COMMISSION STAFF WORKING DOCUMENT Evaluation of the European Neighbourhood Instrument Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Mid-term review report of the External Financing Instruments
Date: 2017-12-15
Institutions: Directorate-General for International Cooperation and Development, European Commission
Subjects: Central and Eastern European countries, European Neighbourhood and Partnership Instrument, European neighbourhood policy, Mediterranean region (EU), cross-border cooperation, economic integration, economic reform, financial aid, political reform, regional cooperation

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 15.12.2017  SWD(2017) 602 final  COMMISSION STAFF WORKING DOCUMENT Evaluation of the European Neighbourhood Instrument Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Mid-term review report of the External Financing Instruments {COM(2017) 720 final} - {SWD(2017) 463 final} - {SWD(2017) 600 final} - {SWD(2017) 601 final} - {SWD(2017) 604 final} - {SWD(2017) 605 final} - {SWD(2017) 606 final} - {SWD(2017) 607 final} - {SWD(2017) 608 final} - {SWD(2017) 609 final}  
 
 
Contents 

Executive summary .................................................................................................................... 2 

Purpose of the evaluation ....................................................................................................... 3 

Scope of the evaluation .......................................................................................................... 3 

2. Background of the initiative ................................................................................................... 4 

Description of ENI and its objectives .................................................................................... 4 

Baseline .................................................................................................................................. 5 

3. Method ................................................................................................................................... 7 

4. Implementation state of play .................................................................................................. 9 

5. Answers to the evaluation questions .................................................................................... 15 

6. Conclusions .......................................................................................................................... 32 

Annex 1. Evaluation Questions ................................................................................................ 34 

Annex 2. Procedural information ............................................................................................. 37 

Annex 2bis Response to the opinion of the Regulatory Scrutiny Board .................................. 41 

Opinion of the Regulatory Scrutiny Board .......................................................................... 41 

Title: Evaluation / European Neighbourhood Instrument ................................................. 41 
Overall opinion:   1st submission: NEGATIVE ................................................................. 41 
2nd submission: 28/09/2017 - POSITIVE .............................................................................. 41 

Annex 3. Synopsis report of the stakeholders' consultation ..................................................... 45 

Consultation strategy ................................................................................................................ 45 

Stakeholder mapping ........................................................................................................ 45 

Stakeholder consultation strategy ..................................................................................... 47 

Stakeholder consultation framework ................................................................................ 48 

Timeframe ........................................................................................................................ 48 

Stakeholder statistics ........................................................................................................ 48 

Open Public Consultation (07/02/17 - 05/05/17) ............................................................. 50 

Annex 4. Acronyms .................................................................................................................. 54 

Annex 5. External evaluators' report, including its annexes and methods and analytical models 
used ........................................................................................................................................... 57 

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Executive summary 

This Staff Working Document evaluates the European Neighbourhood Instrument (ENI) at its 
mid-term, covering the period January 2014 to June 2017. With a budget of EUR 15.4 billion, 
the  ENI  is  the  largest  financing  instrument  within  the  EU  budget  supporting  the 
implementation  of  the  European  Neighbourhood  Policy  (ENP)  in  the  16  Neighbourhood 
countries. Its overall objective is to advance further towards an area of shared prosperity and 
good neighbourliness by developing a special relationship founded on cooperation, peace and 
security,  mutual  accountability  and  a  shared  commitment  to  the  universal  values  of 
democracy, the rule of law and respect for the human rights. The main findings are as follows: 

The  ENI  remains  relevant  and  fit  for  purpose.  It  has  allowed  the  EU  to  implement  the 
reviewed  Neighbourhood  Policy.  It  has  proven  its  flexibility,  in  line  with  the  impact 
assessment,  by  reacting  to  the  multiple  crises  and  new  challenges  in  the  Neighbourhood,  in 
particular in Ukraine, Tunisia and in relation to the migration crises. The implementation of 
the principle of differentiation  has allowed the EU to  adapt its support to  partner countries’ 
needs and ambitions (e.g. by more than doubling EU assistance to Tunisia), as envisaged in 
the  ENI  impact  assessment.  However,  the  response  capacity  of  the  instrument  has  been 
stretched to its limits.  

As  regards  effectiveness,  ENI  presents  a  mixed  picture.  In  the  field  of  human  rights, 
democracy  and  governance,  the  political  context  in  many  countries  has  made  it  difficult  to 
pursue comprehensive support strategies and impeded the achievement of significant results. 
However,  EU  support  in  the  area  of  economic  governance  and  trade  has  contributed  to  the 
improved business environment in several countries in the Eastern  Neighbourhood, but  also 
Morocco, as well as to the increased trade potential between the Neighbourhood countries and 
the  EU.  Budget  support  under  the  ENI  has  contributed  to  macroeconomic  stabilisation  in 
important  EU  partners  such  as  Jordan,  Moldova,  Tunisia  and  Ukraine.  The  incentive-based 
approach has been only partly successful in promoting deep and sustainable democracy; it has 
been more effective in supporting those partners committed to reforms (in particular Georgia, 
Morocco,  Tunisia  and  Ukraine).  Overall,  the  prospects  for  ensuring  the  sustainability  of 
reforms are limited in several countries because of the unfavourable political environment.  

Within  the  Commission,  the  ENI  is  delivering  aid  efficiently  in  terms  of  procedures, 
processes  and  the  ratio  of  administrative  costs,  with  an  adequate  organisational  set-up  and 
quality in-house expertise (although concentrated in only some key priority areas). The ENI 
has  a  clear  EU  added-value  resulting  from  its  ability  to  provide  substantial  funding  in  the 
form  of  grants,  its  capacity  to  mobilise  other  EU  instruments  and  loans  from  financial 
institutions,  its  capacity  to  mobilise  EU  Member  States'  expertise  and  its  policy  leverage 
through dialogue with national authorities and civil society. It offers a unique portfolio of aid 
modalities which can be used in a coherent way and adjusted to the partner country’s needs 
and capacity. None of these features can be achieved individually by EU Member States. 

Significant  efforts  are  made  to  coordinate  ENI  and  other  external  financing  instruments 
programmes,  although  there  is  scope  to  increase  the  coordination  between  country  and 
regional  programmes.  Coordination  with  the  Member  States  has  increased,  in  particular 
through the development  of  joint  programming  approaches (e.g.  in  Moldova  and  Palestine). 
The blending of ENI grants with loans from other financial institutions (in particular those of 
European  Financial  Institutions),  attracted  significant  additional  resources  to  achieve  ENI 
objectives. Policy dialogue and cooperation leveraged the implementation of agreed reforms 

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in  a  number  of  countries  (e.g.  public  administration  reform  in  Ukraine).  This  leverage  is 
stronger when budget support is used as implementing modality, because of the greater depth 
of policy dialogue with the beneficiary throughout the life of the operation.  

1. Introduction 

Purpose of the evaluation 

This document sets out the results of a mid-term evaluation of the European Neighbourhood 
Instrument  2014-2020  (ENI)1.  The  evaluation  assesses  whether  the  ENI  is  fit  for  purpose, 
based on its performance to-date, to deliver on its objectives of advancing further towards an 
area  of  shared  prosperity  and  good  neighbourliness  by  developing  a  special  relationship 
founded on cooperation, peace and security, mutual accountability and a shared commitment 
to the universal values of democracy, the rule of law and respect for human rights2.  

Its  purpose  is  to  inform  future  work  on  the  instrument  and  its  actions.  In  particular,  this 
evaluation,  which  is  part  of  a  set  of  ten  evaluations  covering  all  the  EU  external  financing 
instruments3,  informs  the  Mid-Term  Review  Report4,  which  draws  conclusions  across  these 
instruments. 

This  document  is  largely  based  on  an  external  evaluation  carried  out  by  independent 
consultants, presented in Annex 5, complemented by internal assessments, other evaluations 
and a broad consultation process. 

Scope of the evaluation 

This evaluation covers the period from 1 January 2014 to 1 June 2017. However, due to the 
length of the implementation cycle of the ENI, the availability of data and results are limited. 
Therefore the evaluation also looks at the previous instrument for the Neighbourhood (ENPI, 
2007-2013) 5 for  some  of  the  evaluation  criteria  (e.g.  efficiency  and  effectiveness).  When 
using  the  previous  instrument  as  a  source  of  data,  it  is  important  to  note  that  the  overall 
objective of the ENI has broadly remained the same as for the former instrument. 

Consistent  with  the  requirements  of  the  Common  Implementing  Regulation,  and  in  view  to 
usefully feed into the Mid-Term Review Report, the evaluation is set at instrument level. As a 
consequence,  it  focuses,  to  the  extent  possible,  on  the  elements  contained  in  the  ENI 
Regulation  (e.g.  on  its  principles,  scope,  flexibility  and  complementarity  with  other 
instruments)  rather  than  on  the  projects  that  have  been  put  in  place  on  the  basis  of  the 

1 Regulation (EU) No 232/2014 of the European Parliament and of the Council of 11 March 2014, OJ L77, p. 27 
2 Art. 1.1 of the ENI. 
3 11th European Development Fund (EDF), European Neighbourhood Instrument (ENI), European Instrument for 
Democracy  and  Human  Rights  (EIDHR),  Greenland  Decision  (GD),  Instrument  contributing  to  Stability  and 
Peace  (IcSP),  Instrument  for  Pre-accession  Assistance  (IPA  II),  Instrument  on  Nuclear  Safety  Cooperation 
(INSC),  Overseas  Countries  and  Territories  Decision  (OCT),  Partnership  Instrument  (PI)  and  the  Common 
Implementing Regulation (CIR). For the purpose of this exercise, the evaluation of the Overseas Countries and 
Territories Decision is included within the evaluation of the 11th European Development Fund. 
4 As  requested  in  Article  17  of  the  Common  Implementing  Regulation:  Regulation  (EU)  No  236/2014  of  the 
European Parliament and of the Council of 11 March 2014, OJ L77, p. 95 
5 Regulation (EC) No 1638/2006 of the European Parliament and of the Council of 24 October 2006 laying down 
general provisions establishing a European Neighbourhood and Partnership Instrument  (ENPI) of 9 November 
2006, OJ L130  

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instrument.  However,  some  information  on  programming  has  also  been  included  to  show 
progress on how the instrument has been implemented (see section 4). 

The  countries  covered  by  the  evaluation  are  those  eligible  under  the  ENI  Regulation  (see 
annex 1 of the Regulation)6.  

In  accordance  with  the  EU  Better  Regulation  Agenda 7  and  the  Common  Implementing 
Regulation,  the  following  evaluation  criteria  are  used:  relevance;  effectiveness,  impact  and 
sustainability;  efficiency;  EU  added  value;  coherence,  consistency,  complementarity  and 
synergies, and leverage. 

2. Background of the initiative 

The  External  Financing  Instruments  make  up  a  major  part  of  the  Multiannual  Financial 
Framework's8 Heading IV "Global Europe"9 which provides the EU with the tools necessary 
to reinforce its role on the world stage and to ensure that it is able to live up to its ambitions in 
promoting its interests and universal values and principles such as democracy, human rights, 
peace, solidarity, stability and poverty reduction and to help safeguard global public goods.  

Adopted  in  early  2014,  the  External  Financing  Instruments  were  designed  to  facilitate  and 
support policy implementation, with the intention of remaining relevant for the entire duration 
of  the  Multi-annual  Financial  Framework,  thereby  enabling  the  EU  to  implement  external 
action policy as needed within the defined principles and objectives.  

Description of ENI and its objectives 

implementation  of 

The European Neighbourhood Instrument (ENI) is the main financing instrument to support 
the 
the  European  Neighbourhood  Policy  (ENP).  The  European 
Neighbourhood Policy (ENP) was conceived in 2003 to develop closer relations between the 
enlarged  EU  and  its  neighbouring  countries.  The  ENP  was  substantially  reviewed  in  2011, 
notably  in  the  context of the EU's response to  the events of the Arab Spring. It was further 
reviewed  in  2015  to  take  account  of  the  significant  political  developments  in  the 
neighbourhood. 

The ENI Regulation, consistent with Article 8 of the Treaty on European Union (TEU), aims 
to advance further towards an area of shared prosperity and good neighbourliness involving 
the  Union  and  the  Neighbourhood  countries  and  territories  by  developing  a  special 
relationship founded on cooperation, peace and security, mutual accountability and a shared 
commitment to the universal values of democracy, the rule of law and respect for the human 
rights (see the Intervention Logic below). The EU provides its support to partner countries in 
the Neighbourhood region mainly through the ENI, with its initial envelop of over EUR 15.4 
billion  for  2014-2020,  replenished  on  a  number  of  occasions  since  2014.  The  ENI  replaced 
the  European  Neighbourhood  and  Partnership  Instrument  (ENPI),  which  covered  the  period 

6  They  are:  Armenia,  Azerbaijan,  Belarus,  Georgia,  The  Republic  of  Moldova  and  Ukraine,  for  the 
Neighbourhood  East,  and  Algeria,  Egypt,  Israel,  Jordan,  Lebanon,  Libya,  Morocco,  occupied  Palestinian 
territory, Syria, Tunisia, for the Neighbourhood South. 
7 Commission  Communication  Better  regulation  for  better  results  –  An  EU  Agenda,  COM  (2015)  215,  and 
Commission Staff Working Document Better Regulation guidelines, SWD (2015) 111. 
8 Council  Regulation  (EU,  EURATOM)  No  1311/2013  of  2  December  2013  laying  down  the  Multiannual 
Financial Framework for the years 2014-2020, OJ L 347/884, p. 884. 
9 The Multi-annual Financial Framework is divided into six broad groups of expenditure called "Headings". The 
EFIs make up the majority of Heading IV: Global Europe. 

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2007-2013. It covers the same countries with the exception of Russia, which is only eligible 
to multi-country and Cross-Border Cooperation programmes under the ENI with a particular 
focus on people to people contacts and with the principle of co-financing by EU and Russia. 

Union support under the ENI Regulation is used for the benefit of partner countries and the 
areas involved  in  cross-border  cooperation,  as well as  for the common benefit of the Union 
and  partner  countries.  It  is  programmed  through:  bilateral,  multi-country  and  Cross-Border 
Cooperation programmes. 

The  main  objectives  for  assistance  under  the  ENI  are  the  promotion  of  human  rights,  good 
governance and the rule of law and the strengthening of civil society, market access and free 
trade  areas,  the  management  of  migration,  sustainable  and 
inclusive  development, 
environment and climate change, security and prevention and management of conflicts as well 
as regional and cross-border cooperation. 

The reconstructed ENI Intervention Logic (IL) was designed based on the ENI Regulation and 
the evolution of the ENI strategic documents, notably the revised ENP of November 2015. 

The  ENI  is  not  the  only  instrument  in  place  to  implement  the  ENP.  In  addition  to  other 
contributing  instruments  (such  us  the  DCI,  EIDHR  and  IcSP)  and  EU's  external  crisis 
response tools (such us Macro-Financial Assistance and Humanitarian assistance) the EU also 
conducts policy dialogue promotes participation of partner countries in EU programmes and 
sectoral policies (agreements on trade, aviation, Research and Development, SMEs, migration 
and mobility etc.). These activities contribute to the achievements of ENI objectives, but are 
not part of this evaluation. Their contributions to ENI objectives cannot be disentangled form 
contributions of ENI programmes.  

Baseline 

As  this  is  a  mid-term  evaluation,  the  baseline  has  been  set  at  January  2014  when  the  ENI 
2014-2020 entered into force. Therefore the evaluation compares, to the extent possible, the 
current  situation  with  that  of  January  2014.  For  some  evaluation  criteria,  where  data  is 
unavailable  for  this  reference  date,  earlier  baselines  have  been  used,  as  described  in  the 
document  (see  Evaluation  questions  on  effectiveness  and  efficiency),  considering  that  the 
overall objectives of ENI are in line with the ones of the ENPI. 

The ENI Regulation doesn't include indicators at instrument level. Indicators are defined for 
each  country  at  sector  level  in  multi-annual  programming  documents  and  specific 
programmes.  Indicators  are  linked  to  specific  country  situations  and  reform  objectives  and 
progress  can  only  be  assessed  in  these  sectors  at  country  level.  Therefore  aggregation  at 
instrument  level  is  often  not  possible,  in  particular  in  sectors  such  as  public  administration 
reforms,  judiciary  reform  or  public  finance  management  reforms.  This  means  that  progress 
and impact cannot be assessed at the level of the instrument; assessment of progress is made 
at country or regional level for the different sectors. 

The  ENI  has  been  implemented  in  all  countries,  despite  the  difficult  and  often  worsening 
political,  social, and economic situation  in  many of them  in  2014, because  non-engagement 
was  not  an  option  for  the  EU10,  given  the  close  relationship  with  these  countries  and  the 

10 Relations with the government of Syria were suspended in 2011. 

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immediate  impact  on  the  EU  itself  of  major  crises  at  its  borders.  Supporting  the  sometimes 
difficult political and economic transition processes in these countries was an imperative for 
the EU.  

Supporting partner countries which have embarked on ambitious agreements with the EU, the 
most  advanced  ones  being  the  Association  Agreements  including  Deep  and  Comprehensive 
Free  Trade  Areas  (AA/DCFTA)  with  Moldova,  Georgia  and  Ukraine  is  one  of  the  key 
objectives  of  the  ENI.  To  that  end  capacity  development  is  a  major  component  of  reforms 
programmes under the ENI.  

Figure 1 – Reconstructed Intervention Logic 

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Positive  incentives  and  reward  for  progress  in  democratic  reforms  were  introduced  in  the 
aftermath of the Arab Spring ("more for more" approach). This has been formally translated 
in  the  ENI  Regulation  with  the  introduction  of  the  incentive-based  approach  (with  the  so-
called  "umbrella  programmes"),  with  financial  incentives  decided  on  an  annual  basis  for 
partner countries committed to achieve progress towards deep and sustainable democracy and 
implementation  of  agreed  reform  objectives  contributing  to  the  attainment  of  that  goal. 
Progress  is  assessed  on  the  basis  of  the  country  annual  progress  reports  and  other  relevant 
documents.  The  Regulation  also  provides  for  a  higher  degree  of  differentiation  among 
partners, including in the definition of country allocations. 

The objectives of the instrument have also been streamlined with a focus on policy priorities 
and a more limited number of specific objectives.  A better link with relevant internal polices 
and instruments was promoted, in particular with the extension of the possibility for countries 
to participate in some EU programmes and in the work of EU agencies. 

In  line  with  the  EU  commitments  in  Busan  to  increase  the  coherence,  complementarity  and 
effectiveness  of  EU  action  abroad,  the  ENI  Regulation  encourages  moves  towards  joint 
programming. 

3. Method  

This evaluation is supported by an external evaluation carried out from August 2016 to May 
2017.  The  external  evaluation  of  the  ENI  was  managed  by  the  Inter-Service  Group  through 
the  following  steps:  an  inception  report  (which  explained  how  the  evaluation  design  would 
deliver  the  information  required);  a  desk  report  (providing  initial  responses  to  evaluation 
questions); visits to Egypt, Georgia, Lebanon, Tunisia and Ukraine to meet key interlocutors 
to obtain first-hand view in-country; a survey to EU delegations covering all instruments; an 
Open Public Consultation11 on the draft report which comprised of a 12 week online survey 
and targeted meetings with Member States in March 2017; and a final report.  

Overall,  the  quality  of  the  collected  evidence  (data,  documentation,  interviews  and  survey 
results) for this evaluation can be assessed as good, within the limitations mentioned below. 
Beside  the  limited  amount  of  information  available  on  implementation,  there  was  a  limited 
feedback  from  the  Open  Public  Consultation  and  the  Commission  services  had  to  provide 
substantial comments and revisions to the text provided by the external evaluators in order to 
address some shortcomings, notably related to the understanding of the policy framework and 
articulation  of  the  different  financing  instruments.  This  Staff  Working  Document  largely 
concurs with the findings and conclusions of the external evaluation.  

Organisation 

As part of a wider set of evaluations covering the eight External Financing Instruments, the 
European Development Fund (EDF) and the Common Implementing Regulation (CIR), all the 
evaluations were carried out in an interlinked and co-ordinated manner. To ensure coherence 
of the different evaluations, relevant Commission services have worked closely together from 
the beginning of the process in June 2015. The external contractor delivered its final report at 
the  end  of  June  2017.  All  reports  prepared  by  the  external  contractor  were  discussed, 

11 https://ec.europa.eu/europeaid/public-consultation-external-financing-instruments-european-union_en 

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reviewed and approved by the dedicated  Inter  Service Group set up by the Commission  for 
the ENI evaluation. 

The  draft  final  report  prepared  by  the  external  contractor  was  placed,  with  the  other 
instruments draft reports, on the web for the open public consultation (OPC) from 7 February 
to  3  May  2017.  Forty  four  contributions  were  received.  During  that  period  targeted  face  to 
face meetings were organised with representatives of civil society organisations (CSOs), EU 
Member States and the European Parliament12.  

Evaluation Design 

The intervention logic (IL) forms the backbone of the analytical framework. It is visualised in 
an IL diagram, which brings together the most relevant elements (from inputs to impacts, but 
also assumptions) in a single framework. To take into account the revised ENP policy of 2015 
that  put  a  focus  on  the  stabilisation  and  the  ability  of  responding  to  emergencies  in  the 
neighbourhood, a reconstructed IL was prepared by the external consultants13. 

Covering the different levels of the IL, the evaluation questions (EQ) structure the analysis to 
gather  evidence.  Each  question  was  structured  into  judgement  criteria  (JC)  and  indicators 
required to provide an answer based on a synthesis of evidences.  

Methodology and data 

The EU evaluation criteria (relevance, effectiveness, efficiency, coherence, and added value, 
complemented  by  impact,  sustainability,  consistency,  complementarity  and  synergies  and 
leverage) were applied as an underlying basis. The evaluation questions gave rise to a number 
of judgement criteria and associated indicators. The external evaluation used a mixed methods 
approach blending quantitative and qualitative methods, with a focus on the latter. The main 
analytical  tools  consisted  of  rigorous  assessment  of  documentation  and  consultation  of 
stakeholders  (semi-structured  interviews,  group  consultations),  and  the  Open  Public 
Consultation;  key  issues  were  also  addressed  by  a  survey  of  beneficiaries  and  stakeholders 
organised by the Commission. 

For all EQs, data collection included a mixture of desk review of documents, semi-structured 
interviews in Brussels by phone or face-to-face, as well as four field missions that took place 
to Egypt, Georgia, Tunisia, and Ukraine.  

Challenges and limitations 

The process of this evaluation is robust and the evidence reasonably solid. However, external 
evaluators were faced with four main challenges: 

- the implementation of ENI was still in its early stages when the collection of evidence took 
place.  Therefore,  effectiveness/sustainability/impact  criteria  could  not  be  assessed  based  on 
outputs and outcomes at this stage; 

- the timeframe in which the evaluation took place was tight given the requirements imposed 
by  the  Common  Implementing  Regulation.  This  resulted  in  difficulties  related  to  access  to 
data, documentation and availability of key respondents; 

12 See Annex 3. 
13 See at page 6. 

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-  the  ENI  impact  assessment  had  not  provided  an  estimation  of  the  expected  impact  in 
quantitative terms14; 

- The ENPI is still under implementation, and there is no ex-post evaluation yet at this stage 
and it was not possible to build on that.  

The multiple rounds of commenting also mean that facts were verified and this facilitated the 
cross  verification  of  data  from  multiple  sources.  The  evaluators  were  provided  access  to  all 
relevant information and colleagues within the Commission services and in EU Delegations. 
The  Commission  services  also  ensured  that  the  evaluators  would  have  access  to 
representatives of the beneficiaries.  

As indicated by the Intervention Logic, the ENI instrument can only be seen as a contributing 
factor towards any results achieved, especially in the context of the geo-political changes in 
the Neighbourhood regions. Many factors, both internal and external, affect developments in 
the beneficiaries. The reform agenda for stabilising the neighbourhood, economic integration 
of  partners  in  the  EU  market  and  political  association  is  highly  demanding  and  requires  a 
strong  political  commitment  from  partners.  Ultimately,  it  is  for  the  countries  to  adopt  and 
implement the necessary reforms and policies for ensuring that they can reap the benefits of 
economic integration and political association. 

4. Implementation state of play 

Specific objectives and priorities and indicative financial allocations for EU support are set in 
multi-annual programming documents,  whose duration is  adapted to the situation  prevailing 
in each country or region (from two to four years) and which are developed through a wide 
consultation  process,  involving  the  authorities,  civil  society  organisations  and  all  relevant 
stakeholders  and  the  Member  States.  These  priorities  at  country  or  regional  level  are  then 
translated into annual action programmes detailing the different actions.  

The vast majority of funding is channelled through bilateral programmes, tailored to the needs 
of  each  partner  country,  in  line  with  the  principles  of  differentiation  and  ownership  of  the 
Neighbourhood  policy.  In  addition,  the  ENI  also  supports  multi-country  and  Cross  Border 
Cooperation  programmes  (15  ENI-CBC  programmes  adopted  for  the  period  2014-2020, 
totalling around EUR 1 billion). The ENI also contributes to the Erasmus+ programme with a 
planned amount of more than EUR 700 million for 2014-2020.  

In response to the recent developments in the Neighbourhood and in order to implement the 
Global  Strategy  for  the  EU's  Foreign  and  Security  Policy  of  2016  and  the  ENP  Review  of 
2015,  some  multi-annual  programming  documents  were  revised  by  anticipation  in  2017 
instead of 2018. 

Joint programming is developing in the neighbourhood and a full-fledged joint programming 
document will be adopted in the course of 2017 for Palestine, covering the period 2017-2020, 
which will replace a Single Support Framework. 

Under  the  ENI,  the  EU  continued  to  increase  its  support  to  civil  society,  through 
mainstreaming  but  also  through  specific  complementary  allocations  to  support  the 

14 This was largely inevitable, considering the high number of sectors and countries involved, the fact that the 
programming had not taken place yet, that the amount of resources available was not known yet and that many 
interventions are of soft nature. 

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development of their capacities, helping them become more professional and reliable partners 
in the policy-making and reform processes. 

Cooperation  under  the  ENI  is  implemented  through  a  range  of  modalities.  Support  to  large 
reforms is often implemented through sector budget support programmes, when conditions in 
the  country  allow,  or  sector  programmes.  Technical  assistance  is  provided  to  accompany 
reform  programmes  and  support  partner  countries  in  the  implementation  of  Association 
Agreements,  including  by  sharing  expertise  from  Member  States  through  TAIEX 15 , 
Twinnings16 and the SIGMA17 programme. 

Under  the  ENI,  the  blending  approach  has  been  further  developed  with  the  Neighbourhood 
Investment  Facility  (NIF)  which  leverages  loans  from  European  Financial  Institutions  to 
finance  investments  in  sustainable  energy,  transport  infrastructure,  environment  and  private 
sector development, targeting small and medium-sized enterprises.  

The  ENI  incentive-based  mechanism  ("Umbrella  Programme")  is  providing,  on  an  annual 
basis, additional funding to countries demonstrating progress in building deep and sustainable 
democracy for an amount of around 10% of the annual ENI budget (average amount of EUR 
200  million  a  year).  The  main  beneficiaries  from  2014  to  2016  were  Tunisia,  Ukraine  and 
Georgia (see table below).  

Since the adoption of the ENI, the EU has been faced with the need to respond to the multiple 
crises  and  unforeseen  events  which  unfold  in  its  neighbourhood  (see  the  following  table, 
pointing out the main negative events affecting several countries, with related impact.  

Table  1  - Major  events  having  negatively  affected  some  ENI  beneficiary  countries  and 
related impact 

Country 

Neighbourhood East 
Armenia 

(59%  of 

Ukraine 
the 
population and 51% of the 
of 
GDP 
total 

Major 
affecting 
country 

events 
the 

Impact 

joins 

In  2015  Armenia 
officially 
the 
Russian-led  Eurasian 
Customs 
Union, 
having 
decided 
against  signing  an 
Association 
EU 
Agreement. 
Maidan 
2014 
Annexation 

event 

of 

in 

Reduced willingness to comply with the EU agenda 

Political  instability  (Indicator  on  Political  stability  and 
absence of violence (WB)  from 45.5 in 2010 to 5.71 in 
2014) 

15 Technical  Assistance  and  Information  Exchange  programme  of  the  Commission.  The  programme,  initially 
created for Enlargement countries, provides short term technical assistance coming from EU Member States to 
partner countries' institutions. 
16  The  programme  foresees  medium-term  technical  assistance  provided  by  experts  coming  from  EU  MS 
institutions to their homologues in the partner countries. 
17 SIGMA (Support for Improvement in Governance and Management) is a joint initiative of the Organisation 
for Economic Co-operation and Development and the European Union providing support in the area of public 
administration, rule of law. 

10 

 
 
 
 
                                                 
Neighbourhood 
before the crisis) 

East 

Crimea by Russia 
Conflict 
Ukraine 

in  eastern 

of 

Neighbourhood South 
the 
(38% 
Egypt 
population and 17% of the 
total 
of 
GDP 
Neighbourhood  South  in 
the  last  year  for  which 
statistics  are  available  for 
all countries - 2006)  

(2011) 
Revolution 
and  political  unrest 
(2013). Terrorism 

Civil war in Syria 
Terrorism 

Losses  of  human  lives  (about  10,000  reported  killed 
since the start of the crisis) 
Substantial  interference  of  Russia  in  national  politics 
and security 
Substantial losses in economic terms (growth rate from 
5.5% in 2010 to -6.6% in 2104 and -9.8% in 2015) 
Macroeconomic  imbalances  (Fiscal  balance  -4.14%  of 
GDP in 2014; public debt 70% in 2014, as opposed to a 
40% of GDP the year before) 

environment 

and 
Deteriorated  macroeconomic 
macroeconomic  imbalances  (fiscal  balance  -12.9%  in 
2014 of GDP; public debt around 90%) 
Worsening  conditions  of  Rule  of  law  (RoL  indicator 
(WB) down from 49.76 in 2010 to 31.25 in 2015) 
Increased  insecurity  (Indicators  on  Political  Stability 
and  absence  of  violence  (WB)  from  19.43  in  2010  to 
8.57 in 2015) 
No budget support payments since 2012. 
Major inflow of refugees from Syria (at least 660,000) 
Macroeconomic  imbalances  (Fiscal  balance  at  least  -
11% of GDP during the  last years; public debt  around 
90% of GDP) 

(3.3%  of 

the 
Jordan 
population and 2.5% of the 
total 
of 
GDP 
Neighbourhood  South  in 
the  last  year  for  which 
statistics  are  available  for 
all countries - 2006) 
Lebanon 
the 
(4%  of 
population and 3.6% of the 
total 
of 
GDP 
Neighbourhood  South  in 
the  last  year  for  which 
statistics  are  available  for 
all countries - 2006) 
Libya 
the 
of 
population  and  9%  of  the 
total 
of 
GDP 
Neighbourhood  South  in 
the  last  year  for  which 
statistics  are  available  for 
all countries - 2006) 
the 
of 
Syria 
population and 5.3% of the 
total 
of 
GDP 
Neighbourhood  South  in 
the  last  year  for  which 
statistics  are  available  for 
all countries - 2006) 

(10% 

(3% 

(5.3%  of 

Tunisia 
the 
population and 5.6% of the 
total 
of 
GDP 
Neighbourhood  South  in 
the  last  year  for  which 
statistics  are  available  for 
all countries - 2006) 

Civil war in Syria 
Terrorism 

Major inflow of refugees from Syria (about 1.1 million) 
Macroeconomic  imbalances  (fiscal  balance  at  –  7.5% 
of GDP in 2015; public debt around 140% of GDP) 

Fall  of  the  Kaddafi 
regime 
in  2011 
following  the  Arab 
Spring 
Terrorism 

Deep  political  instability  and  deteriorated  security 
(Indicator on Political stability and absence of violence 
(WB) from 47.39 in 2010 to 3.35 in 2015 
Collapsing economy (IMF estimates a growth rate of -
53%  of  DGP  in  2014;  a  fiscal  balance  of  –  73%    of 
GDP in the same year) 

Civil  war  following 
the Arab Spring 
Creation  of  ISIL  in 
2014 
Military 
interventions 
NATO and Russia 

of 

and 
Revolution 
instability 
political 
following  the  Arab 
Spring.  Three  major 
terrorist  attacks 
in 
2015. 

Major  political  disruption  (Indicator  on  Political 
stability  and  absence  of  violence  (WB)  from  22.27  in 
2010 to 0 in the last years) 
Major macroeconomic crisis (no data available) 
Losses  of  human  lives  (estimates  vary,  but  go  up  to  a 
level of 475,000) 
More than 5 millions of people escaping 
About 6.5 million internally displaced 
Macroeconomic  imbalances  (Fiscal  balance  -5.2%  of 
GDP in 2015; public debt above 57% in the same year) 
Negative impact, in terms of security and attractiveness 
for  investments  and  tourism  due  the  deteriorated 
situation  in  Libya  (Indicator  on  Political  stability  and 
absence  of  violence  from  43.60  in  2010  to  18.47  in 
2014, and still deteriorating) 
Social unrest 

11 

 
 
 
 
 
 
 
 
The flexibility of the instrument has been stretched to the limit. The initial budged proved to 
be  insufficient,  which  was  partially  addressed  through  transfers  from  other  external 
instruments.  Faced  with  the  illegal  annexation  of  Crimean  peninsula  by  the  Russian 
Federation and the conflict in the eastern Ukraine when the negotiation of the ENI Regulation 
had  just  been  finalised,  the  Commission  mobilised  all  the  possibilities  of  the  external 
cooperation regulations tool box and adopted in April 2014 a major State Building Contract of 
EUR  355  million  to  support  the  political  and  economic  stabilisation  of  Ukraine,  the  largest 
bilateral programme ever for Ukraine. This was also the first large programme adopted under 
the  new  ENI  Regulation,  showing  its  flexibility  to  respond  to  major  crises.  It  was 
accompanied by a EUR 10 million programme in favour of civil society to help civil society 
organisations (CSOs) monitor national reforms.  

The  same  year,  the  scale  of  the  Syrian  crisis  and  its  enormous  impact  on  neighbouring 
countries led the Commission to establish EU Regional Trust Fund in Response to the Syrian 
Crisis  (the  "Madad"  fund)18.  This  Trust  Fund  brings  a  more  coherent  and  integrated  EU 
response  to  the  crisis  and  primarily  addresses  longer  term  economic,  educational  and  social 
needs of Syrian refugees in neighbouring countries such as Jordan, Lebanon, Turkey and Iraq, 
as  well  as  helping  overstretched  host  communities  and  their  administrations.  As  of  end  of 
June  2017,  contributions  from  the  EU  budget  to  the  Madad  fund  amounted  to  EUR  956.20 
million,  of  which  EUR  523.5  million  from  ENI  for  a  total  amount  of  around  EUR  1300 
million. The establishment of the Madad fund aimed at responding to the challenges around 
the Syria crisis in a more integrated and coherent way and leveraging additional funds from 
the Member States, alleviating EU budget constraints. 

The  ENI  also  contributed  to  the  EU  emergency  trust  fund  for  Africa 19 for  stability  and 
addressing  root  causes  of  irregular  migration  and  displaced  persons  in  Africa  for  a  total  of 
EUR 194 million since 2015, in order to address the root causes of migration and the different 
aspects  of  migration  management  in  the  five  beneficiary  countries  of  the  North  Africa 
window (Algeria, Egypt, Libya, Morocco and Tunisia). 

A  number  of  special  measures  has  also  been  used  to  ensure  quicker  reaction  to  evolving 
needs. 

Since  2014,  the  initial  ENI  budget  set  at  EUR  15.4  billion  in  2014  has  been  substantially 
increased  (by  EUR  1.1  billion)  through  reinforcements  from  Heading  IV  margin, 
redeployments  in  Heading  IV  and  reinforcement  from  Contingency  Margin  in  support  of 
UNRWA and in response to the consequences of Syrian Crisis.  

In  total,  until  June  2017,  EUR  7.0  billion  have  been  committed,  and  EUR  5.3  billion 
disbursed.  Out  of  the  first  amount,  EUR  4.4  billion  were  committed  to  the  partners  in  the 
South  (63  %),  and  EUR  2.0  billion  to  the  East  (28  %),  with  EUR  3.3  billion  and  EUR  1.5 
billion disbursed so far.  

18 Set  up  in  December  2014  to  face  the  Syrian  refugee  crisis,  with  contribution  from  ENI,  Turkey,  IPA  and 
several  Member  States, 
than  EUR  1.3  billion.  See 
https://ec.europa.eu/neighbourhood-enlargement/neighbourhood/countries/syria/madad_en. 
19 EU  emergency  trust  fund  for  Africa  for  stability  and  addressing  root  causes  of  irregular  migration  and 
displaced persons in Africa, set-up end at the Valetta Summit in November 2015 

fund  has  already 

reached  more 

the 

12 

 
 
                                                 
The  implementation  of  ENI  assistance  is  continuously  monitored,  in  particular  through 
Results-Oriented  Monitoring  (ROM)  of  projects  and  programmes 20 ,  internal  monitoring 
implemented by EU Delegation staff and evaluations at policy, thematic, as well as at country 
or regional level21.  

No systemic  monitoring of ENI at instrument level  is  taking place,  also in  the absence  of a 
specific monitoring system set out at instrument level. Results reporting has so far taken place 
in  the  framework  of  the  end  of  project  results  reporting  exercise,  put  in  place  by  DEVCO 
based  on  the  EU  Results  Framework22,  but  focused  so  far  only  on  projects  related  to  the 
previous Multi-annual Financing Framework (MFF). 

20 An average number of 150 projects is subject to ROM per year. Related reports are not made public. 
21  See  DG  NEAR  evaluation  plan  and  published  evaluation  reports  on  https://ec.europa.eu/neighbourhood-
enlargement/news_corner/key-documents_en 
22 This consists of a set of indicators at development, operational and organisational level on which DEVCO is 
gathering  data  and  reporting  since  2016.  See  https://ec.europa.eu/europeaid/sites/devco/files/swd-2015-80-f1-
staff-working-paper-v3-p1-805238_en_0.pdf. 

13 

 
 
 
                                                 
2015 

2014 

of which  
umbrella 

Table 2 -ENI 2014-2017commitments(as of July 2017) 
Country/ 
Programme 
South 
Algeria 
Egypt 
Israel 
Jordan 
Lebanon  
Libya 
Morocco 
Palestine 
Syrian crisis * 
Tunisia  
Reg. & other  
multi-country  
Africa TF ** 

26,3 
115,0 
-  
174,5 
143,3 
8,0 
218,0 
307,5 
61,3 
169,0 

25,0 
105,0 
2,0 
100,0 
40,0 
3,0 
210,0 
325,3 
409,0 
186,8 

15,0 
15,0 

196,4 

229,1 

50,0 

20,0 

of which 
umbrella 

2016 

of which 
umbrella 

2017 
indicative 

Country/ 
Programme 

2014 

2015 

2016 

ENI + ENPI 2014-2016 payments   

25,0 
105,0 
1,8 
80,0 
40,0 
10,0 
190,0 
290,0 
170,0 
213,5 

126,0 

55,0 

30,0 

71,8 

80,5 

30,0 
100,0 
1,8 
88,0 
44,0 
12,5 
189,5 
310,0 
201,0 
300,0 

181,0 

139,0 

Algeria 
Egypt 
Israel 
Jordan 
Lebanon  
Libya 
Morocco 
Palestine 
Syrian crisis*** 
Tunisia  
Reg. & other 
 multi-country  

33,0 
91,1 
4,4 
56,3 
78,2 
11,0 
76,2 
303,2 
2,0 
178,5 

33,2 
64,6 
6,6 
101,3 
100,3 
7,7 
134,5 
317,5 
35,1 
142,0 

92,8 

118,9 

42,2 
93,2 
4,2 
148,4 
66,9 
6,2 
224,0 
330,6 
78,6 
108,2 

173,9 

30 

Total ENI South 

1.452,0 

100  

1.602,5 

101,8  

1.306,3 

80,5  

1.596,8  

Total ENI South 

926,8 

1.061,8 

1.306,4 

EAST 
Armenia 
Azerbaijan*  
Belarus 
Georgia 
Moldova 
Ukraine  
Reg. & other 
 multi-country 

34,0 
21,0 
19,0 
131,0 
131,0 
242,0 

152,4 

30,0 
14,5 
14,5 
100,0 
90,0 
200,0 

150,1 

28,0 
13,5 
29,0 
110,0 
89,0 
200,0 

144,5 

10,0 

90,0 

30,0 
30,0 
40,0 

21,0 

92,0 

28,0 
19,1 
29,0 
110,0 
89,0 
200,0 

144,5 

Armenia 
Azerbaijan 
Belarus 
Georgia 
Moldova 
Ukraine  
Reg. & other 
 multi-country 

23,2 
6,8 
22,3 
41,1 
93,7 
314,1 

47,0  

36,7 
22,1 
17,9 
71,9 
42,2 
80,0 

88,8 

49,2 
21,5 
23,7 
96,4 
82,8 
206,2 

111,0 

Total ENI East 

730,4 

100  

599,1 

100  

614,0 

113  

619,6 

Total ENI East 

548,1  

359,6 

590,8 

TOTAL ENI 
* including ENI contribution to the EU Madad fund   ** ENI contribution to the EU Africa TF ***excluding TF payments 

  2201,6 

 2182.4 

 1920,3 

 2189,4 

 201,8 

 193,5 

200  

1.623,2  

1.573,2  

2078,00 

14 

 
  
  
  
 
  
  
 
 
 
 
 
 
  
  
  
 
  
  
  
 
  
  
  
 
  
  
 
  
  
 
  
  
  
 
  
 
  
  
  
 
  
  
  
 
 
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
 
  
  
  
 
  
  
  
 
 
  
  
 
 
  
  
  
 
 
 
 
5. Answers to the evaluation questions 

Evaluation Question 1: Relevance  
To what extent do the overall and the specific objectives and the design23 of the ENI respond 
to: (i) EU priorities and beneficiary needs identified at the time the instrument was adopted 
(2014)?; (ii) Current EU priorities, in particular emerging from the 2015 ENP Review such 
as  stabilisation,  and  beneficiary  needs,  given  the  evolving  challenges  and  priorities  in  the 
international context (2017)?  

Overall, the ENI instrument appeared fit for purpose at the moment it was set out, properly 
addressing the most significant needs identified, in line with the policy framework set out by 
the revised European Neighbourhood Policy (ENP) and as  such  it ensured credibility  to  the 
EU's intention to deepen political cooperation and pursue gradual economic integration with 
its neighbours. 

The relevance of the ENI instrument remains rooted in the existence of an EU policy for its 
neighbourhood. This is reflected in the Treaty (Article 8: "The Union shall develop a special 
relationship  with  neighbouring  countries")  which  calls  for  a  special  relation  with  the 
neighbours, and in the strong political will of EU member States to have a dedicated policy 
for  the  European  Neighbourhood  and  related  instruments.  The  Council  conclusions  on  the 
ENP  of  2015  are  quite  clear  in  that  respect  ("Underlining  the  importance  of  a  special 
relationship  with  the  EU's  neighbours,  the  stabilisation  of  the  neighbourhood  in  political, 
economic and security terms will be the main political priority for the EU in the next years").  

During  the public consultation launched  in  2015 on the occasion  of the review of the ENP, 
many stakeholders reaffirmed that the EU must have a special and more effective relationship 
with its neighbours with dedicated tools24. Most ENP partners with only a few exceptions – 
and not taking into account those countries that are at war like Syria – want to build special 
relations with the European Union. On its part, the EU has very strong interest to engage in 
special relations with neighbours also in order to promote and defend EU values and common 
interests. This is key for building resilience in the neighbourhood. The ENI is only part of a 
wider set of tools to ensure that the EU delivers on the commitment of Article 8 of the Treaty.  

The EU priorities with regard to the European Neighbourhood Instrument (ENI) stem from its 
policy framework, as defined in Article 3(1), and are not set out in a single specific document 
but rather in a set of bilateral agreements, Communications, conclusions and declarations of 
EU institutions (European Parliament and Council).  

Though  the  strategic  framework  is  complex  and  defined  by  a  plurality  of  documents  (as 
pointed out by the external evaluators, who consider that this complex set somewhat hinders 
(its) clear understanding and visibility25), the Commission services consider that the strategic 
framework for the implementation of the ENI is clearly set out in the recently adopted Global 
Strategy  for  the  EU's  Foreign  and  Security  Policy  26  (and  its  predecessor,  the  2003  EU 

23 i.e. how it all fits together. 
24 Joint Staff Working Document "Towards a new European Neighbourhood Policy". SWD (2015) 500 final of 
18.11.2015 
25 Page. 3 of the evaluation report. 
26 http://europa.eu/globalstrategy/ 

15 

 
 
                                                 
Security  Strategy 27 )  and  the  2015  Joint  Communication  on  the  review  of  the  European 
Neighbourhood  Policy28.  However,  what  is  somewhat  missing  is  a  clear  description  about 
how the EU intends to mobilise its various instruments in complement of the ENI. Though the 
articulation between geographic and thematic instruments makes sense in principle, the lack 
of  clear,  operational  document  explaining  the  articulation  of  all  EU  instruments  makes  it 
complicated for beneficiaries and external stakeholders to easily grasp it. That being said, the 
ENI  is  the  main  financial  instrument  to  support  partners  in  the  region  with  grants,  and  the 
existence  of  other  much  smaller  instruments  provides  a  broader  range  of  available  tools, 
allows  for  greater  flexibility  and  is  thus  serving  the  principle  of  differentiation,  as  also 
acknowledged  by  the  external  evaluators29,  though  several  interventions  for  human  rights 
actions,  for  security,  for  the  promotion  of  EU  interests  were  also  funded  from  ENI,  from 
which the large majority of financial resources was coming30. 

The  objectives  (Article  1)  and  thematic  priorities  (Article  2)  of  the  ENI  Regulation  are 
congruent with the six core pillars of the ENP as laid out in the 2011 Joint Communication on 
the  ENP  “A  new  response  to  a  Changing  Neighbourhood”31.  The  latter  is  the  main  policy 
document that framed the preparation of the ENI Regulation. Even after the adoption of the 
ENP Review in November 201532, the broad and comprehensive nature of priorities listed in 
the  ENI  Regulation,  as  well  as  the  framework  for  programming  and  implementation,  has 
allowed  the  EU  to  respond  to  new  priorities.  As  a  result,  the  Regulation  ensures  the 
responsiveness of the ENI to the challenges of the Neighbourhood in line with ENP priorities, 
which has been a proof of flexibility. 

The  EU  has  responded  to  considerable  challenges  in  the  neighbourhood  since  2014,  in 
particular  to  the  consequences  of  the  Syrian  Crisis,  the  illegal  annexation  of  the  Crimean 
peninsula by Russia and the conflict in eastern Ukraine, civil war in Libya, the emergence of 
the  Islamic  State,  and  high  youth  unemployment  in  most  partner  countries  fuelling 
resentment,  disenfranchisement  and  pressures  to  migrate  towards  Europe.  The  response 
capacity, budget and flexibility of the ENI instrument has been stretched to its limits. In fact, 
external evaluators33 and a few stakeholders34 have considered that the response brought under 
the ENI has not been proportionate to the needs and challenges.  

Commission  services  agree  that  facing  the  challenges  in  the  neighbourhood  now  and  in  the 
future (e.g. reconstruction of war-torn regions in Ukraine and Syria, state building in Libya, 
tackling rising inequalities in most countries, pressing demographics in Egypt and Palestine, 
boosting  sustainable  and  inclusive  growth  in  the  partner  countries)  requires  increased  EU 

27 https://europa.eu/globalstrategy/en/european-security-strategy-secure-europe-better-world 
28https://ec.europa.eu/neighbourhood-enlargement/sites/near/files/neighbourhood/pdf/key-
documents/151118_joint-communication_review-of-the-enp_en.pdf 
29  “An  example  of  this  coherence  is  that  EIDHR  should  focus  on  civil  society  action,  while  geographic 
instruments should support projects undertaken by national governments”, Evaluation report, vol. II, page 324. 
30  The  external  evaluation  reports  also  refers  to  the  fact  that  "there  have  been  cases  where  ENI  country 
programming does not always reflect sufficiently priorities indicated under other instruments or policy issues of 
high importance to other line DGs (e.g. the SSFs of Lebanon and Jordan did not consider migration even though 
it is a focal area of DCI and also several DGs (HOME, ECHO). When the Syrian crisis led to a massive influx of 
refugees to this country, this lack of consistency became problematic)” Evaluation report, vol. II, par. 5.3.2, page 
289. 
31 COM(2011) 303 of 25 May 2011 
32 JOIN (2015) 50 final of 18 November 2015 
33 See evaluation report, page 30. 
34 See Annex 3. 

16 

 
 
                                                 
political  and  financial  investment  as  well  as  leveraging  additional  funding,  including  by 
further  enhancing  cooperation  with  major  Financial  Institutions  and  participation  of  the 
private sector though blending facility and guarantees.  

Despite  the  numerous  efforts  to  adapt  to  circumstances,  the  ENI  instrument  was  not 
specifically conceived to contribute to crisis prevention, thus enhancing broad EU interests (as 
pointed  out  by  external  evaluators).  This  would  require  that  strategy  and  programming 
documents, which do not usually include a risk assessment analysis that goes beyond projects 
or sectors35, include geostrategic analyses (both conflict analysis and early warning) aiming at 
identifying  and  anticipating  possible  discontinuities,  social/political  changes  and  risk  of 
conflict,  better  assessing  the  potential  for  violent  and  radical  changes  in  the  neighbourhood 
countries and ensuring early  and coherent EU action.  Currently,  these documents which are 
shared with the partner governments broadly reflect the political status quo. 

In countries where budget support is deployed, a detailed country risk assessment is compiled 
and updated every year based on a list of pre-defined criteria which allow comparison to be 
made  over  the  years  for  a  particular  country  and  also  among  different  countries.  The 
Commission  services  acknowledge  that  interventions  on  the  ground  shall  be  based  on  good 
anticipation  of  possible  developments.  Nevertheless,  some  of 
the 
neighbourhood  in  2011-2015  were  radical  and  violent,  and  challenging  for  all  development 
actors  present  on  the  ground.  In  such  difficult  circumstances  the  implementation  of  the 
instrument was flexible and the Commission adjusted the financial allocations in accordance 
with the scope of the challenges36.  

the  changes 

in 

Nevertheless,  the Commission  services  acknowledge  that linkages between  the political  and 
geopolitical risk analysis already conducted within the EU institutions (notably in the EEAS) 
and the services in charge of programming financial assistance under ENI were not adequate. 
An  integrated,  comprehensive  approach  was  not  in  place  and  human  rights  and  gender  are 
crucial  in  this  context  as  well.  Moreover  the  analysis  of  agents  and  factors  of  changes  in 
programming  documents  was  not  adequately  developed.  The  Commission  services  do  not 
consider that there is a need however to set a specific component on crisis prevention under 
the  ENI,  nor  to  create  dedicated  structures  to  crisis-stricken  countries.  Many  of the  existing 
interventions by ENI and other instruments (in particular the IcSP) are already contributing to 
crisis prevention (e.g. providing budget support and macro financial assistance to Tunisia in 
2014-15  helped  prevent  macroeconomic  crisis).  Rather,  flexibility,  though  present,  was 
probably not sufficient, and the necessary synergies with the instrument contributing to peace 
and stability which works on crisis prevention were not sufficiently developed.  

The ENI Regulation sets out solid foundations for enhanced alignment with EU and partners’ 
needs  and  priorities,  which  was  emphasised  by  the  ENP  Review  in  2015.  In  comparison  to 
ENPI,  the  ENI  strengthened  the  principle  of  differentiation  and  the  focus  on  country 
ownership and civil society37. As evidenced by face to face consultations, partners value this 
principle38. With the exception of the magnitude, the ENI interventions look in general well in 
line with on-going challenges, emerging needs and limited capacities/political will for reform 
in  most  of  the  ENI  partner  countries.  Policy  dialogue  is  an  inherent  feature  of  the  ENI 

35 See evaluation report, page 3. 
36 "In  total,  12.5%  of  the  total  value  of  ENI  commitments  were  either  reallocated  or  added  after  the  initial 
allocations had been made in 2014", Evaluation report, vol. 2, par. 12.2.5, page 71. 
37 This principle is clearly stated in the ENP review. 
38 Evaluation report, vol. 3, Face to face consultation. 

17 

 
 
                                                 
framework  that  is  implemented,  thus  ensuring  that  strategy  and  programming  documents  as 
well as ENI programmes are aligned to  the priorities of partner countries’ governments  and 
their citizens' needs (especially through the inclusion of civil society representatives).  

Evaluation Question 2:  Effectiveness, impact, sustainability 
To what extent does the ENI deliver results against the instrument's objectives, and specific 
EU priorities? 

It is still too early to assess with absolute certainty the effectiveness, impact and sustainability 
of the instrument given the short period of implementation39. Only some strategic, high level 
indicators40 can  give  an  initial  evidence  of  whether  or  not  the  countries  are  moving  in  the 
expected  direction,  knowing  that  the  EU  can  only  indirectly  influence  their  evolution. 
However,  considering  the  continuity  of  interventions  from  the  previous  instrument 41,  and 
despite the negative impact of exogenous factors (Arab Spring, wars, refugee crisis, economic 
slowdown in Europe), significant reforms were accompanied and progress was registered in 
those countries that were willing to engage in a reform process and in those areas where there 
was  ownership  by  the  national  authorities  and  the  external  conditions  were  conducive.  For 
example,  there  has  been  a  clear  trend  of  improved    business  environment  in  some 
Neighbourhood East partners such as Georgia; Jordan has demonstrated economic resilience 
despite the huge strains from the Iraq war and refuges crisis, notably through budget support 
grants  provided  by  the  ENI  and  loans  under  the  EU  macro-financial  assistance;  important 
public administration reform programmes in Georgia, Morocco and Ukraine supported by the 
EU have allowed improved service delivery and public financial management42; Tunisia has 
made progress in its democratic transition with hugely improved press freedom and voice and 
accountability.  This  can  be  shown  by  some  international  indicators  in  the  table  below  (in 
green cases of significant improvement; in red cases of significant deterioration). 

Table 3 – Evolution of selected indicators in some countries 

Indicators 

Region/Country 

2010 

2013 

2016 

Distance to frontier (WB) (range 1-100) 

N East 
Georgia 
Moldova 
Ukraine 
N South 
Morocco 

59.73 
76.61 
59.21 
44.21 
58.64 
60.04 

67.19 
82.09 
32.26 
58.14 
56.97 
64.38 

72.10 
80.20 
72.75 
63.90 
54.69 
67.50 

39 One of the contributors to the OPC says that "Results are limited, especially as it seems that the ENI was not 
ready  to  address  major  crisis  happening  relatively  suddenly:  the  instrument,  while  flexible,  lacks  in  terms  of 
preparation, forecasting and situation assessment", Evaluation report, Annex, 3, Summary of OPC contribution, 
Question 1. 
40  Examples  of  these  indicators  are  those  related  to  the  business  environment  (Doing  Business),  political 
stability, rule law, regulatory quality, press freedom, mentioned in the  table below,  
41 Which is still under implementation, and for which no ex-post evaluation has taken place. 
42 With regard to Georgia, the PEFA report issued in 2013 (concluded that "Georgia has advanced significantly 
its budgetary and financial managements systems since the previous PEFA assessment Report of 2008" (page 8),  
getting an A rating on 65% of sub areas assessed by the report, being very highly rated on areas like transparency 
and budget classification.  In the case of Morocco, the comparison between the 2009 and 2016 PEFA 
demonstrated an improvement in many areas, with a 17% increase of indicators with an A or B score. 

18 

 
 
 
 
 
 
 
 
                                                 
World Competitiveness Index (WEF) (range 1-7) 

Jordan 

57.17 

57.88 

57.30 

N East 
Georgia 
N South 
Morocco 

4 
3.8 
4.1 
4.1 

4.1 
4.1 
4.2 
4.1 

4.2 
4.32 
4.1 
4.2 

Corruption perception index (Transparency International) (range 1-100) 

N East 
Georgia 
N South 

Regulatory Quality (WB) (range 1-100) 

N East 
Georgia 
N South 

2.8* 
3.8* 
3.5* 

43.04 
65.05 
44.50 

33.7 
49 
34.7 

43.30 
73.68 
36.04 

Press Freedom (Reporters without Borders (range 100-1)$ 

39 
50.2 
72.5 

N East 
N South 
Tunisia 
Voice and Accountability (WB) (range 1-100) 
N East 
Georgia 
N South 
Tunisia 

29.94 
42.18 
22.96 
9.95 

38.7 
37.4 
39.93 

30.49 
54.50 
29.02 
44.08 

36.8 
57 
34.8 

48.48 
81.25 
32.59 

38.5 
46.1 
31.6 

32.51 
53.69 
29.50 
56.65  

*: For this year the range was 1-10. 
$: For this indicator a decrease in the score means an improvement.  

Recent reports from the European Court of Auditors for the operations in Tunisia and Ukraine 
have demonstrated that EU actions under ENI and its predecessor ENPI were effective43. On 
the  economic  governance  side,  also  the  recently-concluded  evaluation  is  rather  positive 
regarding interventions in Georgia and Morocco notably on Public Financial Management44. 
The strategic evaluation on Azerbaijan, currently in its final stage, tends to conclude in very 
positive terms about the role played by EU assistance in enabling the country to approximate 
the EU acquis, especially thanks to the twinning and TAIEX instruments. This is also one of 

43 The  special  report  of  the  European  Court  of  Auditors  on  Tunisia  (n.  3,  2017  confirms  that  "the  money  was 
generally  well  spent  as  it  contributed  significantly  to  the  democratic  transition  and  the  economic  stability  of 
Tunisia  after  the  revolution".  It  also  stated  that  "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." 
(page 6). 
The  special  report  of  Ukraine  (n.  32,  2016)  concludes  that  in  the  wake  of  the  Maidan  events  in  2014  "EU 
assistance  to  Ukraine  has  been  partially  effective  in  supporting  the  transformation  of  Ukraine  into  a  well 
governed state" (page 7). Overall, the report recognises the capacity of the EU to substantially increase the level 
of  financial  support  to  the  country,  also  thanks  to  budget  support  and  macro-financial  assistance,  while 
improving  the  policy  dialogue.  Steps  forward  were  taken  in  critical/strategic  areas,  like  public  administration 
reform  and  energy,  though  "the  economic  and  geopolitical  challenges  faced  by  Ukraine  heavily  affect 
government priorities and the activities of the public services" (page 14). 
44 

In  visited  stable  countries  (Georgia,  Morocco),  "their  macro  fiscal  balances  have  been  stable,  governance 
indicators improving in time together with/and growth outcomes (employment and leaving standards) paving the 
way for further improvement of EG in general. Nevertheless, in countries in transition or affected from external 
shocks (Tunisia, Ukraine, Egypt and somehow Jordan), the interventions have been partially effective with the 
best positive outcomes in governance matters and mixed (positive and negative) outcomes in employment and 
unemployment levels" (page 11).

19 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
 
the conclusions of the strategic evaluation on Jordan45, which also notes that the EU, together 
with other actors, instigated, through its policy dialogue, significant reforms in the energy and 
social  protection  sector.  Overall,  many  of  the  above-mentioned  evaluations  point  to  the 
distinct  EU  contribution  on  institutional  strengthening.  Also,  Cross  Border  Cooperation 
programmes have  had a positive impact  on people to people contract  and good neighbourly 
relations between EU regions and those of neighbourhood countries, although they have had 
less impact on stability and security at the border46. 

However,  in  countries  where  there  is  no  strong  political  commitment  to  comprehensive 
reforms or the willingness to have closer relations with the EU, the effectiveness of the ENPI 
and the ENI has been less strong. 

Since  2014,  progress  of  the  Neighbourhood  countries  regarding  respect  of  EU  fundamental 
values  has  been  uneven.  In  the  field  of  human  rights,  democracy  and  governance,  the 
Commission  has  targeted  activities  that  are  relevant  and  important,  but  the  countries  and 
regional contexts have made it difficult to pursue comprehensive support strategies and hence 
impeded  the  achievement  of  significant  results.  While  the  Results  Oriented  Monitoring 
(ROM) Annual report (2014) on the ENI47 estimates that actions under the ENI and the ENPI 
have effectively delivered well targeted outputs of good technical quality in the field of rule of 
law  and  good  governance  (e.g.  by  strengthening  civil  society  in  various  countries),  the 
prospects  for  sustainability  are  limited  in  several  countries.  The  unfavourable  political 
environment (look at the previous table) in most Neighbourhood countries remains the main 
cause.  Nevertheless,  limited  improvements  and  success  stories  exist  in  specific  contexts  or 
areas48.  For  example,  Ukraine  made  significant  steps  forwards  with  reforms  in  the  areas  of 
anti-corruption, public procurement and public administration. 

In  the  context  of  the  EU  efforts  at  promoting  deep  and  sustainable  democracy  (one  of  the 
objective of the ENI), the incentive-based approach has been partly successful49. Indeed, first 
of all, it is already the case that those partners most keen to establish a close relation with the 
EU  are  offered  more  developed  incentives  (e.g.  Association  Agreement  -  AA/Deep  and 
Comprehensive Free Trade Agreement - DCFTA) for three partners in the East and two in the 
South,  access to  EU programmes,  visa  facilitation or  liberalisation agreements  in  place, etc. 
Second, the existing mechanism has been effective in supporting partners that had committed 
to  reforms,  most  notably  Ukraine,  Tunisia,  and  Georgia.  This  has  allowed  for  example  to 
double  the  annual  allocation  to  Tunisia  at  a  critical  moment  to  support  the  transition  of  the 
country and to substantially increase the support to Ukraine’s political and economic reforms 
after the illegal annexation of the Crimean peninsula and the conflict in the eastern part of the 

45 Evaluation  of  the  EU's  cooperation  with  the  Hashemite  Kingdom  of  Jordan,  February  2015,  available  at 
https://ec.europa.eu/europeaid/sites/devco/files/strategic-evaluation-cooperation-ec-jordan-1340-main-report-
201502_en.pdf 
46 Ex-post Evaluation of 2007-2013 ENPI CBC Programmes; draft Desk report; July 2017. 
47 These reports remain internal to the Commission. 
48 Six out of 12 countries report improvement in the rule of law and better governance (Algeria, Jordan, Ukraine, 
Morocco,  Georgia  and  Armenia),  and  in  the  areas  of  human  rights  (Algeria,  Jordan,  Morocco,  Palestine, 
Moldova  and  Georgia),  sub-regional  cooperation  (Jordan,  Belarus,  Georgia,  Egypt,  Moldova  and  Azerbaijan) 
and management of mobility of people and of legal migration (Jordan, Ukraine, Morocco, Georgia, Moldova and 
Azerbaijan).  Five  countries  refer  to  an  improvement  in  the  management  of  irregular  migration  (Morocco, 
Belarus,  Georgia,  Moldova  and  Azerbaijan)  and  only  3  countries  see  progress  in  CBC  cooperation  (Belarus, 
Moldova and Armenia) – Evaluation report, vol. 2, page 81 and page 347.  
49 Page viii of the evaluation report and Annex 3. 

20 

 
 
                                                 
country  (in  line  with  the  expectations  of  the  impact  assessment 50 on  the  greater  need  for 
flexibility). This support has allowed effective macroeconomic stabilisation in these partners 
and/or avoiding economic recessions51. For example, after the large recession in 2014-2015 in 
Ukraine,  growth  rebounded  to  more  than  2%  in  2016  and  international  reserves  doubled 
thanks in particular to the large EU and international support package (including ENI grants 
and loans from the macro-financial assistance instrument)52. Thirdly, the existing provisions 
of  the  incentives-based  approach  (the  umbrella  programmes  and  the  ranges  mechanism) 
ensure that EU interests and values are taken into consideration in the allocation mechanism. 
However,  it  should  be  noted  that  the  incentive  in  form  of  additional  umbrella  funds  has 
limited  impact  on  reform  processes  in  partner  countries,  and  that  providing  indicative 
allocations  in  form  of  ranges  is  perceived  as  misleading  by  some  partner  countries.  As 
mentioned in the external evaluation report, "the mechanism has allowed extending the scope 
of  reforms  already  agreed  but  hardly  incentivised  partner  countries  for  more  or  deeper 
reforms"53.  

The  results  of  ENI  sector  programmes  and  associated  policy  dialogue  considerably  differ 
between countries and within countries. Good preparation, political and sectoral commitment 
to reforms, administrative capacities and the mobilisation of national resources are key factors 
of  success;  when  these  conditions  are  not  met,  the  ENI  programmes  cannot  reach  intended 
objectives. This also explains why the mix of implementation modalities has been adjusted to 
the absorption capacity, Public Financial Management discipline and sector priorities of each 
country.  The  choice  of  implementation  modalities  is  strongly  linked  to  the  EU  response  to 
partners' needs and priorities. On the positive side, ENI actions have been readily available to 
support the dialogue and identified reforms with the Eastern partnership framework, leading, 
among others, to the identification of 20 very concrete deliverables to be achieved by 2020 in 
the four priority areas identified at the Riga Summit.54 

Few  ENI  programmes  have  already  been  implemented  on  the  ground.  Most  programmes 
launched  so  far  inevitably  do  not  yet  fully  address  the  latest  EU  priorities  (as  stated  by  the 
ENP Review of late 2015) and still focus mainly on addressing the long-term root causes of 
migration  and  poverty,  although  there  are  notable  exceptions  (e.g.  the  large  budget  support 
operations  for  Ukraine  and  Tunisia  that  were  targeted  at  the  stabilisation  of  the  economic 
situation  of  these  two  important  partners).  Newly  designed  ENI  programmes  (but  not  yet 
implemented) focus more on the new orientations of the revised ENP. The most recent project 
formulations  address  ‘EU  policy  priorities’  adopted  by  the  2015  ENP  Review,  recent 
communications  on  security,  migration,  resilience  and  the  Global  Strategy  for  the  EU's 
Foreign  and  Security  Policy  inter  alia  through  the  integrated  approach  in  order  to  address 
crises.  To  note,  the  adopted  Partnership  Priorities  for  Lebanon  and  Jordan,  and  those  in 
preparation  for  Algeria,  Armenia,  Azerbaijan,  Belarus  and  Egypt  indicate  the  new  way 
forward.  

Addressing  the  refugee  crisis  through  the  flexible  use  of  resources  coming  from  the  ENI, 
other EU instruments (such as the Instrument for Pre-accession Assistance and Humanitarian 

50 COM 2011 839 (final), 07/12/2011. 
51 Jordan has continued growing at rates above 2% and is substantially decreasing the fiscal deficit, despite the 
difficult regional environment; IMF expects Tunisia to grow at 2.5% in 2017 and Ukraine at 2% in 2017. 
52 IMF Article IV consultation with Ukraine, April 2017. 
53 Evaluation report, vol. 1, par. 4.3. 
54
(2017)300 
enlargement/sites/near/files/eap_20_deliverables_for_2020.pdf 

https://ec.europa.eu/neighbourhood-

9.06.2017 

SWD 

of 

21 

 
 
                                                 
Aid), and EU Member States by means of their contributions to the Trust Funds55 has had a 
positive impact in reducing the flow of refugees in Europe and the associated tensions with 
unmanaged  flows.  The  continuous  flow  of  refugees  on  the  central  Mediterranean  migration 
route demonstrates however that the scale of the EU response so far does not match the scale 
of the problem in countries of transit or origin56. 

The preparation and implementation of ENPI/ENI programmes is extensively used to sustain 
a strong policy dialogue. According to the external evaluators, the comparative advantage of 
the  EU  in  this  field  is  fully  acknowledged  by  the  partner  countries,  EU  Member  States  and 
other  donors57.  The  degree  of  leadership  of  the  partner  country  in  the  dialogue  varies  and 
depends on the expertise and the coordination capacity of the governmental body in charge of 
international cooperation. Reported progress is of different quality in each country and even 
across sectors in a single country. In this context, chronic political instability, tensions in the 
relations with the EU and weakening administrative capacity in some partner countries since 
2011  have  hampered  the  likelihood  of  ENI  programmes  to  reach  their  objectives.  This  has 
been for example the case in countries such as Moldova and Egypt. 

Though  several  countries  in  the  Eastern  Neighbourhood  have  significantly  improved  their 
performance  recently  including  through  strong  EU  support  and  conditionality,  the  ENI 
countries remain among those with a relatively poor business environment, in particular in the 
South58, Over the last decade, and through support provided by the ENPI and ENI, the EU has 
contributed  to  a  significant  extent  to  increased  trade  potential  within  the  Southern 
Neighbourhood59, and between the Neighbourhood countries and the EU60, though increase in 
trade flows within each sub region has been limited in both Neighbourhood regions.  

In both regions, limited available information as well as the parallel support of many donors 
does not permit for explicitly linking EU financed projects to economic progress or resilience. 
Moreover, as most of them are middle-income countries, the specific contribution of the ENI 
actions is difficult to measure against national public policies. However, as shown in the table 
3  ,  it  is  likely  that,  in  the  absence  of  particular  shocks,  the  continuous  financial  support 
provided under the ENPI and now the ENI, associated with the ongoing policy dialogue have 
contributed  to  improve  the  enabling  environment  and  to  some  significant  results  in  some 
partner countries (e.g. Georgia, Tunisia, and Morocco).  

55 They  represent  a  way  by  which  funds  coming  from  different  sources  are  pooled  together  and  managed  in  a 
more flexible way by the Commission, enabled by art. 4.1 of the Common Implementing Regulation. 
56 " The protracted crisis with the steady increase of refugees requires an additional and urgent effort to address 
the recent developments and especially the growing tensions in the social fabric."  Evaluation report, vol. 2, par. 
1.2.4. 
57 Page 10 of the Evaluation report. 
58 According  to  the  World  Bank  Doing  Business  report  the  distance  to  frontier  indicator,  representing  the 
distance  vis-à-vis  the  best  performing  country  in  terms  of  business  environment,  declined  from  58.64  for  the 
Neighbourhood South in 2010, just before the Arab Spring, to 54.69 in 2016; for the Neighbourhood East, on the 
contrary, the indicator improved from 59.73 in 2010 to 72.10 in 2016 
59 Indeed, the commitments taken within the Association Agreements led to a gradual reduction of tariff barriers 
and  to  substantial  investments  made  in  the  areas  of  standards  and  quality  controls.  In  the  period  2010-2014 
exports  form  Neighbourhood  South  countries  to  the  EU  (excluding  Syria  and  Libya)  increased  from  76  to  95 
billion dollars despite the economic crisis (see also Evaluation report, vol. 2, pages 111-112).  
60 Evaluation  of  the  EU's  support  to  two  European  Neighbourhood  Policy  regions  –  June  2013,  available  at 
https://ec.europa.eu/europeaid/strategic-evaluation-eu-cooperation-east-and-south-enpi-regions-2004-2010_en 

22 

 
 
                                                 
EU  cross  cutting  priorities  (including  fundamental  rights,  gender  equality,  climate  change) 
have been unevenly implemented, with difficulties where they are not seen as priorities by the 
partners (although there are exceptions such as the continuous work in Morocco on Gender61 
or on democracy building in Tunisia62). 

Evaluation Question 3: Efficiency 
To what extent is the ENI delivering efficiently? 

The  ENI  is  delivering  aid  efficiently  in  terms  of  procedures,  processes  and  the  ratio  of 
administrative costs63. Financial control systems are in place and are effective at all levels64, 
and  monitoring  and  evaluation  systems  at  project  and  at  country  level  provide  the  required 
feedback  on  implementation.  Financial  management  procedures  have  been  largely  kept 
identical  to  the  ENPI,  reducing  the  disruption  and  loss  of  efficiency  associated  to  major 
changes.  Often  ENI  programmes  continue  directly  on  the  achievements  made  by  the  ENPI, 
for  example  the  ENI  Cross  Border  Cooperation  programmes.  One  additional  step  that  has 
been introduced in the multi-annual programming process, is the strategic dialogue with the 
European Parliament before the finalisation of multi-annual programming documents, which 
adds several weeks to the programming process.  This represents a step forward in terms of 
transparency and inclusiveness, but clearly negatively impacts on efficiency. 

The features of the ENI Regulation and the CIR have allowed flexibility – something in line 
with  the impact assessment and valued both by the external evaluators and the stakeholders 
consulted,  though  with  diverging  views 65 -  and  offered  new  opportunities  to  achieve  the 
policy objectives. However, the EU Budget Financial Regulation, the Common Implementing 
Regulation (CIR) and the Commission administrative procedures and practices have prevailed 
over  simplification  efforts,  leaving  the  regulatory  burden  unchanged66;  this  has  undermined 
reaching one of the objectives of the ENI impact assessment. The cumbersome administrative 
procedures  make  it  difficult  for  smaller  civil  society  organisations  and  social  partner 
organisations  (trade  unions  and  employers'  organisations)  to  get  involved  in  project 
implementation67 or may distract from the core business of the association68. 

In the case of cross border cooperation (CBC), the simplification of implementation rules was 
an important objective; a recent survey of programmes authorities managing CBC operations 
show that the ENI rules have brought an improvement compared to the previous ENPI rules69, 
as expected by the impact assessment. 

61 A first EUR 48 million support programme was financed under the ENPI in 2011 and a second one of EU 35 
million is tentatively planned for the annual action plan of 2017. Both programmes have a large budget support 
component. 
62 JC 21, indicator 211, page 79 Volume 2 of the Evaluation report 
63 Indeed,  administrative  costs  represented  in  2015  2%  of  the  committed  amounts.  This  percentage  becomes 
3.1% looking at actual expenditures. Overstretched human resources, on the one side, use of national systems, 
while using budget support, explain this overall positive figure.  See evaluation report, Annex 2, page 141. 
64 Par. 3.1.2 in Evaluation report, vol. 2, elaborates more on the controls performed. 
65 Evaluation report, vol. 2, par. 1.2.2, and vol. 3, OPC, Question 3. 
66 See evaluation report, page 16. 
67 Evaluation report, vol. 3, par. 5.5.1;  

68 See N. Cherif, " Improving Foreign Support to Tunisia’s Civil Society", C·A·Perspectives 

on Tunisia No. 07-2017. 
69 Ex-post Evaluation of 2007-2013 ENPI CBC Programmes; draft Desk report; July 2017. 

23 

 
 
                                                 
Under  the  ENI  Regulation  no  significant  changes  occurred  in  the  time  span  required  to 
finalise a decision (the benchmark is set to 47 weeks for multi-annual programming, despite 
the  four  weeks  added  by  the  Strategic  Dialogue  with  the  European  Parliament  before 
finalisation  of  the  programming  documents)  and  for  the  various  steps  of  implementation 
(formulation,  financial  agreement,  contracting).  ).  However,  some  partner  countries  still 
complain  that  the  process  is  too  long  and  bureaucratic  and  that  it  is  difficult  to  see  a  link 
between  a  programming  mission,  when  consultations  with  partner  countries  authorities  take 
place,  and  beginning  of  implementation.  However,  EU  Delegations  indicated  that  the  time 
span for decision-making is improving70, as expected under the Impact Assessment. 

Special measures71 made possible by the Financing Regulation and the CIR are contributing 
to the ENI’s efficiency in delivery by accelerating the implementation process for unforeseen 
needs. The recourse to special measures (used notably in the case of Ukraine to respond to the 
2014  event)  does  provide  flexibility  to  the  EU  response  and  can  help  accelerate  the 
programme preparation process. 

The  external  evaluation  found  that  the  ENI  exhibits  an  adequate  organisational  set-up  and 
high quality in-house expertise which are considered key factors of efficiency in general and 
of cost-efficiency in particular. In the present setting, cost-efficiency of ENI management is 
confirmed  by  an  administrative  cost  ratio  of  2.0%  on  2015  commitments  (2.5%  in  2014). 
However, in the absence of special arrangements (like with the Support Group for Ukraine72, 
or  the  Madad  fund  to  address  the  refugee  crisis),  the  Commission  faced  serious  human 
resources constraints when a strong increase in financial assistance volumes took place (e.g. 
Tunisia). 

In-house  expertise  was  strengthened  with  the  creation  of  Centres  of  Thematic  Expertise 
(CoTE)  which  enhance  coherence  in  formulating  sector  and  thematic  ENI  interventions, 
lessons  of  past  projects  and  best  practices  from  other 
allowing  drawing  on 
countries/regions.  The  expertise  is  focused  on  the  most  important  policy  areas  but  in  some 
cases  internal  capacities  remain  weak.  This  is  compensated  through  closer  interaction  with 
line DGs. 

the 

Budget  support  operations  can  contribute  to  deliver  efficiently  and  rapidly  (as  evidenced  in 
the swift delivery of large operations to Ukraine in 2014 and Tunisia since 2011). However, 
the  strict  eligibility  criteria  linked  to  budget  support,  and  the  time  required  for  the  good 
preparation  of  the  operations,  restrict  the  use  of  this  modality  to  only  a  limited  number  of 
countries which have clear strategies and the strong willingness to implement them. As noted 
by  the  Court  of  Auditors'  special  report  on  EU  assistance  to  Moldova 73 ,  when  the 
Commission's  programmes  are  not  fully  aligned  to  the  national  strategies,  and  when 
conditionality is not interpreted strictly, they reduce the Commission's leverage. 

The setting of +/-10% range in the multi-annual indicative budget is another mechanism used 
– even if not intended –to introduce more flexibility in annual allocations74 among countries. 

70 Evaluation report, page 16. 
71 See evaluation report, vol. 2,  par. 1.2.4, referring to the different special measures taken to address the crisis 
in Ukraine of the refugee crisis in Syria to support Jordan or Lebanon.  
72 See evaluation report Volume 2, page 158 
73 https://www.eca.europa.eu/en/Pages/DocItem.aspx?did=37235. 
74Annual  allocations  per  country  are  a  commission  decision,  as  multiannual  allocations  are  indicative  and 
defined before the adoption of the actual annual budget. 

24 

 
 
                                                 
However, given the multiple developments in a series of countries, both positive or negative, 
and  the  tight  budget,  the  Commission  adjusted  the  initially  planned  indicative  envelopes 
beyond  the  10%  range;  there  were  strong  increase  in  Jordan,  Ukraine  and  Tunisia  (not 
counting umbrella programmes funding) and decrease in Azerbaijan and Algeria for example. 
This  flexibility  has  been  in  line  with  the  objectives  set  out  in  the  impact  assessment  and 
proved useful to respond to fast evolving challenges. 

The monitoring and evaluation (M&E) system for the ENI was not set out at the Regulation 
level, but rather at corporate level, through the EU Results Framework75, and then through the 
normal  programming  and  planning  stage  (Single  Support  Framework  or  Country  Strategy 
Papers and Multi-annual Indicative Programmes/ Annual Action Documents), but cannot rely 
on national systems for assessing results, due to the poor quality of statistics, sometimes, and 
to  a  still  limited  culture  of  monitoring  and  evaluation.  Monitoring  and  reporting  systems 
(including  result-oriented  monitoring;  the  Programme  Statement;  as  well  as  the  Authorising 
Officer  by  Sub-Delegation  and  the  External  Assistance  Management  Reports)  represent  an 
efficient way to inform the Management and steer the work. Projects’ activities are monitored 
in a robust and systematic way at the level of outputs; in the case of CBC programmes, for 
example,  a  number  of  common  output  indicators  have  been  defined  in  order  to  improve 
communication on results. This should enable better reporting in the future as well as future 
evaluation. However, reporting on outcome and long term impact remains embryonic76. This 
is partly due to the lack of relevant indicators, partly to an unclear intervention logic (theory 
of change)77. In 2018, after three pilot years, the Commission will be able to start reporting on 
operational results achieved under the ENI. In addition, a new information management tool 
under development will also focus more on results  reporting and should be  gradually rolled 
out as of 2018. Work has started already at the Commission on defining standardised set of 
result indicators for specific sector interventions (such as for Public Financial Management or 
Public administration reform, thanks to SIGMA). Further work is ongoing in the framework 
of the updating of the EU Results Framework and in the perspective of the implementation of 
a new IT tool (OPSYS) with a dedicated dimension dedicated to results.. 

Evaluation Question 4: Added value 
To  what  extent  do  the  ENI  programmes  add  value  compared  to  interventions  by  Member 
States or other key donors? 

As  an  European  Union  instrument,  the  ENI  is  unique  in  the  sense  that  it  federates  the 
somehow  diverging  interests  of  the  Member  States  around  the  common  objectives  of  the 
European Neighbourhood policy. This is linked to the closeness of the ENI beneficiaries and 
their  direct  influence  on  domestic  issues  (through  migration,  security,  trade).  Through  the 
ENI, the EU common perception of urgency to work with our Neighbours is more vivid than 
ever  even  though  differences  in  means  and  solutions  could  be  debated  on.  This  dynamism 
overcomes  the  traditional  EU  Member  States'  vested  interests  or  historical  links  with 
beneficiary countries.  

75 https://ec.europa.eu/europeaid/sites/devco/files/swd-2015-80-f1-staff-working-paper-v3-p1-805238_en_0.pdf. 
76  See  evaluation  report,  page  21.  See  also  https://ec.europa.eu/europeaid/eu-international-cooperation-and-
development-first-report-selected-results-july-2013-june-2014_en,  for  DEVCO  report  on  results  including  also 
ENI countries. 
77According to an analysis made in the framework of the 127 Results Oriented Monitoring reviews made in the 
region,  in  72%  of  the  cases  in  which  the  projects  were  found  problematic  (meaning  unlikely  to  achieve  the 
expected outcomes), which were 42% of the total) , this was related to the lack of relevant indicators. 

25 

 
 
                                                 
Seen  in  a  broad  context,  there  is  a  positive  EU  added-value  in  ENI  programming  and 
implementation vis-à-vis EU Member States. 

The EU added value can be seen through the ENI’s i) ability to provide substantial funding 
mainly through grants in such cases as the responses to the Syrian Crisis, the stabilisation of 
Ukraine and Tunisia, or the support to reformers such as Georgia and Morocco78, ii) capacity 
to  coordinate  with  other  EU  instruments  and  mobilise  EU  Member  States'  parallel  funding 
along  commonly  agreed  objectives  to  address  everything  from  long-term  to  short-term  and 
emergency  challenges79,  iii)  comparative  advantages  in  mobilising  expertise  suited  for  the 
needs  and  priorities  within  a  framework  consistent  with  EU  and  partner  countries’  mutual 
interests,  and  iv)  political  influence  and  policy  leverage 80 through  dialogue  with  national 
authorities and civil society81. Moreover, various aid modalities (like Twinning and TAIEX, 
enabling  the  mobilisation  of  key  EU  public  expertise)  can  be  used  in  a  coherent  way  and 
adjusted to the partner country’s (absorption) capacity. None of these features can be achieved 
individually by EU Member States.  

Moreover,  the  importance  of  keeping  a  specific  instrument  was  emphasised  by  several 
contributors to the Open Public Consultation82. It is also unique to the EU to actively combine 
regional,  CBC  and  ENI-wide  programmes  to  promote  confidence  building  and  good 
neighbourly83 relations among  countries  on  both  sides  of  the EU  borders and  in  some  cases 
with  the  involvement  of  the  Russian  Federation.  The  combination  of  intervention  types  and 
aid  modalities  is  unique  among  donors,  even  more  so  when  the  ENI  uses  innovative 
instruments  like  blending 84  and  EU  Trust  Funds  to  mobilise  additional  funding  and 
implementation capacities. Trust Funds (the "Madad" fund and the North Africa Window of 
the  EU  Emergency  trust  fund  for  Africa)  are  another  potential  incentive  for  reducing  EU 
Member States aid fragmentation by using their expertise and implementation capacities. To 
date the Madad fund has attracted resources from many EU Member States, although the level 
of  these  contributions  could  be  higher  given  the  magnitude  of  the  challenges  in  the  region. 

78 Since 2014, ENI demonstrated (in particular in relation to Ukraine) a strong capacity to attract unprecedented 
envelops within a coordinated policy framework. Since the 2014 crisis, some EUR 8 billion were made available 
by the EU institutions, in a collective effort coordinated by the Support Group for Ukraine (SGUA).. Evaluation 
report, Annex 2, page 195. 
79 "The capacity for reconciliation and confidence building (sometimes a long term perspective) is reinforced by 
the mix of instruments at the disposal of EUDs to answer contradicting needs and priorities. This flexibility of 
choice  between  instruments  is  not  significant  in  financial  terms  (ENI  provides  on  average  some  90%  of  the 
resources  availed  to  Neighbourhood  partners),  but  is  important  to  keep  a  diversified  portfolio  addressing 
long/short terms needs and conflicting priorities at country level", Evaluation report, Annex 2, page 195.  
80 "Most significant achievements regarding policy reforms were conveyed by budget support preparation and 
implementation.  BS  (state  building  contracts  and  sector  budget  support)  tranche  indicators  provide  a  sound 
framework for assessing progress in the reform agenda. EUDs without a BS have fewer opportunities to engage 
in  policy  dialogue  –  mainly  during  preparation  and  signature  of  multi-annual  programming  or  financing 
agreements." Evaluation report, Annex 2, page 373. 
81 JC 41, Evaluation report page 23 
82 A  public  authority  pointed  out  that  "regardless  of  its  final  form,  there  is  a  need  for  a  separate  financial 
instrument supporting the implementation of the ENP"; also, an organisation expressed the view that "the ENI 
has the potential to contribute to stabilisation in the European Neighbourhood" (Evaluation report, vol. 3, page 
159). 
83  "The  combination  of  regional,  cross-border  and  Neighbourhood-wide  programmes  and  initiatives,  with 
resources  that  –  though  not  sufficient  compared  to  the  felt  needs  of  national  authorities  and  civil  society 
expectations regarding the EU – are proportionate to the objectives of the actions, and is already an EU added-
value in itself.", Evaluation report, Annex 2, page 196. 
84 Blending  is  a  way  by  which  different  sources  of  funding  (grants,  loans,  guarantees),  also  coming  from  the 
private sector, are mobilised to stimulate higher investment funding. 

26 

 
 
                                                 
However,  visibility  of  the  EU  in  such  operations  is  rather  limited;  more  generally,  strategic 
communication  and  visibility  are  areas  where  stakeholders  have  noted  room  for 
improvement85. 

The added value of the EU in enhancing the approximation to its acquis differs according to 
the  ambition  of  partners  in  their  relations  with  the  EU.  Nevertheless,  the  adoption  of  EU 
legislation  and  norms  and  standards  remains  a  key  objective  for  many  partners  and  derive 
from their contractual obligations with the EU (notably those having DCFTAs), but also from 
the interest to improve export perspectives in third countries. For example, the adoption of EU 
sanitary  and  phytosanitary  standards  is  necessary  for  all  countries  to  export  agricultural 
products  to  the  EU,  but  can  also  make  the  products  more  tradable  in  non  EU  countries. 
Approximation to  the acquis is therefore taking place  in the economic area and in  technical 
areas related to Rule of law issues irrespective of the willingness of a country to implement 
more fundamental and critical reforms. This explains the success of the twinning instruments 
also in relatively less open minded governments. 

Evaluation Question 5: Coherence, consistency, complementarity and synergies  
To what extent does the ENI facilitate coherence, consistency, complementarity and synergies 
both internally between its own set of objectives and programmes and vis-à-vis other EFIs? 

The  internal  coherence  within  the  ENI  programmes  is  good.  The  overall  good  internal 
coherence  is  based  on  the  existence  of,  and  compliance  with,  the  programming  instructions 
but also the continuous efforts of the different services to avoid overlaps86. This finding is also 
shared by the external (ROM) monitoring.  

The  ENI  bilateral,  multi-country  and  cross-border  (CBC)  programmes  have  each  been 
designed with different cooperation areas in mind and the Commission services make full use 
of  this  comprehensive  toolbox 87 .  Coherence  is  mainly  found  in  relation  to  the  policy 
framework of the Regulation (e.g. the strategic intent) rather than in operational linkages or 
synergies.  However,  the  extent  to  which  coherence  and  complementarity  issues  are  fully 
exploited during implementation is not always clear from management reporting. Also, some 
evaluations suggest that the coordination of regional and bilateral programmes is suboptimal. 
For  instance,  evaluations  have  shown  that  there  is  little  coordination  between  bilateral 
programmes,  regional  programmes  and  investment  facilities  in  relation  to  private  sector 
development,  an  area  in  which  EU  aid  is  intended  to  come  from  a  combination  of  bilateral 
aid,  regional  private  sector  development  programmes  and  regional  investment  facilities.88 
According to another evaluation89, Palestine is also an example case of the lack of consistency 
between the implementation of financial cooperation, the EU's official discourse and actions 
taken by individual Member States.  

85 See JC 55, Volume 2 of the Evaluation report and annex 3 on the stakeholders' consultation. 
86 Page 26 Evaluation report. 
87 JC 51, page 26 Evaluation report 
88 Thematic Evaluation of the EU's Support to Private Sector Development in Third Countries – Algeria, Jordan, 
Morocco 
https://ec.europa.eu/europeaid/strategic-evaluation-eu-support-private-sector-
development-third-countries-2004-2010_en; and 2017 Draft report on Evaluation to Private sector development. 
89  Strategic  evaluation  of  the  EU  cooperation  with  the  occupied  Palestinian  Territory  and  support  to  the 
Palestinian  people  (2008-2013):  https://ec.europa.eu/europeaid/strategic-evaluation-eu-cooperation-occupied-
palestinian-territory-and-support-palestinian-people_en 

Ukraine: 

and 

27 

 
 
                                                 
There  is  coherence  between  the  ENI  Regulation  and  the  actions  implemented  under  ENI  in 
the  sense  that  actions  are  required  to  present  expected  results  in  line  with  the  specific 
objectives of the Regulation. A bottom-up process (meaning that actions’ priorities have been 
based on the needs of partner countries) ensures this coherence. In addition, the quality review 
process  and  Quality  Support  Groups  have  guaranteed  that  inconsistencies  are  spotted  and 
corrected during the programming cycle90.  

Overall  consistency  between  the  instruments  is  good  and  is  ensured  through  different 
coordination  mechanisms  and  close  dialogue.  At  the  level  of  the  design  of  the  country  or 
regional programmes, there are numerous coordination mechanisms among the Commission 
services and the EEAS that ensure complementarity. For example, the Commission elaborated 
a  joint  humanitarian  and  development  framework  for  Syria,  Jordan  and  Lebanon,  supported 
by  different  instruments  ENI,  emergency  assistance  and  IcSP;  since  2011,  there  have  been 
numerous  examples  when  external  financing  instruments  intervene  at  different  stages  of  a 
crisis situation, for example in the case of Libya, Tunisia and Ukraine, with the humanitarian 
instrument intervening usually first, followed by the IcSP and then the ENI intervention. The 
same complementarity applies in the case of the Syrian refugees crisis where the humanitarian 
instrument  focuses  on  life  saving  actions  and  the  ENI  is  more  geared  towards  longer  term 
development  issues  (such  as  providing  support  for  schooling  of  children  in  hosting 
communities  in  Jordan  and  Lebanon).  Strong  coordination  also  exists  within  the  Eastern 
Partnership ensuring prioritisation including for investments in connectivity. 

Also, country team meetings are an occasion to discuss the interventions of each instrument; 
for  example,  the  respective  activity  of  all  instruments  in  Ukraine  is  coordinated  by  the 
Support  Group  for  Ukraine  the  service  invites  representatives  from  other  services  in  the 
quality  review  process  of  programming  documents  and  then  these  programming  documents 
from  the  ENI  go  through  the  formal  inter-service  consultation  process  of  the  Commission. 
The same process applies for the programming process of other instruments. 

The fact that the vast majority of funds comes from the ENI also ensures that the ENI strategy 
documents  are  considered  by  other  instruments  as  the  main  points  of  reference  for  their 
interventions. For example, in 2015, 88% of the total allocation to the ENP countries of North 
Africa was provided by the ENI instrument and 8.6% by the humanitarian instrument. In the 
South Caucasus, the ENI provided 85% of total EU funds. Thematic instruments have not had 
the resources required to match the challenges faced by most neighbourhood countries. 

There are also instances when resources from the ENI and EU internal programmes are pulled 
together  in  a  coherent  manner.  For  example,  resources  from  the  ENI  are  transferred  to  the 
Erasmus + programme at the beginning of two multi annual periods and put at the disposal of 
EU  national  agencies;  similarly,  the  resources  from  the  ENI  on  CBC  are  combined  with 
resources  from  the  European  Development  Fund  in  a  context  of  one  single  operational 
programme. This was one key expectation from the ENI impact assessment. 

All key aspects for stabilisation and development of partner countries are covered by the set 
of External Financing Instruments: defenders of human rights, empowerment of civil society, 
institutional building (of national and local authorities), etc. For most of these aspects, related 
objectives  can  be  found  in  the  geographic  instrument  and  in  related  thematic  Instruments. 

90 JC 52, page 26 Evaluation report 

28 

 
 
                                                 
Crisis  prevention  is  indicated  as  an  ENI  objective 91 .  In  fact,  most  actions  under  ENI 
encompassing a crisis prevention or tensions alleviation component are related to acute crisis 
and post-crisis situations and rather contribute to mitigate a potential deepening of the crisis. 
This  is  certainly  a  key  aspect  for  stabilisation,  for  instance,  through  short-term  (budget) 
support to Tunisia to help the country maintain its macro-economic stability or the support to 
host and refugee communities in Lebanon and Jordan. However, the share of ENI resources 
dedicated  to  the  actual  prevention  of  crisis,  acknowledged  as  being  the  most  cost-effective 
approach  to  stabilisation,  is  rather  low.  This  is  not  a  big  limitation  per  se,  as  there  is  a 
dedicated  thematic  instrument  for  crisis  response  and  prevention,  the  IcSP,  which  works  to 
complement  ENI  programmes.  However,  emerging  needs  linked  to  crisis  prevention  and 
response are only partly addressed (mainly by the IcSP)92. Nevertheless, the Commission does 
not  consider,  as  suggested  by  the  external  evaluators  that  there  is  a  need  to  establish  a 
dedicated component on crisis prevention within the ENI as this would undermine flexibility. 
More  focus  on  this  aspect  of  EU  interventions  is  needed  in  strategic  and  programming 
documents. 

Coherence has not been sufficient between funding channelled through the CBC programmes 
with other funding provided in the context of various regional cooperation frameworks as well 
as the implementation of EU's macro-regional strategies.  

In a different context, the Neighbourhood Investment Facility (NIF) is a primary instrument 
for  coordination  and  alignment  of  European  financial  institutions,  including,  but  by  far  not 
only,  the  European  Investment  Bank  (EIB)  and  the  European  Bank  for  Reconstruction  and 
Development (EBRD). The NIF supports (mainly) infrastructure projects that complement or 
follow the reform agenda implemented by partner countries and supported by Sector Reform 
Programmes (including where relevant with budget support). This sequencing is important as 
it guarantees that instruments are used to the best of their values: grants, also in the form of 
Budget  support  for  the  reform  process  and  the  associated  legislative  agenda  (laws, 
regulations,  policies)  and  loans  (through  the  NIF  and  in  partnership  with  European  and 
international financing institutions) for the implementation of investments that these reforms 
have identified as priority and the viability of which is ensured by the reformed institutional 
and regulatory set up.   

The  trust  funds  for  Syrian  Crisis  and  Africa  have  been  used  successfully  and  so  have  been 
other  EU  instruments  outside  the  ENI,  such  as  Macro-Financial  Assistance  (MFA)93.  Most 
coordination  efforts  between  ENI  and  other  instruments  are  made  at  the  level  of  the  EU 
Delegations.  Programme  managers  in  charge  of  one  particular  sector  are  able  to  properly 
sequence and coordinate the various instruments.  

A  telephone  survey  confirmed  that  coordination  with  EU  Member  States  has  been 
strengthened in recent years94, also through Joint Programming, even though they are reluctant 
to  further  advance  programme  complementarity  and  synergies.  Most  partner  countries  are 
now  engaged  in  a  way  or  another  in  this  process,  with  different  levels  of  ambitions;  in  the 
case of Palestine, a full joint programming document has been prepared in 2017, replacing the 
previous EU programming document. 

91 A  table  listing  all  the  "potential  crisis  prevention  projects"  funded  by  ENI  can  be  found  in  the  evaluation 
report, Vol 2, p 291-295. 
92 JC 54, pages 26-27 Evaluation report 
93 Page 27, Evaluation report. 
94 Page 33, Evaluation report. 

29 

 
 
                                                 
However, evidence from field visits demonstrates that gaining strength in advocacy by joining 
hands  with  EU  Member  States  (and  beyond  with  IFIs  and  other  donors)  is  differentiated 
between the East and the South.95 In the East, the EU (including EIB and EBRD) is typically 
the  main  (up  to  70%  of  ODA)  donor,  few  EU  Member  States  are  active  (mainly  Germany, 
Poland and Sweden) and only loans for middle-income countries are available from IMF and 
the World Bank. In the South, the state of play is more balanced. Besides the EU institutions, 
EU  Member  States  are  more  present  and  IFIs  can  propose  concessional  loans.  Even  if  the 
potential for synergy is higher for consistency in dialogue on policy reforms, it is difficult to 
materialise  due  to  the  weakness  of  the  coordination,  notably  by  lack  of  leadership  by 
beneficiary governments. Public financial management and sector policy dialogues are mostly 
fuelled by the EU and the World Bank, the other donors presenting a lower profile. 

In  general,  there  is  room  for  improvement  concerning  the  communication  to  the  partner 
countries and the general public on the EU's assistance.  

Evaluation question 6: Leverage 
To  what  extent  has  the  ENI/ENPI  leveraged:  further  funds  and/or  political  and  policy 
engagement (for example to what extent has the incentive-based approach leveraged progress 
made by partner countries in building and consolidating deep and sustainable democracy and 
in implementing agreed political, economic and social reform objectives). 

Though  it  is  too  early  to  assess  the  extent  to  which  ENI  has  improved  the  leverage  of  EU 
resources  on  the  capacity  of  partners  to  engage  in  structural  reforms 96 ,  especially  the 
experience with budget support and blending tends to support a positive contribution of EU 
interventions97. 

Expected  results  of  committed  budget  support  programmes  seem  encouraging  so  far.  This 
corroborates the findings of previous evaluations on budget support operations financed under 
the  ENPI,  according  to  which  the  experience  of  many  countries  demonstrates  that  budget 
support can achieve significant results within a diverse and often challenging set of contexts98. 
In  particular,  it  has  contributed  in  important  ways  to  upgrading  the  capability  of  these 
governments  to  manage  their  public  finances,  to  deliver  services  and  to  regulate  economic 
activity, for the benefit of their citizens. For example, one evaluation noted that the coverage 
of  health  services  and  of  secondary  and  tertiary  education  had  improved  in  Morocco  and 
Tunisia, and there were significant reductions in income poverty in both countries (although it 
is  difficult  to  attribute  this  directly  to  budget  support) 99.  This  evaluation  highlighted  the 
limited  scope  of  reforms  addressing  governance  issues,  which  remains  a  current  challenge 
under the ENI.  

95 See evaluation report Vol 2 page 208 
96 Progress  can  be  noticed  also  in  “difficult”  sectors  (anti-corruption,  rule  of  law,  human  rights,  civil  society 
etc.). Evidence of the implementation of the agreed actions/ programmes are many, as reported by the EUDs in 
each  country,  can  be  found  in  Armenia,  with  a  Justice  reform  programme;  in  Georgia,  with  development  of 
DCFTA and SMEs; in Ukraine, with a Justice and anti-corruption reform (legal framework), SMEs; in Moldova, 
with Legislation on anti-discrimination, Visa Liberalisation; in Morocco, with Healthcare for migrants, students 
and independents; in Tunisia, with Civil Society, Justice reform. See evaluation report, Vol. 2, page 375.  
97 Page 35, Evaluation report. 
98 Synthesis of Budget Support Evaluations: analysis of the findings, conclusions and recommendations of seven 
country evaluations of Budget Support – ADE 2014 
99

 https://ec.europa.eu/europeaid/sites/devco/files/strategic-evaluation-synthesis-ec-budget-support-1335-main-

report-201411_en.pdf, Summary of key findings. 

30 

 
 
                                                 
Blending  of  EU  grants  with  resources  (loans  and  grants)  of  EU  and  EU  Member  States’ 
financial  institutions  –  and  to  a  lesser  extent  with  IFIs  –  proved  to  be  an  effective  way  to 
attract  additional  resources  to  achieve  ENI  objectives  through  infrastructure  projects  or  by 
supporting private sector development100. Since 2008, ENPI/ENI instruments have contributed 
EUR 1 678 million to the Neighbourhood Investment Facility (NIF), leading to a total of close 
to EUR 15 billion from financial institutions. Also 15 EU Member States have committed a 
total  of  EUR  84  million  to  the  NIF  Trust  Fund,  complementing  ENPI/EU  resources.  ENI 
funds brought into EU trust funds have induced EU Member States to contribute but not at the 
level proportionate to the challenges. 

the  ENI  actions 

Through  policy  dialogue  and  cooperation, 
leveraged  sustainable 
implementation of agreed reform priorities in a number of countries during the period under 
review,  mainly  Morocco,  Georgia,  Ukraine  and  Tunisia.  Egypt  is  improving  its  up-take  of 
ENI-sponsored reforms as  well  but these are limited to  ‘technical’ areas  (renewable energy, 
urban development). In the other countries of the Neighbourhood, many factors which remain 
beyond  the  reach  of  EU  action  (e.g.  political  weakness,  oil  revenues,  on-going  conflicts, 
diverging  regional  alliances  etc.)  represent  stumbling  blocks  to  leverage  at  present.  ENI 
leverage  is  stronger  in  those  cases  where  the  budget  support  modality  can  be  used  as  the 
amount  of  resources  invested  by  the  EU  is  much  higher  than  for  traditional  technical 
assistance programmes, there is a stronger policy dialogue and focus on horizontal issues like 
public  financial  management,  not  to  mention  the  possibility  to  attract  other  donors  to 
participate in support packages for such reforms (e.g. Morocco and Tunisia)101. 

The  ENI  provided  the  framework  and  the  resources  to  mobilise  additional  funding,  either 
from  the  pre-existing  blending  facility  -  NIF102,  or  from  recent  initiatives  like  the  EU  Trust 
Funds (for example resources leveraged from EU Member States amount to just over 10% of 
the contribution from the EU Budget).  

Financial leverage is sought at project level, either by partnering with EU Member States and 
International Financial Institutions, or by promoting contributions from the national budgets. 
There are many successful reported cases of funds’ pooling at a project level103. Other types of 
funds’  pooling,  such  as  public  private  partnerships  or  schemes  using  diaspora  remittances, 
have  not  been  used  so far  for various reasons (e.g. like the  significant sovereign  risk  or  the 
lack of an appropriate legal framework). 

It  should  be  also  noted that,  as  appears in  the external  evaluation,  it is  difficult  to  assess to 
what  extent  the  incentive-based  mechanisms  under  the  ENI  have  leveraged  reforms  since 
those  countries  that  implemented  more  reforms  were  in  general  already  convinced  of  their 
interest  (as  Georgia,  Morocco,  Jordan,  Ukraine),  whilst  others  did  not  find  the  incentive  a 
sufficient reason to embark in new reforms (Egypt, Azerbaijan, among others). 

the  “Economic  Governance”  evaluation,  Annexes  on  Morocco  and  Tunisia 

100 JC 63, pages 37-38 Evaluation report 
101  In  these  countries  the  African  Development  Bank  has  normally  been  involved  in  joint  budget  support 
- 
operations.  See 
https://ec.europa.eu/neighbourhood-
enlargement/sites/near/files/170818_thematic_ev_of_economic_governance_-_final_report.pdf..  
102 It is estimated that 1 euro committed by the EC originated an overall investment of 8.6 euros in 2014 and 6.9 
in 2015. See page 38, Evaluation report. 
103 Page 38, Evaluation report. 

31 

 
 
                                                 
6. Conclusions 

The  European  Neighbourhood  Instrument  (ENI)  is  the  main  and  by  far  the  largest  financial 
instrument  supporting  through  grants  the  implementation  of  the  EU  policy  towards  the  16 
countries in the Southern and Eastern Neighbourhood of the EU, and Russia for programmes 
where it is eligible.  

It is yet difficult to assess the effectiveness of ENI as implementation started only in 2015 and 
most  programmes  adopted  since  then  require  time  to  be  rolled  out,  let  alone  to  produce 
outputs  and  outcomes.  In  many  instances,  actions  financed  under  the  previous  instrument 
(ENPI)  and  ENI,  together  with  other  EU  instruments,  have  been  effective  in  supporting 
stabilisation and building the resilience of important partner countries, notably by allowing a 
swift recovery of growth in Ukraine after 2015 or by avoiding a recession in Tunisia which 
could  have  derailed  the  smooth  transition  to  democracy.  ENPI/ENI  funds  have  also  been 
helpful  in  the  stabilisation  of  Jordan  and  Lebanon  which  have  been  confronted  with  the 
massive influx of Syrian refugees, notably in the efforts made to provide school opportunities 
for  Syrian  children.  ENPI  and  ENI  interventions  have  contributed  to  institutional  and 
administrative strengthening in many partner countries, through the provision of high level of 
EU  expertise.  ENPI  and  ENI  funds  have  also  leveraged  much  higher  funds  (notably  loans) 
from European and international financial institutions, and strengthened the policy leverage of 
the EU. 

The evaluation finds that ENI is overall relevant and fit for purpose. It has allowed the EU to 
implement  the  reviewed  Neighbourhood  Policy.  The  ENI  has  also  proven  its  capacity  to 
respond  in  a  flexible  manner,  in  line  with  the  impact  assessment,  to  the  multiple  crises  and 
new challenges in the Neighbourhood, in particular in Ukraine and Tunisia. This included the 
mobilisation of funding from other sources (in particular from the margin of heading IV and 
other  external  financing  instruments),  the  mobilisation  of  other  instruments,  such  as 
Humanitarian  Aid  and  Macro-Financial  Assistance,  in  parallel  to  ENI  interventions,  the 
Special  measures  to  address  the  Ukrainian  crisis,  as  well  as  Trust  Funds  in  response  to  the 
refugee crisis.  

The external evaluation, the broad consultation with stakeholders and the internal assessments 
highlight certain areas to be further considered:  

  The  current  challenges  and  needs  in  the  Neighbourhood  have  put  serious  strains  on  the 
ENI  budget  and  human  resources,  and  despite  budget  reinforcements  and  use  of  all 
flexibility  mechanisms,  the  response  capacities  of  the  instrument  have  been  stretched  to 
their limits.  

  The  large  share  of  programmed  assistance  has  allowed  to  keep  supporting  structural 
reforms but at times limited the scope for adjusting the EU financial response to pressing 
needs.  The  lack  of  a  single  support framework  for  Ukraine in  the  first  years  of  the ENI 
implementation has not prevented the Commission to provide relevant support. 

  The  complex  political  environment  in  some  Neighbourhood  countries  means  that  the 
implementation  of  the  ENI  has  not  been  equally  effective  in  all  countries,  despite 
increasing differentiation. 

  Neighbourhood  countries  have  made  varying  degrees  of  progress  in  political  and 
economic  reforms.  Nonetheless,  both  the  political  and  the  economic  situation  remain 
challenging  in  many  of  them,  notably  because  of  high  unemployment,  an  unfavourable 

32 

 
 
business climate and high corruption levels. ENI operations are addressing the root causes 
of these challenges but partner countries' commitment to reform varies greatly and limits 
the  effectiveness  of  ENI  interventions.  In  addition  to  partners'  political  commitment  to 
reforms, their institutional capacity is key for the sustainability of reform and meaningful 
policy dialogue with the EU. 

  The  implementation  of  the  incentive-based  approach  defined  in  the  ENI  provided 
significantly  higher  financial  resources  to  those  partners  that  have  made  the  strongest 
progress on political reforms but its impact on leveraging further reforms, in particular in 
other  countries,  still  needs  to  be  demonstrated.  The  ENI  has  not  been  able  to  provide 
sufficient incentives to those countries reluctant to engage in political reforms. 

  The overall coherence and complementarity of the different EU instruments has improved 
but  was  not  always  up  to  the  high  challenges  the  EU  was  confronted  with  in  the 
Neighbourhood. Existing risk analyses and scenario building tools, already developed by 
the EEAS, have not been sufficiently used in the framework of joint action by the EEAS 
and Commission services. 

  As  it  is  the  case  for  other  external  action  instruments,  reporting  at  outcome  and  impact 
remains  embryonic  both  at  the  instrument  and  at  country  level.  Work  is  ongoing  to 
develop an efficient monitoring system at the Commission and to support data production 
by partner countries. 

Overall, the existence of a dedicated financial instrument for the neighbourhood has been one 
of the most concrete evidence translating the political importance attached to the region by the 
EU, and has lent credibility to the EU's intention to deepen political cooperation and pursue 
gradual economic integration with its neighbours.  

33 

 
 
 
Annex 1. Evaluation Questions 

Relevance  

1. To what extent do the overall and the specific objectives (ENI Regulation, Article 1 and 2) 
and the design104 of the ENI respond to: 

(i)  EU  priorities  and  beneficiary  needs  identified  at  the  time  the  instrument  was  adopted 
(2014)? 

(ii)  Current  EU  priorities,  in  particular  emerging  from  the  2015  ENP  Review  such  us 
stabilisation,  and  beneficiary  needs,  given  the  evolving  challenges  and  priorities  in  the 
international context (2017)?  

Information sought in this area includes: 

 

 A  timeline  showing  congruence/divergence  of  the  instrument  against  the  initial  context 
(e.g.  ENP  review  2011,  negotiations  on  Association  Agreements  and  DCFTAs)  and 
against the evolving context, including global challenges, and institutional policy changes  
e.g. to what extent does the ENI support the implementation of the revised ENP, how it 
responds to new policy/political situations in our partner countries and also respond to the 
demands  of  Agenda  2030,  including  the  need  to  co-operate  with  emerging  countries  on 
implementing the SDGs.  

Effectiveness, impact, sustainability 

2. To what extent does the ENI deliver results against the instrument's objectives, and specific 
EU priorities?105 

Information sought in this area includes: 

  To what extent do ENPI/ENI programmes contribute towards shared prosperity and good 
neighbourliness,  and towards the other general and specific objectives listed in the ENI 
Regulation, Article 1 and 2 

  To  what  extent  have  ENI/ENPI  programmes  supported  policy  dialogue  and 

implementation of reform objectives agreed with each partner countries? 

  To what extent has the ENI/ENPI contributed to the European Union's priorities for smart, 

sustainable and inclusive growth?  

  To  what  extent  has  the  ENI/ENPI  contributed  to  enhance  sub-regional,  regional  and 

European Neighbourhood-wide collaboration as well as cross-border cooperation. 

  To  what  extent  does  the  ENI  mainstream  EU  policy  priorities  (e.g.  gender,  climate 
change)  and  other  issues  highlighted  for  mainstreaming  in  the  instrument,  and,  where 
relevant, deliver on the commitments including the financial allocations (ENI Regulation 
preamble, Article 1, 2 and 7) 

  To  what  extent  does  the  ENI/ENPI  promote  principles  of  aid  effectiveness,  such  as 

ownership, joint programming (ENI Regulation, Article 5)  

  To what extent are the processes conducive to programming, identification/formulation of 

effective actions (ENI Regulation, Article 6-17)?  

104 i.e. how it all fits together 
105 Evaluators will need to look at both the current ENI 2014-2020 and the previous ENPI 2007-2013 to respond 
to this question. Evaluators should distinguish the findings between the two periods. 

34 

 
 
                                                 
  To what extent has the ENI/ENPI provided differentiated support?  

  To what extent does the ENI use the incentive-based approach? (ENI Regulation, Article 

4 and 7)  

  To what extent is the ENI flexible enough to respond to changing needs? (e.g. in response 

to the ENP review of 2015, and rapidly evolving contexts in many countries)  

Efficiency 
3. To what extent is the ENI delivering efficiently?106 

Information sought in this area includes: 

  What is the ratio of administrative costs (as defined as “ENI Support Expenditure” in the 

Draft General Budget of the EU107) to overall budget? 

  How efficient is budget execution in terms of time taken from commitments to payments? 

  Have the changes made to ENI 2014 – 2020 from the previous ENPI 2007 – 2013 brought 
efficiency  gains?  E.g.  to  what  extent  have  changes  in  the  programming  process 
contributed to simplification?  

  Are  there  areas,  such  as  administrative/management  procedures,  where  the  ENI  can  be 

simplified to eliminate unnecessary burden? 

  To what extent is the ENI in line with the implementing rules of the CIR? Specifically in 

terms of:  

o  Implementation 

  Subject matter and principles 
  Adoption of action programmes, individual measures and special measures 
  Support measures 

o  Provisions on the Financing Methods 
  General financing provisions 
  Taxes duties and charges 
  Specific financing provisions 
  Protection of the financial interests of the Union 

o  Rules  on  nationality  and  origin  for  public  procurement,  grant  and  other  award 

procedures 

o  Climate action and biodiversity expenditure 
o  Involvement of stakeholders of beneficiary countries 
o  Common rules 

  Eligibility under the ENI 

o  Monitoring and evaluation of actions 

  To what extent are the following in place and functioning: 

o  appropriate  monitoring    processes  and  indicators    for  measurement  of  the 

performance of the ENI instrument 

o  relevant  strategic  and  operational  indicators    to  measure  results  achieved  by  the 

ENI? 

106 Evaluations  will  need  to  compare,  where  possible,  information  from  the  current  ENI  2014-2020  with  the 
previous ENPI 2007-2013. 
107

the 

latest, 

2016 

draft 

budget 

http://eur-

 See 
of 
item 
lex.europa.eu/budget/data/DB/2016/en/SEC03.pdf   

22-01-04-02 

Title 

22, 

35 

 
 
                                                 
Added value 

4. To what extent do the ENI programmes add value compared to interventions by Member 
States or other key donors? 

Information sought in this area includes: 

  Where the ENI is operating in the same field as Member States or other key donors, does 
it offer added value in terms of size of engagement, particular expertise, and/or particular 
weight in advocacy? 

Coherence, consistency, complementarity and synergies  

5.  To  what  extent  does  the  ENI  facilitate  coherence,  consistency,  complementarity  and 
synergies  both  internally  between  its  own  set  of  objectives  and  programmes  and  vis-à-vis 
other EFIs? 

Information sought in this area includes: 

  To  what  extent  are  the  different  ENI  programmes  coherent/complementing/overlapping 
with  one  another,  including  coherence  between  bilateral,  multi-country and  cross-border 
cooperation programmes? 

  To what extent are the different ENI programmes aligned with the evolving ENP policy 

and, where relevant, the EU development policy? 

  To what extent are the programmes consistent with EU external action policies? 
  To  what  extent  do  the  programmes  complement/overlap/stimulate  synergies  with  other 

external action financing instruments?108  

  To  what  extent  does  the  ENI  complement/overlap  with  other  EU  instruments  outside  of 

development policy? 

  To what extent does the ENI complement/overlap with interventions of other donors?  

Leverage 

6. To what extent has the ENI/ENPI leveraged  

  further funds and/or  

  political  and policy engagement (for example  to  what  extent has  the incentive-based 
approach leveraged progress made by partner countries in building and consolidating 
deep and sustainable democracy and in implementing agreed political, economic and 
social reform objectives). 

7. To what extent could the ENI be enhanced to achieve its policy objectives more effectively 
and efficiently?  

8. How can programming and implementation of ENI assistance be enhanced to improve the 
impact and sustainability of financial assistance? 

108 Note the respective mandates of DEVCO and FPI in EIDHR, PI and  IcSP  instruments 

36 

 
 
 
                                                 
Annex 2. Procedural information 

Organisation  

This  evaluation  assessed  the  European  Neighbourhood  Instrument  (ENI)  ahead  of  the  Mid-
Term Review Report, as set out in Article 17 of the Common Implementing Regulation (CIR 
2014).  It  will  mainly  be  used  to  generate  information  for  the  Mid-Term  Review  Report 
requested by the CIR due end 2017.   The evaluation provides information on relevance, EU 
added  value,  coherence  and  complementarity,  effectiveness,  efficiency,  sustainability, 
leverage and impact of the instrument.  

The  Staff  working  document  is  based  on  the  independent  assessment  carried  out  by  an 
external contractor and complemented by further internal analysis.   

The  lead  DG  to  carry  out  and  manage  this  evaluation  has  been  the  Directorate  General  for 
Neighbourhood and Enlargement Negotiations (DG NEAR).  But as this evaluation was part 
of a wider set of evaluations covering the instruments under Heading IV of the Multiannual 
Financial Framework 2014-2020 as set out in the CIR, as well as the performance review of 
the  European  Development  Fund,  and  in  view  of  ensuring  a  consistent  European  external 
policy,  all  the  evaluations  were  carried  out  in  an  interlinked  and  co-ordinated  manner.    To 
ensure this coherence of the different evaluation from the beginning DG NEAR, DEVCO, FPI 
and EEAS worked closely together. 

An  Umbrella  Inter-service  Steering  group  (ISG)  was  set  up  to  oversee  the  mid-term  review 
process  of  the  external  instruments.    This  ISG  is  chaired  by  the  Directorate  General  for 
International  Cooperation  and  development  (DEVCO)  and  is  composed  of  members  from 
relevant Commission services..  In addition ISGs were set up for each individual evaluation. 
The process started in June 2015 and the Umbrella ISG met formally for the first time on 21 
September  2015  and  during  the  following  weeks  and  months  agreed  on  the  joint  elements 
which  all  the  different  evaluation  should  use  in  their  specific  roadmaps  and  Terms  of 
reference. 

The ISG for the ENI evaluation was set up in October 2015, including relevant services of the 
Commission,  and  met  for  the  first  time  on  15  October  2015.    The  roadmap  for  ENI  was 
published, like all the other instruments Road Maps, at the end of October 2015; no comments 
were  received.  The  Terms  of  reference  were  approved  by  the  ISG  on  15  April  2016.  A 
specific  contract  was  awarded  on  9  June  2016  to  PARTICIP  GmbH,  using  the  framework 
contract  set  up  for  carrying  out  evaluations  in  the  context  of  external  relations,  and  the 
evaluators started their work on 30 June 2016. 

All foreseen deliverables were discussed in depth by the ISG, under the coordination of the 
evaluation manager in DG NEAR. During the evaluation process from October 2015 onwards 
the ISG met 7 times, in addition the members were consulted through email several times on 
draft and revised draft reports. 

Following the approval of the Draft Report by the ISG after the meeting of 11 January 2017, 
this  report  was  then  placed,  with  the  other  instruments  draft  reports,  on  the  Commission's 
website  for  the  web  based  open  public  consultation  (OPC)  on  7  February  2017.    The  OPC 
concluded  on  3  May  2017.  During  the  OPC  period  targeted  face  to  face  meetings  were 
organised with representatives of CSOs, both from the beneficiary countries and Europe, with 
representatives of EU member states and European Parliament. Following the closure of the 
OPC, during which 44 responses were received, a revised report was discussed again by the 
ISG leading to the issuing of the final report. 

37 

 
 
Evaluation Design 

Concerning  the  evaluation  design,  the  intervention  logic  (IL)  forms  the  backbone  of  the 
analytical  framework.  It  is  visualised  through  an  overall  reconstructed  IL  diagram,  which 
brings together the most relevant elements (from inputs to impacts, but also assumptions) in a 
single framework.  

In  accordance  with  the reconstructed  IL  for  ENI,  the  evaluation  first  focused  mainly  on  the 
additional  features  and  tools  introduced  with  the  ENI  Regulation.    The  development  of 
intervention  logics  for  the  ENP  2011  and  its  revised  version  of  2015  that  successively 
constituted the pivot of the instrument’s policy framework led the consultant to pay additional 
attention to the ability of DG NEAR and EEAS to respond to emergencies and crises in the 
Neighbourhood.  

The critical analysis of the (reconstructed) IL helped to focus the evaluative framework (EQs, 
JCs  and  indicators)  on  key  issues,  particularly  the  underlying  theory  of  change  and  the 
assumptions that ensure the operationalisation of the regulatory provisions.  

Evaluation questions, which were very similar to all the simultaneously on-going instruments 
evaluations,  structure  the  analysis  to  gather  evidence.  The  evaluation  questions,  as  well  as 
more  instrument-specific  sub-questions,  were  provided  in  the  Terms  of  Reference. 
Considering the objective of the various instruments evaluations launched under the mid-term 
review, consistency among the respective EQ/JC structure was prioritised up to the JC level. 
Each question was structured into JC and indicators required to provide an answer based on a 
synthesis of evidences.  

Methodology and data 

Concerning data collection and analysis, the evaluation of ENI was evidence-based. The EU 
evaluation  criteria  (relevance,  effective-ness,  efficiency,  EU  added  value,  coherence, 
consistency,  complementarity  and  synergies,  as  well  as  leverage)  were  applied  as  an 
underlying basis. The evaluation questions (EQs) from the Terms of Reference gave rise to a 
number of JCs and associated indicators. The evaluation was indicator-based. 

The  evaluation  used  a  mixed  methods  approach  blending  quantitative  and  qualitative 
methods, with a focus on the latter. The main analytical tools consisted of rigorous assessment 
of  documentation  and  consultation  of  stakeholders  (via  interviews,  group  consultations,  and 
the  Open  Public  Consultation-  OPC;  key  issues  have  also  been  addressed  by  a  joint-
instruments survey managed by the chapeau contract). 

For  all  EQs,  data  collection  included  various  tools  and  methods.  Priority  was  given  to 
document  review  and  interviews  at  HQ,  in  line  with  the  methodological  indications  in  the 
ToR  and  further  guidance  provided  by  DG  NEAR  and  DEVCO.  Data  collection  activities 
were carried out mainly during the desk phase, but also continued during subsequent phases. 
They included:  

• Compilation and analysis of roughly 300 DG NEAR/EEAS documents; 

•  Interviews  with  approximately  60  staff  (mostly  heads  of  unit/division  and  key  staff)  in 
NEAR, EEAS, Line DGs, EU Member States representatives in ENI Committee; 

•  Questionnaire-based  telephone  survey  with  twelve  (of  16)  Heads  of  Cooperation  in  ENI 
countries; 

• Analysis of EAMRs for the years 2013, 2014, and 2015; 

38 

 
 
• Analysis of the QSG2 quality reviews 2014 to-date; 

• Results of the Joint Survey, notably the ENI-specific open questions. 

The  above  sources  were  complemented  during  the  validation  phase,  which  focused  on  (i) 
validation  of  the  hypotheses  identified  by  JCs  and  EQs  during  the  desk  work  and  (ii) 
gathering the views of the stakeholders (national authorities, CSOs, EU Member States) and 
EU Delegations as key implementers/partners of ENI programmes.  

The  four  field  missions  (Egypt,  Georgia,  Tunisia,  and  Ukraine)  utilised  the  same  interview 
guidelines and were reported upon based on a common template.  

Interviews  were  organised  during  the  desk  phase  with  relevant  units  of  DG  NEAR  and  the 
EEAS, as well as other concerned EU institutions and Member States. To the extent possible, 
interviews were attended by two senior experts of the team. Brief interview guidelines were 
transmitted at least two days before the meetings, in particular for telephone interviews (with 
EU Delegations Heads of Cooperation, Centres of Thematic Expertise (CoTEs), EU Member 
States).  

The combination of data collection methods and techniques varied according to the different 
EQs  and  JCs.  Several  methods  and  techniques  were  used  to  collect  the  necessary  data  to 
assess a given JC according to the nature of the set of indicators identified. Where possible, 
the Evaluation Team combined the use of qualitative and quantitative data and relied both on 
primary and secondary data sources (EU Budget, NEAR) while taking into account re-source 
and time constraints.  

The synthesis phase was devoted to constructing answers to the evaluation questions, revising 
and  strengthening  the  narrative  of  the  intervention  logic  and  formulating  conclusions  and 
recommendations  on  the  basis  of  the  data  collected  throughout  the  process.  A  draft  final 
report was made available for an Open Public Consultation, which provided some inputs for 
the final report. 

Challenges and limitations 

The main challenge, as identified already in the ToR, has been the very tight timeline dictated 
by  the  CIR.  The  evaluation  team  managed  to  mitigate  potential  limitations  by  mobilising 
resources to carry out all tasks indicated in the methodology in parallel and analyse additional 
sources  of  information  when  available.  The  agreed  tight  schedule  might  have  somewhat 
limited  the  depth  of  data  treatment  but  was  overall  overcome  effectively  by  the  external 
evaluators' team.  

The  key  limitation,  which  is  inherent  to  any  mid-term  review,  is  that  the  outputs  of  the 
Instrument  (i.e.  ENI  programmes  under  the  SSF)  have  only  recently  entered  the 
implementation  stage.  Therefore,  effectiveness/sustainability/impact  criteria  could  not  be 
assessed  based  on  actual  results  at  this  stage.  The  external  evaluators'  team  was,  however, 
able to gain a first impression on these criteria based on the quality of the action documents 
and,  for  the  five  case  studies,  the  congruence  of  the  analysis  of  the  context  and  the  EU 
response strategy. 

The  ISG  as  well  as  other  staff  from  DG  NEAR,  EEAS  and  ENI  delegations  actively 
participated in providing missing data to the evaluators.  The multiple rounds of commenting 
also mean that facts have been verified and this facilitated the triangulation of data. 

39 

 
 
Overall,  the  quality  of  the  collected  evidence  (documentation,  interviews,  data  and  survey 
results)  for  this  evaluation  can  be  assessed  as  good,  demonstrating  a  satisfactory  degree  of 
confidence regarding the various findings of this evaluation.  

40 

 
 
 
 
Annex 2bis Response to the opinion of the Regulatory Scrutiny Board 

Opinion of the Regulatory Scrutiny Board 

Title: Evaluation / European Neighbourhood Instrument  

Overall opinion:   1st submission: NEGATIVE 

2nd submission: 28/09/2017 - POSITIVE 

Comments on 2nd submission 

NEAR Response 

Further 

(C) 
recommendations 

considerations 

and 

(1)  The  report  should  apply  the  intervention 
logic  more  systematically  throughout.  A  new 
section  summarising  partner  country  contexts 
(see also point 3 below) could form a basis for 
assessing 
'key 
the 
contextual 
'intervention  assumptions'  were  met.  The 
section  on  limitations  of  the  report  should 
for  ENI 
discuss  associated 
performance  and  draw  any  lessons  for  the 
future. 

the  extent 
the 
factors'  have  applied  and 

implications 

to  which 

In  view  of  keeping  a  coherent  approach  for 
the external financing instruments SWDs and 
not  to  overload  the  documents  given  the 
number 
this 
concerned, 
countries 
recommendation is not taken on board.  

of 

put 

emphasis 

The  Conclusions 
on 
problematic  issues  to  be  tackled.  A  "fiche 
contradictoire"  will  be  shortly  prepared  by 
the services to address issues to be corrected 
within  the  present  instrument.  Work  has 
started, meanwhile, with respect to the future 
MFF, for which a Impact Assessment will be 
prepared. 

(2)  Annex  3  contains  some  useful  material  on 
stakeholder concerns, and the report might refer 
to this in its responses  to evaluation questions. 
More  generally,  these  are  concerns  that  the 
evaluation  could  follow  up  on,  triangulating 
across  other  data 
to  provide 
policymakers  with  a  clearer  understanding  of 
alleged  shortcomings.  The  same  holds  for  the 
recommendations of the external evaluation and 
the  critical  comments  from 
the  Court  of 
Auditors.  Commission  services  should  account 
for these concerns and explain why they are not 
taken up in the report. 

sources 

(3) In order to make the report more readable 
and more self-standing, as well as to better 

The  revised  version  includes  more  reference 
to  the  consultation,  both  on  line  (OPC)  and 
through ad hoc meetings with EU MS, the EP 
and  civil  society  and 
local  authorities' 
organisations.   

Some  Court  of  Auditors  reports  are  rather 
positive.  Reference  has  been  added 
to 
different  CoA  reports  and  to  other  thematic 
evaluations. 

The 

section  on  Conclusion  has  been 

41 

 
 
   
reworked. 

This  report  is  an  evaluation  of  the  ENI 
regulation  and  cannot  go  into  the  details  of 
the situation in each of the 16 ENI countries, 
which  would  make  the  report  very  long.    In 
addition,  consistency  with  the  other  external 
financing  instruments  SWDs  needs  to  be 
ensured, and the Commission cannot have in 
these reports a state of play on the countries it 
is  intervening  in.  A  table  has  been  added 
making  reference to  the  major  events  having 
taken place in some countries in the last few 
years  with  the  impact  in  the  concerned 
countries. 

. 

present the current context of the ENI, the 
report could summarise separately the 
situation and context of the 16 partner 
countries in question. This might take the 
form of either a summary table or a dedicated 
section. The objective would be to describe 
the context in which ENI has been operating 
and to give the reader an overview of the 
varied and often deteriorating circumstances 
in recipient countries during the review 
period. An overview table of the 16 countries 
might usefully set out the main challenges the 
countries have faced that have complicated 
ENI implementation. As programme 
effectiveness relies on partner country co-
operation, this section should link with a 
section on limitations (see below). The 
limitations section could then address 
associated consequences for programme 
implementation and evaluation. The report 
should discuss how changes in political 
commitment of partner countries may have 
lowered ENI performance in this context.  

The  executive  summary  is  mostly  easy  to 
follow.  The  main  report  is  less  accessible, 
with  language  that  often  seems  aimed  at 
insiders. More could be done to communicate 
the  main  points  in  plain  language,  especially 
in the conclusions section. 

Comments on 1st submission 

It  should  do  more 

(1)  Presentation,  scope  and  lessons  learnt 
The  SWD  should  be  revised  to  become  a  self-
standing  document,  which  a  non-expert  reader 
can  understand  without  having  to  consult  the 
external  study. 
than 
summarise  positive  aspects  and  conclusions  of 
the external study. In its analysis, findings and 
conclusions,  the  SWD  currently  appears  to 
the 
overlook  critical  views  expressed 
external 
evaluation,  European  Court  of 
Auditors'  reports  and  by  some  stakeholders. 
The  SWD  should  be  transparent  about  these 
and  explain  where  the  Services  may  not  agree 
with  the  assessment  of  the  external  evaluation 
study  and  why 
(e.g.  crisis  prevention, 
flexibility,  involvement  of  national  authorities, 
multiple strategy scenarios). Since the results of 
into 
this  mid-term  evaluation  will 

feed 

in 

in 

The revised version put more emphasis on the 
critical aspects pointed out by the evaluation. 
These  will  be  better  addressed 
the 
framework  of  the  "fiche  contradictoire"  that 
DG  NEAR  is  preparing  on  the  follow-up. 
Whenever  DG  NEAR  disagrees  with  the 
views  expressed  by  the  evaluators,  this  is 
clearly  said,  and  will  be  mentioned  in  the 
"fiche contradictoire" if recommendations are 
not  accepted.  More  substantial  changes  are 
likely to be proposed in the framework of the 
future instrument, which is outside the scope 
of the current mid-term review report.  

42 

 
 
 
that  receive  more 

developing  the  future  instrument,  the  SWD 
should  identify  and  cover  aspects  that  are 
relevant to learning from past experience. This 
includes  assessing  what  design  features  (e.g. 
priority 
flexible 
setting,  programmed  vs 
support,  delivery  mechanisms,  incentive-based 
approach) of the instrument work well or not. It 
would  be  helpful  to  indicate  any  countries  or 
sectors 
than  sufficient 
funding  (e.g.  'donor  congestion')  and  where 
there are shortages. It would also be helpful to 
include  an  assessment  of 
the  degree  of 
coherence  and  complementarity  with  other 
financing 
report  should 
critically  assess  the  existing  monitoring  and 
reporting  arrangements.  It  should  present  any 
lessons  for  future  data  collection  that  would 
facilitate  a  better-informed  and  more  useful 
evaluation in the future. 

instruments.  The 

2)  Effectiveness,  Efficiency,  Intervention 
Logic 

it 

in 

the 

should 

to  stabilisation 

the  ENI's  objectives 

The  SWD  should  explain  its  metrics  for 
assessing  effectiveness  of  the  ENI.  Firstly,  it 
(e.g. 
should  clarify 
contribute 
region, 
alignment  with  the  EU  values  and  rules,  …). 
explain  how  ENI 
Secondly, 
interventions  are  intended  to  work  towards 
reaching  those  objectives  (the 
'intervention 
logic').  It  should  also  incorporate  relevant 
experience  with  the  predecessor  programme 
(ENPI)  and  expectations  as  set  out  in  the 
impact assessment for the current ENI. In doing 
so,  the  SWD  should  specify  which  design 
features of the ENI make it effective or not (e.g. 
flexibility,  budget  support,  conditionality). 
Using  the  intervention  logic,  the  SWD  should 
specify  what  benchmarks  it  will  use  to  assess 
the  performance  of  the  instrument.  The  SWD 
should also describe what the ENI adds to other 
programmes, and compare against a country or 
set of countries where this instrument does not 
operate. Finally, it should explain how changes 
in  the  Neighbourhood  policy  have  affected  the 
effectiveness of the ENI. 

The  revised  text  has  addressed,  as  much  as 
possible  these  points.  Reference  is  made  to 
the  ENI  Impact  Assessment  and  ENPI 
performance,  whenever  possible,  to  explain 
to which extent it was up to the expectations, 
mentioning  areas  where  some 
important 
results were achieved (in streamlining public 
administration  reforms  (Georgia,  Ukraine), 
keep focus on democratic transition despite a 
difficult  environment  and  terrorism  attacks 
(Tunisia),  ensure  economic  resilience 
in 
(Jordan,  Ukraine, 
difficult  environments 
Tunisia). Reference to high level indicators is 
made  to  highlight  progress,  or  lack  of  it,  in 
relevant areas. 

Further  elements  of  value  added  of  EU 
support  and  complementarity  with  other 
instruments have been added. 

Areas  of  success  in  terms  of  simplification 
and  flexibility  are  highlighted,  together  with 
areas where more work is required. 

The  SWD  should  identify  any  potential  for 
simplifying processes and procedures. It should 
include 
to 
information 
conclusions  on  ENI  efficiency  in  terms  of 
ratio  of 
procedures,  processes  and 

relevant 

basic 

the 

43 

 
 
This  part  has  also  been  strengthened.  The 
importance  of  the  ENI,  which  provides  most 
of  the  funding  to  Neighbourhood  countries 
and  its  complementarity  with  specific,  but 
very 
instruments 
thematic 
contributions is emphasised. 

small, 

administrative costs. 

3) Relevance and coherence 

the 

trade-offs 

should  assess 

the  continued 
The  SWD 
the  ENI  as  a  geographic 
relevance  of 
instrument  covering  countries  in  very  diverse 
circumstances and with very different needs. It 
should  discuss 
in  using 
geographic  versus  thematic  instruments  in  the 
countries covered by the ENI. The SWD should 
explain  what  design 
features  make  ENI 
complementary  to  other  financing  instruments, 
e.g.  the  European  Instrument  for  Democracy 
and Human Rights, the Instrument contributing 
to  Stability  and  Peace, 
the  Development 
Cooperation Instrument, as well as instruments 
like  Erasmus+.  It  should  explain  relevant 
sequencing  considerations  when 
is 
overlap  between  the  geographic  and  thematic 
focus  (e.g.  short-term  crisis  prevention  by 
thematic  instruments  followed  by  long-term 
stability by geographic instruments). 

there 

44 

 
 
 
Annex 3. Synopsis report of the stakeholders' consultation 

Consultation strategy 

The evaluation of the European Neighbourhood Instrument (ENI) for the period 2014-20 was 
supposed  to  feed,  together  with  parallel  evaluations  of  other  external  financing  instruments 
under  the  multiannual  financial  framework  (MFF),  the  required  mid-term  review  report 
(MTR). The objectives of all instruments evaluations, including the one on the ENI, are to a) 
provide  the relevant external  relations  services of  the  European  Union and  the  wider  public 
with  an  assessment  of  the  instruments,  including  complementarities  and  synergies  among 
them; and b) inform the programming and implementation of the current instruments, as well 
as the next generation of instruments.  

This consultation strategy provides an overview of the approach that was taken for consulting 
with the main stakeholders of this evaluation. It contains two elements. The first describes the 
overall  setup  of  the  strategy  (i.e.  the  underlying  stakeholder  mapping,  the  framework  and 
strategy  as  well  as  the  timeframe).  The  second  provides  statistics  on  the  consultation  of 
stakeholders.  An  important  component  of  the  stakeholder  strategy  is  the  open  public 
consultation  (OPC)  at  the  end  of  the  synthesis  phase  of  the  evaluation  to  acquire  feedback 
from all relevant parties on the main evaluation findings, which is presented shortly in its own 
separate section below. 

One  should  also  mention  that  the  consultation  had  already  started  at  the  moment  of  the 
evaluation preparation, when the roadmap was published, together with the others related to 
the  other  external  evaluations,  to  seek  feedback  from  stakeholders.  But  no  feedback  was 
received on any of the roadmaps. 

Stakeholder mapping 

An important element of any consultation strategy is to identify or map the stakeholder groups 
to be consulted as illustrated in the figure below. 

Figure 1  Stakeholder Mapping 

45 

 
 
The table below was first introduced as a planning tool in the Inception Report and has been 
updated to provide information on the actual consultations that took place during the course of 
this evaluation. It provides details of who was consulted, on what issue, when and how. 

Table 1  Consultation process: Who, what, when and how? 

Who? (Type and 
group) 

What? (Consultation issues) 

When? 
(Stage) 

How? (tool) 

EQ1  EQ2  EQ3  EQ4  EQ5  EQ6 

Commission Services and EEAS  

DG NEAR 

 

 

 

 

 

 

All stages  

Interviews 

 

 

 

 

 

Desk and 
validation 

Interviews 

DG DEVCO, AGRI, 
TRADE, CLIMA, 
ECFIN, HOME, 
EUROSTAT… 

ERDF, EIB, EBRD 

EEAS 

EU Delegations 

 

 

Development partners 

Agencies and 
ministries of EU 

 

 

 

 

 

 

 

 

 

 

 

 

Validation 

Interviews 

All stages 

Interviews 

Desk and 
validation 

Interviews, EUD 
survey  

 

 

All stages 

Interviews and 
OPC 

46 

Partner countries -regionalRegional organisations & partners•CSO networks and regional platforms grouping authorities at regional level•UfM, 5+5 dialogue, EaP, ND, BBS, ...04Partner countries -national•Aid coordination ministries•CSOs andauthoritiesat national level03EU entity01ENI/ENPI keyprogrammestaff•National programmes•Regional programmes(EUROMED projects, ENPARD, CKIS, TRACECA, ...)06Development partners02Private sector•Trade associations•European ChamberofCommerce. 05•DG NEAR –Directorates R: Resources and A: Strategy•DG NEAR –Geographic Directorates B, C and Support Group for Ukraine•DG DEVCO, DG AGRI, DG TRADE, DG CLIMA, DG ECFIN, DG HOME, EUROstats•EEAS•EU DelegationsStakeholder Mapping•Agencies and ministries of EU MS•Multilateral andinternational organisations•Third countrydonors. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Who? (Type and 
group) 

What? (Consultation issues) 

When? 
(Stage) 

How? (tool) 

EQ1  EQ2  EQ3  EQ4  EQ5  EQ6 

Member States 

Multilateral 
organisations (e.g. 
UN, World Bank) 

Third-country donors 
(e.g., USAID) 

 

 

Partner countries (national) 

 

 

 

 

Validation 

Interviews 

Validation 

Interviews 

Aid coordination 
ministries, ministries 
involved in informal 
dialogues (e.g. EaP) 

CSOs and 
authorities at 
national level 

 

 

 

 

 

 

 

 

 

 

 

Validation 
and 
synthesis 

Validation 
and 
synthesis 

Interviews and 
OPC 

Interviews, 
group 
discussions and 
OPC 

Regional organisations, partnerships, cooperation frameworks or networks 

UfM, LAs, EaP, ND, 
BBS… 

CSO networks and 
regional platforms; 
grouping of LAs at 
regional level 

 

 

 

 

 

 

ENI/ENPI key programmes (only team leaders, for case studies) 

Synthesis 

OPC 

Synthesis 

OPC 

Validation 

Interviews  

Validation 

Interviews  

National 
programmes  

Regional 
programmes 
(EUROMED 
projects, ENPARD, 
CKIS, TRACECA…)  

Private sector 

Trade associations 

European Chamber 
of Commerce 

 

 

 

 

 

 

Stakeholder consultation strategy 

 

 

Synthesis 

OPC 

Synthesis 

OPC 

The stakeholder mapping for ENI outlined the main institutions or groups that are considered 
as ‘stakeholders’. The developed stakeholder consultation strategy aimed at ensuring that the 
evaluation team could fully engage with all these stakeholders during the evaluation process. 
An important component of this consultation process was the open public consultation (OPC) 
done at the end of the synthesis phase of the evaluation to acquire feedback from all relevant 
parties on the main evaluation findings. Details on the implemented and completed approach 
are given below. 

47 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The approach taken by this evaluation to engaging with the scope of all these aforementioned 
stakeholders has been defined by their role in ENI and their relative importance and influence 
over it. The consultation approach for the principal stakeholders identified in the above table 
has been as follows: 

Commission Services and EEAS 

The evaluation team closely consulted all the relevant DG NEAR geographical and thematic 
units  throughout  the  desk  and  validation  phases  and  informed  them  of  results  in  the 
evaluation. Other DGs and entities have been consulted during the desk and validation phases 
where specific instances required it and informed of evaluation results. EU Delegations have 
also been consulted and informed throughout all phases of the evaluation.  

Development Partners 

The  development  partners  active  in  the  Neighbourhood  (EU  Member  States  agencies, 
international organisations) have been consulted in-country in the validation phase as well as 
desk phase if judged necessary. 

Partner countries (national) 

Aid coordination ministries and other relevant line ministries of partner countries have been 
consulted in the case study countries  during the validation phase. CSOs also  have an active 
role in ensuring citizens are adequately represented in the formulation of ENI actions and in 
overseeing as well as implementing them. They have been consulted particularly during the 
validation phase and the OPC. 

Stakeholder consultation framework 

Consultation with stakeholders took place via the following means: 

 

 

Interviews  (face-to-face  and  via  phone)  and  group  discussions  with  various 
stakeholders at HQ level as well as via field missions to four case study countries; 
Interviews with EU Delegations in the form of a phone survey (in general targeting the 
Heads of Cooperation) during the desk phase; 
Instruments-wide survey to EU delegations (coordinated by the chapeau team); 

 
  Open Public Consultation (OPC) via web and face-to-face. 

Timeframe 

 The timeframe for the delivery of the consultation strategy as follows: 

Consultation actions 

Desk Phase 

Validation Phase (incl. presentation of preliminary 
findings) 

Deadline  

Until 10th October 2016 

Until 24th November 2016 

Synthesis Phase (pre-OPC) 

Open Public Consultation 

Synthesis Phase (post-OPC) 

Stakeholder statistics 

Until 16th January 2017 

From 7th February 2017 until 5th May 2017 

Until mid-June 2017 

Interviews took place during the desk phase with all relevant units of DG NEAR, as well as 
other EU entities and EU Member States. At the same time, interviews with EU Delegations 

48 

 
 
(in  general  with  the  Heads  of  Cooperation)  were  undertaken  in  form  of  a  phone  survey. 
During the validation phase, interviews took mainly place within the frame of field visits to 
four case study countries (Egypt, Georgia, Ukraine and Tunisia). Consultation in the synthesis 
phase  mainly  concentrated  on  the  Open  Public  Consultation  and  the  targeted  face-to-face 
meetings  (see  separate  chapter  below)  and  reverting  to  previous  interview  partners  for 
clarification  following  the  comments  on  the  report.  During  all  phases,  the  evaluation  team 
proactively reached out to the identified stakeholders and made sure that everyone was given 
an opportunity to provide inputs. 

To the possible extent, interviews were structured around interview guidelines shared with the 
interview partners beforehand and were attended by two (senior) experts of the team. In total, 
174 interview partners were consulted, the vast majority of which fit into the category of “EU 
entity”. The following graphs provide a more detailed overview of the persons interviewed. 

Figure 2  Overview of persons interviewed by category 

Figure 3  Overview of persons interviewed by country109 

109 "HQ"  stands  for  stakeholders  interviewed  at  an  EU-wide  level  and  mostly  refers  to  Commission  staff  in 
Brussels. 

49 

11624322020406080100120140EU entityDevelopment partnersPartner countriesENI/ENPI Key programmes 
 
 
                                                 
Open Public Consultation (07/02/17 - 05/05/17) 

The Open Public Consultation (OPC) done at the end of the synthesis phase represented an 
important component of this consultation process. By collecting contributions through a web 
survey  and  through  technical  workshops,  it  allowed  to  acquire  feedback  from  all  relevant 
parties on the main evaluation findings. Even though the OPC was also aimed at the broader 
public  and  all  relevant  stakeholders  were  targeted,  particular  attention  was  paid  to  the 
contributions of EU Member States.  

From  the  web  OPC,  a  total  of  44  contributors  answered  questions  related  to  the  ENI 
evaluation.  

Figure 4  Type of contributors from the web OPC 

50 

82282019178020406080100HQUkraineGeorgiaEgyptTunisiaOther ENI countriesOther; 1; 2%Industry, business or workers's organisations; 1; 2%Citizen/individual; 2; 5%Research/academia; 4; 9%EU platform, network, or association; 4; 9%Public authority; 13; 30%Organisation or association; 19; 43% 
 
 
 
 
The very limited number of contributions received doesn't not allow the possibility to come 
up  with  relevant  conclusions,  also  because  the  responses  to  the  questions  presented  a  very 
polarised  perception,  confirming  the  overall  mixed  picture  to  which  the  external  evaluation 
came up with.  

The instrument is generally considered as being relevant (with regards to the proximity of the 
Neighbourhood,  human  rights  and  the  need  to  provide  a  differentiated  approach  for  the 
partner countries) and as having an added value (in a sense that the EU is seen as a driving 
factor  behind  reforms  in  partner  countries  and  that  its  assistance  adds  political  weight  to 
specific policies and issues).  

Even though coherence  and  coordination is mentioned positively by some, it is also often 
raised as an area that still needs improvement, in particular with regards to EU Member States 
and  other  donors.  Other  mainly  negative  answers  (but  also  several  mixed  contributions) 
frequently  cite  the  increasing  instability  in  the  Neighbourhood  as  evidence  that  ENI  has 
failed  to  achieve  its  primary  objective  of  creating  an  area  of  “good  neighbourliness”. 
However, some contributors criticize the instrument in particular for  focusing  too  much  on 
short-term  stability  issues  and  raise  concerns  about  ENI  funding  increasingly  being 
channelled to security, at the expense of a more sustainable support of democracy, human 
rights and civil society. 

The mainly positive assessments, which were submitted in majority by public authorities, all 
praise the incentive-based approach for its results in the Eastern Partnership, underlining the 
belief  that  the  “more  for  more”  principle  has  managed  to  foster  major  reforms  and 
transformation.  Positive  results  of  the  mechanism  in  specific  cases (e.g.  Georgia, Ukraine, 
Tunisia) are also often mentioned in mixed answers, most of which highlight the relevance of 
the principle and the need to reward and encourage countries that have shown goodwill in 
establishing reforms that mirror EU values.  

The contributors of both mixed and  mainly negative assessments however call into question 
the effectiveness of the incentive-based approach: the financial volume is too small to have a 
real  leverage  effect  (in  comparison  to  the  countries’  GDP)  and  the  actual  promotion  of 
human  rights  and  democracy  has  suffered  from  the  application  of  a  more  pragmatic 
approach  centred  around  ownership  and  common  values  following  the  recent  crises  (in 
particular related to  migration).  This is  perceived as  creating a  reward  mechanism  mainly 
for  “friendly  governments” that are willing to go along a specific reform path, rather than 
offering an incentive to human rights and democracy reforms in the whole Neighbourhood. In 
this  context,  a  very  interesting  complementary  point  has  been  put  forward  by  one  of  the 
contributors:  “When  partner  countries  show  their  goodwill  in  establishing  reforms  that 
mirror EU values, it is only natural that they receive the support that matches their ambition. 
However, when central governments in partner countries are not complying and not willing to 
bring  positive  changes,  the  budget  allocated  through  the  ENI  is  in  theory  distributed  to 
NGOs. Yet, EU Delegations find it difficult to identify and involve umbrella organisations that 
represent  civil  society  at  large.  In  this  case,  the  ones  penalised  are  first  and  foremost  the 
citizens  since  they  do  not  benefit  from  programmes  that  foster  stability.”  EU  platform, 
network or association 
With regard to the contribution to the stabilisation process, as one could have expected, most 
contributors express their opinion that the current political situation in the Neighbourhood and 
its recent crises (repression and hardening of regimes in the aftermath of the “Arab Spring”, 
outbreak of conflicts in Libya, Syria and Ukraine) are evidence of the failing attempts of ENI 
(and to a larger scale EU) to stabilise the region. In the negative and mixed answers, several 
explanations are given as to why the stabilisation efforts have been unsuccessful; citing a lack 

51 

 
 
of  complementarity  and  flexibility,  but  also  the  lack  of  political  will  and  the  difficult 
situation of civil society in the Neighbourhood countries.  

The main topic present in most of the answers is however the balance  between  short term 
efforts  (crisis  prevention/response,  security  policies)  and  long-term  development.  In  that 
respect,  some  (mainly  positive)  answers  tend  to  see  the  ENI’s  focus  on  long-term 
development  as  an  enabling  factor  for  positive  results  (for  example  in  Ukraine  and 
Tunisia, but also the CBC Programmes were mentioned as a positive example of a long-term 
engagement  which  establishes  networks  and  exchanges  across  borders,  thus  stabilising 
relationships).  This  view  is  also  shared  in  some  mixed  or  negative  answers,  stating  that 
EU/ENI  has  to  concentrate  even  further  on  long-term  reforms  and  development  in  order  to 
truly contribute to the stability of the region. But there are also other voices that identify the 
insufficient  means  of  crisis  prevention  as  the  main  problem  of  EU/ENI  efforts  of 
stabilisation. One of the  more neutral  statements in  this respect summarizes the issue:  “The 
key dilemma is to have a field-informed and adaptable policy that allows for cooperation on 
concrete  problems  needing  responses  in  the  immediate  while  not  neglecting  long-term 
support  to  regional  integration,  key  for  sustainable  solutions.  The  ENI  can  be  tweaked  and 
improved but the EU needs to find a common long-term, strategic and comprehensive vision 
for the Neighbourhood, taking into account what is feasible, in light of interests, aspirations 
and opportunities on both sides. Otherwise the responses that ENI can offer are quite limited 
and  their  achievements  can  be  quickly  undermined  by  structural  challenges  and  recurrent 
crises.” Research/academia 

Beside  the  OPC,  and  besides  bilateral  meetings  organised  by  the  external  evaluators  in  the 
field  with  different  stakeholders,  over  180  participants  from  the  EU  Parliament  and  EU 
Member States attended a technical workshop organised in Brussels in March. In addition, the 
draft  evaluation  report  was  also  presented  at  the  Policy  Forum  on  Development  and  in  the 
Council’s  Working  Parties  on  Eastern  Europe  and  Central  Asia 
(COEST)  and 
Mashreq/Maghreb (MaMa) in April. The main feedback received was the following: 

During each meeting, a number of issues were raised with regards to the evaluation findings, 
but also to ENI in general. Comments were made by different stakeholders from the Council 
of 
the  European  Union,  European  Parliament,  Member  States  and  Civil  Society 
Organisations.  

The  following  bullet  points  summarise  the  main  issues  raised  during  the  face-to-face 
consultations: 

  The principle of differentiation is generally appreciated as means for better and more 
targeted  assistance.  Nonetheless,  if  each  country  is  treated  specifically,  the  overall 
instrument is put into question; 

  The  incentive-based  approach  is  an  important  tool,  but  clearly  has  room  for 

improvement to make it more effective, e.g. by revising the allocation criteria; 

  The  point  of  the  appropriate  balance  between  crisis  prevention  and  long-term 

development was raised; 

  Coordination and coherence between different programmes (bilateral, multilateral) or 
instruments  needs  improving  and  operational  linkages  and  synergies  need  to  be 
created; 

  Cooperation between EU Delegations and Member States needs strengthening, e.g. by 

applying Joint Programming in a systematic way; 

52 

 
 
 
  The lag between programming and implementation; 
  The (low) absorption capacity of partner countries is seen as the main obstacle of an 
effective  and  fast  implementation  of  the  instrument  and  a  key  problem  in  the 
Neighbourhood; 
Insufficient (time) capacities of EU Delegations staff; 

 
  Visibility  aspects  of  ENI  with  regards  to  strategic  communication  (reaching  out  in  a 

broader sense than only governments) and with regards to indirect management; 

  Added value of Trust Funds over standard ENI programmes; 
  Advantages and disadvantages of Budget Support; 
 

Involvement  of  CSOs  especially  with  regards  to  the  challenges  of  reaching  out  to 
smaller CSOs. 

53 

 
 
 
Annex 4. Acronyms 

AA 

AFD 

AOSD 

AP 

ATA 

BS 

CBC 

CC 

CH 

ECB 

CIR 

COEST 

COSCE 

CoTE 

CRIS 

CSO 

DAC 

DCFTA 

DCI 

DG AGRI 

DG BUDG 

DG DEVCO 

DG ECHO 

DG ECFIN 

DG ECFIN 

DG ELARG 

DG HOME 

DG NEAR 

DG TAXUD 

DG TRADE 

EAMR 

EAMRs 

EBRD 

EC 

Association Agreement 

Agence Française de Développement 

Authorising Officer by Sub-Delegation 

Action Plan 

Anti-Tax Avoidance Directive 

Budget Support 

Cross-Border Cooperation 

Climate Change 

Switzerland 

European Central Bank 

Common Implementing Regulation 

Working Party on Eastern Europe and Central Asia 

Council of Europe 

Centres of Thematic Expertise 

Common Relex Information System 

Civil Society Organisation 

Development Assistance Committee 

Deep and Comprehensive Free Trade Areas 

Development Co-operation Instrument 

Directorate-General for Agriculture and Rural Development 

Directorate-General for Budget 

Directorate General for International Co-operation and Development 

Directorate-General for European Civil Protection and Humanitarian Aid 
Operations 

Directorate-General for Economic and Financial Affairs 

Directorate-General for Economic and Financial Affairs 

Former Directorate-General for Neighbourhood and Enlargement 

Directorate-General for Migration and Home Affairs 

Directorate-General for Neighbourhood and Enlargement Negotiations 

Directorate-General for Taxation and Customs Union 

Directorate-General for Trade 

External Assistance Management Report 

External Assistance Management Reports 

European Bank for Reconstruction and Development 

European Commission 

54 

 
 
 
 
EDF 

EEA 

EEAS 

EEC 

EFI 

EFTA 

EIA 

EIB 

European Development Fund 

European Economic Area 

European External Action Service 

European Economic Community 

External Financing Instrument 

European Free Trade Association 

Environmental impact assessment  

European Investment Bank 

EIDHR 

European Instrument for Democracy and Human Rights 

EIF 

ENI 

ENP 

ENPI 

EP 

EQ 

ERDF 

EU 

EUD 

EUISS 

EUR 

EU MS 

European Investment Fund 

European Neighbourhood Instrument 

European Neighbourhood Policy 

European Neighbourhood and Partnership Instrument 

European Parliament 

Evaluation Question 

European Regional Development Fund 

European Union 

Delegation of the European Union 

European Union Institute for Security Studies 

Euro 

EU Member States  

EURATOM 

European Atomic Energy Community 

EUTF 

FAQ 

FEMIP 

FPI 

FR 

HoD 

HQ 

HR 

IcSP 

IFI 

INGO 

IO 

IPA 

JC 

KFW 

KPI 

EU Trust Fund 

Frequently Asked Questions 

Facility for Euro-Mediterranean Investment and Partnership 

Foreign Policy Instrument 

Financial Regulation 

Head of Delegation 

Headquarters 

Human rights 

Instrument contributing to Stability and Peace 

International Financial Institution 

International Non-Governmental Organization 

International Organisation 

Instrument for Pre-accession Assistance 

Judgement Criterion 

Kreditanstalt für Wiederaufbau (German development bank) 

Key Performance Indicator 

55 

 
 
LAs 

LRRD 

LS 

MFA 

MFF 

MICs 

MIP 

MIS 

MS 

MTR 

NGOs 

NIF 

ODA 

OECD 

PAR 

PFM 

PPP 

PRAG 

RACER 

RF 

ROM 

SDGs 

SGUA 

SMEs 

SSF 

TEU 

TF 

TOR 

UFM 

UN 

UK 

UNFCCC 

USAID 

VAT 

VET 

WB 

Local Authorities 

Linking Relief, Rehabilitation and Development 

Local Stakeholders 

Macro-Financial Assistance  

Multiannual Financial Framework 

Middle-Income Countries 

Multiannual Indicative Programme 

Management information System  

Member State 

Mid-Term Review 

Non-Governmental Organisations 

Neighbourhood Investment Facility 

Official Development Assistance 

Organisation for Economic Co-operation and Development 

Public Administration Reform 

Public Finance Management 

Public-Private Partnership 

Practical Guide 

Relevance, acceptability, clarity, easiness, robustness indicators 

Result Framework 

Results-Oriented Monitoring 

Sustainable Development Goals 

Support Group for Ukraine  

Small- and Medium-Sized Enterprises 

Single Support Framework 

Treaty on the European Union 

Trust Fund 

Terms of Reference 

Union for the Mediterranean 

United Nations 

United Kingdom 

Climate Change Framework Convention on Climate Change 

United States Agency for International Development 

Value-Added Tax 

Vocational Education and Training 

World Bank 

56 

 
 
Annex  5.  External  evaluators'  report,  including  its  annexes  and 
methods and analytical models used 

"The  external  evaluation  can  be 
consultation-external-financing-instruments-european-union_en" 

found  here:  https://ec.europa.eu/europeaid/public-

57