Special Report No 14 // 2016#EU policy initiatives and financial support for Roma integration: significant progress made over the last decade, but additional efforts needed on the ground #(pursuant to Article 287(4), second subparagraph, TFEU)
Date: 2016-05-04
Institutions: European Court of Auditors
Subjects: EU Member State, EU aid, EU programme, Roma, access to education, equal treatment, ethnic discrimination, job access, marginalisation, social integration

EN 

2016 

NO 14

Special Report  EU policy initiatives and 

financial support for Roma 
integration: significant 
progress made over the 
last decade, but additional 
efforts needed on the 
ground

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EN 

2016 

Special Report

NO 14

EU policy initiatives and 
financial support for Roma 
integration: significant 
progress made over the 
last decade, but additional 
efforts needed on the 
ground

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

Audit team

02

The ECA’s special reports set out the results of its performance and compliance audits of specific budgetary areas or 
management topics. The ECA selects and designs these audit tasks to be of maximum impact by considering the risks 
to performance or compliance, the level of income or spending involved, forthcoming developments and political and 
public interest.

This performance audit was produced by Audit Chamber II — headed by ECA Member Henri Grethen — which specialises 
in structural policies, transport and energy spending areas. The audit was led by the Reporting Member Henri Grethen, 
supported by Marc Hostert, Head of private office; the core audit team consisted of Emmanuel Rauch, Principal Manager, 
Naiara Zabala Eguiraun, Aino Nyholm and Zhivka Kalaydzhieva, Auditors. Language support was provided by Richard 
Moore.

Contents

03

Paragraph

Glossary

I – VII 

Executive summary

1 – 14 

Introduction

1 – 3 

The Roma population

4 – 8 

Legal and policy framework

9 – 12 

How does the EU provide financial support to Roma integration measures?

13 – 14  Role of other European and international organisations in relation to Roma integration

15 – 26  Audit scope and objectives

27 – 120  Observations

27 – 56  Progress made in terms of strategies in place at EU and Member State level, but most 
improvements came too late to have an impact on the 2007-2013 programme period

29 – 40  EU policy initiative on Roma inclusion was agreed upon in 2011, after the EU enlargements in 2004 and 2007

41 – 56  Progress at Member State level: National Roma integration strategies had been adopted, but some 

shortcomings remained

57 – 94  More attention given to Roma integration measures in the 2014-2020 period as compared to 2007-

2013 in the field of cohesion policy

59 – 65  Despite the lack of mention of Roma integration in the legal framework for 2007-2013, the selected Member 

States referred to Roma integration in their OPs

66 – 83  Greater focus on Roma issues at EU level was reflected in the ESIF framework for 2014-2020

84 – 94  OP-level monitoring tools at disposal during the 2007-2013 programme period were ill-suited for measuring 

the performance of Roma integration measures

 
Contents 

04

95 – 120  Most projects were carried out as planned, but ‘best practice’ criteria contributing to successful 

Roma inclusion were not always applied and monitoring project performance was difficult

96 – 100  All projects examined were in line with OP objectives, but selection procedures did not specifically aim to 

select Roma inclusion-related projects

101 – 102  Projects were generally carried out according to plan

103 – 115  Indication that better consideration of Roma-specific criteria, such as the common basic principles (CBPs) on 

Roma inclusion, contributed positively to project performance

116 – 120  Assessing the results for the 2007-2013 period was made more difficult by difficulties in gathering 

information about Roma people

121 – 133  Conclusions and recommendations

Annex I  —  Operational programmes examined

Annex II  — 

 Governance bodies of the Structural Funds in the visited Member States

Annex III  — 

 Common basic principles (CBPs) on Roma inclusion

Reply of the Commission

 
 
 
 
Glossary

05

Common basic principle (CBP): The common basic principles (CBPs) are a set of 10 criteria for ensuring success 
in Roma inclusion initiatives. These principles were discussed at the first meeting of the European Platform for 
Roma inclusion in 2009 in Prague. They were then included as an annex to the conclusions of a meeting of the 
Employment, Social Policy, Health and Consumer Affairs Council held on 8 June 2009.

Country-specific recommendations (CSR): Country‑specific recommendations (CSR) are recommendations 
relating to structural challenges which it is appropriate to address through multiannual investments that fall directly 
within the scope of the ESI Funds as set out in the fund‑specific regulations. They are adopted by the Commission in 
accordance with Articles 121(2) and Article 148(4) of the Treaty on the Functioning of the European Union (TFEU).

Discrimination: Directive No 2000/43 defines two types of discrimination:

 ο

 ο

Direct discrimination occurs where one person is treated less favourably than another is, has been or would 
be treated in a comparable situation on grounds of racial or ethnic origin.

Indirect discrimination occurs where an apparently neutral provision, criterion or practice would put persons 
of a racial or ethnic origin at a particular disadvantage compared with other persons, unless that provision, 
criterion or practice is objectively justified by a legitimate aim and the means of achieving that aim are 
appropriate and necessary.

European Regional Development Fund (ERDF): The European Regional Development Fund (ERDF) aims at 
reinforcing economic and social cohesion within the European Union by redressing the main regional imbalances 
through financial support for the creation of infrastructure and productive job‑creating investment, mainly for 
businesses.

European Social Fund (ESF): The European Social Fund (ESF) aims at strengthening economic and social cohesion 
within the European Union by improving employment and job opportunities (mainly through training measures), 
encouraging a high level of employment and the creation of more and better jobs.

European Structural and Investment Funds (ESIF): The European Structural and Investment Funds (ESIF) are the 
Union’s means of reducing disparities between the levels of development of its various regions, and of helping less 
developed regions to catch up. Based on Article 174 TFEU, they contribute to the goal of strengthening economic, 
social and territorial cohesion.

Ex ante conditionalities (EAC): Ex ante conditionalities (EAC) are criteria established in partnership agreements, 
which are regarded as necessary prerequisites for the effective and efficient use of Union support covered by those 
agreements. When preparing ERDF, Cohesion Fund and ESF OPs under the 2014‑2020 programme period, Member 
States have to assess whether these conditions are fulfilled. If they have not been fulfilled, action plans need to be 
prepared to ensure fulfilment by 31 December 2016.

Institutional discrimination: Discrimination that has become ingrained in organisational structures and 
procedures.

Intermediate body: An intermediate body is any public or private body or service which acts under the 
responsibility of a managing authority, or which carries out duties on behalf of such an authority vis‑à‑vis 
beneficiaries implementing operations.

Glossary 

06

Managing authority: A managing authority is a national, regional or local public authority (or any other public 
or private body), which has been designated by a Member State to manage an operational programme. Its 
tasks include selecting projects to be funded, monitoring how projects are implemented and reporting to the 
Commission on financial aspects and results achieved.

National Roma contact point (NRCP): The national Roma contact point (NRCP) is a national authority whose role 
is to coordinate the development and implementation of the national Roma integration strategy/set of integrated 
policy measures.

National Roma integration strategy (NRIS): Each Member State with a Roma population was asked by the 
Commission to prepare a national Roma integration strategy (NRIS) covering the period 2011‑2020 or, if a strategy 
already existed, to adapt it to meet the EU’s Roma integration goals, with targeted actions and sufficient funding 
(national, EU and other) to deliver them. These strategies should also propose solutions to address the current 
barriers to a more effective use of EU funds and lay the foundations of a robust monitoring mechanism to ensure 
concrete results for Roma. Some Member States do not have a NRIS as such, but have a ‘set of integrated measures’ 
instead.

Non-governmental organisation (NGO): The term non‑governmental organisation (NGO) is used to refer to 
a range of different organisations that typically share the following characteristics:

 ο

 ο

 ο

 ο

They are not created to generate profit. Although they may have paid employees and engage in 
revenue‑generating activities, they do not distribute profits to members.

They are voluntary citizens’ groups.

They must have some degree of formal or institutional existence (e.g. statutes or other governing document 
setting out their mission, objectives and scope) as they are accountable to their members and donors.

They are independent, in particular of government, public authorities, political parties and commercial 
organisations.

Operational programme (OP): An operational programme (OP) sets out a Member State’s priorities and specific 
objectives and how the EU funding (EU and national public and private co‑financing) will be used during a given 
period (generally 7 years) to finance projects. These projects must contribute to achieve a certain number of 
objectives specified at the level of the OP’s priority axis. OPs exist for each of the funds in the Cohesion area (i.e. 
ERDF, Cohesion Fund and ESF). An OP is prepared by the Member State and has to be approved by the Commission 
before any payments from the EU budget can be made. OPs can only be modified during the period covered if both 
parties agree.

Output: That which is produced or accomplished with the resources allocated to an intervention (e.g. grants 
distributed to farmers, training courses delivered to unemployed people, a road built in a developing country).

Result: Immediate changes that arise for direct addressees at the end of their participation in an intervention (e.g. 
improved accessibility to an area due to the construction of a road, trainees who have found a job).

Glossary 

07

Segregation/desegregation

 ο

 ο

Segregation is caused by a number of factors, including discriminatory actions, economic and demographic 
mechanisms. It is characterised by the physical and social separation of members of a marginalised group from 
members of non‑marginalised groups and unequal access to mainstream, inclusive and high‑quality services.

Desegregation means action to eliminate segregation. Desegregation measures should establish the 
conditions for equal access to high‑quality services, including education, housing, labour market, health and 
any other relevant field.

Social inclusion: The process of improving the terms for individuals and groups to take part in society.
Social inclusion aims to empower poor and marginalised people to take advantage of burgeoning global 
opportunities. It ensures that people have a voice in decisions which affect their lives and that they enjoy equal 
access to markets, services and political, social and physical spaces.

Executive summary

08

I
The Roma people of Europe have been subject to discrimination since their arrival on the territory of today’s Euro‑
pean Union many centuries ago. Today, the Roma population is the largest ethnic minority in the EU, at an estimated 
6.2 million, and is mostly marginalised. In the Member States where the concentration of Roma population is high‑
est, Roma people account for between 15 and 20 % of school pupils and new labour market entrants.

II
The greater part of EU financial support for social inclusion measures in general, including measures promoting 
Roma inclusion, is provided through the European Regional Development Fund (ERDF) and the European Social 
Fund (ESF). The amount channelled specifically to Roma integration initiatives is not recorded. However, Mem‑
ber States’ planning documents suggest that around 1.5 billion euros has been earmarked for the socioeconomic 
integration of marginalised communities such as Roma during the 2014‑2020 programme period. Similar indicative 
figures are not available for 2007‑2013.

III
In our audit, we assessed whether the EU policy initiatives and financial support through the ERDF and ESF had 
contributed effectively to Roma integration. In particular, we examined whether:

‑ 

‑ 

‑ 

the EU and national Roma strategies facilitated the effective use of the ERDF and ESF for Roma inclusion meas‑
ures in each programme period;

the ERDF and ESF framework for each programme period was designed so as to allow effective support Roma 
integration measures; and

projects implemented under the ERDF and the ESF during the 2007‑2013 programme period contributed effec‑
tively to Roma integration.

The audit work was carried out at the Commission and in four Member States (Bulgaria, Spain, Hungary and Roma‑
nia), and covered the period from 2007 to 2015.

Executive summary 

09

IV
We found that the Commission has made significant progress in setting out EU policy initiatives promoting Roma 
integration, and that all the Member States visited had developed a national Roma integration strategy (NRIS) by 
2012, but that this had come too late to have an impact on the design of ERDF and ESF operational programmes 
(OPs) and the selection of projects during the 2007‑2013 programme period. A number of shortcomings remain 
as regards these NRISs. First, the national strategies do not indicate what level of funding is needed to carry out 
the proposed measures for Roma inclusion. They also do not state the amount of money available for such meas‑
ures from the national budget and, through the ERDF and ESF, from the EU budget. Second, anti‑discrimination 
and anti‑gypsyism have not been given enough attention. Third, the need for active participation by civil society 
organisations, in particular representatives of the Roma community itself, was not always taken into account in the 
selected Member States when NRISs were being drafted. Finally, the role of national Roma contact points (NRCP) set 
up to coordinate the development and implementation of the NRISs has sometimes been undermined by a mis‑
match of resources and responsibilities.

V
In relation to the 2014‑2020 period, a number of improvements are noted: for example, Roma integration is explic‑
itly referred to in the European structural and investment funds (ESIF) regulation and specific funding priority has 
been introduced. Moreover, Member States with country‑specific recommendations (CSRs) related to Roma integra‑
tion are obliged to devote funds to promoting it. We consider, however, that additional efforts are required at both 
Commission and Member State level to make sure that these changes will result in projects better contributing to 
Roma integration on the ground.

VI
Most ERDF and ESF projects examined during our audit had achieved their general objectives, but these objectives 
were often not specifically Roma‑related. We also concluded that projects that had been selected and implemented 
in accordance with ‘best practice’ criteria adopted by the Council, the so‑called common basic principles on Roma 
inclusion (CBP), were more likely to contribute effectively to the integration of the Roma population. Moreover, 
we found that monitoring the progress made by Roma integration projects has been difficult, mainly because of 
shortcomings in relation to the availability and quality of data on Roma participants. The lack of comprehensive and 
robust data is a problem not only in relation to projects, but also for policymaking at EU and national level. Unless 
swift action is taken, this situation will remain unchanged for the 2014‑2020 period.

Executive summary 

10

VII
We make the following recommendations in this report:

Recommendation 1

The Member States should, when revising their NRISs or when making amendments:

(a)  specify what level of funding is needed to carry out the measures for Roma inclusion proposed in the strategy. 
NRISs should indicate the funding available for such measures from the national budget and, through the ERDF 
and ESF, from the EU budget. The Member States should also formally undertake to ensure that efforts to imple‑
ment measures in favour of Roma integration are not jeopardised by short‑term changes in political priorities;

(b)  include indicators and target values which deal with anti‑discrimination or, more specifically, anti‑gypsyism. 
During the 2014‑2020 programme period, these indicators should also be taken into account in the design of 
measures promoting the inclusion of marginalised Roma communities within the ESIF framework, in line with 
the requirements of the racial equality directive;

(c)  ensure that civil society organisations including Roma representatives are systematically consulted and included 

when Roma integration measures are being planned and implemented;

(d)  define in more detail the role played by NRCPs in relation to the NRISs, and ensure that the NRCPs’ powers and 

responsibilities are commensurate with the resources made available to them.

Recommendation 2

(a)  The Commission should make sure, when revising relevant operational programmes that measures carried out 

under the ESIF are of an inclusive nature and contain provisions aimed at fighting segregation. Segregational 
practices should be clearly described and explicitly excluded from funding under the ESIF framework (and not 
only mentioned in the recitals), particular attention being paid in this connection to education and housing 
projects. This would help to reinforce the link between CSRs and the use of the ESIF.

(b)  The Commission should make full use in OP monitoring committee meetings of the information contained in 
the reports which Member States are required to provide from 2016 under the Council recommendation on ef‑
fective Roma integration measures, as well as of the findings arising from that information. This is to ensure that 
the areas of weakness identified in the reports are tackled by means of ESIF and/or Member State funds (e.g. by 
reallocating funds to areas where shortcomings have been identified).

Executive summary 

11

Recommendation 3

Member States should make use of the ‘best practice’ criteria for Roma integration (such as the Council’s 10 CBPs) 
when making calls for proposals and selecting projects. Where appropriate, calls should be organised to select 
long‑term projects in favour of marginalised Roma communities. Finally, wherever possible, the allocation of ESIF 
funding should be made subject to the sustainability of projects, without continued EU funding, after their comp‑ 
letion. These aspects should also be considered when the 2014‑2020 operational programmes are modified.

Recommendation 4

The Commission should ensure, in the next programme period or when revising the operational programmes, 
that Roma integration objectives included in the NRISs are reflected in the ESIF framework at all operational levels, 
whenever applicable. In this context, it should ensure that data are collected reliably in order to allow progress to 
be monitored and evaluated between individual projects and at all levels of administration.

Recommendation 5

Member States should complement the common output and results indicators set out in the ESIF legislation with 
Roma‑specific indicators, where appropriate. These indicators should be aligned with those specified in the NRISs, 
and they should subsequently be used in the monitoring of the 2014‑2020 operational programmes. They could 
build on those developed by the Fundamental Rights Agency in 2016.

Recommendation 6

The Member States should consider acting together, in view of preparations for the next programme period, to seek 
to ensure legal certainty on the use of ESF to fund any social inclusion measures irrespective of a link to employ‑
ment. The removal of legal uncertainty would facilitate the Member States in making full use of the ESF for the 
purpose of social inclusion, including through measures to combat discrimination.

Recommendation 7

The Commission should consider proposing changes to the ESIF legislation to ensure that, from the programme 
period beginning in 2020, the distribution of funds among the different Member States takes into account specific 
social inclusion indicators: in particular, the proportion of marginalised groups such as the Roma within the popula‑
tion. It should ensure that any additional ESF funds made available to Member States as a result of this change are 
earmarked for the specific purpose of supporting marginalised communities.

Recommendation 8

(a)  The Commission should work together with the Member States to develop a common methodology which 
provides relevant data on the Roma population to monitor their social inclusion, in line with national legal 
frameworks and EU legislation, including existing possible derogations. This should be done at the latest when 
preparing the next programme period.

(b)  The Commission should encourage Member States, in accordance with national legal frameworks and EU legis‑
lation, including existing possible derogations, to collect in a comprehensive manner statistical data on ethnic‑
ity within the next 2 years. Eurostat could include relevant questions in surveys such as the Labour Force Survey 
and in the European Union Statistics on Income and Living Conditions.

Introduction

12

The Roma population

01 
The Roma people of Europe are the descendants of groups which left the Indian 
subcontinent around 1 000 years ago and began arriving on the territory of 
today’s European Union in the 14th century. By 1450, the Roma people had set‑
tled in almost the whole of Europe. In central Europe, the first deportations and 
expulsions of Roma people were already taking place by then. The term ‘Roma’ 
refers to different groups (see Box 1) which have certain cultural characteristics in 
common, as well as a history of persistent marginalisation in European societies.

1
x
o
B

What do we mean by ‘Roma’?

According to the Council of Europe1, ‘Roma’ refers to Roma, Sinti, Kale, and related groups in Europe, includ‑
ing Travellers and the Eastern groups (Dom and Lom), and covers the wide diversity of the groups concerned, 
including persons who identify themselves as Gypsies.

Although the cultural and ethnic identity of these groups is not homogenous, for practical reasons, we have 
used the word ‘Roma’ to refer to all of them.

1  Council of Europe, ‘Descriptive Glossary of terms relating to Roma issues’, 2012.

02 
Today, the Roma population is the largest ethnic minority in Europe. Estimates 
of the size of the community vary widely between 10 and 12 million people. Of 
these, around 6.2 million reside in the EU, most of them in central and eastern 
Member States. The vast majority of Roma in Europe (80‑85 %) now live a settled 
lifestyle2. Roma people maintaining an itinerant lifestyle should not be confused 
with Roma people moving from one EU Member State to settle in another. Fig-
ure 1 shows the concentration of Roma people in the EU, candidate countries3 
and potential candidate countries4.

2  COM(2011) 173 final of 

5 April 2011 ‘An EU Framework 
for National Roma Integration 
Strategies up to 2020’.

3  Albania, former Yugoslav 

Republic of Macedonia, 
Montenegro, Serbia and 
Turkey.

4  Bosnia and Herzegovina and 

Kosovo*.

 
Introduction 

13

(2012)

1 Estimated Roma population in the EU, candidate and potential candidate countries 
e
r
u
g
i
F

FI
11 000

EE
1 050

LV
12 500

LT
3 000

PL
32 500

SK
490 000

HU
750 000

RS*
600 000

AL
115 000

RO
1 850 000

BG
750 000

SE
50 000

DK
2 500

DE
105 000

CZ
200 000

AT
35 000
SI
8 500

IE
37 500

UK
225 000

NL
40 000

BE
30 000

LU
300

FR
400 000

IT
150 000

HR
35 000

Bosnia and Herzegovina
58 000
ME
20 000

Kosovo*
37 500

MT
0

ES
750 000

PT
52 000

EU Member States

Candidate countries

Potential candidate countries

Number = Average estimated size of Roma population.
Average estimate as proportion of total population (in %):

From 5 to 10

From 1 to 4.9 

From 0.4 to 0.9  

Less than 0.4

Source: ECA, based on Council of Europe data.

The former Yugoslav 
Republic of Macedonia
197 000

TR
2 750 000

EL
175 000

CY
1 250

Administrative boundaries: © EuroGeographics © UN-FAO © Turkstat
Cartography: Eurostat - Gisco, 01/2015

0

200

400

600

800 km

* All reference to Kosovo, whether to the territory, institutions or population, 
in this text shall be understood in full compliance with United Nations Security 
Council Resolution 1244 and without prejudice to the status of Kosovo.

 
Introduction 

14

03 
Around four fifths of the EU’s estimated Roma population live in the eight 
Member States listed in Table 1. In the Member States where the concentration 
of Roma population is highest (Bulgaria, Slovakia, Romania and Hungary), Roma 
people account for between 15 and 20 % of school pupils and new labour market 
entrants.

Member States with the largest estimated number of Roma people

1
e
l
b
a
T

Member State

Average estimated size of Roma population

Number of people

Proportion of total 
population

Minimum estimate

Maximum estimate

Romania 

Bulgaria 

Hungary 

Spain 

Slovakia 

France 

Czech Republic 

Greece 

Total 

Total for all EU

1 850 000

750 000

750 000

750 000

490 000

400 000

200 000

175 000

5 365 000

6 197 100

8.6 % 

9.9 % 

7.5 % 

1.6 % 

9.0 % 

0.6 % 

1.9 % 

1.5 % 

3.0 %

1.2 %

1 200 000

700 000

500 000

500 000

380 000

300 000

150 000

50 000

3 780 000

4 368 700

2 500 000

800 000

1 000 000

1 000 000

600 000

500 000

250 000

300 000

6 950 000

8 025 500

Note: The ‘Total for all EU’ figures include Croatia.

Source: Council of Europe, ‘Estimates and official numbers of Roma in Europe’, July 2012.

 
Introduction 

15

Legal and policy framework

04 
The EU treaties are the main legal basis for all EU initiatives aimed at promoting 
social inclusion in general, and the integration of Roma people in particular. Art‑ 
icle 2 of the Treaty on the European Union (TEU) is particularly relevant: among 
other things, it safeguards the rights of persons belonging to minorities (see 
Box 2).

2
x
o
B

Article 2 of the Treaty on the European Union

‘The Union is founded on the values of respect for human dignity, freedom, democracy, equality, the rule of 
law and respect for human rights, including the rights of persons belonging to minorities. These values are 
common to the Member States in a society in which pluralism, non‑discrimination, tolerance, justice, solidarity 
and equality between women and men prevail’.

05 
Furthermore, Article 10 of the Treaty on the Functioning of the European Union 
(TFEU) establishes the EU’s aim of combating discrimination on the grounds of ra‑
cial or ethnic origin by means of action by the Council (Article 19 TFEU). Article 21 
TFEU also establishes the right of EU citizens to move and reside freely within the 
EU.

06 
The following legal and policy instruments are also relevant to Roma integration 
measures:

—  the Charter of Fundamental Rights of the European Union of 20005, in par‑

ticular Article 21 on non‑discrimination. It became legally binding after the 
Treaty of Lisbon entered into force on 1 December 2009;

—  the two Council directives from 2000 on equal treatment6: the racial equality 
directive, which prohibits discrimination on the grounds of racial or ethnic 
origin in various areas; and the employment equality directive, which con‑
tains provisions stipulating equal treatment in the workplace;

5  Charter of Fundamental Rights 
of the European Union (OJ 
C 364, 18.12.2000, p. 1).

6  Council Directive 2000/43/EC 

of 29 June 2000 implementing 
the principle of equal 
treatment between persons 
irrespective of racial or ethnic 
origin (‘racial equality 
directive’) (OJ L 180, 19.7.2000, 
p. 22), Council Directive 
2000/78/EC of 
27 November 2000 
establishing a general 
framework for equal 
treatment in employment and 
occupation (‘employment 
equality directive’) (OJ L 303, 
2.12.2000, p. 16).

 
Introduction 

—  the European Parliament and Council Directive of 2004 on the right of free 

movement for EU citizens7;

—  the Council Framework Decision of 2008 on combating racism and xenopho‑
bia8, which defines a common criminal law approach to fight against racist 
and xenophobic speech and crime;

—  the Council Recommendation of 2013 on effective Roma integration meas‑

ures9; and

—  the Commission’s Communication of 2011 on the EU’s framework for national 
Roma integration strategies up to 202010, which also establishes the role of 
the Fundamental Rights Agency in this connection11.

07 
Current EU‑level policy priorities aimed at promoting the inclusion of Roma peo‑
ple stem from the EU 2020 strategy, which was agreed in 2010 and which aims to 
deliver smart, sustainable and inclusive growth in Europe. To measure progress 
towards achieving the EU 2020 goals, five headline targets were agreed for the 
whole EU. The success of Roma inclusion policy has the potential to affect three 
of these five targets (the targets concerning education12; employment13; and 
fighting poverty and social exclusion14) in Member States with a high proportion 
of Roma residents.

08 
In this report, the terms ‘integration’ and ‘inclusion’ are both used to refer to 
measures aimed at improving the living conditions and human rights situation of 
Roma people living in the EU’s Member States15 (see Box 3).

16

7  Directive 2004/38/EC of the 
European Parliament and of 
the Council of 29 April 2004 on 
the right of citizens of the 
Union and their family 
members to move and reside 
freely within the territory of 
the Member States amending 
Regulation (EEC) No 1612/68 
and repealing Directives 
64/221/EEC, 68/360/EEC, 
72/194/EEC, 73/148/EEC, 
75/34/EEC, 75/35/EEC, 90/364/
EEC, 90/365/EEC and 93/96/
EEC (OJ L 158, 30.4.2004, p. 77). 
In particular, Articles 6 and 7 
on the right of residence for 
up to 3 months and right of 
residence for more than 
3 months, respectively.

8  Council Framework Decision 
of 28 November 2008 on 
combating certain forms and 
expressions of racism and 
xenophobia by means of 
criminal law.

9  Council Recommendation of 
9 December 2013 on effective 
Roma integration measures in 
the Member States (OJ C 378, 
24.12.2013, p. 1).

10  COM(2011) 173 final.

11  The role of the Fundamental 
Rights Agency in connection 
with national Roma 
integration strategies consists 
of the following: (a) providing 
expertise to EU institutions, (b) 
collecting of data and (c) 
working together with 
Member States in order to 
come up with tools to provide 
evidence on progress made.

12  The targets in the field of 

education are to reduce the 
rates of early school leaving 
below 10 % and having at least 
40 % of 30‑34 year‑olds 
completing their third level 
education.

13  The target is to have 75 % of 
the 20‑64 year‑olds in 
employment.

14  The target is to have at least 
20 million fewer people in or 
at risk of poverty and social 
exclusion.

15  This approach is consistent 
with the Council of the 
European Union’s definition 
presented in its conclusions 
on the EU Framework for 
National Roma Integration 
Strategies up to 2020: Council 
of the European Union (2011), 
Council Conclusions on an EU 

Introduction 

17

3
x
o
B

Interchangeable use of the terms ‘integration’ and ‘inclusion’

The words ‘integration’ and ‘inclusion’ are often used interchangeably to describe the overall objectives of 
political initiatives aimed at improving the situation of the Roma population.

‘Integration’ is used more frequently in the context of initiatives aimed at protecting fundamental rights and 
values (as described in Article 2 TEU). It can be found in the national Roma integration strategies.

‘Inclusion’ is used more in the context of socioeconomic initiatives. It appears, for example, in the Europe 2020 
strategy, which aims to achieve smart, inclusive and sustainable growth.

How does the EU provide financial support to Roma 
integration measures?

09 
The greater part of EU financial support for social inclusion (where measures in 
favour of Roma integration were co‑financed) is provided mainly through the 
European Social Fund (ESF), and also the European Regional Development Fund 
(ERDF), in the context of the EU’s cohesion policy. Other funds are also available 
under specific programmes subject to direct management by the Commission16.

10 
The ESF and ERDF are implemented through national and regional multiannual 
operational programmes (OPs) prepared by the Member States and approved by 
the Commission. Within each OP, total available funds are broken down among 
the different priority axes of the OP.

11 
The ERDF and ESF budget for 2007 to 2013 was around 201 billion euros and 
76 billion euros, respectively. In the 2014 ‑2020 programme period, the ERDF 
and ESF are part of the European Structural and Investment Funds (ESIF)17; their 
overall budget is around 197 billion euros (ERDF) and 86 billion euros (ESF) for the 
entire period.

Framework for National Roma 
Integration Strategies up to 
2020, 3089th Employment, 
Social Policy, Health and 
Consumer Affairs Council 
meeting, Brussels, 
19 May 2011.

16  Programme for Employment 

and Social Innovation (EaSI) 
2014‑2020; its predecessor was 
‘Community Programme for 
Employment and Social 
Solidarity — PROGRESS 
2007‑2013’; ‘Rights, Equality 
and Citizenship Programme 
(2014‑2020)’; its predecessors 
being the Fundamental Rights 
and Citizenship Programme, 
the Daphne III Programme 
and the Progress Programme 
in the actions on 
Anti‑discrimination and 
Gender Equality.

In the 2014‑2020 programme 
period, the ERDF, the ESF and 
the Cohesion Fund, together 
with the European Agricultural 
Fund for Rural Development 
(EAFRD) and the European 
Maritime and Fisheries Fund 
(EMFF), they make up the 
European Structural and 
Investment Funds (ESIF).

17 

 
Introduction 

18

12 
The proportion of these amounts channelled specifically to Roma integration 
initiatives is not recorded. But we can infer from Member States’ planning docu‑
ments that around 1.5 billion euros has been earmarked for the socioeconomic 
integration of marginalised communities such as Roma during the 2014‑2020 
programme period (see also paragraph 69 and Table 6). Similar indicative figures 
are not available for the 2007‑2013 programme period.

Role of other European and international 
organisations in relation to Roma integration

13 
The Council of Europe was the first institution to address Roma integration at Eur‑ 
opean level. For over 40 years, it has been carrying out work aimed at combating 
discrimination against Roma people and improving the integration of marginal‑
ised Roma communities.

14 
Other international organisations had also been active in the field of Roma in‑
tegration, their role being distinct, such as the World Bank, the Organisation for 
Security and Cooperation in Europe (the Office for Democratic Institutions and 
Human Rights) and the United Nations Development Programme.

Audit scope and objectives

19

18  Other directorates‑general 

with responsibilities in relation 
to areas of the EU Framework 
for National Roma Integration 
Strategies are DG Education 
and Culture, DG Health and 
Food Safety and DG 
Neighbourhood and 
Enlargement Negotiations.

15 
Through this audit we assessed whether the EU policy initiatives and financial 
support through the ERDF and ESF had effectively contributed to Roma integra‑
tion. Our audit scope covered both the 2007‑2013 and the 2014‑2020 programme 
periods. In particular, we examined whether:

—  the EU framework and national Roma strategies facilitated the effective use 

of the ERDF and ESF for Roma inclusion measures in each programme period;

—  the ERDF and ESF framework of each programme period was designed so as 

to allow effective support to Roma integration measures; and

—  projects implemented under the ERDF and the ESF during the 2007‑2013 

programme period contributed effectively to Roma integration.

16 
We collected audit evidence from interviews with Commission and Member 
State officials, as well as project promoters and project participants. We also re‑
viewed documents obtained from EU and Member State authorities and project 
promoters.

17 
We first evaluated the support for Roma integration provided by the Commission. 
This support included EU legislation, policy frameworks, and specific guidance 
describing the EU’s priorities and targets; we examined these in connection with 
initiatives from both the 2007‑2013 and the 2014‑2020 programme periods. We 
also looked at how the Commission ensured the respect of fundamental rights. 
This part of our audit work was carried out at the Commission’s directorates‑gen‑
eral (DGs) which deal most substantially with policies related to Roma integra‑
tion: DG Justice and Consumers, DG Employment, Social Affairs and Inclusion and 
DG Regional and Urban Policy18.

Audit scope and objectives 

20

18 
We also reviewed Member States’ strategic frameworks for promoting Roma 
integration, and in particular the national Roma integration strategies (NRISs). We 
considered that Roma integration measures supported by the ERDF and the ESF 
should be closely linked to these frameworks to achieve maximum effectiveness. 
We also examined whether the visited Member States had put in place appropri‑
ate administrative arrangements to implement their strategic frameworks for 
Roma inclusion successfully. Coordinating the development and implementation 
of NRISs is the responsibility of national Roma contact points (NRCPs). We there‑
fore held meetings with the NRCPs of the four visited Member States, i.e. Bul‑
garia, Spain, Hungary and Romania, as well as those of Germany, Greece, France, 
Slovakia and the United Kingdom, in order to gain a wider knowledge of the na‑
tional strategies and of the possible changes made between the two programme 
periods in terms of strategies, plans and programme design.

19 

In the 2007‑2013 programme 
period, these four Member 
States together received 
14.1 billion euros of aid for 
social inclusion measures from 
the ERDF and ESF. This is 20 % 
of the total amount allocated 
from the Structural Funds for 
social inclusion measures in all 
Member States across the 
same period.

20  One initially selected project 

was removed from the sample 
for want of relevance.

19 
For the 2007‑2013 programme period, we also evaluated how the ERDF and ESF 
OPs had been designed, implemented and monitored in order to assess their 
ability to support Roma integration measures effectively. We examined a sample 
of projects from that period in order to evaluate their contribution to the integra‑
tion of the marginalised Roma populations. Our assessment of the 2014‑2020 ESIF 
was limited to the design of the aspects of the ERDF and ESF which were relevant 
to Roma integration, since the audit took place at a very early stage in the pro‑
gramme period.

20 
We selected four Member States (Bulgaria, Spain, Hungary and Romania) on the 
strength of the number of Roma people living there, and because they had al‑
located a large amount of funding to policy areas which could potentially have 
supported Roma inclusion initiatives19.

21 
For the four Member States visited, we selected seven ERDF and ESF OPs from the 
2007‑2013 programme period which we considered relevant to Roma inclusion 
initiatives, and examined a total of 19 projects implemented under those OPs20 
(see Annex I); these projects were selected on the basis of information supplied 
by the national authorities. We focused on education, employment, healthcare 
and housing projects, but we also visited projects dealing with other topics, 
such as social inclusion or anti‑discrimination (see Table 5). All selected projects 
had been completed by 2013. A list of the bodies responsible for selecting and 
implementing the projects examined in the context of this audit can be found in 
Annex II.

Audit scope and objectives 

21

21  The EURoma network is 

a European network involving 
representatives of EU Member 
States aiming to promote the 
use of the Structural Funds to 
enhance the effectiveness of 
policies targeting the Roma 
community.

22  Fundación Secretariado 

Gitano, Technical secretariat of 
the EURoma network, 
‘Tackling Roma Needs in the 
2014‑2020 Structural Funds 
Programming Period — Guide 
to improve the planning 
process’, May 2013.

23  The FRA was established in 

2007 as an EU Agency with the 
specific task of providing 
independent, evidence‑based 
advice on fundamental rights. 
The FRA and the United 
Nations Development 
Programme, UNDP, have 
carried out separately and 
jointly Roma household 
surveys in 2004, 2009, 
2012 and 2015.

22 
Our audit criteria draw on the experience of the EURoma network21, which has 
issued recommendations22 for ensuring success in Roma inclusion initiatives. We 
also visited the Fundamental Rights Agency (FRA) to obtain information on data 
collection23.

23 
The most important of these criteria are the ten common basic principles, or 10 
CBPs; these are shown in Figure 2 and described in detail in Annex III. These 
principles were discussed at the first meeting of the European Platform for Roma 
inclusion in 2009 in Prague. They were then included as an annex to the conclu‑
sions of a meeting of the Employment, Social Policy, Health and Consumer Affairs 
Council held on 8 June 2009.

24 
The measures addressing the integration of the marginalised Roma population 
of the OPs which we had selected from the 2007‑2013 programme period were 
incorporated into nine new OPs for the 2014‑2020 period. We assessed the new 
ESIF framework on the basis of these nine new OPs.

25 
During the audit, we were assisted by external experts on Roma integration. We 
also put in place a panel of four advisors, providing input to our audit approach 
and ensuring that important aspects of the Roma integration issue had been 
taken into account.

26 
Since measures promoting the integration of marginalised Roma, and their re‑
sults, may be perceived very differently by different stakeholders, we put togeth‑
er focus groups in each selected Member State. In doing so, we aimed to bring 
together experts, and stakeholder representatives to allow them to share their 
opinions on Roma inclusion measures in connection with our preliminary find‑
ings for each visited Member State. Later, we held a final focus group meeting 
with 13 different stakeholders (including our panel of advisors). The aim of this 
meeting was to review our preliminary findings and to discuss potential conclu‑
sions and recommendations.

Audit scope and objectives 

22

2 Ten common basic principles (CBP) on Roma inclusion
e
r
u
g
i
F

10. 
Active participation
of the Roma 

1. 
Constructive,
pragmatic and non-discriminatory 
policies

9. 
Involvement of 
civil society

2. 
Explicit but not
     exclusive targeting

8. 
Involvement of
     regional and local
authorities

7. 
Use of European
Union instruments

3. 
Inter-cultural
     approach

4. 
Aiming for the
     mainstream

6. 
Transfer of evidence-based
policies

5.
Awareness for the gender 
dimension

Source: ECA.

 
Observations

23

Progress made in terms of strategies in place at EU and 
Member State level, but most improvements came too 
late to have an impact on the 2007-2013 programme 
period

27 
We examined policy developments at both EU and national level towards improv‑
ing the targeting and fostering of Roma integration measures. First, we assessed 
the policy developments at EU level. Second, we reviewed the national Roma 
integration strategies and evaluated whether they were an appropriate tool for 
better addressing Roma integration issues.

24  Council Decisions of 
30 March 1998 and 
6 December 1999 on the 
principles, priorities, 
intermediate objectives and 
conditions contained in the 
Accession Partnership with 
the Republic of Bulgaria, the 
Czech Republic, the Republic 
of Hungary, Romania and the 
Slovak Republic.

28 
We assessed whether an EU strategic framework concerning Roma integration 
initiatives had been in place for the 2007‑2013 programme period, as well as 
whether there were any amendments or improvements over time. For EU‑funded 
Roma integration policy to be effective, the Commission needs to support the 
work of Member States by providing EU legislation, policy frameworks or specific 
guidance.

EU policy initiative on Roma inclusion was agreed upon in 
2011, after the EU enlargements in 2004 and 2007

EU policy initiatives were adopted too late to have an impact on 
the design of the 2007-2013 programme period

29 
The issue of Roma inclusion gained particular significance at EU level in the 
run‑up to the accession to the EU of a number of central and eastern European 
states, some of them with large Roma populations, in 2004 and 2007. The Acces‑
sion Partnership agreements for Bulgaria, the Czech Republic, Hungary, Romania 
and Slovakia24 made the further integration of the Roma people a medium‑term 
political priority.

24

25  Regulation (EU) No 437/2010 
of the European Parliament 
and of the Council of 
19 May 2010 amending 
Regulation (EC) No 1080/2006 
on the European Regional 
Development Fund as regards 
the eligibility of housing 
interventions in favour of 
marginalised communities (OJ 
L 132, 29.5.2010, p. 1).

26  COM(2011) 173 final.

27  Employment, Social Policy, 

Health and Consumer Affairs 
Council configuration.

Observations 

30 
However, the EU did not make Roma integration a specific political priority after 
the accessions of 2004 and 2007. No reference was made to Roma integration in 
the initial versions of the 2007‑2013 regulations. Nor was there any requirement 
to include it as a specific priority in ERDF or ESF OPs. The first specific reference 
to Roma integration appeared in 2010, when the eligibility conditions in the ERDF 
regulation governing housing measures were amended25.

31 
In 2008, the Commission started making efforts to improve the situation of mar‑
ginalised Roma. Following the first EU Roma summit in September 2008, it estab‑
lished a European Platform for Roma inclusion, an inter‑service Roma Task Force, 
a network of NRCPs and a working party on Roma integration indicators which is 
coordinated by the Fundamental Rights Agency (see paragraph 94). Other sup‑
port structures include two thematic working groups under the NRCP network 
and regular consultation meetings with civil society organisations, international 
organisations and academic networks. DG Justice and Consumers, together with 
the directorates‑general responsible for managing ESIF, also organises regular 
fact‑finding missions and high level bilateral dialogues with Member States. 
These visits give national and local authorities, civil society organisations and all 
Commission departments concerned the chance to discuss policy developments 
face‑to‑face.

32 
But it was in April 2011 that the first important EU‑level document addressing 
Roma integration was issued: a communication issued by the Commission on an 
EU framework for national Roma integration strategies26 (NRISs). Then, the EPSCO 
Council27 adopted Conclusions in May, in which Member States committed to 
prepare, update or develop their NRISs. This took place after the Commission, 
through its Commissioner for Justice, Fundamental Rights and Citizenship, made 
a statement on the latest developments in the Roma situation, stating that dis‑
crimination on the basis of ethnic origin or race was not welcome in Europe. The 
Commissioner also indicated that the Commission was ready to launch infringe‑
ment proceedings against one Member State (France) for having applied the free 
movement directive in a discriminatory fashion which was incompatible with 
the Charter of Fundamental Rights of the European Union. The European Coun‑
cil Conclusions of June 2011 noted the major importance of Roma inclusion and 
called on the rapid implementation of EPSCO conclusions as regards the prepara‑
tion, updating or development of Member States’ strategies.

Observations 

25

33 
This was the first EU initiative specifically concerning the Roma community, 
which included a follow‑up mechanism. It proposed that each Member State 
draw up its own NRIS (see paragraph 41). This initiative provided a sound frame‑
work for fostering Roma inclusion and set out areas in which action should be 
taken and targets set. Specifically, it set out four key priority areas of interven‑
tion: education, employment, healthcare and housing. Member States were asked 
to set achievable goals in these areas.

34 
The Member States were not asked to deal separately with anti‑discrimination 
measures, or to establish associated targets. These were addressed as a cross‑cut‑
ting theme in all of the other four areas28 mentioned above; however, specific 
measurable indicators and targets on anti‑discrimination were rarely set. This is 
a significant shortcoming of the existing policy framework, as it makes it difficult 
for the Commission to measure progress made.

28  Equal treatment is horizontal 

principle of the EU Framework, 
which sees it as precondition 
for effective Roma inclusion. 
The EU Framework explicitly 
recognises that ‘first of all, 
Member States need to ensure 
that Roma are not 
discriminated against but 
treated like any other EU 
citizens with equal access to all 
fundamental rights as 
enshrined in the EU Charter of 
Fundamental Rights’, ‘An EU 
Framework for National Roma 
Integration Strategies up to 
2020’, p. 2.

29  Council Recommendation of 
9 December 2013 on effective 
Roma integration measures in 
the Member States.

Inclusion of the Roma population since 2011: from a policy-based 
approach to political commitment

Council recommendation dealing with Roma integration adopted in 2013

35 
A 2013 Council recommendation29 was the EU’s first legal instrument dealing 
exclusively with Roma integration, reflecting a fundamental step forward in 
the EU’s approach to Roma inclusion. Instead of persisting with a policy‑based 
approach, the recommendation established the inclusion of the Roma popula‑
tion as a Member States’ political commitment reflecting established provisions 
protecting human rights. The recommendation provides specific guidance to 
help Member States to improve and speed up work to promote Roma integra‑
tion in the fields of education, employment, healthcare and housing. It also gives 
guidance on horizontal policy measures; these include guidance on tackling 
anti‑discrimination. The recommendation also refers explicitly to anti‑gypsyism, 
which refers to a specific form of racism fuelled by historical discrimination.

Observations 

Commission issuing country-specific recommendations (CSRs) on Roma 
inclusion since 2012

36 
Since 2012, the Commission has issued country‑specific recommendations (CSRs) 
on Roma inclusion. Since then, this kind of CSRs has been addressed to five Mem‑
ber States with large Roma minorities: Bulgaria, Hungary, Slovakia, Czech Repub‑
lic and Romania. Table 2 gives details of the subject of these CSRs addressed to 
each of these five Member States.

2 Subject of Roma integration CSRs in the five Member States concerned
e
l
b
a
T

2014

2013

2012

Bulgaria

Roma integration in general

Education

Employment/Education

Czech Republic

n/a

Education

Education

Hungary

Romania

Slovakia

Roma integration in general

Poverty/Education

Poverty/Education

n/a

Education

Roma integration in general/
Education

Employment/Education

Education

Education

Education

Education

Education

Education

Education

26

2015

Source: ECA, based on Commission data.

37 
The Commission has also monitored closely the implementation of the two 
relevant directives30 on equal treatment (Table 3 contains more details about the 
implementation of the racial equality directive). It launched infringement pro‑
ceedings against the Czech Republic in 2014 and Slovakia in 2015, in both cases 
due to the segregation of Roma pupils in the education system. The remaining 
cases do not relate specifically to Roma people. The Commission monitors as well 
the implementation of the 2008 framework decision on combating certain forms 
and expressions of racism and xenophobia by means of criminal law. Since 2014, 
this framework decision is enforceable.

30  Council Directive 2000/43/EC 
(‘racial equality directive’), 
Council Directive 2000/78/EC 
(‘employment equality 
directive’).

 
Observations 

27

3 Monitoring of the implementation of the racial equality directive 2000/43/EC
e
l
b
a
T

Transposition

Infringement1

Member State

Deadline

Completed by deadline

Non-conformity of MS 
legislation with EU law

Incorrect application of 
EU law by MS

Belgium

Bulgaria

Czech Republic

Denmark

Germany

Estonia

Ireland

Greece

Spain

France

Croatia

Italy

Cyprus

Latvia

Lithuania

Luxembourg

Hungary

Malta

Netherlands

Austria

Poland

Portugal

Romania

Slovenia

Slovakia

Finland

Sweden

United Kingdom

19-Jul-03

1-Jan-07

1-May-04

19-Jul-03

19-Jul-03

1-May-04

19-Jul-03

19-Jul-03

19-Jul-03

19-Jul-03

1-Jul-13

19-Jul-03

1-May-04

1-May-04

1-May-04

19-Jul-03

1-May-04

1-May-04

19-Jul-03

19-Jul-03

1-May-04

19-Jul-03

1-Jan-07

1-May-04

1-May-04

19-Jul-03

19-Jul-03

19-Jul-03

√

√

√

√

√

√

√

√

√

√

√

√

√

√

√

√

√

√

√

√

√

√

√

√

√

√

√

√

Closed

Closed

Closed

Closed

Closed

Closed

Closed

Closed

Closed

Closed

Closed

Closed

Closed

Closed

Closed

Closed

Closed

Open

Closed

Closed

Open

Open

Closed

Closed

Information as at December 2015.

1 
Note: Only the cases of the Czech Republic and Slovakia are infringement procedures related specifically to Roma people.

Source: ECA, based on Commission data.

 
28

31  Commission Delegated 

Regulation (EU) No 240/2014 
of 7 January 2014 on the 
European code of conduct on 
partnership in the framework 
of the European Structural and 
Investment Funds (OJ L 74, 
14.3.2014, p. 1).

32  Romact aims to improve the 

responsiveness and 
accountability of local 
authorities, particularly 
elected officials and senior 
civil servants, towards 
marginalised Roma 
communities. It focuses on 
generating long‑term 
sustained political 
commitment which will lead 
to sustainable plans and 
measures for Roma inclusion 
(see also http://coe‑romact.
org/).

33  ROMED consists of two 

phases. The first phase of 
ROMED has been leading an 
initiative aiming to train 
mediators in delivering quality 
mediation between Roma 
communities and local 
authorities. Since the 
programme started in 2011, 
over 1 300 mediators have 
been trained in 22 countries. 
The second phase of ROMED, 
which started in 2013, focuses 
on local contexts and in 
particular on how mediation 
can stimulate the participation 
of Roma communities for 
a more inclusive and 
democratic governance of 
selected municipalities in 11 
country‑members of the 
Council of Europe (see also 
http://romed.coe‑romact.
org/).

Observations 

Guidance issued by the Commission and enhanced cooperation with the 
Council of Europe

38 
Alongside these main initiatives, the Commission has issued many pieces of 
policy guidance on the use of funds for Roma inclusion. These include, among 
others, thematic guidance documents on Roma and on marginalised communi‑
ties, document relating to the thematic ex ante conditionality on the integration 
of marginalised Roma communities and a guidance note for Member States on 
the use of European Structural and Investment Funds in tackling educational and 
spatial segregation.

39 
Moreover, in 2014, the Commission has issued a European Code of Conduct for 
Partnership, which stipulates that Member States should involve civil society 
organisations in partnership agreements and ensure that they play an active role 
in designing and implementing programmes supported by the ESIF31.

40 
To increase the effectiveness of its work in the field of Roma integration, the 
Commission has also since 2011 worked more closely with the Council of Europe, 
an organisation with a great deal of experience in this area (see paragraph 13). In 
particular, the Commission has participated in meetings organised by the secre‑
tariat of the Council of Europe and in certain joint programmes with the Council 
of Europe (Romact32 and ROMED33).

Progress at Member State level: National Roma integration 
strategies had been adopted, but some shortcomings 
remained

41 
Member States were requested in 2011 to prepare national Roma integration 
strategies (NRIS) covering the period 2011‑2020 or, if a strategy already existed, 
to adapt it to meet the EU’s Roma integration goals. These strategies should set 
out targeted actions and information on the funding (national, EU and other) to 
deliver them. They should also propose solutions to address the current barriers 
to a more effective use of EU funds and lay the foundations of a robust monitor‑
ing mechanism to ensure concrete results for Roma.

29

34  Apart from Malta which states 

that it has no Roma 
population.

35  National Social Inclusion 

Strategy‑Extreme poverty, 
child poverty, the Roma (NSIS), 
as in Hungary the strategy was 
not only for Roma. For the 
sake of clarity, it will be 
referred hereafter as NRIS.

Observations 

42 
As regards these national strategies for Roma integration, we:

—  examined the specific content of the NRISs of the visited Member States;

—  checked whether relevant stakeholders had been identified for the imple‑

mentation of the NRIS and what the role of the national Roma contact points 
(NRCPs) was in this context;

—  assessed the monitoring arrangements in relation to their implementation; 

and

—  reviewed how the Commission assessed the Member States’ reports on im‑

plementation of their NRIS.

National Roma integration strategies (NRISs)

National Roma integration strategies adopted by all Member States visited

43 
After the Commission issued its communication asking Member States to adopt 
a NRIS, all Member States34 did so. Some Member States opted for an integrated 
set of policy measures for the purpose of Roma integration, which we considered 
to be the equivalent of a NRIS. NRISs were followed by action plans in all four 
visited Member States. They also each set up a national Roma contact point.

44 
The Commission did not stipulate that anti‑discrimination should be included 
among the key priority areas in NRISs. However, the NRISs of Bulgaria, Hungary35 
and Spain went beyond the four main prescribed areas of education, employ‑
ment, healthcare and housing: they included a chapter dealing specifically with 
anti‑discrimination. Romania’s NRIS referred also to anti‑discrimination but only 
indirectly, when discussing the four main prescribed areas. Of the four selected 
Member States, only Bulgaria and Hungary had set any targets concerning 
anti‑discrimination.

Observations 

30

45 
Three of the four NRISs included targets concerning education, employment, 
healthcare and housing. The fourth one, Hungary’s NRIS, included general 
targets, but there were no quantified target values associated with them, and 
not all targets referred specifically to the Roma population, such as in the field 
of housing. While the strategy provided relevant information on the situation of 
the Roma population in Hungary, this was not used to formulate Roma‑specific 
indicators or baseline values in the NRIS. The NRIS of Romania included baseline 
values only for certain indicators. This made it difficult to evaluate the results 
achieved under these NRISs, since the starting point was unknown.

All national Roma integration strategies refer to the 10 common basic 
principles (CBP) on Roma inclusion

46 
All strategies either directly (Bulgaria, Hungary and Spain) or indirectly (Roma‑
nia) referred to the 10 common basic principles (CBP) on Roma inclusion (see 
paragraph 23 and Figure 2). We found, however, that the Member States had not 
always applied the 10 CBPs when they were drafting the strategies themselves:

 ο

 ο

in the case of Spain and Bulgaria, written evidence was provided on the 
consultation of civil society organisations and the feedback provided by the 
national authorities on the NGOs contribution,

in the case of Romania and Hungary, CBP 9, concerning the involvement of 
civil society, and CBP 10, concerning the active participation of Roma people 
in policymaking, had only partially been followed:

— 

— 

In Romania, a consultation process took also place prior to the adoption 
of the NRIS, with several meetings being organised, but civil society or‑
ganisations questioned the transparency and the number of these. They 
also stated they had not been informed on how their contributions had 
been taken on board. We found no evidence on whether and how the 
Romanian authorities took into account the NGOs contributions.

In Hungary, there was little evidence on how the NRIS consultation pro‑
cess had been carried out, and the updated version of the NRIS included 
no information about whether or how the comments from the different 
stakeholders had been taken into account. No consultation had taken 
place concerning the action plan. In addition, two civil society organisa‑
tions had been appointed to implement the most important measures of 
the NRIS alongside public authorities. This had the effect of crowding out 
other civil society organisations.

Observations 

31

National Roma integration strategies do not specify the financial support 
available in the Member States for measures supporting Roma inclusion

47 
Our analysis showed that the NRISs of Bulgaria, Hungary and Spain contained no 
information on the financial allocations available for Roma‑related measures, be 
it either under the national budget or from the ERDF or ESF OPs co‑financed from 
the EU budget. In the case of Bulgaria, the NRIS stated that the EU funds were the 
main source of financing for projects implementing the NRIS. Only in Romania 
was a budget provided, though it contained some inconsistencies: the ERDF was 
not mentioned in the NRIS as a source of funding, even though it had been used 
as such since the ERDF was amended in 2010, before the NRIS was even adopt‑
ed36. The absence of information on the financial means available to tackle the 
issues related to Roma inclusion makes it difficult to assess whether the Member 
States’ strategies were realistic from the start.

36  Regulation (EC) No 1080/2006 
of the European Parliament 
and of the Council of 
5 July 2006 on the European 
Regional Development Fund 
and repealing Regulation (EC) 
No 1783/1999 (OJ L 210, 
31.7.2006, p. 1).

37  COM(2011) 173 final, p. 9.

38  E.g. the Spanish NRCP 

recognised in the 2014 annual 
report to the Commission the 
challenge of allocating more 
resources to the NRCP in order 
to ensure an adequate 
implementation of the NRIS.

Assignment of responsibilities for the implementation of the 
NRISs: the role of the national Roma contact points (NRCPs)

48 
All Member States covered by our analysis had set up and defined the respon‑
sibilities of NRCPs in accordance with the requirements of the Commission’s 
communication of 2011. The NRCPs are responsible for coordinating the develop‑
ment and implementation of the NRIS. They monitor progress made under the 
NRIS and share this information with the Commission37. However, NRCPs’ powers 
are limited. The assignment of operational responsibilities to national ministries 
meant that the NRCPs from the selected Member States had no powers in the ar‑
eas of employment, education, housing or health. The NRCPs also had no power 
to decide how financial resources were allocated to integration programmes.

49 
The size, structure and responsibilities of the nine selected NRCPs varied widely. 
Several NRCPs had already existed under a different name before the concept of 
an NRCP was introduced by the Commission; some had then been assigned fur‑
ther responsibilities without being provided with any additional resources38. The 
capacity of the Bulgarian NRCP was insufficient, as described in paragraph 50.

32

39  Civil Society Monitoring 

Report on the implementation 
of NRIS and Decade Action 
Plan 2012 in Bulgaria, p. 9.

Observations 

50 
However, we identified two shortcomings in terms of assigning responsibility for 
implementing the NRIS. First, poor cooperation was found in Romania and Spain. 
Second, a mismatch between responsibilities and resources was found in Bulgaria 
and Spain:

— 

In Romania, we observed that poor cooperation between the National 
Agency for Roma and various government ministries in the provision of data 
was jeopardising the proper monitoring of the NRIS. Similarly, in Spain, we 
observed that the existing coordinating bodies (such as the Group on Techni‑
cal Cooperation) were not effective in providing reliable data and coordinat‑
ing policies, showing a need for better coordination in order to ensure that 
the NRIS is implemented properly. Both of these examples of poor coordina‑
tion hampered the collection of reliable data, making it harder to monitor the 
implementation of the NRIS.

— 

In Bulgaria, low levels of powers and resources were made available to the 
Bulgarian NRCP, despite it being one of the main bodies in charge of imple‑
menting and monitoring the NRIS. Several non‑profit organisations in Bul‑
garia drew attention to a lack of political will39. A similar problem was identi‑
fied by the Spanish NRCP in its 2014 progress report.

Shortcomings in monitoring the progress of the national Roma 
integration strategies

51 
We found that monitoring and assessing the progress of the NRIS was a signifi‑
cant challenge for all visited Member States (see also paragraph 74):

— 

In Bulgaria, no specific monitoring and accountability procedures were pro‑
vided for in the NRIS. Moreover, not all measures had quantifiable targets.

— 

In Hungary, although an indicator system for the programme monitoring had 
been developed, the data it contained had not been updated since 2012.

— 

In Romania, the monitoring process was significantly weakened by the 
absence of information on the indicators set out in the NRIS and by a lack of 
structured financial data concerning the implementation process. Monitor‑
ing reports did not mention the targets set or the degree to which they had 
been achieved, making it difficult to assess how effectively they had been 
implemented.

— 

In Spain, the 2014‑2016 action plan only included a description of the actions 
for 2014. Actions for 2015 were not drawn up until mid‑2015, which hindered 
the planning process for that year.

Observations 

33

Commission’s assessment on the implementation of the NRISs

52 
The European Commission assessed these national strategies, identifying their 
weaknesses, and in May 2012 published its conclusions in a communication (Na‑
tional Roma Integration Strategies: a first step in the implementation of the EU 
Framework). The Commission began in 2013 to carry out a yearly assessment of 
how successfully NRISs were being implemented. This yearly assessment contains 
details of overall shortcomings that need to be addressed. The main conclusions 
of the last years’ assessments referred to the fact that the necessary precondi‑
tions for implementing the strategies successfully were still not in place, render‑
ing the implementation of the NRISs slow. In particular, the following elements 
were missing: concrete targets and corresponding measures to tackle segrega‑
tion of Roma children in the educational system, a clearer timeframe for imple‑
mentation and a clearer financial allocation, as well as measures to fight discrimi‑
nation and racism towards the Roma people.

53 
Since then, Member States have made some progress in implementing their 
NRISs. But the Commission’s 2015 report showed that certain shortcomings that 
had existed at least since 2012 had still not been resolved in 2014: certain nec‑
essary conditions for implementing the strategies successfully were still not in 
place. This confirmed the observations we made in the four selected Member 
States.

54 
For example, the goal of tackling the segregation of Roma children in the educa‑
tional system was set out in the strategies, but the insufficient number of meas‑
ures and targets which had been introduced made it difficult to achieve. Where 
such measures did exist, the timeframe for their implementation was unclear, as 
were the budgetary arrangements. These shortcomings have slowed down the 
implementation of the NRIS. In Bulgaria, the progress report also referred to the 
lack of political will and the need to improve anti‑discrimination measures.

55 
Such shortcomings, in particular the issue of segregation in education, have been 
included in country‑specific recommendations issued to several Member States. 
In the case of the Czech Republic and Slovakia, the Commission even initiated 
infringement procedures on these grounds against the Member States (see para‑
graph 37).

Observations 

34

56 
At the start of the 2014‑2020 programme period the Commission checked wheth‑
er these elements had been addressed in the Partnership Agreements. It has 
made use of its advisory role in the Monitoring Committee meetings of the OPs 
we assessed for the 2014‑2020 programme period to also point out the relevance 
of the Roma‑related CSRs for the relevant OPs.

More attention given to Roma integration measures in 
the 2014-2020 period as compared to 2007-2013 in the 
field of cohesion policy

57 
We analysed whether Roma integration had been clearly referred to in the 2007‑
2013 Cohesion policy framework. We also checked how Member States receiving 
ERDF and ESF co‑financing for Roma integration initiatives ensured that the ini‑
tiatives developed at EU level were incorporated into relevant national strategies 
and OPs.

58 
For the 2014‑2020 programme period, we assessed whether Roma integration 
had been clearly referred to in the ESIF legal framework and whether the Com‑
mission tackled the shortcomings which had arisen in the 2007‑2013 programme 
period. For both periods, we examined whether the Commission and the 
Member States had set up an effective monitoring system in the field of Roma 
integration.

Observations 

35

Despite the lack of mention of Roma integration in the 
legal framework for 2007-2013, the selected Member States 
referred to Roma integration in their OPs

The 2007-2013 OPs examined made reference to Roma integration 
in general terms

59 
When the Cohesion policy framework for the 2007‑2013 programme period was 
being drafted, Roma integration had not yet been identified as a specific EU‑level 
priority. The word ‘Roma’ did not appear at all in the 2007‑2013 regulations. Nev‑
ertheless, all four visited Member States had at least one existing regional or na‑
tional Roma integration strategy or an equivalent programme. They all addressed 
Roma integration in at least some of their OPs, in the ways described in Table 4.

4 Reference to Roma inclusion in the 2007-2013 ERDF and ESF OPs
e
l
b
a
T

References to the Roma community

Specific target group

Specific indicators

in measures aimed at 
vulnerable groups

in measures aimed at  
helping the least  
developed areas

Bulgaria

Spain

Hungary

Romania

X

X

X

X

X

X

X

X

X

X

Source: ECA, based on Commission data.

60 
Despite the change to the ERDF regulation in 2010, most measures in our sample 
which were relevant to marginalised Roma were co‑financed under the ESF (see 
paragraph 30). A high proportion of them (7 out of 17) were employment‑related 
measures (see Table 5). This can be explained by the fact that Article 162 of the 
TFEU implies that ESF projects and measures must have a link to employment. 
The ESF regulation, on the other hand, allows, and even encourages social inclu‑
sion measures to be funded. This does not provide authorities with legal certain‑
ty that ESF funding can be used for any social inclusion measures irrespective of 
a link to employment.

 
Observations 

36

5
e
l
b
a
T

Fields of action of examined projects

ESF

ERDF

Project 1

Project 2

Project 3

Project 4

Project 5

√

√

√

ESF

√

√

Project 6

Project 7

Project 8

Project 9

Project 10

√

√

√

√

√

Project 11

Project 12

Project 13

Project 14

Project 15

ESF

ERDF

√

√

√

√

√

ESF (Fight against Discrimination OP)

ESF (Andalusia OP)

Project 16

Project 17

Project 18

Project 19

√

√

√

√

Bulgaria

Education

Employment

Health

Social inclusion

Social infrastructure

Hungary

Education

Employment

Health

Social inclusion

Social infrastructure

Romania

Education

Employment

Health

Social inclusion

Social infrastructure

Spain

Education

Employment

Health

Social inclusion

Social infrastructure

Note: Relevant ERDF‑funded social infrastructure projects in Hungary were implemented but were not selected for audit because they had not 
been completed by 2013.

Source: ECA.

 
37

Increasing the adaptability of 
workers and firms, enterprises 
and entrepreneurs, improving 
access to employment and 
sustainability, improving the 
social inclusion of 
less‑favoured persons, 
improving human capital.

Observations 

Limited reference to Roma integration strategies and few number 
of Roma-specific indicators in the 2007-2013 ERDF and ESF OPs

40 

61 
However, only one of the seven 2007‑2013 ERDF and ESF OPs examined referred 
to the NRIS and three OPs set out Roma‑specific indicators:

—  The OP for the development of Human Resources (POSDRU) in Romania 

explicitly referred to the Roma integration strategy in place when the OP 
entered into force. Implementing this integration strategy was one of the 
OP’s stated objectives. Although this OP was not specifically targeted at the 
Roma community, it did also include an output indicator and a result indica‑
tor specifically referring to Roma people.

—  The Bulgarian ESF OP which we selected also included Roma‑related output 

and result indicators for certain measures.

—  The Hungarian OP we selected included one Roma‑specific indicator which 

was not directly related to a specific measure.

The remaining four selected OPs did not have any Roma‑specific indicators.

No information on the financial support for Roma integration 
specified in the 2007-2013 OPs examined

62 
ESF funding was provided according to priority themes: objectives to which the 
ESF aimed to contribute. Roma integration initiatives were most likely to contrib‑
ute to the objectives of the ESF priority themes for social inclusion40. Over the 
7‑year programme period, 11.5 billion euros were initially allocated (of EU and 
national funds) to social inclusion measures in ESF OPs with dedicated Social 
Inclusion Priority Axes. However, no financial information was available on which 
proportion of this funding was devoted to the integration of marginalised Roma 
communities. In addition, Roma inclusion initiatives were also able to access 
funding under other, more general, priority themes, such as those concerning 
education and employment.

Observations 

38

63 
ERDF funding was also provided according to other priority themes, of which the 
most relevant to Roma integration was ‘Social infrastructure’41. A total 18.6 bil‑
lion euros of funding was allocated under this priority theme. This consisted 
mostly of mainstream support which was not targeted at a specific group, as 
explained in Box 4.

41  This encompasses the 
following investment 
categories: education, health, 
childcare, housing and other 
social infrastructure.

4
x
o
B

Mainstream and targeted support: complementary approaches to Roma inclusion

Mainstream support refers to policies addressed to the general public, with no distinction being made be‑
tween recipients on the grounds of race, ethnic origin, or other irrelevant factors.

Targeted support refers to policies aimed explicitly but not necessarily exclusively at one or several specific 
target groups, such as a specific minority group.

Experience shows that Roma people are more likely to integrate successfully into society if they can also ac‑
cess support under mainstream initiatives which do not target them exclusively. There is no single model for 
administering this: a tailor‑made approach needs to be used which takes into account local circumstances42.

42 

‘How to mainstream Roma inclusion in general programmes, projects and interventions’, Reinforcing Policy Learning for Roma Inclusion, 
European Social Fund (ESF) Learning Network.

64 
Until the ERDF regulation was amended in 2010, the ERDF was unable to provide 
support targeted at specific groups, with the exception of Member States that 
acceded to the EU on or after 1 May 2004 and in certain circumstances. Since this 
amendment, a total of 80 million euros has been allocated to integrated housing 
schemes targeting marginalised communities, including Roma people, across 
eight Member States43.

43  Bulgaria, Czech Republic, 

Greece, France, Italy, Hungary, 
Romania and Slovakia.

65 
Our analysis also showed that many Member States did not collect ethnicity data 
and were consequently unable to determine the size of the Roma population 
in a given geographical area and to assess the specific difficulties faced by this 
group. This may have contributed to the difficulties in determining the necessary 
level of funding for Roma integration.

 
Observations 

39

Greater focus on Roma issues at EU level was reflected in the 
ESIF framework for 2014-2020

44  Article 4(1) in all three 

regulations.

Better alignment of ESIF financial support with the EU’s 2020 
Strategy and the Commission’s country-specific recommendations 
(CSRs)

66 
The ESIF regulations44 (i.e. the common provision regulation, the ERDF regulation 
and the ESF regulation) stipulate that the ESIF must provide support that is con‑
sistent with the EU’s 2020 Strategy for Smart, Sustainable and Inclusive Growth 
and with relevant country‑specific recommendations (CSRs).

67 
The Partnership Agreements in three of the four Member States visited (Bulgaria, 
Hungary and Romania) made reference to the specific CSRs concerning the Roma 
community issued since 2012. This was also the case in Slovakia. For Spain, no 
such CSR was issued.

68 
The CSRs regarding Roma integration have mainly concerned education (see also 
paragraph 36 and Table 2). When the OPs were being drawn up, the Member 
States which had received a CSR on this subject were encouraged by the Commis‑
sion to use EU funds to carry out reforms of their mainstream education policies 
to ensure that Roma people had equal access to the education system. In Hun‑
gary, though, the education desegregation measures included in the OPs for the 
2014‑2020 programme period which we examined were insufficiently detailed. 
We therefore doubt that Hungary will be successful in tackling the segregation 
which remains in its education system with the help of the ESIF (see Box 5).

Observations 

40

5
x
o
B

Lack of desegregation measures in the field of education in ESIF framework in 
Hungary

Hungary’s 2007‑2013 ‘Social Renewal’ OP, priority 3 of which dealt with education, used the number of active 
local educational desegregation programmes as an indicator. ‘Desegregation’ was an indirect reference to the 
Roma target group. The indicator was aimed at disadvantaged regions and areas, with a target value of 100 
implemented programmes by 2013 (the 2007 baseline figure was 2).

However, this indicator was not included in the last modified version of the OP. Consequently, it was not meas‑
ured and will also not be measured at the end of the programme period. There is also no detailed description 
of what education desegregation measures Hungary intends to carry out in the 2014‑2020 programme period. 
This shows a lack of commitment to addressing the issue of segregation in education using the Structural 
Funds.

Specific investment priority for marginalised communities (such as 
Roma) in 12 EU Member States

69 
The ESIF framework 2014‑2020 also puts greater emphasis on ensuring that the 
objectives of OPs co‑financed under the ESIF are consistent with EU priorities. It 
includes a specific investment priority for ESF OPs, which explicitly mentions the 
Roma people. This investment priority (IP 9(ii) ‘Integration of marginalised com‑
munities such as the Roma’) provided a link between policy priorities as reflected 
in the CSRs and EU funding priorities, as well as providing a dedicated way to 
earmark funds for this purpose.

45  Article 2(33) of Regulation (EU) 
No 1303/2013: ‘applicable 
ex ante conditionality’ means 
a concrete and precisely 
predefined critical factor, 
which is a prerequisite for and 
has a direct and genuine link 
to, and direct impact on, the 
effective and efficient 
achievement of a specific 
objective for an investment 
priority or a Union priority’ (OJ 
L 347, 20.12.2013, p. 320).

70 
Moreover, one of the ex ante conditionalities45 (EACs), i.e. the criteria which it sets 
for co‑financing, refers specifically to that investment priority, thus ensuring that 
proper attention is paid to it in OPs. The Roma integration EAC for IP 9(ii) is: ‘[…] 
a national Roma inclusion strategic policy framework is in place’.

 
Observations 

41

71 
All five Member States (Bulgaria, Czech Republic, Hungary, Romania and Slovakia) 
which had received CSRs concerning Roma inclusion had included IP 9(ii) in at 
least one of their OPs for 2014‑2020 (see Table 6). These five Member States had 
previously included proposals in their partnership agreements about ways to use 
EU funds to promote Roma inclusion.

72 
Another seven Member States (Belgium, Greece, Spain, France, Italy, Austria and 
Poland) had also included IP 9(ii) in at least one OP. In other words, 12 Member 
States which are collectively home to more than 90 % of the EU’s estimated Roma 
population had included IP 9(ii) in at least one OP. As Table 6 shows, 1.5 bil‑
lion euros has been allocated to IP 9(ii) for the 2014‑2020 programme period.

6 Amounts made available to Member States under investment priority 9(ii) 
e
l
b
a
T

‘Integration of marginalised communities such as the Roma’ for the 2014-2020 
programme period

Member State

Amount 
(million euro)

Proportion of Member State’s 
total ESF funding

Proportion of total funding 
under IP 9 (ii)

Hungary1

Romania1

Czech Republic1

Bulgaria1

Slovakia1

Greece

Italy

Spain

Poland

Belgium

France

Austria

Total

470    

372    

200    

143    

99    

73    

71    

48    

19    

10    

8    

4    

1 518 

10.0 %

7.8 %

5.8 %

9.4 %

4.6 %

2.0 %

0.7 %

0.6 %

0.1 %

1.0 %

0.1 %

0.9 %

n/a

85 %

15 %

100 %

1  Member States with country‑specific recommendations regarding Roma.

Source: ECA, based on Commission data.

 
Observations 

42

73 
In these Member States, though, not all OPs which covered geographical areas 
with large Roma populations included IP 9(ii), or any indicators relevant to it. This 
was also true of some OPs which had allocated significant amounts to the main 
areas relevant for the integration of the Roma population. Two examples of this 
are the regional OP for Andalusia, where almost 50 % of the Spanish Roma popu‑
lation live, and the ESF OP ‘Economic Development and Innovation’ in Hungary 
under which many employability measures will be implemented.

74 
Four Member States (Bulgaria, Czech Republic, Greece and Slovakia) had only 
partially met, at the time of the audit, the EACs applicable to IP 9(ii) which had 
been set in the common provisions regulation, mostly due to the fact that they 
had no proper monitoring tools or methodology for implementing their NRISs 
(see paragraph 51). Croatia, Italy, Hungary and Slovakia had not met the general 
EAC concerning anti‑discrimination. All of these Member States subsequently 
submitted action plans to the Commission explaining how they intended to meet 
these EACs. The Commission then assessed their content. From the information 
received the Commission concluded that Hungary had fulfilled the criteria on 
anti‑discrimination and that Slovakia had met the EAC regarding IP 9(ii) on the 
basis of the action plan they submitted.

75 
Although IP 9(ii) is a helpful innovation, the ESIF are currently managed in a way 
that ignores differences between Member States in the current situation of the 
Roma population. ESIF funds are allocated among the Member States according 
to indicators with no specific relevance to the Roma population, such as overall 
population, unemployment rate or GDP. In our opinion, these indicators are not 
the most appropriate way of determining how much EU funding for Roma inte‑
gration should be allocated to each Member State.

Observations 

43

Integrated approach to provide financial support to Roma 
integration also used by all four Member States visited

76 
Using an integrated approach has a positive effect on efforts to encourage Roma 
integration using the ESIF. All four selected Member States had used an inte‑
grated approach — addressing several different fields simultaneously46 — in at 
least one of their OPs with single or multi‑fund47 OPs. In this respect, on the one 
hand, Romania provided a good example (see Box 6). On the other hand, in Spain 
the lack of arrangements defining an integrated approach in the regional OP for 
Andalusia was a missed opportunity.

46  For Roma integration, the 
relevant fields are housing; 
education; health; social 
affairs; employment and 
security; and desegregation 
measures.

47  Hungary.

6
x
o
B

A good example of an integrated approach — a joint selection committee in 
Romania

In order to make better use of the Structural Funds, Romania used an integrated approach with two OPs (the 
Human Capital ESF OP and the Regional ERDF OP). One of these OPs drew co‑financing from the ERDF, and the 
other from the ESF. Both OPs shared a common priority axis. Romania also set up a joint selection committee 
in which the managing authorities of the two OPs were represented, as well as three other common bodies, 
including the NRCP and the national anti‑discrimination council. Common calls for proposals were issued for 
both OPs, with the same eligibility conditions and in the same areas of action. The OPs also provided comple‑
mentary co‑financing (i.e. using ERDF and ESF for different project activities which are carried out in a related 
or consecutive manner).

Funding devoted to anti-discrimination measures

77 
Article 8 of the ESF regulation states that Member States should use the ESF to 
support initiatives with the specific objective of combating discrimination. ESF 
investment priority 9(iii) ‘Combating all forms of discrimination and promoting 
equal opportunities’ (IP 9(iii)) is used to provide support to such initiatives.

78 
Eleven Member States included IP 9(iii) in at least one of their OPs for the 2014‑
2020 programme period. The total amount of funding which had been allocated 
under IP 9(iii) was 414 million euros (see  Table 7).

 
Observations 

44

promoting equal opportunities’ per Member State

7 Amounts allocated under IP 9(iii) ‘Combating all forms of discrimination and 
e
l
b
a
T

Member State

Amount 
(million euro)

Proportion of Member State’s 
total ESF funding

Proportion of total funding 
under IP 9.3

Spain

Greece

Portugal

Slovakia1

Czech Republic1

Poland

Cyprus

Ireland

France

Belgium

Germany

Total

 145   

 99   

 51   

 40   

 22   

 19   

 14   

 11   

 8   

 4   

 1   

414 

1.9 %

2.7 %

0.7 %

1.8 %

0.6 %

0.1 %

10.8 %

2.0 %

0.1 %

0.4 %

0.0 %

n/a

91 %

9 %

100 %

1  Member States with country‑specific recommendations regarding Roma.

Source: ECA, based on Commission data.

79 
Of the four Member States which we examined, Spain had included IP 9(iii) in 
seven of its OPs. The Czech Republic and Slovakia, both of which were subject to 
infringement proceedings due to the segregation of Roma pupils in the educa‑
tion system (see paragraph 37), had each included IP 9(iii) in one OP. Bulgaria, 
Hungary and Romania had not included it in any. This is a missed opportunity 
to support anti‑discrimination measures that could be integrated with measures 
under IP 9(ii), hence enhancing the chances for initiatives on Roma inclusion to 
be more effective, since the lack of anti‑discrimination measures is considered as 
one of the main reasons why Roma inclusion measures can fail.

 
45

48  Rodríguez Cabrero, G. 

‘Promoting Social Inclusion of 
Roma. A Study of National 
Policies. Spain’, Universidad de 
Alcalá on behalf of the EC, DG 
Employment, Social Affairs 
and Inclusion, July 2011.

49  Of this, 33 billion euros are 

estimated to be allocated to 
education measures, 
34 billion euros to 
employment measures and 
33 billion euros to social 
inclusion measures.

50  Adam Kullmann: Litmus Test 
of Effective Use of Structural 
Funds, Supporting Structural 
Reforms of Basic Public 
Services to Promote Roma 
Inclusion, EStIF, 2015, p. 231.

51  Commission Delegated 

Regulation (EU) No 240/2014.

Observations 

Significant amounts of funding have been devoted to education, 
employment and social inclusion measures

80 
The ESIF framework also earmarks significant amounts of money for mainstream 
social inclusion measures; experience shows that these are a crucial tool for suc‑
cessfully promoting Roma integration, as the recognised ‘Spanish model of Roma 
inclusion’ can prove48. According to information published by the Commission in 
February 2016, 100 billion euros of ERDF and ESF funding have been allocated to 
education, employment and social inclusion measures for the 2014‑2020 period49.

81 
The five Member States which have been the subject of specific CSRs regarding 
Roma inclusion (Bulgaria, Czech Republic, Hungary, Romania and Slovakia) ac‑
count for around one fifth of this total, i.e. around 20 billion euros. The estimated 
share of marginalised Roma among different target populations (e.g. people 
at risk of poverty and social exclusion) implies that, if equal access is provided, 
around 500 million euros per year could benefit Roma people of target popula ‑
tions under mainstream ESIF‑supported programmes in these countries50. For this 
same period and the same five Member States, 183 million euros per year will be 
made available under IP 9(ii) (i.e. targeted initiatives). This demonstrates the im‑
portance of using mainstream policies effectively for Roma inclusion initiatives.

New tools for improving consultations and cooperation between 
public authorities and civil society organisations

82 
The most important tool for encouraging the involvement of civil society or‑
ganisation in ESIF’s planning and implementation process is the European Code 
of Conduct on Partnership51. This document contains guidelines helping Mem‑
ber States to establish ESIF partnership agreements and OPs. These guidelines 
include a recommendation to use transparent procedures for finding potential 
partners and working with them. They also stipulate that calls for proposals, pro‑
gress reports, and programme monitoring and evaluation procedures should be 
transparent. The guidelines include a number of good practices concerning the 
rules of membership of partnerships and the internal procedures of monitoring 
committees.

Observations 

46

83 
From the OPs selected for the 2014‑2020 period, which included IP 9(ii), moni‑
toring committee meetings had been organised for seven of the nine OPs. In 
total, 14 meetings had taken place and in 10 of them Roma representatives were 
present in the meetings. In all monitoring committee meetings of the ESF OPs 
(except for one case in Hungary52) there was a Roma organisation representative 
and, in the case of Bulgaria, also the NRCP.

52 

In the case of Hungary where 
no Roma representative was 
present at the monitoring 
committee meeting, this 
absence and the need to have 
one, was discussed during the 
meeting.

OP-level monitoring tools at disposal during the 2007-
2013 programme period were ill-suited for measuring the 
performance of Roma integration measures

Monitoring systems provided an inadequate basis for reporting on 
Roma integration during the 2007-2013 programme period

Limitations for public authorities to collect data on ethnicity in some 
Member States

84 
In some Member States, there are constitutional limitations on the collection of 
data by public authorities (see two examples in Box 7). This makes it more dif‑
ficult to monitor Roma‑specific indicators.

7
x
o
B

Gathering data on ethnicity: legal difficulties

Germany has not collected any socioeconomic and population statistics on the basis of ethnic origin since 
the end of the Second World War: its NRCP has confirmed that no specific figures are known for any national 
minority.

French law specifically forbids the state from collecting personal ethnicity data.

 
Observations 

85 
Nevertheless, Directive 95/46/EC on the processing of personal data and on the 
free movement of such data, and Regulation (EC) No 45/2001 on the protection of 
individuals with regard to the processing of personal data by the Community in‑
stitutions and bodies and on the free movement of such data stipulate a number 
of exceptions to the prohibition of processing of personal data revealing racial 
or ethnic origin, in particular ‘when the data subject has given his or her express 
consent to the processing of those data’. Such provisions remain in the draft gen‑
eral data protection regulation53.

53 

86 
The Fundamental Rights Agency considers that the European Data Protection 
Supervisor and these EU’s data protection legal provisions provide adequate 
regulation for processing personal and sensitive data. Moreover, during our audit, 
several bodies (including the Commission, the FRA and the EURoma network) 
have confirmed that processing disaggregated data pertaining to ethnicity is not 
unlawful in any EU Member State54. It was also pointed out to us that, in cases 
where it genuinely is difficult to collect the data on the ethnicity of participants, 
practical alternatives exist, such as the use of anonymous surveys where random‑
ly selected respondents are asked to self‑identify on the basis of unambiguous 
consent.

87 
However, even if ethnicity data can lawfully be collected, there is no guarantee 
that it will be reliable or useful. In Romania, for example, information on ethnic‑
ity was collected in the census. But this data was not used for the purposes of 
Romania’s NRIS, the Romanian authorities relying instead on estimates made by 
the Council of Europe. This indicated that the Member State’s knowledge of its 
own Roma population was unreliable.

47

In January 2012, the 
Commission proposed 
a comprehensive reform of 
the EU data protection rules, 
the central element of which is 
a general data protection 
regulation. On 
18 December 2015, the 
Committee of Permanent 
Representatives endorsed the 
regulation; and on 
12 February 2016, the Council 
confirmed this agreement. 
The general data protection 
regulation shall apply from 
25 May 2018. One distinction 
between the directive and the 
regulation on the issue of 
sensitive data is that the latter 
expands the definition of 
sensitive data to include 
genetic data, biometric data 
and data concerning sexual 
orientation. A second 
distinction is the 
disappearance of the term 
‘substantial public interest’. 
The regulation refers to the 
exemption of data processing 
necessary to ‘the performance 
of a task carried out in the 
public interest’ and makes the 
link to the provision of 
‘suitable measures to 
safeguard the data subject’s 
legitimate interests’.

54  Fundación Secretariado 

Gitano, Technical secretariat of 
the EURoma network, 
‘Tackling Roma Needs in the 
2014‑2020 Structural Funds 
Programming Period ‑ Guide 
to improve the planning 
process’, May 2013, p. 65.

Observations 

48

Data on ethnicity of participants collected at project level, but not passed 
on to the OP monitoring system

88 
At project level, however, we found that a number of the promoters in all four 
Member States visited during the audit collected data on the ethnicity of partici‑
pants, but this data was not passed on to managing authorities or intermediate 
bodies (see also paragraph 118). This meant that Roma‑related data which was 
available at project level did not reach the OP monitoring system.

89 
For example, this was the case in Spain. The intermediate body of the regional OP 
for Andalusia was not even aware of which projects had addressed Roma people, 
although this information was available at project level. The intermediate body 
was only able to provide us with a list of projects which had targeted disadvan‑
taged groups in general, whether or not there had been any Roma participants. 
This was similar in Hungary.

OP monitoring in three out of four Member States hampered by 
inconsistencies in defining and recording indicators at project level

90 
Moreover, OP monitoring in three out of four Member States visited (Bulgaria, 
Hungary and Romania) was hampered by inconsistencies in defining and re‑
cording indicators at project level. In Romania, the existence of three types of 
indicators (programme, supplementary and additional indicators) at the time the 
projects were implemented, together with the lack of obligation to report on any 
of them, made the monitoring process unnecessarily complicated and produced 
results which were difficult to compare.

91 
In Hungary, four of the five examined projects mentioned in Annex II did not 
report formally on the attainment of results targets, since the project included 
no results targets (results targets had in fact been set, but they were erroneously 
classified as output targets and were consequently not reported as results).

Observations 

49

Efforts to improve monitoring have been made for the 2014-2020 
programme period, but certain limitations remain

92 
Monitoring Roma integration remains a challenge for the period 2014‑2020. One 
element that might help measure progress of Roma integration measures is the 
availability of common indicators; each fund has specific rules setting out com‑
mon indicators which must be used in all programmes financed under it. Annex 1 
of the ESF regulation, for example, specifies a number of standardised indicators 
which are relevant to Roma integration programmes:

—  A common output indicator 15: ‘Migrants, people with a foreign background, 

minorities (including marginalised communities such as the Roma)’;

—  A common immediate result indicator 28: ‘Disadvantaged participants en‑
gaged in job searching, in education/training, gaining a qualification or in 
employment, including self‑employment, upon leaving’;

—  A common longer‑term result indicator 32: ‘Disadvantaged participants in 

employment, including self‑employment, 6 months after leaving’.

These indicators can be complemented with relevant programme‑specific 
indicators.

93 
However, unless specific Roma‑related indicators are specified, these common 
indicators will not provide an effective basis for monitoring Roma integration 
initiatives. In addition, weaknesses in monitoring tools persist, and even led to 
the associated EAC being only partially fulfilled (see paragraph 74). This demon‑
strates how difficult it is to carry out accurate monitoring in the field of Roma 
integration.

Observations 

94 
To alleviate these difficulties, the Commission asked the Fundamental Rights 
Agency55 to set up a working group on indicators to be used in connection with 
Roma integration. As planned, the indicators were set up by 1 January 2016; this 
may enable an agreement to be reached with the NRCPs (which all participated 
in the working group) on using a comparable reporting structure throughout 
all participating Member States. It can also allow the impact of the ESIF on the 
implementation of the NRIS to be measured to a certain extent, especially in 
Member States which have aligned the ESIF measures and indicators to those of 
the NRIS, such as Greece and Slovakia (see Box 8). At March 2016, according to 
the Commission, 21 Member States accepted to test these indicators, but it is not 
yet clear whether the Commission will be successful in brokering an agreement 
to this effect between all Member States, since there is no requirement for Mem‑
ber States to make any changes to the system they use.

50

55  Mandate set in the 

Commission’s communication 
on an EU framework for 
national Roma integration 
strategies (COM (2011) 173 
final).

8
x
o
B

Improving the monitoring of Roma inclusion initiatives — a good example of 
aligning the monitoring of OPs with NRISs

The Commission recommended to Slovakia that funds from its OP Human Resources (OP HR) be used for 
implementing measures adopted in the NRIS up to 2020. The Slovak NRCP, which took part in all technical 
and formal meetings with the Commission, contributed to the conception of all measures under OP HR that 
focused specifically on marginalised Roma communities. These measures are consistent with the objectives of 
the NRIS; this will make it easier to measure progress made towards achieving the NRIS targets, as they have 
been reflected in the OP itself. Subsequently, the Monitoring and Assessment project Slovakia has put in place 
will be used to monitor the implementation of the NRIS, as well as the implementation of measures within OP 
HR.

 
Observations 

51

Most projects were carried out as planned, but ‘best 
practice’ criteria contributing to successful Roma 
inclusion were not always applied and monitoring 
project performance was difficult

56  The 19 projects were selected 
through these 16 calls for 
proposals.

95 
During this audit we also visited 19 projects for Roma integration, looking at how 
they had been prepared, selected and implemented, and how their results had 
been monitored (if at all). All examined projects were carried out under the 2007‑
2013 programme period. For each of these projects we examined whether:

—  the selection procedures were in line with the specific Roma integration ob‑

jectives and priorities defined in the OP;

—  the projects had been implemented according to plan;

—  the projects delivered their expected results;

—  monitoring arrangements were in place in order to monitor the results 

achieved by the projects regarding Roma inclusion.

All projects examined were in line with OP objectives, but 
selection procedures did not specifically aim to select Roma 
inclusion-related projects

Selection procedures for some OPs not geared towards Roma 
inclusion-related projects

96 
The selection procedures for all OPs examined in the four Member States ensured 
that each project was in line with the relevant OP objectives. Of the 16 calls for 
proposals56 which we assessed, nine explicitly referred to Roma people as a tar‑
get group: three of five in Bulgaria, the two in Spain, three of five in Hungary and 
one of four in Romania. The other seven were aimed at disadvantaged groups in 
general. Part of one further Spanish OP was designed around a link with Roma 
people. This explains why the application documents of some of the examined 
projects did not always contain references to the Roma population: they often 
addressed a wider group, such as vulnerable groups in general, in line with the 
OP objectives.

Observations 

52

97 
Evaluators generally had no specific experience of Roma inclusion issues. Instead, 
they tended to have knowledge of social inclusion in general. The OP ‘Fight 
against Discrimination’ in Spain was an exception; here, the evaluators had spe‑
cific knowledge on Roma inclusion.

Roma-specific indicators to monitor project performance not 
systematically required

98 
Our analysis showed that there was also some confusion about the way to set 
out indicators for monitoring the project performance. In Hungary, result targets 
(such as ‘finding a job within 6 months after having taken part in a project’) were 
not always required in calls for proposals. In Spain, result‑based targets were also 
not compulsory. In three cases in Bulgaria, output targets had occasionally been 
wrongly categorised as result targets in the project application, and this had not 
been corrected during the selection process (see also paragraph 118).

99 
In cases where they were required, result targets did not always refer explicitly 
to the Roma population. Instead, they referred to a wider group, such as ‘vulner‑
able groups’. This was seen in an ERDF OP in Bulgaria and ESF OPs in Hungary and 
Andalusia.

Relevant stakeholder groups not always appropriately involved

100 
The involvement of all relevant stakeholders, either in the preparation of the 
project or as project partners, contributes significantly to the success and sus‑
tainability of projects. However, project selection procedures generally failed to 
incentivise such wide involvement. Within our sample, this problem affected in 
particular social housing projects in Bulgaria. Local residents were not involved in 
the project, and no awareness‑raising campaigns were carried out; this led to the 
social rejection of project proposals.

Observations 

53

Projects were generally carried out according to plan

14 out of 19 projects examined had achieved their objectives in 
terms of outputs, budget, timing and scope

101 
In terms of outputs, budget, timing and scope, 14 of the 19 examined projects 
had met the objectives set out in the grant agreement. Four projects had not 
been carried out as planned, due to delays (two projects in Bulgaria) or changes 
in the scope of projects (one project in Bulgaria and another project in Romania). 
For another project in Hungary, both the indicators and the information available 
were so complex that it was not possible to reconcile them and assess whether 
output targets had been attained. The number of Roma participants had been 
recorded as an output for all but two of the examined projects.

1 An IT room for users of a social services centre in Baia Mare (Romania)
e
r
u
t
c
i
P

Source: ECA.

 
Observations 

54

10 out of 13 projects for which monitoring data was available had 
also met their results targets

102 
For 17 of the 19 examined projects, results targets had been set, though they did 
not necessarily refer to the Roma population specifically. These targets were only 
monitored in 13 cases. Ten of these 13 projects had generally achieved their ob‑
jectives. Specific targets concerning the Roma population had been set for four 
of the 17 projects with results targets. Three of these four projects had achieved 
their targets (one in Bulgaria, two in Romania and one in Spain).

Indication that better consideration of Roma-specific 
criteria, such as the common basic principles (CBPs) on Roma 
inclusion, contributed positively to project performance

103 
Based on our examination of the selected projects, we consider that a better 
consideration of Roma‑specific criteria would have made it more likely for some 
of these projects to positively contribute to a sustainable integration of Roma 
people. Of the 19 examined projects, 17 were implemented after the common 
basic principles (CBPs) on Roma inclusion had been adopted by the Council in 
June 2009 (see paragraph 23). The following examples illustrate how an applica‑
tion of the CBPs at the selection stage could have made a difference to the suc‑
cess of the project.

CBP 2: Roma integration policies and projects should target the 
Roma population explicitly but not exclusively

104 
CBP 2 stipulates that Roma integration policies and projects should target the 
Roma population explicitly but not exclusively. They should be aimed broadly at 
targets such as ‘disadvantaged groups’; mention clearly that these groups include 
Roma people; and describe specific action to ensure that projects reach the 
Roma population successfully. An employment programme in Spain was a good 
example of the application of this principle (see Box 9).

Observations 

55

9
x
o
B

Explicit but non-exclusive targeting helped an employment programme to reach 
the Roma population successfully (Spain, project 16)

An employment programme of OP ‘Lucha contra la discriminación’ in Spain aimed to integrate Roma people 
into the labour market. Participants were interviewed, and one of three courses of action was recommended: 
1. find a job, 2. undertake professional training or 3. attend workshops to acquire skills needed to find employ‑
ment. Companies were then contacted for information about vacancies or internship possibilities.

Disadvantaged Roma people had been addressed together with other people in a similar socioeconomic 
situation. Across Spain, a target had been set stipulating that 70 % of participants should be of Roma origin. 
Thanks also to other initiatives to encourage Roma participation (such as awareness‑raising measures), this 
target was achieved and the results sustained throughout the programme’s operation.

CBP 3: Need for an intercultural approach involving the use of 
mediators and awareness-raising campaigns

105 
CBP 3 describes the need for an intercultural approach involving the use of 
mediators and awareness‑raising campaigns. Applying this principle is crucial for 
ensuring the success of projects, especially those concerning housing. A lack of 
awareness can fatally undermine projects that could otherwise have been suc‑
cessful (see example in Box 10).

0
1
x
o
B

Lack of focus in terms of determining the target group and insufficient attention 
to cultural factors negatively affected the implementation of a health project 
(Bulgaria, project 4)

A project involving health screenings was implemented in Bulgaria under the priority axis of ‘Social inclusion’. 
This project was listed in the action plan for implementing the NRIS. However, no indicators referring to the 
‘vulnerable population’ target group were included. This project had three target groups. These were ‘vul‑
nerable population’ (consisting of groups at specific risk to health; people with a disability; socially excluded 
groups and communities; and vulnerable ethnic groups), ‘people of working age’ and ‘inhabitants of outlying 
regions’.

About 620 000 people were invited to undergo a screening; about 56 000 actually did. There is no information 
about how many of these were from the target groups. The lack of any explicit mention of the Roma popula‑
tion, and even of the target group ‘vulnerable population’, suggests a lack of a focus in attracting participants 
from those groups to the project.

Two factors inhibited the wider participation of Roma people. One of them was that the invitations were sent 
by letter: illiteracy is comparatively high among the Roma. Another was Roma women’s widespread fear of 
medical services, for historical reasons. Mediators could have been used to alleviate this problem.

 
 
Observations 

56

CBP 4: Importance of promoting the inclusion of the Roma 
population in mainstream society

106 
CBP 4 states the importance of promoting the inclusion of the Roma population 
in mainstream society. Ten of the examined projects which had set entry into 
the mainstream labour market as a results target had achieved good results by 
involving both public and private entities when implementing projects. Four 
projects had not fulfilled their objectives in this respect:

—  In Hungary, three examined projects did not involve private‑sector employ‑

ers during the implementation phase; this turned out to be a shortcoming, as 
participants subsequently could not find a job in the primary labour market. 
If they were employed at all, they were hired by public authorities.

— 

In Bulgaria, one project also failed to achieve its target of getting at least 8 % 
of its participants into the primary labour market.

107 
On the other hand, the measures implemented under Spain’s ‘Lucha contra la 
discriminación’ OP, which in the area of Roma integration focused mainly on 
employment, were not designed to work in tandem with mainstream policies. 
The Spanish public employment service, SEPE, was not involved in conceiving 
or implementing them until December 2014. It was therefore unable to bring its 
own experience to bear in planning the measures. Nor could it incorporate the 
experience gained from the project in its own policies.

108 
In contrast, three of the five projects examined in Romania had been carried out 
by an NGO in partnership with a public entity. This ensured that project partners 
benefited from each other’s knowledge, and allowed public bodies to make good 
use of project results in the design and implementation of their mainstream 
policies. For example, the results of the ERDF project were disseminated by the 
intermediate body after the project was completed.

Observations 

57

CBP 5: Awareness of gender issues

109 
CBP 5 concerns awareness of gender issues. Roma women are more likely than 
women in general and Roma men to experience social exclusion from main‑
stream society. They are often victims of double discrimination: discrimination on 
the grounds of gender, and on grounds of ethnic origin. However, Roma women 
have a crucial role to play in promoting inclusion; for example, promoting the 
integration of children into the education system. Overall goals for Roma integra‑
tion will be very difficult to attain if gender issues are not taken into account and 
if programmes fail to reach women.

110 
In Spain, all four examined projects explicitly addressed gender issues. The pro‑
jects succeeded in reaching women, the proportion of female participants vary‑
ing between 50 % and 70 %. In two cases, there were high rates of success in job 
insertion. In one of these cases, the same rate of employment was achieved for 
women as for men (about 24 %) and in another case, the labour market insertion 
rate for women reached 90 %. Another successful example is described in Box 11.

1
1
x
o
B

Women participation in a health project: multiplying the effects of inclusion 
(Romania, project 12)

One key objective of a health project in Romania was the creation of a network of health mediators for Roma 
communities. This project was run in partnership with the Romanian Public Health Institute.

The general objective of the project was to increase the employment rate among Roma women and to 
offer them better access to the labour market, in order to avoid social exclusion and to promote equal 
opportunities.

Among other things, the project trained 100 Roma women to work in 100 Roma communities that had never 
had a health mediator.

The project was successful because it promoted the inclusion of Roma women through qualifications and em‑
ployment. Moreover, it was positive for the reason that using Roma women as mediators is likely to multiply 
the effects of inclusion.

 
Observations 

58

CBP 6: Importance of learning from previous experience

111 
CBP 6 stresses the importance of learning from previous experience. In 14 of 19 
cases, this principle had been respected: previous experience of carrying out 
projects had demonstrably increased the capacity of project promoters, some of 
whom had also applied this expertise to subsequent projects.

112 
In Spain, the ‘Promociona’ education project built on an employment programme 
(‘Acceder’) that had been running successfully since 2000. The NGO managing 
those programmes as intermediate body also shared its own expertise with other 
NGOs acting as intermediate bodies for the ‘Lucha contra la discriminación’ OP. 
Each NGO had a focus on different vulnerable groups, and they regularly shared 
experience among themselves. The examined projects of the Andalusia OP 
added to the knowledge and information held by the public bodies which im‑
plemented the projects, because all data collected by the project promoters was 
stored in the public employment service’s records. This provided public authori‑
ties with a valuable tool for policy evaluation and further planning; it had been in 
use since the programme started in 2004.

CBP 7: Use of EU instruments

113 
CBP 7 concerns the use of EU instruments. All examined projects had by defini‑
tion used EU instruments to some extent, since they had received funding from 
the ERDF or the ESF. Four projects had gone further, using a combination of 
funding from the two funds; we consider this to be a good method of providing 
integrated support. The project described in Box 12, which was implemented in 
Bulgaria, gives an example of this.

Observations 

59

2
1
x
o
B

Use of integrated approach involving the ERDF and the ESF (Bulgaria, project 5)

The objective of this ERDF project (see Picture 2) was to improve the inclusion of people in underprivileged 
and vulnerable circumstances by raising their living standards and by generally improving the quality of the 
housing stock in the municipality. Social housing was intended to provide access to basic living conditions 
for approximately 165 socially vulnerable people who lived in dilapidated, overcrowded housing that did not 
comply with legal requirements for the construction and planning of residential buildings.

In Bulgaria, it was necessary for housing projects to be integrated with the provision of social services. Con‑
sequently, project selection criteria stated that promoters should provide the residents of new homes with 
employment, education and health services. Those social services were part of a programme called Integra, 
which was financed under the ESF in parallel with the housing measures.

(Bulgaria)

2 The rear façade of the refurbished social housing apartment block in Devnya 
e
r
u
t
c
i
P

Source: ECA.

 
 
Observations 

60

CBP 8: Involvement of regional and local authorities

114 
CBP 8 concerns the involvement of regional and local authorities, as they play 
a key role in the practical implementation of policies. Often, to have a long‑term 
effect, projects need a sustainable source of financing and, sometimes, the 
backing of a private promoter or a public authority. A good example was found 
in Romania where an important element of one project was passed over to the 
National Institute for Public Health, which was also an implementation partner of 
this project (see Box 11).

115 
Ten of the 19 examined projects depended heavily on the continued availability 
of long‑term public financing, because the project promoters were non‑profit 
organisations. Four other projects had been taken over and funded by public 
authorities; in each case, this had been planned from the start. The long‑term 
sustainability of three further projects should have been guaranteed by a public 
authority as stated in the project description, but had not been, either because of 
weaknesses in project management (in one case in Bulgaria) or because of a lack 
of sustained financial support at local level (see Box 13).

3
1
x
o
B

A lack of sustainable financial support made it difficult for successfully 
implemented projects to have a lasting impact (Romania, projects 12 and 14)

One project involved training and hiring 210 Roma people as Roma local experts. During the project, these 
experts had worked for local authorities for no charge. It was planned that the local authorities would hire and 
pay the experts on a permanent basis after the project ended. Soon after it did, the local authorities stated 
that they were unable to do so because of the economic circumstances. This meant that only 67 Roma local 
experts were hired by municipalities in 2015.

In the second project, 100 Roma women were trained as health mediators. As part of the project, lobbying 
work had taken place at local level to promote the benefits of health mediators to the community and to en‑
courage the creation of corresponding positions within the local administration. Although this lobbying work 
elicited a generally positive response, the level of support ultimately granted by local authorities to the health 
mediators programme was lower than expected. This had a significant effect on the impact of the project, as 
well as on the provision of health mediators in general: only approximately 350 health mediators were em‑
ployed in Romania in 2015, compared to 860 in 2009.

Although both projects were carried out successfully, the lack of sustained financial and institutional support 
from local authorities hampered the projects’ potential impact on the integration of the Roma population.

 
Observations 

61

Assessing the results for the 2007-2013 period was made 
more difficult by difficulties in gathering information about 
Roma people

116 
We also assessed how project promoters had monitored project results, in par‑
ticular in terms of integration of the Roma population, and whether the Com‑
mission or the Member States had carried out evaluations, particularly thematic 
evaluations regarding the inclusion of the Roma population or vulnerable groups.

Project-level monitoring: inconsistent approaches to data 
collection and indicator definitions

117 
Monitoring the success of Roma integration projects is not easy, because it is 
affected by methodological and practical difficulties in gathering information 
about Roma people. We will discuss these difficulties in further detail below. In 
most cases (17), though, project promoters had managed to gather information 
about the number of Roma participants their project had, and sometimes even 
about the results these participants had achieved: for example, in terms of find‑
ing jobs. Monitoring of this type was usually carried out when projects ended, 
but in some long‑term projects it was also done while the project was being 
implemented.

118 
For 14 of these 17 projects, ethnicity data was collected by means of self‑identifi‑
cation. One further project did not provide any information on how participants’ 
data had been collected. Two other projects did not collect any such data at all 
(one project in Bulgaria and another one in Romania). The quality of the monitor‑
ing was hampered by the following main weaknesses:

—  First, for 13 of the 19 examined projects, the results which were recorded 

were not specifically related to Roma integration but rather to the benefits 
brought to a wider target group — for example, ‘vulnerable groups’ in gen‑
eral, if indeed a target group was specified at all. Data about Roma participa‑
tion was in fact available, but had not always been passed on to the manag‑
ing authority or the intermediate body (see paragraph 88). This implies that 
the information submitted to the managing authorities did not include any 
reliable insights into the specific contributions made by projects to the inclu‑
sion of marginalised Roma people.

Observations 

62

—  Second, where projects had collected ethnicity data, the underlying method‑
ology for doing so was not consistent across Member States, or even across 
projects in individual Member States. In six cases, participants had been 
asked to answer a yes/no question on whether they were of Roma ethnicity. 
In six other cases, participants had been able to choose from a list of vulner‑
able groups to which they belonged. In two further cases, participants had 
been able to choose only one particular identity, either ethnic or national. 
Thus, it was not possible for participants to self‑identify as being, say, Hun‑
garian and Roma, though they may in fact have described themselves as 
belonging to both groups given the chance. This meant that the collected 
data was not necessarily exhaustive.

—  Third, indicators were classified differently in different Member States, and 
sometimes even within individual countries. As an example, four of the ex‑
amined Hungarian projects did not have any formal result indicators. Nev‑
ertheless, the project’s output indicators included indicators which should 
properly have been classified as result indicators: for example, the successful 
completion of training courses. In Bulgaria, three projects’ result indicators 
were duplicates of the projects’ output indicators; for example, the number 
of campaigns held or health screenings undertaken under the project. In Ro‑
mania, an employment indicator was classified as an output indicator on one 
occasion, and as a result indicator on another.

Evaluations partially balanced out the lack of Roma-specific 
monitoring at OP level

119 
Even though they do not always present a complete picture evaluations can 
serve as a basis for certain conclusions. Evaluations of the support provided un‑
der the ERDF and ESF with focus on the integration of marginalised Roma (albeit 
sometimes part of a larger evaluation on disadvantaged groups) had been car‑
ried out in all the four visited Member States and by the Commission.

Observations 

120 
These evaluations provided information not contained in the monitoring reports, 
making it possible to gain useful information on progress made:

— 

In 2011, an evaluation carried out by DG Employment, Social affairs and Inclu‑
sion, for example, concluded that Roma participation in ESF‑funded meas‑
ures had increased from 100 000 people with a Roma background during the 
entire 2000‑2006 period to 110 000 Roma in the first 2 years of the 2007‑2013 
programme period57. However, this had not had a sustained effect on re‑
ducing unemployment among the Roma population, despite the increased 
ESF contribution to promoting labour market participation. The evaluation 
pointed out that measures that uniquely target employment alone are unlike‑
ly by themselves to address the multifaceted obstacles to Roma inclusion. It 
stressed the importance of a holistic approach to promoting Roma inclusion 
that addresses wider barriers to their inclusion, in particular in the fields of 
education, health and housing.

— 

In 2013, an evaluation was carried out in Spain to determine the impact of the 
OP ‘Lucha contra la discriminación’ OP between 2006 and 201158. It concluded 
that investing in integrating vulnerable groups into the labour market had 
many positive outcomes, including economic ones. The evaluation concluded 
that every euro invested in these measures had attracted an overall return of 
1.38 euros.

63

57  Roma Thematic Report, 

commissioned by DG EMPL 
and carried out in 2011. This 
report forms a part of a wider 
study ‘Evaluation of ESF 
support for Enhancing Access 
to the Labour Market and the 
Social Inclusion of Migrants 
and Ethnic Minorities’.

58  El Empleo de las personas 
vulnerables: una inversión 
social rentable. Evaluación de 
Impacto del Programa 
Operativo Plurirregional Lucha 
Contra la Discriminación, 
dirigido por Gregorio 
Rodríguez Cabrero, 2013.

Conclusions and 
recommendations

64

121 
In the 2007‑2013 programme period, the extent to which Structural Funds con‑
tributed to the inclusion of marginalised Roma communities was made difficult 
to assess by the fact that the objectives were often not explicitly Roma‑related 
and the consequent failure of the selected Member States to record reliable and 
comparable information specifically on Roma beneficiaries, on the funding made 
available and on progress made. When data were available, the contribution of 
the Structural Funds projects to the integration of the Roma population depend‑
ed to some extent on whether specific success factors concerning Roma inte‑
gration had been respected in policy design and when projects were designed, 
selected and implemented.

122 
In the 2014‑2020 programme period, the design and criteria of funding priori‑
ties have been improved. Roma integration has been explicitly referred to in the 
ESIF legislation. Indeed, an investment priority makes reference to it, and Mem‑
ber States with CSRs related to Roma integration are obliged to devote funds to 
promoting it. Finally, the new results‑oriented approach of the ESIF legislation 
introduces a monitoring framework that should eventually improve the quality of 
data which can be collected. However, it is too early to make a meaningful assess‑
ment of how this has been implemented.

123 
Despite the progress which has been made, certain obstacles and dilemmas re‑
main. These make it more difficult for the ESIF to maximise their impact on Roma 
integration. These shortcomings are presented below, together with recommen‑
dations for addressing them.

Progress made in terms of strategies in place at EU and Member 
State level, but most improvements came too late to have an 
impact on the 2007-2013 programme period

124 
The Commission has made significant progress in setting out EU policy initiatives 
promoting Roma integration over the last decade. Since 2011, the Commission 
has devoted greater attention to Roma integration, requiring each Member State 
to draft a NRIS and to set up a NRCP. This has however come too late to have an 
impact on the design of ERDF and ESF OPs and the selection of projects during 
the 2007‑2013 programme period (see paragraphs 29 to 34 and 38 to 40).

Conclusions and recommendations 

65

125 
The NRIS, and later the Council Recommendation of 2013, transformed Roma 
integration from an issue dealt with exclusively through policies into a Member 
States’ political commitment reflecting established provisions protecting human 
rights. With this change, anti‑discrimination was established as a key area where 
action by the Member States was required (see paragraphs 35 to 37 and 43 to 45).

126 
Our audit identified a number of shortcomings as regards these NRIS:

—  First, the national strategies do not indicate what level of funding is needed 
to carry out the proposed measures for Roma inclusion. They also do not 
state the amount of money available for such measures, from the national 
budget and, through the ERDF and ESF, from the EU budget (see paragraph 
47).

—  Second, anti‑discrimination and anti‑gypsyism have not been provided 

enough attention. None of the NRISs which we assessed made any reference 
to anti‑gypsyism as a particular form of discrimination. In none of the OPs we 
examined it was explicitly referred to, and we saw almost no projects deal‑
ing specifically with this aspect. Up to now, the Commission has not required 
Member States to set measurable targets connected with anti‑discrimination. 
The lack of any such targets leaves scope for institutional discrimination to 
develop or continue unchecked; this can significantly undermine the effec‑
tiveness of Roma integration projects, including those co‑financed from the 
EU budget (see paragraphs 34 to 44 and 54).

—  Third, the need for active participation by civil society organisations, in par‑
ticular representatives of the Roma community itself, was not always taken 
into account in the selected Member States when NRISs were being drafted. 
Failing to include civil society organisations and the Roma community at 
every stage of the process risks undermining the effectiveness of policies and 
projects (see paragraph 46).

—  Finally, the role of NRCPs has sometimes been undermined by a mismatch of 

resources and responsibilities (see paragraphs 48 to 50).

Conclusions and recommendations 

66

127 
Since 2012, country‑specific recommendations have been used to draw atten‑
tion to various issues; for instance, that of segregation in education. During the 
2014‑2020 programme period, Member States must comply with these recom‑
mendations when using ESIF funds. Furthermore, under the Council Recommen‑
dation on Effective Roma Integration measures, Member States will be required 
from 2016 to provide information on fighting discrimination and anti‑gypsyism. 
The resulting information will give the Commission more information about the 
progress which has been made in each Member State (see paragraph 36).

Recommendation 1

The Member States should, when revising their NRISs or when making 
amendments:

(a)  specify what level of funding is needed to carry out the measures for Roma 
inclusion proposed in the strategy. NRISs should indicate the funding avail‑
able for such measures from the national budget and, through the ERDF and 
ESF, from the EU budget. The Member States should also formally undertake 
to ensure that efforts to implement measures in favour of Roma integration 
are not jeopardised by short‑term changes in political priorities;

(b)  include indicators and target values which deal with anti‑discrimination or, 
more specifically, anti‑gypsyism. During the 2014‑2020 programme period, 
these indicators should also be taken into account in the design of measures 
promoting the inclusion of marginalised Roma communities within the ESIF 
framework, in line with the requirements of the racial equality directive;

(c)  ensure that civil society organisations including Roma representatives are 

systematically consulted and included when Roma integration measures are 
being planned and implemented;

(d)  define in more detail the role played by NRCPs in relation to the NRISs, and 
ensure that the NRCPs’ powers and responsibilities are commensurate with 
the resources made available to them.

Conclusions and recommendations 

67

Recommendation 2

(a)  The Commission should make sure, when revising relevant operational pro‑

grammes, that measures carried out under the ESIF are of an inclusive nature 
and contain provisions aimed at fighting segregation. Segregational prac‑
tices should be clearly described and explicitly excluded from funding under 
the ESIF framework (not only mentioned in the recitals), particular attention 
being paid in this connection to education and housing projects. This would 
help to reinforce the link between CSRs and the use of the ESIF.

(b)  The Commission should make full use in OP monitoring committee meetings 
of the information contained in the reports which Member States are re‑
quired to provide from 2016 under the Council Recommendation on Effective 
Roma Integration measures, as well as of the findings arising from that infor‑
mation. This is to ensure that the areas of weakness identified in the reports 
are tackled by means of ESIF and/or Member State funds (e.g. by reallocating 
funds to areas where shortcomings have been identified).

More attention given to Roma integration measures in the 2014-
2020 period as compared to 2007-2013

128 
Despite the lack of focus on Roma integration during the 2007‑2013 programme 
period, the selected OPs made reference to the need to promote the inclu‑
sion of the Roma population. Similarly, most of the assessed calls for proposals 
made reference to the Roma people as a target group, or referred to the need to 
promote the social inclusion of the Roma people. Overall, however, the design of 
the ERDF and ESF during the 2007‑2013 programme period was poorly suited for 
Roma‑inclusion measures: OPs contained few Roma‑specific indicators and the 
assessed calls for proposals, despite having often Roma marginalised population 
as a target group, did not specify selection procedures that would take into ac‑
count the specific requirements of Roma projects such as making use of the ‘best 
practice’ criteria for Roma integration (such as the Council’s 10 CBPs) or the fund‑
ing of long‑term projects. Financial information on the support made to Roma 
integration was available for none of the ERDF and ESF OPs examined by us (see 
paragraphs 59, 61 to 65 and 96).

Conclusions and recommendations 

68

129 
A number of these shortcomings have been addressed in the 2014‑2020 period. 
In particular, Roma integration is explicitly referred to in the ESIF legislation and 
specific funding priorities have been improved. On the basis of the most recent 
information made available by the Commission, it can be estimated that around 
1.5 billion euros will be available for measures targeting marginalised communi‑
ties (such as Roma). Further improvements are the issuing of Roma‑specific CSRs 
and the better alignment of the ESIF framework to EU policy priorities (including 
those on Roma integration), the availability of common indicators relevant to 
Roma integration programmes or the issuing of guidance by the Commission such 
as on the use of ESIF funds in tackling spatial and educational segregation. Moreo‑
ver, Member States with CSRs related to Roma integration are obliged to devote 
ERDF and ESF funds to promoting it (see paragraphs 66 to 83 and 92 to 94).

130 
We consider, however, that efforts are required at both Commission and Member 
State level to make sure that these changes will result in projects better contrib‑
uting to Roma integration on the ground: this applies in particular to the criteria 
used to select the best projects for Roma inclusion and the OP’s monitoring 
systems for the 2014‑2020 period (see paragraphs 88, 89 and 92 to 94).

131 
Furthermore, the way the ESIF, and the ESF in particular, are set up prevents their 
impact in terms of the social inclusion of Roma people from being maximised. 
Indicators used to allocate ESIF funds among Member States ignore differences 
in the current situation of the Roma population (see paragraphs 60 and 75).

Recommendation 3

Member States should make use of the ‘best practice’ criteria for Roma integra‑
tion (such as the Council’s 10 CBPs) when making calls for proposals and select‑
ing projects. Where appropriate, calls should be organised to select long‑term 
projects in favour of marginalised Roma communities. Finally, wherever possible, 
the allocation of ESIF funding should be made subject to the sustainability of 
projects, without continued EU funding, after their completion. These aspects 
should also be considered when the 2014‑2020 operational programmes are 
modified.

Conclusions and recommendations 

69

Recommendation 4

The Commission should ensure, in the next programme period or when revising 
the operational programmes, that Roma integration objectives included in the 
NRISs are reflected in the ESIF framework at all operational levels, whenever ap‑
plicable. In this context, it should ensure that data are collected reliably in order 
to allow progress to be monitored and evaluated between individual projects 
and at all levels of administration.

Recommendation 5

Member States should complement the common output and results indicators 
set out in the ESIF legislation with Roma‑specific indicators, where appropriate. 
These indicators should be aligned with those specified in the NRISs and they 
should subsequently be used in the monitoring of the 2014‑2020 operational 
programmes. They could build on those developed by the Fundamental Rights 
Agency in 2016.

Recommendation 6

The Member States should consider acting together, in view of preparations for 
the next programme period, to seek to ensure legal certainty on the use of ESF 
to fund any social inclusion measures irrespective of a link to employment. The 
removal of legal uncertainty would facilitate the Member States in making full 
use of the ESF for the purpose of social inclusion, including through measures to 
combat discrimination.

Recommendation 7

The Commission should consider proposing changes to the ESIF legislation to 
ensure that, from the programme period beginning in 2020, the distribution 
of funds among the different Member States takes into account specific social 
inclusion indicators: in particular, the proportion of marginalised groups such as 
the Roma within the population. It should ensure that any additional ESF funds 
made available to Member States as a result of this change are earmarked for the 
specific purpose of supporting marginalised communities.

Conclusions and recommendations 

70

Most projects were carried out as planned, but not always ‘best 
practice’ criteria contributing to successful Roma inclusion were 
applied and monitoring project performance was difficult

132 
Most ERDF and ESF projects examined during our audit had achieved their gen‑
eral objectives, but these objectives were often not specifically Roma‑related. 
We also concluded that projects that had been selected in accordance with ‘best 
practice’ criteria adopted by the Council, the so called the common basic prin‑
ciples (CBP) on Roma inclusion, were more likely to contribute effectively to the 
integration of the Roma population (see paragraphs 104 to 115).

133 
Moreover, we found that monitoring the progress made by Roma integration 
projects has been difficult, mainly because of shortcomings in relation to the 
availability and quality of data on Roma participants. This lack of comprehensive 
and robust data is a problem not only in relation to projects, but also for policy 
making at EU and national level. Unless swift action is taken, this situation will 
remain unchanged for the 2014‑2020 period (see paragraphs 51, 84 to 94 and 117 
to 120).

Recommendation 8

(a)  The Commission should work together with the Member States to develop 
a common methodology which provides relevant data on the Roma popula‑
tion to monitor their social inclusion, in line with national legal frameworks 
and EU legislation, including existing possible derogations. This should be 
done at the latest when preparing the next programme period.

(b)  The Commission should encourage Member States, in accordance with 

national legal frameworks and EU legislation, including existing possible 
derogations, to collect in a comprehensive manner statistical data on ethnic‑
ity within the next two years. Eurostat could include relevant questions in 
surveys such as the Labour Force Survey and in the European Union Statistics 
on Income and Living Conditions.

Conclusions and recommendations 

71

This report was adopted by Chamber II, headed by Mr Henri GRETHEN, Member 
of the Court of Auditors, in Luxembourg at its meeting of 4 May 2016.

For the Court of Auditors

Vítor Manuel da SILVA CALDEIRA
President

 
 
 
Annexes

72

I Operational programmes examined
x
e
n
n
A

Member State

Operational programme 2007-2013

Bulgaria

2007BG161PO001 OP ‘Regional Development’ (ERDF)
2007BG051PO001 OP ‘Human Resources Development’ (ESF)

Hungary

2007HU05UPO001 OP ‘Social Renewal’ (ESF)

Operational programme 2014-2020

2014BG16RFOP001 OP ‘Regions in growth’ (ERDF)
2014BG05M9OP001 OP ‘Human Resources Development’ (ESF)
2014BG05M2OP001 Operational programme ‘Smart Education for 
Sustainable Growth’ (ESF)

2014HU16M0OP001 OP ‘Economic Development and Innovation’ 
(multi-fund OP ESF and ERDF)
2014HU05M2OP001 OP ‘Human Resources Development’ (multi-
fund OP ESF and ERDF)

2007RO051PO001 Sectoral OP for the development of Human 
Resources (ESF)
2007RO161PO001 Regional OP (ERDF)

2014RO05M9OP001 Human Capital OP (ESF)
2014RO16RFOP002 Regional OP (ERDF)

2007ES05UP0002 OP ‘Fight against discrimination’ (ESF)
2007ES051P0005 Regional OP ‘ESF 2007-2013 Andalusia’

2014ES05SFOP012  OP ‘Social Inclusion and Social Economy’ (ESF)
2014ES05SFOP022 Regional OP ‘ESF 2014-2020 Andalusia’ (ESF)

Romania

Spain

Source: ECA.

 
Annexes 

73

Governance bodies of the Structural Funds in the visited Member States

I
I
x
e
n
n
A

Bulgaria

Managing Authority

Intermediate Body

Project Beneficiary

Hungary

Managing Authority

Intermediate Body

Project Beneficiary

Romania

Managing Authority

Intermediate Body

Project 1

Project 2

Project 3

Project 4

ESF

ESF MA
(Ministry of labour and social policy)

Not applicable as the MA 
is the beneficiary

Ministry of  
Education and Science

Public Body  
(Social Assistance 
Agency)

Public Body  
(Social Assistance 
Agency)

Ministry of Labour 
and Social Policy

NGO

Public Body 
(Dupnitsa Municipality)

Ministry of Health

ERDF

Project 5

ERDF MA 
(Min. of Reg. Dev. and 
Public Works)

For this ERDF OP, there 
are no IBs foreseen

Public Body 
(Devnya Municipality)

Project 6

Project 7

ESF

Project 8

ESF MA 
(Ministry of Human Resources)

does not exist

Project 9

Project 10

Ministry of National 
Economy

Public Body 
(Balassagyarmati Prison)

Public Body 
(Ózd Municipality)

NGO

Project 11

Project 12

Project 13

Project 14

ESF

ESF MA 
(Ministry of EU Funds)

Regional (NW) IB 
(Dep. of the Labour 
Ministry)

Regional (Bucharest) IB 
(Dep. of the Labour 
Ministry)

Ministry of  
Education 
(acting as IB)

ERDF

Project 15

ERDF MA
(Min. of Reg. Dev. and 
Public Admin)

Regional (North-
West) IB  
(Dep. of the Labour 
Ministry)

Regional (North-
West) IB 
(Dep. of Min. of Reg. Dev. 
and Public Admin)

Public Body 
(National Agency for 
Roma) 

Public Body 
(Baia Mare  
Municipality Social 
Service)

Project Beneficiary

NGO

Spain

Managing Authority

Intermediate Body

Project Beneficiary

Source: ECA.

ESF (Fight against Discrimination OP)

ESF (Andalusia OP)

Project 16

Project 17

Project 18

Project 19

ESF MA 
(Ministry of Employment and Social Security)

Foundation

Regional IB
(Junta de Andalucia)

NGO

 
Annexes 

74

I Common basic principles (CBPs) on Roma inclusion
I
I
x
e
n
n
A

The ten common basic principles (CBPs) were discussed at the first meeting of the European Platform for Roma 
inclusion in 2009 in Prague. They were then included as an annex to the conclusions of a meeting of the Em‑
ployment, Social Policy, Health and Consumer Affairs Council held on 8 June 2009.

1.  Constructive, pragmatic and non-discriminatory policies

Policies aiming to promote the inclusion of Roma people respect and realise the core values of the Euro‑
pean Union, which include human rights and dignity, non‑discrimination, equality of opportunity, and 
economic development. Roma inclusion policies are integrated with mainstream policies, particularly in 
the fields of education, employment, social affairs, housing, health and security. The aim of these policies 
is to provide the Roma population with effective access to equal opportunities in Member State societies.

2.  Explicit but not exclusive targeting

Explicit but not exclusive targeting of Roma people is essential for inclusion policy initiatives. This means 
focusing on Roma people as a target group, though not to the exclusion of other people who share 
broadly similar socioeconomic circumstances. This approach does not separate Roma‑focused interven‑
tions from broader policy initiatives. In addition, where relevant, consideration must be given to the likely 
impact of broader policies and decisions on the social inclusion of Roma people.

3. 

Inter-cultural approach

There is a need for an inter‑cultural approach which involves Roma people together with people from dif‑
ferent ethnic backgrounds. Inter‑cultural learning and skills are essential for effective communication and 
policy, and deserve to be promoted; combating prejudices and stereotypes is also indispensable.

 
Annexes 

75

I 4.  Aiming for the mainstream
I
I
x
e
n
n
A

All inclusion policies aim to insert the Roma in the mainstream of society (mainstream educational insti‑
tutions, mainstream jobs, and mainstream housing). Where partially or entirely segregated education or 
housing still exists, Roma inclusion policies must aim to remove them. The development of artificial and 
separate ‘Roma’ labour markets should be avoided.

5.  Awareness of the gender dimension

Roma inclusion policy initiatives should take into account the needs and circumstances of Roma women. 
They should address issues such as multiple discrimination and problems of access to health care and child 
support, but also domestic violence and exploitation.

6.  Transfer of evidence-based policies

It is essential that Member States learn from their own experiences of developing Roma inclusion initiatives 
and share their experiences with other Member States. It is recognised that the development, implementa‑
tion and monitoring of Roma inclusion policies requires a good base of regularly collected socioeconomic 
data. Where relevant, the examples and experiences of social inclusion policies concerning other vulner‑
able groups, both from inside and from outside the EU, should also be taken into account.

7.  Use of European Union instruments

In the development and implementation of their policies aiming at Roma inclusion, it is crucial that the 
Member States make full use of European Union instruments, including legal instruments (racial equality 
directive, Framework Decision on Racism and Xenophobia), financial instruments (European Social Fund, 
European Regional Development Fund, European Agricultural Fund for Rural Development, Instrument for 
Pre‑Accession) and coordination instruments (Open Methods of Coordination). Member States must ensure 
that the use of financial instruments accords with these common basic principles, and make use of the ex‑
pertise within the European Commission, in respect of the evaluation of policies and projects. Peer review 
and the transfer of good practices are also facilitated on the expert level by EURoma (European Network 
on Social Inclusion and Roma under the Structural Funds).

 
Annexes

76

I 8. 
I
I
x
e
n
n
A

Involvement of regional and local authorities

Member States need to design, develop, implement and evaluate Roma inclusion policy initiatives in close 
cooperation with regional and local authorities. These authorities play a key role in the practical imple‑
mentation of policies.

9. 

Involvement of civil society

Member States also need to design, develop, implement and evaluate Roma inclusion policy initiatives in 
close cooperation with civil society actors such as non‑governmental organisations, social partners and 
academics/researchers. The involvement of civil society is recognised as vital both for the mobilisation 
of expertise and the dissemination of knowledge required to develop public debate and accountability 
throughout the policy process.

10.  Active participation of the Roma

The effectiveness of policies is enhanced with the involvement of Roma people at every stage of the 
process. Roma involvement must take place at both national and European levels through the input of 
expertise from Roma experts and civil servants, as well as by consultation with a range of Roma stakehold‑
ers in the design, implementation and evaluation of policy initiatives. It is of vital importance that inclusion 
policies are based on openness and transparency and tackle difficult or taboo subjects in an appropriate 
and effective manner. Support for the full participation of Roma people in public life, stimulation of their 
active citizenship and development of their human resources are also essential.

 
Reply of the Commission

77

Executive summary

II
The Commission notes that, apart from the amounts of 1.5 billion euros corresponding to the allocation to the 
investment priority 9(ii) of the ESF, further financing for the benefit of Roma inclusion is provided through a number 
of other investment priorities (IPs) of both ESF and ERDF.

IV
The Commission recalls that anti‑discrimination is a horizontal principle that should be taken into account during 
the preparation and implementation of the Partnership Agreements and Operational Programmes in all ESI Funds 
(as laid down in Article 7 CPR). 

The partnership principle as enshrined in the common provisions regulation (CPR) (Article 5) and in the European 
Code of Conduct requires relevant partners to be involved in the design and implementation of the partnership 
agreements and operational programmes (including in the monitoring committees as required in Article 48 CPR) in 
the ESF and ERDF OPs.

V
The Commission notes that in the context of its responsibilities under shared management it is helping Member 
States to make sure that the changes introduced for the 2014‑2020 period will result in projects better contributing 
to Roma integration, for example through assessment of the fulfilment of relevant ex ante conditionalities, guidance 
or its advisory role in monitoring committees.

VI
The Commission acknowledges that monitoring of EU‑funded projects’ effective contribution to the integration of 
the Roma is challenging due to objective legal obstacles for collecting data based on ethnicity and the application 
of the explicit but not exclusive targeting approach often making that Roma are not the only group benefiting from 
support to marginalised groups. 

However, the Commission believes that in the 2014‑2020 period, the monitoring of Roma integration will be signifi‑
cantly improved on the basis of the ESF Investment Priority 9(ii), the relevant specific objectives in the ESF and ERDF 
operational programmes and the use of the ESF common output indicator for participants as well as programme‑
specific indicators and targets.

Recommendation 1
The Commission notes that the recommendation is addressed to the Member States.

Reply of the Commission

78

Recommendation 1 (a)
The Commission recalls that the level of the European Structural & Investment Funds (ESI Funds or ESIF) support to 
measures for marginalised communities such as the Roma can only be indicative given the fact that Member States 
are only required to provide financial data when the dedicated ESF investment priority 9(ii) is selected and/or when 
specific targets/objectives/indicators have been set in other ESF and ERDF relevant thematic objectives.

Recommendation 1 (b)
The Commission underlines that, if the CPR contains a general ex ante conditionality on anti‑discrimination for 
all the ESI Funds, the assessment of its fulfilment shall be limited to the criteria laid down in the ESIF regulations. 
Also, when deciding on the specific and adequate policy measures — including the content of strategies — within 
national and regional competences the principle of subsidiarity should be respected. 

Member States were expected to include specific objectives and targets in their OPs in cases where they have 
selected the dedicated ESF investment priority 9(iii) ‘Combating all forms of discrimination and promoting equal 
opportunities’. This is particularly the case for Member States with country‑specific recommendations (CSRs) in this 
field.

Recommendation 1 (c)
Article 5 CPR states that relevant bodies representing civil society are part of the partnership and multi‑level gov‑
ernance principle. In accordance with Article 5(2) CPR, the partners shall be involved, inter alia, in the preparation of 
partnership agreements and through the preparation and implementation of programmes.

Recommendation 2 (a)
The Commission accepts the recommendation, considers that it should be implemented at the level of the opera‑
tional programmes, and stresses that it is already taking measures in this direction. 

As it is pointed out in paragraph 38, the Commission has issued thematic guidance called ‘Guidance for Member 
States on the use of European Structural and Investment Funds in tackling educational and spatial segregation’ 
in 2015. Member States are invited to follow the provisions of the guidance in programming and implementation 
in order to prevent and tackle both educational and housing segregation of marginalised communities, including 
Roma. 

The Commission is fully aware that effective implementation on the ground is critical. Experts are therefore being 
contracted by the Commission to help Member States to implement the guidance note primarily focusing on Czech 
Republic, Slovakia, Hungary, Romania and Bulgaria.

Reallocation and modification of Operational Programmes (OPs) should as a general rule be initiated by Member 
States.

Reply of the Commission

79

Recommendation 2 (b)
The Commission accepts the recommendation and considers that it is already taking measures in this direction.

The Commission will make full use of the national progress reports, including in monitoring committee meetings, 
with a view to invite and encourage Member States to reinforce measures supported by ESI Funds where necessary 
to better address the Roma‑related challenges identified. Following this discussion the Member States may submit 
requests for OP amendments as laid down in Article 30(1) CPR. 

Moreover, the Commission notes that in accordance with Article 23(1)(a) CPR, it may only use its powers to request 
Member States to re‑programme their OPs to address those Roma‑related challenges that are identified in country‑
specific recommendations and where the reallocation of funding to address them is needed.

Recommendation 3
The Commission notes that the recommendation is addressed to the Member States.

The possibility to fund sustainable actions to effectively support Roma integration is addressed in different ways in 
the ESIF regulations. 

First of all, long‑term (7‑year long) actions are possible under the 2014‑2020 programming period and the length of 
any given project should be commensurate with the planned objectives. 

Secondly, the ESF regulation contains a framework for better tracking positive outcomes in terms of marginalised 
groups inclusion (of which Roma) through its common output and longer term result indicators which aim at pro‑
moting the sustainability of the ESF‑funded actions for marginalised Roma communities.

Thirdly, in the case of infrastructure projects financed through ERDF, as is the case for any sector, the Member State 
should take into consideration how the sustainability of the project will be ensured in those cases where this is 
relevant after their completion (e.g. maintenance).

Recommendation 4
The Commission accepts the recommendation and will take it into account as much as possible for the next pro‑
gramming period.

Regarding the funding period 2014‑2020, it should be noted that the Roma integration objectives have been already 
reflected in the ESIF framework from the design of the operational programmes for the Member States where the 
Roma‑specific ex ante conditionality applies. 

The initiative for revising operational programmes lies mostly with the Member States. In accordance with the CPR, 
requests for amendment of programmes submitted by a Member State shall be duly justified and shall in particular 
set out the expected impact of the changes to the programme on achieving the Union strategy for smart, sustain‑
able and inclusive growth, and the specific objectives defined in the programme.

Within the legal framework for 2014‑2020, subject to audits, the managing authority of the relevant Operational 
Programme has the obligation to establish a system to record and store in computerised form data on each opera‑
tion necessary, inter alia, for monitoring and evaluation purposes. This refers to financial data, as well as to outputs 
and results.

Reply of the Commission

80

Recommendation 5
The Commission notes that the recommendation is addressed to the Member States and draws the attention to 
the fact that beside the legal limitations to collect data on the ethnicity ground in some Member States, any Roma 
specific indicator falls under the data protection regime (Article 8 of Directive 95/46/EC) of so called sensitive data. 
Individuals retain the right to refuse consent for the data to be collected. Therefore, the data on the number of 
Roma participating in ESIF‑funded activities rely indeed mostly on self‑declarations.

Recommendation 6
The Commission notes that the recommendation is addressed to the Member States.

The Commission, however, underlines that its full implementation concerning the possibility for the ESF to fund any 
social inclusion measures, irrespective of a link to employment, would require a treaty change modifying the ESF 
mission as set out in Article 162. 

The Commission further considers that the ESF regulation, as it stands and interpreted in accordance with Article 
162 TFEU, can already address the issue of Roma integration in a legally sound way through the social inclusion 
thematic objective. 

In this context, the ESF can finance Roma integration measures provided that these measures are part of an inte‑
grated set of actions aimed at bringing, even indirectly, the Roma closer to the labour market. 

This legal interpretation of the eligibility of Roma integration measures under the ESF has been communicated to 
Member States in November 2015.

The Commission, therefore, considers that there is no legal uncertainty.

Recommendation 7
The Commission accepts the recommendation and it will consider, in the context of the preparation of the next 
multiannual financial framework when examining the criteria for the allocation of funds, the role that social 
inclusion challenges should play as well as the need for a further targeting of resources to support marginalised 
communities.

Recommendation 8 (a)
The Commission does not accept the recommendation. 

While it is always willing to work with the Member States, given the diversity of national situations and approaches 
and the need to respect the subsidiarity principle, the Commission does not consider it feasible or appropriate to 
develop a common methodology in this field.

Recommendation 8 (b)
The Commission does not accept the recommendation as it considers that this issue should be left to the discretion 
of the Member States in line with the principle of subsidiarity. 

Furthermore, the Commission does not plan to collect statistical data on ethnicity in the Labour Force Survey and in 
the European Union Statistics on Income and Living Conditions. Collecting statistical data on the Roma population 
is technically and legally very difficult, as well as expensive.

Reply of the Commission

81

Introduction

12
The Commission notes that, apart from the amounts of 1.5 billion euros corresponding to the allocation to the 
investment priority 9(ii) of the ESF, further financing for the benefit of Roma inclusion is provided through a number 
of other investment priorities of both ESF and ERDF.

Observations

30
In the 2007‑2013 period the ESF regulation followed a mainstreaming approach not targeting the Roma but more 
generally disadvantaged groups. As such Roma integration was covered by the priority ‘reinforcing the social inclu‑
sion of disadvantaged people’. 

Some Member States have even chosen to explicitly cover the issue of Roma Integration in their National Strategic 
Reference Framework for the programming of the structural funds in the 2007‑2013 period.

34
The Commission notes that the EU Framework explicitly recognises that ‘first of all, Member States need to ensure 
that Roma are not discriminated against but treated like any other EU citizens with equal access to all fundamental 
rights as enshrined in the EU Charter of Fundamental Rights’. Equal treatment is therefore a horizontal principle and 
considered as precondition for effective Roma integration. While EU institutions and Member States have a joint 
responsibility to improve the social inclusion of Roma using all instruments and policies under their respective com‑
petence, Member States have the primary responsibility and competences to change the situation of marginalised 
populations, in accordance with the subsidiarity principle.

39
Partnership, together with multi‑level governance, is a long‑standing key principle of shared management funds 
(which was applied also in the previous programming periods) and as such it is also enshrined in Article 5 CPR gov‑
erning the ESI funds for 2014‑2020. The Code of Conduct adopted by means of a Commission delegated regulation 
helps Member States in organising the partnership and covers a number of practical issues such as the representa‑
tive nature of the selected partners, selection procedures, procedural requirements to ensure timely, meaningful 
and transparent consultation, as well as the principle of partner representation throughout the whole cycle, includ‑
ing at monitoring committees.

40
The Commission notes that it has contributed with significant financing to the two mentioned joint programmes 
(Romact and ROMED).

Reply of the Commission

82

44
While it has not set targets on anti‑discrimination, the Spanish NRIS emphasises the need for complementarity and 
synergies with the Second Plan for Citizenship and integration for 2011‑2014 and the National Strategy against rac‑
ism, discrimination, xenophobia and intolerance that foresee concrete measures to fight discrimination.

45
As described in the Hungarian NRIS strategy, the objective of social inclusion policy does not only address Roma, 
but it targets a wider group. Its objectives are: to reduce the rate of people living in poverty or social exclusion, to 
reduce the social arrears of disadvantaged children and to reduce social differences between Roma and non‑Roma. 
These objectives are horizontally addressed via five areas: improving labour market opportunities of long‑term 
unemployed at active age; reducing child poverty; targeting socialisation‑related and socio‑cultural disadvantages; 
addressing the disadvantages related to education and labour market for Roma women; addressing the develop‑
ment gap in disadvantaged territories.

49
In its 2015 assessment on the progress made in the implementation of NRIS for Bulgaria, the Commission indeed 
noted that the NRCP ‘lacks human and political resources to effectively fulfil its mandate and convincingly steer pro‑
gress’. However, it is also true that the implementation of NRIS relies heavily on the ESIF. Thus, in practice, the NRCP 
is supported in its functions by supplementary structures. An inter‑ministerial working group on planning and coor‑
dination of ESIF interventions in 2014‑2020 was set up in 2015 under the leadership of the ESIF Central Coordination 
Unit, with participation of the NRCP and the relevant ministries at deputy minister level (labour, education, health, 
regional development, agriculture), experts (coordinators under the six priority areas of NRIS) as well as representa‑
tives of the municipalities.

50 Second indent
The Commission notes that in the current political context there are developments which may lead to more and 
more attention being devoted to the problems of the Roma in Bulgaria.

51 First indent
In Bulgaria, annual monitoring of the implementation of the NRIS takes places on the basis of administrative report‑
ing of all relevant institutions and municipalities, and it will be further strengthened through a new monitoring 
system to be ready by end‑December 2016.

54
See Commission reply to paragraph 50 concerning Bulgaria.

Reply of the Commission

83

60
The Commission does not share the Court’s observation implying that there is legal uncertainty. The mission of the 
ESF as laid down in Article 162 TFEU is to improve the employment opportunities for workers in the internal market. 
Therefore, applying the thematic objective 9 on social inclusion in accordance with Article 162 TFEU implies that the 
ESF can finance any Roma integration measures that are part of an integrated set of actions which contribute, even 
if only indirectly, to bringing Roma closer to the labour market. This legal interpretation of the eligibility of Roma 
integration measures under the ESF has been clarified and communicated to Member States in November 2015. 
The ESF support can be further complemented by other instruments that Member States can use to address the 
basic needs and to provide material assistance to the Roma such as the Fund for European Aid to the Most Deprived 
(FEAD).

The Commission also notes that the Court has only included in its sample completed ERDF housing projects. Given 
the date of modification of the regulation and the lead time necessary for the preparation of such projects, a num‑
ber of projects were still underway at the time of the audit.

61
The Commission notes that no regulatory requirement existed for such indicators in the programme. However, as 
regards ESF, Annex XXIII required the reporting of actual participation of minorities, and of disadvantaged groups 
into ESF operations.

The Commission notes that as under the programming period 2007‑2013 the ESF followed a mainstream approach 
to support disadvantaged groups, the definition of target groups as well as the specific objectives, targets and 
indicators to be used were left to the Member States on the basis of the challenges they faced as outlined in their 
national reform programmes (NRPs) and national action plans for social inclusion (NAPSI).

62
The absence of financial information is explained by the fact that the Roma population was not exclusively targeted 
for ESF support. 

64
For instance, Hungary and Czech Republic launched actions supported by ERDF targeting deprived neighbour‑
hoods populated by Roma before the amendment.

65
The Commission notes that according to the EU legal framework on data protection, individuals have the right to 
refuse consent for the collection of data related to ethnicity. As such, data collected on ethnicity can indeed prove 
unreliable to support a decision on the necessary level of funding for Roma integration.

A few Member States (e.g. Hungary, Slovakia) have introduced either ethnic or socioeconomic proxy indicators 
(such as poverty maps, segregated neighbourhoods in urban and rural areas, people in extreme poverty) in order 
to identify the needs and determine the necessary funding. Involvement of Roma communities is ensured by these 
approaches.

See also paragraph 87 of the Court’s report.

Moreover, in several Member States, the collection of ethnic data is prohibited by law. 

Reply of the Commission

84

68
The Commission underlines that the relevant operational programme clearly and repeatedly commits that educa‑
tional measures should lead to inclusive education and desegregation, including a specific indicator referring to the 
number of educational facilities participating in desegregation programmes.

The calls for project proposals developed from the operational programmes contain more details about the specific 
requirements linked to educational measures. These are consulted with the programme monitoring committees in 
which the Commission is also participating as advisory member. 

The guidance note on the use of ESI funds for desegregation provides a methodological guidance to be followed for 
designing the calls for proposal and implementation of the projects.

What is more, during the negotiations Hungary took into account the CSRs in place, and selected the relevant IP 
which can provide support for Roma communities.

In 2015 the Commission requested from the Hungarian authorities further information on the support provided for 
the development of public education, and would like to see more detailed description of funding available in this 
field. 

Box 5 — Lack of desegregation measures in the field of education in ESIF framework in 
Hungary
The Commission notes that a local educational equity plan is a precondition for local governments applying for 
funds including actions supported by ESI Funds. 

In the 2014‑2020 ERDF/ESF Human Resources Development OP there is clear and repeated commitment towards 
desegregation and there are a number of measures aimed at desegregation (e.g. education, housing). 

With regard to the level of detail of these measures in the OP, see Commission reply to paragraph 68.

69
The Commission notes that a number of other investment priorities from both ESF and ERDF falling under the the‑
matic objectives 8, 9 and 10 of the CPR relating to employment, social inclusion and education also support Roma 
integration with significant amounts in areas such as inclusive education, social housing, access to social and health 
services. These also contribute, where relevant, to implementing the CSRs (e.g. for pre‑school and educational 
infrastructure).

This is consistent with the application of the Common Basic Principle 2 on ‘explicit but not exclusive targeting’ and 4 
on ‘Aiming for the mainstream’. According to these, Roma inclusion should be an integral part of mainstream social 
inclusion and poverty alleviation measures, in order to prevent further isolation of Roma communities.

A good example of this is to be found in the Slovak OP on Human Resources, as confirmed by the Court in Box 8. 
Slovakia agreed to the Commission’s recommendation to establish a multi‑fund OP with two dedicated priority axes 
for ESF and ERDF respectively, each consisting of a series of specific objectives to be implemented in an integrated 
fashion.

Reply of the Commission

85

73
The Commission notes that the IP 9(ii) has been systematically selected for the OPs of the Member States with the 
highest proportion of Roma population (i.e. Bulgaria, Czech Republic, Hungary, Romania and Slovakia) and of those 
who received a CSR on Roma inclusion.

In Spain, the National OP for Social Inclusion active in the whole territory of Spain contains provisions for Roma 
Inclusion measures under IP 9(ii). 

With the aim to adopt an inclusive approach, Spain agreed with the Commission to implement comprehensive 
social inclusion measures under the IP9(i) addressed to various vulnerable sub‑groups, including Roma. In the case 
of Andalucía, the measure included in the regional ESF Operational programme under the Investment priority 9(i) 
called ‘Diseño Y Ejecución De Estrategias Locales de Empleabilidad e Inserción Social de las Personas en Situación 
o Riesgo de Exclusión Social’ targets specific local areas affected by poverty and social inclusion and provide assis‑
tance for employment, housing, social integration, education, etc. The Commission considers that the Roma popula‑
tion from Andalucía can be effectively covered by the abovementioned measure and also by the national OP.

In the case of Hungary, the Human Resources OP — which has a complementary set‑up in 2014‑2020 covering the 
six convergence regions of Hungary — has an allocation on Investment Priority 9(ii) as part of its Priority 1 and as 
transnational cooperation and financial instrument in Priority 5.

75
The Commission notes that for the financial support made available to Member States in the context of cohesion 
policy, the allocation of resources follows a repartition key based on criteria linked to the overall cohesion objec‑
tive and therefore principally reflecting their level of development. In this respect, the level of financial support 
also reflects the financing capacity of the Member States and regions and helps them address their key challenges, 
including in the context of social inclusion. Moreover, the obligation of Member States to allocate a certain mini‑
mum share of the funds to the ESF (Article 92(4) CPR), the obligation to earmark at least 20 % of these ESF resources 
to thematic objective 9 ‘promoting social inclusion, combating poverty and any discrimination’ (Article 4(2) of the 
ESF regulation) and the need to concentrate the support taking into account relevant CSRs (Article 18 CPR) ensures 
that in all Member States where the integration of the Roma is a particular challenge, sufficient ESI funds support is 
made available to address it.

79
The Commission notes that it is common that anti‑discrimination measures are included under specific objectives 
and examples of actions of other IPs, including 9(ii) but also 9(i).

In Hungary anti‑discrimination is handled as a horizontal element in the Partnership Agreement negotiations and in 
the structuring of OP allocations. This is a choice of the Member State.

In Bulgaria, although IP 9.3 is not selected as an investment priority, anti‑discrimination awareness‑raising measures 
aimed at tackling stereotypes and promoting the cultural identity of the ethnic communities are mainstreamed in 
both ‘Human Resources Development’ and ‘Science and Education for Smart Growth’ OPs as a tool to prevent dis‑
crimination and promote equal opportunities.

In Romania the ESF‑financed Human Capital OP (HCOP) takes the view that social exclusion is not related to ethnic‑
ity, but to poverty in general. The programme therefore explicitly targets the Roma without excluding other mar‑
ginalised communities and disadvantaged groups. 

Reply of the Commission

86

83
See Commission reply to paragraph 39. 

Common Commission reply to paragraphs 84-85 
The Commission stresses that beside the legal limitations to collect data on the ethnicity ground in some Member 
States, individuals have the right to refuse consent for the data to be collected. The data on the number of Roma 
participating in ESF‑funded activities rely indeed mostly on self‑declarations. Nevertheless, all participants under 
the investment priority 9(ii) can be considered as part of marginalised communities such as Roma, which will facili‑
tate the reporting on this target group during the programming period 2014‑2020.

Common Commission reply to paragraphs 86-87 
The Commission notes that the Fundamental Rights Agency is not a competent body to interpret EU legal 
provisions.

The Commission underlines that the collection of ethnic data is unlawful in some Member States and that it is 
a national competence. If data cannot be lawfully collected, the question of its processing becomes irrelevant. 

The practical alternatives mentioned by the Court to gather data on ethnicity are in effect not exempted of severe 
limitations for monitoring purposes, although they could provide qualitative evidence on ESF support to ESF Roma 
participants. 

Since they are based on self‑declaration and requiring consent, their reliability could be reduced (there could be low 
response rates due to reluctances to self‑declare and/or respond, and responses might be biased). Also the drawing 
of samples and extrapolation could be hampered by the uncertainty of the actual population universe observed.

The NRIS adopted by Romanian Government in 2015 uses as reference the data from the 2011 census, based on the 
hetero‑identification: the self‑declared Roma account for 3.3 % of the population, representing 621 573 persons.

The Romanian authorities acknowledge in the strategy that estimates of Roma population vary and the strategy 
makes reference to Council of Europe and World Bank estimates, but the baseline remains set according to the 
census.

Instead, the Human Capital OP (ESF co‑financed) takes into account the Council of Europe’s estimation of 1.85 mil‑
lion Romanian Roma. Hence, the reliability of baseline and ethnicity data for monitoring purposes remains 
challenging.

Reply of the Commission

87

88
In 2007‑2013, there was no requirement to report Roma as a separate category and, consequently, to gather such 
data from the beneficiaries.

Member States were only required to report (and gather data) on the characteristics of the participants in ESF 
operations. Data on Roma participants were reported as part of the categories ‘Minorities’ or ‘Other disadvantaged’ 
in the breakdown of participants by vulnerable groups, in accordance with national rules. 

The 2007‑13 OPs did also not have Roma‑related common output indicators, reflected in relevant OPs as ‘pro‑
gramme indicators’ and aggregated at EU level.

Roma as a separate category would only have been reported in the annual implementation reports if such a specific 
indicator was selected for target setting in the OP.

89
For Spain in the 2007‑2013, the Roma population was not a specific target group for many of the operations; there‑
fore there was no obligation to specify the ethnicity of the participants. In addition, as acknowledged by the Coun‑
cil recommendation on Effective Roma integration, data collection on ethnic grounds can be a sensitive issue and 
Member States should be allowed to choose their own monitoring methods in line with the principle of subsidiarity. 

90
For the 2014‑2020 programming period, the OPs contain provisions to ensure data consistency. These also empha‑
sise the need to make all definitions available to all beneficiaries. Moreover, the Commission provided practical 
guidance on ensuring the consistency of indicator definitions.

There is also a new requirement to record and store performance data by operation in a computerised form in order 
to allow them to be aggregated where necessary for the purpose of monitoring, evaluation, financial management, 
verification and audit (Article 24(2) of Commission Delegated Regulation 480/2014). 

In Romania the existence of three types of indicators has been raised and eventually addressed in the Human 
Capital OP 2014‑2020 which foresees output and result indicators at programme level that have subsequently been 
defined in the Specific Guidelines that accompany each call for applications. 

91
When targeting particularly vulnerable groups, it is sometimes meaningful not to set quantified result targets (as 
opposed to outputs targets) so as to prevent ‘creaming’ effects (i.e. that lesser disadvantaged groups are selected 
for the intervention in order to achieve a higher success rate). 

For the 2014‑2020 programming period, targets are to be set at operation level for each relevant result indicator 
(see Annex III of the Commission Delegated Regulation 480/2014). 

Reply of the Commission

88

92
While Annex I of the 2014‑2020 ESF regulation does not foresee a precise common indicator for Roma participants, 
the monitoring of Roma integration will be significantly improved in cases where specific indicators are agreed in 
the OP or if the specific objective targets exclusively Roma population.

Furthermore, the collection of data on individual participants will enhance the possibility of bodies responsible for 
the operations and managing authorities to aggregate and monitor data on Roma participants, including results.

In case of operations exclusively targeted to Roma, detailed information about the socioeconomic characteristics 
and labour market situation and results of the ESF participants will be collected through the common output and 
result indicators and any additional specific indicator agreed in the OP. This applies also to IPs not exclusively tar‑
geted to Roma but for which the OP foresees a specific indicator on Roma. These have to be recorded and stored at 
operation level, as required by Annex III of the Commission Delegated Regulation (EU) No 480/2014 of 3 March 2014.

93
The weakness identified by the Court is addressed by the current regulatory framework.

Member States with important challenges in the social inclusion of Roma are addressing them through separate 
Investment Priority 9(ii) on marginalised communities such as Roma. In this case, detailed information about the 
socioeconomic characteristics and labour market situation and results of the ESF participants covered by the IP will 
be collected through the common output and result indicators. 

Furthermore, Roma‑related programme specific indicators may provide specific information on Roma. In the 
adopted operational programmes, 69 programme specific indicators refer to Roma, in particular in Croatia, Roma‑
nia, Slovenia and Spain.

The existence of an ex ante conditionality in this area will improve the monitoring of the Member States in this area. 
Member States have until end 2016 to fulfil all ex ante conditionalities. 

96
The Commission underlines that the selection criteria should be in line with the specific objectives set out in the 
OPs. Therefore, if the specific objectives of the OPs do not target Roma people, the selection criteria will embrace 
the disadvantaged groups as mentioned in the specific objectives of the OPs.

For the ERDF managing authority concerned in Bulgaria, the target group was wider than Roma people as the calls 
for proposals were structured in a way to open up these for all marginalised communities, not just Roma.

Reply of the Commission

89

98
For the 2014‑2020 programming period, the OPs contain provisions to ensure data consistency. These also empha‑
sise the need to make all definitions available to all beneficiaries. Moreover, the OP provides practical guidance on 
ensuring the consistency of indicator definitions.

For ERDF, the reporting on indicators at programme level was not obligatory in 2007‑2013. Indicators at project level 
are included in the relevant applications, and monitored by the Member States.

The Commission receives the applications only for major projects.

99
During the 2007‑2013 programming period, there were no common result indicators by target group in the EU regu‑
latory requirements.

‘Vulnerable groups’ may therefore be used to target a wider population in similar life circumstances as some of the 
Roma population, and not differentiate on ethnic basis.

In the specific case mentioned, the Roma population was not a separate target group in the ESF Andalucía OP in the 
2007‑2013 programming period, but was addressed as part of the vulnerable population at risk of social exclusion. 
Result targets were defined for the number of people overall at risk of exclusion.

100
While two municipalities in Bulgaria failed to implement their projects due to negative public opinion in the local 
area, all other municipalities are about to finalise (or in one case have already done so as in the case of Devnja) their 
successful social housing projects.

101
The Commission notes that while project implementation deviated in some cases from the initial planning, it did 
not have a direct impact on the target groups.

102
See Commission reply to paragraph 91 relating to ‘creaming’ effects.

103
The Commission underlines that the use of Roma‑specific criteria is appropriate in cases where the selection criteria 
set out in the call for proposals specifically target Roma people, which was not systematically the case for the 19 
projects audited by the ECA. 

Reply of the Commission

90

Box 10 — Lack of focus in terms of determining the target group and insufficient 
attention to cultural factors negatively affected the implementation of a health project 
(Bulgaria, project 4)
The fact that the population of vulnerable people could not be identified in advance and therefore the Roma were 
not specifically mentioned as a target group was due to limitations in the data of the national screening register 
and the non‑collection of information on the basis of ethnicity. 

In the case of the project involving health screenings in Bulgaria, the beneficiary explained that, for reasons linked 
to non‑discrimination, no sub‑population was specifically targeted.

107
While it is true that SEPE was named Intermediate Body for this OP only in 2014, its participation in the last Monitor‑
ing Committee was an opportunity for exchange of best practices, useful especially in the current programming 
period.

118 — First indent
See Commission replies to paragraphs 81 and 88 on reporting requirements and to paragraph 91 relating to ‘cream‑
ing’ effects.

118 — Second indent
For the 2014‑2020 programming period, the OPs contain provisions to ensure data consistency. These also empha‑
sise the need to make all definitions available to all beneficiaries. Moreover, the OP provides practical guidance on 
ensuring the consistency of indicator definitions.

Conclusions and recommendations

121
In a number of cases, the projects selected did not target explicitly Roma people but rather disadvantaged/vul‑
nerable groups of people due to the mainstreaming approach explained in the Commission reply to paragraph 
30. It is for this reason that the data collected, including financial ones as well as the indicators used, were not 
Roma‑specific.

The Commission also recalls that the 2007‑2013 regional operational programmes covered pilot projects on sup‑
port for housing for the benefit of vulnerable groups, including Roma; such projects were explicitly developed 
with an enhanced focus on an integrated approach, addressing several dimensions associated to social inclusion 
goals. Unfortunately these projects were not finalised at the cut‑off date of the ECA audit targeted at completed 
operations.

Reply of the Commission

91

124
The Commission recalls that certain countries (e.g. Hungary and Slovakia) identified Roma inclusion as an important 
topic in their National Strategic Reference Frameworks (NSRF) for the 2007‑2013 period and developed comprehen‑
sive approaches for addressing it, prior to the development of the NRIS in the context of the EU policy framework.

125
The Commission notes that the 2013 recommendation is rather an extension of the EU framework that goes beyond 
the framework and provides new areas that were not mentioned in the 2011 communication.

126
The shortcomings mentioned by the Court were already identified by the Commission in its 2012 assessment. 

Recommendation 1
The Commission notes that the recommendation is addressed to the Member States.

Recommendation 1 (a)
The Commission recalls that the level of ESI funds support to measures for marginalised communities such as the 
Roma can only be indicative given the fact that Member States are only required to provide financial data when the 
dedicated ESF investment priority 9(ii) is selected and/or when specific targets/objectives/indicators have been set 
in other ESF and ERDF relevant thematic objectives.

Recommendation 1 (b)
The Commission underlines that, if the CPR contains a general ex ante conditionality on anti‑discrimination for 
all the ESI Funds, the assessment of its fulfilment shall be limited to the criteria laid down in the ESIF regulations. 
Also, when deciding on the specific and adequate policy measures — including the content of strategies — within 
national and regional competences the principle of subsidiarity should be respected. 

Member States were expected to include specific objectives and targets in their OPs in cases where they have 
selected the dedicated ESF investment priority 9(iii) ‘Combating all forms of discrimination and promoting equal 
opportunities’. This is particularly the case for Member States with CSRs in this field.

Recommendation 1 (c)
Article 5 CPR states that relevant bodies representing civil society are part of the partnership and multi‑level gov‑
ernance principle. In accordance with Article 5(2), the partners shall be involved, inter alia, in the preparation of 
partnership agreements and through the preparation and implementation of programmes.

Reply of the Commission

92

Recommendation 2 (a)
The Commission accepts the recommendation, considers that it should be implemented at the level of the opera‑
tional programmes, and stresses that it is already taking measures in this direction. 

As it is pointed out in paragraph 38, the Commission has issued thematic guidance called ‘Guidance for Member 
States on the use of European Structural and Investment Funds in tackling educational and spatial segregation’ 
in 2015. Member States are invited to follow the provisions of the guidance in programming and implementation 
in order to prevent and tackle both educational and housing segregation of marginalised communities, including 
Roma. 

The Commission is fully aware that effective implementation on the ground is critical. Experts are therefore being 
contracted by the Commission to help Member States to implement the guidance note primarily focusing on Czech 
Republic, Slovakia, Hungary, Romania and Bulgaria.

Reallocation and modification of operational programmes should as a general rule be initiated by Member States.

Recommendation 2 (b)
The Commission accepts the recommendation and considers that it is already taking measures in this direction.

The Commission will make full use of the national progress reports, including in monitoring committee meetings, 
with a view to invite and encourage Member States to reinforce measures supported by ESI Funds where necessary 
to better address the Roma‑related challenges identified. Following this discussion the Member States may submit 
requests for OP amendments as laid down in Article 30(1) CPR. 

Moreover, the Commission notes that in accordance with Article 23(1)(a) CPR, it may only use its powers to request 
Member States to reprogramme their OPs to address those Roma‑related challenges that are identified in country‑
specific recommendations and where the reallocation of funding to address them is needed.

128
The Commission stresses that as far as the ESF is concerned, the lack of focus on Roma integration during the 2007‑
2013 programming period derives from the mainstream approach on disadvantaged people adopted (see the prior‑
ity ‘reinforcing the social inclusion of disadvantaged people’). Therefore, it was up to the Member States to define 
the disadvantaged people they wanted to target based on the needs and challenges they faced.

As far as the Roma‑specific indicators are concerned, there was no regulatory requirement in place. 

Moreover, it has to be noted that the selection criteria should be in line with the specific objectives set out in the 
OPs. Therefore, if the specific objectives of the OPs did not target Roma people, the selection criteria embraced the 
disadvantaged groups of people as mentioned in the specific objectives of the OPs.

Reply of the Commission

93

129
The Commission notes that, apart from the amounts of 1.5 billion euros corresponding to the allocation to the 
investment priority 9(ii) of the ESF, further financing for the benefit of Roma inclusion is provided through a number 
of other investment priorities of both ESF and ERDF (see also Commission reply to paragraph 69).

130
The Commission notes that in the context of its responsibilities under shared management it is helping Member 
States to make sure that the changes introduced for the 2014‑2020 period will result in projects better contributing 
to Roma integration, for example through assessment of the fulfilment of relevant ex ante conditionalities, guidance 
or its advisory role in monitoring committees.

131
The Commission refers to its reply to paragraph 75 and considers that the obligation of Member States to allocate 
a certain minimum share of the funds to the ESF (Article 92(4) CPR), the obligation to earmark at least 20 % of ESF 
resources to thematic objective 9 'promoting social inclusion, combating poverty and any discrimination' (Article 
4(2) of the ESF regulation) and the need to concentrate the support taking into account relevant CSRs (Article 18 
CPR) ensure that in all Member States where the integration of the Roma is a particular challenge, sufficient ESI 
funds support is made available to address it.

Recommendation 3
The Commission notes that the recommendation is addressed to the Member States.

The possibility to fund sustainable actions to effectively support Roma integration is addressed in different ways in 
the ESIF regulations. 

First of all, long‑term (7‑year long) actions are possible under the 2014‑2020 programming period and the length of 
any given project should be commensurate with the planned objectives. 

Secondly, the ESF regulation contains a framework for better tracking positive outcomes in terms of marginalised 
groups inclusion (of which Roma) through its common output and longer term result indicators which aim at pro‑
moting the sustainability of the ESF‑funded actions for marginalised Roma communities.

Thirdly, in the case of infrastructure projects financed through ERDF, as is the case for any sector, the Member State 
should take into consideration how the sustainability of the project will be ensured in those cases where this is 
relevant after their completion (e.g. maintenance).

Reply of the Commission

94

Recommendation 4
The Commission accepts the recommendation and will take it into account as much as possible for the next pro‑
gramming period.

Regarding the funding period 2014‑2020, it should be noted that the Roma integration objectives have been already 
reflected in the ESIF framework from the design of the Operational Programmes for the Member States where the 
Roma‑specific ex ante conditionality applies. 

The initiative for revising operational programmes lies mostly with the Member States. In accordance with the CPR, 
requests for amendment of programmes submitted by a Member State shall be duly justified and shall in particular 
set out the expected impact of the changes to the programme on achieving the Union strategy for smart, sustain‑
able and inclusive growth, and the specific objectives defined in the programme.

Within the legal framework for 2014‑2020, subject to audits, the managing authority of the relevant Operational 
Programme has the obligation to establish a system to record and store in computerised form data on each opera‑
tion necessary, inter alia, for monitoring and evaluation purposes. This refers to financial data, as well as to outputs 
and results.

Recommendation 5
The Commission notes that the recommendation is addressed to the Member States and draws the attention to 
the fact that beside the legal limitations to collect data on the ethnicity ground in some Member States, any Roma 
specific indicator falls under the data protection regime (Article 8 of Directive 95/46/EC) of so‑called sensitive data. 
Individuals retain the right to refuse consent for the data to be collected. Therefore, the data on the number of 
Roma participating in ESIF‑funded activities rely indeed mostly on self‑declarations. 

Recommendation 6
The Commission notes that the recommendation is addressed to the Member States.

The Commission, however, underlines that its full implementation concerning the possibility for the ESF to fund any 
social inclusion measures, irrespective of a link to employment, would require a treaty change modifying the ESF 
mission as set out in Article 162. 

The Commission further considers that the ESF regulation, as it stands and interpreted in accordance with Article 
162 TFEU, can already address the issue of Roma integration in a legally sound way through the social inclusion 
thematic objective. 

In this context, the ESF can finance Roma integration measures provided that these measures are part of an inte‑
grated set of actions aimed at bringing, even indirectly, the Roma closer to the labour market. 

This legal interpretation of the eligibility of Roma integration measures under the ESF has been communicated to 
Member States in November 2015.

The Commission, therefore, considers that there is no legal uncertainty.

Reply of the Commission

95

Recommendation 7
The Commission accepts the recommendation and it will consider, in the context of the preparation of the next 
multiannual financial framework when examining the criteria for the allocation of funds, the role that social 
inclusion challenges should play as well as the need for a further targeting of resources to support marginalised 
communities.

133
The Commission underlines that the collection of ethnic data is unlawful in some Member States and that it is 
a national competence. 

Beside the legal limitations to collect data on the ethnicity ground in some Member States, individuals have the 
right to refuse consent for the data to be collected. The data on the number of Roma participating in ESIF‑funded 
activities rely indeed mostly on self‑declarations. 

Nevertheless, all participants under the investment priority 9(ii) can be considered as part of marginalised com‑
munities such as Roma, which will facilitate the reporting on this target group during the programming period 
2014‑2020.

The 2014‑2020 OPs also contain provisions to ensure data consistency. These emphasise the need to make all defini‑
tions available to all beneficiaries. Moreover, the OP provides practical guidance on ensuring the consistency of 
indicator definitions.

There is also a new requirement to record and store performance data by operation in a computerised form in order 
to allow them to be aggregated where necessary for the purpose of monitoring, evaluation, financial management, 
verification and audit (Article 24(2) Commission Delegated Regulation 480/2014). 

Article 142 CPR states that all or part of the interim payments may be suspended if ‘there is a serious deficiency in 
the quality and reliability of the monitoring system or of the data on common and specific indicators’.

Recommendation 8 (a)
The Commission does not accept the recommendation. 

While it is always willing to work with the Member States, given the diversity of national situations and approaches 
and the need to respect the subsidiarity principle, the Commission does not consider it feasible or appropriate to 
develop a common methodology in this field.

Recommendation 8 (b)
The Commission does not accept the recommendation as it considers that this issue should be left to the discretion 
of the Member States in line with the principle of subsidiarity.

Furthermore, the Commission does not plan to collect statistical data on ethnicity in the Labour Force Survey and in 
the European Union Statistics on Income and Living Conditions. Collecting statistical data on the Roma population 
is technically and legally very difficult, as well as expensive.

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Event

Adoption of APM/Start of audit

Official sending of draft report to Commission (or other auditee)

Adoption of the final report after the adversarial procedure

Commission’s (or other auditee’s) official replies received in all languages

Date

22.10.2014

21.3.2016

4.5.2016

14.6.2016

 
 
At an estimate of 6.2 million, the Roma population is the 
EU’s largest ethnic minority. But it is mostly marginalised. 
This report assesses whether EU policy initiatives and 
financial support in Bulgaria, Spain, Hungary and Romania 
have contributed effectively to Roma integration. Some 
1.5 billion euros has been earmarked for the integration of 
marginalised communities such as Roma between 
2014 and 2020. We found that while the European 
Commission has made significant progress in setting out 
policy initiatives to promote Roma integration, obstacles 
and dilemmas remain and additional efforts are required 
at both Commission and Member State level.

EUROPEAN
COURT
OF AUDITORS