REPLIES OF THE COMMISSION TO THE SPECIAL REPORT OF THE EUROPEAN COURT OF AUDITORS "EU YOUTH GUARANTEE: FIRST STEPS TAKEN BUT IMPLEMENTATION RISKS AHEAD"
Date: 2015-03-23
Institutions: European Commission
Subjects: continuing education, fight against unemployment, humanisation of work, job access, job creation, youth policy, youth unemployment













EUR-Lex - 52015DC0143 - EN











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52015DC0143

REPLIES OF THE COMMISSION TO THE SPECIAL REPORT OF THE EUROPEAN COURT OF AUDITORS "EU YOUTH GUARANTEE: FIRST STEPS TAKEN BUT IMPLEMENTATION RISKS AHEAD" /* COM/2015/0143 final */









REPLIES OF THE
COMMISSION TO THE SPECIAL REPORT OF THE EUROPEAN COURT OF AUDITORS
"EU YOUTH
GUARANTEE: FIRST STEPS TAKEN BUT IMPLEMENTATION RISKS AHEAD"
EXECUTIVE
SUMMARY
V.
First bullet: The Commission
notes the recommendation addressed to Member States and would indeed welcome in
some cases a better overview of the estimated cost of all planned measures to
combat youth unemployment.
The template produced
by the Commission requested Member States to provide information on EU,
national, regional/local, employer and other funding sources thus encouraging
the Member States to give the complete information on the overall costs and
funding of a YG (including funding gaps).
19 out of 28 Member States have
provided this information (with different degrees of detail).
Second bullet: The Commission
accepts the recommendation and considers it as partially implemented, in
particular through the Council Recommendation on a Quality Framework for
Traineeships, the European Alliance for Apprenticeships and the related Council
Declaration and the monitoring of the quality of employment in the European
Semester.
Regarding the promotion of
qualitative attributes, the Commission will further stimulate the reflection
around "good-quality" offers, taking into account the qualitative
attributes mentioned in the Guidance for evaluation of the YEI. The Commission
will in particular: animate a debate on the concept of "good-quality"
offers in the next meeting of national YG coordinators, invite Member States to
discuss the concept of "good-quality" offer in the context of the
EMCO work, explore the possibility of addressing "good-quality" YG
offers under the Mutual Learning Programme (MLP), and provide further guidance
on "good-quality" in the YG FAQ document.
The Commission notes that ex post
evaluations will provide evidence on the quality of job offers, as recommended
in the guidance for the evaluation of YEI.
Third bullet: The Commission
accepts the recommendation and considers it as partially implemented. through
the indicators framework as endorsed by the EPSCO Council, through the relevant
arrangements that are set out in article 19 and Annex I and II of the ESF
Regulation and relevant CPR provisions related to monitoring and evaluation in
the case of measures financed from the YEI and through its commitment to report
on the implementation of the Youth Guarantee to the European Parliament and the
Council in 2016.
Monitoring
activities will feed into the Commission's assessment of the Youth Guarantee
implementation under future European Semesters. They will also inform the
Commission's 2016 report on the implementation of the Youth Guarantee, which
will be formally submitted to the European Parliament and the Council through
the appropriate channels.
INTRODUCTION
15. The Commission notes that a
further 11 billion aim at measures such as modernisation of employment services
and self- employment measures which will also indirectly support youth
employment. 
Over 26 billion euros will be
spent on education measures including life-long learning where young people are
likely to be among the main beneficiaries. 
OBSERVATIONS
37. The Commission would like to
remind that it operates in a soft law environment, based on a Council
recommendation and that while many sub-elements of a Youth Guarantee are
desirable where appropriate, not all of them need to be part of a particular
national scheme. 
Moreover, the evaluation of the
submitted YGIP was just a first step in a process of continued monitoring of
the implementation of the Youth Guarantee in Member States. The Commission
monitors the implementation of Youth Guarantee schemes within the European
Semester. The European Semester process covers a broad spectrum of national
policies which are linked to the delivery of a Youth Guarantee.
First indent: In the
context of the European Semester, the need for enhancing ICT/digital skills is
highlighted where appropriate.
Second indent: The Commission is
of the opinion that failure to consider a link between the non-acceptance of a
reasonable offer and unemployment or social assistance benefits does not
necessarily limit the effectiveness of a Youth Guarantee scheme.  
The Commission’s Staff Working
Document sets out that principles of mutual obligation such as participation in
active labour market policies could be considered when designing a Youth
Guarantee scheme[1].
In the Council
Recommendation the principle of mutual obligation is called upon in the context
of early intervention and activation (recommendation 10).
While "mutual
obligation" may carry important benefits, it does not figure in the
assessment grid, as it would be too prescriptive to judge a scheme against its
inclusion in case a Member State chooses to not base their scheme on it or in
case their national provisions and practices do not allow it.
Priority was therefore
given to assess the main building blocks of the Youth Guarantee and the
intended existence and coverage of offers.
41. In the context of an adoption
of an operational programme containing YEI-related measures, "a strategic
policy framework for promoting youth employment" must be in place before
any disbursement of Funds from the Commission. The Commission's assessment of
this pre-condition (so called YEI ex-ante conditionality) is based on the
Member State's self-assessment and the information provided therein. Whenever the Member
State has referred to additional national strategies on youth employment other
than the YGIP, the Commission had to base its assessment regarding the YEI
ex-ante conditionality fulfilment on all the strategic documents for youth
employment referred to by the Member States. Nevertheless, when assessing the
YEI ex-ante conditionality, the Commission's looks at the consistency with the
YGIP so that the ESF investments will match the policy objectives of the Member
State concerned.
42. The Commission notes that the
assessment framework for YGIP is not the same as for the YEI ex-ante
conditionality, as the two processes are driven by different objectives –
respectively policy objective (YG) and legal compliance (YEI).
The criteria for fulfilment of
the ex-ante conditionality do require "the existence of a strategic policy
framework for promoting youth employment including through the implementation
of the Youth Guarantee". The sub-criteria against which this "strategic
policy framework" should be assessed by the Commission services were also
laid down in the Regulation. The latter do not make any reference to the
existence of a YGIP and a fortiori to its positive assessment by the
Commission. 
Therefore, there is no automatic
link between the assessment of the YGIP which is done from a policy perspective
and against the Youth Guarantee recommendation and the assessment of the
YEI-related EAC which is done through a fixed set of criteria detailed in the
CPR. 
The Commission notes that such a
link which would have made the existence of a YGIP a legal requirement for
fulfilling the YEI ex-ante conditionality was proposed by the Commission but
rejected by the Council during the legislative process. 
43. The Commission refers to its
reply to paragraph 42. The sometimes nuanced or slightly different outcomes of
the two processes are explained by their different although to some extent
interlinked nature. 
The sub-criteria against which
the "strategy policy framework for promoting youth employment" should
be assessed contain also qualitative elements such as the identification of key
stakeholders, including the public authorities involved and the coordinating
arrangements with the partners, the set-up of early intervention and activation
systems as well as the monitoring arrangements. The assessment of these
qualitative elements is going beyond a pure formality check. 
Moreover, to the extent feasible,
the context of the Commission's assessment of the YEI ex-ante conditionality
fulfilment did serve as a channel for requesting certain modifications to the
YGIP (for example in the case of France).
Common Commission reply to
paragraphs 45 and 46.
The Commission agrees and would
like to point out that investing in a Youth Guarantee is crucial for the EU to
preserve its future growth potential. Significant EU financial support can help
- most notably from the European Social Fund and in the context of the Youth
Employment Initiative. But to make the Youth Guarantee a reality, Member States
also need to prioritise youth employment measures in their national budgets.
47.
19 out of 28 Member States have provided information on the envisaged sources
of funding of their Youth Guarantee scheme (with different degrees of detail).
In some cases, the Commission would however welcome a better overview of the
estimated cost of all planned measures even if it is aware that any
estimates of the costs of a Youth Guarantee are subject to caveats.
49. The Youth Guarantee
recommendation does not prescribe any precise way in which the Member States
will implement the Youth Guarantee since it will very much depend on the
national situation (i.e. number of the NEETs they have and their specific
characteristics). 
The impacts will therefore depend
on the choice of Member States as regards the targeting and the design of the
support.
As explained in the Explanatory
Memorandum of the Commission's proposal, it is accompanied by a Staff Working
Document (SWD), which goes into more details about what constitutes a Youth
Guarantee, addresses questions about costs and benefits of such schemes, and
describes one by one the ingredients necessary to make the Youth Guarantee a
success. Furthermore, in an annex, the SWD presents policies supporting youth
employment already in place in the 27 Member States and Croatia, reflecting the
various starting points of these countries towards setting up fully-fledged
Youth Guarantee schemes. 
The real cost of a Youth
Guarantee will also depend on the national circumstances and the way in which
it is set up and implemented in each Member State. As such, any estimates of
the costs of a Youth Guarantee are subject to a number of caveats. 
In that respect, country examples
of Austria, Finland, Sweden and the UK could be considered as an indication of
potential costs for the Member States intentions about implementing the Youth
Guarantee. 
50. The Commission refers to its
reply to paragraph 15.
53.
The Commission refers to its reply to paragraph 47.
54. The Commission
indeed informed France that the quantitative overall targets of the plan are
not sufficiently clear and indicated that doubts remain on the qualitative
aspects of the offers that Pôle Emploi will propose to the NEETs in order to
comply with the YG. Further
follow up is taking place in the context of the European semester. 
In its YGIP, Ireland provided a
table which sets out information on average participation, inflow of new
participants, the expected inflow of young people and the indicative cost of
youth provision. Irish authorities are reticent to project future participation
numbers until national budget allocations are decided and therefore did not
provide any figures beyond 2014. It was therefore not deemed necessary or
appropriate to request further information from the Irish authorities.
Common Commission reply to
paragraphs 55 and 56.
The Commission considered that it
was primarily important to be able to see if (sufficient) national resources
were allocated in addition to the EU funds. It therefore provided the Members
State with a template where they were asked to provide information on the
available funding sources, i.e. whether it would originate from EU, national,
regional/local, employer and/or other funding sources.
The breakdown between the
different EU funds was secondary at that stage, since the Operational
Programmes were to follow shortly. The Commission considered that a detailed
breakdown of EU funding sources by ESF/YEI funds would be provided within the
relevant OPs, especially as the informal negotiations on the OP financial plans
were still ongoing between the Member States and the Commission. 
57.
The Commission notes that regularity of YEI expenditure will be subject to
verifications as part of the normal assurance building process which duly takes
specific risks into account.
Common Commission reply to
paragraphs 61 and 62.
The Commission agrees that
"good-quality" is a crucial element for implementing the Youth
Guarantee. 
The Commission promotes a set of
qualitative attributes for traineeships (through the Council Recommendation on
a Quality Framework for Traineeships) and for apprenticeships (through the
European Alliance for Apprenticeships and the related Council Declaration). For
jobs, the Commission monitors the quality of employment in the European
Semester, with particular attention being paid to school-to-work transitions
and issues related to labour market segmentation. 
Regarding the quality of
employment in the open market, the Commission is of the view that any quality
assessment will be dependent on the situation of the relevant labour market,
including aspects such as labour laws or the current economic climate.
The Commission will further
stimulate the reflection around "good-quality" offers, taking into
account the qualitative attributes mentioned in the Guidance for evaluation of
the YEI. The Commission will in particular animate a debate on the concept of
"good-quality" offers in the next meeting of national YG
coordinators, invite Member States to discuss the concept of "good-quality"
offer in the context of the EMCO work, explore the possibility of addressing
"good-quality" YG offers under the Mutual Learning Programme (MLP),
and provide further guidance on "good-quality" in the YG FAQ
document.
63. The Commission refers to its
common reply to paragraphs 61 and 62.
In addition, the Commission
considers that a consistent implementation of the YG and a “one size fits all”
approach is neither possible nor  in line with the Council recommendation,
which clearly indicates that YG schemes should be in accordance with local,
regional and national circumstances. 
However, the Commission agrees
that an effective implementation of Youth Guarantee schemes is crucial. The
outcome based approach followed by the Commission has precisely many advantages
in assessing the effectiveness of the measures within the YG schemes, as it
takes into account the diverse labour market situations and the suitability of
an offer to the individual.
In this regard, the Commission is
of the view that, in general, an offer is of good quality if the person who
benefits from it achieves sustainable labour market attachment. That is to say,
not return to unemployment or inactivity thereafter; a "good-quality"
offer can thus be measured by its outcome. As said (cf. common reply to
paragraphs 61 and 62) the Commission will further stimulate the reflection
around "good-quality" offers.
The Commission notes that offers
of apprenticeships, traineeships and continued education, be them subsidised
offers – such as those financed under YEI/ESF programmes or under national
programmes – or not, are already covered by quality standards.
65. The Commission would like to
point out that a lengthy consensus building exercise was necessary to define a
common monitoring framework. This might have delayed the adoption of the Youth
Guarantee Council Recommendation at a critical moment and thus hindered swift
delivery.
68. The Commission would like to
point out that the results from the monitoring feed into the key documents
adopted by the European Commission in the context of the European Semester
(Commission Staff Working Documents, In- Depth Reviews, proposals for Country
Specific Recommendations). 
The Commission has regular
exchanges with the European Parliament on the European Semester developments.
Moreover, further to the 27-28
June 2013 European Council conclusions, the Commission will report to the European
Parliament and the Council in 2016 on the implementation of the Youth Guarantee
and on the operation of the YEI.
Common Commission reply to
paragraphs 69 and 70. 
The Commission notes that a second review of
progress on the implementation of Youth Guarantee schemes in 21 Member States
took place in EMCO on 3 December 2014 with conclusions for each reviewed Member
State. These will be followed up in May 2015. All December 2014 EMCO reviews
focused extensively on the Youth Guarantee schemes in a consistent manner,
according to Working Methods applied to all Member States. Both the May and
December 2014 reviews were echoed in the following EPSCO meetings on Youth
unemployment and the Youth Guarantee.
71. The Indicator Framework for
Monitoring the Youth Guarantee was endorsed by EMCO on 22 September 2014. The
EPSCO Council endorsed in December 2014 the EMCO Key messages on the Indicator
Framework for Monitoring the Youth Guarantee which ask for a strong political
commitment to overcome the existing obstacles in data collection and ensure a
sound monitoring system of the Youth Guarantee at EU and Member State level,
based on the proposed framework.
See also Commission reply to
paragraph 65.
72. The Commission agrees that
the continued commitment of Member States is needed. The YG pilot data
collection was launched by the EMCO indicators' group in October 2014. The aim
was to test the methodology proposed for the regular administrative data
collection for monitoring the implementation of the Youth Guarantee and assess
the obstacles faced by Member States and how they can be overcome in view of
launching regular data collection in June 2015. By 18 February all Member
States but three have sent their contributions. The remaining contributions are
expected soon.
73. The reading of the scoreboard
of key
employment and social indicators is supplemented by the additional information
derived from –inter alia- the Employment Performance Monitor (EPM), and the
assessment of policy measures undertaken by the Member States.
Common Commission reply to
paragraphs 74 to 76. 
The Commission emphasizes that
the formulation and adoption of CSR is foremost a political process, where on
the basis of country specific analysis in the Staff working documents, the
Commission makes a proposal which is then reviewed through a multilateral
surveillance process in Committees, Council Groups and subsequently endorsed by
the European Council. 
The Commission's proposals for
Country Specific Recommendations take into account the specificities of each
country's situation.
Box 7 - Country-Specific
Recommendations in 2013 - Examples of Lithuania and Italy
The Commission considers that
recommendations for both Lithuania and Italy took duly into account the
specificities of each country's situation. 
77. The Commission notes that on
a whole, the Semester process is leading, over a medium term perspective, to
considerable reform efforts in Member States. 
80. The Commission considers that
the YGIP submitted by Member States provide already in most cases a useful
general overview of all Youth Guarantee measures. 
Moreover, the Commission has set
up a monitoring system for the Youth Guarantee. Structural reforms are
monitored through the European Semester, including EMCO. Measures targeting
individuals will be monitored both through the Indicator Framework for
Monitoring the Youth Guarantee, and in the case of measures financed from the YEI,
through the relevant arrangements that are set out in article 19 and Annex I
and II of the ESF Regulation and relevant CPR provisions related to monitoring
and evaluation.
84. The Annex II ESF indicators
for YEI have been designed to follow as closely as possible the ESF Annex I
common indicators. At the same time, they reflect the specific nature of YEI.
First indent: For the purpose of
ensuring the quality result in relation to the (YEI) funding provided, the
Commission is interested in measuring the overall outcomes in relation to the
change in the person's status – namely that from being a NEET at the stage of
entering the operation to a potential change after the YEI support.
The Youth Guarantee
has its own monitoring requirements which will allow tracking the type of
offers provided under the Youth Guarantee from 2016 onwards. 
Second indent: The YEI
indicators follow the logic and pattern of the ESF common indicators.
Subsequent monitoring
for former participants in YEI measures places additional burden on the
participants and administrative resources. For some of the measures such
extensive obligatory monitoring might be seen as costly and excessive. Effects
observed after prolonged time also decrease causality linking observations to
the interventions, decreasing the value-added of these observations.
However, Member States
can in addition to compulsory monitoring decide to have additional longer term
indicators, for example to repeat a survey after 6 months. Also, Member States
have an obligation to carry out impact evaluations, which will provide insights
on long term effects of interventions such as income differentials for
subsequent year and similar indicators in addition to the indicators presented
in Annex II.
Third indent: Whenever
a Member State has stated in its OP that it plans to extend the target group to
below 30 years, the Commission has requested that the Member State includes
additional programme-specific indicators to cover the 25-29 group.
Result indicators are
not age specific as such and do not cover any age group such as 15-18 etc.
However, Member States are asked by the Commission to include Programme
specific Output indicators for YEI age group 25-29, if they decide to target
them. Such indicators will allow assessing effectiveness of interventions when
crossed with YEI Annex II Result indicators.
CONCLUSIONS AND RECOMMENDATIONS
87.
See Commission reply to paragraph 37.
89. The Commission refers to its
reply to paragraph 47.
The Commission notes that the
Council recommendation does not prescribe any precise way in which the Member
States will implement the YG (i.e. employment, continued education,
apprenticeship or a traineeship) since it will depend on the national situation
(i.e. how many NEETs they have, the structure of NEETs). The targeting and the
design of the precise support influences the costs and benefits and makes it
difficult to estimate in advance the costs and benefits of all potential
options.  
The Commission however agrees
that there might be a risk that total funding may not be adequate to implement
the Youth Guarantee schemes and has encouraged Member States to prioritise
youth employment measures in their national budgets.
It should also be recalled that
EU funds support to the YG goes beyond direct YEI and ESF measures for young
persons' training and employment measures. The ESF also supports labour market
services modernisation, self-employment, education and social inclusion
measures – which partly also support youth employment from a structural reform
point of view.
Recommendation 1
The Commission notes the
recommendation addressed to Member States and would indeed welcome in some
cases a better overview of the estimated cost of all planned measures to combat
youth unemployment
The template produced
by the Commission requested Member States to provide information on EU,
national, regional/local, employer and other funding sources thus encouraging
the Member States to give the complete information on the overall costs and
funding of a YG (including funding gaps).
19
out of 28 Member States have provided this information (with different degrees
of detail).
90.
The Commission considers that a consistent implementation of the Youth
Guarantee and a “one size fits all” approach is neither possible nor in line
with the Council recommendation, which clearly indicates that YG schemes should
be in accordance with local, regional and national circumstances. 
The Commission agrees that an
effective implementation of Youth Guarantee schemes is crucial. The outcome
based approach followed by the Commission has precisely many advantages in
assessing the effectiveness of the measures within the YG schemes, as it takes
into account the diverse labour market situations and the suitability of an
offer to the individual.
In this regard, the Commission is
of the view that, in general, an offer is of good quality if the person who
benefits from it achieves sustainable labour market attachment. That is to say,
not return to unemployment or inactivity thereafter; a "good-quality"
offer can thus be measured by its outcome.
The Commission notes that offers
of apprenticeships, traineeships and continued education, be them subsidised
offers – such as those financed under YEI/ESF programmes or under national
programmes – or not, are already covered by quality standards.
In this regard, the Commission
promotes a set of qualitative attributes for traineeships (through the Council
Recommendation on a Quality Framework for Traineeships) and for apprenticeships
(through the European Alliance for Apprenticeships and the related Council
Declaration). For jobs, the Commission monitors the quality of employment in
the European Semester, with particular attention being paid to school-to-work
transitions and issues related to labour market segmentation. 
Regarding the quality of
employment in the open market, the Commission notes that any quality assessment
will be dependent on the situation of the relevant labour market, including
aspects such as labour laws or the current economic climate.
Recommendation 2
The Commission accepts the
recommendation and considers it as partially implemented, in particular through
the Council Recommendation on a Quality Framework for Traineeships, the
European Alliance for Apprenticeships and the related Council Declaration and
the monitoring of the quality of employment in the European Semester.
Regarding the promotion of
qualitative attributes, the Commission will further stimulate the reflection
around "good-quality" offers, taking into account the qualitative
attributes mentioned in the Guidance for evaluation of the YEI. The Commission
will in particular: animate a debate on the concept of "good-quality"
offers in the next meeting of national YG coordinators, invite Member States to
discuss the concept of "good-quality" offer in the context of the
EMCO work, explore the possibility of addressing "good-quality" YG
offers under the Mutual Learning Programme (MLP), and provide further guidance
on "good-quality" in the YG FAQ document.
The Commission notes that ex post
evaluations will provide evidence on the quality of job offers, as recommended
in the guidance for the evaluation of YEI.
91. The Commission monitors the
implementation of the Youth Guarantee within the European Semester, including
through bilateral meetings with member states, and through fact finding
missions. 
Through its membership in the
Employment Committee (EMCO) – in its preparation of Council deliberations – the
Commission also contributes to the multilateral surveillance on Youth Guarantee
implementation. Dedicated multilateral surveillance reviews were held by EMCO
in this regard once in 2013 and twice in 2014. Both the May and December 2014
reviews were echoed in the following EPSCO meetings on Youth unemployment and
the Youth Guarantee.
The Commission, where
appropriate, proposes country-specific recommendations to Member States, The
conclusions of the EMCO multilateral reviews feed into the final CSR
negotiations.
EMCO endorsed an Indicator
Framework for Monitoring the Youth Guarantee on 22 September 2014, based on
macroeconomic, implementation and follow-up levels indicators which, taken
together, will aim to provide a holistic view of Youth Guarantee schemes’
impact on the labour market situation of young people across Europe. The
administrative data necessary for the 'implementation level' is currently
tested through a pilot data collection exercise in all 28 Member States, with
regular data collection due to start in 2015. Key messages on the Indicator
Framework were endorsed by the EPSCO Council on 11 December 2014, highlighting
Member States’ political commitment to providing the necessary data.
Measures targeting individuals
will be monitored both through the Indicator Framework for Monitoring the Youth
Guarantee, and in the case of measures financed from the YEI, through the
relevant arrangements that are set out in article 19 and Annex I and II of the
ESF Regulation and relevant CPR provisions related to monitoring and
evaluation. Regarding specifically the YEI, the Commission has set up a framework
for monitoring the YEI actions implemented within YG framework, by setting
common indicators in its ESF regulation. 
Recommendation 3
The Commission accepts the
recommendation and considers it as partially implemented. through the
indicators framework as endorsed by the EPSCO Council, through the relevant
arrangements that are set out in article 19 and Annex I and II of the ESF
Regulation and relevant CPR provisions related to monitoring and evaluation in
the case of measures financed from the YEI and through its commitment to report
on the implementation of the Youth Guarantee to the European Parliament and the
Council in 2016.
Monitoring
activities will feed into the Commission's assessment of the Youth Guarantee
implementation under future European Semesters. They will also inform the
Commission's 2016 report on the implementation of the Youth Guarantee, which
will be formally submitted to the European Parliament and the Council through
the appropriate channels.
[1]
European
Commission Staff Working Document, SWD(2012) 409 final, p. 4.