Special Report No 3 // 2017#EU Assistance to Tunisia #(pursuant to Article 287(4), second subparagraph, TFEU)
Date: 2017-02-14
Institutions: European Court of Auditors
Subjects: EU aid, European neighbourhood policy, Tunisia, democratisation, economic development, economic situation, economic stabilisation, financial aid, international cooperation, macroeconomics

EN 

2017 

NO 03

Special Report  EU Assistance  

to Tunisia

1977 - 2017

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

Tel. +352 4398-1
Enquiries: eca.europa.eu/en/Pages/ContactForm.aspx
Website: eca.europa.eu
Twitter: @EUAuditors

More information on the European Union is available on the internet (http://europa.eu).

Luxembourg: Publications Office of the European Union, 2017

Print 
PDF 
EPUB 

ISBN 978-92-872-6978-2 
ISBN 978-92-872-7000-9 
ISBN 978-92-872-6997-3 

ISSN 1831-0834 
ISSN 1977-5679 
ISSN 1977-5679 

doi:10.2865/20964 
doi:10.2865/68205 
doi:10.2865/351177 

QJ-AB-17-002-EN-C
QJ-AB-17-002-EN-N
QJ-AB-17-002-EN-E

© European Union, 2017
Reproduction is authorised provided the source is acknowledged.

EN 

2017 

NO 03

Special Report

EU Assistance  
to Tunisia

(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 Chamber III of the ECA, which is responsible for the audit of the external ac-
tions’ and security and justice spending areas. Mr Karel Pinxten, Dean of this Chamber, is the reporting Member. He was 
supported in the preparation of the report by the Head of his office, Gerard Madden; Alejandro Ballester Gallardo, Princi-
pal audit manager; Nikolaos Zompolas, Head of task; Thomas Haellstrom, Erika Soveges and Nicola Berloco, Auditors.

From left to right: Karel Pinxten, Alejandro Ballester Gallardo, Nikolaos Zompolas, Gerard Madden,  
Erika Soveges, Nicola Berloco, Thomas Haellstrom.

Contents

03

Paragraph

Acronyms and abbreviations

I - VIII 

Executive summary

1 - 11 

Introduction

1 - 6 

7 - 8 

Country context

EU cooperation framework

9 - 11 

Funding for development

12 - 15  Audit scope and approach

16 - 61  Observations

16 - 28 

The EEAS and the Commission addressed most key challenges with substantial additional funds in 
coordination with the main donors but aid was not sufficiently focused

17 - 22 

Funds were significantly increased to address urgent requirements

23 - 25 

Funds were spread over too many areas

26 - 28 

EU actions were well coordinated with the main donors, but joint programming with the Member States 
was not achieved

29 - 61 

EU actions substantially assisted Tunisia but there were shortcomings in the Commission’s 
implementation of programmes

30 - 44  General budget support was disbursed quickly but the conditionality attached was too flexible

45 - 47 

The MFA loan provided valuable access to finance despite delays and a low rate of disbursement

48 - 54 

Sectoral budget support programmes were relevant but lacked a credible strategy

55- 61 

Projects tackled relevant issues but there were design weaknesses and delays

 
Contents 

04

62- 73  Conclusions and recommendations

Annex I  —  List of Budget Support Programmes and Macro-Financial Assistance

Annex II  —  List of projects

Replies of the Commission and the EEAS

 
 
 
05

Acronyms and 
abbreviations

ADB: African Development Bank

AFD: Agence Française de Développement

BSP: Budget Support Programmes

CRIS: Common Relex Information System

DAC: Development Assistance Committee (of the Organisation of Economic: Cooperation and Development)

EBRD: European Bank for Reconstruction and Development

EEAS: European External Action Service

EIB: European Investment Bank

ENI: European Neighbourhood Instrument

ENPI: European Neighbourhood and Partnership Instrument

EUD: European Union Delegation

IMF: International Monetary Fund

MFA: Macro-Financial Assistance

NIF: Neighbourhood Investment Facility

NIP: National Indicative Programme

PAR: Programme d’Appui à la Relance

PEFA: Public Expenditure and Financial Accountability

SPRING: Support for Partnership, Reforms and Inclusive gGrowth

SBC: State Building Contracts

SSF: SINGLEingle SUPPORTupport FRAMEWORKramework

Executive summary

06

I
Tunisia’s ‘Jasmine revolution’, in January 2011, is regarded as the first of the ‘Arab Spring’ series of uprisings. Since 
then, Tunisia has substantially advanced its political transition to democracy during a period of uncertainty charac-
terised by political instability, social unrest and terrorist attacks. The EU has provided considerable political and sub-
stantial financial support to help Tunisia cope with the new challenges. In the period 2011 to 2015, the EU allocated 
a sum of 1.3 billion euro bilateral assistance to Tunisia.

II
We assessed whether the EU assistance delivered to Tunisia after the Arab Spring revolution of 2011 has been well 
spent. We conclude that the money was generally well spent as it contributed significantly to the democratic transi-
tion and the economic stability of Tunisia after the revolution. However, there were a number of shortcomings in 
the Commission’s management of the assistance.

III
The European External Action Service (EEAS) and the Commission responded quickly with financial support to 
address two of the main challenges: the economic crisis and the transition to democracy. We found that the Com-
mission tried to tackle too many areas with the result that the potential impact of its aid was diluted and its numer-
ous actions were difficult to manage. EU actions were well coordinated with the main donors and within the EU 
institutions and departments, but joint programming with the Member States was not realised.

IV
EU finance was delivered in a number of ways: general and sectoral budget support, a Macro-Financial Assistance 
(MFA) loan and stand-alone projects.

Executive summary 

07

V
Four large budget support programmes transferred substantial funds quickly, and assisted the Tunisian counter-
parts to shape a reform agenda. Nevertheless, the disbursement conditions were too flexible and reduced the part-
ner’s incentive to take the measures specified in the financing agreements. The Public Expenditure and Financial 
Accountability (PEFA) assessment, which could serve as an indisputable test of the real progress on reforms in the 
public finance sector, has not been made since 2010. The new PEFA assessment is expected to be finalised in March 
2017.

VI
Slow implementation was a major shortcoming which was common to the MFA loan, most of the sectoral budget 
support and projects. The MFA loan helped Tunisia to access finance on favourable terms. Sectoral budget support 
was provided to three sectors but two of these lacked credible sector strategies. For both sectoral budget support 
and projects, we found cases where the objectives of actions were neither specific nor measurable.

VII
The Tunisian authorities implemented some significant reforms but at a very slow pace. This slow implementation 
was mainly due to the numerous changes of government and the significant nature and number of the challenges 
faced. The Commission has committed itself to continue supporting Tunisia, both politically and financially, in deal-
ing with these challenges.

VIII
The report sets out a number of recommendations to improve the planning of the assistance and the management 
of the EU actions.

Introduction

08

1 

2 

3 

4 

The World Bank, World Data 
Bank, Development Indicators.

The National Dialogue Quartet 
was formed in 2013 and 
comprises four organisations 
in Tunisian civil society: The 
Tunisian General Labour 
Union, the Tunisian 
Confederation of Industry, 
Trade and Handicrafts, the 
Tunisian Human Rights 
League and the Tunisian Order 
of Lawyers.

International Monetary Fund, 
‘Request for an extended 
arrangement under the 
extended Fund Facility’, 
May 2016.

Tunisia transparency score has 
decreased from 41 in 2012 and 
2013, to 40 in 2014 and 
38 in 2015.

Country context

01 
Tunisia is a lower middle income country situated in North Africa. In 2015 it had 
a population of approximately 11 million and a Gross National Income per capita 
of 3 970 USD1. After 23 years in power President Zine El Abidine Ben Ali was 
deposed in January 2011 following the Tunisian Revolution, also known as the 
‘Jasmine Revolution’. This is regarded as being the first of the uprisings collec-
tively known as the Arab Spring.

02 
Tunisia is the post Arab Spring revolution country with the most advanced politi-
cal transition. In the past four years, it adopted a new constitution and held free 
and fair elections. The 2015 Nobel Peace Prize was awarded to the National Dia-
logue Quartet2 for ‘its decisive contribution to building a pluralistic democracy in 
Tunisia, in the wake of the Jasmine Revolution of 2011’. 03 
After 2011, the country experienced significant uncertainty, social unrest and 
attacks against civil targets by armed militants. In this period, it has struggled 
to preserve short-term macroeconomic stability in the face of a difficult interna-
tional economic environment and increased regional turmoil.

04 
Strengthening economic activity is one of the most significant challenges of 
Tunisia as this is a prerequisite for sustainably addressing the core socioeconomic 
concerns of the country, namely high unemployment and regional disparities. 
During the decade 2000 to 2010, Tunisia achieved average economic growth of 
4.4 %, but the rate contracted by 1.9 % in 2011, the year of the revolution. The 
overall unemployment rate is high. After rising to 19 % in 2011, it improved to 
15 % in 2015. Nevertheless, the rate of unemployment is particularly high among 
women (23 %), young graduates (67 %), and young people in general (35 %)3.

05 
Tunisia faces challenges related to the weak institutional capacity, the excessive 
centralization of decision making and corruption. Tunisia ranked in the middle of 
the ranking, 76th out of 174 countries in 2015, in Transparency International’s Cor-
ruption Perception Index4. The World Justice Project Rule of Law Index for 2015 
ranks Tunisia 43rd overall and among the best countries in the region.

09

5 

6 

In 2015, tourism activities 
(foreign exchange receipts) 
declined by 54 %.

EEAS/European Commission, 
Tunisie Programme Indicatif 
National 2011-2013.

7  COM(2011) 200 final of 8 March 

2011 ‘A partnership for 
Democracy and Shared 
Prosperity with the southern 
Mediterranean’.

8  COM(2011) 303 final of 

25 May 2011 ‘A new response 
to a changing 
Neighbourhood’.

9 

EEAS, ‘Relations Tunisie-Union 
Européenne: Un partenariat 
privilégié. Plan d’Action 
2013-2017’ https://eeas.
europa.eu/delegations/
tunisia/documents/
press_corner/
plan_action_tunisie_
ue_2013_2017_fr.pdf

Introduction 

06 
Security is increasingly becoming an important challenge. Following the clashes 
with Salafists (2012), and political assassinations (2013), the 2015 terrorist attacks 
at the Bardo Museum, in Sousse and against the Presidential Guard dealt a severe 
blow to the country’s economy5 and the society alike.

EU cooperation framework

07 
The EU-Tunisia Association Agreement of July 1995 is the basis for bilateral rela-
tions. In November 2006, the Commission produced a Country Strategy Paper 
laying down the framework for EU cooperation with Tunisia for 2007-2013. In 
November 2010 the Commission produced a mid-term review of the strategy and 
the National Indicative Programme (NIP) for the period 2011 to 2013 6, which put 
this strategy into practice.

08 
EU cooperation changed significantly following the Arab Spring revolution, in 
2011. In March 2011, the EU committed to support all its southern neighbours that 
were ‘able and willing to embark on reforms through a Partnership for Democ-
racy and Shared Prosperity’7. In May 2011, the European External Action Service 
(EEAS) and the Commission adopted a new approach towards the sixteen coun-
tries of the European Neighbourhood8. This new approach aimed at strengthen-
ing the partnership between the EU and the countries and societies of the neigh-
bourhood, building and consolidating healthy democracies, pursuing sustainable 
economic growth and establishing links among the people and the civil society 
of the countries in the region. Based on the new strategic approach, in 2012, the 
EU concluded a political agreement with Tunisia on an Action Plan for the period 
2013 to 2017 which established a privileged partnership 9. The key elements of 
that partnership are:

(a)  deeper political cooperation, including high level political dialogue, parlia-

mentary cooperation, cooperation on security issues and democracy and 
justice;

(b)  greater social and economic integration with the European Union in order to 

build a Common Economic Area, as well as developing the EU-Tunisia Deep 
and Comprehensive Free Trade Agreement;

(c)  a closer partnership between peoples by strengthening individual and 

organisational links in the areas of education, employment, health, culture, 
immigration and mobility.

Introduction 

10

Funding for development

09 
The bilateral cooperation assistance allocated to Tunisia for the period from 
2011 to 2015 was 1.3 billion euro. This financing included programmes of the 
European Neighbourhood and Partnership Instrument (ENPI) and the European 
Neighbourhood Instrument (ENI), thematic instruments and programmes10, 
humanitarian aid, the Neighbourhood Investment Facility (NIF), and one MFA 
agreement signed in 2014 (see Graph 1).

10  The thematic instruments are 
the European Instrument for 
Democracy and Human 
Rights, the Instrument 
contributing to Stability and 
Peace, the cross-border 
cooperation programme 
(Italy-Tunisia), and the 
programme for non-state 
actors and local authorities.

1
h
p
a
r
G

Commitments to Tunisia by financing instrument for the period 2011 to 2015

NIF (51.3 million euro)

Thematic instruments (64.2 million euro)

Humanitarian aid (80.5 million euro)

MFA (300.0 million euro)

ENPI and ENI (800.8 million euro)

Source: European Union Delegation (EUD) in Tunisia, Rapport 2015, Coopération de l’Union européenne en Tunisie, May 2016 and Common Relex 
Information System (CRIS) database.

 
Introduction 

11

10 
In the period from 2011 to 2015, the Commission planned and implemented 
budget support programmes (see Box 1), both general and sectoral, an MFA loan 
and stand-alone projects. The general budget support programmes consisted 
of a cluster of five consecutive programmes11 that aimed at the relaunch of the 
economy and included measures for structural reforms in various areas. The 
sectoral budget support programmes had essentially been set up before 2011 
but disbursements were mostly made after the revolution. They covered various 
areas such as education, water, environment and state budget reform. Addition-
ally, the Commission funded projects covering services, works, procurement of 
equipment and twinning programmes. The Commission contracted with differ-
ent types of implementing bodies such as UN agencies, national agencies and 
civil society organisation.

11  PAR1 is a multi-sectoral 

budget operation, and PAR2 
to PAR5 are State Building 
Contracts (SBC) operations. 
SBC provide budget support 
in fragile and transition 
situations. They were 
introduced by the Commission 
in 2012 and, for the purposes 
of DAC coding they are 
considered as general budget 
support.

1
x
o
B

The budget support modality

Budget support involves the transfer of financial resources to the National Treasury of a partner country, fol-
lowing the respect by the latter of agreed conditions for payment. It is not provided to every country. Eligi-
bility criteria have to be met before and during the programme and conditions need to be fulfilled before 
payments are made.

It involves dialogue, financial transfers to the national treasury account of the partner country, performance 
assessment and capacity development, based on partnership and mutual accountability.

Budget Support is paid in fixed or variable tranches. Fixed tranches have a fixed value, specified in advance 
within the financing agreement. They are disbursed in full (when all conditions are met) or not at all (if one or 
more conditions are not met). Variable tranches have a maximum value specified in advance in the financing 
agreement. They are either disbursed in full or in part with the amount disbursed being based on the perfor-
mance achieved in relation to pre-specified targets or designated performance indicators (provided that at 
the same time the general conditions are all met).

Extracts from the European Commission’s Budget Support Guidelines, September 2012.

 
Introduction 

11 
France and Germany are the other major European bilateral donors12.The Eu-
ropean Investment Bank (EIB)13 and the European Bank for Reconstruction and 
Development (EBRD)14 are major lenders in Tunisia. International financial institu-
tions also provide substantial funding. Since 2012, the World Bank has committed 
2.1 billion USD in total. The International Monetary Fund (IMF) also has consider-
able involvement in Tunisia. In May 2016, the IMF approved a second country pro-
gramme, a 48 month extended arrangement for an amount of 2.9 billion USD15.

12

12  Since 2011, they have allocated 

to Tunisia 776 and 
950 million euro respectively 
in loans and grants.

13  Since 2011, the overall 
financing to Tunisia is 
1.5 billion euro (in sectors such 
as industry, water, transports, 
energy and services).

14  Since 2013, the EBRD has 
financed 25 projects and 
disbursed a total of 
300 million euro.

15  This is the second programme 
of IMF in Tunisia. In the period 
from 2013 to 2015, a stand-by 
agreement programme 
disbursed 1.6 billion USD to 
Tunisia.

Audit scope and approach

13

12 
The audit examined whether the EU assistance delivered to Tunisia after the Arab 
Spring revolution of 2011 has been well spent. In order to carry out this assess-
ment, the audit of the efficiency and effectiveness of the assistance answered the 
following sub-questions:

(a)  Did the EEAS and the Commission address key challenges faced by Tunisia?

(b)  Did the Commission implement its programmes well?

16  The overall bilateral 

cooperation assistance for the 
period from 2011 to 2015 is 
1.3 billion euro. This sum 
includes programmes through 
the ENPI, the ENI, the thematic 
instruments, the NIF and the 
MFA loan.

17  The IMF, the African 

Development Bank, the World 
Bank, the Agence Française de 
Développement.

13 
The audit covered the spending through the ENPI and the ENI. It focused on 
the economic crisis response programmes and the EU actions in the areas of 
democratic transition, governance, justice, and economic growth. The audit also 
covered MFA.

14 
The audit sample covered 70 % of the bilateral cooperation assistance allocated 
to Tunisia from 2011 to 201516. As well as the MFA loan, we audited seven budget 
support programmes and fourteen projects. More detailed information on the EU 
actions covered is given in Annexes I and II.

15 
The audit work was carried out between March and July 2016. We gathered 
evidence for our assessment through documentary review and interviews with 
the EEAS, the Commission and the EU Delegation in Tunis, the Tunisian authori-
ties, Civil Society Organisations, as well as International Financial Institutions and 
other donors17. We also carried out a two week visit to Tunisia in May 2016.

Observations

14

18  The multi-annual 

development assistance 
strategy for the period 
2007 to 2013 was laid down in 
the country strategy paper. 
The NIP 2011-2013 defined in 
further detail the allocated 
funds and the priorities. The 
NIP referred to the funds 
allocated under the ENPI.

19  From 2014 onwards, ENI has 
replaced ENPI as the main 
development cooperation 
instruments with the 
neighbourhood countries.

20  The ‘more for more’ incentive 
mechanism (called SPRING in 
the context of ENPI (until 2013) 
and Umbrella funds in the 
context of the ENI (see also 
table 1 on the additional 
contributions)).

The EEAS and the Commission addressed most key 
challenges with substantial additional funds in 
coordination with the main donors but aid was not 
sufficiently focused

16 
In this section, we examine whether priorities and funding allocations were prop-
erly adapted after 2011 in order to address the key challenges faced by Tunisia. 
We also assess whether the challenges were promptly addressed through well-
coordinated actions.

Funds were significantly increased to address urgent 
requirements

17 
In 2010, before the revolution, the Commission had a development aid pro-
gramme18 of 240 million euro for the period 2011 to 2013. It set the following pri -
ority areas for the development assistance: employment, economic reforms and 
support to the private sector and justice. A cross-cutting objective was to extend 
the reach of good governance.

18 
In the aftermath of the revolution the funds allocated were substantially in-
creased and the focus of the EU bilateral cooperation was changed. The alloca-
tions for the period 2011 to 2013 almost doubled to 445 million euro. The average 
annual allocations, from the ENPI and the ENI19, surged from 80 million euro, 
for the period before the revolution, to 170 million euro, for the period from 
2011 to 2015 (see  Graph 2). The significantly augmented funding was granted in 
particular through the incentive-based mechanism ‘more for more’ which pro-
vided additional assistance to the partner countries showing sustained commit-
ments to and progress in reforms20.

Observations 

15

2
h
p
a
r
G

ENPI and ENI annual commitments to Tunisia for the period 2007 to 2015

o
r
u
e
n
o

i
l
l
i

m

250

200

150

100

50

0

170  million

80 million

2007

2008

2009

2010

2011

2012

2013

2014

2015

Source: CRIS Database.

19 
Since 2011, support for democracy has been one of the targeted areas for assis-
tance (see Graph 3). EU election observation missions were undertaken to ensure 
that elections were conducted properly. Further support for the democratic tran-
sition was provided by programmes to support civil society, justice and the ac-
tivities of the new parliament. After 2011, the Commission prepared programmes 
to address the regional disparities which were among the causes of security and 
social tensions. These programmes supported marginalised areas, the rehabilita-
tion of low-income neighbourhoods and the health sector.

 
 
Observations 

16

ENPI and ENI commitments to Tunisia before and after 2011 by priority area (size in 
proportion of the allocations per year)

3
h
p
a
r
G

EU COMMITMENTS 
AFTER THE REVOLUTION

EU COMMITMENTS 
BEFORE THE REVOLUTION

2007-2010

Sustainable development 
18 %
Improved graduate 
employbility
22 %

300
mio €

Economic governance 
and competitiveness
60 %

2011-2013

2011-2013

Justice
7 %

Support to the 
private sector
34 %

Employment
23 %

Economic reforms
and governance
36 %

240 
mio €

445 mio €

Economic reform
and recovery
73 %

Social sector and
environment
20 %

Good governance
and democracy
7 %

2014-2015

356 mio €

Fundamental elements
of democracy
18 %

Regional and local
development
20 %

Socio-
economic 
reform for 
inclusive growth
62 %

Source: European Commission NIPs and State of the Play, October 2015.

 
Observations 

17

20 
The additional funds that were made available after the revolution, allowed the 
EEAS and the Commission to provide substantial support for the national pro-
gramme for economic recovery. In a fragile and deteriorating macroeconomic 
situation, the Programme d’Appui à la Relance (PAR) was a large relaunch pro-
gramme which brought together substantial funds from various donor and finan-
cial institutions to provide much needed funds to tackle the pressing economic 
needs. The Commission contribution to PAR was its largest outlay in terms of 
funds committed in Tunisia. This funding comprised of five general budget sup-
port programmes that committed 448 million euro in five years, i.e. more than 
half of the funds allocated under ENPI and ENI for the period 2011 to 2015. This 
amount was bolstered by ‘more for more’ funds which provided an extra 155 mil-
lion euro in the period from 2011 to 2015 (see paragraph 18 and  Table 1). This 
general budget support had particular significance for the Tunisian authorities 
as most of the other funding provided from donors was in in the form of loans, 
which had servicing costs and payback obligations.

1 Contribution of ‘more for more’ allocations to PAR programmes
e
l
b
a
T

(million euro)

PAR programme

PAR1

PAR2

PAR3

PAR4

PAR5

Total 

Year

2011

2012

2013

2014

2015

Overall allocated amount

‘more for more’ funds 
allocated to PAR 
programmes

Total ‘more for more’ 
funds allocated annually

100

68

110

100

70

448

10

0

45

47

53

155

20

80

55

50

71.8

276.81

1 

 The balance of ‘more for more’ funds of 121.8 million euro was used for projects over a wide range of areas e.g. justice, renovation of 
infrastructure of poor neighbourhoods, etc.

Source: EEAS and CRIS database.

21 
The Commission addressed the economic needs of the country primarily through 
the PAR programmes but additional support was provided through an MFA loan 
and specific projects. Following a request from the Tunisian authorities a loan of 
300 million euro was provided, in 2014, to supplement the IMF loan in support of 
the government’s economic stabilisation and reform programme.

 
18

21  Commission Directorate 

General for Neighbourhood 
and Enlargement, Tunisia 
Financial Assistance fiche, 
State of play: October 2015.

22  EUD, Rapport 2015, 

Coopération de l’Union 
européenne en Tunisie.

Observations 

22 
While the macroeconomic and democratic reform challenges could be tackled 
relatively quickly, the same was not true for the security sector reform. The Tu-
nisian government first requested EU support for this reform as early as October 
2011. The Commission responded promptly to this request but it took two years 
before Tunisian authorities agreed on the terms of reference for a peer review 
of the security sector in Tunisia. In December 2013, twelve security experts from 
the EU Member States produced a peer review report. After the approval of the 
Tunisian authorities, an identification and formulation mission was carried out, in 
January 2015. The terrorist attacks in March and June 2015 accelerated the politi-
cal dialogue and in November 2015 the Tunisian government signed up to the 
Commission’s proposal for a security sector reform programme with a budget of 
23 million euro. This was four years after the initial request. Following approval of 
the programme, a contract for the rehabilitation of security infrastructures and 
the supply of equipment was signed in June 2016.

Funds were spread over too many areas

23 
The Tunisian authorities did not manage to develop a reliable and comprehensive 
national development plan. The lack of this plan prevented the donors from hav-
ing an overall view of the country’s priorities, the required funds, and the pro-
gress on key indicators. Thus, EU actions were designed on the basis of the con-
tinuous and intensive policy dialogue with the Tunisian authorities, on reports 
produced by various needs assessment and identification missions organised by 
the EEAS and the Commission.

24 
The EU actions covered a very wide range of activities. Following the 2011 revolu-
tion, there was strong demand for support across numerous sectors. The Action 
Plan for 2013-2017 of the privileged partnership (see paragraph 8) set thirteen 
priorities each of which was assigned multiple actions. Given the increase of the 
available funds, the Commission expanded the scope of cooperation to try and 
meet this demand. The strategic documents such as the NIP 2011-2013 and Single 
Support Framework (SSF) 2014-2015, set very broad priority areas. This led to 
decisions being adopted and projects being planned which covered too many 
areas. In the SSF for 2014-2015, one of the priority sectors (fundamental elements 
of democracy) included six distinct components covering a wide range of areas: 
justice, equal opportunities, migration and border management, media reform, 
security sector reform and support for the cultural sector21. The EUD’s annual 
report22 refers to actions spread over more than twenty headings (including 
education, health, agriculture, environment, climate change, transports, research, 
and thematic areas such as trans-border cooperation).

19

23  Council, European Parliament 
and Commission on European 
Union, (2006/C 46/01), Joint 
statement by the Council and 
the representatives of the 
governments of the Member 
States meeting within the 
Council, the European 
Parliament and the 
Commission on European 
Union Development Policy: 
‘The European Consensus’.

24  OECD, Paris Declaration on Aid 
Effectiveness, 2005 (http://
www.oecd.org/dac/
effectiveness/34428351.pdf).

25  Germany, Spain, France, Italy, 
the Netherlands and Austria.

26  Article 5 of Regulation (EU) No 
232/2014 of the European 
Parliament and of the Council 
of 11 March 2014 establishing 
a European Neighbourhood 
Instrument (OJ L 77, 15.3.2014, 
p. 27).

Observations 

25 
The huge variety of activity areas was contrary to the Commission’s own objec-
tive of focussing aid on a small number of areas. Recognised best practice in the 
allocation of development aid, as set out in the EU Consensus on Development23 
and the Paris Declaration on Aid Effectiveness24 states that EU donors should aim 
at focusing their active involvement in a particular country on a maximum of 
three sectors each. By not sufficiently focusing its efforts, the Commission diluted 
the potential impact of the funding and made its management more difficult.

EU actions were well coordinated with the main donors, but 
joint programming with the Member States was not achieved

26 
The EU actions were well coordinated with the main international development 
stakeholders in Tunisia such as the IMF, World Bank, African Development Bank 
(ADB) and the Agence Française de Développement (AFD). The EU planned and 
implemented important programmes together with other donors – in particular 
budget support and the MFA. Certain EU projects were executed by UN agencies, 
national development agencies and development banks. As of 2016, there were 
also nine ongoing twinning projects with a total budget of 12 million euro that 
were financed by the EU and implemented by Member States25.

27 
The EU is the donor which gives the highest amount of grants to Tunisia and is 
present in many different areas. The EUD therefore has a significant role in the 
donor community. It actively facilitates the coordination of the donors who meet 
at least monthly and discuss in detail the planning of the programmes as well as  
problems which arise during the implementation of the programmes.

28 
The EEAS and the Commission worked in close collaboration with the Member 
States through regular consultations and frequent exchanges of relevant infor-
mation at each stage of the programme cycle, in particular, in the context of the 
ENI committee. However this collaboration did not extend to joint programming 
with the MS which was recommended by the ENI regulation26. The EEAS and the 
Commission have been carrying out discussions with EU Member States over 
the past four years with a view to gradually engaging in joint programming in 
Tunisia.

Observations 

20

EU actions substantially assisted Tunisia but there 
were shortcomings in the Commission’s 
implementation of programmes

29 
In this section, we examine how well the Commission has implemented its bilat-
eral development assistance programmes. We assess four types of programmes: 
(a) four general budget support programmes, (b) three sectoral budget support 
programmes, (c) the MFA loan, and (d) 14 projects. We assess their design, execu-
tion and the outputs delivered.

General budget support was disbursed quickly but the 
conditionality attached was too flexible

30 
The PAR programmes (see paragraph 20) represented about 56 % of the ENPI and 
ENI commitments. These programmes managed to channel substantial funds to 
Tunisia, relatively quickly. Overall, it took one to two years from the design to the 
disbursement of the bulk of the amount contracted. Thus, by the end of 2015, 
the PAR programmes has paid out 78 % of the amounts committed for 2011-2015, 
while the figures for the MFA loan and projects were 67 % and 22 % respectively. 
By the end of 2015, only 60 % of the available allocations to projects were con-
tracted, while the budget support and the MFA allocations were contracted 85 % 
and 100 % respectively (see Graph 4).

4
h
p
a
r
G

Amounts allocated, contracted and paid by type of assistance (as at 31.12.2015,  
2011-2015 period)

o
r
u
e
n
o

i
l
l
i

m

500

400

300

200

100

0

Budget support

MFA

Projects

Source: CRIS database.

Allocated

Contracted

Paid

 
 
Observations 

21

31 
This EU assistance was designed to channel substantial amounts to support the 
fragile economy, promote social cohesion, and encourage Tunisia ‘to embark 
on reforms through a Partnership for Democracy and Shared Prosperity’27. The 
related disbursements during the period 2011 to 2015 were about 350 million.

27  COM(2011) 200 final.

28  The contribution of the three 
co-donors was in loans.

32 
The first PAR programme was jointly planned and implemented with the World 
Bank, the ADB and the AFD28 while the second was with the World Bank and 
the ADB. The overall budget of PAR1 was 1 billion euro in loans and grants (out 
of which 100 million euro was the contribution of the EU). The overall budget 
of PAR2 was 720 million euro in loans and grants, to which the EU contributed 
68 million euro. The joint planning and execution of those programmes amplified 
the donor’s leverage on the partner country to implement reforms. It also en-
sured that there was no duplication of efforts among the donors. The subsequent 
PARs 3 and 4 were financed by the EU only.

Disbursement conditionality was too flexible

33 
The EU contribution to the PAR programmes was by means of general budget 
support. From 2013 onwards this was classified as ‘state building contracts’ (SBC). 
This is the most flexible form of budget support and is designed for countries 
in a fragile situation or in transition. Disbursement conditions under this form 
of budget support are more flexible as, for instance, the eligibility condition for 
partner countries to have a reliable and credible national development plan is 
not required as long as the government commits to develop one. According to 
the Commission’s own budget support guidelines, SBCs are not supposed to last 
more than one or two years. For Tunisia, this form of budget support has already 
been given for three years (PARs 3 and 4) but will be used again in the latest PAR 
(PAR5), for a duration of three more years.

Observations 

22

34 
The PAR programmes function through the disbursement of one or two tranches 
over a maximum of two years. Under the best practices applicable to the budget 
support programmes, the Commission firstly agrees a reform programme with 
the partner country. Based on this programme, the Commission then decides 
on the conditions for disbursement, signs the financing agreement, and allows 
a period of time for the partner country to implement these reforms and con-
sequently fulfil the conditions of disbursement. However, in the case of the PAR 
programmes, the conditions were substantially met prior to the financing agree-
ment, already during the planning stage. This modus operandi was systematically 
used by the Commission in order to expedite the payment of the first tranche 
of the PAR programmes. Thus, the disbursement of the first tranche of PAR1 was 
made two months after the signature of the financing agreement; for the PAR2 
and PAR3 this was made after only two weeks (see Table 2).

2
e
l
b
a
T

PAR programmes execution

PAR programmes 

Speed of implementation

Programme

Decision 
year

 Allocated 

 Paid 

Date of the 
signature of 
the Financing 
Agreement

Date of  
payment 
(1st tranche)

Date of  
payment 
(2nd tranche)

Time gap 
between the 
Financing 
Agreement 
and 1st 
payment

Time gap 
between the 
Financing 
Agreement 
and 2nd 
payment

PAR 1

PAR 2

PAR 3

PAR 4

2011

2012

2013

2014

100 000 000 

99 424 813 

68 000 000 

65 415 314 

110 000 000 

110 000 000 

100 000 000 

75 000 000 

28.9.11

4.12.12

6.12.13

8.7.15

2.12.11

17.12.12

20.12.13

8.12.15

17.12.12

NA

4.12.14

pending

64

13

14

150

439

NA

358

pending

Source: CRIS database (October 2016).

35 
In one case (PAR1) the measures for the second tranche were not fixed when the 
contract was signed, but one year later. The measures needed to fulfil the condi-
tions for the payment of all the programmes’ tranches should be agreed when 
the financing agreement is signed, in order to give sufficient time to the partner 
country to implement the reforms.

 
Observations 

23

36 
As the additional ‘more for more’ funds constituted almost one third of the pro-
grammes’ budget, we examined whether they were used to establish new condi-
tions and trigger new measures from the Tunisian authorities. Only in the case of 
PAR3, a variable tranche, with three specific conditions, was further conditional-
ity added for the extra funds. These funds were determined towards the end of 
a programme’s planning (see Box 2) and while this was certainly a complicating 
factor, it did not preclude the establishment of conditions and measures.

2
x
o
B

The procedure for allocating the additional funds ‘more for more’

Steps of the procedure:

 ο In December of year N, the EUD produces the first draft of the progress report;

 ο In March of year N+1, EEAS and the EC produce a joint note on the progress in all neighbourhood countries;

 ο In June of year N+1, a decision is taken (it is approved by the ENI committee). The funds have to be commit-

ted to specific programmes by the end of year N+1.

37 
The PAR disbursements were conditional on the fulfilment of a great many 
specific measures. On average each of the four programmes examined included 
27 specific measures. These covered many wide ranging areas, namely: (a) trans-
parency, democratic participation, justice and the fight against corruption, 
(b) public finance, (c) regional disparities, (d) unemployment and social inclusion, 
(e) micro-finance, and (f) economic growth. The large number of addressed areas 
dilutes the focus of the policy dialogue with the partner country.

38 
The Commission took payment decisions having assessed overall progress and 
the government commitment to a national development plan rather than the 
completion of each measure required from the Tunisian authorities. In practice, 
this meant that the Commission assessed the overall progress as satisfactory 
even though some measures had not been taken. This approach reduced the 
partner’s incentive to take the measures set out in the financing agreement and 
weakened the leverage the Commission could exert on the Tunisian authorities to 
implement much needed reforms.

 
Observations 

24

39 
The Commission focused on output measures as opposed to long term results 
because of the political instability in the country. Most measures of the PAR 
programmes were designed to be achievable within a short time frame and often 
took the form ‘decree X shall be adopted by government’ or similar. However, 
a decree can be adopted by the government, but may not be promptly and 
properly implemented by the administration. In fact, implementation of some 
structural reforms continues to be unsatisfactory or slow, even in the areas where 
the Tunisian government has taken some measures.

Public Finance Management assessment delayed

40 
There has been no overall evaluation of the PAR programmes. Given the size 
and complexity of these programmes an overall evaluation could have provided 
useful feedback on the progress of the reforms and indicate weaknesses in the 
approach.

41 
The Commission made use of various evaluations that were carried out, by dif-
ferent international organisations, on specific aspects of governance. However, 
these were not intended to substitute for the PEFA, which is a very thorough and 
widely respected overall assessment of public financial management. Although 
the Commission’s budget support guidelines recommend a PEFA assessment 
every four years the last one was made in 2010. A commitment to conduct a new 
assessment was made in 2014 to be co-financed by the EU, the World Bank and 
the ADB. However, there were major delays in contracting an expert and in dis-
cussing the draft report with the Tunisian authorities. The new PEFA assessment 
is expected to be finalised in March 2017.

42 
Not only was the PEFA assessment required to provide assurance on all aspects 
of public finance management, it was also needed as an indicator of possible 
weaknesses which might need to be urgently addressed. For these reasons and, 
in view of the very significant amounts of budget support being paid to the 
national treasury, it is unsatisfactory that this assessment was not available within 
the period specified in the guidelines.

25

29  European Commission, 
Information Note to the 
European Parliament and to 
the Council, MFA to the 
Republic of Tunisia, 
disbursement of the Second 
Tranche, 26.11.2015.

Observations 

Slow pace of reform

43 
Overall, some progress has been made in the areas covered by the programmes 
but the pace of reforms has been slow.

(a)  With regard to transparency and participation, there has been progress in the 
areas of access to administrative information, association rights, transparency 
of the budget and publication of the reports of the Tunisian Court of Audi-
tors. However, obtaining access to administrative information related to the 
government and public organisations is a continuous challenge.

(b)  Regarding Civil Society participation, the setting up of a Non-Governmental 

Organisation (NGO) has been made easier but this is still a lengthy process. 
Although the legal framework provides that a new NGO can be set up in 
a few weeks only, in practice this takes six months to a year because of ad-
ministrative bottlenecks.

(c)  Concerning public finance management, the adoption of a National Develop-
ment Plan and the organic law on budget is required in order to improve the 
execution of the budget. The implementation of reforms regarding public 
private partnerships and public procurement has been a slow process. A new 
law on public procurement which meets international standards has been 
adopted and an action plan to replace the cumbersome procedures is ongo-
ing. A key challenge that remains is to increase the transparency, accountabil-
ity and effectiveness of external and internal audit.

(d)  In relation to regional disparities, the measures taken in the context of the 
PAR programmes have improved the revenues of the municipalities. Never-
theless, given the structural weaknesses i.e. reduced economic activities and 
lack of local taxes, the majority of the municipalities face financial difficulties 
which can only be solved by an extensive restructuring of their finance, in the 
context of the decentralization process foreseen for the beginning of 2017.

(e)  With regard to social inclusion, the government has strengthened the social 
safety net by increasing the amount of monthly allocations and the number 
of beneficiaries. Nevertheless, it has not improved the targeting of potential 
beneficiaries which must await the development of a unified registry for 
households29.

26

30 

31 

IMF, Tunisia, 2015 Article IV 
Consultation, Sixth review 
under the stand-by 
arrangement, and request for 
re-phasing, October 2015.

IMF, Request for an extended 
arrangement under the 
Extended Fund Facility, 
Annex I. The 2013-15 
SBA-Context, Design, and 
Outcomes, June 2016.

32  Decision No 778/2013/EU of 

the European Parliament and 
the Council of 12 August 2013 
providing further macro-
financial assistance to Georgia 
(OJ L 218, 14.8.2013, p. 15).

Observations 

(f)  As far as the micro-finance is concerned, although the regulatory frame-
work according to the international standards is in place, the access to 
micro-finance is still limited. An upgrade of the regulatory and supervi-
sory framework, removal of existing caps on lending rates, and appropri-
ate accounting norms would also help in this area30. It is important to 
note that the Commission implements a project aiming at supporting the 
development of microfinance in less developed areas of the country.

(g)  To boost economic growth, a new investment code in line with the objec-
tive of protecting market access, reducing investment restrictions, and ra-
tionalising exemptions, has been prepared but has not yet been adopted 
by the Parliament.

44 
The IMF noted delays in the implementation of the reforms required by its 
own programme 2013-2015. In its assessment31 the IMF states that only about 
60 % of the 46 structural benchmarks introduced under the programme were 
met. It further stated that ‘the commitment of the authorities and of a broad 
spectrum of stakeholders to the reform agenda is essential to avoid reversals 
in program implementation’.

The MFA loan provided valuable access to finance despite 
delays and a low rate of disbursement

45 
In August 2013 the Tunisian government asked the EU for a MFA loan. Tunisia 
had at that time a significant and urgent need for external financing. This aid, 
which was required urgently, took 21 months from the initial request to first 
payment (see Table 3). The Parliament and Council have declared that the EU 
should be able to make MFA available expeditiously when circumstances call 
for immediate action32. Much of the delay can, however, be seen as outside 
the control of the EU, such as the time it took for Tunisia to ratify the Memo-
randum of Understanding of the MFA operation. However, in the context of 
a request for urgent financing, it still took a considerable amount of time to 
process this loan at EU level.

Observations 

27

Timeline of the MFA

3
e
l
b
a
T

Date

Action

August 2013

December 2013

May 2014

July 2014

August 2014

March 2015

May 2015

December 2015

October 2016 

Source: European Commission.

Request by Tunisia

Commission proposal

Adoption by Council and Parliament

MFA committee

MoU counter-signed by Tunisia

Ratified by the Tunisian Parliament

1st tranche disbursed

2nd tranche disbursed

3rd tranche pending

Months from the request 
of the programme

start

4

9

11

12

19

21

28

38

46 
The EU agreed a loan of 300 million euro split into three tranches. The Commis-
sion financed the loan, through loans from financial institutions. Repayment and 
interest conditions for Tunisia were the same as the conditions the Commission 
got from the financial institutions. So far the interest rates have been low, be-
tween 0.498 % and 1.125 %. The repayment risk of the MFA loan was covered by 
the Guarantee Fund for external actions which is financed by the EU budget.

33  The Stand-By agreement 
programme 2013-2015.

34  COM(2016) 67 final of 

12 February 2016 ‘Proposition 
for a Decision of the European 
Parliament and of the Council 
providing further MFA to 
Tunisia’.

47 
Further to the access to financing at low interest rates, the MFA loan provided 
for specific reforms through the conditions for disbursement in the loan agree-
ment. The loan was designed in coordination with the IMF; the main condition 
for disbursement was satisfactory implementation of the IMF programme33. 
Additionally, it included nine conditions (similar to the conditions of the BSP); 
four conditions for the second disbursement and five for the third disbursement. 
The Commission ensured that the loan was well coordinated with the PAR pro-
grammes and the technical assistance provided by the EU and the other donors. 
The MFA programme provided much needed finance at low cost. By setting a lim-
ited number of conditions and monitoring their implementation it has managed 
to encourage the adoption of additional reforms. The Commission is preparing to 
make an additional loan of 500 million euro, having noted in this context: ‘overall, 
reform progress remains limited, in part due to the delicate political transition, al-
though the recent positive momentum is encouraging and government remains 
committed to continuing on a positive reform path’34.

 
Observations 

28

Sectoral budget support programmes were relevant but 
lacked a credible strategy

Lack of credible strategies and robust conditions

48 
The sectoral BSPs were relevant as they addressed some of the partner country’s 
needs. Nevertheless, two out of the three programmes audited relating to the 
water sector and support to municipalities were not based on a credible strat-
egy for either of these sectors. While some plans and studies were available no 
detailed comprehensive plan was available showing the priorities and how these 
were to be tackled.

49 
Currently, Tunisia which benefits from state building contracts mainly because it 
lacks an overall national development plan incorporating the sectoral strategies, 
also benefits from funds of sectoral budget support programmes. This practice 
departs from the best practice as indicated in the guidelines of the Commission.

50 
There were problems with the design of the conditions. The main weaknesses are 
illustrated in Box 3:

(a)  the baselines of the conditions were not known at the time of the signature 

of the programme;

(b)  certain conditions were not appropriate;

(c)  certain eligibility criteria were not met at the time of the signature of the 

financing agreement.

Observations 

29

(a) 

3 Cases of weaknesses found in the design of sectoral budget support programmes
x
o
B

In BS6 (water), the programme defined some indicators and the relevant performance criteria, without 
having established the baselines for these indicators. For example, one payment condition of the variable 
tranche for 5 million euro was the increase of the number of volumetric counters of deep wells by 300 
in the first year, by 700 in the second year and by 1 200 in the third year. Nevertheless, at the time of the 
agreement, it was not clear to the Commission how many wells were or were not equipped with volumet-
ric counters and the extent of the problem addressed by the condition was therefore unknown. Another 
payment condition for the variable tranche of budget support, relating to the collection of fees by the 
state for the pumping of ground water, has not yet been met.

(b) 

(c) 

In the case of BS6, the programme set conditions that were easy to meet. For example, one payment 
condition of the variable tranche, for funds of 2.5 million euro, was the increase of the technical staff 
in a relevant department by 5 persons in the first year, by 10 the second year and by 25 the third year. 
However, the department reported an increase of the technical staff by 71 persons in the first year. In this 
case the payment condition was not based on an adequate analysis of the staffing requirements. The op-
posite situation also prevailed when other conditions were too difficult to meet, thus delaying the overall 
implementation of the programmes.

In the cases of BS5 and BS6, not all eligibility criteria were met at the time of the signature of the financ-
ing agreement. The financing agreement of the BS5 stipulated that only the second and third tranche 
were covered by the general conditions for payment (eligibility criteria). Thus eligibility criteria were not 
applied to the first tranche of 9 million euro, which was disbursed based on signature of the budget sup -
port contract only. As regards BS6, even though one of the eligibility conditions was only partially met, 
the financing agreement was still signed. According to the Budget Support Guidelines the use of sector 
budget support as a modality depends on the outcome of the assessment of the eligibility criteria.

51 
The Commission determined eligibility for payment under one programme (BS7) 
on the basis of its assessment that ‘satisfactory progress’ had been made overall 
on the matrix of payment conditions. This practice reduces the partner’s incen-
tive to implement all the individual measures (see paragraph 38). This also raises 
the question as to why certain conditions for payment were set if they were not 
going to be applied.

Delays in the programme implementation

52 
For two out of the three programmes audited there were substantial delays in 
the execution of the programmes. In one case (BS5) the implementation period 
has been extended by 70 % of the originally planned schedule (from 60 months 
to 102 months through four consecutive amendments) and in another case (BS6) 
by 33 % (an additional 24 months). Delays were due either to the programme’s 
environment (i.e. political instability, institutional resistance to change) or to 
weaknesses in the design (see paragraph 50).

 
Observations 

30

53 
Technical assistance projects were designed in parallel with the main sector 
budget support programme in order to assist the administration implement the 
reform programme agreed. Nevertheless, in two cases (BS5 and BS6) there were 
delays in contracting the technical assistance projects and for BS7 there was no 
technical assistance directly related to the implementation of the programme 
measures.

35  Namely, PJ 7, 8, 10, 11, 12, 13 

and 14.

54 
In several cases the impact of the programmes was substantially limited due to 
slow progress of the required reforms. For example, with regard to BS5 (decision 
of 2007), one intended important result of the programme was the reform of the 
annual budget. This reform was expected to advance considerably following the 
preparation of a law. However, its adoption by the Parliament is still pending and 
following the adoption of this law, five more years are needed in order to imple-
ment this reform fully.

Projects tackled relevant issues but there were design 
weaknesses and delays

Some design weaknesses made assessment of project 
performance difficult

55 
Half of the projects in our sample35 had one or more of the following weaknesses 
related to their design (see examples Box 4):

(a)  a lack of relevant, specific and measurable project objectives;

(b)  missing indicators which didn’t allow proper measurement of performance, 

monitoring of activities, and timely corrective actions;

(c)  a lack of baseline indicators which restricted the comparison of the situation 

before and after the action;

Observations 

31

4
x
o
B

Cases of design weaknesses in the projects reviewed

(a)  PJ12 was a technical assistance project aimed at reinforcing the institutional capacity of the Supreme 

Professional Institute of Lawyers. As a specific objective, the achievement of which would have to be as-
sessed at a later stage, this was a vague formulation. The contract specified indicators such as the number 
of violations of human rights and the average duration of the civil and penal suits. Yet, these indicators 
were only marginally and indirectly related to the project and were not the most appropriate benchmarks 
to assess the achievement of the project’s objective.

(b)  Project PJ14 was designed to support the democratic transition in Tunisia. It aimed at establishing good 
practices, strengthening the capacity of Members of the Parliament, and improving the Parliament’s ad-
ministrative capacity. Although, the contract provided a description of the principal activities, there were 
no indicators established to allow measurement of performance and assessment of the added value of 
the project.

(c)  The subject of PJ13 was the support for civil society in Tunisia. The objective and the indicators were 
vague and translated into a number of activities rather than specific indicators. Furthermore, as there 
were no indicators presenting the situation in the civil society, before and after the action, the assess-
ment of the added value of the project was hampered.

56 
In four projects36 out of the fourteen examined some key elements were not 
included in the contracts (see Box 5) and the level of detail in budgets was not 
adequate to properly assess the reasonableness of costs and therefore facilitate 
an assessment of efficiency.

36  Namely, PJ 6, 7, 8, and 10.

5
x
o
B

Example of project with insufficient stipulations in the contract

With regard to PJ10, the contract was signed on the basis of a very general description and preliminary estima-
tions of the works. Major works on the Court of Nabeul was one of the deliverables of the project. Initially, the 
procedures (preliminary study, design, technical study, execution dossier, specifications and tender dossier) 
covered the rehabilitation of the whole Court. Nevertheless, only one out of the three tender lots was ex-
ecuted by the beneficiary because the budget of the project was not enough to finance all the three lots. The 
remaining two lots (about 30 % of the overall budget) are supposed to be executed, at a later stage, by the 
Tunisian authorities. In this case, the absence of detailed description of the scope in the contract didn’t allow 
for a proper assessment of the efficiency and effectiveness of the project.

 
 
Observations 

57 
With regard to the two projects contracted with an intermediary37, the Commis-
sion committed to pay this intermediary about 1.2 million euro as administrative 
fees. The planning documents did not include an analysis of the added value of 
using an intermediary instead of contracting directly with the final beneficiary38.

Substantial delays in the execution of the projects

58 
The implementation period of the projects was substantially extended in ten of 
the fourteen projects in the sample (see Table 4). In six cases39 the implementa-
tion period was extended by more than 50 % of the agreed implementation 
period. Delays in implementation were to a large extent due to the fact that the 
time needed to achieve certain results had been initially underestimated. In most 
of the cases, time extensions result in the increase of certain costs categories, 
such as staff costs, which have to be funded from the Commission’s fixed contri-
bution40. Less funding will then be available to finance the core activities of the 
project. As these contracts were signed after 2011, the Commission was aware of 
the difficult circumstances in the country, still it did not adapt the time frame and 
the scale of the projects accordingly.

32

37  The projects PJ7 and PJ8, with 
a cumulative budget of 
41 million euro, aimed at 
reducing the social 
inequalities and regional 
disparities in urban and 
sub-urban areas through 
infrastructure works that 
improved the quality of life, 
creation of employment and 
access to micro-finance.

38  As the EIB has done in the 
context of the same action.

39  Namely, PJ 1, 2, 6, 8, 12 and 14.

40  European Court of Auditors, 

Special Report No 3/2011 ‘The 
efficiency and effectiveness of 
EU contribution channelled 
through UN organisations in 
conflict-affected countries’ 
(http://eca.europa.eu).

4
e
l
b
a
T

Extensions to project implementation periods

Project

Contract Year

Original duration

Duration

1st amendment

2nd amendment

Extension of the duration

(in months)

PJ1

PJ2

PJ3

PJ4

PJ5

PJ6

PJ7

PJ8

PJ9

PJ10

PJ11

PJ12

PJ13

PJ14

2011

2011

2012

2012

2015

2012

2012

2013

2013

2013

2011

2011

2013

2012

Source: CRIS database.

23

23

8

8

60

36

48

42

36

43

30

18

36

32

46

46

56

69

48

53

34

24.5

42

39

52.5

34.5

51

29.5

23

0

0

Original contracted period still ongoing

20

0

27

12

10

4

16.5

6

19

 
Observations 

33

59 
For three of the projects examined41 we found that the impact and sustainability 
of the results achieved to date were not safeguarded by a proper exit strategy. 
In those cases, the projects created mainly temporary jobs, but further funds 
and policy actions are necessary to ensure their continuation. As the Tunisian 
counterpart lacked enough funds and capacity to maintain the infrastructure 
delivered by the projects, sustainability will depend on the availability of further 
support from donors.

41  Namely, PJ 6, 7 and 8.

42  Namely, PJ 3, 4, 11 and 12.

60 
The impact of four projects42 was substantially impeded by the slow progress of 
the required reforms. For example, in 2012, about 2.5 million euro was spent to 
supply to Tunisian institutions special equipment to test conformity of electronic 
products with EU rules. Nevertheless, this equipment has been of limited use be-
cause Tunisia has not yet adopted the relevant EU standards as provided by the 
Agreement on Conformity Assessment and Acceptance of industrial products.

61 
Although two factors, namely project design weaknesses and slow project imple-
mentation, hampered the assessment of the projects, overall projects addressed 
real country needs and contributed to some important progress in relevant areas. 
For instance, the projects to support small and medium industries delivered use-
ful support to 700 businesses. Two other projects contributed significantly to the 
rehabilitation of poor urban districts and the project relating to the Parliament 
improved its infrastructure and reinforced its cooperation with the European 
Parliament.

Conclusions and 
recommendations

34

62 
EU funding made a significant contribution to the democratic transition and to 
the economic stability of Tunisia. We conclude that in the period following the 
revolution in 2011, the EU funds have been generally well spent. Extra funds were 
made available to cope with the new challenges and the Commission worked 
closely with other donors to organise the channelling of funds. However, a num-
ber of shortcomings were identified in the EU management of the assistance.

63 
While progress has been made this has been slow mainly due to a number of 
factors which included many changes of government and the lack of an overall 
national development plan. The lack of such a plan from the Tunisian authorities 
considerably complicated the process of properly targeting the Commission’s as-
sistance (see paragraph 23).

64 
In general, the Commission’s approach was very ambitious as it tried to address 
too many priorities. The wide range of issues tackled and activities undertaken 
through Budget Support, projects and the MFA loan, conflicts with the Commis-
sion’s own policy of concentrating its assistance on a small number of key areas 
and activities (see paragraphs 24 to 25).

65 
Coordination with other donors was good across a wide spectrum of activities 
although joint programming with Member States was not achieved (see para-
graphs 26 to 28).

Recommendation 1 - Strengthen the programming and focus 
of the EU assistance

The EEAS and the Commission should:

(a)  use political and policy dialogue to ensure that the Tunisian authorities adopt 

a comprehensive national development plan.

(b)  for the next planning period, develop a limited number of specific priorities 

and reduce the number of actions in order to increase the focus and potential 
impact of the EU assistance.

(c)  make sure that joint programming with Member States is achieved, in order 

to improve the focus and coordination of the aid.

Conclusions and recommendations 

35

66 
Aid was given through a number of aid modalities, comprising mainly of General 
Budget Support (State Building Contracts), Sector Budget Support (Sector Reform 
Contracts), an MFA loan and projects. Tunisia also benefitted significantly from 
the ‘more for more’ initiative which significantly increased the funds available for 
General Budget Support (see paragraphs 30 to 31).

67 
The General Budget Support was provided through the PAR programmes, which 
were also substantially funded by World Bank and IMF loans, in the early years. 
This form of support helped the government shape the reform agenda and, un-
der the classification of State Building Contracts, allowed for more flexibility than 
traditional budget support. However, it is designed to be a short term approach, 
lasting one to two years, rather than a long term solution (see paragraphs 32 to 
33).

68 
When the financing agreements of budget support programmes were signed 
some of the conditions therein had already been met, or were met shortly after-
wards. This considerably reduced the incentive element of the support. The im-
plementation of the many measures, required by the financing agreements, was 
assessed as a whole, with the result that payments were made even when some 
of the relevant measures were not carried out (see paragraphs 34 to 39).

69 
The allocation of ‘more for more’ funds was decided at a very late stage which 
created difficulties for planning the best use of this assistance. Regarding the 
additional impact intended to be achieved from the substantial transfers of ‘more 
for more’ funds, this was not clearly apparent (see paragraph 36).

70 
The PEFA provides an internationally recognised, comprehensive assessment of 
a country’s public financial management. This should be carried out every four 
years according to the Commission’s own Budget Support Guidelines. Given the 
large amounts paid in the form of budget support and the importance of PEFA as 
a monitoring and planning tool it is unsatisfactory that no PEFA has been carried 
out since 2010. The new PEFA assessment is expected to be finalised in March 
2017 (see paragraphs 40 to 42).

Conclusions and recommendations 

36

Recommendation 2 - Strengthen the implementation of EU 
budget support programmes

The Commission should:

(a)  for future budget support programmes, reduce the number of measures 

required to meet the conditions attached to Budget Support and ensure that 
these measures are significant. In order to incentivise the Tunisian authori-
ties to make significant progress with their reforms, the Commission should 
make disbursements conditional on the satisfactory attainment of individual 
measures and performance indicators, rather than on overall progress.

(b)  strive to ensure that a PEFA, in view of its significance as a planning and 

monitoring tool, is carried out every four years as a minimum.

71 
The MFA loan of 300 million euro, which was urgently required by the Tunisian 
authorities, took nearly two years to organise. While some of the delay was not 
at EU level, it still took over 11 months to process at EU institutional level (see 
paragraphs 45 to 47).

Recommendation 3 – Make proposals to speed up the MFA 
approval process

The Commission should explore with its co-legislators the available options to 
accelerate the approval procedures of subsequent MFA programmes, particularly 
for emergency funding.

72 
Sector Budget Support was paid out on a much smaller scale than general 
budget support. A credible sector strategy was not evident for two of the three 
programmes examined. The impact of the programmes was hampered by delays 
and general slow progress in the implementation of the required reforms (see 
paragraphs 48 to54).

Conclusions and recommendations 

37

73 
Some significant projects were carried out but with many delays. In the absence 
of clear objectives and indicators, progress on many of these was difficult to 
assess. In many cases the projects were over ambitious and their timetable over 
optimistic. This led to an increase in overhead costs (see paragraphs 55 to 61).

Recommendation 4 – Improve the planning of projects

The Commission should, when planning future projects in Tunisia, establish clear 
objectives and indicators which are realistic in the particular circumstances of the 
project concerned.

This Report was adopted by Chamber III, headed by Mr Karel PINXTEN, Member 
of the Court of Auditors, in Luxembourg at its meeting of 14 February 2017.

For the Court of Auditors

Klaus-Heiner LEHNE
President

 
 
 
Annexes

38

I
x
e
n
n
A

List of Budget Support Programmes and Macro-Financial Assistance

Number

Decision No

MFA

NA

Decision 
year

2013

Modality

Title

MFA

MFA

BS1

23143 and 23279

2011

BS2

BS3

BS4

BS5

BS6

BS7

24074

24469

37533

19508

2012

2013

2014

2007

21889

2010

18438

(2013)

BSP

BSP

BSP

BSP

BSP

BSP

BSP

Programme d'Appui à la Relance and 
Support for Partnership Reform and 
Inclusive Growth — SPRING (PAR1)

Programme d’Appui à la Relance  
(PAR 2) 

Troisième Programme d'Appui à la 
Relance (PAR 3)

Progamme d'Appui à la Relance  
(PAR 4)

Programme d’Appui à la Gestion 
Budgétaire par Objectifs

Programme d'appui aux politiques 
publiques de gestion des ressources 
en eau pour le développement rural 
et agricole

Tunisie — PRAL — ex-Programme 
d'appui à la compétivité (PAC I)

 (euro)

Allocated 
amount

Contracted 
amount

Paid amount

300 000 000 

300 000 000

200 000 000

100 000 000 

99 424 813

99 424 813

68 000 000 

67 339 484 

65 415 314

110 000 000 

110 000 000

110 000 000 

100 000 000 

99 546 000

75 000 000 

30 000 000

29 267 989

29 267 989

57 000 000

56 067 853 

 24 623 541

41 000 000

40 357 374

 40 357 374

 
39

(euro)

Contracted 
amount

Paid amount 

4 328 400

4 092 200

6 170 540

5 575 780

1 179 590

1 179 590

1 260 000

1 260 000

10 000 000

1 982 210

Annexes 

List of projects

I
I
x
e
n
n
A

Number

Decision No

Contract Year

Project

PJ1

PJ2

PJ3

PJ4

PJ5

PJ6

PJ7

PJ8

PJ9

PJ10

PJ11

PJ12

PJ13

PJ14

20216

20216

20216

20216

22772

23202

23202

24409

23556

23557

19073

19073

23558

23569

2011

2011

2012

2012

2015

2012

2012

2013

2013

2013

2011

2011

2013

2012

Mobilisation d’expertise court terme au profit des PME indus-
trielles et des institutions tunisennes — Coaching technique 
et non technique

Mobilisation d’expertise court terme au profit des PME Indus-
trielles et des institutions d’appui — Qualité

Acquisition et installation d’une chambre semi anechoîque 
pour essais de comptabilité electromagnétiques de dix metres 
avec cages annexes

Acquisition et mise en place d’un laboratoire pour des essais 
de compatibilité Electromagnétiques

Programme on Small Business Support in the services sector 
of Tunisia

Projet de création d’emplois et accompagnement à la réinser-
tion en complétant les dispositifs de l’Etat en Tunisie

6 476 777

5 850 000

Financement de la mise à niveau de quartiers populaires

8 000 000

7 900 000

Financement de la mise à niveau de quartiers populaires en 
Tunisie

Soutien à l’amélioration du système de justice des enfants en 
Tunisie

Réhabilitation selon les standards internationaux de Tribu-
naux et établissements pénitentiaires avec une dotation de 
matériel informatique

32 900 000

22 000 000

1 800 000

1 710 000

12 848 749

12 206 312

Renforcement des capacités institutionnelles en Tunise

1 461 000

1 314 652

Assistance Technique pour le renforcement des capacités insti-
tutionelles de l’Institut Supérieur de la Profession d'Avocats

629 965

503 972

Programe d’Appui à la Société Civile en Tunisie

3 399 228

2 604 875

Appui au processus constitutionnel et parlementaire en 
Tunisie

1 809 778

1 364 907

 
Reply of the Commission  
and the EEAS

40

Executive summary

III
The Commission and the EEAS agree with the assessment of the quick response, but would like to stress that several 
areas had to be tackled because of the large number of socioeconomic needs/emergencies the Tunisian govern-
ment was confronted with following the revolution. In this context, the EU was called on to assist Tunisia to respond 
to these needs which were a matter of political credibility as much as an operational necessity. Results obtained in 
the course of the period are good since the EU assistance contributed significantly to the country’s economic and 
political stability after the revolution, notably by accompanying major socioeconomic and political reforms.

The Commission considers that assistance was therefore not diluted, but rather responded to the vast number of 
emergency reforms which Tunisia inevitably faced in the post-revolutionary period.

Moreover, it must be highlighted that all projects adopted since 2014 related to one of the three focal sectors 
enshrined in the single support framework (SSF) 2014-16 (socioeconomic reforms for inclusive growth, fundamental 
elements of democracy and sustainable regional and local development).

The Commission acknowledges that the Tunisian authorities may have encountered difficulties in managing all the 
assistance, due to the post-revolution context and frequent changes of governments and within the administration. 
However, it must also be emphasised that the absorption rate forEU projects is higher than that of other donors.

The joint programming process has been put on hold due to delays on the part of Government in formulating and 
adopting a new 5-year development plan. This will allow the EU to better align the programming exercise to the 
priorities included in the plan so as to enhance division of labour among donors, including Member States.

A joint programming mission took place in parallel to the EEAS/DG Neighbourhood and Enlargement Negotiations 
programming mission held on October 2016. A consultant is currently coordinating with all Member States and the 
joint programming exercise will likely be operational in 2017.

The EU’s macro-financial assistance (MFA) provides balance-of-payments support to face Tunisia’s acute external 
financing needs and in support of the financial assistance programme it has agreed with the IMF. This allows Tunisia 
to make the necessary economic adjustment less harsh and abrupt, and aims to contribute to restoring its economic 
sustainability. The MFA conditionality therefore addresses a number of priorities in several interlinked areas of struc-
tural reform, as a comprehensive approach to support an economic adjustment programme.

The Commission considers that its assistance to Tunisia, including its MFA, has been concentrated on a limited num-
ber of sectors. In addition, in several support areas (such as statistics, public finance management and good govern-
ance of the Court of Auditors) strong coordination with other donors and within different Commission services was 
crucial to add the MFA’s added leverage for important reforms to be fully implemented.

Reply of the Commission and the EEAS 

41

V
In a context characterised by political instability it was essential to strike the right balance between quick impact 
measures and longer-term processes while using the tools offered by the Commission’s Budget support policy. The 
instrument of a state building contract is a more flexible budget support modality specifically designed for fragile/
post-crisis situations. While resorting to this more flexible modality in Tunisia, the Commission nevertheless strictly 
assessed the disbursement conditions for each of the four budget support programmes. Furthermore, the stabili-
sation of the situation and Tunisia’s progress evidences the success of the operations as they were conceived and 
implemented. A more detailed analysis of this point is provided below, from paragraph 30 onwards.

The Commission confirms that the current ongoing PEFA assessment was in fact launched in 2014, thus 4 years after 
the last PEFA assessment. The current PEFA assessment encountered delays outside the control of the Commission, 
mainly due to methodological questions and their consequences. It should be highlighted that a new methodology 
for the PEFA exercise was reviewed in 2015. The new PEFA report for Tunisia is being finalised.

VI
The Commission underlines that a reform programme may not always be encapsulated within a single, comprehen-
sive and coherent policy or strategy document. In such cases, the analysis is based on the different measures and on 
the reform process followed by the government to strengthen the system.

In the case of the sector budget support mentioned above, the Commission assessed the sector policies as com-
plete, as well as relevant and credible. These sector budget support operations had been adopted before the revo-
lution; later the programmes were adapted to the new situation to stabilise the results supported by the operations.

The Commission considers that late disbursements of MFA loans were not caused by slow implementation of the 
assistance, but were due to a combination of a number of factors. It took the Parliament and the Council more than 
5 months to adopt the Commission proposal under the ordinary legislative procedure. Furthermore, the Tunisian 
authorities took more than 6 months to ratify the EU–Tunisia memorandum of understanding containing the MFA 
conditionality. The second disbursement was delayed due to the fact that Tunisia had not fulfilled all the conditions 
on time.

Introduction

09
The Commission considers that it is worth mentioning that when the MFA-I operation of EUR 300 million was 
adopted, in April 2014, it constituted the largest MFA ever provided to a country in the southern Neighbourhood, 
until a new MFA operation, also for Tunisia, of EUR 500 million was proposed by the Commission in February 2016, 
and adopted in July 2016. This second MFA aims to further support the economic transition, particularly in the wake 
of the 2015 terrorist attacks and their negative impact on economic activity.

Reply of the Commission and the EEAS 

42

Observations

20
The Commission underlines that PAR 1 was a multisectoral budget operation and PAR 2 to PAR 5 are state building 
contract operations.

22
The Commission points out that it has always acted in a timely manner whenever action was required on its side, 
amid a difficult political and security context. The Commission also notes that the action document of the SSR 
programme was finalised at technical level on 18 June 2015 (quality support group meeting), before the June 2015 
terrorist attack. Several other actions in the field of security were also put in place during this period (regional 
projects, projects funded under the Instrument for Stability and the Instrument contributing to Stability and Peace, 
etc.) before or in parallel to the preparation of the SSR programme.

23
The Commission notes that in the first years after the revolution coordination among donors took place on basis of 
an economic recovery plan of the Tunisian authorities and of the governmental development letters. These docu-
ments led to several packages of donor financial support under the so-called Programmes d’Appui à la Relance 
(PAR), some of which even used a joint policy matrix. Subsequently, coordination among donors, including the EU 
through its budget support and MFA operations, was facilitated by the agreement between the IMF and the Tuni-
sian authorities on a comprehensive programme of macroeconomic adjustment and structural reforms.

24
The Commission would like to stress that funds were not spread over too many areas and aid was sufficiently 
focused.

While EU aid indeed touched on a wide number of sectors, it did so, initially, in recognition of the vast challenges 
and needs Tunisia was facing in the post-revolutionary period. It also did so in response to specific demands for 
assistance by the Tunisian authorities at a time when the government badly needed international support. Indeed, 
between 2011 and 2013 ‘emergency operations’ were adopted targeting essential services, supporting the demo-
cratic transition and accompanying the process of socioeconomic reforms.

However, once the situation appeared to progressively stabilise (roughly from 2014 onwards), the EU did strive to 
concentrate its assistance. This effort materialised in the single support framework for 2014-2016, which identified 
three sectors of intervention (socioeconomic reforms for inclusive growth, fundamental elements of democracy 
and sustainable regional and local development) in an effort to channel our assistance. These three sectors were 
systematically taken into account when designing annual action programmes in favour of Tunisia.

Reply of the Commission and the EEAS 

43

25
The Commission and the EEAS stress that their decisions did not lead to the dilution of funding and to difficulties of 
management. Delays and management difficulties were directly and primarily linked to external factors (i.e. political 
instability, difficult country economic situation).

The Commission underlines that MFA conditionality addresses a limited number of priorities in several interlinked 
areas of structural reform, as a comprehensive approach to support an economic adjustment programme. This 
should not be seen as a departure from the Commission’s policy of concentrating its assistance on a limited number 
of sectors. In addition, in several support areas (such as statistics, public finance management and good govern-
ance of the Court of Auditors) strong coordination with other donors and within different Commission services was 
crucial for important reforms to be fully implemented.

26
The Commission notes that EU actions were well coordinated with Member States and the main international 
donors, but joint programming with the Member States was not achieved due to the late adoption of the national 
development plan. Coordination and close communication with Member States took place on a regular basis and 
was constructive.

28
The joint programming process has been put on hold in order to align the programming exercise to the 5-year 
development plan so as to enhance the division of labour among donors, including Member States.

A joint programming mission took place in parallel to the EEAS/DG Neighbourhood and Enlargement Negotiations 
programming mission held in October 2016. A consultant is currently coordinating with all Member States and the 
joint programming exercise will probably be operational in 2017.

29
The Commission notes that EU actions substantially assisted Tunisia but some minor shortcomings were found in 
the Commission’s implementation of programmes.

The Commission would like to reiterate that the PAR1 programme was a multisectoral budget operation and PAR 2 
to PAR 5 are state building contract operations. The difference in modality has consequences for the analysis of the 
programmes.

Reply of the Commission and the EEAS 

44

32
The Commission would like to stress that even though PAR3 and PAR4 were financed only by the EU, these pro-
grammes, and the measures defined therein, were coordinated with other donors.

33
The Commission would like to highlight the fact that the Programme d’appui à la relance 1 (PAR 1) was a multi- 
sector budget support and that subsequent PAR operations used the state building contract modality, which has 
been specifically designed to allow the EU to support partner countries in fragile/post-crisis situations.

While the state building contract modality used allows for some flexibility as outlined in the policy adopted in 2011, 
its implementation by Commission services has always been rigorous. Performance indicators used were defined 
following a lengthy and comprehensive policy dialogue process with the authorities. These indicators have allowed 
important reform processes to be brought forward in the course of the period under review. The urgency of the 
situation the EU had to respond to and the short-term nature of the modality chosen to implement the state build-
ing contracts should not be associated with an impression of ‘flexibility’ of the disbursement conditions.

The Commission underlines that it is possible and foreseen by the relevant Budget Support Guidelines to renew 
state building contracts, particularly when the transition to other budget support instruments is not yet feasible.

It is worth keeping in mind that the Budget Support Guidelines relating to state building contracts were new (2012) 
and the modality untested when they were first applied in a middle income country going through a huge politi-
cal transition such as Tunisia. This Tunisian experience, confirmed also by the implementation of state building 
contracts in other countries, has led the Commission to a revision of the guidance concerning the duration of state 
building contracts and the possibility of adopting state building contracts in parallel to sector budget support 
operations. A revision of the budget support guidelines will document this lesson learnt.

34
The Commission states that, in a limited number of cases, indicators/measures were met before the signing of 
financing agreements. But this rather reflects the fact that Commission’s lengthy administrative process leading 
to the adoption of financing decisions is not fitted for the sort of emergency operation the Commission and other 
donors (World Bank and African Development Bank) strived to put in place in Tunisia at the time to respond to 
a particularly unstable political and socioeconomic situation.

Indeed, those measures had been formally approved with the authorities many months before the signing of the 
financing agreement. However, between the time the measure was agreed and the time the financing decision was 
adopted by the Commission, the measure had indeed been adopted/implemented by the government. This success 
was also the result of an intense policy dialogue with the authorities and hence would not have taken place to the 
same extent or within the same timeframe in the absence of the budget support operations.

35
The financing decision presented to the Member States and the financing agreement signed with the Government 
of Tunisia clearly stated that the performance indicators for the second tranche would be identified during the sec-
ond year of the programme. Such an arrangement is not in contradiction with the guidelines and is useful in volatile 
situations where a fully fledged programming over several years is difficult to formulate, such as in Tunisia in 2011 
(i.e. with a caretaker government, impending elections).

Reply of the Commission and the EEAS 

45

36
The Commission draws attention to the fact that, while ‘more for more funds’ were not formally announced before 
May or June of year N+1, the Commission and the EEAS had already carried out an assessment of the situation in the 
various countries in the region and had a clear sense — quite early in the year (generally by January/February) — of 
the ‘more for more’ amount each country would be receiving. Therefore, when negotiating programmes and the 
matrix of indicators, the Commission’s team kept some room for manoeuvre and factored in either additional pro-
grammes or in some cases a higher amount than the one officially available at the beginning of the negotiations.

37
The Commission emphasises that EU assistance was based upon the demands of the Tunisian authorities and needs 
were bilaterally discussed, agreed and assessed. The large number of measures included in PAR 1-3 needs to be 
viewed from the perspective of joint budget support operations, implemented by three budget support agencies, 
against financial commitments in excess of a billion dollars per operation.

Thus, taking into account the presence of several donor agencies (contributing with state-of-the-art expertise) and 
the important amount of these operations, the number of measures is actually close to the standard for such types 
of operations.

The PAR programmes benefited from high-level attention with regular Cabinet meetings dedicated to reviewing 
their implementation (this would not occur for a smaller programme) and it should be duly noted that the vast 
majority of these measures were met.

38
The Commission is of the view that the assessment of each of the PAR I-IV matrix conditions was done with equal 
rigour.

The Commission underlines that in application of the 2011 communication and the related 2012 Council conclusions 
on ‘The future approach to EU budget support to third countries’, a dynamic approach will continue to be applied to 
eligibility criteria. This approach was particularly adapted in view of the unstable political situation that was prevail-
ing at the time and the use — for the first time in Tunisia — of a state building contract.

This approach is in line with the provisions of the Budget Support Guidelines on state building contract operations. 
This modality has been included in the 2012 budget support guidelines to be used during crisis, post-crisis and 
fragile situations. It is therefore a more flexible modality. Nevertheless the assessment of disbursement files by the 
Commission is as thorough as any other budget support modality.

It should be added that all but a few (fairly marginal) anticipated results were eventually achieved. Thus, the flexibil-
ity granted for PAR III and IV does not appear to have led to inferior results/impact in the medium term.

39
The Commission notes that implementation of some structural economic reforms continues to be slow or needs 
strong improvement whereas reforms accompanying the democratic transition have been more satisfactory. The 
adoption of results-oriented measures or indicators would not have been possible in the context of state building 
contracts of 1 to 2 years as is recalled in the Budget Support Guidelines, which foresee that ‘performance indicators 
… will mainly be process indicators’ (p. 99).

Reply of the Commission and the EEAS 

46

Complementary interventions in the form of technical assistance were ensured and thus supported the author ities 
in the drafting and adopting of legislation/regulations (or administrative procedures) necessary to operationalise 
a given law or decree. Thanks to the policy mix, most of the measures identified by the EU led to concrete results.

Just like in other post-revolutionary processes, profound political and institutional changes currently taking place in 
Tunisia will take time to produce their full results.

40
The Commission would like to stress that a rapidly evolving situation with an overburdened and ever-changing 
administrative and political situation (six Governments between 2011 and 2015) would have made the task of imple -
menting a high-quality and objective evaluation particularly difficult to undertake during this period. In terms of 
evaluation methodology it would also have been too early to assess impacts.

The latest fully fledged evaluation of budget support operations took place in 2010. These evaluations are usually 
conducted over a 10-year span. It is necessary to take a step back in order to objectively assess the situation.

This said, an evaluation is being conducted by DG Neighbourhood and Enlargement Negotiations on programmes 
focusing on economic governance, which includes all the budget support programmes implemented in Tunisia 
except BS6.

Furthermore, the Commission monitored carefully outputs, outcomes and results during this period and made full 
use of instruments to assess the results of specific budget support measures, and also made use of various evalua-
tions carried out by different international organisations.

41
The Commission would like to underline that the new PEFA assessment has been carried out following the newly 
adopted methodology by the PEFA Secretariat, which has resulted in several contradictory conclusions as regards 
2010 PEFA assessment and delays in its approval by Tunisian authorities — delays which are outside the control of 
the Commission, the World Bank or the African Development Bank.

Nevertheless, the Commission confirms that the current ongoing PEFA assessment was in fact launched in 2014, 
thus 4 years after the last PEFA assessment was carried out and therefore in respect of internal budget support 
guidelines.

In addition to the PEFA, as a prior step to the decision to provide MFA support, the Commission carried out, in 
December 2013, a full and comprehensive operational assessment of the administrative and financial circuits of the 
Ministry of Finance and the Central Bank of Tunisia.

42
The Commission would like to stress that PEFA is a useful tool but it is not a mandatory obligation and furthermore 
requires the commitment and full cooperation of the country.

After 2011, Tunisia (and its partners) have benefited from a dozen high-quality assessments of the country’s public 
finance management system during the period under review, despite the absence of a recent PEFA. These assess-
ments were conducted in the framework of Commission programmes and by independent organisations such as 
the IMF, the Organisation for Economic Cooperation and Development (OECD) and the Open Budget Survey.

Reply of the Commission and the EEAS 

47

These various assessments generated in-depth information on the different PFM dimensions (budget formula-
tion, budget execution, accounting, procurement, internal and external controls, asset management, transparency, 
reform agenda, etc.).

Despite the PEFA being launched with some delays in 2014, its results are expected in early 2017 and will be used to 
assess PFM progress in the country.

43
The Commission would like to emphasise that in the circumstances Tunisia has been facing since 2011, with the 
important challenges the country had to respond to (political, economic, social, security related), Tunisia remains 
a model in the region. The transition process is a long and difficult one which will still require further important 
efforts from this partner.

(a)
The Commission is of the view that while challenges remain in some areas, the progress compared with the situa-
tion prevailing in 2011 has been unambiguously positive and sustained. The website for open budget of the Ministry 
of Finance is a good example of the huge efforts made in this regard (http://www.mizaniatouna.gov.tn).

Independent surveys of budget transparency or statistics dissemination (international budget survey for 2011 and 
2015, a statistics dissemination website) now rank Tunisia as a leader in its income/regional country groupings.

The recent promulgation of an organic law on freedom of information, coupled with a vibrant civil society eager to 
already take advantage of these new rights, points to further progress in the years to come.

(b)
The EU’s civil society support programme (PASC) contributed to resolving problems related to the establishment 
of 180 NGOs in the governorate of Tozeur. The programme entered into an agreement with the Tunisian govern-
ment’s services responsible for organisations to help applicant civil society organisations prepare their registration 
applications. In addition, the programme includes a technical assistance component to help the Tunisian authorities 
establish an IT-based system for the NGO department that could speed up the handling of files, including for the 
registration of NGOs.

(c)
While the implementation of reforms regarding public–private partnerships and public procurement has met fierce 
resistance from some quarters of the administration, all the related implementing regulations have been adopted 
and the effective implementation of the laws is starting in earnest. Early positive results are already starting to be 
registered, especially regarding public procurement, with the ongoing digitalisation of all procurement procedures.

With respect to external audit, the forthcoming adoption of an organic law granting full independence to the Court 
of Auditors (a PAR IV measure) is anticipated to mark a watershed in the conduct of external auditing in Tunisia. 
The Commission will continue to provide technical assistance to the Court to ensure that it fully seizes these new 
opportunities.

Regarding internal audit, some work remains to be done to rationalise the institutional framework. This is planned 
in the PAR V programme.

Reply of the Commission and the EEAS 

48

(d)
The measures included in the PAR programmes were aimed at stabilising municipal finances, which were facing 
an unsustainable financing burden due to a sharp fall in local revenues after the revolution. They were followed 
with the ‘Cap vers la décentralisation et le développement des territoires’ programme (EUR 43 million) by a more 
structural approach in the context of decentralisation. But the latter could not have been implemented without the 
success of the former and prior to the political decision to embark on a decentralisation process.

(e)
Progress in terms of targeting beneficiaries has indeed been disappointing in spite of the EU, the IMF and the World 
Bank insistently calling on the authorities to act on it. This reflects deep-seated political difficulties in strengthening 
eligibility criteria for such programmes. Despite these setbacks, it is important to keep insisting on these reforms 
given their critical contribution to public finance sustainability. This continues to be done jointly by the IMF, the 
World Bank and the EU (MFA). However, it is expected that the new Social Identification Number database and the 
evaluation of the current social assistance programmes as well as the proposed scoring system will improve the 
targeting of these programmes.

(f)
The Commission considers that thanks to the disbursement conditions set in PAR-III budget support and donors’ 
coordinated policy dialogue with Ministry of Finance a regulatory framework that is conducive to the development 
of microfinance is now in place in Tunisia. The latter has permitted the creation of seven microfinance institutions 
serving less developed unserved regions, including two (Microcred and Taysir) financially supported by the EU, AFD, 
EIB and EBRD. According to the latest annual reports of Microcred and Taysir, 7 684 microentrepreneurs have been 
served with financial and technical assistance services since operations started in 2015, of whom 4 205 are women 
and 3 338 are youth.

(g)
A new Investment law was adopted by parliament in September 2016 in the context of the preparation for the Tuni-
sia 2020 Conference. This law, alongside recently adopted legislation on competition, bankruptcy and PPP, should 
make for a much-improved investment climate moving forward.

45
The Commission considers that it is important to note that before the first MFA disbursement can take place mul-
tiple procedural steps have to be taken. Before proposing an MFA operation, the Commission assesses the sound-
ness of the financial circuits in the beneficiary country through an operational assessment which takes at least 
a month. As Commission proposals for MFA are subject to the ordinary legislative procedure according to Article 
212 tfeu, they have to be adopted by the parliament and the council. After this adoption, a memorandum of under-
standing (MoU) containing MFA conditionality has to be approved by a Member State committee and signed by the 
beneficiary country. In addition, Tunisia had to ratify the MoU.

Subsequently, the funds for the disbursement have to be borrowed by the Commission on the markets, which nor-
mally takes about a month. For Tunisia, it has to be mentioned that 1 month was lost within the ordinary legislative 
procedure due to the fact that the approval by the Parliament plenary was shifted in the last moment to the April II 
plenary, which means that the Commission proposal took 5 months to be approved by the co-legislators. Further-
more, it has to be noted that the signature and ratification of the MoU by Tunisia had already taken more than 
7 months.

Reply of the Commission and the EEAS 

49

47
The Commission considers that the MFA programme has been key to push forward much-needed reforms in Tunisia, 
in close coordination with other international donors and the government’s own reform plans, particularly in a dif-
ficult transition environment. The new MFA programme brings the total MFA support to Tunisia to date to EUR 800 
million and ensures the continuity of reforms while tackling a new set of measures that aim to support Tunisia’s 
efforts to move towards a more sustainable economic model.

48
The Commission considers that eligibility criteria, including the implementation of a relevant and credible policy, 
have been met at the moment of the approval of each programme as well as before each payment.

In the cases mentioned of BS5 and BS6 the Commission notes that, as indicated by the Budget Support Guidelines, 
‘A reform programme may not always be encapsulated into a single, comprehensive and coherent policy or strategy 
document. In such cases, the analysis will be based on the different measures and reform process followed by the 
government to strengthen the system.’ In application of the guidance that the Commission assessed the sector poli-
cies as complete, as well as relevant and credible.

49
The Commission would like to clarify that the three sector budget support programmes were adopted before the 
revolution, following eligibility criteria in place at that moment, whereas the state building contracts were adopted 
after the revolution to give a response to a completely new context that demanded a new approach and made 
Tu nisia eligible for such an instrument. It should also be noted that the Commission is currently revising the budget 
support guidelines to allow for the adoption of state building contracts and sector budget support at the same 
time.

50

(a)
See reply to Box 3(a)

(b)
See reply to Box 3(b)

Box 3 — Cases of weaknesses found in the design of sectoral budget support 
programmes

(a)
The Commission partially agrees. At the time of project design, it proved difficult to measure the baselines for all 
indicators. Therefore, to address this situation, targets for certain indicators were expressed as absolute units of 
progress, rather than relative to baseline values.

With regards to the target on volumetric counters, it is worth noting that it represented a 10 % increase on the 
value of drillings with legal concessions, which was considered as significant. The over-achievement is due to the 
inclusion of volumetric counters for drillings for which a legal concession is not necessary (surface water or at low 
depths). For indicator D, there were major changes in the government recruitment policy after 2011 which could 
not be anticipated when the programme was designed. After two decades of conservative recruitment policy in the 
water sector, increased human resources could be assessed as a positive development.

Reply of the Commission and the EEAS 

50

When the programme was signed, in 2011, it was difficult to anticipate that the new government in place from 
2012 would not prioritise the collection of fees on groundwater pumping, which was an objective for the previous 
govern ment. This failure might be ascribed more to a change in political will than to the suspension of function by 
one unit.

(b)
The Commission points out concerning BS6 that for indicator D, there were major changes in the government 
recruitment policy after 2011 which could not be anticipated when the programme was designed. After two dec-
ades of conservative recruitment policy in the water sector, increased human resources could be assessed as a very 
positive development.

(c)
In the case of BS6 the Commission underlines that, as indicated by the Budget Support Guidelines, ‘A reform pro-
gramme may not always be encapsulated into a single, comprehensive and coherent policy or strategy document. 
In such cases, the analysis will be based on the different measures and reform process followed by the government 
to strengthen the system.’ It is in application of this guidance that the Commission assessed the sector policies as 
complete, relevant and credible.

In the case of BS5 the Commission would like to highlight that this financing agreement was signed in 2008 under 
different conditions and practices. Nevertheless, for subsequent programmes and disbursements the Commission 
has thoroughly applied the Budget Support Guidelines.

51
The Commission stresses the fact that the matrix mentioned was developed by the Government as a summary 
description of the measures it intended to implement to restore the financial strength of Tunisian municipalities.

As part of the assessment of government strategy, the matrix provided the best available description of its detailed 
plan of actions.

As such, there was no a priori judgement that some measures were not going to be met but that as in all strategies, 
some measures may be more important than others (at least from the standpoint of the Commission). However, the 
assessment of the eligibility condition on public policy involves an evaluation of the overall Government plan of 
action, not only those actions deemed critical to the Commission.

The Commission further notes that in addition to the overall matrix of measures mentioned, the main three objec-
tives of the programme – dramatically raise revenue, freeze the main driver of increased spending (recruitments) 
and increase the execution of local development investment projects – were captured by the performance indica-
tors in the programme’s second tranche.

With hindsight the rate of completion of these measures was particular high which suggests that the conditions 
were both relevant and feasible.

Reply of the Commission and the EEAS 

51

52
The Commission agrees but stresses that conditions were numerous (BS5) and particularly difficult for both pro-
grammes. For BS6, the programme’s duration was extended from 72 to 96 months to respond to the difficulties 
faced by the new government, and in particular the Ministry of Agriculture, after the political events of 2011. The 
main objective of this extension was to ensure that the complementary measures for the smooth implementation of 
the programme could be put in place.

The pace of programme implementation was heavily dependent on exogenous factors related to the post-Revolu-
tion context.

53
The Commission agrees and notes that delays in contracting the technical assistance components of project BS5 
and BS6 were duly justified by the complexity of the sectors supported and the need to engage into in-depth stra-
tegic and policy discussion in order to identify well the beneficiaries’ needs based on proper assessments.

The Commission would like to clarify that though there was no technical assistance under BS7, technical assistance 
was provided in the framework of other ongoing programmes. The eligible contracting period according to finan-
cial regulations was elapsed by the time the programme content was reviewed, which prevented the contracting of 
additional technical assistance.

54
The Commission agrees and recognises that the legislative process has been rather slow since the revolution as 
Constitutional and other (e.g., security, corruption) priorities have taken precedent to matters such as budgetary 
legislation. The adoption of the law is anticipated during the first quarter of 2017.

It should be stressed, however, that significant progress has been registered in terms of budget procedures even 
before the passing of the law. As of today, 22 out of 26 ministries have adopted programme-budgets and include 
performance indicators related to their public policy objectives (in addition to budget data) in their budget submis-
sions to Parliament.

The increase in the score given by the International Budget Survey underscores the improvements made in these 
areas.

In this context, the promulgation of the Budget law will mark the completion rather than the launch of this perfor-
mance-based reform.

55
The Commission notes that half of the projects had no design weaknesses. On the other half, the Commission would 
like to make the following comments (see below):

(a)
The Commission would like to underline that objectives related to concerned projects were relevant, specific and 
measurable enough.

As regards PJ7 and PJ8, the Commission considers that ‘l’amélioration des conditions de vie des populations défavori-
sées ou fragilisées socialement, par la réalisation d’infrastructures de base et d’équipements de proximité dans les zones 
urbaines defavorisées’ is a sufficiently relevant and specific objective that can be measured by the number of basic 
infrastructures and equipment provided to informal areas in the framework of the programme.

Reply of the Commission and the EEAS 

52

As regards PJ11, the Commission considers that the twinning programme objective in favour of the Tunisian Court of 
Auditors ‘diagnostic et préparation de la réforme institutionnelle’ combined with detailed expected results and objec-
tively verifiable indicators is specific and measurable.

Furthermore, the four objectives of PJ14 are considered by the Commission as highly relevant and specific in order 
to support the establishment of a modern, capable and well-functioning Parliament during the democratic transi-
tion period. Such objectives, linked with the expected results are sufficiently measurable.

(c)
The observation of the Court refers to a specific case (PJ13)for which explanations are detailed under point c) below.

Box 4 – Cases of design weaknesses in the projects reviewed

(a)
The Court refers to indicators set to measure the general objectives of the project. During the project implementa-
tion phase, indicators were slightly revised to better reflect the achievement of results.

(b)
The Commission would like to point out that the standard contribution agreement template does not request 
a logical framework. A result and resources framework, which is the equivalent of a logical framework, is annexed 
to the contract. The Commission therefore considers that there were indicators according to the appropriate format 
for projects under delegated management.

(c)
The Commission stresses that support to civil society in Tunisia was impossible before the revolution. Foreign fund-
ing was forbidden and civil society activities were very limited and under strict control of the Government. There-
fore, there were no indicators available to assess this sector before 2011.

The indicators have been defined, according to the information available at that time, to help measure the degree 
of implementation of the activities.

The Commission notes that although the indicators are not very detailed, the project organised 435 dialogue/con-
sultation workshops in the 24 governorates, 120 workshops with civil society organisations representatives and 
public actors, worked with 3,500 associations and created 36 association networks. It should also be noted that 
a thorough study on the situation of civil society in Tunisia was conducted by the EUD.

The final evaluation of the programme will take place in February 2017, and will allow for a thorough assessment of 
the impact of this ambitious programme.

In addition the Commission would like to highlight that this project is considered as a flagship project and an out-
standing example in the whole neighbourhood South region.

Reply of the Commission and the EEAS 

53

56
The Commission notes that all the projects included documents, templates and the level of detail which is required 
in such cases.

The Commission underlines that the budget breakdown for project PJ 6, 7, 8 and 10, gives sufficient information to 
assess costs. The efficiency of the programme was assessed through a series of progress reports as defined in the 
contract.

57
The Commission would like to reiterate (as regards the added value of delegating the management of funds to the 
intermediary vs an indirect management by the concerned Tunisian public body) that the intermediary was at the 
time of adoption of the two projects the leading donor in the area of informal areas rehabilitation, and had been 
supporting the implementation of the Tunisian national rehabilitation programme for years. Administrative fees 
charged by the intermediary (2.9% of total funds engaged in both projects) are much lower than expenses related 
to the functioning of Project Management Units needed in case of indirect management.

Furthermore, the indirect management option would have been much more time consuming, leading to imple-
mentation delays since a learning period on EU rules and procedures would have been required to get the Tunisian 
beneficiary acquainted with them.

58
The Commission stresses that the extensions granted did not lead to any increase of total costs. These were ‘no-cost 
extensions’ as the overall budget of programmes cannot be increased.

No-cost extension may result in a redistribution of certain costs to the detriment of others but such aspects are part 
of the risks associated with operating in these environments. However, during negotiations of no-cost extension 
requests, the Commission makes every effort to ensure that any additional staff costs resulting from such exten-
sions are kept to a minimum so as not to jeopardise the success of the project. The length of the Tunisian demo-
cratic transition was longer than expected in the immediate aftermath of the 2011 Revolution, when the projects 
sampled were signed.

59
As regards the impact and sustainability of results, the Commission would like to emphasize that the specific objec-
tive of PJ6, as stated in the Financing Agreement, was the creation of temporary jobs on the one hand and the 
improvement of the employability of low-skilled workers by providing vocational training on the other. The Com-
mission considers both objectives as met. Furthermore, a second phase of the project has been adopted in 2016 
(Integrated local development programme) with the same implementing partner. The latter will maximize impact 
and ensure sustainability of results.

As regards PJ7 and PJ8, the financial difficulties to ensure the maintenance of public infrastructure provided to 
informal areas will be tackled as well in the framework of the same new programme in preparation, where the 
development of a proper national strategy as regards the control and development of informal areas, including the 
maintenance of public infrastructure, is envisaged as one of the expected results.

Reply of the Commission and the EEAS 

54

60
The Commission would like to point out that the equipment supplied under projects PJ3 and PJ4 already benefit-
ted export oriented Tunisian SMEs as it allows them to carry out in Tunisia the tests on products in compliance with 
EU rules at much lower costs than abroad. This resulted in reduced production costs and a subsequent increase in 
competitiveness vis-à-vis other producers.

The supply of this equipment is already having a positive impact in terms of access to the EU internal market for 
Tunisian SMEs, even if an Agreement on Conformity Assessment and Acceptance of industrial products (ACAA) is 
not yet concluded.

For PJ11, nearly all the activities planned had been implemented by the end of the twinning. Furthermore, given 
that the purpose of the twinning was to support the Tunisian Court of Auditors to prepare a draft organic law and 
reorganise its structure to implement the provisions of the law once adopted, the delays had no substantial impact.

Concerning PJ12, due to frequent changes of government and appointment of different Directors (4 in 3 years), all 
the legislation drafted within the project could not be implemented before the end of the project.

Conclusions and recommendations

63
In the first years after the Tunisian revolution, coordination among donors took place mostly on the basis of the 
so-called Programmes d’appui a la reliance (PAR), which supported the authorities’ economic recovery plan, and, 
subsequently, on the basis of the IMF’s comprehensive programme.

64
The Commission notes that several areas had to be tackled because of the socioeconomic challenges Tunisia was 
confronted with following the revolution. Results obtained so far are good since EU assistance contributed signifi-
cantly to improve socioeconomic and political stability in the country after the revolution. The Commission stresses 
that it has followed its own policy of concentrating its assistance. Indeed, in spite of the fact that a variety of activi-
ties have been undertaken over the period under review, these were in line with the three main sectors identified in 
the SSF 2014-16.

As mentioned under point 43, the situation of Tunisia since 2011 and the important demands to support the transi-
tion process which followed the revolution in many different areas should be acknowledged. The EU had put into 
place all its available instruments to accompany Tunisia through this complex process, which led to the adoption of 
a new Constitution unanimously praised, and free and fair elections.

The EU’s macro-financial assistance provides balance-of-payment support to help Tunisia face acute external financ-
ing needs and in support of the financial assistance programme it has agreed with the IMF. This allows Tunisia to 
make the necessary economic adjustment less harsh and abrupt, and aims to contribute to restoring its economic 
sustainability, which is a precondition for durable social development. The MFA conditionality therefore addresses 
a number of priorities in several inter-linked areas of structural reform, as a comprehensive approach to support an 
economic adjustment programme. The Commission considers that this is not a departure from the Commission’s 
policy from concentrating its assistance on a limited number of sectors. In addition, in several support areas (such 
as statistics, public finance management and good governance of the Court of Auditors) strong coordination with 
other donors and within different Commission services was crucial to add the MFA’s added leverage for important 
reforms to be fully implemented.

Reply of the Commission and the EEAS 

55

65
The Commission would like to emphasise that the joint programming process had been put on hold in anticipation 
of the presentation, by the Government, of its five-year development plan. The Commission and Member States’ 
intention being to align the programming exercise to the five-year development plan, to improve division of labour 
and coordination.

The joint programming process will be resumed in 2017.

Recommendation 1 - Strengthen the programming and focus of the EU assistance
The Commission and the EEAS accept the recommendation.

(a)
The Commission and EEAS will continue to use political and policy dialogue to ensure that the Tunisian authorities 
adopt a comprehensive national development plan and specific reform strategies. These issues have been reiter-
ated during Commissioner Hahn and HRVP Mogherini’s visits to Tunisia and also during the visit of Tunisian Presi-
dent here in Brussels in November and December 2016.

(b)
The Commission and EEAS will prepare the Single Strategic Framework for 2017-20 according to the EU guidelines 
which require focusing its assistance on three priorities sectors in order to maximise the impact of its aid.

(c)
Joint Programming will be resumed in 2017.

68
The Commission states that, in a limited number of cases, indicators/measures were met before the signing of 
financing agreements. Indeed, those measures had been formally approved with the authorities many months 
before the signing of the financing agreement and were implemented by the Government at the time the financing 
decision was adopted by the Commission. This should be seen as success and as the result of an intense policy dia-
logue with the authorities and hence would not have taken place to the same extent or within the same time frame 
in the absence of the budget support.

69
The EEAS and Commission agree on the need to work to anticipate the ‘more for more’ decisions.

Reply of the Commission and the EEAS 

56

70
The Commission would like to stress that PEFA is a useful tool but it is not a mandatory obligation and further-
more requires commitment and full cooperation of the partner country. After 2011 Tunisia (and its partners), have 
benefitted from a dozen high quality assessments of the country’s public finance management system. They were 
conducted in the framework of Commission programmes and by recognised organisations such as the IMF, the 
OCDE, Open Budget Survey. In addition, before providing MFA support, the Commission carried out, in December 
2013, a full and comprehensive Operational Assessment of the administrative and financial circuits of the Ministry 
of Finance and the Central Bank of Tunisia. Therefore the Commission considers that comprehensive and relevant 
information was available and used.

The Commission confirms that the current PEFA assessment was launched in 2014 and will be finalised in 2017. 
Delays in finalizing it are due to methodological problems and outside the control of the Commission.

Recommendation 2 - Strengthen the implementation of EU budget support 
programmes
The Commission accepts the recommendation.

(a)
With today’s more stable political context in Tunisia and in view of close coordination with other donors, the 
Commission agrees that the performance indicators can now be more focused for future operations. However, 
a dynamic approach will continue to apply to eligibility criteria, in line with budget support guidelines provisions. In 
the Tunisian context, individual measures were used as benchmarks to assess the Government’s overall progress in 
implementing its national reforms programme (one of the four eligibility criteria) and this practice proved particu-
larly efficient.

Concerning the last sentence that ‘disbursements should be made conditional to the satisfactory completion of 
individual measures, rather than on overall progress’, the Commission underlines that in application of the 2011 
communication and related 2012 Council Conclusions on ‘The Future Approach to EU Budget Support to Third 
Countries’, this dynamic approach has to be applied to eligibility criteria. The Commission links disbursements to 
performance indicators negotiated and agreed with the partner Government only after all eligibility criteria have 
been met, demonstrating satisfactory overall progress in the implementation of the programme.

(b)
The Commission recognises the significance of the PEFA as a planning and monitoring tool, however the Commis-
sion underlines that the PEFA assessment cannot be unilaterally imposed on the partner Government. The Commis-
sion will nevertheless continue to collaborate with the partner Government to strive to carry out a PEFA assessment 
according to the recommended periodicity.

Reply of the Commission and the EEAS 

57

71
The time period of 11 months between the Tunisian request for MFA and the signing of the Memorandum of Under-
standing (MoU) EU-Tunisia containing the MFA conditionality can be explained as follows.

Prior to the adoption of the Commission proposal for a MFA operation, the Commission did a comprehensive 
operational assessment of the soundness of the financial circuits in Tunisia to comply with the requirements of the 
EU Financial Regulation. The Commission proposal had then to be approved by the Parliament and the Council 
under the ordinary legislative procedure in accordance with Article 212 TFEU. Although the co-legislators managed 
to adopt the Commission proposal within 5 months without a Trilogue, one month was lost due to the fact that 
the approval by the Parliament plenary was shifted in the last moment to the April II plenary. After the adoption 
of the MFA operation, the negotiations on the draft MoU had to be finalised before the MoU had to be approved 
by a Member State Committee and could be signed by the EU in July 2014 (11 months after the Tunisian request). It 
then took the Tunisian authorities more than 6 months to ratify the MoU in March 2015. The first disbursement of 
MFA could be disbursed soon after the ratification in May 2015, whereas the second disbursement could only take 
place in December 2015 due to a lack of compliance by the Tunisian authorities with MFA conditionality.

Recommendation 3 - Make proposals to speed up the MFA approval process
The Commission accepts the recommendation.

The Commission notes that, even though significant progress has been achieved regarding the speed of the adop-
tion by the Parliament and the Council of MFA decisions, there is still room for improvement. More speedy adop-
tions could be achieved for instance if the number of meetings of the Committee on International Trade of the 
European Parliament (INTA) before an INTA vote could be reduced, if the Parliament approval would systematically 
take place at the plenary (including mini-plenaries) immediately following the INTA vote, if mini-plenaries could be 
used for the signatures by the Presidents of the Parliament and the Council and if the Council would also make use 
of the written procedure for adoptions if necessary.

The Commission also notes that, following previous recommendations by the Court of Auditors and a Resolution on 
MFA of the Parliament in 2003, it had proposed in 2011 a Framework Regulation for MFA aimed, inter alia, at expe-
diting decision-making by replacing the legislative decisions by implementing acts. However, as the co-legislators 
decided to retain legislative acts and the ordinary legislative procedure, the Commission withdrew this proposal in 
2013.

73
The Commission stresses that the extensions granted did not lead to any increase of total costs. These were ‘no-cost 
extensions’ as the overall budget of programmes cannot be increased.

Reply of the Commission and the EEAS 

58

No cost extension may result in a redistribution of certain costs to the detriment of others but such aspects are part 
of the risks associated with operating in these environments. However, during negotiations of no cost extension 
requests, the Commission makes every effort to ensure that any additional staff costs resulting from such exten-
sions are kept to a minimum so as not to jeopardise the success of the project. The length of the Tunisian demo-
cratic transition was longer than expected in the immediate aftermath of the 2011 Revolution, when the projects 
sampled were signed.

Recommendation 4 – Improve the planning of projects
The Commission accepts the recommendation.

HOW TO OBTAIN EU PUBLICATIONS

Free publications:

(cid:127) 

one copy: 
via EU Bookshop (http://bookshop.europa.eu);

(cid:127)   more than one copy or posters/maps: 

from the European Union’s representations (http://ec.europa.eu/represent_en.htm);  
from the delegations in non-EU countries (http://eeas.europa.eu/delegations/index_en.htm);  
by contacting the Europe Direct service (http://europa.eu/europedirect/index_en.htm) or  
calling 00 800 6 7 8 9 10 11 (freephone number from anywhere in the EU) (*).

(*) 

The information given is free, as are most calls (though some operators, phone boxes or hotels may charge you).

Priced publications:

(cid:127) 

via EU Bookshop (http://bookshop.europa.eu).

Event

Adoption of the Audit Planning Memorandum/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

1.3.2016

1.12.2016

14.2.2017

2.3.2017

 
We assessed whether the EU assistance delivered to Tunisia 
after the Arab Spring revolution of 2011 has been well 
spent. We concluded that the money was generally well 
spent as it contributed significantly to the democratic 
transition and the economic stability of Tunisia after the 
revolution. 
Nevertheless, a number of shortcomings were identified in 
the EU management of the assistance. In order to address 
these shortcomings, the Court makes recommendations for 
the European External Action Service and the Commission 
that concern the focusing of the assistance on a small 
number of sectors, strengthening the implementation of 
the budget support programmes, and finally, improving the 
planning of the programmes and speeding up their 
implementation.

1977 - 2017