. The Fund contributed to the development of EUROSUR by co-financing activities both under Member States national programmes and under Union actions. These activities aimed to improve situational awareness and increase the reaction capability at the external borders by detecting, preventing and combating illegal immigration and cross-border crime and by helping to protect and save the lives of migrants. Activities under EUROSUR also contributed towards solidarity and responsibility between Member States which is an important aspect of the operational objective on integrated border management. It needs to be pointed out that the actions financed by the Fund under the national objective of EUROSUR are interpreted in a much broader manner than the implementation of the action provided for by the EUROSUR Regulation (2013/1052). For example Member States could include in their national programmes, under the national objective EUROSUR, projects such as purchasing surveillance equipment or developing border surveillance systems which are linked to border surveillance in general, but not directly to EUROSUR’s implementation.

The Fund also provided support for the development of IT systems, notably for the upgrading and operation (under operating support) of the Schengen Information System (Schengen Information System II). This allowed the Member States to upgrade and maintain the IT systems and ensure their interoperability and interconnectivity between the different national systems, which in turn contributed to a more effective management of the EU’s external borders. Under the specific objective of integrated border management, it is specifically indicated that the Member States should respect human rights and the principle of non-refoulement. Two Member States reported that the maintenance and modernisation of border control buildings and facilities, and the introduction of modern technologies for border control contributed to ensuring international protection for those needing it and respect for the fundamental rights and the human dignity of third-country nationals. Two Member States reported that human rights issues were tackled through specific training sessions, with the support of EU agencies and international organisations working in the field of migration and human rights (e.g. IOM, UNHCR, and Frontex). One Member States reported implementing an action focused on acquiring linguistic and cultural mediation, aiming of facilitate communication between the State Police and migrants during landing and/or rescue operations as well as when applying for international protection. Furthermore, another Member States reported a project still being implemented that aims to strengthen the development of training schemes on human rights and fundamental freedoms. Currently, the Fund is not supporting Member States in applying the non-refoulement principle. Regarding direct management, 6 out of 7 action grants awarded under UAs are linked to border control, surveillance or management. However none of them had been completed within the evaluation period. Therefore, it is premature to reach any conclusions on their effectiveness. As for Emergency assistance (EMAS), only 7 out of 46 EMAS actions had been finalised in the period covered by the interim evaluation. EMAS has been used in seven Member States, especially in Greece, Italy and Bulgaria during the migration crisis to deal with the extra pressures at the external borders. In Bulgaria, for example, the amount of EMAS support in the period 2014-2017 amounts to EUR 124.8 million which is three times higher than the allocation for the national programme covering the whole period 2014-2020. Therefore, the Fund’s effectiveness in this specific case depends to a large extent on the interaction between the EMAS support and the national programme. EMAS support has been considered essential in addressing emergency needs. The situation is somewhat different in both Greece and Italy as their EMAS allocations under ISF-BV are smaller than in the case of Bulgaria but the size of their respective national programmes are much larger. Nevertheless, EMAS has been an important component in all these countries in dealing with the crisis especially when the national programmes were not yet running due to delays in approval. While EMAS measures proved to be a very efficient instrument in rapidly addressing a number of emergency situations arising from the migration crisis, action grants under UAs were less popular. Member States expressed limited interest in them with few proposals received to the calls published by the Commission. They are also subject to lengthy delays in implementation. Perhaps their design including eligibility rules could be adapted to better address Member States’ needs. Overall, the Fund has contributed towards ensuring a high level of security in the EU as far as it is possible at this stage of the implementation, also taking into account the migration and security crisis. The results achieved so far show that the Fund is an effective tool in supporting Member States in achieving a common visa policy and an integrated border management. Implementation delays were mainly linked to the late approval of the national programmes, but now that programmes are running, the Fund’s implementation is on track. All the Fund’s implementation modes contributed towards the achieving the Fund’s objectives. As regards shared management, the Fund contributed to ensuring a high level of security in the EU while facilitating legitimate travel, through a uniform and high level of control of the EU’s external borders and the effective processing of Schengen visas. Direct and indirect management modes contributed to more effective border and visa management through addressing urgent and specific needs in emergency and unpredictable situations requiring a timely and effective response and through projects promoting transnational actions or actions of particular interest to the EU. These actions helped to strengthen the national capacity in the operational management of both borders and visa matters. Examples of different types of border management projects implemented by the Member States Austria supported the procurement of thermal imaging vehicles for Frontex operations to increase the value of border police operations in other Member States, simplifying and improving border management. Also in the Czech Republic and Poland, the Fund co-financed the acquisition of thermal processing to strengthen the protection and surveillance of the external borders. In Slovenia, a key investment in strengthening the situational awareness at the external borders was the purchasing of two police patrol boats for the control of its maritime border to obtain data for the national situational picture using the navigation systems and by reporting important events. Both vessels are permanently in use, and data are collected and processed within the national coordination centre. 4.1How efficient has ISF-BV been so far? In a nutshell Overall, in the limits of available data, it could be considered that the results of the Fund were achieved at a reasonable cost in terms of both human and financial resources. Some Member States have put in place national efficiency measures. However, most Member States face problems with the EU guidance, common indicators, and the reporting/monitoring calendar. The perceived administrative burden can be considered as a factor that undermines efficiency. This question aims to consider the relationship between the Fund’s inputs (i.e. resources, budget etc.) and the outputs and results that it achieved. It tries to answer two questions: (i) to what extent the effects of the ISF-BV actions were achieved at a reasonable cost in terms of financial and human resources deployed and (ii) what measures were put in place to prevent, detect, report and follow-up cases of fraud, and other irregularities.

Shared management A number of findings from the EBF ex post evaluation address issues related to efficiency, which have been taken into account in the ISF-BV’s design such as more flexible multiannual programmes, sufficient allocation of resources at Member States level, simplified structure of the Fund, improvement of the overall evaluation tools, etc. all of which have an impact on the Fund’s efficiency. According to the evidence gathered by the external evaluation, overall, the results of the Fund were achieved at a reasonable cost in terms of both human and financial resources as far as it is possible to assess at this stage. The perceived administrative burden can be considered as the main factor that undermines efficiency. The national programmes’ implementation started very slowly creating challenges for evaluating the Fund’s cost-effectiveness because the majority of the projects are still ongoing. The Fund’s overall implementation is now on track. For shared management, a 38 % implementation rate has been achieved. The payment rate stood at 12 % by the end of 2016. Possible reasons for such a low payment rate may include: 1) late approval of most of the national programmes; 2) complexity and length of public procurement procedures that delayed implementation, especially the purchasing of patrolling equipment such as vessels, boats, helicopters etc.; 3) administrative burden (i.e. reporting requirements in relation to the annual accounts) that delayed implementation; and 4) low pre-financing rates, hampering Member States commitment and the payments. Taking into consideration the annual accounts for 2017 submitted by the Member States in mid-February, we can conclude that the overall payment rate improved from 12 % to 24 %, with significant improvements noted for Italy, Lithuania, Spain and many other Member States as illustrated in Figure 7. Low levels of costs for human resources were associated with the national programmes’ implementation (at responsible authority or delegated authority level). In terms of number of full-time equivalents (FTEs) in the responsible authority, delegated authority and audit authority in comparison to the number of projects implemented, the large variation found may suggest that the method of award (direct award, call for proposals etc.) and the type of action to be implemented (i.e. specific action or regular project under the national programme) affect the number of FTEs needed. On average, 7.08 FTEs per Member States have been involved in managing the Fund and have been paid through technical assistance and/or national budgets, with remarkable differences between the different Member States. For example, at the time, Belgium had 3 FTEs to manage 27 projects and an allocation for the national programme of EUR 17.5 million, while Italy has involved 14 FTEs in managing 22 projects and an allocation of EUR 156.3 million. Overall, considering the average number of projects implemented by 2017 (12.84), an average of 0.55 FTEs was engaged per project. Overall, Member States show a growing or stable number of FTEs over the years from 2014 to 2017, except Germany (FTEs decreased in number from 25 to 21) and Malta (FTEs decreased from 13 to 10). On average, the number of FTEs increased from 2.44 in 2014 to 6.80 in 2016, increasing further in 2017. In addition, considering the ratio between technical assistance, plus the administrative indirect cost, and the amount of the funds claimed for the financial year, on average the ratio stood around 1.41. In this regard, the ratio increased significantly over the years from 0.16 in 2015 to 0.67 in 2016, and more than doubled in 2017. Considering the ratio FTE (average)/amount of the funds claimed for the financial year (average), 0.5 FTEs have been involved per million for the implementation of the ISF. In this regard, there has been a significant decrease over the years, dropping from an average of 1.35 FTEs in 2014, to 0.72 FTEs in 2016, with a further decrease in 2017 to 0.5 FTEs, leading to decreasing labour intensity of fund management.

According to stakeholders, some of the success factors that brought efficiency have been the following: ·public agencies, as beneficiaries of the Fund could use their own networks to involve additional resources on an ad hoc basis and at no extra cost for the project; ·considerable knowledge and expertise had been gained through experience from previous projects (especially from SOLID and other programmes with multiannual projects); ·staff were already employed in the organisation; and ·the flexibility of the national programmes (their multiannuality). Furthermore national measures concerning the application, implementation, monitoring and reporting processes have been put in place in some Member States to ensure efficiency which include some of the following actions: ·administrative and technical project approval procedures; ·procedures to assess appropriateness of expenditure; ·responsible authority project monitoring mechanisms; and ·national coordination mechanisms. There are also a number of issues that Member States believe negatively affect efficiency and these are: ·the requirement to allocate minimum percentages among national objectives; ·complex and recurrent reports; ·common indicators: and ·the alignment of monitoring calendars. Measures put in place to prevent, detect, report and follow-up cases of suspected fraud and other irregularities include: ·on the side of prevention:

ocareful examination of project applications; oex ante public procurement control systems; orisk analyses by the responsible authority/delegated authority; otraining courses on fraud prevention or fraud risk management; oprovision of guidance tools; and oregular communication between projects and responsible authority staff; ·on the side of detection : oadministrative control checks; ooperational on-the-spot checks; ofinancial on-the-spot checks; and oex post audits; ·on the side of reporting and follow-up: oimplementation of communication instruments; oestablishment of procedures for reporting suspected fraud; and oestablishment of procedures for corrective and deterrent measures. The majority of Member States claims that the anti-fraud measures are appropriate and effective, stating that stringent mechanisms ensure the effective prevention of fraud and irregularities. Experience suggests, however, that there is always a potential trade-off between the procedures in place to prevent fraud and irregularities and the Fund’s overall efficiency, in the sense that measures can be seen as very effective for preventing fraud, but they are not necessarily very efficient from a management perspective. Direct management

Regarding the 7 action grants awarded under the UAs, none of them had been completed by 30 June 2017 and only 7 out of 46 EMAS actions had been finalised in the corresponding period. Consequently, their overall implementation rate is very low and it is too premature to reach any conclusions on their ef