Special Report No 22/2012 ‘Do the European Integration Fund and European Refugee Fund contribute effectively to the integration of third-country nationals?’
Date: 2013-01-16
Institutions: European Court of Auditors
Subjects: EU migration policy, aid to refugees, foreign national, fund (EU), integration of migrants, third country

EUROPEAN
COURT OF AUDITORS

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DO THE EUROPEAN INTEGRATION 
FUND AND EUROPEAN REFUGEE FUND 
CONTRIBUTE EFFECTIVELY TO THE 
INTEGRATION OF THIRD-COUNTRY 
NATIONALS?

EN

 
 
 
 
Special Report No 22 

 2012

DO THE EUROPEAN INTEGRATION 
FUND AND EUROPEAN REFUGEE 
FUND CONTRIBUTE EFFECTIVELY 
TO THE INTEGRATION OF THIRD-
COUNTRY NATIONALS?

(pursuant to Article 287(4), second subparagraph, TFEU)

EUROPEAN COURT OF AUDITORS

EUROPEAN COURT OF AUDITORS
12, rue Alcide De Gasperi
1615 Luxembourg
LUXEMBOURG

Tel. +352 4398-1
Fax +352 4398-46410
E-mail: eca-info@eca.europa.eu
Internet: http://eca.europa.eu

Special Report No 22 

 2012

A great deal of additional information on the European Union is available on the Internet.
It can be accessed through the Europa server (http://europa.eu).

Cataloguing data can be found at the end of this publication.
Luxembourg: Publications Office of the European Union, 2012

ISBN 978-92-9241-049-0
doi:10.2865/49933

© European Union, 2012
Reproduction is authorised provided the source is acknowledged.

Printed in Luxembourg

3

CONTENTS

Paragraph

GLOSSARY

I–VII 

EXECUTIVE SUMMARY

1–16 

INTRODUCTION

6–11 

WHO DO THE EIF AND ERF SUPPORT?

12–16 

ROLES AND RESPONSIBILITIES

17–19 

AUDIT SCOPE AND APPROACH

20–75 

OBSERVATIONS

20–41 

 INDIVIDUAL PROJECTS SUCCESSFUL BUT THE FUNDS’ OVERALL CONTRIBUTION TO THE INTEGRATION OF 
THIRD-COUNTRY NATIONALS COULD NOT BE MEASURED

24–27 

AUDITED MEMBER STATES DID NOT SET SUFFICIENTLY QUANTIFIED TARGETS AND INDICATORS …

28–33 

… AND THE COMMISSION’S EIF INTERMEDIATE REPORT PRESENTED ONLY LIMITED INFORMATION

34–35 

36–41 

 THE LOW-RATE OF IMPLEMENTATION DURING THE FIRST TWO YEARS REDUCES THE POTENTIAL EFFECTIVENESS 
OF THE FUNDS …

… BUT THE AUDITED PROJECTS ACHIEVED POSITIVE RESULTS AND FUNDS WERE CONSIDERED BY MEMBER 
STATES TO BE VALUABLE FOR INTEGRATION

42–59 

THE EFFECTIVENESS OF THE FUNDS’ CONTRIBUTION TO INTEGRATION IS LIKELY TO BE LIMITED BECAUSE …

44 

… THE SPLIT OF INTEGRATION MEASURES BETWEEN ERF AND EIF CAUSES PRACTICAL DIFFICULTIES

45–47 

ANNUAL PROGRAMMING LEADS TO EXCESSIVE ADMINISTRATION …

48 

… AND THERE ARE BURDENSOME FINANCING ARRANGEMENTS

49–51 

52–59 

THE DESIGN INTRODUCED A LONG CHAIN OF CONTROLS AND SOME MEMBER STATES HAVE ADDED TO THIS 
ADMINISTRATIVE BURDEN …

… AND INSUFFICIENT COHERENCE AND COMPLEMENTARITY WITH OTHER EU FUNDS LED TO OVERLAPS AND 
LOSS OF SYNERGIES

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60–75 

62–64 

 RESPONSIBLE AUTHORITIES HIGHLY COMMITTED BUT DELAYS AT ALL LEVELS AND WEAKNESSES IN THE 
MANAGEMENT AND CONTROL SYSTEM MAY FURTHER REDUCE THE PROGRAMMES’ EFFECTIVENESS

DELAYS IN THE ADOPTION OF THE LEGISLATION AND IN THE COMMISSION AND MEMBER STATES’ CRUCIAL 
TASKS …

65–66 

… LEADING TO THE COMMISSION ISSUING GUIDANCE LATE TO MEMBER STATES

67–69 

WEAKNESSES IN MEMBER STATES’ MONITORING SYSTEMS NOT DETECTED BY THE COMMISSION …

70–72 

PERSISTENT WEAKNESSES AND FAILURES IN CERTIFYING AND AUDIT AUTHORITIES

73–75 

THE RESPONSIBLE AUTHORITIES ARE MOSTLY FULFILLING THEIR KEY FUNCTIONS DESPITE THE LIMITATIONS IN 
DESIGN AND IMPLEMENTATION

76–93 

CONCLUSIONS AND RECOMMENDATIONS

79–80 

 EFFECTIVENESS OF EIF AND ERF COULD NOT BE MEASURED

81–82 

83–85 

 AUDITED PROJECTS LARGELY CONTRIBUTING TO INTEGRATION BUT NOT ALL AVAILABLE FUNDS ARE USED 
BY THE MEMBER STATES

 FRAGMENTED DESIGN OF THE FUNDS CAUSING DISPROPORTIONATE AND EXCESSIVE ADMINISTRATIVE 
BURDEN FOR FINAL BENEFICIARIES, MEMBER STATES AND THE COMMISSION

86–87 

 COHERENCE AND COMPLEMENTARITY WITH OTHER EU FUNDS NOT SUFFICIENTLY ENSURED

88–90 

 SUCCESSIVE DELAYS HAMPERING IMPLEMENTATION AT BOTH MEMBER STATES AND COMMISSION LEVEL

91–93 

 DELAYS IN THE ESTABLISHMENT OF EFFECTIVE MANAGEMENT AND CONTROL STRUCTURES IN THE MEMBER 
STATES

ANNEX  — 

 AUDITED PROJECTS

REPLY OF THE COMMISSION

Special Report No 22/2012 – Do the European Integration Fund and European Refugee Fund contribute effectively to the integration of third-country nationals?

 
GLOSSARY

5

Annual Programme (AP): A Member State’s work programme implementing the multi-annual programme.

Asylum seeker/Asylum applicant: Person who is applying for refugee status or subsidiary protection.

Commitment: Legal budgetary obligation, such as a financing decision or contract.

European Integration Fund (EIF): The European Fund for the Integration of third-country nationals supports 
national and EU initiatives that facilitate the integration of non-EU immigrants into European societies.

European Refugee Fund (ERF): The European Refugee Fund supports EU states’ efforts in receiving refugees 
and displaced persons and in guaranteeing access to consistent, fair and effective asylum procedures.

European Return Fund (RF): The European Return Fund seeks to encourage the development of cooperation 
between EU states and with countries of return.

European Social Fund (ESF): One of the EU’s Structural Funds, set up to reduce differences in prosperity and 
living standards across EU Member States and regions.

Eurostat: Eurostat is the statistical office of the European Union and a directorate-general of the European 
Commission.

External Borders Fund (EBF): The External Borders Fund establishes financial solidarity by supporting those 
countries with a heavy financial burden to implement the common standards for control of the EU’s external 
borders.

Framework research programme: The EU’s main instrument for funding research in Europe, the current sev-
enth framework research programme for research and technological development (FP 7) runs from 2007–13.

Management and Control System (MCS): Set of procedures and practical arrangements for a Member State 
to implement the SOLID Funds.

Refugee: A third-country national who, owing to a well-founded fear of being persecuted for reasons of race, 
religion, nationality, political opinion or membership of a particular social group, is outside the country of 
nationality and is unable or unwilling to return to that country, or a stateless person, who, being outside of the 
country of former habitual residence for the same reasons as mentioned above, is unable or, owing to such 
fear, unwilling to return to it.

SMART objectives: Objectives are SMART when they are specific, measurable, achievable, relevant and timely.

SOLID programme: The ‘General programme on Solidarity and Management of Migration Flows for the period 
2007–13’ consisting of four funds (EIF, ERF, EBF, RF).

Subsidiary protection: Applicants who do not qualify for refugee status, but who cannot return to their 
country of origin due to a real risk of suffering serious harm (torture or inhuman or degrading treatment, death 
penalty or execution, serious individual threat to the life or person as result of indiscriminate violence) have 
the right to subsidiary protection.

Third-country nationals (TCNs): Citizens from countries outside the European Union (non-EU citizens).

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EXECUTIVE SUMMARY

I.
The EU’s SOLID programme supports actions to fos-
ter integration of third-country nationals in EU Mem-
ber States and strengthen solidarity by sharing the 
financial burden resulting from the management of 
common external borders and the implementation of 
common policies on asylum and immigration.

II.
The  objective  of  the  Cour t ’s  audit  was  to  assess 
whether  the  European  Integration  Fund  and  Euro-
pean Refugee Fund, forming part of the SOLID pro-
gramme, contribute effectively to the integration of 
third-country nationals. These funds are implemented 
by the Commission and Member States through shared 
management.

III.
The Court found that it was not possible for the Com-
mission or Member States to assess the contribution of 
the SOLID funds to integration because audited Mem-
ber States did not set proper targets or indicators for 
their annual programmes. The Commission’s intermedi-
ate report on results achieved and on qualitative and 
quantitative aspects of the implementation, based on 
Member States’ reports, did not provide enough infor-
mation for the Funds to be evaluated or steered. At the 
level of individual projects, the sample audited by the 
Court showed positive results but these could not be 
linked to success at a higher level, not least because 
the implementation rate was low in the 2007 and 2008 
national annual programmes. Later programmes have 
not yet been completed.

IV.
The effectiveness of the Funds has been hampered 
by the design of the SOLID programme, which is frag-
mented, burdensome and inadequately coordinated 
with other EU funds. The splitting of funding for target 
groups which have similar needs has created prob-
lems for authorities and beneficiaries. This, together 
with the combination of multiple funds and annual 
programming, plus a long chain of controls by three 
authorities, has led to excessive administration out 
of proportion to the size of the funds involved. Insuf-
ficient coherence and complementarity with other 
EU funds leads to overlaps, missed opportunities for 
synergy and a risk of double-funding.

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EXECUTIVE SUMMARY

(d)  The Commission should place greater importance 
on obtaining concrete details on the assurance of 
coherence and complementarity in EU funds from 
Member States. 

(e)  The Commission and Member States should set 
up an obligatory system of common indicators, 
and Member States should set target values for 
national programmes.

(f )  For  the  start  of  the  new  programme,  the  Com-
mission should ensure that its key guidelines are 
ready in advance and that Member States have set 
up adequate Management and Control Systems.

V.
Responsible Authorities are mostly fulfilling their key 
functions, despite the problems inherent in the design 
and staff shortages. However, the SOLID programme 
suffered from delays from the start, with late adop-
tion of the legislation. This led to late submission of 
programmes, implementing rules and guidance not 
being available until well into the programmes’ imple-
mentation, and misunderstandings about the relative 
roles of the three authorities. 

VI.
Delays continue to feature, both in Member States’ 
submission of programmes and reports, and in the 
Commission reviewing and giving its approval. Fur-
thermore, weaknesses in the set-up of Member States’ 
Management and Control Systems were not identified 
early enough by the Commission and serious failures 
by Certifying and Audit Authorities persist in one Mem-
ber State.

VII.
The Court recommends that:

(a)  The legislator should simplify the programming 
arrangements with single national programmes 
to cover the whole period.

(b)  In establishing management and control systems, 
the Commission and Member States should give 
due  consideration  to  propor tionality  with  the 
amount of funds involved and the impact on re-
sources, as well as drawing on previous experience 
in similar funds.

(c)  The Commission should carry out a comprehen -
sive assessment of needs for integration regardless 
of whether migrants have EU or third-country na-
tionality. Based on this assessment, an appropriate 
fund(s) structure should be designed which ends 
the  separation  of  the  target  population  on  the 
basis of nationality and which is oriented towards 
the needs of the final beneficiaries. Setting an ob-
ligatory priority to fund third-country nationals 
would ensure that they receive the necessary spe-
cific attention.

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INTRODUCTION

8

1  Citizens from countries 
outside the European Union 
(non-EU citizens).

2  Common Basic Principles 
for Immigrant Integration 
Policy in the European Union 
adopted by the Council and 
the Representatives of the 
Governments of the Member 
States on 19 November 2004.

3  Then the ‘European 
Community’.

4  Council conclusions 
establishing the Common 
Basic Principles for Immigrant 
Integration Policy, recital 4.

5  Stockholm Programme 
2009, Common Agenda 2011, 
Council Conclusions on the 
Common Agenda 2011, 
EU 2020 strategy. 

1. 

2. 

3. 

Integration of third-country nationals1 is high on the political agenda of 
the Member States and, during the last decade, the EU has considerably 
increased its activities in this area. Though there is no formal definition 
of integration for the EU, the ‘Common basic principles for immigrant 
integration policy’ interpret integration as ‘a dynamic, two-way process 
of mutual accommodation by all immigrants and residents of Member 
States’ based on ’the respect of the basic values of the European Union’ 2. 
The common basic principles identify the following as key ingredients 
for integration: employment, knowledge of the host society’s language 
and culture, education, equal access to goods and services as well as 
political participation.

Integration policy has evolved as a part of immigration policy which, 
being at the very heart of state sovereignty, for a long time remained 
largely within the competence of individual Member States. With the 
coming into force of the Amsterdam Treaty in 1999, the European Un-
ion3 gained competence in immigration matters and committed itself to 
develop ‘an area of freedom, security and justice’. The Tampere European 
Council in 1999 concluded that the EU ‘must ensure fair treatment of 
third-country nationals who reside legally on the territory of its Member 
States’, calling for a ‘more vigorous integration policy’ to grant rights 
and obligations to third-country nationals comparable with those of EU 
citizens. 

While integration policy remains a national competence, the Member 
States recognise that the ‘failure of an individual Member State to de-
velop and implement a successful integration policy can have in different 
ways adverse implications for other Member States and the European 
Union’ 4. In addition, successful integration is seen as crucial for economic 
and social cohesion in the EU as well as for realising the full positive po-
tential of migration in building a competitive and sustainable economy 5.

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4. 

The EU’s contribution towards establishing a ‘coherent European frame-
work  on  integration  of  third-countr y  nationals’ 6  takes  broadly  three 
forms. Firstly, the EU develops the legislative/normative framework with 
the  adoption  of  legally  binding  and  non-binding  instruments  in  the 
area7. Secondly, it facilitates the exchange of good practices between 
Member States through networks and handbooks8. Thirdly, the EU sup-
ports integration through financial instruments, specifically, the ‘General 
Programme on Solidarity and Management of Migration Flows for the 
period 2007–13’ (SOLID programme, see Table).

9

6  COM(2005) 389 final 
of 1 September 2005 — 
A Common Agenda for 
Integration — Framework 
for the Integration of Third-
Country Nationals in the 
European Union.

7  The Common Basic 
Principles taking the form of 
non-binding guidelines.

8  Examples are the National 
Contact Points on Integration, 
the European Integration 
Forum, the Handbooks on 
Integration. 

TABLE

SOLID PROGRAMME FUNDS, 2007–13

Financial instrument

Implementation

EU funds (million euro)

European Integration Fund (EIF)

European Refugee Fund (ERF)

External Borders Fund (EBF)

European Return Fund (RF)

Total

2007–13

2008–13

2007–13

2008–13

Note: Detail may not sum to totals because of rounding.  
Source: European Commission.

830

623

1 908

681

4 043

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10

5. 

The SOLID programme aims to improve management of migratory flows 
at the level of the European Union and to strengthen solidarity between 
Member States. It shares the financial burden resulting from the inte -
grated management of common external borders and the implementa-
tion of common policies on asylum and immigration. The programme 
is composed of four Funds: the External Borders Fund, the European 
Return Fund, the European Refugee Fund and the European Fund for 
the Integration of third-country nationals. Figure 1 shows the 2010 EIF 
commitments by Member State.

FIGURE 1

2010 EIF COMMITMENTS BY MEMBER STATE

Source: EIF allocation calculation, 2010.

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11

6. 

7. 

8. 

WHO DO THE EIF AND ERF SUPPORT?

Two of the programme’s four Funds concern integration. The European 
Integration Fund (EIF) supports Member States in facilitating the social, 
civic and cultural integration of third-country nationals into European 
societies (see Box 1)9. According to its legal base, the Fund should focus 
primarily on the integration of newly arrived third-country nationals.

The European Refugee Fund (ERF) targets asylum policy support and aims 
to reinforce the efforts made by the Member States in receiving refugees 
and displaced persons, including integration measures (see Box 2)10. 

Both the EIF and ERF provide financing of 50 % of eligible project costs 
and  up  to  75 %  in  specific  cases,  the  remainder  being  funded  from  
national sources.

9  Council Decision 
2007/435/EC of 25 June 2007 
establishing the European 
Fund for the Integration of 
third-country nationals for 
the period 2007 to 2013 
as part of the General 
programme Solidarity and 
Management of Migration 
Flows 2007/435/EC  
(‘EIF Decision’) (OJ L 168, 
28.6.2007, p. 18). Commission 
Decision 2008/457/EC of 
5 March 2008 laying down 
rules for the implementation 
of Council Decision 
2007/435/EC (OJ L 167, 
27.6.2008, p. 69).

10  Decision No 573/2007/EC of the European Parliament and of the Council of 23 May 2007 establishing the European Refugee Fund 
for the period 2008 to 2013 as part of the General programme Solidarity and Management of Migration Flows and repealing Council 
Decision 2004/904/EC (‘ERF Decision’) (OJ L 144, 6.6.2007, p. 1). Commission Decision 2008/22/EC of 19 December 2007 laying down rules for 
the implementation of Decision No 573/2007/EC (OJ L 7, 10.1.2008, p. 1).

EIF project addressing third-country nationals, implemented by Poradna pro integraci 
(Counselling Centre for Integration), Czech Republic

©  Poradna pro integraci.  

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BOX 1

OBJECTIVES OF THE EUROPEAN INTEGRATION FUND 
(ARTICLE 3 OF EIF DECISION) 

The EIF can support: 

(a)  development and implementation of admission procedures supportive of the integration process;

(b)  development  and  implementation  of  the  integration  process  of  newly  arrived  third-countr y 

nationals;

(c)  increase of the Member States’ capacity to develop, implement, monitor and evaluate policies and 

measures for the integration of third-country nationals;

(d)  exchange of information, best practices and cooperation in and between Member States.

BOX 2

ELIGIBLE INTEGRATION ACTIONS FOR THE EUROPEAN REFUGEE FUND 
(ARTICLE 3 OF ERF DECISION)

The ERF can, amongst others, support actions relating to the integration of persons referred to in 
Article 6 (refugees, persons under subsidiary protection, asylum seekers), whose stay in a particular 
Member State is of a lasting and stable nature. 

These may include:

(a)  advice and assistance in areas such as housing, means of subsistence, integration into the labour 

market, medical, psychological and social care;

(b)  actions enabling persons to adapt to the society of the Member State in socio-cultural terms, and 

to share the values enshrined in the Charter of Fundamental Rights of the European Union;

(c)  actions to promote durable and sustainable participation in civil and cultural life;

(d)  measures focusing on education, vocational training, or recognition of qualifications and diplomas;

(e)  actions designed to promote self-empowerment and self-sufficiency;

(f )  actions that promote meaningful contact and constructive dialogue with the receiving society;

(g)  measures to support the acquisition of skills, including language training;

(h)  actions that promote both equality of access and equality of outcomes in relation to dealings with 

public institutions. 

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9. 

The European Integration Fund targets the integration of third-country 
nationals, i.e. non-EU citizens. In 2010, 32,5 million non-nationals (i.e. 
persons who are not citizens of their country of residence) were living 
in the territory of the EU, representing 6,5 % of the total EU population. 
Of these (see Figure 2), 20,2 million were third-country nationals, poten-
tially eligible for EIF or ERF, and 12,3 million were EU nationals residing 
in a Member State other than that where they hold citizenship 11. EU 
nationals are not eligible for EIF or ERF but may potentially be targeted 
by other EU funds such as the ESF.

11  Eurostat, Statistics in 
Focus 34/2011.

FIGURE 2

FOREIGN RESIDENTS OF THE EUROPEAN UNION, 2010

Foreign residents of EU MS — 32,5 million

Third-country nationals — 20,2 million

Total  
EU inhabitants

501 million

EIF target group

Economic, study  
and research migrants

Family migrants

18,6 million

EU nationals
living in another MS

12,3 million

ERF  
target  
group

Refugees, 
subsidiary 
and 
temporary 
protection

1,4 million

Asylum 
seekers

0,3 million

Note: Data for Refugees and Asylum seekers from 2009. Detail may not sum to totals because of rounding. 
Source: Eurostat, UNHCR. 

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14

The distribution of third-country nationals varies across the Member 
States, as shown in Figure 3.

Third-country nationals or stateless persons who have applied for asylum 
(asylum seekers) or who have been granted refugee status or subsidiary 
protection status are excluded from the EIF but are within the target 
group of the European Refugee Fund 12. During 2010, 258  940 asylum 
applications were registered in the EU13. 

12  The target group of 
the ERF also concerns 
‘resettlements’ (persons who 
have been transferred from 
a third country to an EU 
Member State). 

13  Eurostat, Statistics in 
Focus 48/2011.

10. 

11. 

FIGURE 3

THIRD-COUNTRY NATIONALS, AS PERCENTAGE OF NATIONAL POPULATION AND 
ABSOLUTE NUMBERS, 2010

Source: Eurostat and Home Affairs DG EIF allocation calculation.

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12. 

13. 

14. 

15. 

16. 

15

ROLES AND RESPONSIBILITIES

The management and control provisions are the same for the four SOLID 
funds and are implemented through shared management. According to 
this principle, the Member States are responsible for the implementation 
(operational and financial) of the funded actions while the Commission 
remains responsible for the overall budget execution. For the use of 
each Fund, the Commission adopts strategic guidelines setting out the 
EU programming framework. Each participating Member State prepares 
a multi-annual programme applying these strategic guidelines in the 
context of its own needs.

14  For EIF, responsibilities 
laid out in Article 25 of 
Decision 2007/435/EC.

15  For EIF, responsibilities 
laid out in Article 28 of 
Decision 2007/435/EC.

16  For EIF, responsibilities 
laid out in Article 27 of 
Decision 2007/435/EC.

The  multi-annual  programme  is  implemented  through  annual  pro-
grammes.  Both  of  these  are  subject  to  the  Commission’s  approval. 
Member States submit final reports after the completion of each annual 
programme.

The Commission is also responsible for ensuring that the Member States 
have set up adequate Management and Control Systems (MCS), that ap-
propriate information, publicity and follow-up is provided for the funded 
projects and that actions are consistent with, and complementary to, 
other relevant Union policies and initiatives.

Member  States’  implementation  is  followed  up  by  the  Commission 
through desk-reviews of management and control systems descriptions, 
through receipt of progress and final reports and by audit and monitor-
ing visits to Member States.

At the level of the Member States, the management and control system 
(see Figure 5) comprises:

(a) 

The Responsible Authority (RA), responsible for managing and im-
plementing the multi-annual programme. In particular, it submits 
multi-annual and annual programmes to the Commission, selects 
operations and verifies the eligibility of the expenditure claimed 
by the final beneficiaries.14

(b)  The Audit Authority (AA) performs audits to verify the functioning 

of the management and control systems.15

(c) 

The Certifying Authority (CA) certifies that the expenditure declared 
complies with the applicable rules.16

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AUDIT SCOPE AND APPROACH

16

17. 

The overall objective and main audit question was to assess whether, 
through the EIF and ERF, the SOLID programme contributes effectively 
to the integration of third-country nationals. The main audit question 
was broken down into the following sub-questions:

17  MIPEX (Migrant Integration 
Policy Index) measures the 
development of legislation 
to integrate migrants in EU 
Member States and selected 
non-EU countries.

(a)  Are the SOLID funds’ results backed up by effective monitoring and 

evaluation of the programme?

(b)  Did the design of the Funds contribute to effective implementation 

of the Funds?

(c)  Are the systems for implementing integration measures within the 

SOLID programme well managed?

18. 

The audit focused on the management and control systems of the Com-
mission and the Member States under the 2007–13 Solidarity and Migra-
tion framework for both the EIF and the ERF. The assessment of results 
is primarily based on the annual programmes already completed at the 
start of the audit (Annual Programmes of 2007  and  2008). The audit did 
not  per form  a  direct  assessment  on  the  effectiveness  of  integration 
measures in Member States.

19. 

The audit was based on:

(a) 

(b) 

a review of documents on the preparation for, implementation and 
evaluation of the SOLID funds at the Commission and interviews 
with Commission officials from the Home Affairs DG and, for infor-
mation purposes, the Employment, Social Affairs and Inclusion DG,

the audit of selected aspects of the management and control sys-
tem of EIF and ERF in five Member States (Czech Republic, Ger-
many, Luxembourg, Portugal, United Kingdom) including interviews 
with Responsible Authorities, Audit Authorities and Certifying Au-
thorities. The selection of these Member States was based on the 
number and proportion of third-country nationals, the share of EIF 
commitments and the development of integration legislation as 
measured in the MIPEX17,

(c)  on-the-spot visits to 22 completed projects in the selected Mem-
ber States of the 2007 (EIF), 2008  and  2009 (ERF and EIF) annual 
programmes based on a  judgmental (non-statistical) sample (see 
the Annex), 

(d)  a review of the Commission’s legislative proposals on the Asylum 
and Migration Fund and the corresponding general provisions for 
the 2014–20 period.

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OBSERVATIONS

17

INDIVIDUAL PROJECTS SUCCESSFUL BUT 
THE FUNDS’ OVERALL CONTRIBUTION TO THE 
INTEGRATION OF THIRD-COUNTRY NATIONALS 
COULD NOT BE MEASURED

The Funds’ overall contribution to the integration of third-country na-
tionals cannot be measured beyond results at project level. This is due 
to the lack of a proper monitoring and evaluation system in the audited 
Member States and at the Commission. The lack of measurable indica-
tors or quantified targets in the programming documents made it im-
possible to measure results. The weaknesses of the intermediate report 
on the results achieved and on qualitative and quantitative aspects of 
implementation of the Fund18 meant that it was of limited value to assess 
the Funds’ effectiveness. The implementation rates of the programmes 
in 2007 and 2008 were low yet the projects audited clearly contributed 
towards the integration of third-country nationals.

18  Article 48.3(b) of the EIF 
Council Decision refers to 
the ‘intermediate report on 
the results achieved and on 
qualitative and quantitative 
aspects of implementation 
of the Fund’ to be produced 
by the Commission. This is 
hereafter referred to as the 
‘intermediate report’.

The Court examined, for five Member States (see paragraph 19), the EIF 
and ERF multi-annual programmes, the annual programmes for 2007, 
2008 and 2011  and  final  reports  for  completed  annual  programmes. 
Twenty-two finalised projects in these countries were visited and au-
dited on the spot (see the Annex).

In order to evaluate the success of integration actions undertaken with-
in the SOLID funds, the Court examined whether annual programmes 
included  SMART  objectives  suppor ted  by  measurable  indicators.  It 
sought to identify the extent to which individual projects and annual 
programmes contributed to the multi-annual programmes and whether 
reporting at project and programme level was made against the indica-
tors and targets set. 

To  support  effective  steering  of  the  programme,  Member  States  are 
obliged to submit evaluation reports, which the Commission uses to 
compile an intermediate report for the European Parliament and the 
Council on results achieved and qualitative and quantitative aspects in 
the implementation of the Funds.

20. 

21. 

22. 

23. 

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EIF project implemented by Association de Soutien aux Travailleurs Immigrés (ASTI) 
(Association for Support to Immigrant Workers), Luxembourg

©  European Commission.

AUDITED MEMBER STATES DID NOT SET SUFFICIENTLY QUANTIFIED 
TARGETS AND INDICATORS …

Though Member States were required to complete a section in the An -
nual Programmes (APs) titled ‘Quantifiable results’, measurable targets 
were only specified for around half of the actions examined in the APs 
of the five Member States. This was not detected or corrected by the 
Commission  (see  paragraphs  67  to  69).  Furthermore,  the  majority  of 
the targets set pertained only to the number of projects or participants 
instead of also measuring more specific aspects of projects, such as the 
success rate in obtaining qualifications. 

19  Document presented 
to SOLID committee, 
SOLID/2007/27.

The Court recognises that integration is a difficult concept to measure, 
and particularly when attempting to assess the impact of specific instru-
ments. However, the Commission has demonstrated19 that it is possible 
to define indicators relating to the output and outcomes of funded ac-
tions. Examples of indicators used by the audited Member States are set 
out in Box 3. 

24. 

25. 

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BOX 3

EXAMPLES OF INDICATORS USED IN THE AUDITED PROGRAMMES

Good example 1: Measurable output indicator with target value and reference to the 
current situation

 ο Objective of the measure: Development and organisation of educational activities targeted to 

third-country nationals (language courses, civic courses …).

 ο Output indicator: Number and categories of third-country nationals participating. 

 ο Target: 300 third-country national participants (total 2007–13).

 ο Baseline situation: No pre-existing courses.

Good example 2: Measurable outcome indicators related to the above measure

 ο Outcome Indicator:

 — Number of third-country nationals satisfied with the activities. 

 — Number of third-country nationals successfully completing the activities.

Poor example: Two output indicators which are not clearly defined, potentially overlapping 
and therefore not measurable

 ο Objective of the measure: Creation of meeting places between immigrants and host society 

(intercultural exchanges, awareness-raising activities).

 ο Output indicator: Number and type of discussions/subjects discussed classified as ‘subjects which 

are more superficial’ versus ‘subjects which are more personal’.

 ο Output indicator: Number of participants and classification of participants: ‘parents and children’, 

‘youth and children’. 

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26. 

27. 

In the Final Reports, the audited Member States often included quantifi-
able outputs but only in a few cases had targets been set against which 
success  could  be  evaluated.  Even  where  projects  were  satisfactorily 
evaluated in these final reports, this did not always give a full picture 
of the progress towards fulfilling annual and multi-annual programme 
objectives.

20  Article 48 of 
Decision 2007/435/EC.

Due to these weaknesses in programming and reporting at national level, 
no clear assessment of results can be performed. Neither Member States 
nor the Commission are able to judge the effectiveness of the Funds in 
attaining their objectives. Results can only be established at project level, 
and even then, only where clear targets and indicators have been set.

… AND THE COMMISSION’S EIF INTERMEDIATE REPORT PRESENTED 
ONLY LIMITED INFORMATION

28. 

According to the legislation, the intermediate report should be submit-
ted  by  the  Commission  to  the  European  Parliament  and  the  Council 
by 31 December 2010 20. This was only done almost one year later, on 
5 December 2011, due to: 

(a) 

the late or incomplete submission by Member States of final reports 
on annual programmes; and 

(b) 

the unrealistic timetable set out in the legislation.

29. 

The  intermediate  report  contains  no  quantitative  results  of  the  pro-
grammes beyond the number of projects funded in each Member State 
and how many Member States have funded projects for each priority. 
The table in the report which, according to the title, purports to show 
which types of operations were actually funded has several weaknesses: 

(a) 

it is only based on plans rather than actual implementation; 

(b) 

it does not include any indication of amounts spent; and 

(c) 

it contains specific inaccuracies (for example, a project preparing 
individuals  for  migration  to  Germany  was  obser ved  during  the 
Court’s audit but no actions of this type were recorded in the table). 

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21  Section 7.5 of the 
intermediate report.

30. 

31. 

32. 

The absence of adequate quantified results in the intermediate report 
is at least partially due to the absence of obligatory common indica-
tors which would make results comparable between Member States. In 
preparation for the upcoming ex post evaluation, the Commission is now 
addressing the lack of comparable data by requesting Member States to 
provide information on basic common indicators. However, since these 
indicators were not established in advance and collected during im-
plementation, the validity and usefulness of the evaluation is limited 
and the compilation process becomes inefficient. In its proposal for the 
period 2014–20, the Commission has proposed the development of an 
obligatory set of common indicators from the start of the programme.

In the intermediate report, examples of projects are given to illustrate 
the types of activities undertaken, but there is no indication of their 
representativity in terms of frequency or value.

Despite  the  fact  that  Member  States  supposedly  set  their  own  pro -
grammes according to identified needs and objectives, two Member 
States (the Netherlands and Poland) stated21 that their programmes were 
not relevant for them. Poland explained that the programmes were too 
narrow and the Netherlands reported that ‘the Fund’s allocation repre-
sented a relatively small proportion of the national budget for integra -
tion and was not seen as adding real value to national strategies.’ This 
statement has not been challenged or critically evaluated in the report 
by the Commission.

33. 

These weaknesses in the intermediate report mean that it provides only 
a very limited contribution to the assessment of results or to the steering 
of the Funds.

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22  Rates calculated based 
on the amount claimed by 
Member States.

THE LOW RATE OF IMPLEMENTATION DURING THE FIRST TWO YEARS 
REDUCES THE POTENTIAL EFFECTIVENESS OF THE FUNDS …

34. 

Figure 4 shows that the rate of EIF budget implementation22 in Member 
States for the years 2007 and 2008 (the only years for which programmes 
had been completed at the time of the audit) was generally low although 
from 2007 to 2008 the total implementation rate for all Member States 
increased from 66 % to 77 % in the second year. The data shows great 
variation among Member States ranging (for 2007) from 15 % (Czech 
Republic) to 100 % (France). Most of the Member States with very low 
implementation rates in 2007 improved in 2008, but only one of them 
climbed above the 50 % mark. Despite the overall improvements, seven 
countries showed a decrease in implementation from 2007  to 2008. By 
June 2012, the Commission had still not received the Member States’ cost 
claims for six APs (one for the 2007 APs: Malta, and five for the 2008 APs 
Greece, Spain, Malta, Netherlands and the United Kingdom). These were 
due for 30 September 2010 (2007 APs) and 31 March 2011 (2008 APs).

35. 

Contributing factors for this low take-up rate are presented in later ob-
servations (paragraphs 42 to 75). Under-implementation of the budgeted 
plans of annual programmes risks that the planned outputs and impacts 
are not achieved.

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FIGURE 4

EIF BUDGET IMPLEMENTATION

Source: European Commission and Court calculations. 

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… BUT THE AUDITED PROJECTS ACHIEVED POSITIVE RESULTS AND 
FUNDS WERE CONSIDERED BY MEMBER STATES TO BE VALUABLE FOR 
INTEGRATION

Due to the lack of quantified targets and indicators and the weaknesses 
in the intermediate report, the Court was only able to seek evidence of 
the effectiveness of the ERF and EIF by visiting projects. 

Of the 22 projects which were audited on the spot, 18 were judged by 
the Court to have achieved results which contributed positively to the 
integration of third-country nationals in so far as they formed part of 
the Member States’ strategies (see Box 4).

36. 

37. 

BOX 4

EXAMPLES OF PROJECTS ACHIEVING POSITIVE RESULTS

The Luxembourg EIF supported the project ‘Partenariats pour l’intégration interculturelle: mise en place de services 
d’information et d’orientation’ (‘Partnerships for intercultural integration: Setting up of Information and orienta-
tion services’). The project was carried out by the Association de Soutien aux Travailleurs Immigrés (Association for 
Support to Immigrant Workers) (ASTI) and aimed to improve the integration of third-country nationals by giving 
equal access to information concerning the rights and obligations of citizens. Activities included the establish-
ment of a partnership with different associations, the development of a website (http://www.bienvenue.lu) and 
an interpretation service. The co-financing by the EIF was 50 % or 112 000 euro from the 2009 Annual Programme. 

In Germany, the ERF supported the project ‘…und drin bist Du? Flüchtlinge als Teil der Gesellschaft — auf dem 
Weg in ein selbstbestimmtes Leben’ (‘… Are you in? Refugees as part of society — on the way to a self-determined 
life’). The three-year project, carried out by the Caritasverband für das Erzbistum Berlin e.V. (Caritas, Archdiocese 
of Berlin), was supported in its first year by 42 509  euro from the ERF Annual Programme 2009 (50 % co-financ -
ing rate). It aimed to improve reception conditions for asylum seekers/refugees and strengthen services and 
structures in Eastern Brandenburg. A total of 683 people participated in the project’s activities such as German 
courses or intercultural staff training. 

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38. 

39. 

40. 

Of the four audited projects which did not achieve their objectives, two 
of the projects were completed after downward revision of the goals to 
be achieved, while one potentially useful and innovative project failed, 
in part, due to the unrealistic targets and methodology approved by the 
Responsible Authority in the application (see Box 5). 

However, there is no direct link between the fulfilment of individual 
projects and the attainment of overall success, due to the inadequate 
target-setting at programme level, lack of associated quantified results 
and budget under-implementation.

According to the Commission’s intermediate report, most Member States 
perceive the EIF as providing ‘value-added’ despite the difficulties in 
implementation. Where Member States had a less developed integration 
policy framework, the Fund enabled the design of a comprehensive inte -
gration framework. For some Member States it filled the gap in national 
resources or provided the opportunity to expand support to specific 
target groups. In addition, the intermediate report found increased co-
operation between authorities within and between Member States.

BOX 5

EXAMPLE OF A FAILED PROJECT

In the UK, the ERF supported a project which did not succeed. The Merseyside Fire and Rescue Service  (MFRS) 
made an innovative application to address the high fire-risks identified in the refugee population, by way 
of home checks (800 dwellings), work placements in the fire service, website development, leaflets in over 
30 languages and the education of landlords. The project’s first year was to be supported by an ERF grant of 
21 325  euro. Several control stages failed at the Responsible Authority. The target of 800 home checks turned 
out to be unrealistic as the underlying refugee population was much smaller than had been assumed and the 
addresses of the target population could not be obtained by the MFRS. The Responsible Authority started to 
address the unrealistic assumptions and targets of the project only after the funding was granted and planned 
monitoring visits to the project did not take place in time. Furthermore, the Responsible Authority demanded, 
in contrast to Commission guidance on the matter, that the MFRS collect proof of the refugees’ status. This 
reduced the willingness of the target population to accept MFRS checks even further. As a result, only 60 home 
checks were funded and the project was abandoned after its first year.

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41. 

The above evaluation results are, at least in part, supported by evidence 
collected during the Court’s audit. The audited Member States reported 
that the Funds enabled them to undertake additional or new integration 
activities. 

42. 

43. 

THE EFFECTIVENESS OF THE FUNDS’ CONTRIBUTION 
TO INTEGRATION IS LIKELY TO BE LIMITED 
BECAUSE …

The previous section shows that the effectiveness of the Funds to date 
cannot be measured. The next two sections will explain that the poten-
tial of the Funds to be effective is limited by weaknesses in design and 
implementation. As a result, the Funds are unlikely to be fully effective 
in their contribution to the integration of third-country nationals.

The Court assessed whether the legal and administrative set-up of the 
SOLID funds enabled effective management with a reasonable level of 
administration and control. It examined whether the integration needs 
of Member States had been identified via a satisfactory consultation 
process and Impact Assessment. The audit verified whether there was 
a coherent and coordinated approach with other Union instruments. 

EIF Project implemented by Türkische Gemeinde in Deutschland e.V. (TGD) 
(Turkish Community in Germany)

©  Vorintegrationsprojekt Türkische Gemeinde in Deutschland e.V.

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… THE SPLIT OF INTEGRATION MEASURES BETWEEN ERF AND EIF 
CAUSES PRACTICAL DIFFICULTIES

44. 

In four of the five Member States visited, the Responsible Authority (see 
Box 6) and the final beneficiaries experienced practical difficulties in 
separating ERF and EIF target groups, particularly with regard to ‘integra-
tion measures’, because:

 ο

 ο

certain activities would normally be jointly geared towards the ERF and the 
EIF target groups since they have similar needs, e.g. language courses or 
intercultural activities,

there is an administrative burden associated with the allocation of costs to 
different Funds (ERF and EIF) for the same activity (for example, a language 
course). This deters Member States’ authorities and final beneficiaries from 
designing activities which meet their needs efficiently. 

ANNUAL PROGRAMMING LEADS TO EXCESSIVE ADMINISTRATION …

45. 

The four SOLID funds have a system of annual programming and report -
ing by the Member States. Consequently, every year, the Commission 
receives around 100 annual programmes for the four SOLID funds to 
review and approve. In addition, a final report for each completed annual 
programme must also be submitted by the Member States and validated 
by the Commission. Little or no added value is produced by this exercise. 
The process places excessive administrative burden on both the Member 
States authorities and the Commission. The impact of such a system was 
not adequately considered when the SOLID programme was set up. 

BOX 6

EIF VERSUS ERF

For the UK Responsible Authority (UK), ‘the requirement to separate different categories of migrants acts in 
direct contradiction to the notions of integration, appreciation of diversity and community cohesion’, it ‘creates 
confusion and is overly complex in terms of project administration and management, because costs have to 
be separated and allocated. A “mixed group” including EU citizens should be possible’ as this ‘would encourage 
more participative and innovative project proposals, which are likely to be more effective in terms of integra-
tion outcomes’.

The Czech Responsible Authority considered the split between ERF and EIF to be artificial in certain cases, 
in particular with regard to the regional integration centres funded under EIF. These centres could provide 
help and training to both third-country nationals and asylum seekers/refugees. According to the Responsible 
Authority, they have to duplicate their activities which is especially inefficient when the target groups are small. 

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Member States and the Commission are now advocating the use of only 
multi-annual programmes. In addition, the Commission pointed out that 
some Member States made inferences from the annual programming 
cycle which had not been intended, such as the idea that projects could 
only last for one annual programme.

23  Court of Auditors Opinion 
No 7/2011 (OJ C 47,17.2.2012, 
p. 1).

In line with the findings of this audit and with the outcome of a  public 
consultation, the Commission proposes to change the system for the 
period  2014–20  into  a single  national  programme  per  fund  to  cover 
the whole financial period. This would mean having fewer than 60 pro-
grammes to cover both the Asylum and Migration Fund (AMF) and In-
ternal Security Fund (ISF) over the entire period. 

… AND THERE ARE BURDENSOME FINANCING ARRANGEMENTS 

When Member States have spent 60 % of the initial pre-financing pay -
ment, they are entitled to apply for a second payment. However, the leg -
islation was not clearly drafted which led to confusion amongst Member 
States. The procedures for applying and obtaining this second payment 
are burdensome and dissuade Responsible Authorities from applying. 
This, in turn, has delayed payments made by the Responsible Authority 
and led to cash flow problems for final beneficiaries.

THE DESIGN INTRODUCED A LONG CHAIN OF CONTROLS AND SOME 
MEMBER STATES HAVE ADDED TO THIS ADMINISTRATIVE BURDEN …

Checks performed by the three authorities (Responsible Authority, Certi-
fying Authority, Audit Authority) duplicated rather than complemented 
each other. While checks and balances are needed in every funding sys-
tem, the SOLID configuration is based on the Structural Funds model23 
and causes a disproportionate burden given the  relatively  low sums 
involved (see paragraph 54). The current system is a drain on Commis -
sion and national resources. 

46. 

47. 

48. 

49. 

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50. 

51. 

52. 

Although Member States’ authorities audited by the Court complained 
that the administrative structure inflicted an unnecessary burden on 
the Funds’ management, two of the five Member States audited made 
matters worse by carrying out disproportionately high levels of checks 
on beneficiaries. In the UK, the Responsible Authority has established 
a rigorous monitoring system featuring elements which promote good 
project implementation (see Box 8), but at the same time makes addi-
tional control demands including monthly reporting, 100 % verifications 
by the Responsible Authority, ex post audits by the Audit Authority and 
excessive requirements on project beneficiaries to prove eligibility of 
participants (see Box 5). In Germany, partly due to the lack of a  suit-
able data management system, the Certifying Authority had to compile 
information on every project by assessing all final reports before it was 
able to make a selection for further checks. 

24  An ex ante assessment 
involves an evaluation of the 
conditions for the launch of 
a programme or institution.

25  The EIF proposal only 
focused on legally residing 
third-county nationals as it 
was founded on the legal 
basis for immigration policy.

Weaknesses such as the lack of indicators, programme annuality and the 
hierarchy between Member State authorities (see paragraph 70) could 
have been avoided had the experiences from Structural Fund manage-
ment been better taken into account in the design of the EIF and ERF. 
Neither the audited Member States nor the Commission capitalised on 
their previous experiences in the Structural Funds. 

… AND THE INSUFFICIENT COHERENCE AND COMPLEMENTARITY WITH 
OTHER EU FUNDS LED TO OVERLAPS AND LOSS OF SYNERGIES

The  Commission  per formed  only  a  limited  ex ante  assessment 24  and 
stakeholder consultation on integration needs in the EU for the prepa-
ration of its legislative proposal. No overall strategy on how to address 
the EU’s integration needs was developed. As a result, opportunities were 
missed to strengthen the quality of the proposal25.

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26  European Commission, DG 
Home Affairs (2011), Impact 
assessment study on the Multi-
annual Financial Framework 
(MFF) in the area of Home 
Affairs, study undertaken by 
GHK.

27  The European Social Fund: 
migrants and minorities, 2010 
(http://ec.europa.eu/esf ).

53. 

Outside the SOLID programme, there are other Union instruments which 
support similar actions that may contribute to the integration of third-
country nationals. These include: 

(a) 

European  Social Fund (ESF)  — aims  to prevent and combat un-
employment and develop human resources and social integration 
into the labour market. It funds programmes for the integration of 
migrants regardless of their citizenship, in particular ‘to increase the 
participation of migrants in employment and thereby strengthen 
their social integration’.

(b)  Education and Culture DG’s programmes  — activities under the 
2007–13  Culture  Programme  and  the  2007–13  Citizenship  Pro-
gramme may include projects related to inter-cultural dialog, active 
citizenship, etc. The 2007–13 Lifelong Learning Programme includes 
the  priority  to ‘promote  social  inclusion  and  gender  equality  in 
education and training, including the integration of migrants and 
Roma’.

(c)  Research Framework Programmes  — have been used to fund re-
search in relation to migrant issues by developing new knowledge, 
tools, indicators and databases to support European migration pol-
icy, in particular for the labour market, social welfare, social cohe-
sion and the fight against various forms of discrimination.

54. 

In its preparatory work, the Commission did not take the Education and 
Culture DG or Research Framework programmes into account. Although 
the Commission’s ex ante  assessment identified the ESF as comprising rel-
evant actions, the full extent of the overlap with EIF remained unknown. 
There are no specific data available to judge the extent to which the ESF 
supports the integration of third-country nationals. The Commission es-
timates that during 2007–13, 1,17 billion euro from the ESF is budgeted 
for ‘Increasing migrants’ participation in employment’ 26. The ESF also 
finances social inclusion measures which can support the integration 
of migrants so at least part of the 9,98  billion euro budgeted for this is 
relevant for integration of third-country nationals 27. The Commission did 
not identify this in its ex ante assessment for the SOLID programmes or 
for the period 2014–20. The ESF’s financing of integration-related issues 
is therefore far larger than the EIF (830 million euro for 2007–13) and the 
ERF (623 million euro for 2008–13) combined.

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55. 

56. 

The Commission intended the EIF to be complementary to the ESF, sup-
porting actions that could not be funded by the latter28. Third-country 
nationals do not have the same legal rights as EU citizens and this was 
given as justification for separate treatment under different funds. How-
ever, the audit showed that most, if not all, EIF measures could be funded 
under ESF. For the Member States authorities and final beneficiaries, 
the separation between ESF and EIF causes an additional bureaucratic 
burden, in particular, because these funds have different administrative 
structures (see Figure 5) and requirements.

28  COM(2005) 123 final of 
6 April 2005 — Proposal 
for a Council Decision 
establishing the European 
Fund for the Integration of 
Third-country nationals for 
the period 2007–13 as part 
of the General programme 
‘Solidarity and Management 
of Migration Flows’.

29  Recital 12 of Decision 
2007/435/EC.

The EIF’s design problems are increased by the limited functioning of the 
systems set up to ensure coherence and complementarity. During the 
adoption process of the ESF and EIF programmes, the Commission did 
not place enough emphasis on the complementarity of the two funds. 
Whilst the coordination between the Employment, Social Affairs and 
Inclusion DG and the Home Affairs DG has improved in recent years, in 
three out of the five Member States audited, the obligatory coordination 
mechanism29 between EIF and ESF was not in place, was inadequate, or 
had only recently been established despite their assertions that they had 
done so at the outset. The Commission failed to identify this problem in 
its assessment of the EIF Management and Control System. 

57. 

As a result of the absence of coherence in design and implementation, 
there are significant overlaps between EIF and ESF, with the ESF support-
ing the integration of third-country nationals with significantly larger 
amounts. These overlaps cause additional costs (e.g. staff costs) and 
potential synergies are lost (See Box 7). 

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58. 

59. 

Whilst  the  new  proposal  for  2014–20  opens  up  the  target  group  for 
local and regional integration measures to EU citizens with a migrant 
background (persons having at least one parent who is a third-country 
national) it does not deal with the underlying problem of overlap with 
the ESF. 

Without a  dedicated component in the ESF or a  separate integration 
fund founded on both the ESF and the EIF legal bases, integration needs 
cannot be comprehensively addressed.

BOX 7

PORTUGUESE CALL CENTRES AND ACIDI COMPARISON OF EIF AND ESF FUNDING

In Portugal, only two organisations can apply for EIF funding: ‘Alto Comissariado para a Imigração e Diálogo 
Intercultural’ (ACIDI) and the ‘Serviço de Estrangeiros e Fronteiras’ (SEF). ACIDI, a public body integrated into 
the Interior Ministry, is the most important of the two and is the organisation responsible for integration 
of immigrants and minorities in Portugal. During the Court’s on-the-spot visit, the representatives stated 
that ESF and EIF integration funding overlaps. For 2008–11 they received around 18,2  million euro from the 
ESF and 7,4  million  euro from the EIF.30 The activities listed in the ESF Operational Programme could also 
be financed from the EIF programme. One example found by the Court was the financing of two similar 
multilingual call centres. ACIDI’s National Immigrant Support Centre (CNAI) hosts a call centre set up for 
third-country nationals (financed by the ESF). When SEF applied for a call centre to cope with specific third-
country national information, the ACIDI project was not considered and demand for its own call centre fell 
after the opening of that of SEF.

Due to the fact that migrant organisations can apply both to the ESF and for sub-projects of ACIDI, there is 
an increased risk of a lack of coherent approach and double-funding. 

30  Source: ESF Project lists published on the website of the respective ESF Programme, EIF Project information from Responsible 
Authority.

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RESPONSIBLE AUTHORITIES HIGHLY COMMITTED 
BUT DELAYS AT ALL LEVELS AND WEAKNESSES 
IN THE MANAGEMENT AND CONTROL SYSTEM 
MAY FURTHER REDUCE THE PROGRAMMES’ 
EFFECTIVENESS

The  programme  is  implemented  via  the  shared  management  mode 
and,  as  such,  there  are  responsibilities  placed  on  both  the  Commis-
sion and Member States with regard to the principles of sound financial 
management.

31  Article 51 of 
Decision 2007/435/EC.

32  ERF III began in 2008.

The Court examined aspects of the systems in the Commission and Mem-
ber States which are directly relevant to the effectiveness of the Funds.

DELAYS IN THE ADOPTION OF THE LEGISLATION AND IN THE 
COMMISSION AND MEMBER STATES’ CRUCIAL TASKS …

The Council and European Parliament Decision establishing the ERF for 
2008–13 and the Council Decision for the EIF for the period 2007–13 
were not adopted until 23 May 2007 and 25 June 2007 respectively. The 
Commission Decisions laying down the implementing rules were only 
adopted on 19  December  2007 and 5  March  2008. In principle, Annual 
Programmes should be submitted by the Member States by 1 Novem-
ber of year n-1, prior to the programme start. Due to the late adoption 
of the legislation, derogations were given for later submission of the 
2007 and 2008 APs 31. The Commission is required to inform the Member 
States whether the AP can be approved within one month of submission 
and adopt Financing Decisions by 1 March of the year in question.

The auditors examined the AP submission process for five Member States 
concerning 200732, 2008 and 2011. Of the 25 EIF and ERF APs examined, 
only three were submitted by Member States in a timely fashion. Delays 
on the part of the Member States were blamed on the heavy workload 
placed on the Responsible Authorities of the Member States, political 
changes leading to internal reorganisation and, according to the Com-
mission, drafting of over-elaborate programmes.

60. 

61. 

62. 

63. 

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64. 

65. 

66. 

67. 

Furthermore, the Commission did not inform the Member States within 
one month whether the APs could be approved in any of the examined 
cases, nor did it adopt the financing decisions within the time set aside 
in the legislation. The delays were most serious for the 2007 and  2008 
APs, with financing decisions for the 2007 EIF programme taking seven 
months longer to adopt than envisaged in the legislation. For the 2011 
APs, the average delay was two months for EIF and one month for ERF.

… LEADING TO THE COMMISSION ISSUING GUIDANCE LATE TO 
MEMBER STATES

A wide range of guidance has been issued by the Commission, covering 
such topics as eligibility of expenditure and various aspects of the Mem-
ber States’ Management and Control Systems (MCS). In most areas, this 
guidance has been comprehensive and useful for the Member States. In 
addition, the audited Member States reported that responses to queries 
have been effectively dealt with by the Commission.

However, some important guidance has, partly due to the late adoption 
of the legislation, been issued late, including the implementing rules 
(see paragraph 62) and the more detailed ‘eligibility manual’ which was 
issued for the first time in July 2008. Combined with the wait for adop-
tion of financing decisions, this meant that those Member States who 
were able to allocate national funding to start projects on time could not 
inform final beneficiaries on the agreed eligibility rules. Other Member 
States were forced to delay the start of their programmes. Both situations 
contributed to low implementation rates for the Funds in the early years 
of the programme (see paragraph 35).

WEAKNESSES IN MEMBER STATES’ MONITORING SYSTEMS NOT 
DETECTED BY THE COMMISSION

Prior to the start of the programme, Member States were required to 
submit descriptions of their Management and Control Systems to the 
Commission for approval. The Commission later followed this up with 
visits to check systems on the spot in the Member States. The Court 
examined the Commission’s assessment of the MCS with regard to the 
systems for monitoring projects and programmes and made comparisons 
with the systems it audited in the Member States.

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68. 

69. 

70. 

35

The Commission used a scored checklist for the assessment of the MCS. 
For all of the five Member States audited by the Court, the Commission 
approved the MCS and, in particular, maximum scores were given for the 
four criteria pertaining to the monitoring of projects and programmes.

33  SOLID 2010/15/REV.

The Commission’s checklist did not include questions to verify if systems 
were in place for collecting and aggregating the key operational and 
financial indicators. The Court found that in three of the five audited 
Member States, monitoring systems were inadequate, mainly due to the 
lack of appropriate data collection systems for indicators and targets or 
insufficient project monitoring visits. This situation persisted in the latter 
half of 2011 despite the fact that they had been visited by the Commis-
sion. The Commission’s failure to detect this weakness was partly due to 
crucial elements not being included in the checklist. It was compounded 
by the Commission’s acceptance of descriptions which simply amounted 
to Member States’ intentions transposed from the legislation. In the ab-
sence of properly functioning monitoring systems, implementation of 
the 2007–13 programme cannot be evaluated and steered.

PERSISTENT WEAKNESSES AND FAILURES IN CERTIFYING AND AUDIT 
AUTHORITIES 

As in the Structural Funds, the SOLID programme has a three-tier struc -
ture which includes a Responsible (or Managing) Authority and Audit 
and Certifying Authorities. The difference is that under the SOLID struc-
ture, the Certifying Authority is at the top of the assurance model (see 
Figure 5), placing reliance on the work of the Audit Authority, whereas 
in the long-established Structural Funds, it is the opposite. This has led 
to misunderstandings in Member States about the roles and respective 
duties of the Certifying Authority and Audit Authority. The Commission 
did not detect this in its assessment of the Monitoring and Control Sys-
tem and guidance was only provided in October 2010 33. In Germany, the 
lack of a clear relationship between the three authorities contributed to 
delays in reporting of several months for both the 2007  and 2008 Annual 
Programmes, resulting in late payments to final beneficiaries. 

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36

71. 

72. 

The Court’s audit found serious weaknesses in the work of the Certifying 
Authority and Audit Authority in Portugal. The Audit Authority is required 
by the legislation to audit a sample of at least 10 % of the total eligible 
expenditure for each annual programme. The Portuguese Responsible 
Authority contracts out audits to a private body, which it uses as the 
first level control of project cost claims. In contravention to the legisla-
tion, the Audit Authority uses these same audit reports to fulfil its 10 % 
requirement. Although the Audit Authority also carries out its own on-
the-spot project audits, these do not cover all the annual programmes 
and represent less than 10 % of eligible costs.

The ‘Serviço de Estrangeiros e Fronteiras’ (SEF) has been designated as 
the Certifying Authority in Portugal. In the audit for the 2009 Statement 
of Assurance, the Court found serious weaknesses in the certification 
carried out by SEF for the predecessor of ERF III (ERF II). In 2011, the 
Certifying Authority was still failing to fulfil its responsibilities, both in 
terms of the quality of work performed and delays in completing certifi-
cation. The Responsible Authority was already late in submitting reports 
on the execution of final programmes and at the time of the audit, the 
Certifying Authority had exacerbated the situation by failing to issue 
certifications for the 2008 EIF and ERF reports, or the 2009 EIF progress 
report. Furthermore, the time spent on the spot was hastily arranged 
and insufficient to properly conduct the work necessary for the certi-
fication. No evidence could be presented of the work undertaken, but 
the sampling methods described during the Court’s audit were flawed 
and unlikely to lead to reliable results. The Audit Authority has itself is-
sued a qualified opinion on the work of the Certifying Authority. While 
the situation persists, the control obligations of the Funds are not met, 
increasing risks to sound financial management, and leads to cash flow 
problems at beneficiary level.

FIGURE 5

FUND ASSURANCE MODELS

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37

73. 

74. 

THE RESPONSIBLE AUTHORITIES ARE MOSTLY FULFILLING THEIR 
KEY FUNCTIONS DESPITE THE LIMITATIONS IN DESIGN AND 
IMPLEMENTATION 

Responsible Authorities faced difficulties in the early stages of the pro-
gramme due to time pressures arising from delays in the adoption of 
legislation (see paragraph 62). They continue to be hindered by the on-
erous programming and reporting requirements which, in three of the 
five Member States audited, have been compounded by understaffing. In 
Germany, during the early years of the programme, project verifications 
could not be performed on time due to the lack of Responsible Authority 
personnel, but this was remedied by the time of the Court’s audit. In the 
Czech Republic, resource constraints have meant that interim reporting 
and requests for intermediate payments are not made and a guide for 
final beneficiaries not yet produced. The lack of personnel in the Por-
tuguese Responsible Authority has meant that on-the-spot support at 
final beneficiaries has been limited.

The Responsible Authorities audited by the Court demonstrated high 
levels of commitment and were satisfactorily performing most of the 
fundamental tasks necessary for the management of the Funds. Examples 
of good practice were observed which make a strong contribution to the 
effectiveness of the Funds. These include the pre-start visits made in the 
UK to final beneficiaries (see Box 8) and both Germany and Luxembourg’s 
improvements in setting up systems for the collection of indicators on 
projects. 

BOX 8

UK RESPONSIBLE AUTHORITY PRE-START VISITS

The UK Responsible Authority has, since May 2010, incorporated ‘pre-start assurance’ visits into its project 
management and monitoring. These provide an additional level of support and guidance to the ‘pre-assurance 
workshops’ arranged for multiple beneficiaries. The visits are made by Responsible Authority officials to the 
premises of project beneficiaries who have been selected for EIF or ERF funding. Taking place prior to the sign-
ing of the grant agreement, and before the implementation of the actions, they serve to inform the beneficiary 
about the practical aspects of running the project, to check that they have the necessary systems in place to 
successfully do so, and to improve understanding about expectations and eligibility of funding. Focus is given 
to the expected deliverables of the project, to check that objectives and activities are realistic and achievable 
and ensure that the necessary monitoring and data collection will take place during the course of the project.

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75. 

In three of the five Member States34, insufficient written guidance was 
provided to final beneficiaries on the eligibility of costs. The Commission 
had provided an eligibility manual with a caution on appropriate use, 
implying that Responsible Authorities should accompany it with sup-
plementary explanation and guidance. However, these Member States 
interpreted the Commission’s disclaimer to mean it should in no cir-
cumstances be forwarded to beneficiaries and provided no alternative 
written guidance.

34  Czech Republic, Germany, 
Portugal.

ERF project  ‘Accommodate PRS (Private Rented Sector)’ 
implemented by the Housing Associations’ Charitable Trust (HACT), UK

©  HACT.

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CONCLUSIONS AND RECOMMENDATIONS

39

76. 

77. 

78. 

79. 

The Court’s audit examined whether the EIF and ERF of the SOLID pro-
gramme contribute effectively to the integration of third-country na-
tionals. The audit concluded that it has not been possible to measure 
success of the annual programmes due to the lack of a proper monitor -
ing and evaluation system. Nevertheless, most of the individual projects 
audited achieved positive results and Member States generally consider 
the Funds to have added value. 

Effectiveness of the Funds has been hampered by a fragmented design, 
insufficient complementarity with other EU funds, in particular with the 
ESF, as well as by successive delays and certain weaknesses in the man-
agement and control systems. As a result, the Funds are unlikely to be 
fully effective. 

The conclusions and recommendations below begin with the results 
available on the contribution of the Funds to integration, their design 
and implementation. Many of the findings could be valid for the other 
SOLID funds since the management and control provisions are similar.

EFFECTIVENESS OF EIF AND ERF COULD NOT BE 
MEASURED

The Commission and Member States are unable to assess the overall ef-
fectiveness of the Funds in supporting the integration of third-country 
nationals because Member States have not set up effective monitor-
ing and evaluation systems to report on the achievement of the pro-
grammes. Although the Commission provided extensive guidance on 
indicators, four out of the five audited Member States showed significant 
weaknesses in the inclusion of SMART objectives in programmes, setting 
up appropriate IT collection systems and/or reporting on the achieve -
ment of targets. Consequently, their ability to monitor and steer the 
programmes has been hampered. The Commission failed to detect and 
redress these shortcomings.

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80. 

The informative value of the Commission’s EIF intermediate report is 
weakened by the lack of comparable data and its delayed publication. It 
provides only a very limited assessment of the EIF results for stakehold -
ers. In preparation for the upcoming ex post evaluation, the Commission 
is now addressing the lack of comparable data by requesting Member 
States to provide information on basic common indicators. However, 
since these indicators were not established in advance and collected 
during  implementation,  the  potential  validity  and  usefulness  of  the 
evaluation are weakened and the process becomes inefficient.

RECOMMENDATION 1

The Commission should define an obligatory minimum set of common 
indicators for the Member States to measure output and outcome of 
their programmes, building on the provisions set out in the Commis-
sion’s proposal for 2014–20.

RECOMMENDATION 2

Before  approving  the  programmes,  the  Commission  should  require 
Member States to set SMART indicators and set up IT systems to col-
lect data from the start. 

RECOMMENDATION 3

Member States should, wherever possible, set target values for objec-
tives in order to be able to measure the achievement of programmes.

RECOMMENDATION 4

The Commission and Member States should exchange good practices 
on monitoring and evaluation. 

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41

81. 

82. 

AUDITED PROJECTS LARGELY CONTRIBUTING TO 
INTEGRATION BUT NOT ALL AVAILABLE FUNDS 
ARE USED

Nearly all of the audited projects achieved results which were found to 
contribute to the integration of third-country nationals in the context 
of the Member States’ strategies set out for this. Almost all EU Member 
States commented in the EIF intermediate report that the funds provided 
added value.

The  rate  of  EIF  budget  implementation  in  Member  States  for  the 
2007  and  2008 APs was generally low, though large variations are vis-
ible between Member States. Although the total Fund implementation 
rate improved from 66 % (2007) to 77 % (2008), the Fund remained sig -
nificantly underutilised in several Member States.

RECOMMENDATION 5

Member States should take steps to ensure programmes are fully imple-
mented. This may be done through extension of the scope of national 
programmes, liberalisation of national rules to ensure that funding is 
available to all organisations who are able to contribute to the inte-
gration strategy, or through more extensive information and publicity 
activities.

FRAGMENTED DESIGN OF THE FUNDS CAUSING 
DISPROPORTIONATE AND EXCESSIVE 
ADMINISTRATIVE BURDEN FOR FINAL 
BENEFICIARIES, MEMBER STATES AND  
THE COMMISSION

83. 

The management and control requirements, and in particular the system 
of annual programmes, second pre-financing payment arrangements 
and the three-authorities structure, have imposed a disproportionately 
heavy burden on Member States and final beneficiaries, as well as the 
Commission. Some Member States have added to this burden through 
national legislation and by creating additional obligations. This deters 
final beneficiaries and is a drain on Commission and national resources.

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42

84. 

85. 

Annual programming has placed high demands on the Commission’s 
resources, contributing to delays in its work and was not adequately 
considered by the Commission or legislators in the planning phase. 

The experiences from structural fund management on programming, 
payment arrangements and monitoring systems were not used by the 
Commission or the audited Member States to learn lessons or anticipate 
problems. 

RECOMMENDATION 6

The  legislation  should  introduce  a  system  of  single  national  pro -
grammes to cover the whole financial programming period, instead 
of the existing annual programming arrangements, in line with the 
Commission’s proposal for 2014–20.

RECOMMENDATION 7

The legislation should simplif y the Commission’s payment arrange-
ments, in line with the Commission’s proposal for 2014–20.

RECOMMENDATION 8

Before introducing new management and control requirements and 
when establishing the corresponding systems, the Commission and 
Member States should give due consideration to proportionality, the 
resource impact and take into consideration experience in the manage-
ment of similar programmes.

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43

86. 

87. 

COHERENCE AND COMPLEMENTARITY WITH OTHER 
EU FUNDS NOT SUFFICIENTLY ENSURED

There was no comprehensive assessment of integration needs in the EU 
and, hence, no overall strategy on how to address them. Furthermore, 
important existing or planned Union instruments supporting similar ac-
tions were not identified by the Commission in their preparatory work.

The EIF and ERF (integration part) were drawn up as separate instruments 
from the existing ESF which already targeted integration of third-country 
nationals and EU citizens. Although certain efforts were made to ensure 
coherence and complementarity with the ESF by the Commission in 
both the design and implementation phases, these were not effective. 
The Member States audited do not even comply with the minimum re-
quirements to coordinate with the ESF. As a  result, there are significant 
overlaps between EIF and ESF, with the ESF supporting the integration of 
third-country nationals with significantly larger amounts. Apart from an 
increased risk of double-funding, overlaps are causing additional costs 
(e.g. staff costs) and potential synergies are lost.

RECOMMENDATION 9

The Commission should carry out a comprehensive assessment of needs 
for integration regardless of whether migrants have EU or third-country 
nationality.

RECOMMENDATION 10

Based on this assessment, an appropriate fund(s) structure should be 
designed which ends the separation of the target population on the 
basis of nationality and which is oriented towards the needs of the Final 
Beneficiaries. Setting an obligatory priority to fund third-country na-
tionals would ensure that they receive the necessary specific attention.

RECOMMENDATION 11

The Commission should place greater importance on obtaining con-
crete details of Member States systems for ensuring coherence and 
complementarity in EU funds.

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SUCCESSIVE DELAYS HAMPERING IMPLEMENTATION 
AT BOTH MEMBER STATES AND COMMISSION LEVEL 

The  late  adoption  of  the  legal  basis  delayed  the  implementation,  in 
particular, of the 2007 and 2008 annual programmes, and contributed to 
a low implementation rate. The lack of clear requirements from the start 
of the programmes increases the risk of funding ineligible activities. 

The audited Member States were late in submitting their annual pro-
grammes, as was the Commission in approving the corresponding fi-
nancing decisions. For Member States not prepared to commit funds 
before the approval of the programmes, the start of projects was delayed 
and the period for implementation shortened.

Delays in submission and approval of programmes and reports continue 
to be incurred by both Member States and the Commission, largely due 
to the administrative burden.

88. 

89. 

90. 

ERF project implemented by Conselho Português para os Refugiados (CPR) 
(Portuguese Refugee Council)

©  Conselho Português para os Refugiados (CPR).

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RECOMMENDATION 12

Using the lessons learnt from the programming period 2007-13, legis-
lation should be ready for the start of the new programming period 
(2014–20).

DELAYS IN THE ESTABLISHMENT OF EFFECTIVE 
MANAGEMENT AND CONTROL STRUCTURES IN THE 
MEMBER STATES

The Commission has issued a broad range of guidance for the Member 
States’ authorities on important aspects of the management and con-
trol system. However, these were not provided early enough, limiting 
Member States’ understanding of the requirements. Ad hoc questions 
by Member States on such issues were usually answered effectively by 
the Commission services.

In most audited Member States the Management and Control Systems 
(MCS) were not ready from the outset. The Commission’s checks on the 
MCS description did not reveal this. Despite starting difficulties and in-
sufficient human resources the Responsible Authorities in these Member 
States manage the programmes well. 

In one Member State both the Certifying and the Audit Authority are 
still failing to fulfil their tasks, putting the sound financial management 
of the SOLID programme at risk.

91. 

92. 

93. 

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RECOMMENDATION 13

The Commission should ensure that critical guidelines are available to 
Member States at the start of the programming period.

RECOMMENDATION 14

The Commission should ensure that MCS are ready for the start of the 
programme through adequate checks demanding a practical descrip -
tion of how the legal basis is implemented in a Member State.

RECOMMENDATION 15

Member States should provide the necessary human resources for the 
authorities so as to fulfil their legal obligations.

 This Report was adopted by Chamber IV, headed by Mr Louis GALEA, 
Member  of  the  Cour t  of  Auditors,  in  Luxembourg  at  its  meeting  of 
13 November 2012.

For the Court of Auditors

Vítor Manuel da SILVA CALDEIRA
President

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47

ANNEX 

AUDITED PROJECTS

Country

Final Beneficiary

Project name

Zřízení a provoz Center na podporu integrace cizinců I.
Establishment and operation of centres for support of inte-
gration of foreigners

Správa uprchlických 
zařízení MV

integration  of 

The  project’s  objective  was  to  establish  centres  to  support 
in  Plzeň 
the 
and  Pardubice.  The  centres  are  to  provide  social  and  legal 
counselling,  courses  and  to  act  as  a  platform  for  relevant 
stakeholders.

legally  residing  foreigners 

Annual 
Programme

EIF 2007

Metodika hodnocení monitorovacích nástrojů integračního 
procesu cizinců z třetích zemí v ČR — 1. Fáze
Methodology for evaluating instruments for monitoring the 
integration process for third-country nationals in the Czech 
Republic — Phase I

EIF 2008

Výzkumný ústav 
práce a sociálních 
věcí

The project aimed to provide a methodology and a set of key 
indicators for monitoring TCN integration. 

Czech Republic

Občanské sdružení 
Berkat

Pracovní poradenství v komunitním centru InBáze
Job Consultancy in the Community Centre InBáze

The aim of the project was to provide occupational guidance 
and retraining for asylum seekers.

Poradna pro 
integraci, občanské 
sdružení

Adaptace azylantů v novém domově
Adaptation of refugees in the new home

The  project  activities  included  the  provision  of  essential 
information,  social  and  legal  counselling  and  personal 
assistance for refugees.

ERF 2008

ERF 2008

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Country

Final Beneficiary

Project name

Türkische Gemeinde 
in Deutschland e.V. 
(TGD)

Initiative für Einwanderung und Integration 
Initiative for immigration and integration

The  project  offered  counselling,  information  activities  and 
elementary German courses for third-country nationals who 
are moving to Germany for family reunification. The activi-
ties take place in Turkey.

Annual 
Programme

EIF 2007

Diakonisches Werk 
der Evangelischen 
Kirche in Deutschland 
e.V.

Germany

Leben  — 

Mitten 
im 
Einwanderungsgesellschaft
In the middle of life  — Diakonie in the immigration society

Diakonie 

in 

der 

The project supported the ‘intercultural opening’ of the so-
cial services of the Diakonie. Activities included workshops 
with  staff  from  different  regional  areas  of  the  association, 
conference, etc.

EIF 2007

Junge Flüchtlinge in Berlin
Young refugees in Berlin

OASE Berlin

ERF 2008

Qualification,  orientation  and  leisure  activities  for  unac-
companied minors with refugee background. 

Caritasverband für 
das Erzbistum Berlin 
e.V.

‘… und drin bist Du?’ Flüchtlinge als Teil der Gesellschaft 
— auf dem Weg in ein selbstbestimmtes Leben
‘… are you in?’ Refugees as part of society — on the way to 
a self-determined life

Project  aimed  at  improving  reception  conditions  and  aims 
both  directly  at  asylum  seekers/refugees  and  at  services/
structures in Eastern Brandenburg.

ERF 2008

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Country

Final Beneficiary

Project name

Annual 
Programme

Association de 
Soutien aux 
Travailleurs Immigrés 
(ASTI asbl)

Fondation Caritas 
Luxembourg

Comité de liaison 
des associations 
d’étrangers (CLAE)

Luxembourg

Association de 
Soutien aux 
Travailleurs Immigrés 
(ASTI asbl)

Fondation Caritas
Luxembourg

Comité de liaison 
des associations 
d’étrangers (CLAE)

Partenariats  pour  l'intégration  interculturelle:  mise  en 
place de services d'information et d'orientation 
Partnerships for intercultural integration: Setting up of In-
formation and orientation services

The  project  included  information  and  orientation  services 
for  immigrants,  activities  with  the  host  society  and  inter-
pretation services.

Partages: faisons connaissance!
Let’s get acquainted!

The  project  aimed  to  develop  encounters  between  im-
migrants  and  host  society 
in  order  to  strengthen  the 
relationship. 

Échanges  d’expériences  et  de  bonnes  pratiques  relatives 
aux mesures d'intégration des ressortissants des pays tiers 
et participation de ces ressortissants à la définition et à la 
mise  en  œuvre  de  politiques  d’intégration/A  Citoyenneté 
Égale
Exchange  of  experiences  and  good  practices  in  integration 
of  third-country  nationals  and  participation  of  these  in 
the  formulation  and  implementation  of  integration  policy/ 
Equal citizenship

Activities of the project included researching immigrant as-
sociations and the establishment of contacts with them.

Participation et Formation pour le Vivre Ensemble 
Participation and Education for living together 

The project aimed to improve the inclusion of asylum seek-
ers  into  Luxembourg  society  through  language  courses 
and  qualifications  and  carry  out  activities  and  information 
sessions.

Form’actif 

The project was targeted towards young asylum seekers and 
refugees, to enhance their chances of integration by improv-
ing language skills, job skills and knowledge of Luxembour-
gish culture and way of life.

Encadrement  social  et  d’activités  de  loisirs  dans  centres 
d’hébergement
Social  assistance  and  leisure  activities  in  accommodation 
centres

The  project  included  the  organisation  of  socio-cultural  ac-
tivities and courses in accommodation centres for refugees. 

EIF 2008

EIF 2008

EIF 2008

ERF 2008

ERF 2008

ERF 2008

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Country

Final Beneficiary

Project name

Annual 
Programme

Serviço de 
Estrangeiros 
e Fronteiras (SEF)

Alto Comissariado 
para a Imigração e 
Diálogo Intercultural, 
I.P. (ACIDI)

Centro  de  contacto  multilingue  com  gestão  automática 
e integrada do agendamento 
Multilingual Contact Centre with Automatic and Integrated 
Scheduling Management

The  project  included  the  purchase  and  installation  of VOIP 
(Voice  Over  Internet  Protocol)  equipment,  training  and 
maintenance for a call-centre.

Projectos municipais para a promoção da interculturalidade
Municipal projects to promote interculturality

The  project  supported  activities  of  municipal  authorities 
and civil society to further local integration of migrants.

Portugal

Conselho Português 
de Refugiados (CPR)

Acolhimento  de  Refugiados  e  Interacção  com  a  Comuni-
dade Local
Reception of refugees and interaction with local community

The  project  supported  the  initial  reception  and  integration 
of  asylum  seekers,  refugees  resettled  and  unaccompanied 
minors via the reception centre.

Formar e Informar para o Asilo e Refugiados 
Training and information on asylum and refugees

EIF 2007

EIF 2008

ERF 2008

Conselho Português 
de Refugiados (CPR)

The  project  aimed  to  sensitise  and  inform  the  host  society 
on issues concerning refugees, among other activities via an 
e-learning  training  course  and  via  a  series  of  conferences 
delivered to students and teachers.

ERF 2008

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Country

Final Beneficiary

Project name

Annual 
Programme

Slough Borough 
Council

Migration Works 

Project’s  purpose  was  to  develop  a  model  of  support  for 
TCNs, with learning and networking opportunities.

EIF 2007

Bradford welcomes new arrivals

Bradford College

Project’s  purpose  was  to  deliver  intensive  courses  in  Eng-
lish on a number of subjects designed to help integration of 
TCNs, e.g. language learning.

EIF 2008

United 
Kingdom

The Housing 
Associations’ 
Charitable Trust 
(HACT)

Refugee Community Housing and Employment Project

The  project  supported  refugees  by  providing  training  and 
work placements for them and by stimulating partnerships 
between  local  Refugee  Integration  and  Employment  Ser-
vice,  Housing  Associations,  Local  Authorities  and  Refugee 
Community Organisations.

ERF 2008

Merseyside Fire and 
Rescue Service

Fire awareness, accommodation and integration for 
refugees

The  project  included  home  checks,  website  development, 
leaflets  and  the  education  of  landlords  with  regard  to  fire 
safety issues and safe working practices.

ERF 2009

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REPLY OF THE  
COMMISSION

EXECUTIVE SUMMARY

III.
As required by the legal basis, the Commission will assess 
the contribution of the European Fund for the Integration 
of third-country nationals and of the European Refugee 
Fund  on  the  basis  of  detailed  results  received  from  the 
national evaluation reports covering the period 2007–10 to 
be submitted by 31  October  2012. This should be done on 
the basis of common indicators set by the Commission in 
such a way as they are compatible with the Member States’ 
own indicators at project level and as they produce mean-
ingful results at national and European level. Meanwhile, in 
compliance with the legal basis, the Commission has pub-
lished an intermediate report on the results achieved and 
on quantitative and qualitative aspects of the implementa-
tion which indicated that projects showed positive results 
as far as integration is concerned. This is not affected by 
the fact that some Member States were not in a position 
to spend their full EU allocation in the first two years of 
implementation, when the Fund was first launched.

IV.
The  Commission  does  not  consider  that  the  design  of 
the  EIF  is  fragmented,  burdensome  and  inadequately 
coordinated.  While  recognising  that  the  design  of  the 
European Integration Fund could have been simpler, this 
design reflects legal constraints deriving from the Treaty 
which imposes different Funds for different target groups. 
It also reflects  political choices made in 2006 and 2007. 
Annual programming exercises for instance were consid-
ered a means for the Funds to be able to respond to the 
political dynamics which evolved quickly both at EU and 
national  level  in  the  sensitive  area  of  immigration. The 
comprehensive set of rules established in the Funds were 
developed  to  steer  the  new  Authorities  who  were  then 
inexperienced  in  the  management  of  the  Funds  and  to 
ensure sound management. The Commission has been and 
is proactive and has taken a pragmatic approach towards 
National Authorities to facilitate their management of the 
Funds whenever possible.

The Commission does not consider that the insufficient 
coherence and complementarity with other EU funds leads 
to overlaps, missed opportunities for synergy and risk of 
double-funding. The Commission will ensure that concrete 
arrangements are in place at national level to ensure com-
plementarity and avoid overlaps.

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53

V.
The  Commission  agrees  that  Responsible  Authorities  in 
general are highly committed in fulfilling their core tasks. 
In  cooperation  with  them,  the  Commission  has  worked 
extensively  to  compensate  for  the  late  adoption  of  the 
Funds and to facilitate as much as possible the first years of 
the Funds’ implementation at national level where a whole 
system had to be set up. This was notably done by provid-
ing day-to-day and detailed guidance since the beginning. 
As also recognised by National Authorities, this has proved 
very useful and helped clarifying misunderstandings.

VI.
D elays  in  approving  annual  programmes  have  been 
shortened significantly. However, even with experience, 
it  proved  challenging  for  both  the  Commission  and  the 
Member States to cope with the very difficult deadlines set 
in the legal basis. 

In all cases where deficiencies in the Member States were 
identified, appropriate action has been and is taken by the 
Commission to avoid any risk of undue payment of any EU 
funds.

VII. (a)
The Commission agrees that, with the experience gained, 
it  is  now  possible  to  move  to  a single  multi-annual 
national programme. This is reflected in the future Multi-
annual  Financial  Framework  2014–20,  where  it  is  pro-
posed in the Commission’s proposal for a Regulation for 
the Asylum and Migration Fund (adopted on 15  Novem-
ber  2011 (COM(2011) 751)) to have a single multi-annual 
programme.

VII. (b)
The Commission has taken into consideration proportion-
ality, the amount of the funds involved and the impact on 
resources in its proposal for a Regulation for the Asylum 
and Migration Fund. The management and control system 
requirements are defined in more detail in the new Finan-
cial Regulation.

VII. (c)
The  Commission  does  not  see  the  need  for  a compre -
hensive assessment of needs for integration regardless of 
whether migrants have EU or third-country nationality. EU 
citizens may not be subject to any integration measures 
which restrict their right to move and reside freely in the 
EU. The legal situation of third-country nationals and EU 
citizens is not the same and they cannot be targeted in 
a comprehensive assessment without making a clear dis -
tinction between them.

The  Commission  cannot  design  a fund  structure  which 
ends the separation of the target population on the basis 
of nationality. The difference of target populations is based 
on the difference of legal bases. 

The EIF is part of the common immigration policy (Arti-
cle 79 points 1 and 2 TFEU), which aims at ensuring effi-
cient management of migration flows and fair treatment 
of third-country nationals residing legally in the Member 
States.

EIF measures focus on the first steps migrants can take to 
become integrated in a new country, usually in the main 
urban settings. The ESF aims to intervene at later stages 
with measures that favour integration and inclusion mainly 
aimed at the participation in the labour market. In this sec-
ond phase (ESF) migrants could be mixed with other target 
groups. The two Funds should be kept separate since they 
intervene in different moments of the migrants’ integra-
tion. The Commission has always considered that the divi-
sion and complementarity between the two Funds should 
be determined at the level of Member State.

VII. (d)
The  Commission  will  pay  greater  importance  to  ensure 
that the Member States provide more detailed information 
on the coherence and complementarity in EU funds.

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REPLY OF THE  COMMISSION54

VII. (e)
The Commission agrees with the recommendation to have 
common indicators for the Member States in the Commis-
sion’s proposal for 2014–20.

The  Commission  has  already  included  obligator y  com-
mon  indicators  in  the  proposal  for  the  draft  Regulation 
for the Asylum and Migration Fund, which it adopted on 
15 November 2011 (COM(2011)  751).

VII. (f )
The  proposed  Regulation  for  the  Asylum  and  Migration 
Fund, and the new Financial Regulation will require that 
the Member States have adequately established manage-
ment and control systems with formally designated bodies 
before they will be able to receive EU funds. The Commis-
sion is and will continue discussing and informing Member 
States of the new requirements.

INTRODUCTION

4.
The current ‘General Programme on Solidarity and Manage-
ment of Migration Flows for the period 2007–13’ (SOLID 
programme) was created as part of the multi-annual finan-
cial programming 2007–13. It was a new programme com -
pared to other EU instruments in shared management. In 
addition, it is worth mentioning that the SOLID programme 
brought together a dozen small programmes, pilot projects 
and preparatory actions that were previously running inde-
pendently and without being coordinated among them. 
Further the SOLID programme allowed Member States to 
develop their own programmes. 

9.
The European Integration Fund targets the integration of 
third-countr y  nationals  as  defined  in  the  legal  basis,  at 
the time Article 63 point 3 (a) TEC (now Article 79 points 1 
and 2 TFEU) for immigration, which concerned third-coun -
try nationals and not EU citizens. The legal basis for inte-
gration introduced through the Lisbon Treaty (Article 79 
point 4  TFEU)  covers  measures  established  to  provide 
incentives  and  support  for  the  action  of  Member  States 
with a view to promoting the integration of third-country 
nationals residing legally in their territories, excluding any 
harmonisation of the laws and regulations of the Member 
States.

EU citizens may not be subject to any integration measures 
which restrict their right to move and reside freely in the EU. 

OBSERVATIONS

20.
The Commission considers that the Funds’ overall contribu-
tion to the integration of third-country nationals can now 
be measured beyond results at project level. By 31  Octo-
ber  2012, each Member State must submit a national eval -
uation report on the results and impacts of the Funds for 
the period 2007–10. Based on the analysis of all the funded 
projects and the results achieved by each Member State on 
a set of indicators common to all Member States, it should 
be possible to have a meaningful assessment of the policy 
effect of the Funds. The national reports must assess the 
effectiveness, efficiency, value added and complementarity 
of the Funds and their impact at national level, both quan-
titatively and qualitatively. These Member State reports as 
well as the subsequent Commission reports, should ade-
quately evaluate the results and impact of the Funds. The 
Commission reports will be available in 2013 and will be 
submitted to the EU institutions and widely published. 

24.
The Commission acknowledges that the definition of quan-
tifiable targets in the annual programmes 2007 and  2008 
has  not  been  optimal. The  emphasis  in  2007  and  2008 
was put on the adoption of annual programmes for which 
there  was  a real  risk  of  loss  of  appropriations  since  the 
legal  basis  was  adopted  late  (in  2007)  and  a  number  of 
activities  needed  to  be  per formed  before  adopting  the 
annual  programmes.  At  that  time,  the  Commission  also 
wanted to preserve a  degree of proportionality between 
the  administrative  burden  for  National  Authorities  and 
beneficiaries for annual programmes with small allocations 
and the need to have annual programmes adopted as soon 
as possible. Since 2009 the Commission is already paying 
more attention to these aspects and will make a  close fol-
low up for the next annual programmes for the countries 
where measurable targets would deserve a more thorough 
definition.

See also Commission’s reply to paragraph 62.

26.
During the closure process of the first annual programmes, 
the Commission has requested Member States to improve 
some aspects of the information provided in the closure 
documents  in  par ticular  to  gain  a fuller  picture  of  the 
attainment of the multi-annual and annual objectives.

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REPLY OF THE  COMMISSION55

27.
The Commission considers that it can assess the effective-
ness of the Funds. The fact that some Member States have 
to improve the actions’ output indicators in their annual 
programme will not prevent the Commission from mak-
ing its assessment. Further the national ex post evaluation 
reports must be based exclusively on the indicators set out 
in the Commission templates, which are always measur-
able and in turn refer to project-based indicators, not to 
those set out in the national programmes.

29.
The Commission considers that the presentation followed 
in  the  intermediate  repor t  is  the  correct  way  to  table 
the  operations  covered  by  the  programmes. The  table 
in the report presents a synthetic overview of the differ -
ent  actions  planned  by  the  Member  States  and  reflects 
the  strategy  actually  chosen  by  each  Member  State.  As 
such, it is considered very meaningful for understanding 
the  Fund’s  implementation.  However,  the  Commission 
acknowledges  that  the  title  of  this  table  does  not  fully 
reflect its content.

The Commission also acknowledges that there is one inac-
curacy for pre-departure measures funded by Germany.

30.
At the time the Member States had to submit the national 
evaluation  repor ts  (30  June  2010),  they  had  available 
results only for the first annual programme (out of seven in 
the programming period). Therefore, even if common indi-
cators had been available at this time, their analysis would 
have been of limited value as the period analysed was too 
short. This explains why the Commission did not consider 
it a priority to develop common indicators but preferred to 
focus on launching the programmes and setting up effec-
tive management and control systems. 

The situation is different for the national evaluation reports 
due on 31  October  2012, which should cover several com-
pleted annual programmes. The Commission has designed 
the common indicators to be used by all Member States 
for this evaluation in such a way as (a) they are compatible 
with the Member States’ own indicators at project level (b) 
they produce meaningful results at national and European 
level. The same approach was followed for the ERFII final 
evaluation, with very good results.

The Commission has indeed proposed an obligatory set of 
common indicators from the start of the new programme 
for the period 2014–20. This will enable Member States to 
collect data throughout the programming period, but, as 
explained above, does not change the availability of data 
at the time the evaluation report has to be submitted.

31.
The Commission confirms that the examples of projects 
tabled in the intermediate report are not deemed to be 
representative projects, but ‘success stories’ identified by 
each Member State based e.g. on the project content, its 
effectiveness or its innovatory aspects.

Given the wide range of actions covered by the EIF and the 
high number of projects funded, there is no ‘representative’ 
project. 

32.
The Court’s remark refers to the part of the national evalu-
ation report, where Member States were asked to express 
their assessment of the EIF, in particular as regards their 
needs and priorities. The feedback received was both posi-
tive and negative. The Commission respects the position 
expressed  officially  by  Member  States,  even  when  it  is 
negative. 

The Commission has taken into account in its proposal for 
the  Asylum  and  Migration  Fund  (2014–20)  the  criticism 
expressed inter alia by the two Member States quoted by 
the Court, by enlarging the target group of the Fund and 
by simplifying the implementation procedures. 

33.
For the reason explained above, at the time the national 
evaluation reports had to be submitted, only very limited 
information was available to the Member States.

Detailed  and  meaningful  information  on  the  outputs, 
results and impacts of the Funds have to be made avail-
able in the national evaluation reports covering the period 
2007 to  2010 due at the end of October 2012, because the 
timing of these reports allows covering several years of the 
Funds’ implementation.

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REPLY OF THE  COMMISSION34. and 35. Common reply 
The annual programmes of 2007  and 2008 were adopted in 
late 2008 and early 2009. Both 2007 and 2008 had overlap-
ping eligibility periods and had to be run in parallel. Thus 
the combination of the late adoption and the challenges 
linked to the implementation of a new Fund (such as new 
Responsible Authorities, new rules, new management and 
systems in place), the first two years of implementation 
were exceptionally difficult. Further it is highly probable 
that the late adoption and challenges affected the rates of 
implementation. The Commission is closely monitoring the 
evolution of the implementation rate by Member States.

36.
The report submitted by the Commission is an interme-
diate report on the results achieved and on quantitative 
and qualitative aspects of the implementation. Therefore, 
its  purpose  is  linked  to  implementation  and  it  is  not  an 
evaluation of the effectiveness of the Funds. It was deemed 
too  early  to  assess  the  effectiveness  of  the  Funds  after 
only the two first years of EIF and one year of ERF III. First 
assessments on the effectiveness of the Funds are being 
measured on the basis of the national reports that were 
not available at the time of the Court’s audit and are due 
on 31 October 2012.

37.
The  large  majority  of  projects  have  achieved  positive 
results for the integration of third-country nationals. The 
Fund has become in a very short period of time an effec -
tive tool at the EU level in the area of integration.

38.
The fact that some projects did not work perfectly or pro-
vided  average  results  is  an  embedded  and  acceptable 
risk in project management. Therefore it is not unreason-
able  that  four  out  of  22  projects  audited  may  not  have 
achieved their objectives. However as the area of integra-
tion of third-country nationals and the shared manage -
ment mechanism is new to the Member States one cannot 
expect  a perfect  success  rate  since  the  beginning. With 
the experience gained, Responsible Authorities have been 
developing more accurate targets.

56

Box 5 
The project ‘Merseyside Fire and Rescue Service (MFRS)’ 
had  to  stop  because  the  beneficiary  overestimated  the 
number  of  people  from  the  target  group  which  would 
have been affected by the project. Therefore, this example 
shows that the application, while being innovative, was 
not well conceived.

While  the  Commission  provided  pragmatic  guidance  to 
Member States on evidence of target groups, the Respon-
sible Authority in this case applied stricter rules on benefi-
ciaries than those imposed by the regulatory framework 
set by the Commission.

39.
While  acknowledging  that  some  actions  in  annual  pro-
grammes could have set more detailed targets or quan-
tified  results,  this  does  not  prevent  them  from  having 
achieved good projects and programmes.

40.
The Commission considers that the Fund is to be consid-
ered as an instrument that allows the financing of impor-
tant integration activities in the Member States. In very 
few years the European Fund for the Integration of third-
country nationals has become a tool that fosters integra-
tion-related activities in the participating Member States 
and  is  considered  by  Member  States  to  be  valuable  for 
integration.

42.
The first results on the effectiveness of the Funds can be 
adequately  measured  only  after  the  feedback  given  by 
Member States on the first three years of implementation, 
i.e. as of October 2012. Moreover, what the Court has iden-
tified as ‘weaknesses’ are deliberate choices made at the 
time that, in light of the experience, appear not be neces-
sarily the best solution, in view of available resources and 
challenges.

44.
The split between the two Funds was imposed by the dif-
ferent legal bases in the Treaty, leading inter alia to incom-
patible  adoption  procedures:  ERF  had  to  follow  the  co-
decision procedure with the Council (qualified majority 
voting) and the European Parliament while EIF had to be 
adopted by unanimity in the Council with a simple consul -
tation of the European Parliament.

While sometimes similar actions could legally fall under 
both  the  EIF  and  ERF,  this  is  not  the  case  for  all  actions 
since target groups of EIF and ERF and their needs differ.

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REPLY OF THE  COMMISSION57

44. First indent
Integration of refugees is a single strand of ERF and other 
actions are also covered by ERF area such as reception con-
ditions. The ERF already existed as of 2000 and in order not 
to affect its continuity of operations, ERF III was conceived 
as a continuation of ERFII which proved to be a  great suc -
cess and adapted to the needs on the ground. The other 
actions of ERF would have been adversely affected if they 
had  been  combined  in  competition  with  EIF.  Though 
they  are  two  different  instruments,  the  two  Funds  were 
conceived  as  constituting  a coherent  framework  both 
politically  and  operationally,  where  each  Fund  reflects 
the objectives of a policy but exist in parallel. This is also 
reflected by the fact that both Funds share a common set 
of implementation and management rules as well as con-
trol and monitoring rules.

44. Second indent
In any programme, the costs must be reported in accord-
ance to the projects to which they are incurred and non-
eligible costs separated out. 

45.
The annual programming exercise, while challenging, was 
deliberately chosen by the Commission at that time. It was 
considered that it allowed for a better adaptation of the 
political  dynamics  which  evolve  quickly  both  at  EU  and 
national level in the sensitive area of immigration policies. 
It was also considered as the most suitable instrument to 
look more closely at the eligibility of the actions, taking 
into consideration the novelty of the actions proposed by 
the Fund and the limited experience of National Authori-
ties in this context. However, it is possible that the impact 
has been more important than what had been foreseen at 
that time.

46. and 47. Common reply 
Taking into account that both the Commission and Mem-
ber States have now gained experience in this area, the 
Commission  considers  that  resources  could  now  focus 
on other activities concerning the implementation of the 
Funds. 

48.
Although it cannot be ruled out that some Member States 
have not fully understood the requirements for lodging 
their requests for second prefinancing, this is not the only 
reason for the low number of requests for 2nd prefinanc-
ing. Indeed, in many cases, Member States overestimated 
the  work  required  and  sometimes  even  added  bureau-
cratic burden at national level. Also, sometimes Member 
States  decided  to  give  priority  to  drafting  their  annual 
programmes  and  speeding  up  the  closures  for  the  pro -
grammes already implemented.

Despite the clarifications provided in 2010 the number of 
Member States requesting a second prefinancing remains 
very low.

To avoid any cash flow problems for final beneficiaries, the 
Commission has treated until now all second prefinancing 
requests as a matter of priority. However, in the context of 
growing pressure on payment credits in the EU budget this 
might not be possible any more in the near future.

49.
The Commission is aware of the fact that the management 
and  control  system  applied  at  Member  States  level  can 
be considered heavy in comparison to the level of funds 
managed. To avoid unnecessary complications in the sys-
tems  implemented  by  the  Member  States,  the  Commis-
sion  provided  clarification  through  two  conferences  in 
June 2008 and 2009 and a guidance note in 2010.

There were strong reasons for taking inspiration from the 
Structural  Funds  in  the  design  of  the  management  and 
control  system. The  main  one  was  to  benefit  from  their 
longstanding  experience  in  managing  EU  funds  and  to 
avoid any risk of irregular spending in this new area for 
shared management.

50.
Each  Member  State  is  free  to  choose  its  own  manage-
ment and control system. The Commission only sets the 
minimum internal control criteria that have to be complied 
with to give assurance on the management of EU funds.

The Commission has therefore proposed to move to multi-
annual programming for the future Multiannual Financial 
Framework. This will also constitute a simplification and be 
in line with Structural Funds.

Both Member States quoted by the Court represent cases 
where the National Authorities have added unrequested 
layers of checks.

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REPLY OF THE  COMMISSION51.
What the Court has identified as ‘weaknesses’ are deliber-
ate choices made at the time by the legislator. 

52.
In  2005,  the  Commission  carried  out  an  ex  ante  impact 
assessment that though it was not formalised, was taken 
into account during the discussions that led to the adop-
tion of the Common Basic Principles, endorsed by the Jus-
tice and Home Affairs Council in November 2004, which 
reflect the needs and the objectives in the area of integra-
tion of third-country nationals. The Commission also con-
sulted the National Contact Points on Integration as well 
as some NGOs.

53.
The  EIF  is  a response  at  EU  level  to  the  need  to  have 
a financial  instrument  that  would  be  part  of  a common 
immigration policy and which would address the specific 
needs of third-country nationals once residing in the EU. 
Other EU programmes fund a wide range of actions some 
of which could also benefit the integration of third-coun-
tr y  nationals  but  this  is  not  their  main  objective. These 
other  instruments  are  not  specifically  designed  for  the 
needs of third-country nationals, many of whom are also 
newly arrived with special needs during their first years of 
residence. These other programmes are also concentrated 
in geographic areas that do not have a high concentration 
of third-country nationals.

None of the other EU instruments have the specific obliga-
tion to fund integration activities of third-country nation-
als in the Member States. 

58

53. (a) to 53. (c) Common reply
The  European  Social  Fund  (ESF)  was  set  up  in  order  to 
improve  employment  oppor tunities  for  workers  in  the 
internal market and to contribute thereby to raising the 
standard  of  living.  It  aims  to  render  the  employment  of 
workers  easier  and  to  increase  their  geographical  and 
occupational mobility within the Union, and to facilitate 
their adaptation to industrial changes and to changes in 
production systems, in particular through vocational train-
ing and retraining (Article 162 TFEU). Its objective is also 
to reduce differences in prosperity and living standards 
across EU Member States and regions, and therefore pro-
mote economic and social cohesion. It is devoted to pro-
moting employment in the EU. Funding is spread across 
the Member States and regions, in particular those regions 
where economic development is less advanced. The EIF, on 
the other hand, expresses the political choice to have inte-
gration measures funded in participating Member States 
without  depending  on  the  political  choice  of  Member 
States to include or not such measures in their program-
ming for Structural Funds, nor on the level of competitive-
ness of regions. The level of ESF funding differs from one 
region to another depending on their relative wealth, if 
the GDP per capita is more or less than 75 % of the EU-25 
average. This distinction between regions does not neces-
sarily reflect the concentration of migrants to certain (pri-
marily) urban regions, nor the particular needs as far as 
integration is concerned.

With the EIF, Member States consider it important to have 
many projects funded at national level in order to have 
a wide impact and take account of the national specifi -
cities. Member States considered and still consider inte-
gration  of  third-countr y  nationals  as  being  their  main 
responsibility, while the European level can provide the 
framework for interventions in accordance with the prin-
ciple of subsidiarity. This is the reason why 93 % of the EIF 
is mainly managed through shared management, national 
programmes.

As Commission-managed programmes, the Research, Edu-
cation  and  Culture  programmes  cannot  respond  to  the 
specific requirements and political dynamics which evolve 
quickly both at EU and national level in the sensitive area 
of  immigration  policies.  The  Member  States’  national 
programmes support a large number of actions such as 
awareness-raising campaigns on integration or projects 
targeting integration at local level, which is possible with 
EIF, managed through shared management.

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Although a few Research, or Education and Culture (EAC) 
projects tackle integration, this cannot be compared with 
the large spectrum of integration actions covered by EIF, 
a specific dedicated instrument. In addition, EAC projects 
are transnational projects aiming at disseminating good 
practices in different Member States and have therefore 
very different objectives and scopes. 

54. to 59. Common reply 
The EIF is complementary to the European Social Fund (ESF). 
While the ESF aims to increase occupational and geographi-
cal mobility of workers within the Union, the EIF is targeted 
to addressing specific needs in the area of integration arising 
from the development of the common integration policy. 
Therefore, EIF measures are not identical to those funded by 
the ESF by including integration into all aspects of society.

The legal bases for the ESF and EIF are different and the 
two Funds were developed from two different policy con-
texts. The ESF is part of the EU cohesion policy, which aims 
to  strengthen  the  EU’s  economic,  social  and  territorial 
cohesion, in particular by reducing disparities between the 
levels of development of its various regions. The EIF is part 
of the common immigration policy which aims at ensuring 
efficient management of migration flows and fair treatment 
of third-country nationals residing legally in the Member 
States.  Considering  these  different  policies  and  the  two 
different legal bases, the two Funds target different objec-
tives. These different purposes could not be obtained if the 
Funds were a single Fund.

The ESF-supported actions addressing inclusion and inte-
gration cover both EU citizens and third-country nation-
als, whereas the EIF targets the particular needs of third-
country nationals, in particular newly arrived. The target 
population of the EIF is not necessarily concentrated on 
the regions that receive the highest ESF support.

Most  ESF-suppor ted  actions  on  inclusion  and  integra-
tion focus on meeting the overall objective of increased 
employment. Actions funded under the EIF target a gen -
eral  integration  in  the  countr y,  such  as  introduc tion 
courses, interaction between communities, intercultural 
dialogue, monitoring of integration results, etc.

As some actions could be covered under the two Funds 
and have similar objectives and in order to ensure com-
plementarity between the Funds, the Commission services 
follow internal consultations and procedures to avoid over-
laps when adopting the EIF and the ESF programmes.

However, as national programmes, the emphasis must be 
on the follow-up mechanisms by the Member States where 
they are obliged to ensure complementarity and avoid any 
overlap between the Funds.

The  Commission  is  putting  emphasis  on  these  aspects 
during monitoring visits to Member States and additional 
attention will be paid to this important aspect.

Based on many positive assessments by Member States of 
the impact and added value of the EIF to contribute to the 
establishment of integration strategies, integration cen-
tres, introduction courses, monitoring systems, etc. in the 
Member States, the Commission maintains that integration 
needs can be comprehensively addressed with the current 
and proposed structure of the Funds in the Home Affairs 
area.

Box 7 
In  the  specific  case  of  Por tugal,  the  application  of  the 
national law has the effect that only two organisations are 
beneficiaries of the EIF. There has been a risk of overlap for 
the activities carried out by these organisations which are 
eligible under the EIF and the ESF. In 2012, the Commis-
sion asked Portugal to take the necessary measures so as 
to open up the access of the EIF to relevant organisations 
involved in integration.

Concerning  ACIDI,  the  risk  concerns  the  distribution  of 
staff  costs  for  personnel  that  work  on  the  two  projects 
funded by EIF and ESF. The Audit Authority is aware of this 
risk and will follow it up.

62.
The  EIF  and  ERF  legal  bases  were  adopted  after  a long 
negotiation  process.  In  addition,  the  legislative  proce-
dures  (co-decision  by  qualified  majority  voting  for  ERF 
and unanimity with consultation of the European Parlia-
ment for EIF) applicable for the adoption of the legal basis 
were quite long taking into account that the Commission 
proposal was adopted in April 2005. The same applied for 
the Implementing Rules that, while having been discussed 
ahead of their adoption (as of 2007) with Member States 
through  exper t  meetings,  common  formats  and  guid-
ance documents and bilateral technical advice had to be 
adopted with the assistance of the management commit-
tee  which  could  be  established  once  the  Decisions  had 
entered into force.

I n  view  of  these  delays,  the  Council  has  increased  in 
the legal basis the eligibility period of 2007 annual pro -
grammes to three years not to jeopardise the implementa-
tion of the first annual programmes by Member States.

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REPLY OF THE  COMMISSION60

63.
For 2007  and  2008, in addition to the late adoption of the 
regulations, the legal basis imposed a heavy process before 
the Commission could approve annual programmes and 
therefore a lot of conceptual work was required to make 
the Funds operational from both the Commission and the 
Member States, such as the definition of multi-annual and 
annual programmes by Member States and their approval 
by the Commission. Member States were also required, as 
provided in the legal basis, to put in place management 
and control systems that would ensure a sound manage -
ment of the resources, which had to be assessed by the 
Commission.

In  light  of  the  above  and  taking  into  account  also  the 
novelty of the Fund, it had been difficult to cope with the 
deadlines set out in the legislation which are very difficult 
to meet.

64.
The adoption of annual programmes is now much quicker 
and within a reasonable timeframe, while the deadlines set 
out in the legal basis proved to be very difficult to attain 
despite  the  experience  gained  and  the  efforts  made  by 
the Commission to comply. It was also necessary to ensure 
that annual programmes were of good quality with ade-
quate description of eligible actions to comply with the 
objectives of the Fund. This was not always possible within 
the imposed deadline.

65.
The Commission put special emphasis on accompanying 
National Authorities in the management of the Funds at 
national level. Guidance was provided through daily con-
tacts  between  the  Commission’s  desk  officers  and  the 
Member States but also via the organisation of six semi-
nars/conferences  and  many  presentations  during  the 
SOLID Committee meetings. The Commission also issued 
19 guidance notes on the implementation of the SOLID 
Funds.

66.
Tak ing  into  account  the  delays  in  the  adoption  of  the 
legal framework, the Commission considers that guidance 
has been provided as soon as possible. It is true that the 
Implementing Rules were issued in March 2008 but have 
been extensively discussed with Member States well ahead 
of  their  adoption.  As  of  April  2008  the  Commission  has 
organised a seminar on the Implementing Rules in order 
to draft the manual on eligibility rules that was distributed 
to Member States in June 2008. In addition, the fact that 
Member States were not able to spend their total EU allo-
cation  is  not  linked  to  the  date  when  they  received  the 
guidance but mainly to the novelty of the Fund, the inex-
perience of the Responsible Authorities, the short eligibil-
ity period, and the fact that the two annual programmes 
2007 and 2008 were run in parallel.

69.
The legal basis does not request Member States to estab-
lish a system for collecting and aggregating the key opera -
tional and financial indicators as this might result in dis-
propor tionate  administrative  costs.  However,  the  legal 
basis requires Member States to establish for each project 
key operational and financial indicators, to be monitored 
and  communicated  to  the  Responsible  Authorities. The 
fact that this obligation was adequately included in grant 
agreements  signed  by  the  Responsible  Authorities  was 
verified during audits on the spot. However, for the three 
Member States mentioned by the Court, Commission audit 
missions took place before any monitoring activities had 
started, thus making it impossible to audit this part of the 
management and control system (scope limitation).

70.
The Commission understands that the weaknesses identi-
fied by the Court refer to two out of the five on-the-spot 
audited  Member  States.  The  lack  of  clear  relationship 
between the three authorities in Germany was reported by 
the Commission following its mission of March 2009. The 
action plan put in place by Germany to remedy this defi-
ciency was therefore duly monitored by the Commission.

While the Commission agrees that the model applied in 
the SOLID Funds generated questions from the Member 
States, all these questions were resolved through general 
and targeted guidance provided to the Member States.

As  regards  Germany,  this  has  proven  to  be  insufficient 
and this very specific case is followed up closely by the 
Commission.

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REPLY OF THE  COMMISSION61

CONCLUSIONS AND RECOMMENDATIONS

76.
Th e   Co m m i s s i o n   c o n s i d e r s   t h a t   t h e   p o s i t i ve   re s u l t s 
achieved by projects funded by the EIF confirm its value 
added. For the overall success of the programme detailed 
information  on  the  outputs,  results  and  impacts  of  the 
Fund  were  made  available  in  the  national  evaluation 
reports covering the period 2007  to  2010 that are due by 
31 October  2012. The timing of these reports allows cover-
ing several years of the Fund’s implementation. At the time 
the Member States had to submit the national evaluation 
reports, this was not possible because Member States had 
available results only for the first annual programme out of 
seven in this programming period. 

The  corresponding  Commission  evaluation  repor t  will 
provide detailed information on the outputs, results and 
impacts of the Fund at EU level, based on several imple-
mentation years.

77.
The Fund is considered effective, relevant and added-value 
by the Commission, the Member States and other stake -
holders. While elements can be improved and are being 
improved and the design could have been simpler, this has 
not prevented the Fund from being a robust tool that is 
progressively reaching its fundamental objectives. Com-
plementarity with other EU Funds is ensured at EU level. 
Mechanisms  in  place  at  national  level  to  guarantee  this 
complementarity will be closely further monitored by the 
Commission. 

78.
In  the  Commission’s  view,  the  findings  are  not  neces-
sarily  applicable  to  the  External  Borders  Fund  and  the 
Return Fund, where there are very different actions and 
beneficiaries. 

71. and 72. Common reply
The  Commission  is  aware  of  the  problems  existing  in 
Portugal.

It has taken action in 2012 by providing targeted guidance 
to Portugal, and reinforcing bilateral contacts at all levels 
of responsibilities in order to improve the management 
and control system in Portugal. In parallel, safeguarding 
measures are being taken whenever the Commission has 
identified that there was a risk that ineligible expenditure 
may be charged to the Fund. Where the risk for the funds 
will be confirmed, financial corrections will be applied.

73.
The setup of the SOLID Funds was challenging. This was 
known from the beginning and explains why the annual 
budget available increased each year over the seven-year 
programming  period. The  programming  and  repor ting 
requirements are not onerous. Each year all annual pro-
grammes of all the Member States have been adopted and 
are being implemented by the Member States, therefore 
the Member States are not hindered. Any shortcomings 
linked to insufficient resources allocated by the Member 
States is not in line with the legal basis that foresees that 
Member States shall allocate sufficient resources for each 
authority, when designing their management and control 
system.

74.
The Commission considers that most of the Responsible 
Authorities  are  satisfactorily  per forming  most  of  their 
fundamental tasks. This is reflected in the Annual Activity 
Report of DG Home Affairs.

75.
The  Commission  has  provided  ex tensive  guidance  to 
Member  States  as  regards  eligibility  rules.  It  repeatedly 
informed Member States that the manual was for National 
Authorities  and  that  providing  this  document  to  final 
beneficiaries without proper instructions and recommen-
dations may not be appropriate. However, the Commis-
sion made clear that it was crucial that final beneficiaries 
received guidance on eligibility rules. Many Member States 
organised training for beneficiaries on eligibility rules and 
also translated the manual. 

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REPLY OF THE  COMMISSION62

Recommendation 2
The Commission accepts the recommendation that, before 
approving  the  programmes,  the  Commission  should 
require Member States to set SMART indicators and set up 
IT systems to collect data from the start.

For the Asylum and Migration Fund for 2014–20, the Com-
mission  has  proposed  to  have  common  SMART  indica-
tors and the Member States will indeed be obliged to use 
them. In addition, the Commission will request the Mem-
ber  States  to  set  up  IT  systems  to  collect  these  data  in 
a timely manner.

Recommendation 4
The Commission agrees with the recommendation that the 
Commission and Member States should exchange good 
practices on monitoring and evaluation.

The Commission intends to propose to set up a Monitoring 
and Evaluation Network composed of the Member States 
and  the  Commission. The  network  would  meet  at  least 
once a year.

81.
T h e   C o m m i s s i o n   c o n s i d e r s   t h a t   i n d i v i d u a l   p ro j e c t s 
achieved positive results that contribute to the objective 
of the Fund to contribute to better integration of third-
country nationals.

82.
The  implementation  rates  of  the  first  years  of  imple -
mentation  of  the  Funds  followed  a positive  cur ve  and 
increased from 66 % to 77 % from 2007  to  2008. This trend 
is maintained for 2009 and is expected to continue for the 
four remaining years of implementation of the Funds.

Reply to the title before paragraph 79. 
‘Effectiveness of EIF and ERF could not be 
measured’
Even though the effectiveness of EIF and ERF could not be 
measured yet, the Commission understands that individual 
projects are successful.

79.
The Commission will address these weaknesses with the 
Member States concerned to ensure that the shortcomings 
are addressed in the Member States concerned.

However,  this  should  have  no  impact  on  the  quality  of 
the national evaluation reports that are due by 31  Octo-
ber  2012,  because  the  Commission  has  requested  that 
these  reports  are  based  on  the  individual  projects  (not 
annual programmes) funded so far and on their results and 
effects; and that, for all the projects taken together, the 
assessment is done against the multiannual strategy set at 
the beginning of the multiannual programming period by 
each Member State. This strategy is the framework of refer-
ence for the evaluation.

80.
The  data  included  in  the  Commission’s  intermediate 
report provide a comparison between the Member States 
and their annual programmes. At the time of submission 
of  evaluation  reports,  the  Member  States  had  to  report 
results from one out of seven years of annual programmes. 
Hence the assessment of EIF results could only be limited 
in 2010. The assessment of the results will be available in 
the national evaluation reports which the Member States 
have to submit by 31 October 2012.

The Commission has designed the common indicators to 
be used by all Member States for the current evaluation 
in such a way as (a) they are compatible with their own 
indicators at project level and (b) they produce meaningful 
results at national and European level. The same approach 
was followed for the ERF II final evaluation, with very good 
results.

Recommendation 1
The Commission agrees with the recommendation to have 
common indicators for the Member States in the Commis-
sion’s proposal for 2014–20.

The  Commission  has  already  included  obligator y  com-
mon  indicators  in  the  proposal  for  the  draft  Regulation 
for the Asylum and Migration Fund, which it adopted on 
15 November 2011 (COM(2011)  751).

Special Report No 22/2012 – Do the European Integration Fund and European Refugee Fund contribute effectively to the integration of third-country nationals?

REPLY OF THE  COMMISSION83.
The Commission does not consider that the design of the 
EIF is disproportionate and excessively burdensome. 

Despite the fact that it is heavy, the system of annual pro-
gramming  was  deliberately  chosen  for  ver y  impor tant 
political reasons linked to:

 — the field of intervention that is changing and needs to al-
low regular reassessment of the budgetary allocations per 
Member State;

 — the novelty of the Fund that needed close monitoring of 

Member States by the Commission;

 — the possibility to discuss on a regular basis the activities of the 

Member States in the policy area; and 

 — to check the eligibility of some actions that could be sensitive.

84.
Thanks  to  the  experience  gained  from  the  first  years  of 
implementation of the Fund and in the light of the admin-
istrative burden, the Commission recognises that annual 
programming is heavy and that resources could be now 
better allocated to other activities under the Funds.

85.
In the next programming period 2014–20, the Commission 
seeks for an alignment with the Structural Funds, as far as 
possible.

Recommendation 6
The Commission has therefore proposed to have a multi-
annual programming exercise in the context of the future 
Fund, which also corresponds to the Court’s recommenda-
tion. This will also constitute a simplification and be in line 
with Structural Funds.

Recommendation 7
The Commission considers that this recommendation is 
addressed to the co-legislators.

63

Recommendation 8
The Commission has already implemented the recommen-
dation in its proposal for a Regulation for the Asylum and 
Migration Fund, which it adopted on 15  November  2011 
(COM(2011) 751).

86.
There was an assessment of integration needs in the EU 
leading  up  to  the  formulation  of  objectives  concerning 
the rights and integration of third-country nationals resid-
ing legally in the EU, agreed by the European Council in 
Tampere 1999, in the Hague Programme 2004 and in the 
Stockholm Programme 2009. These objectives were further 
developed into the Common Basic Principles on integra-
tion policy in the EU in 2004, based on the needs identified 
in and agreed by all the Member States. On this basis, the 
Commission has developed its Common Agenda for Inte-
gration in 2005 and the EIF was developed as a financial 
instrument  supporting  Member  States’  actions  towards 
achievement of these objectives and compliance with the 
Common Basic Principles.

87.
The EIF is conceived as complementary to ESF. The EIF is 
focused on the first steps new arrivals take in society. ESF 
inter venes  at  a later  stage. The  point  where  this  transi -
tion takes place is to be determined and checked by the 
Member State, in line with the principle of subsidiarity. In 
short, the Member States were required to take the neces-
sary arrangements to ensure cooperation and coordination 
mechanisms and to ensure that interventions under EIF are 
specific and complementary to ESF. Overlaps between the 
Funds  are  limited  to  possible  projects  that  the  Member 
States must control and the Commission services moni-
tor. The Commission requested in all annual programmes 
a description of the mechanisms to ensure complementa -
rity and will closely follow up the concrete arrangements 
in place at national level to ensure that there is no overlap 
between EIF and ESF.

Recommendation 9
The  Commission  does  not  see  the  need  for  a compre -
hensive assessment of needs for integration regardless of 
whether migrants have EU or third-country nationality. EU 
citizens may not be subject to any integration measures 
which restrict their right to move and reside freely in the 
EU. The legal situation of third-country nationals and EU 
citizens is not the same and they cannot be targeted in 
a comprehensive assessment without making a clear dis -
tinction between them. 

Special Report No 22/2012 – Do the European Integration Fund and European Refugee Fund contribute effectively to the integration of third-country nationals?

REPLY OF THE  COMMISSIONRecommendation 10
The  Commission  cannot  design  a fund  structure  which 
ends the separation of the target population on the basis 
of nationality. The difference of target populations is based 
on the difference of legal bases. 

The EIF is part of the common immigration policy (Arti-
cle 79 points 1 and 2 TFEU), which aims at ensuring effi-
cient management of migration flows and fair treatment 
of third-country nationals residing legally in the Member 
States.

Recommendation 11
The  Commission  agrees  to  make  a closer  follow  up  in 
the  future  Multiannual  Financial  Framework  2014–20  of 
the arrangements put in place at national level to ensure 
coherence and complementarity with EU Funds.

88.
T h e   r a t e   o f   i m p l e m e n t a t i o n   i n   2 0 0 7  a n d  2 0 0 8   w a s 
impacted  by  the  reduced  eligibility  period  (reduced  by 
two thirds for 2007 and by one half for 2008) because of 
the late adoption of the legal basis and the arrangements 
to be put in place by the Member States. In addition, the 
two annual programmes were run in parallel which implied 
that the time for absorption of the two years EU allocations 
by responsible authorities which were relatively new and 
inexperienced, was very short.

Eligible actions were well defined in the legal basis from 
the  star t  and  therefore,  the  risk  of  funding  ineligible 
actions is low. 

90.
The Commission is making efforts so as to reduce the delay 
for adoption of annual programmes and reports, mainly by 
streamlining its own procedure and by implementing the 
same  computerised  system  of  communication  with  the 
Member States as the one of the Structural Funds. It is con-
fident that this will simplify the administrative processes at 
each stage of the procedure.

64

Recommendation 12
The Commission fully agrees with the recommendation 
to use the lessons learnt from the programming period 
2007–13 and has taken all steps to ensure that the legal 
basis will be adopted on time, in particular by adopting 
its proposal for a Regulation for the Asylum and Migration 
Fund  on  15  November  2011.  However,  the  Commission 
is not the only actor in the adoption process and cannot 
guarantee the achievement of this objective.

91.
Taking into account the delays in the adoption of the legal 
framework, the Commission considers that guidance has 
been provided as soon as possible. Implementing Rules 
were issued in March 2008 but have been extensively dis-
cussed with Member States well ahead of their adoption. 
As of April 2008 the Commission has organised a seminar 
on the Implementing Rules in order to draft the manual on 
eligibility rules that was distributed to Member States in 
June 2008. In addition, the fact that Member States were 
not able to spend their total EU allocation is not linked 
to the timing of the guidance but mainly to the novelty 
of the Fund, the inexperience of the Responsible Authori-
ties, the short eligibility period, and the fact that the two 
annual programmes 2007 and 2008 were run in parallel.

92.
A  management  and  control  system  is  composed  of  dif-
ferent  blocks,  all  of  them  are  not  needed  at  the  outset. 
Only the blocks that were in use at the first phase of the 
programming  period  could  be  checked  on  the  spot  by 
the Commission. Other ones could only be described on 
paper. 

93.
The case of the Member State quoted by the Court is well 
known by the Commission and mitigating measures have 
been taken to avoid any undue payment of EU Funds.

Recommendation 13
The  Commission  agrees  to  discuss  with  Member  States 
and  adopt  guidelines  for  implementation  of  the  new 
Fund as soon as possible whenever possible, taking into 
account the timetable for adoption of the new Fund which 
does not depend only on the Commission.

Recommendation 14
The system foreseen in the revised Financial Regulation 
will be different from the current one and will rely on for-
mal designation by the Member States based on designa-
tion criteria defined in the legal basis.

Special Report No 22/2012 – Do the European Integration Fund and European Refugee Fund contribute effectively to the integration of third-country nationals?

REPLY OF THE  COMMISSIONEuropean Court of Auditors

Special Report No 22/2012
Do the European Integration Fund and European Refugee Fund contribute effectively to the integration of third-country nationals?

Luxembourg: Publications Office of the European Union

2012 — 64 pp. — 21 × 29.7 cm

ISBN 978-92-9241-049-0
doi:10.2865/49933

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THIS REPORT ASSESSES WHETHER THE EUROPEAN INTEGRATION FUND AND 

EUROPEAN REFUGEE FUND CONTRIBUTE EFFECTIVELY TO THE INTEGRATION 

OF THIRD-COUNTRY NATIONALS IN THE EU. IT FOUND THAT WHILE POSI-

TIVE RESULTS COULD BE OBSERVED AT THE LEVEL OF INDIVIDUAL AUDITED 

PROJECTS, INADEQUATE SYSTEMS HAD BEEN SET UP TO MEASURE THE SUC-

CESS OF THE FUNDS. THE PROGRAMME DESIGN HAMPERED EFFECTIVENESS 

AND THERE WAS INADEQUATE COORDINATION WITH OTHER EU FUNDS. THE 

COURT  RECOMMENDS,  INTER  ALIA,  SIMPLIFICATION  OF  PROGRAMMING 

ARRANGEMENTS AND A COMPREHENSIVE ASSESSMENT OF INTEGRATION 

NEEDS REGARDLESS OF WHETHER MIGRANTS HAVE EU OR THIRD-COUN-

TRY NATIONALITY. BASED ON THIS ASSESSMENT, AN APPROPRIATE FUND(S) 

STRUCTURE SHOULD BE DESIGNED. 

EUROPEAN COURT OF AUDITORS