COMMISSION STAFF WORKING DOCUMENT Interim Evaluation of the Internal Security Fund - Borders and Visa 2014-2017 Accompanying the document Report from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions on interim evaluation of the Asylum, Migration and Integration Fund and the Internal Security Fund
Date: 2018-06-12
Institutions: Directorate-General for Migration and Home Affairs, European Commission
Subjects: EU migration policy, EU visa policy, Schengen Agreement, external border of the EU, fund (EU), migration control, public safety

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 12.6.2018 SWD(2018) 340 final  COMMISSION STAFF WORKING DOCUMENT Interim Evaluation of the Internal Security Fund - Borders and Visa 2014-2017 Accompanying the document Report from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions  on interim evaluation of the Asylum, Migration and Integration Fund and the Internal Security Fund  {COM(2018) 464 final} - {SWD(2018) 339 final} - {SWD(2018) 341 final}  
 
 
Table of contents 

3. 

ABBREVIATIONS ................................................................................................................................................................. IV 
EXECUTIVE SUMMARY......................................................................................................................................................... 1 
INTRODUCTION .......................................................................................................................................................... 3 
1. 
BACKGROUND TO THE INTERVENTION ....................................................................................................................... 4 
2. 
2.1  Baseline ................................................................................................................................................................ 4 
2.2  Description of ISF-BV and its objectives ........................................................................................................... 10 
IMPLEMENTATION / STATE OF PLAY ........................................................................................................................ 15 
3.1  Description of the implementation process ........................................................................................................ 15 
3.2  Description of the implementation status ........................................................................................................... 16 
4.  METHOD .................................................................................................................................................................. 27 
4.1  Short description of methodology ...................................................................................................................... 27 
4.2  Evaluation questions ........................................................................................................................................... 28 
4.3  Limitations and robustness of findings ............................................................................................................... 28 
5.  ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS ..................................................................................... 30 
5.1  How effective has ISF-BV been so far? ............................................................................................................. 30 
5.2  How efficient has ISF-BV been so far? .............................................................................................................. 37 
5.3  How much simplification and reductions of administrative burden has ISF-BV brought so far? ...................... 40 
5.4  How relevant has ISF-BV been so far? .............................................................................................................. 44 
5.5  How coherent and complementary has ISF-BV been so far? ............................................................................. 49 
5.6  What is the EU added value of ISF-BV so far? .................................................................................................. 54 
5.7  How sustainable are the actions implemented under ISF-BV so far? ................................................................ 57 
CONCLUSIONS AND ISSUES FOR FURTHER CONSIDERATION ...................................................................................... 59 
6.1  Effectiveness ...................................................................................................................................................... 59 
6.2  Efficiency ........................................................................................................................................................... 61 
6.3  Simplification of management procedures and reduction of administrative burden .......................................... 61 
6.4  Relevance ........................................................................................................................................................... 62 
6.5  Coherence and complementarity ........................................................................................................................ 62 
6.6  EU Added Value ................................................................................................................................................ 63 
6.7  Sustainability ...................................................................................................................................................... 64 
ANNEX 1: PROCEDURAL INFORMATION ............................................................................................................................. 65 
ANNEX 2: STAKEHOLDER CONSULTATION ......................................................................................................................... 66 
ANNEX 3: COST/BENEFIT ANALYSIS .................................................................................................................................. 71 
ANNEX 4: EVALUATION QUESTIONS .................................................................................................................................. 74 

6. 

iii 

 
 
 
 
 
 
EMAS 

Emergency assistance 

framework 

European Refugee Fund 

IOM 

International Organisation 
for Migration 

ABBREVIATIONS

AMIF 

Asylum Migration and 
Integration Fund 

BCPs 

Border crossing points  

CIPS 

Specific programme 
Prevention, Preparedness 
and Consequence 
Management of Terrorism 
and Other Security-related 
Risks 

DG 
CONNECT 

DG Communications 
Networks, Content & 
Technology 

DG HOME  Directorate-General for 

Migration and Home 
Affairs 

DG MOVE  DG Mobility and Transport 

DG NEAR  DG Neighbourhood and 

Enlargement Negotiations 

DG 
TAXUD 

DG Taxation and Customs 
Union 

EBCGA 

European Border and Coast 
Guard Agency (Frontex) 

EBF 

EES 

EIF 

External Borders Fund 

Entry/Exit System  

European Fund for the 
Integration of Third-
Country Nationals 

ERF 

EU 

eu-LISA 

European Union 

European Agency for the 
operational management of 
Large-Scale IT Systems in 
the area of freedom, 
security and justice 

Eurostat 

Statistical office of the 
European Union 

FTD 

Facilitated Transit 
Document 

FTE 

Full-time Equivalent 

FRTD 

IBM 

ISEC 

Facilitated Rail Transit 
Document 

Integrated border 
management  

Specific programme 
prevention of and fight 
against organised crime 

ISF 

Internal Security Fund 

ISF-BV 

ISF Borders and Visa 

ISF-P 

ISF Police 

ISS 

MFF 

Internal security strategy 

Multiannual financial 

Member 
States 

Member State(s) 
participating in ISF-BV 
incl. SAC 

PNR 

RF 

RTP 

SAC 

Passenger name record 

European Return Fund 

Registered traveller 
programme 

Schengen associated 
countries 

SOLID 

General programme 
solidarity and management 
of migration flows 

SFC2014  Shared Fund Management 

Common System of the 
Commission 

SSL 

Security and safeguarding 
liberties programme 

List of countries 

AT 

BE 

BG 

CH 

CY 

CZ 

DE 

Austria 

Belgium 

Bulgaria 

Switzerland 

Cyprus 

Czech Republic 

Germany 

DK 

Denmark 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IS 

Estonia 

Greece 

Spain 

Finland 

France 

Croatia 

Hungary 

Iceland 

Italy 

Liechtenstein 

Lithuania 

Luxembourg 

Latvia 

Malta 

Netherlands 

Norway 

PL 

PT 

RO 

SE 

SI 

SK 

UK 

Poland 

Portugal 

Romania 

Sweden 

Slovenia 

Slovakia 

United Kingdom 

IT 

LI 

LT 

LU 

LV 

MT 

NL 

NO 

iv 

 
 
EXECUTIVE SUMMARY 

This  Commission  staff  working  document  (SWD)  examines  the  impact  of  the  Internal  Security 
Fund — Borders and Visa (ISF-BV) covering the period between 1 January 2014 and 30 June 20171 
against eight evaluation criteria: (i) effectiveness, (ii) efficiency, (iii) simplification and reduction of 
administrative  burden,  (iv)  relevance,  (v) coherence,  (vi) complementarity,  (vii) EU  added  value 
and (viii) sustainability. For the programming period 2014-2020, EUR 2.609 billion was allocated 
for  the  management  of  the  EU’s  external  borders  and  visa  policy.  The  Fund  aimed  to  establish 
financial solidarity between Member States by supporting those countries that would experience a 
heavy burden in implementing the common standards for control of the EU’s external borders. 

The assessment focuses on the performance of the ISF-BV’s financial support for the management 
of the EU’s external borders, including at the level of the various individual policy  themes which 
are  major  constituents  of  the  concerned  EU  policy  such  as  organising  controls  and  managing  the 
flows of people at the EU’s external borders. 

During the implementation period under review, migration conditions changed to another paradigm 
as Europe experienced a sudden and unexpected increase in migratory pressure on its southern and 
south-eastern external borders. Therefore, as the migration and security conditions underpinning the 
design  of  the  funding  instrument  in  2011  changed  drastically,  new  needs  and  funding  priorities 
arose  in  order  to  further  protect  the  EU’s  external  borders,  an  area  where  the  absence  of  internal 
border controls was significant. 

The evaluation concludes that ISF-BV support is essential for carrying out the investments required 
to improve the EU’s external border management systems. The ISF-BV is contributing crucially to 
the  application  of  the  Schengen  acquis2  considering  the  increase  of  migration  flows  since  2011, 
especially  in  2014  and  2015.  The  Fund  is  tackling  fragmentation  by  supporting  the  development 
and improvement at the national level of large IT systems, such as the Visa Information System and 
the  second  generation  Schengen  Information  System  (SIS  II),  as  well  as  contributing  to  their 
coherent and effective use throughout all Member States. The ISF-BV is also encouraging a better 
use of resources by increasing the capacity of Member States to undertake border surveillance and 
by developing consular cooperation between Member States. 

The  evaluation  gave  evidence  that,  in  the  challenging  migration  and  security  context  described 
above, the funding instrument is, overall, flexible enough to respond to the changing needs resulting 
from  the  migration  crisis  by  shifting  resources  to  the  affected  Member  States,  also  through 
emergency assistance (EMAS). 

Lastly,  the  evaluation  has  found  that  the  ISF-BV  is  prompting  or  contributing  to  the  set-up  of 
comprehensive management and control systems, through (i) good coordination with the European 
Commission, (ii) applying stringent procurement procedures, and (iii) ex post audits of projects and 
monitoring arrangements. Therefore, the ISF-BV is promoting the reasonable use of EU financing 
in the field of border management. 

1   Commission delegated Reg. (EU) 2017/207 of Oct. 3rd 2016 on the Common Monitoring and Evaluation Framework (CMEF) 
provided for in Reg. (EU) No 514/2014 of the European Parliament and of the Council laying down general provisions on the 
AMIF and on the ISF. 

2    The Schengen acquis is derived from the 1990 Schengen Convention to implement the 1985 Schengen agreement, which 
abolished checks at the internal borders of a number of EU Member States by 1995, creating the ‘Schengen Area’. 

1 

 
 
 
 
 
 
 
 
 
                                                 
Based on the interim evaluation, the following conclusions have been drawn. 

 

ISF-BV’s  effectiveness  has  been  impacted  by  the  migration  and  security  crisis,  which  put 
enormous  pressure  on  the  EU’s  external  borders  and  caused  some  Member  States  to 
reintroduce temporary internal border control measures. Regarding the common visa policy, 
the  Fund  has  helped  to  implement  it  through  better  consular  coverage,  harmonisation  of 
procedures,  facilitating  legitimate  travel,  organising  information  exchanges  and  training 
courses  and  supporting  the  development  of  common  IT  systems.  The  Fund  has  also 
contributed  to  the  development  of  integrated  border  management  policy,  which  increased 
solidarity  among  Member  States  by  co-financing  equipment  used  in  Frontex  joint 
operations.  It  has  also  contributed  to  the  development  of  the  EU’s  acquis  on  border 
the  European  Border  Surveillance  system  (EUROSUR),  and  border 
management, 
management  IT  systems.  However,  consular  cooperation  and  cooperation  with  third 
countries attracted less attention from Member States than expected. 

  The results of ISF-BV so far have been achieved at a reasonable cost in terms of both human 
and  financial  resources,  but  the  administrative  burden  appears  to  be  the  main  factor 
undermining  efficiency.  Even  if  national  programmes  have  been  very  slow  to  begin,  the 
Fund’s  overall  implementation  appears  to  be  on  track,  as  EMAS  bridged  the  funding  gap 
and  catered  to  immediate  needs.  This  was  facilitated  by  the  flexible  approach  applied  to 
EMAS management. 

  The management and control measures have been considered to be appropriate and efficient, 

with stringent mechanisms to ensure fraud and irregularities are prevented. 

  There  is  little  evidence, at  this  stage,  that  the  administrative  burden  has  been  significantly 
reduced,  though  ISF-BV  has  led  to  simplification  relative  to  the  past.  Several  new 
administrative and managerial procedures were introduced, taking into account the lessons 
learnt  from  the  previous  funds,  including  the  adoption  of  the  Better  Regulation  guidelines 
and toolbox and the collection of indicators in order to ensure a more appropraiate measure 
of performance. 

 

ISF-BV is relevant and its original rationale and objectives remain largely valid even though 
the  migration  crisis  has  brought  much  more  focus  on  how  the  EU’s  external  borders  are 
managed. Member States are calling for more flexibility measures. 

  The Fund has been found to be coherent with and complementary to other national and EU 

interventions. 

  The  Fund’s  EU  added  value  has  been  illustrated  both  from  a  policy  and  financial 

perspective. 

  Many  ISF-BV  actions  are  long-term  actions  by  their  nature,  since  they  are  generally 
designed to remain operational beyond the Fund’s support, while the sustainability of other 
actions  relies  on  other  sources  of  national  or  EU  funding.  Training  activities  and  other 
cooperation mechanisms have also contributed to the increased sustainability of actions. 

2 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
1. INTRODUCTION 

This  Commission  SWD  presents  the  interim  evaluation  of  the  Internal  Security  Fund  —  Borders 
and  Visa  (ISF-BV)  in  line  with  Article 57  of  Regulation  (EU)  No  514/2014  of  the  European 
Parliament and of the Council, the Commission Delegated Regulation (EU) 2017/207 and the Better 
Regulation Guidelines3. 

Member States  submitted to  the Commission interim evaluation  reports on the implementation  of 
actions  and  progress  towards  achieving  the  objectives  of  their  national  programmes  by 
31 December  2017.  On  the  basis  of  these  reports,  the  Commission  must  submit  an  interim 
evaluation  report  on  the  implementation  of  Regulation  (EU)  No  513/2014,  Regulation  (EU)  No 
514/2014  and  Regulation  (EU)  No  515/2014  to  the  European  Parliament,  to  the  Council,  to  the 
European Economic and Social Committee and to the Committee of the Regions by 30 June 2018. 

The purpose of the interim evaluation of the ISF-BV is to: 

1)  ensure  transparency  and  accountability  in  the  ISF’s  implementation,  the  general  objective  of 
which is to ensure a high level of security within ‘an area of freedom, security and justice’; and 

2)  help  make  the  future  implementation  of  EU  instruments  in  the  fields  covered  by  ISF  more 
relevant,  effective,  efficient,  and  sustainable  and  enable  them  to  provide  EU  added  value  and 
simplification measures as well as reduce administrative burden. 

This evaluation looks at the progress made in implementing the programme, and assessed whether 
corrective  actions  are  needed  to  make  sure  that  the  programme  delivers  as  planned.  It  also 
contributed to the preparation of the next generation of funding instruments (the successors of ISF-
BV), under the post-2020 multiannual financial framework (MFF). 

This evaluation covers all EU Member States, except Ireland and the United Kingdom that do not 
participate  in  ISF-BV.  In  addition,  the  evaluation  covers  Switzerland,  Iceland,  Liechtenstein  and 
Norway,  who  are  associated  with  the  programme  due  to  the  fact  that  they  fully  implement  the 
Schengen  acquis4. The  evaluation  covers  the  period  from  1 January  2014  until  30 June  2017  and 
covers  the  national  programmes  of  the  participating  countries,  including  specific  actions  and 
technical assistance as well as Union actions and emergency assistance. 

https://ec.europa.eu/info/files/better-regulation-guidelines_en 

3  
4   Throughout this document the term Member States (Member States) refers to the following group of countries: EU Members 

States without the UK and Ireland and also including Switzerland, Iceland, Liechtenstein and Norway. 

3 

 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
2. BACKGROUND TO THE INTERVENTION 

2.1  Baseline 

Policy context 

One  of  the  EU’s  overarching  objectives  is  to  offer  its  citizens  ‘an  area  of  freedom,  security  and 
justice  with  respect  for  fundamental  rights  and  the  different  legal  systems  and  traditions  of  the 
Member  States’  (Art.  67  TFEU).  It  has  been  on  top  of  the  EU  policy  agenda  since  the  Tampere 
Council  Conclusions  in  19995.  To  achieve  this  goal,  the  Member  States  have  to  make  a  common 
effort to invest in the protection and security of their common external borders. 

The Schengen area is one of the EU’s greatest achievements. It is an area without internal borders 
where  the  people  are  ensured  of  the  right  to  free  movement  without  being  subjected  to  border 
checks. Schengen states have improved and tightened controls at their common external borders on 
the basis of common rules to ensure the security of those living or travelling in the Schengen area 
and to prevent illegal entry, while facilitating legitimate travel. The Schengen  acquis provides for 
common rules and procedures to be applied by signatory states with regard to short-term visas and 
border controls. Therefore, all signatory states needed to contribute to ensuring a high and uniform 
level of control on individuals and surveillance of the EU external borders. 

The  consolidation  and  functioning  of  the  Schengen  area  requires  an  overall  border  policy 
architecture  at  the  EU  level  supporting  the  components  of  the  common  integrated  border 
management (IBM) strategy. The IBM concept encompasses three dimensions6: 

  a  common  corpus  of  legislation,  in  particular  the  Schengen  Borders  Code  as  well  as  the 

Regulation on local border traffic; 

  operational  cooperation  between  Member  States,  including  cooperation  as  coordinated  by 

Frontex; 

  solidarity between Member States and the EU through the establishment of an External Borders 

Fund. 

However,  the  burden  borne  to  implement  the  common  standards  for  control  of  the  EU’s  external 
borders  varied  significantly  from  Member  States  to  Member  States.  These  variations  were 
explained  through  the  differences  between  Member  States  in  terms  of  (i)  the  geography  of  their 
external  borders,  (ii) the  number  of  border  crossing  points  (BCPs),  (iii)  the  level  of  migratory 
pressure,  (iv) the  risks  and  threats  encountered  and  (v)  the  number  of  Schengen  visa  applications 
received. 

The  Council  identified  the  External  Borders  Fund  (EBF),  the  first  funding  instrument  that  deals 
with borders, as one of the three dimensions of IBM. The EBF’s general objectives were to increase 
the efficiency of control and management of flows of people at the external borders, as well as unify 
the  implementation  of  the  EU  legislation  on  the  crossing  of  external  borders  and  improve  the 
management of activities organised by consular services. The EBF was implemented under shared 
management  arrangements,  by  means  of  annual  national  programmes.  It  also  funded  Community 
and  specific  actions,  which  were  managed  at  the  initiative  of  the  European  Commission  (direct 
management) and implemented by the Member States. 

5   Tampere European Council 15 and 16 October 1999 Presidency Conclusions. 
6   Council Conclusions, Justice and Home Affairs, 2768th Council Meeting, Brussels, 4-5 December 2006. 

4 

 
 
 
 
 
 
 
 
 
 
 
                                                 
The EBF was one of the four7 EU funding instruments established in 2007 as part of the framework 
programme  on  Solidarity  and  Management  of  Migration  Flows8  (SOLID).  It  was  also  part  of  a 
wider policy package which also included the Frontex Agency9, the Schengen Borders Code10 and 
the Schengen Evaluation Mechanism11. The EBF, backed by funding of EUR 1.82 billion, intended 
to fully support the following five priorities12: 

a)  creating a common integrated border management system to carry out checks on people and 

for the surveillance of the external borders; 

b)  further  developing  and  implementing  the  national  components  of  a  European  Surveillance 
System  for  the  EU’s  external  borders  and  a  permanent  European  Patrol  Network  for  the 
southern maritime borders; 

c)  issuing visas and tackling illegal immigration; 
d)  establishing the IT systems required to implement EU border and visa legislation; and 
e)  promoting the effective and efficient application of EU border and visa legislation13. 

The work towards achieving the IBM is a long-term and complex process, which benefitted from 
the support of the EBF. However, not all components were covered by the Fund. For instance, the 
consolidation and the functioning of the Schengen Area requires the Member States to acquire and 
develop the skills and obtain the equipment and technology necessary to be operational within IBM 
at EU level. Also, while being implemented, the EBF had to face the following challenges indicated 
in the table below. 

Table 1: Overview of expected challenges for the Member States and the EU in the period 2014-202014 

Policy 
challenges in 
the area of 
border 
management 
and visa 

  The  length  of  the  external  border  and  the  number  and  nature  of  border  crossing 
points vary widely between Member States. The responsibilities for border control 
differ  considerably  from  Member  States  to  Member  States,  resulting  in  some  of 
them  bearing  a  disproportionate  share  of  the  associated  costs.  Therefore,  Member 
States at the EU’s periphery with long borders and with many border crossing points 
have  bigger  responsibilities  than  other  Member  States  to  prevent  irregular 
migration, facilitate bona fide cross-border movements and provide security. 

  Member  States  do  not  only  issue  visas  in  their  own  interest,  but  they  have  a 
common  interest  in  applying  common  standards  as  people  holding  a  visa  or 
residence permit from an Member States can move freely to other countries. 

  To  promote  solidarity,  the  EBF  aimed  towards  achieving  a  fair  share  of  the 
responsibilities  between  Member  States  taking  into  account  the  financial  burden 
arising  from  the  introduction  of  integrated  management  of  the  EU’s  external 
borders.  

7   The other three funds are the European Refugee Fund (ERF), the European Fund for the Integration of Third-Country Nationals 

(EIF), and the European Return Fund (RF). 

8   COM (2005) 123 final, Communication establishing a framework programme on Solidarity and the Management of Migration 

Flows for the period 2007-2013, European Commission, 6 April 2005. 

9    Council  Regulation  (EC)  No  2007/2004  of  26  October  2004  establishing  a  European  Agency  for  the  Management  of 
Operational  Cooperation  at  the  External  Borders  of  the  Member  States  of  the  European  Union,    OJ  L  349,  25.11.2004,  p.  1. 
Frontex  has  now  been  replaced  by  the  European  Border  and  Coast  Guard  Agency  as  per  Regulation  (EU)  2016/1624  of  14 
September 2016 on the European Border and Coast Guard (OJ L 251, 16.9.2016, p. 1). 

10   Regulation (EU) No 562/2006 establishing a Community Code on the rules governing the movement of persons across borders 

(Schengen Borders Code), 15 March 2006. 

11   Council Regulation (EU) No 1053/2013 establishing an evaluation and monitoring mechanism to verify the application of the 

Schengen acquis and repealing the Decision of the Executive Committee of 16 September 1998 setting up a Standing 
Committee on the evaluation and implementation of Schengen, 7 October 2013. 

12   Commission Decision 2007/599 /EC of 27 of August 2007 Implementing Decision No 574/2007/EC of the European Parliament 

and of the Council as regards the adoption of strategic guidelines for 2007 to 2013. 

13   The EU External Borders Fund (EBF): European Court of Auditors’ Special Report No 15/2014. December 2014. 
14  

Impact assessment accompanying the proposal for the home affairs funds in 2014-2020 (SEC(2011)1358 of 15.11.2011). 

5 

 
 
 
 
 
 
                                                 
In addition, the future ISF-BV fund was also to address and tackle certain needs and priorities that 
the EBF was not able to deal with, such as: 

a)  further developing an integrated border management system; 
b)  strengthening the operational capabilities of the Member States within EUROSUR; 
c)  maintaining  the  large-scale  IT  systems  (i.e.  Schengen  Information  System  II15,  Visa 

Information System16 or the functioning of an IT agency); 

d)  developing new IT systems, such as the Entry-Exit System (EES) or the registered traveller 

programme (RTP); 

e)  control measures within the area of free movement; and 
f)  support inter-agency cooperation17. 

In  a  parallel  development,  the  internal  security  strategy  (2010-2014)  (ISS)  enabled  the  EU  to 
improve  the  preparedness  and  respond  to  existing  and  emerging  threats  to  the  overall  European 
society. Significant progress was made under the fourth strategic objective of the ISS; strengthening 
security through border management. In relation to this objective, four key actions were identified: 
1) exploit the full potential of EUROSUR; 2) boost Frontex’s contribution at the external borders; 
3) undertake common risk management for moving goods across external borders, and 4) improve 
inter-agency cooperation at national level18. 

The results under the actions above were:  

a) the entry into force at the end of 2013 of EUROSUR; 
b) a new Schengen governance legislation19;  
c) introduction of the Schengen Information System II; 
d) Visa Information System; and 
e)  legislative  proposals  for  an  EES and  an  RTP  (which  would  later  become  the  Passenger 

name record (PNR)). 

Also, the ISS identified future challenges for the EU, both at an internal and external level, related 
to social crises, people’s mobility, demographic changes and/or political instability. Therefore, the 
ISS outlined the following challenges that future strategies and funds should tackle in the coming 
years: 

a) address the further increase in the amount of people coming to the EU; 
b) ensure all Member States sufficiently control their corresponding section of the external 

borders; 

c) ensure solidarity mechanisms are put in place to support Member States under pressure; 
d) support the adoption of the EES and RTP; 
e) ensure the Schengen Information System II operates effectively; 
f) explore the feasibility of establishing a European System of Border Guards and; 
g) devise  a  strategy  and  action  plan  for  the  security  of  the  supply  chain  and  risk 
management, and contribute to its implementation. 

15   The Schengen Information System (SIS) is a highly efficient large-scale information system that supports external border 

control and law enforcement cooperation in the Schengen States. 

16   The Visa Information System allows Schengen States to exchange visa data. It consists of a central IT system and a 

communication infrastructure that links this central system to national systems. 
Impact assessment accompanying the proposal for the home affairs funds in 2014-2020 (SEC(2011)1358 of 15.11.2011). 

17  
18   Final implementation report on the ISS (COM(2014) 365). 
19   Regulation (EU) No 1053/2013; Regulation (EU) No 1051/2013. 

6 

 
 
 
 
 
 
 
 
 
                                                 
In  addition,  Member  States  identified  the  following  key  risks  and  problems20  at  the  EU  external 
borders in 2014: (i) large numbers of illegal border crossings at the external land and sea border; (ii) 
document frauds to circumvent border control measures; and (iii) cross-border crimes and travellers 
who intend to commit crime or terrorism within the EU. 

The  2015  European  Agenda  on  Security21  was  launched  almost  in  parallel  with  the  beginning  of 
ISF-BV’s  implementation.  Since  then,  the  Agenda  has  been  providing  strategic  direction  for  the 
Fund in areas where financial support would bring more added value, such as: 

a)  further development, improvement and optimisation of the Schengen Information System; 
b)  the interlinking of the Schengen Information System with Interpol’s database on stolen and 

lost travel documents (SLTD); 

c)  common risk indicators to support the work of national border authorities when conducting 

checks on people; 

d)  unifying standards of border management; and 
e)  complementary measures to improve security in relation to the movement of goods. 

Funding context 

The  share  of  funding  for  home  affairs  in  the  EU  budget  was  relatively  small  but  it  has  steadily 
grown  (over  the  period  2007-2013  it  amounted  to  EUR 6.45  billion  or  0.77 %  of  the  total  EU 
budget.  It  covered  the  financing  programmes,  and  it  provided  funding  for  large-scale  IT  systems 
(Visa  Information  System,  Schengen  Information  System,  Eurodac)  and  the  agencies).  The 
spending during this period was characterised by heavy ‘back-loading’, increasing from EUR 500 
million in 2007 to EUR 1.5 billion in 2013. Such funding and the corresponding increase enabled 
the EU to tackle several policy challenges during 2007-2013, as described above. 

The table below represents a comparative overview between the EBF and ISF-BV in relation to the 
budget, participation and objectives. 

Table 2: Overview of the Funds related to borders and visa in the periods 2007-2013 and 2014-2020 22 

General 
programme 

Policy 
area 

Fund / Specific programme 
Budget, participation & objectives 

General 
programme 
Solidarity and 
Management 
of Migration 
Flows 

(93 % to 96 % 
shared 

Asylum 

Previous funds 

European Refugee Fund (ERF III) 
EUR 614 million23, all Member States 
except DK 

 Support  and  encourage  Member  States  in 
receiving refugees and displaced persons 
 Emergency  measures  to  address  sudden 
if  migrants  and  asylum 

influx 

mass 
seekers 

Current funds 
Asylum Migration and 
Integration Fund 
(AMIF, 2014-2020) 
EUR 3.137 million (initial), 
all Member States except DK 

 Strengthen and develop all 

aspects of the CEAS 

 Support legal migration to 

20   Those risks were defined in 2014 by the Frontex Risk Analysis Unit after an Annual Analytical Review with Member State 

analysts participating in the Frontex Risk Analysis Network. 

21   Communication from the Commission COM(2015) 185 final. Strasbourg, 28.4.2015. 
22   A full comparative table including all previous and current home affairs funds can be found in Annex 5. 
23   After adoption of EASO; takes account of Decision No 458/2010/EU amending the ERF basic act. 

7 

 
 
 
 
 
 
 
 
 
                                                 
 
 
 
 
 
management; 
remainder 
under 
centralised 
direct 
management) 

Integration 
of legally 
residing 
TCNs, legal 
migration 

Return  

Integrated 
border 
management 
and visa  

Prevention 
of and fight 
against 
organised 
crime 

Combating 
terrorism 
and other 
security-
related risks 

General 
programme 
Security and 
Safeguarding 
Liberties 
(centralised 
direct 
management) 

European Fund for the Integration of Third-
Country Nationals (EIF) 
EUR 825 million, all Member States except 
DK 
 Support 

integration  of  non-EU 

the 

immigrants into European societies 

European Return Fund (RF) 
EUR 676 million, all Member States except 
DK 

 Improve return management 
 Encourage 
cooperation 
development 
between  Member  States  and  countries  of 
return 

External Borders Fund, (EBF) 
EUR 1.820 million, all Member States 
(including RO & BG and the Schengen 
associated states from 2010) except the UK 
and IE 

 Financial 
countries 

solidarity  among  Schengen 

 Manage efficient controls and the flows at 

the external borders 

 Improve  management  of 

the  consular 

authorities 

Specific programme Prevention of and Fight 
against Organised Crime (ISEC) 
EUR 600 million, all Member States 
 Crime  prevention, 

enforcement, 
witness  protection  and  support,  victims 
protection 

law 

Specific programme Prevention, 
Preparedness and Consequence Management 
of Terrorism and Other Security-related 
Risks (CIPS) 
EUR 140 million, all Member States 
 Protection 

critical 
citizens 
infrastructure  from  terrorist  attacks  and 
other security incidents 

and 

of 

the Member States and 
promote effective 
integration of third-country 
nationals 

 Strengthen fair and effective 

return strategies and 
contribute to combating 
illegal immigration 

 Strengthen solidarity and 
responsibility sharing 
between Member States, 
particularly those most 
affected by the migratory 
flows 

Internal security Fund 
(ISF, 2014-2020) 
EUR 3.764 million (initial) 

ISF-Borders and Visa 
All Member States except IE 
and UK plus the Schengen 
associated states CH, IS, LI, 
NO 

 Ensuring a high level of 
security in the EU and 
facilitate legitimate travel 
 Visa and support integrated 

border management 

ISF-Police 
All Member States except DK 
and UK 

 Ensure a high level of 

security in the EU, fight 
against crime, manage risks 
and crisis 

The four different SOLID funds complemented each other and provided a holistic approach to home 
affairs  funding.  However,  there  were  weaknesses,  identified  by  the  ex  post  evaluations,  and  the 
European  Court  of  Auditors  special  reports24,  as  well  as  during  the  Commission’s  impact 
assessment  that  accompanied  its  proposals  for  the  2014-2020  generation  of  home  affairs  funds25. 
Those weaknesses included: (i) a lack of effective monitoring and evaluation systems; (ii) a lack of 
common  indicators  with  measurable  targets;  (iii)  high  administrative  burdens;  and  (iv)  delays  in 
providing evaluation reports at both at Member States and Commission level. 

To counter these weaknesses, recommendations were proposed which included, among others: 

24   ECA (2012) Special report No. 22, Do the European Integration Fund and the European Refugee Fund contribute effectively to 
the integration of third-country nationals? & ECA (2014) Special report No.15, The External Borders Fund has fostered 
financial solidarity but requires better measurement of results and needs to provide further EU added value. 

25   SEC(2011) 1358 final of 15.11.2011. 

8 

 
 
 
                                                 
 
 
 
 
 
 
 
 
 

the adoption of a broader framework to: 

o  allow the funds to adapt to the Member States objectives and changing needs; 
o 

to focus on pressing issues and where needs are the largest; 

  a harmonised approach across all EU funding streams; 
 

the  improvement  of  monitoring  and  evaluation  tools  and  capacities  at  EU,  Member  States 
and project levels; 
the  improvement  of  sustainability  by  awarding  funding  based  on  innovation  and 
sustainability of proposals. 

 

The EBF ex post evaluation’s final report and the EBF SWD also identified several issues, lessons 
and recommendations to be considered, which are detailed in the table below. 

Table 3: Lessons learnt from the EBF and how ISF-BV approached them 

Lessons learnt from the EBF ex post 
evaluation … 
The EBF had a complex architecture, as it consisted 
of four broad objectives, numerous specific 
objectives and five priorities. The aim was to keep 
the Fund concrete and operational but this was not 
achieved. 
There were difficulties linked to evaluation 
limitations when assessing the EBF’s overall 
effectiveness at EU level. The lack of an initial 
baseline and the fact that the EBF’s monitoring and 
evaluation system did not allow for detailed 
monitoring and assessment of the Fund’s 
performance. Set indicators were rather weak and 
monitoring data were not fully reliable. 

The EBF was implemented through a strategic 
multiannual programme covering the whole 
programming period. However, annual 
programmes were adopted yearly, which was 
considered by some Member States a heavy 
administrative burden. 
Eligibility limitations were detected that prevented 
some actions from being implemented. 

The specific actions did not have a clear targeted 
focus. This was also administratively complicated to 
implement and resulted in an overlap with EMAS 
and projects implemented under the annual 
programme.  

Under ISF-BV … 

  The  architecture  was  simplified  as  ISF-
Borders  and  Visa  includes  only  two  specific 
objectives (one for Borders and one for Visa) 
supported by seven operational objectives. 

a) 

b) 

  A  list  of  common  indicators  has  been 
included in the Fund’s legal base. Moreover, 
Delegated  Regulation  (EU)  2017/207  was 
adopted  in  October  2016  on  the  common 
monitoring and evaluation framework for ISF-
Borders and Visa. The following was adopted 
to improve the monitoring of the Fund: 
a  set  of  evaluation  questions  and  indicators 
were  included  in  the  framework  mentioned 
above; 
a  guidance  document  on  the  monitoring  and 
evaluation framework for Member States was 
created; 
a  common  template  for  Member  States  to 
submit the evaluation reports and; 
an  Evaluation  Network  was  created  for 
Member  States  staff  and  the  Commission  to 
discuss and resolve evaluation-related matters.  
  A  single  multiannual  national  programme 
the  period  2014-2020  was 
which  covers 
introduced.  This  speeds  up 
the  funding 
process  and  decreases  administrative  burden 
by  allowing  Member  States  to  apply  national 
eligibility rules with some added flexibility.  

d) 

c) 

 

  There is operating support by which Member 
States can cover staff costs at border crossing 
points. 
It  was  decided  to  abolish  the  specific  action 
under direct management in the ISF-BV and 
shared 
such  actions 
to 
management to allow Member States to have 
more ownership and flexibility. 

include 

in 

9 

 
 
 
 
 
Member States showed little interest in developing 
projects related to consular cooperation. 
Countries receiving small volumes of funds had 
higher management costs. 

  There 

is  a  90 %  co-financing  rate 

in 

NATIONAL PROGRAMMEs. 

  A  threshold  has  been  set  to  ensure  that  each 
Member  States 
a  more 
is 
appropriate  amount  of  funding,  relative  to 
its needs, as a starting block and the allocation 
percentage  for  technical  assistance  has  been 
slightly increased. 

allocated 

Thus, ISF-BV is building on the lessons learnt from its predecessor, the EBF, in providing support 
to Member States for managing the EU’s external borders and the EU’s visa policy. For instance, 
ISF-BV has a larger scope than the EBF, which was more limited to border control and visa policy. 
Through  ISF-BV  the  EU  can,  for  example,  support  verification  measures  within  the  area  of  free 
movement  which  were  not  carried  nearby  the  external  borders.  It  can  also  support  inter-agency 
cooperation  and  the  building  of  connections  across  the  different  law  enforcement  authorities, 
including  those  working  within  the  territory  of  a  Member  State  (police,  border  guards,  customs, 
etc.)  under  an  internal  security  agenda.  ISF-BV  can  also  support  operational  activities  in  the 
Member States related to borders and visa such as staff costs, etc. 

This  SWD,  notwithstanding  its  main  purpose  of  ensuring  transparency  and  accountability,  and 
contributing  to  the  Fund’s  relevance,  effectiveness  and  efficiency,  is  also  looking  to  analyse  the 
extent to which the recommendations that came out of the ex post evaluations of SOLID have been 
taken into account in ISF-BV. 

2.2  Description of ISF-BV and its objectives 

In a nutshell 

ISF-BV  aims  at  ensuring  a  high  level  of  security  in  the  Union  while  facilitating  legitimate  travel, 
through a uniform and high level of control of the external borders and the effective processing of 
Schengen visas, in compliance with the Union’s commitment to fundamental freedoms and human 
rights,  and  is  expression  of  and  implemented  by  the  principle  of  solidarity  and  fair  sharing  of 
responsibility within the EU. 

The legal base of ISF-BV is Regulation (EU) No 515/2014 adopted by the European Parliament and 
the Council on 16 April 2014, and it is based on Article 77(2) of the TFEU. 

General and specific objectives of the ISF-BV 

The objectives for the ISF-BV are set out in Article 3 of the Regulation - the general objective of 
the  Fund  ‘ …shall  be  to  contribute  to  ensuring  a  high  level  of  security  in  the  Union  while 
facilitating  legitimate  travel,  through  a  uniform  and  high  level  of  control  of  the  external  borders 
and  the  effective  processing  of  Schengen  visas,  in  compliance  with  the  Union’s  commitment  to 
fundamental  freedoms  and  human  rights’.  This  general  objective  is  further  broken  down  in  two 
specific objectives on visa policy and border management: 

Specific objective 1: supporting a common visa policy 

10 

 
 
 
 
 
 
 
 
 
 
 
 
 
Applying common visa standards has become essential as people holding a visa or residence permit 
in the Schengen area can move freely from one Member States to another. Therefore, all Member 
States  share  a  common  interest  in  ensuring  that  the  EU’s  visa  policy  is  efficiently  and  securely 
applied.  Therefore,  the  ISF-BV  supports,  through  this  specific  objective,  capacity  building  in  the 
Member States in order to sufficiently implement the common visa policy. 

Specific objective 2: supporting integrated border management 

An efficient border control is crucial to ensuring the free movement of legally residing third-country 
nationals and EU citizens as well as ensuring internal security. As peripheral Member States control 
a  significant  length  of  the  EU’s  external  borders,  their  responsibilities  for  border  control  have 
become  overwhelming.  In  this  regard,  ISF-BV  supports,  through  this  specifc  objective,  (i) the 
further  harmonisation  of  the  border  management,  (ii)  the  sharing  of  information  between  the 
Member  States,  and  (iii) the  sharing  of  information  between  the  Member  States  and  the  Frontex 
Agency. 

To fulfil the specific objectives a number of operational objectives were defined26. 

Table 4: ISF-BV operational objectives 

Operational 
objectives 

(a) To promote the development, implementation and enforcement of policies to 
ensure  that  people,  regardless  of  their  nationality,  are  not  subject  to  checks  when 
crossing the EU’s internal borders, and to ensure efficient monitoring and checks are 
carried out on people crossing the EU’s external borders. 
(b)  To  gradually  establish  an  integrated  management  system  for  external  borders, 
based on solidarity and responsibility, particularly through: 

i. 

strengthening external border checks and surveillance systems, and inter-
agency cooperation between border guards, customs, migration, asylum and 
law  enforcement  authorities  of  Member  States  at  the  external  borders, 
including in the maritime border areas; 

ii.  measures  within  the  Member  States  territories  on  the  management  of 
external  borders  and  the  necessary  supporting  measures  on  document 
security, identity management and the interoperability of acquired technical 
equipment; 
any  measures  that  also  help  prevent  and  combat  cross-border  crime  at 
external borders concerning the movement of people, including trafficking 
in human beings and human smuggling. 

iii. 

(c) To promote the development and implementation of the common policy on 
visas  and  other  short-stay  residence  permits,  and  different  forms  of  consular 
cooperation  to  ensure  better  consular  coverage  and  harmonised  practices  on  visa 
issuing. 
(d) To set up and run IT systems, their communication infrastructure, and equip-
ment that support the common visa policy, border checks and border surveillance 
at  the  external  borders.  These  IT  systems  should  fully  comply  with  personal  data 
protection law. 
(e)  To  boost  situational  awareness  at  the  external  borders  and  the  reaction 
capabilities of Member States; 
(f)  To  ensure  the  EU’s  acquis  on  borders  and  visas  is  efficiently  and  uniformly 
applied,  including  the  effective  functioning  of  the  Schengen  evaluation  and 
monitoring mechanism; 
(g)  To  boost  actions  by  the  Member  States  that  are  helping  to  strengthen  
cooperation  between  Member  States  operating  in  third  countries  concerning  the 

26   Also, as set out in Article 3 of Regulation (EU) No 515/2014. 

11 

 
 
 
 
 
 
 
                                                 
flows  of  third-country  nationals  into  the  Member  States’  territory.  These  actions 
include  preventing  and  tackling  of  illegal  immigration,  as  well  as  cooperating  with 
third  countries  in  full  compliance  with  the  objectives  and  principles  of  the  EU’s 
external action and humanitarian policy 

2.2.1.  Global resources 

According  to  the  legal  base,  the  initial  global  resources  for  implementing  ISF-BV  in  the  period 
2014-2020  were  set  at  EUR 2.76  billion,  whereas  the  reprogrammed  amount  stands  at  EUR 2.61 
billion, as shown in the below figure. Further details in relation to the Fund’s implementation and 
its management modes are explained in Section 3 of this SWD. 

The funds allocated to NATIONAL PROGRAMMEs (65 %  of the total  reprogrammed  resources, 
including  the  Special  Transit  Scheme  (STS)27  for  Lithuania,  and  to  technical  assistance  at  the 
initiative  of  the  Commission  (0.46 %  of  the  total)  have  remained  unchanged.  In  response  to 
unforeseen  needs  caused  by  the  migration  crisis,  significant  differences  were  made  to  funds 
allocated to EMAS (the amount increased from an initial allocation of 1.3 % to 14.8 % of the total 
fund). Furthermore, UAs have decreased by a quarter so more EMAS can be provided. The Member 
States  received  an  additional  amount  of  EUR 192  million  to  purchase  equipment  to  be  used  in 
Frontex  joint  operations.  As  for  the  funds  available  for  IT  systems,  the  overall  allocation  of 
EUR 791 million has not changed - only the part to be implemented via ISF-BV has been reduced 
to  EUR 145.7 million with  the remaining amount  to  be implemented  via  the ‘Smart  Borders’ and 
‘Schengen Information System II’ budget lines managed by the Commission as well as directly by 
two EU agencies (eu-LISA and Frontex).         
Figure 1: Initial and reprogrammed global resources for 2014-2020 (EUR million) 

NPs

IT Systems

146 

791 

1705 
1705 

192 

167 

217 

387 

Frontex tops-ups

0 

UAs

EMAS

TA of EC

Total

35 

12 
12 

2609 

2760 

0

500

1000

1500

2000

2500

3000

Reprogrammed global resources

Initial global resources

2.2.2.  Eligible actions and beneficiaries 

27   Regulation (EU) No 515/2014, Chapter II, Article 11. 

12 

 
 
 
 
 
 
 
 
 
 
                                                 
All  Member  States  (except  IE  and  the  UK)  and  as  well  as  IS,  LI,  NO  and  CH  participate  in  the 
Fund’s  implementation.  The  Fund’s  beneficiaries  include  federal  and  national  authorities,  local 
public  bodies,  non-governmental  and  humanitarian  organisations,  private  and  public  law 
companies, education and research organisations. 

The ISF-BV supports actions in or by Member States, with a special focus on the ones shown in the 
table below, but maintains a wide scope to ensure full coverage of needs. 

Table 5: ISF-BV eligible actions 

ISF-BV 
ELIGIBLE 
ACTIONS 

a)  infrastructure,  buildings  and  systems  required  at  border  crossing  points  and 
for surveillance; 
b) operating equipment, means of transport and communication systems; 
c) IT and communication systems to manage migration flows efficiently; 
d)  infrastructure,  buildings,  communication  and  IT  systems  and  operating 
equipment; 
e) training in the use of the equipment and systems referred to in points (b), (c) 
and  (d)  and  the  promotion  of  quality  management  standards  and  training  of 
border guards; 
f)  secondment  of  immigration  liaisons  officers  and  document  advisers  to  third 
countries; 
g)  studies,  training,  pilot  projects  and  other  actions  that  gradually  establish  an 
integrated management system for external borders; 
the 
h)  studies,  pilot  projects  and  actions 
recommendations,  operational  standards  and  best  practices  resulting  from  the 
operational cooperation between Member States and EU agencies. 

implement 

that  aim 

to 

The Fund can also support actions in relation to or in third countries, such as: IT systems, training, 
promoting  the  development  and  implementation  of  the  common  policy  on  visas  or  boosting 
situational awareness. It also contributes to the financing of technical assistance at the initiative of 
the Member States and the Commission. 

2.2.3.  The Intervention Logic 

The intervention logic (see Figure 2) of the ISF-BV Fund is defined in order to understand what the 
Fund is aiming to achieve and how it will be achieved, by presenting the causal and logical links 
between problems, needs, objectives and eligible actions, as well as the connections between results 
and impacts. The implementation process is further explained in section 3.1. 

13 

 
 
 
 
 
 
 
 
 
 
 
Figure 2: Intervention logic for the interim evaluation of ISF-BV 

14 

 
 
 
 
 
 
 
 
 
 
 
 
3. IMPLEMENTATION / STATE OF PLAY 

3.1  Description of the implementation process 

ISF-BV  is  being  implemented  either  by  the  Member  States  (shared  management),  directly  by  the 
Commission (direct management), or indirectly by entrusting the budget implementation task to a 
third party28 (indirect management). 

Under  shared  management,  resources  are  allocated  through  national  programmes  to  be 
implemented  in  close  cooperation  with  competent  authorities  and  institutions.  Member  States 
implement national programmes which contribute to the EU’s policy objectives but which are also 
tailor-made according to their national context. This ensures a level-playing field among Member 
States, reduces the adverse effects of competition for funding, and brings predictability to funding 
allowing  Member  States  to  better  plan  their  actions.  Some  actions,  due  to  their  nature,  such  as 
transnational actions, innovative projects, support to civil society, and actions requiring funds to be 
mobilised  quickly  are  implemented  under  direct  management  by  the  Commission.  Aside  from 
actions to pursue the Fund’s specific objectives, within national programmes, each Member States 
‘may  use  up  to  40 %  of  the  amount  allocated  to  finance  Operating  Support  to  the  public 
authorities responsible for accomplishing the tasks and services that constitute a public service for 
the Union’29.  

In addition to the basic amount allocated to national programmes, Member States may also receive 
additional resources for the implementation of specific actions (SAs). SAs respond to EU priorities, 
in  particular:  ‘the  setting  up  of  consular  cooperation  mechanisms  between  at  least  two  Member 
States’  (SA1),  and  ‘the  purchasing  of  means  of  transport  and  operating  equipment  that  are 
considered  necessary  for  the  deployment  during  the  joint  operation  by  the  European  Border  and 
Coast  Guard  Agency  (EBCGA,  hereinafter  referred  to  as  Frontex)  and  that  shall  be  put  at  the 
disposal of the Agency’ (SA2)30. Shared management also includes the ‘Special Transit Scheme’31. 
This is a financial instrument that the EU granted to Lithuania to support the management of people 
transiting  between  the  Kaliningrad  region  and  the  rest  of  the  Russian  Federation,  through  EU 
territory,  by  means  of  the  Facilitated  Transit  Document  (FTD)  and  the  Facilitated  Rail  Transit 
Document (FRTD). 

At  the  beginning  of  the  programming  period,  all  Member  States  had  a  policy  dialogue  with  the 
Commission to enable them to prepare their national programmes. Based on the outcome of these 
dialogues, the Member States submitted their multiannual national programmes. The Commission 
examined these programmes, consulted Frontex and eventually approved each national programme. 
To implement their national programmes, Member States had to set up a management and control 
system32. The Commission follows the implementation under shared management by examining the 
annual implementation reports (AIRs) and accounts submitted by the Member States. 

A mid-term review of national programmes was planned for the middle of the programming period, 
i.e. in 2018. In addition, in order to evaluate the programmes, Member States are expected to submit 

28   These parties can be countries or the bodies they have designated, international organisations and their agencies. 
29   As outlined in Article 10 of Regulation (EU) No 515/201424 ‘Operating support shall be concentrated on specific tasks and/or 
services and shall be focused on the objectives as laid down in Annex III. It shall entail full reimbursement of the expenditure 
incurred to accomplish the tasks and/or services defined in the national programme, within the financial limits set by the 
programme and the ceiling laid down in paragraph 1.’ 

30   Regulation (EU) No. 515/2014, Annex II. 
31   Original earmarked resources: EUR 154 million. 
32   Horizontal Regulation (EU) 514/2014, Section 2. 

15 

 
 
 
 
 
 
 
 
                                                 
two  national  evaluation  reports:  an  interim  evaluation  report  by  the  end  of  2017  and  an  ex  post 
evaluation  report  by  the  end  of  2023.  The  Commission  will  take  these  reports  into  account  in  its 
interim and ex post evaluations of the Fund, which are to be sent to the European Parliament, the 
Council, the Economic and Social Committee and the Committee of the Regions by 30 June 2018 
and 20 June 2024 respectively. 

A  small  amount  of  money  equal  to  5 %  of  the  total  national  allocation  plus  EUR 0.5  million  is 
reserved in the national programmes for technical assistance. 

Moreover,  each  Member  States  needs  to  establish  a  partnership  with  relevant  stakeholders 
including, other public authorities, international organisations, NGOs and social partners in order to 
prepare, implement, monitor and evaluate the national programmes. Stakeholders meet regularly in 
a monitoring committee set up to follow the national programme’s implementation. 

For  direct  management,  it  is  the  Commission  that  centrally  and  directly  supervises  budget 
implementation  through  EMAS  and  UAs.  Funds  are  earmarked  by  the  EU  through  calls  for 
proposals,  procurement,  and  direct  awards,  as  planned  in  the  annual  work  programme33.  Under 
indirect  management, 
through  delegation  agreements,  budget 
implementation  tasks  to  Member  States  (or  to  bodies  designated  by  them),  international 
organisations, Member States development agencies, EU agencies, and other bodies, because they 
are  best  placed  to  carry  out  those  activities  and  also  because  of  the  limited  human  and 
administrative resources available in the Commission34. 

the  Commission  entrusts, 

3.2  Description of the implementation status 

3.2.1.  Shared management 

According  to  the  legal  base,  the  total  programmed  EU  contribution  for  shared  management  was 
EUR 2.496 billion consisting of EUR 1.705 billion for national programmes and EUR 791 million 
for the development of (existing and/or new) IT systems that support the management of migration 
flows across the external borders. The allocation to national programmes was further broken down 
to: 

  EUR 1.276 billion to national programmes, of which up to 40 % is available for operating 

support, with EUR 128 million to be distributed under the mid-term review; and  

  EUR 147 million for specific actions; and 
  EUR 154 million for the Special Transit Scheme.  

Regarding  funds  allocated  to  IT  systems,  only  EUR 145.7  million  will  be  provided  via  ISF-BV, 
with  the  remaining  amount  expected  to  be  provided  through  the  ‘Smart  Borders’  and  ‘Schengen 
Information  System  II’  budget  lines  managed  by  the  Commission  as  well  as  directly  by  two  EU 
agencies (eu-LISA and Frontex). 

At  the  end  of  the  interim  evaluation  period  26  national  programmes  were  approved35  and  the 
resources allocated for adopted national programmes stood at EUR 1.533 billion. 

33  The annual work programme is a planning document explaining how the budget allocated for certain policies or funding 

programmes will be spent. 

34   Commission staff working paper –impact assessment for the 2014-2020 funds (SEC(2011)1358). 
35   NO, CH, LI and IS are not approved in the period covered by the interim evaluation. 

16 

 
 
 
 
 
 
 
 
 
 
 
 
                                                 
By  31 December  201636,  Member  States  had  drawn  down  EUR 584  million  of  the  total  EU 
resources  available for the period 2014-2020 for national programmes  that  were adopted, with an 
implementation rate of 38 %. Total payments cleared under the accounts for 2014-2016 amounted 
to EUR 178 million, resulting in a very low payment rate of 12 %. 

Figure 3: ISF-BV shared management: Allocation of global resources to shared management 2014-2020 (EUR million)   

€ 3.000  

€ 2.500  

€ 2.000  

€ 1.500  

€ 1.000  

€ 500  

€ 0  

€ 2 496  
 -       

  791     

€ 2 043 

  192     
  146     

 1 705     

 1 705     

 -       
 -       

 1 533     

Programmed resources as per
legal base

Reprogrammed resources as of
30.06.2017

Resources corresponding to
adopted NPs

National Programmes

IT systems (ETIAS, EES, SIS II)

Frontex equipment top-ups

Disaggregating  data  by  ISF-BV’s  objectives  as  reflected  in  the  Shared  Fund  Management 
Common System of DG HOME (SFC201437), resources have been earmarked for specific objective 
Borders (with 55.9 % of the planned EU commitment/available EU resources for adopted national 
programmes), followed by operating support (with 20.7 %), STS (with 9.7 %) and specific objective 
Visa (with 9.6 %). 4.1 % was dedicated to technical assistance. 

Figure 4: ISF-BV — EU planned resources 2014-2020 under the specifc objectives for adopted national programmes 
(EUR million) 

36   The reference period for shared management ran from January 2014 until 31 December 2016, which corresponds to the period 

covered by the last set of accounts submitted by Member States and cleared by the Commission. 

37   SFC2014 is an IT system used for electronic exchange of information concerning shared fund management between Member 

States and the European Commission. 

17 

 
 
 
 
 
 
 
 
 
 
                                                 
STS 
  148    
10% 

TA 
  62    
4% 

Visa 
  148    
9% 

OS 
  318    
21% 

Borders 
  857    
56% 

For specific objective Visa, the Member States that spent the highest amounts on financed projects 
related  to  this  objective  are  France,  Spain,  Cyprus,  and  Italy,  with  EUR 24.1,  11.2,  9.6,  and  8 
million respectively. Member States that spent the lowest amounts are Estonia, Liechtenstein, and 
Iceland, with projects funded for less than EUR 1 million. 

  Three  Member  States  (Belgium,  the  Netherlands  and  Spain)  have  developed  activities  to 
strengthen consular cooperation through new or improved infrastructure and buildings (co-
locations, common application centres, representations and other infrastructural means). In 
particular, a total number of 4 actions — out of the 35 expected by national programmes — 
were put in place: 2 from the Netherlands and 1 each from Belgium and Spain. 

  Eight  Member  States38  have  engaged  in  activities  aimed  at  developing  and  improving 
consulates’ physical structures and equipment, to help them perform visa-issuing services in 
a more effective and efficient way. Specifically, 156 consulates — out of the 911 expected 
to be covered by national programmes  — have been developed or upgraded, of which: 85 
belong to Belgium, 39 to Estonia, 13 to France, and the remaining 19 to Cyprus (9), Finland 
(6), Spain (2), Sweden (1), and Austria (1). In terms of the implementation rate, according to 
the annual implementation reports for 2016, 7 Member States39 display a rate between 1 % 
and 100 %. 

  Seven  Member  States40  have  already  assigned  Immigration  Liaison  Officers  and  other 
professionals  with  specialised  functions,  to  maintain  direct  contacts  with  host  Member 
States, enabling the effective implementation of EU measures to tackle illegal migration and 
improve information-sharing mechanisms with the host Member States. Member States have 
deployed 105 officers — out of the 392 expected to be covered by national programmes, of 
which: 30 belong to Germany, 23 to France, 20 to the Netherlands, and the remaining 32 to 
Austria (14), Belgium (8), Spain (7), and Hungary (3). 

For  specific  objective  Borders,  the  Member  States  that  spent  the  highest  amounts  on  projects 
related  to  this  objective  were  Italy,  Greece,  and  Spain,  with  EUR 142.3,  124.2,  102.1  million 

38  AT, BE, CY, EE, ES, FI, FR and SE. 
39   AT, BE and BG (100 %), CH (39 %), CY (9 %), CZ (8 %) and DK (1 %). 
40   AT, BE, DE, ES, FR, HU and NL. 

18 

 
 
 
 
 
 
 
 
 
                                                 
respectively. In the remaining 16 Member States projects were financed for less than EUR 45 000 
in each country. 11 Member States41 have not provided data under the referred indicator. As regards 
border control, 8 Member States42 have developed or upgraded 1 414 (out of the 12 454 expected to 
be covered by the national programmes) infrastructure and equipment items aimed at strengthening 
border checks and surveillance. According to the AIRs for 2016, the remaining 22 Member States 
have not implemented any actions yet. 

In  terms  of  the  implementation  rate,  as  shown  by  Figure  4,  the  operating  support  displays  the 
highest  values  (48 %),  followed  by  STS  (38 %),  borders  (37 %),  visa  (28 %),  and  technical 
assistance (27 %). Regarding the payment rate, STS displays the highest values (31 %), followed 
by operating support (22 %), borders (6 %), technical assistance (6 %), and visa (6 %). 
Figure 5: ISF-BV — EU planned resources 2014-2020 for adopted national programmes, Member States commitment 
2014-2016, account amounts (EUR million), implementation and payment rate, by objective 

 € 900  

 € 800  

 € 700  

 € 600  

 € 500  

 € 400  

 € 300  

 € 200  

 € 100  

 € -    

60%

50%

40%

30%

20%

10%

0%

Visa Total

Borders Total

Operating support
Total

TA Total

STS LT Total

 EU planned resources 2014-2020 under SO

MS commitment (2014-2016)

Account amount (2014-2016)

Implementation rate

Payment rate

The  implementation  rate,  on  the  other  hand,  shows  that  Member  States  are  actually  much  more 
advanced  in  their  implementation  on  the  ground  and  that  the  difference  between  the  two  rates  is 
expected to be claimed in the financial records over the following years. 

In addition, breaking up data by Member States (Figure 6), ES  (EUR 208 million), EL (EUR 194 
million), IT (EUR 188 million) and LT (EUR 180 million) are the four Member States which have 
the  highest  value  of  available  resources  for  their  adopted  national  programme.  Overall,  these 
Member States have been allocated 50 % of the total available EU resources 2014-2020. 

In terms of the implementation rate, EE has attained a percentage of 87 %, followed by MT (83 %), 
AT (69 %), BG (66 %), LV (61 %) and BE (61 %). 18 Member States43 have currently achieved an 
implementation  rate  of  between  12 %  and  60 %.  Finally,  2  Member  States44  have  not  committed 

41   LI, LV, LU, MT, ML, PL, PT, RO, SE, SI and SK. It is important to highlight that LI’s national programme is in the process of 

being approved. 

42   EE (823), BG (243), DE (190), ES (129), CY (14), HU (11), BE (2) and IT (2). 
43  

In descending rate order: SK (59.24 %), FR (57.52 %), EL (54.30 %), NL (53.64 %), FI (53.39 %), DE (44.47 %), LT 
(43.17 %), RO (40.82 %), PT (38.84 %), CZ (34.38 %), CY (27.50 %), DK (24.24 %), SI (22.25 %), SE (20.15 %), ES (18.36 
%), IT (15.69 %), HR (14.16 %) and HU (13.86 %). 

44   LU and PL. 

19 

 
 
 
 
 
 
 
                                                 
resources,  displaying  a  rate  of  0 %.  The  payment  rates  vary  significantly  across  Member  States: 
only 1 Member States, EE, has attained a percentage of 50 %, 16 Member States45 have currently 
achieved a payment rate between 1 % and 26 %, whereas 5 Member States46 display a payment rate 
under 1 %. Finally, 4 Member States47 display a payment rate of 0 %. 

Figure  6:  Available  EU  resources  2014-2020  for  adopted  national  programmes,  Member  States  commitment  (2014-
2016) and accounts amounts (2014-2016), by Member States (EUR million), including top-ups. 

 € 250  

 € 200  

 € 150  

 € 100  

 € 50  

 € -    

AT BE BG CY CZ DE DK EE EL ES

FI

FR HR HU IT

LT LU LV MT NL PL PT RO SE

SI

SK

Available EU resources 2014-2020

MS commitment (2014-2016)

Account Amount

Taking  into  consideration  the  annual  accounts  for  2017  submitted  by  the  Member  States  in  mid-
February, we can conclude that the overall payment rate improved from 12 % to 24 %, with Italy, 
Lithuania, Spain and many other Member States making significant improvements as illustrated in 
the figure below. 

45  

In descending rate order: LT (25.74 %), AT (23.15 %), BG (23.13 %), NL (22.70 %), EL (21.70 %), DE (20.21 %), FI (15.48 
%), BE (14.59 %), SE (12.39 %), MT (7.64 %), ES (7.34 %), FR (6.79 %), CY (4.22 %), IT (3.77 %), SK (1.86 %) and SI (1.12 
%). 
 In descending rate order: LU (0.98 %), CZ (0.56 %), HU (0.53 %), LV (0.52 %), and DK (0.22 %). 

46 
47   HR, PL, PT and RO. 

20 

 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Figure 7: ISF-BV payments 2015-2017 (EUR million) 

€ 45 

€ 40 

€ 35 

€ 30 

€ 25 

€ 20 

€ 15 

€ 10 

€ 5 

€ 0 

CZ HR SK PL LU SE BE DK EE AT LV PT NL NO CY FI

SI

FR BG HU RO DE MT EL ES LT

IT

Payments 2015

Payments 2016

Payments 2017

3.2.2.  Direct management 

The  AWPs  for  2014-2017  allocated  a  total  amount  of  EUR 414  million  for  EMAS  (EUR 372 
million)  and  UAs  (EUR 42  million).  Over  the  period  2014-2017,  90 %  of  resources  have  been 
allocated for EMAS, whereas only 10 % was allocated for UAs. UAs have been planned by the EU 
to  allow  for  transnational  actions  or  actions  of  particular  interest  to  the  EU  to  be  funded.  These 
actions  concern  the  general,  specific,  and  operational  objectives  set  by Art.  3  of  Regulation  (EU) 
515/201448.  EMAS  actions  have  been  planned  to  allow  Member  States  to  address  urgent  and 
specific  needs  in  emergency  and  unpredictable  situations  requiring  a  timely  and  effective 
response49. The original planned amount envisaged for EMAS was multiplied by 11. Therefore, the 
reason behind the disproportionate planning between UAs and EMAS may be found in the need to 
properly face the unexpected and unprecedented migratory flows, which put significant pressure on 
the most affected Member States, during 2015 and 2016.  

By  30 June  2017,  a  total  of  123  actions  (46  EMAS  and  77  UAs)  were  financed  under  the  direct 
management  for  a  total  amount  of  EUR 383  million  out  of  the  EUR 414  million  planned  for 
resources for the 2014-2017 AWPs. In terms of the implementation rate50, beneficiaries spent 6 % 
of  total  committed  resources  (EUR 271  million),  with  a  total  payments  amounting  to  EUR 17 
million. 

48   Regulation (EU) N. 515/2014, Art. 13.1; annual work programmes 2014-2017. 
49   Regulation (EU) N. 515/2014, Art. 14.1; annual work programmes 2014-2017. 
50   The implementation rate for direct/indirect management is calculated by dividing the amount of payments, including pre-
financing and final payments, made to a finalised project by the amount awarded in the grant agreements (commitments). 

21 

 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Table 6: AWPs planned resources, by different implementation mechanisms 

Action grants 
Procurement 
Delegation 
agreement 
Other 
Total 

AWP 2014 

AWP 2015 

€9 163 194 
€1 600 000 
€4 500 000 
€450 000 
€15 713 194 

€45 800 000 
€1 667 000 
- 
€3 580 000 
€51 047 000 

AWP 2016 
€249 983 495 
€2 200 000 
€5 000 000 
€2 750 000 
€259 933 495 

AWP 2017 

€77 976 516 
€2 690 000 
€2 300 000 
€4 260 000 
€87 226 516 

Total 

€382 923 205 
€8 157 000 
€11 800 000 
€11 040 000 
€413 920 205 

Emergency assistance measures 

Over  the  period  2014-2017,  the  EU  allocated  a  total  amount  of  EUR 371.6  million  to  cover  the 
priorities  and  objectives  set  by  AWPs  for  EMAS.  By  30 June  2017,  7  Member  States51,  1  EU 
Agency52 and 1 international organisation53 were beneficiaries of a total of 46 EMAS actions. The 
total  committed  resources  amount  to  EUR 257.5  million,  while  payments,  including  both  pre-
financing and final payments, for completed actions stand at EUR 12.8 million. The pre-financing 
paid on ongoing  EMAS actions  amounted  to EUR 143.7  million. It is  important to highlight  that, 
for EMAS measures, the maximum possible co-financing rate of eligible costs is up to 100 %54. 

In terms of the overall implementation rate, it stood at 5 % as of 30 June 2017, which is due to the 
fact that only 7 EMAS projects out of 46 had been completed by that time. However, when we look 
at the implementation of those 7 completed projects, it stands at an impressive rate of 95 %. 

Most  EMAS  actions  were  financed  in  2015  (17)  and  2016  (22)  —  the  years  when  the  migratory 
crisis peaked. IT and EL were the main beneficiaries of EMAS actions, with 18 and 17 measures 
financed  respectively.  Considering  the  financial  support  provided  to  each  Member  States,  BG, IT 
and EL are the main beneficiaries under EMAS, with an initial grant amount55 of EUR 124.8, 59.5 
and  55.9  million  respectively,  followed  by  SI  (EUR 4.9  million),  HR  (EUR 4.0  million),  FR 
(EUR 1.7  million),  and  HU  (EUR 1.5  million).  As  regards  other  organisations,  UNHCR  has 
received EUR 4.1 million and EASO has received EUR 1.1 million. 

51   BG, EL, FR, HR, HU, IT and SI. 
52   EASO 
53   UNHCR 
54   AWPs 2014-2017. 
55   The amount refers to the initial EU allocation (grant amount). This could eventually be subject to a decommitment. 

22 

 
 
 
 
 
 
 
 
 
                                                 
Figure 8: Distribution of EMAS by Member States, by committed and paid amounts by June 30.2017 (EUR million) 

BG

IT

EL

SI

UNHCR

HR

FR

HU

EASO

€0 

€20 

€40 

€60 

€80 

€100 

€120 

€140 

Payments on completed projects by 30.06.2017

Commitments up to 30.06.2017

Based on the type of measures put in place, EMAS can be grouped as follows: 

1.  improvement of operational capacities (28 out of 46 measures); 
2.  acquisition  and  purchase  of  transport,  operating  equipment  (such  as  search  and  rescue  and 
border  surveillance  equipment,  photo-finger  printers),  and  IT  systems  for  a  better  and 
appropriate reaction to the emergency situation (8 out of 46 measures); 

3.  support to staff and costs to keep equipment fit to address emergencies (7 out of 46 measures); 
4.  linguistic and intercultural mediation services (3 out of 46 measures). 

EMAS has also contributed to the Greek hotspots56 by providing funds for food, shelter, medicines 
and transport at the hotspots57 and funds for strengthening the fingerprinting capacity58.   

Union Actions 

Over  the  period  2014-2017,  the  EU  planned  a  total  amount  of  EUR 42.3  million  to  meet  the 
priorities and objectives set by AWPs for UAs. A total number of 77 UAs have funded beneficiaries 
based in nine Member States59. It should be noted that 7 out of the 77 actions are being implemented 
via action grants with none completed by 30 June 2017, with the remaining ones being implemented 
via procurement of services directly by the Commission. 

  Action grants 

The total committed resources for the seven action grants amounted to EUR 3.8 million, while the 
implementation rate as of 30 June 2017 stood at 0 % with no final payments made by that date. The 

56   The Hotspot approach was developed as part of the European Agenda on Migration. The operational support provided to 

Member States is concentrated on registering, identifying, fingerprinting and debriefing asylum seekers. It is also concentrated 
on return operations. The Member States cooperate closely with the Commission and a few EU agencies (EASO, Europol, 
Frontex and Eurojust) in order to operationalise the concept. So far 10 hotspots have been created in Italy and Greece. 

57   HOME/2016/ISFB/AG/EMAS/0030, HOME/2016/ISFB/AG/EMAS/0022. 
58   HOME/2015/ISFB/AG/EMAS/0018 (EASO). 
59   BE, BG, DE, EL, ES, FR, LU, NO and PT. 

23 

 
 
 
 
 
 
 
 
 
 
 
 
                                                 
pre-financing paid to date amounted to EUR 1.2 million. It is important to highlight that, for such 
measures, the maximum possible co-financing rate for eligible costs is up to 95 %60. 

Based on the type of measures put in place, action grants can be grouped as follows: 

1.  EUROSUR (two projects in ES and PT); 
2.  Visa processing (one project in DE); 
3.  Regional cooperation on border management (two projects in BG and EL); 
4.  Schengen Masterlist  Border Control Pilot (two projects in NO and PT)61 

Figure 9: Distribution of action grants by identified clusters, by committed amounts by June 30 2017 (EUR thousand) 

EUROSUR

Visa processing

Regional Cooperation on Border Management

Schengen Masterlist  Border - Control Pilot

€  0 

€  500 

€ 1 000 

€ 1 500 

€ 2 000 

€ 2 500 

€ 3 000 

Commitments up to 30.06.2017

  Procurement 

The  total  committed  resources  for  70  actions  falling  under  the  category  of  procurement, 
administrative  arrangements  and  service  level  agreements  amounted  to  EUR 9.4  million  while 
payments on completed actions amounted to EUR 4.2 million, which corresponded to 52 completed 
actions out of 70 and an implementation rate of 45 % as of 30 June 2017. Procurement essentially 
covers services that the Commission purchased directly and focuses primarily on the financing of 
different evaluation mechanisms, most of which are linked to the Schengen evaluation. 

Most of the contracts were concluded in 2015 and 201662. Due to the nature of procurement, most 
contractors are based close to the Commission’s headquarters. Therefore, Belgium is the Member 
States with the most contracts (57), followed by France (9), Germany (3) and Luxembourg (1). 

Based on the type of measures put in place, procurements can be grouped as follows: 
1.  evaluation mechanisms, mainly Schengen evaluations (41 procurements); 
2.  IT Systems for border management (9); 
3.  visa processing (1); 

60   Union actions annual work programme 2014-2017. 
61   Schengen Masterlists are secure container file-structures, cryptographically signed to prevent alteration, which contain Country 
Signing Certification Authority certificates validated by at least 3 Member States and by which the Commission would like to 
promote the use of electronic authentication of any electronic document. 

62   The lower number of UAs assigned to countries in 2017 may depend on the fact that data only takes into account the first half of 

the year. 

24 

 
 
 
 
 
 
 
 
 
 
                                                 
4.  immigration liaison officers  (2); 
5.  press brochure on Schengen (3); 
6.  webworks (1); 
7.  others  (13). 

Figure 10: Distribution of UAs by identified clusters, by committed and paid amounts by June 30 2017 (EUR thousand) 

Evaluation mechanisms

IT Systems for border management

Others

Immigration Liaison Officers

Webworks

Press Brochure on Schengen

Visa processing

€ 0 

€1 000 

€2 000 

€3 000 

€4 000 

€5 000 

€6 000 

Payments on completed projects by 30.06.2017

Commitments up to 30.06.2017

3.2.3.  Indirect management 

The 2014-2017 AWPs allocated, as of 30 June 2017, a total amount of EUR 12 million for indirect 
management instruments, out of which 42 % of the overall amount was allocated for 2016, 38 % for 
2014, and only 20 % for 2017. 

Operationally, 81 % of the overall resources provided for through the AWPs have been allocated, 
for a total amount of EUR 9.5 million. By 30 June 2017 a total amount of EUR 7.9 million was paid 
as pre-financing with no final payment made by the cut-off date. 

In particular, during the period 2014-2017, the EU entrusted budget implementation tasks, through 
delegation agreements to the following bodies.  

  eu-LISA in order to carry out the ‘Smart Borders Pilot’ testing phase, in the context of a ‘Proof 
of  Concept’  exercise,  as  part  of  the  Smart  Borders  Package  adopted  by  the  Commission  on 
28 February 2013. To implement the given tasks, the EU entrusted a total amount of EUR 3.5 
million, with EUR 3.3 million in pre-financing. 

  The International Centre for Migration Policy Development (ICMPD) to implement the action 
‘Mobility Partnership Facility’, in order to support mobility partnerships and common agendas 
for migration and mobility, in the context of the Global Approach to Migration and Mobility 
(GAMM)63. The action has been put in place under different financial instruments (AMIF, ISF-
Police and ISF-BV) for a total estimated amount of EUR 5.5 million, of which a maximum of 

63   COM(2011) 743 final, Communication from the Commission to the European Parliament, the Council, the European Economic 

and Social Committee and the Committee of the Regions - The Global Approach to Migration and Mobility. 

25 

 
 
 
 
 
 
 
 
 
 
 
 
                                                 
EUR 1 million was entrusted under the ISF-BV, with EUR 800 thousand paid in pre-financing 
up to 30 June 2017. 

  UNHCR  for  implementing  the  action  ‘Support  to  Greece  for  the  development  of  the 
hotspot/relocation  scheme  as  well  as  for  developing  asylum  reception  capacity’,  helping  to 
create  20 000  reception  places.  The  action  has  been  put  in  place  under  different  financial 
instruments (AMIF and ISF-BV) for a total estimated amount of EUR 83.3 million, of which 
EUR 5  million  has  been  entrusted  under  the  ISF-BV,  with  EUR 3.75  million  paid  in  pre-
financing up to 30 June 2017. 

26 

 
 
 
 
4. METHOD 

4.1  Short description of methodology 

This evaluation assesses how the Fund has worked so far and informs the national authorities, the 
EU institutions, the stakeholders and the general public about the key achievements and limitations 
of ISF-BV. It does attempt to explain how the Member States and the Commission plan to address 
weaknesses  and  overcome  obstacles  identified,  to  ensure  that  during  the  second  half  of  the 
implementation  period  corrective  actions  are  taken  and  the  impact  of  any  weaknesses  are 
minimised.  This  forward-looking  aspect  of  the  interim  evaluation  will  also  contribute  to  the 
preparation of the next generation of funding instruments going beyond 2020. 

Similarly  to  the  ex  post  evaluation  of  the  EBF,  the  predecessor  programme,  this  evaluation  was 
carried out by an external consulting firm Ernst & Young between September 2017 and February 
2018.  It  was  coordinated  by  the  HOME  Funds  Evaluation  Team  in  Unit  E3  of  the  Commission’s 
Directorate-General for Migration and Home Affairs with the support of an Inter-Service Steering 
Group comprising other Commission services. 

The  Commission’s  evaluation  relied  on  an  external  study.  It  required  a  systemic  synthesis  of  the 
evidence  regarding  the  ISF-BV’s  implementation.  The  methodology  for  data  collection  included 
both desk and field research. The data collected was subject to quantitative and qualitative analysis. 

Desk research essentially consisted of a review of: 

the relevant legislative documents (i.e. EU Treaties, ISF-BV Regulation); 

 
  policy documents (i.e. European agendas on migration and on security; 
  Commission communications; 
  ex post evaluations of SOLID funds (in particular the EBF); 
  Member States national programmes; 
  AIRs; 
  national interim evaluation reports64 (NIERs); 
  grant agreements; 
 
 
  mission reports from monitoring visits to beneficiaries carried out by the Commission staff; 
  ex post audit reports; 
 
  minutes from policy dialogues preceding the set-up of ISF-BV. 

final technical implementation reports; 
final financial implementation reports; 

results of the mid-term review: and  

The  analysis  also  relied  on  statistical  data  from  SFC2014  for  shared  management  actions  and  on 
ABAC65 data for direct and indirect management actions. 

Field research covered different tools used to include multiple stakeholders categories according to 
the consultation strategy presented in Annex 2. It consisted of 50 phone interviews — exploratory 
phone  interviews  conducted  during  the  inception  phase  and  phone  interviews  with  national 

64    31 Member States were received as LI did not submit its Member States due the fact that no actions covered by ISF-BV were 

implemented during the period covered by the interim evaluation. 

65   ABAC is the European Commission’s accounting IT system. 

27 

 
 
 
 
 
 
 
 
 
 
 
 
                                                 
responsible authorities (RAs), delegated authorities (DAs) and with relevant Commission services 
and agencies. Interviews at national level covered all Member States with external borders and that 
issued high number of visas, ensuring geographical and EU funding balance. An online survey was 
also  carried  out  to  address  a  wider  number  of  stakeholders,  including  audit  authorities  (AAs), 
beneficiaries of multiannual programmes and union actions, members of the monitoring committees 
and experts. The response rate to the survey was almost 15 %. Moreover,  eight case studies were 
produced  with  a  close  focus  on  six  Member  States  (BG,  EL,  ES,  FI,  IT,  and  LT),  EUROSUR 
(covering both direct and shared management) and consular cooperation (specific action). The case 
studies illustrate practical examples of projects carried out by Member States with ISF-BV support. 
Finally, information gathered through the targeted public consultation, launched by the Commission 
in  December  2017  was  also  analysed66.  Information  was  triangulated  to  ensure  validity  and 
robustness. 

4.2  Evaluation questions 

In line with the Better Regulation guidelines, this interim evaluation addresses evaluation questions 
structured around the five evaluation criteria of effectiveness, efficiency, relevance, coherence and 
EU  added  value,  as  well  as  the  criteria  of  complementarity,  sustainability,  and  simplification  and 
reduction of administrative burden introduced by the Horizontal regulation67. 

The  complete  list  of  evaluation  questions  as  set  in  the  legal  base  can  be  found  in  Annex  4.  An 
overview of the answers to the evaluation questions can be found in Annex 4. 

4.3  Limitations and robustness of findings 

A first limitation of this interim evaluation concerns its timing: it is taking place only 3 years after 
the ISF-BV was launched, with many national programmes only being approved after delays, while 
most  projects  have  only  just  started,  making  their  assessment  very  challenging.  Therefore,  the 
evidence on the results and impact of the Fund is very limited. Nonetheless, this evaluation is not 
able  to  produce  a  full  picture  of  the  programme’s  results  and  impacts  and  cannot  draw  final 
conclusions, as insufficient time has lapsed since the beginning of the programming period and the 
Fund is still being implemented. 

Concerning  the  indicators,  limitations  include  issues  related  to  data  availability  and  the 
measurability of impacts (for example, most of the ISF-BV’s indicators focus on outputs).  Often, 
these  indicators  are  not  linked  to  the  Fund’s  specific  objectives.  Therefore  it  is  really  difficult  to 
attribute  the  observed  changes  to  the  Fund.  The  information  gathered  though  primary  sources  is 
limited, since stakeholders have no clear idea of the results brought about by the Fund. Therefore 
the  gathering  of  information  focused  more  on  procedural  issues,  providing  a  very  general 
perspective on the Fund’s implementation, with sporadic examples found on the ground. Also, the 
reliability  of  Member  States  indicators  was  rather  low  as  in  many  cases  common  indicators  were 
not available or equal to 0. This hindered the statistical analysis of the Fund’s implementation and 
financial  progress  as  well  as  the  data  comparison  across  Member  States.  In  some  cases, 
misalignment of data was noted between the national programmes, AIRs and in the NIERs. 

Concerning the period covered by the interim evaluation, for shared management actions the cut-off 
date  was  31 December  2016,  which  is  linked  to  the  period  covered  by  the  latest  set  of  accounts 
submitted  by  the  Member  States  and  cleared  by  the  Commission.  For  actions  under  direct  and 

66   Only 4 responses have been received by representatives of RAs (2 from IT, 1 from BG and 1 from EL). 
67   Regulation (EU) No. 514/2014. 

28 

 
 
 
 
 
 
 
 
 
                                                 
indirect management, the cut-off date was 30 June 2017. The different cut-off dates did not allow 
the  Fund  to  carry  out  a  parallel  assessment  and  comparison  of  results  achieved  under  different 
implementation modes. 

Another limitation has been the lack of benchmarks to compare performance, mainly because AMIF 
and  ISF  are  the  first  home  affairs  programmes  to  have  a  common  monitoring  and  evaluation 
framework  and  a  set  of  indicators  (common,  result  and  impact).  In  addition,  many  of  these 
indicators have been viewed as being not relevant or not easy to populate with data and maintain. 

The  contextual  exogenous  factors  linked  to  the  migration  crisis  itself  are  also  a  significant 
limitation.  The  Fund  adapted  itself  to  the  changing  needs,  which  made  it  difficult  to  evaluate  its 
functioning and implementation against its initial design. 

Furthermore, while most of the interviews were conducted as planned, the response rate to both the 
online survey (15 %) and the Open Public Consultation (OPC, only four respondents) was very low. 
This  hindered  data  triangulation,  allowing  comparison  only  for  those  issues  for  which  responses 
were provided. Therefore, in some cases, evidence is based only on desk research, in other cases the 
documentary analysis is triangulated with interviews, and in fewer cases triangulation also included 
the survey and the OPC. 

Regarding  the  STS  operated  by  Lithuania,  it  should  be  noted  that  the Lithuanian national  interim 
evaluation report does not contain an evaluation of the scheme. Wherever there are references made 
to  the  STS  throughout  this  document,  they  are  solely  based  on  the  interviews  carried  out  by  the 
external consultant with the relevant stakeholders. 

In  the  evaluation,  these  limitations  were  mitigated  to  the  extent  possible.  The  analysis  of  the 
evidence  has  allowed  the  Commission’s  services  to  identify  problems  with  data  availability  and 
quality  that  could  be  overcome  over  the  course  of  the  interim  evaluation.  Conclusions  have  been 
drawn, where possible, based on the triangulation of evidence from various data sources, indicated 
transparently. The use of multiple information sources made it possible to have an overview of the 
implementation  state-of-play  and  of  the  Fund’s  results.  When  answers  were  not  provided  to  the 
online  survey,  information  was  gathered  through  the  analysis  of  the  national  documents  and,  in 
some cases, confirmed (or not) by interviewees. The low number of participants to the surveys was 
counterbalanced  by  the  analysis  of  national  interim  evaluation  reports.  Even  though  these  reports 
were often not exhaustive, they made it possible to gather information on all Member States, and 
identify  trends  and  divergences  across  them.  Whenever  possible,  the  ex  post  evaluations  of  the 
predecessor SOLID programmes have been used as a benchmark. 

29 

 
 
 
 
 
 
 
 
 
 
5. ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS 

5.1  How effective has ISF-BV been so far? 

This  evaluation  question  aims  to  provide  an  insight  into  whether  ISF-BV  is  on  track  to  meet  its 
objectives. The borders and visa instrument has two specific objectives — one linked to a common 
visa  policy and  the  other  to  supporting  integrated  border management.  Overall there  are  seven 
operational objectives — four of which are relevant for the common visa policy and six of which 
are  relevant  for  the  integrated  border  management.  There  are  evaluation  questions  (see  Annex  4) 
addressing each operational objective (see Table 4). 

5.1.1.  Effectiveness in supporting a common visa policy 

Shared management 

In a nutshell 

The Fund has contributed to implementing the EU common visa policy in an effective manner. 
It  facilitated  legitimate  travel.  Information-exchange  and  training  activities  contributed  to  the 
EU’s acquis on visa policy being uniformly implemented. The Fund played an instrumental role 
in  developing  IT  systems  supporting  a  common  visa  policy.  All  these  together  contributed 
towards  (i) a  high  quality  service  for  visa  applicants,  (ii) equal  treatment  of  third-country 
nationals  and  (iii)  tackling  illegal  migration.  The  Fund’s  contribution  in  consular  cooperation 
and in strengthening cooperation with third countries has so far been limited. 

The EU has a common visa policy for short-stay visits to the Schengen area, comprising of a set of 
harmonised rules setting out (i) the countries whose nationals require a visa to travel to the EU and 
those  who  do  not,  (ii) the  procedures  and  conditions  for  issuing  short-stay  visas,  (iii)  a  uniform 
format  for  visa  stickers  and  (iv) a  common  Visa  Information  System  that  records  all  visa 
applications and decisions. EU Member States are among the world’s leading tourist destinations — 
the  number  of  visa  applications  processed  by  Member  States  has  increased  considerably  over  the 
last 8 years and continues to expand. Since 2009, applications for EU visas have risen 50 % — from 
10.2 million to 15.2 million in 2016 coupled with increased costs of processing of visa applications. 
The EU’s common visa policy has also been affected by the migration crisis with increased pressure 
on  consular  staff  worldwide  and  an  increasing  need  for  cooperation  on  irregular  migration  and 
return. 

Overall, the Fund has significantly contributed towards the achievement of a common visa policy, 
as confirmed both by the stakeholders and by the implementation results of the national evaluation 
reports68. The following five aspects of the common visa policy were addressed in the evaluation:  
1) facilitation of legitimate travel; 
2) better consular coverage and harmonised practices on visa issuance; 
3) implementation of EU’s acquis on visas; 
4) cooperation between Member States; and 
5) IT systems and communications infrastructure and equipment. 

68   All Member States. Interviews with 4 RAs (BE, BG, FR and NO). 65% (n=42) of replies to the online survey: 3 AAs (HR; CY 

and LV), 13 Member States (BE, CZ, EE, FI, HU, LV, PT and RO), 1 EMAS beneficiary (EL), 1 Ministry of Foreign Affairs 
(SK), 21 members of Monitoring Committee (AT, BG, CY, EE, LV, MT, RO, SI, ES and ,SE), 2 RAs/DAs (FR and SI), 1 
expert. 

30 

 
 
 
 
 
 
 
 
 
                                                 
 
The  Fund  contributed  to  the  facilitation  of  legitimate  travel,  strengthening  Members  States’ 
national capacities by, for instance: (i ) co-financing  projects  for  strengthening  national  capacity  to 
verify the authenticity of documents used for visa applications, (ii) developing information systems 
for  coordinating  visa  applications69,  and  (iii) procuring  security  equipment  for  consular 
representations in third countries. All this leads to Member States being in a better position to grant 
visas  to  those  visa  applicants  with  legitimate  applications.  In  particular,  projects  under  the  Fund 
supported  the  purchase  of  technical  equipment  (e.g.  document  checking  devices,  communication 
equipment)  to  make  the  processing  of  Schengen  visa  applications  more  efficient  and  to  support 
national  information-sharing  platforms  to  combat  visa  abuse  and  document  fraud.  Training  also 
supported legitimate travel70, by providing consular staff with technical and up-to-date information 
on visa issues and related systems. 

As regards consular cooperation, the ex post evaluation of the EBF revealed that Member States 
showed little interest in developing projects in this area mainly due to (i) the perceived high cost of 
common visa application centres or (ii) perceived issues linked to cost-sharing with other Member 
States  resulting  in  Member  States  choosing  to  keep  their  representations  in  third  countries.  The 
Commission decided to incentivise this area through offering co-financing at a rate of 90 % in the 
national  programmes  under  ISF-BV,  while  the  scope  was  extended  beyond  common  application 
centres  to  include  other  types  of  consular  cooperation  in  addition  to  refurbishment,  adaptation 
and/or equipping of consulates. Despite these measures,  the  Fund’s  contribution towards  consular 
cooperation has been quite limited so far, with many Member States not implementing any projects 
in the area yet. However, those Member States that have carried out consular cooperation activities 
gave  positive  feedback  on  the  Fund’s  contribution.  For  instance,  it  helped  increase  consular 
coverage  by  supporting  the  establishment  of  new  consular  posts  and  other  forms  of  cooperation 
(e.g.  joint  training  courses,  joint  consular  offices)  that  incentivised  Member  States  to  establish 
consular representation agreements to improve visa processing and to promote a common approach 
to  visa  issuance71.  The  use  of  the  Visa  Information  System  facilitated  the  exchange  of  both 
information on fraudulent visa documents and best practices on implementing Schengen standards72. 
Training  courses  also  contributed  towards  harmonising  practices  on  visa  issuance73.  Many 
Member  States74  reported  that  visa  harmonisation  was  supported  through  a  better  exchange  of 
information and best practices being shared between Member States. 

There were difficulties in implementing joint projects between Member States75 due to the different 
national eligibility rules of expenditure, checks, and other rules related  to the posting of staff76. In 
particular, Member States77 involved in specific actions on consular cooperation asked for standard 
and clearer eligibility and expenditure rules at EU level to harmonise and ease the management of 
such actions. Currently, it is not possible to assess the effectiveness of the specific action as only a 
few projects have started and even those are in their initial stages. However, it is interesting to note 

69   BE, EE, and EL. 
70   AT, HU and LV. 
71   7  Member States (EL, FR, HU, LU, MT, NO and PT). 
72 
73   AT, EE, IT, NL and LT. 
74  

 i.e. As a result, up to 44.253 persons using fraudulent travel documents were detected at consulates supported by the Fund. 

7 Member States (EL, FR, HU, LU, MT, NO and PT). 4 interviews: RAs from LT, NO and PT and one delegated authority from 
EL; results from the online survey: 7 Member States (AT, BE, CZ, LU, LV, NL and RO), 2 representatives from Monitoring 
Committees (AT and BG). 
2 interviews with RAs (BE and PT). 9  participants to the Eighth Meeting of the Evaluation Network (BE, CH, EE, ES, HU, LT, 
NL, NO and PL). 
In some Member States only the posted officer receives financial support, in others staff members can also bring their family 
along. 

75 

76  

77   2 interviews with RAs (BE and PT). 9 participants to the Eighth Meeting of the Evaluation Network (BE, CH, EE, ES, HU, LT, 

NL, NO and PL). 

31 

 
 
 
 
 
                                                 
that most Member States considered the needs addressed by the specific actions — harmonisation 
of visa issuance and increasing visibility and consular coverage of Member States — as particularly 
appropriate in light of current migration pressure78. 

Ensuring  the  correct  and  uniform  application  of  the  Union’s  acquis  on  visa  has  been  supported 
either  through  mixed  projects  also  pursuing  other  objectives,  or  through  projects  targeted 
specifically  to  this  objective.  Training  courses  targeted  staff  responsible  for  visa  issuing79  and 
consular officials, police, and border guards engaged in developing and implementing the common 
visa  policy80.  In  some  cases,  training courses  aimed  to  disseminate  best  practices  among  consular 
officials  and  to  provide  them  with  specific  language  courses  or  knowledge  on  the  changing  legal 
situation  at  EU  level  in  the  field  of  visa.  Some  Member  States  organised  training  sessions  for 
consular services on security (e.g. illegal migration) and document verification (i.e. document fraud 
detection, counterfeit or forged travel documents, and documents necessary for visa application)81. 
Other  training  courses  supported  the  implementation  of  the  EU  common  visa  policy  and  the 
Schengen  acquis,  concerning  in  particular  the  Community  Code  on  Visas  (Visa  Code),  including 
instructions  for  running  Visa  Information  System  and  IT  systems.  Training  was  also  aimed  at 
improving  the  quality  of  services  provided  to  visa  applicants,  to  ensure  equal  treatment  of  third-
country nationals in the visa-issuing process82. 

A number of Member States have used the Fund to strengthen cooperation with third countries83. 
Most  projects  in  this  area  improved  the  exchange  of  information  between  authorities  along  the 
migration routes and on the return of illegal migrants. Furthermore, the Fund helped to tackle illegal 
migration by supporting the Member States in deploying temporary liaison officers and visa experts 
in  consulates  in  third  countries,  who  were  directly  responsible  for  the  fight  against  fraudulent 
documentation  or  through  consulates  regularly  consulting  with  each  other  in  order  to  detect 
counterfeit  documents84.  Responsible  authorities  involved  in  cooperation  actions  with  third 
countries gave positive feedback on the actions implemented85. 

The  development  of  a  common  visa  policy  was  also  supported  by  means  of  establishing  and 
operating  IT  systems,  with  particular  regard  to  national  Visa  Information  System,  in  order  to 
ensure  an  efficient  and  smoother  visa  processing.  The  use  of  new  technologies  enabled  the 
authorities  to  comply  with  the  changing  technical/legal  requirements  of  the  common  visa  policy, 
including  the  introduction  of  the  biometric  passports  and  related  compliance  checks.  The 
development of IT systems was often accompanied by staff training measures so as to ensure that 
consular officials, police and border guards have sufficient technical expertise, as well as to ensure 
sustainability. 

Operating  support  guarantees  the  capacity  and  uninterrupted  functioning  of  the  systems  and 
maintenance  of  equipment86.  This  is  a  key  factor  for  ensuring  security  since  well-functioning  IT 
systems are crucial for promptly detecting potential threats. Operational shortcomings may lead to  
the security system being jeopardised. The operating support for Visa measures also proved to be 

78   BE, FR, HU, IT, LT, NL and PT. 
79   13 Member States (AT, BE, EE, EL, ES, FI, FR, HU, LT, LU, LV, SI and SK). 
80   AT, BE, CZ, HU and PT. 1 interview with an responsible authority (NO). OPC: 4 Public Authorities (BG, EL, IT and IT). 
81   BE, EE, EL, FR, HU and SI. 
82   EE, HU, LV and SI. 
83 
84   Results from the online survey: beneficiaries in 7 Member States (AT, BE, CZ, LU, LV, NL and RO), 2 members of Monitoring 

13 Member States (AT, BG, BE, CH, CY, CZ, DE, EE, EL, FI, LU, MT and PL). 

Committees (AT and BG). 

85   3 interviews: 2 with RAs (BE and NL) and 1 with a delegated authority (EL). OPC: 3 Public Authorities (1 in BG, and 2 in IT). 
86   8 Member States (AT, BG, DE, ES, FR, IT, LT and RO). Interviews with 3 RAs (BG, BE and PT). 

32 

 
 
 
 
 
 
                                                 
useful  in  covering  staff  costs  and  other  running  costs  related  to  the  EU  common  visa  policy’s 
implementation, notably by strengthening national capabilities in the visa application process. 

Direct management 

For direct management, only one action grant and one procurement were dedicated to the area of 
visa processing. However no conclusions can be drawn so far as they had not been finalised during 
the period covered by the interim evaluation. 

Examples of different types of visa projects implemented by the Member States 

The Fund supported the development of a Visa Information System in many Member States (AT, 
BE, BG, CZ, ES, FR, LT, LV, and RO)87. In Spain, the visa-issuing procedures were boosted by: 
(i)  including  a  Visa  Information  System  in  most  consulates,  (ii)  improving  and  developing  new 
functionalities  in  the  national  scheme  for  visas  and  VISMail;  and  (iii) developing  measures 
complementary  to  Schengen  Information  System  II.  France  has  implemented  a  website 
https://france-visas.gouv.fr for visa applications that is already in use in 37 countries to facilitate the 
process  of  visa  applications  and  to  harmonise  procedures.  In  Austria,  the  Ministry  of  Foreign 
Affairs deployed experts to  diplomatic representations to  conduct  web-based and  onsite legal and 
technical training for staff dealing with Visa Information System, providing targeted knowledge on 
legal  and  technical  innovations  relating  to  the  Visa  Information  System  rollout.  Moreover,  it 
provided regional training courses for consular staff focused on legal and technical visa issues and 
IT  systems.  In  Finland,  cooperation  was  boosted  by  means  of  strong  support  provided  by  the 
Immigration Liaison Officer (ILO) network through the training of embassy personnel involved in 
the visa granting process. ILOs help prevent illegal immigration by investigating the background of 
visa  applicants  and  by  examining  the  authenticity  of  documents.  Furthermore,  ILOs  support  the 
training of embassy personnel. 

5.1.2.  Effectiveness in supporting integrated border management 

In a nutshell 

The  Fund  has  contributed  to  the  implementation  of  integrated  border  management  in  an 
effective  manner  despite  the  migration  and  security  crisis.  The  Fund  contributed  to  the 
development  of  integrated  border  management  policy.  It  increased  solidarity  among  Member 
States by co-financing equipment used in Frontex joint operations. The Fund helped to develop 
the EU’s acquis on border management. The Fund made a contribution to the development of 
EUROSUR  and  border  management  IT  systems.  Limited  progress  was  registered  regarding 
promoting  the  development,  implementation  and  enforcement  of  policies  with  a  view  of 
ensuring  the  absence  of  any  controls  on  persons,  whichever  their  nationality.  Currently,  the 
Fund  is  not  supporting  Memebr  States  in  the  application  of  the  non-refoulement  principle. 
EMAS  played  an  important  role  in  addressing  the  emergency  needs  at  the  beginning  of  the 
period and bridged the funding gap until the adoption of national programmes.  

87   9 Member States (AT, BE, BG, CZ, ES, FR, LT, LV and RO). Results from the online survey: 5 beneficiaries (1 in AT, 2 in BE 

and CZ). 

33 

 
 
 
 
 
 
 
 
 
 
 
                                                 
 
Under the integrated border management concept the evaluation looked into progress made and the 
Fund’s contribution in the following six aspects:  
1) absence of any checks on people when crossing the internal borders;  
2) efficient checks on people and efficient monitoring of external border crossings; 
3)  gradual  establishment  of  an  integrated  management  system  for  external  borders  based  on 
solidarity and responsibility sharing; 
4) application of  EU’s acquis on border management; 
5) boosting of situational awareness at the external borders; and  
6) setting up and running IT systems including communication infrastructure and equipment. 

Overall, the Fund contributed towards the overall objective on integrated border management, as 
confirmed  both  by  the  stakeholders  and  by  the  implementation  results  of  the  national  evaluation 
reports88. 

In term of addressing the operational objective of ‘promoting the development, implementation 
and enforcement  of  policies with a view of  ensuring the absence  of  any controls on persons, 
whatever  their  nationality,  when  crossing  the  internal  borders  and  to  carry  out  check  on 
persons  and  monitoring  efficiently  the  crossing  of  external  borders’  the  effectiveness  of  ISF-
BV was greatly influenced by the security and migration crisis at the beginning of the programming 
period.  The  unprecedented  flow  of  migrants  into  the  EU  during  this  initial  phase  of  the  Fund’s 
implementation,  who  crossed  the  EU’s  external  border  unchecked,  resulted  in  secondary 
movements89 of non-registered irregular migrants across the Schengen Area. This caused a severe 
strain on the Schengen Acquis, since the absence of internal border control is directly linked to the 
effectiveness of the controls at the external borders of the EU. As a consequence of the secondary 
movements  and  the  security  crisis,  some  Member  States  had  to  temporarily  reintroduce  internal 
border  controls  therefore  affecting  the  Fund’s  effectiveness.  Moreover,  the  crisis  put  a  specific 
focus on the management of the EU’s external borders. 

However, the Fund contributed towards the  effectiveness of the border controls at the external 
borders by supporting measures focused on the replacement/upgrading of: 

  border  control  equipment  (e.g.  work  stations,  portable  computers,  border  check  stamps, 
identification  equipment, 

communication  equipment,  copiers,  specialised  biometric 
optronic devices, mobile equipment for border offices); and 

  surveillance  (e.g.  development  of  electronic  surveillance  systems,  thermovision  cameras, 
USB microscopes that make it possible to verify documents at distance, aerial vehicles)90.  

Border  management  capacity  was  addressed  by  means  of  introducing  automated  border  control 
(ABC)  gates91  that  speeded  up  the  checks  at  the  border  crossing  points.  The  ABC  gates  can  be 
linked  to  national  and  international  IT  systems  making  the  information  exchange  more  efficient. 
Member  States  have  also  introduced  the  Public  Key  Directory92,  as  a  central  repository  for 

88   All the Member States; interviews with 8 RAs (FI, PT, FR, BE, EL, NL, NO and PL); 1 delegated authority (EL); 73% of 
replies to the online survey (AT, BE, BG, HR, CY, CZ, EE, ES,FR, EL, HU, LV, MT, NL, PL, PT, RO, SI, and SE); 7 
participants to the eighth meeting of the Evaluation Network (BE, BG, EL, HR, FR, HU and MT); OPC: 4 Public Authorities (1 
from BG, 1 from EL, and 2 from IT); direct management: two technical reports (HOME/2015/ISFB/AG/EMAS/0001 and 
HOME/2016/ISFB/AG/EMAS/0018) and an interview with the BG Chief Directorate Border Police; indirect management:  
three technical reports (HOME/2014/IM/LISA/0001, HOME/2014/MULT/IM/ICMP/0001 and 
HOME/2016/MULT/IM/UNHC/OOO1). 

89   Secondary movements of migrants comprise movements from the Member States they arrived in to other Member States. 
90   BG, EE and FI. 
91   15 Member States (BE, BG, CH, CY, DE, EE, EL, ES, FI, HU, IS, LU, LV, PL and SI). 
92   BE, BG, FI, MT and PL. 

34 

 
 
 
 
 
 
                                                 
exchanging  information  required  to  authenticate  ePassports  and  to  verify  the  authenticity  of 
travel/identification documents. Further projects are carried out in the following fields:  

  modern  technical  equipment  for  border  surveillance,  including  engineering  appliances  and 

the TETRA communication system;  

  document  verification  devices  such  as  document  testing  equipment  for  faster  and  more 

efficient processes;  
  mobile scanning vehicles; 
  mobile application for carrying out border checks; and  
  purchase of document readers for portable border control devices93. 

With  the  Fund’s  support  Member  States  carried  out  training  activities  in  the  area  of  border 
management,  with  the  aim  of  improving  staff  awareness  and  competencies  in  relation  to  border 
management and the use of related IT information systems. The Fund supported the implementation 
of  the  EU’s  acquis  by  co-financing  training  activities  and  programmes,  which  helped  to  improve 
the  technical,  operational  and  linguistic  skills  of  the  staff  responsible  for  border  management94. 
Furthermore, this objective was indirectly supported by actions aimed at facilitating the cooperation 
and  exchange  of  information  with  other  Member  States  since  such  interventions  strengthened  the 
awareness of the Member States obligations at EU level and supported harmonised practices among 
Member States95. 

Solidarity  and  responsibility  sharing  between  the  Member  States  is  expressed  mainly  through 
joint  operations;  cooperation  between  Member  States  under  EUROSUR  and  through  cooperation 
with  Frontex.  So  far  some  EUR 200  million  has  been  spent  on  specific  actions  to  support  the 
purchase  of  Frontex  equipment  by  14  Member  States,  to  be  used  in  Frontex-coordinated  joint 
operations96. 

The  Fund  contributed  to  the  development  of  EUROSUR97  by  co-financing  activities  both  under 
Member  States  national  programmes  and  under  Union  actions.  These  activities  aimed  to  improve 
situational  awareness  and  increase  the  reaction  capability  at  the  external  borders  by  detecting, 
preventing and combating illegal immigration and cross-border crime and by helping to protect and 
save  the  lives  of  migrants98.  Activities  under  EUROSUR  also  contributed  towards  solidarity  and 
responsibility between Member States which is an important aspect of the operational objective on 
integrated  border  management.  It  needs  to  be  pointed  out  that  the  actions  financed  by  the  Fund 
under  the  national  objective  of  EUROSUR  are  interpreted  in  a  much  broader  manner  than  the 
implementation of the action provided for by the EUROSUR Regulation (2013/1052). For example 
Member  States  could  include  in  their  national  programmes,  under  the  national  objective 
EUROSUR, projects such as purchasing surveillance equipment or developing border surveillance 
systems  which  are  linked  to  border  surveillance  in  general,  but  not  directly  to  EUROSUR’s 
implementation. 

The Fund also provided support for the development of IT systems, notably for the upgrading and 
operation  (under  operating  support)  of  the  Schengen  Information  System  (Schengen  Information 

93   9 Member States (BG, DE, EL, FI, FR, HR, HU, IT and LV). 
94   5 Member States (AT, BE, CZ, HU and PT). 1 interview with responsible authority (NO). OPC: 4 Public Authorities (BG, EL, 

IT and IT). 

95   4 Member States (IT, PL, PT and RO). 
96   AT, BG, DE, ES, FI, FR, GR, IT, MT, LT, LV, PL, PT and RO. 
97   Regulation (EU) No 1052/2013 of the European Parliament and of the Council of 22 October 2013 establishing the European 

Border Surveillance System (EUROSUR). 

98   Results from online survey: 58% (n=46). 2 AAs (CY, LV), 20 beneficiaries (AT, BE, CZ, EE, FI, HU, LV, LU, MT, NL, PT, 
RO and SE), 1 EMAS beneficiary (EL), one expert (UK), 20 members of monitoring committee (AT, BG, CY, EE, HU, LV, 
MT, RO, SI and SE), 2 RAs/DAs (FR and SI). 

35 

 
 
 
 
 
 
                                                 
System  II).  This  allowed  the  Member  States  to  upgrade  and  maintain  the  IT  systems  and  ensure 
their  interoperability99  and  interconnectivity  between  the  different  national  systems,  which  in  turn 
contributed to a more effective management of the EU’s external borders. 

Under  the  specific  objective  of  integrated  border  management,  it  is  specifically  indicated  that  the 
Member  States  should  respect  human  rights  and  the  principle  of  non-refoulement.  Two  Member 
States100 reported that the maintenance and modernisation of  border control buildings and facilities, 
and the introduction of modern technologies for border control contributed to ensuring international 
protection  for  those  needing  it  and  respect  for  the  fundamental  rights  and  the  human  dignity  of 
third-country  nationals.  Two  Member  States101  reported  that  human  rights  issues  were  tackled 
through specific training sessions, with the support of EU agencies and international organisations 
working  in  the  field  of  migration  and  human  rights  (e.g.  IOM,  UNHCR,  and  Frontex).    One 
Member  States102  reported  implementing  an  action  focused  on  acquiring  linguistic  and  cultural 
mediation,  aiming  of  facilitate  communication  between  the  State  Police  and  migrants  during 
landing and/or rescue operations as well as when applying for international protection. Furthermore, 
another  Member  States103    reported  a  project  still  being  implemented  that  aims  to  strengthen  the 
development of training schemes on human rights and fundamental freedoms. Currently, the Fund 
is not supporting Member States in applying the non-refoulement principle. 

Regarding  direct  management,  6  out  of  7  action  grants  awarded  under  UAs  are  linked  to  border 
control,  surveillance  or  management.  However  none  of  them  had  been  completed  within  the 
evaluation period. Therefore, it is premature to reach any conclusions on their effectiveness.  

As  for  Emergency  assistance  (EMAS),  only  7  out  of  46  EMAS  actions  had  been  finalised  in  the 
period covered by the interim evaluation. EMAS has been used in seven Member States, especially 
in  Greece,  Italy  and  Bulgaria  during  the  migration  crisis  to  deal  with  the  extra  pressures  at  the 
external borders. In Bulgaria, for example, the amount of EMAS support in the period 2014-2017 
amounts  to  EUR 124.8  million  which  is  three  times  higher  than  the  allocation  for  the  national 
programme  covering  the  whole  period  2014-2020.  Therefore,  the  Fund’s  effectiveness  in  this 
specific  case  depends  to  a  large  extent  on  the  interaction  between  the  EMAS  support  and  the 
national programme. EMAS support has been considered essential in addressing emergency needs. 
The situation is somewhat different in both Greece and Italy as their EMAS allocations under ISF-
BV are smaller than in the case of Bulgaria but the size of their respective national programmes are 
much  larger.  Nevertheless,  EMAS  has  been  an  important  component  in  all  these  countries  in 
dealing with the crisis especially when the national programmes were not yet running due to delays 
in approval. 

While EMAS measures proved to be a very efficient instrument in rapidly addressing a number of 
emergency situations arising from the migration crisis, action grants under UAs were less popular. 
Member States expressed limited interest in them with few proposals received to the calls published 
by the Commission. They are also subject to lengthy delays in implementation. Perhaps their design 
including eligibility rules could be adapted to better address Member States’ needs. 

Overall, the Fund has contributed towards ensuring a high level of security in the EU as far as it is 
possible  at  this  stage  of  the  implementation,  also  taking  into  account  the  migration  and  security 
crisis.  The  results  achieved  so  far  show  that  the  Fund  is  an  effective  tool  in  supporting  Member 

99   11 Member States (AT, BE, BG, CH, CY, DE, EE, EL, FI, LT and LU). 
100   BG and SK. 
101   HU and IT. 
102   IT. 
103   CY. 

36 

 
 
 
 
 
 
 
                                                 
States  in  achieving  a  common  visa  policy  and  an  integrated  border  management.  Implementation 
delays  were  mainly  linked  to  the  late  approval  of  the  national  programmes,  but  now  that 
programmes  are  running,  the  Fund’s  implementation  is  on  track.  All  the  Fund’s  implementation 
modes contributed towards the achieving the Fund’s objectives. As regards shared management, the 
Fund contributed to ensuring a high level of security in the EU while facilitating legitimate travel, 
through  a  uniform  and  high  level  of  control  of  the  EU’s  external  borders  and  the  effective 
processing of Schengen visas. Direct and indirect management modes contributed to more effective 
border  and  visa  management  through  addressing  urgent  and  specific  needs  in  emergency  and 
unpredictable  situations  requiring  a  timely  and  effective  response  and through  projects  promoting 
transnational actions or actions of particular interest to the EU. These actions helped to strengthen 
the national capacity in the operational management of both borders and visa matters. 

Examples of different types of border management projects implemented by the Member 
States 

Austria supported the procurement of thermal imaging vehicles for Frontex operations to increase 
the  value  of  border  police  operations  in  other  Member  States,  simplifying  and  improving  border 
management.  Also  in  the  Czech  Republic  and  Poland,  the  Fund  co-financed  the  acquisition  of 
thermal  processing  to  strengthen  the  protection  and  surveillance  of  the  external  borders.  In 
Slovenia,  a key  investment in  strengthening  the  situational awareness  at  the  external  borders was 
the purchasing of two police patrol boats for the control of its maritime border to obtain data for the 
national  situational  picture  using  the  navigation  systems  and  by  reporting  important  events.  Both 
vessels  are  permanently  in  use,  and  data  are  collected  and  processed  within  the  national 
coordination centre. 

5.2  How efficient has ISF-BV been so far? 

This  question  aims  to  consider  the  relationship  between  the  Fund’s  inputs  (i.e.  resources,  budget 
etc.) and the outputs and results that it achieved. It tries to answer two questions: (i) to what extent 
the  effects  of  the  ISF-BV  actions  were  achieved  at  a  reasonable  cost  in  terms  of  financial  and 
human resources deployed and (ii) what measures were put in place to prevent, detect, report and 
follow-up cases of fraud, and other irregularities. 

In a nutshell 

Overall, in the limits of available data, it could be considered that the results of the Fund were 
achieved  at  a  reasonable  cost  in  terms  of  both  human  and  financial  resources.  Some  Member 
States  have  put  in  place  national  efficiency  measures.  However,  most  Member  States  face 
problems with the EU guidance, common indicators, and the reporting/monitoring calendar. The 
perceived administrative burden can be considered as a factor that undermines efficiency.  

Shared management 

A number of findings from the EBF ex post evaluation address issues related to efficiency, which 
have  been  taken  into  account  in  the  ISF-BV’s  design  such  as  more  flexible  multiannual 
programmes,  sufficient  allocation  of  resources at  Member  States  level,  simplified  structure  of  the 
Fund, improvement of the overall evaluation tools, etc. all of which have an impact on the Fund’s 
efficiency. 

37 

 
 
 
 
 
 
 
 
 
 
According to the evidence gathered by the external evaluation, overall, the results of the Fund were 
achieved  at  a  reasonable  cost  in  terms  of  both  human  and  financial  resources104  as  far  as  it  is 
possible to assess at this stage. The perceived administrative burden can be considered as the main 
factor that undermines efficiency. 

The  national  programmes’  implementation  started  very  slowly  creating  challenges  for  evaluating 
the  Fund’s  cost-effectiveness  because  the  majority  of  the  projects  are  still  ongoing.  The  Fund’s 
overall implementation is now on track.  For shared management, a 38 % implementation rate has 
been achieved. The payment rate stood at 12 % by the end of 2016. Possible reasons for such a low 
payment rate may include:  
1) late approval of most of the national programmes; 
2) complexity and length of public procurement procedures that delayed implementation, especially 
the purchasing of patrolling equipment such as vessels, boats, helicopters etc.; 
3) administrative burden (i.e. reporting requirements in relation to the annual accounts) that delayed 
implementation; and 
4) low pre-financing rates, hampering Member States commitment and the payments105. 

Taking  into  consideration  the  annual  accounts  for  2017  submitted  by  the  Member  States  in  mid-
February,  we  can  conclude  that  the  overall  payment  rate  improved  from  12 %  to  24 %,  with 
significant  improvements  noted  for  Italy,  Lithuania,  Spain  and  many  other  Member  States  as 
illustrated in Figure 7. 

Low  levels  of  costs  for  human  resources  were  associated  with  the  national  programmes’ 
implementation (at responsible authority or delegated authority level). In terms of number of full-
time  equivalents  (FTEs)  in  the  responsible  authority,  delegated  authority  and  audit  authority  in 
comparison to the number of projects implemented, the large variation found may suggest that the 
method  of  award  (direct  award,  call  for  proposals  etc.)  and  the  type  of  action  to  be  implemented 
(i.e.  specific  action  or  regular  project  under  the  national  programme)  affect  the  number  of  FTEs 
needed. 

On average, 7.08 FTEs per Member States have been involved in managing the Fund and have been 
paid  through  technical  assistance106  and/or  national  budgets,  with  remarkable  differences  between 
the different Member States. For example, at the time, Belgium had 3 FTEs to manage 27 projects 
and  an  allocation  for  the  national  programme  of  EUR 17.5  million,  while  Italy  has  involved  14 
FTEs  in  managing  22  projects  and  an  allocation  of  EUR 156.3  million.  Overall,  considering  the 
average  number of projects implemented by  2017 (12.84), an average of 0.55 FTEs was engaged 
per project. 

Overall,  Member  States  show  a  growing  or  stable  number  of  FTEs  over  the  years  from  2014  to 
2017, except Germany (FTEs decreased in number from 25 to 21) and Malta (FTEs decreased from 
13 to 10). On average, the number of FTEs increased from 2.44 in 2014 to 6.80 in 2016, increasing 
further  in  2017.  In  addition,  considering  the  ratio  between  technical  assistance,  plus  the 
administrative indirect cost, and the amount of the funds claimed for the financial year, on average 
the ratio stood around 1.41. In this regard, the ratio increased significantly over the years from 0.16 
in  2015  to  0.67  in  2016,  and  more  than  doubled  in  2017.  Considering  the  ratio  FTE 
(average)/amount  of  the  funds  claimed  for  the  financial  year  (average),  0.5  FTEs  have  been 

104   As also confirmed by 18 Member States (AT, BG, CH, CZ, DE, ES, FR, HU, LU, MT, NL, PL, EL, HR, IS, SE, SI and SK); 10 

participants to the eighth Evaluation Network Meeting (BE, BG, FI, HR, HU, NL, NO, PL, PT and RO). 

105   Conclusions of the AMIF-ISF Committee questionnaire, 2016; interviews with the Commission staff. 
106   Technical assistance should enable the Member States to support the implementation of their national programmes and assist 

beneficiaries in complying with their obligations and EU law. 

38 

 
 
 
 
 
 
 
                                                 
involved per million for the implementation of the ISF. In this regard, there has been a significant 
decrease  over  the  years,  dropping  from  an  average  of  1.35  FTEs  in  2014,  to  0.72  FTEs  in  2016, 
with  a  further  decrease  in  2017  to  0.5  FTEs,  leading  to  decreasing  labour  intensity  of  fund 
management. 

According  to  stakeholders,  some  of  the  success  factors  that  brought  efficiency  have  been  the 
following:  

  public  agencies,  as  beneficiaries  of  the  Fund  could  use  their  own  networks  to  involve 

additional resources on an ad hoc basis and at no extra cost for the project; 

  considerable  knowledge  and  expertise  had  been  gained  through  experience  from  previous 

projects (especially from SOLID and other programmes with multiannual projects); 

  staff were already employed in the organisation; and 
 

the flexibility of the national programmes (their multiannuality). 

Furthermore  national  measures  concerning  the  application,  implementation,  monitoring  and 
reporting  processes  have  been  put  in  place  in  some  Member  States107  to  ensure  efficiency  which 
include some of the following actions: 

  administrative and technical project approval procedures; 
  procedures to assess appropriateness of expenditure; 
 
  national coordination mechanisms.  

responsible authority project monitoring mechanisms; and 

the requirement to allocate minimum percentages among national objectives108; 

There are also a number of issues that Member States believe negatively affect efficiency and these 
are:  
 
  complex and recurrent reports109; 
  common indicators110: and  
 

the alignment of monitoring calendars111. 

Measures  put  in  place  to prevent,  detect, report and follow-up cases  of  suspected fraud and other 
irregularities include: 

  on the side of prevention: 

o  careful examination of project applications; 
o  ex ante public procurement control systems; 
o  risk analyses by the responsible authority/delegated authority; 
o 
o  provision of guidance tools; and 
o  regular communication between projects and responsible authority staff; 

training courses on fraud prevention or fraud risk management; 

  on the side of detection : 

o  administrative control checks; 
o  operational on-the-spot checks; 
o  financial on-the-spot checks; and 

107   7 Member States (AT, BE, FR, HU, MT, PL and SE). Interviews with 7 RAs (BG, CH, EL, FI, LT, PL and PT). 
108   2 Member States (BE and SI). 9 participants to the eighth Evaluation Network Meeting (BE, CH, EE, ES, HU, LT, NL, NO and 

PL). 

109   8 Member States (AT, BE, CY, CZ, ES, FR, IT and LV); 5 participants to the eighth Evaluation Network Meeting (BE, BG, DE, 

IT and NO); interviews with 2 RAs (BG and NO). 

110   11 participants to the eighth Evaluation Network Meeting (BE, DE, CZ, FI, FR, HU, LU, MT, NO, PL and PT); 1 Member 

States (DE). Interview with 1 responsible authority (NO). 

111   2 participants to the eighth meeting of the Evaluation Network (BE and FR). 3 Member States (BE, CY and FI). Interviews with 

2 RAs (FR and BE). Results from the online survey: 3 beneficiaries (BE, CZ and LU) and 2 AAs (CY and HU). 

39 

 
 
 
 
 
 
                                                 
o  ex post audits; 

  on the side of reporting and follow-up: 

implementation of communication instruments; 

o 
o  establishment of procedures for reporting suspected fraud; and 
o  establishment of procedures for corrective and deterrent measures. 

The  majority  of  Member  States  claims  that  the  anti-fraud  measures  are  appropriate and  effective, 
stating  that  stringent  mechanisms  ensure  the  effective  prevention  of  fraud  and  irregularities. 
Experience suggests, however, that there is always a potential trade-off between the procedures in 
place to prevent fraud and irregularities and the Fund’s overall efficiency, in the sense that measures 
can be seen as very effective for preventing fraud, but they are not necessarily very efficient from a 
management perspective. 

Direct management 

Regarding the 7 action grants awarded under the UAs, none of them had been completed by 30 June 
2017  and  only  7  out  of  46  EMAS  actions  had  been  finalised  in  the  corresponding  period. 
Consequently,  their  overall  implementation  rate  is  very  low  and  it  is  too  premature  to  reach  any 
conclusions  on  their  efficiency.  However,  it  is  worthwhile  noting  that  for  the  seven  completed 
EMAS actions the implementation rate was close to 100 %. As for procurement, which constitutes 
19 % of UAs, its implementation follows the relevant Commission procedures and is considered to 
be efficient. 

The  human  resources  at  the  EU  level  have  only  slightly  increased,  despite  the  large  increase  in 
value of the EMAS and the emergency situation on the ground following the migration crisis, and 
the  need  to  closely  follow-up  and  assist those  Member  States  under  pressure  while  implementing 
their  respective  national  programme.  These  factors  have  put  an  enormous  strain  on  the 
Commission’s services. 

No  data  was  available  at  the  time  of  performing  this  interim  evaluation  on  actions  under  indirect 
management. 

5.3  How  much  simplification  and  reductions  of  administrative  burden  has 
ISF-BV brought so far? 

The interim evaluation of the Fund proved that progress has been made in simplifying procedures 
for the beneficiaries under shared management with some room for improvement noted in relation 
to simplified cost options and the perceived high administrative burden. Beneficiaries under direct 
management  benefited  from  increased  simplification  of  procedures.  Nonetheless,  it  is  difficult  to 
quantify  how  much  simplification  was  brought  by  the  ISF-BV  overall.  Therefore,  a  qualitative 
assessment has been made. 

In a nutshell 

A  number  of  measures  that  aimed  to  simplify  management  procedures  and  reduce 
administrative  burden  have  been  put  in  place.  Despite  these  measures,  Member  States  still 
perceive  administrative  burden  as  being  high  and  the  implementation  of  the  simplified  cost 
options as problematic. Increased simplification has been noted under direct management.  

40 

 
 
 
 
 
 
 
 
 
 
 
 
Shared management 

The  EBF  ex  post  evaluation112  raised  some  efficiency  issues  also  connected  to  simplification 
matters  (i.e.  the  short  terms  of  the  programming  cycle,  the  need  to  ascribe  long-standing 
investments related to a multiannual programming framework to specific annual programmes). The 
Commission  Staff  Working  Paper  —  Impact  Assessment  for  AMIF  and  ISF  recommended  the 
introduction  of  the  following  components  in  order  to  increase  simplification  of  management 
procedures and reduce administrative burden:  
1) limiting the number of financial instruments to a two-fund structure; 
2) setting up a common, underpinning instrument, laying down uniform rules and procedures under 
both Funds (Horizontal Regulation); and 
3) a multiannual programming cycle113. 

All  these  recommendations  have  been  taken  on  board  by  ISF-BV.  First  of  all,  the  different 
instruments under the SOLID and SSL programmes have been replaced by only two funds: AMIF 
and ISF. In  addition, Regulation (EU) 514/2014 (Horizontal Regulation), common to both Funds, 
and delegated acts have been introduced laying down a shared management framework to improve 
operational harmonisation and simplify implementation, monitoring, and evaluation mechanisms114. 
Furthermore,  the  Fund  has  been  built  up  in  line  with  a  more  flexible  multiannual  programming 
cycle115,  providing  the  right  balance  between  the  duration  of  EU  terms  of  office  and  the  need  to 
ensure  the  higher  stability  of  programming  cycles,  and  allow  higher  investments’  value  and 
predictability116.  All  Member  States  confirmed  the  advantages  entailed  by  the  multiannual 
programming117, including: 

 

 

 

the possibility to promptly identify strategic and long-term priorities, as well as to establish 
new emerging priorities to address up-and-coming unforeseen needs; 
the possibility to plan and implement large investments in the long run, without restrictions 
imposed by the annual implementation cycle; and 
the  reduction  of  administrative  overlaps  and  burden  thanks  to  the  annual  programming 
cycle. 

A  number  of  measures  were  introduced  to  increase  overall  simplification  The  introduction  of 
national eligibility rules provided for some flexibility in the management of the Fund by RAs by 
means  of  clearer  rules  compliant  with  the  different  national  legislation  and  administrative 
procedures,  which  allowed  beneficiaries  to  improve  their  understanding  and  operational  capacity, 
therefore  reducing  the  time  needed  for  processing  applications  and  delays  in  implementation118. 
While  the  introduction  of  national  eligibility  rules  was  considered  as  positive  by  most  Member 
States, for some it was a hampering factor especially when it comes to multi-state projects. As for 
the  simplified  cost  options  (SCOs),  particularly  the  flat  rate  applied  to  indirect  costs,  they  (i) 
provided significant administrative simplification, (ii) made project management easier, (iii) led to a 

112   Optimity Advisers and CSD (2016). Ex post evaluation of the External Borders Fund 2011-2013. 
113   SEC(2011) 1358 final. 
114   European Commission, ‘The basic acts and other regulations of the 2014-2020 Home Affairs Funds: AMIF and ISF’. 
115   Regulation (EU) 515/2014, (51) in alignment to Council Regulation (EU, Euratom) No 1311/2013 of 2 December 2013 laying 

down the multiannual financial framework for the years 2014-2020. 

116   Answers by EU Officials interviewed during interviews and of 4 out of 30 Member States (BG, PL, MT and NL) providing an 
overview of ISF-BV’s positive aspects and implementation issues during the eighth Meeting of the Evaluation Network. 
117   All Member States. Interviews with 7 RAs (BG, PT, PL, FR, national programme, NL and LT). 50% of the replies to the online 
survey. Only Switzerland (interview with the Swiss responsible authority) has provided a different opinion, reporting that the 
multiannual programming has actually increased overall burden in terms of planning actions, since the seven-year timeframe 
does not enable support for actions that can effectively respond to the ever-changing context, nor does it provide support for the 
requirements in the fields of borders and visa management. 

118   Member States: AT, DE, EE, EL, HU, LT, LU, MT, PL and PT. On the contrary, Cyprus stressed that the introduction of 
national eligibility rules, as they needed to be established anew, created higher administrative burden, especially at the 
beginning of the new programming period. 

41 

 
 
 
 
                                                 
reduction of error rates and (iv) allowed RAs and beneficiaries to focus on outputs and results119. 
However,  in  some  cases,120  the  adoption  of  SCOs  raised  implementation  issues,  due  to  the 
absence  of  common  principles  and  standards  which  hindered  or  discouraged  beneficiaries  from 
declaring  and  reporting  all  costs,  as  they  were  afraid  that  audit  authorities  may  declare  costs 
ineligible.  

The  introduction  of  operating  support121  has  been  positively  assessed,  since  it  enabled  national 
budgets to be supported on issues that would otherwise be difficult to cover (e.g. sustainability of 
maintenance  costs)122.  Moreover,  the  increased  cooperation  between  the  responsible  authority 
and  beneficiaries,  also  committed  to  by  means  of  operational  guidance  and  support  directly 
provided by the responsible authority, is regarded as very positive, improving implementation and 
reporting,  and  verification 
increasing 
requirements123.  The  digitalisation  of  reporting  and  communication  procedures was  positively 
assessed  by  several  Member  States,  since  it  allowed  financial  and  technical  reports  to  be  sent  in 
electronic  form,  which  shortened  the  document  processing  time  for  beneficiaries124  and  also 
facilitated  the  work  of  RAs  thanks  to  the  centralisation  of  all  relevant  documents  and 
communications with the Commission in one electronic database125.  

the  beneficiaries’  compliance  with  monitoring, 

As  regards  the  Special  Transit  Scheme  for  Lithuania,  the  instrument  has  been  assessed  very 
positively by projects’ beneficiaries, although there have not been significant changes, compared to 
the previous period126. However, despite the multiple measures introduced to increase simplification 
and the positive feedback they received127, stakeholders agreed on the Fund’s limited contribution 
to reducing administrative burden128. Monitoring, reporting, and verification procedures remain 
burdensome and many Member States pointed out a lack of detailed instructions, asking for more 
Commission  guidelines  in  order  to  meet  the  monitoring  and  reporting  standards  required  by  the 
Commission129. Furthermore, the Common Monitoring and Evaluation Framework was established 
too  late,  which    hindered  the  Fund’s  implementation  since  the  reporting  on  projects  had  to  be 
adjusted  under  the  CMEF  while  projects  had  already  started130.  Also,  the  RAs  of  the  Schengen 
Associated  Member  States  criticised  delays  during  the  programming  stage.  In  their  opinion, 
simplification would have been increased by ensuring Schengen Associated Countries’ accession to 
the Fund at an earlier stage, allowing them to begin implementing actions at the same time as other 
Member States131. 

119   Member States: CH, EL, FR, LT, LU and PL. Interviews with 4 RAs (BG, BE, NL and SI). 
120   Webinar held on 14 November on ISF problem definition in the context of the Interim Evaluation to support the preparation of 
the next generation of EU Funds in the Home Affairs area; interview with the BG Responsible Authority. 37% of replies to the 
online survey. 

121   Regulation (EU) 515/2014, Art.10. 
122   Member States: AT, CH, CY, IS, IT and PT. 
123   Member States: AT, BE and HR. 
124   Member States: FI, BE, EE and PL. 
125   Ibidem. 
126   Member States: LT. 
127   Details are provided further in this section. 
128   Member States: AT, BE, BG, CH, CY, CZ, DE, EL, EE, ES, FI, FR, HR, HU, IT, LU, LV, MT, NL, PL, PT, SE and SI. 

Interviews with 6 RAs (NO, NL, BE, IT, ES and BG); 1 delegated authority (EL). 

129   Interviews with BE, CH, and NO RAs and Webinar held on 14 November on ISF problem definition in the context of the 

Interim Evaluation to support the preparation of the next generation of EU Funds in the Home Affairs area. 

130   CMEF was approved on 3 October 2016. 
131   Interviews with CH and NO RAs. 

42 

 
 
 
 
 
                                                 
Examples of the use of simplified cost options 

In  Finland  and  Romania,  the  use  of  the  flat  rate  financing  for  indirect  costs  has  facilitated 
beneficiaries, since travel costs do not need to be tracked in the bookkeeping132. On the contrary, 
Hungary could only implement simplified cost options to a limited extent, since the plan to use unit 
scale costs and lump sums for training projects was not approved by the responsible authority due to 
the presence of non-comparable cost categories, despite the projects being of the same naturet133.  

Direct management 

Under direct management, procedures are considered to be appropriate, clear and transparent and do 
not create additional burden for Member States or beneficiaries134. Most difficulties encountered by 
beneficiaries  in  implementing  EMAS  actions  are  generally  connected  with  national  political 
issues135 or operational difficulties related to the projects’ implementation (i.e. lack of adequate and 
competent human resources to implement the measures)136. 

132   Member States: FI and RO. 
133   Member States: HU. 
134   Analysis of EMAS and UAs technical reports. Interviews with RAs: BG and IT. 71 % of replies to the online survey. 
135   For instance, as regards the implementation of EMAS in Greece (HOME/2014/ISFB/AG/EMAS/0007 and 

HOME/2014/ISFB/AG/EMAS/0008), the austerity measures and capital control at national level created a limited vendor base 
and frequent requests for advance payments. 

136   Analysis of EMAS and UAs technical reports. 

43 

 
 
 
 
 
 
 
                                                 
5.4  How relevant has ISF-BV been so far? 

This evaluation question aims to determine whether the Fund’s original objectives are still relevant 
and how well they still match the current needs and problems. It also addresses the question of the 
Fund’s flexibility against changing circumstances in the wider context. 

In a nutshell 

The Fund's original rationale and objectives are still relevant in the aftermath of the migratory 
crisis. Appropriate mechanisms have been put in place to address the changing needs both at the 
programming  and  implementation  stages.  The  flexibility  offered  by  the  Fund,  consisting  of 
transfers of money between different objectives, helped to address the changing needs. However 
Member  States  would  appreciate  even  more  flexibility  that  would  result  from  the  minimum 
allocations  of  funds  to  objectives  no  longer  being  imposed  and  the  number  of  national 
objectives being reduced.  

The  design  of  the  national  programmes,  including  the  identification  of  key  needs,  priorities  and 
objectives, was supported by the policy dialogue between the Commission and the Member States 
at the beginning of the programming stage. The policy dialogue took account of both the difficulties 
encountered  during  the  EBF  programming  cycle  and  the  new  and  emerging  needs  as  reported  at 
national level. In some Member States the objectives set in the national programmes were based on 
national  strategic  documents  defining  long-term  goals  and  priorities,  further  helping  to  align  the 
national programmes with the identified needs. A common problem perceived at national level was 
the migratory pressure at the external borders and related security threats. In this light, all Member 
States allocated more resources under specific objective Borders than under specific objective Visa. 
Also,  given  the  fragmentation  of  actions  under  multiple  national  objectives  that  prevented  the 
pooling  of  resources  around  key  priorities  and  made  it  difficult  to  implement  cross-objective 
projects. This has also led to an increased administrative burden as the Member States are required 
to  report  on  the  implementation  of  cross-objective  actions  for  each  national  objectives  concerned 
with the actions specific scope.  

During the Fund’s implementation, some trends increased the need for an effective EU action at its 
external borders. An increasing number of refusals of entry issued at the EU’s external borders has 
been  noted  since  2014  with  115 862  registered  in  2014,  130 279  in  2015,  215 403  in  2016  and  a 
slightly  lower  number  in  2017  -  183 548137.  Document  fraud  detections  at  the  Member  States’ 
external  borders  decreased  steadily  since  2014  on  specific  incoming  routes138  and  reached  their 
lowest  level  in  the  second  quarter  of  2016  compared  to  figures  since  the  beginning  in  2013139. 
Increased  migratory  pressure  in  the  Central  Mediterranean  has  been  noted  mainly  due  to  West 
African arrivals with the highest levels of irregular migration reported in 2017140. The exceptional 
migratory pressure required common high standards of border management that fully comply with 
the rule of law and with fundamental rights in order to prevent cross-border crime and terrorism141. 
In this context, the Commission introduced an action plan as part of a broader effort to address the 

137   Frontex Risk Analysis Annual Report 2018. 
138   Ibid. 
139   Frontex Risk Analysis (FRAN) 2016, Q2. 
140   In the first quarter of 2017, irregular migration flows from Libya, Turkey, Algeria and Greece all increased, while the number of 

arrivals from Tunisia decreased (Frontex Risk Analysis (FRAN) 2017, Q1). 

141   COM(2015) 185 final European Agenda on Security. 

44 

 
 
 
 
 
 
 
                                                 
 
root causes of irregular migration, in cooperation with countries of origin and transit142. In addition, 
the  visa  liberalisation  dialogues  with  neighbouring  countries  (Georgia,  Ukraine,  Kosovo  and 
Turkey) raised the need for strengthened cooperation in the area of border control, requiring also a 
revision of the ‘suspension mechanism’143. 

The identification of priorities to be covered by the ISF-BV national programmes was based on a 
thorough  policy  dialogue  between  the  EU  and  the  Member  States,  taking  into  account  the 
difficulties encountered during the previous programming cycle, the new EU policy priorities and 
the new and emerging needs as reported at the national level. The interim evaluation also indicates 
that  the  Fund’s  scope  is  sufficiently  broad  to  enable  necessary  actions  to  be  implemented  in  the 
areas of external border management  and the common policy on visa. Despite new and emerging 
needs which changed the migration picture, the Fund’s objectives are still relevant and have adapted 
to challenges144. What also contributed to addressing the changing needs, is the  flexibility offered 
by  the  Fund,  i.e.  Member  States  are  allowed  to  transfer  money  between  the  specific  objectives 
worth up to 15 % of the basic allocation without needing to revise the national programme. 

Regarding  borders,  almost  all  Member  States  deemed  the  increasing  pressure  at  the  external 
borders  as  a  significant  challenge  to  their  border  control  policy145.  Such  pressure  resulted  in  an 
increase in the proportion of passengers that come from outside the Schengen area out of the total 
number  of  passengers146.  As  migration  patterns  are  fluid  and  the  composition  of  the  flow  is 
constantly  changing,  more  attention  needs  to  be  paid  to  the  link  between  border  management, 
terrorism and cross-border crime and this is where both ISF-BV and ISF-P proved to be useful and 
relevant. Member States identified the following needs during the programming stage: 

increase border surveillance capacity147; 

 
  develop EUROSUR through:148  

o  developing the EUROSUR national coordination centres; 
o  developing and modernising automated surveillance systems; and 
o  upgrading the National Situational Picture for EUROSUR through collecting related 
information and data so as to ensure compliance with EUROSUR requirements; 

  maintain and further upgrade the national Schengen Information System II and link it with 
relevant international databases (Schengen Information System, SIRENE), and train border 
guards  especially  in  Schengen  Borders  Code  practices  and  modules  from  the  Frontex 
Common Core Curriculum149; 

142   COM /2015) 285 final EU action plan against migrant smuggling (2015-2020). 
143   This suspension mechanism ex Article 1a of Regulation (EC) No 539/2001 allows the visa exemption for third-country nationals 
to be temporarily suspended in certain emergency situations, as a last resort. The proposed revision was meant to strengthen the 
suspension mechanism by making it easier for Member States to notify circumstances leading to a possible suspension (COM 
(2016) 290 final). 

144   Eighth Meeting of the Evaluation Network: BE, CH, EE, ES, LT, NL, NO, PL and HU. Member States: AT, CH, CY, CZ, DE, 
EL, FI, HU, IT, LT, LU, LV, NL, PL, PT, RO, SE, SI and SK. Interviews with 10 RAs (NO, PT, PL, BG, FR, NL, LT, NL, FI 
and IT) and 1 delegated authority (EL). 
145   National programmes: BE, BG, CH and NL. 
146   For instance in the baseline data given in the Swiss draft national programme, in 2015, compared to 2014, the number of asylum 
applications rose by 66.3% (from 23 765 applications to 39 523). Thus, Switzerland remained one of the primary destination 
countries for people crossing the central Mediterranean to Europe. 

147   National programmes: CY, CZ, FR and IT. 
148   A priority in the following National programmes: BG, CY, CZ, FI, FR, GR, HR, LV, LT, PL and SK. In the case of EE and FI, 
EUROSUR was emphasised as the most significant development in the coming years. On the contrary, EUROSUR was not a 
priority for NO and SI where all necessary infrastructure and equipment had already been purchased before the ISF was 
implemented. 
149Further information on the Frontex Common Core Curriculum can be found at: http://frontex.europa.eu/training/educational-
standards/ 

45 

 
 
 
 
                                                 
 

information  exchange150  (strengthen  capacities  of  communication  systems 
improve 
supporting the border control and further develop Visa Information System functionality for 
fluid communication between the various services);  

  ensure  the  correct  application  of  EU  acquis151  (training  for  staff  tasked  with  guarding 
borders on the EU legal instruments, on the specific tasks in the process of border control in 
order to improve their professional qualifications and knowledge152 incl. relevant language 
training for border guards153; and 
introduce  common  EU  standards154  (introduce  ABC  technology  and  strengthen  controls  at 
border  crossing  points)  and  improve  the  national  Schengen  Information  System  II  and 
SIRENE through the operating support155. 

 

Regarding  visa,  the  ever-increasing  number  of  visa  applications  posed  a  challenge  to  consulates 
especially  due  to  problems  concerning  the  security  of  their  premises  and  obsolete  equipment  for 
visa  processing  as  reported  by  a  number  of  Member  States156.  Consequently,  the  Member  States 
identified a number of key needs during the programming stage157, such as: 

  developing  the  national  visa  systems  including  the  improvement/replacement/maintenance 

 

of equipment; 
furnishing  consulates  with  modern  equipment  to  help  detect  falsified  documents  and 
upgrade network services158;  

  ensuring  quality  processing  of  visa  applications  and  continuous  improvement  of  the  visa-

 

issuing process; 
training consular officials and staff assigned to the national visa system on Schengen acquis 
and on counterfeited and false documents; 

  establishing  and/or  maintaining  consular  cooperation  with  other  Member  States  so  as  to 

exchange experiences, best practices, and knowledge;  

  purchasing additional or replacing the existing IT and security equipment; and 
  ensuring  the  exchange  of  information  and  connecting  all  visa  authorities  through  the  Visa 

Information System (VIS Mail phase 2 began operating on 20 January 2016)159. 

Furthermore,  with  regard  to  the  operating  support,  it  was  mainly  used  for  maintaining  the  Visa 
Information  System160  and  ensuring  proper  functioning  and  further  development  of  Schengen 
Information System II used at all border crossing points161. 

Despite  evidence  gathered  on  the  relevance  of  the  Fund,  some  areas  for  improvement  have 
been reported by the Member States162. Basic amounts of resources had to be allocated to certain 
specific  objectives  outlined  in  the  legal  base  for  the  ISF-BV  (minimum  percentages).  However, 
where a Member State did not address one of the specific objectives in its national programme set 

150   National programmes: BG, CZ, FI, FR and HU. 
151   National programmes: BG, CZ, EE, FR, GR, HR, HU, PT, SK and SI. 
152   e.g. training on implementation of Schengen Acquis, document forgery, methodological training, and handling apprehended 

vulnerable-persons. 

153   Referred to in national programmes: FI and FR. 
154   National programmes: DE, DK, FI, GR, IT, PT and SK. The installation of the ABC gates was a top priority in Iceland. 
155   National programmes: LV, LU, PT and SI. 
156   National programmes: CH, CY, EE and FR. 
157   Source: National programmes. 
158   For instance, a single internet service provider that will create a Multi-Protocol Label Switching network. 
159   As underlined by the Hungarian national programme, it was necessary to invest in Visa Information System and interoperability 

for Visa Information System with existing and new IT systems. Similarly, Denmark intended to optimise 75 % of Visa 
Information System with the Fund’s help. On the contrary, Switzerland covered this need through national resources. 

160   5 national programmes (IT, CY, ES, FI and FR). 
161   5 national programmes (FI, DE, HR, IS and SK). 
162   Interviews with 2 RAs (BE and CH). 

46 

 
 
 
 
 
                                                 
out  in  the  ISF-BV  Regulation  or  where  the  allocation  envisaged  was  below  the  minimum 
percentage  for  some  objectives,  the  Member  States  concerned  had  to  provide  a  justification  for 
deviating. Despite the afore-mentioned flexibility offered by the Fund, some Member States thought 
the number of national objectives was too high with the links between them unclear163, resulting in 
the  fragmentation  of  projects  under  different  national  objectives.    This  prevents  the  pooling  of 
resources under the national objectives deemed most relevant at the national level. Therefore, some 
Member States suggested providing a smaller number of objectives with a cross-cutting and broader 
scope, which would increase the Fund’s overall relevance164. 

Direct and indirect management 

Both direct and indirect management actions proved to be relevant. They were complementary 
to national programmes and helped to achieve the Fund’s priorities and objectives165. Their flexible 
operational architecture contributes  to  the  Fund’s  relevance with  action strategies  being  redefined 
according to actual emerging needs by means of simple and quick amendments to grant agreements 
(i.e. to get further administrative and operational support, modify the EU contribution or extend the 
period covered by the grant agreement). 

The  Fund  may  support  UAs,  i.e.  transnational  actions  or  actions  of  particular  interest  to  the  EU 
concerning the general, specific and operational objectives referred to in Article 3166. UAs should 
be aligned with the following aspects identified in the intervention logic: 

  problems, i.e. 

o  ‘Member States have divergent interpretations and application of visa code’, 
o  ‘IT systems potential is under used’, 
o  ‘External border management is not fully integrated’; 

  needs, i.e. 

o  ‘Improving services for visa applicants, boosting practice harmonisation’, 
o  ‘Supporting Schengen acquis on border and visa application’, 
o  ‘Developing EU common border management system’; and 

 

impacts, i.e. 

o  ‘Enhanced situational awareness, through staff training concerned with border and 

visa management’, 

o  ‘Higher, full, and interoperable use of (existing or new) IT systems’, 
o  ‘Improved cooperation and dialogue with third countries, by means of agreements 

and partnerships’,  

o  ‘Increased harmonisation to migration management and internal security’.  

According  to  the  analysis  of  UAs’  2014-2017  AWPs,  the  original  priorities  and  objectives  set  by 
the  legal  base  for  UAs167  are  still  relevant.  It  is  possible  to  identify  six  clusters  of  priorities  and 
objectives  pursued  by  the  AWPs  that  were  relevant  in  order  to  address  the  needs  over  the  period 
2014-2017:  (i)  Schengen  evaluation,  (ii)  EUROSUR,  (iii)  training  of  ILOs,  (iv)  regional 
cooperation,  (v)  coordination  of  research  activities,  and  (vi)  IT  tools  (Schengen  Information 
System).  Interviews  conducted  with  beneficiaries  of  UAs  confirmed  the  relevance  of  these 

163   Member States: AT. Eighth Meeting of the Evaluation Network: BE and NL. 
164   Member States: AT. Eighth Meeting of the Evaluation Network: BE and NL. Poland is not in line with this statement as it 

deems the rules governing the transfer of funds between different objectives as easing the Fund’s management, allowing for 
flexible adaptation to the current needs. 

165   Interviews with 6 RAs (BE, BG, FR, PT, PL and LT). 
166   Regulation (EU) 515/2014. 
167   Regulation (EU) 515/2014. 

47 

 
 
 
 
 
 
                                                 
priorities.  In  particular,  one  Member  States168  stressed  the  importance  of  developing  EUROSUR 
and  increasing  Member  States  cooperation  in  order  to  improve  border  control.  To  this  end,  it 
allocated a significant part of the Fund’s resources to the control of the maritime external borders 
and to the establishment of an integrated network of IT systems with other Member States. Another 
Member  States169  confirmed  that  strengthening  the  cooperation  between  Member  States  by 
exchanging information and good practices was relevant for improving border surveillance and for 
preventing transnational organised crime. 

EMAS  actions  ensured  there  was  financial  assistance  to  address  urgent  and  specific  needs  in  the 
event of emergency situations stemming from exceptional migratory pressure170. EMAS actions are 
aligned with problems (‘Migratory pressure and security threats are increasing’), needs (‘Tackling 
illegal migration’), and impacts (‘Immediate taking on of unforeseen migratory pressure and risks 
through  EMAS  and  adequate  resource  distribution’)  as  identified  in  the  intervention  logic. 
According  to  the  analysis  of  EMAS  2014-2017  AWPs,  the  above-mentioned  problems  and  needs 
still remained valid over the period 2014-2017. However, their gravity has increased immensely as 
a result of the migration crisis171. EMAS has also contributed to the Greek hotspots172 by providing 
funds  for  food,  shelter,  medicines  and  transport  at  the  hotspots,  and  funds  for  strengthening  the 
fingerprinting capacity on the ground. It should be also noted in response to the migration crisis the 
allocation of funds to EMAS increased 11 times. 

As  regards  measures  put  in  place  to  address  changing  needs,  it  is  important  to  note  that  the 
needs  identified  during  the  programming  stage  did  not  change  significantly  during  the  Fund’s 
implementation; rather it is the volume of issues to be addressed that increased as a consequence of 
the migration crisis173. 

A  number  of  mechanisms  have  contributed  to  ensuring  the  Fund’s  relevance174  and  the  Member 
States’ ability to address changing needs. 

At  the  beginning,  the  policy  dialogues  between  the  Commission  and  the  responsible  authorities 
enabled key needs to be identified and priorities and objectives to be designed accordingly175. The 
consultative  method  adopted  with  key  stakeholders  (the  Commission  and  central  authorities 
concerned  with  the  Fund’s  implementation)  and  direct  beneficiaries  (generally  public  institutions 
and  ministries)  enabled  their  needs  to  be  clearly  identified  during  the  programming  stage176  and  
emerging needs to be assessed alongside the programming cycle. 

Changing  needs  were  addressed  through  minor  budgetary  adjustments  and  transfers  between  the 
specific  objectives  of  the  national  programme  of  up  to  15 %  of  the  basic  allocation  thanks  to  the 
flexibility clause in the legal base. This was considered to be a useful tool that enabled adaptation 
to  the  changing  environment  and  allowed  some  fine-tuning  during  the  implementation  cycle177. 

168   Interview with 1 Union action beneficiary (PT). 
169   Interview with 1 Union action beneficiary (ES). 
170   Regulation (EU) 515/2014, Article 2 f) and Article 14. 
171   Interviews with 7 RAs (BE, BG, EL, FR, LT, PL and PT). 
172   The Hotspot approach was developed as part of the European Agenda on Migration. The operational support provided to 

Member States is concentrated on registering, identifying, fingerprinting and debriefing asylum seekers. It is also concentrated 
on return operations. The Member States cooperate closely with the Commission and a few EU agencies (EASO, Europol, 
Frontex and Eurojust) in order to operationalise the concept. So far 10 hotspots have been created in Italy and Greece. 
173   Member States: CZ, DE, LT, PT and SK. Interviews with 4 RAs (NL, BG, PL and NO) and 1 delegated authority (EL). 
174   Interviews with 6 RAs (BE, BG, FR, PT, PL and LT). 
175   Member States: AT, BE, CH, CZ, MT and NL. 
176   Member States: AT, BE, BG, CH, CY, CZ, EE, FR, HR, HU, IT, LU, MT, NL, RO, SE and SI. 
177   Member States: AT and PL. 

48 

 
 
 
 
 
 
 
                                                 
Furthermore,  continuous  programme  monitoring  during  the  implementation  stage178  allows  the 
responsible  authority  to  promptly  analyse  the  content  defined  in  the  national  programmes  and  to 
adapt  to  changing  circumstances  and  emerging  needs  in  cooperation  with  the  Monitoring 
Committee (MC). Due to the changes needed, the responsible authority should consider whether a 
revision  of  the  programme  is  necessary.  Reprogramming  may  be  required  in  order  to  address  the 
recommendations following a Schengen evaluation report179. 

The  mid-term  review  mechanism  allows  for  a  reassessment  of  needs  and  a  dialogue  with  the 
Commission including the possibility to amend the programme where necessary, therefore ensuring 
that the Fund still corresponds to the actual needs180.  

In addition, the ISF Monitoring Committee has also contributed to ensuring that the Fund remains 
relevant.  In  fact,  the  Monitoring  Committee  should  support  the  Fund’s  implementation.  As 
evaluation  reports  show,  the  Committee  also  makes  recommendations  on  how  to  improve 
implementation and payment capacities181. 

5.5  How coherent and complementary has ISF-BV been so far? 

These  evaluation  questions  look  at  the  extent  to  which  different  ISF-BV  actions  work  together 
internally and with other EU interventions and identify whether there are complementarities, gaps 
and overlaps between different initiatives. 

5.5.1.  Coherence 

In a nutshell 

The Fund is considered to be coherent with other EU and national interventions. Coherence with 
other  EU  financing  instruments  was  ensured  at  the  programming  stage.  Coordinating 
mechanisms have been put in place to ensure continued coherence at the implementation stage. 
The Monitoring Committee and the Responsible Authority play key roles in ensuring coherence. 

ISF-BV funded actions were found to be coherent with other actions related to border management 
and visa system policy funded by other EU financial instruments, incl. AMIF and ISF-P, and from 
the national resources of the Member States. Some policy fields were found to be at a higher risk of 
overlapping with the Fund, including some areas under ESIF, the European Regional Development 
Fund  and  the  Societal  Challenge  ‘Secure  Societies  —  protecting  freedom  and  security  of  Europe 
and  its  citizens’  under  Horizon  2020.  Nonetheless,  no  overlaps  or  duplications  between  the  Fund 
and the aforementioned interventions have been found to date. 

Internally, there is high coherence and complementarity between national programmes and EMAS, 
which  have  clearly  supported  each  other  and  high  coherence  between  national  programmes  and 
UAs  (the  latter  being  clearly  design  to  complement  the  national  programmes).  EMAS  especially 
played  a  significant  role  in  bridging  the  gap  until  national  programmes  were  fully  adopted. 

178   Member States: CH, FI, FR, HU, LU, MT, NL, PL, RO and SK. 
179   Art. 12 of Regulation (EU) No. 515/2014 in accordance with Council Regulation (EU) No 1053/2013  of 7 October 2013 
establishing an evaluation and monitoring mechanism to verify the application of the Schengen acquis and repealing the 
Decision of the Executive Committee of 16 September 1998 setting up a Standing Committee on the evaluation and 
implementation of Schengen. 
180   Member States: FR, HR, PL and RO. 
181   Member States: CZ, DE and LV. 

49 

 
 
 
 
 
 
 
 
 
                                                 
 
However,  there  appears  to  be  room  for  improvement,  especially  with  regard  to  UAs  and  EMAS, 
because  most  ISF-BV  beneficiaries  were  not  aware  of  other  ISF-BV  financed  actions  and 
considered  coordination  to  be  an  informal  initiative.  There  is  clearly  a  need  for  more  formalised 
information at project and national level. 

Several  Member  States  carried  out  assessments  of  other  EU  interventions  with  similar  objectives 
during  the  programming  phase182,  covering  in  particular:  European  Structural  and  Investment 
Funds183;  EU  external  relations  instruments184;  and  other  EU  funds  or  programmes185.  In  other 
Member States186, coherence was ensured by making it mandatory for project applicants to give an 
overview of the projects they implemented previously in similar areas with the support of EU funds 
or other instruments. 

Most Member States adopted different coordinating mechanisms to ensure coherence with similar 
interventions carried out under other EU funds. The main ones are: 

 

information exchange on the Fund’s actions and projects between the responsible authority 
and  other  institutional  actors  responsible  for  other  funds  at  different  levels  and  with 
Frontex; 

  structured  policy discussion  — regular  meetings to  discuss strategic documents organised 
with  the  managing  authorities  of  other  EU  programmes  and  interinstitutional  working 
groups involving representatives of the potential beneficiaries187; and 
institutional arrangements, specific directorates, divisions, units, platforms, and committees 
set up to boost the coordination and synergies with other EU funds188. 

 

Most Member States emphasised the key role of specific actors including relevant public authorities 
at national level, international organisations, non-governmental organisations, etc. that contributed 
to the Fund’s implementation, by (i) boosting synergies and preventing overlaps between ISF-BV, 
ESIF  programmes,  and  other  EU  instruments  and  (ii)  strengthening  communication  and 
coordination among actors concerned by different instruments189. Thus the MC was shown to be the 
main  institutional  tool  that  ensured  the  ISF-BV’s  complementarity  and  coordination  with  other 
funds. The MC includes, as members or as observers, representatives of institutions responsible for 
the  use  of  other  relevant  funds.  It  holds  regular  meetings  and  continuously  analyses  the 
implementation status of ISF-BV projects. The Responsible Authority communicates regularly with 
relevant partners and other state administration authorities to avoid any overlaps, ensures there is no 
double-funding by examining and validating the original invoices, and implements the decisions of 
the MC. 

Finally,  ensuring  coherence  between  the  ISF-BV  actions  and  other  interventions  with  similar 
objectives  at  EU  level  is  extremely  important  in  order  to  ensure  that  external  borders  and  the 
common  visa  policy  are  managed  effectively.  Some  EU  programmes  have  been  deemed  quite 
similar  to  the  ISF-BV  interventions.  Customs  2020  is  the  EU  programme  supporting  the 
functioning and modernisation of national customs in the EU as well as administration cooperation 

182   All national programmes; Member States: BE, DE, EE, FI, FR, HU, LT, LV, MT, NL and PL; interviews with 4 RAs (CH, BG, 

FI and BE). 

183   European Regional Development Fund, European Social Fund, Cohesion Fund, European Agricultural Fund for Rural 

Development, and European Maritime and Fisheries Fund. 

184   e.g. Instrument for Pre-Accession Assistance, European Neighbourhood and Partnership Instrument, and Instrument 

contributing to Stability and Peace. 

185   e.g. Lifelong Learning programme, Cultural programme, and Youth in Action programme. 
186   Member States: CZ, EE and IT. 
187   AIRs: BG, IT and SI. 
188   AIRs: AT, BG, CY, CZ, HR, MT and SE. 
189   Member States: BE, CZ, CY, DE, EE, FI, HR, LV, LT, NO, PL, RO, SE, SI and SK. 

50 

 
 
 
 
 
 
                                                 
for  the  period  2014-2020.  No  overlaps  between  Customs  2020  and  ISF-BV  have  been  noted  so 
far190.  Nonetheless,  since  Customs  2020  and  ISF-BV  share  common  objectives  related  to  security 
issues  and  training,  potential  areas  for  synergies  have  been  noted  in  those  two  areas191.  Potential 
synergies  have  been  looked  for  through  joint  meetings  and  work  on  documents  and  guidelines  
concerning  co-operation aspects of border guards and customs services.  The ex post evaluation of 
the  EBF  had  already  called  for  a  better  mapping  and  monitoring  of  programmes  which  include 
actions taking place at the external borders in order to check the possibility of joint procurement or 
training192. 

Actions  funded  by  Frontex  are  also  an  example  of  an  intervention  that  is  coherent  with  ISF-BV. 
ISF-BV  supports  measures  under  Frontex  joint  operations  in  order  to  boost  the  Agency’s 
operational capacity. This is enabled by the specific actions under ISF-BV. However, the need for 
more  coordination  between  the  Commission  and  Frontex  was  already  underlined  in  the  EBF’s  ex 
post evaluation193 as one recommendation was to ensure that the Commission consults Frontex on 
the draft national  programmes  of the Member States before adopting them. This  recommendation 
has already been taken into account in the ISF-BV Regulation, which in Article 9(4) provides for 
such  obligatory  consultation.  During  the  programming  period,  the  Commission  consulted  Frontex 
on all draft national programmes and took into account to the extent possible all comments received 
by the Agency. In addition, to ensure coherence between the activities financed by the ISF-BV and 
Frontex,  the  Commission  put  in  place  coordination  measures  that  encompass  electronic  data 
exchange on purchases of Frontex equipment both under shared and direct management and provide 
Frontex with direct access to SFC2014 together with the related IT training. 

Examples of national assessments of other interventions during the programming stage 

In Austria, the co-financing agreements for projects financed by the BMEIA194 contained a requirement for 
the  project  beneficiary  to  ensure  there  was  no  duplication.  Belgium  regularly  organised  consultations 
within  the  Steering  Committee  including  representatives  of  the  Foreign  Affairs  (External  relation 
instruments), Social Integration, Interior (e.g. Horizon 2020) and Asylum-Migration offices. Furthermore, 
project  applicants  are  requested  to  report  on  other  sources  of  European  funding  they  benefit  from.  In 
Cyprus, meetings with the relevant competent authorities were conducted during the programming  stage 
for the examination of subjects of common interest and to avoid any overlap. In Greece, the responsible 
authority  carried  out  extensive  consultation  with  beneficiaries  involved  in  other  programmes  to  avoid 
duplication with other actions. Italy adopted an integrated approach to ensure coherence, relying on multi-
sectoral  (integrating  policies,  services,  and  initiatives  referring  to  different  yet  complementary  areas), 
multi-level (involving all relevant institutional actors), and multi-stakeholder (involving all relevant actors) 
mechanisms. Moreover, regular meetings between the RAs of AMIF and ISF-BV were organised to share 
information on activities implemented under the two funds.  

190   However, according to a representative of DG TAXUD, synergies among different EU policies and instruments concerned with 

borders might by increased. Interview with DG TAXUD. 

191   COMMISSION STAFF WORKING DOCUMENT Customs 2020 programme Progress Report for 2015. 
192   Interview with DG TAXUD. 
193   Conclusions of the ex post evaluation of the External Border Fund (EBF) 2007-2013; SEC(2011) 1358 final: COMMISSION 

STAFF WORKING PAPER IMPACT ASSESSMENT. 
194   Federal Ministry for Europe, Integration and Foreign Affairs. 

51 

 
 
 
 
 
                                                 
Examples of coordinating mechanisms to ensure the Fund’s coherence with other 
interventions during the implementation stage 

In  Bulgaria,  the  International  Projects  Directorate  within  the  Ministry  of  the  Interior  examines  project 
proposals and partnerships with EU financial institutions195. Its activity is part of the national strategy to 
ensure  the  coherence  and  coordination  with  ESIF.  ISF-BV’s  MC  meets  regularly  to  address  potential 
duplications; ISF-BV’s responsible authority meets monthly with beneficiaries of the ISF-BV projects to 
detect inter alia possible duplications with other projects. In Cyprus, since 2013, the Directorate-General 
for  European  Programmes,  Coordination  and  Development  is  responsible  for  implementing  the 
Europe2020 strategy and for coordinating the implementation of EU funds and programmes. In the Czech 
Republic, the Coordinating Committee 2014+ (KV)196 was established within the Ministry of the Interior 
as an internal mechanism dealing with ESIF, AMIF, and ISF. The KV consists of several working groups 
covering  all  projects  in  order  to  prevent  any  overlap.  In  Germany,  a  clear  separation  between  the 
objectives  and  approaches  of  AMIF  and  ISF  in  the  area  of  migration  was  achieved  by  indicating  the 
Federal Office for Migration and Refugees as being responsible for implementing AMIF and the Federal 
Police Headquarters for implementing ISF-BV. In Sweden, the SEFI Council (Council for the protection 
of  EU  financial  interests)  was  set  up  to  promote  the  efficient  and  accurate  use  of  EU-related  funds.  A 
meeting  ‘Ensuring  synergies  and  strengthening  capacities  for  addressing  migration  and  integration 
challenges  in  Sweden’  was  held  jointly  by  the  Swedish  authorities  and  the  European  Commission  on 
17 February 2017. 

5.5.2.  Complementarity 

In a nutshell 

The  Fund’s  objectives  are  complementary  to  other  national  policies.  Complementarity  with 
other  EU  financing  instruments  was  planned  at  the  programming  stage.  Coordinating 
mechanisms have been put in place to ensure complementarity at the implementation stage. 
Different implementation modes are complementary to each other. 

The evaluation raised evidence  on the complementarity between  the  objectives set in the national 
programmes and those set in national policies in the area of borders and visa197. No overlapping or 
duplication has been found. 

As for synergies, the security research under Horizon 2020 with its border component is the main 
source of synergies with the ISF-BV. Other EU interventions with potential for synergies with the 
ISF-BV include ESIF, under which training for border police is financed, the ERDF, Customs 2020 
and  Frontex  joint  operations.  It  should  be  noted  that  so  far,  more  emphasis  has  been  put  on 
minimising the risk of any potential overlaps rather than on synergies themselves. 

Some Member States198 carried out assessments of the national interventions with complementary 
objectives during the identification of the funding priorities and measures under ISF-BV. Different 
consultation,  coordination,  and  collaboration  mechanisms  were  put  in  place  to  ensure  alignment 
with actions set in the framework of other national policies199, including: 

195   The European Investment Fund, the European Investment Bank and the European Bank for Reconstruction and Development. 
196   The members of the KV are the deputies of the Minister of the Interior, the police president and the director of the fire rescue 

service. 

197   Member States: CH, CZ, EE, EL, ES, LT, LU, PL and SE. 
198   Member States: AT, BG, CZ, DE, EE, ES, FI, FR, HU and PL. 
199   Member States: BE, DE, ES, FR, HU and SI. 

52 

 
 
 
 
 
 
 
 
                                                 
 
 

financial instruments and mechanisms to ensure traceability and control of funding throughout 
the entire project lifetime; 

  consultation mechanisms with key stakeholders; and 
  application  and  project  selection  procedures  that  require  the  project’s  coherence  and 

complementarity to be demonstrated. 

The  responsible  authority  and  the  MC  also  played  a  key  role  in  ensuring  the  Fund’s 
complementarity with national strategies in the field of visa and borders200. 

In  Member  States  where  no  assessment  was  carried  out  at  the  programming  stage,  the 
complementarity  was  ensured  through  management  practices  during  the  Fund’s  implementation. 
More precisely, the wide stakeholder consultation during the programming stage allowed for high 
consistency of priorities and projects, therefore ensuring there were no overlaps with other relevant 
interventions201. 

The  interim  evaluation  highlighted  evidence  on  the  complementarity  among  the  Fund’s  different 
implementation mechanisms (shared, direct and indirect). Many Member States deem the different 
implementation modes as having directly contributed to meeting ISF-BV objectives, ensuring that 
all needs that are not covered by shared management instruments can be covered through direct or 
indirect  management  instruments202.  Moreover,  no  overlapping  or  duplication  was  found  between 
them,  since  they  actually  covered  different  types  of  actions203.  Specifically,  direct  and  indirect 
management were generally intended to be designed and implemented to improve and complement 
interventions  planned  under  national  programmes,  or  to  fund  interventions  that  cannot  be 
implemented  under  shared  management  for  several  reasons  (i.e.  allocation  limits,  difficulties  in 
reviewing  national  programmes).  In  particular,  EMAS  enabled  the  support  of  actions,  which  are 
difficult to be implemented under national programmes (due to allocation limits), since they address 
emerging  and  unpredictable  needs  arising  from  emergency  situations.  In  addition,  EMAS  has 
played  a  significant  role  in  bridging  the  funding  gap  until  the  national  programmes  have  been 
adopted. EMAS has also improved private-public synergies204. UAs allowed the Member States to 
plan  and  implement  cross-country  projects,  otherwise  not  affordable  under  the  national 
programme205.  Moreover,  indirect  management  projects  allowed  the  EU  to  entrust  budget 
implementation  tasks  to  partner  countries  or  the  bodies  they  have  designated  or  international 
organisations  provided  with  the  necessary  expertise  and  knowledge  to  properly  manage  and 
implement the measures required. 

Examples of national assessments of other interventions during the programming stage 

In  Cyprus  the  complementarity  issue  of  the  objectives  and  actions  was  taken  into  consideration  by  the 
responsible authority in the programming phase. Furthermore, the country’s DG EPCD206 launched the EU 
Funds  Web  Portal  in  2014  serving  as  an  information  hub  for  the  public  and  businesses  for  all  the  cross-
cutting  EU  programmes  to  enable  further  coordination  among  the  funds.  In  the  Czech  Republic,  the 
‘National Schengen Plan 2014’ (NSP 2014) setting up the national strategy for visa policy was taken into 
account in the preparation of the national programme, thus ensuring mutual complementarity.  
In Switzerland, the national IBM strategy was taken into account while the the National Programme was 

200   Member States: AT, DE, EE, FI, HR, LT, LV, NL, PL, SI and SK. 
201   Member States: BE, CH, DE, EL, HR, IT, LU, MT, PT and SI. Interviews with BE, BG, NO and PT RAs. 
202   Eighth Meeting of the Evaluation Network: BE, BG, EL, HR, FR, HU, MT, NL and NO. 
203   Interviews with the Commission officials, BG Chief Directorate Police, IT Navy and CIES Onlus (beneficiary of Italian 

EMAS), EL delegated authority. 

204   Ibidem. 
205  Interview with the Commission officials. 
206   Directorate-General for European Programmes, Coordination and Development. 

53 

 
 
 
 
 
 
 
                                                 
being  prepared  and  was  used  in  particular  to  prioritise  the  measures  planned  under  the  ISF-BV.  This 
ensured  that  the  objectives  of  the  envisaged  measures  were  in  line  with  and  complementary  to  the 
objectives of the existing actions of Swiss IBM.  

Examples of coordinating mechanisms to ensure the Fund’s complementarity with national 
interventions 

In Austria a separate unit within the EU department of the Ministry of the Interior (BM.I) was responsible 
for  coordinating  all  EU  funding  instruments  at  the  BM.I  including  the  avoidance  of  potential  double-
funding. Furthermore, the templates for project proposals and monitoring and reporting included questions 
specifically aimed at preventing double-funding. In Bulgaria and Finland the ISF Monitoring Committee 
was indicated as responsible for ensuring the coordination between the relevant EU and national financing 
instruments. During the regular meetings, representatives from the relevant authorities could discuss ISF-
BV  projects  detecting  any  possible  synergies  and  complementarities  with  projects  financed  through 
national  resources.  In  Hungary  the  Ministry  of  Interior  (MoI)  plays  a  significant  role  in  preventing  any 
overlapping and double financing with the national budget. The MoI also leads the Border Control Inter-
ministerial Working Group which should ensure the harmonisation of all the developments at the borders 
which are co-financed by the EU or national funds; In  Iceland and Slovakia the responsible authority is 
responsible for ensuring complementarity between co-financing from ISF-BV and other sources of funding 
at national and international level to foster synergies with national investments. In  Italy a monitoring and 
evaluation information system (containing the data of ISF and national operational programmes) was used 
to  detect  possible  duplication  of  projects  from  different  financial  instruments  and  to  generate  alerts 
automatically. 

5.6  What is the EU added value of ISF-BV so far? 

This question aims to assess the value that results from ISF-BV that is additional to the value that 
could  result  from  interventions  which  would  have  been  achieved  by  Member  States  at  national 
level. 

In a nutshell 

The  Fund  ensured  EU  added  value  through  innovative  investments  in  infrastructure  and 
equipment. It supported cooperation between Member States. Training activities enabled by the 
Fund contributed to  harmonising practices between  Member States. A higher EU added  value 
could have been expected in areas of consular cooperation, cooperation with third countries and 
IT systems. 

Shared management 

The interim evaluation collected evidence on the added value of the projects supported by the Fund. 
Stakeholders207 agree that the Fund has strongly contributed to ensuring a high level of security in 
the  EU,  supporting  the  adoption  of  a  harmonised  approach  to  visa  processing  as  well  as  the 
establishment  of  IBM.  The  Fund  acts  as  a  catalyst,  enabling,  supporting,  and  stimulating 
innovations that are taken up at national level, in terms of infrastructure, equipment and systems, 

207   Interviews with Member States RAs (BE, BG, EL, FR, NL, NO, PL and SI). Information was also gathered through 

questionnaires on the funding priorities in the Commission policy areas for the MFF post-2020 circulated by the Commission to 
the responsible authority for preparing the AMIF and ISF Committee on 13 March 2017. 

54 

 
 
 
 
 
 
 
 
 
                                                 
 
 
new  operational  techniques,  and  working  methods208.  In  this  respect,  the  actions  considered  as 
bringing higher EU added value are the ones supporting the national capacity, both in the areas of 
visa and borders209. 

The uniform deployment of up-to-date IT systems by all Member States appears to be key to fully 
achieving a common visa policy and IBM. Since large-scale IT systems need huge investments, it is 
likely  that,  without  an  EU  intervention,  national  IT  systems  would  have  continued  to  be  diverse, 
thus affecting the EU’s capacity to achieve the overall objectives in the border and visa policy field. 
In this view, the Fund added value to national efforts by allocating some resources specifically for 
this  purpose  and  by  pushing  all  Member  States  in  implementing  similar  systems  in  line  with  EU 
standards, thus easing the exchange of information and increasing the EU’s security levels. In the 
field  of  visa,  the  use  of  new  technologies  added  value  in  terms  of  efficiency  in  processing  visas, 
improving the exchange of data and information within and between Member States210. In the field 
of  borders,  the  EU  added  value  resulted  in  interoperable  modern  technologies  being  developed, 
which  improved  the  efficiency  and  speed  of  the  Schengen  Information  System  and  Visa 
Information System. This promoted interconnection with the Schengen partners, which contributed 
to  strengthening  border  checks  and  monitoring211.  Actions  related  to  IT  systems  were  usually 
complemented  by  actions  funded  by  the  operating  support212,  which  focused  on  the  upgrading, 
developing  and  maintaining  ITC  equipment  used  to  support  both  visa  issuing  and  border 
management213. 

Moreover, the Fund contributed to improved cooperation among the different actors involved at 
different  levels  (EU,  national,  projects  level),  therefore  enabling  the  strengthening  of  Member 
States  capacities  and  users  awareness  as  well  as  the improvement  of  the  quality  of  services214.  In 
light of this, stakeholders found that consular cooperation brings EU added value215, by: 

  setting up and developing common application centres; 
  purchasing  equipment  for  consular  offices  including  hardware  equipment  for  the 
functioning  of  national  Visa  Information  System  and  its  connection  to  central  Visa 
Information System; 
repairing/refurbishing consular offices; 

 
  deploying consular officers; and 
 

implementing technological infrastructure. 

The  Fund  has  also  strengthened  information  sharing  and  collaboration  mechanisms.  It  has  also 
enabled synergies on security issues between Member States216. 

According  to  some  Member  States217,  EU  added  value  was  related  to  the  Fund’s  capacity  to 
strengthen  solidarity  and  responsibility,  by  boosting  cooperation  under  EUROSUR  and  with 
Frontex. 

208   responsible authority responding to the questionnaires for the MFF post-2020: BE, BG, FR, IT, NL and PL; Interview with 

CIES Onlus (Italian EMAS beneficiary). 45% of replies to the online survey. 

209   responsible authority responding to the questionnaires for the MFF post-2020: AT, CH, CY, EE, ES, FI, HU, IT, LU, PL, SE, SI 

and SK. 

210   20 Member States (AT, BE, BG, CY, CZ, DE, DK, EE, FI, FR, EL, HU, IT, LV, LT, PT, RO, SE, SI and SK). 5 interviews: 4 

RAs (EL, NO, BE and FR) and one delegated authority (EL). OPC: 3 Public Authorities (BG, EL and IT). 

211   6 Member States (AT, CZ, DE, EE, FR and LV). Interview with FR responsible authority. 
212   ES and SI. 
213   RAs that responded to the questionnaires for the MFF post-2020: CH, ES, FI, IT and SI. 
214   Member States: BE, DE, EE, EL, ES, HR, HU, LU, LV, NL, PL and PT. 45% of replies to the online survey. 
215   responsible authority responding to the questionnaires for the MFF post-2020: HU, LT, RO and SK. 
216   Member States: BE, CY, DE, EL, ES, FI, HR, LU, LV, NL, PL, RO and SK. 
217   4 Member States (AT, BE, CZ and PL). 

55 

 
 
 
 
 
 
                                                 
From a financial perspective, the Fund enabled projects with a high volume of investments to be 
implemented that would have not been possible under national budgets. Without the support of ISF-
BV  (i)  the  scope  of  actions  would  have  not  been  the  same,  (ii)  the  quality  could  have  been 
compromised  given  the  high  standards  required  for  EU-funded  projects,  and  (iii)  there  could 
potentially have been implementation delays and the loss of knowledgeable staff218. 

What  is  more,  training  activities  brought  EU  added  value  since  it  enabled  practices  to  be 
harmonised across the Member States. Concerning the field of visa, the training of personnel was 
aimed  at  supporting  the  implementation  of  the  common  visa  policy  and  the  correct  and  uniform 
application of the Schengen acquis219. Concerning the management of external borders, the training 
aimed to facilitate the sharing of information and best practices for border control to improve the 
effectiveness of the border checks220. 

To conclude, it is worth mentioning some areas where a higher EU added value might be expected 
in light of the Fund’s objectives and related EU commitment. In particular, consular cooperation 
represents the second national objective in terms of EU commitment (10 %, with a total amount of 
EUR 14.8 million). However, Member States included few consular cooperation activities in their 
national programmes, showing a low interest towards this objective. Similar considerations apply to 
Member States cooperation with third countries, as only a few Member States221 implemented 
actions  pursuing  this  objective  and  most  stakeholders  considered  the  Fund’s  contribution  quite 
limited. Finally, despite the results achieved in terms of setting up and running  IT systems, some 
Member  States222  reported  that  better  results  would  be  achieved  if  the  EU  financing  was  higher. 
Additional  EU  resources  would  have  ensured  better  IT  systems  development  as  well  as  systems 
interoperability. 

Direct management 

The analysis of data showed that, without the resources provided by the Fund under EMAS, the use 
of  national  funding  only  would  have  resulted  in  a  more  difficult  and  smaller  scale 
implementation of actions with a lower impact overall. EU added value of EMAS can be seen in 
innovative  solutions  proposed223,  and  the  effective,  timely,  and  efficient  handling  of  migration 
flows,  the  crisis,  and  emerging  needs.  The  EMAS  measures  have  contributed  to  (i) a  closer 
cooperation  and  collaboration  across  Member  States,  (ii)  improved  coordination  of  relevant 
stakeholders at local and national level and (iii) improved synergies between public institutions and 
the private sector. 

As  for  the  few  action  grants  awarded  under  UAs,  their  implementation  is  at  a  very  early  stage. 
Therefore no conclusions can be drawn for the interim evaluation. 

Indirect management 

The Fund allocated some resources to specific bodies and institutions which allowed them to extend 
the  scope  of  their  activities  by  complementing  Commission  and  national  actions  requiring  a  high 

218   Member States: AT, BE, BG, CY, CZ, DE, EE, EL, ES, FI, FR, HR, HU, IT, LT, LU, LV, MT, NL, PL, PT, RO, SI and SK. 
219   responsible authority responding to the questionnaires for the MFF post-2020: AT, CY, EE, HU, LT, SI and SK. 
220   responsible authority responding to the questionnaires for the MFF post-2020: CY, LT and SK. 
221   4 Member States (AT, ES, IS and LT) declared to have implemented projects, without providing any detail/further information. 
222   Ref. Ares(2017)2412067, ‘High-level expert group on information systems and interoperability - Final report’ (May 2017. 13 

Member States (AT, CH, CY, ES, FI, HU, IT, LT, LU, PL, RO, SE and SK). 

223   As also supported by the online survey: 71% (n=22) of respondents chose the options ‘3 – moderate extent’ and ‘4 – high 
extent’ to the survey question ‘To what extent do you think that Union Actions allowed for innovative solutions?’. 

56 

 
 
 
 
 
 
 
 
 
 
                                                 
level  of  expertise  and  knowledge.  This  mechanism  provided  EU  added  value  by  strengthening 
existing  synergies  between  stakeholders  at  different  levels  (international,  EU,  Member  States), 
therefore developing a coherent EU response to emerging challenges. 

Three actions have been implemented under indirect management so far. The Commission entrusted 
eu-LISA to carry out the ‘Smart Borders Pilot’ testing phase, in the context of a ‘Proof of Concept’ 
exercise, as regards the Smart Borders Package adopted by the Commission on 28 February 2013. 
Overall, over a period of 7 months, eu-LISA successfully carried out 78 testing activities for both 
automated  and  manual  border  controls,  covering  different  environments,  and  finally  provided  a 
significant  evidence  base  to  assert  the  feasibility  of  systems  and  processes  proposed  for  Smart 
Borders. The Fund allowed eu-LISA to improve the relationship with several subjects: (i) Member 
States,  by  coordinating  and  supervising  their  activities;  (ii)  the  Commission  and  the  European 
Parliament,  through continuous  communication and  reporting  activities; (iii)  other  EU  institutions 
and  agencies  (i.e.  European  Data  Protection  Supervisor,  the  Fundamental  Rights  Agency  and 
Frontex), involved in both the preparation and execution phases. 

The  Commission  entrusted  the  ICMPD  to  implement  the  action  ‘Mobility  Partnership  Facility’ 
(MPF).  The  MPF  contributed  to  operationalising  the  EU  GAMM  and  improving  the  EU’s 
discussion and cooperation with partner countries, in the area of migration and mobility, providing 
them  with  targeted,  flexible  and  tailor-made  assistance.  Preliminary  results  showed  that  the  MPF 
allowed Member States and partner countries to implement their priorities according to: (i) flexible 
deadlines;  (ii)  simple  procedures  (i.e.  user-friendly  grant  agreements,  15-day  long  evaluation 
process); and (iii) a significant co-financing rate, up to 95 %. The MPF contributed to strengthening 
partner  countries’  capacities,  improving  the  levels  of  information  and  knowledge  to  critically 
review ongoing activities and policy processes. 

Furthermore,  the  Commission  entrusted  the  UNHCR  to  implement  the  action  ‘Support  to  Greece 
for  the  development  of  the  hotspot/relocation  scheme  as  well  as  for  developing  asylum  reception 
capacity’. This action helped to create 20 000 reception places and supported relocation processes, 
easing  the  deployment  of  UNHCR  expertise and  technical  staff.  UNHCR  staff  also supported  the 
Greek  Ministry  of  Interior  in  managing  and  coordinating  the  sites  as  well  as  the  Reception  and 
Identification Service. The action improved the capacities of several national stakeholders involved 
in  implementing  referred  processes,  as  well  as  the  cooperation  and  coordination  mechanisms 
between them. 

5.7  How sustainable are the actions implemented under ISF-BV so far? 

Evidence collected suggests that the project outputs are able to continue after the EU support is over 
both for shared, direct and indirect management. 

In a nutshell 

The sustainability of actions funded by ISF-BV relies on the continuity of EU funding with the 
national  funding.  This  appears  to  be  insufficient  to  ensure  the  same  level  of  investments. 
Training  activities  play  an  important  role  in  ensuring  the  sustainability  of  actions  in  the  long 
term.  

Shared & direct management 

57 

 
 
 
 
 
 
 
 
 
 
 
The  EBF  ex  post  evaluation224  concluded  that  overall  the  actions  in  the  2011-2013  period  were 
sustainable, as most of the assets acquired and knowledge generated were still being used while the 
evaluation was conducted (2016). The evaluation recommended that the following components be 
introduced in order to further improve sustainability of actions: 

  sustainability indicators to be part of the approval process at project and annual programme 

level; 

  compulsory  ex  ante  assessments  of  investments  requiring  significant  maintenance  and 
operating  costs  with  commitment  from  beneficiaries  to  secure  the  estimated  post-
acquisition costs; and 

  procurement  process  to  include  provisions  on  the  length  of  warranty,  maintenance,  and 

training if appropriate. 

The  ISF-BV  embraced  some  of  the  recommendations  from  the  EBF  ex  post  evaluation. 
Sustainability indicators were not included among the common indicators provided by Regulation 
(EU) No 515/2014 and 22225 out of 30 Member States226 did not include any specific reference to 
sustainability  in  the  national  programmes.  Common  indicators  were  eventually  introduced  by 
Commission  Delegated  Regulation  (EU)  2017/207227.  Only  five  Member  States  committed  to  the 
sustainability  of  the  implemented  projects228.  There  is  no  evidence  of  specific  provisions  or 
mandatory  requirements  either  for  the  ex  ante  assessment  of  investment  or  for  the  length  of 
warranty, maintenance, and training. 

However,  beyond  the  issues  related  to  the  EBF  ex  post  evaluation’s  conclusion,  the  interim 
evaluation of ISF-BV highlighted evidence of the sustainability of the Fund’s results. 22 out of 30 
Member States stated that the ISF-BV actions are long-term actions by their nature, since they are 
generally designed and structured to remain operational after the Fund’s support ends. In particular, 
investments in infrastructure, facilities, and IT systems have relatively high sustainability, as they 
usually require smaller maintenance costs compared to the initial investments. Even if not explicitly 
referring  to  sustainability,  the  Fund  —  particularly  operating  support  resources  —  was  used  for 
maintaining the equipment purchased, aiming to ensure the proper functioning of infrastructure and 
to give continuity to the activities229. The sustainability of actions is also ensured through training 
sessions,  information-sharing,  and  cooperation  mechanisms  that  helped  to  improve  expertise, 
knowledge,  and  the  qualifications  of  staff  involved  in  managing  and  implementing  projects230. 
Furthermore, the effects achieved through the Fund’s support are also expected to continue after the 
EU  funding,  relying  on  national  budgets  to  ensure  the  continuity  of  interventions  and  related 
impacts231. 

Examples of Member States reporting on project sustainability during the programming 
phase 

Estonia  planned  the  purchase  of  an  additional  central  station  and  of  the  infrastructure  supporting  it  to 
ensure  the  sustainability  of  the  operative  radio  communication  network,  making  border  control  more 

224   Optimity Advisors and CSD (2016). Ex post evaluation of the External Borders Fund 2011-2013. 
225   National programmes: AT, BE, BG, CH, CY, CZ, DE, DK, EE, EL, ES, FI, FR, HR, HU, IT, LT, LU, LV, MT, NL, PL, PT, 

RO, SE, SI and SK. 

226   National programmes are not available for IS, LI and NO. 
227   Example of sustainability indicator: number of equipment in use 2 years after their acquisition/number of equipment acquired 

under the Fund (> than EUR 10 000). 

228   National programmes: EE, LT, LV, MT and SK. 
229   National programmes: all countries except Switzerland and the Netherlands. Interviews: 5 RAs (BE, BG, CH, LT and PL). 
230   Member States: BE, CY, CZ, DE, EE, EL, ES, FI, FR, HR, HU, IT, LU, MT and RO. Interviews: 3 RAs (BE, El and LT) and I 

delegated authority (EL). 1 beneficiary responding to the online survey. 

231   Member States: BE, CY, CZ, DE, EE, EL, ES, FI, FR, HR, HU, IT, LU, MT and RO. 

58 

 
 
 
 
 
 
                                                 
effective.  Moreover,  attention  is  devoted  to  sustaining  the  activities  involving  the  Immigration  Liaison 
Officers  (ILOs)  in  order  to  maintain  the  established  connections  in  third  countries  (e.g.  in  Ukraine); 
Lithuania  expressed  its  commitment  to  maintaining  the  border  surveillance  systems  through  national 
resources. It aims to ensure the disaster recovery and business continuity plan is implemented232, as well as 
the  back-up  components  of  the  national  Schengen  Information  System  II;  Latvia  expected  to  have  a 
reliable,  modern  and  sustainable  national  entry/exit  system;  Malta  in  its  Manual  of  Procedures  for  the 
Asylum, Migration and Integration Fund and Internal Security Fund 2014-2020, sustainability of projects is 
directly mentioned in the subtitle ‘Sustainable Management of Internal Security and Migration Flows’233, 
making  it  a  compulsory  requirement  to  include  the  text  in  the  publications  concerning  AMIF/ISF.  In 
Slovakia authorities involved in the ISF-BV management have to regularly check the staff expertise so as 
to  be  prepared  in  case  of  changes  in  the  operational  environment.  There  is  often  the  need  for  specific 
training (including language trainings) to upgrade staff skills, ensuring the sustainability and continuity of 
the achieved high-level performance. 

Examples of measures to ensure sustainability 

Austria, Belgium and Cyprus, during the programming stage, included project beneficiaries in the public 
policy dialogue as well as in the negotiation process, with the aim of identifying potential investments, the 
impact  of  which  was  likely  to  produce  significant  results,  at  EU  and  national  levels,  beyond  the  Fund’s 
support234.  Bulgaria  sets  strict  sustainability  requirements  in  its  eligibility  rules  to  apply  for  projects. 
Beneficiaries have to guarantee that they will also maintain the projects through national funding after the 
ISF-BV  fund  is  finished.  Sustainability  requirements  depend  on  the  type  of  equipment  purchased:  IT 
systems should be used for at least 3 years whereas helicopters, vessels, and buildings should be in use for 
almost 10 years235. In Malta beneficiaries are obliged to sign a declaration that ensures that the investments 
will  be  operational  after  the  Fund’s  support  ends236.  In  Poland,  beneficiaries  have  to  demonstrate 
significant  long-term  sustainability,  declaring  the  annual  cost  for  the  project  maintenance  and  their 
commitment in assuring it. The sustainability of the projects is measured by the Delegated Authority after 
the project is completed237. Switzerland requires beneficiaries to use the infrastructure they purchase for at 
least 3 years238. 

As for shared management, the sustainability of investments under direct and indirect management 
is also ensured by other funding schemes. In particular, under direct  management it is ensured by 
referring  to  other  EU  Funds  (i.e.  AMIF),  national,  and  other  donor’s  resources  as  well  as  by  the 
exchange of good practices and know-how among actors and other Member States. Under indirect 
management,  the  sustainability  of  investments  is  ensured  by  the  commitment  of  resources  under 
Member States national budgets as well as the exchange of good practice and know-how. 

6. CONCLUSIONS AND ISSUES FOR FURTHER CONSIDERATION 

6.1  Effectiveness 

232   Measures that ensure the continuity of the project in case of unexpected events. 
233   Ministry for European Affairs and Implementation of the Electoral Manifesto (2015). Asylum, Migration and Integration Fund 

and Internal Security Fund 2014–2020: manual of procedures. 

234   Member States: AT, BE and CY. 
235   Interview with Bulgarian responsible authority. 
236   Member States: MT. 
237   Interview with PL responsible authority. 
238   Interview with CH responsible authority. 

59 

 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Concerning the common visa policy, the Fund is considered mainly effective. The Fund helped to 
facilitate  legitimate  travel,  boosting  Members  States’  capacities  to  verify  the  authenticity  of 
documents  used  for  visa  applications,  to  develop  information  system  for  coordinating  visa 
applications  and procuring security equipment for consular representations in third countries. The 
Fund’s  contribution  towards  consular  cooperation  was  limited  in  many  Member  States  due to  the 
delays  in  starting  the  implementation.  Training  courses  targeted  consular  officials,  police,  and 
border guard officials engaged in developing and implementing the common visa policy. The EU’s 
acquis on visa has been supported either through mixed projects that also pursue other objectives, or 
through projects specifically targeted to this objective. The development of a common visa policy 
was  also  supported  through  the  establishment  and  operation  of  IT  systems,  particularly  regarding 
the  national  Visa  Information  System.  The  operating  support  for  visa measures  also  proved  to  be 
extremely useful for covering those staff costs and other running costs related to implementing the 
EU’s  common  visa  policy.  Only  a  few  Member  States  have  used  the  Fund  to  strengthen  their 
cooperation  with  third  countries.  However,  the  Fund  allowed  some  Member  States  multiple 
postings  of  temporary  liaison  officers  and  visa  experts  to  consulates  in  the  third  countries  and 
therefore improved the detection of fraudulent documents. The existence of different national rules 
for implementing the Fund was a factor that hindered joint projects between Member States. 

As regards the area of integrated border management, the Fund is considered mainly effective in 
the context of the security and migration crisis. By boosting the border management capacity at the 
EU’s external borders, the Fund contributed to safeguarding the free movement of people within the 
Schengen  area.  The  Fund  contributed  towards  the  effectiveness  of  external  border  controls  by 
supporting measures focused  on purchasing, modernising, upgrading  and replacing border  control 
and surveillance equipment. Border management capacity was addressed through  the introduction 
of Automated Border Control (ABC) gates. Training activities co-financed by the Fund contributed 
to the implementation of the EU’s acquis that aims to improve staff awareness and competencies on 
border  management  and  on  using  related  IT  information  systems.  These  training  activities  also 
improved  the  linguistic  skills  of  the  staff  responsible  for  border  management.  The  cooperation 
facilitated by the Fund between Member States and between Member States and Frontex, including 
purchases  of  equipment  to  be  used  in  Frontex  operations  with  the  Fund’s  help,  contributed  to 
solidarity  and  responsibility  sharing.  The  Fund  played  also  a  significant  role  in  developing 
EUROSUR239  by  co-financing  activities  both  under  national  programmes  and  UAs  with  the 
objective of improving situational awareness and increasing the reaction capability at the external 
borders.  However,  limited  progress  was  registered  regarding  promoting  the  development, 
implementation and enforcement of policies with a view of ensuring the absence of any controls on 
persons,  whatever  their  nationality.  Currently,  the  Fund  is  not  supporting    Member  States  in  the 
application of the non-refoulement principle. 

Regarding direct management, it is very difficult to draw any conclusions on the effectiveness of 
the action grants awarded under UAs or EMAS since very few actions have been completed in the 
period  covered  by  the  interim  evaluation.  While  EMAS  measures  proved  to  be  an  efficient 
instrument  to  rapidly address  a  number  of  emergency  situations  arising  from  the  migration  crisis, 
action grants under UAs proved to less popular. Member States expressed limited interest in them 
with few proposals received to the calls published by the Commission. 

Issues for future consideration: 

  The  current  structure  of  the  Fund  divided  into  external  borders  and  visa  should  be 

maintained. 

239   Regulation (EU) No 1052/2013 of the European Parliament and of the Council of 22 October 2013 establishing the European 

Border Surveillance System (EUROSUR). 

60 

 
 
 
 
 
                                                 
  The  possibility  of  using  emergency  assistance  is  crucial  and  also  ensures  the  Fund’s 

responsiveness and relevance in changing circumstances. 

6.2  Efficiency 

The  implementation  of  the  national  programmes  started  very  slowly  creating  challenges  for 
evaluating the Fund’s cost-effectiveness because the majority of the projects are still ongoing. Low 
levels  of  human  resources  costs  were  associated  with  the  pace  of  implementation  of  the  national 
programmes  in  the  Member  States.  Overall,  human  resources  at  EU  and  national  level  show  a 
growing or stable number of FTEs over the years from 2014 to 2017, despite the large increase in 
value of the EMAS and the emergency situation on the ground following the migration crisis. 

Efficiency  was  ensured  by  means  of  considerable  knowledge  and  expertise  gained  through 
experience  from  previous  projects  and  the  flexibility  of  the  national  programmes.  Furthermore 
national measures concerning the application, implementation, monitoring and reporting processes 
have been put in place in some Member States to ensure efficiency. As for the anti-fraud measures, 
they are generally considered as appropriate and effective. 

There are also a number of issues at Member States level that Member States deem as negatively 
affecting efficiency and these are: (i) requirement to allocate minimum percentages among national 
objectives,  (ii)  complex  and  recurrent  reports,  (iii)  common  indicators  and  (iv)  alignment  of 
monitoring calendars. 

Overall, direct and indirect management actions were deemed reasonable in terms of financial and 
human resources. 

Issues for future consideration: 

  The  common  monitoring  and  evaluation  framework  with  relevant  indicators  should  be 
established  at  the  beginning  of  the  programming  period  addressing  for  example  reporting 
requirements. 

  The  framework  for  jointly  implemented  projects,  for  example,  in  the  area  of  common 
consular cooperation should be better refined, addressing, for example, eligibility rules. 

6.3  Simplification of management procedures and reduction of administrative 
burden 

Overall,  the  ISF-BV  ensured  clear  progress  was  made  towards  simplifying  procedures  especially 
regarding the programming phase. Stakeholders highlighted that multiannual programming enabled 
emerging needs to be addressed throughout the seven-year timeframe and large investments to be 
managed  in  the  long  term.  This  contributed  to  a  reduction  of  administrative  burden  raised  by  the 
annual implementation cycle. Administrative simplification also came from the introduction of the 
simplified cost options, and particularly the flat rate calculation used with indirect costs, as well as 
from the digitalisation of reporting and communication procedures. 

However,  the  administrative  burden  is  still  perceived  as  high,  as  regards  both  the  administrations 
responsible  for  managing  the  funds  and  beneficiaries.  The  Common  Monitoring  and  Evaluation 
Framework was established too late, well after the projects had started. Monitoring, reporting, and 
verification measures are still perceived as burdensome and Member States ask for clearer and more 
detailed  guidance  to  ease  compliance  with  Commission  requirements.  Further  guidance  is  also 

61 

 
 
 
 
 
 
 
 
 
 
 
needed to ensure a common definition of the simplified cost options that is perceived as positive but 
is still not clear to beneficiaries, making them reluctant to use it. 

As regards direct management, procedures showed to be suitable, clear, and transparent and do not 
create additional burden to Member States or beneficiaries. 

Issues for future consideration: 

  The  common  monitoring  and  evaluation  framework  with  relevant  indicators  should  be 
established  at  the  beginning  of  the  programming  period  simplifying  the  processes  and 
calendars. 

6.4  Relevance 

The priorities and  objectives set by Regulation (EU) 515/2014  as  well as  those within the annual 
work programme of both EMAS and Union actions have proven to still be relevant and aligned to 
current  needs  and  problems.  The  types  of  needs  identified  during  the  programming  stage  did  not 
change  significantly  during  the  Fund’s  implementation  and  no  new  need  or  priority  emerged  that 
was  not  properly  covered  by  the  Fund.  The  main  mechanisms  identified  to  ensure  the  Fund’s 
relevance  included  (i)  the  policy  dialogue  and  the  consultative  method  adopted  during  the 
programming  stage,  (ii)  the  monitoring  role  played  by  both  the  responsible  authority  and  by  the 
Monitoring  Committee,  (iii)  the  possibility  to  make  budgetary  adjustments  and  transfers,  and 
(iv) the mid-term review of the national programmes. 

The  interim  evaluation  also  shows  that  the  Fund’s  scope  is  sufficiently  broad  to  enable  the 
implementation  of  the  necessary  actions  in  the  areas  of  external  border  management  and  the 
common policy on visa. 

Despite the evidence gathered on the Fund’s relevance, it has been noted that more flexibility would 
be  needed  as  far  as  the  national  programmes’  implementation  is  concerned.  The  main  issue  was 
found  around  the  fragmentation  of  actions  under  multiple  national  objectives  that  prevented 
resources being pooled around key priorities making the implementation of cross-objective projects 
difficult. This has also led to an increased administrative burden as the Member States are required 
to  report  on  the  implementation  of  cross-objective  actions  for  each  national  objective  concerned 
with the action’s specific scope. 

Issues for future consideration: 

  The Fund’s scope, which allows flexibility, should be maintained. 
  The  fragmentation  of  national  programmes  under  several  objectives  with  minimum 

percentages of funding should be reconsidered in order to increase flexibility. 

6.5  Coherence and complementarity 

Most assessments of other EU interventions carried out by Member States have taken place at the 
programming  stage  in  order  to  ensure  coherence  and  complementarity  with  them.  Most  Member 
States have also adopted different coordinating mechanisms at the implementation stage to ensure 
coherence and complementarity with similar interventions carried out under other EU funds. These 
mechanisms  include  interinstitutional  exchange  of  information  and  cooperation  among  authorities 
responsible  for  different  EU  funds  and  specific  institutional  arrangements  to  boost  their 
coordination  and  synergies.  No  overlapping  has  been  found  between  the  ISF-BV  and  national 
interventions in the field of visa and borders. The design of the national programmes was based on a 
thorough policy dialogue between the Commission and the Member States, taking account of key 

62 

 
 
 
 
 
 
 
 
 
 
 
needs and priorities as reported at the national level. Also, it has been claimed that the Monitoring 
Committee  and  the  Responsible  Authority  play  a  pivotal  role  in  ensuring  synergies  and  avoiding 
overlaps between the ISF-BV and other EU instruments. They did this through regular cooperation 
with other national institutions implementing other funds (incl. EU funds) and with counterparts in 
other Member States to avoid any overlaps and double-funding. 

As  regards  direct  management,  both  EMAS  and  UAs  show  they  are  coherent  with  and 
complementary  to  actions  supported  by  other  EU  funds,  actions  supported  by  EU  Agencies,  and 
other  EMAS  actions  funded  under  the  ISF-BV.  No  issues  of  overlapping  between  the  ISF-BV’s 
direct management instruments and other relevant national interventions have been found.  EMAS 
actions  generally  improve  and  complete  interventions  planned  at  national  level  and  allow  for 
actions to be implemented on a larger scale. 

Issues for future consideration: 

  As  coherence  and  complementarity  were  ensured  at  the  programming  stage,  in  future 
coordination  should  be  intensified  during  implementation  in  order  to  ensure  even  better 
coherence and complementarity between different types of actions. 

  The  complementarity  of  emergency  assistance  with  respective  national  programmes  and 

other EU programmes should be ensured from the start. 

6.6  EU Added Value 

The  Fund’s  increased  cooperation  among  actors  dealing  with  visa  processing  and  border 
management across the EU, improving the sharing of information and practices and contributing to 
their harmonisation at the EU level. Furthermore, the Fund bolstered the interconnection of national 
IT and information systems, both among the Member States and with EU systems. Training proved 
to  be  a  relevant  mechanism  to  ensure  the  Fund’s  EU  added  value  since  it  supported  a  common 
understanding  of  visa  and  border  issues  and  related  management.  Operating  support  allowed  the 
Member  States  to  finance  daily  tasks  and  regular  operating  costs  (i.e.  staff,  maintenance,  repair 
costs) on both border and visa management. 

From a financial point of view, without a dedicated EU funding instrument in the areas covered by 
ISF-BV, national funding would not have allowed the effective and efficient funding of the actions 
planned. Actions would have been implemented with much more difficulty. They would not have 
been implemented on the scale nor in the timeframe planned due to insufficient national resources. 

A higher EU added value could have been expected in areas of consular cooperation, cooperation 
with  third  countries  and  IT  systems,  especially  in  light  of  the  Fund’s  objectives  and  related  EU 
commitment. 

As  regards  direct  management,  without  the  resources  provided  by  EMAS  and  UAs,  national 
funding on its own would have resulted in a much more difficult and smaller scale implementation, 
with  a  lower  general  impact.  The  Fund’s  main  advantages  entailed  by  these  measures  included 
higher  cooperation  both  across  and  within  Member  States,  including  the  sharing  of  information, 
know-how  and  good  practices  as  well  as  better  private-public  collaboration.  This  allowed  for  a 
prompt and efficient handling of migration flows and related emergencies. 

Actions  funded  under  indirect  management  consisted  of  allocating  some  resources  to  specific 
bodies  and  institutions,  which  allowed  them  to  extend  the  scope  of  their  activities  by 
complementing Commission and national actions requiring a high level of expertise and knowledge. 

63 

 
 
 
 
 
 
 
 
 
 
 
This  mechanism  provided  EU  added  value  by  strengthening  existing  synergies  between 
stakeholders  at  different  levels  (international,  EU,  Member  States)  and  therefore  developing  a 
coherent EU response to emerging challenges. 

Issues for future consideration: 

  Support  through  ISF-BV  and  all  its  instruments  should  be  continued  which  would  send  a 
clear  message  on  the  importance  of  solidarity  and  cooperation  between  Member  States  in 
order to manage the EU’s external borders effectively. 

6.7  Sustainability 

The majority of Member States did not report any evidence on the sustainability of projects. Some 
Member  States  reported  that  they  took  care  of  sustainability  in  the  programming  stage,  by 
requesting beneficiaries to demonstrate their commitment to maintaining the projects even after the 
ISF.  According  to  the  national  evaluation  reports,  only  five  Member  States  committed  to  the 
sustainability of the implemented actions. 

Many  ISF-BV  actions  are  long-term  actions  by  their  nature,  since  they  are  generally  designed  to 
remain  operational  beyond  the  Fund’s  support  (investments  in  infrastructure,  facilities,  and  IT 
systems).  ISF-BV-funded  training  sessions  and  cooperation  mechanisms  contributed  to  the 
sustainability  of  actions  through  improving  expertise,  knowledge,  and  the  qualifications  of  staff 
involved  in  managing  and  implementing  projects.  In  conclusion,  the  effects  achieved  through  the 
Fund’s support are also expected to continue after the Fund has finished, relying greatly on future 
EU funding and also national budgets to ensure the continuity of interventions and related impacts. 

Under  direct  and  indirect  management,  sustainability  of  actions  depends  on  complementary  EU, 
national or other donor funding. 

Issues for future consideration: 

  Sustainability,  in  terms  of  both  financial  sustainability  and  the  effects  of  sustainability, 

should be taken into account at the project design and selection stage. 

  Disseminating  information  and  supporting  the  uptake  of  good  practices  by  other  projects 

should further improve sustainability. 

64 

 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 1: PROCEDURAL INFORMATION 

Leading Directorate-General 
of 
Participating 
Commission 

units 

the 

Participating DGs in ISSG  

Legal base 

Roadmap approval 
Decide planning  
Exceptions to the Better Regulation 
guidelines 
consulting 
External 
specialised in evaluation 

firm 

Number  of  inter-service  steering 
group meetings 
Last deliverable handed in 
Approval  of  the  final  report  by 
Steering Group 
Regulatory  Scrutiny  Board  (RSB) 
meeting  
Resubmission  of  the  SWD  to  the 
RSB 

the Commission 
A2 — Legal Affairs 
B2 — Visa Policy and document security 
B3 — Information Systems for Borders and Security 
C2 — Border Management and Schengen 
E1 — Union Actions 
E2  —  National  programmes  for  south  and  east  Europe, 
evaluation, AMF/ISF Committee 
E3  —  National  programmes  for  north  and  west  Europe, 
budget, MFF, agencies 
Secretariat-General 
DG BUDG 
DG JUST 
DG TAXUD 
According  to  Art.  57  of  Regulation  (EU)  No 514/2014,  the 
Commission shall submit to the European Parliament, to the 
Council,  to  the  European  Economic  and  Social  Committee 
and  to  the  Committee  of  the  Regions  an  interim  evaluation 
report of ISF-BV at the level of the Union by 30 June 2018. 
11 April 2017 
PLAN/2017/891 
None noted  

Contract signed on 19 September 2017 with a consortium of: 
  Ernst & Young Special Business Services (lead partner), 

BE; 

  Centre for International Legal Cooperation, NL; 
  Rand Europa Community Interest Company, UK.  
4 meetings as (last on: 8 March 2018) 

12 March 2018 (Final report for acceptance) 

11 April 2018  

65 

 
 
 
 
 
 
 
 
 
 
ANNEX 2: STAKEHOLDER CONSULTATION 

ISF-BV  had  a  consultation  strategy  whose  objective  was  to  gather  input  from  stakeholders 
(evidence, data, as well as views and opinions) and ensure that all of them have the opportunity to 
present their views to the Commission on how well the existing programmes have performed and 
the extent to which they met the EU’s objectives in these areas. Stakeholders’ input was sought to 
provide  the  Commission  with  valuable  insights  on  how  well  the  current  funds  are  performing, 
including on the challenges related to the implementation. 

The  Commission  services  have  worked  on  the  future  multiannual  financial  framework  in  clusters 
setting up a streamlined consultation that covered both forward and backward looking questions on 
the programmes. This open consultation, as provided for in the Better Regulation guidelines and the 
interim evaluation’s consultation strategy, was meant for the general public and was published for 8 
weeks  on  the  Commission’s  portal240.  350  answers  and  52  position  papers  have  been  received  in 
this  context.  No  separate,  specific  open  consultation  for  the  mid-term  evaluation  was  carried  out. 
Launching  a  specific  consultation  for  the  mid-term  evaluations  could  have  created  confusion  and 
not provided much added value compared to the broader exercise.  

Instead,  a  targeted  consultation  specific  for  the  mid-term  evaluation  was  carried-out,  which 
eventually  was  used  to  contextualise  the  findings.  The  questionnaires  were  aimed  at  the 
beneficiaries of Union actions and EMAS and were made available in English, French and German. 
This consultation only received input from 4 participants. 

The results of this targeted consultation are reproduced below: 

  Of the 4 answers received, half (2) were from individuals answering in their professional capacity and 
half (2) from respondents answering on behalf of their organisations. All 4 of these were from national 
public authorities and have declared knowing very well ISF-BV because they have benefitted from its 
funding. 

  The first part of the consultation concerned the importance of the specific objectives of ISF-BV for the 
policy  priorities  in  the  Member  States  (absence  of  controls  at  internal  borders,  checks  at  external 
borders,  integrated  management  system  for  the  external  borders,  better  consular  cooperation  on  visa 
issuance,  IT  systems,  situational  awareness,  Union  aquis,  copperation  of  Member  States  in  third 
countries and with third countries). The answers received are overwhelmingly consider very important 
the ISF-BV objectives. 

  The second part of the consultation concerned the extent at which the actions financed by ISF-BV in the 
Member  States  contribute  to  the  Fund's  objectives  (absence  of  controls  at  internal  borders,  checks  at 
external borders, integrated management system for the external borders, better consular cooperation on 
visa  issuance,  IT  systems,  situational  awareness,  Union  aquis,  copperation  of  Member  States  in  third 
countries and with third countries). The vast majority of answers consider that ISF-BV funded projects 
do  contribute  to  the  development  of  the  Fund's  objectives  (either  to  a  great  extent  or  fully).  Only  one 
participant did not know how to answer in the following cases: absence of controls at internal borders, 
IT  systems,  copperation  of  Member  States  in  third  countries  and  with  third  countries.  Half  of  the 
participants  (2)  did  not  know  how  to  answer  to  the  question  regarding  better  consular  cooperation  on 
visa issuance. 

  All respondents consider ISF-BV being able to address new and emerging needs and having a positive 

influence on how Member States work with border management and Schengen visa processing. 

  Regarding the cooperation among Member States, respondents consider that ISF-BV's contribution was 

positive in the area of borde management (4), and Schengen visa processing (2). 

  Regarding  whether  the  EU  policies  would  have  been  implemented  without  the  support  of  ISF-BV, 

240   http://ec.europa.eu/info/consultations_en 

66 

 
 
 
                                                 
respondents are divided with half (2) considering it mostly likely in the area of border management and 
half (2) unlikely, while the majority (3) considered likely in the area of Schengen visa processing. 

  Looking at ISF-BV so far, respondents did not know whether the Fund promotes new actions that were 
not  delivered  in  the  Member  States  before  in  the  area  of  borde  management  (2)  and  Schengen  visa 
processing (4 out of 4). 

  All  respondents  think  that  ISF-BV  funded  projects  help  beneficiaries  to  better  support  border 
management, better protect external borders, better ensure the smooth crossing of borders, better tackle 
illegal immigration and better facilitate the travel of third-country nationals. 

  Respondents were divided in who considered ISF-BV generally easier or much easier (3) to implement 

compared to the previous programming period (SOLID) and who found it generally harder (1). 

  In what concerns the degree at which actions financed by ISF-BV are coherent with actions and projects 
funded by national resources, all respondents were positive (4) in  the field of border management and 
half of them were positive in the field of Schengen visa processing (2) with the other halh not being able 
to answer. 

  Regarding  sustainability,  respondents  were  divided  into  those  who  believe  actions  would  continue  at 
least partially also in the absence of the EU financial support (2) and those who did not know whether 
this would have happened (2). The same proportion was then reproduced regarding the achievement of 
the  objectives  in  the  absence  of  ISF-BV  –  2  who  consider  that  these  could  have  been  achieved  and  2 
who believe it would have not been possible. 

  This targeted consultation has complemented the interviews and an online consultation run in 
parallel by the consultant, and the table below provides an overview of the response rate to this 
latter.  The  results  of  all  those  consultations  have  been  used  to  answer  and  contextualise  the 
answers to the evaluation questions. 

   

This  targeted  consultation  has  complemented  the  interviews  and  an  online  consultation  run  in 
parallel  by  the  consultant,  and  the  table  below  provides  an  overview  of  the  response  rate  to  this 
latter. The results of all those consultations have been used to answer and contextualise the answers 
to the evaluation questions. 

Table 8: Overview of consultant's online survey respondents 

N. Sent 

Discarded  

N. Completed 

Monitoring Committees 

167 

16 

Ministry of Foreign Affairs 

responsible authority and delegated authority 

audit authority 

EMAS beneficiaries/coordinator 

UAs beneficiaries/coordinators 

Multiannual programme beneficiaries 

Experts 

Total 

12 

21 

32 

42 

3 

110 

9 

396 

Source: ISF-BV Interim evaluation by EY 

0 

5 

4 

1 

0 

2 

5 

33 

26 

1 

4 

2 

4 

0 

17 

1 

55 

In  addition  to  this,  the  evaluation  reflected  the  results  of  a  forward-looking  workshop  with 
representatives of responsible authorities and the Member States evaluators. Its results are presented 
below: 

Participants: two representatives of the COM, three representatives of EY (EY, service provider 

67 

 
 
 
 
 
 
for  the  Interim  Evaluation  of  the  ISF-BV  2014-2017),  representatives  of  nine  Member  States 
and two Schengen Associated Countries. 
Date: 30th November 2017. 

Contribution  of  the  ISF-BV  to  the  harmonisation  of  visa  processing/issuing  and  to  the 
effective implementation of an integrated border management 
Visa processing 

  The  Fund  contributes  to  the  establishment  of  an  information-based  decision-making,  to  the 
development  of  instruments  (an  APP,  in  particular)  that  provide  relevant  information,  and 
enable sharing information with other MS. Visa application procedures have been externalised 
to a specific Agency, managed under the national budget.  

  The  Fund  contributes  to  the  delivery  of  training  in  foreign  missions.  Ministries  of  Foreign 
Affairs have outsourced visa issuance service. The impact of training is hardly quantifiable, and 
the  available  indicators  are  not  fitting  for  purpose.  In  general,  however,  trainings  have  been 
positively evaluated and staff’s skills have upgraded.  

  Some MS have not implemented any projects under this objective, but they are still interested in 
putting in place some actions. They regret the limited capacity of beneficiaries to draft projects.  
  The  main  contribution  of  the  Fund  is  the  operating  support,  above  all  for  the  maintenance  of 
VIS.  Despite  the clear contribution of  the  Fund,  there  are  issues  concerning  national  capacity 
that affect the Fund’s success. Embassies struggle to: i) design and manage projects under the 
National Programme (above all on security issues); ii) manage EU funding - since they do not 
have the skills to manage the financial implementation.  

  The main contribution of the Fund is the possibility to finance IT projects (VIS) and projects 
concerning  the  deployment  of  visa  experts  for  regional  training  in  third  countries.  These  are 
important to implement Union’s standards and to keep the staff up-to-date. The visa application 
service  has  been  externalised.  A  project  for  the  development  of  consulates  not  approved  yet, 
was considered too risky in terms of sustainability, due to constant changes. 

  Projects  concerning:  i)  training  on  visa  application  for  consular  officials,  visa  specialists, 
internal staff and for third countries representatives (located in third countries); ii) IT projects 
for  visa  management  (i.e.  purchase  of  fingerprint  scanners,  renewal  of  computers  to  process 
Schengen Visas). 

  Projects  with  different  scope  (i.e  training,  deployment  of  DVO).  However,  some  externalities 

are causing delays. 

Implementation of integrated border management 

  Projects concerning the establishment of ABC gates and the deployment of ILOs, considering 

both relevant eligible actions. 

  Projects concerning the deployment of ILOs, the purchase of equipment, and the development 

of smart borders. ISF-BV also supports cooperation measures with third countries. 

  Since  MS  are  required  to  comply  with  EU  standard  in  the  area  of  border  management,  the 
contribution of the Fund has been mainly in the development of IT systems (i.e. SIS, ETIAS) - 
for  better  collecting  and  using  relevant  information  on  border  checks  -  smart  borders 
mechanism and training, in compliance with EU standards. 

Experience  with  Specific  Actions  on  consular  cooperation  and  the  purchase  of  means  of 
transport  and  operating  equipment  for  the  deployment  during  joint  operations  by  the  Frontex 
Agency. 

  Specific  Actions  on  consular  cooperation,  both  as  project  lead  and  as  participant,  not  able  to 
assess the current added-value of such actions. Despite the large sums of money provided, there 
are issues of administrative burdens raising from national laws and regulations.  

  Issue of lack of additional funding for the management of specific actions. 

68 

 
 
 
 
 
  Specific  Actions  for  the  development  of  Schengen  Houses  and  CCM.  Difficult  to  be 

implemented, due to externalities and challenges related to the multinational management. 

  All countries agree on the fact that: i) multinational projects are difficult to be managed due to 
different  national  eligibility  and  implementation  rules.  Suggestion  that  COM  establishes 
standard  eligibility  and  expenditure  rules;  ii)  additional  funding  should  be  provided  for  the 
management of Specific Actions; iii) Specific Actions for FRONTEX equipment are easier to 
be managed since they consist in procurement and purchase. 

Key advantages and issues of the ISF-BV as compared to the previous fund. 

  There  has  been  huge  improvement  compared  to  the  EBF.  Multiannual  programming  allows 
more flexibility. However, the Fund should probably focus on fewer objectives with a broader 
scope, without limiting the resources to narrowly defined objectives.  

  National objectives should be more focused.   
  Operating support is very useful in the area of borders management. Some don’t use operating 

support on visa issues due to difficulties in project acquisition.  

Administrative burden, if any. 

  Need to establish simplified procedures at Union level, also across programmes. 
  All countries agree on the fact that most administrative burden derives from national rules and 

from heavy national procurement procedures. 

Extent to which the effects of the ISF-BV actions are achieved at a reasonable cost in terms of 
financial and human resources deployed. 

  Current costs are not effectively monitored by Responsible Authorities and COM, mainly due 

to administrative burden.  

  Too early to draw conclusions on this, given the long duration of the projects. 

Extent to which the Fund still covers needs and problems as evolved since its establishment in 
2014. 

  According to all countries, nothing is missing in terms of priorities, since the scope of the Fund 
is  broad  and  can  cover  the  Smart  Border  initiative.  However,  a  discussion  panel  on  border 
management to address mid-term review may be needed. 

  Need  to  develop  national  implementation  capacity,  since  many  challenges  derive  from  MS’s 

lack of management capacity.  

  The  area  of  competence  of  beneficiaries  is  limited,  and  thus  they  may  be  less  interested  in 

implementing projects with a wider scope. 

Sustainability measures. 

  All countries agree that ISF-BV projects are sustainable by nature. The main issues concern: 
  - the fact that staff turnover is very high and this entails the need to provide continuous training 

schemes. Training is a sustainable action as information and material is shared. 

  - IT-related projects may be not sustainable, since technology develops fast. 
  Proposal to share a booklet of good practices to improve sustainability. 

Coherence  and  complementarity.  All  countries  agree  on  the  need  of  mapping  potential 
overlapping and complementarity with other funds, during the designing phase of new financial 
instruments.  However,  MS  are  not  able  to  do  this  alone  and  suggest  that  COM  could  start  a 
mapping  of  all  funding  possibilities.  Moreover,  some  countries  suggest  creating  a  network  to 
standardise different eligible costs under different funds. 

  Added- value brought about by the EU support, if any. 
  According to all countries, without the support of the Fund, actions depending on year-to-year 

69 

 
 
 
 
 
 
 
 
national budget would have been financed and put in place with a smaller scale and scope, and 
later in time. ISF-BV stimulates a better management and acts as a good incentive to implement 
relevant actions (i.e. smart borders, IT systems). In some cases, the Fund helps implementing 
projects that bring benefits only on the long-term and thus are not a national political priority. 

Main problems during or with the implementation, if any. 

  Regulations  have  been  approved  too  late  at  the  EU  level.  Implementing  regulations  were 
actually not ready when approving some National Programmes. Some countries have set up a 
specialized unit on EU funding to effectively manage the allocated resources. 

  Some  have  set  up  a  specialised  bureau  of  border  guards  with  expertise  in  EU  project 

management. This had a very positive impact on the Fund’s implementation. 

  The  same  staff  members  and  beneficiaries  are  often  engaged  in  overlapping  issues  and  tasks, 

creating implementation delays. 

Measures  put  in  place  to  prevent,  detect,  report  and  follow-up  on  cases  of  fraud  and  other 
irregularities, if any. 

  No country present at the workshop has put in place special methods and measures to prevent, 

detect, and report frauds. 

70 

 
 
 
 
 
 
ANNEX 3: COST/BENEFIT ANALYSIS 

The  following  table  analyses  the  costs  incurred  by  the  various  actors  involved  in 
implementing ISF-BV, the target group, the beneficiaries, the national administrations and the 
EU.  These  costs  vary  from  the  administrative/indirect  or  compliance  costs  for  the 
beneficiaries,  to  the  administrative  costs  or  technical  assistance  for  the  RAs,  to  the  actual 
financial costs for the EU and to the human resources costs for all of the above. The analyses 
made were both qualitative and quantitative (including monetary analyses). 

Table 11: Overview of costs associated with the ISF-BV 

Target Group 

n/a 

Beneficiaries 
Admin 

EMAS and UAs, as well as indirect management actions have been achieved at reasonable financial costs. 
Most beneficiaries of EMAS and UAs consider the overall funding and administrative costs to be appropriate, 

as were the number of staff involved in the implementation. 

The procedures applicable to EMAS and UAs are simpler and quicker compared to shared management, and 
they allow for prompt and suitable interventions. This is particularly relevant in the case of EMAS, since 
national budgets are often shown not to be adequate to cope with emergencies. 

In  terms  of  allocations,  most  beneficiaries  consider  the  overall  funding  to  be  adequate,  also  because  it  is 
possible to ask for amendments to the grant agreements. Moreover, procurement procedures represent one 
of  the  main  components  that  ensure  the  efficient  achievement  of  results,  since  they  allow  the  most 
economical  offers  to  be  selected  —  complying  with  tender  specifications,  timeliness  of  deliveries,  and 
other relevant factors. 

Direct management: EUR 414 million (planned) — EUR 271 million (allocated) — EUR 17 million (spent). 
Indirect management: EUR 12 million (planned) — EUR 9.5 million (allocated) — EUR 0 million (spent). 

National administrations 
TA 

By 31 December 2016, Member States had spent a total amount of EUR 3.7 million overall out of the total of 

HR 

EUR 62 million, with the payment rate at 0.13 % and an implementation rate of 6 %.  

The  complexity  and  recurrence  of  reporting  requirements  entail  implementation  delays  and  administrative 
burden;  according  to  several  Member  States,  compared  to  the  previous  programming  period,  reporting 
requirements have considerably increased. 

TA costs and administrative costs of projects increased between 2015 and 2016, with a low decrease in 2017. 
According  to  available  data  (11  out  of  30  Member  States):  2015  EUR 1.17  million  (ratio=1.16);  2016 
EUR 6.78 million (ratio= 0.7); and 2017 EUR 6.68 million (ratio= 1.48). 

The Fund is efficient as regards the deployment of human resources. Some concerns emerged regarding the 
lack  of  knowledge,  expertise,  and  capacity  of  professionals  involved  at  national  level  in  managing  and 
implementing the Fund. 

On average, 7.08 FTEs have been involved in implementing the Fund and are  paid through TA or national 
budgets,  with  remarkable  differences  between  the  different  Member  States.  Overall,  considering  the 
average  number  of  projects  implemented  by  2017  (12.84),  an  average  of  0.55  FTEs  were  engaged  per 
project. 

Considering the ratio FTEs (average)/ amount of the funds claimed for the financial year (average), 0.5 FTEs 
have  been  involved  per  EUR  1  million  for  the  implementing  ISF-BV.  In  this  regard,  there  has  been  a 
significant decrease over the years, dropping from an average of 1.35 FTEs in 2014, to 0.72 in 2016, with a 
further decrease in 2017. On average, according to available data (11 out of 30 Member States) compared 
to 2016, the costs for FTEs have decreased by 0.2 % (EUR -222 198 per million); compared to 2015, the 
costs for FTEs have decreased by 0.3 % (EUR -854 935 per million). 

EU budget. By comparison, the total value of the AMIF is considerably higher (EUR 6 888 million). 

The total value of ISF-BV (EUR 2 609 million), although considerable, represents a small fraction of the total 

European Union 
Budget 
Commit 
Payments  Looking into each implementation mechanism individually: shared management shows a total payment rate 
of 6.38 %; direct management shows a total payment rate of 6.12 % (EMAS: 5.93 %; UAs; 0.19 %); and 
indirect management shows a total payment rate of 81 %. Therefore, both shared and direct management 
do  not  appear  to  be  on  track  to  being  fully  used.  Payments  made  so  far  amount  to:  shared  management 
EUR 178 million; direct management: EUR 171 million; and indirect management: EUR 8 million. 

71 

 
 
 
 
 
HR 

The  number  of  FTEs  dedicated  to  implementing  the  ISF  (both  Borders  and  Visa  and  Police)  has  increased 
over  the  period  2014-2017  as  well  as  the  related  costs.  Specifically,  in  2014  144  FTEs  were  involved 
(including 22 external personnel) out of a total of 322 the Commission staff. There has been a significant 
increase in this figure over recent years, rising from 153 FTEs (including 26 external personnel) in 2015 
(out of a total of 454 the Commission staff), to 162 (including 27 external personnel) in 2016 (out of a total 
of  480  the  Commission  staff).  There  was  a  further  increase  in  2017,  with  a  total  number  of  187  FTEs 
(including 32 external personnel), out of a total of 555 the Commission staff. 

Total costs: EUR 68 million. 
Costs related to HR dedicated to implementing the ISF have increased. Specifically, in 2014 costs amounted 
to  EUR 17.6  million  (including  EUR 1.6  million  for  external  personnel).  There  has  been  a  significant 
increase over recent years, rising from EUR 18.7 million (including EUR 2 million for external personnel) 
in 2015, to EUR 20 million (including EUR 2 million for external personnel) in 2016. In 2017, total costs 
currently stand at EUR 12 million, calculated as 50 % of total annual cost as the interim evaluation only 
covers the period up to 30 June 2017. 

The  following  table  analyses  the  benefits  gained  by  the  various  actors  involved  in 
implementing ISF-BV, the target group, the beneficiaries, the national administrations and the 
EU.  These  benefits  vary  from  intangible  such  as  knowledge  developed  or  capacity  built  to 
tangible  such  as  financial  support.  The  analyses  made  are  both  qualitative  and  quantitative 
(including monetary). 

Table 12: Overview of benefits brought by ISF-BV during 2015-2017 

Visa management — supports a common visa policy to (i) facilitate legitimate travel, a high quality 
of service to visa applicants as well as equal treatment of third-country nationals, and (ii) tackle 
illegal migration. Benefits: tangible (financial) and intangible (knowledge) 
Target Group 
Number of uniform visas issued: 13 860 218 
Number of uniform Schengen visas issued at BCPs: 99 473 
Number of uniform visas applied for in consulates: 15 003 765 
Number of uniform  visas  issued  in  consulates: 13 760 693, which,  includes  the  issuing  of  multiple  entry  uniform  visas: 

8 121 701; and of long-term visas: 95 759 

Number of uniform visas not issued in consulates: 1 034 248 
Beneficiaries 
The  Fund  contributed  towards  the  achievement  of  a  common  visa  policy.  It  helped  to  facilitate  legitimate  travel  across 
Europe, by co-financing projects aimed at strengthening the national capacity, ensuring the refurbishment of premises 
used for visa issuance and the procurement of security equipment for consular representations in third countries. The 
Fund  helped  to  ensure  the  correct  and  uniform  application  of  the  EU’s  acquis  on  visa,  indirectly  through  projects 
pursuing  other  objectives.  Moreover,  the  Fund  contributed  to  consular  harmonisation  through  measures  aimed  at 
improving the exchange of information and practices. Specifically, the establishment and operation of IT systems, with 
particular  regard  to  national  Visa  Information  System,  ensured  efficient  and  smoother  visa  processing  and  made  it 
possible to deal with the changing technical/legal requirements of the common visa policy, including the introduction of 
digital passports and related compliance checks. The development of a common visa policy was also supported through 
training for consular officials, police, Ministry of Interior officials and border guard officials. 

Number of consular cooperation activities developed with the Fund’s help: 4.  
number of staff trained in aspects related to the common visa policy with the Fund’s help: 2 240. 
National administrations 
Setting up of administrative structures and training for staff and relevant stakeholders 
Number of consulates developed or upgraded with the Fund’s help: 156 
Number of specialised posts in third countries (immigration liaison officers) supported by the Fund: 105 
Hours of training courses in aspects related to the common visa policy with the Fund’s help: 756 
European Union 

Support Border Management241:  

241   Section 6.3 (Section answering evaluation questions). 

72 

 
 
 
 
 
                                                 
strengthened integrated border management; 
uniform and high level of control and protection of external borders; and 
smooth crossing of the external borders in conformity with the Schengen acquis.  
Benefits: tangible (financial support to Member States authorities and provision of services to) and 
intangible (increased knowledge and awareness). 
Target Group 

Beneficiaries 
The Fund contributed towards an integrated border management. Although many Member States did not implement any 
actions specifically aimed at abolishing all checks on people crossing internal borders, interventions co-financed by the 
Fund  have  in  any  case  indirectly  contributed  to  this  objective.  ISF-BV  actions  were  aimed  at  boosting  the  border 
management  capacity  to  prevent  cross-border  crime  and  irregular  migration,  through  introducing  Automated  Border 
Control systems and the Public Key Directory, and using modern technical equipment for border surveillance such as (i) 
engineering  appliances  and  the  TETRA  communication  system;  (ii)  document  verification  devices;  (iii)  mobile 
scanning vehicles; (iv) mobile application for carrying out border checks and the purchasing of document readers for 
portable border control devices; and (v)  introducing biometric data. The Fund also helped to strengthen solidarity and 
responsibility  towards  an  integrated  external  borders  management  system  by  means  of  cooperation  among  Member 
States,  including  interventions  under  EUROSUR,  and  between  Member  States  and  Frontex.  Moreover,  the  Fund 
supported  the  application  of  the  EU’s  acquis  by  co-financing  training  activities  and  programmes,  which  helped  to 
improve the technical, operational, and even linguistic skills of staff responsible for border management. In addition, 
the Fund supported border management through adopting interoperable modern technologies in line with EU standards. 

Number of border crossings of the external borders through ABC gates supported through the Fund: 18 782 556 
Number of incidents reported by Member States to the European Situational Picture: 7 104 
Number of staff trained in aspects related to border management with the Fund’s help: 2 760 out of the 29 678 expected by 

national programmes 

National administrations 
Setting up of administrative structures and training for staff and relevant stakeholders. 
Number of border control (checks and surveillance) infrastructure and tools developed or upgraded with the Fund’s help: 

1 414. 

Number of national border surveillance infrastructure established/further developed under EUROSUR: 4. 
Number of training courses in aspects related to border management with the help of the Fund: 105 training hours — out 

of the 332 772 expected by national programmes. 

European Union 

Emergency situation — support Member States in substantiated emergency situations requiring 
urgent action. 
Benefits: improved operational capacities; means of transport, infrastructure, operating equipment 
and IT systems for better border management; support to staff, maintenance and repair costs; 
linguistic and intercultural mediation services. 
Target Group 

Beneficiaries 
EMAS actions are considered to be effective measures which can create positive impacts overall and enable actions to be 
implemented promptly and effectively in response to emergency situations. This is due to the presence of beneficiaries 
with high levels of competencies and expertise. 

EUR 256  million  (planned  resources)  —  EUR 245  million  (allocated)  —  EUR 165.6  million  (spent).  Payment  rate: 

5.93 %. 

improving operational capacities (27); 

45 EMAS actions put in place including those aimed at: 
 
  purchasing means of transport, infrastructure, operating equipment and IT systems for a better border management (8); 
  supporting staff, maintenance and repair costs (7); and  
 
National administrations 

improving linguistic and intercultural mediation services (3).  

European Union 

73 

 
 
 
 
 
 
 
ANNEX 4: EVALUATION QUESTIONS 

Effectiveness 
How  did  the  Internal  Security  Fund  (‘Fund’)  contribute  to  the  achievement  of  the  general 
objective defined in the Regulation (EU) No 515/2014? 
How did the Fund contribute to the achievement of the following specific objectives: Support 
a common visa policy to facilitate legitimate travel; Provide a high quality of service to visa 
applicants; Ensure equal treatment of third-country nationals and Tackle illegal migration? 

  What progress was made towards promoting the development and implementation of 
the common visa policy to facilitate legitimate travel, and how did the Fund contribute 
to achieving this progress? 

  What  progress  was  made  towards ensuring  better consular  coverage  and  harmonised 
practices on visa issuance between Member States, and how did the Fund contribute to 
achieving this progress? 

  What  progress  was  made  towards  ensuring  the  application  of  the  Union’s  acquis  on 

visas and how did the Fund contribute to achieving this progress? 

  What  progress  was  made  towards  Member  States’  contribution  to  strengthening  the 
cooperation between Member States operating in third countries as regards the flows 
of third-country national into the territory of Member States, including prevention and 
tackling  of  illegal  immigration,  as  well  as  the  cooperation  with  third  countries,  and 
how did the Fund contribute to achieving this progress? 

  What  progress  was  made  towards  supporting  the  common  visa  policy  by  setting  up 
and running IT systems, their communication infrastructure and equipment, and how 
did the Fund contribute to achieving this progress? 

  How did the operating support provided for in Article 10 of the Regulation (EU) No 
515/2014  contribute  to  the  achievement  of  the  specific  objective  on  common  visa 
policy? 

How  did  the  Fund  contribute  to  supporting  integrated  border  management,  including 
promoting further harmonisation of border management-related measures in accordance with 
common  Union  standards  and  through  the  sharing  of  information  between  Member  States, 
and  between  Member  States  and  the  European  Agency  for  the  Management  of  Operational 
Cooperation at the External Borders of the Member States of the European Union? How did 
the  Fund  contribute  to  ensuring,  on  one  hand,  a  uniform  and  high  level  of  control  and 
protection of external borders, including by tackling illegal immigration; on the other hand, 
the  smooth  crossing  of  the  external  borders  in  conformity  with  the  Schengen  acquis,  while 
guaranteeing access to international protection for those needing it, in accordance with the 
obligations  contracted  by  the  Member  States  in  the  field  of  human  rights,  including  the 
principle of non-refoulement? 

  What  progress  was  made  towards  promoting  the  development,  implementation  and 
enforcement of policies with a view to ensure the absence of any controls on persons 
when crossing the internal borders, and how did the Fund contribute to achieving this 
progress? 

  What  progress  was  made  towards  carrying  out  checks  on  persons  and  monitoring 
efficiently  the  crossing  of  external  borders,  and  how  did  the  Fund  contribute  to 
achieving this progress? 

74 

 
 
 
 
 
  What  progress  was  made  towards  gradually  establishing  an  integrated  management 
system  for  external  borders,  based  on  solidarity  and  responsibility,  and  how  did  the 
Fund contribute to achieving this progress? 

  What  progress  was  made  towards  ensuring  the  application  of  the  Union’s  acquis  on 

border management, and how did the fund contribute to achieving this progress? 

  What progress was made towards contributing to reinforcing situational awareness at 
the external borders and the reaction capabilities of Member States, and how did the 
Fund contribute to achieving this progress? 

  What  progress  was  made  towards  setting  up  and  running  IT  systems,  their 
communication  infrastructure  and  equipment  that  support  border  checks  and  border 
surveillance at the external borders, and how did the Fund contribute to achieving this 
progress? 

  How  did  the  operating  support  provided  for  in  Article 10  of  the  Regulation 
No 515/2014  contribute  to  the  achievement  of  the  specific  objective  on  border 
management? 

Efficiency 
Were the results of the Fund achieved at reasonable cost? 

  To what extent were  the expected results of the Fund achieved at reasonable cost in 

terms of deployed financial and human resources? 

  What measures were put in place to prevent, detect, report and follow-up on cases of 

fraud and other irregularities, and how did they perform? 

Simplification and reduction of administrative burden 
Were  the  management  procedures  of  the  Fund  simplified  and  the  administrative  burden 
reduced for its beneficiaries? 

  Did  the  innovative  procedures  introduced  by  the  Fund  (simplified  cost  option, 
multiannual  programming,  national  eligibility  rules,  more  comprehensive  national 
programmes allowing for flexibility, operating support and Special Transit Scheme for 
Lithuania) lead to simplification for the beneficiaries of the Fund? 

Relevance 
Did the objectives of the interventions funded by the Fund correspond to the actual needs? 

75 

 
 
 
 
 
  Did  the  objectives  set  by  Member  States  in  their  national  programmes  respond  to 

identified needs? 

  Which measures did Member State put in place to address changing needs? 

Coherence 
Were  the  objectives  set  in  the  national  programme  coherent  with  the  ones  set  in  other 
programmes  funded  by  EU  resources  and  applying  to  similar  areas  of  work?  Was  the 
coherence ensured also during the implementation of the Fund? 

  Was an assessment of other interventions with similar objectives carried out and taken 

into account during the programming stage? 

  Were coordination mechanisms between the Fund and other interventions with similar 
objectives established to ensure their complementarity for the implementing period? 
  Were the actions implemented through the Fund coherent with and non-contradictory 

to other interventions with similar objectives? 

  Do the Fund’s different instruments (national programmes, TA, UAs, EMAS) support 

each other? 

Complementarity 
Were  the  objectives  set  in  the  national  programme  and  the  corresponding  implemented 
actions complementary to those set in the framework of other policies — in particular those 
pursued by the Member State? 

  Was an assessment of other interventions with complementary objectives carried out 

and taken into account during the programming stage? 

  Were coordination mechanisms between the Fund and other interventions with similar 
objectives established to ensure their complementarity for the implementing period? 
  Were mechanisms aimed to prevent overlapping of financial instruments put in place? 

EU Added Value 
Was any EU added value brought about by the EU support? 

  What  are  the  main  types  of  added  value  resulting  from  the  support  of  the  Fund 

(volume, scope, role, process)? 

  Would  the Member State  have carried out the actions required to  implement the EU 

policies in the areas supported by the Fund without its financial support? 

  What  would  be  the  most  likely  consequences  of  an  interruption  of  the  support 

provided by the Fund? 

  To which extent have actions supported by the Fund resulted in a benefit at the Union 

level? 

  What was the EU added value of the operating support? 

Sustainability  
Are the positive effects of the projects supported by the Fund likely to last when its support 
will be over? 

  What  were  the  main  measures  adopted  by  the  Member  State  to  ensure  the 
sustainability of the results of the projects implemented with support of the Fund (both 
at programming and implementation stage)? 

76 

 
 
 
 
 
 
 
  Were  mechanisms  put  in  place  to  ensure  a  sustainability  check  at  programming  and 

implementation stage? 

  To  what  extent  are  the  outcomes/benefits  of  the  actions  sustained  by  the  Fund 

expected to continue thereafter? 

What measures were adopted to ensure the continuity of the activities carried out thanks to the 
operating support? 

77